1 | Building Technologies Program 

BUILDING TECHNOLOGIES PROGRAM

Energy Conservation Program for Appliance 

Standards:

SNOPR Public Meeting for Microwave Ovens

Marc

We

Departm

Energy Efficienc
2 | Building Technologies Program 

Introduction

Purpose of the Public Meeting

 To present revised methodologies based on stakeholder fe

and characterize results for analyses

 To discuss specific issues related to each analysis To seek input from attendees on methodologies, assumpti

data sources

 To describe remaining steps before issuance of Final Rule
3 | Building Technologies Program 

Introduction

DOE welcomes comments, data, and information concerning analysis on microwave ovens. Throughout this presentationthat correspond to issues raised in DOE’s published materiaanalysis are raised for discussion in boxes like this one. Noncomments are welcome on any part of DOE’s analysis.

Issues for Comment
4 | Building Technologies Program 

Introduction

NOPR

SNOPR

(Standby

Power)

 Framework Document made available by DOE on March 15, 2006. ( ANOPR issued by DOE on November 15, 2007 (72 FR 64432) (ANOP

Meeting on December 13, 2007)

 NOPR issued by DOE on October 17, 2008 (73 FR 62034) (NOPR Pu

on November 13, 2008). Comments from stakeholders led DOE to rulemaking for microwave oven standby power.

 Final Rule issued by DOE on April 8, 2009 addressing cooking effic

standards. (74 FR 16040) DOE determined that new cooking efficistandards for microwave ovens were not justified.

Steps in the Microwave Oven Energy Conservation Sta

Rulemaking

Final

Rule (Cooking

Efficiency)

ANOPR Framework Document

Final

Rule (Sta

Power
5 | Building Technologies Program 

Introduction

Purpose of the SNOPR

 The October 2008 NOPR analyzed microwave standby power as a m

energy consumption separate from cooking efficiency, and proposprescriptive standards for standby power.

 DOE received comments that it should consider an updated versio

international standby power standard (International ElectrotechnicCommission (IEC) 62301), which was expected shortly.

 Therefore, the rulemaking for microwave oven standby power was 

rather than included in the April 2009 Final Rule to allow DOE to co62301 Second Edition

• EPCA’s statutory requirement to consider the “most current version”• International harmonization

 The SNOPR analysis also addresses comments on other topics rec

NOPR.

 This SNOPR presents the revised analysis and proposes new stand

for comment.
6 | Building Technologies Program 

Introduction

 SNOPR for microwave oven standby power issued by DOE on Janu

(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 bas Final Rule Publication

• In accordance with EPCA, as amended by EISA 2007.

SNOPR Schedule
7 | Building Technologies Program 

Introduction

Test Procedure

 DOE published an interim final rule for the microwave oven 

procedure on March 9, 2011, to incorporate measures of stamode and off mode energy use.

 The test procedure amendments are based on IEC 62301 Fi

which was the most current at the time that the interim fina

finalized.

• IEC Standard 62301 Second Edition published on January 2

 DOE received comments on the interim final rule supportin

incorporation by reference of the second edition.

 DOE published an SNOPR on November 23, 2011, to propos

amendments based on IEC 62301 Second Edition and to adcovered products.

• DOE is currently considering comments received.
8 | Building Technologies Program 

Proposed Amended Energy Conservation Standards for 

Oven Standby Power (TSL 3)

Proposed Standards

 The compliance date of these standards would be three 

the publication of the final rule.

DOE invites comments on these newly proposed energy conservation standards.

Product Class

Proposed Ene

Conservation Stan

Microwave-Only Ovens and Countertop Combination Microwave Ovens

Maximum Standby Pow

watt

Built-In and Over-the-Range Combination Microwave Ovens

Maximum Standby Pow

watts
9 | Building Technologies Program 

Opening Remarks and Comments from Interes

Parties on the Proposed Energy Conservation Sta

At this time, DOE welcomes opening remarks from intparties on the SNOPR for microwave oven standby po
10 | Building Technologies Program 

The SNOPR analyses consist of revisions to the NOPR analyses.

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups to DetermineProductPrice

Life-CycleCost andPayback Period Analyses

Market & Technology Assessment

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

NOPR

Analysis

Trial 

Standard 

Levels

Regulator

Impact 

Analysis

SNOPR Analyses Flow Diagram
11 | Building Technologies Program 

Market Assessment

SNOPR Updates: Product Classes

 DOE divides covered products into classes by: 

• the type of energy used,• capacity, or • other performance-related features that affect consumer utility and 

 DOE defines a microwave oven as follows:

“A class of kitchen ranges/ovens which is a household cooking applian

of a compartment designed to cook or heat food by means of microwa

 In the 2008 NOPR, DOE proposed a single product class 

encompassing microwave ovens with and without browninelements, 

• Did not include microwave ovens incorporating convection systems 

(“combination microwave ovens”).

 In response to comments, DOE reassessed the covered pro

• Determined that combination microwave ovens would also be cons

covered products under the regulatory definition because they are ccooking or heating food by means of microwave energy.
12 | Building Technologies Program 

Market Assessment

Product Classes

 DOE investigated whether there are any performance relate

that would justify separate energy conservation standards 

• Microwave-only vs. Combination• Configuration:

Countertop Built-In Over
13 | Building Technologies Program 

Market Assessment

Product Classes: Microwave-Only Over-the-Rang

Countertop

 DOE conducted a survey of over-the-range microwave-only 

available on the U.S. market.

• Display technologies used are similar to those used in countertop m

only units (i.e., LED displays, LCDs, and VFDs).

• In-store standby mode testing on a limited sample of over-the-rang

only units showed similar standby power consumption as countertoonly units.

 DOE tentatively concludes that over-the-range microwave-o

would not warrant a separate product class from microwavcountertop units.

• May have additional components that are energized during active m

operation.

• However, DOE’s testing showed that the presence of such features 

increase the standby power consumption.
14 | Building Technologies Program 

Market Assessment

Product Classes: Countertop Combination v

Microwave-Only

 DOE also conducted standby power testing on a sample of 

representative combination microwave ovens. 

 Countertop Combination Microwave Ovens:

• Use similar display technologies as countertop microwave-o• Standby power consumption ranging from 1.2 W to 4.7 W, s

standby power consumption for countertop microwave-only 

 DOE tentatively concludes that countertop combination mi

ovens would not warrant a product class separate from miconly ovens.
15 | Building Technologies Program 

Market Assessment

Product Classes: Built-In and Over-the-Rang

Combination 

 DOE testing showed standby power consumption for these 

ranged from 4.1 W to 8.8 W, higher than the standby power consumption for other microwave oven product types.

 DOE’s reverse-engineering analysis suggests that addition

for these products are required to handle the thermal loads associated with their installation and to provide consumer 

 Require a significant number of additional relays on the co

and thus require a larger power supply for the control of su
16 | Building Technologies Program 

Market Assessment

Product Classes

 DOE believes that a separate product class should be estab

built-in and over-the-range combination microwave ovens.

Product Class1. Microwave-Only Ovens and Countertop Combination Microwave Ove2. Built-in and Over-the-Range Combination Microwave Ovens

Issue 7: DOE requests information on any utility or performa

impacts to built-ins at the standard level proposed b
17 | Building Technologies Program 

Technology Assessment

SNOPR Updates: Operating Modes

 The DOE test procedure, as amended in the interim final 

provides definitions for standby mode and off mode in movens :

• “Standby mode means any mode in which a ... microwav

connected to a mains power source and offers one or mofollowing user-oriented or protective functions which may indefinite time:

– To facilitate the activation of other modes (including activatio

deactivation of active mode) by remote switch (including rem

internal sensor, or timer;

– Continuous functions, including information or status display

clocks) or sensor-based functions. A timer is a continuous c(which may or may not be associated with a display) that allregularly scheduled tasks and that operates on a continuous 

• “Off mode means a mode in which a ... microwave oven 

to a mains power source and is not providing any active mstandby mode function and where the mode may persist findefinite time. An indicator that only shows the user that in the off position is included within the classification of an 
18 | Building Technologies Program 

Technology Assessment

Operating Modes

 In the NOPR, DOE noted that it observed no microwave ov

test sample that were capable of operation in off mode, anthat its research suggested that no microwave ovens avaUnited States are capable of off mode operation.

 DOE received no comments or data indicating that microw

with an off mode are currently available or expected to beavailable on the U.S. market.

 DOE investigated the potential for microwave ovens with 

switch 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 mod

there would be no benefit associate with such a standard

Issue 1: DOE requests input and data regarding off mode po

microwave ovens.
19 | Building Technologies Program 

Technology Assessment

SNOPR Updates: Technology Options

 In the NOPR, DOE identified features which affect standb

• Cooking sensors;• Display technologies; and• Control strategies and associated control boards, includin

turn off power to components during standby mode.

 Additional testing showed that standby power characteri

countertop combination microwave ovens and over-the-rmicrowave-only units are similar to that of countertop miunits.

 Tests on over-the-range combination microwave ovens s

standby power for these products also depend largely on listed above.
20 | Building Technologies Program 

Technology Assessment

Technology Options: Cooking Sensors

 DOE noted in the NOPR that zero-standby power piezoele

sensors were available in microwave ovens in the U.S. mthat other sensors (infrared, weight, relative humidity seneither been applied in microwave ovens sold elsewhere oidentified 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 

internationally for years.

• It is not aware of data showing that these sensors would 

and accuracy significantly different than the absolute humcommonly employed in U.S. microwave ovens.

• It is not aware of any intellectual or patent infringement is

of the above-listed sensors.
21 | Building Technologies Program 

Technology Assessment

Technology 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 technolo

• Reliability in higher-heat installations, such as over-the-range;• Viewing angle and visibility;• Availability of sizes and colors demanded by consumers of higher-end 

which allow manufacturers to provide a consistent appearance among 

suite.

 Additional DOE research indicates:

• Each display technology is currently incorporated in multiple over-the-• Temperature ratings for the three types of displays are comparable.• Each display technology offers acceptable brightness, viewing angle, 

display complex characters in both countertop and over-the-range mi

• No microwave oven display had intermittent backlighting or other feat

utility.

 DOE continues to believe that all display technologies can be integra

countertop and over-the-range microwave ovens with no loss of utili
22 | Building Technologies Program 

Issue 2: DOE requests input and data on the utility provided 

features that contribute to microwave oven standby particular, DOE seeks information on the utility of dtechnologies, as well as on cooking sensors that do require standby power.

Issue for Public Comment
23 | Building Technologies Program 

Technology Assessment

Technology Options: Power Supply and Control B

 DOE determined for the NOPR that switching power supp

improve standby power by increasing power supply and efficiency.

• Up to 75-percent conversion efficiency with 0.2 W or less standb• DOE believed such power supplies were unproven in long-term m

applications.

 Additional DOE research indicates:

• Switching power supplies are found in many consumer products 

suggesting adequate reliability and durability.

• No data suggests that reliability is significantly worse than conve

power supplies over the lifetime of a microwave oven.

• While switching power supplies in other consumer applications m

percent efficiency, DOE is unaware of any switching power suppapplication in microwave ovens that exceed 75-percent efficiency

 DOE observed switching power supplies in certain comb

microwave ovens in its recent test sample.
24 | Building Technologies Program 

Technology Assessment

Technology Options: Automatic Power-Dow

 Automatic power-down allows manufacturers to make de

between incorporating standby power-consuming featuredisplays or cooking sensors) and including a function to those components during standby mode.

 Commenters requested DOE consider a user-activated co

off the display.

• With the display switched off, the microwave oven would 

unless other features associated with standby mode rema

• DOE is not aware of any products incorporating such a us

control.

• DOE also does not have information on how often consum

make use of this feature.

• Although DOE is unable to consider user-activated contro

off the display as a design feature, manufacturers are not the proposed standards from incorporating it in their prod
25 | Building Technologies Program 

Issue 3: DOE requests input and data on control strategies a

enable manufacturers to make design tradeoffs betwincorporating standby-power-consuming features sdisplays or cooking sensors and including a functiopower off to these components during standby modalso seeks comment on the viability and cost of micoven control board circuitry that could accommodatransistors to switch off cooking sensors and displa

Issue 4: Whether switching or similar modern power supplie

operate successfully inside a microwave oven and tassociated efficiency impacts on standby power.

Issues for Public Comment
26 | Building Technologies Program 

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups to DetermineProductPrice

Life-CycleCost andPayback Period Analyses

Market & Technology Assessment

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

NOPR

Analysis

Trial 

Standard 

Levels

Regulator

Impact 

Analysis

SNOPR Analyses Flow Diagram
27 | Building Technologies Program 

Engineering Analysis

Standby Power Levels – Product Class 1

 For the NOPR, DOE established the following standby powe

for analysis: 

 DOE believes that the TSLs and associated analyses are st

product class 1.

Standby PowerLevel (TSL) Source

Stan

Powe

Baseline Baseline 4.

1 FEMP Procurement Efficiency Recommendation 2.2 Gap Fill 1.3 IEA 1-Watt Program 1.4 Max Tech 0.0
28 | Building Technologies Program 

Engineering Analysis

Standby Power Levels – Product Class 2

 For the SNOPR, DOE reverse-engineered a representative s

built-in and over-the-range combination microwave ovens.

• Analyzed the various components that contribute to the stan

consumption. 

• Measured standby power consumption of individual compon

Standby PowerLevel (TSL) Description

Stan

Powe

Baseline Baseline 4.

1 Zero-standby cooking sensor 3.2 Switch mode power supply 2.3 Solid state relays and optimized switch mode power supply 2.4 Max Tech – automatic power down 0.0
29 | Building Technologies Program 

Engineering Analysis

Incremental Manufacturing Costs – Product Cla

 DOE believes the standby power levels and corresponding 

incremental manufacturing costs presented in the NOPR refundamentally valid for product class 1.

 Scaled incremental costs to 2010$ using the Producer Price 

Standby Power Level Standby Power (W) Incremental Cost (2010$

Baseline 4.0 N/A

1 2.0 $0.272 1.5 $0.603 1.0 $1.314 0.02 $4.58
30 | Building Technologies Program 

Engineering Analysis

Incremental Manufacturing Costs – Product Cla

 To evaluate the built-in and over-the-range combination mic

oven product class, DOE conducted analyses on a test samcombination microwave ovens.

• Product teardowns• Control board cost analyses

 DOE estimated the cost associated with each standby powe

using quotes from various component suppliers to determiof the components used in each design option.

Standby Power Level Standby Power (W) Incremental Cost (2010$

Baseline 4.5 N/A

1 3.7 $0.002 2.7 $2.293 2.2 $9.444 0.04 $5.18
31 | Building Technologies Program 

Issue 5: DOE requests input and data on the estimated incre

manufacturing costs, as well as the assumed approachieve TSL 3 for microwave oven standby mode anmode. DOE also seeks comment on whether any intproperty or patent infringement issues are associatdesign options considered in the analyses.

Issue for Public Comment
32 | Building Technologies Program 

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups to DetermineProductPrice

Life-CycleCost andPayback Period Analyses

Market & Technology Assessment

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

NOPR

Analysis

Trial 

Standard 

Levels

Regulator

Impact 

Analysis

SNOPR Analyses Flow Diagram
33 | Building Technologies Program 

Life-Cycle Cost and Payback Period Analysis

LCC and PBP Analysis Inputs Update

Inputs October 2008 NOPR Changes fo

Affecting Installed Costs

Product Cost Derived by multiplying manufacturer cost by manufacturer, distributor 

markups and sales tax.

Used experience curvscaling index to forec

Affecting Operating Costs

Annual Energy Use Annual energy use determined from the annual usage (average daily 

use cycles).

No change

Energy Prices Electricity: Updated using EIA’s 2006 Form 861 data.

Variability: Regional energy prices determined for 13 regions.

Electricity: Updated u861 data.Variability: No change

Energy Price Trends

Energy: Forecasts updated with EIA’s Annual Energy Outlook 2008 

(AEO 2008).

Reference Case, High Growth forecasts upd2010 May Release.

Repair and Maintenance Costs

Assumed no repair or maintenance costs. No change

Affecting Present Value of Annual Operating Cost Savings

Product Lifetime Estimated using survey results from RECS (1990, 1993, 1997, 2001, 

2005) and the U.S. Census AHS (2005, 2007), along with historic data on appliance shipments.

No change

Discount Rates Variability: Characterized using Weibull probability distributions. No change

Affecting Installed and Operating Costs

Effective Date of New Standard

2012 2014
34 | Building Technologies Program 

Base and Standards Case Efficiency Distributio

Life-Cycle Cost and Payback Period Analysis

 LCC and PBP analysis typically analyzes standard leve

to a baseline efficiency level

 Not all consumers purchase products at baseline levels

• Must account for consumers purchasing more efficient product

accurately estimate consumer economic impacts

 Base-Case efficiency distributions define the percentage o

being purchased at various efficiency levels

• Consumers already purchasing products at efficiencies greater 

equal to a prospective standard level are not impacted by the s

 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, b

ENERGY STAR levels using the 3-year payback period criterio
35 | Building Technologies Program 

Life-Cycle Cost and Payback Period Analysis

Base and Standards Case Efficiency Distributio

 DOE maintained the shipments-weighted standby power and an

energy use shown in the following tables throughout the forecast period, 2014–2043. 

Microwave and Countertop Combination Ovens: Standby Energy Consumption D

2014 for Base and Standards Cases

Stand-by 

Power (W)

Annual Energy Use 

(kWh/yr)

Market Share (%)

Base Case

Standby Power Le

123

4.00 34.8 46%2.00 17.4 35% 81%1.50 13.0 19% 19% 100%1.00 8.69 0% 0% 0% 1000.02 0.17 0% 0% 0% 0% 

Shipments Weighted Standby Power 2.83 1.90 1.50 1.0

Shipments Weighted Annual Energy Use 24.6 16.5 13.0 8.7 
36 | Building Technologies Program 

Life-Cycle Cost and Payback Period Analysis

Base and Standards Case Efficiency Distributio

 DOE maintained the shipments-weighted standby power and ann

energy use shown in the following tables throughout the forecast period, 2014–2043. 

Over the Range Combination Ovens: Standby Energy Consumption Distribution

Base and Standards Cases

Stand-by 

Power (W)

Annual Energy Use 

(kWh/yr)

Market Share (%)

Base Case

Standby Power 

1 2 

4.50 39.1 100%3.70 32.1 0% 100%2.70 23.5 0% 0% 100%2.20 19.1 0% 0% 0% 0.04 0.35 0% 0% 0% 

Shipments Weighted Standby Power 4.50 3.70 2.70 

Shipments Weighted Annual Energy Use 39.1 32.1 23.5 
37 | Building Technologies Program 

Issue 6: DOE requests input and data on the estimated mark

microwave ovens at the standby power consumptiostipulated by the proposed standards (1.0 W for cou2.2 W for combination)

Issue for Public Comment
38 | Building Technologies Program 

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups to DetermineProductPrice

Life-CycleCost andPayback Period Analyses

Market & Technology Assessment

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

NOPR

Analysis

Trial 

Standard 

Levels

Regulator

Impact 

Analysis

SNOPR Analyses Flow Diagram
39 | Building Technologies Program 

Shipments Analysis

Inputs 2008 NOPR Description Changes for the SNONumber of Product Classes One product class. Market share data provided by 

AHAM.

Two product classes: (1) all microwave ovcountertop microwave oven-combination; microwave oven-combination. Market shaAHAM; 99% product class #1 and 1% proclass market shares held constant over fo

New Construction Shipments

Housing forecasts updated with EIA AEO 2009 April 

release forecasts for the Reference case, High growth case, and Low growth case. 

No change in approach. Housing forecastAEO 2010 forecasts for the Reference caand Low growth case. 

Replacements Determined by tracking total product stock by vintage 

and establishing the failure of the stock using retirement functions from the LCC and PBP analysis. Retirement functions revised to be based on Weibulllifetime distributions.

No change. 

 Shipments Analysis Inputs 1 through 3
40 | Building Technologies Program 

Shipments Analysis

Inputs 2008 NOPR Description 

Retired Units not Replaced (i.e., non-replacements)

Used to calibrate shipments model to historical shipments data. N

Historical Shipments Data sources include AHAM data submittal and Appliance magazine. N

Purchase Price, Operating Cost, and Household Income Impacts due to Efficiency Standards

Developed “relative price” elasticity, which accounts for the purchase price and the present value of operating cost savings divided by household income. Used purchase price and efficiency data specific to residential refrigerators, clothes washers, and dishwashers between 1980 and 2002 to determine a “relative price” elasticity of demand of -0.34. 

N

Fuel Switching Not applicable. N

 Shipments Analysis Inputs 4 through 7
41 | Building Technologies Program 

Inputs 2008 NOPR Description Changes for the 

Base-Case Forecasted Efficiencies

Shipment-weighted efficiency (SWEF) determined in 2005. SWEF held constant over forecast period. 

No change. 

Standards-Case Forecasted Efficiencies

Analyzed as one product class. Roll-up scenario used for determining SWEF in the year that standards become effective for each standards case. SWEF held constant over forecast period. 

Analyzed as two product classused for determining SWEF in become effective for each stanconstant over forecast period.

Annual Energy Consumption per Unit

Annual 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 fo

Energy Cost per Unit Annual weighted-average values as a function of the annual 

energy consumption per unit and energy (and water) prices. 

No change.

Impact Analyses

 NIA inputs 1 through 5 and corresponding outputs for utilit

environmental, employment, and regulatory impact analyse
42 | Building Technologies Program 

Inputs 2008 NOPR Description Changes for the 

Repair Cost and Maintenance Cost per Unit

Incorporated changes in repair costs as a function of standby power.

No change.

Escalation of Energy Prices AEO 2008 forecasts (to 2030); extrapolated to 2042. Updated to AEO 2010 May rele

extrapolated to 2043.

Energy Site-to-Source Conversion

Conversion varies yearly and is generated by DOE/EIA’s NEMS program (a time-series conversion factor; includes electric 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 

Impact Analyses

 NIA inputs 6 through 10 and corresponding outputs for util

environmental, employment, and regulatory impact analyse
43 | Building Technologies Program 

Trial Standard Levels

Trial Standard 

Level

Standby Power (W)

Product Class 1: MicrowaveOnly and Countertop 

Combination

Product Class 2: B

Over-the-Range Co

1 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 lev
44 | Building Technologies Program 

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups to DetermineProductPrice

Life-CycleCost andPayback Period Analyses

Market & Technology Assessment

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

NOPR

Analysis

Trial 

Standard 

Levels

Regulator

Impact 

Analysis

SNOPR Analyses Flow Diagram
45 | Building Technologies Program 

Manufacturer Impact Analysis

SNOPR Updates

 DOE updated the MIA results based on several changes to 

analyses that impact the MIA:

• Engineering Analysis - Updated manufacturing production c

(MPCs) for Product Class 1, new MPCs for Product Class 2costs converted to 2010$. 

• NIA - Updated total shipments and efficiency distributions, u

analysis period (2014-2043) and base year (2011), and incoprice trends into the analysis;

 DOE also updated the conversion costs

• To segment total product and capital conversion costs betwe

Class 1 and Product Class 2, DOE used the same split betwtwo product classes as used in the NIA

• DOE used the same per-platform costs at each standby pow

both product classes, but converted these product and capitconversion costs to 2010$ using the PPI.
46 | Building Technologies Program 

Manufacturer Impact Analysis

Summary of Results at the Proposed Standards 

 At TSL 3, the impacts on INPV range from approximately -$

to -$73.6 million (a change in INPV of -4.7 percent to -6.5 pe

• Base case industry value is estimated to be $1.1 billion in $2• The required conversion costs are estimated to be $94.7 mi

3. As an indication of the magnitude of these conversion coscash flow decreases by approximately 29.9 percent, to $59.compared to the base-case value of $84.2 in the year before compliance date of the standard. 

• The incremental MPCs at TSL 3 are estimated to be $1.31 f

Class 1 and $9.44 for Product Class 2. The range of the impINPV and cash flow at TSL 3 varies depending on the ability manufacturers to pass on these increases in MPCs to their 

 The vast majority of microwave ovens are imported and the 

employment impacts in the GRIM are small.
47 | Building Technologies Program 

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Markups to DetermineProductPrice

Life-CycleCost andPayback Period Analyses

Market & Technology Assessment

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

NOPR

Analysis

Trial 

Standard 

Levels

Regulator

Impact 

Analysis

SNOPR Analyses Flow Diagram
48 | Building Technologies Program 

Proposed Standards

 DOE considered four TSLs for standby power, beginn

the most efficient level (TSL 4) and worked down to a where the benefits of potential standards outweighed burdens.

• DOE tentatively concludes that at TSL 4, the benefits of ene

savings, economic gain, and emissions reductions would boutweighed by the potential economic burden on consumerof product utility and the large capital conversion costs that in a reduction in INPV for manufacturers.

• DOE tentatively concludes that TSL 3 saves a significant am

energy and is technologically feasible and economically jus

Selection of Proposed Standard
49 | Building Technologies Program 

Proposed Standards

Microwave-Only 

and Countertop 

Combination 

Ovens

Built-In 

the-

Com

O

Proposed standard level 3 

National Energy Savings (quads) 0.41 0

Net Present Value 

(2010$ billion)

3% discount rate 3.58 07% discount rate 1.81 0

Industry Net 

Present Value

2010$ million 1031.6 to 1050.6 22.3 

% change (6.5) to (4.8) (7.1) 
50 | Building Technologies Program 

Closing

How to Submit Comments...

 Public Meeting – oral comments will be captured in the transcript 

part of the public record.

 Written comments – Reference docket #: EERE-2011-BT-STD-00

RIN #: 1904-AC07

Email: MWO-2011-BT-STD-0048@ee.doe.gov Mail: Mrs. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program1000 Independence Avenue, SW, Mailstop EE-2JWashington, DC 20585-0121

Courier: Mrs. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program950 L'Enfant Plaza, 6th FloorWashington, DC 20024

Telephone: (202) 586-2945
51 | Building Technologies Program 

APPENDIX
52 | Building Technologies Program 

Introduction

Statutory Authority – the Energy Policy and 

Conservation Act (EPCA) as Amended

 EPCA (42 U.S.C. 6291 et seq.) set forth criteria and procedures for D

adoption and amendment of energy conservation standards and tesfor covered products.

 Energy Independence and Security Act of 2007 (EISA 2007) Amendm

• Any final rule establishing or revising a standard for a covered produ

after July 1, 2010, shall incorporate standby and off mode energy usstandard if feasible. If not feasible, DOE shall prescribe a separate sstandby and off mode energy use, if justified.

 New microwave oven standby power standards are being considere

rulemaking that also initially covered residential dishwashers, dehuconventional cooking products and commercial clothes washers.

• Amended dishwasher and dehumidifier standards were established b• Standards for conventional cooking products and microwave ovens a

efficiency were addressed in a final rule in April 2009.

• Amended commercial clothes washer standards were adopted by fin

January 2010.
53 | Building Technologies Program 

The Energy Policy and Conservation Act (EPCA) directs D

consider seven factors when setting energy conservation sta

Factor Analysis

1. Economic impact on consumers and 

manufacturers

Life-cycle cost analysisManufacturer impacts analys

2. Lifetime operating cost savings Life-cycle cost analysis3. Total projected energy savings National impact analysis4. Impact on utility or performance Screening analysis

Engineering analysis

5. Impact of any lessening of competition Manufacturer impacts analys6. Need for national energy conservation National impact analysis7. Other factors the Secretary considers 

relevant

Environmental assessmentUtility impact analysisEmployment impact analysis

Introduction
54 | Building Technologies Program 

Introduction

Test Procedure Background

 DOE’s test procedure for microwave ovens appears at appe

part 430 subpart B of Title 10 of the Code of Federal Regula

 DOE repealed the regulatory provisions establishing the co

efficiency test procedure for microwave ovens under EPCA 

rule published on July 22, 2010.

• DOE determined that the microwave oven test procedure pr

measure cooking efficiency do not produce accurate and retest results.

• Was unaware of any test procedures that have been develo

address the concerns with the DOE microwave oven cookintest procedure.

 EISA 2007 Amendments to EPCA direct DOE to incorporate 

of standby and off mode energy consumption into its microtest procedure by March 31, 2011.
55 | Building Technologies Program 

Engineering Analysis

Efficiency Metric

 DOE eliminated the active mode cooking efficiency test pro

provisions in a July 2010 Test Procedure Final Rule.

• Existing provisions did not produce accurate and repeatable • Absence of active mode provisions result in a de facto sepa

use descriptor for microwave oven standby mode and off muse.

 Proposed standards are based on a maximum average stan

power, in Watts (W).
56 | Building Technologies Program 

Engineering Analysis

Incremental Manufacturing Costs

 From product testing and reverse engineering, DOE observ

correlations between:

• Specific components and technologies, or combinations the• Measured standby power

 DOE obtained preliminary incremental manufacturing costs 

associated with standby power levels by considering combthose components as well as other technology options idenreduce standby power.

 DOE presented manufacturing cost estimates based on quo

obtained from:

• suppliers, • interviews with manufacturers and subject matter experts, • research and literature review, and • numerical modeling.
57 | Building Technologies Program 

Baseline and Incremental Markups

■ Markups relate customer price to cost of goods sold (CGS■ Baseline markups relate price to cost prior to a change in 

• Baseline markups indicate a customer price that covers all of a re

expenses plus profit.

• Direct labor costs (salaries, payroll, rental and occupancy) are inc

■ Incremental markups relate the incremental change in cus

price to the incremental change in CGS beyond baseline

• Some distribution costs remain constant with CGS increases.• Incremental markups cover only expenses that vary with CGS – in 

expenses that increase due to an increase in equipment efficiency

• For example, direct labor costs (salaries, payroll, rental and occupancy

with efficiency-induced changes in CGS.

• DOE assumes other operating costs and profit will scale proportio

CGS.

Markups to Determine Equipment Price
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Estimates of Retail Market Competition

■ DOE assumed that competition in the retail market, combined 

inelastic demand, will put downward pressure on retail marginsupporting the incremental markup approach.

■ To confirm that retail markets are competitive, DOE used a co

used index of market concentration, the Four Firm Concentrat(FFCR).*

■ An FFCR < 40% indicates a relatively unconcentrated market, 

FFCR > 70% indicates a concentrated market (oligopoly).

■ FFCRs were evaluated for major appliance sales in three reta

Electronics and Appliance Stores, Building and Material and SDealers, and General Merchandise Stores. In each case, the rFFCR was well below the 40% threshold.

* The Department of Justice uses a more complete index, the Herfindahl-Hirschman Index (HHI), b

the information necessary for calculating an HHI.

Markups to Determine Equipment Price
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Life-Cycle Cost and Payback Period Analysis

LCC and PBP Analysis Inputs
60 | Building Technologies Program 

■ Background

• DOE must publish an initial regulatory flexibility analysis if it c

that the rule will not have a significant economic impact on a snumber of small entities.

■ Findings

• DOE identified no small business manufacturer of microwave 

which there would be a significant economic impact

Regulatory Flexibility Act
61 | Building Technologies Program 

Summary of Results

TSL 1 TSL 2 

National Energy Savings (quads) 0.21 0.30 NPV of Consumer Benefits (2010$ billion)

7% discount rate 1.02 1.42 3% discount rate 1.98 2.78 

Maximum Industry NPV Change (2010$ billion) (27.1) to

(29.3)

(45.2) to 

(52.4)

Maximum Industry NPV Change (%) (2.4) to 

(2.6)

(4.0) to 

(4.6)

Mean LCC Savings (2010$)

Microwave-Only Ovens and Countertop Combination Microwave Ovens 7 10 

Built-In and Over-the-Range Combination

Microwave Ovens

6 11 

Present Value of CO2 Emissions Savings (2010$ billion) 70 to 

1,066

101 to 

1,539