APPENDIX 13A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDES 

TABLE OF CONTENTS 

13A.1 CONVENTIONAL COOKING PRODUCTS...................................................... 13A-1

13A.2 MICROWAVE OVENS (ENERGY FACTORY STANDARDS)....................... 13A-9

 13A - i 

EERE-2006-STD-0127 COMMENT 64.2
APPENDIX 13A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDES 

13A.1 CONVENTIONAL COOKING PRODUCTS 

Cooking Products Rulemaking 

Manufacturer Impact Analysis Interview Guide:

Electric and Gas Cooktops, Ovens, and Ranges

March 4, 2008 

13A-1

EERE-2006-STD-0127 COMMENT 64.2
1 

Section 6313(a)(6)(A) of 42 U.S.C. requires the U.S. Department of Energy (DOE) to set forth 

energy conservation standards that are technologically feasible, economically justified, and that 

would result in significant additional energy conservation. This interview guide allows the 

opportunity for manufacturers to provide valuable information that will assist DOE in its 

decisions for the cooking products rulemaking. 

For the advance notice of proposed rulemaking (ANOPR) for cooking products, DOE based its 

analyses on the 1996 Technical Support Document for Residential Cooking Products (1996 

TSD). The costs found in the 1996 TSD were converted to 2007 dollars using the producer price 

index (PPI). The information found in the 1996 TSD was also supplemented with currently 

researched data and information provided by the Association of Home Appliance Manufacturers 

(AHAM). 

For the notice of proposed rulemaking (NOPR) analyses, Navigant Consulting Inc. (NCI) 

developed a “strawman” model of the cooking products industry financial performance called the 

Government Regulatory Impact Model (GRIM). The GRIM uses publicly available data (e.g., 

U.S. Securities and Exchange Commission (SEC) 10-K Forms) and 1996 TSD figures that were 

adjusted by shipment volumes and the PPI. These interviews will serve to review and 

supplement the strawman GRIM inputs and provide an opportunity to discuss the possible 

impacts of different efficiency levels on such issues as manufacturing costs, equipment prices, 

product sales, direct employment, capital assets, and industry competitiveness. 

KEY ISSUES 

DOE is currently reviewing a set of efficiency levels for Electric Coil Cooktops, Electric Smooth 

Cooktops, Gas Cooktops, Electric Standard Oven, Electric Self-Clean Oven, Gas Standard Oven, 

Gas Self-Clean Oven, and Electric and Gas Ranges rulemaking analyses. The efficiency levels 

are presented below as they apply to the various product classes. In responding to this 

questionnaire, please refer to the energy factor (EF) values described below. 

13A-2

EERE-2006-STD-0127 COMMENT 64.2
Table 1.1 Efficiency Levels 

Product 

Class Baseline Efficiency Level 1, 1a* 

Efficiency 

Level 2 

Efficiency 

Level 3 

Efficiency 

Level 4 

Efficiency 

Level 5 

Efficiency 

Level 6 

Electric 

Coil 

Cooktops 

0.737 0.769 - - - - -

Electric 

Smooth 

Cooktops 

0.742 0.753 - - - - -

Gas 

Cooktops 0.156 0.399 0.420 - - - -

Electric 

Standard 

Oven 

0.1066 0.1113 0.1163 0.1181 0.1206 0.1209 -

Electric 

Self-Clean 

Oven 

0.1099 0.1102 0.1123 - - - -

Gas 

Standard 

Oven 

0.0298 0.0536 

0.0583* 0.0566 0.0572 0.0593 0.0596 0.060 

Gas SelfClean Oven 0.0540 0.0625 0.0627 0.0632 - - -

* Baseline + Electronic Spark Ignition: Cooking efficiency decrease = 0.09 (absolute percentage points), added 

electricity consumption = 0.0 Wh. Efficiency levels 1 and 1a correspond to designs that are utilized for the same 

purpose--eliminate the need for a standing pilot--but the technologies for each design are different. Efficiency level 

1 is a hot surface ignition device while standard level 1a is a spark ignition device 

1.1 What are the key issues for your company regarding cooking products related to energy 

conservation standards and this rulemaking? 

1.2 For the issues identified, how significant are they for each efficiency level? 

1.3 How can we most effectively incorporate these issues in the Manufacturer Impact Analysis 

(MIA)? 

2 FINANCIAL PARAMETERS 

As stated above, NCI has developed a “strawman” model of the cooking products industry 

financial performance called the GRIM, using publicly available data (e.g., SEC 10-K Forms) on 

cooking products manufacturers. This section attempts to understand how your company’s 

financial situation differs from our industry aggregate picture. 

2.1 Please compare your financial parameters to the GRIM parameters tabulated below. 

13A-3

EERE-2006-STD-0127 COMMENT 64.2
Table 2.1 Financial Parameters for Cooking Products Manufacturers 

GRIM Input Definition Cooking 

Products GRIM 

Estimated 

Value 

Your Actual (if 

significantly 

different from our 

estimate) 

Income Tax Rate Corporate (average) effective 

income tax paid (percentage of 

earnings before interest and 

taxes, EBIT) 

33.1% 

Discount Rate Weighted average cost of capital 

(inflation-adjusted weighted 

average of corporate cost of debt 

and return on equity) 

6.6% 

Working Capital Current assets less current 

liabilities (percentage of 

revenues) 

3.3% 

SG&A Selling, general, and 

administrative expenses 

(percentage of revenues) 

13.0% 

R&D Research and development 

expenses (percentage of 

revenues) 

2.3% 

Depreciation Amortization of fixed assets 

(percentage of revenues) 3.4% 

Capital Expenditures Outlay of cash to acquire or 

improve capital assets 

(percentage of revenues, not 

including acquisition or sale of 

business units) 

3.5% 

3 PRODUCTION COST BREAKDWON 

Using information from the 1996 TSD, DOE estimated the industry average percentage 

breakdown of each manufacturing cost in the full production cost. 

3.1 Please compare your full production cost percentages to the GRIM full production cost 

percentages tabulated below. Are the different percentages of each cost representative of 

your company or the cooking products industry? Please explain any differences. 

Table 3.1 Breakdown by Percentage of Full Production Costs for Baseline Cooking 

Products 

Components of Full Production Costs Estimated % of Full 

Production Cost 

Your Actual (if significantly 

different from our estimate) 

Materials 66.19 % 

Labor 12.98 % 

Overhead 16.55 % 

Depreciation 4.28 % 

4 SHIPMENT PROJECTION AND MARKET SHARE 

13A-4 

EERE-2006-STD-0127 COMMENT 64.2
4.1 Would you expect your market share to change once standards become effective? Does 

your outlook change with higher efficiency levels? 

4.2 How would you expect shipments to change for the industry as a whole as a function of 

standards and why? 

5 CONVERSION COSTS 

An increase in energy conservation standards may cause your company to incur one-time capital 

and product conversion costsa. DOE calls these conversion costs because they are the costs of 

changing your business to comply with new energy conservation standards. 

5.1 What level of conversion costs do you anticipate incurring under the different efficiency 

levels? Refer to the tables below to provide your company’s estimates for the industry. 

Please compare your conversion costs with the GRIM conversion costs for the industry 

tabulated below. Please provide additional qualitative information to help us understand 

the nature of your investments. 

Table 5.1 Electric Coil Cooktops Conversion Costs ($ Millions) 

Standard 

Level 

GRIM Estimated Total Industry Your Estimate (if significantly different from our estimate 

Total Industry 

Conversion 

Capital 

Expenditures 

Product 

Conversion 

Expenses 

Conversion Capital 

Expenditures 

Product 

Conversion 

Expenses 

Stranded 

Assets 

Baseline 

(0.737) 

$0 $0 

Level 1 

(0.769) 

$0 $13 

Table 5.2 Electric Smooth Cooktops Conversion Costs ($ Millions) 

Standard 

Level 

GRIM Estimated Total Industry Your Estimate (if significantly different from our estimate 

Total Industry 

Conversion 

Capital 

Expenditures 

Product 

Conversion 

Expenses 

Conversion Capital 

Expenditures 

Product 

Conversion 

Expenses 

Stranded 

Assets 

Baseline 

(0.742) 

$0 $0 

Level 1 

(0.753) 

$104.4 $13 

Table 5.3 Gas Cooktops Conversion Costs ($ Millions) 

a

 Capital and product conversion costs include capital conversion expenditures, product conversion expenditures and 

stranded assets. Capital Conversion Expenditures – One time investments in plant, property, and equipment (PPE) 

necessitated by an energy conservation standard. These may be completely incremental to existing PPE or they 

could involve replacement of existing PPE. Product Conversion Expenditures – One-time expenses in research, 

product development, testing, and marketing necessitated by an appliance energy conservation standard. Stranded 

Assets – Investments such as equipment or tooling that become obsolete as a result of new regulation. 

13A-5

EERE-2006-STD-0127 COMMENT 64.2
Standard 

Level 

GRIM Estimated Total 

Industry 

Your Estimate (if significantly different from our estimate 

Total Industry 

Conversion 

Capital 

Expenditures 

Product 

Conversion 

Expenses 

Conversion Capital 

Expenditures 

Product 

Conversion 

Expenses 

Stranded 

Assets 

Baseline 

(0.156) 

$0 $0 

Level 1 

(0.399) 

$4.4 $13 

Level 2 

(0.420) 

$4.4 $26 

Table 5.4 Electric Standard Oven Conversion Costs ($ Millions) 

Standard 

Level 

GRIM Estimated Total 

Industry 

Your Estimate (if significantly different from our estimate 

Total Industry 

Conversion 

Capital 

Expenditures 

Product 

Conversion 

Expenses 

Conversion Capital 

Expenditures 

Product 

Conversion 

Expenses 

Stranded 

Assets 

Baseline 

(0.1066) 

$0 $0 

Level 1 

(0.1113) 

$0.9 $13 

Level 2 

(0.1163) 

$1.5 $26 

Level 3 

(0.1181) 

$103.3 $39 

Level 4 

(0.1206) 

$167.7 $52 

Level 5 

(0.1209) 

$179.8 $65 

Table 5.5 Electric Self-Clean Oven Conversion Costs ($ Millions) 

Standard 

Level 

GRIM Estimated Total 

Industry 

Your Estimate (if significantly different from our estimate 

Total Industry 

Conversion 

Capital 

Expenditures 

Product 

Conversion 

Expenses 

Conversion Capital 

Expenditures 

Product 

Conversion 

Expenses 

Stranded 

Assets 

Baseline 

(0.1099) 

$0 $0 

Level 1 

(0.1102) 

$28.8 $13 

Level 2 

(0.1123) 

$109.6 $26 

13A-6

EERE-2006-STD-0127 COMMENT 64.2
Table 5.6 Gas Standard Oven Conversion Costs ($ Millions) 

Standard 

Level 

GRIM Estimated Total 

Industry 

Your Estimate (if significantly different from our estimate 

Total Industry 

Conversion 

Capital 

Expenditures 

Product 

Conversion 

Expenses 

Conversion Capital 

Expenditures 

Product 

Conversion 

Expenses 

Stranded 

Assets 

Baseline 

(0.0298) 

$0 $0 

Level 1,1a 

(0.0536) 

(0.0583) 

$2.9 

$3.6 

$13 

Level 2 

(0.0566) 

$3.9 $26 

Level 3 

(0.0572) 

$8.4 $39 

Level 4 

(0.0593) 

$57.3 $52 

Level 5 

(0.0596) 

$58.4 $65 

Level 6 

(0.060) 

$74.5 $78 

Table 5.7 Gas Self-Clean Oven Conversion Costs ($ Millions) 

Standard 

Level 

GRIM Estimated Total 

Industry 

Your Estimate (if significantly different from our estimate 

Total Industry 

Conversion 

Capital 

Expenditures 

Product 

Conversion 

Expenses 

Conversion Capital 

Expenditures 

Product 

Conversion 

Expenses 

Stranded 

Assets 

Baseline 

(0.540) 

$0 $0 

Level 1 

(0.0625) 

$6.8 $13 

Level 2 

(0.0627) 

$15.6 $26 

Level 3 

(0.0632) 

$17.4 $39 

6 PROFITABILITY AND MANUFACTURING CAPACITY 

One of the primary objectives of the MIA is to assess the impact of efficiency levels on industry 

profitability and changes in manufacturing capacity. 

6.1 Do profit levels vary by efficiency level? Please explain why or why not? 

6.2 Do you expect any changes in your estimated profitability following the new energy 

conservation standard? If so, please explain why. 

6.3 How would the imposition of new energy conservation standards affect your 

manufacturing capacity at your production facilities? Would any facilities be closed, 

downsized, added, or upgraded? 

13A-7

EERE-2006-STD-0127 COMMENT 64.2
7 CUMULATIVE REGULATORY BURDEN 

Cumulative regulatory burden refers to the burden that industry faces from overlapping effects of 

new or revised DOE standards and/or other regulatory actions affecting the same products or 

industry 

7.1 Are there other recent or impending regulations that cooking products manufacturers face 

(from DOE or otherwise)? What level of investment are you expecting to incur as a result 

of these regulations? 

7.2 Under what circumstances would you be able to coordinate any expenditures related to 

other regulations thereby lessening the cumulative burden? 

8 DIRECT EMPLOYMENT IMPACT ASSESSMENT 

The impact of new energy conservation standards on employment is an important consideration 

in the rulemaking process. This section of the interview guide seeks to explore current trends in 

cooking products production employment and solicit manufacturer views on how domestic 

employment patterns might be affected by new energy conservation standards. 

8.1 Would your domestic employment levels change under new energy conservation 

standards? If so, please explain how they would change. 

8.2 Would the workforce skills necessary under new energy conservation standards require 

extensive retraining or replacement of employees? 

9 CONSOLIDATION 

New energy conservation standards can alter the competitive dynamics of the market. This can 

include prompting companies to enter or exit the market, or to merge. DOE and the Justice 

Department are both interested in any potential reduction in competition that would result from a 

new energy conservation standard. 

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

describe your expectations. 

9.2 How would new standards affect your ability to compete? 

9.3 Could new standards disproportionately advance or harm the competitive positions of 

some firms (e.g., small businesses)? 

13A-8

EERE-2006-STD-0127 COMMENT 64.2
13A.2 MICROWAVE OVENS (ENERGY FACTORY STANDARDS) 

Cooking Products Rulemaking 

Manufacturer Impact Analysis Interview Guide: Microwave Ovens 

March 3, 2008 

13A-9

EERE-2006-STD-0127 COMMENT 64.2
1 KEY ISSUES 

The Department of Energy (DOE) is currently reviewing a set of efficiency levels for Microwave 

Ovens (MWO). The efficiency levels are presented below as they apply to the single product 

class. In responding to this questionnaire, please refer to the energy factor (EF) values described 

below. 

Table 1.1 Efficiency Levels (EF %) 

Product 

Class Baseline Efficiency Level 1 

Efficiency 

Level 2 

Efficiency 

Level 3 

Efficiency 

Level 4 

Microwave 

Ovens 55.70 58.60 58.80 59.70 60.20 

1.1 What are the key issues for your company regarding MWO related to energy conservation 

standards and this rulemaking? 

1.2 For the issues identified, how significant are they for each efficiency level? 

1.3 How can we most effectively incorporate these issues in the Manufacturer Impact Analysis 

(MIA)? 

2 SHIPMENT PROJECTION AND MARKET SHARE 

2.1 Would you expect your market share to change once standards become effective? Does 

your outlook change with higher efficiency levels? 

2.2 How would you expect shipments to change for the industry as a whole as a function of 

standards and why? 

3 CONVERSION COSTS 

An increase in energy conservation standards may cause your company to incur one-time 

capital and product conversion costs. DOE calls these conversion costs because they are 

the costs of changing your business to comply with new energy conservation standards. 

3.1 What level of conversion costs do you anticipate incurring under the different efficiency 

levels? Refer to the tables below to provide your company’s estimates. Please provide 

additional qualitative information to help us understand the nature of your investments. 

Table 3.1 MWO Conversion Costs 

Standard Level Conversion Capital 

Expenditures 

Product Conversion 

Expenses 

Stranded Assets 

Baseline (55.70) 

Level 1 (58.60) 

Level 2 (58.80) 

Level 3 (59.70) 

Level 4 (60.20) 

13A-10

EERE-2006-STD-0127 COMMENT 64.2
4 PROFITABILITY AND MANUFACTURING CAPACITY 

One of the primary objectives of the MIA is to assess the impact of efficiency levels on industry 

profitability and changes in manufacturing capacity. 

4.1 Does your company have any MWO manufacturing facilities located in the United States? 

How would you expect shipments to change for the industry as a whole as a function of 

standards and why? 

4.2 Do you expect any changes in your estimated profitability following the new energy 

conservation standard? If so, please explain why. 

4.3 How would the imposition of new energy conservation standards affect your 

manufacturing capacity at your production facilities? Would any facilities be closed, 

downsized, added, or upgraded? 

5 CUMULATIVE REGULATORY BURDEN 

Cumulative regulatory burden refers to the burden that industry faces from overlapping effects of 

new or revised DOE standards and/or other regulatory actions affecting the same products or 

industry. 

5.1 Are there other recent or impending regulations that MWO manufacturers face (from DOE 

or otherwise)? What level of investment are you expecting to incur as a result of these 

regulations? 

5.2 Under what circumstances would you be able to coordinate any expenditures related to 

other regulations thereby lessening the cumulative burden? 

6 DIRECT EMPLOYMENT IMPACT ASSESSMENT 

The impact of new energy conservation standards on employment is an important consideration 

in the rulemaking process. This section of the interview guide seeks to explore current trends in 

MWO production employment and solicit manufacturer views on how domestic employment 

patterns might be affected by new energy conservation standards. 

6.1 Would your domestic employment levels change under new energy conservation 

standards? If so, please explain how they would change. 

6.2 Would the workforce skills necessary under new energy conservation standards require 

extensive retraining or replacement of employees? 

7 CONSOLIDATION 

New energy conservation standards can alter the competitive dynamics of the market. This can 

include prompting companies to enter or exit the market, or to merge. DOE and the Justice 

Department are both interested in any potential reduction in competition that would result from a 

new energy conservation standard. 

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

describe your expectations. 

13A-11

EERE-2006-STD-0127 COMMENT 64.2
7.2 How would new standards affect your ability to compete? 

7.3 Could new standards disproportionately advance or harm the competitive positions of 

some firms (e.g., small businesses)? 

13A-12

EERE-2006-STD-0127 COMMENT 64.2