CHAPTER 1. INTRODUCTION 

TABLE OF CONTENTS 

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

1.2	 SUMMARY OF NATIONAL BENEFITS .........................................................................1-1
 

1.3	 OVERVIEW OF STANDARDS FOR RESIDENTIAL CLOTHES DRYERS
 

AND ROOM AIR CONDITIONERS .................................................................................1-6
 

1.4	 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS .....................1-8
 

1.5	 STRUCTURE OF THE DOCUMENT............................................................................. 1-11
 

LIST OF TABLES 

Table 1.2.1 Annualized Benefits and Costs of Amended Standards (TSL 4) for Clothes 

Dryers for 2014–2043 Period...................................................................................1-4
 

Table 1.2.2 Annualized Benefits and Costs of Amended Standards (TSL 4) for Room
 

Air Conditioners for 2014–2043 Period..................................................................1-5
 

Table 1.4.1 Analyses Under the Process Rule* ....................................................................... 1-10
 

1-i 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 supporting the information presented in the direct final rule (DFR) for 

residential clothes dryers and room air conditioners. This TSD reports on the activities and 

analyses conducted in support of the DFR. 

1.2 SUMMARY OF NATIONAL BENEFITS 

DOE’s analyses indicate that the standards for residential clothes dryers and room air 

conditioners would save a significant amount of energy over 30 years (2014–2043)―an 

estimated 0.39 quads of cumulative energy for clothes dryers and 0.31 quads of cumulative 

energy for room air conditioners. The combined total, 0.70 quads, is equivalent to three-fourths 

of the estimated amount of energy used in 2008 to dry clothes in all U.S. homes. In addition, 

DOE expects the energy savings from today’s standards to eliminate the need for approximately 

0.98 gigawatts (GW) of generating capacity by 2043. 

The cumulative national net present value (NPV) of total consumer costs and savings of 

today’s standards in 2009$ ranges from $1.08 billion (at a 7-percent discount rate) to $3.01 

billion (at a 3-percent discount rate) for clothes dryers, and from $0.57 billion (at a 7-percent 

discount rate) to $1.47 billion (at a 3-percent discount rate) for room air conditioners. This NPV 

expresses the estimated total value of future operating-cost savings minus the estimated 

increased product costs for products purchased in 2014–2043, discounted to 2011. 

In addition, the standards would have significant environmental benefits. The energy 

savings would result in cumulative greenhouse gas emission reductions of approximately 36.1 

million metric tons (Mt) of carbon dioxide (CO2) from 2014 to 2043. During this period, the 

standards would also result in emissions reductions of approximately 29.3 thousand tons of 

nitrogen oxides (NOX) and 0.073 ton of mercury (Hg). DOE estimates that the net present 

monetary value of the CO2 emissions reductions is between $170 and $2,654 million, expressed 

in 2009$ and discounted to 2011. DOE also estimates that the net present monetary value of the 

NOX emissions reductions, expressed in 2009$ and discounted to 2011, is $4.3 to $43.8 million 

at a 7-percent discount rate, and $8.9 to $91.7 million at a 3-percent discount rate. 

The benefits and costs of the standards can also be expressed in terms of annualized 

values over the 2014–2043 period. The annualized monetary values are the sum of (1) the 

annualized national economic value, expressed in 2009$, of the benefits from operating the 

product (consisting primarily of operating cost savings from using less energy, minus increases 

in equipment purchase costs, which is another way of representing consumer NPV), plus (2) the 

1-1 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

monetary value of the benefits of emission reductions, including CO2 emission reductions.a The 

value of the CO2 reductions is otherwise known as the Social Cost of Carbon (SCC), and is 

calculated using a range of values per metric ton of CO2 developed by a recent interagency 

process. The monetary benefits of cumulative emissions reductions are reported in 2009$ so that 

they can be compared with the other costs and benefits in the same dollar units. The derivation of 

the SCC values is discussed in chapter 16. 

Although adding the value of consumer savings to the values of emission reductions 

provides a valuable perspective, two issues should be considered. First, the national operating 

cost savings are domestic U.S. consumer monetary savings that occur as a result of market 

transactions, while the value of CO2 reductions is based on a global value. Second, the 

assessments of operating cost savings and CO2 savings are performed with different methods that 

use quite different time frames for analysis. The national operating cost savings is measured for 

the lifetime of products shipped in 2014–2043. The SCC values, on the other hand, reflect the 

present value of future climate-related impacts resulting from the emission of one ton of carbon 

dioxide in each year. These impacts go well beyond 2100. 

Table 1.2.1 shows the annualized values for the clothes dryer standards. Using a 7­

percent discount rate and the SCC value of $22.1/ton in 2010 (in 2009$), the cost of the 

standards for clothes dryers in today’s rule is $52.3 million per year in increased equipment 

costs, while the annualized benefits are $139.1 million per year in reduced equipment operating 

costs, $25.0 million in CO2 reductions, and $0.9 million in reduced NOX emissions. In this case, 

the net benefit amounts to $112.7 million per year. Using a 3-percent discount rate and the SCC 

value of $22.1/ton in 2010 (in 2009$), the cost of the standards for clothes dryers in today’s rule 

is $55.4 million per year in increased equipment costs, while the benefits are $209.1 million per 

year in reduced operating costs, $25.0 million in CO2 reductions, and $1.4 million in reduced 

NOX emissions. In this case, the net benefit amounts to $180.1 million per year. 

Table 1.2.2 shows the annualized values for the room air conditioner standards. Using a 

7-percent discount rate and the SCC value of $22.1/ton in 2010 (in 2009$), the cost of the 

standards for room air conditioners in today’s rule is $107.7 million per year in increased 

equipment costs, while the annualized benefits are $153.7 million per year in reduced equipment 

operating costs, $19.5 million in CO2 reductions, and $0.999 million in reduced NOX emissions. 

In this case, the net benefit amounts to $66.4 million per year. Using a 3-percent discount rate 

and the SCC value of $22.1/ton in 2010 (in 2009$), the cost of the standards for room air 

conditioners in today’s rule is $111.0 million per year in increased equipment costs, while the 

benefits are $186.2 million per year in reduced operating costs, $19.5 million in CO2 reductions, 

a

 DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized values. 

First, DOE calculated a present value for the time-series of costs and benefits using a discount rate of either three or 

seven percent. From the present value, DOE then calculated the fixed annual payment over the analysis time period 

(2014 through 2043) that yielded the same present value. The fixed annual payment is the annualized value. 

Although DOE calculated annualized values, this does not imply that the time-series of cost and benefits from which 

the annualized values were determined is a steady stream of payments. 

1-2 

and $1.20 million in reduced NOX emissions. In this case, the net benefit amounts to $95.9 

million per year. 

1-3 

 

 

 

 

 

 

 

 

 

 

Table 1.2.1 Annualized Benefits and Costs of Amended Standards (TSL 4) for 

Clothes Dryers for 2014–2043 Period 

Discount Rate 

Primary 

Estimate* 

Low 

Estimate* 

High 

Estimate* 

Monetized (million 2009$/year) 

Benefits 

Operating Cost Savings 

7% 139.1 120.6 158.3 

3% 209.1 177.4 241.3 

CO2 Reduction at $4.9/t** 5% 6.0 6.0 6.0 

CO2 Reduction at $22.1/t** 3% 25.0 25.0 25.0 

CO2 Reduction at $36.3/t** 2.5% 39.8 39.8 39.8 

CO2 Reduction at $67.1/t** 3% 76.0 76.0 76.0 

NOX Reduction at 

$2,519/ton** 

7% 0.9 0.9 0.9 

3% 1.4 1.4 1.4 

Total† 

7% plus CO2 range 146.1 to 216.1 127.6 to 197.6 165.3 to 235.3 

7% 165.0 146.5 184.3 

3% 235.4 203.7 267.6 

3% plus CO2 range 216.5 to 286.5 184.8 to 254.8 248.7 to 318.7 

Costs 

Incremental Product Costs 

7% 52.3 48.8 55.9 

3% 55.4 51.2 59.6 

Net Benefits 

Total† 

7% plus CO2 range 93.7 to 163.7 78.7 to 148.7 109.4 to 179.4 

7% 112.7 97.7 128.3 

3% 180.1 152.5 208.1 

3% plus CO2 range 161.1 to 231.1 133.6 to 203.6 189.1 to 259.1 

* The Primary, Low, and High Estimates utilize forecasts of energy prices and housing starts from the AEO2010 

Reference case, Low Economic Growth case, and Low Economic Growth case, respectively. 

** The CO2 values represent global values (in 2009$) of the social cost of CO2 emissions in 2010 under several 

scenarios. The values of $4.9, $22.1, and $36.3per metric ton are the averages of SCC distributions calculated using 

5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.1 per ton represents the 95th 

percentile of the SCC distribution calculated using a 3-percent discount rate. The value for NOX (in 2009$) is the 

average of the low and high values used in DOE’s analysis. 

† Total benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 3-percent 

discount rate, which is $22.1/ton in 2010 (in 2007$). In the rows labeled as “7% plus CO2 range” and “3% plus CO2 

range,” the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are 

added to the full range of CO2 values. 

1-4 

 

 

 

 

 

 

 

 

 

 

 

 

Table 1.2.2 Annualized Benefits and Costs of Amended Standards (TSL 4) for Room 

Air Conditioners for 2014–2043 Period 

Discount Rate 

Primary 

Estimate* 

Low 

Estimate* 

High 

Estimate* 

Monetized (million 2009$/year) 

Benefits 

Operating Cost Savings 

7% 153.7 145.1 161.9 

3% 186.2 174.2 197.3 

CO2 Reduction at $4.9/t** 5% 5.0 5.0 5.0 

CO2 Reduction at $22.1/t** 3% 19.5 19.5 19.5 

CO2 Reduction at $36.3/t** 2.5% 30.7 30.7 30.7 

CO2 Reduction at $67.1/t** 3% 59.4 59.4 59.4 

NOX Reduction at 

$2,519/ton** 

7% 0.999 0.999 0.999 

3% 1.197 1.197 1.197 

Total† 

7% plus CO2 range 159.6 to 214.0 151.1 to 205.5 167.9 to 222.3 

7% 174.1 165.5 182.4 

3% 206.8 194.9 218.0 

3% plus CO2 range 192.3 to 246.7 180.4 to 234.8 203.5 to 257.9 

Costs 

Incremental Product Costs 

7% 107.7 107.7 107.7 

3% 111.0 111.0 111.0 

Net Benefits 

Total† 

7% plus CO2 range 51.9 to 106.3 43.4 to 97.8 60.2 to 114.6 

7% 66.4 57.8 74.7 

3% 95.9 83.9 107.0 

3% plus CO2 range 81.4 to 135.8 69.4 to 123.8 92.5 to 146.9 

* The Primary, Low, and High Estimates utilize forecasts of energy prices and housing starts from the AEO2010 

Reference case, Low Economic Growth case, and Low Economic Growth case, respectively. 

** The CO2 values represent global values (in 2009$) of the social cost of CO2 emissions in 2010 under several 

scenarios. The values of $4.9, $22.1, and $36.3 per metric ton are the averages of SCC distributions calculated using 

5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.1 per ton represents the 95th 

percentile of the SCC distribution calculated using a 3-percent discount rate. The value for NOX (in 2009$) is the 

average of the low and high values used in DOE’s analysis. 

† Total benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 3-percent 

discount rate, which is $22.1/ton in 2010 (in 2009$). In the rows labeled as “7% plus CO2 range” and “3% plus CO2 

range,” the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are 

added to the full range of CO2 values. 

1-5 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

1.3	 OVERVIEW OF STANDARDS FOR RESIDENTIAL CLOTHES DRYERS 

AND ROOM AIR CONDITIONERS 

The Energy Policy and Conservation Act (EPCA) of 1975, Pub. L. 94-163 (42 United 

States Code (U.S.C.) 6291–6309), established an energy conservation program for major 

household appliances. The National Energy Conservation Policy Act of 1978 (NECPA), Pub. L. 

95-619, amended EPCA to add Part Cb

 of Title III (42 U.S.C. 6311–6317), which established an 

energy conservation program for certain industrial equipment. Additional amendments to EPCA 

give DOE the authority to regulate the energy efficiency of several products, including 

residential clothes dryers and room air conditioners—the products that are the focus of this 

document. The amendments to EPCA in the National Appliance Energy Conservation Act of 

1987 (NAECA), Pub. L. 100-12, established energy conservation standards for room air 

conditioners, as well as requirements for determining whether these standards should be 

amended. (42 U.S.C. 6295(c) and (g)) 

DOE published draft data sheets containing energy-savings potentials for all covered 

products in October 2005 as part of its fiscal year 2006 schedule-setting process. These data 

sheets summarized the following in table format: (1) the potential energy savings from 

regulatory action in cumulative quads from 2010 to 2035, (2) the potential economic benefits or 

burdens, (3) the potential environmental or energy security benefits, (4) the status of required 

changes to test procedures, (5) other regulatory actions, (6) recommendations by interested 

parties, (7) evidence of market-driven or voluntary efficiency improvements, (8) regulatory 

issues, and (9) the 2005 priority. However, DOE had completed the calculations for residential 

clothes dryers and room air conditioners in previous years. Therefore, the following sections cite 

the appropriate fiscal year’s priority-setting activities for which DOE completed the energy 

savings calculations for each product. 

NAECA established prescriptive standards for residential clothes dryers, requiring gas 

clothes dryers not to be equipped with constant burning pilots, and further required that DOE 

conduct two cycles of rulemakings to determine if more stringent standards are justified.c

 (42 

U.S.C. 6295 (g)(3) and (4)) On May 14, 1991, DOE published a final rule in the Federal 

Register (FR) establishing the first set of performance standards for residential clothes dryers; 

the new standards became effective on May 14, 1994. 56 FR 22250. DOE initiated a second 

standards rulemaking for residential clothes dryers by publishing an advance notice of proposed 

rulemaking (ANOPR) in the Federal Register on November 14, 1994. 59 FR 56423. However, 

pursuant to the priority-setting process outlined in the July 15, 1996, “Procedures, Interpretations 

and Policies for Consideration of New or Revised Energy Conservation Standards for Consumer 

b

 Part C has been redesignated Part A-1 in the United States Code for editorial reasons. 

c DOE defines “electric clothes dryer” under EPCA as “a cabinet-like appliance designed to dry fabrics in a tumbletype drum with forced air circulation. The heat source is electricity and the drum and blower(s) are driven by an 

electric motor(s).” 10 CFR 430.2. Gas clothes dryers would have a similar definition, but the heat source would be 

gas. 

1-6 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Products”d (the “Process Rule”), DOE classified the standards rulemaking for residential clothes 

dryers as a low priority for its fiscal year 1998 priority-setting process. As a result, DOE 

suspended the standards rulemaking activities for them. 

As reported, DOE’s draft data sheets for the fiscal year 2006 schedule-setting process 

included an updated analysis suggesting that amended standards for residential clothes dryers 

would have an energy savings potential ranging from 1.6 to 4.8 quadrillion British thermal units 

(Btu), or “quads,” for electric clothes dryers and an energy savings potential of 0.06 quads for 

gas clothes dryers.e DOE based the low- and high-potential energy savings estimates for electric 

clothes dryers on the use of microwave and heat pump technologies, respectively. DOE is 

unaware of any commercially available microwave dryers that are currently for sale in any 

country. There are at least four manufacturers of heat pump dryers in Europe and Japanf

, but 

DOE is unaware of any such models on the market in the United States. 

NAECA established performance standards for room air conditioners that became 

effective on January 1, 1990, and directed DOE to conduct two cycles of rulemakings to 

determine if more stringent standards are justified.g

 (42 U.S.C. 6295 (c)(1) and (2)) On March 4, 

1994, DOE published in the Federal Register a notice of proposed rulemaking (NOPR) for 

several products, including room air conditioners. 59 FR 10464. As a result of the Process Rule, 

DOE suspended activities to finalize standards for room air conditioners. DOE subsequently 

resumed rulemaking activities related to room air conditioners, and, on September 24, 1997, 

DOE published a final rule establishing an updated set of performance standards, with an 

effective date of October 1, 2000. 62 FR 50122. 

As reported in DOE’s draft data sheets for the fiscal year 2006 schedule-setting process, 

amended standards for room air conditioners would be expected to have an energy savings 

potential ranging from 0.8 to 1.5 quads.h The low- and high-potential energy savings estimates 

corresponded to efficiency increases of 10 and 20 percent, respectively. 

d

 61 FR 36974 (July 15, 1996) (establishing 10 CFR part 430, subpart C, appendix A). 

e

 DOE based these estimates on the 2003 prioritization analysis, with a small adjustment for the 2010–2035 

timeframe. 

f Paul Roggema, “Sustainability in Home Appliances,” Appliance Magazine European Edition, May 2007, p. 5. 

Available online at: http://www.appliancemagazine.com/editorial.php?article=1747&zone=208&first=1. 

g DOE defines “room air conditioner” under EPCA as a “consumer product, other than a ‘packaged terminal air 

conditioner,’ which is powered by a single phase electric current and which is an encased assembly designed as a 

unit for mounting in a window or through the wall for the purpose of providing delivery of conditioned air to an 

enclosed space. It includes a prime source of refrigeration and may include a means for ventilating and heating.” 10 

CFR 430.2. 

h

 DOE based these energy savings estimates on an updated analysis of room air conditioners it conducted for its 

2005 priority setting. The spreadsheet is available from the DOE Building Technologies Program, Appliances and 

Commercial Equipment Standards website at: 

www.eere.energy.gov/buildings/appliance_standards/docs/2006_schedule_setting_spreadsheets.zip 

1-7 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

1.4 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS 

Under EPCA, when DOE studies 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; 

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. 

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)) 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 energy conservation standards 

rulemaking process involves three additional, formal public notices, which DOE publishes in the 

1-8 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Federal Register. The first of the rulemaking notices is a notice of public meeting (NOPM), 

which is designed to publicly vet the models and tools used in the preliminary rulemaking and to 

facilitate public participation before the NOPR stage. The second notice is the notice of proposed 

rulemaking (NOPR), which presents a discussion of comments received in response to the 

NOPM and the preliminary analyses and analytical tools; analyses of the impacts of potential 

amended energy conservation standards on consumers, manufacturers, and the Nation; DOE’s 

weighting of these impacts of amended energy conservation standards; and the proposed energy 

conservation standards for each product. The third notice is the final rule, which presents a 

discussion of the comments received in response to the NOPR; the revised analyses; DOE’s 

weighting of these impacts; the amended energy conservation standards DOE is adopting for 

each product; and the effective dates of the amended energy conservation standards. 

In October 2007, DOE published a NOPM and announced the availability of the 

framework document. 10 CFR 430 (October 9, 2007) The framework document, Rulemaking 

Framework Document for Residential Clothes Dryers and Room Air Conditioners, describes the 

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

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

http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/dryer_roomac_fra 

mework.pdf. 

Subsequently, DOE held a public meeting on October 24, 2007 (“October 2007 public 

meeting”) to discuss procedural and analytical approaches to the rulemaking. In addition, DOE 

used the public meeting to inform and facilitate involvement of interested parties in the 

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

different analyses, such as the engineering analysis and the consumer economic analyses (i.e., 

the life-cycle cost (LCC) and payback period (PBB) analyses), the methods proposed for 

conducting them, and the relationships among the various analyses. 

During the October 2007 public meeting, interested parties commented about numerous 

issues relating to each one of the analyses listed in Table 1.4.1. Comments from interested parties 

submitted during the framework document comment period elaborated on the issues raised 

during the public meeting. DOE attempted to address these issues during its preliminary analyses 

and summarized the comments and DOE’s responses in chapter 2 of the preliminary TSD. 

1-9 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 1.4.1 Analyses Under the Process Rule* 

Preliminary Analyses NOPR Final Rule 

Market and technology assessment Revised preliminary analyses Revised NOPR analyses 

Screening analysis Life-cycle cost sub-group 

analysis 

Engineering analysis Manufacturer impact analysis 

Energy use determination Utility impact analysis 

Markups for equipment price 

determination 

Life-cycle cost and payback period 

analysis 

Employment impact analysis 

Environmental assessment 

Shipments analysis Regulatory impact analysis 

National impact analysis 

Preliminary manufacturer impact analysis 

* In the current rulemaking DOE conducted the analyses listed under NOPR as part of the final rule analysis. 

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

interviews with manufacturers of the residential clothes dryers and room air conditioners 

considered in this rulemaking. DOE selected companies that represented production of all types 

of products, ranging from small to large manufacturers, and included the Association of Home 

Appliance Manufacturers (AHAM) member companies. DOE had four objectives for these 

interviews: (1) solicit manufacturer feedback on the draft inputs to the engineering analysis; (2) 

solicit feedback on topics related to the preliminary manufacturer impact analysis; (3) provide an 

opportunity, early in the rulemaking process, to express manufacturers’ concerns to DOE; and 

(4) foster cooperation between manufacturers and DOE. 

DOE incorporated the information gathered during the engineering interviews with 

manufacturers into its engineering analysis (chapter 5) and the preliminary manufacturer impact 

analysis (chapter 12). 

DOE developed spreadsheets for the engineering, LCC, PBP, and national impact 

analyses for each product. For each product, DOE developed an LCC spreadsheet that calculates 

the LCC and PBP at various energy efficiency levels. DOE also developed a national impact 

analysis spreadsheet that calculates the national energy savings (NES) and national net present 

values (NPVs) at various energy efficiency levels. This spreadsheet includes a model that 

forecasts the impacts of amended energy conservation standards at various levels on product 

shipments. All of these spreadsheets are available on the DOE website for residential clothes 

dryers and the DOE website for room air conditioners: 

(http://www1.eere.energy.gov/buildings/appliance_standards/residential/clothes_dryers.html, 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/room_ac.html). 

1-10 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

On February 23, 2010, DOE published the NOPM and availability of the preliminary 

TSD. 75 FR 7987. The preliminary TSD provides technical analyses and results that support the 

information presented in the preliminary NOPM and the executive summary for residential 

clothes dryers and room air conditioners. The preliminary TSD also provides a detailed 

description of all of the analyses discussed in the paragraphs above. The preliminary TSD is 

available on DOE’s website at: 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/preliminary_analysis_ts 

d.html. 

Following publication of the NOPM and the preliminary TSD, DOE held a public 

meeting on March 16, 2010 to facilitate discussion about the preliminary analyses that were 

performed for the NOPM and described in the preliminary TSD. In addition to the public 

meeting, a written comment period was open until April 26, 2010 to allow interested parties to 

provide new comments or elaborate on any comments made at the public meeting. 

On September 27, 2010, AHAM and the American Council for an Energy-Efficient 

Economy (ACEEE) jointly submitted on behalf of themselves and 26 manufacturers and 8 

energy efficiency advocates the “Joint Petition to Adopt Joint Stakeholder Agreement as it 

Relates to the Rulemaking on Energy Conservation Standards for Residential Clothes Dryers and 

Room Air Conditioners,” which included recommendations for amended energy conservation 

standards for residential clothes dryers and room air conditioners. After receiving this Petition as 

well as comments on the preliminary analysis, DOE determined it would consider the clothes 

dryer and room air conditioner energy conservation standards provided in the Petition as part of a 

direct final rule that updated the preliminary analyses based on inputs from these interested 

parties. DOE organized and held a second round of interviews with manufacturers to gather 

additional feedback on the analyses and to provide input to the manufacturer impact analysis that 

was conducted for the final rule. 

In addition to revising the various preliminary analyses, DOE also performed an LCC 

subgroup analysis, manufacturer impact analysis, utility impact analysis, employment impact 

analysis, and regulatory impact analysis for the final rule. 

1.5 STRUCTURE OF THE DOCUMENT 

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

17 chapters and associated 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. 

1-11 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 2 Analytical Framework: describes the rulemaking process. 

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

considered products and the technologies available for increasing 

product efficiency. 

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

efficiency of the considered products, and determines which technology 

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 Markups Analysis: discusses the methods used for establishing markups 

for converting manufacturer costs to customer retail prices. 

Chapter 7 Energy Use Analysis: discusses the process used for generating energyuse estimates for the considered products as a function of standard 

levels. 

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

standards on individual customers and users of the products and 

compares the LCC and PBP of products 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 

product 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 

annual product shipments and estimates of future product energy 

efficiency distributions in the absence and presence of amended energy 

conservation 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 

products 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 product manufacturers. 

1-12 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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. 

Chapter 15 Environmental Assessment: discusses the effects of standards on 

emissions of carbon dioxide (CO2), nitrogen oxides (NOx), and mercury. 

Chapter 16 Monetization of Emission Reductions Benefits: discusses the basis for 

the estimated monetary values used for the reduced emissions of CO2 

and other pollutants that are expected to result from each of the TSLs 

considered. 

Chapter 17 Regulatory Impact Analysis: discusses the impact of non-regulatory 

alternatives to efficiency standards. 

Appendix 5A AHAM Data Request Sheets 

Appendix 5B Data Submissions 

Appendix 5C Engineering Questionnaires 

Appendix 5D Room Air Conditioner Engineering Data 

Appendix 7A RECS 2005 Variables and Values 

Appendix 7B CBECS 2003 Variables and Values 

Appendix 7C LCC Energy Use Calculations 

Appendix 7D Weather and Temperature Parameters 

Appendix 8A User Instructions for LCC and PBP Spreadsheets 

Appendix 8B Uncertainty and Variability 

Appendix 8C Lifetime Distributions 

Appendix 8D Distributions Used for Discount Rates 

Appendix 8E Technical Aspects of the Tariff-Based Approach for Room Air 

Conditioner Energy Prices 

1-13 
 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix 8F Development of Monthly Allocation Factors for Residential Baseline 

Energy Use 

Appendix 8G Rebuttable Payback Analysis Results 

Appendix 8H Determination of Base-Case Efficiency Distributions 

Appendix 8I Life-Cycle Cost Analysis Using Alternative Energy Price Scenarios 

Appendix 8J Estimation of Equipment Price Trends for Residential Clothes Dryers 

and Room Air Conditioners 

Appendix 10A User Instructions for Shipments and National Energy Savings 

Spreadsheet Model 

Appendix 10B National Energy Savings and Net Present Value Using Alternative 

Energy Price Scenarios 

Appendix 10C National Net Present Value of Consumer Benefits and Emissions 

Reductions Using Alternative Learning Curves 

Appendix 12A Manufacturer Impact Analysis Interview Guides 

Appendix 12B Government Regulatory Impact Model (GRIM) Overview 

Appendix 15A Emissions Factors for Fuel Combustion from Natural Gas, LPG, and 

Oil-Fired Residential Appliances 

Appendix 16A Social Cost of Carbon for Regulatory Impact Analysis Under Executive 

Order 12866 

Appendix 17A Regulatory Impact Analysis: Supporting Materials 

1-14