From: Cleary, Jennifer

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

To: Timothy Sutherland

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

Su bject: 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 Tab le 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 g roup 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 prov ide on these questions.

Best regards,

- TimAPPENDIX 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 l evel. 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 request ing 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 Bo ok 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 overhe ad 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, DO E 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 f or 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 reques ted 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

To p

- 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 integra ted 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 t he

previous two calendar years of data collected from its members.

Note s :

**•** Models with MEF/W F 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 Fe deral 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 basel ine unit’s cost.

# Depreciation on the conversion capital expenditu re 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. Di rect

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 overhe ad includes indirect labor, downtime, set

- up costs,

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

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.M anufacturer Impact Analysis Questions:

**•** What fraction of the Commercial Clothes Washer manufacturing industry is r epresented 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 acc ount 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 disproportiona tely 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 produ cts 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 manu facturer to the retail outlet? What is the share

of product going through each distr ibution channel?