American Councilfor an Energy-Efficient Economy

Appliance Standards Awareness Project

California Energy Commission

Consumer Federation of America

Natural Resources Defense Council

National Consumer Law Center

National Grid, USA

Northeast Energy Efficiency Partnerships

Northwest Power and Conservation Council

Pacific Gas & Electric Company

Vermont Energy Investment Corporation

June 1, 2004

Spencer Abraham

Secretary of Energy

U.S. Department of Energy

1000 Independence Avenue SW

Washington, DC 20585

Dear Secretary Abraham,

We are writing to formally petition DOE to conduct a rulemaking to amend existing

minimum efficiency standards for residential refrigerators, refrigerator-freezers, and

freezers. As you know, these products are regulated by DOE under the National

Appliance Energy Conservation Act (NAECA) of 1987. Initial standards on refrigerators,

which were established by Congress and signed by President Reagan, took effect in 1990.

DOE subsequently strengthened these standards by 25% effective 1993 and an additional

30% effective 2001 . Currently nearly 700 products are being produced and sold that

exceed the 2001 standard by 15%, including half a dozen products that exceed the 2001

standard by 30%.' We respectfully submit that the existence of these products, combined

with the other evidence presented in this petition, more than justifies the granting of this

petition and the commencement of another round of rulemaking for refrigerators to

amend existing standards. We ask you to begin this rulemaking in Fiscal Year 2005.

Petitioners include energy efficiency organizations, environmental organizations,

consumer organizations, states and electric utilities. The undersigned organizations have

a strong interest in the establishment of strong, cost-effective appliance standards under

NAECA, including new standards for residential refrigerators. Appliance energy

efficiency standards are the single most effective tool for reducing energy usage while

still providing consumers with reliable and affordable energy services . Increasing

appliance efficiency levels reduces electricity waste and electricity demand and reduces

air pollution and other environmental problems associated with electricity generation,

1 EPA and DOE, ENERGY STAR Qualified Refrigerators, last uploaded April 19, 2004. Available at

httl2://www.energystar.gov/index.cfm?c=refrig.pr refrigerators.

I

EE-PS-04-001 COMMENT 01.12

American Council for an Energy-Efficient Economy 

Appliance Standards Awareness Project 

California Energy Commission 

Consumer Federation of America 

Spencer Abraham 

Secretary of Energy 

Natural Resources Defense Council 

National Consumer Law Center 

National Grid, USA 

Northeast Energy Efficiency Partnerships 

Northwest Power and Conservation Council 

Pacific Gas & Electric Company 

Vermont Energy Investment Corporation 

June 1,2004 

U.S. Department of Energy 

1000 Independence Avenue SW 

Washington, DC 20585 

Dear Secretary Abraham, 

We are writing to formally petition DOE to conduct a rulemaking to amend existing 

minimum efficiency standards for residential refrigerators, refrigerator-freezers, and 

freezers. As you know, these products are regulated by DOE under the National 

Appliance Energy Conservation Act (NAECA) of 1987. Initial standards on refrigerators, 

which were established by Congress and signed by President Reagan, took effect in 1990. 

DOE subsequently strengthened these standards by 25% effective 1993 and an additional 

30% effective 2001. Currently nearly 700 products are being produced and sold that 

exceed the 2001 standard by 15%, including half a dozen products that exceed the 2001 

standard by 30%. I We respectfully submit that the existence of these products, combined 

with the other evidence presented in this petition, more than justifies the granting of this 

petition and the commencement of another round of rulemaking for refrigerators to 

amend existing standards. We ask you to begin this rulemaking in Fiscal Year 2005. 

Petitioners include energy efficiency organizations, environmental organizations, 

consumer organizations, states and electric utilities. The undersigned organizations have 

a strong interest in the establishment of strong, cost-effective appliance standards under 

NAECA, including new standards for residential refrigerators. Appliance energy 

efficiency standards are the single most effective tool for reducing energy usage while 

still providing consumers with reliable and affordable energy services. Increasing 

appliance efficiency levels reduces electricity waste and electricity demand and reduces 

air pollution and other environmental problems associated with electricity generation, 

1 EPA and DOE, ENERGY STAR Qualified Refrigerators, last uploaded April 19, 2004. Available at 

http://www.energystar.gov/index.cfm?c=refrig.pr refrigerators. 
while providing consumers with the same level of service from their appliances. As

President Bush's National Energy Policy states, appliance standards "stimulate energy

savings that benefit the consumer and reduce fossil fuel consumption, thus reducing air

emissions. ,2 Appliance energy efficiency standards also have important benefits for

consumers, including low-income consumers: by reducing electricity usage, standards

reduce consumer bills for those who purchase appliances and also help to reduce

electricity prices overall by reducing wholesale electricity prices, particularly at times of

peak demand. Appliance standards are an important tool for relieving stress on

overloaded electric grids and provide a means for electric utilities to provide least cost

service to their customers. Finally, appliance standards assist in ensuring energy security

by helping to reduce America's dependence on imported fossil fuels and by reducing

electric grid vulnerability.

Petitions for Amended Standards Under NAECA

Under NAECA, DOE is mandated to conduct two reviews of standards on each regulated

product. These two reviews have been completed for refrigerators. However, section

325(n) of NAECA [42 U.S.C. § 6295( n)] also provides that:

Petition for an Amended Standard.-(1) With respect to each covered product

described in paragraphs (1) through (11), and in paragraphs (13) and (14) of

section 322(a) [refrigerators are in paragraph (1)], any person may petition the

Secretary to conduct a rulemaking to determine for a covered product if the

standards contained either in the last final rule required under subsections (b)

through (i) of this section [refrigerators are covered under subsection (b)] or in a

final rule published under this section shall be amended.

(2) The Secretary shall grant a petition if he finds that it contains evidence

which, assuming no other evidence were considered, provides an adequate basis

for amending the standards under the following criteria-

(A) amended standards will result in significant conservation of energy;

(B) amended standards are technologically feasible; and

(C) amended standards are cost effective as described in subsection

(o)(2)(B)(i)(II). [This calls for comparing "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 covered products which are likely to

result from the imposition of the standard"].

The grant of a petition by the Secretary under this subsection creates no

presumption with respect to the Secretary's determination of any of the criteria in

a rulemaking under this section.

In this petition, we will show how the three key criteria for a petition are met, and

therefore that DOE has no choice but to grant the petition. Furthermore, DOE has just

begun a process to set priorities for standards rulemakings in Fiscal Year 2005, and

2 National Energy Policy Development Group, 2001, National Energy Policy. Pp. 4-5, Washington, DC:

U,S. Government Printing Office.

2

EE-PS-04-001 COMMENT 01.12

while providing consumers with the same level of service from their appliances. As 

President Bush's National Energy Policy states, appliance standards "stimulate energy 

savings that benefit the consumer and reduce fossil fuel consumption, thus reducing air 

emissions.,,2 Appliance energy efficiency standards also have important benefits for 

consumers, including low-income consumers: by reducing electricity usage, standards 

reduce consumer bills for those who purchase appliances and also help to reduce 

electricity prices overall by reducing wholesale electricity prices, particularly at times of 

peak demand. Appliance standards are an important tool for relieving stress on 

overloaded electric grids and provide a means for electric utilities to provide least cost 

service to their customers. Finally, appliance standards assist in ensuring energy security 

by helping to reduce America's dependence on imported fossil fuels and by reducing 

electric grid vulnerability. 

Petitions for Amended Standards Under NAECA 

Under NAECA, DOE is mandated to conduct two reviews of standards on each regulated 

product. These two reviews have been completed for refrigerators. However, section 

325(n) ofNAECA [42 U.S.C. § 6295(n)] also provides that: 

Petition for an Amended Standard.-(l) With respect to each covered product 

described in paragraphs (1) through (11), and in paragraphs (13) and (14) of 

section 322(a) [refrigerators are in paragraph (1)], any person may petition the 

Secretary to conduct a rulemaking to determine for a covered product if the 

standards contained either in the last final rule required under subsections (b) 

through (i) of this section [refrigerators are covered under subsection (b)] or in a 

final rule published under this section shall be amended. 

(2) The Secretary shall grant a petition ifhe finds that it contains evidence 

which, assuming no other evidence were considered, provides an adequate basis 

for amending the standards under the following criteria-

(A) amended standards will result in significant conservation of energy; 

(B) amended standards are technologically feasible; and 

(C) amended standards are cost effective as described in subsection 

(0 )(2)(B)(i)(II). [This calls for comparing "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 covered products which are likely to 

result from the imposition of the standard"]. 

The grant of a petition by the Secretary under this subsection creates no 

presumption with respect to the Secretary's determination of any of the criteria in 

a rulemaking under this section. 

In this petition, we will show how the three key criteria for a petition are met, and 

therefore that DOE has no choice but to grant the petition. Furthermore, DOE has just 

begun a process to set priorities for standards rulemakings in Fiscal Year 2005, and 

2 National Energy Policy Development Group, 2001, National Energy Policy. Pp. 4-5, Washington, DC: 

U,S. Government Printing Office. 

2 
therefore the timing is just right for adding a new rulemaking into the schedule. In

addition, although budgetary issues are irrelevant to the establishment of amended

standards under NAECA, we note that DOE should have funds for a new rulemaking as a

substantial amount of funds for the standards program are not being spent in Fiscal Year

2004 and are therefore available for Fiscal Year 2005. Congress is likely to provide

additional funds for the program in Fiscal Year 2005, including some funds beyond the

budget request.

In the following sections we discuss each of the three key petition criteria in relation to

residential refrigerators, refrigerator-freezers, and freezers.

Conservation of Energy

On April 27, 2004, DOE issued a set of analyses that it is using to help set rulemaking

priorities for the standards program.3 As part of this analysis DOE estimated the energy

savings from possible new efficiency standards including the current ENERGY STAR®

specification (energy consumption at least 15% less than the current mandatory standard)

and higher tiers developed by the Consortium for Energy Efficiency, a group of utilities,

states and non-profit organizations that plan and operate energy-saving programs. In this

analysis, DOE found that a new standard at the ENERGY STAR level would save an

average of 83 kWh per refrigerator, and that when multiplied by the more than 9 million

refrigerators sold annually, would save 2.89 quads of energy on a cumulative basis over

the 2010-2035 period.4 This level of savings is similar to the recent fluorescent ballast

final rule.5

As part of the same analysis, DOE also looked at CEE tier 3 and found that this level of

performance would save an average of 166 kWh per refrigerator, resulting in cumulative

savings of 5.78 quads of energy over the 2010-2035 period.6 This level of savings is

similar to DOE's recently completed clothes washer, water heater and central air

conditioner rules,7 and similar to the potential savings from the distribution transformer

and residential furnace/boiler rulemakings now underway.8

3 In particular, we refer to "Appendix A: FY2005 Technical Support Document" which can be found at

httt)://www.eere.energy.gov/buildings/aVpliance standards/2005 priority setting.htnl . [Relevant excerpts

are included as Attachment 1].

4 Ibid., p. 7-7.

5 In the Final Rule setting the new ballast standard, DOE states: "The Department concludes that an

electronic ballast standard saves a significant amount of energy. The energy savings reported in the

Department's analysis for an electronic ballast standard based on the Joint Comments ranged between 1.20

and 2.32 Quads of energy, not including the HVAC effects. The Department considers energy savings

within this range to be significant." Federal Register 65(182), Sept. 19, 2000, p. 56745.

6 Appendix A, p. 7-7. See note #3.

7 In the Final Rule setting the clothes washer standard, DOE states: "Next, we considered the two step

1.04/1.26 MEF efficiency level, which was proposed in the Joint Comment (Joint Comment, No. 204)

[This is the standard ultimately adopted]. This trial standard level, Trial Standard Level 3, has energy

savings of 5.52 quads through 2030, a significant amount." Federal Register 66(9), Jan. 12, 2001, p. 3327.

In the Final Rule setting the new water heater standard, DOE states: "Next, we considered trial standard

level three [This is the standard ultimately adopted]. This trial standard level saves about 4.6 quads of

energy, a significant amount." Federal Register 66(11), Jan. 17, 2001, p. 4493.

3

EE-PS-04-001 COMMENT 01.12

therefore the timing is just right for adding a new rulemaking into the schedule. In 

addition, although budgetary issues are irrelevant to the establishment of amended 

standards under NAECA, we note that DOE should have funds for a new rulemaking as a 

substantial amount of funds for the standards program are not being spent in Fiscal Year 

2004 and are therefore available for Fiscal Year 2005. Congress is likely to provide 

additional funds for the program in Fiscal Year 2005, including some funds beyond the 

budget request. 

In the following sections we discuss each of the three key petition criteria in relation to 

residential refrigerators, refrigerator-freezers, and freezers. 

Conservation of Energy 

On April 27, 2004, DOE issued a set of analyses that it is using to help set rulemaking 

priorities for the standards program.

3 As part of this analysis DOE estimated the energy 

savings from possible new efficiency standards including the current ENERGY STAR® 

specification (energy consumption at least 15% less than the current mandatory standard) 

and higher tiers developed by the Consortium for Energy Efficiency, a group of utilities, 

states and non-profit organizations that plan and operate energy-saving programs. In this 

analysis, DOE found that a new standard at the ENERGY STAR level would save an 

average of 83 kWh per refrigerator, and that when multiplied by the more than 9 million 

refrigerators sold annually, would save 2.89 quads of energy on a cumulative basis over 

the 2010-2035 period.4 This level of savings is similar to the recent fluorescent ballast 

final rule.5 

As part of the same analysis, DOE also looked at CEE tier 3 and found that this level of 

performance would save an average of 166 kWh per refrigerator, resulting in cumulative 

savings of 5.78 quads of energy over the 2010-2035 period.6 This level of savings is 

similar to DOE's recently completed clothes washer, water heater and central air 

conditioner rules/ and similar to the potential savings from the distribution transformer 

and residential furnacelboiler rulemakings now underway.8 

3 In particular, we refer to "Appendix A: FY2005 Technical Support Document" which can be found at 

http://www.eere.energy.gov/buildings/appliance standards/2005 priority setting.html. [Relevant excerpts 

are included as Attachment 1]. 

4 Ibid., p. 7-7. 

5 In the Final Rule setting the new ballast standard, DOE states: "The Department concludes that an 

electronic ballast standard saves a significant amount of energy. The energy savings reported in the 

Department's analysis for an electronic ballast standard based on the Joint Comments ranged between 1.20 

and 2.32 Quads of energy, not including the HV AC effects. The Department considers energy savings 

within this range to be significant." Federal Register 65(182), Sept. 19,2000, p. 56745. 

6 Appendix A, p. 7-7. See note #3. 

7 In the Final Rule setting the clothes washer standard, DOE states: "Next, we considered the two step 

1.0411.26 MEF efficiency level, which was proposed in the Joint Comment (Joint Comment, No. 204) 

[This is the standard ultimately adopted]. This trial standard level, Trial Standard Level 3, has energy 

savings of 5.52 quads through 2030, a significant amount." Federal Register 66(9), Jan. 12,2001, p. 3327. 

In the Final Rule setting the new water heater standard, DOE states: "Next, we considered trial standard 

level three [This is the standard ultimately adopted]. This trial standard level saves about 4.6 quads of 

energy, a significant amount." Federal Register 66(11), Jan. 17,2001, p. 4493. 

3 
In summary, with savings of this magnitude , it is clear that a new refrigerator standard

will "result in significant conservation," under NAECA Section 322(n)(2)(A), 42 U.S.C.

§ 6295(n)(2)(A). The savings levels that DOE itself has published are similar to the levels

it has found to be significant in prior DOE rulemakings.

Technical Feasibility

DOE's recent analysis also deals with the issue of technical feasibility of a new standard.

DOE notes that more than 50 products meet the CEE tier 1 levels (20% savings relative

to the DOE standard), 11 meet CEE tier 2 (25% savings relative to the DOE standard),

and 6 meet CEE tier 3 (30% savings).9 More recent data is available on the ENERGY

STAR web site. As of April 19, 2004 this site listed 687 refrigerators and refrigeratorfreezers meeting ENERGY STAR, 102 models meeting CEE tier 1, 17 meeting CEE tier 2,

and 9 meeting CEE tier 3.10 If this many existing products can meet these higher

efficiency levels, then clearly higher efficiency standards are "technically feasible" under

NAECA Section 322(n)(2)(B), 42 U.S.C. § 6295(n)(2)(B).

Cost-Effectiveness

Since energy savings and technical feasibility are clear cut, cost-effectiveness will be the

key issue in determining whether a new refrigerator efficiency rulemaking is warranted.

The petition must contain evidence "which, assuming no other evidence were considered,

provides an adequate basis for amending the standards," which requires a much lower

standard of evidence than that required for setting an actual new standard (42 U.S.C. §

6295(n)(2)(C)).

Again, DOE's April 2004 analysis provides the data that is needed to show that this

criteria can be met. Specifically, in this analysis DOE uses decade-old estimates it

developed of the incremental cost of more efficient refrigerators relative to a unit meeting

the current federal standard.11 In the case of the current ENERGY STAR levels, DOE

estimates an incremental cost of $60 per unit and finds that at this cost, the cumulative

net present value benefits (i.e. the "savings in operating costs throughout the estimated

average life of the covered product") at this standard level are $500 million more than the

costs.12 This finding alone should satisfy the legislated criteria for granting our petition

and beginning a rulemaking that will collect more recent cost data. There is no evidence

In the Final Rule setting the new central air conditioner and heat pump standard, DOE states: "Next, we

considered Trial Standard Level 4. This level specifies 13 SEER equipment for all product classes. In

considering Trial Standard Level 4 the Roll-up efficiency scenario and reverse engineering cost data are the

assumptions we consider to be the most probable... Primary energy savings would likely be 4.2 quads

which the Department considers significant." Federal Register 66(14), Jan. 22, 2001, p. 7197.

8 "Appendix B: FY2005 Draft Priority-Setting Data Sheets" which can be found at

http://www.eere.energy.gov/buildings/appliance standards/2005priority setting.html.

9 Appendix A, p. 7-3. See note #3.

10 EPA and DOE, ENERGY STAR Qualified Refrigerators, last uploaded April 19, 2004. See note #1.

" These estimates were published by DOE in 1995 but developed a few years earlier.

12 Appendix A, p. 7-7. See note #3.

4

EE-PS-04-001 COMMENT 01.12

In summary, with savings of this magnitude, it is clear that a new refrigerator standard 

will "result in significant conservation," under NAECA Section 322(n)(2)(A), 42 U.S.C. 

§ 6295(n)(2)(A). The savings levels that DOE itself has published are similar to the levels 

it has found to be significant in prior DOE rulemakings. 

Technical Feasibility 

DOE's recent analysis also deals with the issue of technical feasibility of a new standard. 

DOE notes that more than 50 products meet the CEE tier 1 levels (20% savings relative 

to the DOE standard), 11 meet CEE tier 2 (25% savings relative to the DOE standard), 

and 6 meet CEE tier 3 (30% savings).9 More recent data is available on the ENERGY 

STAR web site. As of April 19, 2004 this site listed 687 refrigerators and refrigeratorfreezers meeting ENERGY STAR, 102 models meeting CEE tier 1, 17 meeting CEE tier 2, 

and 9 meeting CEE tier 3.10 If this many existing products can meet these higher 

efficiency levels, then clearly higher efficiency standards are "technically feasible" under 

NAECA Section 322(n)(2)(B), 42 U.S.C. § 6295(n)(2)(B). 

Cost-Effectiveness 

Since energy savings and technical feasibility are clear cut, cost-effectiveness will be the 

key issue in determining whether a new refrigerator efficiency rulemaking is warranted. 

The petition must contain evidence "which, assuming no other evidence were considered, 

provides an adequate basis for amending the standards," which requires a much lower 

standard of evidence than that required for setting an actual new standard (42 U.S.C. § 

6295(n)(2)(C)). 

Again, DOE's April 2004 analysis provides the data that is needed to show that this 

criteria can be met. Specifically, in this analysis DOE uses decade-old estimates it 

developed of the incremental cost of more efficient refrigerators relative to a unit meeting 

the current federal standard.ll In the case of the current ENERGY STAR levels, DOE 

estimates an incremental cost of $60 per unit and finds that at this cost, the cumulative 

net present value benefits (i.e. the "savings in operating costs throughout the estimated 

average life of the covered product") at this standard level are $500 million more than the 

costS.12 This finding alone should satisfy the legislated criteria for granting our petition 

and beginning a rulemaking that will collect more recent cost data. There is no evidence 

In the Final Rule setting the new central air conditioner and heat pump standard, DOE states: ''Next, we 

considered Trial Standard Level 4. This level specifies 13 SEER equipment for all product classes. In 

considering Trial Standard Level 4 the Roll-up efficiency scenario and reverse engineering cost data are the 

assumptions we consider to be the most probable ... Primary energy savings would likely be 4.2 quads 

which the Department considers significant." Federal Register 66(14), Jan. 22, 2001, p. 7197. 

8 "Appendix B: FY2005 Draft Priority-Setting Data Sheets" which can be found at 

http://www.eere.energy.gov/buildings/appliance standards/2005 priority setting.html. 

9 Appendix A, p. 7-3. See note #3. 

10 EPA and DOE, ENERGY STAR Qualified Refrigerators, last uploaded April 19, 2004. See note #1. 

11 These estimates were published by DOE in 1995 but developed a few years earlier. 

12 Appendix A, p. 7-7. See note #3. 

4 
that we are aware of that ENERGY STAR level refrigerators have any maintenance costs in

excess of those of non-ENERGY STAR models. Therefore, maintenance costs do not affect

the result of this cost-effectiveness analysis.

However, it is worth noting that more recent data indicates that the old DOE cost

estimates overestimate costs by at least about a factor of two, and perhaps by a factor of

nine. Specifically, a recent review by the American Council for an Energy-Efficient

Economy of the Sears website found that ENERGY STAR refrigerators cost an average of

about $36 more than otherwise comparable units that are not ENERGY STAR.13 Thus,

current incremental costs appear to be nearly half of what DOE estimated in the 1990s.

At an incremental cost of $36, an ENERGY STAR refrigerator saving 83 kWh/year will

have a simple payback to the consumer of about 5 years at current national average

electricity prices. If we revise DOE's net present value analysis to change the

incremental cost to $36 but leave all other assumptions the same, then the net benefits of

this standard increase to $3.2 billion.14

Furthermore, current costs for ENERGY STAR are for a niche product and not for

widespread production. In particular, as shown in Attachment 2, manufacturers are

currently charging a large cost premium for ENERGY STAR side-by-side units since these

are high-end units for which manufacturers can charge very profitable prices. Past

experience shows that when new standards are set, costs are generally much less than

what manufacturers and DOE estimate during the standard-setting process. For example,

the U.S. Census Bureau, as part of its annual Census of Manufacturers, collects data on

the number of refrigerators shipped and the value of the shipments. Taking value of

shipments and dividing by the number shipped gives average value per unit, including

manufacturer costs, markups and profit. In preparation for the 2001 standard,

manufacturers made a variety of product changes, primarily in 2000 and 2001. Therefore,

the incremental cost at the manufacturer level of the new standards can be estimated by

comparing value per unit for 1999 (which was $424.96) and 2002 ($427.94). The

difference is only $2.98.15 If we multiply this by DOE's estimate of the markup factor

between manufacturer costs and consumer cost (2.07),16 then the real world incremental

cost is approximately $6, which is only 12% of the $50 average consumer incremental

cost estimated by DOE in the rulemaking.17

13 Details are provided in Attachment 2.

14 Net benefit calculations were done with DOE's "refrig_std_nes_20040409" spreadsheet available at

http://www.eere.energyy.gov/buildings/gppliance standards/2005 priority setting.html . Only incremental

costs were changed.

15 Details of this data analysis are provided in Attachment 3.

16 We derive this markup factor by comparing the retail price of a top mount auto defrost refrigeratorfreezer at the selected standard level from Table 4.1 on p. 4-3 with the manufacturer cost of this same

model from Table 3.5 on p. 3-2. DOE, 1995, Technical Support Document: Energy Efficiency Standards

for Consumer Products: Refrigerators, Refrigerator-Freezers, and Freezers, DOE/EE-0064. Washington,

DC: DOE.

17 Ibid., Table 5.3.4, p. 5-12.

5

EE-PS-04-001 COMMENT 01.12

that we are aware of that ENERGY STAR level refrigerators have any maintenance costs in 

excess of those of nOn-ENERGY STAR models. Therefore, maintenance costs do not affect 

the result of this cost-effectiveness analysis. 

However, it is worth noting that more recent data indicates that the old DOE cost 

estimates overestimate costs by at least about a factor of two, and perhaps by a factor of 

nine. Specifically, a recent review by the American Council for an Energy-Efficient 

Economy of the Sears website found that ENERGY STAR refrigerators cost an average of 

about $36 more than otherwise comparable units that are not ENERGY STAR. 13 Thus, 

current incremental costs appear to be nearly half of what DOE estimated in the 1990s. 

At an incremental cost of $36, an ENERGY STAR refrigerator saving 83 kWh/year will 

have a simple payback to the consumer of about 5 years at current national average 

electricity prices. Ifwe revise DOE's net present value analysis to change the 

incremental cost to $36 but leave all other assumptions the same, then the net benefits of 

this standard increase to $3.2 billion.J4 

Furthermore, current costs for ENERGY STAR are for a niche product and not for 

widespread production. In particular, as shown in Attachment 2, manufacturers are 

currently charging a large cost premium for ENERGY STAR side-by-side units since these 

are high-end units for which manufacturers can charge very profitable prices. Past 

experience shows that when new standards are set, costs are generally much less than 

what manufacturers and DOE estimate during the standard-setting process. For example, 

the U.S. Census Bureau, as part of its annual Census of Manufacturers, collects data on 

the number of refrigerators shipped and the value of the shipments. Taking value of 

shipments and dividing by the number shipped gives average value per unit, including 

manufacturer costs, markups and profit. In preparation for the 2001 standard, 

manufacturers made a variety of product changes, primarily in 2000 and 2001. Therefore, 

the incremental cost at the manufacturer level of the new standards can be estimated by 

comparing value per unit for 1999 (which was $424.96) and 2002 ($427.94). The 

difference is only $2.98. 15 Ifwe multiply this by DOE's estimate of the markup factor 

between manufacturer costs and consumer cost (2.07),16 then the real world incremental 

cost is approximately $6, which is only 12% of the $50 average consumer incremental 

cost estimated by DOE in the rulemaking. 17 

13 Details are provided in Attachment 2. 

14 Net benefit calculations were done with DOE's "refrig_std_nes_20040409" spreadsheet available at 

http://www.eere.energy.govlbuildings/appliance standards12005 priority setting.html. Only incremental 

costs were changed. 

15 Details of this data analysis are provided in Attachment 3. 

16 We derive this markup factor by comparing the retl;il price of a top mount auto defrost refrigeratorfreezer at the selected standard level from Table 4.l on p. 4-3 with the manufacturer cost of this same 

model from Table 3.5 on p. 3-2. DOE, 1995, Technical Support Document: Energy Efficiency Standards 

for Consumer Products: Refrigerators, Refrigerator-Freezers, and Freezers, DOEIEE-0064. Washington, 

DC: DOE. 

17 Ibid., Table 5.3.4, p. 5-12. 

5 
If we apply this 12% factor to DOE's 1990s estimate of a $60 incremental cost for the

current ENERGY STAR level, then we get an incremental cost of only $7, a simple payback

of one year, and the net benefits of such a standard increase to $5.6 billion.18

We can apply the same logic to DOE's 1990's estimate of the incremental cost of a unit

using 30% less energy than the current standard (e.g., CEE tier 3). In the 1990s DOE

estimated a $235 incremental cost, but if DOE overestimated this cost increase to the

same degree it overestimated the incremental cost of a unit just meeting the new standard,

then the incremental cost is only $28 ($235 * 12%), the simple payback about two years,

and the net benefits of the standard $10.1 billion.19

In summary, even with DOE's very dated and conservative assumptions, the costeffectiveness test is met by a standard 15% below the present one (i.e., the current

ENERGY STAR). But if newer data are used, such as current incremental costs for ENERGY

STAR or adjusting the earlier DOE estimates in light of actual experience implementing

the 2001 standard, then new refrigerator standards are even more cost-effective (e.g.

probably more cost-effective than almost any other standard DOE has set). In short, we

have pointed to more than enough evidence to provide an "adequate basis" for

determining that amended standards are cost effective, sufficient to require the granting

of this petition (42 U.S.C. § 6295(n)(2)(C)).

Conclusion

DOE's own analysis indicates that a new refrigerator standard will save a significant

amount of energy, is technologically feasible, and is cost-effective. Thus, using DOE's

own analysis, the three criteria under NAECA for granting a petition for amended

standards are met. Furthermore, more recent cost data indicate that a new refrigerator

standard could well be one of the most successful standards, with very large economic

benefits and energy savings. Given these findings, we respectfully request that this

petition be granted and that you begin a new rulemaking for refrigerators and related

products in Fiscal Year 2005.

Sincerely,

Steven M. Nadel

Executive Director

American Council for an Energy-Efficient Economy

1001 Connecticut Ave. NW, Suite 801

Washington, DC 20036

18 See note #14.

19 See note #14.

6

EE-PS-04-001 COMMENT 01.12

Ifwe apply this 12% factor to DOE's 1990s estimate of a $60 incremental cost for the 

current ENERGY STAR level, then we get an incremental cost of only $7, a simple payback 

of one year, and the net benefits of such a standard increase to $5.6 billion. I 8 

We can apply the same logic to DOE's 1990's estimate of the incremental cost of a unit 

using 30% less energy than the current standard (e.g., CEE tier 3). In the 1990s DOE 

estimated a $235 incremental cost, but if DOE overestimated this cost increase to the 

same degree it overestimated the incremental cost of a unit just meeting the new standard, 

then the incremental cost is only $28 ($235 * 12%), the simple payback about two years, 

and the net benefits of the standard $10.1 billion. 19 

In summary, even with DOE's very dated and conservative assumptions, the costeffectiveness test is met by a standard 15% below the present one (i.e., the current 

ENERGY STAR). But if newer data are used, such as current incremental costs for ENERGY 

STAR or adjusting the earlier DOE estimates in light of actual experience implementing 

the 2001 standard, then new refrigerator standards are even more cost-effective (e.g. 

probably more cost-effective than almost any other standard DOE has set). In short, we 

have pointed to more than enough evidence to provide an "adequate basis" for 

determining that amended standards are cost effective, sufficient to require the granting 

of this petition (42 U.S.C. § 6295(n)(2)(C)). 

Conclusion 

DOE's own analysis indicates that a new refrigerator standard will save a significant 

amount of energy, is technologically feasible, and is cost-effective. Thus, using DOE's 

own analysis, the three criteria under NAECA for granting a petition for amended 

standards are met. Furthermore, more recent cost data indicate that a new refrigerator 

standard could well be one of the most successful standards, with very large economic 

benefits and energy savings. Given these findings, we respectfully request that this 

petition be granted and that you begin a new rulemaking for refrigerators and related 

products in Fiscal Year 2005. 

Sincerely, 

Steven M. Nadel 

Executive Director 

American Council for an Energy-Efficient Economy 

1001 Connecticut Ave. NW, Suite 801 

Washington, DC 20036 

18 See note #14. 

19 See note #14. 

6 
^&,_,2 //,,^-

Andrew L. deLaski

Executive Director

Appliance Standards Awareness Project

20 Belgrade Ave., Suite 1

Boston, MA 02131

William J. Keese

Chairman

California Energy Commission

1516 Ninth St.

Sacramento, CA 95814

Mel Hall-Crawford

Energy Projects Manager

Consumer Federation of America

1424 16 St., Suite 604

Washington, DC 20036

1f

__4 --

David B. Goldstein

Senior Scientist

Katherine Kennedy

Senior Attorney

Natural Resources Defense Council

71 Stevenson St., Suite 825

San Francisco, CA 94105

7

EE-PS-04-001 COMMENT 01.12

Andrew L. deLaski 

Executive Director 

Appliance Standards Awareness Project 

20 Belgrade Ave., Suite 1 

Boston, MA 02131 

William J. Keese 

Chairman 

California Energy Commission 

1516 Ninth St. 

Sacramento, CA 95814 

Mel Hall-Crawford 

Energy Projects Manager 

Consumer Federation of America 

1424 16 St., Suite 604 

Washington, DC 20036 

#:- ff~- David B. Goldstein 

Senior Scientist 

Katherine Kennedy 

Senior Attorney 

Natural Resources Defense Council 

71 Stevenson St., Suite 825 

San Francisco, CA 94105 

7 
Charles Harak, Esq.

National Consumer Law Center

(On behalf of its low-income clients)

77 Summer Street, 10th floor

Boston, MA 02110

617 542-8010 (ph)

61.7 542-8028 (fax)

charak@nclc.org

Timothy M. Stout

Vice President - Energy Efficiency

National Grid, USA

55 Bearfoot Rd.

Northborough, MA 01532

Susan E. Coakley

Executive Director

Northeast Energy Efficiency Partnerships

5 Militia Dr.

Lexington, MA 02421

Stephen L. Crow

Executive Director

Northwest Power and Conservation Council

851 S.W. Sixth Ave., Suite 1100

Portland, OR 97204

Roland J. Risser

Director, Customer Energy Efficiency

Pacific Gas and Electric Company

P.O. Box 770000

San Francisco, CA 94177

8

EE-PS-04-001 COMMENT 01.12

r.\ ... l.l~nnl\; I\, \1\j)' '1......- ".N 'lv\jy\W~' i1J.!fi 

Charles Harak, Esq. 

National Consumer Law Center 

(On behalf of its low-income clients) 

77 Summer Street, 10th floor 

Boston, MA 02110 

617542-8010 (ph) 

61.7542-8028 (fax) 

charak@nclc.org 

~1Yl.~ 

Timothy M. Stout 

Vice President - Energy Efficiency 

National Grid, USA 

55 Bearfoot Rd. 

Northborough, MA 01532 

Susan E. Coakley 

Executive Director 

Northeast Energy Efficiency Partnerships 

5 Militia Dr. 

Lexington, MA 02421 

Stephen L. Crow 

Executive Director 

Northwest Power and Conservation Council 

851 S.W. Sixth Ave., Suite 1100 

Portland, OR 97204 

Roland J. Risser 

Director, Customer Energy Efficiency 

Pacific Gas and Electric Company 

P.O. Box 770000 

San Francisco, CA 94177 

8 
Beth Sachs

Executive Director

Vermont Energy Investment Corporation

255 S.Champlain St.

Burlington, VT 05401

9

EE-PS-04-001 COMMENT 01.12

Beth Sachs 

Executive Director 

Vennont Energy Investment Corporation 

255 S.Champlain St. 

Burlington, VT 05401 

9 
Attachment 1.

Refrigerator Section from DOE FY2005 Technical Support Document

(full document available at:

http://www.eere.energy.gov/buildings/appliance standards/2005 priority setting html )

10

EE-PS-04-001 COMMENT 01.12

Attachment 1. 

Refrigerator Section from DOE FY2005 Technical Support Document 

(full document available at: 

http://www.eere.energy.gov/buildings/appliance standards/2005 priority setting.html) 

10 
A7 Refrigerators and Refrigerator-Freezers, Freezers, and Compact Refrigerators

A7.1 Background

Refrigerators, refrigerator-freezers, and freezers are major household appliances designed for the

refrigerated storage of food products. A refrigerator consists of a refrigerated cabinet designed

for the refrigerated storage of food at temperatures above 0°C (32°F) and below 3.9°C (39°F),

configured for general refrigerated food storage, and having a source of refrigeration requiring

single phase, alternating current electric energy input only. A refrigerator may include a

compartment for the storage of food at temperatures below 0°C (32°F), but does not provide a

separate low temperature compartment designed for freezing and storage of food at temperatures

below -13.3°C (8°F). A refrigerator-freezer is a cabinet which consists of at least one

compartment designed for the refrigerated storage of food at temperatures above 0°C (32°F) and

at least one other compartment designed for the freezing and storage of food at temperatures

below -13.3°C (8°F). A freezer consists of a cabinet for the storage and freezing of foods at -

17.8°C (0°F) or below. Compact refrigerators are defined by the DOE as having less than a 7.75

cubic foot capacity and 36 inches or less in height.

In 1987, the National Appliance Energy Conservation Act (NAECA) was signed into law

establishing minimum energy efficiency standards for refrigerators, refrigerator-freezers, and

freezers. For twelve product classes, NAECA specified the maximum allowable energy in

kilowatt-hours per year for products manufactured on or after January 1, 1990 (NAECA 1987).

Subsequent to the NAECA requirements, a new set of minimum efficiency standards became

effective first in 1993 then again in 2001 (DOE 1997). The new minimum efficiency standards

in 1993 eliminated 99 percent of the models and increased efficiency by 25 to 30 percent relative

to the NAECA requirements. The minimum efficiency standards that became effective on July

1, 2001 increase the efficiency of the most popular product class, top mount refrigerator-freezers

with auto-defrost, by approximately 30 percent relative to the 1993 standards.

Table A7-1 provides background data on the installed base, annual shipments, lifetime, and

national annual energy consumption for refrigerator-freezers and freezers. The background data

are divided into three categories: standard size refrigerators and refrigerator-freezers, freezers,

and compact refrigerators.

7-1

EE-PS-04-001 COMMENT 01.12

A7 Refrigerators and Refrigerator-Freezers, Freezers, and Compact Refrigerators 

A7.1 Background 

Refrigerators, refrigerator-freezers, and freezers are major household appliances designed for the 

refrigerated storage of food products. A refrigerator consists of a refrigerated cabinet designed 

for the refrigerated storage offood at temperatures above O°C (32°F) and below 3.9°C (39°F), 

configured for general refrigerated food storage, and having a source of refrigeration requiring 

single phase, alternating current electric energy input only. A refrigerator may include a 

compartment for the storage of food at temperatures below O°C (32°F), but does not provide a 

separate low temperature compartment designed for freezing and storage of food at temperatures 

below -13.3°C (8°F). A refrigerator-freezer is a cabinet which consists of at least one 

compartment designed for the refrigerated storage of food at temperatures above O°C (32°F) and 

at least one other compartment designed for the freezing·and storage of food at temperatures 

below -13.3°C (8°F). A freezer consists of a cabinet for the storage and freezing offoods at -

17.8°C (O°F) or below. Compact refrigerators are defined by the DOE as having less than a 7.75 

cubic foot capacity and 36 inches or less in height. 

In 1987, the National Appliance Energy Conservation Act (NAECA) was signed into law 

establishing minimum energy efficiency standards for refrigerators, refrigerator-freezers, and 

freezers. For twelve product classes, NAECA specified the maximum allowable energy in 

kilowatt-hours per year for products manufactured on or after January 1, 1990 (NAECA 1987). 

Subsequent to the NAECA requirements, a new set of minimum efficiency standards became 

effective first in 1993 then again in 2001 (DOE 1997). The new minimum efficiency standards 

in 1993 eliminated 99 percent of the models and increased efficiency by 25 to 30 percent relative 

to the NAECA requirements. The minimum efficiency standards that became effective on July 

1,2001 increase the efficiency of the most popular product class, top mount refrigerator-freezers 

with auto-defrost, by approximately 30 percent relative to the 1993 standards. 

Table A7-1 provides background data on the installed base, annual shipments, lifetime, and 

national annual energy consumption for refrigerator-freezers and freezers. The background data 

are divided into three categories: standard size refrigerators and refrigerator-freezers, freezers, 

and compact refrigerators. 

7-1 
Table A7-1: Standard Refrigerator, Freezer, and Compact Refrigerator Background Data

Type Data type Value' Source/Comments

Installed Base millions 142 Based on historical shipments and

,

equipment lifetime of 19 years

Refrigerator &

ri

Annual Shipments, millions 9.74 (Appliance 2004)

Ref geratorFreezers Equipment Lifetime, years 19 (DOE 1995)

AEC, quad 0.86 Based on installed base and stock

annual energy use

Installed Base millions 29 Based on historical shipments and,

equipment lifetime of 19 years

Annual Shipments, millions 1.49 (Appliance 2004)

Freezers

Equipment Lifetime, years 19 (DOE 1995)

AEC, quad 0.14 Based on installed base and stock

annual energy use

Installed Base millions 12 Based on historical shipments and

,

equipment lifetime of 19 years

Compact Annual Shipments, millions 1.40 (Appliance 2004)

Refrigertors Equipment Lifetime, years I 1 (DOE 1995)

AEC quad 0.04 Based on installed base and stock,

annual energy use

Installed base, annual shipment, and AEC values are for the year 2002.

A7.2 Product Technology Description and Market Presence

Technology for improving refrigerator and freezer performance include: using more efficient

compressors, reducing the power consumption of fans, using smart defrost technology to

minimize the amount of defrost that is needed and adding insulation.

The saturation of refrigerators/refrigerator-freezers was 96 percent in 2001, based on the number

of households with at least one refrigerator (AHAM 2003). The sales of compact refrigerators

have increased appreciably in the last several years. While most seem to be sold to residential

consumers, significant amounts are also prevalent in non-residential applications such as hotels,

dormitories and offices.

The Federal Energy Management Program (FEMP), ENERGY STAR®, and the Consortium for

Energy Efficiency (CEE) specify voluntary efficiency requirements for refrigerators,

refrigerator-freezers, and freezers (FEMP 2004; ENERGY STAR® 2004; CEE 2004). FEMP

provides efficiency targets only for standard size refrigerator-freezers. For example, for topmount refrigerator-freezers with auto-defrost, the specified annual energy use reduction target is

four percent lower than the current minimum standard. FEMP is in the process of revising its

purchasing recommendations for refrigerators, in order to be in alignment with ENERGY

STAR® specifications. The difference between FEMP and ENERGY STAR® will be that while

7-2

EE-PS-04-001 COMMENT 01.12

Table A7-1: Standard Refrigerator, Freezer, and Compact Refrigerator Background Data 

Refrigerator & 

RefrigeratorFreezers 

Freezers 

Compact 

Refrigertors 

AEC,quad 

Installed Base, millions 

Annual 

AEC,quad 

0.14 

12 

0.04 

Based on installed base and stock 

annual energy use 

Based on historical shipments and 

equipment lifetime of 19 years 

Based on installed base and stock 

annual use 

Installed base, annual shipment, and AEC values are for the year 2002. 

A7.2 Product Technology Description and Market Presence 

Technology for improving refrigerator and freezer performance include: using more efficient 

compressors, reducing the power consumption of fans, using smart defrost technology to 

minimize the amount of defrost that is needed and adding insulation. 

The saturation ofrefrigeratorslrefrigerator-freezers was 96 percent in 2001, based on the number 

of households with at least one refrigerator (AHAM 2003). The sales of compact refrigerators 

have increased appreciably in the last several years. While most seem to be sold to residential 

consumers, significant amounts are also prevalent in non-residential applications such as hotels, 

dormitories and offices. 

The Federal Energy Management Program (FEMP), ENERGY ST AR®, and the Consortium for 

Energy Efficiency (CEE) specify voluntary efficiency requirements for refrigerators, 

refrigerator-freezers, and freezers (FEMP 2004; ENERGY STAR® 2004; CEE 2004). FEMP 

provides efficiency targets only for standard size refrigerator-freezers. For example, for topmount refrigerator-freezers with auto-defrost, the specified annual energy use reduction target is 

four percent lower than the current minimum standard. FEMP is in the process of revising its 

purchasing recommendations for refrigerators, in order to be in alignment with ENERGY 

ST AR® specifications. The difference between FEMP and ENERGY ST AR® will be that while 

7-2 
ENERGY STAR® specifies an efficiency curve, FEMP divides recommendations into bins

based on capacity and reports their recommendations in kWh/year rather than as a percentage

increase in efficiency.

ENERGY STAR® specifies annual energy use reduction targets of 15, 10, and 20 percent for

standard size refrigerator-freezers, freezers, and compact refrigerators respectively. CEE targets

only standard-size refrigerator-freezers. CEE specifies three tier levels specifying annual energy

use reduction targets of 20, 25, and 30 percent relative to current minimum efficiency standards.

The market presence of higher efficiency refrigerators and freezers can be gauged somewhat by

the number refrigerators meeting the ENERGY STAR® specifications and CEE tier levels. The

AHAM 2003 Fact Book reports that 25 percent of sales of refrigerator products over 6.5 cu. ft. in

capacity meet ENERGY STAR® levels (AHAM 2003). On January 1, 2004, the ENERGY

STAR® criteria changed for all full size refrigerators (above 7.75 cu. ft in capacity). For topmount refrigerator-freezers with volumes between 16.5 to 18.4 cu. ft., 33 models currently meet

the ENERGY STAR® criteria. For chest freezers, twelve models currently meet the ENERGY

STAR® criteria; however, none were in the 22.5 to 24.4 cu. ft. range. For single-door

refrigerators, 23 models currently meet the ENERGY STAR® criteria (ENERGY STAR®

2004). All single-door refrigerator models meeting ENERGY STAR® have volumes less than

7.75 cu.ft., qualifying them as compact refrigerators. According to information compiled by

ENERGY STAR®, several refrigerator-freezer models meet the CEE tier levels. Over 50

refrigerator-freezer models he between the first two CEE tier levels (i.e., energy use of 20 to 25

percent lower than existing minimum standards), five models lie between the second and third

CEE tier levels (i.e., energy use of 25 to 30 percent lower than existing minimum standards), and

six models have lower energy consumption than the third CEE tier level (ENERGY STAR®

2004).

Tables A7-2 through A7-4 provide the UEC values corresponding to various efficiency levels of

standard-size refrigerator-freezers, freezers, and compact refrigerators.

7-3

EE-PS-04-001 COMMENT 01.12

ENERGY ST AR® specifies an efficiency curve, FEMP divides recommendations into bins 

based on capacity and reports their recommendations in kWh/year rather than as a percentage 

increase in efficiency. 

ENERGY STAR® specifies annual energy use reduction targets of 15, 10, and 20 percent for 

standard size refrigerator-freezers, freezers, and compact refrigerators respectively. CEE targets 

only standard-size refrigerator-freezers. CEE specifies three tier levels specifying annual energy 

use reduction targets of20, 25, and 30 percent relative to current minimum efficiency standards. 

The market presence of higher efficiency refrigerators and freezers can be gauged somewhat by 

the number refrigerators meeting the ENERGY ST AR® specifications and CEE tier levels. The 

AHAM 2003 Fact Book reports that 25 percent of sales of refrigerator products over 6.5 cu. ft. in 

capacity meet ENERGY STAR® levels (AHAM 2003). On January 1,2004, the ENERGY 

STAR® criteria changed for all full size refrigerators (above 7.75 cu. ft in capacity). For topmount refrigerator-freezers with volumes between 16.5 to 18.4 cu. ft., 33 models currently meet 

the ENERGY STAR® criteria. For chest freezers, twelve models currently meet the ENERGY 

ST AR® criteria; however, none were in the 22.5 to 24.4 cu. ft. range. For single-door 

refrigerators, 23 models currently meet the ENERGY STAR® criteria (ENERGY STAR® 

2004). All single-door refrigerator models meeting ENERGY ST AR® have volumes less than 

7.75 cu.ft., qualifYing them as compact refrigerators. According to infonnation compiled by 

ENERGY STAR®, several refrigerator-freezer models meet the CEE tier levels. Over 50 

refrigerator-freezer models lie between the first two CEE tier levels (i.e., energy use of20 to 25 

percent lower than existing minimum standards), five models lie between the second and third 

CEE tier levels (i.e., energy use of 25 to 30 percent lower than existing minimum standards), and 

six models have lower energy consumption than the third CEE tier level (ENERGY ST AR® 

2004). 

Tables A7-2 through A7-4 provide the UEC values corresponding to various efficiency levels of 

standard-size refrigerator-freezers, freezers, and compact refrigerators. 

7-3 
Table A7-2: Standard-Size Refrigerator-Freezer Technology Levels and UEC Values

Technology Level

UEC'

( hli'h/ enr) Source

Typical New 552 (AHAM 2003)

Minimum Efficiency Standard 484' (DOE 1997)

FEMP3 (4% decrease) 530 (FEMP 2004)

ENERGY STAR® ( 15% decrease) 469 (ENERGY STAR® 2004)

CEE Tier 1 (20% decrease) 442 (CEE 2004)

CEE Tier 2 (25% decrease) 414 (CEE 2004)

CEE Tier 3 (30% decrease) 338 (CEE 2004)

1 UEC values are a shipment-weighted average of all standard-size refrigerator-freezers.

2 Minimum standard for top- mount refrigerator-freezer with auto defrost, 21.4 cu. ft. adjusted volume.

3 FEMP is in the process of revising its purchasing recommendations for refrigerators , in order to be in alignment

with ENERGY STAR® specifications. The difference between FEMP and ENERGY STAR® will be that while

ENERGY STAR® specifies an efficiency curve, FEMP divides recommendations into bins based on capacity and

reports their recommendations in kWh/year rather than as a percentage increase in efficiency.

Table A7-3: Freezer Technology Levels and UEC Values

.[`l.Cih s,-'1ia z^sll3'^slt } 14911 i'.I.Rir

UEC values are a shipment-weighted average of all freezers .

Table A7-4: Compact Refrigerator Technology Levels and UEC Values

E cciuu^in^r 1. eil i. f,l^'liiti^^:ar} t uriht^auili.^ nine .

CC

UEC values are a shipment-weighted average of all compact refrigerators.

Tables A7-5 through A7-7 provide retail price information corresponding to the efficiency levels

specified in Tables A7-2 through A7-4. Retail price data for typical new standard-size

refrigerator-freezers and freezers are provided by AHAM in their 2003 Fact Book (AHAM

2003). A representative retail price for a typical new compact refrigerator was obtained from a

retailer website (WalMart 2004). Retail prices are generated for high efficiency levels from the

percentage price increases indicated by the price versus efficiency relationships in DOE's 1995

refrigerator Technical Support Document (TSD) (DOE 1995).

7-4

EE-PS-04-001 COMMENT 01.12

Table A 7-2: Standard-Size Refrigerator-Freezer Technology Levels and VEC Values 

VEe values are a shipment-weighted avemge of all standard-size refrigemtor-freezers. 

2 Minimum standard for top- mount refrigemtor-freezer with auto defrost, 21.4 cu. ft. adjusted volume. 

3 FEMP is in the process of revising its purchasing recommendations for refrigemtors, in order to be in alignment 

with ENERGY ST AR® specifications. The difference between FEMP and ENERGY ST AR® will be that while 

ENERGY ST AR® specifies an efficiency curve, FEMP divides recommendations into bins based on capacity and 

reports their recommendations in kWh/year mther than as a percentage increase in efficiency. 

Table A7-3: Freezer Technology Levels and VEC Values 

Table A7-4: Compact Refrigerator Technology Levels and VEC Values 

(ENERGY STAR'H) 20(}4} 

UEC values are a shipment-weighted avemge of all compact refrigerators. 

Tables A7-5 through A7-7 provide retail price infonnation corresponding to the efficiency levels 

specified in Tables A7-2 through A7-4. Retail price data for typical new standard-size 

refrigerator-freezers and freezers are provided by AHAM in their 2003 Fact Book (AHAM 

2003). A representative retail price for a typical new compact refrigerator was obtained from a 

retailer website (WalMart 2004). Retail prices are generated for high efficiency levels from the 

percentage price increases indicated by the price versus efficiency relationships in DOE's 1995 

refrigerator Technical Support Document (TSD) (DOE 1995). 

7-4 
Table A7-5: Standard-Size Refrigerator-Freezer Retail Prices

Technolo gy Level

UEC

( kWh/year)

Retail Price

($ 2002) Source

Typical New 552 $788 (AHAM 2003)

FEMP (4% decrease) 530 $796 (DOE 1995)'

ENERGY STAR® ( 15%

decrease)

469 $856 (DOE 1995)'

CEE Tier 1 (20% decrease) 442 $903 (DOE 1995)'

CEE Tier 2 (25% decrease) 414 $961 (DOE 1995)'

CEE Tier 3 (30% decrease) 338 $1031 (DOE 1995)'

' Price vs. efficiency relationship, top-mount refrigerator-freezer with auto-defrost, Table 4.1

Table A7-6 Freezer Retail Prices

UEC Retail Price

Technology Level ( kWh/year) (S2002) Source

Typical New 444 $405 (AHAM 2003)

ENERGY STAR® (10% 400 $415 (DOE 1995)'

decrease)

Price vs. efficiency relationship, chest manual defrost freezer, Table 4.8, baseline to design option 2

efficiency range.

Table A7-7: Compact Refrigerator Retail Prices

UGC Retail Price

Technology Level ( kWh/year) ($2002) Source

Typical New 300 $125 (WalMart 2004)

ENERGY STAR® (20% 240 $131 (DOE 1995)'

decrease)

' Price vs. efficiency relationship, compact manual defrost refrigerator, Table 4.9.

A7.3 Test Procedure Status

Standard-size refrigerators, refrigerator-freezers, freezers, and compact refrigerators are all

covered under the same DOE test procedure. They are tested at an ambient temperature of 90°F

while internal volume temperatures are kept within specified temperature conditions. DOE has

recently taken action on a couple of issues regarding the test procedure. Also, there have been

recent actions to improve AHAM's test standard. The National Institute of Standards and

Technology (NIST) has investigated the possibility of harmonizing the U.S. test procedure with

international test standards. All of these recent actions are described in more detail below.

7-5

EE-PS-04-001 COMMENT 01.12

Table A 7-5: Standard-Size Refrigerator-Freezer Retail Prices 

Price vs. efficiency relationship, top-mount refrigerator-freezer with auto-defrost, Table 4.1 

Table A 7-6 Freezer Retail Prices 

Typical Ncw 

ENERGYSTAR® (10% 

decrease) 400 $415 (DOE 1995)1 

Price vs. efficiency relationship, chest manual defrost freezer, Table 4.8, baseline to design option 2 

efficiency range. 

Table A7-7: Compact Refrigerator Retail Prices 

ENERGY ST AR® (20% 

decrease) 240 $131 (DOE 1995)1 

Price vs. efficiency relationship, compact manual defrost refrigerator, Table 4.9. 

A7.3 Test Procedure Status 

Standard-size refrigerators, refrigerator-freezers, freezers, and compact refrigerators are all 

covered under the same DOE test procedure. They are tested at an ambient temperature of 900 P 

while internal volume temperatures are kept within specified temperature conditions. DOE has 

recently taken action on a couple of issues regarding the test procedure. Also, there have been 

recent actions to improve AHAM's test standard. The National Institute of Standards and 

Technology (NIST) has investigated the possibility of harmonizing the U.S. test procedure with 

international test standards. All of these recent actions are described in more detail below. 

7-5 
Credit for a more efficient defrost system

DOE issued a direct final rule, which became effective in May 2003 , amending the calculation of

the test time period for "long-time" automatic defrost units (DOE 2003). This change gives

credit for a control capable of detecting frost so that the defrosting occurs other than during a

compressor-on cycle, thereby saving energy by taking advantage of the natural warming of the

evaporator during the compressor-off cycle. This revision has no effect on the testing of

refrigerators and refrigerator-freezers that do not employ a long-time automatic defrost system.

Change in electric refrigerator definition to exclude wine coolers

Several manufacturers of wine coolers requested exemptions from the refrigerator energy

efficiency standards. Some wine coolers are made with glass front doors, which make them less

energy efficient than standard refrigerators. As a result, the DOE amended the definition of

"electric refrigerator", effective December 19, 2001 , to include a maximum temperature of the

fresh food storage compartment, and to exclude certain appliances whose physical configuration

makes them unsuitable for general storage of perishable foods. The purpose of the revised

electric refrigerator definition was to exclude wine coolers from the energy efficiency regulation

(DOE 2001). This rule may also affect other compact refrigerators designed to store and cool

beverages other than wine. For example, since the time of the test procedure revision, a new

product has entered the market that is both a compact refrigerator and wine cooler whose

performance cannot be rated by the existing test procedure.

Repeatability issues for testing compact refrigerators

Because of inconsistencies in test results for compact refrigerators , the National Institute of

Standards and Technology (NIST) investigated repeatability and reproducibility issues and

published a report entitled "Repeatability of Energy Consumption Test Results for Compact

Refrigerators". In addition, NIST participated in a task force formed by the Association of

Home Appliance Manufacturers (AHAM) to revise their AHAM HRF-1 test procedure. The

latest version of AHAM's test procedure is now AHAM HRF-1, 2003. But the existing DOE

test procedure still references an older version of the AHAM test procedure, AHAM HRF-1,

1979. DOE may need to amend the test procedure to reference the most recent version of

ARAM HRF-1.

Harmonizing with international standards

NIST has done comparisons between ISO's international test standards and the North American

test standard. The two test procedures are similar but not identical. Differences include the

ambient temperature at which the refrigerators are tested and the ISO specified test load. There

is some interest in harmonizing and unifying the two test procedures by manufacturers interestec

in international trade. Recently, the United States, Canada, and Mexico have harmonized their

test procedures.

7-6

EE-PS-04-001 COMMENT 01.12

Credit for a more efficient defrost system 

DOE issued a direct final rule, which became effective in May 2003, amending the calculation of 

the test time period for "long-time" automatic defrost units (DOE 2003). This change gives 

credit for a control capable of detecting frost so that the defrosting occurs other than during a 

compressor-on cycle, thereby saving energy by taking advantage of the natural warming of the 

evaporator during the compressor-off cycle. This revision has no effect on the testing of 

refrigerators and refrigerator-freezers that do not employ a long-time automatic defrost system. 

Change in electric refrigerator definition to exclude wine coolers 

Several manufacturers of wine coolers requested exemptions from the refrigerator energy 

efficiency standards. Some wine coolers are made with glass front doors, which make them less 

energy efficient than standard refrigerators. As a result, the DOE amended the definition of 

"electric refrigerator", effective December 19,2001, to include a maximum temperature of the 

fresh food storage compartment, and to exclude certain appliances whose physical configuration 

makes them unsuitable for general storage of perishable foods. The purpose of the revised 

electric refrigerator definition was to exclude wine coolers from the energy efficiency regulation 

(DOE 2001). This rule may also affect other compact refrigerators designed to store and cool 

beverages other than wine. For example, since the time of the test procedure revision, a new 

product has entered the market that is both a compact refrigerator and wine cooler whose 

performance cannot be rated by the existing test procedure. 

Repeatability issues for testing compact refrigerators 

Because of inconsistencies in test results for compact refrigerators, the National Institute of 

Standards and Technology (NIST) investigated repeatability and reproducibility issues and 

published a report entitled "Repeatability of Energy Consumption Test Results for Compact 

Refrigerators". In addition, NIST participated in a task force formed by the Association of 

Home Appliance Manufacturers (AHAM) to revise their AHAM HRF-I test procedure. The 

latest version of AHAM's test procedure is now AHAM HRF-I, 2003. But the existing DOE 

test procedure still references an older version of the AHAM test procedure, AHAM HRF-l, 

1979. DOE may need to amend the test procedure to reference the most recent version of 

AHAMHRF-l. 

Harmonizing with international standards 

NIST has done comparisons between ISO's international test standards and the North American 

test standard. The two test procedures are similar but not identical. Differences include the 

ambient temperature at which the refrigerators are tested and the ISO specified test load. There 

is some interest in harmonizing and unifying the two test procedures by manufacturers intereste( 

in international trade. Recently, the United States, Canada, and Mexico have harmonized their 

test procedures. . 

7-6 
A7.4 Energy Savings Estimates and Calculations

Table A7-8 presents the energy savings potential for the FEMP, ENERGY STAR®, and CEE

efficiency levels specified in Tables A7-2 through A7-4. Also provided in Table A7-8 is the

economic benefit or burden to consumers for each efficiency level. Note that only the FEMP

and ENERGY STAR® efficiency levels yield an economic benefit to consumers. Consumer

national utility bill savings for a given year are derived by taking the national annual energy

savings and multiplying it by the corresponding electricity price from the DOE-Energy

Information Administration's Annual Energy Outlook 2004 (DOE 2004). Consumer national

equipment cost increases are derived by taking the per unit change in equipment cost and

multiplying it by the annual shipments. Cumulative bill savings and equipment cost increases are

summed over the time period 2010-2035 with the net benefit or burden being the difference

between the two values.13

Table A7-8: Refrigerator Potential Energy and Economic Impact Estimates

echnology Level

UEC

(kWh/yr)

Energy Saving

Potential, 2010-2035

((juads)

l otential Economic

Benefits/Rurden.s: Cumulative

NPV 2010-2035 (billions of

$2002)

Standard-Size Refrigerator-Freezers

Base Case 552 NA NA

FEMP 530 0.77 1.00

ENERGY STAR® 469 2.89 0.52

CEE Tier 1 442 3.85 -1.28

CEE Tier 2 414 4.82 -4.07

CEE Tier 3 386 5.78 -7.85

Freezers

Base Case 444 NA NA

ENERGY STAR® 400 0.38 0.61

Compact Refrigerators

Base Case 300 NA NA

ENERGY STAR® 240 0.48 0.87

13 Economic calculations are performed with a spreadsheet tool which is available on the DOE Building

Technologies Program, Appliances and Commercial Equipment Standards web site.

<http://www.eere.energy.gov/buildings/appliance standards/2005_priority_setting.html>

7-7

EE-PS-04-001 COMMENT 01.12

A7.4 Energy Savings Estimates and Calculations 

Table A7-8 presents the energy savings potential for the FEMP, ENERGY STAR®, and CEE 

efficiency levels specified in Tables A 7-2 through A 7 4. Also provided in Table A 7 -8 is the 

economic benefit or burden to consumers for each efficiency level. Note that only the FEMP 

and ENERGY STAR® efficiency levels yield an economic benefit to consumers. Consumer 

national utility bill savings for a given year are derived by taking the national annual energy 

savings and multiplying it by the corresponding electricity price from the DOE-Energy 

Information Administration's Annual Energy Outlook 2004 (DOE 2004). Consumer national 

equipment cost increases are derived by taking the per unit change in equipment cost and 

multiplying it by the annual shipments. Cumulative bill savings and equipment cost increases are 

summed over the time period 2010-2035 with the net benefit or burden being the difference 

between the two values. 13 

Table A7-8: Refrigerator Potential Energy and Economic Impact Estimates 

13 Economic calculations are perfonned with a spreadsheet tool which is available on the DOE Building 

Technologies Program, Appliances and Commercial Equipment Standards web site. 

<http://www.eere.energy.govlbuildingsiappliance_standards/2005-priority_setting.html> 

7-7 
A7.5 Regulatory Actions and Cumulative Burden

For full line manufacturers of white goods, consideration needs to be given to what other

regulatory actions are in effect for other products.

Also, refrigerator manufacturers had to recently comply with U.S. EPA regulations on the phaseout of HCFC-141b in 2003, the blowing agent that was used for foam insulation. Any

consideration given to updated minimum efficiency requirements needs to account for the effort

and cost manufacturers expended for meeting this regulation.

A7.6 Issues Impacting Potential Energy Efficiency Standards

DOE's most recent energy efficiency standards became effective on July 1, 2001. This set of

standards is the third set of minimum efficiency requirements that the industry has faced since

1990. The first set of standards took effect in 1990 and the second set in 1993.

Wine cooler and beverage centers as well as combination refrigerator/beverage coolers, need

definitions and possible test procedures and standards.

Compact refrigerators are a fast growing part of the overall refrigerator market. Thus, due to

their increased national energy consumption, potential energy savings could become greater in

the future.

7-8

EE-PS-04-001 COMMENT 01.12

A7.S Regulatory Actions and Cumulative Burden 

For full line manufacturers of white goods, consideration needs to be given to what other 

regulatory actions are in effect for other products. 

Also, refrigerator manufacturers had to recently comply with U .S. EPA regulations on the phaseout ofHCFC-141b in 2003, the blowing agent that was used for foam insulation. Any 

consideration given to updated minimum efficiency requirements needs to account for the effort 

and cost manufacturers expended for meeting this regulation. 

A7.6 Issues Impacting Potential Energy Efficiency Standards 

DOE's most recent energy efficiency standards became effective on July 1,2001. This set of 

standards is the third set of minimum efficiency requirements that the industry has faced since 

1990. The first set of standards took effect in 1990 and the second set in 1993. 

Wine cooler and beverage centers as well as combination refrigeratorlbeverage coolers, need 

definitions and possible test procedures and standards. 

Compact refrigerators are a fast growing part of the overall refrigerator market. Thus, due to 

their increased national energy consumption, potential energy savings could become greater in 

the future. 

7-8 
References

Appliance Magazine. 2004. "Healthy Times Ahead." January, 2004.

Association of Home Appliance Manufacturers (ARAM). 1996. Data on compact refrigerators.

Chicago, IL.

Association of Home Appliance Manufacturers (AHAM). 2003. "Fact Book 2003." Chicago, IL.

Consortium for Energy Efficiency (CEE). 2004. www.ceel.org

ENERGY STAR®. 2004. www.energystar.gov

Federal Energy Management Program (FEMP). 2004.

http://www.eere.energy.ov a/femp/technolog e^ s/eeproducts.cftn

National Appliance Energy Conservation Act (NAECA), 1987, Pub. L. 100-12

U.S. Department of Energy (DOE)-Office of Codes and Standards, 1995. "Technical Support

Document: Energy Efficiency Standards for Consumer Products: Refrigerators, RefrigeratorFreezers, & Freezers." Washington, DC. DOE/EE-0064.

U.S. Department of Energy (DOE)-Office of Energy Efficiency and Renewable Energy. 1997.

"Energy Conservation Program for Consumer Products: Energy Conservation Standards for

Refrigerators, Refrigerator-Freezers and Freezers; Final Rule." Federal Register 62 (81): 23102-

23116.

U.S. Department of Energy (DOE)-Office of Energy Efficiency and Renewable Energy. 2001.

"Energy Conservation Program for Consumer Products: Amendment to the Definition of Electric

Refrigerator; Final Rule." Federal Register 66 (223): 57845-57848.

U.S. Department of Energy (DOE)-Office of Energy Efficiency and Renewable Energy. 2003.

"Energy Conservation Program for Consumer Products: Test Procedure for Refrigerators and

Refrigerator-Freezers; Direct Final Rule." Federal Register 68 (45): 10957-10961.

U.S. Department of Energy (DOE), Energy Information Administration. 2004. "Annual Energy

Outlook 2004 with projections to 2025." Washington, DC. DOE/EIA-0383(2004). January

2004.

WalMart. 2004. Retail price for a Haier 4.2 cu.ft. compact refrigerator. March, 2004.

www.walmart.com

7-9

EE-PS-04-001 COMMENT 01.12

References 

Appliance Magazine. 2004. "Healthy Times Ahead." January, 2004. 

Association of Home Appliance Manufacturers (AHAM). 1996. Data on compact refrigerators. 

Chicago, IL. 

Association of Home Appliance Manufacturers (AHAM). 2003. "Fact Book 2003." Chicago, IL. 

Consortium for Energy Efficiency (CEE). 2004. www.cee1.org 

ENERGY STAR®. 2004. www.energystar.gov 

Federal Energy Management Program (FEMP). 2004. 

http://www.eere.energy.gov/femp/technologies/eeproducts.cfrn 

National Appliance Energy Conservation Act (NAECA), 1987, Pub. L. 100-l2 

U.S. Department of Energy (DOE)-Office of Codes and Standards, 1995. "Technical Support 

Document: Energy Efficiency Standards for Consumer Products: Refrigerators, RefrigeratorFreezers, & Freezers." Washington, DC. DOElEE-0064. 

U.S. Department of Energy (DOE)-Office of Energy Efficiency and Renewable Energy. 1997. 

"Energy Conservation Program for Consumer Products: Energy Conservation Standards for 

Refrigerators, Refrigerator-Freezers and Freezers; Final Rule." Federal Register 62 (81): 23102-

23116. . 

U.S. Department of Energy (DOE)-Office of Energy Efficiency and Renewable Energy. 2001. 

"Energy Conservation Program for Consumer Products: Amendment to the Definition of Electric 

Refrigerator; Final Rule." Federal Register 66 (223): 57845-57848. 

U.S. Department of Energy (DOE)-Office of Energy Efficiency and Renewable Energy. 2003. 

"Energy Conservation Program for Consumer Products: Test Procedure for Refrigerators and 

Refrigerator-Freezers; Direct Final Rule." Federal Register 68 (45): 10957-10961. 

U.S. Department of Energy (DOE), Energy Information Administration. 2004. "Annual Energy 

Outlook 2004 with projections to 2025." Washington, DC. DOElEIA-0383(2004). January 

2004. 

WaIMart.2004. Retail price for a Haier 4.2 cu.ft. compact refrigerator. March,2004. 

www.walmart.com 

7-9 
Attachment 2

Incremental Cost of ENERGY STAR Refrigerators , May 2004

not ENERGY STAR ENERGY STAR

Volume

Brand Color Type (cu. Ft.) Other features Model Price Model Price Price A % A Notes

Kenmore White Top freezer 20.6 icemaker 73092 $ 650.00 74172 $ 650.00 0%

Kenmore White Top freezer 20.6 icemaker 74162 $ 630.00 74172 $ 650.00 $20.00 3% ES model loses the wine/beverage rack

Kenmore White Top freezer 20.6 63092 $ 600.00 64172 $ 600.00 0%

Kenmore White Top freezer 20.6 64152 $ 580.00 64172 $ 600.00 $20.00 3%

Kenmore White Top freezer 18.3 63892 $ 550.00 64882 $ 550.00 0%

GE White Top freezer 17.9 GTS18KBPWW $ 600.00 GTH18JBRWW $ 580.00 -20 -3% ES model adds "NeverClean" condenser, Deluxe Quiet Design

GE White Top freezer 14.9 GTR15BBRWW $ 510.00 GTH15BBRWW $ 550.00 $40.00 8% ES model adds"FrostGuard"

Top freezer Average $8.57

Kenmore White Side by side 21.9 54242 $ 1,000.00 55582 $ 1,120.00 $120.00 ES model has many trademarked names associated with it (e.g. 12% "America's Quietest sound package", "Acceler-Ice ice production")

Kenmore White Side by side 25.4 54542 $ 1,050.00 54582 $ 1,170.00 $120.00 o ES model has many trademarked names associated with it (e.g.

11 /o "America's Quietest sound package", "Acceler-Ice ice production")

GE White Side by side 22 thru-door ice & water GSS22KGPWW $ 1,150.00 GSH22KGPWW $ 1,200.00 $50.00 4% Identical features, except for ENERGY STAR

GE White Side by side 25 thru-door ice & water GSS25J FPW W $ 1,050.00 GSH25VGRWW $ 1,250.00 $200.00 19%

Frigidaire White Side by side 22.6 thru-door ice & water FRS23KF5CW $ 900.00 FRS23KF6CW $ 1,000.00 $100.00 11 % ES model adds crisper light & water filter indicator light

Side by side Average $118.00

ES d l h t d k d "T A

Amapa White Bottom freezer 21.9 ARB2217CW $ 1,250.00 ABB2227DEW $ 1,250.00

mo e as many ra emar e names (e.g., emp- ssure

0% freshness control", "SofSound I Quiet package", "FreshNest egg

storage")

Bottom freezer Average $0

General notes for ACEEE analysis:

As the source of pricing, we used http://www.sears.com/ during the May 20-21, 2004 period. This has the advantage of being "real world" pricing, not as inflated as MSRP.

We used "Regular" prices and ignored sale prices, discounts, and coupons, mostly because the discounts were variously time dependant (so doing the research the next day would, literally, have

resulted in different price points.)

The market shares used below are from DOE 1995 TSD p. B-4. We use the single-family home column and exclude compact manual defrost units in calculating market shares.

ype

Top freezer

Average

cost of

ENERGY

STAR

$8.57

eight

3% 6.26

Side by side $118.00 25% $29.50

Bottom freezer $0 2% $0.00

$35.76 = Weighted Average

6/1/04 ENERGY STAR refrigerator costs

EE-PS-04-001 COMMENT 01.12

Attachment 2 

Incremental Cost of ENERGY STAR Refrigerators, May 2004 

Volume 

Brand Color Type (cu. Ft.) other features 

Kenmore White Top freezer 20.6 icemaker 

Kenmore White Top freezer 20.6 icemaker 

Kenmore White Top freezer 20.6 

Kenmore White Top freezer 20.6 

Kenmore White Top freezer 18.3 

GE White Top freezer 17.9 

GE White Top freezer 14.9 

Kenmore White Side by side 21.9 

Kenmore White Side by side 25.4 

GE White Side by side 22 thru-door ice & water 

GE White Side by side 25 thru-door ice & water 

Frigidaire White Side by side 22.6 thru-door ice & water 

Amana White Bottom freezer 21.9 

General notes for ACEEE analysis: 

not ENERGY STAR 

Model Price 

73092 $ 650.00 

74162 $ 630.00 

63092 $ 600.00 

64152 $ 580.00 

63892 $ 550.00 

GTS18KBPWW $ 600.00 

GTR15BBRWW $ 510.00 

54242 $ 1,000.00 

54542 $ 1,050.00 

GSS22KGPWW $ 1,150.00 

GSS25JFPWW $ 1,050.00 

FRS23KF5CW $ 900.00 

ENERGY STAR 

Model Price Price A 

74172 $ 650.00 

74172 $ 650.00 $20.00 

64172 $ 600.00 

64172 $ 600.00 $20.00 

64882 $ 550.00 

GTH18JBRWW $ 580.00 -20 

GTH15BBRWW $ 550.00 $40.00 

Top freezer Average $8.57 

55582 $ 1,120.00 

54582 $ 1,170.00 

GSH22KGPWW $ 1,200.00 

GSH25VGRWW $ 1,250.00 

FRS23KF6CW $ 1,000.00 

Side by side Average 

$120.00 

$120.00 

$50.00 

$200.00 

$100.00 

$118.00 

IARB2217CW $ 1,250.00 IABB2227DEW $ 1,250.00 I 

Bottom freezer Average $0 

%A Notes 

0% 

3% ES model loses the wine!beverage rack 

0% 

3% 

0% 

-3% ES model adds "NeverClean" condenser, Deluxe Quiet Design 

8% ES model adds"FrostGuard" 

12% ES model has many trademarked names associated with it (e.g. 

o "America's Quietest sound package", "Acceler-Ice ice production") 

11% ES model has many trademarked names associated with it (e.g. 

o "America's Quietest sound package", "Acceler-lce ice production") 

4% Identical features, except for ENERGY STAR 

19% 

11 % ES model adds crisper light & water filter indicator light 

ES model has many trademarked names (e.g., "Temp-Assure 

0% freshness control", "SofSound I Quiet package", "FreshNest egg 

storage") 

As the source of pricing, we used http://www.sears.com!duringtheMay20-21.2004period.Thishastheadvantageofbeing·realworld·pricing. not as inflated as MSRP. 

We used "Regular' prices and ignored sale prices, discounts, and coupons, mostly because the discounts were variously time dependant (so doing the research the next day would, literally, have 

resulted in different price points.) 

The market shares used below are from DOE 1995 TSD p. B-4. We use the single-family home column and exclude compact manual defrost units in calculating market shares. 

6!1!04 

Type 

Top freezer 

Side by side 

Bottom freezer 

Average 

cost of 

ENERGY 

STAR Weight 

$8.57 

$118.00 

$0 

73% 

25% 

2% ________ ~~~ 

ENERGY STAR refrigerator costs 
Attachment 3

Household Refrigerator Shipments and Costs

From Census of Manufacturers -- MA335F (Major Household Appliances)

Change relative to:

Previous

Year Quantity Value Value/unit 1997 year

1997 12,092.4 $5,272.4 $436.01 $0.00 NA

1998 11,279.0 5,035.6 446.46 10.45 $10.45

1999 11,692.5 4,968.8 424.96 -11.05 -21.50

2000 12,354.7 5,395.8 436.74 0.73 11.78

2001 11,776.4 5,227.1 443.86 7.85 7.12

2002 12,067.9 5,164.3 427.94 -8.07 -15.93

Data are compiled by the Bureau of the Census and are available at:

hILtp://www.census.gov/cir/www/335/ma335f.html .

EE-PS-04-001 COMMENT 01.12

Attachment 3 

Household Refrigerator Shipments and Costs 

From Census of Manufacturers -- MA335F (Major Household Appliances) 

Change relative to: 

Previous 

Year Quantity Value Value/unit 1997 year 

1997 12,092.4 $5,272.4 $436.01 $0.00 NA 

1998 11,279.0 5,035.6 446.46 10.45 $10.45 

1999 11,692.5 4,968.8 424.96 -11.05 -21.50 

2000 12,354.7 5,395.8 436.74 0.73 11.78 

2001 11,776.4 5,227.1 443.86 7.85 7.12 

2002 12,067.9 5,164.3 427.94 -8.07 -15.93 

Data are compiled by the Bureau of the Census and are available at: 

http://www.census.gov/cir/www/335/ma335f.html .