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CHAPTER 1. INTRODUCTION

TABLE OF CONTENTS

1.1 PURPOSE OF THE DOCUMENT.............................................................................. 1-1

1.2 OVERVIEW OF STANDARDS FOR RESIDENTIAL DISHWASHERS................... 1-1

1.3 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS .................. 1-2

1.4 STRUCTURE OF THE DOCUMENT ........................................................................ 1-4

LIST OF TABLES

Table 1.3.1 Analyses Under the Process Rule ..................................................................... 1-3
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CHAPTER 1. INTRODUCTION

1.1 PURPOSE OF THE DOCUMENT

This technical support document (TSD) is a stand-alone report that provides the technical 

analyses and results supporting the information presented in the direct final rule and executive 

summary for residential dishwashers.

1.2 OVERVIEW OF STANDARDS FOR RESIDENTIAL DISHWASHERS

The Energy Policy and Conservation Act (EPCA) of 1975, Pub. L. 94-163 (42 United 

States Code (U.S.C.) 6291–6309), established an energy conservation program for major 

household appliances. The National Energy Conservation Policy Act of 1978 (NECPA), Pub. L. 

95-619, amended EPCA to add Part Ca of Title III (42 U.S.C. 6311–6317), which established an 

energy conservation program for certain industrial equipment. Additional amendments to EPCA 

give DOE the authority to regulate the energy efficiency of several products, including 

residential dishwashers—the products that are the focus of this document. The amendments to 

EPCA in the National Appliance Energy Conservation Act of 1987 (NAECA), Pub. L. 100-12, 

established standards for residential dishwashers, as well as requirements for determining 

whether these standards should be amended. (42 U.S.C. 6295(g))

NAECA established the first prescriptive standards for residential dishwashers, requiring 

that dishwashers be equipped with an option to dry without heat, and further required that DOE 

conduct two cycles of rulemakings to determine if more stringent standards are justified.b (42 

U.S.C. 6295 (g)(1) and (4)) On May 14, 1991, DOE published a final rule in the Federal 

Register (FR) establishing the first set of performance standards for residential dishwashers; the 

compliance date of the new standards was May 14, 1994. 56 FR 22250. DOE initiated a second 

standards rulemaking for residential dishwashers, publishing an advance notice of proposed 

rulemaking (ANOPR) on November 14, 1994, to consider amending the energy conservation 

standards for clothes washers, dishwashers, and clothes dryers. 59 FR 56423. However, as a 

result of the priority-setting process outlined in its Procedures for Consideration of New or 

Revised Energy Conservation Standards for Consumer Products (the “Process Rule”) (61 FR 

36974 (July 15, 1996); 10 CFR part 430, subpart C, appendix A), DOE suspended the standards 

rulemaking for dishwashers.

 

a Part C has been redesignated Part A-1 in the United States Code for editorial reasons.

b DOE defines “dishwasher” under EPCA as “a cabinet-like appliance which with the aid of water and detergent, 

washes, rinses, and dries (when a drying process is included) dishware, glassware, eating utensils, and most cooking 

utensils by chemical, mechanical and/or electrical means and discharges to the plumbing drainage system.” 10 CFR 

430.2. 
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To complete the second rulemaking cycle required by NAECA, on March 15, 2006, DOE 

published on its website the Rulemaking Framework for Commercial Clothes Washers and 

Residential Dishwashers, Dehumidifiers, and Cooking Products, and a notice announcing the 

availability of this framework document. On November 15, 2007, DOE published an ANOPR 

addressing energy conservation standards for these products. 72 FR 64432. On December 19, 

2007, however, Congress enacted the Energy Independence and Security Act of 2007 (EISA 

2007), Pub. L. 110-140, which, among other things, established maximum energy and water use 

levels for residential dishwashers manufactured on or after January 1, 2010. (42 U.S.C. 

6295(g)(10)) Because EISA 2007 established standards for residential dishwashers, DOE 

codified the statutory standards for these products in a final rule published March 23, 2009. 74 

FR 12058.

1.3 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS

Under EPCA, when DOE is studying new or amended standards, it must consider, to the 

greatest extent practicable, the following seven factors (42 U.S.C. 6295 (o)(2)(B)(i)):

1) the economic impact of the standard on the manufacturers and consumers of the affected 

products; 

2) the savings in operating costs throughout the estimated average life of the product 

compared to any increases in the initial cost or maintenance expense; 

3) the total projected amount of energy savings likely to result directly from the imposition 

of the standard; 

4) any lessening of the utility or the performance of the products likely to result from the 

imposition of the standard; 

5) the impact of any lessening of competition, as determined in writing by the Attorney 

General, that is likely to result from the imposition of the standard; 

6) the need for national energy conservation; and 

7) other factors the Secretary considers relevant.

Other statutory requirements are set forth in 42 U.S.C. 6295 (o)(1)–(2)(A), (2)(B)(ii)–

(iii), and (3)–(4) and 42 U.S.C. 6316(e).

DOE initiated the current rulemaking in response to the “Agreement on Minimum 

Federal Efficiency Standards, Smart Appliances, Federal Incentives and Related Matters for 

Specified Appliances” (the “Joint Petition”), a comment submitted on July 30, 2010, by groups 
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representing manufacturers, energy and environmental advocates, and consumer groups

(collectively, the “Joint Petitioners”). This collective set of comments, which DOE refers to in 

this notice as the “Joint Petition”c recommends specific energy conservation standards for 

residential dishwashers that, in the commenters’ view, would satisfy the EPCA requirements in 

42 U.S.C. 6295(o).

EPCA allows DOE to issue a direct final rule establishing an energy conservation 

standard on receipt of a statement submitted jointly by interested persons that are fairly 

representative of relevant points of view (including representatives of manufacturers of covered 

products, States, and efficiency advocates) that contains recommendations with respect to an 

energy conservation standard that are in accordance with the provisions of 42 U.S.C. 6295(o). 

DOE has concluded that the recommendations of the Joint Petition satisfy the requirements of 42 

U.S.C. 6295(o). Therefore, DOE is publishing this direct final rule concurrently with a notice of 

proposed rulemaking that proposes identical energy conservation standards. If DOE receives 

adverse comment and determines that such comment may provide a reasonable basis for 

withdrawing the direct final rule, this final rule will be withdrawn and DOE will proceed with 

the proposed rule.

For the direct final rule, DOE conducted each of the analyses typically performed at the 

Preliminary Analysis and NOPR rulemaking stages, as shown in Table 1.3.1.

Table 1.3.1 Analyses Under the Process Rule

Preliminary Analyses NOPR Final Rule

Market and technology assessment Revised preliminary analyses Revised NOPR analyses

Screening analysis Life-cycle cost sub-group 

analysis

Engineering analysis Manufacturer impact analysis

Energy use determination Utility impact analysis

Markups for equipment price 

determination

Environmental assessment

Life-cycle cost and payback period 

analysis

Employment impact analysis

Shipments analysis Regulatory impact analysis

National impact analysis

Preliminary manufacturer impact analysis

As part of the information gathering and sharing process, DOE organized and held 

interviews with manufacturers of the residential dishwashers considered in this rulemaking. DOE 

selected companies that represented production of all types of products, ranging from small to 

 

c DOE Docket No. EERE–2011–BT–STD–0060, Comment 1.
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large manufacturers, and included the Association of Home Appliance Manufacturers (AHAM)

member companies. DOE had four objectives for these interviews: (1) solicit manufacturer 

feedback on the draft inputs to the engineering analysis; (2) solicit feedback on topics related to 

the manufacturer impact analysis; (3) provide an opportunity to express manufacturers’ concerns 

to DOE; and (4) foster cooperation between manufacturers and DOE. DOE incorporated the 

information gathered during the engineering interviews with manufacturers into its engineering 

analysis (chapter 5) and the manufacturer impact analysis (chapter 12).

DOE developed spreadsheets for the engineering, Life-Cycle Cost (LCC) Payback Period 

(PBP), and national impact analyses for each product. The LCC spreadsheet calculates the LCC 

and PBP at various energy efficiency levels. The national impact analysis spreadsheet calculates 

the national energy savings and national net present values at various energy efficiency levels. 

This spreadsheet includes a model that forecasts the impacts of amended energy conservation 

standards at various levels on product shipments. All of these spreadsheets are available on the 

DOE website for residential dishwashers at:

www1.eere.energy.gov/buildings/appliance_standards/residential/dishwashers.html.

DOE can also provide quantitative outputs from its analyses in machine-readable format 

upon request. For example, outputs from trial runs of the LCC Monte Carlo simulations can be 

provided in such a format.

1.4 STRUCTURE OF THE DOCUMENT

This TSD outlines the analytical approaches used in this rulemaking. The TSD consists of 

the following chapters and appendices.

Chapter 1 Introduction: provides an overview of the appliance standards program 

and how it applies to this rulemaking, and outlines the structure of the 

document.

Chapter 2 Analytical Framework: describes the analytical process and methods.

Chapter 3 Market and Technology Assessment: characterizes the market for the 

considered products and the technologies available for increasing 

product efficiency.

Chapter 4 Screening Analysis: identifies all the design options that improve 

efficiency of the considered products, and determines which technology 

options are viable for consideration in the engineering analysis.
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Chapter 5 Engineering Analysis: discusses the methods used for developing the 

relationship between increased manufacturer price and increased 

efficiency.

Chapter 6 Markups Analysis: discusses the methods used for establishing markups 

for converting manufacturer prices to customer product costs.

Chapter 7 Energy Use Analysis: discusses the process used for generating energyuse estimates for the considered products as a function of standard 

levels.

Chapter 8 Life-Cycle Cost and Payback Period Analysis: discusses the effects of 

standards on individual customers and users of the products and 

compares the LCC and PBP of products with and without higher 

efficiency standards.

Chapter 9 Shipments Analysis: estimates shipments of the products over the 30-

year analysis period that is used in performing the national impact 

analysis (NIA).

Chapter 10 National Impact Analysis: assesses the national energy savings, and the 

national net present value of total consumer costs and savings, expected 

to result from specific, potential energy conservation standards.

Chapter 11 Consumer Subgroup Analysis: discusses the effects of standards on 

different subgroups of consumers.

Chapter 12 Manufacturer Impact Analysis: discusses the effects of standards on the 

finances and profitability of product manufacturers.

Chapter 13 Employment Impact Analysis: discusses the effects of standards on 

national employment.

Chapter 14 Utility Impact Analysis: discusses certain effects of the considered on 

electric and gas utilities.

Chapter 15 Environmental Assessment: discusses the effects of standards on three 

pollutants—sulfur dioxide (SO2), nitrogen oxides (NOx), and mercury—

as well as carbon dioxide emissions.

Chapter 16 Monetization of Emission Reductions Benefits

Chapter 17 Regulatory Impact Analysis: discusses the impact of non-regulatory 

alternatives to efficiency standards.
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Appendix 8-A User Instructions for Life-Cycle Cost and Payback Period Spreadsheets

Appendix 8-B Uncertainty and Variability

Appendix 8-C Estimation of Equipment Price Trends for Residential Dishwashers

Appendix 8-D Lifetime Distributions

Appendix 8-E Distribution Used for Discount Rates

Appendix 8-F LCC and PBP Results Using Alternative Base Case Efficiency 

Distribution

Appendix 9-A Relative Price Elasticity of Demand for Appliances

Appendix 10-A User Instructions for Shipments and National Impact Analysis

Spreadsheets

Appendix 10-B National Net Present Value of Consumer Benefits Using Alternative 

Product Price Forecasts

Appendix 10-C National Energy Savings and Net Present Value Using Alternative 

Economic Growth Scenarios

Appendix 10-D. National Energy Savings And Net Present Value Using Alternative 

Analysis Period

Appendix 10-E. National Energy Savings and Net Present Value Using Alternative Base 

Case Efficiency Trend

Appendix 12-A Manufacturer Impact Analysis Interview Guide

Appendix 12-B Government Regulatory Impact Model

Appendix 16-A Social Cost of Carbon for Regulatory Impact Analysis under Executive 

Order 12866

Appendix 17-A Regulatory Impact Analyisis: Supporting Material