# APPENDIX 17A. REGULATORY IMPACT ANALYSIS SUPPORTING

MATERIAL

TABLE OF CONTENTS

17A.1 BACKGROUND ON MARKET PE NETRATION CURVES DEVELOPED

BY XENERGY..................................................................................................... 17A-1

17A.2 UTILITY REBATE PROGRAMS FOR COMMERCIAL CLOTHES

WASHERS AND RESIDENTIAL DISHWASHERS ......................................... 17A-2 17A.2.1 Rebate Programs for Commercial Clothes Washers............................................. 17A-3 17A.2.2 Rebate Programs for Residential Dishwashers..................................................... 17A-5

17A.3 DEVELOPMENT OF CONSUMER TAX CREDITS IMPACT ANALYSIS.... 17A-9

17A.4 EPACT 2005 FEDERAL TAX CREDIT LEVELS FOR RESIDENTIAL

APPLIANCES AND APPLIANCE MANUFACTURERS ............................... 17A-11 17A.4.3 Residential Appliances........................................................................................ 17A-11 17A.4.4 Energy Efficient Appliance Credits for Manufacturers...................................... 17A-11

LIST OF TABLES

Table 17A.2.1 Rebate Programs for Commercial Clothes Washers................................. 17A-4 Table 17A.2.2 Rebate Programs for Residential Dishwashers......................................... 17A-6

LIST OF FIGURE

Figure 17A.1.1 	 Comparison of Exponential and Logistic Curves Showing External and

Internal Influences on Consumers ............................................................ 17A-2

17A-i

# APPENDIX 17A. REGULATORY IMPACT ANALYSIS SUPPORTING MATERIAL

17A.1	 BACKGROUND ON MARKET PENETRATION CURVES DEVELOPED BY

XENERGY

Xenergy, Inc. developed a re-parameterized, mixed-source information diffusion model to estimate market impacts induced by financial incentives for energy-efficient appliances. The basic premise of this mixed-source model is that information diffusion drives technology adoption.

There is extensive economic literature on the diffusion process of new products as technologies evolve. Some of the literature focuses primarily on the development of analytical models of diffusion patterns of new products for individual consumers or for technologies from

competing firms. 1



# , 2



# , 3 

# One study records researchers’ attempts to investigate underlying factors that drive diffusion processes. 4 

# Because of the distinct characteristics of diverse new products, few studies have conclusively developed a universally-applicable model. Some key findings, however, have seemed to gain wide recognition in academia and industry.

First, new technologies may not be adopted by all potential users, regardless of their economic benefits and technological merits. Therefore, a ceiling on the adoption rate exists for many products. Second, not all adopters purchase new products at the same time; some act earlier after the introduction of a new product, while others respond slowly, waiting for products to become more mature. Third, diffusion processes can be approximately characterized by asymmetric S-curves, depicting three stages of diffusion: starting, accelerating, and decreasing as the adoption ceiling is being reached.

An important diffusion model, the epidemic model , is widely used in marketing and social studies on diffusion. It assumes that a) consumers value the benefits of a new product identically and b) the cost of a new product is constant or declines monotonically over time. What induces a consumer to purchase the new product is information about the availability and the benefits of the product. In other words, it is information diffusion that drives new product adoption by individual consumers. 3 

# The model incorporates information diffusion from both internal sources (news spread by word of mouth from early adopters) and external sources (the “announcement effect” by government, other institutions, or commercial advertising) by superimposing a logistic function with an exponential function. 1,4



# The relative degree of influence by internal or external sources determines the general shape of the diffusion curve of a specific product. 1,4 

# For instance, if the adoption of one particular product is more influenced by external sources of information diffusion (announcement effect) than by internal sources (word of mouth among earlier adopters to prospective adopters), the rate of diffusion at the beginning stage of the diffusion process is much higher. This reflects the immediate information exposure to a significant number of

17A-1

# prospective adopters brought about by external sources, in contrast to the more gradual exposure to internal sources such as news propagation by earlier adopters, a small proportion of the population, to other prospective adopters. Graphically speaking, a relatively dominant external source of information diffusion gives an immediate jump-start to the adoption of a new product in the first years, forming a concave curve with respect to the Y axis (see the exponential curve in Figure A.1). Adoption of a new product with a stronger influence by internal sources of information diffusion (such as a socially-tightened network formed by prospective adopters) may start with a few early adopters and gradually increase as the number of adopters grows, and thus form a convex curve (see the logistic curve in Figure 17A.1.1).

100%

90%

80%

70%

60%

50%

40%

30%

20%

10% Logistic Function Modified Exponential Function

0% 

# External Influence

Internal InfluenceMarket Penetration



# 0 5 10 15 20 25



# Year



# Figure 17A.1.1	 Comparison of Exponential and Logistic Curves Showing External

and Internal Influences on Consumers

17A.2	 UTILITY REBATE PROGRAMS FOR COMMERCIAL CLOTHES

WASHERS AND RESIDENTIAL DISHWASHERS

The following two tables present a summary of rebate program amounts offered throughout the U.S. for commercial clothes washers and for residential dishwashers.

17A-2 30

# 17A.2.1 Rebate Programs for Commercial Clothes Washers

DOE found 24 agencies with programs for commercial clothes washers. Rebates for this product have been offered by electric utilities, gas utilities, water utilities, and municipal and regional agencies. These entities offer rebates for commercial clothes washers meeting efficiency criteria that usually match those set by ENERGY STAR or the Consortium for Energy Efficiency. In some areas customers can receive rebates from both their energy and water utilities. Table 17A.2.1 shows the agency names, States, rebate amounts, and program websites. Multiple entries in the table indicate either that an agency offers two rebate amounts (i.e., one for customers with gas water heaters and another for those with electric water heaters) or that the agency is an umbrella for several rebate programs. The average rebate amount is a simple average of the wide range of all of the entries (rather than being population-weighted).

17A-3Table 17A.2.1 Rebate Programs for Commercial Clothes WashersUtility or AgencyStateAmountWebsiteAlliant EnergyIA$100http://alliantenergy.com/docs/groups/public/documents/pub/p015218.hcspCPUC LightWash (former)CA$450http://www.cuwcc.org/Uploads/annual_reports/FY2003/Annual_Report_2003.pdfLADWPCA$430http://www.ladwp.com/ladwp/cms/ladwp001820.jspSoCalGas, SCECA$210http://www.mwdsaveabuck.com/multifamily.htmlSDG&E (Sempra)CA$75http://sdge.com/residential/PY2006-08MFapplication.pdfBAWSCA (Bay Area)CA$220https://www.conservationrebates.com/programs/cop/CoinOp.aspxContra Costa County Water District/PG&ECA$220http://www.ccwater.com/conserve/rebates_cwasher.aspSFPUCCA$150http://www.friendlyplumber.com/plumbing101/commercialwasherrebate.html$200EBMUDCA$150http://www.ebmud.com/conserving_&_recycling/non_residential/clotheswasher_rebate/default.htm$250Silicon Valley PowerCA$350http://www.siliconvalleypower.com/bus/?sub=rebatewashCity of AustinTX$250http://www.ci.austin.tx.us/watercon/cwasher.htm$100Seattle Public UtilitiesWA$100http://www.savingwater.org/business_laundryrebate.htm$125$50http://www.savingwater.org/inside_laundry_washwise.htm$75$100BPA$180http://www.bpa.gov/Energy/N/projects/post2006conservation/manual/$75PG&ECA$35http://www.pge.com/includes/docs/pdfs/application/07App_GI.pdf$75EBMUDCA$150http://www.ebmud.com/conserving_&_recycling/non_residential/clotheswasher_rebate/default.htm$250Riverside Public UtilitiesCA$75http://www.riversideca.gov/utilities/busi-energystar.aspAlbuquerque Water Utility AuthorityNM$100http://www.abcwua.org/pdfs/Washer%20Rebate.pdfMarin CountyCA$50www.marinwater.orgHelix Water District (San Diego)CA$300Truckee Donner PUDCA$100http://www.tdpud.org/index.php?cId=34Energy Trust of OregonOR$225http://www.energytrust.org/residential/mf/clotheswashers.html$180Puget Sound EnergyWA$200http://www.pse.com/solutions/forbusiness/pages/comRebates.aspx?tab=4&chapter=2Seattle Water UtilityWA$300http://www.savingwater.org/business_WSTP.htm#financialNumber of Agencies24Average Rebate Amount$174Rebate Percent of Incremental Cost31%Websites last accessed January, 2008.17A-4

# 17A.2.2 Rebate Programs for Residential Dishwashers

DOE found 88 agencies with programs for residential dishwashers. Rebates for this product have been offered by electric utilities, gas utilities, and municipal and regional agencies. These entities offer rebates for dishwashers meeting efficiency criteria that usually match those set by ENERGY STAR or the Consortium for Energy Efficiency. Table 17A.2.2 shows the agency names, States, rebate amounts, and program websites. Multiple entries in the table indicate that an agency offers two rebate amounts, one for customers with gas water heaters and another for those with electric water heaters. The average rebate amount is a simple average of the wide range of all of the entries.

17A-5Table 17A.2.2 Rebate Programs for Residential DishwashersUtility or AgencyStateAmountWebsiteCity of RosevilleCA$25http://www.conservationrebates.com/programs/REC/AppliancesProgram.aspxAspen CORECO$75http://www.aspencore.org/sitepages/pid46.php#washerFort Collins UtilitiesCO$25http://fcgov.com/water/washer-rebate.phpHoly Cross EnergyCO$25http://www.holycross.com/$75Longmont PowerCO$50http://www.ci.longmont.co.us/lpc/index.htmGroton UtilitiesCT$60http://www.grotonutilities.com/elec_conserv_resident_appliance.aspKootenai ElectricID$25http://www.kec.com/rebates.phpRocky Mountain PowerID, UT$20http://www.homeenergysavings.net/idaho/dishwashers.htmlLinn County RECIA$50http://www.linncountyrec.com/cgi-script/csarticles/articles/000003/000334.htmMaquoketa Valley RECIA$25http://www.mvec.com/index.php?option=com_content&task=view&id=20&Itemid=23#starEastern Iowa RECIA$25http://www.easterniowa.com/East-Central RECIA$25http://www.ecirec.coop/prod_serv/rebates.shtmlTIP RECIA$35http://www.tiprec.com/rebates.htmlConsumers EnergyIA$25http://www.consumersenergy.coop/residential/products_services/incentives/index.htmlGuthrie County RECIA$25http://www.guthrie-rec.coop/cgi-script/csArticles/articles/000000/000049.htmFarmers RECIA$25http://www.farmersrec.com/Promotions.htmSouthwest Iowa RECIA$25http://www.swiarec.coop/prod_serv/rebates.shtmlClarke ECIA$25http://www.cecnet.net/rebates.htmlChicopee Electric LightMA$50http://www.celd.com/news.php?id=36Concord Muni Light PlantMA$50http://www.concordma.gov/pages/ConcordMA_LightPlant/applianceMansfield Muni Elec Dep'tMA$75http://www.mansfieldelectric.com/rebateBrochure/billingForm.htmlMarblehead Light Dep'tMA$25http://www.marbleheadelectric.com/rebate.htmMarblehead Light Dep'tMA$50http://www.marbleheadelectric.com/rebate.htmNorth Attleboro ElectricMA$30http://www.dsireusa.org/library/includes/incentivesearch.cfm?Incentive_Code=MA61F&Search=TableType&type=Rebate&CurrentPageID=7&EE=1&RE=1Reading Muni Light Dep'tMA$50http://www.rmld.com/rebates.htmShrewsbury ElectricMA$50http://www.shrewsbury-ma.gov/light/rebates.aspWakefield Gas & LightMA$50http://www.wakefield.ma.us/Public_Documents/WakefieldMA_MGLD/rcsprogram.htmLincoln Electric Co-OpMT$10http://www.lincolnelectric.coop/energy_star_rebates.htmCity of AnaheimCA$50http://www.anaheim.net/article.asp?id=992Burbank Water and PowerCA$75http://www.burbankwaterandpower.com/homerewards.htmlPG&ECA$30http://www.pge.com/res/rebates/dishwashers/index.html$50SDG&E (Sempra)CA$30http://www.sdge.com/residential/singleFamilyRebate/docs/rebateOverview.pdfSouthern California GasCA$30http://www.socalgas.com/residential/savemoney/instant.shtml,City of LompocCA$50http://www.cityoflompoc.com/splash/utilprograms.htmGlendale Water and PowerCA$40http://www.glendalewaterandpower.com/smart_home_saving_rebates.asp17A-6Utility or AgencyStateAmountWebsiteHercules Municipal UtilityCA$50http://www.dsireusa.org/library/includes/incentivesearch.cfm?Incentive_Code=CA133F&Search=TableType&type=Rebate&CurrentPageID=7&EE=1&RE=1IID EnergyCA$50http://www.dsireusa.org/library/includes/incentivesearch.cfm?Incentive_Code=CA97F&Search=TableType&type=Rebate&CurrentPageID=7&EE=1&RE=1Lassen MUDCA$35http://www.lmud.org/rebate.htmLodi Electric UtilityCA$25http://www.lodielectric.com/residential/rebateoffer.php?id=2City of Palo AltoCA$50http://www.cityofpaloalto.org/depts/utl/news/details.asp?NewsID=65&TargetID=12Plumas Sierra Rural ElectricCoopCA$35http://www.psln.com/energy_rebates.php?sec=enersol&pag=enerrebRedding Electric UtilityCA$25http://www.reupower.com/energysvc/energy-rebates.aspRiverside Public UtilitiesCA$50http://www.riversideca.gov/utilities/resi-energystar.aspSMUDCA$30http://www.smud.org/rebates/index.html$50Truckee Donner PUDCA$100http://www.tdpud.org/index.php?cId=34City of GridleyCA$25http://www.gridley.ca.us/documents/appliancerebateapp.pdfImperial Irrigation DistrictqCA$50http://www.iid.com/Media/PubRebApp-En_WEB07b.pdfHawaiian Electric CompanyHI$50http://www.heco.com/portal/site/heco/menuitem.508576f78baa14340b4c0610c510b1ca/?vgnextoid=a2670c0ed85b2110VgnVCM1000005c011bacRCRD&vgnextchannel=6558f2b154da9010VgnVCM10000053011bacRCRD&vgnextfmt=default&vgnextrefresh=1&level=0&ct=article#mainContent%20idKauai Island Utility CooperativeHI$50http://www.kiuc.coop/co-opportunities/index.htmBlachly Lane, EugeneOR$5http://www.northwestenergystar.com/index.php?cID=183&searchType=state&state=OR&type%5B%5D=Dishwashers&slSearch=searchCentral Electric, RedmondOR$25AshlandOR$30OR$60BandonOR$50Columbia River PUD, St. HelensOR$25Consumers Power, PhilomathOR$20Douglas EC, RoseburgOR$30Emerald, EugeneOR$25Eugene Water and ElectricOR$20Forest GroveOR$30Milton FreewaterOR$15MonmouthOR$15Salem ElectricOR$60TillamookOR$25Wasco, The DallesOR$25CheneyWA$21$24ChewelahWA$10017A-7Utility or AgencyStateAmountWebsiteMason County PUD #3, SheltonWA$25Mason County PUD #1, SheltonWA$60Modern Electric, SpokaneWA$22$24Snohomish County, EverettWA$35Okanogan CountyWA$50Coulee DamWA$60Wahkiakum PUD #1, CathlametWA$75DelcoID$15City of RupertID$15East End, RupertID$15Riverside Electric, RupertID$50Soda SpringsID$15Fall River, AshtonID$25Farmers, HeyburnID$15Idaho FallsID$15Northern Lights, SagleID$25Glacier, Cut BankMT$25Lincoln, EurekaMT$10Mission Valley , PabloMT$50Anoka Muni UtilityMN$50http://www.ci.anoka.mn.us/vertical/Sites/%7B213A9A90-C8E1-49AA-AC02­51D3C4882D33%7D/uploads/%7B93715A51-EA59-4213-BD5E-73A264F5E4F2%7D.PDFBuffalo Municipal UtilitiesNY$50http://www.ci.buffalo.mn.us/Utilities/Electric/EnergyRebate.htmBPA$25http://www.bpa.gov/Energy/N/projects/post2006conservation/manual/Number of Agencies88Average Rebate Amount$37Websites last accessed January, 2008.17A-8

# 17A.3 DEVELOPMENT OF CONSUMER TAX CREDITS IMPACT ANALYSIS

Clothes Washers

To analyze the Consumer Tax Credits policy for commercial clothes washers (CCWs), DOE studied the Oregon Department of Energy’s experience with Residential Energy Tax Credits (RETC) for residential clothes washers (RCWs). DOE chose RCWs because the product is similar to CCWs, and because the available data on Oregon's Business Energy Tax Credits (BETC)—which include CCWs—did not disaggregate tax credits claimed by appliance. Also, the ENERGY STAR program did not have data on CCW shipments.

Note that the RETC efficiency level for RCWs is minimum MEF of 2.0 and maximum water factor of 6.5. The proposed standard level for CCWs is minimum MEF of 2.2 and maximum water factor of 5.1, which is a stricter level. However, DOE assumed that by 2012 consumer behavior would be similar under a tax credit program aimed at high-efficiency CCW

units.

As stated in the RIA chapter, DOE calculated that Oregon taxpayers claimed credits for almost one quarter of Oregon’s total residential clothes washer shipments in 2006. DOE needed to estimate what portion of those taxpayers claiming credits were primarily motivated by the tax credits themselves, what portion were influenced by utility rebate incentives, and what portion were "free riders"—those who would have purchased efficient appliances without a tax credit or rebate incentive but still claimed the tax credit. To attribute the Oregon tax credits claimed to each of these influences, DOE reviewed a report prepared by KEMA on efficient RCWs in the Northwest. This report studied the penetration of residential clothes washers in Oregon and Washington, two neighboring states that have utility rebate programs for this product. 5 

# KEMA made a "highly conservative estimate" that 50 percent of Oregon's ENERGY STAR clothes washers were “ultra high efficiency” (UHE) a 

# units, based on tax credit data from Oregon Department of Energy (ODOE). In contrast, KEMA made a "highly conservative estimate" that 15 percent of Washington’s ENERGY STAR clothes washers were UHE models, based on rebate data from two utilities in the State. (KEMA also estimated that 19% of the State’s population was eligible for rebates.) KEMA’s report attributed the difference in UHE market share in the two States to the Oregon tax credits. Based on this attribution, DOE estimated that 38 percent of the tax credits claimed were actually due to rebates; these represent 9 percent of total shipments.

To estimate the free riders among the Oregon clothes washer shipments, DOE used the market penetration of the baseline CCW units on the penetration curve presented in Figure

17.3.6. This penetration was 9.2 percent of total shipments, which is 38 percent of the number of tax credit claims. DOE then estimated that the remaining 24 percent of the Oregon clothes

a 

# Units meeting specifications of minimum MEF of 2.20 an d maximum WF of 6.5 ( which are also the Oregon tax

credit specifications).


# 17A-9

# washer tax credits claimed for the years 1998–2005 were attributable to tax credits alone, or 5.8 percent of total shipments.

Dishwashers

For 2006 DOE calculated that Oregon taxpayers claimed credits for 14 percent of Oregon’s total dishwasher shipments. DOE did not find data comparing Oregon and Washington’s efficient dishwasher sales. To estimate the portions of these tax credit claims that were likely due to utility rebates and to market impacts, DOE reviewed a report by Itron on utility rebate programs in California. That report compared the percentage of free riders in residential clothes washer and dishwasher rebate programs in 2005. 6 

# Itron found that the penetration rate of ENERGY STAR dishwashers (85%) was much higher than that of ENERGY STAR clothes washers (40%). b 

# Itron also found that the percentage of free riders was greater for dishwasher programs than for clothes washer programs. DOE’s previous estimates showed that the incremental cost from the baseline was much smaller for high-efficiency dishwashers than for high-efficiency clothes washers, 7,8 

# which could explain the higher penetration rate for efficient dishwashers; an incentive program for a product whose market share is already high would tend to have more free riders. Based on these various factors, DOE estimated that market impacts (part of which are due to free riders) were responsible for a higher percentage of dishwasher tax credit claims than were market impacts for residential clothes washer tax credit

claims.

Itron’s report contained two estimates of free riders for ENERGY STAR dishwashers for 2005. DOE took the simple average of the supplier estimate of 93% in the self-reported consumer estimate of 59%, yielding 76%. DOE compared this to the simple average of free rider estimates for residential clothes washers, which were 77% from suppliers and 43% from consumers, yielding 60%. DOE assumed that the difference in free riders between the two products would be on the order of the difference between these two estimates (16%).

DOE interpreted the higher percentage of consumers purchasing dishwashers as free riders and then claiming tax credits, and the lower percentage of taxpayers influenced primarily by rebates, estimating that 49 percent of Oregon's 2006 dishwasher tax credits claimed (6.9 percent of total dishwasher shipments) were due to market impacts. It estimated that utility rebates were responsible for 32 percent of tax credits claimed (4.5 percent of total shipments). DOE attributed the remaining 20 percent of tax credits claimed (2.8 percent of total shipments)

to tax credits.

b 

# Values are from ENERGY STAR website based on D&R International data by state.


# 17A-10

# 17A.4	 EPACT 2005 FEDERAL TAX CREDIT LEVELS FOR RESIDENTIAL

APPLIANCES AND APPLIANCE MANUFACTURERS

17A.4.3 Residential Appliances

The residential appliance Federal tax credit qualification specifications are:

� 

# Furnaces and boilers: Annual Fuel Use Efficiency (AFUE) 95 or higher

� 

# Central air conditioning units: highest tier standards set by the Consortium for Energy Efficiency (CEE), which require a SEER of 15 and an EER of 12.5 for split systems and SEER 14 and EER 12 for single-package systems.

o 

# Air-source heat pumps must have a HSPF of 9 or greater, SEER 15 or higher, and EER 13 or higher.

o 

# Ground-source heat pumps must meet the following criteria (the same criteria as for ENERGY STAR):

� 

# Closed-loop systems—14.1 cooling EER and 3.3 COP

� 

# Open-loop systems—16.2 EER and 3.6 COP

� 

# Direct-expansion systems—15 EER and 3.5 COP. In addition, groundsource heat pumps must include a desuperheater (which preheats water for a water heater) or an integrated water heating system.

� 

# Fans for heating and cooling systems: fan uses no more than 2 percent of total heating system energy use, as defined by DOE test procedure.

� 

# Water heaters:

o 

# Gas or propane water heaters—Energy Factor of at least 0.8. The only models that meet this standard currently are tankless water heaters and some systems that combine both space and water heating.

o 

# Heat pump water heaters—Energy Factor of at least 2.0

17A.4.4 Energy Efficient Appliance Credits for Manufacturers

Each manufacturer is limited to a total of $75 million for all credits under this provision. Of that cap, no more than $20 million can be claimed for the lowest tier of qualifying refrigerators. The tax credit amounts and criteria for production of energy-efficient appliances

are as follows:

� Clothes washers: $100 for models that meet the 2007 ENERGY STAR © 

# criteria

� Refrigerators (three tiers):

o 

# $75 for models that save at least 15 percent relative to 2001 Federal standards (same as the current ENERGY STAR criteria); available only in 2006

o 

# $125 for models that save at least 20 percent relative to 2001 Federal standards

o 

# $175 for models that save 25 percent or more relative to 2001 Federal standards

� Dishwashers: $32.31 for models that meet the 2007 ENERGY STAR criteria

17A-11

# REFERENCES

1 

# Geroski, P.A., Models of Technology Diffusion. 2000. Research Policy. 29, 603-625.

2 

# Hall, B. H. and B. Khan. “Adoption of New Technology.” 2003. Working Paper No.E03­

330. Department of Economics, University of California, Berkeley, CA.

3 

# Lekvall, P. and C. Wahlbin. “A Study of Some Assumptions Underlying Innovation

Diffusion Functions.” 1973. Swedish Journal of Economics.

4 

# Van den Bulte, C. “Want to Know How Diffusion Speed Varies Across Countries and Products? Try a Bass Model.” PDMA Vision, October 2002. Product Development and Management Association. XXVI No 4.

5 

# KEMA. Consumer Product Market Progress Evaluation Report 3. 2007. Prepared for Northwest Energy Efficiency Alliance. Kema, Inc.: Portland, OR. Report #07-174.

6 

# Itron And KEMA. 2004/2005 Statewide Residential Retrofit Single-Family Energy Efficiency Rebate Evaluation. 2007. Prepared for The California Public Utilities Commission, Pacific Gas and Electric Company, San Diego Gas and Electric Company, Southern California Edison, and Southern California Gas Company. Itron, Inc. and KEMA, Inc.: Oakland, CA. CPUC-Id#: 1115-04.

7 

# U.S. Department of Energy. Technical Support Document: Energy Efficiency Standards for Consumer Products and Commercial and Industrial Equipment: Residential Dishwashers, Dehumidifiers, and Cooking Products, and Commercial Clothes Washers , November 2007. Washington, DC. Chapter 8.

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

8 

# U.S. Department of Energy. Final Rule Technical Support Document (TSD): Energy Efficiency Standards for Consumer Products: Clothes Washers , December 2000. Washington, DC. Chapter 7.

< http://www.eere.energy.gov/buildings/appliance_standards/residential/clwash_0900_r.html >



# 17A-12