During the pendency of OIRA review, DOE independently decided to consider energy 

conservation standards for conventional cooking tops and conventional ovens separately, 

and removed conventional cooking tops from the proposed rulemaking. The attached 

draft addresses only energy conservation standards for conventional ovens, including 

conventional ovens that are a part of conventional ranges. Unless otherwise noted, all 

changes shown in the attached draft were made at the recommendation of OIRA.
1

[6450-01-P]

DEPARTMENT OF ENERGY

10 CFR Part 430

[Docket Number EERE–2014–BT–STD–0005]

RIN: 1904–AD15

Energy Conservation Program: Energy Conservation Standards for Residential 

Conventional Ovens

AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION: Notice of proposed rulemaking (NOPR) and public meeting.

SUMMARY: The Energy Policy and Conservation Act of 1975 (EPCA), as amended,

prescribes energy conservation standards for various consumer products and certain 

commercial and industrial equipment, including residential conventional ovens. EPCA 

also requires the U.S. Department of Energy (DOE) to determine whether more-stringent, 

amended standards would be technologically feasible and economically justified, and 

would save a significant amount of energy. In this notice, DOE proposes new and 

amended energy conservation standards for residential conventional ovens. The notice 

also announces a public meeting to receive comment on these proposed standards and 

associated analyses and results.
2

DATES: DOE will hold a public meeting on [Day of week, Month, Day, Year], from 9 

a.m. to 4 p.m., in Washington, DC. The meeting will also be broadcast as a webinar. See 

section VII Public Participation for webinar registration information, participant 

instructions, and information about the capabilities available to webinar participants. 

DOE will accept comments, data, and information regarding this notice of 

proposed rulemaking (NOPR) before and after the public meeting, but no later than

[INSERT DATE 60 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL 

REGISTER]. See section VII Public Participation for details.

ADDRESSES: The public meeting will be held at the U.S. Department of Energy, 

Forrestal Building, Room [NUMBER], 1000 Independence Avenue, SW., Washington,

DC 20585. To attend, please notify Ms. Brenda Edwards at (202) 586–2945Persons can 

attend the public meeting via webinar. For more information, refer to the Public 

Participation section near the end of this notice. 

Any comments submitted must identify the NOPR for Energy Conservation 

Standards for residential conventional cooking products, and provide docket number EE2014–BT–STD–0005 and/or regulatory information number (RIN) number 1904-AD15. 

Comments may be submitted using any of the following methods: 

1. Federal eRulemaking Portal: www.regulations.gov. Follow the instructions for 

submitting comments. 
3

2. E-mail: ConventionalCookingProducts2014STD0005@ee.doe.gov. Include the 

docket number and/or RIN in the subject line of the message.

3. Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies 

Program, Mailstop EE-2J, 1000 Independence Avenue, SW., Washington, DC, 

20585-0121. If possible, please submit all items on a CD. It is not necessary to 

include printed copies.

4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of Energy, 

Building Technologies Program, 950 L’Enfant Plaza, SW., Suite 600, 

Washington, DC, 20024. Telephone: (202) 586-2945. If possible, please submit 

all items on a CD, in which case it is not necessary to include printed copies.

Written comments regarding the burden-hour estimates or other aspects of the 

collection-of-information requirements contained in this proposed rule may be submitted 

to Office of Energy Efficiency and Renewable Energy through the methods listed above 

and by e-mail to Chad_S_Whiteman@omb.eop.gov.

For detailed instructions on submitting comments and additional information on 

the rulemaking process, see section VII of this document (Public Participation).

Docket: The docket, which includes Federal Register notices, public meeting 

attendee lists and transcripts, comments, and other supporting documents/materials, is 

available for review at regulations.gov. All documents in the docket are listed in the 

regulations.gov index. However, some documents listed in the index, such as those 
4

containing information that is exempt from public disclosure, may not be publicly 

available.

A link to the docket web page can be found at: 

http://www.regulations.gov/#!docketDetail;D=EERE-2014-BT-STD-0005. This web 

page will contain a link to the docket for this notice on the regulations.gov site. The 

regulations.gov web page will contain simple instructions on how to access all 

documents, including public comments, in the docket. See section VII for further

information on how to submit comments through www.regulations.gov. 

For further information on how to submit a comment, review other public 

comments and the docket, or participate in the public meeting, contact Ms. Brenda 

Edwards at (202) 586-2945 or by email: Brenda.Edwards@ee.doe.gov.

FOR FURTHER INFORMATION CONTACT: 

Mr. John Cymbalsky, U.S. Department of Energy, Office of Energy Efficiency 

and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence 

Avenue, SW., Washington, DC, 20585-0121. Telephone: (202) 287-1692. E-mail: 

kitchen_ranges_and_ovens@ee.doe.gov.

Ms. Celia Sher, U.S. Department of Energy, Office of the General Counsel, GC33, 1000 Independence Avenue, SW., Washington, DC, 20585-0121. Telephone: (202) 

287-6122. E-mail: Celia.Sher@hq.doe.gov. 
5

SUPPLEMENTARY INFORMATION:

Table of Contents

SUPPLEMENTARY INFORMATION:

Table of Contents

I. Synopsis of the Proposed Rule

A. Benefits and Costs to Consumers

B. Impact on Manufacturers

C. National Benefits and Costs

D. Conclusion

II. Introduction

A. Authority

B. Background

1. Current Standards

2. History of Standards Rulemaking for Residential Conventional Cooking 

Products

III. General Discussion

A. Scope of Coverage

B. Further Rulemaking to Consider Energy Conservation Standards for Conventional 

Cooking Tops

C. Test Procedure

D. Technological Feasibility

1. General

2. Maximum Technologically Feasible Levels

E. Energy Savings

1. Determination of Savings

2. Significance of Savings

F. Economic Justification

1. Specific Criteria

2. Rebuttable Presumption

IV. Methodology and Discussion of Comments

A. Market and Technology Assessment

1. General

2. Product Classes

3. Technology Options

B. Screening Analysis

1. Screened-Out Technologies

2. Remaining Technologies

C. Engineering Analysis

1. Methodology

2. Product Testing and Reverse Engineering
6

3. Efficiency Levels

4. Incremental Manufacturing Production Cost Estimates

5. Consumer Utility

D. Markups Analysis

E. Energy Use Analysis

F. Life-Cycle Cost and Payback Period Analysis

1. Product Costs

2. Installation Costs

3. Unit Energy Consumption

4. Energy Prices

5. Repair and Maintenance Costs

6. Product Lifetime

7. Discount Rates

8. Compliance Date

9. Base Case Efficiency Distribution

10. Inputs to Payback Period Analysis

11. Rebuttable-Presumption Payback Period

G. Shipments Analysis

H. National Impact Analysis

1. Efficiency Trends

2. National Energy Savings

3. Net Present Value of Customer Benefit

I. Consumer Subgroup Analysis

J. Manufacturer Impact Analysis

1. Overview

2. GRIM Analysis and Key Inputs

3. Discussion of Comments

4. Manufacturer Interviews

K. Emissions Analysis

L. Monetizing Carbon Dioxide and Other Emissions Impacts

1. Social Cost of Carbon

2. Social Cost of Other Air Pollutants

M. Utility Impact Analysis

N. Employment Impact Analysis

V. Analytical Results

A. Trial Standard Levels

B. Economic Justification and Energy Savings

1. Economic Impacts on Individual Consumers

2. Economic Impacts on Manufacturers

3. National Impact Analysis

4. Impact on Utility or Performance of Products

5. Impact of Any Lessening of Competition

6. Need of the Nation to Conserve Energy

7. Summary of National Economic Impacts

8. Other Factors

C. Conclusion
7

1. Benefits and Burdens of TSLs Considered for Conventional Ovens

2. Annualized Benefits and Costs of the Proposed Standards

VI. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

B. Review Under the Regulatory Flexibility Act

1. Description and Estimated Number of Small Entities Regulated

2. Description and Estimate of Compliance Requirements

3. Duplication, Overlap, and Conflict with Other Rules and Regulations

4. Significant Alternatives to the Rule

C. Review Under the Paperwork Reduction Act

D. Review Under the National Environmental Policy Act of 1969

E. Review Under Executive Order 13132

F. Review Under Executive Order 12988

G. Review Under the Unfunded Mandates Reform Act of 1995

H. Review Under the Treasury and General Government Appropriations Act, 1999

I. Review Under Executive Order 12630

J. Review Under the Treasury and General Government Appropriations Act, 2001

K. Review Under Executive Order 13211

L. Review Under the Information Quality Bulletin for Peer Review

VII. Public Participation

A. Attendance at the Public Meeting

B. Procedure for Submitting Prepared General Statements For Distribution

C. Conduct of the Public Meeting

D. Submission of Comments

E. Issues on Which DOE Seeks Comment

VIII. Approval of the Office of the Secretary

I. Synopsis of the Proposed Rule

Title III, Part B1 of the Energy Policy and Conservation Act of 1975 (EPCA or 

the Act), Pub. L. 94-163 (42 U.S.C. 6291-6309, as codified), established the Energy 

Conservation Program for Consumer Products Other Than Automobiles.2 These 

products include residential conventional ovens, the subject of this rulemaking.

 1

 For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A. 2 All references to EPCA in this document refer to the statute as amended through the American Energy 

Manufacturing Technical Corrections Act (AEMTCA), Pub. L. 112-210 (Dec. 18, 2012).
8

Pursuant to EPCA, any new or amended energy conservation standard must be 

designed to achieve the maximum improvement in energy efficiency that is 

technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A))

Furthermore, the new or amended standard must result in a significant conservation of 

energy. (42 U.S.C. 6295(o)(3)(B)) In accordance with these and other statutory 

provisions discussed in this notice, DOE proposes new and amended energy conservation 

standards for residential conventional ovens. The proposed standards, which are the 

maximum allowable integrated annual energy consumption (IAEC), are shown in Table 

I-1. The integrated annual energy consumption includes active mode (including fan-only 

mode for conventional ovens), standby mode, and off mode energy use. These proposed 

standards, if adopted, would apply to all products listed in Table I-1 and manufactured in, 

or imported into, the United States on or after the date three years after the publication of 

any final rule for this rulemaking. The proposed standards correspond to trial standard 

level (TSL) 2, which is described in section V.A. DOE also notes that any newly adopted 

performance standards for conventional ovens resulting from this current rulemaking 

would not affect the current prescriptive standards prohibiting constant burning pilots for 

all gas cooking products (10 CFR 430.32(j)).
9

Table I -1. Proposed Energy Conservation Standards for Conventional Ovens

Product Class

Maximum Integrated Annual 

Energy Consumption (IAEC)

Electric Standard Oven, Free-standing 122.5 + (31.8 × Rated Cavity 

Volume in cubic feet) kWh/yr

Electric Standard Oven, Built-In/Slide-In 128.6 + (31.8 × Rated Cavity 

Volume in cubic feet) kWh/yr

Electric Self-Clean Oven, Free-Standing 163.2 + (42.3 × Rated Cavity 

Volume in cubic feet) kWh/yr

Electric Self-Clean Oven, Built-In/Slide-In 169.1 + (42.3 × Rated Cavity 

Volume in cubic feet) kWh/yr

Gas Standard Oven, Free-Standing 492.9 + (214.4 × Rated Cavity 

Volume in cubic feet) kWh/yr

Gas Standard Oven, Built-In/Slide-In 499.5 + (214.4 × Rated Cavity 

Volume in cubic feet) kWh/yr

Gas Self-Clean Oven, Free-Standing 746.7 + (214.4 × Rated Cavity 

Volume in cubic feet) kWh/yr

Gas Self-Clean Oven, Built-In/Slide-In 755.5 + (214.4 × Rated Cavity 

Volume in cubic feet) kWh/yr

Note: The Rated Cavity Volume is the volume of the oven cavity in cubic feet as measured using the final 

DOE test procedure at 10 CFR part 430, subpart B, appendix I.

As discussed in section III.B, DOE has decided to defer its decision regarding 

whether to adopt amended energy conservation standards for conventional cooking tops, 

pending further rulemaking. In both the test procedure NOPR published on January 30, 

2013 (78 FR 6232, the January 2013 TP NOPR) and the test procedure supplemental 

NOPR (SNOPR) published on December 3, 2014 (79 FR 71894, the December 2014 TP 

SNOPR), DOE proposed amendments to the cooking products test procedure in 

Appendix I to subpart B of Title 10 of the CFR part 430 that would allow for the testing 

of active mode energy consumption of induction cooking tops. After reviewing public 

comments on the December 2014 TP SNOPR, conducting interviews with manufacturers, 

and performing additional analyses, DOE believes further study is required before a 

cooking top test procedure can be established that produces test results which measure 

energy use during a representative average use cycle, is repeatable and reproducible, and 
10

is not unduly burdensome to conduct. For these reasons, this NOPR is limited to 

addressing energy conservation standards for conventional ovens. As discussed in section 

III.A, the proposed standards would cover conventional ovens, including conventional 

ovens that are a part of conventional ranges. DOE intends to complete the rulemaking 

process for conventional cooking tops once additional key data and information become 

available.

A. Benefits and Costs to Consumers

Table I-2 presents DOE’s evaluation of the economic impacts of the proposed 

standards on consumers of residential conventional ovens, as measured by the average 

life-cycle cost (LCC) savings and the simple payback period (PBP).3 The average LCC 

savings are positive for all product classes, and the PBP is less than the average lifetime 

of the equipment, which is estimated to be 15 years for electric and 17 years for gas 

ovens. 

Table I-2. Impacts of Proposed Energy Conservation Standards (TSL 2) on 

Consumers of Residential Conventional Ovens

Product Class Average LCC Savings*

(2014$)

Simple Payback Period 

(years)

 3 The average LCC savings are measured relative to the base-case efficiency distribution, which depicts the 

market in the compliance year (see section IV.F.9). The simple PBP, which is designed to compare specific 

efficiency levels, is measured relative to the baseline model.
11

Electric Standard Oven, 

Free-standing $15.18 4.0

Electric Standard Oven, 

Built-in/Slide-in $15.25 4.0

Electric Self-Clean Oven, 

Free-Standing $14.10 0.9

Electric Self-Clean Oven, 

Built-in/Slide-in $14.20 0.9

Gas Standard Oven, FreeStanding $289.73 1.7

Gas Standard Oven, Builtin/Slide-in $289.77 1.7

Gas Self-Clean Oven, 

Free-Standing $282.80 1.2

Gas Self-Clean Oven, 

Built-In/Slide-in $282.85 1.2

*Calculation does not include households with zero LCC savings (no impact) 

DOE’s analysis of the impacts of the proposed standards on consumers is 

described in section IV.F of this notice.

B. Impact on Manufacturers

The industry net present value (INPV) is the sum of the discounted cash flows to 

the industry from the base year through the end of the analysis period (2015 to 2048). 

Using a real discount rate of 9.1 percent, DOE estimates that the industry net present 

value (INPV) for manufacturers of residential conventional ovens is $783.5 million in 

2014$. Under the proposed standards, DOE expects that manufacturers may lose up to 

11.0 percent of their INPV, which is approximately $86.4 million in 2014$. Additionally, 

based on DOE’s interviews with the manufacturers of residential conventional ovens, 

DOE does not expect any plant closings or significant loss of employment.
12

DOE’s analysis of the impacts of the proposed standards on manufacturers is 

described in section IV.J of this NOPR notice.

C. National Benefits and Costs4

DOE’s analyses indicate that the proposed standards would save a significant 

amount of energy. The lifetime energy savings from residential conventional oven 

products purchased in the 30-year period that begins in the assumed year of compliance 

with the proposed standards (2019–2048), relative to the base case without the proposed 

standards, amount to 0.71 quadrillion Btu (quads).5 This represents a savings of 11.2

percent relative to the energy use of these products in the base case.

The cumulative net present value (NPV) of total consumer costs and savings of

the proposed standards for ovens in residential conventional cooking products ranges 

from $4.7 billion (at a 7-percent discount rate) to $11.0 billion (at a 3-percent discount 

rate). This NPV expresses the estimated total value of future operating-cost savings 

minus the estimated increased product costs for products purchased in 2019–2048. 

In addition, the proposed standards would have significant environmental 

benefits. The energy savings described above are estimated to result in cumulative 

 4 All monetary values in this section are expressed in 2013 dollars and, where appropriate, are discounted to 

2014.

5 A quad is equal to 1015 British thermal units (Btu). The quantity refers to full-fuel-cycle (FFC) energy 

savings. FFC energy savings includes the energy consumed in extracting, processing, and transporting 

primary fuels (i.e., coal, natural gas, petroleum fuels), and thus presents a more complete picture of the 

impacts of energy efficiency standards. For more information on the FFC metric, see section IV.H.2.

A quad is equal to 1015 British thermal units (Btu).
13

emission reductions of 41.1 million metric tons (Mt)6 of carbon dioxide (CO2), 221.2

thousand tons of methane, 29.5 thousand tons of sulfur dioxide (SO2), 69 thousand tons 

of nitrogen oxides (NOX), 0.52 thousand tons of nitrous oxide (N2O), and 0.09 tons of 

mercury (Hg).7 The cumulative reduction in CO2 emissions through 2030 amounts to 7.5

Mt, which is equivalent to the emissions resulting from the annual electricity use of 0.7

million homes.

The value of the CO2 reductions is calculated using a range of values per metric 

ton of CO2 (otherwise known as the Social Cost of Carbon, or SCC) developed by a 

recent Federal interagency process.8 The derivation of the SCC values is discussed in 

section IV.L. Using discount rates appropriate for each set of SCC values (see Table I-4), 

DOE estimates the present monetary value of the CO2 emissions reduction is between 

$0.3 billion and $4.1 billion, with a value of $1.3 billion using the central SCC case 

represented by $41.2/t in 2015.

9 DOE also estimates the present monetary value of the 

NOX emissions reduction, is $0.1 billion at a 7-percent discount rate and $0.2 billion at a 

3-percent discount rate.10

 6 A metric ton is equivalent to 1.1 short tons. Results for emissions other than CO2 are presented in short 

tons.

7 DOE calculated emissions reductions relative to the Annual Energy Outlook 2014 (AEO 2014) Reference 

case, which generally represents current legislation and environmental regulations for which implementing 

regulations were available as of October 31, 2013.

8 Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 

12866. Interagency Working Group on Social Cost of Carbon, United States Government. May 2013; 

revised November 2013. http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technicalupdate-social-cost-of-carbon-for-regulator-impact-analysis.pdf. 9 The values only include CO2 emissions, not CO2 equivalent emissions; other gases with global warming 

potential are not included.

10 DOE is currently investigating valuation of avoided Hg and SO2 emissions.
14

Table I-3 summarizes the national economic costs and benefits expected to result 

from the proposed standards for residential conventional ovens.

Table I-3. Summary of National Economic Benefits and Costs of Proposed Energy 

Conservation Standards for Residential Conventional Ovens*

Category

Present 

Value

Billion 2014$

Discount 

Rate

Benefits

Operating Cost Savings 5.0 7%

11.6 3%

CO2 Reduction Monetized Value ($12.2.0/t case)** 0.3 5%

CO2 Reduction Monetized Value ($41.2/t case)** 1.3 3%

CO2 Reduction Monetized Value ($63.4/t case)** 2.1 2.5%

CO2 Reduction Monetized Value ($121/t case)** 4.1 3%

NOX Reduction Monetized Value†

0.1 7%

0.2 3%

Total Benefits††

6.4 7%

13.2 3%

Costs

Incremental Installed Costs 0.3 7%

0.6 3%

Total Net Benefits

Including Emissions Reduction Monetized Value†† 6.1 7%

12.6 3%

* This table presents the costs and benefits associated with residential conventional ovens shipped in 

2019−2048. These results include impacts to consumers which accrue after 2048 from the products 

purchased in 2019−2048. The results account for the incremental variable and fixed costs incurred by 

manufacturers due to any final standard, some of which may be incurred in preparation for the rule. 

** The CO2 values represent global monetized values of the SCC, in 2014$, in 2015 under several 

scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated 

using 5%, 3%, and 2.5% discount rates, respectively. The fourth case represents the 95th percentile of the 

SCC distribution calculated using a 3% discount rate. The SCC time series incorporate an escalation factor. 

† The $/ton values used for NOX are described in section IV.L.2.

†† Total Benefits for both the 3% and 7% cases are derived using the series corresponding to average SCC 

with 3-percent discount rate ($40.5/t case).
15

The benefits and costs of these proposed standards, for products sold in 2019-

2048, can also be expressed in terms of annualized values. The annualized monetary 

values are the sum of (1) the annualized national economic value of the benefits from 

consumer operation of products that meet the new or amended standards (consisting 

primarily of operating cost savings from using less energy, minus increases in equipment 

purchase and installation costs, which is another way of representing consumer NPV), 

and (2) the annualized monetary value of the benefits of emission reductions, including 

CO2 emission reductions.11

Although combiningDOE believes that the values of operating savings and CO2

emission reductions provides a useful perspectiveare both important, two issues should be 

consideredare relevant. First, the national operating savings are domestic U.S. consumer 

monetary savings that occur as a result of market transactions, whereas the value of CO2

reductions is based on a global value. Second, the assessments of operating cost savings 

and CO2 savings are performed with different methods that use different time frames for 

analysis. The national operating cost savings is measured for the lifetime of residential 

conventional cooking productsovens shipped in 2019–2048. Because CO2 emissions 

 11 To convert the time-series of costs and benefits into annualized values, DOE calculated a present value in 

2014, the year used for discounting the NPV of total consumer costs and savings. For the benefits, DOE 

calculated a present value associated with each year’s shipments in the year in which the shipments occur 

(e.g., 2020 or 2030), and then discounted the present value from each year to 2014. The calculation uses

discount rates of 3 and 7 percent for all costs and benefits except for the value of CO2 reductions, for which 

DOE used case-specific discount rates, as shown in Table I.3. Using the present value, DOE then calculated 

the fixed annual payment over a 30-year period, starting in the compliance year that yields the same present 

value.
16

have a very long residence time in the atmosphere,12 the SCC values in future years 

reflect future climate-related impacts resulting from the emission of CO2 that continue 

well beyond 2100.

Estimates of annualized benefits and costs of the proposed standards are shown in 

Table I-4. The results under the primary estimate are as follows. Using a 7-percent 

discount rate for benefits and costs other than CO2 reduction, for which DOE used a 3-

percent discount rate along with the average SCC series that has a value of $40.541.2/t in 

2015, the cost of the proposed standards is $33.15 million per year in increased 

equipment costs, while the benefits are $631494 million per year in reduced equipment 

operating costs, $13174 million in CO2 reductions, and $9 million in reduced NOX

emissions. In this case, the net benefit amounts to $738543 million per year. Using a 3-

percent discount rate for all benefits and costs and the average SCC series that has a value 

of $41.2/t in 2015, the cost of the proposed standards is $33.1 million per year in 

increased equipment costs, while the benefits are $648 million per year in reduced 

operating costs, $74 million in CO2 reductions, and $13 million in reduced NOX

emissions. In this case, the net benefit amounts to $701 million per year.

 12 The atmospheric lifetime of CO2 is estimated of the order of 30–95 years. Jacobson, MZ (2005). 

"Correction to "Control of fossil-fuel particulate black carbon and organic matter, possibly the most 

effective method of slowing global warming."" J. Geophys. Res. 110. pp. D14105.
17

Table I-4. Annualized Benefits and Costs of Proposed Energy Conservation 

Standards for Residential Conventional Ovens

Discount Rate

Primary 

Estimate*

Low Net 

Benefits 

Estimate*

High Net 

Benefits 

Estimate*

million 2014$/year

Benefits

Operating Cost Savings

7% 494 457 542

3% 648 593 719

CO2 Reduction Monetized 

Value ($12.02/t case)* 5% 21 20 24

CO2 Reduction Monetized 

Value ($40.541.2/t case)* 3% 74 68 81

CO2 Reduction Monetized 

Value ($6263.4/t case)* 2.5% 108 100 119

CO2 Reduction Monetized 

Value ($119121/t case)* 3% 228 211 252

NOX Reduction Monetized 

Value† 

7% 9.24 8.66 10.11

3% 13.43 12.46 14.80

Total Benefits††

7% plus CO2

range

524 to 731 485 to 677 576 to 804

7% 577 534 634

3% plus CO2

range

682 to 889 625 to 817 758 to 986

3% 734 674 815

Costs

Consumer Incremental 

Product Costs

7% 34 34 33

3% 33 34 33

Net Benefits

Total††

7% plus CO2

range

491 to 697 451 to 642 543 to 771

7% 543 499 601

3% plus CO2

range

649 to 856 592 to 783 725 to 953

3% 701 640 783
18

* This table presents the annualized costs and benefits associated with residential conventional ovens

shipped in 2019−2048. These results include benefits to consumers which accrue after 2048 from the 

products purchased in 2014−2043. The results account for the incremental variable and fixed costs incurred 

by manufacturers due to any final standard, some of which may be incurred in preparation for the rule. The 

Primary, Low Benefits, and High Benefits Estimates utilize projections of energy prices from the AEO 

201513 Reference case, Low Estimate, and High Estimate, respectively. In addition, incremental product 

costs reflect a medium decline rate in the Primary Estimate, a low decline rate in the Low Benefits 

Estimate, and a high decline rate f in the High Benefits Estimate. The methods used to derive projected 

price trends are explained in section IV.F.1.

** The CO2 values represent global monetized values of the SCC, in 2014$, in 2015 under several 

scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated 

using 5%, 3%, and 2.5% discount rates, respectively. The fourth case represents the 95th percentile of the 

SCC distribution calculated using a 3% discount rate. The SCC time series incorporate an escalation factor. 

† The $/ton values used for NOX are described in section IV.L.2.

†† Total Benefits for both the 3% and 7% cases are derived using the series corresponding to the average 

SCC with 3-percent discount rate ($41.2/t case). In the rows labeled “7% plus CO2 range” and “3% plus 

CO2 range,” the operating cost and NOX benefits are calculated using the labeled discount rate, and those 

values are added to the full range of CO2 values.

DOE’s analysis of the national impacts of the proposed standards is described in 

sections IV.H, IV.K and IV.L of this notice.

D. Conclusion

DOE has tentatively concluded that the proposed standards represent the 

maximum improvement in energy efficiency that is technologically feasible and 

economically justified, and would result in the significant conservation of energy. DOE 

further notes that products achieving these standard levels are already commercially 

available for at least some, if not most, product classes covered by this proposal. Based 

on the analyses described above, DOE has tentatively concluded that the benefits of the 

proposed standards to the Nation (energy savings, positive NPV of consumer benefits, 

 13 http://www.eia.gov/forecasts/AEO/
19

consumer LCC savings, and emission reductions) would outweigh the burdens (loss of 

INPV for manufacturers and LCC increases for some consumers). 

DOE also considered more-stringent energy efficiency levels as trial standard 

levels, and is considering them in this rulemaking. However, DOE has tentatively 

concluded that the potential burdens of the more-stringent energy efficiency levels would 

outweigh the projected benefits. Based on consideration of the public comments DOE 

receives in response to this notice and related information collected and analyzed during 

the course of this rulemaking effort, DOE may adopt energy efficiency levels presented 

in this notice that are either higher or lower than the proposed standards, or some 

combination of level(s) that incorporate the proposed standards in part.

II. Introduction

The following section briefly discusses the statutory authority underlying this

proposal, as well as some of the relevant historical background related to the 

establishment of standards for residential cooking products.

A. Authority

Title III, Part B of the Energy Policy and Conservation Act of 1975 (EPCA or the 

Act), Pub. L. 94-163 (42 U.S.C. 6291-6309, as codified) established the Energy 

Conservation Program for Consumer Products Other Than Automobiles, a program 

covering most major household appliances (collectively referred to as “covered 
20

products”), which includes residential cooking products14, and specifically residential 

conventional ovens, that are the subject of this rulemaking. (42 U.S.C. 6292(a)(10)) 

EPCA prescribed energy conservation standards for these products (42 U.S.C. 

6295(h)(1)), and directed DOE to conduct rulemakings to determine whether to amend

these standards. (42 U.S.C. 6295(h)(2)) (DOE notes that under 42 U.S.C. 6295(m), the 

agency must periodically review its already established energy conservation standards for 

a covered product. Under this requirement, the next review that DOE would need to 

conduct must occur no later than six years from the issuance of a final rule establishing or 

amending a standard for a covered product.)

Pursuant to EPCA, DOE’s energy conservation program for covered products 

consists essentially of four parts: (1) testing; (2) labeling; (3) the establishment of Federal 

energy conservation standards; and (4) certification and enforcement procedures. The 

Federal Trade Commission (FTC) is primarily responsible for labeling, and DOE 

implements the remainder of the program. Subject to certain criteria and conditions, DOE 

is required to develop test procedures to measure the energy efficiency, energy use, or 

estimated annual operating cost of each covered product. (42 U.S.C. 6293) Manufacturers 

of covered products must use the prescribed DOE test procedure as the basis for 

certifying to DOE that their products comply with the applicable energy conservation 

standards adopted under EPCA and when making representations to the public regarding 

 14 DOE’s regulations define kitchen ranges and ovens, or “cooking products”, as one of the following 

classes: conventional ranges, conventional cooking tops, conventional ovens, microwave ovens, 

microwave/conventional ranges and other cooking products. (10 CFR 430.2) Based on this definition, in 

this notice, DOE interprets kitchen ranges and ovens to refer more generally to all types of cooking 

products including, for example, microwave ovens.
21

the energy use or efficiency of those products. (42 U.S.C. 6293(c) and 6295(s)) Similarly, 

DOE must use these test procedures to determine whether the products comply with 

standards adopted pursuant to EPCA. Id. The DOE test procedures for residential 

conventional cooking products currently appear at title 10 of the Code of Federal 

Regulations (CFR) part 430, subpart B, appendix I (Appendix I). 

DOE must follow specific statutory criteria for prescribing new or amended 

standards for covered products. As indicated above, any new or amended standard for a 

covered product must be designed to achieve the maximum improvement in energy 

efficiency that is technologically feasible and economically justified. (42 U.S.C. 

6295(o)(2)(A)) Furthermore, DOE may not adopt any standard that would not result in

the significant conservation of energy. (42 U.S.C. 6295(o)(3)) Moreover, DOE may not 

prescribe a standard: (1) for certain products, including residential conventional ovens, if 

no test procedure has been established for the product, or (2) if DOE determines by rule 

that the standard is not technologically feasible or economically justified. (42 U.S.C. 

6295(o)(3)(A)–(B)) In deciding whether a standard is economically justified, DOE must 

determine whether the benefits of the standard exceed its burdens. (42 U.S.C. 

6295(o)(2)(B)(i)) DOE must make this determination after receiving comments on the 

proposed standard, and by considering, to the greatest extent practicable, the following 

seven statutory factors:

1. The economic impact of the standard on manufacturers and consumers of the 

products subject to the standard;
22

2. The savings in operating costs throughout the estimated average life of the 

covered products in the type (or class) compared to any increase in the price, initial 

charges, or maintenance expenses for the covered products that are likely to result from 

the imposition of the standard; 

3. The total projected amount of energy, or as applicable, water, savings likely to 

result directly from the imposition of the standard;

4. Any lessening of the utility or the performance of the covered 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 and water conservation; and

7. Other factors the Secretary of Energy (Secretary) considers relevant. (42 U.S.C. 

6295(o)(2)(B)(i)(I)–(VII))

EPCA, as codified, also contains what is known as an “anti-backsliding” 

provision, which prevents the Secretary from prescribing any amended standard that 

either increases the maximum allowable energy use or decreases the minimum required 

energy efficiency of a covered product. (42 U.S.C. 6295(o)(1)) Also, the Secretary may 

not prescribe an amended or new standard if interested persons have established by a 

preponderance of the evidence that the standard is likely to result in the unavailability in 

the United States of any covered product type (or class) of performance characteristics

(including reliability), features, sizes, capacities, and volumes that are substantially the 

same as those generally available in the United States. (42 U.S.C. 6295(o)(4))
23

Further, EPCA, as codified, establishes a rebuttable presumption that a standard is 

economically justified if the Secretary finds that the additional cost to the consumer of 

purchasing a product complying with an energy conservation standard level will be less 

than three times the value of the energy savings during the first year that the consumer 

will receive as a result of the standard, as calculated under the applicable test procedure. 

(42 U.S.C. 6295(o)(2)(B)(iii))

Additionally, 42 U.S.C. 6295(q)(1) specifies requirements when promulgating a 

standard for a type or class of covered product that has two or more subcategories. DOE 

must specify a different standard level than that which applies generally to such type or 

class of products for any group of covered products that have the same function or 

intended use if DOE determines that products within such group (A) consume a different 

kind of energy from that consumed by other covered products within such type (or class); 

or (B) have a capacity or other performance-related feature which other products within 

such type (or class) do not have and such feature justifies a higher or lower standard. (42 

U.S.C. 6294(q)(1)) In determining whether a performance-related feature justifies a 

different standard for a group of products, DOE must consider such factors as the utility 

to the consumer of the feature and other factors DOE deems appropriate. Id. Any rule 

prescribing such a standard must include an explanation of the basis on which such 

higher or lower level was established. (42 U.S.C. 6295(q)(2))
24

Federal energy conservation requirements generally supersede State laws or 

regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 

6297(a)–(c)) DOE may, however, grant waivers of Federal preemption for particular 

State laws or regulations, in accordance with the procedures and other provisions set forth 

under 42 U.S.C. 6297(d)).

Finally, pursuant to the amendments contained in section 310(3) of EISA 2007,

any final rule for new or amended energy conservation standards promulgated after July 

1, 2010, are required to address standby mode and off mode energy use. (42 U.S.C. 

6295(gg) (3)) Specifically, when DOE adopts a standard for a covered product after that 

date, it must, if justified by the criteria for adoption of standards under EPCA (42 U.S.C. 

6295(o)), incorporate standby mode and off mode energy use into the standard, or, if that 

is not feasible, adopt a separate standard for such energy use for that product. (42 U.S.C. 

6295(gg)(3)(A)–(B)) DOE’s current test procedures for residential conventional cooking 

products address standby mode and off mode energy use. In this rulemaking, DOE 

intends to incorporate such energy use into any amended energy conservation standards it 

adopts in the final rule. 

DOE has also reviewed this proposed regulation pursuant to Executive Order 

13563. 76 FR 3281 (Jan. 21, 2011). EO 13563 is supplemental to and explicitly reaffirms 

the principles, structures, and definitions governing regulatory review established in 

Executive Order 12866. To the extent permitted by law, agencies are required by 

Executive Order 13563 to: (1) propose or adopt a regulation only upon a reasoned 
25

determination that its benefits justify its costs (recognizing that some benefits and costs 

are difficult to quantify); (2) tailor regulations to impose the least burden on society, 

consistent with obtaining regulatory objectives, taking into account, among other things, 

and to the extent practicable, the costs of cumulative regulations; (3) select, in choosing 

among alternative regulatory approaches, those approaches that maximize net benefits 

(including potential economic, environmental, public health and safety, and other 

advantages; distributive impacts; and equity); (4) to the extent feasible, specify 

performance objectives, rather than specifying the behavior or manner of compliance that 

regulated entities must adopt; and (5) identify and assess available alternatives to direct 

regulation, including providing economic incentives to encourage the desired behavior, 

such as user fees or marketable permits, or providing information upon which choices can 

be made by the public. 

DOE emphasizes as well that Executive Order 13563 requires agencies to use the 

best available techniques to quantify anticipated present and future benefits and costs as 

accurately as possible. In its guidance, the Office of Information and Regulatory Affairs 

has emphasized that such techniques may include identifying changing future compliance 

costs that might result from technological innovation or anticipated behavioral changes.

For the reasons stated in the preamble, DOE believes that the NOPR is consistent with 

these principles, including the requirement that, to the extent permitted by law, benefits 

justify costs and that net benefits are maximized. Consistent with EO 13563, and the 

range of impacts analyzed in this rulemaking, the energy efficiency standards proposed 
26

herein by DOE achieve maximum net benefits. For further discussion of how this NOPR

achieves maximum net benefits, see section V.

B. Background

1. Current Standards

In a final rule published on April 8, 2009 (April 2009 Final Rule), DOE 

prescribed the current energy conservation standards for residential cooking products to 

prohibit constant burning pilots for all gas cooking products (i.e., gas cooking products 

both with or without an electrical supply cord) manufactured on or after April 9, 2012. 74 

FR 16040, 16041–16044. DOE's regulations, codified at 10 CFR 430.2, define 

conventional cooking tops, conventional ovens, and conventional ranges as classes of 

cooking products. As noted in the April 2009 Final Rule, DOE considered standards for 

conventional cooking tops and conventional ovens separately, and noted that any cooking 

top or oven standard would apply to the individual components of the conventional range. 

74 FR 16040, 16053. 

Based on DOE’s review of gas cooking products available on the market in the 

United States, DOE notes that there may be confusion regarding how the current 

standards apply to different pilot ignition systems. Specifically, DOE is aware of a gas 

range that is designed to heat and cook food based on the principle of heat storage. A low 

input rate burner continuously heats the cooking top surface and cast iron oven cavities, 

and maintains these components at a constant temperature. A secondary “pilot burner” is 

used to ignite the main burner and this pilot remains lit between cooking cycles as well as 
27

when the main burner is shut off for short periods of non-use. Although the secondary 

pilot may provide additional heating to the body of the range, its primary function is to 

ignite the main burner, and would thus be considered a constant burning pilot because it 

is a continuous gas flame used to ignite the gas at the main burner. It is the main burner 

that provides the primary source of heat for the cooking function of the range. 

In this NOPR, DOE is clarifying that a constant burning pilot in conventional 

cooking products is considered to be a continuous gas flame having the primary purpose 

to ignite the gas at the burner(s) that is (are) used to heat or cook food and which remains 

lit between cooking cycles. The design and configuration, including whether it 

incorporates any air premixing or whether it has a secondary heating function, does not 

exclude the device from consideration as constant burning pilot.

DOE also notes that any newly adopted performance standards for conventional 

cooking products resulting from this current rulemaking would not affect the current 

prescriptive standards prohibiting constant burning pilots for all gas cooking products.

2. History of Standards Rulemaking for Residential Conventional Cooking Products

The National Appliance Energy Conservation Act of 1987 (NAECA), Pub. L. No. 

100-12, amended EPCA to establish prescriptive standards for gas cooking products, 

requiring gas ranges and ovens with an electrical supply cord that are manufactured on or 

after January 1, 1990, not to be equipped with a constant burning pilot light. NAECA also 

directed DOE to conduct two cycles of rulemakings to determine if more stringent or 
28

additional standards were justified for kitchen ranges and ovens. (42 U.S.C. 6295 (h)(1)–

(2))

DOE undertook the first cycle of these rulemakings and published a final rule on 

September 8, 1998, which found that no standards were justified for conventional electric 

cooking products at that time. In addition, partially due to the difficulty of conclusively 

demonstrating that elimination of standing pilots for conventional gas cooking products 

without an electrical supply cord was economically justified, DOE did not include 

amended standards for conventional gas cooking products in the final rule. 63 FR 48038. 

For the second cycle of rulemakings, DOE published the April 2009 Final Rule

amending the energy conservation standards for conventional cooking products to 

prohibit constant burning pilots for all gas cooking products (i.e., gas cooking products 

both with or without an electrical supply cord) manufactured on or after April 9, 2012.

DOE decided to not adopt energy conservation standards pertaining to the cooking 

efficiency of conventional electric cooking products because it determined that such 

standards would not be technologically feasible and economically justified at that time. 

74 FR 16040, 16041–16044.15

EPCA also requires that, not later than 6 years after the issuance of a final rule 

establishing or amending a standard, DOE publish a NOPR proposing new standards or a 

notice of determination that the existing standards do not need to be amended. (42 U.S.C. 

 15 As part of the April 2009 Final Rule, DOE decided not to adopt energy conservation standards pertaining 

to the cooking efficiency of microwave ovens. DOE also published a final rule on June 17, 2013 adopting 

energy conservation standards for microwave oven standby mode and off mode. 78 FR 36316. DOE is not 

considering energy conservation standards for microwave ovens as part of this rulemaking. 
29

6295(m)(1)) Based on this provision, DOE must publish by March 31, 2015, either a 

NOPR proposing new standards for conventional electric cooking products and/or 

amended standards for conventional gas cooking products16 or a notice of determination 

that the existing standards do not need to be amended.

On February 12, 2014, DOE published a request for information (RFI) notice (the 

February 2014 RFI) to initiate the mandatory review process imposed by EPCA. As part 

of the RFI, DOE sought input from the public to assist with its determination on whether 

new or amended standards pertaining to conventional cooking products are warranted. 79 

FR 8337. In making this determination, DOE must evaluate whether new or amended 

standards would (1) yield a significant savings in energy use and (2) be both 

technologically feasible and economically justified. (42 U.S.C. 6295(o)(3)(B))

III. General Discussion

A. Scope of Coverage

As discussed in section II.A, 6292(a)(10) of EPCA covers kitchen ranges and 

ovens, or “cooking products.” DOE’s regulations define “cooking products” as consumer 

products that are used as the major household cooking appliances. They are designed to 

cook or heat different types of food by one or more of the following sources of heat: gas, 

electricity, or microwave energy. Each product may consist of a horizontal cooking top 

 16 As discussed in section III.A, DOE is also tentatively planning to consider new energy conservation 

standards for gas cooking products with higher burner input rates, which were previously excluded from 

standards.
30

containing one or more surface units17 and/or one or more heating compartments. They 

must be one of the following classes: conventional ranges, conventional cooking tops, 

conventional ovens, microwave ovens, microwave/conventional ranges and other cooking 

products. (10 CFR 430.2) In this NOPR, DOE is considering energy conservation 

standards for certain residential conventional cooking products, namely, conventional 

ovens.

DOE notes that conventional ranges are defined in 10 CFR 430.2 as a class of

kitchen ranges and ovens which is a household cooking appliance, consisting of a 

conventional cooking top and one or more conventional ovens. In this rulemaking, DOE 

is not considering gas and electric conventional ranges as a distinct product category and 

is not basing its product classes on that category. Instead, DOE plans to consider energy 

conservation standards for conventional cooking tops and conventional ovens separately. 

Because ranges consist of both a cooking top and oven, any potential cooking top or oven 

standards would apply to the individual components of the range. DOE invites comment 

on its proposal to develop two distinct component standards under separate timetables, 

and whether issues of product design and development, consumer utility, and more 

broadly, cumulative regulatory burden concerns that could arise as a result of its proposal 

(see sections IV.J and VII.E). DOE anticipates issuing a NOPR for energy conservation 

standards for cooktops in the next year. In this NOPR, DOE is proposing to clarify in 

the definitions of conventional cooking tops and conventional ovens, in 10 CFR 430.2, 

that these include the individual cooking top or oven portion of a conventional range.

 17 The term surface unit refers to burners for gas cooking tops, electric resistance heating elements for 

electric cooking tops, and inductive heating elements for induction cooking tops.
31

As part of the most recent standards rulemaking for conventional cooking 

products, DOE decided to exclude residential conventional gas cooking products with 

higher burner input rates, including products marketed as “commercial-style” or 

“professional-style,” from consideration of energy conservation standards due to a lack of 

available data for determining efficiency characteristics of those products. DOE considers 

these products to be gas cooking tops with burner input rates greater than 14,000 British 

thermal units (Btu)/hour (h) and gas ovens with burner input rates greater than 22,500 

Btu/h. 74 FR 16040, 16054 (Apr. 8, 2009); 72 FR 64432, 64444–64445 (Nov. 15, 2007). 

DOE also stated that the current DOE cooking products test procedures may not

adequately measure performance of gas cooking tops and ovens with higher burner input 

rates. 72 FR 64432, 64444–64445 (Nov. 15, 2007).

As part of the February 2014 RFI, DOE stated that it tentatively planned to 

consider energy conservation standards for all residential conventional cooking products, 

including gas cooking products with higher burner input rates. In addition, DOE stated 

that it may consider developing test procedures for these products and determine whether 

separate product classes are warranted. 79 FR 8337, 8340 (Feb. 12, 2014).

The Association of Home Appliance Manufacturers (AHAM) and Whirlpool 

Corporation (Whirlpool) commented that because there is no test procedure to test 

commercial-style products, they cannot effectively comment on how these products 

should be treated in a standards rulemaking, nor can DOE effectively evaluate their 
32

energy use. (AHAM, STD No. 9 at p. 218; Whirlpool, STD No. 13 at p. 2) AHAM added 

that nothing has changed since DOE determined in the April 2009 Final Rule that it lacks 

efficiency data to determine whether commercial-style cooking products should be 

excluded from the rulemaking, and thus, DOE cannot make a tentative conclusion to 

consider energy conservation standards for commercial-style products. (AHAM, STD 

No. 9 at pp. 2–3) In response to the December 2014 TP SNOPR, Sub Zero Group, Inc. 

(Sub Zero) stated that DOE's conclusion that the existing test procedure in Appendix I 

should be used to test ovens with high input rates is incorrect. Sub Zero commented that,

due to the lack of data, complexity, and small potential for energy savings, DOE should

exempt commercial-style or “high performance” products from coverage. (Sub Zero, TP 

No. 20 at p. 319) 

Pacific Gas and Electric Company (PG&E), Southern California Gas Company 

(SCGC), San Diego Gas and Electric (SDG&E), and Southern California Edison (SCE) 

(collectively, the California investor-owned utilities (IOUs)) supported DOE’s decision to 

consider standards for professional-style gas cooking products and commented that DOE 

should refer to American National Standards Institute (ANSI) Standard Z83.11-

2006/CSA Standard 1.8-2006 (R2011), “Gas Food Service Equipment,” when developing 

a definition for these products. (California IOUs, STD No. 11 at p. 1)

 18 A notation in the form “AHAM, STD No. 9 at p. 2” identifies a written comment (1) made by AHAM; 

(2) recorded in document number 9 that is filed in the docket of this energy conservation standards 

rulemaking (Docket No. EERE–2014–BT–STD–0005) and maintained in the Resource Room of the 

Building Technologies Program; and (3) which appears on page 2 of document number 9.

19 A notation in the form “Sub Zero, TP No. 20 at p. 3” identifies a written comment (1) made by Sub Zero; 

(2) recorded in document number 20 that is filed in the docket of the concurrent cooking products test 

procedures rulemaking (Docket No. EERE-2012-BT-TP-0013) and maintained in the Resource Room of 

the Building Technologies Program; and (3) which appears on page 3 of document number 20.
33

As discussed in section III.B, DOE proposed to amend the conventional cooking 

top test procedure in Appendix I to, among other things, measure the energy use of gas 

cooking tops with high burner input rates and to clarify that the existing conventional 

oven test procedure is appropriate for ovens with high burner input rates, including 

products marketed as commercial-style. See 79 FR 71894 (Dec. 3, 2014). DOE notes 

that the current definitions for “conventional cooking top,” “conventional oven,” and 

“conventional range” in 10 CFR 430.2 already cover conventional gas cooking products 

with higher burner input rates, as these products are household cooking appliances with 

surface units or compartments intended for the cooking or heating of food by means of a 

gas flame. As a result, DOE is proposing energy conservation standards for all residential 

conventional cooking products, including gas cooking products with higher burner input 

rates. As discussed in section IV.A.2, DOE is not considering establishing a separate 

product class for gas cooking products with higher burner input rates that are marketed as 

“commercial-style” and, as a result, DOE is not proposing separate definitions for these 

products.

Natural Resources Defense Council (NRDC) commented that DOE should 

separately define commercial and residential gas cooking products. NRDC noted that 

because of the availability of residential gas cooking tops with higher burner input rates 

previously associated with commercial use, these burner types are not what define 

commercial units. NRDC stated that the definitions should be based on more fundamental 

distinctions between commercial and residential products, such as configuration of the 
34

burners on the cooking top, number of burners, or number of high-input rate burners. 

(NRDC, STD No. 12 at p. 2) As part of this rulemaking, DOE is considering energy 

conservation standards for residential conventional cooking products. As discussed 

above, this includes residential conventional gas cooking products with high burner input 

rates, including those marketed as commercial-style. For these products, DOE tentatively 

concludes that the existing definitions for conventional cooking top, conventional oven, 

and conventional range accurately describe the products that are the subject of this 

rulemaking. In addition, DOE clarifies that the proposed scope of coverage for this 

rulemaking relates only to consumer products. Thus, this rule applies to those residential 

conventional cooking products that are of a type which, to any significant extent, are 

distributed into commerce for personal use or consumption. (See 42 U.S.C. 6291(1)).

These consumer products can be distinguished from commercial/industrial equipment, 

which are of a type not sold for consumer use. (42 U.S.C. 6311(2)(A)) Thus, DOE is not 

proposing to define commercial cooking products as part of this rulemaking.

DOE notes that the test procedures for conventional ranges, cooking tops, and 

ovens found at Appendix I do not address all possible types of combined cooking 

products (i.e., residential products that combine a conventional cooking product with 

other appliance functionality, which may or may not include another cooking product), 

such as microwave/conventional ovens or any other products that may combine a 

conventional cooking product with other appliance functionality that is not a 

conventional cooking product. DOE stated in the February 2014 RFI that because test 

procedures are not available addressing products that combine a conventional cooking 
35

product with other appliance functionality that is not a conventional cooking product 

(e.g., microwave/conventional ovens), DOE is not considering energy conservation 

standards for such products at this time. 79 FR 8337, 8340 (Feb. 12, 2014).

AHAM and Whirlpool agreed with DOE’s tentative determination to not consider 

standards for combined cooking products. (AHAM, STD No. 9 at p. 3; Whirlpool STD 

No. 13 at p. 2) AHAM stated that combined products are too diverse and probably do not 

occupy enough of the market to justify coverage by DOE. AHAM stated that DOE has 

not provided sufficient analysis on each of these products to justify their coverage, nor 

has DOE provided adequate definitions. Thus, AHAM continues to oppose the inclusion 

of combined products in the scope of covered products in the conventional cooking 

products rulemakings. (AHAM, STD No. 9 at p. 3) In the absence of comments opposing

this determination and for the reasons discussed above, DOE is not considering energy 

conservation standards in this NOPR for products that may combine a conventional 

cooking product with other appliance functionality that is not a conventional cooking 

product. 

B. Further Rulemaking to Consider Energy Conservation Standards for Conventional 

Cooking Tops

As part of this rulemaking, DOE intends only to address energy conservation 

standards for conventional ovens, including conventional ovens that are a part of 

conventional ranges. In response to the concurrent cooking products test procedure 
36

proposed rulemaking, DOE received a number of comments from interested parties that 

presented information and arguments for deferring the rulemaking process to consider 

standards for conventional cooking tops until a representative, repeatable, and 

reproducible test procedure could be developed. DOE also conducted a series of 

manufacturer interviews and performed additional testing in order to confirm stakeholder 

comments that additional study was warranted before establishing both a test procedure 

and amended standards for conventional cooking tops. These comments and DOE’s 

response are discussed below.

In the January 2013 TP NOPR, DOE proposed amendments to the cooking 

products test procedure in Appendix I to subpart B of Title 10 of the CFR part 430 that 

would allow for testing the active mode energy consumption of induction cooking 

products; i.e., conventional cooking tops and ranges equipped with induction heating 

technology for one or more surface units on the cooking top. DOE proposed to 

incorporate induction cooking tops by amending the definition of “conventional cooking 

top” to include induction heating technology. Furthermore, DOE proposed to require for 

all cooking tops the use of test equipment compatible with induction technology. 

Specifically, DOE proposed to replace the solid aluminum test blocks currently specified 

in the test procedure for cooking tops with hybrid test blocks comprising two separate 

pieces: an aluminum body and a stainless steel base. 78 FR 6232, 6234 (Jan. 30, 2013).

AHAM commented that DOE should rely on the finalized version of the test 

procedure (i.e., the October 2012 TP Final Rule) and not a proposed test procedure when 
37

evaluating energy conservation standards, particularly given the significant opposing 

comments that question the validity of the proposed test procedure for cooking tops (as 

discussed in AHAM’s comments on the January 2013 TP NOPR). Accordingly, AHAM 

stated that DOE should address AHAM’s and other stakeholder comments regarding 

induction cooking and finalize amendments to the test procedure before using those 

amendments to conduct any analysis for the standards rulemaking, or else proceed 

without addressing induction cooking products in this round of standards rulemaking. 

(AHAM, STD No. 9 at pp. 3–4, 6, 7) 

AHAM and Whirlpool commented that a test procedure should be developed to 

address commercial-style cooking products if DOE plans to evaluate them in a standards 

analysis. (AHAM, STD No. 9 at p. 2; Whirlpool, STD No. 13 at p. 1) AHAM also 

commented that DOE should either proceed without addressing commercial-style 

products as it did for the April 2009 Final Rule or delay the rulemaking analysis until 

there is a finalized test procedure that can measure commercial-style products. (AHAM, 

STD No. 9 at p. 4, 6, 7) AHAM added that it cannot provide data regarding the 

differences between residential-style and commercial-style gas cooking products without 

a test procedure to measure higher input rated burners. (AHAM, STD No. 9 at p. 7) The 

California IOUs supported amending the test procedure to measure the energy use of 

residential conventional gas cooking products with higher burner input rates. (California 

IOUs, STD No. 11 at p. 2)
38

In the December 2014 TP SNOPR, DOE modified its proposal from the January 

2013 TP NOPR to specify different test equipment that would allow for measuring the 

energy efficiency of induction cooking tops, and would include an additional test block 

size for electric surface units with large diameters (both induction and electric resistance). 

79 FR 71894 (Dec. 3, 2014). In addition, DOE proposed methods to test non-circular 

electric surface units, electric surface units with flexible concentric cooking zones, and 

full-surface induction cooking tops. Id. In the December 2014 TP SNOPR, DOE also 

proposed amendments to add a larger test block size to test gas cooking top burners with 

higher input rates. Id.

AHAM formally requested an extension of the comment period for the December 

2014 TP SNOPR, citing the difficulty the members had procuring the specified hybrid 

test block materials, and noting that many manufacturers were not able to properly assess 

the new specifications, testing variation, repeatability, and reproducibility of the proposed 

test procedure before the comment period closed. (AHAM, TP No. 14 at p. 1) AHAM 

also expressed concern with DOE’s choice to pursue an accelerated rulemaking schedule 

for cooking products, stating that DOE’s deadlines did not allow for a thorough technical 

examination. AHAM believes DOE has not conducted adequate outreach to 

manufacturers, has not been sufficiently transparent in its data collection and analysis, 

and has failed to adhere to its own Process Improvement Rule, which calls for all of the 

above. AHAM asked DOE to conduct more substantive dialogue with stakeholders that 

would result in more in-depth comments on the test procedure SNOPR and advised DOE 
39

that the cooking top test procedure as proposed in the December 2014 TP SNOPR may 

result in technical problems. (AHAM, TP No. 18 at pp. 1-2)

Both the BSH Home Appliances Corporation (BSH) and General Electric 

Appliances (GE) confirmed that delays associated with acquiring the hybrid test block 

materials meant they needed additional time to evaluate DOE’s proposed cooking top test 

procedure. (BSH, TP No. 16 at p. 2; GE, TP No. 17 at p. 1) BSH commented that the 

proposed hybrid test block method fails to cover several aspects which are necessary to 

enhance the reproducibility of measuring cooking top energy consumption, such as test 

load sizing and positioning, and recommended DOE take into account important 

specifications which are already fixed in International Electrotechnical Commission 

(IEC) Standard 60350-2 Edition 2, “Household electric appliances – Part 2: Hobs –

Method for measuring performance” (IEC Standard 60350-2). (BSH, TP No. 16 at p. 1) 

Further, both manufacturers and AHAM suggested that DOE specify additional test block 

diameters because the test block sizes proposed by DOE do not adequately reflect the 

surface unit sizes currently available on the market. (BSH, TP No. 16 at p. 5; GE, TP No. 

17 at p 2; AHAM, TP No. 18 at p. 2)

Stakeholders also expressed a significant number of concerns with the use of 

thermal grease. GE noted that since receiving DOE's proposal, it has not been able to 

replicate the DOE test results using the methods described. (GE, TP No. 17 at p. 2) 

Specifically, GE observed that the aluminum body slid off the stainless steel base during 

the test, that the thermal grease dried out, and that the amount of grease between the 
40

blocks changed from one test to another. (GE, TP No. 17 at p. 2) Both manufacturers and 

AHAM requested that DOE specify an operating temperature range for the thermal 

grease as well as an application thickness to address these issues, but also noted that the 

thermal conductivity and viscosity of the grease may still change over time or after 

repeated use at high temperatures. (BSH, TP No. 16 at p. 11; GE, TP No. 17 at p. 2; 

AHAM, TP No. 18 at p. 3) GE further commented that the variation introduced by the 

hybrid test block due to block construction, flatness, thermal grease, and inadequate 

sizing, may be small sources of variation individually, but collectively, these issues result 

in a test method that is incapable of being able to reliably discern efficiency differences 

between similar products, alternate technology options, and product classes. Thus, GE 

believes the test method proposed for conventional cooking tops in the December 2014 

TP SNOPR results in too much variability to serve as the basis for establishing a 

standard. (GE, TP No. 17 at p. 3)

The California IOUs also stated that they prefer an alternative to the hybrid test 

block and recommended that DOE require water-heating test methods to measure the 

cooking efficiency of conventional cooking tops. Specifically, the California IOUs 

requested that DOE align the residential cooking product test methods with existing 

industry test procedures, such as ASTM F1521-12 and IEC Standard 60350-2. (California 

IOUs, TP No. 19 at p. 1) The California IOUs commented that they plan to conduct 

additional testing to better characterize the differences between the water-heating and 

hybrid test block test procedures, and will provide these results to DOE. According to the 

California IOUs, the differences in test procedure standard deviation between the hybrid 
41

test block and water-heating test method as presented in the December 2014 TP SNOPR 

did not sufficiently show that the hybrid test block method is more repeatable than a 

water-heating method. (California IOUs, TP No. 19 at p. 2) Additionally, the California

IOUs believe cooking efficiencies derived using a water-heating test method are more 

representative of the actual cooking performance of cooking tops as opposed to a test 

procedure using hybrid test blocks since many different foods prepared on cooktops will 

have relatively high liquid content. (California IOUs, TP No. 19 at p. 1)

In February and March of 2015, DOE conducted a series of interviews with 

manufacturers of conventional cooking products, representing the majority of the U.S. 

market, regarding the proposed cooking top test procedure. Manufacturers agreed that the 

hybrid test block method, as proposed, presented many issues which had not yet been 

addressed, and which left the repeatability and reproducibility of the test procedure in 

question. These concerns were similar to those expressed in written comments but came 

from a larger group of contributing manufacturers and included: 

• Difficulty obtaining the hybrid test block materials;

• Difficulty obtaining and applying the thermal grease without more 

detailed specifications (i.e., thermal conductivity alone was not sufficient 

to identify a grease that performed according to DOE’s descriptions in the 

SNOPR);

• Difficulty testing induction cooking tops that use different programming 

techniques to prevent overheating (some manufacturers still observed that 
42

power to the heating elements cut off prematurely during testing with the 

hybrid test block, despite adding thermal grease); and

• The need for larger test block sizes to test electric surface units having 

12-inch and 13-inch diameters and gas surface units with high input rates.

Interviewed manufacturers that produce and sell products in Europe 

overwhelmingly supported the use of water-heating test method and harmonization with 

IEC Standard 60350-2 for measuring the energy consumption of electric cooking tops. 

These manufacturers noted that the benefits of pursuing a test method similar to the IEC 

water-heating method include compatibility with all electric cooking top types, additional 

cookware diameters to account for the variety of surface unit sizes on the market, and the 

test load’s ability to represent a real-world cooking top load. 

For these reasons, DOE has decided to continue the energy conservation standards 

rulemaking for conventional ovens but to defer its decision regarding adoption of energy 

conservation standards for conventional cooking tops until a representative, repeatable 

and reproducible test method for cooking tops is finalized. At such time, DOE will 

consider further modifications to DOE’s cooking top active mode test procedure and, on 

the basis of such an amended test procedure, DOE will analyze potential energy 

conservation standards for cooking top energy consumption. DOE invites data and 

information that will allow it to further conduct the analysis of cooking tops, particularly 

when using a water-heating method to evaluate energy consumption. DOE anticipates 

issuing additional notices for cooking top test procedures and standards in order to obtain 
43

public input on DOE’s updated proposals. As part of these notices, DOE will carefully 

consider and address any cooking top-related comments on the December 2014 TP 

SNOPR and the February 2014 RFI that remain relevant.

C. Test Procedure

DOE’s test procedures for conventional ranges, conventional cooking tops, 

conventional ovens, and microwave ovens are codified at appendix I to subpart B of Title 

10 of the CFR part 430.

DOE established the test procedures in a final rule published in 

the Federal Register on May 10, 1978. 43 FR 20108, 20120–20128. DOE revised its test 

procedures for cooking products to more accurately measure their efficiency and energy 

use, and published the revisions as a final rule in 1997. 62 FR 51976 (Oct. 3, 1997). 

These test procedure amendments included: (1) a reduction in the annual useful cooking 

energy; (2) a reduction in the number of self-cleaningSelf-Clean oven cycles per year; 

and (3) incorporation of portions of IEC Standard 705-1988, “Methods for measuring the 

performance of microwave ovens for household and similar purposes,” and Amendment 

2-1993 for the testing of microwave ovens. Id. The test procedures for conventional 

cooking products establish provisions for determining estimated annual operating cost, 

cooking efficiency (defined as the ratio of cooking energy output to cooking energy 

input), and energy factor (defined as the ratio of annual useful cooking energy output to 

total annual energy input). 10 CFR 430.23(i); Appendix I. 
44

DOE subsequently conducted a rulemaking to address standby and off mode 

energy consumption, as well as certain active mode (i.e., fan-only mode) testing 

provisions, for residential conventional cooking products. DOE published a final rule on 

October 31, 2012 (77 FR 65942, the October 2012 TP Final Rule), adopting standby and 

off mode provisions that satisfy the EPCA requirement that DOE include measures of 

standby mode and off mode energy consumption in its test procedures for residential 

products, if technically feasible. (42 U.S.C. 6295(gg)(2)(A))

In the December 2014 TP SNOPR, DOE proposed modifications to the test block 

used to evaluate conventional cooking top energy consumption. As discussed in section 

III.B, DOE plans to consider further modifications to DOE’s cooking top active mode 

test procedure in a future rulemaking. In the December 2014 TP SNOPR, DOE also 

proposed to incorporate methods for measuring conventional oven volume, clarified that 

the existing oven test block must be used to test all ovens regardless of input rate, and 

provided a method to measure the energy consumption and efficiency of conventional 

ovens equipped with an oven separator. 79 FR 71894 (Dec. 3, 2014). DOE is proposing 

energy conservation standards for conventional ovens in this NOPR based on these

proposals in the December 2014 TP SNOPR. DOE intends to update the standards 

rulemaking analyses based on any final amendments related to ovens developed as part of 

the concurrent test procedure rulemaking. DOE recognizes that interested parties need 

sufficient time to evaluate the proposed energy conservation standards using the final test 

procedure for conventional ovens. DOE considers the stated energy conservation 
45

standards rulemaking process to provide sufficient time to submit meaningful comments

based on a finalized DOE conventional oven test procedure. 

D. Technological Feasibility

1. General

In each energy conservation standards rulemaking, DOE conducts a screening 

analysis based on information gathered on all current technology options and prototype 

designs that could improve the efficiency of the products or equipment that are the 

subject of the rulemaking. As the first step in such an analysis, DOE develops a list of 

technology options for consideration in consultation with manufacturers, design 

engineers, and other interested parties. DOE then determines which of those means for 

improving efficiency are technologically feasible. DOE considers technologies 

incorporated in commercially available products or in working prototypes to be 

technologically feasible. 10 CFR part 430, subpart C, appendix A, section 4(a)(4)(i).

After DOE has determined that particular technology options are technologically 

feasible, it further evaluates each technology option in light of the following additional 

screening criteria: (1) practicability to manufacture, install, and service; (2) adverse 

impacts on product utility or availability; and (3) adverse impacts on health or safety. 10 

CFR part 430, subpart C, appendix A, section 4(a)(4)(ii)-(iv). Section IV.B of this notice 

discusses the results of the screening analysis for residential conventional ovens, 

particularly the designs DOE considered, those it screened out, and those that are the 

basis for the trial standard levels (TSLs) in this rulemaking. For further details on the 
46

screening analysis for this rulemaking, see chapter 4 of the NOPR Technical Support 

Document (TSD).

2. Maximum Technologically Feasible Levels

When DOE proposes to adopt an amended standard for a type or class of covered 

product, it must determine the maximum improvement in energy efficiency or maximum 

reduction in energy use that is technologically feasible for such product. (42 U.S.C. 

6295(p)(1)) Accordingly, in the engineering analysis, DOE determined the maximum 

technologically feasible (“max-tech”) improvements in energy efficiency for residential 

conventional ovens, using the design parameters for the most efficient products available

on the market or in working prototypes, and information from the previous rulemaking. 

The max-tech levels that DOE determined for this rulemaking are described in section 

IV.C.3 of this proposed rule and in chapter 5 of the NOPR TSD.

E. Energy Savings

1. Determination of Savings

For each TSL, DOE projected energy savings from the products that are the 

subject of this rulemaking purchased in the 30-year period that begins in the year of 

compliance with new and amended standards (2019 to 2048).20 The savings are measured 

over the entire lifetime of products purchased in the 30-year analysis period. DOE 

quantified the energy savings attributable to each TSL as the difference in energy 

consumption between each standards case and the base case. The base case represents a 

 20 DOE also presents a sensitivity analysis that considers impacts for products shipped in a 9-year period.
47

projection of energy consumption in the absence of new and amended efficiency 

standards, and it considers market forces and policies that affect demand for more 

efficient products. 

DOE uses its national impact analysis (NIA) spreadsheet models to estimate 

energy savings from potential new and amended standards. The NIA spreadsheet model 

(described in section IV.H of this notice) calculates energy savings in site energy, which 

is the energy directly consumed by products at the locations where they are used. For 

electricity, DOE calculates national energy savings in terms of primary energy savings, 

which is the savings in the energy that is used to generate and transmit the site electricity

For electricity, natural gas, and oil, DOE also calculates full-fuel-cycle (FFC) energy 

savings. As discussed in DOE’s statement of policy and notice of policy amendment, the 

FFC metric includes the energy consumed in extracting, processing, and transporting 

primary fuels (i.e., coal, natural gas, petroleum fuels), and thus presents a more complete 

picture of the impacts of energy efficiency standards. 76 FR 51281 (Aug. 18, 2011), as 

amended at 77 FR 49701 (Aug. 17, 2012). 

To calculate primary energy savings, DOE derives annual conversion factors from 

the model used to prepare the Energy Information Administration’s (EIA) most 

recent Annual Energy Outlook (AEO).

21 For FFC energy savings, DOE’s approach is 

based on the calculation of an FFC multiplier for each of the energy types used by 

covered products or equipment. For more information, see section IV.H.2.

 21 For this NOPR, DOE used AEO 2014. Available at http://www.eia.gov/forecasts/AEO/
48

2. Significance of Savings

To adopt standards for a covered product, DOE must determine that such action 

would result in “significant” energy savings. (42 U.S.C. 6295(o)(3)(B)) Although the 

term “significant” is not defined in the Act, the U.S. Court of Appeals for the District of 

Columbia Circuit, in Natural Resources Defense Council v. Herrington, 768 F.2d 1355, 

1373 (D.C. Cir. 1985), opined that Congress intended “significant” energy savings in the 

context of EPCA to be savings that were not “genuinely trivial.” The energy savings for 

the proposed standards (presented in section IV.H.2) are nontrivial, and, therefore, DOE 

considers them “significant” within the meaning of section 325 of EPCA.

F. Economic Justification

1. Specific Criteria

EPCA provides seven factors to be evaluated in determining whether a potential 

energy conservation standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)) The 

following sections discuss how DOE has addressed each of those seven factors in this 

rulemaking.

a. Economic Impact on Manufacturers and Consumers

In determining the impacts of a potential amended standard on manufacturers, 

DOE conducts a manufacturer impact analysis (MIA), as discussed in section IV.J. DOE 

first uses an annual cash-flow approach to determine the quantitative impacts. This step 

includes both a short-term assessment—based on the cost and capital requirements during 
49

the period between when a regulation is issued and when entities must comply with the 

regulation—and a long-term assessment over a 30-year period. The industry-wide 

impacts analyzed include industry net present value (INPV), which values the industry on 

the basis of expected future cash flows; cash flows by year; changes in revenue and 

income; and other measures of impact, as appropriate. Second, DOE analyzes and reports 

the impacts on different types of manufacturers, including impacts on small 

manufacturers. Third, DOE considers the impact of standards on domestic manufacturer 

employment and manufacturing capacity, as well as the potential for standards to result in 

plant closures and loss of capital investment. Finally, DOE takes into account cumulative 

impacts of various DOE regulations and other regulatory requirements on manufacturers.

For individual consumers, measures of economic impact include the changes in 

LCC and PBP associated with new or amended standards. These measures are discussed 

further in the following section. For consumers in the aggregate, DOE also calculates the 

national net present value of the economic impacts applicable to a particular rulemaking.

DOE also evaluates the LCC impacts of potential standards on identifiable subgroups of 

consumers that may be affected disproportionately by a national standard.

b. Savings in Operating Costs Compared to Increase in Price

EPCA requires DOE to consider the savings in operating costs throughout the 

estimated average life of the covered product in the type (or class) compared to any 

increase in the price of, or in the initial charges for, or maintenance expenses of, the 
50

covered product that are likely to result from a standard. (42 U.S.C. 6295(o)(2)(B)(i)(II)) 

DOE conducts this comparison in its LCC and PBP analysis. 

The LCC is the sum of the purchase price of a product (including its installation) 

and the operating expense (including energy, maintenance, and repair expenditures) 

discounted over the lifetime of the product. The LCC analysis requires a variety of inputs, 

such as product prices, product energy consumption, energy prices, maintenance and 

repair costs, product lifetime, and consumer discount rates. To account for uncertainty 

and variability in specific inputs, such as product lifetime and discount rate, DOE uses a 

distribution of values, with probabilities attached to each value. For its analysis, DOE 

assumes that consumers will purchase the covered products in the first year of 

compliance with amended standards. 

The LCC savings for the considered efficiency levels are calculated relative to a 

base case that reflects projected market trends in the absence of amended standards. DOE 

identifies the percentage of consumers estimated to receive LCC savings or experience an 

LCC increase, in addition to the average LCC savings associated with a particular 

standard level. DOE’s LCC and PBP analysis is discussed in further detail in section 

IV.F.

c. Energy Savings

Although significant conservation of energy is a separate statutory requirement 

for adopting an energy conservation standard, EPCA requires DOE, in determining the 
51

economic justification of a standard, to consider the total projected energy savings that 

are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As 

discussed in section IV.H.2, DOE uses spreadsheet models to project national energy 

savings.

d. Lessening of Utility or Performance of Products

In establishing classes of products, and in evaluating design options and the 

impact of potential standard levels, DOE evaluates potential standards that would not 

lessen the utility or performance of the considered products. (42 U.S.C. 

6295(o)(2)(B)(i)(IV)) Based on data available to DOE, the standards proposed in this

notice would not reduce the utility or performance of the products under consideration in 

this rulemaking.

e. Impact of Any Lessening of Competition

EPCA directs DOE to consider the impact of any lessening of competition, as 

determined in writing by the Attorney General, that is likely to result from a proposed

standard. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It also directs the Attorney General to 

determine the impact, if any, of any lessening of competition likely to result from a 

proposed standard and to transmit such determination to the Secretary within 60

days of the publication of a proposed rule, together with an analysis of the nature and 

extent of the impact. (42 U.S.C. 6295(o)(2)(B)(ii)) DOE will transmit a copy of this 

proposed rule to the Attorney General with a request that the Department of Justice 
52

(DOJ) provide its determination on this issue. DOE will publish and respond to the

Attorney General’s determination in the final rule.

f. Need for National Energy Conservation

DOE also considers the need for national energy conservation in determining 

whether a new or amended standard is economically justified. (42 U.S.C. 

6295(o)(2)(B)(i)(VI)) The energy savings from new or amended standards are likely to 

provide improvements to the security and reliability of the nation’s energy system. 

Reductions in the demand for electricity also may result in reduced costs for maintaining 

the reliability of the nation’s electricity system. DOE conducts a utility impact analysis to 

estimate how standards may affect the nation’s needed power generation capacity, as 

discussed in section IV.M.

New or amended standards also are likely to result in environmental benefits in 

the form of reduced emissions of air pollutants and greenhouse gases (GHGs) associated 

with energy production and use. DOE conducts an emissions analysis to estimate how 

standards may affect these emissions, as discussed in section IV.K. DOE reports the 

emissions impacts from each TSL it considered in section IV.K of this notice. DOE also 

estimates the economic value of emissions reductions resulting from the considered 

TSLs, as discussed in section IV.L.
53

g. Other Factors

EPCA allows the Secretary of Energy, in determining whether a standard is 

economically justified, to consider any other factors that the Secretary deems to be 

relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) To the extent interested parties submit any 

relevant information regarding economic justification that does not fit into the other 

categories described above, DOE could consider such information under “other factors.”

2. Rebuttable Presumption

As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a rebuttable 

presumption that an energy conservation standard is economically justified if the 

additional cost to the consumer of a product that meets the standard is less than three 

times the value of the first year’s energy savings resulting from the standard, as 

calculated under the applicable DOE test procedure. DOE’s LCC and PBP analyses 

generate values used to calculate the effects that proposed energy conservation standards 

would have on the payback period for consumers. These analyses include, but are not 

limited to, the 3-year payback period contemplated under the rebuttable-presumption test. 

In addition, DOE routinely conducts an economic analysis that considers the full range of 

impacts to consumers, manufacturers, the Nation, and the environment, as required under 

42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis serve as the basis for DOE’s 

evaluation of the economic justification for a potential standard level (thereby supporting 

or rebutting the results of any preliminary determination of economic justification). The 

rebuttable presumption payback calculation is discussed in section IV.F.11 of this 

proposed rule.
54

IV. Methodology and Discussion of Comments

DOE used several analytical tools to estimate the impact of the proposed 

standards. The first tool is a spreadsheet that calculates the LCC and PBP of potential 

energy conservation standards. The national impacts analysis uses a spreadsheet set that 

provides shipments forecasts and calculates national energy savings and net present value 

resulting from potential energy conservation standards. DOE uses the third spreadsheet 

tool, the Government Regulatory Impact Model (GRIM), to assess manufacturer impacts 

of potential standards. These three spreadsheet tools are available at the website for this 

rulemaking: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.asp

x?ruleid=85. Additionally, DOE used output from the latest version of EIA’s Annual 

Energy Outlook (AEO),) 2014, a widely known energy forecast for the United States, for 

the emissions and utility impact analyses.

A. Market and Technology Assessment

1. General

For the market and technology assessment, DOE develops information that 

provides an overall picture of the market for the products concerned, including the 

purpose of the products, the industry structure, and market characteristics. This activity 

includes both quantitative and qualitative assessments, based primarily on publicly 

available information. Chapter 3 of the NOPR TSD contains additional discussion of the 

market and technology assessment.
55

2. Product Classes 

When evaluating and establishing energy conservation standards, DOE divides 

covered products into product classes by the type of energy used or by capacity or other 

performance-related features that justifies a different standard. In making a determination 

whether a performance-related feature justifies a different standard, DOE must consider 

such factors as the utility to the consumer of the feature and other factors DOE 

determines are appropriate. (42 U.S.C. 6295(q))

During the previous energy conservation standards rulemaking for cooking 

products, DOE evaluated product classes for conventional ovens based on energy source 

(i.e., gas or electric). These distinctions initially yielded two conventional oven product

classes: (1) gas ovens; and (2) electric ovens. DOE later determined that the type of ovencleaning system is a utility feature that affects performance. DOE found that standard 

ovens and ovens using a catalytic continuous-cleaning process use roughly the same 

amount of energy. On the other hand, self-cleaningSelf-Clean ovens use a pyrolytic 

process that provides enhanced consumer utility with lower overall energy consumption 

as compared to either standard or catalytically lined ovens. DOE defined the following 

product classes in the TSD for the April 2009 Final Rule (2009 TSD)22 for conventional 

ovens:

• Electric ovens – standard oven with or without a catalytic line;

• Electric ovens – self-clean oven;

 22 The technical support document from the previous residential cooking products standards rulemaking is 

available at: http://www.regulations.gov/#!documentDetail;D=EERE-2006-STD-0127-0097.
56

• Gas ovens – standard oven with or without a catalytic line; and

• Gas ovens – self-clean oven.

As part of the February 2014 RFI, DOE stated that it tentatively plans to maintain 

the product classes for conventional ovens from the previous standards rulemaking, as 

presented above. DOE stated that it may consider whether separate product classes are 

warranted for conventional gas ovens with higher burner input rates. 79 FR 8337, 8341–

8342 (Feb. 12, 2014).

Based on DOE’s review of gas conventional ovens and ranges available on the 

U.S. market, and based on manufacturer interviews and testing conducted as part of the 

engineering analysis described in section IV.C and Chapter 5 of the TSD, DOE notes that 

the self-cleaning function of the self-clean oven may employ methods other than a high 

temperature pyrolytic cycle to perform the cleaning action. Specifically, DOE is aware of 

a type of self-cleaning oven that uses a proprietary oven coating and water to perform a 

self-clean cycle with a shorter duration and at a significantly lower temperature setting.

The self-cleaning cycle for these ovens, unlike catalytically-lined standard ovens that 

provide continuous cleaning during normal baking, still have a separate self-cleaning 

mode that is user-selectable and must be tested separately. In this NOPR, DOE is 

clarifying that a self-clean electric or gas conventional oven is an oven that has a userselectable mode separate from the normal baking mode, not intended to heat or cook 

food, which is dedicated to cleaning and removing cooking deposits from the oven cavity 

walls. 
57

With regard to commercial-style products, AHAM commented that without a 

definition or test procedure for such products, neither AHAM nor DOE can determine at 

this stage whether these products would warrant a separate product class. AHAM noted

that DOE should first develop a test procedure for these products to allow for analysis of

them. (AHAM, No. 9 at p. 12)

Based on DOE’s review of the residential conventional gas ovens available on the 

market, residential-style gas ovens typically have an input rate of 16,000 to 18,000 Btu/h

whereas residential gas ovens marketed as commercial-style typically have burner input 

rates ranging from 22,500 to 30,000 Btu/h.23 Additional review of both the residentialstyle and commercial-style gas oven cavities indicated that there is significant overlap in 

oven cavity volume between the two oven types. Standard residential-style gas oven 

cavities range from 2.5 to 5.6 cubic feet (ft3

) in volume and gas ovens marketed as 

commercial-style have cavity volumes ranging from 3.0 to 6.0 ft3

. Sixty percent of the 

commercial-style models surveyed had cavity volumes between 4.0 and 5.0 ft3 while fifty 

percent of the standard models had cavity volumes between 4.0 and 5.0 ft3. The primary 

differentiating factor between the two oven types was burner input rate, which is greater 

than 22,500 Btu/h for commercial-style gas ovens. 

 23 However, DOE noted that many gas ranges, while marketed as commercial- or professional-style and 

having multiple surface units with high input rates, did not have a gas oven with a burner input rate above 

22,500 Btu/h.
58

As discussed in the December 2014 TP SNOPR, DOE determined that the test 

load for ovens as specified in the existing DOE test procedure in Appendix I is 

appropriate for gas ovens with burner input rates greater than 22,500 Btu/h. 79 FR at 

71915–71916. As a result, DOE conducted testing for this NOPR to determine whether 

conventional gas ovens with higher burner input rates warrant establishing a separate 

product class. DOE evaluated the cooking efficiency of the eight conventional gas ovens

listed in Table IV-1. Five of these ovens had burners rated at 18,000 Btu/h or less and the 

remaining three had burner input rates ranging from 27,000 Btu/h to 30,000 Btu/h.

Table IV-1. Performance Characteristics of Gas Oven Test Sample

Test 

Unit

# Type

Installation

Configuration

Burner 

Input Rate 

(Btu/h)

Cavity 

Volume 

(cubic feet 

(ft3))

Measured 

Cooking 

Efficiency

Normalized 

Cooking 

Efficiency**

1 Standard Freestanding 18,000 4.8 6.6% 7.0%

2 Standard Freestanding 18,000 4.8 6.0% 6.3%

3 Self-Clean Freestanding 18,000 5.0 7.6% 8.1%

4 Standard Freestanding 16,500 4.4 6.2% 6.2%

5 Self-Clean Built-in 13,000 2.8 9.4% 8.3%

6 Standard * Freestanding 28,000 5.3 4.3% 5.1%

7 Standard * Slide-in 27,000 4.4 5.2% 5.2%

8 Standard * Freestanding 30,000 5.4 3.9% 4.7%

* These products are marketed as commercial-style gas ovens.

** Measured cooking efficiency normalized to a fixed cavity volume of 4.3 cubic feet.

The measured cooking efficiencies for ovens with burner input rates above 22,500 

Btu/h were lower than for ovens with ratings below 22,500 Btu/h, even after normalizing

cooking efficiency to a fixed cavity volume. However, DOE also noted that the 

conventional gas ovens with higher burner input rates in DOE’s test sample were 

marketed as commercial-style and had greater total thermal mass, including heavier racks 
59

and thicker cavity walls, even after normalizing for cavity volume. To determine whether 

the lower measured efficiency of these ovens was due to the higher input rate burners, 

DOE isolated the heating element from the thermal mass of the oven by placing 1-inch 

thick insulation on all surfaces inside the oven cavity, except for the bottom of the cavity 

where the burner was located, and ran tests according to the DOE test procedure. By 

adding insulation, heat transfer to the cavity walls was minimized and retained in the 

cavity to heat the test block. DOE selected test unit 3 and test unit 8 in Table IV-1 for test 

because of the similarity in cavity volume, their difference in efficiency, and their 

differing input rate (18,000 Btu/h and 30,000 Btu/h, respectively). Figure IV.1 displays 

the resulting test block temperature increase as a function of test time, measured with and 

without insulation lining the interior oven cavity walls. 
60

Figure IV.1 Test Load Temperature With and Without Insulation Lining the 

Interior Cavity Walls

Without the added insulation inside the oven cavity, the temperature rise in the 

test block was similar for each oven, despite the large difference in burner input rate. In 

contrast, by adding insulation inside the cavity, the test block temperature in the 30,000 

Btu/h oven increased at a faster rate than in the 18,000 Btu/h oven. This suggests that 

much of the energy input to the 30,000 Btu/h oven goes to heating the added mass of the 

cavity, rather than the test load, resulting in relatively lower measured efficiency. 

DOE also investigated the time it took each oven in the test sample to heat the test 

load to a final test temperature of 234 degrees Fahrenheit (°F) above its initial 

0

50

100

150

200

250

300

350

400

450

500

0 1000 2000 3000 4000

Temperature (F°)

Time (s)

Test Unit 3 (18,000 Btu/h) Test Unit 3 (18,000 Btu/h) - Insulation

Test Unit 8 (30,000 Btu/h) Test Unit 8 (30,000 Btu/h) - Insulation
61

temperature, specified in the DOE test procedure in Appendix I. As shown in Table IV-2, 

gas ovens with burner input rates greater than 22,500 Btu/h do not heat the test load

significantly faster than the ovens with lower burner input rates, and two out of the three 

units with the higher burner input rates took longer than the average time to heat the test 

load. Therefore, DOE preliminarily concludes that there is no unique utility associated 

with faster cook times that is provided by gas ovens with burner input rates greater than 

22,500 Btu/h. 

Table IV-2. Gas Oven Test Times

Unit Type

Burner Input 

Rate (Btu/h)

Bake Time to Reach 234°F 

Above Initial Temp 

(min)

Difference in 

Time from Avg

(min)

1 Standard 18,000 43.6 -3.8

2 Standard 18,000 43.6 -3.8

3 Self-Clean 18,000 47.2 -0.2

4 Standard 16,500 44.9 -2.5

5 Self-Clean 13,000 48.9 1.5

6 Standard * 28,000 48.9 1.5

7 Standard * 27,000 45.4 -2.0

8 Standard * 30,000 57.2 9.8

Average 47.4 -

* Test units 6, 7, and 8 are marketed as commercial-style ovens.

In response to the December 2014 TP SNOPR, Sub Zero commented that 

categorizing all ovens under the term conventional cooking suggests that DOE is unaware 

of the significant positive differences provided to a subset of consumers by commercialstyle products. (Sub Zero, TP No. 20 at p. 2) If standards are to be proposed, Sub Zero 

requested that the product classes be significantly expanded in number to recognize the 

unique and important utility and performance attributes associated with “high 

performance” cooking products. (Sub Zero, TP No. 20 at p. 3) Sub Zero suggested that 
62

these products offer residential consumers performance similar to that found in 

restaurants, at a safety and convenience level that is acceptable for residential use. 

Commercial-style ovens would thus include gas ranges in widths up to 60 inches, gas 

ovens up to 36 inches wide with high output infrared broilers and convection fans, dual 

fuel ranges combining gas cooktops with sealed burners and large, electric self-cleaning 

convection ovens that use hidden bake elements and multiple heating circuits for added 

control, as well as separate convection elements or multiple convection fans. Sub Zero 

believes that analysis based largely on the traditional 30-inch wide gas or electric range 

cannot adequately evaluate the very different performance attributes offered by high 

performance products which are essential to consumer utility. (Sub Zero, TP No. 20 at p. 

2)

In selecting a test sample to support DOE’s engineering analysis, discussed in 

section IV.C.2 and Chapter 5 of the TSD, DOE attempts to capture a wide range of 

products having features that may result in the determination of additional product 

classes. DOE included two commercial-style gas ovens greater than 30-inches in width as

part of its test sample. DOE is not aware of data showing the improved cooking 

performance of these products due to the features described in the comments as compared 

to conventional gas ovens not marketed as commercial-style or commercial-style gas 

ovens less than or equal to 30 inches in width. All of the commercial-style ovens 

evaluated by DOE contained features such as infrared broilers, convection fans, and 

hidden bake elements, but DOE observed that many of the same features were also 

available in conventional gas ovens with lower input rates. DOE welcomes data 
63

demonstrating the improved cooking performance associated with the features for 

commercial-style gas ovens with widths greater than 30-inches that result in increased 

energy consumption, but are not available in conventional gas ovens with lower input 

rates or commercial-style gas ovens with widths of 30 inches or less.

Based on DOE’s testing, reverse engineering, and additional discussions with 

manufacturers, DOE determined that the major differentiation between conventional gas 

ovens with lower burner input rates and those with higher input rates, including those 

marketed as commercial-style, was design and construction related to aesthetics rather 

than improved cooking performance. Further, DOE did not identify any unique utility 

conferred by commercial-style gas ovens. For the reasons discussed above, DOE is not 

proposing to establish a separate product class for conventional gas ovens with higher 

burner input rates.

As discussed in section III.B, in the October 2012 TP Final Rule, DOE amended 

appendix I to include methods for measuring fan-only mode24. Based on DOE’s testing of 

freestanding, built-in, and slide-in conventional gas and electric ovens, DOE noted that 

all of the built-in and slide-in ovens tested consumed energy in fan-only mode, whereas 

freestanding ovens did not. The energy consumption in fan-only mode for built-in and 

slide-in ovens ranged from approximately 1.3 to 37.6 watt-hours (Wh) per cycle (0.25 to 

7.6 kWh/yr). Based on DOE’s reverse engineering analyses discussed in section IV.C.2, 

DOE noted that built-in and slide-in products had an additional exhaust fan and vent

assembly that was not present in freestanding products. The additional energy required to 

 24 Fan-only mode is an active mode that is not user-selectable in which a fan circulates air internally or 

externally to the cooking product for a finite period of time after the end of the heating function.
64

exhaust air from the oven cavity is necessary for slide-in and built-in installation 

configurations to meet safety-related temperature requirements because the oven is 

enclosed in cabinetry. For these reasons, DOE proposes to include separate product 

classes for freestanding and built-in/slide-in ovens. 

In summary, DOE proposes the product classes listed in Table IV-3 for the

NOPR.

Table IV-3. Proposed Product Classes for Conventional Ovens

Product 

Class Product Type Sub-Category Installation Type

1

Electric oven

Standard with or without a 

catalytic line

Freestanding

2 Built-in/Slide-in

3 Self-clean Freestanding

4 Built-in/Slide-in

5

Gas oven

Standard with or without a 

catalytic line

Freestanding

6 Built-in/Slide-in

7 Self-clean Freestanding

8 Built-in/Slide-in

3. Technology Options 

As part of the market and technology assessment, DOE uses information about 

existing and past technology options and prototype designs to help identify technologies 

that manufacturers could use to improve energy efficiency. Initially, these technologies 

encompass all those that DOE believes are technologically feasible. Chapter 3 of the 

NOPR TSD includes the detailed list and descriptions of all technology options identified 

for this equipment.
65

In the February 2014 RFI, DOE stated that based on a preliminary review of the 

cooking products market and information published in recent trade publications, technical 

reports, and manufacturer literature, the results of the technology screening analysis 

performed during the previous standards rulemaking remain largely relevant for this 

rulemaking. 79 FR 8337, 8341 (Feb. 12, 2014). DOE stated in the February 2014 RFI that 

it planned to consider the technology options presented in Table IV-4 for conventional 

ovens. 79 FR 8337, 8342–8343 (Feb. 12, 2014).

Table IV-4. February 2014 RFI Technology Options for Conventional Ovens

1. Bi-radiant oven (electric only)

2. Electronic spark ignition (gas only)

3. Forced convection 

4. Halogen lamp oven (electric only) 

5. Improved and added insulation 

6. Improved door seals 

7. No oven-door window 

8. Oven separator

9. Radiant burner (gas only)

10. Reduced conduction losses

11. Reduced thermal mass

12. Reduced vent rate

13. Reflective surfaces

14. Steam cooking

15. Low-standby-loss electronic controls

In response to the February 2014 RFI, DOE received a number of comments 

regarding the technology options for conventional ovens.
66

AHAM commented that forced convection should not be considered a technology 

option for gas or electric ovens. AHAM stated that only some foods can be cooked with 

convection and that accelerating the cooking time or baking rate for other foods will not 

produce acceptable results. Accordingly, AHAM believes this technology option would 

impact consumer utility. (AHAM, STD No. 9 at p. 5) DOE recognizes that using forced 

convection for cooking certain foods may be undesirable. DOE is not considering forced 

convection as a complete replacement to the conventional bake cooking function. Instead 

DOE considered forced convection as a separate heating mode in addition to the bake 

function for the engineering analysis. DOE also notes that the test procedure in Appendix

I averages the energy consumption measured during bake-only mode with the energy 

consumption measured during forced convection mode to calculate the total cooking 

efficiency and IAEC for the oven, representing equal use of forced convection and bakeonly cooking cycles. As a result, DOE is retaining forced convection as a technology 

option for this NOPR.

AHAM and Whirlpool commented that reducing the vent rate should not be 

considered because it could result in incomplete combustion. In addition, AHAM stated 

that it would impact the ability of the product to manage moisture release. (AHAM, STD 

No. 9 at p. 6; Whirlpool, STD No. 13 at p. 4) As noted in the 2009 TSD, DOE believes 

that vent size of both standard electric and standard gas ovens could be reduced while 

maintaining a satisfactory combustion environment. Since all Self-Clean ovens are 

already designed with this technology, no new improvements are required by the industry 

to incorporate this technology option. DOE noted in the 2009 TSD that an increase of 
67

approximately 0.62 absolute percentage points for standard electric ovens and 0.5 

absolute percentage points for standard gas ovens was possible with this technology 

option. As a result, DOE retained reduced vent rate as a technology option for standard 

ovens for this NOPR.

AHAM commented that improved door seals may not provide a significant 

improvement in efficiency. (AHAM, STD No. 9 at p. 6) DOE notes that door seals for 

standard ovens generally consist of a strip of silicone rubber, while Self-Clean ovens 

usually incorporate fiberglass seals. Because some venting is required for proper cooking 

performance, a complete seal on the oven is undesirable. As DOE noted in the 2009 TSD, 

the oven door seals can be improved further without sealing the oven completely. Based 

on discussions with manufacturers, DOE believes that fiberglass seals can be installed in 

standard ovens to improve efficiency. As a result, DOE retained improved door seals as a 

technology option for standard ovens. 

Whirlpool commented that it has already optimized insulation in its ovens for 

safety reasons. (Whirlpool, STD No. 13 at p. 4) DOE noted in the 2009 TSD that 

standard ovens used low-density insulation (1.09 pounds (lb)/ft3

) whereas self-clean 

ovens used higher-density insulation (1.90 lb/ft3). Based on interviews with 

manufacturers for this rulemaking, DOE notes that manufacturers generally use the same 

amount of insulation for standard ovens versus self-clean ovens, but with different 

densities. Insulation is added primarily to pass Underwriters Laboratory (UL) surface 

temperature safety testing requirements, which explains why Self-Clean ovens, which 
68

require high temperatures for pyrolysis, tend to have a more effective insulation package. 

DOE notes that higher-density insulation can be used in standard ovens to improve 

efficiency. As a result, DOE retained improved insulation as a technology option for 

standard ovens.

Whirlpool commented that there may be savings associated with steam cooking 

realized by the user, but these savings would likely not be measured in the DOE test 

procedure. (Whirlpool, STD No. 13 at p. 4) While there are several residential steam 

ovens currently on the market, DOE is unaware of any test procedures that accurately 

measure the energy use of the steam cooking mode while producing repeatable and 

reproducible results. As a result, DOE is unaware of any data regarding the efficiency of 

steam cooking. For these reasons, DOE did not consider steam cooking in the analysis.

Whirlpool commented that there could be savings for gas ovens from electronic 

spark ignition over a glo-bar igniter, which could use 250–500W throughout the cooking 

cycle. (Whirlpool, STD No. 13 at p. 4) As discussed in section IV.C.2, based on DOE’s 

testing, DOE agrees that switching from a glo-bar to an electronic spark ignition system 

would result in energy savings. As a result, DOE is maintaining electronic spark ignition 

as a technology option for this NOPR.

Based on DOE’s review of products on the market, DOE notes that radiant 

burners for gas ovens are only incorporated into broiling, which is a secondary cooking 

function not measured under the test procedure; energy use is instead measured during 
69

the primary bake function. As a result, the benefits of radiant burners are not measured by 

the current test procedure. Accordingly, DOE eliminated radiant burners in gas ovens 

from further analysis. 

In the previous standards rulemaking, DOE noted that oven separators had only 

been researched, but never put into production. 72 FR 64432, 64456 (Nov. 15, 2007). 

Based on DOE’s review of products on the market, DOE notes that one manufacturer 

offers a conventional electric oven with an oven separator. As a result, DOE plans to 

consider oven separators as a technology option for electric ovens.

In addition to the technology options presented in Table IV-4, DOE considered an 

additional technology option for optimizing the burner and cavity design for gas ovens 

based on product testing and reverse engineering analyses conducted for this NOPR. As 

described in section IV.A.2 and further in section IV.C.2, DOE’s testing indicated that 

reducing the thermal mass of the oven cavity can increase cooking efficiency. Because 

oven cavity and burner design are interdependent, DOE is proposing to consider 

optimized burner and cavity design as a technology option for increasing efficiency for 

gas ovens consistent with products available on the market rather than the reduced 

thermal mass technology option considered for the previous rulemaking.

Table IV-5 lists the proposed technology options that DOE is considering for the

NOPR.
70

Table IV-5. Proposed Technology Options for Conventional Ovens

1. Bi-radiant oven (electric only)

2. Electronic spark ignition (gas only)

3. Forced convection 

4. Halogen lamp oven (electric only) 

5. Improved and added insulation (standard ovens only)

6. Improved door seals 

7. No oven-door window 

8. Oven separator (electric only)

9. Reduced conduction losses

10. Reduced vent rate

11. Reflective surfaces

12. Low-standby-loss electronic controls

13. Optimized burner and cavity design

DOE seeks comment on the use of optimized burner and cavity design (and other 

options listed in Table IV-5) to meet the proposed efficiency levels discussed in section 

I.A.1.b. (See section VII.E )

B. Screening Analysis

DOE uses the following four screening criteria to determine which technology 

options are suitable for further consideration in an energy conservation standards 

rulemaking:

1. Technological feasibility. Technologies that are not incorporated in commercial 

products or in working prototypes will not be considered further.

2. Practicability to manufacture, install, and service. If it is determined that mass 

production and reliable installation and servicing of a technology in commercial 

products could not be achieved on the scale necessary to serve the relevant market 
71

at the time of the compliance date of the standard, then that technology will not be 

considered further.

3. Impacts on product utility or product availability. If it is determined that a 

technology would have significant adverse impact on the utility of the product to 

significant subgroups of consumers or would result in the unavailability of any 

covered product type with performance characteristics (including reliability), 

features, sizes, capacities, and volumes that are substantially the same as products 

generally available in the United States at the time, it will not be considered 

further.

4. Adverse impacts on health or safety. If it is determined that a technology would 

have significant adverse impacts on health or safety, it will not be considered 

further.

(10 CFR part 430, subpart C, appendix A, 4(a)(4) and 5(b))

In sum, if DOE determines that a technology, or a combination of technologies, 

fails to meet one or more of the above four criteria, it will be excluded from further 

consideration in the engineering analysis. The reasons for eliminating any technology are 

discussed below.
72

The subsequent sections include comments from interested parties pertinent to the 

screening criteria, DOE’s evaluation of each technology option against the screening 

analysis criteria, and whether DOE determined that a technology option should be 

excluded (“screened out”) based on the screening criteria.

1. Screened-Out Technologies

For conventional ovens, DOE screened out added insulation, bi-radiant oven, 

halogen lamp oven, no oven door window, and reflective surfaces, for the reasons that 

follow. 

Although some analyses have shown reduced energy consumption by increasing 

the thickness of the insulation in the oven cabinet walls and doors from two inches to four 

inches, consumer utility would be negatively impacted by the necessary reduction in 

cavity volume to maintain the same oven footprint and overall cabinet volume. Therefore, 

DOE screened out added insulation. The improved insulation design option, however, 

will be retained, because insulation with a higher density (i.e., greater insulating value) 

does not require additional space and thus would not impact oven cavity size. 

The last working prototype of a bi-radiant oven known to DOE was tested in the 

1970s. The technology requires a low-emissivity cavity, electronic controls, and highly 

absorptive cooking utensils. The need for specialized cookware and cavity maintenance 
73

issues negatively impact consumer utility. Therefore, DOE screened out bi-radiant ovens 

from further analysis.

DOE is not aware of any ovens that utilize halogen lamps alone as the heating 

element, and no data were found or submitted to demonstrate how efficiently halogen 

elements alone perform relative to conventional ovens. DOE believes that it would not be 

practicable to manufacture, install, and service halogen lamps for use in consumer 

cooking products on the scale necessary to serve the relevant market at the time of the 

standard’s effective date. Therefore, DOE screened out halogen lamp ovens.

Whirlpool commented that oven door windows are a key consumer utility and 

purchase driver, and there may even be more energy used from increased door openings 

to check on food (associated with no oven door window) versus looking through the 

window. (Whirlpool, STD No. 13 at p. 4) DOE notes that the 2009 TSD reported a small 

annual energy savings associated with no oven door window, but that consumer practices 

of opening the door to inspect the food while cooking could negate any benefit. 

Comments during manufacturer interviews and comments from stakeholders in previous 

rulemakings agreed that removing the window was not a feasible option for most ovens. 

63 FR 48038, 48040-48041 (Sep. 8, 1998); 72 FR 64432, 64456 (Nov. 15, 2007). 

Reduced consumer utility, and the potential for increased energy use along with 

decreased safety due to the additional door openings, justify elimination of this design 

option from further analysis. In addition, DOE addresses the efficiency impact of double-
74

pane or other highly insulated oven door windows by means of the reduced conduction 

losses design option, which has been retained for further analysis. 

Whirlpool commented that reflective surfaces would be very difficult to 

implement correctly. Whirlpool stated that there would be reduced consumer savings if 

the surface gets dirty and reduced consumer functionality from the appearance of stains. 

(Whirlpool, STD No. 13 at p. 4) In the 2009 TSD, DOE noted that manufacturers have 

stated that it has been very difficult to obtain satisfactory cooking performance with 

reflective surfaces and that reflective surfaces degrade after the first baking function and 

continue to degrade through the life of the product. DOE also noted in the 2009 TSD that 

is uncertain whether, or how much, energy savings is realizable with this technology 

option. Because of the uncertainty of the potential energy savings and the general lack of 

sophistication in the technology in terms of maintaining clean, reflective surfaces over 

the lifetime of the product, DOE screened out this technology option from further 

analysis.

2. Remaining Technologies

Based on the screening analysis, DOE considered the design options listed in 

Table IV-6 for conventional ovens.
75

Table IV-6. Remaining Conventional Oven Technology Options

1. Electronic spark ignition (gas only)

2. Forced convection 

3. Improved insulation 

4. Improved door seals (standard ovens only)

5. Oven separator (electric only)

6. Reduced conduction losses

7. Reduced vent rate

8. Low-standby-loss electronic controls

9. Optimized burner and cavity design (gas only)

C. Engineering Analysis

The engineering analysis estimates the cost-efficiency relationship of products at 

different levels of increased energy efficiency. This relationship serves as the basis for 

the cost-benefit calculations for consumers, manufacturers, and the Nation. In 

determining the cost-efficiency relationship, DOE estimates the increase in manufacturer 

cost associated with increasing the efficiency of products from the baseline up to the 

maximum technologically feasible (“max-tech”) efficiency level for each product class.

1. Methodology

DOE typically structures the engineering analysis using one of three approaches: 

(1) the design-option approach, which provides the incremental costs of adding design 

options to a baseline model that will improve its efficiency (i.e., lower its energy use); (2) 

the efficiency-level approach, which provides the incremental costs of moving to higher 

energy efficiency levels, without regard to the particular design option(s) used to achieve 

such increases; and (3) the reverse-engineering (or cost-assessment) approach, which 

provides “bottom-up” manufacturing cost assessments for achieving various levels of 

increased efficiency, based on teardown analyses (or physical teardowns) that provide
76

detailed data on costs for parts and material, labor, overhead, and equipment, tooling, 

conveyor, and space investments for models that operate at particular efficiency levels. 

In the February 2014 RFI, DOE stated that in order to create the cost-efficiency 

relationship, it anticipated having to structure its engineering analysis using a designoption approach, supplemented by reverse engineering (physical teardowns and testing of 

existing products in the market) to identify the incremental cost and efficiency 

improvement associated with each design option or design option combination. In 

addition, DOE stated that it intends to consider cost-efficiency data from the 2009 TSD. 

79 FR 8337, 8347 (Feb. 12, 2014). DOE maintained this approach for this NOPR. DOE 

also conducted interviews with manufacturers of conventional ovens to develop a deeper 

understanding of the various combinations of design options used to increase product 

efficiency, and their associated manufacturing costs. 

2. Product Testing and Reverse Engineering 

To develop the cost-efficiency relationships for the engineering analysis, DOE 

conducted testing and reverse engineering teardowns on products available on the market. 

Because there are no performance-based energy conservation standards or energy 

reporting requirements for conventional cooking products, DOE selected test units based 

on performance-related features and technologies advertised in product literature. DOE’s 

test sample included 1 gas wall oven, 7 gas ranges, 5 electric wall ovens, and 2 electric 

ranges for a total of 15 conventional ovens covering all of the product classes considered 

in this NOPR. The test units are described in detail in chapter 5 of the NOPR TSD.
77

Each test unit was tested according to the oven test procedure clarifications 

proposed in the December 2014 TP SNOPR. DOE then conducted physical teardowns on 

each test unit to develop a manufacturing cost model and to evaluate key design features.

DOE supplemented its reverse engineering analyses by conducting manufacturer 

interviews to obtain feedback on efficiency levels, design options, inputs for the 

manufacturing cost model, and resulting manufacturing costs. DOE used the results from 

testing, reverse engineering, and manufacturer interviews to develop the efficiency levels 

and manufacturing costs discussed in sections IV.C.3 and IV.C.4.

Table IV-7 and Table IV-8 present the testing results for the conventional gas and 

electric cooking tops, respectively.ovens, respectively. 

Table IV-7. DOE Conventional Gas Oven Test Results

Test

Unit 

# Oven Product Class

Burner 

Input Rate 

(Btu/h)

Cavity 

Volume 

(ft3)

Ignition 

Type

Convection 

(Y/N)

IAEC 

(kBtu/yr)

1 Gas Standard – Freestanding 18,000 4.8 Spark N 1341.4

2 Gas Standard – Freestanding 18,000 4.8 Glo-bar N 1503.7

3 Gas Self-Clean - Freestanding 18,000 5.0 Glo-bar Y 1419.0

4 Gas Standard – Freestanding 16,500 4.4 Glo-bar N 1516.6

5 Gas Self-Clean – Built-in/Slide-in 13,000 2.8 Glo-bar N 1171.3

6 Gas Standard – Freestanding 28,000 5.3 Glo-bar Y 2078.9

7 Gas Standard – Built-in/Slide-in 27,000 4.4 Glo-bar Y 1938.0

8 Gas Standard – Freestanding 30,000 5.4 Glo-bar Y 2315.1

Table IV-8. DOE Conventional Electric Oven Test Results

Test 

Unit 

# Oven Product Class

Heating 

Element 

Wattage (W)

Cavity 

Volume 

(ft3)

Convectio

n (Y/N)

IAEC 

(kWh/yr)

1 Electric Self-Clean – Freestanding 3,000 5.9* Y 266.2
78

2 Electric Standard – Freestanding 2,000 2.4 N 213.7

3 Electric Self-Clean – Built-in/Slide-in 3,400 2.7 N 158.7

4 Electric Standard – Built-in/Slide-in 2,600 4.3 N 287.8

5 Electric Self-Clean – Built-in/Slide-in 2,600 4.3 N 308.8

6 Electric Self-Clean – Built-in/Slide-in 2,600 4.3 Y 341.8

7 Electric Self-Clean – Built-in/Slide-in 2,800 4.3 N 370.0

* Test Unit 1 was equipped with an oven separator that allowed for splitting the single cavity into two 

separate smaller cavities with volumes of 2.7 ft3 and 3.0 ft3

.

3. Efficiency Levels

a. Baseline Efficiency Levels

A baseline unit is a product that just meets current Federal energy conservation 

standards. DOE uses the baseline unit for comparison in several phases of the NOPR 

analyses, including the engineering analysis, LCC analysis, PBP analysis, and NIA. To 

determine energy savings that will result from an amended energy conservation standard, 

DOE compares energy use at each of the higher energy ELs to the energy consumption of 

the baseline unit. Similarly, to determine the changes in price to the consumer that will 

result from an amended energy conservation standard, DOE compares the price of a unit 

at each higher EL to the price of a unit at the baseline.

As part of the February 2014 RFI, DOE initially developed baseline efficiency 

levels by considering the current standards for conventional gas ovens and the baseline 

efficiency levels for conventional electric ovens from the previous standards rulemaking 

analysis. DOE developed tentative baseline efficiency levels for the February 2014 RFI 

considering the current test procedure in appendix I. The baseline efficiency levels 

proposed in the February 2014 RFI are presented in Table IV-9. DOE developed baseline 
79

efficiency levels for standby mode and off mode based on test data presented in the 

microwave oven test procedure SNOPR.

25 For fan-only mode, DOE developed baseline 

efficiency levels considering the additional annual energy consumption in fan-only mode

based on test data presented in an SNOPR for the conventional cooking products test 

procedure. 77 FR 31443, 31449 (May 25, 2012). The efficiency levels presented in the 

February 2014 RFI are based on an oven with a cavity volume of 3.9 ft3

.

Table IV-9. February 2014 RFI Conventional Oven Baseline Efficiency Levels

Product Class

2009 Standards Rulemaking

Proposed IAEC

Energy 

Factor 

(EF)

Annual Energy 

Consumption26

Electric Oven – Standard Oven with or 

without a Catalytic Line 0.1066 274.9 kWh 370.0 kWh

Electric Oven – Self-Clean Oven 0.1099 266.6 kWh 360.0 kWh

Gas Oven – Standard Oven with or 

without a Catalytic Line 0.0536 1656.7 kBtu 2076.5 kBtu

Gas Oven – Self-Clean Oven 0.0540 1644.4 kBtu 1965.0 kBtu

AHAM commented that, while they agreed fan-only mode should be considered, 

DOE should gather more data before determining appropriate baseline levels. AHAM 

stated that DOE should update the data collected during the test procedure rulemaking 

and request information from manufacturers on the energy use in fan-only mode. 

(AHAM, STD No. 9 at p. 6) Whirlpool commented that fan-only mode power varies 

greatly for ovens and depends on the size of the oven, insulation, dual or single speed fan, 

 25 In the May 2012 microwave oven test procedure SNOPR, DOE considered test procedure amendments 

for measuring the standby mode and off mode energy consumption of combined cooking products and, as a 

result, presented standby power data for microwave ovens, conventional cooking tops, and conventional 

ovens. 77 FR 28805, 28811 (May 16, 2012). 26 DOE notes that the previous conventional cooking products test procedure in appendix I included the 

clock energy consumption. As a result, DOE subtracted the clock energy consumption before adding the 

standby and off mode energy consumption when considering integrated efficiency levels for this standards 

rulemaking.
80

single or double oven, etc. Whirlpool stated that it does not currently have fan-only mode 

data and cannot comment on the appropriateness of DOE’s assumptions for fan-only 

power. (Whirlpool, STD No. 13 at p. 6)

DOE developed baseline efficiency levels for this NOPR considering both data 

from the previous standards rulemaking and the measured energy use for the test units. 

As discussed in section IV.C.2, DOE conducted testing for all units in its test sample to 

measure IAEC, which includes energy use in active mode (including fan-only mode) and 

standby mode. DOE also requested energy use data as part of the manufacturer 

interviews. However, because manufacturers are not currently required to conduct testing 

according to the DOE test procedure, very little energy use information was available.

The baseline efficiency levels for this NOPR differ from those presented in the 

February 2014 RFI. DOE compared the minimum cooking efficiency measured in its test 

sample to the minimum cooking efficiency levels assumed for the previous standards 

rulemaking analysis. Often, the lowest measured efficiency in DOE’s test sample for this 

NOPR was lower than the values for the previous rulemaking. 

To update the baseline efficiency levels for conventional ovens, first DOE 

derived a new relationship between IAEC and cavity volume as discussed in section 

I.A.1.c. Using the slope from the previous rulemaking, DOE selected new intercepts 

corresponding to the ovens in its test sample with the lowest efficiency, so that no ovens 

in the test sample were cut off by the baseline curve. DOE then set baseline standby 
81

energy consumption for conventional ovens equal to that of the oven/range with the 

highest standby energy consumption in DOE’s test sample to maintain the full 

functionality of controls for consumer utility. While only DOE test data was available to 

validate the baseline equation for gas ovens, DOE compared the new baseline equation 

for electric ovens with data available in the Natural Resources Canada (NRCan) 

databases, which showed that DOE’s assumptions for slopes and intercepts reasonably 

represented the market. A detailed discussion of DOE’s derivation of the cavity volume 

relationship is provided Chapter 5 of the NOPR TSD.

In addition to the product classes proposed in the February 2014 RFI, DOE is 

also proposing separate product classes for freestanding and built-in/slide-in ovens as 

discussed in section IV.A.2. As a result, DOE developed separate baseline efficiency 

levels for each proposed product class based on testing conducted for this NOPR. The 

proposed baseline efficiency levels for this NOPR are presented in Table IV-10. After 

receiving manufacturer feedback and reviewing products currently on the market, DOE 

determined that a cavity volume of 3.9 ft3 no longer represents the market average. Thus, 

efficiency levels are based on an oven with a cavity volume of 4.3 ft3. Additional details 

on the development of the proposed baseline efficiency levels are included in chapter 5 of 

the NOPR TSD.
82

Table IV-10. Conventional Oven Baseline Efficiency Levels

Product Class Sub Type Proposed IAEC*

Electric Oven – Standard Oven with or 

without a Catalytic Line

Freestanding 294.5 kWh

Built-in/Slide-in 301.5 kWh

Electric Oven – Self-Clean Oven Freestanding 355.0 kWh

Built-in/Slide-in 361.1 kWh

Gas Oven – Standard Oven with or 

without a Catalytic Line

Freestanding 2118.2 kBtu

Built-in/Slide-in 2128.1 kBtu

Gas Oven – Self-Clean Oven Freestanding 1883.8 kBtu

Built-in/Slide-in 1893.7 kBtu

* Proposed IAEC baseline efficiency levels are normalized based on a 4.3 ft3 volume oven. 

b. Incremental Efficiency Levels

For each product class, DOE analyzes several efficiency levels and determines the 

incremental cost at each of these levels. For the February 2014 RFI, DOE tentatively 

proposed the incremental efficiency levels presented in Table IV-11 through Table 

IV-14.. DOE developed these levels based primarily on the efficiency levels presented in 

the 2009 TSD, adjusted to account for the proposed and amended test procedures. DOE 

also considered efficiency levels for standby mode and off mode associated with 

changing conventional linear power supplies to switch-mode power supplies and the 

Commission of the European Communities Regulation 1275/2008 (hereinafter 

“Ecodesign regulation”), which requires products to have a maximum standby power of 1 

W. 79 FR 8337, 8345-8346 (Feb. 12, 2014).The efficiency levels presented in the 

February 2014 RFI are based on an oven with a cavity volume of 3.9 ft3

. 
83

Table IV-11. February 2014 RFI Gas Standard Oven Efficiency Levels

Level Efficiency Level Source

Proposed IAEC

(kBtu)

Baseline 2009 TSD (Electric Glo-bar Ignition) 2076.5

1 2009 TSD (Electric Glo-bar Ignition) + SMPS 1932.0

2 2009 TSD (Improved Insulation) + SMPS 1844.2

3 2009 TSD (2 + Electronic Spark Ignition) + 

SMPS 1717.7

4 2009 TSD (3 + Improved Door Seals) + SMPS 1702.6

5 2009 TSD (4 + Reduced Vent Rate) + SMPS 1695.4

6 2009 TSD (5 + Reduced Conduction Losses) + 

SMPS 1685.9

7 2009 TSD (6 + Forced Convection) + SMPS 1636.0

8 2009 TSD (7) + 1W Standby 1499.1

Table IV-12. February 2014 RFI Gas Self-Clean Oven Efficiency Levels

Level Efficiency Level Source

Proposed IAEC

(kBtu)

Baseline 2009 TSD (Baseline) 1965.0

1 2009 TSD (Baseline) + SMPS 1820.5

2 2009 TSD (Forced Convection) + SMPS 1596.9

3 2009 TSD (2) + Electronic Spark Ignition + 

SMPS 1482.3

4 2009 TSD (3 + Improved Door Seals) + SMPS 1472.0

5 2009 TSD (4 + Reduced Conduction Losses) + 

SMPS 1467.8

6 2009 TSD (5) + 1 W Standby 1330.9

Table IV-13. February 2014 RFI Electric Standard Oven Efficiency Levels

Level Efficiency Level Source

Proposed IAEC

(kWh)

Baseline 2009 TSD (Baseline) 370.0

1 2009 TSD (Baseline) + SMPS 327.7

2 2009 TSD (Reduced Vent Rate) + SMPS 316.1

3 2009 TSD (2 + Improved Insulation) + SMPS 304.8

4 2009 TSD (3 + Improved Door Seals) + SMPS 300.9

5 2009 TSD (4 + Reduced Conduction Losses) + 

SMPS 300.3

6 2009 TSD (5 + Forced Convection) + SMPS 295.2

7 2009 TSD (6) + 1 W Standby 255.0
84

Table IV-14. February 2014 RFI Electric Self-Clean Oven Efficiency Levels

Level Efficiency Level Source

Proposed IAEC

(kWh)

Baseline 2009 TSD (Baseline) 360.0

1 2009 TSD (Baseline) + SMPS 317.7

2 2009 TSD (Reduced Conduction Losses) + 

SMPS 317.0

3 2009 TSD (2 + Forced Convection) + SMPS 312.0

4 2009 TSD (3) + 1 W Standby 271.9

In response to the February 2014 RFI, AHAM disagreed with DOE’s

consideration of the 1-W Ecodesign regulation standby requirements because products 

sold in the European Union are different from the products sold in the United States.

(AHAM, STD No. 9 at p. 6) DOE reevaluated the efficiency levels associated with 

standby power improvements based on design options identified during product testing 

and reverse engineering rather than considering an efficiency level specifically associated 

with the 1-W Ecodesign regulation standby requirement.

Laclede commented that DOE’s assumption of 3.5 amp ×110 volt continuous 

consumption of a typical glo-bar ignition module would mean its consuming 385 W 

(0.385 kW) per hour. Laclede stated that they believe this may be the worst-case scenario 

and may make it appear that further efficiency improvements are possible. However, 

Lacelede stated that further efficiency improvements in glo-bar may lead to higher costs 

for gas cooking products without sufficient economic benefits. Laclede’s testing data 

indicates glo-bar ignition system consumption of only 0.16 kWh. (Laclede, STD No. 8 at 

p. 2) Laclede also commented that it appears that DOE considers the electric load from 

glo-bar ignition systems as of no value to the thermal process of cooking in the oven. 

Laclede contends this electric resistance load in gas ovens most likely does contribute to 
85

the cooking process and DOE will need to provide transparent and robust analyses to 

explain this relationship. (Laclede, STD No. 8 at pp. 2–3) 

Based on DOE’s testing of units in its test sample, electric glo-bar ignition 

systems consumed between 330 W and 450 W and ranged between 0.141 kWh and 0.261 

kWh per cycle, with an average of 0.202 kWh per cycle. DOE notes that the glo-bar 

energy consumption may vary depending on burner and cavity design (e.g., burner input 

rating, cavity volume). DOE also notes that the glo-bar ignition system was not power on 

throughout the entire cooking cycle and only consumed power when gas flow to the 

burner was on, turning off when the burner cycled off. As discussed above, DOE updated 

its efficiency level analysis based on testing conducted for this NOPR. Any contribution 

of the glo-bar ignition system to heating the load would be accounted for in testing 

according to the DOE test procedure in Appendix I. 

For the NOPR, DOE developed incremental efficiency levels for each product 

class by first considering information from the 2009 TSD. In cases where DOE identified 

design options during testing and reverse engineering teardowns, DOE updated the 

efficiency levels based on the tested data. In addition to the efficiency levels associated 

with design options identified in the February 2014 RFI, DOE also included an efficiency 

level for electric ovens based on a test unit equipped with an oven separator that allowed 

for reducing the cavity volume that is used for cooking. For conventional gas ovens, 

DOE’s testing showed that energy use was correlated to oven burner and cavity design 

(e.g., thermal mass of the cavity and racks) and can be significantly reduced when 
86

optimized. DOE determined the efficiency level associated with optimized burner and 

cavity design based on the tested units normalized for cavity volume. 

Table IV-15 through Table IV-18 show the incremental efficiency levels for each 

product class, including whether the efficiency level is from the 2009 TSD or based on 

testing for the NOPR. The efficiency levels are normalized based on an oven with a 

cavity volume of 4.3 ft3. Details of the derivations of each efficiency level are provided in 

chapter 5 of the NOPR TSD.

Table IV-15. Electric Standard Oven Efficiency Levels

Level

Efficiency Level 

Source Design Option

Proposed IAEC (kWh)

Freestanding

Built-in / 

Slide-in

Relative % 

Decrease in 

IAEC

Baseline NOPR Testing Baseline 294.5 301.5 -

1 NOPR Testing Baseline + SMPS 284.6 291.4 -3.37%

2 2009 TSD 1 + Reduced Vent Rate 271.7 278.2 -4.51%

3 2009 TSD 2 + Improved Insulation 259.2 265.4 -4.61%

4 2009 TSD 3 + Improved Door Seals 254.9 261.0 -1.64%

5 NOPR Testing 4 + Forced Convection 244.6 250.5 -4.04%

6 NOPR Testing 5 + Oven Separator 207.8 212.8 -15.04%

7 2009 TSD 6 + Reduced Conduction Losses 207.3 212.2 -0.27%

Table IV-16. Electric Self-Clean Oven Efficiency Levels

Level

Efficiency Level 

Source Design Option

Proposed IAEC (kWh)

Freestanding

Built-in / 

Slide-in

Relative % 

Decrease in 

IAEC

Baseline NOPR Testing Baseline 355.0 361.1 -

1 NOPR Testing Baseline + SMPS 345.1 351.0 -2.78%

2 NOPR Testing 1 + Forced Convection 327.2 332.7 -5.21%

3 NOPR Testing 2 + Oven Separator 278.9 283.7 -14.74%

4 2009 TSD 3 + Reduced Conduction Losses 278.1 282.9 -0.29%
87

Table IV-17. Gas Standard Oven Efficiency Levels

Level

Efficiency Level 

Source Design Option

Proposed IAEC (kBtu)

Freestanding

Built-in / 

Slide-in

Relative %

Decrease in 

IAEC

Baseline 2009 TSD Baseline 2118.2 2128.1 -

1 NOPR Testing Baseline + Optimized Burner/Cavity 1649.3 1657.0 -22.14%

2 NOPR Testing 1 + SMPS 1614.7 1622.2 -2.10%

3 NOPR Testing 2 + Electronic Spark Ignition 1490.7 1497.7 -7.68%

4 2009 TSD 3 + Improved Insulation 1414.8 1421.5 -5.09%

5 2009 TSD 4 + Improved Door Seals 1400.6 1407.2 -1.01%

6 NOPR Testing 5 + Forced Convection 1355.6 1362.0 -3.21%

7 2009 TSD 6 + Reduced Conduction Losses 1347.0 1353.3 -0.64%

Table IV-18. Gas Self-Clean Oven Efficiency Levels

Level

Efficiency Level 

Source Design Option

Proposed IAEC (kBtu)

Freestanding

Built-in / 

Slide-in

Relative % 

Decrease in 

IAEC

Baseline 2009 TSD Baseline 1883.8 1893.7 -

1 NOPR Testing Baseline + SMPS 1848.2 1858.0 -1.89%

2 NOPR Testing 1 + Electronic Spark Ignition 1668.7 1677.5 -9.71%

3 NOPR Testing 2 + Forced Convection 1596.3 1604.7 -4.34%

4 2009 TSD 3 + Reduced Conduction Losses 1591.0 1599.4 -0.33%

c. Relationship between IAEC and Oven Cavity Volume 

The conventional oven efficiency levels detailed above are predicated upon 

baseline ovens with a cavity volume of 4.3 ft3

. Based on DOE’s testing of conventional 

gas and electric ovens and discussions with manufacturers, IAEC scales with oven cavity 

volume due to the fact that larger ovens have higher thermal masses and larger volumes 

of air (including larger vent rates) than smaller ovens. Because the DOE test procedure 

for measuring IAEC uses a fixed test load size, larger ovens with higher thermal mass 

will have a higher measured IAEC. As a result, DOE considered available data to 

characterize the relationship between IAEC and oven cavity volume. 
88

DOE established the slopes by first evaluating the data from the 2009 TSD, which 

presented the relationship between measured energy factor (EF) and cavity volume, then 

translated from EF to IAEC considering the range of cavity volume for the majority of 

products available on the market. DOE believes these slopes continue to be relevant 

based on DOE’s testing. For electric ovens, DOE considered the data for standard and 

self-clean ovens available in the Natural Resources Canada product databases.27 DOE 

notes that this data is based on the same test procedure considered for the previous DOE 

standards rulemaking, and as a result, DOE believes the slopes based on these larger 

datasets are relevant for this analysis. The intercepts for each efficiency level were then 

chosen so that the equations pass through the desired IAEC corresponding to a particular 

volume. Values for the slopes and intercepts for each conventional oven product class are 

presented in Table IV-19 and Table IV-20. Additional details regarding the derivation of 

the slopes and intercepts for the oven IAEC versus cavity volume relationship are 

presented in chapter 5 of the NOPR TSD.

 27 Available at: http://oee.nrcan.gc.ca/pml-lmp/index.cfm?action=app.searchrecherche&appliance=OVENS_E. 
89

Table IV-19. Slopes and Intercepts of Electric Oven IAEC versus Cavity Volume 

Relationship

Level

Standard Electric Ovens Self-Clean Electric Ovens

Slope = 31.8 Slope = 42.3

Freestanding 

Intercepts

Built-in / Slide-in 

Intercepts

Freestanding 

Intercepts

Built-in / Slide-in 

Intercepts

Baseline 157.74 164.78 173.12 179.18

1 147.82 154.62 163.24 169.13

2 134.98 141.47 145.28 150.86

3 122.45 128.64 97.05 101.81

4 118.20 124.29 96.24 100.98

5 107.91 113.75 - -

6 71.10 76.07 - -

7 70.54 75.49 - -

Table IV-20. Slopes and Intercepts of Gas Oven IAEC versus Cavity Volume 

Relationship

Level

Standard Gas Ovens Self-Clean Gas Ovens

Slope = 214.4 Slope = 214.4

Freestanding 

Intercepts

Built-in / Slide-in 

Intercepts

Freestanding 

Intercepts

Built-in / Slide-in 

Intercepts

Baseline 1196.3 1206.2 961.8 971.8

1 727.4 735.1 926.3 936.0

2 692.7 700.3 746.7 755.5

3 568.8 575.8 674.4 682.8

4 492.9 499.5 669.1 677.5

5 478.7 485.2 - -

6 433.7 440.1 - -

7 425.1 431.4 - -

4. Incremental Manufacturing Production Cost Estimates

Based on the analyses discussed above, DOE developed the cost-efficiency results

for each product class shown in Table IV-21. Where available, DOE developed 

incremental manufacturing production costs (MPCs) based on manufacturing cost 

modeling of test units in its sample featuring the proposed design options. For design 

options that were not observed in DOE’s sample of test units for this NOPR, DOE used 

the incremental manufacturing costs developed as part of the 2009 TSD, then adjusted the 

values to reflect changes in the Bureau of Labor Statistics’ Producer Price Index (PPI) for 
90

household cooking appliance manufacturing.

28 DOE notes that the estimated incremental 

MPCs would be equivalent for the freestanding and built-in/slide-in oven product classes.

Table IV-21. Conventional Oven Incremental Manufacturing Product Cost (2014$)

Level

Electric Ovens Gas Ovens

Standard Self-Clean Standard Self-Clean

Baseline - - - -

1 $0.82 $0.82 $0.00 $0.82

2 $2.76 $25.00 $0.82 $7.31

3 $7.89 $56.74 $7.31 $27.96

4 $10.22 $61.93 $12.44 $33.15

5 $34.40 - $14.77 -

6 $66.14 - $35.43 -

7 $70.36 - $39.74 -

5. Consumer Utility

In determining whether a standard is economically justified, EPCA requires DOE 

to consider “any lessening of the utility or the performance of the covered products likely 

to result from the imposition of the standard.” (42 USC 6295(o)(2)(B)(i)(IV)) 

In a response to the December 2014 TP SNOPR, Sub Zero commented that 

heavier gauge materials provide customers with extended product life, quality, 

functionality, and durability. Sub Zero also commented that that full extension oven racks 

provided in these products provide consumer utility. (Sub Zero, TP No. 20 at p. 3)

 28 Available at: http://www.bls.gov/ppi/. 
91

In response to the February 2014 RFI, AHAM and Whirlpool commented that 

new energy conservation standards could likely impact the utility of conventional ovens

in the following ways: 

• A standard could lower burner input rates, which will impact cooking times. 

Higher burner input rates allow for quicker cooking time, which is an important 

consumer utility; 

• A standard could result in smaller oven windows. Consumers desire larger 

windows in order to view the food during cooking without opening the oven door. 

Smaller windows could result in more door openings, and thus increase energy 

use; 

• A standard could also result in the removal of accent lighting and large displays 

which are preferred consumer features. There is reduced consumer utility from 

further reducing standby power from what products use today. According to 

Whirlpool, the market is still pushing manufacturers to add more advanced 

electronics that use more standby power. (AHAM, STD No. 9 at p. 7; Whirlpool, 

STD No. 13 at pp. 5, 8).

Accordingly, AHAM and Whirlpool opposed amendment of the existing 

standards for cooking products. AHAM and Whirlpool stated that not only would 

amended standards fail to be technologically feasible or economically justified, but they 

would also impact the utility of cooking products. (AHAM, STD No. 9 at p. 7; 

Whirlpool, STD No. 13 at p. 8). 
92

DOE conducted the engineering analysis by considering design options that are 

consistent with products currently on the market, and as a result, DOE did not consider 

changes that would result in smaller oven windows or removal of accent lighting and 

display features. In addition, as discussed in section IV.A.2, DOE noted that gas ovens

with higher burner input rates did not have significantly faster cooking times when tested 

according to the DOE test procedure in Appendix I. This is likely due in large part to the 

fact that gas-cooking products with higher burner input rates marketed as commercialstyle often have significantly larger thermal masses, which absorb a significant amount of 

additional heat. DOE is also not aware of data justifying how added thermal mass 

improves durability, extends product life, or provides additional consumer utility as 

compared to standard residential-style ovens. As a result, DOE does not believe that any 

of the design options and efficiency levels considered in this NOPR would impact the 

consumer utility of conventional ovens, as suggested by AHAM and Whirlpool. However 

DOE welcomes continued feedback on this topic, including how the efficiency levels and 

technology options presented in Table IV-15 through Table IV-18 may affect consumer 

utility (see section VII.E).

D. Markups Analysis

The markups analysis develops appropriate markups in the distribution chain to 

convert the MPC estimates derived in the engineering analysis to consumer prices. At 

each step in the distribution channel, companies mark up the price of the product to cover 

business costs and profit margin. For conventional cooking products, the main parties in 

the distribution chain are manufacturers and retailers.
93

Thus, DOE analyzed a manufacturer-to-consumer distribution channel consisting 

of three parties: (1) the manufacturers of the products; (2) the retailers purchasing the 

products from manufacturers and selling them to consumers; and (3) the consumers who 

purchase the products.

The manufacturer markup converts MPC to manufacturer selling price (MSP). 

DOE developed an average manufacturer markup by examining the annual Securities and 

Exchange Commission (SEC) 10-K reports filed by publicly traded manufacturers 

primarily engaged in appliance manufacturing and whose combined product range 

includes conventional cooking products. 

For retailers, DOE developed separate markups for baseline products (baseline 

markups) and for the incremental cost of more efficient products (incremental markups). 

Incremental markups are coefficients that relate the change in the MSP of higherefficiency models to the change in the retailer sales price. DOE relied on economic data 

from the U.S. Census Bureau to estimate average baseline and incremental markups.29

In addition to developing manufacturer and retailer markups, DOE included sales 

taxes in the final appliance retail prices. DOE used an Internet source, the Sales Tax 

Clearinghouse, to calculate applicable sales taxes.

 29 U.S. Census, 2007 Annual Retail Trade Survey (ARTS), Electronics and Appliance Stores sectors
94

Chapter 6 of the NOPR TSD provides details on DOE’s development of markups 

for conventional ovens.

E. Energy Use Analysis

The energy use analysis provides estimates of the annual energy consumption of 

ovens at the considered efficiency levels. DOE uses these values in the LCC and PBP 

analyses and in the NIA to establish the savings in consumer operating costs at various 

product efficiency levels. DOE developed energy consumption estimates for all product 

classes analyzed in the engineering analysis.

For the April 2009 Final Rule, DOE utilized a 2004 California Residential 

Appliance Saturation Study (RASS) 30 and a Florida Solar Energy Center (FSEC) study 31

to establish representative annual energy use values for cooking products. For this NOPR, 

DOE used an update to the California RASS32 and a recent FSEC study33 to establish 

representative annual energy use values for conventional ovens. These studies confirmed 

that annual cooking energy use has been consistently declining since the late 1970s. 

DOE’s energy use analysis estimated the range of energy use of cooking products 

 30 California Energy Commission, California Statewide Residential Appliance Saturation Study (June 

2004). 

31 D.S. Parker. “Research Highlights from a Large Scale Residential Monitoring Study in a Hot Climate,” 

Proceeding of International Symposium on Highly Efficient Use of Energy and Reduction of its 

Environmental Impact (January 2002). 

32 California Energy Commission, Residential Appliance Saturation Survey (RASS) (2009). 33 Parker, D., Fairey, P., Hendron, R., “Updated Miscellaneous Electricity Loads and Appliance Energy 

Usage Profiles for Use in Home Energy Ratings, the Building America Benchmark Procedures and Related 

Calculations,” Florida Solar Energy Center (FSEC) (2010).
95

in the field, i.e., as they are actually used by consumers. Because energy use by 

residential cooking products varies greatly based on consumer usage patterns, DOE 

established a range of energy use. The Energy Information Administration (EIA)’s

2009 Residential Energy Consumption Survey (RECS 2009) is one source for estimating 

the range of energy use for cooking products. 34 DOE used data from RECS 2009 for this 

NOPR to establish this range. 35 Although RECS 2009 does not provide the annual 

energy consumption of the cooking product, it does provide the frequency of cooking 

use. DOE was unable to use the frequency of use to calculate the annual energy 

consumption using a bottom-up approach, as data in RECS did not include information 

about the duration of a cooking event to allow for an annual energy use calculation. DOE 

therefore relied on California RASS and FSEC studies to establish the annual energy 

consumption of a cooking product.

From RECS 2009, DOE developed household samples for each product class. For 

each household using a conventional cooking product, RECS provides data on the 

frequency of use and number of meals cooked in the following bins: (1) less than once 

per week, (2) once per week, (3) a few times per week, (4) once per day, (5) two times 

per day, and (6) three or more times per day. Thus, DOE utilized the frequency of use to 

define the variability of the annual energy consumption. Conducting the analysis in this 

manner captures the observed variability in annual energy consumption while 

 34 U.S. Department of Energy: Energy Information Administration, Residential Energy Consumption 

Survey: 2009 RECS Survey Data (2013) (Available at: 

http://www.eia.gov/consumption/residential/data/2009/). 35 RECS 2009 is based on a sample of 12,083 households statistically selected to represent 113.6 million 

housing units in the United States. RECS 2009 data are available for 27 geographical areas (including 16 

large States) (Available at: www.eia.gov/consumption/residential/).
96

maintaining the average annual energy consumption. To determine the variability of 

cooking product energy consumption, DOE first equated the weighted-average cooking 

frequency from RECS with the average energy use values based on CA RASS and FSEC 

studies. DOE then varied the annual energy consumption for each RECS household 

based on its reported cooking frequency. Thus, DOE utilized the range in frequency of 

use to define the variability of the annual energy consumption. 

Chapter 7 of the NOPR TSD describes the energy use analysis in detail. 

AHAM expressed objections to DOE's reliance on RECS 2009 for analyses, 

stating that it is difficult, if not impossible, to compare the results to the energy use 

measured in a controlled test procedure situation. (AHAM, STD No. 9 at p. 7) DOE 

utilized RECS 2009 only to characterize variability of usage across various consumers. 

For representative energy use DOE relied on other studies and surveys to establish 

baseline energy consumption.

Whirlpool noted that cooking product energy use is unique from other major 

appliances in that there is a wide variation amongst consumers, with consumer behavior 

as a key determinant. (Whirlpool, STD No. 13 at p. 8) DOE acknowledges that consumer 

behavior is a key determinant of the eventual energy use by the product. To characterize 

the variability in usage across consumers, DOE utilized data from RECS 2009, as 

described above.
97

F. Life-Cycle Cost and Payback Period Analysis

The purpose of the LCC and PBP analysis is to evaluate the economic impacts of 

potential energy conservation standards for cooking products on individual consumers. 

The LCC is the total consumer expense over the life of the product, including purchase 

and installation expense and operating costs (energy expenditures, repair costs, and 

maintenance costs). The PBP is the number of years it would take for the consumer to 

recover the increased costs of purchasing a higher efficiency product through energy 

savings. To calculate LCC, DOE discounted future operating costs to the time of 

purchase and summed them over the lifetime of the product. 

For any given efficiency level, DOE measures the change in LCC relative to an 

estimate of the base-case product efficiency distribution. The base-case estimate reflects 

the market in the absence of new or amended energy conservation standards, including 

the market for products that exceed the current energy conservation standards. In 

contrast, the PBP is measured relative to the baseline product.

DOE calculated the LCC and payback periods for conventional cooking tops and

ovens for a nationally representative set of housing units selected from RECS 2009. By 

using a representative sample of households, the analysis captured the variability in 

energy consumption and energy prices associated with cooking product use.

For each sample household, DOE determined the energy consumption for the 

cooking product and the appropriate energy price. DOE first calculated the LCC 
98

associated with a baseline cooking product for each household. To calculate the LCC 

savings and PBP associated with products meeting higher efficiency standards, DOE 

substituted the baseline unit with more efficient designs.

As part of the LCC and PBP analyses, DOE developed data that it used to 

establish product prices, installation costs, annual household energy consumption, energy 

prices, maintenance and repair costs, product lifetime, and discount rates. Inputs to the 

LCC and PBP analysis are categorized as: (1) inputs for establishing the total installed 

cost and (2) inputs for calculating the operating costs. DOE models the uncertainty and 

the variability in the inputs to the LCC and PBP analysis using Monte Carlo simulations

and probability distributions.36

The following sections contain comments on the inputs and key assumptions of 

DOE’s LCC and PBP analysis and explain how DOE took these comments into 

consideration. Chapter 8 of the TSD accompanying this notice contains detailed 

discussion of the methodology and data utilized for the LCC and PBP analysis. 

 36 The Monte Carlo process statistically captures input variability and distribution without testing all 

possible input combinations. Therefore, while some atypical situations may not be captured in the analysis, 

DOE believes the analysis captures an adequate range of situations in which the conventional cooking 

products operate.
99

1. Product Costs

To calculate the prices faced by cooking products purchasers, DOE multiplied the 

manufacturing costs developed from the engineering analysis by the supply chain 

markups it developed (along with sales taxes). 

To project future product prices, DOE examined the electric and gas cooking 

products Producer Price Index (PPI) for the period 1982-2013. This index, adjusted for 

inflation, shows a declining trend. The decline for gas cooking products is a little more 

significant than that for electric cooking products (see appendix 10-D of the NOPR TSD). 

Based on an exponential fit of the adjusted PPIs, DOE utilized a declining price trend for 

both electric and gas cooking products as the default case to project future product price.

2. Installation Costs 

Installation costs include labor, overhead, and any miscellaneous materials and 

parts. For this NOPR, DOE used data from the 2013 RS Means Mechanical Cost Data on 

labor requirements to estimate installation costs for conventional ovens. 37

In general, DOE estimated that installation costs would be the same for different 

efficiency levels. 

3. Unit Energy Consumption

Section IV.E describes the derivation of annual energy use for conventional 

 37 RS Means Company Inc., RS Means Mechanical Cost Data (2013) (Available at 

http://rsmeans.reedconstructiondata.com/default.aspx).
100

ovens.

DOE did not find any evidence of a rebound effect, in which consumers use a 

more efficient appliance more intensively, for conventional cooking products.ovens.

Cooking practices are affected by people’s eating habits, which are unlikely to change 

due to higher product efficiency. DOE requests comment on its decision to not use a 

rebound effect for cooking products (see issue 11 in section VII.E).

4. Energy Prices

DOE derived marginal residential electricity and natural gas prices for 27 

geographic areas.

38

DOE estimated residential electricity prices for each of the 27 areas based on 

20122013 data from EIA Form 861, Annual Electric Power Industry Report.39 DOE first 

estimated a marginal residential price for each utility, and then calculated an marginal

price for each area by weighting each utility with customers in an area by the number of 

residential customers served in that area. 

DOE estimated marginal residential natural gas prices in each of the 27 

geographic areas based on 20122013 data from the EIA publication Natural Gas Monthly

 38 DOE characterized the geographic distribution into 27 geographic areas to be consistent with the 27 

states and group of states reported in RECS 2009.

39 Utility EIA form 861 submissions for 20132012 are available at 

http://www.eia.gov/electricity/data/eia861/
101

publication.

40 DOE calculated a marginal natural gas price for each area by first 

calculating the average prices for each State, and then calculating a regional price by 

weighting each State in a region by its population. 

To estimate future trends in electricity and natural gas prices, DOE used price 

forecasts in AEO 20142015. To arrive at prices in future years, DOE multiplied the 

marginal prices described above by the forecast of annual average changes in nationalaverage residential electricity and natural gas prices. Because the AEO 20142015

forecasts prices only to 2040, DOE used the average rate of change during 2025–2040 to 

estimate the price trends beyond 2040. 

Laclede and the American Gas Association (AGA) suggest that DOE use 

consumer marginal energy rates when evaluating the LCC for each standard efficiency 

level. They noted that this approach was recommended by DOE's Advisory Committee 

on Appliance Energy Efficiency Standards in April 1998. AGA notes that a marginal 

price analysis reflects incremental changes in natural gas costs most closely associated 

with changes in the amount of gas consumed. (Laclede, STD No. 8 at p. 4 and AGA, 

STD No. 7 at p. 2) DOE developed estimates of marginal electricity and natural gas 

prices for the NOPR analysis.

The spreadsheet tool used to conduct the LCC and PBP analysis allows users to 

select the AEO 2015 high-growth case or low-growth case price forecasts to estimate the 

 40 The EIA Natural Gas Monthly publication is available at http://www.eia.gov/naturalgas/monthly/
102

sensitivity of the LCC and PBP to different energy price forecasts. 

5. Repair and Maintenance Costs

Repair costs are associated with repairing or replacing components that have 

failed in the appliance. Maintenance costs are associated with maintaining the operation 

of the equipment. 

Typically, small incremental changes in product efficiency incur no, or only very 

small, changes in repair and maintenance costs over baseline products. For all electric 

cooking products, DOE did not include any changes in repair and maintenance costs for 

products more efficient than baseline products.

For gas ovens, DOE determined the repair and maintenance costs associated with 

different types of ignition systems. Following the approach adopted in the April 2009 

Final Rule for electric glo-bar/hot surface ignition systems, DOE estimated an average 

repair cost of $170 occurring every fifth year during the product’s lifetime. For electronic 

spark ignition systems, DOE estimated an average repair cost of $206 occurring in the 

tenth year of the product’s life. DOE seeks comments from the industry on repair cost 

estimation (see section VII.E).

See chapter 8 of the TSD accompanying this notice for further information 

regarding repair and maintenance costs.
103

6. Product Lifetime 

Equipment lifetime is the age at which the equipment is retired from service. DOE 

used a variety of sources to establish low, average, and high estimates for product 

lifetime. Utilizing data from Appliance Magazine Market Insight, DOE established

average product lifetimes of 15 years for conventional electric ovens and 17 years for

conventional gas ovens.

41 DOE characterized the product lifetimes with Weibull 

probability distributions. See chapter 8 of the TSD accompanying this notice for further 

details on the sources used to develop product lifetimes, as well as the use of Weibull 

distributions.

7. Discount Rates

In the calculation of LCC, DOE applies discount rates appropriate to households 

to estimate the present value of future operating costs. DOE estimated a distribution of 

residential discount rates for conventional cooking products based on consumer financing 

costs and opportunity cost of funds related to appliance energy cost savings and 

maintenance costs.

To establish residential discount rates for the LCC analysis, DOE’s approach 

involved identifying all relevant household debt or asset classes in order to approximate a 

consumer’s opportunity cost of funds related to appliance energy cost savings and 

maintenance costs. DOE estimated the average percentage shares of the various types of 

 41 Appliance Magazine, Market Insight. The U.S. Appliance Industry: Market Value, Life Expectancy & 

Replacement Picture 2012.
104

debt and equity by household income group using data from the Federal Reserve Board’s 

Survey of Consumer Finances (SCF) for 1995, 1998, 2001, 2004, 2007, and 2010.42

Using the SCF and other sources, DOE then developed a distribution of rates for each 

type of debt and asset by income group to represent the rates that may apply in the year in 

which amended standards would take effect. DOE assigned each sample household a 

specific discount rate drawn from one of the distributions. The average rate across all 

types of household debt and equity and income groups, weighted by the shares of each 

class, is 5.0 percent. See chapter 8 in the NOPR TSD for further details on the 

development of consumer discount rates.

8. Compliance Date

The compliance date is the date when a covered product is required to meet a new 

or amended standard. DOE calculated the LCC and PBP for all customers as if each were 

to purchase new equipment in the year that compliance with amended standards is 

required. EPCA, as amended, requires that not later than 6 years after issuance of any 

final rule establishing or amending a standard, DOE must publish either a notice of 

determination that standards for the product do not need to be amended, or a NOPR that 

includes new proposed energy conservation standards. (42 U.S.C. 6295(m)(1)) DOE’s 

last final rule for conventional cooking products was issued on March 31, 2009. Thus, 

DOE must act by March 31, 2015. (42 U.S.C. 6295(m)(1)(b). Any amended standards 

 42 Note that two older versions of the SCF are also available (1989 and 1992). These surveys were not used 

in this analysis because they do not provide all of the necessary types of data (e.g., credit card interest 

rates). DOE determines that the 15-year span covered by the six surveys included is sufficiently 

representative of recent debt and equity shares and interest rates.
105

would apply to conventional cooking products manufactured three years after the date on 

which the final amended standard is published. (42 U.S.C. 6295(m)(4)(A)(i)) Therefore, 

for purposes of its analysis, DOE assumed that a final rule would be published in 2016, 

which results in 2019 being the first year of compliance with amended standards.

9. Base Case Efficiency Distribution

To accurately estimate the percentage of consumers that would be affected by a 

particular standard level, DOE estimates the distribution of equipment efficiencies that 

consumers are expected to purchase under the base case (i.e., the case without amended 

energy efficiency standards). DOE refers to this distribution of equipment energy 

efficiencies as a base-case efficiency distribution. This approach reflects the fact that 

some consumers may already purchase equipment with efficiencies greater than the 

baseline equipment levels.

DOE did not have market data reflecting the efficiency distribution of cooking 

products being sold. DOE’s Compliance Certification Database provides information on 

models of gas cooking products that comply with the requirement of not having a 

standing pilot. In the absence of data on the efficiency distribution of the products being 

sold in the market, DOE calculated the market share of available efficiency options based 

on consumer’s sensitivity to first cost. DOE treated renters and owners as two separate 

entities to establish price sensitivities, and used a logit model to characterize historical 

shipments as a function of price. DOE used shipments data collected by the Market 

Research Magazine and the PPI for household cooking appliance manufacturers between 
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the years 2002 – 2012, along with the manufacturer cost data from the engineering 

analysis to analyze factors that influence consumer purchasing decisions of cooking 

products. Because the data are not sufficient to capture any definite trend in efficiency, 

DOE used the 2013 distribution (described in Chapter 8 of the NOPR TSD) to represent 

the market in the compliance year (2019).

Table IV-22 and present market shares of the efficiency levels in the base case 

for conventional ovens.

43 See chapter 8 of the NOPR TSD for further details on the 

development of base-case market shares.

Table IV-22. Conventional Electric Ovens: Base Case Efficiency Distribution

Standard Ovens Self-Clean Ovens

Standard 

Level

IAEC

(kWh)

Market 

Share

Standard 

Level

IAEC

(kWh)

Market 

Share Freestanding Built-in Freestanding Builtin

Baseline 294.5 301.5 40.4% Baseline 355.0 361.1 46.5%

1 284.6 291.4 9.7% 1 345.1 351.0 15.8%

2 271.7 278.2 9.6% 2 327.2 332.7 14.0%

3 259.2 265.4 9.3% 3 278.9 283.7 12.0%

4 254.9 261.0 9.2% 4 278.1 282.9 11.7%

5 244.6 250.5 8.1%

6 207.8 212.8 6.9%

7 207.3 212.2 6.8%

 43 For the conventional oven product classes, the efficiency levels are based on an oven with a cavity 

volume of 3.9 ft3

. As discussed in section IV.C.3, DOE developed slopes and intercepts to characterize the 

relationship between IEAC and cavity volume for each efficiency level.
107

Table IV-23. Conventional Gas Ovens: Base Case Efficiency Distribution

Standard Ovens Self-Clean Ovens

Standard 

Level

IAEC

(kBtu) Market 

Share

Standard 

Level

IAEC

(kBtu) Market 

Freestanding Built-in Freestanding Built-in Share

Baseline 2,118.2 2,128.1 42.5% Baseline 1,883.8 1,893.7 47.5%

1 1,649.3 1,657.0 8.6% 1 1,848.2 1,858.0 13.6%

2 1,614.7 1,622.2 8.6% 2 1,668.7 1,677.5 13.4%

3 1,490.7 1,497.7 8.4% 3 1,596.3 1,604.7 12.8%

4 1,414.8 1,421.5 8.3% 4 1,591.0 1,599.4 12.6%

5 1,400.6 1,407.2 8.2%

6 1,355.6 1,362.0 7.8%

7 1,347.0 1,353.3 7.7%

10. Inputs to Payback Period Analysis

The PBP is the amount of time it takes the consumer to recover the additional 

installed cost of more efficient equipment, compared to baseline equipment, through 

energy cost savings. PBPs are expressed in years. PBPs that exceed the life of the product 

mean that the increased total installed cost is not recovered in reduced operating 

expenses.

The inputs to the PBP calculation are the total installed cost of the product to the 

customer for each efficiency level and the annual first year operating expenditures for 

each efficiency level. The PBP calculation uses the same inputs as the LCC analysis, 

except that energy price trends and discount rates are not needed.
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11. Rebuttable-Presumption Payback Period

EPCA establishes a rebuttable presumption that a standard is economically 

justified if the Secretary finds that the additional cost to the consumer of purchasing a 

product complying with an energy conservation standard level will be less than three 

times the value of the energy savings during the first year that the consumer will receive 

as a result of the standard, as calculated under the test procedure in place for that 

standard. (42 U.S.C.(o)(2)(B)(iii) For each considered efficiency level, DOE determines 

the value of the first year’s energy savings by calculating the quantity of those savings in 

accordance with the applicable DOE test procedure, and multiplying that amount by the 

average energy price forecast for the year in which compliance with the amended 

standards would be required.

G. Shipments Analysis

DOE uses projections of product shipments to calculate the national impacts of 

standards on energy use, NPV, and future manufacturer cash flows. DOE develops 

shipment projections based on historical data and an analysis of key market drivers for 

each product. Historical shipments data are used to build up an equipment stock and also 

to calibrate the shipments model. DOE accounted for three market segments: (1) new 

construction, (2) existing homes (i.e., replacing failed products), and (3) retired but not 

replaced. DOE used the retired but not replaced market segment to calibrate the 

shipments model to historical shipments data. 
109

DOE considered the impacts of prospective standards on product shipments. The 

combined market of conventional electric and gas cooking products is completely 

saturated. Thus, DOE concluded that any price increase due to a standard would not 

impact the overall decision to purchase. However, DOE did implement an impact due to a 

standard on the efficiency of the product that will likely be purchased. This impact is 

captured through a change in the efficiency distribution of the market.

Table IV-24 summarizes the approach and data DOE used to derive the inputs to 

the shipments analysis for the NOPR. 
110

Table IV-24. Approach and Data Used to Derive the Inputs to the Shipments 

Analysis

Inputs Approach

New Construction 

Shipments

Determined by multiplying housing forecasts by 

forecasted saturation of cooking products for new 

housing. Housing forecasts based on AEO2014

projections. New housing product saturations based 

on RECS 2009. Forecasted saturations maintained at 

2009 levels.

Replacements Determined by tracking total product stock by 

vintage and establishing the failure of the stock using 

retirement functions from the LCC and PBP analysis. 

Retirement functions were based on Weibull lifetime 

distributions.

Retired but not 

replaced

Used to calibrate shipments model to historical 

shipments data to account for a decline in the 

replacement shipments.

Historical 

Shipments

Data sources include U.S. Statistical Review of 

Appliance Industry and Appliance Magazine.

Impacts Due to 

Efficiency 

Standards

Not considered due to a fully saturated market. 

Fuel Switching Not considered, as no significant movement was 

observed from historical data.

To determine new construction shipments, DOE used a forecast of new housing 

coupled with product market saturation data for new housing. For new housing 

completions and mobile home placements, DOE adopted the projections from EIA’s 

AEO 2015 through 2040.

DOE estimated replacements using product retirement functions developed from 

product lifetimes. For this NOPR, DOE used retirement functions based on Weibull 

distributions.

To reconcile the historical shipments with the model, DOE assumed that every 
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retired unit is not replaced. DOE attributed the reason for this non-replacement to 

building demolition occurring at the rate of approximately three percent of the retiring 

units per annum over the period 2013–2048. The assumed not-replaced rate is distributed 

into 2.8 percent for electric cooking products and 4.1 percent for gas cooking products.

DOE allocated shipments to each of the eight product classes based on the current 

market share of each class. DOE developed the market shares based on historical data 

collected from Appliance Magazine Market Research report44 and U.S. Appliance 

Industry Statistical Review.45 The shares are kept constant over time.

AGA voiced concern that the establishment of energy conservation standards for 

natural gas cooking appliances may result in increased first-cost of these appliances, 

making them less attractive and leading to potential fuel switching. (AGA, STD No. 7 at 

p. 2) Because this NOPR considers standards for both electric and natural gas appliances, 

any increase in the price of the appliance would impact cooking products of both fuel 

types. As switching typically includes additional installation costs for accessing the new 

fuel source (e.g. installation of a gas line for gas appliances and installation of electrical 

lines for electrical appliances), which would outweigh the incremental change in 

equipment price, DOE determined that fuel-switching would not occur.

 44 Appliance Magazine Market Research. The U.S. Appliance Industry: Market Value, Life Expectancy & 

Replacement Picture 2012.

45 Appliance 2011. U.S. Appliance Industry Statistical Review: 2000 to YTD 2011.
112

For further details on the shipments analysis, please refer to chapter 9 of the 

NOPR TSD.

H. National Impact Analysis

The NIA assesses the national energy savings and the national NPV of total 

consumer costs and savings that would be expected to result from amended standards at 

specific efficiency levels.

DOE used an MS Excel spreadsheet model to calculate the national energy 

savings and the consumer costs and savings from each TSL.46 The NIA calculations are 

based on the annual energy consumption and total installed cost data from the energy use 

analysis and the LCC analysis. DOE projected the lifetime energy savings, energy cost 

savings, equipment costs, and NPV of customer benefits for each product class over the 

lifetime of equipment sold from 2019 through 2048. 

DOE evaluated the impacts of proposed standards for conventional ovens by 

comparing base-case projections with standards-case projections. The base-case 

projections characterize energy use and customer costs for each product class in the 

absence of proposed energy conservation standards.

 46 DOE’s use of MS Excel as the basis for the spreadsheet models provides interested parties with access to 

the models within a familiar context. In addition, the TSD and other documentation that DOE provides 

during the rulemaking help explain the models and how to use them. Interested parties can review DOE’s 

analyses by changing various input quantities within the spreadsheet.
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Table IV-25 summarizes the key inputs for the NIA. The sections following 

provide further details, as does chapter 10 of the NOPR TSD.

Table IV-25. Inputs for the National Impact Analysis

Input Description

Shipments Annual shipments from shipments model.

Compliance date January 1, 2019.

Base case efficiency Based on the consumer choice model.

Standards case efficiency Based on a “roll up” scenario to establish a 

2019 shipment weighted efficiency. 

Annual energy consumption 

per unit

Calculated for each efficiency level and 

product class based on inputs from the 

energy use analysis.

Total installed cost per unit Calculated by efficiency level using 

manufacturer selling prices and weightedaverage overall markup values. 

Energy expense per unit Annual energy use is multiplied by the 

corresponding average electricity and gas 

price.

Escalation of electricity and 

gas prices

AEO 2015 forecasts (to 2040) and 

extrapolation beyond 2040 for electricity 

and gas prices. 

Electricity site-to-primary 

energy conversion

A time series conversion factor; includes 

electric generation, transmission, and 

distribution losses. 

Discount rates 3% and 7%.

Present year 2014. 

1. Efficiency Trends

A key component of DOE’s estimates of national energy savings and NPV is the 

energy efficiencies forecasted over time. For the base case, in the absence of any 

historical efficiency data, and absence of an ENERGY STAR program for conventional 

cooking products, DOE assumed that efficiency would remain constant at the 2019 levels 
114

derived in the LCC and PBP analysis. DOE provides 1 percent and 2 percent efficiency 

growth rates as options for sensitivity analysis.follow the distribution based on consumer 

choice model. The model responds to changes in product prices, and therefore, is affected 

by the learning effect on the prices.

To estimate the impact that standards would have in the year compliance becomes 

required, DOE used a "roll-up" scenario, which assumes that equipment efficiencies in 

the base case that do not meet the standard level under consideration would "roll up" to 

meet the new standard level and equipment shipments at efficiencies above the standard 

level under consideration are not affected. In each standards case, the efficiency 

distributions remain constant at the 2019 levels for the remainder of the shipments 

forecast period.

2. National Energy Savings

For each year in the forecast period, DOE calculates the national energy savings 

for each standard level by multiplying the shipments of ovens by the per-unit annual 

energy savings. Cumulative energy savings are the sum of the annual energy savings over 

the lifetime of all equipment shipped during 2019–2048.

The annual energy consumption per unit depends directly on equipment 

efficiency. DOE used the shipment-weighted energy efficiencies associated with the base 

case and each standards case, in combination with the annual energy use data, to estimate 

the shipment-weighted average annual per-unit energy consumption under the base case 
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and standards cases. The national energy consumption is the product of the annual energy 

consumption per unit and the number of units of each vintage, which depends on 

shipments. DOE calculates the total annual site energy savings for a given standards case 

by subtracting total energy use in the standards case from total energy use in the base 

case. Note that total shipments are the same in the standards cases as in the base case.

DOE converted the site electricity consumption and savings to primary energy 

(power sector energy consumption) using annual conversion factors derived from 

the AEO 2014 version of the National Energy Modeling System (NEMS). 

The American Public Gas Association (APGA), National Propane Gas 

Association (NGPA), AGA, and Laclede recommend that DOE incorporate full fuel 

cycle analysis in the conservation standard. (APGA, STD No. 6 at p. 2, NPGA, STD No.

5 at pp. 1-3, AGA, STD No. 7 at p. 2, and Laclede, STD No. 8 at p. 3) In response to the 

recommendations of a committee on “Point-of-Use and Full-Fuel-Cycle Measurement 

Approaches to Energy Efficiency Standards” appointed by the National Academy of 

Science, DOE announced its intention to use FFC measures of energy use, GHG 

emissions and other emissions in the national impact analyses and emissions analyses 

included in future energy conservation standards rulemakings. 76 FR 51281 (August 18, 

2011). After evaluating the approaches discussed in the August 18, 2011 notice, DOE 

published a statement of amended policy in the Federal Register in which DOE explained 

its determination that NEMS is the most appropriate tool for its FFC analysis and its 

intention to use NEMS for that purpose. 77 FR 49701 (August 17, 2012). The FFC 
116

factors incorporate losses in production and delivery in the case of natural gas (including 

fugitive emissions), and energy used to produce and deliver the fuels used by power 

plants. The approach used for this NOPR, and the FFC multipliers that were applied, are 

described in appendix 10A of the NOPR TSD. DOE continues to work with the Federal 

Trade Commission (FTC) to make available to the consumer information regarding FFC 

energy use through the Energy Guide label. Table IV-26 through Table IV-29 below 

present the FFC equivalent of IAEC for the considered efficiency levels.

Table IV-26. Conventional Electric Standard Ovens: FFC equivalent of IAEC

Standard 

Level

IAEC - Site IAEC - FFC

(kWh) (kWh)

Freestanding Built-in Freestanding Built-in

Baseline 294 302 962 985

1 285 291 930 952

2 272 278 888 909

3 259 265 847 867

4 255 261 833 853

5 245 250 799 819

6 208 213 679 695

7 207 212 677 694
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Table IV-27. Conventional Electric Self-Clean Ovens: FFC equivalent of IAEC

Standard 

Level

IAEC - Site IAEC - FFC

(kWh) (kWh)

Freestanding Built-in Freestanding Built-in

Baseline 355 361 1,160 1,180

1 345 351 1,128 1,147

2 327 333 1,069 1,087

3 279 284 912 927

4 278 283 909 924

Table IV-28. Conventional Gas Standard Ovens: FFC equivalent of IAEC

Standard 

Level

IAEC – Site IAEC – FFC

(kBtu) (kBtu)

Freestanding Built-in Freestanding Built-in

Baseline 2,118 2,128 2,347 2,358

1 1,649 1,657 1,828 1,836

2 1,615 1,622 1,789 1,798

3 1,491 1,498 1,652 1,660

4 1,415 1,421 1,568 1,575

5 1,401 1,407 1,552 1,559

6 1,356 1,362 1,502 1,509

7 1,347 1,353 1,493 1,500

Table IV-29. Conventional Gas Self-Clean Ovens: FFC equivalent of IAEC

Standard 

Level

IAEC – Site IAEC - FFC

(kBtu) (kBtu)

Freestanding Built-in Freestanding Built-in

Baseline 1,884 1,894 2,087 2,098

1 1,848 1,858 2,048 2,059

2 1,669 1,677 1,849 1,859

3 1,596 1,605 1,769 1,778

4 1,591 1,599 1,763 1,772
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3. Net Present Value of Customer Benefit 

The inputs for determining the NPV of the total costs and benefits experienced by 

consumers are: (1) total annual installed cost; (2) total annual savings in operating costs; 

and (3) a discount factor to calculate the present value of costs and savings. DOE 

calculates the lifetime net savings for equipment shipped each year as the difference 

between the base case and each standards case in total savings in lifetime operating costs 

and total increases in installed costs. DOE calculates lifetime operating cost savings over 

the life of each considered oven unit in conventional cooking products shipped during the 

forecast period.

a. Total Annual Installed Cost

The total installed cost includes both the equipment price and the installation cost. 

For each product class, DOE calculated equipment prices by efficiency level using 

manufacturer selling prices and weighted-average overall markup values. Because DOE 

calculated the total installed cost as a function of equipment efficiency, it was able to 

determine annual total installed costs based on the annual shipment-weighted efficiency 

levels determined in the shipments model. DOE accounted for the repair and maintenance 

costs associated with the ignition systems in gas cooking products.

As noted in section IV.F.1, DOE assumed a declining trend in the conventional 

cooking products prices over the analysis period. In addition, DOE conducted sensitivity 

analyses using alternative price trends: one in which the rate of decline in prices is greater 

after 2014, and one in which the rate of decline is lower. These price trends, and the NPV 
119

results from the associated sensitivity cases, are described in appendix 10B of the NOPR 

TSD.

b. Total Annual Operating Cost Savings

The per-unit energy savings were derived as described in section IV.H.2. To 

calculate future electricity and natural gas prices, DOE applied the projected trend in 

national-average commercial electricity and natural gas price from the AEO 2015

Reference case, which extends to 2040, to the prices derived in the LCC and PBP 

analysis. DOE used the trend from 2025 to 2040 to extrapolate beyond 2040. DOE 

requests comment on its approach (see issue 9 in section VII.E).

In addition, DOE analyzed scenarios that used the energy price projections in 

the AEO 2015 Low Economic Growth and High Economic Growth cases. These cases 

have higher and lower energy price trends compared to the Reference case. These price 

trends, and the NPV results from the associated cases, are described in appendix 10C of 

the NOPR TSD.

In calculating the NPV, DOE multiplies the net dollar savings in future years by a 

discount factor to determine their present value. DOE estimates the NPV using both a 3-

percent and a 7-percent real discount rate in accordance with guidance provided by the 

OMB to Federal agencies on the development of regulatory analysis.47 The discount rates 

 47 U.S. Office of Management and Budget, “Circular A-4: Regulatory Analysis,” Section E, (Sept. 17, 

2003) (Available at: http://www.whitehouse.gov/omb/circulars_a004_a-4/).
120

for the determination of NPV are in contrast to the discount rates used in the LCC 

analysis, which are designed to reflect a consumer’s perspective. The 7-percent real value 

is an estimate of the average before-tax rate of return to private capital in the U.S. 

economy. The 3-percent real value represents the “social rate of time preference,” which 

is the rate at which society discounts future consumption flows to their present value.

I. Consumer Subgroup Analysis 

In analyzing the potential impact of new or amended standards on individual 

consumers, DOE evaluates the impact on identifiable subgroups of consumers that may 

be disproportionately affected by a national standard level. For this NOPR, DOE used 

RECS 2009 data to analyze the potential effect of standards for residential cooking 

products on two consumer subgroups: (1) households with low income levels, and (2) 

households comprised of seniors.

More details on the consumer subgroup analysis can be found in chapter 11 of the 

TSD accompanying this notice.

J. Manufacturer Impact Analysis

1. Overview

DOE conducted an MIA for residential conventional ovens to estimate the 

financial impact of new and amended energy conservation standards on manufacturers of 

these products. The MIA has both quantitative and qualitative aspects. The quantitative 

part of the MIA relies on the GRIM, an industry cash-flow model customized for 
121

residential conventional ovens covered in this rulemaking. The key GRIM inputs are data 

on the industry cost structure, equipment costs, shipments, and assumptions about 

manufacturer markups and conversion costs. The key MIA output is INPV. DOE used the 

GRIM to calculate cash flows using standard accounting principles and to compare 

changes in INPV between a base case and various TSLs in the standards case. The 

difference in INPV between the base and standards cases represents the financial impact 

of new and amended energy conservation standards on residential conventional oven

manufacturers. Different sets of assumptions (scenarios) produce different INPV results. 

The qualitative part of the MIA addresses factors such as manufacturing capacity; 

characteristics of, and impacts on, any particular subgroup of manufacturers; and impacts 

on competition.

DOE conducted the MIA for this rulemaking in three phases. In the first phase 

DOE prepared an industry characterization based on the market and technology 

assessment and publicly available information. In the second phase, DOE developed an 

interview guide based on the industry financial parameters derived in the first phase. In 

the third phase, DOE conducted interviews with a variety of residential conventional 

cooking product manufacturers that account for more than 85 percent of domestic 

residential conventional oven sales covered by this rulemaking. During these interviews, 

DOE discussed engineering, manufacturing, procurement, and financial topics specific to 

each company and obtained each manufacturer’s view of the residential conventional 

oven industry as a whole. The interviews provided information that DOE used to evaluate 

the impacts of new and amended standards on manufacturers’ cash flows, manufacturing 
122

capacities, and direct domestic manufacturing employment levels. Section V.B.2 of this 

NOPR contains a discussion on the estimated changes in the number of domestic 

employees involved in manufacturing residential conventional ovens covered by the 

proposed standards. Section IV.J.4 of this NOPR contains a description of the key issues 

manufacturers raised during the interviews.

During the third phase, DOE also used the results of the industry characterization 

analysis in the first phase and feedback from manufacturer interviews to group together 

manufacturers that exhibit similar production and cost structure characteristics. DOE 

identified one manufacturer subgroup for a separate impact analysis – small business 

manufacturers – using the small business employee threshold of 750 total employees 

published by the Small Business Administration (SBA). This threshold includes all 

employees in a business’ parent company and any other subsidiaries. Based on this 

classification, DOE identified seven residential conventional oven manufacturers that 

qualify as small businesses. The manufacturer subgroup analysis is discussed in greater 

detail in chapter 12 of the NOPR TSD and in section VI.B of this notice.

2. GRIM Analysis and Key Inputs

DOE uses the GRIM to quantify the changes in cash flows over time due to new

and amended energy conservation standards. These changes in cash flows result in either 

a higher or lower INPV for the standards case compared to the base case (the case where 

a standard is not set). The GRIM analysis uses a standard annual cash flow analysis that 

incorporates manufacturer costs, markups, shipments, and industry financial information 
123

as inputs. It then models changes in costs, investments, and manufacturer margins that 

result from new and amended standards. The GRIM uses these inputs to calculate a series 

of annual cash flows beginning with the base year of the analysis, 2015, and continuing 

to 2048. DOE computes INPV by summing the stream of annual discounted cash flows 

during the analysis period. DOE used a real discount rate of 9.1 percent for residential 

conventional cooking product manufacturers. The discount rate estimates were derived 

from industry corporate annual reports to the Securities and Exchange Commission (SEC 

10-Ks). During manufacturer interviews residential conventional oven manufacturers 

were asked to provide feedback on this discount rate. Most manufacturers agreed that a 

discount rate of 9.1 was appropriate to use for residential conventional oven

manufacturers. Many inputs into the GRIM came from the engineering analysis, the NIA, 

manufacturer interviews, and other research conducted during the MIA. The major GRIM 

inputs are described in detail in the following sections.

a. Capital and Product Conversion Costs

DOE expects new and amended energy conservation standards for residential 

conventional ovens to cause manufacturers to incur conversion costs to bring their 

production facilities and product designs into compliance with the new and amended 

standards. For the MIA, DOE classified these conversion costs into two major groups: (1) 

capital conversion costs, and (2) product conversion costs. Capital conversion costs are 

investments in property, plant, and equipment necessary to adapt or change existing 

production facilities such that new product designs can be fabricated and assembled. 

Product conversion costs are investments in research, development, testing, marketing, 
124

certification, and other non-capitalized costs necessary to make product designs comply 

with new and amended standards.

Using feedback from manufacturer interviews, DOE conducted a top-down

analysis to calculate the capital and product conversion costs for residential conventional 

oven manufacturers. DOE asked manufacturers during interviews to estimate the total 

capital and product conversion costs they would need to incur to be able to produce each 

residential conventional oven at specific ELs. DOE then summed these values provided 

by manufacturers to arrive at total top-down industry conversion cost for residential 

conventional ovens.

See chapter 12 of this NOPR TSD for a complete description of DOE’s 

assumptions for the capital and product conversion costs.

b. Manufacturer Production Costs

Manufacturing more efficient residential conventional ovens is typically more 

expensive than manufacturing baseline products due to the need for more costly materials 

and components. The higher MPCs for these more efficient products can affect the 

revenue, gross margin, and the cash flows of residential conventional oven

manufacturers. DOE developed MPCs for each representative unit at each EL analyzed. 

DOE purchased a number of units for each product class, then tested and tore down those 

units to create a unique bill of materials for the purchased unit. Using the bill of materials

for each residential conventional oven, DOE was able to create an aggregated MPC based 
125

on the material costs from the bill of materials, the labor costs based on an average labor 

rate and the labor hours necessary to manufacture the residential conventional oven, and 

the overhead costs, including depreciation, based on a markup applied to the material and

labor costs based on the materials used. For more information about MPCs, see section 

IV.C of this NOPR.

c. Shipment Scenarios

INPV, the key GRIM output, depends on industry revenue, which depends on the 

quantity and prices of residential conventional ovens shipped in each year of the analysis 

period. Industry revenue calculations require forecasts of: (1) the total annual shipment 

volume of residential conventional ovens; (2) the distribution of shipments across product 

classes (because prices vary by product class); and (3) the distribution of shipments 

across efficiency levels (because prices vary with efficiency level).

In the base case shipment analysis, DOE develops shipment projections based on 

historical data and an analysis of key market drivers for each product. In the standards 

case, DOE modeled a roll-up scenario. The roll-up scenario represents the case in which 

all shipments in the base case do not meet the new and amended standards shift to now 

meet the new and amended standard level but do not exceed the new and amended 

standard. Also, no shipments that meet or exceed the new and amended standards have an 

increase in efficiency due to the new and amended standards.
126

For a complete description of the shipments used in the base and standards case 

see the shipments analysis discussion in section IV.G of this NOPR.

d. Markup Scenarios

As discussed in the previous manufacturer production costs section, the MPCs for 

each of the product classes of residential conventional ovens are the manufacturers’ 

factory costs for those units. These costs include materials, direct labor, depreciation, and 

overhead, which are collectively referred to as the cost of goods sold (COGS). The MSP 

is the price received by residential conventional oven manufacturers from their 

customers, typically retail outlets, regardless of the downstream distribution channel 

through which the residential conventional ovens are ultimately sold. The MSP is not the 

cost the end-user pays for residential conventional ovens because there are typically 

multiple sales along the distribution chain and various markups applied to each sale. The 

MSP equals the MPC multiplied by the manufacturer markup. The manufacturer markup 

covers all the residential conventional oven manufacturer’s non-production costs (i.e.,

selling, general and administrative expenses (SG&A), research and development (R&D), 

and interest, etc.) as well as profit. Total industry revenue for residential conventional 

oven manufacturers equals the MSPs at each EL for each product class multiplied by the 

number of shipments at each EL for each product class.

Modifying these manufacturer markups in the standards case yields a different set 

of impacts on residential conventional oven manufacturers than in the base case. For the 

MIA, DOE modeled two standards case markup scenarios for residential conventional 
127

ovens to represent the uncertainty regarding the potential impacts on prices and 

profitability for residential conventional oven manufacturers following the 

implementation of new energy conservation standards. The two scenarios are: (1) a 

preservation of gross margin markup scenario, and (2) a preservation of operating profit 

markup scenario. Each scenario leads to different manufacturer markup values, which, 

when applied to the inputted MPCs, result in varying revenue and cash flow impacts on 

residential conventional oven manufacturers.

The preservation of gross margin markup scenario assumes that the COGS for 

each residential conventional oven is marked up by a flat percentage to cover SG&A 

expenses, R&D expenses, interest expenses, and profit. This allows manufacturers to 

preserve the same gross margin percentage in the standards case as in the base case

throughout the entire analysis period. This markup scenario represents the upper bound of 

the residential conventional oven industry profitability in the standards case because 

residential conventional oven manufacturers are able to fully pass through additional 

costs due to standards to their consumers.

To derive the preservation of gross margin markup percentages for residential 

conventional ovens, DOE examined the SEC 10-Ks of all publicly traded residential 

conventional oven manufacturers to estimate the industry average gross margin 

percentage. DOE estimated that the manufacturer markup for residential conventional 

ovens is 1.20 for all residential conventional ovens. Manufacturers were then asked about 

this industry gross margin percentage derived from SEC 10-Ks during interviews. 
128

Residential conventional oven manufacturers agreed that the 1.20 average industry gross 

margin calculated from SEC 10-Ks was an appropriate estimate to use in the MIA. DOE 

seeks comment on the use of 1.20 for all residential conventional ovens.

DOE included an alternative markup scenario, the preservation of operating profit 

markup scenario, because manufacturers stated they do not expect to be able to markup 

the full cost of production in the standards case, given the highly competitive residential 

conventional oven market. The preservation of operating profit markup scenario assumes 

that manufacturers are able to maintain only the base case total operating profit in 

absolute dollars in the standards case, despite higher production costs and investment. 

The base case total operating profit is derived from marking up the COGS for each 

product by the preservation of gross margin markup previously described. In the 

standards case for the preservation of operating profit markup scenario, DOE adjusted the 

residential conventional oven manufacturer markups in the GRIM at each TSL to yield 

approximately the same earnings before interest and taxes in the standards case in the 

year after the compliance date of the new and amended standards as in the base case. 

Under this scenario, while manufacturers are not able to earn additional operating profit 

on higher per unit production costs and the increase in capital and product investments 

that are required to comply with new and amended energy conservation standards, they

are able to maintain the same operating profit in absolute dollars in the standards case 

that was earned in the base case.
129

The preservation of operating profit markup scenario represents the lower bound 

of industry profitability in the standards case. This is because manufacturers are not able 

to fully pass through the additional costs necessitated by new and amended energy 

conservation standards, as they are able to do in the preservation of gross margin markup 

scenario. Therefore, manufacturers earn less revenue in the preservation of operating 

profit markup scenario than they do in the preservation of gross margin markup scenario.

3. Discussion of Comments

The February 2014 RFI did not focus on the MIA or specifically address any 

issues relating to the MIA. Therefore, DOE did not receive any MIA specific comments 

from the February 2014 RFI.

4. Manufacturer Interviews

DOE conducted manufacturer interviews following publication of the February 

2014 RFI in preparation for the NOPR analysis. In these interviews, DOE asked 

manufacturers to describe their major concerns with this residential conventional ovens

rulemaking. The following section describes the key issues identified by residential 

conventional oven manufacturers during these interviews.

a. Premium Products Tend to be Less Efficient

Manufacturers stated that their premium products are usually less efficient than 

their baseline products. For example, premium ovens typically have bigger cavities with

hidden heat sources under the floor of the cavity. This makes the heat source less direct,
130

therefore decreasing the efficiency. On the other hand, baseline ovens tend to use direct 

heating sources which are more efficient. Manufacturers warned DOE that focusing only 

on the efficiency of residential conventional ovens could cause some manufacturers to 

redesign their products in a way that reduces consumer satisfaction as consumers tend to 

value premium features.

b. Product Utility

Manufacturers stated that energy efficiency is not one of the most important 

aspects that consumers value when purchasing residential conventional ovens. 

Manufacturers state that there are several other factors, such as performance and 

durability, which consumers value more when purchasing residential conventional ovens. 

Forcing manufacturers to improve the efficiency of their products could lead to some 

manufacturers removing premium features that consumers desire from their products, 

reducing overall consumer utility.

c. Testing and Certification Burdens

Several manufacturers expressed concern about the testing and recertification 

costs associated with new and amended energy conservation standards for residential 

conventional ovens. Because testing and certification costs are incurred on a per model 

basis, if a large number of models are required to be redesigned to meet new and 

amended standards, manufacturers would be forced to spend a significant amount of 

money testing and certifying products that were redesigned due to new and amended 

standards. Manufacturers stated that these testing and certification costs associated with 

residential conventional ovens could significantly strain their limited resources if these 
131

costs were all incurred in the three year time frame from the publication of a final rule to 

the implementation of the standards.

K. Emissions Analysis

In the emissions analysis, DOE estimated the reduction in power sector emissions 

of carbon dioxide (CO2), nitrogen oxides (NOx), sulfur dioxide (SO2), and mercury (Hg) 

from potential energy conservation standards for conventional cooking products.ovens. In 

addition, DOE estimated emissions impacts in production activities (extracting, 

processing, and transporting fuels) that provide the energy inputs to power plants. These 

are referred to as “upstream” emissions. Together, these emissions account for the FFC. 

In accordance with DOE’s FFC Statement of Policy,

48 the FFC analysis includes impacts 

on emissions of methane (CH4) and nitrous oxide (N2O), both of which are recognized as 

GHGs. 

DOE primarily conducted the The analysis of power sector emissions analysis using 

uses marginal emissions factors calculated using a methodology based on results published 

for CO2the AEO 2014 reference case and mosta set of side cases that implement a variety of 

efficiency-related policies.

49 The methodology is described in chapter 15 of the other gases

derived from data in AEO 2014. NOPR TSD.

 48 76 FR 51281 (Aug. 18, 2011). DOE’s FFC was amended in 2012 for reasons unrelated to the inclusion of 

CH4 and N2O. 77 FR 49701 (Aug. 17, 2012).

49 DOE did not use AEO 2015 for the emissions analysis because it does not provide the side cases that 

DOE uses to derive marginal emissions factors. 
132

Combustion emissions of CH4 and N2O were estimated using emissions intensity 

factors published by the U.S. Environmental Protection Agency (EPA), GHG Emissions 

Factors Hub.50 Site emissions of CO2 and NOX (from gas combustion) were estimated 

using emissions intensity factors from an EPA publication.

51 DOE developed separate 

emissions factors for power sector emissions and upstream emissions. The method that 

DOE used to derive emissions factors is described in chapter 13 of the final ruleNOPR

TSD.

For CH4 and N2O, DOE calculated emissions reduction in tons and also in terms 

of units of carbon dioxide equivalent (CO2eq). Gases are converted to CO2eq by 

multiplying the physical units by the gas' global warming potential (GWP) over a 100-

year time horizon. Based on the Fifth Assessment Report of the Intergovernmental Panel 

on Climate Change,52 DOE used GWP values of 28 for CH4 and 265 for N2O.

Because the on-site operation of gas cooking products requires use of fossil fuels 

and results in emissions of CO2 and NOx at the sites where these appliances are used, 

DOE also accounted for the reduction in these site emissions and the associated upstream 

 50 See http://www.epa.gov/climateleadership/inventory/ghg-emissions.html 51 U.S. Environmental Protection Agency, Compilation of Air Pollutant Emission Factors, AP-42, Fifth 

Edition, Volume I: Stationary Point and Area Sources (1998) (Available at: 

http://www.epa.gov/ttn/chief/ap42/index.html). 52 IPCC, 2013: Climate Change 2013: The Physical Science Basis. Contribution of Working Group I to the 

Fifth Assessment Report of the Intergovernmental Panel on Climate Change [Stocker, T.F., D. Qin, G.-K. 

Plattner, M. Tignor, S.K. Allen, J. Boschung, A. Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.)]. 

Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. Chapter 8.
133

emissions due to potential standards. Site emissions were estimated using emissions 

intensity factors from an EPA publication.53

EIA prepares the Annual Energy Outlook using NEMS. Each annual version of 

NEMS incorporates the projected impacts of existing air quality regulations on 

emissions. AEO 2014 generally represents current legislation and environmental 

regulations, including recent government actions, for which implementing regulations 

were available as of October 31, 2013.

SO2 emissions from affected electric generating units (EGUs) are subject to 

nationwide and regional emissions cap-and-trade programs. Title IV of the Clean Air Act 

sets an annual emissions cap on SO2 for affected EGUs in the 48 contiguous states and 

the District of Columbia (D.C.). SO2 emissions from 28 eastern states and D.C. were also 

limited under the Clean Air Interstate Rule (CAIR), which created an allowance-based 

trading program that operates along with the Title IV program. 70 FR 25162 (May 12, 

2005). CAIR was remanded to the EPA by the U.S. Court of Appeals for the District of 

Columbia Circuit but it remained in effect.54 In 2011, EPA issued a replacement for 

CAIR, the Cross-State Air Pollution Rule (CSAPR). 76 FR 48208 (Aug. 8, 2011). On 

August 21, 2012, the D.C. Circuit issued a decision to vacate CSAPR.55 The court 

ordered EPA to continue administering CAIR. On April 29, 2014, the U.S. Supreme 

 53 U.S. Environmental Protection Agency, Compilation of Air Pollutant Emission Factors, AP-42, Fifth 

Edition, Volume I: Stationary Point and Area Sources (1998) (Available at: 

http://www.epa.gov/ttn/chief/ap42/index.html). 54 See North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008); North Carolina v. EPA, 531 F.3d 896 (D.C. 

Cir. 2008).

55 See EME Homer City Generation, LP v. EPA, 696 F.3d 7, 38 (D.C. Cir. 2012), cert. granted, 81 

U.S.L.W. 3567, 81 U.S.L.W. 3696, 81 U.S.L.W. 3702 (U.S. June 24, 2013) (No. 12-1182).
134

Court reversed the judgment of the D.C. Circuit and remanded the case for further 

proceedings consistent with the Supreme Court's opinion.56 On October 23, 2014, the 

D.C. Circuit lifted the stay of CSAPR. 57 Pursuant to this action, CSAPR went into effect 

(and CAIR ceased to be in effect) as of January 1, 2015. 

Because AEO 2014 was prepared prior to the Supreme Court's opinion, it 

assumed that CAIR remains a binding regulation through 2040. Thus, DOE’s analysis 

used emissions factors that assume that CAIR, not CSAPR, is the regulation in force. 

However, the difference between CAIR and CSAPR is not relevant for the purpose of 

DOE's analysis of emissions impacts from energy conservation standards.

The attainment of emissions caps is typically flexible among EGUs and is 

enforced through the use of emissions allowances and tradable permits. Beginning in 

2016, however, SO2 emissions will decline significantly as a result of the Mercury and 

Air Toxics Standards (MATS) for power plants. 77 FR 9304 (Feb. 16, 2012). In the final 

MATS rule, EPA established a standard for hydrogen chloride as a surrogate for acid gas 

hazardous air pollutants (HAP), and also established a standard for SO2 (a non-HAP acid 

gas) as an alternative equivalent surrogate standard for acid gas HAP. The same controls 

are used to reduce HAP and non-HAP acid gas; thus, SO2 emissions will be reduced as a 

result of the control technologies installed on coal-fired power plants to comply with the 

 56 See EPA v. EME Homer City Generation, 134 S.Ct. 1584, 1610 (U.S. 2014). The Supreme Court held in 

part that EPA's methodology for quantifying emissions that must be eliminated in certain States due to their 

impacts in other downwind States was based on a permissible, workable, and equitable interpretation of the 

Clean Air Act provision that provides statutory authority for CSAPR. 

57 See Georgia v. EPA, Order (D. C. Cir. filed October 23, 2014) (No. 11-1302), 
135

MATS requirements for acid gas. AEO 2014 assumes that, in order to continue operating, 

coal plants must have either flue gas desulfurization or dry sorbent injection systems 

installed by 2016. Both technologies, which are used to reduce acid gas emissions, also 

reduce SO2 emissions. Under the MATS, emissions will be far below the cap established 

by CAIR, so it is unlikely that excess SO2 emissions allowances resulting from the lower 

electricity demand would be needed or used to permit offsetting increases in SO2

emissions by any regulated EGU. Therefore, DOE believes that energy efficiency 

standards will reduce SO2 emissions in 2016 and beyond.

CAIR established a cap on NOx emissions in 28 eastern states and the District of 

Columbia.58 Energy conservation standards are expected to have little effect on NOx

emissions in those states covered by CAIR because excess NOx emissions allowances 

resulting from the lower electricity demand could be used to permit offsetting increases 

in NOx emissions. However, standards would be expected to reduce NOx emissions in 

the states not affected by the caps, so DOE estimated NOx emissions reductions from the 

standards considered in this proposed rule for these states.

The MATS limit mercury emissions from power plants, but they do not include 

emissions caps. DOE estimated mercury emissions reduction using emissions factors 

based on AEO 2014, which incorporates the MATS. 

 58 CSAPR also applies to NOX, and it would supersede the regulation of NOX under CAIR. As stated 

previously, the current analysis assumes that CAIR, not CSAPR, is the regulation in force. The difference 

between CAIR and CSAPR with regard to DOE’s analysis of NOX is slight.
136

L. Monetizing Carbon Dioxide and Other Emissions Impacts

As part of the development of this rule, DOE considered the estimated monetary 

benefits from the reduced emissions of CO2 and NOX that are expected to result from 

each of the TSLs considered. In order to make this calculation similar to the calculation 

of the NPV of consumer benefit, DOE considered the reduced emissions expected to 

result over the lifetime of equipment shipped in the forecast period for each TSL. This 

section summarizes the basis for the monetary values used for each of these emissions 

and presents the values considered in this rulemaking.

DOE is relying on a set of values for the SCC that was developed by an 

interagency process. A summary of the basis for these values is provided below, and a 

more detailed description of the methodologies used is provided as an appendix to 

chapter 14 of the NOPR TSD.

1. Social Cost of Carbon 

The SCC is an estimate of the monetized damages associated with an incremental 

increase in carbon emissions in a given year. It is intended to include (but is not limited 

to) changes in net agricultural productivity, human health, property damages from 

increased flood risk, and the value of ecosystem services. Estimates of the SCC are 

provided in dollars per metric ton of carbon dioxide. A domestic SCC value is meant to 

reflect the value of damages in the United States resulting from a unit change in carbon 

dioxide emissions, while a global SCC value is meant to reflect the value of damages 

worldwide.
137

Under section 1(b)(6) of Executive Order 12866, “Regulatory Planning and 

Review,” 58 FR 51735 (Oct. 4, 1993), agencies must, to the extent permitted by law, 

assess both the costs and the benefits of the intended regulation and, recognizing that 

some costs and benefits are difficult to quantify, propose or adopt a regulation only upon 

a reasoned determination that the benefits of the intended regulation justify its costs. The 

purpose of the SCC estimates presented here is to allow agencies to incorporate the 

monetized social benefits of reducing CO2 emissions into cost-benefit analyses of 

regulatory actions. The estimates are presented with an acknowledgement of the many 

uncertainties involved and with a clear understanding that they should be updated over 

time to reflect increasing knowledge of the science and economics of climate impacts.

As part of the interagency process that developed the SCC estimates, technical 

experts from numerous agencies met on a regular basis to consider public comments, 

explore the technical literature in relevant fields, and discuss key model inputs and 

assumptions. The main objective of this process was to develop a range of SCC values 

using a defensible set of input assumptions grounded in the existing scientific and 

economic literatures. In this way, key uncertainties and model differences transparently 

and consistently inform the range of SCC estimates used in the rulemaking process.

a. Monetizing Carbon Dioxide Emissions

When attempting to assess the incremental economic impacts of carbon dioxide 

emissions, the analyst faces a number of challenges. A report from the National Research 
138

Council points out that any assessment will suffer from uncertainty, speculation, and lack 

of information about: (1) future emissions of greenhouse gases; (2) the effects of past and 

future emissions on the climate system; (3) the impact of changes in climate on the 

physical and biological environment; and (4) the translation of these environmental 

impacts into economic damages.59 As a result, any effort to quantify and monetize the 

harms associated with climate change will raise serious questions of science, economics, 

and ethics and should be viewed as provisional.

Despite the limits of both quantification and monetization, SCC estimates can be 

useful in estimating the social benefits of reducing carbon dioxide emissions. The agency 

can estimate the benefits from reduced (or costs from increased) emissions in any future 

year by multiplying the change in emissions in that year by the SCC values appropriate 

for that year. The NPV of the benefits can then be calculated by multiplying each of these 

future benefits by an appropriate discount factor and summing across all affected years.

It is important to emphasize that the interagency process is committed to 

updating these estimates as the science and economic understanding of climate change 

and its impacts on society improves over time. In the meantime, the interagency group 

will continue to explore the issues raised by this analysis and consider public comments 

as part of the ongoing interagency process.

 59 National Research Council. Hidden Costs of Energy: Unpriced Consequences of Energy Production and 

Use. National Academies Press: Washington, DC (2009).
139

b. Development of Social Cost of Carbon Values

In 2009, an interagency process was initiated to offer a preliminary assessment of 

how best to quantify the benefits from reducing carbon dioxide emissions. To ensure 

consistency in how benefits are evaluated across Federal agencies, the Administration 

sought to develop a transparent and defensible method, specifically designed for the 

rulemaking process, to quantify avoided climate change damages from reduced CO2

emissions. The interagency group did not undertake any original analysis. Instead, it 

combined SCC estimates from the existing literature to use as interim values until a more 

comprehensive analysis could be conducted. The outcome of the preliminary assessment 

by the interagency group was a set of five interim values: global SCC estimates for 2007 

(in 2006$) of $55, $33, $19, $10, and $5 per metric ton of CO2. These interim values 

represented the first sustained interagency effort within the U.S. government to develop 

an SCC for use in regulatory analysis. The results of this preliminary effort were 

presented in several proposed and final rules. 

c. Current Approach and Key Assumptions 

After the release of the interim values, the interagency group reconvened on a 

regular basis to generate improved SCC estimates. Specifically, the group considered 

public comments and further explored the technical literature in relevant fields. The 

interagency group relied on three integrated assessment models commonly used to 

estimate the SCC: the FUND, DICE, and PAGE models. These models are frequently 

cited in the peer-reviewed literature and were used in the last assessment of the 
140

Intergovernmental Panel on Climate Change (IPCC). Each model was given equal weight 

in the SCC values that were developed. 

Each model takes a slightly different approach to model how changes in 

emissions result in changes in economic damages. A key objective of the interagency 

process was to enable a consistent exploration of the three models while respecting the 

different approaches to quantifying damages taken by the key modelers in the field. An 

extensive review of the literature was conducted to select three sets of input parameters 

for these models: climate sensitivity, socio-economic and emissions trajectories, and 

discount rates. A probability distribution for climate sensitivity was specified as an input 

into all three models. In addition, the interagency group used a range of scenarios for the 

socio-economic parameters and a range of values for the discount rate. All other model 

features were left unchanged, relying on the model developers’ best estimates and 

judgments.

In 2010, the interagency group selected four sets of SCC values for use in 

regulatory analyses.60 Three sets of values are based on the average SCC from three 

integrated assessment models, at discount rates of 2.5 percent, 3 percent, and 5 percent. 

The fourth set, which represents the 95th-percentile SCC estimate across all three models 

at a 3-percent discount rate, is included to represent higher-than-expected impacts from 

climate change further out in the tails of the SCC distribution. The values grow in real 

 60 Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866. Interagency 

Working Group on Social Cost of Carbon, United States Government (February 2010) (Available at: 

http://www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-forRIA.pdf).
141

terms over time. Additionally, the interagency group determined that a range of values 

from 7 percent to 23 percent should be used to adjust the global SCC to calculate 

domestic effects,61 although preference is given to consideration of the global benefits of 

reducing CO2 emissions. Table IV-30 presents the values in the 2010 interagency group 

report, which is reproduced in appendix 14-A of the NOPR TSD.

Table IV-30. Annual SCC Values from 2010 Interagency Report, 2010–2050 (in 

2007 dollars per metric ton CO2)

Year

Discount Rate %

5 3 2.5 3

Average Average Average 95th Percentile

2010 4.7 21.4 35.1 64.9

2015 5.7 23.8 38.4 72.8

2020 6.8 26.3 41.7 80.7

2025 8.2 29.6 45.9 90.4

2030 9.7 32.8 50.0 100.0

2035 11.2 36.0 54.2 109.7

2040 12.7 39.2 58.4 119.3

2045 14.2 42.1 61.7 127.8

2050 15.7 44.9 65.0 136.2

The SCC values used were generated using the most recent versions of the three 

integrated assessment models that have been published in the peer-reviewed literature.62

Table IV-31 shows the updated sets of SCC estimates from the 2013 interagency update 

 61 It is recognized that this calculation for domestic values is approximate, provisional, and highly 

speculative. There is no a priori reason why domestic benefits should be a constant fraction of net global 

damages over time.

62 Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 

12866. Interagency Working Group on Social Cost of Carbon, United States Government (May 2013; 

revised November 2013) (Available at: 

http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbonfor-regulator-impact-analysis.pdf).
142

in five-year increments from 2010 to 2050. Appendix 14-B of the NOPR TSD provides 

the full set of values. The central value that emerges is the average SCC across models at 

3-percent discount rate. However, for purposes of capturing the uncertainties involved in 

regulatory impact analysis, the interagency group emphasizes the importance of including 

all four sets of SCC values.

Table IV-31. Annual SCC Values from 2013 Interagency Update, 2010–2050 (in 

2007 dollars per metric ton CO2)

Year

Discount Rate %

5 3 2.5 3

Average Average Average 95th Percentile

2010 11 32 51 89

2015 11 37 57 109

2020 12 43 64 128

2025 14 47 69 143

2030 16 52 75 159

2035 19 56 80 175

2040 21 61 86 191

2045 24 66 92 206

2050 26 71 97 220

AHAM suggested that DOE rely on the 2010 estimates for SCC until it has 

resolved all comments on the derivation of the SCC estimates from the 2013 report. 

(AHAM, STD No. 9, at p. 8) The 2013 report provides an update of the SCC estimates 

based solely on the latest peer-reviewed version of the models, replacing model versions 

that were developed up to ten years ago in a rapidly evolving field. It does not revisit 

other assumptions with regard to the discount rate, reference case socio-economic and 

emission scenarios, or equilibrium climate sensitivity. Improvements in the way damages 

are modeled are confined to those that have been incorporated into the latest versions of 
143

the models by the developers themselves in the peer-reviewed literature. Given the above, 

using the 2010 estimates would be inconsistent with DOE’s objective of using the best 

available information in its analyses.

It is important to recognize that a number of key uncertainties remain, and that 

current SCC estimates should be treated as provisional and revisable since they will 

evolve with improved scientific and economic understanding. The interagency group also 

recognizes that the existing models are imperfect and incomplete. The National Research 

Council report mentioned above points out that there is tension between the goal of 

producing quantified estimates of the economic damages from an incremental ton of 

carbon and the limits of existing efforts to model these effects. There are a number of 

analytical challenges that are being addressed by the research community, including 

research programs housed in many of the Federal agencies participating in the 

interagency process to estimate the SCC. The interagency group intends to periodically 

review and revise those estimates to reflect increasing knowledge of the science and 

economics of climate impacts, as well as improvements in modeling.

In summary, in considering the potential global benefits resulting from reduced 

CO2 emissions, DOE used the values from the 2013 interagency report, adjusted to 

2014$ using the Gross Domestic Product price deflator. For each of the four SCC cases 

specified, the values used for emissions in 2015 were $12.2, $41.2, $63.4, and $121 per 

metric ton avoided (values expressed in 2014$). DOE derived values after 2050 using the 

relevant growth rates for the 2040-2050 period in the interagency update. 
144

DOE multiplied the CO2 emissions reduction estimated for each year by the SCC 

value for that year in each of the four cases. To calculate a present value of the stream of 

monetary values, DOE discounted the values in each of the four cases using the specific 

discount rate that had been used to obtain the SCC values in each case.

DOE acknowledges the limitations of the SCC estimates, which are discussed in 

detail in the 2010 interagency group report. Specifically, uncertainties in the assumptions 

regarding climate sensitivity, as well as other model inputs such as economic growth and 

emissions trajectories, are discussed and the reasons for the specific input assumptions 

chosen are explained. However, the three integrated assessment models used to estimate 

the SCC are frequently cited in the peer-reviewed literature and were used in the last 

assessment of the IPCC. In addition, new versions of the models that were used in 2013 

to estimate revised SCC values were published in the peer-reviewed literature (see 

appendix 14B of the NOPR TSD for discussion). Although uncertainties remain, the 

revised estimates that were issued in November, 2013 are based on the best available 

scientific information on the impacts of climate change. The current estimates of the SCC 

have been developed over many years, using the best science available, and with input 

from the public. In November 2013, OMB announced a new opportunity for public 

comment on the interagency technical support document underlying the revised SCC 

estimates. 78 FR 70586 (Nov. 26, 2013). OMB is reviewing comments and considering 

whether further revisions to the SCC estimates are warranted. DOE stands ready to work 
145

with OMB and the other members of the interagency working group on further review 

and revision of the SCC estimates as appropriate.

In addition, it is important to note that the monetized benefits of carbon emission 

reductions are one factor that DOE considers in its evaluation of the economic 

justification of proposed standards. As shown in Table I.4, the benefits of these standards 

in terms of consumer operating cost savings exceed the incremental costs of the 

standards-compliant products. The benefits of CO2 emission reductions were considered 

by DOE, but were not determinative in DOE’s decision to adopt these standards.

2. Social Cost of Other Air Pollutants

As noted above, DOE has taken into account how amended energy conservation 

standards would reduce site NOX emissions nationwide and increase power sector NOX

emissions in those 22 States not affected by the CAIR. DOE estimated the monetized 

value of net NOX emissions reductions resulting from each of the TSLs considered for 

this NOPR based on estimates found in the relevant scientific literature. Estimates of 

monetary value for reducing NOX from stationary sources range from $476 to $4,893 per 

ton in 2013$.63 DOE calculated monetary benefits using a medium value for NOX 

emissions of $2,684 per short ton and real discount rates of 3 percent and 7 percent. 

developed by EPA for 2016, 2020, 2025, and 2030.64 The values reflect estimated 

 63 U.S. Office of Management and Budget, Office of Information and Regulatory Affairs, 2006 Report to 

Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on State, Local, and 

Tribal Entities (2006) (Available at: 

http://www.whitehouse.gov/sites/default/files/omb/assets/omb/inforeg/2006_cb/2006_cb_final_report.pdf). 64 http://www2.epa.gov/benmap/sector-based-pm25-benefit-ton-estimates
146

mortality and morbidity per ton of directly emitted NOX reduced by electricity generating 

units. EPA developed estimates using a 3-percent and a 7-percent discount rate to 

discount future emissions-related costs. The values in 2016 are $5,562/ton using a 3-

percent discount rate and $4,920/ton using a 7-percent discount rate (2014$). DOE 

extrapolated values after 2030 using the average annual rate of growth in 2016-2030. 

DOE multiplied the emissions reduction (tons) in each year by the associated $/ton 

values, and then discounted each series using discount rates of 3 percent and 7 percent as 

appropriate.

DOE is evaluating appropriate monetization of avoided SO2 and Hg emissions in 

energy conservation standards rulemakings. It has not included monetization of these 

emissions in the current analysis. DOE requests comment on its approach to monetizing 

emissions reductions for cooking products (see issue 12 in section VII.E)

M. Utility Impact Analysis 

The utility impact analysis estimates several effects on the power generation 

industry that would result from the adoption of new or amended energy conservation 

standards. In the utility impact analysis, DOE analyzes the changes in installed electricity 

capacity and generation that would result for each TSL. The utility impact analysis is 

based on published output from the NEMS associated with AEO 2014. NEMS produces

the AEO reference case as well as a number of side cases that estimate the economy-wide 

impacts of changes to energy supply and demand. DOE uses those published side cases 

that incorporate efficiency-related policies to estimate the marginal impacts of reduced 
147

energy demand on the utility sector.65 The output of this analysis is a set of timedependent coefficients that capture the change in electricity generation, primary fuel 

consumption, installed capacity and power sector emissions due to a unit reduction in 

demand for a given end use. These coefficients are multiplied by the stream of energy 

savings calculated in the NIA to provide estimates of selected utility impacts of new or 

amended energy conservation standards. Chapter 15 of the NOPR TSD describes the 

utility impact analysis in further detail.

N. Employment Impact Analysis

Employment impacts from new or amended energy conservation standards 

include direct and indirect impacts. Direct employment impacts are any changes in the 

number of employees of manufacturers of the equipment subject to standards; the MIA 

addresses those impacts. Indirect employment impacts are changes in national 

employment that occur due to the shift in expenditures and capital investment caused by 

the purchase and operation of more efficient equipment. Indirect employment impacts 

from standards consist of the jobs created or eliminated in the national economy, other 

than in the manufacturing sector being regulated, due to: (1) reduced spending by end 

users on energy; (2) reduced spending on new energy supply by the utility industry; (3) 

increased consumer spending on the purchase of new equipment; and (4) the effects of 

those three factors throughout the economy. 

 65 DOE did not use AEO 2015 for the analysis because it does not provide the side cases that DOE uses to 

derive marginal impact factors.
148

One method for assessing the possible effects on the demand for labor of such 

shifts in economic activity is to compare sector employment statistics developed by the 

Labor Department’s Bureau of Labor Statistics (BLS). BLS regularly publishes its 

estimates of the number of jobs per million dollars of economic activity in different 

sectors of the economy, as well as the jobs created elsewhere in the economy by this 

same economic activity. Data from BLS indicate that expenditures in the utility sector 

generally create fewer jobs (both directly and indirectly) than expenditures in other 

sectors of the economy. There are many reasons for these differences, including wage 

differences and the fact that the utility sector is more capital-intensive and less laborintensive than other sectors. Energy conservation standards have the effect of reducing 

consumer utility bills. Because reduced consumer expenditures for energy likely lead to 

increased expenditures in other sectors of the economy, the general effect of efficiency 

standards is to shift economic activity from a less labor-intensive sector (i.e., the utility 

sector) to more labor-intensive sectors (e.g., the retail and service sectors). Thus, based 

on the BLS data alone, DOE believes net national employment may increase because of 

shifts in economic activity resulting from amended standards.

DOE estimated indirect national employment impacts for the standard levels 

considered in this NOPR using an input/output model of the U.S. economy called Impact 

of Sector Energy Technologies, Version 3.1.1 (ImSET).66 ImSET is a special-purpose 

version of the “U.S. Benchmark National Input-Output” (I–O) model, which was 

 66 M.J. Scott, O.V. Livingston, P.J. Balducci, J.M. Roop, and R.W. Schultz, ImSET 3.1: Impact of Sector 

Energy Technologies, PNNL-18412, Pacific Northwest National Laboratory (2009) (Available at: 

www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf).
149

designed to estimate the national employment and income effects of energy-saving 

technologies. The ImSET software includes a computer-based I–O model having 

structural coefficients that characterize economic flows among the 187 sectors most 

relevant to industrial, commercial, and residential building energy use.

DOE notes that ImSET is not a general equilibrium forecasting model, and 

understands the uncertainties involved in projecting employment impacts, especially 

changes in the later years of the analysis. Because ImSET does not incorporate price 

changes, the employment effects predicted by ImSET may over-estimate actual job 

impacts over the long run. Therefore, DOE generated results for near-term timeframes, 

where these uncertainties are reduced. For more details on the employment impact 

analysis, see chapter 16 of the NOPR TSD.

V. Analytical Results

The following section addresses the results from DOE’s analyses with respect to 

potential energy conservation standards for conventional cooking products.ovens. It 

addresses the TSLs examined by DOE and the projected impacts of each of these levels if 

adopted as energy conservation standards for conventional cooking products.ovens.

Additional details regarding DOE’s analyses are contained in the NOPR TSD supporting 

this notice.
150

A. Trial Standard Levels

DOE analyzed the benefits and burdens of three TSLs for conventional cooking 

products.ovens. These TSLs were developed using combinations of efficiency levels for 

the product classes analyzed by DOE. DOE presents the results for those TSLs in this 

proposed rule. The results for all efficiency levels that DOE analyzed are in the NOPR 

TSD. 

Table V-1. and Table V-2. presents the TSLs and the corresponding efficiency 

levels for conventional cooking productsovens.

67 TSL 3 represents the maximum 

technologically feasible (“max-tech”) improvements in energy efficiency for all product 

classes. TSL 2 comprises efficiency levels for all product classes providing the maximum 

NES with maximum NPV. TSL 1 was configured with standby levels with maximum 

NES.

Table V-1. Summary of Trial Standard Levels for Ovens, Electric

TS

L

Electric Standard 

Ovens, FreeStanding

Electric Standard 

Ovens, BuiltIn/Slide-In

Electric Self-Clean

Ovens, FreeStanding

Electric Self-Clean

Ovens, BuiltIn/Slide-In

Efficiency 

Level

IAEC

(kWh/yr)

Efficiency 

Level

IAEC

(kWh/yr)

Efficiency 

Level

IAEC

(kWh/yr)

Efficiency 

Level

IAEC

(kWh/yr)

1 1 284.6 1 291.4 1 345.1 1 351.0

2 3 259.2 3 265.4 1 345.1 1 351.0

3 7 207.3 7 212.2 4 278.1 4 282.9

 67 For the conventional oven product classes, the efficiency levels are based on an oven with a cavity 

volume of 3.9 ft. As discussed in section I.A.1.c, DOE developed slopes and intercepts to characterize the 

relationship between IEAC and cavity volume for each efficiency level.
151

Table V-2. Summary of Trial Standard Levels for Ovens, Gas

TS

L

Gas Standard Ovens, 

Free-Standing

Gas Standard Ovens, 

Built-In/Slide-In

Gas Self-Clean 

Ovens, FreeStanding

Gas Self-Clean 

Ovens, BuiltIn/Slide-In

Efficiency 

Level

IAEC

(kBtu/yr)

Efficiency 

Level

IAEC

(kBtu/yr)

Efficiency 

Level

IAEC

(kBtu/yr)

Efficiency 

Level

IAEC

(kBtu/yr)

1 Baseline 2,118.2 Baseline 2,128.1 1 1,848.2 1 1,858.0

2 4 1,414.8 4 1,421.5 2 1,668.7 2 1,677.5

3 7 1,347.0 7 1,353.3 4 1,591.0 4 1,599.4

Additionally, Table V-3 to Table V-6 illustrate the design and performance 

related changes that are assumed for each TSL for each product class.

Table V-3. Summary of Trial Standard Levels and Design Options for Ovens, 

Electric Standard

TSL

Electric Standard Ovens, Free-Standing Electric Standard Ovens, Built-In/Slide-In

Efficiency 

Level Design Option Efficiency Level Design Option

1 1 1. SMPS 1 1. SMPS

2 3

1. SMPS

2. Reduced Vent Rate

3. Improved Insulation

3

1. SMPS

2. Reduced Vent Rate

3. Improved Insulation

3 7

1. SMPS

2. Reduced Vent Rate

3. Improved Insulation

4. Improved Door Seals

5. Forced Convection

6. Oven Separator

7. Reduced Conduction 

Losses

7

1. SMPS

2. Reduced Vent Rate

3. Improved Insulation

4. Improved Door Seals

5. Forced Convection

6. Oven Separator

7. Reduced Conduction 

Losses

Table V-4. Summary of Trial Standard Levels and Design Options for Ovens, 

Electric Self-Clean

TSL

Electric Self-Clean Ovens, Free-Standing Electric Self-Clean Ovens, Built-In/Slide-In

Efficiency 

Level Design Option Efficiency Level Design Option

1 1 1. SMPS 1 1. SMPS

2 1 1. SMPS 1 1. SMPS

3 4

1. SMPS

2. Forced Convection

3. Oven Separator

4. Reduced Conduction 

Losses

4

1. SMPS

2. Forced Convection

3. Oven Separator

4. Reduced Conduction 

Losses
152

Table V-5. Summary of Trial Standard Levels and Design Options for Ovens, Gas

Standard

TSL

Gas Standard Ovens, Free-Standing Gas Standard Ovens, Built-In/Slide-In

Efficiency 

Level Design Option Efficiency Level Design Option

1 Baseline - Baseline -

2 4

1. Optimized Burner/Cavity

2. SMPS

3. Electric Spark Ignition

4. Improved Insulation

4

1. Optimized Burner/Cavity

2. SMPS

3. Electric Spark Ignition

4. Improved Insulation

3 7

1. SMPS

2. Optimized Burner/Cavity

3. Electric Spark Ignition

4. Improved Insulation

5. Improved Door Seals

6. Forced Convection

7. Reduced Conduction Losses

7

1. SMPS

2. Optimized Burner/Cavity

3. Electric Spark Ignition

4. Improved Insulation

5. Improved Door Seals

6. Forced Convection

7. Reduced Conduction 

Losses

Table V-6. Summary of Trial Standard Levels and Design Options for Ovens, Gas

Self-Clean

TSL

Gas Self-Clean Ovens, Free-Standing Gas Self-Clean Ovens, Built-In/Slide-In

Efficiency 

Level Design Option Efficiency Level Design Option

1 1 1. SMPS 1 1. SMPS

2 2 1. SMPS

2. Electronic Spark Ignition 2 1. SMPS2. Electronic Spark Ignition

3 4

1. SMPS

2. Electronic Spark Ignition

3. Forced Convection

4. Reduced Conduction Losses

4

1. SMPS

2. Electronic Spark Ignition

3. Forced Convection

4. Reduced Conduction 

Losses
153

B. Economic Justification and Energy Savings

1. Economic Impacts on Individual Consumers

DOE analyzed the economic impacts on conventional cooking productsoven

consumers by looking at the effects potential amended standards would have on the LCC 

and PBP. DOE also examined the impacts of potential standards on consumer subgroups. 

These analyses are discussed below.

a. Life-Cycle Cost and Payback Period

In general, higher-efficiency products affect consumers in two ways: (1) purchase 

price increases, and (2) operating costs decrease. Inputs used for calculating the LCC and 

PBP include total installed costs (i.e., product price plus installation costs), and operating 

costs (i.e., annual energy savings, energy prices, energy price trends, repair costs, and 

maintenance costs). The LCC calculation also uses product lifetime and a discount rate. 

Chapter 8 of the NOPR TSD provides detailed information on the LCC and PBP 

analyses.

Table V-7 through Table V-22 show the LCC and PBP results for all efficiency 

levels considered for each conventional oven product class. In the first of each pair of 

tables, the simple payback is measured relative to the baseline product. In the second 

table, the LCC savings are measured relative to the base-case efficiency distribution in 

the compliance year (see section IV.F.8 of this notice). 
154

Table V-7. Average LCC and PBP Results by Efficiency Level for PC1 Electric 

Standard Ovens, Free-Standing

TSL Efficiency 

Level

Average Costs 

2014$ Simple 

Payback

years Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

1 1 $558 $16 $191 $748 0.9

2 3 $568 $15 $174 $742 4.0

3 7 $653 $12 $142 $795 17.5

Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency 

level. The PBP is measured relative to the baseline product.

Table V-8. Average LCC Savings Relative to the Base-Case Efficiency Distribution 

for PC1 Electric Standard Ovens, Free-Standing

TSL Efficiency 

Level

Life-Cycle Cost Savings

% of Consumers that 

Experience Average Savings*

Net Cost 2014$

1 1 0% $13.96

2 3 12% $15.18

3 7 82% ($37.60)

*The calculation does not includes households with zero LCC savings (no impact).

Table V-9. Average LCC and PBP Results by Efficiency Level for PC2 Electric 

Standard Ovens, Built-In/Slide-In

TSL Efficiency 

Level

Average Costs 

2014$ Simple 

Payback

years Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

1 1 $584 $16 $190 $775 0.9

2 3 $594 $15 $174 $768 4.0

3 7 $680 $12 $142 $821 17.5

Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency 

level. The PBP is measured relative to the baseline product.
155

Table V-10. Average LCC Savings Relative to the Base-Case Efficiency Distribution 

for PC2 Electric Standard Ovens, Built-In/Slide-In

TSL Efficiency 

Level

Life-Cycle Cost Savings

% of Consumers that 

Experience Average Savings*

Net Cost 2014$

1 1 0% $14.11

2 3 12% $15.25

3 7 82% ($37.64)

*The calculation does not includes households with zero LCC savings (no impact).

Table V-11. Average LCC and PBP Results by Efficiency Level for PC3 Electric 

Self-Clean Ovens, Free-Standing

TSL Efficiency 

Level

Average Costs 

2014$ Simple 

Payback

years Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

1,2 1 $602 $22 $251 $853 0.9

3 4 $686 $18 $211 $897 18.1

Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency 

level. The PBP is measured relative to the baseline product.

Table V-12. Average LCC Savings Relative to the Base-Case Efficiency Distribution 

for PC3 Electric Self-Clean Ovens, Free-Standing

TSL Efficiency 

Level

Life-Cycle Cost Savings

% of Consumers that 

Experience Average Savings*

Net Cost 2014$

1,2 1 0% $14.10

3 4 76% ($27.79)

*The calculation does not includes households with zero LCC savings (no impact).
156

Table V-13. Average LCC and PBP Results by Efficiency Level for PC4 Electric 

Self-Clean Ovens, Built-In/Slide-In

TSL Efficiency 

Level

Average Costs 

2014$ Simple 

Payback

years Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

1,2 1 $628 $22 $252 $880 0.9

3 4 $712 $18 $212 $924 18.1

Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency 

level. The PBP is measured relative to the baseline product.

Table V-14 Average LCC Savings Relative to the Base-Case Efficiency Distribution 

for PC4 Electric Self-Clean Ovens, Built-In/Slide-In

TSL Efficiency 

Level

Life-Cycle Cost Savings

% of Consumers that 

Experience Average Savings*

Net Cost 2014$

1,2 1 0% $14.20

3 4 76% ($27.80)

*The calculation does not includes households with zero LCC savings (no impact).

Table V-15. Average LCC and PBP Results by Efficiency Level for PC5 Gas 

Standard Ovens, Free-Standing

TSL Efficiency 

Level

Average Costs 

2014$ Simple 

Payback

years Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

1 Baseline $602 $20 $600 $1,202 --

2 4 $619 $9 $277 $896 1.7

3 7 $656 $9 $277 $933 5.3

Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency 

level. The PBP is measured relative to the baseline product.

Table V-16 Average LCC Savings Relative to the Base-Case Efficiency Distribution 

for PC5 Gas Standard Ovens, Free-Standing

TSL Efficiency Life-Cycle Cost Savings
157

Level

% of Consumers that 

Experience Average Savings*

Net Cost 2014$

1 Baseline 0% ---

2 4 0% $289.73

3 7 24% $178.91

*The calculation does not includes household with zero LCC savings (no impact).

Table V-17. Average LCC and PBP Results by Efficiency Level for PC6 Gas 

Standard Ovens, Built-In/Slide-In

TSL Efficiency

Level

Average Costs 

2014$ Simple 

Payback

years Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

1 Baseline $628 $20 $600 $1,228 --

2 4 $645 $9 $277 $922 1.7

3 7 $682 $9 $277 $959 5.3

Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency 

level. The PBP is measured relative to the baseline product.

Table V-18 Average LCC Savings Relative to the Base-Case Efficiency Distribution 

for PC6 Gas Standard Ovens, Built-In/Slide-In

TSL Efficiency 

Level

Life-Cycle Cost Savings

% of Consumers that 

Experience Average Savings*

Net Cost 2014$

1 Baseline 0% ---

2 4 0% $289.77

3 7 24% $178.92

*The calculation does not includes households with zero LCC savings (no impact).
158

Table V-19 Average LCC and PBP Results by Efficiency Level for PC7 Gas SelfClean Ovens, Free-Standing

TSL Efficiency 

Level

Average Costs 

2014$ Simple 

Payback

years Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

1 1 $718 $20 $612 $1,329 0.8

2 2 $726 $13 $334 $1,060 1.2

3 4 $762 $13 $333 $1,094 5.4

Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency 

level. The PBP is measured relative to the baseline product.

Table V-20. Average LCC Savings Relative to the Base-Case Efficiency Distribution 

for PC7 Gas Self-Clean Ovens, Free-Standing

TSL Efficiency 

Level

Life-Cycle Cost Savings

% of Consumers that 

Experience Average Savings*

Net Cost 2014$

1 1 0% $18.02

2 2 0% $282.80

3 4 27% $165.73

*The calculation does not include households with zero LCC savings (no impact).

Table V-21 Average LCC and PBP Results by Efficiency Level for PC8 Gas SelfClean Ovens, Built-In/Slide-In

TSL Efficiency 

Level

Average Costs 

2014$ Simple 

Payback

years Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

1 1 $744 $20 $612 $1,355 0.8

2 2 $752 $13 $334 $1,086 1.2

3 4 $788 $13 $333 $1,120 5.4

Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency 

level. The PBP is measured relative to the baseline product.
159

Table V-22. Average LCC Savings Relative to the Base-Case Efficiency Distribution 

for PC8 Gas Self-Clean Ovens, Built-In/Slide-In

TSL Efficiency 

Level

Life-Cycle Cost Savings

% of Consumers that 

Experience Average Savings*

Net Cost 2014$

1 1 0% $18.03

2 2 0% $282.85

3 4 27% $165.75

*The calculation does not include households with zero LCC savings (no impact).

b. Consumer Subgroup Analysis

As described in section IV.I of this notice, DOE determined the impact of the 

considered TSLs on low-income households and senior-only households. Table V-23

through Table V-30 compare the average LCC savings and PBP at each efficiency level 

for the two consumer subgroups, along with the average LCC savings for the entire 

sample. In most cases, the average LCC savings and PBP for low-income households and 

senior-only households at the considered efficiency levels are not substantially different 

from the average for all households. Chapter 11 of the NOPR TSD presents the complete 

LCC and PBP results for the subgroups.

Table V-23. Comparison of Average LCC Savings for Consumer Subgroups and All 

Households for PC1 Electric Standard Ovens, Free-Standing

Average Life-Cycle Cost Savings (2014$) Simple Payback Period (years)

TSL Low-income 

households

Senior-only 

households

All 

Households

Low-income 

households

Senior-only 

households

All 

Households

1 $13.88 $14.00 $13.96 0.9 0.9 0.9

2 $18.70 $12.28 $15.18 3.6 4.4 4.0

3 ($28.75) ($45.09) ($37.60) 14.9 20.6 17.5
160

Table V-24. Comparison of Average LCC Savings for Consumer Subgroups and All 

Households for PC2 Electric Standard Ovens, Built-In/Slide-In

Average Life-Cycle Cost Savings (2014$) Simple Payback Period (years)

TSL Low-income 

households

Senior-only 

households

All 

Households

Low-income 

households

Senior-only 

households

All 

Households

1 $14.06 $14.11 $14.11 0.9 0.9 0.9

2 $18.79 $12.34 $15.25 3.6 4.4 4.0

3 ($28.80) ($45.13) ($37.64) 14.9 20.6 17.5

Table V-25. Comparison of Average LCC Savings for Consumer Subgroups and All 

Households PC3 Electric Self-Clean Ovens, Free-Standing

Average Life-Cycle Cost Savings (2014$) Simple Payback Period (years)

TSL Low-income 

households

Senior-only 

households

All 

Households

Low-income 

households

Senior-only 

households

All 

Households

1,2 $13.98 $14.19 $14.10 0.9 0.9 0.9

3 ($18.98) ($32.84) ($27.79) 15.2 20.3 18.1

Table V-26. Comparison of Average LCC Savings for Consumer Subgroups and All 

Households PC4 Electric Self-Clean Ovens, Built-In/Slide-In

Average Life-Cycle Cost Savings (2014$) Simple Payback Period (years)

TSL Low-income 

households

Senior-only 

households

All 

Households

Low-income 

households

Senior-only 

households

All 

Households

1,2 $14.11 $14.27 $14.20 0.9 0.9 0.9

3 ($18.99) ($32.84) ($27.80) 15.2 20.3 18.1

Table V-27. Comparison of Average LCC Savings for Consumer Subgroups and All 

Households PC5 Gas Standard Ovens, Free-Standing

Average Life-Cycle Cost Savings (2014$) Simple Payback Period (years)

TSL Low-income 

households

Senior-only

households

All 

Households

Low-income 

households

Senior-only 

households

All 

Households

1 $0.00 $0.00 $0.00 -- -- --

2 $314.79 $282.03 $289.73 1.4 1.8 1.7

3 $197.33 $173.10 $178.91 4.4 5.7 5.3

Table V-28. Comparison of Average LCC Savings for Consumer Subgroups and All 

Households for PC6 Gas Standard Oven, Built-In/Slide-In

Average Life-Cycle Cost Savings (2014$) Simple Payback Period (years)

TSL Low-income 

households

Senior-only 

households

All 

Households

Low-income 

households

Senior-only 

households

All 

Households

1 $0.00 $0.00 $0.00 -- -- --

2 $314.84 $282.07 $289.77 1.4 1.8 1.7

3 $197.34 $173.11 $178.92 4.4 5.7 5.3
161

Table V-29. Comparison of Average LCC Savings for Consumer Subgroups and All 

Households for PC7 Gas Self-Clean Ovens, Free-Standing

Average Life-Cycle Cost Savings (2014$) Simple Payback Period (years)

TSL Low-income 

households

Senior-only 

households

All 

Households

Low-income 

households

Senior-only 

households

All 

Households

1 $17.28 $18.39 $18.02 0.8 0.7 0.8

2 $298.61 $278.34 $282.80 1.0 1.3 1.2

3 $176.87 $162.47 $165.73 4.7 5.7 5.4

Table V-30. Comparison of Average LCC Savings for Consumer Subgroups and All 

Households for PC8 Gas Self-Clean Oven, Built-In/Slide-In

Average Life-Cycle Cost Savings (2014$) Simple Payback Period (years)

TSL Low-income 

households

Senior-only 

households

All 

Households

Low-income 

households

Senior-only 

households

All 

Households

1 $17.30 $18.40 $18.03 0.8 0.7 0.8

2 $298.68 $278.39 $282.85 1.0 1.3 1.2

3 $176.89 $162.48 $165.75 4.7 5.7 5.4

c. Rebuttable Presumption Payback

As discussed above, EPCA provides a rebuttable presumption that an energy 

conservation standard is economically justified if the increased purchase cost for a 

product that meets the standard is less than three times the value of the first-year energy 

savings resulting from the standard. In calculating a rebuttable presumption payback 

period for the considered standard levels, DOE used discrete values rather than 

distributions for input values, and, as required by EPCA, based the energy use calculation 

on the DOE test procedures for conventional cooking products. As a result, DOE 

calculated a single rebuttable presumption payback value, and not a distribution of 

payback periods, for each efficiency level. 

Table V-31 presents the rebuttable-presumption payback periods for the 

considered TSLs. While DOE examined the rebuttable-presumption criterion, it 

considered whether the standard levels considered for this rulemaking are economically 
162

justified through a more detailed analysis of the economic impacts of those levels 

pursuant to 42 U.S.C. 6295(o)(2)(B)(i). The results of that analysis serve as the basis for 

DOE to evaluate the economic justification for a potential standard level (thereby 

supporting or rebutting the results of any preliminary determination of economic 

justification).

Table V-31. Conventional Ovens: Rebuttable PBPs (years)

Product Class Trial Standard Level

1 2 3

PC1: Electric Standard Ovens, Free-Standing 0.9 2.3 8.5 

PC2: Electric Standard Ovens, Built-In/Slide-In 0.8 2.3 8.3 

PC3: Electric Self-Clean Ovens, Free-Standing 0.9 0.9 8.4

PC4: Electric Self-Clean Ovens, Built-In/Slide-In 0.9 0.9 8.3 

PC5: Gas Standard Ovens, Free-Standing -- 2.4 7.0 

PC6: Gas Standard Ovens, Built-In/Slide-In -- 2.4 6.9 

PC7: Gas Self-Clean Ovens, Free-Standing 3.1 4.6 15.3 

PC8: Gas Self-Clean Ovens, Built-In/Slide-In 3.1 4.6 15.2 

2. Economic Impacts on Manufacturers

DOE performed an MIA to estimate the impact of new and amended energy 

conservation standards on manufacturers of residential conventional ovens. The 

following sections describe the expected impacts on residential conventional oven

manufacturers at each TSL. Chapter 12 of this NOPR TSD explains the MIA in further 

detail.

a. Industry Cash-Flow Analysis Results

Table V-32 through Table V-33 depict the financial impacts (represented by 

changes in INPV) of new and amended energy conservation standards on residential 

conventional oven manufacturers as well as the conversion costs that DOE estimates 
163

manufacturers would incur at each TSL. To evaluate the range of cash flow impacts on 

the residential conventional oven industry, DOE modeled two markup scenarios that 

correspond to the range of anticipated market responses to new and amended standards. 

Each markup scenario results in a unique set of cash flows and corresponding industry 

values at each TSL.

In the following discussion, the INPV results refer to the difference in industry 

value between the base case and the standards case that result from the sum of discounted 

cash flows from the base year (2015) through the end of the analysis period. The results 

also discuss the difference in cash flows between the base case and the standards case in 

the year before the compliance date for new and amended energy conservation standards. 

This figure represents the size of the required conversion costs relative to the cash flow 

generated by the residential conventional oven industry in the absence of new and 

amended energy conservation standards. In the engineering analysis, DOE enumerates 

common technology options that achieve the efficiencies for each of the product classes. 

For descriptions of these technology options and the required efficiencies at each TSL, 

see section IV.C and section V.A respectively of this NOPR.

To assess the upper (less severe) end of the range of potential impacts on 

residential conventional oven manufacturers, DOE modeled a preservation of gross

margin markup scenario. This scenario assumes that in the standards case, manufacturers 

would be able to pass along all the higher production costs required for more efficient

products to their consumers. Specifically, the industry would be able to maintain its 
164

average base case gross margin (as a percentage of revenue) despite the higher product 

costs in the standards case. In general, the larger the product price increases, the less 

likely manufacturers are to achieve the cash flow from operations calculated in this 

scenario because it is less likely that manufacturers would be able to fully mark up these 

larger cost increases.

To assess the lower (more severe) end of the range of potential impacts on the 

residential conventional oven manufacturers, DOE modeled the preservation of operating 

profit markup scenario. This scenario represents the lower end of the range of potential 

impacts on manufacturers because no additional operating profit is earned on the higher 

product costs, eroding profit margins as a percentage of total revenue.

Table V-32 and Table V-33 present the projected results for residential 

conventional ovens under the preservation of gross margin and preservation of operating 

profit markup scenarios. DOE examined results for all product classes together since 

most manufacturers produce both gas and electric ovens.
165

Table V-32. Manufacturer Impact Analysis for Residential Conventional Ovens –

Preservation of Gross Margin Markup Scenario

Units Base Case

Trial Standard Level

1 2 3

INPV (20132014$ 

millions) 783.5 762.8 702.6 140.6 

Change in INPV

(20132014$ 

millions) - (20.7) (80.9) (642.9)

(%) - (2.6) (10.3) (82.0)

Product Conversion Costs (20132014$ 

millions) - 4.3 67.9 401.5 

Capital Conversion Costs (20132014$ 

millions) - 9.0 42.0 528.0

Total Conversion Costs (20132014$ 

millions) - 13.3 109.9 929.5 

*DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative 

numbers

Table V-33. Manufacturer Impact Analysis for Residential Conventional Ovens –

Preservation of Operating Profit Markup Scenario

Units Base Case

Trial Standard Level

1 2 3

INPV (20132014$ 

millions) 783.5 762.1 697.1 56.0 

Change in INPV

(20132014$ 

millions) - (21.4) (86.4) (727.5)

(%) - (2.7) (11.0) (92.9)

Product Conversion Costs (20132014$ 

millions) - 4.3 67.9 401.5 

Capital Conversion Costs (20132014$ 

millions) - 9.0 42.0 528.0

Total Conversion Costs (20132014$ 

millions) - 13.3 109.9 929.5

TSL 1 sets the efficiency level at baseline for two product classes (gas standard 

ovens, free-standing; and gas standard ovens, built-in/slide-in), and EL 1 for six product 

classes (electric standard ovens, free-standing; electric standard ovens, built-in/slide-in; 

electric self-clean ovens, free-standing; electric self-clean ovens, built-in/slide-in; gas 

self-clean ovens, free-standing; and gas self-clean ovens, built-in/slide-in). At TSL 1, 
166

DOE estimates impacts on INPV range from -$21.4 million to -$20.7 million, or a change 

in INPV of -2.7 percent to -2.6 percent. At TSL 1, industry free cash flow (operating cash 

flow minus capital expenditures) is estimated to decrease to $52.1 million, or a drop of 

14.3 percent, compared to the base-case value of $60.8 million in 2018, the year leading 

up to new and amended energy conservation standards.

Percentage impacts on INPV are slightly negative at TSL 1. DOE does not 

anticipate that manufacturers would lose a significant portion of their INPV at this TSL. 

DOE projects that in the expected year of compliance (2019), 100 percent of gas standard 

oven, free-standing shipments; and gas standard oven, built-in/slide-in shipments would 

meet or exceed the efficiency levels required at TSL 1. Meanwhile in 2019, 60 percent of 

electric standard oven, free-standing shipments; 60 percent of electric standard oven, 

built-in/slide-in shipments; 53 percent of electric self-clean oven, free-standing 

shipments; 53 electric self-clean oven, built-in/slide-in shipments; 52 percent of gas selfclean oven, free-standing shipments; and 52 percent of gas self-clean oven, built-in/slidein shipments would meet the efficiency levels at TSL 1.

DOE expects conversion costs to be small at TSL 1 because the design changes

prescribed at this TSL only affect standby mode power consumption and do not apply to 

active mode power consumption. DOE expects residential conventional oven

manufacturers to incur $4.3 million in product conversion costs for product redesigns that 

will convert residential conventional ovens from using linear power supply to switch 

mode power supply to reduce standby power consumption. DOE expects $9.0 million in 
167

capital conversion costs for manufacturers to upgrade production lines and retool 

equipment associated with achieving this reduction in standby power.

At TSL 1, under the preservation of gross margin markup scenario, the shipmentweighted average MPC increases very slightly by approximately 0.1 percent relative to 

the base-case MPC. This extremely slight price increase is outweighed by the $13.3

million in conversion costs estimated at TSL 1, resulting in slightly negative INPV 

impacts at TSL 1 under the preservation of gross margin markup scenario.

Under the preservation of operating profit markup scenario, manufacturers earn 

the same nominal operating profit as would be earned in the base case, but manufacturers 

do not earn additional profit from their investments. The very slight increase in the

shipment weighted-average MPC is again outweighed by a slightly lower average 

manufacturer markup (slightly smaller than the 1.20 manufacturer markup used in the 

base case) and $13.3 million in conversion costs, resulting in slightly negative impacts at 

TSL 1.

TSL 2 sets the efficiency level at EL 1 for two product classes (electric self-clean 

ovens, free-standing; and electric self-clean ovens, built-in/slide-in), EL 2 for two product 

classes (gas self-clean ovens, free-standing; and gas self-clean ovens, built-in/slide-in), 

EL 3 for two product classes (electric standard ovens, free-standing and electric standard 

ovens, built-in/slide-in); and EL 4 for two product classes (gas standard ovens, freestanding and gas standard ovens, built-in/slide-in). At TSL 2, DOE estimates impacts on 
168

INPV to range from -$86.4 million to -$80.9 million, or a change in INPV of -11.0

percent to -10.3 percent. At this standard level, industry free cash flow is estimated to 

decrease to $17.6, or a drop of 71.0 percent, compared to the base-case value of $60.8

million in 2018.

Percentage impacts on INPV are moderately negative at TSL 2. While the $109.9 

million in industry conversion costs represent a significant investment for manufacturers, 

DOE does not anticipate that manufacturers would lose a significant portion of their 

INPV at this TSL since the base case INPV for manufacturers is slightly less than $800 

million. DOE projects that in 2019, 40 percent of electric standard oven, free-standing 

shipments; 40 percent of electric standard oven, built-in/slide-in shipments; 53 percent of 

electric self-clean oven, free-standing shipments; 53 percent of electric self-clean oven, 

built-in/slide-in shipments; 32 percent of gas standard oven, free-standing shipments; 32 

percent of gas standard oven, built-in/slide-in shipments; 39 percent of gas self-clean 

oven, free-standing shipments; and 39 percent of gas self-clean oven, built-in/slide-in 

shipments would meet or exceed the efficiency levels at TSL 2.

While DOE expects conversion costs to be a large investment at TSL 2, the much 

larger base case INPV reduces the overall INPV impact on a percentage basis at TSL 2. 

DOE expects that product conversion costs will significantly rise from $4.3 million at 

TSL 1 to $67.9 million at TSL 2 for extensive product redesigns and testing. Capital 

conversion costs will also significantly increase from $9.0 million at TSL 1 to $42.0 

million at TSL 2 to upgrade production equipment to accommodate for added or 
169

redesigned features in each product class. The large conversion costs at TSL 2 are driven 

by reduce vent rate and improve insulation in the electric oven product classes, and 

conversion from glo-bar to electronic spark ignition systems in the gas oven product 

classes.

At TSL 2, under the preservation of gross margin markup scenario, the shipment

weighted-average MPC only slightly increases by 0.9 percent, relative to the base-case 

MPC. In this scenario, INPV impacts are moderately negative because manufacturers 

incur sizable conversion costs ($109.9 million) and are not able to recover much of those 

conversion costs through the slight increase in the shipment weighted-average MPC at 

TSL 2.

Under the preservation of operating profit markup scenario, the 0.9 percent 

shipment weighted-average MPC increase is outweighed by a slightly lower average 

manufacturer markup (slightly smaller than the 1.20 manufacturer markup used in the 

base case) and $109.9 million in conversion costs, resulting in moderately negative INPV 

impacts at TSL 2.

TSL 3 sets the efficiency level at max tech for all product classes. At TSL 3, DOE 

estimates impacts on INPV to range from -$727.5 million to -$642.9 million, or a change 

in INPV of -92.9 percent to -82.0 percent. At this standard level, industry free cash flow 

is estimated to decrease by approximately 635.3 percent to -$325.5 million, compared to 

the base-case value of $60.8 million in 2018.
170

At TSL 3 conversion costs significantly increase causing free cash flow to 

become significantly negative in the year leading up to energy conservation standards and 

cause manufacturers to loss a substantial amount of INPV. Also, the percent change in 

INPV at TSL 3 is significantly negative due to the extremely large conversion costs. 

Manufacturers at this TSL would have a very difficult time in the short term to make the 

necessary investments to comply with new and amended energy conservation standards 

prior to when standards went into effect. Also, the long-term profitability of residential 

conventional oven manufacturers could be seriously jeopardized as some manufacturers 

would struggle to comply with standards at this TSL.

A high percentage of total shipments will need to be redesigned to meet efficiency 

levels prescribed at TSL 3. DOE projects that in 2019, only 7 percent of electric standard 

oven, free-standing shipments; 7 percent of electric standard oven, built-in/slide-in 

shipments; 12 percent of electric self-clean oven, free-standing shipments; 12 percent of 

electric self-clean oven, built-in/slide-in shipments; 8 percent of gas standard oven, freestanding shipments; 8 percent of gas standard oven, built-in/slide-in shipments; 13 

percent of gas self-clean oven, free-standing shipments; and 13 percent of gas self-clean 

oven, built-in/slide-in shipments would meet the efficiency levels prescribed at TSL 3.

DOE expects significant conversion costs at TSL 3, which represents max tech.

DOE expects product conversion costs to significantly increase from $67.9 million at 

TSL 2 to $401.5 million at TSL 3. Large increases in product conversion are due to the 
171

vast majority of shipments needing extensive redesign as well as a significant increase in 

testing and recertification for redesigned products. DOE estimates that capital conversion 

costs will also significantly increase from $42.0 million at TSL 2 to $528.0 million at

TSL 3. Capital conversion costs are driven by investments in production equipment to 

accommodate for forced convection and reduced conduction losses in the electric and gas 

oven product classes as well as the addition of induction heating elements for the electric 

smooth cooking top product class.

At TSL 3, under the preservation of gross margin markup scenario, the shipment

weighted-average MPC increases by 12.7 percent relative to the base-case MPC. In this 

scenario, INPV impacts are significantly negative because the $929.5 million in 

conversion costs significantly outweighs the modest increase in shipment weightedaverage MPC.

Under the preservation of operating profit markup scenario, the 12.7 percent MPC 

increase is again significantly outweighed by a lower average manufacturer markup of 

1.19 (compared to 1.20 used in the base case) and $929.5 million in conversion costs, 

resulting in significantly negative impacts at TSL 3.

b. Impacts on Employment

DOE quantitatively assessed the impacts of new and amended energy 

conservation standards on direct employment. DOE used the GRIM to estimate the 

domestic labor expenditures and number of domestic production workers in the base case 
172

and at each TSL from 2019 to 2048. DOE used statistical data from the U.S. Census 

Bureau’s 2011 Annual Survey of Manufacturers (ASM), the results of the engineering 

analysis, and interviews with manufacturers to determine the inputs necessary to calculate 

industry-wide labor expenditures and domestic employment levels. Labor expenditures 

involved with the manufacturing of the products are a function of the labor intensity of 

the products, the sales volume, and an assumption that wages remain fixed in real terms 

over time.

In the GRIM, DOE used the labor content of the MPCs to estimate the annual 

labor expenditures in the industry. DOE used census data and interviews with 

manufacturers to estimate the portion of the total labor expenditures that is attributable to 

domestic labor.

The production worker estimates in this section cover only workers up to the linesupervisor level directly involved in fabricating and assembling a product within a 

manufacturing facility. Workers performing services that are closely associated with 

production operations, such as material handing with a forklift, are also included as 

production labor. DOE’s estimates account for production workers who manufacture only 

the specific products covered in this rulemaking.

The employment impacts shown in Table V-34 represent the potential production 

employment that could result following new and amended energy conservation standards. 

The upper bound of the results estimates the maximum change in the number of 
173

production workers that could occur after compliance with new and amended energy 

conservation standards when assuming that manufacturers continue to produce the same 

scope of covered products in the same production facilities. It also assumes that domestic 

production does not shift to lower labor-cost countries. Because there is a real risk of 

manufacturers evaluating sourcing decisions in response to new and amended energy 

conservation standards, the lower bound of the employment results includes the estimated 

total number of U.S. production workers in the industry who could lose their jobs if some 

or all existing production were moved outside of the United States. While the results 

present a range of employment impacts following 2019, the following sections also 

include qualitative discussions of the likelihood of negative employment impacts at the 

various TSLs. Finally, the employment impacts shown are independent of the 

employment impacts from the broader U.S. economy, documented in chapter 17 of the 

NOPR TSD.

Using 2011 ASM data and interviews with manufacturers, DOE estimates that 

approximately 60 percent of the residential conventional ovens sold in the United States 

are manufactured domestically. With this assumption, DOE estimates that in the absence 

of new and amended energy conservation standards, there would be approximately 6,564

domestic production workers involved in manufacturing residential conventional ovens in 

2019. Table V-34 shows the range of the impacts of new and amended energy 

conservation standards on U.S. production workers in the residential conventional oven

industry.
174

Table V-34. Potential Changes in the Total Number of Domestic Residential 

Conventional Ovens Production Workers in 2019

Base Case

Trial Standard Level

1 2 3

Total Number of Domestic Production 

Workers in 2019

(without changes in production locations)

6,564 6,571 6,622 7,397

Potential Changes in Domestic Production 

Workers in 2019* - 0 - 7 (1,641) - 58 (3,282) – 833

*DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative 

numbers

At the upper end of the range, all examined TSLs show a slight increase in the 

number of domestic employment for residential conventional ovens. DOE believes that 

manufacturers would increase production hiring due to the increase in the labor 

associated with adding the required components to make residential conventional ovens 

more efficient. However, as previously stated, this assumes that in addition to hiring more 

production employees, all existing domestic production would remain in the United 

States and not shift to lower labor-cost countries.

DOE does not expect any significant changes in domestic employment at TSL 1 

because standards would only affect standby mode power consumption at this TSL. Most 

manufacturers stated that this TSL would not require significant design changes and 

therefore would not have a significant impact on domestic employment decisions.

At TSLs 2 and 3, all product classes would require higher efficiency standards 

and therefore most manufacturers would be required to make modifications to their 

existing production lines. However, manufacturers stated that due to the larger size of 

most residential conventional ovens very few units are shipped from far distances such as 
175

Asia or Europe. The vast majority of residential conventional ovens are currently made in 

North America. Some manufacturers stated that even significant changes to production 

line would not cause them to shift their production to lower labor-cost countries, as 

several manufacturers either only produce residential conventional ovens domestically or 

have recently made significant investments to continue to produce a portion of their 

residential conventional ovens domestically. DOE estimates that at most 25 percent of the 

domestic labor for residential conventional ovens could move to other countries in 

response to the standards proposed at TSL 2. However, DOE believes this to be a high 

upper bound estimate as most manufacturers would not significantly alter their 

production locations at the efficiency levels prescribed at TSL 2.

At TSL 3, manufacturers could alter production locations in response to standards 

since all product classes would be required to meet max tech. DOE estimated that at most 

50 percent of the domestic labor for residential conventional ovens could move to other 

countries in response to the standards prescribed at TSL 3.

DOE seeks comment on the potential domestic employment impacts to residential 

conventional oven manufacturers at the proposed efficiency levels.

c. Impacts on Manufacturer Capacity

Residential conventional oven manufacturers stated that they did not anticipate 

any capacity constraints for the efficiency levels analyzed for either electric or gas 

residential conventional ovens.
176

DOE requests comment on any potential manufacturer capacity constraints caused 

by the proposed standards in this NOPR, TSL 2.

d. Impacts on Sub-Groups of Manufacturers

Using average cost assumptions to develop an industry cash-flow estimate may 

not be adequate for assessing differential impacts among manufacturer subgroups. Small 

manufacturers, niche product manufacturers, and manufacturers exhibiting cost structures 

substantially different from the industry average could be affected disproportionately. 

DOE analyzed the impacts to small businesses in section VI.B and did not identify any 

other adversely impacted subgroups for residential conventional ovens for this 

rulemaking based on the results of the industry characterization.

DOE requests comment on manufacturer subgroups that DOE should analyze 

and/or types of residential conventional oven manufacturers for the subgroup analysis.

e. Cumulative Regulatory Burden

While any one regulation may not impose a significant burden on manufacturers, 

the combined effects of recent or impending regulations may have serious consequences 

for some manufacturers, groups of manufacturers, or an entire industry. Assessing the 

impact of a single regulation may overlook this cumulative regulatory burden. In addition 

to energy conservation standards, other regulations can significantly affect 

manufacturers’ financial operations. Multiple regulations affecting the same 
177

manufacturer can strain profits and lead companies to abandon product lines or markets 

with lower expected future returns than competing products. For these reasons, DOE 

conducts a cumulative regulatory burden analysis as part of its rulemakings pertaining to 

appliance efficiency.

DOE acknowledges that most residential conventional oven manufacturers also 

make appliances that are or could be subject to future energy conservation standards 

implemented by DOE. DOE is aware of several other energy conservations that could 

also affect residential conventional oven manufacturers. These energy conservation 

standards include residential refrigerators and freezers that have a compliance date in 

2014,68 residential clothes dryers that have a compliance date in 2015,69 residential 

clothes washers that have a compliance date in 2015 and in 2018,70 and microwave ovens 

that have a compliance date in 2016.71

The compliance years and expected industry conversion costs of relevant 

amended energy conservation standards are indicated in Table V-35.

 68 Energy conservation standards for residential refrigerators, refrigerators-freezers, and freezers became 

effective on September 14, 2014. 76 FR 57516 [Docket Number EE–2008–BT–STD–0012] 69 Energy conservation standards for residential clothes dryers became effective on January 1, 2015. 76 FR 

52854 [Docket Number EERE–2007–BT–STD–0010] 70 The first round of prescribed energy conservation standards for residential clothes washers became 

effective on March 7, 2015. The second round of standards will go into effect on January 1, 2018. 77 FR 

59719 [Docket Number EERE–2008–BT–STD–0019] 71 Energy conservation standards for microwave oven operating in standby mode and off mode will go into 

effect on June 17, 2016. 78 FR 36316 [Docket Number EERE–2011–BT–STD–0048]
178

Table V-35. Compliance Dates and Expected Conversion Expenses of Federal 

Energy Conservation Standards Affecting Residential Conventional Oven

Manufacturers

Federal Energy Conservation 

Standards Compliance Date Estimated Total Industry Conversion Expense

Residential Refrigerators and Freezers

76 FR 57516 (September 15, 2011) 2014 $1,243M (2009$)

Residential Clothes Dryers

76 FR 52854 (April 21, 2011) 2015 $95M (2009$)

Residential Clothes Washers

77 FR 59719 (May 31, 2012)

2015 – First Round

2018 – Second Round $418.5M (2010$)

Microwave Ovens

78 FR 36316 (June 17, 2013) 2016 $43.1M (2011$)

Residential Cooking Tops 2020* N/A**

* The date listed is an approximation. The exact date is pending final DOE action

** For energy conservation standards awaiting DOE final action. DOE does not have finalized estimated 

total industry conversion expenses.

DOE discusses these and other requirements and includes the full details of the 

cumulative regulatory burden analysis in chapter 12 of the NOPR TSD. DOE seeks 

comment on the compliance costs of any other regulations residential conventional oven

manufacturers must make, especially if compliance with those regulations is required 

three years before or after the estimated compliance date of this proposed standard 

(2019).

3. National Impact Analysis

a. Significance of Energy Savings

To estimate the energy savings attributable to potential standards for conventional

ovens, DOE compared the energy consumption of those products under the base case to 

their anticipated energy consumption under each TSL. Table V-36 and Table V-37

present DOE’s projections of the national energy savings for each TSL considered for 

conventional ovens. The savings were calculated using the approach described in section 

IV.H.1 of this notice.
179

Table V-36. Conventional Ovens: Cumulative Primary National Energy Savings for 

Products Shipped in 2019–2048 (quads)

Product Class Trial Standard Level

1 2 3

PC1: Electric Standard Ovens, 

Free-Standing 0.023 0.057 0.161

PC2: Electric Standard Ovens, 

Built-In/Slide-In 0.000 0.001 0.003

PC3: Electric Self-Clean Ovens, 

Free-Standing 0.071 0.071 0.372

PC4: Electric Self-Clean Ovens, 

Built-In/Slide-In 0.021 0.021 0.108

PC5: Gas Standard Ovens, FreeStanding 0.000 0.204 0.209

PC6: Gas Standard Ovens, BuiltIn/Slide-In 0.000 0.038 0.039

PC7: Gas Self-Clean Ovens, 

Free-Standing 0.038 0.268 0.282

PC8: Gas Self-Clean Ovens, 

Built-In/Slide-In 0.002 0.014 0.014

TOTAL (All Products) 0.156 0.673 1.188
180

Table V-37. Conventional Ovens: Cumulative FFC National Energy Savings for 

Products Shipped in 2019–2048

Product Class Trial Standard Level

1 2 3

PC1: Electric Standard 

Ovens, Free-Standing 0.024 0.060 0.168

PC2: Electric Standard 

Ovens, Built-In/Slide-In 0.000 0.001 0.003

PC3: Electric Self-Clean 

Ovens, Free-Standing 0.074 0.074 0.389

PC4: Electric Self-Clean

Ovens, Built-In/Slide-In 0.022 0.022 0.113

PC5: Gas Standard Ovens, 

Free-Standing 0.000 0.216 0.223

PC6: Gas Standard Ovens, 

Built-In/Slide-In 0.000 0.041 0.042

PC7: Gas Self-Clean Ovens, 

Free-Standing 0.040 0.281 0.297

PC8: Gas Self-Clean Ovens, 

Built-In/Slide-In 0.002 0.014 0.015

TOTAL (All Products) 0.163 0.709 1.251

OMB Circular A-472 requires agencies to present analytical results, including 

separate schedules of the monetized benefits and costs that show the type and timing of 

benefits and costs. Circular A-4 also directs agencies to consider the variability of key 

elements underlying the estimates of benefits and costs. For this rulemaking, DOE 

undertook a sensitivity analysis using nine, rather than 30, years of product shipments. 

The choice of a nine-year period is a proxy for the timeline in EPCA for the review of 

certain energy conservation standards and potential revision of and compliance with such 

revised standards.73 The review timeframe established in EPCA is generally not 

 72 U.S. Office of Management and Budget, “Circular A-4: Regulatory Analysis” (Sept. 17, 2003) 

(Available at: http://www.whitehouse.gov/omb/circulars_a004_a-4/) 73 Section 325(m) of EPCA requires DOE to review its standards at least once every 6 years, and requires, 

for certain products, a 3-year period after any new standard is promulgated before compliance is required, 

except that in no case may any new standards be required within 6 years of the compliance date of the 
181

synchronized with the product lifetime, product manufacturing cycles, or other factors 

specific to conventional ovens. Thus, such results are presented for informational 

purposes only and are not indicative of any change in DOE’s analytical methodology. 

The NES sensitivity analysis results based on a nine-year analytical period are presented 

in Table V-38. The impacts are counted over the lifetime of conventional ovens

purchased in 2019–2027.

Table V-38. Conventional Ovens: Cumulative FFC National Energy Savings for 

Products Shipped in 2019–2027

Product Class Trial Standard Level

1 2 3

PC1: Electric Standard Ovens, 

Free-Standing 0.007 0.016 0.046

PC2: Electric Standard Ovens, 

Built-In/Slide-In 0.000 0.001 0.002

PC3: Electric Self-Clean Ovens, 

Free-Standing 0.018 0.018 0.102

PC4: Electric Self-Clean Ovens, 

Built-In/Slide-In 0.006 0.006 0.033

PC5: Gas Standard Ovens, FreeStanding 0.000 0.070 0.072

PC6: Gas Standard Ovens, BuiltIn/Slide-In 0.000 0.013 0.013

PC7: Gas Self-Clean Ovens, FreeStanding 0.012 0.081 0.085

PC8: Gas Self-Clean Ovens, BuiltIn/Slide-In 0.001 0.004 0.004

TOTAL (All Products) 0.044 0.210 0.358

 

previous standards. While adding a 6-year review to the 3-year compliance period adds up to 9 years, DOE 

notes that it may undertake reviews at any time within the 6 year period and that the 3-year compliance date 

may yield to the 6-year backstop. A 9-year analysis period may not be appropriate given the variability that 

occurs in the timing of standards reviews and the fact that for some consumer products, the compliance 

period is 5 years rather than 3 years.
182

b. Net Present Value of Consumer Costs and Benefits

DOE estimated the cumulative NPV to the nation of the total costs and savings for 

consumers that would result from particular standard levels for conventional ovens. In 

accordance with the OMB’s guidelines on regulatory analysis (OMB Circular A-4, 

section E, September 17, 2003),74 DOE calculated NPV using both a 7-percent and a 3-

percent real discount rate. 

Table V-39. shows the consumer NPV results for each TSL DOE considered for 

conventional ovens. The impacts are counted over the lifetime of products purchased in 

2019–2048.

Table V-39. Conventional Ovens: Cumulative Net Present Value of Consumer 

Benefits for Products Shipped in 2019–2048

Equipment Type

Discount 

Rate

Trial Standard Level

1 2 3*

PC1: Electric Standard 

Ovens, Free-Standing

3% 0.17 0.31 (0.57)

7% 0.07 0.11 (0.49)

PC2: Electric Standard 

Ovens, Built-In/Slide-In

3% 0.00 0.01 (0.02)

7% 0.00 0.00 (0.01)

PC3: Electric Self-Clean 

Ovens, Free-Standing

3% 0.52 0.52 (1.02)

7% 0.21 0.21 (0.96)

PC4: Electric Self-Clean 

Ovens, Built-In/Slide-In

3% 0.16 0.16 (0.32)

7% 0.07 0.07 (0.30)

 74 Available at: www.whitehouse.gov/omb/circulars_a004_a-4.
183

PC5: Gas Standard Ovens, 

Free-Standing

3% 0.00 3.59 3.06

7% 0.00 1.55 1.24

PC6: Gas Standard Ovens, 

Built-In/Slide-In

3% 0.00 0.67 0.57

7% 0.00 0.29 0.23

PC7: Gas Self-Clean 

Ovens, Free-Standing

3% 0.28 5.48 4.72

7% 0.12 2.31 1.87

PC8: Gas Self-Clean 

Ovens, Built-In/Slide-In

3% 0.01 0.28 0.24

7% 0.01 0.12 0.10

TOTAL (All Products)

3% 1.15 11.02 6.67

7% 0.48 4.66 1.67

*Parentheses indicate negative (-) values. 

The NPV results based on the aforementioned 9-year analytical period are 

presented in Table V-40.. The impacts are counted over the lifetime of products 

purchased in 2019–2027. As mentioned previously, such results are presented for 

informational purposes only and is not indicative of any change in DOE’s analytical 

methodology or decision criteria. 
184

Table V-40. Conventional Ovens: Cumulative Net Present Value of Consumer 

Benefits for Products Shipped in 2019–2027 

Equipment Type Discount 

Rate

Trial Standard Level

1 2 3*

Billion 2014$

PC1: Electric Standard 

Ovens, Free-Standing

3% 0.06 0.10 (0.28)

7% 0.03 0.05 (0.28)

PC2: Electric Standard 

Ovens, Built-In/Slide-In

3% 0.00 0.00 (0.01)

7% 0.00 0.00 (0.01)

PC3: Electric Self-Clean 

Ovens, Free-Standing

3% 0.16 0.16 (0.53)

7% 0.09 0.09 (0.55)

PC4: Electric Self-Clean 

Ovens, Built-In/Slide-In

3% 0.05 0.05 (0.17)

7% 0.03 0.03 (0.18)

PC5: Gas Standard 

Ovens, Free-Standing

3% 0.00 1.47 1.22

7% 0.00 0.83 0.65

PC6: Gas Standard 

Ovens, Built-In/Slide-In

3% 0.00 0.27 0.22

7% 0.00 0.15 0.12

PC7: Gas Self-Clean 

Ovens, Free-Standing

3% 0.10 2.02 1.71

7% 0.06 1.16 0.92

PC8: Gas Self-Clean 

Ovens, Built-In/Slide-In

3% 0.01 0.11 0.09

7% 0.00 0.06 0.05

TOTAL (All Products)

3% 0.38 4.18 2.26

7% 0.22 2.38 0.72

*Parentheses indicate negative (-) values. 
185

The above results reflect the use of a default trend to estimate the change in price 

for conventional ovens over the analysis period (see section IV.F.1of this notice). DOE 

also conducted a sensitivity analysis that considered one scenario with a lower rate of 

price decline than the reference case and one scenario with a higher rate of price decline 

than the reference case. The results of these alternative cases are presented in appendix 

10C of the NOPR TSD. In the high price decline case, the NPV is higher than in the 

default case. In the low price decline case, the NPV is lower than in the default case.

c. Impacts on Employment

DOE expects energy conservation standards for conventional ovens to reduce 

energy bills for consumers of those products, and the resulting net savings to be 

redirected to other forms of economic activity. These expected shifts in spending and 

economic activity could affect the demand for labor. As described in section IV.N of this 

notice, DOE used an input/output model of the U.S. economy to estimate indirect 

employment impacts of the TSLs that DOE considered in this rulemaking. DOE 

understands that there are uncertainties involved in projecting employment impacts, 

especially changes in the later years of the analysis. Therefore, DOE generated results for 

near-term timeframes, where these uncertainties are reduced.

The results suggest that the proposed standards are likely to have negligible 

impact on the net demand for labor in the economy. The net change in jobs is so small 

that it would be imperceptible in national labor statistics and might be offset by other, 
186

unanticipated effects on employment. Chapter 16 of the NOPR TSD presents detailed 

results.

4. Impact on Utility or Performance of Products

Based on testing conducted in support of this proposed rule, discussed in section 

IV.C.2 of this notice, DOE concluded that the standards proposed in this NOPR would 

not reduce the utility or performance of the conventional ovens under consideration in 

this rulemaking. Manufacturers of these products currently offer units that meet or exceed 

the proposed standards. 

5. Impact of Any Lessening of Competition

DOE has also considered any lessening of competition that is likely to result from 

the proposed standards. The Attorney General determines the impact, if any, of any 

lessening of competition likely to result from a proposed standard, and transmits such 

determination to DOE, together with an analysis of the nature and extent of such impact. 

(42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii))

DOE will transmit a copy of this NOPR and the accompanying TSD to the 

Attorney General, requesting that the DOJ provide its determination on this issue. DOE 

will consider DOJ’s comments on the proposed rule in determining whether to proceed

with the proposed energy conservation standards. DOE will also publish and respond to 

DOJ’s comments in the Federal Register.
187

6. Need of the Nation to Conserve Energy

Enhanced energy efficiency, where economically justified, improves the nation’s 

energy security, strengthens the economy, and reduces the environmental impacts of 

energy production. Reduced electricity demand due to energy conservation standards is 

also likely to reduce the cost of maintaining the reliability of the electricity system, 

particularly during peak-load periods. As a measure of this reduced demand, chapter 15 

in the NOPR TSD presents the estimated reduction in generating capacity for the TSLs 

that DOE considered in this rulemaking.

Energy savings from proposed standards for conventional ovens are expected to 

yield environmental benefits in the form of reduced emissions of air pollutants and 

greenhouse gases. Table V-41. provides DOE’s estimate of cumulative emissions 

reductions to result from the TSLs considered in this rulemaking. DOE reports annual 

emissions reductions for each TSL in chapter 13 of the NOPR TSD.
188

Table V-41. Conventional Ovens: Cumulative Emissions Reduction for Products 

Shipped in 2019–2048

Trial Standard Level

1 2 3

Power Sector Emissions

CO2 (million metric tons) 9.0 38.6 68.2

SO2 (thousand tons) 7.4 29.1 51.8

NOX (thousand tons) 6.9 32.2 56.7

Hg (tons) 0.02 0.09 0.16

CH4 (thousand tons) 0.88 3.51 6.22

N2O (thousand tons) 0.13 0.50 0.89

Upstream Emissions

CO2 (million metric tons) 0.52 2.52 4.42

SO2 (thousand tons) 0.09 0.36 0.63

NOX (thousand tons) 7.5 36.6 64.2

Hg (tons) 0.00 0.00 0.00

CH4 (thousand tons) 43.6 218 381

N2O (thousand tons) 0.00 0.02 0.03

Total FFC Emissions

CO2 (million metric tons) 9.5 41.1 72.6

SO2 (thousand tons) 7.5 29.5 52.4

NOX (thousand tons) 14.4 68.8 120.9

Hg (tons) 0.02 0.09 0.16

CH4 (thousand tons) 44.4 221.2 387.5

CH4 (thousand tons 

CO2eq)* 1,244 6,195 10,849 

N2O (thousand tons) 0.13 0.52 0.92

N2O (thousand tons 

CO2eq)* 34.6 137.0 243.2

* CO2eq is the quantity of CO2 that would have the same GWP.

As part of the analysis for this proposed rule, DOE estimated monetary benefits 

likely to result from the reduced emissions of CO2 and NOX that DOE estimated for each 

of the considered TSLs. As discussed in section IV.L of this notice, for CO2, DOE used 
189

the most recent values for the SCC developed by an interagency process. The four sets of 

SCC values for CO2 emissions reductions in 2015 resulting from that process (expressed 

in 2014$) are represented by $12.2/metric ton (the average value from a distribution that

uses a 5-percent discount rate), $41.2/metric ton (the average value from a distribution 

that uses a 3-percent discount rate), $63.4/metric ton (the average value from a 

distribution that uses a 2.5-percent discount rate), and $121/metric ton (the 95th-percentile 

value from a distribution that uses a 3-percent discount rate). The values for later years 

are higher due to increasing damages (emissions-related costs) as the projected 

magnitude of climate change increases. 

Table V-42. presents the global value of CO2 emissions reductions at each TSL. 

For each of the four cases, DOE calculated a present value of the stream of annual values 

using the same discount rate as was used in the studies upon which the dollar-per-ton 

values are based. DOE calculated domestic values as a range from 7 percent to 23 percent 

of the global values; these results are presented in chapter 14 of the NOPR TSD.
190

Table V-42. Conventional Ovens: Estimates of Global Present Value of CO2

Emissions Reduction for Products Shipped in 2019–2048

TSL

SCC Case*

5% discount 

rate, average

3% discount 

rate, average

2.5% discount 

rate, average

3% discount 

rate, 95th

percentile

Million 2014$

Power Sector Emissions

1 62.0 288.2 458.0 892.8

2 266.7 1,238.9 1,968.8 3,836.7 

3 473.1 2,194.1 3,485.5 6,794.3

Upstream Emissions

1 3.5 16.6 26.5 51.5

2 17.1 80.0 127.4 248.0

3 30.0 140.6 223.8 435.8

Total FFC Emissions

1 65.5 304.8 484.5 944.3 

2 283.8 1,319.0 2,096.1 4,084.7

3 503.1 2,334.7 3,709.3 7,230.1 

DOE is well aware that scientific and economic knowledge about the contribution 

of CO2 and other GHG emissions to changes in the future global climate and the 

potential resulting damages to the world economy continues to evolve rapidly. Thus, any 

value placed on reducing CO2 emissions in this rulemaking is subject to change. DOE, 

together with other Federal agencies, will continue to review various methodologies for 

estimating the monetary value of reductions in CO2 and other GHG emissions. This 

ongoing review will consider the comments on this subject that are part of the public 

record for this and other rulemakings, as well as other methodological assumptions and 

issues. However, consistent with DOE’s legal obligations, and taking into account the 
191

uncertainty involved with this particular issue, DOE has included in this proposed rule 

the most recent values and analyses resulting from the interagency process.

DOE also estimated the cumulative monetary value of the economic benefits 

associated with NOX emissions reductions anticipated to result from the considered TSLs

for conventional ovens. The dollar-per-ton value that DOE used is discussed in section

IV.L of this notice. Table V-43. presents the cumulative present values for each TSL 

calculated using 7-percent and 3-percent discount rates.

Table V-43. Conventional Ovens: Estimates of Present Value of NOX Emissions 

Reduction for Products Shipped in 2019–2048

TSL 3% discount rate 7% discount rate

Million 2014$

Power Sector Emissions

1 24.6 9.7

2 113.8 45.2

3 200.9 80.1

Upstream Emissions

1 25.9 9.7

2 127.1 48.4

3 223.2 85.1

Total FFC Emissions

1 50.4 19.4

2 240.9 93.5

3 424.1 165.2

7. Summary of National Economic Impacts

The NPV of the monetized benefits associated with emissions reductions can be 

viewed as a complement to the NPV of the consumer savings calculated for each TSL 

considered in this rulemaking. 
192

Table V-44. presents the NPV values that result from adding the estimates of the 

potential economic benefits resulting from reduced CO2 and NOX emissions in each of 

four valuation scenarios to the NPV of consumer savings calculated for each TSL 

considered in this rulemaking, at both a 7-percent and 3-percent discount rate. The CO2

values used in the columns of each table correspond to the four sets of SCC values 

discussed above.

Table V-44. Conventional Ovens: Net Present Value of Consumer Savings 

Combined with Present Value of Monetized Benefits from CO2 and NOX

Emissions Reductions 

TSL

Consumer NPV at 3% Discount Rate added with:

SCC Case $12.2/t

and Medium 

NOX Value 

SCC Case $41.2/t 

and Medium 

NOX Value 

SCC Case $63.4/t 

and Medium 

NOX Value 

SCC Case $121/t

and Medium 

NOX Value 

Billion 2014$

1 1.3 1.5 1.7 2.1

2 11.5 12.6 13.4 15.3

3 7.6 9.4 10.8 14.3

TSL

Consumer NPV at 7% Discount Rate added with:

SCC Case $12.2/t 

and Medium 

NOX Value

SCC Case $41.2/t 

and Medium 

NOX Value

SCC Case $63.4/t 

and Medium 

NOX Value

SCC Case $121/t 

and Medium 

NOX Value

Billion 2014$

1 0.6 0.8 1.0 1.4

2 5.0 6.1 6.9 8.8

3 2.3 4.2 5.5 9.1

Although adding the value of consumer savings to the values of emission 

reductions provides a valuable perspective, two issues should be considered. First, the 

national operating cost savings are domestic U.S. monetary savings that occur as a result 
193

of market transactions, while the value of CO2 reductions is based on a global value. 

Second, the assessments of operating cost savings and the SCC are performed with 

different methods that use different time frames for analysis. The national operating cost 

savings is measured for the lifetime of equipment shipped in 2019 to 2048. Because CO2

emissions have a very long residence time in the atmosphere,75 the SCC values in future 

years reflect future climate-related impacts resulting from the emission of CO2 that

continue well beyond 2100.

8. Other Factors

The Secretary of Energy, in determining whether a standard is economically 

justified, may consider any other factors that the Secretary deems to be relevant. (42 

U.S.C. 6295(o)(2)(B)(i)(VII)) DOE did not consider any other factors for this NOPR.

C. Conclusion

When considering proposed standards, the new or amended energy conservation 

standard that DOE adopts for any type (or class) of covered product must be designed to 

achieve the maximum improvement in energy efficiency that the Secretary determines is 

technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) In 

determining whether a standard is economically justified, the Secretary must determine 

whether the benefits of the standard exceed its burdens, considering to the greatest extent 

practicable the seven statutory factors discussed previously. (42 U.S.C. 6295(o)(2)(B)(i)) 

 75 The atmospheric lifetime of CO2 is estimated of the order of 30–95 years. Jacobson, MZ (2005). 

"Correction to "Control of fossil-fuel particulate black carbon and organic matter, possibly the most 

effective method of slowing global warming."" J. Geophys. Res. 110. pp. D14105.
194

The new or amended standard must also result in a significant conservation of energy. 

(42 U.S.C. 6295(o)(3)(B)) 

The Department considered the impacts of standards at each TSL, beginning with 

a maximum technologically feasible level, to determine whether that level was 

economically justified. Where the max-tech level was not justified, DOE then considered 

the next most efficient level and undertook the same evaluation until it reached the 

highest efficiency level that is both technologically feasible and economically justified 

and saves a significant amount of energy.

To aid the reader as DOE discusses the benefits and/or burdens of each trial 

standard level, tables present a summary of the results of DOE’s quantitative analysis for 

each TSL. In addition to the quantitative results presented in the tables, DOE also 

considers other burdens and benefits that affect economic justification. Those include the 

impacts on identifiable subgroups of consumers who may be disproportionately affected 

by a national standard. Section V.B.1 of this notice presents the estimated impacts of 

each TSL for these subgroups.

DOE also notes that the economics literature provides a wide-ranging discussion 

of how consumers trade off upfront costs and energy savings in the absence of 

government intervention. Much of this literature attempts to explain why consumers 

appear to undervalue energy efficiency improvements. This undervaluation suggests that 

regulation that promotes energy efficiency can produce significant net private gains (as 
195

well as producing social gains by, for example, reducing pollution). There is evidence 

that consumers undervalue future energy savings as a result of (1) a lack of information; 

(2) a lack of sufficient salience of the long-term or aggregate benefits; (3) a lack of 

sufficient savings to warrant delaying or altering purchases; (4) excessive focus on the 

short term, in the form of inconsistent weighting of future energy cost savings relative to 

available returns on other investments; (5) computational or other difficulties associated 

with the evaluation of relevant tradeoffs; and (6) a divergence in incentives (between

renters and owners, or builders and purchasers). Having less than perfect foresight and a 

high degree of uncertainty about the future, consumers may trade off these types of 

investments at a higher than expected rate between current consumption and uncertain 

future energy cost savings.

In DOE’s current regulatory analysis, potential changes in the benefits and costs 

of a regulation due to changes in consumer purchase decisions are included in two ways: 

First, if consumers forego a purchase of a product in the standards case, this decreases 

sales for product manufacturers, and the impact on manufacturers attributed to lost 

revenue is included in the MIA. Second, DOE accounts for energy savings attributable 

only to products actually used by consumers in the standards case; if a regulatory option 

decreases the number of products used by consumers, this decreases the potential energy 

savings from an energy conservation standard. DOE provides estimates of shipments and 

changes in the volume of product purchases in chapter 9 of the NOPR TSD. However, 

DOE’s current analysis does not explicitly control for heterogeneity in consumer 
196

preferences, preferences across subcategories of products or specific features, or 

consumer price sensitivity variation according to household income.

76

While DOE is not prepared at present to provide a fuller quantifiable framework 

for estimating the benefits and costs of changes in consumer purchase decisions due to an 

energy conservation standard, DOE is committed to developing a framework that can

support empirical quantitative tools for improved assessment of the consumer welfare 

impacts of appliance standards. DOE has posted a paper that discusses the issue of 

consumer welfare impacts of appliance energy efficiency standards, and potential

enhancements to the methodology by which these impacts are defined and estimated in 

the regulatory process.77 DOE welcomes comments on how to more fully assess the 

potential impact of energy conservation standards on consumer choice and how to 

quantify this impact in its regulatory analysis in future rulemakings.

1. Benefits and Burdens of TSLs Considered for Conventional Ovens

Table V-45. and Table V-46. summarize the quantitative impacts estimated for 

each TSL for conventional ovens. The efficiency levels contained in each TSL are 

described in section V.A of this notice.

 76 P.C. Reiss and M.W. White. Household Electricity Demand, Revisited. Review of Economic Studies

(2005) 72, 853–883. 77 Alan Sanstad, Notes on the Economics of Household Energy Consumption and Technology Choice. 

Lawrence Berkeley National Laboratory. 2010. Available online at: 

www1.eere.energy.gov/buildings/appliance_standards/pdfs/consumer_ee_theory.pdf
197

Table V-45. Conventional Ovens: Summary of National Impacts

Category TSL 1 TSL 2 TSL 3

Cumulative FFC Energy Savings quads

0.163 0.709 1.251

NPV of Consumer Costs and Benefits 2014$ billion

3% discount rate 1.2 11.0 6.7

7% discount rate 0.5 4.7 1.7

Cumulative FFC Emissions Reduction

CO2 million metric 

tons 9.5 41.1 72.6

SO2 thousand tons 7.5 29.5 52.4

NOX thousand tons 14.4 68.8 120.9

Hg tons 0.02 0.09 0.16 

CH4 thousand tons 44.4 221.2 387.5 

CH4 thousand tons

CO2eq* 1,244 6,195 10,849 

N2O thousand tons 0.13 0.52 0.92

N2O thousand tons

CO2eq* 34.6 137.0 243.2

Value of Emissions Reduction

CO2 2014$ million*

* 66 to 944 284 to 4,085 503 to 7,230

NOX – 3% discount 

rate 2014$ million 50.4 240.9 424.1

NOX – 7% discount 

rate 2014$ million 19.4 93.5 165.2

Parentheses indicate negative (-) values.

* CO2eq is the quantity of CO2 that would have the same GWP.

** Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced 

CO2 emissions.
198

Table V-46. Conventional Ovens: Summary of Manufacturer and Consumer 

Impacts

Category TSL 1 TSL 2 TSL 3*

Manufacturer Impacts

Industry NPV (2014$ million) 

(Base Case INPV = $783.5)

762.1 -

762.8 697.1 - 702.6 56.0 - 140.6

Industry NPV (% change) (2.7) - (2.6) (11.0) -

(10.3) (92.9) - (82.0)

Consumer Average LCC Savings (2014$)

PC1: Electric Standard 

Ovens, Free-Standing $13.96 $15.18 ($37.60)

PC2: Electric Standard 

Ovens, Built-in/Slide-in $14.11 $15.25 ($37.64)

PC3: Electric Self-Clean 

Ovens, Free-Standing $14.10 $14.10 ($27.79)

PC4: Electric Self-Clean 

Ovens, Built-in/Slide-in $14.20 $14.20 ($27.80)

PC5: Gas Standard Ovens, 

Free-Standing $0.00 $289.73 $178.91

PC6: Gas Standard Ovens, 

Built-In/Slide-In $0.00 $289.77 $178.92

PC7: Gas Self-Clean Ovens, 

Free-Standing $18.02 $282.80 $165.73

PC8: Gas Self-Clean Ovens, 

Built-In/Slide-In $18.03 $282.85 $165.75

Consumer Simple PBP (years)

PC1: Electric Standard 

Ovens, Free-Standing 0.9 4.0 17.5

PC2: Electric Standard 

Ovens, Built-in/Slide-in 0.9 4.0 17.5

PC3: Electric Self-Clean 

Ovens, Free-Standing 0.9 0.9 18.1

PC4: Electric Self-Clean 

Ovens, Built-in/Slide-in 0.9 0.9 18.1

PC5: Gas Standard Ovens, 

Free-Standing -- 1.7 5.3

PC6: Gas Standard Ovens, 

Built-In/Slide-In -- 1.7 5.3

PC7: Gas Self-Clean Ovens, 

Free-Standing 0.8 1.2 5.4

PC8: Gas Self-Clean Ovens, 

Built-In/Slide-In 0.8 1.2 5.4

% of Consumers that Experience Net Cost

PC1: Electric Standard 

Ovens, Free-Standing 0 12 82
199

Category TSL 1 TSL 2 TSL 3*

PC2: Electric Standard 

Ovens, Built-in/Slide-in 0 12 82

PC3: Electric Self-Clean 

Ovens, Free-Standing 0 0 76

PC4: Electric Self-Clean 

Ovens, Built-in/Slide-in 0 0 76

PC5: Gas Standard Ovens, 

Free-Standing 0 0 24

PC6: Gas Standard Ovens, 

Built-In/Slide-In 0 0 24

PC7: Gas Self-Clean Ovens, 

Free-Standing 0 0 27

PC8: Gas Self-Clean Ovens, 

Built-In/Slide-In 0 0 27

* Parentheses indicate negative (-) values. 

DOE first considered TSL 3, which represents the max-tech efficiency levels. 

TSL 3 would save 1.25 quads of energy, an amount DOE considers significant. TSL 3 

has an estimated NPV of consumer benefit of 1.7 billion using a discount rate of 7 

percent, and 6.7 billion using a discount rate of 3 percent.

The cumulative emissions reductions at TSL 3 are 72.6 Mt of CO2, 120.9

thousand tons of NOX, 52.4 thousand tons of SO2, 0.2 ton of Hg, 387.5 thousand tons of 

CH4, and 0.92 thousand tons of N2O. The estimated monetary value of the CO2 emissions 

reduction at TSL 3 ranges from $503 million to $7,230 million.

At TSL 3, the average LCC impact is a savings ranging from -$37.64 for PC2 

(Electric Standard Ovens, Built-In/Slide-In) to $178.92 for product class 6 (Gas Standard 

Ovens, Built-in/Slide-in). The simple payback period ranges from 5 years for PC5, PC6, 

PC7, and PC8 (Gas Standard Ovens, Free-Standing and Built-In/Slide-In, and Gas Self-
200

Clean Ovens, Free-Standing and Built-In/Slide-In) to 18 years for PC1, PC2, PC3, and 

PC4 (Electric Standard Ovens, Built-In/Slide-In and Free-Standing and Electric SelfClean Ovens, Built-In/Slide-In and Free-Standing). The fraction of consumers 

experiencing an LCC net cost ranges from 24 percent for PC5 and PC6 (Gas Standard 

Ovens, Free-Standing and Built-In/Slide-In) to 82 percent for PC1 and PC2 (Electric 

Standard Oven, Free-Standing and Built-In/Slide-In).

At TSL 3, the projected change in INPV ranges from a decrease of $727.5 million 

to a decrease of $642.9 million, equivalent to a loss of 92.9 percent and a loss of 82.0

percent, respectively.

Products that meet the efficiency standards specified by this TSL are forecast to 

represent 11 percent of shipments in the year leading up to new and amended standards. 

As such, manufacturers would have to redesign the vast majority of their products by the 

2019 compliance date to meet demand. Redesigning all these units to meet the current 

max-tech efficiency levels would require considerable capital and equipment conversion 

expenditures. At TSL 3, the capital conversion costs total $528.0 million, 4.3 times the 

industry annual capital expenditure in the year leading up to new and amended standards. 

DOE estimates that complete platform redesigns would cost the industry $401.5 million 

in product conversion costs. These conversion costs largely relate to the research 

programs required to develop new products that meet the efficiency standards set forth by 

TSL 3. These costs are equivalent to 4.5 times the industry annual budget for research 

and development. Total capital and product conversion costs associated with the changes 
201

in products and manufacturing facilities required at TSL 3 would require significant use 

of manufacturers’ financial reserves , impacting other areas of business that compete for 

these resources, and significantly reducing INPV. In addition, manufacturers could face a 

substantial impact on profitability at TSL 3. Because manufacturers are more likely to 

reduce their margins to maintain a price-competitive product at higher TSLs, DOE 

expects that TSL 3 would yield impacts closer to the high end of the range of INPV 

impacts. If the high end of the range of impacts is reached, as DOE expects, TSL 3 could 

result in a net loss of 92.9 percent in INPV to residential conventional oven

manufacturers. As a result, at TSL 3, DOE expects that some companies could be forced 

to exit the residential conventional oven market or shift production abroad, both of which 

would negatively impact domestic manufacturing capacity and employment.

In view of the foregoing, DOE concludes that, at TSL 3 for conventional ovens, 

the benefits of energy savings, positive NPV of total customer benefits, customer LCC 

savings for four of the eight product classes, emission reductions and the estimated 

monetary value of the emissions reductions would be outweighed by the negative 

customer impacts for product classes 1, 2, 3, and 4 (Electric Standard Ovens, FreeStanding and Built-In/Slide-In and Electric Self-Clean Ovens, Free-Standing and BuiltIn/Slide-In), the significant reduction in industry value at TSL 3, as well as the potential 

for loss of domestic manufacturing. Consequently, DOE has concluded that TSL 3 is not 

economically justified.
202

DOE then considered TSL 2. TSL 2 would save 0.71 quads of energy, an amount 

DOE considers significant. Under TSL 2, the estimated NPV of consumer benefit is $4.7

billion using a discount rate of 7 percent, and $11.0 billion using a discount rate of 3 

percent.

The cumulative emissions reductions at TSL 2 are 41.1 Mt of CO2, 68.8 thousand 

tons of NOX, 29.5 thousand tons of SO2, 0.09 tons of Hg, 221.2 thousand tons of CH4, 

and 0.52 thousand tons of N2O. The estimated monetary value of the CO2 emissions 

reduction at TSL 2 ranges from $284 million to $4,085 million.

At TSL 2, the average LCC impact is a savings ranging from $14.10 for PC3

(Electric Self-Clean Ovens, Free-Standing) to $289.77 for PC6 (Gas Standard Ovens,

Built-In/Slide-in). The simple payback period ranges from 1 year for PC3, PC4, PC7, and 

PC8 (Electric Self-Clean Ovens, Free-Standing and Built-In/Slide-In and Gas Self-Clean 

Ovens, Free-Standing and Built-In/Slide-In) to 4 years for PC1 and PC2 (Electric 

Standard Ovens Free-Standing and Built-In/Slide-In). The fraction of consumers 

experiencing an LCC net cost ranges from zero percent for PC3 through PC8 (Electric 

Self-Clean Ovens, Free-Standing and Built-In/Slide-In, Gas Standard Ovens, FreeStanding and Built-In/Slide-In, and Gas Self-Clean Ovens, Free-Standing and BuiltIn/Slide-In) to 12 percent for PC1 and PC2 (Electric Standard Ovens, Free-Standing and 

Built-In/Slide-In).
203

At TSL 2, the projected change in INPV ranges from a decrease of $86.4 million

to a decrease of $80.9 million, equivalent to a loss of 11.0 percent and a loss of 10.3

percent, respectively. Products that meet the efficiency standards specified by this TSL 

are forecast to represent 46 percent of shipments in the year leading up to new and 

amended standards. DOE estimates that compliance with TSL 2 would require 

manufacturers to make an estimated $42.0 million in capital conversion costs. This 

represents a 0.3 times increase in the annual capital expenditure budget in the year 

leading up to new and amended standards. TSL 2 will also require manufacturers to make 

an estimated $67.9 million in product conversion costs primarily relating to the research 

and development programs needed to improve upon existing platforms to meet the 

specified efficiency levels. This represents 0.8 times the industry budget for research and 

development in the year leading up to new and amended standards. The substantial 

reduction in conversion costs corresponding to compliance with TSL 2 greatly mitigates 

the operational risk and impact on INPV.

The Secretary tentatively concludes that at TSL 2 for residential conventional 

ovens, the benefits of energy savings, positive NPV of consumer benefits, emission 

reductions, and the estimated monetary value of the CO2 emissions reductions, and 

positive average LCC savings would outweigh the negative impacts on some consumers 

and on manufacturers, including the conversion costs that would result in a reduction in 

INPV for manufacturers.
204

After considering the analysis and the benefits and burdens of TSL 2, DOE has 

tentatively concluded that this TSL will offer the maximum improvement in efficiency 

that is technologically feasible and economically justified, and will result in significant 

conservation of energy. Therefore, DOE proposes TSL 2 for conventional ovens. The 

proposed energy conservation standards for conventional ovens are shown in Table 

V-47..

Table V-47. Proposed Amended Energy Conservation Standards for Conventional 

Ovens

Compliance Date:

January 1, 2019

Product Class

Integrated Annual Energy Consumption 

(IAEC)

Electricity 

Consumption kWh/

year

Gas Consumption

kBtu/year

Electric Standard Ovens, Free-Standing

122.5 + (31.8 × 

Rated Cavity 

Volume)

--

Electric Standard Ovens, Built-in/Slide-in

128.6 + (31.8 × 

Rated Cavity 

Volume)

--

Electric Self-Clean Ovens, Free-Standing

163.2 + (42.3 × 

Rated Cavity 

Volume) 

--

Electric Self-Clean Ovens, Built-in/Slide-in

169.1 + (42.3 × 

Rated Cavity 

Volume)

--

Gas Standard Ovens, Free-Standing --

492.9 + (214.4 × 

Rated Cavity 

Volume)

Gas Standard Ovens, Built-in/Slide-in --

499.5 + (214.4 × 

Rated Cavity 

Volume)

Gas Self-Clean Ovens, Free-Standing --

746.7 + (214.4 × 

Rated Cavity 

Volume)

Gas Self-Clean Ovens, Built-In/Slide-in --

755.5 + (214.4 × 

Rated Cavity 

Volume)

Note: The Rated Cavity Volume is the volume of the oven cavity in cubic feet as measured using the final 

DOE test procedure at 10 CFR part 430, subpart B, appendix I.
205

2. Annualized Benefits and Costs of the Proposed Standards

The benefits and costs of the proposed standards can also be expressed in terms of 

annualized values. The annualized monetary values are the sum of (1) the annualized 

national economic value of the benefits from operating products that meet the proposed 

standards (consisting of operating cost savings from using less energy, minus increases in 

product purchase costs, which is another way of representing consumer NPV), and (2) the 

monetary value of the benefits of CO2 and NOX emission reductions.

78

Table V-48 shows the annualized values for conventional ovens under TSL 2, 

expressed in 20132014$. The results under the primary estimate are as follows. Using a 

7-percent discount rate for benefits and costs other than CO2 reductions, for which DOE 

used a 3-percent discount rate along with the SCC series corresponding to a value of 

$40.541.2/ton in 2015 (in 20132014$), the cost of the standards for conventional cooking 

productsovens in the proposedtoday’s rule is $12.733.5 million per year in increased 

equipment costs, while the annualized benefits are $112494 million per year in reduced 

equipment operating costs, $36.174 million in CO2 reductions, and $2.19 million in 

reduced NOX emissions. In this case, the net benefit amounts to $138543 million per 

year. Using a 3-percent discount rate for all benefits and costs and the SCC series 

corresponding to a value of $40.541.2/ton in 2015 (in 20132014$), the cost of the 

 78 To convert the time-series of costs and benefits into annualized values, DOE calculated a present value in 

2014, the year used for discounting the NPV of total consumer costs and savings. For the benefits, DOE 

calculated a present value associated with each year’s shipments in the year in which the shipments occur 

(2020, 2030, etc.), and then discounted the present value from each year to 2014. The calculation uses

discount rates of 3 and 7 percent for all costs and benefits except for the value of CO2 reductions, for which 

DOE used case-specific discount rates. Using the present value, DOE then calculated the fixed annual

payment over a 30-year period, starting in the compliance year that yields the same present value.
206

standards for conventional ovens in today’s rule is $12.633.1 million per year in 

increased equipment costs, while the benefits are $131648 million per year in reduced 

operating costs, $36.174 million in CO2 reductions, and $2.313 million in reduced NOX

emissions. In this case, the net benefit amounts to $157701 million per year.
207

Table V-48. Annualized Benefits and Costs of Proposed Amended Standards (TSL 

2) for Conventional Ovens Sold in 2019–2048

Discount Rate

Primary 

Estimate*

Low Net 

Benefits 

Estimate*

High Net 

Benefits 

Estimate*

Million 20132014$/year

Benefits

Consumer Operating Cost 

Savings

7% 631494 597457 678542

3% 832648 784593 900719

CO2 Reduction at 

$12.02/t** 5% 3821 3520 4224

CO2 Reduction at 

$40.541.2/t** 3% 13174 12168 14581

CO2 Reduction at 

$6263.4/t** 2.5% 193108 178100 213119

CO2 Reduction at 

$119121/t** 3% 406228 376211 449252

NOX Reduction at 

$2,684/t† 

7% 9.24 8.66 910.11

3% 1113.43 1012.46 1214.80

Total†††

7% plus CO2

range

678524 to 

1,046731

640485 to 

980677

730576 to 

1,137804

7% 771577 726534 833634

3% plus CO2

range

881682 to 

1,250889

829625 to 

1,170817

954758 to 

1,361986

3% 975734 915674 1,057815

Costs

Consumer Incremental 

Product Costs

7% 3334 3634 3133

3% 33 3634 3033

Total††

7% plus CO2

range

645491 to 

1,013697

604451 to 

944642

699543 to 

1,106771

7% 738543 690499 802601

3% plus CO2

range

849649 to 

1,217856

793592 to 

1,133783

924725 to 

1,331953

3% 942701 879640 1,027783
208

* The results include benefits to consumers which accrue after 2048 from products purchased from 2019 

through 2048. Costs incurred by manufacturers, some of which may be incurred prior to 2019 in 

preparation for the rule, are not directly included, but are indirectly included as part of incremental 

equipment costs. The Primary, Low Benefits, and High Benefits Estimates utilize forecasts of energy prices 

and housing starts from the AEO 20142015 Reference case, Low Estimate, and High Estimate, 

respectively. In addition, incremental product costs reflect a medium decline rate for projected product 

price trends in the Primary Estimate, a low decline rate in the Low Benefits Estimate, and a high decline 

rate in the High Benefits Estimate. The methods used to derive projected price trends are explained in 

section IV.F.1 of this notice.

** The CO2 values represent global values (in 20132014$) of the social cost of CO2 emissions in 2015 

under several scenarios. The values of $12.0, $40.52, $41.2, and $6263.4 per ton are the averages of SCC 

distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The value of $119121 per ton 

represents the 95th percentile of the SCC distribution calculated using a 3% discount rate.

†† The $/ton values used for NOX are described in section IV.L.2.

†† Total Benefits for both the 3% and 7% cases are derived using the SCC value calculated at a 3% 

discount rate, which is $40.541.2/ton in 2015 (20132014$). In the rows labeled as “7% plus CO2 range” 

and “3% plus CO2 range,” the operating cost and NOX benefits are calculated using the labeled discount 

rate, and those values are added to the full range of CO2 values.

VI. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

Section 1(b)(1) of Executive Order 12866, “Regulatory Planning and Review,” 58 

FR 51735 (Oct. 4, 1993), requires each agency to identify the problem that it intends to 

address, including, where applicable, the failures of private markets or public institutions 

that warrant new agency action, as well as to assess the significance of that problem. The 

problems that the proposed standards address are as follows:

(1) Insufficient information and the high costs of gathering and analyzing relevant 

information leads some consumers to miss opportunities to make cost-effective 

investments in energy efficiency.

(2) In some cases the benefits of more efficient products are not realized due to 

misaligned incentives between purchasers and users. An example of such a case is 
209

when the products purchase decision is made by a building contractor or building 

owner who does not pay the energy costs.

(3) There are external benefits resulting from improved energy efficiency of 

appliances that are not captured by the users of such equipment. These benefits 

include externalities related to public health, environmental protection, and 

national security that are not reflected in energy prices, such as reduced emissions 

of air pollutants and greenhouse gases that impact human health and global

warming.

In addition, DOE has determined that this regulatory action is a “an

“economically significant regulatory action” under Executive Order 12866. DOE 

presented to the Office of Information and Regulatory Affairs (OIRA) in the OMB for 

review the draft rule and other documents prepared for this rulemaking, including a 

regulatory impact analysis (RIA), and has included these documents in the rulemaking 

record. The assessments prepared pursuant to Executive Order 12866 can be found in the 

technical support document for this rulemaking.

DOE has also reviewed this regulation pursuant to Executive Order 13563. 76 FR 

3281 (Jan. 21, 2011). Executive Order 13563 is supplemental to and explicitly reaffirms 

the principles, structures, and definitions governing regulatory review established in 

Executive Order 12866. To the extent permitted by law, agencies are required by 

Executive Order 13563 to: (1) propose or adopt a regulation only upon a reasoned 

determination that its benefits justify its costs (recognizing that some benefits and costs 
210

are difficult to quantify); (2) tailor regulations to impose the least burden on society, 

consistent with obtaining regulatory objectives, taking into account, among other things, 

and to the extent practicable, the costs of cumulative regulations; (3) select, in choosing 

among alternative regulatory approaches, those approaches that maximize net benefits 

(including potential economic, environmental, public health and safety, and other 

advantages; distributive impacts; and equity); (4) to the extent feasible, specify 

performance objectives, rather than specifying the behavior or manner of compliance that 

regulated entities must adopt; and (5) identify and assess available alternatives to direct 

regulation, including providing economic incentives to encourage the desired behavior, 

such as user fees or marketable permits, or providing information upon which choices can 

be made by the public.

DOE emphasizes as well that Executive Order 13563 requires agencies to use the 

best available techniques to quantify anticipated present and future benefits and costs as 

accurately as possible. In its guidance, the Office of Information and Regulatory Affairs 

has emphasized that such techniques may include identifying changing future compliance 

costs that might result from technological innovation or anticipated behavioral changes. 

For the reasons stated in the preamble, DOE believes that the NOPR is consistent with 

these principles, including the requirement that, to the extent permitted by law, benefits 

justify costs and that net benefits are maximized.
211

B. Review Under the Regulatory Flexibility Act

The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires preparation of an 

initial regulatory flexibility analysis (IRFA) for any rule that by law must be proposed for 

public comment, unless the agency certifies that the rule, if promulgated, will not have a 

significant economic impact on a substantial number of small entities. As required by 

Executive Order 13272, “Proper Consideration of Small Entities in Agency Rulemaking,” 

67 FR 53461 (August 16, 2002), DOE published procedures and policies on February 19, 

2003, to ensure that the potential impacts of its rules on small entities are properly 

considered during the rulemaking process. 68 FR 7990. DOE has made its procedures 

and policies available on the Office of the General Counsel’s website 

(http://energy.gov/gc/office-general-counsel). DOE has prepared the following IRFA for 

the products that are the subject of this rulemaking.

1. Description and Estimated Number of Small Entities Regulated

a. Methodology for Estimating the Number of Small Entities

For manufacturers of residential conventional ovens, the Small Business 

Administration (SBA) has set a size threshold, which defines those entities classified as 

“small businesses” for the purposes of the statute. DOE used the SBA’s small business 

size standards to determine whether any small entities would be subject to the 

requirements of the rule. 65 FR 30836, 30848 (May 15, 2000), as amended at 65 FR 

53533, 53544 (September 5, 2000) and codified at 13 CFR part 121. The size standards 

are listed by North American Industry Classification System (NAICS) code and industry 

description and are available 
212

at http://www.sba.gov/sites/default/files/files/Size_Standards_Table.pdf. Residential 

conventional oven manufacturing is classified under NAICS 335221, “Household 

Cooking Appliance Manufacturing.” The SBA sets a threshold of 750 employees or 

fewer for an entity to be considered a small business for this category.

DOE reviewed the potential standard levels considered in this NOPR under the 

provisions of the Regulatory Flexibility Act and the procedures and policies published on 

February 19, 2003. To better assess the potential impacts of this rulemaking on small 

entities, DOE conducted a more focused inquiry of the companies that could be small 

business manufacturers of products covered by this rulemaking. During its market 

survey, DOE used available public information to identify potential small manufacturers. 

DOE’s research involved industry trade association membership directories (e.g., 

AHAM), information from previous rulemakings, individual company websites, and 

market research tools (e.g., Hoover’s reports) to create a list of companies that 

manufacture or sell residential conventional ovens covered by this rulemaking. 

Table VI-1. Sources Used to Identify Residential Conventional Oven Manufacturers

Source Number of Large 

Manufacturers Identified

Number of Small 

Manufacturers Identified

AHAM Trade Association Directory 10 1

Previous Rulemaking 2 3

Market Research 0 3

Total 12 7

DOE also asked stakeholders and industry representatives if they were aware of 

any additional small manufacturers during manufacturer interviews and at DOE public 

meetings. DOE reviewed publicly available data and contacted various companies on its 
213

complete list of manufacturers, as necessary, to determine whether they met the SBA’s 

definition of a small business manufacturer. DOE screened out companies that do not 

offer products impacted by this rulemaking, do not meet the definition of a “small 

business,” or are foreign owned and operated.

DOE identified 19 companies that either manufacture or sell residential 

conventional ovens that would be affected by this proposal. Of these 19 companies, DOE 

identified seven that met the SBA’s definition of a small business.

b. Manufacturer Participation

DOE contacted identified businesses to invite them to take part in a manufacturer 

impact analysis interview. Of the businesses contacted, DOE was able to reach and 

discuss potential standards with one small business. DOE also obtained information about 

small businesses and potential impacts on small businesses while interviewing large 

manufacturers.

c. Residential Conventional Oven Industry Structure and Nature of Competition

Three major manufacturers supply approximately 85 percent of the market for 

residential conventional ovens. DOE estimates that the remaining 15 percent of the 

market is served by a combination of small businesses and large businesses. None of the 

three major manufacturers of residential conventional ovens affected by this rulemaking 

is a small business.
214

d. Comparison between Large and Small Manufacturers

In general, small manufacturers differ from large manufacturers in several ways 

that affect the extent to which a manufacturer may be impacted by proposed standards. 

Characteristics of small manufacturers typically include: lower production volumes, 

fewer engineering resources, and less access to capital. Lower production volumes in 

particular may place small manufacturers at a competitive disadvantage relative to large 

manufacturers as they convert products and facilities to comply with new and amended 

standards. When producing at lower volumes, a small manufacturer’s conversion costs 

must be spread over fewer units than a larger competitor’s. Therefore, unless a small 

manufacturer can differentiate its products in order to earn a price premium, the small 

manufacturer may experience a disproportionate cost penalty as it spreads one-time 

conversion costs over fewer unit sales. Additionally, when producing at lower volumes, 

small manufacturers may lack the purchasing power of their larger competitors and may 

therefore face higher costs when sourcing components for more efficient products. 

Disadvantages tied to lower production volumes may be further exacerbated by the fact 

that small manufacturers often have more limited engineering resources than their larger 

competitors, thereby complicating the redesign effort required to comply with new and 

amended standards. Finally, small manufacturers often have less access to capital, which 

may be needed to cover the conversion costs associated with new and amended standards. 

Combined, these factors may entail a disproportionate burden on small manufacturers.
215

2. Description and Estimate of Compliance Requirements

At TSL 1 DOE estimates capital conversion costs of $0.3 million and product 

conversion costs of $0.1 million for an average small manufacturer. For an average large 

manufacturer, DOE estimates capital conversion costs of $0.6 million and product 

conversion costs of $0.3 million.

At TSL 2, the level proposed here, DOE estimates capital conversion costs of $1.3

million and product conversion costs of $4.1 million for an average small manufacturer. 

For an average large manufacturer, DOE estimates capital conversion costs of $2.7

million and product conversion costs of $3.3 million. Table VI-2 presents the estimated 

conversion costs as a percentage of annual revenue for an average small manufacturer 

relative to an average large manufacturer.

Table VI-2. Conversion Costs Facing an Average Small Manufacturer versus an 

Average Large Manufacturer of Residential Conventional Ovens

Capital Conversion Costs 

as a Percentage of Annual 

Revenue

Product Conversion Costs 

as a Percentage of Annual

Revenue

Total Conversion Costs 

as a Percentage of 

Annual Revenue

Average Small 

Manufacturer 2% 6% 8%

Average Large 

Manufacturer 1% 1% 1%

At TSL 3, DOE estimates capital conversion costs of $16.5 million and product 

conversion costs of $19.2 million for an average small manufacturer. For an average 

large manufacturer, DOE estimates capital conversion costs of $34.4 million and product 

conversion costs of $22.2 million. 
216

As the results for TSL 2 indicate, new and amended energy conservation 

standards could potentially impact small businesses disproportionately. Although 

estimated conversion costs at TSL 2 are higher for an average large manufacturer than an 

average small manufacturer, the relative impacts of conversion costs on large 

manufacturers will likely be offset by higher annual revenues. This is consistent with the 

dynamic previously described, whereby large manufacturers tend to have larger 

production and sales volumes over which to spread costs and may also enjoy a 

competitive advantage due to their size and ability to access capital that may not be 

available to small manufacturers. Since the proposed standards could cause competitive

concerns for small manufacturers, DOE cannot certify that the proposed standards would 

not have a significant impact on a substantial number of small businesses.

DOE requests comments on the number of small businesses identified and on the 

impacts of new and amended energy conservation standards on small businesses.

3. Duplication, Overlap, and Conflict with Other Rules and Regulations

DOE is not aware of any rules or regulations that duplicate, overlap, or conflict 

with the rule being proposed.

4. Significant Alternatives to the Rule

The discussion in the previous section analyzes impacts on small businesses that 

would result from DOE’s new and amended standards. In addition to the other TSLs 

being considered, the NOPR TSD includes a regulatory impacts analysis (RIA). For 
217

residential conventional cooking products, the RIA discusses the following policy 

alternatives: (1) no change in standard; (2) consumer rebates; (3) consumer tax credits; 

(4) manufacturer tax credits; (5) voluntary energy efficiency targets; and (6) bulk 

government purchases. While these alternatives may mitigate to some varying extent the 

economic impacts on small entities compared to the proposed standards, DOE did not 

consider these alternatives further because they are either not feasible to implement 

without authority and funding from Congress, or are expected to result in energy savings 

that are much smaller (ranging from approximately XX percent to XX percent of the 

primary energy savings) than those that will be achieved by the standard levels proposed 

in this NOPR. In reviewing alternatives, DOE also examined energy conservation 

standards set at a lower efficiency levels, TSL 1. However, TSL 1 achieves 75 percent 

lower energy savings and 84 percent less NPV benefits to consumers compared to the 

energy savings and NPV benefits at TSL 2. While TSL 1 would reduce the impacts on 

small business manufacturers, it would come at the expense of a significant reduction in 

energy savings and NPV benefits to consumers, which would be inconsistent with DOE’s 

statutory mandate to maximize the improvement in energy efficiency that the Secretary 

determines is technologically feasible and economically justifiedIn reviewing alternatives

to the proposed rule, DOE examined energy conservation standards set at higher and

lower efficiency levels, TSL 3 and TSL1, respectively. As discussed in section VI.B.2, 

compared to TSL 3, DOE estimates that the capital conversion costs and product 

conversion costs for an average small manufacturer at TSL 2 would be 92 and 79 percent 

lower, respectively. The substantial reduction in small manufacturer capital and product 
218

conversion costs corresponding to TSL 2 compared to TSL 3 greatly mitigates the 

operational risk and the impact of the standard on INPV.

While TSL 1 would reduce the impacts on small business manufacturers, it would 

come at the expense of a significant reduction in energy savings and NPV benefits to 

consumers, achieving 75 percent lower energy savings and 84 percent less NPV benefits 

to consumers compared to the energy savings and NPV benefits at TSL 2.

DOE believes that establishing standards at TSL 2 balances the benefits of the 

energy savings and the NPV benefits to consumers created at TSL 2 with the potential 

burdens placed on residential conventional oven manufacturers, including small business 

manufacturers. Accordingly, DOE is declining to adopt anyone of thesethe other TSLs 

considered above, or the other policy alternatives analyzed and is proposing the standards 

set forthdetailed as part of the regulatory impacts analysis included in this NOPR. 

Chapter 17 of this NOPR TSD contains further detail on the policy alternatives DOE 

considered as part of the RIA.

Additional compliance flexibilities may be available through other means. For 

example, individual manufacturers may petition for a waiver of the applicable test 

procedure. (See 10 CFR 431.401.) Further, EPCA provides that a manufacturer whose 

annual gross revenue from all of its operations does not exceed $8,000,000 may apply for 

an exemption from all or part of an energy conservation standard for a period not longer 

than 24 months after the effective date of a final rule establishing the standard. (42 U.S.C. 
219

6295 (t)). DOE estimates that two of the seven small manufacturers could potentially 

petition for a waiver based on their annual gross revenue not exceeding $8 million. 

Additionally, Section 504 of the Department of Energy Organization Act, 42 U.S.C. 

7194, provides authority for the Secretary to adjust a rule issued under EPCA in order to 

prevent “special hardship, inequity, or unfair distribution of burdens” that may be 

imposed on that manufacturer as a result of such rule. Manufacturers should refer to 10 

CFR part 430, subpart E, and part 1003 for additional details

DOE continues to seek input from businesses that would be affected by this 

rulemaking and will consider comments received in the development of any final rule.

(See section VII.E. that solicits specific data as well as input on the results of the analyses 

contained in this section VI.B.4).

C. Review Under the Paperwork Reduction Act

Manufacturers of covered products must certify to DOE that their products 

comply with any applicable energy conservation standards. In certifying compliance, 

manufacturers must test their products according to the applicable DOE test procedure, 

including any amendments adopted for that test procedure. DOE has established 

regulations for the certification and recordkeeping requirements for all covered consumer 

products and commercial equipment, including conventional cooking products. 76 FR 

12422 (March 7, 2011). The collection-of-information requirement for the certification 

and recordkeeping is subject to review and approval by OMB under the Paperwork 

Reduction Act (PRA). This requirement has been approved by OMB under OMB control 
220

number 1910-1400. Public reporting burden for the certification is estimated to average 

30 hours per response, including the time for reviewing instructions, searching existing 

data sources, gathering and maintaining the data needed, and completing and reviewing 

the collection of information. 

Notwithstanding any other provision of the law, no person is required to respond 

to, nor shall any person be subject to a penalty for failure to comply with, a collection of 

information subject to the requirements of the PRA, unless that collection of information 

displays a currently valid OMB Control Number.

D. Review Under the National Environmental Policy Act of 1969

Pursuant to the National Environmental Policy Act (NEPA) of 1969, DOE has 

determined that the proposed rule fits within the category of actions included in

Categorical Exclusion (CX) B5.1 and otherwise meets the requirements for application of 

a CX. See 10 CFR Part 1021, App. B, B5.1(b); 1021.410(b) and Appendix B, B(1)-(5). 

The proposed rule fits within the category of actions because it is a rulemaking that 

establishes energy conservation standards for consumer products or industrial equipment, 

and for which none of the exceptions identified in CX B5.1(b) apply. Therefore, DOE has 

made a CX determination for this rulemaking, and DOE does not need to prepare an 

Environmental Assessment or Environmental Impact Statement for this proposed rule. 

DOE’s CX determination for this proposed rule is available at http://cxnepa.energy.gov/.
221

E. Review Under Executive Order 13132

Executive Order 13132, “Federalism.” 64 FR 43255 (Aug. 10, 1999) imposes 

certain requirements on Federal agencies formulating and implementing policies or 

regulations that preempt State law or that have Federalism implications. The Executive 

Order requires agencies to examine the constitutional and statutory authority supporting 

any action that would limit the policymaking discretion of the States and to carefully 

assess the necessity for such actions. The Executive Order also requires agencies to have 

an accountable process to ensure meaningful and timely input by State and local officials 

in the development of regulatory policies that have Federalism implications. On March 

14, 2000, DOE published a statement of policy describing the intergovernmental 

consultation process it will follow in the development of such regulations. 65 FR 13735. 

EPCA governs and prescribes Federal preemption of State regulations as to energy 

conservation for the products that are the subject of this proposed rule. States can petition 

DOE for exemption from such preemption to the extent, and based on criteria, set forth in 

EPCA. (42 U.S.C. 6297) No further action is required by Executive Order 13132.

F. Review Under Executive Order 12988

With respect to the review of existing regulations and the promulgation of new 

regulations, section 3(a) of Executive Order 12988, “Civil Justice Reform,” imposes on 

Federal agencies the general duty to adhere to the following requirements: (1) eliminate 

drafting errors and ambiguity; (2) write regulations to minimize litigation; and (3) 

provide a clear legal standard for affected conduct rather than a general standard and 

promote simplification and burden reduction. 61 FR 4729 (Feb. 7, 1996). Section 3(b) of 
222

Executive Order 12988 specifically requires that Executive agencies make every 

reasonable effort to ensure that the regulation: (1) clearly specifies the preemptive effect, 

if any; (2) clearly specifies any effect on existing Federal law or regulation; (3) provides 

a clear legal standard for affected conduct while promoting simplification and burden 

reduction; (4) specifies the retroactive effect, if any; (5) adequately defines key terms; 

and (6) addresses other important issues affecting clarity and general draftsmanship under 

any guidelines issued by the Attorney General. Section 3(c) of Executive Order 12988 

requires Executive agencies to review regulations in light of applicable standards in 

section 3(a) and section 3(b) to determine whether they are met or it is unreasonable to 

meet one or more of them. DOE has completed the required review and determined that, 

to the extent permitted by law, this proposed rule meets the relevant standards of 

Executive Order 12988.

G. Review Under the Unfunded Mandates Reform Act of 1995

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA) requires each 

Federal agency to assess the effects of Federal regulatory actions on State, local, and 

Tribal governments and the private sector. Pub. L. 104-4, sec. 201 (codified at 2 U.S.C. 

1531). For a proposed regulatory action likely to result in a rule that may cause the 

expenditure by State, local, and Tribal governments, in the aggregate, or by the private 

sector of $100 million or more in any one year (adjusted annually for inflation), section 

202 of UMRA requires a Federal agency to publish a written statement that estimates the 

resulting costs, benefits, and other effects on the national economy. (2 U.S.C. 1532(a),

(b)) The UMRA also requires a Federal agency to develop an effective process to permit 
223

timely input by elected officers of State, local, and Tribal governments on a proposed 

“significant intergovernmental mandate,” and requires an agency plan for giving notice 

and opportunity for timely input to potentially affected small governments before 

establishing any requirements that might significantly or uniquely affect small 

governments. On March 18, 1997, DOE published a statement of policy on its process for 

intergovernmental consultation under UMRA. 62 FR 12820. DOE’s policy statement is

also available at http://energy.gov/gc/office-general-counsel.

Although the proposed rule does not contain a Federal intergovernmental 

mandate, it may require expenditures of $100 million or more on the private sector. 

Specifically, the proposed rule will likely result in a final rule that could require 

expenditures of $100 million or more. Such expenditures may include: (1) investment in 

research and development and in capital expenditures by conventional cooking product

manufacturers in the years between the final rule and the compliance date for the new 

standards, and (2) incremental additional expenditures by consumers to purchase higherefficiency conventional cooking products, starting at the compliance date for the 

applicable standard.

Section 202 of UMRA authorizes a Federal agency to respond to the content 

requirements of UMRA in any other statement or analysis that accompanies the proposed 

rule. 2 U.S.C. 1532(c). The content requirements of section 202(b) of UMRA relevant to 

a private sector mandate substantially overlap the economic analysis requirements that 

apply under section 325(o) of EPCA and Executive Order 12866. The 
224

SUPPLEMENTARY INFORMATION section of the NOPR and the “Regulatory 

Impact Analysis” section of the TSD for this proposed rule respond to those 

requirements. 

Under section 205 of UMRA, the Department is obligated to identify and consider 

a reasonable number of regulatory alternatives before promulgating a rule for which a 

written statement under section 202 is required. 2 U.S.C. 1535(a). DOE is required to 

select from those alternatives the most cost-effective and least burdensome alternative 

that achieves the objectives of the proposed rule unless DOE publishes an explanation for 

doing otherwise, or the selection of such an alternative is inconsistent with law. This

proposed rule would establish energy conservation standards for conventional cooking 

products that are designed to achieve the maximum improvement in energy efficiency 

that DOE has determined to be both technologically feasible and economically justified. 

A full discussion of the alternatives considered by DOE is presented in the “Regulatory 

Impact Analysis” section of the TSD for the proposed rule.

H. Review Under the Treasury and General Government Appropriations Act, 1999

Section 654 of the Treasury and General Government Appropriations Act, 1999 

(Pub. L. 105-277) requires Federal agencies to issue a Family Policymaking Assessment 

for any rule that may affect family well-being. This rule would not have any impact on 

the autonomy or integrity of the family as an institution. Accordingly, DOE has 

concluded that it is not necessary to prepare a Family Policymaking Assessment.
225

I. Review Under Executive Order 12630

DOE has determined, under Executive Order 12630, “Governmental Actions and 

Interference with Constitutionally Protected Property Rights” 53 FR 8859 (Mar. 18, 

1988), that this regulation would not result in any takings that might require 

compensation under the Fifth Amendment to the U.S. Constitution.

J. Review Under the Treasury and General Government Appropriations Act, 2001

Section 515 of the Treasury and General Government Appropriations Act, 2001 

(44 U.S.C. 3516, note) provides for Federal agencies to review most disseminations of 

information to the public under guidelines established by each agency pursuant to general 

guidelines issued by OMB. OMB’s guidelines were published at 67 FR 8452 (Feb. 22, 

2002), and DOE’s guidelines were published at 67 FR 62446 (Oct. 7, 2002). DOE has 

reviewed the NOPR under the OMB and DOE guidelines and has concluded that it is 

consistent with applicable policies in those guidelines.

K. Review Under Executive Order 13211

Executive Order 13211, “Actions Concerning Regulations That Significantly 

Affect Energy Supply, Distribution, or Use” 66 FR 28355 (May 22, 2001), requires 

Federal agencies to prepare and submit to OIRA at OMB, a Statement of Energy Effects 

for any proposed significant energy action. A “significant energy action” is defined as 

any action by an agency that promulgates or is expected to lead to promulgation of a final 

rule, and that: (1) is a significant regulatory action under Executive Order 12866, or any 

successor order; and (2) is likely to have a significant adverse effect on the supply, 
226

distribution, or use of energy, or (3) is designated by the Administrator of OIRA as a 

significant energy action. For any proposed significant energy action, the agency must 

give a detailed statement of any adverse effects on energy supply, distribution, or use 

should the proposal be implemented, and of reasonable alternatives to the action and their 

expected benefits on energy supply, distribution, and use. 

DOE has tentatively concluded that this regulatory action, which sets forth energy 

conservation standards for conventional cooking products, is not a significant energy 

action because the proposed standards are not likely to have a significant adverse effect 

on the supply, distribution, or use of energy, nor has it been designated as such by the 

Administrator at OIRA. Accordingly, DOE has not prepared a Statement of Energy 

Effects on the proposed rule.

L. Review Under the Information Quality Bulletin for Peer Review 

On December 16, 2004, OMB, in consultation with the Office of Science and 

Technology Policy (OSTP), issued its Final Information Quality Bulletin for Peer Review 

(the Bulletin). 70 FR 2664 (Jan. 14, 2005). The Bulletin establishes that certain scientific 

information shall be peer reviewed by qualified specialists before it is disseminated by 

the Federal Government, including influential scientific information related to agency 

regulatory actions. The purpose of the bulletin is to enhance the quality and credibility of 

the Government’s scientific information. Under the Bulletin, the energy conservation 

standards rulemaking analyses are “influential scientific information,” which the Bulletin 

defines as scientific information the agency reasonably can determine will have, or does 
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have, a clear and substantial impact on important public policies or private sector 

decisions. 70 FR 2667.

In response to OMB’s Bulletin, DOE conducted formal in-progress peer reviews 

of the energy conservation standards development process and analyses and has prepared 

a Peer Review Report pertaining to the energy conservation standards rulemaking 

analyses. Generation of this report involved a rigorous, formal, and documented 

evaluation using objective criteria and qualified and independent reviewers to make a 

judgment as to the technical/scientific/business merit, the actual or anticipated results, 

and the productivity and management effectiveness of programs and/or projects. The 

“Energy Conservation Standards Rulemaking Peer Review Report” dated February 2007 

has been disseminated and is available at the following Web 

site: www1.eere.energy.gov/buildings/appliance_standards/peer_review.html.

VII. Public Participation

A. Attendance at the Public Meeting

The time, date, and location of the public meeting are listed in the DATES and 

ADDRESSES sections at the beginning of this notice. If you plan to attend the public 

meeting, please notify Ms. Brenda Edwards at (202) 586-2945 

or Brenda.Edwards@ee.doe.gov. Please note that foreign nationals participating in the 

public meeting are subject to advance security screening procedures which require 

advance notice prior to attendance at the public meeting. If a foreign national wishes to 

participate in the public meeting, please inform DOE of this fact as soon as possible by 
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contacting Ms. Regina Washington at (202) 586-1214 or by email: Regina.Washington@ee.doe.gov so that the necessary procedures can be 

completed. 

Please also note that those wishing to bring laptops into the Forrestal Building 

will be required to obtain a property pass. Visitors should avoid bringing laptops, or 

allow an extra 45 minutes.

Due to the REAL ID Act implemented by the Department of Homeland Security 

(DHS), there have been recent changes regarding ID requirements for individuals wishing 

to enter Federal buildings from specific states and U.S. territories. Driver's licenses from 

the following states or territory will not be accepted for building entry and one of the 

alternate forms of ID listed below will be required. DHS has determined that regular 

driver's licenses (and ID cards) from the following jurisdictions are not acceptable for 

entry into DOE facilities: Alaska, American Samoa, Arizona, Louisiana, Maine, 

Massachusetts, Minnesota, New York, Oklahoma, and Washington. Acceptable alternate 

forms of Photo-ID include: U.S. Passport or Passport Card; an Enhanced Driver's License 

or Enhanced ID-Card issued by the states of Minnesota, New York or Washington 

(Enhanced licenses issued by these states are clearly marked Enhanced or Enhanced 

Driver's License); a military ID or other Federal government issued Photo-ID card.

In addition, you can attend the public meeting via webinar. Webinar registration 

information, participant instructions, and information about the capabilities available to 

webinar participants will be published on DOE’s website at: [INSERT LINK].
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Participants are responsible for ensuring their systems are compatible with the webinar 

software.

B. Procedure for Submitting Prepared General Statements For Distribution

Any person who has plans to present a prepared general statement may request 

that copies of his or her statement be made available at the public meeting. Such persons 

may submit requests, along with an advance electronic copy of their statement in PDF 

(preferred), Microsoft Word or Excel, WordPerfect, or text (ASCII) file format, to the 

appropriate address shown in the ADDRESSES section at the beginning of this notice. 

The request and advance copy of statements must be received at least one week before 

the public meeting and may be emailed, hand-delivered, or sent by mail. DOE prefers to 

receive requests and advance copies via email. Please include a telephone number to 

enable DOE staff to make follow-up contact, if needed.

C. Conduct of the Public Meeting

DOE will designate a DOE official to preside at the public meeting and may also 

use a professional facilitator to aid discussion. The meeting will not be a judicial or 

evidentiary-type public hearing, but DOE will conduct it in accordance with section 336 

of EPCA (42 U.S.C. 6306). A court reporter will be present to record the proceedings and 

prepare a transcript. DOE reserves the right to schedule the order of presentations and to 

establish the procedures governing the conduct of the public meeting. After the public 

meeting, interested parties may submit further comments on the proceedings as well as on 

any aspect of the rulemaking until the end of the comment period.
230

The public meeting will be conducted in an informal, conference style. DOE will 

present summaries of comments received before the public meeting, allow time for 

prepared general statements by participants, and encourage all interested parties to share 

their views on issues affecting this rulemaking. Each participant will be allowed to make 

a general statement (within time limits determined by DOE), before the discussion of 

specific topics. DOE will allow, as time permits, other participants to comment briefly on 

any general statements. 

At the end of all prepared statements on a topic, DOE will permit participants to 

clarify their statements briefly and comment on statements made by others. Participants 

should be prepared to answer questions by DOE and by other participants concerning 

these issues. DOE representatives may also ask questions of participants concerning other 

matters relevant to this rulemaking. The official conducting the public meeting will 

accept additional comments or questions from those attending, as time permits. The 

presiding official will announce any further procedural rules or modification of the above 

procedures that may be needed for the proper conduct of the public meeting.

A transcript of the public meeting will be included in the docket, which can be 

viewed as described in the Docket section at the beginning of this notice. In addition, any 

person may buy a copy of the transcript from the transcribing reporter.
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D. Submission of Comments

DOE will accept comments, data, and information regarding this proposed rule 

before or after the public meeting, but no later than the date provided in the DATES 

section at the beginning of this proposed rule. Interested parties may submit comments, 

data, and other information using any of the methods described in the ADDRESSES 

section at the beginning of this notice. 

Submitting comments via regulations.gov. The regulations.gov web page will 

require you to provide your name and contact information. Your contact information will 

be viewable to DOE Building Technologies staff only. Your contact information will not 

be publicly viewable except for your first and last names, organization name (if any), and 

submitter representative name (if any). If your comment is not processed properly 

because of technical difficulties, DOE will use this information to contact you. If DOE 

cannot read your comment due to technical difficulties and cannot contact you for 

clarification, DOE may not be able to consider your comment.

However, your contact information will be publicly viewable if you include it in 

the comment itself or in any documents attached to your comment. Any information that 

you do not want to be publicly viewable should not be included in your comment, nor in 

any document attached to your comment. Otherwise, persons viewing comments will see 

only first and last names, organization names, correspondence containing comments, and 

any documents submitted with the comments. 
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Do not submit to regulations.gov information for which disclosure is restricted by 

statute, such as trade secrets and commercial or financial information (hereinafter 

referred to as Confidential Business Information (CBI)). Comments submitted through 

regulations.gov cannot be claimed as CBI. Comments received through the website will 

waive any CBI claims for the information submitted. For information on submitting CBI, 

see the Confidential Business Information section below.

DOE processes submissions made through regulations.gov before posting. 

Normally, comments will be posted within a few days of being submitted. However, if 

large volumes of comments are being processed simultaneously, your comment may not 

be viewable for up to several weeks. Please keep the comment tracking number that 

regulations.gov provides after you have successfully uploaded your comment. 

Submitting comments via email, hand delivery/courier, or mail. Comments and 

documents submitted via email, hand delivery, or mail also will be posted to 

regulations.gov. If you do not want your personal contact information to be publicly 

viewable, do not include it in your comment or any accompanying documents. Instead, 

provide your contact information in a cover letter. Include your first and last names, 

email address, telephone number, and optional mailing address. The cover letter will not 

be publicly viewable as long as it does not include any comments

Include contact information each time you submit comments, data, documents, 

and other information to DOE. If you submit via mail or hand delivery/courier, please 
233

provide all items on a CD, if feasible. It is not necessary to submit printed copies. No 

facsimiles (faxes) will be accepted.

 

Comments, data, and other information submitted to DOE electronically should 

be provided in PDF (preferred), Microsoft Word or Excel, WordPerfect, or text (ASCII) 

file format. Provide documents that are not secured, that are written in English, and that 

are free of any defects or viruses. Documents should not contain special characters or any 

form of encryption and, if possible, they should carry the electronic signature of the 

author. 

Campaign form letters. Please submit campaign form letters by the originating 

organization in batches of between 50 to 500 form letters per PDF or as one form letter 

with a list of supporters’ names compiled into one or more PDFs. This reduces comment 

processing and posting time. 

Confidential Business Information. According to 10 CFR 1004.11, any person 

submitting information that he or she believes to be confidential and exempt by law from 

public disclosure should submit via email, postal mail, or hand delivery/courier two wellmarked copies: one copy of the document marked confidential including all the 

information believed to be confidential, and one copy of the document marked nonconfidential with the information believed to be confidential deleted. Submit these 

documents via email or on a CD, if feasible. DOE will make its own determination about 

the confidential status of the information and treat it according to its determination.
234

Factors of interest to DOE when evaluating requests to treat submitted 

information as confidential include: (1) A description of the items; (2) whether and why 

such items are customarily treated as confidential within the industry; (3) whether the 

information is generally known by or available from other sources; (4) whether the 

information has previously been made available to others without obligation concerning 

its confidentiality; (5) an explanation of the competitive injury to the submitting person 

which would result from public disclosure; (6) when such information might lose its 

confidential character due to the passage of time; and (7) why disclosure of the 

information would be contrary to the public interest.

It is DOE’s policy that all comments may be included in the public docket, 

without change and as received, including any personal information provided in the 

comments (except information deemed to be exempt from public disclosure). 

E. Issues on Which DOE Seeks Comment

Although DOE welcomes comments on any aspect of this proposal, DOE is 

particularly interested in receiving comments and views of interested parties concerning 

the following issues: 

1. DOE seeks comment on its proposal to develop two distinct component 

standards under separate timetables, and whether issues of product design and 
235

development, consumer utility and more broadly, cumulative regulatory burden 

concerns would arise as a result of its proposal (see section III.A of this notice).

2. DOE requests comment on its decision to defer the consideration of 

adopting energy conservation standards for conventional cooking tops until a 

representative, repeatable and reproducible test method for cooking tops is finalized. 

DOE invites data and information that will allow it to further conduct the analysis of 

cooking tops, particularly when using a water-heating method to evaluate energy 

consumption. (see section III.B of this notice). 

3. DOE requests comment on the proposed product classes for residential 

conventional cooking products. DOE requests comment on establishing separate 

product classes for freestanding and built-in/slide-in ovens. DOE also welcomes 

comment and data on the determination that conventional gas cooking products with 

higher input rates do not warrant establishing a separate product class. (see section 

IV.A.2 of this notice).

4. DOE seeks data that characterize the energy consumption of residential 

steam ovens currently available on the market and requests comment regarding 

whether a test procedure that accurately measures the energy of a steam cooking 

mode exists. DOE also seeks comment on the use of optimized burner and cavity 

design (and other options listed in Table IV-5) to meet the proposed efficiency levels 

discussed in section I.A.1.b (see section IV.A.3 of this notice). 
236

5. DOE requests comment and data regarding additional design options or 

variants of the considered design options that can increase the range of considered 

efficiency improvements for conventional cooking products, including design options 

that may not yet be found in the market (see section IV.B.2 of this notice).

6. DOE requests comment on the proposed baseline and incremental 

efficiency levels. DOE specifically requests inputs and test data on the efficiency 

improvements associated with the design options identified at each incremental 

efficiency level that were determined based on either the analysis from the 2009 TSD 

or updated based on testing and reverse engineering analyses for this NOPR. DOE 

also seeks comment and data on the proposed slopes and intercepts used to 

characterize the relationship between IAEC and oven cavity volume for each 

conventional oven product class (see section IV.C.3 of this notice).

7. DOE requests input and data on the proposed incremental manufacturing 

production costs for each efficiency level analyzed that were determined based on 

either the analysis from the 2009 TSD adjusted to reflect changes in the PPI or costs 

determined based on testing and reverse engineering analyses conducted for this 

NOPR (see section IV.C.4 of this notice).

8. DOE seeks comment on the tentative determination that the proposed 

efficiency levels and design options would not impact the consumer utility of 

conventional ovens (see section IV.C.5 of this notice). 
237

9. DOE requests comments on repair costs and frequency of repair incurred 

by gas standard and self-clean ovens with Glo-bar ignition and electronic spark 

ignition technologies. In this NOPR, DOE used data from 2008 provided by the 

industry (see section IV.E.5 of this notice for details). 

10. DOE requests data that would allow for use of different price trend 

projections for electric and gas cooking products. (see section IV.H.3.b of this notice)

11. To estimate the impact on shipments of the price increase for the 

considered efficiency levels, DOE determined that the overall market will be inelastic 

to price changes and will not impact shipments. DOE welcomes stakeholder input on 

the effect of amended standards on impacts across products within the same fuel class 

and equipment. (see section IV.G of this notice).

12. DOE requests comment on the reasonableness of the approach DOE has 

used to consider the rebound effect with higher-efficiency cooking products. (see 

section IV.F.3 of this notice)

13. DOE requests comment on DOE’s approach for estimating monetary 

benefits associated with emissions reductions. (see section IV.L of this notice).
238

14. DOE seeks comment on the proposed manufacturer markup of 1.20 for all 

residential conventional ovens (see section IV.J.2).

15. DOE seeks comment on the potential domestic employment impacts to 

residential conventional oven manufacturers at the proposed efficiency levels (see 

section V.B.2).

16. DOE requests comment on any potential manufacturer capacity constraints 

caused by the proposed standards in the NOPR, TSL 2 (see section V.B.2).

17. DOE requests comment on manufacturer subgroups that DOE should 

analyze and/or types of residential conventional oven manufacturers for the subgroup 

analysis (see section V.B.2).

18. DOE seeks comment on the compliance costs of any other regulations 

residential conventional oven manufacturers must make, especially if compliance 

with those regulations is required three years before or after the estimated compliance 

date of this proposed standard (2019) (see section V.B.2).

19. DOE requests comments on the number of small businesses identified and 

on the impacts of new and amended energy conservation standards on small 

businesses (see section VI.B).
239

VIII. Approval of the Office of the Secretary

The Secretary of Energy has approved publication of this proposed rule.
240

List of Subjects in 10 CFR Part 430

Administrative practice and procedure, Confidential business information, Energy 

conservation, Household appliances, Imports, Intergovernmental relations, Reporting and 

recordkeeping requirements, and Small businesses. 

Issued in Washington, DC, on 

________________________________

David T. Danielson

Assistant Secretary

Energy Efficiency and Renewable Energy
241

For the reasons set forth in the preamble, DOE proposes to amend part 430 of 

chapter II, subchapter D, of title 10 of the Code of Federal Regulations, as set forth 

below: 

PART 430 - ENERGY CONSERVATION PROGRAM FOR CONSUMER 

PRODUCTS

1. The authority citation for Part 430 continues to read as follows:

Authority: 42 U.S.C. 6291-6309; 28 U.S.C. 2461 note.

2. In §430.2 revising the definitions of “conventional cooking top” and “conventional 

oven” to read as follows:

§430.2 Definitions.

* * * * *

Conventional cooking top means a class of kitchen ranges and ovens which is a 

household cooking appliance consisting of a horizontal surface containing one or more 

surface units which include either a gas flame or electric resistance heating. This includes 

the conventional cooking top portion of a conventional range.

Conventional oven means a class of kitchen ranges and ovens which is a 

household cooking appliance consisting of one or more compartments intended for the 

cooking or heating of food by means of either a gas flame or electric resistance heating. It 

does not include portable or countertop ovens which use electric resistance heating for 
242

the cooking or heating of food and are designed for an electrical supply of approximately 

120 volts. This includes the conventional oven(s) portion of a conventional range.

* * * * *

3. In §430.32 revise paragraph (j) to read as follows:

§430.32 Energy and water conservation standards and their compliance dates.

* * * * *

(j) Cooking Products. 

(1) Gas cooking products with an electrical supply cord manufactured on or after January 

1, 1990, shall not be equipped with a constant burning pilot light.

(2) Gas cooking products without an electrical supply cord manufactured on or after 

April 9, 2012, shall not be equipped with a constant burning pilot light.

(3) Conventional ovens manufactured on or after [INSERT DATE 3 YEARS AFTER 

FINAL RULE FEDERAL REGISTER PUBLICATION] shall have an integrated annual 

energy consumption no greater than:
243

Product Class

Integrated Annual Energy 

Consumption

Electric Standard Oven, Free-standing 122.5 + (31.8 × Rated Cavity 

Volume in cubic feet) kWh/yr

Electric Standard Oven, Built-In/Slide-In 128.6 + (31.8 × Rated Cavity 

Volume in cubic feet) kWh/yr

Electric Self-Clean Oven, Free-Standing 163.2 + (42.3 × Rated Cavity 

Volume in cubic feet) kWh/yr

Electric Self-Clean Oven, Built-In/Slide-In 169.1 + (42.3 × Rated Cavity 

Volume in cubic feet) kWh/yr

Gas Standard Oven, Free-Standing 492.9 + (214.4 × Rated Cavity 

Volume in cubic feet) kWh/yr

Gas Standard Oven, Built-In/Slide-In 499.5 + (214.4 × Rated Cavity 

Volume in cubic feet) kWh/yr

Gas Self-Clean Oven, Free-Standing 746.7 + (214.4 × Rated Cavity 

Volume in cubic feet) kWh/yr

Gas Self-Clean Oven, Built-In/Slide-In 755.5 + (214.4 × Rated Cavity 

Volume in cubic feet) kWh/yr

Note: The Rated Cavity Volume is the volume of the oven cavity in cubic feet as 

measured using the final DOE test procedure at 10 CFR part 430, subpart B, appendix I.

(4) Microwave-only ovens and countertop convection microwave ovens manufactured on 

or after June 17, 2016 shall have an average standby power not more than 1.0 watt. Builtin and over-the-range convection microwave ovens manufactured on or after June 17, 

2016 shall have an average standby power not more than 2.2 watts.

* * * * *