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-i
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

APPENDIX 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-1
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

1 

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 Electric 

Coil 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-2
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 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-3
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 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-4
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

4 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 costsa

. 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-5 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 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-6
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 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-7
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

7 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-8
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

13B.2 MICROWAVE OVENS (ENERGY FACTORY STANDARDS)
 

Cooking Products Rulemaking
 

Manufacturer Impact Analysis Interview Guide: Microwave Ovens
 

March 3, 2008
 

KEY ISSUES 

13B-9
 

1 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The 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-10 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

One 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-11
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

7.2	 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-12
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

13B.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-13
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

1.3	 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-14
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

program to lower standby power consumption below 1 W for MWOsb, 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 costsc

. 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-15
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 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 procedured

. 

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-16
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

13B.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-17
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

8.	 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-18
 

EE-2006-STD-0127 COMMENT 41.2
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

5.5	 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
 

EE-2006-STD-0127 COMMENT 41.2