1 | Energy Efficiency and Renewable Energy 

Energy Conservation Standards:

Notice of Proposed Rulemaking for

Residential Dishwashers

February 5, 2015

Bryan BerrDepartment of EnBuilding Technolo

EERE‐2014‐BT‐ST

ResDishwashers2ee.doe.gov
2

Welcome• Introductions (around the room)

• Role of the Facilitator• Ground Rules

– Speak one at a time.– Say your name for the record – there will be a complete transcrip

meeting.

– Be concise – share the ‘air‐time’.

– Keep the focus here – cell phones on silent; limit sidebar conversa

– Webinar participants turn phone on mute; ‘raise your hand’ to be 

to speak.

• Housekeeping Items• Agenda Review• Opening Remarks
3

Listening Via the Webcast• The Department is broadcasting this meeting live ove

Internet.

• DOE is providing the webcast to accommodate stakeh

that are unable to attend the public meeting in perso

• The web broadcast allows stakeholders to listen in an

the slides.

• All stakeholders are encouraged to submit written co

after the public meeting.
4

Agenda

9:00 – 9:30 am Welcome, Introduction

9:30 – 10:00 am Overview, Scope, Proposed Standard

10:00 – 10:15 am Market and Technology Assessment and 

10:15 – 10:45 am Engineering Analysis

10:45 – 11:00 am Break

11:00 – 11:15 am Energy Use and Markups Analysis

11:15 – 12:00 pm Life‐Cycle Cost and Payback Period Analy

12:00 – 1:00 pm Lunch

1:00 – 2:00 pm Shipments and National Impact Analysis

2:00 – 3:00 pm MIA and NOPR Analyses

3:00 – 4:00 pm Proposed Standard and Closing Remarks
5

Purpose of the Public Meeting

• Present the procedural and analytical approaches to 

potential energy conservation standards for resident

dishwashers.

• Invite comment on the energy conservation standard

proposed rulemaking (NOPR) and technical support (TSD), including DOE’s proposed standard levels.

• Invite participants to provide summary comments o

statements and raise additional issues for discussion
6

Issues for Discussion• Issue “boxes” correspond to the list of issues for which th

Department seeks comments.

• The list of issues is in the NOPR, available at:

http://www.regulations.gov/#!documentDetail;D=EERE‐2

0021‐0007

• The deadline for submitting comments is February 17, 201

(EST).

Issue Box: DOE welcomes comments, data, and informati

concerning the standards it is considering for residentialdishwashers. Issues that correspond to those raised in DO

published material will be presented. Whether invited by 

issue box or not, comments are welcome on any part of D

analysis.
7

Opening Remarks

Meeting participants are invited to provide open

remarks or statements at this time.
8

Public Meeting Topics

1 Overview, Scope, and Proposed Standard2 Market & Technology and Screening3 Engineering4 Energy Use and Markups Analysis5 Life-Cycle Cost & Payback Period Analysi6 Shipments and National Impact Analysis

7 MIA, NOPR Analyses, and Closing Remark
9

Regulatory History• Energy Policy and Conservation Act of 1975 (EPCA), 

– Amended by National Energy Conservation Policy Act of 19

619, to establish the “Energy Conservation Program for Cer

Equipment.”

– Authorizes DOE to establish conservation standards for cov

or equipment that would likely result in significant nationa

savings.

– Specifies a list of covered residential and commercial produ

contains provisions to classify additional products as covere

• Dishwasher regulations:

– The National Appliance Energy Conservation Act of 1987, P

amended EPCA and required an unheated drying option fo

– Energy conservation standards final rules

• 1991 (56 FR 22250), effective May 14, 1994.

• 2009 (74 FR 12058), effective January 1, 2010.• Current Standards – 2012 (77 FR 31918), effective May 30, 2
10

Scope of Coverage• 10 CFR 430.2 defines “dishwasher” as:

– “a cabinet‐like appliance which with the aid of water and d

washes, rinses, and dries (when a drying process is include

glassware, eating utensils, and most cooking utensils by ch

mechanical and/or electrical means and discharges to the p

drainage system.”

• Product Classes

– Compact (capacity less than eight place settings plus six se

specified in ANSI/AHAM DW‐1)

– Standard (capacity equal to or greater than eight place sett

serving pieces)

• DOE proposes to maintain the existing definition an

classes for residential dishwashers.
11

EPCA Factors

EPCA directs DOE to consider seven factors when sett

conservation standards. (42 U.S.C. 6313(a)(6)(B))

EPCA Factors Corresponding DOE 

1. Economic impact on consumers and

manufacturers

Life‐Cycle Cost Ana

Manufacturer Impact 

2. Lifetime operating cost savings compared

to increased cost for the equipment Life‐Cycle Cost Ana

3. Total projected energy savings National Impact An4. Impact on utility or performance Engineering Anal

Screening Analy

5. Impact of any lessening of competition Manufacturer Impact 6. Need for national energy conservation National Impact An7. Other factors the Secretary considers

relevant

Emissions analy

Emissions monetizatio

Utility, employment, and reg

analyses
12

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy &Water Use Analysis

Manufacturer Impact Analysis

NOPR Final Rule 

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis
13

Proposed Standards

TSL

Standard Compact

Efficiency 

Level AEU (kWh/year)

Water 

Consumption

(gal/cycle)

Efficiency 

Level

AEU 

(kWh/year)

1 1 295 4.25 Baseline 222 2 3 234 3.10 1 203 3 4 180 2.22 2 141 
14

Rationale for Adopting the Proposed Standard

TSL Benefits Burden

2

• 1.0 quad of energy saved from 2019–2048• Net benefits of $0.23 billion in NPV at 7%

discount rate and $2.14 billion at 3% discount

rate

• Emission reductions:

‐ 61.9 MMt CO2 valued at up to $6.1 billion

‐ 126.7 kt of NOX valued at up to $0.17 billion

• For both product classes, the average LCC

savings are positive

• Net decrease in INPV 

34.7% ($203.7 millio

residential dishwash
15

Public Meeting Topics

1 Overview, Scope, and Proposed Standard2 Market & Technology and Screening3 Engineering4 Energy Use and Markups Analysis5 Life-Cycle Cost & Payback Period Analysi6 Shipments and National Impact Analysis

7 MIA, NOPR Analyses, and Closing Remark
16

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy &Water Use Analysis

Manufacturer Impact Analysis

NOPR Final Rule 

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis
17

Market and Technology AssessmentPurpose• Define product classes

• Characterize the residential dishwasher industry

• Identify existing regulatory and voluntary efficiency p

• Gather historical shipments and other relevant mark

• Identify technology options for improving efficiencySee chapter 3 of the TSD for further discussion of the m

technology assessment.
18

Market and Technology AssessmentProduct Classes• The proposed standards would apply to the existing 

classes for residential dishwashers.

– Compact (capacity less than eight place settings plus six se

specified in ANSI/AHAM DW‐1)

– Standard (capacity equal to or greater than eight place sett

serving pieces)
19

Market and Technology AssessmentTechnology Assessment• Purpose

– To develop a preliminary list of technology options that cou

the efficiency of dishwashers.

– To examine the list in greater detail, including removing ina

technologies, in subsequent analyses.

• Method

– DOE identified technology options from:

• Technical support documents from previous rulemakings

• Literature review and manufacturer specification sheets

• Product teardowns

• The full list of technologies that DOE identified can b

Chapter 3 of the TSD.
20

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy &Water Use Analysis

Manufacturer Impact Analysis

NOPR Final Rule 

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis
21

Screening Analysis• Purpose

– To determine which technology options will be considered 

downstream analyses.

• Technology options are “screened out” if they:

– Are not technologically feasible

– Are not practicable to manufacture, install, and service

– Have adverse impacts on equipment utility or availability to 

– Have adverse impacts on health or safety

• Screened‐Out Technologies:

– Reduced inlet water temperature

– Supercritical carbon dioxide washing

– Ultrasonic washing

• The remaining technology options were considered 

engineering analysis.
22

Public Meeting Topics

1 Overview, Scope, and Proposed Standard2 Market & Technology and Screening3 Engineering4 Energy Use and Markups Analysis5 Life-Cycle Cost & Payback Period Analysi6 Shipments and National Impact Analysis

7 MIA, NOPR Analyses, and Closing Remark
23

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy &Water Use Analysis

Manufacturer Impact Analysis

NOPR Final Rule 

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis
24

Engineering AnalysisPurpose• Evaluate design options that improve efficien• Characterize manufacturer production cost (M

versus efficiency for higher‐efficiency dishwa

Downstream Ana

• Life‐Cycle Cost an

Payback Period A

• National Impact A

• Manufacturer Im

Analysis

Manufacturer Production Cost–

Efficiency Relationship

Manufacturer

Production Cost

Efficiency Level
25

Engineering Analysis

Develop Baseline and 

Higher ELs

Select Representative

Units

Identify Design

Options at ELs

Calculate Costs

Generate Cost‐

Efficiency Curves



Determine appropriate baseline and higher efficie

both product classes.Select representative units for testing and reverse 

Identify design options used to increase product e

determine mix of design options needed to reach 

efficiency levels.

Conduct cost modeling analysis based on teardow

representative products and the observed design 

efficiency levels identified.

Generate cost‐efficiency curves, which account fo


26

Engineering AnalysisBaseline Efficiency Levels• DOE selected baseline efficiency levels consistent wi

2013 standards.

• DOE is aware of dishwashers available on the market 

baseline levels for both product classes.

Product Class Efficiency Level kWh/year gal/cycle

Standard 307 5.0Compact 222 3.5
27

Engineering AnalysisStandard Dishwasher Efficiency Levels• DOE analyzed the following improved efficiency leve

the baseline for standard dishwashers:

Level Efficiency Level Reference Source Efficiency Level kWh/year ga

Baseline DOE Standard 307 

EL 1 ENERGY STAR (current) 295 

EL 2 Available for Purchase 280 

EL 3 Available for Purchase 234 

EL 4 Maximum Availablea 180 

a) Source: DOE‐certified dishwashers as of May 22, 2014
28

Engineering AnalysisStandard Dishwasher Efficiency Levels• DOE identified EL 3 (the standards proposed in this N

surveying units available on the market.

• DOE observed that few units are available between t

efficiency and the maximum available.
29

Engineering AnalysisCompact Dishwasher Efficiency Levels• DOE analyzed the following improved efficiency leve

the baseline for compact dishwashers:

• DOE is not aware of compact models available on th

EL 1; however, while developing its proposal, ENERG

discussed efficiency improvements and necessary de

changes with manufacturers.

Level Efficiency Level Reference Source Efficiency Level kWh/year ga

Baseline DOE Standard 222 

EL 1 Proposed ENERGY STAR 203 

EL 2 Maximum Availablea 141 

a) Source: DOE‐certified dishwashers as of May 22, 2014
30

Issue 1: DOE requests comment on the efficiency levels selected 

analysis. Specifically, DOE requests feedback on whether cleanin

performance or any other consumer utility is affected at any of 

analyzed efficiency levels.

Request for Comment
31

Engineering AnalysisTesting• DOE conducted testing in support of both this NOPR 

developing the ENERGY STAR Cleaning Performance Method.

• DOE observed that cleaning performance typically d

lower energy and water consumptions, with 0.4 kWh

machine electric energy consumption and 3 gal/cycle consumption appearing to be key levels.

– This occurred for the heavy and medium soil loads. For the 

load, cleaning performance did not appear to be related to 

water consumption; however, the amount of soil used in a 

is very low.
32

Engineering AnalysisTesting• Based on these results, DOE expects EL 3 to maintain 

cleaning performance.
33

Engineering AnalysisReverse Engineering• DOE tore down each unit tested in support of this NO

• Teardown information was also pulled from the anal

conducted in support of the May 2012 standards for 

are either still available on the market or are represe

currently available models.

• From these teardowns, DOE observed the typical de

incorporated into baseline and higher‐efficiency mod

• Chapter 5 of the TSD provides more detailed informa

teardowns and design options at each efficiency leve
34

Engineering AnalysisManufacturing Cost Model

Raw

Materials

Finished

Materials

P

Tea

Sele

Fabrication

Processes

Bill of 

As

Pro

Manu

• Physical teardown analysis

conducted with representativeproducts.

• Bills of material were generated

during the product teardowns

and were entered into the costmodel.

• Cost model generated

manufacturing, material, labor,and overhead costs.
35

Engineering Analysis

Structure/Classification of Manufacturing Cos

Full Manufacturer Selling

Price (MSP)

Non‐Production Cost **

Selling General & Admin. R & D 

Full Manufacturing Production Cost (MPC)*

Direct Labor Direct Material Overhead

Full Manufacturing Production Cost (MPC)*

Direct Labor Direct Material Overhead

Indirect laborIndirect materialMaintenanceDepreciationTaxesInsurance related

to assets

Market research

AdvertisingPOS promotionSales person

compensation &

travelLogistics‐ Warehousing‐ Delivery‐ Record keeping

Costs of

service &staff unitsGeneralcorporatecosts –

comp., etc.

Costsassociate

efforts to 

new or

improvedequipme

productiprocesse

* Tax Reform Act of 1986 essentially requires companies to measure cost of goods sold as the full production cos

** In a company’s income statement, many of these costs are reported as a lump sum, under SG&A expenses.
36

Engineering AnalysisCost‐Efficiency Relationship• Based on these analyses, DOE generated cost‐efficie

for each product class.

ProductClass Level Efficiency Level Incr. M

kWh/year gal/cycle

Standard

Baseline 307 5.0 $‐

EL 1 295 4.25 $9.5

EL 2 280 3.5 $36.5

EL 3 234 3.1 $74.7EL 4 180 2.22 $74.7

Compact

Baseline 222 3.5 $‐EL 1 203 3.1 $8.0

EL 2 141 2.0 $21.5
37

Issue 2: DOE requests comment on the estimated MPCs for eac

analyzed efficiency levels. DOE seeks input on what design optio

manufacturers are likely to incorporate into residential dishwash

each of the analyzed efficiency levels, and their associated costs

Request for Comment
38

Public Meeting Topics

1 Overview, Scope, and Proposed Standard2 Market & Technology and Screening3 Engineering4 Energy Use and Markups Analysis5 Life-Cycle Cost & Payback Period Analysi6 Shipments and National Impact Analysis

7 MIA, NOPR Analyses, and Closing Remark
39

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy &Water Use Analysis

Manufacturer Impact Analysis

NOPR Final Rule 

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis
40

Markups Analysis

Overview
41

Markups Analysis• Purpose

– Determine consumer prices based on manufacturer’s sellin

baseline and higher efficiency equipment.

– Characterize product distribution channels.

• Method

– Analyze company direct costs, expenses, and profits. Manu

estimated in the Engineering Analysis.

– U.S. Census Annual Retail Trade Survey– Sales Taxes: The Sales Tax Clearinghouse

Manufacturers Retailers Consumers
42

Markups Analysis: Markup Types• Baseline Markups

– Relate the MSP of baseline product to the consumer purch

– Indicate a consumer price that covers the retailer’s expense

• Incremental Markups

– Relate the increase in MSP of more efficient products to th

consumer purchase price.

– Cover only expenses that vary with MSP, in this case, expen

increase due to an efficiency standard.
43

Markups Analysis: Overall Markups

• Applied baseline markups to the MSP of the baseli

and the incremental markups to the incremental dMSP at each level above the baseline.

Standard and Compact Product Class

Markup Baseline IncrementalManufacturer 1.24Retailer 1.36 1.11Sales Tax 1.071

Overall 1.81 1.47
44

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy &Water Use Analysis

Manufacturer Impact Analysis

NOPR Final Rule 

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis
45

Energy and Water Use Analysis

Overview
46

Energy and Water Use Analysis• Purpose

– Determine annual energy and water use at the considered 

levels.

– Use annual energy and water use needed to determine cos

Life‐Cycle Cost and Payback Period Analysis.

• Method

– Use research studies and engineering analysis data to deve

energy use by efficiency level.

– Use DOE‐EIA’s Residential Energy Consumption Survey (REC

develop frequency ranges for annual energy and water use 

U.S. households.

– Use AD Little Survey to develop average annual energy use
47

Energy and Water Use Analysis

EL Energy Use (kWh/yr) Water Use (gal/cyc) Standby Power (W) Total* (kWh/cyc) Water Heating** (kWh/cyc) 

Baseline 307 5.00 0.0 1.43 0.82 

1 295 4.25 0.5 1.35 0.70 

2 280 3.50 0.5 1.28 0.58 

3 234 3.10 0.5 1.07 0.51 

4 180 2.22 0.5 0.82 0.37 

EL Energy Use (kWh/yr) Water Use (gal/cyc) Standby Power (W) Total* (kWh/cyc) Water Heating** (kWh/cyc) 

Baseline 222 3.50 2.3 0.94 0.58 

1 203 3.10 1.7 0.88 0.51 

2 141 2.00 0.5 0.64 0.33 

Standard Dishwashers: Per‐Cycle Energy and Water Use by Efficiency Level

Compact Dishwashers: Per‐Cycle Energy and Water Use by Efficiency Level

*Annual standby energy use is based on an assumed dishwasher cycle of one hour and 215 cycles per year. Standby hours = 

minus 215 * 1 hour = 8,551 hours.

*Based on the use of an electric water heater at 98% efficiency.
48

Energy and Water Use Analysis

Standard Dishwashers: Annual Energy and Water Use by Efficiency Level

Compact Dishwashers: Annual Energy and Water Use by Efficiency Level*Water‐heating energy use is based on water heater efficiencies of 98% for electric, 80% for gas, and 78% for oil.

EL

Annual Energy Use 

Total

(kWh/yr)

Water Heating* Machine +

Drying +

(kWh/yr)

Stand

Powe

(kWh/

Electric

(kWh/yr)

Gas

(MMBtu/yr)

Oil

(MMBtu/yr)

Baseline 307 177 0.74 0.76 130 0.0 

1 295 150 0.63 0.64 140 4.3 2 280 124 0.52 0.53 152 4.3 3 234 110 0.46 0.47 120 4.3 4 180 79 0.33 0.34 97 4.3 

EL

Annual Energy Use 

Total

(kWh/yr)

Water Heating* Machine +

Drying +

(kWh/yr)

Stand

Powe

(kWh/

Electric

(kWh/yr)

Gas

(MMBtu/yr)

Oil

(MMBtu/yr)

Baseline 222 124 0.52 0.53 78 19.7 

1 203 110 0.46 0.47 79 14.5 2 141 71 0.30 0.30 66 4.3 
49

Public Meeting Topics

1 Overview, Scope, and Proposed Standard2 Market & Technology and Screening3 Engineering4 Energy Use and Markups Analysis5 Life-Cycle Cost & Payback Period Analysi6 Shipments and National Impact Analysis

7 MIA, NOPR Analyses, and Closing Remark
50

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy &Water Use Analysis

Manufacturer Impact Analysis

NOPR Final Rule 

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis
51

Life‐Cycle Cost and Payback Period Analysis

Overview
52

Life‐Cycle Cost and Payback Period Analysis• Purpose

– Provide an economic evaluation from the consumer’s perspective

– Life‐Cycle Cost (LCC) = the total consumer cost over the life of the 

– Payback Period (PBP) = the time required to recover the increased 

price of more energy‐efficient equipment through reduced opera

• Method

– Use energy and water use as input into operating costs.

– Determine total installed costs for each efficiency level (EL).

– Determine first‐year and product lifetime operating costs.

– Calculate PBP by dividing average increase in installed cost by ave

in first‐year operating cost.

– Calculate LCC by adding installed costs and lifetime operating cost

– Calculate LCC savings by subtracting LCC of each EL from LCC of th

consumer would purchase in the absence of a new standard.
53

LCC and PBP Analysis: Consumer Sample• Model consumer households on the RECS 2009 sam

developed in the energy and water use analysis.

• Use range frequencies in RECS to show variability in 

energy and water use and resulting costs.

• Characterize with probability distributions of other in

discount rates and lifetimes).

– Monte Carlo sampling was used to create a consumer list w

values for these inputs.
54

LCC and PBP Analysis: Total Installed Cost Inpu• Total Installed Cost = sum of equipment price and ins

cost.

• Product price = provided by Engineering Analysis and 

Analysis.

– Producer price indices (PPI) used to project residential dish

in 2019.

– DOE used producer price indices (PPI) from the Bureau of L

(BLS) for “other miscellaneous household appliances,” av

1988‐2013.

• Installation costs = labor and materials necessary pro

installation

– Costs based on RS Means Residential Cost Data 2013.

– DOE assumed that installation costs would not change base

efficiency level.
55

LCC and PBP Analysis: Operating Cost Inputs• Annual energy and water consumption provided by Energy and 

Analysis.

• Energy Information Administration (EIA) Form 861 Data used to 

electricity prices for 27 geographic areas.

• EIA Natural Gas Navigator used to develop natural gas prices fo

geographic areas.

• EIA State Energy Consumption, Price and Expenditures Estimat

used to develop LPG and oil prices for 27 geographic areas.

• Raftelis Water and Waste Water Rate Survey used to develop w

for 4 Census Regions.

• DOE used Annual Energy Outlook (AEO) 2014 for projections of 

energy prices for each census division.

• DOE used Consumer Price Index (CPI) trend of national water p

(1970 – 2012) to develop future water prices.
56

LCC and PBP Analysis: Operating Cost Inputs• Maintenance costs represent the labor and material

to maintain the equipment

• Repair costs are associated with repairing or replacin

components that have failed.

– Typically, small incremental changes in product efficiency in

no changes in repair and maintenance costs over baseline 

Therefore, DOE did not include maintenance and repair cos

based on efficiency level.
57

Request for Comment

Issue 3: DOE requests comments on the determination of

maintenance, and repair costs for more efficient residential

dishwashers. If not appropriate, DOE requests information a

data that can be used to develop appropriate repair and

maintenance costs for products more efficient than baseline

products.
58

LCC and PBP Analysis: Product Lifetime• Base product lifetime on a Weibull probability distrib

historical shipments data and saturations for RECS anAmerican Housing Survey.

– Average lifetime for both product classes: 15.4 years

0.0%1.0%2.0%3.0%4.0%5.0%6.0%

0 5 10 15 20 25 30 35 40 45 50

Year

Retirement Function for Dishwashers

(mean = 15.4 years)
59

LCC and PBP Analysis: Discount Rates• Use discount rates to convert streams of annual ope

expenses to present value in the LCC analysis.

– Derived from various types of debt and equity

– Federal Reserve Board’s Survey of Consumer Finances is a s

much of the equity and debt data.

Income Group Discount Rate (%)

1 4.852 5.123 4.754 4.045 3.806 3.57

Overall Average 4.49
60

LCC and PBP Analysis: Energy Efficiency in the 

• Analyze standard levels relative to

a baseline efficiency level.

• Define base case efficiency

distributions from the percentage

of products being purchased at

various efficiency levels.

• Use historical shipments weighted

base case efficiency trend (2002 –

2009) to estimate base case

efficiency in the year of

compliance (2019).

250270290310330350370390410430

2002

2005

2008

2011

2014

2017

2020

2023

2026

2029

2032

Base‐case AEU (kWh/year)

Year

Base Case Annual Energy 
61

LCC and PBP Analysis: Energy Efficiency in the 

Efficiency

Level

Annual Energy Use

(kWh/yr)

Water Use

(gal/cycle)

Market

Share

Baseline 307 5.00 12.1%

1 295 4.25 43.9%2 280 3.50 40.3%3 234 3.10 3.2%4 180 2.22 0.4%

Efficiency

Level

Annual Energy Use

(kWh/yr)

Water Use

(gal/cycle)

Market

Share

Baseline 222 3.50 48.1%

1 203 3.10 14.8%2 141 2.00 37.0%

Standard Dishwashers: Base Case Efficiency Distribution in 2019

Compact Dishwashers: Base Case Efficiency Distribution in 2019
62

Request for Comment

Issue 4: DOE requests comments, information and data on 

base case efficiency distributions of residential dishwashers

Given that historical market share efficiency data from 200

2009 were used to develop estimated base case efficiency

distributions in the compliance year (2019), DOE seeks morrecent historical market share efficiency data that would be

useful for developing the base case efficiency distributions 

the analysis period.
63

LCC and PBP Analysis: Results

EL

Annual

Energy Use

(kWh/yr)

Water

Use

(gal/cyc)

Life‐Cycle Cost

2013$ Average Life‐

Cycle Cost

Savings ($)

Simpl

Payba

(years

Total

Installed Cost

($)

Average

Lifetime

Operating

Cost ($)

Average Life‐

cycle Cost

($)

Baseline 307 5.00 483 518 1,000 ‐‐ ‐‐ 

1 295 4.25 495 492 987 2 6.1 2 280 3.50 531 462 993 ‐2 10.8 

3 234 3.10 582 387 970 21 9.0 4 180 2.22 582 296 879 112 5.3 

EL

Annual

Energy Use

(kWh/yr)

Water

Use

(gal/cyc)

Life‐Cycle Cost

2013$ Average Life‐

Cycle Cost

Savings ($)

Simple

Paybac

(years

Total

Installed Cost

($)

Average

Lifetime

Operating

Cost ($)

Average Life‐

cycle Cost

($)

Baseline 222 3.50 456 302 758 ‐‐ ‐‐ 

1 203 3.10 467 274 741 8 4.5 2 141 2.00 485 188 673 51 2.9 

Standard Dishwashers: LCC and PBP Results

Compact Dishwashers: LCC and PBP Results
64

Issue 5: DOE invites comments and recommendations from inte

parties on any other aspects related to the Life‐Cycle Cost and P

Period Analysis.

Request for Comment
65

Public Meeting Topics

1 Overview, Scope, and Proposed Standard2 Market & Technology and Screening3 Engineering4 Energy Use and Markups Analysis5 Life-Cycle Cost & Payback Period Analysi6 Shipments and National Impact Analysis

7 MIA, NOPR Analyses, and Closing Remark
66

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy &Water Use Analysis

Manufacturer Impact Analysis

NOPR Final Rule 

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis
67

Shipments Analysis• Purpose

– Quantify changes over time of product shipments due to p

energy efficiency standards.

– Estimate the disaggregation of shipments into product clas

change in shipments by product class over time.

• Method

– Use historical shipments, and RECS data for stock estimatio

– Account for replacements and new installations.
68

Historical Shipments &

Market Share by

Product Class

Appliance Lifetime

Tot

Replacement

Shipments

Shipments by

Product Class

New Installation

Shipments Analysis: Modeling Approach
69

Shipments Analysis: Model Inputs

Inputs Data Source / Description

Historical Shipments

Total dishwasher shipments data:‐ Appliance Magazine (1972 – 1988),‐ AHAM Fact book (1989 – 1994),

‐ AHAM (2000 – 2010), and‐ Appliance Design (2011 – 2012).

Shipments by Product Class

Market share by product class: NPD data (2001 – 2011

‐ Standard Dishwashers: 99.2%

‐ Compact Dishwashers: 0.8%

Replacement

Dishwasher lifetime retirement function developed fro

Cost Analysis

‐ Average lifetime = 15.4 years

New Installation New installation estimated using AEO 2014 new housi

Product Price and Operating

Costs

LCC provides product prices for 2019.

Product price trend is applied to product price for the 

2048.Future operating costs estimated using AEO 2014 ene

and CPI national water price index trend.
70

Shipments Analysis: Base Case vs Standards Ca• Base Case Shipments Projection

– Capture base‐case shipments projection when new standa

adopted.

– Project shipments to account for replacements and new in– Develop base‐case projections for product classes.

• Standards Case Shipments Projection

– Project shipments for the base case using historical shipme– Develop standards case projections accounting for purchas

increases and operating cost savings.
71

Shipments Analysis: Standards Impacts on Ship

TSL

Annual Shipments (Unit: million)

2012 2015 2020 2030 2040 

Base

Case 5.7 7.3 7.5 8.2 9.0 

1 5.7 7.3 7.5 8.2 9.0 2 5.7 7.3 7.3 8.2 9.0 3 5.7 7.3 7.4 8.2 9.0 

• Shipments under each TSL are approximately the same as the 

shipments
72

Issue 6: DOE requests comments and information relating to the 

to the shipments model, particularly updated shipments and ma

share of standard and compact dishwashers.

DOE also welcomes stakeholder inputs and estimates on the eff

amended standards on future residential dishwasher shipments

Request for Comment
73

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy &Water Use Analysis

Manufacturer Impact Analysis

NOPR Final Rule 

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis
74

National Impact Analysis• Purpose

– Determine the projected national energy and water saving

consumer national net present value.

• Method

– Develop annual series of national energy, water and econo

– Use the shipments model to estimate the total stock of res

dishwashers in service each year.

– Aggregate the costs and energy and water use per unit in a

– Report estimates for economic impact as change in consum

Net Present Value (NPV) (in constant year dollars).

– Account for the time‐value of money through defined disco
75

Shipments Model

National Energy/Water Savings

NationalEconomicImpacts

LCC Analysis Results and Other Inputs

N

Energ

Savin

trilli

N

Net P

(2013 

• National energy and water savings calculated for period from 2

years)

• NPV calculated for products shipped over the period from 2019 

years of shipments).

National Impact Analysis: Process

National Economic Impacts
76

Inputs Description

Total Installed Cost Annual weighted‐average per unit values as a function of efficien

from the LCC analysis.

Annual Energy andWater Use

Annual weighted‐average per unit values as a function of efficienfrom LCC analysis.

Base‐CaseEfficiencies

Shipments‐weighted efficiencies determined for the effective ye

base‐case efficiency distribution from LCC analysis.

Standards‐CaseProjectedEfficiencies

Roll‐up scenario assumed for determining shipment‐weighted ef

each standards case.

Energy Prices Average prices and forecasted energy prices from EIA AEO 2014 

2040) and extrapolation to 2048.

Water Price Linear extrapolation of inflation‐adjusted historical national wate

(to 2048).

Full Fuel Cycle Multiplier to convert site energy to full‐fuel cycle energy.

Discount Rate 7 percent and 3 percent real from OMB’s Regulatory Analysis Gu

Present Year Future expenses are discounted to the year 2014.

National Impact Analysis: Inputs
77

National Impact Analysis: Trial Standard Levels

TSL

Standard Compact

Efficiency

Level

Annual

Energy Use

(kWh/year)

Water Use

(gal/cycle)

Efficiency

Level

Annual

Energy Use

(kWh/year)

W

(g

1 1 295 4.25 Baseline 222 2 3 234 3.10 1 203 3 4 180 2.22 2 141 
78

National Impact Analysis: Energy and Water Sav

TSL Primary Energy Savings (quads) Full‐Fuel‐Cycle Energy Savings (quads) National 

Savin

(trillion ga

1 0.00 0.01 0.032 1.00 1.06 0.243 2.39 2.53 0.99
79

National Impact Analysis: Consumer NPV Result

TSL 7% Discount Rate (billion 2013$) 3% Discount Ra

(billion 2013$)

1 0.05 0.152 0.23 2.143 5.56 15.70
80

Issue 7: DOE analyzed the effects of potential standards on produ

purchased over a 30‐year period, and it undertook a sensitivity a

using 9 years rather than 30 years of product shipments. The cho

year period of shipments is consistent with the DOE analysis for o

products and commercial equipment. The choice of a 9‐year peri

proxy for the timeline in EPCA for the review of certain energy co

standards and potential revision of, and compliance with, such am

standards. DOE is seeking input on ways to refine the analytical t

Request for Comment
81

Public Meeting Topics

1 Overview, Scope, and Proposed Standard2 Market & Technology and Screening3 Engineering4 Energy Use and Markups Analysis5 Life-Cycle Cost & Payback Period Analysi6 Shipments and National Impact Analysis

7 MIA, NOPR Analyses, and Closing Remark
82

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy &Water Use Analysis

Manufacturer Impact Analysis

NOPR Final Rule 

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis
83

Purpose:• Assess the impacts of potential energy conservation standards o

manufacturers;

• Identify and estimate impacts on manufacturer subgroups that m

severely affected than the industry as a whole; and

• Examine the direct employment, product competition, manufact

capacity, and cumulative regulatory impacts on the industry.

Methodology:• Analyze industry cash flow and industry net present value (INPV) 

of the Government Regulatory Impact Model (GRIM); and

• Interview manufacturers to refine inputs to the GRIM, develop s

analyses, and address qualitative issues.

MIA: Overview
84

• Phase 1

– DOE creates an industry profile to characterize the market a

important issues that require further investigation.

• Phase 2

– DOE prepares an industry cash flow model and an interview

questionnaire to guide subsequent discussions with manufa

• Phase 3

– DOE interviews manufacturers and assesses the impacts of s

both quantitatively (using the GRIM) and qualitatively (impa

employment, competition, manufacturing capacity, and regu

burden).

MIA: Methodology

Industry profile

Develop preliminary GRIM

Develop interview guide

Interviews& industrysubgroupanalyses

Assess employmcompeticapacityregulatoburdens

Phase 1 Phase 2 Phase 3
85

For this rulemaking, DOE relied on information gathered from manufacturer interv

conducted in support of the May 2012 direct final rule (DFR). At that time, key issu

• Impact on Dishwasher Performance

– Wash performance, drying performance, cycle time, and noise levels

– Possible need for multiple washes

• Test procedures

– Multitude of additional test procedures in the field

– Lack of performance metrics

– Single versus multiple cycles

• Increased Competition

– Removal of features from higher efficiency units as a means to cut costs to 

low‐cost minimally‐compliant product OR the disappearance of entry‐leve

manufacturers are forced to add other features and cost in line with curre

efficiency products. The latter would increase competition within the high

segment.

• Cumulative Regulatory Burden

– Dishwashers are only one of a suite of products offered by manufacturers

– R&D, capital expenditures, and retraining to meet standards for each prod

MIA: Key Issues
86

• During interviews relating to the May 2012 DFR, DOE rece

feedback from manufacturers supporting the calculated 1

baseline markup

• DOE modeled two Markup Scenarios for DWs

– Preservation of Gross Margin Percentage (i.e. Flat Markup)

– Preservation of Operating Profit

• Preservation of Gross Margin Percentage Markup Scenar

Severe for Manufacturers

– In the flat markup scenario manufacturers fully pass through add

to their consumers and maintain their gross margin percentage in 

standards case.

• Preservation of Operating Profit Markup Scenario = Most 

for Manufacturers

– In the preservation of operating profit markup scenario manufact

maintain the same total operating profit in absolute dollars in the 

case as in the base case, despite a higher level of investment.

MIA: Scenarios Analyzed
87

• DOE modeled two Conversion Cost (CC) Scenarios fo

– CCs Based on May 2012 DFR

– CCs Based on 2014 Engineering Cost Model

• Conversion Costs Based on May 2012 DFR

– DOE scaled the product and capital CC estimates developed 

May 2012 DFR to reflect the new efficiency levels for each 

class.

• Conversion Costs Based on 2014 Engineering Cost M

– DOE developed a separate capital CC scenario using the en

cost model. For this estimate, DOE identified the design pa

considered in the engineering analysis, estimated the cost 

changes in production equipment to implement each desig

and aggregated these costs to reflect the industry‐wide inv

using market information about the number of platform an

families currently on the market from each manufacturer.

MIA: Scenarios Analyzed
88

MIA: INPV Results

• Preservation of Gross Margin Percentage Markup – Product and Capital 

from May 2012 DFR (Least Severe Impact for Manufacturers)

• Preservation of Operating Profit Markup – Product and Capital CCs Scal

2012 DFR (Most Severe Impact for Manufacturers)

Units Base Case Trial Standard Level 12

INPV (2013$ millions) 586.6 507.3 483.0 

Change in INPV (2013$ millions) ‐ ‐79.2 ‐103.6 

(%) ‐ ‐13.5% ‐17.7% 

Product Conversion Costs (2013$ millions) ‐ 38.3 61.7 Capital Conversion Costs (2013$ millions) ‐ 79.2 172 Total Conversion Costs (2013$ millions) ‐ 117.5 233.7 

Units Base Case Trial Standard Level 12

INPV (2013$ millions) 586.6 506.1 404.2 

Change in INPV (2013$ millions) ‐ ‐80.5 ‐182.3 

(%) ‐ ‐13.7% ‐31.1% 

Product Conversion Costs (2013$ millions) ‐ 38.3 61.7 Capital Conversion Costs (2013$ millions) ‐ 79.2 172 Total Conversion Costs (2013$ millions) ‐ 117.5 233.7 
89

MIA: INPV Results

• Preservation of Gross Margin Percentage Markup – Capital CCs Based o

Engineering Cost Model (Least Severe Impact for Manufacturers)

• Preservation of Operating Profit Markup – Capital CCs Based on 2014 E

Cost Model (Most Severe Impact for Manufacturers)

Units Base Case Trial Standard Level 12

INPV (2013$ millions) 586.6 543.1 465.2 

Change in INPV (2013$ millions) ‐ ‐43.5 ‐121.4 

(%) ‐ ‐7.4% ‐20.7% 

Product Conversion Costs (2013$ millions) ‐ 38.3 61.7 Capital Conversion Costs (2013$ millions) ‐ 35.4 219.7 Total Conversion Costs (2013$ millions) ‐ 73.7 281.4 

Units Base Case

Trial Standard Level

12

INPV (2013$ millions) 586.6 541.8 382.9 

Change in INPV (2013$ millions) ‐ ‐44.7 ‐203.7 

(%) ‐ ‐7.6% ‐34.7% 

Product Conversion Costs (2013$ millions) ‐ 38.3 61.7 Capital Conversion Costs (2013$ millions) ‐ 35.4 219.7 Total Conversion Costs (2013$ millions) ‐ 73.7 281.4 
90

Request for CommentDetails of the Manufacturer Impact Analysis can be found in chapter 12 of the TSDIssue 9: As part of the MIA, DOE estimates the product and capita

conversion costs that all manufacturers must make to comply with

potential standards. DOE requests comment on the product indus

conversion costs and capital industry conversion costs necessary fo

manufacturers to comply with the proposed standards.
91

Request for CommentDetails of the Manufacturer Impact Analysis can be found in chapter 12 of the TSD

Issue 10: DOE quantitatively assessed the impacts of standards on 

employment. DOE seeks comment on the potential domestic

employment impacts to DW manufacturers at the proposed effica

levels.

Issue 11: DOE seeks comment on the compliance costs of any othe

regulations DW manufacturers must make, especially if those

regulations take place three years before or after the estimated

compliance date of these proposed standards (2019).
92

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy &Water Use Analysis

Manufacturer Impact Analysis

NOPR Final Rule 

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis
93

Consumer Subgroup Analysis• Purpose

– Evaluate the economic impacts of standards on consumer s

who may be disproportionately impacted compared with t

user population.

• Method

– Identify senior‐only and low‐income households.

• Results

– LCC and PBP results were not appreciably different than fo

population.
94

• Purpose

– Estimate the emissions reductions resulting from amended 

conservation standards.

– Includes estimating considers full‐fuel‐cycle emissions; bot

emissions and “upstream” emissions.

– Includes fugitive methane emissions.

• Method

– Provide from National Impact Analysis an annual time‐serie

savings over the analysis period.

– Use Energy Information Administration’s National Energy M

System (NEMS) to represent the impacts of amended stand

Emissions Analysis
95

Emissions Analysis: Results

TSL 1 TSL 2 

CO2 (million metric tons) 0.30 61.86 

NOx (thousand tons) 3.44 126.66 

SO2 (thousand tons) ‐0.42 42.93 

Hg (tons) ‐0.001 0.13 

N2O (thousand tons) ‐0.005 0.74 

CH4 (thousand tons) 7.05 345.12 
96

Emission Monetization Analysis• Use the most current Social Cost of Carbon (SCC) values develo

interagency process.

– SCC is intended to be a monetary measure of the incremental dam

from greenhouse gas (GHG) emissions, including, but not limited 

productivity loss, human health effects, property damage from ris

and changes in the ecosystem.

• Use the most recent (2013) U.S. government interagency estim

SCC for emissions in 2015, per metric ton avoided (in 2013$):

– $12.0 (average value from distribution with a 5% discount rate)

– $40.5 (average value from distribution with a 3% discount rate)

– $62.4 (average value from distribution with a 2.5% discount rate)

– $119 (95th‐percentile value from distribution with a 3% discount 

• Report the SCC in constant dollars as increased over time.

• Monetize the NOx emissions reductions resulting from amende

– Estimates of monetary value range from $476 to $4,893 per short 

– DOE calculated monetary benefits using a medium value of $2,68
97

Emission Monetization Analysis: Results

TSL 1 TSL 2 TS

CO2 2.3 to 31.3 427.4 to 6,114.5 963.8 to 

NOx 3 % discount rate 4.9 173.3 40

NOx 7 % discount rate 2.4 79.2 17

Full Fuel Cycle Emissions Reduction Benefits (million 
98

Request for Comment

Issue 12: DOE requests comment on the application of the n

values used to determine the social benefits of CO2 emission

reductions over the rulemaking analysis period. In particular

agency solicits comment on its derivation of SCC values after 

where the agency applied the average annual growth rate of 

estimates in 2040–2050 associated with each of the four set
99

Utility Impact Analysis• Purpose

– Estimate the changes in electric installed capacity and gene

result from amended energy conservation standards.

• Method

– Provide from National Impact Analysis an annual time‐serie

savings over the analysis period.

– Use Energy Information Administration’s National Energy M

System (NEMS) to represent the impacts of amended stand

• Output

– Reductions in total electricity generation.

– Reductions in primary fuel (e.g. coal, natural gas) consump

– Changes to the mix of electricity generation by fuel type.

– Changes to total installed capacity.
100

Employment Impact Analysis• Purpose

– Estimate the national net impact on jobs as a consequence 

energy conservation standards, including indirect employm

• Method

– Use the ImSET (Impact of Sector Energy Technologies) mod

evaluation of indirect employment impacts; direct employm

to the commercial air conditioning industry are developed 

Manufacturer Impact Analysis.

– Input into ImSET the changes in national equipment and en

expenditures from the National Impact Analysis.

• Results

– Net labor market impacts are negligible over time due to th

magnitude of the short‐term effects.
101

Regulatory Impact Analysis• Purpose

– Investigate the national impacts of non‐regulatory alternat

mandatory amended energy conservation standards.

• Method

– Modify the NIA spreadsheet to analyze the following non‐r

alternatives and their impact on purchase price and energy 

use.

– Output– National Energy Savings and Net Present Value for the non

alternatives.

• No new regulatory action • Manufacturer tax credits

• Consumer rebates • Voluntary efficiency targets

• Consumer tax credits • Bulk government procureme
102

How to Submit Written Comments

In all correspondence, please refer to this rulemaking by:

– Standards for Residential Dishwashers

– Docket Number EERE‐2014‐BT‐STD‐0021

– Regulation Identification Number (RIN) 1904‐AD24

Email: ResDishwashers2014STD0021@ee.doe.gov

Postal: CourierMs. Brenda Edwards Ms. Brenda Edwards

U.S. Department of Energy U.S. Department of Energy

Building Technologies Program, Building Technologies Prog

Mailstop EE‐5B 950 L’Enfant Plaza, SW

1000 Independence Avenue, SW Washington, DC 20024

Washington, DC 20585‐0121 Tel: 202 586‐2945

Comment period closes February 17, 2015, 11:59