APPENDIX 5A. AHAM DATA SUBMITTAL 

TABLE OF CONTENTS 

5A.1 INTRODUCTION .................................................................................................. 5A-1 

5A.2 AHAM DISHWASHER DATA SUBMITTAL ..................................................... 5A-1 

5A.2.1 AHAM Dishwasher Shipments and Incremental Cost Data................................... 5A-1 

5A.2.2 AHAM Narrative on Dishwasher Standby Energy Consumption .......................... 5A-3 

5A.3 AHAM DEHUMIDIFIER DATA SUBMITTAL .................................................. 5A-5 

5A.4 AHAM COMMERCIAL CLOTHES WASHER DATA SUBMITTAL ............... 5A-9 

LIST OF FIGURES 

Figure 5A.2.1 AHAM Dishwasher Shipments, Market Share, and Incremental Cost 

Data Submittal ............................................................................................ 5A-2 

Figure 5A.2.2 AHAM Dishwasher Standby Power Narrative ........................................... 5A-4 

Figure 5A.3.1 AHAM Dehumidifier Shipments, Market Share, and Incremental Cost 

Data Submittal ............................................................................................ 5A-6 

Figure 5A.4.1 AHAM CCW Shipments, Average Energy and Water Use, and 

Incremental Cost Data Submittal ................................................................ 5A-9 

5A-i 

EE-2006-STD-0127 COMMENT 39.2
APPENDIX 5A. AHAM DATA SUBMITTAL 

5A.1 INTRODUCTION 

This appendix presents the shipments and incremental cost data submitted to the U.S. 

Department of Energy (DOE) by the Association of Home Appliance Manufacturers (AHAM) in 

support of the engineering analysis for this rulemaking. Information was provided for residential 

dishwashers and dehumidifiers, and commercial clothes washers (CCWs) in response to data 

request sheets generated by DOE and provided to AHAM. In addition, AHAM provided a 

narrative description of standby power consumption in dishwashers. See Chapter 5 of the 

technical support document (TSD) for details of the engineering analysis for which this data was 

used. 

5A.2 AHAM DISHWASHER DATA SUBMITTAL 

AHAM supplied shipments and incremental cost data for standard-size dishwashers up to 

an efficiency level of 0.72 energy factor (EF). Data were not provided at higher efficiency levels 

for standard dishwashers, nor at any efficiency level for compact dishwashers, due to disclosure 

concerns, since there are fewer than 3 manufacturers who produce such products. 

5A.2.1 AHAM Dishwasher Shipments and Incremental Cost Data 

Figure 5A.2.1 reproduces the tables of dishwasher data submitted to DOE by AHAM. 

The first table, designated Table 1 in AHAM's submittal, specifies the efficiency levels and 

corresponding energy factors for which data was sought from AHAM's member manufacturers. 

These are the same efficiency levels that were used for the engineering analysis. 

AHAM Table 2 contains the annual shipments data for standard dishwashers along with 

the shipment-weighted average efficiency from 1995 to 2005. AHAM Table 3 lists the market 

share efficiency data for 2002 to 2005. AHAM Table 4 was reserved for further comment on 

dishwasher standby power. AHAM Tables 5, 6A, and 6B provide incremental manufacturing, 

one-time production, and conversion capital cost data for efficiency levels up to and including an 

EF of 0.72. 

5A-1

EE-2006-STD-0127 COMMENT 39.2
Figure 5A.2.1 AHAM Dishwasher Shipments, Market Share, and Incremental Cost 

Data Submittal 

DOE DW Rulemaking Data Submittal Spreadsheet (Version 9/7/06) 

Table 1 Revised Exploratory Efficiency Levels for Standard Dishwasher Analysis 

Level Efficiency Level Source Efficiency Level (EF) 

Standard 

baseline DOE Standard 0.46 

1 ENERGY STAR (scaled for 

compact) 0.58 

2 2007 ENERGY STAR 0.65 

3 Added based on 

stakeholder suggestions 0.72 

4 Gap Fill from E Star List 0.92

5 Max Available 1.11** 

** Source: ENERGY STAR qualified dishwashers as of February 8, 2006. 

Note: Exploratory levels for compacts have been removed as AHAM will not be providing DOE with data on this category. 

Table 2 Standard Dishwasher Shipment and Shipment-Weighted Average Efficiency Data 

Shipments, Domestic + Shipment-Weighted 

Year Imports Average Efficiency 

(# of Units) (EF) 

1995 4,253,745 0.485 

1996 4,316,828 0.476 

1997 4,655,200 0.495 

1998 5,073,023 0.508 

1999 5,424,973 0.504 

2000 5,833,686 0.503 

2001 5,752,217 0.533 

2002 5,906,348 0.553 

2003 6,467,303 0.581 

2004 6,867,551 0.598 

2005 7,280,046 0.599 

Table 3 Standard Dishwasher Market Share Efficiency Data 

Standard 

Market Share (percent) 

2002 2003 Efficiency Bins (EF) 2004 2005 

0.46-0.49: Baseline = 0.46 40% 22% 9% 3% 

0.50-0.53 9% 5% 2% 2% 

0.54-0.57 0% 0% 0% 2% 

0.58-0.59: E STAR = 0.58 15% 19% 18% 43% 

0.60 - 0.61 13% 16% 28% 17% 

0.62 - 0.63 4% 23% 31% 22% 

0.64 - 0.65 2007 E. Star = 0.65 9% 6% 9% 8% 

0.66 - 0.67 5% 5% 1% 0% 

0.68 and above 5% 5% 2% 3% 

TOTAL: 100% 100% 100% 100% 

Note: market max = 1.11 

Table 4 - Standby Power & Water Usage 

AHAM will be providing this information request in narrative form. 

5A-2 

EE-2006-STD-0127 COMMENT 39.2
Table 5 Shipment-Weighted Standard Dishwasher Manufacturer Cost Data

Exploratory EF Levels - Standard Dishwashers 

0.58 0.62 0.65 0.68 0.72 

Minimum Incremental Costs ($ Per Unit)* - Shipment-Weighted 

Minimum $3.22 $4.52 $5.39 $17.11 $34.05 

Average Increment ipment-Weighted 

Average $4.01 $7.38 $14.00 

al Costs ($ Per Unit)* - Sh

$30.35 $71.38 

Maximum Incremental Costs ($ Per Unit)* - Shipment-Weighted 

Maximum $4.92 $8.43 $14.50 $37.64 $91.74 

Table 6A Total Industry Average One-Time Production Conversion Expenses for R&D and Marketing ($, millions) 

EF 0.58 0.72 

l $5.73 $29.23 

l $3.29 $13.99 

Product Class 

0.62 0.65 0.68 

Industry tota : R&D $1.43 $4.43 $18.53 

Industry tota : Marketing $0.99 $1.99 $7.49 

Exploratory EF Levels - Standard Dishwashers 

Average One-Time Product Conversion Expenses ($, Millions) - Industry Total 

Table 6B Total Industry Average Conversion Capital Expenditure ($, Millions) 

EF 0.58 0.72 

l $16.85 $19.95 $98.45 

7,302 

i

Product Class 

0.62 0.65 0.68 

Industry total: Building 

Industry tota : Tooling/Equipment $23.25 $44.85 

Total Shipments 3,452 7,302 7,302 7,302 

Exploratory EF Levels - Standard Dishwashers 

Average One-Time Product Conversion Expenses ($, Millions) - Industry Total 

Insuff cient Data Submitted 

Total Shipments - in thousands 

Note: Shipment-weighted tooling equipment depreciation lifetime: 5 years 

5A.2.2 AHAM Narrative on Dishwasher Standby Energy Consumption 

AHAM separately provided a narrative on dishwasher standby power, which represented 

the consensus opinion of manufacturers that produce approximately 90% of standard 

dishwashers sold in the U.S. Figure 5A.2.2 is a reproduction of the standby power submittal 

document. 

5A-3

EE-2006-STD-0127 COMMENT 39.2
Figure 5A.2.2 AHAM Dishwasher Standby Power Narrative 

October 3, 2006 

Mr. Michael Rivest 

Managing Director 

Navigant Consulting, Inc. 

1801 K Street, NW 

Suite 500 

Washington, D.C. 20006- 1301 

RE: Supplemental Information for Efficiency Standards Rulemakings: Position Statement on Dishwasher 

Standby Power 

The Association of Home Appliance Manufacturers (AHAM), as the trade association representing 

manufacturers of dishwashers, offers the following position statement regarding standby power use in 

dishwashers to assist Navigant Consulting, Inc.’s contract work for the DOE on the standard rulemaking 

for dishwashers. This information supplements the dishwasher data AHAM submitted to the DOE on 

September 9, 2006. The position stated represents the consensus of producers of approximately 90% of 

the standard dishwashers sold in the U.S. 

Standby Power - Dishwashers 

AHAM’s position is that if standby power is incorporated in the standard, it should be included as part of 

a maximum total annual energy usage rather than by establishing a prescriptive standby power level. 

Standby power is important in improving overall efficiency of dishwashers. Typically, standard 

dishwashers with an EF of less than 0.50 are non-electronic models that use no standby power, but also 

have no energy-saving features or capabilities. Higher efficiency models with electronic controls, such as 

those that meet Energy Star requirements, have energy-saving capabilities such as soil sensor technology 

that can shorten the cycle if the dishes are clean, or delay start to reduce peak energy. While these units 

may use more standby power, the overall benefits for these units are better since they can reduce annual 

energy usage or shave peak load. 

Thank you for the opportunity to provide this information. Please feel free to contact me with any 

questions that you might have. 

Sincerely, 

Lawrence R. Wethje, P.E. 

Vice President, Technical Services

AHAM 

5A-4

EE-2006-STD-0127 COMMENT 39.2
5A.3 AHAM DEHUMIDIFIER DATA SUBMITTAL 

AHAM submitted to DOE shipments, market share and incremental cost data 

representing the aggregate input from the producers of over 95% of the dehumidifiers sold in the 

U.S. with capacities less than 75 pints/day. AHAM did not provide any data on units with 

capacities greater than 75 pints/day. In addition, AHAM did not provide any market share 

information for capacities other than 35.01 pints/day - 45.00 pints/day or 54.01 pints/day - 74.99 

pints/day, nor did it provide manufacturer cost data for 35.01 - 45.00 pints/day at the highest 

efficiency level (EF = 1.74), due to confidentiality concerns. 

Figure 5A.3.1 reproduces the tables of dehumidifier data submitted to DOE by AHAM. 

The first table, designated Table 1 in AHAM's submittal, specifies the efficiency levels and 

corresponding energy factors for each capacity for which data was sought from AHAM's 

member manufacturers. These are the same efficiency levels that were used for the engineering 

analysis. 

AHAM Table 2 contains the annual shipments data for dehumidifiers along with the 

shipment-weighted average efficiency from 2003 to 2005. AHAM Tables 3A, 3B, and 3C list 

market share efficiency data from 2003 to 2005 for 35.01 pints/day - 45.00 pints/day and 54.01 

pints/day - 74.99 pints/day. As mentioned previously, no data for other capacities was provided 

due to the limited number of manufacturers producing these product classes. 

AHAM Table 4 provides incremental manufacturing and one-time production conversion 

costs. In this table, AHAM combined data for 0 - 25.00 pints/day and 25.01 - 35.00 pints/day 

into a single product class of 0 - 35.00 pints/day for confidentiality purposes. AHAM Table 5 

lists the depreciation assumptions used for the data in AHAM Table 4. AHAM noted that the 

cost information in their Tables 4 and 5 did not take into consideration that the regulation of the 

R-22 refrigerant currently used in dehumidifiers may be revised by the U.S. Environmental 

Protection Agency, possibly beginning in the year 2010. A ban at or about 2010 would require 

AHAM to submit adjusted cost information to account for the costs to use alternative 

refrigerants. 

5A-5

EE-2006-STD-0127 COMMENT 39.2
Figure 5A.3.1 AHAM Dehumidifier Shipments, Market Share, and Incremental Cost 

Data Submittal 

Table 1 Revised Exploratory Efficiency Levels for Dehumidifier Analysis 

Efficiency Levels (liters/kWh) Efficiency Level Level Source 25.01-35.00 35.01–45.00 54.01-74.99 

pints/day pints/day pints/day 

baseline DOE Standard 

(effective 2007) 1.20 1.30 1.50 

Between DOE and 

1 Default 2012 1.25 1.35 1.55 

Standard 

Default 2012 

2 Standard (EPACT 1.30 1.40 1.60 

2005)

Revised based on 

3 stakeholder 1.35 1.45 1.65 

suggestions

Added based on 

4 stakeholder 1.40 1.50 1.70 

suggestions

5 Max Available* 1.45 1.74 1.80 

* Source: ENERGY STAR qualified dehumidifiers as of April 27, 2006. 

Table 2 Dehumidifier Shipment and Shipment-Weighted Average Efficiency Data 

≤ 25.00 25.01-

35.00 

35.01-

45.00 

45.01-

54.00 

54.01-

74.99 ≥75.00 ≤ 25.00 25.01-35.00 

35.01-

45.00 

45.01-

54.00 

54.01-

74.99 ≥75.00 

Year 

Shipments, Domestic + Imports Shipment-Weighted Average Efficiency 

(Thousands of Units) (liters/kWh) 

2003 178 282 307 289 255 1.25 1.26 1.35 1.48 1.56 

2004 169 389 395 343 376 1.27 1.27 1.38 1.56 1.56 

2005 127 509 455 406 460 1.28 1.26 1.42 1.57 1.57 

Table 3A Dehumidifier Market Share Efficiency Data, ≤ 25.00 and 25.01–35.00 pints/day Product Classes 

2003 2004 2005 

≤ 25.00 pints/day 

Efficiency 

Bins 

Market Share (percent) 

2003 2004 2005 

25.01–35.00 pints/day 

Efficiency 

Bins 

Market Share (percent) 

< 1.00 < 1.20 

1.00-1.09: Baseline 

= 1.00 

1.20-1.24: Baseline 

= 1.20 

1.10-1.19: Mid 

Point = 1.10 

1.25-1.29: Mid 

Point = 1.25 

1.20-1.24: EPACT 

2005=1.20 

1.30-1.34: EPACT 

2005=1.30 

1.25-1.29: 

Suggested =1.25 

1.35-1.39: 

Suggested =1.35 

1.30-1.37: 

Suggested = 1.30 

1.40-1.44: 

Suggested = 1.40 

> 1.37: Max 

Available = 1.38 

> 1.44: Max 

Available = 1.45 

Insufficient Data 

5A-6 

EE-2006-STD-0127 COMMENT 39.2
Table 3B Dehumidifier Market Share Efficiency Data, 35.01–45.00 and 45.01–54.00 pints/day Product Classes 

2003 2004 2005 

Efficiency 

Bins 

Market Share (percent) 

35.01-45.00 pints/day 

2003 2004 2005 

Efficiency 

Bins 

Market Share (percent) 

45.01-54.00 pints/day 

< 1.30 < 1.40 

1.30-1.34: Baseline 

= 1.30 

70 54 27 1.40-1.44: Baseline 

= 1.40 

1.35-1.39: Mid 

Point = 1.35 

35 1.45-1.49: Mid 

Point = 1.45 

1.40-1.44: EPACT 

2005=1.40 

4 1.50-1.54: EPACT 

2005=1.50 

1.45-1.49: 

Suggested =1.45 

26 38 1.55-1.59: 

Suggested = 1.55 

1.50-1.59: 

Suggested = 1.50 

8 38 1.60-1.69: 

Suggested = 1.60 

> 1.59: Max 

Available = 1.74 

> 1.69: Max 

Available = 2.02 

Insufficient Data 

Table 3C Dehumidifier Market Share Efficiency Data, 54.01–74.99 and ≥ 75.00 pints/day Product Classes 

2003 2004 2005 

Efficiency 

Bins 

Market Share (percent) 

54.01-74.99 pints/day 

2003 2004 2005 

Efficiency 

Bins 

≥ 75.00 pints/day 

Market Share (percent) 

< 1.50 3 < 2.25 

1.50-1.54: Baseline 

= 1.50 

9 31 2.25-2.34: Baseline 

= 2.25 

1.55-1.59: Mid 

Point = 1.55 

75 2.35-2.44: Mid 

Point = 2.38 

1.60-1.64: EPACT 

2005=1.60 

76 57 2.45-2.50: EPACT 

2005=2.50 

1.65-1.69: 

Suggested =1.65 

22 15 12 2.51-2.55: 

Suggested =2.55 

1.70-1.79: 

Suggested = 1.70 

2.56-2.65: 

Suggested = 2.60 

> 1.79: Max 

Available = 1.80 

> 2.65: Max 

Available = 2.75 

5A-7

EE-2006-STD-0127 COMMENT 39.2
Table 4 Dehumidifier Manufacturer Cost Data 

ici 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 

EF 1.50 1.55 1.65 

l 

N/A 8 

l 

0 0 0 0 0 N/A 0 0 0 9 

l 

7 N/A 

N/A 

6 N/A 0.2 

($ Per Unit)* (

($ Per Unit)* (

) 

/ /

($ Per Unit) ( ) 

Product Class 

Eff ency Level 

1.25 1.30 1.35 1.40 1.45 1.35 1.40 1.45 1.74 1.60 1.70 1.80 

Tota

Incremental 

Costs 

3.12 4.92 10.41 18.8 25.61 6.11 14.47 22.68 32.84 4.18 12.36 23.18 33.94 

Tota

Incremental 

Costs 

8.03 15.2 21.9 22.5 29 

Tota

Incremental 

Costs 

10 20 29.54 34.79 10 35.38 46.36 65.34 13 16 19 63 87 

R&D 0.05 0.15 2.25 4.75 7.15 1.7 3.43 3.6 4.6 0.1 0.23 0.4 6.9 11.8 

Marketing 0.1 0.15 1.7 4.75 0.6 2.65 2.7 3.75 0.1 0.15 6.35 11 

MINIMUM Incremental Costs LOWEST INDIVIDUAL MFR. 

MAXIMUM Incremental Costs HIGHEST INDIVIDUAL MFR. 

One-Time Product Conversion Expenses ($, Millions) (TOTAL FOR ALL MFRS.

0 - 35.00 pints day 35.01–45.00 pints/day 54.01-74.99 pints day 

AVERAGE Incremental Costs SHIPMENT WEIGHTED

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

with the federal standard for residential dehumidifiers (effective 2007) and is equal to 1.20 liters/kWh for 25.01-

35.00 pints/day, 1.30 liters/kWh for 35.01-45.00 pints/day, and 1.50 liters/kWh for 54.01-74.99 pints/day. 

NOTE: The first category, 0 - 35 pints/day, is shipment weighted based on all shipments below 35 

pints/day because some mfrs. did not have shipments between 25 - 35 pints/day. 

Table 5 Dehumidifier Depreciation Assumptions Used to Calculate Per Unit Incremental 

Depreciation in Table 4 

Product Class 25.01-35.00 pints/day 35.01–45.00 pints/day 54.01-74.99 pints/day 

Efficiency Level 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 

EF 1.25 1.30 1.35 1.40 1.45 1.35 1.40 1.45 1.50 N/A 1.55 1.60 1.65 1.70 1.80 

Conversion Capital Expenditure Assumption ($, Millions) (TOTAL FOR ALL MFRS.) 

Building 0.03 5.05 5.1 5.15 5.2 0.03 0.05 0.1 5.15 N/A 0.03 0.05 0.1 6.15 6.2 

Tooling/ 

Equipment 0.3 1.85 3.9 6.95 9 2.45 4.5 4.55 8.65 N/A 0.65 0.7 0.75 8.1 12 

Units Shipped (TOTAL FOR ALL MFRS IN THOUSANDS.) 

525 625 745 745 745 548 548 548 648 N/A 450 450 450 612 612 

Depreciation Lifetimes (years) 

Building 10 10 10 

Tooling/ 

Equipment 3 3 3 

5A-8

EE-2006-STD-0127 COMMENT 39.2
5A.4 AHAM COMMERCIAL CLOTHES WASHER DATA SUBMITTAL 

AHAM supplied shipments, average energy and water use, and incremental cost data to 

DOE, representing the aggregated inputs from manufacturers which produce the significant 

majority of CCWs. 

Figure 5A.4.1 reproduces the tables of CCW data submitted to DOE by AHAM. The 

first table, designated Part I in AHAM's submittal, contains the annual shipments data along with 

the shipment-weighted average modified energy factor (MEF) and water factor (WF) from 2002 

to 2005. 

Part II provides average energy and water use for a baseline CCW with an MEF of 1.26. 

Part III contains shipment-weighted incremental costs for two efficiency levels: 

MEF=1.42/WF=9.5 and MEF=2.0/WF=5.5. Data was not provided at other efficiency levels due 

to confidentiality concerns. 

Figure 5A.4.1 AHAM CCW Shipments, Average Energy and Water Use, and 

Incremental Cost Data Submittal 

Commercial Clothes Washers (CCW) 

Part I: Annual Shipments & Shipment-Weighted MEF and WF - Vertical and Horizontal Axis Combined 

YEAR TOTAL 

SHIPMENTS MEF WF 

2002 175,187 1.30 11.77 

2003 190,720 1.33 11.42 

2004 178,382 1.33 11.33 

2005 177,394 1.41 10.91 

Part II: Average Energy and Water Use for Vertical Axis CCW with MEF of 1.26 

MEF TYPE Average 

 WF 

Average 

cu.ft 

Average 

Hot Water 

 kWh/cycle 

Average 

Machine 

kWh/cycle 

Average 

Dryer 

kWh/cycle 

Average 

Standby 

W 

Average 

Water use

gallons/cycle 

1.26 V 11.1 3.1 0.87 0.18 1.38 * 34.3 

* insufficient data reported 

Part III: Aggregated Shipment-Weighted Incremental Cost to go from current 1.26 MEF standard to levels indicated below 

MEF: 1.42 1.6 1.72 1.8 2 2.2 

Water Factor: 9.5 8.5 8 7.5 5.5 5.1 

Shipment-Weighted 

Incremental Cost: $74.63 * * * $316.35 * 

* insufficient data reported 

5A-9 

EE-2006-STD-0127 COMMENT 39.2