From: Cleary, Jennifer

Sent: Tuesday, August 12, 2014 9:19 AM

To: Timothy Sutherland

Cc: Maithili Iyer; Nicole Buccitelli; Leybourn, Steve; Notini, Jill; McArver, Rob

Subject: RE: Data request for DOE commercial clothes washer rulemaking

Tim,

See below and attached for the answers to your questions. Hopefully, this clarifies things. I apologize 

for the confusion--this file should replace the original one we sent you. Please let me know if you have 

any further questions.

Best,

Jenn

From: Timothy Sutherland

Sent: Tuesday, August 05, 2014 3:01 PM

To: Cleary, Jennifer

Cc: Maithili Iyer; Nicole Buccitelli

Subject: RE: Data request for DOE commercial clothes washer rulemaking

Hi Jenn,

Thanks very much for sending this data. We do have a couple follow-up questions based on this 

submission:

 In Table A-2, the 2013 shipment-weighted efficiency data doesn’t seem to be consistent with 

the data in Table A-3. Specifically:

o For top-loaders, the DOE standard for maximum WF has been 9.5 since 2007, but the 

2012 and 2013 data show average WF of 9.77 and 9.63. This is due to sell-through of 

older models

o For front-loaders, 2013 average MEF value is shown as 1.86, yet the market share data 

indicates that 100% of sales were of 2.20 and 2.40 models. The file has been updated 

with corrected values.

o For front-loaders, 2013 average WF value is shown as 3.16, yet the lowest available WF 

on the market is 3.7 WF, which had 0% sales. The file has been updated with corrected 

values

 In Table A-3, for top-loading 2013 data, does the 57% at 1.60 MEF include products sold at 1.60 

and higher (up to including max tech at 1.85?) Yes, the data does include top load MEFs sold at 

1.60 and higher.

o If so, is there any possibility of further breaking down the 1.60 sales by higher efficiency 

levels? (1.70 and 1.85) Or alternatively, understanding the need to preserve 

manufacturer confidentiality, would it be possible to split out the 1.60 data into two 

groups: the first group at 1.60, and the second group for everything higher than 

1.60? We cannot break down the data further due to confidentiality concerns.
That last bullet point is along the lines of the question I had sent you while you were out. Thanks in 

advance for any further info you can provide on these questions.

Best regards,

-Tim
APPENDIX A – DRAFT ENGINEERING ANALYSIS DATA REQUEST SHEETS

DOE seeks average incremental production cost to take basic models in the categories shown from the 

current DOE minimum efficiency level (or proposed baseline level) to the specified efficiency level. For 

those product classes where more than one basic model may exist, please indicate the minimum and 

maximum incremental costs that would be incurred across the array of basic models.

The data sheets are divided by product and contain tables requesting shipment and manufacturer cost 

data. The shipment-weighted energy use data of Table A-2 should be based on the DOE clothes washer 

test procedure (10 CFR 430, subpart B, appendix J1, J2).

Shipments

For commercial clothes washers, the AHAM 2005 Fact Book offers historical shipments data, but the 

information is not disaggregated by product class. As shown in the “shipment request” tables below, 

DOE hopes to collect both shipments data and shipment-weighted average efficiency data dating back to 

1995. In addition, DOE hopes to collect market share efficiency data (i.e., data on the distribution of 

equipment shipments by efficiency) for each product class. 

Manufacturer Costs

Incremental cost data (in U.S. dollars) include the materials, labor, and overhead needed to take basic 

models from the current minimum DOE baseline efficiency standard to each higher efficiency level. The 

depreciation of the conversion capital expenditures is an important component of the overhead for DOE 

to understand. Therefore, DOE is requesting information about conversion capital expenditures by 

efficiency level.

DOE requests notification from those interested parties planning to submit data by the close of the 

framework comment period.

Please provide aggregated industry data for the following tables.
Table A-1 Commercial Clothes Washer Shipments, Domestic plus Imports, in

Thousands of Units

Year Total Top-Loading % Imported Front-Loading % Imported

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010 164,196 104,159 * 60,037 *

2011 160,973 106,592 * 54,381 *

2012 173,384 120,442 * 52,942 *

2013 206,136 150,864 * 55,272 *

For the type of data requested in the table above, it is AHAM’s policy to only retain the 

previous two calendar years of data collected from its members. 

*AHAM only has collected domestic shipment data from its members. 
Table A-2 Shipment-Weighted Average Efficiency Data 

Top-Loading Front-Loading

Year EF / MEF / IMEF* WF / IWF† EF / MEF / IMEF* WF / IWF†

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010 1.36 (MEF) 9.10 (WF) 2.19 (MEF) 4.68 (WF)

2011 1.32 (MEF) 9.33 (WF) 2.31 (MEF) 4.43 (WF)

2012 1.28 (MEF) 9.77 (WF) 2.34 (MEF) 4.36 (WF)

2013 1.46 (MEF) 9.63 (WF) 2.38 (MEF) 4.05 (WF)

* Please specify whether energy factor (EF), modified energy factor (MEF), or integrated modified energy factor 

(IMEF).

† Please specify whether water factor (WF) or integrated water factor (IWF).

For the type of data requested in the table above, it is AHAM’s policy to only retain the 

previous two calendar years of data collected from its members.
Table A-3 Market Share Efficiency Data*

Top-Loading Front-Loading

Efficiency 

Bins Market Share† (Percent) Efficiency Bins Market Share† (Percent)

MEF WF 2009 2010 2011 2012 2013 MEF WF 2009 2010 2011 2012 2013

1.26 9.5 82% 80% 77% 43% 1.72 8.0 1% 0% 0% 0%

1.42 9.5 18% 20% 22% 0% 1.80 7.5 1% 0% 0% 0%

1.60‡ 8.5‡ 0% 0% 1% 57% 2.00‡ 5.5‡ 28% 28% 30% 0%

2.20 5.1 68% 34% 20% 31%

2.40 4.0 0% 38% 50% 69%

2.60 3.7 0% 0% 0% 0%

* Efficiency bins correspond to those used during the prior CCW rulemaking in addition to the proposed TSLs for 

this rulemaking. 

† Total market shares should equal 100%.

‡ January 8, 2013 DOE standard.

For the type of data requested in the table above, it is AHAM’s policy to only retain the 

previous two calendar years of data collected from its members. 

Notes:

• Models with MEF/WF data not meeting the criteria for both MEF and WF for any of the 

Efficiency Bins in the table above were included in the Efficiency Bin for which the value of

the lesser efficient, MEF or WF, is satisfied. For example, a model with a MEF = 2.01 and 

WF = 5.6 would have been included in the 1.80/7.5 Efficiency Bin.

 

• The percentages for the Front-Loading may not add up to 100% due to the absence of the 

current Federal Minimum Standard levels from the MEF/WF Efficiency Bins listed in the 

table. 
Table A-4 Aggregate Manufacturer Cost Data: Front-Loading Commercial Clothes Washers

Efficiency Level Baseline Level 1 Level 2 Level 3

MEF 2.00 2.20 2.40 2.60

WF 5.5 4.5 4.0 3.7

Average Incremental Costs ($ Per Unit)*

Direct Material 0

Direct Labor 0

Overhead# 0

Minimum Incremental Costs ($ Per Unit)*

Direct Material 0

Direct Labor 0

Overhead# 0

Maximum Incremental Costs ($ Per Unit)*

Direct Material 0

Direct Labor 0

Overhead# 0

Conversion Capital Expenditures ($, Millions)

Building CAPX 0

Tooling/ Equipment CAPX 0

R&D 0

Marketing 0

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

# Depreciation on the conversion capital expenditure should NOT be included in incremental overhead. 

_______________________________________________.

Direct material – Costs of raw materials including scrap that can be traced to final or end products. Direct material costs do 

not include indirect material costs, which are attributed to supplies that may be used in the production process but are not 

assigned to final products (e.g., lubricating oil for production machinery).

Direct labor – The earnings of workers who assemble parts into a finished good or operate machines in the production 

process. Direct labor includes the fringe benefits of direct laborers, such as group health care, as well as overtime pay. Direct 

labor does not include indirect labor, which is defined as the earnings of employees who do not work directly in assembling 

equipment, such as supervisors, janitors, stockroom personnel, and forklift operators.

Overhead – Factory overhead excluding depreciation. Factory overhead includes indirect labor, downtime, set-up costs, 

indirect material, expendable tools, maintenance, property taxes, insurance on assets, and utility costs. Factory overhead does 

not include selling, general, and administrative costs (SG&A); R&D; interest; or profit (accounted for by DOE separately).

AHAM has not collected the type of data requested in the table above from its members. 
Manufacturer Impact Analysis Questions:

• What fraction of the Commercial Clothes Washer manufacturing industry is represented by 

AHAM? Please indicate if this is by quantity or value of shipments.

Response: AHAM does not collect total commercial clothes washer shipments, and so we 

cannot provide a response to this question. Note that the data provided above is the result of a 

voluntary data collection program (AHAM’s annual energy survey data). It does not represent 

total industry. And the participants may vary from year to year. Unlike some of our other data, 

this data does not include an expansion factor to account for those not participating.

• Are you aware of, or do you represent any small business or low volume manufacturers? Please 

identify them. 

• In the absence of new standards, do you expect any industry consolidation?

• Could new standards disproportionately advance or harm the competitive positions of some 

firms?

• Could new standards result in disproportionate economic or performance penalties for particular 

consumer/user subgroups?

• Beyond price and energy efficiency, could new standards result in products that will be more or 

less desirable to consumers due to changes in product functionality, utility, or other features?

• What distribution channels are used from the manufacturer to the retail outlet? What is the share 

of product going through each distribution channel?