8 1988 Proposed Standards Rulemaking For Three Products Summary of Comments Background o On December 2, 1988, The Department of Energy (DOE) published a notice of Proposed Rulemaking regarding energy conservation standards for three products (refrigerators, refrigerator-freezers, freezers, small gas furnaces, and television sets). o For refrigerators, DOE requested information on a range of standards, from the 1990 'level prescribed by the legislation to level 3, which is approximately 25 percent less energy consumptive than the legislated level. For small gas furnaces, DOE proposed a standard of 78 percent Annual Fuel Utilization Efficiency (AFUE), which is the highest level within the range the legislation directs DOE to consider. For television sets, DOE proposed that standards were not economically justified. o Thirty-three persons representing manufacturers, trade associations, utilities, state governments and public interest groups testified at DOE's public hearing on January 12-13, 1989. DOE received 120 written comments during the comment period ending January 31, 1989. o The comments received concerning refrigerators and small gas furnaces included substantial specific data and recommendations. Based on this information, DOE will conduct a new analysis for this rulemaking. The comments received concerning television sets were general and did not contain specific data. Refrigerators, Refrigerator-freezers, Freezers o Approximately one-half of the comments and testimony addressed DOE's proposal for refrigerators. o None of the comments support the adoption of level 3. o Comments from some 60 members of Congress stress that DOE should adopt the highest level that meets the criteria of the legislation. o Utilities, public interest groups and state governments argue that level 3 is too low and that DOE should adopt level 4 since it is the lowest point on the life cycle cost curve, it is technologically feasible and it provides a consumer payback period of 3.3-4.0 years (depending on product class) for a product with an expected life of 18 years. o Utilities, in particular, maintain that the 7 percent discount rate used by DOE is too high that consumers rate of return is much less--3 percent of 4 percent, and that a lower discount rate would add justification for level 4. The Environmental Protection Agency commented that it used a 3 percent discount rate in its recent rulemakings. Background Proposed Standards Rulemaking For Three Products Summary ofComments .,MAg 8 '1989

oOn December 2, 1988, The Department ofEnergy (DOE) published a notice of Proposed Rulemaking regarding energy conservation standards for three products (refrigerators, refrigerator-freezers, freezers, small gas furnaces, and television sets).
oFor refrigerators, DOE requested information on a range of standards, from the 1990 level prescribed by the legislation to level 3, which is approximately 25 percent less energy consumptive than the legislated level. For small gas furnaces, DOE proposed a standard of 78 percent Annual Fuel Utilization Efficiency (AFUE), which is the highest level within the range the legislation directs DOE to consider. For television sets, DOE proposed that standards were not economicallyjustified.

oThirty-three persons representingmanufacturers, trade associations, utilities, state governments and public interestgroups testified at DOEls public hearing on January 12-13, 1989. DOE received 120 written comments during the comment period ending January 31, 1989.
oThe comments received concerning refrigerators and small gas furnaces included substantial specific data and recommendations. Based on this information, DOE will conduct a new analysis for this rulemaking. The comments received concerning television sets were general and did not contain specific data. Refrigerators, Refrigerator-freezers, Freezers
oApproximately one-halfof the comments and testimony addressed DOEls proposal for refrigerators.

oNone ofthe comments support the adoption of level 3.
oComments from some 60 members ofCongress stress thatDOE should adopt the highest level thatmeets the criteria of the legislation.
oUtilities, public interest groups and state governments argue that level 3is too low and thatDOE should adopt level 4 since it is the lowest pointon the life cycle costcurve, it is technologically feasible and itprovides a consumer payback period of 3.3-4.0years (depending on product class) for a product with an expected life of 18years.
oUtilities, in particular, maintain that the 7percentdiscount rate used by DOE is too high that consumers rate ofreturn ismuch less--3 percentof4percent, and that a lower discount ratewould add justification for level 4. The Environmental Protection Agency commented that itused a 3percentdiscount rate in its recent rulemakings. Background Proposed Standards Rulemaking For Three Products Summary ofComments .,MAg 8 '1989

oOn December 2, 1988, The Department ofEnergy (DOE) published a notice of Proposed Rulemaking regarding energy conservation standards for three products (refrigerators, refrigerator-freezers, freezers, small gas furnaces, and television sets).
oFor refrigerators, DOE requested information on a range of standards, from the 1990 level prescribed by the legislation to level 3, which is approximately 25 percent less energy consumptive than the legislated level. For small gas furnaces, DOE proposed a standard of 78 percent Annual Fuel Utilization Efficiency (AFUE), which is the highest level within the range the legislation directs DOE to consider. For television sets, DOE proposed that standards were not economicallyjustified.

oThirty-three persons representingmanufacturers, trade associations, utilities, state governments and public interestgroups testified at DOEls public hearing on January 12-13, 1989. DOE received 120 written comments during the comment period ending January 31, 1989.
oThe comments received concerning refrigerators and small gas furnaces included substantial specific data and recommendations. Based on this information, DOE will conduct a new analysis for this rulemaking. The comments received concerning television sets were general and did not contain specific data. Refrigerators, Refrigerator-freezers, Freezers
oApproximately one-halfof the comments and testimony addressed DOEls proposal for refrigerators.

oNone ofthe comments support the adoption of level 3.
oComments from some 60 members ofCongress stress thatDOE should adopt the highest level thatmeets the criteria of the legislation.
oUtilities, public interest groups and state governments argue that level 3is too low and thatDOE should adopt level 4 since it is the lowest pointon the life cycle costcurve, it is technologically feasible and itprovides a consumer payback period of 3.3-4.0years (depending on product class) for a product with an expected life of 18years.
oUtilities, in particular, maintain that the 7percentdiscount rate used by DOE is too high that consumers rate ofreturn ismuch less--3 percentof4percent, and that a lower discount ratewould add justification for level 4. The Environmental Protection Agency commented that itused a 3percentdiscount rate in its recent rulemakings.o Manufacturers and trade associations argue that DOE should not amend the 1990 legislated standards. They cite uncertainty of chlorofluorocabon (CFC) availability and questionable performance of CFC alternatives. Small Gas Furnaces o Nearly one half of the comments and testimony address DOE's proposal for small gas furnaces. o Furnace manufacturers, related trade associations, the electric power industry, state governments and public interest groups support DOE's proposal. o The gas industry, in particular, those located in the South and Southwest, argued for a lower standard level. Impacts/problems cited with the proposed level include: higher first costs and installation costs, especially in multi-family structures, if separate venting is required; impact on gas industry of builder decisions to install electric resistance heating in new construction (less costly to builder to install, more costly in consumer energy costs); and decreased market share for gas companies, especially in warm climate areas due to fuel switching. Television Sets o Approximately 10 percent of the comments and testimony address DOE's proposal for TV sets. o Manufacturers and trade associations support DOE's proposal. o Utilities and public interest groups argue that DOE should adopt standards for this product since level 3 for color TVs and level 2 for black and white TVs will save energy, are technologically feasible, and provide a consumer payback in less than 2 years for color TVs and in 2 1/2 - 3 years for black and white TVs. oManufacturers and trade associations argue thatDOE should not amend the 1990 legislated standards. They cite uncertainty of chlorofluorocabon (CFC) availability and questionable performance of CFC alternatives. Small Gas Furnaces
oNearly one half of the comments and testimony address DOE's proposal for small gas furnaces.

oFurnace manufacturers, related trade associations, the electric power industry, state governments and public interest groups support DOE's proposal.

oThe gas industry, in particular, those located in the South and Southwest, argued for a lower standard level. Impacts/problems cited with the proposed level include: higher first costs and installation costs, especially in multi-family structures, if separate venting is required; impact on gas industry ofbuilder decisions to install electric resistance heating in new construction (less costly to builder to install, more costly in consumer energy costs); and decreased market share for gas companies, especially in warm climate areas due to fuel switching. Television Sets
oApproximately 10 percentof the comments and testimony address DOE's proposal for TV sets.
oManufacturers and trade associations support DOE's proposal.
oUtilities and public interest groups argue thatDOE should adopt standards for this product since level 3for colorTVs and level 2 for black and white TVs will save energy, are technologically feasible, and provide a consumer payback in less than 2years for colorTVs and in 2 1/2 - 3years for black and white TVs. oManufacturers and trade associations argue thatDOE should not amend the 1990 legislated standards. They cite uncertainty of chlorofluorocabon (CFC) availability and questionable performance of CFC alternatives. Small Gas Furnaces
oNearly one half of the comments and testimony address DOE's proposal for small gas furnaces.

oFurnace manufacturers, related trade associations, the electric power industry, state governments and public interest groups support DOE's proposal.

oThe gas industry, in particular, those located in the South and Southwest, argued for a lower standard level. Impacts/problems cited with the proposed level include: higher first costs and installation costs, especially in multi-family structures, if separate venting is required; impact on gas industry ofbuilder decisions to install electric resistance heating in new construction (less costly to builder to install, more costly in consumer energy costs); and decreased market share for gas companies, especially in warm climate areas due to fuel switching. Television Sets
oApproximately 10 percentof the comments and testimony address DOE's proposal for TV sets.
oManufacturers and trade associations support DOE's proposal.
oUtilities and public interest groups argue thatDOE should adopt standards for this product since level 3for colorTVs and level 2 for black and white TVs will save energy, are technologically feasible, and provide a consumer payback in less than 2years for colorTVs and in 2 1/2 - 3years for black and white TVs.