TECHNICAL REPORT:

Analysis of Amended Energy Conservation Standards for

Residential Refrigerator-Freezers

October 2005

U.S. Department of Energy

Assistant Secretary

Office of Energy Efficiency and Renewable Energy

Building Technologies Program

Appliances and Commercial Equipment Standards

Washington, DC 20585

 EE-PS-2006-001 COMMENT 04.7

TECHNICAL REPORT: 

Analysis of Amended Energy Conservation Standards for 

Residential Refrigerator-Freezers 

October 2005 

U.S. Department of Energy 

Assistant Secretary 

Office of Energy Efficiency and Renewable Energy 

Building Technologies Program 

Appliances and Commercial Equipment Standards 

Washington, DC 20585 

#4.7 
TABLE OF CONTENTS

EXECUTIVE SUMMARY ................................................................................................. ES-1

CHAPTER 1. INTRODUCTION ......................................................................................1-1

CHAPTER 2. MARKET AND TECHNOLOGY ASSESSMENT ...................................2-1

2.1 MARKET ASSESSMENT ........................................................................................... 2-1

2.2 ENERGY PERFORMANCE .......................................................................................2-2

2.3 DESIGN OPTIONS TO IMPROVE EFFICIENCY ......................................................2-4

2.4 TEST PROCEDURE STATUS ....................................................................................2-6

2.4.1 Credit for a more efficient defrost system ......................................................... 2-6

2.4.2 Change in electric refrigerator definition to exclude wine coolers .....................2-6

2.4.3 Repeatability issues for testing compact refrigerators ........................................2-6

2.4.4 Harmonizing with international standards .........................................................2-7

CHAPTER 3. ENGINEERING ANALYSIS .....................................................................3-1

3.1 REVIEW OF 1995 TSD ...............................................................................................3-1

3.1.1 Top-Mount Refrigerators .................................................................................. 3-1

3.1.2 Side-Mount Refrigerators .................................................................................3-2

3.1.3 DOE 1995 TSD Cost Analyses .........................................................................3-3

3.2 AHAM DATA SUBMITTAL AND CONSOLIDATION ............................................3-4

3.2.1 Comparison of AHAM Cost Data with TSD Cost Estimates ............................3-5

3.3 MANUFACTURER INTERVIEWS ............................................................................3-6

3.3.1 15 Percent Energy Use Reduction .....................................................................3-6

3.3.2 25 Percent Energy Use Reduction .....................................................................3-7

3.3.3 Bottom-Mount Refrigerators ............................................................................. 3-7

3.3.4 Platform Changes .............................................................................................3-7

3.3.5 Intellectual Property ......................................................................................... 3-7

CHAPTER 4. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS ................ 4-9

4.1 LIFE-CYCLE COST METHODOLOGY .....................................................................4-9

4.2 CONSUMER RETAIL PRICE ...................................................................................4-11

4.2.1 Baseline Retail Price ....................................................................................... 4-11

4.2.2 Incremental Retail Prices based on Incremental Manufacturing Costs .............4-14

4.2.2.1 Incremental Manufacturing Costs ..................................................... 4-14

4.2.2.2 Manufacturer-to-Consumer Markup ................................................. 4-15

4.2.2.3 Resultant Incremental Retail Prices ..................................................4-15

4.2.3 Incremental Retail Prices based on Regression Analysis .................................4-16

4.2.4 Comparison of Manufacturing Cost-Based and Regression Analysis Retail

Prices .............................................................................................................. 4-18

4.2.5 Focused Matched Pair Analysis ......................................................................4-20

4.3 LIFETIME ELECTRICITY COST ............................................................................4-23

4.3.1 Annual Electricity Cost ...................................................................................4-23

4.3.1.1 Annual Electricity Consumption ......................................................4-23

 EE-PS-2006-001 COMMENT 04.7

#4.7 

TABLE OF CONTENTS 

EXECUTIVE SUMMARY ................................................................................................. ES-l 

CHAPTER 1. INTRODUCTION ...................................................................................... 1-1 

CHAPTER 2. MARKET AND TECHNOLOGY ASSESSMENT ........•...............•.......... 2-1 

2.1 MARKET ASSESSMENT ........................................................................................... 2-1 

2.2 ENERGY PERFORMANCE ....................................................................................... 2-2 

2.3 DESIGN OPTIONS TO IMPROVE EFFICIENCy ...................................................... 2-4 

2.4 TEST PROCEDURE STATUS .................................................................................... 2-6 

2.4.1 Credit for a more efficient defrost system ......................................................... 2-6 

2.4.2 Change in electric refrigerator definition to exclude wine coolers ..................... 2-6 

2.4.3 Repeatability issues for testing compact refrigerators ........................................ 2-6 

2.4.4 Harmonizing with international standards ......................................................... 2-7 

CHAPTER 3. ENGINEERING ANALYSIS ..................................................................... 3-1 

3.1 REVIEW OF 1995 TSD ............................................................................................... 3-1 

3 .1.1 Top-Mount Refrigerators .................................................................................. 3-1 

3.1.2 Side-Mount Refrigerators ................................................................................. 3-2 

3.1.3 DOE 1995 TSD Cost Analyses ......................................................................... 3-3 

3.2 AHAM DATA SUBMITTAL AND CONSOLIDATION ............................................ 3-4 

3.2.1 Comparison of AHAM Cost Data with TSD Cost Estimates ............................. 3-5 

3.3 MANUFACTURER INTERVIEWS ............................................................................ 3-6 

3.3.1 15 Percent Energy Use Reduction ..................................................................... 3-6 

3.3.2 25 Percent Energy Use Reduction ..................................................................... 3-7 

3.3.3 Bottom-Mount Refrigerators ............................................................................. 3-7 

3.3.4 Platform Changes ............................................................................................. 3-7 

3.3.5 Intellectual Property ......................................................................................... 3-7 

CHAPTER 4. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS ................ 4-9 

4.1 LIFE-CYCLE COST METHODOLOGY .................................................................... .4-9 

4.2 CONSUMER RETAIL PRICE ................................................................................... 4-11 

4.2.1 Baseline Retail Price ....................................................................................... 4-11 

4.2.2 Incremental Retail Prices based on Incremental Manufacturing Costs ............ .4-14 

4.2.2.1 Incremental Manufacturing Costs ..................................................... 4-14 

4.2.2.2 Manufacturer-to-Consumer Markup ................................................. 4-15 

4.2.2.3 Resultant Incremental Retail Prices ................................................. .4-15 

4.2.3 Incremental Retail Prices based on Regression Analysis ................................ .4-16 

4.2.4 Comparison of Manufacturing Cost-Based and Regression Analysis Retail 

Prices .............................................................................................................. 4-18 

4.2.5 Focused Matched Pair Analysis ..................................................................... .4-20 

4.3 LIFETIME ELECTRICITY COST ........................................................................... .4-23 

4.3.1 Annual Electricity Cost.. ................................................................................ .4-23 

4.3.1.1 Annual Electricity Consumption ..................................................... .4-23 
4.3.1.2 Electricity Prices ..............................................................................4-27

4.3.2 Product Lifetime ............................................................................................. 4-27

4.3.3 Discount Rate ................................................................................................. 4-28

4.3.4 Electricity Price Trends ..................................................................................4-29

4.4 PAYBACK PERIOD METHODOLOGY ..................................................................4-30

4.5 RESULTS OF THE LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS ..4-30

CHAPTER 5. NATIONAL IMPACT ANALYSIS ...........................................................5-1

5.1 NATIONAL ENERGY SAVINGS CALCULATION ..................................................5-1

5.2 NET PRESENT VALUE CALCULATION .................................................................5-3

5.3 INPUTS TO THE NES AND NPV CALCULATIONS ................................................ 5-5

5.3.1 Shipments......................................................................................................... 5-5

5.3.1.1 Historical Shipments ..........................................................................5-5

5.3.1.2 Projected Shipments ........................................................................... 5-6

5.3.1.3 Product Class Market Shares and Project Shipments by Product Class5-7

5.3.2 Unit Electricity Consumption and Consumer Retail Prices ..............................5-10

5.3.2.1 Weighted-Average Unit Electricity Consumption and Per-Unit

Consumer Retail Price for Baseline, 15 percent less energy, and 25

percent less energy Products ...............................................................5-10

5.3.2.2 Base Case and Standards Case Market Shares ..................................5-11

5.3.2.3 Base Case and Standards Case Unit Electricity Consumption and

Consumer Retail Prices ................................................................................... 5-14

5.3.3 Product Lifetime ............................................................................................. 5-22

5.3.4 Electricity Price .............................................................................................. 5-22

5.3.5 Site-to-Source Energy Conversion Factors ......................................................5-23

5.3.6 Discount Rate ................................................................................................. 5-24

5.3.7 Analysis Period ..............................................................................................5-25

5.4 NES AND NPV RESULTS ........................................................................................5-25

CHAPTER 6. MANUFACTURER IMPACT ANALYSIS ...............................................6-1

6.1 IMPACT ON FINANCIAL PERFORMANCE ............................................................ 6-1

6.1.1 Conversion Costs .............................................................................................. 6-1

6.1.2 Profitability ......................................................................................................6-2

6.1.3 Impact on Export Sales .............................................................. .......................6-3

6.2 IMPACT ON U.S. PRODUCTION AND JOBS ...........................................................6-3

6.2.1 Industry Consolidation ...................................................................................... 6-4

6.3 IMPACT ON PRODUCT UTILITY AND INNOVATION ..........................................6-4

6.4 CUMULATIVE BURDEN ..........................................................................................6-5

6.4.1 Existing Energy Efficiency Standard for. Refrigerator-Freezers ......................... 6-6

6.4.2 Insulation Blowing Agent Phase Out ................................................................6-7

6.4.3 Energy Conservation Standards for Other Products Made by the

Manufacturers of Refrigerator-Freezers ............................................................6-7

6.4.4 State Energy Conservation Standards ................................................................6-7

6.4.5 The Energy Policy Act of 2005 .........................................................................6-7

6.4.6 International Energy Efficiency Regulations ..................................................... 6-9

6.4.7 Waste Disposal and Recycling Requirements....................................................6-9

ii

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#4.7 

4.3.1.2 Electricity Prices .............................................................................. 4-27 

4.3.2 Product Lifetime ............................................................................................. 4-27 

4.3.3 Discount Rate ................................................................................................. 4-28 

4.3.4 Electricity Price Trends .................................................................................. 4-29 

4.4 PAYBACK PERIOD METHODOLOGY ................................................................. .4-30 

4.5 RESULTS OF THE LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS . .4-30 

CHAPTER 5. NATIONAL IMPACT ANALYSIS ........................................................... 5-1 

5.1 NATIONAL ENERGY SAVINGS CALCULATION .................................................. 5-1 

5.2 NET PRESENT VALUE CALCULATION ................................................................. 5-3 

5.3 INPUTS TO THE NES AND NPV CALCULATIONS ................................................ 5-5 

5.3.1 Shipments ......................................................................................................... 5-5 

5.3.1.1 Historical Shipments .......................................................................... 5-5 

5.3.1.2 Projected Shipments ........................................................................... 5-6 

5.3.1.3 Product Class Market Shares and Project Shipments by Product Class5-7 

5.3.2 Unit Electricity Consumption and Consumer Retail Prices .............................. 5-1O 

5.3.2.1 Weighted-Average Unit Electricity Consumption and Per-Unit 

Consumer Retail Price for Baseline, 15 percent less energy, and 25 

percent less energy Products ............................................................... 5-10 

5.3.2.2 Base Case and Standards Case Market Shares .................................. 5-11 

5.3.2.3 Base Case and Standards Case Unit Electricity Consumption and 

Consumer Retail Prices ................................................................................... 5-14 

5.3.3 Product Lifetime ............................................................................................. 5-22 

5.3.4 Electricity Price .............................................................................................. 5-22 

5.3.5 Site-to-Source Energy Conversion Factors ...................................................... 5-23 

5.3.6 Discount Rate ................................................................................................. 5-24 

5.3.7 Analysis Period .............................................................................................. 5-25 

5.4 NES AND NPV RESULTS ........................................................................................ 5-25 

CHAPTER 6. MANUFACTURER IMPACT ANALYSIS ............................................... 6-1 

6.1 IMPACT ON FINANCIAL PERFORMANCE ............................................................ 6-1 

6.1.1 Conversion Costs .............................................................................................. 6-1 

6.1.2 Profitability ...................................................................................................... 6-2 

6.1.3 Impact on Export Sales ..................................................................................... 6-3 

6.2 IMPACT ON U.S. PRODUCTION AND JOBS ........................................................... 6-3 

6.2.1 Industry Consolidation ...................................................................................... 6-4 

6.3 IMPACT ON PRODUCT UTILITY AND INNOVATION .......................................... 6-4 

6.4 CUMULATIVE BURDEN .......................................................................................... 6-5 

6.4.1 Existing Energy Efficiency Standard for Refrigerator-Freezers ......................... 6-6 

6.4.2 Insulation Blowing Agent Phase Out ................................................................ 6-7 

6.4.3 Energy Conservation Standards for Other Products Made by the 

Manufacturers of Refrigerator-Freezers ............................................................ 6-7 

6.4.4 State Energy Conservation Standards ................................................................ 6-7 

6.4.5 The Energy Policy Act of 2005 ......................................................................... 6-7 

6.4.6 International Energy Efficiency Regulations ..................................................... 6-9 

6.4.7 Waste Disposal and Recycling Requirements .................................................... 6-9 

ii 
#4.

6.4.8 Restriction of Hazardous Substances ..............................................................6-10

6.4.9 Microwave Oven Radio Frequency Emission Regulations ..............................6-11

6.4.10 Arc-Fault Protection for Window Air-Conditioning Unit Power Cords ...........6-11

6.4.11 Flammable Vapor Resistance Standard for Water Heaters ..............................6-11

6.4.12 Water Factor Standards for Clothes Washers ..................................................6-11

6.4.13 Indoor Air Quality Regulations for Ranges and Ovens....................................6-12

6.4.14 Impact of Cumulative Burden on Small Manufacturers...................................6-12

APPENDIX A. ARAM DATA SUBMITTAL REQUEST............................................... A-i

APPENDIX B. CONSUMER RETAIL PRICE DATASET: SUMMARY DATA AND

REGRESSION ANALYSIS DETAILS................................................... B-i

APPENDIX C. DETAILS OF FOCUSED MATCHED PAIRS ...................................... C-i

APPENDIX D. MANUFACTURER INTERVIEW GUIDE ........................................... D-i

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 EE-PS-2006-001 COMMENT 04.7

#4.7 

6.4.8 Restriction of Hazardous Substances .............................................................. 6-10 

6.4.9 Microwave Oven Radio Frequency Emission Regulations .............................. 6-11 

6.4.10 Arc-Fault Protection for Window Air-Conditioning Unit Power Cords ........... 6-11 

6.4.11 Flammable Vapor Resistance Standard for Water Heaters .............................. 6-11 

6.4.12 Water Factor Standards for Clothes Washers .................................................. 6-11 

6.4.13 Indoor Air Quality Regulations for Ranges and Ovens .................................... 6-12 

6.4.14 Impact of Cumulative Burden on Small Manufacturers ................................... 6-12 

APPENDIX A. AHAM DATA SUBMITTAL REQUEST ............................................... A-1 

APPENDIX B. CONSUMER RETAIL PRICE DATASET: SUMMARY DATA AND 

REGRESSION ANALYSIS DETAILS ................................................... B-1 

APPENDIX C. DETAILS OF FOCUSED MATCHED PAIRS ...................................... C-1 

APPENDIX D. MANUFACTURER INTERVIEW GUIDE ........................................... D-1 

iii 
LIST OF TABLES

Table 2-1. Energy Consumption of Residential Refrigeration Equipment ................................2-1

Table 2-2. Residential Refrigerator and Refrigerator-Freezer Unit Shipment Data ...................2-2

Table 2-3. Refrigerator, Refrigerator-Freezer, and Freezer Energy Efficiency Standards .........2-3

Table 2-4. Maximum UEC Values for Refrigerator-Freezers with Different Specifications ..... 2-4

Table 3-1. TSD Energy Use Calculations ................................................................................3-1

Table 3-2. DOE 1995 TSD Manufacturing Cost Analysis Summary (1992$) ..........................3-4

Table 3-3. Incremental Manufacturing Costs for Top-Mounted Refrigerator-Freezers without

Through-the-Door Features .............................................................................................. 3-5

Table 3-4. Incremental Manufacturing Costs for Side-Mount Refrigerator-Freezers with

Through-the-Door Features .............................................................................................. 3-5

Table 3-5. Comparison of 1995 TSD and AHAM Manufacturing Cost Premium Estimates ....3-6

Table 4-1. Baseline Retail Prices: Refrigerator-Freezers with Top-Mount Freezer and

without TTD Ice Service ................................................................................................ 4-13

Table 4-2. Baseline Retail Prices: Refrigerator-Freezers with Side-Mount Freezer and with

TTD Ice Service ............................................................................................................. 4-14

Table 4-3. Incremental Manufacturing Costs: Refrigerator-Freezers with Top-Mount

Freezer and without TTD Ice Service ............................................................................. 4-14

Table 4-4. Incremental Manufacturing Costs: Refrigerator-Freezers with Side-Mount

Freezer and with TTD Ice Service ..................................................................................4-14

Table 4-5. Manufacturer-to-Consumer Markups for Refrigerator-Freezers ............................4-15

Table 4-6. Manufacturing Cost-Based Incremental Retail Prices: Refrigerator-Freezers with

Top-Mount Freezer and without TTD Ice Service ..........................................................4-15

Table 4-7. Manufacturing Cost-Based Incremental Retail Prices: Refrigerator-Freezers with

Side-Mount Freezer and with TTD Ice Service ...............................................................4-15

Table 4-8. Regression Analysis Results on the Incremental Retail Price of Energy Star ........4-16

Table 4-9. Regression Analysis Incremental Retail Prices: Refrigerator-Freezers with TopMount Freezer and without TTD Ice Service ..................................................................4-18

Table 4-10. Regression Analysis Incremental Retail Prices: Refrigerator-Freezers with SideMount Freezer and with TTD Ice Service .......................................................................4-18

Table 4-11. Comparison of Matched Pairs: Refrigerator-Freezers with Top-Mount Freezer

and without TTD Ice Service ........................................................................................4-22

Table 4-12. Comparison of Matched Pairs: Refrigerator-Freezers with Side-Mount Freezer

and with TTD Ice Service ..............................................................................................4-22

Table 4-1.3. Freezer-Volume-to-Total-Refrigerated-Volume: Refrigerator-Freezers with

Top-Mount Freezer and without TTD Ice Service ..........................................................4-24

Table 4-14. Freezer-Volume-to-Total-Refrigerated-Volume: Refrigerator-Freezers with

Side-Mount Freezer and with TTD Ice Service ...............................................................4-24

Table 4-15. Adjusted Total Volumes: Refrigerator-Freezers with Top-Mount Freezer and

without TTD Ice Service ................................................................................................ 4-25

Table 4-16. Adjusted Total Volumes: Refrigerator-Freezers with Side-Mount Freezer and

with TTD Ice Service ..................................................................................................... 4-25

Table 4-17. Annual Electricity Consumption: Refrigerator-Freezers with Top-Mount

Freezer and without TTD Ice Service ............................................................................. 4-26

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 EE-PS-2006-001 COMMENT 04.7

#4.7 

LIST OF TABLES 

Table 2-1. Energy Consumption of Residential Refrigeration Equipment.. .............................. 2-1 

Table 2-2. Residential Refrigerator and Refrigerator-Freezer Unit Shipment Data ................... 2-2 

Table 2-3. Refrigerator, Refrigerator-Freezer, and Freezer Energy Efficiency Standards ......... 2-3 

Table 2-4. Maximum DEC Values for Refrigerator-Freezers with Different Specifications ..... 2-4 

Table 3-1. TSD Energy Use Calculations ................................................................................ 3-1 

Table 3-2. DOE 1995 TSD Manufacturing Cost Analysis Summary (1992$) .......................... 3-4 

Table 3-3. Incremental Manufacturing Costs for Top-Mounted Refrigerator-Freezers without 

Through-the-Door Features ....................................................................... : ...................... 3-5 

Table 3-4. Incremental Manufacturing Costs for Side-Mount Refrigerator-Freezers with 

Through-the-Door Features .............................................................................................. 3-5 

Table 3-5. Comparison of 1995 TSD and AHAM Manufacturing Cost Premium Estimates .... 3-6 

Table 4-1. Baseline Retail Prices: Refrigerator-Freezers with Top-Mount Freezer and 

without TTD Ice Service ................................................................................................ 4-13 

Table 4-2. Baseline Retail Prices: Refrigerator-Freezers with Side-Mount Freezer and with 

TTD Ice Service ............................................................................................................. 4-14 

Table 4-3. Incremental Manufacturing Costs: Refrigerator-Freezers with Top-Mount 

Freezer and without TID Ice Service ............................................................................ .4-14 

Table 4-4. Incremental Manufacturing Costs: Refrigerator-Freezers with Side-Mount 

Freezer and with TTD Ice Service .................................................................................. 4-14 

Table 4-5. Manufacturer-to-Consumer Markups for Refrigerator-Freezers ........................... .4-15 

Table 4-6. Manufacturing Cost-Based Incremental Retail Prices: Refrigerator-Freezers with 

Top-Mount Freezer and without TTD Ice Service ......................................................... .4-15 

Table 4-7. Manufacturing Cost-Based Incremental Retail Prices: Refrigerator-Freezers with 

Side-Mount Freezer and with TTD Ice Service .............................................................. .4-15 

Table 4-8. Regression Analysis Results on the Incremental Retail Price of Energy Star ....... .4-16 

Table 4-9. Regression Analysis Incremental Retail Prices: Refrigerator-Freezers with TopMount Freezer and without TID Ice Service ................................................................. .4-18 

Table 4-10. Regression Analysis Incremental Retail Prices: Refrigerator-Freezers with SideMount Freezer and with TTD Ice Service ...................................................................... .4-18 

Table 4-11. Comparison of Matched Pairs: Refrigerator-Freezers with Top-Mount Freezer 

and without TTD Ice Service ........................................................................................ 4-22 

Table 4-12. Comparison of Matched Pairs: Refrigerator-Freezers with Side-Mount Freezer 

and with TTD Ice Service .............................................................................................. 4-22 

Table 4-13. Freezer-Volume-to-Total-Refrigerated-Volume: Refrigerator-Freezers with 

Top-Mount Freezer and without TTD Ice Service ......................................................... .4-24 

Table 4-14. Freezer-Volume-to-Total-Refrigerated-Volume: Refrigerator-Freezers with 

Side-Mount Freezer and with TTD Ice Service .............................................................. .4-24 

Table 4-15. Adjusted Total Volumes: Refi:igerator-Freezers with Top-Mount Freezer and 

without TTD Ice Service ................................................................................................ 4-25 

Table 4-16. Adjusted Total Volumes: Refrigerator-Freezers with Side-Mount Freezer and 

with TTD Ice Service ..................................................................................................... 4-25 

Table 4-17. Annual Electlicity Consumption: Refrigerator-Freezers with Top-Mount 

Freezer and without TTD Ice Service ............................................................................. 4-26 

iv 
#4.7

Table 4-18. Annual Electricity Consumption: Refrigerator-Freezers with Side-Mount

Freezer and with TTD Ice Service ..................................................................................4-26

Table 4-19. Average Residential Retail Price of Electricity, 2000-2003 ................................4-27

Table 4-20. After-Tax Real Interest or Return Rates for Household Debt and Equity Types..4-29

Table 4-21. Consumer Retail Price and Retail Price Increases : Refrigerator-Freezers with

Top-Mount Freezer and without TTD Ice Service ..........................................................4-32

Table 4-22. First-Year and Lifetime Electricity Costs and Electricity Cost Savings:

Refrigerator-Freezers with Top-Mount Freezer and without TTD Ice Service ................4-32

Table 4-23. LCC, LCC Savings, and Payback Periods: Refrigerator-Freezers with

Top-Mount Freezer and without TTD Ice Service ..........................................................4-32

Table 4-24. Consumer Retail Price and Retail Price Increases : Refrigerator-Freezers with

Side-Mount Freezer and with TTD Ice Service ...............................................................4-33

Table 4-25 . First-Year and Lifetime Electricity Costs and Electricity Cost Savings:

Refrigerator-Freezers with Side-Mount Freezer and with TTD Ice Service.....................4-33

Table 4-26. LCC, LCC Savings, and Payback Periods: Refrigerator -Freezers with SideMount Freezer and with TTD Ice Service .......................................................................4-33

Table 5-1. Historical Refrigerator-Freezer Shipments .............................................................5-5

Table 5-2. Projected Refrigerator -Freezer Shipments ..............................................................5-7

Table 5-3. Market Share of Refrigerator -Freezer Product Classes ........................................... 5-8

Table 5-4. Refrigerator-Freezer Shipments Used in the Analysis ............................................. 5-9

Table 5-5 . Weighted-Average UECs and Retail Prices: Refrigerator -Freezers with TopMount Freezer and without TTD Ice Service ..................................................................5-10

Table 5-6. Weighted-Average UECs and Retail Prices: Refrigerator-Freezers with SideMount Freezer and with TTD Ice Service .......................................................................5-10

Table 5-7. Market Share of Baseline and Current Energy Star Refrigerator -Freezers............. 5-11

Table 5-8. Standards Case Market Share Scenarios: Refrigerator-Freezers with Top-Mount

Freezer and without TTD Ice Service ............................................................................. 5-12

Table 5-9. Standards Case Market Share Scenarios: Refrigerator-Freezers with Side-Mount

Freezer and with TTD Ice Service ..................................................................................5-13

Table 5-10. Base Case and Standards Case Average UECs for New Product Shipments:

Refrigerator-Freezers with Top-Mount Freezer and without TTD Ice Service ................5-15

Table 5-11. Base Case and Standards Case Average UECs for New Product Shipments:

Refrigerator-Freezers with Side-Mount Freezer and with TTD Ice Service.....................5-17

Table 5-12. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for

New Product Shipments : Refrigerator-Freezers with Top-Mount Freezer and without

TTD Ice Service .............................................................................................................5-19

Table 5-13. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for

New Product Shipments : Refrigerator-Freezers with Side-Mount Freezer and with

TTD Ice Service .............................................................................................................5-21

Table 5-14. Historical and Forecasted Electricity Prices ........................................................5-23

Table 5-15. Site-to-Source Conversion Factors .....................................................................5-24

Table 5-16. National Energy Savings and Net Present Value of Standards for RefrigeratorFreezers with Top-Mount Freezer and without TTD Ice Service & with Side-Mount

Freezer and with TTD Ice Service (2010-2035) ............................................................. 5-26

Table 6-1. Estimated Investments and Expenses to Reach Various Efficiency Levels, from

1993 Standard Levels .......................................................................................................6-6

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#4.7 

Table 4-18. Annual Electricity Consumption: Refrigerator-Freezers with Side-Mount 

Freezer and with TTD Ice Service ................................................................................. .4-26 

Table 4-19. Average Residential Retail Price of Electricity, 2000-2003 ............................... .4-27 

Table 4-20. After-Tax Real Interest or Return Rates for Household Debt and Equity Types . .4-29 

Table 4-21. Consumer Retail Price and Retail Price Increases: Refrigerator-Freezers with 

Top-Mount Freezer and without TID Ice Service ......................................................... .4-32 

Table 4-22. First-Year and Lifetime Electricity Costs and Electricity Cost Savings: 

Refrigerator-Freezers with Top-Mount Freezer and without TTD Ice Service ............... .4-32 

Table 4-23. LCC, LCC Savings, and Payback Periods: Refrigerator-Freezers with 

Top-Mount Freezer and without TID Ice Service ......................................................... .4-32 

Table 4-24. Consumer Retail Price and Retail Price Increases: Refrigerator-Freezers with 

Side-Mount Freezer and with TTD Ice Service .............................................................. .4-33 

Table 4-25. First-Year and Lifetime Electricity Costs and Electricity Cost Savings: 

Refrigerator-Freezers with Side-Mount Freezer and with TTD Ice Service .................... .4-33 

Table 4-26. LCC, LCC Savings, and Payback Periods: Refrigerator-Freezers with SideMount Freezer and with TTD Ice Service ...................................................................... .4-33 

Table 5-1. Historical Refrigerator-Freezer Shipments ............................................................. 5-5 

Table 5-2. Projected Refrigerator-Freezer Shipments .............................................................. 5-7 

Table 5-3. Market Share of Refrigerator-Freezer Product Classes ........................................... 5-8 

Table 5-4. Refrigerator-Freezer Shipments Used in the Analysis ............................................. 5-9 

Table 5-5. Weighted-Average UECs and Retail Prices: Refrigerator-Freezers with TopMount Freezer and without TTD Ice Service .................................................................. 5-10 

Table 5-6. Weighted-Average UECs and Retail Prices: Refrigerator-Freezers with SideMount Freezer and with TTD Ice Service ....................................................................... 5-10 

Table 5-7. Market Share of Baseline and Current Energy Star Refrigerator-Freezers ............. 5-11 

Table 5-8. Standards Case Market Share Scenarios: Refrigerator-Freezers with Top-Mount 

Freezer and without TTD Ice Service ............................................................................. 5-12 

Table 5-9. Standards Case Market Share Scenarios: Refrigerator-Freezers with Side-Mount 

Freezer and with TTD Ice Service .................................................................................. 5-13 

Table 5-10. Base Case and Standards Case Average UECs for New Product Shipments: 

Refrigerator-Freezers with Top-Mount Freezer and without TTD Ice Service ................ 5-15 

Table 5-11. Base Case and Standards Case Average UECs for New Product Shipments: 

Refrigerator-Freezers with Side-Mount Freezer and with TTD Ice Service ..................... 5-17 

Table 5-12. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for 

New Product Shipments: Refrigerator-Freezers with Top-Mount Freezer and without 

TTD Ice Service ............................................................................................................. 5-19 

Table 5-13. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for 

New Product Shipments: Refrigerator-Freezers with Side-Mount Freezer and with 

TTD Ice Service ............................................................................................................. 5-21 

Table 5-14. Historical and Forecasted Electricity Prices ........................................................ 5-23 

Table 5-15. Site-to-Source Conversion Factors ..................................................................... 5-24 

Table 5-16. National Energy Savings and Net Present Value of Standards for RefrigeratorFreezers with Top-Mount Freezer and without TTD Ice Service & with Side-Mount 

Freezer and with TTD Ice Service (2010-2035) ............................................................. 5-26 

Table 6-1. Estimated Investments and Expenses to Reach Various Efficiency Levels, from 

1993 Standard Levels ....................................................................................................... 6-6 

v 
Table-2.Product and Equipment Measures Overview ............................................................6-8

Table 6-3. Refrigerator-Freezer Tax Incentives .......................................................................6-8

Table B- 1. Variable Statistics for Basic Side-Mount and Top-Mount Refrigerator -Freezers. B-1

Table B-2. Details of the "Long" Regression Analysis to determine the Energy Star Retail

Price Increment: Top-Mount Refrigerator-Freezers ............................................. B-2

Table B-3. Details of the "Long" Regression Analysis to determine the Energy Star Retail

Price Increment: Side-Mount Refrigerator-Freezers ............................................ B-3

Table C- l. Top-Mount Refrigerator-Freezer Matched Pairs ................................................. C-2

Table C-2. Side-Mount Refrigerator -Freezer Matched Pairs................................................. C-6

vi

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 6-2.Product and Equipment Measures Overview ............................................................ 6-8 

Table 6-3. Refrigerator-Freezer Tax Incentives ....................................................................... 6-8 

Table B-1. Variable Statistics for Basic Side-Mount and Top-Mount Refrigerator-Freezers. B-1 

Table B-2. Details of the "Long" Regression Analysis to determine the Energy Star Retail 

Price Increment: Top-Mount Refrigerator-Freezers ............................................. B-2 

Table B-3. Details of the "Long" Regression Analysis to determine the Energy Star Retail 

Price Increment: Side-Mount Refrigerator-Freezers ............................................ B-3 

Table C-L Top-Mount Refrigerator-Freezer Matched Pairs ................................................. C-2 

Table C-2. Side-Mount Refrigerator-Freezer Matched Pairs ................................................. C-6 

vi 
#4,7

LIST OF FIGURES

Figure 4-1. Illustration of LCC for Baseline and Standards ...................................................4-10

Figure 4-2. Flow Diagram of Life-Cycle Cost and Payback Period Analysis .........................4-11

Figure 4-3. Sales by Retail Price: Refrigerator-Freezers with Top-Mount Freezer................4-12

Figure 4-4. Sales by Retail Price: Refrigerator-Freezers with Side-Mount Freezer ...............4-13

Figure 4-5. Retail Prices for Refrigerator-Freezers with Top-Mount Freezer and without

TTD Ice Service .............................................................................................................4-19

Figure 4-6. Retail Prices for Refrigerator-Freezers with Side-Mount Freezer and with TTD

Ice Service .....................................................................................................................4-20

Figure 4-7. Forecasted Electricity Prices ...............................................................................4-29

Figure 4-8. Life-Cycle Costs: Top-Mount Refrigerator-Freezers without TTD Ice Service 4-34

Figure 4-9. Life-Cycle Costs: Side-Mount Refrigerator-Freezers with TTD Ice Service........4-34

Figure 5-1. Flow Diagram of National Energy Savings Calculation ........................................5-2

Figure 5-2. Flow Diagram of Net Present Value Calculation ...................................................5-4

Figure 5-3. Projection of Refrigerator-Freezer Shipments to 2035...........................................5-6

Figure 5-4. Base Case and Standards Case Average UECs for New Product Shipments:

Refrigerator-Freezers with Top-Mount Freezer and without TTD Ice Service ................5-16

Figure 5-5. Base Case and Standards Case Average UECs for New Product Shipments:

Refrigerator-Freezers with Side-Mount Freezer and with TTD Ice Service.....................5-18

Figure 5-6. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for

New Product Shipments: Refrigerator-Freezers with Top-Mount Freezer and without

TTD Ice Service .............................................................................................................5-20

Figure 5-7. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for

New Product Shipments: Refrigerator-Freezers with Side-Mount Freezer and with

TTD Ice Service .............................................................................................................5-22

Figure 5-8. National Energy Savings from Standards for Refrigerator-Freezers with TopMount Freezer and without TTD Ice Service & with Side-Mount Freezer and with

TTD Ice Service .............................................................................................................5-26

Figure 5-9. Net Present Value from Standards for Refrigerator-Freezers with Top-Mount

Freezer and without TTD Ice Service & with Side-Mount Freezer and with TTD Ice

Service ........................................................................................................................... 5-27

vii

 EE-PS-2006-001 COMMENT 04.7

#4.7 

LIST OF FIGURES 

Figure 4-1. Illustration of LCC for Baseline and Standards .................................................. .4-10 

Figure 4-2. Flow Diagram of Life-Cycle Cost and Payback Period Analysis ........................ .4-11 

Figure 4-3. Sales by Retail Price: Refrigerator-Freezers with Top-Mount Freezer. .............. .4-12 

Figure 4-4. Sales by Retail Price: Refrigerator-Freezers with Side-Mount Freezer .............. .4-13 

Figure 4-5. Retail Prices for Refrigerator-Freezers with Top-Mount Freezer and without 

TTD Ice Service ............................................................................................................. 4-19 

Figure 4-6. Retail Prices for Refrigerator-Freezers with Side-Mount Freezer and with TTD 

Ice Service ..................................................................................................................... 4-20 

Figure 4-7. Forecasted Electricity Prices .............................................................................. .4-29 

Figure 4-8. Life-Cycle Costs: Top-Mount Refrigerator-Freezers without TTD Ice Service ... .4-34 

Figure 4-9. Life-Cycle Costs: Side-Mount Refrigerator-Freezers with TTD Ice Service ....... .4-34 

Figure 5-1. Flow Diagram of National Energy Savings Calculation ........................................ 5-2 

Figure 5-2. Flow Diagram of Net Present Value Calculation ................................................... 5-4 

Figure 5-3. Projection of Refrigerator-Freezer Shipments to 2035 ........................................... 5-6 

Figure 5-4. Base Case and Standards Case Average UECs for New Product Shipments: 

Refrigerator-Freezers with Top-Mount Freezer and without TTD Ice Service ................ 5-16 

Figure 5-5. Base Case and Standards Case Average UECs for New Product Shipments: 

Refrigerator-Freezers with Side-Mount Freezer and with TTD Ice Service ..................... 5-18 

Figure 5-6. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for 

New Product Shipments: Refrigerator-Freezers with Top-Mount Freezer and without 

TTD Ice Service ............................................................................................................. 5-20 

Figure 5-7. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for 

New Product Shipments: Refrigerator-Freezers with Side-Mount Freezer and with 

TTD Ice Service ............................................................................................................. 5-22 

Figure 5-8. National Energy Savings from Standards for Refrigerator-Freezers with TopMount Freezer and without TTD Ice Service & with Side-Mount Freezer and with 

TTD Ice Service ............................................................................................................. 5-26 

Figure 5-9. Net Present Value from Standards for Refrigerator-Freezers with Top-Mount 

Freezer and without TTD Ice Service & with Side-Mount Freezer and with TTD Ice 

Service ........................................................................................................................... 5-27 

vii 
EXECUTIVE SUMMARY

The purpose of the analysis contained in this report is to provide the Department of

Energy (DOE or the Department) with updated information to use in scheduling a new amended

standards rulemaking for refrigerator-freezers in the 2006 appliance standards schedule setting

process. Congress initially established conservation standards for refrigerators-freezers that

became effective in 1990. The Department amended the standards with new standards that went

into effect in 1993, followed by the current amended standards that went into effect in 2001.

This analysis examines the technological and economic feasibility of new amended standards set

at existing Energy Star levels for the two most popular product classes of refrigerators: topmount refrigerator-freezers without through-the-door features and side-mount refrigeratorfreezers with through-the-door features.

This technical report contains six chapters:

Introduction

Market and Technology Assessment

Engineering Analysis

Life-Cycle Cost and Payback Period Analysis

National Impact Analysis

Manufacturer Impact Analysis

The executive summary provides an overview of the analysis and results presented in

Chapter 2 through Chapter 6 of this report.

Recently, Congress and the President passed and signed into law the Energy Policy Act

of 2005 (EPACT 2005). This report summarizes some of the energy-efficient product provisions

in EPACT 2005, but does not attempt to project the impact of these new provisions.

Market and Technology Assessment

Chapter 2 of this report presents the results of the market and technology assessment.

Refrigerators, refrigerator-freezers, and freezers (including compact refrigerators) currently have

an installed base in the United States of 183 million units and, collectively, have estimated

national annual energy consumption in 2004 of over one quad. Two product classes represent a

large proportion of total product shipments: (1) refrigerator-freezers with top-mount freezers and

without through-the-door (TTD) service and (2) refrigerator-freezers with side-mount freezers

and with TDD service. Consequently, the Department's assessment in this technical report

focuses on these top-mount and side-mount refrigerator-freezers product classes.

Table ES-1 shows the unit energy consumption (UEC) of typically-sized top-mount and

side-mount refrigerator-freezers. UECs are shown based on current DOE energy efficiency

standards as well as those that correspond to existing voluntary efficiency programs, including

Energy Star, the Federal Energy Management Program (FEMP), and the Consortium for Energy

Efficiency (CEE).

ES-1

 EE-PS-2006-001 COMMENT 04.7

#4.7 

EXECUTIVE SUMMARY 

The purpose of the analysis contained in this report is to provide the Department of 

Energy (DOE or the Department) with updated information to use in scheduling a new amended 

standards rulemaking for refrigerator-freezers in the 2006 appliance standards schedule setting 

process. Congress initially established conservation standards for refrigerators-freezers that 

became effective in 1990. The Department amended the standards with new standards that went 

into effect in 1993, followed by the current amended standards that went into effect in 2001. 

This analysis examines the technological and economic feasibility of new amended standards set 

at existing Energy Star levels for the two most popular product classes of refrigerators: topmount refrigerator-freezers without through-the-door features and side-mount refrigeratorfreezers with through-the-door features. 

This technical report contains six chapters: 

• Introduction 

• Market and Technology Assessment 

• Engineering Analysis 

• Life-Cycle Cost and Payback Period Analysis 

• National Impact Analysis 

• Manufacturer Impact Analysis 

The executive summary provides an overview of the analysis and results presented in 

Chapter 2 through Chapter 6 of this report. 

Recently, Congress and the President passed and signed into law the Energy Policy Act 

of 2005 (EP ACT 2005). This report summarizes some of the energy-efficient product provisions 

in EPACT 2005, but does not attempt to project the impact of these new provisions. 

Market and Technology Assessment 

Chapter 2 of this report presents the results of the market and technology assessment. 

Refrigerators, refrigerator-freezers, and freezers (including compact refrigerators) currently have 

an installed base in the United States of 183 million units and, collectively, have estimated 

national annual energy consumption in 2004 of over one quad. Two product classes represent a 

large propOltion of total product shipments: (1) refrigerator-freezers with top-mount freezers and 

without through-the-door (TTD) service and (2) refrigerator-freezers with side-mount freezers 

and with TDD service. Consequently, the Department's assessment in this technical report 

focuses on these top-mount and side-mount refrigerator-freezers product classes. 

Table ES-l shows the unit energy consumption (UEC) of typically-sized top-mount and 

side-mount refrigerator-freezers. UECs are shown based on current DOE energy efficiency 

standards as well as those that correspond to existing voluntary efficiency programs, including 

Energy Star, the Federal Energy Management Program (FEMP), and the Consortium for Energy 

Efficiency (CEE). 

ES-l 
®7

Table ES-i. Maximum UEC Values for Refrigerator-Freezers with Different

Specifications

DOE Efficiency Standard 486 671

FEMP 460 620

Current Energy Star (15% decrease) 413 570

CEE Tier 1 (20% decrease) 389 537

CEE Tier 2 (25% decrease) 364 503

CEE Tier 3 (30% decrease) 340 -469

* Auto defrost, no through-the-door features, 18.2 Cu. ft. total volume, and 21.4 Cu. ft. adjusted volume.

** Auto defrost, through-the-door features, 21.7 cu. ft. total volume, and 26.2 cu. ft. adjusted volume.

Technologies used to increase the energy efficiency of refrigerator-freezers include: highefficiency compressors; variable-capacity compressors; high-efficiency evaporator and

condenser fans; high-efficiency evaporator and condenser fan motors; eliminating thermal shorts;

improved door face frame/gasket design; smart defrost technology; added cabinet insulation;

lower-conductivity insulation; and vacuum panel insulation.

Engineering Analysis

Chapter 3 of this report presents the engineering analysis. The engineering analysis

addressed the design changes and the added manufacturing cost of producing more efficient

refrigerator-freezers. The Department analyzed two energy use reduction standard levels: (1) a

product with 15 percent less annual energy consumption than a product meeting current energy

conservation standards and (2) a product with 25 percent less annual energy consumption.

Refrigerator-freezers with 15 percent less energy consumption correspond to products meeting

current Energy Star requirements. Refrigerator-freezers with 25 percent less energy

consumption correspond to products meeting potential future Energy Star levels, assuming new

minimum efficiency standards are set at existing Energy Star levels.

The manufacturing cost assessment for the two improved efficiency levels primarily

relies upon information from three sources:

• The Department's initial review of the DOE 1995 Technical Support Document

(TSD);

Industry-average data collected in May 2005, from refrigerator manufacturers by the

Association of Home Appliance Manufacturers (ARAM) and provided to DOE; and

• Information provided by individual refrigerator manufacturers during interviews.

Analysis focused on top-mount and side-mount refrigerator-freezers, the two most

popular product classes.

ES-2

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table ES-l. Maximum VEC Values for Refrigerator-Freezers with Different 

Specifications 

413 

389 537 

364 503 

* Auto defrost, no through-the-door features, 18.2 cu. ft. total volume, and 21.4 cu. ft. adjusted volume. 

** Auto defrost, through-the-door features, 21.7 cu. fL total volume, and 26.2 cu. ft. adjusted volume. 

Technologies used to increase the energy efficiency of refrigerator-freezers include: highefficiency compressors; variable-capacity compressors; high-efficiency evaporator and 

condenser fans; high-efficiency evaporator and condenser fan motors; eliminating thermal shorts; 

improved door face frame/gasket design; smart defrost technology; added cabinet insulation; 

lower-conductivity insulation; and vacuum panel insulation. 

Engineering Analysis 

Chapter 3 of this report presents the engineering analysis. The engineering analysis 

addressed the design changes and the added manufacturing cost of producing more efficient 

refrigerator-freezers. The Depmtment analyzed two energy use reduction standard levels: (1) a 

product with 15 percent less annual energy consumption than a product meeting current energy 

conservation standards and (2) a product with 25 percent less annual energy consumption. 

Refrigerator-freezers with 15 percent less energy consumption correspond to products meeting 

CUlTent Energy Star requirements. Refrigerator-freezers with 25 percent less energy 

consumption correspond to products meeting potential future Energy Star levels, assuming new 

minimum efficiency standards are set at existing Energy Star levels. 

The manufacturing cost assessment for the two improved efficiency levels primarily 

relies upon information from three sources: 

• The Department's initial review of the DOE 1995 Technical Support Document 

(TSD); 

• Industry-average data collected in May 2005, from refrigerator manufacturers by the 

Association of Horne Appliance Manufacturers (AHAM) and provided to DOE; and 

• Information provided by individual refrigerator manufacturers during interviews. 

Analysis focused on top-mount and side-mount refrigerator-freezers, the two most 

popular product classes. 

ES-2 
Achieving 15 percent energy use reduction can be done with many typical refrigeratorfreezers through the use of higher-efficiency components. In order to achieve 25 percent energy

use reduction, significant cabinet load reduction is generally required, leading to entire redesign

of the units. While these changes are typical for many products, in many cases achieving the

targeted energy use can be more difficult, thus leading to more drastic changes for 15 percent

reduction and/or making redesign for 25 percent reduction impractical.

The manufacturing costs of achieving 15 percent and 25 percent energy use reductions

for typical 18.2 cu. ft. top-mount and 21.7 cu. ft. side-mount refrigerator-freezers, as reported in

the 1995 TSD (DOE 1995) and by the AHAM 2005 data collection effort, are summarized in

Table ES-2. The average AHAM cost premiums are production volume-weighted averages.

Table ES-2. 1995 TSD and AHAM Manufacturing Cost Estimates

15% Reduction (current Energy Star) Note 1

1995 TSD Cost Premium [$1992] $26 $40

2005 AHAM Cost Premium (min.-avg.-max.) $8 - $17 - $400 $5-$27-$95

25% Reduction Note 2

1995 TSD Cost Premium [$1992] No data $53

2005 AHAM Cost Premium (min.-avg.-max.) $18 - $54 - $141 $6 - $126 - $219

* Auto defrost, no through-the-door features, 18.2 cu. ft. total volume, and 21. 4 cu. ft. adjusted volume

** Auto defrost, through-the-door features, 21.7 cu. ft. total volume, and 26.2 cu. ft. adjusted volume.

Note 1: The energy use of this design package for the TSD cost premium estimate is 2 percent above Energy Star.

Note 2: The energy use of this design package for the TSD cost premium is 1 percent above the energy use target.

Life-Cycle Cost and Payback Period Analysis

Chapter 4 presents the life-cycle cost (LCC) and payback period (PBP) analysis. The

LCC and PBP analysis provide the Department with information on the economic impact of

potential energy conservation standards on consumers for refrigerator-freezers with 15 percent

less annual energy consumption than baseline products as well as refrigerator-freezers with 25

percent less annual energy consumption than the baseline product.

The Department calculated the LCC by adding the consumer retail price for the

refrigerator-freezer, plus lifetime electricity costs (discounted and summed over the life of the

refrigerator-freezer). The analysis compares the LCC of baseline products and more-efficient

products. The Department also calculated the PBP, which is the ratio of the increase in consumer

retail price due to a potential standard divided by the annual savings in electricity cost savings.

The Department calculated consumer retail prices based on the incremental

manufacturing costs determined from the engineering analysis as well as from a regression

analysis of price data from a large dataset of refrigerator-freezer sales data. Table ES-3 and

Table ES-4 show the consumer retail prices of top-mount and side-mount refrigerator-freezers,

respectively. Note that the retail prices based on the regression analysis were determined only at

the 15 percent less energy use level.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Achieving 15 percent energy use reduction can be done with many typical refrigeratorfreezers through the use of higher-efficiency components. In order to achieve 25 percent energy 

use reduction, significant cabinet load reduction is generally required, leading to entire redesign 

of the units. While these changes are typical for many products, in many cases achieving the 

targeted energy use can be more difficult, thus leading to more drastic changes for 15 percent 

reduction and/or making redesign for 25 percent reduction impractical. 

The manufacturing costs of achieving 15 percent and 25 percent energy use reductions 

for typical 18.2 cu. ft. top-mount and 21.7 cu. ft. side-mount refrigerator-freezers, as reported in 

the 1995 TSD (DOE 1995) and by the AHAM 2005 data collection effort, are summarized in 

Table ES-2. The average AHAM cost premiums are production volume-weighted averages. 

Table ES-2. 1995 TSD and AHAM Manufacturing Cost Estimates 

:;:~~% ;:',</a , I 1'op-Motfiit * I " Side-Mount **", 

15% Reduction (current Energy Star) Note 1 

1995 TSD Cost Premium [$1992] $26 $40 

2005 AHAM Cost Premium (min.-avg.-max.) $8 - $17 - $400 $5 - $27 - $95 

25% Reduction Note 2 

1995 TSD Cost Premium [$1992] No data $53 

2005 AHAM Cost Premium (min.-avg.-max.) $18 - $54 - $141 $6 - $126 - $219 

* Auto defrost, no through-the-door features, 18.2 cu. ft. total volume, and 21.4 cu. ft. adjusted volume 

** Auto defrost, through-the-door features, 21.7 cu. ft. total volume, and 26.2 cu. ft. adjusted volume. 

Note 1: The energy use of this design package for the TSD cost premium estimate is 2 percent above Energy Star. 

Note 2: The energy use of this design package for the TSD cost premium is 1 percent above the energy use target. 

Life-Cycle Cost and Payback Period Analysis 

Chapter 4 presents the life-cycle cost (LCC) and payback period (PBP) analysis. The 

LCC and PBP analysis provide the Department with information on the economic impact of 

potential energy conservation standards on consumers for refrigerator-freezers with 15 percent 

less annual energy consumption than baseline products as well as refrigerator-freezers with 25 

percent less annual energy consumption than the baseline product. 

The Department calculated the LCC by adding the consumer retail price for the 

refrigerator-freezer, plus lifetime electricity costs (discounted and summed over the life of the 

refrigerator-freezer). The analysis compares the LCC of baseline products and more-efficient 

products. The Department also calculated the PBP, which is the ratio of the increase in consumer 

retail price due to a potential standard divided by the annual savings in electricity cost savings. 

The Department calculated consumer retail prices based on the incremental 

manufacturing costs determined from the engineering analysis as well as from a regression 

analysis of price data from a large dataset of refrigerator-freezer sales data. Table ES-3 and 

Table ES-4 show the consumer retail prices of top-mount and side-mount refrigerator-freezers, 

respectively. Note that the retail prices based on the regression analysis were determined only at 

the 15 percent less energy use level. 

ES-3 
#4®7

Table ES-3. Consumer Retail Price and Retail Price Increases: Refrigerator-Freezers with

Top-Mount Freezer and without TTD Ice Service

21-22 cu. ft.

Mfg. t6s^Based -51 r F " j. ^' II

RETAIL PRICE (2005$)

Baseline $329 $386 $457

15% less energy $345 $367 $381 $356 $402 $420 $1186 $434 $477 '`$499 $531 $520

25% less energy $457 $704 $1047 NA $422 $494 $668 NA $537 $613 $735 NA

RETAIL PRICE INCREASE (2005$)

15% less energy $16 $38 $52 $28 $16 $35 $800 $49 $20 $42 $74 $63

25% less energy $128 $376 $718 NA $36 $108 $282 NA $80 $157 $278 NA

Table ES-4. Consumer Retail Price and Retail Price Increases: Refrigerator-Freezers with

Side-Mount Freezer and with TTD Ice Service

_..

• ^

1 ".t t i tW, 27-30 cu. ft.

.

77 UMLM ll min-T Avg. x.

RETAIL PRICE (2005$)

Baseline $702 $789 $926

15% less energy $712 $756 $892 $750 $799 $824 $999 $855 $10081 $1110 $1136 $1014

25% less energy $714 $955 $1140 NA $849 $988 $1399 NA Insufficient Data NA

RETAIL PRICE INCREASE (2005$)

15% less energy $10 $54 $190 $47 $10 $35 $210 $66 $82 $184 $210 $88

25% less energy $12 $253 $438 NA $60 $199 $610 NA Insufficient Data NA

Table ES-5 and ES-6 show the LCCs, LCC savings, and PBPs for the 15 percent and 25

percent less energy use standard levels for top-mount and side-mount refrigerator-freezers. LCC

presented in these tables is based on a discount rate of 6.7 percent and product lifetime of 19

years.

Table ES-5. LCC, LCC Savings, and Payback Periods: Refrigerator-Freezers with TopMount Freezer and without TTD Ice Service

MIT" L",-MAR ) F X,"

LCC (2005$)

Baseline $754 $849 $951

15% less energy $706 $729 $742 $718 $795 $814 $1579 $828 $897 $919 $951 $940

25% less energy $776 $1023 $1366 NA $769 $841 $1015 NA $907 $984 $1105 NA

LCC SAVINGS (2005$)

15% less energy $48 $26 $12 $36 $53 $35 (`S73 1) $21 $54 $32 $0 $11

25% less energy $22) ($269) (`'612) NA $80 $8 'S i (S NA $43 ($33) ($155) NA

PAYBACK PERIOD (years)

15% less energy 2.9 6.9 9.5 5.0 2.7 5.8 133.9 8.1 3.1 6.7 11.6 10.0

25% less energy 14.0 41.1 78.5 NA 3.6 10.9 28.3 NA 7.5 14.7 26.2 NA

ES-4

 EE-PS-2006-001 COMMENT 04.7

Table ES-3. Consumer Retail Price and Retail Price Increases: Refrigerator-FreezerS}With 

Top-Mount Freezer and without TTD Ice Service 

Table ES-4. Consumer Retail Price and Retail Price Increases: Refrigerator-Freezers With 

Side-Mount Freezer and with TTD Ice Service 

Table ES-5 and ES-6 show the LCCs, Lee savings, and PBPs for the 15 percent and 25 

percent less energy use standard levels for top-mount and side-mount refrigerator-freezers. Lee 

presented in these tables is based on a discount rate of 6.7 percent and product lifetime of 19 

years. 

Table ES-S. LCC, LCC Savings, and Payback Periods: Refrigerator-Freezers with TopMount Freezer and without TTD Ice Service 

"" !&¢ (j ~?~ 4""~ 14-1'icp.. ft>0 " ~ ~;; ~ 'llf~ '2 18-20lbt~" ~ 21-22 cu. ft ');:i ~0 

~1% x Regress.; Regress.- Mfg. Cost-Based Reg~ss- 0 

~ ,,~ Min. Avg. ~lMin. ~ Based "0 Min. Avg. Max. Based Min. Avg. Max. Based 

LCC (2005$) 

Baseline $754 $849 $951 

15% less energy $706 I $729 I $742 I $718 $7951 $814 I $1579 I $828 $8971 $919 I $951 I $940 

25% less energy $776 I $1023 I $1366 I NA $7691 $841 I $1015 I NA $9071 $984 1$11051 NA 

LCC SA VINGS (2005$) 

15% less energy $48 I $26 I $12 I $36 II $53 I $35 I ($731) I $21 $54 I $32 I $0 I $11 

25 % less energ}' ($22) I ($269) I (1;612) I NA $80 I $8 I (,; 'S"(, hn) I NA $43 I ($33) 1($[55)1 NA 

PAYBACK PERIOD (years) 

15% less energy 2.9 I 6.9 I 9.5 I 5.0 2.7 I 5.8 I 133.9 I 8.1 3.1 I 6.7 I 11.6 I 10.0 

25% less energy 14.0 I 41.1 I 78.5 I NA 3.6 I 10.9 I 28.3 I NA 7.5 I 14.7 1 26.2 I NA 

ES-4 
#4o7

Table ES-6. LCC, LCC Savings, and Payback Periods: Refrigerator-Freezers with SideMount Freezer and with TTD Ice Service

Baseline $1338 $1463 $1641

15% less energy $1253 $1296 $1433 $1290 $1372 $1398 $1572 $1428 $1615 $1717 $1743 $1621

25% less energy $1191 $1432 $1617 NA $1355 $1494 $1905 NA Insufficient Data NA

LCC SAVINGS (2005$)

15% less energy $85 $42 (S95) $48 $91 $66 (5.109) $35 $25 ($77) ($.103) $19

25% less energy $147 ($94) ($279) NA $109 ($31) ($4.41) NA Insufficient Data NA

PAYBACK PERIOD (years)

15% less energy 1.2 6.6 23.2 5.8 1.1 4.1 24.1 7.6 8.9 19.9 22.8 9.6

25% less energy 0.9 18.5 32.1 NA 4.1 13.7 42.1 NA 11 Insufficient Data NA

Reviewing the results of the LCC and PBP analysis, the Department identified the

following:

• With certain exceptions, LCC savings are generally realized at the 15 percent less

energy use standard level;

• With certain exceptions, LCC savings are not achieved at the 25 percent less energy

use standard level;

• With certain exceptions, PBPs of less than half the lifetime of the product are realized

at the 15 percent less energy use standard level; and

• With certain exceptions, PBPs exceed well over half the lifetime of the product at the

25 percent less energy use standard level.

National Impact Analysis

Chapter 5 presents the national impact analysis, consisting of the determination of

national energy savings (NES) and national net present value (NPV) from an energy

conservation (or efficiency) standard that would require refrigerator-freezers to use 15 percent

less energy than current baseline models. For purposes of this analysis, the Department assumed

the effective date of such a standard would be the year 2010. The Department calculated the

NES and NPV based on an analysis period of 2010 through 2035.

In preparing this analysis, the Department found that the most critical input to the

national impact analysis is the market share of future Energy Star products. For a new amended

energy conservation standard set at current Energy Star levels (i.e., 1.5 less energy consumption),

the Department assumed the future Energy Star level has 25 percent less energy consumption

than current baseline products. Because it is difficult to forecast the market share of products

once a new standard becomes effective, the Department analyzed the following two market share

scenarios: (1) a No Future Energy Star scenario where 100 percent of the market is assumed to

be at the new standard level (which is equivalent to the current Energy Star level), and (2) a

ES-5

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table ES-6. Lee, Lee Savings, and Payback Periods: Refrigerator-Freezers with SideMount Freezer and with TTD Ice Service 

Reviewing the results of the LCC and PBP analysis, the Department identified the 

following: 

• With certain exceptions, LCC savings are generally realized at the 15 percent less 

energy use standard level; 

• With certain exceptions, LCC savings are not achieved at the 25 percent less energy 

use standard level; 

• With certain exceptions, PBPs of less than half the lifetime of the product are realized 

at the 15 percent less energy use standard level; and 

• With certain exceptions, PBPs exceed well over half the lifetime of the product at the 

25 percent less energy use standard level. 

National Impact Analysis 

Chapter 5 presents the national impact analysis, consisting of the determination of 

national energy savings (NES) and national net present value (NPV) from an energy 

conservation (or efficiency) standard that would require refrigerator-freezers to use 15 percent 

less energy than current baseline models. For purposes of this analysis, the Department assumed 

the effective date of such a standard would be the year 2010. The Department calculated the 

NBS and NPV based on an analysis period of 2010 through 2035. 

In preparing this analysis, the Department found that the most critical input to the 

national impact analysis is the market share of future Energy Star products. For a new amended 

energy conservation standard set at current Energy Star levels (i.e., 15 less energy consumption), 

the Department assumed the future Energy Star level has 25 percent less energy consumption 

than current baseline products. Because it is difficult to forecast the market share of products 

once a new standard becomes effective, the Department analyzed the following two market share 

scenarios: (1) a No Future Energy Star scenario where 100 percent of the market is assumed to 

be at the new standard level (which is equivalent to the current Energy Star level), and (2) a 

ES-5 
#4®7

Current Energy Star scenario where market shares of current and future Energy Star are assumed

to be equivalent to the market shares of current baseline and current Energy Star products.

Table ES-7 summarizes the NES and NPV results. Results of the national impact

analysis are provided for the two standards case scenarios (No Future Energy Star and Current

Energy Star), the two retail price estimates (manufacturing cost-based or regression analysisbased), and the two discount rates (three percent and seven percent real) considered for the

national impact analysis. Because the Department could not use the regression analysis to

generate prices for products with 25 percent less energy consumption, regression analysis-based

retail prices are applicable only to the No Future Energy Star scenario.

For the No Future Energy Star standards case scenario, the NES due to standards for topmount and side-mount refrigerator-freezers are 2.4 quads of primary energy (1.1 quads from topmount refrigerator-freezers and 1.3 quads from side-mount refrigerator-freezers). For the

Current Energy Star standards case scenario, the savings are 3.4 quads of primary energy (1.3

quads from top-mount refrigerator-freezers and 2.1 quads from side-mount refrigerator-freezers).

The NPV of standards depends on the scenario, the retail price estimate, and the discount

rate. For a discount rate of three percent real, both standards case scenarios have a positive NPV.

The NPV of the No Future Energy Star scenario is $10.1 billion with manufacturing cost-based

retail prices and $8.0 billion with regression-based retail prices. The NPV of the Current Energy

Star scenario is $3.3 billion. For a discount rate of seven percent real, the No Future Energy Star

scenario still yields a positive NPV, $3.3 billion with manufacturing cost-based prices and $2.2

billion with regression-based prices, but the NPV under the Current Energy Star scenario

becomes negative at -$1.2 billion.

The Current Energy Star scenario yields the greatest energy savings because of the

assumed market share of future Energy Star products. But because of the significant retail price

increase associated with future Energy Star products, the NPV of the Current Energy Star

scenario is significantly lower than the NPV of the No Future Energy Star scenario.

Table ES-7. National Energy Savings and Net Present Value of Standards for

Refrigerator-Freezers with Top-Mount Freezer and without TTD Ice Service & with SideMount Freezer and with TTD Ice Service (2010-2035)

_1 r1 1 I ` .. NPV ,

J1 e

S

Mfg. Cost 3 2 4

$4.0 $6.0 $10.1 No Future Energy tar 1.1 1. . Regress. 3% $3.3 $4.7 $8.0

Current Energy Star Mfg. Cost 1.3 2.1 3.4 $2.4 $0.9 $3.3

N F t E St Mfg. Cost 1 1 1 3 2 4

$1.3 $2.0 $3.3

o u ure nergy ar . . .

Regress. 7% $0.9 $1.3 $2.2

Current Energy Star ! Mfg. Cost 1.3 2.1 3.4 $0.2 ($1.4) ($1.2)

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Current Energy Star scenario where market shares of current and future Energy Star are assumed 

to be equivalent to the market shares of current baseline and current Energy Star products. 

Table ES-7 summarizes the NES and NPV results. Results of the national impact· 

analysis are provided for the two standards case scenarios (No Future Energy Star and Current 

Energy Star), the two retail price estimates (manufacturing cost-based or regression analysisbased), and the two discount rates (three percent and seven percent real) considered for the 

national impact analysis. Because the Department could not use the regression analysis to 

generate prices for products with 25 percent less energy consumption, regression analysis-based 

retail prices are applicable only to the No Future Energy Star scenario. 

For the No Future Energy Star standards case scenario, the NES due to standards for topmount and side-mount refrigerator-freezers are 2.4 quads of primary energy (1.1 quads from topmount refrigerator-freezers and 1.3 quads from side-mount refrigerator-freezers). For the 

Current Energy Star standards case scenario, the savings are 3.4 quads of primary energy (1.3 

quads from top-mount refrigerator-freezers and 2.1 quads from side-mount refrigerator-freezers). 

The NPV of standards depends on the scenario, the retail price estimate, and the discount 

rate. For a discount rate of three percent real, both standards case scenarios have a positive NPV. 

The NPV of the No Future Energy Star scenario is $10.1 billion with manufacturing cost-based 

retail prices and $8.0 billion with regression-based retail prices. The NPV of the Current Energy 

Star scenario is $3.3 billion. For a discount rate of seven percent real, the No Future Energy Star 

scenario still yields a positive NPV, $3.3 billion with manufacturing cost-based prices and $2.2 

billion with regression-based prices, but the NPV under the Current Energy Star scenario 

becomes negative at -$1.2 billion. 

The Current Energy Star scenario yields the greatest energy savings because of the 

assumed market share of future Energy Star products. But because of the significant retail price 

increase associated with future Energy Star products, the NPV of the Current Energy Star 

scenario is significantly lower than the NPV of the No Future Energy Star scenario. 

Table ES-7. National Energy Savings and Net Present Value of Standards for 

Refrigerator-Freezers with Top-Mount Freezer and without TTD Ice Service & with SideMount Freezer and with TTD Ice Service (2010-2035) 

ES-6 
Manufacturer Impact Analysis

Chapter 6 presents the Department's assessment of the impact of regulations on U.S.

manufacturers of refrigerator-freezers. The Department carried out a preliminary evaluation of

the impact of potential new regulations on manufacturer financial performance, domestic

refrigerator-freezer manufacturing capacity and employment levels, and product utility and

innovation. A primary focus was to identify the cumulative burden that industry faces from the

overlapping effect of new or recent DOE standards and/or other regulatory action affecting the

same product or industry. The primary sources of information for this evaluation were the

structured interviews conducted in 2005 with manufacturers of refrigerator-freezers.

The Department received manufacturers' views on what they perceived to be the possible

impact of potential new amended standards on their future profitability, especially in the context

of the current standards, which have only been in effect since 2001. As stated by manufacturers,

new amended energy efficiency standards have the potential to impact financial performance in

several different ways. The capital investment needed to upgrade or redesign products and

product platforms before they have reached the end of their useful life can require conversion

costs that otherwise would not be expended, resulting in stranded investments. In addition,

higher efficiency standards can result in higher per-unit costs that may deter some customers

from buying higher-margin units with more features, thereby decreasing manufacturer

profitability. Manufacturers stated that the prospect of product redesign as a result of new

amended standards penalizes established manufacturers and alters the playing field for entry to

the market by new competitors who do not carry debt burdens from recent investments in new

product lines. In their view, this can decrease the relative barrier to entry of competitors into the

market, which can increase market competition, reduce incumbent manufacturer profitability,

and decrease U.S.-based production.

Typically, in the absence of new energy efficiency regulations, a refrigerator-freezer

production line would have a life cycle of approximately 15 to 20 years. During that period,

manufacturers would not make major product changes that altered the underlying platforms.

Thus, a standard that took effect and resulted in a major product platform redesign before the end

of the platform's life would cannibalize a portion. of the earlier capital investments. Based on

discussions with manufacturers, most have made significant capital investments to meet the DOE

efficiency standard levels that took effect in 2001 and a new standard that required platform

changes could strand assets before the end of their useful life. The 1995 TSD estimated the

capital conversion costs for the 2001 standard at approximately 725 million dollars. Based on

the interviews, this figure is low by a factor of two compared to the actual level of investment by

the refrigerator-freezer industry in the years leading up to and immediately following the 2001

standards implementation. It must be noted, however, that not all of these costs can be attributed

to efficiency standards since the platform changes entailed other product enhancements and cost

reduction initiatives.

The Department asked manufacturers what level of conversion costs they anticipated if a

new efficiency standard required a 15 percent reduction in unit energy consumption relative to

the current standard. The level of expected conversion costs varied widely between

manufacturers, depending on such factors as the energy performance of their current products,

whether their current products could achieve the 15 percent reduction via component-level

ES-7

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Manufacturer Impact Analysis 

Chapter 6 presents the Department's assessment of the impact of regulations on U.S. 

manufacturers of refrigerator-freezers. The Department carried out a preliminary evaluation of 

the impact of potential new regulations on manufacturer financial performance, domestic 

refrigerator-freezer manufacturing capacity and employment levels, and product utility and 

innovation. A primary focus was to identify the cumulative burden that industry faces from the 

overlapping effect of new or recent DOE standards and/or other regulatory action affecting the 

same product or industry. The primary sources of information for this evaluation were the 

structured interviews conducted in 2005 with manufacturers of refrigerator-freezers. 

The Department received manufacturers' views on what they perceived to be the possible 

impact of potential new amended standards on their future profitability, especially in the context 

of the current standards, which have only been in effect since 2001. As stated by manufacturers, 

new amended energy efficiency standards have the potential to impact financial performance in 

several different ways. The capital investment needed to upgrade or redesign products and 

product platforms before they have reached the end of their useful life can require conversion 

costs that otherwise would not be expended, resulting in stranded investments. In addition, 

higher efficiency standards can result in higher per-unit costs that may deter some customers 

from buying higher-margin units with more features, thereby decreasing manufacturer 

profitability. Manufacturers stated that the prospect of product redesign as a result of new 

amended standards penalizes established manufacturers and alters the playing field for entry to 

the market by new competitors who do not carry debt burdens from recent investments in new 

product lines. In their view, this can decrease the relative barrier to entry of competitors into the 

market, which can increase market competition, reduce incumbent manufacturer profitability, 

and decrease U.S.-based production. 

Typically, in the absence of new energy efficiency regulations, a refrigerator-freezer 

production line would have a life cycle of approximately 15 to 20 years. During that period, 

manufacturers would not make major product changes that altered the underlying platforms. 

Thus, a standard that took effect and resulted in a major product platform redesign before the end 

of the platform's life would cannibalize a portion of the earlier capital investments. Based on 

discussions with manufacturers, most have made significant capital investments to meet the DOE 

efficiency standard levels that took effect in 2001 and a new standard that required platform 

changes could strand assets before the end of their useful life. The 1995 TSD estimated the 

capital conversion costs for the 2001 standard at approximately 725 million dollars. Based on 

the interviews, this figure is low by a factor of two compared to the actual level of investment by 

the refrigerator-freezer industry in the years leading up to and immediately following the 2001 

standards implementation. It must be noted, however, that not all of these costs can be attributed 

to efficiency standards since the platform changes entailed other product enhancements and cost 

reduction initiatives. 

The Department asked manufacturers what level of conversion costs they anticipated if a 

new efficiency standard required a 15 percent reduction in unit energy consumption relative to 

the current standard. The level of expected conversion costs varied widely between 

manufacturers, depending on such factors as the energy performance of their current products, 

whether their current products could achieve the 15 percent reduction via component-level 

ES-7 
#4,7

modifications or needed platform modifications, and the extent to which manufacturers expected

to upgrade their platforms to allow for a future Energy Star level. At a minimum, a typical

manufacturer would need to spend approximately 30 million dollars if no platform redesigns

were needed. More likely, some manufacturers would need some level of platform redesign to

reach a 15 percent improvement, particularly when the investments are taken in the context of

future Energy Star levels. The potential for costs on the order of several hundred million dollars

exists if even a single major manufacturer's product platforms undergo a full redesign. When

asked to quantify the investments engendered by a 25 percent efficiency improvement,

manufacturers referred to the investment level required by the 2001 standard and gave estimates

totaling well over one billion dollars.

Several manufacturers indicated that a new standard level. would cause existing pressures

on margins and profitability to increase because only a limited portion of customers are willing

to pay more for energy efficiency. Manufacturers believe that they could not pass on to

customers all of the cost increases required to meet the standard, since historically, the appliance

industry has not been able to recoup standards-induced capital costs in prices. Manufacturers

reported that industry margins have actually decreased over time, since large manufacturers are

willing to reduce margins to increase volumes because they need certain volumes to operate

efficiently.

In addition, several manufacturers noted that a new energy-efficiency standard would

facilitate the entry of foreign competitors into the U.S. market. Without a new standard, a new

manufacturer would need to make large capital investments to build production capacity, - -

investments that existing manufacturers would not need to make. In the case of a new standard,

however, most manufacturers would need to carry out product platform redesigns for some of

their products to meet the new standard. This would neutralize much of the cost advantage from

existing infrastructure that current manufacturers have relative to new, foreign-based

manufacturers.

Over the past several years, some refrigerator-freezer manufacturers have moved a

portion of their production out of the U.S., primarily driven by concerns about profitability and

the opportunity for lower labor costs. Mexico is the most common location for both U.S. and

foreign manufacturers to establish new production capacity to serve the U.S. refrigerator-freezer

market, as it offers low labor rates (relative to the U.S.) and proximity to the U.S. market. Based

on information obtained through the interviews, the Department estimates that approximately 25

percent of all residential refrigerator-freezers sold in the U.S. are manufactured in Mexico and

that this portion is likely to increase within a few years. Manufacturers indicated they anticipate

that new standards would accelerate the trend to manufacture refrigerator-freezers outside of the

country. Amended standards may alter the rate at which refrigerator-freezer production is moved

to Mexico because if manufacturers need to make large capital investments to produce

redesigned product platforms, they have strong financial. incentives to invest in a location with

lower labor costs. Given manufacturers' perceived need to offer Energy Star products, a new

standard that requires a 15 percent reduction in unit energy may initiate the platform changes

necessitating investment levels that would accelerate relocation of U.S. based manufacturing to

Mexico

 EE-PS-2006-001 COMMENT 04.7

#4.7 

modifications or needed platform modifications, and the extent to which manufacturers·expected 

to upgrade their platforms to allow for a future Energy Star level. At a minimum, a typiCal 

manufacturer would need to spend approximately 30 million dollars if no platform redes~gns 

were needed. More likely, some manufacturers would need some level of platform redesign to 

reach a 15 percent improvement, particularly when the investments are taken in the context of 

future Energy Star levels. The potential for costs on the order of several hundred million dollars 

exists if even a single major manufacturer's product platforms undergo a full redesign. When 

asked to quantify the investments engendered by a 25 percent efficiency improvement, 

manufacturers referred to the investment level required by the 2001 standard and gave estimates 

totaling well over one billion dollars. 

Several manufacturers indicated that a new standard level would cause existing pressures 

on margins and profitability to increase because only a limited portion of customers are willing 

to pay more for energy efficiency. Manufacturers believe that they could not pass on to 

customers all of the cost increases required to meet the standard, since historically, the appliance 

industry has not been able to recoup standards-induced capital costs in prices. Manufacturers 

reported that industry margins have actually decreased over time, since large manufacturers are 

willing to reduce margins to increase volumes because they need certain volumes to operate 

efficiently. 

In addition, several manufacturers noted that a new energy-efficiency standard would 

facilitate the entry of foreign competitors into the U.S. market. Without a new standard, a new 

manufacturer would need to make large capital investments to build production capacity, --

investments that existing manufacturers would not need to make. In the case of a new standard, 

however, most manufacturers would need to carry out product platform redesigns for some of 

their products to meet the new standard. This would neutralize much of the cost advantage from 

existing infrastructure that current manufacturers have relative to new, foreign-based 

manufacturers. 

Over the past several years, some refrigerator-freezer manufacturers have moved a 

portion of their production out of the U.S., primarily driven by concerns about profitability and 

the 0ppOltunity for lower labor costs. Mexico is the most common location for both U.S. and 

foreign manufacturers to establish new production capacity to serve the U.S. refrigerator-freezer 

market, as it offers low labor rates (relative to the U.S.) and proximity to the U.S. market. Based 

on information obtained through the interviews, the Department estimates that approximately 25 

percent of all residential refrigerator-freezers sold in the U.S. are manufactured in Mexico and 

that this portion is likely to increase within a few years. Manufacturers indicated they anticipate 

that new standards would accelerate the trend to manufacture refrigerator-freezers outside of the 

country. Amended standards may alter the rate at which refrigerator-freezer production is moved 

to Mexico because if manufacturers need to make large capital investments to produce 

redesigned product platforms, they have strong financial incentives to invest in a location with 

lower labor costs. Given manufacturers' perceived need to offer Energy Star products, a new 

standard that requires a 15 percent reduction in unit energy may initiate the platform changes 

necessitating investment levels that would accelerate relocation of U.S. based manufacturing to 

Mexico 

ES-8 
When assessing the benefits and burdens of a potential revision of product energy

standard levels, the Department considers the regulatory burden that will impact the

manufacturers of the product at or around the time the new standards would come into effect.

Based on its own research and discussions with manufacturers, the Department identified several

existing or pending regulations relevant to residential refrigerators, including:

® Existing energy efficiency standard for refrigerator-freezers

® Insulation blowing agent phase out

Energy efficiency standards for other products made by the same manufacturers

® State energy efficiency standards

® International energy efficiency standards

® Waste disposal and recycling requirements

Complying with these regulations requires that corporations invest both human and

capital resources.

In addition to the above, provisions of the recent Energy Policy Act of 2005 may have

some impact on manufacturers; particularly the State consumer rebates for Energy Star products

and the federal manufacturer tax incentives. This report summarizes some of the energyefficient product provisions in EPACT 2005, but does not attempt to project the impact of these

new provisions.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

When assessing the benefits and burdens of a potential revision of product energy 

standard levels, the Department considers the regulatory burden that will impact the 

manufacturers of the product at or around the time the new standards would corne into effect. 

Based on its own research and discussions with manufacturers, the Department identified several 

existing or pending regulations relevant to residential refrigerators, including: 

• Existing energy efficiency standard for refrigerator-freezers 

• Insulation blowing agent phase out 

• Energy efficiency standards for other products made by the same manufacturers 

• State energy efficiency standards 

• International energy efficiency standards 

• Waste disposal and recycling requirements 

Complying with these regulations requires that corporations invest both human and 

capital resources. 

In addition to the above, provisions of the recent Energy Policy Act of 2005 may have 

some impact on manufacturers; particularly the State consumer rebates for Energy Star products 

and the federal manufacturer tax incentives. This report summarizes some of the energyefficient product provisions in EPACT 2005, but does not attempt to project the impact of these 

new provisions. 

ES-9 
CHAPTER 1. INTRODUCTION

Congress initially established standards for residential refrigerators, refrigerator-freezers,

and freezers that became effective in 1990. The Department amended the standards with new

standards that went into effect in 1993, followed by the current amended standards that went into

effect in 2001.

In April 2005, the Department granted a petition to conduct a rulemaking on new

amended standards for residential refrigerator-freezers, based on meeting petition criteria set

forth at 42 U.S.C. § 6295(n). However, the granting of the petition creates no presumption with

respect to the Secretary's determination of whether a rulemaking meets the more rigorous criteria

for amending standards. Since the Department's most recent analytical data is now ten years old

(1995 TSD), the Department decided to conduct some limited new analyses to provide the

Secretary of Energy with current information to use in scheduling a rulemaking on amending

refrigerator-freezers standards in the 2006 appliance standards schedule setting process. This

analysis examines the technological and economic feasibility of new standards set at existing

Energy Star levels for the two most popular product classes of refrigerators: top-mount

refrigerator-freezers without through-the-door features and side-mount refrigerator-freezers with

through-the-door features. Because these two product classes account for over 85 percent of

current product shipments, the Department confined its updated analysis to these two classes.

This report contains chapters on the following analyses:

• Market and Technology Assessment - Assesses the current U.S. market of refrigeratorfreezers and identifies and assesses technologies for reducing refrigerator-freezer annual

energy consumption. An assessment and status of the current test procedure is also

provided.

• Engineering Analysis - Determines the incremental manufacturing cost of achieving

annual energy use reductions of 15 and 25 percent relative to baseline products (i.e.,

products meeting current minimum efficiency standards). The 15 percent less energy use

level corresponds to existing Energy Star levels. The 25 percent less energy use level

corresponds to expected future Energy Star levels assuming new standards are set at

existing Energy Star levels.

• Life-Cycle Cost and Payback Period Analysis - Determines the life-cycle cost (LCC)

savings and payback periods of more efficient products based on: (1) incremental

manufacturing costs determined from the Engineering Analysis and (2) incremental

consumer retail prices from a regression analysis performed on a large data set of

refrigerator sales data.

• National Impact Analysis - Determines the national energy savings (NES) and consumer

net present value (NPV) of new standards set at existing Energy Star levels. Because the

NES and NPV are dependent on the market share of expected future Energy Star

products, results are provided for two market share scenarios; (1) no future Energy Star

1-1

 EE-PS-2006-001 COMMENT 04.7

#4.7 

CHAPTER 1. INTRODUCTION 

Congress initially established standards for residential refrigerators, refrigerator-freezers, 

and freezers that became effective in 1990. The Department amended the standards: with new 

standards that went into effect in 1993, followed by the current amended standards that went into 

effect in 2001. 

In April 2005, the Department granted a petition to conduct a rulemaking orihew 

amended standards for residential refrigerator-freezers, based on meeting petition criteria set 

forth at 42 U.S.C. § 6295(n). However, the granting of the petition creates no presumption with 

respect to the Secretary's determination of whether a ru1emaking meets the more rigorous criteria 

for amending standards. Since the Department's most recent analytical data is now ten years old 

(1995 TSD), the Department decided to conduct some limited new analyses to provide the 

Secretary of Energy with current information to use in scheduling a rulemaking on amending 

refrigerator-freezers standards in the 2006 appliance standards schedule setting process. This 

analysis examines the technological and economic feasibility of new standards set a.texisting 

Energy Star levels for the two most popular product classes of refrigerators: top-mount 

refrigerator-freezers without through-the-door features and side-mount refrigerator:'freezers with 

through-the-door features. Because these two product classes account for over 85 percent of 

cun-ent product shipments, the Department confined its updated analysis to these two classes. 

This report contains chapters on the following analyses: 

• Market and Technology Assessment - Assesses the cun'ent U.S. market of refrigeratorfreezers and identifies and assesses technologies for reducing refrigerator-freezer annual 

energy consumption. An assessment and status of the current test procedure is also 

provided. 

• Engineering Analysis - Determines the incremental manufacturing cost of achieving 

annual energy use reductions of 15 and 25 percent relative to baseline products (i.e., 

products meeting current minimum efficiency standards), The 15 percent less energy use 

level corresponds to existing Energy Star levels. The 25 percent less energy use level 

corresponds to expected future Energy Star levels assuming new standards are set at 

existing Energy Star levels. 

• Life-Cycle Cost and Payback Period Analysis - Determines the life-cycle cost (LCC) 

savings and payback periods of more efficient products based on: (1) incremental 

manufacturing costs determined from the Engineering Analysis and (2) incremental 

consumer retail prices from a regression analysis performed on a large data set of 

refrigerator sales data. 

• National Impact Analysis - Determines the national energy savings (NES) and consumer 

net present value (NPV) of new standards set at existing Energy Star levels. Because the 

NES and NPV are dependent on the market share of expected future Energy Star 

products, results are provided for two market share scenarios; (1) no future Energy Star 

1-1 
products and (2) future Energy Star product market shares equal to current market shares

of existing Energy Star products.

Manufacturer Impact Analysis - Determines the qualitative impacts to manufacturers of

new standards set at existing Energy Star levels.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

products and (2) future Energy Star product market shares equal to current market shares 

of existing Energy Star products. 

• Manufacturer Impact Analysis - Determines the qualitative impacts to manufacturers of 

new standards set at existing Energy Star levels. 

1-2 
#®7

CHAPTER 2. MARKET AND TECHNOLOGY ASSESSMENT

2.1 MARKET ASSESSMENT

Refrigerators, refrigerator-freezers, and freezers are major household appliances designed

for the refrigerated storage of food products. In 2001, 96 percent of households had at least one

refrigerator or refrigerator-freezer. A refrigerator consists of a refrigerated cabinet designed for

the refrigerated storage of food at temperatures above 0°C (32°F) and below 3.9°C (39°F),

configured for general refrigerated food storage, and having a source of refrigeration requiring

single phase, alternating current electric energy input only. A refrigerator may include a

compartment for the storage of food at temperatures below 0°C (32°F), but does not provide a

separate low temperature compartment designed for freezing and storage of food at temperatures

below -13.3°C (8°F). A refrigerator-freezer is a cabinet which consists of at least one

compartment designed for the refrigerated storage of food at temperatures above 0°C (32°F) and

at least one other compartment designed for the freezing and storage of food at temperatures

below -13.3°C (8°F). Top and bottom refrigerator-freezers have a horizontal partition between

the freezer and refrigerator sections, with the freezer located above and below the refrigerator

section, respectively. In contrast, side-mount units have a vertical partition between the freezer

and refrigerator sections, with one on the right and the other on the left side of the unit. A

freezer consists of a cabinet for the storage and freezing of foods at -17.8°C (0°F) or below.

Compact refrigerators are defined by the DOE as having less than a 7.75 cubic foot capacity and

36 inches or less in height. The sales of compact refrigerators have increased appreciably in the

last several years. While most seem to be sold to residential consumers, significant amounts are

also prevalent in non-residential applications such as hotels, dormitories and offices.

Refrigerators and refrigerator-freezers account for about 83 percent of the annual energy

consumption (AEC) and 78 percent of the installed base of residential refrigeration products (see

Table 2-1).'

Table 2-1. Energy Consumption of Residential Refrigeration Equipment

Installed Base (millions)

Refrigerators & Refrigerator-Freezers

Freezers

Compact Refrigerators

Source: DOE FY-2005 Priority Setting TSD.

0.86

0.14

0.04

142

Based on data from the Association of Home Appliance Manufacturers (AHAM),

refrigerator-freezer shipments are much greater than refrigerator shipments.2 In addition, topmount and bottom-mount refrigerator-freezers historically have had approximately twice the

sales volume of side-mount products (see Table 2-2).

 EE-PS-2006-001 COMMENT 04.7

#4.7 

CHAPTER 2. MARKET AND TECHNOLOGY ASSESSMENT 

2.1 MARKET ASSESSMENT 

Refrigerators, refrigerator-freezers, and freezers are major household appliances designed 

for the refrigerated storage of food products. In 2001, 96 percent of households had at least one 

refrigerator or refrigerator-freezer. A refrigerator consists of a refrigerated cabinet designed for 

the refrigerated storage of food at temperatures above O°C (32°F) and below 3.9°C (39°F), 

configured for general refrigerated food storage, and having a source of refrigeration requiring 

single phase, alternating current electric energy input only. A refrigerator may include a 

compartment for the storage of food at temperatures below O°C (32°F), but does not provide a 

separate low temperature compartment designed for freezing and storage of food at temperatures 

below -13.3°C (8°F). A refrigerator-freezer is a cabinet which consists of at least one 

compartment designed for the refrigerated storage of food at temperatures above O°C (32°F) and 

at least one other compartment designed for the freezing and storage of food at temperatures 

below -13.3°C (8°F). Top and bottom refrigerator-freezers have a horizontal partition between 

the freezer and refrigerator sections, with the freezer located above and below the refrigerator 

section, respectively. In contrast, side-mount units have a vertical partition between the freezer 

and refrigerator sections, with one on the right and the other on the left side of the unit. A 

freezer consists of a cabinet for the storage and freezing of foods at -17.8°C (O°F) or below. 

Compact refrigerators are defined by the DOE as having less than a 7.75 cubic foot capacity and 

36 inches or less in height. The sales of compact refrigerators have increased appreciably in the 

last several years. While most seem to be sold to residential consumers, significant amounts are 

also prevalent in non-residential applications such as hotels, dormitories and offices. 

Refrigerators and refrigerator-freezers account for about 83 percent of the annual energy 

consumption (AEC) and 78 percent of the installed base of residential refrigeration products (see 

Table 2_1).1 

Table 2-1. Energy Consumption of Residential Refrigeration Equipment 

Eguipment lJJypl~Jw' II'" .1;00 ;/ ,,~ ~ I all AEC (quads) "(_It Installed Base (millions) 

Refrigerators & Refrigerator-Freezers 0.86 142 

Freezers 0.14 29 

Compact Refrigerators 0.04 12 

Source: DOE FY -2005 Pnonty Settmg TSD. 

Based on data from the Association of Home Appliance Manufacturers (AHAM), 

refrigerator-freezer shipments are much greater than refrigerator shipments. 2 In addition, topmount and bottom-mount refrigerator-freezers historically have had approximately twice the 

sales volume of side-mount products (see Table 2-2). 

2-1 
Table 2-2. Residential Refrigerator and Refrigerator-Freezer Unit Shipment Data

2004 164,614 6,925,454 3,832,129

2003 180,128 6,383,096 3,457,797

2002 61,880 6,488,361 3,194,103

2001 36,245 6,283,725 2,985,467

2000 33,151 6,297,553 2,885,902

1999 46,662 6,252,716 2,799,194

1998 75,535 6,077,185 2,624,970

Source: ARAM.

Consequently, the Department's assessment in this document focuses on top-mount and

side-mount refrigerator-freezers because they account for a very large percentage of both

installed base and AEC.

2.2 ENERGY PERFORMANCE

Refrigerator-freezer energy consumption is influenced by both mandatory and voluntary

performance standards. Annual unit energy consumption (UEC) must fall below minimum

levels established by DOE, which took effect in 2001.3 The energy standards apply to

refrigerators and refrigerator-freezers with a total refrigerated volume of less than 1104 liters (39

cubic feet) and to freezers with a total refrigerated volume of less than. 850 liters (30 cubic feet).

The mandated UEC's depend on product class and adjusted volume. Compact refrigerators and

freezers represent separate product classes and have a volume less than 220 liters (7.75 cubic

feet) and a height of 0.91 meters (36 inches) or less. The adjusted volume is equal to the fresh

food internal volume plus 1.63 times the freezer internal volume. The energy standards are

summarized in Table 2-3 below.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 2-2. Residential Refrigerator and Refrigerator-Freezer Unit Shipment Data 

\Year 

2004 164,614 6,925,454 3,832,129 

2003 180,128 6,383,096 3,457,797 

2002 61,880 6,488,361 3,194,103 

2001 36,245 6,283,725 2,985,467 

2000 33,151 6,297,553 2,885,902 

1999 46,662 6,252,7l6 2,799,194 

1998 75,535 6,077,185 2,624,970 

Source: AHAM. 

Consequently, the Department's assessment in this document focuses on top-mount and 

side-mount refrigerator-freezers because they account for a very large percentage of both 

installed base and ABC. 

2.2 ENERGY PERFORMANCE 

Refrigerator-freezer energy consumption is influenced by both mandatory and voluntary 

performance standards. Annual unit energy consumption (UEC) must fall below minimum 

levels established by DOE, which took effect in 2001.3 The energy standards apply to 

refrigerators and refrigerator-freezers with a total refrigerated volume of less than 1104 liters (39 

cubic feet) and to freezers with a total refrigerated volume of less than 850 liters (30 cubic feet). 

The mandated DEC's depend on product class and adjusted volume. Compact refrigerators and 

freezers represent separate product classes and have a volume less than 220 liters (7.75 cubic 

feet) and a height of 0.91 meters (36 inches) or less. The adjusted volume is equal to the fresh 

food internal volume plus 1.63 times the freezer internal volume. The energy standards are 

summarized in Table 2-3 below. 

2-2 
#4®7

Table 2-3. Refrigerator, Refrigerator -Freezer, and Freezer Energy Efficiency Standards

F du: t class

Ene ;, soda s equaio:r fcrmaxiiai enerr use

{vela

Ef`ei,_

E.82r'AV+246

0.7f av+24E.4

E. 2A's+24E:4

0, 2.f av+24E:»

ser

.icratcr Freezers-^ - r def c si h : _ + in =a rreri

7, "`efr;, sratcr-Freezer=- - efr _t h is_,r_.fntedfreezexaanh

AV: Adjusted Volume in cubic feet

av: Adjusted Volume in liters

+355

,^r+355

{I:42=i'f+5:01

+2 4

v+5_

C ?a+r+2B4

14.c x'+391

11 04".416D

C av+160

C4: t+299+

C. ?7.-.v+328,

1 C.C A J+355,

C ^,--3f5

1 ;±2!34`

2 av+2x44"

1 ':.04 :41 dD

0_'_'ra'i+1r0

0:2aav+276.0

4.01,' tV+507.5

0-47av+507.5

4:80AV+45P.0

CL"8ava-=zSG.U

I D.2v-A^:+3"00.0

G 38av+35£cG

10.10AV+40C0

C Hav+4D5.t0

7 5SAV+251.3

G.27av+255.3

12:43A11+1126-1

0.44au+32e.1

P.GEAJ+143. 7

C.2tiav+143.7

1 0.70AV+2@@.0

0_283v+29@:0

7:0GAV+3AC.0

015av+39E.0

12.70-N!+355.0

0.45av+355.0

7.8DAV+801.0

C.27av+5D 1:a:

1 i.10&V+38?.0

C.4Bav+387.0

P 70AV+250.8

C.HW4-25_18

11.4DAV+391.0

C.403v+3A1.0

1 C.45AV+t 520

K.0

Much of the technical discussion in this report focuses on top-mount refrigerator-freezers

without through-the-door features and side-mount refrigerator-freezers with through-the-door

features, since these two product classes make up a very large proportion of the overall market.

Furthermore, the Department focused on a top-mount with 18.2 total internal volume (21.4 cu. ft.

adjusted volume) and a side-mount with 21.7 total internal volume (26.2 cu. ft. adjusted volume).

These refrigerator-freezer sizes are typical for their product classes and were selected for detailed

analysis as part of the 1995 TSD.

In addition to mandatory standards, there are voluntary efficiency programs, including

Energy Star, the Federal Energy Management Program (FEMP), and the Consortium for Energy

Efficiency (CEE). Table 2-4 presents maximum unit energy consumption (UEC) values for the

DOE standard and the three aforementioned voluntary standards for a top- mount refrigeratorfreezer with auto defrost and no through-the-door features and a side-mount refrigerator freezer

with through-the-door features, with 21.4 cu. ft. and 26.2 cu. ft. adjusted volumes, respectively.

Energy Star specifies annual energy use reduction targets of 15 percent for standard size

refrigerator-freezers. The Consortium for Energy Efficiency (CEE) identifies three tier levels

2-3

 EE-PS-2006-001 COMMENT 04.7

#;4.7 

Table 2-3. Refrigerator, Refrigerator-Freezer, and Freezer Energy Efficiency Standards 

Product class 

i. ReirigErators lind lRefTjgerailzf4'reezers wm !mlnIJaJ as-cst .......... ___ ................. _ ............ __ ............. . 

2.. f1~atc.-FreeZEr--il'3r1iaJ a'JiIoolatic defrost ............................................................................................ . 

3. R~ab:lf-FreeZEfS-i'i'J!;OO1l1i!ic defrost vlllh tojH11lY4nted freezer witllout :throuWA~ ice ser .... 

ioe ·ard all,refrigera.tcrs-.autcmafic defrost ......................................................................................................... . 

4. RemgeJaror-Freez'i:rs-.aulomafic d2iicst wiill Si~lOOl1!e1 freezer \i'.illw~ 1:hroa .. l'n·lllls-door ~:re 

s.enJice ....... _ ....... _ ................. _ .......... _ ..................................................................................................... .. 

5. R~atcf-FreeZEf5-il/tIi;OO1a'Jc defrost w0ih OOItom,mollnieci ~ ,\Ii;lloottrnroogll .. ihe-tioor ~ 

5'Ef!Jice; .......................................................................................................................... _ ................................................................. .. 

e·(. R~atcr-FreeZErs-ilfJtOO1a1ic defrost wiih lop.;(llO'Jnt:ci freezer willl ttn:ot;gh·ltle-do07 ice5€rviCi? 

7. R~ab:lf·FreeZErs-a'iJtnm;;itk defroEtw'lth side·rncunli?d freezer ,.lith through-tiie·oo:x ice service 

R Upright Freszsrs w!.h Manual Defrost ........................................................................................................................ . 

!l Up:ight FreeZErs wlll f;JJt~. Defrost .......................................... __ ............................................. _ .. _ 

1il ahas1 Freezers:and all .:iller Free:zerseKCiept c,.~ Freezers ......................................................... . 

11. CorrIpact Refrigera!iors andLReftigeralar-Freezers IlMh tiI_al Defrost ................................. _ ...... _ ..... .. 

12.. CorrIpaci Ri:frige;r;;.i«-Freezef--fPl'r.la! .alrtomalic defirost ......... _._ .............................................. , ....... .. 

13. Compact Reil1igerab:lf .. F~as-au:tama~J defrost I'o\!ill ~ freez:", and compact ail .. reiilg-

·erators-3'3.oo1l1ilc d.,fre,st ............................................... " ............................................................................................................ .. 

14. O!Jm;:;eaci Refrigerilo£or-Fineezsrs--auiomaoo deftos! 'tlilh sidEHTlOUllt:ci freeZEr ....................................... . 

1&. ~act Refrigs:;;.~N·Fr~rs-aooDmafic defr05:.'1lll1h.bofu:lm-rr.:runied ITeezar .................................. .. 

teo ,)cfl';padlUp~Ff$Zers wlih Manual Defrost ................. _ .............. _. __ ............................................. .. 

H. ~aci Uprlgihit Frs-=zgs wllh hJtoma'!ic Defrost ...................... _ .............................................................. .. 

t8. Ocn)j::eaC'l Chest meZErs ............................................................................ _ ............................................................... .. 

AV: Adjusted Volume in cubic feet 

av: Adjusted Volume in liters 

.lamrll/}' ~ 1. 1Q113 

13.5AV+2l}Q 

G.48a.V+200 

1Il4A'IJ+300 

{l.37rut-+3GS 

1t'dlAV+3!i5· 

G.51av+3!i5 

11.SA\f+5ll1 

{L42AV+1lO1 

1tl.5/i:V+367 

G.5B~7 

17JjAV+3Q1 

CLtl2:a.v+3Il:1 

1tl.3AV+B27 

G.5BaV+527 

'111.3/>;"1+264 

0J36alt+264 

14;QAV+391 

(L53aJM.3Q1 

1 H1AV+l'llU 

Oc.39alt+ TOO 

13Jii\V+2liQo 

GAaa1l+2liQo 

11:i.4AV+3QBo 

£L37ii1!i1+3W> 

1tl.I1AV~ 

!L57il!1+355> 

'l1.BAV+501· 

1142«+501-

1MAV+3!!?3 

IJ.5Bav+367. 

111.3.AV+2.M· 

11.36a1l+2.Mo 

14;9P,V+39<1·· 

IHl&III+3Q1. 

HJQAV+'t6Uo 

IJ.39a1l+16Uo 

il!t82AV+24B..t 

G ..3~.4 

a82'AV+24B.4 

O.31av+248.4 

!ll8M.V+21fHI 

!l35av+27ttO 

,~t91AV+liffi'.5 

(U7mR-507;O 

4.6IlAV+45Q;U 

0i.16alH45IHI 

1Il2OAV+3!i5;0 

O~.O 

11111lAV+4UeW 

!l3&w+4ll6;O 

7.55AV+25B.3 

!f27all+25i!l.3 

12.-43I\V+326.1 

G.~.1 

iIl.88AV+143.7 

£!i..35av+'f43.7 

111.7DAV+-2BQ.iJ G~.iJ 

1JlIlAV+3I!B;O 

Oi.2Sav-t3l!S.iJ 

127DAV+355.iJ 

O~Jl 

1.f!IlAV+5Il1.0 

0'27av+li01.0 

13JIlAV+3t17 . .n 

O,4f3av.t367JJ 

'fl.78A11+25Il8 

G.35all+25ll.8 

11.4IlAV+391,0 

1}'4f1av+391 ;0 

11l.45AV+-t52JJ 

0'.37a11+ 152.0 

Much of the technical discussion in this report focuses on top-mount refrigerator-freezers 

without through-the-door features and side-mount refrigerator-freezers with through-the-door 

features, since these two product classes make up a very large propoltion of the overall market. 

Furthermore, the Department focused on a top-mount with 18.2 total internal volume (21.4 cu. ft. 

adjusted volume) and a side-mount with 21.7 total internal volume (26.2 cu. ft. adjusted volume). 

These refrigerator-freezer sizes are typical for their product classes and were selected for detailed 

analysis as part of the 1995 TSD. 

In addition to mandatory standards, there are voluntary efficiency programs, including 

Energy Star, the Federal Energy Management Program (FEMP), and the Consortium for Energy 

Efficiency (CEE). Table 2-4 presents maximum unit energy consumption (UEC) values for the 

DOE standard and the three aforementioned voluntary standards for a top- mount refrigeratorfreezer with auto defrost and no through-the-door features and a side-mount refrigerator freezer 

with through-the-door features, with 21.4 cu. ft. and 26.2 cu. ft. adjusted volumes, respectively. 

Energy Star specifies annual energy use reduction targets of 15 percent for standard size 

refrigerator-freezers. The Consortium for Energy Efficiency (CEE) identifies three tier levels 

2-3 
specifying annual energy use reduction targets of 20, 25, and 30 percent relative to current

minimum efficiency standards (for Tiers 1, 2, and 3). As of July 2005, the Energy Star

refrigerators database included 79 refrigerator-freezer models with an adjusted volume of at least

18 cu. ft. that met the CEE Tier 1 performance level and four models that met the CEE Tier 2

performance level.4

Table 2-4. Maximum UEC Values for Refrigerator-Freezers with Different Specifications

DOE Efficiency Standard 486 671 Energy Star (2004)'

FEMP 460 620 FEMP (2005)

Current Energy Star ( 15% decrease) 413 570 Energy Star (2004)6

CEE Tier 1 (20% decrease) 389 537

CEE Tier 2 (25% decrease) 364 503 CEE (2004)

CEE Tier 3 (30% decrease) 340 469

* Auto defrost, no through-the-door features, 18.2 cu. ft. total volume, and 21.4 cu. ft. adjusted volume.

** Auto defrost, through-the-door features, 21.7 cu. ft. total volume, and 26.2 cu. ft. adjusted volume.

Source: DOE FY-2005 Priority Setting TSD.

DOE and Energy Star levels have the greatest impact on products sold, i.e., the DOE

standards apply to all products sold and Energy Star units account for approximately 20 percent

and 50 percent of top- & bottom-mount and side-mount refrigerator -freezer units sold,

respectively.2

2.3 DESIGN OPTIONS TO IMPROVE EFFICIENCY

Refrigerator-freezer energy efficiency can be increased in several ways, including (but

not limited to) using the design options listed below. To varying degrees, existing products

incorporate one or more of these approaches to meet existing DOE mandatory and other

voluntary (e.g., Energy Star) efficiency levels.

• Higher-efficiency compressors. Energy Efficiency Ratios (EER's) of compressors used

in standard-size refrigerator-freezers can range from about 5 to about 6.1 Btu/hr-W at

standard rating conditions. Higher-efficiency compressors use less energy but are also

more expensive.

• Variable-capacity compressors. Variable-speed compressors operate at a range of speeds

in order to allow capacity modulation. They generally use permanent magnet motors and

require power electronics to vary the speed. The additional power electronic hardware

makes them more expensive. Furthermore, implementation cost can be more expensive,

because control of variable-speed compressors requires a more sophisticated control

approach, which can require use of electronic control. Energy savings are possible with

variable-speed compressors because they operate with reduced mass flow over longer

time periods to deliver the same amount of refrigeration as a single-speed unit. The

2-4

 EE-PS-2006-001 COMMENT 04.7

#4.7 

specifying annual energy use reduction targets of 20, 25, and 30 percent relative to current 

minimum efficiency standards (for Tiers 1, 2, and 3). As of July 2005, the Energy Star 

refrigerators database included 79 refrigerator-freezer models with an adjusted volume of at least 

18 cu. ft. that met the CEE Tier 1 performance level and four models that met the CEE Tier 2 

performance level. 4 

Table 2-4. Maximum VEC Values for Refrigerator-Freezers with Different Specifications !&~ 0./ P _., '"~ :~"'&~ ';co;&#&,,'0'$04£ 

'Specification ;: E! ~:}i~:~A'~ ""'~'" /"" 

DOEEffi lClency St an d d ar 486 671 E nergy S tar (2004) 

FEMP 460 620 FEMP (2005)° 

Current Energy Star (15% decrease) 413 570 Energy Star (2004)6 

CEE Tier 1 (20% decrease) 389 537 

CEE Tier 2 (25% decrease) 364 503 CEE (2004)7 

CEE Tier 3 (30% decrease) 340 469 

* Auto defrost, no through-the-door features, 18.2 cu. ft. total volume, and 21.4 cu. ft. adjusted volume. 

** Auto defrost, through-the-door features, 21.7 cu. ft. total volume, and 26.2 cu. ft. adjusted volume. 

Source: DOE FY-2005 Priority Setting TSD. 

DOE and Energy Star levels have the greatest impact on products sold, i.e., the DOE 

standards apply to all products sold and Energy Star units account for approximately 20 percent 

and 50 percent of top- & bottom-mount and side-mount refrigerator-freezer units sold, 

respectively.2 

2.3 DESIGN OPTIONS TO IMPROVE EFFICIENCY 

Refrigerator-freezer energy efficiency can be increased in several ways, including (but 

not limited to) using the design options listed below. To varying degrees, existing products 

incorporate one or more of these approaches to meet existing DOE mandatory and other 

voluntary (e.g., Energy Star) efficiency levels. 

• Higher-efficiency compressors. Energy Efficiency Ratios (EER's) of compressors used 

in standard-size refrigerator-freezers can range from about 5 to about 6.1 BtU/hr-W at 

standard rating conditions. Higher-efficiency compressors use less energy but are also 

more expensive. 

• Variable-capacity compressors. Variable-speed compressors operate at a range of speeds 

in order to allow capacity modulation. They generally use permanent magnet motors and 

require power electronics to vary the speed. The additional power electronic hardware 

makes them more expensive. Furthermore, implementation cost can be more expensive, 

because control of variable-speed compressors requires a more sophisticated control 

approach, which can require use of electronic control. Energy savings are possible with 

variable-speed compressors because they operate with reduced mass flow over longer 

time periods to deliver the same amount of refrigeration as a single-speed unit. The 

2-4 
#4®7

reduced mass flow allows the refrigerant temperatures in the evaporator and condenser to

more closely approach the air temperatures , thus reducing temperature lift.

• More efficient evaporator and condenser fans. Advanced-design fan blades can reduce

losses associated with movement of air.

• More efficient evaporator and condenser fan motors. Shaded-pole motors were used

traditionally to power evaporator and condenser fans. These motors were inexpensive

but inefficient. Brushless-DC motors with AC-power input have been commercialized.

These motors are significantly more efficient.

• Eliminating thermal shorts. Unintended heat leak paths through the walls and door

panels of refrigerator -freezers can exist where there are wall penetrations, liner

transitions, etc. Careful design to eliminate and/or reduce heat leak paths can

significantly reduce total refrigeration load.

• Improved door face frame/gasket design. The potential for high heat leak at the

doorframe is due to the transition from internal to external liners in this area , and the

potential for gaps between the doors and cabinet to allow infiltration. The added heat

leak in this area generally cannot be completely avoided, leading to the almost universal

use of anti-sweat heating (provided by electric heaters and/or refrigerant lines carrying

hot gas or liquid refrigerant) to keep externally exposed refrigerator surfaces from

condensing ambient moisture in humid climates. Careful. design of this area can

significantly reduce load and energy use.

• Using smart defrost technology, such as adaptive defrost control (ADC) to minimize the

amount of defrost that is needed . One adaptive defrost control approach is toadjust the

defrost time interval based on the time required for the defrost heater to warm the

evaporator up to the defrost termination temperature . A quick warm-up time indicates a

small frost layer (i.e. due to low exterior humidity and/or infrequent door openings),

which indicates that a longer time interval is possible.

• Adding more cabinet insulation to reduce thermal losses, i.e. increasing thickness of

walls or doors.

• Using a blowing agent, which provides a lower-conductivity insulation . Manufacturers

have had to move away from CFC- and HCFC-based blowing agents. A range of

blowing agents is in use today. The different options provide varying insulation thermal

conductivity . Switching to a more efficient blowing agent could reduce cabinet load but

may be more costly.

Vacuum panel insulation. Vacuum panels have been commercially available for a

number of years but have not been adopted in any significant quantity for domestic

refrigeration products due to their relatively high cost. However, this technology can

significantly reduce refrigeration load without increasing wall thickness.

 EE-PS-2006-001 COMMENT 04.7

reduced mass flow allows the refrigerant temperatures in the evaporator and condenser to 

more closely approach the air temperatures, thus reducing temperature lift. 

• More efficient evaporator and condenser fans. Advanced-design fan blades call/educe 

losses associated with movement of air. 

.. More efficient evaporator and condenser fan motors. Shaded-pole motors were~used 

traditionally to power evaporator and condenser fans. These motors were inexpensive 

but inefficient. Brushless-DC motors with AC-power input have been commercialized. 

These motors are significantly more efficient. 

• Eliminating thermal shorts. Unintended heat leak paths through the walls and door 

panels of refrigerator-freezers can exist where there are wall penetrations, liner 

transitions, etc. Careful design to eliminate and/or reduce heat leak paths can 

significantly reduce total refrigeration load. 

• Improved door face frame/gasket design. The potential for high heat leak at the 

doorframe is due to the transition from internal to external liners in this area, and.the 

potential for gaps between the doors and cabinet to allow infiltration. The added heat 

leak in this area generally cannot be completely avoided, leading to the almosttmiversal 

use of anti-sweat heating (provided by electric heaters and/or refrigerant lines carrying 

hot gas or liquid refrigerant) to keep externally exposed refrigerator surfaces from 

condensing ambient moisture in humid climates. Careful design of this area can 

significantly reduce load and energy use. 

• Using smart defrost technology, such as adaptive defrost control (ADC) to minimize the 

amount of defrost that is needed. One adaptive defrost control approach is to adjust the 

defrost time interval based on the time required for the defrost heater to warm the 

evaporator up to the defrost termination temperature. A quick warm-up time indicates a 

small frost layer (i.e. due to low exterior humidity and/or infrequent door openings), 

which indicates that a longer time interval is possible. 

• Adding more cabinet insulation to reduce thermal losses, i.e. increasing thickness of 

walls or doors. 

• Using a blowing agent, which provides a lower-conductivity insulation. Manufacturers 

have had to move away from CFC- and HCFC-based blowing agents. A range of 

blowing agents is in use today. The different options provide varying insulation thermal 

conductivity. Switching to a more efficient blowing agent could reduce cabinet load but 

may be more costly. 

• Vacuum panel insulation. Vacuum panels have been commercially available for a 

number of years but have not been adopted in any significant quantity for domestic 

refrigeration products due to their relatively high cost. However, this technology can 

significantly reduce refrigeration load without increasing wall thickness. 

2-5 
2.4 TEST PROCEDURE STATUS

Standard-size refrigerators, refrigerator-freezers, freezers, and compact refrigerators are

all covered under the same DOE test procedure. They are tested at an ambient temperature of

90°F while internal volume temperatures are kept within specified temperature conditions. DOE

has recently taken action on some issues regarding the test procedure. Also, there have been

recent actions to improve AHAM's test standard. The National Institute of Standards and

Technology (NIST) has investigated the possibility of harmonizing the U.S. test procedure with

international test standards. These issues are described in more detail below.

2.4.1 Credit for a more efficient defrost system

DOE issued a direct final rule, which became effective in May 2003, amending the

calculation of the test time period for "long-time" automatic defrost units.8 This change gives

credit for a control capable of initiating defrost during a compressor off-cycle, thereby saving

energy by taking advantage of the natural warming of the evaporator during the compressor off

cycle. This revision has no effect on the testing of refrigerators and refrigerator-freezers that do

not employ a long-time automatic defrost system.

2.4.2 Change in electric refrigerator definition to exclude wine coolers

Several manufacturers of wine coolers requested exemptions from the refrigerator energy

efficiency standards. Some wine coolers are made with glass front doors, which make them less

energy efficient than standard refrigerators. As a result, the Department amended the definition

of "electric refrigerator", effective December 19, 2001, to include a maximum temperature of the

fresh food storage compartment, and to exclude certain appliances whose physical configuration

makes them unsuitable for general storage of perishable foods. The purpose of the revised

electric refrigerator definition was to exclude wine coolers from the energy efficiency

regulations.9 This rule may also affect other compact refrigerators designed to store and cool

beverages other than wine. For example, since the time of the test procedure revision, a new

product has entered the market that is both a compact refrigerator and wine cooler whose

performance cannot be rated by the existing test procedure.

2.4.3 Repeatability issues for testing compact refrigerators

Because of inconsistencies in test results for compact refrigerators, the National Institute

of Standards and Technology (NIST) investigated repeatability issues and published a report

entitled "Repeatability of Energy Consumption Test Results for Compact Refrigerators".10 In

addition, NIST participated in a task force formed by the Association of Home Appliance

Manufacturers (AHAM) to revise their AHAM HRF-1 test procedure. The latest version of

AHAM's test procedure is now AHAM HRF-1, 2003. But the existing DOE test procedure still

references an older version of the AHAM test procedure, AHAM HRF- 1, 1979. DOE may need

to amend the test procedure to reference the most recent version of AHAM HRF-1.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

2.4 TEST PROCEDURE STATUS 

Standard-size refrigerators, refrigerator-freezers, freezers, and compact refrigerators are 

all covered under the same DOE test procedure. They are tested at an ambient temperature of 

90°F while internal volume temperatures are kept within specified temperature conditions. DOE 

has recently taken action on some issues regarding the test procedure. Also, there have been 

recent actions to improve AHAM's test standard. The National Institute of Standards and 

Technology (NIST) has investigated the possibility of harmonizing the U.S. test procedure with 

international test standards. These issues are described in more detail below. 

2.4.1 Credit for a more efficient defrost system 

DOE issued a direct final rule, which became effective in May 2003, amending the 

calculation of the test time period for "long-time" automatic defrost units. 8 This change gives 

credit for a control capable of initiating defrost during a compressor off-cycle, thereby saving 

energy by taking advantage of the natural warming of the evaporator during the compressor off 

cycle. This revision has no effect on the testing of refrigerators and refrigerator-freezers that do 

not employ a long-time automatic defrost system. 

2.4.2 Change in electric refrigerator definition to exclude wine coolers 

Several manufacturers of wine coolers requested exemptions from the refrigerator energy 

efficiency standards. Some wine coolers are made with glass front doors, which make them less 

energy efficient than standard refrigerators. As a result, the Department amended the definition 

of "electric refrigerator", effective December 19,2001, to include a maximum temperature of the 

fresh food storage compartment, and to exclude certain appliances whose physical configuration 

makes them unsuitable for general storage of perishable foods. The purpose of the revised 

electric refrigerator definition was to exclude wine coolers from the energy efficiency 

regulations. 9 This rule may also affect other compact refrigerators designed to store and cool 

beverages other than wine. For example, since the time of the test procedure revision, a new 

product has entered the market that is both a compact refrigerator and wine cooler whose 

performance cannot be rated by the existing test procedure. 

2.4.3 Repeatability issues for testing compact refrigerators 

Because of inconsistencies in test results for compact refi-igerators, the National Institute 

of Standards and Technology (NIST) investigated repeatability issues and published a report 

entitled "Repeatability of Energy Consumption Test Results for Compact Refrigerators". I 

0 In 

addition, NIST participated in a task force formed by the Association of Home Appliance 

Manufacturers (AHAM) to revise their AHAM HRF-l test procedure. The latest version of 

AHAM's test procedure is now AHAM HRF-l, 2003. But the existing DOE test procedure still 

references an older version ofthe AHAM test procedure, AHAM HRF-l, 1979. DOE may need 

to amend the test procedure to reference the most recent version of AHAM HRF-l. 

2-6 
TV4®7

2.4.4 Harmonizing with international standards

NIST has done comparisons between ISO's international test standards and the North

American (i.e., the DOE) test standard. The two test procedures are similar but not identical.

Differences include the ambient temperature at which the refrigerators are tested and the ISO

specified test load. There is some interest in harmonizing and unifying the two test procedures

by manufacturers interested in international trade. Recently, the United States, Canada, and

Mexico have harmonized their test procedures.

 EE-PS-2006-001 COMMENT 04.7

2.4.4 Harmonizing with international standards 

NIST has done comparisons between ISO's international test standards and .tJ:leNorth 

American (i.e., the DOE) test standard. The two test procedures are similar but notidentical. 

Differences include the ambient temperature at which the refrigerators are tested and the ISO 

specified test load. There is some interest in harmonizing and unifying the two test procedures 

by manufacturers interested in international trade. Recently, the United States, Canada; and 

Mexico have harmonized their test procedures. 

2-7 
REFERENCES

U.S. Department of Energy , FY 2005 Preliminary Priority-Setting Summary Report -

Appendix A: FY 2005 Technical Support Document (TSD), 2005. Washington, DC. Available

at: http://www.eere.energy..ov/buildinLs/appliance standards/pdfs/f05 priority setting app a.pdf.

2 Association of Home Appliance Manufacturers, Summary Data Tables: Refrigerator-Freezer

Data Collectionfor Cost/Efficiency Information for DOE Petition, 2005. Information

provided by the Association of Home Appliance Manufacturers (AHAM) to the U.S.

Department of Energy, May 13, 2005.

U.S. Department of Energy -Office of Energy Efficiency and Renewable Energy, Energy

Conservation Program for Consumer Products : Energy Conservation Standards for

Refrigerators, Refrigerator-Freezers and Freezers ; Final Rule. Federal Register, 1997.

62(81 ): pp. 23102-23116.

4

5

6

7

Energy Star, ENERGY STAR Refrigerators & Freezers Product List, July 5, 2005. Available

at: http://NT.lww.energystar.gov/.index.cfi.i.i?c=refrig.pr refrigerators.

Energy Star, Refrigerators & Freezers Key Product Criteria , 2004. Energy Star Product

Information. Available at: bttp://www. energystar. gov/index.cfm?c=refrig..L)K__Grit refrigerators.

Federal Energy Management Program, How to Buy an Energy-Efficient Residential

Refrigerator, 2004. Washington, DC. September. Available at:

ht!p://www.eere.energy.goN,/feLnp/pdfs/l-ef'rig.pdf.

Consortium for Energy Efficiency, High-Efficiency Specifications for Dishwashers and

Refrigerators, Consortium for Energy Efficiency (CEE) Super-Efficient Home Appliances

Initiative, 2004. Boston, MA. Available at: http://www.ceel.org/resid/seha/dishw/dishwashrefrigspecs.pdf.

U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Energy

Conservation Program for Consumer Products : Test Procedure for Refrigerators and

Refrigerator-Freezers; Direct Final Rule. Federal Register, 2003, 68(45): pp. 10957-10961.

U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Energy

Conservation Program for Consumer Products: Amendment to the Definition of Electric

Refrigerator; Final Rule. Federal Register, 2001 , 66(223): pp. 57845-57848.

10 National Institute of Standards and Technology , 2000, Repeatability of Energy Consumption

Test Results for Compact Refrigerators, September 2000. Gaithersburg, MD. Report No.

NISTIR-6560. Available at: http://fire.mist.gov/bfr-lpubs/buil.d0()/art055.lrtm.l.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

REFERENCES 

2 

3 

4 

5 

6 

7 

8 

9 

U.S. Department of Energy, FY 2005 Preliminary Priority-Setting Summmy ReportAppendix A: FY 2005 Technical Support Document (TSD), 2005. Washington, DC. Available 

at: http://www.eere.energy.goylbuildings/appliance standards/pdfs/fy05 priority setting app a.pdf. 

Association of Home Appliance Manufacturers, Summary Data Tables: Rejl'igerator-Freezer 

Data Collection for CostlE:fficiency Infonnationfor DOE Petition, 2005. Information 

provided by the Association of Home Appliance Manufacturers (AHAM) to the U.S. 

Department of Energy, May 13,2005. 

u.s. Department of Energy-Office of Energy Efficiency and Renewable Energy, Energy 

Conservation Program for Consumer Products: Energy Conservation Standards for 

Refrigerators, Refrigerator-Freezers and Freezers; Final Rule. Federal Register, 1997. 

62(81): pp. 23102-23116. 

Energy Star, ENERGY STAR Refrigerators & Freezers Product List, July 5,2005. Available 

at: http://www.energystar.govlindex.cfnl?c::::refrig.pr refrigerators. 

Energy Star, Refrigerators & Freezers Key Product Criteria, 2004. Energy Star Product 

Information. Available at: http://www.energystaLgov/index.cfm?c::::refrig.pr cdt refrigerators. 

Federal Energy Management Program, How to Buy an Energy-E:fficient Residential 

Rejrigerator,2004. Washington, DC. September. Available at: 

http://www.eere.energy.goy/femp/pdfs/refrig.pdf. 

ConsOltium for Energy Efficiency, High-E:fficiency Spec(fications for Dishwashers and 

Refrigerators, Consortium for Energy Efficiency (CEE) Super-Efficient Home Appliances 

Initiative,2004. Boston, MA. Available at: http://www.ceel.org/resid/seha/dishw/dishwashrefrig specs.pdf. 

U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Energy 

Conservation Program for Consumer Products: Test Procedure for Refrigerators and 

Refrigerator-Freezers; Direct Final Rule. Federal Register, 2003, 68(45): pp. 10957-10961. 

U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Energy 

Conservation Program for Consumer Products: Amendment to the Definition of Electric 

Refrigerator; Final Rule. Federal Register, 2001, 66(223): pp. 57845-57848. 

]0 National Institute of Standards and Technology, 2000, Repeatability of Energy Consumption 

Test Results for Compact Refrigerators, September 2000. Gaithersburg, MD. Report No. 

NISTIR -6560. Available at: http://fire.nist.gov/bfrlpubs/buildOO/art055.html. 

2-8 
#®7

CHAPTER 3. ENGINEERING ANALYSIS

In order to estimate the design and cost impacts of different potential standard levels, the

Department used three information sources:

• The Department's 1995 Technical Support Document (TSD), prepared as part of the

2001 Energy-Efficiency Standard.'

• Cost impact data collected by the Association of Home Appliance Manufacturers

(AHAM) from its member companies in 2005 and consolidated for DOE use and review.2

• Information regarding required design changes provided by manufacturers during

interviews.

3.1 REVIEW OF 1995 TSD

The Department re-evaluated the analysis presented in its 1995 Technical Support

Document (TSD) for refrigerator-freezers (see Table 3-1). Note that the TSD analysis started

with a baseline energy use, which is 16 percent below the 1993 Standards for the side-mount

product class, while the top-mount baseline was equivalent to the 1993 Standard. Table 3-1

summarizes the efficiency levels analyzed in the 1995 TSD in relation to 1993 and 2001 Energy

Standards and the potential new standard levels.

Table 3-1. TSD Energy Use Calculations

1993 Energy Efficiency Standard 697 954

2001 Energy Efficiency Standard 486 671

15% Reduction (Current Energy Star) 413 570

25% Reduction 365 503

1995 TSD Analysis Baseline 701 800

1995 TSD Analysis Minimum 422 508

Auto defrost, no through-the-door features, 18.2 cu. ft. total volume, and 21.4 cu. ft. adjusted volume.

** Auto defrost, through-the-door features, 21.7 cu. ft. total volume, and 26.2 cu. ft. adjusted volume.

Source: DOE 1995 TSD.

3.1.1 Top-Mount Refrigerators

The 1995 analysis identified two design paths for the top-mount product class to achieve

the minimum 422 kWh energy use (two percent higher than current Energy Star). Both paths

included:

 EE-PS-2006-001 COMMENT 04.7

CHAPTER 3. ENGINEERING ANALYSIS 

In order to estimate the design and cost impacts of different potential standard levels, the 

Department used three information sources: 

• The Department's 1995 Technical Support Document (TSD), prepared as part 

2001 Energy-Efficiency Standard. 1 

• Cost impact data collected by the Association of Home Appliance Manufacturers 

(AHAM) from its member companies in 2005 and consolidated for DOE use and review.2 

• Information regarding required design changes provided by manufacturers during 

interviews. 

3.1 REVIEW OF 1995 TSD 

The Department re-evaluated the analysis presented in its 1995 Technical Support 

Document (TSD) for refrigerator-freezers (see Table 3-1). Note that the TSD analysis started 

with a baseline energy use, which is 16 percent below the 1993 Standards for the side-mount 

product class, while the top-mount baseline was equivalent to the 1993 Standard. Table3-1 

summarizes the efficiency levels analyzed in the 1995 TSD in relation to 1993 and 2001 Energy 

Standards and the potential new standard levels. 

Table 3-1. TSD Energy Use Calculations 

15% Reduction 

25% Reduction 

1995 TSD Baseline 701 

1995 TSD Analysis Minimum 422 508 

* Auto defrost, no through-the-cloor features, 18.2 cu. ft. total volume, and 21.4 cu. ft. adjusted volume. 

** Auto defrost, through-the-door features, 21.7 cu. ft. total volume, and 26.2 cu. ft. adjusted volume. 

Source: DOE 1995 TSD. 

3.1.1 Top-Mount Refrigerators 

The 1995 analysis identified two design paths for the top-mount product class to achieve 

the minimum 422 kWh energy use (two percent higher than CUlTent Energy Star). Both paths 

included: 

3-1 
• Higher-efficiency compressor (increase from 4.68 to 5.45 EER)

• Higher-efficiency evaporator fan

• Higher-efficiency evaporator and condenser fan motors (motor input wattage reduction

from 9.1W for the evaporator fan and 12W for the condenser fan to 4.5W for each)

• Improved gaskets

• Increased condenser and evaporator areas, and

• Adaptive defrost control (ADC).

In addition, the first design path incorporated 2.54cm (one-inch) wall. and door insulation

thickness increases, while the second incorporated vacuum panels. Baseline insulation

thicknesses were 3.8 cm (1.5 inch) for the doors, 5.5 cm (2.2 inch) average for the freezer walls,

and 4.3 cm (1.7 inch) average for the fresh food walls. The vacuum panel option assumed that

half of the total wall and door surfaces would be covered with 1-inch thick vacuum panels. The

TSD does not provide detail regarding all of the design options listed. For example, the percent

increase in condenser and evaporator areas was not specified.

Note that the design option paths described in this section would be applied to units

achieving compliance with the 1993 Energy Standard. Hence, today's refrigerator-freezers

would already incorporate some of these options.

While the minimum UEC for the TSD top-mount analysis is not down to the 413

kWh/year level of the current Energy Star, it is nearly down to this level. Compressors with

EER's up to about 6.1 Btu/W-hr are available today, so the same combination of design options

using today's best compressors would likely meet the Energy Star level. One of the design paths

achieving the 422 kWh/year level does not require vacuum panels, suggesting that this level of

energy use can be achieved with readily available components at reasonable cost. In practice,

about 20 percent of the top- and bottom-mount units sold today meet the Energy Star

performance level`, which reinforces the observation that there exist ways to achieve this

efficiency level at reasonable cost.

The TSD analysis does not provide any indication of which design options would be

required to achieve energy use 25 percent below the 2001 Standard for top-mount refrigerators.

3.1.2 Side-Mount Refrigerators

Three of the TSD analysis design paths for the side-mount product class achieved the

current Energy Star performance level.. All of these incorporated:

• Higher-efficiency compressor (increase from 5.18 to 5.6 EER)

• Higher-efficiency evaporator fan

3-2

 EE-PS-2006-001 COMMENT 04.7

#4.7 

• Higher-efficiency compressor (increase from 4.68 to 5.45 EER) 

• Higher-efficiency evaporator fan 

• Higher-efficiency evaporator and condenser fan motors (motor input wattage reduction 

from 9.IW for the evaporator fan and 12W for the condenser fan to 4.5W for each) 

• Improved gaskets 

• Increased condenser and evaporator areas, and 

• Adaptive defrost control (ADC). 

In addition, the first design path incorporated 2.54cm (one-inch) wall and door insulation 

thickness increases, while the second incorporated vacuum panels. Baseline insulation 

thicknesses were 3.8 cm (1.5 inch) for the doors, 5.5 cm (2.2 inch) average for the freezer walls, 

and 4.3 cm (1.7 inch) average for the fresh food walls. The vacuum panel option assumed that 

half of the total wall and door surfaces would be covered with 1-inch thick vacuum panels. The 

TSD does not provide detail regarding all of the design options listed. For example, the percent 

increase in condenser and evaporator areas was not specified. 

Note that the design option paths described in this section would be applied to units 

achieving compliance with the 1993 Energy Standard. Hence, today's refrigerator-freezers 

would already incorporate some of these options. 

While the minimum DEC for the TSD top-mount analysis is not down to the 413 

kWh/year level of the current Energy Star, it is nearly down to this level. Compressors with 

EER's up to about 6.1 Btu/W-hr are available today, so the same combination of design options 

using today's best compressors would likely meet the Energy Star level. One of the design paths 

achieving the 422 kWh/year level does not require vacuum panels, suggesting that this level of 

energy use can be achieved with readily available components at reasonable cost. In practice, 

about 20 percent of the top- and bottom-mount units sold today meet the Energy Star 

performance levef, which reinforces the observation that there exist ways to achieve this 

efficiency level at reasonable cost. 

The TSD analysis does not provide any indication of which design options would be 

required to achieve energy use 25 percent below the 2001 Standard for top-mount refrigerators. 

3.1.2 Side-Mount Refrigerators 

Three ofthe TSD analysis design paths for the side-mount product class achieved the 

current Energy Star performance level. All of these incorporated: 

• Higher-efficiency compressor (increase from 5.18 to 5.6 EER) 

• Higher-efficiency evaporator fan 

3-2 
11

17497

• Higher-efficiency evaporator and condenser fan motors (motor input wattage reduction

from 8.0W for the evaporator fan and 11.6W for the condenser fan to 4.5W for each)

• Increased condenser and evaporator areas, and

• Better thermal management (reduced load) for the through-the-door feature.

The three groups also added the following groups of design options:

• Path 1: 2.54cm (one inch) additional insulation thickness for walls and doors

• Path 2: 1.27cm ( 1/2 inch) additional insulation thickness for walls and doors, ADC, and

improved gaskets

• Path 3: Vacuum panels and ADC.

Baseline insulation thicknesses for this unit were 3.8 cm (1.5 inch) for the doors, 5.8 cm

(2.3 inch) average for the freezer walls, and 5.1 cm (2.0 inch) average for the fresh food walls.

The fact that there are multiple paths, two of which do not include vacuum panels,

suggests that this level of energy use can be achieved cost-effectively. This is corroborated by

current sales levels for Energy Star-compliant side-mount refrigerators, which represent about 50

percent of the sales of this product class.2

The 508 kWh/year energy use level, the minimum calculated for side-mounts in the TSD,

is nearly 25 percent below the 2001 Standard. The single design path for this energy level

incorporates Path 1 above plus the following.

• Adaptive Defrost Control.

• Reduced Gasket Heat Leak

If the higher level of efficiency of today's best compressors is taken into consideration,

the TSD suggests that a full range of design options not including vacuum panels or variable

speed compressors may be able to achieve this energy level for side-mounts.

3.1.3 DOE 1995 TSD Cost Analyses

Manufacturing cost estimates presented in the 1995 TSD for design packages, which

meet energy use targets at 15 percent and 25 percent below the 2001 Standard, are summarized

in Table 3-2. The cost for the design option package, which is the lowest cost, is presented if

more than one design option package meets the energy target.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

• Higher-efficiency evaporator and condenser fan motors (motor input wattage.reduction 

from 8.0W for the evaporator fan and 11.6W for the condenser fan to 4.5W fo~ each) 

• Increased condenser and evaporator areas, and 

• Better thermal management (reduced load) for the through-the-door feature. 

The three groups also added the following groups of design options: 

• Path 1: 2.54cm (one inch) additional insulation thickness for walls and doors 

• Path 2: 1.27cm (Y2 inch) additional insulation thickness for walls and doors, ADC, and 

improved gaskets 

• Path 3: Vacuum panels and ADC. 

Baseline insulation thicknesses for this unit were 3.8 cm (1.5 inch) for the doors, 5.8 cm 

(2.3 inch) average for the freezer walls, and 5.1 cm (2.0 inch) average for the fresh food walls. 

The fact that there are multiple paths, two of which do not include vacuum panels, 

suggests that this level of energy use can be achieved cost-effectively. This is corroborated by 

current sales levels for Energy Star-compliant side-mount refrigerators, which represent about 50 

percent of the sales of this product c1ass. 2 

The 508 kWh/year energy use level, the minimum calculated for side-mounts in the TSD, 

is nearly 25 percent below the 2001 Standard. The single design path for this energy level 

incorporates Path 1 above plus the following. 

• Adaptive Defrost Control. 

• Reduced Gasket Heat Leak 

If the higher level of efficiency oftoday's best compressors is taken into consideration, 

the TSD suggests that a full range of design options not including vacuum panels or variable 

speed compressors may be able to achieve this energy level for side-mounts. 

3.1.3 DOE 1995 TSD Cost Analyses 

Manufacturing cost estimates presented in the 1995 TSD for design packages, which 

meet energy use targets at 15 percent and 25 percent below the 2001 Standard, are summarized 

in Table 3-2. The cost for the design option package, which is the lowest cost, is presented if 

more than one design option package meets the energy target. 

3-3 
Table 3-2. DOE 1995 TSD Manufacturing Cost Analysis Summary (1992$)

2001 Standard Level

Minimum Manufacturing Cost $300 $618

15% Reduction (current Energy Star) Note 1

Minimum Manufacturing Cost $326 $658

Cost Premium $26 $40

25% Reduction Note 2

Minimum Manufacturing Cost No data $671

Cost Premium $53

Auto defrost, no through-the-door features, 18.2 cu, ft. total volume, and 21.4 cu. ft. adjusted volume.

Auto defrost, through-the-door features, 21.7 cu. ft. total volume, and 26.2 cu. ft. adjusted volume.

Note 1: The energy use of this design package is 2 percent above Energy Star.

Note 2: The energy use of this design package is 1 percent above the energy use target.

Source: DOE 1995 TSD.

The Department also performed a review of the cost increases associated with the

different design options presented in the 1995 TSD. These increases appear, for the most part, to

be reasonable and consistent with the Department's understanding of costs for the components

and design changes presented, with the exception of vacuum panel costs. For the top-mount unit,

the TSD estimates that using 2.54cm- (one inch) thick vacuum panels covering 50 percent of

exterior walls and the door increased the unit's cost by $46.65. Based on a unit total surface area

of about 6.5m2 (70ft), this yields a vacuum panels cost of less than $14.50/m2 ($1.40/ft). An

initial investigation by the Department indicates that current OEM costs for vacuum panels range

from $43/m2 to $54/m2 ($4/ft2 to $5/ft2) for large quantities. In addition, the Department is not

familiar with cost projections from vacuum panel vendors below $21/m2 ($2/ft2). The total cost

impact for a refrigerator-freezer would also include design and process changes required to

properly apply the vacuum panels. These costs do not include allowance for vacuum panel

breakage during manufacturing. These preliminary data lead to the initial conclusion that the

$46.65 incremental vacuum panel cost estimate presented in the TSD is low, likely by at least a

factor of two.

3.2 AHAM DATA SUBMITTAL AND CONSOLIDATION

In support of the Department of Energy in this review effort, AHAM collected

incremental cost data from its member companies in May 2005. Costs were requested for

achieving 15 percent and 25 percent reduction in UEC relative to the current DOE standard for

several sizes of refrigerator-freezers of the two most common product classes: top-mount without

through-the-door features and side-mount with through-the-door features. Subsequently, AHAM

aggregated the data by weighting the individual data by company-level sales volumes for each

class and size of units and provided the aggregated data to DOE for review and subsequent

analysis. The data request survey provided to manufacturers by AHAM is contained in

Appendix A.

Table 3-3 and Table 3-4 summarize the incremental manufacturing costs for the topmount and side-mount refrigerator-freezers. The "average" column values equal the average

3-4

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 3-2. DOE 1995 TSD Manufacturing Cost Analysis Summary (1992$) 

Minimum Cost 

15% Reduction (current Energy Star) 

Minimum Manufacturing Cost 

Cost Premium 

25% Reduction 

Minimum Manufacturing Cost 

Cost Premium 

$300 

Note 1 

$326 

$26 

No data 

$618 

$658 

$40 

Note 2 

$671 

* Auto defrost, no through-the-door features, 18.2 cu. ft. total volume, and 21.4 cu. ft. adjusted volume. 

** Auto defrost, through-the-door features, 21.7 cu. ft. total volume, and 26.2 cu. ft. adjusted volume. 

Note 1: The energy use of this design package is 2 percent above Energy Star. 

Note 2: The energy use of this design package is 1 percent above the energy use target. 

Source: DOE 1995 TSD. 

The Department also performed a review of the cost increases associated with the 

different design options presented in the 1995 TSD. These increases appear, for the most part, to 

be reasonable and consistent with the Department's understanding of costs for the components 

and design changes presented, with the exception of vacuum panel costs. For the top-mount unit, 

the TSD estimates that using 2.54cm- (one inch) thick vacuum panels covering 50 percent of 

exterior walls and the door increased the unit's cost by $46.65. Based on a unit total surface area 

of about 6.5m2 (70ft2), this yields a vacuum panels cost of less than $14.50/m2 ($1.40/ft2). An 

initial investigation by the Department indicates that current OEM costs for vacuum panels range 

from $43/m2 to $54/m2 ($4/ft2 to $5/ft2) for large quantities. In addition, the Department is not 

familiar with cost projections from vacuum panel vendors below $211m2 ($2/ft2

). The total cost 

impact for a refrigerator-freezer would also include design and process changes required to 

properly apply the vacuum panels. These costs do not include allowance for vacuum panel 

breakage during manufacturing. These preliminary data lead to the initial conclusion that the 

$46.65 incremental vacuum panel cost estimate presented in the TSD is low, likely by at least a 

factor of two. 

3.2 AHAM DATA SUBMITTAL AND CONSOLIDATION 

In support of the Department of Energy in this review effort, AHAM collected 

incremental cost data from its member companies in May 2005. Costs were requested for 

achieving 15 percent and 25 percent reduction in UEC relative to the current DOE standard for 

several sizes of refrigerator-freezers ofthe two most common product classes: top-mount without 

through-the-door features and side-mount with through-the-door features. Subsequently, AHAM 

aggregated the data by weighting the individual data by company-level sales volumes for each 

class and size of units and provided the aggregated data to DOE for review and subsequent 

analysis. The data request survey provided to manufacturers by AHAM is contained in 

Appendix A. 

Table 3-3 and Table 3-4 summarize the incremental manufacturing costs for the topmount and side-mount refrigerator-freezers. The "average" column values equal the average 

3-4 
#4®7

incremental cost for all products in that size range weighted by shipment volumes, while the

"minimum" and "maximum" values are based on the incremental cost for the basic model of

each manufacturer with the lowest and highest incremental cost. The costs include materials,

burdened labor, and amortization of capital expenses.'

Table 3-3. Incremental Manufacturing Costs for Top-Mounted Refrigerator-Freezers

without Through-the-Door Features

15% less energy 1 $8.00 $19.04 1 $26.00 $8.00

25% less energy $64.00 $187.80 $359.00 $18.00

Source: AHAM.

$141.00

Table 3-4. Incremental Manufacturing Costs for Side-Mount Refrigerator-Freezers with

Through-the-Door Features

15% less energy 1 $5.00 1 $26.88

25% less energy 1 $6.00

Source: ARAM.

$126.40

$95.00

$219.00 $30.00 I $99.63 $305.00 Insufficient Data

3.2.1 Comparison of AHAM Cost Data with TSD Cost Estimates

The manufacturing cost premium estimates of the 1.995 TSD and the AHAM data are

compared in Table 3-5 below for the product models and energy use levels for which data is

available. In all cases, the TSD estimates are within the range of cost premium estimates

provided by AHAM. However, the TSD estimates for the side-mount appear to be high for the

15 percent reduction and low for the 25 percent reduction.

a Typically burdened labor is composed of labor and overhead where overhead includes indirect labor for downtime,

set-up time, supervisors, materials handling, and clerical. Some other overhead costs such as utilities and insurance

might also be included or may be allocated as indirect materials or material burden. Practices for classifying other

overhead costs vary by manufacturer.

3-5

 EE-PS-2006-001 COMMENT 04.7

#4.7 

incremental cost for all products in that size range weighted by shipment volumes, while the 

"minimum" and "maximum" values are based on the incremental cost for the basic model of 

each manufacturer with the lowest and highest incremental cost. The costs include materials, 

burdened labor, and amortization of capital expenses. a 

Table 3-3. Incremental Manufacturing Costs for Top-Mounted Refrigerator-Freezers 

without Through-the-Door Features 

15% less energy $8.00 $19.04 $26.00 $8.00 $17.31 $400.00 $10.00 $21.21 $37.00 

25% less energy $64.00 $187.80 $359.00 $18.00 $54.10 $141.00 $40.00 $78.29 $139.00 

Source: AHAM. 

Table 3-4. Incremental Manufacturing Costs for Side-Mount Refrigerator-Freezers with 

Through-the-Door Features 

25% less energy $6.00 $126.40 $219.00 $30.00 $305.00 Insufficient Data 

Source: AHAM. 

3.2.1 Comparison of AHAM Cost Data with TSD Cost Estimates 

The manufacturing cost premium estimates of the 1995 TSD and the AHAM data are 

compared in Table 3-5 below for the product models and energy use levels for which data is 

available. In all cases, the TSD estimates are within the range of cost premium estimates 

provided by AHAM. However, the TSD estimates for the side-mount appear to be high for the 

15 percent reduction and low for the 25 percent reduction. 

a Typically burdened labor is composed of labor and overhead where overhead includes indirect labor for downtime, 

set-up time, supervisors, materials handling, and clerical. Some other overhead costs such as utilities and insurance 

might also be included or may be allocated as indirect materials or material burden. Practices for classifying other 

overhead costs vary by manufacturer. 

3-5 
Table 3-5. Comparison of 1995 TSD and AHAM Manufacturing Cost Premium Estimates

15% Reduction (current Energy Star)

1995 TSD Cost Premium [$1992]

Note 1

$26 $40

AHAM Cost Premium (min.-avg.-max.) $8-$17-$400 $5-$27-$95

25% Reduction Note 2

1995 TSD Cost Premium [$1992] No data $53

AHAM Cost Premium (min.-avg.-max.) $18-$54-$141 $6-$126-$219

Auto defrost, no through -th e-door features, 18.2 cu. ft. total volume, and 21.4 cu. ft. adjusted volume.

* Auto defrost, through-the-door features, 21.7 cu. ft. total volume, and 26.2 cu. ft. adjusted volume.

Note 1: The energy use of this design package for the TSD cost premium estimate is 2 percent above Energy Star.

Note 2: The energy use of this design package for the TSD cost premium is 1 percent above the energy use target.

3.3 MANUFACTURER INTERVIEWS

Initially, the Department's cost analysis focused on a review of the 1995 TSD and

evaluation of the consumer price differential between "matched pairs" of products, i.e., products

whose only differences were their efficiency levels (e.g., comparing a unit that performed at the

DOE standard level and another unit that met the Energy Star requirements). AHAM and its

member companies indicated that the matched pair approach had several limitations, notably that

the products may not be true matched pairs (e.g., due to product features), that retail. price

differences between matched pairs do not necessarily reflect OEM cost differences due to market

factors, and that the approach does not consider the full product lines offered by manufacturers.

Models, which would have an Energy Star matched pair, would typically be carefully picked to

allow for a more cost-effective boost of the efficiency level. Manufacturers noted during

structured interviews that they often do not maintain their margins for higher-cost Energy Star

units because they believe that consumers do not think that the additional cost can justify

relatively modest savings. Non-energy features, however, can often command greater premiums

than Energy Star.

During interviews, manufacturers were asked what groupings of design options would be

required in order to reduce energy use of top-mount and side-mount refrigerators to levels which

are 15 percent and 25 percent below the 2001 Standard. The discussion was helpful to better

understand which of the 1995 TSD design paths were already implemented. Additionally, the

conversations resulted in a better understanding of the design strategies underlying the 2005

AHAM data. The discussion below represents a consolidation of the responses in order to avoid

revealing design details for any given manufacturer.

3.3.1 15 Percent Energy Use Reduction

For the most part, achieving a 15 percent energy use reduction is possible with the use of

a high-efficiency compressor, high-efficiency fan motors (brushless-DC fan motors) for both the

evaporator and condenser fans, and adaptive defrost control. In general, manufacturers indicated

that they had to incorporate more energy-efficient features to achieve the reduction for sidemount units than for top-mount units. In some cases, significantly more aggressive design

options (i.e. variable-speed compressors and/or vacuum panels) would be required in order to

achieve a 15 percent energy use reduction. This is more likely the case with counter-depth (24-

3-6

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 3-5. Comparison of 1995 TSD and AHAM Manufacturing Cost Premium Estimates 

I ~ 

~ cC JiS: ~"'8 y-",~ 1ti"$!< 'ii" 4"'Y;jpll' x Top-BDun~'!!/ s; I ",is ide-Mount ** 

15% Reduction (current Energy Star) Note 1 

1995 TSD Cost Premium [$1992] $26 $40 

AHAM Cost Premium (min.-avg.-max.) $8 - $17 - $400 $5 - $27 - $95 

25% Reduction Note 2 

1995 TSD Cost Premium [$1992] No data $53 

AHAM Cost Premium (min.-avg.-max.) $18 - $54 - $141 $6 - $126 - $219 

* Auto defrost, no through-the-door features, 18.2 cu. ft. total volume, and 21.4 cu. ft. adjusted volume. 

** Auto defrost, through-the-door features, 21.7 cu. ft. total volume, and 26.2 cu. ft. adjusted volume. 

Note 1: The energy use of this design package for the TSD cost premium estimate is 2 percent above Energy Star. 

Note 2: The energy use of this design package for the TSD cost premium is 1 percent above the energy use target. 

3.3 MANUFACTURER INTERVIEWS 

Initially, the Department's cost analysis focused on a review of the 1995 TSD and 

evaluation of the consumer price differential between "matched pairs" of products, i.e., products 

whose only differences were their efficiency levels (e.g., comparing a unit that performed at the 

DOE standard level and another unit that met the Energy Star requirements). AHAM and its 

member companies indicated that the matched pair approach had several limitations, notably that 

the products may not be true matched pairs (e.g., due to product features), that retail price 

differences between matched pairs do not necessarily reflect OEM cost differences due to market 

factors, and that the approach does not consider the full product lines offered by manufacturers. 

Models, which would have an Energy Star matched pair, would typically be carefully picked to 

allow for a more cost-effective boost of the efficiency level. Manufacturers noted during 

structured interviews that they often do not maintain their margins for higher-cost Energy Star 

units because they believe that consumers do not think that the additional cost can justify 

relatively modest savings. Non-energy features, however, can often command greater premiums 

than Energy Star. 

During interviews, manufacturers were asked what groupings of design options would be 

required in order to reduce energy use of top-mount and side-mount refrigerators to levels which 

are 15 percent and 25 percent below the 2001 Standard. The discussion was helpful to better 

understand which ofthe1995 TSD design paths were ah-eady implemented. Additionally, the 

conversations resulted in a better understanding of the design strategies underlying the 2005 

AHAM data. The discussion below represents a consolidation of the responses in order to avoid 

revealing design details for any given manufacturer. 

3.3.1 15 Percent Energy Use Reduction 

For the most part, achieving a 15 percent energy use reduction is possible with the use of 

a high-efficiency compressor, high-efficiency fan motors (brushless-DC fan motors) for both the 

evaporator and condenser fans, and adaptive defrost control. In general, manufacturers indicated 

that they had to incorporate more energy-efficient features to achieve the reduction for sidemount units than for top-mount units. In some cases, significantly more aggressive design 

options (i.e. variable-speed compressors and/or vacuum panels) would be required in order to 

achieve a 15 percent energy use reduction. This is more likely the case with counter-depth (24-

3-6 
#e.

inch-deep) units, which have increased surface/volume ratio, which means that these units have

more surface area to transfer heat than more conventional units of the same internal volume.

3.3.2 25 Percent Energy Use Reduction

Achieving 25 percent energy use reduction generally could not be done just by switching

to more efficient components. Instead, it requires a reduction in load transmitted through the

refrigerator walls and doors. This would be done by increasing wall thickness if possible, but

could potentially require the use of vacuum panels. In either case, this involves redesign of

product platforms with the associated capital investments required to purchase new

manufacturing tooling. Use of variable speed compressors was also mentioned as a possible

additionally required design change. All manufacturers indicated that one or more of their

refrigerator models could not cost-effectively be brought to the 25 percent reduced energy level

and would likely be discontinued.

3.3.3 Bottom-Mount Refrigerators

While most of the analysis discussed in this report addresses top-mount and side-mount

refrigerators, one manufacturer pointed out that bottom-mount refrigerators are also an important

product class that should be considered. Design options to achieve 15 percent and 25 percent

energy use reductions for bottom-mount refrigerators were reported to be similar to those

required for top-mount refrigerators.

3.3.4 Platform Changes

It is important to note that many manufacturers would likely take a platform-based

approach toward product redesign such that different models built using one platform could

achieve both the standard level and a future Energy Star performance level. As discussed in the

"Market Impact" section, this is driven by the market need to offer a range of products that can

meet both performance levels to serve some key clients, such as major retail chains and the U.S.

government. The future Energy Star energy use may be 25 percent below the 2001 Standard.

Hence, it would be expected that, if a 15 percent energy use reduction is mandated by DOE,

manufacturers would need to implement wall thickness increases in order to be able to meet both

15 percent and 25 percent reduction levels with a given production platform (the 25 percent

models would include more high-efficiency components).

3.3.5 Intellectual Property

Although manufacturers did not have major concerns about intellectual property rights

impeding access to technologies used to enhance efficiency, a few manufacturers did note that

one (foreign) company owns patents related to linear compressors, a variable-capacity

compressor technology which may have better efficiency than conventional rotary-motor

reciprocating compressors.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

inch-deep) units, which have increased surface/volume ratio, which means that these.units have 

more surface area to transfer heat than more conventional units of the same internal volume. 

3.3.2 25 Percent Energy Use Reduction 

Achieving 25 percent energy use reduction generally could not be done just by switching 

to more efficient components. Instead, it requires a reduction in load transmitted through the 

refrigerator walls and doors. This would be done by increasing wall thickness if possible, but 

could potentially require the use of vacuum panels. In either case, this involves redesign of 

product platfOlIDs with the associated capital investments required to purchase new 

manufacturing tooling. Use of variable speed compressors was also mentioned as a possible 

additionally required design change. All manufacturers indicated that one or more of their 

refrigerator models could not cost-effectively be brought to the 25 percent reduced energy level 

and would likely be discontinued. 

3.3.3 Bottom-Mount Refrigerators 

While most of the analysis discussed in this report addresses top-mount and side-mount 

refrigerators, one manufacturer pointed out that bottom-mount refrigerators are also an important 

product class that should be considered. Design options to achieve 15 percent and 25 percent 

energy use reductions for bottom-mount refrigerators were reported to be similar to those 

required for top-mount refrigerators. 

3.3.4 Platform Changes 

It is impOltant to note that many manufacturers would likely take a platform-based 

approach toward product redesign such that different models built using one platform could 

achieve both the standard level and a future Energy Star performance level. As discussed in the 

"Market Impact" section, this is driven by the market need to offer a range of products that can 

meet both performance levels to serve some key clients, such as major retail chains and the U.S. 

government. The future Energy Star energy use may be 25 percent below the 2001 Standard. 

Hence, it would be expected that, if a 15 percent energy use reduction is mandated by DOE, 

manufacturers would need to implement wall thickness increases in order to be able to meet both 

15 percent and 25 percent reduction levels with a given production platform (the 25 percent 

models would include more high-efficiency components). 

3.3.5 Intellectual Property 

Although manufacturers did not have major concerns about intellectual property rights 

impeding access to technologies used to enhance efficiency, a few manufacturers did note that 

one (foreign) company owns patents related to linear compressors, a variable-capacity 

compressor technology which may have better efficiency than conventional rotary-motor 

reciprocating compressors. 

3-7 
REFERENCES

U.S. Department of Energy, Technical Support Document: Energy Efficiency Standards for

Consumer Products: Refrigerators, Refrigerator-Freezers, & Freezers, July 1995.

Washington, DC. Report No. DOE/EE-0064.

2 Association of Home Appliance Manufacturers, Summary Data Tables: Refrigerator-Freezer

Data Collection for Cost/Efficiency Information for DOE Petition, 2005. Information

provided by the Association of Home Appliance Manufacturers (AHAM) to the U.S.

Department of Energy, May 13, 2005.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

REFERENCES 

2 

U.S. Department of Energy, Technical Support Document: Energy Efficiency Standardsfor 

Consumer Products: Refrigerators, Refrigerator-Freezers, & Freezers, July 1995. 

Washington, DC. Report No. DOE/EE-0064. 

Association of Home Appliance Manufacturers, Summary Data Tables: Refrigerator-Freezer 

Data Collectionfor Cost/Efficiency Infonnationfor DOE Petition, 2005. Information 

provided by the Association of Home Appliance Manufacturers (AHAM) to the U.S. 

Department of Energy, May 13,2005. 

3-8 
#4®7

CHAPTER 4. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS

Increasing the energy efficiency of a product to comply with a standard affects the costs

of purchasing and operating the product. Higher-efficiency products usually have higher

installed costs and lower operating costs. The Department performed a life-cycle cost (LCC) and

payback period (PBP) analysis to help determine whether the operating cost savings of potential

new standards for refrigerator-freezers are sufficient to justify the higher purchase price.

For the purposes of this analysis, the Department analyzed the LCC and PBP of amended

energy conservation standards for the following two product classes of refrigerators, refri(yeratorfreezers, and freezers: (1) top-mounted freezer without through-the-door (TTD) ice service,

automatic defrost and (2) side-mounted freezer with TTD ice service, automatic defrost. The

Department analyzed two standard levels: (1) product with 15 percent less annual energy

consumption than the baseline product (i.e., a product meeting current energy conservation

standards) and (2) a product with 25 percent less annual energy consumption than the baseline

product. The Department assumed baseline products to equal the maximum energy consumption

allowed by current energy conservation standards. Refrigerator-freezers with 15 percent less

energy consumption correspond to products meeting current Energy Star requirements.

Refrigerator-freezers with 25 percent less energy consumption correspond to products meeting

potential future Energy Star levels, assuming new standards are set at existing Energy Star levels.

4.1 LIFE-CYCLE COST METHODOLOGY

The Department calculated the LCC by adding the installed cost and all the operating

costs until the end of the product lifetime as shown in Equation 4.1. The total installed cost for a

refrigerator-freezer includes the consumer retail price and the installation cost. The operating

costs include the electricity expense and any repair and maintenance costs. The equation

discounts future operating costs to the year of installation.

LCC = P+

O

(1+ r)`

where:

P = total installed cost ($),

E = sum over analysis period,

Ot = annual operating cost ($),

r = discount rate for costs, and

t = lifetime (years).

Eq. 4.1

The LCC savings is the difference between the LCC of the base line (i.e., the product

meeting current energy conservation standards) and the LCC of the product meeting new

standards. For purposes of this analysis, the Department assumed the installation, repair, and

maintenance costs were equal to zero.

4-9

 EE-PS-2006-001 COMMENT 04.7

#4.7 

CHAPTER 4. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS 

Increasing the energy efficiency of a product to comply with a standard affects the costs 

of purchasing and operating the product. Higher-efficiency products usually have higher 

installed costs and lower operating costs. The Department performed a life-cycle cost (LCC) and 

payback period (PBP) analysis to help determine whether the operating cost savings of potential 

new standards for refrigerator-freezers are sufficient to justify the higher purchase price. 

For the purposes of this analysis, the Department analyzed the LCC and PBPof amended 

energy conservation standards for the following two product classes of refrigerators, refrigeratorfreezers, and freezers: (1) top-mounted freezer without through-the-door (TID) ice service, 

automatic defrost and (2) side-mounted freezer with TTD ice service, automatic defrost. The 

Department analyzed two standard levels: (1) product with 15 percent less annual energy 

consumption than the baseline product (i.e., a product meeting current energy conservation 

standards) and (2) a product with 25 percent less annual energy consumption than the baseline 

product. The Department assumed baseline products to equal the maximum energy consumption 

allowed by current energy conservation standards. Refrigerator-freezers with 15 percent less 

energy consumption correspond to products meeting current Energy Star requirements. 

Refrigerator-freezers with 25 percent less energy consumption correspond to products meeting 

potential future Energy Star levels, assuming new standards are set at existing Energy Star levels. 

4.1 LIFE-CYCLE COST METHODOLOGY 

The Department calculated the Lee by adding the installed cost and all the operating 

costs until the end of the product lifetime as shown in Equation 4.1. The total installed cost for a 

refrigerator-freezer includes the consumer retail price and the installation cost. The operating 

costs include the electricity expense and any repair and maintenance costs. The equation 

discounts future operating costs to the year of installation. 

~ °t LCC = P+ LC> )1 1+1' Eq.4.1 

where: 

P = total installed cost ($), 

L = sum over analysis period, 

Ot = annual operating cost ($), 

r = discount rate for costs, and 

t = lifetime (years). 

The Lee savings is the difference between the Lee of the baseline (i.e., the product 

meeting current energy conservation standards) and the Lee of the product meeting new 

standards. For purposes of this analysis, the Department assumed the installation, repair, and 

maintenance costs were equal to zero. 

4-9 
Figure 4-1 illustrates the cumulative costs, which include the initial total installed cost

and the discounted annual operating costs, over the equipment lifetime for a hypothetical

baseline product (no standards) and a product meeting new standards. Typically, the standards

case has a higher initial total installed cost than the baseline.

A

COSTS

($)

$0

Baseline

A

Difference:

p Baseline - Standards

0

13 13

n

0

13 13

13

A

A

A

13

A

A

Standards LCC

q q q q q q t 9)

LCC Savings

A

A

Years Since Purchase

Figure 4-1. Illustration of LCC for Baseline and Standards

Over the years that the refrigerator is in use, the system incurs electricity costs. The

baseline product consumes more electricity than the product in the standards case, so the total

LCC is generally higher for the baseline product than for the product meeting new standards.

Figure 4-2 illustrates the inputs, calculated values, and outputs of the LCC analysis. A

representative value or range of values represents each input. The Department annotated data

sources in the LCC and PBP spreadsheet model and fully documented them in this chapter.

The Department performed the LCC and PBP analysis using representative values for

product retail prices and lifetimes, energy costs , energy usage, and discount rates. The following

sections discuss and document the LCC inputs.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Figure 4-1 illustrates the cumulative costs, which include the initial total installed cost 

and the discounted annual operating costs, over the equipment lifetime for a hypothetical 

baseline product (no standards) and a product meeting new standards. Typically, the standards 

case has a higher initial total installed cost than the baseline. 

COSTS 

($) Baseline ~ 

b. 

Difference: 

Baseline - Standards 

o 0 o o 0 

BaselineLCC 

000 LCC Savings 

$0 I-I _________ ~<T-D~D~D~--------------------------~~~~~--~~ 000 

o 0 

Years Since Purchase 

Figure 4-1. Illustration ofLCC for Baseline and Standards 

Over the years that the refrigerator is in use, the system incurs electricity costs. The 

baseline product consumes more electricity than the product in the standards case, so the total 

Lee is generally higher for the baseline product than for the product meeting new standards. 

Figure 4-2 illustrates the inputs, calculated values, and outputs of the Lee analysis. A 

representative value or range of values represents each input. The Department annotated data 

sources in the Lee and PEP spreadsheet model and fully documented them in this chapter. 

The Department pelformed the Lee and PEP analysis using representative values for 

product retail prices and lifetimes, energy costs, energy usage, and discount rates. The following 

sections discuss and document the Lee inputs. 

4-10 
Manufacturing

Cost

Manufacturerto-Consumer

Markup

Annual

Electricity

Consumption

Electricity

Price

Consumer

Retail

Price

Product

Lifetime

Discount Rate

Electricity

Price Trend

Payback

Period

Life-Cycle

Cost

LCC Inputs

Calculated Values

LCC & PBP Output

Figure 4-2. Flow Diagram of Life-Cycle Cost and Payback Period Analysis

4.2 CONSUMER RETAIL PRICE

The consumer retail price represents the price to the consumer of purchasing a

refrigerator-freezer. The Department determined the consumer retail price of more-efficient

refrigerator-freezers by first establishing the retail price of baseline products (i.e., products

meeting current energy conservation standards) and then establishing the incremental retail price

associated with the more efficient products. The Department determined two sets of incremental

retail prices: one set based on incremental manufacturing costs and the other set based on a

regression analysis of refrigerator-freezer sales data. The Department also conducted an analysis

of focused matched pairs of refrigerator-freezers to determine the incremental price of more

efficient products. The focused matched pairs consisted of two models where most features were

similar with the exception that one model met Energy Star and the other model did not.

4.2.1 Baseline Retail Price

The Department determined the retail prices associated with baseline top-mount and sidemount refrigerator-freezers through an analysis of retail prices from The NPD Group.' The NPD

Group dataset includes information about the average price and model number of more than

2000 refrigerator models sold in 2004 in the United States. The data also include information

about the refrigerator brand, manufacturer, attributes (e.g., total refrigerated volume, number and

type of shelves), and sales, and whether each model. has an Energy Star rating.

4-11

 EE-PS-2006-001 COMMENT 04.7

Manufactuting 

Cost 

Manufacturerto-Consumer 

Markup 

Annual 

Electricity 

Consumption 

Electlicity 

Price 

Consumer 

Retail 

Price 

Product 

Lifetime 

Discount Rate 

Electricity 

Price Trend 

Payback 

Period 

Lifetime 

E1ectlicity 

Cost 

#4.7 

Figure 4-2. Flow Diagram of Life-Cycle Cost and Payback Period Analysis 

4.2 CONSUMER RETAIL PRICE 

The consumer retail price represents the price to the consumer of purchasing a 

refrigerator-freezer. The Department determined the consumer retail price of more-efficient 

refrigerator-freezers by first establishing the retail price of baseline products (i.e., products 

meeting cunent energy conservation standards) and then establishing the incremental retail price 

associated with the more efficient products. The Department determined two sets of incremental 

retail prices: one set based on incremental manufacturing costs and the other set based on a 

regression analysis of refrigerator-freezer sales data. The Department also conducted an analysis 

of focused matched pairs of refrigerator-freezers to determine the incremental price of more 

efficient products. The focused matched pairs consisted of two models where most features were 

similar with the exception that one model met Energy Star and the other model did not. 

4.2.1 Baseline Retail Price 

The Department determined the retail prices associated with baseline top-mount and sidemount refrigerator-freezers through an analysis of retail prices £i'om The NPD Group.1 The NPD 

Group dataset includes information about the average price and model number of more than 

2000 refrigerator models sold in 2004 in the United States. The data also include information 

about the refrigerator brand, manufacturer, attributes (e.g., total refrigerated volume, number and 

type of shelves), and sales, and whether each model has an Energy Star rating. 

4-11 
The NPD Group dataset includes information on 535 top-mount and 629 side-mount

refrigerator-freezer models. Summary information on these models is included in Appendix B.

The Department used price and sales information about these models to select groups of basic

top-mount and side-mount refrigerator-freezers. The Department defined basic refrigeratorfreezers from the distribution of lower-priced, high-selling models.

As shown in Figure 4-3, the sales-weighted distribution of top-mount models indicated a

price grouping of 387 models under $600 (over 90 percent of sales). As a result, the Department

defined this grouping of 387 models as basic top-mount models.

32%

30%

29%

25%

22%

18%

14% _14%

18%

Basic model upper price limit.

11%

7

4

7%

2%

0% 0% a 0% a 1 C r -^^^^ -,--

0°/a 1% 0% 0% 0%

0

53 179 305 431 557 683 809 935

Price (dollars per unit)

Figure 4-3. Sales by Retail Price: Refrigerator -Freezers with Top-Mount Freezer

Of the 387 top-mount models under $600, 262 models are without TTD ice service and

do not meet current Energy Star levels. Thus, the Department considered these 262 models to be

baseline models (i.e., models just meeting current energy conservation standards). Table 4-1

shows the sales-weighted baseline prices associated with three capacity size ranges of top-mount

refrigerator-freezers. Capacities are in total refrigerated volume (i.e., fresh food compartment

volume plus freezer compartment volume).

 EE-PS-2006-001 COMMENT 04.7

#4.7 

The NPD Group dataset includes information on 535 top-mount and 629 side-mount 

refrigerator-freezer models. Summary information on these models is included in Appendix B. 

The Department used price and sales information about these models to select groups of basic 

top-mount and side-mount refrigerator-freezers. The Department defined basic refrigeratorfreezers from the distribution of lower-priced, high-selling models. 

As shown in Figure 4-3, the sales-weighted distribution of top-mount models indicated a 

price grouping of 387 models under $600 (over 90 percent of sales). As a result, the Deprutment 

defined this grouping of 387 models as basic top-mount models. 

30% 

Basic model upper price limit. 

0% 0% 

935 

Price (dollars per unit) 

Figure 4-3. Sales by Retail Price: Refrigerator-Freezers with Top-Mount Freezer 

Of the 387 top-mount models under $600, 262 models are without TTD ice service and 

do not meet current Energy Star levels. Thus, the Depru·tment considered these 262 models to be 

baseline models (i.e., models just meeting current energy conservation standru·ds). Table 4-1 

shows the sales-weighted baseline prices associated with three capacity size ranges of top-mount 

refrigerator-freezers. Capacities are in total refrigerated volume (i.e., :liesh food compartment 

volume plus freezer comprutment volume). 

4-12 
#4®7

Table 4-1. Baseline Retail Prices: Refrigerator-Freezers with Top-Mount Freezer and

without TTD Ice Service

L&L

Baseline Retail Price $329 $386

Source: The NPD Group/NPD Houseworld - POS.

For side-mount models, Figure 4-4 shows the sales-weighted distribution indicating a

price grouping of 302 models under $1100 (70 percent of sales). As a result, the Department

defined this grouping of 302 models as basic side-mount models.

42%

36%

300

24%

18°/O

12°/

28%

18% 18% Basic model upper price limit.

60

8%

6%

j 2%

%

o% o 0% 0% % I I 0%

199 467 736 1004 1272 1541 1809

333 602 870 1138 1407 1675 1943

Price ( dollars per unit)

Figure 4-4. Sales by Retail Price: Refrigerator-Freezers with Side-Mount Freezer

Of the 302 top-mount models under $1100, 143 models feature TTD ice service and do

not meet current Energy Star levels. Thus, the Department considered these 143 models to be

baseline models. Table 4-2 shows the sales-weighted baseline prices associated with three

capacity size ranges of side-mount refrigerator freezers. Capacities are in total refrigerated

volume.

9%

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 4-1. Baseline Retail Prices: Refrigerator-Freezers with Top-Mount Freezer and 

without TTD Ice Service 

Source: The NPD Group/NPD Houseworld - POS. 

For side-mount models, Figure 4-4 shows the sales-weighted distribution indicating a 

price grouping of 302 models under $1100 (70 percent of sales). As a result, the Department 

defined this grouping of 302 models as basic side-mount models. 

CI 42% 

36% 

30% ·28% 

'" .; 24% TIl 

.... 

0 

Cl 

... 

<.> 

t 18% Basic model upper price limit. 

=--

12% 

6% 

0% 0% 0% 

0% 

199 467 

333 602 870 1138 1407 

Plice (dollars per unit) 

Figure 4-4. Sales by Retail Price: Refrigerator-Freezers with Side-Mount Freezer 

Of the 302 top-mount models under $1100,143 models feature TID ice service and do 

not meet current Energy Star levels. Thus, the Department considered these 143 models to be 

baseline models. Table 4-2 shows the sales-weighted baseline prices associated with three 

capacity size ranges of side-mount refrigerator freezers. Capacities are in total refrigerated 

volume. 

4-13 
Table 4-2. Baseline Retail Prices: Refrigerator-Freezers with Side-Mount Freezer and with

TTD Ice Service

4.2.2 Incremental Retail Prices based on Incremental Manufacturing Costs

4.2.2.1 Incremental Manufacturing Costs

As detailed in chapter 2 on the engineering analysis, the Association of Home Appliance

Manufacturers (AHAM) collected manufacturing cost data from manufacturers of refrigeratorfreezers.2 The data provided the incremental manufacturing cost of achieving energy use levels

15 percent and 25 percent lower than current baseline levels. The incremental manufacturing

cost data provided by AHAM to the Department were for three size ranges of refrigeratorfreezers with top-mounted freezers and without TTD ice service, as well as three size ranges of

refrigerator-freezers with side-mounted freezer and with TTD ice service. For each capacity

size category, a minimum, average, and maximum incremental manufacturing cost was provided.

The incremental manufacturing cost data are summarized in Table 4-3 for top-mount

refrigerator-freezers and in Table 4-4 for side-mount refrigerator-freezers.

Table 4-3. Incremental Manufacturing Costs: Refrigerator-Freezers with Top-Mount

Freezer and without TTD Ice Service

25% less energy

Source: AHAM..

$64.00

$1.9.04

$187.801$359.00 $18.00 $54.10 $141.00 $40.00

$21.21

$78.29 1$139.00

Table 4-4. Incremental Manufacturing Costs: Refrigerator -Freezers with Side-Mount

Freezer and with TTD Ice Service

15% less energy $5.00 1 $26.88 1 $95.00 I $5.00 I $17.67 1$105.00

25% less energy $6.00 $126.40 $219.00 $30.00 1 $99.63 $305.00

Source: AHAM.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 4-2. Baseline Retail Prices: Refrigerator-Freezers with Side-Mount Freezer and with 

TTD Ice Service 

Source: The NPD GrouplNPD Housewor1cl- POS. 

4.2.2 Incremental Retail Prices based on Incremental Manufacturing Costs 

4.2.2.1 Incremental Manufacturing Costs 

As detailed in chapter 2 on the engineering analysis, the Association of Home Appliance 

Manufacturers (AHAM) collected manufacturing cost data from manufacturers of refrigeratorfreezers. 2 The data provided the incremental manufacturing cost of achieving energy use levels 

15 percent and 25 percent lower than current baseline levels. The incremental manufacturing 

cost data provided by AHAM to the Department were for three size ranges of refrigeratorfreezers with top-mounted freezers and without TTD ice service, as well as three size ranges of 

refrigerator-freezers with side-mounted freezer and with TTD ice service. For each capacity 

size category, a minimum, average, and maximum incremental manufacturing cost was provided. 

The incremental manufacturing cost data are summarized in Table 4-3 for top-mount 

refrigerator-freezers and in Table 4-4 for side-mount refrigerator-freezers. 

Table 4-3. Incremental Manufacturing Costs: Refrigerator-Freezers with Top-Mount 

Freezer and without TTD Ice Service 

D <>.1 ¢ "'00'%;/ 2 '"'$!~ j ~~"'~ 1'-17 cu. It: £ :". " ,18 .. 20 cu. It:"" 

, 

" %t 21-22 ~t J. « '" '"' ~"i 0%~g0;; q?'d,,/%;}~ *'-' ~ "" -%'.~ '>/;';5;; 

~ /'~ ~/ %00 '" x ' , " 11' &' • 

*"'Y 

!fjif~rgy I.Js~"lleyel;~~ Min. J\.Yg. ': Max. x .Min.pi ~vg. ~::Max. Min. ~vg;1 Max. g 

15% less energy $8.00 $19.04 $26.00 $8.00 $17.31 $400.00 $10.00 $21.21 $37.00 

25 % less energy $64.00 $187.80 $359.00 $18.00 $54.10 $141.00 $40.00 $78.29 $139.00 

Source: AHAM. 

Table 4-4. Incremental Manufacturing Costs: Refrigerator-Freezers with Side-Mount 

Freezer and with TTD Ice Service 

25 % less energy $6.00 $126.40 $219.00 $30.00 Insufficient Data 

Source: AHAM. 

4-14 
#4®7

4.2.2.2 Manufacturer-to-Consumer Markup

The manufacturer-to-consumer markup is a multiplier used to convert manufacturing

costs into consumer retail prices. For this analysis, the Department estimated this markup from a

prior technical support document (TSD) the Department published in 1995 to assess whether

amended energy conservation standards were warranted for refrigerator-freezers.' Table 4-5

shows the manufacturing costs, retail prices, and deduced markups developed from this prior

analysis for baseline top-mount and side-mount refrigerator freezers. The deduced markup is the

retail price divided by the manufacturing cost.

Table 4-5. Manufacturer-to-Consumer Markups for Refrigerator-Freezers

,rf

i 1w rr3 t°_ ., ^ A -^ r

Top-Mount Freezer without TTD Ice Service $259.53 $554. 67*W 2.14

Side-Mount Freezer with TTD Ice Service $597.41 ' $ 1161.51" 1.94

Source: DOE 1995 TSD. Table 3.5.; Source : DOE 1995 TSD. Table 4.1.

Source : DOE 1995 TSD. Table 3.8.; Source: DOE 1995 TSD. Table 4.4.

Because the deduced markups for both of the above product classes of refrigeratorfreezers are approximately 2.0, the Department chose to use a manufacturer-to-consumer markup

of 2.0 for this analysis. The Department assumed this markup to include all sales taxes.

4.2.2.3 Resultant Incremental Retail Prices

Based on the manufacturer-to-consumer markup of 2.0, the incremental manufacturing

costs in. Tables 4-3 and 4-4 can be converted to incremental consumer retail prices. The

incremental retail price data are summarized in Table 4-6 for top-mount refrigerator-freezers and

in Table 4-7 for side-mount refrigerator-freezers.

Table 4-6. Manufacturing Cost-Based Incremental Retail Prices: Refrigerator -Freezers

with Top-Mount Freezer and without TTD Ice Service

15% less energy

25% less energy

$16.00 1 $38.08 1 $52.00 1 $16.00 1 $34.62 1$800.001 $20.00

$128.00 $375.60 $718.00 $36.00 $108.20 $282.00 $80.00 $156.58

Table 4-7. Manufacturing Cost-Based Incremental Retail Prices: Refrigerator-Freezers

with Side-Mount Freezer and with TTD Ice Service

15% less energy

25% less energy

$10.00 1 $53.76 1$190.001 $1.00 1 $35.34 1$210.00

$12.00 $252.80 $438.00 $60.00 $199.26 $610.00

4-15

 EE-PS-2006-001 COMMENT 04.7

#4.7 

4.2.2.2 Manufacturer-to-Consumer Markup 

The manufacturer-to-consumer markup is a multiplier used to convert manufa9tllfing 

costs into consumer retail prices. For this analysis, the Department estimated this rnat~p from a 

prior technical support document (TSD) the Department published in 1995 to assessvJhether 

amended energy conservation standards were warranted for refrigerator-freezers.3 Table 4-5 

shows the manufacturing costs, retail prices, and deduced markups developed from this prior 

analysis for baseline top-mount and side-mount refrigerator freezers. The deduced ~kup is the 

retail price divided by the manufacturing cost. 

Table 4-5. Manufacturer-to-Consumer Markups for Refrigerator-Freezers 

Top-Mount Freezer without TTD Ice Service $259.53* 

Side-Mount Freezer with TTD Ice Service $597.41 t 

, Source: DOE 1995 TSD. Table 3.5.; ** Source: DOE 1995 TSD. Table 4.1. 

I Source: DOE 1995 TSD. Table 3.8.; H Source: DOE 1995 TSD. Table 4.4. 

$554.67** 2.14 

$1161.51tt 1.94 

Because the deduced markups for both of the above product classes of refrigeratorfreezers are approximately 2.0, the Department chose to use a manufacturer-to-consumer markup 

of 2.0 for this analysis. The Department assumed this markup to include all sales taxes. 

4.2.2.3 Resultant Incremental Retail Prices 

Based on the manufacturer-to-consumer markup of 2.0, the incremental manufacturing 

costs in Tables 4-3 and 4-4 can be converted to incremental consumer retail prices. The 

incremental retail price data are summarized in Table 4-6 for top-mount refrigerator-freezers and 

in Table 4-7 for side-mount refrigerator-freezers. 

Table 4-6. Manufacturing Cost-Based Incremental Retail Prices: Refrigerator-Freezers 

with Top-Mount Freezer and without TTD Ice Service 

15% less energy $16.00 $38.08 $52.00 $16.00 $34.62 $800.00 $20.00 $42.42 $74.00 

25 % less energy $128.00 $375.60 $718.00 $36.00 $108.20 $282.00 $80.00 $156.58 $278.00 

Table 4-7. Manufacturing Cost-Based Incremental Retail Prices: Refrigerator-Freezers 

with Side-Mount Freezer and with TTD Ice Service 

25 % less energy $12.00 $252.80 $438.00 $60.00 $199.26 $610.00 Insufficient Data 

4-15 
4.2.3 Incremental Retail Prices based on Regression Analysis

The Department performed a regression analysis of basic top-mount and side-mount

refrigerator-freezer models from The NPD Group dataset to estimate the incremental retail price

of current Energy Star compliant products (i.e., products with 15 percent less energy

consumption than baseline products). As described earlier in section 3.2.1, Baseline Retail

Price, there are 387 basic top-mount models and 302 basic side-mount models.

The Department developed regression equations to determine the retail price increment

due to Energy Star. It developed a "short" regression equation with retail price as a function of

Energy Star and total capacity as well as a "long" regression equation with retail price as a

function of Energy Star, total capacity, attributes (i.e., TTD services, icemaker, water filter,

drawer, and shelf specifications) and brand name. The Department developed the "long"

regression equations with and without weighting refrigerator-freezer models by sales in 2004.

As shown in Table 4-8, the current Energy Star rating adds between $39 and $47 to the

price of a basic top-mount refrigerator-freezer and between $60 and $85 to the price of a basic

side-mount refrigerator-freezer.

Table 4-8. Regression Analysis Results on the Incremental Retail Price of Energy Star

Top-Mount Equations

"Short" Regression: Energy Star, total capacity

Price $47.40 0.24 387

"Long" Regression: Energy Star, total capacity, attribute, and brand name

Price

Price, sales-weighted

$44.39

$39.30

0.42

0.83

387

387

Side-Mount Equations

"Short" Regression: Energy Star, total capacity

Price $65.80 0.03 302

"Long" Regression: Energy Star, total capacity, attribute, and brand name

Price

Price, sales-weighted

$60.40

$84.90

0.11

0.51

302

302

Source: The NPD Group/NPD Houseworld - POS.

The results of the complete variable regression equations are included in Appendix B.

The estimated coefficients of the focus variables are significant and have the expected sign in all

but one instance.b The attribute variable coefficients have the expected sign in most cases, but

b The statistic of significance in the un-weighted regressions is the t statistic, defined as the estimated value of the

coefficient divided by its estimated standard deviation. Commonly, a t statistic over 2 suggests a coefficient to be

greater than zero with a high degree of confidence. In the sales-weighted regressions, a similar z statistic is used to

denote significance of the estimated coefficient.

4-16

 EE-PS-2006-001 COMMENT 04.7

#4.7 

4.2.3 Incremental Retail Prices based on Regression Analysis 

The Department performed a regression analysis of basic top-mount and side-mount 

refrigerator-freezer models from The NPD Group dataset to estimate the incremental retail price 

of current Energy Star compliant products (i.e., products with 15 percent less energy 

consumption than baseline products). As described earlier in section 3.2.1, Baseline Retail 

Price, there are 387 basic top-mount models and 302 basic side-mount models. 

The Department developed regression equations to determine the retail price increment 

due to Energy Star. It developed a "short" regression equation with retail price as a function of 

Energy Star and total capacity as well as a "long" regression equation with retail price as a 

function of Energy Star, total capacity, attributes (i.e., TID services, icemaker, water filter, 

drawer, and shelf specifications) and brand name. The Department developed the "long" 

regression equations with and without weighting refrigerator-freezer models by sales in 2004. 

As shown in Table 4-8, the current Energy Starrating adds between $39 and $47 to the 

price of a basic top-mount refrigerator-freezer and between $60 and $85 to the price of a basic 

side-mount refrigerator-freezer. 

Table 4-8. Regression Analysis Results on the Incremental Retail Price of Energy Star , I I" %i!t iENERtiYST "@ 

• \It ~ I % / ~ *1 '0 /0~vc M;;: v~, Wff " // " , 0~ ~2 'f.~igt ,., "'iii/X ~ ,;;J;:&;; 

Rfi';;sion fit - N:mberJfr ~ / 

/ Y /, :7~ Coefficient ,L I," p i~'>":;;0WJ/ :;0 twt 

, :~/,~~b/: ' /' 

~& "C~h 1 ~f:s?~~11j1x /~ ;#; %,1" "s;\ /;; Ilf ~0 v 2 Observatiols i!fI /? d~pric~AENERGY 0" R _";;,;R » % 'if"%; 

Top-Mount Equations 

"Short" Regression: Energy Star, total capacity 

Price $47.40 0.24 387 

"Long" Regression: Energy Star, total capacity, attribute, and brand name 

Price $44.39 0.42 387 

Price, sales-weighted $39.30 0.83 387 

Side-Mount Equations 

"Short" Regression: Energy Star, total capacity 

Price $65.80 0.03 302 

"Long" Regression: Energy Star, total capacity, attribute, and brand name 

Price $60.40 0.11 302 

Price, sales-weighted $84.90 0.51 302 

Source: The NPD Group/NPD Houseworld - POS. 

The results of the complete variable regression equations are included in Appendix B. 

The estimated coefficients of the focus variables are significant and have the expected sign in all 

but one instance.b The attribute variable coefficients have the expected sign in most cases, but 

b The statistic of significance in the un-weighted regressions is the t statistic, defined as the estimated value of the 

coefficient divided by its estimated standard deviation. Commonly, a t statistic over 2 suggests a coefficient to be 

greater than zero with a high degree of confidence. In the sales-weighted regressions, a similar z statistic is used to 

denote significance of the estimated coefficient. 

4-16 
#4.7

are less often significant. Although all the variables in the sales-weighted regressions are shown

to be significant at the 95 percent confidence level, the test of significance is biased upwards

because the dependent variable (retail price) is averaged over all model sales.

The Department chose the non-sales-weighted "long" regression equation as providing

the most representative retail price increment for Energy Star (i.e., $44.39 for top-mount and

$60.40 for side-mount). As just noted, the sales-weighted regressions include a bias, since the

retail price associated with any given model is actually an average value averaged across all sales

of the given model.. Thus, the results from the sales-weighted regression are biased to overrepresent the average retail price rather than the actual retail price. The Department chose the

non-sales-weighted "long" regression equation over the non-sales-weighted "short" regression

equation because the attribute and brand names variables influence the retail price of refrigerator

models. Including these variables tends to improve the accuracy of the retail price coefficient.

The retail price increment for Energy Star determined from the non-sales-weighted

"long" regressions is associated with specific capacities (i.e., total refrigerated volumes). For

top-mount refrigerator-freezers the $44.39 price increment is for an 18.3 cubic foot capacity unit

while, for side-mount products, the $60.40 price increment is for a 24.1 cubic foot capacity unit.

The non-sales-weighted "long" regressions also demonstrate that the size or total capacity of the

refrigerator-freezer impacts the price. The price coefficient for capacity is $5.97 per cubic foot

and $6.30 per cubic foot for top-mount and side-mount refrigerator-freezers, respectively.

Because the regression analysis provided a capacity price increment as well as an Energy Star

price increment, the Department was able to generate incremental retail prices for each of the

size categories in which manufacturing cost data were submitted (refer back to Table 4-3 and

Table 4-4 for the size categories). Equations 4.2 and 4.3 provide the expressions for determining

the retail price increment of Energy Star for top-mount and side-mount refrigerator-freezers,

respectively.

TM PRICE FSTAR = $44.3 9 +(TM cAPAciTY - 18.3 ) • $5.97

where:

TMPRICE ESTAR = top-mount Energy Star price increment at TMcAPACJTY,

$44.39 = Energy Star price increment for top-mount at 18.3 cu. ft.,

TMCAPACITY = capacity in cu. ft. of top-mount refrigerator-freezer,

18.3 = top-mount capacity for $44.39 Energy Star price increment, and

$5.97 = top-mount price coefficient for capacity per cu. ft.

Eq. 4.2

SMPRICE ESTAR = $60.40+(SMCAPACITY - 24.1) • $6.30 Eq. 4.3

 EE-PS-2006-001 COMMENT 04.7

#4.7 

are less often significant. Although all the variables in the sales-weighted regressions are shown 

to be significant at the 95 percent confidence level, the test of significance is biased upwards 

because the dependent variable (retail price) is averaged over all model sales. 

The Department chose the non-sales-weighted "long" regression equation as providing 

the most representative retail price increment for Energy Star (i.e., $44.39 for top-mount and 

$60.40 for side-mount). As just noted, the sales-weighted regressions include a bias, since the 

retail price associated with any given model is actually an average value averaged across all sales 

of the given model. Thus, the results from the sales-weighted regression are biased to overrepresent the average retail price rather than the actual retail price. The Departmentchose the 

non-sales-weighted "long" regression equation over the non-sales-weighted "short" regression 

equation because the attribute and brand names variables influence the retail price of refrigerator 

models. Including these variables tends to improve the accuracy of the retail price coefficient. 

The retail price increment for Energy Star determined from the non-sales-weighted 

"long" regressions is associated with specific capacities (i.e., total refrigerated volumes). For 

top-mount refrigerator-freezers the $44.39 price increment is for an 18.3 cubic foot capacity unit 

while, for side-mount products, the $60.40 price increment is for a 24.1 cubic foot capacity unit. 

The non-sales-weighted "long" regressions also demonstrate that the size or total capacity of the 

refrigerator-freezer impacts the price. The price coefficient for capacity is $5.97 per cubic foot 

and $6.30 per cubic foot for top-mount and side-mount refrigerator-freezers, respectively. 

Because the regression analysis provided a capacity price increment as well as an Energy Star 

price increment, the Department was able to generate incremental retail prices for each of the 

size categories in which manufacturing cost data were submitted (refer back to Table 4-3 and 

Table 4-4 for the size categories). Equations 4.2 and 4.3 provide the expressions for determining 

the retail price increment of Energy Star for top-mount and side-mount refrigerator-freezers, 

respectively. 

TM PRICE ESTAR = $44.39+(TM CAPACITY -18.3)· $5.97 

where: 

TMpRICE ESTAR 

$44.39 

TMCAPAClTY 

18.3 

. $5.97 

= top-mount Energy Star price increment at TMcAPACITY, 

= Energy Star price increment for top-mount at 18.3 cu. ft., 

= capacity in cu. ft. oftop-mount refrigerator-freezer, 

= top-mount capacity for $44.39 Energy Star price increment, and 

= top-mount price coefficient for capacity per cu. ft. 

SM PRICE ESTAR = $60.40 + (SM CAPACITY - 24.1)· $6.30 

4-17 

Eq.4.2 

Eq.4.3 
where:

SMPRICEESTAR = side-mount Energy Star price increment at SMCAPACITY,

$60.40 = Energy Star price increment for side-mount at 24.1 cu. ft.,

SMCAPACITY = capacity in cu. ft. of side-mount refrigerator-freezer,

24.1 = side-mount capacity for $60.40 Energy Star price increment, and

$6.30 = side-mount price coefficient for capacity per cu. ft.

Table 4-9 and Table 4-10 show the incremental retail price of achieving current Energy

Star levels (i.e., 15 percent lower energy consumption than baseline products) for size categories

in which manufacturing costs were submitted. To calculate the price increments shown in the

tables below, the Department assumed the average value of the capacity range is the

representative size (e.g., 15.5 cubic feet for the 14-17 cubic foot size category). Note that the

Department could not establish the price increment of products with 25 percent less energy, as

these products are currently not sold in significant numbers and were therefore not included in

the dataset provided by The NPD Group.

Table 4-9. Regression Analysis Incremental Retail Prices: Refrigerator -Freezers with

Top-Mount Freezer and without TTD Ice Service

Source: The NPD Group/NPD Houseworld - POS.

Table 4-10. Regression Analysis Incremental Retail Prices : Refrigerator-Freezers with

Side-Mount Freezer and with TTD Ice Service

Source: The NPD Group/NPD Houseworld - POS.

4.2.4 Comparison of Manufacturing Cost-Based and Regression Analysis Retail Prices

Figure 4-5 and Figure 4-6 provide the consumer retail price estimates for top-mount and

side-mount refrigerator-freezers, respectively. For the retail prices based on manufacturing

costs, the figures provide prices based not only on average cost estimates, but for minimum and

maximum cost estimates as well. Retail price comparisons are only possible for the 15 percent

less energy standard level, since the regression analysis was only able to generate prices for this

energy consumption level. In general, the retail price estimates based on the average

manufacturing cost estimates and the regression analysis are similar. For top-mount refrigeratorfreezers, the difference in the retail price estimates between the two approaches ranges from $11.

to $21. For side-mount refrigerator-freezers, the difference between the two approaches is

4-18

 EE-PS-2006-001 COMMENT 04.7

where: 

SMpRICE ESTAR 

$60.40 

SMCAPACITY 

24.1 

$6.30 

= side-mount Energy Star price increment at SMCAPACITY, 

= Energy Star price increment for side-mount at 24.1 cu. ft., 

= capacity in cu. ft. of side-mount refrigerator-freezer, 

#4.7 

= side-mount capacity for $60.40 Energy Star price increment, and 

= side-mount price coefficient for capacity per cu. ft. 

Table 4-9 and Table 4-10 show the incremental retail price of achieving CUlTent Energy 

Star levels (i.e., 15 percent lower energy consumption than baseline products) for size categories 

in which manufacturing costs were submitted. To calculate the price increments shown in the 

tables below, the Department assumed the average value ofthe capacity range is the 

representative size (e.g., 15.5 cubic feet for the 14-17 cubic foot size category). Note that the 

Department could not establish the price increment of products with 25 percent less energy, as 

these products are currently not sold in significant numbers and were therefore not included in 

the dataset provided by The NPD Group. 

Table 4-9. Regression Analysis Incremental Retail Prices: Refrigerator-Freezers with 

Top-Mount Freezer and without TTD Ice Service 

Source: The NPD Group/NPD Houseworld - POS. 

Table 4-10. Regression Analysis Incremental Retail Prices: Refrigerator-Freezers with 

Side-Mount Freezer and with TTD Ice Service 

Source: The NPD Group/NPD Houseworld - POS. 

4.2.4 Comparison of Manufacturing Cost-Based and Regression Analysis Retail Prices 

Figure 4-5 and Figure 4-6 provide the consumer retail price estimates for top-mount and 

side-mount refrigerator-freezers, respectively. For the retail prices based on manufacturing 

costs, the figures provide prices based not only on average cost estimates, but for minimum and 

maximum cost estimates as well. Retail price comparisons are only possible for the 15 percent 

less energy standard level, since the regression analysis was only able to generate prices for this 

energy consumption level. In general, the retail price estimates based on the average 

manufacturing cost estimates and the regression analysis are similar. For top-mount refrigeratorfTeezers, the difference in the retail price estimates between the two approaches ranges from $11 

to $21. For side-mount refrigerator-freezers, the difference between the two approaches is 

4-18 
#4®7

broader. While the 21-23 and 24-26 cubic foot size categories have price differences of $7 and

$31, respectively, the 27-30 cubic foot size category has a price difference of $96.

$800

$700

$600

$500

O

v

$400

(L

$300

A)

it

$200

$100

$0

El Mfg Cost Min

E3 Kffg Cost Avg

f Mfg Cost Max

El Regress

LOWCOLn 'Itm

Ent-f-.

$1,047 $1,186

oN

11

00

Ica ._...

Ns9.;

N CV CV

M (9 \

I

\q

N

m

a) LOCq Ln

.

I%

I

r

Baseline 15% less 25% less Baseline 15% less 25% less Baseline 15% less 25% less

energy energy energy energy energy energy

14-17 cu.8. 18-20 cu.ft. 21-22 cu.ft.

Figure 4-5. Retail Prices for Refrigerator-Freezers with Top-Mount Freezer and without

TTD Ice Service

4-19

 EE-PS-2006-001 COMMENT 04.7

#4.7 

broader. While the 21-23 and 24-26 cubic foot size categories have price differences of $7 and 

$31, respectively, the 27-30 cubic foot size category has a price difference of $96. 

$800 

Ila Mig Cost Min 

$700 ... 

II Mig Cost Avg 

$600 

{i):' 

Ililll Regress 

In 

0 $500 0 

~ 

CJ.) 

t> $400 .;: 

ll. 

·m $300 

a:; 

cc 

$200 

$100 

$0 

Baseline 15% less 25% less Baseline 15% less 25% less Baseline 15% less 25% less 

energy energy energy energy energy energy 

'- V .J '- 'V' .J '- V .J 

14-17 cu.ft. 18-20 cu.ft. 21-22 cu.ft. 

Figure 4-5. Retail Prices for Refrigerator-Freezers with Top-Mount Freezer and without 

TTD Ice Service 

4-19 
$1,2001

$1,000

$800 ^

$600 -{

$400 -{

$200

• Mfg Cost Mn

Mfg Cost Avg

® Mfg Cost Max

Regress

NN...

<f}

C)

Co

ffl

co \ O

NUJ ,,U) •It

ff;

l

Z/Z

r

O

C)

Co

N.

H)

P"1

U

V/1

k

A

L-A

co

N.

(R

Baseline 15% less 25% less Baseline 15% less 25% less Baseline 15% less

energy energy energy energy energy

21-23 cu.ft. 24-26 cu.ft. 27-30 cu.ft.

Figure 4-6. Retail Prices for Refrigerator-Freezers with Side-Mount Freezer and with

TTD Ice Service

4.2.5 Focused Matched Pair Analysis

The Department conducted a focused matched pair analysis to quantify the difference in

consumer retail price for a matched pair of refrigerators that are very similar in features except

for annual energy consumption.

Both manufacturer and retailer web sites provide detailed information on features for

each model, including retail price and energy consumption. The Department selected eight pairs

of top-mount models and four pairs of side-mount models for comparison. The process it used

for finding matching pairs was as follows:

• At the manufacturer's web site, the Department narrowed the selection shown to those

having a common capacity or total refrigerated volume.

• The Department examined other features such as whether or not a refrigerator had an icemaker, water filter, or TTD ice and/or water service. Other features considered in

comparisons included glass versus wire shelves, and the number of shelves in the

refrigerator and freezer compartments.

• The Department obtained fresh food volumes and freezer volumes from the

manufacturer's web site and calculated an adjusted total volume based on the

Department's test procedure. The Department used the adjusted total volume to calculate

4-20

 EE-PS-2006-001 COMMENT 04.7

#4.7 

~ Mig Cost Min 0 

$1,200 '<t 

II Mig Cost Avg 

$1,000 II Regress 

U; $800 I/') 

0 

0 

~ 

G) 

(,) $600 .;:: 

n. 

'iii 

-

G) $400 

a: 

$200 

$0 

Baseline 15% less 25% less Baseline 15% less 25% less Baseline 15% less 

energy energy energy energy energy 

'- ./ ...... J \. J 

""'" 'V'" V' 

21-23 cu.ft. 24-26 cu. ft. 27-30 cu.ft. 

Figure 4-6. Retail Prices for Refrigerator-Freezers with Side-Mount Freezer and with 

TTD Ice Service 

4.2.5 Focused Matched Pair Analysis 

The Department conducted a focused matched pair analysis to quantify the difference in 

consumer retail price for a matched pair of refrigerators that are very similar in features except 

for annual energy consumption. 

Both manufacturer and retailer web sites provide detailed information on features for 

each model, including retail price and energy consumption. The Department selected eight pairs 

of top-mount models and four pairs of side-mount models for comparison. The process it used 

for finding matching pairs was as follows: 

• At the manufacturer's web site, the Department narrowed the selection shown to those 

having a common capacity or total refrigerated volume. 

• The Department examined other features such as whether or not a refrigerator had an icemaker, water filter, or TTD ice and/or water service. Other features considered in 

comparisons included glass versus wire shelves, and the number of shelves in the 

refrigerator and freezer compartments. 

• The Department obtained fresh food volumes and freezer volumes from the 

manufacturer's web site and calculated an adjusted total volume based on the 

Department's test procedure. The Department used the adjusted total volume to calculate 

4-20 
#4,7

the current maximum allowable annual electricity consumption for each refrigeratorfreezer. The Department also determined the Energy Star maximum allowable electricity

consumption threshold. (A detailed discussion of adjusted total volume and annual

electricity consumption is in section 3.3.1.1.)

The Department found no two models where, except for one being Energy Star, all other

features were the same. Therefore, the Department used its judgment to select two

models close enough for comparison. To eliminate price difference due to color, DOE

used only the color white for comparison.

Once it had selected the matched pairs, the Department entered the pertinent data on

energy consumption and features into a spreadsheet and determined the difference in energy

consumption for each pair. It collected retail price data from nine web sites, including the

manufacturer and eight retailers. The retail prices used by the Department were the

manufacturer's suggested retail price and, at the retail sites, the advertised selling price. The

detailed energy consumption, features, and retail price data for the matched pairs are in

Appendix C.

Table 4-11 and Table 4-12 summarize the results for the top-mount refrigerator-freezers

and the side-mount refrigerator-freezers, respectively. The model designated as Baseline

achieves or exceeds the current energy efficiency standards but is not an Energy Star model. In

the "Delta Price" column, the range refers to the retail prices from the web sites. The number of

web sites giving retail prices varied among the models. Where no range is given, the retail price

is that from the manufacturer. The "Average Incremental Price" for Energy Star refers to the

difference between the average retail prices of each matched pair.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

the current maximum allowable annual electricity consumption for each refrigenitor-: 

freezer. The Department also determined the Energy Star maximum allowable electricity 

consumption threshold. (A detailed discussion of adjusted total volume and annual 

electricity consumption is in section 3.3.1.1.) 

• The Department found no two models where, except for one being Energy Star, all other 

features were the same. Therefore, the Department used its judgment to select two 

models close enough for comparison. To eliminate price difference due to color, DOE 

used only the color white for comparison. 

Once it had selected the matched pairs, the Department entered the pertinent data on 

energy consumption and features into a spreadsheet and determined the difference in energy 

consumption for each pair. It collected retail price data from nine web sites, including the 

manufacturer and eight retailers. The retail prices used by the Department were the 

manufacturer's suggested retail price and, at the retail sites, the advertised selling price. The 

detailed energy consumption, features, and retail price data for the matched pairs are in 

Appendix C. 

Table 4-11 and Table 4-12 summarize the results for the top-mount refrigerator-freezers 

and the side-mount refrigerator-freezers, respectively. The model designated as Baseline 

achieves or exceeds the current energy efficiency standards but is not an Energy Star model. In 

the "Delta Price" column, the range refers to the retail prices from the web sites. The number of 

web sites giving retail prices varied among the models. Where no range is given, the retail price 

is that from the manufacturer. The "Average Incremental Price" for Energy Star refers to the 

difference between the average retail prices of each matched pair. 

4-21 
#497

Table 4-11. Comparison of Matched Pairs: Refrigerator-Freezers with Top-Mount Freezer

and without TTD Ice Service

i

L r ,

.T

^

^f .,r ^;1 n:`I 1^ ^J l1^.

ll y p

1 "

Baseline GTS22KBPWW 21.7 81

Energy Star GE GTH22KKBRWW 21.7 15.3% $30-$50 $40 5.4%

Baseline Frigidaire FRT21C5A 20.5 77

Energy Star FRT21HC5D 20.6 15.1 % $95-$100 $98 22.3%

Baseline ETIMHKXM 21.0 71

Energy Star Whirlpool ETIMTEXM 21.0 13.8% $44-$160 $93 17.0%

Baseline 74192 20.6 77

Energy Star Kenmore 74172 20.6 15.1 % $50-$ 180 $115 23.0%

Baseline Whirlpool ET8MHKXM 1.8.2 72

Energy Star ET8FTEXM 18.2 14.9% $0-$60 $44 8.8%

Baseline GTSI8KBPWW 17.9 72

Energy Star GE GTH18BRWW 17.9 14.9% $20-$25 $23 3.4%

Baseline GTR16BBSRWW 15.7 69

Energy Star GE GTH16BBSLWW 15.7 15.2% $30 $30 5.2%

Baseline

GE

GTR15BBR 14.9 67

Energy Star GTH15BBR 14.9 15.0% $0-$30 $15 2.7%

Table 4-12. Comparison of Matched Pairs: Refrigerator-Freezers with Side-Mount

Freezer and with TTD Ice Service

i r C: v5 7 ^. 1} 1F. 1

Baseline PSI23NGPWW GE Profile 22.6 102

Energy Star PSH23PGRWW 22.6 14.9% $250 $250 9.6%

Baseline GSS25KGPWW 24.9 105

Energy Star

GE

GSH25KGRWW 25.0 14.7% (` 3)-$50 $24 1.9%

Baseline GLRS267ZD 25.7 109 $100-

Energy Star Frigidaire GLHS268ZD 26.0 15.0% $ 160 $126 11.9%

Baseline ASD2622HRW 25.6 88

Energy Star Amana ASD2624HEW 25.6 12.5%° $50-$100 $62 6.7%

The results from Table 4-11 and Table 4-12 show that the difference in energy use

between Baseline and Energy Star models in each matched pair is similar among the pairsgenerally around 15 percent. The difference in retail price (incremental retail price) varies

considerably, however.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 4-11. Comparison of Matched Pairs: Refrigerator-Freezers with Top-Mount Freezer 

and without TTD Ice Service 

IS.3% $30-$50 $40 5.4% 

Frigidaire FRT21CSA 77 

FRT2IHCSD 15.1% $95-$100 $98 22.3% 

Whirlpool ETlMHKXM 21.0 71 

ETlMTEXM 21.0 13.8% $44-$160 $93 17.0% 

Kenmore 74192 20.6 77 

74172 20.6 15.1% $SO-$180 $l1S 23.0% 

Whirlpool ET8MHKXM 18.2 72 

ET8FTEXM 18.2 14.9% $0-$60 $44 8.8% 

GE GTS18KBPWW 17.9 72 

GTH18BRWW 17.9 14.9% $20-$25 $23 3.4% 

GE GTR16BBSRWW 15.7 69 

GTH16BBSLWW IS.7 IS.2% $30 $30 5.2% 

GE GTRlSBBR 14.9 67 

GTH1SBBR 14.9 IS.0% $0-$30 $IS 2.7% 

Table 4-12. Comparison of Matched Pairs: Refrigerator-Freezers with Side-Mount 

Freezer and with TTD Ice Service 

~ 

-'<~I" II'" j I~II Aw,ag' ,0 I.~ 'I ' , ' ~ 1i1<f. ' , .', "" 't % tal" ~ Delta "~,', i:: ,;: Incremental • '";'<i~x '" (0 "'" ,,0 "" , " ~ '(/ 2 J?,}"''' U&« lIi'llis"l, Energy Use Deltil'''' Delta, Price for ii, : '%4\~ 'c l' R e f:''''''~ r1gera 

~. ~ * ~I: v w~ iMoluIDe rtkWh/yr &: ,Price': ' Price' Energy Star _&{~ i$~? it ~J;h~ J 

Category mand ,~, MOdel N umbep", ( cli'fJitlld, ~'flercellt)' Range Average (Percellt) 

Baseline GE Profile PSI23NGPWW 22.6 102 

Energy Star PSH23PGRWW 22.6 14.9% $250 $250 9.6% 

Baseline GE GSS25KGPWW 24.9 105 

Energy Star GSH2SKGRWW 2S.0 14.7% (S3)-$50 $24 1.9% 

Baseline Frigidaire GLRS267ZD 25.7 109 $100-

Energy Star GLHS268ZD 26.0 IS.0% $160 $126 11.9% 

Baseline Amana ASD2622HRW 2S.6 88 

Energy Star ASD2624HEW 25.6 12.S% $50-$100 $62 6.7% 

The results from Table 4-11 and Table 4-12 show that the difference in energy use 

between Baseline and Energy Star models in each matched pair is similar among the pairsgenerally around 15 percent. The difference in retail price (incremental retail price) varies 

considerably, however. 

4-22 
#4®7

There is no clear evidence that differences in features between a pair have a consistent

effect on price.' Pricing differences among retailers appears to be a factor. For some pairs, the

incremental price varied considerably among the web sites. It may be the case that the increased

retail price of an Energy Star refrigerator is affected by marketing decisions based on what

consumers are willing to pay for the Energy Star designation. Among the top-mount models, the

smaller-capacity pairs generally show a lower percentage incremental price than the larger pairs.

Also, the larger models have a higher incremental price for Energy Star but also have higher

incremental electricity consumption savings.

This matched pair analysis shows that: (1) there is a large variation in the incremental

retail price among matched pairs for a similar percentage improvement in energy efficiency, and

(2) the results are too varied to establish a clear relationship between retail price and efficiency.

Therefore, the Department believes that the matched pair analysis can best be used as a reality

check on the other two methods used to estimate consumer retail prices (i.e., the manufacturingcost-based method and the regression analysis). The incremental retail prices from the focused

matched pair analysis generally fall within the range of prices from the manufacturing-cost-based

method and the regression analysis.

4.3 LIFETIME ELECTRICITY COST

The lifetime electricity cost includes the annual electricity costs discounted over the

product lifetime at an appropriate discount rate. Elements of the Department's methodology for

performing this analysis are as follows:

® The analysis period starts in 2010, the assumed start year for possible new energy

conservation standards.

• The analysis uses electricity prices projected over the analysis period (see section 3.3.4,

Electricity Price Trends).

• The analysis discounts energy cost to the assumed start year for standards (2010).

• All. monetary results are in 2005$.

4.3.1 Annual Electricity Cost

The operating cost is the sum of the annual electricity costs plus any replacement or

maintenance costs. The annual electricity cost is the product of the annual electricity

consumption times the electricity price for any given year.

4.3.1.1 Annual Electricity Consumption

The Department calculated the annual electricity consumption (also called unit energy

consumption) for the capacity size categories for which manufacturing cost data were provided.

As noted earlier (section 3.2.2.1) manufacturing cost data were provided for three size ranges for

Examination of the prices at manufacturer web sites indicated that, for models of similar capacity, those with more

features did not consistently have a higher price.

4-23

 EE-PS-2006-001 COMMENT 04.7

#4.7 

There is no clear evidence that differences in features between a pair have a consistent 

effect on price. C Pricing differences among retailers appears to be a factor. For some pairs, the 

incremental price varied considerably among the web sites. It may be the case that the increased 

retail price of an Energy Star refrigerator is affected by marketing decisions based on what 

consumers are willing to pay for the Energy Star designation. Among the top-mount models, the 

smaller-capacity pairs generally show a lower percentage incremental price than the larger pairs. 

Also, the larger models have a higher incremental price for Energy Star but also have higher 

incremental electricity consumption savings. 

This matched pair analysis shows that: (1) there is a large variation in the incremental 

retail price among matched pairs for a similar percentage improvement in energy efficiency, and 

(2) the results are too varied to establish a clear relationship between retail price and efficiency. 

Therefore, the Department believes that the matched pair analysis can best be used as a reality 

check on the other two methods used to estimate consumer retail prices (i.e., the manufacturingcost-based method and the regression analysis). The incremental retail prices from the focused 

matched pair analysis generally fall within the range of prices from the manufacturing-cost-based 

method and the regression analysis. 

4.3 LIFETIME ELECTRICITY COST 

The lifetime electricity cost includes the annual electricity costs discounted over the 

product lifetime at an appropriate discount rate. Elements of the Depmtment's methodology for 

peliorming this analysis are as follows: 

• The analysis period stms in 2010, the assumed start year for possible new energy 

conservation standards. 

• The analysis uses electricity prices projected over the analysis period (see section 3.3.4, 

Electricity Price Trends). 

• The analysis discounts energy cost to the assumed stm year for standards (2010). 

• All monetary results are in 2005$. 

4.3.1 Annual Electricity Cost 

The operating cost is the sum of the annual electricity costs plus any replacement or 

maintenance costs. The annual electricity cost is the product of the annual electricity 

consumption times the electricity price for any given year. 

4.3.1.1 Annual Electricity Consumption 

The Depmtment calculated the annual electricity consumption (also called unit energy 

consumption) for the capacity size categories for which manufacturing cost data were provided. 

As noted earlier (section 3.2.2.1) manufacturing cost data were provided for three size ranges for 

C Examination of the prices at manufacturer web sites indicated that, for models of similar capacity, those with more 

features did not consistently have a higher price. 

4-23 
both top-mount and side-mount refrigerator-freezers. The size ranges were based on total

refrigerated volume (i.e., fresh food compartment volume plus freezer compartment volume).

The annual electricity consumption for refrigerator-freezers is a function of the adjusted

total volume rather than the total refrigerated volume. The equation for calculating the adjusted

total volume is:4

VolQdj = Vol7e fng + 1.63 - Volfree.Zer

Eq. 4.4

where:

Vol,di = adjusted total volume in cubic feet,

Vol,refrig = fresh food compartment volume in cubic feet,

1.63 = adjustment factor, and

VUlfreezer = freezer compartment volume in. cubic feet.

The Department had to determine representative freezer-volume-to-total -refrigerated-volume

(FV-TRV) ratios for each refrigerator-freezer size range to determine the adjusted total volume.

The Department determined representative ratios from the California Energy Commission's

(CEC) appliance database.5 For refrigerator-freezers sold in California, the appliance database

provides the fresh food, freezer, and total volumes. Table 4-13 and Table 4-14 provide the

minimum, average, and maximum FV-TVR ratios for top-mount and side-mount refrigeratorfreezers, respectively:

Table 4-13. Freezer-Volume-to-Total-Refrigerated-Volume: Refrigerator-Freezers with

Top-Mount Freezer and without TTD Ice Service

14-17 0.196 0.265 0.295

18-20 0.222 0.267 0.315

21-22 0.292 0.298 0.308

Source: CEC.

Table 4-14. Freezer-Volume-to-Total-Refrigerated-Volume: Refrigerator-Freezers with

Side-Mount Freezer and with TTD Ice Service

21-23 0.295 0.350 0.452

24-26 0.337 0.379 0.399

27-30 0.351 0.373 0.391

Source: CEC.

4-24

 EE-PS-2006-001 COMMENT 04.7

#4.7 

both top-mount and side-mount refrigerator-freezers. The size ranges were based on total 

refrigerated volume (i.e., fresh food compartment volume plus freezer compartment volume). 

The annual electricity consumption for refrigerator-freezers is a function ofthe adjusted 

total volume rather than the total refrigerated volume. The equation for calculating the adjusted 

total volume is: 4 

Vol adj = Vol r~frig + 1. 63 • Vol freezer 

where: 

Voladj 

Volrefrig 

1.63 

VOlfreezer 

= adjusted total volume in cubic feet, 

= fresh food compartment volume in cubic feet, 

= adjustment factor, and 

= freezer compartment volume in cubic feet. 

Eg.4.4 

The Department had to determine representative freezer-volume-to-total-refrigerated-volume 

(FV-TRV) ratios for each refrigerator-freezer size range to determine the adjusted total volume. 

The Department determined representative ratios from the California Energy Commission's 

(CEC) appliance database. 5 For refrigerator-freezers sold in California, the appliance database 

provides the fresh food, freezer, and total volumes. Table 4-13 and Table 4-14 provide the 

minimum, average, and maximum FV-TVR ratios for top-mount and side-mount refrigeratorfreezers, respectively~ 

Table 4-13. Freezer-Volume-to-Total-Refrigerated-Volume: Refrigerator-Freezers with 

Top-Mount Freezer and without TTD Ice Service 

Total R~fi~r~!~d x#~~' ~ x iFreez.olume-IP-TotalJJJefrigerated Eolume » X 

&8 

»q 

Volume R~lIe (cu. ft.~ x x Minimum Ratio'S ~erage Ratio ;;~ximum Ratio 

14-17 0.196 0.265 0.295 

18-20 0.222 0.267 0.315 

21-22 0.292 0.298 0.308 

Source: CEC. 

Table 4-14. Freezer-Volume-to-Total-Refrigerated-Volume: Refrigerator-Freezers with 

Side-Mount Freezer and with TTD Ice Service 

X .~£ , x '7' !JWt~< R' Irll 2%, 

, 110tal R~.~rate~ Ji;\,~ X(~x r"'~itx, :' iFreeliC olume~1'1'otal:;~ efngerated I! ume a xX 

Volume R~i~x(cu,; ft·t', '2" ~ Minimum Ratio ,;1" 'Iyerage Ratio / _ 

21-23 0.295 0.350 0.452 

24-26 0.337 0.379 0.399 

27-30 0.351 0.373 0.391 

Source: CEC. 

4-24 
#4®7

With the FV-TVR ratio known, the Department calculated the adjusted total volume. For

each size range, the Department used the mid-point of the range as the representative total

refrigerated volume, which, when coupled with the representative value for the FT-TVR ratio, it

used to calculate the adjusted total volume. Table 4-15 and Table 4-16 provide the

representative adjusted total volumes, as well as the components necessary for determining them,

for top-mount and side-mount refrigerators, respectively. The Department based the adjusted

total volumes on the average value for the FV-TVR ratio from Table 4-13 and Table 4-14.

Table 4-15. Adjusted Total Volumes: Refrigerator-Freezers with Top-MountFreezer and

without TTD Ice Service

Table 4-16. Adjusted Total Volumes: Refrigerator-Freezers with Side-Mount Freezer and

with TTD Ice Service

1+1i

..--..._..

,^/^ 1 i'1)t i1 ! P is ^(V_Y I.j 1ka3'^I'o^• 7 .; t;y

41

l 1 tY. a".Tf

1{9`t V

._..

!1111! a 1 k/ 1 1

21-23 22.0 0.350 7.7 14.3 26.9

24-26 25.0 0.379 9.5 15.5 31.0

27-30 28.5 0.373 10.6 17.9 35.2

With representative adjusted total volumes established for each size range, the

Department was able to determine the annual electricity consumption for baseline products and

products with 15 percent and 25 percent less energy consumption. The Department assumed the

baseline annual energy consumption for each size range to be equal to the current maximum

allowable annual energy consumption.6 The current maximum allowable annual energy

consumption for top-mount refrigerator-freezers without TTD ice service is:

TM UEC,,,aa = 9.8 ® Vol ad,' + 276 Eq. 4.5

 EE-PS-2006-001 COMMENT 04.7

#4.7 

With the FV -TVR ratio known, the Department calculated the adjusted total volume. For 

each size range, the Department used the mid-point of the range as the representative total 

refrigerated volume, which, when coupled with the representative value for the FT-TVRratio, it 

used to calculate the adjusted total volume. Table 4-15 and Table 4-16 provide the 

representative adjusted total volumes, as well as the components necessary for determining them, 

for top-mount and side-mount refrigerators, respectively. The Department based the adjusted 

total volumes on the average value for the FV-TVR ratio from Table 4-13 and Table 4-14. 

Table 4-15. Adjusted Total Volumes: Refrigerator-Freezers with Top-Mount Freezer and 

without TTD Ice Service 

~ ~ '"1 '" - I' , >, I ' I ~ I X~~\.' Toti!t,». J~d-~2IJ!: olJl If} Av~ e Fr~e0z~r,: '~yJ~ J,j 

,fv ~$l!riger~~. R/R,elEera0ll !" V~I~t2q!~1i!1- iFre~zer !§fcfsh Food Adjusted !l[o1ume Rangd ~NVolume Ran ~~0 R gerated-" I'olume ~l1c"olume Total Volume 

;,Ji~~bic f;~iia:rr~ '[c0ifb~ fe~' ~::i' I y~_~utii~.~ I (~~bi~ feet) I (~1ibic feet) I (cubic feet) 

14-17 15.5 0.265 4.1 11.4 18.1 

18-20 19.0 0.267 5.1 13.9 22.2 

21-22 21.5 0.298 6.4 15.1 25.5 

Table 4-16. Adjusted Total Volumes: Refrigerator-Freezers with Side-Mount Freezer and 

with TTD Ice Service 

, . "1" - I -. I I I ~q :~. / Total d?lff7\_ Mid-BOlnt of tal Ave e Ereezer- ' '/ /t~ 

, !priger" t'Reg'eral· vo"!<i~~I!Jt- iir':"" ,,:;;;"h Food Adjusted 

,!Vfj!lme !J!~~~j .rol~~ R

1

.' Re g~r~I~~~,q:, Volume 3folume Total Volume 

j':'(cubic feet?t"~'l~!'~q~cn1)i~ fee zy I _lum~ ~itii' I (cubic feet) I (cubic feet) I (cubic feet) 

21-23 22.0 0.350 7.7 14.3 26.9 

24-26 25.0 0.379 9.5 15.5 31.0 

27-30 28.5 0.373 10.6 17.9 35.2 

With representative adjusted total volumes established for each size range, the 

Department was able to determine the annual electricity consumption for baseline products and 

products with 15 percent and 25 percent less energy consumption. The Department assumed the 

baseline annual energy consumption for each size range to be equal to the current maximum 

allowable annual energy consumption.6 The current maximum allowable annual energy 

consumption for top-mount refrigerator-freezers without TTD ice service is: 

TM UECmax = 9.g-Vol alii +276 Eq.4.5 

4-25 
where:

TM UECmwc = maximum annual (or unit) electricity consumption in kilowatt-hours

(kWh) per year for top-mount refrigerator-freezers without TTD ice

service, and

VOladj = adjusted total volume in cubic feet.

The current maximum allowable annual energy consumption for side-mount refrigeratorfreezers with TTD ice service is:

SM UEC,,,ax =10.1 • Voladi + 406 Eq. 4.6

where:

SM UEClar = maximum annual (or unit) electricity consumption in kWh per year for

side-mount refrigerator-freezers with TTD ice service, and

Voladj = adjusted total volume in cubic feet.

To arrive at the annual energy consumption values corresponding to the 15 percent less energy

use and 25 percent less energy use levels, the Department reduced the baseline energy

consumption by 15 percent and 25 percent, respectively. Table 4-17 and Table 4-18 provide the

annual energy consumption values for baseline products and products with 15 percent and 25

percent less energy consumption for top-mount and side-mount refrigerator-freezers,

respectively.

Table 4-17. Annual Electricity Consumption: Refrigerator-Freezers with Top-Mount

Freezer and without TTD Ice Service

1.4-17 18.1 453 385 340

18-20 22.2 493 419 370

21-22 25.5 526 447 395

Table 4-18. Annual Electricity Consumption: Refrigerator-Freezers with Side-Mount

Freezer and with TTD Ice Service

Lt`

21-23 26.9 677 576 508

24-26 31.0 719 611 539

27-30 35.2 762 647 571

4-26

 EE-PS-2006-001 COMMENT 04.7

#4.7 

where: 

TM UECmax = maximum annual (or unit) electricity consumption in kilowatt-hours 

(kWh) per year for top-mount refrigerator-freezers without TTD ice 

service, and 

Voladj = adjusted total volume in cubic feet. 

The current maximum allowable annual energy consumption for side-mount refrigeratorfreezers with TTD ice service is: 

SM UECmax = 10.1-Vol adj + 406 Eq.4.6 

where: 

SM UECmax = maximum annual (or unit) electricity consumption in kWh per year for 

side-mount refrigerator-freezers with TTD ice service, and 

Voladj = adjusted total volume in cubic feet. 

To arrive at the annual energy consumption values corresponding to the 15 percent less energy 

use and 25 percent less energy use levels, the Department reduced the baseline energy 

consumption by 15 percent and 25 percent, respectively. Table 4-17 and Table 4-18 provide the 

annual energy consumption values for baseline products and products with 15 percent and 25 

percent less energy consumption for top-mount and side-mount refrigerator-freezers, 

respectively. 

11 

f 

Table 4-17. Annual Electricity Consumption: Refrigerator-Freezers with Top-Mount 

Freezer and without TTD Ice Service 

-', efr;ge.;a umeRange 

ubic feet) " 

14-17 18.1 453 385 340 

18-20 22.2 493 419 370 

21-22 25.5 526 447 395 

Table 4-18. Annual Electricity Consumption: Refrigerator-Freezers with Side-Mount 

Freezer and with TTD Ice Service 

;0 ~lfrige~!ltrrA /;./C !!enrs~ntativ~~:;:»::> ~:;~ Annual Electricity Consumption (kllizyr) / R ~ /B ~il· too liI' tal V 1 B , ,,' " SF?! ume ~nge/B ,» \J~ '/shq oum~» 'r~:::~;:liJX ,'~ ~'7'f<c: ISm, less 2Sfl'~less 

1i~ 'b· Ii t~:;)11 ~"/ % lc, 1)* Ii ) , ,,',~% Su' '0' , ",,0' ~. 

/, lI! IC ee ::: ' ]w:: '~l!~' »cu IC eet BY //::g' *::~~ ~»; 'Baseline ';I» ,Y energy en~rgy 

21-23 26.9 677 576 508 

24-26 31.0 719 611 539 

27-30 35.2 762 647 571 

4-26 
#4®7

4.3.1.2 Electricity Prices

When conducting a standards rulemaking, the Department normally uses marginal energy

prices for valuing energy savings. Marginal prices are prices that consumers pay (or save) for

the last units of energy used (or saved). Marginal prices reflect a change in a consumer's bill

(possibly associated with new energy efficiency standards) divided by the corresponding change

in the amount of energy the consumer used . However, because the complexity of a marginal

price analysis is not warranted for this LCC and PBP analysis, the Department used average

electricity prices.

The Department calculated average electricity prices for the residential sector from the

Energy Information Administration (EIA)'s Annual Energy Review (AER) 2003.7 Table 4-19

shows the national average residential electricity prices from 2000 to 2003. Electricity prices are

provided by EIA in nominal dollars and 2000 dollars. The Department used gross domestic

product (GDP) implicit price deflators to convert values into specific years' dollars.' Table 4-19

provides the electricity prices in nominal, 2000, 2003, and 2005 dollars.

Table 4-19. Average Residential Retail Price of Electricity, 2000-2003

2000 8.24 8.24 8.72 8.95

2001 8.62 8.42 8.92 9.15

2002 8.46 8.14 8.60 8.82

2003 8.71 8.24 8.71 8.93

Source : EIA AER 2003; conversions to 2003$ and 2005$ done with GDP implicit price deflators.

Because it conducted the LCC and PBP analysis in 2005$, the Department used

electricity prices in 2005$. The Department applied projected price trends to the electricity price

in 2003 to obtain electricity prices for future years (see Electricity Price Trends, section 3.3.4).

4.3.2 Product Lifetime

The Department estimated the product lifetime from a prior TSD the Department

published in 1995 to assess whether amended energy conservation standards were warranted for

refrigerator-freezers.2 The product lifetime from the prior TSD was estimated to be 19 years.

AHAM in their Fact Book provides an estimate of the average length of first ownership

of refrigerator-freezers.9 As stated by AHAM, the length of first ownership does not refer to the

average useful product lifetime, which tends to be much higher. In 2001, AHAM reports an

average first ownership length of 8.5 years for full size refrigerators. Appliance Magazine

provides a range of first ownership lengths based on the expert judgment of their staff.10 The

magazine lists an average first ownership length of 13 years for standard refrigerators (i.e., noncompact) with minimum and maximum lengths of 10 and 16 years, respectively.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

4.3.1.2 Electricity Prices 

When conducting a standards rulemaking, the Department normally uses marginal energy 

prices for valuing energy savings. Marginal prices are prices that consumers pay (or save) for 

the last units of energy used (or saved). Marginal prices reflect a change in a consumer's bill 

(possibly associated with new energy efficiency standards) divided by the corresponding change 

in the amount of energy the consumer used. However, because the complexity of a marginal 

price analysis is not warranted for this Lee and PBP analysis, the Department used average 

electricity prices. 

The Department calculated average electricity prices for the residential sector from the 

Energy Information Administration (EIA)'s Annual Energy Review (AER) 2003.7 Table 4-19 

shows the national average residential electricity prices from 2000 to 2003. Electricity prices are 

provided by EIA in nominal dollars and 2000 dollars. The Department used gross domestic 

product (GDP) implicit price deflators to convert values into specific years' dollars. 8 Table 4-19 

provides the electricity prices in nominal, 2000, 2003, and 2005 dollars. 

Table 4-19. Average Residential Retail Price of Electricity, 2000-2003 

2000 8.24 8.24 8.72 8.95 

2001 8.62 8.42 8.92 9.15 

2002 8.46 8.14 8.60 8.82 

2003 8.71 8.24 8.71 8.93 

Source: EIA AER 2003; conversions to 2003$ and 2005$ done with GDP implicit price deflators. 

Because it conducted the Lee and PBP analysis in 2005$, the Department used 

electricity prices in 2005$. The Department applied projected price trends to the electricity price 

in 2003 to obtain electricity prices for future years (see Electricity Price Trends, section 3.3.4). 

4.3.2 Product Lifetime 

The Department estimated the product lifetime from a prior TSD the Department 

published in 1995 to assess whether amended energy conservation standards were warranted for 

refrigerator-freezers. 2 The product lifetime from the prior TSD was estimated to be 19 years. 

AHAM in their Fact Book provides an estimate of the average length of first ownership 

of refrigerator-freezers. 9 As stated by AHAM, the length of first ownership does not refer to the 

average useful product lifetime, which tends to be much higher. In 2001, AHAM reports an 

average first ownership length of 8.5 years for full size refi·igerators. Appliance Magazine 

provides a range of first ownership lengths based on the expert judgment of their staff. lO The 

magazine lists an average first ownership length of 13 years for standard refrigerators (i.e., noncompact) with minimum and maximum lengths of 10 and 16 years, respectively. 

4-27 
For purposes of calculating the LCC, the Department must determine the product's full

lifetime operating costs. As a result, the Department uses the product lifetime rather than the

length of first ownership. Although the first owner may not be incurring all of the operating

costs associated with the appliance, some other consumer is, i.e., the subsequent owner of the

appliance.

4.3.3 Discount Rate

The calculation of the LCC uses a discount rate to calculate the present value of future

annual electricity costs. To establish the discount rate, the Department used the same discount

rate it had developed for another residential product-specifically, residential. furnaces and

boilers.11 The Department chose to use only the discount rates that it had developed for the

purchase of furnaces and boilers to replace old or failed equipment because most refrigeratorfreezers are purchased to replace existing units. For equipment purchased to replace old or failed

equipment where cash or some form of credit is used to finance the acquisition, it is appropriate

to establish how the purchase affects a consumer's overall household financial situation. For

example, even though the purchase might be financed through a dealer loan or other short-term

financing vehicle, the purchase is likely to cause the consumer either to incur additional credit

card debt or to forego investment in some type of savings-related asset. Cash that was once

available either to pay for household expenses or to invest in an asset like the stock market or a

savings account now must be earmarked to pay off the equipment purchase, thus causing the

consumer to incur additional credit card debt or to lose the opportunity to earn income from

assets.

The Department estimated the average household equity and debt portfolio from the 1995

and 1998 Federal Reserve Board's Survey of Consumer Finances (SCF).12 The Department

estimated interest or return rates associated with each type of equity and debt from a variety of

sources. Rates for second mortgages and credit cards are from 1998 SCF data. The Department

estimated interest rates associated with household certificates of deposit (CDs), treasury bills (Tbills), and corporate bonds as an average of the Federal Reserve Board time-series data covering

1977-2001.13 Based on relative returns to less-liquid assets, the Department assumed that the

interest rate on transactions (checking) accounts averages two percent real. The midpoint of the

transactions account distribution is two percent. The Department based the two percent figure on

an analysis of returns to money-market accounts and savings accounts, and returns to CD and

bond holdings. It estimated the annual return associated with household stock holdings as an

average of data published by the Stern Business School covering the 1977-2001 period. 14 The

Department estimated mutual fund rates as an average of the Standard and Poor's (S&P) 500

stock rate (67 percent) and the T-bill rate (33 percent).

Table 4-20 summarizes the average shares of household equity and debt based on the

above sources and the real, after-tax interest rates associated with each type of equity or debt.

The Department assumed a marginal tax rate of 28 percent and Consumer Price Index (CPI)

inflation to derive real from nominal values. The weighted-average real., after-tax interest rate

across all types of household debt and equity used to purchase replacement furnaces or boilers is

6.7 percent. The Department used a 6.7 percent discount rate for its calculation of the LCC of

refrigerator-freezers.

4-28

 EE-PS-2006-001 COMMENT 04.7

#4.7 

For purposes of calculating the LCC, the Department must determine the product's full 

lifetime operating costs. As a result, the Department uses the product lifetime rather than the 

length of first ownership. Although the fIrst owner may not be incurring all of the operating 

costs associated with the appliance, some other consumer is, i.e., the subsequent owner of the 

appliance. 

4.3.3 Discount Rate 

The calculation of the LCC uses a discount rate to calculate the present value of future 

annual electricity costs. To establish the discount rate, the Department used the same discount 

rate it had developed for another residential product-specifIcally, residential furnaces and 

boilers. 11 The Department chose to use only the discount rates that it had developed for the 

purchase of furnaces and boilers to replace old or failed equipment because most refrigeratorfreezers are purchased to replace existing units. For equipment purchased to replace old or failed 

equipment where cash or some form of credit is used to finance the acquisition, it is appropriate 

to establish how the purchase affects a consumer's overall household financial situation. For 

example, even though the purchase might be financed through a dealer loan or other short-term 

financing vehicle, the purchase is likely to cause the consumer either to incur additional credit 

card debt or to forego investment in some type of savings-related asset. Cash that was once 

available either to pay for household expenses or to invest in an asset like the stock market or a 

savings account now must be earmarked to payoff the equipment purchase, thus causing the 

consumer to incur additional credit card debt or to lose the opportunity to earn income from 

assets. 

The Department estimated the average household equity and debt pOltfolio from the 1995 

and 1998 Federal Reserve Board's Survey of Consumer Finances (SCF).12 The Department 

estimated interest or return rates associated with each type of equity and debt from a variety of 

sources. Rates for second mortgages and credit cards are from 1998 SCF data. The Depmtment 

estimated interest rates associated with household certifIcates of deposit (CDs), treasury bills (Tbills), and corporate bonds as an average of the Federal Reserve Board time-series data covering 

1977-2001.13 Based on relative returns to less-liquid assets, the Department assumed that the 

interest rate on transactions (checking) accounts averages two percent real. The midpoint of the 

transactions account distribution is two percent. The Depmtment based the two percent figure on 

an analysis of returns to money-market accounts and savings accounts, and returns to CD and 

bond holdings. It estimated the annual return associated with household stock holdings as an 

average of data published by the Stern Business School covering the 1977-2001 period. 14 The 

Department estimated mutual fund rates as an average of the Standard and Poor's (S&P) 500 

stock rate (67 percent) and the T-bill rate (33 percent). 

Table 4-20 summarizes the average shares of household equity and debt based on the 

above sources and the real, after-tax interest rates associated with each type of equity or debt. 

The Department assumed a marginal tax rate of 28 percent and Consumer Price Index (CPI) 

inflation to derive real from nominal values. The weighted-average real, after-tax interest rate 

across all types of household debt and equity used to purchase replacement furnaces or boilers is 

6.7 percent. The Department used a 6.7 percent discount rate for its calculation of the LCC of 

refrigerator-freezers. 

4-28 
#4®7

Table 4-20. After-Tax Real Interest or Return Rates for Household Debt and Equity Types

d

Second Mortgage

Credit Card and installment

Transaction (checking) accounts

CD (6-month)

Savings bonds (Treasury)

Bonds (Corporate AAA)

Stocks (S&P 500)

Mutual fiords

Weighted-average value

Source: DOE 2004 TSD.

3.0%

9.1%

20.0%

7.9%

1.6%

8.3%

30.2%

19.8%

100%

5.9%

12.0%

2.0%

2.8%

3.7%

4.4%

9.6%

7.6%

4.3.4 Electricity Price Trends

The Department used EIA's Annual Energy Outlook 2005 (AEO 2005) Reference Case15

residential electricity price forecast to project prices from 2003 to 2035. The Department used a

linear extrapolation based on the last ten years (2015-2025) in the forecast to project prices to

the end of the analysis period (2035). Figure 4-7 shows the forecasted electricity prices based on

a 2003 price of 8.93 0/kWh.

Figure 4-7. Forecasted Electricity Prices

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 4-20. After-Tax Real Interest or Return Rates for Household Debt and Equity Types 

Second Mortgage 3.0% 5.9% 

Credit Card and installment 9.1% 12.0% 

Transaction (checking) accounts 20.0% 2.0% 

CD (6-month) 7.9% 2.8% 

Savings bonds (Treasury) 1.6% 3.7% 

Bonds (Corporate AAA) 8.3% 4.4% 

Stocks (S&P 500) 30.2% 9.6% 

Mutual funds 19.8% 7.6% 

Weighted-average value 100% 6.7% 

Source: DOE 2004 TSD. 

4.3.4 Electricity Price Trends 

The Department used EIA's Annual Energy Outlook 2005 (AEO 2005) Reference ease

l5 

residential electricity price forecast to project prices from 2003 to 2035. The Department used a 

linear extrapolation based on the last ten years (2015-2025) in the forecast to project prices to 

the end of the analysis period (2035). Figure 4-7 shows the forecasted electricity prices based on 

a 2003 price of 8.93 ¢IkWh. 

(I) 

u 

8.9+---~~--------------------------------------------_4 

8.8+-------T-------------------------------------------_4 

.;: ~ 8.7 -1------ --\-------------------------------------------------,~ 

a.* 

~:g 

·u re 8.6 +--------+------------------------------------:-:~~----_4 

E c: u .- (I)..c: 8.5 

iUS: 

-..II:: .!!! In 8.4 +-----------\------------------+----------------------------1 

--

c: c: 

(I) (I) "u 8.3 ";; --- (I) 

IX: 8.2+----------4--------+-------------------------------~ 

8.1 

8.0+-------r------,-------,------~------,_------r_----_4 

2000 2005 2010 2015 2020 2025 2030 2035 

Year 

Figure 4-7. Forecasted Electricity Prices 

4-29 
4.4 PAYBACK PERIOD METHODOLOGY

A simple measure of the impact of an energy-efficiency standard is the PBP. PBP relates

the increase in total installed costs to the decrease in annual operating costs, where the

differences are between the baseline and the more efficient product. In this PBP analysis, total

installed costs are equivalent to consumer retail prices and operating costs are equivalent to

electricity costs. The Department did not discount costs in determining the PBP.

The PBP is the amount of time (in years) needed to recover, through lower electricity

costs (EC), the additional consumer retail price (RP) for the more efficient product. In this

analysis, the Department used the electricity costs in the first year. Therefore, the equation has

the simple solution:

ARP

PBP =

AEC

where:

PBP = time (in years) needed to recover through lower operating costs,

ARP = difference in consumer retail price between the baseline and the more

energy efficient product, and

DEC = decrease (savings) in annual electricity costs in the year 2010.

Eq. 4.7

4.5 RESULTS OF THE LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS

LCC and PBP results are provided for the two product classes that the Department has

analyzed: (1) top-mounted freezer without TTD ice service, automatic defrost and (2) sidemounted freezer with TTD ice service, automatic defrost. Results are provided for two standard

levels: (1) product with 15 percent less annual energy consumption than the baseline product

(i.e., a product meeting current energy conservation standards) and (2) product with 25 percent

less annual energy consumption that the baseline product.

The difference in LCC between the baseline product and the more energy-efficient

product is the LCC savings. Positive values represent net savings and negative values (in

parentheses) represent net costs. The payback period is determined by dividing the increased

consumer retail price by the first year's electricity cost savings.

For each of the two product classes analyzed by the Department, the LCC and PBP

results include individual. tables for the following:

• Consumer Retail Price and Retail Price Increase

• First-Year and Lifetime Electricity Costs and Electricity Cost Savings

• LCC, LCC Savings, and Payback Period

The tables detailing the consumer retail prices and electricity costs are provided to clearly

show the components of the LCC and PBP. Table 4-21, Table 4-22, and Table 4-23 provide the

4-30

 EE-PS-2006-001 COMMENT 04.7

#4.7 

4.4 PAYBACK PERIOD METHODOLOGY 

A simple measure ofthe impact of an energy-efficiency standard is the PBP. PBP relates 

the increase in total installed costs to the decrease in annual operating costs, where the 

differences are between the baseline and the more efficient product. In this PBP analysis, total 

installed costs are equivalent to consumer retail prices and operating costs are equivalent to 

electricity costs. The Department did not discount costs in determining the PBP. 

The PBP is the amount of time (in years) needed to recover, through lower electricity 

costs (EC), the additional consumer retail price (RP) for the more efficient product. In this 

analysis, the Department used the electricity costs in the first year. Therefore, the equation has 

the simple solution: 

where: 

PBP= 

MP 

I:J.EC 

PBP = time (in years) needed to recover through lower operating costs, 

MP = difference in consumer retail price between the baseline and the more 

energy efficient product, and 

I1EC = decrease (savings) in annual electricity costs in the year 2010. 

Eg.4.7 

4.5 RESULTS OF THE LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS 

LCC and PBP results are provided for the two product classes that the Department has 

analyzed: (1) top-mounted freezer without TID ice service, automatic defrost and (2) sidemounted freezer with TTD ice service, automatic defrost. Results are provided for two standard 

levels: (1) product with 15 percent less annual energy consumption than the baseline product 

(i.e., a product meeting current energy conservation standards) and (2) product with 25 percent 

less annual energy consumption that the baseline product. 

The difference in LCC between the baseline product and the more energy-efficient 

product is the LCC savings. Positive values represent net savings and negative values (in 

parentheses) represent net costs. The payback period is determined by dividing the increased 

consumer retail price by the first year's electricity cost savings. 

For each of the two product classes analyzed by the Department, the LCC and PBP 

results include individual tables for the following: 

• Consumer Retail Price and Retail Price Increase 

• First -Year and Lifetime Electricity Costs and Electricity Cost Savings 

• LCC, LCC Savings, and Payback Period 

The tables detailing the consumer retail prices and electricity costs are provided to clearly 

show the components of the LCC and PBP. Table 4-21, Table 4-22, and Table 4-23 provide the 

4-30 
#®7

results for the top-mount refrigerator-freezer product class. Table 4-24, Table 4-25, and Table

4-26 provide the results for the side-mount refrigerator-freezer product class.

For the 15 percent less energy standard level, a total of twelve results are provided,

consisting of a combination of four retail price estimates (three based on minimum, average, and

maximum manufacturing costs and one based on the regression analysis) and three size

categories. For the 25 percent less energy standard level, a total of nine results are provided for

the top-mount product class, consisting of a combination of three retail price estimates (based on

minimum, average, and maximum manufacturing costs) and three size categories. For the sidemount product class, only six possible results are provided for the 25 percent less energy

standard level, consisting of a combination of three retail price estimates (based on minimum,

average, and maximum manufacturing costs) and two size categories.

For the top-mount product class, LCC savings are realized at the 15 percent less energy

standard level for 11 of the 12 possible results, with the only exception being the maximum

manufacturing-cost-based retail price for the 18-20 cubic foot size category. PBPs of less than

half the lifetime of the product (ranging from 2.7 to 9.5 years) are achieved at the 15;percent less

energy standard level for 9 of the 12 possible results, with the exceptions being the maximum

manufacturing-cost-based retail price for the 18-20 and 21-22 cubic foot size categories as well

as the regression-based retail price for the 21-22 cubic foot size category. At the 25 percent less

energy standard level, LCC savings are realized for only three of the nine possible results: the

minimum manufacturing-cost-based retail price for the 18-20 and 21-22 cubic foot size

categories and the average manufacturing-cost-based retail price for the 18-20 cubic foot size

category. PBPs of less than half the lifetime of the product (ranging from 3.6 to 7.5 years) at the

25 percent less energy standard level are achieved for only two of the nine possible results: the

minimum manufacturing-cost-based retail price for the 18-20 and 21-22 cubic foot size

categories.

For the side-mount product class, LCC savings are realized at the 15 percent less energy

standard level for 8 of the 12 possible results. LCC savings are not realized for the maximum

manufacturing-cost-based retail price at all three size categories as well as the average

manufacturing-cost-based retail price for the 27-30 cubic foot size category. PBPs of less than

half the lifetime of the product (ranging from 1.1 to 9.6 years) are achieved at the 15 percent less

energy standard level for the same eight retail price and size category combinations for which

LCC savings are realized. At the 25 percent less energy level, LCC savings are realized for only

two of the nine possible results: the minimum manufacturing-cost-based retail price for the 21-

23 and 24-26 cubic foot size categories. PBPs of less than half the lifetime (ranging from 0.9 to

4.1 years) of the product are achieved at the 25 percent less energy standard level for the same

two retail price and size category combinations for which LCC savings are realized.

Figure 4-8 and Figure 4-9 graphically represent the LCC results for the top-mount and

side-mount product classes, respectively. To prevent clutter, LCC results are provided based

only on the average manufacturing-cost-based retail price and the regression-analysis-based

retail price.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

results for the top-mount refrigerator-fi'eezer product class. Table 4-24, Table 4-25, and Table 

4-26 provide the results for the side-mount refrigerator-freezer product class. 

For the 15 percent less energy standard level, a total of twelve results are provided, 

consisting of a combination of four retail price estimates (three based on minimum, average, and 

maximum manufacturing costs and one based on the regression analysis) and three size 

categories. For the 25 percent less energy standard level, a total of nine results are provided for 

the top-mount product class, consisting of a combination of three retail price estimates (based on 

minimum, average, and maximum manufacturing costs) and three size categories. For the sidemount product class, only six possible results are provided for the 25 percent less energy 

standard level, consisting of a combination of three retail price estimates (based on minimum, 

average, and maximum manufacturing costs) and two size categories. 

For the top-mount product class, Lee savings are realized at the 15 percent less energy 

standard level for 11 of the 12 possible results, with the only exception being the maximum 

manufacturing-cost-based retail price for the 18-20 cubic foot size category. PBPs of less than 

half the lifetime of the product (ranging from 2.7 to 9.5 years) are achieved at the 15 percent less 

energy standard level for 9 ofthe 12 possible results, with the exceptions being the maximum 

manufacturing-cost-based retail price for the 18-20 and 21-22 cubic foot size categories as well 

as the regression-based retail price for the 21-22 cubic foot size category. At the 25 percent less 

energy standard level, Lee savings are realized for only three of the nine possible results: the 

minimum manufacturing-cost-based retail price for the 18-20 and 21-22 cubic foot size 

categories and the average manufacturing-cost-based retail price for the 18-20 cubic foot size 

category. PBPs ofless than half the lifetime of the product (ranging from 3.6 to 7.5 years) at the 

25 percent less energy standard level are achieved for only two of the nine possible results: the 

minimum manufacturing-cost-based retail price for the 18-20 and 21-22 cubic foot size 

categories. 

For the side-mount product class, Lee savings are realized at the 15 percent less energy 

standard level for 8 of the 12 possible results. Lee savings are not realized for the maximum 

manufacturing-cost-based retail price at all three size categories as well as the average 

manufacturing-cost-based retail price for the 27-30 cubic foot size category. PBPs of less than 

half the lifetime ofthe product (ranging from 1.1 to 9.6 years) are achieved at the 15 percent less 

energy standard level for the same eight retail price and size category combinations for which 

Lee savings are realized. At the 25 percent less energy level, Lee savings are realized for only 

two of the nine possible results: the minimum manufacturing-cost-based retail price for the 21-

23 and 24-26 cubic foot size categories. PBPs of less than half the lifetime (ranging from 0.9 to 

4.1 years) of the product are achieved at the 25 percent less energy standard level for the same 

two retail price and size category combinations for which Lee savings are realized. 

Figure 4-8 and Figure 4-9 graphically represent the Lee results for the top-mount and 

side-mount product classes, respectively. To prevent clutter, Lee results are provided based 

only on the average manufacturing-cost-based retail price and the regression-analysis-based 

retail price. 

4-31 
Table 4-21. Consumer Retail Price and Retail Price Increases: Refrigerator-Freezers with Top-

^' ^

RETAIL PRICE (2005$)

Baseline $329 $386 $457

15% less energy $345 $367 $381 $356 $402 $420 $1186 $434 $477 $499 $531 $520

25% less energy $457 $704 $1047 NA $422 $494 $668 NA $537 $613 $735 NA

RETAIL PRICE INCREASE (2005$)

15% less energy $16 $38 $52 $28 $16 $35 $800 $49 $20 $42 $74 $63

25% less energy $128 $376 $718 NA $36 $108 $282 NA $80 $157 $278 NA

Table 4-22. First-Year and Lifetime Electricity Costs and Electricity Cost Savings: RefrigeratorFIRST-YEAR ELECTRICITY COSTS (2005$) LIFETIME ELECTRICITY COSTS (2005$)

Baseline $37 $40 $42 Baseline $425 $463 $494

15% less energy $31 $34 $36 15% less energy $362 $394 $420

25% less energy $27 $30 $32 25% less energy $319 $347 $370

FIRST-YEAR ELECTRICITY COST SAVINGS (2005$) LIFETIME ELECTRICITY COST SAVINGS (2005$)

15% less energy $5 $6 $6 15% less energy $64 $69 $74

25% less energy $9 $10 $11 25% less energy $106 $116 $123

Table 4-23. LCC, LCC Savings, and Payback Periods: Refrigerator-Freezers with Top-Mount

Freezer and without TTD Ice Service

_T _7 WAI

LCC (2005$)

Baseline $754 $849 $951

15% less energy $706 $729 $742 $718 $795 $814 $1579 $828 $897 $919 $951 $940

25% less energy $776 $1023 $1366 NA $769 $841 $1015 NA $907T$984 $1105 NA

LCC SAVINGS (2005$)

15% less energy $48 $26 $12 $36 $53 $35 iS': ? $21 $54 $32 $0 $11

25% less energy ($22j ($269) ($612) NA $80 $8 NA 11 $43 ($33) (` 155) NA

PAYBACK PERIOD (years)

15% less energy 2.9 6.9 9.5 5.0 2.7 5.8 133.9 8.1 3.1 6.7 11.6 10.0

25% less energy 14.0 41.1 78.5 NA 3.6 10.9 28.3 NA 7.5 14.7 26.2 NA

Mount Freezer and without TTD Ice Service

Freezers with Top-Mount Freezer and without TTD Ice Service

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 4-21. Consumer Retail Price and Retail Price Increases: Refrigerator-Freezers with TopMount Freezer and without TTD Ice Service 

Table 4-22. First-Year and Lifetime Electricity Costs and Electricity Cost Savings: RefrigeratorF reezers WI 'th T M F d op- ount reezer an WI 'th ou t TTD IS' ce erVlce 

FIRST-YEAR ELECTRICITY COSTS (2005$) LIFETIME ELECTRICITY COSTS (2005$) 

Baseline $37 $40 $42 Baseline $425 $463 $494 

15% less energy $31 $34 $36 15% less energy $362 $394 $420 

25 % less energy $27 $30 $32 25% less energy $319 $347 $370 

FIRST-YEAR ELECTRICITY COST SAVINGS (2005$) LIFETIME ELECTRICITY COST SAVINGS (2005$) 

15 % less energy $5 $6 $6 15 % less energy $64 $69 $74 

25 % less energy $9 $10 $11 25% less energy $106 $116 $123 

Table 4-23. LCC, LeC Savings, and Payback Periods: Refrigerator-Freezers with Top-Mount 

Freezer and without TTD Ice Service 

4-32 
#4s7

Table 4-24. Consumer Retail Price and Retail Price Increases: Refrigerator-Freezers with Sidei ^_^6 ^^ l.C kL q6^"i. .

RETAIL PRICE (2005$)

27-30 cu. ft.

1_ ^E4 ^ ^f ,vr f l!^ ^ ISSr:' .4 *^ , 1 .tl ^ ^^ - I^^ • ^- •' 1

Baseline $702 $789 $926

15% less energy $712 $756 $892 $750 $799 $824 $999 $855 $1008 $1110 $1136 $1014

25% less energy $714 $955 $1140 NA $849 $988 $1399 NA Insufficient Data NA

RETAIL PRICE INCREASE (2005$)

15% less energy $10 $54 $190 $47 $10 $35 $210 $66 $82 $184 $210 $88

25% less energy $12 $253 $438 NA $60 $199 $610 NA Insufficient Data NA

Table 4-25. First-Year and Lifetime Electricity Costs and Electricity Cost Savings: RefrigeratorFIRST-YEAR ELECTRICITY COSTS ( 2005$) LIFETIME ELECTRICITY COSTS (2005$)

Baseline $55 $58 $61 Baseline $636 $675 $715

15% less energy $46 $49 $52 15% less energy $540 $574 $608

25% less energy $41 $44 $46 25% less energy $477 $506 $536

FIRST-YEAR ELECTRICITY COST SAVINGS (2005$) LIFETIME ELECTRICITY COST SAVINGS (2005$)

15% less energy $8 $9 $9 15% less energy $95 $101

T

$107

25% less energy $14 $15 $15 25% less energy $159 $169 $179

Table 4-26. LCC, LCC Savings, and Payback Periods : Refrigerator-Freezers with Side-Mount

Freezer and with TTD Ice Service

..^.r3__.:. 4F. ! jf I f. ^11,^J Y ..J-6 Y 1:.15a ' w{ l jJ 1111ME{ • { ' •

LCC (2005$)

Baseline $1338 $1463 $1641

15% less energy $1253 $1296 $1433 $1290 $1372 $1398 $1572 $1428 $1615 $1717 $1743 $1621

25% less energy $1191 $1.432 $1617 NA $1.355 $1494 $1905 NA Insufficient Data NA

LCC SAVINGS (2005$)

15% less energy $85 $42 $48 $91 $66 31.09) $35 $25 (S77) (81.03) $19

25% less energy $147 ;S94> 79) NA 11$1091 (5441? NA 11 Insufficient Data NA

PAYBACK PERIOD ( years)

15% less energy 1.2 6.6 23.2 5.8 1.1 4.1 24.1 7.6 8.9 19.9 22.8 9.6

25% less energy 0.9 18.5 32.1 NA 4.1 13.7 42.1 NA 11 Insufficient Data NA

Freezers with Side-Mount Freezer and with TTD Ice Service

Mount Freezer and with TTD Ice Service

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 4-24. Consumer Retail Price and Retail Price Increases: Refrigerator-Freezers with SideMount Freezer and with TTD Ice Service 

Table 4-25. First-Year and Lifetime Electricity Costs and Electricity Cost Savings: RefrigeratorFreezers witb Side-Mount Freezer and with TTD Ice Service 

I 

FIRST -YEAR ELECTRICITY COSTS (2005$) LIFETIME ELECTRICITY COSTS (2005$) 

Baseline $55 $58 $61 Baseline $636 $675. $715 

15% less energy $46 $49 $52 15 % less energy $540 $574 $608 

25% less energy $41 $44 $46 25 % less energy $477 $506 $536 

FIRST -YEAR ELECTRICITY COST SAVINGS (2005$) LIFETIME ELECTRICITY COST SAVINGS (2005$) 

15% less energy $8 $9 $9 15 % less energy $95 $101 $107 

25% less energy $14 $15 $15 25 % less energy $159 $169 $179 

Table 4-26. LCC, LCC Savings, and Payback Periods: Refrigerator-Freezers with Side-Mount 

Freezer and with TTD Ice Service 

4-33 
$1 , 050

25%

$1 , 000

950

25% less /

$ energy /

900

Baseline

$ 15% less

energy

25%

$850

$800

-r,-•-21-22cu.ft. regr

15% ---*-21-22 cu.ft. mfg

o• • - 18-20 cuft regr

m 18-20 cu ft mf $750 . . g

14-17 cu. . ft mfg

15% o -- 14-17 cu.ft. regr

$700

550 500 450 400 350 300

Annual Energy Use (kWh/yr)

Figure 4-8. Life-Cycle Costs: Top-Mount Refrigerator-Freezers without TTD Ice Service

$1,750

$1,700

$1,650

$1,600

$1,550

$1,500

$1,450

$1,400

$1,350

$1,300

$1,250

.. .,.- .

Baseline

15% less

energy 25% less _...._-_

energy

_^. 15% 25%

---27-30 cu.ft. Mfg Z/O

A• • • 27-30 cu.ft. regr

o,, - 24-26 cut. regr

m-24-26 cut. Mfg 15%

---.-- 21-23 cut. Mfg Br

o---21-23cu.ft. regr

800 750 700 650 600 550 500

Annual Energy Use (kWh/yr)

Figure 4-9. Life-Cycle Costs: Side-Mount Refrigerator-Freezers with TTD Ice Service

4-34

 EE-PS-2006-001 COMMENT 04.7

~ 25% 

/ 

25% less / I----a,...~~~__,_,__,-----_____:;"L-- energy ---i

l 

------1 

I 

",<:;> 15% 

~========;=======-'------'--------'--------4 400 

Annual Energy Use (kWh/yr) 

350 300 

#4.7 

Figure 4-8. Life-Cycle Costs: Top-Mount Refrigerator-Freezers without TTD Ice Service 

$1,750 

$1,700 

$1,650 

~ $1,600 It) 

0 

0 

e $1,550 'Ui 

0 

(.) 

$1,500 II> 

'0 

>-

(.) $1,450 cb 

:: 

..J 

$1,400 

$1,350 

$1,300 

$1,250 

Baseli"~~ -_. "_'_' '_'_"_"_' _'_'"_'_' '_'_--'" ,b. I 1~le~ I' 

.................................. _ .... _ ................. _ ............................ energy ............................ _ ....... 25% le~ __ ............ . 

energy I 

1----------8---------------------------..-----1 

15% I I--______ ~'~.~'.~-~~~~-- ____ ~~-----25%~ 

800 

~27-30 cU.ft. mfg I---------~~------~-~ 

-, '6",27-30 cU.ft. regr 

- --0- -,24-26 cu.ft. regr I--___________ ~---~ 

__ 24-26 cu.ft. mfg 

............... 21-23 cu.ft. mfg 

,. ·<:;>·,·21-23 cu.ft. regr 

750 700 650 600 

Annual Energy Use (kWh/yr) 

15% 

550 500 

Figure 4-9. Life-Cycle Costs: Side-Mount Refrigerator-Freezers with TTD Ice Service 

4-34 
#4®7

REFERENCES

The NPD Group, Inc., The NPD Group/NPD Houseworld - POS, Refrigerators, January -

December 2004, 2005. Port Washington, NY.

Association of Home Appliance Manufacturers, Summary Data Tables: Refrigerator -Freezer

Data Collection for Cost/Efficiency Information for DOE Petition, 2005 . Information

provided by the Association of Home Appliance Manufacturers to the U.S. Department of

Energy, May 1.3, 2005.

3

4

5

6

7

8

9

1 0

I'

U.S. Department of Energy, Technical Support Document: Energy Efficiency Standards for

Consumer Products: Refrigerators, Refrigerator-Freezers, & Freezers, July 1995.

Washington, DC. Report No. 'DOE/EE-0064.

Code of Federal Regulations, Appendix Al to Subpart B of Part 430-Uniform Test Method

for Measuring the Energy Consumption of Electric Refrigerators and Electric RefrigeratorFreezers. 10 CFR Pt. 430, Subpt. B, App. Al.

California Energy Commission, Appliance Database, Refrigerator-Freezers, 2005.

Sacramento, CA. File: comm refrig_frzrs.zip; Last modified, January 6, 2005.

<http://www. energy. ca. gov/appliances/appliance/excel_based_files/refrigerators/>

U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Energy

Conservation Program for Consumer Products: Energy Conservation Standards for

Refrigerators, Refrigerator-Freezers and Freezers; Final Rule. Federal Register, 1997.

62(81): pp. 231.02-23116.

U.S. Department of Energy-Energy Information Administration, Annual Energy Review

2003, September 2004. Washington DC. Report No. DOE/EIA-0384(2003). Table 8-10,

Average Retail Prices of Electricity, 1960-2003.

U.S. Government Printing Office, Budget of the United States Government: Historical Tables

Fiscal Year 2005, Section 10 - Gross Domestic Product and Implicit Outlay Deflators, Table

10.1 - Goss Domestic Product and Deflators Used in the Historical Tables: 1940-2009,

2005. Washington, DC. GPO Access: <http://www.gpoaccess.gov/usbudget/fy05/hist.html>

Association of Home Appliance Manufacturers, 2003 Fact Book, 2003. Washington, DC.

Table 11.

"The Life Expectancy/Replacement Picture," Appliance Magazine, September 2004. p. P-5.

U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Technical

Support Document: Energy Efficiency Program for Consumer Products: Energy

Conservation Standards for Residential Furnaces and Boilers, September 2004. Washington,

DC.

4-35

 EE-PS-2006-001 COMMENT 04.7

#4.7 

REFERENCES 

2 

3 

4 

5 

6 

7 

8 

9 

The NPD Group, Inc., The NPD GrouplNPD Houseworld - pas, Refrigerators,JanuaryDecember 2004, 2005. Port Washington, NY. 

Association of Home Appliance Manufacturers, Summary Data Tables: Refrigerator-Freezer 

Data Collection for Cost/Efficiency Infonnationfor DOE Petition, 2005. Information 

provided by the Association of Home Appliance Manufacturers to the U.S. Department of 

Energy, May 13, 2005. 

U.S. Department of Energy, Technical Support Document: Energy Efficiency Standardsfor 

Consumer Products: Rt;frigerators, Refrigerator-Freezers, & Freezers, July 1995. 

Washington, DC. Report No. DOEIEE-0064. 

Code of Federal Regulations, Appendix Al to Subpart B of Part 430-Uniform Test Method 

for Measuring the Energy Consumption of Electric Refrigerators and Electric RefrigeratorFreezers. 10 CFR Pt. 430, Subpt. B, App. AI. 

California Energy Commission, Appliance Database, Refrigerator-Freezers, 2005. 

Sacramento, CA. File: comm_refrig_frzrs.zip; Last modified, January 6,2005. 

<http://www.energy.ca.gov/appliances/appliance/exceLbased_files/refrigerators/> 

U.S. Depattment of Energy-Office of Energy Efficiency and Renewable Energy, Energy 

Conservation Program for Consumer Products: Energy Conservation Standards for 

Refrigerators, Refrigerator-Freezers and Freezers; Final Rule. Federal Register, 1997. 

62(81): pp. 23102-23116. 

U.S. Depattment of Energy-Energy Information Administration, Annual Energy Review 

2003, September 2004. Washington DC. Report No. DOEIEIA-0384(2003). Table 8-10, 

Average Retail Prices of Electricity, 1960-2003. 

U.S. Government Printing Office, Budget of the United States Government: Historical Tables 

Fiscal Yeat· 2005, Section 10 - Gross Domestic Product and Implicit Outlay Deflators, Table 

10.1 - Goss Domestic Product and Deflators Used in the Historical Tables: 1940-2009, 

2005. Washington, DC. GPO Access: <http://www.gpoaccess.gov/usbudget/fy05/hist.html> 

Association of Home Appliance Manufacturers, 2003 Fact Book, 2003. Washington, DC. 

Table 11. 

10 "The Life Expectancy/Replacement Picture," Appliance Magazine, September 2004. p. P-5. 

11 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Technical 

Support Document: Energy Efficiency Program for Consumer Products: Energy 

Conservation Standards for Residential Furnaces and Boilers, September 2004. Washington, 

DC. 

4-35 
12

13

14

15

The Federal Reserve Board, 1998 Survey of Consumer Finances, 1998.

<http://www.federalreserve. gov/pubs/oss/oss2/98/scf98home.html#summary>

The Federal Research Board, Federal Reserve Statistical Interest Rates, H. 15 Historical Data,

2000.

Damodaran Online Data Page, Historical Returns on Stocks, Bonds and Bills- United States.

(Last accessed October 9, 2002), <http://pages.stern.nyu.edu/-adamodar/>

U.S. Department of Energy-Energy Information Administration, Annual Energy Outlook

2005, February, 2005. Washington, DC. Report No. DOE/EIA-0383(2005).

 EE-PS-2006-001 COMMENT 04.7

#4.7 

12 The Federal Reserve Board, 1998 Survey of Consumer Finances, 1998. 

<http://www.federalreserve.gov/pubs/oss/oss2/98/scf98home.html#summary> 

13 The Federal Research Board, Federal Reserve Statistical Interest Rates, H.15 Historical Data, 

2000. 

14 Damodaran Online Data Page, Historical Returns on Stocks, Bonds and Bills-United States. 

(Last accessed October 9, 2002), <http://pages.stern.nyu.edu/~adamodar/> 

15 U.S. Department of Energy-Energy Information Administration, Annual Energy Outlook 

2005, February, 2005. Washington, DC. Report No. DOE/EIA-0383(2005). 

4-36 
#4®7

CHAPTER 5. NATIONAL IMPACT ANALYSIS

This chapter describes the national impact analysis, consisting of the determination of

national energy savings (NES) and national net present value (NPV) from an energy

conservation (or efficiency) standard that would require refrigerator-freezers to use 15 percent

less energy than current baseline models. For purposes of this analysis, the Department assumed

the effective date of such a standard would be the year 2010. The Department assumed the

energy consumption of baseline products to equal the maximum energy consumption allowed by

current energy conservation standards. Refrigerator-freezers with 15 percent less energy

consumption correspond to products meeting current Energy Star requirements. For the

purposes of this analysis, the Department analyzed the NES and NPV of amended energy

conservation standards for the following two product classes of refrigerators, refrigerator.

freezers, and freezers: (1) top-mounted freezer without through-the-door (TD) ice service,

automatic defi-ost, and (2) side-mounted freezer with TTD ice service, automatic defrost.

5.1 NATIONAL ENERGY SAVINGS CALCULATION

Figure 5-1 illustrates the inputs, intermediate values, and outputs of the NES calculation.

The NES is the difference between the national energy consumption in the base case (i.e., the

case without amended energy conservation standards) and the standards case (i.e., the case with

amended energy conservation standards). The Department developed a spreadsheet model to

calculate the NES from refrigerator-freezer standards for the two product classes of interest to

this analysis. The spreadsheet model calculated the stock of refrigerator-freezers for these two

product classes in any given year by adding up the shipments of refrigerator-freezers in that year

plus the preceding 18 years (based on a refrigerator-freezer lifetime of 19 years). The average

unit (or annual) electricity consumption (UEC) of the refrigerator-freezer stock was calculated

from the average UEC of shipments in each of the relevant years. This calculation was

performed separately for the base case and the standards case. The total number of refrigeratorfreezers in the stock was then multiplied by the average UEC to calculate annual site electricity

consumption. The site-to-source conversion factor for that year was then used to calculate

source energy consumption in primary quadrillion (1015) British thermal units (quads). This was

calculated for the base case and the standards case and the difference was taken to determine

annual energy savings from a standard. The energy savings were summed for all of the years of

the analysis period (2010-2035) to determine the cumulative national energy savings.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

CHAPTERS. NATIONAL IMPACT ANALYSIS 

This chapter describes the national impact analysis, consisting of the determination of 

national energy savings (NES) and national net present value (NPV) from an energy 

conservation (or efficiency) standard that would require refrigerator-freezers to use15 percent 

less energy than current baseline models. For purposes of this analysis, the Department assumed 

the effective date of such a standard would be the year 2010. The Department assumed the 

energy consumption of baseline products to equal the maximum energy consumption allowed by 

CUlTent energy conservation standards. Refrigerator-freezers with 15 percent less energy 

consumption correspond to products meeting current Energy Star requirements. For the 

purposes of this analysis, the Department analyzed the NES and NPV of amended energy 

conservation standards for the following two product classes of refrigerators, refrigeratorfreezers, and freezers: (1) top-mounted freezer without tlu'ough-the-door (TID) ice service, 

automatic defrost, and (2) side-mounted freezer with TTD ice service, automatic defrost. 

5.1 NATIONAL ENERGY SAVINGS CALCULATION 

Figure 5-1 illustrates the inputs, intermediate values, and outputs of the NES calculation. 

The NES is the difference between the national energy consumption in the base case (i.e., the 

case without amended energy conservation standards) and the standards case (i.e., the case with 

amended energy conservation standards). The Department developed a spreadsheet model to 

calculate the NES from refrigerator-freezer standards for the two product classes of interest to 

this analysis. The spreadsheet model calculated the stock of refrigerator-freezers for these two 

product classes in any given year by adding up the shipments of refrigerator-freezers in that year 

plus the preceding 18 years (based on a refrigerator-freezer lifetime of 19 years). The average 

unit (or annual) electricity consumption (VEC) of the refrigerator-freezer stock was calculated 

from the average VEC of shipments in each of the relevant years. This calculation was 

performed separately for the base case and the standards case. The total number of refrigeratorfreezers in the stock was then multiplied by the average VEC to calculate annual site electricity 

consumption. The site-to-source conversion factor for that year was then used to calculate 

source energy consumption in primary quadrillion (1015

) British thermal units (quads). This was 

calculated for the base case and the standards case and the difference was taken to determine 

annual energy savings from a standard. The energy savings were summed for all of the years of 

the analysis period (2010-2035) to determine the cumulative national energy savings. 

5-1 
Historical

Shipments

Product Class

Market Shares

Product Lifetime

Baseline Unit

Electricity

Consumption

Base Case UEC

Market Shares

15% less energy

Unit Electricity

Consumption

Standards Case

UEC Market Shares

25% less energy

Unit Electricity

Consumption

Site-to-Source

Energy Conversion

Analysis Period

Annual

Electricity

Savings

National Energy

Savings

Projected

Shipments

LShipments dby

ass

Bas e Case Unit

Electricity -I

Consumption

V

Unit Electricity

Savings

(Base-Standards)

Standards Case

Unit Electricity

Consumption

Figure 5-1 . Flow Diagram of National Energy Savings Calculation

 EE-PS-2006-001 COMMENT 04.7

I 

Historical 

Shipments 

Product Class 

Market Shares 

-_ .... __ .. _--------_ ... -. 

Product Lifetime 

Baseline Unit 

Electricity 

Consumption 

Base Case UEC 

Market Shares 

15% less energy 

Unit Electricity 

Consumption 

Standards Case 

UEC Market Shares 

25% less energy 

Unit Electricity 

Consumption 

Site-to-Source 

: 

Energy Conversion 

Analysis Period 

Projected 

Shipments 

-------------7 Projected 

Shipments by Z Product Class 

--1 Base Case Unit I Electricity 

Consumption 

Standards Case 

Z f Unit Electricity 

Consumption 

t 

#4.7 

If Unit Electricity / Savings 

(Base-Standards) 

L( / Al1IlUal 

Electricity 

Savings 

_._--

National Energy 

Savings 

Figure 5-1. Flow Diagram of National Energy Savings Calculation 

5-2 
#4®7

5.2 NET PRESENT VALUE CALCULATION

Figure 5-2 illustrates the inputs, intermediate values, and outputs of the NPV calculation.

The NPV is the difference between the sum of national total installed costs and operating costs in

the base case and the sum of national total installed costs and operating costs in the standards

case. For the purposes of this analysis, the total installed cost consists only of the consumer

retail price of the refrigerator-freezer and the operating cost consists only of the electricity cost.

A positive NPV occurs when the present value of electricity cost savings exceeds the present

value of increased refrigerator-freezer retail prices associated with the standard. The=Department

determined the NPV of standards with the same spreadsheet model used to calculate the NES.

The electricity savings in each year were multiplied by that year's electricity price to determine

annual electricity cost savings. For each year, the spreadsheet also calculated the weightedaverage consumer retail price of refrigerator-freezers in the base case and standards case, and

took the difference to determine the incremental retail price per unit. To determine the annual

incremental cost of efficiency, this incremental retail price was multiplied by the number of units

shipped in that year. This incremental cost was subtracted from the annual electricity cost

savings to determine annual net savings or costs. A discount factor was applied to each year's

annual savings or costs to determine the net present value of the savings or costs. These savings

or costs were then summed across all of the years of the analysis to give the total NPV of

standards.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

5.2 NET PRESENT VALUE CALCULATION 

Figure 5-2 illustrates the inputs, intermediate values, and outputs of the NPV calculation. 

The NPV is the difference between the sum of national total installed costs and operating costs in 

the base case and the sum of national total installed costs and operating costs in the standards 

case. For the purposes of this analysis, the total installed cost consists only of the consumer 

retail price of the refrigerator-freezer and the operating cost consists only of the electricity cost. 

A positive NPV occurs when the present value of electricity cost savings exceeds the present 

value of increased refrigerator-freezer retail prices associated with the standard. The Department 

determined the NPV of standards with the same spreadsheet model used to calculate the NBS. 

The electricity savings in each year were multiplied by that year's electricity price to determine 

annual electricity cost savings. For each year, the spreadsheet also calculated the weightedaverage consumer retail price of refrigerator-freezers in the base case and standards case, and 

took the difference to determine the incremental retail price per unit. To determine the annual 

incremental cost of efficiency, this incremental retail price was multiplied by the number of units 

shipped in that year. This incremental cost was subtracted from the annual electricity cost 

savings to determine annual net savings or costs. A discount factor was applied to each year's 

annual savings or costs to determine the net present value of the savings or costs. These savings 

or costs were then summed across all of the years of the analysis to give the total NPV of 

standards. 

5-3 
Historical

Shipments

Product Class

Market Shares

Projected

Shipments by

Product Class

Product Lifetime

Baseline Consumer

Retail Price

15% less energy

Consumer Retail

Price

25% less energy

Consumer Retail

Price

Annual Electricit

Savings (From

NES Flow

Diagram)

Base Case

Consumer

Retail Price

Base Case UEC

Market Shares

Standards Case

Consumer

Retail Price

Standards Case

UEC Market Shares

y

Electricity Prices

Analysis Period

Discount Rate

NPV Inputs

Calculated Values j

NPV Output

Incremental

Retail Price

(Base-Standards)

Annual

Incremental

Retail Price

Annual

Electricity Cost

Savings

C

Net Present

Value

Figure 5-2. Flow Diagram of Net Present Value Calculation

 EE-PS-2006-001 COMMENT 04.7

#4.7 

-1----- NRVlnpl!ts 

Historical ___ Projected ~. Calculate4Values Shipments Shipments 

• C) .. N~y()U;Pllt . . ..... .. 

Product Class Projected 

Shipments by ! 

Market Shares 1 Product Class 

Product Lifetime 

Baseline Consumer 

Retail Price 

Base Case VEC Base Case 

Market Shares f 7 Consumer 

Retail Price 

15 % I ess energy 

~ Incremental / Consumer Retail Retail Price 

Price (Base-Standards) 

Standards Case SW,dM'" C~, f 

VEC Market Shares 7 Consumer 

Retail Price 

-I / t AIIDual 

25% less energy Incremental 

Consumer Retail Retail Price 

Price 

/ Annual Electricity I- Savings (From 

NES}I'low 

Diagram) Annual / Electricity Cost / Savings 

Electricity Prices 

Analysis Period 

I 

Discount Rate 

I 

Net Present 

Value 

Figure 5-2. Flow Diagram of Net Present Value Calculation 

5-4 
#4

5.3 INPUTS TO THE NES AND NPV CALCULATIONS

The following sections discuss and document the inputs to the calculation of the NES and

NPV.

5.3.1 Shipments

5.3.1.1 Historical Shipments

The Department obtained historical refrigerator-freezer shipment data from the

Association of Home Appliance Manufacturers (ARAM).' Table 5-1 shows historical

refrigerator-freezer shipments from 1982 through 2004.

Table 5-1. Historical Refrigerator -Freezer Shipments

1982

1984

1983

1985

1986

1.987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

4.36

5.34

5.88

6.00

6.41

6.75

6.73

6.45

6.46

6.41

6.72

7.05

7.59

7.65

7.98

7.92

8.77

9.10

9.22

9.31

9.74

10.02

10.92

Source: AHAM.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

5.3 INPUTS TO THE NES AND NPV CALCULATIONS 

The following sections discuss and document the inputs to the calculation of the NBS and 

NPV. 

5.3.1 Shipments 

5.3.1.1 Historical Shipments 

The Department obtained historical refrigerator-freezer shipment data from the 

Association of Home Appliance Manufacturers (AHAM).J Table 5-1 shows historical 

refrigerator-freezer shipments from 1982 through 2004. 

Table 5-1. Historical Refrigerator-Freezer Shipments 

1982 4.36 

1983 5.34 

1984 5.88 

1985 6.00 

1986 6.41 

1987 6.75 

1988 6.73 

1989 6.45 

1990 6.46 

1991 6.41 

1992 6.72 

1993 7.05 

1994 7.59 

1995 7.65 

1996 7.98 

1997 7.92 

1998 8.77 

1999 9.10 

2000 9.22 

2001 9.31 

2002 9.74 

2003 10.02 

2004 10.92 

Source: AHAM. 

5-5 
5.3.1.2 Projected Shipments

The Department estimated future shipments from a linear extrapolation of the historical

shipments growth trend in the years 1995 through 2004. Figure 5-3 shows the linear

extrapolation and Table 5-2 shows projected refrigerator-freezer shipments for 2005 through

2035.

24

Shipments = 0.3306 * Year - 652.01

20 R2 = 0.9519

16

12

8

0

1995 2000 2005 2010 2015 2020 2025 2030 2035

Year

Figure 5-3. Projection of Refrigerator-Freezer Shipments to 2035

 EE-PS-2006-001 COMMENT 04.7

#4.7 

5.3.1.2 Projected Shipments 

The Department estimated future shipments from a linear extrapolation of the historical 

shipments growth trend in the years 1995 through 2004. Figure 5-3 shows the linear 

extrapolation and Table 5-2 shows projected refrigerator-freezer shipments for 2005 through 

2035. 

-til 

c: 

~ 'e 

-til 

-

c: 

CI) 

E 

Co 

:2 

(/) 

20 +--------------------4 

16 

12 

8 

Shipments = 0.3306 * Year - 652.01 

R2 = 0.9519 

o +------.------r_----~-----,------~----~------r_----~ 

1995 2000 2005 2010 2015 2020 2025 2030 2035 

Year 

Figure 5-3. Projection of Refrigerator-Freezer Shipments to 2035 

5-6 
#4®7

Table 5-2. Projected Refrigerator-Freezer Shipments

L

2005 10.84

2006 11.17

2007 11.50

2008 11.83

2009 12.17

2010. 12.50

2011 12.83

2012 13.16

2013 13.49

2014 13.82

2015 14.15

2016 14.48

2017 14.81

2018 15.1.4

2019 15.47

2020 15.80

2021 16.13

2022 16.46

2023 16.79

2024 17.12

2025 17.46

2026 17.79

2027 18.12

2028 18.45

2029 18.78

2030 19.11

2031 19.44

2032 19.77

2033 20.10

2034 20.43

2035 20.76

5.3.1.3 Product Class Market Shares and Project Shipments by Product Class

The Department used AHAM data on the market share of different refrigerator-freezer

types to estimate the fraction of all refrigerator-freezer shipments that fall into the two product

classes considered for this analysis (i.e., top-mount refrigerator-freezers without TTD ice service

and side-mount refrigerator-freezers with TTD ice service), as well as the capacity size ranges

included in this analysis.' Table 5-3 shows the AHAM market share data for top- or bottommounted refrigerator-freezers as well as for side-mount refrigerator-freezers.

 EE-PS-2006-001 COMMENT 04.7

5.3.1.3 

Table 5-2. Projected Refrigerator-Freezer Shipments 

2005 

2006 

2007 

2008 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2031 

2032 

2033 

2034 

2035 

11.17 

11.50 

11.83 

12.17 

12.50 

12.83 

13.16 

13.49 

13.82 

14.15 

14.48 

14.81 

15.14 

15.47 

15.80 

16.13 

16.46 

16.79 

17.12 

17.46 

17.79 

18.12 

18.45 

18.78 

19.11 

19.44 

19.77 

20.10 

20.43 

20.76 

#4.7 

Product Class Market Shares and Project Shipments by Product Class 

The Department used AHAM data on the market share of different refrigerator-freezer 

types to estimate the fraction of all refrigerator-freezer shipments that fall into the two product 

classes considered for this analysis (i.e., top-mount refrigerator-freezers without TTD ice service 

and side-mount refrigerator-freezers with TTD ice service), as well as the capacity size ranges 

included in this analysis. 1 Table 5-3 shows the AHAM market share data for top- or bottommounted refrigerator-freezers as well as for side-mount refrigerator-freezers. 

5-7 
Table 5-3. Market Share of Refrigerator-Freezer Product Classes

1998

1999

2000

2001

2002

2003

2004

Source: AHAM.

69.27

68.82

68.33

67.53

66.59

63.70

63.41

,per"'^'ent'

29.92

30.77

31.31

32.08

32.78

34.51

35.09

The Department estimated future market shares for these two categories of refrigeratorfreezers by performing a linear extrapolation of the market shares from 1998 to 2004. The third

and fourth columns of Table 5-4 show the results of this extrapolation.

Based on data from The NPD Group, the Department estimated that top-mount

refrigerator-freezers without TTD ice service in the size category range of 14 to 21 cubic feetd

comprise 81.2 percent of total top- and bottom-mount refrigerators.2 It also estimated that sidemount refrigerator-freezers with TTD ice service in the size category range of 21 to 30 cubic feet

comprise 98.4 percent of total side-mount refrigerator-freezer shipments.2 The Department

applied these multipliers to the refr igerator-freezer shipments to calculate shipments of only

those product classes covered by this analysis. The last two columns of Table 5-4 show the

refrigerator-freezer shipments used in the analysis.

d Size category is based on cubic feet of total refrigerated volume (fresh food volume plus freezer volume).

5-8

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 5-3. Market Share of Refrigerator-Freezer Product Classes 

1998 

1999 

2000 

2001 

2002 

2003 

2004 

Source: AHAM. 

69.27 

68.82 

68.33 

67.53 

66.59 

63.70 

63.41 

~RI:!I!!I!IIIlIJIP!III! 

The Department estimated future market shares for these two categories of refrigeratorfreezers by performing a linear extrapolation of the market shares from 1998 to 2004. The third 

and fourth columns of Table 5-4 show the results of this extrapolation. 

Based on data from The NPD Group, the Department estimated that top-mount 

refrigerator-freezers without TID ice service in the size category range of 14 to 21 cubic feetd 

comprise 81.2 percent of total top- and bottom-mount refrigerators.2 It also estimated that sidemount refrigerator-freezers with TTD ice service in the size category range of 21 to 30 cubic feet 

comprise 98.4 percent oftotal side-mount refrigerator-freezer shipments. 2 The Department 

applied these multipliers to the refrigerator-freezer shipments to calculate shipments of only 

those product classes covered by this analysis. The last two columns of Table 5-4 show the 

refrigerator-freezer shipments used in the analysis. 

d Size category is based on cubic feet of total refrigerated volume (fresh food volume plus freezer volume). 

5-8 
#4.7

Table 5-4. Refrigerator-Freezer Shipments Used in the Analysis

Shipments of

included Side-

.:Mount Freezer,

(rriilliori

1995 7.65 73.18% 26.82% 4.55 2.02

1996 7.98 72.12% 27.88% 4.67 2.19

1997 7.92 71.07% 28.88% 4.57 2.25

1998 8.77 69.27% 29.92% 4.93 2.58

1999 9.10 68.82% 30.77% 5.09 2.76

2000 9.22 68.33% 31.31% 5.12 2.84

2001 9.31 67.53% 32.08% 5.10 2.94

2002 9.74 66.59% 32.78% 5.27 3.14

2003 10.02 63.70% 34.51% 5.18 3.40

2004 10.92 63.41% 35.09% 5.62 3.77

2005 10.84 62.62% 35.87% 5.52 3.83

2006 11.17 61.57% 36.74% 5.59 4.04

2007 11.50 60.51% 37.62% 5.65 4.26

2008 11.83 59.45% 38.49% 5.72 4.48

2009 12.17 58.40% 39.36% 5.77 4.71

2010 12.50 57.34% 40.24% 5.82 4.95

2011 12.83 56.29% 41.11% 5.86 5.19

2012 13.16 55.23% 41.98% 5.90 5.44

2013 13.49 54.1.8% 42.86% 5.94 5.69

2014 13.82 53.12% 43.73% 5.96 5.95

2015 14.15 52.06% 44.60% 5.98 6.21

2016 14.48 51.01% 45.48% 6.00 6.48

2017 14.81 49.95% 46.35% 6.01 6.76

2018 15.14 48.90% 47.22% 6.01 7.04

2019 15.47 47.84% 48.10% 6.01 7.32

2020 15.80 46.79% 48.97% 6.01 7.62

2021. 16.13 45.73% 49.85% 5.99 7.91

2022 16.46 44.67% 50.72% 5.97 8.22

2023 16.79 43.62% 51.59% 5.95 8.53

2024 17.12 42.56% 52.47% 5.92 8.84

2025 17.46 41.51% 53.34% 5.89 9.16

2026 17.79 40.45% 54.21% 5.84 9.49

2027 18.12 39.40% 55.09% 5.80 9.82

2028 18.45 38.34% 55.96% 5.74 10.16

2029 18.78 37.28% 56.83% 5.69 10.50

2030 19.11 36.23% 57.71% 5.62 10.85

2031 19.44 35.17% 58.58% 5.55 1.1.21

2032 19.77 34.12% 59.46% 5.48 11.57

2033 20.10 33.06% 60.33% 5.40 11.93

2034 20.43 32.01% 61.20% 5.31 12.31

2035 20.76 30.95% 62.08% 5.22 12.68

Sources: Columns 1-3: AHAM; Columns 4-5: The NPD Group/NPD Houseworld - POS.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 5-4. Refrigerator-Freezer Sbipments Used in the Analysis 

~"""'PBIf'! 

1995 7.65 73.18% 4.55 2.02 

1996 7.98 72.12% 4.67 2.19 

1997 7.92 71.07% 28.88% 4.57 2.25 

1998 8.77 69.27% 29.92% 4.93 2.58 

1999 9.10 68.82% 30.77% 5.09 2.76 

2000 9.22 68.33% 31.31 % 5.12 2.84 

2001 9.31 67.53% 32.08% 5.10 2.94 

2002 9.74 66.59% 32.78% 5.27 3.14 

2003 10.02 63.70% 34.51% 5.18 3.40 

2004 10.92 63.41% 35.09% 5.62 3.77 

2005 10.84 62.62% 35.87% 5.52 3.83 

2006 11.17 61.57% 36.74% 5.59 4.04 

2007 11.50 60.51% 37.62% 5.65 4.26 

2008 11.83 59.45% 38.49% 5.72 4.48 

2009 12.17 58.40% 39.36% 5.77 4.71 

2010 12.50 57.34% 40.24% 5.82 4.95 

2011 12.83 56.29% 41.11 % 5.86 5.19 

2012 13.16 55.23% 41.98% 5.90 5.44 

2013 13.49 54.18% 42.86% 5.94 5.69 

2014 13.82 53.12% 43.73% 5.96 5.95 

2015 14.15 52.06% 44.60% 5.98 6.21 

2016 14.48 51.01 % 45.48% 6.00 6.48 

2017 14.81 49.95% 46.35% 6.01 6.76 

2018 15.14 48.90% 47.22% 6.01 7.04 

2019 15.47 47.84% 48.10% 6.01 7.32 

2020 15.80 46.79% 48.97% 6.01 7.62 

2021 16.13 45.73% 49.85% 5.99 7.91 

2022 16.46 44.67% 50.72% 5.97 8.22 

2023 16.79 43.62% 51.59% 5.95 8.53 

2024 17.12 42.56% 52.47% 5.92 8.84 

2025 17.46 41.51 % 53.34% 5.89 9.16 

2026 17.79 40.45% 54.21% 5.84 9.49 

2027 18.12 39.40% 55.09% 5.80 9.82 

2028 18.45 38.34% 55.96% 5.74 10.16 

2029 18.78 37.28% 56.83% 5.69 10.50 

2030 19.11 36.23% 57.71% 5.62 10.85 

2031 19.44 35.17% 58.58% 5.55 11.21 

2032 19.77 34.12% 59.46% 5.48 11.57 

2033 20.10 33.06% 60.33% 5.40 11.93 

2034 20.43 32.01 % 61.20% 5.31 12.31 

2035 20.76 30.95% 62.08% 5.22 12.68 

Sources: Columns 1-3: AHAM; Columns 4-5: The NPD Group/NPD Houseworld - pos. 

5-9 
5.3.2 Unit Electricity Consumption and Consumer Retail Prices

5.3.2.1 Weighted-Average Unit Electricity Consumption and Per-Unit Consumer

Retail Price for Baseline, 15 percent less energy, and 25 percent less energy

Products

For each of the two product classes, top-mount refrigerator-freezers and side-mount

refrigerator-freezers, the Department calculated a representative weighted-average UEC and a

representative weighted-average per-unit consumer retail price for a baseline refrigerator-freezer,

for a refrigerator-freezer that consumes 15 percent less energy, and for a refrigerator-freezer that

consumes 25 percent less energy. The UEC and retail price data are shown in Table 5-5 and

Table 5-6 for top-mount and side-mount units, respectively. The Department used data from The

NPD Group to estimate the percent of shipments allocated to each size category to arrive at

weighted-average UEC and retail price values.' The UECs are from the life-cycle cost (LCC)

and payback period (PBP) analysis. The retail prices are also from the LCC and PBP analysis

and are based on the average manufacturing-cost-based retail prices as well as the regression

analysis-based retail prices.

Table 5-5. Weighted-Average UECs and Retail Prices: Refrigerator-Freezers with TopMount Freezer and without TTD Ice Service

-7

7

14-17 21.9% 453 385 340 $329 $367 $704 $356

18-20 43.9% 493 419 370 $386 $420 $494 $434

21-22 26.3% 526 447 395 $457 $499 $613 $520

Weighted-Avg. Value 493 419 370 $392 $430 $578 $440

Sources: Percent of Shipments: The NPD Group /NPD Houseworld - POS ; UEC: Table 4-17, LCC and PBP Analysis;

Retail Price : Table 4-2 1, LCC and PBP Analysis.

Table 5-6. Weighted-Average UECs and Retail Prices: Refrigerator-Freezers with SideMount Freezer and with TTD Ice Service

-7 7

[ ^ F.k }O ^.w

1II

y ...

11 1 F, E.1 -

,gg',

JOS F

4i^L_

21-23 25.1% 677 575

.

508 $702 $756 $955 $750

24-26 74.2% 719 611 539 $789 $824 $988 $855

27-30 0.3% 762 648 572 $926 $1,110 $1,209' $101.4

Weighted-Avg. Value 709 602 531 $767 $808 $980 $829

* Due to insufficient data, the value here is an approximation based on the price differential for the 25% less energy

model for the two smaller size categories.

Sources: Percent of Shipments: The NPD Group/NPD Houseworld - POS ; UEC: Table 4-18, LCC and PBP Analysis;

Retail Price: Table 4-24, LCC and PBP Analysis.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

5.3.2 Unit Electricity Consumption and Consumer Retail Prices 

5.3.2.1 Weighted-Average Unit Electricity Consumption and Per-Unit Consumer 

Retail Price for Baseline, 15 percent less energy, and 25 percent less energy 

Products 

For each of the two product classes, top-mount refrigerator-freezers and side-mount 

refrigerator-freezers, the Department calculated a representative weighted-average UEC and a 

representative weighted-average per-unit consumer retail price for a baseline refrigerator-freezer, 

for a refrigerator-fi'eezer that consumes 15 percent less energy, and for a refrigerator-freezer that 

consumes 25 percent less energy. The UEC and retail price data are shown in Table 5-5 and 

Table 5-6 for top-mount and side-mount units, respectively. The Department used data from The 

NPD Group to estimate the percent of shipments allocated to each size category to arrive at 

weighted-average UEC and retail price values. 1 The UECs are from the life-cycle cost (LCC) 

and payback period (PBP) analysis. The retail prices are also from the LCC and PBP analysis 

and are based on the average manufacturing-cost-based retail prices as well as the regression 

analysis-based retail prices. 

Table 5-5. Weighted-Average UECs and Retail Prices: Refrigerator-Freezers with TopMount Freezer and without TTD Ice Service 

Table 5-6. Weighted-Average UECs and Retail Prices: Refrigerator-Freezers with SideMount Freezer and with TTD Ice Service 

21-23 25.1% 677 575 508 $702 $756 $955 $750 

24-26 74.2% 719 611 539 $789 $824 $988 $855 

27-30 0.3% 762 648 572 $926 $1,110 $1,209* $1014 

Weighted-Avg. Value 709 602 531 $767 $808 $980 $829 

* Due to insufficient data, the value here is an approXimatIOn based on the plice differential for the energy 

model for the two smaller size categories. 

Sources: Percent of Shipments: The NPD GroupINPD Houseworld - POS ; DEC: Table 4-18, LCC and PEP Analysis; 

Retail Price: Table 4-24, LCC and PEP Analysis. 

5-10 
4.7

5.3.2.2 Base Case and Standards Case Market Shares

The UECs and consumer retail prices associated with the base case and standards case are

dependent on the market shares of baseline, 15 percent less energy, and 25 percent less energy

products.

Base Case Market Shares. The Department based the market share of baseline and

current Energy Star (i.e., 15 percent less energy) products for top-mount and side-mount

refrigerator-freezers in the years 2002-2004 on data provided by AHAM (Table 5-7).' Note that

the market share of products with 25 percent less energy consumption for the years 2002-2004 is

negligible. Also note that market share data were not made available for the first year (2001) in

which the last set of refrigerator-freezer energy conservation standards became effective.

Table 5-7. Market Share of Baseline and Current Energy Star Refrigerator-Freezers

2002 86% 14% 54% 46%

2003 79% 21% 49% 51%

2004 78% 22% 51% 49%

Source: AHAM.

For years after 2004, because the market share of current Energy Star products did not

appreciably change from 2003 to 2004, the Department assumed for the base case that the market

share of baseline and current Energy Star products remained essentially unchanged from their

2004 levels. From 2005 to 2035, the Department assumed that the market share of baseline and

current Energy Star refrigerator-freezers stay fixed at 78 percent and 22 percent, respectively.

For side-mount refrigerator-freezers, the Department assumed that the market share of baseline

and current Energy Star products remained at 50 percent each from 2005 to 2035.

Standards Case Market Shares. For a new amended energy conservation standard set at

current Energy Star levels (i.e., 15 less energy consumption), the market share of the current

Energy Star product (which would become the new baseline level) and any future Energy Star

product can have a significant impact on the NES and NPV due to the new standard. Because it

is difficult to forecast the market share of products once a new standard becomes effective, the

Department analyzed the following two market share scenarios: (1) a No Future Energy Star

scenario where 100 percent of the market is assumed to be at the new standard level (which is

equivalent to the current Energy Star level), and (2) a Current Energy Star scenario where

market shares of current and future Energy Star are assumed to be equivalent to the market

shares of current baseline and current Energy Star products. Under the Current Energy Star

scenario, the future Energy Star level. is assumed to have 25 percent less energy consumption

than current baseline products.

Table 5-8 shows the standards case market shares for top-mount refrigerators under the

No Future Energy Star and Current Energy Star market share scenarios. Under the Current

Energy Star scenario, after the standard becomes effective in 2010, the market share of current

and future Energy Star products in the years 2011-2013 are assumed to be equivalent to the

market share of current baseline and current Energy Star products in the years 2002-2004. For

5-11

 EE-PS-2006-001 COMMENT 04.7

#4.7 

5.3.2.2 Base Case and Standards Case Market Shares 

The UECs and consumer retail prices associated with the base case and standards case are 

dependent on the market shares of baseline, 15 percent less energy, and 25 percent less energy 

products. 

Base Case Market Shares. The Department based the market share of baseline and 

current Energy Star (i.e., 15 percent less energy) products for top-mount and side-mount 

refrigerator-freezers in the years 2002-2004 on data provided by AHAM (Table 5-7).1 Note that 

the market share of products with 25 percent less energy consumption for the years 2002-2004 is 

negligible. Also note that market share data were not made available for the fIrst year (2001) in 

which the last set of refrigerator-freezer energy conservation standards became effective. 

Table 5-7. Market Share of Baseline and Current Energy Star Refrigerator-Freezers 

For years after 2004, because the market share of current Energy Star products did not 

appreciably change from 2003 to 2004, the Department assumed for the base case that the market 

share of baseline and current Energy Star products remained essentially unchanged from their 

2004 levels. From 2005 to 2035, the Department assumed that the market share of baseline and 

current Energy Star refrigerator-freezers stay fIxed at 78 percent and 22 percent, respectively. 

For side-mount refrigerator-freezers, the Department assumed that the market share of baseline 

and current Energy Star products remained at 50 percent each from 2005 to 2035. 

Standards Case Market Shares. For a new amended energy conservation standard set at 

current Energy Star levels (i.e., 15 less energy consumption), the market share of the current 

Energy Star product (which would become the new baseline level) and any future Energy Star 

product can have a signifIcant impact on the NES and NPV due to the new standard. Because it 

is difficult to forecast the market share of products once a new standard becomes effective, the 

Department analyzed the following two market share scenarios: (1) a No Future Energy Star 

scenario where 100 percent of the market is assumed to be at the new standard level (which is 

equivalent to the current Energy Star level), and (2) a CUlTent Energy Star scenario where 

market shares of current and future Energy Star are assumed to be equivalent to the market 

shares of current baseline and current Energy Star products. Under the Current Energy Star 

scenario, the future Energy Star level is assumed to have 25 percent less energy consumption 

than current baseline products. 

Table 5-8 shows the standards case market shares for top-mount refrigerators under the 

No Future Energy Star and CUlTent Energy Star market share scenarios. Under the Current 

Energy Star scenario, after the standard becomes effective in 2010, the market share of current 

and future Energy Star products in the years 2011-2013 are assumed to be equivalent to the 

market share of CUlTent baseline and current Energy Star products in the years 2002-2004. For 

5-11 
subsequent years out to 2035, the market shares are equivalent to what is assumed in the base

case for current baseline and current Energy Star products (i.e., 78 percent and 22 percent,

respectively). Because data were not available to show the market share of current Energy Star

products in 2001, the Department assumed that the market shares of current and future Energy

Star products in 2010 are 90 percent and 10 percent, respectively.

Table 5-8. Standards Case Market Share Scenarios: Refrigerator-Freezers with TopMount Freezer and without TTD Ice Service

2002 86% 14% 0% 86% 14% 0%

2003 79% 21% 0% 79% 21% 0%

2004 78% 22% 0% 78% 22% 0%

2005 78% 22% 0% 78% 22% 0%

2006 78% 22% 0% 78% 22% 0%

2007 78% 22% 0% 78% 22% 0%

2008 78% 22% 0% 78% 22% 0%

2009 78% 22% 0% 78% 22% 0%

2010 0% 100% 0% 0% 90% 10%

2011 0% 100% 0% 0% 86% 14%

2012 0% 100% 0% 0% 79% 21%

2013 0% 100% 0% 0% 78% 22%

2014 0% 100% 0% 0% 78% 22%

2015 0% 100% 0% 0% 78% 22%

2016 0% 100% 0% 0% 78% 22%

2017 0% 100% 0% 0% 78% 22%

2018 0% 100% 0% 0% 78% 22%

2019 0% 100% 0% 0% 78% 22%

2020 0% 100% 0% 0% 78% 22%

2021 0% 100% 0% 0% 78% 22%

2022 0% 100% 0% 0% 78% 22%

2023 0% 100% 0% 0% 78% 22%

2024 0% 100% 0% 0% 78% 22%

2025 0% 100% 0% 0% 78% 22%

2026 0% 100% 0% 0% 78% 22%

2027 0% 100% 0% 0% 78% 22%

2028 0% 100% 0% 0% 78% 22%

2029 0% 100% 0% 0% 78% 22%

2030 0% 100% 0% 0% 78% 22%

2031 0% 100% 0% 0% 78% 22%

2032 0% 100% 0% 0% 78% 22%

2033 0% 100% 0% 0% 78% 22%

2034 0% 100% 0% 0% 78% 22%

2035 0% 100% 0% 0% 78% 22%

Table 5-9 shows the standards case market shares for side-mount refrigerators under the

No Future Energy Star and Current Energy Star market share scenarios. Under the Current

Energy Star scenario, after the standard becomes effective in 2010, the market share of current

5-12

 EE-PS-2006-001 COMMENT 04.7

#4.7 

subsequent years out to 2035, the market shares are equivalent to what is assumed in the base 

case for current baseline and current Energy Star products (i.e., 78 percent and 22 percent, 

respectively). Because data were not available to show the market share of current Energy Star 

products in 2001, the Department assumed that the market shares of current and future Energy 

Star products in 2010 are 90 percent and 10 percent, respectively. 

Table 5-8. Standards Case Market Share Scenarios: Refrigerator-Freezers with TopMount Freezer and without TTD Ice Service 

2002 86% 14% 0% 86% 14% 0% 

2003 79% 21% 0% 79% 21% 0% 

2004 78% 22% 0% 78% 22% 0% 

2005 78% 22% 0% 78% 22% 0% 

2006 78% 22% 0% 78% 22% 0% 

2007 78% 22% 0% 78% 22% 0% 

2008 78% 22% 0% 78% 22% 0% 

2009 78% 22% 0% 78% 22% 0% 

2010 0% 100% 0% 0% 90% 10% 

2011 0% 100% 0% 0% 86% 14% 

2012 0% 100% 0% 0% 79% 21% 

2013 0% 100% 0% 0% 78% 22% 

2014 0% 100% 0% 0% 78% 22% 

2015 0% 100% 0% 0% 78% 22% 

2016 0% 100% 0% 0% 78% 22% 

2017 0% 100% 0% 0% 78% 22% 

2018 0% 100% 0% 0% 78% 22% 

2019 0% 100% 0% 0% 78% 22% 

2020 0% 100% 0% 0% 78% 22% 

2021 0% 100% 0% 0% 78% 22% 

2022 0% 100% 0% 0% 78% 22% 

2023 0% 100% 0% 0% 78% 22% 

2024 0% 100% 0% 0% 78% 22% 

2025 0% 100% 0% 0% 78% 22% 

2026 0% 100% 0% 0% 78% 22% 

2027 0% 100% 0% 0% 78% 22% 

2028 0% 100% 0% 0% 78% 22% 

2029 0% 100% 0% 0% 78% 22% 

2030 0% 100% 0% 0% 78% 22% 

2031 0% 100% 0% 0% 78% 22% 

2032 0% 100% 0% 0% 78% 22% 

2033 0% 100% 0% 0% 78% 22% 

2034 0% 100% 0% 0% 78% 22% 

2035 0% 100% 0% 0% 78% 22% 

Table 5-9 shows the standards case market shares for side-mount refrigerators under the 

No Future Energy Star and Current Energy Star market share scenarios. Under the Current 

Energy Star scenario, after the standard becomes effective in 2010, the market share of current 

5-12 
#4®7

and future Energy Star products in the years 2011-2013 would be equivalent to the market share

of current baseline and current Energy Star products in the years 2002-2004. For subsequent

years out to 2035, the market shares are equivalent to what is assumed in the base case for

current baseline and current Energy Star products (i.e., 50 percent). Because data were not

available to show the market share of current Energy Star products in 2001, the Department

assumed that the market shares of current and future Energy Star products in 2010 are 75 percent

and 25 percent, respectively.

Table 5-9. Standards Case Market Share Scenarios: Refrigerator-Freezers with SideMount Freezer and with TTD Ice Service

2002 54% 46% 0%

2003 49% 51% 0%

2004 51% 49% 0%

2005 50% 50% 0%

2006 50% 50% 0%

2007 50% 50% 0%

2008 50% 50% 0%

2009 50% 50% 0%

2010 0% 100% 0%

2011 0% 100% 0%

2012 0% 100% 0%

2013 0% 100% 0%

2014 0% 100% 0%

2015 0% 100% .0%

2016 0% 100% 0%

2017 0% 100% 0%

2018 0% 100% 0%

2019 0% 100% 0%

2020 0% 100% 0%

2021 0% 100% 0%

2022 0% 100% 0%

2023 0% 100% 0%

2024 0% 100% 0%

2025 0% 100% 0%

2026 0% 100% 0%

2027 0% 100% 0%

2028 0% 100% 0%

2029 0% 100% 0%

2030 0% 100% 0%

2031 0% 100% 0%

2032 0% 100% 0%

2033 0% 100% 0%

2034 0% 100% 0%

2035 0% 100% 0%

54%

49%

51%

50%

50%

50%

50%

50%

46%

51%

49%

50%

50%

50%

50%

50%

75%

54%

49%

51%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

0%

0%

0%

0%

0%

0%

0%

0%

25%

46%

51%

49%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

50%

 EE-PS-2006-001 COMMENT 04.7

#4.7 

and future Energy Star products in the years 2011-2013 would be equivalent to the market share 

of current baseline and current Energy Star products in the years 2002-2004. For subsequent 

years out to 2035, the market shares are equivalent to what is assumed in the base c£l~~ for 

current baseline and current Energy Star products (i.e., 50 percent). Because data were not 

available to show the market share of current Energy Star products in 2001, the Department 

assumed that the market shares of current and future Energy Star products in 2010 are 75 percent 

and 25 percent, respectively. 

Table 5-9. Standards Case Market Share Scenarios: Refrigerator-Freezers with SideMount Freezer and with TTD Ice Service 

2002 54% 46% 0% 54% 46% 0% 

2003 49% 51% 0% 49% 51% 0% 

2004 51% 49% 0% 51% 49% 0% 

2005 50% 50% 0% 50% 50% 0% 

2006 50% 50% 0% 50% 50% 0% 

2007 50% 50% 0% 50% 50% 0% 

2008 50% 50% 0% 50% 50% 0% 

2009 50% 50% 0% 50% 50% 0% 

2010 0% 100% 0% 0% 75% 25% 

2011 0% 100% 0% 0% 54% 46% 

2012 0% 100% 0% 0% 49% 51% 

2013 0% 100% 0% 0% 51% 49% 

2014 0% 100% 0% 0% 50% 50% 

2015 0% 100% 0% 0% 50% 50% 

2016 0% 100% 0% 0% 50% 50% 

2017 0% 100% 0% 0% 50% 50% 

2018 0% 100% 0% 0% 50% 50% 

2019 0% 100% 0% 0% 50% 50% 

2020 0% 100% 0% 0% 50% 50% 

2021 0% 100% 0% 0% 50% 50% 

2022 0% 100% 0% 0% 50% 50% 

2023 0% 100% 0% 0% 50% 50% 

2024 0% 100% 0% 0% 50% 50% 

2025 0% 100% 0% 0% 50% 50% 

2026 0% 100% 0% 0% 50% 50% 

2027 0% 100% 0% 0% 50% 50% 

2028 0% 100% 0% 0% 50% 50% 

2029 0% 100% 0% 0% 50% 50% 

2030 0% 100% 0% 0% 50% 50% 

2031 0% 100% 0% 0% 50% 50% 

2032 0% 100% 0% 0% 50% 50% 

2033 0% 100% 0% 0% 50% 50% 

2034 0% 100% 0% 0% 50% 50% 

2035 0% 1000() 0% 0% 50% 50% 

5-13 
5.3.2.3 Base Case and Standards Case Unit Electricity Consumption and

Consumer Retail Prices

Based on the weighted-average UEC and per- unit consumer retail price data in Table 5-5

and Table 5-6, and the base case and standards case market share data in Table 5-7, Table 5-8,

and Table 5-9, the Department determined the average annual UEC and consumer retail price of

new product shipments corresponding to each year of the base case and standards case forecast.

Base Case and Standards Case Unit Energy Consumption. Table 5-10 and Figure 5-4

show the average UECs of new product shipments in the base case and standards case for the

top-mount refrigerator-freezer product class. Table 5-1.1. and Figure 5-5 show the average UECs

of new product shipments in the base case and standards case for the side-mount refrigeratorfreezer product class. Under the standards case there are two scenarios considered; the No

Future Energy Star and Current Energy Star scenarios.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

5.3.2.3 Base Case and Standards Case Unit Electricity Consumption and 

Consumer Retail Prices 

Based on the weighted-average UEC and per-unit consumer retail price data in Table 5-5 

and Table 5-6, and the base case and standards case market share data in Table 5-7, Table 5-8, 

and Table 5-9, the Department determined the average annual UEC and consumer retail price of 

new product shipments corresponding to each year of the base case and standards case forecast. 

Base Case and Standards Case Unit Energy Consumption. Table 5-10 and Figure 5-4 

show the average UECs of new product shipments in the base case and standards case for the 

top-mount refrigerator-freezer product class. Table 5-11 and Figure 5-5 show the average UECs 

of new product shipments in the base case and standards case for the side-mount refrigeratorfreezer product class. Under the standards case there are two scenarios considered; the No 

Future Energy Star and Current Energy Star scenarios. 

5-14 
#4®7

Table 5-10. Base Case and Standards Case Average UECs for New Product Shipments:

Refrigerator-Freezers with Top-Mount Freezer and without TTD Ice Service

: { t .E^i 1. ^^I. RI1.11l y,'n Ir ^b'.^yI I I II c' _

2002 483 483 483

2003 477 477 477

2004 477 477 477

2005 477 477 477

2006 477 477 477

2007 477 477 477

2008 477 477 477

2009 477 477 477

2010 477 419 414

2011 477 419 412

2012 477 419 409

2013 477 419 408

2014 477 419 408

2015 477 419 408

2016 477 419 408

2017 477 419 408

2018 477 419 408

2019 477 419 408

2020 477 419 408

2021 477 419 408

2022 477 419 408

2023 477 419 408

2024 477 419 408

2025 477 419 408

2026 477 419 408

2027 477 419 408

2028 477 419 408

2029 477 419 408

2030 477 419 408

2031 477 419 408

2032 477 419 408

2033 477 41.9 408

2034 477 419 408

2035 477 419 408

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 5-10. Base Case and Standards Case Average UECs for New Product Shipments: 

Refrigerator-Freezers with Top-Mount Freezer and without TTD Ice Service 

2002 483 483 483 

2003 477 477 477 

2004 477 477 477 

2005 477 477 477 

2006 477 477 477 

2007 477 477 477 

2008 477 477 477 

2009 477 477 477 

2010 477 419 414 

2011 477 419 412 

2012 477 419 409 

2013 477 419 408 

2014 477 419 408 

2015 477 419 408 

2016 477 419 408 

2017 477 419 408 

2018 477 419 408 

2019 477 419 408 

2020 477 419 408 

2021 477 419 408 

2022 477 419 408 

2023 477 419 408 

2024 477 419 408 

2025 477 419 408 

2026 477 419 408 

2027 477 419 408 

2028 477 419 408 

2029 477 419 408 

2030 477 419 408 

2031 477 419 408 

2032 477 419 408 

2033 477 419 408 

2034 477 419 408 

2035 477 419 408 

5-15 
Figure 5-4. Base Case and Standards Case Average UECs for New Product Shipments:

Refrigerator-Freezers with Top-Mount Freezer and without TTD Ice Service

5-16

 EE-PS-2006-001 COMMENT 04.7

490 

480 ~ 1m. 

470 

460 

"i:" 

>-

~ 450 

~ () 440 

w 

::;) 

430 

420 fl"-u-u-o--c 

410 ~ 

400 

2001 2005 2009 2013 

#4.7 

Base Case 

, 

1 

No Future Energy Star Scenario Standards Case 

:::l--{]--{:j---Cr--Q' .......... O ............ ·Q ......... u-{:}--·r.l---i::l--(:}-()-......... Cf. .. · .. · ...... ,[)_ .. o-c :::j.-n-r.l-(1 

Current Energy Star Scenario Standards Case 

2017 

Year 

2021 2025 2029 2033 

Figure 5-4. Base Case and Standards Case Average UECs for New Product Shipments: 

Refrigerator-Freezers with Top-Mount Freezer and without TTD Ice Service 

5-16 
#4 ®7

Table 5-11. Base Case and Standards Case Average UECs for New Product Shipments:

Refrigerator-Freezers with Side-Mount Freezer and with TTD Ice Service

^•H.c. ( ^`-d cl.. ^^ jiJ ^i`_iiell^3.,' iv^R 'r g..^.:-'r ^^dalV;lp±

ht''d!' I+Js.^^_ -^ rl,l^tt I - _carea;t....

2002 660 660 660

2003 654 654 654

2004 656 656 656

2005 655 655 655

2006 655 655 655

2007 655 655 655

2008 655 655 655

2009 655 655 655

2010 655 602 585

2011 655 602 570

2012 655. 602 566

2013 655 602 568

2014 655 602 567

2015 655 602 567

2016 655 602 567

201.7 655 602 567

2018 655 602 567

2019 655 602 567

2020 655 602 567

2021 655 602 567

2022 655 602 567

2023 655 602 567

2024 655 602 567

2025 655 602 567

2026 655 602 567

2027 655 602 567

2028 655 602 567

2029 655 602 567

2030 655 602 567

2031 655 602 567

2032 655 602 567

2033 655 602 567

2034 655 602 567

2035 655 602 567

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 5-11. Base Case and Standards Case Average UECs for New Product Shipments: 

Refrigerator-Freezers with Side-Mount Freezer and with TTD Ice Service 

2002 660 660 660 

2003 654 654 654 

2004 656 656 656 

2005 655 655 655 

2006 655 655 655 

2007 655 655 655 

2008 655 655 655 

2009 655 655 655 

2010 655 602 585 

2011 655 602 570 

2012 655 602 566 

2013 655 602 568 

2014 655 602 567 

2015 655 602 567 

2016 655 602 567 

2017 655 602 567 

2018 655 602 567 

2019 655 602 567 

2020 655 602 567 

2021 655 602 567 

2022 655 602 567 

2023 655 602 567 

2024 655 602 567 

2025 655 602 567 

2026 655 602 567 

2027 655 602 567 

2028 655 602 567 

2029 655 602 567 

2030 655 602 567 

2031 655 602 567 

2032 655 602 567 

2033 655 602 567 

2034 655 602 567 

2035 655 602 567 

5-17 
660

650

640

620

610

U

600

590

630

Base Case

No Future Energy Star Scenario Standards Case

Current Energy Star Scenario Standards Case

Year

Figure 5-5. Base Case and Standards Case Average UECs for New Product Shipments:

Refrigerator-Freezers with Side-Mount Freezer and with TTD Ice Service

Base Case and Standards Case Unit Consumer Retail Prices. Table 5-12 and Figure 5-

6 show the average per-unit consumer retail prices of new product shipments in the base case and

standards case for the top-mount refrigerator-freezer product class. Table 5-13 and Figure 5-7

show the average per-unit consumer retail prices of new product shipments in the base case and

standards case for the side-mount refrigerator-freezer product class. Under the standards case

there are two scenarios considered; the No Future Energy Star and Current Energy Star

scenarios. For the No Future Energy Star scenario, retail prices are based on the two sets of price

estimates; average manufacturing cost-based and regression analysis-based. As noted earlier, the

Current Energy Star scenario is composed of products with 15 percent less energy consumption

and 25 percent less energy consumption. Because the Department could not use the regression

analysis to generate prices for products with 25 percent less energy consumption, retail prices

under the Current Energy Star scenario are based only on manufacturing costs.

5-18

 EE-PS-2006-001 COMMENT 04.7

660 "\ .... w650 

640 

630 

'i:' 620 ?: 

I! 

! 

1\ 

'l 

~ 610 

(.) 

w 600 ::I 

590 \ 

580 

570 

560 

2001 2005 2009 

\ 

""-,... 

2013 

#4.7 

Base CaseNo Future Energy Star Scenario Standards Case -

Current Energy Star Scenario Standards Case _ 

2017 

Year 

2021 2025 2029 2033 

I 

Figure 5-5. Base Case and Standards Case Average UECs for New Product Shipments: 

Refrigerator-Freezers with Side-Mount Freezer and with TTD Ice Service 

Base Case and Standards Case Unit Consumer Retail Prices. Table 5-12 and Figure 5-

6 show the average per-unit consumer retail prices of new product shipments in the base case and 

standards case for the top-mount refrigerator-freezer product class. Table 5-13 and Figure 5-7 

show the average per-unit consumer retail prices of new product shipments in the base case and 

standards case for the side-mount refrigerator-freezer product class. Under the standards case 

there are two scenarios considered; the No Future Energy Star and Current Energy Star 

scenarios. For the No Future Energy Star scenario, retail prices are based on the two sets of price 

estimates; average manufacturing cost-based and regression analysis-based. As noted earlier, the 

Current Energy Star scenario is composed of products with 15 percent less energy consumption 

and 25 percent less energy consumption. Because the Department could not use the regression 

analysis to generate prices for products with 25 percent less energy consumption, retail prices 

under the Current Energy Star scenario are based only on manufacturing costs. 

5-18 
#4®7

Table 5-12. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for

New Product Shipments: Refrigerator-Freezers with Top-Mount Freezer and without

TTD Ice Service

2002 $398 $398

2003 $400 $400

2004 $401 $401

2005 $401 $401

2006 $401 $401

2007 $401 $401

2008 $401 $401

2009 $401 $401

2010 $401 $430

2011 $401 $430

2012 $401 $430

2013 $401 $430

2014 $401 $430

2015 $401 $430

2016 $401 $430

2017 $401 $430

2018 $401 $430

2019 $401 $430

2020 $401 $430

2021 $401 $430

2022 $401 $430

2023 $401 $430

2024 $401 $430

2025 $401 $430

2026 $401 $430

2027 $401 $430

2028 $401 $430

2029 $401 $430

2030 $401 $430

2031 $401 $430

2032 $401 $430

2033 $401 $430

2034 $401 $430

2035 $401 $430

$398

$400

$401

$401

$401

$401

$401

$401

$445

$451

$461

$463

$463

$463

$463

$463

$463

$463

$463

$463

$463

$463

$463

$463

$463

$463

$463

$463

$463

$463

$463

$463

$463

$463

$399

$402

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

$403

X399

$402

$403

$403

$403

$403

$403

$403.

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

$440

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 5-12. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for 

New Product Shipments: Refrigerator-Freezers with Top-Mount Freezer and without 

TTD Ice Service 

2002 $398 $398 $398 $399 $399 

2003 $400 $400 $400 $402 $402 

2004 $401 $401 $401 $403 $403 

2005 $401 $401 $401 $403 $403 

2006 $401 $401 $401 $403 $403 

2007 $401 $401 $401 $403 $403 

2008 $401 $401 $401 $403 $403 

2009 1 1 $401 $403 $403 

2010 $401 $430 $445 $403 $440 

2011 $401 $430 $451 $403 $440 

2012 $401 $430 $461 $403 $440 

2013 $401 $430 $463 $403 $440 

2014 $401 $430 $463 $403 $440 

2015 $401 $430 $463 $403 $440 

2016 $401 $430 $463 $403 $440 

2017 $401 $430 $463 $403 $440 

2018 $401 $430 $463 $403 $440 

2019 $401 $430 $463 $403 $440 

2020 $401 $430 $463 $403 $440 

2021 $401 $430 $463 $403 $440 

2022 $401 $430 $463 $403 $440 

2023 $401 $430 $463 $403 $440 

2024 $401 $430 $463 $403 $440 

2025 $401 $430 $463 $403 $440 

2026 $401 $430 $463 $403 $440 

2027 $401 $430 $463 $403 $440 

2028 $401 $430 $463 $403 $440 

2029 $401 $430 $463 $403 $440 

2030 $401 $430 $463 $403 $440 

2031 $401 $430 $463 $403 $440 

2032 $401 $430 $463 $403 $440 

2033 $401 $430 $463 $403 $440 

2034 $401 $430 $463 $403 $440 

2035 $401 $430 $403 $440 

5-19 
.... _..._.... -_...... _--__

Mfg Cost-Based Retail Price: Current Energy Star Scenario Standards Case

Regression-Based Retail Price:

No Future Energy Star Scenario Standards Case

..................

Mfg Cost-Based Retail Price:

No Future Energy Star Scenario Standards Case

Regression-Based Retail Price : Base Case ...__......... .-_

1

deo'

......&_........._........g..._ -0 .......0 ....10 .....0 .....1C,...._0'....10.........0..._p...._p.......p......p.......p......Gz......p............G;......p......q......^y.......0 ...._0...._0 ......

Mfg Cost-Based Retail Price : Base Case

Figure 5-6. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for

New Product Shipments: Refrigerator-Freezers with Top-Mount Freezer and without

TTD Ice Service

5-20

 EE-PS-2006-001 COMMENT 04.7

#4.7 $470~-----------------------·----·····------·--------·-·---·- .. -----.... -.-.. - .. --.----.. --, Mfg Cost-Based Retail Price: Current Energy Star Scenario Standards Case 

$460+----------------1-~~----------------------------------~ 

i $450 -l-----------------}L---- Regression-Based Retail Price: 

g I No Future Energy Star Scenario Standards Case 

~ ~ (I) $440 ~~~-..~,...,..c,..., 

(,) 

";:: 

0.. 

~ $430 -------.. -- , 

a: Mfg Cost-Based Retail Price: 

lii $420 -J---------fl--------No Future Energy Star Scenario Standards Case -

E 

::J 

III 

g $410 ........... -------.. ---...... -_.-.......................... _ .... --.... -.- Regression-Based Retail Price: Base Case .... -.... -........ . 

/ u ~ ..... 'tk-... ., ... Ii!l ...... ., ..... -1j ...... <> ..... -0 ...... <:> ...... " ..... <> ...... 6--.. -0 ...... 6-...... "' ..... -0 ...... 6-... --0 ...... {> ...... <> ... -o-... (, ....... " ...... {> ...... <> ...... " ...... <> ...... " ...... {> ... <> ...... " .... .. 

$400~y~~~~~~~~~~~~~~~~~~~~~~~~ 

Mfg Cost-8ased Retail Price: Base case/ 

$390+-~--~~~-r--~~--~~--~--~-r--~~--~~--~~ 

2001 2005 2009 2013 2017 

Year 

2021 2025 2029 2033 

Figure 5-6. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for 

New Product Shipments: Refrigerator-Freezers with Top-Mount Freezer and without 

TTD Ice Service 

5-20 
#4.7

Table 5-13. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for

New Product Shipments: Refrigerator-Freezers with Side-Mount Freezer and with TT D

Ice Service

2002

2003

2004

2005

2006

2007

2008

2009

$786

$788

$787

$788

$788

$788

$788

$788

$786

$788

$787

$788

$788

$788

$788

$788

$786

$788

$787

$788

$788

$788

$788

$788

$796

$799

$797

$798

$798

$798

$798

$798

%96

$799

$797

$798

$798

$798

$798

$798

2010 $788 $808 $851 $798 $829

2011 $788 $808 $887 $798 $829

2012 $788 $808 $896 $798 $829

2013 $788 $808 $892 $798 $829

2014 $788 $808 $894 $798 $829

2015 $788 $808 $894 $798 $829

2016 $788 $808 $894 $798 $829

2017 $788 $808 $894 $798 $829

2018 $788 $808 $894 $798 $829

2019 $788 $808 $894 $798 $829

2020 $788 $808 $894 $798 $829

2021 $788 $808 $894 $798 $829

2022 $788 $808 $894 $798 $829

2023 $788 $808 $894 $798 $829

2024 $788 $808 $894 $798 $829

2025 $788 $808 $894 $798 $829

2026 $788 $808 $894 $798 $829

2027 $788 $808 $894 $798 $829

2028 $788 $808 $894 $798 $829

2029 $788 $808 $894 $798 $829

2030 $788 $808 $894 $798 $829

2031 $788 $808 $894 $798 $829

2032 $788 $808 $894 $798 $829

2033 $788 $808 $894 $798 $829

2034 $788 $808 $894 $798 $829

2035 $788 $808 $894 $798 $829

 EE-PS-2006-001 COMMENT 04.7

#.4.7 

Table 5-13. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for 

New Product Shipments: Refrigerator-Freezers with Side-Mount Freezer and with TTD 

Ice Service 

2002 $786 $786 $786 $796 $796 

2003 $788 $788 $788 $799 $799 

2004 $787 $787 $787 $797 $797 

2005 $788 $788 $788 $798 $798 

2006 $788 $788 $788 $798 $798 

2007 $788 $788 $788 $798 $798 

2008 $788 $788 $788 $798 $798 

2009 $788 $788 $788 $798 $798 

2010 $788 $808 $851 $798 

2011 $788 $808 $887 $798 $829 

2012 $788 $808 $896 $798 $829 

2013 $788 $808 $892 $798 $829 

2014 $788 $808 $894 $798 $829 

2015 $788 $808 $894 $798 $829 

2016 $788 $808 $894 $798 $829 

2017 $788 $808 $894 $798 $829 

2018 $788 $808 $894 $798 $829 

2019 $788 $808 $894 $798 $829 

2020 $788 $808 $894 $798 $829 

2021 $788 $808 $894 $798 $829 

2022 $788 $808 $894 $798 $829 

2023 $788 $808 $894 $798 $829 

2024 $788 $808 $894 $798 $829 

2025 $788 $808 $894 $798 $829 

2026 $788 $808 $894 $798 $829 

2027 $788 $808 $894 $798 $829 

2028 $788 $808 $894 $798 $829 

2029 $788 $808 $894 $798 $829 

2030 $788 $808 $894 $798 $829 

2031 $788 $808 $894 $798 $829 

2032 $788 $808 $894 $798 $829 

2033 $788 $808 $894 $798 $829 

2034 $788 $808 $894 $798 $829 

2035 $788 $808 $894 8 $829 

5-21 
$900

$880

mV

a.

$840

d

d

E $820

U)

a

0

U

V

$800

$780

2001 2005

Mf Cost-Based Retail Price : Current Ener Star Scenario Standards Case

2009 2013 2017 2021

Year

2025 2029 2033

Figure 5-7. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for

New Product Shipments: Refrigerator-Freezers with Side-Mount Freezer and with TTD

Ice Service

5.3.3 Product Lifetime

As described in the LCC and PBP analysis, the Department estimated the product lifetime

from a prior technical support document (TSD) the Department published in 1995 to assess

whether amended energy conservation standards were warranted for refrigerator-freezers.' The

product lifetime from the prior TSD was estimated to be 19 years.

As noted in the LCC and PBP analysis, the length of first ownership is shorter than the

product lifetime. The Department has accounted for the length of first ownership in past

standards rulemakings, specifically, in the technical analysis that was conducted in support of the

most recent clothes washer Final Rule.` The shipments and national impact analyses accounted

for the length of clothes washer first ownership and how it related to the market of used clothes

washers.

For purposes of this national impact analysis for refrigerator-freezers, the Department did

not address the issues of first ownership and a used appliance market. If the Department pursues

a standards rulemaking, the extent to which first ownership and a used appliance market are

addressed will depend on the input of stakeholders.

5.3.4 Electricity Price

As described in the LCC and PBP analysis, the Department calculated electricity prices

for the residential sector from the Energy Information Administration (EIA)'s Annual Energy

- - - - - - - - - - - - - -

. .................... 77

Regression-Based Retail Price:

No Future Energy Star Scenario Standards Case

.............{,,...._ .............,....._ ....... ......., _............, .--A............._ ........A...._..............y...............................................A........

Mfg Cost-Based Retail Price:

/ No Future Energy Star Scenario Standards Case

/ Regression-Based Retail Price : Base Case

Mfg Cost•Based Retail Price: Base Case

5-22

 EE-PS-2006-001 COMMENT 04.7

0' 

:g 

$900 

$880 

~ $860 

.;: ~ 

/l. 

.- $840 

~ a:: 

.... 

Q) 

E $820 ::s 

III 

c: 

o 

() 

$800 

$780 

2001 

=-

IlL 

III" 

2005 

#4.7 

Mfa Cost-Based Retail Price: Current Enerav Star Scenario Standards Case 

(~ 

I 

I 

t ... t;; ...... t;; ...... /i ...... t;; 

! 

'T 

2009 2013 

........ 

Regression-Based Retail Price: 

No Future Energy Star Scenario Standards Case ~ 

... -!J. ....... t> ...... -!J. ....... & ...... t> ...... {). ...... t. ....... -!J.·······{).······t,·······-b;······u······-!J.········t>·····-/i-· .... -!J. ....... -!J. ....... /i ..... ~ ....... {). ...... , 

Mfg Cost-Based Retail Price: 

/' No Future Energy Star Scenario Standards Case 

Regression-Based Retail Price: Base Case __ ~ 

~. Mfg Cost-Based Retail Price: Base Case 

2017 

Year 

2021 2025 2029 2033 

-

Figure 5-7. Base Case and Standards Case Average Per-Unit Consumer Retail Prices for 

New Product Shipments: Refrigerator-Freezers with Side-Mount :Freezer and with TTD 

Ice Service 

5.3.3 Product Lifetime 

As described in the Lee and PBP analysis, the Department estimated the product lifetime 

from a prior technical support document (TSD) the Department published in 1995 to assess 

whether amended energy conservation standards were warranted for refrigerator-freezers. 3 The 

product lifetime from the prior TSD was estimated ,to be 19 years. 

As noted in the Lee and PBP analysis, the length of first ownership is shorter than the 

product lifetime. The Department has accounted for the length of first ownership in past 

standards rulemakings, specifically, in the technical analysis that was conducted in support of the 

most recent clothes washer Final Rule. 4 The shipments and national impact analyses accounted 

for the length of clothes washer first ownership and how it related to the market of used clothes 

washers. 

For purposes of this national impact analysis for refrigerator-freezers, the Department did 

not address the issues of fIrst ownership and a used appliance market. If the Department pursues 

a standards rulemaking, the extent to which first ownership and a used appliance market are 

addressed will depend on the input of stakeholders. 

5.3.4 Electricity Price 

As described in the Lee and PBP analysis, the Department calculated electricity prices 

for the residential sector from the Energy Information Administration (EIA)'s Annual Energy 

5-22 
#4®7

Review (AER) 2003.5 Electricity prices are provided by EIA in nominal dollars and 2000 dollars

for the years 1960-2003. The Department used gross domestic product (GDP) implicit price

deflators to convert values into 2005 dollars.6

The Department then used EIA's Annual Energy Outlook 2005 (AEO 2005) Reference

Case? residential electricity price forecast to project prices from 2003 to 2035. The Department

used a linear extrapolation based on the last ten years (2015-2025) in the forecast to project

prices to the end of the analysis period (2035). Table 5-14 shows the forecasted electricity prices

based on a 2003 price of 8.93 cents per kilowatt-hour. (0/kWh).

Table 5-14. Historical and Forecasted Electricity Prices

r^; k^<1'i tiil'4 F. E.}r SI

2001 9.19 2026 8.54

2002 8.87 2027 8.56

2003 8.93 2028 8.58

2004 8.86 2029 8.59

2005 8.84 2030 8.61

2006 8.57 2031 8.63

2007 8.25 2032 8.65

2008 8.08 2033 8.67

2009 8.09 2034 8.68

2010 8.07 2035 8.70

2011 8.08 2036 8.72

2012 8.13 2037 8.74

2013 8.20 2038 8.76

2014 8.29 2039 8.77

2015 8.31 2040 8.79

2016 8.29 2041 8.81

2017 8.31 2042 8.83

2018 8.37 2043 8.85

2019 8.45 2044 8.87

2020 8.48 2045 8.88

2021 8.52 2046 8.90

2022 8.50 2047 8.92

2023 8.48 2048 8.94

2024 8.49 2049 8.96

2025 8.52 2050 8.97

Source : EIA AER 2003; EIA AEO 2005.

5.3.5 Site-to-Source Energy Conversion Factors

The Department calculated energy savings as site energy, which it then converted to

source energy- the energy that electric power plants consume. As shown in Table 5-15, the

Department used site-to-source energy conversion factors from the AEO 2005. The Department

extrapolated the values in later years (after 2025) from their relative sources because the AEO

5-23

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Review (AER) 2003.5 Electricity prices are provided by EIA in nominal dollars and 2000 dollars 

for the years 1960-2003. The Department used gross domestic product (GDP) implicit price 

deflators to convert values into 2005 dollars. 6 

The Department then used EIA's Annual Energy Outlook 2005 (AEO 2005) Reference 

Case7 residential electricity price forecast to project prices from 2003 to 2035. The Department 

used a linear extrapolation based on the last ten years (2015-2025) in the forecast to project 

prices to the end of the analysis period (2035). Table 5-14 shows the forecasted electricity prices 

based on a 2003 price of 8.93 cents per kilowatt-hour (¢/kWh). 

Table 5-14. Historical and Forecasted Electricity Prices 

2001 9.19 2026 8.54 

2002 8.87 2027 8.56 

2003 8.93 2028 8.58 

2004 8.86 2029 8.59 

2005 8.84 2030 8.61 

2006 8.57 2031 8.63 

2007 8.25 2032 8.65 

2008 8.08 2033 8.67 

2009 8.09 2034 8.68 

2010 8.07 2035 8.70 

2011 8.08 2036 8.72 

2012 8.13 2037 8.74 

2013 8.20 2038 8.76 

2014 8.29 2039 8.77 

2015 8.31 2040 8.79 

2016 8.29 2041 8.81 

2017 8.31 2042 8.83 

2018 8.37 2043 8.85 

2019 8.45 2044 8.87 

2020 8.48 2045 8.88 

2021 8.52 2046 8.90 

2022 8.50 2047 8.92 

2023 8.48 2048 8.94 

2024 8.49 2049 8.96 

2025 8.52 2050 8.97 

Source: EIA AER 2003; EIA AEO 2005. 

5.3.5 Site-to-Source Energy Conversion Factors 

The Department calculated energy savings as site energy, which it then converted to 

source energy- the energy that electric power plants consume. As shown in Table 5-15, the 

Department used site-to-source energy conversion factors from the AEO 2005. The Department 

extrapolated the values in later years (after 2025) from their relative sources because the AEO 

5-23 
does not forecast beyond 2025. To arrive at values for these later years, the Department used the

forecast's trend from 2015 to 2025 to establish conversion factors in the years 2025 to 2035.

Table 5-15. Site-to-Source Conversion Factors

2004 10,960

2005 10,942

2006 10,916

2007 10,900

2008 10,855

2009 10,805

2010 10,757

2011 10,709

2012 10,662

2013 1.0,631

2014 10,591

2015 10,541

2016 10,498

2017 10,463

201.8 1.0,419

2019 10,388

2020 10,352

2021 10,329

2022 10,302

2023 10,279

2024 10,259

2025 10,240

2026 10,210

2027 10,180

2028 10,151

2029 10,121

2030 10,092

2031 10,063

2032 1.0,034

2033 10,005

2034 9,975

2035 9,947

Source : EIA, AEO 2005.

5.3.6 Discount Rate

The Department calculated the NPV of cost savings with both a three-percent and a

seven-percent real discount rate. It used the three-percent real discount rate to represent the rate

at which society discounts future consumption flows to their present value, and the seven -percent

5-24

 EE-PS-2006-001 COMMENT 04.7

#4.7 

does not forecast beyond 2025. To arrive at values for these later years, the Department used the 

forecast's trend from 2015 to 2025 to establish conversion factors in the years 2025 to 2035. 

Table 5-15. Site-to-Source Conversion Factors 

2004 10,960 

2005 10,942 

2006 10,916 

2007 10,900 

2008 10,855 

2009 10,805 

2010 10,757 

2011 10,709 

2012 10,662 

2013 10,631 

2014 10,591 

2015 10,541 

2016 10,498 

2017 10,463 

2018 10,419 

2019 10,388 

2020 10,352 

2021 10,329 

2022 10,302 

2023 10,279 

2024 10,259 

2025 10,240 

2026 10,210 

2027 10,180 

2028 10,151 

2029 10,121 

2030 10,092 

2031 10,063 

2032 10,034 

2033 10,005 

2034 9,975 

2035 9,947 

Source: ElA, AEO 2005. 

5.3.6 Discount Rate 

The Department calculated the NPV of cost savings with both a three-percent and a 

seven-percent real discount rate. It used the three-percent real discount rate to represent the rate 

at which society discounts future consumption flows to their present value, and the seven-percent 

5-24 
#4®7

real discount rate to represent the average real rate of return on private investment in the U.S.

economy. The Department used these discount rates in accordance with the Office of

Management and Budget (OMB)'s guidance to Federal agencies on the development of

regulatory analysis (OMB Circular A-4, September 17, 2003), and section E, "Identifying and

Measuring Benefits and Costs," therein.

5.3.7 Analysis Period

For purposes of calculating the NES and NPV, the Department used an analysis period of

2010 (the assumed effective date of new energy conservation standards) through 2035. For the

calculation of the NPV, DOE determined increases in the national consumer retail prices for each

year of the analysis period (2010-2035); it determined national electricity cost savings for each

year beginning from the start of the analysis period (2010) to the year when products purchased

in the year 2035 retired.

5.4 NES AND NPV RESULTS

Table 5-16, Figure 5-8, and Figure 5-9 summarize the NES and NPV due to new energy

conservation standards set at 15 percent lower energy consumption than current energy

conservation standards. Results of the national impact analysis are provided for the two

standards case scenarios (No Future Energy Star and Current Energy Star), the two retail price

estimates (manufacturing cost-based or regression analysis-based), and the two discount rates

(three percent and seven percent real) considered for the national. impact analysis. As noted

earlier, regression analysis-based retail prices are applicable only to the No Future Energy Star

scenario.

For the No Future Energy Star standards case scenario, the NES due to standards for topmount and side- mount refrigerator-freezers are 2.4 quads of primary energy (1.1 quads from topmount refrigerator-freezers and 1.3 quads from side-mount refrigerator-freezers). For the

Current Energy Star standards case scenario, the savings are 3.4 quads of primary energy (1.3

quads from top-mount refrigerator-freezers and 2.1 quads from side-mount refrigerator-freezers).

The NPV of standards depends on the scenario, the retail price estimate, and the discount

rate. For a discount rate of three percent real, both standards case scenarios have a positive NPV.

The NPV of the No Future Energy Star scenario is $10.1. billion with manufacturing cost-based

retail prices and $8.0 billion with regression-based retail prices. The NPV of the Current Energy

Star scenario is $3.3 billion. For a discount rate of seven percent real, the No Future Energy Star

scenario still yields a positive NPV, $3.3 billion with manufacturing cost-based prices and $2.2

billion with regression-based prices, but the NPV under the Current Energy Star scenario

becomes negative at -$1.2 billion.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

real discount rate to represent the average real rate of return on private investment in the U.S. 

economy. The Department used these discount rates in accordance with the Office of 

Management and Budget (OMB)'s guidance to Federal agencies on the development of 

regulatory analysis (OMB Circular A-4, September 17, 2003), and section E, "Identifying and 

Measuring Benefits and Costs," therein. 

5.3.7 Ana1ysis Period 

For purposes of calculating the NES and NPV, the Department used an analysis period of 

2010 (the assumed effective date of new energy conservation standards) through 2035. Forthe 

calculation of the NPV, DOE determined increases in the national consumer retail prices for each 

year of the anaJysis period (2010-2035); it determined national electricity cost savings for each 

year beginning from the start of the analysis period (2010) to the year when products purchased 

in the year 2035 retired. 

5.4 NES AND NPV RESULTS 

Table 5-16, Figure 5-8, and Figure 5-9 summarize the NES and NPV due to new energy 

conservation standards set at 15 percent lower energy consumption than current energy 

conservation standards. Results of the national impact analysis are provided for the two 

standards case scenarios (No Future Energy Star and Current Energy Star), the two retail price 

estimates (manufacturing cost-based or regression analysis-based), and the two discount rates 

(three percent and seven percent real) considered for the national impact analysis. As noted 

earlier, regression analysis-based retail prices are applicable only to the No Future Energy Star 

scenario. 

For the No Future Energy Star standards case scenario, the NES due to standards for topmount and side-mount refrigerator-freezers are 2.4 quads of primary energy (1.1 quads from topmount refrigerator-freezers and 1.3 quads from side-mount refrigerator-freezers). For the 

Current Energy Star standards case scenario, the savings are 3.4 quads of primary energy (1.3 

quads from top-mount refrigerator-freezers and 2.1 quads from side-mount refrigerator-freezers). 

The NPV of standards depends on the scenario, the retail price estimate, and the discount 

rate. For a discount rate of three percent real, both standards case scenarios have a positive NPV. 

The NPV of the No Future Energy Star scenario is $10.1 billion with manufacturing cost-based 

retail prices and $8.0 billion with regression-based retail prices. The NPV of the Current Energy 

Star scenario is $3.3 billion. For a discount rate of seven percent real, the No Future Energy Star 

scenario still yieJds a positive NPV, $3.3 billion with manufacturing cost-based prices and $2.2 

billion with regression-based prices, but the NPV under the Current Energy Star scenario 

becomes negative at -$1.2 billion. 

5-25 
Table 5-16. National Energy Savings and Net Present Value of Standards for RefrigeratorFreezers with Top-Mount Freezer and without TTD Ice Service & with Side-Mount

Freezer and with TTD Ice Service (2010-2035)

No Future Energy Star Regress. 3%

Current Energy Star Mfg. Cost

No Future Energy Star Mfg. Cost

Regress. 1 7%

1.3 2.1 I 3.4

1.3 2.4

Current Energy Star I Mfg. Cost 1.3 1 2.1 1 3.4 11

4.0

Side-Mount

ElTop- Mount

2.4

0.0-I

3.4

$3.3 $4.7 $8.0

$2.4 $0.9 $3.3

$1.3 $2.0 $3.3

$0.9 $1.3 $2.2

$0.2 1 ($1.4)

No Future Energy Star Current Energy Star

Figure 5-8. National Energy Savings from Standards for Refrigerator-Freezers with TopMount Freezer and without TTD Ice Service & with Side-Mount Freezer and with TTD Ice Service

5-26

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 5-16. National Energy Savings and Net Present Value of Standards for RefrigeratorFreezers with Top-Mount Freezer and without TTD Ice Service & with Side-Mount 

Freezer and with TTD Ice Service (2010-2035) 

III Side-Mount 3.4 

3.5 III Top- Mount 1----------------- ------j 

'F 

!"II 

,~ 3.0 -1-------------------

c.. 

~ 2.4 ~ 2.5 +------- -----------

..!:!: 

II) 

~ 2.0 + .. _._ ........ -............. .. 'S; 

!"II 

en 

~ 1.5+----

>-

CI) 

c: 

w 1.0+----

iij 

c: 

o 

;; 

~ 0.5+----

0.0+----

No Future Energy Star Current Energy Star 

Figure 5-8. National Energy Savings from Standards for Refrigerator-Freezers with TopMount Freezer and without TTD Ice Service & with Side-Mount Freezer and with TTD Ice Service 

5-26 
#4e7

3% real discount rate 7% real discount rate

$12

$10.1 I Side-Mount-

$10 ® Top- M ount

car

0

$8.0

N $8

C

0

$6

as

$4 .. ._..__ -- - .._.._._ ^__...__ $3.3 _.... .......... . _. _.$3. 3 .... ..__. _......... _.........

$2.2

$2 j-^

-$1.2

$0

-$2

Mg Cost-Based: Regress-Based: Mfg Cost-Based: Mfg Cost-Based: Regress-Based: Mfg Cost -Based:

No Future Energy No Future Energy Current Energy No Future Energy No Future Energy Current Energy

Star Star Star Star Star Star

Figure 5-9. Net Present Value from Standards for Refrigerator-Freezers with Top-Mount Freezer

and without TTD Ice Service & with Side-Mount Freezer and with TTD Ice Service

5-27

 EE-PS-2006-001 COMMENT 04.7

$12 

$10 

(ii: 

U'l 

0 

0 

N $8 c 

g 

e $6 

Q) 

:::J 

iii $4 > 

... 

c 

Q) 

I/j $2 Q) 

... 

a. 

... 

Q) 

Z $0 

3% real discount rate 

$10.1 

Mfg Cost-Based: Regress-Based: 

No Future Energy No Future Energy 

Star Star 

Mfg Cost·Based: 

Current Energy 

Star 

#4.7 

7% real discount rate 

II Side-Mount 

IITop- Mount 

$2.2 

Mfg Cost·Based: Regress-Based: Mfg Cost-Based: 

No Future Energy No Future Energy Current Energy 

Star Star Star 

Figure 5-9. Net Present Value from Standards for Refrigerator-Freezers with Top-Mount Freezer 

and without TTD Ice Service & with Side-Mount Freezer and with TTD Ice Service 

5-27 
REFERENCES

Association of Home Appliance Manufacturers, Summary Data Tables: Refrigerator-Freezer

Data Collection for Cost/Efficiency Information for DOE Petition, 2005. Information

provided by the Association of Home Appliance Manufacturers (AHAM) to the U.S.

Department of Energy, May 13, 2005.

2

3

4

The NPD Group, Inc., The NPD GroupINPD Houseworld - POS, Refrigerators, January -

December. 2004, 2005. Port Washington, NY.

U.S. Department of Energy, Technical Support Document: Energy Efficiency Standards for

Consumer Products: Refrigerators, Refrigerator-Freezers, & Freezers, July 1995.

Washington, DC. Report No. DOE/EE-0064.

U.S. Department of Energy , Final Rule Technical Support Document (TSD): Energy

Efficiency Standards for Consumer Products: Clothes Washers, December 2000.

Washington, DC. Chapter 9.

U.S. Department of Energy-Energy Information Administration, Annual Energy Review

2003, September 2004. Washington DC. Report No. DOE/EIA-0384(2003). Table 8-10,

Average Retail Prices of Electricity, 1960-2003.

6 U.S. Government Printing Office, Budget of the United States Government: Historical Tables

Fiscal Year 2005, Section 10 - Gross Domestic Product and Implicit Outlay Deflators, Table

10.1 - Goss Domestic Product and Deflators Used in the Historical Tables: 1940-2009,

2005. Washington, DC. GPO Access: <http://www.gpoaccess.gov/usbudget/fy05/hist.html>

U.S. Department of Energy-Energy Information Administration, Annual Energy Outlook

2005, February 2005. Washington, DC. Report No. DOE/EIA-0383(2005).

 EE-PS-2006-001 COMMENT 04.7

#4.7 

REFERENCES 

2 

3 

4 

5 

6 

7 

Association of Home Appliance Manufacturers, Summary Data Tables: Refrigerator-Freezer 

Data CoUectionfor Cost/Efficiency Infonnationfor DOE Petition, 2005. Information 

provided by the Association of Home Appliance Manufacturers (AHAM) to the U.S. 

Department of Energy, May 13, 2005. 

The NPD Group, Inc., The NPD GrouplNPD Houseworld - POS, Refrigerators, JanuaryDecember 2004,2005. Port Washington, NY. 

U.S. Department of Energy, Technical Support Document: Energy £;fficiency Standardsfor 

Consumer Products: Refrigerators, Refrigerator-Freezers, & Freezers, July 1995. 

Washington, DC. Report No. DOEIEE-0064. 

U.S. Department of Energy, Final Rule Technical Support Document (TSD): Energy 

Efficiency Standards for Consumer Products: Clothes Washers, December 2000. 

Washington, DC. Chapter 9. 

U.S. Department of Energy-Energy Information Administration, Annual Energy Review 

2003, September 2004. Washington DC. Report No. DOEIEIA-0384(2003). Table 8-10, 

Average Retail Prices of Electricity, 1960-2003. 

U.S. Government Printing Office, Budget of the United States Government: Historical Tables 

Fiscal Year 2005, Section 10 - Gross Domestic Product and Implicit Outlay Deflators, Table 

10.1 - Goss Domestic Product and Deflators Used in the Historical Tables: 1940-2009, 

2005. Washington, DC. GPO Access: <http://www.gpoaccess.gov/usbudgetlfy05/hist.html> 

U.S. Department of Energy-Energy Information Administration, Annual Energy Outlook 

2005, February 2005. Washington, DC. Report No. DOEIEIA-0383(2005). 

5-28 
CHAPTER 6. MANUFACTURER IMPACT ANALYSIS

The Department carried out a preliminary evaluation of the impact of potential new

regulations on manufacturer financial performance, domestic refrigerator-freezer manufacturing

capacity and employment levels, and product utility and innovation. A primary focus was to

identify the cumulative burden that industry faces from the overlapping effect of new or recent

DOE standards and/or other regulatory action affecting the same product or industry. The

primary sources of information for this evaluation were the 2005 structured interviews with

manufacturers of refrigerator-freezers (see Appendix D). In order to maintain confidentiality,

information disclosed by individual manufacturers is not identified with a specific manufacturer.

Instead, this evaluation reports only aggregated information and does not disclose sensitive

information or identify company-specific information.

6.1 IMPACT ON FINANCIAL PERFORMANCE

The Department received manufacturers' views on what they perceived to be the possible

impact of potential new standards on their future profitability. As stated by manufacturers, a

new energy conservation standard has the potential to impact financial performance in several

different ways. The capital investment needed to upgrade or redesign products and product

platforms before they have reached the end of their useful life can require conversion costs that

otherwise would not be expended, resulting in stranded investments. In addition, higher

efficiency standards can result in higher per-unit costs that may deter some customers from

buying higher-margin units with more features, decreasing manufacturer profitability.

Manufacturers stated that the prospect of product redesign as a result of standards penalizes

established manufacturers and alters the playing field for entry to the market by new competitors

who do not carry debt burdens from recent investments in new product lines. In their view, this

can decrease the relative barrier for competitors entering the market, thereby increasing market

competition, reducing incumbent manufacturer profitability, and decreasing U.S.-based

production.

6.1.1 Conversion Costs

Typically, in the absence of new energy efficiency regulations, a refrigerator-freezer

production line would have a life cycle of approximately 1.5 to 20 years. During that period,

manufacturers would not make major product changes that altered the underlying platforms.

Thus, a standard that took effect and resulted in a major product platform redesign before the end

of the platform's life would cannibalize a portion of the earlier capital investments. Based on

discussions with manufacturers, most have made significant capital investments to meet the DOE

efficiency standard levels that took effect in 2001; new standards that required platform changes

could strand assets before the end of their useful life. The 1995 TSD estimated the capital

conversion costs for the 2001 standard at approximately 725 million dollars. Based on the

interviews, this figure is low by a factor of two compared. to the actual level of investment by the

refrigerator-freezer industry in the years leading up to and immediately following the 2001

standards implementation. It must be noted, however, that not all these costs can be attributed to

6-1

 EE-PS-2006-001 COMMENT 04.7

#4.7 

CHAPTER6. MANUFACTURER IMPACT ANALYSIS 

The Department carried out a preliminary evaluation of the impact of potential new 

regulations on manufacturer financial performance, domestic refrigerator-freezer manufacturing 

capacity and employment levels, and product utility and innovation. A primary focus was to 

identify the cumulative burden that industry faces from the overlapping effect of new or recent 

DOE standards and/or other regulatory action affecting the same product or industry. The 

primary sources of information for this evaluation were the 2005 structured interviews with 

manufacturers of refrigerator-freezers (see Appendix D). In order to maintain confidentiality, 

information disclosed by individual manufacturers is not identified with a specific manufacturer. 

Instead, this evaluation reports only aggregated information and does not disclose sensitive 

information or identify company-specific information. 

6.1 IMPACT ON FINANCIAL PERFORMANCE 

The Department received manufacturers' views on what they perceived to be the possible 

impact of potential new standards on their future profitability. As stated by manufacturers, a 

new energy conservation standard has the potential to impact financial performance in several 

different ways. The capital investment needed to upgrade or redesign products and product 

platforms before they have reached the end of their useful life can require conversion costs that 

otherwise would not be expended, resulting in stranded investments. In addition, higher 

efficiency standards can result in higher per-unit costs that may deter some customers from 

buying higher-margin units with more features, decreasing manufacturer profitability. 

Manufacturers stated that the prospect of product redesign as a result of standards penalizes 

established manufacturers and alters the playing field for entry to the market by new competitors 

who do not carry debt burdens from recent investments in new product lines. In their view, this 

can decrease the relative barrier for competitors entering the market, thereby increasing market 

competition, reducing incumbent manufacturer profitability, and decreasing U.S.-based 

production. 

6.1.1 Conversion Costs 

Typically, in the absence of new energy efficiency regulations, a refrigerator-freezer 

production line would have a life cycle of approximately 15 to 20 years. During that period, 

manufacturers would not make major product changes that altered the underlying platforms. 

Thus, a standard that took effect and resulted in a major product platform redesign before the end 

of the platform's life would cannibalize a portion of the earlier capital investments. Based on 

discussions with manufacturers, most have made significant capital investments to meet the DOE 

efficiency standard levels that took effect in 2001; new standards that required platform changes 

could strand assets before the end of their useful life. The 1995 TSD estimated the capital 

conversion costs for the 2001 standard at approximately 725 million dollars. Based on the 

interviews, this figure is low by a factor of two compared to the actual level of investment by the 

refrigerator-freezer industry in the years leading up to and immediately following the 2001 

standards implementation. It must be noted, however, that not all these costs can be attributed to 

6-1 
efficiency standards since the platform changes entailed other product enhancements and cost

reduction initiatives.

The Department asked manufacturers what level of conversion costs they anticipated if

new efficiency standards required a 15 percent reduction in unit energy consumption relative to

the current standards. The level of expected conversion costs varied widely between

manufacturers, depending on such factures as the energy performance of their current products,

whether their current products could achieve the 15 percent reduction via component-level

modifications or needed platform modifications , and the extent to which manufacturers expected

to upgrade their platforms to allow for a future Energy Star level . At a minimum, a typical

manufacturer would need to spend approximately 30 million dollars if no platform redesigns

were needed. More likely, some manufacturers would need some level of platform redesign to

reach a 15 percent improvement, particularly when the investments are taken in context with

future Energy Star levels. The potential for costs on the order of several hundred million dollars

exists if even a single major manufacturer 's product platforms undergo a full redesign . Capital

expenditures would account for roughly 75 to 80 percent of the cost , with product development

expenses accounting for the remaining portion.

When asked to quantify the investments engendered by a 25 percent efficiency

improvement, manufacturers referred to the investment level required by the 2001 standards and

gave estimates totaling well over one billion dollars.

6.1.2 Profitability

Several manufacturers indicated that a new standard level would cause existing pressures

on margins and profitability to increase because only a limited portion of customers are willing

to pay more for energy efficiency . Manufacturers believe that they could not pass on to

customers all of the cost increases required to meet the standard . since historically, the appliance

industry has not able been to recover standard -induced capital:costs in prices . Over time industry

margins have actually decreased as large manufacturers , who need certain volumes to operate

efficiently, are willing to reduce margins to increase volumes. The profit margin impact would

be minimized if manufacturers could produce higher-efficiency products at small incremental.

costs without lowering product utility. However, an increase in unit cost to customers may tend

to decrease the quantity of non-energy features that customers purchase , and manufacturers

indicated that products with such features can often command greater premiums than energyefficient products.

In addition, several manufacturers noted that new standards would facilitate the entry of

foreign competitors in the U.S. market. Without new standards, a new manufacturer would need

to make large capital investments to build production capacity , --investments that existing

manufacturers would not need to make. In the case of new standards , however, most

manufacturers would need to carry out product platform redesigns for some of their products to

meet the new standards. This would neutralize much of the cost advantage from existing

infrastructure that current manufacturers have relative to new, foreign-based manufacturers. In

fact, should they elect to relocate to a lower cost country to be cost competitive with the new

market entrants, conversion costs would tend to be higher for domestic manufacturers due to the

additional costs associated with the closure of existing facilities.

6-2

 EE-PS-2006-001 COMMENT 04.7

#4.7 

efficiency standards since the platform changes entailed other product enhancements and cost 

reduction initiatives. 

The Department asked manufacturers what level of conversion costs they anticipated if 

new efficiency standards required a 15 percent reduction in unit energy consumption relative to 

the current standards. The level of expected conversion costs varied widely between 

manufacturers, depending on such factures as the energy performance of their current products, 

whether their current products could achieve the 15 percent reduction via component-level 

modifications or needed platform modifications, and the extent to which manufactw·ers expected 

to upgrade their platforms to allow for a future Energy Star level. At a minimum, a typical 

manufacturer would need to spend approximately 30 million dollars if no platform redesigns 

were needed. More likely, some manufacturers would need some level of platform redesign to 

reach a 15 percent improvement, particularly when the investments are taken in context with 

future Energy Star levels. The potential for costs on the order of several hundred million dollars 

exists if even a single major manufacturer's product platforms undergo a full redesign. Capital 

expenditures would account for roughly 75 to 80 percent of the cost, with product development 

expenses accounting for the remaining portion. 

When asked to quantify the investments engendered by a 25 percent efficiency 

improvement, manufacturers referred to the investment level required by the 2001 standards and 

gave estimates totaling well over one billion dollars. 

6.1.2 Profitability 

Several manufacturers indicated that a new standard level would cause existing pressures 

on margins and profitability to increase because only a limited portion of customers are willing 

to pay more for energy efficiency. Manufacturers believe that they could not pass on to 

customers all of the cost increases required to meet the standard. since historically, the appliance 

industry has not able been to recover standard-induced capital'costs in prices. Over time industry 

margins have actually decreased as large manufacturers, who need certain volumes to operate 

efficiently, are willing to reduce margins to increase volumes. The profit margin impact would 

be minimized if manufacturers could produce higher-efficiency products at small incremental 

costs without lowering product utility. However, an increase in unit cost to customers may tend 

to decrease the quantity of non-energy features that customers purchase, and manufacturers 

indicated that products with such features can often command greater premiums than energyefficient products. 

In addition, several manufacturers noted that new standards would facilitate the entry of 

foreign competitors in the U.S. market. Without new standards, a new manufacturer would need 

to make large capital investments to build production capacity, --investments that existing 

manufacturers would not need to make. In the case of new standards, however, most 

manufacturers would need to carry out product platform redesigns for some of their products to 

meet the new standards. This would neutralize much of the cost advantage from existing 

infrastructure that current manufacturers have relative to new, foreign-based manufacturers. In 

fact, should they elect to relocate to a lower cost country to be cost competitive with the new 

market entrants, conversion costs would tend to be higher for domestic manufacturers due to the 

additional costs associated with the closure of existing facilities. 

6-2 
#4®7

Finally, multiple manufacturers noted that product quality and reliability could suffer for

a period of time after the new standards are in effect, particularly if a product and its platform

required wholesale redesign to meet the standards. This could increase warranty costs to

manufacturers as these problems are resolved and, if customers find major quality issues, could

damage a manufacturer's reputation and decrease their market share.

6.1.3 Impact on Export Sales

Overall, manufacturers indicated that the export of U.S. refrigerator-freezers to other

countries was a small portion of the market. In most cases, new efficiency standards would not

have a large impact on export sales except in cases where the standards resulted in a product

redesign that would increase product dimensions; product redesign is an important parameter in

some export markets.

6.2 IMPACT ON U.S. PRODUCTION AND JOBS

The impact of new efficiency standards on employment is an important consideration in

the rulemaking process. In order to assess how domestic employment patterns might be affected

by new energy efficiency standards for refrigerator-freezers, the Department posed several

questions to manufacturers related to this topic.

Over the past several years, some refrigerator-freezer manufacturers have moved a

portion of their production out of the U.S., primarily driven by concerns about profitability and

the opportunity for lower labor costs. Mexico is the most common location for both U.S. and

foreign manufacturers to establish new production capacity to serve the U.S. refrigerator-freezer

market, since it offers low labor rates (relative to the U.S.) and proximity. to the U.S. market.

Based on information obtained from the interviews, the Department estimates that approximately

25 percent of all residential refrigerator-freezers sold in the U.S. are manufactured in Mexico and

that this portion is likely to increase within a few years. Manufacturers indicated that they

anticipate new standards would accelerate the trend to manufacture refrigerator-freezers outside

of the country. New standards may alter the rate at which refrigerator-freezer production is

moved to Mexico because if manufacturers need to make large capital investments to produce

redesigned product platforms, they have strong financial. incentives to invest in a location with

lower labor costs.

Multiple manufacturers commented that as more production moves out of the U.S.,

design and R&D functions could also be exported. To date, an initial review of the trade news

publications by the Department could not confirm this trend.

Recently, Asian, and to a lesser extent, European manufactures, have begun to seek a

larger share of the U.S. market. The domestic manufacturers interviewed stated that due to

shipping times and costs, these foreign companies would rely primarily upon new production

capacity in the U.S. and Mexico to meet the needs of the U.S. market. An initial review of the

trade news publications by the Department confirms this trend.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Finally, multiple manufacturers noted that product quality and reliability could suffer for 

a period of time after the new standards are in effect, particularly if a product and its platform 

required wholesale redesign to meet the standards. This could increase warranty costs to 

manufacturers as these problems are resolved and, if customers find major quality issues, could 

damage a manufacturer's reputation and decrease their market share. 

6.1.3 Impact on Export Sales 

Overall, manufacturers indicated that the export of U.S. refrigerator-freezers to other 

countries was a small portion of the market. In most cases, new efficiency standards would not 

have a large impact on export sales except in cases where the standards resulted in a product 

redesign that would increase product dimensions; product redesign is an important parameter in 

some export markets. 

6.2 IMPACT ON U.S. PRODUCTION AND JOBS 

The impact of new efficiency standards on employment is an important consideration in 

the rulemaking process. In order to assess how domestic employment patterns might be affected 

by new energy efficiency standards for refrigerator-freezers, the Department posed several 

questions to manufacturers related to this topic. 

Over the past several years, some refrigerator-freezer manufacturers have moved a 

portion of their production out of the U.S., primarily driven by concerns about profitability and 

the oppOltunity for lower labor costs. Mexico is the most common location for both U.S. and 

foreign manufacturers to establish new production capacity to serve the U.S. refrigerator-freezer 

market, since it offers low labor rates (relative to the U.S.) and proximity to the U.S. market. 

Based on information obtained from the interviews, the Department estimates that approximately 

25 percent of all residential refrigerator-freezers sold in the U.S. are manufactured in Mexico and 

that this portion is likely to increase within a few years. Manufacturers indicated that they 

anticipate new standards would accelerate the trend to manufacture refrigerator-freezers outside 

of the country. New standards may alter the rate at which refrigerator-freezer production is 

moved to Mexico because if manufacturers need to make large capital investments to produce 

redesigned product platforms, they have strong financial incentives to invest in a location with 

lower labor costs. 

Multiple manufacturers commented that as more production moves out of the U.S., 

design and R&D functions could also be exported. To date, an initial review of the trade news 

publications by the Department could not confirm this trend. 

Recently, Asian, and to a lesser extent, European manufactures, have begun to seek a 

larger share of the U.S. market. The domestic manufacturers interviewed stated that due to 

shipping times and costs, these foreign companies would rely primarily upon new production 

capacity in the U.S. and Mexico to meet the needs of the U.S. market. An initial review of the 

trade news publications by the Department confirms this trend. 

6-3 
6.2.1 Industry Consolidation

New standards can cause manufacturers to exit one or more portions of the markets

affected by the standards. Thus, standards also affect the degree of industry consolidation, that

is, the degree to which a limited number of companies dominate a market. At present, four

companies, Electrolux, General Electric, Maytag, and Whirlpool, account for a large majority of

refrigerator-freezer sales. Recently, several organizations, including a major domestic

refrigerator-freezer manufacturer have made offers to purchase Maytag.

Manufacturers indicated that more stringent energy efficiency standards might lead to

greater outsourcing for the production of lower-margin units, such as top-mount refrigeratorfreezers. For example, since the 2001 rulemaking, at least one major manufacturer has stopped

producing top-mount units and elected to source them from another major manufacturer and

market them with their brand. If a company currently producing top-mounts needs to undergo

major product platform redesign to meet a new standard level, they may decide that the large

capital and R&D resource investments would not yield sufficient profits and also may decide to

exit that portion of the market.

One manufacturer also noted that the residential freezer market, a subset of the products

covered by the petition, already has a high degree of consolidation, i.e., two major market

players. Although freezers are not explicitly included in the preliminary analysis, they would be

included in a possible future refrigerator-freezer rulemaking.

Ultimately, the decision by any manufacturer to exit refrigerator-freezer production

would require an assessment of the linkages between that business and other appliances.

Manufacturers and their retail partners generally perceive some value in being a full-line

producer. If a manufacturer perceived significant value in other white goods and if the total.

product line generated acceptable rates of return, it might continue to produce refrigeratorfreezers, even in the face of declining company values due to investment in new refrigeratorfreezer technology. Alternately, as stated above, manufacturers may elect to label products

manufactured by their competitors, effectively concentrating the production of these models.

6.3 IMPACT ON PRODUCT UTILITY AND INNOVATION

New standards can impact purchasers of refrigerator freezers by increasing or decreasing

products' utility, e.g., the interior volume or non-energy features. Manufacturers generally

believed that more stringent energy efficiency standards, particularly the 25 percent

improvement level, would decrease product innovations and, in some cases, result in reduced

product utility.

All manufacturers stated that more stringent standards would require re-design of some

portion of their products. This consumes research and development (R&D) resources, both

human and financial, and directs these assets away from other potential investments that would

normally go toward enhancing the functionality of existing products or developing new products.

Many manufacturers indicated that they could achieve a 15 percent UEC reduction using

component-.level changes to products, which would result in more modest diversion of funds.

Nonetheless, some manufacturers may still redesign product platforms so that they can continue

6-4

 EE-PS-2006-001 COMMENT 04.7

#4.7 

6.2.1 Industry Consolidation 

New standards can cause manufacturers to exit one or more portions of the markets 

affected by the standards. Thus, standards also affect the degree of industry consolidation, that 

is, the degree to which a limited number of companies dominate a market. At present, four 

companies, Electrolux, General Electric, Maytag, and Whirlpool, account for a large majority of 

refrigerator-freezer sales. Recently, several organizations, including a major domestic 

refrigerator-freezer manufacturer have made offers to purchase Maytag. 

Manufacturers indicated that more stringent energy efficiency standards might lead to 

greater outsourcing for the production of lower-margin units, such as top-mount refrigeratorfreezers. For example, since the 2001 rulemaking, at least one major manufacturer has stopped 

producing top-mount units and elected to source them from another major manufacturer and 

market them with their brand. If a company currently producing top-mounts needs to undergo 

major product platform redesign to meet a new standard level, they may decide that the large 

capital and R&D resource investments would not yield sufficient profits and also may decide to 

exit that portion of the market. 

One manufacturer also noted that the residential freezer market, a subset of the products 

covered by the petition, already has a high degree of consolidation, i.e., two major market 

players. Although freezers are not explicitly iJ)cluded in the preliminary analysis, they would be 

included in a possible future refrigerator-freezer rule making. 

Ultimately, the decision by any manufacturer to exit refrigerator-freezer production 

would require an assessment of the linkages between that business and other appliances. 

Manufacturers and their retail partners generally perceive some value in being "a full-line 

producer. If a manufacturer perceived significant value in other white goods and if the total 

product line generated acceptable rates of return, it might continue to produce refrigeratorfreezers, even in the face of declining compnny values due to investment in new refrigeratorfreezer technology. Alternately, as stated above, manufacturers may elect to label products 

manufactured by their competitors, effectively concentrating the production of these models. 

6.3 IMPACT ON PRODUCT UTILITY AND INNOVATION 

New standards can impact purchasers of refrigerator freezers by increasing or decreasing 

products' utility, e.g., the interior volume or non-energy features. Manufacturers generally 

believed that more stringent energy efficiency standards, particularly the 25 percent 

improvement level, would decrease product innovations and, in some cases, result in reduced 

product utility. 

All manufacturers stated that more stringent standards would require re-design of some 

portion of their products. This consumes research and development (R&D) resources, both 

human and financial, and directs these assets away from other potential investments that would 

normally go toward enhancing the functionality of existing products or developing new products. 

Many manufacturers indicated that they could achieve a 15 percent UEC reduction using 

component-level changes to products, which would result in more modest diversion of funds. 

Nonetheless, some manufacturers may still redesign product platforms so that they can continue 

6-4 
#4e7

to produce both standard-level and Energy Star products for marketing reasons. For products

and product platforms that would require a complete re-design, a common theme raised by

manufacturers when discussing a 25 percent UEC decrease, the required R&D investments

would be significantly greater. A platform redesign takes approximately three years and would

have a correspondingly larger impact on product innovation and functionality.

Higher efficiency levels could also decrease product utility. Multiple manufacturers

indicated that to achieve a 25 percent - or, for some products, a 15 percent - lower UEC, they

would use thicker insulation. To a large extent, the maximum dimensions of refrigeratorfreezers are fixed by builders, i.e., a standard space exists for refrigerator freezers in kitchens,

and manufacturers design units to fit within these dimensions to avoid decreasing their potential

market size. This is particularly the case for higher-end counter-depth and built-in products that

are designed to have a depth equal to kitchen counters and, practically speaking, whose depth

cannot exceed 61cm. (24 inches). Consequently, thicker wall insulation would lead to a decrease

in interior dimensions and internal volume. In addition, at least one manufacturer noted that

reduced unit volume would likely reduce the size of interior features in an attempt to minimize

the impact of smaller dimensions of product utility.

More stringent standards could also decrease the range of products available to

customers. When presented with a hypothetical new standard representing a 15 percent UEC

decrease relative to the current DOE standards, manufacturers indicated that they might

discontinue certain products for which it may prove challenging to meet the standard level, such

as built-in and counter-depth units. Alternately, they might outsource production of those units

and continue to sell units under their brand. When manufacturers were asked about a

hypothetical Energy Star UEC 25 percent lower than the current DOE standards, several

manufacturers stated that they might discontinue making some or all Energy Star products.

Manufacturers noted that they often do not necessarily maintain their margins for higher-cost

Energy Star units because they believe that consumers do not think that the additional cost can

justify the relatively modest savings. To date, however, many have produced Energy Star units

because they need them to have their product line marketed via major retail chains, to sell to

government, and to have their products part of utility rebate programs. As discussed previously,

achieving a 25 percent UEC reduction would require extensive product and product platform

redesign for most manufacturers. For certain mainstream products, multiple manufacturers

indicated that the market benefit of having Energy Star would not be sufficient to overcome the

capital costs required to re-design the products and production to meet the new Energy Star

performance level. In other cases, manufacturers are not sure if they could produce costeffective units that achieve the 25 percent reduction relative to the current standard.

6.4 CUMULATIVE BURDEN

When assessing the benefits and burdens of a potential revision of product energy

standard levels, the Department considers several. factors in addition to energy savings potential.

and cost-effectiveness. It also takes into account the regulatory burden that will impact the

manufacturers of the product at or around the time the new standards would come into effect.

Based on its own research and discussions with manufacturers, the Department identified several

existing or pending regulations relevant to residential refrigerators, including:

6-5

 EE-PS-2006-001 COMMENT 04.7

#4.7 

to produce both standard-level and Energy Star products for marketing reasons. For products 

and product platforms that would require a complete re-design, a common theme raised by 

manufacturers when discussing a 25 percent VEC decrease, the required R&D investments 

would be significantly greater. A platform redesign takes approximately three years and would 

have a correspondingly larger impact on product innovation and functionality. 

Higher efficiency levels could also decrease product utility. Multiple manufacturers 

indicated that to achieve a 25 percent - or, for some products, a 15 percent - lower DEC, they 

would use thicker insulation. To a large extent, the maximum dimensions of refrigeratorfreezers are fixed by builders, i.e., a standard space exists for refrigerator freezers in kitchens, 

and manufacturers design units to fit within these dimensions to avoid decreasing their potential 

market size. This is particularly the case for higher-end counter-depth and built-in products that 

are designed to have a depth equal to kitchen counters and, practically speaking, whose depth 

cannot exceed 61cm (24 inches). Consequently, thicker wall insulation would lead to a decrease 

in interior dimensions and internal volume. In addition, at least one manufacturer noted that 

reduced unit volume would likely reduce the size of interior features in an attempt to minimize 

the impact of smaller dimensions of product utility. 

More stringent standards could also decrease the range of products available to 

customers. When presented with a hypothetical new standard representing a 15 percent VEC 

decrease relative to the current DOE standards, manufacturers indicated that they might 

discontinue certain products for which it may prove challenging to meet the standard level, such 

as built-in and counter-depth units. Alternately, they might outsource production of those units 

and continue to sell units under their brand. When manufacturers were asked about a 

hypothetical Energy Star VEC 25 percent lower than the current DOE standards, several 

manufacturers stated that they might discontinue making some or all Energy Star products. 

Manufacturers noted that they often do not necessarily maintain their margins for higher-cost 

Energy Star units because they believe that consumers do not think that the additional cost can 

justify the relatively modest savings. To date, however, many have produced Energy Star units 

because they need them to have their product line marketed via major retail chains, to sell to 

government, and to have their products part of utility rebate programs. As discussed previously, 

achieving a 25 percent VEC reduction would require extensive product and product platform 

redesign for most manufacturers. For certain mainstream products, multiple manufacturers 

indicated that the market benefit of having Energy Star would not be sufficient to overcome the 

capital costs required to re-design the products and production to meet the new Energy Star 

performance level. In other cases, manufacturers are not sure if they could produce costeffective units that achieve the 25 percent reduction relative to the current standard. 

6.4 CUMULATIVE BURDEN 

When assessing the benefits and burdens of a potential revision of product energy 

standard levels, the Department considers several factors in addition to energy savings potential 

and cost-effectiveness. It also takes into account the regulatory burden that will impact the 

manufacturers of the product at or around the time the new standards would come into effect. 

Based on its own research and discussions with manufacturers, the Depmtment identified several 

existing or pending regulations relevant to residential refrigerators, including: 

6-5 
• Existing energy efficiency standard for refrigerator-freezers

• Insulation blowing agent phase out

• Energy efficiency standards for other products made by the same manufacturers

• State energy efficiency standards

• International energy efficiency standards

• Waste disposal and recycling requirements

Complying with these regulations requires that corporations invest both human and

capital resources. The following subsections discuss in greater detail regulations impacting the

refrigerator-freezer industry.

6.4.1 Existing Energy Efficiency Standard for Refrigerator-Freezers

In 1987, the National. Appliance Energy Conservation Act (NAECA) was signed into law

establishing minimum energy efficiency standards for residential refrigerators, refrigeratorfreezers, and freezers. NAECA specified for twelve product classes the maximum allowable

energy in kilowatt-hours per year for products manufactured on or after January 1, 1990.

Subsequent to the NAECA requirements, revised minimum efficiency standards for residential

refrigeration products became effective first in 1993 then again in 2001. The minimum

efficiency standards of 1993 eliminated 99 percent of the models previously manufactured and

increased efficiency by 25 to 30 percent relative to the initial NAECA requirements. The

minimum efficiency standards that became effective on July 1, 2001 increased the efficiency of

the most popular product class, top mount refrigerator-freezers with auto-defrost, by

approximately 30 percent relative to the 1993 standards.

Table 6-1 presents values from the 1995 TSD for estimates of the tooling, equipment,

buildings, and research and development investments needed to convert from producing

equipment that performed at the TSD Baseline level to units whose UEC meets either the 2001

standard level or a level 15 percent lower than the 2001 standard for a typical large

manufacturer.' The values are very low compared to the actual expenditures that manufacturers

reported during the interviews.

Table 6-1. Estimated Investments and Expenses to Reach Various Efficiency Levels, from

1993 Standard Levels

Top-Mount

Side-Mount

$154

$20

$83/$254

$100

$83 million path used

vacuum panels

Note: The TSD Baseline energy use is .16 percent below the 1993 Standard for the side-mount

Source: DOE 1995 TSD.

6-6

 EE-PS-2006-001 COMMENT 04.7

#4.7 

• Existing energy efficiency standard for refhgerator-freezers 

• Insulation blowing agent phase out 

• Energy efficiency standards for other products made by the same manufacturers 

.. State energy efficiency standards 

• International energy efficiency standards 

• Waste disposal and recycling requirements 

Complying with these regulations requires that corporations invest both human and 

capital resources. The following subsections discuss in greater detail regulations impacting the 

refrigerator-freezer industry. 

6.4.1 Existing Energy Efficiency Standard for Refrigerator-Freezers 

In 1987, the National Appliance Energy Conservation Act (NAECA) was signed into law 

establishing minimum energy efficiency standards for residential refrigerators, refrigeratorfreezers, and freezers. NAECA specified for twelve product classes the maximum allowable 

energy in kilowatt-hours per year for products manufactured on or after January 1, 1990. 

Subsequent to the NAECA requirements, revised minimum efficiency standards for residential 

refrigeration products became effective tirst in 1993 then again in 2001 .. The minimum 

efficiency standards of 1993 eliminated 99 percent of the models previously manufactured and 

increased efficiency by 25 to 30 percent relative to the initial NAECA requirements. The 

minimum efficiency standards that became effective on July 1, 2001 increased the efficiency of 

the most popular product class, top mount refrigerator-freezers with auto-defrost, by 

approximately 30 percent relative to the 1993 standards. 

Table 6-1 presents values from the 1995 TSD for estimates of the tooling, equipment, 

buildings, and research and development investments needed to convert from producing 

equipment that performed at the TSD Baseline level to units whose UEC meets either the 2001 

standard level or a level 15 percent lower than the 2001 standard for a typical large 

manufacturer. 1 The values are very low compared to the actual expenditures that manufacturers 

reported during the interviews. 

Table 6-1. Estimated Investments and Expenses to Reach Various Efficiency Levels, from 

1993 Standard Levels 

I~~ • ridel ~ f.1? iBaseli'l.~01'·1 Nfl leliq~to.Below 21 .:;; 1992$, mn !P ~ ~; .' .: 1992$, ous) . . Comments 0~~. ~~I • •• :. 

~ 

Top-Mount $154 $83/$254 $ 83 million path used 

vacuum panels 

Side-Mount $20 $100 

Note: The TSD Baselme energy use 1S 16 percent below the 1993 Standard for the side-mount 

Source: DOE 1995 TSD. 

6-6 
#4®7

6.4.2 Insulation Blowing Agent Phase Out

Production of refrigerator foam insulation uses a blowing agent. The Montreal Protocol

required that the U.S. begin to phase out the blowing agent HCFC-141b beginning in January

2003. This impacted refrigerator-freezers produced in the U.S. and caused manufacturers to

switch to other blowing agents with a much lower ozone depletion potential, such as HFC-245fa.

Several manufacturers indicated that they have switched to HFC-245fa. Only one company,

however, holds a license to produce HFC-245fa for the U.S. market. This represents a

significant challenge for manufacturers to control product costs and avoid future production

disruptions. Alternative blowing agents such as HFC-134a or cyclopentane have other

drawbacks, such as lower thermal resistance and/or increased implementation costs due to

flammability. On the other hand, use of HCFC-141b for refrigerators imported into the U.S. may

continue in countries with a later phase-out date, such as Mexico.

6.4.3 Energy Conservation Standards for Other Products Made by the Manufacturers of

Refrigerator-Freezers

Most manufacturers. of refrigerator-freezers produce other white goods that have been

subject to NAECA, including dishwashers, clothes washers, and clothes dryers. Notably, new

efficiency standards will come into effect for clothes washers in 2007. The capital conversion

costs to increase clothes washer efficiency from the level established in the rule published in

May, 1991 (taking effect in May, 1994) to that taking effect in 2004 were estimated to be $631

million for the entire industry.2

6.4.4 State Energy Conservation Standards

In addition to Federal regulations, certain states have proposed conservation standards for

similar types of products. For example, California's Title 20 regulates wine chiller energy

consumption.3

6.4.5 The Energy Policy Act of 2005

On August 8th, 2005, President George W. Bush signed the Energy Policy Act of 2005

(EPACT 2005) into law.4 EPACT 2005 contains several energy efficiency provisions, including

energy efficiency standards for a host of consumer products and commercial equipment,

directives for the Secretary of Energy to set standards for other products and equipment, and a

package of financial incentives for efficient products, buildings, and vehicles. The manufacturer

incentives for residential refrigerators and the standards for commercial. refrigerators, freezers

and refrigerator-freezers, in particular, will affect the same manufacturers impacted by the new

DOE standard considered in this document.' The following reviews the standards and financial

incentives as provided in EPACT 2005 and signed into law, and highlights relevant products in

more detail. Table 6-2 provides a general overview of those products and standards affected by

EPACT 2005.

e According to the Act, `refrigerators' refers to residential model automatic defrost refrigerator-freezers with an

internal volume of at least 16.5 cubic feet.

6-7

 EE-PS-2006-001 COMMENT 04.7

#4.7 

6.4.2 Insulation Blowing Agent Phase Out 

Production of refrigerator foam insulation uses a blowing agent. The Montreal Protocol 

required that the U.S. begin to phase out the blowing agent HCFC-141b beginning in January 

2003. This impacted refrigerator-freezers produced in the U.S. and caused manufacturers to 

switch to other blowing agents with a much lower ozone depletion potential, such as HFC-245fa. 

Several manufacturers indicated that they have switched to HFC-245fa. Only one company, 

however, holds a license to produce HFC-245fa for the U.S. market. This represents a 

significant challenge for manufacturers to control product costs and avoid future production 

disruptions. Alternative blowing agents such as HFC-134a or cyclopentane have other 

drawbacks, such as lower thermal resistance and/or increased implementation costs due to 

flammability. On the other hand, use ofHCFC-141b for refrigerators imported into the U.S. may 

continue In countries with a later phase-out date, such as Mexico. 

6.4.3 Energy Conservation Standards for Other Products Made by the Manufacturers of 

Refrigerator-Freezers 

Most manufacturers of refrigerator-freezers produce other white goods that have been 

subject to NAECA, including dishwashers, clothes washers, and clothes dryers. Notably, neW 

efficiency standards will come into effect for clothes washers in 2007. The capital conversion 

costs to increase clothes washer efficiency from the level established in the rule published in 

May, 1991 (tiling effect in May, 1994) to that taking effect in 2004 were estimated to be $631 

million for the entire industry.2 

6.4.4 State Energy Conservation Standards 

In addition to Federal regulations, certain states have proposed conservation standards for 

similar types of products. For example, California's Title 20 regulates wine chiller energy . 3 consumptIon. 

6.4.5 The Energy Policy Act of 2005 

On August 8th, 2005, President George W. Bush signed the Energy Policy Act of 2005 

(EPACT 2005) into law.4 EPACT 2005 contains several energy efficiency provisions, including 

energy efficiency standards for a host of consumer products and commercial equipment, 

directives for the Secretary of Energy to set standards for other products and equipment, and a 

package of financial incentives for efficient products, buildings, and vehicles. The manufacturer 

incentives for residential refrigerators and the standards for commercial refrigerators, freezers 

and refrigerator-freezers, in particular, will affect the same manufacturers impacted by the new 

DOE standard considered in this document. e The following reviews the standards and financial 

incentives as provided in EPACT 2005 and signed into law, and highlights relevant products in 

more detail. Table 6-2 provides a general overview of those products and standards affected by 

EPACT2005. 

e According 10 the Act, 'refrigerators' refers to residential model automatic defrost refrigerator-freezers with an 

internal volume of at least 16.5 cubic feet. 

6-7 
Table 6-2.Product and Equipment Measures Overview

Tax Incentives

Residential Refrigerators (refrigerator-freezers)

Residential Clothes Washers

Residential Dishwashers

New and Existing Homes

Commercial Buildings

Heating and Cooling Equipment

Stationary Fuel Cells

Transportation Tax Incentives

Standards

Commercial Refrigerators, Freezers, and Refrigerator-Freezers

Automatic Commercial Ice Makers

Dehumidifiers

Commercial Clothes Washers

Commercial Packaged Heating and Air Conditioning Equipment

Ceiling Fans and Ceiling Fan Light Kits

Torchiere Lamps

Fluorescent Lamp Ballasts

Compact-Fluorescent Lamps

Low-Voltage, Dry-Type Distribution Transformers

Exit Signs

Traffic Signal Modules and Pedestrian Signals

Pre-Rinse Spray Valves

Mercury Vapor Lamp Ballasts (Phaseout)

Unit Heaters

Rulemaking Directives

Commercial Refrigerators, Freezers, and Refrigerator-Freezers

Refrigerated Bottle or Canned Vending Machines

Battery Chargers and External Power Supplies

Ceiling Fans and Ceiling Fan Light Kits

EPACT 2005 provides tax credits to manufacturers for the production of energy-efficient

residential refrigerators, clothes washers, and dishwashers. The total credit for residential

refrigerators is equal to an applicable credit amount multiplied by the eligible production. Table

6-3 highlights the applicable credit amount along with credit limitations. According to EPACT

2005, eligible production for refrigerators equals the number of appliances produced in a year

over 110% of the average number of appliances produced during the preceding three-year period.

Table 6-3. Refrigerator-Freezer Tax Incentives

15% $75 Up to Equals the number of appliances produced in a

$20,000,000 ^ year over 110% of the average number of

20% $125 Up to appliances produced during the preceding three25% $175 $75,000,000* year period.

Notes: According to EPACT 2005, `refrigerators' refers to residential model automatic defrost refrigerator-freezers

with an internal volume of at least 16.5 cubic feet. Applicable equipment includes refrigerator-freezers

manufactured in 2006 with savings between 15-20% (15%), and those manufactured in 2006 or 2007 with savings

between 20-25% (20%) or at least 25%. Percentage savings refer to 2001 energy conservation standards.

* Reduced by the amount of credit taken in previous years

6-8

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table 6-2.Product and Equipment Measures Overview 

(iene~al; - jSure Descdptions an(j~oirer~ ioaucts'~$m .!IiZ~ ~'" %;y qwpt»ent ''0 

) 2~ "' 

Tax Incentives 

Residential Refrigerators (ref'rigerator-freezers) 

Residential Clothes Washers 

Residential Dishwashers 

New and Existing Homes 

Commercial Buildings 

Heating and Cooling Equipment 

Stationary Fuel Cells 

Transportation Tax Incentives 

Standards 

Commercial Refrigerators, Freezers, and Refrigerator-Freezers 

Automatic Commercial Ice Makers 

Dehumidifiers 

Commercial Clothes Washers 

Commercial Packaged Heating and Air Conditioning Equipment 

Ceiling Fans and Ceiling Fan Light Kits 

Torchiere Lamps 

Fluorescent Lamp Ballasts 

Compact 'Fluorescent Lamps 

Low-Voltage, Dry-Type Distribution Transformers 

Exit Signs 

Traffic Signal Modules and Pedestrian Signals 

Pre-Rinse Spray Valves 

Mercury Vapor Lamp Ballasts (Phaseout) 

Unit Heaters 

Rulemaking Directives 

Commercial Refrigerators, Freezers, and Refrigerator-Freezers 

Refrigerated Bottle or Canned Vending Machines 

Battery Chargers and External Power Supplies 

Ceiling Fans and Ceiling Fan Light Kits 

EP ACT 2005 provides tax credits to manufacturers for the production of energy-efficient 

residential refrigerators, clothes washers, and dishwashers. The total credit for residential 

rr~frigerators is equal to an applicable credit amount multiplied by the eligible production. Table 

6-3 highlights the applicable credit amount along with credit limitations. According to EPACT 

2005, eligible production for refrigerators equals the number of appliances produced in a year 

over 110% of the average number of appbances produced during the preceding three-year period. 

Table 6-3. Refrigerator-Freezer Tax Incentives 

~:~,~!n~",~ #" nlicaH1 •• LimitationS;' "liT 'b"' ~o~.n ?z~1/02 \§ iUf j!" 0, /J$ 

:l~ ~~~ /i'01j$: 

JId 

~at:@!ll;;t rf~ JjI ~ ~~q'$'~~<4~+';S"~!" ;;j»5~~ ft% yft z~f%;/'00;?s;iU;,Ij:g ~e I ,,)llOnD zwfo: "1t~~~0"t,*~~'"),,(",,", "S0~~ #st ~ '" ?V;;;;'Y}0 ;"t2G1"2!kJ! 0~ ;\; ;;; 

>0""" \/0&"", 

15% $75 Up to Equals the number of appliances produced in a 

$20,000,000 year over 110% ofthe average number of 

20% $125 Up to appliances produced during the preceding three25% $175 $75,000,000* year period. 

Notes: Accordmg to EPACT 2005, 'refngerators' refers to resIdentIal model automatIc defi'ost refrIgerator-freezers 

with an internal volume of at least 16.5 cubic feet. Applicable equipment includes refrigerator-freezers 

manufactured in 2006 with savings between 15-20% (15%), ancl those manufactured in 2006 or 2007 with savings 

between 20-25% (20%) or at least 25%. Percentage savings refer to 2001 energy conservation standards. 

* Reduced by the amount of credit taken in previous years 

6-8 
#4,7

Some of the same manufacturers regulated by standards for residential refrigerators,

freezers, and refrigerator-freezers are also covered under other product standards in EPACT

2005. For example, EPACT 2005 sets standards for products and equipment including

dehumidifiers, commercial clothes washers, commercial refrigerators, freezers, and refrigeratorfreezers, commercial heating and cooling, and vending machines.

The increased stringency of standards for regulated equipment varies. However, new

standards for equipment mentioned above generally coincide with recent or existing Energy Star

standards. For example, the new energy consumption standards for solid door refrigerators,

freezers, and refrigerator-freezers, as specified in EPACT 2005, are roughly the same as current

energy star criteria. The new standards for dehumidifiers generally raises the energy factor to

existing Energy Star criteria, if not slightly below in some casesf and the new energy factor

standard for commercial clothes washers matches the pre-2004 Energy Star standard 5,6,7

Many provisions of the recently passed Energy Policy Act of 2005 may have some

impact on manufacturers; including State consumer rebates for Energy Star products, as well as

the federal manufacturer tax incentives and product standards noted above. However, this report

does not attempt to project the impact of these new provisions.

6.4.6 -International Energy Efficiency Regulations

Most refrigerator-freezer manufacturers sell a small portion of their total production to

countries besides the U.S. In those cases, the products must meet the standards for each country.

Based on manufacturer interviews, companies may design some units to meet more stringent

standards than the U.S., e.g., for the European Union, to minimize the number of product

variations. In general, however, most other countries have less stringent standard levels than the

U.S.

6.4.7 Waste Disposal and Recycling Requirements

Several manufacturers noted that their products exported to Europe and the Canadian

province of Ontario will fall under recent laws mandating that manufacturers of electronic and

electrical equipment, which includes residential. refrigerators and freezers, take back such

equipment from consumers in a manner that is at least cash-neutral to the consumer. In January

2003, the European Union approved the "Waste from Electronic and Electrical Equipment"

(WEEE) directive with the goal of "promoting waste recovery with a view to reducing the

quantity of waste for disposal and saving natural resources, in particular by reuse, recycling,

composting, and recovering energy from waste". Refrigerators (and other white goods) fall under

this regulation. It requires that manufacturers selling a range of products, including refrigerators

and freezers, in the EU dispose of, recycle, or recover goods that they manufacture after August

13, 2005. Toward this end, it requires that "users of electrical and electronic equipment from

private household should have the possibility of returning WEEE at least free of charge ... each

producer should be responsible for financing the management of the waste from his own.

Note: The new standards categorize capacity groupings into five bins as opposed to the three originally used by

Energy Star so categories overlap.

6-9

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Some of the same manufacturers regulated by standards for residential refrigerators, 

freezers, and refrigerator-freezers are also covered under other product standards in EPACT 

2005. For example, EPACT 2005 sets standards for products and equipment including 

dehumidifiers, commercial clothes washers, commercial refrigerators, freezers, and refrigeratorfreezers, commercial heating and cooling, and vending machines. 

The increased stringency of standards for regulated equipment varies. However, new 

standards for equipment mentioned above generally coincide with recent or existing Energy Star 

standards. For example, the new energy consumption standards for solid door refrigerators, 

freezers, and refrigerator-freezers, as specified in EPACT 2005, are roughly the same as current 

energy star criteria. The new standards for dehumidifiers generally raises the energy factor to 

existing Energy Star criteria, if not slightly below in some casesf and the new energy factor 

standard for commercial clothes washers matches the pre-2004 Energy Star standard.5

,6,7 

Many provisions of the recently passed Energy Policy Act of 2005 may have some 

impact on manufacturers; including State consumer rebates for Energy Star products, as well as 

the federal manufacturer tax incentives and product standards noted above. However, this report 

does not attempt to project the impact of these new provisions. 

6.4.6 . International Energy 'Efficiency Regulations 

Most refrigerator-freezer manufacturers sell a small portion of therr total production to 

countries besides the U.S. In those cases, the products must meet the standards for each country. 

Based o~ manufacturer interviews, companies may design some units to meet more stringent 

standards than the U.S., e.g., for the European Union, to minimize the number of product 

variations. In general, however, most other countries have less stringent standard levels than the 

U.S. 

6.4.7 'Vaste Disposal and Recycling Requirements 

Several manufacturers noted that their products exported to Europe and the Canadian 

province of Ontario will fall under recent laws mandating that manufacturers of electronic and 

electrical equipment, which includes residential refrigerators and freezers, take back such 

equipment from consumers in a manner that is at least cash-neutral to the consumer. In January 

2003, the European Union approved the "Waste from Electronic and Electrical Equipment" 

(WEEE) directive with the goal of "promoting waste recovery with a view to reducing the 

quantity of waste for disposal and saving natural resources, in particular by reuse, recycling, 

compo sting, and recovering energy from waste". Refrigerators (and other white goods) fall under 

this regulation. It requires that manufacturers selling a range of products, including refrigerators 

and freezers, in the EU dispose of, recycle, or recover goods that they manufacture after August 

13,2005. Toward this end, it requires that "users of electrical and electronic equipment from 

private household should have the possibility of returning WEEE at least free of charge ... each 

producer should be responsible for financing the management of the waste from his own 

fNote: The new standards categorize capacity groupings into five bins as opposed to the three originally used by 

Energy Star so categories overlap. 

6-9 
products." Producers also have explicit minimum recovery rates that they must achieve by

December 31, 2006, i.e., in the case of residential refrigerators, refrigerator-freezers, and

freezers; it equals 80 percent of refrigerators by weight. It also requires the producers to recover

portions of the waste from products manufactured prior to August 13, 2005, based on their past

market share.8

Under the Ontario Waste Diversion Act of 2002, the government of the Canadian

province of Ontario has recently requested the development of a waste diversion program for

WEEE materials, including refrigerators.9'10 Although the process for WEEE recovery and

required recovery rates have yet to be established, it also requires manufacturers to take

responsibility for diversion of WEEE.6,u The request commissions a study for completion in

mid-2005 that will explicitly include recommendations on the adequacy of a year-long timeline

for developing the program. This implies that a program could be finalized in 2006, with a

launch possible in 2007.6'12

At present, the U.S. does not have waste disposal or recycling requirements for

refrigerator-freezers. Some manufacturers indicated that they believe similar requirements could

be extended to all of Canada and, in the future, potentially to the U.S. This could cause

manufacturers to alter product re-designs to facilitate product recycling. At this point in time,

the Department is not familiar with any similar legislation in the United States, but

acknowledges that the Ontario legislation could have an impact on refrigerator-freezer design

because of the tight integration of the U.S. and Canadian white goods markets.

6.4.8 'Restriction of Hazardous Substances

In early 2003, the EU published the "The Restriction of Hazardous Substances in

Electrical and Electronic Equipment (ROHS)" Directive. This directive pertains to white goods

covered by the WEEE regulation (discussed above) and explicitly states that "Member States

shall ensure that, from 1 July 2006, new electrical and electronic equipment put on the market

does not contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls

(PBB) or polybrominated diphenyl ethers (PBDE)." Multiple manufacturers noted that this

would impact refrigerator-freezer units that they export to Europe. In addition, the directive

states that the European Commission and the Council of the EU can agree to prohibit "other

hazardous substances" "as soon as scientific evidence is available" in the future, i.e., other

materials may be prohibited from refrigerators sold to the EU in the future.13 A limited number

of exemptions exist, many for mercury (in lamps) and lead9, as well as for defense products and

certain types of medical equipment.14 The European Committee of household appliance

manufacturers, CECED, presents the following "critical examples of applications [that] are

banned"10:

• Lead in solder for electrical and electronic parts

• Lead in PVC and other types of plastics

• Chromium VI on screws and other metallic parts, and

• Platings and coatings using the materials (each layer is considered as a separate part).

 EE-PS-2006-001 COMMENT 04.7

#4.7 

products." Producers also have explicit minimum recovery rates that they must achieve by 

December 31,2006, i.e., in the case of residential refrigerators, refrigerator-freezers, and 

freezers; it equals 80 percent of refrigerators by weight. It also requires the producers to recover 

portions of the waste from products manufactured prior to August 13, 2005, based on their past 

market share. 8 

Under the Ontario Waste Diversion Act of 2002, the government of the Canadian 

province of Ontario has recently requested the development of a waste diversion program for 

WEEE materials, including refrigerators.9

,lO Although the process for WEEE recovery and 

required recovery rates have yet to be established, it also requires manufacturers to take 

responsibility for diversion ofWEEE.6

,1l The request commissions a study for completion in 

mid-200S that will explicitly include recommendations on the adequacy of a year-long timeline 

for developing the program. This implies that a program could be finalized in 2006, with a 

launch possible in 2007.6

,12 

At present, the U.S. does not have waste disposal or recycling requirements for 

refrigerator-freezers. Some manufacturers indicated that they believe similar requirements could 

be extended to all of Canada and, in the future, potentially to the U.S. This could cause 

manufacturers to alter product re-designs to facilitate product recycling. At this point in time, 

the Dep.artment is not familiar with any similar legislation in the United States, but 

.. acknowledges that the Ontario legislation could have an impact on refrigerator-freezer design 

because of the tight integration of the U.S. and Canadian white goods markets. 

6.4.8 . Restriction of Hazardous Substances 

In early 2003, the EU published the ''The Restriction of Hazardous Substances in 

Electrical and Electronic Equipment (ROHS)" Directive. This directive pertains to white goods 

covered by the WEEE regulation (discussed above) and explicitly states that "Member States 

shall ensure that, from 1 July 2006, new electrical and electronic equipment put on the market 

does not contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls 

(PBB) or polybrominated diphenyl ethers (PBDE)." Multiple manufacturers noted that this 

would impact refrigerator-freezer units that they export to Europe. In addition, the directive 

states that the European Commission and the Council of the EU can agree to prohibit "other 

hazardous substances" "as soon as scientific evidence is available" in the future, i.e., other 

materials may be prohibited from refrigerators sold to the EU in the future.13 A limited number 

of exemptions exist, many for mercury (in lamps) and lead9

, as well as for defense products and 

certain types of medical equipment. 14 The European Committee of household appliance 

manufacturers, CECED, presents the following "critical examples of applications [that] are 

banned" 1 0

: 

• Lead in solder for electrical and electronic parts 

• Lead in PVC and other types of plastics 

• Chromium VI on screws and other metallic parts, and 

• Platings and coatings using the materials (each layer is considered as a separate patt). 

6-10 
#4®7

6.4.9 Microwave Oven Radio Frequency Emission Regulations

Microwave ovens have recently been subject to FCC requirements, which limit radio

frequency emissions onto the power lines serving these units'. Previously microwave ovens

were subject only to regulations governing externally leaked emissions to assure safety of nearby

people. Microwave ovens have been regulated since October 1971 by the FDA for limitation of

radiated emissions (the limit is 5 milliwatts of microwave radiation per square centimeter at

approximately 2 inches from the oven surface). The recent FCC regulation addresses possible

interference of microwave ovens with power line carrier and RF devices resulting from

emissions of RF frequencies onto electric power lines. The regulation adopts the requirements of

the international standard IEC/CISPR Publication 11, which sets limits for conducted emissions

in the frequency ranges 9kHz to 30MHz. These standards took effect July 10, 2005, for all

microwave ovens sold in the U.S.

6.4.10 Arc-Fault Protection for Window Air-Conditioning Unit Power Cords

The 2002 National Electric Code (which is referenced by many local codes) added

requirement 440.65 which states that window air-conditioners with single-phase cord and plug

electrical connection must incorporate either arc fault protection or leakage current detection in

the power supply cord within 12" of the attachment plug. This requirement took effect August 1,

2004. These changes aim to reduce the risk of fire associated, for example, with the fatigue of

conductors and insulation leading to development of high-impedance arcs against which

conventional circuit breakers provide no protection.

6.4.11 Flammable Vapor Resistance Standard for Water Heaters

A voluntary standard has been adopted by water heater manufacturers to improve

resistance of residential water heaters to igniting flammable vapors from external sources such as

spilled gasoline. The standard mandates design changes, which make the water heaters resistant

to igniting flammable vapors outside of the water heater. Initial adoption of the standard for

conventional (i.e. atmospherically-fired, natural draft vented) 30, 40, and 50-gallon residential

gas water heaters occurred July 1, 2003, and it was extended to power vented and larger models

on July 1, 2005.

6.4.12 Water Factor Standards for Clothes Washers

Water factor standards for clothes washers have been pursued by California and other

states. In California, water factor standards for commercial clothes washers took effect in 2004.

California standards for residential clothes washers call for a maximum water factor (gallons of

water used per cubic feet of washer capacity) of 8.5 to take effect on January 1, 2007, and a

water factor of 6.0 by January 1, 2010. California must get a waiver from DOE, since regulation

of residential appliance efficiency is under the jurisdiction of the federal government. A request

for a waiver has been submitted to DOE. A number of states have also adopted or are

considering the same commercial clothes washer standards, which were enacted in California.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

6.4.9 Microwave Oven Radio Frequency Emission Regulations 

Microwave ovens have recently been subject to FCC requirements, which limit radio 

frequency emissions onto the power lines serving these unitsl

. Previously microwave ovens 

were subject only to regulations governing externally leaked emissions to assure safety of nearby 

people. Microwave ovens have been regulated since October 1971 by the FDA for limitation of 

radiated emissions (the limit is 5 milliwatts of microwave radiation per square centimeter at 

approximately 2 inches from the oven surface). The recent FCC regulation addresses possible 

interference of microwave ovens with power line carrier and RF devices resulting from 

emissions of RF frequencies onto electric power lines. The regulation adopts the requirements of 

the international standard IEC/CISPR Publication 11, which sets limits for conducted emissions 

in the frequency ranges 9kHz to 30MHz. These standards took effect July 10, 2005, for all 

microwave ovens sold in the U.S. 

6.4.10 Arc-Fault Protection for Window Air-Conditioning Unit Power Cords 

The 2002 National Electric Code (which is referenced by many local codes) added 

requirement 440.65 which states that window air-conditioners with single-phase cord and plug 

electrical connection must incorporate either arc fault protection or leakage current detection in 

the power supply cord within 12" ofthe attachment plug. This requirement took effect August 1, 

2004. These changes aim to reduce the risk of fire associated, for example, with the fatigue of 

conductors and insulation leading to development of high-impedance arcs against which 

conventional circuit breakers provide no protection. 

6.4.11 Flammable Vapor Resistance Standard for Water Heaters 

A voluntary s~andard has been adopted by water heater manufacturers to improve 

resistance of residential water heaters to igniting flammable vapors from external sources such as 

spilled gasoline. The standard mandates design changes, which make the water heaters resistant 

to igniting flammable vapors outside of the water heater. Initial adoption of the standard for 

conventional (i.e. atmospherically-fired, natural draft vented) 30, 40, and 50-gallon residential 

gas water heaters occurred July 1,2003, and it was extended to power vented and larger models 

on July 1, 2005. 

6.4.12 Water Factor Standards for Clothes Washers 

Water factor standards for clothes washers have been pursued by California and other 

states. In California, water factor standards for commercial clothes washers took effect in 2004. 

California standards for residential clothes washers call for a maximum water factor (gallons of 

water used per cubic feet of washer capacity) of 8.5 to take effect on January 1,2007, and a 

water factor of 6.0 by January 1, 2010. California must get a waiver from DOE, since regulation 

of residential appliance efficiency is under the jurisdiction of the federal government. A request 

for a waiver has been submitted to DOE. A number of states have also adopted or are 

considering the same commercial clothes washer standards, which were enacted in California. 

6-11 
6.4.13 Indoor Air Quality Regulations for Ranges and Ovens

In 2002 Assembly Bill 1173 (Keeley, 2002; California Health and Safety Code Section

39930) was enacted. This bill required the California Air Resources Board to prepare a report on

the growing issue of Indoor Air Quality. The report was completed in July 20052. One of the

sources of indoor pollutants discussed in the report is unvented cooking appliances fired with

natural gas or propane, such as residential ranges or ovens. Such appliances were identified as

sources of carbon monoxide, nitrogen oxides, particles, soot, and polycyclic aromatic

hydrocarbons. The authors put these appliances on a list of "High Priority Source Categories for

Mitigation" with such sources as ozone-generating air cleaners, tobacco smoke, and radon. One

of the key mitigation strategies mentioned for such appliances is to require venting, an action,

which would require significant design modifications for such appliances. Since the report has

just recently been submitted to the legislature, it is not clear at this stage whether any such

regulations are likely to be considered for passage into law.

6.4.14 Impact of Cumulative Burden on Small Manufacturers

The manufacturer interviews indicated that smaller refrigerator manufacturers typically

have smaller corporate research and development staffs than larger manufacturers. Although

small manufacturers often have a more limited product range than major manufacturers, the

effort to address some aspects of regulations are relatively fixed and. do not scale directly with

the number of products or product platforms produced. Consequently, the cumulative burden of

regulations will tend to place more of a burden on smaller manufacturers because of their more

limited resources.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

6.4.13 Indoor Air Quality Regulations for Ranges and Ovens 

In 2002 Assembly Bill 1173 (Keeley, 2002; California Health and Safety Code Section 

39930) was enacted. This bill required the California Air Resources Board to prepare a repOlt on 

the growing issue ofIndoor Air Quality. The report was completed in July 20052

• One of the 

sources of indoor pollutants discussed in the report is unvented cooking appliances fIred with 

natural gas or propane, such as residential ranges or ovens. Such appliances were identified as 

sources of carbon monoxide, nitrogen oxides, pmticles, soot, and polycyclic aromatic 

hydrocarbons. The authors put these appliances on a list of "High Priority Source Categories for 

Mitigation" with such sources as ozone-generating air cleaners, tobacco smoke, and radon. One 

of the key mitigation strategies mentioned for such appliances is to require venting, an action, 

which would require significant design modifications for such appliances. Since the report has 

just recently been submitted to the legislature, it is not clear at this stage whether any such 

regulations are likely to be considered for passage into law. 

6.4.14 Impact of Cumulative Burden on Small Manufacturers 

The manufacturer interviews indicated that smaller refrigerator manufacturers typically 

have smaller corporate research and development statIs than larger manufacturers. Although 

small manufacturers often have a more limited product range than major manufacturers, the 

effort to address some aspt<cts of regulations are relatively fixed' anddo not scale directly with 

the number of products or product platforms produced. Consequently, the cumulative burden of 

regulations will tend to place more of a burden on smaller manufacturers because of their more 

limited resources. 

6-12 
114 TT4 .7

REFERENCES

1

2

3

4

5

6

7

8

9

1 0

11

U.S. Department of Energy , Technical Support Document: Energy Efficiency Standards fo

Consumer Products: Refrigerators, Refrigerator-Freezers, & Freezers, July 1995.

Washington, DC. Report No . DOE/EE-0064.

U.S. Department of Energy , Office of Energy Efficiency and Renewable Energy, Final Rule

Technical Support Document (TSD): Energy Efficiency Standards for Consumer Products:

Clothes Washers, December 2000. Washington, DC. Available at:

http://www . eere.energy. gov/buildings/appliance standards/residenti.ai/cl.wash 0900 r .html.

California Energy Commission, Title 20 Appliance Efficiency Regulations, April 2005.

Sacramento, CA. Report No. CEC 400-2005-012. Available at:

http://www.energy.ca. ov/2005publ.ications/CEC-400-2005-012/CEC-400-2005-012.PDF.

U.S. Congress. Energy Policy Act of 2005 (H.R. 6). Conference report passed by House on

July 28`h, 2005 and passed by Senate on July 29`h, 2005. Signed into law August 8`h, 2005.

Energy Star Program. "Clothes Washers Key Product Criteria." Available online at

http://www.energystar.gov/i.nclex.cf]x1?c=clot:.heswash..pr_crit clothes washers

. "Energy Star Program Requirements for Commercial Solid Door Refrigerators and

Freezers Eligibility Criteria"

http://www.energvstar.gov/ia/partners/12rod.uct s pets/eligibil.ity/commer refrig elig.ppdf

"Energy Star Program Requirements for Dehumidifiers: Partner Commitments."

Available online at

http://www.energystar.gov/ia/partners/product specs/program regs/dehumi.d prog retpdf

European Union, "Directive 2002/96/96/EC of the European Parliament and of the Council

of 27 January 2003 on Waste Electrical and Electronic Equipment (WEEE)," Official

Journal ofthe European Union, pp. L37/24-L37/38. Available at: http ://europa. eu.int/eurlex/pri/en/oi/dat/2003/1 037/1 03720030213en002400 38. pdf.

Waste Diversion Ontario, Waste Diversion Act, 2002 (Bill 90), Ascended to on June27.

Available at: http://www.elaws.gov.on.ea/DBLaws/Source/Statutes/English/2002/S02006 e.htm.

Ontario, Letter by L. Dombrowsky, Minister of the Environment of Ontario, Canada, to B.

Balkisson, Chair, Waste Diversion Ontario, Dated 20 December, 2004. Available at:

htt ://www.ene.gov.on.ca/envi.sion/lancVWI)A/electronics/letter1220()4.pdf.

Waste Diversion Ontario, "Waste Electrical and Electronic Equipment," Ontario Regulation

393/04 - Made Under the Waste Diversion Act, 2002, Made and Filed 14 December, 2004,

Ontario Gazette, January 1, 2005. Available at:

htt.://www.elaws.gov.on.ca[DBLaws/Source/Regis/Enalish/2004/R04393 e.htm.

6-13

 EE-PS-2006-001 COMMENT 04.7

#4.7 

REFERENCES 

2 

3 

4 

5 

6 

7 

8 

9 

u.s. Department of Energy, Technical Support Document: Energy Efficiency Standardsfor 

Consumer Products: Refrigerators, Refrigerator-Freezers, & Freezers, July 1995. 

Washington, DC. Report No. DOEIEE-0064. 

u.s. Department of Energy, Office of Energy Efficiency and Renewable Energy, Final Rule 

Technical Support Document (TSD): Energy Efficiency Standardsfor Consumer Products: 

Clothes Washers, December 2000. Washington, DC. Available at: 

http://www.eere.energv .goY/buildings/appliance standards/residcntiallclwash 0900 r .html. 

California Energy Commission, Title 20 Appliance Efficiency Regulations, April 2005. 

Sacramento, CA. Report No. CEC 400-2005-012. Available at: 

http://www.energy.ca.govI2005publications/CEC-400-2005-012/CEC-400-2005-012.PDF. 

U.S. Congress. Energy Policy Act of 2005 (H.R. 6). Conference report passed by House on 

July 28th, 2005 and passed by Senate on July 29th, 2005. Signed into law August 8th, 2005. 

Energy Star Program. "Clothes Washers Key Product Criteria." Available online at 

http://www.energystar.govlindex.cfm?c=c1otheswash.pr crit clothes washers 

___ . "Energy Star Program Requirements for Commercial Solid Door Refrigerators and 

Freezers Eligibility Criteria" 

http://www.energ:vstar. gov/ialpartners/product specs/eIigibiIitvlcommer refhg elig.pdf 

___ . "Energy Star Program Requirements for Dehumidifiers: Partner Commitments." 

Available online at 

http://www.enen!ystar.gov/ialpartners/product specs/program reqs/dehumid prog reg.pdf 

European Union, "Directive 2002/96/96IEC of the European Parliament and of the Council 

of 27 January 2003 on Waste Electrical and Electronic Equipment (WEEE)," Official 

Journal of the European Union, pp. L37l24-L37/38. Available at: http://europa.eu.inUcurlexlpri/en/oi/dat/200311 03711 03720030213en00240038.pdf. 

Waste Diversion Ontario, Waste Diversion Act, 2002 (Bill 90), Ascended to on June27. 

Available at: http://www.claws.go\..on.ca/DBLaws/Source/Statutes/Englishl2002/S02006c.htm. 

10 Ontario, Letter by L. Dombrowsky, Minister of the Environment of Ontario, Canada, to B. 

Balkisson, Chair, Waste Diversion Ontario, Dated 20 December, 2004. Available at: 

http://www.cnc.goY.on.ca/enYision/laneVWDlVelectronics/letterl22004.pdf. 

I J Waste Diversion Ontario, "Waste Electrical and Electronic Equipment," Ontario Regulation 

393/04 - Made Under the Waste Diversion Act, 2002, Made and Filed 14 December, 2004, 

Ontario Gazette, January 1, 2005. Available at: 

http://www.elaws.gov.on.cafDBLaws/Source/Rezs/English/2004/R04393e.htm. 

6-13 
12 McGuire, J.M., "Canada Including Appliances in WEEE Program," Appliance Design, April

1, 2005 . Available at:

http://www.ammagazine.com/CDA/AiticleInformation/features/BNP Features ItemIO,2606.14772

2,00.htlnl.

13

14

European Union, "Directive 2002/95/EC of the European Parliament and of the Council of

27 January 2003 on the Restriction of the Use of Certain Hazardous Substances in Electrical.

and Electronic Equipment ", Official Journal of the European Union, L 37, February 13,

2003, pp. 19 - 23. Available at:

http://europa.eu. int/eurlex/prileii/oj/dat/2003/] 037/1 03720030213en00i90023.pdt'.

CEDED, "RoHS Guide," Frequently Asked Questions about Directive 2002/95/EC, PP 05-

03, February 9, 2005. Available at:

http://www. aharn. org./l ibrary/.tiles/PP %200503 %20R.oHS %2 0Gui.de. p d1.'.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

12 McGuire, J.M., "Canada Including Appliances in WEEE Program," Appliance Design, April 

1,2005. Available at: 

http://www.ammagazine.comlCDNArticlelnformationlfeatures/BNP Features ItemlO,2606.14772 

2,OO.html. 

13 European Union, "Directive 2002/95IEC of the European Parliament and of the Council of 

27 January 2003 on the Restriction of the Use of Certain Hazardous Substances in Electrical 

and Electronic Equipment", Official Journal of the European Union, L 37, February 13, 

2003, pp. 19 - 23. Available at: 

http://europa.eu.intieurlex!priJen!oj/datI2003/1 0371l 03720030213en00190023.pdf. 

14 CEDED, "RoHS Guide," Frequently Asked Questions about Directive 2002/951EC, PP 05-

03, February 9,2005. Available at: 

http://www.aham.org/librarylfiles/PP% 200503%20RoHS %20Guide.pdf. 

6-14 
4®7

APPENDIX A. AHAM DATA SUBMITTAL REQUEST

Excerpt from AHAM's request to manufacturers for cost data, described above in the

AHAM Data Submittal and Consolidation Section, is reproduced below.

Please return the attached survey, indicating the average incremental production cost to

take your basic models in the categories shown from the current DOE minimum efficiency level.

to 15% better. In other words, if it costs $200 to produce a basic model at the current baseline

minimum efficiency level, and it costs $230 to make it 15% more efficient, the incremental cost

difference is $30. If you have more than one basic model at the minimum efficiency level in

each of the size categories indicated, average the incremental costs and show that number.

We want to submit an aggregate shipment weighted average, so please indicate your

approximate annual shipment volumes for each category. Also, in order to provide the

contractors with some sensitivity around the average numbers, for those categories where you

have more than one basic model, please indicate the minimum and maximum incremental costs.

A description of the costs to include are noted under the tables on the survey form attached.

Shipments

For the Top Freezer and Side-By-Side tables, in the last column please indicate the total

shipment numbers for all models (those that are already Energy Star compliant and those that are

not). The cost should be the average, minimum or maximum cost to raise the units from current

DOE compliant models to the current DOE Energy Star level. For the tables of the New Energy

Star levels for Top Freezer and Side-By-Side, please indicate in the last column an approximate

number of new Energy Star units that might be shipped, given an approximate Energy Star level

as described below.

Another Element

We would also ask that you consider another element in the cost of refrigerator efficiency

improvements. If the minimum efficiency level is raised to the current Energy Star level, models

will meet the existing Energy Star level and this will result in DOE Energy Star office seeking an

increase in the Energy Star qualification level. We believe that the cost of increasing some

portion of your models to the NEW Energy Star level should be accounted for in this

efficiency/cost data collection. Obviously, it is difficult to envision what this new Energy Star

level might be. For purposes of this data collection, we would suggest that the companies

estimate the cost of having some number of units to an Energy Star level equivalent to the energy

25% less than today's DOE Minimum Efficiency level across all the categories. The shipment

numbers in the far right column would then be the approximate number of units that will then be

sold as the new Energy Star units. We recognize this is a hypothetical estimate. We have

included two new tables in the enclosed form. We need this information separately in order to

discuss this scenario with DOE and the contractor.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

APPENDIX A. AHAM DATA SUBMITTAL REQUEST 

Excerpt from AHAM's request to manufacturers for cost data, described above inthe 

AHAM Data Submittal and Consolidation Section, is reproduced below. 

Please return the attached survey, indicating the average incremental production cost to 

take your basic models in the categories shown from the current DOE minimum efficiency level 

to 15% better. In other words, if it costs $200 to produce a basic model at the current baseline 

minimum efficiency level, and it costs $230 to make it 15% more efficient, the incremental cost 

difference is $30. If you have more than one basic model at the minimum efficiencYlevel in 

each of the size categories indicated, average the incremental costs and show that number. 

We want to submit an aggregate shipment weighted average, so please indicate your 

approximate annual shipment volumes for each category. Also, in order to provide the 

contractors with some sensitivity around the average numbers, for those categories where you 

have more than one basic model, please indicate the minimum and maximum incremental costs. 

A description of the costs to include are noted under the tables on the survey form attached. 

Shipments 

For the Top Freezer and Side-By-Side tables, in the last column please indicate the total 

shipment numbers for all models (those that are already Energy Star compliant and those that are 

not). The cost should be the average, minimum or maximum cost to raise the units from current 

DOE compliant models to the current DOE Energy Star level. For the tables of the New Energy 

Star levels for Top Freezer and Side-By-Side, please indicate in the last column an approximate 

number of new Energy StaJ.' units that might be shipped, given an approximate Energy Star level 

as described below. 

Another Element 

We would also ask that you consider another element in the cost of refrigerator efficiency 

improvements. lfthe minimum efficiency level is raised to the current Energy Star level, models 

will meet the existing Energy Star level and this will result in DOE Energy Star office seeking an 

increase in the Energy Star qualification level. We believe that the cost of increasing some 

portion of your models to the NEW Energy Star level should be accounted for in this 

efficiency/cost data collection. Obviously, it is difficult to envision what this new Energy Star 

level might be. For purposes of this data collection, we would suggest that the companies 

estimate the cost of having some number of units to an Energy Star level equivalent to the energy 

25% less than today's DOE Minimum Efficiency level across all the categories. The shipment 

numbers in the faJ.· right column would then be the approximate number of units that will then be 

sold as the new Energy Star units. We recognize this is a hypothetical estimate. We have 

included two new tables in the enclosed form. We need this information separately in order to 

discuss this scenario with DOE and the contractor. 

A-I 
CONFIDENTIAL Refrigerator-Freezer Data Collection

for Cost/Efficiency Information for DOE Petition

Top Freezers - Auto Defrost

Size2, Average Minimum4 Maximums Approximate

Ft.3 Incremental Cost per Incremental Cost per Incremental Cost per Total

product to Achieve 15% product to Achieve 15% product to Achieve 15% Annual

Better Eff. than Min. Better Eff. than Min. Better Eff. than Min. Shipments

DOE Std DOE Std DOE Std

14-17

18-20

21-22

23-25

Top Freezers - Auto Defrost-Increase for New Energy Star Level

(Approximately 25% less energy than today 's DOE Standard)

Size2, Average3' Minimum4 Maximums Approx.

Ft.3 Incremental Cost per Incremental Cost per Incremental Cost per Annual

product to increase to product to increase to product to increase to Shipments of

New Energy Star level new Energy Star Level new Energy Star Level New Energy

Star units

14-17

18-20

21-22

23-25

Side By Sides - Auto Defrost with Through-the-Door Ice & Water

Size2, Averages"3 Minimum4 Maximums Approximate

Ft.3 Incremental Cost per Incremental Cost per Incremental Cost per Total

product to Achieve 15% product to Achieve 15% product to Achieve 15% Annual

Better Eff. than Min. Better Eff. than Min. Better Eff. than Min. Shipments

DOE Std DOE Std DOE Std

18-20

21 - 23

24-26

27-30

Side By Sides - Auto Defrost with Through -the-Door Ice & Water-Energy Star

Size2, Average3" Minimum4 Maximums Approximate

Ft.3 Incremental Cost per Incremental Cost per Incremental Cost per Annual Shipments

product to increase to product to increase to product to increase to of New Energy Star

New Energy Star level new Energy Star Level new Energy Star Level Units

18-20

21-

24-26

27-30

(Approximately 25% less energy than today's DOE Minimum)

A-2

 EE-PS-2006-001 COMMENT 04.7

Size2, 

Ft.3 

14 -17 

18 -20 

21-22 

23 -25 

Size2, 

Ft.3 

14 -17 

18 -20 

21-22 

23 -25 

Size2, 

Ft.3 

18 -20 

21-23 

24-26 

27 -30 

#4.7 

CONFIDENTIAL Refrigerator-Freezer Data Collection 

for CostlEfficiency Information for DOE Petition 

Top Freezers - Auto Defrost 

Average Minimum4 MaximumS Approximate 

Incremental Cost per Incremental Cost per Incremental Cost per Total 

product to Achieve 15% product to Achieve 15% product to Achieve 15% Annual 

Better Eff. than Min. Better Eff. than Min. Better Eff. than Min. Shipments 

DOEStd DOE Std DOE Std 

Top Freezers - Auto Defrost-Increase for New Energy Star Level 

(Approximately 25% less energy than today's DOE Standard) 

Average3~ Minimum4 MaximumS Approx. 

Incremental Cost per Incremental Cost per Incremental Cost per Annual 

product to increase to product to increase to product to increase to Shipments of 

New Energy Star level new Energy Star Level new Energy Star Level New Energy 

Star units 

Side By Sides - Auto Defrost with Through-the-Door Ice & Water 

Average1'3 Minimum4 MaximumS Approximate 

Incremental Cost per Incremental Cost per Incremental Cost per Total 

product to Achieve 15% product to Achieve 15% product to Achieve 15% Annual 

Better Eff. than Min. Better Eff. than Min. Better Eff. than Min. Shipments 

DOEStd DOEStd DOE Std 

Side By Sides - Auto Defrost with Through-the-Door Ice & Water-Energy Star 

(A _pproXlma t e y I 25o/t 0 I ess energy th an t d o ay 'DOE s M' lmmum . ) 

Size2, Average3'7 Minimum4 MaximumS Approximate 

Ft.3 Incremental Cost per Incremental Cost per Incremental Cost per Annual Shipments 

product to increase to product to increase to product to increase to of New Energy Star 

New Energy Star level new Energy Star Level new Energy Star Level Units 

18 -20 

21-23 

24-26 

27 -30 

A-2 
#4,7

1. Incremental cost data (in U.S. $) includes the materials, burdened labor, and amortization

of capitol expense needed to take basic models from the current minimum DOE baseline

efficiency standard to a 15% improvement in energy efficiency.

2. For sizes between the ranges shown above, just include units in the nearest size category.

3. In the "Average" column, average the incremental cost for all products in that size range.

4. For the "Minimum" column, show the incremental cost for the basic model with the

lowest associated cost.

5. For the "Maximum" column, show the incremental cost for the basic model with the

highest associated cost.

6. There are a variety of different ways manufacturers may choose to achieve the higher

efficiency level. (e.g., more insulation, better gaskets, improved control and defrost

schemes, more efficient compressors and fan motors, etc.). All manufacturers will not

use the same design options for all models. Therefore, instead of listing design options

(some of which may include proprietary information) we are choosing to just show the

incremental cost associated with whatever means a manufacturer may choose, without

disclosing each manufacturers' specific approach.

7. The incremental cost to achieve the New Energy Star levels would be the cost to raise

whatever current units or platforms to the new (hypothetical) Energy Star level

approximately 25% improvement in energy over today's DOE Minimum Efficiency

level.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

1. Incremental cost data (in U.S. $) includes the materials, burdened labor, and amortization 

of capitol expense needed to take basic models from the current minimum DOE baseline 

efficiency standard to a 15% improvement in energy efficiency. 

2. For sizes between the ranges shown above, just include units in the nearest size category. 

3. In the "Average" column, average the incremental cost for all products in that size range. 

4. For the "Minimum" column, show the incremental cost for the basic model with the 

lowest associated cost. 

5. For the "Maximum" column, show the incremental cost for the basic model with the 

highest associated cost. 

6. There are a variety of different ways manufacturers may choose to achieve the higher 

efficiency level (e.g., more insulation, better gaskets, improved control and defrost 

schemes, more efficient compressors and fan motors, etc.). All manufacturers will not 

use the same design options for all models. Therefore, instead of listing design options 

(some of which may include proprietary information) we are choosing to just show the 

incremental cost associated with whatever means a manufacturer may choose, without 

disclosing each manufacturers' specific approach. 

7. The incremental cost to achieve the New Energy Star levels would be the cost to raise 

whatever current units or platforms to the new (hypothetical) Energy Star level 

approximately 25% improvement in energy over today's DOE Minimum Efficiency 

level. 

A-3 
APPENDIX B. CONSUMER RETAIL PRICE DATASET: SUMMARY DATA AND

REGRESSION ANALYSIS DETAILS

Table B-1 provides the variable statistics for the top-mount and side-mount refrigeratorfreezers from The NPD Group dataset that were used for establishing the baseline consumer

retail price and the incremental retail price of current Energy Star products.

Table B-l. Variable Statistics for Basic Side-Mount and Top-Mount Refrigerator-Freezers

_Refrigerator Size and Efficiency Variables

1. Price 896.6 65.0 1397.2 552.5 53.0 4327.0

2. Capacity (cu. ft.) 24.1 18.0 27.0 18.3 8.5 26.0

3. Electricity use (kWh/yr) NA NA NA NA NA NA

4. Energy Star 0.5 0.0 1.0 0.4 0.0 1.0

5. Sales 1866.5 1 58460 2602 1 104649

Refrigerator Attributes

1. Through door Ice and Water 0.9 0.0 1.0 0.1 0.0 1.0

2. Icemaker Standard 0.0 0.0 1.0 0.2 0.0 1.0

3. Water Filter 0.9 0.0 1.0 0.2 0.0 1.0

4. Contoured Door 0.1 0.0 1.0 0.1 0.0 1.0

5. Meat and Crisper Drawers 0.6 0.0 1.0 0.3 0.0 1.0

6. Glass Shelves 0.2 0.0 1..0 0.3 0.0 1.0

7. Wire Shelves 0.0 0.0 1.0 0.2 0.0 1.0

8. Spill proof Shelves 0.7 0.0 1.0 0.4 0.0 1.0

Refrigerator Brands

1. Amana 0.1 0.0 1.0 0.0 0.0 1.0

2. Avanti pro NA NA NA 0.0 0.0 1.0

3. Danby NA NA NA 0.0 0.0 1.0

4. Frigidaire 0.2 0.0 1.0 0.2 0.0 1.0

5. General Electric 0.3 0.0 1.0 0.3 0.0 1.0

6. Haier 0.0 0.0 1.0 0.0 0.0 1.0

7. Hot Point 0.0 0.0 1.0 0.0 0.0 1.0

8. Kitchen aid 0.0 0.0 1.0 0.1 0.0 1.0

9. LG Electronics 0.1. 0.0 1.0 0.0 0.0 1.0

10. Magic Chef NA NA NA 0.0 0.0 1.0

1.1. Maytag 0.0 0.0 1.0 0.1 0.0 1..0

12. Roper 0.0 0.0 1.0 0.0 0.0 1.0

13. Viking 0.3 0.0 1.0 NA NA NA

14. Summit NA NA NA 0.0 0.0 1.0

15. Whirlpool 0.3 0.0 1.0 0.2 0.0 1.0

Table B-2 shows the details of the "long" regression analysis performed to establish the

retail price increment of current Energy Star products for top-mount refrigerator-freezers. There

are two sets of results; one set summarizes the details for the non-sales-weighted regression

while the other set summarizes the details for the sales-weighted regression.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

APPENDIX B. CONSUMER RETAIL PRICE DATASET: SUMMARY DATA AND 

REGRESSION ANALYSIS DETAILS 

Table B-1 provides the variable statistics for the top-mount and side-mount refrigeratorfreezers from The NPD Group dataset that were used for establishing the baseline consumer 

retail price and the incremental retail price of current Energy Star products. 

Table B-1. Variable Statistics for Basic Side-Mount and Top-Mount Refrigerator-Freezers 

1. Price 65.0 1397.2 552.5 53.0 4327.0 

2. Capacity (cu. ft.) 18.0 27.0 18.3 8.5 26.0 

3. Electricity use (kWh/yr) NA NA NA NA NA 

4. Energy Star 0.0 1.0 0.4 0.0 1.0 

5. Sales 1 58460 2602 1 104649 

0.9 0.0 1.0 0.1 1.0 

0.0 0.0 1.0 0.2 0.0 1.0 

3. Water Filter 0.9 0.0 1.0 0.2 0.0 1.0 

4. Contoured Door 0.1 0.0 1.0 0.1 0.0 1.0 

5. Meat and Crisper Drawers 0.6 0.0 1.0 0.3 0.0 1.0 

6. Glass Shelves 0.2 0.0 1.0 0.3 0.0 1.0 

7. Wire Shelves 0.0 0.0 1.0 0.2 0.0 1.0 

8. 0.7 0.0 1.0 0.4 0.0 1.0 

1. Amana 0.1 0.0 1.0 0.0 0.0 1.0 

2. A vanti pro NA NA NA 0.0 0.0 1.0 

3. Danby NA NA NA 0.0 0.0 1.0 

4. Frigidaire 0.2 0.0 1.0 0.2 0.0 1.0 

5. General Electric 0.3 0.0 1.0 0.3 0.0 1.0 

6. Haier 0.0 0.0 1.0 0.0 0.0 1.0 

7. Hot Point 0.0 0.0 1.0 0.0 0.0 1.0 

8. Kitchen aid 0.0 0.0 1.0 0.] 0.0 1.0 

9. LG Electronics 0.1 0.0 1.0 0.0 0.0 1.0 

10. Magic Chef NA NA NA 0.0 0.0 1.0 

11. Maytag 0.0 0.0 1.0 0.1 0.0 1.0 

12. Roper 0.0 0.0 1.0 0.0 0.0 1.0 

13. Viking 0.3 0.0 1.0 NA NA NA 

14. Summit NA NA NA 0.0 0.0 1.0 

15. 0.3 0.0 1.0 0.2 0.0 1.0 

Table B-2 shows the details of the "long" regression analysis performed to establish the 

retail price increment of current Energy Star products for top-mount refrigerator-freezers. There 

are two sets of results; one set summarizes the details for the non-sales-weighted regression 

while the other set summarizes the details for the sales-weighted regression. 

B-1 
Table B-2. Details of the "Long" Regression Analysis to determine the Energy Star Retail

Price Increment: Top-Mount Refrigerator-Freezers

Top-Freezer Price Regression

Refrigerator Price, depandent variable

regression

coefficients

statistical

significance

Sales-weighted Top-Freezer Price Regression

Refrigerator Price, depandent variable

regression

coefficients

statistical

significance

(sprice/Aenergy t(362) (Aprice/Aenergy Z

Focus Variables star) Focus Variables star)

Intercept 29 4 7.44 Intercept 223.7 385.1

Energy Star 44,39 4.63 Energy Star 323 350.8

Total volume '97 3.48 Total volume I113 878.1

Attribute Variables Attribute Variables

No through door Ice and Water 2.35 No through door Ice and Water 321.0 214.7

Ice only 32.03 0.98 Ice only 70.6 115.9

No Icemaker > 1407 -3.92 No Icenraker 51.2 -493.1

Ice maker optional 41,72 -2.97 Icennkeroptional -36.4 -412.1

No Water filter 5.56 0.34 No Water filter -26.5 -116.3

Not contoured door -1.44 -0.09 Not contoured door -53.1 -331.0

Crisper drawer only -1.82 -0.17 Crisper drawer only _18 -39.9

Wire shelves 29.60 -2.39 Wire shelves .49.5 -487.3

Glass shelves -3.13 -0.27 Glass shelves -12.1 -150.4

Plastic shelves -82.21 -1.79 Plastic shelves 38.5 -36.8

Brand Variables Brand Variables

Amana 9.97 0.28 Annna 7?5 132.1

Avantipro -35.41 -1.08 Avantipro -9.3 -31.6

Danby -44.61 -1.38 Danby 24.7 90.8

Prigidaire -20.84 -1.50 Frigidaire 39.1 -373.2

GenElec :_'8,89 2.24 GcnFiec -39 -2,5.9

Haler -1 .33 -0.05 Haier -28.9 -150.3

Hotpoint .65.50 -3.44 Hotpoint -29.3 -74.8

Kitchenniaid 55.2 2.48 Kitchenmaid 65.0 43.7

LGEec 45.51 1.43 LGnec 951 223.3

MagicChef -51.19 -1.75 MagicChef -65.0 -169.4

Maytag -13,10 2.38 Maytag 383 184.1

Roper -29.16 -1.55 Roper -40.44 -380.7

Highlighted coefficients are si gnificant at the 95% level. Highlighted coefficients are significant at the 95% level.

Table B-3 shows the details of the "long" regression analysis performed to establish the

retail price increment of current Energy Star products for side-mount refrigerator-freezers. There

are two sets of results; one set summarizes the details for the non-sales-weighted regression

while the other set summarizes the details for the sales-weighted regression.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table B-2. Details of the "Long" Regression Analysis to determine the Energy Star Retail 

Price Increment: Top-Mount Refrigerator-Freezers 

Top-lireezer Price Regression Sales-weighted Top-I'reezer !,rice Regression 

Refrigerator Price, depandent variable Refrigerator Price, depandent variable 

regression statistical regressicn statistical 

coefficients significance coefficients significance 

(ll.price/ll.energy t(362) (ll.price/ll.energy z 

Focus Variables star) Focus Variables star) 

hnercept 295A7 7.44 Intercept :2"' -,,">.1 -, 385.1 

Energy Star 44.39 4.63 Energy Star 39.3 350.8 

Total volu!re S.Y'! 3.48 Total volume U.S 878.1 

Attribute Variables Attribute Variables 

No through door Ice and Wate, 5~}ff:r: 2.35 No through door lee and Water 121.(} 214.7 

lee only 32.03 0.98 lee only 70.6 115.9 

No !cemaker -6\.07 -3.92 No leemaker -51.2 -493.1 

Ice maker optional .. ·W!] -2.97 Icennker optional -36.4 -412.1 

No Water filter 5.56 0.34 No Water filter -26.5 -116.3 

Not contoured door -1.44 -0.09 Not contoured door ··5:'.1 -331.0 

Cris per drawer only -1.82 -0.17 Crisper drawer only -3.8 -39.9 

Wire shelves ·,),9.60 -2.39 Wire shelves ·49.5 -487.3 

Glass shelves -3.13 -0.27 Glass shelves -12.1 -150.4 

Plastic shelves -82.21 -1.79 Plastic shelves -38.5 -36.8 

Brand Variables Bralld Variables 

Amana 9.97 0.28 Amana 735 132.1 

Avantipro -35.41 -1.08 Avantipro -9.3 -31.6 

Danby -44.61 -1.38 Danby 24.7 90.8 

Frigidaire -20.84 -1.50 Frigidaire -39.1 -373.2 

GenBec 28.88 2.24 C",nBec ··3.9 -25.9 

Haier -1.33 -0.05 Haier -28.9 -150.3 

Hotpoint .. 65.50 -3.44 Hotpoint ":~t).3 -74.8 

Kitchenmaid 65.7"::. 2.48 Kitchenmaid 65.0 43.7 

LGElec 45.51 1.43 LGElec 9Ll 223.3 

MagicOJef -51.19 -1.75 MagicChef -(,').0 -169.4 

May tag -13.10 2.38 May tag 3K3 184.1 

Roper -29.16 -1.55 Roper .. 40.4 -380.7 

Hi<>hlighted coefficients are significant at the 95% level. Highlighted coetticients are significant at the 95% level. 

Table B-3 shows the details of the "long" regression analysis performed to establish the 

retail price increment of current Energy Star products for side-mount refrigerator-freezers. There 

are two sets of results; one set summarizes the details for the non-sales-weighted regression 

while the other set summarizes the details for the sales-weighted regression. 

B-2 
Table B-3. Details of the "Long" Regression Analysis to determine the Energy Star Retail

Price Increment: Side-Mount Refrigerator-Freezers

Side by Side Price Regression

Refrigerator Price, depandent variable

regression

coefficients

statistical

significance

Sales-Weighted Side by Side Price Regression

Refrigerator Price, dependent variable

regression statistical

coefficients significance

(Apiice/Aenergy t(283) (iprice/t,energy z

Focus Variables star) Focus Variables star)

Intercept 415.2 1.8 Intercept 1'21.78 30.86

Energy star (d 4 2.4 Energy Star 819'7 340.21

Capacity 6.3 0.8 Capacity 25,6` 287.17

Attribute Variables Attribute Variables

No through door Ice andWatei 113.4 1.8 No through doorlce and Water 992-; 47.16

No Icemaker -58.1 -0.7 No lcemaker 22.14 -7.94

No water filter 7.8 0.2 No Water filter 25. 0 34.66

Not contoured doors 6 2.l Flat, uncontoured Door 38.51 -36.61

Crisper drawers 7.8 0.3 Crisper drawer (no neat drawer) 9. 9. 5 -284.10

Wire shelves -63.4 -0.3 Wire shelves - 16, 2.2 -21.87

Glass shelves 68.5 0.4 Glass shelves -53,75 -12.70

Spillproof shelves 105.1 0.6 Plastic shelves 1'3,x33 4.63

Brand Variables Brand Variables

Roper -118.0 -0.9 Arnana- "96 46.81

Amana -48.6 -0.5 Frigidaire t 7.28 26.27

Frigidaire 10.6 0.1 Genllec 19.3.12 71.09

GeneralFlectic 0.1 0.0 Hotpoint -6.93 -1.73

Hotpoint -184.6 -1.6 Kitchennnrid 1,4.9,1 25.04

Kitchenmaid 53.4 0.5 Maytag 1'-9.26 68.89

Maytag 22.1 0.2 Roper 3.37 1.30

Whirlpool 5.9 0.1 Whirlpool 12:.21 47.91

Highlighted coefficients are sig nificant at the 95% level. .Highlighted coefficients are significant at the 95% level.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table B-3. Details of the "Long" Regression Analysis to determine the Energy Star Retail 

Price Increment: Side-Mount Refrigerator-Freezers 

Side by Side Price Regression Sales-Weighted Side by Side Price Regression 

Refrigerator Price, depandent variable Refrigerator Price, depandent variable 

regression statistical regression statistical 

coefficients si Jnifif.'ance coefficients significance 

(t.pricelt.energy t(283) (t.pricelt.energy z 

Focus Variables star) Focus Variables star) 

Intercept 415.2 1.8 Intercept J23.7g 30.86 

Fnergy star (,0 ... 2.4 Energy Star ~1.m 340.21 

Capacity 6.3 0.8 Capacity 25.65 287.17 

Attrib ute Variables Attribute Variables 

No through door Ice and Wate, 113.4 1.8 No through door Ice and Water S9,'27 47.16 

No Icemaker -58.1 -0.7 No lcemaker p22.14 -7.94 

No water filter 7.8 0.2 No Water filter 26,10 34.66 

Not contoured doors :;8.0 2.1 ,",lat, uneon toured Door ':58.55 -36.61 

Gis per drawers 7.8 0.3 Crisper dmwer (no n~at dmwer) ··7R.95 -284.10 

Wire shelves -63.4 -0.3 Wire shelves ··115.2), -21.87 

G1a~s shelves 68.5 0.4 Glass shelves ··5:.;,75 -12.70 

Spillproof shelves 105.1 0.6 Plastic shelves H()3 4.63 

Brand Variables Brand Variables 

Roper -118.0 -0.9 Amma' 46.81 

Amana -48.6 -0.5 Frigidaire 67.2~ 26.27 

Frigidaire 10.6 0.1 GenEiec ](;:U2 71.09 

Geneml Eiechlc 0.1 0.0 Hotpoint -6.93 -1.73 

Hotpoint -184.6 -1.6 Kitchenmlid I!;l"'l 25.04 

Kitchenmaid 53.4 0.5 May tag 17926 68.89 

May tag 22.1 0.2 Roper 3.37 1.30 

Whirlpool 5.9 0.1 Whirlpool 122.2. 47.91 

Highlighted coefficients are significant at the 95% level. Highlighted coefficients are significant at the 95% level. 

B-3 
#4®7

APPENDIX C. DETAILS OF FOCUSED MATCHED PAIRS

Table C-I and Table C-2 show the details of the focused matched pair analysis for topmount and side-mount refrigerator -freezers, respectively. Details include the annual energy

consumption, retail prices, and model features.

 EE-PS-2006-001 COMMENT 04.7

#4.7 

APPENDIX C. DETAILS OF FOCUSED MATCHED PAIRS 

Table C-l and Table C-2 show the details of the focused matched pair analysis for topmount and side-mount refrigerator-freezers, respectively. Details include the annual energy 

consumption, retail prices, and model features. 

C-l 
#4,7

Table C-1. Top-Mount Refrigerator-Freezer Matched Pairs

`•^ ^' d•1 ! i•^^•• _ +-,. s ^`'vsr.'"d'YP • t (DIY • = ^It

tll. 9d ^

^

_

.r..

Baseline GE GE GTS22KBPWW 21.7 15 . 4 6.4 25.7 448.7 529 81

Energy Star GE GE GTH22KBRWW 21.7 15.4 6.4 25.7 448.7 448

Baseline Frigidaire Frigidaire FRT21C5A 20.5 15. 3 5.3 23.8 433. 2 509 77

Energy Star Frigidaire Frigidaire FRT21HC5D 20.6 15. 3 5.3 23.8 433.2 432

Baseline Whirlpool Whirlpool ETIMHKXM 21.0 14. 6 6.4 25 . 0 443. 1 514 71

Energy Star Whirlpool Whirlpool ET1MTEXM 21.0 14. 5 6.5 25.1 443.6 443

Baseline Kenmore 74192 20. 6 15.4 5.3 23.9 434. 1 509 77

Energy Star Kenmore 74172 20.6 15 . 4 5.3 23. 9 434.1 432

Baseline Whirlpool Whirlpool ET8MHKXM 18.2 13.2 5.0 21 . 4 412.4 484 72

Energy Star Whirlpool Whirlpool ET8FTEXM 18.2 13. 2 5.0 21 . 4 412.4 412

Baseline GE GE GTS18KBPWW 17.9 12.9 5.0 21.0 409. 4 482 72

Energy Star GE GE GTH18BRWW 17.9 12.9 5.0 21.0 409.4 410

Baseline GE GE GTR16BBSRWW 15.7 11 . 6 4.1 18.3 386. 6 455.0 69

Energy Star GE GE GTH16BBSLWW 15.7 11.4 4. 1 18.1 385.6 386.0

Baseline GE GE GTR15BBR 14.9 10. 8 4.1 17. 5 380. 0 447 67

Energy Star GE GE GTH15BBR 14.9 10. 7 4.1 17 .4 379.4 380

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table C-l. Top-Mount Refrigerator-Freezer Matched Pairs 

GE GE GTS22KBPWW 21.7 15.4 6.4 25.7 448.7 529 81 

GE GE GTH22KBRWW 21.7 15.4 6.4 25.7 448.7 448 

Baseline Frigidaire Frigidaire FRT21C5A 20.5 15.3 5.3 23.8 433.2 509 77 

Energy Star FRT21HC5D 20.6 15.3 5.3 23.8 433.2 432 

Baseline Whirlpool Whirlpool ET1MHKXM 21.0 14.6 6.4 25.0 443.1 514 71 

Energy Star Whirlpool Whirlpool ET1MTEXM 21.0 14.5 6.5 25.1 443.6 443 

Baseline Kenmore 74192 20.6 15.4 5.3 23.9 434.1 509 77 

Star Kenmore 74172 20.6 15.4 5.3 23.9 434.1 432 

Baseline Whirlpool Whirlpool ET8MHKXM 18.2 13.2 5.0 21.4 412.4 484 72 

Energy Star Whirlpool Whirlpool ET8FTEXM 18.2 13.2 5.0 21.4 412.4 412 

Baseline GE GE GTS18KBPWW 17.9 12.9 5.0 21.0 409.4 482 72 

Energy Star GE GE GTH18BRWW 17.9 12.9 5.0 21.0 409.4 410 

Baseline GE GE GTR16BBSRWW 15.7 11.6 4.1 18.3 386.6 455.0 69 

Star GE GE GTH16BBSLWW 15.7 11.4 4.1 18.1 385.6 386.0 

GE GE GTR15BBR 14.9 10.8 4.1 17.5 380.0 447 67 

GE GE GTH15BBR 14.9 10.7 4.1 17.4 379.4 380 

C-2 
Table C-1. Top-Mount Refrigerator-Freezer Matched Pairs (cont.)

Baseline GE GE GTS22KBPWW $799.00 $649.88 $799.00 $729.00

Energy Star GE GE GTH22KBRWW $849.00 $50.00 Not Listed $849.00 $50.00 $759.00 $30.00

Baseline Frigidaire Frigidaire FRT21C5A $449.00 Not Listed Not Listed Not Listed

Energy Star Frigidaire Frigidaire FRT21 HC5D $549.00 $100.00 Not Listed Not Listed Not Listed

Baseline Whirlpool Whirlpool ETIMHKXM $599.00 Not Listed $577.00 Not Listed

Energy Star Whirlpool Whirlpool ETiMTEXM $759.00 $160.00 Not Listed $727.00 $150.00 Not Listed

Baseline Kenmore 74192 $499.98 $499.98 Not listed Not Listed

Energy Star Kenmore 74172 $679.99 $180.01 $549.88 $49.90 Not listed Not Listed

Baseline Whirlpool Whirlpool ET8MHKXM $549.00 Not Listed $527.00 Not Listed

Energy Star Whirlpool Whirlpool ET8FTEXM $599.00 $50.00 $569.99 $583.12 $56.12 Not Listed

Baseline GE GE GTS18KBPWW $709.00 649.9 647.0 629.0

Energy Star GE GE GTH18BRWW $729.00 $20.00 Not Listed Not Listed Not Listed

Baseline GE GE GTR16BBSRWW $579.00 Not Listed Not Listed Not Listed

Energy Star GE GE GTH16BBSLWW $609.00 $30.00 Not Listed Not Listed Not Listed

Baseline GE GE GTR15BBR $579.00 $549.99 Not Listed $499.00

Energy Star GE GE GTH15BBR $609.00 $30.00 $549.99 $0.00 Not Listed Not Listed

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table C-l. Top-Mount Refrigerator-Freezer Matched Pairs (cont.) 

Baseline GE GE GTS22KBPWW $799.00 $649.88 $799.00 $729.00 

Energy Star GE GE GTH22KBRWW $849.00 Not Listed $849.00 $50.00 $759.00 

Baseline Frigidaire Frigidaire FRT21C5A $449.00 Not Listed Not Listed Not Listed 

re Frigidaire FRT21 HC5D $549.00 $100.00 Not Listed Not Listed Not Listed 

Baseline Whirlpool Whirlpool ET1MHKXM $599.00 Not Listed $577.00 Not Listed 

Energy Star Whirlpool ET1MTEXM $759.00 $160.00 Not Listed $727.00 $150.00 Not Listed 

Baseline Kenmore 74192 $499.98 $499.98 Not listed Not Listed 

Energy Star Kenmore 74172 $679.99 $180.01 $549.88 $49.90 Not listed Not Listed 

Whirlpool ET8MHKXM $549.00 Not Listed $527.00 Not Listed 

Whirlpool ET8FTEXM $599.00 $50.00 $569.99 $583.12 $56.12 Not Listed 

GE GTS18KBPWW $709.00 649.9 647.0 629.0 

GE GTH18BRWW $729.00 $20.00 Not Listed Not Listed Not Listed 

Baseline GE GE GTR16BBSRWW $579.00 Not Listed Not Listed Not Listed 

Energy Star GE GE GTH16BBSLWW $609.00 $30.00 Not Listed Not Listed Not Listed 

Baseline GE GE GTR15BBR $579.00 $549.99 Not Listed $499.00 

Star GE GE GTH15BBR $609.00 $30.00 $549.99 $0.00 Not Listed Not Listed 

C-3 
Table C-1. Top-Mount Refrigerator-Freezer Matched Pairs (cont.)

Baseline GE GE GTS22KBPWW Not Listed $649.00 Not Listed Not Listed Not Listed

Ener Star GE GE GTH22KBRWW Not Listed $679.00 $30.00 $672.94 $649.00 Not Listed

Baseline Frigidaire Frigidaire FRT21C5A $426.00 $479.00 $430.59 Not Listed $419.00

Ener Star Fri idaire Frigidaire FRT21HC5D $521.00 $95.00 Not Listed Not Listed Not Listed Not Listed

Baseline Whirlpool Whirlpool ETIMHKXM $599.00 $529.00 $556.25 $529.00 $449.00

Energy Star Whirlpool Whirlpool ET1 MTEXM $599.00 $0.00 $629.00 $100.00 $600.00 $43.75 $649.00 $120.00 $529.00 $80.00

Baseline Kenmore 74192 Not Listed Not Listed Not Listed Not Listed Not Listed

Energy Star Kenmore 74172 Not Listed Not Listed Not Listed Not Listed Not Listed

Baseline Whirlpool Whirlpool ET8MHKXM $499.00 $489.00 $530.00 $489.00 $429.00

Ener Star Whirlpool Whirlpool ET8FTEXM $499.00 $0.00 $549.00 $60.00 $561.25 $31.25 $549.00 $60.00 $479.00 $50.00

Baseline GE GE GTS18KBPWW Not Listed. Not Listed $627.50 $649.00

Energy Star GE GE GTH18BRWW Not Listed Not Listed $652.50 $25.00 Not Listed

Baseline GE GE GTR16BBSRWW Not Listed Not Listed Not Listed Not Listed Not Listed

Ener Star GE GE GTH16BBSLWW Not Listed Not Listed Not Listed Not Listed Not Listed

Baseline GE GE GTR15BBR Not Listed' Not Listed Not Listed Not Listed Not Listed

Ener y Star GE GE GTH15BBR Not Listed Not Listed Not Listed Not Listed Not Listed

 EE-PS-2006-001 COMMENT 04.7

GE 

GE 

Frigidaire 

Whirlpool 

GE 

GE 

GE 

GE 

GE 

GE 

GE 

GE 

Table C-l. Top-Mount Refrigerator-Freezer Matched Pairs (cont.) 

74192 

74172 

ET8MHKXM 

GTR16BBSRWW 

GTH16BBSLWW 

GTR15BBR 

GTH15BBR Not Listed 

C-4 

Not Listed 

Not Listed 

Not Listed 

Not Listed 

Not Listed 

Not Listed 

#4.7 

Not Listed 

Not Listed 

Not Listed 

Not Listed 
#4.,7

*ufWliirr:

Table C-Z. Top-Mount Refrigerator-Freezer Matched Pairs (cont.)

Baseline GE GE GTS22KBPWW n x glass 4 wire 1

Energy Star GE GE GTH22KBRWW n x glass 4 wire 1

Baseline Frigidaire Frigidaire FRT21C5A n x wire 2 wire 2

Energy Star Frigidaire Frigidaire FRT21HC5D n x wire 2 wire 1

Baseline Whirlpool Whirlpool ET1MHKXM n x glass 3 glass 1

Energy Star Whirlpool Whirlpool ET1 MTEXM n x glass 3 glass 1 has dual cooling

Baseline Kenmore 74192 n x glass 3 wire 1

Energy Star Kenmore 74172 n x glass 5 wire 1 humidity controlled crispers

Baseline Whirlpool Whirlpool ET8MHKXM n x glass 3 1

Energy Star Whirlpool Whirlpool ET8FTEXM n x glass 4 1 has dual cooling

Baseline GE GE GTS18KBPWW n x glass 4 wire 1

Energy Star GE GE GTH18BRWW n x glass 4 wire 1

Baseline GE GE GTR16BBSRWW n x wire 2 0

Energy Star GE GE GTHI6BBSLW W n x wire 2 0

Baseline GE GE GTR15BBR n x wire 2 0

Energy Star GE GE GTH15BBR n x wire 2 0

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table C-l. Top-Mount Refrigerator-Freezer Matched Pairs (cont.) 

Baseline GE GE GTS22KBPWW n x glass 4 wire 

Energy Star GE GE GTH22KBRWW n x glass 4 wire 

Baseline Frigidaire Frigidaire FRT21C5A n x wire 2 wire 2 

Energy Star Frigidaire Frigidaire FRT21 HC5D n x wire 2 wire 1 

Baseline Whirlpool Whirlpool ET1MHKXM n x glass 3 glass 

ET1MTEXM n x 3 glass has dual cooling 

Baseline Kenmore 74192 n x glass 3 wire 

Energy Star Kenmore 74172 n x glass 5 wire humidity controlled crispers 

Baseline Whirlpool Whirlpool ET8MHKXM n x glass 3 

Energy Star Whirlpool Whirlpool ET8FTEXM n x glass 4 has dual 

Baseline GE GE GTS18KBPWW n x glass 4 wire 

Star GE GE GTH18BRWW n x ass 4 wire 

Baseline GE GE GTR16BBSRWW n x wire 2 0 

Energy Star GE GE GTH16BBSLWW n x wire 2 0 

Baseline GE GE GTR15BBR n x wire 2 0 

Energy Star GE GE GTH15BBR n x wire 2 0 

C-5 
Table C-2. Side-Mount Refrigerator-Freezer Matched Pairs

Baseline GE GE Profile I PSI23NGPWW 22.6 14.4 8.2 27.8 583.9 686 102

Energy Star GE GE Profile I PSH23PGRWW 1122.6 14.1 8.5 28.0 585.2 584

Baseline GE GE GSS25KGPWW 24.9 15.4 9.6 31.0 611.1 715 105

Energy Star GE GE GSH25KGRWW 25.0 15.4 9.6 31.0 611.1 610

Baseline Frigidaire Frigidaire GLRS267ZD 25.7 16.5 9.5 31.9 619.3 727 109

Energy Star Frigidaire Frigidaire GLHS268ZD 26.0 16.5 9.5 31.9 619.4 618

Baseline Maytag Amana ASD2622HRW 25.6 15.8 9.8 31.8 617.9 705 88

Energy Star Maytag Amana ASD2624HEW 25.6 15.8 9.8 31.8 617.9 617

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table C-2. Side-Mount Refrigerator-Freezer Matched Pairs 

GE GE Profile PSI23NGPWW 22.6 14.4 8.2 27.8 583.9 686 102 

GE GE Profile PSH23PGRWW 22.6 14.1 8.5 28.0 585.2 584 

GE GE GSS25KGPWW 24.9 15.4 9.6 31.0 611.1 715 105 

GE GE GSH25KGRWW 25.0 15.4 9.6 31.0 611.1 610 

Baseline Frigidaire Frigidaire GLRS267ZD 25.7 16.5 9.5 31.9 619.3 727 109 

Energy Star Frigidaire Frigidaire GLHS268ZD 26.0 16.5 9.5 31.9 619.4 618 

Maytag Amana ASD2622HRW 25.6 15.8 9.8 31.8 617.9 705 88 

Amana ASD2624HEW 25.6 15.8 9.8 31.8 617.9 617 

C-6 
#4®7

Table C-2. Side-Mount Refrigerator-Freezer Matched Pairs (cont.)

Retail Price Data:`

$1,139.00 j

$1,239.00

$140.01

Not Listed

Not Listed

Not Listed

$999.00

Not Listed

Not Listed

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table C-2. Side-Mount Refrigerator-Freezer Matched Pairs (cont.) 

C-7 
#4,7

Table C-2. Side-Mount Refrigerator-Freezer Matched Pairs (cont.)

Dat

^,'^', I ^ alt •.lc

Baseline GE GE Profile PSI23NGPWW $2,499.00 Not Listed Not Listed Not Listed Not Listed

Energy Star GE GE Profile PSH23PGRWW Not Listed Not Listed Not Listed Not Listed Not Listed

Baseline GE GE GSS25KGPWW Not Listed Not Listed $1,269.00 Not Listed Not Listed

Energy Star GE GE GSH25KGRWW Not Listed Not Listed $1,266.25 $-2.75 Not Listed Not Listed

Baseline Frigidaire Frigidaire GLRS267ZD Not Listed Not Listed $955.29 $1,029.00 Not Listed

Energy Star Frigidaire Frigidaire GLHS268ZD $1,099.00 $1,189.00 $1,058.82 $103.53 $1,189.00 '$160.00 Not Listed

Baseline Maytag Amana ASD2622HRW Not Listed $869.00 $900.00 $869.00 $849.00

Energy Star Maytag Amana ASD2624HEW Not Listed $919.00 $50.00 $954.87 $54.87 $919.00 $50.00 $905.00 $56.00

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table C-2. Side-Mount Refrigerator-Freezer Matched Pairs (cont.) 

Baseline GE GE Profile PSI23NGPWW $2,499.00 Not Listed Not Listed Not Listed Not Listed 

Energy Star GE GE Profile PSH23PGRWW Not Listed Not Listed Not Listed Not Listed Not Listed 

Baseline GE GE GSS25KGPWW Not Listed Not Listed $1,269.00 Not Listed Not Listed 

Energy Star GE GE GSH25KGRWW Not Listed Not Listed $1,266.25 $-2.75 Not Listed Not Listed 

Frigidaire Frigidaire GLRS267ZD Not Listed Not Listed $955.29 $1,029.00 Not Listed 

GLHS268ZD $1,099.00 $1,189.00 $1,058.82 $103.53 $1,189.00 $160.00 Not Listed 

Baseline Maytag Amana ASD2622HRW Not Listed $869.00 $900.00 $869.00 $849.00 

Energy Star Maytag Amana ASD2624HEW Not Listed $919.00 $50.00 $954.87 $54.87 $919.00 $50.00 $905.00 $56.00 

C-8 
Table C-2. Side-Mount Refrigerator-Freezer Matched Pairs (cont.

Category Manufacturer brand Model Number ice None ' Installed installable Filter'

ional<o

n%e'rP'W7 ll" nbe

Baseline

Energy Star

GE

GE

GE Profile I

GE Profile

PSI23NGPWW I

PSH23PGRWW

ly

y

x

x

glass

glass

3

3

wire 2

2

Baseline GE GE GSS25KGPWW y x x glass 3 4

Energy Star GE GE GSH25KGRWW y x x glass 3 4

Baseline Frigidaire Frigidaire GLRS267ZD y x x glass 3 glass 2

Energy Star Frigidaire Frigidaire GLHS268ZD y x x glass 3 glass 2

Baseline Maytag Amana ASD2622HRW y x x glass 3

Energy Star Maytag Amana* ASD2624HEW y x x glass 3

 EE-PS-2006-001 COMMENT 04.7

#4.7 

Table C-2. Side-Mount Refrigerator-Freezer Matched Pairs (cont.) 

Baseline GE GE Profile PSI23NGPWW x 3 wire 2 

Energy Star GE GE Profile PSH23PGRWW x 3 2 

Baseline GE GE GSS25KGPWW y x x glass 3 4 

Energy Star GE GE GSH25KGRWW y x x glass 3 4 

Baseline Frigidaire Frigidaire GLRS267ZD y x x glass 3 glass 2 

Star re GLHS268ZD x x 3 2 

Baseline Maytag Amana ASD2622HRW x x 3 

Energy Star Maytag Amana' ASD2624HEW x x 3 

C-9 
APPENDIX D. MANUFACTURER INTERVIEW GUIDE

BACKGROUND: PRIORITY SETTING CRITERIA

1. Energy savings potential

2. Potential economic benefits / burdens

3. Potential environmental or energy security benefits

4. Applicable deadlines for rulemakings

5. Incremental DOE resources required to complete rulemaking process

6. Evidence of market-driven or voluntary efficiency improvements

7. Status of required changes to test-procedures

8. Impact of potential regulation on product innovation

9. Fuel neutrality

10. Impact on peak demand for electricity

11. Impact of potential regulation on small businesses

12. Cumulative regulative burden on products, related products manufactured by the same

manufacturers

DESIGN FOR ENERGY IMPROVEMENT INFORMATION REQUEST

We want to confirm information on the cost impact of increasing refrigerator efficiency

by understanding the design options involved in the efficiency improvement. We expect a

significant, but not large, level of design change associated with bringing current refrigerator

model lines up to Energy Star level. It is our expectation that Energy Star level can be achieved

with some insulation thickness increase and use of more efficient refrigeration system

components. Questions are as follows.

1. What design changes are generally required to convert a typical 2001-compliant TopMount refrigerator to Energy Star level? Are the set of required design changes different

for Side-by-Side models?

2. What additional design changes would be required to achieve an additional. 10% energy

reduction, possibly the level of a future Energy Star?

D-1

 EE-PS-2006-001 COMMENT 04.7

#4.7 

APPENDIX D. MANUFACTURER INTERVIEW GUIDE 

BACKGROUND: PRIORITY SETTING CRITERIA 

1. Energy savings potential 

2. Potential economic benefits / burdens 

3. Potential environmental or energy security benefits 

4. Applicable deadlines for rulemakings 

5. Incremental DOE resources required to complete rulemaking process 

6. Evidence of market-driven or voluntary efficiency improvements 

7. Status of required changes to test· procedures 

8. Impact of potential regulation on product innovation 

9. Fuel neutrality 

10. Impact on peak demand for electricity 

11. Impact of potential regulation on small businesses 

12. Cumulative regulative burden on products, related products manufactured by the same 

manufacturers 

DESIGN FOR ENERGY IMPROVEMENT INFORMATION REQUEST 

We want to confirm information on the cost impact of increasing refi'igerator efficiency 

by understanding the design options involved in the efficiency improvement. We expect a 

significant, but not large, level of design change associated with bringing CutTent refi'igerator 

model lines up to Energy Star level. It is our expectation that Energy Star level can be achieved 

with some insulation thickness increase and use of more efficient refrigeration system 

components. Questions are as follows. 

1. What design changes are generally required to convert a typical2001-compliant TopMount refrigerator to Energy Star level? Are the set of required design changes different 

for Side-by-Side models? 

2. What additional design changes would be required to achieve an additional 10% energy 

reduction, possibly the level of a future Energy Star? 

D-l 
#4®7

3. Are "matched pair" models instructive for understanding these design differences? We

are defining matched pairs as a pair of models that are effectively the same units except

for energy : the models have nearly identical internal volume , identical external

dimensions and features, but one model meets the 2001 Energy Standard and the other

meets Energy Star. Design differences between such units may be instructive in

illustrating the differences between 2001-compliant units and current Energy Star units.

Are such data available for Top-Mount and Side-by-Side model pairs?

4. What are the fundamental differences between required design changes that make the

cost increment much higher for some product class/sizes than others?

MANUFACTURER IMPACT ANALYSIS TOPICS

1 Key Issues

1.1 What are the key issues for your company regarding a possible future residential

refrigerator rulemaking?

2 Conversion Costs

2.1 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.

2.2 2.2 How would the imposition of new energy efficiency 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?

2.3 How might a new standard impact product innovation?

3 Product Mix and Profitability

3.1 How would your company's product mix and marketing strategy change with changes in

the efficiency standard?

3.2 Would the current percentage of shipments at Energy Star be the same under a new "15%

more-efficient " standard?

3.3 What distribution channels are used from the manufacturer to the retail outlet? What is the

share of product going through each distribution channel?

3.4 Generally how would new refrigerator standards impact your customer mix, distribution

channels and corresponding profit margins`?

3.5 How might a new standard impact the Energy Star program and consequently your firm?

D-2

 EE-PS-2006-001 COMMENT 04.7

#4.7 

3. Are "matched pair" models instructive for understanding these design differences? ·We 

are defining matched pairs as a pair of models that are effectively the same units except 

for energy: the models have nearly identical internal volume, identical external 

dimensions and features, but one model meets the 2001 Energy Standard and the other 

meets Energy Star. Design differences between such units may be instructive in 

illustrating the differences between 200l-compliant units and current Energy Star units. 

Are such data available for Top-Mount and Side-by-Side model pairs? 

4. What are the fundamental differences between required design changes that make the 

cost increment much higher for some product class/sizes than others? 

MANUFACTURER IMPACT ANALYSIS TOPICS 

1 Key Issues 

1.1 What are the key issues for your company regarding a possible future residential 

refrigerator rulemaking? 

2 Conversion Costs 

2.1 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. 

2.2 2.2 How would the imposition of new energy efficiency 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? 

2.3 How might a new standard impact product innovation? 

3 Product Mix and Profitability 

3.1 How would your company's product mix and marketing strategy change with changes in 

the efficiency standard? 

3.2 Would the current percentage of shipments at Energy Star be the same under a new" 15% 

more-efficient" standard? 

3.3 What distribution channels are used from the manufacturer to the retail outlet? What is the 

share of product going through each distribution channel? 

3.4 Generally how would new refrigerator standards impact your customer mix, distribution 

channels and corresponding profit margins? 

3.5 How might a new standard impact the Energy Star program and consequently your fIrm? 

D-2 
3.6 In reference to the "summary data tables" provided by AHAM, for each product class,

what is the approximate percentage of shipments (i.e., market share) for each refrigerator

size?

4 Exports, Foreign Competition, and Outsourcing

4.1 Would new standards change your projected export sales?

4.2 Would new standards have an impact on the portion of the domestic market served by

foreign competition?

4.3 Would standards impact your decisions regarding domestic production levels? How would

domestic employment levels change under new energy efficiency standards?

5 Market Shares and Industry Consolidation

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

5.2 How would new standards affect your ability to compete?

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

some firms?

5.4 Are there concerns over intellectual property?

5.5 Could new standards result in disproportionate economic or performance penalties for

particular consumer/user subgroups?

5.6 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?

6 Cumulative Regulatory Burden

6.1 Are there recent or impending regulations on refrigerators or other products that impose a

cumulative burden on the industry?

What is the total expected impact of those other regulations?

 EE-PS-2006-001 COMMENT 04.7

#4.7 

3.6 In reference to the "summary data tables" provided by AHAM, for each product class, 

what is the approximate percentage of shipments (i.e., market share) for each refrigerator 

size? 

4 Exports, Foreign Competition, and Outsourcing 

4.1 Would new standards change your projected export sales? 

4.2 Would new standards have an impact on the portion of the domestic market served by 

foreign competition? 

4.3 Would standards impact your decisions regarding domestic production levels? How would 

domestic employment levels change under new energy efficiency standards? 

5 Market Shares and Industry Consolidation 

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

5.2 How would new standards affect your ability to compete? 

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

some fIrms? 

5.4 Are there concerns over intellectual property? 

5.5 Could new standards result in disproportionate economic or performance penalties for 

particular consumer/user subgroups? 

5.6 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? 

6 Cumulative Regulatory Burden 

6.1 Are there recent or impending regulations on refrigerators or other products that impose a 

cumulative burden on the industry? 

What is the total expected impact of those other regulations? 

D-3