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.

 CE-RM-87-102 COMMENT 08

Background 

Proposed Standards Rulemaking 

For Three Products 

Summary of Comments 

.,MAg 8 '1989 

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 

DOEls 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 DOEls 

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 of Comments 

.,MAg 8 '1989 

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 

DOEls 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 DOEls 

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. 
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.

 CE-RM-87-102 COMMENT 08

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. 

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.