Energy Conservation Standards for

Residential Dishwashers, Dehumidifiers, and Cooking 

and Commercial Clothes Washers 

Notice of Proposed Rulemaking (NOPR

Public Meeting 

Building Technologies Program

Office of Energy Efficiency and Renewable Energy

U.S. Department of Energy

November 13, 2008

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

 EE-2006-STD-0127 COMMENT 40.4
 Purposes

• To invite comment on the proposed energy conservation standard level TSL 

conventional cooking products, TSL 3b for microwave ovens, and TSL 3 for 

clothes washers and to request recommendations for alternatives.

• To present methodologies and characterize results for this rulemaking analy• To discuss specific issues related to each analysis;• To seek input from interested parties on methodologies, assumptions, data 

results from the analyses; and

• To describe the next steps.

 Comments from Participants

• Participants are invited to provide summary comments or statements;• Participants are invited to raise additional issues for discussion today; and• NOPR comment period closes December 16, 2008.

Purpose of the Public Meeting and 

Comments From Participants

 EE-2006-STD-0127 COMMENT 40.4
Statutory Authority – the Energy Policy and 

Conservation Act (EPCA) as amended

 The Energy Independence and Security Act of 2007 (EISA) am

EPCA (42 U.S.C. 6295(g)(10),(cc)) to prescribe standards for dand dehumidifiers, so DOE is not proposing standards for the

products.

 The proposed notice addresses the requirements of the follow

which DOE is required to publish a NOPR addressing energy conservation standards for residential electric and gas kitcheand ovens, residential microwave ovens, and commercial clowashers by September 30, 2008.

• DOE’s Report to Congress, which was prepared in response to sectio

Energy Policy Act of 2005 (EPACT 2005) and section 305 of EISA.

• The Consolidated Consent Decree in New York v. Bodman. No. 05 Ci

(S.D.N.Y. filed Sept. 7, 2005) and Natural Resources Defense Counci(No. 05 Civ. 7808 (S.D.N.Y. filed Sept. 7, 2005).

 EE-2006-STD-0127 COMMENT 40.4
DOE Actions on Residential Cooking Products 

Commercial Clothes Washers

 Test Procedures

• Final Rule for residential cooking products published on October 3, 1997, w

several revisions to more accurately measure efficiency. 62 FR 51976.

• Notice of Proposed Rulemaking (NOPR), proposing standby power test met

microwave ovens, published in the Federal Register on October 17, 2008. 

• Final Rule for CCWs, which adopted the EPACT 2005 amendments to EPC

CCWs be rated according to the residential clothes washer test procedure, 

October 18, 2005. 70 FR 60407, 60416.

 Energy Conservation Standards

• Notice of availability of the Framework Document published March 27, 2006• Advance Notice of Public Rulemaking (ANOPR) published November 15, 20

64432.

• Technical Support Document (TSD) posted on DOE website.• Notice of Proposed Rulemaking (NOPR) published in the Federal Register o

2008. 73 FR 62034.

– Issued by DOE on September 30, 2008.– Available to stakeholders for review approximately a month prior to the public mee

• Final Rule scheduled for March 2009.

 EE-2006-STD-0127 COMMENT 40.4
EPCA directs DOE to consider seven factors when 

energy conservation standards

Factor Analysis

1. Economic impact on consumers 

and manufacturers

Life-cycle cost analysisManufacturer impact analysis

2. Lifetime operating cost savings Life-cycle cost analysis3. Total projected energy savings National impact analysis 4. Impact on utility or performance Screening analysis

Engineering analysis

5. Impact of any lessening of 

competition

Manufacturer impact analysis

6. Need for national energy 

conservation

National impact analysis

7. Other factors the Secretary 

considers relevant

Environmental assessmentUtility impact analysisEmployment impact analysis

 EE-2006-STD-0127 COMMENT 40.4
Selection of Proposed Standards – Conventional C

Products

 DOE considered four trial standard levels (TSLs), beginning with 

efficient level (TSL 4) and worked down to a level where the benef

potential standards outweighed the burdens.

• DOE tentatively concludes that at TSL 4, the benefits of energy savings and 

reductions would be outweighed by the potential multi-million dollar negative economic cost to the Nation, the economic burden on consumers, and the laconversion costs that could result

• DOE tentatively concludes that at TSL 3 and TSL 2, the benefits of energy s

emissions reductions would still be outweighed by the economic burden on and the adverse impacts on manufacturers’ INPV.

• At TSL 1, only amended energy conservation standards consisting of presc

requirements to eliminate standing pilots for gas cooktops and gas standard 

be promulgated by DOE. DOE tentatively concludes that TSL 1 saves a sigamount of energy and is technologically feasible and economically justified.

 DOE requests comments on whether it should adopt TSL 1 or som

mix of efficiency levels for the conventional cooking product clas

Prop

 EE-2006-STD-0127 COMMENT 40.4
Prop

Proposed Amended Energy Conservation Standar

Conventional Cooking Products (TSL 1)

Electric Oven/Self-Clean Oven No StandardElectric Oven/Standard Oven with or without a No StandardCatalytic LineGas Oven/Self-Clean Oven No Change to Existing 

No Constant Burnin

Lights

Gas Oven/Standard Oven with or without a Catalytic LineElectric Cooktop/Smooth Elements No StandardElectric Cooktop/Low or High Wattage Open No Standard(Coil) Elements

No Constant Burnin

Lights

Gas Cooktop/Conventional Burners

Proposed Energy Cons

Product Class Standards

 EE-2006-STD-0127 COMMENT 40.4
Selection of Proposed Standard – Microwave O

 DOE considered four TSLs each for energy factor and standby power, b

the most efficient levels (TSL 4a for energy factor and TSL 4b for standbworked down to a level where the benefits of potential standards outweburdens.

• DOE tentatively concludes that at TSL 4a to TSL 1a for energy factor, the benefits o

and emissions reductions would be outweighed by the potential multi-million to mulnegative net economic cost to the Nation, the economic burden on consumers, and conversion costs that could result. DOE tentatively concludes that none of the TSL

oven cooking efficiency are economically justified. Therefore, DOE proposes no st

microwave oven cooking efficiency or energy factor.

• DOE tentatively concludes that at TSL 4b for standby power, the benefits of energy 

gain, and emissions reductions would be outweighed by the potential economic burfrom loss of product utility and the large capital conversion costs that would result in 

for manufacturers.

• DOE tentatively concludes that TSL 3b for standby power saves a significant amou

technologically feasible and economically justified.

 DOE requests comments on whether it should adopt TSL 3b or some ot

power level for microwave ovens, and whether it should adopt some effenergy factor.

Prop

 EE-2006-STD-0127 COMMENT 40.4
Prop

Proposed Amended Energy Conservation Standard for 

Oven Standby Power (TSL 3b)

Maximum Standby Pow

watt

Microwave Ovens with or without Thermal Elements

Proposed Energy Cons

Product Class Standards

 EE-2006-STD-0127 COMMENT 40.4
Selection of Proposed Standards – Commercial C

Washers

 DOE considered five trial standard levels (TSLs), beginning with t

efficient level (TSL 5) and worked down to a level where the benefpotential standards outweighed the burdens.

• DOE tentatively concludes that at TSL 5 and TSL 4, the benefits of energy s

economic benefits, and emissions reductions would be outweighed by the pdisincentivizing consumers to purchase high-efficiency front-loading CCWs 

capital conversion costs that could result in a substantial reduction in manuf

• DOE tentatively concludes that TSL 3 saves a significant amount of energy 

technologically feasible and economically justified.

• At TSL 3, DOE recognizes the potential adverse impacts to the LVM and th

adverse impacts may be significant for CCW market competition. Therefore

carefully consider the Department of Justice’s review of the proposed stand

before issuing its final rule for this product.

 DOE requests comments on whether it should adopt TSL 3 or som

of efficiency levels for the commercial clothes washer product cla

Prop

 EE-2006-STD-0127 COMMENT 40.4
Prop

Proposed Amended Energy Conservation Standard for C

Clothes Washers (TSL 3)

Front-Loading 2.00 Modified Energy Factor/5.5 WatTop-Loading 1.76 Modified Energy Factor/8.3 Wat

Product Class Proposed Energy Conservation Sta

 EE-2006-STD-0127 COMMENT 40.4
 Opening Remarks

• At this time, DOE welcomes opening remarks from interested part

NOPR for residential dishwashers, dehumidifiers, and cooking procommercial clothes washers.

Opening Remarks and Comments from Interes

Parties on the Proposed Energy Conservation Sta

Opening Remarks 

 EE-2006-STD-0127 COMMENT 40.4
Summary of Issues on which DOE seeks comment - NOPR 

Issues for Publ

1. The proposed standards for residential gas kitchen ranges and ovens, microw

CCWs, as well as the proposed “no-standard” standard for residential electric 

and ovens other than microwave ovens;

2. Battery-powered spark ignition modules as a viable alternative to standing pilo

3. The preliminary determination of the technical infeasibility of incorporating mic

cooking efficiency with standby mode and off mode power into a single metric

4. Input and data regarding off mode power for microwave ovens;

5. Input and data on the utility provided by specific features that contribute to mic

standby power, particularly the utility of display technologies and cooking sens

require standby power;

6. Input and data on control strategies available to allow manufacturers to make 

between incorporating standby-power-consuming features such as displays or sensors and including a function to turn power off to these components during 

also, the viability and cost of microwave oven control board circuitry that could 

transistors to switch off cooking sensors and displays.

7. Whether switching or similar modern power supplies can operate successfully 

microwave oven and the associated efficiency impacts on standby power.

 EE-2006-STD-0127 COMMENT 40.4
Summary of Issues on which DOE seeks comment - NOPR 

Issues for Publ

8. The selection of microwave oven standby power efficiency levels for the engin

9. Input and data on the estimated incremental manufacturing costs, as well as a

achieve each standby level for microwave ovens; also, whether there are any 

property or patent infringement issues associated with the design options pres

Technical Support Document (TSD) to achieve each standby level;

10. Input and data on the estimated market share of microwave ovens at different 

consumption levels;

11. The appropriateness of using other discount rates in addition to seven percent 

percent to discount from future emissions reductions.

12. The determination of the anticipated environmental impacts of the proposed ru

the method for valuing the expected CO2 and NOx emissions savings due to tstandards.

 EE-2006-STD-0127 COMMENT 40.4
Proposed Standards

(Issue #1)

Issues for Publ

DOE invites comments on the proposed standards for residenkitchen ranges and ovens, microwave ovens, and CCWs, as wproposed “no-standard” standard for residential electric kitchand ovens other than microwave ovens.

 EE-2006-STD-0127 COMMENT 40.4
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

 EE-2006-STD-0127 COMMENT 40.4
 Purpose

• To characterize manufacturer cost-efficiency relationships for higher efficien

equipment.

• To evaluate design options that improve efficiency relative to the baseline u• Sensitivity analysis to look at current material prices.

 Product classes analyzed

• All residential cooking product and CCW product classes were analyzed.

 Design-option approach for residential cooking products

• DOE updated the cost-efficiency curves from the 1996 TSD for conventiona

products and microwave ovens (energy factor) by the Producer Price Index 

• DOE analytically derived the relationship between microwave oven cost and 

 Efficiency-level approach for commercial clothes washers

• Industry supplied cost-efficiency data for two efficiency levels above the bas• DOE analytically supplemented and validated this data to extend the cost-e

over all efficiency levels for both product classes.

Engin

Engineering Analysis

 EE-2006-STD-0127 COMMENT 40.4
Gas Cooking Product Ignition Systems

(Issue #2)

 There is currently a prescriptive standard prohibiting constant b

pilots on gas ranges and ovens that are equipped with an electsupply cord.

 The proposed cooking product standard would eliminate stand

on all gas cooking products.

 DOE has tentatively identified battery-powered spark ignition s

a viable alternative:

• Battery-powered ignition systems are available on other products 

instantaneous gas water heaters, barbecues, and furnaces.

• Such systems appear to meet safety standards of ANSI Z21.1

Engin

DOE invites comments on the viability of battery-powered spamodules as an alternative to standing pilot ignition systems.

 EE-2006-STD-0127 COMMENT 40.4
Technical Infeasibility of Incorporating Standby Po

Off Mode Power into Microwave Oven Energy Des

(Issue #3)

 DOE and AHAM data showed no correlation between cooking efficiency 

known feature such as output power or cavity size.

 Test-to-test variability in cooking efficiency was several EF percentage 

compared to a total range in the test sample of 55-62%.

 DOE found that combining the per-cycle measurement of EF, measured 

period of seconds, with standby and off mode energy consumption, memultiple hours, is not representative of the energy efficiency of the microver either a very short or extended period of time.

 DOE believes that, while mathematically possible, it would be technical

incorporate two disparate and largely incompatible metrics of similar maand standby power) into a combined energy efficiency metric that produmeaningful result.

Engin

DOE invites comments on the preliminary determination of the infeasibility of incorporating microwave oven cooking efficiencstandby mode and off mode power into a single metric.

 EE-2006-STD-0127 COMMENT 40.4
Microwave Oven Off Mode Power

(Issue #4)

 “Standby mode” is defined as “the condition in which an energy-us

• (I) is connected to a main power source; and• (II) offers 1 or more of the following user-oriented or protective funct

– (aa) To facilitate the activation or deactivation of other functions 

active mode) by remote switch (including remote control), interntimer. 

– (bb) Continuous functions, including information or status displa

clocks) or sensor-based functions.” (42 U.S.C. 6295(gg)(1)(A)(ii

 “Off mode” is defined as “the condition in which an energy-using p

• (I) is connected to a main power source; and• (II) is not providing any standby mode or active mode function.” (42 

6295(gg)(1)(A)(ii))

 DOE observed no off mode power consumption in its test sample of micr

DOE’s research suggests that no microwave ovens available in the Uniteconsume energy in an off mode.

Engin

DOE invites comments on, and input and data regarding, off mfor microwave ovens. 

 EE-2006-STD-0127 COMMENT 40.4
Utility of Microwave Oven Features that Contrib

Standby Power (Issue #5)

 Cooking Sensors

• Typically consume 1-2 W and require several minutes for warm-up• DOE has identified several types of zero-standby-power sensors, at least one 

believes has zero incremental cost and is being developed for microwave ove

 Display Technologies

• Light-Emitting Diode (LED)• Liquid Crystal Display (LCD) with or without backlighting• Vacuum Fluorescent Display (VFD)

 Power Supplies and Control Board Options

• Upgraded power supply components• Lower-power components• Switching power supplies

Engin

DOE invites comments on, and input and data regarding, the uprovided by specific features that contribute to microwave ovepower, particularly display technologies and cooking sensors require standby power.

 EE-2006-STD-0127 COMMENT 40.4
Microwave Oven Automatic Power-Down Func

(Issue #6)

 Very low (less than 1 W) standby power levels could be met acc

the EISA 2007 and IEC 62301 definitions of “standby mode” by incorporating an automatic function that turns off most power-cocomponents once a period of inactivity has elapsed.

 DOE has determined a large number of microwave ovens in oth

such as Japan, implement this feature.

Engin

DOE invites comments on, and input and data regarding, controstrategies available to allow manufacturers to make design tradbetween incorporating standby-power-consuming features sucdisplays or cooking sensors and including a function to turn pothese components during standby mode; also, the viability and microwave oven control board circuitry that could accommodatransistors to switch off cooking sensors and displays.

 EE-2006-STD-0127 COMMENT 40.4
Microwave Oven Power Supplies

(Issue #7)

 Switching power supplies offer the highest conversion efficienci

percent) and lowest no-load standby losses (0.2 W or less).

 They also have higher cost, higher part count, and greater com Switching power supplies are as-yet unproven in long-term mic

applications, and the greater complexity of these power supplielower overall reliability. 

Engin

DOE invites comments on whether switching or similar modern supplies can operate successfully inside a microwave oven anassociated efficiency impacts on standby power.

 EE-2006-STD-0127 COMMENT 40.4
Microwave Oven Standby Power Levels

(Issue #8)

Engin

DOE invites comments on the selection of microwave oven stalevels for the engineering analysis.

4 Max-Tech 0.023 IEA 1-Watt Program 1.02 Gap Fill 1.5

2.0 FEMP Procurement Efficiency Recommendation

1Baseline Baseline 4.0

Standby Power 

(W) Standby Level Source Standby Level

 EE-2006-STD-0127 COMMENT 40.4
Microwave Oven Cost versus Standby Powe

(Issue #9)

Engin

DOE invites comments on, and input and data regarding, the esincremental manufacturing costs, as well as approaches to achstandby level for microwave ovens; also, whether there are anintellectual property or patent infringement issues associated wdesign options presented in the Technical Support Document (achieve each standby level.

• Auto power-down for all display technologies• Level 2 +

• Upgraded relays or switching power supply for LED

• Upgraded relays + switching power supply for backlit LCD

• Auto power-down for VFD• Level 1 + 

• Upgraded power supply for LED• Upgraded relays for VFD

• Zero-standby cooking sensor• Upgraded power supply for backlit LCD and VFD• Cooking sensor + any display technology

Approach

4 3 2 1 

Baseline 

Standby Level I

 EE-2006-STD-0127 COMMENT 40.4
Request for Additional Comments

Publ

DOE invites comments on any other issues pertaining to the Engineering Analysis.

 EE-2006-STD-0127 COMMENT 40.4
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

 EE-2006-STD-0127 COMMENT 40.4
 Energy Use Characterization

• To develop energy (and water) consumption savings estimates fo

product efficiency levels. 

 Markups for Equipment Price Determination

• To characterize the channels for how equipment is distributed fro

manufacturer to the customer.

• To determine prices paid by customers based on manufacturer se

for baseline and higher efficiency equipment.

 Life-Cycle Cost and Payback Period Analyses

• To develop the customer life-cycle cost savings and payback peri

efficiency equipment.

Purpose

 EE-2006-STD-0127 COMMENT 40.4
Approach

 Conventional Cooking Products

• Annual energy use has been in decline since 1970s.• 2004 California Residential Appliance Saturation Survey and Flor

Energy Center used to estimate annual energy use.

 Microwave Ovens

• Annual energy use has been relatively steady since the late 1980• 2004 California Residential Appliance Saturation Survey used to e

annual energy use.

 Commercial Clothes Washers

• Based on per-cycle energy and water use multiplied by the cycles • Number of cycles per year based on various studies.

– Multi-Family: Average = 3.4; Range = 1 to 10.9.– Laundromats: Average = 6; Range = 3 to 8.

Energy Use C

 EE-2006-STD-0127 COMMENT 40.4
Distribution Channels, Inputs and Results 

Markups to Determine E

 Conventional Cooking Products and Microwave Ovens

• Based on AHAM Fact Book; Over 93 percent of sales through retail outlet• Markups estimated assuming all products purchased from retail outlets.• Overall baseline markup = 1.95; overall incremental markup = 1.55.

 Commercial Clothes Washers

• Based on data from CEE, overwhelming majority of products sold through 

route operators.

– Laundromats generally purchase product through distributors.– Multi-family housing and large institutions generally lease equipment through ro

• Based markup calculations only on the distribution channel involving distr

– Assumed resulting equipment prices would be representative of prices paid by 

acquiring equipment from route operators.

• Overall baseline markup = 1.93; overall incremental markup = 1.59.

Manufacturer Retailer Consumer

Manufacturer

Distributor Laundromat

Route Operator Multi-Family Housing

Consumer

 EE-2006-STD-0127 COMMENT 40.4
 LCC equals consumer price plus the sum of operating costs disc

particular base year.

 Economic evaluation from the customer perspective. Analysis implemented in an Excel® spreadsheet combined with C

 Analysis models the uncertainty and variability of inputs using M

simulation and probability distributions.

• For the residential products, household samples created from 2001 Residen

Consumption Survey to characterize the variability in energy use and/or ene

 Results are expressed as LCC savings (baseline minus standard  Simple payback period (in years) is also calculated and reported i

analysis.

Life-Cycle Cost and Payback P

Approach

Combine Changes 

in Costs 

Installed Cost

(Customer Price + Installation Cost)

Operating Expenses

Convert 

to Present 

Value

 EE-2006-STD-0127 COMMENT 40.4
Life-Cycle Cost and Payback P

 Electricity Prices

• Based on EIA Form 861 Data.• Developed for 13 Regions: 9 Census Divisions and 4 Large State

 Natural Gas Prices

• Based on data from EIA’s Natural Gas Monthly.• Developed for 13 Regions: 9 Census Divisions and 4 Large State

 Water and Wastewater Prices

• Based on data from Raftelis Consultants and AWWA.• Developed for 4 Census Regions due to data limitations.

 Energy Price Forecasts

• Based on 2008 Annual Energy Outlook.

 Water and Wastewater Price Forecasts

• Projections from 1970-2006 based on CPI national water price ind

average).

• Price projections to 2042 based on average growth rate from 197

Energy and Water Prices

 EE-2006-STD-0127 COMMENT 40.4
Life-Cycle Cost and Payback P

 Conventional Cooking Products

• Installation Cost: Base cost = $146 based on RS Means.

– Additional installation cost for installing an electrical outlet for gas cooking 

not use electricity.

– National Electrical Code indicates that only pre-1960 homes need outlet.

 ~55% of RECS household sample with gas cooktops and standard ovens 

– RS Means estimate for installing GFCI outlet with grounding = $235.– Weighted average installation cost = $130.– Only gas standard (non-self-cleaning) ranges are sold with standing pilots; 

shared equally by gas cooktop and gas standard oven installations.

• Repair and Maintenance Costs: Determined only for gas cooking prod

on type of ignition system.

– Standing Pilot: One-time $126 cost in the 10th year of product’s life.

– Glo-bar/hot surface: $147 cost every 5th year of product’s life.

– Electronic spark: One-time $178 cost in the 10th year of product’s life.

 Microwave Ovens

• No installation costs; No maintenance costs.

 Commercial Clothes Washers

• Installation Cost: Base cost = $186 based on RS Means.• Repair and Maintenance Costs: Annualized cost a function of 1⁄2 consu

price divided by product lifetime.

Installation, Repair and Maintenance Costs

 EE-2006-STD-0127 COMMENT 40.4
Discount Rates and Product Lifetime

Life-Cycle Cost and Payback P

 Discount Rates

• Based on the finance cost of raising funds to purchase appliances.

– Financial cost of any debt incurred to purchase equipment.– Opportunity cost of any equity used to purchase equipment.

• Residential Conventional Cooking Products and Microwave Ovens

– New Housing = Average real mortgage rate = 3.2%.– Replacements = Weighted-average real rate associated with various household 

bonds, stocks, CDs) and debt (e.g., credit card, home equity loans) = 5.5%.

– Primary data source: Federal Reserve Board’s Survey of Consumer Finances f

1992, 1995, 1998, 2001, and 2004.

• Commercial Clothes Washers

– Calculated from the weighted-average cost of capital to the firm (WACC) to obt

financing.

– Weighted-average real value = 5.7% for purchasers of commercial clothes was

 Product Lifetime

• Based on various sources including Appliance magazine and past DOE TSDs.• Conventional Cooking Products: Min = 10 (elec), 12 (gas); Average = 19; Max = 28 • Microwave Ovens: Min= 7; Average = 9; Max = 10.• Commercial CW: Min = 7 (MF), 5 (Laund); Avg = 11.3 (MF), 7.1 (Laund); Max = 15• All product lifetimes characterized with Weibull distribution.

 EE-2006-STD-0127 COMMENT 40.4
Equipment Assignment in the Base Case

1a* 0.0583 8.2%

6 0.0600 0%5 0.0596 0%4 0.0593 0%3 0.0572 0%

2 0.420 0% 2 0.0566 0%1 0.399 93.2% 1* 0.0536 74.2%

Baseline 0.156 6.8% Baseline 0.0298 17.6%

Level EF Market Share Level EF Market Share

Gas Cooktops Gas Standard Ovens

Top-Loading Front-Loading

3 1.76 8.30 3.0% 3 2.20 5.10 1.5%

0.0%

33.3%63.6%

Market Share

8.509.509.50

WF

1.601.421.26

MEF

21

Baseline

Level

4 2.35 4.40 1.5%2 2.00 5.50 85.3%1 1.80 7.50 4.4%

Baseline 1.72 8.00 7.4%

Level MEF WF Market Share

Life-Cycle Cost and Payback 

Conventional Cooking Products

Commercial Clothes Washers

 Based on historical 

AHAM.

 Electric coil and sm

Electric standard anGas self-clean ovenovens assumed to at baseline levels.

 Based on distributi

reported in CEC dat

4a 0.602 4.0 0%3a 0.597 4.0 0%2a 0.588 4.0 0%1a 0.586 4.0 0%4b 0.557 0.02 0%3b 0.557 1.0 0%2b 0.557 1.5 19.2%1b 0.557 2.0 34.6%

Baseline 0.557 4.0 46.2%

Level EF Standby Power (WP) Market Share

Microwave Ovens

 Based on distributio

consumption of 52 AHAM and DOE.

 Avoids overstating the benefits from increasing product efficiency by showing 

of consumers already purchasing efficient products.

 EE-2006-STD-0127 COMMENT 40.4
Issues for which DOE seeks comments

(Issue #10)

DOE seeks input and data on the estimated market share of movens at different standby power consumption levels. 

Life-Cycle Cost and Payback 

 DOE estimated the market share of microwave ovens at differen

power consumption levels on a limited set of tested units.

 A different set of market shares could affect the percent of consu

benefiting from a standard that limits standby power.

 EE-2006-STD-0127 COMMENT 40.4
Life-Cycle Cost 

Conventional Gas Cooking Products

Average LCC Savings vs. Installed Cost

($90)($75)($60)($45)($30)($15)

$0

$15

$300 $325 $350 $375 $400 $425 $450 $475 $500 $

Installed Cost

Average LCC Savings

Baseline

Level 1a(Spark Ignition)

Level 1(Globar Ignition)

Level 2 Level 3

Level 4 Level 

Lev

Baseline

Level 1 (Spark Ignition)

Level 2

Gas Cookotps

Gas Standard Ovens

 EE-2006-STD-0127 COMMENT 40.4
Life-Cycle Cost 

Microwave Ovens

Average LCC Savings vs. Installed Cost

($35)($30)($25)($20)($15)($10)

($5)

$0$5

$10$15$20

$200 $210 $220 $230 $240 $250 $260 $270 $280 $290 $

Installed Cost

Average LCC SavingsBaseline: 4 W Level 1a Level 2a Level 3a

Level 4a

Level 1b: 2 W

Level 2b: 1.5 W

Level 3b: 1 W Level 4b: 0.02 W

Standby Power Levels

EF Levels

 EE-2006-STD-0127 COMMENT 40.4
Life-Cycle Cost 

Commercial Clothes Washers

Average LCC Savings vs. Installed Cost

($25)

$0

$25$50$75

$100$125$150$175$200$225$250

$650 $750 $850 $950 $1,050 $1,150 $1,250 $1,350 $1

Installed Cost

Average LCC Savings

Baseline

Level 1

Level 2

Level 3

Level 4

Baseline

Level 1

Level 2

Top-Loading

Front-Loading

Level 3

 EE-2006-STD-0127 COMMENT 40.4
Request for Additional Comments

Publ

DOE invites comments on any other issues pertaining to the Use, Markups, and Life-Cycle Cost and Payback Period Analy

 EE-2006-STD-0127 COMMENT 40.4
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

 EE-2006-STD-0127 COMMENT 40.4
Purpose

 Shipments Analysis

• To estimate cooking product and commercial clothes washer ship

over time.

 National Impact Analysis

• To estimate the National Energy Savings (NES) from cooking prod

commercial clothes washer energy conservation standards at diffeefficiency levels.

• To estimate the national economic impact on the nation (or the Ne

Value (NPV)) from home appliance energy conservation standarddifferent efficiency levels.

Ship

 EE-2006-STD-0127 COMMENT 40.4
Approach

Ship

 Estimate base-case shipments forecasts (2012–2042)

• Develop a shipments model that accounts for shipments to:

– New construction: New housing construction forecasts multiplied by hist

product ownership.

– Replacements: Product retirement functions (product lifetimes) applied t

• Historical shipments used to calibrate shipments model.

– Cooking products: Early replacements.– Commercial clothes washers: Non-replacements (retired units not repla

 Estimate standards-case shipments forecasts (2012–2042)

• Developed with same data as used to estimate base-case forecasts• Accounts for purchase price and operating cost changes due to sta

as household income.

• Purchase price effects dominate.• Shipments forecasted to drop due to standards but consumers are 

be less sensitive to initial changes in purchase price.

 EE-2006-STD-0127 COMMENT 40.4
Cooking Products

Shipments A

02468

10121416182022

1985 1995 2005 2015 

Year

Shipments (million)

Base CaseStandards Case

 Example Standard Level = 1 W Sta

 Conventional Cooking Products  Microwave Ovens

• Complete market saturation; no 

drop in shipments due to standards forecasted.

• No equipment switching.• Elimination of standing pilot ignition 

in gas cooking products estimated not to cause fuel switching to electric cooking; cost of electrical outlet to accommodate electric cooking products is over 5 times greater than outlet for gas cooking products.

 EE-2006-STD-0127 COMMENT 40.4
Commercial Clothes Washers

Shipments A

0.000.010.020.030.040.050.06

1985 1995 2005 2015 

Year

Shipments (million)

0.000.050.100.150.200.25

1985 1995 2005 2015 2025 2035

Year

Shipments (million)

Base CaseStandards Case

Top-Loading Washers Front-Loading Wa

 Example Standard Level = 1.76 MEF, 8.3 WF

 Example Standard Level = 

 EE-2006-STD-0127 COMMENT 40.4
 National energy savings calculated from 2012-2042.

 National NPV calculated for product shipments entering the building stock  Base case incorporates the penetration of higher efficiency products. Standards “roll up” inefficient products but do not affect efficient products

Approach

National 

Example: Gas Standard Ovens

SWEF (EF) 0.0498 0.0540 0.0566 0.0572 0.0593 0.0596 0.060

1a* 0.0583 8.2% 8.2% 0% 0% 0% 0% 0% 

6 0.0600 0% 0% 0% 0% 0% 0% 100% 

5 0.0596 0% 0% 0% 0% 0% 100% - 4 0.0593 0% 0% 0% 0% 100% - - 

3 0.0572 0% 0% 0% 100% - - - 2 0.0566 0% 0% 100% - - - - 

1* 0.0536 74.2% 91.8% - - - - - 

Baseline 0.0298 17.6% - - - - - - 

1 2 3 4 5 6 

Candidate Standard Level Base Case

Market Shares

EF

Candidate 

Standard 

Level

 Once a standard is in place, old equipment goes out of the inventory according 

efficiency mix. New equipment is sold to replace equipment according to the n

mix.

 Use national average equipment prices, annual energy use, energy prices, annu

maintenance expenditures from LCC analysis. Streams of energy use and total 

over analysis time periods and costs discounted to the present.

 EE-2006-STD-0127 COMMENT 40.4
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

 EE-2006-STD-0127 COMMENT 40.4
 Purpose

• To develop a list of standard levels from which impacts are weighed and a pro

level is selected.

– Each trial standard level consists of a set of potential minimum efficiency 

all product classes, and may vary between product classes; and

– NOPR analyses assess impacts for trial standard levels (not product cla

 Method 

• Trial standard levels are assembled from the product classes identified in the 

– Analyzed standard levels cover a range of efficiencies and can include:

 Most energy efficient level (max tech); Efficiency level with the lowest life-cycle cost; Efficiency level with a payback period of three years or less;

 Efficiency levels with noteworthy technologies; and Efficiency levels that fill in large gaps between candidate standard 

– Each trial standard level consists of the analyzed standard level from ea

that meets one of the above criteria.

• “Mixed” TSLs were constructed based on NPV results for product classes.

Trial S

Selection of Trial Standard Levels

 EE-2006-STD-0127 COMMENT 40.4
Trial S

Trial Standard Levels for the NOPR

Conventional Cooking Products

* Gas self-cleaning ovens are already required to use pilotless ignition systems because they are equipped with power cords.

0.0625 

No New Standard* (Baseline) No New Standard* (Baseline) Gas Self-Cleaning Ovens

Gas Standard Ovens No Pilot No Pilot No Pilot 

Electric Self-Cleaning Ovens No Standard (Baseline) No Standard (Baseline) No Standard (Base

Electric Standard Ovens No Standard (Baseline) 0.1163 0.1163 Gas Cooktops No Pilot No Pilot No Pilot Electric Smooth Cooktops No Standard (Baseline) No Standard (Baseline) No Standard (BaseElectric Coil Cooktops No Standard (Baseline) 0.769 0.769 

Product class TSL 1 TSL 2 TSL 3 

Trial standard levels (EF)

Microwave Oven Energy Factor

EF 0.586 0.588 0.597 0.602

TSL 1a TSL 2a TSL 3a TSL 4a

Trial standard levels

Microwave Ovens Standby Power

2.0 1.5 1.0 0.02 Standby Power (W)

TSL 1b TSL 2b TSL 3b TSL4b

Trial standard levels

Commercial Clothes W

WF 7.5 5.5 5.5 MEF 1.80 2.00 2.00 Front-Loading

WF 9.5 8.5 8.3 MEF 1.42 1.60 1.76 Top-Loading

TSL 1 TSL 2 TSL 3 

Trial Standard 

 EE-2006-STD-0127 COMMENT 40.4
NPV Results by TSL

 Conventional Cooking Products

• TSLs 1 through 3 provide a positive NPV ranging from $0.22 Billio

Billion at 7 percent discount rate.

• TSL 4 provides a negative NPV of -$12.55 Billion at 7 percent disc

 Microwave Ovens

• TSLs 1a through 4a provide a negative NPV ranging from -$0.61 B

-$4.94 Billion at 7 percent discount rate.

• TSLs 1b through 4b provide a positive NPV ranging from $0.91 Bi

$1.61 Billion at 7 percent discount rate. 

 Commercial Clothes Washers

• TSL 1 provides a negative NPV of -$0.001 Billion at 7 percent disc• TSLs 2 through 5 provide a positive NPV ranging from $0.32 Billio

Billion at 7 percent discount rate.

National 

 EE-2006-STD-0127 COMMENT 40.4
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

 EE-2006-STD-0127 COMMENT 40.4
Consumer Subgroup Analysis

Consumer Su

 Purpose

• To evaluate the economic impacts of standards on consumer subgroups who 

disproportionately impacted compared with the general user population.

 Method

• For cooking products, DOE identified low-income consumers and seniors as s

could be disproportionately affected, and examined the impact of proposed st

them.

• For commercial clothes washers, DOE identified small businesses and consu

municipal water and sewer that could be disproportionately affected, and exam

of proposed standards on this them.

• DOE used the LCC spreadsheet model to determine the impact on the cookin

commercial clothes washer subgroups.

 Output

• LCC savings and simply payback period (in years) for the identified customer • Determined that the subgroups were not disproportionately impacted by the s

 EE-2006-STD-0127 COMMENT 40.4
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

 EE-2006-STD-0127 COMMENT 40.4
Manufacturer Impact Analysis

Manufacturer I

 Purpose

• To assess the impacts of standards on residential cooking product and comm

washer manufacturers;

• To identify and estimate impacts on manufacturer sub-groups that may be m

impacted than the industry as a whole;

• Two manufacturers of gas ranges, ovens, and cooktops with standing p

classified as small businesses by the SBA.

• One “Low-Volume Manufacturer” (LVM) is focused on the commercial la

business and has much lower revenues than its larger competitors in thclothes washer market.

• To examine the impact of cumulative regulatory burdens on the industry.

 Method 

• Analyze industry cash flow and net present value through use of the Governm

Regulatory Impact Model (GRIM); and

• Interview manufacturers to refine inputs to the GRIM, develop sub-group ana

address qualitative issues.

 EE-2006-STD-0127 COMMENT 40.4
Manufacturer Impact Analysis Process

Manufacturer I

 The MIA consists of three phases:

Industry profile

Develop straw-man GRIM*

Develop interview guide

Interviews

& industrywide / 

subgroup

analyses

Assess direct employment, competition, cumulative burden

Phase 2

* Government Regulatory Impact Model (GRIM)

Phase 1 Phase 3

 EE-2006-STD-0127 COMMENT 40.4
INPV Results by TSL

 Change in INPV analyzed for two scenarios:

• Cooking Products

– Preservation of Gross Margin Percentage Markup– Preservation of Gross Margin Absolute Dollars Markup

• Commercial Clothes Washers

– Preservation of Gross Margin Percentage Markup with Base Case Shipments– Preservation of Gross Margin Percentage Markup with Price Elasticity of Demand 

 Conventional Cooking Products

• Gas cooktops: INPV ranges from -$5 million to -$12 million at TSL 1 to $28 million to -$• Electric cooktops: INPV ranges from $0 at TSL 1 to $77 million to -$383 million at TSL • Gas ovens: INPV ranges from -$7 million to -$10 million at TSL 1 to -$47 million to -$18• Electric ovens: INPV ranges from $0 at TSL 1 to -$10 million to -$469 million at TSL 4.

 Microwave Ovens

• Energy Factor: INPV ranges from $44 million to -$199 million at TSL 1a to $267 million 

TSL 4a.

• Standby Power: INPV ranges from -$22 million to -$26 million at TSL 1b to -$35 million 

4b.

 Commercial Clothes Washers

• INPV ranges from $4 million to $3 million at TSL 1 to -$30 million to -$32 million at TSL 5

Manufacturer 

 EE-2006-STD-0127 COMMENT 40.4
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

 EE-2006-STD-0127 COMMENT 40.4
 Purpose

• To investigate the effects on utilities from reduced energy sales and peak load 

potential standards.

 Method 

• Use National Energy Savings Results; and• Use the EIA’s National Energy Modeling System (NEMS-BT) tailored for DOE’

Technologies Program.

 Output

• Change in electricity and gas sales and price by region;• Change in the mix of electricity generation; and• Change in installed capacity and generation.

Utility Im

Utility Impact Analysis

 EE-2006-STD-0127 COMMENT 40.4
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

 EE-2006-STD-0127 COMMENT 40.4
 Purpose

• To report net jobs created or eliminated nationally as a consequence of new or 

energy conservation standards. Employment impacts include direct and indirec

 Method 

• Uses the Impact of Sector Energy Technologies (ImSET) model to assess the 

employment impacts;

• Estimate changes in employment, industry output, and wage income in the ove

States economy resulting from changes in expenditures in the various sectors economy;

• Estimate changes in costs and benefits using the NIA analysis; and• Direct employment impacts are addressed in the Manufacturer Impact Analysis 

 Output

• Change in employment in national economy, other than in the manufacturing s

regulated, as a consequence of the amended energy conservation standards.

Employment I

Employment Impact Analysis

 EE-2006-STD-0127 COMMENT 40.4
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

 EE-2006-STD-0127 COMMENT 40.4
 Purpose

• To report environmental impacts as a consequence of the amended energy co

standards, including changes in power plant emissions.

 Output

• Calculated the reduction in power plant emissions of carbon dioxide (CO2), oxi

(NOX) and mercury (Hg), using the NEMS-BT computer model.

• Calculated the reduction in on-site emissions (CO2 and NOX) where gas applia

(i.e., gas cooking products and gas water heating and drying for commercial cl

• Sulfur dioxide (SO2) emission was not included due to the emission cap set by 

Act Amendments of 1990. Impact on SO2 emissions changes was estimated a

affect value of emissions allowances under the cap.

• Monetized value of reductions in CO2, NOX, and Hg.• Assessed impact to SO2 allowance prices.

Environment

Environmental Assessment

 EE-2006-STD-0127 COMMENT 40.4
Issues for which DOE seeks comments

(Issues #11 and #12)

DOE seeks comment on the appropriateness of using other discouaddition to seven percent and three percent real to discount future reductions. 

DOE seeks comment on the determination of the anticipated enviroimpacts of the proposed rule, particularly with respect to the methvaluing the expected CO2, NOX, and Hg emissions savings due to t

proposed standards. 

Environment

 DOE believes that discounted environmental benefits represent a policy 

wherein benefits farther in the future are less significant than energy savto the present.

 DOE has made several additions to its monetization of environmental em

reductions in today’s proposed rule, but has chosen to continue to repor

benefits separately from the net benefits of energy savings.

 Nothing in EPCA, nor in the National Environmental Policy Act, requires 

economic value of emissions reduction be incorporated in the net presenanalysis of the value of energy savings. 

 Unlike energy savings, the economic value of emissions reduction is not 

marketplace. 

 EE-2006-STD-0127 COMMENT 40.4
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

 EE-2006-STD-0127 COMMENT 40.4
 Purpose

• To investigate the national impacts due to non-regulatory alternatives comp

mandatory energy conservation standards.

• The non-regulatory alternatives that DOE analyzed include: 

– No New Regulatory Action;– Consumer Rebates;– Commercial Customer Tax Credits; – Voluntary Energy-Efficiency Targets—ENERGY STAR;– Manufacturer Tax Credits;– Early Replacement; and – Bulk Government Purchases.

 Method

• Modify NIA spreadsheet model to consider the above scenarios and assess 

adoption of products at the proposed standard levels.

 Output

• National Energy Savings and Net Present Value of the non-regulatory altern

Regulatory Im

Regulatory Impact Analysis

 EE-2006-STD-0127 COMMENT 40.4
Summary of Issues on which DOE seeks comment - NOPR 

Issues for Publ

1. The proposed standards for residential gas kitchen ranges and ovens, microw

CCWs, as well as the proposed “no-standard” standard for residential electric 

and ovens other than microwave ovens;

2. Battery-powered spark ignition modules as a viable alternative to standing pilo

3. The preliminary determination of the technical infeasibility of incorporating mic

cooking efficiency with standby mode and off mode power into a single metric

4. Input and data regarding off mode power for microwave ovens;

5. Input and data on the utility provided by specific features that contribute to mic

standby power, particularly the utility of display technologies and cooking sens

require standby power;

6. Input and data on control strategies available to allow manufacturers to make 

between incorporating standby-power-consuming features such as displays or sensors and including a function to turn power off to these components during 

also, the viability and cost of microwave oven control board circuitry that could 

transistors to switch off cooking sensors and displays.

7. Whether switching or similar modern power supplies can operate successfully 

microwave oven and the associated efficiency impacts on standby power.

 EE-2006-STD-0127 COMMENT 40.4
Summary of Issues on which DOE seeks comment - NOPR 

Issues for Publ

8. The selection of microwave oven standby power efficiency levels for the engin

9. Input and data on the estimated incremental manufacturing costs, as well as a

achieve each standby level for microwave ovens; also, whether there are any 

property or patent infringement issues associated with the design options pres

Technical Support Document (TSD) to achieve each standby level;

10. Input and data on the estimated market share of microwave ovens at different 

consumption levels;

11. The appropriateness of using other discount rates in addition to seven percent 

percent to discount from future emissions reductions.

12. The determination of the anticipated environmental impacts of the proposed ru

the method for valuing the expected CO2 and NOx emissions savings due to tstandards.

 EE-2006-STD-0127 COMMENT 40.4
Request for Additional Comments

Publ

DOE invites comments on any remaining issues pertaining to NOPR.

 EE-2006-STD-0127 COMMENT 40.4
How to Submit Comments...

 Public Meeting – Oral comments will be captured in the transcript and 

part of the public record.

 Written comments – NOPR comment period open until December 16, 

Reference docket #: EE–2006–STD–0127 and/or RIN #: 1904–AB49

Email: home_appliance.rulemaking@ee.doe.govMail: Ms. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program, Mailstop EE–2J1000 Independence Avenue, SW.Washington, DC 20585–0121.Telephone: (202) 586–2945.

Courier: Ms. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program950 L’Enfant Plaza, SW., 6th Floor,Washington, DC 20024.

 EE-2006-STD-0127 COMMENT 40.4
Backup Slides

 EE-2006-STD-0127 COMMENT 40.4
Summary of Results For Conventional Cooking Products

Industry NPV (% Change)

0 (1) – (2) (1) – (2

Industry NPV (2006$ million)

0 (8) – (19) (8) – (19

Electric Ovens

Industry NPV (% Change) (2) (2) (1) – (9

Industry NPV (2006$ million) (7) – (10) (7) – (10) (6) – (4

Gas Ovens

Industry NPV (% Change)

0 (1) – (3) (1) – (3

Industry NPV (2006$ million)

0 (2) – (11) (2) – (1

Electric Cooktops

Industry NPV (% Change) (2) – (4) (2) – (4) (2) – (4

Industry NPV (2006$ million) (5) – (12) (5) – (12) (5) – (12

Gas Cooktops

Industry Impacts:

3% Discount Rate 0.609 1.186 1.374 

7% Discount Rate 0.215 0.393 0.381 

NPV (2006$ billion):

Generation Capacity Reduction (GW)** 0.056 0.074 0.109 

3% Discount Rate 0.08 0.12 0.17 

7% Discount Rate 0.04 0.06 0.08 

Primary Energy Saved (quads) 0.14 0.23 0.32 

Category TSL 1 TSL 2 TSL 3 

 EE-2006-STD-0127 COMMENT 40.4
Electric Oven/Self-Clean Oven - - - Electric Oven/Standard Oven with or without a Catalytic Line - 8.0 8.0 

Gas Oven/Self-Clean Oven - - 11.4 Gas Oven/Standard Oven with or without a Catalytic Line 9.4 9.4 9.4 

Electric Cooktop/Smooth Elements - - - 

Electric Cooktop/Low or High Wattage Open (Coil) Elements - 7.3 7.3 Gas Cooktop/Conventional Burners 4.5 4.5 4.5 

Median PBP (years):

Electric Oven/Self-Clean Oven - - - Electric Oven/Standard Oven with or without a Catalytic Line - 9 9 Gas Oven/Self-Clean Oven - - 1 Gas Oven/Standard Oven with or without a Catalytic Line 6 6 6 

Electric Cooktop/Smooth Elements - - - 

Electric Cooktop/Low or High Wattage Open (Coil) Elements - 4 4 

Gas Cooktop/Conventional Burners 13 13 13 

Mean LCC Savings* (2006$):

Hg (t) 0 – 0.20 0 – 0.26 0 – 0.

NO 6.32 – 12.06 6.39 – 13.71 10.11 – 

x (kt)

CO 14.62 16.62 25.0

2 (Mt)

Cumulative Emissions Impacts†:

Category TSL 1 TSL 2 TSL 

Summary of Results For Conventional Cooking Products - Con

 EE-2006-STD-0127 COMMENT 40.4
Net Benefit (%) - - - No Impact (%) - - - 

Net Cost (%) - - - 

Electric Cooktop/Smooth Elements

Net Benefit (%) - 70.6 70.6 

No Impact (%) - 0.0 0.0 Net Cost (%) - 29.4 29.4 

Electric Cooktop/Low or High Wattage Open (Coil) Elements

Net Benefit (%) 6.3 6.3 6.3 

No Impact (%) 93.5 93.5 93.5 

Net Cost (%) 0.2 0.2 0.2 

Gas Cooktop/Conventional Burners

LCC Results:

Category TSL 1 TSL 2 TSL 

Summary of Results For Conventional Cooking Products - Con

 EE-2006-STD-0127 COMMENT 40.4
† CO2 emissions impacts include physical reductions at power plants and at households. NOx emissions impacts in

reductions at power plants as well as production of emissions allowance credits where NOx emissions are subject t

** Changes in installed generation capacity by 2042 based on AEO 2008 Reference Case.

* Parentheses indicate negative (-) values. For LCCs, a negative value means an increase in LCC by the amount indi

Net Benefit (%) - - - 

No Impact (%) - - - 

Net Cost (%) - - - 

Electric Oven/Self-Clean Oven

Net Benefit (%) - 56.1 56.

No Impact (%) - 0.0 0.0 

Net Cost (%) - 43.9 43.

Electric Oven/Standard Oven with or without a Catalytic Line

Net Benefit (%) - - 41.

No Impact (%) - - 0.0 

Net Cost (%) - - 58.

Gas Oven/Self-Clean Oven

Net Benefit (%) 11.2 11.2 11.No Impact (%) 82.3 82.3 82.

Net Cost (%) 6.5 6.5 6.5 

Gas Oven/Standard Oven with or without a Catalytic Line

LCC Results:

Category TSL 1 TSL 2 TSL 

Summary of Results For Conventional Cooking Products - Con

 EE-2006-STD-0127 COMMENT 40.4
Hg (t) 0 – 0.25 0 – 0.37 0 – 0

NO 0.58 – 14.25 0.85 – 20.85 1.37 – 3

x (kt)

CO 11.49 16.95 27.5

2 (Mt)

Cumulative Emissions Impacts†:

Industry NPV (% Change) 3 – (14) 8 – (27) 16 – (

Industry NPV (2006$ million) 44 – (199) 117 – (386) 237 – (

Industry Impacts:

3% Discount Rate (1.07) (2.96) (5.77% Discount Rate (0.61) (1.60) (3.0

NPV (2006$ billion):Generation Capacity Reduction (GW)** 0.063 0.097 0.16

3% Discount Rate 0.05 0.05 0.0

7% Discount Rate 0.02 0.02 0.0

Primary Energy Saved (quads) 0.08 0.09 0.1

Category TSL 1a TSL 2a TSL 

Summary of Results For Microwave Ovens (Energy Factor)

 EE-2006-STD-0127 COMMENT 40.4
† CO2 emissions impacts include physical reductions at power plants. NOx emissions impacts include physical r

plants as well as production of emissions allowance credits where NOx emissions are subject to emissions caps

** Changes in installed generation capacity by 2042 based on AEO 2008 Reference Case.

* Parentheses indicate negative (-) values. For LCCs, a negative value means an increase in LCC by the amount i

Net Benefit (%) 4.3 1.1 0.4 

No Impact (%) 53.7 53.7 53.

Net Cost (%) 42.0 45.2 45.

LCC Results:Median PBP (years): 29.4 57.1 81.Mean LCC Savings* (2006$): (3) (10) (19

Category TSL 1a TSL 2a TSL 

Summary of Results For Microwave Ovens (Energy Factor) – Con

 EE-2006-STD-0127 COMMENT 40.4
Hg (t) 0 – 0.50 0 – 0.76 0 – 1.09 NO 1.23 – 30.30 1.87 – 46.02 2.67 – 65.

x (kt)

CO 23.15 35.19 50.48 

2 (Mt)

Cumulative Emissions Impacts†:

Industry NPV (% Change) (1.50) – (1.77) (2.44) – (3.28) (2.52) – (4.

Industry NPV (2006$ million) (22) – (26) (35) – (48) (37) – (71

Industry Impacts:

3% Discount Rate 2.03 2.79 3.52 7% Discount Rate 0.91 1.25 1.56 

NPV (2006$ billion):

Generation Capacity Reduction (GW)** 0.145 0.222 0.320 3% Discount Rate 0.13 0.18 0.25 7% Discount Rate 0.06 0.09 0.12 Primary Energy Saved (quads) 0.23 0.33 0.45 

Category TSL 1b TSL 2b TSL 3

Summary of Results For Microwave Ovens (Standby Power)

 EE-2006-STD-0127 COMMENT 40.4
† CO2 emissions impacts include physical reductions at power plants. NOx emissions impacts include physical r

plants as well as production of emissions allowance credits where NOx emissions are subject to emissions caps

** Changes in installed generation capacity by 2042 based on AEO 2008 Reference Case.

* Parentheses indicate negative (-) values. For LCCs, a negative value means an increase in LCC by the amount i

Net Benefit (%) 43.3 80.9 100

No Impact (%) 53.7 19.1 0.0 

Net Cost (%) 0.0 0.0 0.0 

LCC Results:Median PBP (years): 0.3 0.6 1.5 Mean LCC Savings* (2006$): 6 13 18 

Category TSL 1b TSL 2b TSL 

Summary of Results For Microwave Ovens (Standby Power) – Co

 EE-2006-STD-0127 COMMENT 40.4
Summary of Results For Commercial Clothes Washers

Wastewater Discharge Impacts (trillion gallons) 0.00 0.16 0.19 0.20 

Hg (t) 0 – 0.05 0 – 0.12 0 – 0.17 0 – 0.1

NO 1.43 – 3.25 3.04 – 7.13 4.25– 9.93 4.51 – 10

x (kt)

CO 3.79 8.30 11.55 12.28 

2 (Mt)

Cumulative Emissions Impacts†:

Industry NPV (% Change) 6.5 – 4.9 (6.4) – (10.3) (26.5) – (31.1) (32.0) – (

Industry NPV (2006$ million) 4 – 3 (4) – (6) (15) – (17) (18) – (

Industry Impacts:

3% Discount Rate 0.04 0.83 1.16 1.27 

7% Discount Rate (0.001) 0.32 0.46 0.50 

NPV (2006$ billion):

Generation Capacity Reduction (GW)** 0.009 0.020 0.028 0.030 

3% Discount Rate 0.00 0.09 0.10 0.11 

7% Discount Rate 0.00 0.04 0.05 0.05 

Primary Water Saved (trillion gallons) 0.00 0.16 0.19 0.21 

3% Discount Rate 0.03 0.06 0.08 0.09 

7% Discount Rate 0.01 0.03 0.04 0.04 

Primary Energy Saved (quads) 0.05 0.11 0.15 0.16 

Category TSL 1 TSL 2 TSL 3 TSL 

 EE-2006-STD-0127 COMMENT 40.4
Summary of Results For Commercial Clothes Washers – Contin

Net Benefit (%) 10.9 93.6 96.1 96.1 96.1No Impact (%) 35.7 2.8 2.8 2.8 2.8Net Cost (%) 53.4 3.6 1.1 1.1 1.1

Laundromat

Net Benefit (%) 19.3 81.7 87.2 87.2 87.2

No Impact (%) 35.7 2.8 2.8 2.8 2.8

Net Cost (%) 45.0 15.4 10.0 10.0 10.0

Multi-Family

Top-Loading

LCC Results:

Front-Loading, Laundromat 0.0 0.3 0.3 1.7 1.6Front-Loading, Multi-Family 0.0 0.4 0.4 2.8 2.8Top-Loading, Laundromat 7.4 2.8 2.4 2.4 2.4Top-Loading, Multi-Family 10.7 4.5 3.8 3.8 3.8

Median PBP (years):

Front-Loading, Laundromat 9.5 58 58 140 250

Front-Loading, Multi-Family 8.7 52 52 134 234

Top-Loading, Laundromat (19.6) 166 252 252 252

Top-Loading, Multi-Family (11.6) 154 244 244 244

Mean LCC Savings* (2006$):

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 

 EE-2006-STD-0127 COMMENT 40.4
† CO2 emissions impacts include physical reductions at power plants and at commercial 

buildings. NOx emissions impacts include physical reductions at power plants as well as 

production of emissions allowance credits where NOx emissions are subject to emissions cap

** Changes in installed generation capacity by 2042 based on AEO 2008 Reference Case.

* Parentheses indicate negative (-) values. For LCCs, a negative value means an increase in LCC by the amount indicated.

Net Benefit (%) 7.3 11.7 11.7 97.2 98.5

No Impact (%) 92.7 88.3 88.3 2.8 1.5

Net Cost (%) 0.0 0.0 0.0 0.0 0.0

Laundromat

Net Benefit (%) 7.3 11.7 11.7 94.9 97.0

No Impact (%) 92.7 88.3 88.3 2.8 1.5

Net Cost (%) 0.0 0.0 0.0 2.3 1.5

Multi-Family

Front-Loading

LCC Results:

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 

Summary of Results For Commercial Clothes Washers – Contin

 EE-2006-STD-0127 COMMENT 40.4
Market Characteristics – Residential Gas Ran

Market and Technolo

 Four manufacturers account for approximately 89% of the dom

market share of gas ranges.

Source: Appliance Magazine, 30th Annual Portrait of the U.S. Appliance Industry, September 2007.

GE, 38%

Electrolux 

(Frigidaire), 25%

Maytag, 15%

Whirlpool, 11%

Peerless Premier, 

7%

Others, 4%

 EE-2006-STD-0127 COMMENT 40.4
Market Characteristics – Residential Electric Ra

Market and Technolo

 Four manufacturers account for approximately 90% of the dom

market share of electric ranges.

Source: Appliance Magazine, 30th Annual Portrait of the U.S. Appliance Industry, September 2007.

GE, 49%

Whirlpool, 22%

Electrolux 

(Frigidaire), 10%

Maytag, 9%

Peerless Premier, 

5%

Others, 5%

 EE-2006-STD-0127 COMMENT 40.4
Market Characteristics – Microwave Ovens

Market and Technolo

 The microwave oven market differs from the rest of the domes

product market.

• Many of the manufacturers are foreign-owned companies with ma

facilities outside of the United States.

• Many of the domestic appliance manufacturers rebrand foreign-m

products.

Source: Appliance Magazine, 30th Annual Portrait of the U.S. Appliance Industry, September 2007.

LG Electronics, 35%

Sharp, 21%

Samsung, 12%

Daewoo, 8%

Panasonic, 8%

Whirlpool, 4%

Others, 12%

 EE-2006-STD-0127 COMMENT 40.4
Market Characteristics – Commercial Clothes Wa

Market and Technolo

 Four manufacturers account for nearly entire domestic market 

commercial clothes washers.

Source: Consortium for Energy Efficiency (CEE). Commercial, Family-Sized Washers: An Initiative Description of the Consortium 

GE WascomatWhirlpool LGMaytag Continental Alliance Electrolux

Major Manufacturers Other Manufacturers

 EE-2006-STD-0127 COMMENT 40.4
Product Classes

Market and Technolo

•

 Cooking Products

• Gas cooktop/conventional burners• Electric cooktop/open (coil) elements• Electric cooktop/smooth elements• Gas oven/standard oven• Gas oven/self-clean oven• Electric oven/standard oven• Electric oven/self-clean oven• Microwave oven with or without thermal elements

 Commercial Clothes Washers

• Top-loading• Front-loading

 EE-2006-STD-0127 COMMENT 40.4
Screening Analysis Method

Scr

 Design options screened using the following criteria:

• Technological feasibility;• Practicability to manufacture, install and service;• Adverse impacts on product utility or product availability; and• Adverse impacts on health or safety.

 EE-2006-STD-0127 COMMENT 40.4
Technologies Selected for Further Considerat

Scr

Gas Cooktops4. Thermostatically controlled burners3. Sealed burners2. Insulation1. Electronic ignitionElectric Open (Coil) Element Cooktops4. Low-standby-loss electronic controls3. Insulation2. Improved contact conductance1. Electronic controlsElectric Smooth Element Cooktops4. Low-standby-loss electronic controls3. Induction elements2. Halogen elements1. Electronic controls

 EE-2006-STD-0127 COMMENT 40.4
Technologies Selected for Further Considerat

(Continued)

Scr

Gas and Electric Ovens9. Steam cooking8. Reduced vent rate 7. Reduced conduction losses 6. Radiant burner (gas only)5. Pilotless ignition (gas only)4. Low-standby-loss electronic controls 3. Improved insulation 2. Improved door seals 1. Forced convection 

 EE-2006-STD-0127 COMMENT 40.4
Technologies Selected for Further Considerat

(Continued)

Scr

Microwave Ovens (Energy Factor)10. Reflective surfaces9. Modified wave guide8. Low-standby-loss electronic controls7. Improved power supply efficiency 6. Improved magnetron efficiency 5. Improved fan efficiency 4. Eliminate or improve ceramic stirrer cover3. Dual magnetrons2. Cooking sensors1. Added insulation

Microwave Ovens (Standby Power)4. Automatic power-down3. Improved power supply and control board options2. Cooking sensors with no standby power requirement1. Lower-power display technologies

 EE-2006-STD-0127 COMMENT 40.4
Technologies Selected for Further Considerat

(Continued)

Scr

Commercial Clothes Washers15. Tighter tub tolerance14. Thermostatically controlled mixing valves 13. Steam washing 12. Spray rinse or similar water-reducing rinse technology 11. Low-standby-power electronic controls10. Increased motor efficiency 9. Improved water extraction to lower remaining moisture content8. Improved front-loading-washer drum design7. Improved fill control6. Front-loading design with recirculation5. Direct-drive motor4. Automatic water fill control3. Advanced agitation concepts for top-loading machines2. Added insulation1. Adaptive control systems

 EE-2006-STD-0127 COMMENT 40.4
Downstream Ana

• Life-Cycle Cost an

Payback Period

• National Impacts• Manufacturer Imp

Analysis

Cost – Efficiency 

Relationship

Incremental 

Manufacturing Cost

EF

Engin

 Characterize the relationship between manufacturer cost and efficienc

MEF/WF) or standby power

Purpose of the Engineering Analysis

 EE-2006-STD-0127 COMMENT 40.4
Conventional Cooking Products: Historical Annual E

 Conventional cooking product annual energy consumption has 

decline since 1970s

 Latest data from 2004 California Residential Appliance Saturati

and the Florida Solar Energy Center used to estimate annual en

• Variability in the annual energy based on data from the 2001 RECS

Energy Use and Water Us

Electric Ranges Gas Ranges

 EE-2006-STD-0127 COMMENT 40.4
Microwave Ovens: Historical Annual Energy 

 Annual energy consumption has held ‘relatively’ steady since the  Latest data from 2004 California Residential Appliance Saturation 

to estimate annual energy use

• Variability in the annual energy based on data from the 2001 RECS

Energy Use and Water Us

 EE-2006-STD-0127 COMMENT 40.4
Cooktop, Oven, and Microwave Oven: Annual Ene

 Electric Cooktops (0.737 EF)

• Cooking = 128 kWh/year

 Electric Standard Ovens (0.107 EF)

• Cooking = 132 kWh/year• Clock = 34.2 kWh/year

 Electric Self-Clean Ovens (0.096 EF)

• Cooking = 117 kWh/year• Clock = 33 kWh/year• Self-Clean = 21 kWh/year

 Microwave Ovens (0.557 EF)

• Cooking = 131 kWh/year

 Gas Cooktops (0.156 EF)

• Cooking = 0.7 MMBtu/year• Standing Pilots = 2.0 MMB

 Gas Standard Ovens (0.03

• Cooking = 0.8 MMBtu/year• Standing Pilot = 1.0 MMBtu• Units with Hot Surface Igni

 Gas Self-Clean Ovens (0.0

• Cooking = 0.7 MMBtu/year• Self-Clean = 0.2 MMBtu/ye• Hot Surface Ignition = 21 k• Clock = 32 kWh/year

Energy Use and Water Us

 DOE relied on latest energy use estimates to establish base

energy consumption

 EE-2006-STD-0127 COMMENT 40.4
Commercial Clothes Washers: Annual Energy and W

 Annual Energy & Water Use = Per-Cycle Use x Cycles per year Per-cycle energy use components

• Water-heating• Drying• Machine

 Drying energy use (RMC) and machine energy use are a functio

• Based on residential clothes washer data

 Number of cycles per day

• Multi-Family: Average = 3.4; Range = 1 to 10.9• Laundromats: Average = 6; Range = 3 to 8

 Annual energy and water use of baseline top-loading clothes w

MEF, 9.50 WF) 

• Multi-Family

– Energy use = 2769 kWh/year (1020 kWh WH; 1583 kWh drying; 16– Water use = 33 1000-gallons/year

• Laundromats

– Energy use = 4866 kWh/year (1793 kWh WH; 2782 kWh drying; 29– Water use = 58 1000-gallons/year

Energy Use and Water Us

 EE-2006-STD-0127 COMMENT 40.4
Baseline and Incremental Markups

Markups to Determine E

 Markups relate customer price to cost of goods sold (CGS

 Baseline markups relate price to cost prior to a change in e

• Baseline markups indicate a customer price that covers all of a reta

distributor’s expenses plus profit

• Direct labor costs (salaries, payroll, rental and occupancy) are inclu

 Incremental markups relate the incremental change in cus

to the incremental change in CGS

• Some costs remain constant with CGS increases• Incremental markups cover only expenses that vary with CGS – in 

expenses that increase due to an increase in equipment efficiency

– For example, direct labor costs (salaries, payroll, rental and occupancy) 

efficiency-induced changes in CGS

• DOE assumes other operating costs and profit will scale proportion

 EE-2006-STD-0127 COMMENT 40.4
Markups to Determine E

Resulting Markups

1.55 

* Represents average of all seven product classes of cooking products.

Overall 1.95 1.93

Sales Tax 1.069* 1.0684Distributor - - 1.43 

Retailer 1.45 1.15 - 

Manufacturer 1.26 1.26

Markup Baseline Incr. Baseline 

Cooking Products Commercial Clothes 

 EE-2006-STD-0127 COMMENT 40.4
Life-Cycle Cost and Payback P

LCC Calculation Flowchart

Total Installed

Cost

From 

Engineering 

Analysis

(Cost is a 

Function of 

Efficiency)

From Markups 

to Determine 

Equipment 

Price

Repair Cost

Maintenance

Cost

Annual

Operating

Expense

Lifetime

Operating

Expense

From Energy Use 

and Water Use 

Characterization

(Energy & Water 

Use are a Function 

of Efficiency)

Payback

Period

Energy

(and Water)

Consumption

Manufacturer

Markup

Sales Tax

Retailer or

Distributor

Markup

Consumer

Price

Baseline

Manufacturer

Cost

Std-Level

Manufacturer

Cost

Energy

(and Water)

Prices

Annual Energy

(and Water)

Cost

Lifetime

Discount Rate

Energy

(and Water)Price Trend

Installation

Cost

 EE-2006-STD-0127 COMMENT 40.4
National Impact Analysis Process

Shipments Model

National Energy Savings

NationalEconomicImpacts

LCC Analysis Results and Other Inputs

N

Ener

(

N

Net P

(2006 

 National energy savings calculated for period from 2012-2042 (30 ye NPV calculated for period from 2012-2062

 EE-2006-STD-0127 COMMENT 40.4
Shipments Model

Ship

Appliance Stock

Appliance

Lifetime

Replacement

Shipments

Combined

Shipments

New Building

Construction

New Building

Appliance

Saturation

New

Construction

Shipments

Historical

Shipments

Shipments

Difference

Total

Shipments

Early Retirement

Rate

(Calibration Variable)

Early

Replacement

Shipments

(For Cooking Products)

Units not

Replaced

(For Commercial CW)

Rate of NonReplacement

(Calibration Variable)

Product 

Market S

Tota

Shipm

by Cla

(For Cooking 

 EE-2006-STD-0127 COMMENT 40.4
Purchase Price and Operating Cost Impact

Ship

 Shipments impacts due to purchase price and operating co

are accounted for when forecasting standards case shipme

 Shipments Model used Relative Price

(RP) elasticity to estim

impacts from purchase price (PP) and the present value of ocost (PVOC) changes

 Purchase price effects dominate but mitigated by househol Based on historical shipments, retail price, efficiency, and i

for home appliances, RP elasticity = -0.34

• 10% increase in RP results in a 3.4% drop in shipments• Consumers become less sensitive to initial changes in purchase pr

– Based on economic literature, RP elasticity drops 65% in ten years

Income

PP PVOC RP

+

=

 EE-2006-STD-0127 COMMENT 40.4
Inputs

National 

 Total Installed Cost

• Average per unit values as a function of efficiency level taken from LCC analysis

 Repair and Maintenance Costs

• No increase in repair and maintenance costs with efficiency

 Annual Energy Use

• Average per unit values as a function of efficiency level taken from LCC analysis

 Base-Case and Standards-Case Forecasted Efficiencies

• Base-Case efficiencies 2005-2012: Based on base case efficiency distributions fr• Standards-Case efficiencies 2012: Based on “Roll-up” scenario• Forecasted efficiencies: Frozen at 2012 levels with the exception of base case eff

cooking products

 Energy and Water Prices

• Average prices taken from LCC analysis• Future energy prices adjusted according to trend forecasted by the 2008 Annual E• Future water prices forecasted on linear extrapolation of CPI national water price 

2006

 Electricity Site-to-Source Conversion Factors

• Conversion factors based on marginal heat rates from NEMS corresponding to 20

Outlook

• Factors vary annually and account for generation, distribution, and transmission lo

 Discount Rate

• 7% and 3% real from OMB’s Regulatory Analysis Guideline A-4

 Present Year

• Future expenses are discounted to the year 2007

 EE-2006-STD-0127 COMMENT 40.4