16-i

CHAPTER 16. REGULATORY IMPACT ANALYSIS 

TABLE OF CONTENTS 

16.1 INTRODUCTION ......................................................................................................... 16-1 

16.2 METHODOLOGY ........................................................................................................ 16-1 

16.2.1 Policy Assumptions ....................................................................................................... 16-2 

16.2.2 Policy Interactions ......................................................................................................... 16-4 

16.3 NON-REGULATORY POLICY ASSUMPTIONS ...................................................... 16-5 

16.3.1 No New Regulatory Action ........................................................................................... 16-5 

16.3.2 Financial Incentives Policies.......................................................................................... 16-5 

16.3.2.1 Consumer Rebates ....................................................................................... 16-7 

16.3.2.2 Consumer Tax Credits............................................................................... 16-15 

16.3.2.3 Manufacturer Tax Credits.......................................................................... 16-16 

16.3.3 Voluntary Energy Efficiency Targets.......................................................................... 16-16 

16.3.4 Bulk Government Purchases........................................................................................ 16-17 

16.4 RESULTS SUMMARY FOR NON-REGULATORY ALTERNATIVES................. 16-18 

LIST OF TABLES 

Table 16.1.1 Policy Alternatives to National Standards......................................................... 16-1 

Table 16.2.1 Proposed Standard Levels* for Polyphase Small Electric Motors (TSL 5)....... 16-3 

Table 16.2.2 Proposed Standard Levels for CSIR Small Electric Motors (TSL 7)................ 16-4 

Table 16.2.3 Proposed Standard Levels for CSCR Small Electric Motors (TSL 7)............... 16-4 

Table 16.3.1 Benefit/Cost Ratios for 4-pole 1 HP Polyphase Motor Rebate Policy Case...... 16-8 

Table 16.3.2 Polyphase Small Electric Motor Consumer Rebate Efficiency Market 

Share Impacts..................................................................................................... 16-8 

Table 16.3.3 Benefit/Cost Ratios for Capacitor-Start Small Electric Motor Rebate 

Policy Case....................................................................................................... 16-10 

Table 16.3.4 Capacitor-Start Small Electric Motor Target-Level Consumer Rebate 

Efficiency Market Share Impacts..................................................................... 16-11 

Table 16.3.5 Benefit/Cost Ratios for Capacitor-Start Small Electric Motors, CSIR Level 

4 Rebate Policy Case ....................................................................................... 16-13 

Table 16.3.6 Capacitor-Start Small Electric Motor TSL 5 Consumer Rebate Efficiency 

Market Share Impacts...................................................................................... 16-13 

Table 16.3.7 Benefit/Cost Ratios for Capacitor-Start Small Electric Motors, CSCR-only 

Rebate Policy Case .......................................................................................... 16-14 

Table 16.3.8 Capacitor-Start Small Electric Motor CSCR-Only Consumer Rebate 

Efficiency Market Share Impacts..................................................................... 16-14 

Table 16.3.9 Small Electric Motor Consumer Tax Credit Efficiency Market Share 

Impacts............................................................................................................. 16-15 

EERE-2007-BT-STD-0007 COMMENT 19
16-ii

Table 16.3.10 Small Electric Motor Manufacturer Tax Credit Efficiency Market Share 

Impacts............................................................................................................. 16-16 

Table 16.3.11 Small Electric Motor Voluntary Efficiency Target Market Share Impacts..... 16-17 

Table 16.3.12 Small Electric Motor Bulk Government Purchases Efficiency Market 

Share Impacts................................................................................................... 16-18 

Table 16.4.1 Non-Regulatory Alterative Market Share Summary ....................................... 16-19 

Table 16.4.2 Non-Regulatory Alternatives for Polyphase Small Electric Motors................ 16-19 

Table 16.4.3 Non-Regulatory Alternatives for Capacitor-Start Small Electric Motors........ 16-20 

LIST OF FIGURES 

Figure 16.3.1 Market Penetration Curve for Polyphase Small Electric Motors....................... 16-9 

Figure 16.3.2 Market Penetration Curve for CSIR Small Electric Motors............................ 16-11 

Figure 16.3.3 Market Penetration Curve for CSCR Small Electric Motors........................... 16-12 

EERE-2007-BT-STD-0007 COMMENT 19
16-1 

CHAPTER 16. REGULATORY IMPACT ANALYSIS 

16.1 INTRODUCTION 

 The Department of Energy (DOE) has determined that energy conservation standards for 

small electric motors constitute an “economically significant regulatory action” under Executive 

Order (E.O.) 12866 “Regulatory Planning and Review.” 58 FR 51735 (October 4, 1993). 

Therefore, DOE’s proposed energy conservation standards require a regulatory impact analysis 

(RIA), which involves an evaluation of non-regulatory alternatives to the standards. 

 Under the Process Rule (Procedures for Consideration of New or Revised Energy 

Conservation Standards for Consumer Products, 61 FR 36974 (July 15, 1996); 10 CFR Part 430, 

Subpart C, Appendix A), DOE is committed to continually explore non-regulatory alternatives to 

standards. This RIA, which DOE has prepared pursuant to E.O. 12866, is subject to review under 

the Executive Order by the Office of Management and Budget (OMB)’s Office of Information 

and Regulatory Affairs (OIRA). 58 FR 51735. 

 DOE identified five major non-regulatory alternatives to standards as representing 

feasible policy options to achieve greater energy efficiency for the products that are the subject 

of this rulemaking. These are listed in Table 17.1.1. DOE evaluated each alternative in terms of 

its ability to achieve significant energy savings at a reasonable cost, and compared the 

effectiveness of each one to the effectiveness of the proposed standards. DOE did not analyze an 

“early replacement” scenario because it did not find any data supporting an underlying trend 

toward higher efficiency over time, which suggests that early replacement would not achieve 

significant energy savings. 

Table 16.1.1 Policy Alternatives to National Standards 

No New Regulatory Action 

Consumer Rebates 

Consumer Tax Credits 

Manufacturer Tax Credits 

Voluntary Energy Efficiency Targets 

Bulk Government Purchases 

 

16.2 METHODOLOGY 

 This section describes the approach DOE used to analyze non-regulatory policies for 

small electric motors. 

EERE-2007-BT-STD-0007 COMMENT 19
16-2 

 To calculate the national energy savings and the net present value (NPV) corresponding 

to each policy alternative, DOE used its national impact analysis (NIA) spreadsheet models. (See 

Chapter 10 of the technical support document (TSD) for a description of the NIA spreadsheet 

models.) To compare each alternative to the proposed standards, DOE quantified the effect of 

each alternative on the purchase of small electric motors meeting the target levels, which are 

defined as the efficiency levels in the proposed standards. Once it had made the quantitative 

assumptions for each alternative policy, DOE made the appropriate revisions to the inputs in the 

NIA spreadsheet models. The main model inputs that DOE revised were market shares of 

equipment at target efficiencies and shipment-weighted average annual energy consumption. The 

shipments for any given year are comprised of a distribution of efficiency levels. DOE assumed 

that standards would affect 100 percent of the shipments, while the non-regulatory policies 

would affect a smaller percentage of the shipments. In each policy case, DOE made particular 

assumptions about the percentage of shipments impacted by the policy under analysis. DOE then 

calculated the shipment-weighted average energy consumption and costs using these market 

shares. 

 A shift in the market share of higher efficiency units may increase the average installed 

cost of energy-consuming equipment. Operating costs will generally decrease due to a decline in 

energy consumption. Therefore, DOE calculated an NPV for non-regulatory alternatives in the 

same way as it did for the proposed standards. In some scenarios, total installed cost increases 

are partially mitigated by government rebates or tax credits. However, DOE assumed that credits 

and rebates would be paid for in another form (such as additional taxes), and therefore did not 

include them as a benefit for the purposes of calculating the national NPV. DOE did not consider 

administrative costs for any of the non-regulatory policies in its analysis. Inclusion of such costs 

would decrease their NPVs by a small amount. 

 The key measures of the impact of each alternative are: 

• National energy savings in quadrillion Btus (quads): Cumulative national primary energy 

savings for equipment bought in the period from the effective date of the policy case 

(2015) to the year 2045. 

• Net present value: The value of net monetary savings from equipment bought in the 

period from the effective date of the policy case (2015) to the year 2045. DOE calculated 

the NPV as the difference between the present value of equipment and operating 

expenditures (including energy) in the base case and the present value of expenditures in 

each alternative policy case. DOE calculated operating expenses (including energy) for 

the life of the equipment. 

16.2.1 Policy Assumptions 

 The impacts of non-regulatory policies are by nature uncertain, since they depend on 

program implementation and marketing efforts and the subsequent consumer behavior response. 

The projected impacts depend on the assumptions regarding the consumer participation rate, and 

are therefore subject to more uncertainty than the impacts of mandatory standards, which DOE 

EERE-2007-BT-STD-0007 COMMENT 19
16-3 

assumes will have full compliance. To increase the robustness of the analysis, DOE conducted a 

literature review on each non-regulatory policy and consulted with key experts to gather 

information on similar incentive programs that have already been implemented in the U.S. By 

studying field experience with sample programs of each type, DOE sought to make credible 

assumptions of their potential market impacts. Section 16.3 below reports the conclusions from 

this research as they apply to the policy modeling assumptions and includes the corresponding 

literature citations. 

 Each of the policy alternatives to the proposed standards that DOE considered would 

improve the average efficiency of new small electric motors relative to the base case (no new 

regulatory action). The analysis considered that each alternative policy would induce consumers 

to purchase units at higher efficiency levels than they would otherwise purchase, reaching the 

efficiency levels corresponding to the proposed standards, or the target levels. In contrast to the 

proposed standards, however, their market penetration rate in the alternative policy cases may 

not be 100 percent. 

 The efficiency levels corresponding to the proposed standards for polyphase small 

electric motors are those in TSL 5, as shown in Table 16.2.1. The proposed standards for 

capacitor-start induction-run (CSIR) and capacitor-start capacitor-run (CSCR) small electric 

motors are those in TSL 7, as shown in Tables 16.2.2 and 16.2.3. 

Table 16.2.1 Proposed Standard Levels* for Polyphase Small Electric Motors (TSL 5) 

Motor output 

power 

6 Poles 4 Poles 2 Poles 

0.25 Hp / 0.18 kW 77.4 72.7 69.8 

0.33 Hp / 0.25 kW 79.1 75.6 73.7 

0.5 Hp / 0.37 kW 81.1 80.1 76.0 

0.75 Hp / 0.55 kW 84.0 83.5 81.6 

1 Hp / 0.75 kW 84.2 85.2 83.6 

1.5 Hp / 1.1 kW 85.2 87.1 86.6 

2 Hp / 1.5 kW 89.2 88.0 88.2 

≥3 Hp / 2.2 kW 90.8 90.0 90.5 

* Standard levels are expressed as efficiency (%). 

EERE-2007-BT-STD-0007 COMMENT 19
16-4 

Table 16.2.2 Proposed Standard Levels for CSIR Small Electric Motors (TSL 7) 

Motor output 

power 

6 Poles 4 Poles 2 Poles 

0.25 Hp / 0.18 kW 65.4 69.8 71.4 

0.33 Hp / 0.25 kW 70.7 72.8 74.2 

0.5 Hp / 0.37 kW 77.0 77.0 76.3 

0.75 Hp / 0.55 kW 81.0 80.9 78.1 

1 Hp / 0.75 kW 84.1 82.8 80.0 

1.5 Hp / 1.1 kW 87.7 85.5 82.2 

2 Hp / 1.5 kW 89.8 86.5 85.0 

≥3 Hp / 2.2 kW 92.2 88.9 85.6 

* Standard levels are expressed as efficiency (%). 

Table 16.2.3 Proposed Standard Levels for CSCR Small Electric Motors (TSL 7) 

Motor output 

power 

6 Poles 4 Poles 2 Poles 

0.25 Hp / 0.18 kW 63.9 68.3 70.0 

0.33 Hp / 0.25 kW 69.2 71.6 72.9 

0.5 Hp / 0.37 kW 75.8 76.0 75.1 

0.75 Hp / 0.55 kW 79.9 80.3 77.0 

1 Hp / 0.75 kW 83.2 82.0 79.0 

1.5 Hp / 1.1 kW 87.0 84.9 81.4 

2 Hp / 1.5 kW 89.1 86.1 84.2 

≥3 Hp / 2.2 kW 91.7 88.5 84.9 

* Standard levels are expressed as efficiency (%). 

 DOE assumed that the non-regulatory policy impacts would last from the effective date 

for proposed standards for small electric motors—2015—through the end of the analysis period, 

2045. 

16.2.2 Policy Interactions 

 DOE calculated the impacts of each regulatory policy separately from those of the other 

policies. In actual practice, certain policies are often most effective when implemented in 

combination to provide incentives, such as bulk government purchases with consumer rebates. 

DOE attempted to make conservative assumptions to avoid double-counting policy impacts. 

Therefore, the policy impacts reported below are not additive; the combined impact of several or 

all of the policies may not be inferred from adding the results together. 

 

EERE-2007-BT-STD-0007 COMMENT 19
16-5 

16.3 NON-REGULATORY POLICY ASSUMPTIONS 

16.3.1 No New Regulatory Action 

 The case in which no new regulatory action is taken with regard to small electric motor 

efficiency constitutes the base case scenario described in Chapter 10. This case defines the basis 

of comparison for all other scenarios. By definition, no new regulatory action yields zero energy 

savings and an NPV of zero dollars. 

16.3.2 Financial Incentives Policies 

 DOE considered scenarios in which the Federal government would provide two types of 

financial incentives: rebates and tax credits. The government could provide consumers with a 

rebate for purchasing energy efficient equipment meeting the target level for each product. Tax 

credits could be offered to consumers who purchase target-level small electric motors. The 

government could also provide tax credits to manufacturers to offset costs associated with 

producing such equipment. 

 DOE’s evaluation of consumer rebates used a comprehensive study of the potential for 

energy efficiency in California performed by Xenergy, Inc., which summarized experience with 

various utility rebate programs.1

 This analysis method is based on curves that estimate the 

market penetration of a technology based on its benefit/cost (B/C) ratio. DOE consulted with 

experts and reviewed several other methods of estimating market penetration of efficient 

technologies due to consumer rebate programs that were developed since the referenced Xenergy 

report was published.2,3,4,5 However, these methods were based either on other economic

parameters (payback period) or on expert surveys predicting penetration of a new technology 

over time. Therefore, DOE decided to use the penetration curve method based on B/C ratio, 

which incorporates lifetime operating cost savings, and was calibrated with utility rebate 

program participation results. 

 Xenergy’s information diffusion model estimates market impacts induced by financial 

incentives for energy efficient appliances. The basic premise of this model is that information 

diffusion drives technology adoption. The model is formulated to characterize the influences of 

both internal and external sources of information on consumer behavior by superimposing two 

components in the equation, each capturing the effect of one of two different types of 

information source. The effects of these two types of information diffusion mechanisms are 

different. Internal sources of information influence consumers to purchase new products due 

mainly to word-of-mouth from early adopters, while external information sources influence 

consumers to change their adoption decisions as a result of marketing efforts and information 

coming from outside the consumer group. (Appendix 16A of the TSD contains further details on 

modeling these influences.) 

 Xenergy’s model combined these two information diffusion mechanisms and generated a 

set of measure “implementation curves” or penetration curves, which Xenergy calibrated using 

EERE-2007-BT-STD-0007 COMMENT 19
16-6 

evaluation data from utility rebate programs. Consumer response to rebate incentives appears to 

be a combination of the two information source types. The penetration curves illustrate the 

increased penetration (i.e., increased market share) of efficient equipment as a result of consumer 

response to B/C ratio changes induced by a specific rebate program. The penetration curves are 

used to depict various diffusion patterns based on perceived barriers to consumer purchase of 

high-efficiency equipment. There are penetration curves for varying levels of market barriers, 

from “no barriers” to “extremely high barriers.” These curves provide a means to study the 

impact of changing the B/C ratio, by reducing the initial equipment cost through financial 

incentives, on the consumer participation rate. 

 The penetration curves do not exactly model the dynamics of a particular equipment 

market. Therefore, DOE used them in the following way to predict changes in equipment market 

shares. If the current market share is 0.0%, DOE assumed that the market share would increase 

to be equal to the difference between the penetration-curve market share at the no-rebate B/C 

ratio and the penetration-curve with-rebate B/C/ ratio. If the current market share at the target 

level is greater than zero, DOE used the penetration curve to determine that ratio between the 

with-rebate and no-rebate market shares, and applied this ratio to the motor market under 

consideration. DOE limited the effect of the rebate by assuming that it could no increase the 

market share above the maximum for the corresponding penetration curve. For example, if the 

current market share were 5% and the penetration curve predicted a no-rebate market share of 

3% and a with-rebate market share of 12%, DOE would assume that the rebate would increase 

the target-level market share by a factor of 4, to 20%. 

 DOE based its estimates of the impacts of consumer tax credits on actual program 

experience with State tax credits in Oregon. DOE studied State tax credits in Montana as well. 

DOE also attempted to determine residential consumer participation due to the Federal appliance 

tax credits, which were mandated by the Energy Policy Act of 2005 (EPACT 2005). For the 

manufacturer tax credits policy, DOE attempted to investigate manufacturer participation due to 

the efficient equipment tax credits from EPACT 2005. Both the Federal consumer and 

manufacturer credits were in effect in 2006 and 2007. Unfortunately, the Internal Revenue 

Service (IRS) had not yet published data on taxpayer response to either of these tax credits. 

 DOE also incorporated previous research that had differentiated the impact of tax credits 

into the “direct price effect,” which arises from the incremental equipment cost savings, and the 

“announcement effect,” which is independent of the credit amount.6,7

 The announcement effect 

derives from the credibility that a particular technology receives from its inclusion in an 

incentive program, as well as changes in product marketing strategy, and the resulting 

modifications in markups and pricing. DOE assumed that the direct price effect and the 

announcement effect would apply to the consumer tax credit policy as well as the consumer 

rebate policy, and that half of the increases in market penetration associated with either policy 

would be due to the direct price effect and half to the announcement effect. 

EERE-2007-BT-STD-0007 COMMENT 19
16-7 

16.3.2.1 Consumer Rebates 

 DOE modeled the impact of the consumer rebate policy by determining the increase in 

market penetration of target-level equipment relative to its market penetration in the base case. 

Polyphase Small Electric Motors 

 For conventional cooking products, DOE estimated the impact of increasing the 

benefit/cost (B/C) ratio via a rebate that paid a portion of the incremental installed cost between a 

unit meeting the baseline efficiency level and a unit meeting the target efficiency level. DOE 

based the rebate amount on a large sample of utility rebate programs for NEMA Premium-rated 

polyphase electric motors (three-digit frame series). Since DOE found no rebate programs for 

small electric motors, DOE chose these larger motors as similar equipment, with similar market 

dynamics. DOE gathered data on rebate programs for 1 horsepower motors offered by 48 

agencies or utilities throughout the country. (See Appendix 16A for a listing of these rebate 

programs.) The simple average of the rebate amounts in these programs, $26, is roughly 25% of 

the incremental cost between a 1 HP three-digit frame series motor which meets current 

efficiency standards for medium motors and a motor which meets NEMA Premium efficiency. 

NEMA Premium efficiency for medium motors corresponds most closely with TSL 5, the 

Department’s proposed standard level for small polyphase motors. DOE assumed that a rebate 

program for small polyphase electric motors would offer a similar rebate of $25 for a 4 pole, 1 

HP motor, with rebate amounts for other motor speeds and powers scaling in the same fashion as 

motor cost (see chapter 8 for a discussion of price scaling). DOE assumed the rebates would 

remain in effect until they had transformed the markets so that the shift in market share of 

efficient units seen in the first year of the programs would be maintained throughout the forecast 

period (2015–2045). 

 DOE first calculated the B/C ratio for the target 4-pole 1 HP unit without a rebate. It then 

calculated another B/C ratio for the unit meeting the target level, with a rebate, relative to the 

baseline unit. Because of the incremental cost reductions due to the rebates, the B/C ratios for the 

rebate policy unit were larger. Table 17.3.1 shows the benefits as lifetime operating cost savings, 

incremental installed costs without rebates and with rebates, and B/C ratios without rebates and 

with rebates. 

EERE-2007-BT-STD-0007 COMMENT 19
16-8 

Table 16.3.1 Benefit/Cost Ratios for 4-pole 1 HP Polyphase Motor Rebate Policy Case 

4 pole 1 HP 

Polyphase 

Benefit 

(Lifetime Operating Cost Savings) $ 57.90 

Incremental Installed Cost (Increased 

Installed Cost) $131.23 

B/C Ratio with No Rebate 0.44

Current Market Share 0.0% 

Rebate Amount $25.00 

Adjusted Incremental Installed Cost 

(Increased Installed Cost after Rebate) $106.23 

B/C Ratio for Rebate Policy Case 0.55 

Penetration Curve Projected 

Increase in Market Share 0.4% 

 DOE then used the B/C ratios with the penetration curve shown in Figure 17.3.1 to 

estimate the increased percentage of consumers who would purchase the units that meet the 

policy target levels if given a rebate incentive. For polyphase small electric motors, DOE 

selected the “moderate barriers” curve, which has the greatest degree of correspondence (among 

the curves prepared by Xenergy) between the market share calculated from the B/C ratio of each 

efficiency level and the current market share for each efficiency level. Figure 17.3.1 shows the 

increase in penetration rates of target-level units as a function of their higher B/C ratios. Using 

the method discussed above, DOE estimated that the market share of equipment meeting the 

policy target due to a rebate policy would increase by 0.4 percent above the base case market 

share for polyphase small electric motors. 

 To calculate the impacts of this policy, DOE adjusted the market shares of polyphase 

small electric motors at the target efficiencies in its NIA model to represent the policy case 

scenario. Table 16.3.2 shows the efficiency distribution used. 

Table 16.3.2 Polyphase Small Electric Motor Consumer Rebate Efficiency Market 

Share Impacts 

Baseline CSL 1 CSL 2 CSL 3 CSL 4 CSL 5 CSL 6 CSL 7 

Base case 82.0% 4.0% 4.0% 4.0% 6.0% 0.0% 0.0% 0.0% 

Rebate case 81.6% 4.0% 4.0% 4.0% 6.0% 0.4% 0.0% 0.0% 

EERE-2007-BT-STD-0007 COMMENT 19
0.0%

2.0%

4.0%

6.0%

8.0%

10.0%

12.0%

14.0%

16.0%

18.0%

20.0%

0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4 1.6 1.8 2.0 2.2 2.4 2.6 2.8 3.0 3.2 3.4 3.6 3.8 4.0

Participant Benefit-Cost Ratio

Penetration Rate

Figure 16.3.1 Market Penetration Curve for Polyphase Small Electric Motors 

Capacitor-Start Small Electric Motors 

 For capacitor-start small electric motors, DOE assumed that the rebate would cover a 

portion of the incremental cost between a motor meeting the baseline efficiency level and a unit 

meeting the target efficiency level. DOE assumed that the rebate amount for a 1 HP motor would 

be equal to the $25 rebate offered for 1 HP polyphase small electric motors (based, in turn, on 

current rebate programs for three-digit frame series polyphase motors). Similar to polyphase 

motors, DOE assumed that the rebate amount would scale with the number of poles and power of 

the motor in the same fashion as motor prices scale. DOE assumed the rebates would remain in 

effect until they had transformed the markets so that the shift in market share of efficient units 

seen in the first year of the programs would be maintained throughout the forecast period (2015–

2045). 

 DOE first analyzed the impact of rebates at the efficiency levels prescribed by TSL 7. 

However, for CSIR motors at this efficiency level, a $25 rebate (scaled from a 1 HP motor) had 

no effect on the efficiency distribution of CSIR motor shipments. Therefore, DOE chose to 

undertake the remainder of its analysis of policy alternatives with the efficiency levels 

corresponding to TSL 5. 

16-9 

EERE-2007-BT-STD-0007 COMMENT 19
16-10 

 For each type of capacitor-start motor (induction-run and capacitor-run), DOE first 

calculated the B/C ratio for the target unit without a rebate. It then calculated another B/C ratio 

for the unit meeting the target level, with a rebate, relative to the baseline unit. Because of the 

incremental cost reductions due to the rebates, the B/C ratios for the rebate policy unit were 

larger. Table 17.3.3 shows the benefits as lifetime operating cost savings, incremental installed 

costs without rebates and with rebates, and B/C ratios without rebates and with rebates. 

Table 16.3.3 Benefit/Cost Ratios for Capacitor-Start Small Electric Motor Rebate Policy 

Case 

4-pole 1/2 HP CSIR 4-pole 3⁄4 HP CSCR 

Benefit (Lifetime Operating Cost Savings) $109.81 $71.34 

Incremental Installed Cost (Increased Installed Cost) $97.50 $48.90 

B/C Ratio with No Rebate 1.13 1.57 

Penetration Curve Market Share without Rebate 0.4% 32.6% 

Current Market Share at Target Level 0.0% 21.0% 

Rebate Amount $17.67 $21.65 

Adjusted Incremental Installed Cost 

(Increased Installed Cost after Rebate) $79.83 $27.25 

B/C Ratio for Rebate Policy Case 1.38 2.82 

Penetration Curve Market Share with Rebate 0.7% 45.8% 

DOE Estimated Market Share with Rebate 0.3% 29.5% 

 DOE then used the B/C ratios with the penetration curves shown in Figures 17.3.2 and 

17.3.3 to estimate the increased percentage of consumers who would purchase the units that meet 

the policy target levels if given a rebate incentive. For CSIR motors, DOE chose the “moderate 

barriers” curve. In the case of CSIR motors, the incremental cost between the baseline and the 

TSL is substantial, and the benefit-cost ratios of less energy-efficient levels, compared with their 

market shares, indicate that the “moderate barriers” curve is the best fit. Figure 17.3.6 shows the 

increase in penetration rates of target-level CSIR units as a function of their higher B/C ratios. 

Using the method discussed above, DOE estimated that the market share of equipment meeting 

the policy target due to a rebate policy would increase by 0.3 percent. For CSCR motors, DOE 

chose the “low barriers” curve, because the incremental cost between the baseline and the TSL is 

small and there is currently substantial market share at or above the target level. Figure 17.3.7 

shows the increase in penetration rates of target-level CSCR units as a function of their higher 

B/C ratios. Using the method discussed above, DOE estimated that the market share of CSCR 

equipment meeting the policy target due to a rebate policy would increase by 8.5 percent. 

 To calculate the impacts of this policy, DOE adjusted the market shares of capacitor-start 

motors at the target efficiencies in its NIA model to represent the policy case scenarios. Table 

17.3.4 shows the efficiency distributions used. DOE also adjusted the relative shipment-weighted 

average prices of CSIR and CSCR motors to incorporate the rebate amounts and used its 

modified logistic market share model to incorporate rebates into its model of the relative market 

share of CSIR and CSCR motors within each combination of power and number of poles. 

EERE-2007-BT-STD-0007 COMMENT 19
Table 16.3.4 Capacitor-Start Small Electric Motor Target-Level Consumer Rebate 

Efficiency Market Share Impacts 

Baseline Eff. 1 Eff. 2 Eff. 3 Eff. 4 Eff. 5 Eff. 6 Eff. 7 Eff. 8 

CSIR 

Base case 40.0% 7.0% 20.0% 30.0% 2.0% 1.0% 0.0% 0.0% - 

Rebate case 39.7% 7.0% 20.0% 30.0% 2.0% 1.0% 0.3% 0.0% - 

CSCR 

Base case 67.0% 10.0% 2.0% 2.0% 11.0% 3.0% 5.0% 0.0% 0.0% 

Rebate case 58.5% 10.0% 2.0% 10.5% 11.0% 3.0% 5.0% 0.0% 0.0% 

0%

5%

10%

15%

20%

25%

012345678

Participant Benefit-Cost Ratio

Penetration Rate

Figure 16.3.2 Market Penetration Curve for CSIR Small Electric Motors 

16-11 

EERE-2007-BT-STD-0007 COMMENT 19
0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14

Participant Benefit-Cost Ratio

Penetration Rate

Figure 16.3.3 Market Penetration Curve for CSCR Small Electric Motors 

Other Capacitor-Start Rebate Scenarios 

 DOE analyzed two additional consumer rebate scenarios for capacitor-start motors. The 

first scenario models the impact of a $25 rebate for 1 HP CSIR motors (as well as scaled rebates 

for other classes) which meet the efficiency of efficiency level 4, rather than level 6. CSCR 

rebates in this scenario continue to promote the target efficiency level (level 3). This corresponds 

to a rebate program targeting capacitor-start TSL 2. This rebate reimburses the consumer for a 

significantly larger fraction of the incremental cost, resulting in significantly greater utilization 

of the rebate program. Table 17.3.5 shows the B/C ratios for this scenario. 

16-12 

EERE-2007-BT-STD-0007 COMMENT 19
16-13 

Table 16.3.5 Benefit/Cost Ratios for Capacitor-Start Small Electric Motors, CSIR Level 4 

(TSL 2) Rebate Policy Case 

4-pole 1/2 HP CSIR 4-pole 3⁄4 HP CSCR 

Benefit (Lifetime Operating Cost Savings) $90.15 $71.34 

Incremental Installed Cost (Increased Installed Cost) $35.15 $48.90 

B/C Ratio with No Rebate 2.56 1.46 

Penetration Curve Market Share without Rebate 2.7% 32.6% 

Current Market Share at Target Level 3.0% 21.0% 

Rebate Amount $17.67 $21.65 

Adjusted Incremental Installed Cost 

(Increased Installed Cost after Rebate) $17.48 $27.25 

B/C Ratio for Rebate Policy Case 5.16 2.62 

Penetration Curve Market Share with Rebate 12.0% 45.8% 

DOE Estimated Market Share with Rebate 13.2% 29.5% 

 DOE then used the B/C ratios with the penetration curves shown in Figures 17.3.2 and 

17.3.3 to estimate the increased percentage of consumers who would purchase the units that meet 

efficiency level 4 if given a rebate incentive. DOE again chose the “high barriers” curve for 

CSIR motors and the “low barriers” curve for CSCR motors. Using the method discussed above, 

DOE estimated that the market share of CSIR equipment at efficiency level 4 would increase by 

11.2 percent. 

Table 16.3.6 Capacitor-Start Small Electric Motor TSL 5 Consumer Rebate Efficiency 

Market Share Impacts 

Baseline Eff. 1 Eff. 2 Eff. 3 Eff. 4 Eff. 5 Eff. 6 Eff. 7 Eff. 8 

CSIR 

Base case 40.0% 7.0% 20.0% 30.0% 2.0% 1.0% 0.0% 0.0% - 

Rebate case 29.8% 7.0% 20.0% 30.0% 12.2% 1.0% 0.0% 0.0% - 

CSCR 

Base case 67.0% 10.0% 2.0% 2.0% 11.0% 3.0% 5.0% 0.0% 0.0% 

Rebate case 58.5% 10.0% 2.0% 10.5% 11.0% 3.0% 5.0% 0.0% 0.0% 

 DOE’s CSIR/CSCR market share model, detailed in section 9.4, indicates that there are 

significant market barriers to the purchase of CSCR motors, even when it would be cost effective 

for consumers to do so. DOE therefore analyzed a rebate scenario which targets only CSCR 

motors. This scenario models the effects of relatively large rebates ($50 for 1 HP motors) for 

CSCR motors which meet the policy-target efficiency level (efficiency level 3, corresponding to 

TSL 7), where there is no rebate for CSIR motors. Table 17.3.7 shows the B/C ratios and 

resulting market share impacts for this scenario. 

EERE-2007-BT-STD-0007 COMMENT 19
16-14 

Table 16.3.7 Benefit/Cost Ratios for Capacitor-Start Small Electric Motors, CSCR-only 

Rebate Policy Case 

4-pole 1/2 HP CSIR 4-pole 3⁄4 HP CSCR 

Benefit (Lifetime Operating Cost Savings) $109.81 $71.34 

Incremental Installed Cost (Increased Installed Cost) $97.50 $48.90 

B/C Ratio with No Rebate 1.13 1.57 

Penetration Curve Market Share without Rebate 0.4% 32.6% 

Current Market Share at Target Level 0.0% 21.0% 

Rebate Amount $0.00 $21.65 

Adjusted Incremental Installed Cost 

(Increased Installed Cost after Rebate) $97.50 $27.25 

B/C Ratio for Rebate Policy Case 1.13 13.71 

Penetration Curve Market Share with Rebate 0.4% 69.8% 

DOE Estimated Market Share with Rebate 0.0% 44.9% 

 DOE then used the CSCR B/C ratios with the penetration curve shown in Figure 17.3.3 to 

estimate the increased percentage of consumers who would purchase CSCR motors which meet 

the target efficiency level. DOE again chose the “low barriers” penetration curve. Using the 

method discussed above, DOE estimated that the market share of CSCR equipment at efficiency 

level 3 (the CSCR level of TSL 6) would increase by 23.9 percent. DOE again used its 

CSIR/CSCR market share model to model the impact of this differential rebate program on 

CSCR market share within each equipment class. DOE found that this program would increase 

total shipments of CSCR motors in the analysis period (2015-2045) from 6.9 million in the base 

case to 11.1 million. 

 To calculate the impacts of these policies, DOE adjusted the market shares of capacitorstart small electric motors at the relevant efficiencies in its NIA model to represent the policy 

case scenarios. Table 16.3.8 shows the efficiency distributions used to analyze these rebate 

policies. 

Table 16.3.8 Capacitor-Start Small Electric Motor CSCR-Only Consumer Rebate 

Efficiency Market Share Impacts 

Baseline Eff. 1 Eff. 2 Eff. 3 Eff. 4 Eff. 5 Eff. 6 Eff. 7 Eff. 8 

CSIR 

Base case 40.0% 7.0% 20.0% 30.0% 2.0% 1.0% 0.0% 0.0% - 

Rebate case 40.0% 7.0% 20.0% 30.0% 2.0% 1.0% 0.0% 0.0% - 

CSCR 

Base case 67.0% 10.0% 2.0% 2.0% 11.0% 3.0% 5.0% 0.0% 0.0% 

Rebate case 43.1% 10.0% 2.0% 25.9% 11.0% 3.0% 5.0% 0.0% 0.0% 

EERE-2007-BT-STD-0007 COMMENT 19
16-15 

16.3.2.2 Consumer Tax Credits 

 Consumer tax credits cover a percentage of the difference in incremental product price 

between equipment meeting baseline efficiency levels and that with higher efficiencies. 

Consumer tax credits are considered a viable non-regulatory market transformation program, as 

shown by the inclusion of Federal consumer tax credits in EPACT 2005 for various residential 

appliances. 

 DOE estimated that for both polyphase and capacitor-start small electric motors, the 

consumer participation rate would be lower than the rate of participation in consumer rebates. 

Research on tax credits has shown that the time delay to the consumer in receiving a 

reimbursement through a tax credit, plus the added transaction costs in tax return preparation, 

make the tax credit incentive less effective than a rebate received at the time of purchase. Based 

on previous analysis8

, DOE assumed that only 60 percent as many consumers would take 

advantage of the tax credit as would take advantage of a rebate. 

 Using a similar approach as for the rebate policy, DOE estimated that the market share of 

target efficiency level motors would increase due to consumer tax credits over the base case. For 

all covered motors, these changes in percentage market penetrations are 60 percent of the market 

penetration changes estimated for the consumer rebate policy. 

 DOE assumed that the impact of this policy would be to permanently transform the 

market so that the increased market penetration seen in the first year of the program would be 

maintained throughout the forecast period. Table 17.3.9 shows the efficiency distributions used 

in analyzing the impact of this policy. 

Table 16.3.9 Small Electric Motor Consumer Tax Credit Efficiency Market Share 

Impacts 

Baseline Eff. 1 Eff. 2 Eff. 3 Eff. 4 Eff. 5 Eff. 6 Eff. 7 Eff. 8 

Polyphase 

Base case 82.0% 4.0% 4.0% 4.0% 6.0% 0.0% 0.0% 0.0% - 

Consumer 

Tax Credit 81.8% 4.0% 4.0% 4.0% 6.0% 0.2% 0.0% 0.0% 

- 

CSIR 

Base case 40.0% 7.0% 20.0% 30.0% 2.0% 1.0% 0.0% 0.0% - 

Consumer 

Tax Credit 39.8% 7.0% 20.0% 30.0% 2.0% 1.0% 0.2% 0.0% 

- 

CSCR 

Base case 67.0% 10.0% 2.0% 2.0% 11.0% 3.0% 5.0% 0.0% 0.0% 

Consumer 

Tax Credit 61.9% 10.0% 2.0% 7.1% 11.0% 3.0% 5.0% 0.0% 0.0% 

EERE-2007-BT-STD-0007 COMMENT 19
16-16 

16.3.2.3 Manufacturer Tax Credits 

 Manufacturer tax credits are considered a viable non-regulatory market transformation 

program, as shown by the inclusion of Federal tax credits in EPACT 2005 for manufacturers of 

residential appliances. Similar to consumer tax credits, manufacturer tax credits would 

effectively result in lower product prices for consumers by an amount that covered part of the 

incremental price difference between products meeting baseline efficiency levels and those 

meeting targeted efficiency levels. 

 DOE assumed that this incentive policy would help reimburse manufacturers for 

retooling costs. Because these tax credits would go to manufacturers instead of consumers, DOE 

assumed that manufacturers would pass on the reduced costs. Since the direct price effect is 

approximately equivalent to the announcement effect,6 DOE estimated that half of the consumers 

assumed to take advantage of consumer tax credits would purchase more-efficient products due 

to a manufacturer tax credit program. Using this information, DOE calculated the percentage by 

which market penetration of target efficient level motors would increase due to manufacturer tax 

credits over the base case. 

 DOE assumed that the impact of this policy would be to permanently transform the 

market so that the increased market penetration seen in the first year of the program would be 

maintained throughout the forecast period. Table 17.3.10 shows the efficiency distributions used 

in analyzing the impact of this policy. 

Table 16.3.10 Small Electric Motor Manufacturer Tax Credit Efficiency Market Share 

Impacts 

Baseline Eff. 1 Eff. 2 Eff. 3 Eff. 4 Eff. 5 Eff. 6 Eff. 7 Eff. 8 

Polyphase 

Base case 82.0% 4.0% 4.0% 4.0% 6.0% 0.0% 0.0% 0.0% - 

Manufacturer 

Tax Credit 81.9% 4.0% 4.0% 4.0% 6.0% 0.1% 0.0% 0.0% 

- 

CSIR 

Base case 40.0% 7.0% 20.0% 30.0% 2.0% 1.0% 0.0% 0.0% - 

Manufacturer 

Tax Credit 39.9% 7.0% 20.0% 30.0% 2.0% 1.0% 0.1% 0.0% 

- 

CSCR 

Base case 67.0% 10.0% 2.0% 2.0% 11.0% 3.0% 5.0% 0.0% 0.0% 

Manufacturer 

Tax Credit 64.5% 10.0% 2.0% 4.6% 11.0% 3.0% 5.0% 0.0% 0.0% 

16.3.3 Voluntary Energy Efficiency Targets 

For all categories of small electric motors, DOE assumed that the market behavior in the 

context of voluntary targets would be similar to market behavior related to the voluntary NEMA 

Premium program for three-digit frame series polyphase motors. Current market share for 

EERE-2007-BT-STD-0007 COMMENT 19
16-17 

NEMA Premium motors is roughly 25%. However, DOE assumed that 20% of this market share 

can be attributed to promotion, labeling, and other non-financial incentives, and 5% may be 

attributed to current rebate programs for such motors. DOE assumed that a voluntary program 

for small electric motors would achieve a 20% market share in the target efficiency levels for 

polyphase and CSIR motors. Current CSCR market share in the target level and above is 21%. 

DOE assumed that a voluntary program similar to NEMA Premium would increase this share by 

10%, to 31%. Table 17.3.11 shows the efficiency distributions DOE assumed would result from 

a voluntary efficiency program. DOE assumed that these levels would be achieved in 2015 and 

remain constant throughout the analysis period. 

Table 16.3.11 Small Electric Motor Voluntary Efficiency Target Market Share Impacts 

Baseline Eff. 1 Eff. 2 Eff. 3 Eff. 4 Eff. 5 Eff. 6 Eff. 7 Eff. 8 

Polyphase 

Base case 82.0% 4.0% 4.0% 4.0% 6.0% 0.0% 0.0% 0.0% - 

Voluntary 

Effic. Targets 62.0% 4.0% 4.0% 4.0% 6.0% 20.0% 0.0% 0.0% - 

CSIR 

Base case 40.0% 7.0% 20.0% 30.0% 2.0% 1.0% 0.0% 0.0% - 

Voluntary 

Effic. Targets 20.0% 7.0% 20.0% 30.0% 2.0% 1.0% 0.0% 20.0% - 

CSCR 

Base case 67.0% 10.0% 2.0% 2.0% 11.0% 3.0% 5.0% 0.0% 0.0% 

Voluntary 

Effic. Targets 57.0% 10.0% 2.0% 12.0% 11.0% 3.0% 5.0% 0.0% 0.0% 

16.3.4 Bulk Government Purchases 

 DOE assumed that a bulk government purchase policy would encourage Federal, State, 

and local governments to purchase equipment meeting the target efficiency levels. Aggregating 

public sector demand could provide a market signal to manufacturers and vendors that some of 

their largest customers sought suppliers with products that met an efficiency target at favorable 

prices. This program also could induce “market pull” impacts through manufacturers and 

vendors achieving economies of scale for high-efficiency products. 

 While there have been several bulk government purchasing initiatives at the Federal, 

State, and municipal levels, most of these programs have not tracked data on number of 

purchases or degree of compliance with procurement specifications. In many cases, procurement 

programs are decentralized, being part of larger State or regional initiatives. At the Federal level, 

the Federal Energy Management Program (FEMP) has performed studies of savings potential for 

its procurement specifications for appliances and other equipment on which DOE based its 

assumptions for this policy. Yet FEMP does not track purchasing data, due to the complexity of 

the purchasing systems, number of vendors, etc. There is evidence of increasing interest and 

activity in “green purchasing" on the State, county, and municipal levels. While many of these 

programs target office equipment, the existence of a growing infrastructure for efficient 

EERE-2007-BT-STD-0007 COMMENT 19
16-18 

purchasing specifications indicates that such impacts that DOE attributed to bulk government 

purchasing programs are feasible.9,10

 DOE analyzed only commercial-sector motor applications for government purchases. 

Direct government involvement in the industrial sector is very small. While direct government 

administration of housing is significant, residential applications of covered small electric motors 

are very small, and government purchases in this sector are unlikely to have a significant impact. 

DOE used the 2003 Commercial Building Energy Consumption Survey to determine the fraction 

of commercial floor space owned by government agencies, 23.7%, and assumed that government 

purchases an equivalent fraction of small electric motors in commercial applications. DOE then 

assumed that 80% of government purchases of small electric motors in commercial applications 

would meet the target efficiency level. For polyphase motors, such a program could increase 

market share for target-level equipment by 7.7%, while for capacitor-start motors it could 

increase the market share by 7.4%. Table 17.3.12 shows the resulting efficiency distributions, 

which DOE assumed would remain constant throughout the analysis period. 

Table 16.3.12 Small Electric Motor Bulk Government Purchases Efficiency Market 

Share Impacts 

Baseline Eff. 1 Eff. 2 Eff. 3 Eff. 4 Eff. 5 Eff. 6 Eff. 7 Eff. 8 

Polyphase 

Base Case 82.0% 4.0% 4.0% 4.0% 6.0% 0.0% 0.0% 0.0% - 

Bulk Gov’t 

Purchases 74.3% 4.0% 4.0% 4.0% 6.0% 7.7% 0.0% 0.0%

- 

CSIR 

Base Case 40.0% 7.0% 20.0% 30.0% 2.0% 1.0% 0.0% 0.0% - 

Bulk Gov’t 

Purchases 32.6% 7.0% 20.0% 30.0% 2.0% 1.0% 0.0% 7.4%

- 

CSCR 

Base Case 67.0% 10.0% 2.0% 2.0% 11.0% 3.0% 5.0% 0.0% 0.0%

Bulk Gov’t 

Purchases 59.6% 10.0% 2.0% 9.4% 11.0% 3.0% 5.0% 0.0% 0.0%

16.4 RESULTS SUMMARY FOR NON-REGULATORY ALTERNATIVES 

 Table 17.4.1 summarizes the impact of non-regulatory alternatives on the market share of 

target-level motors. (The capacitor-start TSL 2 consumer rebate does not change the market 

share of CSIR motors which meet the requirements of TSL 5 or TSL 7, but does save energy due 

to the increased market share of efficiency-level-4 CSIR motors.) 

EERE-2007-BT-STD-0007 COMMENT 19
16-19 

Table 16.4.1 Non-Regulatory Alterative Market Share Summary 

Market Share at or above Target 

Level (%) 

Policy Alternatives Polyphase CSIR CSCR 

No New Regulatory Action 0.0 0.0 21.0 

Target-Level Consumer Rebates 0.4 0.3 29.5 

TSL 2 Consumer Rebates N/A 13.2* 29.5 

CSCR-Only Consumer Rebates N/A 0.0 44.9 

Consumer Tax Credits 0.2 0.2 26.1 

Manufacturer Tax Credits 0.1 0.1 23.6 

Voluntary Efficiency Targets 20.0 20.0 31.0 

Bulk Government Purchases 7.7 7.4 28.4 

* Market share at CSIR efficiency level 4 or above (3.0% in the base case) 

 Tables 16.4.2 and 16.4.3 show the national energy savings and NPV resulting from the 

various non-regulatory alternative policy cases, when the efficiency target levels are equal to the 

proposed standard levels for each product (except where noted). The cases in which no 

regulatory action is taken with regard to small electric motors constitute the base case (or "No 

Action") scenarios, in which energy savings and NPV are zero by definition. For comparison, the 

tables also include the impacts of the proposed energy conservation standards. The NPV amounts 

shown in Tables 16.4.2 and 16.4.3 are based on two discount rates (seven percent and three 

percent real). The non-regulatory alternatives achieve lower energy savings than the proposed 

standards and have lower NPV. Table 16.4.3 shows the energy savings and NPV corresponding 

to a market scenario in which the market share shift between CSIR and CSCR driven by each 

policy alternative is complete by 2015. 

Table 16.4.2 Non-Regulatory Alternatives for Polyphase Small Electric Motors 

Net Present Value* 

(billion 2008$)

Policy Alternatives 

Primary 

Energy 

Savings 

(quads) 7% discount rate 3% discount rate 

No New Regulatory Action 0.0000 0.0000 0.0000 

Consumer Rebates 0.0015 0.0005 0.0030 

Consumer Tax Credits 0.0009 0.0003 0.0018 

Manufacturer Tax Credits 0.0004 0.0001 0.0009 

Voluntary Efficiency Targets 0.0716 0.0231 0.1426 

Bulk Government Purchases 0.0276 0.0089 0.0549 

Proposed Standards at TSL 5 0.3298 0.0598 0.5635 

* Net present value (NPV) is the value of a time series of costs and savings. DOE determined the NPV from 2015 

to 2065 in billions of 2008$.

EERE-2007-BT-STD-0007 COMMENT 19
16-20 

Table 16.4.3 Non-Regulatory Alternatives for Capacitor-Start Small Electric Motors 

Net Present Value* 

(billion 2008$)

Policy Alternatives 

Primary 

Energy 

Savings 

(quads) 7% discount rate 3% discount rate 

No New Regulatory Action 0.000 0.000 0.000 

Consumer Rebates 0.071 0.245 0.566 

TSL 2 Consumer Rebates 0.187 0.517 1.237 

CSCR-Only Consumer Rebates 0.130 0.428 0.993 

Consumer Tax Credits 0.057 0.206 0.473 

Manufacturer Tax Credits 0.047 0.178 0.405 

Voluntary Energy Efficiency Targets 0.749 0.331 1.469 

Bulk Government Purchases 0.311 -0.016 0.304 

Proposed Standards at TSL 7 2.128 5.674 13.586 

* Net present value (NPV) is the value of a time series of costs and savings. DOE determined the NPV from 

2015 to 2065 in billions of 2008$.

EERE-2007-BT-STD-0007 COMMENT 19
16-21 

 

REFERENCES 

1

 Rufo, M. and F. Coito. California's Secret Energy Surplus: The Potential for Energy 

Efficiency. Prepared for The Energy Foundation and The Hewlett Foundation. 2002. 

XENERGY Inc.: Oakland, CA. 

2

 Rufo, M. Personal communication. Itron, Inc., Oakland, CA. Telephone conversation with 

Barbara Atkinson, LBNL. January 2008. 

3

 ICF International. Arizona Public Service Energy Efficient Market Potential Study. 2007. ICF 

International: Fairfax, VA. 

4

 Lee, A. Personal communication. Quantec, LLC, Portland, OR. Telephone conversation with 

Barbara Atkinson, LBNL. January 2008. 

5

 Mosenthal, P. Personal communication. Optimal Energy, Bristol, VT. Telephone 

conversation with Barbara Atkinson, LBNL. January 2008. 

6

 Train, K. Customer Decision Study: Analysis of Residential Customer Equipment Purchase 

Decisions. Prepared for Southern California Edison by Cambridge Systematics, Pacific 

Consulting Services, The Technology Applications Group, and California Survey Research 

Services. 1994. 

7

 LBNL. Analysis of Tax Credits for Efficient Equipment. Lawrence Berkeley National 

Laboratory, End-Use Forecasting Group: Berkeley, CA. 

<http://enduse.lbl.gov/Projects/TaxCredits.html> (Last accessed April 24, 2008.) 

8

 U.S. Department of Energy-Office of Codes and Standards, Technical Support Document: 

Energy Efficiency Standards for Consumer Products: Refrigerators, Refrigerator-Freezers, 

and Freezers, including Environmental Assessment and Regulatory Impact Analysis, July, 

1995. Washington, DC. Report No. DOE/EE-0064. 

<http://www.osti.gov/bridge/product.biblio.jsp?osti_id=90266> 

9

 Smith , N. Personal communication. National Association of State Procurement Officials 

(NAPSO), Lexington, KY. Telephone conversation with Barbara Atkinson, LBNL. April, 

2008. <http://www.naspo.org/about/index.cfm> (Last accessed April 24, 2008.) 

10 Responsible Purchasing Network. <http://www.responsiblepurchasing.org/> (Last accessed 

April 24, 2008.) 

EERE-2007-BT-STD-0007 COMMENT 19