U.S. Department of Energy

Energy Conservation Program for Consumer Products

and Commercial and Industrial Equipment

Framework Document Public Meeting on

Energy Conservation Standards for

Residential Clothes Washers

September 21, 2009

Washington, DC

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

EERE-2008-BT-STD-0019 COMMENT 06
Welcome and Introduction

• Introductions• Role of the Facilitator• Ground Rules (norms)

– Listen as an ally– Use short, succinct statements/keep to the point– Hold sidebar conversations outside the room– Focus on issues, not personalities– One person speak at a time (raise hand to be recognize

your name for the record)

– Set cell phones to silent/vibrate

• Housekeeping Items• Agenda Review• Opening Remarks

EERE-2008-BT-STD-0019 COMMENT 06
9:00 – 9:05 am Welcome9:05 – 9:15 am Opening remarks, introductions, and age

Stephen Witkowski

9:15 – 9:30 am Rulemaking and analytical methodology o

Stephen Witkowski

9:30 – 10:30 am Market and Technology Assessment

Judith Reich

10:30 – 10:45 am Break10:45 – 11:30 am Screening Analysis and Engineering Ana

Judith Reich

11:30 – 12:00 pm Preliminary Manufacturer Impact Analysis

Judith Reich

12:00 – 1:00 pm Break for lunch

Morning Agenda

EERE-2008-BT-STD-0019 COMMENT 06
Afternoon Agenda

1:00 – 2:00 pm Markups for Equipment Price Determinatio

Use Determination; and Life-Cycle Cost and Period AnalysisIsaac Turiel

2:00 – 2:45 pm Shipments Analysis, National Impact Analy

LCC Subgroup AnalysisGregory Rosenquist

2:45 – 3:00 pm Break3:00 – 3:15 pm Manufacturer Impact Analysis

Judith Reich

3:15 – 3:45 pm Utility Impact Analysis, Employment Impac

Environmental Assessment, and RegulatorAnalysisGregory Rosenquist

3:45 – 4:30 pm Other issues and comments; closing remar

EERE-2008-BT-STD-0019 COMMENT 06
Stakeholder Opening Statements

• Stakeholders who contacted DOE to request an opportunity 

an opening statement should speak now.

EERE-2008-BT-STD-0019 COMMENT 06
Public Meeting Agenda

23

NOPR Analyses

14

Rulemaking OverviewIntroduction

5 Final Rule6 Closing Remarks

23

Pre-NOPR AnalysesEnergy Conservation Standards

4

Test Procedures

5 NOPR Analyses6 Closing Remarks

EERE-2008-BT-STD-0019 COMMENT 06
Purpose of the Framework Document Public M

• Present the procedural and analytical approaches to eva

energy conservation standards for residential clothes wa

• Provide a forum for public discussion of rulemaking issue• Encourage stakeholders to submit data, information, and 

comments

EERE-2008-BT-STD-0019 COMMENT 06
Requests for Comment

Issue Box In the Rulemaking Framework Document for Residential Clothes Washers, DOE welcomes comment. Throughout this presentation specific issues will be brought discussion on slides such as this, with identifying numbercorresponding to those in the Framework Document. Nonetheless, comments concerning any part of the documepresentation are welcome.

EERE-2008-BT-STD-0019 COMMENT 06
In all correspondence, please refer to the Residential Clothes Wa

rulemaking by:

– Framework Document for Residential Clothes Washers– Docket Number EERE-2008-BT-STD-0019, and– Regulatory Identification Number (RIN) 1904-AB90

Email: RCW-2008-STD-0019@ee.doe.gov

Feedback Is Requested 

Especially on Items Identified in Framework Doc

Postal Mail:

Ms. Brenda Edwards-JonesU.S. Department of EnergyBuilding Technologies Program,

Mailstop EE-2J

1000 Independence Avenue, SWWashington, DC 20585-0121Telephone: (202) 586-2945

Comment period closes September 28, 2009

Courier:

Ms. Brenda Edwards-JonesU.S. Department of EnergyBuilding Technologies Progra

6th Floor

950 L’Enfant Plaza, SWWashington, DC 20024Telephone: (202) 586-2945

EERE-2008-BT-STD-0019 COMMENT 06
Background

• Energy Policy and Conservation Act (EPCA) of 1

established an energy conservation program for household appliances (42 USC 6291 et seq.)

• Amendments to EPCA in the National Appliance 

Conservation Act of 1987 (NAECA) (42 USC 6295 

– Established prescriptive energy conservation standard

residential clothes washers

– Directed DOE to conduct two cycles of rulemakings to 

if more stringent standards are justified.

EERE-2008-BT-STD-0019 COMMENT 06
Previous Rulemakings

– Final Rule published May 14, 1991 set performance sta

effective May 14, 1994. (56 FR 22279)

– Second standards rulemaking initiated by publication o

November 14, 1994. (59 FR 56423)

– Rulemaking activities suspended in FY 1996. During th

revised the standard-setting process and published a fProcedures for Consideration of New or Revised Energ

Conservation Standards for Consumer Products.(61 FR 36974; 10 CFR part 430, subpart C, Appendix A

– Second standards rulemaking re-initiated by publicatio

ANOPR on November 19, 1998

– Second Final Rule published January 12, 2001 set per

standards effective in two phases: January 1, 2004 and 2007. (66 FR 3314)

EERE-2008-BT-STD-0019 COMMENT 06
Previous Rulemakings, cont.

– Energy Independence and Security Act (EISA) of 2007

(P.L. 110-140) revised energy conservation standards residential clothes washers, effective January 1, 2011.(42 USC 6295(g)(9))

– EISA 2007 directed DOE to publish a final rule no later 

December 31, 2011 determining whether to amend the standards manufactured on or after January 1, 2015.

– EISA 2007 also directed DOE to consider standby mod

mode energy consumption in future amendments to enefficiency standards 

EERE-2008-BT-STD-0019 COMMENT 06
Current Rulemaking for 

Residential Clothes Washers

• In order to meet the EISA 2007 deadline, DOE initiated th

rulemaking on Residential Clothes Washers.

• Today’s public meeting is about the Framework Documen• Test Procedure revisions concurrent with the Pre-NOPR:

– TP NOPR for standby and off-mode energy consumpt– TP NOPR for energy efficiency

EISA 2007

NOPR1 Final Rule

Residential Clothe

Test Procedu

(TP Standby and TP 

Framework

Document Pre-NOPR1

En

R

NOPR1 Final Rule

1 Pre-NOPR: Preliminary Notice of Proposed Rulemaking NOPR: Notice of Proposed Rulem

EERE-2008-BT-STD-0019 COMMENT 06
23

NOPR Analyses

14

Test ProceduresIntroduction

3

Pre-NOPR AnalysesEnergy Conservation Standards

4

Introduction

5 NOPR Analyses Final Rule6 Closing Remarks

Public Meeting Agenda

EERE-2008-BT-STD-0019 COMMENT 06
Test Procedure – Residential Clothes Was

Tes

• DOE published a Final Rule for the clothes washer test pro

on August 27, 1997, effective on January 1, 2004. (62 FR 

• DOE amended the test procedure in the 2001 rulemaking, 

incorporating changes to the energy test cloth, remaining m

content (RMC), and extractor testing. (66 FR 3330)

• DOE amended the test procedure again in 2003 (68 FR 62

– Replaced lowest spin cycle of 50 gravitation (g) force with a 

cycle of 100 g for testing the cloth used in the extraction pha

– Specified the use of additional statistical analysis to qualify t

interactive effect between different lots of the test cloth and speeds to improve consistency with the baseline data 

EERE-2008-BT-STD-0019 COMMENT 06
• EISA 2007 directed DOE to amend test procedures to incl

measurement of standby mode and off mode energy cons

• Definition of active mode, off mode, standby mode as defin

– Active mode: The condition in which an energy-using product

(1) is connected to a main power source(2) has been activated; and(3) provides one or more main functions

– Off mode: The condition in which an energy-using product

(1) is connected to a main power source; and(2) is not providing any standby or active mode function

– Standby mode: The condition in which an energy-using product

(1) is connected to a main power source; and(2) offers one or more of the following user-oriented or protective fu

(a) To facilitate the activation or deactivation of other functions (in

mode) by remote switch (including remote control), internal senso(b) Continuous functions, including information displays (including sensor-based functions.

EISA 2007 Standby and Off-Mode Considera

Tes

EERE-2008-BT-STD-0019 COMMENT 06
Clothes Washer Test Procedure Rulemak

• DOE must take into consideration the current versions of I

Electrotechnical Commission (IEC) Standard 62301 – “Ho

electrical appliances – Measurement of standby power”

• DOE is aware that IEC 62301 is currently under revision, w

revision expected to be published mid-2010.

• Based on stakeholder comments on test procedure rulema

other household appliances, DOE has determined to consdefinitions under the expected revision of IEC 62301.

• DOE has delayed the clothes washer test procedure rulem

the EISA deadline of June 30, 2009 in order to allow consi

new IEC 62301 language.

Tes

EERE-2008-BT-STD-0019 COMMENT 06
Request for Comment

Tes

Item 1-1 DOE requests input from interested parties on the merevising its test procedures for residential clothes washers andseeks input (including supporting data) regarding how these procedures can be improved.

EERE-2008-BT-STD-0019 COMMENT 06
23

NOPR Analyses

1

Energy Conservation Standards

4

Rulemaking OverviewIntroduction

2

Pre-NOPR AnalysesTest Procedure

4

Introduction

5 NOPR Analyses Final Rule6 Closing Remarks

Public Meeting Agenda

EERE-2008-BT-STD-0019 COMMENT 06
Energy Conserva

42 U.S.C. 6295(o)(2)(B)(i) directs DOE to take into consider

factors when setting energy conservation standards for R

Clothes Washers

EPCA Factors DOE Analys

1. Economic impact on consumers and 

manufacturers

Life-Cycle Cost AnalysManufacturer Impact A

2. Lifetime operating cost savings 

compared to increased cost for the product

Life-Cycle Cost Analys

3. Total projected energy savings National Impact Analys

4. Impact on utility or performance Engineering Analysis

Screening Analysis

5. Impact of any lessening of competition Manufacturer Impact A6. Need for national energy conservation National Impact Analys7. Other factors the Secretary considers 

relevant

Environmental AssessmUtility Impact AnalysisEmployment Impact An

EERE-2008-BT-STD-0019 COMMENT 06
Stages for the Energy Conservation Stand

Rulemaking Process

Framework Document

Framework 

Document 

Public 

Meeting

Framework 

Document 

Public 

Meeting

Points of Stakeholder Participation Points of Stakeholder Participation

Milestones for DOE Milestones for DOE

Pre-NOPR

Public 

Meeting

Pre-NOPR

Public 

Meeting

NOPR

Public 

Meeting

NOPR

Public 

Meeting

Energy Conserva

Pre-NOPR Published

NOPR Published

Final Rule Published

Dec. 31, 2011

S

2009 2010 2011 2012 2013 2014 20

EERE-2008-BT-STD-0019 COMMENT 06
Framework Document

Framework

Document Pre-NOPR NOPR Final Rule

Today

• Today’s public meeting covers the Framework Document for this rulemakin• Federal Register Notice of Public Meeting – (74 FR 44306, August 28, 

– Gives notice of the public meeting and availability of the Framework D

discussed today

• Encourages interested parties to submit comments• Framework Document

– Provides an overview of the rulemaking process and encourages early 

participation

– Invites comments on proposed approach and issues– The Framework Document is available online: 

http://www1.eere.energy.gov/buildings/appliance_standards/residentia

clothes_washers_framework.html

Energy Conserva

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy & Water Use Determination

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Steps in the Standards Rulemaking: Pre-NO

Preliminary Manufacturer Impact Analysis

Energy Conserva

EERE-2008-BT-STD-0019 COMMENT 06
Analyses for the Pre-NOPR

Energy Conserva

Approaches Key Inputs

Analyses Key Outp

Market and Technolog

y

Assessment

Screening Analysis

Engineering Analysis

Product Price

Determination Life-Cycle Cost and 

Payback Period 

Analyses

National Impact

Analysis

Energy Use

Shipments

Analysis

• Product Classes• Technology Options• Product Designs• Life-Cycle Costs• Payback Periods• National Energy Savi• Net Present Values

• Characterize Industry

• Market Segmentation• Non-Regulatory Programs

Framework 

• Efficiency-Level Approach• Design Option Approach

• Energy Prices• Installation Costs

• Maintenance & Repair Costs

• Accounting Approach

• Backcast and Forecast• Market Saturation

• Identify Firms/Products • Historical Shipments

•Retail Price Collection and

Analysis

Design Options

Product Classes

Retail Prices

Design Energy/ Use

Advance Notice of Proposed Rulemakin

• Efficiency/Performance• Commercial Products

Candidate

Standard 

Levels

• Analysis of Energy Use 

Data

Technology Options

• Design Options

• Energy Price Forecasts• Site-to-Source Factors

• Energy-Efficiency Levels

• Analysis of Market Data• Analysis of Product Data

• Installation

Costs

• Maint Costs

• Repair Costs

• UEC• Energy Prices

Annual Energy Use (UEC)

Preliminar

y

Manufacturer Impact

Analysis

• Manufacturer Prices• Average Costs

• Conversion Capital E• Direct Employment Im

• Product Prototypes

Energy-Efficiency

Levels Product Designs

Market and Technolog

y

Assessment

Screening Analysis

Engineering Analysis

Product Price

Determination Life-Cycle Cost and 

Payback Period 

Analyses

National Impact

Analysis

Energy Use

Shipments

Analysis

• Product Classes• Technology Options• Product Designs• Life-Cycle Costs• Payback Periods• National Energy Savi• Net Present Values

• Characterize Industry

• Market Segmentation• Non-Regulatory Programs

Framework 

• Efficiency-Level Approach• Design Option Approach

• Energy Prices• Installation Costs

• Maintenance & Repair Costs

• Accounting Approach

• Backcast and Forecast• Market Saturation

• Identify Firms/Products • Historical Shipments

•Retail Price Collection and

Analysis

Design Options

Product Classes

Retail Prices

Design Energy/ Use

Publication of Pre-Rulemaking 

• Efficiency/Performance• Commercial Products

Candidate

Standard 

Levels

• Analysis of Energy Use 

Data

Technology Options

• Design Options

• Energy Price Forecasts• Site-to-Source Factors

• Energy-Efficiency Levels

• Analysis of Market Data• Analysis of Product Data

• Installation

Costs

• Maint Costs

• Repair Costs

• UEC• Energy Prices

Annual Energy Use (UEC)

Preliminar

y

Manufacturer Impact

Analysis

• Manufacturer Prices• Average Costs

• Conversion Capital E• Direct Employment Im

• Product Prototypes

Energy-Efficiency

Levels Product Designs

EERE-2008-BT-STD-0019 COMMENT 06
Purpose of the Pre-NOPR Public Meetin

• To present methodologies for the Pre-NOPR analyses, a

characterize results

• To discuss specific issues related to the Pre-NOPR anal• To seek input from attendees on methodologies, assump

data sources

• To describe upcoming analyses and next steps, and see

input

Energy Conserva

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Steps in the Standards Rulemaking: NOP

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

RevisePre-NOPR Analyses

EnvironmeAssessme

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Energy Conserva

EERE-2008-BT-STD-0019 COMMENT 06
Analyses for the NOPR and Final Rule

Energy Conserva

Utility Impact

Analysis 

Notice of Proposed Rulemaki

Revise Pre-NOP

R

Analyses

Life-Cycle Cost 

Sub-Group Analysis

Manufacturer Impact

Analysis

Employment Impact

Analysis 

Revise Analyses

• Industry Cash Flow• Sub-Group Cash-Flo

w

• Direct Employment Im• Competitive Impacts• Cumulative Regulato• National Employmen• Revised Results

• Stakeholder Comments• Demographics

• Manufacturer Interviews• GRIM Analysis

• Emission Rates• National Energy Savings

• Stakeholder Comments

• Manufacturer Prices• Average Costs

• Manufacturer Financial Data

Advance Notice of Proposed Rulemakin

Environmental

Assessment

Regulatory Impact

Analysis

• Emission Estimates

• Utility Load Factors• National Energy Savings

• Non-Regulatory

Alternatives

• NEMS-BT

• ImSET• NEMS-BT

Direct Employment Impacts

• National Energy Savings• National Product Costs• National Operating Costs

• Utility Impacts

• Life-Cycle Costs• Payback Periods

• National Energy Savi• Net Present Values

• Trial Standard Levels 

TSLs

• Department of Justice Revie

w

Utility Impact

Analysis 

Notice of Proposed Rulemaki

Analyses

Life-Cycle Cost 

Sub-Group Analysis

Manufacturer Impact

Analysis

Employment Impact

Analysis 

Revise Analyses

• Industry Cash Flow• Sub-Group Cash-Flo

w

• Direct Employment Im• Competitive Impacts• Cumulative Regulato• National Employmen• Revised Results

• Stakeholder Comments• Demographics

• Manufacturer Interviews• GRIM Analysis

• Emission Rates• National Energy Savings

• Stakeholder Comments

• Manufacturer Prices• Average Costs

• Manufacturer Financial Data

Publication of Pre-Rulemaking 

Environmental

Assessment

Regulatory Impact

Analysis

• Emission Estimates

• Utility Load Factors• National Energy Savings

• Non-Regulatory

Alternatives

• NEMS-BT

• ImSET• NEMS-BT

Direct Employment Impacts

• National Energy Savings• National Product Costs• National Operating Costs

• Utility Impacts

• Life-Cycle Costs• Payback Periods

• National Energy Savi• Net Present Values

• Trial Standard Levels 

TSLs

• Department of Justice Revie

w

EERE-2008-BT-STD-0019 COMMENT 06
Purpose of the NOPR Public Meeting

• To hear the views of stakeholders on DOE’s proposed st

level

• To obtain input on any remaining issues relating to the N

Proposed Rulemaking 

DOE will consider all verbal and written input i

preparing its Final Rule.

Energy Conserva

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document NOPR Final Rule Pre-NOPR NOPR

Analyses for Final Rule

Final 

Energy Conserva

Revise NOPR 

Analyses

EERE-2008-BT-STD-0019 COMMENT 06
23

Pre-NOPR Analyses

14

Rulemaking OverviewIntroduction

2

Energy Conservation StandardsTest Procedure

3

Introduction

5 NOPR Analyses Final Rule6 Closing Remarks

Public Meeting Agenda

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy & Water Use Determination

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Steps in the Standards Rulemaking: Pre-NO

Preliminary Manufacturer Impact Analysis

Pre-

EERE-2008-BT-STD-0019 COMMENT 06
Market and Technology Assessment

• Purpose:

– Characterize the market, the residential clothes washer ind

the measures to improve efficiency

• Method: 

– Identify and characterize manufacturers of residential cloth

washers

– Estimate shipments and trends in the market;– Identify technologies that could improve efficiency; and– Identify regulatory and non-regulatory initiatives intended t

the efficiency of the products covered under this rulemakin

Market and Technolo

EERE-2008-BT-STD-0019 COMMENT 06
Relationship of Market and Technology Asses

to other Analyses

Market and 

Technology 

Assessment

Product Classes

Technology Options to improve efficiency

Screening Analysis

Design Options to improve efficiency

Engineering Analysis

Market and Technolo

EERE-2008-BT-STD-0019 COMMENT 06
Request for Comment

Item 3-1 DOE requests information that would contribute to the massessment for the residential clothes washers covered in this rul(e.g., current product features and efficiencies, product feature anefficiency trends, and historical product shipments and prices).

Market and Technolo

EERE-2008-BT-STD-0019 COMMENT 06
Definitions

• Under EPCA, DOE provides definitions of clothes washe

(10 CFR 430.2):

• Clothes washer means a consumer product designed to clean 

utilizing a water solution of soap and/or detergent and mechanicagitation or other movement, and must be one of the following cautomatic clothes washers, semi-automatic clothes washers, anclothes washers.

Market and Technolo

EERE-2008-BT-STD-0019 COMMENT 06
Definitions (cont.)

• Automatic clothes washer means a class of clothes washer w

control system which is capable of scheduling a preselected co

of operations, such as regulation of water temperature, regulatiowater fill level, and performance of wash, rinse, drain, and spin without the need for user intervention subsequent to the initiatio

machine operation. Some models may require user intervention these different segments of the cycle after the machine has begoperation, but they do not require the user to intervene to regulawater temperature by adjusting the external water faucet valves

• Semi-automatic clothes washer means a class of clothes was

the same as an automatic clothes washer except that user interrequired to regulate the water temperature by adjusting the extefaucet valves.

• Other clothes washer means a class of clothes washer which 

automatic or semi-automatic clothes washer.

Market and Technolo

EERE-2008-BT-STD-0019 COMMENT 06
• DOE will formulate a separate energy conservation stan

each product class.

• In general, DOE divides covered equipment into classes 

– Type of energy used– Capacity of the equipment– Other performance-related features such as those th

provide utility to the consumer, or others deemed apby the Secretary that justify different standard levels(42 USC 6295(q))

Market and Technolo

Equipment Product Classes

EERE-2008-BT-STD-0019 COMMENT 06
Market and Technolo

Proposed Residential Clothes Washer Product 

Residential Clothes Washers1. Top-loading, compact (less than 1.6 cubic feet capacity)2. Top-loading, standard (1.6 cubic feet or greater capacity)3. Top-loading, semiautomatic *4. Front-loading5. Suds-saving *

* DOE is unaware of any top-loading semiautomatic or suds-saving clothes wthe market. DOE proposes to eliminate these product classes for this reasonbecause it believes they do not offer any added utility that is inherently less e

efficient that would require protection from the energy conservation standards

EERE-2008-BT-STD-0019 COMMENT 06
Market and Technolo

Item 3-2 DOE requests input from interested parties on the prproduct classes and the criteria used for creating these productclasses. What other factors, if any, should DOE consider beyonidentified above as a basis for developing product classes? Whanswering, please explain in detail and cite specific examples textent possible.Item 3-3 DOE seeks comment on the merits of retaining or elimthe top-loading semiautomatic and suds-saving clothes washer product classes.Item 3-4 DOE seeks comment as to whether the method of “loclothes washers or any other consumer utility generally associawith the method of loading are “features” within the meaning of U.S.C. 6295(o)(4) in EPCA and whether the availability of such feature(s) would likely be affected by eliminating the separate cfor these product types previously established by DOE.

Request for Comment

EERE-2008-BT-STD-0019 COMMENT 06
Initial Technology Options for Clothes Was

Market and Technolo

1. Adaptive fill controls2. Added insulation3. Advanced agitation concepts for top-loading machines4. Automatic fill control5. Bubble action6. Direct-drive motor7. Electrolytic disassociation of water8. Horizontal-axis design9. Hot water circulation loop10. Front-loading design with recirculation11. Improved fill control12. Improved front-loading washer drum design

EERE-2008-BT-STD-0019 COMMENT 06
Initial Technology Options for Clothes Was

(cont.)

Market and Technolo

13. Improved water extraction to lower remaining moisture conten14. Increased motor efficiency15. Low-standby-power design16. Ozonated laundering17. Plastic particle cleaning18. Reduced thermal mass19. Spray rinse or similar water-reducing rinse technology20. Steam washing21. Thermostatically controlled mixing valves22. Tighter tub tolerance23. Ultrasonic washing

EERE-2008-BT-STD-0019 COMMENT 06
Request for Comment

Item 4-1 Are there any technologies listed in the above table thashould not consider because of their impacts on safety, performaconsumer utility of the product? If so, why?Item 4-2 Are there other technologies that DOE should consider technology options, and what, if any, impacts would the technolobe expected to have on safety, performance, and consumer utilit

Market and Technolo

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Steps in the Standards Rulemaking: Pre-NO

Preliminary Manufacturer Impact Analysis

Pre-

Energy & Water Use Determination

EERE-2008-BT-STD-0019 COMMENT 06
Screening Analysis

Scre

Impacts on health or safety

Impacts on product utility or availability to consumers

Practicability to manufacture, install and service

Technological feasibility

• Purpose

– Screen out technology options that DOE will not consider in t

engineering analysis for residential clothes washers

• Method:

– DOE will evaluate each technology option based on the follo

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Steps in the Standards Rulemaking: Pre-NO

Preliminary Manufacturer Impact Analysis

Pre-

Energy Use Determination

EERE-2008-BT-STD-0019 COMMENT 06
Downstream Rule

Analyses

• Life-Cycle Cost a

Payback Period

• Manufacturer Im

Analysis 

• National Impacts

Manufacturer Cost –

Efficiency Relationship

Manufacturer 

Cost

Efficiency Level

Engineering Analysis

• Purpose: 

– To characterize the relationship between manufacturer co

energy efficiency.

Engin

EERE-2008-BT-STD-0019 COMMENT 06
Õ Determine characteristics of common or typical 

will serve as reference points to assess changeenergy conservation standards. Baseline modemeet existing minimum energy conservation sta

Õ Perform detailed product disassembly to determ

technologies and design features associated wiefficiency level, and the manufacturing costs asthem. A “green-field” model of the subject unit abe aggregated to produce industry-wide estimat

Õ Collect manufacturer cost data on efficient cloth

room air conditioner designs. Conduct interviewmanufacturers to enhance understanding of effiimprovements and associated costs.

Õ Determine manufacturing cost-efficiency curves 

reverse-engineering and industry-supplied cost cost-efficiency relationships with interview informpublicly available data. 

Define 

Baseline 

Models

Define 

Baseline 

Models

Data 

Collection, &

Interviews

Develop

Engineering

Analysis

Curves

Engineering Analysis Methodology

Engin

ReverseEngineering

EERE-2008-BT-STD-0019 COMMENT 06
Baseline unit efficiencies are defined.

1 2 3

BASELINE

Development of Cost-Efficiency Curves

Engin

Efficiency

Incremental 

Manufacturing Cost

Efficiency Efficien

Incremental 

Manufacturing Cost

Incremental 

Manufacturing Cost

Reverse-engineering defines incremental manufacturing costs associated with raising efficiency to each level above the baseline.

DOE reviewqualifies manufactudata with amanufactusupplied daand publiclavailable d

EERE-2008-BT-STD-0019 COMMENT 06
Engin

Residential Clothes Washer Baseline Mod

Residential Clothes Washers

Modified Energy 

Factor (MEF) 

(ft3/kWh)

Wa

1. Top-loading, compact

(less than 1.6 cubic feet capacity) 0.65 

2. Top-loading, standard

(1.6 cubic feet or greater capacity) 1.26 

3. Top-loading, semiautomatic * * 4. Front-loading 1.72 5. Suds-saving * * 

* DOE is unaware of any information on baseline performance of top-loading semiausuds-saving clothes washers

EERE-2008-BT-STD-0019 COMMENT 06
Engin

Item 5-1 DOE seeks input from interested parties on whether above energy efficiency levels are appropriate for characterizinperformance of baseline units.Item 5-2 DOE seeks input on baseline efficiency levels for toploading semiautomatic and suds-savings clothes washers.Item 5-3 DOE seeks information on the specific technological characteristics of the baseline model for each product class, including the technologies described in the Market and Technosection. Examples of the types of information DOE seeks inclutype of wash basket drive motor and the typical input wattage, well as the type of fill control system.

Request for Comment

EERE-2008-BT-STD-0019 COMMENT 06
Engin

Efficiency-Level Approach for Residential Clothe

• DOE proposes to use an efficiency-level approach for 

residential clothes washers because data indicates a srange of efficiencies for most of the product classes.

• Reverse-engineering will be used to identify cost and e

impacts at efficiency levels including, at minimum, baseEnergy Star standard levels.

• Limited testing will establish the link between specific 

technologies and efficiency levels.

• DOE will seek incremental cost data from manufacture

each efficiency level, supplemented with stakeholder inand publicly available data.

• Cost-efficiency curves will be generated from incremen

for each efficiency level.

EERE-2008-BT-STD-0019 COMMENT 06
Reverse-Engineering Methodology

Engin

Raw 

Materials

Finished Materials

Purchased Parts

Selection 

of Units

Physical 

Teardown

Bill of 

Materials

Assembly 

Processes

Manufacturing 

Cost

Fabrication 

Processes

EERE-2008-BT-STD-0019 COMMENT 06
Engin

• Direct material• Direct labor• Factory overhead• Depreciation

• Sales & marketing• Research & 

development

• Building• Tooling/Equipment

Full 

Production 

Cost

Conversion 

Costs 

(Non-Production Costs)

Manufac

+ = Cost D

Industry Cost Submittal

• Costs will be provided on a shipment-weighted, industryaggregated basis.• Data will not be provided for product classes and/or effic

levels representing fewer than three manufacturers.

• DOE will request information about the depreciation met

manufacturers use to expense conversion capital.

EERE-2008-BT-STD-0019 COMMENT 06
Item 5-4 DOE requests feedback on the use of an efficiency-lapproach to determine the relationship between manufacturer and energy efficiency for residential clothes washers, supplemas needed, by a design-option approach.Item 5-5 DOE requests input on the selection of appropriate pclasses for reverse-engineering analysis, and any product clasfor which it is appropriate to extend these results analytically.

Engin

Request for Comment

EERE-2008-BT-STD-0019 COMMENT 06
Engin

Efficiency Levels

• DOE will conduct the engineering analysis (and LCC and 

analyses) on all product classes for which it suggests efflevels.

• DOE is required to analyze maximum technologically fea

(“max tech”) efficiency levels

– In some cases, DOE defines the highest efficiency level ba

maximum available efficiency currently on the market.

– “Max available” may not correspond to “max tech” if, for ex

some design options are not yet commercially available.

– DOE will seek stakeholder input to resolve this potential dis

EERE-2008-BT-STD-0019 COMMENT 06
Engin

Efficiency Levels for Top-Loading Standard

Residential Clothes Washers

Level Efficiency Level Source Efficiency Level MEF WF

Baseline DOE Standard 1.26 9.501 Gap Fill 1.40 9.50

2 ENERGY STAR 1.72 8.003 CEE Tier 1 1.80 7.50

4 CEE Tier 2 2.00 6.00

5 Max Available* 2.26 4.48

* DOE estimated these values based on data contained within the CEC (or other) res

clothes washer database.

EERE-2008-BT-STD-0019 COMMENT 06
Engin

Efficiency Levels for Top-Loading Compact

Residential Clothes Washers

Level Efficiency Level Source Efficiency Level MEF WF

Baseline DOE Standard 0.65 18.40

1 Max Available* 0.78 13.90

* DOE estimated these values based on data contained within the CEC (or other) res

clothes washer database.

EERE-2008-BT-STD-0019 COMMENT 06
Engin

Efficiency Levels for Front-Loading Reside

Clothes Washers

Level Efficiency Level Source Efficiency Level MEF WF

Baseline ENERGY STAR* 1.72 8.001 CEE Tier 1 1.80 7.50

2 CEE Tier 2 2.00 6.00

3 CEE Tier 3 2.20 4.50

4 Gap Fill 2.40 4.20

5 Max Available** 2.89 3.36

* DOE determined there are no current front-loading residential clothes washers belo

** DOE estimated these values based on data contained within the CEC (or other) resclothes washer database.

EERE-2008-BT-STD-0019 COMMENT 06
Item 5-6 DOE seeks input from interested parties about the adequacy of the proposed efficiency levels for requesting incremental cost data from manufacturers. DOE also seeks inpfrom interested parties on appropriate maximum technologicalfeasible efficiency levels and the basis for why those levels shbe selected.

Engin

Request for Comment

EERE-2008-BT-STD-0019 COMMENT 06
Engin

Proprietary Designs

• DOE will evaluate all design options that are commercia

available or present in a working prototype, including prodesigns and technologies.

• Proprietary designs will only be considered if they do not 

a unique path to a given efficiency level.

• The confidentiality of manufacturers will be maintained.

EERE-2008-BT-STD-0019 COMMENT 06
Item 5-7 Are there proprietary designs or technologies for residential clothes washers of which DOE should be aware in rulemaking? If so, what are these designs and how should DOacquire the cost data necessary for evaluating them?

Engin

Request for Comment

EERE-2008-BT-STD-0019 COMMENT 06
Engin

Outside Regulatory Changes

• Consider the effects on manufacturers of other regulator

changes outside of the standards rulemaking process.

• Example: Some manufacturers in the residential clothes 

industry are subsidiaries of larger parent companies that manufacture other products subject to Federal regulation

– Phase-out of chlorofluorocarbon (CFC) and hydrochloroflu

(HCFC) refrigerants mandated by U.S. Environmental ProtAgency

– DOE standards for residential clothes dryers and room air 

conditioners enacted since 1990

– Reduction of Hazardous Substances (RoHS) EU directive

EERE-2008-BT-STD-0019 COMMENT 06
Item 5-8 Are there additional outside regulatory issues that Dshould consider in its analysis of residential clothes washers? identify what they are and how DOE should consider them for purposes of its analysis.

Engin

Request for Comment

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Steps in the Standards Rulemaking: Pre-NO

Preliminary Manufacturer Impact Analysis

Energy & Water Use Determination

EERE-2008-BT-STD-0019 COMMENT 06
Preliminary Manufacturer Imp

Legislative Requirements

• The Manufacturer Impact Analysis (MIA) fulfills a legislat

requirement to determine if a proposed standard is econjustified.

– EPCA provides 7 factors to evaluate in determining whethe

efficiency standard is justified. Two factors are addressed 

• Economic impact of standards on manufacturers• Impacts of any lessening of competition in the industry

– MIA format changes described in the 2006 report to Congr

http://www.eere.energy.gov/buildings/appliance_standards/2006_schedule_

• DOE will collect, evaluate, and report preliminary MIA d

Pre-NOPR, if manufacturers can supply the requisite in

• Preliminary data include: anticipated conversion capital 

expenditures by efficiency level and anticipated direct eimpacts

EERE-2008-BT-STD-0019 COMMENT 06
Preliminary Manufacturer Imp

Methodology

• The MIA consists of three main phases. In the Pre-NOPR

preliminary MIA focuses on Phase 1 

Industry profile

Phase 2

* Government Regulatory Impact Model (GRIM)

Phase 1 Phase 3

Pre-NOPR 

Preliminary MIA Interviews

Develop straw-man GRIM*

Develop interview guide

Interviews

& industrywide / 

subgroup

analyses

Asemcocubu

EERE-2008-BT-STD-0019 COMMENT 06
Preliminary Manufacturer Impact Analys

• Purpose:

– Provide initial discussion on any potential impacts of energ

conservation standards on manufacturers of residential clodryers and room air conditioners.

– Provide an opportunity to verify DOE market information a

engineering design options.

Preliminary Manufacturer Imp

EERE-2008-BT-STD-0019 COMMENT 06
Preliminary Manufacturer Imp

Methodology: Phase 1

• Consists of the industry profile and preliminary manufact

impact analysis interviews

Industry Profile Industry Profile

» Evaluate current and past industry 

structure and market characteristics

» Produce an industry profile report 

with aggregated findings and characteristics

» Identify critical issues that require 

special consideration in the MIA, for 

example:

» Types or groups of manufacturers» Access to technology» Potential regulatory scenarios

» Evaluate current and past industry 

structure and market characteristics

» Produce an industry profile report 

with aggregated findings and characteristics

» Identify critical issues that require 

special consideration in the MIA, for 

example:

» Types or groups of manufacturers» Access to technology» Potential regulatory scenarios

Preliminary MIA Inter

Preliminary MIA Inte

» Occurs during the engine

analysis

» Topics include:

» Shipment projections» Conversion costs» Product mix and profit» Market shares and ind

consolidation

» Cumulative regulatory 

» Occurs during the enginee

analysis

» Topics include:

» Shipment projections» Conversion costs» Product mix and profita» Market shares and indu

consolidation

» Cumulative regulatory b

EERE-2008-BT-STD-0019 COMMENT 06
LCC and PBP Analysis Inputs

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Steps in the Standards Rulemaking: Pre-NO

Preliminary Manufacturer Impact Analysis

Energy & Water Use Determination

EERE-2008-BT-STD-0019 COMMENT 06
Markups for Equipment Price 

Markups for Equipment Price Determinat

• DOE uses markups to convert manufacturer costs from th

engineering analysis into consumer retail prices.

• DOE needs retail prices for the life-cycle cost and paybac

analysis.

• DOE must characterize distribution channels for each pro

– DOE understands that over 93% percent of consumer prod

distributed from manufacturers directly to retailers.

• DOE develops markups for each party involved in produc

distribution.

• SEC 10-K reports provide data for calculating manufactu• U.S. Census Business Expenditure Survey provides data 

calculating retailer markups.

• DOE will collect retail price data for validation purposes.• DOE will investigate the variability of retail prices.

EERE-2008-BT-STD-0019 COMMENT 06
Markups for Equipment Price 

(Item 7-1) DOE welcomes comments on its proposed approach developing estimates of future retail prices.

Request for Comment

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Steps in the Standards Rulemaking: Pre-NO

Preliminary Manufacturer Impact Analysis

Energy and Water Use Determination

EERE-2008-BT-STD-0019 COMMENT 06
• Purpose:

– Develop annual energy and water use data for the life-cycle c

payback period analyses to calculate annual operating costs.

• Method:

– Develop household samples from DOE-EIA’s Residential Ene

Consumption Survey (RECS) for the three product class to be detail in the Engineering Analysis.

• Front-loading, standard size washers• Top-loading standard size washers• Top-loading compact washers

– Use RECS data along with Engineering Analysis data to deve

energy and water use on a per-household basis.

Energy and Water Use Determination

Energy U

EERE-2008-BT-STD-0019 COMMENT 06
Energy and Water Use Determination Appr

Energy and Water U

Annual Usage

per household

(cycles/year)

+

Water Heater

& Dryer 

Fuel Types 

per household

Annual Energy and 

Water Use by 

efficiency level

Per household

MEF & WF by

efficiency level

from Engineering 

Analysis

+

EERE-2008-BT-STD-0019 COMMENT 06
Energy and Water U

Washer Usage and Capacity

• Usage has been decreasing while capacity has been increasing.• Is larger washer capacity a cause of lower washer usage?• Does the test procedure capture the field energy and water use i

larger washer capacity?

EERE-2008-BT-STD-0019 COMMENT 06
• Purpose:

– DOE will consider the “rebound effect” in its determination 

energy consumption

• Assumptions:

– Rebound effect occurs when a more efficient appliance or 

is used more intensively so the expected savings may not materialize

– No rebound effect for home appliances according to existin

literature, although consumers may choose to purchase lamodels with more features resulting in increased energy us

Rebound Effect

Energ

EERE-2008-BT-STD-0019 COMMENT 06
Item 6-1 DOE seeks input from interested parties on the appropresented for estimating both the typical values and variability in annual energy and water consumption of residential clothes waItem 6-2 DOE seeks comments on the rebound effect associatwith more efficient residential clothes washers. In other words, Dseeks input on what portion of the energy savings resulting from efficient equipment may be lost due to increased usage or conspurchasing larger or more feature-laden clothes washers. DOE interested in receiving any data that may support these comme

Energy U

Request for Comment

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Steps in the Standards Rulemaking: Pre-NO

Preliminary Manufacturer Impact Analysis

Energy & Water Use Determination

EERE-2008-BT-STD-0019 COMMENT 06
• Method:

– LCC equals consumer price plus the sum of annual operating 

(including repair and maintenance costs) discounted to a par

year.

– Economic evaluation from the consumer perspective.– Analysis implemented in an Excel® spreadsheet.

– Results are expressed as LCC difference (baseline minus sta– Payback Period (PBP) is also calculated and reported in this 

Life-Cycle Cost and Payback Period Analy

• Purpose:

– Assess the net life-cycle cost (LCC) impacts of differing efficie

on the consumer.

Life-Cycle Cost and Paybac

EERE-2008-BT-STD-0019 COMMENT 06
Approach

• Monte Carlo simulation analysis to be used.

– Characterize the variability and uncertainty associated with th

using probability distributions.

– RECS household samples will be used to characterize the va

annual energy and water use and energy and water prices.

– Probability distributions will be used to characterize the unce

other operating cost inputs (e.g., discount rates, equipment limanufacturing costs.

• One LCC and PBP analysis result per product class.

– Analysis to be conducted for each proposed product class to 

in detail in the Engineering Analysis.

• Develop base case efficiency distributions to avoid ov

the benefits from increasing product efficiency.

Life-Cycle Cost and Paybac

EERE-2008-BT-STD-0019 COMMENT 06
Efficiency Distributions Example from LCC A

Life-Cycle Cost and Paybac

EERE-2008-BT-STD-0019 COMMENT 06
Base Case Efficiency Distributions

• Avoids overstating the benefits from increasing produ

– Market share data (or base case efficiency distributions) show 

percentage of consumers already purchasing efficient produc

– Requesting market share data for specific efficiency bins.

Life-Cycle Cost and Paybac

Top-Loading – Compact Top-Loading – Standard Front-Load

Efficiency Bins Market Share 2005 or 2006 Efficiency Bins Market Share 2005 or 2006 Efficiency Bins 

(MEF) (WF) (Percent) (MEF) (WF) (Percent) (MEF) (WF) 

0.65 18.40 1.26 9.50 1.72 8.000.78 13.90 1.40 9.50 1.80 7.50

1.72 8.00 2.00 6.001.80 7.50 2.20 4.502.00 6.00 2.40 4.202.25 4.45 2.89 3.36

EERE-2008-BT-STD-0019 COMMENT 06
Item 8-1 DOE seeks input from interested parties on the planned approach of using Monte Carlo simulation and probability distributions to conduct the LCC and PBP anItem 8-2 DOE requests data from interested parties to characterize the current mix of residential clothes washeefficiencies in the market.

Request for Comment

Life-Cycle Cost and Paybac

EERE-2008-BT-STD-0019 COMMENT 06
Life-Cycle Cost and Paybac

LCC and PBP Analysis Inputs

EERE-2008-BT-STD-0019 COMMENT 06
Electricity Prices

• Electricity prices are used to convert energy use to ener• DOE will develop electricity prices from DOE-Energy Inf

Administration (EIA) Form 861 data. 

• DOE will use the DOE-EIA Annual Energy Outlook (AEO

projections of future average energy prices (reference, hlow scenarios). 

• DOE may evaluate other quantitative price projections p

stakeholders as sensitivities.

Life-Cycle Cost and Paybac

EERE-2008-BT-STD-0019 COMMENT 06
Natural Gas and Oil Prices

• Natural gas and oil prices are used to convert energy us

energy costs. 

• DOE will develop natural gas and oil prices from “Natura

Monthly” and “Petroleum Navigator.”

• DOE will use the DOE-EIA Annual Energy Outlook 

(AEO

projections of future average natural gas and oil prices (high, and low scenarios). 

• DOE may evaluate other quantitative price projections p

stakeholders as sensitivities.

Life-Cycle Cost and Paybac

EERE-2008-BT-STD-0019 COMMENT 06
Water Prices

• Water prices are used to convert water use to water cos• DOE will develop water prices from AWWA and Raftelis 

Consultants (RFC). 

• DOE will use historical Bureau of Labor’s Consumer Pri

for Water and Sewerage for projections of future averagprices and historical RFC data. 

• DOE may evaluate other quantitative price projections p

stakeholders as sensitivities.

Life-Cycle Cost and Paybac

EERE-2008-BT-STD-0019 COMMENT 06
Wastewater Prices

• Wastewater prices are used to convert wastewater crea

wastewater costs. 

• DOE will develop wastewater prices from AWWA and R

Financial Consultants (RFC). 

• DOE will use historical Bureau of Labor’s Consumer Pri

for Water and Sewerage and historical RFC data for pro

future average wastewater prices. 

• DOE may evaluate other quantitative price projections p

stakeholders as sensitivities.

Life-Cycle Cost and Paybac

Item 8-3 DOE seeks input from interested parties on the plannapproach for estimating current and forecasted energy, water, wastewater prices.

EERE-2008-BT-STD-0019 COMMENT 06
Maintenance, Repair and Installation Cos

• DOE does not currently have information indicating that ro

and maintenance costs are different for more and less efficwashers.

• Installation costs may change if more efficient products are 

significantly larger or heavier.

Life-Cycle Cost and Paybac

Item 8-4 DOE seeks input from interested parties on whether it correct to assume that changes in maintenance, repair, and installation costs will be negligible for more efficient residential cwashers. If this is incorrect, DOE is interested in the reasons whis so and specific ways to correct this assumption.

EERE-2008-BT-STD-0019 COMMENT 06
Product Lifetimes

• DOE proposes to use an analysis where product lifetimes f

case and standards case are the same.

• Past DOE analyses have used an average product lifetime 

years for clothes washers.

• DOE is investigating whether RECS data can be used to p

another source for clothes washer lifetime.

Life-Cycle Cost and Paybac

Item 8-5 DOE seeks input from interested parties on approplifetimes for the residential clothes washer product classes coin this rulemaking.

EERE-2008-BT-STD-0019 COMMENT 06
Discount Rate

• Discount rates are used to convert streams of annual op

expenses to present value in the LCC analysis.

• DOE will use similar approach as for other residential pro

standards rulemakings.

– Derived from estimates of the “finance cost” to purchase re

products.

– Finance cost based on:

• Financial cost of any debt incurred to purchase products (e.g., credit ca

equity loans)

• Opportunity cost of any equity to purchase products (e.g., stocks, bond

accounts)

– Federal Reserve Board’s Survey of Consumer Finances is 

much of the equity and debt data.

Life-Cycle Cost and Paybac

Item 8-6 DOE seeks input from interested parties on the planapproach for estimating discount rates for residential consume

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Steps in the Standards Rulemaking: Pre-NO

Preliminary Manufacturer Impact Analysis

Energy & Water Use Determination

EERE-2008-BT-STD-0019 COMMENT 06
Shipments Analysis

• Purpose:

– Estimate future product shipments which are inputs to the 

Impacts Analysis and Manufacturer Impact Analysis.

Ship

• Method:

– The shipments model will rely on a range of data sources. – The model will only consider shipments of covered product

EERE-2008-BT-STD-0019 COMMENT 06
Ship

Base-Case Shipments Forecast Approac

• Depicts the situation where new standards are not adopted• Shipments forecasts account for: (1) product sales to new 

construction and (2) replacements for failed units.

• Historical forecasts (‘backcasts’) calibrated to historical sh

– Calibration performed by accounting for product sales to exis

households that do not already own the appliance.

• Data requirements:

– New construction product sales

• New housing construction forecasts: EIA’s Annual Energy Outlo• Historical rates of product ownership (saturation rates): EIA’s RE

Bureau’s AHS, and AHAM’s Fact Book.

– Replacements

• Product lifetimes and retirement functions of LCC and PBP analy

– Historical shipments

EERE-2008-BT-STD-0019 COMMENT 06
Sh

Request for Comment

Item 9-1 DOE seeks data on representative saturation rates foresidential clothes washers.

EERE-2008-BT-STD-0019 COMMENT 06
Ship

Residential Clothes Washer Historical Shipme

• DOE requests historical shipments data in order to calibr

base-case shipments forecasts.

Year

Shipments, Domestic + Imports

(Thousands of Units)

Top-Loading FrontLoading Suds-Saving Compact Standard Semi- automatic

199319941995199619971998199920002001200220032004200620072008

EERE-2008-BT-STD-0019 COMMENT 06
Sh

Request for Comment

Item 9-2 DOE seeks historical shipments data broken down by pclass.

EERE-2008-BT-STD-0019 COMMENT 06
Ship

Standards Impacts on Shipments

• DOE develops Standards-Case Forecasts from the same 

used to develop the Base-Case Forecast.

• Standards-Case Forecasts also use purchase price incre

operating cost savings to estimate shipments impacts.

• It is difficult to obtain data showing sensitivity of shipmen

purchase price and operating costs.

– DOE may forecast Standards-Case shipments forecasts w

scenarios (i.e., specific percentage drops in annual shipmeparticular efficiency levels).

• DOE will consider impacts from market-pull programs.

EERE-2008-BT-STD-0019 COMMENT 06
Sh

Request for Comment

Item 9-3 As part of its preliminary manufacturer impact analysis, input from manufacturers and other interested parties on the poteof new energy conservation standards on product shipments.Item 9-4 DOE also requests input on any market-pull programs ththe adoption of more efficient residential clothes washer products.

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Steps in the Standards Rulemaking: Pre-NO

Preliminary Manufacturer Impact Analysis

Energy & Water Use Determination

EERE-2008-BT-STD-0019 COMMENT 06
• Method:

– Develop annual series of national energy, water, and was

economic impacts.

– Utilize the shipments model to estimate the total stock of a

in service each year.

– Utilize the LCC to estimate cost and energy and water use 

any given year.

– Aggregate the costs and energy and water use for all yea

analysis period.

– Report national energy savings (NES).– Report national water savings (NWS).– Report estimates for economic impact as change in consu

National Net Present Value (NPV) (in constant year dollar

– Account for the time-value of money though defined disco

National Impact Analysis

• Purpose:

– Determine the projected national energy, water, and wast

savings and consumer national net present value.

National I

EERE-2008-BT-STD-0019 COMMENT 06
Base Case

Annual Energy

Consumption

2045

Base Case

Annual Energy

Consumption

2017

Base Case

Annual Energy

Consumption

2016

Base Case

Annual Energy 

& Water

Consumption

2015

National Energy and Water Savings Flow Di

National I

Shipments

Analysis Sta

Cas

Base-Case Projection

Base Case

Annual Ener

Consumptio

Base Case

Annual Energy

Consumption

2017

Base Case

Annual Energy

Consumption

2016

Standards Case

Annual Energy

& Water

Consumption

2015

Base-Case

Cumulative

Energy 

& Water Use

Standards-Case 

Cumulative

Energy 

& Water Use

Site to Source

Energy

Conversion

National Energy

& Water

Savings

EERE-2008-BT-STD-0019 COMMENT 06
National Consumer Net Present Value Flow D

National I

Shipments

Analysis Standa

Case P

Energy & Water

Cost

(2015 –

2045)

Base-Case 

Projection

Cumulative

Operating Cost 

Savings

Cumulative

Total Equipment

Cost Increase

Discount 

Rate

Net Present

Value

Maint &

Repair Cost

(2015 –

2045)

Equipment

Cost

(2015 –

2045)

Energy

& Water Cost

(2015 –

2045)

Maint &

Repair Cost

(2015 –

2045)

EERE-2008-BT-STD-0019 COMMENT 06
National I

Shipment-Weighted Efficiency and

Market Share Efficiency Data

• Shipment-weighted efficiency data:

– Key components of the national impact analysis are depend

shipment-weighted efficiencies.

• Per-unit annual energy and water consumption—needed to dete

NWS.

• Retail price and per-unit annual operating costs—needed to det

– Historical trends in product efficiency help project future prod

efficiencies for the base-case.

• Market share efficiency data

– Historical market share efficiency data help estimate how sta

impact base-case efficiencies.

– Market share data (or base-case efficiency distributions) are 

the LCC and PBP analysis and will also be used in the natioanalysis.

• DOE has assumed a “roll up” scenario to forecast standards im

standards rulemakings.

EERE-2008-BT-STD-0019 COMMENT 06
National I

Residential Clothes Washer Historical Efficien

• DOE requests historical shipment-weighted average efficienc

product class in order to calculate NES, NWS, and NPV.

Shipment-Weighted Average Efficiency 

Year

Top-Loading Front-Loading 

Compact Standard Semi-automatic

(MEF or EF) (WF) (MEF or EF) (WF) (MEF or EF) (WF) (MEF or EF) (WF) (ME

199319941995199619971998199920002001200220032004200620072008

EERE-2008-BT-STD-0019 COMMENT 06
Item 10-1 DOE seeks historical SWEF (EF or MEF and WF) product class. DOE also seeks historical market share data sthe percentage of product shipments by efficiency level for as product classes as possible.Item 10-2 DOE seeks input on its plan to develop NES spreamodels for estimating national impacts of amended energy conservation standards for residential clothes washers. For exare spreadsheet models still the preferred approach for estimanational impacts?

National I

Request for Comment

EERE-2008-BT-STD-0019 COMMENT 06
23

NOPR Analyses

14

Rulemaking OverviewIntroduction

2

Energy Conservation StandardsTest Procedure

3

Introduction

5 NOPR Analyses

4 Pre-NOPR Analyses

6 Closing Remarks

Public Meeting Agenda

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Steps in the Standards Rulemaking: NOP

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

RevisePre-NOPR Analyses

EnvironmeAssessme

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Steps in the Standards Rulemaking: NOP

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

RevisePre-NOPR Analyses

EnvironmeAssessme

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

EERE-2008-BT-STD-0019 COMMENT 06
Life-Cycle Cost Subgroup Analysis

• Purpose:

– Analyze the economic impacts of standards on consumers

subgroups who may be disproportionately impacted compathe general user population.

• Method:

– Extend the LCC analysis to examine the impacts for define

subgroups.

Life-Cycle Cost Sub

EERE-2008-BT-STD-0019 COMMENT 06
Life-Cycle Cost Subgr

Item 11-1 DOE requests input as to which consumer subgroupany, it should consider when devising standards for residential clothes washers.

Request for Comment

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Steps in the Standards Rulemaking: NOP

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

RevisePre-NOPRAnalyses

EnvironmeAssessme

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

EERE-2008-BT-STD-0019 COMMENT 06
Manufacturer Imp

Manufacturer Impact Analysis

• Purpose: 

– Assess the impacts of standards on manufacturers. – Identify and estimate impacts on manufacturer subgroups t

be more severely impacted than the industry as a whole.

– Examine the impact of cumulative regulatory burden on the 

• Method: 

– Analyze industry cash flow and net present value through u

Government Regulatory Impact Model (GRIM).

– Interview manufacturers to refine inputs to the GRIM, deve

subgroup analyses, and address qualitative issues.

EERE-2008-BT-STD-0019 COMMENT 06
Manufacturer Imp

Methodology

• In the NOPR phase, the MIA will consist of phases 2 and 

Phase 1 Phase 2 Phase 3

Pre-NOPR 

Industry profile

* Government Regulatory Impact Model (GRIM)

Preliminary MIA Interviews

Develop straw-man GRIM*

Develop interview guide

Interviews

& industrywide / 

subgroup

analyses

Asemcocubu

EERE-2008-BT-STD-0019 COMMENT 06
Manufacturer Imp

Methodology: Phase 2

• Consists of the strawman GRIM and interview guide pre

Strawman GRIM Strawman GRIM

» Starting point for discussion of 

impacts

» Inputs include:

» Manufacturer prices» Shipment forecasts» Manufacturing cost estimates» Financial information

» Starting point for discussion of 

impacts

» Inputs include:

» Manufacturer prices» Shipment forecasts» Manufacturing cost estimates» Financial information

Interview Guide Prep

Interview Guide Prepa

» Interview topics include:

» Engineering analysis» Shipments model» Cost structure and financ

parameters

» Conversion costs» Cumulative burden» Direct employment impac» Import / Export issues» Consolidation / competitiv» Replacement parts or refu» Impact of the standard’s e

» Interview topics include:

» Engineering analysis» Shipments model» Cost structure and financia

parameters

» Conversion costs» Cumulative burden» Direct employment impact» Import / Export issues» Consolidation / competitive » Replacement parts or refu» Impact of the standard’s ef

EERE-2008-BT-STD-0019 COMMENT 06
Manufacturer Imp

Methodology: Phase 3

• Consists of the manufacturer interviews, subgroup analy

assessment of industry impacts

Manufacturer Interviews Manufacturer Interviews

» Confidential discussion of potential 

impacts resulting from standards, including:

» Obsolescence of existing manufacturing assets» Tooling» Investment

» Confidential discussion of potential 

impacts resulting from standards, including:

» Obsolescence of existing manufacturing assets» Tooling» Investment

Assessment of Imp

Assessment of Imp

» Assess competitive impac

smaller, significant manuf

» Assess cumulative regula

burden on manufacturers amended DOE standards regulatory actions

» Assess impacts on indust

employment levels

» Assess impacts on manu

subgroups

» Assess competitive impac

smaller, significant manufa

» Assess cumulative regulat

burden on manufacturers amended DOE standards regulatory actions

» Assess impacts on industr

employment levels

» Assess impacts on manuf

subgroups

EERE-2008-BT-STD-0019 COMMENT 06
Manufacturer Imp

Cumulative Regulatory Burden

• Regulations that could affect the industries impacted by 

rulemaking include:

– DOE standards for residential clothes washers (existing an

upcoming)

– EPA-mandated phase-out of HCFCs– Reduction of Hazardous Substances (RoHS) directive.

EERE-2008-BT-STD-0019 COMMENT 06
Manufacturer Imp

Item 12-1 DOE seeks comment on appropriate manufacturer subgroups, if any, that DOE should consider in a manufacturer subgroup analysis for residential clothes washers.

Request for Comment

Item 12-2 What other regulations or pending regulations shoulconsider in its examination of cumulative regulatory burden?

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Steps in the Standards Rulemaking: NOP

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

RevisePre-NOPR Analyses

EnvironmeAssessme

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

EERE-2008-BT-STD-0019 COMMENT 06
Utility Impact Analysis

• Purpose:

– Assess the overall impacts on domestic energy supplies th

result from the imposition of standards. 

• Method:

– DOE proposes to use NEMS-BT, a variant of the NEMS (N

Energy Modeling System) developed and used by DOE/EIA Annual Energy Outlook (AEO) report, as the basis of the UImpact Analysis.

– Outputs of the utility impact analysis include forecasts of el

and gas sales, price, and avoided capacity resulting from a comparison of base and standards cases.

– DOE will model the energy savings impacts from amended 

conservation standards using NEMS-BT to generate forecadeviate from the AEO reference case.

Utility I

EERE-2008-BT-STD-0019 COMMENT 06
Utility Imp

Item 13-1 DOE seeks input from interested parties on its planuse NEMS-BT to conduct the utility impact analysis. Is the NEMmodel appropriate for assessment of utility impacts of energy conservation standards? If not, why? What would be a more appropriate model for DOE to use?

Request for Comment

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Steps in the Standards Rulemaking: NOP

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Revise Pre-NOPR Analyses

EnvironmeAssessme

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

EERE-2008-BT-STD-0019 COMMENT 06
Employment Impact Analysis

• Purpose:

– Assess the overall impact on national employment from 

imposition of efficiency standards at differing levels.

– Include both direct and indirect employment impacts.

• Direct employment impacts are estimated in the manufactu

analysis.

• Indirect employment impacts result from shifting consumer 

among goods and services ( “substitution effect”) and chanequipment and energy costs (“income effect”).

• Method:

– DOE intends to use the ImSET (Impact of Sector Energy 

Technologies) model for the evaluation of indirect emploimpacts. (Note: ImSET is an update of IMBUILD.)

Employment Im

EERE-2008-BT-STD-0019 COMMENT 06
Employment Imp

Item 14-1 DOE welcomes feedback on its planned approach fassessing national employment impacts, both direct and indireis interested in whether other tools or factors should be considepart of its analysis. If other tools or factors should be considereplease identify them and explain why, and how, they should be integrated into DOE’s analysis.

Request for Comment

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Steps in the Standards Rulemaking: NOP

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

RevisePre-NOPR Analyses

EnvironmeAssessme

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

EERE-2008-BT-STD-0019 COMMENT 06
Environmental Assessment

• Purpose:

– Estimate national environmental impacts from new energy efficien

for residential clothes washers covered under this rule

• Method:

– DOE intends to use the environmental impacts predicted from the 

modeling analysis used for the Utility Impacts Analysis. The followare assessed: 

• Carbon dioxide (CO2)

– NEMS calculates quantities of U.S. emissions of CO2 from power plants

– DOE will consider the use of monetary values to represent the value of CO2 emiss

• Sulfur dioxide (SO2) 

– Clean Air Act amendments of 1990 cap SO2 emissions

– Any measurable impact from NEMS in terms of the trading price of SO2 in the utility 

• Nitrogen oxides (NOx)

– Clean Air Interstate Rule (CAIR) permanently caps NOx emissions in 28 eastern S

– NEMS calculates quantities of U.S. emissions of NOx from power plants in 22 “non

– For the 28 “capped” States and DC, NEMS will determine any measurable impact 

trading price of NOx in the utility sector

• Mercury (Hg)

– Court actions vacated the Clean Air Mercury Rule (CAMR), which would have capp– DOE is considering approaches to address the issue of Hg emissions in light of the 

Environmen

EERE-2008-BT-STD-0019 COMMENT 06
Item 15-1 DOE invites comments on how to estimate monetary values as

with CO2 emissions reductions or on any widely accepted values that mig

in DOE’s analyses.Item 15-2 DOE seeks input from interested parties on how it should addr

emissions in this rulemaking consistent with the current CAIR requiremenItem 15-3 Because court actions have vacated the CAMR, DOE seeks ininterested parties on how it should address Hg emissions in this rulemakiItem 15-4 DOE seeks input from interested parties on its plans to use NEconduct the environmental impact analysis on the equipment covered by rulemaking. DOE is particularly interested in whether there are any other to the environmental assessment that it should consider and the advantagdisadvantages of each of those approaches.Item 15-5 Are there any other environmental factors DOE should considerulemaking? If so, what are they and why should they be considered?

Request for Comment

Environmen

EERE-2008-BT-STD-0019 COMMENT 06
Framework

Document Pre-NOPR NOPR Final Rule Effective Date

Steps in the Standards Rulemaking: NOP

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

RevisePre-NOPR Analyses

EnvironmeAssessme

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

EERE-2008-BT-STD-0019 COMMENT 06
Regulatory Impact Analysis

• Purpose:

– Explore the potential for non-regulatory alternatives to new e

efficiency standards.

• Method:

– Base the assessment on the actual impacts of any such initi

date, but consider information presented regarding the impaexisting initiative might have in the future.

Regulatory I

EERE-2008-BT-STD-0019 COMMENT 06
23

NOPR Analyses

14

Rulemaking OverviewIntroduction

2

Energy Conservation StandardsTest Procedure

3

Introduction

5 Final Rule4 Pre-NOPR Analyses6 Closing Remarks5 NOPR Analyses

Public Meeting Agenda

EERE-2008-BT-STD-0019 COMMENT 06
In all correspondence, please refer to the Residential Clothes Wa

rulemaking by:

– Framework Document for Residential Clothes Washers– Docket Number EERE-2008-BT-STD-0019, and– Regulatory Identification Number (RIN) 1904-AB90

Email: RCW-2008-STD-0019@ee.doe.gov

Feedback Is Requested 

Especially on Items Identified in Framework Doc

Clos

Postal Mail:

Ms. Brenda Edwards-JonesU.S. Department of EnergyBuilding Technologies Program,

Mailstop EE-2J

1000 Independence Avenue, SWWashington, DC 20585-0121Telephone: (202) 586-2945

Comment period closes September 28, 2009

Courier:

Ms. Brenda Edwards-JonesU.S. Department of EnergyBuilding Technologies Progra

6th Floor

950 L’Enfant Plaza, SWWashington, DC 20024Telephone: (202) 586-2945

EERE-2008-BT-STD-0019 COMMENT 06