ANALYTICAL RESULTS IN SUPPORT OF STAKEHOLDER NEGOTIATIONS ON 

AMENDED ENERGY CONSERVATION STANDARDS FOR 

RESIDENTIAL CLOTHES WASHERS, 

RESIDENTIAL REFRIGERATOR-FREEZERS AND FREEZERS,
 

AND ROOM AIR CONDITIONERS 

Update to May 4 and 5, 2010 Results 

May 20, 2010 

The following analytical results have been generated by Lawrence Berkeley National Laboratory 

(LBNL) and Navigant Consulting, Inc. (NCI) to support stakeholder negotiations concerning 

amended energy conservation standards for residential clothes washers, residential refrigeratorsfreezers and freezers, and room air conditioners. The analytical results presented here are an 

update to results provided on April 15, May 4, and May 5, 2010. The results provided here, as 

well as those provided earlier on the above dates, are based on inputs (e.g., manufacturer selling 

prices as a function of efficiency) and analytical tools which are still under review. Therefore, 

the following information may not reflect final results to be published in subsequent DOE 

rulemaking documents. 

CLOTHES WASHERS 

Life-cycle cost (LCC), payback period (PBP), and national impact analysis (NIA) results were 

requested for the following efficiency levels. 

Table 1. Clothes Washer Efficiency Levels: Stakeholder Requested 

Level Modified Energy Factor 

(MEF) 

Water Factor 

(WF) 

Older Energy Star 1.42 9.0 

Old Energy Star 1.72 8.0 

Energy Star®

/ CEE Tier 1 1.80 7.5 

CEE Tier 2 2.00 6.0 

CEE Tier 3 2.20 4.5 

New higher tier 2.40 4.0 

Notes: The Energy Star® level will shift to CEE Tier 2 level effective 1/1/2011. California’s pending petition for waiver 

from preemption would require a maximum 6.0 water factor. 

Analyses have been designed for DOE to analyze most of the requested efficiency levels. In 

addition, standby power limitations have also been considered. The efficiency levels and standby 

power limits are listed in the table below. 

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EERE-2008-BT-STD-0019 COMMENT 34
Table 2. Clothes Washer Efficiency Levels: ‘Stakeholder Requested’ and ‘Analyzed for DOE’ 

Requested Levels Top-Loading Washers Front-Loading Washers 

MEF WF Effcy 

Level MEF WF Standby Power 

Effcy 

Level MEF WF Standby Power 

Baseline 1.26 9.50 0.00 Baseline 1.72 8.00 2.30 

1.42 9.0 1 1.40 9.50 0.00 - - -

1.72 8.0 2 1.72 8.00 0.00 1 1.72 8.00 1.70 

2 1.72 8.00 0.08 

1.80 7.5 

3 1.80 7.50 2.30 

4 1.80 7.50 1.70 3 1.80 7.50 0.08

5 1.80 7.50 0.08 

2.00 6.0 6 2.00 6.00 0.08 4 2.00 6.00 0.08 

2.20 4.5 7 2.26 4.48 0.08 5 2.20 4.50 0.08 

2.40 4.0 - - - - 6 2.40 4.20 0.08 

- - - - - - 7 2.60 3.80 0.08 

- - - - - - 8 2.89 3.36 0.08 

The following LCC, PBP, and NIA results are based on the efficiency levels that have been 

analyzed for DOE. 

Technology Description 

The following tables list the technologies that comprise the MEF/WF efficiency levels that were 

considered for top-loading and front-loading washers. 

Table 3. Top-Loading Clothes Washer Technologies by Efficiency Level 

Efficiency Level MEF/WF Design Options 

1 1.40/9.5 

 Thermistor Temperature Control 

 Pressure Sensor for Fill Level Control 

 Two-Speed Motor 

2 1.72/8.0 

Efficiency Level 1 Design Options + 

 Thermistor Temperature Control with Additional Setpoints 

 Electronic Pressure Sensor and Flowmeter for Fill Level Control 

 Increased Capacity 

 Fabric Softener Option 

 Spray Rinse 

3, 4, 5 1.80/7.5 

Efficiency Level 2 Design Options + 

 Floating Basket/Back EMF Fill Level Control 

 Separate Solenoid Water Flow Control 

 Increased Capacity 

 Direct-Drive Motor 

 Electronic Controls 

 Stainless Steel Wash Basket 

 Water Recirculation 

6 2.00/6.0 

Efficiency Levels 3/4/5 Design Options + 

 Increased Capacity 

 Low-Profile Agitator 

 Multiple Spin Speeds 

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EERE-2008-BT-STD-0019 COMMENT 34
7 2.26/4.48 

Efficiency Level 6 Design Options + 

 Increased Capacity 

 Internal Water Heating 

Table 4. Front-Loading Clothes Washer Technologies by Efficiency Level 

Efficiency Level MEF/WF Design Options 

3 1.80/7.5  None (same as baseline) 

4 2.00/6.0 

Efficiency Level 3 Design Options + 

 Increased Capacity 

 Internal Water Heating 

 Thermistor Temperature Control 

 Increased Maximum Spin Speed 

5 2.20/4.5 

Efficiency Level 4 Design Options + 

 Increased Capacity 

 Electronic Pressure Sensor and Flowmeter for Fill Level Control 

 Increased Maximum Spin Speed 

 Improved Control Scheme 

 Direct-Drive Motor 

6 2.40/4.2 

Efficiency Level 5 Design Options + 

 Increased Capacity 

 Increased Maximum Spin Speed 

 Further Improvements in Control Scheme 

7 2.60/3.8 

Efficiency Level 6 Design Options + 

 Increased Capacity 

 Increased Maximum Spin Speed 

 Further Improvements in Control Scheme 

 Water Recirculation 

8 2.89/3.36 

Efficiency Level 6 Design Options + 

 Increased Capacity 

 Increased Maximum Spin Speed 

 Further Improvements in Control Scheme 

LCC and PBP Results 

The following LCC and PBP results were calculated separately for top-loading and front-loading 

clothes washers. Top-loading results in the ‘May 4’ version were generated for two different 

scenarios. The scenarios differed based on the assumptions regarding the base-case efficiency 

distribution. The base-case efficiency distribution represents the distribution of products by 

efficiency in the absence of new standards in the year 2015 (the year in which standards are 

assumed to be effective). The scenarios are identified as C and D to maintain consistency with 

how results were identified in the ‘April 16’ and ‘May 4’ versions. Each scenario is based on 

manufacturing costs developed by DOE. As described in the ‘May 4’ version of the results, 

forecasted water and wastewater prices were revised to reflect the historical trend observed from 

1975 to 2008. The ‘April 15’ version had used higher forecasted prices based on the relatively 

steeper price gain observed since 2004. 

Top-Loading Scenario C: 

Manufacturer Costs: DOE. 

Base Case Efficiency Distribution: AHAM; Same as the year 2008. 

Top-Loading Scenario D: 

Manufacturer Costs: DOE. 

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EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

 

 

Base Case Efficiency Distribution: Migration of products to 1.72 MEF by 2015. 

The LCC and PBP result shown in Tables 5, 6C, and 6D are identical to the results in the ‘May 

4’ version. 

Table 5. Front-Loading Washers: LCC and PBP Results 

Effcy 

Level 

2015 

Base 

Case 

Effcy 

Distr 

MEF WF Standby 

Power 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Households that Experience 

Median Average cu.ft./ 

kWh/cyc 

gal / 

cu.ft watt Net Cost No 

Impact 

Net 

Benefit 

0 0.0% 1.72 8.00 2.30 

1 0.0% 1.72 8.00 1.70 $0 0% 100% 0% NA NA 

2 0.0% 1.72 8.00 0.08 $0 0% 100% 0% NA NA 

3 4.3% 1.80 7.50 0.08 $0 0% 100% 0% NA NA 

4 24.0% 2.00 6.00 0.08 $6 0% 96% 4% 0.9 1.1 

5 48.9% 2.20 4.50 0.08 $78 0% 72% 27% 1.2 1.6 

6 11.4% 2.40 4.20 0.08 $198 7% 23% 70% 2.7 3.7 

7 11.4% 2.60 3.80 0.08 $229 11% 12% 77% 3.4 4.7 

8 0.0% 2.89 3.36 0.08 $371 13% 0% 87% 3.2 4.7 

Table 6C. Top-Loading Washers: LCC and PBP Results, Scenario C 

Effcy 

Level 

2015 

Base 

Case 

Effcy 

Distr 

MEF WF Standby 

Power 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Households that Experience 

Median Average cu.ft./ 

kWh/cyc 

gal / 

cu.ft watt Net Cost No 

Impact 

Net 

Benefit 

0 43.60% 1.26 9.50 0.00 

1 43.60% 1.40 9.50 0.00 -$35 43% 56% 1% 0.4 0.3 

2 1.85% 1.72 8.00 0.00 $137 9% 13% 78% 2.3 4.0 

3 0.62% 1.80 7.50 2.30 $16 54% 11% 35% 11.4 17.5 

4 0.62% 1.80 7.50 1.70 $16 54% 11% 35% 11.1 17.7 

5 0.62% 1.80 7.50 0.08 $35 48% 10% 42% 10.4 17.2 

6 4.55% 2.00 6.00 0.08 $203 21% 9% 70% 4.5 8.1 

7 4.55% 2.26 4.48 0.08 $348 19% 5% 76% 4.2 7.5 

Table 6D. Top-Loading Washers: LCC and PBP Results, Scenario D 

Effcy 

Level 

2015 

Base 

Case 

Effcy 

Distr 

MEF WF Standby 

Power 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Households that Experience 

Median Average cu.ft./ 

kWh/cyc 

gal / 

cu.ft watt Net 

Cost 

No 

Impact 

Net 

Benefit 

0 0.00% 1.26 9.50 0.00 

1 0.00% 1.40 9.50 0.00 $0 0% 100% 0% NA NA 

2 89.05% 1.72 8.00 0.00 $0 0% 100% 0% NA NA 

3 0.62% 1.80 7.50 2.30 $16 54% 11% 35% 11.4 17.5 

4 0.62% 1.80 7.50 1.70 $16 54% 11% 35% 11.1 17.7 

5 0.62% 1.80 7.50 0.08 $35 48% 10% 42% 10.4 17.2 

6 4.55% 2.00 6.00 0.08 $203 21% 9% 70% 4.5 8.1 

7 4.55% 2.26 4.48 0.08 $348 19% 5% 76% 4.2 7.5 

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EERE-2008-BT-STD-0019 COMMENT 34
NIA Results 

The following NIA results provide the national energy savings (NES), national water savings 

(NWS), and net present value (NPV) for the requested efficiency levels. 

As was done for the ‘April 15’ and ‘May 4’ versions of the results, the NIA was conducted using a 

cross-elasticity of demand to determine the change in market share of top- and front-loaders based 

on changes in the incremental price increase for each product class due to increased standards. For 

example, if the incremental price increase due to standards is larger for top-loaders than frontloaders, then front-loading washers are forecasted to gain market share. Shifts in market share 

between top- and front-loaders explains the negative NES and NWS for front-loaders, i.e., increased 

market share and shipments of front-loaders forecasted under the standards case results in increased 

front-loader national energy consumption relative to the front-loader base-case. Of course, the 

increase in front-loader shipments has a corresponding decrease in top-loader shipments, and the 

decreased shipments of top-loaders forecasted under the standards case results in an even further 

decrease in top-loader national energy consumption relative to the top-loader base-case. 

The NIA results below are based on the same two scenarios considered in the LCC and PBP 

analysis. The MEF and WF pairings that were analyzed along with their corresponding top- and 

front-loader efficiency levels and standby power limits are presented in Table 7. 

Table 7. Front- and Top-Loaders Efficiency Levels for MEF and WF pairs 

Efficiency Pairing Top-Loader Front-Loader 

MEF WF 

Efficiency 

Level 

Standby Power 

watt 

Efficiency 

Level 

Standby Power 

watt 

1.40 9.5 1 0.00 0 1.70 

1.72 8.0 2 0.00 2 0.08 

1.80 7.5 5 2.30 3 0.08 

2.00 6.0 6 0.08 4 0.08 

2.20 4.5 7** 0.08 5 0.08 

2.40 4.2 7** 0.08 6 0.08 

** Top-loading washers analyzed as 2.26 MEF / 4.48 WF. 

With the exception of the efficiency pairing of 2.20 MEF/4.5 WF, the NIA results presented in 

Tables 8C and 8D are identical to the results in the ‘May 4’ version. In the ‘May 4’ version, the 

efficiency pairing of 2.20 MEF/4.5 WF was based on efficiency level 6 for top-loaders, rather than 

efficiency level 7. 

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EERE-2008-BT-STD-0019 COMMENT 34
Table 8C. NIA Results, Scenario C 

1.40 MEF / 9.5 WF 1.72 MEF / 8.0 WF 1.80 MEF / 7.5 WF 

FL TL ALL FL TL ALL FL TL ALL 

NES (quad) 0.00 0.03 0.03 -0.23 1.22 0.98 -0.85 1.89 1.04 

NWS (trillion gal.) 0.00 -0.46 -0.46 -0.41 1.93 1.51 -1.50 3.41 1.91 

NPV @ 7% (bill $) -0.04 -1.13 -1.16 -5.45 11.10 5.65 -19.81 20.19 0.38 

NPV @ 3% (bill $) -0.08 -2.75 -2.84 -11.52 26.77 15.25 -41.89 48.14 6.25 

Mkt Shr in 2015 54% 46% 57% 43% 65% 35% 

Mkt Shr in 2030 56% 44% 59% 41% 67% 33% 

2.00 MEF / 6.0 WF 2.20 MEF / 4.5 WF** 2.40 MEF / 4.2 WF** 

FL TL ALL FL TL ALL FL TL ALL 

NES (quad) -0.77 2.07 1.30 -1.01 2.70 1.69 -0.81 2.59 1.78 

NWS (trillion gal.) -1.11 4.64 3.52 -1.16 6.71 5.55 -0.88 6.51 5.63 

NPV @ 7% (bill $) -17.73 24.05 6.32 -23.90 33.84 9.94 -22.81 32.03 9.22 

NPV @ 3% (bill $) -37.07 57.68 20.61 -49.50 80.83 31.33 -46.55 76.85 30.30 

Mkt Share in 2015 64% 36% 68% 32% 67% 33% 

Mkt Share in 2030 67% 33% 71% 29% 70% 30% 

** Top-loading washers analyzed as 2.26 MEF / 4.48 WF. 

Table 8D. NIA Results, Scenario D 

1.40 MEF / 9.5 WF 1.72 MEF / 8.0 WF 1.80 MEF / 7.5 WF 

FL TL ALL FL TL ALL FL TL ALL 

NES (quad) 0.00 0.00 0.00 0.00 0.00 0.00 -0.59 0.61 0.03 

NWS (trillion gal.) 0.00 0.00 0.00 0.00 0.00 0.00 -1.03 1.33 0.30 

NPV @ 7% (bill $) 0.00 0.00 0.00 0.00 0.00 0.00 -13.67 7.90 -5.77 

NPV @ 3% (bill $) 0.00 0.00 0.00 0.00 0.00 0.00 -28.91 18.93 -9.98 

Mkt Shr in 2015 54% 46% 54% 46% 61% 39% 

Mkt Shr in 2030 56% 44% 56% 44% 64% 36% 

2.00 MEF / 6.0 WF 2.20 MEF / 4.5 WF** 2.40 MEF / 4.2 WF** 

FL TL ALL FL TL ALL FL TL ALL 

NES (quad) -0.51 0.85 0.34 -0.74 1.53 0.79 -0.54 1.42 0.88 

NWS (trillion gal.) -0.67 2.88 2.22 -0.71 5.28 4.57 -0.44 5.09 4.65 

NPV @ 7% (bill $) -11.69 13.29 1.61 -17.55 24.30 6.75 -16.41 22.50 6.09 

NPV @ 3% (bill $) -24.31 31.26 6.95 -36.11 56.44 20.33 -33.10 52.51 19.41 

Mkt Share in 2015 61% 39% 65% 35% 63% 37% 

Mkt Share in 2030 63% 37% 67% 33% 66% 34% 

** Top-loading washers analyzed as 2.26 MEF / 4.48 WF. 

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EERE-2008-BT-STD-0019 COMMENT 34
REFRIGERATORS 

Life-cycle cost (LCC), payback period (PBP), and national impact analysis (NIA) results were 

requested for the following product classes (PC) efficiency levels (EL). 

Table 9. Refrigerator and Freezer Efficiency Levels: Stakeholder Requested 

Product EL1 EL2 EL3 EL4 EL5 EL6 EL7 EL8 

PC3: Top Mount 10% 15% 20% 25% 30% 35% 40% 45% 

PC 5: Bottom Mount 10% 15% 20% 25% 30% 35% 40% 45% 

PC 7: Side by Sides 10% 15% 20% 25% 30% 35% 40% 45%** 

PC 9: Vertical freezers 10% 15% 20% 25% 30% 35% 40% 45% 

PC 10: Chest units 10% 15% 20% 25% 30% 35% 40% 45% 

PC 11: Compact fridge 10% 15% 20% 25% 30% 35% 40% 45% 

PC 18: Compact freezers 10% 15% 20% 25% 30% 35% 40% 45% 

** Maximum EL considered in DOE’s Preliminary Analysis = 40%. 

As reported in the ‘April 15’ and ‘May 4’ versions, the maximum reductions in annual energy use 

specified in the preliminary analysis have been reevaluated. As a result of the reevaluation, these 

maximum reductions have tentatively been determined to be overestimated. The table below 

identifies the efficiency levels which are likely to be analyzed for the next phase of the standards 

rulemaking. 

Table 10. Refrigerator and Freezer Efficiency Levels: ‘Analyzed for DOE’ 

Product EL1 EL2 EL3 EL4 EL5 EL6 EL7 EL8 

PC3: Top Mount 10% 15% 20% 25% 30% 31.7% - -

PC 5: Bottom Mount 10% 15% 20% 25% 30% 33.3% - -

PC 7: Side by Sides 10% 15% 20% 25% 30% 31% - -

PC 9: Vertical freezers 10% 15% 20% 25% 30% 35% 40% 43.2% 

PC 10: Chest units 10% 15% 20% 25% 30% 35% - -

PC 11: Compact fridge 10% 15% 20% 25% 30% 35% 40% 45% 

PC 18: Compact freezers 10% 15% 20% 25% 30% 35% 40% -

Also as reported in the ‘April 15’ and ‘May 4’ versions, in addition to the adjustments made to the 

maximum reductions in annual energy use, revisions have been made to the manufacturer selling 

price vs. efficiency relationships. In all cases, the incremental changes in manufacturer selling price 

to achieve reductions in energy use have increased relative to the estimates in the preliminary 

analysis. 

The following LCC, PBP, and NIA results are based on the efficiency levels likely to be 

analyzed for DOE in the next phase of the standards rulemaking. 

Technology Description 

The following figures identify the technologies that comprise the efficiency levels that were 

considered for refrigerators and freezers. Because each efficiency level is comprised of several 

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EERE-2008-BT-STD-0019 COMMENT 34
   

     

       

   

   

technology options, the figures display the range of efficiencies for which each major type of 

technology applies. Of the set of technologies identified, variable-speed compressors (VSC) and 

vacuum insulated panels (VIP) are the most advanced. For standard-sized refrigerators, VSCs 

and VIPs are estimated to be necessary starting at efficiency level 3 (20% lower energy use than 

the baseline). For standard-sized freezers, VSCs are estimated to be necessary starting at 

efficiency level 5 (30%) while VIPs are estimated to be necessary starting at efficiency level 6 

(35%). For compact refrigerators and freezers, VSCs are estimated to be necessary starting at 

efficiency level 4 (25%) while VIPs are estimated to be necessary starting at efficiency level 6 

(35%). 

0% 10% 20% 30% 40% 50%

Modest‐CostOptions(compressor,

fans, heat exchanger)

Controls(adaptive defrost, variable

anti‐sweat)

Variable SpeedCompressor

VacuumInsulationPanels

Figure 1. Standard-Size Refrigerator Technologies by Efficiency Level 

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EERE-2008-BT-STD-0019 COMMENT 34
   

     

   

   

   

   

   

     

   

   

   

0% 10% 20% 30% 40% 50%

Modest‐CostOptions(compressor,

fans, heat exchanger)

Controls(adaptive defrost)

Wall ThicknessIncreases

Variable SpeedCompressor

VacuumInsulationPanels

Figure 2. Standard-Size Freezer Technologies by Efficiency Level 

0% 10% 20% 30% 40% 50%

Modest‐CostOptions(compressor,

fans, heat exchanger)

Wall ThicknessIncreases

Variable SpeedCompressor

VacuumInsulationPanels

Figure 3. Compact Refrigerator and Freezer Technologies by Efficiency Level 

LCC and PBP Results 

Usage Adjustment Factor (UAF) 

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EERE-2008-BT-STD-0019 COMMENT 34
As described in the ‘April 15’ and ‘May 4’ versions, for the preliminary analysis, usage 

adjustment factors (UAF) were developed to convert the rated or test energy consumption of a 

standard-sized refrigerator or freezer into a field-based value. UAF values determined in the 

preliminary analysis were greater than one. In the “May 4’ version, it was reported that an 

evaluation of seven metered refrigerator and freezer end-use studies consisting of over 1,600 data 

points demonstrated that UAFs on average are closer to one. Therefore, only the scenario based 

on UAFs normalized to a weighted-average value of 1.0, i.e., field energy consumption equals 

rated energy consumption (scenario B) was retained and analyzed. In general, this is still the 

case for the results presented below (i.e., the weighted-average UAF is close to 1.0), although the 

implementation of the field-based UAFs have been incorporated so that household-specific 

values are a function of certain characteristics of the household. 

Non-HFC Blowing Agent 

As reported in the ‘May 4’ version, also under evaluation is the impact of non-HFC blowing 

agents on the production of foam insulation due to possible climate change legislation that may 

phase-out the use of HFCs. The potential move from the current blowing agent, HFC-245fa, to 

cyclopentane has the effect of reducing the resistivity of the foam insulation, thereby increasing 

refrigerator and freezer energy use. Therefore, for the same sets of design options, a lower 

efficiency gain is achievable with cyclopentane blown insulation. Table 11 shows the non-HFCbased efficiency levels that correspond with the HFC-based efficiency levels. 

Table 11. Refrigerator and Freezer Efficiency Levels: HFC and Non-HFC Levels 

Product EL1 EL2 EL3 EL4 EL5 EL6 EL7 EL8 

PC3: Top Mount HFC 10% 15% 20% 25% 30% 31.7% - -

Non-HFC 5.5% 10.8% 16% 21.3% 26.5% 28.3% - -

PC 5: Bottom Mount HFC 10% 15% 20% 25% 30% 33.3% - -

Non-HFC 5.5% 10.8% 16% 21.3% 26.5% 30% - -

PC 7: Side by Sides HFC 10% 15% 20% 25% 30% 31% - -

Non-HFC 5.5% 10.8% 16% 21.3% 26.5% 27.6% - -

PC 9: Vertical 

freezers 

HFC 10% 15% 20% 25% 30% 35% 40% 43.2% 

Non-HFC 5.5% 10.8% 16% 21.3% 26.5% 31.8% 37% 40.4% 

PC 10: Chest units HFC 10% 15% 20% 25% 30% 35% - -

Non-HFC 5.5% 10.8% 16% 21.3% 26.5% 31.8% - -

PC 11: Compact 

fridge 

HFC 10% 15% 20% 25% 30% 35% 40% 45% 

Non-HFC 5.5% 10.8% 16% 21.3% 26.5% 31.8% 37% 42.3% 

PC 18: Compact 

freezers 

HFC 10% 15% 20% 25% 30% 35% 40% -

Non-HFC 5.5% 10.8% 16% 21.3% 26.5% 31.8% 37% 

The costs of attaining current standard levels (i.e. 0% efficiency level) while using cyclopentane 

have not been included in this analysis. Hence, the incremental costs for design of products 

using cyclopentane have been adjusted so that the incremental cost is $0 at 0% efficiency level). 

Additional costs associated with the conversion, assuming climate change legislation is enacted, 

would be considered as part of the cumulative regulatory burden in the refrigeration product 

rulemaking. 

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EERE-2008-BT-STD-0019 COMMENT 34
Note, the use of non-HFC-based refrigerants, in particular, isobutane (R-600a), was not 

considered for most of the product classes two reasons: (1) while allowing the use of 

hydrodcarbons such as isobutane in residential refrigeration systems is under consideration by 

both UL and the EPA, the proposed limits are close to 60 grams, which is not sufficient for most 

product classes without the availability of new heat exchanger technology to significantly reduce 

the refrigerant charge amounts, and (2) the expectation that proposed allowances for use of HFCs 

(for example in the Waxman-Markey Bill, H.R. 2454, which was passed by the U.S. House of 

Representatives on June 26, 2009) would be sufficient for use of HFC-134a by the residential 

refrigeration industry, since the majority of HFC consumption is currently used for insulation. 

Isobutane was considered as a design option for compact refrigerators (PC 11). 

CO2 Cap-and-Trade 

As described in an addendum to the ‘May 4’ version, potential U.S. legislation to create a capand-trade program to limit CO2 emissions was assessed by determining its impact on forecasted 

electricity prices. Forecasted increases in electricity prices were analyzed as a sensitivity as part 

of determining the life-cycle cost (LCC) savings and payback periods (PBP). In the addendum 

to the ‘May 4’ version, the sensitivity was performed only for product class 3 (top-mount 

refrigerators) and product class 5 (side-mount refrigerators). The results presented below are 

provided for all product classes. 

Scenarios 

Taking into consideration the issues discussed above pertaining to the UAF, non-HFC blowing 

agents, and potential CO2 cap-and-trade programs, the following LCC and PBP results were 

calculated based on three different efficiency scenarios. The scenarios are identified as B1, B2, 

and B3 to maintain consistency with how the results were identified in the ‘April 16’ and ‘May 

4’ versions. 

HFC Scenario B1: 

UAF: Developed on a household basis resulting in a weighted-average UAF close to 1.0. 

Efficiency: Based on the use of HFC-blown insulation (HFC-245fa). 

Forecasted electricity prices: AEO2010 Reference Case. 

Non-HFC Scenario B2: 

UAF: Developed on a household basis resulting in a weighted-average UAF close to 1.0. 

Efficiency: Based on the use of non-HFC-blown insulation (cyclopentane). 

Forecasted electricity prices: AEO2010 Reference Case. 

HFC with ‘CO2 Cap-and-Trade’ Scenario B3: 

UAF: Developed on a household basis resulting in a weighted-average UAF close to 1.0. 

Efficiency: Based on the use of HFC-blown insulation (HFC-245fa). 

Forecasted electricity prices: AEO2010 Reference Case adjusted to account for CO2 cap-andtrade program. 

The results presented below incorporate further changes not accounted for in the ‘May 4’ version 

including: (1) incorporation of repair costs; (2) as described above, changes in the 

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EERE-2008-BT-STD-0019 COMMENT 34
implementation of the UAF; (3) AEO2010 electricity price forecasts; and (4) changes in the 

base-case efficiency distribution (i.e., the distribution of products by efficiency in the absence of 

new standards in the year 2014 (the year in which standards are assumed to be effective)). The 

above changes were made so that the results presented below will more closely match the results 

DOE will eventually publish for the next phase of the standards rulemaking. 

12 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

Table 12B1. PC 3, Top-Mount Refrigerators: LCC and PBP Results, Scenario B1 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $49 0.9% 22.4% 76.7% 2.3 2.6 

2 (15) $73 1.5% 18.3% 80.3% 2.7 3.0 

3 (20) $45 34.4% 8.9% 56.8% 8.1 10.9 

4 (25) $42 45.8% 0.0% 54.2% 9.6 11.8 

5 (30) -$10 65.8% 0.0% 34.2% 13.5 16.0 

6 (32) -$36 71.6% 0.0% 28.4% 15.0 19.4 

Table 12B2. PC 3, Top-Mount Refrigerators: LCC and PBP Results, Scenario B2 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (6) $27 0.8% 22.4% 76.8% 2.2 2.5 

2 (11) $53 1.5% 18.3% 80.3% 2.7 3.0 

3 (16) $26 40.9% 8.9% 50.2% 9.4 12.0 

4 (21) $25 50.8% 0.0% 49.2% 10.5 12.5 

5 (27) -$24 69.7% 0.0% 30.3% 14.4 16.9 

6 (28) -$50 75.1% 0.0% 24.9% 16.0 19.4 

Table 12B3. PC 3, Top-Mount Refrigerators: LCC and PBP Results, Scenario B3 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $56 0.7% 22.4% 76.9% 2.1 2.4 

2 (15) $83 1.2% 18.3% 80.6% 2.4 2.7 

3 (20) $58 31.1% 8.9% 60.1% 7.4 9.8 

4 (25) $59 41.4% 0.0% 58.6% 8.7 10.6 

5 (30) $12 60.5% 0.0% 39.5% 12.2 14.5 

6 (32) -$14 66.8% 0.0% 33.2% 13.6 16.5 

13 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

Table 13B1. PC 5, Bottom-Mount Refrigerators: LCC and PBP Results, Scenario B1 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $10 0.0% 87.2% 12.8% 2.0 2.2 

2 (15) $15 0.1% 87.1% 12.9% 2.1 2.4 

3 (20) $24 3.2% 68.0% 28.8% 4.4 5.2 

4 (25) $9 65.3% 0.0% 34.7% 14.2 17.4 

5 (30) -$43 80.3% 0.0% 19.7% 19.4 23.9 

6 (33) -$63 81.6% 0.0% 18.4% 19.7 25.4 

Table 13B2. PC 5, Bottom-Mount Refrigerators: LCC and PBP Results, Scenario B2 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (6) $6 0.0% 87.2% 12.8% 1.9 2.2 

2 (11) $11 0.1% 87.1% 12.9% 2.1 2.4 

3 (16) $20 3.0% 68.0% 29.1% 4.4 5.1 

4 (21) $8 63.6% 0.0% 36.4% 13.5 16.4 

5 (27) -$42 79.6% 0.0% 20.4% 18.5 22.5 

6 (30) -$60 80.7% 0.0% 19.3% 18.8 23.6 

Table 13B3. PC 5, Bottom-Mount Refrigerators: LCC and PBP Results, Scenario B3 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $12 0.0% 87.2% 12.8% 1.8 2.0 

2 (15) $17 0.0% 87.1% 12.9% 1.9 2.1 

3 (20) $27 2.7% 68.0% 29.3% 4.0 4.7 

4 (25) $18 60.7% 0.0% 39.3% 12.8 15.4 

5 (30) -$29 76.2% 0.0% 23.8% 17.4 26.3 

6 (33) -$46 77.6% 0.0% 22.4% 17.7 21.9 

14 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

Table 14B1. PC 7, Side-Mount Refrigerators: LCC and PBP Results, Scenario B1 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $21 0.20% 78.08% 21.72% 2.4 2.7 

2 (15) $44 0.50% 52.16% 47.34% 2.4 2.8 

3 (20) $58 7.80% 37.26% 54.94% 3.7 6.5 

4 (25) $55 41.52% 0.02% 58.46% 5.6 12.0 

5 (30) -$30 72.23% 0.00% 27.77% 9.8 20.9 

6 (31) -$51 75.29% 0.00% 24.71% 10.7 21.2 

Table 14B2. PC 7, Side-Mount Refrigerators: LCC and PBP Results, Scenario B2 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (6) $12 0.18% 78.08% 21.74% 2.4 2.6 

2 (11) $36 0.42% 52.14% 47.44% 2.4 2.7 

3 (16) $52 7.10% 37.24% 55.66% 3.7 6.1 

4 (21) $52 39.45% 0.00% 60.55% 5.6 11.2 

5 (27) -$31 71.74% 0.00% 28.26% 9.8 19.5 

6 (28) -$50 74.96% 0.00% 25.04% 10.7 20.4 

Table 14B3. PC 7, Side-Mount Refrigerators: LCC and PBP Results, Scenario B3 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $24 0.15% 78.07% 21.78% 2.2 2.5 

2 (15) $50 0.38% 52.13% 47.49% 2.2 2.5 

3 (20) $68 6.72% 37.23% 56.05% 4.6 5.7 

4 (25) $71 37.31% 0.00% 62.69% 8.6 10.5 

5 (30) -$8 67.58% 0.00% 32.42% 14.9 18.1 

6 (31) -$27 70.84% 0.00% 29.16% 15.8 19.0 

15 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

Table 15B1. PC 9, Upright Freezers: LCC and PBP Results, Scenario B1 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $62 1.7% 19.9% 78.4% 2.3 3.2 

2 (15) $84 9.9% 1.7% 88.5% 4.4 6.6 

3 (20) $111 11.3% 0.6% 88.1% 4.9 10.2 

4 (25) $129 15.7% 0.5% 83.8% 5.8 8.0 

5 (30) $149 17.8% 0.2% 82.0% 6.3 8.6 

6 (35) $129 30.9% 0.0% 69.1% 8.5 12.1 

7 (40) $84 46.4% 0.0% 53.6% 11.3 16.7 

8 (43) -$50 68.6% 0.0% 31.4% 17.1 31.5 

Table 15B2. PC 9, Upright Freezers: LCC and PBP Results, Scenario B2 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (6) $33 1.9% 19.9% 78.2% 2.2 4.1 

2 (11) $58 11.5% 1.7% 86.7% 4.9 7.3 

3 (16) $87 13.0% 0.6% 86.4% 5.2 7.6 

4 (21) $107 17.1% 0.5% 82.4% 6.2 9.2 

5 (27) $130 19.2% 0.2% 80.6% 6.5 8.9 

6 (32) $112 33.0% 0.0% 67.0% 8.8 15.9 

7 (37) $69 48.1% 0.0% 51.9% 11.6 17.5 

8 (40) -$62 70.6% 0.0% 29.4% 17.7 28.5 

Table 15B3. PC 9, Upright Freezers: LCC and PBP Results, Scenario B3 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $70 1.5% 19.9% 78.7% 2.0 2.8 

2 (15) $98 8.2% 1.7% 90.1% 3.9 5.6 

3 (20) $130 9.7% 0.6% 89.7% 4.3 6.1 

4 (25) $154 13.4% 0.5% 86.1% 5.2 7.3 

5 (30) $180 15.2% 0.2% 84.6% 5.6 7.5 

6 (35) $165 27.0% 0.0% 73.0% 7.5 11.4 

7 (40) $125 41.4% 0.0% 58.6% 9.9 15.1 

8 (43) -$5 62.9% 0.0% 37.1% 15.1 22.9 

16 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

Table 16B1. PC 10, Chest Freezers: LCC and PBP Results, Scenario B1 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $39 0.8% 1.1% 98.1% 2.2 2.2 

2 (15) $55 1.3% 0.2% 98.5% 3.5 3.6 

3 (20) $71 24.6% 0.2% 75.2% 4.2 4.4 

4 (25) $51 27.0% 0.2% 72.8% 8.7 9.0 

5 (30) $58 53.9% 0.0% 46.2% 9.1 9.4 

6 (35) $15 70.9% 0.0% 29.1% 13.3 13.8 

Table 16B2. PC 10, Chest Freezers: LCC and PBP Results, Scenario B2 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (6) $21 0.7% 1.1% 98.2% 2.1 2.1 

2 (11) $39 1.5% 0.2% 98.3% 3.8 3.9 

3 (16) $56 30.3% 0.2% 69.5% 4.6 4.7 

4 (21) $38 31.2% 0.2% 68.6% 9.6 9.8 

5 (27) $46 58.1% 0.0% 41.9% 9.8 10.0 

6 (32) $5 74.5% 0.0% 25.5% 14.3 14.6 

Table 16B3. PC 10, Chest Freezers: LCC and PBP Results, Scenario B3 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $44 0.5% 1.1% 98.4% 1.9 1.9 

2 (15) $64 1.0% 0.2% 98.8% 3.1 3.2 

3 (20) $83 20.2% 0.2% 79.6% 3.8 3.9 

4 (25) $66 22.4% 0.2% 77.4% 7.7 8.1 

5 (30) $76 46.7% 0.0% 53.3% 8.1 8.3 

6 (35) $37 63.6% 0.0% 36.4% 11.8 12.2 

17 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

Table 17B1. PC 11, Compact Refrigerators: LCC and PBP Results, Scenario B1 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $10 11.4% 1.6% 87.0% 2.0 1.9 

2 (15) $13 16.5% 1.4% 82.1% 2.3 2.3 

3 (20) $15 24.4% 1.4% 74.2% 2.8 2.7 

4 (25) $10 42.9% 0.9% 56.2% 3.9 3.8 

5 (30) $8 50.0% 0.8% 49.2% 4.4 4.3 

6 (35) -$14 76.9% 0.0% 23.1% 6.7 6.7 

7 (40) -$14 75.5% 0.0% 24.5% 6.6 6.4 

8 (45) -$42 87.2% 0.0% 12.8% 8.7 8.5 

Table 17B2. PC 11, Compact Refrigerators: LCC and PBP Results, Scenario B2 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (6) $5 10.4% 1.6% 88.0% 1.9 1.8 

2 (11) $9 17.4% 1.4% 81.2% 2.4 2.3 

3 (16) $11 26.4% 1.4% 72.2% 2.9 2.8 

4 (21) $7 47.0% 0.9% 52.1% 4.2 4.1 

5 (27) $6 53.3% 0.8% 45.9% 4.6 4.5 

6 (32) -$16 79.7% 0.0% 20.3% 7.1 7.0 

7 (37) -$16 77.7% 0.0% 22.3% 6.9 6.7 

8 (42) -$43 88.4% 0.0% 11.6% 9.1 8.8 

Table 17B3. PC 11, Compact Refrigerators: LCC and PBP Results, Scenario B3 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $11 10.6% 1.6% 87.8% 1.9 1.8 

2 (15) $15 15.6% 1.4% 83.0% 2.2 2.2 

3 (20) $17 22.8% 1.4% 75.8% 2.7 2.6 

4 (25) $13 40.7% 0.9% 58.4% 3.8 3.7 

5 (30) $11 47.4% 0.8% 51.8% 4.2 4.1 

6 (35) -$10 74.2% 0.0% 25.9% 6.5 6.4 

7 (40) -$10 72.7% 0.0% 27.3% 6.3 6.1 

8 (45) -$37 85.7% 0.0% 14.3% 8.3 8.1 

18 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

Table 18B1. PC 18, Compact Freezers: LCC and PBP Results, Scenario B1 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $9 12.5% 4.7% 82.9% 2.8 2.7 

2 (15) $5 44.7% 0.0% 55.3% 4.9 5.1 

3 (20) -$31 92.9% 0.0% 7.1% 11.5 11.7 

4 (25) -$32 90.3% 0.0% 9.7% 10.5 10.6 

5 (30) -$38 91.0% 0.0% 9.0% 10.9 10.9 

6 (35) -$37 87.9% 0.0% 12.1% 10.0 10.0 

7 (39) -$87 96.5% 0.0% 3.5% 13.9 14.0 

Table 18B2. PC 18, Compact Freezers: LCC and PBP Results, Scenario B2 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (6) $4 14.6% 4.7% 80.7% 3.0 3.0 

2 (11) $1 57.2% 0.0% 42.8% 6.0 6.0 

3 (16) -$35 96.3% 0.0% 3.7% 13.7 13.8 

4 (21) -$36 93.8% 0.0% 6.1% 11.9 11.9 

5 (27) -$41 93.6% 0.0% 6.4% 12.0 12.0 

6 (32) -$39 90.3% 0.0% 9.7% 10.7 10.7 

7 (37) -$89 97.2% 0.0% 2.8% 14.8 14.8 

Table 18B3. PC 18, Compact Freezers: LCC and PBP Results, Scenario B3 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $10 11.4% 4.7% 83.9% 2.6 2.6 

2 (15) $6 41.7% 0.0% 58.4% 4.7 4.8 

3 (20) -$29 91.1% 0.0% 8.9% 10.9 11.1 

4 (25) -$30 88.1% 0.0% 11.9% 10.0 10.1 

5 (30) -$35 88.6% 0.0% 11.4% 10.3 10.4 

6 (35) -$33 85.3% 0.0% 14.7% 9.5 9.5 

7 (39) -$83 95.4% 0.0% 4.6% 13.2 13.2 

19 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

 

 

 

 

 

NIA Results 

The following NIA results provide the national energy savings (NES) and net present value (NPV) 

for the requested efficiency levels. The NIA results below are based on only scenarios B1 and B2. 

Table 19. Standard-Size Refrigerator-Freezers: NES Results (quads) 

Efficiency Level 

(% less than 

baseline energy 

use) 

Top-Mount RefrigeratorFreezer* Bottom-Mount RefrigeratorFreezer** Side-by-Side RefrigeratorFreezer*** 

B1 B2 Scen B1 Scen B2 Scen B1 Scen B2 Scen B1 Scen B2 

1 (10) 1 (6) 0.89 0.49 0.04 0.02 0.21 0.12 

2 (15) 2 (11) 1.36 0.98 0.06 0.05 0.44 0.36 

3 (20) 3 (16) 1.85 1.51 0.12 0.10 0.75 0.68 

4 (25) 4 (21) 2.39 2.08 0.28 0.27 1.22 1.18 

5 (30) 5 (27) 2.88 2.60 0.44 0.44 1.68 1.66 

6 (31-33) 6 (28-30) 3.03 2.77 0.55 0.56 1.77 1.75 

* Includes product classes 1, 1A, 2, 3A, and 6 as well as product class 3. 

** Includes product class 5A as well as product class 5. 

*** Includes product class 4 as well as product class 7. 

Table 20. Standard-Size Refrigerator-Freezers: NPV Results (billion $) 

Efficiency 

Level 

(% less than 

baseline) 

Top-Mount RefrigeratorFreezer* Bottom-Mount RefrigeratorFreezer** Side-by-Side RefrigeratorFreezer*** 

7% Disc Rt 3% Disc Rt 7% Disc Rt 3% Disc Rt 7% Disc Rt 3% Disc Rt 

B1 B2 Scen 

B1 

Scen 

B2 

Scen 

B1 

Scen 

B2 

Scen 

B1 

Scen 

B2 

Scen 

B1 

Scen 

B2 

Scen 

B1 

Scen 

B2 

Scen 

B1 

Scen 

B2 

1 (10) 1 (6) 2.95 1.64 8.47 4.68 0.15 0.08 0.42 0.22 0.69 0.38 2.01 1.10 

2 (15) 2 (11) 4.31 3.10 12.53 9.02 0.21 0.15 0.62 0.44 1.43 1.17 4.19 3.42 

3 (20) 3 (16) 1.56 0.47 8.69 5.52 0.32 0.27 0.99 0.84 1.75 1.55 5.75 5.16 

4 (25) 4 (21) 0.73 -0.22 8.82 6.00 -0.10 -0.12 0.66 0.61 1.15 1.06 6.00 5.68 

5 (30) 5 (27) -3.67 -4.49 1.96 -0.50 -1.16 -1.14 -0.95 -0.91 -2.89 -2.88 -0.49 -0.54 

6 (31­

33) 

6 (28­

30) -5.75 -6.52 -1.68 -4.01 -1.59 -1.55 -1.52 -1.41 -3.82 -3.79 -2.01 -2.01 

* Includes product classes 1, 1A, 2, 3A, and 6 as well as product class 3. 

** Includes product class 5A as well as product class 5. 

*** Includes product class 4 as well as product class 7. 

20 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

 

 

 

 

Table 21. Standard-Size Refrigerator-Freezers: NES Results (quads) 

Efficiency Level 

(% less than baseline 

energy use) Upright Freezers* Chest Freezers** 

B1 B2 Scenario B1 Scenario B2 Scenario B1 Scenario B2 

1 (10) 1 (6) 0.19 0.10 0.13 0.07 

2 (15) 2 (11) 0.32 0.23 0.21 0.15 

3 (20) 3 (16) 0.44 0.36 0.29 0.23 

4 (25) 4 (21) 0.56 0.49 0.36 0.31 

5 (30) 5 (27) 0.68 0.61 0.43 0.39 

6 (35) 6 (32) 0.79 0.73 0.49 0.45 

7 (40) 7 (37) 0.88 0.83 - -

8 (43.2) 8 (40) 0.90 0.86 - -

* Includes product class 9 only. 

** Includes product classes 8 and 10A as well as product class 10. 

Table 22. Standard-Size Refrigerator-Freezers: NPV Results (billion $) 

Efficiency Level 

(% less than 

baseline) 

Upright Freezers* Chest Freezers** 

7% Disc Rt 3% Disc Rt 7% Disc Rt 3% Disc Rt 

B1 B2 Scen B1 Scen B2 Scen B1 Scen B2 Scen B1 Scen B2 Scen B1 Scen B2 

1 (10) 1 (6) 0.70 0.36 2.06 1.04 0.48 0.25 1.39 0.72 

2 (15) 2 (11) 0.93 0.62 2.96 2.02 0.67 0.47 2.07 1.45 

3 (20) 3 (16) 1.20 0.92 3.94 3.09 0.85 0.66 2.70 2.14 

4 (25) 4 (21) 1.35 1.10 4.68 3.92 0.52 0.35 2.34 1.84 

5 (30) 5 (27) 1.53 1.31 5.48 4.81 0.57 0.42 2.71 2.26 

6 (35) 6 (32) 1.17 0.98 5.13 4.55 -0.02 -0.15 1.72 1.33 

7 (40) 7 (37) 0.50 0.35 4.15 3.65 - - - -

8 (43.2) 8 (40) -1.16 -1.30 1.03 0.59 - - - -

* Includes product class 9 only. 

** Includes product classes 8 and 10A as well as product class 10. 

21 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

 

 

 

Table 23. Compacts: NES Results (quads) 

Efficiency Level 

(% less than baseline 

energy use) Compact Refrigerators* Compact Freezers** 

B1 B2 Scenario B1 Scenario B2 Scenario B1 Scenario B2 

1 (10) 1 (6) 0.14 0.08 0.03 0.02 

2 (15) 2 (11) 0.20 0.15 0.04 0.03 

3 (20) 3 (16) 0.27 0.22 0.05 0.04 

4 (25) 4 (21) 0.33 0.28 0.07 0.06 

5 (30) 5 (27) 0.38 0.34 0.08 0.07 

6 (35) 6 (32) 0.42 0.38 0.09 0.08 

7 (40-39) 7 (37) 0.47 0.43 0.09 0.09 

8 (45) 8 (40) 0.48 0.46 - -

* Includes product classes 11A, 12, 13, 13A, 14, and 15 as well as product class 11 

** Includes product classes 16 and 17 as well as product class 18 

Table 24. Compacts: NPV Results (billion $) 

Efficiency Level 

(% less than 

baseline) 

Compact Refrigerators* Compact Freezers** 

7% Disc Rt 3% Disc Rt 7% Disc Rt 3% Disc Rt 

B1 B2 Scen B1 Scen B2 Scen B1 Scen B2 Scen B1 Scen B2 Scen B1 Scen B2 

1 (10) 1 (6) 0.32 0.18 0.77 0.43 0.07 0.04 0.17 0.09 

2 (15) 2 (11) 0.42 0.30 1.05 0.74 0.04 0.02 0.13 0.07 

3 (20) 3 (16) 0.47 0.36 1.19 0.92 -0.17 -0.19 -0.24 -0.30 

4 (25) 4 (21) 0.30 0.20 0.92 0.68 -0.17 -0.19 -0.24 -0.29 

5 (30) 5 (27) 0.22 0.14 0.82 0.62 -0.20 -0.22 -0.29 -0.33 

6 (35) 6 (32) -0.45 -0.52 -0.47 -0.65 -0.19 -0.21 -0.25 -0.29 

7 (40-39) 7 (37) -0.46 -0.51 -0.43 -0.57 -0.43 -0.44 -0.68 -0.71 

8 (45) 8 (40) -1.18 -1.23 -1.83 -1.95 - - - -

* Includes product classes 11A, 12, 13, 13A, 14, and 15 as well as product class 11 

** Includes product classes 16 and 17 as well as product class 18 

22 

EERE-2008-BT-STD-0019 COMMENT 34
ROOM AIR CONDITIONERS 

At the April 15, 2010 meeting, stakeholders requested life-cycle cost (LCC) and payback period 

(PBP) results for room air conditioners. 

LCC and PBP Results 

Cabinet Size Constraints 

As described in the ‘May 4’ version of the results, two scenarios are currently under 

consideration: (1) two sets of cabinet size increases as was considered for the preliminary 

analysis and (2) one cabinet size increase assuming that cabinet constraints are more severe than 

assumed for the preliminary analysis. To provide an indication of the impact of room air 

conditioner cabinet size increases, the weight and volume corresponding to baseline, a single 

cabinet size increase, and two cabinet size increases are presented below for the three product 

classes with louvered sides that were analyzed in depth by DOE. 

Table 25. Room Air Conditioner Weight and Volume based on Cabinet Size Increase 

Design Description 

Weight 

(lb) 

Volume 

(ft3) 

PC 1: < 6000 Btu/h with Louvers 

Baseline 38.6 1.3 

 First Size Increase 42.7 1.9 

 Second Size Increase 46.8 2.8 

PC 3: 8000-13,999 Btu/h with Louvers 

8000 Btu/h Size Unit 

Baseline 49.4 2.1 

 First Size Increase 55.7 3.1 

 Second Size Increase 63.6 4.8 

12,000 Btu/h Size Unit 

Baseline 76.5 4.6 

 First Size Increase 81.2 5.5 

 Second Size Increase 87.6 7.1 

PC 5: ≥ 20,000 Btu/h with Louvers 

Baseline 129.2 7.6 

 First Size Increase 136.4 8.9 

 Second Size Increase 156.5 11.9 

Scenarios 

The following LCC and PBP results were calculated based on the above two cabinet size 

increase scenarios as well as the CO2 cap-and-trade scenario analyzed for refrigerators. The 

scenarios are identified as A1, B, and A2 to maintain consistency with how the results were 

identified in the ‘May 4’ version. 

23 

EERE-2008-BT-STD-0019 COMMENT 34
Cabinet Constraint Scenario A1 (two size increase): Preliminary analysis assumptions where 

two sets of cabinet size increases were considered for window units (i.e. product classes 1, 3, and 

5, with louvered sides). 

Cabinet Constraint Scenario B (one size increase): More severe cabinet constraints where 

only one cabinet size increase is assumed. 

Cabinet Constraint (two size increase) with ‘CO2 Cap-and-Trade’ Scenario A2: Same as 

cabinet constraint scenario A1 but with AEO2009 Reference Case forecasted electricity prices 

adjusted to account for CO2 cap-and-trade program. 

Note that for product class 8, 8000-13,999 Btu/h, without louvered sides, no size increases were 

considered for the preliminary analysis due to the dominance of the replacement market for these 

units, and the fixed size of wall sleeves. 

As described in the ‘May 4’ version, the following results are presented in terms of integrated 

EER (IEER), which integrates active and standby mode energy use, as required by the EPCA as 

modified by the Energy Independence and Security Act of 2007. The IEER is calculated as 

follows: 

750 h Capacity(Btu / hr) IEER  750 h  Power (W )  5,115hPower (W ) Active Stndby 

The baseline IEER is defined assuming that the baseline standby load is 1.4W. The baseline 

IEER is lower than the current energy standard for EER, because of the additional energy use 

associated with standby mode. Higher-than-baseline efficiency levels have been chosen at levels 

represented by numbers with significant digits extending to tenths of Btu/hr-W (i.e. 10.6) rather 

than corresponding directly to current EER-based efficiency level descriptors such as “ENERGY 

STAR”. Hence, while efficiency level 2 corresponds roughly to the current ENERGY STAR 

level, its active mode EER would be slightly different. This has been done to avoid future IEER 

standards represented by numbers with significant digits extending to the hundredths of Btu/hrW. 

24 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

Table 26A1. PC 1, <6000 Btu/h, with Louvers: LCC and PBP Results, Scenario A1 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 9.52 

1 10.1 $25 15% 4% 81% 0.9 5.9 

2 10.6 $41 20% 4% 76% 1.6 12.2 

3 11.1 $51 31% 0% 69% 2.5 13.4 

4 11.6 $57 37% 0% 63% 3.1 16.0 

5 12.0 $63 39% 0% 61% 3.5 17.6 

Table 26B. PC 1, <6000 Btu/h, with Louvers: LCC and PBP Results, Scenario B 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 9.52 

1 10.1 $25 15% 4% 81% 0.9 5.9 

2 10.5 $39 18% 4% 77% 1.5 8.2 

3 10.9 -$18 75% 0% 25% 7.4 41.9 

Table 26A2. PC 1, <6000 Btu/h, with Louvers: LCC and PBP Results, Scenario A2 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 9.52 

1 10.1 $28 14% 4% 82% 0.9 5.9 

2 10.6 $46 19% 4% 77% 1.6 12.2 

3 11.1 $57 29% 0% 71% 2.5 13.4 

4 11.6 $65 35% 0% 65% 3.1 16.0 

5 12.0 $72 36% 0% 64% 3.5 17.6 

25 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

Table 27A1. PC 3, 8000-13,999 Btu/h, with Louvers: LCC and PBP Results, Scenario A1 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 9.7 

1 10.3 $15 13% 48% 39% 1.5 8.2 

2 10.8 $23 16% 47% 37% 2.4 11.4 

3 11.3 $24 52% 3% 45% 6.6 22.2 

4 11.5 -$24 69% 1% 30% 10.9 45.6 

Table 27B. PC 3, 8000-13,999 Btu/h, with Louvers: LCC and PBP Results, Scenario B 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 9.7 

1 10.3 $14 14% 48% 38% 1.6 8.7 

2 10.8 $23 16% 47% 37% 2.4 11.7 

3 11.3 -$45 82% 3% 15% 18.6 70.1 

Table 27A2. PC 3, 8000-13,999 Btu/h, with Louvers: LCC and PBP Results, Scenario A2 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 9.7 

1 10.3 $16 12% 48% 39% 1.5 8.2 

2 10.8 $26 16% 47% 38% 2.4 11.4 

3 11.3 $30 50% 3% 47% 6.6 22.2 

4 11.5 -$18 67% 1% 32% 10.9 45.6 

26 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

Table 28A1. PC 5, ≥ 20,000 Btu/h, with Louver: LCC and PBP Results, Scenario A1 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 8.47 

1 9.0 $20 14% 63% 23% 3.2 7.2 

2 9.4 $31 20% 57% 23% 5.6 7.7 

3 9.8 $39 63% 1% 36% 11.8 14.6 

4 10.0 $15 71% 0% 29% 16.1 21.1 

Table 28B. PC 5, ≥ 20,000 Btu/h, with Louver: LCC and PBP Results, Scenario B 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 8.47 

1 9.0 $17 17% 63% 20% 4.3 9.6 

2 9.4 -$28 35% 57% 8% 20.5 31.2 

3 9.7 -$333 97% 1% 3% 99.8 151.7 

Table 28A2. PC 5, ≥ 20,000 Btu/h, with Louver: LCC and PBP Results, Scenario A2 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 8.47 

1 9.0 $23 13% 63% 24% 3.2 7.2 

2 9.4 $36 20% 57% 24% 5.6 7.7 

3 9.8 $47 61% 1% 38% 11.8 14.6 

4 10.0 $25 70% 0% 30% 16.1 21.1 

27 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

Table 29-1. PC 8, 8000-13,999 Btu/h, without Louver: LCC and PBP Results 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 8.4 

1 8.9 $14 3% 61% 37% 0.8 2.6 

2 9.3 $24 4% 61% 35% 1.1 4.0 

3 9.8 $38 39% 0% 61% 4.7 13.7 

Table 29-2. PC 8, 8000-13,999 Btu/h, without Louver: LCC and PBP Results with ‘CO2 Capand-Trade’ 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 8.4 

1 8.9 $16 3% 61% 37% 0.8 2.6 

2 9.3 $26 4% 61% 35% 1.1 4.0 

3 9.8 $43 37% 0% 63% 4.7 13.7 

28 

EERE-2008-BT-STD-0019 COMMENT 34