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CHAPTER 1. INTRODUCTION

TABLE OF CONTENTS

1.1 PURPOSE OF THE DOCUMENT.............................................................................. 1-1

1.2 OVERVIEW OF STANDARDS FOR RESIDENTIAL CLOTHES WASHERS.......... 1-1

1.3 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS .................. 1-2

1.4 STRUCTURE OF THE DOCUMENT ........................................................................ 1-5

LIST OF TABLES

Table 1.3.1 Analyses Under the Process Rule ..................................................................... 1-4
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CHAPTER 1. INTRODUCTION

1.1 PURPOSE OF THE DOCUMENT

This technical support document (TSD) is a stand-alone report that provides the technical 

analyses and results supporting the information presented in the direct final rule and executive 

summary for residential clothes washers. This TSD reports on the activities and analyses

conducted in the period following the preliminary analysis of this rulemaking.

1.2 OVERVIEW OF STANDARDS FOR RESIDENTIAL CLOTHES WASHERS

The Energy Policy and Conservation Act (EPCA) of 1975, Pub. L. 94-163 (42 United 

States Code (U.S.C.) 6291–6309), established an energy conservation program for major 

household appliances. The National Energy Conservation Policy Act of 1978 (NECPA), Pub. L. 

95-619, amended EPCA to add Part Ca of Title III (42 U.S.C. 6311–6317), which established an 

energy conservation program for certain industrial equipment. Additional amendments to EPCA 

give DOE the authority to regulate the energy efficiency of several products, including 

residential clothes washers—the products that are the focus of this document. The amendments 

to EPCA in the National Appliance Energy Conservation Act of 1987 (NAECA), Pub. L. 100-12, 

established standards for residential clothes washers, as well as requirements for determining 

whether these standards should be amended. (42 U.S.C. 6295(g))

NAECA established the first prescriptive standards for residential clothes washers,

requiring that all rinse cycles of clothes washers manufactured after January 1, 1988, shall 

include an unheated water option, but may have a heated water rinse option, and further required 

that DOE conduct two cycles of rulemakings to determine if more stringent standards are 

justified.b (42 U.S.C. 6295 (g)(2) and (4)) On May 14, 1991, DOE published a final rule in the 

Federal Register (FR) establishing the first set of performance standards for residential clothes 

washers; the compliance date of the new standards was May 14, 1994. 56 FR 22279. DOE 

conducted a second standards rulemaking for residential clothes washers, publishing a January 

2001 final rule revising the energy conservation standards; the revised standards became 

effective in two phases, with compliance dates of January 1, 2004, and January 1, 2007. 66 FR 

3314.

 

a Part C has been redesignated Part A-1 in the United States Code for editorial reasons.

b DOE defines “clothes washer” under EPCA as “a consumer product designed to clean clothes, utilizing a water 

solution of soap and/or detergent and mechanical agitation or other movement, and must be one of the following 

classes: automatic clothes washers, semi-automatic clothes washers, and other clothes washers.” 10 CFR 430.2. 
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As part of its priority-setting activities for fiscal year 2006, DOE conducted analyses for 

residential clothes washers to estimate the energy savings potential of amended standards. DOE 

determined that amended standards could result in energy savings for residential clothes washers 

of 5.5 quads cumulative over the period of 2004–2030. A summary of the analyses is available 

on DOE’s website at 

www1.eere.energy.gov/buildings/appliance_standards/pdfs/2006_activities_data_sheets.pdf

1.3 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS

Under EPCA, when DOE is studying new or amended standards, it must consider, to the 

greatest extent practicable, the following seven factors (42 U.S.C. 6295 (o)(2)(B)(i)):

1) the economic impact of the standard on the manufacturers and consumers of the affected 

products; 

2) the savings in operating costs throughout the estimated average life of the product 

compared to any increases in the initial cost or maintenance expense; 

3) the total projected amount of energy savings likely to result directly from the imposition 

of the standard; 

4) any lessening of the utility or the performance of the products likely to result from the 

imposition of the standard; 

5) the impact of any lessening of competition, as determined in writing by the Attorney 

General, that is likely to result from the imposition of the standard; 

6) the need for national energy conservation; and 

7) other factors the Secretary considers relevant.

Other statutory requirements are set forth in 42 U.S.C. 6295 (o)(1)–(2)(A), (2)(B)(ii)–

(iii), and (3)–(4) and 42 U.S.C. 6316(e).

DOE considers stakeholder participation to be a very important part of the process for 

setting energy conservation standards. Through formal public notifications (i.e., Federal Register

notices), DOE actively encourages the participation and interaction of all stakeholders during the 

comment period in each stage of the rulemaking. Beginning with the framework document and 

during subsequent comment periods, interactions among stakeholders provide a balanced 

discussion of the information that is required for the standards rulemaking.
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Before DOE determines whether or not to adopt a proposed energy conservation 

standard, it must first solicit comments on the proposed standard. (42 U.S.C. 6295(m)(2)(B); 42 

U.S.C. 6295(p)(2)) Any new or amended standard must be designed to achieve significant 

additional conservation of energy and be technologically feasible and economically justified. (42 

U.S.C. 6295(o)(2)(A)) To determine whether economic justification exists, DOE must review 

comments on the proposal and determine that the benefits of the proposed standard exceed its 

burdens to the greatest extent practicable, weighing the seven factors listed above. (42 U.S.C. 

6295 (o)(2)(B)(i))

After the publication of the framework document, the energy conservation standards 

rulemaking process involves three additional, formal public notices, which DOE publishes in the 

Federal Register. The first of the rulemaking notices is a notice of public meeting (NOPM), 

which is designed to publicly vet the models and tools used in the preliminary rulemaking and to 

facilitate public participation before the next stage. The second notice is the notice of proposed 

rulemaking (NOPR), which presents a discussion of comments received in response to the 

NOPM and the preliminary analyses and analytical tools; analyses of the impacts of potential 

amended energy conservation standards on consumers, manufacturers, and the Nation; DOE’s 

weighting of these impacts of amended energy conservation standards; and the proposed energy 

conservation standards for the product. The third notice is the final rule, which presents a 

discussion of the comments received in response to the NOPR; the revised analyses; DOE’s 

weighting of these impacts; the amended energy conservation standards DOE is adopting for the

product; and the compliance dates of the amended energy conservation standards.

DOE initiated the current rulemaking on August 28, 2009 by publishing a notice 

announcing the availability of the framework document, the “Energy Conservation Standards 

Rulemaking Framework Document for Residential Clothes Washers.” In this notice, DOE also 

announced a public meeting and requested public comment on the matters raised in the 

framework document. 74 FR 44306 (Aug. 28, 2009). The framework document described the 

procedural and analytical approaches that DOE anticipated using to evaluate energy conservation 

standards for clothes washers and identified various issues to be resolved in conducting this 

rulemaking. The framework document is available at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/clothes_washers_fra

mework.pdf.

DOE held a public meeting on September 21, 2009, where it presented the contents of the 

framework document; described the analyses it planned to conduct during the rulemaking; 

sought comments from interested parties on these subjects; and, in general, sought to inform 

interested parties about, and facilitate their involvement in, the rulemaking. Interested parties 

commented about numerous issues relating to each one of the analyses listed in Table 1.3.1. At 

the meeting and during the period for commenting on the framework document, DOE received 

many comments that helped it identify and resolve issues involved in this rulemaking. DOE then 

began to gather additional information to perform a preliminary analysis to help develop 

potential energy conservation standards for residential clothes washers.
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Table 1.3.1 Analyses Under the Process Rule

Preliminary Analyses NOPR Final Rule

Market and technology assessment Revised preliminary analyses Revised NOPR analyses

Screening analysis Life-cycle cost sub-group 

analysis

Engineering analysis Manufacturer impact analysis

Energy use determination Utility impact analysis

Markups for equipment price 

determination

Emissions analysis

Life-cycle cost and payback period 

analysis

Employment impact analysis

Shipments analysis Regulatory impact analysis

National impact analysis

Preliminary manufacturer impact analysis

In response to the framework document, DOE received the “Agreement on Minimum 

Federal Efficiency Standards, Smart Appliances, Federal Incentives and Related Matters for 

Specified Appliances” (the “Joint Petition”), a comment submitted by groups representing 

manufacturers, energy and environmental advocates, and consumer groups (collectively, the 

“Joint Petitioners”). This collective set of comments, which DOE refers to in this notice as the 

“Joint Petition”c recommends specific energy conservation standards and their compliance dates 

for residential clothes washers that, in the commenters’ view, would satisfy the EPCA 

requirements in 42 U.S.C. 6295(o).

EPCA allows DOE to issue a direct final rule establishing an energy conservation 

standard on receipt of a statement submitted jointly by interested persons that are fairly 

representative of relevant points of view (including representatives of manufacturers of covered 

products, States, and efficiency advocates) that contains recommendations with respect to an 

energy conservation standard that are in accordance with the provisions of 42 U.S.C. 6295(o). 

DOE has concluded that the recommendations of the Joint Petition satisfy the requirements of 42

U.S.C. 6295(o). Therefore, DOE is publishing this direct final rule concurrently with a notice of 

proposed rulemaking that proposes identical energy conservation standards and compliance 

dates. If DOE receives adverse comment and determines that such comment may provide a 

reasonable basis for withdrawing the direct final rule, this final rule will be withdrawn and DOE 

will proceed with the proposed rule.

 

c DOE Docket No. EERE–2008–BT–STD–0019, Comment 32. DOE considered the Joint Petitioners’ comments to 

supersede earlier comments by the listed parties regarding issues subsequently discussed in the Joint Petition.
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As part of the information gathering and sharing process, DOE organized and held 

interviews with manufacturers of the residential clothes washers considered in this rulemaking as 

part of the engineering analysis. DOE selected companies that represented production of all types 

of products, ranging from small to large manufacturers, and included the Association of Home 

Appliance Manufacturers (AHAM) member companies. DOE had four objectives for these 

interviews: (1) solicit manufacturer feedback on the draft inputs to the engineering analysis; (2) 

solicit feedback on topics related to the preliminary manufacturer impact analysis; (3) provide an 

opportunity, early in the rulemaking process, to express manufacturers’ concerns to DOE; and 

(4) foster cooperation between manufacturers and DOE. DOE incorporated the information 

gathered during the engineering interviews with manufacturers into its engineering analysis 

(chapter 5) and the manufacturer impact analysis (chapter 12).

DOE developed spreadsheets for the engineering, Life-Cycle Cost (LCC) Payback Period 

(PBP), and national impact analyses for each product. The LCC spreadsheet calculates the LCC 

and PBP at various energy efficiency levels. The national impact analysis spreadsheet calculates 

the national energy savings and national net present values at various energy efficiency levels. 

This spreadsheet includes a model that forecasts the impacts of amended energy conservation 

standards at various levels on product shipments. All of these spreadsheets are available on the 

DOE website for residential clothes washers at:

www1.eere.energy.gov/buildings/appliance_standards/residential/clothes_washers.html.

DOE can also provide quantitative outputs from its analyses in machine-readable format 

upon request. For example, outputs from trial runs of the LCC Monte Carlo simulations can be 

provided in such a format.

1.4 STRUCTURE OF THE DOCUMENT

This TSD outlines the analytical approaches used in this rulemaking. The TSD consists of 

14 chapters, an emissions analysis, a regulatory impact analysis, a monetization analysis, a panel 

analysis, and appendices.

Chapter 1 Introduction: provides an overview of the appliance standards program 

and how it applies to this rulemaking, and outlines the structure of the 

document.

Chapter 2 Analytical Framework: describes the rulemaking process.

Chapter 3 Market and Technology Assessment: characterizes the market for the 

considered products and the technologies available for increasing 

product efficiency.
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Chapter 4 Screening Analysis: identifies all the design options that improve 

efficiency of the considered products, and determines which technology 

options are viable for consideration in the engineering analysis.

Chapter 5 Engineering Analysis: discusses the methods used for developing the 

relationship between increased manufacturer price and increased 

efficiency.

Chapter 6 Markups Analysis: discusses the methods used for establishing markups 

for converting manufacturer prices to customer product costs.

Chapter 7 Energy Use Analysis: discusses the process used for generating energyuse estimates for the considered products as a function of standard 

levels.

Chapter 8 Life-Cycle Cost and Payback Period Analysis: discusses the effects of 

standards on individual customers and users of the products and 

compares the LCC and PBP of products with and without higher 

efficiency standards.

Chapter 9 Shipments Analysis: estimates shipments of the products over the 30-

year analysis period that is used in performing the national impact 

analysis (NIA).

Chapter 10 National Impact Analysis: assesses the national energy savings, and the 

national net present value of total consumer costs and savings, expected 

to result from specific, potential energy conservation standards for 

residential clothes washers.

Chapter 11 Consumer Subgroup Analysis: discusses the effects of standards on 

different subgroups of consumers.

Chapter 12 Manufacturer Impact Analysis: discusses the effects of standards on the 

finances and profitability of product manufacturers.

Chapter 13 Employment Impact Analysis: discusses the effects of standards on 

national employment.

Chapter 14 Utility Impact Analysis: discusses certain effects of the considered 

standards on electric and gas utilities.

Chapter 15 Emissions Analysis: discusses the effects of standards on three 

pollutants—sulfur dioxide (SO2), nitrogen oxides (NOx), and mercury—

as well as carbon dioxide emissions.
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Chapter 16 Monetization of Emission Reductions Benefits

Chapter 17 Regulatory Impact Analysis: discusses the impact of non-regulatory 

alternatives to efficiency standards.

Chapter 18 Do Standards Increase Consumer Welfare? Evidence from a 2007 

Change In Energy Efficiency Requirements for Clothes Washers

Appendix 5-A Engineering Data Request Sheets

Appendix 5-B AHAM Data Submittal

Appendix 5-C Engineering Questionnaires

Appendix 8-A User Instructions for Life-Cycle Cost and Payback Period Spreadsheets

Appendix 8-B Uncertainty and Variability

Appendix 8-C Lifetime Distributions

Appendix 8-D Distributions of Interest Rates for Household Debt and Equity

Appendix 8-E Estimation of Equipment Price Trends for Residential Clothes Washers

Appendix 9-A Relative Price Elasticity of Demand for Clothes Washers

Appendix 10-A User Instructions for Shipments and National Impact Analysis

Spreadsheets

Appendix 10-B National Product and Operating Costs

Appendix 10-C National Net Present Value of Consumer Benefits Using Alternative 

Product Price Forecasts

Appendix 12-A Manufacturer Impact Analysis

Appendix 15-A Environmental Emissions Factors 

Appendix 16-A Social Cost of Carbon

Appendix 17-A RIA Supporting Materials