ANALYTICAL RESULTS IN SUPPORT OF STAKEHOLDER NEGOTIATIONS ON 

AMENDED ENERGY CONSERVATION STANDARDS FOR 

RESIDENTIAL CLOTHES WASHERS, 

RESIDENTIAL REFRIGERATOR-FREEZERS AND FREEZERS,
 

AND ROOM AIR CONDITIONERS 

Update to April 15, 2010 Results 

May 4, 2010 

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

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

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

update to initial results provided on April 15, 2010. The results provided here, as well as those 

provided earlier on April 15th, are based on inputs (e.g., manufacturer selling prices as a function 

of efficiency) and analytical tools which are still under review. Therefore, the following 

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

documents. 

CLOTHES WASHERS 

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

requested for the following efficiency levels. 

Table 1. Clothes Washer Efficiency Levels: Stakeholder Requested 

Level Modified Energy Factor 

(MEF) 

Water Factor 

(WF) 

Older Energy Star 1.42 9.0 

Old Energy Star 1.72 8.0 

Energy Star®

/ CEE Tier 1 1.80 7.5 

CEE Tier 2 2.00 6.0 

CEE Tier 3 2.20 4.5 

New higher tier 2.40 4.0 

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

from preemption would require a maximum 6.0 water factor. 

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

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

power limits are listed in the table below. 

1 

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

Requested Levels Top-Loading Washers Front-Loading Washers 

MEF WF MEF WF Standby 

Power MEF WF Standby Power 

Baseline 1.26 9.50 0.00 1.72 8.00 2.30 

1.42 9.0 1.40 9.50 0.00 - - -

1.72 8.0 1.72 8.00 0.00 1.72 8.00 1.70 

1.72 8.00 0.08 

1.80 7.5 

1.80 7.50 2.30 

1.80 7.50 1.70 1.80 7.50 0.08

1.80 7.50 0.08 

2.00 6.0 2.00 6.00 0.08 2.00 6.00 0.08 

2.20 4.5 2.26 4.48 0.08 2.20 4.50 0.08 

2.40 4.0 - - - 2.40 4.20 0.08 

- - - - - 2.60 3.80 0.08 

- - - - - 2.89 3.36 0.08 

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

analyzed for DOE. 

LCC and PBP Results 

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

clothes washers. 

Top-loading results in the initial ‘April 15’ version were generated for four different scenarios. 

The scenarios differed based on the source of the manufacturing costs (AHAM or DOE) and 

assumptions regarding the base-case efficiency distribution. The base-case efficiency distribution 

represents the distribution of products by efficiency in the absence of new standards in the year 

2015 (the year in which standards are assumed to be effective). After consultation with AHAM, 

the ‘DOE’ manufacturing costs are currently best believed to represent the cost-efficiency 

relationship for top-loading washers. Therefore, as listed below, only the ‘DOE’ cost scenarios 

(C and D) were retained and analyzed. 

Top-Loading Scenario C: 

Manufacturer Costs: DOE. 

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

Top-Loading Scenario D: 

Manufacturer Costs: DOE. 

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

In addition to retaining only the ‘DOE’ cost scenarios, forecasted water and wastewater prices 

were revised to reflect the historical trend observed from 1975 to 2008. The ‘April 15’ version 

had used higher forecasted prices based on the relatively steeper price gain observed since 2004.
 

2 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

Table 3. Front-Loading Washers: LCC and PBP Results 

Effcy 

Level 

2015 

Base 

Case 

Effcy 

Distr 

MEF WF Standby 

Power 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Households that Experience 

Median Average cu.ft./k 

Wh/cyc 

gal / 

cu.ft watt Net Cost No 

Impact 

Net 

Benefit 

0 0.0% 1.72 8.00 2.30 

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

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

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

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

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

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

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

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

Table 4C. Top-Loading Washers: LCC and PBP Results, Scenario C 

Effcy 

Level 

2015 

Base 

Case 

Effcy 

Distr 

MEF WF Standby 

Power 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Households that Experience 

Median Average cu.ft./k 

Wh/cyc 

gal / 

cu.ft watt Net Cost No 

Impact 

Net 

Benefit 

0 43.60% 1.26 9.50 0.00 

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

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

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

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

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

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

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

Table 4D. Top-Loading Washers: LCC and PBP Results, Scenario D 

Effcy 

Level 

2015 

Base 

Case 

Effcy 

Distr 

MEF WF Standby 

Power 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Households that Experience 

Median Average cu.ft./k 

Wh/cyc 

gal / 

cu.ft watt Net Cost No 

Impact 

Net 

Benefit 

0 0.00% 1.26 9.50 0.00 

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

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

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

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

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

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

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

3 

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

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

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

As was done for the ‘April 15’ version of the results, the NIA was conducted using a cross-elasticity 

of demand to determine the change in market share of top- and front-loaders based on changes in the 

incremental price increase for each product class due to increased standards. For example, if the 

incremental price increase due to standards is larger for top-loaders than front-loaders, then frontloading washers are forecasted to gain market share. Shifts in market share between top- and frontloaders explains the negative NES and NWS for front-loaders, i.e., increased market share and 

shipments of front-loaders forecasted under the standards case results in increased front-loader 

national energy consumption relative to the front-loader base-case. Of course, the increase in frontloader shipments has a corresponding decrease in top-loader shipments, and the decreased shipments 

of top-loaders forecasted under the standards case results in an even further decrease in top-loader 

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

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

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

front-loader efficiency levels and standby power limits are presented in Table 5. 

Table 5. Front- and Top-Loaders Efficiency Levels for MEF and WF pairs 

Efficiency Pairing Top-Loader Front-Loader 

MEF WF 

Efficiency 

Level 

Standby Power 

watt 

Efficiency 

Level 

Standby Power 

watt 

1.40 9.5 1 0.00 0 1.70 

1.72 8.0 2 0.00 2 0.08 

1.80 7.5 5 2.30 3 0.08 

2.00 6.0 6 0.08 4 0.08 

2.20 4.5 6 0.08 5 0.08 

2.40 4.2 7** 0.08 6 0.08 

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

4 

EERE-2008-BT-STD-0019 COMMENT 34
Table 6C. NIA Results, Scenario C 

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

FL TL ALL FL TL ALL FL TL ALL 

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

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

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

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

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

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

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

FL TL ALL FL TL ALL FL TL ALL 

NES (quad) -0.77 2.07 1.30 -0.67 2.04 1.37 -0.81 2.59 1.78 

NWS (trillion gal.) -1.11 4.64 3.52 -0.60 4.58 3.98 -0.88 6.51 5.63 

NPV @ 7% (bill $) -17.73 24.05 6.32 -15.97 23.58 7.61 -22.81 32.03 9.22 

NPV @ 3% (bill $) -37.07 57.68 20.61 -32.83 56.61 23.78 -46.55 76.85 30.30 

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

Mkt Share in 2030 67% 33% 66% 34% 70% 30% 

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

Table 6D. NIA Results, Scenario D 

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

FL TL ALL FL TL ALL FL TL ALL 

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

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

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

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

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

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

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

FL TL ALL FL TL ALL FL TL ALL 

NES (quad) -0.51 0.85 0.34 -0.41 0.82 0.41 -0.54 1.42 0.88 

NWS (trillion gal.) -0.67 2.88 2.22 -0.18 2.83 2.65 -0.44 5.09 4.65 

NPV @ 7% (bill $) -11.69 13.29 1.61 -9.99 12.83 2.84 -16.41 22.50 6.09 

NPV @ 3% (bill $) -24.31 31.26 6.95 -20.23 30.20 9.97 -33.10 52.51 19.41 

Mkt Share in 2015 61% 39% 60% 40% 63% 37% 

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

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

5 

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

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

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

Table 7. Refrigerator and Freezer Efficiency Levels: Stakeholder Requested 

Product EL1 EL2 EL3 EL4 EL5 EL6 EL7 EL8 

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

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

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

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

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

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

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

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

As reported in the ‘April 15’ version, the maximum reductions in annual energy use specified in the 

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

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

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

Table 8. Refrigerator and Freezer Efficiency Levels: ‘Analyzed for DOE’ 

Product EL1 EL2 EL3 EL4 EL5 EL6 EL7 EL8 

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

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

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

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

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

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

PC 18: Compact freezers 10% 15% 20% 25% 30% 35% 39% -

Also as reported in the ‘April 15’ version, in addition to the adjustments made to the maximum 

reductions in annual energy use, revisions have been made to the manufacturer selling price vs. 

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

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

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

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

LCC and PBP Results 

As described in the ‘April 15’ version, for the preliminary analysis, usage adjustment factors 

(UAF) were developed to convert the rated or test energy consumption of a standard-sized 

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

6 

EERE-2008-BT-STD-0019 COMMENT 34
analysis were greater than one. At the time of the ‘April 15’ version of the results, the UAFs 

developed for the preliminary analysis were under reevaluation. As a result, two UAF scenarios 

were considered in the ‘April 15’ version: (1) Scenario A based on UAFs from the preliminary 

analyses and (2) Scenario B based on UAFs normalized to a weighted-average value of 1.0, i.e., 

field energy consumption equals rated energy consumption. Based on an evaluation of seven 

metered refrigerator and freezer end-use studies consisting of over 1,600 data points, it has been 

tentatively concluded that UAFs on average are closer to one. Therefore, only UAF scenario B 

was retained and analyzed. 

Also under evaluation is the impact of non-HFC blowing agents on the production of foam 

insulation due to possible climate change legislation that may phase-out the use of HFCs. The 

potential move from the current blowing agent, HFC-245fa, to cyclopentane has the effect of 

reducing the resistivity of the foam insulation, thereby increasing refrigerator and freezer energy 

use. Therefore, for the same sets of design options, a lower efficiency gain is achievable with 

cyclopentane blown insulation. Table 9 shows the non-HFC-based efficiency levels that 

correspond with the HFC-based efficiency levels. 

Table 9. Refrigerator and Freezer Efficiency Levels: HFC and Non-HFC Levels 

Product EL1 EL2 EL3 EL4 EL5 EL6 EL7 EL8 

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

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

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

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

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

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

PC 9: Vertical 

freezers 

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

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

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

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

PC 11: Compact 

fridge 

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

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

PC 18: Compact 

freezers 

HFC 10% 15% 20% 25% 30% 35% 39% -

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

Therefore, the following LCC and PBP results were calculated based on two different efficiency 

scenarios. 

HFC Scenario B1: 

UAF: Normalized to a weighted-average value of 1.0. 

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

Non-HFC Scenario B2: 

UAF: Normalized to a weighted-average value of 1.0. 

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

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

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

7 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

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

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

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

rulemaking. 

Note, the use of non-HFC-based refrigerants, in particular, isobutane (R-600a), was not 

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

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

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

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

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

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

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

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

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

Table 10B1. PC 3, Top-Mount Refrigerators: LCC and PBP Results, Scenario B1 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $47 1.2% 18.9% 79.9% 2.6 3.0 

2 (15) $71 2.0% 13.0% 85.1% 3.0 3.4 

3 (20) $46 31.0% 13.0% 56.1% 8.4 9.6 

4 (25) $42 45.1% 0.0% 54.9% 10.0 11.4 

5 (30) -$9 66.1% 0.0% 33.9% 14.1 16.2 

6 (32) -$32 71.3% 0.0% 28.7% 15.5 17.7 

Table 10B2. PC 3, Top-Mount Refrigerators: LCC and PBP Results, Scenario B2 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (6) $26 1.0% 19.4% 79.6% 2.5 2.9 

2 (11) $51 2.0% 13.0% 85.0% 3.0 3.4 

3 (16) $27 37.6% 13.0% 49.4% 9.6 11.1 

4 (21) $25 50.1% 0.0% 49.9% 10.8 12.4 

5 (27) -$24 69.9% 0.0% 30.1% 15.1 17.3 

6 (28) -$47 74.3% 0.0% 25.7% 16.5 19.0 

8 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

Table 11B1. PC 5, Bottom-Mount Refrigerators: LCC and PBP Results, Scenario B1 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $8 0.1% 88.5% 11.4% 2.3 2.7 

2 (15) $12 0.2% 88.4% 11.5% 2.5 2.9 

3 (20) $15 0.4% 88.4% 11.2% 3.5 4.1 

4 (25) $0 71.8% 0.0% 28.2% 16.3 18.7 

5 (30) -$48 83.3% 0.0% 16.7% 21.1 24.3 

6 (33) -$67 84.2% 0.0% 15.8% 21.2 24.4 

Table 11B2. PC 5, Bottom-Mount Refrigerators: LCC and PBP Results, Scenario B2 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (6) $5 0.1% 87.9% 12.0% 2.2 2.5 

2 (11) $9 0.1% 87.8% 12.1% 2.5 2.9 

3 (16) $12 0.6% 87.8% 11.6% 3.7 4.3 

4 (21) -$2 70.4% 0.0% 29.6% 15.5 18.2 

5 (27) -$48 82.4% 0.0% 17.6% 20.2 23.7 

6 (30) -$64 82.5% 0.0% 17.5% 19.9 23.3 

9 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

Table 12B1. PC 7, Side-Mount Refrigerators: LCC and PBP Results, Scenario B1 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $19 0.3% 75.2% 24.5% 2.8 3.1 

2 (15) $45 0.9% 31.6% 67.6% 2.9 3.2 

3 (20) $55 8.3% 31.6% 60.2% 5.3 5.9 

4 (25) $48 41.7% 0.0% 58.4% 9.3 10.7 

5 (30) -$40 74.1% 0.0% 25.9% 16.2 18.5 

6 (31) -$62 77.7% 0.0% 22.3% 17.4 19.8 

Table 12B2. PC 7, Side-Mount Refrigerators: LCC and PBP Results, Scenario B2 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (6) $22 0.1% 75.0% 24.9% 1.5 1.7 

2 (11) $47 0.6% 31.8% 67.7% 2.5 2.8 

3 (16) $56 7.6% 31.8% 60.6% 5.1 5.7 

4 (21) $49 40.9% 0.0% 59.1% 9.3 10.6 

5 (27) -$40 74.4% 0.0% 25.6% 16.2 18.4 

6 (28) -$62 77.9% 0.0% 22.1% 17.4 19.7 

10 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

Table 13B1. PC 9, Upright Freezers: LCC and PBP Results, Scenario B1 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $77 0.1% 19.7% 80.3% 1.7 2.1 

2 (15) $111 3.2% 1.6% 95.2% 3.3 4.0 

3 (20) $147 3.9% 0.5% 95.6% 3.7 4.4 

4 (25) $174 6.7% 0.5% 92.8% 4.5 5.4 

5 (30) $204 8.6% 0.2% 91.2% 4.9 5.8 

6 (35) $201 16.6% 0.0% 83.4% 6.4 7.6 

7 (40) $175 27.7% 0.0% 72.3% 8.3 9.9 

8 (43) $69 50.2% 0.0% 49.8% 12.1 14.5 

Table 13B2. PC 9, Upright Freezers: LCC and PBP Results, Scenario B2 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (6) $43 0.1% 20.0% 79.9% 1.6 2.0 

2 (11) $80 4.0% 1.6% 94.4% 3.7 4.4 

3 (16) $119 4.8% 0.5% 94.7% 3.9 4.7 

4 (21) $149 8.1% 0.5% 91.5% 4.7 5.6 

5 (27) $181 9.6% 0.2% 90.2% 5.0 6.0 

6 (32) $181 17.8% 0.0% 82.2% 6.5 7.9 

7 (37) $158 29.7% 0.0% 70.3% 8.4 10.2 

8 (40) $35 55.3% 0.0% 44.7% 12.8 15.5 

11 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

Table 14B1. PC 10, Chest Freezers: LCC and PBP Results, Scenario B1 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $45 0.3% 15.7% 84.0% 2.3 2.6 

2 (15) $67 1.9% 1.1% 97.0% 3.3 3.8 

3 (20) $63 19.4% 0.3% 80.3% 7.0 8.2 

4 (25) $88 13.9% 0.3% 85.7% 6.2 7.2 

5 (30) $73 31.0% 0.3% 68.7% 9.0 10.4 

6 (35) $51 44.9% 0.0% 55.1% 11.5 13.2 

Table 14B2. PC 10, Chest Freezers: LCC and PBP Results, Scenario B2 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (6) $26 0.0% 15.1% 84.8% 1.8 2.0 

2 (11) $49 2.2% 1.1% 96.7% 3.3 3.8 

3 (16) $70 4.0% 0.3% 95.7% 3.9 4.5 

4 (21) $57 27.1% 0.3% 72.6% 8.3 9.6 

5 (27) $69 28.2% 0.3% 71.6% 8.5 9.7 

6 (32) $43 46.4% 0.0% 53.6% 11.5 13.2 

12 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

Table 15B1. PC 11, Compact Refrigerators: LCC and PBP Results, Scenario B1 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $8 18.9% 2.9% 78.3% 2.5 2.4 

2 (15) $13 15.8% 2.5% 81.7% 2.3 2.2 

3 (20) $11 33.8% 2.5% 63.7% 3.4 3.3 

4 (25) $3 58.0% 1.6% 40.4% 5.0 4.9 

5 (30) $9 49.1% 0.0% 50.9% 4.3 4.2 

6 (35) -$3 66.4% 0.0% 33.6% 5.6 5.4 

7 (40) -$11 73.2% 0.0% 26.8% 6.3 6.1 

8 (45) -$46 88.4% 0.0% 11.6% 8.9 8.6 

Table 15B2. PC 11, Compact Refrigerators: LCC and PBP Results, Scenario B2 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (6) $6 9.5% 2.9% 87.6% 1.8 1.8 

2 (11) $10 15.6% 2.5% 82.0% 2.2 2.2 

3 (16) $12 23.3% 2.5% 74.2% 2.8 2.7 

4 (21) $8 43.6% 1.7% 54.7% 4.0 4.0 

5 (27) $7 50.9% 0.0% 49.1% 4.5 4.4 

6 (32) -$12 76.3% 0.0% 23.7% 6.7 6.5 

7 (37) -$12 74.3% 0.0% 25.8% 6.4 6.3 

8 (42) -$37 86.2% 0.0% 13.8% 8.3 8.1 

13 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

Table 16B1. PC 18, Compact Freezers: LCC and PBP Results, Scenario B1 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (10) $12 6.3% 4.7% 89.0% 2.0 2.0 

2 (15) -$13 83.0% 0.0% 17.1% 8.8 9.3 

3 (20) -$22 87.4% 0.0% 12.6% 9.6 9.8 

4 (25) -$41 92.9% 0.0% 7.1% 11.4 11.5 

5 (30) -$31 86.5% 0.0% 13.5% 9.5 9.5 

6 (35) -$71 95.3% 0.0% 4.8% 12.7 12.7 

7 (39) -$97 96.9% 0.0% 3.1% 14.0 14.0 

Table 16B2. PC 18, Compact Freezers: LCC and PBP Results, Scenario B2 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost Savings Payback Period (years) 

Average 

Savings 

Consumers with 

Median Average Net Cost No Impact Net Benefit 

Baseline 

1 (6) $6 7.9% 4.3% 87.8% 2.3 2.3 

2 (11) $3 45.6% 0.0% 54.4% 5.2 5.2 

3 (16) -$31 95.0% 0.0% 5.0% 12.5 12.5 

4 (21) -$32 92.2% 0.0% 7.8% 11.0 11.0 

5 (27) -$33 89.3% 0.0% 10.7% 10.2 10.2 

6 (32) -$31 85.6% 0.0% 14.4% 9.3 9.3 

7 (37) -$80 96.2% 0.0% 3.8% 13.1 13.1 

NIA Results 

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

for the requested efficiency levels. The NIA results below are based on the same two scenarios 

considered in the LCC and PBP analysis. 

14 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

 

 

 

 

 

Table 17. Standard-Size Refrigerator-Freezers: NES Results (quads) 

Efficiency Level 

(% less than 

baseline energy 

use) 

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

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

1 (10) 1 (6) 0.89 0.49 0.03 0.03 0.21 0.21 

2 (15) 2 (11) 1.37 0.99 0.05 0.05 0.50 0.49 

3 (20) 3 (16) 1.88 1.54 0.18 0.18 0.90 0.89 

4 (25) 4 (21) 2.36 2.05 0.28 0.28 1.23 1.21 

5 (30) 5 (27) 2.79 2.50 0.32 0.32 1.52 1.50 

6 (31-33) 6 (28-30) 2.92 2.65 0.34 0.34 1.58 1.55 

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

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

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

Table 18. Standard-Size Refrigerator-Freezers: NPV Results (billion $) 

Efficiency 

Level 

(% less than 

baseline) 

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

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

B1 B2 Scen 

B1 

Scen 

B2 

Scen 

B1 

Scen 

B2 

Scen 

B1 

Scen 

B2 

Scen 

B1 

Scen 

B2 

Scen 

B1 

Scen 

B2 

Scen 

B1 

Scen 

B2 

1 (10) 1 (6) 3.44 1.91 9.56 5.30 0.14 0.14 0.38 0.39 0.79 0.89 2.27 2.44 

2 (15) 2 (11) 5.10 3.70 14.33 10.39 0.20 0.20 0.57 0.57 1.87 1.94 5.35 5.46 

3 (20) 3 (16) 2.55 1.29 11.13 7.57 -0.38 -0.38 -0.25 -0.24 1.30 1.33 5.45 5.45 

4 (25) 4 (21) 1.86 0.73 11.41 8.19 -0.75 -0.74 -0.61 -0.59 0.77 0.77 5.49 5.41 

5 (30) 5 (27) -1.82 -2.82 5.89 3.00 -1.04 -1.03 -0.95 -0.93 -2.08 -2.11 1.13 0.98 

6 (31­

33) 

6 (28­

30) -3.40 -4.36 3.34 0.57 -1.16 -1.15 -1.07 -1.04 -2.77 -2.81 0.02 -0.15 

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

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

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

15 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

 

 

 

 

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

Efficiency Level 

(% less than baseline 

energy use) Upright Freezers* Chest Freezers** 

B1 B2 Scenario B1 Scenario B2 Scenario B1 Scenario B2 

1 (10) 1 (6) 0.25 0.14 0.15 0.09 

2 (15) 2 (11) 0.39 0.29 0.24 0.18 

3 (20) 3 (16) 0.54 0.45 0.33 0.27 

4 (25) 4 (21) 0.68 0.60 0.41 0.36 

5 (30) 5 (27) 0.82 0.74 0.49 0.45 

6 (35) 6 (32) 0.95 0.88 0.56 0.52 

7 (40) 7 (37) 1.06 0.99 - -

8 (43.2) 8 (40) 1.12 1.01 - -

* Includes product class 9 only. 

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

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

Efficiency Level 

(% less than 

baseline) 

Upright Freezers* Chest Freezers** 

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

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

1 (10) 1 (6) 1.06 0.59 3.10 1.71 0.67 0.37 1.94 1.08 

2 (15) 2 (11) 1.50 1.07 4.58 3.31 0.96 0.70 2.90 2.11 

3 (20) 3 (16) 1.95 1.56 6.07 4.91 1.18 0.94 3.67 2.97 

4 (25) 4 (21) 2.28 1.93 7.31 6.26 0.98 0.77 3.65 3.04 

5 (30) 5 (27) 2.57 2.25 8.45 7.51 1.06 0.88 4.13 3.59 

6 (35) 6 (32) 2.41 2.14 8.68 7.86 0.64 0.49 3.61 3.15 

7 (40) 7 (37) 1.84 1.57 8.03 7.21 - - - -

8 (43.2) 8 (40) 0.65 0.21 6.02 4.74 - - - -

* Includes product class 9 only. 

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

16 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

 

 

 

Table 21. Compacts: NES Results (quads) 

Efficiency Level 

(% less than baseline 

energy use) Compact Refrigerators* Compact Freezers** 

B1 B2 Scenario B1 Scenario B2 Scenario B1 Scenario B2 

1 (10) 1 (6) 0.13 0.07 0.03 0.02 

2 (15) 2 (11) 0.20 0.14 0.04 0.03 

3 (20) 3 (16) 0.26 0.21 0.05 0.04 

4 (25) 4 (21) 0.32 0.27 0.06 0.06 

5 (30) 5 (27) 0.37 0.33 0.08 0.07 

6 (35) 6 (32) 0.41 0.37 0.08 0.08 

7 (40-39) 7 (37) 0.45 0.42 0.09 0.09 

8 (45) 8 (40) 0.47 0.45 - -

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

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

Table 22. Compacts: NPV Results (billion $) 

Efficiency Level 

(% less than 

baseline) 

Compact Refrigerators* Compact Freezers** 

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

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

1 (10) 1 (6) 0.37 0.21 0.89 0.50 0.09 0.05 0.22 0.11 

2 (15) 2 (11) 0.51 0.36 1.23 0.88 -0.06 0.03 -0.05 0.11 

3 (20) 3 (16) 0.56 0.43 1.40 1.10 -0.10 -0.16 -0.11 -0.24 

4 (25) 4 (21) 0.43 0.32 1.21 0.94 -0.20 -0.16 -0.27 -0.21 

5 (30) 5 (27) 0.38 0.29 1.17 0.94 -0.14 -0.15 -0.14 -0.19 

6 (35) 6 (32) -0.20 -0.28 0.06 -0.13 -0.32 -0.14 -0.48 -0.13 

7 (40-39) 7 (37) -0.19 -0.25 0.15 -0.01 -0.43 -0.36 -0.66 -0.55 

8 (45) 8 (40) -0.82 -0.88 -1.07 -1.21 - - - -

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

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

17 

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

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

(PBP) results for room air conditioners. 

LCC and PBP Results 

Two scenarios are currently under consideration: (1) two sets of cabinet size increases as was 

considered for the preliminary analysis and (2) one cabinet size increase assuming that cabinet 

constraints are more severe than assumed for the preliminary analysis. Therefore, the following 

LCC and PBP results were calculated based on the above two cabinet size increase scenarios. 

Cabinet Increase Constraint Scenario A: Preliminary analysis assumptions where two sets of 

cabinet size increases were considered for window units (i.e. product classes 1, 3, and 5, with 

louvered sides). 

Cabinet Increase Constraint Scenario B: More severe cabinet constraints where only one 

cabinet size increase is assumed. 

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

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

units, and the fixed size of wall sleeves. 

The results are presented in terms of integrated EER (IEER), which integrates active and standby 

mode energy use, as required by the EPCA as modified by the Energy Independence and 

Security Act of 2007. The IEER is calculated as follows: 

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

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

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

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

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

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

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

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

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

18 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

Table 23A. PC 1, <6000 Btu/h, with Louvers: LCC and PBP Results, Scenario A 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 9.52 

1 10.1 $26 15% 4% 81% 0.9 6.3 

2 10.6 $42 20% 4% 76% 1.6 11.6 

3 11.1 $51 30% 0% 70% 2.4 14.0 

4 11.6 $57 36% 0% 64% 3.1 17.1 

5 12.0 $63 38% 0% 62% 3.4 23.5 

Table 23B. PC 1, <6000 Btu/h, with Louvers: LCC and PBP Results, Scenario B 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 9.52 

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

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

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

19 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

Table 24A. PC 3, 8000-13,999 Btu/h, with Louvers: LCC and PBP Results, Scenario A 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 9.7 

1 10.3 $14 14% 49% 37% 1.6 10.4 

2 10.8 $23 17% 47% 36% 2.5 11.9 

3 11.3 $24 53% 3% 44% 6.7 33.1 

4 11.5 -$24 69% 1% 30% 11.2 79.1 

Table 24B. PC 3, 8000-13,999 Btu/h, with Louvers: LCC and PBP Results, Scenario B 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 9.7 

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

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

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

20 

EERE-2008-BT-STD-0019 COMMENT 34
 

 

 

Table 25A. PC 5, ≥ 20,000 Btu/h, with Louver: LCC and PBP Results, Scenario A 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 8.47 

1 9.0 $21 14% 63% 23% 3.2 7.3 

2 9.4 $33 21% 57% 23% 5.5 7.6 

3 9.8 $40 63% 1% 37% 11.8 14.5 

4 10.0 $17 71% 0% 29% 15.8 20.9 

Table 25B. PC 5, ≥ 20,000 Btu/h, with Louver: LCC and PBP Results, Scenario B 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 8.47 

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

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

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

Table 26B. PC 8, 8000-13,999 Btu/h, without Louver: LCC and PBP Results, Scenario B 

Energy 

Efficiency 

Level 

IEER 

Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Savings 

Consumers with 

Net Median Average 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 8.4 

1 8.9 $14 3% 61% 36% 0.8 2.6 

2 9.3 $23 4% 61% 35% 1.1 3.7 

3 9.8 $37 39% 0% 61% 4.7 17.9 

21 

EERE-2008-BT-STD-0019 COMMENT 34