APPENDIX A

– DRAFT ENGINEERING ANALYSIS DATA REQUEST SHEETS

DOE seeks average incremental production cost to take basic models in the categories shown

from the current DOE minimum efficiency level (or proposed baseline level) to the specified

efficiency l evel. For those product classes where more than one basic model may exist, please

indicate the minimum and maximum incremental costs that would be incurred across the array of

basic models.

The data sheets are divided by product and contain tables request ing shipment and manufacturer

cost data. The shipment

- weighted energy use data of Table A

- 2 should be based on the DOE

clothes washer test procedure (10 CFR 430, subpart B, appendix J1, J2).

Shipments

For commercial clothes washers, the AHAM 2005 Fact Bo ok offers historical shipments data,

but the information is not disaggregated by product class. As shown in the “shipment request”

tables below, DOE hopes to collect both shipments data and shipment

- weighted average

efficiency data dating back to 1995. In addition, DOE hopes to collect market share efficiency

data ( i.e. , data on the distribution of equipment shipments by efficiency) for each product class.

Manufacturer Costs

Incremental cost data (in U.S. dollars) include the materials, labor, and overhe ad needed to take

basic models from the current minimum DOE baseline efficiency standard to each higher

efficiency level. The depreciation of the conversion capital expenditures is an important

component of the overhead for DOE to understand. Therefore, DO E is requesting information

about conversion capital expenditures by efficiency level.

DOE requests notification from those interested parties planning to submit data by the close of

the framework comment period.

Please provide aggregated industry data f or the following tables.Table A

- 1 Commercial Clothes Washer Shipments, Domestic plus Imports , in

Thousands of Units

Year Total Top

- Loading % Imported Front

- Loading % Imported

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010 164,196 104

, 159 * 60,037 *

2011 160

, 973 106,592 * 54,381 *

For the type of data requested in the table above , it is AHAM’s policy to only retain

the pre vious two calendar years of data collected from its members

.

*AHAM only has collected domestic shipment data from its members.Table A

- 2 Shipment

- Weighted Average Efficiency Data

Top

- Loading Front

- Loading

Year EF / MEF / IM EF* WF / I WF † EF / MEF / IM EF* WF / I WF †

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010 1.36 (MEF) 9.10 (WF) 2.19 (MEF) 4.68 (WF)

2011 1.32 (MEF) 9.33 (WF) 2.31 (MEF) 4. 43 (WF)

* Please specify whether energy factor (EF), modified energy factor (MEF), or integrated modified energy

factor (IMEF).

† Please specify whether water factor (WF) or integrated water factor (IWF).

For the type of data requested in the table ab ove , it is AHAM’s policy to only retain

the previous two calendar years of data collected from its members.Table A

- 3 Market Share Efficiency Data*

Top

- Loading Front

- Loading

Efficiency Bins Market Share †

(Percent) Efficiency Bins Market Share †

(Percent)

MEF WF 2009 2010 2011 MEF WF 2009 2010 2011

1.26 9.5 82% 80% 1.72 8.0 1% 0%

1.42 9.5 18% 20% 1.80 7.5 1% 0%

1.60‡ 8.5‡ 0% 0% 2.00‡ 5.5‡ 28% 28%

2.20 5.1 68% 34%

2.40 4.0 0% 38%

2.60 3.7 0% 0%

* Efficiency bins correspond to those used during the prior CCW rulemaking in addition to the proposed

TSLs for this rulemaking.

† Total market shares should equal 100%.

‡ January 8, 2013 DOE standard.

For the type of data requested in the table above , it is AHAM’s policy to only ret ain

the previous two calendar years of data collected from its members.

Note s :

**•** Models with MEF/W F data not meeting the criteria for both MEF and WF for any

of the Efficiency Bins in the table above were included in the Efficiency Bin for

which the val ue of the lesser efficient, MEF or WF, is satisfied. For example, a

model with a MEF = 2.01 and WF = 5.6 would have been included in the 1.80/7.5

Efficiency Bin.

**•** The percentages for the Front

- Loading may not add up to 100% due to the absence

of the curre nt Federal Minimum Standard levels from the MEF/WF Efficiency Bins

listed in the table

.Table A

- 4 Aggregate Manufacturer Cost Data: Front

- Loading Commercial Clothes

Washers

Efficiency Level Baseline Level 1 Level 2 Level 3

MEF 2.00 2.20 2.40 2.60

WF 5.5 4.5 4.0 3.7

Average Incremental Costs ($ Per Unit)*

Direct Material 0

Direct Labor 0

Overhead # 0

Minimum Incremental Costs ($ Per Unit)*

Direct Material 0

Direct Labor 0

Overhead # 0

Maximum Incremental Costs ($ Per Uni t)*

Direct Material 0

Direct Labor 0

Overhead # 0

Conversion Capital Expenditures ($, Millions)

Building CAPX 0

Tooling/ Equipment CAPX 0

R&D 0

Marketing 0

* Incremental costs per unit should be reported relative to the baseline unit’s cost.

# Depreciation on the conversion capital expenditu re should NOT be included in incremental overhead.

_______________________________________________.

Direct material

– Costs of raw materials including scrap that can be traced to fin al or end products. Direct material

costs do not include indirect material costs, which are attributed to supplies that may be used in the production

process but are not assigned to final products ( e.g ., lubricating oil for production machinery).

Direct l abor

– The earnings of workers who assemble parts into a finished good or operate machines in the

production process. Direct labor includes the fringe benefits of direct laborers, such as group health care, as well as

overtime pay. Direct labor does not in clude indirect labor, which is defined as the earnings of employees who do not

work directly in assembling equipment, such as supervisors, janitors, stockroom personnel, and forklift operators.

Overhead

– Factory overhead excluding depreciation. Factory o verhead includes indirect labor, downtime, set

- up

costs, indirect material, expendable tools, maintenance, property taxes, insurance on assets, and utility costs. Factory

overhead does not include selling, general, and administrative costs (SG&A); R&D; int erest; or profit (accounted for

by DOE separately).

AHAM has not collected the type of data requested in the table above from its

members.M anufacturer Impact Analysis Questions:

**•** What fraction of the Commercial Clothes Washer manufacturing industry is represented

by AHAM? Please indicate if this is by quantity or value of shipments.

Response : AHAM does not collect total commercial clothes washer shipments, and so

we cannot provide a response to this question.

**•** Are you aware of, or do you represen t any small business or low volume manufacturers?

Please identify them.

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

**•** Could new standards disproportionately advance or harm the competitive positions of

some firms?

**•** Could ne w standards result in disproportionate economic or performance penalties for

particular consumer/user subgroups?

**•** 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?

**•** What distribution channels are used from the manu facturer to the retail outlet? What is

the share of product going through each distribution channel?