#23.4

Technologies Unable to be Analyzed and Exempted Product

Classes (Issue #6)

n A number of product classes and technologies were excluded from the

engineering analysis for one or more of the following reasons:

• Data on consumer usage was unavailable, possibly indicating inapplicability of the test

procedure.

• Efficiency data was unavailable.

• Available data suggests that the efficiency benefits of a technology are negligible.

DOE invites comment on extending the analyses to these excluded

technologies. DOE seeks input on energy efficiency data and potential

limitations of existing test procedures.

20

EE-2006-STD-0127 COMMENT 23.4
#23.4

Technologies Unable to be Analyzed (Issue #6)

9.90"MIS "I'al Fa* F

Dishwashers None

Dehumidifiers Built-in hygrometer/humidistat

• Improved controls

• Improved defrost measures

• Improved flow-control devices

• Low-standby-loss controls

• Washable air filters

Cooking Products Thermostatically-controlled burners and insulation for gas cooktops

• Electronic controls, low-standby -loss controls, induction, and

insulation for electric cooktops

• Radiant burners for gas ovens

• Steam cooking for electric ovens

• Cooking sensors, dual magnetrons, improved ceramic stirrers, lowstandby-loss controls, modified waveguides , or added insulation for

microwave ovens

Commercial Clothes Washers Improved drum designs for horizontal-axis clothes washers

0 Low-standby-loss controls 91

EE-2006-STD-0127 COMMENT 23.4
#23.4

Engineering Analysis Methods and Approach

Method

AHAM Data

Review of Past TSD

Product Teardown

Product Testing

Manufacturer Interviews

Dishwashers

Efficiency-Level Approach

Dehumidifiers Commercial

Clothes Washers

Design-Option

Approach

Cooking

Products

22

EE-2006-STD-0127 COMMENT 23.4
#23.4

Efficiency-Level Approach

n Cost-efficiency curves were supplied to DOE by AHAM.

• Costs were provided on a shipment-weighted, industry-aggregated basis per efficiency level

• Data were not provided for product classes and/or efficiency levels representing fewer than

three manufacturers.

Direct material

Direct labor

Factory overhead

Depreciation

n Sales & marketing

n Research & development

n Building

n Tooling/Equipment

n Manufacturer interviews were conducted to further understand variability in

industry-supplied cost data.

n Efficiency-level approach was supported by reverse-engineering from which

additional cost-efficiency information was derived. 23

EE-2006-STD-0127 COMMENT 23.4
Reverse-Engineering Methodology

#23.4

24

EE-2006-STD-0127 COMMENT 23.4
#23.4

Design-Option Approach

Develop

Baseline

ng Analysis

n Define baseline specifications for each product class

n Implement design options one-by-one in order of shortest

payback to longest payback

Calculate Cost n

Increments and

EF

Generate CostEfficiency

Curves/

Determine the cumulative incremental cost of each design

option relative to the baseline and recalculate EF with design

options in place

n Generate cost-efficiency curves , which account for full

production costs

25

EE-2006-STD-0127 COMMENT 23.4
Dishwashers : Incremental Efficiency Levels

Efficiency

Level

Efficiency Level Source

•

•

Baseline Current Federal Standard 0.62 0.46

1 Energy Star (prior to January 1, 2007) (scaled for

compact) 0.78 0.58

2 CEE Tier 1 (2006) (scaled for compact) 0.84 0.62

3 Energy Star (January 1, 2007) 0.88 0.65

4 CEE Tier 2 (2006) (scaled for compact) 0.92 0.68

5 Gap Fill 1.01 0.72

6 Gap Fill 1. 08 0.80

7 Maximum Available 1.74 1.11

26

EE-2006-STD-0127 COMMENT 23.4
Dishwashers : Cost-Efficiency Relationship

n AHAM provided incremental manufacturing cost data for standard

dishwashers at efficiency levels up to and including EF = 0.72.

n DOE validated this data with testing and reverse-engineering of several

dishwasher platforms.

n DOE's analysis showed reasonable agreement with industry-supplied

data, even though only a limited number of platforms were analyzed.

n Based on this validation, a cost-efficiency curve was generated for

standard dishwashers up to the maximum available level.

27

EE-2006-STD-0127 COMMENT 23.4
#23.4

........................

Dishwashers: Extending Analyses to the Compact Product

Class (Issue #4)

n DOE conducted full engineering analysis on standard -size dishwashers.

n DOE scaled efficiency levels for compact dishwashers from standard-size

dishwashers, using baseline from existing efficiency standard and max

available from Energy Star database.

n Fewer than 3 manufacturers produce compact-sized dishwashers, so cost

data is unavailable for confidentiality reasons.

DOE invites comment on extending the analyses to compact

dishwashers.

28

EE-2006-STD-0127 COMMENT 23.4
#23.4

Dishwashers: Use of an Annual Energy Consumption Metric,

Incorporating Standby Power

n The dishwasher test procedure includes a measurement of standby power,

but standby is not included in the EF metric.

n AHAM did not supply standby power data, but the LCC analysis accounts

for standby power in the calculation of annual energy consumption.

n DOE recommends that if standby power is determined to be a significant

source of energy savings , that it be incorporated in an annual energy

usage metric.

n An annual energy usage metric would allow manufacturers flexibility in

specifying features and design options.

DOE invites comment on the specification of annual energy usage as the

metric for dishwasher standards, rather than a prescriptive standard for

standby power alone.

29

EE-2006-STD-0127 COMMENT 23.4
#23.4

Dehumidifiers: Consolidation of Product Classes for

Analysis

n A subset of the product classes defined by EPACT 2005 was analyzed,

based on industry-supplied data.

25.00 Pints/Day or Less C

25.01 - 35.00 Pints/Day p

35.01 - 45.00 Pints/Day

45.01 - 54.00 Pints/Day N

54.01 - 74.99 Pints/Day

75.00 Pints/Day or More N

ombine

roduct c

o data supplied

o data supplied

oduct Classes

Analyzed

0 - 35.00 Pints/Day

35.01 - 45.00 Pints/Day

54.01 - 74.99 Pints/Day

30

EE-2006-STD-0127 COMMENT 23.4
#23.4

Dehumidifiers : Incremental Efficiency Levels

Efficiency

Level Efficiency Level Source 35.01-45.00 54. 0 1-74. 99

pints/day pints/day

Current Federal Standard Baseline (effective 2007) 1.20 1.30 1.50

1 Gap Fill 1.25 1.35 1.55

2 Default 2012 Standard

(EPACT 2005) 1.30 1.40 1.60

3 Gap Fill 1.35 1.45 1.65

4 Gap Fill 1.40 1.50 1.70

5 Maximum Available 1.45 1.74 1.80

31

EE-2006-STD-0127 COMMENT 23.4
#23.4

Dehumidifiers: Cost-Efficiency Relationship

n AHAM provided incremental manufacturing cost data for the three product

classes analyzed.

n DOE validated this data with reverse -engineering, with units chosen to

span the range of efficiencies within each product class.

n DOE's analysis showed reasonable agreement with industry-supplied

data.

n Based on this validation , cost-efficiency curves were generated for the

three product classes.

32

EE-2006-STD-0127 COMMENT 23.4
#23.4

Cooking Products : Implementation of the Design Option

Approach

n Previous rulemaking (1996 Technical Support Document for Residential

Cooking Products) identified incremental efficiencies and manufacturing

costs associated with each design option.

n For this analysis, DOE assumed, with stakeholder concurrence, that for

each design option that passed the screening analysis:

• The incremental efficiency remained the same as in the 1996 TSD.

• The incremental manufacturing cost from 1996 TSD (in 1990 $) must be scaled by the

Producer Price Index (PPI) for the appropriate appliance category:

Category

Electric Cooking Products

Gas Cooking Products

PPI 2006/PPI 1990

93.7%

93.9%

33

EE-2006-STD-0127 COMMENT 23.4
#23.4

Cooking Products : Cooktop Incremental Efficiency

Levels

Efficiency Level

Baseline 0.156 0.737 0.742

1 0.399 0.769 0.753

2 0.420

34

EE-2006-STD-0127 COMMENT 23.4
#23.4

Cooking Products: Oven Incremental Efficiency Levels

'ergy Factor

11111111111111111

Gas, Gas, Self- Electric, Electric,

standard ci^ Self- Microwave

Baseline 0.0298 0.054 0. 1066 0.1099 0.557

1 0.0536 0.0625 0.1113 0.1102 0.586

2 0.0566 0. 0627 0.1163 0.1123 0.588

3 0.0572 0. 0632 0.1181 0.597

4 0.0593 0.1206 0.602

5 0.0596 0.1209

6 0.0600

la 0.0583

35

EE-2006-STD-0127 COMMENT 23.4
#23.4

Cooking Products: AHAM Microwave Oven Efficiency

Data Submittal

63.0

62.0

61.0

60.0

57.0

56.0

55.0 55.0

54.0 54.0 1

600.0 700.0 800.0 900.0 1000.0 1100.0 1200.0 13C 0.5 0.7 0.9 1.1 1.3 1.5 1.7 1.9 2.1 2.3

Measured Output Power (W) Cavity Volume (cubic feet)

n The data failed to demonstrate any correlation between efficiency and

characteristic microwave oven parameters , including output power or cavity

volume.

•

•

♦ •

♦ ♦

♦

♦ ♦ •

♦ ♦

•

60.0 -

59.0 . i

w •

58.0

57.0

63.0 .___.__._-.__._ _

62.0

61.0 -

n These data and the updated cost-efficiency analysis from the 1996 TSD were

validated through additional microwave oven testing conducted by DOE. 36

EE-2006-STD-0127 COMMENT 23.4
#23.4

Microwave Oven Design Options (Issue #5)

n Microwave oven design options and efficiency levels analyzed were

derived from those in the 1996 TSD.

n DOE received stakeholder comments that, unlike for other cooking

products, microwave oven technology has changed significantly since the

previous rulemaking.

n DOE believes that most design options implemented since the previous

rulemaking are intended to enhance consumer utility rather than improve

energy efficiency.

DOE invites comment on microwave oven design options that impact

annual energy consumption, including those that are not currently

measured by the test procedure.

37

EE-2006-STD-0127 COMMENT 23.4
#23.4

Cooking Products: AHAM Microwave Oven Standby

Power Data Submittal

n Measurements were made with a starting clock setting of 12:00.

n Data demonstrate a wide range of values.

n MWOs with cooking sensors tend to consume higher standby power.

7

q • No Sensor

q Sensor

5 -I

4

3

2

0

1 - -

0

600.0 700.0 800.0 900.0 1000.0 1100.0 1200.0 1300.0

Measured Output Power (W)

38

EE-2006-STD-0127 COMMENT 23.4