APPENDIX 13B. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDES

TABLE OF CONTENTS

13B.1 CONVENTIONAL COOKING PRODUCTS.......................................................13B-1 13B.2 MICROWAVE OVENS (ENERGY FACTORY STANDARDS)........................13B-9 13B.3 MICROWAVE OVENS (STANDBY POWER STANDARDS)........................13B-13

13B.4 COMMERICAL CLOTHES WASHERS ...........................................................13B-17

13B-iAPPENDIX 13B. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDES

13B.1 CONVENTIONAL COOKING PRODUCTS



## Cooking Products Rulemaking Manufacturer Impact Analysis Interview Guide:

Electric and Gas Cooktops, Ovens, and Ranges

13B-11 Section 6313(a)(6)(A) of 42 U.S.C. requires the U.S. Department of Energy (DOE) to set forth energy conservation standards that are technologically feasible, economically justified, and that would result in significant additional energy conservation. This interview guide allows the opportunity for manufacturers to provide valuable information that will assist DOE in its decisions for the cooking products rulemaking.

For the Advance Notice of Proposed Rulemaking (ANOPR) for cooking products, DOE based its analyses on the 1996 Technical Support Document for Residential Cooking Products (1996 TSD). The costs found in the 1996 TSD were converted to 2007 dollars using the producer price index (PPI). The information found in the 1996 TSD was also supplemented with currently researched data and information provided by AHAM.

For the Notice of Proposed Rulemaking (NOPR) analyses, Navigant Consulting Inc. (NCI) developed a “strawman” model of the cooking products industry financial performance called the Government Regulatory Impact Model (GRIM). The GRIM uses publicly available data ( e.g. , U.S. Securities and Exchange Commission (SEC) 10-K Forms) and 1996 TSD figures that were adjusted by shipment volumes and the PPI. These interviews will serve to review and supplement the strawman GRIM inputs and provide an opportunity to discuss the possible impacts of different efficiency levels on such issues as manufacturing costs, equipment prices, product sales, direct employment, capital assets, and industry competitiveness.

KEY ISSUES

The Department of Energy (DOE) is currently reviewing a set of efficiency levels for ElectricCoil Cooktops, Electric Smooth Cooktops, Gas Cooktops, Electric Standard Oven, Electric SelfClean Oven, Gas Standard Oven, Gas Self-Clean Oven, and Electric and Gas Ranges rulemaking analyses. The efficiency levels are presented below as they apply to the various product classes. In responding to this questionnaire, please refer to the energy factor (EF) values described below.

13B-2Table 1.1 Efficiency Levels

Product

Class Baseline Efficiency Level 1, 1a* Efficiency

Level 2 Efficiency

Level 3 Efficiency

Level 4 Efficiency

Level 5 Efficiency

Level 6

Electric

Coil Cooktops 0.737 0.769

- - - - -

Electric

Smooth Cooktops 0.742 0.753

- - - - -

Gas Cooktops 0.156 0.399 0.420

- - - -

Electric

Standard

Oven 0.1066 0.1113 0.1163 0.1181 0.1206 0.1209

-

Electric

Self-Clean

Oven 0.1099 0.1102 0.1123

- - - -

Gas

Standard

Oven 0.0298 0.0536

0.0583* 0.0566 0.0572 0.0593 0.0596 0.060

Gas SelfClean Oven 0.0540 0.0625 0.0627 0.0632

- - -

* Baseline + Electronic Spark Ignition: Cooking efficiency decrease = 0.09 (absolute percentage points), added electricity consumption = 0.0 Wh. Efficiency levels 1 and 1a correspond to designs that are utilized for the same purpose--eliminate the need for a standing pilot--but the technologies for each design are different. Efficiency level 1 is a hot surface ignition device while standard level 1a is a spark ignition device

1.1 What are the key issues for your company regarding cooking products related to energy conservation standards and this rulemaking?

1.2 For the issues identified, how significant are they for each efficiency level?

1.3 How can we most effectively incorporate these issues in the Manufacturer Impact Analysis (MIA)?

2 FINANCIAL PARAMETERS

As stated above, NCI has developed a “strawman” model of the cooking products industry financial performance called the GRIM, using publicly available data ( e.g. , SEC 10-K Forms) on cooking products manufacturers. This section attempts to understand how your company’s financial situation differs from our industry aggregate picture.

2.1 Please compare your financial parameters to the GRIM parameters tabulated below.

13B-3Table 2.1 Financial Parameters for Cooking Products Manufacturers

GRIM Input Definition Cooking

Products GRIM

Estimated

Value Your Actual (if significantly

different from our estimate)

Income Tax Rate Corporate (average) effective income tax paid (percentage of

earnings before interest and taxes, EBIT) 33.1%

Discount Rate Weighted average cost of capital (inflation-adjusted weighted average of corporate cost of debt and return on equity) 6.6%

Working Capital Current assets less current liabilities (percentage of revenues) 3.3%

SG&A Selling, general, and administrative expenses (percentage of revenues) 13.0%

R&D Research and development expenses (percentage of revenues) 2.3%

Depreciation Amortization of fixed assets (percentage of revenues) 3.4%

Capital Expenditures Outlay of cash to acquire or improve capital assets (percentage of revenues, not including acquisition or sale of business units) 3.5%

3 PRODUCTION COST BREAKDWON

Using information from the 1996 TSD, DOE estimated the industry average percentage breakdown of each manufacturing cost in the full production cost.

3.1 Please compare your full production cost percentages to the GRIM full production cost percentages tabulated below. Are the different percentages of each cost representative of your company or the cooking products industry? Please explain any differences.

Table 3.1 Breakdown by Percentage of Full Production Costs for Baseline Cooking

Products
Components of Full Production Costs Estimated % of Full

Production Cost Your Actual (if significantly different from our estimate)

Materials 66.19 %

Labor 12.98 %

Overhead 16.55 %

Depreciation 4.28 %

13B-44 SHIPMENT PROJECTION AND MARKET SHARE

4.1 Would you expect your market share to change once standards become effective? Does your outlook change with higher efficiency levels?

4.2 How would you expect shipments to change for the industry as a whole as a function of standards and why?

5 CONVERSION COSTS

An increase in energy conservation standards may cause your company to incur one-time capital and product conversion costs a . DOE calls these conversion costs because they are the costs of changing your business to comply with new energy conservation standards.

5.1 What level of conversion costs do you anticipate incurring under the different efficiency levels? Refer to the tables below to provide your company’s estimates for the industry. Please compare your conversion costs with the GRIM conversion costs for the industry tabulated below. Please provide additional qualitative information to help us understand the nature of your investments.

Table 5.1 Electric Coil Cooktops Conversion Costs ($ Millions)

Standard

Level GRIM Estimated Total Industry Your Estimate (if significantly different from our estimate Total Industry

Conversion

Capital Expenditures Product

Conversion

Expenses Conversion Capital Expenditures Product

Conversion

Expenses Stranded

Assets

Baseline (0.737) $0 $0

Level 1 (0.769) $0 $13

Table 5.2 Electric Smooth Cooktops Conversion Costs ($ Millions)

Standard

Level GRIM Estimated Total Industry Your Estimate (if significantly different from our estimate Total Industry

Conversion

Capital Expenditures Product

Conversion

Expenses Conversion Capital Expenditures Product

Conversion

Expenses Stranded

Assets

Baseline (0.742) $0 $0

Level 1 (0.753) $104.4 $13

a Capital and product conversion costs include capital conversion expenditures, product conversion expenditures and stranded assets. Capital Conversion Expenditures – One time investments in plant, property, and equipment (PPE) necessitated by an energy conservation standard. These may be completely incremental to existing PPE or they could involve replacement of existing PPE. Product Conversion Expenditures – One-time expenses in research, product development, testing, and marketing necessitated by an appliance energy conservation standard. Stranded Assets – Investments such as equipment or tooling that become obsolete as a result of new regulation. 13B-5Table 5.3 Gas Cooktops Conversion Costs ($ Millions)

Standard

Level GRIM Estimated Total Industry Your Estimate (if significantly different from our estimate Total Industry

Conversion

Capital Expenditures Product

Conversion

Expenses Conversion Capital Expenditures Product

Conversion

Expenses Stranded

Assets

Baseline (0.156) $0 $0

Level 1 (0.399) $4.4 $13

Level 2 (0.420) $4.4 $26

Table 5.4 Electric Standard Oven Conversion Costs ($ Millions)

Standard

Level GRIM Estimated Total Industry Your Estimate (if significantly different from our estimate Total Industry

Conversion

Capital Expenditures Product

Conversion

Expenses Conversion Capital Expenditures Product

Conversion

Expenses Stranded

Assets

Baseline (0.1066) $0 $0

Level 1 (0.1113) $0.9 $13

Level 2 (0.1163) $1.5 $26

Level 3 (0.1181) $103.3 $39

Level 4 (0.1206) $167.7 $52

Level 5 (0.1209) $179.8 $65

Table 5.5 Electric Self-Clean Oven Conversion Costs ($ Millions)

Standard

Level GRIM Estimated Total Industry Your Estimate (if significantly different from our estimate Total Industry

Conversion

Capital Expenditures Product

Conversion

Expenses Conversion Capital Expenditures Product

Conversion

Expenses Stranded

Assets

Baseline (0.1099) $0 $0

Level 1 (0.1102) $28.8 $13

Level 2 (0.1123) $109.6 $26

13B-6Table 5.6 Gas Standard Oven Conversion Costs ($ Millions)

Standard

Level GRIM Estimated Total Industry Your Estimate (if significantly different from our estimate Total Industry

Conversion

Capital Expenditures Product

Conversion

Expenses Conversion Capital Expenditures Product

Conversion

Expenses Stranded

Assets

Baseline (0.0298) $0 $0

Level 1,1a

(0.0536) (0.0583) $2.9 $3.6 $13

Level 2 (0.0566) $3.9 $26

Level 3 (0.0572) $8.4 $39

Level 4 (0.0593) $57.3 $52

Level 5 (0.0596) $58.4 $65

Level 6 (0.060) $74.5 $78

Table 5.7 Gas Self-Clean Oven Conversion Costs ($ Millions)

Standard

Level GRIM Estimated Total Industry Your Estimate (if significantly different from our estimate Total Industry

Conversion

Capital Expenditures Product

Conversion

Expenses Conversion Capital Expenditures Product

Conversion

Expenses Stranded

Assets

Baseline (0.540) $0 $0

Level 1 (0.0625) $6.8 $13

Level 2 (0.0627) $15.6 $26

Level 3 (0.0632) $17.4 $39

6 PROFITABILITY AND MANUFACTURING CAPACITY

One of the primary objectives of the MIA is to assess the impact of efficiency levels on industry profitability and changes in manufacturing capacity.

6.1 Do profit levels vary by efficiency level? Please explain why or why not?

6.2 Do you expect any changes in your estimated profitability following the new energy conservation standard? If so, please explain why.

6.3 How would the imposition of new energy conservation standards affect your manufacturing capacity at your production facilities? Would any facilities be closed, downsized, added, or upgraded?

13B-77 CUMULATIVE REGULATORY BURDEN

Cumulative regulatory burden refers to the burden that industry faces from overlapping effects of new or revised DOE standards and/or other regulatory actions affecting the same products or industry

7.1 Are there other recent or impending regulations that cooking products manufacturers face (from DOE or otherwise)? What level of investment are you expecting to incur as a result of these regulations?

7.2 Under what circumstances would you be able to coordinate any expenditures related to other regulations thereby lessening the cumulative burden?

8 DIRECT EMPLOYMENT IMPACT ASSESSMENT

The impact of new energy conservation standards on employment is an important consideration in the rulemaking process. This section of the interview guide seeks to explore current trends in cooking products production employment and solicit manufacturer views on how domestic employment patterns might be affected by new energy conservation standards.

8.1 Would your domestic employment levels change under new energy conservation standards? If so, please explain how they would change.

8.2 Would the workforce skills necessary under new energy conservation standards require extensive retraining or replacement of employees?

9 CONSOLIDATION

New energy conservation standards can alter the competitive dynamics of the market. This can include prompting companies to enter or exit the market, or to merge. DOE and the Justice Department are both interested in any potential reduction in competition that would result from a new energy conservation standard.

9.1 In the absence of new standards, do you expect any industry consolidation? Please describe your expectations.

9.2 How would new standards affect your ability to compete?

9.3 Could new standards disproportionately advance or harm the competitive positions of some firms ( e.g. , small businesses)?

13B-813B.2 MICROWAVE OVENS (ENERGY FACTORY STANDARDS)



## Cooking Products Rulemaking Manufacturer Impact Analysis Interview Guide: Microwave Ovens

March 3, 2008

KEY ISSUES

13B-9 1The Department of Energy (DOE) is currently reviewing a set of efficiency levels for Microwave Ovens (MWO). The efficiency levels are presented below as they apply to the single product class. In responding to this questionnaire, please refer to the energy factor (EF) values described

below.

Table 1.1 Efficiency Levels (EF %)

Product

Class Baseline Efficiency

Level 1 Efficiency

Level 2 Efficiency

Level 3 Efficiency

Level 4

Microwave

Ovens 55.70 58.60 58.80 59.70 60.20

1.1 What are the key issues for your company regarding MWO related to energy conservation standards and this rulemaking?

1.2 For the issues identified, how significant are they for each efficiency level?

1.3 How can we most effectively incorporate these issues in the Manufacturer Impact Analysis (MIA)?

2 SHIPMENT PROJECTION AND MARKET SHARE

2.1 Would you expect your market share to change once standards become effective? Does your outlook change with higher efficiency levels?

2.2 How would you expect shipments to change for the industry as a whole as a function of standards and why?

3 CONVERSION COSTS

An increase in energy conservation standards may cause your company to incur one-time capital and product conversion costs . DOE calls these conversion costs because they are the costs of changing your business to comply with new energy conservation standards.

3.1 What level of conversion costs do you anticipate incurring under the different efficiency levels? Refer to the tables below to provide your company’s estimates. Please provide additional qualitative information to help us understand the nature of your investments.

Table 3.1 MWO Conversion Costs

Standard Level Conversion Capital Expenditures Product Conversion Expenses Stranded Assets

Baseline (55.70)

Level 1 (58.60)

Level 2 (58.80)

Level 3 (59.70)

Level 4 (60.20)

4 PROFITABILITY AND MANUFACTURING CAPACITY

13B-10One of the primary objectives of the MIA is to assess the impact of efficiency levels on industry profitability and changes in manufacturing capacity.

4.1 Does your company have any MWO manufacturing facilities located in the United States? How would you expect shipments to change for the industry as a whole as a function of standards and why?

4.2 Do you expect any changes in your estimated profitability following the new energy conservation standard? If so, please explain why.

4.3 How would the imposition of new energy conservation standards affect your manufacturing capacity at your production facilities? Would any facilities be closed, downsized, added, or upgraded?

5 CUMULATIVE REGULATORY BURDEN

Cumulative regulatory burden refers to the burden that industry faces from overlapping effects of new or revised DOE standards and/or other regulatory actions affecting the same products or industry.

5.1 Are there other recent or impending regulations that MWO manufacturers face (from DOE or otherwise)? What level of investment are you expecting to incur as a result of these regulations?

5.2 Under what circumstances would you be able to coordinate any expenditures related to other regulations thereby lessening the cumulative burden?

6 DIRECT EMPLOYMENT IMPACT ASSESSMENT

The impact of new energy conservation standards on employment is an important consideration in the rulemaking process. This section of the interview guide seeks to explore current trends in MWO production employment and solicit manufacturer views on how domestic employment patterns might be affected by new energy conservation standards.

6.1 Would your domestic employment levels change under new energy conservation standards? If so, please explain how they would change.

6.2 Would the workforce skills necessary under new energy conservation standards require extensive retraining or replacement of employees?

7 CONSOLIDATION

New energy conservation standards can alter the competitive dynamics of the market. This can include prompting companies to enter or exit the market, or to merge. DOE and the Justice Department are both interested in any potential reduction in competition that would result from a new energy conservation standard.

7.1 In the absence of new standards, do you expect any industry consolidation? Please describe your expectations.

13B-117.2 How would new standards affect your ability to compete?

7.3 Could new standards disproportionately advance or harm the competitive positions of some firms ( e.g. , small businesses)?

13B-1213B.3 MICROWAVE OVENS (STANDBY POWER STANDARDS)



## Cooking Products Rulemaking Standby Power Interview Guide: Microwave Ovens

INTRODUCTION:

The United States Department of Energy (DOE) is currently reviewing energy efficiency standards for cooking products. Of high interest are the standby power requirements of microwave ovens. As a result, the Department invites manufacturers to participate in this questionnaire to help the Department better understand the issues regarding standby power, as well as any potential impacts on consumers that standby power legislation could have.

The Department tested 32 microwave ovens for sale in the US within the past year. The sample included a wide range of input powers and cavity sizes to investigate cooking efficiency and standby power requirements. DOE subsequently published its findings at the December 17, 2007 Advance Notice of Proposed Rulemaking (ANOPR) meeting in Washington DC. Due to comments submitted to DOE during and after this meeting, the Department would like to solicit

additional feedback from manufacturers.

During testing, DOE noted that microwave ovens with cooking sensors tend to consume more standby power than those without cooking sensors. DOE also noted how display size and technology and the associated controller could influence standby power requirements. At the end of the testing cycle, every microwave oven was completely disassembled. DOE noted a wide variety of display types and cooking sensors, even if most other aspects of microwave construction have been largely standardized. This questionnaire will thus focus on the controllers, displays, and power supplies.

Cooking Sensors

DOE would like to understand why manufacturers incorporate cooking sensors into their microwave ovens, and factors influencing the choice of a specific sensor type from among the range of available technologies.

1.1 On a unit shipment-basis, what percentage of microwave ovens that you sell into the US market feature cooking sensors?

1.2 Do you have any data on the percentage of consumers that use the sensor function? Is there any data available quantifying the energy savings associated with the use of a cooking sensor?

13B-131.3 What sensor technologies do you use for microwave ovens sold in the US? What are the standby requirements of these sensors? Are there sensor technologies available that require less power in standby that can be applied in MWOs?

Displays

DOE also noted a wide range of standby power consumption based on the display technology. For example, displays based on vacuum-fluorescent displays tended to consume more power than comparable-sized displays based on light emitting diodes. DOE noted three display types in its market sample, consisting of light-emitting diodes (LEDs), liquid crystal displays (with or without LED backlighting), and vacuum-fluorescent displays.

1.4 What is the consumer utility associated with each type of display? Do consumers demand displays with specific technologies?

1.5 What are the power requirements for each type of display assuming a comparable size and general capability (complexity of the characters that a display can show)? What are the relative costs associated with each type of display?

Controllers and Power Supplies

While cooking sensors and displays consumed the most standby power, DOE also noted that controllers and the control boards also consume standby power. The Department recognizes that there may be tradeoffs between standby power consumption and the ability of control systems to tackle complex tasks.

1.6 What consumer utility is associated with microwave oven controllers? Could controller attributes or functionalities be impacted by reducing microwave oven standby requirements? If so, how?

1.7 Are lower-power versions of these controllers available? What control board design options are available for reducing standby power? At what cost?

1.8 What is the range of efficiencies for controller power supplies? Can higher efficiency power supplies be implemented? At what cost?

Potential Standby Power Standard Levels

DOE surveyed foreign regulatory and non-regulatory programs, identifying Korea’s e-standby program, Australia’s standby program, and Japan’s Top Runner Program as pursuing reductions in standby power consumption through support for the International Energy Agency’s One-Watt

13B-14program to lower standby power consumption below 1 W for MWOs b , among others. DOE is also aware of zero-Watt-standby microwave ovens in Japan that feature cooking sensors.

1.9 What design changes from current US products would be required if the following standby

standard level were established?

• 4 Watts/h

• 2 Watts/h

• 1.5 Watts/h

• 1 Watt/h

• 0 Watt/h

• What would be the manufacturing cost impacts of these changes?

• Are there any impacts on consumer utility as standby power levels are lowered? If so, what are they, and at what standby power levels do they occur?

Standby Power Standards Manufacturer Impacts

DOE understands that by establishing standby power standards, manufacturer could potentially incur one-time capital and product conversion costs c . DOE calls these conversion costs because they are the costs of changing your business to comply with new standby power standards. In addition, DOE would like to understand possible effects of new standby power standards on industry shipments, profitability, and manufacturing capacity.

1.10 What level of conversion costs do you anticipate incurring under different standby power standard level? Refer to the tables below to provide your company’s estimates.

Please provide additional qualitative information to help us understand the nature of your investments.

b IEA Energy Information Centre, Standby Power Use and the IEA “1-Watt Plan) http://www.iea.org/textbase/subjectqueries/standby.asp

c Capital and product conversion costs include capital conversion expenditures, product conversion expenditures and stranded assets. Capital Conversion Expenditures – One time investments in plant, property, and equipment (PPE) necessitated by an energy conservation standard. These may be completely incremental to existing PPE or they could involve replacement of existing PPE. Product Conversion Expenditures – One-time expenses in research, product development, testing, and marketing necessitated by an appliance energy conservation standard. Stranded Assets – Investments such as equipment or tooling that become obsolete as a result of new regulation. 13B-15Table 1.1 MWO Conversion Costs

Standard Level Conversion Capital Expenditures Product Conversion Expenses Stranded Assets

4 Watts/h

2 Watts/h

1.5 Watts/h

1 Watts/h

0 Watts/h

1.11 How would you expect shipments to change for the industry as a whole as a function of standby power standards and why?

1.12 Do you expect any changes in your estimated profitability following new standby power standard? If so, please explain why.

1.13 How would the imposition of new standby power standards affect your manufacturing capacity at your production facilities? Would any facilities be closed, downsized, added, or upgraded?

Standby Test Procedure

As part of the analysis, DOE reviewed the existing DOE cooking efficiency test procedure and possible standby test procedures that could be incorporated. For standby testing, DOE is considering adopting by reference the IEC 62301 standby test procedure d

.

1.14 Do you currently conduct microwave oven standby power testing? If so, which test procedure do you use?

1.15 How do you feel about the incorporation of IEC 62301 to measure standby with the provision that a 12-hour (or possibly 24-hour) test be performed with the clock set to a specific starting time?

d See http://iec.org for further details 13B-1613B.4 COMMERICAL CLOTHES WASHERS

HOME APPLIANCE RULEMAKING

ANOPR INTERVIEW GUIDE

-COMMERCIAL CLOTHES WASHERSDESIGN FOR ENERGY IMPROVEMENT INFORMATION REQUEST

The Department would like to confirm information on the incremental costs of increasing product efficiency by understanding the design options involved in the efficiency improvement.

Commercial Clothes Washers

1. Which design features impacting energy use are generally incorporated into a “baseline”

commercial clothes washer?

2. What design changes are generally required to convert a typical baseline commercial clothes washer (1.26 MEF, 9.5 WF) to the CEE Tier 1 level (1.42 MEF, 9.5 WF)?

1. Are these design changes comparable for horizontal- and vertical-axis washers?

2. What are the costs of the individual design options selected?

3. Are the aggregated industry costs representative of your firm’s costs?

3. What additional design changes are required to achieve the 2007 residential clothes washer ENERGY STAR level (1.72 MEF, 8.0 WF)?

• What are the costs of the individual design options selected?

• Are the aggregated industry costs representative of your firm’s costs?

4. What additional design changes are required to achieve the highest level in the CEC database (2.2 MEF, 5.5 WF)?

• What are the costs of the individual design options selected?

• Are the aggregated industry costs representative of your firm’s costs?

5. What are the fundamental differences between required design changes that make the cost increment much higher for some product class/sizes than others?

6. Would you help the Department understand and estimate the conversion capital investments that would be necessary at each candidate standard level? What is the nature of the capital investments?

7. Are installation costs a function of efficiency? Maintenance costs? Repair costs? If yes, would you please characterize this relationship by providing incremental installation, maintenance, and/or repair cost data?

13B-178. Is there a relationship between MEF and WF? If yes, please characterize this relationship.

PRELIMINARY MANUFACTURER IMPACT ANALYSIS TOPICS

2 Issues

2.1 What are the key issues for your company regarding this product rulemaking?

2.2 Are there any patent, technology, or other issues that you are aware of that would prevent your company or competitors from implementing higher-efficiency designs or control algorithms?

3 Shipment Projections

3.1 What is your company’s approximate market share in each of the product classes? (Note: there is only one product class for commercial clothes washers. Please provide market share information for horizontal- and vertical-axis washers.)

3.2 Would you expect your market share to change once standards become effective? Does your outlook change with higher efficiency levels?

3.3 How would you expect shipments to change for the industry as a whole as a function of standards and why?

3.4 Looking at price/cost effects only, how would you expect shipments to change for a 25%, 50%, 100% or 200% manufacturer price/cost increase?

4 Conversion Costs

4.1 What level of capital expenditure and product conversion costs would you anticipate to make at higher standard levels? Please describe what they are and provide your best estimate of their respective magnitudes.

4.2 How would the imposition of new energy conservation standards affect capacity utilization and manufacturing assets at your domestic production facilities? Would a new standard result in stranded capital assets? Would any facilities be closed or downsized? Added or upgraded?

4.3 How might a new standard impact product innovation?

5 Product Mix and Profitability

5.1 How would your company’s product mix and marketing strategy change with changes in the efficiency standard?

5.2 Would the current percentage of shipments at the (residential) ENERGY STAR level be

the same under a new standard?

5.3 What distribution channels are used from the manufacturer to the retail outlet? What is the share of product going through each distribution channel?

5.4 Generally how would new product standards impact your customer mix, distribution channels, and corresponding profit margins?

13B-185.5 How might a new standard impact the ENERGY STAR program and consequently your

firm?

5.6 What is the approximate percentage of shipments ( i.e. , market share) for each product, or more specifically, for each product class? (Note: there is only one product class for commercial clothes washers. Please provide product mix information for horizontal- and vertical-axis washers.)

6 Market Shares and Industry Consolidation

6.1 In the absence of new standards, do you expect any industry consolidation?

6.2 How would new standards affect your ability to compete?

6.3 Could new standards disproportionately advance or harm the competitive positions of

some firms?

6.4 Are there concerns over intellectual property?

6.5 Could new standards result in disproportionate economic or performance penalties for particular consumer/user subgroups?

6.6 Beyond price and energy efficiency, could new standards result in products that will be more or less desirable to consumers due to changes in product functionality, utility, or

other features?

7 Cumulative Regulatory Burden

7.1 Are there recent or impending regulations on your specific product or other products that impose a cumulative burden on the industry?

7.2 If so, what is the total expected impact of those other regulations?

13B-19