CHAPTER 12. LIFE-CYCLE COST SUBGROUP ANALYSIS 

TABLE OF CONTENTS 

12.1 	INTRODUCTION ......................................................................................................... 12-1 


12.2 	SUBGROUPS DEFINITION ........................................................................................ 12-1 


12.3 	 INPUTS TO THE SUBGROUP ANALYSIS FOR CONSUMERS WITHOUT 


MUNICIPAL WATER/SEWER ................................................................................... 12-2 


12.3.2 Wastewater Prices for Consumers Using Septic Systems ............................................. 12-3 


12.4 	 INPUTS TO THE SUBGROUP ANALYSIS FOR SMALL BUSINESSES ............... 12-3 


12.4.1 Small Business Statistics for Commercial Laundry....................................................... 12-3 


12.4.2 Small Company Discount Rates .................................................................................... 12-5 


12.5 	 RESULTS FOR COMMERCIAL CLOTHES WASHER SUBGROUPS.................... 12-7 


LIST OF TABLES 

Table 12.3.1 Water Price Estimation for Residential Private Well Water Supply ................. 12-3 


Table 12.4.1 Coin-operated laundries & drycleaners: Number of Establishments and 


Receipts by Nonemployer and Employer Status ............................................... 12-4 


Table 12.4.2 Establishment and Firm Size: Legal Form of Organization .............................. 12-4 


Table 12.4.3 Establishment and Firm Size: Receipts/Revenue Size of Establishments......... 12-5 


Table 12.4.4 Discount Rate Difference Between Small Company and Market Average....... 12-6 


Table 12.4.5 Small Company Discount Rates and Small Cap Premium ................................ 12-7 


Table 12.5.1 Top-Loading Commercial Clothes Washers: LCC and PBP Results for 


Non-Public Water and Sewer Supply ................................................................ 12-8 


Table 12.5.2 Top-Loading Commercial Clothes Washers: LCC and PBP Results for 


Small Companies ............................................................................................... 12-8 


Table 12.5.3 Front-Loading Commercial Clothes Washers: LCC and PBP Results for 


Non-Public Water and Sewer Supply ................................................................ 12-9 


Table 12.5.4 Front -Loading Commercial Clothes Washers: LCC and PBP Results for 


Small Companies ............................................................................................... 12-9 


12-i 

EERE-2006-STD-0127 COMMENT 66.2
CHAPTER 12. LIFE-CYCLE COST SUBGROUP ANALYSIS 


12.1 INTRODUCTION
 

Chapter 8 describes the Life-Cycle Cost (LCC) and Payback Period (PBP) Analysis that 

examines impacts of energy efficiency standards on the U.S. population. In analyzing the 

potential impact of new or amended standards on residential and commercial consumers, DOE 

further evaluates the impact on identifiable groups of consumers (i.e., subgroups) that may be 

disproportionately affected by a national standard level. The LCC subgroup analysis evaluates 

impacts by analyzing the LCC and PBPs for subgroups commercial consumers. For commercial 

clothes washers, DOE identified two consumer subgroups: small business subgroups that own 

commercial laundries and consumers not served by municipal water and sewer. 

DOE determined the impact on consumer subgroups for commercial clothes washers 

using the LCC Spreadsheet Model, which allows for the examination of particular consumer 

subgroups. For the small business subgroup, consumer discount rates different than the general 

population were used while the subgroup of consumers not served by municipal water and sewer 

used different water and wastewater prices than the general population. The inputs for the two 

subgroups are described in sections 12.3 and 12.4. 

The technical support document (TSD) for DOE’s notice of proposed rulemaking 

(NOPR) covered conventional cooking products (i.e., cooktops and ovens), microwave oven 

energy factor (EF), microwave oven standby power consumption, and commercial clothes 

washers (CCW).1

 DOE has already completed its standards rulemaking for conventional 

cooking products and microwave oven EF and has published both a final rule2

 and corresponding 

TSD.3 This chapter presents information and results pertaining solely to CCWs. The impact of 

more-efficient equipment on microwave oven standby power will be addressed in a subsequent 

TSD. 

12.2 SUBGROUPS DEFINITION 

DOE analyzed the potential effects of standards on two subgroups: consumers not served 

by municipal water and sewer providers and small commercial clothes washer businesses. 

For consumers not served by water and sewer, DOE analyzed the potential impacts of 

standards by conducting the analysis with well water and septic system prices, rather than water 

and wastewater prices based on data from Raftelis Financial Consultants and the American 

Water Works Association.4 

For small commercial clothes washer businesses, DOE analyzed the potential impacts of 

standards by conducting the analysis with different discount rates, as small businesses do not 

have the same access to capital as larger businesses. As described below, DOE estimated that for 

12-1
 

EERE-2006-STD-0127 COMMENT 66.2
businesses purchasing commercial clothes washers, small companies have an average discount 

rate which is 3.5 percent higher than the industry average. 

12.3	 INPUTS TO THE SUBGROUP ANALYSIS FOR CONSUMERS WITHOUT 

MUNICIPAL WATER/SEWER 

In 1950, 62 percent of the population received water from public supplies.5 By 2000, the 

percentage of people receiving water from public supply rose to 85 percent. As evidenced by the 

numbers, the trend is away from privately owned wells. However currently in the United States, 

more than 44 million American residents still use privately owned individual wells to pump 

household water used. The National Groundwater Association (NGWA) estimates that more than 

15 million American households are served by privately owned individual wells. The NGWA 

estimates that the annual economic value of the privately owned pumped water is $3.09 billion 

and the value of the installed well/pump infrastructure is $64.3 billion.5 

DOE considered several factors for developing consumer prices for private well supplied 

water. Initial costs to install a well for water includes well siting, well drilling, pump purchase 

and installation, water testing, and a water treatment system (if necessary). Ongoing costs 

include pump maintenance and pump operating fuel to lift water to surface and to the point of 

use. However, DOE’s calculations for the water price to consumers using private wells are 

based only on the volumetric charge to calculate water prices, since only this charge would be 

affected by a change in water consumption. Including the fixed charge in the average would lead 

to a higher water price and would not capture the impacts of product efficiency changes. 

Information about frequency of need and cost of water treatment was unavailable. 

The calculation of average per-unit-volume prices proceeds in three steps: (1) for each 

consumer, divide the total annual economic value of pumped water by the number of people 

using private well water (divide by 360 for a daily economic value by person); (2) calculate a 

value per gallons by assuming a daily person water usage of 100 gallons; and (3) calculate a 

value per thousand gallons to compare with public supply values. 

Table 12.3.1 shows a summary of the values used to determine a $1.93 per thousand 

gallons of private well water for residential consumers. 

12-2
 

EERE-2006-STD-0127 COMMENT 66.2
 

 

 

 

Table 12.3.1 Water Price Estimation for Residential Private Well Water Supply 

Annual Economic Value Of Pumped Water (2004$) $3,090,000,000 

Annual Economic Value By Person (2004$) $69.64 

Daily Economic Value By Person (2004$) $0.19 

Gallons Of Water Person Uses Daily 100 

Value Per Gallon (2004$) $ .002 

Value Per Thousand Gallons $1.93 (2004$); $2.62 (2008$)* 

Source: National Ground Water Association 

* Converted to 2008$ by multiplying costs in 2004$ by the ratio of 2008 GDP (1.1981) to 2004 GDP (1.0893). 

Converted the price for year 2004 to the price in 2008 by multiplying the 2004 price by the ratio of the average 

water CPI in 2008 (331.33) to average water CPI in 2004 (268.10). 

12.3.2 Wastewater Prices for Consumers Using Septic Systems 

The National Onsite Wastewater Recycling Association (NOWRA) collects national cost 

data on residential septic systems from states willing to share it. To date, only Ohio has sent 

NOWRA a complete cost accounting for its state’s residences using septic.6 Using the Ohio data 

and anecdotal information from NOWRA, “annual system costs (system installation plus 

operation and maintenance) amortized over 30 years were calculated and ranged from $336 

(conventional system) to $1,172 (drip distribution) which is very similar to the state average 

sewer rate costs of $442 annually, and 30 year annual costs of $504 to 1,272 with the addition of 

connection fees and costs.”7 Given the similarity in operating costs between septic systems and 

sewer usage and due to the lack of national data, DOE recommends for septic system using 

consumers the wastewater price calculated for consumers on publicly owned treatment facilities 

of $2.57 per thousand gallons in 2007$ or $2.78 per thousand gallons in 2008$.a 

12.4 INPUTS TO THE SUBGROUP ANALYSIS FOR SMALL BUSINESSES 

12.4.1 Small Business Statistics for Commercial Laundry 

The small business administration (SBA) defines a small business by its annual receipts 

or its number of employees. Coin-operated laundries and drycleaners are considered small if its 

annual revenue is less than $6.5 million.8 

This industry is comprised of: (1) establishments primarily engaged in operating facilities 

with coin-operated or similar self-service laundry and dry-cleaning equipment for customer use 

on the premises and (2) establishments primarily engaged in supplying and servicing coinoperated or similar self-service laundry and drycleaning equipment for customer use in places of 

a

 Converted to 2008$ by multiplying costs in 2007$ by the ratio of 2008 GDP (1.1981) to 2007 GDP (1.1727). 

Converted the price for year 2007 to the price in 2008 by multiplying the 2007 price by the ratio of the average 

water CPI in 2008 (331.33) to average water CPI in 2007 (312.64). 

12-3
 

EERE-2006-STD-0127 COMMENT 66.2
business operated by others, such as apartments and dormitories. Table 12.4.1 provides the 

statistics on coin-operated lanudromats and drycleaners.9 

Table 12.4.1	 Coin-operated laundries & drycleaners: Number of Establishments and 

Receipts by Nonemployer and Employer Status 

All Firms Nonemployers* Employers 

Establishments 

Receipts 

($1,000) Establishments 

Receipts 

($1,000) Establishments 

Receipts 

($1,000) 

26,906 4,216,696 14,707 758,447 12,199 3,458,255 

* Nonemployers are businesses with no paid employees 

Source: U.S. Census Bureau, 2002. 

The following two tables provide further detail on the establishment firm size and 

receipts and revenues. Table 12.4.2 provides the establishment firm size by the type of legal 

organization.10 Table 12.4.3 provides the firm size by the amount of sales per year.11 

Table 12.4.2	 Establishment and Firm Size: Legal Form of Organization 

Legal form of organization 

Number of 

Establishments 

Receipts/Revenue 

($1,000) 

Number of 

employees 

All establishments 12,199 3,458,255 46,198 

Corporations 7,527 2,608,061 31,233 

Individual proprietorships 3,323 480,869 9,571 

Partnerships 1,347 - -

Other legal forms of organization 2 - -

Source: U.S. Census Bureau, 2002. 

12-4
 

EERE-2006-STD-0127 COMMENT 66.2
Table 12.4.3 Establishment and Firm Size: Receipts/Revenue Size of Establishments 

Meaning of sales/receipts/revenue size categories 

or establishments operated the entire year 

Number of 

establishments 

Receipts/ 

Revenue 

($1,000) 

Number of 

employees 

All establishments 12,199 3,458,255 46,198 

Establishments operated for the entire year 10,084 3,263,919 43,326 

Less than $10,000 35 163 29 

$10,000 to $24,999 164 2,930 217 

$25,000 to $49,999 685 26,473 1,103 

$50,000 to $99,999 2,442 183,436 5,451 

$100,000 to $249,999 4,486 709,913 14,986 

$250,000 to $499,999 1,604 547,125 10,122 

$500,000 to $999,999 433 285,424 4,759 

$1,000,000 to $2,499,999 124 188,512 2,131 

$2,500,000 to $4,999,999 40 143,843 730 

$5,000,000 to $9,999,999 32 217,821 738 

$10,000,000 or more 39 958,279 3,060 

Source: U.S. Census Bureau, 2002. 

Based on the data in Table 12.4.3, over 99 percent of establishments (operated for the 

entire year) have receipts/revenues of less than $5 million. But only 64 percent of industry 

receipts/revenues are earned by establishments that make less than $5 million. Therefore, even 

though almost all establishments are small, a significant percent of the revenues are captured by 

large establishments (i.e., those that earn at least $5 million). Because small establishments 

capture less than 70 percent of total industry revenues, small establishments do not represent the 

entire industry and should be analyzed as a subgroup. 

12.4.2 Small Company Discount Rates 

To calculate discount rates for small companies that purchase commercial clothes 

washers, DOE used the same methodology as the general population of commercial clothes 

washer consumers as presented in Chapter 8, section 8.2.4.3. Although the methodology is 

appropriate, the capital asset pricing model (CAPM)b

 used in section 8.2.4 for the general 

population underestimates the cost of capital for small companies. In CAPM, the risk premium 

is used to account for the higher returns associated with greater risk. However, for small 

companies, particularly very small companies, historic returns have been significantly higher 

than the CAPM equation predicts. This additional return can be accounted for by adding a size 

premium to the cost of equity for small firms: 

ke � Rf � �� � ERP� � S 

ke = Cost of equity, 

b

 See 8.2.4.3 for more extensive description of CAPM and its parameters. 

12-5
 

EERE-2006-STD-0127 COMMENT 66.2
 

 

 

 

c 

Rf = Expected return on risk-free assets, 

= Risk coefficient of the firm, 


ERP = Equity risk premium, and 


S = Size Premium. 


DOE obtained size premium data from Ibbotson Associates’ Stocks, Bonds, Bills, and 

Inflation 2007 Yearbook.

12 For the period of 1926–2006, the average size premium for the 

smallest companies in all industries is 6.27 percent, implying that on average, historic 

performance of small companies has been 6.27 percent higher than the CAPM estimate of the 

small company cost of equity.c 

To estimate the difference in discount rate between small companies and the industry 

average, DOE calculated the average discount rate for small companies in industries that 

purchase commercial clothes washers and also for all companies in those industries. DOE 

calculated the real weighted average cost of capital as described in section 8.2.4.3, using the cost 

of equity including a size premium for small companies instead of the CAPM cost of equity.d 

DOE also performed these calculations for companies in all industries. Discount rate estimates 

are presented below in Table 12.4.4. 

Table 12.4.4 Discount Rate Difference Between Small Company and Market Average 

 Discount Rate 

Sector Average Std Dev Difference 

Select Industries 5.8% 1.7% --

Select Industries, Small 9.3% 3.0% 3.5% 

Entire Market 6.3% 2.3% --

Entire Market, Small 10.2% 3.3% 3.8% 

DOE estimates that in industries that purchase commercial clothes washers, small 

companies have an average discount rate 3.5 percent higher than the industry averagee. This 

conclusion is supported by the similar difference (3.8 percent) between small and average 

company discount rates for the entire market based on data from Damodaran.f, 13 

In Chapter 8, section 8.2.4, DOE estimated average discount rate for Personal Services, 

Educational Services, Hotels/Gaming, and REIT to be 5.7 percent. Applying the additional small 

capitalization (small cap) discount rate premium of 3.5 percent presented above (in Table 12.4.4) 

In this calculation, small companies are defined as companies with market capitalization of less than or equal to 

$84.5 million, the Ibbotson Associates’ definition of Decile 10 companies. 

d	 As in 8.2.4.3, this calculation uses financial data from Damodaran Online, for the Educational Services, 

Hotels/Gaming, and REIT sectors. Damodaran Online does not include data for the Personal Services industry, so 

DOE is unable to include it in this calculation. e This 3.5% discount rate premium is an average across all companies in the three select industries, giving equal 

weighting to each company. f The group of select industries includes 146 companies total, 51 of which are small companies. The Damodaran 

database for the entire market includes 6559 companies total, 2605 of which are small companies. 

12-6
 

EERE-2006-STD-0127 COMMENT 66.2
to the 5.7 percent discount rate for industries that purchase commercial washers, the discount rate 

for small companies in these industries is approximately 9.2 percent. 

The small cap discount rate premium is presented by industry in Table 12.4.5, along with 

estimated small company discount rates by industry based on the calculations in Chapter 8, 

section 8.2.4.3. Because there was insufficient data to estimate it separately, DOE assumes that 

the small cap discount rate premium for Personal Services is the same as the average for all small 

companies in Educational Services, Hotels/Gaming, and REIT. 

Table 12.4.5 Small Company Discount Rates and Small Cap Premium 

Industry 

Small Cap Discount 

Rate Premium 

Average Industry 

Discount Rate* 

Small Company 

Discount Rate 

Personal Services 3.5% 4.3% 7.8% 

Educational Services 3.7% 7.9% 11.6% 

Hotels/Gaming 3.2% 5.8% 9.0% 

REIT 4.2% 5.7% 9.9% 

* From Chapter 8, Section 8.2.4. 

12.5 RESULTS FOR COMMERCIAL CLOTHES WASHER SUBGROUPS 

Tables 12.5.1 and 12.5.2 below summarize the top-loading commercial clothes washer 

LCC results for multi-family households and commercial laundries that do not use public water 

and/or sewer supply, or are defined as a small business. Tables 12.5.3 and 12.5.4 below 

summarize the front-loading commercial clothes washer LCC results for multi-family 

households and commercial laundries that do not use public water and/or sewer supply, or are 

defined as a small business. For the three candidate standard levels for top-loading washers and 

the four candidate standard levels for front-loading washers, the LCC results provide the average 

or mean LCC, the relative LCC savings or costs, and the percentage of consumers that are 

burdened with net costs, realize net savings, or incur no impact. 

12-7
 

EERE-2006-STD-0127 COMMENT 66.2
 

 

 

 

 

Table 12.5.1 Top-Loading Commercial Clothes Washers: LCC and PBP Results for 

Non-Public Water and Sewer Supply 

Candidate 

Standard 

Level TSL 

Life-Cycle Cost Life-Cycle Cost Savings 

Payback Period 

(Years)** 

Average 

Installed 

Price 

Average 

Operati 

ng Cost 

Average 

LCC 

Average 

Savings 

Households with 

Net Cost Median Average 

No 

Impact* 

Net 

Benefit 

Multi-Family Application 

Baseline - $760 $3,323 $4,083 - - - - - -

1 1, 2 $883 $3,212 $4,095 -$8.1 43.2% 35.0% 21.8% 11.6 17.9 

2 3, 4, 5 $974 $2,926 $3,900 $184.5 13.4% 1.3% 85.2% 4.5 5.5 

Commercial Laundry Application 

Baseline - $760 $3,482 $4,242 - - - - - -

1 1, 2 $883 $3,386 $4,269 -$17.7 51.3% 35.0% 13.8% 7.8 9.2 

2 3, 4, 5 $974 $3,079 $4,053 $195.7 2.7% 1.3% 96.0% 2.8 2.9 

* 	 “No impact” means that the base case forecast commercial clothes washer assigned to the building has greater 

efficiency than the level indicated, so the household is not affected. 

** 	 Based on the payback calculation, a very small change in operating cost can result in a few extremely large 

paybacks, which will skew the average payback. In these cases, median is probably a better indicator. 

Table 12.5.2	 Top-Loading Commercial Clothes Washers: LCC and PBP Results for 

Small Companies 

Candidate 

Standard 

Level TSL 

Life-Cycle Cost Life-Cycle Cost Savings 

Payback Period 

(Years)** 

Average 

Installed 

Price 

Average 

Operati 

ng Cost 

Average 

LCC 

Average 

Savings 

Households with 

Net Cost Median Average 

No 

Impact* 

Net 

Benefit 

Multi-Family Application 

Baseline - $760 $2,659 $3,419 - - - - - -

1 1, 2 $883 $2,569 $3,452 -$22.0 50.7% 35.6% 13.7% 11.7 17.7 

2 3, 4, 5 $974 $2,341 $3,315 $112.6 21.2% 1.5% 77.4% 4.5 5.6 

Commercial Laundry Application 

Baseline - $760 $2,963 $3,723 - - - - - -

1 1, 2 $883 $2,880 $3,764 -$26.1 58.6% 35.6% 5.8% 7.8 9.2 

2 3, 4, 5 $974 $2,620 $3,594 $140.9 5.6% 1.5% 92.9% 2.8 3.0 

* 	 “No impact” means that the base case forecast commercial clothes washer assigned to the building has greater 

efficiency than the level indicated, so the household is not affected. 

** 	 Based on the payback calculation, a very small change in operating cost can result in a few extremely large 

paybacks, which will skew the average payback. In these cases, median is probably a better indicator. 

12-8
 

EERE-2006-STD-0127 COMMENT 66.2
 

 

 

 

 

 

 

 

 

 

 

 

Table 12.5.3 Front-Loading Commercial Clothes Washers: LCC and PBP Results for 

Non-Public Water and Sewer Supply 

Candidate 

Standard 

Level TSL 

Life-Cycle Cost Life-Cycle Cost Savings 

Payback Period 

(Years)** 

Average 

Installed 

Price 

Average 

Operati 

ng Cost 

Average 

LCC 

Average 

Savings 

Households with 

Net Cost Median Average 

No 

Impact* 

Net 

Benefit 

Multi-Family Application 

Baseline - $1,365 $2,904 $4,270 - - - - - -

1 1 $1,365 $2,904 $4,138 $4.8 0.0% 96.4% 3.6% 0.0 0.0 

2 2, 3 $1,388 $2,772 $3,725 $19.9 0.0% 96.4% 3.6% 0.4 0.4 

3 4 $1,428 $2,337 $3,628 $95.0 1.0% 22.4% 76.6% 3.0 3.2 

4 5 $1,470 $2,200 $3,513 $210.4 0.6% 0.0% 99.4% 2.8 3.1 

Commercial Laundry Application 

Baseline - $1,365 $2,042 $4,430 - - - - - -

1 1 $1,365 $3,065 $4,287 $5.1 0.0% 96.4% 3.6% 0.0 0.0 

2 2, 3 $1,388 $2,921 $3,822 $21.8 0.0% 96.4% 3.6% 0.2 0.2 

3 4 $1,428 $2,434 $3,727 $95.8 0.0% 22.4% 77.6% 1.7 1.8 

4 5 $1,470 $2,299 $3,600 $222.9 0.0% 0.0% 100.0% 1.6 1.7 

* 	 “No impact” means that the base case forecast commercial clothes washer assigned to the building has greater efficiency 

than the level indicated, so the household is not affected. 

** 	 Based on the payback calculation, a very small change in operating cost can result in a few extremely large paybacks, 

which will skew the average payback. In these cases, median is probably a better indicator. 

Table 12.5.4	 Front -Loading Commercial Clothes Washers: LCC and PBP Results for 

Small Companies 

Candidate 

Standard 

Level TSL 

Life-Cycle Cost Life-Cycle Cost Savings 

Payback Period 

(Years)** 

Average 

Installed 

Price 

Average 

Operati 

ng Cost 

Average 

LCC 

Average 

Savings 

Households with 

Net Cost Median Average 

No 

Impact* 

Net 

Benefit 

Multi-Family Application 

Baseline - $1,365 $2,327 $3,693 - - - - - -

1 1 $1,365 $2,327 $3,587 $3.7 0.0% 96.4% 3.6% 0.0 0.0 

2 2, 3 $1,388 $2,222 $3,265 $14.9 0.0% 96.4% 3.6% 0.4 0.5 

3 4 $1,428 $1,877 $3,196 $69.1 4.1% 22.2% 73.7% 3.0 3.2 

4 5 $1,470 $1,768 $3,113 $151.7 4.2% 0.0% 95.8% 2.9 3.1 

Commercial Laundry Application 

Baseline - $1,365 $1,643 $3,977 - - - - - -

1 1 $1,365 $2,611 $3,855 $4.2 0.0% 96.4% 3.6% 0.0 0.0 

2 2, 3 $1,388 $2,490 $3,467 $17.6 0.0% 96.4% 3.6% 0.2 0.2 

3 4 $1,428 $2,079 $3,392 $75.9 0.0% 22.2% 77.7% 1.8 1.9 

4 5 $1,470 $1,964 $3,291 $176.4 0.0% 0.0% 100.0% 1.6 1.7 

* 	 “No impact” means that the base case forecast commercial clothes washer assigned to the building has greater efficiency 

than the level indicated, so the household is not affected. 

** 	 Based on the payback calculation, a very small change in operating cost can result in a few extremely large paybacks, 

which will skew the average payback. In these cases, median is probably a better indicator. 

12-9 

EERE-2006-STD-0127 COMMENT 66.2
The non-public water and sewer supply users and the small company subgroups show a 

similar trend in average LCC differences and consumer impacts (i.e., percentage of consumers 

significantly or insignificantly impacted) as the overall sample. In general, the benefits of 

moving to a higher efficiency are less in the case of the small business subgroups. 

12-10
 

EERE-2006-STD-0127 COMMENT 66.2
 

 

 

 

 

 

 

 

 

REFERENCES 

1	 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy. Technical 

Support Document: Energy Efficiency Program for Consumer Products and Commercial and 

Industrial Equipment: Residential Dishwashers, Dehumidifiers, Cooking Products, and 

Commercial Clothes Washers, September, 2008. Washington, DC. 

<http://www1.eere.energy.gov/buildings/appliance_standards/residential/home_appl_tsd.html> 

2	 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Energy 

Conservation Standards for Certain Consumer Products (Dishwashers, Dehumidifiers, 

Microwave Ovens, and Electric and Gas Kitchen Ranges and Ovens) and for Certain 

Commercial and Industrial Equipment (Commercial Clothes Washers); Final Rule. Federal 

Register, 2009. 74(66): pp. 16040-16096. 

3	 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy. Technical 

Support Document: Energy Efficiency Program for Consumer Products and Commercial and 

Industrial Equipment: Residential Dishwashers, Dehumidifiers, Cooking Products, and 

Commercial Clothes Washers, March, 2009. Washington, DC. 

<http://www1.eere.energy.gov/buildings/appliance_standards/residential/cooking_products_final_rul 

e_tsd.html> 

4	 Raftelis Financial Consultants, Inc. 2004 RFC/AWWA Water and Wastewater Rate Survey, 

2004. Charlotte, NC, Kansas City, MO, and Pasadena, CA. 

<http://www.raftelis.com/ratessurvey.html> 

5	 National Ground Water Association. Ground Water Use for America. 2005. 

6	 Jerry Stonebridge, National Onsite Wastewater Recycling Association, January 23, 2008. 

Personal communication. 

7	 Ohio Department of Health “Report to the Household and Small Flow Onsite Sewage 

Treatment System Study Commission.” January 1, 2008 

8	 U.S. Government Printing Office. Title 13: Business Credit and Assistance, Part 121—Small 

Business Size Regulations, Section 121.201—Small Business Size Standards by NAICS 

Industry, Subsector 812—Personal and Laundry Services, 812310—Coin-Operated 

Laundries and Drycleaners, 2008. Washington, DC.

 <http://ecfr.gpoaccess.gov/cgi/t/text/textidx?c=ecfr&sid=b6e780955530049be4cc0d0a0e391115&rgn=div5&view=text&node=13:1. 

0.1.1.15&idno=13#13:1.0.1.1.15.1.264.9 > 

9	 U.S. Census Bureau, 2002 Economic Census. Industry Statistics Sampler, NAICS 812310, 

Coin-operated laundries and drycleaners, 2002. Washington, DC. 

<http://www.census.gov/econ/census02/data/industry/E812310.HTM#T2> 

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EERE-2006-STD-0127 COMMENT 66.2
 

 

 

 

10	 U.S. Census Bureau, 2002 Economic Census. Sector 81: Other Services (Except Public 

Administration): Subject Series - Estab & Firm Size: Legal Form of Organization for the 

United States: 2002, 2005. Washington, DC. 

<http://factfinder.census.gov/servlet/IBQTable?_bm=y&-ds_name=EC0281SSSZ7&­

NAICS2002=812310> 

11	 U.S. Census Bureau, 2002 Economic Census. Sector 81: Other Services (Except Public 

Administration): Subject Series - Estab & Firm Size: Receipts/Revenue Size of 

Establishments for the United States: 2002, 2005. Washington, DC. 

<http://factfinder.census.gov/servlet/IBQTable?_bm=y&-ds_name=EC0281SSSZ1&­

NAICS2002=812310> 

12	 Ibbotsons Associates. Stocks, Bonds, Bills, and Inflation 2007 Yearbook, 2007. Chicago, IL. 

13	 Damodaran Online. The Data Page: Cost of Capital by Industry Sector, 2006. 

<http://pages.stern.nyu.edu/~adamodar/> 

12-12
 

EERE-2006-STD-0127 COMMENT 66.2