Energy Conservation Standard

Residential Refrigerators and Fr

Preliminary Analysis Public Me

Building Technologies Program 

Office of Energy Efficiency and Renewable E

U.S. Department of Energy

December 10, 2009

EERE-2008-BT-STD-0012 COMMENT 26
 To present methodologies and characterize result

date

 To discuss specific issues related to each analysi To seek input from attendees on methodologies, a

data sources

 To describe upcoming analyses and next steps

Purpose of the Public Meetin

EERE-2008-BT-STD-0012 COMMENT 26
Issues for Comment

Issue Box: DOE welcomes comments, data, and infor

concerning its preliminary analysis on resrefrigeration products. Throughout this prissues that correspond to issues raised in published material from this preliminary anraised for discussion in boxes like this onecomments are welcome on any part of DO

EERE-2008-BT-STD-0012 COMMENT 26
234

Background and Legal Authority

Public Meeting Agenda

5

2 Market & Tech; Screening; Engineering3 Energy Use; Markup Analysis

41 Statute and Context5

Life-Cycle Cost and Payback Period A

National Impact Analysis

6 Preliminary MIA; NOPR Analyses

EERE-2008-BT-STD-0012 COMMENT 26
Previous Rulemakings

 Final Rule published November 17, 1989 set per

standards effective January 1, 1993. (54 FR at 4

 Rule correction affecting three product classes p

24, 1990. (55 FR at 42845)

 Second round final rule published April 28, 1997 

effective July 1, 2001. (62 FR at 23102)

 Analyses published in October 2005 to support p

additional refrigerator rulemaking.

 Energy Independence and Security Act 2007 (EI

publication of updated standards by December 3effect January 1, 2014.

EERE-2008-BT-STD-0012 COMMENT 26
Stakeholder Participation in the Rulema

Federal Register 

notices

Framework 

Document

Preliminary 

Analysis NOPR 

• Public meetings and oral comments• Written comments on Federal Register notices, 

Support Documents and Analytical Spreadshee

• Data input from manufacturers and other interes

Stakeholder 

participation

Today

EERE-2008-BT-STD-0012 COMMENT 26
Preliminary Analysis Rulemaking 

Framework 

Document ANOPR NOPR Fina

Rule NOPR Fina

Market & Technology

ScreeningAnalysis

Engineering Analysis

Energy Use & End Use Load Characterization

Shipments Analysis

Markups for Equipment Price Determination

Life-Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis

Preliminary 

Analysis

EERE-2008-BT-STD-0012 COMMENT 26
Key Documents Describing the Prelimina

 Executive Summary includes:

• An overview of the preliminary activities and preliminary tech

(TSD);

• Key results of the analyses; and• Issues on which DOE seeks comment from interested partie

 Chapter 2 of the preliminary TSD discusses the analy

includes:

• A review of the analyses conducted and plans for analyses 

stages; and

• A discussion of comments on the analytical Framework from 

DOE’s responses to those comments.

 Notice of Public Meeting (NOPM) and availability of th

includes:

• Details of the public meeting for the Refrigeration Products p

analyses; and

• A description of the preliminary analyses, results, and docum

website for interested parties to review.

EERE-2008-BT-STD-0012 COMMENT 26
Framework 

Document ANOPR NOPR Fina

Rule

Analyses for Notice of Proposed Rulem

NOPR Preliminary Analyses Final Rule

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

EERE-2008-BT-STD-0012 COMMENT 26
Framework 

Document ANOPR NOPR Fina

Rule NOPR Preliminary Analyses

Analyses for Final Rule

Final Review

Revise

NOPR

Analyses

Fina

Rule

EERE-2008-BT-STD-0012 COMMENT 26
The Energy Policy and Conservation Act (EPCA) dir

seven factors when setting energy conservat

Factor Ana

1. Economic impact on consumers 

and manufacturers

Life-cycle cost analyManufacturer impact 

2. Lifetime operating cost savings Life-cycle cost analy3. Total projected energy savings National impact analy4. Impact on utility or performance Screening analysis

Engineering analysis

5. Impact of any lessening of 

competition

Manufacturer impact 

6. Need for national energy 

conservation

National impact analy

7. Other factors the Secretary 

considers relevant

Environmental assesUtility impact analysiEmployment impact 

EERE-2008-BT-STD-0012 COMMENT 26
Comments from Participants

 Participants are invited to provide summary com

statements

 Participants are invited to raise additional issues 

today

 Preliminary analysis comment period open throu

2010

EERE-2008-BT-STD-0012 COMMENT 26
234

Background and Legal Authority

Public Meeting Agenda

5

2 Market & Tech; Screening; Engineering3 Energy Use; Markup Analysis

41 Statute and Context5

Life-Cycle Cost and Payback Period A

National Impact Analysis

6 Preliminary MIA; NOPR Analyses

EERE-2008-BT-STD-0012 COMMENT 26
Framework

Document

Preliminary

Activities NOPR Final Rule Effe

D

Preliminary Activities Flow Diag

ScreeningAnalysis

Engineering Analysis

Energy Use Characterization

Shipments Analysis

Markups to Determine Product Price

Life-Cycle Cost and Payback Period Analyses

Market & Technology Assessment

Preliminary Manufacturer Impact Analysis

EERE-2008-BT-STD-0012 COMMENT 26
 Market & Technology Assessment:

• To characterize the residential refrigerator, refrigerator-f

market to determine available product efficiencies, manu

by product class, and technologies available for increasi

Purpose

Market and 

EERE-2008-BT-STD-0012 COMMENT 26
Market Characteristics

Market and 

 Refrigerators and Refrigerator-Freezers:

• Standard-sized refrigerator-freezers:

• Roughly 90% of market held by 3 major domestic m• Shipments peaked at 11 million units in 2005 and 2• Shipments dropped to just over 9 million units in 20

• Compact† refrigerators:

• Roughly 1⁄4 of market held by 1 international manufa• Roughly 1⁄4 of market held by 5 domestic manufactu• Remainder split among smaller suppliers• Shipments were close to 2 million units in 2006 and 

 Freezers:

• Chest and upright freezers:

• 85% of market held by 2 North American manufactu• 13% of market held by one manufacturer outside N• Shipments were around 2 million units in 2007*

• Compact† freezers:

• 500,000 compact freezers were shipped in 2007*

*Appliance Magazine Data†Compact products have less than 7.75 ft3 refrigerated volume and are less than 36 inc

EERE-2008-BT-STD-0012 COMMENT 26
Market and 

Test Procedures

 Concurrent test procedure rulemaking:

• DOE expects to propose many test procedure amendme• Two-step timing of applicability of test procedure (TP) am

• Some amendments to be applicable shortly after TP • Some amendments to be applicable coincident with 

conservation standards (ECS).

• The ECS preliminary analyses have been conducted bas

expectations regarding the amendments to be promulgat

 Key test procedure changes affecting preliminary analyse

• Temperature changes planned for IEC 62552:

• Refrigerator-freezers: 5  ̊F / 45  ̊F compartment tem

change to 0  ̊F / 39  ̊F

• Refrigerators: 15  ̊F / 45  ̊F compartment temperatu

change to 15  ̊F / 39  ̊F

• All-Refrigerators: 38  ̊F compartment temperature c• Volume adjustment factors change for all products

• Variable Anti-Sweat Heater Control• Modified volume calculation method• Reinforcement of icemaker requirements, but no icemak

EERE-2008-BT-STD-0012 COMMENT 26
Market and 

The analyses currently do not incorporate ice

 There is no measurement of icemaking energy in th

procedure.

 None of the comments made during the Framework 

called for measurement of icemaking energy. 

 AHAM began working on a test procedure for meas

icemaking energy in summer 2009.

 DOE will be considering these factors in the develo

rules for the energy conservation standard and test 

EERE-2008-BT-STD-0012 COMMENT 26
Market and 

Request for Comment: 

Icemaking Energy Use

Issue 20: Test Procedure Revision to Incorporate Icem

Use:DOE requests comments on icemaking ene

1) What is the expected schedule for finalizing 

repeatable test procedure?

2) What type of energy use metric involving ic

use should be established?

3) What is a fair way of establishing maximum 

energy use as a function of product class avolume?

4) What technology options exist to reduce ice

use?

EERE-2008-BT-STD-0012 COMMENT 26
Market and 

Product Classes: Framework Phase Pro

Comments

 New classes proposed at the framework workshop: 

• 19: Refrigerator-freezers—automatic defrost with bottom

with TTD ice service

• 20: Chest freezers with automatic defrost• DOE proposes redesignating these product classes 5A a

consistency with Canadian Standards, as suggested in s

 Convertible-bottom-drawer refrigerator-freezers:

• No proposed new product class at this time.

 Wine coolers:

• These products are not refrigerators and DOE currently h

regulate them.

 Built-in products

• Comments were received supporting separate product c

products.

• DOE has conducted preliminary assessment of this issue 

determined approach for this rulemaking.

EERE-2008-BT-STD-0012 COMMENT 26
Market and 

Product Classes: Current Develop

• Separation of product classes due to expected revised te

• Energy use of refrigerators and refrigerator-freezers shou

energy use of all-refrigerators should decrease.

• Some product classes include both refrigerators and all-r

some include both refrigerator-freezers and all-refrigerato

• The all-refrigerators, which have 0.5 ft3 of freezer volume 

have separate product classes in order to have meaning

• Clarification of automatic defrost for all-refrigerators:

• Manual Defrost: “ . . . defrosting . . . is accomplished by 

means with manual initiation and manual termination of t

operation” (AHAM HRF-1-1979)

• Off-cycle defrost could not be considered manual and he

• Combination of product classes due to low shipment volu

similarity:

• Product classes 1 and 2.• Product classes 11 and 12.

EERE-2008-BT-STD-0012 COMMENT 26
Product Class Definition

1A All-refrigerators with manual defrost*3A All-refrigerators with automatic defrost5A Refrigerator-freezers—automatic defro

mounted freezer with TTD ice service

10A Chest freezers with automatic defrost11A Compact all-refrigerators with manual 13A Compact all-refrigerators with automa

Market and 

Proposed Product Classes

* Are there any products in this class?

 DOE has modified changes to product class definitions 

in the Framework:

• Rename product classes 19 and 20 as new product class• Establish separate product classes 1A, 3A, 11A, and 13A 

Freezers

EERE-2008-BT-STD-0012 COMMENT 26
Market and 

Request for Comment: 

Product Class Definitions

Issue 1: Use of the Proposed Designations for Produ

and 10A:DOE proposes to re-designate product clasnamed 19 and 20 as 5A and 10A to maintain with Canadian Standards.

Issue 2: Establishment of Separate Product Classes 

RefrigeratorsDOE proposes to establish product classes 13A for all-refrigerators to allow separate stthese products.

Issue 3: Possible Combination of Product Classes 1 

Product Classes 11 and 12DOE is considering combination of these paclasses.

EERE-2008-BT-STD-0012 COMMENT 26
Market and 

Request for Comment: 

Product Class Definitions

Issue 15: Clarification of the Distinction Between Man

Automatic Defrost for All-Refrigerators:DOE requests comment on the interpretatiodefrost is a form of automatic defrost for all

EERE-2008-BT-STD-0012 COMMENT 26
Technology Assessment

 DOE identified technologies for each product cov

rulemaking from the following sources:

• Technical support documents from previous rulemaking• Literature review;• Product teardowns; and• Input from interested parties.

 The full list of technologies that DOE identified ca

Chapter 3, Market and Technology Assessment , technical support document.

EERE-2008-BT-STD-0012 COMMENT 26
Screening Analysis

 PURPOSE: To apply screening criteria establis

determine which technologies to evaluate and w

out.

 Technologies were screened using the following 

• Technological feasibility;• Practicability to manufacture, install and service;• Adverse impacts on product utility or product availability; a• Adverse impacts on health or safety. Chapter 4 of the preliminary TSD includes detail

screening process.

EERE-2008-BT-STD-0012 COMMENT 26
Technologies Screened In

Design Option PC3 PC5 PC7 PC

Increased Insulation Thickness

9

1 i

Vacuum-Insulated Panels

9

9

9

9

Improved Compressor Efficiency

9

9

9

9

Variable-Speed Compressor

9

9

9

9

Increased Evaporator Surface Area

9

9

9

9

Increased Condenser Surface Area

9

9

9

Forced Convection Condenser 

9

Brushless DC Evaporator Fan

9

9

9

9

Brushless DC Condenser Fan

9

9

9

9

Adaptive Defrost

9

9

9

9

Variable Anti-Sweat Heater Control

9

EERE-2008-BT-STD-0012 COMMENT 26
Screening Analysis: Framework Phase 

 Framework comments suggested that DOE should 

alternative foam-blowing agents and refrigerants i

 Pending climate change legislation could reduce a

HFC’s.

 Alternative foam-blowing agents• Industry standard HFC-245fa has best thermal perform

substances 

• CFC compounds already phased out due to ozone dep

• Alternative foam-blowing agents could increase energy 

not considered as technology options

 Alternative refrigerants

• Current industry standard is HFC-134a• R-600a (isobutane) could be used, but is flammable• Current UL standards limit hydrocarbon quantities to un

use of R-600a was not considered as a technology opti

 Further details are in the Engineering Analysis an

Impact Analysis sections.

EERE-2008-BT-STD-0012 COMMENT 26
Preliminary Activities Flow Diag

Framework

Document

Preliminary

Activities NOPR Final Rule Effe

D

Screenin

g

Analysis

Engineering Analysis

Energy Use Characterization

Shipments Analysis

Markups to Determine Product Price

Life-Cycle Cost and Payback Period Analyses

Market & Technology Assessment

Preliminary Manufacturer Impact Analysis

EERE-2008-BT-STD-0012 COMMENT 26
Downstre

• Life-Cycle 

Payback 

• National • Manufact

Analysis

Cost – Efficiency 

Relationship

Incremental 

Manufacturing Cost

Efficiency

 Characterize the relationship between manufactur

energy efficiency.

Purpose of the Engineering Ana

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis: Methodo

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis: Representative 

 DOE conducted detailed analysis on product classes represe

overall shipments of covered products.*

 Within each “representative” product class, DOE selected thr

detailed analysis:

• Two units of nearly identical design except for ENERGY STAR rating fo• A third unit of a different size.

*Based on AHAM-aggregated data for market share by product class for refrigeratorsand freezers. 

Analyzed Product Classes

EERE-2008-BT-STD-0012 COMMENT 26
Product Category Product Class 

Standard-Size Refrigerators and RefrigeratorFreezers

Product Class 3: Refrigerator-freezer—autom

with top-mounted freezer without TTD ice se

Product Class 5: Refrigerator-freezers—autom

defrost with bottom-mounted freezer without service

Product Class 7: Refrigerator-freezers—autom

defrost with side-mounted freezer with TTD 

Standard-Size Freezers Product Class 9: Upright freezers with automa

Product Class 10: Chest freezers and all othe

except compact freezers

Compact-Size Refrigerators and RefrigeratorFreezers

Product Class 11: Compact refrigerators and 

freezers with manual defrost 

Compact-Size Freezers Product Class 18: Compact chest freezers 

Representative Products: DOE selected three units a

capacities for each representative product class.

EERE-2008-BT-STD-0012 COMMENT 26
Request for Comment: 

Representative Products

Issue 6: Variation of Product Characteristics as Com

Representative Products :DOE conducted detailed analysis on produtypical for the representative product classapproach did not provide much information variation in product design and the resultincosts to achieve different efficiency levels. comment on the variation of refrigeration pand the distribution of incremental costs to use reductions.

EERE-2008-BT-STD-0012 COMMENT 26
 Definition of the baseline efficiency levels is comp

expected modification of the test procedure.

• Both measured energy use and adjusted volume will ch

 Baseline efficiency levels are defined by the curre

conservation standards, using the current test pro

 DOE developed baseline efficiency curves for the 

energy test procedure.

• AHAM provided data showing the changes in energy u

volume for certain product classes under the current an

• DOE modeled energy under both procedures for comp• New equations were derived describing baseline produ

on the new test procedures.

Engineering Analysis: Baseline Effici

EERE-2008-BT-STD-0012 COMMENT 26
 Current equation:  Energy use relationship: Adjusted Volume relationship: New equation: New equation constants:

New Energy Use / Adjusted Volume Re

BECNEWTP = ESA

AVNEWTP = 

VCA

BECCURTP = × 

A

A

A 

VCAF ESAF B VCAF AV BEC AESAF 

NEWTP NEWTP ⎟ 

×⎠⎞ ⎜⎝⎛ ⎟ ×=⎠⎞ ⎜⎝⎛ +××=

BA BESAF

VCAF

ESAF ANEW ⎟ × NEW ×= ⎠⎞ ⎜⎝⎛ = ;

EERE-2008-BT-STD-0012 COMMENT 26
 Example: Product Class 7

• AHAM aggregated data under new test procedur

• Average change to Adjusted Volume = 1.6%• Average change to Energy Use = 14.0%• ESAF = 1.14 and VCAF = 1.016• Current standard:• A = 10.1 and B = 406;

• ANEW = 10.1 × 1.14 ÷ 1.016 = 11.33 and BNEW = 4• New Baseline Energy Consumption:

New Energy Use / Adjusted Volume Re

BECCURTP = AV 

1.10

BECNEWTP = 33.11 AVNEWTP + 

EERE-2008-BT-STD-0012 COMMENT 26
Request for Comment: 

Baseline Energy Use / Adjusted Volume 

Issue 4: Approach for Development of Baseline Ene

Volume Relationships under the Proposed DOE has developed energy use — adjusted relationships for baseline products tested uexpected new test procedure for use as the energy conservation standards to be propophase of this rulemaking. DOE seeks commapproach used and the resulting baseline eequations.

 Details of these calculations and the resulting expected 

use equations for all product classes can be found in Cpreliminary TSD.

EERE-2008-BT-STD-0012 COMMENT 26
Slope of Energy Use / Adjusted Volume 

 There are questions about the developed baseline 

equations for some product classes, particularly P

 The existing energy conservation standard curves 

product classes have noticeably lower slope than 

Adjusted Volume (ft3)

EERE-2008-BT-STD-0012 COMMENT 26
DOE analysis supports suspicion that slop

the energy use curves may be l

• DOE conducted energy analysis for the products analyz

varying size (see Chapter 5 of the TSD for details of the 

• The analysis shows that the slopes of the curves for a n

classes may require adjustment.

Product 

Class

Calculated Energy Curve 

Slope from ERA

Slope from Pro

Energy Us

3 13.3 10

5 12.3 5

7 11.9 1

9 9.4 12

10 7.7 9

11 16.4 12

11A 20 to 35 10

18 4.5 10

EERE-2008-BT-STD-0012 COMMENT 26
Request for Comment: 

Baseline Energy Use / Adjusted Volume 

Issue 5: Modification of the Baseline Energy Use/Ad

Curve Slope:DOE invites comment on whether an adjustslopes of the baseline energy use relationsthe proposed test procedures is warranted product classes, and by how much. DOE reinformation supporting comments that indisuch slope changes.

EERE-2008-BT-STD-0012 COMMENT 26
 Incremental efficiency levels are defined by p

energy use less than baseline.

 In this discussion, efficiency levels based on 

test procedure are the same as efficiency lev

the new test procedure.

Incremental Efficiency Level

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis: Max-Available a

 Max-available efficiency levels identified based on ENERGY S

databases range from 1% below baseline for PC13 to 51% be

 Max-tech levels were determined using energy modeling usin

technically applicable for each product class.

 DOE conducted engineering analysis for efficiency levels up t

efficiency levels were not expected to be cost-effective.

*This does not include a 53% PC3 all-refrigerator.

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis: Methodo

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis: Energy Model D

 DOE upgraded the EPA Refrigerator Analysis (ERA

use in the engineering analysis

• Updated algorithms for heat exchanger modeling based 

research.

• Upgrade to Windows platform.• Internal iteration of heat exchanger performance and re• Many modifications to improve accuracy and flexibility.

 DOE used an interim DOS version 

of the program for much of the rulemaking preliminary analysis.

 The Windows version, 

incorporating all of the improvements, is available on the rulemaking website as part of the rulemaking analytical tools.

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis: Energy Modeli

 DOE acquired energy model input data from the fo

• Reverse engineering (including physical teardown)• Laboratory energy tests• Manufacturer interviews• Component vendor interviews

 DOE used energy modeling to determine the effic

achievable with selected groups of design options

CurrentProduct Energy Models

New Test Procedure Baseline Energy Model

Energy Savings with Single Design Options

Calibration 

based on Energy Guide and Test Data

New 

Temperatures, some design changes

Determine the 

most costeffective design options

EERE-2008-BT-STD-0012 COMMENT 26
 Product Class 5 design with French Doors

• Reduction of existing product efficiency to properly repr

performance (most PC5 products are ENERGY STAR r

• Adjustment of 18.5 ft3 model to add French Doors not p

teardown unit

• Adjustment of the 25 ft3 Product Class 5A model to rem

convert double-drawer freezer compartment to single-d

 Product Class 7 design

• Adjustment of the 22 ft3 Product Class 4 model to add T

 Further details are in section 5.7.4 of the Engineer

Chapter of the preliminary TSD.

Energy model design changes were mad

baseline models with the desired design c

EERE-2008-BT-STD-0012 COMMENT 26
 Airside thermal resistance for spine fin evaporato Thermal resistance of composite vacuum panel / f ERA output adjustment as needed to address situ

ERA was not configured for the required calculatiresistance change for only selected cabinet walls

 Summary Calculations 

 Cost-efficiency curves based on groups of de Cost-efficiency curves based on efficiency lev

Supplemental Spreadsheet Calcul

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis: Methodo

EERE-2008-BT-STD-0012 COMMENT 26
Cost Model Methodology

Raw 

Materials

Finished Materials

Purchased Parts

Physical 

Teardown

Bill of 

Materials

Assembly 

Processes

Manufacturing 

Cost

Fabrication 

Processes

 BOM develope

teardowns

 Fabricated par

• Raw mater

sources, msupplier inte

• Fabrication 

manufacturvisits, and i

 Purchased pa

• Estimate pr

interviews a

 Manufacturer 

• Total cost o

and direct o

 Cost model assumptions and details are explained in section 5.6 

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis: Methodo

EERE-2008-BT-STD-0012 COMMENT 26
 DOE calculated incremental costs for the design opt Use of more efficient components:

• Manufacturing cost difference is the component price diffe

original component, unless additional costs are noted.

 Overhead and depreciation was added for some des

• The manufacturing model was used to develop representa

OH/depreciation costs to direct material/labor costs for diff

 Depreciation costs for insulation thickness increase

• Insulation thickness increases would, under a conservative 

substantial or complete product redesign, which may requiplant.

• The applicable depreciation costs for different product grou

the manufacturing cost model.

 G & A and profit:

• Unless otherwise noted, DOE cost-efficiency curves includ

for G&A and profit, which converts manufacturing productiomanufacturer selling price (MSP).

• DOE established a manufacturer markup equal to 26%.

Incremental Cost Estimate

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis: Methodo

EERE-2008-BT-STD-0012 COMMENT 26
Cost-Efficiency Curve: Development Me

 Baseline energy use based on proposed en Design options added from the baseline to 

pathway for improving energy efficiency;

 Cost model developed from product teardo

and vendor interviews; incremental costs cdesign option or groups of design options

 Cost-efficiency curves generated based on 

and costs of design option groups;

 Cost-efficiency curves converted to be bas

through determination of the design option achieve each efficiency level. 

• Interpolation or full inclusion of incremental des

appropriate at each efficiency level

• DOE developed curves based on efficiency leve• Costs of the two products analyzed for each pro

each efficiency level.

Develop 

Baseline

Calculate Costs

Develop Design 

Option Pathway

Generate CostDesign Option 

Curves

Convert to CostEfficiency 

Curves

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis Incremental Cos

Top-Mount Refrigerator-Freezer (Produ

(16 ft3)

ff

f

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis Incremental Cos

Bottom-Mount Refrigerator-Freezer (Prod

ft

3

ft

3

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis Incremental Cos

Side-Mount Refrigerator-Freezer (Produ

ft

3

ft

3

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis Incremental Cos

Upright Freezer (Product Class 

ft

3

ft

3

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis Incremental Cos

Chest Freezer (Product Class 1

ft

3

ft

3

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis Incremental Cos

Compact Refrigerator-Freezer (Produc

ft

3

ft

3

EERE-2008-BT-STD-0012 COMMENT 26
Engineering Analysis Incremental Cos

Compact Chest Freezer (Product Cl

ft

3

ft

3

EERE-2008-BT-STD-0012 COMMENT 26
Cost-Efficiency Curves: DOE Curves vs. 

 AHAM provided aggregated incremental cost data fo

3, 5, 7, 9, and 11.

 DOE removed the manufacturer markup from its cur

comparison to AHAM data.

 The AHAM curves include material, labor, overhead, 

one-time expenses (i.e. R&D, marketing, etc.).

 In general, there is reasonable agreement between t

curves, with a few caveats.

 Additional details can be found in section 5.9.2 of th

EERE-2008-BT-STD-0012 COMMENT 26
Cost-Efficiency Curves: DOE Curves vs. 

Product Class 3

 The aggregated average costs for a portion of the AHAM response

“MIN/MAX” curve) is consistent with DOE results 

EERE-2008-BT-STD-0012 COMMENT 26
Cost-Efficiency Curves: DOE Curves vs. 

Product Class 5

EERE-2008-BT-STD-0012 COMMENT 26
Cost-Efficiency Curves: DOE Curves vs. 

Product Class 7

 The leveling off of the AHAM curves in the 30%-35% range, especia

expected to be an anomaly of the reporting and aggregation proce

EERE-2008-BT-STD-0012 COMMENT 26
Cost-Efficiency Curves: DOE Curves vs. 

Product Class 9

 The DOE costs are lower than the AHAM data, especially at the 20% 

diminishes at the higher efficiency levels.

EERE-2008-BT-STD-0012 COMMENT 26
Cost-Efficiency Curves: DOE Curves vs. 

Product Class 11

 These curves exhibit large discrepancy. DOE teardowns suggest t

20% (ENERGY STAR) level should be significantly lower than $75. 

EERE-2008-BT-STD-0012 COMMENT 26
Cost-Efficiency Curves: Vacuum Insulation 

 DOE notes that efficiency levels significantly beyond 

STAR levels are possible, but:

• This is dependent on the use of VIPs, resulting in sig

cost.

 The LCC analysis shows that some portion of the co

by the additional efficiency improvement for most p

 Thus, new standard levels could require much more 

VIPs.

 VIPs were not screened out, because this technolog

available products—the technology also was not sc1997 rulemaking.

 However, some consideration of the viability of VIPs 

mass production levels may be appropriate.

EERE-2008-BT-STD-0012 COMMENT 26
Request for Comment: 

Cost-Efficiency Curves: Cost of 

Issue 14: Maturity of Vacuum Insulation Panels for Hi

Production:DOE invites comments on this issue and alsinformation that would allow a more rigorouassessment to be conducted.

EERE-2008-BT-STD-0012 COMMENT 26
 DOE conducted in-depth analysis on seven produ

representing more than 90% of product shipments

 DOE proposes to extend the rulemaking to the oth

classes after establishing standard levels for the a

• Example: use the same required percent energy use re

was used for PC3.

 The methodology for establishing the low-volume 

stnadard levels is described in section 2.15 of the 

Low-Volume Products

EERE-2008-BT-STD-0012 COMMENT 26
Request for Comment: 

Low-Volume Products

Issue 7: Development of Energy Standards for Low

Products:DOE seeks comment on its suggested appdeveloping energy standards for low-volu

EERE-2008-BT-STD-0012 COMMENT 26
Preliminary Results Regarding Differences in 

 DOE received comment during the framework per

separate product classes for built-ins due to increand costs associated with meeting higher efficien

 Based on input from manufacturers, DOE conclud

are more likely to use higher-cost components to STAR status, as compared with conventional prod

 Hence, DOE developed preliminary cost-efficiency 

Built-In products to more carefully examine this is

Conventional Built-InDesign Change Cost Impact Design Change Increase Compressor EER from 5.5 to 6.25

$10.50 Replace Compressor w

Variable-Speed

Add Brushless DC Condenser Fan Motor

$3.75 Add Brushless DC Con

and Evaporator Fan Mo

TOTAL $14.25 Difference 

EERE-2008-BT-STD-0012 COMMENT 26
Preliminary Results: Bottom-Mount Refrigerato

vs. Conventional (Product Class 

EERE-2008-BT-STD-0012 COMMENT 26
Preliminary Results: Bottom-Mount Refrigerato

vs. Conventional (Product Class 

EERE-2008-BT-STD-0012 COMMENT 26
Request for Comment: 

Product Class Definitions: Built-in Refriger

Issue 16: Analysis of Built-In Products:

DOE seeks additional technical and cost infbuilt-in products that would aid in assessmthe costs to achieve higher efficiency levels higher with these products.

 Pre-NOPR analysis focus has been on convention

the high-volume product classes. 

• DOE has not conducted complete assessment of 

differences associated with Built-Ins.

 DOE has not yet made determination regarding es

separate product classes for these products and sinformation. 

EERE-2008-BT-STD-0012 COMMENT 26
 As previously mentioned, pending climate change 

ban the use of HFCs as foam-blowing agents.

 Current state-of-the-art for minimizing energy use 

HFC-245fa.

 Likely alternatives (e.g. cyclopentane) would likely 

insulation resistivity.

 DOE conducted preliminary analyses to assess th

to efficiency levels.

 Analyses were conducted assuming a 10% low

which probably overstates the difference.

 Results were compared to current products b

HFC-245fa foam.

Supplemental Analyses: 

Cyclopentane Foam-Blowing Ag

EERE-2008-BT-STD-0012 COMMENT 26
Comparison of 18.5 ft3 Product Class 5 refrigerator-freezer w

and product with insulation having 10% lower resistivity

Supplemental Analyses: Cyclopentane Foam

Incremental Cost

With HFC-245fa Blowing Agent

With Insulation having 10% lower resistivity

Note: Analysis assumes no insulation cost differ

EERE-2008-BT-STD-0012 COMMENT 26
Request for Comment: 

Alternative Foam-Blowing Age

Issue 17: Technical Data for Alternative Foam-Blowin

DOE seeks up to date technical data on the differences and the impact to thermal perfoalternative refrigerants.

Issue 18: Likely Scenarios for Alternative Foam-Blow

DOE seeks comment on the likely scenarios manufacturers, assuming that laws such as pending legislation banning HFC’s are passDOE seeks information regarding the timing alternative agents.

 DOE expects cyclopentane to have a resistivity clo

245fa than the value used in this analysis.

 Federal legislation currently pending would phase 

EERE-2008-BT-STD-0012 COMMENT 26
Other Issues

DOE invites comments and recommendations fr

parties on any other aspects relating to the Market 

Assessment, the Screening Analysis, and the Engin

EERE-2008-BT-STD-0012 COMMENT 26
234

Background and Legal Authority

Public Meeting Agenda

5

2 Market & Tech; Screening; Engineering3 Energy Use; Markup Analysis

41 Statute and Context5

Life-Cycle Cost and Payback Period A

National Impact Analysis

6 Preliminary MIA; NOPR Analyses

EERE-2008-BT-STD-0012 COMMENT 26
Framework 

Document

Preliminary

Analysis

NOPR Fina

Rule

Market & Technology

ScreeningAnalysis

Engineering Analysis

Energy Use & End Use Load Characterization

Shipments Analysis

Markups for Equipment Price Determination

Life-Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis

Preliminary Activities Flow Diag

EERE-2008-BT-STD-0012 COMMENT 26
 Purpose

• Determine customer prices under a standards scena

manufacturer costs.

• Characterize product distribution channels and mark• Describe refrigerator and freezer retailer direct costs

profits.

 Inputs

• Firm balance sheets

– SEC 10-K reports for 4 large appliance manufacturers 

• Average sales tax rates for each Census division an• Retailers: U.S. Census Bureau Business Expenses 

“Household Appliance Stores”

 Output

• Baseline and incremental markups.

Markups to Determine Equipmen

Purpose, Inputs, and Outpu

Markups to De

EERE-2008-BT-STD-0012 COMMENT 26
Refrigerator and Freezer Distribution 

 Data from AHAM indicate that an overwhelming m

refrigerators and freezers are sold through retail oaware of any other significant distribution channethat all customers purchase appliances from thes

Markups to De

Manufacturer Retailer C

EERE-2008-BT-STD-0012 COMMENT 26
Baseline and Incremental Mark

 Markups relate customer price to cost of goods so

 Baseline markups relate price to cost prior to a ch

• Baseline markups indicate a customer price that covers a

expenses plus profit.

• Direct labor costs (salaries, payroll, rental and occupancy

 Incremental markups relate the incremental chang

to the incremental change in CGS beyond baseline

• Some distribution costs remain constant with CGS increa• Incremental markups cover only expenses that vary with 

expenses that increase due to an increase in equipment 

– For example, direct labor costs (salaries, payroll, rental and o

efficiency-induced changes in CGS.

• DOE assumes other operating costs and profit will scale 

Markups to De

EERE-2008-BT-STD-0012 COMMENT 26
Markups to D

Resulting Markup Multipliers

Refrigerators and Freeze

Markup Baseline I

Manufacturer 1.26Retailer 1.45 Distributor - Sales Tax 1.069Overall 1.95 

EERE-2008-BT-STD-0012 COMMENT 26
 Purpose:

• Develop annual energy use data for the life-cycle cost and payback 

annual operating costs.

 Method: Standard-Sized Products

• Develop household samples from DOE-EIA’s 2005 Residential Ene

(RECS) for the five standard-sized product classes analyzed in detaAnalysis.

– Standard-Sized Refrigerators and Refrigerator-Freezers

 #3: Refrigerator-freezer—auto defrost, top-mounted free

 #5: Refrigerator-freezers—auto defrost, bottom-mounted  #7: Refrigerator-freezers—auto defrost, side-mounted fre

– Standard-sized Freezers

 #9: Upright freezers, auto defrost #10: Chest freezers and all other freezers except compa

• Use RECS data along with Engineering Analysis data to develop an

per-household basis.

 Method: Compact Products

• Use Engineering Analysis data to develop annual energy use for th

classes analyzed in detail in the Engineering Analysis

– Compact-sized refrigerators and refrigerator-freezers

 #11: Compact refrigerators and refrigerator-freezers, ma

– Compact-sized freezers

 #18: Compact chest freezers

Energy Use Determination

EERE-2008-BT-STD-0012 COMMENT 26
UsageAdjustmentFactor

Standard-Sized Products: Energy Use Determina

Unit Agefrom RECS

+

Unit Volumefrom RECS

FECRECS =Field Energy Consumption(kWh/year)from RECS

NEWTEST

RECS

TEC

FEC UAF =

TECSTD =Test EnergyConsumption(kWh/year)

 ESAF is the Energy Standard Adjustment Factor, a multiplicative factor that ac

test procedure’s temperatures on energy consumption

 FECNEW is determined for each household within each household sample and 

 The result is a distribution of FECNEW for each standard level for a given house

 Approach is carried out on a per-household basis for all households within a 

TECNEWTEST = TECSTD x ESAF 

Test Energy

Consumption at

New Standard

(kWh/year)

ESAF from Engineering

Analysis

EERE-2008-BT-STD-0012 COMMENT 26
Standard-Sized Products: Usage Adjustme

 For households with two refrigerators, DOE split the RECS en

two, with the same UAF

• UAF adjusted down by a factor of 0.7 for second refrigerators assu

basement.

 DOE also adjusted the UAF to account for ENERGY STAR re

STAR was assigned based on a model using household incomthe refrigerator.

 DOE used engineering data to define maximum and minimum 

each household, and used these to remove outliers.

 The average UAF for each product class is greater than 1, ind

field energy use exceeds test procedure energy use.

 Factors not accounted for by the test procedure:

• Ice making• Degradation over time

EERE-2008-BT-STD-0012 COMMENT 26
Average, Minimum and Maximum Usage Adju

Product Class Mean UAF Min. UAF Max. UAF 

Top-mount refrigeratorfreezer 1.23 0.13 3.08 

Bottom-mount refrigerator- freezer 1.08 0.13 2.89 

Side-by-side refrigerator-freezer 1.44 0.20 2.41 

Upright freezer 1.37 0.32 1.97 

Chest freezer 1.48 0.34 2.56 

EERE-2008-BT-STD-0012 COMMENT 26
Example: Product Class 3 Usage Adjustment Fac

Frequency Chart

.000.007.013.020.027

0.181 0.804 1.427 2.050 

10,000 Trials 

Forecast: UAF (1)

EERE-2008-BT-STD-0012 COMMENT 26
Example: Product Class 7 Usage Adjustment Fac

Frequency Chart

.000.005.011.016.021

0.233 0.778 1.323 1.869 

10,000 Trials 

Forecast: UAF (1)

EERE-2008-BT-STD-0012 COMMENT 26
Average Annual Energy Use for Standard-Sized Refr

Product Class Proposed Test 

(kWh/year)

Field (kWh

Top-mount refrigeratorfreezer 534 

Bottom-mount refrigerator- freezer 652 

Side-by-side refrigerator-freezer 756 

Upright freezer 717 

Chest freezer 428 

EERE-2008-BT-STD-0012 COMMENT 26
Issues for Public Comment

Issue 8: Field Energy Use of Standard-Size Refrigera

DOE welcomes comments, data, and informrelationship between field and test energy ccontemporary standard-sized refrigeration p

EERE-2008-BT-STD-0012 COMMENT 26
Energy use results for compact refrigeration 

 RECS and other surveys do not provide energy use data for co

and freezers.

 DOE assumed that the field energy use of these products is eq

energy consumption (equivalent to a UAF = 1).

 DOE used the California Energy Commission database to build 

product sizes.

Product Class Proposed Test 

(kWh/year)

Fie(kW

Compact refrigerators and refrigerator-freezers with manual defrost

325 

Compact chest freezers 313 

EERE-2008-BT-STD-0012 COMMENT 26
Issues for Public Comment

Issue 9: Field Energy Use of Compact Refrigeration 

DOE welcomes comments, data, and informrelationship between field and test energy ccompact refrigeration products.

EERE-2008-BT-STD-0012 COMMENT 26
234

Background and Legal Authority

Public Meeting Agenda

5

2 Market & Tech; Screening; Engineering3 Energy Use; Markup Analysis

41 Statute and Context5

Life-Cycle Cost And Payback Period A

National Impact Analysis

6 Preliminary MIA; NOPR Analyses

EERE-2008-BT-STD-0012 COMMENT 26
Framework 

Document

Preliminary

Analysis

NOPR Fina

Rule

Energy Use Characterization

Market and TechnologyAssessment

ScreeningAnalysis

Engineering Analysis

Markups toDetermine Equipment Price Life-Cycle 

Cost and Payback Period Analysis

Shipments Analysis

Preliminary Manufacturer Impact Analysis

Preliminary Activities Flow Diag

EERE-2008-BT-STD-0012 COMMENT 26
 Purpose

• To develop the customer life-cycle cost (LCC) savings a

(PBP) for higher efficiency equipment compared to the 

Purpose of the Life-Cycle Cost and Payback 

Life-Cycle Cost an

EERE-2008-BT-STD-0012 COMMENT 26
 Method

• LCC equals consumer price plus the sum of operating cos

particular base year

• Economic evaluation from the consumer perspective• Analysis implemented in an Excel® spreadsheet combined • Analysis models the uncertainty and variability of inputs us

simulation and probability distributions

– For the residential products, household samples created from 

Consumption Survey to characterize the variability in energy 

• Results are expressed as LCC savings (baseline minus ca• Simple Payback Period (PBP, years) is also calculated an

First Cost

(Consumer Price +

Installation Cost)

Operating 

Expenses

Comb

in 

LCC 

Convert to Present Value

Life-Cycle Cost and 

EERE-2008-BT-STD-0012 COMMENT 26
Life-Cycle Cost an

LCC and PBP Analysis Inputs

EERE-2008-BT-STD-0012 COMMENT 26
Total Installed Costs

Life-Cycle Cost and 

 Total Installed Costs = Retail Price + Installation C Equipment Retail Price = Manufacturing Costs x M

• Manufacturing cost vs. efficiency relationships developed 

Analysis

• Markups and Sales Taxes developed in the Markups to D

Price analysis

 Installation costs represent the labor and material

install the appliance

• DOE did not consider or calculate installation costs for re• Installation costs do not vary with efficiency

EERE-2008-BT-STD-0012 COMMENT 26
Baseline Equipment Price

 DOE used market sales data collected by The NPD Grou

distributions of baseline prices for each product class.

 NPD data allowed DOE to determine the price distributio

STAR appliances meeting the criteria for each product c

Life-Cycle Cost and 

0%2%4%6%8%

10%12%14%16%

$150

$350

$550

$750

$950

$1,150

$1,350

$1,550

$1,750

$1,950

$2,150

$2,350

$2,550

$2,750

$2,950

$3,150

$3,350

$3,550

$3,750

$3,950

$4,150

$4,350

$4,550

Selling Price

Percent of Sales

Example: Baseline retail price for side-by-side refrigewith through-the-door ice service (PC 7)

EERE-2008-BT-STD-0012 COMMENT 26
Life-Cycle Cost and 

Examples: Average Customer First C

$500$550$600$650$700$750$800

1.00 0.90 0.80 0.70 0.60 0.50

Efficiency (Current Standard = 1.0)

Average Customer Cost

Upright Freezers (Product Class 9) Side-by-side Refri

1.00 0.90 0.80 

Efficiency (Cu

EERE-2008-BT-STD-0012 COMMENT 26
 Electricity Prices

• Based on EIA Form 861 Data• Developed for 13 Regions: 9 Census Divisions an

Electricity Prices

Life-Cycle Cost an

Geographic Area

Average Residential Price 

2008$/kWh

Average Comm

2008$/k

New England 0.162 

Middle Atlantic 0.127 

East North Central 0.102 

West North Central 0.088 

South Atlantic 0.099 

East South Central 0.087 

West South Central 0.093 

Mountain 0.097 

Pacific 0.099 

New York State 0.178 

California 0.150 

Texas 0.128 

Florida 0.117 

EERE-2008-BT-STD-0012 COMMENT 26
Electricity Price Forecasts

 Energy price projections to 2030 based on EIA/AEO American Reco

Case

 AEO High Growth and Low Growth (AEO2009) cases can be run as a 

 Electricity price forecasts to 2070: Based on average rate of change 

Life-Cycle Cost an

Electricity Price Trends

0.80.91.01.11.2

2000 2005 2010 2015 2020 2025 

AEO 2009 Reference Res ElecAEO 2009 Reference Com Elec

EERE-2008-BT-STD-0012 COMMENT 26
Standard-Sized Product Lifetime

 DOE used appliance data collected by RECS and the Ameri

(AHS), combined with the shipments history, to estimate refr

lifetime.

 RECS asks respondents to provide the age of their first and 

as well as freezers, allowing DOE to determine the fraction owithin a particular period which are still in use.

 DOE combined the 1990, 1993, 1997, 2001, and 2005 REC

single survival function, in the form of a Weibull distribution.

Life-Cycle Cost an

16.2

17.4

0.00.20.40.60.81.01.21.4

0 5 10 15 20 25 30 35 40 45 5

Age (years)

Fraction Surviving

EERE-2008-BT-STD-0012 COMMENT 26
Standard-Sized Product Survival and Retireme

Refrigerators:

0%

10%20%30%40%50%60%70%80%90%

100%

0 5 10 15 

0%

10%20%30%40%50%60%70%80%90%

100%

0 5 10 15 20 25 30 35 40 45 50

Age

% Surviving% Retiring

Freezers:

Life-Cycle Cost an

Mean Lifetime: 17.4 years Median Lifetime: 16.2 years

Mean LifetimMedian Lifet

EERE-2008-BT-STD-0012 COMMENT 26
Conversion to Second Refrigerator

 Refrigerator shipments are driven in part by a customer choi

refrigerator while retaining their existing appliance as a seco

 DOE used RECS to develop of conversion function for prima

function represents the fraction of operating refrigerators of a second refrigerators.

0.00.20.40.60.81.0

0 10 20 30 40 

Age (years)

Fraction converted to 2nd refrigerator Conversion function

Life-Cycle Cost an

EERE-2008-BT-STD-0012 COMMENT 26
Compact Product Lifetime

 RECS and the Commercial Buildings Energy Survey (CBEC

enough information to develop a lifetime for compact refrigethe methodology developed for standard-sized appliances.

 DOE used the reported stock of compact refrigerators from 

combined with the shipments history from Appliance magaz

lifetime estimate.

 A lifetime of 10 years, as estimated by Appliance magazine, 

stock estimate that far exceeds the reported data from REC

 A Weibull distribution with a mean lifetime of 5.62 years, co

shipments history, fits the current reported stock of compact 

 DOE estimated that the lifetime of a compact freezer has the 

lifetime of a compact refrigerator as a standard-size freezer refrigerator. This results in a compact freezer lifetime distrib7.46 years.

Life-Cycle Cost an

EERE-2008-BT-STD-0012 COMMENT 26
Issues for Public Comment

Issue 11: Lifetime of Compact Refrigeration Products

DOE calibrated the average lifetime of compmatch the existing stock of compact refrigethe RECS and CBECS surveys. The resultinlifetime is 5.62 years. It used a simple ratio estimate the lifetime of compact freezers. Dcomment on its approach for estimating the compact refrigerators and freezers.

Life-Cycle Cost an

EERE-2008-BT-STD-0012 COMMENT 26
 Discount Rates

• Based on the finance cost of raising funds to purchase applian

– Financial cost of any debt incurred to purchase equipment– Opportunity cost of any equity used to purchase equipment

• Residential Rates

– Weighted-average real rate associated with various household 

stocks, CDs) and debt (e.g., credit card, home equity loans) = 4

– Primary data source: Federal Reserve Board’s Survey of Cons

1989, 1992, 1995, 1998, 2001, 2004, and 2007 

• Commercial Rates

– Calculated from the weighted-average cost of capital to the firm 

debt financing

– Weighted-average real value = 6.2% CHECK for purchasers o

commercial applications

 Repair and Maintenance Costs

• Assumed no changes with increased efficiency for all products

Other Inputs

Life-Cycle Cost an

EERE-2008-BT-STD-0012 COMMENT 26
Issue for Public Comment

Life-Cycle Cost an

Issue 10: Repair and Maintenance Costs:

Because DOE did not find any evidence thamaintenance costs change as refrigeration increases, it did not include these costs in invites comment on this approach and requinformation showing the extent to which remaintenance costs change as refrigeration increases beyond the baseline levels used 

EERE-2008-BT-STD-0012 COMMENT 26
Efficiency Distributions in the Base 

 To accurately estimate the percentage of consumers 

affected by a particular energy conservation standard into account the distribution of product efficiencies cumarketplace. 

• Consumers already purchasing products at efficiencies 

to a prospective standard level are not impacted by the 

 DOE conducted its LCC and PBP analyses by consid

breadth of product efficiencies that consumers purcha

case (i.e., the case without new energy efficiency stan

for those consumers who already purchase more effic

 DOE developed base case efficiency distributions for 

analyzed product classes based on data provided by 

Life-Cycle Cost an

EERE-2008-BT-STD-0012 COMMENT 26
Equipment Assignment in the Base Cas

Top-Mount (PC 3) Bottom-Mount (PC 

Level Energy Factor Market Share Market Share 

Baseline 1.00 81% 12% 

1 0.90 6% 0% 2 0.85 0% 0% 3 0.80 13% 88% 

4 0.75 0% 0% 5 0.70 0% 0% 6 0.65 0% 0% 7 0.60 0% 0% 8 0.55 0% 0%

Life-Cycle Cost an

Standard-Sized Refrigerator-Freezers

Standard-Sized Freezers

Upright (PC 9) Ch

Level Energy Factor Market Share M

Baseline 1.00 82% 

1 0.90 17% 2 0.85 1% 3 0.80 0% 4 0.75 0% 5 0.70 0% 6 0.65 0% 7 0.60 0% 8 0.55 0% 

EERE-2008-BT-STD-0012 COMMENT 26
Equipment Assignment in the Base Cas

Compact Refrigerators (PC 11) Comp

Level Energy Factor Market Share 

Baseline 1.00 97% 

1 0.90 0% 

2 0.85 0% 

3 0.80 1% 

4 0.75 2% 

5 0.70 0% 

6 0.65 0% 

7 0.60 0% 

8 0.55 0% 

Life-Cycle Cost an

Compact Refrigeration Products

EERE-2008-BT-STD-0012 COMMENT 26
Life Cycle Cost Results 

Example: Standard-Sized Side-by-Side Refriger

with Through-the-door Ice Service (Product 

Life-Cycle Cost and 

-300-200-100

0

100200300400500600700800

12345

Efficie

Life-cycle Cost Savings($)

Mean Median

EERE-2008-BT-STD-0012 COMMENT 26
LCC and PBP Results 

Example: Standard-Sized Side-by-Side Refriger

with Through-the-door Ice Service (Product 

05

10152025

12345

Effici

Payback Period(yr)

Mean Median

Life-Cycle Cost and 

EERE-2008-BT-STD-0012 COMMENT 26
LCC Effect of Field vs. Test Energy Cons

Upright Freezers: Mean UAF = 1.37 Side-by-side Refri

$1,250$1,500$1,750$2,000$2,250

1.00 0.90 0.80 0.70 0.60 0.50

Efficiency (Current Standard = 1.0)

Average Customer Cost

With UAFNormalized UAF

1.00 0.90 0.80 

Efficiency (Cur

Life-Cycle Cost and 

EERE-2008-BT-STD-0012 COMMENT 26
Other Issues

DOE invites comments and recommendations fr

parties on any other aspects related to the Life-Cyc

EERE-2008-BT-STD-0012 COMMENT 26
234

Background and Legal Authority

Public Meeting Agenda

5

2 Market & Tech; Screening; Engineering3 Energy Use; Markup Analysis

41 Statute and Context5

Life-Cycle Cost and Payback Period A

National Impact Analysis

6 Preliminary MIA; NOPR Analyses

EERE-2008-BT-STD-0012 COMMENT 26
Framework 

Document

Preliminary

Analysis

NOPR Fina

Rule

Energy Use Characterization

Market and TechnologyAssessment

ScreeningAnalysis

Engineering Analysis

Markups toDetermine Equipment Price Life-Cycle 

Cost and Payback Period Analysis

Shipments Analysis

Preliminary Manufacturer Impact Analysis

Preliminary Activities Flow Diag

EERE-2008-BT-STD-0012 COMMENT 26
Purpose

 Shipments Analysis

• To estimate refrigerator and freezer shipments over time• To estimate the disaggregation of shipments into produc

this changes over time.

 National Impact Analysis

• To estimate the change in efficiency distributions over tim• To estimate the National Energy Savings (NES) from ref

efficiency standards at different levels.

• To estimate the national economic impact on the nation 

Value (NPV)) from refrigerator and freezer efficiency stalevels.

EERE-2008-BT-STD-0012 COMMENT 26
National Impact Analysis Proc

Shipments Model

National Energy Savings

National EconomicImpacts

LCC Analysis Results and Other Inputs

 National energy savings calculated for period from 2 NPV calculated for products shipped over the period 

EERE-2008-BT-STD-0012 COMMENT 26
Appliance Stock

Appliance

Lifetime

Replacement

Shipments

Combined

Shipments

New Building

Construction

New Building

Appliance

Saturation

New

Construction

Shipments

Existing

Building Stock

w/o Appliance

Rate of Purchase

(Calibration Variable)

Shipments to

Exist Bldg Stock

w/o Appliance

Historical

Shipments

Shipments

Difference

(For Std-Size and Compact Freezers)

Total

Shipments

Second

Appliance Rate

(Calibration Variable)

Shipments of

Additional Units

to Existing Homes

(For Std.-Size Refrigerators)

Adjust Shipments

to New

Construction

(For Compact Refrigerators)

Shares to

Lodging and

Other Comm’l

(Calibration Variable)

S

EERE-2008-BT-STD-0012 COMMENT 26
Product Class Market Shares: Standard-Size Refriger DOE fit RECS and AHAM side-by-side and bottom-freeze

a model based on growing share for these classes amon

 The model approaches a limit of approximately 46.5% sh

bottom-mount classes by the end of the analysis period

20.00%25.00%30.00%35.00%40.00%45.00%50.00%

1985 1995 2005 2015 2025 2035 

Year

Side- and Bottom-freezer Market Share Forecast market sha

AHAM Shipments ShRECS Side-freezer Limiting fraction

EERE-2008-BT-STD-0012 COMMENT 26
Issue for Public Comment

Issue 13: Forecasted Market Shares of Top-Mount vs

Mount Refrigerator-Freezers:This model was based on the historical conof homeowners as a whole, as well as highhomeowners, the historical market share drental and owner-occupied households, anshares of top-, side- and bottom-mount proshipments. DOE seeks comment on its app

EERE-2008-BT-STD-0012 COMMENT 26
Shipments Model Inputs

Input Data Source/De

Replacements

Appliance Lifetime From Life-Cycle Cost AnalysisNew Construction ShipmentsResidential ConsumersForecasted New Housing U.S. DOE-EIA, 2009 Annual Energy Outloo

New Housing Saturations U.S. DOE-EIA, 1990, 1993, 1997, 2001, 20

Consumption Survey

Commercial ConsumersForecasted New Construction U.S. DOE-EIA, 2009 Annual Energy Outloo

Commercial Completions

New Building Saturations U.S. DOE-EIA, 1999, 2003 Commercial Bu

Survey; American Lodging Association, 19

Historical ShipmentsAll Refrigeration Products AHAM Data Submittal, AHAM Fact Book, AShipments by Product ClassAll Refrigeration Products AHAM Data SubmittalStandard-Size Refrigerator-Freezers AHAM Data Submittal; U.S. DOE-EIA 1990

Residential Energy Consumption Survey

EERE-2008-BT-STD-0012 COMMENT 26
Example: Standard-Size Refrigerator-F

Base Case Shipments Forecast

 To calibrate Shipments Model, units are converted from pr

refrigerator at the rate determined in the lifetime analysis

 Shipments forecasted to increase as shipments are tied to 

construction and more homes have multiple units

0.05.0

10.015.020.025.0

1990

1995

2000

2005

2010

2015

2020

2025

2030

2035

Millions

ConversionNew constructionReplacementsModeled ShipmentsHistorical Shipments

EERE-2008-BT-STD-0012 COMMENT 26
Purchase Price and Operating Cost 

 Shipments impacts due to purchase price and oper

are accounted for when forecasting standards case 

 Shipments Model used Relative Price

(RP) elasticit

impacts from purchase price (PP) and the present vcost (PVOC) changes

 Purchase price effects dominate but mitigated by h Based on historical shipments, retail price, efficien

for home appliances, RP elasticity = -0.34

• 10% increase in RP results in a 3.4% drop in shipments• Consumers become less sensitive to initial changes in pu

– Based on economic literature, RP elasticity drops 65% in ten 

Income

PP PVOC RP

+

=

EERE-2008-BT-STD-0012 COMMENT 26
0.05.0

10.015.020.025.0

1990 2000 2010 2020 2030 2040

Millions

BaseCSL6CSL8

0.00.51.01.52.02.53.03.54.04.5

1990 1995 2000 2005 2010 

Millions

0.01.02.03.04.05.06.07.0

199019931996199920022005200820112014201720202023202620292032203520382041

Miliions

CSL6CSL7CSL8Base

0.000.100.200.300.400.500.600.700.800.90

19901993199619992002200520082

Millions

BaseCSL3CSL5CSL8

Standards Case Shipments Results

Standard-Size Refrigerator-Freezers Sta

Compact Refrigerators 

EERE-2008-BT-STD-0012 COMMENT 26
Inputs

 Total Customer Cost

• Average per unit values as a function of efficiency level taken from LC

 Repair and Maintenance Costs

• No increase in repair and maintenance costs with efficiency

 Annual Energy Use

• Average per unit values as a function of efficiency level taken from LC

 Base-Case and Standards-Case Forecasted Efficiencies

• Base-Case efficiencies 2007-2014: Based on base case efficiency dis• Standards-Case efficiencies 2014: Based on “Roll-up” scenario• Forecasted efficiencies: Increase in efficiency from 2014 to 2021 due 

 Energy Prices

• Average prices taken from LCC analysis• Future energy prices adjusted according to trend forecasted by the Am

Reinvestment Act case from the 2009 Annual Energy Outlook

 Electricity Site-to-Source Conversion Factors

• Conversion factors based on marginal heat rates from NEMS corresp

Outlook

• Factors vary annually and account for generation, distribution, and tra

 Discount Rate

• 7% and 3% real from OMB’s Regulatory Analysis Guideline A-4

 Present Year

• Future expenses are discounted to the year 2009

EERE-2008-BT-STD-0012 COMMENT 26
Efficiency Distribution Forecast: Base 

 DOE developed forecasts of the efficiency distributions for each prod

historical efficiency trends driven, in part, by the ENERGY STAR prog

 ENERGY STAR market share grew between 2001 and 2007. ENERG

changed for several product classes in 2008, which DOE forecasts w

before 2014. DOE forecasts that the ENERGY STAR market shares 

ENERGY STAR market shares in 2007.

 In the absence of new standards, DOE forecasts that the ENERGY S

increase the stringency of its criteria in 2014, and that ENERGY STAwould again equal ENERGY STAR market share in 2007 and 2014. Tthen fixed from 2021 to 2043.

 Example: Side-by-side Refrigerator-freezers (Product Class 7)

Energy Use Factor 2007 2014 20

1.0 25.0% 25.0% 25

0.90 43.0% 43.0% 43

0.85 30.3% 0.0% 0.

0.80 1.7% 32.0% 0.

0.75 0.0% 0.0% 32

EERE-2008-BT-STD-0012 COMMENT 26
Efficiency Distribution Forecast: Standard

 In the case with new standards, DOE developed a “roll-u

model.

 At the introduction of new standards in 2014, DOE forec

market share into the new minimum efficiency level. Thashare at or below the level of the new standard is “rolled the standard.

 Over the 7 years from 2014 to 2021, DOE forecasts that t

new ENERGY STAR level (set at 20% less energy use thwill grow linearly to reach the same market share as disforecast for 2014.

 Efficiency distributions are fixed from 2021 to 2043.

EERE-2008-BT-STD-0012 COMMENT 26
Base-Case and Standards-Case Forecasted 

Example: Side-by-Side Refrigerator-Freeze

Level EF

Market Shares

Base-Case

Standards Case

1 2

3

4

5

Baseline 1.00 25% - - - - - 

1 0.90 43% 68% - - - - 

2 0.85 0% 0% 68% - - - 3 0.80 32% 32% 32% 100% - - 

4 0.75 0% 0% 0% 0% 100% - 5 0.70 0% 0% 0% 0% 0% 100% 6 0.65 0% 0% 0% 0% 0% 0% 7 0.60 0% 0% 0% 0% 0% 0% 

SWEF (EF) 0.893 0.868 0.834 0.800 0.750 0.700 

Level

EF

Market Shares

Base-Case

Standards Case

1 2

3

4

5

Baseline 1.00 25% - - - - - 

1 0.90 43% 68% - - - - 

2 0.85 0% 0% 68% - - - 3 0.80 0% 0% 0% 68% - - 

4 0.75 32% 32% 32% 0% 68% - 5 0.70 0% 0% 0% 32% 0% 68% 

6 0.65 0% 0% 0% 0% 32% 0% 

7 0.60 0% 0% 0% 0% 0% 32% 

SWEF (EF) 0.877 0.852 0.818 0.768 0.718 0.668 

2014:

2021 and later:

EERE-2008-BT-STD-0012 COMMENT 26
Issue for Public Comment

Issue 12: Efficiency Distribution Forecasts:

To accurately estimate the share of consumaffected by a standard at a particular efficieLCC and PBP analyses considered the projof product efficiencies that consumers woubase case and standards cases. DOE’s projaccount growth in market share of ENERGY products in the coming years. DOE invites approach used to forecast market shares oefficiency levels.

EERE-2008-BT-STD-0012 COMMENT 26
Example Annual Savings and Cost R

Standard-Sized Top-Mount Refrigerator-F

Product Class 3 

Efficiency Level 3 (20%)

-0.5

0

0.5

1

1.5

2

2.5

2010 2015 2020 2025 2030 2035 2040 2045 2050 2055 2060 

Year

Billions of 2008 Dollars

Operating Cost SavingsIncremental Product CostNet Savings

EERE-2008-BT-STD-0012 COMMENT 26
Example National Energy Savings and Net Presen

Efficiency 

Level

Top-Mount Std-Size 

Refrigerator-Freezers Std. Size 

NES 

(quads)

NPV at 3% 

(billions of 

$2008)

NPV at 7% 

(billions of 

$2008)

NES 

(quads)

N

(b

0.90 1.10 13.39 5.08 0.34 0.85 1.69 20.16 7.60 0.55 0.80 2.35 26.57 9.79 0.75 0.75 3.01 31.08 11.01 0.96 0.70 3.65 33.86 11.35 1.15 0.65 4.20 34.26 10.57 1.34 0.60 4.78 32.78 8.75 1.51 0.55 5.28 31.53 7.18 1.63 

EERE-2008-BT-STD-0012 COMMENT 26
Other Issues

DOE invites comments and recommendations f

parties on any other aspects related to the Nationa

EERE-2008-BT-STD-0012 COMMENT 26
234

Background and Legal Authority

Public Meeting Agenda

5

2 Market & Tech; Screening; Engineering3 Energy Use; Markup Analysis

41 Statute and Context5

Life-Cycle Cost and Payback Period A

National Impact Analysis

6 Preliminary MIA; NOPR Analyses

EERE-2008-BT-STD-0012 COMMENT 26
Preliminary Activities Flow Diag

Framework

Document

Preliminary

Activities NOPR Final Rule Effe

D

Screenin

g

Analysis

Engineering Analysis

Energy Use Characterization

Shipments Analysis

Markups to Determine Product Price

Life-Cycle Cost and Payback Period Analyses

Market & Technology Assessment

Preliminary Manufacturer Impact Analysis

EERE-2008-BT-STD-0012 COMMENT 26
 DOE conducted on-site and telephone interviews 

manufacturers of residential refrigeration equipm

 Topics included:

• Engineering analysis overview, methodology, and resu• Key Issues (as defined by manufacturer);• Current market conditions (shipments, market share, p

profitability);

• Manufacturer sub-group analysis;• Product utility and innovation (performance vs. efficienc• Potential impacts of amended energy conservation stan

conversion costs); and

• Cumulative regulatory burdens (state, federal, internatio

Preliminary Manufacturer Impact Analysis (

Preliminary Man

EERE-2008-BT-STD-0012 COMMENT 26
 DOE interviewed manufacturers representing mo

market for residential refrigeration products.

 At least 90 percent of the standard-size product marke

 At least 80 percent of the overall market.

Residential Refrigeration Product

Manufacturer

Sub-Group 

Analysis

Product Utility and Innovation

ImpacEfficieStanda

Current 

Market 

Conditions

KeyIssues

Preliminary Man

EERE-2008-BT-STD-0012 COMMENT 26
 Increased Conversion Costs:

• Significant changes to required baseline efficiency leve

significantly higher conversion costs than moderate cha

• Significant changes to required baseline efficiency leve

with wall thickness increases rather than just componen

 Impact to U.S. Production and Jobs

• Standards requiring investment in new plants will likely 

manufacturing jobs within the U.S. 

• Manufacturers would build new plants elsewhere to tak

labor costs.

Residential Refrigeration Products Ke

Preliminary Man

EERE-2008-BT-STD-0012 COMMENT 26
 Cumulative Regulatory Burden:

• Pending climate change legislation will likely limit the am

gases (GHG’s) allowed within refrigeration products anrefrigeration products.

• Limits on GHG’s would require manufacturers to conve

refrigerants and foam-blowing agents.

• Many of the most viable alternative refrigerants are hyd

would require significant capital investment in order to msafety standards.

• Changing energy efficiency standards in Canada and c

regulations in Europe present additional regulatory burdmanufacturers of refrigeration products.

 Impact to Product Utility:

• Product utility could be lost if new efficiency standards 

wall thickness since storage volume would decrease whremains the same.

• Other features such as glass doors and multiple tempe

compartments increase energy consumption and may hin order to meet new efficiency standards, decreasing p

Residential Refrigeration Products Ke

Preliminary Man

EERE-2008-BT-STD-0012 COMMENT 26
Other Issues

DOE welcomes comments and recommenda

interested parties on any aspects related to the 

Manufacturer Impact Analysis.

Preliminary Man

EERE-2008-BT-STD-0012 COMMENT 26
Framework 

Document ANOPR NOPR Fina

Rule

Analyses for Notice of Proposed Rulem

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

NOPR Preliminary Analysis Final Rule

Trial 

Standard 

Levels

EERE-2008-BT-STD-0012 COMMENT 26
Framework 

Document ANOPR NOPR Fina

Rule

Analyses for Notice of Proposed Rulem

NOPR Preliminary Analysis Final Rule

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

EERE-2008-BT-STD-0012 COMMENT 26
Revise Preliminary Analysis

Analysis Action

Engineering Analysis

 Consider comments Revise using latest da

Life-Cycle Cost and Payback Period Analyses

 Consider comments Revise using latest da Conduct LCC sub-gro

National Impacts Analysis

 Consider comments Revise using latest da

Rev

EERE-2008-BT-STD-0012 COMMENT 26
Framework 

Document ANOPR NOPR Fina

Rule

Analyses for Notice of Proposed Rulem

NOPR Preliminary

Analysis

Final 

Rule

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

EERE-2008-BT-STD-0012 COMMENT 26
Life-Cycle Cost Subgroup Analy

 Purpose

• Evaluate impacts on any identifiable groups or custo

disproportionately affected by any national energy e

 Method

• Analyze the LCC and payback periods (PBPs) for th

into any identifiable groups. LCC spreadsheet modeinputs to represent particular groups.

• Possible subgroups include low-income households 

 Output

• Customer subgroup life-cycle costs and payback pe• Identification of subgroups particularly affected by a 

EERE-2008-BT-STD-0012 COMMENT 26
Purchase Price Impacts

 DOE will be especially sensitive to increases in the pu

equipment due to new standards, to avoid negative imidentifiable population groups that may not be able to increases in equipment price.

EERE-2008-BT-STD-0012 COMMENT 26
Framework 

Document ANOPR NOPR Fina

Rule

Analyses for Notice of Proposed Rulem

NOPR Preliminary

Analysis

Final 

Rule

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

EERE-2008-BT-STD-0012 COMMENT 26
 Purpose:

• To develop a list of potential amended standard lev

impacts are weighed and a proposed standard leve

– Each trial standard level consists of a set of eff

all product classes, and may vary between prod

– NOPR analyses assess impacts for trial standa

efficiency levels for each product class).

 Method:

• Trial standard levels are assembled from the produ

efficiency levels identified in the preliminary analys

– Trial standard levels cover a range of efficienci

 Most energy efficient level (max-tech); Efficiency level with the lowest life-cycle co Efficiency level with a payback period of th Efficiency levels with noteworthy technolog Efficiency levels that fill in large gaps.

Selection of Trial Standard Lev

EERE-2008-BT-STD-0012 COMMENT 26
Request for Comment: 

Criteria for the Selection of Trial Stand

DOE requests feedback on the criteria it shou

basing the selection of Trial Standard Le

 A critical part of the NOPR analysis on which DOE 

guidance is the criteria used in selecting trial stan

 Trial standard levels are created from combinatio

levels at the product class level.

EERE-2008-BT-STD-0012 COMMENT 26
Framework 

Document ANOPR NOPR Fina

Rule

Analyses for Notice of Proposed Rulem

NOPR Preliminary

Analysis

Final 

Rule

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

EERE-2008-BT-STD-0012 COMMENT 26
Manufacturer Impact Analysi

Manu

 Purpose

• Assess the impacts of standards on refrigerator and 

manufacturers.

• Identify and estimate impacts on manufacturer sub-g

more severely impacted than the industry as a whole

• Examine the impact of cumulative regulatory burden

 Method 

• Analyze industry cash flow and net present value th

Government Regulatory Impact Model (GRIM).

• Interview manufacturers to refine inputs to the GRIM

analyses, and address qualitative issues.

 Output

• Manufacturer sub-group net present value impacts.• Other sub-group net present value impacts.• Other impacts.

EERE-2008-BT-STD-0012 COMMENT 26
Industry profile

Develop straw-man GRIM

Develop interview guide

Interviews 

& industrywide / 

subgroup 

analyses

Assempcomcumburd

Phase 2

Manufacturer Impact Analysis (MIA) 

Manu

Ph

 The MIA process consists of three phases:

Phase 1

EERE-2008-BT-STD-0012 COMMENT 26
The MIA is both concurrent and coordinate

throughout the rulemaking pro

Phase I

Industry Profile

Phase III

Manufacturer Interviews

Revised Industry Cash Flow

Manufacturer Subgroup Analysis

Qualitative Assessment

Phase II

“Strawman” GRIM

Manufacturer Impact Analysis

Sc

Scr

Eng

Eng

L

N

S

Na

Sa

Co

Con

U

Env

Envir

Other Rule

Ind

Ind

Manu

EERE-2008-BT-STD-0012 COMMENT 26
Phase I: Industry Profile

Manu

• Collect financial and market information:

• Industry reports;• Company annual reports and websites;• Trade journals;• U.S. Census Bureau;• SEC 10-K form filings;• Information from the preliminary activities prec

manufacturer production costs, markups; and selling prices, shipments.

EERE-2008-BT-STD-0012 COMMENT 26
Manufacturer Prices

Shipments

Manuf

Financ

Cash Flow Impacts, Changes in Industry NPV

GRIM

Phase II: Develop Straw-man G

• The Government Regulatory Impact Model (GRIM

cash flow analysis that estimates the change in due to the introduction of new efficiency standa

Manu

EERE-2008-BT-STD-0012 COMMENT 26
Phase II: Develop Interview Gu

Manu

 A critical aspect of the MIA involves interviews wit

An interview guide is sent to manufacturers in preIII. 

 Interview topics will include:

 Engineering analysis; Shipments model; Cost structure and financial 

parameters;

 Conversion costs (capital 

expenditures, tooling, R&D, testing);

 Impact of other regulations / 

cumulative burden;

 Direct employment impacts;

 Import / Exp Consolidatio

impacts;

 Replacemen

refurbishme

 Impact of th

effective dat

 Other topics 

manufacture

EERE-2008-BT-STD-0012 COMMENT 26
Phase III: Manufacturer Intervie

Manu

 Expected timeframe. Time and personnel commitment for manufacturer

GRIM, GRIM assumptions, subgroup analysis disc

 Confidentiality agreements.

EERE-2008-BT-STD-0012 COMMENT 26
Phase III: Manufacturer Subgroup A

Manu

 The subgroup analysis is a more focused version 

wide analysis.

• Work with subgroup representatives to tailor a GR

unique financial characteristics.

• Consider and focus on issues of importance to th

including employment, capacity utilization and cum

• Review draft findings with subgroup members dur

EERE-2008-BT-STD-0012 COMMENT 26
Framework 

Document ANOPR NOPR Fina

Rule

Analyses for Notice of Proposed Rulem

NOPR Preliminary Analysis Final Rule

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

EERE-2008-BT-STD-0012 COMMENT 26
 Purpose

• Investigate the effects on electric utilities from reduc

consumption and reduced peak load demand due to conservation standards.

 Method 

• Uses national energy savings results.• Uses the Energy Information Administration’s Nation

System (NEMS) tailored for DOE’s Building Techno(NEMS-BT).

 Output

• Change in electricity sales and price by region.• Change in the mix of electricity generation.• Change in new capacity construction.

Utility Impact Analysis

EERE-2008-BT-STD-0012 COMMENT 26
Framework 

Document ANOPR NOPR Fina

Rule

Analyses for Notice of Proposed Rulem

NOPR Preliminary Analysis Final Rule

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

EERE-2008-BT-STD-0012 COMMENT 26
 Purpose

• Report net jobs created or eliminated nationally as a 

energy conservation standards.

 Method 

• Uses the ImSET (Impact of Sector Energy Technolo

evaluation of indirect employment impacts.

• Changes in equipment and energy expenditures are 

National Energy Savings Analysis.

• Direct employment impacts are developed in the Ma

Analysis.

 Output

• Change in the commercial and energy sector emplo

consequence of new energy conservation standards

Emp

Employment Impact Analysis

EERE-2008-BT-STD-0012 COMMENT 26
Framework 

Document ANOPR NOPR Fina

Rule

Analyses for Notice of Proposed Rulem

NOPR Preliminary

Analysis

Final 

Rule

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

EERE-2008-BT-STD-0012 COMMENT 26
 Purpose

• Report environmental impacts as a consequence of 

conservation standards, including changes in power 

 Method 

• Energy savings results taken from the National Ene• Energy Information Administration’s National Energy 

(NEMS) provides power-plant emissions.

 Output

• Estimate of national emission reductions of sulfur di

of nitrogen (NOx ), carbon dioxide (CO2 ) and mercury 

Env

Environmental Assessment

EERE-2008-BT-STD-0012 COMMENT 26
Issue for Public Comment

Issue 19: Valuing Air-Borne Emission Reductions:

DOE plans on monetizing the emission redstandards consistent with methods used in standards rulemakings pertaining to refrigevending machines and commercial clothes example, in the case of CO2 , DOE used valu

to $55 per metric ton of CO2 to value the em

to standards. DOE invites comments on thmonetizing the emission savings due to enstandards.

En

EERE-2008-BT-STD-0012 COMMENT 26
Framework 

Document ANOPR NOPR Fina

Rule

Analyses for Notice of Proposed Rulem

NOPR Preliminary Analysis Final Rule

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

Preliminary

Analysis

Trial 

Standard 

Levels

EERE-2008-BT-STD-0012 COMMENT 26
 Purpose

• Investigate the national impacts due of non-regulator

compared with mandatory energy conservation stand

• The non-regulatory alternatives that may be conside

– No new regulatory action; early replacement; prescript

tax credits; manufacturer tax credits; customer rebates

targets; bulk government procurement.

 Method

• NES spreadsheet model is modified to consider scen

energy prices and escalation factors; implicit market customer purchase price, operating cost, and income equipment stock data. 

 Output

• National Energy Savings and Net Present Value of th

alternatives.

• Impact of non-regulatory alternatives on purchase pr

efficient equipment.

Reg

Regulatory Impact Analysis

EERE-2008-BT-STD-0012 COMMENT 26
 DOE seeks to encourage development of consens

new standards because standards with such broalikely to balance effectively the economic, energy, interests affected by standards.

 Any recommendation must satisfy the seven statu

provided by EPCA for determining whether an enestandard is technologically feasible and economicwill result in significant energy savings.

 Any consensus recommendation should also incl

DOE can use to assess the seven statutory criteriwhether the benefits of the standard exceed its bugreatest extent practicable.

Consensus Recommendation

EERE-2008-BT-STD-0012 COMMENT 26
Factor An

1. Economic impact on consumers and 

manufacturers

Life-cycle cost anManufacturer imp

2. Lifetime operating cost savings Life-cycle cost an3. Total projected energy savings National impact a4. Impact on utility or performance Screening analys

Engineering anal

5. Impact of any lessening of 

competition

Manufacturer imp

6. Need for national energy 

conservation

National impact a

7. Other factors the Secretary 

considers relevant

Environmental asUtility impact anaEmployment imp

The Energy Policy and Conservation Act (EPCA

consider seven factors when setting energy cons

EERE-2008-BT-STD-0012 COMMENT 26
Final Comments and Question

DOE requests comments and invites questi

interested parties regarding the Department o

Residential Refrigeration Products Rulem

EERE-2008-BT-STD-0012 COMMENT 26
How to Submit Comments...

 Public Meeting – oral comments will be captured in th

become part of the public record.

 Written comments – Preliminary comment period ope

Reference docket #: EERE-2008-BT-STD-0012 and/o

Email: appliance.rulemaking@ee.doe.govMail: Ms. Brenda Edwards-Jones

U.S. Department of Energy Building Technologies Program, Mail stop EE-2Preliminary Analysis for Residential RefrigeratoEERE-2008-BT-STD-0012 1000 Independence Avenue, SW Washington DC, 20585-0121

Courier: Ms. Brenda Edwards-Jones 

U.S. Department of Energy Building Technologies Program, 1J-018 1000 Independence Avenue, SW Washington DC, 20585-0121

EERE-2008-BT-STD-0012 COMMENT 26