1 | Building Technologies Programeere.energy.govThe Parker Ranch installation in HawaiiBUILDING TECHNOLOGIES PROGRAMEnergy Conservation Program for ApplianceStandards:SNOPR Public Meeting for Microwave OvensMarch 14, 2012Wes AndersonDepartment of EnergyEnergy Efficiency & Renewable Energy2 | Building Technologies Programeere.energy.govIntroductionPurpose of the Public MeetingTo present revised methodologies based on stakeholder feedback,and characterize results for analysesTo discuss specific issues related to each analysisTo seek input from attendees on methodologies, assumptions anddata sourcesTo describe remaining steps before issuance of Final Rule3 | Building Technologies Programeere.energy.govIntroductionDOE welcomes comments, data, and information concerning itsanalysis on microwave ovens. Throughout this presentation, issuesthat correspond to issues raised in DOE’s published material from thisanalysis are raised for discussion inboxes like this one. Nonetheless,comments are welcome on any part of DOE’s analysis.Issues for Comment4 | Building Technologies Programeere.energy.govIntroductionNOPRSNOPR(StandbyPower)Framework Document made available byDOE on March 15, 2006. (71 FR 15059)ANOPR issued by DOE on November 15,2007 (72 FR 64432) (ANOPR PublicMeeting on December 13, 2007)NOPR issued by DOE on October 17,2008 (73 FR 62034) (NOPR Public Meetingon November 13, 2008). Comments fromstakeholders led DOE to continuerulemaking for microwave oven standby power.Final Rule issued by DOE on April 8, 2009 addressing cooking efficiencystandards. (74 FR 16040) DOE determined that new cooking efficiencystandards for microwave ovens were not justified.Steps in the Microwave Oven Energy Conservation StandardsRulemakingFinalRule (CookingEfficiency)ANOPRFrameworkDocumentFinalRule (StandbyPower)5 | Building Technologies Programeere.energy.govIntroductionPurpose of the SNOPRThe October 2008 NOPR analyzed microwave standby power as a measure ofenergy consumption separate from cooking efficiency, and proposed newprescriptive standards for standby power.DOE received comments that it should consider an updated version of theinternational standby power standard (International ElectrotechnicalCommission (IEC) 62301), which was expected shortly.Therefore, the rulemaking for microwave oven standby power was continuedrather than included in the April 2009 Final Rule to allow DOE to consider IEC62301 Second Edition•EPCA’s statutory requirement to consider the “most current version”•International harmonizationThe SNOPR analysis also addresses comments on other topics received on theNOPR.This SNOPR presents the revised analysis and proposes new standard levelsfor comment.6 | Building Technologies Programeere.energy.govIntroductionSNOPR for microwave oven standby powerissued by DOE on January 31, 2012(SNOPR Public Meeting today, March 14, 2012)Comments on SNOPR from interested parties•Transcript records oral comments from today’s public meeting•Written comments (comment period closes April 16, 2012)DOE reviews and considers all comments submitted on a timely basis.Final Rule Publication•In accordance with EPCA, as amended by EISA 2007.SNOPR Schedule7 | Building Technologies Programeere.energy.govIntroductionTest ProcedureDOE published an interim final rule for the microwave oven testprocedure on March 9, 2011, to incorporate measures of standbymode and off mode energy use.The test procedure amendments are based on IEC 62301 First Edition,which was the most current at the time that the interim final rule wasfinalized.•IEC Standard 62301 Second Edition published on January 27, 2011.DOE received comments on the interim final rule supporting theincorporation by reference of the second edition.DOE published an SNOPR on November 23, 2011, to proposeamendments based on IEC 62301 Second Edition and to addresscovered products.•DOE is currently considering comments received.8 | Building Technologies Programeere.energy.govProposed Amended Energy Conservation Standards for MicrowaveOven Standby Power (TSL3)Proposed StandardsThe compliance date of these standards would be three years fromthe publication of the final rule.DOE invites comments on these newly proposed energyconservation standards.Product ClassProposed EnergyConservation StandardsMicrowave-Only Ovens and CountertopCombination Microwave OvensMaximum Standby Power = 1.0wattBuilt-In and Over-the-Range CombinationMicrowave OvensMaximum Standby Power = 2.2watts9 | Building Technologies Programeere.energy.govOpening Remarks and Comments from InterestedParties on the Proposed Energy Conservation StandardsAt this time, DOE welcomes opening remarks from interestedparties on the SNOPR for microwave oven standby power.10 | Building Technologies Programeere.energy.govThe SNOPR analyses consist of revisions to the NOPR analyses.ScreeningAnalysisEngineeringAnalysisEnergy UseCharacterizationShipmentsAnalysisNationalImpactAnalysisMarkups toDetermineProductPriceLife-CycleCost andPaybackPeriod AnalysesMarket &TechnologyAssessmentProposedStandardLevelsEmploymentImpactAnalysisUtility &Environmental ImpactAnalysisLife-CycleCostSubgroupAnalysisManufacturerImpactAnalysisReviseNOPRAnalysisTrialStandardLevelsRegulatoryImpactAnalysisSNOPR Analyses Flow Diagram11 | Building Technologies Programeere.energy.govMarket AssessmentSNOPR Updates: Product ClassesDOE divides covered products into classes by:•the type of energy used,•capacity, or•other performance-related features thataffect consumer utility and efficiency.DOE defines a microwave oven as follows:“A class of kitchen ranges/ovens whichis a household cookingappliance consistingof a compartment designed to cook orheat food by means of microwave energy.”In the 2008 NOPR, DOE proposed a single product classencompassing microwave ovens with and without browning (thermal)elements,•Did not include microwave ovensincorporating convection systems(“combination microwave ovens”).In response to comments, DOE reassessed the covered products.•Determined that combination microwave ovens would also be consideredcovered products under the regulatory definition because they are capable ofcooking or heating food bymeans of microwave energy.12 | Building Technologies Programeere.energy.govMarket AssessmentProduct ClassesDOE investigated whether there are any performance related featuresthat would justify separate energy conservation standards based on:•Microwave-only vs. Combination•Configuration:Countertop Built-In Over-the-Range13 | Building Technologies Programeere.energy.govMarket AssessmentProduct Classes: Microwave-Only Over-the-Range vs.CountertopDOE conducted a survey of over-the-range microwave-only unitsavailable on the U.S. market.•Display technologies used are similar tothose used in countertop microwaveonly units (i.e., LED displays, LCDs, and VFDs).•In-store standby mode testing on a limited sample of over-the-range microwaveonly units showed similar standby powerconsumption as countertop microwaveonly units.DOE tentatively concludes that over-the-range microwave-only unitswould not warrant a separate product class from microwave-onlycountertop units.•May have additional components thatare energized during active modeoperation.•However, DOE’s testing showed that the presence of such features did notincrease the standby power consumption.14 | Building Technologies Programeere.energy.govMarket AssessmentProduct Classes: Countertop Combination vs.Microwave-OnlyDOE also conducted standby power testing on a sample of 13representative combination microwave ovens.Countertop Combination Microwave Ovens:•Use similar display technologies as countertop microwave-only units.•Standby power consumption ranging from 1.2 W to 4.7 W, similar to thestandby power consumption for countertop microwave-only units.DOE tentatively concludes that countertop combination microwaveovens would not warrant a product class separate from microwaveonly ovens.15 | Building Technologies Programeere.energy.govMarket AssessmentProduct Classes: Built-In and Over-the-RangeCombinationDOE testing showed standby power consumption for these productsranged from 4.1 W to 8.8 W, higher than the standby powerconsumption for other microwave oven product types.DOE’s reverse-engineering analysis suggests that additional featuresfor these products are required to handle the thermal loadsassociated with their installation and to provide consumer utility.Require a significant number of additional relays on the control boardand thus require a larger power supply for the control of such relays.16 | Building Technologies Programeere.energy.govMarket AssessmentProduct ClassesDOE believes that a separate product class should be established forbuilt-in and over-the-range combination microwave ovens.Product Class1. Microwave-Only Ovens and Countertop Combination Microwave Ovens2. Built-in and Over-the-Range Combination Microwave OvensIssue 7:DOE requests information on any utility or performanceimpacts to built-ins at the standard level proposed by DOE.17 | Building Technologies Programeere.energy.govTechnology AssessmentSNOPR Updates: Operating ModesThe DOE test procedure, as amended in the interim final rule,provides definitions for standby mode and off mode in microwaveovens :•“Standby modemeans any mode in which a ... microwave oven isconnected to a mains power source and offers one or more of thefollowing user-oriented or protective functions which may persist for anindefinite time:– To facilitate the activation of other modes (including activation ordeactivation of active mode) by remoteswitch (including remote control),internal sensor, or timer;– Continuous functions, including information or status displays (includingclocks) or sensor-based functions. Atimer is a continuous clock function(which may or may not be associatedwith a display) that allows forregularly scheduled tasks and thatoperates on a continuous basis.”•“Off modemeans a mode in which a ... microwave oven is connectedto a mains power source and is not providing any active mode orstandby mode function and where the mode may persist for anindefinite time. An indicator that only shows the user that the product isin the off position is included within the classification of an off mode.”18 | Building Technologies Programeere.energy.govTechnology AssessmentOperating ModesIn the NOPR, DOE noted that itobserved no microwave ovens in itstest sample that were capable of operation in off mode, and furtherthat its research suggested thatno microwave ovens available in theUnited States are capable of off mode operation.DOE received no comments or data indicating that microwave ovenswith an off mode are currently available or expected to becomeavailable on the U.S. market.DOE investigated the potential for microwave ovens with an on/offswitch to operate in off mode.•Such units would be capable of off mode.•Zero energy would be consumed in off mode.DOE did not propose in the SNOPR standards for off mode becausethere would be no benefit associate with such a standard.Issue 1:DOE requests input and data regarding off mode power formicrowave ovens.19 | Building Technologies Programeere.energy.gov19Technology AssessmentSNOPR Updates: Technology OptionsIn the NOPR, DOE identified features which affect standby power:•Cooking sensors;•Display technologies; and•Control strategies and associated control boards, including a function toturn off power to components during standby mode.Additional testing showed that standby power characteristics forcountertop combination microwave ovens and over-the-rangemicrowave-only units are similar to that of countertop microwave-onlyunits.Tests on over-the-range combination microwave ovens showed thatstandby power for these products also depend largely on the featureslisted above.20 | Building Technologies Programeere.energy.govTechnology AssessmentTechnology Options: Cooking SensorsDOE noted in the NOPR that zero-standby power piezoelectric steamsensors were available in microwaveovens in the U.S. market, andthat other sensors (infrared, weight, relative humidity sensors) hadeither been applied in microwave ovens sold elsewhere or had beenidentified as feasible for these applications.Commenters raised concerns about:•Availability, reliability, and accuracy;•Intellectual property issues.DOE conducted additional research, and notes:•Alternate sensor technologies have been available on the marketinternationally for years.•It is not aware of data showing that these sensors would have reliabilityand accuracy significantly different than the absolute humidity sensorscommonly employed in U.S. microwave ovens.•It is not aware of any intellectual or patent infringement issues for anyof the above-listed sensors.21 | Building Technologies Programeere.energy.govTechnology AssessmentTechnology Options: Display TechnologiesDOE identified three display technologies for microwave ovens:•Light-emitting diode (LED) displays•Liquid crystal displays (LCDs) with and without backlighting•Vacuum fluorescent displays (VFDs)Commenters submitted information on the utility of display technologies:•Reliability in higher-heat installations, such as over-the-range;•Viewing angle and visibility;•Availability of sizes and colors demanded byconsumers of higher-end products andwhich allow manufacturers to providea consistent appearanceamong products in asuite.Additional DOE research indicates:•Each display technology is currently incorporated in multiple over-the-range models.•Temperature ratings for the threetypes of displays are comparable.•Each display technology offers acceptable brightness, viewing angle, and ability todisplay complex characters in both countertop and over-the-range microwave ovens.•No microwave oven display had intermittent backlighting or other features that lessenutility.DOE continues to believe that all display technologies can be integrated incountertop and over-the-range microwave ovens with no loss of utility.22 | Building Technologies Programeere.energy.govIssue 2:DOE requests input and data on the utility provided by specificfeatures that contribute to microwave oven standby power. Inparticular, DOE seeks information on the utility of displaytechnologies, as well as on cooking sensors that do notrequire standby power.Issue for Public Comment23 | Building Technologies Programeere.energy.govTechnology AssessmentTechnology Options: Power Supply and Control BoardsDOE determined for the NOPR that switching power supplies couldimprove standby power by increasing power supply and control boardefficiency.•Up to 75-percent conversion efficiency with 0.2 W or less standby power.•DOE believed such power supplies wereunproven in long-term microwave ovenapplications.Additional DOE research indicates:•Switching power supplies are found inmany consumer products and appliances,suggesting adequate reliability and durability.•No data suggests that reliability is significantly worse than conventional linearpower supplies over the lifetime of a microwave oven.•While switching power supplies in otherconsumer applications may achieve 92-percent efficiency, DOE is unaware of anyswitching power supplies suitable forapplication in microwave ovens that exceed 75-percent efficiency.DOE observed switching power supplies in certain combinationmicrowave ovens in its recent test sample.24 | Building Technologies Programeere.energy.govTechnology AssessmentTechnology Options: Automatic Power-DownAutomatic power-down allows manufacturers to make design tradeoffsbetween incorporating standby power-consuming features (such asdisplays or cooking sensors) and including a function to cut power tothose components during standby mode.Commenters requested DOE consider a user-activated control to turnoff the display.•With the display switched off, the microwave oven would be in off modeunless other features associated with standby mode remain energized.•DOE is not aware of any products incorporating such a user-activatedcontrol.•DOE also does not have information on how often consumers mightmake use of this feature.•Although DOE is unable to consider user-activated controls for turningoff the display as a design feature, manufacturers are not precluded bythe proposed standards from incorporating it in their products.25 | Building Technologies Programeere.energy.govIssue 3:DOE requests input and data on control strategies available toenable manufacturers to make design tradeoffs betweenincorporating standby-power-consuming features such asdisplays or cooking sensors and including a function to turnpower off to these components during standby mode. DOEalso seeks comment on the viability and cost of microwaveoven control board circuitry that could accommodatetransistors to switch off cooking sensors and displays.Issue 4:Whether switching or similar modern power supplies canoperate successfully inside a microwave oven and theassociated efficiency impacts on standby power.Issues for Public Comment26 | Building Technologies Programeere.energy.govScreeningAnalysisEngineeringAnalysisEnergy UseCharacterizationShipmentsAnalysisNationalImpactAnalysisMarkups toDetermineProductPriceLife-CycleCost andPaybackPeriod AnalysesMarket &TechnologyAssessmentProposedStandardLevelsEmploymentImpactAnalysisUtility &Environmental ImpactAnalysisLife-CycleCostSubgroupAnalysisManufacturerImpactAnalysisReviseNOPRAnalysisTrialStandardLevelsRegulatoryImpactAnalysisSNOPR Analyses Flow Diagram27 | Building Technologies Programeere.energy.govEngineering AnalysisStandby Power Levels – Product Class 1For the NOPR, DOE established the following standby power levelsfor analysis:DOE believes that the TSLs and associated analyses are still valid forproduct class 1.Standby PowerLevel (TSL) SourceStandbyPower(W)Baseline Baseline 4.01 FEMP Procurement Efficiency Recommendation 2.02 Gap Fill 1.53 IEA 1-Watt Program 1.04 Max Tech 0.0228 | Building Technologies Programeere.energy.govEngineering AnalysisStandby Power Levels – Product Class 2For the SNOPR, DOE reverse-engineered a representative sample ofbuilt-in and over-the-range combination microwave ovens.•Analyzed the various components that contribute to the standby powerconsumption.•Measured standby power consumption of individual components.Standby PowerLevel (TSL) DescriptionStandbyPower(W)Baseline Baseline 4.51 Zero-standby cooking sensor 3.72 Switch mode power supply 2.73Solid state relays and optimized switch modepower supply2.24 Max Tech – automatic power down 0.0429 | Building Technologies Programeere.energy.govEngineering AnalysisIncremental Manufacturing Costs – Product Class 1DOE believes the standby power levels and correspondingincremental manufacturing costs presented in the NOPR remainfundamentally valid for product class 1.Scaled incremental costs to 2010$ using the Producer Price Index.StandbyPower Level Standby Power(W)Incremental Cost(2010$)Baseline 4.0 N/A1 2.0 $0.272 1.5 $0.603 1.0 $1.314 0.02 $4.5830 | Building Technologies Programeere.energy.govEngineering AnalysisIncremental Manufacturing Costs – Product Class 2To evaluate the built-in and over-the-range combination microwaveoven product class, DOE conducted analyses on a test sample of 13combination microwave ovens.•Product teardowns•Control board cost analysesDOE estimated the cost associated with each standby power level byusing quotes from various component suppliers to determine the costof the components used in each design option.StandbyPower Level Standby Power(W)Incremental Cost(2010$)Baseline 4.5 N/A1 3.7 $0.002 2.7 $2.293 2.2 $9.444 0.04 $5.1831 | Building Technologies Programeere.energy.govIssue 5:DOE requests input and data on the estimated incrementalmanufacturing costs, as well as the assumed approaches toachieve TSL 3 for microwave oven standby mode and offmode. DOE also seeks comment on whether any intellectualproperty or patent infringement issues are associated with thedesign options considered in the analyses.Issue for Public Comment32 | Building Technologies Programeere.energy.govScreeningAnalysisEngineeringAnalysisEnergy UseCharacterizationShipmentsAnalysisNationalImpactAnalysisMarkups toDetermineProductPriceLife-CycleCost andPaybackPeriod AnalysesMarket &TechnologyAssessmentProposedStandardLevelsEmploymentImpactAnalysisUtility &Environmental ImpactAnalysisLife-CycleCostSubgroupAnalysisManufacturerImpactAnalysisReviseNOPRAnalysisTrialStandardLevelsRegulatoryImpactAnalysisSNOPR Analyses Flow Diagram33 | Building Technologies Programeere.energy.govLife-Cycle Cost and Payback PeriodAnalysisLCC and PBP Analysis Inputs UpdateInputs October 2008 NOPR Changes for the SNOPRAffecting Installed CostsProduct Cost Derived by multiplying manufacturer cost by manufacturer, distributormarkups and sales tax.Used experience curve fits to forecast a pricescaling index to forecast product costs.Affecting Operating CostsAnnual Energy Use Annual energy use determined from the annual usage (average dailyuse cycles).No changeEnergy Prices Electricity: Updated using EIA’s 2006 Form 861 data.Variability: Regional energy prices determined for 13 regions.Electricity: Updatedusing EIA’s 2009 Form861 data.Variability: No change.Energy PriceTrendsEnergy: Forecasts updated with EIA’s Annual Energy Outlook 2008(AEO 2008).Reference Case, High Growth, and LowGrowth forecasts updated with EIA’s AEO2010 May Release.Repair andMaintenance CostsAssumed no repair or maintenance costs. No changeAffecting Present Value ofAnnual Operating Cost SavingsProduct Lifetime Estimated using surveyresults from RECS (1990, 1993, 1997, 2001,2005) and the U.S. Census AHS (2005, 2007), along with historicdata on appliance shipments.No changeDiscount Rates Variability: Characterized using Weibull probability distributions. No changeAffecting Installed and Operating CostsEffective Date ofNew Standard2012 201434 | Building Technologies Programeere.energy.govBase and Standards Case Efficiency DistributionsLife-Cycle Cost and Payback PeriodAnalysisLCC and PBP analysis typically analyzes standard levels relativeto a baseline efficiency levelNot all consumers purchase products at baseline levels•Must account for consumers purchasing more efficient products toaccurately estimate consumer economic impactsBase-Case efficiency distributions define the percentage of productsbeing purchased at various efficiency levels•Consumers already purchasing productsat efficiencies greater than orequal to a prospective standard level are not impacted by the standardBase-Case Efficiency Distributions•Determined by using 2005 data supplied by AHAMStandards-Case Efficiency Distributions•Applied a “roll-up” approach used in the preliminary analysis, but assignedENERGY STAR levels using the 3-year payback period criterion.35 | Building Technologies Programeere.energy.govLife-Cycle Cost and Payback PeriodAnalysisBase and Standards Case Efficiency DistributionsDOE maintained the shipments-weighted standby power and annualenergy use shown in the following tables throughout the forecastperiod, 2014–2043.Microwave and Countertop Combination Ovens: Standby Energy Consumption Distributions in2014 for Base and Standards CasesStand-byPower(W)Annual Energy Use(kWh/yr)Market Share(%)BaseCaseStandby Power Level12344.00 34.8 46%2.00 17.4 35% 81%1.50 13.0 19% 19% 100%1.00 8.69 0% 0% 0% 100%0.02 0.17 0% 0% 0% 0% 100%Shipments Weighted Standby Power2.83 1.90 1.50 1.00 0.02Shipments Weighted Annual Energy Use24.6 16.5 13.0 8.7 0.1736 | Building Technologies Programeere.energy.govLife-Cycle Cost and Payback PeriodAnalysisBase and Standards Case Efficiency DistributionsDOE maintained the shipments-weighted standby power and annualenergy use shown in the following tables throughout the forecastperiod, 2014–2043.Over the Range Combination Ovens: Standby Energy Consumption Distributions in 2014 forBase and Standards CasesStand-byPower(W)Annual Energy Use(kWh/yr)Market Share(%)Base CaseStandby Power Level1 2 344.50 39.1 100%3.70 32.1 0% 100%2.70 23.5 0% 0% 100%2.20 19.1 0% 0% 0% 100%0.04 0.35 0% 0% 0% 0% 100%Shipments Weighted Standby Power4.50 3.70 2.70 2.20 0.04Shipments Weighted Annual Energy Use39.1 32.1 23.5 19.1 0.3537 | Building Technologies Programeere.energy.govIssue 6:DOE requests input and data on the estimated market share ofmicrowave ovens at the standby power consumptionstipulated by the proposed standards (1.0 W for countertop;2.2 W for combination)Issue for Public Comment38 | Building Technologies Programeere.energy.govScreeningAnalysisEngineeringAnalysisEnergy UseCharacterizationShipmentsAnalysisNationalImpactAnalysisMarkups toDetermineProductPriceLife-CycleCost andPaybackPeriod AnalysesMarket &TechnologyAssessmentProposedStandardLevelsEmploymentImpactAnalysisUtility &Environmental ImpactAnalysisLife-CycleCostSubgroupAnalysisManufacturerImpactAnalysisReviseNOPRAnalysisTrialStandardLevelsRegulatoryImpactAnalysisSNOPR Analyses Flow Diagram39 | Building Technologies Programeere.energy.govShipments AnalysisInputs 2008 NOPR Description Changes for the SNOPRNumber of ProductClassesOne product class. Market share data provided byAHAM.Two product classes: (1) all microwave oven-only andcountertop microwave oven-combination; (2) over-the-rangemicrowave oven-combination. Market share data provided byAHAM; 99% product class #1 and 1% product class #2. Productclass market shares held constant over forecast period.New ConstructionShipmentsHousing forecasts updated with EIA AEO 2009 Aprilrelease forecasts for the Reference case, High growthcase, and Low growth case.No change in approach. Housing forecasts updated with EIAAEO 2010 forecasts for the Reference case, High growth case,and Low growth case.Replacements Determined by tracking total product stock by vintageand establishing the failure of the stock usingretirement functions from the LCC and PBP analysis.Retirement functions revised to be based on Weibulllifetime distributions.No change.Shipments Analysis Inputs 1 through 340 | Building Technologies Programeere.energy.govShipments AnalysisInputs 2008 NOPR Description Changesfor theSNOPRRetired Units not Replaced (i.e.,non-replacements)Used to calibrate shipments model to historical shipments data. No change.Historical Shipments Data sources include AHAM data submittal and Appliance magazine.No change.Purchase Price, Operating Cost,and Household Income Impacts dueto Efficiency StandardsDeveloped “relative price” elasticity, which accounts for the purchase price and thepresent value of operating cost savings divided by household income. Usedpurchase price and efficiency data specificto residential refrigerators, clotheswashers, and dishwashers between 1980 and 2002 to determine a “relative price”elasticity of demand of -0.34.No change.Fuel Switching Not applicable. No change.Shipments Analysis Inputs 4 through 741 | Building Technologies Programeere.energy.govInputs 2008 NOPR Description Changes for the SNOPRBase-Case ForecastedEfficienciesShipment-weighted efficiency (SWEF) determined in 2005.SWEF held constant over forecast period.No change.Standards-Case ForecastedEfficienciesAnalyzed as one product class. Roll-up scenario used fordetermining SWEF in the year that standards becomeeffective for each standards case. SWEF held constant overforecast period.Analyzed as two product classes. Roll-up scenarioused for determining SWEF in the year that standardsbecome effective for each standards case. SWEF heldconstant over forecast period.Annual Energy Consumptionper UnitAnnual weighted-average values as a function of SWEF. No change.Total Installed Cost per Unit Annual weighted-average values as a function of SWEF. Incorporated learning rate to forecast product prices.Energy Cost per Unit Annual weighted-average values as a function of the annualenergy consumption per unit and energy (and water) prices.No change.Impact AnalysesNIA inputs 1 through 5 and corresponding outputs for utility,environmental, employment, and regulatory impact analyses42 | Building Technologies Programeere.energy.govInputs 2008 NOPR Description Changes for the SNOPRRepair Cost and MaintenanceCost per UnitIncorporated changes in repair costs as a function ofstandby power.No change.Escalation of Energy Prices AEO 2008 forecasts (to 2030); extrapolated to 2042.Updated to AEO 2010 May release forecasts (to 2035);extrapolated to 2043.Energy Site-to-SourceConversionConversion varies yearly and is generated by DOE/EIA’sNEMS program (a time-series conversion factor; includeselectric generation, transmission, and distribution losses).No change.Discount Rate 3 and 7 percent real. No change.Present Year Future expenses discounted to 2007. Future expenses discounted to 2011.Impact AnalysesNIA inputs 6 through 10 and corresponding outputs for utility,environmental, employment, and regulatory impact analyses43 | Building Technologies Programeere.energy.govTrial Standard LevelsTrial StandardLevelStandby Power(W)Product Class 1: MicrowaveOnly and CountertopCombinationProduct Class 2: Built-In andOver-the-Range Combination1 2.00 3.702 1.50 2.703 1.00 2.204 0.02 0.04The TSLs analyzed are equivalent to the standby power levels44 | Building Technologies Programeere.energy.govScreeningAnalysisEngineeringAnalysisEnergy UseCharacterizationShipmentsAnalysisNationalImpactAnalysisMarkups toDetermineProductPriceLife-CycleCost andPaybackPeriod AnalysesMarket &TechnologyAssessmentProposedStandardLevelsEmploymentImpactAnalysisUtility &Environmental ImpactAnalysisLife-CycleCostSubgroupAnalysisManufacturerImpactAnalysisReviseNOPRAnalysisTrialStandardLevelsRegulatoryImpactAnalysisSNOPR Analyses Flow Diagram45 | Building Technologies Programeere.energy.govManufacturer Impact AnalysisSNOPR UpdatesDOE updated the MIA results based on several changes to otheranalyses that impact the MIA:•Engineering Analysis - Updated manufacturing production costs(MPCs) for Product Class 1, new MPCs for Product Class 2, and allcosts converted to 2010$.•NIA - Updated total shipments and efficiency distributions, used a newanalysis period (2014-2043) and base year (2011), and incorporatedprice trends into the analysis;DOE also updated the conversion costs•To segment total product and capital conversion costs between ProductClass 1 and Product Class 2, DOE used the same split between thesetwo product classes as used in the NIA•DOE used the same per-platform costs at each standby power level forboth product classes, but converted these product and capitalconversion costs to 2010$ using the PPI.46 | Building Technologies Programeere.energy.govManufacturer Impact AnalysisSummary of Results at the Proposed Standards LevelAt TSL 3, the impacts on INPV range from approximately -$52.9 millionto -$73.6 million (a change in INPV of -4.7 percent to -6.5 percent).•Base case industry value is estimated to be $1.1 billion in $2010.•The required conversion costs are estimated to be $94.7 million at TSL3. As an indication of the magnitude of these conversion costs, industrycash flow decreases by approximately 29.9 percent, to $59.0 million,compared to the base-case value of $84.2 in the year before thecompliance date of the standard.•The incremental MPCs at TSL 3 are estimated to be $1.31 for ProductClass 1 and $9.44 for Product Class 2. The range of the impacts onINPV and cash flow at TSL 3 varies depending on the ability ofmanufacturers to pass on these increases in MPCs to their customers.The vast majority of microwave ovens are imported and theemployment impacts in the GRIM are small.47 | Building Technologies Programeere.energy.govScreeningAnalysisEngineeringAnalysisEnergy UseCharacterizationShipmentsAnalysisNationalImpactAnalysisMarkups toDetermineProductPriceLife-CycleCost andPaybackPeriod AnalysesMarket &TechnologyAssessmentProposedStandardLevelsEmploymentImpactAnalysisUtility &Environmental ImpactAnalysisLife-CycleCostSubgroupAnalysisManufacturerImpactAnalysisReviseNOPRAnalysisTrialStandardLevelsRegulatoryImpactAnalysisSNOPR Analyses Flow Diagram48 | Building Technologies Programeere.energy.govProposed StandardsDOE considered four TSLs for standby power, beginning withthe most efficient level (TSL 4) and worked down to a levelwhere the benefits of potential standards outweighed theburdens.•DOE tentatively concludes that at TSL 4, the benefits of energysavings, economic gain, and emissions reductions would beoutweighed by the potential economic burden on consumers from lossof product utility and the large capitalconversion costs that would resultin a reduction in INPV for manufacturers.•DOE tentatively concludes that TSL 3 saves a significant amount ofenergy and is technologically feasible and economically justified.Selection of Proposed Standard49 | Building Technologies Programeere.energy.govProposed StandardsMicrowave-Onlyand CountertopCombinationOvensBuilt-In and Overthe-RangeCombinationOvensProposed standard level3 3National Energy Savings(quads)0.41 0.01Net Present Value(2010$ billion)3% discount rate3.58 0.027% discount rate1.81 0.01Industry NetPresent Value2010$ million1031.6 to 1050.6 22.3 to 23.9% change(6.5) to (4.8) (7.1) to (0.3)50 | Building Technologies Programeere.energy.govClosingHow to Submit Comments...Public Meeting – oral comments will be captured in the transcript and becomepart of the public record.Written comments – Reference docket #: EERE-2011-BT-STD-0048 and/orRIN #: 1904-AC07Email: MWO-2011-BT-STD-0048@ee.doe.govMail: Mrs. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program1000 Independence Avenue, SW, Mailstop EE-2JWashington, DC 20585-0121Courier: Mrs. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program950 L'Enfant Plaza, 6th FloorWashington, DC 20024Telephone: (202) 586-294551 | Building Technologies Programeere.energy.govAPPENDIX52 | Building Technologies Programeere.energy.govIntroductionStatutory Authority – the Energy Policy andConservation Act (EPCA) as AmendedEPCA (42 U.S.C. 6291et seq.) set forth criteria and procedures for DOE’sadoption and amendment of energy conservation standards and test proceduresfor covered products.Energy Independence and Security Act of 2007 (EISA 2007) Amendments to EPCA•Any final rule establishing or revising a standard for a covered product, adoptedafter July 1, 2010, shall incorporatestandby and off mode energy use into a singlestandard if feasible. If not feasible, DOE shall prescribe a separate standard forstandby and off mode energy use, if justified.New microwave oven standby power standards are being considered as part of arulemaking that also initially covered residential dishwashers, dehumidifiers, andconventional cooking products and commercial clothes washers.•Amended dishwasher and dehumidifier standardswere established by EISA 2007.•Standards for conventional cooking productsand microwave ovensas to cookingefficiency were addressed in a final rule in April 2009.•Amended commercial clothes washer standards were adopted by final rule inJanuary 2010.53 | Building Technologies Programeere.energy.govThe Energy Policy and Conservation Act (EPCA) directs DOE toconsider seven factors when setting energy conservation standardsFactor Analysis1. Economic impact on consumers andmanufacturersLife-cycle cost analysisManufacturer impacts analysis2. Lifetime operating cost savings Life-cycle cost analysis3. Total projected energy savings National impact analysis4. Impact on utility or performance Screening analysisEngineering analysis5. Impact of any lessening of competition Manufacturer impacts analysis6. Need for national energy conservation National impact analysis7. Other factors the Secretary considersrelevantEnvironmental assessmentUtility impact analysisEmployment impact analysisIntroduction54 | Building Technologies Programeere.energy.govIntroductionTest Procedure BackgroundDOE’s test procedure for microwave ovens appears at appendix I topart 430 subpart B of Title 10 of the Code of Federal Regulations.DOE repealed the regulatory provisions establishing the cookingefficiency test procedure for microwave ovens under EPCA in a finalrule published on July 22, 2010.•DOE determined that the microwave oven test procedure provisions tomeasure cooking efficiency do not produce accurate and repeatabletest results.•Was unaware of any test procedures that have been developed thataddress the concerns with the DOE microwave oven cooking efficiencytest procedure.EISA 2007 Amendments to EPCA direct DOE to incorporate a measureof standby and off mode energy consumption into its microwave oventest procedure by March 31, 2011.55 | Building Technologies Programeere.energy.govEngineering AnalysisEfficiency MetricDOE eliminated the active mode cooking efficiency test procedureprovisions in a July 2010 Test Procedure Final Rule.•Existing provisions did not produce accurate and repeatable results.•Absence of active mode provisions result in a de facto separate energyuse descriptor for microwave oven standby mode and off mode energyuse.Proposed standards are based on a maximum average standbypower, in Watts (W).56 | Building Technologies Programeere.energy.govEngineering AnalysisIncremental Manufacturing CostsFrom product testing and reverse engineering, DOE observedcorrelations between:•Specific components and technologies, or combinations thereof, and•Measured standby powerDOE obtained preliminary incremental manufacturing costsassociated with standby power levels by considering combinations ofthose components as well as other technology options identified toreduce standby power.DOE presented manufacturing cost estimates based on quotesobtained from:•suppliers,•interviews with manufacturers and subject matter experts,•research and literature review, and•numerical modeling.57 | Building Technologies Programeere.energy.govBaseline and Incremental Markups■Markupsrelate customer price to cost of goods sold (CGS)■Baseline markupsrelate price to cost prior to a change in efficiency•Baseline markups indicate a customer price that covers all of a retailer’sexpenses plus profit.•Direct labor costs (salaries, payroll, rental and occupancy) are included.■Incremental markupsrelate the incremental change in customerprice to the incremental change in CGS beyond baseline•Some distribution costs remainconstant with CGS increases.•Incremental markups cover only expensesthat vary with CGS – in this case,expenses that increase due to anincrease in equipment efficiency.•For example, direct labor costs (salaries,payroll, rental and occupancy) do not varywith efficiency-induced changes in CGS.•DOE assumes other operating costs and profit will scale proportionally withCGS.Markups to Determine EquipmentPrice58 | Building Technologies Programeere.energy.govEstimates of Retail Market Competition■DOE assumed that competition in the retail market, combined withinelastic demand, will put downward pressure on retail margins,supporting the incremental markup approach.■To confirm that retail markets are competitive, DOE used a commonlyused index of market concentration, the Four Firm Concentration Ratio(FFCR).*■An FFCR < 40% indicates a relatively unconcentrated market, while anFFCR > 70% indicates a concentrated market (oligopoly).■FFCRs were evaluated for major appliance sales in three retail channels:Electronics and Appliance Stores, Building and Material and SuppliesDealers, and General Merchandise Stores. In each case, the resultingFFCR was well below the 40% threshold.* The Department of Justice uses amore complete index, the Herfindahl-Hirschman Index (HHI), but DOE lackedthe information necessary for calculating an HHI.Markups to Determine EquipmentPrice59 | Building Technologies Programeere.energy.govLife-Cycle Cost and Payback PeriodAnalysisLCC and PBP Analysis Inputs60 | Building Technologies Programeere.energy.gov■Background•DOE must publish an initial regulatory flexibility analysis if it cannot certifythat the rule will not have a significant economic impact on a substantialnumber of small entities.■Findings•DOE identified no small business manufacturer of microwave ovens forwhich there would be a significant economic impactRegulatory Flexibility Act61 | Building Technologies Programeere.energy.govSummary of ResultsTSL 1 TSL 2 TSL 3 TSL 4(MaxTech)National Energy Savings(quads)0.21 0.30 0.41 0.63NPV of Consumer Benefits(2010$ billion)7% discount rate1.02 1.42 1.82 2.253% discount rate1.98 2.78 3.59 4.60Maximum Industry NPV Change(2010$ billion)(27.1) to(29.3)(45.2) to(52.4)(52.9) to(73.6)(90.4) to(165.7)Maximum Industry NPV Change(%)(2.4) to(2.6)(4.0) to(4.6)(4.7) to(6.5)(8.0) to(14.7)Mean LCC Savings(2010$)Microwave-Only Ovens and Countertop Combination Microwave Ovens7 10 13 12Built-In and Over-the-Range CombinationMicrowave Ovens6 11 4 27Present Value of CO2Emissions Savings(2010$ billion)70 to1,066101 to1,539139. to2,118213 to3,259ProposedLevel