CHAPTER 1. INTRODUCTION 

TABLE OF CONTENTS 

1.1 PURPOSE OF THE DOCUMENT ................................................................................. 1-1 
 

1.2 OVERVIEW OF STANDARDS FOR RESIDENTIAL DISHWASHERS, 

DEHUMIDIFIERS, AND COOKING PRODUCTS AND COMMERCIAL 

CLOTHES WASHERS ................................................................................................... 1-1 
 

1.3 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS...................... 1-3 
 

1.4 STRUCTURE OF THE DOCUMENT............................................................................ 1-8 
 

LIST OF TABLES 

Table 1.3.1 Analyses Under the Process Rule ........................................................................ 1-5

Table 1.3.2 Proposed Energy Conservation Standards for Cooking Products and 

Commercial Clothes Washers.............................................................................. 1-7 
 

1-i 


EERE-2006-STD-0127 COMMENT 66.2
CHAPTER 1. INTRODUCTION 


1.1 PURPOSE OF THE DOCUMENT 


This technical support document (TSD) is a stand-alone report that provides the technical 

analyses and results in support of the information presented in the supplemental notice of 

proposed rulemaking (SNOPR) for establishing energy conservation standards for commercial 

clothes washers (CCWs). The TSD for DOE’s notice of proposed rulemaking (NOPR) also 

covered conventional cooking products (i.e., cooktops and ovens), microwave oven energy factor 

(EF), and microwave oven standby power consumption (which along with CCWs are referred to 

as “the considered products”.) Energy conservation standards for conventional cooking products 

and microwave oven EF were addressed in a final rule, published April 8, 2009 (74 FR 16040; 

the “April 2009 Final Rule”), accompanied by a final rule TSD. The impact of more efficient 

equipment on microwave oven standby power will be addressed in a subsequent TSD. 

1.2 	 OVERVIEW OF STANDARDS FOR RESIDENTIAL DISHWASHERS, 

DEHUMIDIFIERS, AND COOKING PRODUCTS AND COMMERCIAL 

CLOTHES WASHERS 

The Energy Policy and Conservation Act (EPCA) of 1975 (42 U.S.C. 6291–6309) 

established an energy conservation program for major household appliances. The National 

Energy Conservation Policy Act of 1978 (NECPA) amended EPCA to add Part C of Title III (42 

U.S.C. 6311–6317), which established an energy conservation program for certain industrial 

equipment. Additional amendments to EPCA have given the Department of Energy (DOE) the 

authority to regulate the energy efficiency of several products, including residential dishwashers, 

dehumidifiers, and cooking products and CCWs—the products that are the focus of this 

document. The amendments to EPCA in the National Appliance Energy Conservation Act of 

1987 (NAECA) established prescriptive energy conservation standards for dishwashers and 

cooking products, as well as requirements for determining whether these standards should be 

amended. (42 U.S.C. 6291–6309) The amendments to EPCA in the Energy Policy Act of 2005 

(EPACT 2005), P.L. 109-58, included provisions that expanded DOE’s energy conservation 

program to include certain residential products and commercial equipment, including 

dehumidifiers and CCWs. 

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.a (42 U.S.C. 6295(h)(1)–(2)) DOE initially analyzed standards for cooking products as 

a DOE is required to conduct two cycles of rulemakings for both gas and electric cooking products. 

1-1 


EERE-2006-STD-0127 COMMENT 66.2
part of an eight-product standards rulemaking. It 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 the July 15, 1996, Procedures for Consideration of New 

or Revised Energy Conservation Standards for Consumer Products (the “Process Rule”), 61 FR 

36974 (July 15, 1996), DOE refined its standards analysis of cooking products. With regard to 

gas cooking products, DOE focused on the economic justification for eliminating standing pilots. 

Partially due to the difficulty of conclusively demonstrating that elimination of standing pilots 

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 no 

standards were justified for electric cooking products. DOE never completed that standards 

rulemaking for gas cooking products. 

NAECA also established prescriptive standards for dishwashers, requiring that they be 

equipped with an option to dry without heat, and further required that DOE conduct two cycles 

of rulemakings to determine if more stringent standards are justified. (42 U.S.C. 6295(g)(1), (4), 

(5)) On May 14, 1991, DOE issued a final rule establishing the first set of performance standards 

for dishwashers; the new standards became effective on May 14, 1994. 56 FR 22250. DOE 

initiated a second standards rulemaking for dishwashers by issuing an advance notice of 

proposed rulemaking (ANOPR) on November 14, 1994. 59 FR 56423. As a result of the prioritysetting process outlined in the Process Rule, DOE suspended the standards rulemaking for 

dishwashers. The Energy Independence and Security Act of 2007 (EISA 2007; Pub. L. No. 110­

140) amended EPCA to establish revised energy conservation standards for residential 

dishwashers. (42 U.S.C. 6295(g)(9)) These EISA 2007 amendments set energy efficiency 

standards for these products, effective January 1, 2010; therefore, DOE did not adopt standards 

for residential dishwashers in the April 2009 Final Rule, nor is addressing standards for these 

products in this SNOPR. Instead, DOE has codified these statutory standards in a separate final 

rule, published March 23, 2009 (74 FR 12058). 

Dehumidifiers are products first covered by EPACT 2005, which established standards 

for these products with an effective date of October 1, 2007. (Section 135(c)(4)) EPACT 2005 

also required that DOE issue a final rule by October 1, 2009, to determine whether these 

standards should be amended. If amended standards were justified, EPACT 2005 required them 

to become effective by October 1, 2012. In the event that DOE failed to publish a final rule by 

October 1, 2009, EPACT 2005 specified a new set of amended standards with an effective date 

of October 1, 2012. EISA 2007 amended EPCA to establish revised energy conservation 

standards for dehumidifiers, effective October 1, 2012. (42 U.S.C. 6295(cc)) As with 

dishwashers, DOE did not adopt standards for dehumidifiers in the April 2009 Final Rule, nor is 

addressing standards for these products in the SNOPR. Instead, DOE has codified these statutory 

standards in a separate final rule, published March 23, 2009 (74 FR 12058). 

Like dehumidifiers, CCWs are equipment first covered by EPACT 2005. EPACT 2005 

established standards for CCWs with an effective date of January 1, 2007. (Section 136(e)) 

EPACT 2005 also requires that DOE issue a final rule by January 1, 2010, to determine whether 

these standards should be amended. 

1-2 


EERE-2006-STD-0127 COMMENT 66.2
1.3 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS 

Under EPCA, when DOE evaluates new or amended standards, it must consider, to the 

greatest extent practicable, the following seven factors (42 U.S.C. 6295(o)(2)(B)(i); 42 U.S.C. 

6316(a)): 

1) the economic impact of the standard on the manufacturers and on the consumers of the 

products subject to such a standard; 

2) the savings in operating costs throughout the estimated average life of the covered 

product in the type (or class) compared to any increases in the price of, or in the initial 

charges for, or maintenance expenses of, 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 considers relevant. 

Other statutory requirements are set forth in 42 U.S.C. 6295(o)(1)–(2)(A), (2)(B)(ii)–(iii), 

(3)–(4) and 42 U.S.C. 6316(a). 

DOE considers the participation of interested parties to be a very important part of the 

process for setting energy conservation standards. DOE actively encourages the participation and 

interaction of all interested parties during the comment period in each stage of the rulemaking. 

Beginning with the framework document and during subsequent comment periods, interactions 

among interested parties provide a balanced discussion of the information that is required for the 

standards rulemaking. 

In conducting energy conservation standards rulemakings, DOE involves interested 

parties through formal public notifications (i.e., Federal Register notices). For this rulemaking, 

DOE employed the procedures set forth in the Process Rule to the extent they were appropriate 

for developing energy conservation standards for the considered products. The Process Rule 

greatly enhances opportunities for public input and improved analytic approaches, and 

encourages adoption of consensus-based standards. The Process Rule provides policies and 

guidelines for early public review and consultation with interested parties with regard to 

identifying and screening design options, selecting a proposed standard, and establishing the 

1-3 


EERE-2006-STD-0127 COMMENT 66.2
final standard. The factors for screening design options include: (1) technological feasibility; (2) 

practicability to manufacture, install, and service; (3) adverse impacts on product utility or 

product availability; and (4) adverse impacts on health or safety (Process Rule at section 4(a)(4)). 

61 FR 36982. 

The Process Rule requires DOE to evaluate uncertainty and variability through the use of 

scenario or probability analysis, and provides for review by experts and interested parties of the 

analyses used, including: (1) qualitative and quantitative analytical methods; (2) economic, 

engineering, and life-cycle cost (LCC) analyses; and (3) impacts on manufacturers and 

consumers, national energy savings, the economy, and the environment. Although the Process 

Rule specifically applies only to the development of energy conservation standards for consumer 

products, DOE has decided to apply its procedures to the development of energy conservation 

standards for commercial and industrial equipment as well. See appendix A to subpart C of Title 

10 of the Code of Federal Regulations Part 430 (10 CFR Part 430). 

Before DOE determines whether or not to adopt a proposed energy conservation 

standard, it must first solicit comments on the proposed standard. (42 U.S.C. 6295(o)(2)(B)(i)) 

Any new or amended standard must be designed to achieve significant additional conservation of 

energy and be technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) To 

determine whether economic justification exists, DOE must review comments on the proposal 

and determine that the benefits of the proposed standard exceed its burdens to the greatest extent 

practicable, weighing the seven factors listed above. (42 U.S.C. 6295(o)(2)(B)(i)) 

After the publication of the framework document, the standards rulemaking process 

involves three additional formal, major public notices, which DOE publishes in the Federal 

Register. The first of the rulemaking notices is an ANOPRb, which is designed to publicly vet the 

models and tools used in the rulemaking, and to facilitate public participation before the 

proposed rule stage. The second notice is a NOPR, which presents a discussion of comments 

received in response to the ANOPR; analysis of the impacts of standards on consumers, 

manufacturers, and the nation; DOE’s weighting of these impacts; and the proposed standards. 

The third notice is the final rule, which presents a discussion of comments received in response 

to the NOPR; the revised analysis of the impacts of standards; DOE’s weighting of these 

impacts; the standards DOE is adopting; and the effective dates of the standards. 

In April, 2006, DOE published a Rulemaking Framework for Commercial Clothes 

Washers and Residential Dishwashers, Dehumidifiers, and Cooking Products, describing the 

procedural and analytical approaches DOE anticipated using to evaluate the establishment of 

b

 In energy conservation standards rulemakings in the past, and for this rulemaking, DOE issued an ANOPR 

following publication of the framework document. The Energy Independence and Security Act of 2007 eliminated 

the requirement that DOE issue ANOPRs as part of the standards rulemaking process; see EISA 2007, at sec. 307. 

DOE is now using an alternative process known as the preliminary activities and analyses. The preliminary activities 

and analyses will provide the same information and ability for public comment as the ANOPR, but without 

publication of analyses in the Federal Register. 

1-4 


EERE-2006-STD-0127 COMMENT 66.2
energy conservation standards for these products. This document is available at 

http://www1.eere.energy.gov/buildings/appliance_standards/. DOE held a public meeting on 

April 27, 2006, to discuss procedural and analytical approaches to the rulemaking, and to inform 

and facilitate interested parties’ involvement in the rulemaking process. The analytical 

framework presented at the public meeting described different analyses, such as the engineering 

analysis and the LCC and payback period (PBP) analysis, the methods proposed for conducting 

them, and the relationships among the various analyses. Table 1.3.1 lists the analyses undertaken 

and reported in each of the formal public rulemaking documents. 

Table 1.3.1 Analyses Under the Process Rule 

ANOPR NOPR Final Rule 

Market and technology assessment Revised ANOPR analyses Revised analyses 

Screening analysis Life-cycle cost sub-group 

analysis 

Engineering analysis Manufacturer impact analysis 

Energy and water use determination Utility impact analysis 

Markups for equipment price 

determination 

Environmental assessment 

Life-cycle cost and payback period 

analysis 

Employment impact analysis 

Shipments analysis Regulatory impact analysis 

National impact analysis 

Preliminary manufacturer impact analysis 

During the April, 2006, public meeting, interested parties commented about the following 

issues related to the rulemaking: (1) the existing DOE test procedure for microwave ovens; (2) 

baseline unit definitions for the considered products; (3) number of product classes for the 

considered products; (4) consideration of limiting standby power as a design option for all 

considered products; (5) technology options for improving efficiency for all considered products; 

(6) type of approach to employ for the engineering analysis; (6) efficiency levels to consider for 

all of the considered products; (7) implications of clothes container volume on CCW efficiency; 

(8) proposed approaches for specifying typical annual energy and water consumption for all 

considered products; (9) potential data sources for characterizing variability in annual energy and 

water consumption; (10) typical distribution channels and markups for the considered products; 

(11) data sources for retail prices; (12) type of approach to employ for the LCC and PBP 

analyses; (13) variability of forecasted energy and water prices; (14) repair, maintenance, and 

installation cost relationship to product efficiency; (15) product lifetimes; (16) development of 

consumer discount rates; (17) purchase price impacts on product shipments; (18) forecasted 

saturation rates of CCWs; (19) consumer subgroups; (20) water and wastewater utility impacts; 

and (21) wastewater discharge impacts. Interested parties’ comments submitted during the 

1-5 


EERE-2006-STD-0127 COMMENT 66.2
Framework Document comment period elaborated on the issues raised at the public meeting. 

DOE worked with its contractors to address these issues in the analyses. 

After the April, 2006, public meeting, as part of the information gathering and sharing 

process, DOE organized and held interviews with manufacturers of the considered products. 

DOE selected companies that represented production of all types of equipment, ranging from 

small to large manufacturers, and included both Association of Home Appliance Manufacturers 

(AHAM) member companies and non-AHAM member companies. DOE had four objectives for 

these interviews: (1) Solicit feedback on the draft engineering analysis (including methodology, 

production costs, manufacturing processes, and findings); (2) solicit feedback on topics related to 

the preliminary manufacturer impact analysis (MIA); (3) provide an opportunity, early in the 

rulemaking process, to express specific concerns to DOE; and (4) foster cooperation between the 

manufacturers and DOE. There were six general topics related to the preliminary manufacturer 

impact analysis discussed during each of the interviews: (1) general key issues; (2) shipment 

projections; (3) capital conversion costs; (4) equipment mix and profitability; (5) market shares 

and industry consolidation; and (6) cumulative regulatory burden. DOE incorporated the 

information gathered at the interviews into its engineering analysis (see chapter 5 of the ANOPR 

TSD) and the preliminary manufacturer impact analysis (see chapter 13 of the ANOPR TSD). 

Following the publication of the ANOPR and the ANOPR public meeting, DOE held additional 

meetings with manufacturers as part of the consultative process for the MIA conducted during 

the NOPR phase of the rulemaking. 

DOE developed spreadsheets for the LCC, PBP, and national impact analyses for each of 

the considered products in an effort to meet the objectives of the Process Rule. For each product, 

DOE developed an LCC spreadsheet that calculates the LCC and PBP at various energy 

efficiency levels. DOE also developed a national impact analysis (NIA) spreadsheet that 

calculates the national energy savings (NES) and national net present values (NPVs) at various 

energy efficiency levels. This spreadsheet includes a model that forecasts the impacts of energy 

efficiency standards at various levels on product shipments. All of these spreadsheets are 

available on the DOE website (http://www1.eere.energy.gov/buildings/appliance_standards), 

within the specific pages for each of the considered products. 

On November 15, 2007, DOE published an ANOPR to consider establishing new or 

revised energy conservation standards for the covered products, and to announce a public 

meeting to receive comments on a variety of issues. 72 FR 64432. This document is available at 

http://www1.eere.energy.gov/buildings/appliance_standards/. DOE held a public meeting on 

December 13, 2007, to provide interested parties the opportunity to comment on topics 

including: (1) the proposed product classes; (2) the analytical framework, models, and tools (e.g., 

LCC and NES spreadsheets) that DOE used to perform analyses of the impacts of energy 

conservation standards; (3) the results of the preliminary analyses; and (4) the candidate energy 

conservation standard levels. 

After the publication of the ANOPR and the presentation of the ANOPR to interested 

parties at the public meeting, DOE conducted interviews with manufacturers of the covered 

products as part of the MIA for the NOPR. There were thirteen general topics discussed during 

1-6 


EERE-2006-STD-0127 COMMENT 66.2
each of the interviews: (1) general key issues; (2) company overview and organizational 

characteristics; (3) company financial parameters; (4) production cost breakdown; (5) shipment 

projections and market shares; (6) equipment mixes; (7) conversion costs; (8) markups and 

profitability; (9) cumulative regulatory burden; (10) exports, foreign competition, and 

outsourcing; (11) direct employment impact assessment; (12) market consolidation; and (13) 

baseline products and different design options. 

Subsequent to the ANOPR, DOE revised its preliminary analyses to address public 

comments it had received on its ANOPR. In addition, DOE conducted all of the analyses 

identified in Table 1.3.1 that are required for the NOPR phase of the rulemaking. 

On October 17, 2008, DOE published a NOPR proposing energy conservation standards 

for the covered products, and to announce a public meeting to receive comments on a variety of 

issues. 73 FR 62034. In conjunction with the NOPR, DOE also published on its website the 

complete TSD for the proposed rule, which incorporated the analyses DOE conducted and 

technical documentation of each analysis, as well as the LCC and NIA spreadsheets. These 

documents are available at http://www1.eere.energy.gov/buildings/appliance_standards/. For the 

reasons discussed above in section 1.2, DOE did not consider energy conservation standards for 

dishwashers and dehumidifiers, and instead codified in a separate final rule the standards set by 

EISA 2007 for these products. 74 FR 12058 (March 23, 2009). The energy conservation 

standards proposed in the NOPR for the remaining covered products were as follows: 

Table 1.3.2 Proposed Energy Conservation Standards for Cooking Products and 

Commercial Clothes Washers 

Product Class 

Proposed Energy Conservation 

Standards 

Conventional Cooking Products 

Gas cooktops/conventional burners No constant burning pilot lights 

Electric cooktops/low or high wattage open (coil) elements No standard 

Electric cooktops/smooth elements No standard 

Gas ovens/standard oven No constant burning pilot lights 

Gas ovens/self-clean oven No change to existing standard 

Electric ovens No standard 

Microwave ovens Maximum standby power = 1.0 watt 

Commercial clothes washers 

Top-loading commercial clothes washers 1.76 Modified Energy Factor / 8.3 

Water Factor 

Front-loading commercial clothes washers 2.00 Modified Energy Factor / 5.5 

Water Factor 

The NOPR also included additional background information on the history of this 

rulemaking and on DOE’s use in this rulemaking of the procedures, interpretations, and policies 

set forth in the Process Rule. 73 FR 62034, 62038–41 (Oct. 17, 2008). DOE held a public 

1-7 

EERE-2006-STD-0127 COMMENT 66.2
meeting on November 13, 2008, to hear oral comments on and solicit information relevant to the 

proposed rule. 

Based on information provided by interested parties at the public meeting and in 

subsequent written comments, DOE determined that additional analyses would be required to 

further evaluate energy conservation standards for CCWs and microwave ovens as to standby 

power. The EISA 2007 amendments to EPCA required DOE to amend the ranges and ovens and 

microwave oven test procedure to incorporate standby and off mode energy consumption no later 

than March 31, 2011. (42 U.S.C. 6295(gg)(2)(B)(vi)) For CCWs, EPCA requires that DOE issue 

a final rule by January 1, 2010, to determine whether the existing energy conservation standards 

should be amended. (42 U.S.C. 6313(e)(2)(A)) Because additional analyses were required to 

resolve issues concerning microwave oven standby power and CCW energy conservation 

standards and EPCA did not require DOE to take action on these products by March 2009 (as 

was required under a Consent Decreec

 for the cooking efficiency for residential electric and gas 

kitchen ranges and ovens and microwave ovens), DOE continued the rulemaking for these 

products at the time of the April 2009 Final Rule. 

In the April 2009 Final Rule, DOE issued a final rule for energy conservation standards 

pertaining to cooking efficiency for residential electric and gas kitchen ranges and ovens and 

microwave ovens, adopting prescriptive standards for gas cooking products, requiring gas ranges 

and ovens not to be equipped with constant burning pilots No energy conservation standards for 

the cooking efficiency for residential electric kitchen ranges and ovens and microwave ovens 

were found to be justified, and, therefore, the April 2009 Final Rule maintained the “no 

standard” standard for these products. The effective date for these new standards would be April 

8, 2012. 

This TSD presents information on the additional SNOPR analyses performed to further 

evaluate energy conservation standards for CCWs. A final rule is planned to be issued after 

addressing public comments received on the SNOPR. A separate final rule for microwave ovens 

pertaining to standby power is planned to be issued as soon as the revised analyses for that 

product are complete. 

1.4 STRUCTURE OF THE DOCUMENT 

This SNOPR TSD outlines the analytical approaches used in this rulemaking. The TSD 

consists of seventeen chapters and appendices. 

c

 “Consent Decree” refers to the consolidated Consent Decree in New York v. Bodman, No. 05 Civ. 7807 (S.D.N.Y. 

filed Sept. 7, 2005) and Natural Resources Defense Council v. Bodman, No. 05 Civ. 7808 (S.D.N.Y. filed Sept. 7, 

2005) 

1-8 


EERE-2006-STD-0127 COMMENT 66.2
Chapter 1 Introduction: provides an overview of the appliance standards program 

and how it applies to this rulemaking, and outlines the structure of the 

document. 

Chapter 2 Analytical Framework: describes the rulemaking process. 

Chapter 3 Market and Technology Assessment: characterizes the market for all 

considered products in this rulemaking and the technologies available 

for increasing product efficiency. 

Chapter 4 Screening Analysis: determines which CCW design options are viable 

for consideration in the engineering analysis. 

Chapter 5 Engineering Analysis: discusses the methods used for developing the 

relationship between increased manufacturer cost and increased 

efficiency. 

Chapter 6 Energy and Water Use Determination: discusses the process used for 

generating energy- and water-use estimates for CCWs as a function of 

standard levels. 

Chapter 7 Markups for Equipment Price Determination: discusses the methods 

used for establishing markups for converting manufacturer costs to 

customer retail prices. 

Chapter 8 Life-Cycle Cost and Payback Period Analysis: discusses the effects of 

standards on individual customers and users of the equipment and 

compares the LCC and PBP of equipment with and without higher 

energy conservation standards. 

Chapter 9 Trial Standard Levels: discusses the trial standard levels and methods 

used to derive the energy-efficiency equations corresponding to the 

proposed energy conservation standards. 

Chapter 10 Shipments Analysis: discusses the methods used for forecasting 

shipments with and without higher efficiency standards, including how 

equipment purchase decisions are economically influenced and how 

DOE models this relationship with econometric equations. 

Chapter 11 National Impact Analysis: discusses the methods used for forecasting 

national energy consumption and national economic impacts based on 

estimates of future equipment efficiency, new construction and building 

starts, and annual equipment sales in the absence and presence of higher 

efficiency standards. 

1-9 


EERE-2006-STD-0127 COMMENT 66.2
Chapter 12 Life-Cycle Cost Subgroup Analysis: discusses the effects of standards 

on different subgroups of consumers and compares the LCC and PBP of 

equipment with and without higher efficiency standards for these 

consumers. 

Chapter 13 Manufacturer Impact Analysis: discusses the financial impact of new 

energy conservation standards on manufacturers. 

Chapter 14 Utility Impact Analysis: discusses the effects of standards on electric 

and gas utilities. 

Chapter 15 Employment Impact Analysis: discusses the effects of standards on 

national employment. 

Chapter 16 Environmental Assessment: discusses the effects of amended energy 

conservation standards on three pollutants—sulfur dioxide (SO2), 

nitrogen oxides (NOx), and mercury—as well as carbon emissions. 

Chapter 17 Regulatory Impact Analysis: discusses the present regulatory actions as 

well as the impact of non-regulatory alternatives to setting new energy 

conservation standards. 

Appendix 5A AHAM Data Submittal: presents the data provided by AHAM to DOE 

for CCWs. 

Appendix 8A User Instructions for LCC and PBP Spreadsheets: briefly describes the 

LCC and PBP spreadsheets for CCWs and provides brief user 

instructions on how to operate the spreadsheets. 

Appendix 8B Uncertainty and Variability: discusses how DOE uses uncertainty and 

variability to characterize the inputs to the LCC and PBP analysis. 

Appendix 8C Lifetime Distributions: discusses how equipment lifetimes are 

characterized with Weibull probability distributions. 

Appendix 10A Relative Price Elasticity of Demand for CCWs: describes the analysis 

that DOE conducted to determine the consumer sensitivity to CCW 

purchase price changes as well as operating cost changes and household 

income. 

Appendix 11A User Instructions for Shipments and NIA Spreadsheets: briefly describes 

the shipments and national impact analysis (NIA) spreadsheets for 

CCWs and provides brief user instructions on how to operate the 

spreadsheets. 

1-10 


EERE-2006-STD-0127 COMMENT 66.2
Appendix 11B National Equipment and Operating Costs: provides the components to 

the NPV for CCWs, namely, the present value of the equipment costs 

and the present value of the operating costs. 

Appendix 13A The Low-Volume Manufacturer: discusses the method for estimating the 

revenue and equipment mix impact on a low-production-volume CCW 

manufacturer. 

Appendix 13B Manufacturer Interview Guides: presents questionnaires used to guide 

DOE interviews with CCW manufacturers. 

Appendix 13C Government Regulatory Impact Model (GRIM): discusses the method to 

estimate the change in value of an industry or manufacturers(s) 

following a regulation or a series of regulations. 

Appendix 14A Interpolation of Utility and Environmental Results from NEMS-BT 

Output: describes the methodology for using output from NEMS-BT to 

estimate the utility impact and environmental impact results for 

equipment standards. 

Appendix 17A Regulatory Impact Analysis Supporting Material: provides more detailed 

information on the data used to conduct the Regulatory Impact Analysis. 

1-11 


EERE-2006-STD-0127 COMMENT 66.2