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), 64432-64515 [E7-22040]
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Federal Register / Vol. 72, No. 220 / Thursday, November 15, 2007 / Proposed Rules
DEPARTMENT OF ENERGY
Office of Energy Efficiency and
Renewable Energy
10 CFR Parts 430 and 431
[Docket No. EE–2006–STD–0127]
RIN 1904–AB49
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)
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Advance notice of proposed
rulemaking and notice of public
meeting.
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AGENCY:
SUMMARY: The Energy Policy and
Conservation Act (EPCA or the Act)
authorizes the Department of Energy
(DOE) to establish energy conservation
standards for various consumer
products and commercial and industrial
equipment—including residential
dishwashers, dehumidifiers, and
electric and gas kitchen ranges and
ovens and microwave ovens (hereafter
referred to as ‘‘cooking products’’), as
well as commercial clothes washers—if
DOE determines that energy
conservation standards would be
technologically feasible and
economically justified, and would result
in significant energy savings. DOE is
publishing this advance notice of
proposed rulemaking (ANOPR) to
consider establishing energy
conservation standards for these
products and to announce a public
meeting to receive comments on a
variety of issues.
DATES: DOE will hold a public meeting
on December 13, 2007, starting at 9 a.m.
in Washington, DC. DOE must receive
requests to speak at the public meeting
no later than 4 p.m., November 29,
2007. DOE must receive a signed
original and an electronic copy of
statements to be given at the public
meeting no later than 4 p.m., December
6, 2007.
DOE will accept comments, data, and
information regarding the ANOPR
before or after the public meeting, but
no later than January 29, 2008. See
section IV, ‘‘Public Participation,’’ of
this ANOPR for details.
ADDRESSES: The public meeting will be
held at the Holiday Inn Capital, 550 C
Street, SW., DC 20024.
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Any comments submitted must
identify the ANOPR for Home
Appliance Products, and provide the
docket number EE–2006–STD–0127
and/or Regulatory Information Number
(RIN) 1904–AB49. Comments may be
submitted using any of the following
methods:
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• E-mail: home_
appliance.rulemaking@ee.doe.gov.
Include the docket number EE–2006–
STD–0127 and/or RIN 1904–AB49 in
the subject line of the message.
• Mail: Ms. Brenda Edwards-Jones,
U.S. Department of Energy, Building
Technologies Program, Mailstop EE–2J,
1000 Independence Avenue, SW.,
Washington, DC 20585–0121. Please
submit one signed paper original.
• Hand Delivery/Courier: Ms. Brenda
Edwards-Jones, U.S. Department of
Energy, Building Technologies Program,
Room 1J–018, 1000 Independence
Avenue, SW., Washington, DC 20585.
Telephone: (202) 586–2945. Please
submit one signed paper original.
For detailed instructions on
submitting comments and additional
information on the rulemaking process,
see section IV of this document (Public
Participation).
Docket: For access to the docket to
read background documents or
comments received, visit the U.S.
Department of Energy, Forrestal
Building, Room 1J–018 (Resource Room
of the Building Technologies Program),
1000 Independence Avenue, SW.,
Washington, DC, (202) 586–2945,
between 9 a.m. and 4 p.m., Monday
through Friday, except Federal holidays.
Please call Ms. Brenda Edwards-Jones at
the above telephone number for
additional information regarding
visiting the Resource Room. Please note:
DOE’s Freedom of Information Reading
Room (Room 1E–190 at the Forrestal
Building) no longer houses rulemaking
materials.
FOR FURTHER INFORMATION CONTACT:
Stephen Witkowski, U.S. Department of
Energy, Office of Energy Efficiency and
Renewable Energy, Building
Technologies, EE–2J, 1000
Independence Avenue, SW.,
Washington, DC 20585–0121, (202) 586–
7463. E-mail: stephen.witkowski
@ee.doe.gov.
Francine Pinto or Eric Stas, U.S.
Department of Energy, Office of the
General Counsel, Forrestal Building,
Mail Station GC–72, 1000 Independence
Avenue, SW., Washington, DC, 20585.
Telephone: (202) 586–9507. E-mail:
Francine.Pinto@hq.doe.gov or
Eric.Stas@hq.doe.gov.
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Regarding the public meeting, Brenda
Edwards-Jones, U.S. Department of
Energy, Building Technologies Program,
Room 1J–018, 1000 Independence
Avenue, SW., Washington, DC 20585.
Telephone: (202) 586–2945. E-mail:
Brenda.Edwards-Jones@ee.doe.gov.
SUPPLEMENTARY INFORMATION:
I. Introduction
A. Purpose of the Advance Notice of
Proposed Rulemaking
B. Overview of the Analyses Performed
1. Engineering Analysis
2. Energy and Water Use Characterization
3. Markups to Determine Equipment Price
4. Life-Cycle Cost and Payback Period
Analyses
5. National Impact Analysis
C. Authority
D. Background
1. History of Standards Rulemaking for
Residential Dishwashers, Dehumidifiers,
and Cooking Products; and Commercial
Clothes Washers
2. Current Rulemaking Process
3. Analysis Process
4. Miscellaneous Rulemaking Issues
a. Joint Stakeholder Recommendations
b. Standby Power for Dishwashers and
Cooking Products
5. Test Procedures
II. Analyses for the Four Appliance Products
A. Market and Technology Assessment
1. Product Classes
a. Dishwashers
b. Dehumidifiers
c. Cooking Products
d. Commercial Clothes Washers
2. Market Assessment
3. Technology Assessment
a. Dishwashers
b. Dehumidifiers
c. Cooking Products
d. Commercial Clothes Washers
B. Screening Analysis
1. Purpose
a. Technological Feasibility
b. Practicability To Manufacture, Install,
and Service
c. Adverse Impacts on Product Utility or
Product Availability
d. Adverse Impacts on Health or Safety
2. Design Options
a. Dishwashers
b. Dehumidifiers
c. Cooking Products
1. Cooktops and Ovens
2. Microwave Ovens
d. Commercial Clothes Washers
C. Engineering Analysis
1. Approach
2. Technologies Unable To Be Included in
the Engineering Analysis
3. Product Classes, Baseline Models, and
Efficiency Levels Analyzed
a. Dishwashers
b. Dehumidifiers
c. Cooking Products
d. Commercial Clothes Washers
4. Cost-Efficiency Results
a. Dishwashers
b. Dehumidifiers
c. Cooking Products
d. Commercial Clothes Washers
D. Energy Use and End-Use Load
Characterization
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1. Dishwashers
2. Dehumidifiers
3. Cooking Products
a. Cooktops and Ovens
b. Microwave Ovens
4. Commercial Clothes Washers
E. Markups To Determine Equipment Price
1. Distribution Channels
2. Approach for Manufacturer Markups
3. Approach for Retailer and Distributor
Markups
4. Sales Taxes
5. Summary of Markups
F. Rebuttable Presumption Payback Periods
G. Life-Cycle Cost and Payback Period
Analyses
1. Approach Taken in the Life-Cycle Cost
Analysis
2. Life-Cycle Cost Inputs
a. Total Installed Cost Inputs
b. Operating Cost Inputs
c. Effective Date
d. Equipment Assignment for the Base Case
3. Payback Period Inputs
4. Life-Cycle Cost and Payback Period
Results
H. Shipments Analysis
1. Shipments Model
2. Data Inputs
3. Shipments Forecasts
I. National Impact Analysis
1. Approach
2. Base Case and Standards Case
Forecasted Efficiencies
3. National Impact Analysis Inputs
4. National Impact Analysis Results
J. Life-Cycle Cost Subgroup Analysis
K. Manufacturer Impact Analysis
1. Sources of Information for the
Manufacturer Impact Analysis
2. Industry Cash Flow Analysis
3. Manufacturer Subgroup Analysis
4. Competitive Impacts Assessment
5. Cumulative Regulatory Burden
6. Preliminary Results for the Manufacturer
Impact Analysis
L. Utility Impact Analysis
M. Employment Impact Analysis
N. Environmental Assessment
O. Regulatory Impact Analysis
III. Candidate Energy Conservation Standard
Levels
IV. Public Participation
A. Attendance at Public Meeting
B. Procedure for Submitting Requests To
Speak
C. Conduct of Public Meeting
D. Submission of Comments
E. Issues on Which the Department of
Energy Seeks Comment
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1. Microwave Oven Standby Power
2. Product Classes
3. Commercial Clothes Washer Horizontal
Axis Designs
4. Compact Dishwashers
5. Microwave Oven Design Options
6. Technologies Unable To Be Analyzed
and Exempted Product Classes
7. Dishwasher Efficiency and Its Impact on
Cleaning Performance
8. Dehumidifier Use
9. Commercial Clothes Washer Per-Cycle
Energy Consumption
10. Commercial Clothes Washer Consumer
Prices
11. Repair and Maintenance Costs
12. Efficiency Distributions in the Base
Case
13. Commercial Clothes Washer Shipments
Forecasts
14. Base-Case and Standards-Case
Forecasted Efficiencies
15. Dehumidifier Cost and Efficiency
Relationships
16. Trial Standard Levels
V. Regulatory Review and Procedural
Requirements
VI. Approval of the Office of the Secretary
I. Introduction
A. Purpose of the Advance Notice of
Proposed Rulemaking
The purpose of this ANOPR is to
provide interested persons with an
opportunity to comment on:
1. The product classes that the
Department of Energy (DOE) is planning
to analyze in this rulemaking;
2. The analytical framework, models,
and tools (e.g., life-cycle cost (LCC) and
national energy savings (NES)
spreadsheets) DOE is using in
performing analyses of the impacts of
energy conservation standards for
residential dishwashers, dehumidifiers,
cooking products, and commercial
clothes washers (CCWs) (collectively
referred to in this ANOPR as ‘‘the four
appliance products’’);
3. The analyses performed for the
ANOPR, including in particular the
results of the engineering analyses, the
LCC and payback period (PBP) analyses,
and the NES and national impact
analyses, which are presented in the
ANOPR Technical Support Document
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(TSD): Energy Efficiency Standards for
Consumer Products and Commercial
and Industrial Equipment: Residential
Dishwashers, Dehumidifiers, And
Cooking Products And Commercial
Clothes Washers, 1 as summarized in
this ANOPR (2007 TSD); and
4. The candidate energy conservation
standard levels that DOE has developed
from these analyses.
B. Overview of the Analyses Performed
The Energy Policy and Conservation
Act (42 U.S.C. 6291 et seq.) directs DOE
to consider establishing or amending
energy conservation standards for
various consumer products and
commercial and industrial equipment,
including the four appliance products
which are the subject of this ANOPR.
For each of these products, DOE
conducted in-depth technical analyses
for this ANOPR in the following areas:
(1) Engineering, (2) energy and water
use characterization, (3) markups to
determine equipment price, (4) LCC and
PBP, (5) shipments, (6) national
impacts, and (7) preliminary
manufacturer impacts. The ANOPR
presents a discussion of the
methodologies and assumptions utilized
in these analyses. For each type of
analysis, Table I.1 identifies the sections
in this document that contain the results
of the analysis, and summarizes the
methodologies, key inputs, and
assumptions for the analysis. DOE
consulted with interested parties in
developing these analyses, and invites
further input from stakeholders on these
topics. Obtaining that input is the
purpose of this ANOPR. Thus, it should
be noted that the analytical results
presented here are subject to revision
following review and input from
stakeholders and other interested
parties. The final rule will contain the
final analytical results.
1 To be published on the DOE Web site at:
https://www.eere.energy.gov/buildings/appliance
_standards/residential/cooking_products.html
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TABLE I.1.—IN-DEPTH TECHNICAL ANALYSES CONDUCTED FOR THE ADVANCE NOTICE OF PROPOSED RULEMAKING
Analysis area
Engineering (TSD Chapter 5):
Dishwashers ...................
Dehumidifiers
Methodology
Key inputs
Efficiency level approach
supplemented with design
option analysis.
Component cost data; Performance values.
Cooking Products ...........
...............................................
...............................................
Commercial Clothes
Washers.
...............................................
...............................................
Establish per-cycle energy
and water use and then
multiply by annual cycles.
Energy and Water Use
Characterization
(TSD Chapter 6):
Dishwashers ...................
Section II.C.3.
Per-cycle energy and water
use; Average annual
usage of 215 cycles based
on DOE test procedure;
Variability of usage based
on Energy Information Administration (EIA)’s Residential Energy Consumption Survey (RECS).
Per-cycle energy and water
use; Average annual
usage of 1095 hours
based on AHAM estimates;
Variability of usage based
on multiple sources.
Recent survey data from
California and Florida—indicates a drop in annual
energy use of ~40% for
electric and gas ranges
and ~15% for microwave
ovens relative to DOE test
procedure estimates; Variability of usage based on
EIA’s RECS.
Per-cycle energy and water
use; Average daily usage
of 3.4 cycles for multi-family and 6 cycles for laundromats; Variability of
usage based on multiple
sources.
Per-cycle water use is a direct function of per-cycle
energy use (based on
AHAM data).
Section II.D.1.
Average usage of 1095
hours is representative of
dehumidifier use.
Section II.D.2.
Recent survey data are indicative of current household
cooking habits; Historical
data from DOE’s 1996
analysis on residential
cooking products are still
representative of component energy use (e.g., selfcleaning, clock, ignition).
Section II.D.3.
Per-cycle energy use data in
DOE’s 2000 TSD on residential clothes washers is
representative of per-cycle
drying and per-cycle machine energy for commercial washers.
Section II.D.4.
Assess financial data from:
(1) U.S. Securities and Exchange Commission (SEC)
reports on appliance manufacturers to develop manufacturer markups and (2)
the U.S. Census Business
Expenditure Survey to develop retailer and commercial distributor markups.
Use markups to transform
manufacturer costs into
consumer prices.
Distribution channels; SEC
reports on appliance manufacturers; U.S. Census
Business Expenditure Survey; State sales taxes;
Shipments to different
States.
Markups for baseline and
more-efficient equipment
are different.
Section II.E.
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Cooking Products ...........
Use recent survey data to
estimate annual energy
use.
Commercial Clothes
Washers.
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Establish daily energy use by
dividing product capacity
by efficiency and then multiply by annual hourly
usage.
Establish per-cycle energy
and water use and then
multiply by annual cycles.
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Analysis can be extended in
subsequent analyses to
product classes and efficiency levels for which the
Association of Home Appliance Manufacturers
(AHAM) did not provide
data.
Historical data from DOE’s
1996 analysis on residential cooking products are
still representative of current manufacturing costs.
Analysis can be extended to
energy and water efficiency levels for which
AHAM did not provide
data.
Dehumidifiers ..................
Markups to Determine
Equipment Price
(TSD Chapter 7):
Dishwashers ...................
Dehumidifiers
Cooking Products
Commercial Clothes
Washers.
Key assumptions
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TABLE I.1.—IN-DEPTH TECHNICAL ANALYSES CONDUCTED FOR THE ADVANCE NOTICE OF PROPOSED RULEMAKING—
Continued
Analysis area
Methodology
Key inputs
Key assumptions
Use Monte Carlo simulation
in combination with inputs
that are characterized with
probability distributions to
establish a distribution of
consumer economic impacts (i.e., LCC savings
and PBPs) that identify the
percent of.
Manufacturer costs; Markups
(including sales taxes); Installation costs; Annual energy (and water) consumption; Energy (and water)
prices and future trends;
Maintenance and repair
costs; Product lifetime; Discount rates.
Dehumidifiers ..................
...............................................
...............................................
Cooking Products ...........
...............................................
...............................................
Commercial Clothes
Washers.
...............................................
...............................................
Only 3% of consumers purchase dishwashers at existing minimum standards
(based on AHAM data);
Standards do not impact
repair and maintenance
costs; AEO2007 basis for
energy price forecasts; Average product lifetime is
12.3 years; Average discount rate is 5.6%.
Approximately 30% of consumers purchase dehumidifiers at existing minimum 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; Average discount rate is 5.6%.
For gas ranges, only 18 percent of consumers purchase equipment with
standing pilots; For electric
cooking products and
microwave ovens, 100 percent of consumer purchase
equipment at baseline levels; Average product lifetime is 19 years for electric
and gas ranges and 9
years for microwave
ovens; Standards do not
impact repair and maintenance costs; AEO2007
basis for energy price forecasts; Average discount
rate is 5.6%.
Approximately 80 percent of
consumers purchase
equipment at existing minimum 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; Discount rate can be estimated by company-weighted average cost of capital.
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LCC and PBP
(TSD Chapter 8):
Dishwashers ...................
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Shipments (TSD Chapter 9):
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II.G.4
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TABLE I.1.—IN-DEPTH TECHNICAL ANALYSES CONDUCTED FOR THE ADVANCE NOTICE OF PROPOSED RULEMAKING—
Continued
Analysis area
Dishwashers ...................
Dehumidifiers
Cooking Products
Commercial Clothes
Washers.
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National Impacts
(TSD Chapter 10):
Dishwashers ...................
Dehumidifiers
Cooking Products
Commercial Clothes
Washers.
Key inputs
Key assumptions
Forecast shipments through
the use of a product stock
accounting model by dividing market into segments—e.g., new construction, replacements, and
early replacements, or firsttime owners; Use increases in purchase price
and savings in operating
costs to forecast the impact of standards on shipments.
Historical shipments (for calibration purposes); Historical product saturations;
New construction forecasts; Survival functions
(based on product lifetimes); Sensitivity to ‘relative price,’ i.e., sensitivity
to the combined effect of
purchase price increases,
operating cost savings,
and household income.
Market segments are: new
construction, replacements,
and first-time owners (existing households without
the product); Sensitivity to
‘relative price’ is low.
Market segments are: replacements and first-time
owners; Sensitivity to ‘relative price’ is low.
Market segments are: new
construction, replacements,
and early replacements;
Sensitivity to ‘relative price’
is low.
Market segments are: new
construction and replacements; New construction
shipments driven by multifamily housing market only;
Sensitivity to ‘relative price’
is low.
II.H.3.
Forecast national annual energy (and water) use, national annual equipment
costs, and national annual
operating cost savings.
Annual forecasted shipments;
Forecasted base case and
standards case efficiencies; Per-unit annual
energy (and water) consumption, Per-unit total installed costs; Per-unit operating costs; Site-tosource conversion factors
for electricity and natural
gas; Discount rates; Effective date of standard; and
Present year.
Annual shipments from shipments model; Forecasted
base case and standards
case efficiencies remain
frozen at levels in the year
2012; National Energy
Modeling System (NEMS)
basis for site-to-source
conversion factors; Discount rates are 3 percent
and 7 percent real based
on Office of Management
and Budget (OMB) guidelines; Future costs discounted to present year:
2007.
Section II.I.4.
1. Engineering Analysis
The engineering analysis establishes
the relationship between the cost and
efficiency of a product DOE is
evaluating for standards. This
relationship serves as the basis for cost
and benefit calculations for individual
consumers, manufacturers, and the
Nation. The engineering analysis
identifies representative baseline
equipment, which is the starting point
for analyzing technologies that provide
energy efficiency improvements.
Baseline equipment here refers to a
model or models having features and
technologies typically found in
equipment currently offered for sale.
The baseline model in each product
class represents the characteristics of
products in that class, and, for products
already subject to energy conservation
standards, usually is a model that just
meets the current standard. After
identifying the baseline models, DOE
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Methodology
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estimates their manufacturing cost, after
which, DOE estimates the incremental
manufacturing costs for producing more
efficient equipment.
For dishwashers, dehumidifiers, and
CCWs, the engineering analysis uses
industry-supplied cost-efficiency data,
which are based on an efficiency-level
approach (which calculates the relative
costs of achieving increases in energy
efficiency levels), and cost-efficiency
curves that DOE derived based on a
design-option approach (which
calculates the incremental costs of
adding specific design options to a
baseline model). For kitchen ranges and
ovens (including microwave ovens),
DOE established cost-efficiency curves
using its 1996 Technical Support
Document for Residential Cooking
Products,2 updated to the present time
in the 2007 TSD for this rulemaking, as
discussed below. Some stakeholders
provided comments to DOE that the
design options and associated efficiency
increments were still valid for cooking
products other than microwave ovens.
For microwave ovens, DOE analyzed
current efficiency data to validate the
efficiency increments specified in the
1996 technical analysis, after which it
was determined that no changes to those
increments were necessary. To
determine manufacturing cost
increments, DOE, with the concurrence
of manufacturers, used producer price
index (PPI) data from the Bureau of
Labor Statistics (BLS) to scale costs
identified in the 1996 analysis to 2006$.
Section II.C on the engineering analysis
discusses this cost-efficiency
relationship, as well as the product
2 Available online at DOE’s website: https://
www.eere.energy.gov/buildings/
appliance_standards/residential/
cooking_products_0998_r.html.
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Federal Register / Vol. 72, No. 220 / Thursday, November 15, 2007 / Proposed Rules
classes analyzed, the representative
baseline units, and the methodology to
be used to extend the analysis to
product classes for which DOE did not
receive data
2. Energy and Water Use
Characterization
The energy use and water
characterization provides estimates of
annual energy and water consumption
for the four appliance products, which
DOE uses in the subsequent LCC and
PBP analyses and the national impact
analysis (NIA). DOE developed energy
consumption estimates for all of the
product classes analyzed in the
engineering analysis, as the basis for its
energy and water use estimates. In the
case of dishwashers, DOE used the
annual usage (in cycles per year)
established in its test procedure to
estimate the product’s annual energy
and water use. For dehumidifiers, DOE
relied on industry-supplied estimates of
annual usage (in hours per year) to
estimate the product’s annual energy
use. For kitchen ranges and ovens, the
2004 California Residential Appliance
Saturation Study (CA RASS) 3 and a
year-long monitoring study conducted
in 1999 by the Florida Solar Energy
Center (FSEC) 4 indicate that household
cooking has continued to drop since the
mid-1990s; DOE used these surveys as
the basis for estimating product annual
energy use. For CCWs, DOE used
industry-sponsored research to estimate
the product’s annual energy and water
use. For further details on the CCW
estimates, see section II.D.4 of this
ANOPR.
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3. Markups to Determine Equipment
Price
DOE derives consumer prices for
products based on manufacturer
markups, retailer markups (for
residential products), distributor
markups (for CCWs), and sales taxes. In
deriving these markups, DOE has
determined: (1) The distribution
channels for product sales; (2) the
markup associated with each party in
3 California Energy Commission. California
Statewide Residential Appliance Saturation Study,
June 2004. Prepared for the California Energy
Commission by KEMA–XENERY, Itron, and
RoperASW. Contract No. 400–04–009. https://
www.energy.ca.gov/appliances/rass/.
4 Parker, D. S. Research Highlights from a Large
Scale Residential Monitoring Study in a Hot
Climate. Proceeding of International Symposium on
Highly Efficient Use of Energy and Reduction of its
Environmental Impact, January 2002. Japan Society
for the Promotion of Science Research for the
Future Program, Osaka, Japan. JPS–RFTF97P01002:
pp. 108–116. Also published as FSEC–PF369–02,
Florida Solar Energy Center, Cocoa, FL. https://
www.fsec.ucf.edu/en/publications/html/FSEC-PF–
369–02/index.htm.
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the distribution channels, and (3) the
existence and magnitude of differences
between markups for baseline
equipment (‘‘baseline markups’’) and for
more-efficient equipment (‘‘incremental
markups’’). DOE calculates both overall
baseline and overall incremental
markups based on the product markups
at each step in the distribution channel.
It defines the overall baseline markup as
the ratio of consumer price (not
including sales tax) and manufacturer
cost for baseline equipment; the overall
incremental markup relates the change
in the manufacturer sales price of
higher-efficiency models (the
incremental cost increase) to the change
in the retailer or distributor sales price.
DOE determined manufacturer markups
through the use of U.S. Securities and
Exchange Commission (SEC) reports on
appliance manufacturers, and used U.S.
Census Business Expenditure Surveys to
develop retailer and commercial
distributor markups. DOE collected
consumer retail prices for each of the
four appliance products to provide a
rough validation of its markups for
baseline equipment. Baseline equipment
is produced in large volumes, is not
heavily laden with consumer features,
and is typically competitively priced by
retailers and distributors; therefore,
collected retail prices of baseline
equipment are likely to reflect the actual
cost of producing and selling
minimally-compliant products.
Because DOE’s approach for
calculating baseline retail prices
through the use of manufacturing costs,
baseline markups, and sales taxes are
intended to capture only the cost of
producing minimally-compliant
equipment, any collected baseline retail
prices serve as a good check on the
prices calculated through the markup
approach. But because more-efficient
equipment often includes non-energy
related features, DOE cannot rely solely
on collected retail prices for highefficiency products to validate the
prices determined through its markup
approach. Current retail prices for highefficiency equipment likely reflect the
added cost of consumer amenities that
have no impact on efficiency and,
therefore, mask the incremental price
associated with features that only affect
product efficiency.
4. Life-Cycle Cost and Payback Period
Analyses
The LCC and PBP analyses determine
the economic impact of potential
standards on individual consumers. The
LCC is the total consumer expense for
a product over the life of the product.
The LCC analysis compares the LCCs of
products designed to meet possible
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energy-efficiency standards with the
LCCs of the products likely to be
installed in the absence of standards.
DOE determines LCCs by considering:
(1) Total installed cost to the purchaser
(which consists of manufacturer costs,
sales taxes, distribution chain markups,
and installation cost); (2) the operating
expenses of the product (determined by
energy and water use, energy and water
prices, and repair and maintenance
costs); (3) product lifetime; and (4) a
discount rate that reflects the real
consumer cost of capital and puts the
LCC in present value terms.
The PBP represents the number of
years needed to recover the increase in
purchase price (including the
incremental installation cost) of moreefficient equipment through savings in
the operating cost of the product. It is
the change in total installed cost due to
increased efficiency divided by the
change in annual operating cost from
increased efficiency.
5. National Impact Analysis
The NIA estimates both the national
energy savings (NES) and the net
present value (NPV) of total customer
costs and savings expected to result
from new standards at specific
efficiency levels (referred to as
candidate standard levels). In
conducting the NIA, DOE calculated
NES and NPV for any given candidate
standard level for each of the four
appliance products as the difference
between a base case forecast (without
new standards) and the standards case
forecast (with standards). DOE
determined national annual energy
consumption by multiplying the
number of units in use (by vintage 5) by
the average unit energy (and water)
consumption (also by vintage).
Cumulative energy savings are the sum
of the annual NES determined over a
specified time period, which in the NIA
consisted of the range of years for which
the forecast was made. The national
NPV is the sum over time of the
discounted net savings each year, which
consists of the difference between total
operating cost savings and increases in
total installed costs. Critical inputs to
this analysis include shipments
projections, retirement rates (based on
estimated product or equipment
lifetimes), and estimates of changes in
shipments and retirement rates in
response to changes in product or
equipment costs due to standards.
5 The term ‘‘vintage’’ refers to the age of the unit
in years.
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C. Authority
Part B of Title III of EPCA established
the energy conservation program for
consumer products other than
automobiles, including dishwashers and
electric and gas kitchen ranges and
ovens (which include microwave
ovens). (This ANOPR refers to electric
and gas kitchen ranges and ovens and
microwave ovens collectively as
‘‘cooking products.’’) Amendments to
EPCA in the National Appliance Energy
Conservation Act of 1987 (Pub. L. 100–
12; NAECA) established energy
conservation standards for dishwashers
and cooking products, as well as
requirements for determining whether
these standards should be amended.
(See 42 U.S.C. 6295(g) and (h),
respectively) Subsequent amendments
expanded Title III of EPCA to include
additional consumer products and
certain commercial and industrial
equipment, including dehumidifiers
and CCWs. In particular, sections
135(c)(4) and 136(e) of the Energy Policy
Act of 2005, Public Law 109–58;
(EPACT 2005) amended EPCA to
authorize DOE to consider the need to
modify the energy conservation
standards that the Act, as amended,
prescribed for dehumidifiers (42 U.S.C.
6295(cc)) and for CCWs (42 U.S.C.
6313(e)), respectively. This includes
authority for DOE to amend the water
efficiency standard the Act, as amended,
prescribes for commercial clothes
washers.
Before DOE prescribes any new or
amended standard for any of the four
appliance products, however, it must
first solicit comments on a proposed
standard. Moreover, DOE must design
each new or amended standard for these
products to achieve the maximum
improvement in energy efficiency that is
technologically feasible and
economically justified, and such a
standard must also result in significant
conservation of energy. (42 U.S.C.
6295(o)(2)(A) and (o)(3); 42 U.S.C.
6316(a)) To determine whether a
proposed standard is economically
justified, DOE must, after receiving
comments on the proposed standard,
determine whether the benefits of the
standard exceed its burdens to the
greatest extent practicable, weighing the
following seven factors:
1. The economic impact of the
standard on manufacturers and
consumers of products subject to the
standard;
2. The savings in operating costs
throughout the estimated average life of
the covered products in the type (or
class) compared to any increase in the
price, initial charges, or maintenance
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expenses for the covered products
which are likely to result from the
imposition of the standard;
3. The total projected amount of
energy, or as applicable, water, savings
likely to result directly from the
imposition of the standard;
4. Any lessening of the utility or the
performance of the covered products
likely to result from the imposition of
the standard;
5. The impact of any lessening of
competition, as determined in writing
by the Attorney General, that is likely to
result from the imposition of the
standard;
6. The need for national energy and
water conservation; and
7. Other factors the Secretary of
Energy (Secretary) considers relevant.
(42 U.S.C. 6295(o)(2)(B)(i); 42 U.S.C.
6316(a))
D. Background
1. History of Standards Rulemaking for
Residential Dishwashers,
Dehumidifiers, and Cooking Products;
and Commercial Clothes Washers
For dishwashers, NAECA amended
EPCA to establish prescriptive
standards, requiring that dishwashers be
equipped with an option to dry without
heat, and further requiring that DOE
conduct two cycles of rulemakings to
determine if more stringent standards
are justified. (42 U.S.C. 6295 (g)(1) and
(4)) On May 14, 1991, DOE issued a
final rule establishing the first set of
performance standards for dishwashers
(56 FR 22250); the new standards
became effective on May 14, 1994 (10
CFR 430.32(f)). DOE initiated a second
standards rulemaking for dishwashers
by issuing an ANOPR on November 14,
1994 (59 FR 56423). However, as a
result of the priority-setting process
outlined in its Procedures for
Consideration of New or Revised Energy
Conservation Standards for Consumer
Products (the ‘‘Process Rule’’) (61 FR
36974 (July 15, 1996); 10 CFR part 430,
Subpart C, Appendix A), DOE
suspended the standards rulemaking for
dishwashers.
Section 135(c)(4) of EPACT 2005
added dehumidifiers as products
covered under EPCA and established
standards for them that will become
effective on October 1, 2007. (42 U.S.C.
6295(cc)) DOE has incorporated these
standards into its regulations (70 FR
60407, 60414 (October 18, 2005); 10
CFR 430.32(v)). The amendments to
EPCA also require that DOE issue a final
rule by October 1, 2009, to determine
whether these standards should be
amended. (42 U.S.C. 6295(cc)) If
amended standards are justified, they
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must become effective by October 1,
2012. (Id.) In the event that DOE fails to
publish such a final rule, the EPACT
2005 specifies a new set of amended
standards with an effective date of
October 1, 2012. (Id.)
As with dishwashers, NAECA
amended EPCA to establish prescriptive
standards for cooking products,
requiring gas ranges and ovens with an
electrical supply cord that are
manufactured on or after January 1,
1990 not to be equipped with a constant
burning pilot, and requiring DOE to
conduct two cycles of rulemakings for
ranges and ovens to determine if the
standards established should be
amended. (42 U.S.C. 6295 (h)(1)–(2))
DOE initially analyzed standards for
cooking products as part of an eightproduct standards rulemaking. It issued
a notice of proposed rulemaking (NOPR)
on March 4, 1994, proposing
performance standards for gas and
electric residential cooking products,
including microwave ovens (59 FR
10464). In accordance with the Process
Rule, DOE refined its standards analysis
for cooking products. For gas cooking
products, DOE focused on the economic
justification for eliminating constant
burning pilots. Partially due to the
difficulty of conclusively demonstrating
that elimination of constant burning
pilots was economically justified for gas
cooking products without an electrical
supply cord, DOE issued a final rule on
September 8, 1998, that covered only
electric cooking products, including
microwave ovens (63 FR 48038). The
final rule found that no standards were
justified for electric cooking products.
DOE never completed its standards
rulemaking for gas cooking products.
Similar to dehumidifiers, EPACT
2005 included amendments to EPCA
that added CCWs as covered equipment,
and it also established standards for
such equipment that is manufactured on
or after January 1, 2007. (EPACT 2005,
section 136(a) and (e); 42 U.S.C. 6311(1)
and 6313(e)) DOE has incorporated
these standards into its regulations (70
FR 60407, 60416 (October 18, 2005); 10
CFR 431.156). EPACT 2005 also requires
that DOE issue a final rule by January
1, 2010, to determine whether these
standards should be amended. (EPACT
2005, section 136(e); 42 U.S.C. 6313(e))
2. Current Rulemaking Process
To initiate the current rulemaking to
develop standards for the four appliance
products, on March 15, 2006, DOE
published on its Web site the
Rulemaking Framework for Commercial
Clothes Washers and Residential
Dishwashers, Dehumidifiers, and
Cooking Products (the Framework
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Document). The Framework Document
describes the procedural and analytic
approaches DOE anticipates using to
evaluate the establishment of energy
conservation standards for these
products. This document is available at:
https://www.eere.energy.gov/buildings/
appliance_standards/pdfs/
home_appl_framework_31506.pdf.
DOE subsequently published a notice
announcing the availability of the
Framework Document, inviting written
public comments to be submitted by
May 11, 2006, and announcing a public
meeting to discuss the proposed
analytical framework for this
rulemaking (71 FR 15059 (March 27,
2006)). At the April 27, 2006 public
meeting, DOE described the different
analyses it would conduct, such as the
LCC and PBP analyses, the methods
proposed for conducting them, and the
relationship among the various
analyses. Manufacturers, trade
associations, environmental advocates,
regulators, and other interested parties
attended the meeting. The major issues
discussed at the public meeting were:
(1) Relevance of the existing DOE test
procedure for microwave ovens; (2)
baseline unit definitions for the four
appliance products; (3) product classes
for the four appliance products; (4)
consideration of limiting standby power
as a design option for all four appliance
products; (5) technology options for
improving efficiency for all four
appliance products; (6) type of approach
to employ for the engineering analysis;
(7) efficiency levels to consider for all
four appliance products; (8) inclusion of
a water factor for dishwashers; (9)
consideration of cleaning performance
in setting dishwasher standards; (10)
implications of clothes container
volume on CCW efficiency; (11)
proposed approaches for specifying
typical annual energy and water
consumption for all four products; (12)
potential data sources for characterizing
variability in annual energy and water
consumption; (13) typical distribution
channels and markups for all four
appliance products; (14) data sources for
retail prices; (15) type of approach to
employ for the LCC and PBP analyses;
(16) variability of forecasted energy and
water prices; (17) repair, maintenance,
and installation cost relationship to
product efficiency; (18) product
lifetimes; (19) development of consumer
discount rates; (20) purchase price
impacts on product shipments; (21)
forecasted saturation rates of
commercial clothes washers; (22)
consumer subgroups; (23) water and
wastewater utility impacts; and (24)
wastewater discharge impacts.
Written comments submitted during
the Framework Document comment
period elaborated on the issues raised at
the meeting and also addressed other
major issues, including the following:
(1) Transparency of manufacturer cost
data development; (2) engineering data
availability for dishwashers, kitchen
ranges and ovens, and CCWs; and (3)
inclusion of embedded energy in
supplying water and treating
wastewater.
DOE developed two spreadsheet tools
for this rulemaking. The first tool
calculates LCC and PBPs. There are six
LCC spreadsheets, one each for the
following products: (1) Dishwashers, (2)
dehumidifiers, (3) cooktops, (4) ovens,
(5) microwave ovens, and (6) CCWs.
Each of the LCC spreadsheets includes
product efficiency distributions and has
the capability to determine LCC savings
and PBPs based on average values. The
spreadsheets also can be combined with
64439
Crystal Ball (a commercially available
software program) to generate a Monte
Carlo simulation, which incorporates
uncertainty and variability
considerations. The second tool (the
NIA spreadsheet tool) calculates the
impacts of candidate standards at
various levels on shipments and
calculates the NES and NPV at various
candidate standard levels. There are five
NIA spreadsheets, one each for the
following products and combinations of
products: (1) Dishwashers, (2)
dehumidifiers, (3) cooktops and ovens,
(4) microwave ovens, and (5) CCWs.
DOE posted these spreadsheets on its
Web site on December 4, 2006, for early
stakeholder review and comment.6
Comments received since publication
of the Framework Document have
helped identify issues involved in this
rulemaking, and have provided
information that has contributed to
DOE’s proposed resolution of these
issues. This ANOPR quotes and
summarizes many of these public
comments. A parenthetical reference at
the end of a quotation or paraphrase
provides the location of the item in the
public record.
3. Analysis Process
Table I.2 sets forth the analyses DOE
has conducted and intends to conduct
in its evaluation of standards for CCWs,
and residential dishwashers, cooking
products, and dehumidifiers. Until
recently, DOE performed the
manufacturer impact analysis (MIA) in
its entirety between the ANOPR and
NOPR during energy conservation
standards rulemakings. As noted in the
table, however, DOE has performed a
preliminary MIA for this ANOPR. DOE
believes this change will improve the
rulemaking process.
TABLE I.2.—THE FOUR APPLIANCE PRODUCTS—ANALYSIS PROCESS
NOPR
Market and technology assessment .......................................
Screening analysis ..................................................................
Engineering analysis ...............................................................
Energy use and end-use load characterization ......................
Markups for equipment price determination ...........................
Life-cycle cost and payback period analyses .........................
Shipments analysis .................................................................
National impact analysis.
Preliminary manufacturer impact analysis.
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ANOPR
Revised ANOPR analyses .....................................................
Life-cycle cost sub-group analysis.
Manufacturer impact analysis.
Utility impact analysis.
Net national employment impacts.
Environmental assessment.
Regulatory impact analysis.
The analyses listed in Table I.2 reflect
analyses used in the rulemaking,
including the development of economic
models and analytical tools. In addition,
in an effort to support groups of
interested parties seeking to develop
and present consensus
recommendations on standards, DOE
6 Available online at DOE’s Web site: https://
www.eere.energy.gov/buildings/
Final rule
appliance_standards/residential/
cooking_products.html
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Revised analyses.
posted draft versions of its LCC and NIA
spreadsheets on its Web site. If timely
new data, models, or tools that enhance
the development of standards become
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b. Standby Power for Dishwashers and
Cooking Products
Standby power is currently
incorporated into the energy factor 8
(EF) for conventional ovens via the
measurement of clock power
consumption and for gas cooktops via
the energy consumption of constant
burning pilots, both of which are
incorporated into the EF calculation for
their respective products. The
dishwasher test procedure includes a
measurement of standby power, but
standby energy use is not incorporated
into calculated EF. The issue of whether
to include standby power in the energy
efficiency metrics for dishwashers and
cooking products was addressed in
several comments that DOE received.
The Alliance to Save Energy, American
Council for an Energy-Efficient
Economy (ACEEE), Appliance
Standards Awareness Project, Natural
Resources Defense Council, and
Northeast Energy Efficiency
Partnerships (hereafter ‘‘Joint
Comment’’) stated that standby energy
use should be included in the analyses
for all products, with the appropriate
metric for the standards being annual
energy consumption rather than energy
factor. The Joint Comment stated that
EPACT 2005 instructs DOE to consider
standby power in its rulemaking for all
products, and where significant, to
include standby power in some fashion
into the appropriate standard. The Joint
Comment further stated that standby
energy use can be significant for clothes
washers, dishwashers, and microwave
ovens. (Joint Comment, No. 9 at p. 2)
For dishwashers, Potomac Resources
Inc. (Potomac) commented that it would
be useful to address standby power
directly through design options such as
the power supply. (Public Meeting
Transcript, No. 5 at p. 61) 9 ACEEE, EEI,
and Whirlpool Corporation (Whirlpool)
agreed that standby power is important
to include in the energy use
calculations, but EEI and Whirlpool
argued that individual system
components should not be regulated,
instead stating that standby power
should be addressed for the system as a
whole. (Public Meeting Transcript, No.
5 at pp. 62, 64, and 66) ACEEE
commented that if standby energy use is
determined to be significant, then DOE’s
analysis should include design options,
efficiency levels, or increased annual
energy consumption to capture
efficiency improvement opportunities.
7 A notation in the form ‘‘EEI, No. 7, p. 2’’
identifies a written comment that DOE has received
and has included in the docket of this rulemaking.
This particular notation refers to a comment (1) by
the Edison Electric Institute, (2) in document
number 7 in the docket of this rulemaking, and (3)
appearing on page 2 of document number 7.
8 Energy factor (EF) is a measure of the energy
consumption required by the product under the
conditions of the DOE test procedure. The units of
EF vary depending on the product. For example, the
EF for dishwashers is expressed in cycles/kWh,
while the EF for dehumidifiers is in liters/kWh.
9 A notation in the form ‘‘Public Meeting
Transcript, No. 5 at p. 61’’ identifies an oral
comment that DOE received during the April 27,
2006, Framework public meeting and which was
recorded in the public meeting transcript in the
docket for this rulemaking (Docket No. EE–2006–
STD–0127), maintained in the Resource Room of
the Building Technologies Program. This particular
notation refers to a comment (1) made during the
public meeting, (2) recorded in document number
5, which is the public meeting transcript that is
filed in the docket of this rulemaking, and (3) which
appears on pages 61 of document number 5.
available, DOE will incorporate them
into this rulemaking.
4. Miscellaneous Rulemaking Issues
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a. Joint Stakeholder Recommendations
The Edison Electric Institute (EEI)
suggested that DOE should use a
negotiated rulemaking process for
residential dishwashers and cooking
equipment, because manufacturers
appear to want regulatory certainty for
these products. EEI suggested a separate
negotiated process for CCWs because
these products are designed for a
different market. For dehumidifiers, EEI
suggested DOE analyze the standards
identified in EPACT 2005 that are due
to become effective in 2012, and if they
are technically feasible, economically
justified, and will not reduce
competition, consider a negotiated
rulemaking so that standards can be
issued before the October 1, 2009
deadline mandated by EPACT 2005.
(EEI, No. 7 at p. 2) 7
The Process Rule specifically
identifies ‘‘consensus proposals for new
or revised standards as an effective
mechanism for balancing the economic,
energy, and environmental interests
affected by standards. Thus,
notwithstanding any other policy on
selection of proposed standards, a
consensus recommendation on an
updated efficiency level submitted by a
group that represents all interested
parties will be proposed by DOE if it is
determined to meet the statutory
criteria.’’ (10 CFR Part 430, Appendix A
to Subpart C, section 5(e)(2)). Therefore,
DOE encourages the submittal of any
consensus proposals or joint stakeholder
recommendations pertaining to any or
all of the four appliance products. If the
supporting analyses provided by the
group address all of the statutory criteria
and use valid economic assumptions
and analytical methods, DOE expects to
use these supporting analyses as the
basis of a proposed rule.
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(Public Meeting Transcript, No. 5 at p.
64) ACEEE, the Association of Home
Appliance Manufacturers (AHAM), and
Whirlpool stated that if DOE
incorporates standby power into the
efficiency standard, it should do this
through maximum annual energy usage
rather than a prescriptive standby power
level. These commenters argued that
such an approach would allow
manufacturers flexibility in meeting the
standard. (Public Meeting Transcript,
No. 5 at p. 125; AHAM, No. 14 at p. 8;
Whirlpool, No. 10 at p. 8) Whirlpool
further commented that if standby
power is included in annual energy
consumption, DOE should add 8.5
kilowatt-hours (kWh) to the standard,
equating to one watt standby power per
covered appliance over the course of a
year. In addition, Whirlpool argued that
standby power should not be driven so
low that it impacts the adoption of
electronics that can shift start times to
off-peak periods. (Whirlpool, No. 10 at
p. 8)
In response to the comments, we note
that the analysis DOE conducted for
dishwashers does not explicitly
consider design options to reduce
standby energy consumption. DOE
conducted the engineering analysis to
capture the costs associated with
improving EF only. The cost data
AHAM provided and the product
teardowns did not specifically account
for changes in standby power. The LCC
analysis, however, does account for
standby power in the calculation of
annual energy consumption. The LCC
assumes a baseline standby power draw
of two watts, totaling 17 kWh of annual
energy consumption. DOE assumes this
same consumption level at all EF
values. If technologies to decrease
standby power consumption are
determined to be a significant source of
energy savings and are technologically
feasible and economically justified, DOE
plans to consider standby power as part
of an overall energy efficiency standard
focusing on maximum annual energy
usage, rather than a separate standby
power level, in order to allow
manufacturers maximum flexibility in
specifying features and design options
while still remaining below a certain
annual energy consumption level. As
one approach, DOE tentatively believes
that a reduction in the two-watt baseline
standby power level could be reflected
in a corresponding reduction in annual
energy usage, which could be modeled
for the purposes of this analysis as an
equivalent change in EF. DOE seeks
comment on the specification of annual
energy usage as the metric for
dishwasher standards.
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ACEEE commented during the
Framework public meeting that the use
of standby power needs to be
considered for all cooking products.
(Public Meeting Transcript, No. 5 at p.
91) AHAM recognized that standby
power consumption is essentially
already included in the test procedure
for ovens and cooktops; however, for
microwave ovens, a test procedure
revision would be required. (Public
Meeting Transcript, No. 5 at p. 92)
AHAM also stated that manufacturers
(driven by consumer/market desires)
want the flexibility to produce
microwave ovens with different
displays, and, thus, different levels of
standby power consumption, in order to
provide products with market
differentiation. Therefore, AHAM
recommended that standby power not
be considered as a separate prescriptive
requirement, but instead, if regulated,
standby power should be incorporated
in an annual energy consumption metric
(AHAM, No. 17 at p. 4). Contrary to
these views, GE Consumer & Industrial
(GE) opposed incorporating standby
power into efficiency standards because
that would result in a determination of
higher energy consumption under the
regulation for ‘‘intelligent’’ appliances.
(GE, No. 13 at p. 4)
DOE added low-standby-power
electronic controls as design options for
both standard and self-cleaning gas
ovens, as well as for both standard and
self-cleaning electric ovens. However, it
did not include these design options
when setting overall efficiency levels for
these products because DOE does not
have efficiency improvement or
incremental cost information on them.
DOE is seeking data to conduct this
analysis and requests stakeholder
comment on this issue.
AHAM provided data on microwave
standby power for a sample of 21
microwave ovens available in the U.S.
market. For the AHAM submission,
standby power was tested in accordance
with International Electrotechnical
Commission (IEC) 62301–2005,
Household electrical appliances—
Measurement of standby power. These
data show a wide range of standby
power use. Microwave oven standby
power consumption is understood to be
a function of the digital clock display,
with more complex graphical displays
drawing more power. AHAM did not
provide the type of oven characteristics
information which could provide more
insight into the factors affecting standby
power or the costs associated with
reducing the standby energy
consumption.
For the NOPR analysis, DOE is
considering purchasing, testing, and
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18:25 Nov 14, 2007
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analyzing microwave ovens to better
understand the utility, cost, and cost
implications of reducing standby power
consumption. Addition of a standby
power test to the existing test procedure
would be necessary before standby
power could be included in an
efficiency standard. DOE intends to
modify the test procedure accordingly
because it believes that standby power
represents a significant portion of
microwave oven annual energy usage.
According to the DOE test procedure,
the annual useful cooking energy output
of a microwave oven is 79.8 kWh. For
a baseline microwave oven with an
efficiency of 55.7 percent, annual energy
consumption for cooking processes is
143.3 kWh. Each watt of standby power
represents an additional 8.76 kWh per
year, or 6 percent of the annual cooking
energy consumption. AHAM-supplied
data demonstrated a wide variation in
existing standby power levels, with
values ranging between 1.5 and 5.8
watts, such that the likely impact of a
standard would be significant. DOE will
conduct testing and teardown analysis
in support of the test procedure NOPR
to incorporate standby power. DOE
plans to complete the test procedure
change prior to publishing the NOPR for
this standard-setting rulemaking.
DOE specifically seeks data and
stakeholder feedback on how to conduct
an analysis of standby power for
microwave ovens. This is identified as
Issue 1 under ‘‘Issues on Which DOE
Seeks Comment’’ in section IV.E of this
ANOPR.
5. Test Procedures
A test procedure outlines the method
to determine the energy efficiency and
annual energy use of products and
equipment, and it is used as the basis
for representation and determination of
compliance with energy conservation
standards. Section 7(b) of the Process
Rule provides that DOE will propose
necessary modifications to the test
procedures for a product before issuing
an ANOPR concerning energy
conservation standards for that product.
Section 7(c) of the Process Rule states
that DOE will issue a final modified test
procedure prior to issuing a proposed
rule for energy conservation standards.
DOE has established test procedures
for each of the four appliance products
subject to today’s notice. DOE last
revised its test procedures for cooking
products in 1997, to make several
revisions to more accurately measure
the efficiency of these products (62 FR
51976 (Oct. 3, 1997); 10 CFR part 430,
Subpart B, Appendix I). Similarly, in
2003, DOE revised its test procedures
for dishwashers to more accurately
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measure their efficiency, as well as their
water use (68 FR 51887 (Aug. 29, 2003);
10 CFR part 430, Subpart B, Appendix
C). At this time, DOE does not expect to
make further changes to the dishwasher
test procedure.
EPACT 2005 amended EPCA to
require that CCWs be rated according to
the same test procedures established for
residential clothes washers. (EPACT
2005, section 136(f); 42 U.S.C.
6314(a)(8)) DOE adopted those test
procedures for CCWs in its final rule
published on October 18, 2005 (70 FR
60407, 60416). EPACT 2005 also
amended EPCA to specify that the U.S.
Environmental Protection Agency (EPA)
test criteria used under the Energy Star
Program must serve as the basis for
DOE’s test procedure for dehumidifiers.
(EPACT 2005, section 135(b); 42 U.S.C.
6293(b)(13)) The Energy Star test criteria
for dehumidifiers require that American
National Standards Institute (ANSI)/
AHAM Standard DH–1–2003,
Dehumidifiers, be used to measure
energy use during capacity-rating tests,
and that the Canadian Standards
Association (CAN/CSA) standard CAN/
CSA–C749–1994 (R2005), Performance
of Dehumidifiers, be used to calculate
the energy factor. DOE has adopted
these test criteria, along with related
definitions and tolerances, as its test
procedure for dehumidifiers (71 FR
71340, 71347, 71366, 713667–68 (Dec.
8, 2006); 10 CFR part 430, Subpart B,
Appendix X).
DOE received comments pertaining to
its test procedures for kitchen ranges
and ovens and CCWs. With regard to
kitchen ranges and ovens, Wolf
Appliance Company, LLC , an affiliate
of Sub-Zero Freezer Company, Inc.
(Wolf), and Whirlpool suggested that
DOE modify its test procedure for
residential kitchen ranges and ovens
because it is inadequate for measuring
the energy use of certain product
characteristics and features.
Specifically, Wolf stated that the current
test procedure does not accurately
measure the performance and efficiency
of several components (such as larger
burner rings, heavier burner grates, and
high performance convection systems).
(Wolf, No. 6 at p. 1) Whirlpool stated
that the current test procedure does not
measure energy consumption as a
function of oven cavity size, does not
address the fundamental differences in
commercial-type products 10 versus
more traditional residential cooking
products, and does not recognize that
10 Commercial-type cooktops and ovens are
characterized by higher burner firing rates, larger
dimensions, and heavier components than typical
residential cooking products.
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gas surface burner efficiency is a
function of the burner rate. Whirlpool
added that the microwave oven test
procedure does not account for the
variation in the product’s size and
wattage, both of which affect microwave
oven energy consumption. (Whirlpool,
No. 10 at p. 6) With regard to CCWs,
Whirlpool noted that commercial
laundry practices differ from the more
familiar residential practices in several
key respects (e.g., the test procedure
assumes that a modest eight-pound load
will be used, but commercial washers
typically are filled with a larger load).
(Whirlpool, No. 10 at p. 3)
In response, DOE recognizes that
there may be issues with its test
procedures for measuring the energy use
impacts of the cooking product
characteristics noted by Wolf and
Whirlpool. However, with the exception
of standby power consumption for
microwave ovens, DOE does not intend
to initiate rulemakings to modify its test
procedures for appliances covered by
this rulemaking, before finalizing
amended energy conservation
standards, for the reasons that follow.
DOE intends to initiate a test procedure
modification for microwave ovens to
include standby power consumption
because the data received from AHAM
indicates that standby power represents
a significant portion of annual energy
usage and because the data shows a
wide spread in current standby power
levels. DOE does not plan a test
procedure change for conventional
ovens because the oven test procedure
already measures standby power in the
form of clock power and, for standard
gas ovens, the pilot light. For cooktops,
DOE does not believe that standby
power not already captured in the test
procedure represents a significant
portion of annual energy consumption.
Gas cooktops already measure the
energy consumption of standing pilots,
which for the baseline configuration are
assumed to consume 600 kWh annually
and which are in addition to the annual
cooking energy consumption. In
comparison, each watt of standby power
consumes 8.76 kWh annually. For
electric cooktops, DOE does not have
any data on standby power
consumption that indicate the potential
for significant energy savings. Therefore,
a test procedure change to measure
standby power for cooktops would not
be warranted. With regard to CCWs,
although for efficiency rating purposes
CCWs use the residential clothes washer
test procedure, DOE’s methods for
characterizing the energy and water use
for commercial washers (as described in
section II.D.4) accounted for the
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consumer usage patterns specific to this
product.
DOE specifically seeks data and
stakeholder feedback on the decision to
retain the existing test procedures for
appliances covered under this
rulemaking other than microwave
ovens. This is identified as Issue 6
under ‘‘Issues on Which DOE Seeks
Comment’’ in section IV.E of this
ANOPR.
II. Analyses for the Four Appliance
Products
This section addresses the analyses
DOE has performed and intends to
perform for this rulemaking. For each
product covered by this rulemaking (i.e.,
residential dishwashers, dehumidifiers,
and cooking products, and CCWs), DOE
will perform a set of separate analyses,
including a market and technology
assessment, a screening analysis, an
engineering analysis, an energy use and
water use characterization, LCC and
PBP analyses, a shipments analysis, a
NIA, and a MIA. A separate sub-section
addresses each type of analysis, which
contains a general introduction that
describes the analysis and a discussion
of related comments received from
interested parties.
A. Market and Technology Assessment
When DOE begins a standards
rulemaking, it develops information that
provides an overall picture of the
market for the products concerned,
including the nature of the product, the
industry structure, and market
characteristics for the product. This
activity consists of both quantitative and
qualitative efforts based primarily on
publicly available information. The
subjects addressed in the market and
technology assessment for this
rulemaking include product classes,
baseline units, technologies for design
options, manufacturers, quantities and
types of products sold and offered for
sale, retail market trends, industry cost
structure, and regulatory and nonregulatory programs. This information
serves as resource material throughout
the rulemaking.
1. Product Classes
In general, when evaluating and
establishing energy efficiency standards,
DOE divides covered products into
classes by: (1) The type of energy used,
and (2) capacity or other performancerelated features that affect consumer
utility and efficiency. Different energy
conservation standards may apply to
different product classes. The following
describes and discusses the product
classes DOE plans to use in this
rulemaking.
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a. Dishwashers
For dishwashers, the size of the unit
significantly affects the amount of
energy consumed due to the
corresponding amount of water heating
required. In other words, standard-sized
dishwashers with relatively greater
water consumption have significantly
greater energy use than compact units.
Because standard dishwashers offer
enhanced consumer utility over
compact units (i.e., the ability to wash
more dishes), DOE has established the
following product classes, which are
based on the size of the dishwasher (as
specified in ANSI/AHAM Standard
DW–1–2005, Dishwashers):
• Compact (capacity less than eight
place settings plus six serving pieces);
and
• Standard (capacity equal to or
greater than eight place settings plus six
serving pieces).
AHAM and EEI both commented that
the two product classes are appropriate
for the analysis. (Public Meeting
Transcript, No. 5 at p. 55; AHAM, No.
14 at p. 8; EEI, No. 7 at p. 3) Potomac,
however, suggested that the standard
product class should be disaggregated to
at least several product classes based on
place-setting capacity. (Public Meeting
Transcript, No. 5 at pp. 61–62).
American Rivers, Association of
Metropolitan Water Agencies, Austin
Water Utility, California Urban Water
Conservation Council, East Bay
Municipal Utility District, and Seattle
Public Utilities (hereafter ‘‘Multiple
Water Organizations’’) recommended
that one or more new product classes be
defined in addition to compact and
standard sizes, which would allow
flexibility for manufacturers to make
smaller or larger machines. According to
the Multiple Water Organizations,
consumers would then be encouraged to
wash full dishwasher loads rather than
partial or multiple loads. (Multiple
Water Organizations, No. 11 at p. 2)
DOE notes that current dishwasher
models include single- and two-drawer
units as well as dishwashers that
provide a user-selectable option for
upper-or lower-rack-only washing to aid
in running optimal load sizes.
Therefore, DOE believes the current two
product classes offer adequate flexibility
in terms of dishwasher loading to
maintain consumer utility and wash
performance for different load sizes.
Thus, additional product classes are not
warranted.
b. Dehumidifiers
EPACT 2005 sets energy conservation
standards for dehumidifiers based on
the capacity of the unit as measured in
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pints of water extracted per day.
(EPACT 2005, section 135(c); 42 U.S.C.
6295(cc)) Specifically, for units
manufactured on or after October 1,
2007, EPACT 2005 sets a separate
standard for dehumidifiers in each of
the following five categories: (1) 25.00
pints/day or less, (2) 25.01–35.00 pints/
day, (3) 35.01–54.00 pints/day, (4)
54.01–74.99 pints/day, and (5) 75.00
pints/day or more. (Id.) EPACT 2005
also prescribes more stringent energy
conservation standards that would go
into effect if DOE fails to issue amended
standards that apply to products
manufactured on or after October 1,
2012. (Id.) In prescribing these
standards, EPACT 2005 subdivides the
35.01–54.00 pints/day category into two
categories: 35.01–45.00 pints/day and
45.01–54.00 pints/day. Therefore, in
accordance with EPACT 2005
amendments to EPCA, DOE is using the
following product classes for
dehumidifiers:
• 25.00 pints/day or less;
• 25.01–35.00 pints/day;
• 35.01–45.00 pints/day;
• 45.01–54.00 pints/day;
• 54.01–74.99 pints/day; and
• 75.00 pints/day or more.
During the Framework public meeting
and Framework comment period,
stakeholders differed as to appropriate
specifications for the product classes for
dehumidifiers. EEI asked whether a
distinction should be made between
fixed and portable dehumidifers. (EEI,
No. 7 at p. 3) AHAM opposed EEI’s
suggestions, expressing a preference for
the product classes as identified in
EPACT 2005. (Public Meeting
Transcript, No. 5 at p. 70; AHAM, No.
14 at p. 9)
While fixed and portable
dehumidifiers offer different utility in
terms of ease of installation and
flexibility in location, DOE is unaware
of any dehumidification performance
differences. Therefore, DOE has
determined that additional product
classes are not warranted based on
portability, and for the purpose of this
rulemaking, DOE intends to maintain
the dehumidifier product classes as
defined by EPACT 2005 (i.e., a ‘‘selfcontained, electrically operated, and
mechanically encased assembly’’).
(EPACT 2005, section 135(a); 42 U.S.C.
6291(34))
DOE also received comments that
baseline unit characteristics for
dehumidifiers may not be possible to
establish since EPACT 2005 will not
come into effect until October 1, 2007.
DOE performed its engineering analysis
across a wide range of unit capacities
and efficiencies to capture as complete
a picture of the 25–75 pints/day
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dehumidifier market as possible. In
total, DOE has disassembled and
analyzed 14 dehumidifiers to date.
Furthermore, DOE used market and
technology assessment research and
consulted with numerous stakeholders
to determine basline unit
characteristics. (Refer to Chapters 3 and
5 of the TSD for further details.) DOE
intends to use EPACT 2005-compliant
dehumidifiers as a baseline since
manufacturers are already modifying
any non-compliant product they have to
meet this new minimum energy
efficiency level.
c. Cooking Products
For cooking products, DOE based its
product classes on energy source (i.e.,
gas or electric) and cooking method (i.e.,
cooktops, ovens, and microwave ovens).
DOE identified five categories of
cooking products:
• Gas cooktops;
• Electric cooktops;
• Gas ovens;
• Electric ovens; and
• Microwave ovens.
In its regulations implementing EPCA,
DOE defines a ‘‘conventional range’’ as
‘‘a class of kitchen ranges and ovens
which is a household cooking appliance
consisting of a conventional cooking top
and one or more conventional ovens.’’
10 CFR 430.2. In this rulemaking, DOE
is not treating gas and electric ranges as
a distinct product category and is not
basing its product classes on that
category. Because ranges consist of both
a cooktop and oven, any potential
cooktop and oven standards would
apply to the individual components of
the range. As a result, product classes
for ranges, for the purpose of standardssetting, are not warranted.
This general approach for defining
product classes was validated in
comments received after the Framework
public meeting. EEI stated that the
product classes are appropriate. (EEI,
No. 7 at p. 3) Wolf stated that the
burden of considering new product
classes since the previous rulemaking
(including modification of existing test
procedures) is not justified by the small
potential energy savings. (Wolf, No. 6 at
p. 2)
DOE also received comments during
the Framework public meeting and
subsequent comment period questioning
whether DOE should consider for
analysis product classes for cooking
products with small shipment volumes.
Whirlpool noted that the rationale for
excluding certain product classes from
analysis in the previous rulemaking
(e.g., grills, griddles, induction
cooktops, and warming/simmering
burners) was based upon consideration
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of factors such as the lack of an
appropriate test procedure, the niche
nature of those products, and the small
amount of empirical data. Since these
conditions still remain today, Whirlpool
commented that DOE should not
analyze these classes. (Whirlpool, No.
10 at p. 5) Wolf stated during the
Framework public meeting that product
classes that were not analyzed in the
prior rulemaking need to be considered
in this standards rulemaking. (Public
Meeting Transcript, No. 5 at p. 84) DOE
is not aware of any data upon which to
determine the measurement of energy
efficiency or energy efficiency
characteristics of products in these
niche classes. Therefore, DOE will not
conduct analyses on product classes
that were identified but excluded in the
previous rulemaking. DOE seeks
efficiency data and inputs to
characterize any limitations of the test
procedure for these product classes.
This topic is identified as Issue 6 under
‘‘Issues on Which DOE Seeks Comment’’
in section IV.E of this ANOPR.
The single product class that DOE
proposes to use for gas cooktops is gas
cooktops/conventional burners, in
accordance with the previous
rulemaking.
AHAM commented that if DOE
decides to proceed with further analysis
of cooking products, DOE should
include an additional product class for
high-performance, commercial-style
products. AHAM stated that the unique
utility and performance attributes
associated with high-performance
cooking products must be recognized
and allowed to continue under the ‘‘safe
harbor’’ provisions of NAECA, which
prevent Federal energy efficiency
standards from resulting in the
unavailability of product types, classes,
performance characteristics, and other
key aspects of the product that are
currently available. (42 U.S.C. 6295
(o)(4)) Due to test procedure
complexities and small market share,
AHAM recommends that DOE exempt
high-performance, commercial-style
residential cooking products. (AHAM,
No. 14 at p. 2) DOE received additional
comments specifically regarding
commercial-type ranges. These
comments are discussed in the context
of gas cooktops, although it should be
recognized that similar responses apply
to the oven component of the range as
well. During the Framework public
meeting, EEI suggested a need to
establish the market share of
commercial-type ranges for this
rulemaking. (Public Meeting Transcript,
No. 5 at p. 81) Both AHAM and Wolf
stated that commercial-type ranges
warrant a separate product class. (Public
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Meeting Transcript, No. 5 at pp. 84 and
86). Wolf further elaborated in the
comment period after the Framework
public meeting that the unique utility
and performance attributes of
commercial-type ranges (explained
below) justify a separate product class.
(Wolf, No. 6 at p. 1) DOE considers
commercial-style ranges to be those
products which incorporate gas
cooktops with higher input rate burners
(i.e., greater than 14,000 Btu/h) and
heavy-duty grates that provide faster
cooking and the ability to cook larger
quantities of food in larger cooking
vessels. The burners are optimized for
the larger-scale cookware to maintain
high cooking performance. Similarly,
DOE considers commercial-style ovens
to have higher input rates (i.e., greater
than 22,500 Btu/h) and dimensions to
accommodate larger cooking utensils or
greater quantity of food items, as well as
features to optimize cooking
performance. GE stated that
commercial-type products should be
exempt from regulation due to their
unique utility and cost, but if they are
regulated, they should be categorized
into a separate product class. (GE, No.
13 at p. 2) Whirlpool commented that,
although shipments of commercial-type
products have increased since the prior
rulemaking, they still remain a niche
product. Whirlpool shared GE’s position
that these products should be exempt
from regulation, particularly since there
is a lack of efficiency data available and
there is little potential for meaningful
energy savings. (Whirlpool, No. 10 at p.
6)
After considering stakeholder
comments, DOE has tentatively decided
to exclude high-performance,
commercial-style gas cooktops
(including the cooktop component of
commercial-style ranges) from the
energy efficiency standard due to the
lack of available data for determining
efficiency characteristics of those
products. In addition, the test procedure
for gas cooktops is based on measuring
temperature rise in an aluminum block
with a diameter dictated by the firing
rate of the burner. The maximum
diameter of the test block is sufficient to
measure higher output residential-scale
burners. For commercial-type burners
that must have larger diameter burner
rings to accomplish complete
combustion, however, this maximum
test block diameter may be too small to
achieve proper heat transfer and may
not be representative of the dimensions
of suitable cookware. However, DOE is
not aware of any data to determine the
measurement of energy efficiency or
energy efficiency characteristics for
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commercial-style cooktops. DOE seeks
data and inputs regarding the energy
efficiency of commerical-type cooktops
as well as any limitations of the test
procedure for this product class. This
topic is identified as Issue 6 under
‘‘Issues on Which DOE Seeks Comment’’
in section IV.E of this ANOPR.
Whirlpool and AHAM commented
that DOE should add sealed gas burners
as a separate product class. (Public
Meeting Transcript, No. 5 at pp. 82 and
85) Whirlpool stated that the added
utility of sealed burners based upon the
ease of consumer cleaning justifies this
distinction. In addition, the increasing
firing rates of sealed burners since the
previous rulemaking coupled with the
necessary grate height increase to
achieve proper combustion make sealed
burners less efficient than open burners.
Whirlpool cited the 1983 International
Gas Research Conference (IGRC)11
report that claimed an efficiency
reduction associated with sealed
burners. In Whirlpool’s opinion, the
boiling water tests upon which this
conclusion was based represented an
inappropriate metric, and any efficiency
determination for sealed burners must
be based on the DOE test procedure. For
these reasons, Whirlpool recommended
development of a separate product class
for sealed burners. (Public Meeting
Transcript, No. 5 at pp. 82–83 and 88)
AHAM stated that gas sealed burners
should be considered as a separate
product class within gas cooktops
because changes are required to provide
appropriate amounts of primary and
secondary air for proper combustion,
which inherently affects energy
efficiency. (AHAM, No. 14 at p. 2)
DOE has observed that there are
conflicting data on the impacts of sealed
burners on energy efficiency
measurements. In the previous
rulemaking, AHAM had stated that
sealed burners often have a lower gas
input rating than conventional burners
due to the reduction in secondary air.
The sealed burner must obtain all of its
secondary air from air that is available
above the cooktop. To obtain sufficient
air for proper combustion, it becomes
necessary to either raise the grate height
or to derate the burner. The IGRC report,
however, states that the reduction in
secondary air results in more primary
aeration to the sealed burner. The
increased primary aeration allows for a
reduced pan-to-burner separation and
increased burner efficiency.
11 J. Flood and T. Enga, ‘‘Energy Conservation
‘Aspects of Cooking Appliances,’’ Proceedings of
the 1983 International Gas Research Conference,
June 13, 1983, London, UK, pp 741–54. Available
online at: https://www.osti.gov/energycitations.
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According to the boiling water tests
conducted in the report, the efficiency
of conventional burners ranged from 42
percent to 48 percent, while the sealed
burner was rated at an efficiency of 53
percent. Commenters have not provided
data showing the correlation of boiling
water tests with efficiency testing
according to the DOE test procedure, as
would render the IGRC report
inapplicable. Accordingly, without clear
indication that the performance of
sealed burners is sufficiently distinct
from that of conventional open gas
burners, DOE will retain the single
product class for gas cooktops and
consider sealed burners as a design
option within that class.
The American Gas Association (AGA)
also proposed two product classes for
gas cooktops, differentiated by the
method of heat transfer associated with
the burners. The two product classes
suggested by the AGA would consist of
direct-flame contact burners that
provide conductive heat transfer and
other burner types that employ
convective and radiant heat transfer.
(AGA, No. 12 at p. 2) DOE believes that
the method of heat transfer does not
provide any unique utility, nor are there
data available that characterize
substantially different performance
based on heat transfer means. Thus,
DOE will retain a single product class
for gas cooktops.
For electric cooktops, DOE
determined that the ease of cleaning
smooth elements means that they have
greater utility to the consumer than coil
elements. Because smooth elements
typically use more energy than coil
elements, DOE has defined the
following product classes for electric
cooktops:
• Electric cooktop/low or high
wattage open (coil) elements; and
• Electric cooktop/smooth elements.
AHAM stated that if DOE decides to
proceed with further analysis of cooking
products, DOE should include an
additional product class for induction
cooktops. AHAM commented the utility
and performance attributes associated
with high-performance cooking
products must be recognized and
allowed to continue under the safe
harbor provisions of NAECA. Due to test
procedure complexities, small market
share, and lack of empirical data,
AHAM and Whirlpool recommended
that DOE exempt induction cooktops.
Whirlpool further commented that if
induction cooktops are analyzed, they
must be treated as a separate product
class, which would entail development
of a new test procedure. (Public Meeting
Transcript, No. 5 at p. 85; AHAM, No.
14 at pp. 2–4; Whirlpool, No. 10 at p.
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5) During the engineering analysis
(Chapter 5 of the TSD) DOE determined
that induction cooktops cannot be tested
according the existing test procedure,
and, therefore, DOE will not consider
this technology for the ANOPR analysis.
DOE seeks efficiency data and inputs to
characterize any limitations of the test
procedure for induction cooktops. This
topic is identified as Issue 6 under
‘‘Issues on Which DOE Seeks Comment’’
in section IV.E of this ANOPR.
For electric ovens, DOE determined
that the type of oven-cleaning system is
a utility feature that affects performance.
DOE found that standard ovens and
ovens using a catalytic continuouscleaning process use roughly the same
amount of energy. On the other hand,
self-cleaning ovens use a pyrolytic
process that provides enhanced
consumer utility with different overall
energy consumption, as compared to
either standard or catalytically-lined
ovens, due to the amount of energy used
during the cleaning cycle and better
insulation. Thus, DOE has defined the
following product classes for electric
ovens:
• Electric oven/standard oven with or
without a catalytic line; and
• Electric oven/self-clean oven.
AHAM concurred with this approach
during the Framework public meeting,
stating that non-self-cleaning and selfcleaning ovens should remain as
separate product classes. (Public
Meeting Transcript, No. 5 at pp. 85–86)
AHAM and Whirlpool both commented
that the feature of a ‘‘catalytic line’’ is
obsolete and, therefore, should be
removed from the non-self-cleaning
oven product class description. (Public
Meeting Transcript, No. 5 at p. 86;
Whirlpool, No. 10 at pp. 9–10) While
DOE is not aware of any electric ovens
currently on the market that are
catalytically lined, it will retain the
current description for completeness.
For gas ovens, for the same reasons as
for electric ovens, DOE is using the
following product classes:
• Gas oven/standard oven with or
without a catalytic line; and
• Gas oven/self-clean oven.
AHAM stated that if DOE decides to
proceed with further analysis, DOE
should include additional product
classes for high-performance,
commercial-style products, which
include commercial-style gas ovens (i.e.,
with burner firing rates greater than
22,500 Btu/h). AHAM commented that
the utility and performance attributes
associated with high-performance
cooking products must be recognized
and allowed to continue under the safe
harbor provisions of NAECA. Due to test
procedure complexities and small
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market share, AHAM recommended that
DOE exempt high-performance,
commercial-style products. (Public
Meeting Transcript, No. 5 at pp. 85–86;
AHAM, No. 14 at pp. 2–4) DOE
recognizes that the test procedure may
not adequately measure performance of
commercial-style ovens. The single test
block may not adequately measure the
temperature distribution that is inherent
with the larger cavity volumes and
higher firing rates typically found in
these products. DOE is not aware of any
data upon which to determine the
measurement of energy efficiency or
energy efficiency characteristics for
commercial-style ovens, so therefore
will not conduct an analysis on this
product class at this time. DOE seeks
data and inputs regarding the energy
efficiency of commercial-type
cooktopsstyle ovens as well as any
limitations of the test procedure for this
product class. This topic is identified as
Issue 6 under ‘‘Issues on Which DOE
Seeks Comment’’ in section IV.E of this
ANOPR.
As discussed for electric ovens,
AHAM and Whirlpool stated that the
‘‘catalytic line’’ descriptor for the
standard gas oven product class is
obsolete and should be removed. While
DOE is not aware of any gas ovens
currently on the market that are
catalytically lined, it will retain the
current description for completeness.
Finally, microwave ovens will
constitute a single product class in this
rulemaking. DOE did not break down
this category of cooking product into
further product classes. This product
class can encompass microwave ovens
with and without browning (thermal)
elements, but does not include
microwave ovens that incorporate
convection systems. DOE is unaware of
any data evaluating the efficiency
characteristics of microwave ovens
incorporating convection systems, so
therefore this type of unit will not be
included in the analysis. DOE seeks data
and inputs on the performance of
microwave ovens with convection
systems. This topic is identified as Issue
6 under ‘‘Issues on Which DOE Seeks
Comment’’ in section IV.E of this
ANOPR.
AHAM stated during the Framework
public meeting that additional product
classes for microwave ovens are needed
that would likely be a function of
volume and wattage, and possibly
installation configuration (i.e., countertop versus over-the-range ovens).
(Public Meeting Transcript, No. 5 at pp.
86–87) In comments submitted after the
Framework public meeting, AHAM
reiterated these comments and added
that humidity sensors would also need
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to be considered. However, AHAM
conceded that the lack of efficiency data
makes it impossible to determine the
appropriate product classes at this time.
(AHAM, No. 14 at p. 6) Similarly,
Whirlpool stated that, without existing
energy consumption standards, it does
not have any data to formulate
appropriate product classes for
microwave ovens, and the company
commented that obtaining these data
would be costly and time consuming.
(Whirlpool, No. 10 at p. 6) After the
Framework public meeting, AHAM
supplied microwave oven efficiency
data to DOE that failed to identify any
correlation between efficiency and
either rated output power or cavity
volume. Therefore, DOE has decided not
to define product classes as a function
of features such as volume or wattage,
and instead will retain the single
product class of microwave ovens with
or without thermal elements.
Comments did not strongly support
the inclusion of microwave/thermal
ovens in the analyses. In addition,
several comments used the term
‘‘combination ovens’’ to refer to not only
microwave/thermal ovens but also other
technologies, such as halogen bulbs. EEI
questioned whether DOE would
consider combination ovens for future
analysis, referring to both microwave
plus thermal and microwave plus
convection units. (Public Meeting
Transcript, No. 5 at p. 139) GE and
AHAM both commented that the DOE
test procedure is inadequate to measure
combination ovens. AHAM further
stated that the small market share of
combination ovens should preclude
them from the analysis. (Public Meeting
Transcript, No. 5 at pp. 140–141). In
comments submitted after the
Framework meeting, EEI stated that,
depending on market share,
combination ovens could impact
baseline energy usage. Although EEI did
not suggest including combination
ovens in the analyses, it did state that
DOE should ensure that any standards
do not eliminate these products from
the market. (EEI, No. 7 at p. 6)
Whirlpool, however, expressed its
opinion that combination ovens should
not be considered a separate product
class due to variations in design and
low market share. (Whirlpool, No. 10 at
p. 6)
DOE recognizes that the microwave
oven test procedure can only test the
microwave heating function of
microwave/thermal ovens, and that it
cannot test the browning function of the
radiant or halogen elements. However,
such browning features are typically a
secondary function of a microwave/
thermal unit, with the primary cooking
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being accomplished via microwave
heating. In combination units, the
convection system performs a
significant portion of the cooking
process, and, therefore, the inability to
measure performance of the convection
component would render the test
procedure inadequate. DOE has no
information that demonstates a
difference in energy performance
between microwave/thermal ovens
operating in microwave mode and
microwave ovens. Therefore, DOE will
include microwave ovens with thermal
browning elements in the single product
class. As discussed above, DOE will not
conduct an analysis at this time of
combination microwave ovens due to a
lack of data evaluating energy efficiency
or energy efficiency characteristics of
microwave ovens incoporating
convection systems.
DOE received several comments
regarding additional product classes for
cooking products not specifically
covered in the above product classes.
For example, EEI questioned whether
outdoor natural-gas-fired or propanefired grills are a covered product for this
analysis, and, if so, it recommended that
DOE conduct an investigation into
shipments and usage patterns. (EEI, No.
7 at p. 5) The test procedures
established in 10 CFR Part 430, Subpart
B, Appendix I are specified for kitchen
ranges and ovens. Further, the test
procedures provide for estimating
annual operating cost for conventional
ranges, conventional cooking tops,
conventional ovens, microwave ovens,
and microwave/conventional ranges. In
response, DOE believes that the
specification of ‘‘kitchen’’ and
‘‘household cooking appliance’’ in the
definitions of ‘‘conventional range’’ and
‘‘conventional cooking top’’ excludes
outdoor gas/propane grills. Therefore,
DOE has decided not to include outdoor
gas/propane grills in the present
analyses.
EEI also commented after the
Framework public meeting that DOE
should include compact cooking
products such as toaster ovens in the
analysis. (EEI, No. 7 at p. 3) However,
the definition of ‘‘conventional oven’’
provided in 10 CFR 430.2 states, in
relevant part, ‘‘It does not include
portable or countertop ovens which use
electric resistance heating for the
cooking or heating of food and are
designed for an electrical supply of
approximately 120 volts.’’ Therefore,
DOE is not including toaster ovens in
the present analyses because they are
not covered products.
In sum, in this rulemaking DOE is
using the following eight product
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classes in analyzing and setting
standards for cooking products:
• Gas cooktops/conventional burners;
• Electric cooktop/low or high
wattage open (coil) elements;
• Electric cooktop/smooth elements;
• Gas oven/standard oven with or
without a catalytic line;
• Gas oven/self-clean oven;
• Electric oven/standard oven with or
without a catalytic line;
• Electric oven/self-clean oven; and
• Microwave oven with or without
thermal elements.
d. Commercial Clothes Washers
EPACT 2005 amendments to EPCA
placed all CCWs in one product class
and applied a single standard for energy
efficiency and a single standard for
water efficiency for this equipment.
(EPACT 2005, section 136(e); 42 U.S.C.
6313(e)) This class encompasses both
top-loading (vertical-axis) and frontloading (horizontal-axis) units.
During the Framework public meeting
and Framework comment period, DOE
received comments expressing opposing
viewpoints regarding the use of one or
two product classes for CCWs. Alliance
Laundry Systems (ALS) pressed for two
product classes, because ALS believes
that in the eyes of consumers,
horizontal- and vertical-axis washers
can be significantly differentiated in
terms of utility and cost. (Public
Meeting Transcript, No. 5 at p. 42)
However, the Joint Comment argued for
a single product class, saying that
consumers only want to clean their
clothes and, thus, make no distinction
between washer product platforms.
(Joint Comment, No. 9 at p. 5) The Joint
Comment argued that, according to
EPCA’s definition of classes found at 42
U.S.C. 6219(a), commercial clothes
washers should be treated as one class
because ‘‘the function * * * of
commericial clothes washers (i.e.,
cleaning clothes) does not depend on
the orientation of the clothes washer
drum axis.’’ (Joint Comment, No. 9 at p.
5) In addition, the Joint Comment
contended that DOE chose to maintain
one product class during the residential
clothes washer rulemaking 12 and, as a
result, urged DOE to do the same in this
12 DOE notes that the Joint Comment is incorrect.
DOE has established five classes of residential
clothes washers, including top-loading compact,
top-loading standard and front-loading (See 10 CFR
part 430, section 430.32(g)). DOE understands how
some stakeholders could believe there is only one
class of standard-size residential clothes washers in
DOE’s regulations since the value of the energy
efficiency standard is the same for both classes.
While the standards are the same, DOE notes they
are separate in DOE’s regulations found at
430.32(g). The max tech level for the two classes are
different, because of the utility features, and are,
therefore, separate classes.
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rulemaking. (Joint Comment, No. 9 at p.
5) EEI also supported DOE’s designation
of a single commercial clothes washer
product class. (EEI, No. 7 at p. 3) AHAM
‘‘recommends that the Department
conduct its analysis using the product
categories currently provided for in its
regulations.’’ (AHAM, No. 14 at p. 7)
The Multi-Housing Laundry Association
(MLA) deferred to its member
manufacturers’ opinions regarding a
single product class. (MLA, No. 8 at p.
2) All manufacturers interviewed by
DOE as part of the manufacturer impact
analysis opposed the elimination of
vertical-axis washers, which could arise
as an issue if a single product class is
analyzed. (See TSD, Chapter 12.)DOE
recognizes that, by analyzing a single
product class and applying a single
standard for energy efficiency and a
single standard for water efficiency to
all CCWs, absent the consideration of
other relevant factors, the highest
economically justified standards could
be sufficiently stringent as to possibly
cause manufacturers to cease
production of vertical-axis washers.
As noted above, EPCA, as amended by
EPACT 2005, applies a single standard
for energy efficiency and a single
standard for water efficiency to all
CCWs. The Congress enacted a single
standard for CCWs some years after DOE
has established five classes for
residential clothes washers, which may
suggest that Congress’s initial
assessment was that a single class
would be most reasonable when
updating these standards. The statutory
provisions do not, however, specifically
prevent DOE from exercising its
technical expertise to create separate
product classes subject to the same
standards, if such differentiation is
determined to be appropriate.
After considering the comments on
the Framework Document, DOE decided
to keep the single class of commercial
clothes washers for today’s ANOPR, but
remains open to the possibility of
changing this approach if further
comments demonstrate that such a
change is warranted. The Joint
Comment, for example, argued that the
function of clothes washers is to clean
clothes and that all commercial clothes
washers perform this function and,
therefore, should be treated as a single
class. DOE has previously rejected this
argument. The residential clothes
washer rulemaking history clearly
demonstrated that size, the axis of
access and certain technologies (e.g.,
suds savings) had consumer utility that
affect performance and, therefore,
warranted separate classes for
residential products. Nevertheless, DOE
has decided to maintain a single class
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for CCWs in today’s ANOPR, for the
reasons that follow. First, other
stakeholders did not provide any
compelling information to support
proposing multiple product classes for
CCWs, Second, even though there may
be some performance-related features on
existing CCWs that might warrant
multiple CCW product classes (as was
demonstrated in the residential clothes
washer rulemaking), technologies may
be available to enable top-loading units
to attain the same efficiency level as
front-loading units, thereby rendering
any product class distinction
meaningless.
In tentatively deciding to retain a
single product class for CCWs, DOE was
sensitive to other considerations
including the likely outcome of
requisite U.S. Department of Justice
(DOJ) review of the potential impacts, if
any, of efficiency standards on
competition, given that a large
percentage of the overall market for
commercial washers is produced by one
manufacturer that specializes in
vertical-axis machines. Another
consideration may be the potential
effect of multiple-class standards on the
market shares of vertical-axis and
horizontal-axis machines. For example,
if separate standards further widened
the first cost differences between these
two classes of washers, then the overall
result might be a decline in the market
share of the more energy efficient
horizontal-axis machines, which could
more than offset any energy savings
achieved in vertical-axis machines.
DOE notes that sections 325 (o)(4) and
327(d)(4) of EPCA require DOE to
consider the availability of performance
characteristics, features, and other
characteristics in setting standards and
in considering State petitions for
exemption from Federal preemption. (42
U.S.C. 6295(o)(4) and 6297(d)(4)) The
California Energy Commission (CEC)
submitted a petition for exemption from
Federal preemption by DOE’s
residential clothes washer standard.13
One of the factors on which DOE based
its denial of the CEC petition was that
it would make top-loading clothes
washers unavailable in the market. (71
FR 78157)
Based on the discussion above, DOE
requests comments on clothes washer
product classes and, if DOE were to
keep a single class for commercial
clothes washers, how to consider the
requirements of section 325(o)(4) of
EPCA in considering Trial Standard
Levels. DOE specifically seeks feedback
on these product classes and invites
13 DOE
Docket No. EE–RM–PET–100, submitted
by the California Energy Commission.
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interested persons to submit written
presentations of data, views, and
arguments as discussed in section IV.E
of this ANOPR.
2. Market Assessment
AHAM is the trade association
representing the majority of dishwasher,
dehumidifier, and cooking product
manufacturers. AHAM conducts market
and consumer research studies and
publishes a biennial Major Appliance
Fact Book. AHAM also develops and
maintains technical standards for
various appliances to provide uniform,
repeatable procedures for measuring
specific product characteristics and
performance features. Other trade
associations relevant to this rulemaking
include the Coin Laundry Association
(CLA), representing the 30,000 coin
laundry owners globally, and the MLA,
a trade association of operator and
supplier companies providing
professional laundry services for the
multi-housing industry.
The majority of the domestic share of
CCWs is held by four major
manufacturers: ALS, the Maytag
Corporation (Maytag), Whirlpool, and
GE. Maytag and Whirlpool merged in
2006 but have continued to maintain
both product lines to this date.
DOE estimates that there are
approximately 13 manufacturers of
residential dishwashers that serve the
domestic market. Approximately 94
percent of the market is served by four
manufacturers: AB Electrolux
(Frigidaire), GE, Maytag, and Whirlpool.
The merger between Whirlpool and
Maytag resulted in the combined
company accounting for 51 percent of
the domestic market.
DOE estimates that there are
approximately 18 manufacturers of
residential dehumidifiers that serve the
domestic market. Approximately two
thirds of the market is represented by
two manufacturers: Whirlpool and LG
Electronics (LG).
DOE estimates that there are
approximately 14 manufacturers of
cooking products (including ovens,
cooktops, and ranges) that serve the U.S.
market. The majority of the cooking
products market is represented by four
companies: Frigidaire, GE, Maytag, and
Whirlpool. GE and Whirlpool represent
nearly three quarters of the electric
range products market. GE represents
over a third of the gas range products
market, while the combined Whirlpool
and Maytag comprise over a quarter.
The microwave oven market differs
from the rest of the domestic cooking
product market in that many of the
manufacturers are foreign-owned
companies with manufacturing facilities
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outside of the United States. Many of
the domestic appliance manufacturers
rebrand foreign-manufactured
microwave products. Major microwave
oven manufacturers are: LG, Samsung
Electronics America, Inc. (Samsung),
and the Sharp Electronics Corporation
(Sharp), serving 67 percent of the
domestic market. The second tier of
approximately 9 manufacturers serves
the remaining 33 percent of the
domestic market.
Due to mergers and acquisitions, the
home appliance industry continues to
consolidate. While the degree of market
share concentration varies by product
type, the market shares of a few
companies provide evidence in support
of this characterization. According to
the September 2006 issue of Appliance
Magazine, Whirlpool, GE, Frigidaire,
and Maytag comprise 92 percent of the
U.S. core appliance market share. ‘‘Core
appliances’’ include dishwashers,
freezers, ranges, refrigerators, and
clothes washers. Whirlpool and Maytag
were allowed by the U.S. Department of
Justice (DOJ) to complete a merger on
March 31, 2006, after an investigation
that focused primarily on residential
laundry but with consideration of
impacts across all product lines.
Although opponents of the merger had
asserted that the combined companies
would control as much as 70 percent of
the residential laundry market and as
much as 50 percent of the residential
dishwasher market,14 DOJ determined
that the merger would not give
Whirlpool excessive market power in
the sale of its products and that any
attempt to raise prices would likely be
unsuccessful. In support of this claim,
DOJ noted: (1) Other U.S. brands,
including Sears Brands LLC (Kenmore),
GE, and Frigidaire, are well established;
(2) foreign manufacturers, including LG
and Samsung, are gaining market share;
(3) existing U.S. manufacturers are
operating below production capacity; (4)
the large home appliance retailers have
alternatives available to resist price
increase attempts; and (5) Whirlpool
and Maytag substantiated large cost
savings and other efficiencies that
would benefit consumers. The
Whirlpool-Maytag merger follows
several other mergers and acquisitions
in the home appliance industry. For
example, Maytag acquired Jenn-Air
Corporation in 1982, Magic Chef, Inc. in
1986, and Amana Appliances in 2001.
Whirlpool acquired the KitchenAid
division of Hobart Corporation in 1986.
White Consolidated Industries (WCI)
14 P. Hussmann, ‘‘Justice to Extend MaytagWhirlpool Merger Review,’’ Newton Daily News
Online (Feb. 14, 2006).
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acquired the Frigidaire division of
General Motors Corporation in 1979,
and AB Electrolux acquired WCI (and
therefore Frigidaire) in 1986. See
Chapter 3 of the TSD for more
information regarding manufacturers of
CCWs and residential dishwashers,
dehumidifiers, and cooking products.
In addition, DOE considers the
possibility of small businesses being
impacted by the promulgation of energy
conservation standards for CCWs and
residential dishwashers, dehumidifiers,
and cooking products. At this time, DOE
is not aware of any small manufacturers,
defined by the Small Business
Administration as having 750
employees or fewer, who produce
products that fall under this rulemaking
and who, therefore, would be impacted
by a minimum efficiency standard.
Should any small business
manufacturers of the four appliance
products be identified, DOE will study
the potential impacts on these small
businesses in greater detail during the
MIA, which it will conduct as a part of
the NOPR analysis. See Chapter 3 of the
TSD for more information regarding
small business manufacturers of CCWs
and residential dishwashers,
dehumidifiers, and cooking products.
Next, DOE identified distribution
channels for each of the products
covered by this rulemaking. For CCWs,
DOE determined that the market
consists of laundromats, private multifamily housing, and large institutions
(e.g., military barracks, universities, and
housing authorities). Most large
institutions and a majority of private
multi-family housing (between 50 and
90 percent) do not purchase clothes
washers directly. Rather, these
organizations lease their laundry space
to a third party known as a route
operator. Route operators supply
laundry equipment and maintain
facilities in exchange for a percentage of
the laundry revenue. Laundromats and
some private building managers
purchase or lease clothes washers
directly from distributors. The main
difference between route operators and
distributors is the length of service
provided to their clients. Route
operators provide ongoing support
while distributor support ends at the
point of sale.
The distribution chain for residential
appliances, including dishwashers,
dehumidifiers, and cooking products,
differs from commercial products, since
the majority of consumers purchase
their appliances directly from retailers.
These retailers include: (1) Home
improvement, appliance, and
department stores; (2) Internet retailers;
(3) membership warehouse clubs; and
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(4) kitchen remodelers. DOE determined
that over 93 percent of residential
appliances are distributed from the
manufacturer directly to a retailer. See
Chapter 3 of the TSD for more
information regarding distribution
channels for CCWs and residential
dishwashers, dehumidifiers, and
cooking products.
DOE considers regulatory and nonregulatory initiatives that affect CCWs
and residential dishwashers,
dehumidifiers, and cooking products.
NAECA established Federal standards
for residential dishwashers, which were
subsequently amended by DOE by a
final rule published in the Federal
Register on May 14, 1994. (56 FR 22250)
NAECA established prescriptive
standards for gas cooking products,
requiring gas ranges and ovens with an
electrical supply cord not to be
equipped with constant burning pilots,
and directed DOE to conduct two cycles
of rulemakings to determine if more
stringent standards are justified. (42
U.S.C. 6295 (h)(1)–(2)) DOE issued a
NOPR on March 4, 1994, proposing
performance standards for gas and
electric residential cooking products,
including microwave ovens. 59 FR
10464. In accordance with its 1996
Process Rule, DOE refined its standards
analysis of cooking products. With
regard to gas cooking products, DOE
focused on the economic justification
for eliminating standing pilot lights.
Partially due to the difficulty of
conclusively demonstrating that
elimination of standing pilot lights was
economically justified, DOE issued a
final rule on September 8, 1998, that
covered only electric cooking products,
including microwave ovens. 63 FR
48038. The final rule found that
standards were not economically
justified for electric cooking products.
DOE never completed its standards
rulemaking for gas cooking products.
Section 136(e) of EPACT 20005
amends section 342 of EPCA, 42 U.S.C.
6313, to add subsection (e) for CCWs.
Likewise, section 135(c)(4) of EPACT
2005 amends section 325 of EPCA, 42
U.S.C. 6295, to add subsection (cc) for
dehumidifiers. New subsection 342(e),
42 U.S.C. 6313(e) establishes energy
conservation standards for CCWs.
Further, it requires that DOE issue a
final rule by January 1, 2010, to
determine whether the standards for
CCWs should be amended. New
subsection 325(cc), 42 U.S.C. 6295(cc),
establishes energy conservation
standards for dehumidifiers based on a
unit’s capacity to extract moisture from
the surrounding air (in pints/day).
These Federally mandated standards for
dehumidifiers will be the national
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standards when they take effect on
October 1, 2007. In addition, EPACT
2005 requires that by October 1, 2009,
DOE issue a final rule for dehumidifiers
to determine whether the standards
should be amended. (EPACT 2005,
section 135(c)(4)) Further, in the event
that DOE fails to publish a final rule
requiring new standards to take effect by
October 1, 2012, EPACT 2005 also
prescribes a new set of amended
standards for dehumidifiers. (Id.)
Prior to the passage of EPACT 2005,
the following States proposed and
adopted State-level efficiency
regulations for CCWs that are identical,
or very similar, to EPACT 2005
regulations: Arizona, California,
Connecticut, Maryland, New Jersey,
Oregon, Rhode Island, and Washington.
The EPACT 2005 energy and water use
standards for CCWs preempt any State
efficiency standards since they became
effective January 1, 2007.15 In addition
to the efficiency standards discussed
above, the State of California requires
that commercial top-loading, semiautomatic clothes washers and
commercial suds-saving clothes washers
manufactured on or after January 1,
2005 have an unheated rinse water
option.
DOE reviewed several voluntary
programs that promote energy-efficient
CCWs, residential dishwashers,
dehumidifiers, and cooking products in
the United States. Many programs,
including the Consortium for Energy
Efficiency (CEE), Energy Star, and the
Federal Energy Management Program
(FEMP), establish voluntary energy
conservation standards for these
products. CEE issues voluntary
specifications for CCWs and standardsized dishwashers under its
Commercial, Family-Sized Washer
Initiative and Super-Efficient Home
Appliance Initiative, respectively.
Energy Star, a voluntary labeling
program backed by the EPA and DOE,
identifies energy efficient products
through a qualification process. To
qualify, a product must exceed Federal
minimum standards by a specified
amount, or if no Federal standard exists,
exhibit selected energy-saving features.
The Energy Star program works to
recognize the top quartile of products on
the market, meaning that approximately
25 percent of products on the market
meet or exceed the Energy Star levels.
Energy Star specifications exist for
many products, including CCWs,
dishwashers, and dehumidifiers. FEMP
15 None of these States submitted a petition for
waiver to DOE, seeking to maintain their existing
efficiency standards for commercial clothes
washers.
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works to reduce the cost and
environmental impact of the Federal
government by advancing energy
efficiency and water conservation,
promoting the use of distributed and
renewable energy, and improving utility
management decisions at Federal sites.
FEMP helps Federal buyers identify and
purchase energy efficient equipment,
including CCWs, residential
dishwashers, and microwave ovens. See
Chapter 3 of the TSD for more
information regarding regulatory and
non-regulatory initiatives. During the
engineering analysis (Chapter 5 of the
TSD), efficiency levels specified by
many of these initiatives will be
analyzed during the generation of costefficiency curves.
DOE reviewed data collected by the
U.S. Census Bureau, EPA, and AHAM to
evaluate annual residential appliance
product shipment trends and the value
of these shipments. As the number of
new home starts and the percentage of
64449
The historical shipments data shown
in Tables II.1, II.2, and II.3 and the
historical market saturation data shown
in Table II.4 provide a better picture of
the market for the four appliance
products. The market saturation data
indicate the percentage of the housing
stock with the appliance. The data in
Table II.4 also include for each of the
given years the number of appliances in
the housing stock. Because commercial
clothes washers are not a household
appliance, market saturation data are
not provided. The historical shipments
and market saturation data for
dishwashers, dehumidifiers, and
cooking products are from the 2005
AHAM Fact Books,16 while the
commercial clothes washer historical
shipments data are based on data
provided to DOE by AHAM for the years
2002–2005 and Appliance Magazine for
the years 1988–1998.17
consumers with multiple units of some
appliances increases annually, the unit
shipments of most appliances are
expected to increase as well. The
shipments of built-in dishwashers
increased by over 76 percent from 1995
to 2005, while the shipments of portable
dishwashers declined 35 percent in the
same time period. After a period of
decline from 1995 to 2002, shipments of
dehumidifiers increased sharply in 2003
and have continued to rise through
2005. Shipments of dehumidifiers
nearly doubled between 1995 and 2005.
From 1995 to 2005, shipments of
electric and gas free-standing ranges and
surface cooking units, electric built-in
ranges, and microwave ovens increased,
while shipments of built-in gas ranges
decreased. However, in real dollars, the
value of shipments for the household
appliance industry has declined by
nearly 14 percent over the period from
1994 to 2005.
TABLE II.1.—INDUSTRY SHIPMENTS OF DISHWASHERS AND DEHUMIDIFIERS
[Domestic and import in thousands of units]
Dishwashers
Year
Dehumidifiers
Built-In
2005
2004
2003
2002
2001
2000
1999
1998
1997
1996
1995
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
Portable
7,294
6,953
6,280
6,049
5,478
5,663
5,542
4,969
4,653
4,417
4,141
Total
133
153
148
158
149
164
170
175
173
189
205
7,428
7,106
6,428
6,207
5,627
5,827
5,712
5,144
4,826
4,606
4,346
1,957
1,672
1,311
799
806
975
950
1,031
820
977
1,003
TABLE II.2.—INDUSTRY SHIPMENTS OF COOKING PRODUCTS
[Domestic and import in thousands of units]
Cooking products
Electric ranges
Gas ranges
Year
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Freestanding
2005
2004
2003
2002
2001
2000
1999
1998
1997
1996
1995
.........................................
.........................................
.........................................
.........................................
.........................................
.........................................
.........................................
.........................................
.........................................
.........................................
.........................................
Built-In
4,685
4,612
4,238
4,030
3,842
3,826
3,785
3,481
3,177
3,123
2,931
16 AHAM, 2005 Fact Book, 2005. Washington, DC.
Available for purchase at: https://www.aham.org/ht/
d/Store/name/FACTBOOK.
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Surface
cooking
units
973
963
841
780
726
706
705
652
617
614
598
542
570
543
528
498
494
493
506
446
418
389
Total
6,201
6,145
5,622
5,338
5,066
5,026
4,983
4,639
4,240
4,155
3,917
Freestanding
3,139
3,124
2,897
2,781
2,580
2,729
2,698
2,543
2,391
2,366
2,391
Built-In
Surface
cooking
units
64
67
67
71
72
70
72
71
73
72
84
560
528
455
416
384
377
367
336
280
272
240
17 ‘Statistical Review’. Appliance Magazine,
April, 1998, 1999.
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15NOP2
Total
3,762
3,719
3,419
3,268
3,036
3,176
3,137
2,950
2,744
2,710
2,715
Microwave
ovens
13,862
15,526
14,274
13,311
13,446
12,644
11,422
10,365
8,883
8,771
8,162
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TABLE II.3.—INDUSTRY SHIPMENTS OF
COMMERCIAL CLOTHES WASHERS
TABLE II.3.—INDUSTRY SHIPMENTS OF
COMMERCIAL CLOTHES WASHERS—
Continued
[Thousands of units]
[Thousands of units]
Year
2005
2004
2003
2002
2001
2000
1999
TABLE II.3.—INDUSTRY SHIPMENTS OF
COMMERCIAL CLOTHES WASHERS—
Continued
[Thousands of units]
Units
......................................
......................................
......................................
......................................
......................................
......................................
......................................
Year
177
178
191
175
194
215
239
1998
1997
1996
1995
1994
1993
Units
......................................
......................................
......................................
......................................
......................................
......................................
Year
265
241
232
209
205
190
1992
1991
1990
1989
1988
Units
......................................
......................................
......................................
......................................
......................................
188
193
225
215
213
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
Dishwashers .................................
Dehumidifiers ...............................
Electric Ranges/Cooktops* ..........
Gas Ranges/Cooktops* ................
Microwave Ovens .........................
Percent
Number
Percent
Number
Percent
Number
Percent
Number
Percent
12
NA
25.8
36.6
Neg.
18.9
NA
40.6
57.7
Neg.
37.2
9.2
48.4
35.7
21.4
44.5
11
58
42.7
25.6
50.3
15.6
58.4
36.1
77.2
53.9
16.7
62.6
38.7
82.7
61.8
14.7
69.2
39.4
94.6
59.3
14.1
66.3
37.8
** 90.7
80.2
20.6
71
42.2
97.2
73.7
18.9
65.3
39
89.3
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* Cooktops not included in 1970 or 1982 data.
** Includes over-the-range and countertop microwave ovens.
During the Framework public
meeting, DOE solicited comments
regarding existing databases to track
CCW efficiencies. ALS commented that
the existing CEC database contains
useful data and should be reviewed.
(Public Meeting Transcript, No. 5 at p.
44) As of March 2007, the CEC database
had 626 entries for dishwashers and 196
entries for CCWs. This database,
however, does not specify which
models are current, and it does not
appear to cover the entire range of
dishwasher models. DOE also consulted
the Energy Star database for residential
clothes washers, dishwashers, and
dehumidifiers. DOE subsequently used
these data to identify units for reverse
engineering tear-downs and other
analysis. Whenever possible, DOE
investigated the design options of the
listed appliances, which then helped
DOE design the interview guides for the
MIA interviews with stakeholders to
solicit comments about design options.
DOE used the data for residential
clothes washers as an additional means
of validation for the CCW analysis.
Natural Resources Canada (NRCan)
publishes a database of electric cooking
appliance performance. Although it is
not completely representative of the
current U.S. cooking products market,
this database covers products available
in the Canadian market, which overlaps
with the U.S. market. Chapter 3 of the
TSD presents data that detail the energy
factors of standard and self-cleaning
electric ranges and ovens, along with
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coil-element and smooth element
electric cooktops.
DOE also evaluated import and export
trends for CCWs and residential
dishwashers, dehumidifiers, and
cooking products as reported by the U.S.
Census Bureau and AHAM, as well as
the market saturation for dishwashers,
dehumidifiers, and cooking products
according to AHAM. On the whole,
major appliance unit imports increased
1.8 percent in 2005 from 2004. Major
appliance unit exports increased 13.5
percent over the same period. In terms
of market saturation, while the
percentage of U.S. households with
electric ranges and/or cooktops and
microwave ovens has decreased slightly
since 2001, the market saturation of
dishwashers, dehumidifiers, and gas
cooking products has increased. See
Chapter 3 of the TSD for more
information regarding historical
shipments and market saturation.
From AHAM data 1818 and the U.S.
Department of Labor’s Consumer Price
Index, DOE estimated average retail
prices for residential appliances,
including clothes washers, dishwashers,
dehumidifiers, and cooking products.
Although prices for electric and gas
ranges have increased in the period
from 1980 to 2005, the increase has been
at a much slower rate than the annual
rate of inflation. Prices of residential
dishwashers, dehumidifiers, microwave
18 Data submitted to DOE as part of this
rulemaking, contained in DOE Docket No. EE–
2006–STD–0127.
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ovens, and clothes washers have
decreased in the same time period. DOE
also developed the household appliance
industry cost structure from publicly
available information from the U.S.
Census Bureau, the Annual Survey of
Manufacturers (ASM), and the SEC 10–
K reports filed by publicly-owned
manufacturers. The statistics illustrate a
steady decline in the number of
production and non-production workers
in the industry.
Inventory levels, expressed both in
dollars and as a percentage of value of
shipments, have steadily declined since
1995 for the household appliance
industry, according to the ASM. DOE
obtained full-production-capacity
utilization rates from the U.S. Census
Bureau, Survey of Plant Capacity from
1994 to 2004. Full production capacity
is defined as the maximum level of
production an establishment could
attain under normal operating
conditions. In the Survey of Plant
Capacity report, the full production
utilization rate is a ratio of the actual
level of operations to the full production
level. The full-production-capacity
utilization rate for household appliances
in aggregate, along with the rates for
cooking appliances and household
laundry appliances, show a decrease in
utilization from 1994 to 2004, although
trends in subsets of that time period
have fluctuated. See Chapter 3 of the
TSD for more information regarding
retail pricing, industry cost structure,
inventory levels, and production
capacity utilization.
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3. Technology Assessment
In the technology assessment, DOE
identifies technologies and design
options that appear to be feasible means
of improving product efficiency, and
characterizes energy efficiency of
residential dishwashers, dehumidifiers,
and cooking products, and CCWs
currently available in the marketplace.
This assessment provides the technical
background and structure on which
DOE bases its screening and engineering
analyses.
mstockstill on PROD1PC66 with PROPOSALS2
a. Dishwashers
DOE identified technologies to
increase the energy efficiency of
residential dishwashers primarily from
a review of the following three sources:
(1) DOE’s ANOPR initiating a standards
rulemaking for dishwashers, published
on November 14, 1994 (59 FR 56423);
(2) recent information provided by trade
publications; and (3) design data
identified in manufacturer product
offerings. Except where otherwise
noted, design options are taken from the
1994 ANOPR. DOE derived the variable
washing pressure and variable-speed
drive technologies from the February
2006 edition of Appliance Magazine.
DOE grouped these technologies
together because they collectively
address manufacturers’ design tradeoffs
between the mechanical soil removal
function of the water and the cycle time
and energy associated with the
dishwasher pump. Condenser and fan/
jet drying are technologies listed in one
manufacturer’s product offerings. DOE
also identified supercritical carbon
dioxide washing from the November
2005 issue of Appliance Magazine. It
added low-standby-loss electronic
controls based on DOE’s analysis of
controller standby power in
dishwashers currently on the market.
In addition to these design options,
the multiple water organizations
commented that DOE should consider a
two-drawer design or similar option
which would improve efficiency under
partial loads. The multiple water
organizations also believe DOE should
consider any design option that would
reduce pre-rinsing. (Multiple Water
Organizations, No. 11 at p. 3) In
interviews with manufacturers, DOE
determined that two-drawer designs
contain no control systems to link the
operation of one drawer with another,
so that each drawer acts in its own
capacity as a compact-size dishwasher.
Therefore, a two-drawer design cannot
be considered as a design option.
Minimizing consumer pre-rinsing
depends on maintaining cleaning
performance; there are no design
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options that specifically address prerinsing. Any design option that achieves
energy efficiency improvements without
incurring significant performance
penalties will indirectly address prerinsing.
DOE considered the design options
that follow.
• Condenser drying
• Fan/jet drying
• Flow-through heating
• Improved fill control
• Improved food filter
• Improved motor efficiency
• Improved spray-arm geometry
• Increased insulation
• Low-standby-loss electronic
controls
• Microprocessor controls and fuzzy
logic, including adaptive or soil-sensing
controls
• Modified sump geometry, with and
without dual pumps
• Reduced inlet-water temperature
• Supercritical carbon dioxide
washing
• Ultrasonic washing
• Variable washing pressure and flow
rates
DOE characterized energy efficiency
as an EF, expressed as cycles/kWh for
dishwashers currently on the market via
a survey of the CEC database of certified
dishwashers.19
b. Dehumidifiers
DOE has not previously conducted a
comprehensive analysis of energy
conservation standards for
dehumidifiers because there are
currently no Federal standards for these
products. The first such standards
become effective October 2007. To build
a list of possible design options, DOE
surveyed the marketplace for
dehumidifier design options by
reviewing a wide assortment of product
literature, through discovery during the
teardown analysis, during stakeholder
interviews, and by using its previous
room-air conditioning rulemaking
analysis as a source for further design
options. DOE identified the following
design options as possible means to
improve dehumidifier performance.
• Built-in hygrometer/humidistat
• Improved compressor efficiency
• Improved condenser performance
• Improved controls
• Improved defrost methods
• Improved demand-defrost controls
• Improved evaporator performance
• Improved fan and fan-motor
efficiency
• Improved flow-control devices
• Low-standby-loss electronic
controls
19 Available online at: https://www.energy.ca.gov/
appliances/appliance/excel_based_files/.
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64451
• Washable air filters
Based on product literature research,
comments, and teardown analysis, DOE
has identified compressor, heat
exchanger, and fan motor improvements
as the most common ways by which
manufacturers improve the energy
efficiency of their dehumidifiers as
measured by the DOE test procedure.
During the Framework public meeting
and Framework comment period,
stakeholders asked that DOE add
improved control systems to the
dehumidifier design options list. ACEEE
and other energy efficiency advocates
recommended that improved controls
(such as fuzzy logic) be added to the
design option list to better control the
dehumidifier. (Public Meeting
Transcript, No. 5 at p. 73; Joint
Comment, No. 9 at p. 4) DOE agrees that
such control technologies offering
potential energy savings are being
implemented by manufacturers, and,
therefore, it added improved controls as
a design option for dehumidifiers.
c. Cooking Products
DOE most recently analyzed energy
conservation standards for cooking
products in 1996 and 1997. In the 1997
analysis, DOE analyzed only gas
cooking products to determine the
technical and economic feasibility of
eliminating standing pilot lights. In its
prior analysis, DOE identified many
technologies that have the potential for
improving gas and electric cooking
efficiency. It has considered all of these
in this rulemaking. In addition, DOE
identified low-standby-loss electronic
controls as a design option for several
cooking products, based on review of
standby power data for microwave
ovens and the potential applicability to
conventional cooking products as well.
Radiant elements for smooth electric
cooktops, which were included in the
previous analysis, were not considered
as a design option for this rulemaking
because manufacturer data provided to
DOE in the prior rulemaking indicated
that this technology does not offer an
efficiency improvement over the
baseline according to the DOE test
procedure. DOE considered the
technologies that follow.
For gas cooktops:
• Catalytic burners
• Electronic ignition
• Insulation
• Radiant gas burners
• Reduced excess air at burner
• Reflective surfaces
• Sealed burners
• Thermostatically-controlled burners
For open (coil) element electric
cooktops:
• Electronic controls
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• Improved contact conductance
• Insulation
• Low-standby-loss electronic
controls
• Reflective surfaces
For smooth element electric cooktops:
• Electronic controls
• Halogen elements
• Induction elements
• Low-standby-loss electronic
controls
For gas and electric ovens:
• Bi-radiant oven (electric only)
• Forced convection
• Halogen lamp oven (electric only)
• Improved and added insulation
• Improved door seals
• Low-standby-loss electronic
controls
• No oven-door window
• Oven separator
• Pilotless ignition (gas only)
• Radiant burner (gas only)
• Reduced conduction losses
• Reduced thermal mass
• Reduced vent rate
• Reflective surfaces
• Steam cooking
DOE received several comments that
the design options from the previous
rulemaking are still relevant because
there have been no major technological
breakthroughs in conventional cooking
products since that time. AHAM
recommended looking at the same
design options because there has been
no change in the market other than for
induction cooking, which according to
AHAM is so expensive it should not be
considered. (Public Meeting Transcript,
No. 5 at p. 93) ACEEE and the Joint
Comment agreed with retaining the
design options from the previous
rulemaking, stating that only modest
updates are needed for conventional
cooking products. (Public Meeting
Transcript, No. 5 at p. 97; Joint
Comment, No. 9 at p. 3) Whirlpool
stated that many of the previous design
options either are not economically
justifiable or have safety issues (Public
Meeting Transcript, No. 5 at p. 94),
while Wolf commented that the cost and
risk of modifying today’s wellperforming products with questionable
design options should not be
underestimated. (Wolf, No. 6 at p. 2)
DOE believes the aforementioned design
options are still relevant and has
retained them for analysis. Consumer
safety is a screening criterion that DOE
has applied in the screening analysis
(Chapter 4 of the TSD), and DOE
assessed economic viability in the LCC
and PBP analyses (Chapter 8 of the
TSD).
For microwave ovens, in the previous
rulemaking, DOE identified all of the
technologies listed below, with the
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exception of cooking sensors, dual
magnetrons, and low-standby-loss
electronic controls. DOE identified
cooking sensors from product literature,
while dual magnetrons were identified
in the February 2006 edition of
Appliance Design as a means to
decrease cooking times. DOE identified
low-standby-loss electronic controls by
reviewing AHAM data for standby
power. In addition, DOE received
comments stating that it needed to
consider sensors and controls that
detect completion of the cooking
process and variable power supplies
that adjust power to the magnetron
during cooking. (Public Meeting
Transcript, No. 5 at p. 91; Joint
Comment, No. 9 at p. 3) DOE did not
receive any information regarding the
energy efficiency impacts of variable
power supplies, and, therefore, will
limit the design option relating to
variable magnetron output to dual
magnetrons. In view of the above, DOE
considered the design options that
follow.
• Added insulation
• Cooking sensors
• Dual magnetrons
• Eliminate or improve ceramic
stirrer cover
• Improved fan efficiency
• Improved magnetron efficiency
• Improved power supply efficiency
• Low-standby-loss electronic
controls
• Modified wave guide
• Reflective surfaces
In written comments, AHAM stated
that DOE considered many design
options for microwave ovens in its 1998
rule and that, after extensive analysis,
DOE determined that no design options
were technologically feasible or
economically justifiable. AHAM also
stated that there have been no
technological or economic
breakthroughs since the previous
determination that would change the
previous conclusion. (AHAM, No. 17 at
p. 1) However, ACEEE disagreed, stating
that there have been some significant
changes in microwave oven technology
since the prior rulemaking. Thus, it
stated that the previous design options
need to be reviewed. (Public Meeting
Transcript, No. 5 at p. 97)
During the Framework public meeting
and Framework comment period, DOE
received comments that the lack of
efficiency data for microwave ovens
would hinder DOE’s ability to establish
efficiency levels, and that DOE should
conduct a test program specifically to
obtain such efficiency data since it
would be difficult for the manufacturers
to do so themselves. Whirlpool stated
that manufacturers are not using the
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Fmt 4701
Sfmt 4702
microwave oven test procedure and, as
a result, there is a lack of efficiency
data. (Public Meeting Transcript, No. 5
at p. 86) Whirlpool commented that the
absence of a microwave oven energy
efficiency standard has resulted in a
dearth of data on microwave ovens.
(Whirlpool, No. 10 at p. 10). ACEEE
commented that, because there are very
few data on microwave ovens, the
baseline efficiency level needs to be
updated from the numbers in the
previous rulemaking. (Public Meeting
Transcript, No. 5 at p. 91) ACEEE
further stated that the process to update
the data should include collecting as
much information from manufacturers
as possible, then supplementing these
data with product testing. The purpose
of these test data, according to ACEEE,
should be to assess the validity of the
efficiency levels analyzed in the
previous rulemaking rather than to
quantify a new cost-efficiency
relationship. (Public Meeting
Transcript, No. 5 at pp. 142–143)
AHAM concurred with DOE’s intention
to conduct microwave oven efficiency
testing as part of this rulemaking
because it would take industry a
significant amount of time to provide
efficiency data. AHAM suggested DOE
may want to commission the National
Institute of Standards and Technology
or some other source to do an
independent evaluation. (Public
Meeting Transcript, No. 5 at p. 143) The
Joint Comment stated that because
microwave oven technology has
changed substantially since the previous
rulemaking, DOE should quickly collect
current data on product performance
and features from manufacturers, and
fill in gaps where necessary.
Manufacturers could then provide
incremental cost data at the selected
efficiency levels. (Joint Comment, No. 9
at p. 3)
Stakeholders questioned which
microwave oven test procedure should
be used. he current DOE test procedure
requires manufacturers to test to IEC
705–1988, Household Microwave
Ovens—Methods for Measuring
Performance, and Amendment 2–1993.
The current IEC test procedure is
designated IEC 60705 Edition 3.2–2006.
Differences between the 1988 and
current IEC test procedures can result in
differences in measured microwave
oven efficiency. In comments received
during the Framework public meeting,
Sharp asked which test procedure
would be used to define microwave
oven efficiency. (Public Meeting
Transcript, No. 5 at p. 141)
Recognizing the lack of existing
energy efficiency data, AHAM
conducted a test program on 21
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microwave ovens from nine
manufacturers, representing a broad
spectrum of units available in the
marketplace and incorporating a variety
of capacities and features. AHAM tested
microwave oven efficiency according to
DOE’s test procedure and standby
power according to IEC 62301–2005,
Household Electrical Appliances—
Measurement of Standby Power. AHAM
found no correlation between energy
efficiency and rated output power or
cavity volume. Efficiencies ranged from
54.8 percent to 61.8 percent. Given the
uncertainties in the test procedure,
resulting in large test-to-test variations,
DOE considers these efficiencies to be
comparable to the efficiencies in the
prior rulemaking’s analysis. Standby
power also showed no correlation with
rated output power, varied significantly
from unit to unit, and ranged from 1.5
watts to 5.8 watts. The FEMP database
of microwave oven standby power
indicates that 90 percent of reported
microwave ovens consume greater than
2 watts in standby mode.
The energy efficiency data upon
which DOE based its analysis was
measured according to the DOE test
procedure, which references IEC 705–
1988 and Amendment 2–1993. DOE
does not plan to revise the test
procedure to incorporate IEC 60705
Edition 3.2–2006, to measure the
cooking efficiency, because DOE is
unaware of any efficiency comparison
data that would justify such a change.
However, as discussed above, DOE is
examining changes to the test procedure
to measure standby-power use.
d. Commercial Clothes Washers
DOE identified technologies to
improve the energy efficiency of CCWs.
The majority of these technologies are
described in the 1996 report entitled
Design Options for Clothes Washers.
(LBNL–47888, October 1996, Lawrence
Berkeley National Laboratory) Steam
washing and improved horizontal-axiswasher drum design were identified in
the September 2005 edition of
Appliance Magazine. DOE identified the
low-standby-power design option
during its engineering analysis review of
all AHAM product classes. It added
spray rinse and advanced agitator
design options in response to comments
received following the Framework
public meeting. DOE considered the
design options that follow.
• Adaptive control systems
• Added insulation
• Advanced agitation concepts for
vertical-axis machines
• Automatic fill control
• Bubble action
• Direct-drive motor
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• Electrolytic disassociation of water
• Horizontal-axis design
• Horizontal-axis design with
recirculation
• Improved fill control
• Improved horizontal-axis-washer
drum design
• Improved water extraction to lower
remaining moisture content
• Increased motor efficiency
• Low-standby-power design
• Ozonated laundering
• Reduced thermal mass
• Spray rinse or similar waterreducing rinse technology
• Steam washing
• Suds savings
• Thermostatically-controlled mixing
valves
• Tighter tub tolerance
• Ultrasonic washing
The Multiple Water Organizations
requested that DOE add the following
design options: (1) Spray rinse, (2)
nutating or other advanced agitators, (3)
advanced power supplies, and (4) steam
cleaning. (Multiple Water
Organizations, No. 11 at p. 1 ) ACEEE
requested that DOE consider more
water-saving design options (e.g., spray
rinse), in addition to energy-saving
design options. (Public Meeting
Transcript, No. 5 at p. 51) In a joint
letter, the Joint Comment requested the
addition of a spray wash design option.
(Joint Comment, No. 9 at p. 5)
DOE has added advanced agitation
concepts for vertical-axis washers.
These agitation systems include
nutating plates, side-mounted mounted
impellers, and any other agitation
technology that eliminates the need for
the traditional large and centrallymounted agitator found in vertical-axis
clothes washer tubs. While such
agitation systems are currently only
found on high-end residential clothes
washers, they have the potential to be
adapted for CCWs and can reduce the
water consumption of vertical-axis
clothes washers substantially.
DOE has also added spray rinse as a
design option but notes that this design
option may not be appropriate for the
commercial laundry market. ALS
commented that some water-reduction
design options (such as the ‘‘innovative
rinse technology’’ in its vertical-axis
models) have faced strong opposition
from some consumers. (ALS, No. 19 at
p. 1) Whirlpool noted that commercial
customers tend to overload their
washers, which leads to unacceptable
rinsing performance. (Whirlpool, No. 10
at p. 3) Given that the industry has
fielded washers with rinse-water use
reduction technologies (such as spray
rinse) in the past and continues to
develop other water saving approaches,
DOE will consider this design option.
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During the Framework public
meeting, stakeholders asked DOE
whether it will address standby power
in CCWs. Potomac suggested that DOE
consider technologies that limit standby
power in CCWs. Such design options
could include improved power supplies
or other technologies that limit power
consumption in standby mode. (Public
Meeting Transcript, No. 5 at p. 52) DOE
recognizes the importance of studying
all aspects of power consumption by
consumer appliances. With the growing
trend of upgrading consumer appliances
to use electronic controllers, standby
power has become a topic of interest
across all appliance categories.
During the Framework public
meeting, DOE solicited comments
regarding existing databases to track
CCW efficiencies. ALS commented that
the existing CEC database is a good
source of information and that DOE
should review it. (Public Meeting
Transcript, No. 5 at p. 44) DOE
subsequently used that database and
others to identify CCWs that meet
various modified energy factor (MEF)
and WF levels. Whenever possible, DOE
investigated the design options of the
listed washers, which then helped DOE
design the interview guides for the MIA
interviews with stakeholders to solicit
comments about design options.
Additional detail on the technology
assessment can be found in Chapter 3 of
the TSD.
B. Screening Analysis
1. Purpose
The purpose of the screening analysis
is to evaluate the design options that
improve the efficiency of a product, in
order to determine which options to
consider further and which options to
screen out because they may not be
technologically feasible, may exhibit
practicability problems (related to
manufacture, installation, or service),
may result in adverse impact on product
utility or product availability, or may
have an adverse impact on health or
safety. DOE consults with industry,
technical experts, and other interested
parties in developing a list of design
options for consideration. DOE then
applies the following set of screening
criteria to determine which design
options are unsuitable for further
consideration in the rulemaking (10 CFR
Part 430, Subpart C, Appendix A at
4(a)(4) and 5(b)).
a. Technological Feasibility
DOE will consider technologies
incorporated in commercial products or
in working prototypes to be
technologically feasible.
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b. Practicability To Manufacture, Install,
and Service
If mass production of a technology in
commercial products and reliable
installation and servicing of the
technology could be achieved on the
scale necessary to serve the relevant
market at the time of the effective date
of the standard, then DOE will consider
that technology practicable to
manufacture, install, and service.
c. Adverse Impacts on Product Utility or
Product Availability
If DOE determines a technology to
have significant adverse impact on the
utility of the product to significant
subgroups of consumers, or to result in
the unavailability of any covered
product type with performance
characteristics (including reliability),
features, sizes, capacities, and volumes
that are substantially the same as
products generally available in the U.S.
at the time, it will not consider this
technology further.
d. Adverse Impacts on Health or Safety
If DOE determines that a technology
will have significant adverse impacts on
health or safety, it will not consider this
technology further.
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2. Design Options
a. Dishwashers
For dishwashers, DOE screened out
reduced inlet-water temperature,
supercritical carbon dioxide washing,
and ultrasonic washing technologies, for
the reasons that follow.
Reduced inlet-water temperature
requires that dishwashers tap the cold
water line for the water supply, which
would require significant alteration of
existing dishwasher installations in
order to accommodate newly-purchased
units incorporating this design option.
Whirlpool commented that such a
retrofit of existing residential plumbing
necessary to accommodate a reduced
inlet-water temperature design would be
costly, and, therefore, DOE should
eliminate this design option.
(Whirlpool, No. 10 at p. 4) DOE agrees
that this design option does not meet
the screening criterion of practicability
to install. Therefore, DOE screened out
reduced inlet-water temperature from
further analysis. AHAM supported this
decision. (AHAM, No. 14 at p. 8)
Supercritical carbon dioxide washing,
in which supercritical carbon dioxide
dissolves grease from the dishware
instead of conventional detergent and
water, is in the research stage, so DOE
believes it would not be practicable to
manufacture, install, and service at the
time of the effective date of an amended
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standard. Furthermore, it is also not yet
possible to assess whether it will have
any adverse impacts on equipment
utility to consumers or equipment
availability, or any adverse impacts on
consumers’ health or safety. Therefore,
DOE screened out supercritical carbon
dioxide washing from further analysis.
For ultrasonic washing, high
frequency energy input into the wash
water creates cavitation bubbles that
remove soil from the dishware via
mechanical scrubbing action. With this
technology, consumer utility is
decreased due to the potential for the
ultrasonic cleaning action to damage
fragile dishware and due to the
perception that the low temperatures do
not sterilize dishes. Whirlpool also
commented that ultrasonic dishwashing
is beyond the technological scope of
current product development.
(Whirlpool, No. 10 at p. 4) Since no
manufacturer currently produces
ultrasonic dishwashers, it is impossible
to assess whether this design option
would have any impacts on consumer
health or safety, or product availability.
Therefore, DOE screened out ultrasonic
dishwashing from further analysis. In
comments submitted after the
Framework public meeting, AHAM
agreed that DOE should eliminate
ultrasonic dishwashing. (AHAM, No. 14
at p. 8) Table II.5 lists the dishwasher
design options that DOE has retained for
analysis.
TABLE II.5.—RETAINED DESIGN
OPTIONS FOR DISHWASHERS
1. Condenser drying.
2. Fan/jet drying.
3. Flow-through heating.
4. Improved fill control.
5. Improved food filter.
6. Improved motor efficiency.
7. Improved spray-arm geometry.
8. Increased insulation.
9. Low-standby-loss electronic controls.
10. Microprocessor controls and fuzzy logic,
including adaptive or soil-sensing controls.
11. Modified sump geometry, with and without dual pumps.
12. Variable washing pressures and flow
rates.
According to Whirlpool, soil sensors
have contributed to significant
dishwasher water and energy savings.
However, Whirlpool is unaware of any
further technological breakthroughs
which would dramatically change the
energy consumption of dishwashers.
Approximately 90 percent of
dishwashers are currently Energy Starqualified. (Whirlpool, No. 10 at p. 1)
DOE has noted that many dishwashers
are able to meet Energy Star
requirements without the use of a soil
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sensor. It may be assumed that the
incorporation of soil sensors to such
models offers the potential for
additional energy savings. DOE also
notes that there are multiple
technologies that can be used by
themselves or to complement others to
determine soiling levels inside a
dishwasher. For example, it is possible
to use a pressure sensor, rather than the
more typical turbidity sensors, to detect
clogging of a filter to infer soil loads.
The maximum technologically feasible
(‘‘max-tech’’) dishwasher that DOE
investigated went a step further,
featuring both a turbidity and a pressure
sensor, implying a benefit from using
both sensor technologies. Since there
are many approaches to and levels of
sophistication of soil sensing may be
taken to depending on the underlying
dishwasher platform, DOE will retain
soil sensing for further analysis.
Whirlpool also stated that variable
washing pressures and flow rates and
condenser drying are beyond the
technological scope of current product
development, and therefore DOE should
eliminate them from further analysis.
(Whirlpool, No. 10 at p. 4) AHAM stated
without elaboration that condenser
drying should be eliminated from the
analysis. (AHAM, No. 14 at p. 8) In
reviewing current dishwasher models,
DOE noted multiple instances in which
manufacturer specifications indicate
variable washing pressures and flow
rates. For example, such a strategy may
include alternating wash water to the
top and bottom racks. In addition, DOE
is aware of at least one dishwasher
platform on the market with true
condensation drying, in which
relatively cool ambient air is drawn
across the outside of the stainless steel
dishwasher cavity, providing a surface
on which moisture from the hotter
dishware can condense. Since variable
washing pressures and flow rates and
condenser drying are already in wide
distribution, DOE will retain these
design options for further analysis.
AHAM also requested that DOE
replace the term ‘‘fan/jet drying’’ with
the term ‘‘fan-assist drying’’ and clarify
the term ‘‘flow-through heating.’’
(AHAM, No. 14 at p. 8) DOE believes
that the change to fan-assist drying is
appropriate, and will designate the
design option in further analyses
accordingly.
‘‘Flow-through heating’’ is
differentiated from conventional
dishwasher heating by the positioning
of the heating element. Conventional
dishwasher heaters use a tubular
electric resistance element positioned
inside the dishwasher cavity, above the
sump, where it is exposed to the wash
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and rinse water. Flow-through heaters
pass the water through a metallic tube
around which a resistive heating
element is wrapped. Consequently, less
water is typically required in the
dishwasher sump for flow-through
heaters since they form an integrated
part of the water flow path and do not
require high levels of standing water
above the sump, as do tubular heating
elements. Therefore, the potential exists
for dishwashers using flow-through
heating to have reduced water and
energy consumption.
b. Dehumidifiers
For dehumidifiers, all technologies
meet the screening criteria.
Table II.6 lists the dehumidifier
design options that DOE has retained for
analysis.
TABLE II.6.—RETAINED DESIGN
OPTIONS FOR DEHUMIDIFIERS
1. Built-in hygrometer/humidistat.
2. Improved compressor efficiency.
3. Improved condenser performance.
4. Improved controls.
5. Improved defrost methods.
6. Improved demand-defrost controls.
7. Improved evaporator performance.
8. Improved fan and fan-motor efficiency.
9. Improved flow-control devices.
10. Low-standby-loss electronic controls.
11. Washable air filters.
c. Cooking Products.
For cooking products, Whirlpool
commented that DOE should eliminate
from this analysis all design options that
DOE eliminated in the previous
rulemaking for reasons of feasibility,
cost, and/or consumer safety.
(Whirlpool, No. 10 at pp. 5–7) DOE will
evaluate each design option again, and
only will eliminate from further
consideration those technologies that
fail to meet one or more of the screening
criteria.
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1. Cooktops and Ovens
For gas cooktops, DOE screened out
catalytic burners, radiant gas burners,
reduced excess air at burner, and
reflective surfaces for the reasons that
follow.
DOE is not aware of any
commercialized catalytic burners for gas
cooktops. Therefore, DOE believes they
would not be practicable to
manufacture, install, and service at the
time of the effective date of an amended
standard. Also, because this technology
is in the research stage, it is not possible
to assess whether it will have any
adverse impacts on equipment utility to
consumers or equipment availability, or
any adverse impacts on consumers’
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health or safety. Therefore, DOE has
decided to exclude catalytic burners
from further analysis.
In the previous rulemaking,
manufacturers concluded that infrared
jet-impingement radiant gas burners
would not be able to comply with the
ANSI Standard Z21.1–2005, Household
Cooking Gas Appliances. Field testing
had shown that users were unable to
turn down the burner satisfactorily,
which indicated a potential health and
safety risk. More recently, a silicon
carbide radiant burner has been tested
to the Japanese Industrial Standard (JIS)
S 2103–1996, Gas Burning Appliances
for Domestic Use, but there is no data
to evaluate whether this burner would
conform to the ANSI standard since it
is not commercially available in the U.S.
Due to potential impacts on consumer
health and safety, DOE screened out
radiant gas burners from further
analysis.
Reduced excess air at the burner has
not been definitively shown to increase
efficiency. Also, because the technology
has not been commercialized, DOE
believes it would not be practicable to
manufacture, install, and service at the
time of the effective date of an amended
standard. In addition, DOE cannot
assess adverse impacts on consumers’
utility, health, or safety or equipment
availability for this technology. Further,
Whirlpool suggests there are
combustion-related issues with reducing
excess air. (Public Meeting Transcript,
No. 5 at p. 94) DOE agrees that reducing
excess air at the burner increases the
possibility of adverse conditions such as
poor flame quality and elevated carbon
monoxide levels, which would suggest
adverse impacts on consumers’ utility,
health, and safety. For these reasons,
DOE screened out reduced excess air at
the burner from further analysis.
In the previous rulemaking,
manufacturers reported adverse impacts
on consumer utility due to the
requirement for regular and careful
cleaning of reflective surfaces, and this
concern remains at present. In addition,
since this technology has still not been
commercialized, DOE cannot assess the
impacts on consumer health and safety
or equipment availability. Therefore,
DOE screened out reflective surfaces for
gas cooktops from further analysis.
Table II.7 lists the gas cooktop design
options that DOE has retained for
analysis.
TABLE II.7.—RETAINED DESIGN
OPTIONS FOR GAS COOKTOPS
1. Electronic ignition.
2. Insulation.
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TABLE II.7.—RETAINED DESIGN OPTIONS FOR GAS COOKTOPS—Continued
3. Sealed burners.
4. Thermostatically-controlled burners.
The Joint Comment agreed with the
inclusion of electronic ignition for gas
ranges, and thereby for gas cooktops and
ovens. They stated that earlier analysis
found significant, cost-effective savings
achieved by eliminating pilot lights.
(Joint Comment, No. 9 at p. 3)
For electric open (coil) cooktops, DOE
screened out reflective surfaces, for the
reasons that follow.
In the previous rulemaking,
manufacturers reported adverse impacts
on consumer utility due to the
requirement for regular and careful
cleaning of reflective surfaces, and this
concern remains at present.
Furthermore, because this technology
has still not been commercialized, DOE
cannot assess its impacts on consumer
health and safety or equipment
availability. Therefore, DOE screened
out reflective surfaces from further
analysis for electric coil cooktops.
Table II.8 lists the electric open (coil)
cooktop design options that DOE has
retained for analysis.
TABLE II.8.—RETAINED DESIGN OPTIONS FOR ELECTRIC OPEN (COIL)
ELEMENT COOKTOPS
1.
2.
3.
4.
Electronic controls.
Improved contact conductance.
Insulation.
Low-standby-loss electronic controls.
For electric smooth cooktops, all
technologies meet the screening criteria.
Table II.9 lists the electric smooth
cooktop design options that DOE has
retained for analysis.
TABLE II.9.—RETAINED DESIGN OPTIONS FOR ELECTRIC SMOOTH ELEMENT COOKTOPS
1.
2.
3.
4.
Electronic controls.
Halogen elements.
Induction elements.
Low-standby-loss electronic controls.
For ovens, DOE screened out added
insulation, bi-radiant oven, halogen
lamp oven, no oven door window, oven
separator, reduced thermal mass, and
reflective surfaces, for the reasons that
follow.
Although some analyses have shown
reduced energy consumption by
increasing the thickness of the
insulation in the oven cabinet walls and
doors from two inches to four inches,
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consumer utility would be negatively
impacted by the necessary reduction in
cavity volume to maintain the same
oven footprint and overall cabinet
volume. Therefore, DOE screened out
added insulation. The improved
insulation design option, however, will
be retained, because insulation with a
higher density (i.e., greater insulating
value) does not require additional space
and thus would not impact oven cavity
size.
The last working prototype of a biradiant oven known to DOE was tested
in the 1970s. The technology requires a
low-emissivity cavity, electronic
controls, and highly absorptive cooking
utensils. The need for specialized
cookware and cavity maintenance issues
negatively impact consumer utility.
Therefore, DOE screened out bi-radiant
ovens from further analysis.
While GE currently markets a line of
electric ovens that incorporates halogen
elements along with conventional
resistance heating elements, microwave
heating, and, optionally, a convection
system, DOE is not aware of any ovens
that utilize halogen lamps alone as the
heating element, and no data were
found or submitted to demonstrate how
efficiently halogen elements alone
perform relative to conventional ovens.
DOE believes that it would not be
practicable to manufacture, install, and
service halogen lamps for use in
consumer cooking products on the scale
necessary to serve the relevant market at
the time of the standard’s effective date.
Therefore, DOE screened out halogen
lamp ovens.
The previous rulemaking’s analysis
reported a small annual energy savings
associated with no oven door window,
but that consumer practices of opening
the door to inspect the food while
cooking could negate any benefit. EEI
commented during the Framework
public meeting that DOE should
eliminate the no oven door window
design option due to the potential
impact on utility and safety, and it is
likely that the technology is not a
feasible option for most ovens. EEI also
suggested evaluating double-pane or
similar oven door windows. (Public
Meeting Transcript, No. 5 at p. 94; EEI,
No. 7 at p. 6) DOE agrees that reduced
consumer utility along with decreased
safety due to the additional door
openings justify elimination of this
design option from further analysis. In
addition, DOE addresses the efficiency
impact of double-pane or other highly
insulated oven door windows by means
of the reduced conduction losses design
option, which has been retained for
further analysis.
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An oven separator has been
researched but has never been put into
production. Manufacturers stated during
the previous rulemaking that a separator
could not be economically designed for
conventional gas ovens. The use of a
separator in electric ovens would
require the installation of an additional
element and a non-conventional control
system. Manufacturers also stated that it
would be difficult to obtain
Underwriters Laboratory and AGA
approvals and meet existing ANSI
standards because of the effect the
separator would have on safety and
performance. Manufacturers also stated
that consumer acceptance would
probably be low because appliances
such as microwave and toaster ovens
already exist to cook small loads. In
addition, the separator would have to be
designed to be ‘‘fool-proof’’ to prevent
consumers from accidentally installing
it incorrectly. With regard to energy use,
the additional metal added to the oven
by the separator (increased thermal
mass) might result in increased energy
losses, although data provided by
AHAM indicated an increase in
efficiency of approximately 0.82
percentage points in an electric oven.
However, the anticipated negative
impacts on consumer utility and safety,
along with practicability to
manufacture, resulted in DOE screening
out the oven separator from further
analysis. Whirlpool expressed support
for elimination of this design option,
mentioning consumer safety as one of
many issues. (Public Meeting
Transcript, No. 5 at p. 95) For example,
safety issues could arise in a gas oven
if the separator is incorrectly installed,
resulting in improper burner operation.
In the previous rulemaking,
manufacturers commented that a
thermal mass reduction in ovens was
not possible without compromising
structural integrity (during both use and
transportation) and increasing heat
losses. Although tests by the Gas
Research Institute (GRI) showed a small
efficiency improvement, the issues of
structural integrity and associated
consumer product safety led DOE to
eliminate thermal mass reduction from
further analysis.
Manufacturers stated in the previous
rulemaking that reflective surfaces
degrade throughout the life of the oven,
particularly for self-cleaning ovens, and
GRI reported tests that showed this
design option can actually result in a
decrease of energy efficiency. The
uncertainty in energy savings, coupled
with a lack of sophistication in the
technology in terms of maintaining the
reflective surfaces over the lifetime of
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the oven, led DOE to eliminate this
technology from further analysis.
Table II.10 lists the gas and electric
oven design options that DOE has
retained for analysis.
TABLE II.10.—RETAINED DESIGN OPTIONS FOR GAS AND ELECTRIC
OVENS
1.
2.
3.
4.
5.
6.
7.
8.
9.
Forced convection.
Improved door seals.
Improved insulation.
Low-standby-loss electronic controls.
Pilotless ignition (gas only).
Radiant burner (gas only).
Reduced conduction losses.
Reduced vent rate.
Steam cooking.
The Joint Comment recommended
that DOE study the energy used by
ignition devices in gas ovens. (Joint
Comment, No. 9 at p. 3) DOE will
include the gas energy consumption of
pilot lights and electrical energy
consumption of pilotless ignition in the
engineering analysis (see Chapter 5 of
the TSD).
2. Microwave Ovens
For microwave ovens, all technologies
meet the screening criteria.
Table II.11 lists the microwave oven
design options that DOE has retained for
analysis.
TABLE II.11.—RETAINED DESIGN
OPTIONS FOR MICROWAVE OVENS
1. Added insulation.
2. Cooking sensors.
3. Dual magnetrons.
4. Eliminate or improve ceramic stirrer cover.
5. Improved fan efficiency.
6. Improved magnetron efficiency.
7. Improved power supply efficiency.
8. Low-standby-loss electronic controls.
9. Modified wave guide.
10. Reflective surfaces.
AHAM submitted written comments
on the microwave oven design options.
For improved fan efficiency, AHAM
commented that, since the fan accounts
for less than 2 percent of the total
energy consumption in the microwave
oven, a high efficiency fan would
improve energy factor by less than 0.5
percent. Therefore, AHAM argued that
efficient fans are not economically
justified. (AHAM, No. 17 at pp. 2–3)
However, AHAM did not provide any
data that supported their conclusion of
a lack of economic justification.
Therefore, DOE will consider improved
fan efficiency in its analysis.
According to AHAM, considerable
effort has already been expended to
optimize magnetron efficiency.
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Manufacturers’ specifications indicate
that typical efficiency is about 73
percent with only a plus or minus 2
percentage point variance. Thus, AHAM
argued that there is little opportunity to
improve microwave energy efficiency
for manufacturers using magnetrons.
(AHAM, No. 17 at p. 3) A literature
review that DOE performed, however,
determined that oscillation efficiencies
of up to 78 percent have been reported.
DOE has decided to retain improved
magnetron efficiency for analysis,
because this design option: (1) Is
technologically feasible; (2) is
practicable to manufacture, install, and
service; (3) does not result in loss of
product utility or product availability;
and (4) does not have adverse impacts
on health or safety.
AHAM commented that there are two
types of high-voltage power supplies
used in microwave ovens, as described
below. The most common type is the
inductive capacitance transformer,
which has an efficiency of about 82
percent. More expensive inverter-based
power supplies are about 84 percent
efficient. Higher efficiency general
purpose transformers do not have stable
enough output power for microwave
oven application. AHAM stated that,
among the units tested, there was no
correlation between power supply type
and cooking efficiency. AHAM also
does not believe there is a cost-effective
opportunity for improving the efficiency
of the power supply. (AHAM, No. 17 at
p. 3) However, AHAM did not submit
any data demonstrating a lack of
correlation between power supply type
and cooking efficiency or refuting
economic justification. Therefore, DOE
will consider improved power supply
efficiency in its analysis, during which
it will assess economic viability.
For reflective surfaces, AHAM
commented that manufacturers are
already using surface finishes to
optimize efficiency. Also, AHAM stated
that proper oven cavity design would
obviate the need to add any metallic
plates inside the cavity to match the
highest oscillation impedance of the
magnetron. (AHAM, No. 17 at p. 2)
Testing by manufacturers, however, has
shown that a high-grade stainless steel
or reflective material steel coating can
improve efficiency by 0.5 percent over
painted cold-rolled steel. Since DOE is
aware of data demonstrating efficiency
improvement as a function of surface
reflectivity, DOE will retain reflective
surfaces for analysis.
d. Commercial Clothes Washers
During the Framework public meeting
and Framework comment period, DOE
solicited comments from stakeholders
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regarding which design options found
in residential clothes washers would be
applicable to CCWs. However, multiple
manufacturers of CCWs cautioned that
CCWs are not just slightly modified
extensions of their residential product
lines, and, thus, some design options
currently found on their residential
lines may not be applicable for
commercial use.
In addition, ALS requested that DOE
recognize the unique environment in
which CCWs operate and how that
precludes the implementation of several
design options found in the residential
market. Such options could be
incompatible with the requirements
regarding ruggedness, reliability, and
performance routinely demanded in a
commercial setting. (Public Meeting
Transcript, No. 5 at p. 43) For example,
Whirlpool stated that design options
such as spray rinse have not performed
adequately in commercial settings due
to the routine problem of overloading by
consumers. Commenters also asserted
that inadequate rinsing performance
typically leads consumers to re-run
loads, thereby increasing water and
energy consumption.
Whirlpool, ALS, and AHAM
requested that the following design
options be removed from consideration:
Bubble action, electrolytic
disassociation of water, ozonated
laundering, reduced thermal mass, suds
saving, ultrasonic washing, and
horizontal-axis design. Whirlpool and
AHAM additionally requested that
steam washing be removed from
consideration. Whirlpool stated that all
of the aforementioned design options
were removed from consideration
during the recent residential clothes
washer rulemaking and, therefore,
should be removed from consideration
during this rulemaking as well. ALS
provided a similar rationale for the
design options it requested to be
excluded. AHAM further requested that
the improved horizontal-axis-washer
drum design option be removed.
(Whirlpool, No. 10 at p. 3; Public
Meeting Transcript, No. 5 at p. 49;
AHAM, No. 14 at p. 7)
In light of the available information,
DOE subsequently screened out bubble
action, electrolytic disassociation of
water, ozonated laundering, reduced
thermal mass, suds saving, and
ultrasonic washing from further
analysis, for the reasons that follow.
Although bubble washing has been
incorporated into commercial products,
production is extremely limited and
further commercialization would
require manufacturers to develop
entirely new platforms. Therefore, DOE
does not believe that this technology
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would be practicable to manufacture,
install, and service on the scale
necessary to serve the relevant market at
the time of the effective date of an
amended standard. For these reasons,
DOE screened out the bubble action
design option.
DOE is not considering electrolytic
disassociation of water and ozonated
laundering because these technologies
are at the research stage. Therefore, DOE
believes that it would not be practicable
to manufacture, install, and service
either technology on the scale necessary
to serve the relevant market at the time
of the effective date of an amended
standard. Also, because these
technologies are in the research stage, it
is not possible to assess whether they
will have any adverse impacts on
equipment utility to consumers or
equipment availability, or any adverse
impacts on consumers’ health or safety.
Therefore, DOE screened out electrolytic
disassociation of water and ozonated
laundering as design options for
improving the energy efficiency of
CCWs.
Reduced thermal mass has not been
incorporated into clothes washers, so
DOE believes that it would not be
practicable to manufacture, install, and
service this technology on the scale
necessary to serve the relevant market at
the time of the effective date of an
amended standard. Also, because this
technology has not been incorporated
into clothes washers, it is not possible
to assess whether it will have any
adverse impacts on equipment utility to
consumers or equipment availability, or
any adverse impacts on consumers’
health or safety. Therefore, DOE
screened out reduced thermal mass as a
design option for improving the energy
efficiency of CCWs.
Suds-saving residential clothes
washers, in which wash water is stored
for subsequent reuse, were previously
commercially available, but required an
adjacent washtub to store suds in
between wash cycles. Due to these
installation requirements, DOE believes
that suds saving clothes washers would
be impractical to install in many
locations. Suds-saving clothes washers
reduce consumer utility by requiring
consumers to occupy space adjacent to
the washer with an additional washtub.
In a commercial setting, this may limit
the number of clothes washers that may
be installed. Consumers must also wash
clothes sequentially to fully capture the
energy saving benefits of suds saving.
Delays between wash cycles allow the
saved water to cool, reducing wash
performance and energy savings.
Finally, suds-saving clothes washers can
carry over heavy soiling between
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clothing loads, reducing wash
performance as well. Therefore, DOE
will not consider suds saving as a
design option for improving the energy
efficiency of commercial clothes
washers.
Ultrasonic washing promotes
mechanical soil removal through the
introduction of ultrasonic vibrations
into the wash tub. This technology has
been demonstrated in clothes washers,
but the ultrasonic clothes washer did
not adequately remove soil from the
clothes. Thus, ultrasonic clothes
washing would reduce consumer utility
by not adequately washing clothes. In
addition, bubble cavitations caused by
standing ultrasonic waves could
potentially damage some fragile clothing
or clothing fasteners, further reducing
consumer utility. Since no
manufacturers currently produce
ultrasonic clothes washers, it is
impossible to assess whether it will
have any impacts on consumers’ health
or safety, or product availability. For
these reasons, DOE screened out
ultrasonic washing as a design option
for improving the energy efficiency of
CCWs.
In the comment period following the
Framework public meeting, EEI
suggested that at least one major
detergent manufacturer has formulated a
cold-water detergent, capable of
washing all types of clothes in cold
water. According to EEI, such detergents
promise significant energy savings since
they could eliminate the need for heated
water in CCWs. (EEI, No. 7 at p. 4)
While cold-water detergents show
promise, the present clothes washer test
procedure does not recognize the
potential energy benefits of such
detergents. DOE will consider possible
future amendments to the test procedure
to account for cold-water detergents.
Thus, in the context of the present
rulemaking, DOE will not analyze the
potential impact of cold-water
detergents.
Table II.12 lists the CCW design
options that DOE has retained for
analysis. For further review of the
retained design options, please see
Chapter 3 of the TSD.
TABLE II.12.—RETAINED DESIGN OP- is due to past input from stakeholders
TIONS FOR COMMERCIAL CLOTHES who were concerned about the
possibility of double-counting the
WASHERS—Continued
8. Improved fill control.
9. Improved horizontal-axis-washer drum design.
10. Improved water extraction to lower remaining moisture content.
11. Increased motor efficiency.
12. Low-standby-power design.
13. Spray rinse or similar water-reducing
rinse technology.
14. Steam washing.
15. Thermostatically-controlled mixing valves.
16. Tighter tub tolerance.
In general, for more detail on how
DOE developed all of the technology
options discussed above and the process
for screening these options, refer to the
technology and screening section
(Chapter 4) of the TSD.
C. Engineering Analysis
In the engineering analysis DOE
evaluates a range of product efficiency
levels and their associated
manufacturing costs. The purpose of the
analysis is to estimate the incremental
manufacturer selling prices for a
product that would result from
achieving increased efficiency levels,
above the level of the baseline model, in
each product class. The engineering
analysis considers technologies and
design option combinations not
eliminated in the screening analysis.
The LCC analysis uses the costefficiency relationships developed in
the engineering analysis.
DOE typically structures its
engineering analysis around one of three
methodologies. These are: (1) The
design-option approach, which
calculates the incremental costs of
adding specific design options to a
baseline model; (2) the efficiency-level
approach, which calculates the relative
costs of achieving increases in energy
efficiency levels, without regard to the
particular design options used to
achieve such increases; and/or (3) the
reverse engineering or cost-assessment
approach, which involves a ‘‘bottomup’’ manufacturing cost assessment
based on a detailed bill of materials
derived from teardowns of the product
being analyzed. Deciding which
TABLE II.12.—RETAINED DESIGN OP- methodology to use for the engineering
TIONS FOR COMMERCIAL CLOTHES analysis depends on the product, the
WASHERS
design options under study, and any
historical data that DOE can draw on.
1. Adaptive control systems.
Traditionally, DOE used a design2. Added insulation.
approach for all of its cost-benefit
3. Advanced agitation concepts for verticalanalyses. However, in more recent
axis machines.
rulemakings, DOE has shifted to using
4. Automatic water fill control.
an efficiency-level approach that may or
5. Direct-drive motor.
may not be supplemented with a
6. Horizontal-axis design.
reverse-engineering analysis. The shift
7. Horizontal-axis design with recirculation.
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energy-efficiency benefits of various
design options. While the efficiencylevel approach has the benefit of being
absolute (each appliance has a tested
efficiency and derivable manufacturing
cost), it depends on the appliance
actually having an efficiency test that
manufacturers report. For product
classes where there are no published
efficiencies, a design-option approach
remains the best alternative to an
efficiency-level approach.
1. Approach
DOE solicited comments during the
Framework public meeting and
subsequent comment period on the
possible approaches to the engineering
analysis. ALS and AHAM stated during
the Framework public meeting that they
support the efficiency-level approach
generally, and ACEEE commented that
the efficiency-level approach should be
verified with the design-option
approach, recognizing that there is
variation in how manufacturers
implement design options. (Public
Meeting Transcript, No. 5 at pp. 65, 73
and 107–110) AHAM commented that
manufacturers will use different design
options to achieve higher efficiency
levels. (Public Meeting Transcript, No. 5
at p. 55) AHAM stated that the designoption approach has validity only for
cooking products, but can serve as a
means of cross-checking the analysis for
the other products. (Public Meeting
Transcript, No. 5 at p. 110) Whirlpool,
GE, and AHAM stated that DOE should
analyze CCWs, dishwashers, and
dehumidifiers with the efficiency-level
approach, while using a design-option
approach for cooking products.
(Whirlpool, No. 10 at pp. 4 and 7; GE,
No. 13 at p. 3; AHAM, No 14 at pp. 4–
9)
In comments submitted during the
comment period after the Framework
public meeting, the Joint Comment
disagreed with using the efficiency-level
approach as the primary means to
estimate efficiency costs. The Joint
Comment stated that the design-option
approach is very important and should
be included for all products as a
complement to and validation of
manufacturer estimates. The Joint
Comment stated that manufacturers
have historically estimated higher costs
during the rulemaking stage, as
compared to the actual costs when the
standards take effect. In addition, the
design-option approach allows
interactions between design options to
factor into the analysis to take advantage
of synergies between measures and to
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avoid double-counting of energy
savings. The Joint Comment also
expressed the need for DOE to make
detailed manufacturing cost data
publicly available, while maintaining
manufacturers’ confidentiality to protect
their competitive positions. They
described manufacturer cost estimates
as a ‘‘black box’’ for other stakeholders.
(Joint Comment, No. 9 at pp. 1–2)
DOE conducted the engineering
analysis for this rulemaking using an
efficiency-level approach supplemented
by a design-option approach for CCWs,
dishwashers, and dehumidifiers. DOE
based this analysis on detailed
incremental cost data primarily
supplied by AHAM. DOE supplemented
these industry-supplied data with its
own design-option analysis by
performing limited product efficiency
testing and physical teardown analysis
of several dishwashers and
dehumidifiers, and by conducting
manufacturer interviews for all three
products. The teardown analysis used
the reverse engineering approach and
resulted in the production of detailed
bills of materials for dishwashers and
dehumidifiers.
For cooking products, DOE conducted
the engineering analysis for this
rulemaking using the design-option
approach, under which it identifies
incremental increases in manufacturer
selling prices for each design option or
combination of design options. As
discussed in section I.B.1 of this
ANOPR, DOE based much of this
analysis on cost and efficiency
information supplied in the previous
rulemaking’s analysis, with costs
updated to reflect current pricing. DOE
supplemented this analysis with new
data that AHAM supplied for
microwave ovens.
In summary, DOE used an efficiencylevel approach supported by a designoption approach for CCWs,
dishwashers, and dehumidifiers, and a
design-option approach for cooking
products. Stakeholders were supportive
of this approach for cooking products.
For CCWs, dishwashers, and
dehumidifiers, DOE supplemented the
industry-supplied data with
consultation with outside experts and
further review of publicly available cost
and performance information. The
supplemental design-option analysis
(which included the reverse
engineering) allowed for validation of
the efficiency-level data, transparency
in assumptions and results, and the
ability to perform independent analyses
for verification. In addition, the
supplemental design-option analysis
allowed DOE to generate analyticallyderived cost-efficiency curves for
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product classes for which industrysupplied curves were not provided. The
methodology DOE used to perform the
efficiency-level and design-option
analyses is described in further detail in
the engineering analysis (Chapter 5 of
the TSD).
The Joint Comment recommended
that the computation of manufacturing
costs also take into account the effect of
market forces by using the simple
average of the lowest cost estimate and
the weighted-average cost. The Joint
Comment stated that manufacturers
with below-average costs will determine
market prices, since higher-priced
manufacturers will need to ‘‘sharpen
their pencils’’ to reduce costs in order
to maintain market share. Additionally,
the Joint Comment stated that
manufacturers should ensure that their
cost estimates reflect mass production,
since efficiency standards will make
today’s niche products commodity
products in the future. (Joint Comment,
No. 9 at p. 2) In response, we note that
DOE conducted its analysis using the
average costs provided by industry,
because DOE believes these are the most
representative of manufacturer costs.
The AHAM-supplied average cost by
efficiency level is shipment-weighted,
which thus represents the most likely
average cost for the industry to make an
incremental efficiency change. The
limited DOE reverse-engineering
analysis based on two dishwasher
platforms that span an efficiency range
from 0.58 to 1.11 EF also largely agreed
with the AHAM-supplied average
incremental cost data. The effects of
mass production were captured in the
cost estimates and reflected in the
production volume estimates that
AHAM provided, as well as in the
production volumes used in DOE’s cost
modeling.
The methodology DOE used to
perform the efficiency-level and designoption analyses and reverse engineering
are described in further detail in the
engineering analysis chapter (Chapter 5)
of the TSD.20
2. Technologies Unable To Be Included
in the ANOPR Analysis
In performing the engineering
analysis, DOE did not consider for
analysis certain technologies that met
the screening criteria but were unable to
be further evaluated for one or more of
the following reasons: (1) Data are not
20 The engineering analysis does not take into
account future increases in manufacturing
efficiency which would affect the cost-efficiency
relationship, due to the inherently speculative
nature of such an inquiry. Accordingly, this
analysis is based on extant products and
manufacturing processes.
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available to evaluate consumer usage of
a product incorporating the technology,
and, therefore the test procedure
conditions and methods may not be
applicable; (2) data are not available to
evaluate the energy efficiency
characteristics of the technology; and (3)
available data suggest that the efficiency
benefits of the technology are negligible.
In the first two cases, DOE is unable to
adequately assess how these
technologies impact annual energy
consumption. Although it did not
consider these technologies further in
the ANOPR analyses, DOE specifically
seeks data and inputs on consumer
usage, performance characteristics, and
representative test methods and
conditions to extend the analyses to
these technologies and to evaluate the
test procedures for the NOPR. This is
identified as Issue 6 under ‘‘Issues on
Which DOE Seeks Comment’’ in section
IV.E of this ANOPR.
For technologies that lack consumer
usage details (including operating
conditions, duration, and frequency),
DOE believes that the existing test
procedures may specify conditions and
methods that are not representative of
actual usage. DOE further believes that
even if data were available to amend the
test procedure, such changes could be
extensive enough to require total
revision, which in turn could warrant
the creation of a separate product class
for that technology in the event that the
test procedure changes indicated unique
utility. For example, many
dehumidifiers feature a built-in relative
humidity (RH) sensor, or hygrometer,
and most (including all units upon
which DOE conducted reverseengineering) feature a built-in
humidistat, a device that allows the
consumer to set the desired RH level for
the room. When the humidity near the
dehumidifier drops below the userdefined or pre-set value, the
dehumidifier automatically shuts off.
This sensor-controlled system
presumably saves energy by avoiding
running the dehumidifier when the RH
is such that further dehumidification
would be neither effective nor desirable.
However, there is no industry consensus
on patterns in ambient conditions and
usage. If such parameters were known to
DOE, the test procedure, which
currently specifies constant ambient
temperature and humidity, would need
to be revised to measure energy savings
associated with these technologies.
Therefore, the built-in hygrometer/
humidistat design option was not
considered for further analysis. Similar
exclusions based on lack of information
on representative consumer usage were
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made for several other design options.
For dehumidifiers, these included
improved controls, improved flowcontrol devices, and low-standby-loss
controls. For cooking products, these
included thermostatically-controlled gas
cooktop burners, electronic controls for
electric cooktops, cooking sensors for
microwave ovens, and steam cooking for
electric ovens.
Furthermore, certain technologies
cannot be measured according to the
conditions and methods specified in the
existing test procedure. For example,
induction cooktops require
ferromagnetic cookware in order to
transfer energy to the food contents. The
test block specified in the DOE test
procedure is aluminum and thus is
unable to measure the efficiency of
induction cooktops. Although DOE is
aware of a NIST study that suggests
induction cooktops provide an
efficiency improvement over baseline
electric smooth cooktops, DOE did not
consider this design option further in
the ANOPR analysis because of the
unresolved nature of the NIST data.
DOE seeks input from stakeholders on
whether the NIST data warrants further
study for the NOPR. Similarly, for
dehumidifiers DOE excluded improved
defrost measures and washable air
filters. Low-standby-loss electronic
controls were not analyzed for electric
cooktops, microwave ovens, and
commercial clothes washer because,
even though DOE considers consumer
usage of these products to be welldefined, the current test procedures do
not measure standby power. For
microwave ovens specifically, for
reasons described in section I.D.4.b,
DOE is considering amending the test
procedure to incorporate a measurement
of standby power consumption. Other
cooking product technologies that do
not have energy benefits captured by the
test procedures include radiant burners
for gas ovens. As mentioned above, DOE
specifically seeks data and inputs on
representative test methods and
conditions to extend the analyses to
these technologies and to evaluate the
test procedures for the NOPR. This is
identified as Issue 6 under ‘‘Issues on
Which DOE Seeks Comment’’ in section
IV.E of this ANOPR.
Available data suggest that some of
the design options would result in such
small energy savings as to be negligible.
For example, according to AHAM, dual
magnetrons in microwave ovens do not
improve energy efficiency due to the
added losses associated with two
magnetron heaters. AHAM also
commented that are no significant
energy savings opportunities associated
with improved ceramic stirrers,
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modified waveguides, or added
insulation. (AHAM, No. 17 at pp. 2–3)
Similarly, DOE is unaware of any data
that indicates a measurable energy
efficiency impact of insulation in gas
and electric coil cooktops. DOE will be
reevaluating microwave oven design
options through reverse-engineering,
and will update the design options and
efficiency levels as necessary for the
NOPR. For commercial clothes washers,
DOE removed improved drum designs
for horizontal-axis clothes washers.
Because DOE intends to focus on the
technologies with measurable impact on
efficiency, design options with
negligible energy savings have been
eliminated from further consideration.
For further information on these
design options, refer to the market and
technology assessment chapter (Chapter
3) and engineering analysis chapter
(Chapter 5) of the TSD.
3. Product Classes, Baseline Models,
and Efficiency Levels Analyzed
DOE conducted the engineering
analysis on the single product class for
CCWs and on all product classes for
cooking products. For dishwashers,
DOE identified baseline models and
efficiency levels for the standard-sized
dishwasher product class. It then scaled
these standard dishwasher efficiency
levels by the ratio of the current
minimum efficiency standards for
standard-versus-compact product
classes to obtain the efficiency levels for
compact-sized machines. For
dehumidifiers, DOE conducted the
engineering analysis on product classes
for which it received incremental cost
data, with the expectation that the
analysis results will be extended to the
remaining product classes in subsequent
analyses.
For each product class, DOE selected
a baseline model as a reference point,
against which to measure changes
resulting from energy conservation
standards. The baseline model in each
product class represents the basic
characteristics of products in that class.
Typically, it is a model that just meets
current required energy conservation
standards.
Tables II.13 through II.20 provide all
of the efficiency levels DOE analyzed in
the engineering analysis and the
reference source of each level for each
of the four appliance product classes
analyzed. Many of these efficiency
levels correspond to those set by energy
efficiency programs or organizations,
including the DOE and EPA Energy Star
Program, and the CEE. DOE calculated
other levels from existing levels to fill
in gaps.
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For the purpose of today’s ANOPR,
DOE considers the highest candidate
standard levels, identified in section
II.C.3 below, to be the maximum
technologically feasible level. DOE
notes that in some cases the highest
efficiency level was identified based on
a review of available product literature
for products commercially available
(i.e., commercial clothes washers and
dehumidifiers). For cooking products,
the maximum levels identified in
section II.C.3.c are based on data
developed from the design option
analysis in the previous rulemaking.
(For more information, see the market
and technology assessment (Chapter 3)
and engineering analysis (Chapter 5) of
the TSD.) Because DOE is required to
determine the maximum technologically
feasible energy efficiency level(s) in any
notice of proposed rulemaking (42
U.S.C. 6295 (p)(2)), DOE seeks comment
on the highest energy efficiency levels
identified in today’s ANOPR for the
purpose of determining appropriate
maximum technologically feasible
energy efficiency levels in the proposed
rule.
a. Dishwashers
For dishwashers, the energy
conservation standards are expressed as
a minimum EF, which is a function of
cycles per kWh. In this rulemaking,
DOE is using baseline models that have
the following efficiencies, which are the
current minimum standards for compact
and standard capacity dishwashers (10
CFR 430.32(f)):
• Compact = 0.62 EF
• Standard = 0.46 EF
For standard dishwasher efficiency
levels, DOE used the Energy Star
criteria, CEE Tier 1 and 2 levels, and the
current maximum technology that is
commercially available. DOE also added
two levels to fill the gap between CEE
Tier 2 and the current maximum
technology that is commercially
available. DOE achieved scaling for
compact dishwashers by using the ratio
of current standard levels for standard
size versus compact size units, although
it determined the max-tech level by a
review of technology in the current
Energy Star database of certified
dishwashers. Table II.13 lists the levels
DOE analyzed for compact and standard
dishwashers:
TABLE II.13.—EFFICIENCY LEVELS FOR
RESIDENTIAL DISHWASHERS
Efficiency levels
Energy Factor,
(cycles/kWh)
Compact
Baseline ....................
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In light of the above, DOE believes
TABLE II.13.—EFFICIENCY LEVELS FOR
RESIDENTIAL DISHWASHERS—Con- that setting the baseline at the current
Federal standard appropriately analyzes
tinued
Efficiency levels
Energy Factor,
(cycles/kWh)
Compact
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1
2
3
4
5
6
7
................................
................................
................................
................................
................................
................................
................................
Standard
0.78
0.84
0.88
0.92
1.01
1.08
1.74
0.58
0.62
0.65
0.68
0.72
0.80
1.11
DOE has specified the current Federal
dishwasher standard as the baseline
unit efficiency level, recognizing that a
significant percentage of dishwashers on
the market meet or exceed Energy Star
levels. Whirlpool agreed with this
approach, commenting that this baseline
efficiency level maintains a necessary
entry-level product. It noted that raising
the baseline efficiency above the
standard could make entry-level
dishwashers unaffordable to low-end
consumers, thus driving down market
penetration of dishwashers and
increasing hand-washing and the
associated water and energy
consumption. Whirlpool also
commented that market-pull programs
such as Energy Star are responsible for
higher efficiency units on the market.
(Public Meeting Transcript, No. 5 at pp.
59–60 and 66–67; Whirlpool, No. 10 at
p. 8)
Northwest Power and Conservation
Council (NWPCC), however,
commented that the baseline EF may
need to be raised above the current
Federal standard. (Public Meeting
Transcript, No. 5 at p. 57) Other
stakeholders agreed. For example,
Potomac commented that the baseline
EF should represent a shipmentweighted average (likely to be between
0.46 and 0.58), which was the Energy
Star level in effect at the time of the
Framework public meeting. (Public
Meeting Transcript, No. 5 at pp. 123–
124) ACEEE commented that, since over
80 percent of the market meets the
current Energy Star level, that level
might be appropriate as the baseline.
(Public Meeting Transcript, No. 5 at p.
124) After the Framework public
meeting, the Multiple Water
Organizations stated that the baseline
should be above the current Federal
standard, and that using the standard as
the baseline would distort the analyses
by making higher efficiency levels
appear more costly and burdensome to
achieve than they really are. (Multiple
Water Organizations, No. 11 at p. 3)
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entry-level dishwashers, and, thus, we
are retaining an engineering baseline EF
of 0.46 for standard-sized dishwashers.
As will be discussed in section II.G.2.d,
because some consumers already
purchase products with efficiencies
greater than the baseline levels, the LCC
and PBP analysis considers the
distribution of products currently sold.
This is done to accurately estimate the
percentage of consumers that would be
affected by a particular standard level
and to prevent overstating the benefits
to consumers of increased minimum
efficiency standards. Also, as will be
discussed in section II.I.2, the resulting
shipment-weighted efficiency (SWEF)
that is determined from the distribution
of products currently sold, as well as
historical SWEFs, are accounted for in
the NIA.
Whirlpool commented that, of the
efficiency levels suggested in the
Framework Document, efficiency levels
up to an EF of 0.68 are reasonable, while
the ‘‘gap fill’’ levels are arbitrary and the
max-tech level is taken from an
extremely expensive, niche machine
from a manufacturer with negligible
market share. (Whirlpool, No. 10 at p. 4)
ACEEE and the Joint Comment
recommended including an efficiency
level for standard dishwashers between
the 0.68 and 0.75 EF levels. They
suggested an EF of 0.71 or 0.72 since
there are three manufacturers with
models currently at 0.72 EF. (Public
Meeting Transcript, No. 5 at p. 124;
Joint Comment, No. 9 at p. 4) DOE
selected a 0.72 EF dishwasher as one of
its teardown units on the basis of its
highest level of design option
combinations for a given platform.
Additionally, AHAM stated that some
efficiency levels exceed the point for
which AHAM members can provide
meaningful cost-efficiency data.
(AHAM, No. 14 at p. 8) Thus, AHAM’s
aggregated manufacturer data were
limited to a maximum EF of 0.72. DOE
included this efficiency level in its
analysis because one of the platforms
upon which DOE performed the reverseengineering analysis included a model
at an EF of 0.72 as its highest efficiency
version. DOE extended its analysis to
include EF up to the max-tech level of
1.11 because this unit represented the
high end of an additional product
platform that DOE reverse-engineered.
The Joint Comment, Multiple Water
Organizations, and Austin Water Utility
(AWU) commented that DOE should
conduct an analysis to determine
whether it should define a standard for
water consumption in addition to
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energy consumption. The Multiple
Water Organizations recommended
assigning a water factor to each
proposed dishwasher efficiency level,
and substantiating the relationship
between energy and water consumption.
They stated that water consumption is
not so tightly correlated with energy
consumption as to obviate the need for
a separately stated WF. They referred
DOE to databases maintained by NRCan
and the Oregon Department of Energy
for data on dishwasher energy and water
consumption. (Public Meeting
Transcript, No. 5 at p. 63; Joint
Comment, No. 9 at pp. 3–4; Multiple
Water Organizations, No. 11 at p. 3)
DOE notes that it does not have
statutory authority to prescribe a water
consumption standard for dishwashers.
The City of Seattle suggested that DOE
base the efficiency metric on energy and
water use per place setting, rather than
an EF according to the two product
classes. (Public Meeting Transcript, No.
5 at p. 58) In response, we note that the
current test procedure does not have
any provision for defining efficiency as
a function of the number of place
settings a dishwasher can clean, and,
therefore, DOE is currently unable to
define an efficiency metric on this basis.
Whirlpool commented that cleaning
performance must be taken into
consideration at higher efficiency levels,
and it stated that, at the max-tech level,
cleaning performance would be highly
suspect. (Public Meeting Transcript, No.
5 at p. 123) DOE notes that while there
is no provision in the current DOE test
procedure for measuring cleaning
performance, interviews conducted by
DOE with manufacturers indicated that
the manufacturers are unwilling to
compromise cleaning performance to
achieve higher energy efficiency at the
expense of market share. Manufacturer
concerns over the potential loss of
consumer utility at higher standard
levels are discussed in Chapter 12, MIA,
of the TSD.
b. Dehumidifiers
For dehumidifiers, each energy
efficiency level is expressed as a
minimum EF, which is a function of
liters per kWh. In this rulemaking, DOE
is using baseline models that have the
following efficiencies, which are the
current minimum standards for this
product (EPACT 2005, section 135(c)(4);
42 U.S.C. 6295(cc); 70 FR 60407, 60414,
(October 18, 2005); 10 CFR 430.32(v)):
• 25.00 pints/day or less = 1.00 EF
• 25.01–35.00 pints/day = 1.20 EF
• 35.01–45.00 pints/day = 1.30 EF
• 54.01–74.99 pints/day = 1.50 EF
DOE combined two product classes
defined by EPACT 2005—25.00 pints/
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day or less and 25.01–35.00 pints/day—
to form a single product class of 0–35.00
pints/day for this analysis, due to the
similar aggregation of data by AHAM in
its manufacturer cost data submittal.
EPACT 2005 also defines two other
product classes, 45.01–54.00 pints/day
and 75.00 pints/day or more, which
DOE did not analyze since AHAM did
not provide data for them. For purposes
of conducting the NIA, DOE believes
that the results from the product classes
analyzed can be extended to the two
statutorily-set product classes for which
AHAM data (or comparable data) are
unavailable. This approach is believed
to be valid due to chassis and
component similarities among the
product classes, with primary
differences due to scaling. DOE’s
approach for extending the results to the
omitted product classes is discussed
further in section II.I.3 of this ANOPR.
DOE seeks comment on this approach to
extend the engineering analysis to
product classes for which a complete
analysis was not performed.
In the Framework public meeting and
during the Framework comment period,
DOE received comments on the
dehumidifier engineering analysis
approach. All stakeholders agreed that
DOE should analyze multiple product
classes to capture the particular
efficiency characteristics of varying
capacity levels. Instead of extrapolating
from one capacity platform, multiple
stakeholders recommended analyzing a
minimum of three capacities (small,
medium, and large) to serve as a
baseline. (Public Meeting Transcript,
No. 5 at pp. 70 and 126–128; AHAM,
No. 14 at p. 9; Joint Comment, No. 9 at
p. 4 ; EEI, No. 7 at pp. 3 and 5)
Whirlpool recommended defining
‘‘small’’ as <25 pints/day, ‘‘medium’’ as
35–45 pints/day, and ‘‘large’’ as 75+
pints/day capacity. (Whirlpool, No. 10
at p. 5) AHAM recommended that DOE
analyze separately each capacity range
mentioned in the Framework Document,
because component availability,
compressor efficiencies, and other
factors vary widely. (AHAM, No. 14 at
p. 9) As discussed above, DOE
performed a complete analysis for the
product classes for which AHAM
supplied data, and extended the results
to the remaining product classes in
subsequent analyses.
DOE received numerous comments
from stakeholders regarding the
appropriateness of the dehumidifier
energy efficiency levels under review in
the Framework Document. AHAM
stated concerns regarding the max-tech
and some of the intermediate efficiency
levels, recommending that DOE
eliminate the EF level of 1.74 for the 35–
45 pints/day product category and
replace it with an EF level of 1.45–1.50,
which AHAM argued is more
representative of max-tech in that
capacity range. (Public Meeting
Transcript, No. 5 at pp. 72 and 129;
AHAM, No. 14 at p. 9) EEI questioned
some of the max-tech levels set for the
lower capacity ranges. (Public Meeting
Transcript, No. 5 at p. 126) Referring to
Table 5.3 in the Framework Document,
Whirlpool commented that the industry
considers an EF of 1.4 for 35–45 pints/
day as the de facto baseline efficiency
standard. Thus, Whirlpool stated that
DOE should drop the EF levels of 1.35
and below for this product class.
Whirlpool also commented that the
efficiency standards described by the EF
level of 1.50 may not be attainable and
should be reduced to an EF of 1.45.
Whirlpool stated that an EF of 1.50
would make dehumidifiers so expensive
that consumers would forgo them and
live with damp, unhealthy basements
instead. Thus, Whirlpool argued that an
even higher EF level would not be
economically justified, and it
recommended that DOE drop the maxtech level EF of 1.74. (Whirlpool, No. 10
at p. 5)
Based on comments received, DOE
analyzed three product classes (0–35.00
pints/day, 35.01–45.00 pints/day, and
54.01–74.99 pints/day) and five
efficiency levels for each product class.
The levels DOE analyzed are set forth in
Table II.14. DOE also reviewed the
efficiency levels proposed in the
Framework Document using available
databases, stakeholder interviews, and
insights from the reverse engineering
efforts. As discussed above, through its
tear-down analysis, DOE found
dehumidifiers with energy efficiency
levels at the highest candidate standard
level identified in section III of today’s
notice. Therefore, DOE believes that the
efficiency levels defined in the
Framework Document are representative
of currently available models, and,
therefore, we have retained them for
further analysis. DOE seeks comment on
the highest energy efficiency levels
identified in today’s ANOPR for the
purpose of determining appropriate
maximum technologically feasible
energy efficiency levels in the proposed
rule.
TABLE II.14.—EFFICIENCY LEVELS FOR RESIDENTIAL DEHUMIDIFIERS
Energy factor (liters/kWh)
0–35.00
(pints/day)
Efficiency levels
Baseline .......................................................................................................................................
1 ...................................................................................................................................................
2 ...................................................................................................................................................
3 ...................................................................................................................................................
4 ...................................................................................................................................................
5 ...................................................................................................................................................
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c. Cooking Products
For residential cooking products
(except for the prescriptive standard for
gas products), there are no existing
minimum energy conservation
standards, as previous analyses failed to
determine economic justification for
them. The DOE test procedure uses an
EF to rate the efficiency of cooking
products. The EF for these products is
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the ratio of the annual useful cooking
energy output of the residential cooking
appliance (i.e., the energy conveyed to
the item being heated) to its total annual
energy consumption. In accordance
with the previous rulemaking for
residential cooking products, DOE has
selected the following baseline EFs for
the product classes DOE is using in this
rulemaking:
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1.20
1.25
1.30
1.35
1.40
1.45
35.01–45.00
(pints/day)
1.30
1.35
1.40
1.45
1.50
1.74
54.01–74.99
(pints/day)
1.50
1.55
1.60
1.65
1.70
1.80
• Electric cooktops, open (coil)
elements = 0.737 EF
• Electric cooktops, smooth elements
= 0.742 EF
• Gas cooktops, conventional burners
= 0.156 EF
• Electric ovens, standard with or
without a catalytic line = 0.107 EF
• Electric ovens, self-clean = 0.096 EF
• Gas ovens, standard with or without
a catalytic line = 0.030 EF
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• Gas ovens, self-clean = 0.054 EF
• Microwave ovens = 0.557 EF
During the Framework public
meeting, Whirlpool suggested that DOE
might need to update baseline efficiency
levels to reflect changes in current oven
cavity volumes. DOE has defined
baseline volumes for gas and electric
non-self cleaning and self-cleaning
ovens as 3.9 cubic feet in accordance
with the previous rulemaking.
Whirlpool believes this volume is too
small to be representative of current
ovens. At the Framework public
meeting, Whirlpool stated that, since the
mid-1990s, oven volumes have
increased due to consumer usage
patterns and consumer demand. As a
result, Whirlpool stated that a more
representative baseline volume would
be five cubic feet. (Public Meeting
Transcript, No. 5 at pp. 90 and 132)
DOE has retained the 3.9 cubic feet
volume to define the efficiency standard
at baseline because there are a large
number of ovens on the market sized for
a 27-inch built-in installation which
incorporate this cavity volume. The
analysis accounts for larger oven cavity
volumes by scaling the efficiency
standard according to linear functions.
DOE defined these scaling functions for
gas and electric standard and selfcleaning ovens based on oven volume,
since it is recognized that efficiency is
affected by thermal mass and vent rates
that are functions of volume. The
scaling functions consist of linear
equations relating EF to volume, which
are described in greater detail in the
TSD. DOE believes the slopes and
intercepts of these equations from the
previous rulemaking to still be valid.
Whirlpool agreed that oven efficiency is
a function of volume, and stated that the
relationship is similar for gas and
electric ovens. However, Whirlpool
commented that DOE should review the
linear equations from the previous
rulemaking. (Public Meeting Transcript,
No. 5 at pp. 90, 133, and 138) DOE has
not identified any technological changes
that would impact the efficiencyvolume relationship, and, therefore, we
are retaining the equations as defined.
Whirlpool also suggested that baseline
efficiency levels might need to account
for sealed burners and high-input-rate
burners as separate product classes.
(Public Meeting Transcript, No. 5 at p.
131) As discussed previously, DOE
determined that sealed burners do not
warrant a separate product class due to
insufficient evidence that the
performance of sealed burners is
distinct from that of conventional open
gas burners. Therefore, DOE analyzed a
single product class for gas cooktops.
Given the lack of empirical data, DOE
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will not analyze commercial-type ranges
(the type of appliances normally
incorporating high-input-rate burners)
as a separate product class.
During the Framework public
meeting, the AWU questioned whether
baseline units would be equipped with
standing pilot ignition systems, while
Whirlpool stated that self-cleaning
ovens do not have standing pilot lights.
(Public Meeting Transcript, No. 5 at p.
136 and 138) In comments received after
the Framework public meeting, EEI
stated that gas pilot lights contribute to
significant standby energy losses.
According to EEI calculations, gas
cooktop pilot lights (assuming 8000
hours of standby) account for 18.72
therms of the total annual baseline
energy consumption of 33 therms, or
56.7 percent. Similarly, of the 29.6
therms annual baseline energy
consumption for standard gas ovens, EEI
attributes 14.0 therms, or 47.3 percent,
to the pilot light. (EEI, No. 7 at p. 5)
Conversely, AGA disputed DOE’s
presumption of significant energy
savings associated with the elimination
of standing pilot lights. AGA argued that
it is likely that less that 20 percent of
gas ranges currently have pilot ignition,
and therefore potential energy savings
will be less than the 0.06 quads over 30
years that DOE had estimated in the
prior rulemaking. AGA concluded that
pilot ignition cooking appliances are a
niche product with unique utility, and
their elimination would result in equity
issues to consumers for whom installing
electrical service adjacent to the range
hookup is not economically justified.
(AGA, No. 12 at pp. 2–3) DOE has
structured the analysis for standing pilot
igntion systems as a design option
associated with the baseline
configurations because DOE has
determined that cooktops incorporating
such ignition systems do not provide
unique utility. Power outages are not
frequent and long enough for residential
electricity customers to consider
operation during a lack of electric power
a significant utility. Between 90 and 93
percent of such customers experience
no electricity outages longer than four
hours per year.21
To analyze the cost-efficiency
relationships for each of the classes of
cooking products, DOE retained the
efficiency levels from the previous
rulemaking for residential cooking
products. For gas cooktops/conventional
burners and gas standard ovens with or
21 A. P. Sanghvi, Cost-Benefit Analysis of Power
System Reliability: Determination of Interruption
Costs. Prepared by RCG/Hagler Bailly, Inc.,
Arlington, VA for Electric Power Research Institute,
Palo Alto, CA, EL–6791. Vol. 2, p. 3–3 and Vol. 3,
p. 3–3. Available online at https://www.epri.com.
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64463
without a catalytic line, the baseline
efficiency level assumes that the
product is equipped with standing pilot
lights and the first standards efficiency
level corresponds to the elimination of
standing pilot lights. However, because
the cleaning cycle of gas self-clean
ovens requires electrical energy use,
EPCA in effect requires that such ovens
currently be equipped with a nonstanding pilot ignition system because a
standing pilot light ignition system is
disallowed if there is an electrical cord
provided on the product. Therefore, the
baseline efficiency level for these ovens
assumes they lack a standing pilot light,
as do all of the efficiency levels DOE
analyzed for this rulemaking. Further,
the first standards efficiency level is not
based on elimination of a standing pilot,
but rather on the addition of the forced
convection design option. For
microwave ovens, DOE used the
efficiency levels corresponding to those
in the previous rulemaking, after first
determining that these levels are
representative of the range of
efficiencies of currently-available
products. Tables II.15 through II.19 set
forth the levels DOE analyzed for
cooking products. For open coil-type
and smooth electric cooktops, only a
single standards efficiency level is
analyzed because design options
associated with higher efficiency levels
were either screened out, as described
in section II.B.2.c.1, or eliminated from
the analysis for the reasons described in
section II.C.2. For gas and electric
ovens, the efficiency levels reported in
Tables II.17 and II.18 are slightly
different than those identified in the
previous rulemaking’s analysis. Refer to
Chapter 5 of the TSD for an explanation
of the cause for these slight differences
in the oven efficiency levels.
TABLE II.15.—EFFICIENCY LEVELS FOR
RESIDENTIAL GAS COOKTOPS
Conventional burners
Efficiency levels
Cooking efficiency
Energy factor
Baseline ............
1 ........................
2 ........................
0.399
0.399
0.420
0.156
0.399
0.420
Whirlpool and GE both commented
that gas cooktop efficiencies should
scale with burner size, in a similar
manner as the relationship between
oven efficiency and volume. (Public
Meeting Transcript, No. 5 at pp. 134–
135) The test procedure, however,
currently contains provisions for testing
gas cooktop burners with different size
test blocks, depending on maximum
burner firing rate. Because the test
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procedure already accounts for burner
size, DOE will retain the existing
efficiency levels without a scaling
function for burner size.
TABLE II.16.—EFFICIENCY LEVELS FOR RESIDENTIAL ELECTRIC COOKTOPS
Open (coil) elements
Smooth elements
Efficiency levels
Cooking efficiency
Baseline ..........................................
1 ......................................................
Energy factor
0.737 ..............................................
0.769 (max-tech) ............................
DOE received a comment from
Whirlpool that the efficiency levels for
0.737
0.769
Cooking efficiency
0.742 ..............................................
0.753 (max-tech) ............................
electric cooktops listed in Table II.16 are
representative of currently available
Energy factor
0.742
0.753
technology. (Public Meeting Transcript,
No. 5 at p. 137)
TABLE II.17.—EFFICIENCY LEVELS FOR RESIDENTIAL GAS OVENS
Standard oven
Self-cleaning oven
Efficiency levels
Cooking efficiency
Baseline ..........................................
1 ......................................................
2 ......................................................
3 ......................................................
4 ......................................................
5 ......................................................
6 ......................................................
1a(1) ................................................
0.059
0.058
0.061
0.062
0.065
0.065
0.066
0.058
Energy factor
..............................................
(globar ignition) ....................
..............................................
..............................................
..............................................
..............................................
(max-tech) ............................
..............................................
0.0298
0.0536
0.0566
0.0572
0.0593
0.0596
0.0600
0.0583
Cooking efficiency
Energy factor
0.071 ..............................................
0.088 ..............................................
0.088 ..............................................
0.089 (max-tech) ............................
........................................................
........................................................
........................................................
........................................................
0.0540
0.0625
0.0627
0.0632
........................
........................
........................
........................
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. Efficiency 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
Cooking efficiency
Baseline ..........................................
1 ......................................................
2 ......................................................
3 ......................................................
4 ......................................................
5 ......................................................
0.122
0.128
0.134
0.137
0.140
0.141
Energy factor
..............................................
..............................................
..............................................
..............................................
..............................................
(max-tech) ............................
0.1066
0.1113
0.1163
0.1181
0.1206
0.1209
Energy factor
0.138 ..............................................
0.138 ..............................................
0.142 (max-tech) ............................
........................................................
........................................................
........................................................
0.1099
0.1102
0.1123
........................
........................
........................
manufacturers select higher wattage
lamps for product differentiation.
Manufacturers also may focus on
Energy fac- features that optimize cooking
Efficiency levels
tor
performance, such as mode stirrers, that
may also be accompanied by small
Baseline ....................................
0.557 increases in energy consumption.
1 ................................................
0.586 (AHAM, No. 17 at p. 2) DOE recognizes
2 ................................................
0.588
that manufacturers may choose to
3 ................................................
0.597
incorporate features that enhance
4 (max-tech) .............................
0.602
product differentiation at the expense of
energy consumption. For a given energy
AHAM noted that many microwave
efficiency level, manufacturers must
oven design features impact energy
weigh the appropriate combination of
efficiency, and that the choice of
design options and other features to
features may be dictated by marketplace meet the energy consumption
demands. For example, higher wattage
requirement set forth in the relevant
cavity lamps produce a brightly
efficiency standard.
illuminated cavity interior, but
d. Commercial Clothes Washers
increasing the lamp wattage by only 10
watts could lower efficiency by about
For all CCWs, EPCA establishes the
0.5 percent. Even so, some
following energy and water
TABLE II.19.—EFFICIENCY LEVELS FOR
RESIDENTIAL MICROWAVE OVENS
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Cooking efficiency
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conservation standards: A minimum
MEF of 1.26 and a maximum WF of 9.5.
(EPACT 2005, section 136(e); 42 U.S.C.
6313(e); see also 70 FR 60416 (Oct. 18,
2005), adding 10 CFR 431.156) In this
rulemaking, DOE is using a baseline
model that has those efficiencies.
As indicated previously for CCWs,
EPCA mandates that DOE determine
both a minimum MEF and a maximum
WF. For the purposes of analyzing the
cost-efficiency relationships for this
product, DOE based some of the
efficiency levels on the MEF and WF
specifications prescribed by the Energy
Star program and the CEE Commercial
Clothes Washer Initiative, and the
maximum levels that are currently
commercially available. These levels are
set forth in the Table II.20:
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TABLE II.20.—EFFICIENCY LEVELS FOR COMMERCIAL CLOTHES WASHERS
Modified Energy
Factor (ft 3/kWh)
Efficiency levels
mstockstill on PROD1PC66 with PROPOSALS2
Baseline ...............................................................................................................................................................
1 ...........................................................................................................................................................................
2 ...........................................................................................................................................................................
3 ...........................................................................................................................................................................
4 ...........................................................................................................................................................................
5 ...........................................................................................................................................................................
6 (max-tech) .........................................................................................................................................................
In the Framework public meeting and
during the Framework comment period,
DOE received comments regarding how
some energy efficiency levels under
consideration for CCWs could eliminate
vertical-axis clothes washers. GE stated
concerns regarding proposed standards
levels for CCWs. GE commented that
low WFs may not be attainable with
vertical-axis clothes washers, thereby
eliminating this low-cost platform from
the CCW market, which in turn could
lead to a decline in the number of
clothes washers available in multifamily housing due to increased costs.
GE urged DOE to consider the consumer
utility of vertical-axis clothes washers,
and it further argued that some
proposed standards levels may not be
attainable even with horizontal-axis
clothes washers. (Public Meeting
Transcript, No. 5 at p. 45; GE, No. 13 at
p. 3) Whirlpool argued that a WF below
9.5 could render a top-loading CCW
incapable of washing clothes properly
and that NAECA would not allow the
elimination of a product class.
(Whirlpool, No. 10 at p. 7) In response
to these comments, DOE notes that it
placed all CCWs in one product class
pursuant to EPACT 2005 (see discussion
of product class definition for CCWs in
section II.A.1.d of this ANOPR), which
applies a single standard for energy
efficiency and a single standard for
water efficiency to all of the CCWs.
(EPACT 2005, section 136(e); 42 U.S.C.
6313(e)) Thus, as discussed in II.C.3.d
above, DOE is treating commercial
clothes washers as a single class that
encompasses both top- and frontloading units.
Several stakeholders requested that
DOE consider additional efficiency
levels for the CCW rulemaking. For
example, ACEEE requested that DOE
evaluate a 2.0 MEF and 5.5 WF level,
since multiple clothes washer models
with this efficiency level are on the
market. (Public Meeting Transcript, No.
5 at p. 51; Public Meeting Transcript,
No. 5 at p. 121) Potomac recommended
that DOE consider the CEC waiver
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18:25 Nov 14, 2007
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petition’s WF breakpoint of 6.0.22
(Public Meeting Transcript, No. 5 at p.
118) The Joint Comment and the
Multiple Water Organizations requested
a gap-fill level between the 1.8 MEF and
the 2.79 MEF max-tech efficiency levels
at 2.0 MEF/5.5 WF as per CEE Tier 3B,
or 2.0 MEF/6.0 WF. (Joint Comment, No.
9 at p. 5; Multiple Water Organizations,
No. 11 at p. 1) As shown in Table II.20,
DOE is evaluating a level of 2.0 MEF
combined with a 5.5 WF.
DOE received numerous comments
regarding the appropriateness of the
max-tech level defined in the CCW
section of the Framework Document.
AHAM objected to the hybrid approach
of choosing the MEF from one washer
model while choosing a WF from
another, as this does not represent an
actual CCW. (Public Meeting Transcript,
No. 5 at p. 46) AHAM subsequently
recommended the elimination of this
efficiency level. (AHAM, No. 14 at p. 7)
According to Whirlpool, this max-tech
level was particularly objectionable
because of the hybrid origin of the MEF
and WF. (Public Meeting Transcript, No.
5 at p. 118) Some stakeholders
countered that the hybrid approach is a
reasonable way to estimate what could
be attainable but that the economics of
such a CCW would probably preclude
such a standards level. (Public Meeting
Transcript, No. 5 at p. 121; Joint
Comment, No. 9 at p. 5) EEI and
multiple stakeholders also suggested
that, if DOE were to reject the hybrid
approach, DOE could instead consider a
max-tech level of 2.48 MEF and 3.5 WF,
since that represents an actual clothes
washer. (EEI, No. 7 at p. 6; Multiple
Water Organizations, No. 11 at p. 2) In
response to these comments, DOE
subsequently altered the Framework
Document exploratory efficiency levels
to include a max-tech level where it
took the MEF and WF from an existing
clothes washer.
22 DOE published a Federal Register notice on
February 6, 2006 acknowledging receipt of and
summarizing the California Energy Commission’s
Petition for Exemption from Federal Preemption of
California’s Water Conservation Standards for
Residential Clothes Washers (71 FR 6022) (Docket
No. EE–RM–PET–100).
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1.26
1.42
1.60
1.72
1.80
2.00
2.20
Water Factor
(gallons/ft 3)
9.5
9.5
8.5
8.0
7.5
5.5
5.1
In addition to comments regarding the
appropriateness of the max-tech level,
DOE received further comments
regarding adding more efficiency levels
to the CCW analysis during the
Framework public meeting and through
subsequent written comments. ALS
agreed with analyzing all proposed
effiency levels with the exception of
max-tech, which ALS rejected because
of the hybrid origin of the MEF and WF,
and because DOE derived these levels
from residential clothes washer data.
(Public Meeting Transcript, No. 5 at pp.
117–118) Multiple Water Organizations
recommended that DOE adopt step-like
incremental increases in both MEF and
WF for each efficiency level. (Multiple
Water Organizations, No. 11 at p. 2)
During the Framework comment
period, DOE received multiple
comments regarding the applicability of
residential clothes washer efficiency
levels in a commerical setting. Both
Whirlpool and GE submitted that the
efficiency levels achieved by residential
clothes washers are not representative of
levels achievable by commercial
products, which experience harder and
more frequent use than residential
products. (Whirlpool, No. 10 at p. 9; GE,
No. 13 at p. 3) AHAM stated that the
efficiency levels set forth in the
Framework Document are not
appropriate and recommended that DOE
consider the different nature of CCWs.
(AHAM, No. 14 at p. 7) DOE recognizes
that current product offerings in the
commercial laundry market do not
include products at each efficiency level
for which DOE is performing an
analysis. DOE notes, however, that
products exist that meet all the levels
specified, so manufacturing cost data
are available to assess CCWs that meet
or exceed the levels specified. Since the
standards are minimum performance
standards, not presciptive standards,
these levels do not represent
predetermined technologies and are
therefore not tied to the residential or
commercial markets.
DOE also received comments
regarding data requests for the CCW
engineering analysis. Whirlpool stated
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that data for the baseline level are
readily available, and that data for some
higher efficiency levels are also
available. (Whirlpool, No. 10 at p. 9)
According to Whirlpool, the low volume
of the U.S. CCW market, the limited
scope of products, and the small
number of manufacturers complicates
the task of establishing manufacturing
cost data in a way that does not lead to
the disclosure of confidential
information. (Whirlpool, No. 10 at p. 12)
The Multiple Water Organizations
requested that DOE work closely with
manufacturers to obtain and make
manufacturing cost data available before
the ANOPR is published. (Multiple
Water Organizations, No. 11 at p. 2)
DOE worked with AHAM and
stakeholders to obtain as much data as
possible. DOE withheld from
publication whatever data could not be
aggregated to maintain confidentiality.
Additional detail on the product
classes, baseline models, and efficiency
levels can be found in Chapter 5 of the
TSD.
4. Cost-Efficiency Results
DOE reports the results of the
engineering analysis as cost-efficiency
data (or ‘‘curves’’) in the form of
incremental manufacturing costs versus
EF (or MEF and WF for CCWs). These
data form the basis for subsequent
analyses in the ANOPR. DOE received
industry-aggregated curves for CCWs,
dishwashers, and dehumidifiers from
AHAM. DOE validated these data
through manufacturer interviews for all
three products and the independent
generation of similar curves for
dishwashers and dehumidifiers. DOE
based these curves on testing and
reverse engineering activities, which
resulted in the generation of a detailed
bill of materials for each product.
For cooking products, DOE retained
the cost data at each efficiency level that
it had defined in the previous
rulemaking’s analysis, updated by
scaling incremental manufacturing costs
by the PPI from 1990 (the reference year
in the prior analysis) to 2006. In
addition, for microwave ovens, DOE
received efficiency test data submitted
by AHAM. The following table
summarizes the data that DOE’s
engineering analysis used to generate
the cost-efficiency results.
TABLE II.21.—ENGINEERING ANALYSIS METHODS
Products
Method
Cooking
products
AHAM Data ..............................................................................................
Review of Past TSD ................................................................................
Product Teardown ...................................................................................
Product Testing ........................................................................................
Manufacturer Interviews ..........................................................................
mstockstill on PROD1PC66 with PROPOSALS2
a. Dishwashers
For dishwashers, AHAM provided
manufacturing cost data up to an
efficiency level of 0.72 EF. DOE
supplemented AHAM’s efficiency-level
cost data submittal with cost
information generated from the
efficiency testing and teardown of
currently-available dishwashers. DOE
conducted efficiency testing of six
dishwashers, representing a range of EFs
across two different product platforms.
Beyond the measurements required to
measure the performance according to
the DOE test procedure, the testing
consisted of multi-submetering to record
disaggregated energy consumption
associated with various design options.
The EFs of the washers tested were 0.58,
0.64, 0.68, 0.78, 0.93, and 1.11.
In addition to efficiency testing, DOE
performed reverse engineering on the
six units tested, as well as on an
additional dishwasher with an EF of
0.72. This last dishwasher was not yet
available on the market at the time of
testing but was released for high-volume
manufacturing three weeks later. To
validate the AHAM data and supply
incremental cost information above the
0.72 EF level, DOE tore down the seven
dishwashers (three high-efficiency
dishwashers that shared the same basic
platform and four other washers
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Dishwashers
Dehumidifiers
Commercial
clothes washers
√
√
..........................
..........................
..........................
√
..........................
√
√
√
√
..........................
√
..........................
√
√
√
..........................
..........................
√
spanning the efficiency range 0.58–0.72
EF). A comparison of AHAM’s and
DOE’s costs indicates that DOE’s cost
estimates are somewhat lower that the
AHAM average costs, but above the
AHAM minimum.
The purpose of comparing DOE’s and
AHAM’s results was to assess the
reasonableness of AHAM’s data
submission, and DOE believes this has
been demonstrated. DOE’s teardown
sample size was very small and could
not be expected to adequately capture
the variability of all products in the
marketplace. Another reason why DOE’s
results are lower than AHAM’s average
is the influence of product platforms.
DOE’s teardown analysis and
manufacturer interviews confirmed that
upgrading components can only raise
EF to a certain point and that overall
system architecture limits EF. The
platform which DOE reverse-engineered
is among the most efficient available
from large-volume manufacturers (with
an EF that spans the range of 0.58 to
0.72). Thus, it is reasonable to assume
that starting from a lower efficiency
platform will result in larger
incremental costs. The results of the
testing and teardown analysis, including
the list of design options identified and
other observations, can be further
reviewed in Chapter 5 of the TSD. If the
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reverse-engineering sample size had
been larger, it is reasonable to assume
that the range of incremental costs by
efficiency level would have broadened.
As a result, DOE feels that the AHAM
submission is reasonable and reflective
of the gamut of dishwasher platforms
and their inherent efficiencies on the
market today.
Standard dishwasher cost-efficiency
results are shown in Table II.22. DOE
was unable to obtain incremental
manufacturing cost information for
compact dishwashers. Accordingly,
DOE particularly seeks stakeholder
feedback on how it can extend the
results of the analysis for the standardclass dishwashers to compact
dishwashers. This is identified as Issue
4 under ‘‘Issues on Which DOE Seeks
Comment’’ in section IV.E of this
ANOPR.
TABLE II.22.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL
STANDARD DISHWASHERS
Standard
Energy factor
(cycles/kWh)
Incremental
cost
Baseline ................................
0.58 .......................................
0.62 .......................................
........................
$4.01
7.38
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from its member companies and
submitted them to DOE. DOE validated
AHAM’s efficiency-level cost data
submittal with a design-options-based/
reverse engineering analysis, tearing
down 14 dehumidifiers representing a
Standard
range of capacities and efficiencies. In
Energy factor
Incremental
generating the cost-efficiency results,
(cycles/kWh)
cost
DOE combined the first two product
0.65 .......................................
14.00 classes proposed by EPACT 2005, 25.00
0.68 .......................................
30.35 pints/day or less and 25.01–35.00 pints/
0.72 .......................................
71.38 day, because some manufacturers did
0.80 .......................................
129.28 not have shipments in the 25.01 to 35.00
1.11 .......................................
180.66 pints/day category. To prevent
disclosure of sensitive information,
b. Dehumidifiers
AHAM did not provide data for the
For dehumidifiers, AHAM collected
EPACT 2005 categories 45.01–54.00
incremental manufacturing cost data
pints/day and 75 pints/day and greater
TABLE II.22.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL
STANDARD DISHWASHERS—Continued
because fewer than three manufacturers
produce units in these categories.
Therefore cost-efficiency curves were
only generated for the following product
classes: 0 to 35.00 pints/day, 35.01 to
45.00 pints/day, and 54.01 to 74.99
pints/day. Results of the reverse
engineering analysis for the product
classes analyzed were in good
agreement with the AHAM data. The
following table shows the dehumidifier
cost-efficiency results. AHAM provided
all of the data for the three product
classes analyzed, except the value for an
EF of 1.74 in the 35.01 to 45.00 product
class, which DOE extrapolated from the
AHAM data.
TABLE II.23.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL DEHUMIDIFIERS
Product class,
pints/day
Energy factor
(L/kWh)
Incremental
cost
0 to 35.00 .....................................................................................................................
Baseline ....................................................
1.25 ...........................................................
1.30 ...........................................................
1.35 ...........................................................
1.40 ...........................................................
1.45 ...........................................................
Baseline ....................................................
1.35 ...........................................................
1.40 ...........................................................
1.45 ...........................................................
1.50 ...........................................................
1.74 ...........................................................
Baseline ....................................................
1.55 ...........................................................
1.60 ...........................................................
1.65 ...........................................................
1.70 ...........................................................
1.80 ...........................................................
........................
$3.12
4.92
10.41
18.80
25.61
........................
6.11
14.47
22.68
32.84
74.72
........................
4.18
8.00
12.36
23.18
33.94
35.01 to 45.00 ..............................................................................................................
54.01 to 74.99 ..............................................................................................................
c. Cooking Products
For conventional cooking products,
DOE derived the cost-efficiency curves
from the previous rulemaking’s analysis,
scaling the incremental manufacturing
costs by the PPI in accordance with
stakeholder comments. Tables II.24
through II.30 and Table II.32 detail the
cost-efficiency results.
TABLE II.24.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL GAS COOKTOPS
Level
Efficiency level source
0 .............
1 .............
2 .............
Baseline ...............................................................................................................................................
0 + Electronic Ignition ..........................................................................................................................
1 + Sealed Burners .............................................................................................................................
Incremental
cost
EF
0.156
0.399
0.420
........................
$12.06
32.06
TABLE II.25.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL ELECTRIC COIL COOKTOPS
mstockstill on PROD1PC66 with PROPOSALS2
Level
Efficiency level source
0 .............
1 .............
Baseline ...............................................................................................................................................
0 + Improved Contact Conductance ...................................................................................................
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Incremental
cost
EF
Sfmt 4702
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0.737
0.769
........................
$2.28
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TABLE II.26.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL ELECTRIC SMOOTH COOKTOPS
Level
Efficiency level source
0 .............
1 .............
Baseline ...............................................................................................................................................
0 + Halogen Lamp Element ................................................................................................................
Incremental
cost
EF
0.742
0.753
........................
$89.09
TABLE II.27.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL GAS STANDARD OVENS
Level
Efficiency level source
0 .............
1 .............
2 .............
3 .............
4 .............
5 .............
6 .............
1a ...........
Baseline ...............................................................................................................................................
0 + Electric Globar Ignition ..................................................................................................................
1 + Improved Insulation .......................................................................................................................
2 + Improved Door Seals ....................................................................................................................
3 + Forced Convection ........................................................................................................................
4 + Reduced Vent Rate ......................................................................................................................
5 + Reduced Conduction Losses ........................................................................................................
0 + Electronic Spark Ignition ...............................................................................................................
Incremental
cost
EF
0.0298
0.0536
0.0566
0.0572
0.0593
0.0596
0.0600
0.0583
........................
$12.06
15.64
16.72
38.86
40.48
44.11
15.00
TABLE II.28.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL GAS SELF-CLEANING OVENS
Level
0
1
2
3
.............
.............
.............
.............
Efficiency level source
Incremental
cost
EF
Baseline ...............................................................................................................................................
0 + Forced Convection ........................................................................................................................
1 + Reduced Conduction Losses ........................................................................................................
2 + Improved Door Seals ....................................................................................................................
0.0540
0.0625
0.0627
0.0632
........................
$11.01
15.38
16.60
TABLE II.29.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL ELECTRIC STANDARD OVENS
Level
0
1
2
3
4
5
.............
.............
.............
.............
.............
.............
Efficiency level source
EF
Baseline ...............................................................................................................................................
0 + Reduced Vent Rate ......................................................................................................................
1 + Improved Insulation .......................................................................................................................
2 + Improved Door Seals ....................................................................................................................
3 + Forced Convection ........................................................................................................................
4 + Reduced Conduction Losses ........................................................................................................
0.1066
0.1113
0.1163
0.1181
0.1206
0.1209
Incremental
cost
........................
$1.63
4.84
8.53
48.14
51.69
TABLE II.30.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL ELECTRIC SELF-CLEANING OVENS
Level
Efficiency level source
0 .............
1 .............
2 .............
Baseline ...............................................................................................................................................
0 + Reduced Conduction Losses ........................................................................................................
1 + Forced Convection ........................................................................................................................
For conventional ovens, the linear
relationships for EF versus volume
allow scaling of the efficiency levels to
cavity volumes other than the baseline
volume. Table II.31 shows the slopes
EF
and intercepts of these relationships.
The table does not show values for
every oven efficiency level because the
previous rulemaking did not analyze
data at every efficiency level, and
0.1099
0.1102
0.1123
Incremental
cost
........................
$4.37
43.98
because certain design options have
been screened out in the current
analysis.
TABLE II.31.—SLOPES AND INTERCEPTS FOR OVEN ENERGY FACTOR VERSUS VOLUME RELATIONSHIP
mstockstill on PROD1PC66 with PROPOSALS2
Intercepts, Electric
Slope = –0.0157
Level
Intercepts, Gas
Slope = –0.0073
Standard
0 .......................................................................................................................
1 .......................................................................................................................
2 .......................................................................................................................
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Self-Clean
Standard
Self-Clean
........................
0.1752
0.1802
0.1632
........................
........................
0.0865
0.0895
........................
0.0865
........................
........................
Sfmt 4702
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TABLE II.31.—SLOPES AND INTERCEPTS FOR OVEN ENERGY FACTOR VERSUS VOLUME RELATIONSHIP—Continued
Intercepts, Electric
Slope = –0.0157
Level
Intercepts, Gas
Slope = –0.0073
Standard
3 .......................................................................................................................
0.1822
Self-Clean
........................
Standard
0.0935
Self-Clean
........................
Note: EF = (Slope x Volume) + Intercept where Volume is expressed in cubic feet.
For microwave ovens, the design
options and efficiency levels DOE
analyzed are those identified in the
previous rulemaking, with incremental
manufacturing costs scaled by the PPI.
DOE specifically seeks stakeholder
feedback on the approach of analyzing
additional design options that would
result in a lowering of the energy
consumption of non-cooking features
(e.g., standby power), even though the
test procedure currently does not
account for such usage in EF. This is
identified as Issue 5 under ‘‘Issues on
Which DOE Seeks Comment’’ in section
IV.E of this ANOPR. It should be noted
that DOE is considering the addition of
standby power measurement to the test
procedure, as identified as Issue 1 under
‘‘Issues on Which DOE Seeks Comment’’
in section IV.E of this ANOPR. The table
below shows the cost-efficiency results
for microwave ovens.
TABLE II.32.—INCREMENTAL MANUFACTURING COST FOR RESIDENTIAL MICROWAVE OVENS
Level
mstockstill on PROD1PC66 with PROPOSALS2
0
1
2
3
4
.............
.............
.............
.............
.............
Efficiency level source
Baseline ...............................................................................................................................................
0 + More Efficient Power Supply ........................................................................................................
1 + More Efficient Fan .........................................................................................................................
2 + More Efficient Magnetron ..............................................................................................................
3 + Reflective Surfaces .......................................................................................................................
d. Commercial Clothes Washers
For CCWs, DOE derived the costefficiency curves from AHAMsubmitted data. Due to limited data
collected, AHAM supplied cost data
only at 1.42 MEF/9.5 WF and 2.0 MEF/
5.5 WF. Based on a survey of CCWs
currently sold, it is DOE’s
understanding that all products sold
which meet an efficiency level of 1.6
EF/8.5 MEF or greater are based on a
horizontal axis platform. Furthermore,
based on interviews with manufacturers
of CCWs, it is DOE’s understanding that
energy and water efficient vertical-axisbased designs currently sold in the
residential market are not being
considered for market introduction into
the commercial laundry sector. Such
designs include spray rinse and nonagitator vertical-axis clothes washers
that replace the agitator with an
impeller, nutating plate, or other
alternative manipulator. Manufacturers
commented during interviews that such
designs are not appropriate for the
heavy-duty demands of commercial
laundry applications.
Notwithstanding the lack of
manufacturing data for CCWs at several
efficiency levels, the information
gathered from the market research and
manufacturer interviews suggests that
CCWs cannot attain satisfactory
cleaning performance at or above
efficiency level 2 (1.6 MEF and 8.5 WF)
without the use of horizontal-axis
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technology. Thus, since DOE believes
vertical-axis CCWs cannot perform
satisfactorily at these efficiency levels,
DOE assumes that all units sold at
efficiency level 2 and higher will be
horizontal-axis CCWs and likely, more
efficient than required. In determining
the incremental costs associated with
these efficiency levels, DOE notes that,
like dishwashers, CCWs are platformdriven products where a given platform
achieves an inherent efficiency based on
design and an optimized control
strategy. This inherent efficiency can be
further enhanced via design option
improvements that the control strategy
can incorporate. However, a
manufacturer may also choose to offer a
range of product efficiencies and
redesign existing products to offer a
less-efficient unit for marketing or other
reasons. The per-unit cost of redesigning
a product to reduce the efficiency is
typically low, though a manufacturer
will have to pay an up-front cost to
develop the new controller, pay for
certifications, etc. Thus, there is a
disincentive to develop less-efficient
units (i.e., ones that marginally meet the
standard) unless the market is large
enough to have the scale to support
multiple price points based in part on
energy efficiency.
Thus, it is not surprising that the
CCW market currently does not offer a
wide range of efficiencies for a given
axis of rotation. The scale of the market
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Incremental
cost
EF
Sfmt 4702
0.557
0.586
0.588
0.597
0.602
........................
$8.68
17.95
32.53
51.11
is small, and the presence of an Energy
Star program deters manufacturers from
offering CCWs that have efficiencies that
lie between the baseline and Energy Star
efficiency levels, as such units would be
more costly than a baseline unit yet not
be eligible for rebates from utilities.
Since all manufacturers currently
produce horizontal-axis CCWs in the
range of 2.0 MEF/5.5 WF, no platform
change would be required to the
existing horizontal-axis CCW lines to
meet any efficiency level up to and
including 2.0 MEF/5.5 WF.23 During
interviews with DOE, manufacturers
provided estimates of the cost increment
to meet 2.2 MEF/5.1 WF, ranging from
$316 to $450. DOE notes that $316 is the
manufacturing cost increment provided
by AHAM to take a CCW from a baseline
efficiency level of 1.26 MEF/9.5 WF to
a level of 2.0 MEF/5.5 WF. Thus, DOE
expects that the incremental costs
between 1.60 MEF/8.5 WF and 2.2 MEF/
5.1 WF would be constant at the same
value as those provided by AHAM for
23 DOE recognizes, however, that changes to the
horizontal-axis CCW lines may be needed to meet
higher production volumes. Any investment to the
horizontal-axis CCW production lines to
accommodate higher sales volumes were not
captured in this analysis. For a qualitative
discussion of capital expenditures required for such
a product conversion, see the preliminary
manufacturer impact analysis chapter (Chapter 12)
of the TSD.
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the level 2.0 MEF/5.5 WF. For further
information, see Chapter 5 of the TSD.
DOE specifically seeks feedback on
the validity of this approach. DOE seeks
information about lower-cost
alternatives to horizontal-axis designs
for levels greater than 1.42 MEF/9.5 WF
and lower than 2.0 MEF/5.5 WF.
Additionally, DOE seeks information
that would enable it to change the
energy and water features of the 2.0
MEF/5.5 WF level to allow for
manufacturer cost differentiation at the
lower (and the higher) levels. DOE is
also interested in receiving comment on
how to weigh the impacts of a marketshift from vertical-axis technologies to
horizontal-axis technologies. These
issues are identified as Issue 3 under
‘‘Issues on Which DOE Seeks Comment’’
in section IV.E of this ANOPR.
The following table shows the
preliminary commercial clothes washer
cost-efficiency results.
TABLE II.33.—INCREMENTAL MANUFACTURING COST FOR COMMERCIAL
CLOTHES WASHERS
Efficiency levels
(MEF/WF)
Incremental
cost
Baseline ................................
1.42/9.5 .................................
1.60/8.5 .................................
1.72/8.0 .................................
1.80/7.5 .................................
2.00/5.5 .................................
2.20/5.1 .................................
........................
$74.73
316.35
316.35
316.35
316.35
316.35
Additional detail on the costefficiency results can be found in
Chapter 5 of the TSD.
mstockstill on PROD1PC66 with PROPOSALS2
D. Energy Use and Water Use
Characterization
The purpose of the energy use
characterization, which DOE performed
for the four appliance products covered
in the ANOPR, is to help assess the
energy-savings potential of different
product efficiencies. The purpose of the
water use characterization, performed
only for CCWs and residential
dishwashers, is to help assess the watersavings potential of more efficient
products. DOE relied on existing test
procedures, as well as the Energy
Information Administration (EIA)’s
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Residential Energy Consumption Survey
(RECS) and other sources (which are
described below for each product) to
establish a range of energy (and water)
use for the four appliance products.
1. Dishwashers
DOE relied on the information in the
DOE test procedure to establish the
typical annual energy and water
consumption of dishwashers. 10 CFR
Part 430, Subpart B, Appendix C. In
particular, DOE determined the annual
energy and water consumption of
dishwashers by multiplying the percycle energy and water use by the
number of cycles per year, consistent
with the DOE test procedure.
Dishwasher per-cycle energy
consumption consists of three
components: (1) Water-heating energy;
(2) machine energy; and (3) drying
energy. The machine energy consists of
the motor energy (for water pumping
and food disposal) and booster heater
energy. The DOE test procedure
provides equations to calculate the total
per-cycle dishwasher energy
consumption.
The largest component of dishwasher
energy consumption is water-heating
energy use, which is directly dependent
on water use. AHAM stated that it was
not possible to provide either
disaggregated per-cycle energy use or
water use data by standard level
because, for any given standard level,
the disaggregated energy use
components and water use can vary
greatly depending on dishwasher
design. (AHAM, No. 14 at p. 8)
However, AHAM did provide data
showing how aggregate per-cycle energy
use and per-cycle water use has changed
over time since 1993. An analysis of the
submitted AHAM data demonstrated
that the relationship between energy
and water use is nearly linear. This
correlation is largely due to the energy
required to heat water to the test
procedure inlet temperature of 120 °F
(49 °C) that most dishwashers use. The
energy required to heat the inlet water
to 120 °F (49 °C) usually represents the
largest proportion of the overall percycle energy usage. Therefore, by
knowing the aggregate per-cycle energy
use, DOE determined the per-cycle
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water use and, in turn, the per-cycle
water-heating energy consumption
using DOE test procedure equations.
DOE analyzed the energy and water
use for candidate standard levels
ranging from 0.58 EF to 1.11 EF for
standard-sized dishwashers. Because
Whirlpool does not produce products
with efficiencies higher than 0.68 EF,
Whirlpool commented that it cannot
provide energy and water consumption
data for efficiency levels 0.72 EF, 0.80
EF, and 1.11 EF. (Whirlpool, No. 10 at
pp. 9 and 12) However, based on the
relationship between aggregate per-cycle
energy use (which can be deduced from
the dishwasher EF) and water use,
which AHAM provided, DOE was able
to estimate the energy use and water use
of dishwashers at all candidate standard
levels. Table II.34 shows the candidate
standard levels for standard-sized
dishwashers and their corresponding
per-cycle energy and water use.
Per-cycle energy use is disaggregated
into two general categories: (1) Water
heating; and (2) machine (e.g., motor
energy for pumping) and dish drying
from an electrical heating element. DOE
estimated the per-cycle energy use by
taking the inverse of the EF. It estimated
the per-cycle water consumption based
on the relationship between energy and
water use. DOE estimated the per-cycle
water-heating energy consumption by
assuming the use of an electric water
heater and multiplying the per-cycle
water consumption by an assumed
temperature rise of 70 °F (21 °C) and a
specific heat of water of 0.0024 kWh/gal
× °F (4.186 joule/gram × °C). The percycle machine and drying energy were
determined by DOE by subtracting the
water-heating energy consumption from
the total energy consumption. The table
below provides the standby power,
which DOE assumed to be two watts.
EEI questioned the degree to which
consumers use the ‘‘heated dry’’ option
to dry dishes instead of air-drying. (EEI,
No. 7 at p. 5) For purposes of
developing the per-cycle energy use and
water use data shown below in Table
II.34, DOE based the amount of time that
the heated dry option is used on the
DOE test procedure (i.e., 50 percent of
the dishwasher cycles).
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TABLE II.34.—STANDARD DISHWASHERS: PER-CYCLE ENERGY AND WATER USE BY CANDIDATE STANDARD LEVEL
Energy Use Components
Candidate Standard Level
EF
DOE determined the average annual
energy and water consumption by
multiplying the per-cycle energy and
water consumption by the number of
cycles per year. In 2003, DOE revised its
test procedure for dishwashers to more
accurately establish their efficiency and
energy and water use. The 2003 test
procedure amendments included a
reduction in the average use cycles per
year, from 264 to 215 cycles per year.24
Arthur D. Little (ADL) conducted a
comprehensive analysis of dishwasher
usage in 2001 that revealed that
dishwashers are used, on average, 215
cycles per year. This usage pattern is
currently used to establish the annual
energy consumption of dishwashers
with the DOE test procedure.
In the context of the present
rulemaking, DOE analyzed additional
sources to determine whether the
number of dishwasher cycles per year
has changed. For example, DOE
Water Use
Water
Heating
Machine +
Drying
Standby
cycles/kWh
Baseline ...............................................................
1 ...........................................................................
2 ...........................................................................
3 ...........................................................................
4 ...........................................................................
5 ...........................................................................
6 ...........................................................................
7 ...........................................................................
Energy Use
kWh/cycle
gal/cycle
kWh/cycle
kWh/cycle
kW
0.46
0.58
0.62
0.65
0.68
0.72
0.80
1.11
2.17
1.72
1.61
1.54
1.47
1.39
1.25
0.90
8.16
6.07
5.56
5.21
4.90
4.52
3.87
2.25
1.37
1.02
0.93
0.88
0.82
0.76
0.65
0.38
0.80
0.70
0.68
0.66
0.65
0.63
0.60
0.52
0.002
0.002
0.002
0.002
0.002
0.002
0.002
0.002
component in a very large and complex
survey instrument dealing with all
aspects of home energy use. (Joint
Comment, No. 9 at p. 4) The Multiple
Water Organizations also urged DOE to
retain the use of 215 cycles per year in
the analysis. (Multiple Water
Organizations, No. 11 at p. 3) Whirlpool
also stated that DOE should retain the
use of 215 cycles per year in its analysis.
(Whirlpool, No. 10 at p. 9) Because the
ADL survey is a much more
comprehensive and larger survey than
the survey performed for RECS, DOE
chose an average usage of 215 cycles per
year as the most representative value for
average dishwasher use.
Therefore, the annual energy and
water consumption shown in Table II.35
reflect an annual usage of 215 cycles per
year. The annual water-heating energy
consumption reflects the use of either
an electric, gas-fired, or oil-fired water
heater.
reviewed EIA’s 2001 RECS data, which
includes the annual usage of households
with dishwashers. Of the more than
4,800 households in RECS, almost 2,500
have dishwashers. However, the
average-use value for dishwashers is 180
cycles per year, with minimum and
maximum values of 26 and 500 cycles
per year, respectively. The Joint
Comment argued that DOE should
continue to use 215 cycles per year in
its analysis of dishwashers. The
organizations maintained that any
estimate derived from the EIA’s 2001
RECS is not nearly as robust as the
estimate derived from the work
conducted by ADL to revise the
dishwasher test procedure. For example,
the Joint Comment stated that RECS
represents a much smaller sample than
the one ADL used (about 2,500
households versus 26,000 households)
and that the questions pertaining to
dishwashers in RECS are just one
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
mstockstill on PROD1PC66 with PROPOSALS2
Baseline ...............................................................
1 ...........................................................................
2 ...........................................................................
3 ...........................................................................
4 ...........................................................................
5 ...........................................................................
6 ...........................................................................
7 ...........................................................................
0.46
0.58
0.62
0.65
0.68
0.72
0.80
1.11
295
219
201
188
177
163
140
81
1.34
1.00
0.91
0.86
0.80
0.74
0.64
0.37
1.24
0.92
0.85
0.79
0.74
0.69
0.59
0.34
MMBtu/year
190
168
163
160
156
153
146
129
MMBtu/year
1.8
1.3
1.2
1.1
1.1
1.0
0.8
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 percent 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
must account for the effects of pre-
24 68
washing when establishing dishwasher
energy use. EEI stated that DOE should
account for pre-washing in estimating
the baseline energy use of dishwashers.
FR 51887 (August 29, 2003).
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Whirlpool stated that increasing the
efficiency of dishwashers too far may
result in wash performance being
compromised, thereby forcing
consumers to pre-wash more and
resulting in increased energy and water
consumption. (Whirlpool, No. 10 at p. 2;
EEI, No. 7 at p. 5) EEI also stated that
the analysis should capture the effects
of reduced household cooking product
usage on dishwasher usage. (EEI, No. 7
at p. 3) Because DOE could not identify
sources of data showing whether the
amount of pre-washing is impacted by
dishwasher efficiency, DOE conducted
its analysis by assuming that hand- or
pre-washing habits are not affected by
product efficiency. But because
increased diswasher energy efficiency
may require future designs to utlize less
water, DOE recognizes the possibility
that more efficient dishwashers may
degrade wash performance. Therefore,
DOE seeks feedback on whether more
efficient dishwasher designs will lead to
increased hand- or pre-washing and, if
so, what increase in energy and water
use can be expected. This is identified
as Issue 7 under ‘‘Issues on Which DOE
Seeks Comment’’ in section IV.E of this
ANOPR. Considering the effects of
reduced household cooking product use
on dishwasher usage, and because
DOE’s dishwasher use assumptions are
based on relatively recent survey data
collected by ADL, DOE believes that any
impacts from reduced cooking are
captured in the updated use value of
215 cycles per year.
As previously stated, of the more than
4,800 households in RECS, almost 2,500
have dishwashers. As will be described
later in section II.G on the LCC and PBP
analysis, DOE used the RECS household
samples with their associated baseline
annual energy consumption to conduct
buckets are full, and the organization
argued that such feature reduces use,
because it is assumed that consumers do
not regularly empty the bucket. (AHAM,
No. 14 at p. 10; Whirlpool, No. 10 at p.
9) Because the AHAM data were
developed based on the experience of
manufacturers, DOE believes that the
AHAM data are the most representative
of actual use. Therefore, DOE relied on
the data AHAM provided, but DOE did
consider other sources of data for
estimating annual energy consumption.
In comparison with AHAM’s
recommendation that DOE use 1,095
operating hours per year as the norm,
other literature sources from ADL,
Energy Star, and LBNL, provide higher
use values of 1,620, 2,851, and 4,320
hours/year, respectively. Therefore,
although DOE relied on AHAM’s
estimate of 1,095 hours to calculate a
dehumidifier’s average energy
consumption, DOE used the higher use
values from the above sources to
demonstrate how they would impact
annual energy consumption.
DOE specifically seeks feedback on
whether AHAM’s estimate of 1,095
hours per year is representative, on
average, of dehumidifier use. This is
identified as Issue 8 under ‘‘Issues on
Which DOE Seeks Comment’’ in section
IV.E of this ANOPR.
For the six product classes of
dehumidifiers, DOE calculated the
baseline annual energy consumption
(i.e., the consumption corresponding to
the standards for each product class that
take effect in 2007), based on the annual
use assumptions presented in Table
II.36 below. As shown in the table, the
calculated annual energy use has an
extensive range based on the capacity
and efficiency of the dehumidifier and
the hours of operation.
the LCC and PBP analyses. Additional
detail on the energy and water use
characterization of dishwashers can be
found in Chapter 6 of the TSD.
2. Dehumidifiers
The ANSI/AHAM Standard DH–1–
2003, ‘‘Dehumidifiers,’’ for energy
consumption measurements during
capacity-rating tests, and CAN/CSA–
C749–94, ‘‘Performance of
Dehumidifiers,’’ for energy factor
calculations, that DOE codified under
EPCA in a final rule for dehumidifiers
provide a method for determining the
product’s rated efficiency in liters/
kWh—but provide no method for
establishing annual energy consumption
(71 FR 71340 (December 8, 2006); 10
CFR 430.23(z)). DOE determined the
annual energy consumption of
dehumidifiers by first dividing the
capacity (in pints per day) by the unit
efficiency (in liters per kWh) and then
multiplying it by the usage in hours per
year.
Both AHAM and Whirlpool
commented on the difficulty of
determining the energy consumption of
dehumidifiers. Whirlpool stated that
energy consumption varies considerably
depending on geographic location and
that average energy consumption is
likely lower than the energy use DOE
suggested in its Framework Document.
In consultation with manufacturers and
others familiar with that type of
product, AHAM estimated that
dehumidifier use is between 875 and
1,315 hours per year, and it
recommended that DOE use the midpoint (1,095 hours) as the norm (with
sensitivity analyses at 875 and 1,315
hours/year). AHAM also stated that
many dehumidifiers shut off
automatically once their condensation
TABLE II.36.—DEHUMIDIFIER ANNUAL ENERGY CONSUMPTION DERIVED FROM HOURLY USE
Product class
Average size
EF
Annual energy use (kWh/year)
AHAM
Pints/day
Pints/day
Liters/day
Liters/kWh
ADL
Low
mstockstill on PROD1PC66 with PROPOSALS2
≤25.00 ........................................
25.01–35.00 ...............................
35.01–45.00 ...............................
45.01–54.00 ...............................
54.01–74.99 ...............................
≥75.00 ........................................
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estimated the annual energy
consumption of electric and gas
ranges.25 The studies that covered the
time period of 1977–1992 showed a
steady decline in the annual energy
consumption. Based on these studies,
DOE published revisions to its test
procedure as a final rule in 1997, which
included a reduction in the annual
useful cooking energy output and a
reduction in the number of self-cleaning
oven cycles per year.26 The annual
useful cooking energy output relates the
TABLE II.37 25.01.—35.00 PINTS/DAY energy factor of the cooking appliance to
DEHUMIDIFIERS: ANNUAL ENERGY the annual energy consumption.
USE BY CANDIDATE STANDARD Therefore, the lower the annual useful
cooking energy output, the lower the
LEVEL
annual energy consumption of the
cooking appliance.
Efficiency
Annual
Candidate
energy use
Whirlpool and EEI stated that the
standard level
annual energy consumption of cooking
liters/kWh
kWh/year
products is very likely lower than it was
Baseline ........
1.20
540 in the mid-1990s due to changes in
1 ....................
1.25
518 consumer eating habits (i.e., people
2 ....................
1.30
498 eating out more often). (Whirlpool, No.
3 ....................
1.35
480 10 at p. 10; EEI, No. 7 at p. 3) Based on
4 ....................
1.40
463 more recent studies of cooking annual
5 ....................
1.45
447 energy use, DOE confirmed that cooking
energy consumption has continued to
Unlike dishwashers, RECS does not
decline since the mid-1990s. Research
have any data that indicate the use or
results from the 2004 California
annual energy consumption of
Residential Appliance Saturation Study
dehumidifiers. Therefore, DOE did not
(CA RASS) 27 and the Florida Solar
use RECS to determine the variability of Energy Center (FSEC) 28 show that the
annual energy consumption. Rather,
annual energy consumption for most
DOE relied exclusively on the data that
electric and gas cooktops and ovens is
AHAM provided (see Table II.37) to
roughly 40 percent less than the energy
characterize the variability in annual
use during the mid-1990s.
energy consumption. As discussed
Based on the more recent annual
previously, DOE used AHAM’s estimate energy use data, DOE established the
of 1,095 hours to calculate the average
25 U.S. Department of Energy-Office of Codes and
annual energy consumption. To
Standards. Technical Support Document for
characterize the variability of use, DOE
Residential Cooking Products, Volume 2: Potential
used a triangular probability
distribution that had an average value of Impact of Alternative Efficiency Levels for Prepared
Residential Cooking Products, April, 1996.
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
online at: https://www.eere.energy.gov/buildings/
maximum value of 1,315 hours. As will
appliance_standards/residential/
be described later in section II.G on the
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
energy consumption when it conducted Statewide Residential Appliance Saturation Study,
June 2004. (Prepared for the CEC by KEMA–
the LCC and PBP analyses. Additional
detail on the energy use characterization XNERGY, Itron, and RoperASW. Contract No. 400–
04–009). Available online at: https://
of dehumidifiers can be found in
www.energy.ca.gov/appliances/rass/.
Chapter 6 of the TSD.
28 Parker, D. S. Research Highlights from a Large
Table II.37 presents the annual energy
consumption by candidate standard
level for the predominant dehumidifier
product class, 25.0–35.00 pints/day. The
annual energy consumption reflects an
annual use corresponding to AHAM’s
mid-estimate of annual hourly operation
(i.e., 1,095 hours per year). Refer to
Chapter 6 of the TSD for the annual
energy consumption by candidate
standard level for the other five
dehumidifier product classes.
3. Cooking Products
mstockstill on PROD1PC66 with PROPOSALS2
a. Cooktops and Ovens
The annual energy consumption of
electric and gas ranges (i.e., cooktops
and ovens) has been in continual
decline since the late 1970s. DOE’s prior
rulemaking on residential cooking
products identified several studies that
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its Environmental Impact, January 2002. Japan
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the Future Program, Osaka, Japan. JPSRFTF97P01002: pp. 108–116. Also published as
FSEC–PF369–02, Florida Solar Energy Center,
Cocoa, FL. Available online at: https://
www.fsec.ucf.edu/en/publications/html/FSEC–PF–
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annual energy consumption for
cooktops and ovens by candidate
standard level. Tables II.38 through II.40
show the annual energy consumption by
candidate standard level for the electric
coil, electric smooth, and gas cooktop
product classes, respectively. Tables
II.41 through II.44 show the annual
energy consumption by candidate
standard level for the electric standard,
electric self-cleaning, gas standard, and
gas self-cleaning oven product classes,
respectively. For gas standard ovens
(Table II.43), candidate standard level 1
(globar or hot surface ignition) and
candidate standard level 1a (spark
ignition) are addressed separately
because the technologies have different
energy use characteristics. Although
both technologies are used for the same
purpose (i.e., to eliminate the need for
a standing pilot), hot surface ignition
uses a significant amount of electrical
energy while spark ignition uses a
negligible amount of electricity. The use
of a globar ignition device is the
technology most commonly used to
eliminate the need for a standing pilot
in gas ovens. Therefore, in the case of
gas standard ovens, efficiency levels two
through six follow efficiency level ‘1’
(globar ignition) rather than level ‘1a’
(spark ignition), and in the case of gas
self-cleaning ovens, the baseline
efficiency level is based on the use of a
globar ignition device. For more details
on how DOE developed the annual
energy consumption for each product
class, refer to Chapter 6 of the TSD.
TABLE II.38.—ELECTRIC COIL
COOKTOPS: ANNUAL ENERGY CONSUMPTION BY CANDIDATE STANDARD
LEVEL
Candidate
standard level
Energy
factor
Annual energy
consumption
kWh/year
Baseline ............
1 ........................
0.737
0.769
128.2
122.9
TABLE II.39.—ELECTRIC SMOOTH
COOKTOPS: ANNUAL ENERGY CONSUMPTION BY CANDIDATE STANDARD
LEVEL
Candidate
standard level
Energy
factor
Annual energy
consumption
kWh/year
Baseline ............
1 ........................
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TABLE II.40.—GAS COOKTOPS: ANNUAL ENERGY CONSUMPTION BY CANDIDATE STANDARD LEVEL
Candidate standard level
Cooking
efficiency
(percent)
Energy factor
Baseline ...............................................................................
1 ...........................................................................................
2 ...........................................................................................
0.156
0.399
0.420
Cooking
Pilot
Total
MMBtu/year
MMBtu/year
MMBtu/year
39.9
39.9
42.0
0.72
0.72
0.69
2.01
........................
........................
2.74
0.72
0.69
TABLE II.41.—ELECTRIC STANDARD OVENS: ANNUAL ENERGY CONSUMPTION BY CANDIDATE STANDARD LEVEL
Candidate standard level
Cooking
efficiency
(percent)
Energy factor
Baseline .........................................................................................
1 .....................................................................................................
2 .....................................................................................................
3 .....................................................................................................
4 .....................................................................................................
5 .....................................................................................................
0.1066
0.1113
0.1163
0.1181
0.1206
0.1209
Cooking
Clock
Total
kWh/year
kWh/year
kWh/year
12.2
12.8
13.4
13.7
14.0
14.1
132.4
125.9
119.7
117.6
70.7
70.6
34.2
34.2
34.2
34.2
34.2
34.2
166.5
160.1
153.9
151.8
149.0
148.6
TABLE II.42.—ELECTRIC SELF-CLEANING OVENS: ANNUAL ENERGY CONSUMPTION BY CANDIDATE STANDARD LEVEL
Candidate standard level
Cooking efficiency
(percent)
Energy factor
Baseline ...............................................................
1 ...........................................................................
2 ...........................................................................
0.1099
0.1102
0.1123
Cooking
Self-clean
Clock
Total
kWh/year
kWh/year
kWh/year
kWh/year
13.8
13.8
14.2
116.6
116.2
113.5
21.1
21.1
21.1
33.3
33.3
33.3
171.0
170.6
167.9
TABLE II.43.—GAS STANDARD OVENS: ANNUAL ENERGY CONSUMPTION BY CANDIDATE STANDARD LEVEL
Cooking
efficiency
(percent)
Energy
factor
Candidate standard level
Baseline ...........................................
1* ......................................................
2 .......................................................
3 .......................................................
4 .......................................................
5 .......................................................
6 .......................................................
1a* ....................................................
0.0298
0.0536
0.0566
0.0572
0.0593
0.0596
0.0600
0.0583
Cooking
MMBtu/yr
5.9
5.8
6.1
6.2
6.5
6.5
6.6
5.8
Ignition
Total
kWh/yr
0.82
0.84
0.80
0.79
0.75
0.75
0.74
0.84
MMBtu/yr
kWh/yr
..................
..................
..................
..................
1.8
1.8
1.8
..................
1.01
..................
..................
..................
..................
..................
..................
..................
..................
21.1
21.1
21.1
21.1
21.1
21.1
..................
MMBtu/yr
kWh/yr
1.83
0.84
0.80
0.79
0.75
0.75
0.74
0.84
0.0
21.1
21.1
21.1
22.9
22.9
22.9
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 derived from candidate standard level 1.
TABLE II.44.—GAS SELF-CLEANING OVENS: ANNUAL ENERGY CONSUMPTION BY CANDIDATE STANDARD LEVEL
Candidate
standard level
mstockstill on PROD1PC66 with PROPOSALS2
Baseline .............
1 ........................
2 ........................
3 ........................
Energy
factor
0.0540
0.0625
0.0627
0.0632
Cooking
effc’y
(percent)
Cooking
MMBtu/yr
7.1
8.8
8.8
8.9
0.68
0.56
0.55
0.55
DOE used 2001 RECS data to establish
the variability of annual cooking energy
consumption for cooktops and ovens.
RECS indicates which households in the
survey of 4,822 households use electric
and gas ranges, ovens, and cooktops.
With regard to electric cooking
products, 2,895 household records have
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kWh/yr
MMBtu/yr
....................
1.8
1.8
1.8
0.17
0.17
0.17
0.17
Ignition
kWh/yr
0.7
0.7
0.7
0.7
cooktops; 1,159 household records have
standard ovens, and 1,601 household
records have self-cleaning ovens. With
regard to gas cooking products, 1,597
household records have cooktops either
in electric ranges or as stand-alone
units; 959 household records have
standard ovens, and 494 household
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kWh/yr
kWh/yr
21.1
21.1
21.1
21.1
31.5
31.5
31.5
31.5
Total
MMBtu/yr
0.86
0.73
0.73
0.72
kWh/yr
53.3
55.1
55.1
55.1
records have self-cleaning ovens. The
above totals represent cooktops and
ovens in households either as a standalone unit or as part of a range.
Although RECS does not provide the
annual energy consumption of the
cooking product for each household
record, it does provide the frequency of
cooking use. Thus, DOE used the
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frequency of use to define the variability
of the annual energy consumption.
Conducting the analysis in this manner
captured the observed variability in
annual energy consumption while
maintaining the average annual energy
consumption shown above in Tables
II.38 through II.44. To determine the
variability of cooking product energy
consumption, DOE first equated the
weighted-average cooking frequency
from RECS with the average energy use
values reported in Tables II.38 through
II.44. DOE then varied the annual
energy consumption for each RECS
household based on its reported cooking
frequency.
For more details on cooking frequency
variability and its impact on the
variability of annual energy
consumption, as well as additional
detail on the energy use characterization
of kitchen ranges and ovens, refer to
Chapter 6 of the TSD. As will be
described later in section II.G on the
LCC and PBP analyses, DOE used the
RECS household samples with their
associated baseline annual energy
consumption to conduct the LCC and
PBP analyses.
b. Microwave Ovens
After an increase since the late 1970s,
the annual energy consumption of
microwave ovens has remained
relatively steady since the late 1980s.
DOE’s previous rulemaking on
residential cooking products identified
studies that estimated the annual energy
consumption of microwave ovens.29
With the exception of one study based
on the use of conditional demand
analysis,30 the studies, which covered
the time period 1988–1994, showed that
annual energy consumption was no
more than 200 kWh/year. Based on
these studies, DOE published revisions
to its test procedure as a final rule in
1997 that included an increase in the
annual useful cooking energy output
that more than doubled the test
procedure’s original value from the late
1970s (62 FR 51976 (October 3, 1997)).
The annual useful cooking energy
output relates the energy factor of the
microwave oven to the annual energy
consumption. Therefore, the higher the
annual useful cooking energy output,
the higher the annual energy
consumption.
A more recent study from the 2004
CA RASS is roughly in line with the
average result from the previous studies
showing that annual energy
consumption has declined 15 percent
since the mid-1990s. Based on the CA
RASS study, DOE established the
annual energy consumption for
microwave ovens by candidate standard
level as shown in Table II.45. For more
details on how DOE developed the
annual energy consumption for
microwave ovens, refer to Chapter 6 of
the TSD.
TABLE II.45.—MICROWAVE OVENS: ANNUAL ENERGY CONSUMPTION BY CANDIDATE STANDARD LEVEL
Candidate standard level
Energy factor
mstockstill on PROD1PC66 with PROPOSALS2
Baseline .......................................................................................................................................
1 ...................................................................................................................................................
2 ...................................................................................................................................................
3 ...................................................................................................................................................
4 ...................................................................................................................................................
0.557
0.586
0.588
0.597
0.602
Cooking
efficiency
(percent)
Total
kWh/year
55.7
58.6
58.8
59.7
60.2
131.0
124.5
124.1
122.2
121.2
In its Framework Document, DOE
requested energy use data for the
individual components of the
microwave oven (e.g., magnetron
filament, magnetron power supply, and
fan and motor). Sharp stated that the
measurement methods in the DOE test
procedure require the establishment of
only the total input power of the oven
and not the input power associated with
individual components. Therefore,
Sharp argued that if the oven is being
tested in accordance with the DOE test
procedure, disaggregated energy use
data is neither apposite nor readily
available. (Public Meeting Transcript,
No. 5 at p. 108) DOE agrees that its test
procedure only requires the
measurement of total energy use, so, for
purposes of this analysis, DOE has
decided to only consider the total
energy consumption of the product.
With regard to the variability of
annual cooking energy consumption, as
it did for cooktops and ovens, DOE used
RECS to establish microwave oven use
variability. The 2001 RECS indicates
that 4,149 of the 4,822 households in
the survey use microwave ovens.
Similar to electric and gas cooktops and
ovens, although RECS does not provide
the annual energy consumption of
microwave ovens for each household
record, it does provide the frequency of
cooking use. Thus, DOE used the
frequency of microwave use to define
the variability of the annual energy
consumption. Conducting the analysis
in this manner captured the observed
variability in annual energy
consumption while maintaining the
average annual energy consumption
shown above in Table II.45. To
determine the variability of cooking
product energy consumption, DOE first
equated the weighted-average cooking
frequency from RECS with the average
energy use values reported above in
Table II.45. DOE then varied the annual
energy consumption for each RECS
household based on its reported cooking
frequency.
For more details on cooking frequency
variability and its impact on the
variability of annual energy
consumption, as well as additional
detail on the energy use characterization
of microwave ovens, refer to Chapter 6
of the TSD. As will be described later in
section II.G on the LCC and PBP
analyses, DOE used the RECS household
samples with their associated baseline
annual energy consumption to conduct
the LCC and PBP analyses.
29 U.S. Department of Energy—Office of Codes
and Standards. Technical Support Document for
Residential Cooking Products, Volume 2: Potential
Impact of Alternative Efficiency Levels for
Residential Cooking Products, April, 1996. Prepared
for the U.S. DOE by Lawrence Berkeley National
Laboratory, Berkeley, CA. Appendix A. Available
online at: https://www.eere.energy.gov/buildings/
appliance_standards/residential/cooking_products
_0998_r.html
30 Electric Power Research Institute. Residential
End-Use Energy Consumption: A Survey of
Conditional Demand Estimates, October 1989. Palo
Alto, CA. CU–6487. Available online at: https://
my.epri.com/portal/server.pt?space=Community
Page&cached=true&parent
name=ObjMgr&parentid=2&control=Set
Community&CommunityID=221&PageIDquery
ComId=0
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4. Commercial Clothes Washers
DOE determined the annual energy
and water consumption of CCWs by
multiplying the per-cycle energy and
water use by the number of cycles per
year. CCW per-cycle energy
consumption has three components: (1)
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Water-heating energy; (2) machine
energy; and (3) drying energy. The
machine energy is comprised of the
motor energy for turning an agitator or
rotating a drum.
The test procedures DOE recently
codified at 10 CFR 431.154 are based on
measuring the performance of
residential clothes washers, and,
therefore, the cycles-per-year values
only indirectly reflect CCW usage
through comparison with their
residential counterparts (71 FR 71340).
However, both ALS and EEI stated that
CCW use is highly variable. ALS stated
that CCW use varies based on the
clothes washer market (e.g., laundry and
multi-housing). ALS recommended
contacting the MLA, the CLA, and route
operators to obtain relevant use data.
(Public Meeting Transcript, No. 5 at pp.
156–157; EEI, No. 7 at p. 6) As
discussed in more detail below, DOE
has relied on several studies including
research sponsored by the MLA and the
CLA (trade associations representing the
commercial laundry industry) to
establish typical use cycles for CCWs.
As shown in Table II.46, DOE
analyzed the energy and water use for
specific candidate standard levels for
CCWs. GE commented that because
clothes container volume (capacity) may
change with product efficiency, DOE
should not use a constant capacity when
determining the energy and water
consumption of CCWs. GE suggested
that DOE evaluate energy consumption
on a per-cubic-foot basis. (Public
Meeting Transcript, No. 5 at p. 158)
DOE agrees that capacity does impact
product efficiency, but no data were
provided or identified on how capacity
may change with increased efficiency.
Therefore, DOE maintained a constant
capacity in its analysis of annual energy
consumption by candidate standard
level. However, DOE invites additional
comments and data regarding the
relationship between CCW capacity and
efficiency.
EEI requested clarification as to
whether the energy consumption
analysis for CCWs would capture
reduced dryer energy consumption as a
result of higher clothes washer
efficiencies. (Pubic Meeting Transcript,
No. 5 at p. 154) In response, we note
that CCWs are rated with an MEF, and
inherent in the determination of the
MEF is the energy required to dry
clothes. Therefore, DOE did capture the
impact of higher efficiencies on dryer
energy use.
Table II.46 shows the candidate
standard levels for CCWs and their
corresponding per-cycle energy and
water use. DOE determined the percycle clothes-drying energy use by first
establishing the remaining moisture
content (RMC) based on the relationship
between RMC and the MEF, and then
using the DOE test procedure equation
that determines the per-cycle energy
consumption for the removal of
moisture. DOE took the per-cycle
machine energy use from its 2000 TSD
for residential clothes washers.31 In the
2000 TSD, for MEFs up to 1.40, machine
energy is 0.133 kWh/cycle. For MEFs
greater than 1.40, machine energy is
0.114 kWh/cycle. With the per-cycle
clothes-drying and machine energy
known, DOE determined the per-cycle
water-heating energy use by first
determining the total per-cycle energy
use (the clothes container volume
divided by the MEF) and then
subtracting from it the per-cycle clothesdrying and machine energy.
DOE specifically seeks stakeholder
feedback on whether the residential
clothes washer per-cycle energy
consumption values for clothes-drying
and machine use taken from its 2000
TSD are representative of CCWs. This is
identified as Issue 9 under ‘‘Issues on
Which DOE Seeks Comment’’ in section
IV.E of this ANOPR.
EEI commented that detergents
formulated for cold-water washes are
now available. Because no hot water
will be required if these detergents are
used, the baseline energy consumption
will be impacted. (EEI, No. 7 at p. 4)
However, DOE cannot assume that
consumers will routinely use cold-water
detergents. Thus, although cold-water
detergents may be available, DOE
determined the water-heating energy
use using the specifications set forth in
the DOE test procedure. The per-cycle
water-heating energy use in Table II.46
below depicts the use of an electric
water heater and a 2.8 ft3 clothes
container volume. DOE determined the
per-cycle hot water use by dividing the
per-cycle water-heating energy use by a
temperature rise of 75 °F (21 °C) and a
specific heat of 0.0024 kWh/gal × °F
(4.186 joule/gram × °C). DOE
determined the total water use by
multiplying the WF by the clothes
container volume.
TABLE II.46.—COMMERCIAL CLOTHES WASHERS: PER-CYCLE ENERGY AND WATER USE BY CANDIDATE STANDARD LEVEL
Energy use
MEF
WF
cu.ft./kWh/cyc
Candidate standard
level
gal/cu.ft.
mstockstill on PROD1PC66 with PROPOSALS2
Baseline ...................
1 ...............................
2 ...............................
3 ...............................
4 ...............................
5 ...............................
6 ...............................
1.26
1.42
1.60
1.72
1.80
2.00
2.20
RMC
(percent)
9.50
9.50
8.50
8.00
7.50
5.50
5.10
Water use
Dryer
Water Heat
Hot
Total
kWh/cyc
53.7
51.2
48.4
46.5
45.3
42.2
39.0
Machine
kWh/cyc
kWh/cyc
gal/cyc
gal/cyc
0.133
0.133
0.114
0.114
0.114
0.114
0.114
1.27
1.21
1.13
1.09
1.06
0.98
0.90
0.82
0.63
0.50
0.43
0.39
0.31
0.26
4.5
3.5
2.8
2.4
2.1
1.7
1.5
26.6
26.6
23.8
22.4
21.0
15.4
14.3
DOE determined the average annual
energy and water consumption for
CCWs by multiplying the per-cycle
energy and water consumption by the
number of cycles per year. Because the
predominant applications of CCWs are
in multi-family buildings and
laundromats, DOE focused only on
these two building applications to
determine the appropriate number of
CCW cycles per year. Other applications
include lodging establishments (e.g.,
hotels and motels), in-patient health
care facilities, and nursing homes.
Relative to multi-family buildings and
laundromats, these other applications
are a small segment of the market.
Therefore, DOE believes it is not critical
to the analysis to accurately characterize
CCW usage for these applications. As
mentioned above, DOE relied on several
31 U.S. Department of Energy. Final Rule
Technical Support Document (TSD): Energy
Efficiency Standards for Consumer Products:
Clothes Washers, December 2000. Washington, DC.
Chapter 4, Table 4.1. Available online at: https://
www.eere.energy.gov/buildings/
appliance_standards/residential/
clothes_washers.html.
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studies including research sponsored by
the MLA and the CLA to establish
typical use cycles for CCWs. Of the
studies on CCW usage, seven focused on
multi-family buildings demonstrating
that usage ranged from one to almost
eleven cycles per day.32 The sparse data
for laundromats from three studies
showed a variation between three to
eight cycles per day.33
Tables II.47 and II.48 show the annual
energy and water consumption for
multi-family buildings and
laundromats, respectively. The energy
and water consumption values provided
below are based on average use cycles
of 3.4 cycles per day for multi-family
64477
buildings and 6 cycles per day for
laundromats. For details on the studies
reviewed by DOE to develop the average
use cycles of CCWs, refer to Chapter 6
of the TSD. In the tables below, the
annual water-heating and clothes-drying
energy consumption reflects the use of
both an electric or a gas water heater
and dryer.
TABLE II.47.—COMMERCIAL CLOTHES WASHERS, MULTI-FAMILY APPLICATION: ANNUAL ENERGY AND WATER USE BY
EFFICIENCY LEVEL
Annual energy use
Candidate
standard level
MEF
WF
Water heating
Drying
Annual water use
Machine
Electric
cu.ft./kWh/cyc
Baseline ...........
1 .......................
2 .......................
3 .......................
4 .......................
5 .......................
6 .......................
gal/cu.ft.
1.26
1.42
1.60
1.72
1.80
2.00
2.20
9.50
9.50
8.50
8.00
7.50
5.50
5.10
Gas
Electric
Gas
kWh/yr
MMBtu/yr
kWh/yr
MMBtu/yr
1020
788
625
532
482
387
328
4.64
3.58
2.84
2.42
2.19
1.76
1.49
1583
1503
1414
1354
1315
1215
1116
6.05
5.74
5.40
5.18
5.02
4.64
4.26
kWh/yr
166
166
142
142
142
142
142
1000 gal/year
33.1
33.1
29.7
27.9
26.2
19.2
17.8
TABLE II.48.—COMMERCIAL CLOTHES WASHERS, LAUNDROMAT APPLICATION: ANNUAL ENERGY AND WATER USE BY
CANDIDATE STANDARD LEVEL
Annual Energy Use
Candidate
standard level
MEF
WF
Water heating
Drying
Annual water use
Machine
Electric
cu.ft./kWh/cyc
mstockstill on PROD1PC66 with PROPOSALS2
Baseline ...........
1 .......................
2 .......................
3 .......................
4 .......................
5 .......................
6 .......................
gal/cu.ft.
1.26
1.42
1.60
1.72
1.80
2.00
2.20
9.50
9.50
8.50
8.00
7.50
5.50
5.10
Gas
Electric
Gas
kWh/yr
MMBtu/yr
kWh/yr
MMBtu/yr
1793
1385
1098
935
847
680
576
8.16
6.30
4.99
4.25
3.85
3.10
2.62
2782
2642
2485
2380
2310
2136
1961
10.63
10.10
9.50
9.10
8.83
8.16
7.49
kWh/yr
291
291
250
250
250
250
250
1000 gal/year
58.3
58.3
52.1
49.1
46.0
33.7
31.3
DOE determined the variability in
annual energy and water consumption
based on usage data from the several
CCW studies cited above. The studies
DOE identified provided eight average
use values for multi-family buildings
ranging from a low of 1.5 cycles per day
to a high of 6.4 cycles per day. For
laundromats, the low and high values
are three and eight cycles per day,
respectively. DOE weighted the usage
from each study to vary the annual
energy and water consumption of CCWs
when it conducted the LCC and PBP
analyses. To reflect the usage patterns
reported in the various studies, DOE
weighted the use studies equally for
multi-family applications. For
laundromats, DOE used a triangular
distribution that ranged from three to
eight cycles per day and skewed it to
yield an average value of six cycles per
day. This range was based solely on data
from the CLA. Of the three studies that
DOE used to establish usage, only the
CLA study provided a range. Because
the two other studies, one from
Equipoise Consulting and the other from
CEE, provided an average use of six
cycles per day, DOE skewed the
triangular distribution to yield an
average value of six cycles per day.
As will be described later in section
II.G on the LCC and PBP analyses, DOE
used the usage variability to vary the
annual energy and water consumption
for multi-family and laundromat
applications when it conducted the LCC
and PBP analyses. Additional detail on
the energy and water use
characterization of CCWs can be found
in Chapter 6 of the TSD.
32 The seven studies were conducted or
commissioned by the following organizations: (1)
City of Toronto (1999); (2) Federal Energy
Management Program (2000); (3),Southern
California Edison (2000); (4) MLA (2002); (5)
Wisconsin Focus on Energy (2004); (6) Equipoise
Consulting (2004); and (7) CEE.
33 The three studies were conducted or
commissioned by the following organizations: (1)
Equipoise Counsulting (2004); (2) CEE; and (3) the
CLA.
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E. Markups To Determine Equipment
Price
This section explains how DOE
developed the markups to equipment
prices that it used to derive total
installed cost for the four appliance
products (see Chapter 7 of the TSD). The
total installed cost is the sum of the
consumer equipment price and the
installation cost. DOE multiplied the
manufacturing costs developed from the
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lodging establishments, and health care
facilities). For these three market areas,
the CEE data indicate that an
overwhelming majority of CCWs are
sold through either distributors or route
operators. Consistent with ALS’s
comment, the CEE data show that
laundromats generally purchase their
equipment through distributors,
1. Distribution Channels
whereas multi-family housing and large
Before it could develop markups, DOE institutions generally lease their
needed to identify distribution channels equipment from route operators.
(i.e., how the product is distributed from Because the CEE data do not indicate
the manufacturer to the consumer).
that national accounts are a significant
AHAM’s 2003 Fact Book shows that
distribution channel, DOE did not
over 93 percent of residential appliances consider them in its analysis. Thus, for
(including dishwashers, dehumidifiers,
purposes of developing the markups for
and cooking products) are distributed
CCWs, DOE based its calculations on
from the manufacturer directly to a
the distribution channel that involves
retailer. Thus, DOE analyzed markups
only distributors. DOE estimated that
for residential dishwasher,
the markups and the resulting consumer
dehumidifier, and cooking product sales equipment prices for the distribution
on the premise that these appliances are channel involving distributors would be
sold based on a manufacturer-to-retailer representative of the prices paid by
distribution channel. Wolf commented
consumers acquiring their equipment
that for commercial-style cooking
from route operators.
products, distributors are also involved
DOE specifically seeks feedback on
in the distribution of the equipment.
whether determining CCW consumer
(Public Meeting Transcript, No. 5 at p.
prices based solely on the distribution
177). For its analysis of cooking
channel that includes distributors will
products, DOE designated commercialresult in representative equipment
style equipment as a separate product
prices for all CCW consumers. This is
class that was exempted from the
identified as Issue 10 under ‘‘Issues on
analysis due to the lack of available data Which DOE Seeks Comment’’ in section
for determining efficiency
IV.E of this ANOPR.
characteristics. Therefore, DOE did not
2. Approach for Manufacturer Markups
consider the distribution channels for
DOE developed an average
commercial-style equipment.
manufacturer markup by examining the
For CCWs, the consumer is usually a
commercial establishment. EEI and ALS annual Securities and Exchange
Commission (SEC) 10–K reports filed by
both commented on the distribution
four publicly-traded manufacturers
channels for this product. EEI stated
primarily engaged in appliance
that national accounts may be
manufacturing and whose combined
applicable if users (e.g., hotels) are
product range includes residential
purchasing units in bulk from dealers.
dishwashers, dehumidifiers, and
ALS stated that the distribution
cooking products and commercial
channels DOE identified during its
clothes washers.35 The four
Framework workshop were correct and
added that laundromat owners generally manufacturers represent a nearly 50
go through distributors to purchase their percent market share for core
clothes washers, whereas multi-housing appliances. Because these companies
owners generally go through route
are typically diversified, producing a
operators. (Public Meeting Transcript,
range of different appliances, an
No. 5 at pp. 175–176).
industry average markup was assumed
DOE developed the distribution
by DOE to be representative for the
channels for this analysis of CCWs after manufacture of each type of appliance.
reviewing data that CEE developed.34
DOE evaluated markups for the years
The CEE data indicate that the relevant
between 2002 and 2005, inclusive.
portions of the commercial, family-sized
3. Approach for Retailer and Distributor
clothes washer market can be divided
Markups
into three areas: (1) Laundromats; (2)
DOE based the retailer markups (for
private multi-family housing; and (3)
large institutions (e.g., military barracks, residential products) and distributor
markups (for CCWs) on financial data
universities, housing authorities,
from the U.S. Census Business
mstockstill on PROD1PC66 with PROPOSALS2
engineering analysis by the supplychain markups it developed (along with
sales taxes) to arrive at the consumer
equipment prices, and added to them
the installation costs to arrive at the
final, installed prices for baseline
products, as well as higher-efficiency
products.
34 Consortium
for Energy Efficiency, Commercial
Family-Sized Washers: An Initiative Description of
the Consortium for Energy Efficiency, 1998.
Available online at: https://www.cee1.org/com/cwsh/
cwsh-main.php3
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35 Security Exchange Commission, SEC 10–K
Reports, Various dates, 2002–2005, Security
Exchange Commission. Available online at: https://
www.sec.gov/
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Expenditure Survey (BES).36 DOE
organized the financial data into balance
sheets that break down cost components
incurred by firms that sell the products.
DOE developed baseline and
incremental markups to transform the
manufacturer sales price into a
consumer equipment price. DOE used
the baseline markups, which cover all of
a retailer’s or distributor’s costs, to
determine the sales price of baseline
models (equipment sold under existing
market conditions). The baseline
markup relates the manufacturer sales
price to the retailer sales price (in the
case of residential products) or
distributor sales price (in the case of
CCWs). Incremental markups cover only
those costs that scale with a change in
the manufacturer’s sales price.
Incremental markups are coefficients
that relate the change in the
manufacturer sales price of higher
efficiency models (equipment sold
under market conditions with new
efficiency standards) to the change in
the retailer or distributor sales price.
DOE used financial data from the
BES, in the ‘‘Household Appliance
Stores’’ category, to calculate markups
used by retailers that apply to
residential dishwashers, cooking
products, and dehumidifiers. It used
financial data from the BES for the
category ‘‘Machinery, Equipment, and
Supplies Merchant Wholesalers’’ to
calculate markups used by distributors
for CCWs. Using these markups, DOE
generated retail prices for each potential
standard level, assuming that each level
would represent a new minimum
efficiency standard.
For CCWs, DOE undertook efforts to
validate the retail prices that it
generated through the use of distributor
markups. Both the Seattle Public
Utilities (SPU) and ALS suggested
sources for establishing the retail price
of CCWs. SPU stated that it may have
relevant data that it obtained through
one of its rebate incentive programs.
ALS suggested that DOE contact the
MLA, route operators, and property
owners. (Public Meeting Transcription,
No. 5 at pp. 174 and 176) DOE contacted
several national distributors of
commercial laundry equipment to
collect CCW retail price data. DOE also
identified a few company Web sites that
provided retail price information. DOE
did obtain the price data offered by
SPU, but because all of the data
corresponded to high-efficiency, front36 U.S. Census Bureau. 1997 Economic Census,
Business Expense Survey, Retail Trade, Household
Appliance Stores and Merchant Wholesalers,
Machinery, Equipment, and Supplies, 1997.
Washington, DC Available online at: https://
www.census.gov/csd/bes/bes97.htm
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loading, horizontal-axis washers, the
data were not useful for identifying the
price differential between baseline and
more-efficient products. With the price
data it did collect, DOE attempted to
develop a retail price-versus-efficiency
curve. However, most of the price data
collected from distributors and Web
sites did not provide the necessary
information to establish the efficiency of
these commercial clothes washers.
Therefore, DOE was only able to
establish the retail price differential
between a typical top-loading, verticalaxis machine and a front-loading,
horizontal-axis machine. The retail
price difference (approximately $500) is
very close to the retail price DOE
generated through the use of markups.
Therefore, for the price difference
between a typical top-loading machine
and a typical front-loading machine,
DOE confirmed that its retail price
increment for achieving CCW
efficiencies in the range of 1.72 to 2.20
MEF were reasonable. Chapter 3 of the
TSD provides details on DOE’s CCW
retail price data collection effort.
4. Sales Taxes
The sales tax component of the DOE
mark-up analysis represents State and
local sales taxes that are applied to the
consumer appliance price. It is a
multiplicative factor that increases the
consumer appliance price. DOE derived
State and local taxes from data provided
by the Sales Tax Clearinghouse.37 These
data represent weighted averages that
include county and city rates. DOE then
derived population-weighted average
tax values for each Census division and
large State.
5. Summary of Markups
Table II.49 summarizes each product’s
markups at each stage in the
distribution channel and the overall
baseline and incremental markups, as
well as sales taxes. AHAM questioned
what the typical overall markup is for
home appliances and stated that, for
residential clothes washers, a prior
standards rulemaking analysis
established an overall markup of
approximately 2.0. (Public Meeting
Transcript, No. 5 at p. 177) As shown
in Table II.49, the overall baseline
markup is approximately 2.0 for all
products, almost the same as the
markup DOE used in its residential
clothes washer standard rulemaking.
The overall incremental markup, which
DOE applied to an incremental change
in manufacturing costs to develop an
incremental change in retail price, is
approximately 1.60. Additional detail
on markups can be found in Chapter 7
of the TSD.
TABLE II.49.—SUMMARY OF MARKUPS
Dishwashers
Dehumidifiers
Cooking products
Commercial clothes washers
Markup
Baseline
Manufacturer ......................................
1.26
Retailer ...............................................
1.45
Incr.
Baseline
Incr.
1.26
1.15
1.45
Baseline
Incr.
1.26
1.15
1.45
Baseline
1.26
1.15
Distributor ...........................................
1.43
Sales Tax ...........................................
1.068
Overall ................................................
1.065
1.95
1.55
1.95
1.069*
1.54
1.95
Incr.
1.18
1.068
1.55
1.93
1.59
• Represents average of all seven product classes of cooking products.
A more energy efficient device will
usually cost more to buy than a device
of standard energy efficiency. However,
the more efficient device will usually
cost less to operate due to reductions in
operating costs (i.e., lower energy bills).
The PBP is the time (usually expressed
in years) it takes to recover the
additional installed cost of the more
efficient device (i.e., the incremental
cost) through energy cost savings. EPCA
establishes a rebuttable presumption
that a standard for any of the four
appliance products is economically
justified ‘‘[i]f the Secretary finds that the
additional cost to the consumer of
purchasing a product complying with
an energy conservation standard level
will be less than three times the value
of the energy * * * savings during the
first year that the consumer will receive
as a result of the standard, as calculated
under the applicable test procedure
* * * ’’ (42 U.S.C. 6295(o)(2)(B)(iii) and
6316(a))
To evaluate the rebuttable
presumption, DOE estimated the
additional cost of purchasing a more
efficient, standard-compliant product,
and compared this cost to the value of
the energy saved during the first year of
operation of the product. DOE
understands that the increased cost of
purchasing a standard-compliant
product includes the cost of installing
the product for use by the purchaser.
DOE calculated the rebuttable
presumption PBP (rebuttable PBP), as
the ratio of the value of the increased
installed price above the baseline
efficiency level to the first year’s energy
cost savings. When this PBP is less than
three years, the rebuttable presumption
is satisfied. When this PBP is equal to
or more than three years, the rebuttable
presumption is not satisfied. In such
case, the Secretary must take such
37 Sales Tax Clearinghouse, Inc. State sales tax
rates along with combined average city and county
mstockstill on PROD1PC66 with PROPOSALS2
information into account when
determining whether a standard is
economically justified. (42 U.S.C.
6295(o)(2)(B)(iii))
Inputs to the PBP calculation are the
first seven inputs shown in Table II.57
found in section II.G.2 of this ANOPR.
The rebuttable PBPs differ from the
other PBPs calculated in the LCC
analysis, in that the calculation of
rebuttable PBP uses discrete values
(rather than distributions) for inputs.
Other than the use of single-point
values, the most notable difference
between the distribution PBP and the
rebuttable PBP is the latter’s reliance on
the DOE test procedure to determine a
product’s annual energy (and water)
consumption. The distribution PBP is
based on the annual energy and water
consumption data described in section
II.D, which are characterized with a
range of values as opposed to the
discrete single-point value that is used
for the rebuttable PBP.
rates, 2006. Available online at: https://thestc.com/
STrates.com.
F. Rebuttable Presumption Payback
Periods
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For dishwashers, DOE based the
annual energy and water consumption
values that it used to determine the
rebuttable PBP on the number of cycles
per year specified in the DOE test
procedure. The number of cycles from
the DOE test procedure, 215 cycles per
year, is equal to the average number of
cycles that DOE used in its
determination of distribution PBPs.
Thus, on average, the rebuttable PBP for
dishwashers is virtually the same as the
average distribution PBP.
For dehumidifiers, the DOE test
procedure does not provide a method
for determining the product’s annual
energy consumption. As a result, the
DOE test procedure does not offer a
basis for determining the rebuttable
PBP. Therefore, for its determination of
rebuttable PBP, DOE decided to use the
same average operational use estimate of
1,095 hours that it used in its
determination of distribution PBPs.
Thus, the rebuttable PBP for
dehumidifiers is virtually the same as
the average distribution PBP.
For cooking products, DOE
determined the rebuttable PBP based on
DOE test-procedure-derived annual
energy consumption values which are,
on average, greater than the annual
energy use that DOE used to determine
the distribution PBPs. Thus, the
rebuttable PBPs for cooking products are
shorter than the distribution PBPs.
Because the distribution PBPs are based
on more recent data that more
accurately reflects the current energy
consumption of cooking products, the
distribution PBPs are more reflective of
actual PBPs than the rebuttable PBPs.
For CCWs, DOE based the annual
energy and water consumption values
that it used to determine the rebuttable
PBP on the number of cycles per year
specified in the DOE test procedure. The
CCW test procedure cites the residential
clothes washer test procedure to
establish efficiency ratings as well as
annual energy and water consumption.
As a result, the annual number of use
cycles, 392 cycles per year, for
determining the annual energy and
water consumption of CCWs, is
representative of residential use, not
commercial use. Because residential use
is significantly lower than the average
usage for commercial applications—
1,241 cycles per year in multi-family
buildings and 2,190 cycles per year in
laundromats—the average annual
energy and water consumption DOE
used to determine rebuttable PBP is
significantly less than the consumption
expected to be associated with actual
usage. As a result, the rebuttable PBP is
significantly longer than the distribution
PBPs for both multi-family and
laundromat applications. To emphasize,
DOE calculated the rebuttable PBPs
based on residential use to comply with
the requirements of EPCA, namely, to
calculate the rebuttable PBP under the
applicable test procedure. DOE
understands that the distribution PBP,
which is based on commercial use,
reflects the actual PBP of CCW.
DOE calculated rebuttable PBPs for
each standard level relative to the
distribution of product efficiencies that
were used for the base case. Section
II.G.2.d of this ANOPR provides details
on the base case efficiency distributions
for each of the four appliance products.
Tables II.50 through II.56 show the
nationally-averaged, rebuttable PBPs
calculated for all product classes and
candidate standard levels for each
considered product.
TABLE II.50.—STANDARD-SIZED DISHWASHERS: REBUTTABLE PAYBACK
PERIODS
Candidate standard
level
PBP
years
EF
Baseline ........................
1 ....................................
2 ....................................
3 ....................................
4 ....................................
5 ....................................
6 ....................................
7 ....................................
0.46
0.58
0.62
0.65
0.68
0.72
0.80
1.11
..............
0.7
2.1
4.6
9.5
17.9
21.8
16.6
TABLE II.51.—DEHUMIDIFIERS: REBUTTABLE PAYBACK PERIODS
0–35.00 pints/day*
Candidate Standard Level
35.01–45.00 pints/day
EF
Baseline ................
1 ............................
2 ............................
3 ............................
4 ............................
5 ............................
PBP years
1.20
1.25
1.30
1.35
1.40
1.45
Level
EF
..................
2.4
1.7
3.0
4.3
5.7
Baseline ................
1 ............................
2 ............................
3 ............................
4 ............................
5 ............................
54.01–74.99 pints/day
PBP years
1.30
1.35
1.40
1.45
1.50
1.74
Level
EF
..................
4.0
5.5
5.8
6.5
8.0
Baseline ................
1 ............................
2 ............................
3 ............................
4 ............................
5 ............................
PBP years
1.50
1.55
1.60
1.65
1.70
1.80
..................
2.3
2.2
2.6
4.7
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
Candidate standard
level
mstockstill on PROD1PC66 with PROPOSALS2
Baseline ................
1 ............................
Electric smooth
PBP
years
EF
0.737
0.769
Level
..................
3.7
Baseline ................
1 ............................
TABLE II.53.
Electric standard
Gas
PBP
years
EF
0.742
0.753
Level
..................
410
Baseline ................
1 ............................
2 ............................
PBP
years
EF
0.156
0.399
0.420
1.3
34
OVENS: REBUTTABLE PAYBACK PERIODS
Electric self-clean
Gas standard
Gas self-clean
Candidate
standard level
EF
PBP
years
Level
EF
PBP
years
Level
EF
PBP
years
Level
EF
PBP
years
Baseline ........
0.1066
............
Baseline ........
0.1099
............
Baseline ........
0.0298
............
Baseline ........
0.0540
............
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TABLE II.53.
Electric standard
Candidate
standard level
1
2
3
4
5
....................
....................
....................
....................
....................
Electric self-clean
PBP
years
EF
0.1113
0.1163
0.1181
0.1206
0.1209
OVENS: REBUTTABLE PAYBACK PERIODS—Continued
2.2
3.3
5.1
24.0
25.2
Gas standard
Level
EF
PBP
years
Level
EF
1 ....................
2 ....................
.......................
.......................
.......................
0.1102
0.1123
............
............
............
88.6
120.2
............
............
............
1* ..................
2 ....................
3 ....................
4 ....................
5 ....................
6 ....................
1a* ................
0.0536
0.0566
0.0572
0.0593
0.0596
0.0600
0.0583
Gas self-clean
PBP
years
4.2
4.8
5.2
20.0
20.3
21.4
1.4
Level
EF
PBP
years
1 ....................
2 ....................
3 ....................
.......................
.......................
.......................
.......................
0.0625
0.0627
0.0632
............
............
............
............
6.5
8.8
9.0
............
............
............
............
* 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 II.54.—MICROWAVE OVENS:
REBUTTABLE PAYBACK PERIODS
Candidate standard level
Baseline ............................
1 ........................................
2 ........................................
3 ........................................
4 ........................................
EF
0.557
0.586
0.588
0.597
0.602
PBP
years
............
18.9
36.8
52.5
73.9
TABLE II.55.—COMMERCIAL CLOTHES
WASHERS, MULTI-FAMILY APPLICATION: REBUTTABLE PAYBACK PERIODS
Candidate standard level
Baseline ............
1 ........................
2 ........................
3 ........................
4 ........................
5 ........................
6 ........................
MEF
1.26
1.42
1.60
1.72
1.80
2.00
2.20
WF
9.50
9.50
8.50
8.00
7.50
5.50
5.10
PBP
years
............
24.0
34.2
25.6
21.2
13.6
9.6
TABLE II.56.—COMMERCIAL CLOTHES
WASHERS, LAUNDROMAT APPLICATION: REBUTTABLE PAYBACK PERIODS
Candidate standard level
mstockstill on PROD1PC66 with PROPOSALS2
Baseline ............
1 ........................
2 ........................
3 ........................
4 ........................
5 ........................
6 ........................
MEF
1.26
1.42
1.60
1.72
1.80
2.00
2.20
WF
9.50
9.50
8.50
8.00
7.50
5.50
5.10
PBP
years
............
29.8
39.1
29.1
24.0
15.0
10.7
Some of the candidate standard levels
appear to satisfy the rebuttable
presumption test, but others do not.
However, PBPs calculated based on
energy consumption in actual field
conditions are generally more accurate
than, and may differ significantly from,
the PBPs calculated under the rebuttable
presumption test, which are based on
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energy consumption under the DOE test
procedure. Therefore, in the LCC and
PBP analyses described in the following
section, DOE evaluated the candidate
standard levels for the considered
products using conditions that reflect
normal use of the equipment.
While DOE has examined the
rebuttable presumption PBPs, DOE does
not expect to determine the economic
justification for any of the standard
levels analyzed based on the ANOPR
rebuttable presumption analysis. DOE’s
decision on standard levels will take
into account the more detailed analysis
of the economic impacts of increased
efficiency pursuant to section
325(o)(2)(B)(i) of EPCA. (42 U.S.C.
6295(o)(2)(B)(i))
G. Life-Cycle Cost and Payback Period
Analyses
The LCC and PBP analyses determine
the economic impact of potential
standards on consumers. The effects of
standards on individual consumers—or
commercial consumers in the case of
CCWs—include changes in operating
expenses (usually lower) and changes in
total installed cost (usually higher). DOE
analyzed the net effect of these changes
for the four appliance products, first, by
calculating the changes in consumers’
LCCs likely to result from candidate
standard levels as compared to a base
case (no new standards). The LCC
calculation considers total installed cost
(which includes manufacturer selling
price, sales taxes, distribution channel
markups, and installation cost),
operating expenses (energy, repair, and
maintenance costs), equipment lifetime,
and discount rate. DOE performed the
LCC analysis from the perspective of the
consumer of each product.
DOE also analyzed the effect of
changes in operating expenses and
installed costs by calculating the PBP of
potential standards relative to a base
case. The PBP estimates the amount of
time it would take the individual or
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commercial consumer to recover the
assumed higher purchase expense of
more energy efficient equipment
through lower operating costs. Similar
to the LCC, the PBP is based on the total
installed cost and the operating
expenses. However, unlike in the LCC,
DOE considers only the first year’s
operating expenses in the calculation of
the PBP. Because the PBP does not
account for changes in operating
expense over time or the time value of
money, it is also referred to as a simple
PBP. DOE utilizes the simple PBP
because of its simplicity, transparency,
and clarity. The simple PBP is a good
approximation of more complex metrics
that are based on operating expenses
that do not change significantly from
year to year. For purposes of capturing
the annual change in operating
expenses, DOE uses the LCC which
accounts for the lifetime operating
expenses of the product. For more detail
on the LCC and PBP analyses, refer to
Chapter 8 of the TSD.
1. Approach
During the Framework workshop,
DOE considered conducting the LCC
and PBP analyses using an approach
that characterized inputs to the analysis
with average values and handling any
uncertainties or variability in the inputs
through the use of scenarios that
analyzed the effect of high and low
values on the results. In recent
standards rulemakings for other
products (e.g., residential furnaces and
boilers and distribution transformers),
DOE conducted the LCC and PBP
analyses by modeling both the
uncertainty and variability in the inputs
using Monte Carlo simulation and
probability distributions. Although
more extensive than the aforementioned
approach based on the use of average
inputs, the Monte Carlo approach
provides additional information,
specifically the percentage of consumers
benefiting from and being burdened by
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a prospective standard. The Joint
Comment supported DOE’s retention of
Monte Carlo-based LCC and PBP
analyses for this rulemaking, as long as
the additional work required to perform
the analyses over a simpler approach is
not extensive. The Joint Comment stated
that the Monte Carlo approach provides
useful information on the percentage of
consumers benefiting from and being
burdened by an efficiency standard.
(Joint Comment, No. 9 at p. 3) EEI and
NWPCC also urged DOE to retain the
Monte Carlo approach due to the
additional information it provides over
a simpler analysis. (EEI, No. 7 at p. 5;
Public Meeting Transcription, No. 5 at
p. 228) DOE agrees with the comments
that the benefits of conducting the LCC
and PBP with a Monte Carlo approach
outweigh the extra effort it takes to
implement it. Therefore, DOE developed
its LCC and PBP spreadsheet models
incorporating both Monte Carlo
simulation and probability distributions
by using Microsoft Excel spreadsheets
combined with Crystal Ball (a
commercially available add-in program).
In addition to characterizing several
of the inputs to the analysis with
probability distributions, in the case of
residential dishwashers, dehumidifiers,
and cooking products, DOE also
developed a sample of individual
households that use each of the
appliances. The household sample sizes
for these residential products are: 2,476
household records from dishwashers;
578 for dehumidifiers; 2,895 for electric
cooktops; 1,159 for electric standard
ovens; 1,601 for electric self-cleaning
ovens; 1,597 for gas cooktops; 959 for
gas standard ovens; and 494 for gas selfcleaning ovens. By developing
household samples, DOE was able to
perform the LCC and PBP calculations
for each household to account for the
variability in energy (and water)
consumption and/or energy price
associated with each household. DOE
used EIA’s 2001 RECS to develop
household samples for each of the above
three sets of products. The 2001 RECS
is a national sample survey of housing
units that collects statistical information
on the consumption of and expenditures
for energy in housing units along with
data on energy-related characteristics of
the housing units and occupants. The
2001 RECS consists of for 4,822 housing
units and was constructed by EIA to be
a national representation of the
household population in the U.S. Of the
household sub-samples used in the LCC
and PBP analysis, only two (for
dehumidifiers and gas self-cleaning
ovens) have a size which is less than 20
percent of the total 2001 RECS housing
unit size. Even so, the potential errors
associated with these smaller subsample sizes are not anticipated to be so
large as to affect the validity of the
results. Specifically, the standard error
of a sample of size ’n’ is the sample’s
standard deviation divided by the
square root of ’n’. For the full 2001
RECS sample the associated standard
error is the sample’s standard deviation
multiplied by 1.5 percent. For the
dehumidifier and gas self-cleaning oven
sub-samples, the associated standard
error is the sub-sample’s standard
deviation multiplied by 4.5 percent.
Although the standard error of the subsamples is three times the size of the
entire 2001 RECS, it is still less than five
percent. DOE believes a standard error
of less than five percent is still small
enough to yield meaningful results.
Therefore, DOE believes the results
generated from the household samples
for dishwashers, dehumidifiers, and
cooking products are representative of
U.S. households using these appliances.
For dishwashers and cooking
products, DOE used EIA’s 2001 RECS to
establish the variability in annual
energy use and energy pricing. (DOE
also established the variability of annual
water use and water pricing for
dishwashers using the 2001 RECS.)
Note, as discussed previously in section
II.D on the energy and water use of the
four appliance products, DOE
characterized the average energy use of
dishwashers and cooking products on
relatively recent studies (for
dishwashers, a 2001 study performed by
ADL, and for cooking products, studies
from the 2004 CA RASS and the FSEC).
Therefore, to emphasize, DOE used
RECS to establish the variability in
annual energy use of dishwashers and
cooking products, not the average
consumption. For dehumidifiers, DOE
used RECS to establish only the
variability in electricity pricing. By
using RECS, DOE was able to assign a
unique annual energy use and/or energy
price to each household in the sample.
Due to the large sample of households
considered in the LCC and PBP
analyses, the range of annual energy use
and/or energy prices is quite large.
Thus, although the annual energy use
and/or energy pricing are not uncertain
for any particular household, their
variability across all households
contributes to the range of LCCs and
PBPs calculated for any particular
candidate standard level.
For CCWs, DOE was unable to
develop a consumer sample, since
neither RECS nor EIA’s Commercial
Building Energy Consumption Survey
(CBECS) provide the necessary data to
develop one. As a result, DOE was not
able to use a consumer sample to
establish the variability in energy use
(and water use) and energy pricing (and
water pricing) for CCWs. Instead, DOE
established the variability and
uncertainty in energy and water use for
CCWs by defining the uncertainty and
variability in the use (cycles per day) of
the equipment. The variability and
uncertainty in energy and water pricing
are characterized by regional differences
in energy and water prices.
2. Life-Cycle Cost Inputs
For each efficiency level analyzed, the
LCC analysis requires input data for the
total installed cost of the equipment, the
operating cost, and the discount rate.
Table II.57 summarizes the inputs and
key assumptions DOE used to calculate
the customer economic impacts of
various candidate standard levels for
each product. A more detailed
discussion of the inputs follows.
TABLE II.57.—SUMMARY OF INPUTS AND KEY ASSUMPTIONS USED IN THE LIFE-CYCLE COST ANALYSES
Description
Baseline Manufacturer Cost ...........
mstockstill on PROD1PC66 with PROPOSALS2
Input
The baseline manufacturer cost is the cost incurred by the manufacturer to produce equipment meeting
existing minimum efficiency standards.
Standard-level manufacturer cost increases are the incremental change in manufacturer cost associated
with producing equipment at a standard level.
Markups and sales tax convert the manufacturer cost to a consumer equipment price.
The installation cost is the cost to the consumer of installing the equipment and represents all costs required to install the equipment other than the marked-up consumer equipment price. The installation cost
includes labor, overhead, and any miscellaneous materials and parts.
Standard-Level Manufacturer Cost
Increases.
Markups and Sales Tax ..................
Installation Cost ..............................
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64483
TABLE II.57.—SUMMARY OF INPUTS AND KEY ASSUMPTIONS USED IN THE LIFE-CYCLE COST ANALYSES—Continued
Input
Description
Annual Energy (and Water) Consumption.
The annual energy consumption is the site energy use associated with operating the equipment. The annual 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 efficiency.
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 costs are associated with repairing or replacing components that have failed. Maintenance costs
are associated with maintaining the operation of the equipment.
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.
The product lifetime is the age at which the equipment is retired from service.
The discount rate is the rate at which DOE discounts future expenditures to establish their present value.
Energy and Water Prices ................
Repair and Maintenance Costs ......
Energy and Water Price Trends .....
mstockstill on PROD1PC66 with PROPOSALS2
Product Lifetime ..............................
Discount Rate .................................
a. Total Installed Cost Inputs
The inputs to calculate total installed
cost are as follows. ‘‘Baseline
manufacturer cost’’ is the cost incurred
by the manufacturer to produce
equipment meeting existing minimum
efficiency standards. ‘‘Standard-level
manufacturer cost increases’’ are the
change in manufacturer cost associated
with producing equipment to meet a
particular energy efficiency level (i.e.,
the incremental cost). Markups and
sales tax convert the manufacturer cost
to a consumer equipment price. The
installation cost is the cost to the
consumer of installing the equipment
and represents all costs required to
install the equipment other than the
marked-up consumer equipment price.
Thus, the total installed cost equals the
consumer equipment price plus the
installation cost. For a complete
discussion on manufacturer costs refer
back to section II.C in this ANOPR. For
details on markups and sales taxes, refer
back to section II.E in this ANOPR.
More specifically, installation costs
include labor, overhead, and any
miscellaneous materials and parts. DOE
determined installation costs for
dishwashers, cooktops and ovens, and
CCWs based on data in the RS Means
Plumbing Cost Data, 2005.38 RS Means
provides estimates on the labor required
to install each of above three products.
For dishwashers, DOE based its
installation cost for baseline equipment
on the nationally representative average
cost associated with the installation of
a four-or-more-cycle dishwasher as
provided by RS Means. In addition,
DOE determined that installation costs
would not be impacted by increased
standard levels. In reference to a design
requiring a reduction in the inlet water
temperature, Whirlpool stated that
because it would require a cold water
38 RS Means. Plumbing Cost Data, 28th Edition,
2005. Kingston, MA. p. 97. Available online for
purchase at: https://www.remeans.com/.
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line to be plumbed to the dishwasher in
addition to the hot water line, this
design would incur greater installation
costs than a baseline dishwasher.
(Public Meeting Transcript, No. 5 at p.
204) DOE agrees with Whirlpool, but in
its development of the manufacturing
cost-versus-efficiency relationship, DOE
did not believe that any of the standard
levels would require a reduction in inlet
water temperature. Thus, DOE did not
alter its decision to keep the installation
cost constant for more efficient designs.
For cooktops and ovens, DOE based
its installation cost for baseline
equipment on the nationally
representative average cost associated
with the installation of 30-inch, freestanding cooking ranges as provided by
RS Means. DOE estimated that the costs
of installing a range are also
representative of the costs of installing
either a cooktop or an oven. However,
Whirlpool suggested that DOE should
assess whether more efficient cooking
products incur increased installation
costs. (Whirlpool, No. 10 at p. 10) As a
basis for assessing whether installation
costs vary with product efficiency, DOE
used its own supplemental analysis to
the previous rulemaking’s TSD. In the
supplemental analysis, DOE determined
that only gas cooktops and ovens with
electronic ignition devices would incur
added installation costs.39 Because DOE
did not receive any information to the
contrary, DOE retained this
determination for its current analysis.
For gas cooktops and ovens, the
previous analysis estimated, as an upper
bound, that 20 percent of households
using gas cooktops and ovens that do
not require electricity to operate would
39 U.S. Department of Energy. Technical Support
Document Energy Conservation Standards for
Consumer Products Cooking Products,
Supplemental Chapter 4—Life Cycle Cost and
Payback Periods, Washington, DC. Available online
at: https://www.eere.energy.gov/buildings/
appliance_standards/residential/cooking_
products_0998_r.html.
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require the installation of an electrical
outlet in the kitchen to bring electrical
service to the product. DOE used data
from RS Means to estimate the
installation cost of an electrical outlet.
For CCWs, GE stated that because
CCWs are more difficult to install than
typical residential clothes washers, the
installation costs associated with
residential washers should not be used
as a basis for establishing CCW
installation costs. (Public Meeting
Transcript, No. 5 at p. 46) DOE agrees
with GE and based its installation cost
for baseline equipment on the nationally
representative average costs associated
with the installation of a four-cycle,
coin operating CCW as provided by RS
Means. DOE determined that
installation costs would not be impacted
by increased standard levels because
none of the CCWs currently on the
market differ from each other in terms
of installation requirements despite
existing variations in their level of
efficiency. All CCW have similar
connections for electrical power,
incoming water, and drains. In addition
to these basic connections, CCW may
require some additional cabling for
vending systems and monitoring.
However, neither vending systems nor
system monitoring enhances CCW
energy efficiency.
Lastly, for dehumidifiers and
microwave ovens, DOE determined that
there are no costs associated with the
installation of these products as a
function of energy efficiency. Both types
of products only require an available
outlet to begin operating. Some
dehumidifiers may require some
additional work to allow condensate to
drain directly into a drain. However,
this product functionality is not related
to energy efficiency—it simply relieves
the user from having to drain the
condensate bucket from time to time.
Additional details on the
development of installation costs can be
found in Chapter 8 of the TSD.
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b. Operating Cost Inputs
The operating cost inputs are as
follows. Annual energy consumption is
the site energy use associated with
operating an appliance product. Annual
water consumption, which is applicable
to dishwashers and CCWs, is the site
water use associated with operating an
appliance product. Energy and water
prices are the prices paid by consumers
for energy (i.e., electricity, gas, or oil)
and water. DOE used energy and water
price trends to forecast energy and water
prices into the future. Multiplying the
annual energy and water consumption
by the energy and water prices yields
the annual energy cost and water cost,
respectively. Repair costs are associated
with repairing or replacing components
that have failed. Maintenance costs are
associated with maintaining the
operation of the equipment. The
product lifetime is the age at which the
equipment is retired from service. The
discount rate is the rate at which DOE
discounted future expenditures to
establish their present value. The inputs
for estimating annual energy (and water)
consumption are discussed in section
II.D.
With regard to energy prices, DOE
derived average prices for 13 geographic
areas consisting of the nine U.S. Census
divisions, with four large States (New
York, Florida, Texas, and California)
treated separately. For Census divisions
containing one of these large States,
DOE calculated the regional average
values leaving out data for the large
State—for example, the Pacific region
average does not include California, and
the West South Central does not include
Texas. EEI stated that DOE should use
commercial energy prices to conduct the
LCC and PBP analyses of CCWs and
residential prices to conduct the
analyses for the residential products.
(EEI, No. 7 at p. 4) DOE agreed with
EEI’s suggestion, and as described
below, DOE developed residential
energy prices for its analysis of
dishwashers, dehumidifiers, and
cooking products, and commercial
energy prices for CCWs.
With regard to water prices, DOE
derived average prices for the four
Census regions. As described below,
DOE used survey data survey covering
approximately 300 water utilities and
200 wastewater utilities to develop
water and wastewater prices. Because a
sample of 200–300 utilities is not large
enough to calculate regional prices for
all U.S. Census divisions and large
States (for comparison, DOE used
electricity price data form more than
3000 utilities), DOE calculated regional
values at the Census region level
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(Northeast, South, Midwest, and West).
Using these energy and water price data,
DOE analyzed their variability at the
regional level for each of the four
appliance products.
For the three residential products (i.e.,
dishwashers, dehumidifiers, and
cooking products), DOE used 2001
RECS data to develop a sample of
individual households that use each of
the appliances. By developing
household samples, DOE was able to
perform the LCC and PBP calculations
for each household to account for the
regional variability in energy and water
prices associated with each household.
Because households use either electric,
gas, or oil water heaters, DOE had to
develop residential electricity, natural
gas, and oil prices for its analysis of
dishwashers. For dehumidifiers, DOE
used only residential electricity prices
because this product runs strictly using
electricity. Since cooking products
consist of electric and gas equipment,
DOE had to use both residential
electricity and natural gas prices in its
analysis.
For CCWs, DOE was unable to
develop a consumer sample, since
neither RECS nor EIA’s CBECS provide
the necessary data to develop one. Thus,
DOE characterized energy and water
price regional variability with
probability distributions. It based the
probability associated with each
regional energy and water price on the
population weight of each region.
Because commercial laundry
establishments use either electric or gas
water heaters and dryers, DOE
developed both commercial electricity
and natural gas prices for its analysis of
CCWs.
DOE estimated residential and
commercial electricity prices for each of
the 13 geographic areas based on data
from EIA Form 861, Annual Electric
Power Industry Report. These data are
published annually and include annual
electricity sales in kWh, revenues from
electricity sales, and number of
consumers, for the residential,
commercial, and industrial sectors, for
every utility serving final consumers.
DOE calculated an average residential
electricity price by first estimating an
average residential price for each
utility—by dividing the residential
revenues by residential sales—and then
calculating a regional average price by
weighting each utility with customers in
a region by the number of residential
consumers served in that region. The
calculation methodology uses recently
available EIA data from 2004. The
calculation methodology of an average
commercial electricity price is identical
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to that for residential price, except that
DOE used commercial sector data.
DOE estimated residential and
commercial natural gas prices in each of
the 13 geographic areas based on data
from the EIA publication Natural Gas
Monthly.40 This publication includes a
compilation of monthly natural gas
delivery volumes and average consumer
prices by State, for residential,
commercial, and industrial customers.
Specifically, DOE used the complete
annual data for 2005 to calculate an
average summer and winter price for
each area. It calculated seasonal prices
because, for some end uses, seasonal
variation in energy consumption is
significant. DOE defined summer as the
months May through September, with
all other months defined as winter. DOE
calculated an average natural gas price
by first calculating the summer and
winter prices for each State, using a
simple average over the appropriate
months, and then calculating a regional
price by weighting each State in a region
by its population. This method differs
from the method used to calculate
electricity prices, because EIA does not
provide consumer-level or utility-level
data on gas consumption and prices.
The calculation methodology of an
average commercial natural gas price is
identical to that for residential price,
except that DOE used commercial sector
data.
DOE estimated residential oil prices
in each of the 13 geographic areas based
on data from EIA’s Petroleum
Navigator.41 From this Web site,
available data include a compilation of
monthly oil delivery volumes and
average consumer prices by State, for
residential, commercial, and industrial
customers. Specifically, DOE used the
complete annual data for 2005 to
calculate an average oil price. It first
calculated the prices for each State
using simple averages and then
calculated a regional price, weighting
each State in a region by its population.
DOE obtained residential water and
wastewater price data from the 2004
Water and Wastewater Rate Survey
conducted by Raftelis Financial
Consultants and the American Water
Works Association.42 The survey covers
approximately 300 water utilities and
40 DOE-Energy Information Administration,
Natural Gas Monthly, available online at: https://
www.eia.doe.gov/oil_gas/natural_gas/
data_publications/natural_gas_monthly/ngm.htm.
41 DOE Energy Information Administration,
Petroleum Navigator, available online at: https://
tonto.eia.doe.gov/dnav/pet/pet_pri_top.asp.
42 Raftelis Financial Consultants, Inc. 2004 RFC/
AWWA Water and Wastewater Rate Survey, 2004.
Charlotte, NC, Kansas City, MO, and Pasadena, CA.
Available online at: https://www.raftelis.com/
ratessurvey.html.
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200 wastewater utilities, with each
industry analyzed separately. The water
survey includes, for each utility, the
cost to consumers of purchasing a given
volume of water. In this case, the data
include a division of the total consumer
cost into fixed and volumetric charges.
Pacific Gas & Electric Company (PG&E)
suggested that DOE determine the
marginal price of water and wastewater
for its analysis. PG&E claimed that the
marginal cost of improving wastewater
treatment plants to comply with State
and Federal regulations is very high.
Because higher marginal costs translate
into higher marginal prices, PG&E states
that the marginal price would be a more
accurate representation of the economic
savings due to reduced water
consumption. (Public Meeting
Transcript, No. 5 at p. 190) As PG&E
suggested, DOE calculated only the
volumetric charge to determine water
prices, since only this charge would be
affected by a change in water
consumption. Including the fixed charge
in the average water price would lead to
a slightly higher water price. For
wastewater utilities, the format is
similar, but the cost refers to the cost of
treating a given volume of wastewater.
EEI stated that price of water and
wastewater is highly variable depending
on consumer use or volume and
geographic location. (Public Meeting
Transcript, No. 5 at p. 192) DOE agrees
with EEI in determining regional water
and wastewater prices. However, a
sample of 200–300 utilities is not large
enough to calculate regional prices for
all U.S. Census divisions and large
States (for comparison, the EIA Form
861 data include more than 3,000
utilities). For this reason, DOE
calculated regional values at the Censusregion level (Northeast, South, Midwest,
and West). DOE calculated average perunit-volume prices by first calculating
the per-unit-volume price for each
utility by dividing the total volumetric
cost by the volume delivered, then
calculating a State-level average price by
weighting each utility in a given State
by the number of consumers it serves
(either residential or commercial), and
finally arriving at a regional average by
combining the State-level averages,
weighting each by the population of that
State. This third step helps reduce any
bias in the sample that may occur due
to relative under-sampling of large
States.
For further details of the methodology
that DOE used for deriving energy and
water prices, see Chapter 8 of the TSD.
In terms of trends, DOE used price
forecasts by the EIA to estimate the
trends in natural gas, oil, and electricity
prices. The Joint Comment stated that
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current EIA energy price forecasts are
too low and will likely be revised
upwards over the next few years. The
Joint Comment requested that DOE use
the latest available price forecasts from
EIA to conduct their analyses. (Joint
Comment, No. 9 at p. 2) To estimate
future energy prices, DOE used EIA’s
Annual Energy Outlook (AEO) 2007,
containing the latest available price
forecasts from EIA.43 To arrive at prices
in future years, DOE multiplied the
average prices described in the
preceding section by the forecast of
annual average price changes in AEO
2007. Because AEO 2007 forecasts
prices to 2030, DOE followed past
guidelines provided to the Federal
Energy Management Program (FEMP) by
EIA and used the average rate of change
during 2020–2030 for electricity and the
average rate of change during 2015–
2020 for natural gas and oil to estimate
the price trends after 2030. More recent
guidelines to FEMP suggest that a 10year rather than a 15-year historical time
period be used to extrapolate natural gas
and oil prices. DOE intends to use the
more recent guidelines to extrapolate
gas and oil prices for the NOPR. For the
analyses to be conducted for the NOPR
and Final Rule, DOE intends to update
its energy price forecasts at those stages
of the rulemaking based on the latest
available AEO.
NWPCC commented that energy rate
caps will be coming off in the next few
years for many States in the U.S. and
asked whether EIA’s energy price
forecasts take this into account. (Public
Meeting Transcript, No. 5 at p. 193) In
response, we note that EIA conducts an
annual review of changes in energy
prices by supply region and State in
developing its AEO. In estimating future
energy prices, EIA determines which
regions of the country are regulated (i.e.,
with rate caps) and which are
competitive or will become competitive
soon (i.e., without rate caps). In past
AEOs, EIA assumed that prices in fully
competitive regions would reflect spot
market prices and would be passed on
to consumers immediately. EIA expects
that the end of price reductions and
caps in many States will push
competitive regions closer to that
representation of competition; however,
EIA anticipates that most customers in
fully competitive regions will not
experience price changes immediately
in response to changes in market
generation costs. Consequently, for AEO
2007, EIA built lags into the calculation
43 U.S. Department of Energy-Energy Information
Administration. Annual Energy Outlook 2007 with
Projections to 2030, February, 2007. Washington,
DC. DOE/EIA–0383 (2007).
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64485
of competitive energy prices to simulate
the delay from the time suppliers
experience cost changes to the time
consumers experience price changes as
a result of the length of fixed-price
contracts for standard-offer service (i.e.,
rates typically provided by regulated
utilities) and competitive retail service.
National Consumer Law Council
(NCLC) asked how DOE will account for
the variability in future electricity prices
in the analyses. (Public Meeting
Transcript, No. 5 at p. 188) In response,
we note that DOE addressed future
variability in electricity prices by
incorporating three separate projections
from AEO 2007 into the spreadsheet
models for calculating LCC and PBP: (1)
Reference Case; (2) Low Economic
Growth Case; and (3) High Economic
Growth Case. These three cases reflect
the uncertainty of economic growth in
the forecast period. The high and low
growth cases show the projected effects
of alternative growth assumptions on
energy markets.
To estimate the future trend for water
and wastewater prices, DOE used data
on the historic trend in the national
water price index (U.S. city average)
from 1970 through 2005 provided by the
Bureau of Labor Statistics. DOE
extrapolated a future trend based on the
linear growth over the 1970–2005 time
period.
For further details on DOE’s method
for forecasting energy and water prices,
see Chapter 8 of the TSD.
With respect to repair and
maintenance costs, DOE assumed that
small, incremental changes in products
related to efficiency result in either no
or only very small changes in repair and
maintenance costs, as compared to
baseline products. DOE acknowledges
there is a greater probability that
equipment with efficiencies that are
significantly greater than the baseline
will incur some level of increased repair
and maintenance costs because such
equipment is more likely to incorporate
technologies that are not widely
available.
On this point, Whirlpool stated that,
in general, more-efficient products use
more sophisticated components and
controls, thereby increasing repair and
maintenance costs. (Whirlpool, No. 10
at p. 10) Whirlpool also stated, in regard
to cooking products, that repair and
maintenance costs for more-efficient
products will be higher than these types
of costs for current baseline products.
For example, Whirlpool cited two
design options—bi-radiant ovens and
electronic controls—as technologies that
would incur higher repair and
maintenance costs. Whirlpool suggested
that DOE should obtain data on repair
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and maintenance costs during the
course of its data collection for the
engineering analysis (similar comment
provided by AHAM). (Whirlpool, No. 10
at p. 10; Public Meeting Transcript, No.
5 at pp. 199–200; AHAM, No. 14 at p.
5) With respect to CCWs, ALS stated
that repair and maintenance costs for
front-loading washers are much higher
than for top-loading washers. (Public
Meeting Transcript, No. 5 at p. 201)
DOE requested that manufacturers and
other stakeholders provide information
regarding appropriate repair and
maintenance costs if stakeholders
believe such estimates are necessary.
However, DOE did not receive any
input, and, therefore, did not include
any changes in repair and maintenance
costs for products more efficient than
baseline products in this ANOPR.
DOE specifically seeks feedback on its
assumption that increases in product
energy efficiency would not have a
significant impact on the repair and
maintenance costs for the four appliance
products covered by this rulemaking.
This is identified as Issue 11 under
‘‘Issues on Which DOE Seeks Comment’’
in section IV.E of this ANOPR.
With regard to appliance product
lifetimes, DOE received several
comments on the appropriate sources
for establishing their length. For
dishwashers, ACEEE stated that some
sources indicate that dishwasher
lifetime is 14 years, while Whirlpool
commented that Appliance Magazine’s
estimate of nine years for dishwasher
lifetime is reasonable and the most
representative of actual consumer
behavior. (Public Meeting Transcript,
No. 5 at p. 206; Whirlpool, No. 10 at p
10) For dehumidifiers, the Joint
Comment estimated a product lifetime
of 15 years based on discussions with
manufacturers and other sources. The
Joint Comment stated that Appliance
Magazine generally provides shorter
lifetimes as compared to other sources.
In contrast, Whirlpool commented that
Appliance Magazine’s estimate of eight
years for dehumidifier lifetime is
reasonable and the most consistent with
actual consumer behavior. (Joint
Comment, No. 9 at p. 5; Whirlpool, No.
10 at p 10) For cooking products, both
AHAM and Whirlpool stated that the
best source for cooking product
lifetimes is Appliance Magazine, as they
believe it provides estimated lifetimes
which are consistent with actual
consumer behavior. (AHAM, No. 14 at
p. 5; Whirlpool, No. 10 at p. 10) Finally,
for CCWs, ALS stated that because
CCWs are typically used more often
than residential clothes washers, CCW
lifetime will be significantly shorter
than the lifetime of residential
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machines. It suggested that the best
sources for CCW product lifetime data
are the MLA and route operators.
(Public Meeting Transcript, No. 5 at p.
206)
To estimate the lifetime for each
product covered by this rulemaking,
DOE used only primary sources of data.
For example, the Federal government’s
Energy Star Web site 44 provides lifetime
estimates for dishwashers and
dehumidifiers, but the estimates are
actually based on data from Appliance
Magazine. Because, in this case,
Appliance Magazine is the primary
source of data, DOE did not use the
Energy Star Web site as a primary
source to estimate product lifetimes.
DOE used a variety of sources to
establish the lifetime of each of the
considered products, including
Appliance Magazine. Using the primary
sources of data, DOE characterized
product lifetimes with uniform
probability distributions ranging from a
minimum to a maximum value.
Microwave ovens were the exception,
since DOE used a triangular probability
distribution for these products instead.
DOE determined the average product
lifetime by calculating the average value
from the applicable primary sources of
data. To establish the minimum and
maximum product lifetime, DOE
generally used the high and low values
from these sources for each of the four
appliance products. See Chapter 8 of the
TSD for more details.
To establish discount rates for the
residential products (i.e., dishwashers,
dehumidifiers, and cooking products),
DOE derived estimates of the finance
cost of purchasing the considered
products. Following financial theory,
the finance cost of raising funds to
purchase appliances can be interpreted
as: (1) The financial cost of any debt
incurred to purchase equipment, or (2)
the opportunity cost of any equity used
to purchase equipment. For the
residential products, the purchase of
equipment for new homes entails
different finance costs for consumers
than the purchase of replacement
equipment. Thus, DOE used different
discount rates for new construction and
replacement installations. NCLC
questioned how DOE would evaluate
the cost of household equity and debt to
develop discount rates for residential
products. (Public Meeting Transcript,
No. 5 at p. 196) As described below,
DOE used the Federal Reserve Board’s
Survey of Consumer Finances (SCF) for
the years 1989, 1992, 1995, 1998, 2001,
and 2004 as the basis for using
44 Energy Star Web site: https://
www.energystar.gov/.
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household equity and debt to calculate
discount rates for residential products.45
The SCF defines the shares of various
equity and debt classes held by U.S.
households, thereby allowing DOE to
properly weight the equity and debt
holdings to derive residential discount
rates. EEI commented that because
interest rates have been rising since
2003, making the cost of capital higher
for residential and commercial
consumers, DOE should take into
account the most recent financial data
when developing discount rates. (EEI,
No. 7 at p. 4) As described below, DOE
used the most recent data available,
including data from the SCF to establish
appropriate residential discount rates,
and data from Damodaran Online to
establish commercial discount rates.46
New equipment is often purchased as
part of the purchase of a home, which
is almost always financed with a
mortgage loan. DOE estimated discount
rates for new-housing equipment using
the effective real (after-inflation)
mortgage rate for homebuyers. This rate
corresponds to the interest rate after
deduction of mortgage interest for
income tax purposes and after adjusting
for inflation. The data sources DOE used
for mortgage interest rates are the SCFs
in 1989, 1992, 1995, 1998, 2001, and
2004. After adjusting for inflation and
interest tax deduction, effective real
interest rates on mortgages across the six
surveys averaged 3.2 percent.
For residential replacement
equipment, DOE’s approach for deriving
discount rate involved identifying all
possible debt or asset classes that might
be used to purchase replacement
equipment, including household assets
that might be affected indirectly. DOE
did not include debt from primary
mortgages and equity of assets
considered non-liquid (such as
retirement accounts), since these would
likely not be affected by replacement
equipment purchases. DOE estimated
the average shares of the various debt
and equity classes in the average U.S.
household equity and debt portfolios
using SCF data for 1989, 1992, 1995,
1998, 2001, and 2004. DOE used the
mean share of each class across the six
sample years as a basis for estimating
the effective financing rate for
replacement equipment. DOE estimated
45 The Federal Reserve Board. 1989, 1992, 1995,
1998, 2001, 2004 Survey of Consumer Finances,
1989, 1992, 1995, 1998, 2001, 2004. Available
online at: https://www.federalreserve.gov/pubs/oss/
oss2/scfindex.html.
46 Damodaran Online is a widely used source of
information about company debt and equity
financing for most types of firms, and was the
source of data for this analysis on educational
services, hotels, and real estate investment trusts.
See https://pages.stern.nyu.edu/adamodar/.
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interest or return rates associated with
each type of equity and debt using SCF
data and other sources. The mean real
effective rate across all types of
household debt and equity, weighted by
the shares of each class, is 5.6 percent.
For CCWs, DOE derived the discount
rate from the cost of capital of publiclytraded firms in the sectors that purchase
CCWs. These companies typically
finance equipment purchases through
debt and equity capital. DOE estimated
the cost of capital of these firms as the
weighted average of the cost of equity
financing and the cost of debt financing.
The costs of debt and equity financing
are usually obtainable from publicly
available data concerning the major
types of companies in the sectors that
purchase CCWs. Damodaran Online is a
widely used source of information about
company debt and equity financing for
most types of firms, and it was the
source of data for this analysis on
educational services, hotels, and real
estate investment trusts. Since
Damodaran Online does not include
data for firms in the personal services
sector (Standard Industrial
Classification 7200), DOE used data
from Ibbotson’s Associates 47 for this
sector.
DOE estimated the cost of equity
using the capital asset pricing model
(CAPM). The CAPM assumes that the
cost of equity for a particular company
is proportional to the systematic risk
faced by that company, where high risk
is associated with a high cost of equity
and low risk is associated with a low
cost of equity. The systematic risk facing
a firm is determined by several
variables: (1) The risk coefficient of the
firm; (2) the expected return on risk-free
assets; and (3) the equity risk premium
(ERP). The risk coefficient of the firm
indicates the risk associated with that
firm relative to the price variability in
the stock market. The expected return
on risk-free assets is defined by the
yield on long-term government bonds.
The ERP represents the difference
between the expected stock market
return and the risk-free rate.
The cost of debt financing is the
interest rate paid on money borrowed by
a company. The cost of debt is estimated
by adding a risk adjustment factor to the
risk-free rate. This risk adjustment factor
depends on the variability of stock
returns represented by standard
deviations in stock prices.
DOE estimated the weighted-average
cost of capital (WACC) using the
47 Ibbotson Associates is a leading authority on
asset allocation with expertise in capital market
expectations and portfolio implementation. See
Ibbotson’s Associates Statistics for SIC 72, available
online at: https://www.ibbotson.com
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respective shares of equity and debt
financing for each of the sectors that
purchase CCWs. It calculated the real
WACC by adjusting the cost of capital
by the expected rate of inflation. To
obtain an average discount rate value,
DOE used additional data from the CEE
on the number of CCWs in use in
various sectors. Weighting each sector
by its market share, DOE estimated the
average discount rate for companies that
purchase CCWs to be 5.7 percent, using
an inflation rate of 2.5 percent (the
average of inflation rates over the 2001–
2005 time period). For further details on
DOE’s method for estimating discount
rates, see Chapter 8 of the TSD.
One additional issue pertaining to the
LCC operating cost inputs concerns the
potential ‘‘split incentives’’ that exist in
the CCW market. Several organizations
commented that under a split incentive
situation, the party purchasing moreefficient and more-expensive equipment
may not realize the operating cost
savings from the more-efficient
equipment. For example, commenters
asserted that under new energy
efficiency standards, route operators
would incur the burden of higher
purchase prices due to more-efficient
equipment; property owners would
realize the benefits of operating cost
savings, and end-users may incur the
burden of increased costs to use the
washers. (Public Meeting Transcript,
No. 5 at p. 239; EEI, No. 7 at p. 4; MLA,
No. 8 at p. 2; Whirlpool, No. 10 at p. 13;
Multiple Water Organizations, No. 11 at
p. 2) In its LCC and PBP analyses, DOE
did not explicitly consider the potential
of split incentives in the CCW market,
because it believes that the probability
of such a split incentive was very low.
The actual consumers of this product
(primarily property-owners of multifamily buildings and laundromats)
realize both the burden of increased
purchase prices and the benefit of
reduced operating cost savings. Any
split incentive that would occur for endusers in the form of increased vending
prices is likely to be very low due to the
competitive nature of the market. For
example, if end-users feel as though
they are paying excessively high prices
to use a service, they will seek out
cheaper options to obtain the service,
thereby forcing providers to adjust their
prices in accordance with what is a
reasonable return on their investment.
Due to the checks and balances that
occur in the marketplace, DOE believes
it is unnecessary to explicitly account
for the possible inequities to end-users
that may arise from a split incentive.
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64487
c. Effective Date
The effective date is the future date
when a new standard becomes effective.
Based on DOE’s implementation report
for energy conservation standards
activities submitted under Section 141
of EPACT 2005, a final rule for the four
appliance products being considered for
this standards rulemaking is scheduled
for completion in March 2009. The
effective date of any new energy
efficiency standards for these products
will be three years after the final rule is
published in the Federal Register (i.e.,
March 2012). DOE calculated the LCC
for all consumers as if they each would
purchase a new piece of equipment in
the year the standard takes effect.
d. Equipment Assignment for the Base
Case
For purposes of conducting the LCC
analysis, DOE analyzed candidate
standard levels relative to a baseline
efficiency level. However, some
consumers already purchase products
with efficiencies greater than the
baseline levels. Thus, to accurately
estimate the percentage of consumers
that would be affected by a particular
standard level, DOE took into account
the distribution of product efficiencies
currently in the marketplace. In other
words, DOE conducted the analysis by
taking into account the full breadth of
product efficiencies that consumers
already purchase under the base case
(i.e., the case without new energy
efficiency standards).
DOE’s approach for conducting the
LCC analysis for residential products
(i.e., dishwashers, dehumidifiers,
cooking products) relied on developing
samples of households that use each of
the products. DOE used a Monte Carlo
simulation technique to perform the
LCC calculations on the households in
the sample. Using the current
distribution of product efficiencies, DOE
assigned each household in the sample
a specific product efficiency. Because it
performed the LCC calculations on a
household-by-household basis, DOE
based the LCC for a particular standard
level on the efficiency of the product in
the given household. For example, if a
household was assigned a product
efficiency that is greater than or equal to
the efficiency of the standard level
under consideration, the LCC
calculation would reveal that this
household is not impacted by an
increase in product efficiency that is
equal to the standard level.
For dishwashers, DOE characterized
base case market shares based on data
that AHAM provided that show the
distribution of standard-sized
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Federal Register / Vol. 72, No. 220 / Thursday, November 15, 2007 / Proposed Rules
dishwasher efficiencies sold in 2005.
Table II.58 presents the market shares of
the candidate standard levels in the base
case for standard-sized dishwashers.
The market shares in Table II.58
represent the products that households
would have been anticipated to
purchase in the year 2012 in the absence
of new standards.
TABLE II.58.—STANDARD-SIZED DISHWASHERS: BASE CASE MARKET
SHARES
Candidate standard
level
Baseline ................
* ............................
* ............................
1 ............................
* ............................
2 ............................
3 ............................
4 ............................
Market
share
(percent)
EF
0.46
0.50
0.54
0.58
0.60
0.62
0.65
0.68
3.0
2.0
2.0
43.0
17.0
22.0
8.0
2.5
TABLE II.58.—STANDARD-SIZED DISH- class. Without any data provided by
WASHERS: BASE CASE MARKET either AHAM or manufacturers or
available from other sources, DOE
SHARES—Continued
assumed that the market shares for the
combined 0–35.00 pints/day class were
Candidate standard
EF
equivalent to the market shares for the
level
closest product class—the 35.01–45.00
5 ............................
0.72
0.2 pint/day product class. For purposes of
6 ............................
0.80
0.2 conducting the NIA, DOE estimated that
7 ............................
1.11
0.2 the market share data for the 35.01–
45.00 pints/day and 54.01–74.99 pints/
* Intermediate efficiency level.
day classes could be used to
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
that AHAM provided that show the
distribution of dehumidifier efficiencies pints/day and greater product classes,
respectively. Table II.59 presents the
in 2005 for two of the six product
market shares of the efficiency levels in
classes: 35.01–45.00 pints/day and
the base case for the three classes of
54.01–74.99 pints/day. Because DOE
conducted the engineering and LCC and dehumidifiers that DOE used to conduct
the LCC analysis. The market shares in
PBP analyses on the combined product
class of 0–35.00 pints/day product class Table II.59 represent the equipment that
households would have been
as well as these two classes, DOE had
to estimate the market share data for the anticipated to purchase in the year 2012
in the absence of new standards.
combined 0–35.00 pints/day product
Market
share
(percent)
TABLE II.59.—DEHUMIDIFIERS: BASE CASE MARKET SHARES
0–35.00 pints/day
Level
35.01–45.00 pints/day
Market
share
(percent)
EF
Baseline ................
1 ............................
2 ............................
3 ............................
4 ............................
5 ............................
1.20
1.25
1.30
1.35
1.40
1.45
27
35
0
0
38
0
Because DOE currently does not
regulate cooking product efficiency with
an energy efficiency descriptor, very
little is known regarding the
distribution of product efficiencies that
consumers in the United States
currently purchase. Therefore, for all
electric cooking products, including
microwave ovens, and gas self-cleaning
ovens, DOE estimated that 100 percent
of the market existed at the baseline
Level
Market
share
(percent)
EF
Baseline ................
1 ............................
2 ............................
3 ............................
4 ............................
5 ............................
54.01–74.99 pints/day
1.30
1.35
1.40
1.45
1.50
1.74
27
35
0
0
38
0
efficiency levels. For gas cooktops and
gas standard ovens, data are available,
both from DOE’s previous rulemaking
analysis and the Appliance Recycling
Information Center, to indicate the
historical percentage of products
shipped with standing pilots. Therefore,
DOE was able to estimate the percentage
of the gas cooktop and gas standard
oven market that is still sold with
standing pilot lights. Table II.60
Level
Market
share
(percent)
EF
Baseline ................
1 ............................
2 ............................
3 ............................
4 ............................
5 ............................
1.50
1.55
1.60
1.65
1.70
1.80
31
0
57
12
0
0
presents the market shares of the
efficiency levels in the base case for gas
cooktops and gas standard ovens. In the
table, candidate standard level 1
represents products without standing
pilot light ignition systems. The market
shares in Table II.60 represent the
equipment that households would have
been anticipated to purchase in the year
2012 in the absence of new energy
conservation standards.
TABLE II.60.—GAS COOKTOPS AND GAS STANDARD OVENS: BASE CASE MARKET SHARES
Gas cooktops
mstockstill on PROD1PC66 with PROPOSALS2
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18:25 Nov 14, 2007
Market share
(percent)
EF
Baseline ............................................
1 ........................................................
2 ........................................................
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0.156
0.399
0.420
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93.2
0
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Candidate standard level
EF
Baseline ............................................
1* ......................................................
2 ........................................................
3 ........................................................
4 ........................................................
5 ........................................................
6 ........................................................
Sfmt 4702
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0.0298
0.0536
0.0566
0.0572
0.0593
0.0596
0.0600
Market share
(percent)
17.6
82.4
0
0
0
0
0
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Federal Register / Vol. 72, No. 220 / Thursday, November 15, 2007 / Proposed Rules
TABLE II.60.—GAS COOKTOPS AND GAS STANDARD OVENS: BASE CASE MARKET SHARES—Continued
Gas cooktops
Candidate standard level
Gas standard ovens
Market share
(percent)
EF
Candidate standard level
Market share
(percent)
EF
1a* ....................................................
0.0583
0
* 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.
For CCWs, DOE was unable to
develop a consumer sample. However, it
took into account the base case mix of
CCW efficiencies by characterizing the
current mix of product efficiencies as a
probability distribution. In other words,
as DOE performed the Monte Carlo
simulation, it evaluated each standard
level analyzed against the distribution
of product efficiencies in the base case.
DOE derived its base case market
share data for CCWs based on shipmentweighted efficiency data that AHAM
provided. Table II.61 presents the
market shares of the candidate standard
levels in the base case for standard-sized
dishwashers. The market shares in
Table II.61 represent the products that
households would have been
anticipated to purchase in the year 2012
in the absence of new energy
conservation standards.
TABLE II.61.—COMMERCIAL CLOTHES WASHERS: BASE CASE MARKET SHARES
Level
MEF
Baseline .......................................................................................................................................
1 ...................................................................................................................................................
2 ...................................................................................................................................................
3 ...................................................................................................................................................
4 ...................................................................................................................................................
5 ...................................................................................................................................................
6 ...................................................................................................................................................
mstockstill on PROD1PC66 with PROPOSALS2
For more details on how DOE
developed the base case product
efficiency distributions for the four
appliance products in the LCC analysis,
refer to Chapter 8 of the TSD.
DOE specifically seeks feedback on its
methodology and data sources for
developing the base case product
efficiency distributions for the four
appliance products. This is identified as
Issue 12 under ‘‘Issues on Which DOE
Seeks Comment’’ in section IV.E of this
ANOPR.
3. Payback Period Inputs
As described above, the PBP is the
amount of time it takes the consumer to
recover the additional installed cost of
more-efficient equipment through
energy (and water) cost savings, as
compared to baseline equipment.
Simple payback period does not take
into account changes in operating
expense over time or the time value of
money. Payback periods are expressed
in years. Payback periods greater than
the life of the product mean that the
increased total installed cost is not
recovered in reduced operating
expenses.
The inputs to the calculation of the
PBP are the total installed cost of the
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equipment to the customer for each
efficiency level and the annual (firstyear) operating expenditures for each
efficiency level. The PBP calculation
uses the same inputs as the LCC
analysis, except that energy (and water)
price trends and discount rates are not
needed. The calculation needs energy
prices only for the year in which a new
standard is expected to take effect, in
this case the year 2012.
4. Life-Cycle Cost and Payback Period
Results
DOE calculated the LCC and PBP
results relative to the base case forecast
for each product class. As mentioned
above, the base case consists of the
projected pattern of equipment
purchases that would occur in the
absence of new efficiency standards.
The following tables (Table II.62
through Table II.75) present the findings
from the LCC and PBP analyses DOE
performed for this ANOPR. DOE
determined the values at each candidate
standard level by excluding the
percentage of households not impacted
by the standard (i.e., those who, in base
case, already purchase a unit at or above
the given efficiency level). Figures
showing the distribution of LCCs, LCC
PO 00000
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Market share
(percent)
WF
1.26
1.42
1.60
1.72
1.80
2.00
2.20
9.50
9.50
8.50
8.00
7.50
5.50
5.10
79.7
0.0
0.0
0.0
0.0
20.3
0.0
impacts, and PBPs with their
corresponding probability of occurrence
are presented in Chapter 8 of the TSD.
Table II.62 shows the LCC and PBP
results for standard-sized dishwashers.
For example, candidate standard level 3
(0.65 EF) shows an average LCC savings
of $17. Note that for standard level 3,
10.6 percent of the housing units in
2012 are shown to have already
purchased a dishwasher at standard
level 3 in the base case and, thus, have
zero savings due to the standard. If one
compares the LCC of the baseline at 0.46
EF ($1124) to the standards case at 0.65
EF ($1025), then the difference in the
LCCs is $99. However, since the base
case includes a significant number of
households that are not impacted by the
standard, the average savings over all of
the households is actually $17, not $99.
With regard to the PBPs shown below,
DOE determined the median and
average values by excluding the
percentage of households not impacted
by the standard. For example, in the
case of standard level 3, 10.6 percent of
the households did not factor into the
calculation of the median and average
PBP.
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TABLE II.62.—STANDARD-SIZED DISHWASHERS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Life-cycle cost
Candidate
standard
level
EF
Baseline
1 ...........
2 ...........
3 ...........
4 ...........
5 ...........
6 ...........
7 ...........
Average
installed
price
0.46
0.58
0.62
0.65
0.68
0.72
0.80
1.11
Average
LCC
$424
339
318
303
291
275
249
183
Tables II.63, II.64, and II.65 show the
LCC and PBP results for dehumidifiers.
For example, in the case of the 35.01–
45.00 pints/day class, candidate
standard level 3 (1.45 EF) shows an
average LCC savings of $8. Note that for
standard level 3, 38.2 percent of the
housing units in 2012 are shown to have
already purchased a dehumidifier at
standard level 3 in the base case and,
Payback period
(years)
Households with
Average
operating
cost
$700
706
712
722
747
811
900
980
Life-cycle cost savings
$1,124
1,045
1,029
1,025
1,038
1,086
1,149
1,162
Average
savings
Net cost
(percent)
$4
13
17
5
¥43
¥106
¥119
No impact
(percent)
Net benefit
(percent)
92.8
32.8
10.6
3.1
0.6
0.4
0.3
7.1
56.0
56.8
38.4
16.5
9.5
16.4
0.1
11.3
32.6
58.6
82.9
90.1
83.3
thus, have zero savings due to the
standard. If one compares the LCC of the
base case at 1.30 EF ($676) to the
standards case at 1.45 EF ($657), then
the difference in the LCCs is $19.
However, since the base case includes a
significant number of households that
are not impacted by the standard, the
average savings over all of the
households is actually $8, not $19. With
Median
Average
0.9
2.8
5.9
11.9
22.5
28.3
21.9
1.5
5.1
10.9
22.2
42.3
51.5
39.3
regard to the PBPs shown below, DOE
determined the median and average
values by excluding the percentage of
households not impacted by the
standard. For example, in the case of
standard level 3 for the 35.01–45.00
pints/day class, 38.2 percent of the
households did not factor into the
calculation of the median and average
PBP.
TABLE II.63.—DEHUMIDIFIERS, 0–35.00 PINTS/DAY: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Life-cycle cost *
Candidate
standard
level
Efficiency
liters/kWh
Baseline
1 ...........
2 ...........
3 ...........
4 ...........
5 ...........
1.20
1.25
1.30
1.35
1.40
1.45
Average
installed
price
Average
operating
cost
$137
142
142
153
166
176
$422
405
389
375
361
349
Life-cycle cost savings *
Payback period
(years) *
Households with
Average
LCC
$558
546
533
528
527
525
Average
savings
..................
$3
11
15
15
17
Net cost
(percent)
No impact
(percent)
Net benefit
(percent)
Median
Average
..................
0.0
0.0
0.2
5.5
25.9
..................
73.1
38.4
38.4
38.4
0.0
..................
26.9
61.6
61.4
56.2
74.1
..................
2.6
1.7
3.2
4.6
5.7
..................
2.5
1.8
3.1
4.5
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
Life-cycle cost
Candidate
standard
level
Efficiency
liters/kWh
Baseline
1 ...........
2 ...........
3 ...........
4 ...........
5 ...........
1.30
1.35
1.40
1.45
1.50
1.74
Average
installed
price
Average
operating
cost
$157
167
167
192
208
272
$519
500
482
465
450
388
Life-cycle cost savings
Payback period
(years)
Households with
Average
LCC
$676
666
661
657
658
660
Average
savings
..................
$3
6
8
8
5
Net cost
(percent)
No impact
(percent)
Net benefit
(percent)
Median
Average
..................
1.5
15.2
17.5
22.7
54.1
..................
73.1
38.2
38.2
38.2
0.0
..................
25.5
46.6
44.3
39.1
45.9
..................
4.4
5.9
6.2
7.0
8.5
..................
4.2
5.8
6.1
6.8
8.3
mstockstill on PROD1PC66 with PROPOSALS2
TABLE II.65.—DEHUMIDIFIERS, 54.01–74.99 PINTS/DAY: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Life-cycle cost
Candidate
standard
level
Efficiency
liters/kWh
Baseline
1.50
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installed
price
18:25 Nov 14, 2007
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operating
cost
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Life-cycle cost savings
Payback period
(years)
Households with
Average
LCC
$914
Frm 00060
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savings
..................
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Net cost
(percent)
No impact
(percent)
Net benefit
(percent)
Median
Average
..................
..................
..................
..................
..................
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TABLE II.65.—DEHUMIDIFIERS, 54.01–74.99 PINTS/DAY: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS—Continued
Life-cycle cost
Candidate
standard
level
1
2
3
4
5
Efficiency
liters/kWh
...........
...........
...........
...........
...........
Average
installed
price
1.55
1.60
1.65
1.70
1.80
Average
LCC
702
680
659
640
604
Tables II.66, II.67, and II.68 show the
LCC and PBP results for cooktops. For
example, in the case of gas cooktops,
candidate standard level 1 (pilotless
ignition with an efficiency of 0.399 EF)
shows an average LCC savings of $19.
Note that for standard level 1, 93.4
percent of the housing units in 2012 are
shown to have already purchased a gas
cooktop with pilotless ignition in the
Payback period
(years)
Households with
Average
operating
cost
195
195
208
224
241
Life-cycle cost savings
Average
savings
897
881
867
864
845
Net cost
(percent)
$5
10
22
25
44
No impact
(percent)
Net benefit
(percent)
68.5
68.5
12.3
0.0
0.0
31.5
31.5
87.7
85.9
92.2
0.0
0.0
0.0
14.1
7.8
base case and, thus, have zero savings
due to the standard. If one compares the
LCC of the baseline at 0.106 EF ($716)
to the standards case at 0.399 EF ($435),
then the difference in the LCCs is $281.
However, since the base case includes a
significant number of households that
are not impacted by the standard, the
average savings over all of the
households is actually $19, not $281.
Median
Average
2.5
2.4
2.8
4.8
4.4
2.4
2.4
2.7
4.9
4.4
With regard to the PBPs shown below,
DOE determined the median and
average values by excluding the
percentage of households not impacted
by the standard. For example, in the
case of standard level 1 for gas cooktops,
93.4 percent of the households did not
factor into the calculation of the median
and average PBP.
TABLE II.66.—ELECTRIC COIL COOKTOPS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Candidate
standard
level
Baseline
1 ...........
Life-cycle cost
EF
Average
installed
price
0.737
0.769
Average
operating
cost
$251
255
Life-cycle cost savings
Average
LCC
$150
144
$401
399
Payback period
(years)
Households with
Average
savings
Net cost
No impact
Net benefit
Median
Average
..................
$3
..................
35.0%
..................
0.0%
..................
65.0%
..................
8.1
..................
18.6
TABLE II.67.—ELECTRIC SMOOTH COOKTOPS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Candidate
standard
level
Baseline
1 ...........
Life-cycle cost
EF
Average
installed
price
0.742
0.753
Average
operating
cost
$288
528
Life-cycle cost savings
Average
LCC
$150
148
$438
676
Payback period
(years)
Households with
Average
savings
Net cost
No impact
Net benefit
Median
Average
..................
¥$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
Life-cycle cost
Candidate
standard
level
mstockstill on PROD1PC66 with PROPOSALS2
Baseline
1 ...........
2 ...........
EF
Average
installed
price
0.106
0.399
0.420
VerDate Aug<31>2005
18:25 Nov 14, 2007
Jkt 214001
Average
LCC
$428
113
107
Tables II.69 through II.72 show the
LCC and PBP results for ovens. For
example, in the case of gas standard
ovens, candidate standard level 1
(pilotless ignition with an efficiency of
0.058 EF) shows an average LCC savings
of $16. Note that for standard level 1, 83
percent of the housing units in 2012 are
shown to have already purchased a gas
Payback period
(years)
Households with
Average
operating
cost
$289
322
351
Life-cycle cost savings
$716
435
458
Average
savings
..................
$19
¥5
Net cost
(percent)
No impact
(percent)
Net benefit
(percent)
Median
Average
..................
0.0
93.2
..................
93.4
0.0
..................
6.7
6.8
..................
1.3
75.3
..................
1.4
195.1
standard oven with pilotless ignition in
the base case and, thus, have zero
savings due to the standard. If one
compares the LCC of the base case at
0.030 EF ($697) to the standards case at
0.058 EF ($603), then the difference in
the LCCs is $94. However, since the
base case includes a significant number
of households that are not impacted by
PO 00000
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Sfmt 4702
the standard, the average savings over
all of the households is actually $16, not
$94. With regard to the PBPs shown
below, DOE determined the median and
average values by excluding the
percentage of households not impacted
by the standard. For example, in the
case of standard level 1 for gas standard
ovens, 83 percent of the households did
E:\FR\FM\15NOP2.SGM
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not factor into the calculation of the
median and average PBP. Also of note
regarding PBPs, the large difference in
the average and median values for
electric self-cleaning ovens and
standard level 5 for gas standard ovens
are due to outliers in the distribution of
results. The Monte Carlo simulation for
electric self-cleaning ovens and
standard level 5 for gas ovens yielded a
few results with PBPs in excess of one
million years. A limited number of
excessively long PBPs produce an
average PBP that is very long. Therefore,
in these cases, the median PBP is a more
representative value to gauge the length
of the PBP.
TABLE II.69.—ELECTRIC STANDARD OVENS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Life-cycle cost
Candidate
standard
level
EF
Baseline
1 ...........
2 ...........
3 ...........
4 ...........
5 ...........
0.1066
0.1113
0.1163
0.1181
0.1206
0.1209
Average
installed
price
Average
operating
cost
$392
395
399
405
462
467
$189
182
175
172
169
169
Life-cycle cost savings
Payback period
(years)
Households with
Average
LCC
$581
576
574
577
631
636
Average
savings
..................
$5
7
4
¥50
¥55
Net cost
(percent)
No impact
(percent)
Net benefit
(percent)
Median
Average
..................
38.3
46.5
54.5
96.4
97.1
..................
0.0
0.0
0.0
0.0
0.0
..................
61.8
53.5
45.5
3.6
2.9
..................
6.0
9.1
13.8
65.5
68.7
..................
45.6
68.7
103.9
493.6
517.9
TABLE II.70.—ELECTRIC SELF-CLEANING OVENS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Life-cycle cost
Candidate
standard
level
EF
Baseline
1 ...........
2 ...........
0.1099
0.1102
0.1123
Average
installed
price
Average
operating
cost
$463
469
527
$200
199
196
Life-cycle cost savings
Payback period
(years)
Households with
Average
LCC
$663
669
723
Average
savings
..................
¥$88
¥142
Net cost
(percent)
No impact
(percent)
No benefit
(percent)
Median
Average
..................
74.6
81.9
..................
0.0
0.0
..................
25.4
18.1
..................
196.7
266.7
..................
1,071.7
1,453.0
TABLE II.71.—GAS STANDARD OVENS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Life-cycle cost
Candidate
standard
level
EF
Baseline
1* ..........
2 ...........
3 ...........
4 ...........
5 ...........
6 ...........
1a* ........
0.0298
0.0536
0.0566
0.0572
0.0593
0.0596
0.0600
0.0583
Average
installed
price
Average
operating
cost
$409
442
447
448
481
483
488
446
$288
162
154
153
149
148
148
134
Life-cycle cost savings
Payback period
(years)
Households with
Average
LCC
$697
603
601
601
630
632
636
580
Average
savings
..................
$16
18
18
¥11
¥12
¥17
39
Net cost
(percent)
No impact
(percent)
No benefit
(percent)
Median
Average
..................
0.0
46.1
47.9
77.4
77.9
79.5
0.0
..................
83.0
0.0
0.0
0.0
0.0
0.0
0.0
..................
17.0
53.9
52.1
22.6
22.1
20.5
100.0
..................
3.3
8.4
9.4
27.2
27.9
30.1
2.2
..................
3.4
136.1
152.3
460.1
1,907.4
426.3
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 derived from candidate standard level 1.
TABLE II.72.—GAS SELF-CLEANING OVENS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Life-cycle cost
mstockstill on PROD1PC66 with PROPOSALS2
Candidate
standard
level
EF
Baseline
1 ...........
2 ...........
3 ...........
0.0540
0.0625
0.0627
0.0632
VerDate Aug<31>2005
Average
installed
price
18:25 Nov 14, 2007
Average
operating
cost
$529
545
551
553
Jkt 214001
$200
183
182
182
PO 00000
Life-cycle cost savings
Payback period
(years)
Households with
Average
LCC
$729
727
733
734
Frm 00062
Average
savings
..................
$1
¥5
¥6
Fmt 4701
Net cost
(percent)
No impact
(percent)
No benefit
(percent)
Median
Average
..................
58.3
67.3
68.4
..................
0.0
0.0
0.0
..................
41.7
32.7
31.6
..................
11.8
16.1
16.7
..................
158.0
235.3
149.0
Sfmt 4702
E:\FR\FM\15NOP2.SGM
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Table II.73 shows the LCC and PBP
results for microwave ovens. For
example, candidate standard level 4
(0.602 EF) shows an average LCC cost
increase of $68. The median and average
PBPs for standard level 4 are 132.2 and
327.5 years, respectively.
TABLE II.73.—MICROWAVE OVENS: LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS
Life-cycle cost
Candidate
standard
level
Baseline
1 ...........
2 ...........
3 ...........
4 ...........
EF
Average
installed
price
0.557
0.586
0.588
0.597
0.602
Average
LCC
$89
84
84
83
82
Tables II.74 and II.75 show the LCC
and PBP results for both product
applications of CCWs. For example, in
the case of the multi-family application,
candidate standard level 5 (2.00 MEF/
5.50 WF) shows an average LCC savings
of $404. Note that for standard level 5,
20.9 percent of consumers in 2012 are
assumed to already be using a CCW in
the base case at standard level 5 and,
Payback period
(years)
Households with
Average
operating
cost
$219
232
246
267
294
Life-cycle cost savings
Average
savings
$308
316
329
349
376
..................
¥8
¥21
¥41
¥68
Net cost
(percent)
No impact
(percent)
Net benefit
(percent)
Median
Average
..................
93.0
98.6
99.6
99.9
..................
0.0
0.0
0.0
0.0
..................
7.0
1.4
0.4
0.1
..................
33.9
65.8
93.9
132.2
..................
84.0
163.1
232.5
327.5
thus, have zero savings due to the
standard. If one compares the LCC of the
base case at 1.26 MEF/9.50 WF ($3303)
to the standards case at 2.00 MEF/5.50
WF ($2794), then the difference in the
LCCs is $509. However, since the base
case includes a significant number of
consumers that are not impacted by the
standard, the average savings over all of
the consumers is actually $404, not
$509. With regard to the PBPs shown
below, DOE determined the median and
average values by excluding the
percentage of households not impacted
by the standard. For example, in the
case of standard level 5, 20.9 percent of
the consumers did not factor into the
calculation of the median and average
PBP.
TABLE II.74.—COMMERCIAL CLOTHES WASHERS, MULTI-FAMILY APPLICATION: LIFE-CYCLE COST AND PAYBACK PERIOD
RESULTS
Life-cycle cost
Candidate standard
level
Baseline ......................
1 .................................
2 .................................
3 .................................
4 .................................
5 .................................
6 .................................
MEF/WF
1.26/9.50
1.42/9.50
1.60/8.50
1.72/8.00
1.80/7.50
2.00/5.50
2.20/5.10
Average
installed
price
Average
operating
cost
$722
840
1,224
1,224
1,224
1,224
1,224
Life-cycle cost savings
Payback period
(years)
Households with
Average
LCC
Average
savings
$3,303
3,294
3,413
3,277
3,167
2,794
2,670
..............
7
¥86
21
109
404
529
$2,581
2,454
2,189
2,053
1,943
1,571
1,446
Net cost
(percent)
No impact
(percent)
Net benefit
(percent)
Median
Average
..................
42.0
61.5
43.3
30.4
9.3
6.3
..................
20.9
20.9
20.9
20.9
20.9
0.0
..................
37.1
17.6
35.9
48.8
69.9
93.7
..............
8.4
11.9
8.8
7.3
4.6
3.8
..............
8.9
12.8
9.5
7.9
5.1
3.6
TABLE II.75.—COMMERCIAL CLOTHES WASHERS, LAUNDROMAT APPLICATION: LIFE-CYCLE COST AND PAYBACK PERIOD
RESULTS
Life-cycle cost
Candidate standard
level
mstockstill on PROD1PC66 with PROPOSALS2
Baseline ......................
1 .................................
2 .................................
3 .................................
4 .................................
5 .................................
6 .................................
MEF/WF
1.26/9.50
1.42/9.50
1.60/8.50
1.72/8.00
1.80/7.50
2.00/5.50
2.20/5.10
Average
installed
price
$722
840
1,224
1,224
1,224
1,224
1,224
DOE presents these findings to
facilitate stakeholder review of the LCC
and PBP analyses. DOE seeks
information and comments relevant to
the assumptions, methodology, and
VerDate Aug<31>2005
18:25 Nov 14, 2007
Average
operating
cost
Jkt 214001
Life-cycle cost savings
Households with
Average
LCC
Average
savings
$3,494
3,487
3,577
3,431
3,308
2,885
2,755
..............
5
¥66
50
147
482
612
$2,772
2,647
2,354
2,207
2,085
1,661
1,532
Net cost
(percent)
No impact
(percent)
Net benefit
(percent)
Median
Average
..................
35.9
61.5
29.2
13.6
0.7
0.2
..................
20.9
20.9
20.9
20.9
20.9
0.0
..................
43.2
17.7
50.0
65.5
78.5
99.8
..............
5.3
6.9
5.1
4.3
2.7
2.2
..............
5.6
7.3
5.4
4.5
2.8
2.0
results for these analyses. See Chapter 8
of the TSD for additional detail on the
LCC and PBP analyses.
PO 00000
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(years)
Frm 00063
Fmt 4701
Sfmt 4702
H. Shipments Analysis
This section presents DOE’s
shipments analysis, which is an input
into the NIA (section II.I). DOE will also
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mstockstill on PROD1PC66 with PROPOSALS2
use shipments estimates as input to the
MIA, which is discussed in section II.K.
DOE will undertake the MIA after the
ANOPR is published, and will report
the MIA findings in the NOPR.
As indicated above and in the
discussion below of the NIA, for each
product, DOE has developed a base case
forecast to depict what would happen to
energy and water use, and to consumer
costs for purchase and operation of the
product, if DOE does not adopt new
energy conservation standards. To
evaluate the impacts of such new
standards, DOE compares these base
case forecasts to forecasts of what would
happen if DOE adopts new standards at
various higher efficiency levels. One
element of both types of forecasts is
product shipments. In determining the
base case, DOE considered historical
shipments, the mix of efficiencies sold
in the absence of standards, and how
that mix might change over time.
1. Shipments Model
DOE estimated shipments for each of
the four appliance products using a
separate Shipments Model.
Furthermore, in the case of cooking
products, DOE developed two separate
Shipments Models—one for cooktops
and ovens and another for microwave
ovens. Therefore, DOE developed a total
of five separate Shipments Models (i.e.,
two for cooking products and one each
for dishwashers, dehumidifiers, and
CCWs). Each Shipments Model was
calibrated against historical shipments.
For purposes of estimating the impacts
of prospective candidate standard levels
on product shipments, each Shipments
Model accounts for the combined effects
of changes in purchase price, annual
operating cost, and household income
on the consumer purchase decision.
In overview, each Shipments Model
considers specific market segments, the
results for which are then aggregated to
estimate total product shipments. In the
case of all of the four appliance
products (with the exception of
dehumidifiers), DOE accounted for at
least two market segments: (1) New
construction and (2) existing buildings
(i.e., replacing failed equipment). For
dehumidifiers, DOE did not consider
the new construction market since this
product, unlike most major household
appliances, is not standard equipment
for new households. Instead, in addition
to accounting for replacements, DOE
accounted for the market of existing
households acquiring new
dehumidifiers for the first time.
Furthermore, for the following products,
DOE accounted for a third market
segment: Cooking products (early
replacements); dishwashers (existing
VerDate Aug<31>2005
18:25 Nov 14, 2007
Jkt 214001
households acquiring the equipment for
the first time); and CCWs (retired units
not replaced).
With regard to the market of existing
households purchasing dehumidifiers,
Whirlpool commented that shipments to
existing households that do not already
own a dehumidifier are likely very low
for two reasons. First, Whirlpool stated
that historical data indicate that annual
dehumidifier shipments have been
relatively constant, and second, the
most significant new housing growth
has been in the Southern and Western
regions of the U.S. where central air
conditioning (as opposed to
dehumidifiers) is used to condition the
space. (Whirlpool, No. 10 at p. 12)
Contrary to Whirlpool’s claim, based on
historical data, DOE found that
shipments have more than doubled
since 1990, with an increase of nearly
50 percent over the 2003–2005 time
period. In allocating shipments to
existing households with a
dehumidifier, DOE used the historical
data to estimate which portion of the
shipments went to these existing
households. DOE first determined that
portion of the shipments that served as
replacements and then allocated the
remaining portion to existing
households without a dehumidifier. As
a result of this calculation, DOE
estimated that 0.6 percent of existing
households without a dehumidifier
would annually purchase this product
over the period 2005–2042.
With regard to the estimation of
forecasted commercial clothes washer
shipments, ALS stated that the market
for CCWs is already saturated and may
decline in the future. ALS believes that
the trend in multi-housing is to install
in-apartment washers rather than
provide common area commercial
laundry. Both ALS and MLA stated that
approximately 200,000 to 230,000
commercial washers are shipped per
year. Whirlpool stated that a saturationbased Shipments Model could be
developed to forecast shipments.
However, because historical industry
shipments have been constant,
Whirlpool suggested that DOE either
hold future product saturations constant
or allow them to decline. (Public
Meeting Transcript, No. 5 at pp. 213 and
219; MLA, No. 8 at p. 1; Whirlpool, No.
10 at p. 12)
DOE confirmed that over the period of
1988–1998, annual shipments of clothes
washers stayed roughly in the range
between 200,000 to 230,000 units per
year. But based on data provided by
AHAM, shipments dropped to
approximately 180,000 units for the year
2005. DOE confirmed this shipments
drop (from a peak of 265,000 units in
PO 00000
Frm 00064
Fmt 4701
Sfmt 4702
1998) using commercial laundry
quantity index data from the U.S.
Census Bureau.48 For purposes of
calibrating its Shipments Model, DOE
attributed this drop to non-replacements
(i.e., a portion of CCWs that were retired
from service over the period 1999–2005
were not replaced). Because DOE tied its
CCW shipments estimates to forecasts of
new multi-family construction as
provided by EIA’s AEO 2007, and
because AEO 2007 forecasts modest
growth in multi-family construction
starts, DOE’s Shipments Model
projected that shipments would recover
and gradually increase after the drop
witnessed over the 1999–2005 period.
Due to the dramatic drop in
shipments seen in the historical data,
DOE specifically seeks feedback on its
assumptions regarding the shipments
forecasts for CCWs. This is identified as
Issue 13 under ‘‘Issues on Which DOE
Seeks Comment’’ in section IV.E of this
ANOPR.
In principle, each market segment and
each product class responds differently
to both the base case demographic and
economic trends and to the
implementation of standards.
Furthermore, retirements, early
replacements, and efficiency trends are
dynamic and can vary among product
classes. Rather than simply
extrapolating a current shipments trend,
the base case shipments analysis uses
driver input variables, such as
construction forecasts and product
lifetime distributions, to forecast sales
in each market segment.
DOE’s Shipments Models take an
accounting approach, by tracking
market shares of each product class, the
vintage of units in the existing stock,
and expected construction trends. The
Models estimate shipments due to
replacements using sales in previous
years and assumptions about the life of
the equipment. Therefore, estimated
sales due to replacements in a given
year are equal to the total stock of the
appliance minus the sum of the
appliances sold in previous years that
still remain in the stock. DOE must
determine the useful service life of the
appliance to determine how long the
appliance is likely to remain in stock.
2. Data Inputs
As discussed above, shipments are
driven primarily by two market
48 U.S. Department of Commerce-Bureau of
Economic Analysis. Industry Economic Accounts,
Gross-Domestic-Product-(GDP)-by-Industry-Data,
1998– NAICS data: GDPbyInd_SHIP_NAICS and
SIC Data: GDPhyind_SHIP_SIC, Commercial
Laundry Quantity Index Data, NAICS code 333312.
Washington, DC. Available online at: https://
preview.bea.gov/industry/gdpbyind_data.htm.
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Federal Register / Vol. 72, No. 220 / Thursday, November 15, 2007 / Proposed Rules
segments: (1) New construction and (2)
replacements.
New housing forecasts and market
saturation data comprised the two
primary inputs for DOE’s estimates of
new construction shipments. ‘‘New
housing’’ includes newly-constructed
single-family and multi-family units
(referred to as ‘‘new housing
completions’’) and mobile home
placements. As noted above for CCWs,
DOE’s Shipments Model used only
newly-constructed multi-family units,
as DOE estimated shipments are driven
solely by multi-family construction
starts. For new housing completions and
mobile home placements, DOE used
actual data through 2005, and adopted
the projections from EIA’s AEO 2007 for
the period of 2006–2030.49 To
determine new construction shipments
for each of the four appliance products
(except dehumidifiers), DOE used
forecasts of housing starts coupled with
the product market saturation data for
new housing. DOE used the 2001 RECS
to establish dishwasher and cooktop
market saturations for new housing. For
commercial clothes washers, DOE relied
on the new construction market
saturation data from CEE.50
In the specific case of dehumidifiers,
EEI stated that DOE should account for
the market saturation of dehumidifying
equipment integrated into central spaceconditioning systems when evaluating
the overall dehumidifier market
saturation. (Public Meeting Transcript,
No. 5 at p. 220) In response, we note
that DOE’s Shipments Model for
dehumidifiers takes into consideration
saturation data pertaining only to
dehumidifiers manufactured as
independent units. Although growth in
central space-conditioning systems with
fully-integrated dehumidifying
equipment may have an impact on
forecasted dehumidifier shipments,
DOE was unable to obtain any data that
indicate the growth of these systems and
their impact on the overall dehumidifier
market.
In general, DOE estimated
replacements using product retirement
functions that it developed from
product lifetimes. For all of the four
appliance products (with the exception
of microwave ovens), DOE based the
retirement function on a uniform
probability distribution for the product
lifetime. The Shipments Models assume
that no units are retired below a
minimum product lifetime and that all
units are retired before exceeding a
maximum product lifetime. NWPCC
noted that DOE should calibrate the
Shipments Models to historical
shipments data to ensure that the
estimates of product lifetimes are
reasonable. (Public Meeting Transcript,
No. 5 at p. 215) As noted previously,
DOE calibrated each Shipments Model
against historical shipments. In its
calibrations, which entailed estimating
which portion of shipments are
replacements, DOE used the product
lifetimes that it established for the LCC
analysis (refer to section II.G.2.b for
more details). DOE found that the
product lifetimes provided reasonable
estimates of overall shipments for each
of the products.
3. Shipments Forecasts
Table II.76 shows the results of the
shipments analysis for the base case for
each of the products. Of the products
listed in Table II.76, dehumidifiers, gas
cooktops and ovens, and electric
cooktops and ovens are comprised of
several product classes. Specifically,
dehumidifiers consist of six product
classes; gas cooktops and ovens consist
of three classes, and electric cooktops
and ovens consist of four classes. For
each of these products (with each
product consisting of more than one
product class, except CCW) DOE’s
analysis estimated the aggregate
shipments. Once it had established the
aggregate shipments estimate, DOE then
allocated the shipments to each product
class based on historical market share
data. Chapter 9 of the TSD provides
details on the product class market
shares for dehumidifiers, gas cooktops
and ovens, and electric cooktops and
ovens.
TABLE II.76.—FORECASTED SHIPMENTS FOR HOME APPLIANCES, 2012–2042, BASE CASE (MILLION UNITS)
Product
2012
mstockstill on PROD1PC66 with PROPOSALS2
Dishwashers .............................................
Dehumidifiers ...........................................
Gas cooktops and ovens .........................
Electric cooktops and ovens ....................
Microwave ovens .....................................
Commercial clothes washers ...................
8.12
1.82
3.80
6.24
16.11
0.24
2015
8.73
1.99
3.82
6.41
15.41
0.24
2020
2025
9.62
2.39
4.05
7.03
17.54
0.27
2030
10.36
2.65
4.26
7.52
17.67
0.29
11.17
2.98
4.43
7.88
19.61
0.32
2035
2040
11.76
3.30
4.57
8.26
20.01
0.34
12.28
3.59
4.75
8.72
21.50
0.37
2042
12.48
3.71
4.82
8.91
21.53
0.38
Cumulative
328
86
133
235
578
9.4
To estimate the combined effects on
product shipments from increases in
equipment purchase price and decreases
in equipment operating costs due to
new efficiency standards, DOE
conducted a literature review and a
statistical analysis on a limited set of
appliance price, efficiency, and
shipments data.
In the literature, DOE found only a
few studies of appliance markets that
are relevant to this rulemaking analysis,
and identified no studies that use timeseries of equipment price and shipments
data after 1980. The information that
DOE summarized from the literature
suggests that the demand for appliances
is price inelastic.
DOE did not find enough equipment
purchase price and operating cost data
to perform a complex analysis of
dynamic changes in the appliance
market. Rather, DOE used purchase
price and efficiency data specific to
residential refrigerators, clothes
washers, and dishwashers over the
period 1980–2002 to evaluate broad
market trends and to conduct simple
regression analyses. These data indicate
that there has been a rise in appliance
shipments and a decline in appliance
purchase price and operating costs over
the time period. Household income has
also risen during this time. DOE
combined the available economic
information into one variable, termed
the ‘‘relative price,’’ which is the sum of
the purchase price and the present value
of operating cost savings divided by
household income, and used this
variable to conduct a regression
analysis. DOE’s regression analysis
suggested that the relative price
elasticity of demand, averaged over the
three appliances, is ¥0.34. For example,
49 49 U.S. Department of Energy-Energy
Information Administration. Annual Energy
Outlook 2007 with Projections to 2030, February,
2007. Washington, DC. DOE/EIA–0383 (2007).
Available online at: https://www.eia.doe.gov/oiaf/
aeo/
50 Consortium for Energy Efficiency. Commercial
Family-Sized Washers: An Initiative Description of
the Consortium for Energy Efficiency, 1998. Boston,
MA. Available online at: https://www.cee1.org/com/
cwsh/cwsh-main.php3.
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for a relative price increase of 10
percent, shipments decrease by 3.4
percent. Note that because the relative
price elasticity incorporates the impacts
from three effects (i.e., purchase price,
operating cost, and household income),
the impact from any single effect is
mitigated by changes from the other two
effects. The relative price elasticity of
¥0.34 is consistent with estimates in
the literature. Nevertheless, DOE
stresses that the measure is based on a
small data set, using simple statistical
analysis. More important, the measure is
based on the premise that economic
variables (including purchase price,
operating costs, and household income)
explain most of the trend in appliances
per household in the U.S. since 1980.
Changes in appliance quality and
consumer preferences may have
occurred during this period, but DOE
did not account for them in this
analysis. Despite these uncertainties,
DOE believes that its estimate of the
relative price elasticity of demand
provides a reasonable assessment of the
impact that purchase price, operating
cost, and household income have on
product shipments.
Because DOE’s forecasts of shipments
and national impacts due to standards is
over a 30-year time period,
consideration must be given as to how
the relative price elasticity is affected
once a new standard takes effect. DOE
considers the relative price elasticity of
¥0.34 to be a short-run value. DOE was
unable to identify sources specific to
household durable goods, such as
appliances, to indicate how short-run
and long-run price elasticities differ.
Therefore, to estimate how the relative
price elasticity changes over time, DOE
relied on a study pertaining to
automobiles showing that the
automobile price elasticity of demand
changes in the years following a
purchase price change.51 With
increasing years after the purchase price
change, the price elasticity becomes
more inelastic until it reaches a terminal
value around the tenth year after the
price change. For its shipments analysis,
DOE incorporated a relative price
elasticity change that resulted in a
terminal value of approximately onethird (¥0.11) of the short-run elasticity
(¥0.34). In other words, consumer
purchase decisions, in time, become less
sensitive to the initial change in the
product’s relative price.
51 S. Hymans. Consumer Durable Spending:
Explanation and Prediction, Brookings Papers on
Economic Activity, 1971. Vol. 1971, No. 1, pp. 234–
239. Available for purchase online at: https://links.
jstor.org/sici?sici=0007–2303(1970)1970%3A2%
3C173%3ACDSEAP%3E2.0.CO%3B2-S.
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PG&E commented that consumers will
replace failed equipment regardless of
the increased purchase price due to
efficiency standards. (Public Meeting
Transcript, No. 5 at p. 224) In its
regression analysis of appliance
purchase price, efficiency, and
shipments data, DOE did not attempt to
quantify the shipments impacts to
separate markets (i.e., new construction
and replacements). Because DOE’s
regression analysis focused on the
impacts to aggregate shipments, it
applied the sensitivity to purchase
price, operating cost, and household
income equally to all markets. DOE
believes this level of precision is
sufficient for capturing the effect that
these three factors have on overall
product shipments.
Additional detail on the shipments
analysis can be found in Chapter 9 of
the TSD.
I. National Impact Analysis
The NIA assesses cumulative NES and
the cumulative national economic
impacts of candidate standards levels.
The analysis measures economic
impacts using the NPV metric, which
represents the net present value (i.e.,
future amounts discounted to the
present) of total customer costs and
savings expected to result from new
standards at specific efficiency levels.
For a given candidate standard level,
DOE calculated both the NPV and the
NES as the difference between a base
case forecast and the standards case. A
summary of this analysis is provided
below, but additional detail on the NIA
for the four appliance products may be
found in Chapter 10 of the TSD.
DOE determined national annual
energy consumption as the product of
the annual energy consumption per unit
and the number of units of each vintage.
This approach accounts for differences
in per-unit energy consumption from
year to year. Cumulative energy savings
are the sum of the annual NES
determined over a specified time period.
DOE calculated net economic savings
each year as the difference between total
operating cost savings and increases in
total installed costs. Cumulative savings
are the sum of the annual NPV
determined over a specified time period.
1. Approach
Over time, in the standards case,
more-efficient products gradually
replace less efficient products. This
affects the calculation of the NES and
NPV, which are both a function of the
total number of units in use and their
efficiencies, and, thus, are dependent on
annual shipments and the lifetime of a
product. Both calculations start by using
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the estimate of shipments and the
quantity of units in service that DOE
derived from the Shipments Model.
With regard to the estimation of NES,
because more-efficient units of a
product gradually replace less efficient
ones, the per-unit energy consumption
of the products in service gradually
decreases in the standards case relative
to the base case. To estimate the
resulting total energy savings for each
candidate efficiency level, DOE first
calculated the national site-energy
consumption for each of the four
appliance products for each year,
beginning with the expected effective
date of the standards (2012), for the base
case forecast and each standards case
forecast. (Site energy is the energy
directly consumed by the units of the
product in operation.) Second, DOE
determined the annual site-energy
savings, consisting of the difference in
site-energy consumption between the
base case and the standards case. Third,
DOE converted the annual site-energy
savings into the annual amount of
energy saved at the source of electricity
generation or of natural gas production
(the source energy) using site-to-source
conversion factors. Finally, DOE
summed the annual source-energy
savings from 2012 to 2042 to calculate
the total NES for that period. DOE
performed these calculations for each
candidate standard level.
To estimate NPV, DOE calculated the
net impact each year as the difference
between total operating cost savings
(including gas and/or electricity and
water, repair, and maintenance cost
savings) and increases in total installed
costs (which consist of the incremental
increase in manufacturer selling price,
sales taxes, distribution chain markups,
and installation cost). DOE calculated
the NPV of each candidate standard
level over the life of the equipment,
using the following three steps. First,
DOE determined the difference between
the equipment costs under the
candidate standard level case and the
base case, to get the net equipment cost
increase resulting from the candidate
standard level. Second, DOE determined
the difference between the base case
operating costs and the candidate
standard level operating costs, to get the
net operating cost savings resulting from
the candidate standard level. Third,
DOE determined the difference between
the net operating cost savings and the
net equipment cost increase to get the
net savings (or expense) for each year.
DOE then discounted the annual net
savings (or expenses) to the year 2006
for products bought in or before 2042
and summed the discounted values to
provide the NPV of a candidate standard
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level. An NPV greater than zero shows
net savings (i.e., the candidate standard
level would reduce customer
expenditures relative to the base case in
present value terms). An NPV that is
less than zero indicates that the
candidate standard level would result in
a net increase in customer expenditures
in present value terms.
Another aspect of the NIA is the
consideration of market-pull or
voluntary programs that promote the
adoption of more-efficient equipment.
PG&E stated that market-pull programs
do not necessarily diminish the impact
of mandatory efficiency standards.
Whirlpool stated that the effectiveness
of one type of market-pull program
(Energy Star) could be diminished if
mandatory standards are set
prematurely. Whirlpool argued that
existing product efficiencies are
approaching Energy Star levels, thereby
diminishing the effectiveness of the
program if mandatory standards are set
too high. (Public Meeting Transcript,
No. 5 at p. 223; Whirlpool, No. 10 at p.
11) In response, DOE notes that for some
products, market-pull programs (e.g.,
Energy Star) have likely increased the
share of energy-efficient equipment both
prior to and after the implementation
date of any new standards. For example,
in the case of dishwashers, the
shipment-weighted efficiency has
increased at an average annul rate of
approximately 2.5 percent since
mandatory efficiency standards came
into effect in 1994. The Energy Star
program, which came into effect for
dishwashers in 1996, was likely
responsible for at least some of the gain
in dishwasher efficiency. Although DOE
recognizes that market-pull programs
such as Energy Star play a factor in
increasing the energy efficiency of
appliances, DOE was not able to obtain
information that quantified precisely
how such programs affect equipment
efficiencies on a national basis.
Consequently, DOE did not explicitly
incorporate the impact of market-based
initiatives that may be implemented in
the future into the analysis.
2. Base Case and Standards Case
Forecasted Efficiencies
A key component of DOE’s estimates
of NES and NPV are the energy
efficiencies that it forecasts over time for
the base case (without new standards)
and each of the standards cases. The
forecasted efficiencies represent the
annual shipment-weighted energy
efficiency of the products under
consideration over the forecast period
(i.e., from the estimated effective date of
a new standard to 30 years after the
standard becomes effective). Because
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key inputs to the calculation of the NES
and NPV are dependent on the
estimated efficiencies, they are of great
importance to the analysis. In the case
of the NES, the per-unit annual energy
(and water) consumption is a direct
function of product efficiency. With
regard to the NPV, two inputs (the perunit total installed cost and the per-unit
annual operating cost), both depend on
efficiency. The per-unit total installed
cost is a direct function of efficiency
while the per-unit annual operating
cost, because it is a direct function of
the per-unit energy (and water)
consumption, is indirectly dependent
on product efficiency.
As first discussed in section II.G.2.d
on the development of base case
efficiencies, for each of the four
appliance products, DOE, using data
provided by AHAM, based its
development of the product efficiencies
in the base case on the assignment of
equipment efficiencies in the year 2005.
The year 2005 is the latest year for
which AHAM provided product
efficiency data. In other words, DOE
determined the distribution of product
efficiencies currently in the marketplace
to develop a shipment-weighted energy
efficiency for the year 2005. For
dehumidifiers, it is important to
reiterate that DOE estimated that the
product efficiencies in the base case for
the 25.00 pints/day and less, 25.01–
35.00 pints/day, and the 45.01–54.00
pints/day product classes were
equivalent to those developed for the
35.01–45.00 pints/day class. DOE also
estimated the base case product
efficiencies developed for the 54.01–
74.99 product class could be applied to
the 75.00 pints/day and greater product
class.
Using the shipment-weighted
efficiency for the year 2005 as a starting
point, DOE developed base case
forecasted efficiencies based on
estimates of future efficiency growth.
For the period spanning 2005–2012
(2012 being the estimated effective date
of a new standard), DOE estimated that
there would be no growth in shipmentweighted efficiency (i.e., no change in
the distribution of product efficiencies).
With the exception of dishwashers
(discussed below), because there are no
historical data to indicate how product
efficiencies have changed over time,
DOE estimated that forecasted
efficiencies would remain frozen at the
2012 efficiency level until the end of the
forecast period (30 years after the
effective date (i.e., 2042)). Although
DOE recognizes the possibility that
product efficiencies may change over
time, DOE is not in a position to
speculate as to how these product
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efficiencies may change without
historical information. DOE did forecast
the market share of gas standard ranges
equipped with standing pilot lights to
estimate the impact of eliminating
standing pilot lights for gas cooktops
and gas standard ovens.
In the case of dishwashers, historical
data show that shipment-weighted
efficiencies have grown at an average
annual rate of approximately two
percent since 1980. As discussed earlier,
some of this efficiency gain during the
1990s is likely attributable to the Energy
Star program. However, historical data
also show that the consumer dishwasher
retail price has dropped considerably
(almost 50 percent) over the same time
period. Because the per-unit installed
cost (or consumer retail price) is tied to
efficiency, using an efficiency growth of
two percent per year would be expected
to result in ever-increasing dishwasher
retail prices over time. However, since
forecasting an increasing retail price is
counter to the historical data, DOE
believes that the most plausible
assumption is that dishwasher
efficiencies will remain frozen at the
2012 efficiency level until the end of the
forecast period.
For its determination of standardscase forecasted efficiencies, DOE used a
‘‘roll-up’’ scenario to establish the
shipment-weighted efficiency for the
year that standards would become
effective (i.e., 2012). DOE believed that
product efficiencies in the base case,
which did not meet the standard level
under consideration, would ‘‘roll-up’’ to
meet the new standard level. Also, DOE
believed that all product efficiencies in
the base case that were above the
standard level under consideration
would not be affected. Using the
shipment-weighted efficiency in the
year 2012 as a starting point, DOE
developed standards case forecasted
efficiencies. For all of the four appliance
products, DOE made the same estimates
regarding forecasted standards-case
efficiencies as for the base case, namely,
that forecasted efficiencies remained
frozen at the 2012 efficiency level until
the end of the forecast period. By
maintaining the same growth rate for
forecasted efficiencies in the standards
case as in the base case (i.e., zero
growth), DOE retained a constant
efficiency difference or gap between the
two cases over the length of the forecast
period. Although frozen trends may not
reflect what happens to base case and
standards case product efficiencies in
the future, DOE believes that
maintaining a frozen efficiency
difference between the base case and
standards case provides a reasonable
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estimate of the impact that standards
have on product efficiency.
DOE specifically seeks feedback on its
estimates of forecasted base-case and
standards-case efficiencies and its view
of how standards impact product
efficiency distributions in the year that
standards take effect. This is identified
as Issue 14 under ‘‘Issues on Which
DOE Seeks Comment’’ in section IV.E of
this ANOPR.
3. National Impact Analysis Inputs
The inputs for the determination of
NES are annual energy (and water)
consumption per unit, shipments,
equipment stock, national annual
energy consumption, and site-to-source
conversion factors.
Because the annual energy (and
water) consumption per unit are directly
dependent on efficiency, DOE used the
SWEFs associated with the base case
and each standards case, in combination
with the annual energy (and water use)
data, to estimate the shipment-weighted
average annual per-unit energy (and
water) consumption under the base case
and standards cases.
The NIA uses forecasted shipments
for the base case and all standards cases.
As noted earlier, the increased total
installed cost of more-efficient
equipment causes some customers to
forego equipment purchases.
Consequently, shipments forecasted
under the standards cases are lower
than under the base case. For
dehumidifiers and microwave ovens, to
avoid the inclusion of savings due to
displaced shipments, DOE used the
standards-case shipments projection
and the standards-case stock to calculate
the annual energy consumption in the
base case. However, in the case of
dishwashers and CCWs, because DOE
explicitly accounted for the energy and
water consumption of the displaced
shipments, DOE maintained the use of
the base-case shipments to determine
the annual energy consumption in the
base case.
In the case of dishwashers, Whirlpool
and AHAM commented that an increase
in purchase price due to standards may
result in some consumers foregoing
dishwasher purchases. Any consumers
who had to switch to hand washing
would increase their energy and water
consumption, since dishwashing is
more energy and water efficient than
hand washing. (Whirlpool, No. 10 at p.
10; AHAM, No. 14 at p. 9) DOE agrees
with Whirlpool and AHAM. DOE
envisioned in its analysis that
consumers foregoing the purchase of a
new unit due to an increase in the
efficiency standard would hand wash
their dishes, and accounted for the
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energy and water consumption
associated with these consumers
switching to hand washing. Based on
the results of two recent European
studies, DOE estimated that hand
washing would use 140 percent more
energy and 350 percent more water than
dishwashing.52 53
In the case of electric and gas cooking
products, because the housing market is
fully saturated (i.e., all households have
cooking appliances), available
information suggested that standards
would neither impact shipments nor
cause shifts in electric and gas cooking
product market shares. Therefore, DOE’s
standards case shipments for electric
and gas cooking products were identical
to its base case shipments.
With regard to CCWs, MLA stated
some apartment builders would install
in-apartment washers (i.e., washers for
each apartment unit) rather than
common-area washers if the increase in
CCW purchase prices caused by
standards is too high. MLA commented
that a market switch from common-area
washers to in-apartment washers would
result in increased energy and water
consumption, since consumers would
tend to use their in-apartment washers
more frequently. (MLA, No. 8 at p. 3)
DOE did account for the drop in CCW
shipments caused by standards, but did
not factor in that builders may install
more in-apartment washers when faced
with higher CCW purchase prices.
Rather, because there is a significant
used CCW market, DOE believes that
establishments that forgo the purchase
of a CCW due to standards would
instead purchase a used clothes washer
with an efficiency equal to the baseline
level (i.e., 1.26 MEF/9.5 WF). DOE
believes that the option of purchasing
used CCWs is more likely, as used
CCWs are a less expensive option to
builders than installing in-apartment
washers.
An extensive description of the
methodology for conducting and
generating the shipments forecasts for
each of the four appliance products can
be found in Chapter 9 of the TSD.
The equipment stock in a given year
is the number of products shipped and
installed from earlier years and which
survive in the given year. The NIA
52 R. Stamminger, Badura, R., Broil, G., Dorr, S.,
and Elschendroich, A., A European Comparison of
Cleaning Dishes by Hand, 2004. University of Bonn,
Germany. Available online at: https://
www.landtechnik.uni-bonn.de/ifl_research/
ifl_research_project.php?sec=HT&no=1.
53 Market Transformation Programme—Briefing
Note. BNW16: A comparison of washing up by hand
with a domestic dishwasher, February 13, 2006.
Market Transformation Programme, United
Kingdom. Available online at: https://
www.mtprog.com/.
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spreadsheet models keep track of the
number of units shipped each year. DOE
believes that the products have an
increasing probability of retiring as they
age.
The national energy consumption is
the product of the annual energy
consumption per unit and the number
of units of each vintage. This calculation
accounts for differences in unit energy
consumption from year to year.
The site-to-source conversion factor is
the multiplicative factor DOE uses for
converting site energy consumption into
primary or source energy consumption.
In the analysis for today’s ANOPR, DOE
used annual site-to-source conversion
factors based on the version of the
National Energy Modeling System
(NEMS) that corresponds to EIA’s AEO
2006.54 These conversion factors take
into account natural gas losses from
pipeline leakage and natural gas used
for pumping energy and transportation
fuel. For electricity, the conversion
factors vary over time due to projected
changes in generation sources (i.e., the
power plant types projected to provide
electricity to the country). DOE
estimated that conversion factors remain
constant at 2030 values throughout the
remainder of the forecast. EEI stated that
mandated increases in renewable energy
use throughout the country will affect
the overall efficiency of electricity
generation, thereby resulting in less
primary energy being saved from energy
savings realized at the site. (EEI, No. 7
at p. 4) In response, we note that AEO
2006 provided a review of renewable
energy programs that were in effect in
23 States at the end of 2005. Therefore,
it is anticipated that the site-to-source
conversion factors that DOE used in its
analysis capture the effects of renewable
energy use.
The Joint Comment stated that the
NIA for dishwashers and CCWs should
include energy saved as a result of
reduced water use, including water
savings in power generation, water
pumping (particularly in the West),
water treatment, and sewage treatment.
(Joint Comment, No. 9 at pp. 3 and 5)
Multiple Water Organizations also
stated that DOE should account for the
embedded energy in water supply and
wastewater treatment when establishing
the energy savings due to increases in
54 For the standards rulemakings, DOE will
generally use the same economic growth and
development assumptions that underlie the most
current AEO published by EIA. For its
determination of site-to-source conversion factors,
DOE used the version of NEMS corresponding to
AEO 2006 for the ANOPR due to the unavailability
of the AEO 2007 version at the time DOE conducted
the NIA. For its analyses for the NOPR and final
rule, DOE is committed to using the latest available
version of NEMS.
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dishwasher and CCW efficiency.
(Multiple Water Organizations, No. 11 at
p. 2) To include the energy required for
treatment and delivery of water in the
NIA would require the development of
new analytical tools. As just noted
above, DOE currently takes savings in
site energy consumption and uses EIA’s
NEMS to calculate source energy
savings at the generation plant, using
site-to-source conversion factors from
NEMS that take into account the
economic interactions between the
energy sector and the rest of the
economy. Proper accounting of
embedded energy impacts at a national
scale, including the embedded energy
due to water savings, would require a
new version of NEMS that analyzes
spending and energy use in dozens, if
not hundreds, of economic sectors. In
addition, this version of NEMS would
need to account for shifts in spending
between these various sectors to account
for the marginal embedded energy
differences between these sectors. DOE
currently does not have access to such
a tool, nor does it have the capability to
accurately estimate the source energy
savings impacts of decreased water or
wastewater consumption and
expenditures. There are activites being
conducted or initiated by the U.S.
Geological Survey (USGS), EPA, and
DOE to study water and wastewater
issues. The USGS compiles national
water data but not at the utility level.
The EPA is sponsoring the WaterSense
Program and programs to promote
energy efficiency in water and
wastewater treatment. Finally, DOE is in
the midst of a National Energy-Water
Roadmap Program that it initiated in
2005, as requested in congressional
appropriations in FY 2005. However,
none of these activites has yet provided
the necessary sources of data or tools to
allow calculation of the embedded
energy in water. Although DOE cannot
yet determine the embedded energy in
water savings, both the LCC and PBP
analyses and the NIA do include the
economic savings from decreased water
and wastewater charges. Such economic
savings should include the economic
value of any energy savings that may be
included in the provision of consumer
water and wastewater services.
The inputs to the NPV calculation are
total installed cost per unit, annual
operating cost savings per unit, total
annual installed cost increases, total
annual operating cost savings, discount
factor, present value of increased
installed costs, and present value of
operating cost savings.
For each of the four appliance
products, the NPV calculation uses the
total installed cost per unit as a function
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of product efficiency. Because the perunit total annual installed cost is
directly dependent on efficiency, DOE
used the base case and standards case
SWEFs in combination with the total
installed costs to estimate the shipmentweighted average annual per-unit total
installed cost under the base case and
standards cases.
As first discussed in the engineering
analysis for dehumidifiers (see section
II.C.2.b), total installed cost and
efficiency relationships were defined for
a subset of the six product classes.
Therefore, for purposes of conducting
the NIA for dehumidifiers, DOE applied
the cost-efficiency data that were
developed for this product class subset
to those classes for which no costefficiency relationships were developed.
Specifically, DOE applied the costs
developed for the combined 0–35.00
pints/day class to the two individual
classes that comprise the combined
class—25.00 pints/day and less and
25.01–35.00 pints/day. Further, DOE
applied the costs developed for the
35.01–45.00 pints/day and 54.01–74.99
pints/day product classes to the 45.01–
54.00 pints/day and 75.00 pints/day and
greater product classes, respectively. In
its application of total installed costs to
those product classes where no cost data
were developed, DOE did not
interpolate or extrapolate the cost data
to account for product efficiency
differences between the classes. For
example, DOE utilized the exact same
total installed costs that were developed
for the baseline and standard levels for
the 35.01–45.00 pints/day product class
to characterize the baseline and
standard level total installed costs for
the 45.01–54.00 pints/day product class.
Chapter 10 of the ANOPR provides
additional details on DOE’s approach
for estimating the total installed costs
for the dehumidifier product classes.
DOE specifically seeks feedback on its
approach for characterizing the total
installed costs for those dehumidifier
product classes in which DOE was not
able to develop cost-efficiency
relationships. This is identified as Issue
15 under ‘‘Issues on Which DOE Seeks
Comment’’ in section IV.E of this
ANOPR.
The annual operating cost savings per
unit includes changes in the energy,
water, repair, and maintenance costs.
DOE believed there would be no
increase in maintenance and repair
costs due to standards for the four
appliance products. Therefore, for each
of the products, DOE determined the
per-unit annual operating cost savings
based only on the energy (and water)
cost savings due to a standard efficiency
level. EEI suggested that DOE should
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64499
include water and wastewater prices in
the analysis. (Public Meeting Transcript,
No. 5 at p. 231) In response, we note
that DOE determined the per-unit
annual operating cost savings by taking
the per-unit annual energy (and water)
consumption savings developed for
each product and multiplying it by the
appropriate energy (and water) price. As
described previously, DOE forecasted
the per-unit annual energy (and water)
consumption for the base case and each
standards case for all four appliance
products by freezing the consumption at
levels estimated for the year 2012. DOE
forecasted energy prices based on EIA’s
AEO 2007. DOE forecasted water prices
based on trends in the national water
price index as provided by the BLS.55
The total annual installed cost
increase is equal to the annual change
in the per-unit total installed cost
(difference between base case and
standards case) multiplied by the
shipments forecasted in the standards
case. As with the calculation of the NES,
DOE did not calculate total annual
installed costs using base case
shipments. Rather, to avoid the
inclusion of savings due to displaced
shipments in the case of dehumidifiers
and microwave ovens, DOE used the
standards case shipments projection
and, in turn, the standards case stock, to
calculate the costs. In the case of
dishwashers, DOE believes that any
consumers foregoing the purchase of a
new unit due to standards would shift
to hand washing. In the case of CCWs,
DOE believes that any drop in
shipments caused by standards would
result in the purchase of used machines.
Electric and gas cooking products are
the notable exception. For electric and
gas cooking products, because the
market is fully saturated, DOE believed
that standards would neither impact
shipments nor cause shifts in electric
and gas cooking product market shares.
Therefore, for electric and gas cooking
products, DOE used the base case
shipments to determine costs for all
standards cases.
The total annual operating cost
savings are equal to the change in the
annual operating costs (difference
between base case and standards case)
per unit multiplied by the shipments
forecasted in the standards case. As
noted above for the calculation of total
annual installed costs, DOE did not
55 U.S. Department of Labor—Bureau of Labor
Statistics. Consumer Price Indexes, Item: Water and
sewerage maintenance, Series Id:
CUUR0000SEHG01, U.S. city average (not
seasonally adjusted), 2006. Washington, DC.
Available online at: https://www.bls.gov/cpi/
home.htm#data.
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necessarily calculate operating cost
savings using the base case shipments.
DOE multiplies monetary values in
future years by the discount factor to
determine the present value. DOE
estimated national impacts using both a
three-percent and a seven-percent real
discount rate as the average real rate of
return on private investment in the U.S.
economy. DOE uses these discount rates
in accordance with guidance provided
by the Office of Management and
Budget (OMB) to Federal agencies on
the development of regulatory analysis
(OMB Circular A–4 (Sept. 17, 2003),
particularly section E, ‘‘Identifying and
Measuring Benefits and Costs’’). For the
sake of these analyses, DOE defines the
present year as 2007.
The present value of increased
installed costs is the annual installed
cost increase in each year (i.e., the
difference between the standards case
and base case), discounted to the
present, and summed for the time
period over which DOE is considering
the installation of equipment (i.e., from
the effective date of standards, 2012, to
the year 2042). The increase in total
installed cost refers to both the
incremental equipment cost and the
incremental installation cost associated
with the higher energy efficiency of
equipment purchased in the standards
case compared to the base case.
The present value of operating cost
savings is the annual operating cost
savings (i.e., the difference between the
base case and standards case),
discounted to the present, and summed
over the period from the effective date
(2012) to the time when the last unit
installed in 2042 is retired from service.
Savings are decreases in operating costs
associated with the higher energy
efficiency of equipment purchased in
the standards case compared to the base
case. Total annual operating cost
savings is the savings per unit
multiplied by the number of units of
each vintage surviving in a particular
year. Equipment consumes energy over
its entire lifetime, and for units
purchased in 2042, the consumption
includes energy consumed until the unit
is retired from service.
Table II.77 summarizes the NES and
NPV inputs to the NIA spreadsheet
model. For each input, the table gives a
brief description of the data source. For
details, see Chapter 10 of the TSD.
TABLE II.77.—NATIONAL ENERGY SAVINGS AND NET PRESENT VALUE INPUTS
Input
Data description
Shipments ...........................................................
Effective Date of Standard .................................
Base-Case Forecasted Efficiencies ....................
Annual shipments from Shipments Model. (See Chapter 9 of the TSD for more details.)
2012.
Shipment-weighted efficiency (SWEF) determined in the year 2005 for each of the four appliance products. SWEF held constant over forecast period of 2005–2042. (See Chapter 10 of
the TSD for more details.)
‘‘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 weighted-average values are a function of SWEF. (See Chapter 10 of the TSD for
more details.)
Annual weighted-average values are a function of SWEF. (See Chapter 10 of the TSD for
more details.)
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.)
No changes in repair and maintenance cost due to standards.
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.)
Conversion varies yearly and is generated by DOE/EIA’s NEMS* program (a time-series conversion factor; includes electric generation, transmission, and distribution losses).
3 and 7 percent real.
Future expenses are discounted to year 2007.
Standards-Case Efficiencies ...............................
Annual Energy Consumption per Unit ................
Total Installed Cost per Unit ...............................
Energy and Water Cost per Unit ........................
Repair Cost and Maintenance Cost per Unit .....
Escalation of Energy and Water Prices .............
Energy Site-to-Source Conversion .....................
Discount Rate .....................................................
Present Year .......................................................
* 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
Below are the NES results (and
national water savings results for
dishwashers and CCWs) for the
candidate standard levels analyzed for
the four appliance products. NES results
are cumulative to 2042 and are shown
as primary energy savings in quads.
National water savings (NWS) results
are expressed in billions of gallons. DOE
based the inputs to the NIA spreadsheet
model on weighted-average values,
yielding results that are discrete point
values, rather than a distribution of
values as in the LCC and PBP analyses.
Chapter 10 of the TSD provides
discounted NES and NWS results based
on discount rates of three and seven
percent.
Table II.78 shows the NES and NWS
results for the candidate standard levels
analyzed for standard-sized
dishwashers.
mstockstill on PROD1PC66 with PROPOSALS2
TABLE II.78.—DISHWASHERS: CUMULATIVE NATIONAL ENERGY SAVINGS AND NATIONAL WATER SAVINGS RESULTS
EF
Candidate standard level
1
2
3
4
5
6
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
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NES
quads
NWS
billion gallons
0.46
0.58
0.62
0.65
0.72
0.80
0.09
0.35
0.61
0.86
1.11
1.54
72
271
458
595
659
808
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TABLE II.78.—DISHWASHERS: CUMULATIVE NATIONAL ENERGY SAVINGS AND NATIONAL WATER SAVINGS RESULTS—
Continued
Candidate standard level
EF
NES
quads
NWS
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
Candidate
standard level
1
2
3
4
5
.......................
.......................
.......................
.......................
.......................
≤ 25.00
25.01–35.00
NES
quads
EF
1.10
1.20
1.25
1.30
1.38
EF
0.01
0.02
0.02
0.02
0.03
35.01–45.00
NES
quads
1.25
1.30
1.35
1.40
1.45
0.01
0.02
0.04
0.05
0.06
45.01–54.00
NES
quads
EF
1.35
1.40
1.45
1.50
1.74
NES
quads
EF
0.01
0.02
0.04
0.05
0.13
1.45
1.50
1.55
1.60
2.02
0.01
0.02
0.04
0.05
0.18
≤ 75.00
54.01–74.99
NES
quads
EF
1.55
1.60
1.65
1.70
1.80
NES *
quads
NES
quads
0.00
0.00
0.00
0.00
0.00
EF
0.01
0.02
0.05
0.07
0.12
ALL
0.04
0.11
0.18
0.25
0.53
2.38
2.50
2.55
2.60
2.75
* NES greater than zero but less than 0.005 quads.
Tables II.80 and II.81 show the NES
results for the candidate standard levels
analyzed for cooktops and ovens,
respectively.
TABLE II.80.—COOKTOPS: CUMULATIVE NATIONAL ENERGY SAVINGS RESULTS
Electric coil
Candidate standard level
Electric smooth
Gas
EF
1 ...............................................................................................................
2 ...............................................................................................................
NES
quads
EF
NES
quads
0.769
................
0.04
................
0.753
................
0.02
................
EF
NES
quads
0.399
0.420
0.10
0.15
TABLE II.81.—OVENS: CUMULATIVE NATIONAL ENERGY SAVINGS RESULTS
Elec standard
Candidate standard level
Elec self-clean
EF
1 * .....................................................................
2 .......................................................................
3 .......................................................................
4 .......................................................................
5 .......................................................................
6 .......................................................................
1a * ...................................................................
NES
quads
EF
NES
quads
0.1113
0.1163
0.1181
0.1206
0.1209
................
................
0.03
0.05
0.06
0.07
0.08
................
................
0.1102
0.1123
................
................
................
................
................
0.01
0.04
................
................
................
................
................
Gas standard
Gas self-clean
NES
quads
EF
0.0536
0.0566
0.0572
0.0593
0.0596
0.0600
0.0583
EF
0.04
0.07
0.08
0.09
0.09
0.10
0.13
NES
quads
0.0625
0.0627
0.0632
................
................
................
................
0.09
0.09
0.10
................
................
................
................
* 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.
mstockstill on PROD1PC66 with PROPOSALS2
Table II.82 shows the NES results for
the candidate standard levels analyzed
for microwave ovens.
TABLE II.82.—MICROWAVE OVENS: CUMULATIVE NATIONAL ENERGY SAVINGS RESULTS
Candidate standard level
1 ...............................................................................................................................................................................
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EF
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0.19
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TABLE II.82.—MICROWAVE OVENS: CUMULATIVE NATIONAL ENERGY SAVINGS RESULTS—Continued
Candidate standard level
NES
quads
EF
2 ...............................................................................................................................................................................
3 ...............................................................................................................................................................................
4 ...............................................................................................................................................................................
0.588
0.597
0.602
0.20
0.25
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
Candidate standard level
1
2
3
4
5
6
MEF/WF
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
Below are the NPV results for the
candidate standard levels considered for
the product classes of each of the four
appliance products. Results are
cumulative and are shown as the
discounted value of these savings in
dollar terms. The present value of
increased total installed costs is the total
installed cost increase (i.e., the
difference between the standards case
and base case), discounted to the
present, and summed over the time
period in which DOE evaluates the
impact of standards (i.e., from the
effective date of standards (2012) to the
year 2042).
Savings are decreases in operating
costs (including energy and water)
associated with the higher energy
efficiency of equipment purchased in
the standards case compared to the base
case. Total operating cost savings are the
savings per unit multiplied by the
number of units of each vintage (i.e., the
year of manufacture) surviving in a
particular year. Equipment consumes
1.42/9.50
1.60/8.50
1.72/8.00
1.80/7.50
2.00/5.50
2.20/5.10
NES
quads
NWS
billion gallons
0.12
0.21
0.26
0.30
0.36
0.43
0
233
350
466
933
1050
energy and must be maintained over its
entire lifetime. For units purchased in
2042, the operating cost includes energy
and water consumed until the last unit
is retired from service.
The tables below show the NPV
results for the candidate standard levels
analyzed for each of the four appliance
products, based on discount rates of
three and seven percent.
Table II.84 shows the NPV results for
the candidate standard levels analyzed
for standard-sized dishwashers.
TABLE II.84.—DISHWASHERS: CUMULATIVE NET PRESENT VALUE RESULTS BASED ON SEVEN-PERCENT AND THREEPERCENT DISCOUNT RATES
NPV
Candidate standard level
mstockstill on PROD1PC66 with PROPOSALS2
1
2
3
4
5
6
7
EF
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
7% Discount
rate
billion 2006$
0.46
0.58
0.62
0.65
0.72
0.80
1.11
Tables II.85 and II.86 show the NPV
results for the candidate standard levels
analyzed for dehumidifiers.
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0.38
1.29
1.73
0.90
¥2.75
¥7.25
¥7.28
3% Discount
rate
billion 2006$
0.94
3.29
4.72
3.61
¥2.94
¥10.77
¥8.16
64503
Federal Register / Vol. 72, No. 220 / Thursday, November 15, 2007 / Proposed Rules
TABLE II.85.—DEHUMIDIFIERS: CUMULATIVE NET PRESENT VALUE RESULTS BASED ON A SEVEN-PERCENT DISCOUNT
RATE
≤ 25.00
Candidate
standard level
1
2
3
4
5
.......................
.......................
.......................
.......................
.......................
25.01–35.00
NPV
@ 7%
billion
2006$
EF
1.10
1.20
1.25
1.30
1.38
NPV
@ 7%
billion
2006$
EF
0.01
0.05
0.05
0.04
0.05
35.01–45.00
1.25
1.30
1.35
1.40
1.45
0.02
0.06
0.07
0.07
0.08
45.01–54.00
NPV
@ 7%
billion
2006$
EF
1.35
1.40
1.45
1.50
1.74
NPV
@ 7%
billion
2006$
EF
0.01
0.03
0.04
0.03
0.00
1.45
1.50
1.55
1.60
2.02
≥75.00
54.01–74.99
NPV
@ 7%
billion
2006$
EF
0.01
0.03
0.04
0.04
0.21
1.55
1.60
1.65
1.70
1.80
NPV *
@ 7%
billion
2006$
EF
0.02
0.05
0.10
0.11
0.19
ALL
NPV
@ 7%
billion
2006$
0.00
0.00
0.00
0.00
0.00
0.08
0.21
0.31
0.31
0.54
2.38
2.50
2.55
2.60
2.75
* NPV greater than zero but less than $0.005 billlion.
TABLE II.86.—DEHUMIDIFIERS: CUMULATIVE NET PRESENT VALUE RESULTS BASED ON A THREE-PERCENT DISCOUNT
RATE
≤ 25.00
Candidate
standard level
1
2
3
4
5
.......................
.......................
.......................
.......................
.......................
25.01–35.00
NPV
@ 3%
billion
2006$
EF
1.10
1.20
1.25
1.30
1.38
NPV
@ 3%
billion
2006$
EF
0.04
0.11
0.13
0.12
0.15
1.25
1.30
1.35
1.40
1.45
Tables II.87 and II.88 show the NPV
results for the candidate standard levels
35.01–45.00
0.04
0.14
0.20
0.21
0.25
45.01–54.00
NPV
@ 3%
billion
2006$
EF
1.35
1.40
1.45
1.50
1.74
NPV
@ 3%
billion
2006$
EF
0.04
0.09
0.13
0.14
0.19
1.45
1.50
1.55
1.60
2.02
≥75.00
54.01–74.99
NPV
@ 7%
billion
2006$
EF
0.04
0.09
0.14
0.16
0.66
1.55
1.60
1.65
1.70
1.80
NPV *
@ 3%
billion
2006$
EF
0.06
0.12
0.27
0.32
0.55
ALL
NPV
@ 3%
billion
2006$
0.00
0.01
0.01
0.01
0.01
0.22
0.57
0.87
0.96
1.81
2.38
2.50
2.55
2.60
2.75
analyzed for cooktops and ovens,
respectively.
TABLE II.87.—COOKTOPS: CUMULATIVE NET PRESENT VALUE RESULTS BASED ON SEVEN-PERCENT AND THREE-PERCENT
DISCOUNT RATES
Electric coil
Electric smooth
Gas
Candidate standard
level
EF
NPV @
7% billion
2006$
NPV @
3% billion
2006$
EF
NPV @
7% billion
2006$
NPV @
3% billion
2006$
1 .................................
2 .................................
0.769
..................
0.05
..................
0.18
..................
0.753
..................
¥7.48
..................
¥14.28
..................
NPV @
7% billion
2006$
EF
NPV @
3% billion
2006$
0.29
¥0.65
0.67
¥0.98
0.399
0.420
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
EF
NPV
@ 7%
billion
2006$
NPV
@ 3%
billion
2006$
EF
NPV
@ 7%
billion
2006$
NPV
@ 3%
billion
2006$
EF
NPV 2
@ 7%
billion
2006$
NPV
@ 35
billion
2006$
EF
NPV 2
@ 7%
billion
2006$
NPV 2
@ 3%
billion
2006$
0.1113
0.1163
0.1181
0.1206
0.1209
............
............
0.06
0.08
0.03
¥0.81
¥0.88
............
............
0.17
0.27
0.19
¥1.39
¥1.52
............
............
0.1102
0.1123
............
............
............
............
............
¥0.28
¥2.87
............
............
............
............
............
¥0.53
¥5.41
............
............
............
............
............
0.0536
0.0566
0.0572
0.0593
0.0596
0.0600
0.0583
0.10
0.11
0.11
¥0.33
¥0.36
¥0.42
0.35
0.24
0.34
0.34
¥0.45
¥0.50
¥0.62
0.92
0.0625
0.0627
0.0632
............
............
............
............
¥0.01
¥0.12
¥0.14
............
............
............
............
0.18
0.02
¥0.05
............
............
............
............
mstockstill on PROD1PC66 with PROPOSALS2
Candidate standard level
1 * .....................................
2 .......................................
3 .......................................
4 .......................................
5 .......................................
6 .......................................
1a * ...................................
* 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.
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Federal Register / Vol. 72, No. 220 / Thursday, November 15, 2007 / Proposed Rules
Tables II.89 shows the NPV results for
the candidate standard levels analyzed
for microwave ovens.
TABLE II.89.—MICROWAVE OVENS: CUMULATIVE NET PRESENT VALUE RESULTS BASED ON SEVEN-PERCENT AND THREEPERCENT DISCOUNT RATES
NPV
Candidate standard level
1
2
3
4
EF
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
7% Discount
rate
billion 2006$
0.586
0.588
0.597
0.602
3% Discount
rate
billion 2006$
¥1.40
¥3.52
¥6.58
¥10.35
¥2.48
¥6.51
¥12.28
¥19.40
Table II.90 shows the NPV results for
the candidate standard levels analyzed
for CCWs.
TABLE II.90.—COMMERCIAL CLOTHES WASHERS: CUMULATIVE NET PRESENT VALUE RESULTS BASED ON SEVENPERCENT AND THREE-PERCENT DISCOUNT RATES
NPV
Candidate standard level
1
2
3
4
5
6
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
...................................................................................................................................................
J. Life-Cycle Cost Subgroup Analysis
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MEF/WF
The LCC subgroup analysis evaluates
impacts of standards on identifiable
groups of customers, such as different
population groups of consumers or
different business types, which may be
disproportionately affected by any
national energy efficiency standard
level. In the NOPR phase of this
rulemaking, DOE will analyze the LCCs
and PBPs for customers that fall into
such groups. The analysis will
determine whether any particular group
of consumers would be adversely
affected by any of the trial standard
levels.
Also, DOE plans to examine
variations in energy prices and energy
use that might affect the NPV of a
standard for customer sub-populations.
To the extent possible, DOE will obtain
estimates of the variability of each input
parameter and consider this variability
in the calculation of customer impacts.
Variations in energy use for a particular
product depend on a number of factors,
such as climate and type of user. DOE
plans to perform sensitivity analyses to
consider how differences in energy use
will affect subgroups of customers.
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DOE will determine the effect on
customer subgroups using the LCC
spreadsheet model. NWPCC stated that
the Monte Carlo approach, if
implemented in the LCC and PBP
analyses, can be used to conduct the
subgroup analysis. NWPCC stated that
the Monte Carlo approach is suitable for
identifying different subgroups, such as
regional subgroups, that may be
impacted differently by standards.
(Public Meeting Transcript, No. 5 at p.
235) As described in section II.G on the
LCC and PBP analyses, DOE used a
Monte Carlo approach to conduct the
LCC and PBP analyses. The spreadsheet
model it used for the LCC analysis,
which incorporates the use of Monte
Carlo sampling, can be used with
different data inputs. The standard LCC
analysis includes various customer
types that use the four appliance
products. DOE can analyze the LCC for
any subgroup, such as low-income
consumers, by using the LCC
spreadsheet model and sampling only
that subgroup. Details of this model are
explained in section II.G.
DOE received several comments as to
which subgroups it should analyze. EEI
suggested that DOE consider low-
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income and senior subgroups. It stated
that low-income consumers are more
likely to use CCWs, and that seniors
tend to use dishwashers and cooking
products less frequently than the overall
population. (EEE, No. 7 at p. 6) For
CCWs, ALS stated that DOE should
consider low-income consumers and
senior citizens, especially if standards
cause an increase in vending prices.
ALS stated that the resulting increase in
vending price would lead to less
available disposable income for lowincome and senior consumers to use
commercial laundry. MLA expressed
the same concerns, but only for lowincome consumers. (Public Meeting
Transcript, No. 5 at p. 237; MLA, No. 8
at p. 2)
GE and PG&E suggested that DOE
consider regional subgroups. GE stated
that regional subgroups for dishwashers
and cooking products would be
appropriate because the regional
saturations for both sets of products
vary significantly. (Public Meeting
Transcript, No. 5 at pp. 240–241) PG&E
stated that DOE should consider
regional subgroups for dehumidifiers.
(Public Meeting Transcript, No. 5 at p.
237) Lastly, the EPA thought it would be
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prudent to consider subgroups that are
not served by water and sewer service
providers, but by wells and septic
systems. EPA believes that these
consumers use less water than the
overall population. (Public Meeting
Transcript, No. 5 at p. 234)
DOE intends to analyze the impacts of
candidate standards on low-income and
senior subgroups. DOE also will
evaluate whether regional variations are
significant enough to warrant an
analysis of regional subgroups for
dishwashers, dehumidifiers, and
cooking products. In its analysis of
dishwashers and CCWs, DOE will also
consider evaluating those consumer
subgroups not served by water and
sewer. In its analysis of subgroups, DOE
will be especially sensitive to purchase
price increases (‘‘first-cost’’ increases) to
avoid negative impacts on identifiable
population groups such as low-income
households (in the case of residential
products) or small businesses with low
annual revenues (in the case of CCWs),
which may not be able to afford a
significant increase in product or
equipment prices.
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K. Manufacturer Impact Analysis
The purpose of the MIA is to identify
the likely impacts of energy
conservation standards on
manufacturers. DOE has begun and will
continue to conduct this analysis with
input from manufacturers and other
interested parties. DOE will
subsequently apply a similar
methodology to its evaluation of
standards. During the MIA, DOE will
consider financial impacts and a wide
range of quantitative and qualitative
industry impacts that might occur
following the adoption of a standard.
For example, if DOE adopts a particular
standard level, it could require changes
to manufacturing practices. DOE will
identify and understand these impacts
through interviews with manufacturers
and other stakeholders during the NOPR
stage of its analysis.
Recently, DOE announced changes to
the MIA format through a report issued
to Congress on January 31, 2006 (as
required by section 141 of EPACT 2005),
entitled ‘‘Energy Conservation
Standards Activities.’’ Previously, DOE
did not report any MIA results during
the ANOPR phase of energy
conservation standards rulemakings;
however, under this new format, DOE
has collected, evaluated, and reported
some preliminary information and data
in section II.K.6 of this ANOPR. For
further information on the MIA process,
the analysis, and the results, please refer
to Chapter 12 of the TSD.
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DOE conducts the MIA in three
phases. In Phase I, DOE creates an
industry profile to characterize the
industry, and conducts a preliminary
MIA to identify important issues that
require consideration. Results of the
Phase I analysis are presented in
Chapter 12 of the TSD. In Phase II, DOE
prepares an industry cash flow model
and an interview questionnaire to guide
subsequent discussions. In Phase III,
DOE interviews manufacturers, and
assesses the impacts of standards both
quantitatively and qualitatively. It
assesses industry and subgroup cash
flow and net present value through use
of the Government Regulatory Impact
Model (GRIM). DOE then assesses
impacts on competition, manufacturing
capacity, employment, and regulatory
burden based on manufacturer
interview feedback and discussions.
Results of the Phase II and Phase III
analyses are presented in the NOPR
TSD.
1. Sources of Information for the
Manufacturer Impact Analysis
Many of the analyses described above
provide important inputs to the MIA.
Such inputs include manufacturing
costs and prices from the engineering
analysis, retail price forecasts, and
shipments forecasts. DOE supplements
this information with company financial
data and other information gathered
during interviews with manufacturers.
As discussed below, this interview
process plays a key role in the MIA
because it allows interested parties to
privately express their views on
important issues. To preserve
confidentiality, DOE aggregates these
perspectives across manufacturers,
creating a combined opinion or estimate
for use in its analyses. This process
enables DOE to incorporate sensitive
information from manufacturers in the
rulemaking process without specifying
precisely which manufacturer provided
a certain set of data.
DOE conducts detailed interviews
with manufacturers to gain insight into
the range of potential impacts of
standards. During the interviews, DOE
typically solicits both quantitative and
qualitative information on the potential
impacts of efficiency levels on sales,
direct employment, capital assets, and
industrial competitiveness. DOE prefers
an interactive interview process, rather
than a written response to a
questionnaire, because it helps clarify
responses and identify additional
issues. Before each interview, DOE
circulates a draft document showing its
estimates of financial parameters based
on publicly available information, such
as filings with the SEC, articles in trade
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publications, etc. DOE subsequently
solicits comments and suggestions on
these estimates during the interviews.
DOE asks interview participants to
identify any confidential information
that they have provided, either orally or
in writing. DOE considers all
information collected, as appropriate, in
its decision-making process. However,
DOE does not make confidential
information available in the public
record. DOE also asks participants to
identify all information that they wish
to have included in the public record,
but that they do not want to have
associated with their interview or
company; DOE incorporates such
information into the public record, but
reports it without attribution.
Finally, DOE collates the completed
interview questionnaires and prepares a
summary of the major issues. For more
detail on the methodology used in the
MIA, refer to Chapter 12 of the TSD.
2. Industry Cash Flow Analysis
The industry cash flow analysis relies
primarily on the GRIM, which helps
identify the effects of various efficiency
regulations and other regulations on
manufacturers. The basic structure of
the GRIM is a standard annual cash flow
analysis that uses price and volume
information as an input, builds on
fundamental base cost information, and
accepts a set of regulatory conditions as
changes in costs and investments. DOE
uses the GRIM to analyze the financial
impacts of more stringent energy
conservation standards on the industry.
The GRIM analysis uses several
factors to determine annual cash flows
from a new standard: (1) Annual
expected revenues; (2) manufacturer
costs including cost of goods sold; (3)
depreciation; (4) research and
development; (5) selling, general, and
administrative expenses; (6) taxes; and
(7) conversion capital expenditures.
DOE compares the results against base
case projections that involve no new
standards. The financial impact of new
standards is the difference between the
two sets of discounted annual cash
flows. For more information on the
industry cash flow analysis, refer to
Chapter 12 of the TSD.
3. Manufacturer Subgroup Analysis
Industry cost estimates are not
adequate to assess differential impacts
among subgroups of manufacturers. For
example, small and niche
manufacturers, or manufacturers whose
cost structure differs significantly from
the industry average, could experience a
disproportionate impact due to
standards changes. Because DOE cannot
consider the impact on every firm
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individually, the results of the industry
characterization are typically used to
group manufacturers exhibiting similar
characteristics.
During MIA interviews, DOE
discusses the potential subgroups and
subgroup members it has identified for
the analysis. DOE encourages the
manufacturers to recommend subgroups
or characteristics that are appropriate
for the subgroup analysis. For more
detail on the manufacturer subgroup
analysis, refer to Chapter 12 of the TSD.
4. Competitive Impacts Assessment
Another factor which DOE must
consider in standard setting is whether
a new standard is likely to reduce
industry competition, and the Attorney
General must determine the impacts, if
any, of reduced competition. DOE
makes a determined effort to gather and
report firm-specific financial
information and impacts. In particular,
the competitive impacts assessment
focuses on the impacts of new energy
efficiency standards on smaller
manufacturers. DOE bases this
assessment on manufacturing cost data
and on information collected from
interviews with manufacturers. Hence,
manufacturer interviews also focus on
gathering information to help assess
asymmetrical cost increases to some
manufacturers, increased proportions of
fixed costs that could increase business
risks, and potential barriers to market
entry (e.g., proprietary technologies).
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5. Cumulative Regulatory Burden
DOE recognizes and seeks to mitigate
the overlapping effects on
manufacturers of new or revised DOE
standards and other regulatory actions
affecting the same equipment. Thus,
DOE analyzes and considers the impact
on manufacturers of multiple, productspecific regulatory actions.
Based on its own research and
discussions with manufacturers, DOE
has identified several regulations
relevant to dishwasher, dehumidifier,
cooking product, and CCW
manufacturers, including existing or
new standards, the phase-out of
hydrochlorofluorocarbon refrigerants,
the prohibition of phosphate-containing
detergents in some jurisdictions,
standards for other products made by
dishwasher, dehumidifier, cooking
product, and CCW manufacturers,
including State standards, and foreign
energy conservation standards.
(Although foreign standards do not
directly affect products entering the
U.S., they do impact manufacturer
operations, in that they represent
additional business expenses for
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manufacturers selling outside the U.S.
market.)
DOE will study the potential impacts
of these cumulative burdens in greater
detail during the MIA conducted during
the NOPR phase.
6. Preliminary Results for the
Manufacturer Impact Analysis
DOE conducted a preliminary
evaluation of the impact of potential
new regulations for the products to be
covered by this rulemaking on
manufacturer financial performance,
manufacturing capacity and
employment levels, and product utility
and innovation. A primary focus was to
identify the cumulative burden that
industry faces from the overlapping
effect of new or recent energy
conservation standards and/or other
regulatory action affecting the same
product or industry.
The primary sources of information
for this analysis were telephone
interviews with manufacturers of
dishwashers, dehumidifiers, and CCWs
carried out during the first quarter of FY
2007. To maintain confidentiality, DOE
did not identify the individual
manufacturers that disclosed
information. Instead, the evaluation
only reports aggregated information and
does not disclose sensitive information
or identify company-specific
information. For the preliminary MIA,
DOE conducted interviews with
manufacturers primarily to identify key
issues and gain insights into the
qualitative impacts of energy
conservation standards. For each
product, DOE used an interview guide
to gather responses from multiple
manufacturers on several issues. All the
interview guides covered the same
general topic areas, but DOE adapted
them, as appropriate, to address each
product category. (Copies of the
interview guides for CCW,
dehumidifier, and dishwasher
manufacturers are contained in
Appendix B of the TSD.)
However, DOE did not interview
cooking product manufacturers at this
stage due to feedback from stakeholders
such as AHAM and several cooking
product manufacturers, suggesting that
DOE limit its efforts to updating the
extensive 1996 cooking product
technical analysis; these stakeholders
reasoned that such an update would
properly represent prices, design
options, and manufacturer issues for
products covered by the present
rulemaking. Thus, DOE updated the
1996 cooking products analysis and
plans to interview manufacturers of
cooking products during the NOPR stage
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of this rulemaking to get feedback on its
analysis and results.
During the course of the preliminary
MIA, DOE interviewed manufacturers
representing over 80 percent of
domestic dishwasher sales, 66 percent
of domestic dehumidifier sales, and
practically 100 percent of CCW sales.
DOE used these same interviews to
review the engineering analysis cost and
performance data contained in chapter 5
of the TSD. However, during the course
of the MIA interviews, focus of the
discussion was shifted from technologyrelated topics to business-related topics.
DOE’s objective was to become familiar
with each company’s particular market
approach and financial structure, and its
concerns and issues related to new
efficiency standards. Most of the
information received from these
meetings is protected by non-disclosure
agreements and resides with DOE’s
contractors. Before each visit, DOE
provided company representatives with
an interview guide that included the
topics that DOE hoped to cover. The
topics included:
• Key issues—the most important
things to consider in setting new
standards from the perspective of
manufacturers;
• Product mix—effects of potential
standard levels on a manufacturer’s
product mix;
• Profitability—insights into market
forces which could affect a
manufacturer’s profitability;
• Conversion costs—estimates of
costs required to meet new standards;
• Manufacturing capacity and
employment levels—decisions to
upgrade, remodel, or relocate existing
facilities and resulting changes in
employment patterns resulting from
new energy efficiency standards;
• Market share and industry
consolidation—changes to competitive
dynamics of the marketplace and the
possible consequences for consumers;
• Product utility and innovation—
effect of standards on product utility
and innovation; and
• Cumulative burden—assessment of
the level and timing of investments
manufacturers are expecting to incur as
a result of other regulations.
Additionally, DOE often introduced,
entertained, and discussed other topics
during the course of the interviews,
such as the impact of various design
options on energy efficiency, how
testing standards and usage patterns
vary by market, and performance issues.
Perhaps the most important aspect of
the preliminary MIA was the
opportunity it created for DOE to
identify key manufacturer issues early
in the development of new standards.
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During the interviews, DOE engaged the
manufacturers in a discussion of their
perception of the key issues in the
rulemaking. DOE then added these key
issues to the list of questions and topics
explored during the interviews.
The concerns that rose to the level of
key issues in the opinion of dishwasher
manufacturers included: (1) The
potential elimination of entry-level
dishwashers from the market; (2) a
possible reduction in dishwasher
washing performance; (3) the increased
likelihood of consumers hand washing
and pre-rinsing dishes; and (4) the
potential relocation of production
facilities overseas.
The key issues expressed by
dehumidifier manufacturers included:
(1) The ability to pass cost increases on
to consumers; (2) increased pressure
from foreign competition; and (3) the
ability to maintain Energy Star product
offerings.
The key issues for CCW
manufacturers included: (1) The risk of
eliminating vertical-axis washers from
the market; (2) reduced product
shipments due to a move away from
central laundry facilities to in-unit
residential laundry and prolonging the
life of existing equipment; (3) reduced
cleaning performance of some energysaving design options; (4) the possible
relocation of production facilities
outside the country; and (5) the
potential for industry consolidation
and/or the elimination of the lowvolume manufacturer.
For more preliminary results for the
MIA, such as other impacts on financial
performance, impacts on product utility
and performance, and additional details
on the impacts of cumulative regulatory
burden, refer to Chapter 12 of the TSD.
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L. Utility Impact Analysis
The utility impact analysis estimates
the effects on the utility industry of
reduced energy consumption due to
improved appliance efficiency. The
analysis compares modeling results for
the base case with results for each
candidate standards case. For each of
the four appliance products, the
analysis will consist of forecasted
differences between the base and
standards cases for electricity
generation, installed capacity, sales, and
prices. For CCWs, as well as residential
dishwashers and cooking products, the
analysis also will examine differences in
sales of natural gas.
To estimate these effects of proposed
standards on the electric and gas utility
industries, DOE intends to use a variant
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of the EIA’s NEMS.56 EIA uses NEMS to
produce its AEO. NEMS produces a
widely recognized reference case
forecast for the United States and is
available in the public domain. DOE
will use a variant known as NEMSBuilding Technologies (BT) to provide
key inputs to the analysis.
The use of NEMS for the utility
impact analysis offers several
advantages. As the official DOE energy
forecasting model, NEMS relies on a set
of premises that are transparent and
have received wide exposure and
commentary. NEMS allows an estimate
of the interactions between the various
energy supply and demand sectors and
the economy as a whole. The utility
impact analysis will determine the
changes for electric utilities in installed
capacity and in generation by fuel type
produced by each candidate standard
level, as well as changes in gas and
electricity sales to the commercial sector
(for CCWs) and the consumer sector (for
residential dishwashers, dehumidifiers,
and cooking products). (Because
dehumidifiers neither operate on gas
nor rely on water heated by gas,
standards for this product do not affect
gas sales.)
DOE plans to conduct the utility
impact analysis as a variant of the
NEMS used to produce the AEO 2007,
applying the same basic set of premises.
For example, the utility impact analysis
uses the operating characteristics (e.g.,
energy conversion efficiency, emissions
rates) of future electricity generating
plants and the prospects for natural gas
supply as specified in the AEO reference
case.
DOE will also explore deviations from
some of the AEO 2007 reference case
premises to represent alternative
futures. Two alternative scenarios use
the high- and low-economic-growth
cases of AEO 2007. (The reference case
corresponds to medium growth.) The
high-economic-growth case uses higher
projected growth rates for population,
labor force, and labor productivity,
resulting in lower predicted inflation
and interest rates relative to the
reference case. The opposite is true for
the low-growth case. Starting in 2012,
the high-growth case predicts growth in
per capita gross domestic product of 3.4
56 For more information on NEMS, please refer to
the U.S. Department of Energy, Energy Information
Administration documentation. A useful summary
is National Energy Modeling System: An Overview
2003, DOE/EIA–0581(2003), March 2003. DOE/EIA
approves use of the name NEMS to describe only
an official version of the model without any
modification to code or data. Because this analysis
entails some minor code modifications and the
model is run under various policy scenarios that are
variations on DOE/EIA assumptions, in this
analysis, DOE refers to it by the name NEMS–BT.
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percent per year, compared with 2.9
percent per year in the reference case
and 2.2 percent per year in the lowgrowth case. As part of varying supplyside growth determinants in these cases,
AEO 2007 also varies the forecasted
energy prices for all three economic
growth cases. Different economic
growth cases affect the rate of growth of
electricity demand.
The electric utility industry analysis
will consist of NEMS–BT forecasts for
generation, installed capacity, sales, and
prices. The gas utility industry analysis
will consist of NEMS–BT forecasts of
sales and prices. The NEMS–BT
provides reference case load shapes for
several end uses, including residential
dishwashing and cooking, but does not
provide load shapes 57 specifically for
dehumidifiers and CCWs. Because most
of the energy consumed by clothes
washers is expended on water heating,
DOE intends to use NEMS–BT’s
commercial water-heating load shapes
to characterize CCWs. For
dehumidifiers, because this end use is
operated in a similar manner to airconditioning equipment, DOE intends to
use NEMS–BT residential space-cooling
load shapes to characterize it. For
electrical end uses, NEMS–BT uses
predicted growth in demand for each
end use to build up a projection of the
total electrical system load growth for
each region, which it uses in turn to
predict the necessary additions to
capacity. For both electrical and gas end
uses, NEMS–BT accounts for the
implementation of efficiency standards
by decrementing the appropriate
reference case load shape. DOE will
determine the size of the decrement
using data for the per-unit energy
savings developed in the LCC and PBP
analyses (see Chapter 8 of the TSD) and
the forecast of shipments developed for
the NIA (see Chapter 9 of the TSD). For
more information on the utility impact
analysis, refer to Chapter 13 of the TSD.
EEI commented that an accurate
assessment of electric utility impacts
requires an evaluation of the type of
load of the appliance (i.e., whether the
load is primarily during system peak
demand or off-peak). (Public Meeting
Transcript, No. 5 at p. 264) In response,
we note that in 2001, EIA conducted a
review of its end-use load shapes and
updated them to better reflect actual end
use behavior.58 As a result, DOE has
57 The ‘‘load shape’’ defines how the product uses
energy on an hourly basis over the course of the
day.
58 Alternative Sectoral Load Shapes for NEMS,
Department of Energy—Energy Information
Administration, Washington, DC, August 2001.
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confidence that the NEMS–BT provides
a good representation of the type of
loads exhibited by its end uses.
With regard to gas utility impacts, the
AGA commented that NEMS–BT does
not address these impacts in a
meaningful way. AGA suggested that
DOE should conduct a workshop on
proposed modeling approaches to
analyzing gas utility impacts. (AGA, No.
12 at p. 3) As noted above, NEMS–BT
allows for the determination of changes
in gas sales due to efficiency standards.
Therefore, DOE’s gas utility impact
analysis goes no further than assessing
the impact on gas sales.
Since the AEO 2007 version of NEMS
forecasts only to the year 2030, DOE
would be required to extrapolate results
for such forecasts to 2042. DOE
conducts an extrapolation to 2042 to be
consistent with the analysis period
being used by DOE in the NIA.
However, DOE has determined that it
will not be feasible to extend the
forecast period of NEMS–BT for the
purposes of this analysis, in part
because EIA does not have an approved
method for extrapolation of many
outputs beyond 2030. While it might
seem reasonable in general to make
simple linear extrapolations of results,
in practice this is not advisable because
outputs could be contradictory. For
example, changes in the fuel mix
implied by extrapolations of those
outputs could be inconsistent with the
extrapolation of marginal emissions
factors. An analysis of various trends is
not necessary and would involve a great
deal of uncertainty. Therefore, for all
extrapolations beyond 2030, DOE
intends to use simple replications of
year 2030 results. While these may seem
unreasonable in some instances, in this
way results are guaranteed to be
consistent. As with the AEO reference
case in general, the implicit premise is
that the regulatory environment does
not deviate from the current known
situation during the extrapolation
period. Only changes that have been
announced with date-certain
introduction are included in NEMS–BT.
Both EEI and SPU stated that DOE
should factor impacts to water and
wastewater utilities into the utility
impact analysis. SPU claimed that, in
some areas of the country, water is
becoming a limited commodity and
should be assessed in the context of a
utility impact analysis. (EEI, No. 7 at p.
6; Public Meeting Transcript, No. 5 at p.
263) Although NEMS–BT provides
estimates of changes in electrical utility
infrastructure requirements as a
Available online at: https://www.onlocationinc.com/
LoadShapesAlternative2001.pdf.
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function of end-use energy savings, it
does not currently have the capability of
calculating similar results for water and
wastewater utilities. The water utility
sector is more complicated than either
the electric utility or gas utility sectors,
with a high degree of geographic
variability produced by a large diversity
of water resource availability,
institutional history, and regulatory
context. DOE currently does not have
access to tools that analyze water utility
impacts. There are activites being
conducted or initiated by the USGS,
EPA, and DOE to study water and
wastewater issues. However, these
activites have yet to provide the
necessary sources of data or tools to
enable a water utility impact analysis
comparable to what can be done on
electric and gas utilities using NEMS.
Therefore, conducting a credible water
and wastewater utility analysis is
beyond DOE’s existing analysis
capabilities.
M. Employment Impact Analysis
The Process Rule includes
employment impacts among the factors
to be considered in selecting a proposed
standard, and it provides guidance for
consideration of the impact (both direct
and indirect) of candidate standard
levels on employment. The Process Rule
states a general presumption against any
candidate standard level that would
directly cause plant closures or
significant loss of domestic
employment, unless specifically
identified expected benefits of the
standard would outweigh the adverse
effects. See the Process Rule, 10 CFR
Part 430, Subpart C, Appendix A,
sections 4(d)(7)(ii) and (vi), and
5(e)(3)(i)(B).
DOE estimates the impacts of
standards on employment for
equipment manufacturers, relevant
service industries, energy suppliers, and
the economy in general. Both indirect
and direct employment impacts are
covered. Direct employment impacts
would result if standards led to a change
in the number of employees at the
factories that produce the four appliance
products and related supply and service
firms. Direct impact estimates are
covered in the MIA.
Indirect employment impacts are
impacts on the national economy other
than in the manufacturing sector being
regulated. Indirect impacts may result
both from expenditures shifting among
goods (substitution effect) and changes
in income that lead to a change in
overall expenditure levels (income
effect). DOE defines indirect
employment impacts from standards as
net jobs created or eliminated in the
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general economy as a result of increased
spending driven by the increased
equipment prices and reduced spending
on energy.
DOE expects new standards for the
four appliance products to increase the
total installed cost of equipment, which
includes manufacturer selling price,
sales taxes, distribution chain markups,
and installation cost. DOE also expects
the new standards to decrease energy
consumption, and thus expenditures on
energy. Over time, increased total
installed cost is paid back through
energy savings. The savings in energy
expenditures may be spent on new
commercial investment and other items.
Using an input/output model of the
U.S. economy, this analysis seeks to
estimate the effects on different sectors
and the net impact on jobs. DOE will
estimate national employment impacts
for major sectors of the U.S. economy in
the NOPR, using public and
commercially available data sources and
software. DOE will make all methods
and documentation available for review
in the TSD for the NOPR.
In overview, DOE developed Impact
of Sector Energy Technologies (ImSET),
a spreadsheet model of the U.S.
economy that focuses on 188 sectors
most relevant to industrial, commercial,
and residential building energy use.59
ImSET is a special-purpose version of
the U.S. Benchmark National InputOutput (I–O) model, which has been
designed to estimate the national
employment and income effects of
energy saving technologies that are
deployed by DOE’s Office of Energy
Efficiency and Renewable Energy. In
comparison with the previous versions
of the model used in earlier
rulemakings, this version allows for
more complete and automated analysis
of the essential features of energy
efficiency investments in buildings,
industry, transportation, and the electric
power sectors. The ImSET software
includes a computer-based I–O model
with structural coefficients to
characterize economic flows among the
188 sectors. ImSET’s national economic
I–O structure is based on the 1997
Benchmark U.S. table (Lawson, et al.
2002),60 specially aggregated to 188
sectors.
Standards for the four appliance
products may reduce energy
59 Roop, J.M., M.J. Scott, and R.W. Schultz. 2005.
ImSET: Impact of Sector Energy Technologies.
PNNL–15273. Pacific Northwest National
Laboratory, Richland, WA.
60 Lawson, Ann M., Kurt S. Bersani, Mahnaz
Fahim-Nader, and Jiemin Guo. 2002. ‘‘Benchmark
Input-Output Accounts of the U. S. Economy,
1997,’’ Survey of Current Business, December, pp.
19–117.
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expenditures and increase equipment
prices in the commercial sector. These
expenditure changes are likely to reduce
commercial and energy sector
employment. At the same time, these
equipment standards may increase
commercial sector investment, and
increase employment in other sectors of
the economy. DOE designed the
employment impact analysis to estimate
the year-to-year net employment effect
of these different expenditure flows.
Although DOE intends to use ImSET
for its analysis of employment impacts,
it welcomes input on other tools and
factors it might consider. For more
information on the employment impact
analysis, refer to Chapter 14 of the TSD.
N. Environmental Assessment
The primary environmental effect of
energy conservation standards for the
four appliance products would be
reduced power plant emissions
resulting from reduced consumption of
electricity. DOE will assess these
environmental effects by using NEMS–
BT to provide key inputs to its analysis.
The environmental assessment produces
results in a manner similar to those
provided in the AEO. In addition to
electrical power, the operation of three
of the four appliance products—CCWs,
dishwashers, and cooking products—
also requires use of fossil fuels, and
results in emissions of carbon dioxide
(CO2), nitrogen oxides (NOX), and sulfur
dioxide (SO2) at the sites where the
appliances are installed. Southern
California Gas Company (SoCal Gas)
and PG&E questioned how DOE will
evaluate the emissions from gas-fired
appliances. (Public Meeting Transcript,
No. 5 at pp. 271–272) In response, we
note that NEMS–BT provides no means
for estimating such site emissions.
Therefore, DOE will calculate, and the
environmental assessment will include,
separate estimates of the effect of the
proposed standard on site emissions of
CO2, NOX, and SO2, based on simple
emissions factors derived from the
literature.61
The intent of the environmental
assessment is to provide emissions
results estimates and to properly
quantify and consider the
environmental effects of all new Federal
rules. The portion of the environmental
assessment that will be produced by
NEMS–BT considers only three
pollutants, SO2, NOX, and mercury, and
one other emission (carbon). The only
form of carbon the NEMS–BT model
61 U.S. Environmental Protection Agency.
Compilation of Air Pollutant Emission Factors, AP–
42, Fifth Edition, Volume 1: Stationary Point and
Area Sources. 1998. Available online at: https://
www. epa.gov/ttn/chief/ap42.html.
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tracks is CO2. Therefore, the carbon
discussed in this analysis is only in the
form of CO2. For each of the trial
standard levels, DOE will calculate total
undiscounted and discounted power
plant emissions using NEMS–BT, and
will use other methods to calculate site
emissions.
Although DOE plans to consider only
SO2, NOX, mercury, and CO2 in its
environmental assessment, there are
other air pollutants which are of
concern. Specifically, the Clean Air Act
requires EPA to set National Ambient
Air Quality Standards for the following
six common air pollutants, also know as
‘‘criteria pollutants’’: (1) Ozone, (2)
particulate matter (PM), (3) carbon
monoxide (CO), (4) nitrogen dioxide, (5)
SO2, and (6) lead. 62 EPA recently added
mercury to this list. But none of the
‘‘criteria pollutants’’ not considered in
the environmental assessment (i.e.,
ozone, PM, CO, and lead) are driven
significantly by either electric utility
power plants or fuel-fired appliances.
Therefore, DOE does not intend on
addressing them in the environmental
assessment. In the case of ozone and
PM, other pollutants are precursors to
their formation, and atmospheric
conditions are the driver behind their
formation. Also, SO2 and NOX, are the
primary precursors to ozone and PM,
respectively, and will already be
addressed by the environmental
assessment. In the case of CO, electric
utilities and fuel-fired appliances are
not significant sources. For electric
power plants, almost all carbon
emissions come out in the form of CO2
as the combustion process is lean
enough not to yield CO in significant
amounts. For fuel-fired appliances,
proper appliance maintenance,
installation, and use can prevent
dangerous levels of CO. A well-designed
and properly functioning heating or
cooking appliance should not produce
toxic or lethal levels of CO, as, most
often, CO poisoning occurs in the home
as a result of malfunctioning appliances.
Finally, with regard to lead, the ban on
the use of leaded gasoline has resulted
in a dramatic decrease in lead emissions
since the mid-1970s. Today, industrial
processes (not electric utilities),
particularly primary and secondary lead
smelters and battery manufacturers, are
responsible for most of lead emissions
and all violations of the lead air quality
standards.
As to power plant emissions, DOE
will conduct each environmental
assessment performed as part of this
rulemaking as an incremental policy
impact (i.e., a standard for the product
under evaluation) on the AEO 2007
forecast, applying the same basic set of
assumptions used in AEO 2007. For
example, the emissions characteristics
of an electricity generating plant will be
exactly those used in AEO 2007. Also,
forecasts conducted with NEMS–BT
consider the supply-side and demandside effects on the electric utility
industry. Thus, DOE’s analysis will
account for any factors affecting the type
of electricity generation and, in turn, the
type and amount of airborne emissions
generated by the utility industry.
The NEMS–BT model tracks carbon
emissions with a specialized carbon
emissions estimation subroutine,
producing reasonably accurate results
due to the broad coverage of all sectors
and inclusion of interactive effects. Past
experience with carbon results from
NEMS suggests that emissions estimates
are somewhat lower than emissions
based on simple average factors. One of
the reasons for this divergence is that
NEMS tends to predict that conservation
displaces generating capacity in future
years. On the whole, NEMS–BT
provides carbon emissions results of
reasonable accuracy, at a level
consistent with other Federal published
results.
NEMS–BT also reports SO2, NOX, and
mercury, which DOE has reported in
past analyses. The Clean Air Act
Amendments of 1990 set an SO2
emissions cap on all power
generation.63 The attainment of this
aggregate limit, however, is flexible
among generators of emissions, due to
the availability of emissions allowances
and tradable permits. Although NEMS
includes a module for SO2 allowance
trading and delivers a forecast of SO2
allowance prices, accurate simulation of
SO2 trading implies that the effect of
efficiency standards on physical
emissions will be zero because
emissions will always be at or near the
ceiling. However, there may be an SO2
benefit from energy conservation, in the
form of a lower SO2 allowance price.
Since the impact of any one standard on
the allowance price is likely small and
highly uncertain, DOE does not plan to
monetize any potential SO2 benefit.
NEMS–BT also has an algorithm for
estimating NOX emissions from power
generation. The impact of these
emissions, however, will be affected by
the Clean Air Interstate Rule (CAIR),
which the EPA published on May 12,
2005. CAIR will permanently cap
62 U.S. Environmental Protection Agency. Six
Common Air Pollutants. Washington, DC. Available
online at: https://www.epa.gov/air/urbanair/.
63 See 40 CFR part 50. (See also U.S.
Environmental Protection Agency Web site at:
https://www.epa.gov/air/caa/).
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emissions of NOX in 28 eastern States
and the District of Columbia. 70 FR
25162 (May 12, 2005). As with SO2
emissions, a cap on NOX emissions
means that equipment efficiency
standards may have no physical effect
on these emissions. When NOX
emissions are subject to emissions caps,
DOE’s emissions reduction estimate
corresponds to incremental changes in
the prices of emissions allowances in
cap-and-trade emissions markets rather
than physical emissions reductions.
Therefore, while the emissions cap may
mean that physical emissions
reductions will not result from
standards, standards could produce an
economic benefit in the form of lower
prices for emissions allowance credits.
However, as with SO2 allowance prices,
DOE does not plan to monetize this
benefit because the impact on the NOX
allowance price from any single energy
conservation standard is likely small
and highly uncertain.
EEI stated that new rules pertaining to
power plant SO2 and NOX emissions
will limit the impact that standards can
have on reducing these emissions. (EEI,
No. 7 at p. 4) As noted above, NEMS–
BT accounts for the most recent
regulations pertaining to power plant
SO2 and NOX emissions and expects
that appliance efficiency standards will
not have any physical effect on these
emissions.
With regard to mercury emissions,
NEMS has an algorithm for estimating
these emissions from power generation.
However, the impact on mercury
emissions will be affected by the Clean
Air Mercury Rule (CAMR), which the
EPA published on May 18, 2005. 70 FR
28606. CAMR will permanently cap
emissions of mercury for new and
existing coal-fired plants in all States.
As with SO2 and NOX emissions, a cap
on mercury emissions means that
appliance efficiency standards may have
no physical effect on these emissions.
When mercury emissions are subject to
emissions caps, DOE’s emissions
reduction estimate corresponds to
incremental changes in the prices of
emissions allowances in cap-and-trade
emissions markets rather than physical
emissions reductions. Therefore, while
the emissions cap may mean that
physical emissions reductions will not
result from standards, standards could
produce an economic benefit in the
form of lower prices for emissions
allowance credits. However, as with SO2
and NOX allowance prices, DOE does
not plan to monetize this benefit
because the impact on the mercury
allowance price from any single energy
conservation standard is likely small
and highly uncertain.
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The Joint Comment stated that DOE
should evaluate mercury and particulate
emissions as part of the environmental
assessment due to their impact on
public health. (Joint Comment, No. 9 at
p. 3) In response, as noted above,
NEMS–BT accounts for the most recent
regulations pertaining to power plant
mercury emissions and expects that
standards will not have any physical
effect on the level of these emissions.
With regard to particulates, these
emissions are a special case because
they arise not only from direct
emissions, but also from complex
atmospheric chemical reactions that
result from NOX and SO2 emissions.
Because of the highly complex and
uncertain relationship between
particulate emissions and particulate
concentrations that impact air quality,
DOE does not plan on reporting
particulate emissions.
Potomac and SPU urged DOE to
evaluate wastewater discharge impacts
due to increased efficiency standards.
(Public Meeting Transcript, No. 5 at p.
269) DOE plans to conduct a separate
analysis of wastewater discharge
impacts as part of the environmental
assessment. DOE intends to derive a
simple national aggregate estimate of
wastewater discharge impacts from
proposed energy conservation
standards, based on estimates of
consumer water savings. It will first
provide a simple estimate of the fraction
of water savings that result in decreased
wastewater discharges. Then, by
applying this discharge fraction to the
water savings estimate, DOE can
provide an approximate wastewater
discharge savings estimate.
The results for the environmental
assessment are similar to a complete
NEMS run as published in the AEO
2007. These results include power
sector emissions for SO2, NOX, and
carbon in five-year forecasted
increments extrapolated to 2042. The
outcome of the analysis for each
candidate standard level is reported as
a deviation from the AEO 2007
reference (base) case.
For more detail on the environmental
assessment, refer to the environmental
assessment report in the TSD.
O. Regulatory Impact Analysis
DOE will prepare a draft regulatory
impact analysis in compliance with
Executive Order 12866, ‘‘Regulatory
Planning and Review,’’ which will be
subject to review by OMB’s Office of
Information and Regulatory Affairs
(OIRA). 58 FR 51735 (October 4, 1993).
As part of the regulatory impact
analysis, and as discussed in section
II.K, ‘‘Manufacturer Impact Analysis,’’
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DOE will identify and seek to mitigate
the overlapping effects on
manufacturers of new or revised DOE
standards and other regulatory actions
affecting the same products. Through
manufacturer interviews and literature
searches, DOE will compile information
on burdens from existing and
impending regulations affecting the four
appliance products covered under this
rulemaking. DOE also seeks input from
stakeholders about relevant regulations
whose impacts it should consider.
The regulatory impact analysis also
will address the potential for nonregulatory approaches to supplant or
augment energy conservation standards
to improve the efficiency of the four
appliance products. One such potential
non-regulatory program is tax credits. In
assessing the potential impacts from tax
credits, EEI suggested that DOE should
evaluate the long-term effects on market
transformation to more-efficient
products from short-term (e.g., two-year)
tax credits. (Public Meeting Transcript,
No. 5 at p. 278) AHAM stated that
recent Federal tax credits for
dishwashers will have an effect on
improving overall product efficiency
and that DOE should consider such
effect as part of analyzing the impact of
tax credits. (Public Meeting Transcript,
No. 5 at p. 277) In response, we noted
that the NOPR will include a complete
quantitative analysis of alternatives to
the proposed energy conservation
standards (including tax credits), and
DOE will use the most recent
information available to make its
assessments. DOE will use the NES
spreadsheet model (as discussed in
section II.I, ‘‘National Impact Analysis’’)
to calculate the NES and NPV for the
alternatives to the proposed
conservation standards. For more
information on the regulatory impact
analysis, refer to the regulatory impact
analysis report in the TSD.
III. Candidate Energy Conservation
Standard Levels
The Process Rule states that DOE will
specify candidate standard levels in the
ANOPR, but will not propose a
particular standard. 10 CFR Part 430,
Subpart C, Appendix A, section
4(c)(1)(i). Section II.I.4, ‘‘National
Impact Analysis Results’’ identifies the
candidate standard levels for each of the
four appliance products. Tables III.1
through III.4 repeat the candidate
standard levels for each of the four
appliance products.
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TABLE III.1.—STANDARD DISHWASHERS: CANDIDATE STANDARD
LEVELS
TABLE III.1.—STANDARD DISHWASHERS: CANDIDATE STANDARD
LEVELS—Continued
TABLE III.1.—STANDARD DISHWASHERS: CANDIDATE STANDARD
LEVELS—Continued
Candidate standard level
Candidate standard level
Candidate standard level
Energy factor
1 ............................................
2 ............................................
3 ............................................
0.46
0.58
0.62
TABLE
Energy factor
4 ............................................
5 ............................................
6 ............................................
0.65
0.72
0.80
Energy factor
7 ............................................
1.11
III.2.—DEHUMIDIFIERS: CANDIDATE STANDARD LEVELS
≤25.00
1
2
3
4
5
25.01–35.00
35.01–45.00
45.01–54.00
54.01–74.99
≥75.00
EF
Candidate standard level
EF
EF
EF
EF
EF
...............................................................
...............................................................
...............................................................
...............................................................
...............................................................
1.10
1.20
1.25
1.30
1.38
1.25
1.30
1.35
1.40
1.45
1.35
1.40
1.45
1.50
1.74
1.45
1.50
1.55
1.60
2.02
1.55
1.60
1.65
1.70
1.80
2.38
2.50
2.55
2.60
2.75
TABLE III.3.—COOKING PRODUCTS: CANDIDATE STANDARD LEVELS
Cooktops
Ovens
Microwave
ovens
Elec coil
Elec smooth
Gas
Elec standard
Elec selfclean
Gas standard
Gas selfclean
EF
EF
EF
EF
EF
EF
EF
0.769
....................
....................
....................
....................
....................
....................
0.752
....................
....................
....................
....................
....................
....................
0.399
0.420
....................
....................
....................
....................
....................
0.1113
0.1163
0.1181
0.1206
0.1209
....................
....................
0.1102
0.1123
....................
....................
....................
....................
....................
Candidate standard level
1* ......................................
2 .......................................
3 .......................................
4 .......................................
5 .......................................
6 .......................................
1a* ....................................
EF
0.0536
0.0566
0.0572
0.0593
0.0596
0.0600
0.0583
0.0625
0.0627
0.0632
....................
....................
....................
....................
0.586
0.588
0.597
0.602
....................
....................
....................
* 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
WASHERS: CANDIDATE STANDARD after the publication of the final rule); or
• A larger increase in the efficiency
LEVELS
Candidate standard level
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1
2
3
4
5
6
............................................
............................................
............................................
............................................
............................................
............................................
Modified energy factor/
water factor
1.42/9.50
1.60/8.50
1.72/8.00
1.80/7.50
2.00/5.50
2.20/5.10
DOE will review the public input it
receives in response to this ANOPR and
will update the analyses appropriately
for each product class before issuing the
NOPR. In addition, DOE will consider
any comments it receives on the
candidate standard levels set forth
above for the four appliance products,
and on whether alternative levels would
satisfy EPCA criteria for DOE adoption
of standards, for example:
• A moderate increase in the
efficiency level at an earlier effective
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level at a later effective date.
For the NOPR, DOE will develop trial
standard levels (TSL) from the above
candidate standard levels for each of the
four appliance products. DOE will
consider several criteria in developing
the TSLs, including, but not limited to,
which candidate standard level has the
minimum LCC, maximum NPV, and
maximum technologically feasible
efficiency. From the list of TSLs
developed, DOE will select one as its
proposed standard for the NOPR, while
explaining the other TSLs considered
and the reasons for their elimination in
deciding upon the level ultimately
proposed.
For a given product consisting of
several product classes (e.g.,
dehumidifiers and cooking products),
DOE will develop each TSL so that it is
comprised of candidate standard levels
from each class that exhibit similar
characteristics. For example, in the case
of dehumidifiers, one of the TSLs will
likely consist of the candidate standard
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level from each of the six classes that
has the minimum LCC.
DOE will also attempt to limit the
number of TSLs considered for the
NOPR by dropping from consideration
candidate standard levels that do not
exhibit significantly different economic
and/or engineering characteristics from
candidate standard levels already
selected as a TSL. For example, in the
case of dishwashers, the candidate
standard level with the minimum LCC
is candidate standard level 3 with an EF
of 0.65. If the sole consideration for
selecting TSLs was LCC, DOE would
likely drop candidate standard level 4
with an EF of 0.68 as its LCC savings are
lower and not significantly different
than the value for candidate standard
level 3.
DOE specifically seeks feedback on
the criteria it should use for basing the
selection of TSLs. This is identified as
Issue 16 under ‘‘Issues on Which DOE
Seeks Comment’’ in section IV.E of this
ANOPR.
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IV. Public Participation
A. Attendance at Public Meeting
The time, date, and location of the
public meeting are set forth in the DATES
and ADDRESSES sections at the beginning
of this document. Anyone who wishes
to attend the public meeting must notify
Ms. Brenda Edwards-Jones at (202) 586–
2945.
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B. Procedure for Submitting Requests to
Speak
Any person who has an interest in
today’s notice, or who is a
representative of a group or class of
persons that has an interest in these
issues, may request an opportunity to
make an oral presentation at the public
meeting. Please hand-deliver requests to
speak to the address shown under the
heading ‘‘Hand Delivery/Courier’’ in the
ADDRESSES section of this notice,
between 9 a.m. and 4 p.m., Monday
through Friday, except Federal holidays.
Requests also may be sent by mail, to
the address shown under the heading
‘‘Postal Mail’’ in the ADDRESSES section
of this notice, or by e-mail to
Brenda.Edwards-Jones@ee.doe.gov.
Persons requesting to speak should
briefly describe the nature of their
interest in this rulemaking and provide
a telephone number for contact. DOE
asks each person selected to be heard to
submit a copy of his or her statement at
least two weeks before the public
meeting, either by hand delivery, mail,
or e-mail as described in the preceding
paragraph. Please include an electronic
copy of your statement, on a computer
diskette or CD when delivery is by mail
or hand delivery. Electronic copies must
be in WordPerfect, Microsoft Word,
Portable Document Format (PDF), or
text in American Standard Code for
Information Interchange (ASCII) file
format. At its discretion, DOE may
permit any person who cannot supply
an advance copy of his or her statement
to participate, if that person has made
alternative arrangements with the
Building Technologies Program. In such
situations, the request to give an oral
presentation should ask for alternative
arrangements.
C. Conduct of Public Meeting
DOE will designate a DOE official to
preside at the public meeting and may
also use a professional facilitator to aid
discussion. The meeting will not be a
judicial or evidentiary-type public
hearing, but DOE will conduct it in
accordance with 5 U.S.C. 553 and
section 336 of EPCA. (42 U.S.C. 6306) A
court reporter will be present to record
the transcript of the proceedings. DOE
reserves the right to schedule the order
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of presentations and to establish the
procedures governing the conduct of the
public meeting. After the public
meeting, interested parties may submit
further comments on the proceedings
and any other aspect of the rulemaking
until the end of the comment period.
The public meeting will be conducted
in an informal, conference style. DOE
will present summaries of comments
received before the public meeting,
allow time for presentations by
participants, and encourage all
interested parties to share their views on
issues affecting this rulemaking. Each
participant will be allowed to make a
prepared general statement (within time
limits determined by DOE) before the
discussion of specific topics. DOE will
permit other participants to comment
briefly on any general statements.
At the end of all prepared statements
on a topic, DOE will permit participants
to clarify their statements briefly and
comment on statements made by others.
Participants should be prepared to
answer questions by DOE and by other
participants concerning these issues.
DOE representatives may also ask
questions of participants concerning
other matters relevant to the public
meeting. The official conducting the
public meeting will accept additional
comments or questions from those
attending, as time permits. The
presiding official will announce any
further procedural rules or modification
of the above procedures that may be
needed for proper conduct of the public
meeting.
DOE will make the entire record of
this proposed rulemaking, including the
transcript from the public meeting,
available for inspection at the U.S.
Department of Energy, Forrestal
Building, Room 1J–018 (Resource Room
of the Building Technologies Program),
1000 Independence Avenue, SW,
Washington, DC, (202) 586–9127,
between 9 a.m. and 4 p.m., Monday
through Friday, except Federal holidays.
Any person may buy a copy of the
transcript from the transcribing reporter.
D. Submission of Comments
DOE will accept comments, data, and
information regarding all aspects of this
ANOPR before or after the public
meeting, but no later than January 29,
2008. Please submit comments, data,
and information electronically to the
following e-mail address:
home_appliance.
rulemaking@ee.doe.gov. Submit
electronic comments in WordPerfect,
Microsoft Word, PDF, or text (ASCII) file
format and avoid the use of special
characters or any form of encryption.
Comments in electronic format should
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be identified by the docket number EE–
2006–STD–0127 and/or RIN 1904–
AB49, and whenever possible carry the
electronic signature of the author.
Absent an electronic signature,
comments submitted electronically
must be followed and authenticated by
submitting the signed original paper
document. DOE will not accept any
telefacsimiles (faxes).
Under 10 CFR 1004.11, any person
submitting information that he or she
believes to be confidential and exempt
by law from public disclosure should
submit two copies. One copy of the
document shall include all the
information believed to be confidential,
and the other copy of the document
shall have the information believed to
be confidential deleted. DOE will make
its own determination about the
confidential status of the information
and treat it according to its
determination.
Factors of interest to DOE when
evaluating requests to treat submitted
information as confidential include: (1)
A description of the items; (2) whether
and why such items are customarily
treated as confidential within the
industry; (3) whether the information is
generally known by, or available from,
other sources; (4) whether the
information has previously been made
available to others without obligation
concerning its confidentiality; (5) an
explanation of the competitive injury to
the submitting person which would
result from public disclosure; (6) when
such information might lose its
confidential character due to the
passage of time; and (7) why disclosure
of the information would be contrary to
the public interest.
E. Issues on Which the Department of
Energy Seeks Comment
DOE is interested in receiving
comments on all aspects of this ANOPR.
DOE especially invites comments or
data to improve DOE’s analysis,
including data or information that will
respond to the following questions or
concerns addressed in this ANOPR:
1. Microwave Oven Standby Power
For the NOPR, DOE is considering
purchasing, testing, and analyzing
microwave ovens to better understand
the utility, cost, and cost implications of
reducing standby power consumption.
Addition of a standby power test to the
existing test procedure would be
necessary before standby power could
be included in an efficiency standard.
DOE is considering this approach for
microwave ovens because data provided
by AHAM suggests that there is an
opportunity for significant energy
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savings via the reduction of standby
power levels. Therefore, DOE requests
data and stakeholder feedback on how
to conduct an analysis of standby power
for microwave ovens. (See section
I.D.4.b of this ANOPR for further
details.)
2. Product Classes
In accordance with EPCA section
325(p)(1)(A), DOE identified the
equipment classes covered under this
rulemaking. (42 U.S.C. 6295(p)(1)(A))
Pursuant to EPCA section 325(p)(1)(B),
DOE requests comments on these
equipment classes and invites interested
persons to submit written presentations
of data, views, and arguments. (42
U.S.C. 6295(p)(1)(B)) (See section II.A.1
of this ANOPR for further details.)
3. Commercial Clothes Washer
Horizontal-Axis Designs
The information available for CCWs
suggests that an efficiency of 1.6 MEF
and 8.5 WF will be based on horizontalaxis technology. As such, it appears that
the incremental costs between 1.60
MEF/8.5 WF and 2.2 MEF/5.1 WF will
be constant at the same value as those
provided by AHAM for the level 2.0
MEF/5.5 WF. DOE particularly seeks
comment on the validity of such an
approach. DOE also seeks information
about lower-cost alternatives to
horizontal-axis designs for levels greater
than 1.42 MEF/9.5 WF and lower than
2.0 MEF/5.5 WF. Additionally, DOE
seeks information that would allow it to
change the energy and water features of
the 2.0 MEF/5.5 WF level to allow for
manufacturer cost differentiation at the
lower (and the higher) levels.
Furthermore, DOE seeks comment on
how to evaluate potential shifts from
vertical-axis technologies to horizontalaxis. (See section II.C.4.d of this ANOPR
for further details.)
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4. Compact Dishwashers
DOE was unable to obtain incremental
manufacturing cost information for
compact dishwashers. Therefore, DOE
did not analyze compact dishwashers
for this ANOPR but expects to set
standards for them. DOE requests
feedback on how it can extend the
results of the analysis for the standard
class to compact dishwashers. (See
section II.C.4 of this ANOPR for further
details.)
5. Microwave Oven Design Options
For microwave ovens, the design
options and efficiency levels that DOE
analyzed are those identified in the
previous rulemaking’s analysis, with
incremental manufacturing costs scaled
by the PPI. DOE requests stakeholder
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feedback on the approach of analyzing
additional design options that would
result in a lowering of the energy
consumption of non-cooking features
(e.g., standby power), even though the
existing test procedure currently does
not account for such usage in EF. (See
section II.C.3 of this ANOPR for further
details.)
6. Technologies Unable to be Analyzed
and Exempted Product Classes
There are a number of technologies
which DOE was unable to analyze for
this ANOPR. Design options associated
with these technologies for
dehumidifiers, cooking products, and
CCWs, while passing the screening
analysis, were eliminated from further
consideration prior to the ANOPR
engineering analysis. In addition,
certain product classes were exempted
on a similar lack of efficiency data. DOE
requests stakeholder input on (1) energy
efficiency data for technologies and
product classes for which such data
does not exist; and (2) potential
limitations of existing test procedures.
The latter may include such issues as
representative usage patterns, ambient
conditions, and test equipment. (See
sections II.A.1 and II.C.2 of this ANOPR
for further details.)
7. Dishwasher Efficiency and its Impact
on Cleaning Performance
DOE was not able to identify sources
of data showing whether the amount of
pre-washing is impacted by dishwasher
efficiency. Therefore, DOE believes that,
to date, hand-washing or pre-washing
habits have not been affected by product
efficiency. Because increased diswasher
energy efficiency may require future
designs to utlize less water, DOE
recognizes the possibility that more
efficient dishwashers may degrade wash
performance. Therefore, DOE seeks
feedback on whether more efficient
dishwasher designs will affect cleaning
performance, leading to increased handwashing or pre-washing and, if so, what
increase in energy and water use can be
expected. (See section II.D.1 of this
ANOPR for further details.)
8. Dehumidifier Use
DOE identified several sources of data
for estimating the annual use of
dehumidifiers. However, DOE gave
more weight to data that AHAM
provided because they were developed
based on the experience of
manufacturers. It appears that AHAM’s
average estimate of 1,095 operating
hours per year is the most representative
of actual use. DOE requests feedback on
whether 1,095 hours per year best
represents the use of dehumidifiers.
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(See section II.D.2 of this ANOPR for
further details.)
9. Commercial Clothes Washer PerCycle Energy Consumption
DOE determined the per-cycle clothes
drying energy use and the per-cycle
machine energy use for CCWs from data
in its 2000 TSD for residential clothes
washers. DOE requests feedback on
whether these per-cycle energy use
characteristics for residential clothes
washers are also representative of CCW
energy use. (See section II.D.4 of this
ANOPR for further details.)
10. Commercial Clothes Washer
Consumer Prices
DOE identified two distribution
channels for CCWs to establish their
price to consumers. One channel
involved distributors that typically sell
to Laundromats, and the other channel
involved route operators that typically
sell or lease to multi-family building
property owners. For purposes of
developing the markups and consumer
equipment prices for CCWs, DOE based
its calculations solely on a distribution
channel that involves distributors. DOE
believed that the markups and the
resulting consumer equipment prices
determined for this distribution channel
also would be representative of the
prices paid by consumers acquiring
their equipment from route operators.
DOE requests feedback on its views
regarding its development of consumer
prices for CCWs. (See section II.E.1 of
this ANOPR for further details.)
11. Repair and Maintenance Costs
Primarily because it did not receive
any specific data on the impacts that
standards might have on repair and
maintenance costs, DOE did not include
any changes in repair and maintenance
costs due to standards for any of the
four appliance products. DOE requests
feedback on its understanding of repair
and maintenance costs. (See section
II.G.2.b of this ANOPR for further
details.)
12. Efficiency Distributions in the Base
Case
To accurately estimate the percentage
of consumers that would be affected by
a particular energy conservation
standard level, DOE took into account
the distribution of product efficiencies
currently in the marketplace. In other
words, DOE conducted its LCC and PBP
analyses by considering the full breadth
of product efficiencies that consumers
purchase under the base case (i.e., the
case without new energy efficiency
standards) to account for those
consumers who already purchase more
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efficient products. DOE developed base
case efficiency distributions for each of
the four appliance products based on a
combination of data sources and
estimates. DOE requests feedback on the
data sources and estimates it used for
developing its base case product
efficiency distributions. (See section
II.G.2.d of this ANOPR for further
details.)
13. Commercial Clothes Washer
Shipments Forecasts
Based on historical data, CCW
shipments dropped significantly
between 1998 and 2005. Because DOE
tied forecasted shipments to the growth
in new multi-family construction, DOE
forecasted a continued increase in
clothes washer shipments over the
analysis period (i.e., 2012–2042).
However, due to the dramatic drop in
shipments seen in the historical data,
DOE is uncertain as to whether
shipments will continue to increase and
requests feedback on the bases for its
shipments forecasts for CCWs. (See
section II.H.1 of this ANOPR for further
details.)
mstockstill on PROD1PC66 with PROPOSALS2
14. Base-Case and Standards-Case
Forecasted Efficiencies
Because key inputs to the calculation
of the NES and NPV are dependent on
the estimated efficiencies under the base
case (without standards) and the
standards case (with standards),
forecasted efficiencies are of great
importance to the analysis. DOE
forecasted base-case and standards-case
efficiencies, believing they remained
frozen throughout the analysis period
(i.e., 2012–2042). DOE used a ‘‘roll-up’’
scenario to establish the shipmentweighted efficiency for the year that
standards are estimated to become
effective (i.e., 2012). Under a roll-up
scenario, DOE believed that product
efficiencies in the base case that did not
meet the standard level under
consideration would roll up to meet the
new standard level. DOE requests
feedback on its methodologies for both
forecasting efficiencies and estimating
the impact that standards have on
product efficiencies. (See section II.I.2
of this ANOPR for further details.)
15. Dehumidifier Cost and Efficiency
Relationships
DOE defined total installed cost and
efficiency relationships for a subset of
the six dehumidifier product classes,
For purposes of conducting its NIA,
DOE applied the cost-efficiency data
that were developed for these product
classes to those classes for which DOE
was unable to develop cost-efficiency
relationships due to lack of data.
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Specifically, DOE applied the costs
developed for the combined 0–35.00
pints/day class to the two individual
classes that comprised the combined
class—25.00 pints/day and less and
25.01–35.00 pints/day. Further, DOE
applied the costs developed for the
35.01–45.00 pints/day and 54.01–74.99
pints/day product classes to the 45.01–
54.00 pints/day and 75.00 pints/day and
greater product classes, respectively. In
its application of total installed costs to
those product classes where no cost data
were developed, DOE did not
interpolate or extrapolate the cost data
to account for product efficiency
differences between the classes. For
example, DOE utilized the exact same
total installed costs that were developed
for the baseline and standard levels for
the 35.01–45.00 pints/day product class
to characterize the baseline and
standard level total installed costs for
the 45.01–54.00 pints/day product class.
DOE requests feedback on its approach
for characterizing the total installed
costs for those dehumidifier product
classes in which it was not able to
develop cost-efficiency relationships.
(See section II.I.3 of this ANOPR for
further details.)
16. Trial Standard Levels
For the NOPR, DOE will develop trial
standard levels (TSL) from the
candidate standard levels for each of the
four appliance products. DOE will
consider several criteria in developing
the TSLs, including, but not limited to,
which candidate standard level has the
minimum LCC, maximum NPV, and
maximum technologically feasible
efficiency. From the list of TSLs
developed, DOE will select one as its
proposed standard for the NOPR. DOE
requests feedback on the criteria it
should use for basing the selection of
TSLs. (See section III of this ANOPR for
further details.)
V. Regulatory Review and Procedural
Requirements
DOE submitted this ANOPR for
review to OMB under Executive Order
12866, ‘‘Regulatory Planning and
Review.’’ 58 FR 51735 (October 4, 1993).
If DOE later proposes energy
conservation standards for any of the
four appliance products, and if the
proposed rule constitutes a significant
regulatory action, DOE would prepare
and submit to OMB for review the
assessment of costs and benefits
required by section 6(a)(3) of the
Executive Order. The Executive Order
requires agencies to identify the specific
market failure or other specific problem
that it intends to address that warrants
new agency action, as well as assess the
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significance of that problem, to enable
assessment of whether any new
regulation is warranted. (Executive
Order 12866, section 1(b)(1)). DOE
presumes that a perfectly functioning
market would result in efficiency levels
that maximize benefits to all affected
persons. Consequently, without a
market failure or other specific problem,
a regulation would not be expected to
result in net benefits to consumers and
the nation. However, DOE also notes
that whether it establishes standards for
these products is determined by the
statutory criteria expressed in EPCA.
Even in the absence of a market failure
or other specific problem, DOE
nonetheless may be required to establish
standards under existing law.
DOE’s preliminary analysis for
dishwashers, dehumidifiers, some gas
cooking products, and commercial
clothes washers explicitly accounts for
the percentage of consumers that
already purchase more efficient
equipment and takes these consumers
into account when determining the
national energy savings associated with
various candidate standard levels. The
preliminary analysis suggests that
accounting for the market value of
energy savings alone (i.e., excluding any
possible ‘‘externality’’ benefits such as
those noted below) would produce
enough benefits to yield net benefits
across a wide array of products and
circumstances. With the exception of
electric and some gas cooking products,
these results quantify the percentage of
consumers that do purchase more
efficient products. DOE requests
additional data (including the
percentage of consumers purchasing
more efficient cooking products and the
extent to which consumers of all
product types will continue to purchase
more efficient equipment), for testing
the existence and extent of these
consumer actions.
DOE believes that there is a lack of
consumer information and/or
information processing capability about
energy efficiency opportunities in the
home appliance market. If this is in fact
the case, DOE would expect the energy
efficiency for home appliances to be
randomly distributed across key
variables such as energy prices and
usage levels. Although, with the
exception of cooking products, DOE has
already identified the percentage of
consumers that already purchase more
efficient products, DOE does not
correlate the consumer’s usage pattern
and energy price with the efficiency of
the purchased product. Therefore, DOE
seeks data on the efficiency levels of
existing home appliances in use by how
often it is utilized (e.g., how many times
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or hours the product is used) and its
associated energy price (and/or
geographic region of the country). DOE
plans to use these data to test the extent
to which purchasers of this equipment
behave as if they are unaware of the
costs associated with their energy
consumption. Also, DOE seeks comment
on additional knowledge of the Federal
Energy Star program, and the program’s
potential as a resource for increasing
knowledge of the availability and
benefits of energy efficient appliances in
the home appliance consumer market.
A related issue is the problem of
asymmetric information (one party to a
transaction has more and better
information than the other) and/or high
transactions costs (costs of gathering
information and effecting exchanges of
goods and services). In the case of
appliances, in many instances the party
responsible for the appliance purchase
may not be the one who pays the cost
to operate it. For example, home
builders in large-scale developments
often make decisions about appliances
without input from home buyers, nor do
they offer options to upgrade them.
Also, apartment owners normally make
decisions about appliances, but it may
be the renters who pay the utility bills.
If there were no transactions costs, it
would be in the home builders’ and
apartment owners’ interest to install
appliances the buyers and renters would
choose on their own. For example, a
renter who knowingly faces higher
utility bills from low-efficiency
appliances would be willing to pay less
in rent, and the apartment owner would
indirectly bear the higher utility cost.
However, this information is not
costless, and it may not be in the
interest of the renter to take the time to
develop it, or, in the case of the landlord
who installs a high-efficiency appliance,
to convey that information to the renter.
To the extent that asymmetric
information and/or high transactions
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costs are problems, one would expect to
find certain outcomes with respect to
appliance energy efficiency. For
example, other things equal, one would
not expect to see higher rents for
apartments with high-efficiency
appliances. Conversely, if there were
symmetric information, one would
expect appliances with higher energy
efficiency in rental units where the rent
includes utilities compared to those
where the renter pays the utility bills
separately. Similarly, for single-family
homes, one would expect higher energy
efficiency levels for replacement units
than appliances installed in new
construction. Within the new
construction market, one would expect
to see appliances with higher energy
efficiency levels in custom-built homes
(where the buyer has more say in
appliance choices) than in comparable
homes built in large-scale
developments.
Of course, there are likely to be
certain ‘‘external’’ benefits resulting
from the improved efficiency of units
that are not captured by the users of
such equipment. These include both
environmental and energy securityrelated externalities that are not already
reflected in energy prices, such as
reduced emissions of greenhouse gases
and reduced use of natural gas and oil
for electricity generation. DOE invites
comments on the weight that should be
given to these factors in DOE’s
determination of the maximum
efficiency level at which the total
benefits are likely to exceed the total
costs resulting from a DOE standard.
As previously stated, DOE generally
seeks data that might enable it to
conduct tests of market failure for
products under consideration for
standard-setting. For example, given
adequate data, there are ways to test for
the extent of market failure for
commercial clothes washers. One would
expect the owners of commercial
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clothes washers who also pay for their
energy and water consumption to
purchase machines that exhibit higher
energy efficiency and lower water usage
compared to machines whose owners do
not pay for the energy and water usage,
other things equal. To test for this form
of market failure, DOE needs data on
energy efficiency and water
consumption of such units and whether
the owner of the equipment is also the
operator. DOE is also interested in other
potential tests of market failure and data
that would enable such tests.
In addition, various other analyses
and procedures may apply to such
future rulemaking action, including
those required by the National
Environmental Policy Act (Pub. L. 91–
190, 42 U.S.C. 4321 et seq.); the
Unfunded Mandates Reform Act of 1995
(Pub. L. 104–4); the Paperwork
Reduction Act (44 U.S.C. 3501 et seq.);
the Regulatory Flexibility Act (5 U.S.C.
601 et seq.); and certain Executive
Orders.
The draft of today’s action and any
other documents submitted to OMB for
review are part of the rulemaking record
and are available for public review at
the U.S. Department of Energy, Forrestal
Building, Room 1J–018, (Resource Room
of the Building Technologies Program),
1000 Independence Avenue, SW.,
Washington, DC, (202) 586–9127,
between 9 a.m. and 4 p.m., Monday
through Friday, except Federal holidays.
VI. Approval of the Office of the
Secretary
The Secretary of Energy has approved
publication of today’s ANOPR.
Issued in Washington, DC, on September
17, 2007.
Alexander A. Karsner,
Assistant Secretary, Energy Efficiency and
Renewable Energy.
[FR Doc. E7–22040 Filed 11–14–07; 8:45 am]
BILLING CODE 6450–01–P
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]]>Agencies
[Federal Register Volume 72, Number 220 (Thursday, November 15, 2007)]
[Proposed Rules]
[Pages 64432-64515]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E7-22040]
[[Page 64431]]
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Part IV
Department of Energy
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Office of Energy Efficiency and Renewable Energy
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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
Federal Register / Vol. 72, No. 220 / Thursday, November 15, 2007 /
Proposed Rules
[[Page 64432]]
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DEPARTMENT OF ENERGY
Office of Energy Efficiency and Renewable Energy
10 CFR Parts 430 and 431
[Docket No. EE-2006-STD-0127]
RIN 1904-AB49
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)
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Advance notice of proposed rulemaking and notice of public
meeting.
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SUMMARY: The Energy Policy and Conservation Act (EPCA or the Act)
authorizes the Department of Energy (DOE) to establish energy
conservation standards for various consumer products and commercial and
industrial equipment--including residential dishwashers, dehumidifiers,
and electric and gas kitchen ranges and ovens and microwave ovens
(hereafter referred to as ``cooking products''), as well as commercial
clothes washers--if DOE determines that energy conservation standards
would be technologically feasible and economically justified, and would
result in significant energy savings. DOE is publishing this advance
notice of proposed rulemaking (ANOPR) to consider establishing energy
conservation standards for these products and to announce a public
meeting to receive comments on a variety of issues.
DATES: DOE will hold a public meeting on December 13, 2007, starting at
9 a.m. in Washington, DC. DOE must receive requests to speak at the
public meeting no later than 4 p.m., November 29, 2007. DOE must
receive a signed original and an electronic copy of statements to be
given at the public meeting no later than 4 p.m., December 6, 2007.
DOE will accept comments, data, and information regarding the ANOPR
before or after the public meeting, but no later than January 29, 2008.
See section IV, ``Public Participation,'' of this ANOPR for details.
ADDRESSES: The public meeting will be held at the Holiday Inn Capital,
550 C Street, SW., DC 20024.
Any comments submitted must identify the ANOPR for Home Appliance
Products, and provide the docket number EE-2006-STD-0127 and/or
Regulatory Information Number (RIN) 1904-AB49. Comments may be
submitted using any of the following methods:
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments.
E-mail: home_appliance.rulemaking@ee.doe.gov. Include the
docket number EE-2006-STD-0127 and/or RIN 1904-AB49 in the subject line
of the message.
Mail: Ms. Brenda Edwards-Jones, U.S. Department of Energy,
Building Technologies Program, Mailstop EE-2J, 1000 Independence
Avenue, SW., Washington, DC 20585-0121. Please submit one signed paper
original.
Hand Delivery/Courier: Ms. Brenda Edwards-Jones, U.S.
Department of Energy, Building Technologies Program, Room 1J-018, 1000
Independence Avenue, SW., Washington, DC 20585. Telephone: (202) 586-
2945. Please submit one signed paper original.
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section IV of this document
(Public Participation).
Docket: For access to the docket to read background documents or
comments received, visit the U.S. Department of Energy, Forrestal
Building, Room 1J-018 (Resource Room of the Building Technologies
Program), 1000 Independence Avenue, SW., Washington, DC, (202) 586-
2945, between 9 a.m. and 4 p.m., Monday through Friday, except Federal
holidays. Please call Ms. Brenda Edwards-Jones at the above telephone
number for additional information regarding visiting the Resource Room.
Please note: DOE's Freedom of Information Reading Room (Room 1E-190 at
the Forrestal Building) no longer houses rulemaking materials.
FOR FURTHER INFORMATION CONTACT: Stephen Witkowski, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies, EE-2J, 1000 Independence Avenue, SW., Washington, DC
20585-0121, (202) 586-7463. E-mail: stephen.witkowski@ee.doe.gov.
Francine Pinto or Eric Stas, U.S. Department of Energy, Office of
the General Counsel, Forrestal Building, Mail Station GC-72, 1000
Independence Avenue, SW., Washington, DC, 20585. Telephone: (202) 586-
9507. E-mail: Francine.Pinto@hq.doe.gov or Eric.Stas@hq.doe.gov.
Regarding the public meeting, Brenda Edwards-Jones, U.S. Department
of Energy, Building Technologies Program, Room 1J-018, 1000
Independence Avenue, SW., Washington, DC 20585. Telephone: (202) 586-
2945. E-mail: Brenda.Edwards-Jones@ee.doe.gov.
SUPPLEMENTARY INFORMATION:
I. Introduction
A. Purpose of the Advance Notice of Proposed Rulemaking
B. Overview of the Analyses Performed
1. Engineering Analysis
2. Energy and Water Use Characterization
3. Markups to Determine Equipment Price
4. Life-Cycle Cost and Payback Period Analyses
5. National Impact Analysis
C. Authority
D. Background
1. History of Standards Rulemaking for Residential Dishwashers,
Dehumidifiers, and Cooking Products; and Commercial Clothes Washers
2. Current Rulemaking Process
3. Analysis Process
4. Miscellaneous Rulemaking Issues
a. Joint Stakeholder Recommendations
b. Standby Power for Dishwashers and Cooking Products
5. Test Procedures
II. Analyses for the Four Appliance Products
A. Market and Technology Assessment
1. Product Classes
a. Dishwashers
b. Dehumidifiers
c. Cooking Products
d. Commercial Clothes Washers
2. Market Assessment
3. Technology Assessment
a. Dishwashers
b. Dehumidifiers
c. Cooking Products
d. Commercial Clothes Washers
B. Screening Analysis
1. Purpose
a. Technological Feasibility
b. Practicability To Manufacture, Install, and Service
c. Adverse Impacts on Product Utility or Product Availability
d. Adverse Impacts on Health or Safety
2. Design Options
a. Dishwashers
b. Dehumidifiers
c. Cooking Products
1. Cooktops and Ovens
2. Microwave Ovens
d. Commercial Clothes Washers
C. Engineering Analysis
1. Approach
2. Technologies Unable To Be Included in the Engineering
Analysis
3. Product Classes, Baseline Models, and Efficiency Levels
Analyzed
a. Dishwashers
b. Dehumidifiers
c. Cooking Products
d. Commercial Clothes Washers
4. Cost-Efficiency Results
a. Dishwashers
b. Dehumidifiers
c. Cooking Products
d. Commercial Clothes Washers
D. Energy Use and End-Use Load Characterization
[[Page 64433]]
1. Dishwashers
2. Dehumidifiers
3. Cooking Products
a. Cooktops and Ovens
b. Microwave Ovens
4. Commercial Clothes Washers
E. Markups To Determine Equipment Price
1. Distribution Channels
2. Approach for Manufacturer Markups
3. Approach for Retailer and Distributor Markups
4. Sales Taxes
5. Summary of Markups
F. Rebuttable Presumption Payback Periods
G. Life-Cycle Cost and Payback Period Analyses
1. Approach Taken in the Life-Cycle Cost Analysis
2. Life-Cycle Cost Inputs
a. Total Installed Cost Inputs
b. Operating Cost Inputs
c. Effective Date
d. Equipment Assignment for the Base Case
3. Payback Period Inputs
4. Life-Cycle Cost and Payback Period Results
H. Shipments Analysis
1. Shipments Model
2. Data Inputs
3. Shipments Forecasts
I. National Impact Analysis
1. Approach
2. Base Case and Standards Case Forecasted Efficiencies
3. National Impact Analysis Inputs
4. National Impact Analysis Results
J. Life-Cycle Cost Subgroup Analysis
K. Manufacturer Impact Analysis
1. Sources of Information for the Manufacturer Impact Analysis
2. Industry Cash Flow Analysis
3. Manufacturer Subgroup Analysis
4. Competitive Impacts Assessment
5. Cumulative Regulatory Burden
6. Preliminary Results for the Manufacturer Impact Analysis
L. Utility Impact Analysis
M. Employment Impact Analysis
N. Environmental Assessment
O. Regulatory Impact Analysis
III. Candidate Energy Conservation Standard Levels
IV. Public Participation
A. Attendance at Public Meeting
B. Procedure for Submitting Requests To Speak
C. Conduct of Public Meeting
D. Submission of Comments
E. Issues on Which the Department of Energy Seeks Comment
1. Microwave Oven Standby Power
2. Product Classes
3. Commercial Clothes Washer Horizontal Axis Designs
4. Compact Dishwashers
5. Microwave Oven Design Options
6. Technologies Unable To Be Analyzed and Exempted Product
Classes
7. Dishwasher Efficiency and Its Impact on Cleaning Performance
8. Dehumidifier Use
9. Commercial Clothes Washer Per-Cycle Energy Consumption
10. Commercial Clothes Washer Consumer Prices
11. Repair and Maintenance Costs
12. Efficiency Distributions in the Base Case
13. Commercial Clothes Washer Shipments Forecasts
14. Base-Case and Standards-Case Forecasted Efficiencies
15. Dehumidifier Cost and Efficiency Relationships
16. Trial Standard Levels
V. Regulatory Review and Procedural Requirements
VI. Approval of the Office of the Secretary
I. Introduction
A. Purpose of the Advance Notice of Proposed Rulemaking
The purpose of this ANOPR is to provide interested persons with an
opportunity to comment on:
1. The product classes that the Department of Energy (DOE) is
planning to analyze in this rulemaking;
2. The analytical framework, models, and tools (e.g., life-cycle
cost (LCC) and national energy savings (NES) spreadsheets) DOE is using
in performing analyses of the impacts of energy conservation standards
for residential dishwashers, dehumidifiers, cooking products, and
commercial clothes washers (CCWs) (collectively referred to in this
ANOPR as ``the four appliance products'');
3. The analyses performed for the ANOPR, including in particular
the results of the engineering analyses, the LCC and payback period
(PBP) analyses, and the NES and national impact analyses, which are
presented in the ANOPR Technical Support Document (TSD): Energy
Efficiency Standards for Consumer Products and Commercial and
Industrial Equipment: Residential Dishwashers, Dehumidifiers, And
Cooking Products And Commercial Clothes Washers, \1\ as summarized in
this ANOPR (2007 TSD); and
---------------------------------------------------------------------------
\1\ To be published on the DOE Web site at: https://
www.eere.energy.gov/buildings/appliance_standards/residential/
cooking_products.html
_____________________________________-
4. The candidate energy conservation standard levels that DOE has
developed from these analyses.
B. Overview of the Analyses Performed
The Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.)
directs DOE to consider establishing or amending energy conservation
standards for various consumer products and commercial and industrial
equipment, including the four appliance products which are the subject
of this ANOPR. For each of these products, DOE conducted in-depth
technical analyses for this ANOPR in the following areas: (1)
Engineering, (2) energy and water use characterization, (3) markups to
determine equipment price, (4) LCC and PBP, (5) shipments, (6) national
impacts, and (7) preliminary manufacturer impacts. The ANOPR presents a
discussion of the methodologies and assumptions utilized in these
analyses. For each type of analysis, Table I.1 identifies the sections
in this document that contain the results of the analysis, and
summarizes the methodologies, key inputs, and assumptions for the
analysis. DOE consulted with interested parties in developing these
analyses, and invites further input from stakeholders on these topics.
Obtaining that input is the purpose of this ANOPR. Thus, it should be
noted that the analytical results presented here are subject to
revision following review and input from stakeholders and other
interested parties. The final rule will contain the final analytical
results.
[[Page 64434]]
Table I.1.--In-Depth Technical Analyses Conducted for the Advance Notice of Proposed Rulemaking
----------------------------------------------------------------------------------------------------------------
ANOPR section for
Analysis area Methodology Key inputs Key assumptions results
----------------------------------------------------------------------------------------------------------------
Engineering (TSD Chapter 5):
Dishwashers............... Efficiency level Component cost Analysis can be Section II.C.3.
Dehumidifiers............. approach data; extended in
supplemented Performance subsequent
with design values. analyses to
option analysis. product classes
and efficiency
levels for which
the Association
of Home Appliance
Manufacturers
(AHAM) did not
provide data.
Cooking Products.......... ................. ................. Historical data
from DOE's 1996
analysis on
residential
cooking products
are still
representative of
current
manufacturing
costs.
Commercial Clothes Washers ................. ................. Analysis can be
extended to
energy and water
efficiency levels
for which AHAM
did not provide
data.
Energy and Water Use
Characterization
(TSD Chapter 6):
Dishwashers............... Establish per- Per-cycle energy Per-cycle water Section II.D.1.
cycle energy and and water use; use is a direct
water use and Average annual function of per-
then multiply by usage of 215 cycle energy use
annual cycles. cycles based on (based on AHAM
DOE test data).
procedure;
Variability of
usage based on
Energy
Information
Administration
(EIA)'s
Residential
Energy
Consumption
Survey (RECS).
Dehumidifiers............. Establish daily Per-cycle energy Average usage of Section II.D.2.
energy use by and water use; 1095 hours is
dividing product Average annual representative of
capacity by usage of 1095 dehumidifier use.
efficiency and hours based on
then multiply by AHAM estimates;
annual hourly Variability of
usage. usage based on
multiple sources.
Cooking Products.......... Use recent survey Recent survey Recent survey data Section II.D.3.
data to estimate data from are indicative of
annual energy California and current household
use. Florida--indicat cooking habits;
es a drop in Historical data
annual energy from DOE's 1996
use of ~40% for analysis on
electric and gas residential
ranges and ~15% cooking products
for microwave are still
ovens relative representative of
to DOE test component energy
procedure use (e.g., self-
estimates; cleaning, clock,
Variability of ignition).
usage based on
EIA's RECS.
Commercial Clothes Washers Establish per- Per-cycle energy Per-cycle energy Section II.D.4.
cycle energy and and water use; use data in DOE's
water use and Average daily 2000 TSD on
then multiply by usage of 3.4 residential
annual cycles. cycles for multi- clothes washers
family and 6 is representative
cycles for of per-cycle
laundromats; drying and per-
Variability of cycle machine
usage based on energy for
multiple sources. commercial
washers.
Markups to Determine
Equipment Price
(TSD Chapter 7):
Dishwashers............... Assess financial Distribution Markups for Section II.E.
Dehumidifiers............. data from: (1) channels; SEC baseline and more-
Cooking Products.......... U.S. Securities reports on efficient
Commercial Clothes Washers and Exchange appliance equipment are
Commission (SEC) manufacturers; different.
reports on U.S. Census
appliance Business
manufacturers to Expenditure
develop Survey; State
manufacturer sales taxes;
markups and (2) Shipments to
the U.S. Census different States.
Business
Expenditure
Survey to
develop retailer
and commercial
distributor
markups. Use
markups to
transform
manufacturer
costs into
consumer prices.
[[Page 64435]]
LCC and PBP
(TSD Chapter 8):
Dishwashers............... Use Monte Carlo Manufacturer Only 3% of II.G.4
simulation in costs; Markups consumers
combination with (including sales purchase
inputs that are taxes); dishwashers at
characterized Installation existing minimum
with probability costs; Annual standards (based
distributions to energy (and on AHAM data);
establish a water) Standards do not
distribution of consumption; impact repair and
consumer Energy (and maintenance
economic impacts water) prices costs; AEO2007
(i.e., LCC and future basis for energy
savings and trends; price forecasts;
PBPs) that Maintenance and Average product
identify the repair costs; lifetime is 12.3
percent of. Product years; Average
lifetime; discount rate is
Discount rates. 5.6%.
Dehumidifiers............. ................. ................. Approximately 30%
of consumers
purchase
dehumidifiers at
existing minimum
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; Average
discount rate is
5.6%.
Cooking Products.......... ................. ................. For gas ranges,
only 18 percent
of consumers
purchase
equipment with
standing pilots;
For electric
cooking products
and microwave
ovens, 100
percent of
consumer purchase
equipment at
baseline levels;
Average product
lifetime is 19
years for
electric and gas
ranges and 9
years for
microwave ovens;
Standards do not
impact repair and
maintenance
costs; AEO2007
basis for energy
price forecasts;
Average discount
rate is 5.6%.
Commercial Clothes Washers ................. ................. Approximately 80
percent of
consumers
purchase
equipment at
existing minimum
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;
Discount rate can
be estimated by
company-weighted
average cost of
capital.
Shipments (TSD Chapter 9):
[[Page 64436]]
Dishwashers............... Forecast Historical Market segments II.H.3.
Dehumidifiers............. shipments shipments (for are: new
Cooking Products.......... through the use calibration construction,
Commercial Clothes Washers of a product purposes); replacements, and
stock accounting Historical first-time owners
model by product (existing
dividing market saturations; New households
into segments-- construction without the
e.g., new forecasts; product);
construction, Survival Sensitivity to
replacements, functions (based `relative price'
and early on product is low.
replacements, or lifetimes); Market segments
first-time Sensitivity to are: replacements
owners; Use `relative and first-time
increases in price,' i.e., owners;
purchase price sensitivity to Sensitivity to
and savings in the combined `relative price'
operating costs effect of is low.
to forecast the purchase price Market segments
impact of increases, are: new
standards on operating cost construction,
shipments. savings, and replacements, and
household income. early
replacements;
Sensitivity to
`relative price'
is low.
Market segments
are: new
construction and
replacements; 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 forecasted Annual shipments Section II.I.4.
Dehumidifiers............. annual energy shipments; from shipments
Cooking Products.......... (and water) use, Forecasted base model; Forecasted
Commercial Clothes national annual case and base case and
Washers.. equipment costs, standards case standards case
and national efficiencies; efficiencies
annual operating Per-unit annual remain frozen at
cost savings. energy (and levels in the
water) year 2012;
consumption, Per- National Energy
unit total Modeling System
installed costs; (NEMS) basis for
Per-unit site-to-source
operating costs; conversion
Site-to-source factors; Discount
conversion rates are 3
factors for percent and 7
electricity and percent real
natural gas; based on Office
Discount rates; of Management and
Effective date Budget (OMB)
of standard; and guidelines;
Present year. Future costs
discounted to
present year:
2007.
----------------------------------------------------------------------------------------------------------------
1. Engineering Analysis
The engineering analysis establishes the relationship between the
cost and efficiency of a product DOE is evaluating for standards. This
relationship serves as the basis for cost and benefit calculations for
individual consumers, manufacturers, and the Nation. The engineering
analysis identifies representative baseline equipment, which is the
starting point for analyzing technologies that provide energy
efficiency improvements. Baseline equipment here refers to a model or
models having features and technologies typically found in equipment
currently offered for sale. The baseline model in each product class
represents the characteristics of products in that class, and, for
products already subject to energy conservation standards, usually is a
model that just meets the current standard. After identifying the
baseline models, DOE estimates their manufacturing cost, after which,
DOE estimates the incremental manufacturing costs for producing more
efficient equipment.
For dishwashers, dehumidifiers, and CCWs, the engineering analysis
uses industry-supplied cost-efficiency data, which are based on an
efficiency-level approach (which calculates the relative costs of
achieving increases in energy efficiency levels), and cost-efficiency
curves that DOE derived based on a design-option approach (which
calculates the incremental costs of adding specific design options to a
baseline model). For kitchen ranges and ovens (including microwave
ovens), DOE established cost-efficiency curves using its 1996 Technical
Support Document for Residential Cooking Products,\2\ updated to the
present time in the 2007 TSD for this rulemaking, as discussed below.
Some stakeholders provided comments to DOE that the design options and
associated efficiency increments were still valid for cooking products
other than microwave ovens. For microwave ovens, DOE analyzed current
efficiency data to validate the efficiency increments specified in the
1996 technical analysis, after which it was determined that no changes
to those increments were necessary. To determine manufacturing cost
increments, DOE, with the concurrence of manufacturers, used producer
price index (PPI) data from the Bureau of Labor Statistics (BLS) to
scale costs identified in the 1996 analysis to 2006$. Section II.C on
the engineering analysis discusses this cost-efficiency relationship,
as well as the product
[[Page 64437]]
classes analyzed, the representative baseline units, and the
methodology to be used to extend the analysis to product classes for
which DOE did not receive data
---------------------------------------------------------------------------
\2\ Available online at DOE's website: https://
www.eere.energy.gov/buildings/appliance_standards/residential/
cooking_products_0998_r.html.
---------------------------------------------------------------------------
2. Energy and Water Use Characterization
The energy use and water characterization provides estimates of
annual energy and water consumption for the four appliance products,
which DOE uses in the subsequent LCC and PBP analyses and the national
impact analysis (NIA). DOE developed energy consumption estimates for
all of the product classes analyzed in the engineering analysis, as the
basis for its energy and water use estimates. In the case of
dishwashers, DOE used the annual usage (in cycles per year) established
in its test procedure to estimate the product's annual energy and water
use. For dehumidifiers, DOE relied on industry-supplied estimates of
annual usage (in hours per year) to estimate the product's annual
energy use. For kitchen ranges and ovens, the 2004 California
Residential Appliance Saturation Study (CA RASS) \3\ and a year-long
monitoring study conducted in 1999 by the Florida Solar Energy Center
(FSEC) \4\ indicate that household cooking has continued to drop since
the mid-1990s; DOE used these surveys as the basis for estimating
product annual energy use. For CCWs, DOE used industry-sponsored
research to estimate the product's annual energy and water use. For
further details on the CCW estimates, see section II.D.4 of this ANOPR.
---------------------------------------------------------------------------
\3\ California Energy Commission. California Statewide
Residential Appliance Saturation Study, June 2004. Prepared for the
California Energy Commission by KEMA-XENERY, Itron, and RoperASW.
Contract No. 400-04-009. https://www.energy.ca.gov/appliances/rass/
index.html.
\4\ Parker, D. S. Research Highlights from a Large Scale
Residential Monitoring Study in a Hot Climate. Proceeding of
International Symposium on Highly Efficient Use of Energy and
Reduction of its Environmental Impact, January 2002. Japan Society
for the Promotion of Science Research for the Future Program, Osaka,
Japan. JPS-RFTF97P01002: pp. 108-116. Also published as FSEC-PF369-
02, Florida Solar Energy Center, Cocoa, FL. https://www.fsec.ucf.edu/
en/publications/html/FSEC-PF-369-02/index.htm.
---------------------------------------------------------------------------
3. Markups to Determine Equipment Price
DOE derives consumer prices for products based on manufacturer
markups, retailer markups (for residential products), distributor
markups (for CCWs), and sales taxes. In deriving these markups, DOE has
determined: (1) The distribution channels for product sales; (2) the
markup associated with each party in the distribution channels, and (3)
the existence and magnitude of differences between markups for baseline
equipment (``baseline markups'') and for more-efficient equipment
(``incremental markups''). DOE calculates both overall baseline and
overall incremental markups based on the product markups at each step
in the distribution channel. It defines the overall baseline markup as
the ratio of consumer price (not including sales tax) and manufacturer
cost for baseline equipment; the overall incremental markup relates the
change in the manufacturer sales price of higher-efficiency models (the
incremental cost increase) to the change in the retailer or distributor
sales price. DOE determined manufacturer markups through the use of
U.S. Securities and Exchange Commission (SEC) reports on appliance
manufacturers, and used U.S. Census Business Expenditure Surveys to
develop retailer and commercial distributor markups. DOE collected
consumer retail prices for each of the four appliance products to
provide a rough validation of its markups for baseline equipment.
Baseline equipment is produced in large volumes, is not heavily laden
with consumer features, and is typically competitively priced by
retailers and distributors; therefore, collected retail prices of
baseline equipment are likely to reflect the actual cost of producing
and selling minimally-compliant products.
Because DOE's approach for calculating baseline retail prices
through the use of manufacturing costs, baseline markups, and sales
taxes are intended to capture only the cost of producing minimally-
compliant equipment, any collected baseline retail prices serve as a
good check on the prices calculated through the markup approach. But
because more-efficient equipment often includes non-energy related
features, DOE cannot rely solely on collected retail prices for high-
efficiency products to validate the prices determined through its
markup approach. Current retail prices for high-efficiency equipment
likely reflect the added cost of consumer amenities that have no impact
on efficiency and, therefore, mask the incremental price associated
with features that only affect product efficiency.
4. Life-Cycle Cost and Payback Period Analyses
The LCC and PBP analyses determine the economic impact of potential
standards on individual consumers. The LCC is the total consumer
expense for a product over the life of the product. The LCC analysis
compares the LCCs of products designed to meet possible energy-
efficiency standards with the LCCs of the products likely to be
installed in the absence of standards. DOE determines LCCs by
considering: (1) Total installed cost to the purchaser (which consists
of manufacturer costs, sales taxes, distribution chain markups, and
installation cost); (2) the operating expenses of the product
(determined by energy and water use, energy and water prices, and
repair and maintenance costs); (3) product lifetime; and (4) a discount
rate that reflects the real consumer cost of capital and puts the LCC
in present value terms.
The PBP represents the number of years needed to recover the
increase in purchase price (including the incremental installation
cost) of more-efficient equipment through savings in the operating cost
of the product. It is the change in total installed cost due to
increased efficiency divided by the change in annual operating cost
from increased efficiency.
5. National Impact Analysis
The NIA estimates both the national energy savings (NES) and the
net present value (NPV) of total customer costs and savings expected to
result from new standards at specific efficiency levels (referred to as
candidate standard levels). In conducting the NIA, DOE calculated NES
and NPV for any given candidate standard level for each of the four
appliance products as the difference between a base case forecast
(without new standards) and the standards case forecast (with
standards). DOE determined national annual energy consumption by
multiplying the number of units in use (by vintage \5\) by the average
unit energy (and water) consumption (also by vintage). Cumulative
energy savings are the sum of the annual NES determined over a
specified time period, which in the NIA consisted of the range of years
for which the forecast was made. The national NPV is the sum over time
of the discounted net savings each year, which consists of the
difference between total operating cost savings and increases in total
installed costs. Critical inputs to this analysis include shipments
projections, retirement rates (based on estimated product or equipment
lifetimes), and estimates of changes in shipments and retirement rates
in response to changes in product or equipment costs due to standards.
---------------------------------------------------------------------------
\5\ The term ``vintage'' refers to the age of the unit in years.
---------------------------------------------------------------------------
[[Page 64438]]
C. Authority
Part B of Title III of EPCA established the energy conservation
program for consumer products other than automobiles, including
dishwashers and electric and gas kitchen ranges and ovens (which
include microwave ovens). (This ANOPR refers to electric and gas
kitchen ranges and ovens and microwave ovens collectively as ``cooking
products.'') Amendments to EPCA in the National Appliance Energy
Conservation Act of 1987 (Pub. L. 100-12; NAECA) established energy
conservation standards for dishwashers and cooking products, as well as
requirements for determining whether these standards should be amended.
(See 42 U.S.C. 6295(g) and (h), respectively) Subsequent amendments
expanded Title III of EPCA to include additional consumer products and
certain commercial and industrial equipment, including dehumidifiers
and CCWs. In particular, sections 135(c)(4) and 136(e) of the Energy
Policy Act of 2005, Public Law 109-58; (EPACT 2005) amended EPCA to
authorize DOE to consider the need to modify the energy conservation
standards that the Act, as amended, prescribed for dehumidifiers (42
U.S.C. 6295(cc)) and for CCWs (42 U.S.C. 6313(e)), respectively. This
includes authority for DOE to amend the water efficiency standard the
Act, as amended, prescribes for commercial clothes washers.
Before DOE prescribes any new or amended standard for any of the
four appliance products, however, it must first solicit comments on a
proposed standard. Moreover, DOE must design each new or amended
standard for these products to achieve the maximum improvement in
energy efficiency that is technologically feasible and economically
justified, and such a standard must also result in significant
conservation of energy. (42 U.S.C. 6295(o)(2)(A) and (o)(3); 42 U.S.C.
6316(a)) To determine whether a proposed standard is economically
justified, DOE must, after receiving comments on the proposed standard,
determine whether the benefits of the standard exceed its burdens to
the greatest extent practicable, weighing the following seven factors:
1. The economic impact of the standard on manufacturers and
consumers of products subject to the standard;
2. The savings in operating costs throughout the estimated average
life of the covered products in the type (or class) compared to any
increase in the price, initial charges, or maintenance expenses for the
covered products which are likely to result from the imposition of the
standard;
3. The total projected amount of energy, or as applicable, water,
savings likely to result directly from the imposition of the standard;
4. Any lessening of the utility or the performance of the covered
products likely to result from the imposition of the standard;
5. The impact of any lessening of competition, as determined in
writing by the Attorney General, that is likely to result from the
imposition of the standard;
6. The need for national energy and water conservation; and
7. Other factors the Secretary of Energy (Secretary) considers
relevant. (42 U.S.C. 6295(o)(2)(B)(i); 42 U.S.C. 6316(a))
D. Background
1. History of Standards Rulemaking for Residential Dishwashers,
Dehumidifiers, and Cooking Products; and Commercial Clothes Washers
For dishwashers, NAECA amended EPCA to establish prescriptive
standards, requiring that dishwashers be equipped with an option to dry
without heat, and further requiring that DOE conduct two cycles of
rulemakings to determine if more stringent standards are justified. (42
U.S.C. 6295 (g)(1) and (4)) On May 14, 1991, DOE issued a final rule
establishing the first set of performance standards for dishwashers (56
FR 22250); the new standards became effective on May 14, 1994 (10 CFR
430.32(f)). DOE initiated a second standards rulemaking for dishwashers
by issuing an ANOPR on November 14, 1994 (59 FR 56423). However, as a
result of the priority-setting process outlined in its Procedures for
Consideration of New or Revised Energy Conservation Standards for
Consumer Products (the ``Process Rule'') (61 FR 36974 (July 15, 1996);
10 CFR part 430, Subpart C, Appendix A), DOE suspended the standards
rulemaking for dishwashers.
Section 135(c)(4) of EPACT 2005 added dehumidifiers as products
covered under EPCA and established standards for them that will become
effective on October 1, 2007. (42 U.S.C. 6295(cc)) DOE has incorporated
these standards into its regulations (70 FR 60407, 60414 (October 18,
2005); 10 CFR 430.32(v)). The amendments to EPCA also require that DOE
issue a final rule by October 1, 2009, to determine whether these
standards should be amended. (42 U.S.C. 6295(cc)) If amended standards
are justified, they must become effective by October 1, 2012. (Id.) In
the event that DOE fails to publish such a final rule, the EPACT 2005
specifies a new set of amended standards with an effective date of
October 1, 2012. (Id.)
As with dishwashers, NAECA amended EPCA to establish prescriptive
standards for cooking products, requiring gas ranges and ovens with an
electrical supply cord that are manufactured on or after January 1,
1990 not to be equipped with a constant burning pilot, and requiring
DOE to conduct two cycles of rulemakings for ranges and ovens to
determine if the standards established should be amended. (42 U.S.C.
6295 (h)(1)-(2)) DOE initially analyzed standards for cooking products
as part of an eight-product standards rulemaking. It issued a notice of
proposed rulemaking (NOPR) on March 4, 1994, proposing performance
standards for gas and electric residential cooking products, including
microwave ovens (59 FR 10464). In accordance with the Process Rule, DOE
refined its standards analysis for cooking products. For gas cooking
products, DOE focused on the economic justification for eliminating
constant burning pilots. Partially due to the difficulty of
conclusively demonstrating that elimination of constant burning pilots
was economically justified for gas cooking products without an
electrical supply cord, DOE issued a final rule on September 8, 1998,
that covered only electric cooking products, including microwave ovens
(63 FR 48038). The final rule found that no standards were justified
for electric cooking products. DOE never completed its standards
rulemaking for gas cooking products.
Similar to dehumidifiers, EPACT 2005 included amendments to EPCA
that added CCWs as covered equipment, and it also established standards
for such equipment that is manufactured on or after January 1, 2007.
(EPACT 2005, section 136(a) and (e); 42 U.S.C. 6311(1) and 6313(e)) DOE
has incorporated these standards into its regulations (70 FR 60407,
60416 (October 18, 2005); 10 CFR 431.156). EPACT 2005 also requires
that DOE issue a final rule by January 1, 2010, to determine whether
these standards should be amended. (EPACT 2005, section 136(e); 42
U.S.C. 6313(e))
2. Current Rulemaking Process
To initiate the current rulemaking to develop standards for the
four appliance products, on March 15, 2006, DOE published on its Web
site the Rulemaking Framework for Commercial Clothes Washers and
Residential Dishwashers, Dehumidifiers, and Cooking Products (the
Framework
[[Page 64439]]
Document). The Framework Document describes the procedural and analytic
approaches DOE anticipates using to evaluate the establishment of
energy conservation standards for these products. This document is
available at: https://www.eere.energy.gov/buildings/appliance_
standards/pdfs/home_appl_framework_31506.pdf.
DOE subsequently published a notice announcing the availability of
the Framework Document, inviting written public comments to be
submitted by May 11, 2006, and announcing a public meeting to discuss
the proposed analytical framework for this rulemaking (71 FR 15059
(March 27, 2006)). At the April 27, 2006 public meeting, DOE described
the different analyses it would conduct, such as the LCC and PBP
analyses, the methods proposed for conducting them, and the
relationship among the various analyses. Manufacturers, trade
associations, environmental advocates, regulators, and other interested
parties attended the meeting. The major issues discussed at the public
meeting were: (1) Relevance of the existing DOE test procedure for
microwave ovens; (2) baseline unit definitions for the four appliance
products; (3) product classes for the four appliance products; (4)
consideration of limiting standby power as a design option for all four
appliance products; (5) technology options for improving efficiency for
all four appliance products; (6) type of approach to employ for the
engineering analysis; (7) efficiency levels to consider for all four
appliance products; (8) inclusion of a water factor for dishwashers;
(9) consideration of cleaning performance in setting dishwasher
standards; (10) implications of clothes container volume on CCW
efficiency; (11) proposed approaches for specifying typical annual
energy and water consumption for all four products; (12) potential data
sources for characterizing variability in annual energy and water
consumption; (13) typical distribution channels and markups for all
four appliance products; (14) data sources for retail prices; (15) type
of approach to employ for the LCC and PBP analyses; (16) variability of
forecasted energy and water prices; (17) repair, maintenance, and
installation cost relationship to product efficiency; (18) product
lifetimes; (19) development of consumer discount rates; (20) purchase
price impacts on product shipments; (21) forecasted saturation rates of
commercial clothes washers; (22) consumer subgroups; (23) water and
wastewater utility impacts; and (24) wastewater discharge impacts.
Written comments submitted during the Framework Document comment
period elaborated on the issues raised at the meeting and also
addressed other major issues, including the following: (1) Transparency
of manufacturer cost data development; (2) engineering data
availability for dishwashers, kitchen ranges and ovens, and CCWs; and
(3) inclusion of embedded energy in supplying water and treating
wastewater.
DOE developed two spreadsheet tools for this rulemaking. The first
tool calculates LCC and PBPs. There are six LCC spreadsheets, one each
for the following products: (1) Dishwashers, (2) dehumidifiers, (3)
cooktops, (4) ovens, (5) microwave ovens, and (6) CCWs. Each of the LCC
spreadsheets includes product efficiency distributions and has the
capability to determine LCC savings and PBPs based on average values.
The spreadsheets also can be combined with Crystal Ball (a commercially
available software program) to generate a Monte Carlo simulation, which
incorporates uncertainty and variability considerations. The second
tool (the NIA spreadsheet tool) calculates the impacts of candidate
standards at various levels on shipments and calculates the NES and NPV
at various candidate standard levels. There are five NIA spreadsheets,
one each for the following products and combinations of products: (1)
Dishwashers, (2) dehumidifiers, (3) cooktops and ovens, (4) microwave
ovens, and (5) CCWs. DOE posted these spreadsheets on its Web site on
December 4, 2006, for early stakeholder review and comment.\6\
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\6\ Available online at DOE's Web site: https://
www.eere.energy.gov/buildings/appliance_standards/residential/
cooking_products.html
_____________________________________-
Comments received since publication of the Framework Document have
helped identify issues involved in this rulemaking, and have provided
information that has contributed to DOE's proposed resolution of these
issues. This ANOPR quotes and summarizes many of these public comments.
A parenthetical reference at the end of a quotation or paraphrase
provides the location of the item in the public record.
3. Analysis Process
Table I.2 sets forth the analyses DOE has conducted and intends to
conduct in its evaluation of standards for CCWs, and residential
dishwashers, cooking products, and dehumidifiers. Until recently, DOE
performed the manufacturer impact analysis (MIA) in its entirety
between the ANOPR and NOPR during energy conservation standards
rulemakings. As noted in the table, however, DOE has performed a
preliminary MIA for this ANOPR. DOE believes this change will improve
the rulemaking process.
Table I.2.--The Four Appliance Products--Analysis Process
------------------------------------------------------------------------
ANOPR NOPR Final rule
------------------------------------------------------------------------
Market and technology Revised ANOPR Revised analyses.
assessment. analyses.
Screening analysis........... Life-cycle cost
sub-group
analysis.
Engineering analysis......... Manufacturer
impact
analysis.
Energy use and end-use load Utility impact
characterization. analysis.
Markups for equipment price Net national
determination. employment
impacts.
Life-cycle cost and payback Environmental
period analyses. assessment.
Shipments analysis........... Regulatory
impact
analysis.
National impact analysis.....
Preliminary manufacturer
impact analysis.
------------------------------------------------------------------------
The analyses listed in Table I.2 reflect analyses used in the
rulemaking, including the development of economic models and analytical
tools. In addition, in an effort to support groups of interested
parties seeking to develop and present consensus recommendations on
standards, DOE posted draft versions of its LCC and NIA spreadsheets on
its Web site. If timely new data, models, or tools that enhance the
development of standards become
[[Page 64440]]
available, DOE will incorporate them into this rulemaking.
4. Miscellaneous Rulemaking Issues
a. Joint Stakeholder Recommendations
The Edison Electric Institute (EEI) suggested that DOE should use a
negotiated rulemaking process for residential dishwashers and cooking
equipment, because manufacturers appear to want regulatory certainty
for these products. EEI suggested a separate negotiated process for
CCWs because these products are designed for a different market. For
dehumidifiers, EEI suggested DOE analyze the standards identified in
EPACT 2005 that are due to become effective in 2012, and if they are
technically feasible, economically justified, and will not reduce
competition, consider a negotiated rulemaking so that standards can be
issued before the October 1, 2009 deadline mandated by EPACT 2005.
(EEI, No. 7 at p. 2) \7\
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\7\ A notation in the form ``EEI, No. 7, p. 2'' identifies a
written comment that DOE has received and has included in the docket
of this rulemaking. This particular notation refers to a comment (1)
by the Edison Electric Institute, (2) in document number 7 in the
docket of this rulemaking, and (3) appearing on page 2 of document
number 7.
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The Process Rule specifically identifies ``consensus proposals for
new or revised standards as an effective mechanism for balancing the
economic, energy, and environmental interests affected by standards.
Thus, notwithstanding any other policy on selection of proposed
standards, a consensus recommendation on an updated efficiency level
submitted by a group that represents all interested parties will be
proposed by DOE if it is determined to meet the statutory criteria.''
(10 CFR Part 430, Appendix A to Subpart C, section 5(e)(2)). Therefore,
DOE encourages the submittal of any consensus proposals or joint
stakeholder recommendations pertaining to any or all of the four
appliance products. If the supporting analyses provided by the group
address all of the statutory criteria and use valid economic
assumptions and analytical methods, DOE expects to use these supporting
analyses as the basis of a proposed rule.
b. Standby Power for Dishwashers and Cooking Products
Standby power is currently incorporated into the energy factor \8\
(EF) for conventional ovens via the measurement of clock power
consumption and for gas cooktops via the energy consumption of constant
burning pilots, both of which are incorporated into the EF calculation
for their respective products. The dishwasher test procedure includes a
measurement of standby power, but standby energy use is not
incorporated into calculated EF. The issue of whether to include
standby power in the energy efficiency metrics for dishwashers and
cooking products was addressed in several comments that DOE received.
The Alliance to Save Energy, American Council for an Energy-Efficient
Economy (ACEEE), Appliance Standards Awareness Project, Natural
Resources Defense Council, and Northeast Energy Efficiency Partnerships
(hereafter ``Joint Comment'') stated that standby energy use should be
included in the analyses for all products, with the appropriate metric
for the standards being annual energy consumption rather than energy
factor. The Joint Comment stated that EPACT 2005 instructs DOE to
consider standby power in its rulemaking for all products, and where
significant, to include standby power in some fashion into the
appropriate standard. The Joint Comment
