EXECUTIVE SUMMARY 

TABLE OF CONTENTS 

ES.1 OVERVIEW OF PRELIMINARY ACTIVITIES...............................................................1 

ES.2 OVERVIEW OF THE PRELIMINARY NOTICE OF PROPOSED 

RULEMAKING ANALYSES AND THE PRELIMINARY TECHNICAL 

SUPPORT DOCUMENT ....................................................................................................3 

ES.3 KEY RESULTS OF THE ANALYSIS ...............................................................................4 

ES.3.1 Market and Technology Assessment .............................................................................4 

ES.3.2 Screening Analysis.........................................................................................................6 

ES.3.3 Engineering Analysis.....................................................................................................6 

ES.3.3.1 Product Classes Analyzed........................................................................ 7 

ES.3.3.2 Manufacturing Cost Assessment.............................................................. 8 

ES.3.4 Markups to Determine Product Price...........................................................................12 

ES.3.5 Energy Use Characterization .......................................................................................13 

ES.3.6 Life-Cycle Cost and Payback Period Analyses ...........................................................16 

ES.3.7 Shipments Analysis......................................................................................................22 

ES.3.8 National Impact Analysis.............................................................................................24 

ES.3.8.1 National Energy Savings........................................................................ 24 

ES.3.8.2 Net Present Value .................................................................................. 25 

ES.3.9 Preliminary Manufacturer Impact Analysis.................................................................27 

ES.4 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT..............................................28 

ES.4.1 Design Options for Clothes Dryers and Room Air Conditioners ................................28 

ES.4.2 Vent-less Clothes Dryers .............................................................................................28

ES.4.3 Underwriters Laboratory Fire Safety Regulation ........................................................28 

ES.4.4 Extrapolation to Estimate Costs for Product Classes not Fully Analyzed...................28 

ES.4.5 Modified Engineering Analysis Approach ..................................................................29 

ES.4.6 Establishing Appropriate Size Limits for Room Air Conditioners with 

Louvered Sides.............................................................................................................29 

ES.4.7 Operating Hours for Room Air Conditioners ..............................................................29 

ES.4.8 Number of Annual Cycles for Clothes Dryers.............................................................29 

ES.4.9 Consideration of Remaining Moisture Content of Clothes for Calculation of 

Clothes Dryer Energy Use ...........................................................................................29 

ES.4.10 Load Sizes for Clothes Dryers .....................................................................................30 

ES.4.11 Repair and Maintenance Costs.....................................................................................30 

ES.4.12 Lifetime of Clothes Dryers and Room Air Conditioners.............................................30 

ES.4.13 Base Case Efficiency Distributions .............................................................................30 

ES.4.14 Manufacturer Subgroups..............................................................................................30 

ES.4.15 Valuing Air-Borne Emission Reductions ....................................................................31 

LIST OF TABLES 

Table ES.3.1 Product Classes for Residential Clothes Dryer Products.........................................5 

Table ES.3.2 Product Classes for Room Air Conditioners............................................................5 

Table ES.3.3 Baseline Residential Clothes Dryer IEF for Analyzed Product Classes..................7 

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EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.4 Baseline Room Air Conditioner IEER for Analyzed Product Classes ....................8 

Table ES.3.5 Incremental Cost Results for Residential Clothes Dryer Product Class 1...............9 

Table ES.3.6 Incremental Cost Results for Residential Clothes Dryer Product Class 2...............9 

Table ES.3.7 Incremental Cost Results for Residential Clothes Dryer Product Class 3...............9 

Table ES.3.8 Incremental Cost Results for Residential Clothes Dryer Product Class 4.............10 

Table ES.3.9 Incremental Cost Results for Residential Clothes Dryer Product Class 5.............10 

Table ES.3.10 Incremental Cost Results for Residential Clothes Dryer Product Class 6.............10 

Table ES.3.11 Cost Results for Room Air Conditioner Product Class 1 ......................................11 

Table ES.3.12 Cost Results for Room Air Conditioner Product Class 3 ......................................12 

Table ES.3.13 Cost Results for Room Air Conditioner Product Class 5 ......................................12 

Table ES.3.14 Cost Results for Room Air Conditioner Product Class 8 ......................................12 

Table ES.3.15 Markups for Clothes Dryers and Room Air Conditioners.....................................13 

Table ES.3.16 Vented Electric Standard and Gas Clothes Dryers: Average Annual 

Energy Consumption by Efficiency Level.............................................................14 

Table ES.3.17 Vented Electric Compact Clothes Dryers: Average Annual Energy 

Consumption by Efficiency Level .........................................................................14 

Table ES.3.18 Vent-less Electric Compact (240 V) Clothes Dryers and Vent-less Electric 

Combination Washer/Dryer: Average Annual Energy Consumption by 

Efficiency Level.....................................................................................................15 

Table ES.3.19 Room Air Conditioner, Without Reverse Cycle, With Louvered Sides, 

<6,000 Btu/h: Average Annual Energy Use ..........................................................15 

Table ES.3.20 Room Air Conditioner, Without Reverse Cycle, With Louvered Sides, 

8,000-13,999 Btu/h: Average Annual Energy Use ................................................15 

Table ES.3.21 Room Air Conditioner, Without Reverse Cycle, With Louvered Sides, 

20,000 Btu/h: Average Annual Energy Use ........................................................16 

Table ES.3.22 Room Air Conditioner, Without Reverse Cycle, Without Louvered Sides, 

8,000-13,999 Btu/h: Average Annual Energy Use ................................................16 

Table ES.3.23 Vented Electric Standard Clothes Dryers: LCC and PBP Results.........................18 

Table ES.3.24 Vented Gas Clothes Dryers: LCC and PBP Results ..............................................18 

Table ES.3.25 Vented Electric Compact (120 V) Clothes Dryers: LCC and PBP Results...........19 

Table ES.3.26 Vented Electric Compact (240 V) Clothes Dryers: LCC and PBP Results...........19 

Table ES.3.27 Vent-less Electric Compact (240 V) Clothes Dryers: LCC and PBP 

Results....................................................................................................................20 

Table ES.3.28 Vent-less Electric Combination Washer/Dryers: LCC and PBP Results ..............20 

Table ES.3.29 Room Air Conditioners, <6,000 Btu/h, with Louvers: LCC and PBP 

Results....................................................................................................................20 

Table ES.3.30 Room Air Conditioners, 8,000-13,999 Btu/h, with Louvers: LCC and PBP 

Results....................................................................................................................21 

Table ES.3.31 Room Air Conditioners, 20,000 Btu/h, with Louvers: LCC and PBP 

Results....................................................................................................................21 

Table ES.3.32 Room Air Conditioners, 8,000-13,999 Btu/h, without Louvers: LCC and 

PBP Results............................................................................................................21 

Table ES.3.33 Clothes Dryers: Cumulative NES Results (quads) ................................................25 

Table ES.3.34 Room Air Conditioners: Cumulative NES Results (quads)...................................25 

Table ES.3.35 Clothes Dryers: Cumulative Consumer Net Present Value, Discounted at 3 

Percent....................................................................................................................26 

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EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.36 Clothes Dryers: Cumulative Consumer Net Present Value, Discounted at 7 

Percent....................................................................................................................26 

Table ES.3.37 Room Air Conditioners: Cumulative Consumer Net Present Value, 

Discounted at 3 Percent .........................................................................................26 

Table ES.3.38 Room Air Conditioners: Cumulative Consumer Net Present Value, 

Discounted at 7 Percent .........................................................................................27 

LIST OF FIGURES 

Figure ES.1.1 Flow Diagram of Analyses for the Residential Clothes Dryers and Room 

Air Conditioners Rulemaking Process...............................................................ES-2 

Figure ES.3.1 Forecasted Shipments for Clothes Dryers (Base Case) ...................................ES-23 

Figure ES.3.2 Forecasted Shipments for Room Air Conditioners (Base Case)......................ES-23 

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EERE-2007-BT-STD-0010 COMMENT 20.3
EXECUTIVE SUMMARY 

ES.1 OVERVIEW OF PRELIMINARY ACTIVITIES

Section 6295(o)(3)(B) of 42 U.S.C. requires the U.S. Department of Energy (DOE) to 

establish energy conservation standards that are technologically feasible and economically 

justified, and would achieve the maximum improvement in energy efficiency. This executive 

summary summarizes the preliminary activities that DOE conducted in consideration of 

amended energy conservation standards for residential clothes dryers and room air conditioners. 

The executive summary describes the preliminary activities and summarizes key results from 

DOE’s preliminary analyses. Additionally, the executive summary delineates issues identified 

during the analyses about which DOE seeks comments from interested parties. These issues are 

highlighted in the public meeting presentation and are further discussed in chapter 2 of the 

preliminary technical support document (TSD). 

Figure ES.1.1 presents a summary of the analytical components of the standards-setting 

process and illustrates how key results are generated. The focal point of the figure is the center 

column, labeled “Analyses.” The columns labeled “Key Inputs” and “Key Outputs” show how 

the analyses fit into the process and how they relate to each other. Key inputs are the types of 

data and other information that the analyses require. Some key information is obtained from 

public databases; DOE collects other inputs from interested parties or persons having special 

knowledge and expertise. Key outputs are analytical results that feed directly into the standardssetting process. The issues on which DOE seeks comment from interested parties derive from the 

key results that are generated by the pre-NOPR analyses. Arrows connecting analyses show the 

types of information that feed from one analysis to another. 

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EERE-2007-BT-STD-0010 COMMENT 20.3
Utility Impact

Analysis 

Notice of Proposed Rulemaking (NOPR) 

Final Rule 

Market and Technology 

Assessment 

Screening Analysis 

Engineering Analysis 

Markups for 

Product Price 

Determination Life-Cycle Cost and 

Payback Period

Analysis 

National Impact

Analysis 

Energy Use 

Revise Pre-NOPR 

Analyses 

Life-Cycle Cost

Sub-Group Analysis 

Manufacturer Impact 

Analysis 

Shipments 

Analysis 

Employment Impact

Analysis 

Revise Analyses 

• Product Classes 

• Technology Options 

• Industry C ash Flow 

• Su b-Group Cash-Flow 

• Direct Employment Impacts 

• Compe titive Impacts 

• Cumulative Regulatory Burden 

• Cost-Efficie ncy R elat ionship 

• Life -Cycle Costs 

• Pa yback Periods 

• National Energ y Savings 

• Net Prese nt Values 

• National Employm ent Im pacts 

• Revised R esu lts 

• Market Se gmenta tion 

• Non-Regulatory Programs 

Framework Document 

• Energy Prices 

• Installation C osts 

• Maintenan ce & Repair Costs 

• Backcast an d Fo recast 

• Ma rket Saturation 

• Stakeholder Com ments 

• D emographics 

• Emission Rat es 

• National Energy Savings 

• Stakeholder Comm ents 

• Id entify Firms/Products 

• H istorical Shipments 

• Manufacturer Prices 

• Average Co sts 

• M anufacturer Financial Da ta 

D esign Options 

Pro duct Classes 

Retail Prices 

D esign Ene rgy 

Notice of Public Meeting (NOPM) 

• Efficie ncy/Perform ance 

• Ma nufacturing C ost 

Candidate 

Standard 

Leve ls 

Environmental 

Assessment 

Regulatory Impact 

Analysis 

Technolo gy Op tions 

• Em issio n Estima tes 

• Utilit y Lo ad Fa cto rs 

• Na tion al Ene rgy Saving s 

• Non -Reg ula tory 

Alternatives 

• Desig n Optio ns 

• Ene rgy Price Fo recasts 

• Site-to-Sou rce Fa cto rs 

• Energy-Efficiency Levels 

Direct Em plo ymen t 

Impacts 

• National Energy Savings 

• National Product Costs 

• National Operating Costs 

• Utility Impacts 

• Life -Cycle Costs 

• Pa yback Periods 

• Installation 

Costs 

• Maint C osts 

• Rep air Costs 

• UEC 

• Energy 

Prices 

• Annu al En ergy Use (UEC) 

Preliminary 

Manufacturer Impact

Analysis 

• Manufa ctu rer Prices 

• Ave rage C osts 

• Conversion Capital E xpen ditures 

• Direct Emp loymen t Impacts 

• National Energ y Savings 

• Net Presen t Values 

• Trial Standa rd Le vels (TSLs) 

TSLs 

• Product Prototypes 

Energy-Efficie ncy 

Le vels 

• Dep artm ent of Justice Revie w 

Figure ES.1.1 Flow Diagram of Analyses for the Residential Clothes Dryers 

and Room Air Conditioners Rulemaking Process 

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EERE-2007-BT-STD-0010 COMMENT 20.3
ES.2 OVERVIEW OF THE PRELIMINARY NOTICE OF PROPOSED 

RULEMAKING ANALYSES AND THE PRELIMINARY TECHNICAL 

SUPPORT DOCUMENT 

For the Pre-NOPR stage, DOE publishes a Pre-NOPR notice of public meeting (NOPM) 

in the Federal Register, which announces the availability of the preliminary technical support 

document, the date and place of the public meeting, and presentation materials interested parties 

may review before the public meeting. In addition, the NOPM highlights the major analyses 

DOE developed in the Pre-NOPR stage. The preliminary TSD describes each preliminary 

analysis in detail, providing detailed descriptions of inputs, sources, methodologies, and results. 

Chapter 2 of the preliminary TSD provides an overview of each preliminary analysis, the 

comments received in response to the analytical approaches DOE described in the framework 

document, and DOE’s responses to those comments. The following chapters of the preliminary 

TSD address the analyses performed for the Pre-NOPR stage. 

Chapter 3 - The market and technology assessment (MTA) characterizes the relevant product 

markets and technology options, including prototype designs. 

Chapter 4 - The screening analysis reviews each technology option uncovered in the MTA to 

determine whether it is technologically feasible; is practicable to manufacture, 

install, and service; would adversely affect product utility or product availability; or 

would have adverse impacts on health and safety. 

Chapter 5 - The engineering analysis develops cost-efficiency relationships that show a 

manufacturer’s cost of achieving increased efficiency. 

Chapter 6 - The markup analysis estimates consumer product prices based on market structures, 

and the manufacturing costs developed in the engineering analysis. 

Chapter 7 - The energy use analysis determines the annual energy consumption of the products 

under consideration. 

Chapter 8 - The life-cycle cost (LCC) and payback period (PBP) analysis calculates, based on 

the usage patterns, installed cost, energy prices, etc. developed in prior chapters, the 

total ownership costs for the life of the appliance at various efficiency levels. 

Chapter 9 - The shipments analysis documents historic unit shipments and forecasts future 

shipments of products under consideration. Shipment patterns heavily influence 

industry revenue and the net present value (NPV) of the industry. 

Chapter 10 - The national impact analysis (NIA) assesses the cumulative national energy savings 

(NES) from standards and the NPV of consumer costs and savings associated with 

standards at different efficiency levels. 

Chapter 12 - The preliminary manufacturer impact analysis (MIA) assesses the potential impacts 

of energy conservation standards on manufacturers, such as effects on expenditures 

for capital conversion, marketing costs, shipments, and research and development 

costs. 

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EERE-2007-BT-STD-0010 COMMENT 20.3
The remaining chapters of the preliminary TSD address the analyses to be performed for 

the NOPR stage: 

Chapter 11 - The life-cycle cost analysis for subgroups evaluates the effects of energy 

conservation standards on various national subgroups of the population. 

Chapter 13 - A utility impact analysis examines impacts of energy conservation standards on the 

generation capacity of electric utilities. 

Chapter 14 - An employment impact analysis examines the effects of energy conservation 

standards on national employment. 

Chapter 15 - An environmental assessment examines the effects of energy conservation 

standards on various airborne emissions. 

Chapter 16 - A regulatory impact analysis examines the national impacts of non-regulatory 

alternatives to mandatory energy conservation standards. 

ES.3 KEY RESULTS OF THE ANALYSIS 

The following sections describe analyses DOE performed in support of the TSD and 

present the key results. 

ES.3.1 Market and Technology Assessment 

When initiating an analysis of potential energy conservation standards for appliance, 

DOE develops information for the products concerned on the present and past industry structure 

and market characteristics. This activity assesses industries and products both quantitatively and 

qualitatively, based on publicly available information. 

When evaluating and establishing energy conservation standards, DOE generally divides 

covered products into product classes by the type of energy used or by capacity or other 

performance-related features that affect efficiency. Different energy conservation standards may 

apply to different product classes. (42 U.S.C. 6295(q)) Table ES.3.1 describes all of the product 

classes being considered for residential clothes dryers in this rulemaking, while Table ES.3.2 

describes all the product classes being considered for room air conditioners. For residential 

clothes dryers, DOE plans to consider four product classes for vented dryers and two product 

classes for vent-less dryers, as shown in Table ES.3.1. This is a new analytical structure for 

clothes dryers, recognizing the unique utility that vent-less clothes dryers offer to consumers.1 

Another new entry with unique utility is the combination washer/dryer (i.e., a device which 

washes and then dries clothes in the same basket/cavity in a combined cycle). 

1

 Previously, DOE has described vent-less dryers as condensing dryers. The new designation reflects the actual 

consumer utility (i.e., no external vent required) and the market availability of vented dryers that also condense. 

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EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.1 Product Classes for Residential Clothes Dryer Products 

No. Product Class 

Vented dryers 

1 Electric, Standard (4.4 cubic feet (ft3

) or greater capacity) 

2 Electric, Compact (120 volts (V)) (less than 4.4 ft3

 capacity) 

3 Electric, Compact (240 V) (less than 4.4 ft3

 capacity) 

4 Gas 

Vent-less dryers 

5 Electric, Compact (240 V) (less than 4.4 ft3

 capacity) 

6 Electric, Combination Washer/Dryer 

For room air conditioners, DOE is considering the same 16 product classes that are 

covered in the current Federal energy conservation standards. 

Table ES.3.2 Product Classes for Room Air Conditioners 

No. Product Class 

Without reverse cycle and with louvered sides 

1 Less than 6,000 Btu/h 

2 6,000 to 7,999 Btu/h 

3 8,000 to 13,999 Btu/h 

4 14,000 to 19,999 Btu/h 

5 20,000 Btu/h or more 

Without reverse cycle and without louvered sides 

6 Less than 6,000 Btu/h 

7 6,000 to 7,999 Btu/h 

8 8,000 to 13,999 Btu/h 

9 14,000 to 19,999 Btu/h 

10 20,000 Btu/h or more 

With reverse cycle 

11 With louvered sides and less than 20,000 Btu/h 

12 Without louvered sides and less than 14,000 Btu/h 

13 With louvered sides and 20,000 Btu/h or more 

14 Without louvered sides and 14,000 Btu/h or more 

Casement 

15 Casement-Only 

16 Casement-Slider 

For both the residential clothes dryer and room air conditioner products that are the topic 

of this rulemaking, DOE addressed (1) manufacturer market share and characteristics, (2) 

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EERE-2007-BT-STD-0010 COMMENT 20.3
existing regulatory and non-regulatory initiatives for improving product efficiency, and (3) 

trends in product characteristics and retail markets. This information provided data and resource 

material throughout the analysis. 

DOE reviewed literature and interviewed manufacturers to develop an overall 

understanding of the residential clothes dryer and room air conditioner industries in the United 

States. Industry publications, including trade journals, literature from manufacturers, government 

agencies, and trade organizations provided the bulk of the information, including (1) 

manufacturers and their market share; (2) shipments by product type; (3) product information; 

and (4) industry trends. Chapter 3 of the preliminary TSD describes the market analysis and 

resulting information. 

DOE typically uses information about existing and past technology options and prototype 

designs to determine which technologies and combinations of technologies manufacturers use to 

attain higher performance levels. In consultation with interested parties, DOE develops a list of 

technologies to be considered. The identified technologies initially include all those DOE 

believes are technologically feasible. 

DOE developed separate lists of technologically feasible technologies for residential 

clothes dryers and room air conditioners. The lists were developed from trade publications, 

technical papers, and manufacturer literature and through consultation with manufacturers of 

components and systems. Because existing products contain many technologies for improving 

product efficiency, product literature and direct examination provided additional information. 

ES.3.2 Screening Analysis 

The screening analysis (chapter 4) examines whether identified technologies (1) are 

technologically feasible; (2) are practicable to manufacture, install, and service; (3) have an 

adverse impact on product utility or availability; and/or (4) have adverse impacts on health and 

safety. DOE develops an initial list of options for enhancing efficiency from the technologies 

that the technology assessment identified as feasible. In consultation with interested parties, DOE 

reviews the list to assess whether the technologies are practicable to manufacture, install, and 

service; would adversely affect product utility or availability; or would have adverse impacts on 

health and safety. In the subsequent engineering analysis, DOE further examines the technology 

options that it did not remove from consideration in the screening analysis. 

ES.3.3 Engineering Analysis 

The engineering analysis (chapter 5) establishes the relationship between the costs of 

manufacturing residential clothes dryers and room air conditioners and their efficiencies. These 

relationships serve as the basis for calculating costs and benefits of modified product designs for 

consumers, manufacturers, and the nation. Chapter 5 describes the product classes DOE 

analyzed, the representative baseline units, the efficiency levels DOE considered, the 

methodology DOE used to develop the manufacturing production cost model, and the costefficiency results. 

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EERE-2007-BT-STD-0010 COMMENT 20.3
ES.3.3.1 Product Classes Analyzed 

DOE based its preliminary analysis for residential clothes dryers on the integrated energy 

factor (IEF) proposed as an alternative energy conservation metric in the clothes dryer and room 

air conditioner test procedure NOPR that DOE published on December 9, 2008 (December 2008 

NOPR), 72 FR 74639, and is continuing to consider in a supplemental test procedure 

rulemaking. The IEF is defined as pounds of clothes load divided by the sum of energy use in 

active mode and energy use in standby mode per cycle. IEF levels were determined from the EF 

and standby energy use as discussed in chapter 5. The test procedure amendments proposed in 

the December 2008 NOPR do not alter the existing provisions for the measurement and 

calculation of EF. 

DOE conducted full analyses for all six product classes, representing essentially 100 

percent of residential clothes dryers sold. Table ES.3.3 shows the IEF assumed for baseline 

products in the preliminary analysis. 

Table ES.3.3 Baseline Residential Clothes Dryer IEF for Analyzed Product Classes 

Product Class 

Baseline EF 

(pounds 

(lb)/kilowatthour (kWh)) 

Baseline 

Standby Power 

(watts (W)) 

Baseline IEF 

(lb/kWh) 

1 3.01 2.0 2.96 

2 3.13 2.0 3.01 

3 2.90 2.0 2.79 

4 2.67 2.0 2.63 

5 2.37 2.0 2.30 

6 1.95 2.0 1.90 

DOE based its preliminary analysis for room air conditioners on the IEER integrated 

efficiency metric proposed as an alternative option in the December 2008 NOPR, and is 

continuing to consider in a supplemental test procedure rulemaking. The IEER is defined as the 

cooling capacity times annual hours of operation divided by the sum of energy use in active 

mode and energy use in standby mode. IEER levels were determined from the EER and standby 

energy use as discussed in chapter 5. The test procedure amendments proposed in the December 

2008 NOPR do not alter the existing provisions for the measurement and calculation of EER. 

DOE conducted full analyses for four key product classes that represent roughly 75 

percent of room air conditioner products sold. These included three product classes of louvered, 

non-reverse cycle room air conditioners, and one product class of non-louvered, non-reverse 

cycle room air conditioners. The four product classes that served as the basis for the costefficiency analysis are shown in Table ES.3.4. Chapter 5 includes additional details on the 

representative product classes. 

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EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.4 Baseline Room Air Conditioner IEER for Analyzed Product Classes 

Product Class 

Baseline EER 

(British Thermal 

Units 

(Btu)/hour(hr)-W) 

Baseline 

Standby Power 

(W) 

Baseline IEER 

(Btu/hr-W) 

1 9.7 1.4 9.52 

3 9.8 1.4 9.71 

5 8.5 1.4 8.47 

8 8.5 1.4 8.43 

ES.3.3.2 Manufacturing Cost Assessment 

DOE typically uses data submitted by the Association of Home Appliance Manufacturers 

(AHAM) as the primary source of cost information for the engineering analysis. AHAM 

provided DOE with aggregated incremental manufacturing cost data from its member companies 

for several product classes of vented clothes dryers. However, AHAM did not receive enough 

responses from members to allow aggregation and reporting of data for the remaining clothes 

dryer product classes and all room air conditioner product classes. 

For clothes dryers, DOE estimated the manufacturing costs associated with an increase in 

energy efficiency for each of the product classes analyzed. DOE conducted an independent 

review of the AHAM data using several methods and data sources. To gain a better 

understanding of the data submitted by member companies and to be able to relate the costs of 

improving efficiency to discrete (or system) technologies, DOE reviewed the TSD from the 

previous rulemaking and conducted interviews with clothes dryer manufacturers. DOE also 

performed detailed reverse-engineering, consisting of disassembling representative units, 

analyzing the materials and manufacturing processes, analyzing the design approaches 

manufacturers use, and developing a spreadsheet model to describe costs. DOE obtained input 

from interested parties on the manufacturing cost model inputs and results. Chapter 5 of the 

preliminary TSD includes information on the inputs used to determine the manufacturing cost, 

including material, labor, and overhead prices. Chapter 5 also includes information on the 

various components and features incorporated into designs for residential clothes dryers. 

DOE’s engineering analysis produced cost-efficiency curves, based on IEF, for the six 

residential clothes dryer product classes, which were compared to the AHAM data for validation. 

The cost-efficiency curves are described by the efficiency levels DOE analyzed and the increase 

in manufacturer production cost (MPC) required to improve a baseline-efficiency product to each 

of the considered efficiency levels. Table ES.3.5 through Table ES.3.10 present the results of the 

engineering analysis for clothes dryers. 

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EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.5 Incremental Cost Results for Residential Clothes Dryer Product Class 1 

Product Class 1: Vented Electric Standard Clothes Dryers 

Efficiency Level IEF 

Incremental MPC 

(2008$) 

Baseline 2.96 – 

1 3.04 $11.89 

2 3.10 $63.56 

3 3.33 $97.48 

4 3.35 $98.78 

5 3.40 $98.14 

6 4.52 $259.13 

Table ES.3.6 Incremental Cost Results for Residential Clothes Dryer Product Class 2 

Product Class 2: Vented Electric Compact (120 V) Clothes Dryers 

Efficiency Level IEF 

Incremental MPC 

(2008$) 

Baseline 3.00 – 

1 3.08 $10.95 

2 3.15 $63.37 

3 3.37 $96.45 

4 3.41 $97.75 

5 3.53 $97.11 

6 4.69 $246.35 

Table ES.3.7 Incremental Cost Results for Residential Clothes Dryer Product Class 3 

Product Class 3: Vented Electric Compact (240 V) Clothes Dryers 

Efficiency Level IEF 

Incremental MPC 

(2008$) 

Baseline 2.79 – 

1 2.86 $10.95 

2 2.96 $63.37 

3 3.06 $96.45 

4 3.10 $97.75 

5 3.19 $97.11 

6 4.34 $246.35 

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EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.8 Incremental Cost Results for Residential Clothes Dryer Product Class 4 

Product Class 4: Vented Gas Clothes Dryers 

Efficiency Level IEF 

Incremental MPC 

(2008$) 

Baseline 2.63 – 

1 2.71 $14.79 

2 2.80 $65.36 

3 2.97 $156.01 

4 2.98 $157.31 

5 3.02 $156.67 

Table ES.3.9 Incremental Cost Results for Residential Clothes Dryer Product Class 5 

Product Class 5: Vent-less Electric Compact (240 V) Clothes Dryers 

Efficiency Level IEF 

Incremental MPC 

(2008$) 

Baseline 2.29 – 

1 2.31 $1.30 

2 2.37 $0.66 

3 2.39 $13.01 

4 2.59 $69.02 

5 3.54 $216.37 

Table ES.3.10 Incremental Cost Results for Residential Clothes Dryer Product Class 6 

Product Class 6: Vent-less Electric Combination Washer/Dryers 

Efficiency Level IEF 

Incremental MPC 

(2008$) 

Baseline 1.90 – 

1 2.15 $0.81 

2 2.34 $54.04 

3 2.39 $55.34 

4 2.42 $54.70 

5 3.31 $230.83 

DOE estimated the manufacturing costs associated with an increase in energy efficiency 

for each of the room air conditioner product classes analyzed. The assessment method involved 

disassembling representative units, analyzing the materials and manufacturing processes, 

analyzing the design approaches manufacturers use, and developing a spreadsheet model to 

describe costs. DOE built a detailed model for assessing manufacturing cost that estimates MPC. 

DOE also aggregated manufacturers’ costs to maintain confidentiality of the data. DOE obtained 

input from interested parties on the manufacturing cost model inputs. In the absence of industrysupplied data, DOE conducted energy modeling analysis to determine the efficiency gains from 

various product design options. Chapter 5 of the preliminary TSD includes information on the 

inputs used to determine the manufacturing cost, including material, labor, and overhead prices. 

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EERE-2007-BT-STD-0010 COMMENT 20.3
Chapter 5 also includes information on the energy modeling analysis and the various components 

and features incorporated into designs for room air conditioners. 

DOE’s engineering analysis produced cost-efficiency curves for the four representative 

room air conditioner product classes. The cost-efficiency curves are described by the efficiency 

levels DOE analyzed and the increase in MPC required to improve a baseline-efficiency product 

to each of the considered efficiency levels. 

DOE calculated the costs for each IEER level based on appropriate selection of active 

mode and standby mode design options. In cases where the IEER efficiency level does not 

coincide with the IEER determined for the design configuration directly analyzed with energy 

and manufacturing cost modeling, DOE took the following approach. If the next design option 

could be partially applied (such as increase in size of a heat exchanger), DOE interpolated 

between costs and IEER levels calculated for the nearest design configurations. If the next design 

option could not be partially applied (such as switch from a permanent-split capacitor (PSC) 

motor to a brushless direct current (DC) motor), the full cost of the next design option was 

applied. 

Table ES.3.11 through Table ES.3.14 present the key results of the engineering analysis 

for room air conditioners. The results presented for each IEER efficiency level are the 

incremental MPC and the total cost to ship the product to a U.S. port, since the vast majority of 

room air conditioners are produced overseas. The shipping cost was calculated to assure that 

shipping cost increases associated with any product size increases are considered. The MPCs for 

the baseline efficiency level are non-zero because they reflect the calculated cost to maintain this 

efficiency level while converting to R-410A refrigerant. 

Table ES.3.11 Cost Results for Room Air Conditioner Product Class 1 

Product Class 1: Without Reverse Cycle, 

With Louvered Sides, < 6,000 Btu/h 

Efficiency 

Level 

IEER Incremental 

MPC 

Total Shipping Cost 

Baseline 9.52 $7.65 $4.18 

1 10.1 $12.18 $5.31 

2 10.6 $18.22 $6.25 

3 11.1 $27.19 $7.64 

4 11.6 $37.30 $8.39 

5 12.0 $44.10 $8.39 

ES-11 

EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.12 Cost Results for Room Air Conditioner Product Class 3 

Product Class 3: Without Reverse Cycle, 

With Louvered Sides, 8,000 - 13,999 Btu/h 

Efficiency 

Level 

IEER Incremental MPC Total Shipping Cost 

Baseline 9.71 $10.39 $10.39 

1 10.3 $18.11 $12.25 

2 10.8 $25.68 $14.65 

3 11.3 $40.51 $18.21 

4 11.5 $78.59 $18.21 

Table ES.3.13 Cost Results for Room Air Conditioner Product Class 5 

Product Class 5: Without Reverse Cycle, 

With Louvered Sides, 20,000 Btu/h 

Efficiency 

Level 

IEER Incremental 

MPC 

Total 

Shipping Cost 

Baseline 8.47 $23.78 $24.79 

1 9.0 $37.47 $27.88 

2 9.4 $52.84 $32.66 

3 9.8 $75.30 $36.46 

4 10.0 $104.34 $36.46 

Table ES.3.14 Cost Results for Room Air Conditioner Product Class 8 

Product Class 8: Without Reverse Cycle, Without Louvered 

Sides, 8,000 – 13,999 Btu/hr 

Efficiency 

Level 

IEER Incremental 

MPC 

Total Shipping 

Cost 

Baseline 8.43 $7.45 $12.26 

1 8.9 $10.95 $12.26 

2 9.3 $15.36 $12.26 

3 9.8 $28.82 $12.26 

ES.3.4 Markups to Determine Product Price 

The markups analysis (chapter 6) develops appropriate markups in the distribution chain 

to convert the estimates of manufacturer cost derived in the engineering analysis to consumer 

prices. In developing markups, DOE determined the distribution channels for residential clothes 

dryers and room air conditioners and the markup associated with each party in the distribution 

channel. Because an overwhelming majority of the considered products are sold through retail 

outlets, DOE estimated that all of the products are purchased by consumers from retail outlets. 

DOE developed separate markups for baseline products (baseline markups) and for the 

cost increase associated with improvements required to produce more-efficient products 

(incremental markups). DOE also added sales tax to the estimated retail prices. Table ES.3.15 

summarizes the markups developed for clothes dryers and room air conditioners. 

ES-12 

EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.15 Markups for Clothes Dryers and Room Air Conditioners 

Markup Baseline Incremental 

Manufacturer 1.26 

Retailer 1.45 1.15 

Sales Tax

 Clothes Dryers 

Room Air Conditioners 

1.068 

1.067 

ES.3.5 Energy Use Characterization 

The energy use characterization provides the basis for estimating the energy savings from 

higher efficiency appliances used in the LCC and subsequent analyses. The DOE test procedure 

provides standardized results that can serve as the basis for comparing the performance of 

different appliances used under the same conditions, but actual usage in the field may differ from 

usage estimated by the test procedure. 

To determine the variation in field energy use by products that would meet possible 

energy efficiency standards, DOE used data from the Energy Information Administration (EIA)’s 

2005 Residential Energy Consumption Survey (RECS). 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. To determine the energy use patterns of room air conditioners in commercial 

applications, DOE used EIA’s 2003 Commercial Building Energy Consumption Survey (CBECS) 

to develop a representative sample of commercial buildings that have room air conditioners. For 

both room air conditioners and clothes dryers, each sample was divided into sub-samples to 

match the product classes analyzed. 

For clothes dryers with a specific efficiency, the annual energy consumption depends on 

the annual number of cycles. DOE estimated the number of clothes dryer cycles per year for each 

sample home using data given by RECS on the number of laundry loads (clothes washer cycles) 

washed per week and the frequency of clothes dryer use. The calculated average is 285 cycles 

per year for electric standard clothes dryers and 271 cycles per year for gas standard clothes 

dryers. 

For a room air conditioner with a specific size and EER, the annual energy use depends 

on the annual hours of operation. For each considered room air conditioner capacity, DOE 

calculated the number of operating hours for each room air conditioner in the residential sample 

using the reported energy use for room air conditioning in the 2005 RECS along with estimates 

of the EER of the room air conditioner(s) in each sample home. DOE based the latter on the 

reported age of the unit and historical data on shipment-weighted average EER. The estimated 

mean number of operating hours for the residential room air conditioner sample is 1,310 hr for 

the >6000 Btu/h product class, 678 hr for the 8,000 to 13,999 Btu /h product classes, and 394 hr 

for the 20,000 Btu /h product class. 

ES-13 

EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.16 through Table ES.3.18 show the results of the energy use analysis for the 

clothes dryer product classes at each considered energy efficiency level, and Table ES.3.19 

through Table ES.3.22 show the results for the representative room air conditioner product 

classes at each considered energy efficiency level. Chapter 7 provides more details on the 

methods, data, and assumptions used for the energy use analysis. 

Table ES.3.16 Vented Electric Standard and Gas Clothes Dryers: Average Annual 

Energy Consumption by Efficiency Level 

Electric Gas 

Integrated 

Energy Factor 

(lb/kWh) 

kWh/year 

Integrated 

Energy 

Factor 

(lb/kWh) 

MMBtu/ 

year kWh/year 

2.96 519 2.63 1.65 71.4 

3.04 504 2.71 1.60 71.4 

3.10 495 2.80 1.53 71.4 

3.33 461 2.97 1.45 67.9 

3.35 457 2.98 1.45 63.6 

3.40 445 3.02 1.45 51.6 

4.52 335 -- -- --

Table ES.3.17 Vented Electric Compact Clothes Dryers: Average Annual Energy 

Consumption by Efficiency Level 

120V 240V 

Integrated Energy 

Factor 

(lb/kWh) 

kWh/year 

Integrated 

Energy Factor 

(lb/kWh) 

MMBtu/ year 

3.00 270 2.79 290 

3.08 263 2.86 283 

3.15 258 2.96 274 

3.37 241 3.06 265 

3.41 237 3.10 260 

3.53 225 3.19 248 

4.69 169 4.34 183 

ES-14 

EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.18 Vent-less Electric Compact (240 V) Clothes Dryers and Vent-less Electric 

Combination Washer/Dryer: Average Annual Energy Consumption by 

Efficiency Level 

Compact Vent-less Dryer (240V) Combination Washer-Dryer 

Integrated Energy 

Factor 

(lb/kWh) 

kWh/year 

Integrated 

Energy Factor 

(lb/kWh) 

kWh/year 

2.29 351 1.90 424 

2.31 347 2.15 375 

2.37 335 2.34 344 

2.39 332 2.36 340 

2.59 307 2.42 328 

3.54 224 3.31 239 

Table ES.3.19 Room Air Conditioner, Without Reverse Cycle, With Louvered Sides, 

<6,000 Btu/h: Average Annual Energy Use 

Efficiency 

(IEER) 

Residential 

(kWh) 

Commercial 

(kWh) 

9.52 688 640 

10.1 648 604 

10.6 618 575 

11.1 590 549 

11.6 565 526 

12.0 546 508 

Table ES.3.20 Room Air Conditioner, Without Reverse Cycle, With Louvered Sides, 

8,000-13,999 Btu/h: Average Annual Energy Use 

Efficiency 

(IEER) 

Residential 

(kWh) 

Commercial 

(kWh) 

9.71 672 1181 

10.3 632 1110 

10.8 602 1059 

11.3 576 1012 

11.5 566 994 

ES-15 

EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.21 Room Air Conditioner, Without Reverse Cycle, With Louvered Sides, 

20,000 Btu/h: Average Annual Energy Use 

Efficiency 

(IEER) 

Residential 

(kWh) 

Commercial 

(kWh) 

8.47 1118 3343 

9.0 1052 3146 

9.4 1007 3012 

9.8 966 2889 

10.0 947 2832 

Table ES.3.22 Room Air Conditioner, Without Reverse Cycle, Without Louvered Sides, 

8,000-13,999 Btu/h: Average Annual Energy Use 

Efficiency 

(IEER) 

Residential 

(kWh) 

Commercial 

(kWh) 

8.43 712 1359 

8.9 673 1285 

9.3 644 1230 

9.8 611 1167 

ES.3.6 Life-Cycle Cost and Payback Period Analyses 

Stipulating new energy conservation standards for products results in changes in 

consumer operating expenses—usually a decrease—and changes in consumer price—usually an 

increase. DOE analyzed the net effect of amended standards on consumers by evaluating the 

LCC using the cost-efficiency relationship derived in the engineering analysis, as well as the 

energy costs derived from the energy use characterization. Inputs to the LCC calculation 

included the installed cost to the consumer (purchase price plus installation cost), operating costs 

(primarily energy expenses), the lifetime of the appliance, and a discount rate. 

Because the installed cost of a product typically increases while operating cost typically 

decreases in response to new standards, there is a time in the life of products having higher-thanbaseline efficiency when the net operating-cost benefit (in dollars) since the time of purchase is 

equal to the incremental first cost of purchasing the higher efficiency product. The length of time 

required for products to reach this cost-equivalence point is known as the payback period (PBP). 

DOE conducted the LCC and PBP analyses using values that reflect utilization of the 

products in the field. DOE identified several input values for estimating the LCC, including retail 

product prices, energy prices, product lifetimes, and discount rates. 

ES-16 

EERE-2007-BT-STD-0010 COMMENT 20.3
For room air conditioners, DOE used utility tariff data to develop monthly marginal 

electricity prices for each RECS household in the LCC sample. The marginal prices are 

calculated by taking account of the difference between the household’s electricity expenditures 

for the base-case electricity use and for a candidate standard level, in combination with the 

associated change in energy use. The price used is based on the standard (non-TOU) tariffs. DOE 

then applied the monthly prices to the estimated electricity use by the room air conditioner in 

each corresponding month. For clothes dryers, DOE used EIA’s energy price data to determine 

average annual residential prices of electricity and natural gas in 13 geographic areas. To 

estimate the future trends in energy prices, DOE used projections from EIA’s Annual Energy 

Outlook 2009 (AEO 2009). 

Because the basis for the lifetime estimates in the literature for clothes dryers and room 

air conditioners is uncertain, DOE used actual data sources to estimate the distribution of clothes 

dryer and room air conditioner lifetimes in the field. By combining survey results from RECS 

and the U.S. Census’s American Housing Survey with the known history of appliance shipments, 

DOE estimated the fraction of appliances of a given age still in operation. The survival function, 

which DOE assumed has the form of a cumulative Weibull distribution, provides an average and 

median appliance lifetime. The analysis yielded an average lifetime for room air conditioners of 

approximately 10.5 years and for clothes dryers of approximately 16 years. 

To estimate the share of consumers that would be affected by a standard at a particular 

efficiency level, DOE’s LCC and PBP analysis considered the projected distribution (i.e., market 

shares) of product efficiencies that consumers purchase under the base case (i.e., the case without 

new energy efficiency standards). DOE primarily relied on data submitted by AHAM to estimate 

the efficiency distributions in recent years for each of the product classes that were analyzed in 

the LCC and PBP analysis. DOE found that the data on recent trends in shipment-weighted 

average efficiency of room air conditioners and shares of ENERGY STAR products are 

inconclusive. Therefore, DOE assumed that the market shares of the efficiency levels in 2014 

will be roughly the same as the shares in 2007. DOE also found little evidence that would 

suggest much change in the distribution of energy efficiencies of clothes dryers in coming years. 

Using the projected distribution of product efficiencies for each product class, DOE 

assigned a specific product efficiency to each sample household. 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 show that this household is not impacted by that 

standard level. 

Table ES.3.23 through Table ES.3.28 show the results of the LCC and PBP analyses for 

the clothes dryer product classes at each considered energy efficiency level, and Table ES.3.29 

through Table ES.3.32 show the results for the representative room air conditioner product 

classes at each considered energy efficiency level. The tables for room air conditioners show the 

combined results for residential and commercial users. The average lifetime operating cost 

presented in the tables is a discounted value. Figures presented in chapter 8 show the range of 

LCC savings and PBPs for all of the efficiency levels considered for each product class. 

ES-17 

EERE-2007-BT-STD-0010 COMMENT 20.3
Chapter 8 provides more details on the methods, data, and assumptions used for the LCC 

and PBP analyses. 

Table ES.3.23 Vented Electric Standard Clothes Dryers: LCC and PBP Results 

CSL 

Baseline

1 

2 

3 

4 

5 

6 

Efficiency 

lb/kWh 

2.96 

3.04 

3.10 

3.33 

3.35 

3.40 

4.52 

Life-Cycle Cost 

Average 

Installed 

Cost 

Average 

Lifetime 

Operating 

Cost 

Average 

LCC 

$552 $657 $1,209 

$571 $638 $1,209 

$651 $627 $1,277 

$703 $584 $1,287 

$705 $578 $1,284 

$704 $563 $1,267 

$953 $424 $1,377 

Life-Cycle Cost Savings 

Households with 

Average 

Savings 

Net 

Cost 

No 

Impact 

Net 

Benefit 

$0 19% 70% 10% 

-$54 78% 21% 1% 

-$64 87% 0% 13% 

-$60 86% 0% 14% 

-$44 79% 0% 21% 

-$154 85% 0% 15% 

Payback Period 

(years) 

Median Average 

15.2 35.6 

78.0 244.6 

30.5 88.2 

27.5 40.2 

20.6 24.6 

24.9 34.7 

Table ES.3.24 Vented Gas Clothes Dryers: LCC and PBP Results 

CSL 

Efficiency 

lb/kWh 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Installed 

Cost 

Average 

Lifetime 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Households with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 2.63 $661 $353 $1,014 

1 2.71 $684 $345 $1,029 -$4 25% 73% 2% 46.3 146.4 

2 2.80 $762 $335 $1,098 -$52 70% 30% 0% 117.6 342.4 

3 2.97 $903 $318 $1,220 -$174 99% 1% 0% 121.7 346.9 

4 2.98 $905 $312 $1,216 -$170 99% 0% 1% 92.3 109.5 

5 3.02 $904 $295 $1,199 -$152 98% 0% 2% 53.3 56.6 

ES-18 

EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.25 Vented Electric Compact (120 V) Clothes Dryers: LCC and PBP Results 

CSL 

Efficiency 

lb/kWh 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Installed 

Cost 

Average 

Lifetime 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Households with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 3.00 $553 $343 $896 

1 3.08 $570 $334 $904 -$8 87% 0% 13% 28.7 74.4 

2 3.15 $651 $327 $978 -$82 100% 0% 0% 95.5 247.3 

3 3.37 $702 $306 $1,008 -$112 98% 0% 2% 61.1 158.0 

4 3.41 $704 $300 $1,004 -$109 98% 0% 2% 51.8 66.5 

5 3.53 $703 $285 $988 -$92 96% 0% 4% 35.4 38.1 

6 4.69 $934 $215 $1,148 -$253 96% 0% 4% 43.0 52.8 

Table ES.3.26 Vented Electric Compact (240 V) Clothes Dryers: LCC and PBP Results 

CSL 

Efficiency 

lb/kWh 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Installed 

Cost 

Average 

Lifetime 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Households with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 2.79 $553 $368 $921 

1 2.86 $570 $359 $929 -$3 34% 61% 5% 28.0 81.3 

2 2.96 $651 $347 $998 -$57 77% 22% 1% 84.8 227.4 

3 3.06 $702 $336 $1,038 -$88 77% 22% 1% 78.0 207.8 

4 3.10 $704 $330 $1,034 -$84 78% 0% 22% 49.0 60.9 

5 3.19 $703 $315 $1,018 -$68 76% 0% 24% 33.1 32.2 

6 4.34 $934 $232 $1,166 -$216 95% 0% 5% 38.6 47.8 

Table ES.3.27 

ES-19 

EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.28 Vent-less Electric Compact (240 V) Clothes Dryers: LCC and PBP 

Results 

CSL 

Efficiency 

lb/kWh 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Installed 

Cost 

Average 

Lifetime 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Households with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 2.29 $1,240 $446 $1,686 

1 2.31 $1,242 $440 $1,683 $3 3% 0% 97% 4.7 4.5 

2 2.37 $1,241 $425 $1,666 $20 0% 0% 100% 0.6 0.6 

3 2.39 $1,260 $421 $1,682 $4 48% 0% 52% 10.4 10.2 

4 2.59 $1,347 $389 $1,736 -$50 90% 0% 10% 25.6 27.5 

5 3.54 $1,575 $284 $1,859 -$173 90% 0% 10% 30.2 38.7 

Table ES.3.29 Vent-less Electric Combination Washer/Dryers: LCC and PBP Results 

CSL 

Efficiency 

lb/kWh 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Installed 

Cost 

Average 

Lifetime 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Households with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 1.90 $1,582 $537 $2,119 

1 2.15 $1,583 $476 $2,059 $60 1% 0% 99% 0.3 0.8 

2 2.34 $1,665 $436 $2,102 $17 58% 0% 42% 12.6 32.7 

3 2.36 $1,667 $432 $2,099 $20 56% 0% 44% 12.1 18.4 

4 2.42 $1,666 $416 $2,083 $36 47% 0% 53% 10.1 12.3 

5 3.31 $1,939 $304 $2,242 -$124 82% 0% 18% 22.6 30.9 

Table ES.3.30 Room Air Conditioners, <6,000 Btu/h, with Louvers: LCC and PBP 

Results 

CSL IEER 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Installed 

Cost 

Average 

Lifetime 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Users with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 9.52 $329 $648 $976 

1 10.1 $337 $613 $950 $26 15% 4% 81% 0.9 6.3 

2 10.6 $347 $586 $933 $42 20% 4% 76% 1.6 11.6 

3 11.1 $362 $561 $924 $51 30% 0% 70% 2.4 14.0 

4 11.6 $379 $539 $917 $57 36% 0% 64% 3.1 17.1 

5 12.0 $389 $522 $911 $63 38% 0% 62% 3.4 23.5 

ES-20 

EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.31 Room Air Conditioners, 8,000-13,999 Btu/h, with Louvers: LCC and PBP 

Results 

CSL IEER 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Installed 

Cost 

Average 

Lifetime 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Users with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 9.71 $489 $655 $1,144 

1 10.3 $502 $614 $1,117 $14 14% 49% 37% 1.6 10.4 

2 10.8 $517 $584 $1,100 $23 17% 47% 36% 2.5 11.9 

3 11.3 $543 $556 $1,099 $24 53% 3% 44% 6.7 33.1 

4 11.5 $602 $546 $1,148 -$24 69% 1% 30% 11.2 79.1 

Table ES.3.32 Room Air Conditioners, 20,000 Btu/h, with Louvers: LCC and PBP 

Results 

CSL IEER 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Installed 

Cost 

Average 

Lifetime 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Users with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 8.47 $860 $1,255 $2,115 

1 9.0 $884 $1,181 $2,065 $21 14% 63% 23% 3.2 7.3 

2 9.4 $913 $1,131 $2,043 $33 21% 57% 23% 5.5 7.6 

3 9.8 $951 $1,084 $2,035 $40 63% 1% 37% 11.8 14.5 

4 10.0 $996 $1,062 $2,058 $17 71% 0% 29% 15.8 20.9 

Table ES.3.33 Room Air Conditioners, 8,000-13,999 Btu/h, without Louvers: LCC and 

PBP Results 

CSL IEER 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Installed 

Cost 

Average 

Lifetime 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Users with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 8.43 $557 $702 $1,259 

1 8.9 $562 $661 $1,223 $14 3% 61% 36% 0.8 2.6 

2 9.3 $569 $631 $1,200 $23 4% 61% 35% 1.1 3.7 

3 9.8 $590 $596 $1,186 $37 39% 0% 61% 4.7 17.9 

ES-21 

EERE-2007-BT-STD-0010 COMMENT 20.3
ES.3.7 Shipments Analysis 

Shipment forecasts are needed to calculate for each product being considered the national 

impacts of standards on energy use, NPV, and future manufacturer cash flows. DOE’s shipments 

models consider shipments for new homes, replacements and other types of purchases. Rather 

than simply extrapolating a current shipments trend, the analysis uses driver input variables to 

forecast sales in each market segment. For new housing units, annual product shipments are 

equal to the number of new housing units built times the purchase rate, which is determined by 

the market share of the product under consideration. To estimate shipments due to replacements, 

the models use shipments in previous years and assumptions about the product lifetime, which 

determine how long an appliance is likely to remain in use. Chapter 9 of the TSD provides 

additional detail on the shipments analysis. 

Figure ES.3.1 and Figure ES.3.2 illustrate the forecasted base-case shipments by market 

segment for clothes dryers and room air conditioners, respectively, along with actual historic 

shipments. The leveling off of the trend forecasted for room air conditioners reflects the product 

reaching saturation of its eligible market. 

ES-22 

EERE-2007-BT-STD-0010 COMMENT 20.3
Figure ES.3.1 Forecasted Shipments for Clothes Dryers (Base 

Case) 

0 

2 

4 

6 

8 

10 

12 

1980 1985 1990 1995 2000 2005 2010 2015 2020 2025 2030 2035 2040 

Millions 

Shipments to Commercial 

Buildings 

New Purchases 

RAC Replacements 

Historical Shipments 

Figure ES.3.2 Forecasted Shipments for Room Air Conditioners 

(Base Case) 

ES-23 

EERE-2007-BT-STD-0010 COMMENT 20.3
ES.3.8 National Impact Analysis 

The NIA estimates the following national impacts from possible candidate standard 

levels for residential clothes dryers and room air conditioners: (1) national energy savings (NES), 

(2) monetary value of the energy savings due to standards, (3) increased total installed costs of 

the considered products due to standards, and (4) the net present value (NPV) of energy savings 

(difference between value of energy savings and increased total installed costs). DOE prepared a 

spreadsheet model to forecast energy savings and national consumer economic costs and savings 

resulting from new standards. In contrast to the LCC and payback period analyses, which use 

probability distributions for the inputs, the NIA uses average or typical values for inputs. 

A key component of DOE’s estimates of NES and NPV is the trend in energy efficiency 

forecasted for the base case (without new standards) and each of the standards cases (with new 

standards). For residential clothes dryers and room air conditioners, DOE did not forecast any 

change in the base-case efficiency distributions over the forecast period. For its determination of 

standards-case efficiency distributions, DOE used a “roll-up” scenario to establish the 

distribution of efficiencies for the year that amended standards are assumed to become effective 

(i.e., 2014) and subsequent years. DOE assumed 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 in 2014. 

For clothes dryers, DOE’s analysis focused on vented electric standard and vented gas 

products. For room air conditioners, DOE analyzed four product classes in detail throughout its 

analysis. For the NIA, DOE assigned each of the 16 product classes to one of four product 

categories, based on technology and efficiency considerations. Thus, the results refer to all 16 

product classes. Chapter 10 provides additional details on this and other aspects of the NIA 

analysis. 

ES.3.8.1 National Energy Savings 

DOE calculated annual NES as the difference between national energy consumption in 

the base case (without new efficiency standards) and under each candidate standard level (CSL). 

DOE estimated energy consumption and savings based on site energy and converted the site 

energy values to primary (source) energy using factors that account for losses in transmission 

and distribution and in electricity generation. Cumulative energy savings are the sum of the 

annual NES, which DOE determined over specified periods. 

The NES results shown in Table ES.3.33 and Table ES.3.34 are cumulative to 2044 and 

are shown as primary energy savings (not discounted) in quads (quadrillion Btu’s). 

ES-24 

EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.34 Clothes Dryers: Cumulative NES Results (quads) 

Product Class Candidate Standard Level 

1 2 3 4 5 6 

Vented Electric Standard 0.04 0.11 0.42 0.46 0.57 1.34 

Vented Electric Compact 120V 0.00 0.00 0.00 0.00 0.00 0.00 

Vented Electric Compact 240V 0.00 0.00 0.00 0.00 0.00 0.01 

Vented Gas 0.01 0.02 0.06 0.07 0.10 

Vent-less Electric Compact 240V 0.00 0.00 0.00 0.01 0.01 

Vent-less Electric Combination Washer/Dryer 0.00 0.00 0.00 0.01 0.01 

Table ES.3.35 Room Air Conditioners: Cumulative NES Results (quads) 

Product Class* Candidate Standard Level 

1 2 3 4 5 

Group 1 - based on Less than 6,000 

Btu/h, with Louvers 

0.15 0.26 0.37 0.46 0.52 

Group 2 - based on 8,000-13,999 

Btu/h, with Louvers 

0.16 0.29 0.49 0.64 

Group 3 - based on 20,000 Btu/h or 

more, with Louvers 

0.01 0.02 0.04 0.05 

Group 4 - based on 8,000-13,999 

Btu/h, with Louvers 

0.02 0.03 0.07 

* Group 1 consists of product class 1: Less than 6,000 Btu/h, Without Reverse Cycle and With Louvers 

Group 2 consists of product classes 2, 3, 4, 11, 16 and is based on Product class 3: 8,000-13,999 Btu/h, Without 

Reverse Cycle and With Louvers 

Group 3 consists of product classes 5 and 12 and is based on product class 12: >20,000 Btu/h, Without Reverse 

Cycle and With Louvers 

Group 4 consists of product classes 6, 7, 8, 9, 10, 13,14 and 15 and is based on product class 8: 8,000-13,999 Btu/h, 

Without Reverse Cycle and Without Louvers 

ES.3.8.2 Net Present Value 

DOE calculated net monetary savings each year as the difference between total savings in 

operating costs and increases in total equipment costs in the base case and standards cases. DOE 

calculated savings over the life of the products purchased in the forecast period. The NPV is the 

difference between the present value of operating cost savings and the present value of increased 

total installed costs. DOE used discount rates of 7 percent and 3 percent to discount future costs 

and savings to the present. The NPV results by product class are shown in Table ES.3.35 through 

Table ES.3.38. A negative NPV indicates that the costs of a standard at a given efficiency level 

exceed the savings. 

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EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.36 Clothes Dryers: Cumulative Consumer Net Present Value, Discounted at 

3 Percent 

Product Class Candidate Standard Level 

1 2 3 4 5 6 

Billion 2008$ 

Vented Electric Standard 0.21 -6.83 -6.40 -5.76 -3.09 -10.66 

Vented Electric Compact 120V 0.00 -0.02 -0.03 -0.03 -0.02 -0.05 

Vented Electric Compact 240V 0.00 -0.07 -0.11 -0.10 -0.07 -0.20 

Vented Gas -0.12 -1.85 -5.80 -5.62 -4.91 

Vent-less Electric Compact 240V 0.00 0.02 0.01 0.08 -0.10 

Vent-less Electric Combination Washer/Dryer 0.06 0.04 0.04 0.06 -0.05 

Table ES.3.37 Clothes Dryers: Cumulative Consumer Net Present Value, Discounted at 

7 Percent 

Product Class Candidate Standard Level 

1 2 3 4 5 6 

Billion 2008$ 

Vented Electric Standard -0.03 -4.26 -5.06 -4.83 -3.69 -10.60 

Vented Electric Compact 120V 0.00 -0.01 -0.02 -0.02 -0.02 -0.03 

Vented Electric Compact 240V 0.00 -0.04 -0.07 -0.06 -0.05 -0.14 

Vented Gas -0.09 -1.13 -3.50 -3.43 -3.13 

Vent-less Electric Compact 240V 0.00 0.01 0.00 0.02 -0.08 

Vent-less Electric Combination Washer/Dryer 0.03 0.00 0.01 0.01 -0.06 

Table ES.3.38 Room Air Conditioners: Cumulative Consumer Net Present Value, 

Discounted at 3 Percent 

Product Class Candidate Standard Level 

1 2 3 4 5 

Billion 2008$ 

Group 1 - based on Less than 

6,000 Btu/h, with Louvers 

1.54 2.52 3.09 3.47 3.83 

Group 2 - based on 8,000-

13,999 Btu/h, with Louvers 

1.43 2.37 2.60 -0.68 

Group 3 - based on 20,000 

Btu/h or more, with Louvers 

0.10 0.16 0.21 0.09 

Group 4 - based on 8,000-

13,999 Btu/h, with Louvers 

0.22 -0.78 -0.54 

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EERE-2007-BT-STD-0010 COMMENT 20.3
Table ES.3.39 Room Air Conditioners: Cumulative Consumer Net Present Value, 

Discounted at 7 Percent 

Product Class Candidate Standard Level 

1 2 3 4 5 

Billion 2008$ 

Group 1 - based on Less than 

6,000 Btu/h, with Louvers 

0.68 1.08 1.27 1.35 1.46 

Group 2 - based on 8,000-

13,999 Btu/h, with Louvers 

0.59 0.95 0.78 -1.37 

Group 3 - based on 20,000 

Btu/h or more, with Louvers 

0.04 0.06 0.06 -0.01 

Group 4 - based on 8,000-

13,999 Btu/h, with Louvers 

0.10 -0.38 -0.30 

ES.3.9 Preliminary Manufacturer Impact Analysis 

The preliminary MIA focuses on manufacturers of residential clothes dryers and room air 

conditioners. Potential impacts include financial effects, both quantitative and qualitative, that 

might result from new energy conservation standards and consequently lead to changes in 

manufacturing practices for residential clothes dryers and room air conditioners. DOE identified 

potential impacts through interviews with manufacturers and other interested parties. Chapter 12 

of the preliminary TSD includes details on the key issues DOE identified during the preliminary 

MIA. 

DOE identified the following key issues for residential clothes dryers: 

Cumulative regulatory burden; 

Impact on product mix; 

ENERGY STAR program; 

Economic impacts; 

Impact on profitability; 

Product conversion costs; and 

Product innovation. 

DOE identified the following key issues for room air conditioners: 

Cumulative regulatory burden; 

Impact on product mix / ENERGY STAR program; 

Industry consolidation; 

Impact on profitability; 

Product conversion costs; 

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EERE-2007-BT-STD-0010 COMMENT 20.3
Product innovation; and 

Impact on consumer subgroups. 

During the Pre-NOPR stage, DOE conducted the preliminary MIA by first identifying 

products, methods, and practices used in the residential clothes dryer and room air conditioner 

industries. Next, DOE determined how energy efficiency improvements affect cost, production, 

and various other manufacturing metrics. Finally, DOE interviewed manufacturers for feedback. 

DOE developed and distributed a questionnaire for use during the interviews. At the beginning 

of the interview process, DOE interviewed manufacturers and adjusted the analysis as 

appropriate, based on the feedback. In the interviews, DOE also examined any additional effects 

on competition, manufacturing capacity, direct employment, and the cumulative burden of other 

regulations affecting manufacturers, as well as several issues raised by individual manufacturers. 

ES.4 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT 

DOE is interested in receiving comments on all aspects of this preliminary analysis. DOE 

especially invites comments or data to improve DOE’s analysis, including data or information 

that will respond to the following questions or concerns that were raised in response to the 

framework document and in preparation of the preliminary TSD. 

ES.4.1 Design Options for Clothes Dryers and Room Air Conditioners 

DOE requests comment and data regarding additional design options or variants of the 

considered design options that can increase the range of considered efficiency improvements for 

both clothes dryers and room air conditioners, including design options that may not yet be found 

in the market. 

ES.4.2 Vent-less Clothes Dryers 

The current DOE clothes dryer test procedure does not contain provisions for testing 

vent-less clothes dryers. DOE invites interested parties to submit inputs on potential clothes 

dryer test procedure amendments to test vent-less clothes dryers, as well as data and information 

on the energy efficiency performance of vent-less clothes dryers. 

ES.4.3 Underwriters Laboratory Fire Safety Regulation 

Residential clothes dryer manufacturers must also comply with the Underwriters 

Laboratory (UL) fire containment regulation for clothes dryers. DOE seeks information from 

interested parties to further evaluate this issue in the NOPR analyses. 

ES.4.4 Extrapolation to Estimate Costs for Product Classes not Fully Analyzed 

DOE developed estimates of incremental costs for room air conditioner product classes 

not fully analyzed by extrapolation methods described in chapter 5. DOE invites comment on the 

proposed extrapolation approach. 

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EERE-2007-BT-STD-0010 COMMENT 20.3
ES.4.5 Modified Engineering Analysis Approach 

In the framework document, DOE proposed the use of an efficiency-level approach for 

the engineering analysis for room air conditioners. Use of this approach was complicated by the 

lack of aggregated industry data and by the phaseout of HCFC-22 refrigerant. As described in 

chapter 5, DOE adopted an approach relying more on a design-option analysis, using both energy 

modeling and manufacturing cost modeling to determine the impacts of efficiency improvements 

for the products. DOE invites comment on this modified approach for conducting the 

engineering analysis. 

ES.4.6 Establishing Appropriate Size Limits for Room Air Conditioners with Louvered 

Sides 

As described in chapter 5, DOE considered size increases for room air conditioners with 

louvered sides. DOE examined the range of sizes of available room air conditioners with 

baseline efficiencies and room air conditioners with increased efficiencies. The data show that 

even baseline efficiency products have a range of sizes. The DOE analysis generally considered 

two increases in size from a size at the low end of the range for each product class analyzed. 

Manufacturers have pointed out that consumer utility is negatively impacted by such size 

increases. However, a methodology for determining appropriate maximum sizes for different 

product classes and capacities has not been established. DOE seeks input on this topic, including, 

if possible, consumer surveys or similar data to guide establishing these maximum size limits. 

ES.4.7 Operating Hours for Room Air Conditioners 

For each considered room air conditioner capacity, DOE calculated the number of 

operating hours for each room air conditioner in the residential sample using the reported energy 

use for room air conditioning in the 2005 RECS along with estimates of the EER of the room air 

conditioner(s) in each sample home. DOE based the latter on the reported age of the unit and 

historical data on shipment-weighted average EER. DOE invites comment on its approach. 

ES.4.8 Number of Annual Cycles for Clothes Dryers 

For the LCC analysis, DOE estimated the number of clothes dryer cycles per year for 

each sample home using data given by RECS on the number of laundry loads (clothes washer 

cycles) washed per week and the frequency of clothes dryer use. DOE invites comment on its 

approach. 

ES.4.9 Consideration of Remaining Moisture Content of Clothes for Calculation of Clothes 

Dryer Energy Use 

To estimate the RMC of clothes washers in the future housing stock, DOE used a 

distribution of values for models listed in the Dec. 22, 2008 CEC directory. The RMC values 

range from 30 percent to 61 percent, with an average of 46 percent. DOE invites comment on 

this approach. 

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EERE-2007-BT-STD-0010 COMMENT 20.3
ES.4.10 Load Sizes for Clothes Dryers 

The DOE test procedure uses weights of 7 lb for standard-size units and 3 lb for compactsize units. For its LCC analysis, DOE developed a distribution of weights by matching the listed 

tub sizes for models in the CEC directory with the correlations between tub size and average 

pounds specified in the test procedure. DOE invites comment on this approach. 

ES.4.11 Repair and Maintenance Costs 

DOE did not find any evidence that repair and maintenance costs change as product 

efficiency increases for room air conditioners and clothes dryers. DOE requests any specific 

information showing the extent to which repair and maintenance costs change as product 

efficiency increases beyond the baseline levels used in DOE’s analysis. 

ES.4.12 Lifetime of Clothes Dryers and Room Air Conditioners 

 DOE conducted an analysis of actual lifetime in the field using a combination of 

shipments data, the stock of the considered appliances, and responses in RECS on the age of the 

appliances in the homes. The data allowed DOE to estimate a survival function, which provides 

an average and a median appliance lifetime. This analysis yielded an average lifetime for clothes 

dryers of approximately 16 years and for room air conditioners of approximately 10.5 years. 

DOE invites comment on its approach for estimating the lifetime of clothes dryers and room air 

conditioners. 

ES.4.13 Base Case Efficiency Distributions 

To estimate the share of consumers that would be affected by a standard at a particular 

efficiency level, DOE’s LCC and PBP analyses considered the projected distribution of product 

efficiencies that consumers would purchase in the base case (i.e., the case without amended 

energy efficiency standards). DOE found that the data on recent trends in shipment-weighted 

average efficiency of room air conditioners and shares of ENERGY STAR products are 

inconclusive. Therefore, DOE assumed that the market shares of the efficiency levels in 2014 

will be roughly the same as the shares in 2007. DOE also believes that there is little evidence to 

expect much change in the distribution of energy efficiencies of clothes dryers in the base case. 

DOE invites comment on the approach used to forecast base-case market shares of the 

considered efficiency levels. 

ES.4.14 Manufacturer Subgroups 

DOE research suggests that there are no residential clothes dryer manufacturers in the 

United States that are designated as small businesses by the U.S. Small Business Administration, 

and that there is at least one room air conditioner manufacturer that is a small business. DOE 

invites comment on its estimates of the number of small businesses who may be impacted by the 

rule and what those impacts might be. 

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EERE-2007-BT-STD-0010 COMMENT 20.3
ES.4.15 Valuing Air-Borne Emission Reductions 

DOE will conduct an environmental assessment as part of the next phase of the standards 

rulemaking, the NOPR. The primary environmental effects of energy conservation standards for 

the considered products are reduced power plant emissions resulting from reduced consumption 

of electricity. DOE will assess these environmental effects by using NEMS-BT along with key 

inputs from the NIA. NEMS-BT considers emissions of carbon dioxide (CO2), sulfur dioxide 

(SO2), nitrogen oxides (NOX), and mercury (Hg). DOE also plans on monetizing the emission 

reductions due to standards consistent with methods used in recent DOE standards rulemakings 

pertaining to other consumer products and commercial equipment. For example, in the case of 

CO2, DOE has used the most recent interagency estimates of the potential global benefits 

resulting from reduced CO2 emissions, which range from $5 to $56 per metric ton of CO2 (the 

unit values represent emissions that are valued in 2008$ for emissions that occur in 2007). . 

DOE invites comments on the approaches for monetizing the emissions reductions due to energy 

conservation standards. 

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