CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

TABLE OF CONTENTS

3.1 INTRODUCTION

........................................................................................................... 3-1 3.2 PRODUCT DEFINITIONS

............................................................................................. 3-1 3.3 PRODUCT CLASSES

..................................................................................................... 3-1 3.4 PRODUCT TEST PROCEDURES

................................................................................. 3-6 3.5 MANUFACTURER TRADE GROUPS

......................................................................... 3-7 3.5.1 Association of Home App liance Manufacturers

.............................................................. 3-8 3.5.2 Coin Laundry Association

............................................................................................... 3-8 3.5.3 Multi-housing Laundry Association

................................................................................ 3-8 3.6 MANUFACTURER INFORMATION

........................................................................... 3-8 3.6.1 Manufacturers and Market Shares

................................................................................... 3-9 3.6.2 Mergers and Acquisitions

.............................................................................................. 3-13 3.6.3 Small Business Impacts

................................................................................................. 3- 15 3.6.4 Distribution Channels

.................................................................................................... 3-15 3.7 REGULATORY PROGRAMS

..................................................................................... 3-16 3.7.1 Federal Energy Conservation Sta ndards Prior to EPACT 2005

.................................... 3-17 3.7.2 Energy Policy Act of 2005

............................................................................................. 3-17 3.7.3 Energy Independence and Security Act of 2007

............................................................ 3-17 3.7.4 State Energy Conservation Standards

............................................................................ 3-19 3.7.5 Canadian Energy Conservation Standards

..................................................................... 3-20 3.7.6 Foreign Standby Power Re gulatory Programs

............................................................... 3-21 3.8 VOLUNTARY PROGRAMS

........................................................................................ 3-22 3.8.1 Consortium for Energy Efficiency

................................................................................. 3-22 3.8.2 ENERGY STAR

............................................................................................................ 3- 23 3.8.3 Federal Energy Management Program

.......................................................................... 3-23 3.9 HISTORICAL SHIPMENTS

......................................................................................... 3-24 3.9.1 New Home Starts

.......................................................................................................... . 3-24 3.9.2 Unit Shipments

........................................................................................................... .... 3-25 3.9.3 Value of Shipments

....................................................................................................... . 3-26 3.9.4 Imports and Exports

...................................................................................................... . 3-28 3.10 MARKET SATURATION

............................................................................................ 3-29 3.11 PRODUCT RETAIL PRICES

....................................................................................... 3-30 3.12 I NDUSTRY COST STRUCTURE

................................................................................ 3-33 3.13 INVENTORY LEVELS AND CAPACITY UTILIZATION RATES

.......................... 3-35 3.14 TECHNOL OGY ASSESSMENT

.................................................................................. 3-36 3.14.1 Product Operations and Components

............................................................................. 3-36 3.14.1.1 Cooking Products

......................................................................................... 3-36 3.14.1.2 Commercial Clothes Washers

...................................................................... 3-40 3.14.2 Technology Options

...................................................................................................... . 3-41 3.14.2.1 Cooking Products

......................................................................................... 3-41 3.14.2.2 Commercial Clothes Washers

...................................................................... 3-64

3-i3.14.3 Energy Efficiency

....................................................................................................... ... 3-75 3.14.3.1 Cooking Products

......................................................................................... 3-75 3.14.3.2 Commercial Clothes Washers

...................................................................... 3-83

LIST OF TABLES

Table 3.6.1 Major and Other Range, Ov en and Cooktop Manufacturers

................................. 3-11 Table 3.6.2 Major and Other Micr owave Oven Manufacturers

................................................ 3-11 Table 3.6.3 Major and Other Commercial Clothes Washer Manufacturers

............................. 3-12 Table 3.6.4 Core Appliance Manufacturers

.............................................................................. 3-13 Table 3.7.1 EPACT 2005 Standards for Commercial Clothe s Washers

................................... 3-17 Table 3.7.2 State Commercial Clothes Washer Regulations Similar to EPACT 2005

............. 3-19 Table 3.7.3 California State Efficiency Standa rds for Commercial Clothes Washers

............. 3-19 Table 3.7.4 California Water Cons ervation Standards for Residential Clothes Washers

......... 3-20 Table 3.7.5 Canadian Energy Conservation St andards for Electric Cooking Products

............ 3-20 Table 3.7.6 Canadian Energy Cons ervation Standards for Residential Clothes Washers

........ 3-21 Table 3.7.7 Proposed EU Ecodesign require ments for standby and off mode

......................... 3-22 Table 3.8.1 CEE Criteria for Comme rcial Clothes Washers

.................................................... 3-23 Table 3.8.2 ENERGY STAR Criteria for Commercial Clothes Washers

................................ 3-23 Table 3.8.3 FEMP Recommendations for Microwave Ovens

.................................................. 3-24 Table 3.8.4 FEMP Recommendations for Commercial Clothes Washers

................................ 3-24 Table 3.9.1 Industry Shipment s of Cooking Products (Domestic and Import in Thousands of Units)

........................................................................................... 3-26 Table 3.9.2 2005 ENERGY STAR Shipments by Product (Domestic and Import)

................. 3-26 Table 3.9.3 Household Appliance Manuf acturing Statistics by Year

....................................... 3-27 Table 3.9.4 Disposition of Previ ous Appliance (Percentage)

................................................... 3-27 Table 3.9.5 Household Cooking Appliance Ma nufacturing Statistics by Year

........................ 3-28 Table 3.9.6 2006–2007 Imports of Appliances Covered by this Rulemaking

.......................... 3-29 Table 3.9.7 2004–2005 Exports of Appliances Covered by this Rulemaking

......................... 3-29 Table 3.10.1 Appliance Satura tion (Number in Millions) and Percentage of U.S. Households with Product

................................................................................... 3-30 Table 3.11.1 Residential Appliance Retail Prices

..................................................................... 3-30 Table 3.11.2 Commercial Clothe s Washer Retail Prices

.......................................................... 3-31 Table 3.12.1 Household Appliance I ndustry Employment and Earnings

................................. 3-33 Table 3.12.2 Household Applian ce Industry Census Data

....................................................... 3-34 Table 3.12.3 Industry Cost St ructure Using SEC Data

............................................................. 3-34 Table 3.13.1 Household Applian ce Industry Census Data

....................................................... 3-35 Table 3.13.2 Full Production Capa city Utilization Rates

......................................................... 3-36 Table 3.14.1 Technology Options for Gas Cooktops

............................................................... 3-42 Table 3.14.2 Technology Options for Open (Coil) Element Electric Cooktops

....................... 3-46 Table 3.14.3 Technology Options for Smooth Element Electric Cooktops

............................. 3-48 Table 3.14.4 Technology Options for Gas and Electric Ovens

................................................ 3-50 Table 3.14.5 Technology Options for Mi crowave Ovens – Energy Factor

.............................. 3-58 Table 3.14.6 Technology Options for Microwave Oven – Standby Power

.............................. 3-62

3-iiTable 3.14.7 Technology Options for Commercial Clothe s Washers

...................................... 3-65

LIST OF FIGURES

Figure 3.6.1 2006 Market Shares for the Domestic Electric Range Market

............................... 3-9 Figure 3.6.2 2006 Market Shares for th e Domestic Gas Range Market

................................... 3-10 Figure 3.6.3 2006 Market Shares for the Do mestic Microwave Oven Market

......................... 3-12 Figure 3.6.4 2006 Core Appliance Market Shares

.................................................................... 3-13 Figure 3.6.5 Commercial Clothes Washer Distribution Channels

............................................ 3-16 Figure 3.9.1 New Privately Owned Single-Family and Multi-Family Housing Unit Starts in the United States from 1998–2007

............................................................... 3-25 Figure 3.11.1 Commercial Clothe s Washer Retail Prices as a Function of Loading-Type and Presence of Coin Box

.................................................................................. 3-32 Figure 3.14.1 Standard Electric Rang es in the NRCan Database

............................................. 3-76 Figure 3.14.2 Self-Cleaning Electric Ranges in the NRCan Database

..................................... 3-77 Figure 3.14.3 Electric Cooktops in the NRCan Database

......................................................... 3-77 Figure 3.14.4 Self-Cleaning Electric Ovens in the NRCan Database

....................................... 3-78 Figure 3.14.5 Non-Self-Cleaning Electric Ovens in the NRCan Database

.............................. 3-79 Figure 3.14.6 AHAM Microwave Oven Efficien cy versus Rated Output Power

.................... 3-80 Figure 3.14.7 AHAM Microwave Oven Effi ciency versus Oven Volume

............................... 3-81 Figure 3.14.8 AHAM and CBEEDAC Microwave Oven Standby Power versus Rated Output Power ,

..................................................................................................... 3-82 Figure 3.14.9 Microwave Oven Standby Power C onsumption from the FEMP Database

....... 3-83 Figure 3.14.10 Commercial Cl othes Washer MEFs in the CEC, ENERGY STAR, and CEE Databases

................................................................................................. 3-84 Figure 3.14.11 Commercial Cl othes Washer WFs in th e CEC, ENERGY STAR, and CEE Databases

................................................................................................. 3-85

3-iiiCHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

3.1 INTRODUCTION
This chapter provides a profile of the resi dential cooking product and commercial clothes washer industries in the United States. The U.S. Department of Energy (DOE) developed the market and technology assessment presented in th is chapter primarily fr om publicly available information. This assessment is helpful in iden tifying the major manufact urers and their product characteristics, which form the basis for the engi neering and the life-cycle cost (LCC) analyses. Present and past industry structur e and industry financial informati on help DOE in the process of conducting the manufacturer impact analysis.

3.2 PRODUCT DEFINITIONS

DOE defines “ cooking products ” under the Energy Polic y and Conservation Act (EPCA) of 1975 (42 U.S.C. 6291–6309) as “consum er products that are used as the major household cooking appliances. They are designed to cook or heat different types of food by one or more of the following sources of heat: gas, electricity, or microwave energy. Each product may consist of a horizontal cooking top containing one or more surface units and/or one or more heating compartments. They must be one of the following classes: conventional ranges, conventional cooking tops, conventional ovens , microwave ovens, microwave/conventional ranges and other cooking pr oducts.” (10 CFR 430.2)

The Energy Policy Act of 2005 (EPACT 2005) (Pub. L. 109-58) established the definition of a commercial clothes washer (CCW) as follows:

The term ‘commercial clothes washer’ means a soft-mount, front-loadi ng or soft-mount, top-loading clothes washer that: A) has a clothes compartment that: i) for horizontal-axis clothes washers, is not more than 3.5 cubic feet; and ii) for vertical-axis clothes washers, is not more than 4.0 cubic feet; and B) is defined for use in: i) applications in which the occupants of more than 1 household will be using the clothes washer, such as multi-family housi ng common areas and coin laundries; or ii) other commercial applications.

(EPACT 2005, section 136(a)(4))

3.3 PRODUCT CLASSES
DOE intends to separate each product (resi dential cooking products and CCWs) into product classes. Because DOE will formulate a separate energy conservation standard for each

3-1product class, the criteria for separation into differe nt classes are: (1) type of energy used, and (2) capacity or other performance-relate d features such as those that provide utility to the consumer or others deemed appropriate by the Secretary that would justify the estab lishment of a separate energy conservation standard. ( 42 U.S.C. 6295 (q) and 6316(a))

For cooking products
, the proposed product classes are based on energy source ( i.e ., gas or electric) and the cooking method ( i.e., cooktops, ovens, and microwave ovens). There are five cooking product classes: (1) gas cooktops; (2) electric cooktops; (3) gas ovens; (4) electric ovens; and (5) microwave ovens. DOE’s proposed product classes are ba sed on the list of classes defined by DOE in its 1996 Technical Support Document for Residential Cooking Products (1996 TSD), which was released as part of the previous standards rulemaking. a Gas and electric ranges b are not listed below as product classes. Because ranges consist of both a cooktop and oven, any potential cooktop and oven standards would apply to the individual components of the range. As a result, pr oduct classes for ranges are not necessary.

For gas cooktops , DOE’s proposed product class is:

• Conventional burners.

Commercial-style gas burners, which are ch aracterized by firing ra tes greater than 14,000 British thermal units per hour (Btu/h) will not be considered for analysis due to a lack of available data for determining efficiency characte ristics. In addition, th e test procedure for gas cooktops is based on measuring temp erature rise in an aluminum block with a diameter dictated by the firing rate of the burner. The maximum diam eter of the test block is sufficient to measure higher output residential-scale bu rners. For commercial-type burners that must have larger diameter burner rings to accomplish complete co mbustion, however, this maximum test block diameter may be too small to achieve proper heat transfer and may not be representative of the dimensions of suitable cookware.

For electric cooktops , DOE’s 1996 TSD determined that the ease of cleaning smooth elements provides enhanced consumer utility over coil elements. Because smooth elements typically use more energy than coil elements , DOE is proposing the following product classes for electric cooktops:

• Low or high wattage open (coil) elements; and

• Smooth elements.

Gas and electric grills and griddles will not be analyzed because DOE is not aware of any data upon which it can base a determination of eith er adequacy of the test procedure to measure energy efficiency or energy efficiency characteri stics of products in th ese niche classes.

a Available online at http://www.eere.energy.gov/buildings/appliance_standards/residential/cooking_products.html

b DOE defines a “conventional range” under EPCA as “a class of kitchen ranges and ovens which is a household cooking appliance consisting of a conventional cooking top and one or more conventional ovens.” (10 CFR 430.2)

3-2For electric ovens , the 1996 TSD determined that the type of oven-cleaning system is a utility feature that affects performance. DOE found that standard ovens and ovens using a catalytic continuous-cleaning process use roughly the same amount of energy. On the other hand, self-cleaning ovens use a pyrolytic process that provides enhanced consumer utility with lower overall energy consumption as compared to either standard or catalytically lined ovens. Thus, DOE is proposing the following product classes for electric ovens:

• Standard oven with or w ithout a catalytic line; and

• Self-clean oven.

For gas ovens , for the same reasons as for electric ovens, DOE is proposing the following product classes:

• Standard oven with or w ithout a catalytic line; and

• Self-clean oven.

DOE proposed in the advance notice of proposed rulemaking (ANOPR), published on November 15, 2007 (November 2007 ANOPR), that standing pilot ignition systems do not provide unique utility that would warrant a separate product class for gas cooking products incorporating them. 72 FR 64463. In considering standing pilot ignition systems as either a separate product class or a design option, DOE notes that the purpose of such systems is to ignite the gas when burner operation is called for during a cooking process, and either standing pilot or electronic ignition provides this function. In addition, DOE has concluded from previous analysis that the average consumer does not experience frequent e nough or long enough power outages to consider the ability to operate in th e event of an electric pow er outage a significant utility.

DOE also addressed a similar issue in th e residential furnace and boiler rulemaking, where DOE made an exception to allow standing pilot ignition for gravity gas-fed boilers. Gravity gas-fed boilers, however, are a type of h eating equipment that represent a unique utility in that they do not require an electric circulation motor to oper ate, a utility which happens to accommodate religious and cultural practices whic h prohibit electronic ignition as well. Thus, the exception is based on continuing to allow pr oducts with certain perf ormance characteristics to be available to all consumers. But DOE is unable to create a similar exception for gas cooking products because there is no unique utility associated with standing pilot ignition.

Through market research, DOE determined that battery-powered electronic ignition systems have been implemented in other products, such as instantaneous gas water heaters, barbeques, furnaces, and other appliances, and the use of such ignition systems appears acceptable under the applicable safety standards contained in the American National Standards Institute (ANSI) Z21.1-2005 and Addenda 1-2007, Household Cooking Gas Appliances (ANSI Z21.1). Therefore, subgroups with religious and cultural practices which prohibit the use of line electricity ( i.e. , electricity from the utility grid) ca n still use gas cooking products without standing pilots, assuming gas cooking products are made available with battery-powered ignition. Furthermore, there is not expected to be any appreciable difference in cooking performance between gas cooking products with or without a standing pilot. Thus, DOE

3-3concludes that standing pilot igni tion systems do not provide a distin ct utility and that a separate class for standing pilot ignition systems is not warranted under section 32 5(q)(1) of EPCA. (42 U.S.C. 6295(q)(1))

Commercial-style gas ovens, with larger cavity volumes ( i.e. , those that correspond to cabinet widths of 36 inches) a nd higher firing rate burners ( i.e ., greater than 22,500 Btu/h), will not be analyzed as a separate product class. DOE recognizes that the test procedure may not adequately measure performance of commercial- style ovens because the single test block may not adequately measure the temperature distribution that is inherent with these products. Further, DOE is unaware of efficiency data or data eval uating the adequacy of the test procedure, so therefore will not conduct an analysis on this product class at this time.

For microwave ovens , DOE proposes no further class breakdown. This product class can encompass microwave ovens with and with out browning elements, but does not include microwave ovens that incorporate convection systems (combination ovens). DOE will not conduct an analysis at this time of combination microwave ovens due to a lack of data evaluating the applicability of the test pr ocedure to microwave ovens inc oporating convection systems.

For commercial clothes washers , DOE is proposing the follow ing product classes based on the method of access:

• Top-loading washers

• Front-loading washers

Typically, top-loading clothes washers (also known as top-lo aders) have a wash basket that rotates around a vertical axis, while front -loader clothes washer s (also known as frontloaders) have a wash basket that rotates around a horizontal axis. However, a limited number of residential horizontal-axis clothes washers which are accessible from the top, using a hatch in the wash basket, are currently availa ble, although DOE is unaware of a ny such CCWs on the market. For the purposes of this analysis, the terms “v ertical-axis” and “top-loading” will be used interchangeably, as will the terms “horizontal- axis” and “front-loading.” Additionally, clothes washers that have a wash basket whose axis of ro tation is tilted from horiz ontal are considered to be horizontal-axis machines for the purposes of this analysis.

In the November 2007 ANOPR, DOE stated that it planned to cons ider a single product class for CCWs in accordance with the prescriptive standards for such equipment set in EPACT 2005. 72 FR 64432, 64465 (Nov. 15, 2007). Through EPACT 2005, Congress imposed a minimum energy efficiency threshold for all CCWs to meet. EPACT 2005 placed all CCWs into a single product class with a single energy e fficiency and water efficiency standard for all covered equipment. Id . Accordingly, these standards en compass both top-loading and frontloading CCWs.

DOE has the authority to establish additio nal product classes within the CCW product category, if warranted. 72 FR 64432 (Nov. 15, 2007). In considering whether separate classes are warranted, DOE must consider the utility and performance characteristics to determine whether the relevant requirements have been met. (42 U.S.C. 6295(q); 6313(a)) Among the

3-4criteria DOE considered when examining potentia l separate product classes for clothes washers was the wash basket axis of rotation, which DOE also used for residentia l clothes washers. (See 10 CFR 430.32(g))

Although DOE considered issuing a single CCW product class in the ANOPR that would encompass both top-loading and front-loading CCWs, further consideration of the relevant statutory provisions and the public comments on the November 2007 ANOPR have led DOE to conclude that EPCA does not permit adoption of a standard that would eliminate top-loading CCWs. Accordingly, for the reasons explained be low, DOE has decided to establish two classes of CCWs based upon axis of access ( i.e. , top-loading or front-loading).

When directing the Secretary to consider am endments to the energy efficiency standards for CCWs, Congress did not mandate use of a single class or alter other re levant provisions of the statute related to setting classes. Firs t, under 42 U.S.C. 6311(21), the definition of “commercial clothes washer” specifically includ es both horizontal-axis clothes washers (frontloading machines) and vertical-a xis clothes washers (top-loadi ng machines). Further, the prescriptive standards for CCWs (1.26 Modified Energy Factor (MEF)/9.5 Water Factor (WF)), as set forth in 42 U.S.C. 6313(e), are achievable by both top-loadi ng and front-loading machines. Neither provision indicates an intention to eliminate either type of CCW currently available.

Next, 42 U.S.C. 6295(o)(4) c provides, “The Secretary may not prescribe an amended or new standard ... that is likely to result in the unavailability in the United States in any covered product type (or class) of performance characte ristics (including reliab ility), features, sizes, capacities, and volumes that are s ubstantially the same as those ge nerally available in the United States at the time of the S ecretary’s finding.” This stat utory provision demonstrates congressional intent to forego pot ential energy savings under certain enumerated circumstances. DOE has determined that this provisi on applies to the present CCW rulemaking.

In previous rulemakings, DOE has concluded that the method of “loading” clothes in washers (axis of access) is a “feature” within the meaning of 42 U.S.C. 6295(o)(4) and, consequently, established separa te product classes for top-loadi ng and front-loading residential clothes washers. 56 FR 22263 (May 14, 1991). DOE reiterated this position in denying the California Energy Commission’s (CEC) petition fo r waiver from Federal preemption of its residential clothes washer regulation. d 71 FR 78157 (Dec. 28, 2006). DOE denied the CEC petition for three separate and independent reason s, one of which was th at “interested parties demonstrated by a preponderance of evidence that the State of Californi a regulation would likely result in the unavailability of a class of residential clothes wash ers in California. ... [T]he rule would violate EPCA in another way, i.e. , it would mandate the 6.0 WF standard in 2010, which would likely result in the una vailability of top-loader re sidential clothes washers.” Id . at 78157­ 58. Given the similarities in technologies a nd design and operating characteristics between residential clothes washers and CCWs, in DOE’s judgment, the axis of access must be accorded similar treatment in the contex t of the current CCW rulemaking.

This provision is also applicable to CCWs, pursuant to 42 U.S.C. 6316(a).

d DOE’s denial of the CEC petition is currently in litigation ( California Energy Comm’n v. DOE , No. 07-71576 (9 th Cir. filed April 23, 2007)).

3-5 cIf DOE were to propose an amended standard for CCWs under the statutory criteria set forth in EPCA based upon a single product class, the result would be a standard that would effectively eliminate top-loading CCWs from the market, because it would set an MEF for all CCWs at a level significantly higher than the ma x-tech for top-loading machines. Because such a standard would violate the st atute (42 U.S.C. 6295(o)(4); 6313(a)), DOE has decided to propose separate product classes and accompanying standards for top-loading and front-loading CCWs in the notice of pr oposed rulemaking (NOPR).

3.4 PRODUCT TEST PROCEDURES
Test procedures exist for all products cove red by this rulemaking to determine energy efficiency and annual energy use as the basis fo r representation and dete rmination of compliance with energy conservation standards. DOE establ ished test procedures for residential cooking products and clothes washers thr ough the rulemaking process. EPACT 2005 established a test procedure for CCWs.

DOE revised its test procedure for cooking products to more accurately measure their efficiency and energy use. For DOE’s cooki ng products test proce dure, DOE published the revisions as a final rule in 1997; these included: (1) a reductio n in the annual useful cooking energy; (2) a reduction in the number of self-clean ing oven cycles per year ; and (3) incorporation of portions of the International Electrotechnical Commissi on (IEC) Standard 705-1998 and Amendment 2-1993 (IEC 705) for the cooking performa nce testing of microwave ovens. (62 FR 51976, (October 3, 1997); 10 CFR part 430, subpart B, appendix I) Note that as of 1997, IEC has established a new numbering convention for sta ndards. This test procedure has accordingly been assigned the publication number IEC 60705, and the current test procedure is IEC 60705 Edition 3.2-2006 (IEC 60705). e

Section 310 of the Energy Independence a nd Security Act of 2007 (EISA 2007) (Pub. L. No. 110-140) amends Section 325 of the EPCA to requi re that that the test procedures for ranges and ovens and microwave ovens be amended to include measurement of standby mode and off mode power, taking into consid eration the most current ve rsion of IEC Standard 62301 Household electrical appliances – Measurement of standby power (IEC 62301) and IEC standard 62087 Methods of measurement for the power consumption of audio, video and related equipment

. f EPCA, as amended by the EISA, also states that the final rule for this test procedure shall be published no later than March 31, 2011. (42 U.S.C. 6295(gg)) DOE notes that the current version of IEC 62301 is designated IE C 62301 Ed. 1.0-2005-06. DOE is also aware that IEC has proposed an updated standard, IEC 62301 Ed. 2.0, that amends the definitions of modes to include off mode(s), network connected sta ndby mode(s), and disconnected mode as well as standby mode(s). However, this revision to IEC 62301 is not expected to be finalized until after the final rule is published for this overall rulemaking.

e For more information visit http://www.iec.ch

.
f IEC 62087 does not cover any products for this rulemaking, and therefore was not considered.

3-6DOE believes separate test procedure rulema kings for standby mode and off mode power for microwave ovens and conventional cooking pr oducts are warranted. DOE does not have any data on standby power consumption in conventiona l cooking products that indicate the potential for significant energy savings. Thus, DOE will c onsider test procedure amendments in a later rulemaking that meets the March 31, 2011, deadline set by the EISA 2007 amendments to EPCA. (42 U.S.C. 6295(gg)(2)(B))

For microwave ovens, a test procedure change to incorporate sta ndby mode and off mode power has been initiated in para llel with the cu rrent rulemaking, and a fi nal rule for the test procedure is expected to be published prior to the publication of a final rule on energy conservation standards. DOE reviewed IEC 62301 as part of DOE’s microwave oven power tests to determine whether the specified test c onditions were suitable for microwave oven tests. The proposed test procedure would incorporate by reference provisions from IEC 62301 as well as language to clarify application of these provi sions for measuring sta ndby mode and off mode power where IEC 62301 is non-specific. The details of the test procedure change can be found in the separate microwave oven test procedure NOPR, which is be ing published in the Federal Register

. EPACT 2005 amended EPCA to require that commercial clothes washers be rated with the same test procedure established for residentia l clothes washers. (42 U.S.C. 6314(a)(8)) DOE adopted test procedures for CCWs in a final rule published on October 18, 2005. 70 FR 60407, 60416. DOE recognizes that the use of the reside ntial clothes washer test procedure could provide an opportunity for CCW manufacturers to incorporate design options for which the residential clothes washer test procedure gives credit, but which are unlikely to save energy in CCWs or provide additional utility to cons umers under actual operating conditions. For example, adaptive fill and load selector switche s are unlikely to be used by CCW consumers, who generally pay a fixed fee per load and who are thus incentivized to run full-sized loads and/or select the maximum fill setting. While DOE believes commercial laundry practices likely differ from residential practices, DOE does not consider these differences to warrant the amendment of the CCW test pro cedure, since the characteristic energy and water use for CCWs are taken into account in the NOPR analyses. DO E recognizes that in certain situations, the controls and/or operation of a CCW can be such that certain design features ( e.g. , fill level) can be set so that the CCW will not necessarily achieve the same energy and water savings that might be expected for residential clothes washer s. However, DOE does not have sufficient usage data to alter its preliminary conclusion that the existing residential clothe s washer test procedure is adequate to measure the energy consumption of CCWs.

3.5 MANUFACTURER TRADE GROUPS
DOE recognizes the importance of trade groups in disseminating information and promoting the interests of the industry that they support. To gain insight into the residential cooking product and CCW industries, DOE researched various associat ions available to manufacturers, suppliers, and users of such equipment. DOE also used the member lists of these groups in the construction of an exhaustive database containing domestic manufacturers.

3-7DOE identified several trade gr oups that support, or have an interest in, the residential cooking product and/or CCW i ndustries, including the Asso ciation of Home Appliance Manufacturers (AHAM), the Coin Laundry Associ ation (CLA), and the Multi-housing Laundry Association (MLA).

3.5.1 Association of Home Appliance Manufacturers

AHAM, g formed in 1967, aims to enhance the value of the home appliance industry through leadership, public educat ion and advocacy. AHAM provide s services to its members including government relations; certification programs for room air conditioners, dehumidifiers and room air cleaners; an active communications program; and technical services and research. In addition, AHAM conducts other market and consumer research studies and publishes a biennial Fact Book . AHAM also develops and maintain s technical standards for various appliances to provide uniform, repeatable procedures for measuring specific product characteristics and performance features.

3.5.2 Coin Laundry Association
The CLA, h based in Downers Grove, Illinois, is a trade association representing the 30,000 coin laundry owners in the United States and around the world. Since 1960, the CLA has provided education and service to the entrepreneurs of the coin laundry industry, promoted their business interests, and promoted th e industry to the general public.

3.5.3 Multi-housing Laundry Association
The MLA, i founded in 1959, is a trade association of operator and supplier companies providing professional laundry serv ices for the multi-housing industry. The MLA works for a favorable legislative and regulatory climate for th e industry, facilitates the exchange of technical and business information among members, and demons trates the value of the industry to target markets.

3.6 MANUFACTURER INFORMATION
The following section details informati on regarding domestic manufacturers of residential cooking products and CCWs, includi ng estimated market shares (section 3.6.1), industry mergers and acquisitions (section 3.6.2 ), potential small business impacts (section 3.6.3), and product distribution channels (section 3.6.4).

g For more information visit http://www.aham.org

.
h For more information visit http://www.coinlaundry.org

.
i For more information visit http://www.mla-online.com

.

3-83.6.1 Manufacturers and Market Shares
Using publicly available data ( e.g. Appliance Magazine and market assessments done by third parties), DOE estimates the market shares for domestic manufacturers of each of the products contained in this standards rulema king. Manufacturers may offer multiple brand names. Some of the brand names come from independent appliance ma nufacturers which have been acquired over time, and domestic manu facturers may put their brand on a product manufactured overseas. Compan ies included in this analys is may also be off-shore manufacturers that maintain a significant domestic presence via a U.S. entity.

For cooking products (including ovens, cooktops, and ranges) DOE estimates that there are approximately 16 domestic manufacturers. As will be discussed in section 3.6.2, Maytag Corporation (Maytag) and Whirlpool Corpor ation (Whirlpool) merged in 2006 but have continued to maintain both pr oduct lines to this date. GE Consumer & Industrial (GE) and Whirlpool represent nearly three quarters of the electri c range products market. GE represents over a third of the gas range products market , while the combined Whirlpool and Maytag comprise over a quarter. AB Electrolux (Frigida ire), Peerless-Premier Appliance Co. (PeerlessPremier), and other small manufacturers make up the difference in both markets. Figure 3.6.1 and Figure 3.6.2 illustrate the 2006 market shares for the domestic residential electric and gas range markets, respectively.

GE, 49%

Whirlpool, 22% Electrolux (Frigidaire), 10% Maytag, 9% Peerless Premier, 5% Others, 5%

Figure 3.6.1 2006 Market Shares for the Domestic Electric Range Market 1

3-9Others, 4%
Peerless Premier, 7%

Whirlpool, 11% GE, 38%

Maytag, 15%

Electrolux (Frigidaire), 25%

Figure 3.6.2 2006 Market Shares for the Domestic Gas Range Market 2

In addition to the manufacturers presented above, manufacturers of ovens , cooktops , and
ranges also include BSH Home App liances Corporation (Bosch-Siemens) (which acquired Thermador Corporation), Dacor, Inc. (Dacor), De’Longhi America, Inc. (De’Longhi), Fagor America Inc. (Fagor), Fisher & Paykel Applia nces Limited (Fisher & Paykel) (which acquired Dynamic Cooking Systems Inc.), Haier America Tr ading, LLC (Haier), Miele, Inc. (Miele), Kenyon International, Inc. (Kenyon), Sub-Zero Freezer Company, Inc. (Sub-Zero) (which acquired the residential division of the Wolf Appliance Company (Wolf)), Felix Storch, Inc. (Summit), and Viking Range Corporation (Vikin g). Table 3.6.1 lists these manufacturers.

3-10Table 3.6.1 Major and Other Range, Oven and Cooktop Manufacturers Major Manufacturers Other Manufacturers GE Peerless-Premier Whirlpool Bosch-Siemens Maytag Dacor Frigidaire De’Longhi Fagor Fisher & Paykel Haier Miele Kenyon Sub-Zero Summit Viking

The microwave oven market differs from the rest of the domestic cooking product market in that many of the manufacturers ar e foreign-owned companies with manufacturing facilities outside of the United States, and many of the domestic applianc e manufacturers rebrand foreign-manufactured products. Table 3.6.2 illust rates the 2006 market shares for the U.S. microwave oven market. Microwave oven manufactur ers with facilities inside the United States include Maytag, the Sharp Elect ronics Corporation (Sharp), Sub-Zero, Summit, and Viking. Figure 3.6.3 lists microwave manufacturers active in the domestic market.

Table 3.6.2 Major and Other Microwave Oven Manufacturers

Major Manufacturers Other Manufacturers LG Electronics, Inc. (LG) D aewoo Electronics Company, Ltd. (Daewoo) Sharp Panasonic Corporation of America (Panasonic) Samsung Electronics America, Inc. (Samsung) Whirlpool

Guangdong Galanz Enterprise Co., Ltd. (Galanz) GD Midea Microwave Oven Mfg. Co., Ltd. (Midea) Sanyo Sub-Zero Summit Viking

3-11Others, 12%

Whirlpool, 4%

LG Electronics, 35%
Panasonic, 8%

Daewoo, 8%

Samsung, 12%

Figure 3.6.3 2006 Market Shares for th e Domestic Microwave Oven Market 3

For commercial clothes washers , DOE estimates that there ar e five domestic and three foreign manufacturers. The majority of market share is held by four major manufacturers, including Alliance Laundry Systems LLC (Alliance), Maytag, Whirlpool, and GE. 4 Other manufacturers include AB Electrolux (Electrolux) j , Continental Girbau, In c. (Continental), LG, and Bermil Industries Corporation (Wascoma t). Table 3.6.3 lists these manufacturers.

Table 3.6.3 Major and Other Commercial Clothes Washer Manufacturers Sharp, 21%

Major Manufacturers Other Manufacturers Alliance Electrolux Maytag Continental Whirlpool LG GE Wascomat

j Commercial clothes washers are marketed under the Elect rolux Professional brand, as opposed to residential clothes washers which are primarily ma rketed under the Frigidaire brand.

3-123.6.2 Mergers and Acquisitions
Due to mergers and acquisitions , the home appliance industry continues to consolidate. While this phenomenon varies from product to product within the indus try, the large market shares of a few companies provide evidence in support of this characterization.

According to the September 2007 issue of Appliance Magazine , four manufacturers comprise 89 percent of the core appliance market share. “Core appliances” include dishwashers, clothes dryers, freezers, ranges, re frigerators, and clothes washers. Table 3.6.4 lists these core appliance manufacturers, and Figure 3.6.4 illustrates the breakdown of 2006 market shares in the core appliance category.

Table 3.6.4 Core Appliance Manufacturers

Core Appliance Manufacturers Whirlpool GE Frigidaire Maytag

Others, 9%
Haier, 2%

Whirlpool, 32% Maytag, 13%

Electrolux (Frigidaire), 17%

GE, 27%

Figure 3.6.4 2006 Core Appliance Market Shares 5

3-13On August 22, 2005, Whirlpool, headquartered in Benton Harbor, Mi chigan, and Maytag, based in Newton, Iowa, announced plans to merge in a deal worth $2.7 billion. 6 Maytag shareholders approved the merger on December 22, 2005. Shortly after announcing the merger, Whirlpool submitted a pre-merger notification to the U.S. Department of Justice (DOJ). The DOJ Antitrust Division initiated an investigation, scheduled to end February 27, 2006, into the effects of the merger, including po tential lessening of competiti on or the creation of a monopoly. Following this initial review, the DOJ asked fo r additional materials from each company and extended the review to March 30, 2006.

Opponents of the merger asserted that the co mbined companies would control as much as 70 percent of the residential laundry market a nd as much as 50 percen t of the residential dishwasher market. 7 Whirlpool claimed that their large potential residential laundry market share was skewed because the company produces wa shing machines for Sears, which sells them under their Kenmore in-house brand. Whirlpool went on to say that they must periodically bid with other manufacturers to keep the Kenmore contract and that S ears controls the pricing of the Kenmore units. 8

In early January 2006, U.S. Senator Tom Ha rkin and U.S. Representative Leonard Boswell, both of Iowa, called upon the DOJ to block the merger, claiming it would give Whirlpool an unfair advantage in the home appliance industry. The Congressmen wrote, that if the DOJ does not block the deal, the agency should at least “require that Whirlpool divest the washer and dryer portions of Maytag to a viable purchaser who will have the financial capability and desire to continue to operate that business.” 9

On March 29, 2006, DOJ closed its investigation and approved the merger. DOJ claims “that the proposed transaction is not likely to reduce competition substantially. The combination of strong rival suppliers with th e ability to expand sales signifi cantly and large cost savings and other efficiencies that Whirlpool appears likely to achieve indicates that this transaction is not likely to harm consumer welfare.” 10

The DOJ Antitrust Division focused its inve stigation on residen tial laundry, although it considered impacts across all products offered by th e two companies. DOJ determined that the merger would not give Whirlpool excessive market power in the sa le of its products and that any attempt to raise prices would likely be unsuccessful. In support of this claim, DOJ noted that (1) other U.S. brands, including Kenmore, GE, and Frigidaire, are well established; (2) foreign manufacturers, including LG and Samsung, are gaining market share; (3) existing U.S. manufacturers are below producti on capacity; (4) the large home appliance retailers have alternatives available to resist price incr ease attempts; and (5) Whirlpool and Maytag substantiated large cost savings and other efficiencies that would benefit consumers. 11

Whirlpool and Maytag completed the merg er on March 31, 2006. This large merger follows several other mergers and acquisitions in the home appliance industry. For example, Maytag acquired Jenn-Air Corporation (Jenn- Air) in 1982, Magic Chef, In c. (Magic Chef) in 1986, and Amana Appliances (Amana) in 2001. Whir lpool acquired the KitchenAid division of Hobart Corporation (KitchenAi d) in 1986. White Consolidated Industries (WC I) acquired the

3-14Frigidaire division of General Motors Cor poration in 1979, and AB Electrolux acquired WCI (and therefore Frigidaire) in 1986.

3.6.3 Small Business Impacts
DOE considers the possibility of small busin esses being impacted by the promulgation of energy conservation standards for residential cooking products and CCWs. At this time, DOE is aware of two small cooking produc ts manufacturers, defined by th e Small Business Association (SBA) as having 750 employees or fewer, who produce products that fall under this rulemaking and who therefore would be impacted by a mini mum efficiency standard. DOE evaluated the potential impacts on these small businesses as pa rt of the manufacturer impact analysis (MIA), which it conducted as a part of the NOPR analysis. For CCWs, manufacturers with 500 or fewer employees are classified by the SBA as small bus inesses. DOE is unaware of any such CCW manufacturers. For further information on the cooking products small busi nesses, see chapter 13 of the TSD.

3.6.4 Distribution Channels
Understanding the distribution channels of products covered by this rulemaking is an important facet of the market assessment. DOE gathered information regarding the distribution channels for residential cooking products and CCW s from publicly available sources. This section contains distribution channel inform ation for residential appliances and CCWs.

The distribution chain for resi dential appliances, including cooking products , differs from commercial products, as the majority of consum ers purchase their applia nces directly from retailers. These retailers include: (1) home impr ovement, appliance, and department stores; (2) Internet retailers; (3) member ship warehouse clubs; and (4) kitchen remodelers. The AHAM Fact Book 2005 reports that home improvement stores clai m nearly one out of every four dollars spent on appliances. 12

Home appliance retailers generally obtain products directly from manufacturers. The AHAM Fact Book 2003 shows that over 93 percent of reside ntial appliances are distributed from the manufacturer directly to a retailer. 13

For commercial clothes washers , DOE used a 1998 Consortium for Energy Efficiency (CEE) report describing their Commercial, Family-S ized Clothes Washer Initiative (see section 3.8.1 of this TSD). 14 This report includes an assessme nt of the CCW market. Figure 3.6.5 illustrates the CCW distribution channels identif ied in this report, which DOE believes are representative of the current market as well.

CEE reports that the CCW market can be divided into three areas, including: (1) laundromats; (2) private multi-family housing; and (3) large institutions ( e.g. , military barracks, universities, and housing authorities.) Most la rge institutions and a majority of private multifamily housing (between 50 and 90 percent) do no t purchase clothes washer s directly. Rather, these organizations lease their laundry space to a third party known as a route operator. Route operators supply laundry e quipment and maintain facilities in exchange for a percentage of the

3-15Manufacturer

Route Operator Distributor (some overlap with route operators)

Private & Institutional Building Manager ( 85%) Laundromat (~15%) laundry revenue. Laundromats and some private building managers, conversely, will purchase clothes washers directly from distributors. The main difference betw een route operators and distributors is the length of serv ice provided to their clients. Route operators provide on-going support while distributor support ends at the point of sale. 15

According to CEE’s report, there are between 2 and 3 million CCWs installed in the United States. In general, these washers are replaced at a rate of 10 percen t per year, resulting in a replacement of approximately 200,000 to 300,000 washers annually. In its 2007 CCW data submittal, AHAM reported somewhat lower sh ipment volumes of 175,000 to 190,000 units per year from 2002–2005. CEE also reports that, of th is annual replacement total, approximately 15 percent go to laundromats while 85 percent go to the multi-family sector. 16

~ Manufacturer

Route Operator Distributor (some overlap with route operators)

Private & Institutional Building Manager (~85%) Laundromat (~15%)

Sou r c e : CEE, Com m er c i al, F a m i l y
- S i z ed W a s h er s : An Initiat i v e Desc r i ption ofption of the Con s or tium fo r Ener g y Ef f i c i e n c y , 19 98.

Figure 3.6.5 Commercial Clothe s Washer Distribution Channels

3.7 REGULATORY PROGRAMS
The following section details current regu latory programs mandating energy conservation standards for residential cooking products a nd CCWs. Section 3.7.1 discusses Federal energy conservation standards prior to EPACT 2005, section 3.7.2 reviews new standards issued by EPACT 2005, section 3.7.3 reviews upcoming standards under EISA 2007, and section 3.7.4 provides an overview of existing St ate standards. In addition, s ection 3.7.5 reviews standards in Canada that may impact the companies servicing the North American market.

3-163.7.1 Federal Energy Conservation Standards Prior to EPACT 2005
The National Appliance Energy Conserva tion Act of 1987 (NAECA) (42 U.S.C. 6291­ 6309) amended EPCA to establish prescriptive standards for gas cooking products , requiring gas ranges and ovens with an elec trical supply cord not to be equipped with constant burning pilots and directed DOE to conduct two cycles of rulemakings to determine if more stringent standards are justified. (42 U.S.C. 6295 (h)(1 )-(2)) DOE initially analyzed standards for cooking products as part of an eight-product st andards rulemaking. It issued a NOPR on March 4, 1994, proposing performance standards for gas and electric residential cooking products, including microwave ovens. 59 FR 10464. In accordance with its Procedures for Consideration of New or Revised Energy Conser vation Standards for Consumer Products (the “Process Rule”) (61 FR 36974 (July 15, 1996); 10 CFR part 430, s ubpart C, appendix A), DOE refined its standards analysis of cooking products. With regard to gas cooking products, DOE focused on the economic justification for eliminating standi ng pilots. Partially due to the difficulty of conclusively demonstrating that elimination of standing pilots was ec onomically justified, DOE issued a final rule on September 8, 1998, that co vered only electric cook ing products, including microwave ovens. 63 FR 48038. The final rule found that standards were not economically justified for electric cooking products. DOE ne ver completed its standards rulemaking for gas cooking products.

3.7.2 Energy Policy Act of 2005
On August 8, 2005, the President signed in to law EPACT 2005. This legislation established energy conservation standards for several reside ntial and commercial products, including commercial clothes washers . Without consideration fo r product classes, section 136(e) of EPACT 2005 amends section 342 of EP CA, 42 U.S.C. 6313, to add subsection (e) for CCWs, which establishes energy and water conser vation standards. These Federally mandated standards for CCWs became the national standa rds when they took effect on January 1, 2007. Table 3.7.1 provides EPACT 2005 standards for CCWs.

Table 3.7.1 EPACT 2005 Standards for Commercial Clothes Washers

Clothes Washer Classification Standards Effective January 1, 2007 MEF* (ft 3 /kWh/cycle) WF* (gallons/ ft 3 /cycle) Top- and front-loading 1.26 9.5 *The Modified Energy Factor (MEF), is a measure of how many kilowatt-hours (kWh) are required to wash each cubic foot (ft 3 ) of washer capacity. It measures the total energy consumption of the washer and also accounts for the amount of energy required to dry clothes based on the remaining moisture content of the clothes. Water Factor (WF) is measured in gallons of water required per cycle per cubic foot of washer capacity.

New subsection 342(e), 42 U.S.C. 6313(e) also requires that DOE issue a final rule by January 1, 2010, to determine whether these standards for CCWs should be amended.

3.7.3 Energy Independence and Security Act of 2007
On December 19, 2007, the President signe d into law EISA 2007, which contains numerous amendments to EPCA. Section 325 of EPCA is amended by section 310 of EISA

3-172007 to require DOE to regulate standby mode and off mode energy consumption as part of an energy conservation standard for all c overed products, including residential ranges and ovens and microwave ovens , for which a final rule is adopted after July 10, 2010. (42 U.S.C. 6295(gg)(1)(A)) Off mode is de fined by EISA 2007 as “the condi tion in which an energy-using product – (I) is connected to a main power source; and (II) is not providing any standby or active mode function.” (42 U.S.C. 6295(gg)(1)(A)(ii)) Active mode refers to the main (cooking) function, while standby is defined by EISA 2007 as “the condition in which an energy-using product (I) is connected to a mainpower source; and (II) offers 1 or more of the following useroriented or protective functions: (aa) To facilitate the activation or deactivation of other functions (including active mode) by remote switc h (including remote control), internal sensor, or timer. (bb) Continuous func tions, including information or st atus displays (including clocks) or sensor-based functions.” ( Id .; 42 U.S.C. 6295(gg)(1)(A)(iii))

Because the final rule for this rulema king is scheduled to be published in the Federal Register by March 31, 2009, an energy conservation st andard for cooking products set forth by this rulemaking is not required to incorporate standby mode and off mode energy consumption. Although DOE is also not required to inco rporate standby mode and off mode energy consumption for any cooking products at this ti me, in the November 2007 ANOPR, DOE stated that it was considering including standby power in the energy conservation standards and intended to initiate amendment of its test pro cedure to measure microwave oven standby power because: 1) energy conservation in standby mo de represents a signi ficant proportion of microwave oven annual energy consumption; and 2) the range of standby power among microwave ovens currently on the market suggests th at the likely impact of a standard would be significant. Such a test procedure change is a prerequisite to in corporate a standby power requirement as part of the energy cons ervation standard for microwave ovens. k Data obtained by DOE during testing of a representative sample of microwave ovens and from AHAM show standby power ranging from 1.1 to 5.8 W. At the Federal Energy Management Program (FEMP)-defined limit of 2 W, the resulting 17.2 kWh of annual standby energy use represents 13 percent of the estimated annual cooking energy consumption for a baseline microwave oven. DOE is unaware of any microwave ovens curren tly on the market in the United States that consume energy in off-mode, di fferentiable from standby mode. Therefore, DOE proposed for the purposes of the NOPR to put forth standa rds for microwave oven standby power only, but remains open to consideration of off-mode standards.

As stated previously, DOE does not have any data on standby power consumption in conventional cooking products ( i.e. , electric and gas cooktops a nd ovens) that indicate the potential for significant energy sa vings. For this reason, DOE is not considering regulating standby and off-mode power for conventional cooking products as part of the current rulemaking.

k As discussed in the November 2007 ANOPR, addressing standby mode and off mode energy consumption is not required for this rulemaking under EPCA, but DOE seeks to publish a final rule for the test procedure amendments prior to March 31, 2009, in order to allow the microwave oven energy conservation standards to account for standby mode and off mode power.

3-183.7.4 State Energy Conservation Standards
Prior to the passage of EPACT 2005, severa l States proposed and adopted State-level efficiency regulations for commercial clothes washers that are identical, or very similar, to EPACT 2005 regulations. The EPACT 2005 energy and water use standards for CCWs preempt any State efficiency standards since they becam e effective January 1, 2007. Table 3.7.2 presents information regarding States adopting CC W standards comparable to EPACT 2005.

Table 3.7.2 State Commercial Clothes Washer Regulations Similar to EPACT 2005
State Effective Date Difference from EPACT 2005

Arizona MEF and WF: 1/1/08 Standards e ffective one year later than EPACT 2005

California MEF: 1/1/05 WF: 1/1/07 MEF standard effective two years earlier than EPACT 2005

Connecticut MEF and WF: 7/1/06 Standards effective six months earlier than EPACT 2005 Maryland MEF and WF: 3/1/07 Standards e ffective two months later than EPACT 2005

New Jersey MEF: 1/1/07 WF: 1/1/10 Water factor standard effective three years later than EPACT 2005 Oregon MEF and WF: 1/1/08 Standards e ffective one year later than EPACT 2005
Rhode Island MEF and WF: 1/1/07 Identical to EPACT 2005
Washington MEF - For Sale: 1/1/07 MEF - Installation: 1/1/08 Does not address water factor

As presented in the table above, the State of California mandates energy and water conservation standards for commercial front-l oading and commercial top-loading automatic clothes washers. Table 3.7.3 provides the Stat e’s CCW energy conservation standards, which are dependent on clothes containe r capacity, and the water conservation standards, which became effective two years after the MEF standards.

Table 3.7.3 California State Efficiency St andards for Commercial Clothes Washers

Clothes Washer Classification Clothes Container Compartment Capacity (ft 3 ) Minimum MEF Effective January 1, 2005 Maximum WF Effective January 1, 2007 Front-loading < 3.5 ft 3 1.26 9.5 Top-loading < 1.6 ft 3
≥ 1.6 ft 3 and < 4.0 ft 3 0.65 1.26 9.5 9.5

In addition to the efficiency standards di scussed above, the State of California requires that commercial top-loading semi-automatic clothes washers and commercial suds-saving clothes washers manufactured on or after Janua ry 1, 2005, have an unheated rinse water option.

Additionally, California issu ed minimum water conservation standards for residential clothes washers. While this does not directly affect products covered by the rulemakings, DOE is aware that this standard may have impact s on manufacturers of CC Ws and other household appliances. Although Federal sta ndards exist for the energy consum ption of residential clothes

3-19washers, no such standard exists for the wate r efficiency. On September 16, 2005, the California Energy Commission (CEC) issued a petition for an exemption from Federal preemption to seek to apply its own State regulation for resident ial clothes washer WF. DOE accepted written comments regarding this Californi a petition until April 7, 2006. Table 3.7.4 provides the State’s proposed residential clothes washer water conser vation standards and their respective effective dates.

Table 3.7.4 California Water Conservation Sta ndards for Residential Clothes Washers Clothes Washer Maximum WF Classification Effective January 1, 2007 Effective January 1, 2010 Top-loading 8.5 6.0 Front-loading 8.5 6.0

On December 28, 2006, DOE issued a decision denying the California petition. 71 FR 78157. The denial of the petition was based on three factors. First, DOE determined that it does not have the statutory authority to prescribe a rule for Californi a that would become effective by January 1, 2007, the first of two compliance date s contained in Title 20, section 1605.2(p)(1) of the California Code of Regulations. Second, DO E ruled that the CEC had not established by a preponderance of the evidence that the State of California has unusual and compelling water interests, a condition required by EPCA for DOE to grant California a waiver from Federal preemption. (42 USC 6297(d)(1)(B)) Finally, a preponderance of evidence showed that the California regulation would likely result in the unavailability of a class of residential clothes washers, specifically top-loader machines, in California. The State has submitted to DOE a request for reconsideration. 17

3.7.5 Canadian Energy Conservation Standards
Canada’s Energy Efficiency Regulations (hereafter Regulations) mandate minimum energy conservation standard s for certain residential cooking products , including electric and gas ranges, cooktops, and ovens. The Regulations do not cover microwave ovens. Like U.S. DOE standards, Canadian Regulations require that gas cooking produc ts, including ranges, ovens, and cooktops, with an electr ical supply cord not be equipped with constant burning pilots. Table 3.7.5 presents the Regulations for electric cooking products.

Table 3.7.5 Canadian Energy Conservation St andards for Electric Cooking Products
Cooking Product Classification Maximum Allowable Energy Consumption (kWh/year)* Free-standing or built-in range s with one or more surface elements and one or more ovens 2.0V + 458 Built-in or wall-mounted ranges without surface elements and with one or more ovens 2.0V + 200 Counter-mounted ranges without ovens and with one or more surface elements on a conventional ( i.e. , not modular) cooktop 258

* Where V = volume of oven in liters

3-20The Canadian government also regulat es the efficiency of residential clothes washers

. While this standard does not directly apply to products covered by this rulemaking, DOE understands that this standard may still impact some North American manufacturers in the home appliance industry. This Regula tion applies to standard or compact electrically operated household clothes washers that are top- or front-loaded, and that ha ve an internal control system that regulates the water temper ature without the need for user intervention subsequent to initiation of machine operation. Table 3.7.6 lists th e current standards that went into effect January 1, 2007, along with the previous standard s that went into effect January 1, 2004.

Table 3.7.6 Canadian Energy Conservation St andards for Residential Clothes Washers

Clothes Washer Classification Minimum MEF (L/kWh/cycle) January 1, 2004 January 1, 2007 Vertical-axis compact (< 45 liter capacity) 18.40 18.40 Vertical-axis standard ( ≥ 45 liter capacity) 29.45 35.68 Horizontal-axis* 29.45 35.68 Suds-saving* NA NA
* These product classes shall be equipped with an unheated rinse water option.

3.7.6 Foreign Standby Power Regulatory Programs
The International Energy Agency (IEA) has raised awareness of standby power through publications, international conferences, and policy advice to governments. In 1999, the IEA developed the “1-Watt Plan,” which proposed reducing standby power internationally in electronic devices and which a dvocates that all countries ha rmonize energy policies and adopt the same definition and test procedure. The IE A has advocated a 1 watt (W) requirement for all consumer electrical products (unless specifica lly excluded) in standby mode. The IEA also stated that IEC 62301 provides an internationall y sanctioned definition and test procedure for standby power, which is now widely specified and used. l

A number of countries have implemented re gulatory approaches to standby power in microwave ovens . Australia has announced plans to implement a mandatory 1 W requirement for all consumer electrical produc ts by 2012, including microwave ovens. 18 The Korea Energy Management Corporation devel oped their “e-standby” program, wh ich currently has a voluntary labeling program for microwave ovens with less than 1 W of standby power. The program is currently transitioning to a mandatory 1 W standard by the year 2010. 19 In accordance with Japan’s Top Runner Program, m Japanese appliance manufacturer s made a voluntary declaration to reduce standby power consumption of microwav e ovens without a timer as close to 0 W as possible and that of microwave ovens with a timer to 1 W or lower. 20

l For more information visit http://www.iea.org/

.

m

Japan’s Energy Conservation Act uses a “top runner” met hod to set energy efficiency targets for residential, commercial, and transportation s ector equipment. Target values for future products are set based on the level of the most energy efficient products on the ma rket at the time of the value setting pr ocess. For more information, visit http://www.eccj.or.jp/index_e.html

3-21The European Union (EU) passed the Ecode sign Directive in 2005 which calls for an implementing measure to reduce standby power fo r a specified list of energy using products, which include microwave ovens. On July 23, 2008, the Commission of the European Communities published a draft proposal containi ng Ecodesign requirements for standby and off mode electric power consumption. Table 3.7.7 presen ts the proposed criteria for standby and off mode power, which are well in line with the IEA 1-Watt plan. 21

Table 3.7.7 Proposed EU Ecodesign re quirements for standby and off mode Mode Maximum Power Watts Tier 1 (1 year after implementi ng measure has come into force) Off (no function) 1.0 W Standby (only reactivation function) 1.0 W Standby (information or status disp lay plus reactivation function 2.0 W Tier 2 (4 years after implementing measure has come into force) Off (no function) 0.5 W Standby (only reactivation function) 0.5 W Standby (information or status disp lay plus reactivation function 1.0 W

3.8 VOLUNTARY PROGRAMS
DOE reviewed several voluntary programs promoting energy efficient residential cooking products and CCWs in the United States. Many programs, including the CEE, ENERGY STAR, and FEMP, establish voluntary energy conservation standards for these products.

3.8.1 Consortium for Energy Efficiency

The CEE n develops initiatives for its Nort h American members to promote the manufacture and purchase of en ergy efficient products and services. The goal of the organization is to induce lasting structural and behavioral change s in the marketplace, resulting in the increased adoption of energy efficient technologies.

In 1998, CEE launched the Commercial, Family-S ized Washer Initiative as an offshoot of its Residential Clothes Washer Initiative. Th e initiative encourages the purchase and use of energy and water efficient commercial clothes washers for laundromats, multi-family buildings and institutions. Table 3.8.1 presents the current voluntary e fficiency specifications for the program. In order to qualify, a CCW must exceed the minimum MEF and remain below a specified WF.

n For more information visit http://www.cee1.org

.

3-22Table 3.8.1 CEE Criteria for Commercial Clothes Washers Level MEF WF Tier 1 1.80 7.5 Tier 2 2.00 6.0 Tier 3 2.20 4.5

3.8.2 ENERGY STAR
ENERGY STAR, a voluntary labe ling program backed by the U.S. Environmental Protection Agency (EPA) and DOE, identifies en ergy efficient products through a qualification
process. o To qualify, a product must exceed Federal minimum standards by a specified amount, or if no Federal standard exists, exhibit sele cted energy saving feat ures. The ENERGY STAR program works to recognize the top quartile of products on the market, meaning that approximately 25 percent of products on the market meet or exceed the ENERGY STAR levels. ENERGY STAR specifications exist fo r several products, including CCWs.

ENERGY STAR criteria exist for top- and front-loading commercial clothes washers with capacities greater than 1.6 cubic feet. New ENERGY ST AR criteria for CCWs, which include energy and water consumption ratings, became effective January 1, 2007. The current criteria and previous criteri a are contained in Table 3.8.2.

Table 3.8.2 ENERGY STAR Criteria for Commercial Clothes Washers Clothes Washer Classification Previous Criteria Level Current Criteria Levels Top- and front-loading clothes washers MEF ≥ 1.42 MEF ≥ 1.72 WF ≤ 8.0

3.8.3 Federal Energy Management Program

DOE’s FEMP p works to reduce the cost and environmental impact of the Federal government by advancing energy efficiency a nd water conservation, pr omoting the use of distributed and renewable energy, and improving util ity management decisions at Federal sites. FEMP helps Federal buyers id entify and purchase energy efficient equipment, including microwave ovens and CCWs.

Executive Order 13221 Energy Efficient Sta ndby Power Devices, signed July 31, 2001, requires that Federal agencies purchase comm ercially available products with low standby power. 66 FR 40571. FEMP, therefore, i ssues standby power recommendations for microwave

ovens . Table 3.8.3 presents the microwave oven recommendations.

o For more information visit http://www.energystar.gov

.

p For more information visit http://www.eere.energy.gov/femp

.

3-23Table 3.8.3 FEMP Recommendations for Microwave Ovens Microwave Oven Classification Standby Power (W)* Standard Microwave Oven ≤ 2

* Based on test procedures specified in IEC 62301

For commercial clothes washers , FEMP issues energy e fficiency recommendations based on washer volume. Table 3.8.4 presents the CCW recommendations.

Table 3.8.4 FEMP Recommendations for Commercial Clothes Washers Clothes Washer Tub Volume Annual Energy Use (kWh/yr)* MEF

1.9 - 2.5 ft 3 410 or less 2.5 or higher 2.6 – 3.3 ft 3 520 or less 2.5 or higher

* Based on 392 wash cycles per year (10 CFR part 430, subpart B, appendix J1)

FEMP estimates that, with electric water heating, replacing a 2.48 ft 3 CCW exhibiting an MEF of 1.80 with a clothes washer exhibiting an MEF of 2.50 will save $1,400 over the lifetime of the unit (assuming Federal average energy pri ces). The same replacement with gas water heating will save $800 over the lifetim e of the clothes washer.

3.9 HISTORICAL SHIPMENTS
Awareness of annual product shipment trends is an important aspect of the market assessment and in the development of the standa rds rulemaking. DOE reviewed data collected by the U.S. Census Bureau, EPA, and AHAM to ev aluate residential appliance product shipment trends and the value of these shipments, which we re used during the shipments analysis (chapter 10 of this TSD.)

3.9.1 New Home Starts
Trends in new home starts may directly a ffect shipments of certain home appliances. While there is certainly both a replacement and remodeling market for some appliances including cooking products, these products are also fixtures in virtually all new homes. Multifamily unit starts can also affect shipments of CCWs.

Figure 3.9.1 presents the number of new si ngle-family and multi-family housing units started in the United States from 1998–2007. Over the 5-year period from 2000–2005, singlefamily home starts increased 39.4 percent, to 1,716,000 units annually. However, between 2005 and 2007, single-family home starts decreased 39.0 percent, to 1,046,000 un its annually. Multifamily unit starts have remained relatively fl at over the past 10 years, hovering around 350,000 units annually. 22

3-240 200 400 600 800 1,000 1,200 1,400 1,600 1,800 2,000Housing Units Started (thousands of units)

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 Single-Family Units Multi-Family Units
Figure 3.9.1 New Privately Owned Single-Family and Multi-Family Housing Unit Starts in the United States from 1998–2007 23

3.9.2 Unit Shipments

AHAM’s Fact Book provides annual unit shipments for residential appliances. Table 3.9.1 presents annual shipments of cooking products . In the 10-year period from 1995–2005, shipments of electric and gas free-standing rang es and surface cooking units, electric built-in ranges, and microwave ovens increased, while sh ipments of built-in gas ranges decreased.

3-25Table 3.9.1 Industry Shipments of Cooking Products (Domestic and Import in Thousands of Units) 24

Year Cooking Products Electric Ranges Gas Ranges

Microwave OvensFreeStanding Built-In Surface Cooking

Units Total FreeStanding BuiltIn Surface Cooking

Units Total 2005 4,685 973 542 6,201 3,139 64 560 3,762 13,862 2004 4,612 963 570 6,145 3,124 67 528 3,719 15,526 2003 4,238 841 543 5,622 2,897 67 455 3,419 14,274 2002 4,030 780 528 5,338 2,781 71 416 3,268 13,311 2001 3,842 726 498 5,066 2,580 72 384 3,036 13,446 2000 3,826 706 494 5,026 2,729 70 377 3,176 12,644 1999 3,785 705 493 4,983 2,698 72 367 3,137 11,422 1998 3,481 652 506 4,639 2,543 71 336 2,950 10,365 1997 3,177 617 446 4,240 2,391 73 280 2,744 8,883 1996 3,123 614 418 4,155 2,366 72 272 2,710 8,771 1995 2,931 598 389 3,917 2,391 84 240 2,715 8,162

ENERGY STAR shipment data for residential clothes washers may also prove useful during this standards rulemaking. Table 3.9.2 pr esents the 2005 breakdo wn of ENERGY STAR versus non-ENERGY STAR shipments fo r residential clothes washers.

Table 3.9.2 2005 ENERGY STAR Shipments by Product (Domestic and Import) Shipments % ENERGY STAR of

Total 25 Product ENERGY STAR-Qualified Other Total 26

Residential Clothes Washers 3,424,000 5,970,000 9,394,000 36.5

3.9.3 Value of Shipments
Table 3.9.3 provides the value of shipments for the household appliance industry from 1994–2006 based upon data from the U.S. Census Bureau’s Annual Survey of Manufacturers (ASM). q The ASM expresses all dollar values in nominal dollars; i.e. , 2006 data are expressed in 2006 dollars, and 2005 data are expressed in 2005 dollars. Using the Gross Domestic Product Implicit Price Deflator, DOE converted each yea r’s value of shipments to 2006 dollars. In constant 2006 dollars, the value of shipments has declined by near ly 22 percent over the 13-year period.

qAvailable online at http://www.census.gov/mcd/asm-as1.html

.

3-26Table 3.9.3 Household Appliance Manufacturing Statistics by Year 27

Year Value of Shipments in Nominal Dollars ($1000) Value of Shipments in 2006 Dollars ($1000) 2006 22,965,146 22,965,146 2005 24,620,117 25,341,881 2004 23,989,141 25,439,547 2003 23,026,196 25,111,893 2002 22,269,541 24,803,498 2001 22,298,897 25,269,862 2000 23,414,965 27,171,194 1999 22,372,219 26,526,720 1998 22,471,878 27,030,451 1997 21,394,445 26,019,810 1996 22,156,900 27,395,591 1995 22,391,300 28,210,228 1994 22,793,900 29,305,108

The increase in shipment volumes combined with an overall decrease in constant-dollar shipment values indicates that the U.S. appliance industry is very competitive.

According to data presented in the AHAM Fact Book 2003 , many old appliances are still being used after consumers purchase new units of same product. Table 3.9.4 presents the various methods by which consumers dispos e of their older appliances.

Table 3.9.4 Disposition of Previous Appliance (Percentage) 28

Product Kept It Left with Previous

Home Sold / Gave Away Recycling Facility Left at Curb for Disposal Retailer Took Away Ranges 6 37 21 13 8 15 Built-In Ranges 4 46 11 15 12 13 Microwave Ovens 17 11 32 12 23 4

The value of shipments of residential cooking products , a subset of the household appliance industry as defined in the ASM, has fl uctuated over the last 13 years when viewed in 2006 real dollars. Overall, the real value of shipments in 2006 was less than one percent lower than the value in 1994. Table 3.9.5 provides th e industry value of shipments for household cooking appliance manufacturing.

3-27Table 3.9.5 Household Cooking Applian ce Manufacturing Statistics by Year 29

Year Value of Shipments in Nominal Dollars ($1000) Value of Shipments in 2006 Dollars ($1000) 2006 4,864,268 4,864,268 2005 5,114,677 5,264,619 2004 4,798,227 5,088,332 2003 4,691,713 5,116,685 2002 4,327,308 4,819,694 2001 3,773,442 4,276,192 2000 4,178,958 4,849,346 1999 3,915,499 4,642,604 1998 3,849,167 4,629,997 1997 3,520,635 4,281,778 1996 3,564,700 4,407,524 1995 3,788,200 4,772,657 1994 3,813,900 4,903,362

3.9.4 Imports and Exports
There is a large market for the import a nd export of home appliances. Each month AHAM publishes import and export data for certain home appliances. These data are released by the U.S. Census Bureau and aggregated by a th ird party. On the whole, major appliance unit imports decreased 1.0 percent in 2007 as compared to 2006. Major appliance unit exports increased 5.2 percent over the same period.

Table 3.9.6 shows selected import data from AHAM’s 2007 Preliminary Year End Import/Export Trade Report

. 30 For microwave ovens less than or equal to 22.5 inches in width, the number of units decreased, while the value of units increased. For microwave ovens 22.5 inches to 31.0 inches in widt h and coin-operated washing machines, both the number and value of units imported increased from 2006–2007. For non-portable cooking pr oducts and electric stoves, ranges, and ovens, the number of units imported decreased over the 1-year period, while the value of those units increased. For microwav e ovens less than 22.5 inches and greater than 31.0 inches in width, both the number and value of units imported decreased. Overall, the value of major appliance imports in creased 4.7 percent from 2006–2007.

3-28Table 3.9.6 2006–2007 Imports of Appliances Covered by this Rulemaking 31 Appliance Description Jan. – Dec. 2007 Jan. – Dec. 2006 % Jan. – Dec. 2007 Jan. – Dec. 2006 % Change Units Change $ Mil (Nominal) Non-portable cooking products 1,305,336 1,384,498 -5.7 371.312 351.130 5.7 Coin-operated washing machines 4,581 2,113 116.8 7.242 3.279 120.9

Microwave ovens ≤ 22.5 inches 5,773,979 6,006,978 -3.9 180.046 189.020 -4.7

Microwave ovens > 22.5-31.0 inches 4,093,919 3,793,086 7.9 196.056 174.112 12.6

Microwave ovens > 31.0 inches 7,188,969 7,649,158 -6.0 634.512 679.261 -6.6 Electric stoves, ranges, and ovens 2,554,770 2,813,383 -9.2 488.650 453.341 7.8

Table 3.9.7 shows selected export data from AHAM’s 2007 Preliminary Year End Import/Export Trade Report

. 32 For the 1-year period from 2006–2007, both the number and value of unit exports of non-por table cooking products and electr ic stoves, ranges, and ovens increased. For the same time period, the numbe r of coin-operated washing machines and microwave oven exports decreased, but the value of those exports increase d. Overall, the total value of exports increased 5.6 percent.

Table 3.9.7 2004–2005 Exports of Appliances Covered by this Rulemaking 33 Appliance Description Jan. – Dec. 2007 Jan. – Dec. 2006 % Jan. – Dec. 2007 Jan. – Dec. 2006 % Change Units Change $ Mil (Nominal) Non-portable cooking products 122,460 107,706 13.7 68.544 58.845 16.5 Coin-operated washing machines 88,382 95,246 -7.2 41.202 40.054 2.9

Microwave ovens 299,981 303,229 -1.1 36543 35.304 3.5 Electric stoves, ranges, and ovens 481,286 453,002 6.2 272.619 258.182 5.6

3.10 MARKET SATURATION

AHAM’s Fact Book 2005 presents the market saturation for cooking products . While the percentage of U.S. households with electric ra nges and/or cooktops and microwave ovens has decreased slightly since 2001, the market saturation of gas cooking products has increased. Table 3.10.1 presents the appliance saturation and percentage of U.S. households with each product as reported in the AHAM Fact Book 2005 . The number of U.S. households with each product is based on U.S. Census Bureau projecti ons of occupied units in the relevant year.

3-29Table 3.10.1 Appliance Saturation (Number in Millions) and Percentage of U.S. Households with Product 34

Product 1970 1982 1990 2001 2005

# % # % # % # % # % Electric Ranges / Cooktops* 25.8 40.6 48.4 58 58.4 62.6 69.2 66.3 71 65.3
Gas Ranges / Cooktops* 36.6 57.7 35.7 42.7 36.1 38.7 39.4 37.8 42.2 39

Microwave Ovens Neg. Neg. 21.4 25.6 77.2 82.7 94.6 90.7** 97.2 89.3

* Cooktops not included in 1970 or 1982 data ** Includes over-the-range and countertop microwave ovens

3.11 PRODUCT RETAIL PRICES
Table 3.11.1 presents the average retail prices (in nominal dollars) of several residential appliances and the Consumer Price Index (CP I) of each year (1982–84 = 100). Although prices for electric and gas ranges have increased since 1 980, the increase has been at a much slower rate than the annual rate of inflati on. Prices of microwave ovens and automatic clothes washers have decreased in the same time period.

Table 3.11.1 Residential Appliance Retail Prices 35

Product Average Retail Prices (Nominal $) Percent Change
1980 1994 2002 2005 1980–2005 Electric Ranges 412 503 508 444 7.8% Gas Ranges 380 499 497 462 21.6%
Microwave Ovens 450 239 145 99 -78.0%
Automatic Clothes Washers 386 394 426 359 -7.0%

Consumer Price Index * 82.4 148.2 179.9 195.3 137.0%
* U.S. Department of Labor, Bureau of Labor Statistics, Consumer Price Index: U.S. city average. 1982–84 = 100.

In the above table, automatic clothes washer s pertain to residential clothes washers, not CCWs. As a result, DOE conducted a limited se arch of consumer retail prices for CCWs by telephoning five commercial laundry di stributors and gathering data fr om four Intern et retailers. Table 3.11.2 summarizes the data collected by DOE. Most of the distri butors and Internet retailers provided a range of prices for each washer model. Only the average price for each model is provided in the table below.

3-30Table 3.11.2 Commercial Clothes Washer Retail PricesSourceSource TypeManufacturerBrandModel NumberCoin BoxLoadingAxisAverage PriceAbsoluteHome.com36InternetWhirlpoolWhirlpoolCAM2752RQYesTop-LoadVertical$749AbtElectronics.com37InternetGeneralElectricRoperRAK2751WWHYesTop-LoadVertical$597AbtElectronics.comInternetWhirlpoolWhirlpoolCAM2752WHYesTop-LoadVertical$688AbtElectronics.comInternetWhirlpoolMaytagMAT12CSWHYesTop-LoadVertical$898AJMadison.com38InternetWhirlpoolWhirlpoolCAM2752RQYesTop-LoadVertical$689Commercial & Coin Laundry Equip.39DistributorWhirlpoolWhirlpoolN/AYesTop-LoadVertical$700Commercial & Coin Laundry Equip.DistributorAllianceSpeed QueenN/AYesTop-LoadVertical$775Commercial Laundry Equipment40DistributorAllianceSpeed QueenSWTBA1WNYesTop-LoadVertical$965Gold Coin Laundry Equipment41DistributorGeneral ElectricGeneral ElectricWCCB1030FYesTop-LoadVertical$900Gold Coin Laundry EquipmentDistributorGeneral ElectricGeneral ElectricWCCB2050YesTop-LoadVertical$920Mac-Gray Services42DistributorWhirlpoolMaytagMAT12PDSWWYesTop-LoadVertical$895Texas Laundry Service43DistributorAllianceSpeed QueenJWT110, SWTB20YesTop-LoadVertical$1,113AbtElectronics.comInternetFrigidaireFrigidaireFCCW3000WHYesFront-LoadHorizontal$949Commercial Laundry EquipmentDistributorAllianceSpeed QueenSWFB61WNYesFront-LoadHorizontal$1,462Gold Coin Laundry EquipmentDistributorGeneral ElectricGeneral ElectricWCCH404VWWYesFront-LoadHorizontal$1,500Laundry Systems44InternetElectroluxWascomatWE16YesFront-LoadHorizontal$1,074Mac-Gray ServicesDistributorWhirlpoolMaytagMAH21PDAWWYesFront-LoadHorizontal$1,450Texas Laundry ServiceDistributorAllianceSpeedQueenSWRF961, SWFB63YesFront-LoadHorizontal$1,695AbsoluteHome.comInternetGeneral ElectricGeneral ElectricWNRD2050DWCNoTop-LoadVertical$649AbtElectronics.comInternetWhirlpoolMaytagMAT13MNWHNoTop-LoadVertical$769AJMadison.comInternetGeneral ElectricGeneral ElectricWNRD2050DNoTop-LoadVertical$529Commercial & Coin Laundry Equip.DistributorN/AN/AN/ANoTop-LoadVertical$850Commercial Laundry EquipmentDistributorAllianceSpeed QueenLWF02NNoTop-LoadVertical$531Gold Coin Laundry EquipmentDistributorGeneral ElectricGeneral ElectricWNRD2050DNoTop-LoadVertical$710Mac-Gray ServicesDistributorWhirlpoolMaytagMAT12PNNoTop-LoadVertical$795Texas Laundry ServiceDistributorAllianceSpeedQueenLWS01, LWS49NoTop-LoadVertical$740Commercial & Coin Laundry Equip.DistributorAllianceSpeed QueenN/ANoFront-LoadHorizontal$1,400Commercial Laundry EquipmentDistributorAllianceSpeed QueenLTF90AWMNoFront-LoadHorizontal$1,229Laundry SystemsInternetFrigidaireWascomatWE16NoFront-LoadHorizontal$923Laundry SystemsInternetAllianceHuebschFTZ91AWN11NoFront-LoadHorizontal$1,300Laundry SystemsInternetAllianceHuebschHWFT61NoFront-LoadHorizontal$1,475Mac-Gray ServicesDistributorWhirlpoolMaytagMAH21PNAWWNoFront-LoadHorizontal$1,350Texas Laundry ServiceDistributorAllianceSpeedQueenLTS90, FTS90NoFront-LoadHorizontal$1,6463-31DOE was unable to establish either the energy or water efficiency of all the washers for which it collected retail prices. Th erefore, a retail price and effi ciency relationship could not be established. But based on the price data collected, it was evident that price was a function of the type of loading ( i.e. , top-loading or front-loading.) Thus , DOE was able to determine a gross estimate of the retail price difference between a re latively inefficient t op-loading washer and a high-efficiency front-loadi ng washer. DOE also determined that price was a function of whether the washer was equipped with a coin box. As a result, DOE grouped the retail price data into four categories based on loading type and the pr esence of a coin box. To demonstrate the impact of the loading type and coin box on retail pri ce, Figure 3.11.1 depicts the price data listed in Table 3.11.2. Noted in Figure 3.11.1 is the average retail price of each of the four groups into which DOE segregated the data.

$500 $750 $1,000 $1,250 $1,500 $1,750

Top-LoadingConsumer Price Coin Box
No Coin Box

A vg Price = $824

A verage Price = $697 A verage Price = $1355 A vg Price = $1332

Front-Loading

Figure 3.11.1 Commercial Clothes Washer Retail Prices as a Function of Loading-Type and Presence of Coin Box

Figure 3.11.1 demonstrates that the averag e price difference between top-loading and front-loading washers varies between $531 for washers with coin boxes and $625 for washers without coin boxes. The above difference prov ides a rough estimate of the impact on current retail pricing from moving to a conventional top-loading washer ( i.e. , a washer with a verticalaxis agitator that submerges the clothes into a tub filled with water) to a conventional frontloading washer ( i.e ., a washer with a horizontal axis that tumbles the clothes through a pool of water.)

As will be shown in chapter 7 of the TSD, DOE used manufacturing costs developed for specific standard levels in combination with ma nufacturer and distributor markups, sales taxes, and installation costs to establish the total inst alled cost differences between baseline and more

3-32efficient CCWs. DOE used the above range in current retail price di fferences between toploading and front-loading washers as an indication of the reasona bleness of the total installed cost estimates that it developed for CCWs.

3.12 INDUSTRY COST STRUCTURE

DOE developed the household appliance industr y cost structure from publicly available information from the ASM, (Table 3.12.1 a nd Table 3.12.2) and the U.S. Securities and Exchange Commission (SEC) 10-K reports filed by publicly owned manufa cturers (summarized in Table 3.12.3). Table 3.12.1 presents the home appliance industry employment levels and earnings from 1994-2006. The statis tics illustrate a steady declin e in the number of production and non-production workers in the industry.

Because the ASM expresses all dollar values in constant 2006 dollars, the following table shows that as industry employment levels decline, the industry payroll is also decreasing. The percent decrease in total industry employees tracks closely with the percent decrease in payroll for all employees.

Table 3.12.1 Household Appliance Industry Employment and Earnings 45

Year Production Workers (‘000) All Employees (‘000) Payroll for All Employees (2006 $ Mil) 2006 60.0 69.7 2,644.0 2005 64.3 76.9 2,778.3 2004 69.4 83.7 3,068.8 2003 71.0 85.3 3,146.5 2002 73.5 88.8 3,334.1 2001 76.6 92.6 3,497.5 2000 82.7 99.5 3,815.2 1999 82.3 97.9 3,691.2 1998 82.4 99.5 3,716.3 1997 79.8 97.2 3,547.4 1996 87.1 108.1 3,798.1 1995 88.9 110.8 3,860.6 1994 90.4 110.4 3,846.0

Table 3.12.2 presents the costs of materials a nd industry payroll as a percentage of value of shipments from 1994–2006. The cost of material s as a percentage of value of shipments has fluctuated slightly over the 13-ye ar period. DOE notes that fluctuat ions in raw material costs are common from year to year. The cost of payroll for production workers as a percentage of value of shipments has declined since 2000. Similarly, the cost of total payroll as a percentage of value of shipments has declined since 2000.

3-33Table 3.12.2 Household Appliance Industry Census Data 46

Year Cost of Materials as a Percentage of Value of Shipments (%) Cost of Payroll for Production Workers as a Percentage of Value of Shipments (%) Cost of Total Payroll (Production + Admin.) as a Percentage of Value of Shipments (%) 2006 60.9 8.9 11.5 2005 56.9 8.3 11.0 2004 57.2 9.0 12.1 2003 55.9 9.2 12.5 2002 54.9 9.7 13.4 2001 56.8 10.1 13.8 2000 55.8 10.2 14.0 1999 54.7 10.2 13.9 1998 56.0 10.0 13.7 1997 52.8 9.9 13.6 1996 56.8 9.9 13.9 1995 57.7 9.4 13.7 1994 55.5 9.2 13.1

Table 3.12.3 presents the industry cost st ructure derived from SEC 10-K reports of publicly owned home appliance ma nufacturers. DOE averaged the financial data from 2002– 2007 of several companies to obtain an industry av erage. Each financial statement entry is presented as a percentage of total revenues.

Table 3.12.3 Industry Cost Structure Using SEC Data
Financial Statement Entry Percent of Revenues Cost of sales 81.3% Net income 1.7% Selling, general and administrative 12.8% Capital expenditure 3.3% Research and development 2.3% Depreciation and amortization 3.3% Net plant, property and equipment 18.7% Working capital 1.6%

A detailed financial analysis of each of the products c overed by this rulemaking is presented in the MIA. (See chapter 13 of this TSD. ) This analysis identi fies key financial inputs including cost of capital, working capita l, depreciation, and capital expenditures.

3-343.13 INVENTORY LEVELS AND CAPACITY UTILIZATION RATES
Table 3.13.1 shows the year-end inventory for the household appliance industry, according to the ASM. Both in dollars and as a percentage of value of shipments, the end-ofyear inventory for the industry has steadily declin ed since 1995. These data illustrate a general trend of domestic manufacturer s retaining less of their in ventories over time since 1994.

Table 3.13.1 Household Appliance Industry Census Data 47
Year End-of-Year Inventory (2006 $ Mil) End-of-Year Inventory as a Percentage of Value

of Shipments (%) 2006 1,688.5 7.4 2005 1,681.3 6.6 2004 1,853.4 7.3 2003 1,857.9 7.4 2002 1,997.2 8.1 2001 2,223.1 8.8 2000 2,511.9 9.2 1999 2,503.3 9.4 1998 2,698.4 10.0 1997 2,592.9 10.0 1996 2,842.7 10.4 1995 3,139.5 11.1 1994 3,252.8 11.1

DOE obtained full production capacity utilization rates from the U.S. Census Bureau, Survey of Plant Capacity from 1994–2006. Table 3.13.2 presents utilization rates for various sectors of the household applian ce industry. Full production capacity is defined as the maximum level of production an establishment could at tain under normal operating conditions. In the Survey of Plant Capacity report, the full production u tilization rate is a ratio of the actual level of operations to the full production level. The full production capacity utilization rate for household appliances in aggregate, along with the rates for cooking appl iances and household laundry appliances, show a decrease in utiliza tion from 1994–2006, although tr ends in subsets of that time period have fluctuated.

3-35Table 3.13.2 Full Production Capacity Utilization Rates 48

Year Rates (%) Household Appliances Cooking Appliances Household Laundry 2006 77 65 80 2005 74 57 79 2004 76 61 77 2003 78 57 85 2002 72 56 87 2001 70 50 90 2000 70 55 88 1999 75 59 87 1998 73 66 75 1997 73 61 80 1996 76 66 81 1995 79 66 83 1994 82 72 89

3.14 TECHNOLOGY ASSESSMENT
This section provides a technology assessm ent for residential cooking products and CCWs. Contained in this tec hnology assessment are details a bout product characteristics and operation (section 3.14.1), an examination of possible technological improvements for each product (section 3.14.2), and a characterization of the product efficiency levels currently commercially available (section 3.14.3).

3.14.1 Product Operations and Components
In preparation for the screening and engi neering analyses, DOE prepared a brief description of the characteristics and operati on of each product covere d by this rulemaking. These descriptions provide a ba sis for understanding the technologies used to improve product efficiency.

3.14.1.1 Cooking Products
Residential cooking products ar e appliances that enable th e homeowner to heat and cook foods by means of transfer of input energy to the food load. Input energy may be electricity, gas, or a combination of the two. Cooktops consist of a horizontal surface comprising one or more heating elements. A cooking vesse l is placed on the top surface of the cooktop over the element to facilitate heat tran sfer to the food load. In conven tional and microwave ovens, the cooking vessel is placed inside a cavity within which the energy transfer takes place. Ranges incorporate both an oven and a cooktop in a single unit.

3-36In a gas cooktop , pressurized natural gas or propane is supplied to each burner by means of an orifice and venturi on the underside of the cooktop surface. A sheet metal box encloses the array of burner supply lines as well as the contro ls for gas delivery and ignition, if provided. Primary air drawn from within the enclosure mixes with the gas at the vent uris and is delivered to the ports typically arrayed radially on the burners above the cooktop surface. Gas flow and thus burner turndown is controlled by individual, typica lly rotary, valves c onnected to the burner supply lines. Upon ignition of the gas-air mixtur e, secondary air is en trained near the burner ports to produce a substantially radial distributi on of flames. For sealed burners in which the cooktop surface interfaces directly with the base of each burner, all secondary air is introduced above the cooktop surface. Open burners can de rive some secondary air from the box as well. Grates positioned above the burners allow a cooki ng vessel to be placed at the proper spacing to ensure adequate secondary air for complete combustion, minimization of carbon monoxide emissions, and adequate convective heat transfer for cooking efficiency.

The simplest ignition scheme for a gas cookt op utilizes a standing pilot, through which a small amount of gas is conti nuously supplied and burned as the ignition source for the burners. Gas cooktops equipped with electr ical cords cannot have a consta nt burning pilot (42 U.S.C. 6295 (h)(1)) and instead utilize some form of electrically powered ignition, typically an intermittently activated spark igniter. An elect ronic control module may automatically energize the spark electrode whenever flame extinction is detected; otherwise the spark igniter must be manually reactivated by means of switches on the burner valve controls in the event of flame loss. Controls for the burners typically consis t of manual burner adjustment as dictated by the rotary valve position. In order to achieve very low firing rates associ ated with such cooking processes as simmering, melting chocolate, or heating delicate sauces, some cooktops incorporate electronic controls that cycle burners on and off.

An electric cooktop consists of a horizontal surface with one or more electrically powered heating elements located either above or below the cooktop surface. When the elements are located above the cooktop surface, the cooking vessel is pl aced directly on an element to heat the vessel and contents through conduc tive heat transfer. The elements are resistively heated by means of th e current supplied to them. An open coil-type cooktop utilizes a spiral-wound sheathed heating element. Removabl e drip bowls beneath each element serve as catch basins for spills. Solid disk elements c ontain a similar resistive element embedded in a flat, circular cast iron housing to provide a more even heating surface a nd greater cleanability than for a coil element. Due to this difference in cleanability, solid disk elements are classified as a separate product class from open coil elements.

Heating elements may also be located unde r a glass-ceramic cooktop surface. Such elements may be of a radiant, halogen, or inducti ve type, which will be described in more detail under the technology options in sect ion 3.14.2.1. Each of these technolo gies is categorized in the smooth cooktop product class along with solid disk elements. Electronic control systems are provided to energize the desired heating elements. These controls may incorporate algorithms for modulation of the element according to cooktop and cooking process parameters.

3-37Gas ovens are appliances designed to bake, roast, or broil foods within an insulated cavity by means of the combustion of natural gas or propane. The major components of the oven include the cavity, the gas burne rs, an ignition system, and a control system. If the oven incorporates a convection cooking mode, one or more fans are s ituated within the cavity to provide a means for forced-air distribution.

The oven cavity is a formed sheet metal enclosure with provision for holding cooking racks at varying positions. The interior surface of the cavity may be bare metal (stainless steel), or it may have a porcelain coating for durability and cleanability. Additives in the porcelain coating can provide catalytic conversion of food spilled on the surface under normal cooking temperatures, thus enabling a continuous cleanin g process. Alternatively, the oven may have features that allow it to be ope rated under a special self-clean mode, which heats the cavity to higher temperatures than those used for cooking. In the process, food spills are pyrolized, leaving an ash residue that is easil y wiped off when the cavity cools down.

Accessories such as lights and sensors for c ontrol of cooking processes are located within the cavity, while an insulated glass window in the oven door al lows observation of the cooking processes without requiring the door to be opened (which would incu r substantial heat loss). The outside of the cavity is wrapped with insulation to minimize heat loss to ambient surroundings. The space between the cavity and the outer sheet metal enclosure which is filled by the insulation typically is made as small as practically pos sible in order to maxi mize the cavity volume.

Gas burners are situated at th e bottom of the cavity for the bake function and the top for broiling. They are typically shield ed by baffles or covers to protect the burners from spills and to help distribute heat evenly. Broil elements may also be of a radiant type in which the combustion of the fuel-air mixture heats a perfor ated ceramic matrix or a metal mesh. As the ceramic or metal heats, it emits infrared radiat ion that can produce heating and surface browning of the cooking load. Combustion products from each burner and gases released during the cooking process are vented fr om the top of the cavity.

Ignition may be achieved through the use of a pilo t or a hot surface ignite r. In the case of a pilot, it may be a continuously burning standing pilot type, or an interm ittently actuated spark igniter may be used to light the pilot when the ove n controls are turned on. In either case, the pilot serves to heat a thermally-actuated switch that keeps the main gas valve open. With hot surface ignition, a ceramic heating element is pl aced in a location wher e the incoming gas-air mixture will impinge on it. As the element is heated electrically, its resistance goes down and current draw goes up. A bi-metallic gas valve in el ectrical series with the igniter deforms as its corresponding current increases, allowing gas flow as long as the hot surface igniter is energized by the burner controller.

Like gas ovens, electric ovens are designed to bake, roast, or broil food. The cavity is similar to those of gas ovens as well, in that the surface finishes may be bare or porcelainized, with or without the catalytic properties. In a ddition, electric ovens may incorporate a self-clean mode for pyrolysis of food matter on in the inte rior surfaces. Accessories and insulation tend to be similar between gas and electric ovens, and electric ovens also inco rporate venting, although

3-38the demands of such venting are lower than t hose for gas ovens since there are no combustion products.

The heat source for the cooking process is t ypically provided by radiant elements. Bake elements are located at the bottom of the cavity, a nd may be either exposed or covered to provide spill protection and improve cleanability. Broil elemen ts are situated at the top of the cavity. Far less common than radiant elements, halogen elem ents are also used to promote faster cooking.

An additional cooking feature on many electric ovens and certain gas ovens is convection mode, in which hot air within the cavity is circul ated by means of one or more fans to speed the cooking process, promote surface crisping, and increase cooking uniformity. Supplemental heating of this recirculated air may be acco mplished by means of a radiant heating element located near the fan.

Additional electrically-powered components in electric ovens may include cavity lights, electronic controls in corporating various types of displays, and cooking sensors.

A microwave oven is an appliance which heats foods and beverages through the conversion of electric energy to electromagnetic (microwave) energy. The food load is placed inside the oven where it is subjected to the microwave energy. In the portion of the electromagnetic spectrum where mi crowave ovens operate, typically 2.45 gigahertz, water, fats, and sugars have high absorptivity and thus food h eats readily. Glass, ceramic, and paper have low absorptivity at these wavelengths, while metals reflect the microwaves. Therefore microwave ovens efficiently heat foods wh ile the cavity and utensils remain cool.

The microwave energy is generated by an elec trically powered magnetron. Line voltage is converted to the high voltage required by the magnetron through the use of a high-voltage transformer. The microwaves are directed from the magnetron into the cavity via a metal duct, or waveguide. To produce a more uniform distribu tion of energy in the cavity, one or more sets of rotating metal blades may be inserted in the waveguide to alter the microwave patterns temporally. Additionally, a turnta ble or translating tray may be provided in the cavity to move the load and thus promote even input energy di stribution to the food. Some microwave ovens are equipped with electrically powered resistive or halogen heating elements for surface browning, and in the case of combination microw ave ovens, an additional fan for forced air distribution to enhance cooking performance.

To achieve reduced power levels for cooking processes such as de frosting, the magnetron is typically cycled at an appropriate duty cycl e which results in a time-averaged power at the desired level. Electronic contro ls may include a clock/timer function as well as a humidity or infrared sensor for detecting when the desire d level of cooking is achieved. Standby power consumption associated with these electronics , as well as the power supply, may be several watts. In addition, a light is typi cally provided that is turned on when the door is opened or when the microwave oven is in operation.

3-39Installation configurations include countertop and over-t he-range. Over-the-range microwave ovens may include a ventilation fan th at turns on automatically when the temperature from the cooktop below it rises; however, such an option is not required for certification under the Underwriters Laboratories (U L) Standard UL 923 - Edition 5, Standard for Microwave Cooking Appliances

.

3.14.1.2 Commercial Clothes Washers

Commercial clothes washers are appliances designed to clean clothes by using a solution of soap and/or detergent and water w ith mechanical agitation. Clothes washers use electricity to operate one or more pumps and to power an electric motor that agitates and spins the clothes. Clothes are washed, rinsed, and spun within a tub that is inside a cabinet. Because clothes washers require heated water for hot and warm water cycles, a separate water heater is typically needed to supply hot water. Most of the energy used by clothes washers is for water heating. Water is fed into the clothes washer through electrically ope rated water valves, one connected to a hot water suppl y line and a second connected to a cold water supply line.

Traditional top-loading clot hes washers have an opening on the top of the cabinet, covered by a door, which gives access to the inner bask et where the load to be washed is placed. The inner basket is typically pe rforated and is surrounded by a la rger outer tub which holds the water when the machine is running. The inner basket typically contains an agitator along a vertical axis, which undergoes a re versing circular motion. The motion of the agitator, which is powered by an electric motor, circulates the clot hes vertically from the bottom to the top of the basket. The spinning action of the inner basket and the drain pump are also powered by the motor. Traditional top-loading clothes washers use more water than other types of washers, and therefore, consume more energy during heated wa sh cycles. They also typically extract less water from laundry during the spin cycle, which results in longer drying time and greater energy consumption.

Non-agitator top-loading clothes washers may have a “wash plate” rather than an agitator to move the clothes within the basket. These top-loading clot hes washers function by partially filling the tub with water for wash and rinse cycl es and using very high spin speeds to extract rinse water from the clothes during the spin cycle. These top-loading clothes washers are more efficient in terms of water and energy than tradit ional top-loaders, but th eir high spin speeds that reduce drying time (and thus dryer energy consumption) may wrinkle clothing more than traditional top-loader spin speeds. These machines work best with low-foaming, high efficiency detergent.

Front-loading clothes washers ut ilize a cylindrical tub or dr um rotating on a horizontal or nearly-horizontal axis to wash clothes. Clothes are us ually loaded along the axis of the cylindrical drum, which has led to this type of cl othes washer to be called a front-loader. The clothes are cleaned by tumbling them in the water ( i.e ., clothes are lifted to the top of the drum by the rotation of the cylinder and then dropped into the water below.) The cylindrical drum is only partially filled with water for wash and rinse cycles. High spin speeds are used to extract the water from the clothes duri ng the spin cycles. These clothes washers are typically more

3-40efficient in terms of water and energy than trad itional top-loaders, but as for non-agitator toploading clothes washers, their high spin speeds may wrinkle clothing.

Although most clothes washers using a horizon tal-axis rotating drum are front-loading, they can be designed to be top-loading as well. In a top-loading hor izontal-axis design, the cabinet has a door at the top that opens above the washer drum. Another door that slides or pivots open then provides access to the inner drum.

Manufacturers typically base co mmercial clothes washers on existing residential clothes washer platforms. This simplifies fabrication and assembly ( i.e. commercial and residential clothes washers can be assembled on the same a ssembly line), and helps reduce the fixed costs associated with tooling, overhead etc. for the (t ypically) much lower commercial clothes washer manufacturing volumes. However, some commerci al clothes washer com ponents are selectively upgraded to make them more rugged, reliable, and vandal-resistant. Furthermore, the user interface is usually simplified (p resenting the commercial user with fewer wash choices than a residential user) and the control system is desi gned to interface with various payment systems (ranging from coin slides to magnetic card readers) . Lastly, the wash cycles may be redesigned to allow satisfactory operation in the commercial- standard 25-minute wash cycle, for example. However, some recent high-efficiency commercial clothes washer entrants feature wash cycles longer than 25 minutes, indicating that manufacturer s may not be able to meet such short wash cycles in conjunction with low water and energy consumption.

3.14.2 Technology Options
In order to gain a deeper understanding of the technol ogical improvements used to increase the efficiency of residential cooki ng products and CCWs, DOE identified several possible technologies and examined the most common improvements used in today’s market.

3.14.2.1 Cooking Products
DOE most recently analyzed energy conservation standards for cooking products in 1996 and 1997. In the 1997 analysis, DOE analyzed only gas cooking products to determine the technical and economic feasibility of eliminati ng standing pilots. DOE’s prior analysis in 1996, contained within the 1996 TSD for cooking products

, identified technologi es that have the potential for improving gas and elec tric cooking efficiency. DOE ha s considered all of these in this rulemaking. In addition, DOE identified low-standby-loss electr onic controls as a technology option for several cooking products, based on review of standby power data for microwave ovens and the assumed applicability to conventional cooking products as well.

For gas cooktops , DOE considered the technologies listed below.

3-41Table 3.14.1 Technology Options for Gas Cooktops 1. Catalytic burners 2. Electronic ignition 3. Insulation 4. Radiant gas burners 5. Reduced excess air at burner 6. Reflective surfaces 7. Sealed burners 8. Thermostatically controlled burners

Catalytic burners

Catalytic burners consist of a porous ceramic or refractory material such as glass or ceramic wool, impregnated with a catalyst. Th e gas-air mixture or ga s alone is fed to the catalytic matrix, whereupon additi onal ambient air diffuses into it. The catalyst, typically palladium or platinum, lowers the activation ener gy required for combustion such that the gas-air mixture subsequently oxidizes at temperatures below those normally required for combustion. This produces a uniform, low-intensity infrared radiation with no visibl e flame. The burners include an electric heating elemen t to preheat the catalyst prior to initiating operation. Catalytic burners in residential applia nces are investigated primar ily as a means of reducing NO x emissions, since NO x formation is highly temperature depe ndent. DOE is not aware of any commercialized catalytic burners fo r gas cooktops or efficiency data for applications of catalytic burners in cooking appliances.

Electronic ignition

Gas cooktops equipped without electrical power cords use a standing pilot ignition system. The energy factor of the cooktop can be increased by replacing the standing pilot system with an electronic ignition system . Actual burner efficiency is not affected by eliminating the standing pilot. The resulting incr ease in EF is due only to the d ecrease in the cooktop’s annual gas energy consumption attributed to the pilot gas consumption.

The most common type of electronic igniti on used by gas cooktops is an intermittent ignition system, where spark ignite rs replace the standing pilots. These igniters are controlled by switches on each burner valve. The switches are typically rotary-actuated so that when the burner valve is turned to the li ght position, a “starter” signal is sent to the control module. Alternatively, the signal can be generated by electronic controls on the user interface of the cooktop. Once the signal is received, the cont rol module activates the spark igniters. The control module can either be a supervised or an unsupervised type. Supervised modules require re-activation of the burner switc hes for cases where burner flames are accidentally extinguished. Unsupervised modules use a sensor located at the burner (often the igniter itself) to sense when the flame has been accidentally extinguished. The burner switches do not need to be reactivated, as the sensor sends a signal back to th e control module to reactivate the igniters. Though they cost more, unsupervised ignition sy stems are preferred ove r systems that use

3-42supervised control modules sin ce they prevent the need to ch eck accidentally extinguished flames. Most of the currently manufactured ga s cooktops that are equipped with intermittent ignition systems use unsupervised control modul es. Because of this , unsupervised control systems are the type of electronic igniti on devices being analyzed for gas cooktops.

It is important to note that intermittent ignition systems consume negligible amounts of electricity. Since the control module is powered directly from line voltage, there are no 24-volt transformer losses associated with it. The spark igniter is activa ted for an extremely short time period so that its cumulative on -time during the course of a y ear, and thus its electricity consumption, is negligible.

A recently introduced igniter technology utili zes a ceramic hot surface igniter in place of the spark igniter. With this type of ignition, the igniter may either be constantly energized whenever the burner valves are open, such as on a simmer setting where the burner is cycled on and off to achieve very low average input rates, or turned on in response to either initial burner gas flow or detection of flame extinction. Th erefore it may be considered an unsupervised system. Improved cooktop utility includes elim ination of the noise a ssociated with spark ignition. Energy consumption during usag e is higher than for spark ignition.

Insulation

Added insulation is only used in a gas c ooktop when it is installe d as a countertop unit (not above an oven). Here, the surrounding structures encompassing the cooktop might experience surface temperature problems that can be alleviated by adding insulation. Insulation underneath the cooktop reduces the surface temperature of all exposed non-cooktop surfaces to levels which meet UL requirements.

Of the information reviewed on effici ency improvements to gas cooktops, adding insulation was never analyzed as a method to improve cooktop performance. Manufacturers’ data from the previous rulema king provided no estimate of energy efficiency improvements from insulating gas cooktops.

Radiant gas burners

Radiant gas burners transfer heat through infrared radiation from the burner surface. The burner consists of a porous matrix through whic h a premixed gas-air mixture is fed. Upon ignition, the flames sit on the surface of the ma trix, heating the surface and causing it to emit radiation at infrared wavelengths. The burner is located under a glass- ceramic cooktop surface.

One form of radiant gas burners is termed the powered Infrared Jet-Impingement (IR-Jet) burner. In an IR-Jet gas burner, both radiant and convective energy are transmitted to the cooking vessel. A forced-draft combustion fan is used to deliver the fully-premixed gas-air mixture to available cooktop burners. At each burner, combustion occurs at the surface of a perforated ceramic tile. As the tile heats, it emits ra diant energy, principally in the far infrared

3-43regime. Combustion products are jetted through perforations in the glass-ceramic cooktop, delivering convective energy to the cooking vessel as well.

As reported in the 1996 TSD, the Gas Re search Institute (GRI) sponsored the development of the IR-Jet gas burner. With GRI’s sponsorship, the American Gas Association Laboratories (AGAL) worked with a range manufact urer to produce a working IR-Jet burner. However, the IR-Jet burner is not currently bein g marketed. Data collected from a boiling water test indicated that the AGAL-devel oped IR-Jet radiant burner is mo re efficient than a comparable conventional open burner. The boiling water test indicated a 16-percent in crease in efficiency

Another type of radiant ga s burner utilizes a silicon carbi de-fiber burner which emits radiation in the near-infrared spectrum. A pr ototype developed jointly by Tokyo Gas and Rinnai Corporation utilized su ch material in a glass-ceramic c ooktop that did not incorporate jet impingement. Instead, combustion products were vented from underneath a solid, nonperforated cooktop. Such a radiant burner relied entirely on radiant heat transfer and conduction from the glass-ceramic after it h eated up. In tests conducted accord ing to the Japanese Industrial Standard (JIS) S 2103:1996, Gas burning cooking appliances for domestic use , which is a water heating procedure, the efficiency was reported as 43.5 percent compared with an estimated 30 percent for traditional gas burners. 49

Reduced excess air at burner

The excess-air ratio is defined as the amount of air used in the combustion process of the gas burner divided by the amount of air necessary for stoichiometr ic combustion. Excess air is provided to ensure high-quality flame characteristics and to creat e a safety margin to ensure complete combustion is reached under all conditions . Reducing the excess-a ir ratio at the burner through redesign and shrouding can improve its effi ciency. This information was provided by the 1980 engineering anal ysis performed by DOE 50 in support of developing energy efficiency standards for a variety of consumer products, in cluding cooktops and ovens. This document does not specify how the burner should be redesigned and shrouded.

Reflective surfaces

Reflective surfaces for gas cooktops utilize highly polished or chromed drip pans underneath the burner. By reflecting some of the radiant heat of the burner back up to the cooking vessel, the efficiency of the burner is increased. The consumer must maintain the reflective finish by cleaning th e drip pans regularly.

Efficiency gains resulting from using refl ective pans are extremely small because gas flames and burners have minimal infrared emissi ons. The primary mechanism for heat transfer to the cooking vessel is conv ection. The efficiency incr ease was obtained from using manufacturers’ data provided by AHAM and report ed in the 1996 TSD. The data indicate that an efficiency increase of only 0.1 percent is re alized due to the inco rporation of reflective surfaces.

3-44Sealed burners

Unlike conventional (open) burners, the cooktop surface surrounding sealed burners interfaces directly with th e base of the burner. This results in a reduced amount of secondary air to the burner for combustion. According to the 1996 TSD, AHAM stated that sealed burners often have a lower gas input rating than convent ional burners due to th e reduction in secondary air. The sealed burner must obtain all of its se condary air from above the cooktop. In order to obtain sufficient air for proper combustion, it become s necessary to either raise the grate height or de-rate the burner. Contrary to these statements, a report from the 1983 International Gas Research Conference 51 states that the reduction in secondary air results in more primary aeration to the sealed burner. The increased primar y aeration allows for a reduced pan-to-burner separation and increased burner efficiency. Accord ing to the boiling water tests conducted in the report, the efficiency of conventional burners ranged from 42–48 percen t, while the sealed burner was rated at an efficiency of 53 percent.

Manufacturers’ data provided by AHAM were us ed to estimate the incr ease in efficiency due to sealed burners in the 1996 TSD. An effi ciency increase of approximately 2.0 percent was estimated.

Thermostatically controlled burners

Thermostatically controlled gas burners cont rol the gas flow to th e burner through the use of a sensing element that extends through an openi ng in the center of the burner. This sensing element makes contact with the bottom of the cooking vessel, detecting the temperature and controlling the input rate to the burner accordi ngly. If the cooking vessel has an uneven bottom in the area where the sensor is supposed to make contact, however, any type of useful temperature control is lost.

Thermostatically controlled burners were widely sold in the late 1950s and 1960s. But due to customer complaints on the operating ch aracteristics of the bur ner, manufacturers dropped this feature. As reported in th e 1996 TSD, manufacturers stated that the sensor’s electric element retains heat due to its mass. This results in the sensor being “fooled ” and causing delays in reaction time. These delays allow wide swings in the thermostatically controlled temperature. Manufacturers stated that even if improvements in sensor manufacturing resulted in no heat retention, the many existing variables a ssociated with the cooking vessel ( e.g ., vessel material, food mass, type of food) make the thermosta tically controlled burne rs’ utility and energy efficiency suspect.

For open (coil) element electric cooktops , DOE considered the technologies listed below.

3-45Table 3.14.2 Technology Options for Open (Coil) Element Electric Cooktops 1. Electronic controls 2. Improved contact conductance 3. Insulation 4. Low-standby-loss electronic controls 5. Reflective surfaces

Electronic controls

Electronic controls using sophisticated c ontrol algorithms can use the dynamic thermal properties of the element to turn off the energy input to the element just in time to “coast” to the desired final temperature without overshooting it.

Research has been conducted to determine the effect that electronic controls have on cooktop efficiency. Danish researchers, te sting breadboard versions of microprocessorcontrolled electric hotplates, found a 20- to 46-pe rcent energy savings in cooking a variety of foods with European recipes. 52

Improved contact conductance

The thermal contact resistance that arises fr om an imperfect contact between the cooking vessel and the open (coil) element can be reduced by improving the flatness of the element. An improved contact conductance allows for more heat to be transferred to the cooking vessel and, thus, an improvement in the efficiency of the element.

As stated in the 1996 TSD, manufacturers a sserted that they have worked on improving the flatness of the element and that the types th at are available currently are doing an excellent job. They also stated that the results obtaine d from DOE test measurem ents do not reflect the actual performance of the open element. The alumin um test block used in the test procedure is much flatter than actual cooking vessels. B ecause of the block’s very flat surface, test efficiencies will be higher th an those obtained from field m easurements using “real” cooking vessels. Therefore, according to the manufacturers, increases in efficiency that can be obtained by improving the contact conductance under DOE test conditions will not be realized under field conditions.

Sources used in assessing the efficiency ga ins that could be expected from improving the contact conductance in the 1996 analysis incl uded: (1) manufacturers’ data provided by AHAM; (2) a costing analysis of technology options for residential applia nces prepared by ADM Associates for Lawrence Berkel ey National Laboratory (LBNL); 53 and (3) an energy efficient electrical product knowledge base prepared by ORTECH International for the Canadian Electrical Association. 54 An additional comment 55 received from Arthur D. Little, Inc. (ADL) following the NOPR for the previous rulemaking reported that the major mechanism for heat transfer was physical contact be tween the vessel and co il, not contact pressu re. Averaging the

3-46data from these sources results in a relative e fficiency increase for this technology option of just over 3 percent.

Insulation

Added insulation is only used in an open (coil) element electric cooktop when it is installed as a countertop unit (not above an oven.) Here, the surrounding structures encompassing the cooktop might experience surface te mperature problems that can be alleviated by adding insulation. Insulation underneath the c ooktop reduces the surfa ce temperature of all exposed non-cooktop surfaces to levels which meet UL requirements.

Of the published information reviewed on efficiency improvements to open (coil) element electric cooktops, adding insulation was never mentioned as a method to improve cooktop performance. Manufacturers’ data provided no estimate of efficiency improvements from insulating cooktops.

Low-standby-loss electronic controls

Electronic controls may consume power even when the electric cooktop is not performing its intended function. Depending on the implem entation of the controller, standby power is required to enable the electronic controls to detect user input without the us er first having to turn on a mechanical power switch or to enable disp lays, illuminate switches, etc. Reducing the standby power consumption of electronic controls would reduce the annual energy consumption of the electric cooktop, but would not impact the energy consumption of the electric cooktop during operation.

Reflective surfaces

As described in the similar technology op tion for gas cooktops, this technology option utilizes highly polished or chromed drip pans underneath the heating element. By reflecting some of the radiant heat of the element back up to the cooking vessel, the efficiency of the element is increased. The consumer must maintain the reflective finish by cleaning the drip pans regularly.

Efficiency gains resulting from using reflectiv e pans are extremely small. The efficiency increase assumed in the 1996 TSD was obtained from data from the following sources: (1) manufacturers’ data provided by AHAM; (2) th e energy efficient elect rical product knowledge base prepared by ORTECH International for the Canadian Electrical Association; 56 and (3) the 1980 DOE engineering analysis for residentia l appliances. 57 Averaging the data from these sources results in an efficien cy increase of 1 percent.

For smooth element electric cooktops , DOE considered the tec hnologies listed below. Radiant elements, which were included in the 1 996 TSD, were not consid ered as a design option for this rulemaking because manufacturer data provided to DOE for the 1996 TSD indicated that

3-47this technology does not offer an efficiency improvement over the baseline according to the DOE test procedure.

Table 3.14.3 Technology Options for Smooth Element Electric Cooktops 1. Electronic controls 2. Halogen elements 3. Induction elements 4. Low-standby-loss electronic controls

Electronic controls

Sophisticated electronic contro ls can be applied to solid disk elements, radiant elements, and halogen elements to allow the element to “coast” to its final temperature. Electronic controls are not applicable to induction elements as the nature of its operation has no need for “coasting” controls. DOE is unaware of any efficiency data characterizing energy savings for electronic controls on smooth element cooktops. However, research previously cited suggests potential energy savings of this technology for open (coil) el ement cooktops and it is possible that similar energy savings could be achieve d for smooth element cooktops.

Halogen elements

Halogen elements transfer energy to the c ooking vessel by direct infr ared radiation from high-powered tungsten-halogen lamps. The ha logen element lies under neath a glass-ceramic panel and consists of one or more lamps installe d horizontally within a corrosion-protected metal dish. The bottom of the metal dish is insulated with microtherm insulation.

Radiant heating coils are commonly fitted around the halogen element to provide heat around the element’s edge. This results in a high ly responsive element that provides an even temperature distribution. Halogen elements can be configured to operate across a wide range of capacities. Parallel or seri es lamp arrangements can yiel d power outputs from 1200–2500 W. Halogen lamp technology reported in the 1996 TSD c onsisted of a circular lamp that can provide a more optimum temperature distribution than tradit ional straight lamps. This circular lamp has the trademark name of Haloring.

The 1996 TSD reported that with the con tinued development of halogen elements, efficiencies had increased. The circular halogen- lamp elements that had recently been developed at the time of the previous analysis could exceed the efficiency of solid disk elements as measured according to the DOE test procedure. Data provided for the 1996 rulemaking by a cooktop manufacturer were used to establish the efficiency gain of a circular halogen lamp element over that of a solid disk element. An efficiency increase of approximately 1.5 percent was measured. It is important to reiterate that this efficiency increase was only for the circular halogen lamp element. Other halogen lamp el ements might not yield the same efficiency increase. The same cooktop manufacturer mentione d above also provided efficiency data based on boiling water tests. These tests indicated that circular halogen lamp elements can yield even

3-48higher efficiency increases over th at of solid disk elements. Eu ropean manufacturers had also conducted boiling water tests indi cating that halogen lamp elem ents (the configuration of halogen lamp tested was not specified) are more efficient than solid disk elements. 58

Induction elements

Induction elements use a solid-state power supply to convert 60 hertz alternating line current into a high-frequency (approximately 25 kilohertz) alternating current. This highfrequency current is supplied to an inductor. Th e inductor is a flat spir al winding located just underneath a glass-ceramic panel. The high-frequency current, whic h is supplied to the inductor, causes it to generate a magnetic field which passes through the glass-ceramic panel unaffected and produces eddy currents in the bottom of the cooking vessel. The vessel must be made of ferromagnetic material, and the eddy currents that are generated within it cause it to heat up. Thus, the vessel essentially beco mes the heating element.

A sensor is placed between the inductor and the glass-ceramic panel, providing a continuous temperature measurement of the vessel bottom. Sensor s also enable the inductor to only heat objects of at least 4 inches in diameter . This prevents any small metal objects, such as forks or spoons, from accidentally being heated. In addition, since the glass-ceramic panel is unaffected by the magnetic field, it remains relatively cool, reducing the potential for accidental burns.

The primary advantages of induction elements are their fast response and control of the heat source, their ease of cleani ng, and their ability to heat vess els that are not flat. Because these features have usually been associated with gas burners, induction elements are being marketed in competition to them.

As just noted, the cooking vessel used with an induction element must be made from a ferromagnetic material. Since aluminum is not a ferromagnetic material, the current DOE test procedure, which specifies an aluminum test bloc k, cannot be used to rate this equipment. In 1978, the National Bureau of Standards (NBS), now called National Institute of Standards and Technology (NIST), developed a proposed method of measuring the energy consumption of induction cooktops. 59 The method is a modification of the current DOE test procedure. Energy use is determined by attaching a ferromagnetic ma terial to the bottom of the aluminum test block. This modification was never formally adopted by DOE, but a source was found that provided data on how a typi cal induction element performed under the proposed method developed by NBS. 60 An absolute efficiency of 84 percent was presented.

Low-standby-loss electronic controls

Electronic controls may consume power even when the electric cooktop is not performing its intended function. Depending on the implem entation of the controller, standby power is required to enable the electronic controls to detect user input without the us er first having to turn on a mechanical power switch or to enable disp lays, illuminate switches, etc. Reducing the standby power consumption of electronic controls would reduce the annual energy consumption

3-49of the electric cooktop, but would not impact the energy consumption of the electric cooktop during operation.

For gas and electric ovens , DOE considered the t echnologies listed below.

Table 3.14.4 Technology Options for Gas and Electric Ovens 1. Bi-radiant oven (electric only) 2. Forced convection 3. Halogen lamp oven (electric only) 4. Improved and added insulation 5. Improved door seals 6. Low-standby-loss electronic controls 7. No oven-door window 8. Oven separator 9. Pilotless ignition (gas only) 10. Radiant burner (gas only) 11. Reduced conduction losses 12. Reduced thermal mass 13. Reduced vent rate 14. Reflective surfaces 15. Steam cooking

Bi-radiant oven (electric only)

A bi-radiant electric oven system was deve loped by Purdue University for Oak Ridge National Laboratory in the late 1970s. 61 The objective of the project was to develop an electric oven that offered significant energy savings w ithout compromising food qua lity. The bi-radiant oven has three important features which provide improved performance: (1) the cavity walls are highly reflective rather than absorptive, there by allowing these surfaces to operate at cooler temperatures; (2) the heating elements, similar in construction to those in conventional ovens but operating at much lower temperatur es, provide a prescribed, balan ced radiant flux to the top and bottom surfaces of the food product; and (3) the baking and roasting utensils have a highly absorptive finish.

The bi-radiant oven was tested under a vari ety of cooking conditions (including the DOE test procedure) and also modele d (using computer thermal analysis programs) to determine its performance. It demonstrated a greater than 50 -percent increase in efficiency over that of a conventional oven. In addition, the separate upp er and lower heating elements required by the oven provided more flexibility in baking and roasting.

Several important practical c oncerns have to be addressed by manufacturers in order to realize the demonstrated energy savings: (1) the oven lining materi al must be durable enough to maintain the low-emissivity (less than 0.1) cavit y surface; (2) microproces sor controls must be used; and (3) as mentioned earlier, the baking and roasting utensils must have a highly absorptive

3-50exterior. However, given the assumption that al l of these criteria ar e met, the 1996 analysis assumed a 50-percent efficiency increase.

Forced convection

A forced convection oven uses a fan to di stribute warm air even ly throughout the oven cavity. The use of forced circulation can reduce fuel consumption by cooking food more quickly, at lower temperatures, and in larger qua ntities than a natural convection oven of the same size and rating. The fan is placed within the rear cabinet wall and a protective screen is placed around it. The screen prevents any items being placed in the oven from “knocking” into the fan and causing damage. The screen may also assist in distributing the heated air evenly throughout the cavity. Product liter ature from manufacturers indica tes that cooking times can be reduced by using forced convection cooking. 62 As a result, forced convection is widely used in electric ovens.

For gas ovens, GRI sponsored the development of two new types of ovens that incorporate forced convection cooking. Both ove n types, one an advanced countertop oven and the other an advanced full-size oven with pyr olytic self-cleaning, also have steam-cooking options. Research and development of the ovens was being conducted at ADL at the time of the 1996 TSD. Of the two oven types, development of the countertop oven was farther along. Test results indicated that countert op oven cooking times are as fast as those found in microwave

ovens. 63 More recently, multiple manufacturers have introduced gas ovens with convection fans.

Estimates from manufacturers, researchers, and published reports ( e.g. , the energy efficient electrical product know ledge base prepared by ORTECH In ternational for the Canadian Electrical Association 64 ) were included in the 1996 TSD analysis to establish the efficiency increase due to forced convection. Averaging th ese estimates results in a relative efficiency increase of 23 percent for gas self-cleaning ovens using for ced convection cooking. For gas standard ovens a value of 4.8 percent was used based on more recent GRI data. 65 Additional data submitted during the NOPR comment period of the 1996 analysis by ADL 66 showed an increase in efficiency for electric co nvection ovens of only 2.4 percent.

. It is also important to cons ider the added electrical ener gy consumption of the convection fan when determining the EF for ovens incorp orating convection cooking. The wattage of a typical convection fan motor is approximately 30 W. Since the duration of the DOE test procedure is approximately 30 minutes, the en ergy consumption of the convection fan is approximately 15 watt-hours (Wh).

Additionally, ovens can use convection elements in addition to resist ance and other types of elements to speed up the cooking process. By utilizing different cooking elements where they are most effective, such combination ovens can reduce the time and energy consumption required to cook food. For example, a convectio n heater and resistance element can provide rapid internal heating while a halogen element provides surface heating and browning. GE has introduced a line of combination ovens utiliz ing conventional resistance heating elements, convection heaters, and halogen elem ents, along with a microwave system. 67 GE claims that this

3-51technology can reduce food preparation times by 50 percent to over 75 percent, depending on the item being cooked. 68 However, it is unclear how much of th e benefit is attributable to the forced convection system alone.

Halogen lamp oven (electric only)

Halogen elements, similar to those used in electric cooktops, can also be used in electric ovens. This oven type was first introduced in Europe, but according to U.S. manufacturers, its acceptance has been slow in the United States. Manufacturers stated in 1996 that the cooking performance of the halogen lamp oven is relati vely poor compared to that of a conventional oven, though it might be advantageous for certain broiling applications.

Alternatively, a conventional oven can use ha logen elements in addition to resistance and/or convection elements to speed up the c ooking process. By utilizing different cooking elements when they are most effective, combination ovens such as the GE product described previously for the forced convection tec hnology option can reduce the time and energy consumption required to cook food. However, no data were found or submitted to demonstrate how efficiently halogen elements alone perf orm relative to conventional ovens.

Improved and added insulation

The efficiency of an oven can be increased by either improving the insulation or adding more insulation to the cabinet walls and oven door . Most models can accommodate 4 inches of insulation in the cabinet walls and door without requiring extensive design changes to the oven. Most standard models have 2 inches of low-density (1.09 pounds (lb)/ft 3 ) fiberglass insulation in the cabinet walls and door, while most self-cleaning ovens use 2 inches of high-density (1.90 lb/ft 3 ) insulation. Insulation is added primarily to pass UL surface temperature tests, which explains why self-cleaning ovens, which require high temperatures fo r pyrolysis, tend to have a more effective insulation package.

Data found in published papers and reports i ndicate that fiberglass insulation density levels do not exceed those found in self-cleaning ovens (1.90 lb/ft 3 ). Thus, while both the thickness and density of the insu lation can be increased in most standard ovens, only the thickness can be increased in most self-cleaning ovens.

Since the DOE test procedure does not requ ire maintaining heat in the oven over an extended period of time, manuf acturers stated in the 1996 ru lemaking that increasing the thickness or density of the oven’s insulation will demonstrate no energy savings. But data provided by several sources indicate that sma ll energy savings can be realized under the conditions of the DOE test procedure.

The following sources were used in the 1996 TSD to establish the efficiency increase from using a denser insulation (1.09 to 1.90 lb/ft 3 ): (1) manufacturers’ data provided by AHAM; (2) the costing analysis of desi gn options for residential appliances prepared by ADM Associates for LBNL; 69 (3) the energy efficient electrical pr oduct knowledge base prepared by ORTECH

3-52International for the Canadian Electrical Association; 70 and (4) the 1980 DOE engineering analysis for residential appliances. 71 Averaging the data from these sources results in an efficiency increase of 4.9 percent for standard gas ovens and 5.2 percent for standard electric

ovens.

Two sources of data were available which show ed an increase in efficiency due to adding more insulation (2 to 4 inches): (1) manuf acturers’ data provided by AHAM for the 1996 TSD and (2) the 1980 DOE engineering anal ysis for residential appliances. 72 Averaging these data points results in an efficiency increase of appr oximately 1.4 percentage points. However, GRI reported no change in energy c onsumption by adding insulation. 73

Improved door seals

Door seals for standard ovens generally consis t of a strip of silic one rubber, while selfcleaning ovens usually incorporate fiberglass seals. These seals are attached to the oven front frame and act as a seal for the door, which serv es to reduce the loss of hot oven air through the door. Because some venting is required for pr oper cooking performance, a complete seal on the oven is undesirable. But the oven door seals can be improved further without sealing the oven completely.

Data from the energy efficient electrical product knowledge base prepared by ORTECH International for the Canadian Electrical Association 74 were used to estimate the efficiency increase from improving the door seals. The da ta indicated that an approximately 7-percent increase in efficiency was possible for standard electric ovens and both standard and selfcleaning gas ovens. However, more recent data by GRI 75 show efficiency increases much less than the 7-percent value previously reported. A va lue of 1 percent, therefore, was used for the standard and self-cleaning gas oven analysis. The GRI report also point ed out the need for sufficient air flow though the oven cavity for pr oper heating and mois ture conditions while cooking.

Low-standby-loss electronic controls

Electronic controls may consume power ev en when the oven is not performing its intended function. Depending on the implementation of the controller, sta ndby power is required to enable the electronic controls to detect user input without the user first having to turn on a mechanical power switch or to enable displays, illuminate switches, etc. Since clock power is incorporated into the EF metric for both ga s and electric ovens, re ducing the standby power consumption of electronic controls would reduc e the EF. Low-standby-loss electronic controls can be implemented in a wide variety of ways.

No oven-door window

Most ovens and ranges come equipped with windows in the door. Using the window, the contents of the oven can be viewed without opening the oven door. But oven-door windows allow more energy to be lost through the door an d, thus, reduce the efficiency of the oven. It

3-53could be argued, however, that having no wi ndow in the door necessitates frequent door openings to check the contents of the oven. Th e lost energy caused by these door openings could offset any energy savings that would result from eliminating the door window.

GRI issued a topical report 76 which discussed this tec hnology option. The report was submitted as a written comment to the 1996 NOPR. GRI’s experimental tests showed a small savings in annual energy usage for both standard and self-clean ovens. However, they reported there could actually be a net energy loss due to c onsumer practices, which would be a function of the number of times a consumer would open the door to inspect the f ood while cooking. With four door openings per test according to the DOE te st procedure, a standard oven would realize a net energy savings of 34 kBtu/yr. For a self-c lean oven, however, GRI calculated a net energy loss of 3 kBtu/yr.

Oven separator

For loads that do not require the entire ove n volume, an oven separator can be used to reduce the cavity volume that is used for c ooking. With less oven volume to heat, the energy used to cook an item would be reduced. The oven separator considered here is the type that can be easily and quickly installed by the user. The side walls of the oven cavity would be fitted with “slots” that guide and hold the separator into position. Different pairs of “slots” would be spaced throughout the oven cavity so that the user could select different positions to place the separator.

Manufacturers’ data provided by AHAM indica ted that an absolute percentage point increase of approximately 0.82 is expected from using an oven separator in standard and selfcleaning electric ovens. For sta ndard and self-cleaning gas ovens, percentage point increases of 0.1 and 0.53 are expected, respectively. No other da ta were provided to demonstrate whether the efficiency increase should be any higher or lower.

As of June, 2008, oven separators have b een researched but ne ver been put into production.

Pilotless ignition (gas only)

Gas ovens equipped without an electrical power cord use a standing pilot ignition system. The EF of the oven can be increased by replacing th e standing pilot system with an electric or electronic ignition system. Actu al oven cooking efficiency is only slightly affected by eliminating the standing pilot. The resulting incr ease in the EF is primarily due to the decrease in the oven’s gas energy consumption during standby.

For gas ovens equipped with a power cord, there are two types of pilotless ignition systems: (1) a spark ignition system and (2) a “glo” ignition system. The spark ignition system uses a spark igniter to light a pi lot. The pilot in turn ignites the oven burner. The igniter is controlled by a control module, wh ich is activated when the thermo stat knob is set to a specific temperature. The igniter will spark until the pi lot is ignited, and the pilot will burn until the

3-54thermostat is turned off. If the pilot should accidentally be extinguished, a sensing circuit within the igniter will reactivate the control module and cause the ignite r to spark. The spark ignition system consumes a negligible amount of electri city. Since the control module is powered directly from line voltage, there are no 24-volt tran sformer losses associated with it. The spark igniter is activated for an extremely short time so that its cumulative on-time during the course of a year, and thus its annual electri city consumption, is negligible.

The “glo” ignition system uses a ceramic “glo”- type igniter. When the thermostat is set to a specific temperature, line voltage is applied to the igniter. Once energized, the igniter draws typically slightly over three amps and heats to a high temperature. In series with the igniter is a safety valve that is electrically activated. Once the igniter current drops to a pre-determined amperage, the safety valve opens, allowing gas to flow to the oven burner. The hot “glo” igniter then ignites the oven burner. Because the safety valve remains open only when the “glo” igniter is drawing the correct current, the igniter must continually dr aw power (typically around 400 W) to keep the burner ignited. 77 Thus the electrical energy consumption of a “glo” ignition system is significant. There are other type s of igniters which draw less wattage which are called “mini” hot surface igniters (H SI). Typical mini-HSIs draw about 50 W and one is reported to operate at 24 W. However, these low-wattage igniters draw less current than standard “glo” igniters, and therefore are below the threshold current needed to open the safety valve. A change in design of the control systems would be required to in corporate these mini-H SIs into cooking oven products.

Radiant burner (gas only)

Viking manufactures a gas oven with a ra diant burner for broiling functions. The infrared element is a metal screen heated by a burner until it emits infr ared radiation, rapidly heating food and searing the outside, while the conventional heat from the flame provides additional food heating.

Reduced conduction losses

Conduction losses from the oven can be re duced by upgrading the oven door. This upgrade includes an additional thermal break and a modified inner panel. In the 1996 rulemaking, manufacturers stated that with ex isting instrumentation, th e DOE test procedure cannot measure the small energy gains that can be obtained by attempting to reduce conduction losses.

However, manufacturers’ da ta provided by AHAM for the 1996 TSD indicated that a very small efficiency increase is possible. The data indicate that only an absolute percentage point increase of 0.05 is expected from reducing conduction losses. No ot her data were obtained to demonstrate whether the efficiency in crease should be any higher or lower.

Reduced thermal mass

3-55Energy is absorbed by the oven compone nts as the oven warms to its operating temperature. By reducing the amount of material used in co nstructing the oven, the amount of energy that is absorbed is reduced and hence th e efficiency increases. One method of achieving this thermal mass reduction is to reduce the gauge of sheet metal used in constructing the oven. Manufacturers asserted that th is type of thermal mass reduc tion was not possible without compromising structural integrity (during both use and transportati on) and increasing heat losses for electric and gas ovens manuf actured at the time of the 1996 TS D. Manufacturers stated that the oven walls must provide strong enough support to hold racks when baking heavy items ( i.e
., turkeys or large roasts) and that oven cavity me tal thickness could not be reduced any further without risking cracking a nd greater heat losses.

Several sources of data for the 1996 TSD indicated that a 10–20 percent reduction in thermal mass is possible. The sources, which stat e that an efficiency increase from reducing the thermal mass is possible, included the follo wing: (1) manufacturers’ data provided by AHAM; (2) the costing analysis of desi gn options for residential appliances prepared by ADM Associates for LBNL; 78 and (3) the energy efficient electric al product knowledge base prepared by ORTECH International for the Canadian Electrical Association. 79 GRI tests showed only a 0.58­ percent efficiency improvement for a self-cl eaning oven with an equi valent of 5.52 pounds of wall material removed. 80

Reduced vent rate

Oven vents function primarily to remove the moisture present during the baking process. Self-cleaning ovens have reduced vent diameter s to limit the air flow in accordance with combustion safety regulations during the high-tempe rature cleaning cycle. For safety reasons for the combustion process, the vent rate found in self -cleaning ovens cannot be reduced any further. But the vent rate of standard ovens can be reduced to the vent rate of se lf-cleaning ovens. This can be accomplished by either reducing the vent-tube size or adding a baffle. A reduction in vent rate causes a corresponding increase in efficiency.

Manufacturers stated in the 1996 TSD that re duced vent rates shoul d only be considered for standard electric ovens. The vent diameters of standard and self-cleaning gas ovens are not significantly different, since both oven types n eed to maintain a satisfactory combustion environment. With regard to standard electric ovens, manufacturers assert ed that vent sizes are unique to the design of the oven. The vent size is critical in maintaining the oven’s proper cooking and safety performance. According to th e manufacturers, mandating a specific vent rate would require most oven models to be redesigned in order to maintain thei r proper performance.

But manufacturers’ data provided by AHAM for the 1996 TSD indicated that the vent size of both standard electric a nd standard gas ovens could be re duced. Since all self-cleaning ovens are already designed with this technology, no new improvements are required by the industry to incorporate this technology option. Averaging the manufactur ers’ data with data obtained from the costing analysis of design options for residential appliances prepared by ADM Associates for LBNL 81 results in an increase of approxima tely 0.62 absolute percentage points for standard electric ovens and 0.5 absolute percentage points for standard gas ovens.

3-56Reflective surfaces

Oven efficiency can be improved by incor porating reflective surf aces onto the walls of the oven cavity. Reflective surfaces improve the oven’s performance by reflecting and retaining infrared radiation within the ove n cavity, thus increasing the percen tage of heat available to be transferred to the food load.

GRI performed tests on this technology option which resulted in a decrease in energy efficiency. 82 The reflective surface interfered with the convective currents and the thermostat, thus fooling the thermostat into cycling. GR I reported that increased reflectance from the chrome-plated inner surface of the oven caused re peated thermostat cycling that “might have contributed to the higher energy consumption,” which resulted in a 12.61-percent decrease in energy efficiency. ADL also commented that the reflected radiation is different from the normal radiation emitted by the oven cavities currently in use. 83

Based on these studies, it is uncertain whether, or how much, energy savings are realizable with this technology option. A smarter controll er for the oven seems to be a reasonable fix for the thermostat cycling proble m. However, there is a general lack of sophistication in the technology to maintain cl ean, reflective surfaces over the lifetime of the product. Manufacturers stated in the previous rulemaking that reflective surfaces degrade throughout the life of the oven, partic ularly for self-cleaning ovens.

Steam cooking

With steam cooking, energy is transferred to the food load by means of the condensation of steam on the food surface. This may take plac e at essentially atmospheric pressure, or the cavity may be pressurized in order to allow higher steam temperatures and thus higher energy transfer to the food. In order to maintain the proper envir onment regardless of pressure, a “steam-tight” oven cavity must be maintaine d. In addition, the use of steam involves considerably higher demands on the oven’s design and materials. Not only are different cavity materials required ( e.g. , temperature-resistant silicone seal s and chrome-nickel steel), but all incorporated elements and accessories have to be redesigned and intensively tested. Though incorporating steam cooking into oven designs is a difficult tas k, various manufacturers claim that there are advantages to using steam over conventional methods of cooking. Those advantages include saved energy and being able to retain more of the food’ s nutritional value. Energy is saved because food items that norma lly would need to be cooked separately ( e.g ., a meat roast in an oven and vegetables on a c ooktop) can be cooked together using the steam cooking process.

There are several electric ove ns with steam functions currently on the market. BSH Home Appliances has recently introduced the Gaggenau Combination Steam and Convection Oven. The oven utilizes a steam injection valve to control steam delivery to the cavity. The temperature and humidity level in the oven are us er-selectable to tailor the cooking process as needed. Speed cooking is not advertised as the primary feature of this oven. Rather, food

3-57quality and nutrition is the focus. The steam capab ility is described as allowing vegetables to be cooked while retaining texture and nutritional content, meat to be roasted without drying out, and leftovers to be reheated without the loss of flavor and texture often associated with microwave reheating. 84 Since this is a built-in oven, water deli very and condensate drainage are provided via plumbing lines much like a dishwasher. Along with Miele and Viking, Gaggenau also markets a steam convection oven which does not require any external plumbing. Instead, it utilizes a refillable containe r for water supply and collection.

While speed cooking is not the primary focus of steam ovens, there is evidence that there is time savings, particularly with larger f ood loads. Sharp’s count ertop Superheated Steam Oven, introduced in August 2004 85 and which incorporates steam generators with conventional resistive heating elements, is described as re ducing cook times for items such as chicken by 50 percent. 86

DOE is unaware of any efficiency data for steam ovens.

For microwave ovens , in the 1996 TSD, DOE considered all of the following technologies to improve EF, with the excepti on of cooking sensors, dual magnetrons, and lowstandby-loss electronic controls. DOE identified cooking sensors from product literature, while dual magnetrons were identified in the February 2006 edition of Appliance Design as a means to decrease cooking times. Low-standby-loss electroni c controls were identified by a review of AHAM data for standby power.

Table 3.14.5 Technology Options for Microwave Ovens – Energy Factor 1. Added insulation 2. Cooking sensors 3. Dual magnetrons 4. Eliminate or improve ceramic stirrer cover 5. Improved fan efficiency 6. Improved magnetron efficiency 7. Improved power supply efficiency 8. Low-standby-loss electronic controls 9. Modified wave guide 10. Reflective surfaces

Added insulation

Adding insulation to the outside of the reflective cavity wall of the oven would diminish heat flow through the walls. However, because the walls absorb a negligible fraction of the microwave energy, there is very little differen ce in temperature between the inside and the outside of the microwave oven. Also, during the short duration of the DOE test procedure, the microwave oven cavity walls do not heat up. Thus , the energy savings of this technology option would be so small as to be not measurable. 87

3-58Cooking sensors

Moisture or humidity sensor s can be incorporated into the microwave oven to detect the cooking state of the food load dur ing operation, inferred by the wate r vapor being released into the cavity. When the sensor detects that a desi red cooking state has been reached, the controller shuts off the microwave oven, thereby preventi ng excess energy consum ption in addition to optimizing food quality. However, DOE is unabl e to obtain any data to verify any energy efficiency impacts.

Dual magnetrons

Dual-magnetron microwave ovens use two ma gnetrons to distribute microwave energy within the cavity in order to more evenly heat food. Conventional microwave ovens use a single magnetron to generate microwaves, and may use a stirrer to distribute th ese microwaves within the microwave cabinet. In addition, most microw ave ovens use a turntable to rotate the item being heated in order to increase food heating uniformity. In order to vary the power of the microwave, the duty cycle of the magnetron is varied.

When food is heated unevenly in a microw ave, consumers must microwave items longer than necessary to ensure the en tire item reaches the desired te mperature. When a microwave oven uses dual magnetrons to more evenly distribute microwaves, this additional heating to ensure high temperature throughout the food may be reduced, reducing microwave energy consumption.

In addition to increasing warming uniform ity, dual magnetrons may reduce the need to cycle the single magnetron in most residential microwave ovens in orde r to modulate power. Cycling the single magnetron may increase wear on the magnetron, reducing its efficiency over its lifetime. Using two small magnetrons which together match the power of a single larger magnetron allows only one of these magnetrons to be engaged when then microwave oven is operated at reduced power levels. However, if both magnetrons share a single high voltage transformer, the decreased transformer efficien cy at partial loading may offset any magnetron efficiency gains from replacing a single cycl ed magnetron with dual magnetrons. DOE is unaware of any energy efficien cy data on dual magnetrons.

Eliminate or improve ceramic stirrer cover

Microwave ovens with fan-type mode sti rrers use a cover over the fan to prevent inadvertent damage to the fan when inserting or removing food and to prev ent degradation of the wave guide due to food splatter. Such mode ls (with browning elements) sometimes use a ceramic mode stirrer cover because plastic type s may not withstand the heat generated by the heating element during the browning operation. 88 These stirrers absorb some microwave energy but are needed to prev ent food splatter inside the wave gui de. Eliminating the ceramic cover would adversely affect consumer utility by requi ring cleaning of the st irrer or by reducing the life of the stirrer.

3-59Improved fan efficiency

Microwave ovens use either one or two fans. One fan is used to remove heat generated by the magnetron from the cavity. The second fa n would be used where mode stirring is accomplished by using slow-moving metal blades. This allows for better distribution of the microwave energy. Since power demand is very low (2–3 W), there is no opportunity for energy savings in models equipped with a second fan. Th e blower fan that is us ed to cool the magnetron and other electrical components uses about 25 W. Increasing the efficiency of this fan can reduce microwave oven energy consumption. Additional data submitted during the NOPR comment period of the previous rulemaking we re incorporated into the 1996 analysis. According to these data, the expected energy savi ngs would be less than originally reported and would have increased cost. These data were averaged with the original data and included in the previous analysis. The increase in efficiency is estimated to be 0.23 abso lute percentage points.

Improved magnetron efficiency

Magnetrons convert electrical energy input into electro magnetic energy at microwave frequency. The conversion efficien cy of a magnetron, also known as the oscillation efficiency, is expressed as output power divided by the power delivered to the anode. In the range of output powers typical of residentia l-scale microwave ovens ( 700–1300 W), nominal magnetron efficiency is approximately 73 percent. 89 Technologies are being investigated by manufacturers to increase efficiencies by several percentage points. Strategies to boost efficiency include improving the permanent magnet to reduce its demagnetization over time and reducing the magnetron dark current. Oscillation efficienci es of up to 78 percent have been reported. 90

Improved power supply efficiency

In order to operate a magnetron, a transforme r must be used to increase the input line voltage from 120 volts to about 4,000 volts. A cont roller, which may dissipate as much as 30 W, controls the power supply. There are two types of high voltage power supplies that are used in microwave ovens. The predominant type is the inductive-capacitance transformer, known as the LC power supply, which has an efficiency of about 82 percent. The other type is the invertertype, which is more expensive but ha s an efficiency of about 84 percent. 91 An improved power supply can be obtained through reduced losses in the controller and in the iron core of the transformer. An efficiency as high as 96 percent is theoretically possible, 92 but does not appear practicable at reasonable cost. Higher efficiency general purpose transfor mers do not have stable enough output power for microwave oven application. Earlier estimates of efficiency increase were 7 percent. However, data supplied by Sharp showed this estimate is much too high. 93 The value used for the current analysis is a 2.9- percent increase in power supply efficiency.

Low-standby-loss electronic controls

Electronic controls may consume power even when the microwave oven is not performing its intended function. Depending on th e implementation of the controller, standby power is required to enable the electronic contro ls to detect user input without the user first

3-60having to turn on a mechanical power switch or to enable displays, illuminate switches, etc. Reducing the standby power consumption of electronic controls would reduce the annual energy consumption of the microwave oven, but would not impact the energy consumption of the microwave oven during cooking operation. DOE is unaware of any standby power data to quantify the impact on energy savings.

Modified wave guide

Wave guides provide the interface betw een the microwave oven cavity and the magnetron. They have very high efficiencies in current models of microwave ovens. A small improvement (about 1 percent) is possible through the use of sp ecial coatings on the interior surface. 94 According to AHAM, the losses associated w ith the wave guide ar e typically less than 0.5 percent of the overall energy consumption. 95

Reflective surfaces

Microwave ovens are designed to have surf aces that are highly re flective of microwave energy. A high-grade stainless steel cavity would be more re flective than a painted or porcelainized cavity interior. Te sting by manufacturers has shown that high-grade stainless steel (or reflective material steel coa ting) would be more efficient th an painted cold-rolled steel by approximately 0.5 percent. 96

Although combination microwave ovens will not be analyzed due to difficulties in testing multiple cooking modes, a brief discussi on will be included due to the potential energy efficiency improvement and increase in consumer utility under real -world conditions.

One of the primary limitations of microwave cook ing is that the food lo ad heats internally faster than the exterior, which is in contact with the relatively co ld air in the oven cavity. This leads to an undesirable moisture distribution, where the exterior remains soggy when the interior is cooked. Therefore, methods ha ve been developed to combine microwave with other modes of heating to mitigate surface moisture accumula tion, provide a browning function that more closely replicates traditi onal cooking processes, and reduce overall cooking times.

Microwave and thermal or convection heati ng combines the featur es of a microwave oven and a conventional or conve ction oven. The GE Profile Ov en with Trivection utilizes electric radiant heating elements augmented by convection and microwave systems to speed cooking. While it is possible to cook in conven tional thermal mode with or without convection, the microwave function cannot be utilized alon e. According to GE, cooking times can be reduced by 50–75 percent compared to a conven tional oven for a wide variety of foods. 97 This oven is also advertised as compatible with al l types of cookware includi ng metal, glass, and
stoneware.

Microwave and jet air-impingement is the combination of microwave energy delivery plus high velocity hot air impacting the food load. This technology is wide ly used in commercial combination ovens for preparing such food products as pizzas. A residential version of this type

3-61of oven began shipping in the fourth quarter of 2006. r According to Appliance Design magazine, the TurboChef Speed Cook Oven cooks up to 15 times faster than a conventional oven. 98 The air jets are arrayed at th e top and bottom of the cavity, and those at the top pass through the magnetron mode stirrer fan to enhance uniformit y. The oven also employs dual magnetrons and top and bottom electric hea ting elements for faster heatup and broil functions.

For microwave oven standby power, DOE investigated technology options for decreasing standby power. DOE identified lower- power display technolog ies, cooking sensors with no standby power requirement, improved power supplies, improved control boards, and automatic power-down from research, literature review, and reverse-engi neering conducted as part of the microwave oven analysis di scussed in chapter 5 of this TSD.

Table 3.14.6 Technology Options for Microwave Oven – Standby Power 1. Lower-power display technologies 2. Cooking sensors with no standby power requirement 3. Improved power suppl y and control board options 4. Automatic power-down

Lower-power display technologies

Microwave ovens are generally constructed using one of the following display types to show clock time and other parameters: (1) vacu um fluorescent display (VFD); (2) backlit and non-backlit liquid crystal display (LCD); and (3) light-emitting diode (LED) display. Within the 32-unit sample that DOE examined as part of the supplemental microwave oven analysis, microwave ovens equipped with VFDs consumed the most power on average, followed by units featuring backlit LCDs, LED displays and non-back lit LCDs. Data gathered by DOE show that standby power levels between 1.1 W and 1.4 W have been achieved in microwave ovens using either LED displays or LCDs, and standby power as low as 1.7 W has been achieved using a backlit LCD. The lowest standby power observe d for a microwave oven with a VFD was 2.5 W. One display manufacturer stated to DOE that backlit LCDs can consume up to 50 percent less energy than VFDs in sizes applicable to mi crowave ovens, depending on the number of LED backlights used to light the disp lay. The manufacturer also stat ed that power requirements for LED displays are generally lower than for VFDs , but the difference depends considerably on the number of diode segments being lit.

The display format on each microwave oven can be characterized as either numeric, alphanumeric, or dot matrix. Whereas numeric displays can only show time, alphanumeric displays can also display letter s, though usually in simplified fo rmat. Dot matrix displays can show various fonts, letters, and symbols via matr ices of pixels, making th em the most flexible display technology. In the revers e-engineering analysis DOE conduc ted as part of chapter 5 of this TSD, DOE observed that LED displays fou nd in microwave ovens generally contain four numeric characters and a row of small words. LC Ds and VFDs allow for more flexibility in the

r For more information visit http://www.turbochef.com

.

3-62numbers and words being displayed by using al phanumeric characters without increasing the power requirements. LED displays could conc eivably achieve this, bu t would require more diode segments, increasing the cost of the disp lay. However, this would not affect standby power, assuming that in standby mode only the clock time is being displayed.

Cooking sensors with no standby power requirement

Cooking sensors detect that a desired cooking state of the food load has been reached and then signal the controller to shut off the microwave oven, thereby preventing excess energy consumption in addition to optimizing food qualit y. During product teardowns (see chapter 5 of this TSD), DOE found that the most common iden tifiable cooking sensors are absolute humidity sensors, which infer the cooking state of the f ood load from the amount of water vapor being released into the cavit y. This sensor technology requires st andby power in the range of 1–2 W to maintain a resistive heating element, whose conduc tivity changes in respons e to the presence of water vapor or other gases, at ope rating temperature. If the power to the sensor is switched off and back on, warm-up times in excess of two minutes may be required. Standby testing by DOE and AHAM revealed no microwave ovens with c ooking sensors that consume less than 2 W in standby mode. One Japanese microwave oven manu facturer stated during discussions with DOE that they are unaware of any humidity sensors th at do not require standby power to stay warm.

DOE has conducted research of cooking sens or technologies and ha s identified cooking sensors with zero standby power re quirements and little to no warm-up time. During the reverseengineering analysis for microwav e ovens (discussed in more detail in chapter 5 of this TSD), DOE observed that microwave ovens from one ma nufacturer use a piezoe lectric steam sensor which requires zero power in standby mode. Th is sensor technology f unctions by detecting a burst of steam created from moisture in the f ood as it cooks. Low fre quency (approximately 10 hertz) components of the output signal of the device correlate with th e amount of hot steam emitted from the load. In addition to steam sens ors, DOE has identified infrared and weight sensors with little to no warm- up time that do not consume standby power and that have been applied in microwave ovens currently on the Japa nese market. Infrared cooking sensors detect the temperature of the load in the field of vi ew of the sensing element. These sensors may require multiple elements or a motor to rotate the sensor in order to expand the field of view to accurately measure the temperatur e of the food load depending on wh ere it is placed in the oven cavity. Weight sensors determine the cooking stat e based upon the reducti on in weight of the food load, which results from mo isture evaporating from the load. DOE has also identified relative humidity sensors as a type of zero-sta ndby power sensor that can be applied in a microwave oven, but is unaware of any microwave ovens on the market that use this type of sensor. Lastly, DOE was made aware of an ab solute humidity sensor that requires no standby power, has zero incremental cost above that of a conventional absolute humidity sensor, and is in the process of being phased into production fo r a major microwave oven supplier to the US market.

Improved power supply and control board options

3-63A potential area for standby power improvement s is the power supplies on the control board. Multiple improvement paths with varying risk to manufacturers ar e available, including the selective upgrading of power supply componen ts to boost efficiency, the reduction of peak power demand through the use of lower-power co mponents, and the transition to switching power supplies.

Typically, microwave ovens incorporate unregul ated plus regulated control board power supplies. The unregulated portion consists of a small transformer, a bri dge rectifier, and an electrolytic capacitor. Voltage regulators then step down the voltage(s) to the level(s) required by the control logic, display, and cooking sensor . This approach results in a rugged power supply which is reliable, but typically has an efficiency of about 55 percent.

According to power supply topology expert s that DOE consulted, the quality of the transformer core material, diode type, capacitor qu ality, and voltage regulat or selection could cut no-load standby power for the power supply in ha lf and boost conversion efficiency from 55 to 70 percent. For a typical 5 W-output microw ave oven power supply, that no-load power consumption improvement is approximately 0.4 W.

Switching power supplies offer the highest conv ersion efficiencies ( up to 75 percent) and lowest no-load standby losses ( 0.2 W or less), though at a higher cost, higher part count, and greater complexity. Besides being as-yet unpro ven in long-term microw ave oven applications, switching power supplies greater complexity may also result in lower overall reliability and take greater care to implement. For example, am ong other issues, a switchi ng power supply can be prone to causing electromagnetic interference. DOE notes that there already are some premium microwave ovens on the U.S. market that incorp orate switching power supplies. However, due to the incremental cost of such a power supply over a conventional power supply and the price competition in the microwave oven market, it is unlikely that switching power supplies will find wider application unless low standby power budgets force manuf acturers to consider them.

Automatic power-down

Manufacturers could al so meet very low ( i.e. , less than 1 W) standby power levels according to the EISA 2007 and IEC 62301 definition of “standby mode” by incorporating an automatic function that turns off most power-c onsuming components once a period of inactivity has elapsed. Such a low-consumption state coul d be user-selectable on demand, or could be the default condition in which the microwave oven is shipped such that the consumer would be required to opt in to maintaining the display, cooking sensor, or other utility feature during standby. DOE has determined that some microw ave oven suppliers to the U.S. market have already taken such approaches to meet prescr iptive standby power standards in other markets such as Japan.

3.14.2.2 Commercial Clothes Washers

For commercial clothes washers , DOE will consider technologies taken from its most recent analysis of amended energy conservation standards for residential clothes washers as well

3-64as from information provided in recent trade publications. Other than the exceptions noted hereafter, the following technol ogies are taken from a 1996 repor t prepared for DOE, entitled Design Options for Clothes Washers

. 99 Steam washing and improved front-loading-washer drum design were identified in the September 2005 edition of Appliance Magazine

. 100 DOE identified the low-standby-power technology option during its engineering analysis review of all AHAM product classes. Spray rinse and advanced agitator technology options were added in response to comments received by DOE following the Framework public meeting.

Technology options that allow CCW platforms to potentially reach higher efficiency levels are listed in Table 3.14.7.

Table 3.14.7 Technology Options fo r Commercial Clothes Washers

1. Adaptive control systems 2. Added insulation 3. Advanced agitation concepts for top-loading machines 4. Automatic fill control 5. Bubble action 6. Direct-drive motor 7. Electrolytic disasso ciation of water 8. Front-loading design with recirculation 9. Improved fill control 10. Improved front-loading-washer drum design 11. Improved water extraction to lowe r remaining moisture content 12. Increased motor efficiency 13. Low-standby-power electronic controls 14. Ozonated laundering 15. Reduced thermal mass 16. Spray rinse or similar wate r-reducing rinse technology 17. Steam washing 18. Suds saving 19. Thermostatically controlled mixing valves 20. Tighter tub tolerance 21. Ultrasonic washing

Adaptive control system

According to the DOE test procedure (10 CFR part 430, subpart B, appendix J1), “an adaptive control system refers to a clothes washer control system which is capable of automatically adjusting washer operation or wash ing conditions based on characteristics of the clothes load placed in the clothe s container, without allowing or requiring consumer intervention or actions.” This technology op tion uses sensors to measure the soil load to adjust the wash temperature, agitation and/or tumble cycle time, number of rinse cycles, spin speed, and other parameters. Water and energy use can then be ta ilored to the load, thereby avoiding washing the clothes more than necessary. Although the DOE test procedure does not provide a means for

3-65determining the energy consumption of a clothes wash er with an adaptive c ontrol system, the test procedure does allow for specific field test procedures to measure energy consumption.

Residential clothes washers have used fu zzy logic to weigh laundry loads and regulate the length of the cycle, water leve l, number of rinses, and drying time. 101 Specific clothes washer designs have incorporated fuzzy logic to optimize the washing process while conserving water usage. The fuzzy-logic control determines th e absorbency of the items being washed at the earliest stage possible after the st art of the washing cycle. The system determines the correct water quantity for clear-water wa shing and subsequent rinsing. 102

Added insulation

This technology option adds insulation around the outer wash tub. Because some heat energy is lost through the shell of the clothe s washer, adding insulation around the outer tub slightly reduces the water temperature needed for a hot wash. However, since the wash cycle is relatively short and the thermal mass of the water is very high, there is very little change in water temperature from adding insula tion. Computer simulations pe rformed on a traditional toploading clothes washer for a 20-minute wash cy cle at 140 °F showed that adding 1 inch of fiberglass insulation relative to no insulation resulted in onl y a 1–2 °F increase in water temperature during parts of the wash. 103

Advanced agitation concepts for top-loading machines

Advanced agitation concepts replace the standa rd agitator found in tr aditional top-loading machines with an alternative mani pulator to agitate clothes and t hus mechanically remove soil. In the residential clothes washer market, these alternatives to agitators have taken different forms, including nutating plates, rotating disks, and side-mounted agitators. In some instances, such agitation concepts allow a top-loading wa sher to avoid the need to cover all clothes completely with water, rotating them in and out of the water-filled portion of the basket, muchlike front-loading washers. Advanced agitation systems add considerable complexity to a toploading clothes washer, and reside ntial clothes washers that feat ure these technologies are sold for prices comparable to front -loading clothes washers.

Since the DOE test procedure captures th e amount of water that a clothes washer consumes, the benefits of an advanced agitation concept washer can be directly measured and quantified via the WF. Potential energy savings are captured by the MEF as long as a portion of the washing cycle consumes heated water.

Automatic fill control

This technology option incorporates advanced control technologies to sense the clothes load and adjust the water level accordingly. Fo r a traditional top-loading machine, this may mean setting the water level to just submerge the clothes load. This technology option can overcome the tendency of consumers to manually se lect a water level greater than required for a given load.

3-66The implementation of this feature varies. Wh ile this feature is inexpensive to implement in all front-loading washers, top-loading wash ers do not benefit from the same advantages regarding drum geomet ry and rotation axis. s As a result, automatic fill control is typically only found in higher-end top-loading models that have electronic controls a nd proprietary designs, limiting adoption to a small percentage of the top-lo ading market. Energy is saved in either topor front-loading designs by reduc ing the amount of hot water us ed in the wash cycle.

Bubble action

Daewoo has developed an air-bubble washing ma chine. This machine uses a low-profile impeller typical in Asian-style top-loading wash ers and combines it with a six-winged, rotating pulsator shaped to direct water in four directions . This pulsator also di stributes air bubbles in different directions. The bubbles are generated by a vibrating bellows, which is driven by an electromagnet. Bubbles are reported to increas e the cleaning power of the washer in several ways: (1) by inducing a high-fre quency pressure fluctuation near the clothes, (2) by increasing the dissolution of detergent, (3 ) by increasing the amount of dissolved oxygen which increases the activity of the detergen t, and (4) by lowering the vi scosity of the wash water. 104, 105 Daewoo washers that utilize air-bubble wa shing action are available in th e European market, but are not available to U.S. consumers. 106

Sharp also developed a bubble washer in which the bubble-generati ng device uses neurofuzzy-logic controls. From a nozzle located at the bottom of the washer, air bubbles are generated by a computer-controlled pulsator and circulated upward in vertical and horizontal swirling motions. The controls ad just the amount of water used, so that a single-tub design that washes the same load size as a conventional dual- tub (inner and outer) co nfiguration uses only. 70 percent as much water and detergent. 107 Although it is mentioned on the manufacturer’s website, this washer is not available in the U.S. 108 Standardized and independent tests have yet to be conducted on the performance of the bubble- action system; therefore, the energy savings potential and wash performance of th e bubble-action technology option is unknown.

Although bubble washing has been incorporated into commercial products in Europe and Asia, production is still extremely limited and fu rther commercialization in the U.S. would require manufacturers to devel op entirely new platforms.

Direct-drive motor

This technology option is primarily intended fo r use in traditional top-loading machines. A traditional top-loading clothes washer uses an induction motor, a mechanical transmission, and

s Front-loading washers can incorporate a fill switch in the sump to monitor water levels as the wash basket and its contents are rotated slowly at the beginning of the wash cycl e. As dry clothes drop into the wash water, they absorb some of it and the water level in the sump drops. The fill switch then opens the fill valve( s) to raise the water level until the sump is full again. This approach does no t work with top- loading washers because the clothes are always immersed in the water. Proprietary solutions have been implemented on some top-loading washers, however.

3-67sometimes a pulley belt. A direct-drive motor can replace this conventional motor/transmission system. Rather than using a be lt and/or transmission, a motor coul d be directly connected to the agitator, thereby avoiding transmission (gear box) losses. In the past, Eaton, a motor manufacturer, claimed that this will result in less mechanical energy required, i.e. , less energy needed to run the agitator motor. This is accomplished by using a brushless direct-current (BLDC) motor with el ectronic controls.

Potential differences in cleaning performance due to the direct-drive substitution were not measured by Eaton. In addition, other parameters such as cycle time or spin speed were not held constant in a comparison test with a conventiona l washer. For the machines tested, Eaton found savings of about 140 Wh per cycle, or 64 percent of motor energy use 109

. In the past, some manufacturers have stated that a limiting performance factor for this technology option was physical size . However, GE uses direct-drive motors on some of their residential top-loading washers. 110 Fisher & Paykel manufactures two top-loading direct-drive washing machines available in the U.S. market. 111 Some front-loading machines also use a direct-drive motor, includi ng models manufactured by LG. 112

Electrolytic disassociation of water

The goal of electrolytic disassociation of water is to reduce hot water usage by substituting the electrolytic production of bleachi ng agents for activation of bleaching chemical reactions in detergents by hot wa ter. A prototype clothes washer with electrolytic disassociation of water has been successfully tested. 113 Although commercial deterg ents perform better at high temperatures, the same hypochlorite concentrati ons obtained by adding bleaching agents to water can be achieved at low temperatures if the ag ents are produced by elec trolytic disassociation within the machine. The bleaching action is due to the chemical reaction of the oxygen (derived from the chemical decomposition of the hypochlorit e) with the insoluble organic compounds that constitute the soil in the clothe s. Together they make solubl e compounds that are dissolved in the water.

Electrolytic disassociation was tested in a laboratory electrochemical cell. Mediumsoiled clothes and white materials were used in the test. The washing cycle test compared the energy consumption of electrolytic cleaning versus conventional detergents. The first test cycle, utilizing electrolytic action, was performed by ad ding four grams per liter of salt to the roomtemperature wash water in the machine. The second test cycle was run with a commercial detergent at a wash water temp erature of 95 °F to 113 °F. For both wash methods, a normal cycle was run. Initial tests showed that energy use dropped from about 2.65 kWh/cycle for a typical washing machine to 1.35 kWh/cycle fo r the new electrochemical method. This technology is still at the research stage.

In the past, manufacturers have stated that electrolytic di sassociation is not a workable approach. Primary concerns are negative eff ects on garments resulting from the bleaching process and poor consumer acceptance due to th eir inability to cont rol the chemistry and temperature in the wash portion of the cycle. 114

3-68Front-loading design with recirculation

This technology option for front-loading washer s uses a small pump to recirculate water out of the sump and spray it into the drum. Th e small amount of standing water in a standard front-loading washer is thus furt her minimized. Less hot water is needed per wash cycle, thereby saving energy.

In the previous residential clothes wash er rulemaking, manufacturers commented that they have not been able to verify th at a savings exists with recirculation. 115 Limiting factors mentioned by these manufacturers include (1) soil removal, (2) tangling, (3) cycle time, (4) rinsing, and (5) suds sensitivity.

In the past, Electrolux has produced mode ls that sprayed 8 liters per minute of water/detergent solution into the drum by means of a supply valve above the door. 116

Improved fill control

This technology option is defined as impr oving the tolerance on ex isting wash-water fill sensing, which can be accomplished by reducing tolera nces of presently used pressure sensors or improving switch design. This technology option relates primarily to top-loading washers, although it is sometimes applicable to front-loadi ng washers, depending on the fill control used on the washer design.

In a traditional top-loading washer, one end of an air hose is connect ed to an air chamber near the bottom of the washer tub and the other end is connected to a pressure switch. As water fills the tub, air in the hose and chamber is forc ed into a smaller volume, thereby increasing the air pressure. The air pressure increases until it activates a pressure switch, which in turn shuts off the water inlet valve. A more accurate wate r-level-setting system would avoid overfilling the wash tub, thereby reducing the amount of water and energy used. In the past, manufacturers have stated that they were not aware of a ny opportunity to reduce tolerances of pressure
117 sensors.

Improved front-loading-washer drum design

Manufacturers of front-loading wa shers continue to research and modify existing drum designs to improve wash performance, reduce ma ss, and increase spin speeds. With each drum revision, manufacturers frequently make claims that their drum designs increase consumer utility by being gentler on clothes or by reducing the cy cle time through better agitation of the clothes in the washer. A reduction in cycle time woul d have a measurable impact on washer power consumption, just as drums that can sustain hi gher spin speeds can reduce the remaining moisture content (RMC) and thus raise the MEF of a washer.

RMC is defined as:

3-69( WC

− WI ) RMC = WI

where WC is the weight of the test cloth immedi ately after completion of the washer spin cycle, and WI is the “bone dry” wei ght of the test cloth.

Implementation of this technology option vari es, with drums featuring special paddles, drum-wall textures, or similar enhancements.

Improved water extraction to lower remaining moisture content

There are several ways to reduce the RMC, in cluding: (1) increasing the spin speed of the wash basket for the final spin cycle; (2) cha nging the direction of ro tation to more evenly distribute clothes; (3) having a longer spin cycle; and (4) in creasing the size or number of drainage holes in the washer drum. Since mech anical water removal is more energy efficient than using heat to dry, energy consumption for the combined wash and dry process is reduced.

The DOE test procedure assumes that the im proved-water-extraction feature will not be used for 25 percent of all wash cycles. Since th is feature can be consumer selectable, clothes subject to wrinkling can be washed with a conve ntional spin-cycle option to avoid a wrinkling problem. Some manufacturers in the past were doubtful that RMCs of 35 percent and 30 percent could be practically obtained

. At the time of the 2001 TSD, laboratory testing was conducted to ascertain RMCs on commercially-available front-loadi ng washers. Measured RMCs ranged from 49 percent to 36 percent with a 50/50 cotton/polyester cloth load. For the same test load, a top-loading machine had a 52 percent RMC. The washers for the above testing were loaded at 3 lb/ft 3 of basket capacity. 118 The DOE test procedure, however, specifies the test load as being closer to 4 lb/ft 3 of basket capacity. Since the size of the cloth te st load has an effect on the RMC achieved, it is unknown whether the above laborator y-tested machines can achieve their stated RMC values under DOE test conditions. As of the 2001 TSD, cl othes washers with a certified RMC of up to 40 percent were available. 119

RMC data are no longer required to be pub lished because the current test procedure requires the publication of only th e MEF and WF for clothes wash ers. RMC data can be found in the CEC CCW database, but this database does not cover all CCWs on the market, nor is it completely current. Thus, DOE is unable to determine the water extraction capabilities of all CCWs that are currently on the market. Supporting the 2001 TSD manufacturer comments indicating skepticism towards ach ieving practical lower RMC va lues, none of the clothes washers listed in the CEC CCW database has an RMC below 39 percent. Top-loading CCWs typically feature an RMC of about 50 percent, while front-loading clothes washers typically feature an RMC of about 40 percent, according to the DOE test procedure.

Increased motor efficiency

3-70About 10 percent of the total electrical energy consumed by a typical clothes washer is used by the electric motor. The typical washing machine has a 1⁄2 – 2⁄3 horsepower motor. In the past, a residential clothes washer manufacturer st ated that replacing a split-phase motor with a capacitor-start motor may increase the efficiency of the motor by 10 percent. 120 Permanent magnet motors offer even higher efficiencies, tho ugh the benefit of a highe r efficiency motor has to be balanced with the higher cost and the re latively small contribution to the overall energy consumption per wash cycle from the motor itself.

Low-standby-power electronic controls

Electronic controls may consume power even when the clothes washer is not performing its intended function. Depending on the implem entation of the controller, standby power is required to enable the electronic controls to detect user input without the us er first having to turn on a mechanical power switch or to enable disp lays, illuminate switches, etc. Reducing the standby power consumption of electronic controls would reduce the annual energy consumption of the clothes washer, but would not impact the energy consumption of the clothes washer during operation. Low-standby-loss electr onic controls can be implemented in a wide variety of ways. DOE is unaware of any data demonstrating energy savings associated with low-standby-power designs for CCWs.

Ozonated laundering

Ozonated laundering systems are available fo r large-scale commercial or institutional use. The ozone, manufactured from ambient air, is injected into the water. There is some debate as to how the process of the ozonated cleaning exac tly works. Some claim the ozone reacts with soluble soils, making them insoluble, after which the mechanical action of the washing separates the soils from the fabric. One manufacturer prop osed that the energy inherent in ozone reduces water tension, making the water a better solvent. Energy is saved with this system because the water is not heated for lightly to moderately soiled laundry. In fact, colder water retains a higher concentration of ozone for a longer time than warmer water. For heavily soiled laundry, temperatures of 100–110 °F are used, which are lo wer than the temperatures required in a conventional washer. Also, since fewer chemicals are used, the rinse time is minimized, thereby reducing the total cycle time and water consumpti on. Economical ozone production is critical to the potential energy savings. One manufacturer estimates savings of 25 percent on “utility expenses” with installation of its system. 121 However, in addition to the ozone generator, a new or reprogrammed controller would be required, adding to the co st of this technology option.

Reduced thermal mass

This technology option uses a plastic tub specially designed to minimize the thermal mass that is heated by the water. Tests by manuf acturers indicate that very little energy can be saved this way because the bulk of the thermal mass is contained in the hot water itself. One manufacturer compared the impact of both por celain-enameled steel and polypropylene outer tubs on water temperature. Both machines were filled with 16 gallons of 140 °F water and

3-71agitated for 10 minutes. After 10 minutes, th ere was no significant difference in water temperature between the two mach ines. Calculations show that if there were no heat losses through the outer tub, the equilibr ium temperature for the tested steel tub described above would be 138.9 °F. Therefore, there is little to be gained by decrea sing the thermal mass of the outer tub. 122

Plastic outer tubs are commonl y used by manufacturers and can be considered as part of the baseline model. There is no practicable wa y to manufacture washing machines with plastic tubs with a lower thermal mass beyond the current practice.

Spray rinse or similar water-reducing rinse technology

Traditional top-loading clot hes washers immerse the clothi ng completely in water during the wash and rinse phases of the cleaning cycle. Spray-rinse systems eliminate the immersion requirement by spraying rinse water into the drum while the wash basket is rotating. The centrifugal force of the rotating ba sket pins the clothes against th e outer walls and subsequently forces the rinse liquid through the cl othes. In the process, the ri nsing liquid picks up remaining suds and transports them into the sump, from whic h they are drained. Since immersion or partial immersion is no longer necessary, le ss rinse water is required. When using hot rinse water, this reduces energy consumption by redu cing the amount of hot water required for the rinse cycle. DOE is unaware of any commercial top-loading cl othes washers currently available that utilize spray rinse.

Manufacturers caution that spray rinse or similar rinse-water reduction technology options are not embraced by all customers. For example, spray rinse technologies allegedly do not function well if a washer is overloaded, requiring a consumer behavior change which is more easily achieved in a residential than a commerci al setting. Previously available top-loading CCWs with spray rinse technology were w ithdrawn from the market, though another manufacturer recently introdu ced a spray-rinsing CCW.

AHAM may develop a rinse performance standard for clothes washers that could preclude the use of rinse-water reduction technologies. The current DOE test procedure, though, captures the benefit of this te chnology option, as any reduction in water consumption improves WF and any reduction in heated water consumption improves MEF.

Steam washing

With steam washing, steam is sprayed on th e laundry to help cl ean and sanitize the clothes without requiring the tub to be filled with water that is heated to sanitizing temperatures. Since less water must be heated to complete a steam washing cycle compared to a traditional washer, which immerses clothes in hot water, steam washing can reduce the energy and water consumption of clothes washers. 123

3-72LG began offering two residential clothes wa shers in the U.S. market that use steam washing in 2005, and Whirlpool launched a stea m clothes washer in the United States in 2008. 124,125 All models are ENERGY STAR-qualified.

Suds saving

A suds-saving feature allows water from one wash cycle to be reused in the next wash cycle. After agitation, sudsy wash water is pumped into a separate storage tub, remaining there until the next wash cycle. While the water is stored, soil settles to the bottom of the tub. During the next wash cycle, all but an inch of the wa ter is pumped back into the washer tub for use again 126 . Manufacturers believe that there is low consumer demand for this option and it would therefore not be used often. In addition, th is option cannot be used for all loads or soil conditions. This option is useful only when there is more than one wash cycle per load of laundry, e.g. , a pre-wash (which is not typically the case), or if the consumer washes more than one load in sequence. Subsequent washes coul d receive diminishing benefits if they are not completed immediately after the previous load, si nce the water in the hol ding tub would cool if left standing too long. Another limiting perf ormance factor mentioned by more than one manufacturer for this technology option was soil removal. In addition, because this option requires an adjacent external wash tub to store su ds in between wash cycles, consumer utility is affected. In a commercial setting, this could limit the number of clothes washers that may be installed.

This technology option is no longer commercially available. Electrolux formerly had a residential model that saved water from the final ri nse of one load to use again as the prewash of the next cycle 127 . Maytag had also featured this technol ogy as a water saving option on one of its washers. However, neither model is still in production.

Thermostatically controlled mixing valves

Thermostatically controlled water valv es (TCWVs) are defined by the DOE test procedure as “clothes washer controls that have the ability to sense and adjust the hot and cold supply water.” This technology option achieves energy savings by more accurately controlling inlet water temperature for hot and warm fills. In a typical non-thermostatically-controlled water inlet system, two solenoid valves are used; one valve opens for hot water fills while the other opens for cold water fills. Both solenoid valves are opened if a warm water setting is selected. In the warm wash mode, fixed fractions of hot and cold water are controlled by flow-control devices. For example, a manufacturer may decide to specify warm water as 50 percent hot water and 50 percent cold water. To reduce hot wate r energy use, some manufacturers have reduced the warm water temperature by using other ratios such as 40 percent hot and 60 percent cold.

Energy can be saved with a TCWV by either reducing the hot water temperature and/or reducing the warm water temperature. For exampl e, the TCWV could be used to lower the hot wash temperature from 135 °F to 130 °F by mixi ng hot water (at 135 °F test inlet conditions) with cold water. Warm water temperature coul d be similarly reduced. The energy savings can

3-73vary widely depending on the test standard’s specified inlet hot water temperature and the selected temperature of the warm water.

The TCWV technology option ha s the potential to oversta te the real-world energy savings, depending on the proximity of the water h eater to the installed clothes washer. When tested under laboratory conditions, the clothes washer is typically close to the hot water source, whereas this is generally not the case in either a residence or commercia l laundry setting. As a result of the distance between the hot water source and the clothes washer, there is a temperature drop due to line losses. Because of these line losses, a clothes washer with a TCWV may use more hot water than predicted on the basis of laboratory testing. Similarly, in a real-world application, savings will also vary with the temperature of in coming cold water. The unheated water temperature will vary with both geographi c location and time of ye ar. More energy would likely be saved in cases of warmer “cold” suppl y water, as a TCWV w ould then reduce the amount of time a hot water valve is open. The amount of savings is also dependent on the set point of the TCWV, the water heater set point, th e temperature selection of the wash (hot or warm cycle), and the location of the sensing th ermostat controlling the inlet water valves. A limiting performance factor mentioned by more th an one manufacturer is soil removal with lower wash temperatures.

Tighter tub tolerance

This technology option reduces the annular volume between the i nner wash basket and the outer tub. This annulus fills with water, but does not add to the clothes washer capacity. Having less space between the inner wash basket and the outer tub reduces the amount of water required for a fill, thereby saving the energy required to heat that water. This option applies primarily to traditional top-loading washers. In a high-efficiency top-loading or front-loading washer, water only occupies the lower portion of the annulus. Since most of the annulus in a high-efficiency top-loading or fr ont-loading washer is filled with air, a smaller annulus does not yield significant energy savings.

Other considerations are also important in determining an appropriate clearance between basket and tub. In the past rulemaking, resident ial clothes washer manufacturers stated that if the annulus is too small there may be problems with “suds lock”, where suds from the wash water remain between the inner wash ba sket and outer tub. Clearance is also needed to drain water during the spin-dry cycle and to allow for deflection of baskets with out-of-balance loads. Increasing the spin speed of the washer basket du ring the spin dry cycle may also require a larger space between tub and basket to allow for greater de flection at higher spin sp eeds. For this latter reason, tighter tub tolerance was not combined with the improved-wa ter-extraction technology option. Other limiting performance factors mentioned by residential clothes washer manufacturers in the past include: (1) noise; (2) vibrat ion; and (3) sand removal.

Ultrasonic washing

The addition of mechanical energy to the wash cycle can reduce the need for hot water (or chemical energy) in the cleaning action of clothes washers. One potential method of

3-74delivering the mechanical energy is through ultrasonic vibrations that loosen and remove some of the dirt on the soiled clothes. Such washi ng machines have been produced by a Japanese firm and were to be marketed in the United St ates. One U.S. clothes washer manufacturer investigated the Japanese product and found that it did not successfully clea n clothes. The U.S. firm stated that the Japanese company is an exce llent manufacturer of ultr asonic transducers, but does not have experience with clothes washing.

One of the problems with ultrasonic washing is that clothes are not uniformly exposed to the vibrations generated by the transducers, whic h means that some areas may remain soiled. Additionally, the wash solution and the submerge d clothes appear to dissipate much of the energy without the clothes being cleaned. A design producing adequate cleaning action does not appear to have been developed. 128

3.14.3 Energy Efficiency
In preparation for the screening and engine ering analyses, DOE gathered data on the energy efficiency of residential cooking pr oducts and CCWs curren tly available in the marketplace. These data were taken from da tabases maintained by a variety of regulatory agencies. While this section is not intended to provide a complete characterization of the energy efficiency of all appliances currently available and in use, it does provide an overview of the energy efficiency of each product covered by this rulemaking.

3.14.3.1 Cooking Products
Conventional Cooking Products

The DOE test procedure for cooktops is based on measuring the amount of energy required to raise an aluminum test block from ro om temperature to a specified temperature above room temperature. Of the efficiency data available, many are based on tests measuring the amount of energy that is required to boil a specifi ed amount of water. The amount of water and length of time to boiling varies, depending on the re searcher or manufacturer conducting the test. In addition, boil times vary with altitude, as increasing altitude decreases the length of time required to boil water. Only efficiency data based on the DOE test are used in the analysis because “boiling water” tests being conducted curre ntly do not use a standardized water load or boiling time.

Although not completely representative of the current U.S. cooking products market, Natural Resources Canada (NRCan) publishes a database of electric cooking appliance performance as measured by the applicable Cana dian Standards Association test procedures. This database covers products available in the Canadian market, which overlaps with the U.S. market. Data from the NRCan database are pres ented as the distribution of listed models as a function of EF, which is calculated by dividing the annual useful cooking energy output from the DOE test procedure by the rated annual energy consumption from the database.

3-75<0.34 0.34 to 0.3 6 >0.36 to 0.38

>0.

3 8 t

o 0. 4 0

>0.

4 0 t

o 0. 4 2

>0.

4 2 t

o 0. 4 4

>0.

4 4 t

o 0. 4 6 >0.46 to 0.48

>0.

4 8 t

o 0. 5 0 >0.50 Figure 3.14.1 displays the EFs of standard open (coil)- and smooth element electric ranges listed in the NRCan database.

Energy Factor
Figure 3.14.1 Standard Electric Ranges in the NRCan Database 129

Figure 3.14.2 displays the EFs of self-cleaning open (coil) - and smooth-element electric ranges listed in the NRCan database. 0 13 13 42

37

6 6
3 3
0 0 0 5 24

5 3 10

0 0 0 0 5 10 15 20 25 30 35 40 45# of Models Co il T o p Sm ooth T o p

3-76<0. 3 4

0 .

34 to 0.36

>0.

36 to 0.

3 8 >0.3 8 t

o 0. 4 0 >0.40 to 0.42

>0.

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4 4 >0.4 4 t

o 0. 4 6 >0.4 6 t

o 0.48

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48 to 0.5 0 >0.5 0 1 0 21

13 32

19

4 2 0 0

9 18 62 58 62

36

16

0 1 2 0 10 20 30 40 50 60 70# of Models Coil Top Smooth Top

Energy Factor
Figure 3.14.2 Self-Cleaning Electric Ranges in the NRCan Database 130

Figure 3.14.3 displays the EFs of open (c oil)- and smooth-element electric cooktops listed in the NRCan database.

25

0 0 0 2 4

1 0 5 4

0 1 1 1 9

4 17

7 17 17 21

17

0 0 0

0.69 0.7 0.71 0.72 0.73 0.74 0.75 0.76 0.77 0.78 0.79 0.8 Energy Factor Coil Smooth# of Models 20

15

10

5

0

Figure 3.14.3 Electric Cooktops in the NRCan Database 131

3-77<0.08

0 .

08

t o 0 . 09 >0.09 to 0.10

>0.

1 0 t

o 0. 1 1 >0.11 to 0.12

> 0.12 to 0. 1 3

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o 0. 1 4 >0.14 to 0.15

>0.

1 5 t

o 0. 1 6 >0.16 Figure 3.14.4 displays the EF s of self-cleaning electric ovens listed in the NRCan database for both single and double ovens, while Figure 3.14.5 displays the EFs of non-selfcleaning electric ovens list ed in the NRCan database for both single and double ovens.

Energy Factor Figure 3.14.4 Self-Cleaning Elect ric Ovens in the NRCan Database 132 97

29 65

17 20 14

1 0 0 3 0 20 40 60 80 10 0 12 0# of Models

3-78<0. 0 8

0 .

08

t o

0.0

9 >0.09 to 0.10 >0.1 0 t

o 0.11 >0.1 1 t

o 0. 1 2 >0.1 2 t

o 0.13 >0.1 3 t

o 0. 1 4

>0.

14 t o 0. 1 5 >0.1 5 t

o 0.16 >0.1 6 5

4

3

2

1

0 0 3

0 2

0 4

1 2

0 0

Energy Factor
Figure 3.14.5 Non-Self-Cleaning Electric Ovens in the NRCan Database 133

While self-cleaning ovens tend to be more efficient than non-self-cleaning ovens, due to the thicker insulation required to maintain sa fe exterior temperatures during oven cleaning cycles, some non-self-cleaning ove ns exhibit EFs comparable to self-cleaning electric ovens. However, no non-self-cleaning electric ovens have EFs above 0.15, while three self-cleaning electric ovens have EFs exceeding 0.16.

Microwave Ovens

For microwave ovens, the DOE test procedure u tilizes the test procedures specified in IEC 705. It should be noted that IEC 705 has been superseded by IEC 60705. DOE does not plan to revise the test procedure to incor porate IEC 60705 to measure the cooking efficiency because, as discussed in chapter 5 of the TSD, DOE conducted analyses on a sample of microwave ovens which indicated that the effici ency measurements obtained with IEC 705 were more stable and repeatable th an those obtained using IEC 60705.

Microwave ovens consume energy in cooking m ode, when heating food, and in standby mode, while powering the clock and electronic controls. AHAM recently provided data on microwave oven efficiency and standby power for a sample of microwave ovens available in the U.S. market. 134 Microwave oven efficiency was tested according to DOE’s test procedure. Standby power was tested according to IEC 62301. Although AHAM only tested 21 units from 9 manufacturers, the units were selected to repr esent a broad spectrum of units available in the market place, and had varying capacities and f eatures. Figure 3.14.6 and Figure 3.14.7 display the AHAM microwave oven efficiency data.# of Models

3-7950% 55% 60% 65%Efficiency

600 700 800 900 1000 1100 1200 1300 1400 Rated Output Power (W)
Figure 3.14.6 AHAM Microwave Oven Effi ciency versus Rated Output Power 135

Figure 3.14.6 illustrates the lack of a corre lation between microwave oven rated output power and microwave oven efficiency. Efficiency remains nearly linear across the tested output power range. Figure 3.14.7 illustrates the relationship between microwave oven volume and microwave oven efficiency. Again, microwave oven efficiency remains constant and nearly linear regardless of microwave oven volume.

3-8050% 55% 60% 65%Efficiency

0.0 0.5 1.0 1.5 2.0 2.5 Microwave Oven Volume (ft^3)
Figure 3.14.7 AHAM Microwave Oven Efficiency versus Oven Volume 136

Figure 3.14.8 displays AHAM-measured mi crowave oven standby power data as a function of rated output power. Figure 3.14.8 al so contains standby power measurements made by the Canadian Building Energy End-Use Data and Analysis Center (CBEEDAC) at the University of Alberta. The data show a wide range of standby power, but there is no correlation between standby power and rated output power.

3-810.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0Standby Power Consumption (W)

600 800 1000 1200 1400 1600 Rated Output Power (W)

AHAM Data CBEEDAC Data Figure 3.14.8 AHAM and CBEEDAC Microwave Oven Standby Power versus Rated Output Power 137,138

FEMP publishes a database of microwave ovens, sorted by standby power, although this database is also not completely representative of microwave ovens availabl e in the U.S. market. Figure 3.14.9 displays the numbe r of microwave oven models av ailable with different standby power levels as listed in th e FEMP standby power database.

3-821 28 56

33

0 10 20 30 40 50 60Number of Models

0 to 1 W 1.1 to 2 W 2.1 to 3 W >3 W Standby Power
Figure 3.14.9 Microwave Oven Standby Power Consumption from the FEMP Database 139

FEMP does not specify microwave oven rated ou tput power. Therefore, it is not possible to make a direct comparison between the FEMP microwave oven standby power data and the AHAM microwave oven test data. However, the distributions of sta ndby power in the FEMP database and the AHAM data are similar. Very few microwave ovens consume less than 1 W of standby power, some microwave ovens consume le ss than 2 W of standb y power, but the large majority of microwave ovens consume between 2.1 and 3 W of standby power.

3.14.3.2 Commercial Clothes Washers
Although not completely repres entative of the current CCW market, the CEC publishes a list of “certified” products. Ev en though the Federal standard only recently was raised to an MEF of 1.26, California had previously enacted a minimum standard at that level, so the database only contains products with MEFs of 1.26 and higher. ENERGY STAR and CEE also publish lists of certified products. Figure 3.14.10 displays the distribut ion of CCWs in the combined CEC, ENERGY STAR, and CEE databases as a function of MEF.

3-831.26 to 1.3

> 1 .3 to 1.4 >1.4 to 1.5

> 1 .5 t

o

1.6 >1.6 to 1.7

> 1 .7 to 1 .

8 >1.8 to 1.9

> 1 .9 to 2. 0 >2.0 to 2.1

> 2 .1 to 2 .

2
>2 .

2 to 2.3

> 2 .3 to 2.4

> 2 .

4

to 2.5

> 2 .5 to 2. 6

> 2 .

6 to 2.7

> 2 .7 to 2.8 73 80

70

60

50

40

30

20

10

0Number of Models 51

32 31 28

14 11 9

2 2 1 1 1

MEF Top-Loading Front-Loading Figure 3.14.10 Commercial Clot hes Washer MEFs in the CE C, ENERGY STAR, and CEE Databases 140 141 142

Figure 3.14.10 illustrates the difference in MEF between top-loading CCWs and frontloading CCWs. All of the CCWs with an MEF below 1.5 are front-loading units, whereas all but one of the washers with an MEF above 1.5 ar e front-loading washers. No commercial toploading washer has an MEF above 1.76, while 129 front-loading commerc ial washer models have an MEF above 2.0.

The CEC, ENERGY STAR, and CEE database s of certified CCWs al so contain data on WF. The databases contain products with WF of 13 or lower. Figur e 3.14.11 displays the distribution of CCWs in the combined CEC, ENERGY STAR, and CEE da tabases as a function of WF.

3-84> 4 to

5 >5 to 6

> 6 to 7 >7 to 8

> 8 to 9

> 9 to 10

> 1 0 t

o 11

> 1 1 to 12

> 1 2 to 13 2 28 47

3 3 9 17 53 62

10 12

0 10 20 30 40 50 60 70Number of Models

WF Top-Loading Front-Loading Figure 3.14.11 Commercial Clothes Washer WF s in the CEC, ENERGY STAR, and CEE Databases 143 144 145

Figure 3.14.11 illustrates the difference in WF between top- and front-loading CCWs. All of the CCWs with a WF greater than 9.0 ar e top-loading units, whereas all of the washers with WF below 7.0 are front-loading units. No top-loading CCW has a WF below 7.0, while 132 front-loading models have a WF below 7.0.

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5 Ibid.

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13 AHAM Fact Book 2003

.

14 CEE. 1998. Op. Cit.

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16 Ibid.

17 DOE Docket No. EE-RM-PET-100, submitted by the California Energy Commission January

29, 2007.

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23 Ibid.

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31 Ibid

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3-8732 Ibid

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33 Ibid

.

34 AHAM Fact Book 2005.

35 Ibid.

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3-8846 Ibid.

47 Ibid.

48 U.S. Census Bureau, Survey of Plant Capacity: 2006 to 1994

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56 ORTECH. 1989. Op. cit.

57 U.S. DOE. 1980. Op. cit.

58 Shepard et al . 1990. Op. cit.

59 L. Andrews. 1978. Proposed Test Procedure fo r Induction Cooking Tops . National Bureau

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3-8961 D. DeWitt and M. Peart. 1982. Bi-Radiant Oven: A Low-Energy Oven System . Purdue University, West Lafayette, IN. Prepared fo r Oak Ridge National Laboratory, Oak Ridge, TN, ORNL/Sub-80/0082/1, ORNL/Sub-80/0082/2, ORNL/Sub-80/0082/3, March 1982.

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64 ORTECH. 1989. Op. cit.

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66 ADL. 1994. Op. cit.

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70 ORTECH. 1989. Op. cit.

71 U.S. DOE. 1980. Op. cit.

72 Ibid.

73 GRI. 1994. Op. cit.

74 ORTECH. 1989. Op. cit.

75 GRI. 1994. Op. cit.

3-9076 Ibid.

77 P. Seibold. 1995. Personal Communications . Norton Company. Worcester, MA, March 1995.

78 ADM. 1987. Op. cit.

79 ORTECH. 1989. Op. cit.

80 GRI. 1994. Op. cit.

81 ADM. 1987. Op. cit.

82 GRI. 1994. Op. cit.

83 ADL. 1994. Op. cit.

84 M. Lowe. 2006. “Cooking Technologies: Overachieving Ovens.” Appliance Design
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85 “Sharp Unveils Fat-Busting Superheated Steam Oven.” Appliance Magazine , August 23, 2005.

86 Lowe. Op. cit

.

87 AHAM. 1990. Comments on the Advanced Notice of Proposed Rulemaking Regarding Energy Conservation Standards for Room Air Conditioners and Kitchen Ranges and Ovens

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88 AHAM. 1990. Op. cit . p. 35.

89 AHAM. 2006. AHAM Test Data on Microwave Ovens . October 23, 2006, Docket Number EE-2006-STD-0127, Comment Number 17, November 30, 2006.

90 T. Ishii, T. Handa, M. Aiga, N. Kuwahara . 2006. “Magnetron.” U.S. Patent Number 7,023,137, assigned to Matsushita Electrical Industrial Co., Ltd., Osaka, Japan, April 4, 2006.

91 AHAM. 2006. Op. cit.

92 C.R. Buffler and R. McNutt. 1978. “Effi ciency Improvement Techniques for Microwave Ovens.” Proceedings of the Conference on Major Home Appliance Technology for Energy Conservation , Lafayette, IN, February 1978.

3-9193 Sharp Electronics Corporation. 1994. Comments on the Notice of Proposed Rulemaking for Microwave Ovens . 59 FR 10464, March 4, 1994, Dock et Number EE-RM-90-201, Comment Number 521, July 18, 1994.

94 AHAM. 1990. Op. cit . p 35.

95 Ibid

.

96 AHAM. 1990. Op. cit . p 31.

97 GE Product Literature. Available online at http://www.geappliances.com/products/introduct ions/trivection/overview/compare_cook_tim es.htm (Accessed September 21, 2008.)

98 Lowe. 2006. Op. cit.

99 P. Biermayer et al . 1996. Design Options for Clothes Washers . LBNL, Berkeley, CA, LBL47888, October 1996.

100 E. Biesen. 2005. “A n Expanding Laundry List.” Appliance Magazine , September 2005.

101 Appliance Manufacturer , April 1995, p. 27.

102 Appliance Manufacturer , February 1995, p. E-58.

103 Science Applications Inc. 1977. Energy Efficiency Program fo r Clothes Washers, Clothes Dryers and Dishwashers , SAI-77-839, La Jolla, CA, pp. 4–45.

104 “Big Plans for Tiny Bubbles.” Appliance Manufacturer , December 1994, p. 32.

105 “Sorting Through Laundry.” Appliance , September 1994, p. 35.

106 Daewoo Product Literature . Available online at http://www.daewoo-electronics.de/eu/p roducts/living_washing_prod.asp?idprod=235 (Accessed September 21, 2008.)

107 I. Turiel, et al . 1995. Evaluation of Advanced Technologies for Residential Appliances and Residential and Commercial Lighting . LBNL, Berkeley, CA, LBL-35982, January 1995.

108 Sharp Product Timeline. Available online at http://sharp-world.com/corporat e/info/his/chronology/p10.html (Accessed September 21, 2008.)

3-92109 S. Kristic et al . 1993. “Direct Comparison: Assessing the Energy Efficiency Impact of a Transmissionless Motor/Drive System for Conventional Clothes Washers.” Proceedings of the 44 th Annual International App liance Technical Conference , May 1993, p.101.

110 GE Product Literature . Available online at http://products.geappliances .com/ApplProducts/Dispatch er?REQUEST=RESULTSPAGE&C ATEGORY=CA0096&CATEGORY=CA0095&SITEID=GEA . (Accessed September 21, 2008.)

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112 LG Electronics Product Lite rature. Available online at http://us.lge.com/download/pr oduct/file/1000003879/WM2688Hss.pdf (Accessed September 21, 2008.)

113 U.S. DOE. 1990. Technical Support Document: Energy Conservation Standards for Consumer Products: Dishwashers, Cl othes Washers, and Clothes Dryers . DOE/CE-0299P, December 1990, p. 3-14.

114 Ibid.

115 Ibid

.

116 “New for ’93.” Electrolux Product Literature, Domotechnica

.

117 Biermayer et al . 1996. Op. cit

.

118 ADL. 1995. Op. cit.

119 Biermayer et al . 1996. Op. cit

.

120 AHAM. 1995. Op. cit.

121 EPRI. 1996. Ozone Laundering: A Better Wash Process for Commercial Laundries

. Technical Brief RP2890, March 1996.

122 U.S. DOE. 1990. Op. cit.

123 “LG Washing Machines In corporate Steam Technology.” Appliance Magazine , June 29, 2005.

124 Ibid.

3-93125 “Whirlpool to Introduce New Products at Builders Show.” Appliance Magazine , February 13, 2008.

126 “New Ways of Washing.” Appliance , September 1992, p. 75.

127 Appliance , September 1995, p. 51.

128 Turiel et al. Op. cit.

129 Natural Resources Canada (NRCan) Database of Major Appliances. Available online at http://oee.nrcan.gc.ca/resident ial/personal/appliances.cfm?attr=4 . (Accessed September 21, 2008.)

130 Ibid.

131 Ibid.

132 Ibid.

133 Ibid.

134 AHAM. 2006. Op. cit.

135 Ibid.

136 Ibid.

137 Ibid.

138 N. Fish, D. White, and D. Ryan. 2006. Standby Power Energy Use of Common Household Appliances . Canadian Building Energy End-Use Data and Analysis Center, University of Alberta, Canada, July 2006.

139 FEMP Microwave Standby Power Database. Available online at http://oahu.lbl.gov/cgi-bin/search_data.pl . (Accessed September 21, 2008.)

140 CEC Appliance Efficiency Database. Op. cit.

141 Energy Star Commercial Clothes Washer Database. Available online at http://www.energystar.gov/index.cfm?fuse action=clotheswash.display_commercial_cw

. (Accessed September 21, 2008.)

3-94142 CEE Commercial Clothes Washer Database. Available online at http://www.cee1.org/com/cwsh/cwsh-main.php3 . (Accessed September 21, 2008.)

143 CEC Appliance Efficiency Database. Op. cit.

144 Energy Star Commercial Clothes Washer Database. Op. cit.

145 CEE Commercial Clothes Washer Database. Op. cit.

3-95