CHAPTER 1. INTRODUCTION 

TABLE OF CONTENTS 

1.1 PURPOSE OF THE DOCUMENT ................................................................................. 1-1 

1.2 OVERVIEW OF STANDARDS FOR RESIDENTIAL DISHWASHERS, 

DEHUMIDIFIERS, AND COOKING PRODUCTS, AND COMMERCIAL 

CLOTHES WASHERS ................................................................................................... 1-1 

1.3 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS...................... 1-2 

1.4 STRUCTURE OF THE DOCUMENT............................................................................ 1-6 

LIST OF TABLES 

Table 1.3.1 Analyses Under the Process Rule ........................................................................ 1-5 

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CHAPTER 1. INTRODUCTION 

1.1 PURPOSE OF THE DOCUMENT 

This technical support document (TSD) is a stand-alone report that provides the technical 

analyses and results in support of the information presented in the advance notice of proposed 

rulemaking (ANOPR) for residential dishwashers, dehumidifiers, and cooking products, and 

commercial clothes washers (also referred to as “the considered products”). 

1.2 OVERVIEW OF STANDARDS FOR RESIDENTIAL DISHWASHERS, 

DEHUMIDIFIERS, AND COOKING PRODUCTS, AND COMMERCIAL 

CLOTHES WASHERS 

The Energy Policy and Conservation Act (EPCA) of 1975 (42 U.S.C. 6291–6309) 

established an energy conservation program for major household appliances. The National 

Energy Conservation Policy Act of 1978 (NECPA) amended EPCA to add Part C of Title III (42 

U.S.C. 6311–6317), which established an energy conservation program for certain industrial 

equipment. Additional amendments to EPCA have given the Department of Energy (DOE) the 

authority to regulate the energy efficiency of several products, including residential dishwashers, 

dehumidifiers, and cooking products, and commercial clothes washers—the products that are the 

focus of this document. The amendments to EPCA in the National Appliance Energy 

Conservation Act of 1987 (NAECA) established prescriptive energy conservation standards for 

dishwashers and cooking products, as well as requirements for determining whether these 

standards should be amended. (42 U.S.C. 6291–6309) The amendments to EPCA in the Energy 

Policy Act of 2005 (EPACT 2005), P.L. 109-58, included provisions that expanded DOE’s 

energy conservation program to include certain residential products and commercial equipment, 

including dehumidifiers and commercial clothes washers. 

NAECA established prescriptive standards for gas cooking products, requiring gas ranges 

and ovens with an electrical supply cord not to be equipped with constant burning pilots, and 

directed DOE to conduct two cycles of rulemakings to determine if more stringent standards are 

justified.a

 (42 U.S.C. 6295 (h)(1)-(2)) DOE initially analyzed standards for cooking products as 

part of an eight-product standards rulemaking. It issued a notice of proposed rulemaking 

(NOPR) on March 4, 1994, proposing performance standards for gas and electric residential 

cooking products, including microwave ovens. 59 FR 10464. In accordance with the July 15, 

1996, Procedures for Consideration of New or Revised Energy Conservation Standards for 

Consumer Products (the “Process Rule”), 61 FR 36974 (July 15, 1996), DOE refined its 

standards analysis of cooking products. With regard to gas cooking products, DOE focused on 

a DOE is required to conduct two cycles of rulemakings for both gas and electric cooking products. 

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the economic justification for eliminating standing pilots. Partially due to the difficulty of 

conclusively demonstrating that elimination of standing pilots was economically justified, DOE 

issued a final rule on September 8, 1998, that covered only electric cooking products, including 

microwave ovens. 63 FR 48038. The final rule found that no standards were justified for 

electric cooking products. DOE never completed its standards rulemaking for gas cooking 

products. 

NAECA also established prescriptive standards for dishwashers, requiring that they be 

equipped with an option to dry without heat, and further required that DOE conduct two cycles 

of rulemakings to determine if more stringent standards are justified. (42 U.S.C. 6295 (g)(1), 

(4), and (5)) On May 14, 1991, DOE issued a final rule establishing the first set of performance 

standards for dishwashers; the new standards became effective on May 14, 1994. 56 FR 22250. 

DOE initiated a second standards rulemaking for dishwashers by issuing an ANOPR on 

November 14, 1994. 59 FR 56423. As a result of the priority-setting process outlined in the 

Process Rule, DOE suspended the standards rulemaking for dishwashers. 

Dehumidifiers are new products covered by EPACT 2005, which established standards 

for these products with an effective date of October 1, 2007. (Section 135(c)(4)) EPACT 2005 

also requires that DOE issue a final rule by October 1, 2009, to determine whether these 

standards should be amended. If amended standards are justified, EPACT 2005 requires them to 

become effective by October 1, 2012. In the event that DOE fails to publish a final rule, EPACT 

2005 specifies a new set of amended standards with an effective date of October 1, 2012. 

Like dehumidifiers, commercial clothes washers are new products covered by EPACT 

2005. EPACT 2005 established standards for commercial clothes washers with an effective date 

of January 1, 2007. (Section 136(e)) EPACT 2005 also requires that DOE issue a final rule by 

January 1, 2010, to determine whether these standards should be amended. 

1.3 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS 

Under EPCA, when DOE is studying new or amended standards, it must consider, to the 

greatest extent practicable, the following seven factors (42 U.S.C. 6295 (o)(2)(B)(i)): 

1) the economic impact of the standard on the manufacturers and consumers of the affected 

products; 

2) the savings in operating costs throughout the estimated average life of the product 

compared to any increases in the initial cost or maintenance expense; 

3) the total projected amount of energy savings likely to result directly from the imposition 

of the standard; 

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4) any lessening of the utility or the performance of the products likely to result from the 

imposition of the standard; 

5) the impact of any lessening of competition, as determined in writing by the Attorney 

General, that is likely to result from the imposition of the standard; 

6) the need for national energy conservation; and 

7) other factors the Secretary considers relevant. 

Other statutory requirements are set forth in 42 U.S.C. 6295 (o)(1)–(2)(A), (2)(B)(ii)– 

(iii), and (3)–(4) and 42 U.S.C. 6316(e). 

DOE considers stakeholder participation to be a very important part of the process for 

setting energy conservation standards. Through formal public notifications (i.e., Federal 

Register notices), DOE actively encourages the participation and interaction of all stakeholders 

during the comment period in each stage of the rulemaking. Beginning with the Framework 

Document and during subsequent comment periods, interactions among stakeholders provide a 

balanced discussion of the information that is required for the standards rulemaking. 

For this rulemaking, DOE will employ the procedures set forth in the Process Rule, to the 

extent they are appropriate for the development of energy conservation standards for the 

considered products. The Process Rule greatly enhances opportunities for public input and 

improved analytic approaches, and encourages adoption of consensus-based standards. The 

Process Rule provides policies and guidelines for early public review and consultation with 

interested parties with regard to identifying and screening design options, selecting a proposed 

standard, and establishing the final standard. The factors for screening design options include: 

(1) technological feasibility; (2) practicability to manufacture, install, and service; (3) adverse 

impacts on product utility or product availability; and (4) adverse impacts on health or safety 

(Process Rule at section 4(a)(4)). 61 FR 36982. 

The Process Rule requires DOE to evaluate uncertainty and variability through the use of 

scenario or probability analysis, and provides for review by experts and interested parties of the 

analyses used, including: (1) qualitative and quantitative analytical methods; (2) economic, 

engineering, and life-cycle cost (LCC) analyses; and (3) impacts on manufacturers and 

consumers, national energy savings, the economy, and the environment. Although the Process 

Rule specifically applies only to the development of energy-efficiency standards for consumer 

products, DOE has decided to apply its procedures to the development of energy conservation 

standards for commercial and industrial equipment as well. See appendix A to subpart C of Title 

10 of the Code of Federal Regulations Part 430 (10 CFR Part 430). 

Before DOE determines whether or not to adopt a proposed energy conservation 

standard, it must first solicit comments on the proposed standard. (42 U.S.C. 6313(a)(6)(B)(i)) 

Any new or amended standard must be designed to achieve significant additional conservation of 

energy and be technologically feasible and economically justified. (42 U.S.C. 6313(a)(6)(A)) 

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To determine whether economic justification exists, DOE must review comments on the 

proposal and determine that the benefits of the proposed standard exceed its burdens to the 

greatest extent practicable, weighing the seven factors listed above. (42 U.S.C. 6295 

(o)(2)(B)(i)) 

After the publication of the Framework Document, the standards rulemaking process 

involves three additional formal, major public notices, which DOE publishes in the Federal 

Register. The first of the rulemaking notices is an ANOPR, which is designed to publicly vet the 

models and tools used in the rulemaking, and to facilitate public participation before the 

proposed rule stage. The second notice is a NOPR, which presents a discussion of comments 

received in response to the ANOPR; analysis of the impacts of standards on consumers, 

manufacturers, and the nation; DOE’s weighting of these impacts; and the proposed standards. 

The third notice is the final rule, which presents a discussion of comments received in response 

to the NOPR; the revised analysis of the impacts of standards; DOE’s weighting of these 

impacts; the standards DOE is adopting; and the effective dates of the standards. 

In April, 2006, DOE published a Rulemaking Framework for Commercial Clothes 

Washers and Residential Dishwashers, Dehumidifiers, and Cooking Products, describing the 

procedural and analytical approaches DOE anticipated using to evaluate the establishment of 

energy conservation standards for these products. This document is available at 

http://www.eere.energy.gov/buildings/appliance_standards/. 

DOE held a public meeting on April 27, 2006, to discuss procedural and analytical 

approaches to the rulemaking, and to inform and facilitate stakeholders’ involvement in the 

rulemaking process. The analytical framework presented at the public meeting described 

different analyses, such as the engineering analysis and the LCC and payback period (PBP) 

analysis, the methods proposed for conducting them, and the relationships among the various 

analyses. Table 1.3.1 lists the analyses to be undertaken and reported in each of the formal 

public rulemaking documents. 

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Table 1.3.1 Analyses Under the Process Rule 

NOPR 

Market and technology assessment 

ANOPR Final Rule 

Revised ANOPR analyses Revised analyses 

Screening analysis Life-cycle cost sub-group 

analysis 

Engineering analysis Manufacturer impact analysis 

Energy and water use determination Utility impact analysis 

Markups for equipment price 

determination 

Environmental assessment 

Life-cycle cost and payback period 

analysis 

Employment impact analysis 

Shipments analysis Regulatory impact analysis 

National impact analysis 

Preliminary manufacturer impact analysis 

During the April, 2006, public meeting, stakeholders commented about the following 

issues related to the rulemaking: the existing DOE test procedure for microwave ovens; baseline 

unit definitions for the considered products; number of product classes for the considered 

products; consideration of limiting standby power as a design option for all four considered 

products; technology options for improving efficiency for all four considered products; type of 

approach to employ for the engineering analysis; efficiency levels to consider for all of the 

considered products; inclusion of water factor for dishwashers; consideration of cleaning 

performance in setting dishwasher standards; implications of clothes container volume on 

commercial clothes washer efficiency; proposed approaches for specifying typical annual energy 

and water consumption for all four considered products; potential data sources for characterizing 

variability in annual energy and water consumption; typical distribution channels and markups 

for the considered products; data sources for retail prices; type of approach to employ for the 

LCC and PBP analyses; variability of forecasted energy and water prices; repair, maintenance, 

and installation cost relationship to product efficiency; product lifetimes; development of 

consumer discount rates; purchase price impacts on product shipments; forecasted saturation 

rates of commercial clothes washers; consumer subgroups; water and wastewater utility impacts; 

and wastewater discharge impacts. 

Stakeholder comments submitted during the Framework Document comment period 

elaborated on the issues raised at the public meeting. DOE worked with its contractors to 

address these issues in the analyses. 

As part of the information gathering and sharing process, DOE organized and held 

interviews with manufacturers of the considered products. DOE selected companies that 

represented production of all types of equipment, ranging from small to large manufacturers, and 

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included both Association of Home Appliance Manufacturers (AHAM) member companies and 

non-AHAM member companies. DOE had four objectives for these interviews: (1) Solicit 

feedback on the draft engineering analysis (including methodology, production costs, 

manufacturing processes, and findings); (2) solicit feedback on topics related to the preliminary 

manufacturer impact analysis; (3) provide an opportunity, early in the rulemaking process, to 

express specific concerns to DOE; and (4) foster cooperation between the manufacturers and 

DOE. 

There were six general topics related to the preliminary manufacturer impact analysis 

discussed during each of the interviews: (1) general key issues; (2) shipment projections; (3) 

capital conversion costs; (4) product mix and profitability; (5) market shares and industry 

consolidation; and (6) cumulative regulatory burden. 

DOE incorporated the information gathered at the interviews into its engineering analysis 

(see Chapter 5) and the preliminary manufacturer impact analysis (see Chapter 12). Following 

the publication of the ANOPR and the ANOPR public meeting, DOE intends to hold additional 

meetings with manufacturers as part of the consultative process for the manufacturer impact 

analysis conducted during the NOPR phase of the rulemaking. 

DOE developed spreadsheets for the LCC, PBP, and national impact analyses for each of 

the considered products in an effort to meet the objectives of the Process Rule. For each product, 

DOE developed an LCC spreadsheet that calculates the LCC and PBP at various energyefficiency levels. DOE also developed a national impact analysis spreadsheet that calculates the 

national energy savings (NES) and national net present values (NPVs) at various energyefficiency levels. This spreadsheet includes a model that forecasts the impacts of energyefficiency standards at various levels on product shipments. All of these spreadsheets are 

available on the DOE website (http://www.eere.energy.gov/buildings/appliance_standards), 

within the specific pages for each of the considered products. 

1.4 STRUCTURE OF THE DOCUMENT 

This ANOPR TSD outlines the analytical approaches used in this rulemaking. The TSD 

consists of fourteen chapters, an environmental assessment, a regulatory impact analysis, and 

appendices. 

Chapter 1 Introduction: provides an overview of the appliance standards program 

and how it applies to this rulemaking, and outlines the structure of the 

document. 

Chapter 2 Analytical Framework: describes the rulemaking process. 

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Chapter 3 Market and Technology Assessment: characterizes the market for the 

considered products and the technologies available for increasing 

equipment efficiency. 

Chapter 4 Screening Analysis: identifies all the design options that improve 

efficiency of the considered products, and determines which technology 

design options are viable for consideration in the engineering analysis. 

Chapter 5 Engineering Analysis: discusses the methods used for developing the 

relationship between increased manufacturer price and increased 

efficiency. 

Chapter 6 Energy and Water Use Determination: discusses the process used for 

generating energy- and water-use estimates for the considered products 

as a function of standard levels. 

Chapter 7 Markups for Equipment Price Determination: discusses the methods 

used for establishing markups for converting manufacturer prices to 

customer equipment prices. 

Chapter 8 Life-Cycle Cost and Payback Period Analysis: discusses the effects of 

standards on individual customers and users of the equipment and 

compares the LCC and PBP of equipment with and without higher 

efficiency standards. 

Chapter 9 Shipments Analysis: discusses the methods used for forecasting 

shipments with and without higher efficiency standards, including how 

equipment purchase decisions are economically influenced and how 

DOE models this relationship with econometric equations. 

Chapter 10 National Impact Analysis: discusses the methods used for forecasting 

national energy consumption and national economic impacts based on 

estimates of future equipment efficiency, new construction and building 

starts, and annual equipment sales in the absence and presence of higher 

efficiency standards. 

Chapter 11 Life-Cycle Cost Subgroup Analysis: discusses the effects of standards 

on different subgroups of consumers and compares the LCC and PBP of 

equipment with and without higher efficiency standards for these 

consumers. 

Chapter 12 Manufacturer Impact Analysis: discusses the effects of standards on the 

finances and profitability of equipment manufacturers. 

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Chapter 13 Utility Impact Analysis: discusses the effects of standards on electric 

and gas utilities. 

Chapter 14 Employment Impact Analysis: discusses the effects of standards on 

national employment. 

Environmental Assessment for Residential Dishwashers, Dehumidifiers, and Cooking 

Products, and Commercial Clothes Washers: discusses the effects of 

standards on three pollutants—sulfur dioxide (SO2), nitrogen oxides 

(NOx), and mercury—as well as carbon emissions. 

Regulatory Impact Analysis for Residential Dishwashers, Dehumidifiers, and Cooking 

Products, and Commercial Clothes Washers: discusses the impact of 

non-regulatory alternatives to efficiency standards. 

Appendix 5A AHAM Data Submittal: presents the data provided by AHAM to DOE 

for aggregated data collection of shipments, market share, incremental 

cost, and one-time manufacturer cost information as a function of 

efficiency level. 

Appendix 5B Manufacturer Interview Guides: presents questionnaires used to guide 

DOE interviews with residential dishwasher and dehumidifier, and 

commercial clothes washer manufacturers. 

Appendix 5C The Low-Volume Manufacturer: discusses the method for estimating the 

revenue and product mix impact on a low-production-volume 

commercial clothes washer. 

Appendix 6A Cooktops and Ovens: Determination of Energy-Using Components: 

discusses the method for determining the energy use by energy-using 

components of cooktops and ovens including cooking, ignition, selfcleaning, and clock energy. 

Appendix 8A User Instructions for LCC and PBP Spreadsheets: briefly describes the 

LCC and PBP spreadsheets for each of the considered products and 

provides brief user instructions on how to operate the spreadsheets. 

Appendix 8B Uncertainty and Variability: discusses how DOE uses uncertainty and 

variability to characterize the inputs to the LCC and PBP analysis. 

Appendix 8C Household Discount Rate Distributions: provides the probability 

distributions for various household debt classes and asset holdings used 

to develop discount rates for household appliances in the LCC analysis. 

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Appendix 9A Relative Price Elasticity of Demand for Appliances: describes the 

analysis that DOE conducted to determine the consumer sensitivity to 

appliance purchase price changes as well as operating cost changes and 

household income. 

Appendix 10A User Instructions for Shipments and NIA Spreadsheets: briefly 

describes the shipments and national impact analysis (NIA) spreadsheets 

for each of the considered products and provides brief user instructions 

on how to operate the spreadsheets. 

Appendix 10B National Equipment and Operating Costs: provides the components to 

the NPV for each of the considered products, namely, the present value 

of the equipment costs and the present value of the operating costs. 

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