CHAPTER 8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS
 

TABLE OF CONTENTS 

8.1 INTRODUCTION ........................................................................................................... 8-1 

8.1.1 General Approach for LCC and PBP Analysis................................................................ 8-1 

8.1.2 Overview of LCC and PBP Inputs................................................................................... 8-2 

8.2 LIFE-CYCLE COST INPUTS ........................................................................................ 8-6 

8.2.1 Total Installed Cost Inputs............................................................................................... 8-6 
 

8.2.1.2 Baseline Manufacturer Cost........................................................................... 8-8 

8.2.1.3 Standard-Level Manufacturer Cost Increases................................................ 8-8 

8.2.1.4 Overall Markup.............................................................................................. 8-9 

8.2.1.5 Installation Cost ............................................................................................. 8-9 

8.2.1.6 Total Installed Cost...................................................................................... 8-10 

8.2.2 Operating Cost Inputs .................................................................................................... 8-11 

8.2.2.1 Annual Energy and Water Consumption ..................................................... 8-13 

8.2.2.2 Energy and Water Prices.............................................................................. 8-15 

8.2.2.3 Energy and Water Price Trends ................................................................... 8-22 

8.2.2.4 Repair and Maintenance Costs..................................................................... 8-24 

8.2.3 Product Lifetime ............................................................................................................ 8-26 

8.2.4 Discount Rates ............................................................................................................... 8-27 

8.2.5 Effective Date of Standard............................................................................................. 8-30 

8.2.6 Equipment Assignment for the Base Case..................................................................... 8-30 

8.3 PAYBACK PERIOD INPUTS...................................................................................... 8-32 

8.4 LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS...................................... 8-33 

8.4.1 Base Case LCC Distributions ........................................................................................ 8-34 

8.4.2 Standard-Level Distributions of LCC Impacts .............................................................. 8-36 

8.4.3 Standard-Level PBP Distributions................................................................................. 8-37 

8.4.4 LCC and PBP Results .................................................................................................... 8-38 

8.5 REBUTTABLE PAYBACK PERIOD.......................................................................... 8-45 

8.5.1 Metric............................................................................................................................. 8-45 

8.5.2 Inputs.............................................................................................................................. 8-45 

8.5.3 Results............................................................................................................................ 8-46 

LIST OF TABLES 

Table 8.1.1 LCC and PBP Input Summary............................................................................. 8-5 

Table 8.2.1 Inputs for Total Installed Cost ............................................................................. 8-7 

Table 8.2.2 Commercial Clothes Washers: Baseline Manufacturer Costs ............................. 8-8 

Table 8.2.3 Top-Loading Commercial Clothes Washers: Standard-Level Manufacturer 

Cost Increases ...................................................................................................... 8-9 

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EERE-2006-STD-0127 COMMENT 69.1
Table 8.2.4 Front-Loading Commercial Clothes Washers: Standard-Level 

Manufacturer Cost Increases................................................................................ 8-9 

Table 8.2.5 Overall Markups .................................................................................................. 8-9 

Table 8.2.6 Commercial Clothes Washers: Baseline Installation Costs............................... 8-10 

Table 8.2.7 Top-Loading Commercial Clothes Washers: Consumer Equipment Prices, 

Installation Costs, and Total Installed Costs...................................................... 8-10 

Table 8.2.8 Front-Loading Commercial Clothes Washers: Consumer Equipment 

Prices, Installation Costs, and Total Installed Costs.......................................... 8-11 

Table 8.2.9 Inputs for Operating Cost................................................................................... 8-11 

Table 8.2.10 Top-Loading Commercial Clothes Washers, Multi-Family Application: 

Annual Energy and Water Use by Efficiency Level.......................................... 8-14 

Table 8.2.11 Top-Loading Commercial Clothes Washers, Laundromat Application: 

Annual Energy and Water Use by Efficiency Level.......................................... 8-14 

Table 8.2.12 Front-Loading Commercial Clothes Washers, Multi-Family Application: 

Annual Energy and Water Use by Efficiency Level.......................................... 8-15 

Table 8.2.13 Front-Loading Commercial Clothes Washers, Laundromat Application: 

Annual Energy and Water Use by Efficiency Level.......................................... 8-15 

Table 8.2.14 Average Commercial Electricity Prices in 2007................................................ 8-17 

Table 8.2.15 Average Commercial Electricity Prices for Commercial Clothes Washers 

in 2008 ............................................................................................................... 8-18 

Table 8.2.16 Average Commercial Natural Gas Prices in 2007 ............................................. 8-19 

Table 8.2.17 Average Commercial Natural Gas Prices for Commercial Clothes Washers 

in 2008 ............................................................................................................... 8-20 

Table 8.2.18 Average Per-Unit-Volume Water Prices in 2006 .............................................. 8-21 

Table 8.2.19 Average Per-Unit-Volume Water Prices for Commercial Clothes Washers 

in 2008 ............................................................................................................... 8-22 

Table 8.2.20 Top-Loading Commercial Clothes Washer Annualized Repair Costs .............. 8-25 

Table 8.2.21 Front-Loading Commercial Clothes Washer Annualized Repair Costs............ 8-25 

Table 8.2.22 Commercial Clothes Washers: Product Lifetime Estimates and Sources ........ 8-26 

Table 8.2.23 Commercial Clothes Washers: Average, Minimum, and Maximum
 

Product Lifetimes............................................................................................... 8-26 

Table 8.2.24 Data for the Calculation of Weighted-Average Cost of Capital for Sectors 

that Purchase Commercial Clothes Washers ..................................................... 8-28 

Table 8.2.25 Weighted Average Cost of Capital for Sectors that Purchase Commercial 

Clothes Washers................................................................................................. 8-29 

Table 8.2.26 Discount Rates for Commercial Clothes Washers............................................. 8-30 

Table 8.2.27 Top-Loading Commercial Clothes Washers: Base Case Market Shares........... 8-32 

Table 8.2.28 Front-Loading Commercial Clothes Washers: Base Case Market Shares......... 8-32 

Table 8.4.1 Top-Loading Commercial Clothes Washers, Multi-Family Application: 

LCC and PBP Results ........................................................................................ 8-39 

Table 8.4.2 Top-Loading Commercial Clothes Washers, Laundromat Application: 

LCC and PBP Results ........................................................................................ 8-39 

Table 8.4.3 Front-Loading Commercial Clothes Washers, Multi-Family Application: 

LCC and PBP Results ........................................................................................ 8-39 

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EERE-2006-STD-0127 COMMENT 69.1
Table 8.4.4 Front-Loading Commercial Clothes Washers, Laundromat Application: 

LCC and PBP Results ........................................................................................ 8-40 

Table 8.5.1 Top-Loading Commercial Clothes Washers, Multi-Family Application: 

Rebuttable Payback Periods............................................................................... 8-46 

Table 8.5.2 Top-Loading Commercial Clothes Washers, Laundromat Application: 

Rebuttable Payback Periods............................................................................... 8-47 

Table 8.5.3 Front-Loading Commercial Clothes Washers, Multi-Family Application: 

Rebuttable Payback Periods............................................................................... 8-47 

Table 8.5.4 Front-Loading Commercial Clothes Washers, Laundromat Application: 

Rebuttable Payback Periods............................................................................... 8-47 

LIST OF FIGURES 

Figure 8.1.1 Flow Diagram of Inputs for the Determination of LCC and PBP ....................... 8-4 

Figure 8.2.1 Electricity Price Trends...................................................................................... 8-23
 

Figure 8.2.2 Natural Gas Price Trends................................................................................... 8-23 

Figure 8.2.3 Water Price Trend.............................................................................................. 8-24 

Figure 8.4.1 Top-Loading Commercial Clothes Washers, Multi-Family Application: 

Base Case LCC Distribution.............................................................................. 8-34 

Figure 8.4.2 Top-Loading Commercial Clothes Washers, Laundromat Application: 

Base Case LCC Distribution.............................................................................. 8-35 

Figure 8.4.3 Front-Loading Commercial Clothes Washers, Multi-Family Application: 

Base Case LCC Distribution.............................................................................. 8-35 

Figure 8.4.4 Front-Loading Commercial Clothes Washers, Laundromat Application: 

Base Case LCC Distribution.............................................................................. 8-36 

Figure 8.4.5 Top-Loading Commercial Clothes Washers, Multi-Family Application: 

Distribution of LCC Impacts for CSL 2 ............................................................ 8-37 

Figure 8.4.6 Commercial Clothes Washers, Multi-Family Application: Distribution of 

PBPs for CSL 3.................................................................................................. 8-38 

Figure 8.4.7 Range of LCC Savings for Top-Loading Commercial Clothes Washers, 

Multi-Family...................................................................................................... 8-41 

Figure 8.4.8 Range of LCC Savings for Top-Loading Commercial Clothes Washers, 

Laundromat........................................................................................................ 8-41 

Figure 8.4.9 Range of LCC Savings for Front-Loading Commercial Clothes Washers, 

Multi-Family...................................................................................................... 8-42 

Figure 8.4.10 Range of LCC Savings for Front-Loading Commercial Clothes Washers, 

Laundromat........................................................................................................ 8-42 

Figure 8.4.11 Range of Payback Periods for Top-Loading Commercial Clothes Washers, 

Multi-Family...................................................................................................... 8-43 

Figure 8.4.12 Range of Payback Periods for Top-Loading Commercial Clothes Washers, 

Laundromat........................................................................................................ 8-43 

Figure 8.4.13 Range of Payback Periods for Front-Loading Commercial Clothes 

Washers, Multi-Family ...................................................................................... 8-44 

Figure 8.4.14 Range of Payback Periods for Front-Loading Commercial Clothes 

Washers, Laundromat ........................................................................................ 8-44 

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EERE-2006-STD-0127 COMMENT 69.1
 

CHAPTER 8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS 

8.1 INTRODUCTION 

This chapter describes the Department of Energy (DOE)’s methodology for analyzing the 

economic impacts of possible energy efficiency standards on individual consumers. The effect 

of standards on individual consumers includes a change in operating expense (usually decreased) 

and a change in purchase price (usually increased). This chapter describes three metrics DOE 

used in the consumer analysis to determine the effect of standards on individual consumers: 

•	 Life-cycle cost (LCC) is the total consumer expense over the life of an appliance, 

including purchase expense and operating costs (including energy expenditures). DOE 

discounts future operating costs to the time of purchase, and sums them over the lifetime 

of the equipment. 

•	 Payback period (PBP) measures the amount of time it takes customers to recover the 

assumed higher purchase price of more energy-efficient equipment through lower 

operating costs. 

•	 Rebuttable payback period is a special case of the PBP. Where LCC and PBP are 

estimated over a range of inputs reflecting actual conditions, rebuttable payback period is 

based on laboratory conditions, specifically DOE test procedure inputs. 

Inputs to the LCC and PBP are discussed in sections 8.2 and 8.3, respectively, of this 

chapter. Results for the LCC and PBP are presented in section 8.4. The rebuttable PBP is 

discussed in section 8.5. Key variables and calculations are presented for each metric. DOE 

performed the calculations discussed here using a series of Microsoft Excel® spreadsheets which 

are accessible on the Internet (http://www.eere.energy.gov/buildings/appliance_standards/). 

Details and instructions for using the spreadsheets are discussed in Appendix 8A. 

This chapter presents information and results pertaining solely to CCWs. As described in 

section 1.3 of chapter 1 of this technical support document (TSD), DOE is continuing the 

rulemaking for energy conservation standards for microwave oven standby power, and analyses 

related to these products will be published in a separate TSD. In addition, DOE issued a final 

rule1

 adopting energy conservation standards for conventional cooking products (i.e., cooktops 

and ovens) and microwave oven energy factor (EF), and details of the analyses for these products 

are contained in the corresponding final rule TSD.2 

8.1.1 General Approach for LCC and PBP Analysis 

Recognizing that several inputs to the determination of consumer LCC and PBP are 

either variable or uncertain, DOE conducted the LCC and PBP analysis by modeling both the 

uncertainty and variability in the inputs using Monte Carlo simulation and probability 

8-1 

EERE-2006-STD-0127 COMMENT 69.1
distributions. A detailed explanation of Monte Carlo simulation and the use of probability 

distributions is contained in Appendix 8B. DOE developed LCC and PBP spreadsheet models 

incorporating both Monte Carlo simulation and probability distributions by using Microsoft 

Excel® spreadsheets combined with Crystal Ball® (a commercially available add-in program). 

As described in Chapter 6, DOE established the variability and uncertainty in energy and 

water use by defining the uncertainty and variability in the usage (in cycles per day) of the 

equipment. As will be described later in this chapter, the variability and uncertainty in energy 

and water pricing are characterized by regional differences in energy and water prices. 

DOE displays the LCC and PBP results as distributions of impacts compared to the 

baseline conditions. Results are presented at the end of this chapter and are based on 10,000 

samples per Monte Carlo simulation run. To illustrate the implications of the analysis, DOE 

generated a frequency chart depicting the variation in LCC and PBP for each standard level 

considered. 

8.1.2 Overview of LCC and PBP Inputs 

The LCC is the total consumer expense over the life of the equipment, including purchase 

expense and operating expense (including energy expenditures). DOE discounts future operating 

expenses to the time of purchase and sums them over the lifetime of the equipment. The PBP is 

the change in purchase expense due to an increased efficiency standard divided by the change in 

annual operating expense that results from the standard. It represents the number of years it will 

take the customer to recover the increased purchase expense through decreased operating 

expenses. 

DOE categorizes inputs to the LCC and PBP analysis as follows: (1) inputs for 

establishing the purchase expense, otherwise known as the total installed cost, and (2) inputs for 

calculating the operating cost. 

The primary inputs for establishing the total installed cost are: 

•	 Baseline manufacturer cost: The costs incurred by the manufacturer to produce 

equipment meeting existing minimum efficiency standards. 

•	 Standard-level manufacturer cost increases: The change in manufacturer cost associated 

with producing equipment to meet a particular standard level. 

•	 Markups and sales tax: The markups and sales tax associated with converting the 

manufacturer cost to a consumer equipment price. The markups and sale tax are 

described in detail in Chapter 7, Markups for Equipment Price Determination. 

•	 Installation cost: The cost to the consumer of installing the equipment. The installation 

cost represents all costs required to install the equipment other than the marked-up 

consumer equipment price. The installation cost includes labor, overhead, and any 

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EERE-2006-STD-0127 COMMENT 69.1
 

miscellaneous materials and parts. Thus, the total installed cost equals the consumer 

equipment price plus the installation cost. 

The primary inputs for calculating the operating cost are: 

•	 Equipment energy and water consumption: The equipment energy consumption is the 

site energy use associated with operating the equipment. The water consumption is the 

site water use associated with operating the equipment. Chapter 6, Energy and Water 

Use Determination, details how DOE determined the equipment energy and water 

consumption based on various data sources. 

•	 Equipment efficiency: The equipment efficiency dictates the equipment energy and water 

consumption associated with standard-level equipment (i.e., equipment with efficiencies 

greater than baseline equipment). Chapter 6, Energy and Water Use Determination, 

details how energy and water consumption change with increasing equipment efficiency. 

•	 Energy and water prices: Energy and water prices are the prices paid by consumers for 

energy (i.e., electricity, gas, or oil) and water. DOE determined current energy prices 

based on data from the DOE- EIA. DOE determined water prices based on data from the 

American Water Works Association (AWWA). 

•	 Energy and water price trends: DOE used the EIA Annual Energy Outlook 2009 

(AEO2009) to forecast energy prices into the future. For the results presented in this 

chapter, DOE used the AEO2009 reference case to forecast future energy prices. DOE 

used consumer price index data specific to water and sewerage maintenance from the 

Bureau of Labor Statistics as the basis for its water price trend. 

•	 Repair and maintenance costs: Repair costs are associated with repairing or replacing 

components that have failed. Maintenance costs are associated with maintaining the 

operation of the equipment. 

•	 Lifetime: The age at which the equipment is retired from service. 

•	 Discount rate: The rate at which DOE discounted future expenditures to establish their 

present value. 

Figure 8.1.1 graphically depicts the relationships between the installed cost and operating 

cost inputs for the calculation of the LCC and PBP. In the figure below, the yellow boxes 

indicate the inputs, the green boxes indicate intermediate outputs, and the blue boxes indicate the 

final outputs (the LCC and PBP). 

8-3 

EERE-2006-STD-0127 COMMENT 69.1
Baseline 

Manufacturer 

Cost 

Std-Level 

Manufacturer 

Cost 

Manufacturer 

Markup 

Retailer or 

Distributor 

Markup 

Sales Tax 

Installation 

Cost 

Total Installed 

Cost 

Water Prices

 Energy and 

Water 

Consumption 

Equipment 

Price 

Lifetime 

Operating 

Expense 

Annual Energy 

and Water 

Expense 

Lifetime Repair and 

Maintenance 

Cost 

Discount Rate 

Energy and 

Water Price 

Trends 

Annual 

Operating 

Expense 

Payback 

Period 

Life-Cycle 

Cost 

Energy Prices 

Figure 8.1.1 Flow Diagram of Inputs for the Determination of LCC and PBP 

Table 8.1.1 summarizes the input values that DOE used to calculate the LCC and PBP. 

Each table summarizes the total installed cost inputs and the operating cost inputs including the 

lifetime, discount rate, and energy and water price trends. DOE characterized all of the total cost 

inputs with single-point values, but characterized several of the operating cost inputs with 

probability distributions that capture the input’s uncertainty and/or variability. For those inputs 

characterized with probability distributions, the values provided in the following tables are the 

average or typical values. Also listed in the following tables is the section of the technical 

support document (TSD) where more detailed information on the inputs can be found. 

8-4 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

Table 8.1.1 LCC and PBP Input Summary 

Input 

Product 

Class Average or Typical Value Characterization 

TSD Section 

Reference 

Total Installed Cost Inputs 

Baseline Manufacturer 

Cost 

TopLoading 1.26 MEF/9.50 WF = $296.30 Single-Point Value 

8.2.1.2 

FrontLoading 1.72 MEF/8.00 WF = $611.02 Single-Point Value 

Standard-Level 

Manufacturer Cost 

Increase 

TopLoading 1.42 MEF/9.50 WF = $77.60 

1.60 MEF/8.50 WF = $134.99 Single-Point Value 

8.2.1.3 

FrontLoading 

1.80 MEF/7.50 WF = $0.00 

2.00 MEF/5.50 WF = $14.21 

2.20 MEF/5.10 WF = $39.34 

2.35 MEF/4.40 WF = $66.16 

Single-Point Value 

Manufacturer Markup Both 1.26 Single-Point Value 7.4 

Distributor Markup Both Baseline = 1.43 

Incremental = 1.18 Single-Point Value 7.5 

Sales Tax Both 1.0690 Single-Point Value 7.6 

Installation Cost Both $190.00 Single-Point Value 8.2.1.5 

Operating Cost Inputs 

Usage Both Multi-Family = 3.4 cycles/day 

Laundromat = 6 cycles/day 

Uniform distribution: 

Multi-Family = 1.5 to 6.4 cyc/day 

Laundromat = 3 to 8 cyc/day 

6.3, 6.4 

Annual Energy Use* 

TopLoading 

Baseline use**: 

Multi-Family = 2769 kWh 

Laundromat = 4867 kWh 

Variability based on usage 

6.3 

FrontLoading 

Baseline use**: 

Multi-Family = 2028 kWh 

Laundromat = 3565 kWh 

Variability based on usage 

Annual Water Use 

TopLoading 

Baseline use**: 

Multi-Family = 33.1 103

 gallon 

Laundromat = 58.3 103

 gallon 

Variability based on usage 

6.3 

FrontLoading 

Baseline use**: 

Multi-Family = 27.9 103

 gallon 

Laundromat = 49.1 103

 gallon 

Variability based on usage 

Energy Prices Both Elec = 10.8 ¢/kWh 

Gas = 11.89 $/MMBtu Single-Point Value 8.2.2.2 

Water and Wastewater 

Prices Both Water = 2.29 $/103

 gallon 

Wastewater = 2.97 $/103

 gallon Singe-Point Value 8.2.2.2 

Repair and 

Maintenance Costs Both Annualized repair cost = 

1⁄2 Equipment price / Lifetime Single-Point Value 8.2.2.4 

Lifetime Both Multi-Family = 11.25 years 

Laundromat = 7.125 years Weibull distribution 8.2.3 

Discount Rate Both 5.7% Custom distribution 8.2.4 

Energy Price Trend Both AEO 2009 Reference Case Two sensitivities: 

High & Low Growth Cases 8.2.2.3 

Water and Wastewater 

Price Trend Both Bureau of Labor Statistics: Water and sewerage CPI Single forecast 8.2.2.3 

* Annual use based on electric water heating and electric clothes drying. 

** Annual use provided for baseline product only. Annual use decreases with increased product efficiency.
 

8-5 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

8.2 LIFE-CYCLE COST INPUTS 

Life-cycle cost is the total customer expense over the life of an appliance, including 

purchase expense and operating costs (including energy expenditures). DOE discounts future 

operating costs to the time of purchase, and sums them over the lifetime of the equipment. DOE 

defines LCC by the following equation: 

N OCt LCC = IC +∑ t (1+ r)

where: 

t=1 

LCC = Life-cycle cost in dollars, 

IC = Total installed cost in dollars, 

∑ = Sum over the lifetime, from year 1 to year N, 

N = Lifetime of appliance in years, 

OC = Operating cost in dollars, 

r = Discount rate, and 

t = Year for which operating cost is being determined. 

DOE expresses dollar values in 2008$. 

The following sections discuss total installed cost, operating cost, lifetime, and discount 

rate. 

8.2.1 Total Installed Cost Inputs 

DOE defines the total installed cost using the following equation: 

IC = EQP + INST 

where: 

EQP = Equipment price (i.e., customer price for the equipment only), expressed in 

dollars, and 

INST = Installation cost or the customer price to install equipment (i.e., the cost for 

labor and materials), also in dollars. 

The equipment price is based on how the consumer purchases the equipment. As 

discussed in Chapter 7, Markups for Equipment Price Determination, DOE defined markups and 

sales taxes for converting manufacturing costs into consumer equipment prices. 

Table 8.2.1 summarizes the inputs for the determination of total installed cost. 

8-6 

EERE-2006-STD-0127 COMMENT 69.1
 

 

Table 8.2.1 Inputs for Total Installed Cost 

Baseline Manufacturer Cost 

Standard-Level Manufacturer Cost 

Manufacturer Markup 

Retailer or Distributor Markup 

Sales Tax 

Installation Cost 

The baseline manufacturer cost is the cost incurred by the manufacturer to produce 

equipment meeting existing minimum efficiency standards. Standard-level manufacturer cost 

increases are the change in manufacturer cost associated with producing equipment at a standard 

level. Markups and sales tax convert the manufacturer cost to a consumer equipment price. The 

installation cost is the cost to the consumer of installing the equipment and represents all costs 

required to install the equipment other than the marked-up consumer equipment price. The 

installation cost includes labor, overhead, and any miscellaneous materials and parts. Thus, the 

total installed cost equals the consumer equipment price plus the installation cost. DOE 

calculated the total installed cost for baseline products based on the following equation: 

ICBASE = EQPBASE + INSTBASE 

= COSTMFG × MUOVERALL _ BASE + INSTBASE 

where: 

ICBASE = Baseline total installed cost, 

EQPBASE = Consumer equipment price for baseline models, 

INSTBASE = Baseline installation cost, 

COSTMFG = Manufacturer cost for baseline models, and 

MUOVERALL_BASE = Baseline overall markup (product of manufacturer markup, baseline 

retailer or distributor markup, and sales tax). 

DOE calculated the total installed cost for standard-level products based on the following 

equation: 

IC STD STD STD = EQP + INST

= (EQP + ΔEQP )+ ( INST + ΔINST ) BASE STD BASE STD 

= ( EQP + INST )+ ( ΔEQP + ΔINST ) BASE BASE STD STD 

= ICBASE + (ΔCOSTMFG × MUOVERALL _ INCR + ΔINSTSTD ) 

where: 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

ICSTD = Standard-level total installed cost, 

EQPSTD = Consumer equipment price for standard-level models, 

INSTSTD = Standard-level installation cost, 

EQPBASE = Consumer equipment price for baseline models, 

ΔEQPSTD = Change in equipment price for standard-level models, 

INSTBASE = Baseline installation cost, 

ΔINSTSTD = Change in installation cost for standard-level models, 

ICBASE = Baseline total installed cost, 

ΔCOSTMFG = Change in manufacturer cost for standard-level models, and 

MUOVERALL_INCR = Incremental overall markup (product of manufacturer markup, 

incremental retailer or distributor markup, and sales tax). 

The remainder of this section provides information about each of the above input 

variables that DOE used to calculate the total installed cost for cooking products, dishwashers, 

dehumidifiers, and commercial clothes washers. 

8.2.1.2 Baseline Manufacturer Cost 

DOE used residential clothes washer data from AHAM’s 2005 Fact Book to develop the 

baseline manufacturer costs for top-loading commercial clothes washers.3 According to the 

AHAM 2005 Fact Book, in the year 2005, total clothes washer sales equaled $3,373,042 million 

while total industry shipments equaled 9,394 million. DOE divided total sales by total shipments 

to arrive at an average manufacturer price of $359.06. Based on a manufacturer markup of 1.26, 

as determined in section 7.2 of Chapter 7, Markups for Equipment Price Determination, DOE 

arrived at a baseline manufacturer cost of $284.97 in 2006$. As detailed in Chapter 5, 

Engineering Analysis, DOE estimated the cost difference between top-loading and front-loading 

washers to arrive at the baseline manufacturer cost for front-loading washers. Table 8.2.2 

presents the baseline manufacturer cost as well as the associated baseline modified energy factor 

and water factor. 

Table 8.2.2 Commercial Clothes Washers: Baseline Manufacturer Costs 

Product Class 

Baseline Modified 

Energy Factor 

(cu.ft./kWh/cyc) 

Baseline 

Water Factor 

(gal/cu.ft.) 

Baseline Manufacturer 

Cost 

(2008$) 

Top-Loading 1.26 9.50 $296.30 

Front-Loading 1.72 8.00 $611.02 

Source: AHAM 2005 Fact Book. 

8.2.1.3 Standard-Level Manufacturer Cost Increases 

DOE used a combination of cost data submitted by AHAM and a reverse engineering 

analysis to develop commercial clothes washer manufacturer cost increases associated with 

increases in product standard levels. Refer to Chapter 5, Engineering Analysis, for details. 

Tables 8.2.3 and 8.2.4 present the standard-level manufacturer cost increases as well as the 

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EERE-2006-STD-0127 COMMENT 69.1
associated modified energy factors and water factors for top-loading and front-loading washers, 

respectively. 

Table 8.2.3	 Top-Loading Commercial Clothes Washers: Standard-Level Manufacturer 

Cost Increases 

Standard Level 

Modified 

Energy Factor 

(cu.ft./kWh/cyc) 

Water 

Factor 

(gal/cu.ft.) 

Standard-Level 

Manufacturer Cost Increase 

(2008$) 

Baseline 1.26 9.50 -

1 1.42 9.50 $77.60 

2 1.60 8.50 $134.99 

Table 8.2.4 Front-Loading Commercial Clothes Washers: Standard-Level Manufacturer 

Cost Increases 

Standard Level 

Modified 

Energy Factor 

(cu.ft./kWh/cyc) 

Water 

Factor 

(gal/cu.ft.) 

Standard-Level 

Manufacturer Cost Increase 

(2008$) 

Baseline 1.72 8.00 -

1 1.80 7.50 $0.00 

2 2.00 5.50 $14.21 

3 2.20 5.10 $39.34 

4 2.35 4.40 $66.16 

8.2.1.4 Overall Markup 

The overall markup is the value determined by multiplying the manufacturer and retailer 

markups and the sales tax together to arrive at a single markup value. Table 8.2.5 shows the 

overall baseline and incremental markups for commercial clothes washers. Refer to Chapter 7, 

Markups for Equipment Price Determination, for details. 

Table 8.2.5	 Overall Markups 

Markup Baseline Incremental 

Manufacturer 1.26 

Distributor 1.43 1.18 

Sales Tax 1.0690 

Overall 1.93 1.59 

8.2.1.5 Installation Cost 

DOE derived baseline installation costs for commercial clothes washers from data in the 

RS Means Mechanical Cost Data, 2008.

4

 This book provides estimates on the labor required to 

install commercial clothes washers. Table 8.2.6 summarizes the nationally representative 

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EERE-2006-STD-0127 COMMENT 69.1
average costs associated with the installation of a four-cycle, coin operating, commercial clothes 

washer as presented in RS Means Mechanical Cost Data. Table 8.2.6 provides both bare costs 

(i.e., costs before O&P) and installation costs including O&P. DOE determined that installation 

costs would not be impacted with increased standard levels. 

Table 8.2.6	 Commercial Clothes Washers: Baseline Installation Costs 

Bare Costs (2005$) Including Overhead & Profit (2005$) 

Installation Type Material Labor Total Total Material* Labor** 

Average $1,100 $125 $1,225 $1,400 $1,210 $190 

Average (2008$) $190 

* Material costs including O&P equal bare costs plus 10% profit.
 

** DOE derived labor cost including O&P by subtracting material with O&P from total with O&P. 

Source: RS Means, Mechanical Cost Data, 2008.
 

8.2.1.6 Total Installed Cost 

The total installed cost is the sum of the consumer equipment price and the installation 

cost. Refer back to section 8.2.1 to see the equations that DOE used to calculate the total 

installed cost for baseline and standard-level products. 

Tables 8.2.7 and 8.2.8 present the consumer equipment price, installation costs, and total 

installed costs for top-loading and front-loading washers, respectively. Prices and costs are 

presented at the baseline level and each standard level. 

Table 8.2.7	 Top-Loading Commercial Clothes Washers: Consumer Equipment Prices, 

Installation Costs, and Total Installed Costs 

Standard 

Level 

Modified 

Energy Factor 

(cu.ft./kWh/cyc) 

Water 

Factor 

(gal/cu.ft.) 

Equipment 

Price 

(2008$) 

Installation 

Cost 

(2008$) 

Total Installed 

Cost 

(2008$) 

Baseline 1.26 9.50 $570.71 $190.00 $760.71 

1 1.42 9.50 $694.05 $190.00 $884.05 

2 1.60 8.50 $785.26 $190.00 $975.26 

8-10 

EERE-2006-STD-0127 COMMENT 69.1
Table 8.2.8 Front-Loading Commercial Clothes Washers: Consumer Equipment Prices, 

Installation Costs, and Total Installed Costs 

Standard 

Level 

Modified 

Energy Factor 

(cu.ft./kWh/cyc) 

Water 

Factor 

(gal/cu.ft.) 

Equipment 

Price 

(2008$) 

Installation 

Cost 

(2008$) 

Total Installed 

Cost 

(2008$) 

Baseline 1.72 8.00 $1,176.90 $190.00 $1,366.90 

1 1.80 7.50 $1,176.90 $190.00 $1,366.90 

2 2.00 5.50 $1,199.48 $190.00 $1,389.48 

3 2.20 5.10 $1,239.43 $190.00 $1,429.43 

4 2.35 4.40 $1,282.05 $190.00 $1,472.05 

8.2.2 Operating Cost Inputs 

DOE defines the operating cost by the following equation: 

OC = EC +WC + RC + MC 

where: 

EC = Energy expenditure associated with operating the equipment, 

WC = For dishwashers and commercial clothes washers, the water expenditure 

associated with operating the equipment, 

RC = Repair cost associated with component failure, and 

MC = Service cost for maintaining equipment operation. 

Table 8.2.9 shows the inputs for determining the operating costs. The inputs listed in 

Table 8.2.9 are also necessary for determining lifetime operating expenses, which include the 

energy price trends (and water price trends), product lifetime, discount rate, and effective date of 

the standard. 

Table 8.2.9 Inputs for Operating Cost 

Annual Energy (and Water) Consumption 

Energy and Water Prices 

Repair and Maintenance Costs 

Energy and Water Price Trends 

Product Lifetime 

Discount Rate 

Effective Date of Standard 

The annual energy consumption is the site energy use associated with operating the 

equipment. The annual water consumption, which is applicable to commercial clothes washers, 

is the site water use associated with operating the equipment. The annual energy (and water) 

8-11 

EERE-2006-STD-0127 COMMENT 69.1
 

 

__ __ 

 

consumption vary with the product efficiency. That is, the energy and water consumption 

associated with standard-level equipment (i.e., equipment with efficiencies greater than baseline 

equipment) are less than the consumptions associated with baseline equipment. Energy and 

water prices are the prices paid by consumers for energy (i.e., electricity, gas, or oil) and water. 

Multiplying the annual energy and water consumption by the energy and water prices yields the 

annual energy cost and water cost, respectively. Repair costs are associated with repairing or 

replacing components that have failed. Maintenance costs are associated with maintaining the 

operation of the equipment. DOE used energy and water price trends to forecast energy and 

water prices into the future and, along with the product lifetime and discount rate, to establish the 

lifetime energy and water costs. The product lifetime is the age at which the equipment is retired 

from service. The discount rate is the rate at which DOE discounted future expenditures to 

establish their present value. DOE calculated the operating cost for baseline products based on 

the following equation: 

OC BASE BASE BASE BASE BASE = EC +WC + RC + MC

= AEC BASE × PRICE ENERGY + AWC BASE × PRICE WATER BASE BASE + RC + MC

where: 

OCBASE = Baseline operating cost, 

ECBASE = Energy expenditure associated with operating the baseline equipment, 

WCBASE = For commercial clothes washers, the water expenditure associated with 

operating the baseline equipment, 

RCBASE = Repair cost associated with component failure for the baseline 

equipment, 

MCBASE = Service cost for maintaining baseline equipment operation, 

AECBASE = Annual energy consumption for baseline equipment, 

PRICEENERGY = Energy price, 

AWCBASE = Annual water consumption for baseline equipment, and 

PRICEWATER = Water price. 

DOE calculated the operating cost for standard-level products based on the following equation: 

OC STD STD STD STD STD = EC +WC + RC + MC

= AEC STD × PRICE ENERGY + AWC STD × PRICE WATER STD STD + RC + MC

= (AEC BASE ΔAEC STD )× PRICEENERGY + (AWCBASE ΔAWC STD )× PRICEWATER 

+ (RC BASE + ΔRC STD )+ ( MCBASE STD + ΔMC ) 

where: 

OCSTD = Standard-level operating cost, 

ECSTD = Energy expenditure associated with operating standard-level equipment, 

8-12 

EERE-2006-STD-0127 COMMENT 69.1
 

WCSTD = For commercial clothes washers, the water expenditure associated with 

operating standard-level equipment, 

RCSTD = Repair cost associated with component failure for standard-level 

equipment, 

MCSTD = Service cost for maintaining standard-level equipment operation, 

AECSTD = Annual energy consumption for standard-level equipment, 

PRICEENERGY = Energy price, 

AWCSTD = Annual water consumption for standard-level equipment, 

PRICEWATER = Water price, 

ΔAECSTD = Change in annual energy consumption caused by standard-level 

equipment, 

ΔAWCSTD = Change in annual water consumption caused by standard-level 

equipment, 

ΔRCSTD = Change in repair cost caused by standard-level equipment, and 

ΔMCSTD = Change in maintenance cost caused by standard-level equipment. 

The remainder of this section provides information about each of the above input 

variables that DOE used to calculate the operating costs for cooking products, dishwashers, 

dehumidifiers, and commercial clothes washers. 

8.2.2.1 Annual Energy and Water Consumption 

Chapter 6, Energy and Water Use Determination, details how DOE determined the 

annual energy and water consumption for baseline and standard-level products. 

DOE characterized the variability of commercial clothes washer usage based on several 

studies. For multi-family product applications, DOE equally weighted each study to establish 

the variability. For laundromat applications, DOE used a range of values varying from three to 

eight cycles per day. Refer back to Chapter 6, section 6.4 to review how DOE characterized 

commercial clothes washer usage variability. 

The tables presented below are based on the energy and water use determination analysis 

described in Chapter 6. Keep in mind that the annual energy and water consumption values in 

the tables below are averages. DOE captured the variability in energy (and water) consumption 

when it conducted its LCC and PBP analysis. 

Tables 8.2.10 and 8.2.11 provide the average annual energy and water consumption by 

efficiency level for top-loading commercial clothes washers. Tables 8.2.12 and 8.2.13 provide 

the average annual energy and water consumption by efficiency level for front-loading 

commercial clothes washers. DOE presents annual consumption based on two applications: 

multi-family housing and laundromats. The tables below are similar to Tables 6.3.2 through 

6.3.5 in section 6.3 from Chapter 6 with the exception that, in the tables below, the electric and 

gas water heating and drying consumptions take into account the percentage of buildings in the 

U.S. that use electric and gas water heaters and dryers. In others words, the electric and gas 

water heating and drying consumption in Tables 8.2.10 through 8.2.13 are weighted by the share 

8-13 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

of buildings that use electric and gas water heaters and dryers. Based on data from the 

Consortium for Energy Efficiency (CEE), 5 the shares of electric and gas water heating and 

drying in multi-family applications are: 20 percent and 80 percent electric and gas water heating, 

respectively, and 40 percent and 60 percent electric and gas drying, respectively. Also based on 

CEE data, 100 percent of laundromats use gas water heating and drying. 

Table 8.2.10	 Top-Loading Commercial Clothes Washers, Multi-Family Application: 

Annual Energy and Water Use by Efficiency Level 

Standard 

Level 

MEF WF 

Annual Energy Use* 

Annual 

Water Use 

Water Heating** Drying*** 

Electric Gas Electric Gas Machine

cu.ft./kWh/cyc gal/cu.ft. kWh/yr MMBtu/yr kWh/yr MMBtu/yr kWh/yr 1000 gal/year 

Baseline 1.26 9.50 204 3.71 633 3.63 166 33.1 

1 1.42 9.50 158 2.87 601 3.45 166 33.1 

2 1.60 8.50 125 2.27 566 3.24 142 29.7 

3 1.76 8.30 101 1.84 534 3.06 142 29.0 

* Annual usage based on 3.4 cycles per day (1241 cycles per year). 

** Electric and gas water heating based on water heater efficiencies of 100% for electric and 75% for gas. Water 

heater consumption is weighted by the share of buildings with electric (20%) and gas (80%) water heaters. 

*** Dryer consumption is weighted by the share of buildings with electric (40%) and gas (60%) dryers. 

Table 8.2.11	 Top-Loading Commercial Clothes Washers, Laundromat Application: 

Annual Energy and Water Use by Efficiency Level 

Standard 

Level 

MEF WF 

Annual Energy Use* 

Annual 

Water Use 

Water Heating** Drying*** 

Electric Gas Electric Gas Machine

cu.ft./kWh/cyc gal/cu.ft. kWh/yr MMBtu/yr kWh/yr MMBtu/yr kWh/yr 1000 gal/year 

Baseline 1.26 9.50 0 8.16 0 10.63 291 58.3 

1 1.42 9.50 0 6.30 0 10.10 291 58.3 

2 1.60 8.50 0 4.99 0 9.50 250 52.1 

3 1.72 8.00 0 4.04 0 8.96 250 50.9 

* Annual usage based on 6 cycles per day (2190 cycles per year). 

** Electric and gas water heating based on water heater efficiencies of 100% for electric and 75% for gas. Water 

heater consumption is weighted by the share of buildings with electric (0%) and gas (100%) water heaters. 

*** Dryer consumption is weighted by the share of buildings with electric (0%) and gas (100%) dryers. 

8-14 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

Table 8.2.12 Front-Loading Commercial Clothes Washers, Multi-Family Application: 

Annual Energy and Water Use by Efficiency Level 

Standard 

Level 

MEF WF 

Annual Energy Use* 

Annual 

Water Use 

Water Heating** Drying*** 

Electric Gas Electric Gas Machine

cu.ft./kWh/cyc gal/cu.ft. kWh/yr MMBtu/yr kWh/yr MMBtu/yr kWh/yr 1000 gal/year 

Baseline 1.72 8.00 106 1.94 542 3.11 142 27.9 

1 1.80 7.50 96 1.75 526 3.01 142 26.2 

2 2.00 5.50 77 1.41 486 2.79 142 19.2 

3 2.20 5.10 66 1.19 446 2.56 142 17.8 

4 2.35 4.40 60 1.10 417 2.39 142 15.4 

* Annual usage based on 3.4 cycles per day (1241 cycles per year). 

** Electric and gas water heating based on water heater efficiencies of 100% for electric and 75% for gas. Water 

heater consumption is weighted by the share of buildings with electric (20%) and gas (80%) water heaters. 

*** Dryer consumption is weighted by the share of buildings with electric (40%) and gas (60%) dryers. 

Table 8.2.13	 Front-Loading Commercial Clothes Washers, Laundromat Application: 

Annual Energy and Water Use by Efficiency Level 

Standard 

Level 

MEF WF 

Annual Energy Use* 

Annual 

Water Use 

Water Heating** Drying*** 

Electric Gas Electric Gas Machine

cu.ft./kWh/cyc gal/cu.ft. kWh/yr MMBtu/yr kWh/yr MMBtu/yr kWh/yr 1000 gal/year 

Baseline 1.72 8.00 0 4.25 0 9.10 250 49.1 

1 1.80 7.50 0 3.85 0 8.83 250 46.0 

2 2.00 5.50 0 3.10 0 8.16 250 33.7 

3 2.20 5.10 0 2.62 0 7.49 250 31.3 

4 2.35 4.40 0 2.41 0 6.99 250 27.0 

* Annual usage based on 6 cycles per day (2190 cycles per year). 

** Electric and gas water heating based on water heater efficiencies of 100% for electric and 75% for gas. Water 

heater consumption is weighted by the share of buildings with electric (0%) and gas (100%) water heaters. 

*** Dryer consumption is weighted by the share of buildings with electric (0%) and gas (100%) dryers. 

8.2.2.2 Energy and Water Prices 

DOE derived energy prices for 13 geographic areas in the U.S. and derived water prices 

for the four Census regions. Using these data, DOE analyzed the variability of energy and water 

prices at the regional level for cooking products and commercial clothes washers. 

DOE characterized energy and water price regional variability with probability 

distributions. It based the probability associated with each regional energy and water price on 

the population weight of each region. 

8-15 

EERE-2006-STD-0127 COMMENT 69.1
The methodology that DOE used for deriving the energy and water prices is presented 

below. Included are tables that summarize the regional energy and water prices for each product. 

Energy Prices 

DOE derived average energy prices from data from EIA. DOE calculated prices for each 

of 13 geographic areas: the nine U.S. Census divisions, with four large States (New York, 

Florida, Texas, and California) treated separately. For Census divisions containing one of these 

large States, DOE calculated the regional average values leaving out data for the large State—for 

example, the Pacific region average does not include California, and the West South Central does 

not include Texas. 

Commercial Electricity Prices 

DOE estimated electricity prices for commercial consumers in each of the above 

geographic areas using EIA Form 861 data.6 These data are published annually and include 

annual electricity sales in kilowatt hours (kWh), revenues from electricity sales, and number of 

consumers, for the residential, commercial, and industrial sectors, for every utility serving final 

consumers. The calculation of an average residential electricity price proceeds in two steps: 

1.	 For each utility, estimate an average residential price by dividing the residential revenues 

by residential sales. 

2.	 Calculate a regional average price, weighting each utility with customers in a region by 

the number of residential consumers served in that region. 

Table 8.2.14 shows the results for each geographic region. 

8-16 

EERE-2006-STD-0127 COMMENT 69.1
 

Table 8.2.14 Average Commercial Electricity Prices in 2007 

Geographic Area Average Price (2007$/kWh) 

New England $0.148 

Middle Atlantic (excludes NY) $0.107 

East North Central $0.088 

West North Central $0.072 

South Atlantic (excludes FL) $0.082 

East South Central $0.083 

West South Central (excludes TX) $0.082 

Mountain $0.081 

Pacific (excludes CA) $0.091 

New York $0.163 

Florida $0.131 

Texas $0.115 

California $0.098 

Source: EIA Form 861. 

Table 8.2.15 shows the national average commercial electricity prices for commercial 

clothes washers based on the relative residential consumer weight of each geographic area. DOE 

used 2006 population estimates from the U.S. Census as a proxy to estimate how the national 

saturation of commercial clothes washers was distributed over the 13 geographic areas.7 

Because DOE conducted the LCC and PBP analysis in 2008$, all electricity prices are in 2008$. 

To perform the necessary monetary conversion, DOE used the GDP to convert the electricity 

prices from 2007$ to 2008$. 

8-17 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

Table 8.2.15 Average Commercial Electricity Prices for Commercial Clothes Washers in 

2008 

Geographic Area 

Average Price 

(2008$/kWh)** Saturations* 

New England $0.156 4.8% 

Middle Atlantic (excludes NY) $0.114 7.1% 

East North Central $0.093 15.5% 

West North Central $0.076 6.7% 

South Atlantic (excludes FL) $0.087 13.0% 

East South Central $0.088 5.9% 

West South Central (excludes TX) $0.087 3.6% 

Mountain $0.085 7.0% 

Pacific (excludes CA) $0.096 4.0% 

New York $0.172 6.4% 

Florida $0.139 6.0% 

Texas $0.121 7.9% 

California $0.104 12.2% 

National Average Price (2008$/kWh) $0.108 -

* Saturations based on 2006 population estimates from Census. 

** Converted to 2008$ by multiplying costs in 2007$ by the ratio of 2008 GDP (1.1981) to 2007 GDP (1.1727). 

Converted the price for year 2007 to the price in 2008 by multiplying the 2007 price by the ratio of the 

average AEO electricity price in 2008 (29.06 $/MMBtu) to average AEO electricity price in 2007 (28.03 

$/MMBtu). 

Commercial Natural Gas Prices 

DOE obtained the data for the natural gas price calculation from the EIA publication 

Natural Gas Monthly.

8

 This publication includes a compilation of monthly natural gas delivery 

volumes and average consumer prices by State, for residential, commercial, and industrial 

customers. The Department used the complete annual data for 2007 to calculate an average 

annul price for each area. The calculation of average prices proceeds in two steps: 

1.	 Calculate the annul price for each State using a simple average over the appropriate 

months. 

2.	 Calculate a regional price, weighting each State in a region by its population. 

This method differs from the method used to calculate electricity prices because EIA does not 

provide consumer- or utility-level data on gas consumption and prices. The commercial price 

units in Table 8.2.16 are in dollars per thousand cubic feet ($/tcf). 

8-18 

EERE-2006-STD-0127 COMMENT 69.1
 

Table 8.2.16 Average Commercial Natural Gas Prices in 2007 

Geographic Area Average Price (2007$/tcf) 

New England $14.12 

Middle Atlantic (excludes NY) $12.49 

East North Central $10.86 

West North Central $10.89 

South Atlantic (excludes FL) $12.94 

East South Central $12.64 

West South Central (excludes TX) $11.21 

Mountain $10.47 

Pacific (excludes CA) $13.91 

New York $11.39 

Florida $10.17 

Texas $9.99 

California $13.04 

Source: EIA Natural Gas Monthly. 

Table 8.2.17 shows the national average commercial natural gas prices for commercial 

clothes washers based on the relative commercial consumer weight of each geographic area. 

DOE used 2006 population estimates from the U.S. Census as a proxy to estimate how the 

national saturation of commercial clothes washers was distributed over the 13 geographic areas. 

Because DOE conducted the LCC and PBP analysis in 2008$, all natural gas prices are in 2008$. 

To perform the necessary monetary conversion, DOE used the GDP to convert the gas prices 

from 2007$ to 2008$. 

8-19 

EERE-2006-STD-0127 COMMENT 69.1
 

 

Table 8.2.17 Average Commercial Natural Gas Prices for Commercial Clothes Washers 

in 2008 

Geographic Area 

Average Price 

(2008$/MMBtu)** Saturations* 

New England $14.43 4.8% 

Middle Atlantic (excludes NY) $12.77 7.1% 

East North Central $11.10 15.5% 

West North Central $11.14 6.7% 

South Atlantic (excludes FL) $13.23 13.0% 

East South Central $12.92 5.9% 

West South Central (excludes TX) $11.46 3.6% 

Mountain $10.70 7.0% 

Pacific (excludes CA) $14.22 4.0% 

New York $11.64 6.4% 

Florida $10.39 6.0% 

Texas $10.21 7.9% 

California $13.33 12.2% 

National Average Price (2008$/MMBtu) $11.89 -

* Saturations based on 2005 population estimates from U.S. Census. 

** 1 tcf gas = 1.03 MMBtu; Converted to 2008$ by multiplying costs in 2007$ by the ratio of 2008 GDP (1.1981) 

to 2007 GDP (1.1727). Converted the price for year 2007 to the price in 2008 by multiplying the 2007 price by 

the ratio of the average AEO gas price in 2008 (11.34 $/MMBtu) to average AEO gas price in 2007 (10.99
 

$/MMBtu).

 Water Prices 

DOE obtained water price data from the year 2006 from the Water and Wastewater Rate 

Survey conducted by Raftelis Financial Consultants and the American Water Works 

Association.9

 The survey covers approximately 216 water utilities and 153 wastewater utilities, 

with each industry analyzed separately. The water survey includes, for each utility, the cost to 

consumers of purchasing a given volume of water. In this case, the data include a division of the 

total consumer cost into fixed and volumetric charges. The calculations use only the volumetric 

charge to calculate water prices, since only this charge would be affected by a change in water 

consumption. Including the fixed charge in the average would lead to a slightly higher water 

price. 

The Water and Wastewater Rate Survey provides prices separately for residential and 

non-residential customers. For wastewater utilities, the format is similar, but the cost refers to 

the cost of treating a given volume of wastewater. In both surveys, the non-residential sector is 

divided into four sub-sectors based on the average monthly volume of water delivered or, 

equivalently, the size of the delivery pipe. The sub-sectors are named non-manufacturing, 

commercial, industrial 1, and industrial 2. DOE’s analysis uses the commercial category to 

estimate prices for commercial consumers. 

8-20 

EERE-2006-STD-0127 COMMENT 69.1
 

 

A sample of 216 utilities is not large enough to calculate regional prices for all U.S. 

Census divisions and large States (for comparison, the EIA Form 861 data include more than 

3000 utilities). For this reason, DOE calculated regional values at the Census region level 

(Northeast, South, Midwest, and West). The calculation of average per-unit-volume prices 

proceeds in three steps: 

1.	 For each utility, calculate the per-unit-volume price by dividing the total volumetric cost 

by the volume delivered. 

2.	 Calculate a State-level average price by weighting each utility in a given State by the 

number of consumers it serves (either residential or commercial). 

3.	 Calculate a regional average by combining the State-level averages, weighting each by 

the population of that State. This third step helps reduce any bias in the sample that may 

occur due to relative under-sampling of large States. 

The results of the calculation for the commercial sector are presented in Table 8.2.18. The price 

units in the table are dollars per thousand gallons ($/tg). 

Table 8.2.18 Average Per-Unit-Volume Water Prices in 2006 

 Commercial 

Region 2005$/tg Water 2005$/tg Wastewater 

Northeast $2.03 $3.06 

Midwest $1.62 $2.30 

South $2.00 $2.27 

West $2.00 $2.54 

Table 8.2.19 shows the national average commercial water and wastewater prices for 

commercial clothes washers based on the relative commercial consumer weight of each region. 

DOE used 2006 population estimates from the U.S. Census as a proxy to estimate how the 

national saturation of commercial clothes washers was distributed over the four regions. 

Because DOE conducted the LCC and PBP analysis in 2008$, it needed to convert all water 

prices into 2008$. To perform the necessary monetary conversion, DOE used the GDP to 

convert the water and wastewater prices from 2005$ to 2008$. 

8-21 

EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

Table 8.2.19 Average Per-Unit-Volume Water Prices for Commercial Clothes Washers in 

2008 

Region 2008$/tg Water** 2008$/tg Wastewater** Saturations* 

Northeast $2.42 $3.65 18.3% 

Midwest $1.93 $2.75 22.1% 

South $2.39 $2.71 36.4% 

West $2.39 $3.03 23.2% 

National $2.29 $2.97 -

* Saturations based on 2006 population estimates from Census.
 

** Converted to 2008$ by multiplying costs in 2005$ by the ratio of 2008 GDP (1.1981) to 2004 GDP (1.1193). 

Converted the price for year 2006 to the price in 2008 by multiplying the 2006 price by the ratio of the average 

water CPI in 2008 (331.33) to average water CPI in 2006 (297.20). 

8.2.2.3 Energy and Water Price Trends 

DOE used price forecasts by the EIA to estimate the trends in natural gas, oil, and 

electricity prices. To arrive at prices in future years, it multiplied the average prices described in 

the preceding section (section 8.2.2.2) by the forecast of annual average price changes in EIA’s 

AEO 2009 updated to reflect the American Recovery and Reinvestment Act (AEO 2009 

ARRA).10 To estimate the trend after 2030, DOE followed past guidelines provided to the 

Federal Energy Management Program (FEMP) by EIA and used the average rate of change 

during 2020–2030. 

The Department set up its analysis to calculate LCC and PBP using three separate 

projections: Reference, Low Economic Growth, and High Economic Growth. These three cases 

reflect the uncertainty of economic growth in the forecast period. The high and low growth 

cases show the projected effects of alternative growth assumptions on energy markets. The AEO 

2009 ARRA provides only forecasts for the Reference Case. Therefore, DOE used the highgrowth case and low-growth forecasts from the AEO 2009 March release to estimate high and 

low growth price trends.11 Figures 8.2.1 and 8.2.2 show the commercial electricity and natural 

gas price trends, respectively, based on the three projections. For the LCC results presented in 

section 8.4, DOE used only the energy price forecasts from the AEO 2009 ARRA Reference 

Case. 

8-22 

EERE-2006-STD-0127 COMMENT 69.1
0.80 

0.85 

0.90 

0.95 

1.00 

1.05 

1.10 

1.15 

1.20 

1.25 

2005 2010 2015 2020 2025 2030 2035 2040 2045 

Year 

Price Trend (2008 = 1) 

High Grow th Case 

Reference Case 

Low Grow th Case 

Figure 8.2.1 Electricity Price Trends 

0.70 

0.80 

0.90 

1.00 

1.10 

1.20 

1.30 

1.40 

1.50 

2005 2010 2015 2020 2025 2030 2035 2040 2045 

Year 

Price Trend (2008 = 1) 

High Grow th Case 

Reference Case 

Low Grow th Case 

Figure 8.2.2 Natural Gas Price Trends 

8-23
 

EERE-2006-STD-0127 COMMENT 69.1
To estimate the future trend for water and wastewater prices, DOE used data on the 

historic trend in the national water price index (U.S. city average) from 1970 through 2008.12 

DOE extrapolated the future trend based on the linear growth from 1970 to 2008. But rather than 

use the extrapolated trend to forecast the prices for the four years after 2008, DOE pinned the 

annual price to the value in 2008. Otherwise, forecasted prices for this four-year time period 

would have been up to eight percent lower than the price in 2008. Beyond the four-year time 

period, DOE used the extrapolated trend to forecast prices out to the year 2043. Figure 8.2.3 

shows the historical and projected water price trend data. DOE used the forecasted data to 

estimate water and wastewater prices for commercial clothes washers. 

0 

100 

200 

300 

400 

500 

600 

1970 1980 1990 2000 2010 2020 2030 2040 

Year 

Water CPI 

Water Price CPI 

Linear Extrapolation 

Figure 8.2.3 Water Price Trend 

8.2.2.4 Repair and Maintenance Costs 

Typically, small incremental changes in product efficiency incur no, or only very small, 

changes in repair and maintenance costs over baseline products. However, equipment with 

efficiencies that are significantly higher than the baseline are more likely to incur higher repair 

and maintenance costs because its higher complexity and higher part count typically increases 

the cumulative probability of failure. 

The Whirlpool Corporation estimates that the unit shipments of horizontal-axis 

commercial clothes washers are less than half that of vertical-axis machines while their inwarranty repair costs are double that of vertical-axis machines.13 This suggests that the repair of 

8-24 

EERE-2006-STD-0127 COMMENT 69.1
 

horizontal-axis machines is four times as costly as that of vertical-axis machines. Because inwarranty repair costs, based on Whirlpool’s experience, are greater for horizontal-axis machines 

that vertical-axis machines, DOE estimated that commercial clothes washer repair costs would 

increase as a function of equipment efficiency. DOE utilized an algorithm developed for central 

air conditioners and heat pumps to estimate repair cost increases.14 This algorithm calculates 

annualized repair costs by dividing the half the equipment retail price by the equipment lifetime 

as show in the expression below: 

0.5 × EQP RCANNUAL = LIFE 

where: 

RCANNUAL = Annualized repair cost associated with equipment, 

EQP = Consumer equipment price, and 

LIFE = Product lifetime. 

Tables 8.2.20 and 8.2.21 show for each product class and each product application 

(multi-family buildings and laundromats) the annualized repair costs for the commercial clothes 

washer baseline and efficiency levels. Annualized repair costs for each product application 

differ because commercial clothes washer lifetime is different for each application. (Product 

lifetimes are presented below is section 8.2.3.) The tables also present the consumer equipment 

prices for the baseline level and each efficiency level. 

Table 8.2.20 Top-Loading Commercial Clothes Washer Annualized Repair Costs 

Level 

Modified 

Energy Factor 

(cu.ft./kWh/cyc) 

Water 

Factor 

(gal/cu.ft.) 

Equipment 

Price 

(2008$) 

Annualized Repair Cost (2008$) 

Multi-Family* Laundromat* 

Baseline 1.26 9.50 $570.71 $25.36 $40.05 

1 1.42 9.50 $694.05 $30.85 $48.71 

2 1.60 8.50 $785.26 $34.90 $55.11 

* Average product lifetime: Multi-family = 11.3 years; Laundromat = 7.1 years. 

Table 8.2.21 Front-Loading Commercial Clothes Washer Annualized Repair Costs 

Level 

Modified 

Energy Factor 

(cu.ft./kWh/cyc) 

Water 

Factor 

(gal/cu.ft.) 

Equipment 

Price 

(2008$) 

Annualized Repair Cost (2008$) 

Multi-Family* Laundromat* 

Baseline 1.72 8.00 $1176.90 $52.31 $82.59 

1 1.80 7.50 $1176.90 $52.31 $82.59 

2 2.00 5.50 $1199.48 $53.31 $84.17 

3 2.20 5.10 $1239.43 $55.09 $86.98 

4 2.35 4.40 $1282.05 $56.98 $89.97 

* Average product lifetime: Multi-family = 11.3 years; Laundromat = 7.1 years. 

8-25 

EERE-2006-STD-0127 COMMENT 69.1
8.2.3 Product Lifetime 

DOE used only primary sources of data to estimate product lifetimes. DOE considered 

the sources listed in Table 8.2.22 to estimate product lifetime. 

Table 8.2.22	 Commercial Clothes Washers: Product Lifetime Estimates and Sources 

Lifetime (years) Source 

7 to 10 CEE (1998) 5 

Top-Loading (12 to 14 lbs.): 5 to 8* 

Front-Loading (18 to 50 lbs.): 10 to 15** CLA 15 

8 to 9*** ACEEE (2001) 16 

5 (high-use)* to 13 (low-use)** Southern California Edison (2000) 17 

15** † CALMAC (2000) 18 

* Used to establish laundromat lifetime only. 

** Used to establish multi-family lifetime only. 

*** Depending on the usage rate, the life can be shorter. 

†

 Based on engineering judgment. 

Because DOE conducted the LCC analysis based on analyzing two product 

applications—multi-family and laundromats—it established separate lifetimes for each product 

application. Because clothes washers in multi-family applications are used less frequently than 

in laundromats, DOE decided to use only those sources that indicated lifetimes of seven years or 

greater for multi-family applications. For laundromats applications, where clothes washers 

receive heavier use, DOE decided to use only those sources that indicated lifetimes of 10 years 

or less. DOE then took an average of the lifetime estimates that met the above criteria. For 

multi-family applications the average lifetime turned out to be 11.3 years, while the average 

lifetime for laundromats was 7.1 years. DOE used the low estimate for the above applicable 

sources to establish the minimum product lifetime for each product application. For multi-family 

applications the minimum estimate is 7 years and for laundromats it is 5 years. To establish the 

maximum product lifetime, DOE took the difference between the minimum and average values 

(4.3 years for multi-family and 2.1 years for laundromats) and added it to the average product 

lifetime. The minimum, average, and maximum lifetime estimates for each product application 

are shown in Table 8.2.23. 

Table 8.2.23	 Commercial Clothes Washers: Average, Minimum, and Maximum Product 

Lifetimes 

Product 

Minimum 

years 

Average 

years 

Maximum 

years 

Multi-Family 

Laundromats 

7.0 

5.0 

11.3 

7.1 

15.5 

9.3 

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EERE-2006-STD-0127 COMMENT 69.1
 

DOE characterized the clothes washer product lifetimes for each product application with 

Weibull distributions. Appendix 8C presents the Weibull distributions for commercial clothes 

washers that DOE used in the LCC and PBP analysis. 

8.2.4 Discount Rates 

DOE derived the discount rates for the LCC and PBP analysis from estimates of the 

finance cost of purchasing the considered products. Following financial theory, the finance cost 

of raising funds to purchase appliances can be interpreted as: (1) the financial cost of any debt 

incurred to purchase equipment, or (2) the opportunity cost of any equity used to purchase 

equipment. For the residential products, the purchase of equipment for new homes entails 

different finance costs for consumers than the purchase of replacement equipment. Thus, DOE 

used different discount rates for new construction and replacement installations. 

For commercial clothes washers, DOE derived the discount rate from the cost of capital 

of publicly traded firms in the sectors that purchase commercial clothes washers.19 These 

companies typically finance equipment purchases through debt and equity capital. DOE 

estimated the cost of capital of these firms as the weighted average of the cost of equity 

financing and the cost of debt financing. 

The costs of debt and equity financing are usually obtainable from publicly available data 

about the following types of companies in the sectors that purchase commercial clothes washers: 

•	 personal services (including laundromats), 

•	 educational services (which buy washers for dormitories), 

•	 hotels, and 

•	 real estate investment trusts (REITs) (i.e., building owners, including owners of 

apartment complexes). 

Damodaran Online is a widely used source of information about company debt and 

equity financing for most types of firms, and was the source of data for this analysis on 

educational services, hotels, and REITs.20 Since Damodaran Online does not include data for 

firms in the personal services sector (SIC 7200), DOE used data from Ibbotson’s Associates for 

this sector.21 Ibbotson Associates is a leading authority on asset allocation with expertise in 

capital market expectations and portfolio implementation. 

DOE estimated the cost of equity using the capital asset pricing model (CAPM).22 The 

CAPM assumes that the cost of equity (ke) for a particular company is proportional to the 

systematic risk faced by that company, where high risk is associated with a high cost of equity 

and low risk is associated with a low cost of equity. The systematic risk facing a firm is 

determined by several variables: the risk coefficient of the firm (β), the expected return on riskfree assets (Rf), and the equity risk premium (ERP). The risk coefficient of the firm indicates the 

risk associated with that firm relative to the price variability in the stock market. The expected 

return on risk-free assets is defined by the yield on long-term government bonds. The ERP 

represents the difference between the expected stock market return and the risk-free rate. The 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

cost of equity financing is estimated using the following equation, where the variables are 

defined as above: 

ke = Rf + (β× ERP) 

where: 

ke = Cost of equity, 

Rf = Expected return on risk-free assets, 

β = Risk coefficient of the firm, and 

ERP = Equity risk premium. 

The cost of debt financing (kd) is the interest rate paid on money borrowed by a company. 

The cost of debt is estimated by adding a risk adjustment factor (Ra) to the risk-free rate. This 

risk adjustment factor depends on the variability of stock returns represented by standard 

deviations in stock prices. So for firm i, the cost of debt financing is: 

k di f ai = R + R

where: 

kd = Cost of debt financing for firm, i, 

Rf = Expected return on risk-free assets, and 

Rai = Risk adjustment factor to risk-free rate for firm, i. 

DOE estimates the weighted-average cost of capital (WACC) using the following 

equation: 

WACC = k e e d d × w + k × w

where: 

WACC = Weighted average cost of capital, 

we = Proportion of equity financing, and 

wd = Proportion of debt financing. 

The values of the parameters used in the calculations are shown in Table 8.2.24 below. 

Table 8.2.24	 Data for the Calculation of Weighted-Average Cost of Capital for Sectors 

that Purchase Commercial Clothes Washers 

Sector β Rf ERP Ra we wd 

Personal Services 0.53 5.2% 5.1% 0.8% 67.4% 32.6% 

Educational Services 1.09 5.2% 5.1% 2.0% 97.5% 2.5% 

Hotels 0.82 5.2% 5.1% 2.0% 73.7% 26.3% 

REIT 0.67 5.2% 5.1% 0.5% 92.6% 7.4% 

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EERE-2006-STD-0127 COMMENT 69.1
 

Based on the procedure described above and the data in Table 8.2.24, Table 8.2.25 shows 

the WACC for each of the four sectors that purchase commercial washers. 

Table 8.2.25	 Weighted Average Cost of Capital for Sectors that Purchase Commercial 

Clothes Washers 

Sector Weighted-Average Cost of Capital 

Personal Services 6.9% 

Educational Services 10.6% 

Hotels 8.5% 

REIT 8.4% 

The WACC provides an estimate of the nominal cost of capital for firms that purchase 

commercial clothes washers. The real WACC is calculated by adjusting the cost of capital by 

the expected rate of inflation using the following formula: 

1+WACC

WACCr = 1

1+ r

_ 

where: 

WACCr = Real weighted-average cost of capital, 

WACC = Weighted-average cost of capital, and 

r = Inflation rate. 

DOE applied this formula to the costs of capital shown in Table 8.2.25 which yielded the 

discount rates for each of the sectors given in Table 8.2.26. For the calculation of the discount 

rates, DOE assumed an inflation rate of 2.5 percent (the average of inflation rates over the 2001– 

2005 time period).23 Because DOE performed the discount rate calculation on companies or 

firms that typically purchase commercial clothes washers, a distribution of discount rates were 

generated within each sector. The standard deviation of the distribution for each sector is 

provided in Table 8.2.26. To obtain an average discount rate value for the entire commercial 

clothe washer industry, DOE analyzed additional data from the CEE. The CEE estimates that 

there are up to 3,000,000 commercial clothes washers in use in the United States, 2,000,000 of 

these in multi-family housing and 420,000 in laundromats.5

 DOE assumed that the remaining 

580,000 washers are used in universities and educational institutions. Using these proportions, 

DOE derived weights of 14 percent, 19.4 percent, and 66.6 percent for personal services, 

educational services, and REIT, respectively. In the absence of any data regarding hotels, DOE 

assumed the weight for educational services was applicable to hotels as well. Weighting each 

sector by its market share, DOE estimated the average discount rate for companies that purchase 

commercial washers to be 5.7 percent, assuming an inflation rate of 2.5 percent (the average of 

inflation rates over the 2001–2005 time period).22 

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EERE-2006-STD-0127 COMMENT 69.1
 

Table 8.2.26 Discount Rates for Commercial Clothes Washers 

 Discount Rate 

Sector Average Std Deviation Share 

Personal Services 4.3% 1.8% 14.0% 

Educational Services 7.9% 5.7% 9.7% 

Hotels 5.8% 2.0% 9.7% 

REIT 5.7% 2.2% 66.6% 

Average 5.7% - 100% 

To account for variation in the discount rates within each of the sectors, DOE used the 

average values and standard deviations in the table above to characterize the discount rates for 

each sector with a normal probability distribution. Because the use of the above standard 

deviations yield distributions with negative values, DOE truncated the lower end of the normal 

distribution at a discount rate of zero. DOE also truncated the higher end of the normal 

distribution in equal proportion to the truncation at the lower end to maintain the average 

discount rates shown above in Table 8.2.26. 

8.2.5 Effective Date of Standard 

The effective date is the future date when a new standard becomes operative. Based on 

DOE’s implementation report for energy conservation standards activities submitted pursuant to 

Section 136 of the Energy Policy Act of 2005, a final rule for the commercial clothes washers 

being considered for this standards rulemaking is scheduled for completion no later than January 

1, 2010. Therefore, the effective date of any new energy efficiency standards for these products 

will be three years after the final rule is published, which is January 1, 2013. The Department 

calculated the LCC for all consumers as if they each would purchase a new piece of equipment 

in the year the standard takes effect. 

8.2.6 Equipment Assignment for the Base Case 

For purposes of conducting the LCC analysis, DOE analyzed standard levels relative to a 

baseline efficiency level. However, some consumers already purchase products with efficiencies 

greater than the baseline levels. Thus, to accurately estimate the percentage of consumers that 

would be affected by a particular standard level, DOE took into account the distribution of 

product efficiencies currently in the marketplace. In other words, rather than analyzing the 

impacts of a particular standard level assuming that all consumers are currently purchasing 

products at the baseline level, DOE conducted the analysis by taking into account the full breadth 

of product efficiencies that consumers purchase under the base case (i.e., the case without new 

energy efficiency standards). 

DOE took into account the mix of commercial clothes washer efficiencies by 

characterizing the current mix of product efficiencies as a probability distribution. In other 

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EERE-2006-STD-0127 COMMENT 69.1
 

words, as DOE performed the Monte Carlo simulation, each standard level analyzed was 

evaluated against the distribution of product efficiencies in the base case. 

Rather than providing market share data, AHAM provided shipment-weighted 

efficiencies of all commercial clothes washers.24 That is, shipment-weighted efficiencies were 

not provided separately for the top-loading and front-loading product classes. For the year 2005, 

the shipment-weighted efficiencies of commercial clothes washers are 1.41 modified energy 

factor (MEF) and 10.91 water factor (WF). Based on the shipment-weighted efficiency data, 

DOE was able to derive the market share of each product class. DOE assumed a bi-modal 

market share distribution consisting of only top-loading equipment meeting current minimum 

efficiency standards of 1.26 MEF/9.5 WF and top-loading equipment with an efficiency of 2.00 

MEF/5.5 WF. Thus, by using a shipment-weighted efficiency of 1.41 MEF, DOE determined 

that the market share of 1.26 MEF/9.5 WF washers is 79.7 percent and the market share of 2.00 

MEF/5.5 WF washers is 20.3 percent.a

 DOE interprets this result as indicating that in the year 

2005, 79.7 percent of the market consists of top-loading washers while 20.3 percent is comprised 

of front-loading washers. 

Subsequent to 2005, energy efficiency tax incentives in the Energy Policy Act of 2005 

and extensions as well as new provisions in the Economic Stabilization Act of 2008 have 

resulted in more front-loading washers being produced by manufacturers. DOE reviewed the 

U.S. Securities and Exchange Commission (SEC) 10K report of the low volume manufacturer 

(LVM) of commercial clothes washers and determined that manufacturer tax credits in this 

recent federal legislation have resulted in significantly increased sales of the front-loading 

washers for the LVM. When accounting for the LVM’s market share, the increase in frontloading sales results in a current market share of 30 percent for front-loading washers. Although 

tax credits are set to expire after 2010, DOE estimates that the tax credits would permanently 

transform the market so that front-loading washers would continue to comprise 30 percent of the 

market over the entire forecast period. 

Knowing the market share of each product class does not provide the distribution of 

equipment efficiencies within each class. Therefore, DOE relied on anther data source—the 

California Energy Commission (CEC).25 As discussed in Section 3.14.3 of Chapter 3, Market 

and Technology Assessment, the CEC publishes the MEFs and WFs of commercial clothes 

washers sold in California. Although the range in efficiencies is relatively wide, the distribution 

is based on the number of available models being sold rather than the percent of shipments being 

sold. Without any other data available, DOE assumed that the distribution of available models in 

the CEC data were representative of actual shipments sold in the U.S. Tables 8.2.27 and 8.2.28 

present the market shares of the efficiency levels in the base case for top-loading and frontloading washers, respectively. The tables represent the equipment that establishments would 

have purchased in the year 2013 in the absence of new standards. 

a

 DOE did not consider the shipment-weighted average WF of 10.91 in performing the market share calculation. 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

Table 8.2.27 Top-Loading Commercial Clothes Washers: Base Case Market Shares 

Standard Level MEF WF Market Share 

Baseline 1.26 9.50 64.8%* 

1 1.42 9.50 33.8%** 

2 1.60 8.50 1.4%*** 

* Represents units with the following MEF and WF ratings: 1.26 ≤ MEF < 1.42; 9.5 ≥ WF > 8.5. 

** Represents units with the following MEF and WF ratings: 1.42 ≤ MEF < 1.60; 9.5 ≥ WF > 8.5. 

*** Represents units with the following MEF and WF ratings: MEF ≥ 1.60; WF ≤ 8.5. 

Table 8.2.28 Front-Loading Commercial Clothes Washers: Base Case Market Shares 

Standard Level MEF WF Market Share 

Baseline 1.72 8.00 3.5%* 

1 1.80 7.50 0.0%** 

2 2.00 5.50 73.7%*** 

3 2.20 5.10 22.8%† 

4 2.35 4.40 0.0%†† 

* Represents units with the following MEF and WF ratings: 1.72 ≤ MEF < 1.80; 8.0 ≥ WF > 7.5. 

** Represents units with the following MEF and WF ratings: 1.80 ≤ MEF < 2.00; 7.5 ≥ WF > 5.5. 

*** Represents units with the following MEF and WF ratings: 2.00 ≤ MEF < 2.20; 5.5 ≥ WF > 5.1. 

†

 Represents units with the following MEF and WF ratings: 2.20 ≤ MEF < 2.35; 5.1 ≥ WF > 4.4. 

†† Represents units with the following MEF and WF ratings: MEF ≥ 2.35; WF ≤ 4.4. 

8.3 PAYBACK PERIOD INPUTS 

The payback period is the amount of time it takes the consumer to recover the assumed 

higher purchase expense of more energy-efficient equipment as a result of lower operating costs. 

Numerically, the PBP is the ratio of the increase in purchase expense (i.e., from a less efficient 

design to a more efficient design) to the decrease in annual operating expenditures. This type of 

calculation is known as a “simple” payback period, because it does not take into account changes 

in operating expense over time or the time value of money; i.e., the calculation is done at an 

effective discount rate of zero percent. 

The equation for PBP is: 

ΔIC

PBP = 

ΔOC 

where: 

ΔIC = Difference in the total installed cost between the more efficient standard level 

and the baseline design, and 

ΔOC = difference in annual operating expenses. 

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EERE-2006-STD-0127 COMMENT 69.1
 

Payback periods are expressed in years. Payback periods greater than the life of the 

product mean that the increased total installed cost is not recovered in reduced operating 

expenses. 

The data inputs to PBP are the total installed cost of the equipment to the consumer for 

each efficiency level and the annual (first year) operating expenditures for each standard level. 

The inputs to the total installed cost are the equipment price and the installation cost. The inputs 

to the operating costs are the annual energy (and water) cost, the annual repair cost, and the 

annual maintenance cost. The PBP uses the same inputs as the LCC analysis as described in 

section 8.2, except that energy (and water) price trends and discount rates are not required. Since 

the PBP is a “simple” payback, the required energy price is only for the year in which a new 

standard is to take effect—in this case, the year 2013. The energy price DOE used in the PBP 

calculation was the price projected for that year. Discount rates are also not required for the 

simple PBP calculation. 

8.4 LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS 

This section presents the LCC and PBP results for commercial clothes washers. DOE’s 

approach for conducting the LCC analysis relied on characterizing the uncertainty and variability 

of many of the inputs to the analysis with probability distributions. DOE used a Monte Carlo 

simulation technique to perform the LCC calculations. DOE calculated the average LCC and 

LCC savings and the median and average PBP for each of the candidate standard levels. These 

standard levels are also referred to as candidate standard levels (CSL). 

DOE calculated LCC savings and PBPs relative to the base case equipment that it 

assigned to commercial consumers. As discussed in section 8.2.6, DOE assigned base case 

equipment that is more efficient than some of the CSLs. For that reason, the average LCC 

impacts are not equal to the difference between the LCC of a specific and the LCC of the 

baseline equipment. 

In the subsections below, DOE presents figures showing the distribution of LCCs in the 

base case for each product class. Also presented below for a specific are figures showing the 

distribution of LCC impacts and the distribution of PBPs. The figures are presented as frequency 

charts that show the distribution of LCCs, LCC impacts, and PBPs with their corresponding 

probability of occurrence. DOE generated the figures for the distributions from a Monte Carlo 

simulation run based on 10,000 samples. The LCC and PBP calculations were performed 10,000 

times by sampling from the probability distributions that DOE developed to characterize many of 

the inputs. 

Based on the Monte Carlo simulations that DOE performed, for each standard-level, 

DOE calculated the share of commercial consumers with a net LCC benefit, with a net LCC cost, 

and with no impact. DOE considered a commercial user to receive no impact at a given if DOE 

assigned it base case equipment that is the same as or has higher efficiency than the CSL. To 

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EERE-2006-STD-0127 COMMENT 69.1
illustrate the range of LCC and PBP impacts among the commercial clothes washer users, the 

sections below present figures that provide such information for each product class. 

8.4.1 Base Case LCC Distributions 

Figures 8.4.1 and 8.4.2 show the frequency charts for the base case LCC for both product 

applications of top-loading commercial clothes washers. Figures 8.4.3 and 8.4.4 show the 

frequency charts for the base case LCC for both product applications of top-loading commercial 

clothes washers.The figures below show the mean LCC of the base case distribution as well as 

the full range of LCCs. 

Frequency Chart 

Mean= $4,023 

.000 

.005 

.009 

.014 

.018 

0 

45.75 

91.5 

137.2 

183 

$1,629 $3,170 $4,711 $6,252 $7,793 

10,000 Trials 9,779 Displayed 

Forecast: Top MF: LCC Lev 0 

Figure 8.4.1 Top-Loading Commercial Clothes Washers, Multi-Family 

Application: Base Case LCC Distribution 

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EERE-2006-STD-0127 COMMENT 69.1
Frequency Chart 

Mean= $4,182 

.000 

.004 

.008 

.012 

.016 

0 

40.5 

81 

121.5 

162 

$2,139 $3,160 $4,182 $5,203 $6,225 

10,000 Trials 9,910 Displayed 

Forecast: Top Laun: LCC Lev 0 

Figure 8.4.2 Top-Loading Commercial Clothes Washers, Laundromat 

Application: Base Case LCC Distribution 

Frequency Chart 

Mean= $4,220 

.000 

.004 

.008 

.013 

.017 

0 

42.25 

84.5 

126.7 

169 

$2,218 $3,481 $4,743 $6,005 $7,267 

10,000 Trials 9,777 Displayed 

Forecast: Front MF: LCC Lev 0 

Figure 8.4.3 Front-Loading Commercial Clothes Washers, Multi-Family 

Application: Base Case LCC Distribution 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

Frequency Chart 

Mean= $4,380 

.000 

.004 

.008 

.013 

.017 

0 

42 

84 

126 

168 

$2,689 $3,534 $4,380 $5,225 $6,070 

10,000 Trials 9,907 Displayed 

Forecast: Front Laun: LCC Lev 0 

Figure 8.4.4	 Front-Loading Commercial Clothes Washers, Laundromat 

Application: Base Case LCC Distribution 

8.4.2 Standard-Level Distributions of LCC Impacts 

Figure 8.4.5 is an example of a frequency chart showing the distribution of LCC 

differences for the case of CSL 2 for top-loading washers, multi-family product application. In 

the figure, a text box next to a vertical line at that value on the x-axis shows the mean change in 

LCC (a savings of $179 in the example here). The note, “Certainty is 86.34% from $0 to 

+Infinity,” means that 86.34 percent of consumers using clothes washers will have LCC savings 

or not be impacted due to the CSL compared to the base case. The large ‘spike’ in Figure 8.4.5 

represents the percentage of consumers that are not impacted by an increase in the CSL, i.e., 

consumers that already use commercial clothes washers with efficiencies greater than or equal to 

the CSL. Refer back to section 8.2.6 on the distribution of product efficiencies under the base 

case. DOE can generate a frequency chart like the one shown in Figure 8.4.5 for every CSL and 

each product application. 

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EERE-2006-STD-0127 COMMENT 69.1
Frequency Chart 

Certainty is 86.34% from $0 to +Infinity 

Mean = $179 

.000 

.006 

.012 

.018 

.024 

0 

58.75 

117.5 

176.2 

235 

($146) $61 $268 $474 $681 

10,000 Trials 9,750 Displayed 

Forecast: To p MF: LCC Sav Lev 2 

Figure 8.4.5	 Top-Loading Commercial Clothes Washers, Multi-Family 

Application: Distribution of LCC Impacts for CSL 2 

8.4.3 Standard-Level PBP Distributions 

Figure 8.4.6 is an example of a frequency chart showing the distribution of payback 

periods of CSL 2 for top-loading washer, multi-family product application. The large ‘spike’ at 

the PBP value of -2.00 indicates the percentage of consumers using commercial clothes washers 

that are not impacted by an increase in the CSL, i.e., consumers that already use top-loading 

commercial clothes washers with efficiencies equal to or greater than then CSL. Refer back to 

section 8.2.6 on the distribution of product efficiencies under the base case. DOE can generate a 

frequency chart like the one shown in Figure 8.4.6 for every CSL and each product application. 

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EERE-2006-STD-0127 COMMENT 69.1
Frequency Chart 

.000 

.008 

.017 

.025 

.033 

0 

83 

166 

249 

332 

-2.00 2.32 6.63 10.95 15.26 

10,000 Trials 9,534 Displayed 

Forecast: Top MF: PB Lev 2 

Figure 8.4.6	 Commercial Clothes Washers, Multi-Family Application:
 

Distribution of PBPs for CSL 3 

8.4.4 LCC and PBP Results 

Tables 8.4.1 and 8.4.2 show the LCC and PBP results for both product applications of 

top-loading commercial clothes washers. Tables 8.4.3 and 8.4.4 show the LCC and PBP results 

for both product applications of front-loading commercial clothes washers. For example, in the 

case of the front-loading washer, multi-family application, CSL 2 (2.00 MEF/5.50 WF) shows an 

average LCC savings of $19.5. Note that for CSL 2, approximately 96 percent of consumers in 

2013 are assumed to already be using a commercial clothes washer in the base case at CSL 2 and 

thus have zero savings due to the standard. If one compares the LCC of the base case at 1.72 

MEF/8.00 WF to the standards case at 2.00 MEF/5.50 WF, then the average LCC savings are 

$530. But since the base case includes a significant number of consumers that are not impacted 

by the standard, the average savings over all of the consumers is $19.5. With regard to the PBPs 

shown below, DOE determined the median and average values by excluding the percentage of 

households not impacted by the standard. For example, in the case of CSL 2 for front-loading 

washers, about 96 percent of the consumers did not factor into the calculation of the median and 

average PBP. 

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Table 8.4.1 Top-Loading Commercial Clothes Washers, Multi-Family Application: LCC 

and PBP Results 

CSL MEF/WF 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Installed 

Price 

Average 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Households with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 1.26/9.50 $760 $3,263 $4,023 - - - - - -

1 1.42/9.50 $883 $3,153 $4,036 -$8.1 43.3% 35.3% 21.5% 11.7 17.3 

2 1.60/8.50 $974 $2,873 $3,847 $178.6 13.8% 1.2% 85.0% 4.6 5.6 

Table 8.4.2 Top-Loading Commercial Clothes Washers, Laundromat Application: LCC 

and PBP Results 

CSL MEF/WF 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Installed 

Price 

Average 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Households with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 1.26/9.50 $760 $3,422 $4,182 - - - - - -

1 1.42/9.50 $883 $3,326 $4,209 -$17.7 51.4% 35.3% 13.3% 7.9 9.1 

2 1.60/8.50 $974 $3,025 $3,999 $190.0 2.9% 1.2% 95.9% 2.8 3.0 

Table 8.4.3 Front-Loading Commercial Clothes Washers, Multi-Family Application: 

LCC and PBP Results 

CSL MEF/WF 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Installed 

Price 

Average 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Households with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 1.72/8.00 $1,365 $2,855 $4,220 - - - - - -

1 1.80/7.50 $1,365 $2,855 $4,091 $4.7 0.0% 96.3% 3.7% 0.0 0.0 

2 2.00/5.50 $1,388 $2,726 $3,690 $19.5 0.0% 96.3% 3.7% 0.4 0.4 

3 2.20/5.10 $1,428 $2,302 $3,596 $91.5 1.4% 23.1% 75.5% 3.0 3.2 

4 2.35/4.40 $1,470 $2,168 $3,484 $202.7 1.1% 0.0% 98.9% 2.9 3.1 

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Table 8.4.4 Front-Loading Commercial Clothes Washers, Laundromat Application: 

LCC and PBP Results 

CSL MEF/WF 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Installed 

Price 

Average 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Households with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 1.72/8.00 $1,365 $2,014 $4,380 - - - - - -

1 1.80/7.50 $1,365 $3,014 $4,240 $5.2 0.0% 96.3% 3.7% 0.0 0.0 

2 2.00/5.50 $1,388 $2,874 $3,787 $22.0 0.0% 96.3% 3.7% 0.2 0.2 

3 2.20/5.10 $1,428 $2,400 $3,695 $93.4 0.0% 23.1% 76.9% 1.8 1.9 

4 2.35/4.40 $1,470 $2,267 $3,572 $216.1 0.0% 0.0% 100.0% 1.6 1.7 

Figures 8.4.7 and 8.4.8 show the range of LCC savings for the CSLs for both product 

applications of top-loading commercial clothes washers. Figures 8.4.9 and 8.4.10 show the 

range of LCC savings for the CSLs for both product applications of front-loading commercial 

clothes washers. For each CSL, the top and the bottom of the box indicate the 75th and 25th 

percentiles, respectively. The bar at the middle of the box indicates the median; 50 percent of 

the households have LCC savings above this value The ‘whiskers’ at the bottom and the top of 

the box indicate the 5th and 95th percentiles. The small box shows the average LCC savings for 

each CSL. 

Figures 8.4.11 and 8.4.12 show the range of PBPs for top-loading commercial clothes 

washers. Figures 8.4.13 and 8.4.14 show the range of PBPs for front-loading commercial clothes 

washers. In these figures, households which are not impacted by an increase in the standard are 

not included (this situation applies to all CSLs except CSL 4 for front-loading washers). 

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EERE-2006-STD-0127 COMMENT 69.1
Life-cycle Cost Savings ($) 

800 

600 

400 

200 

0 

-200 

Median 

\ 

Mean 

CSL 1 CSL 2 

Candidate Standard Level 

Figure 8.4.7	 Range of LCC Savings for Top-Loading Commercial 

Clothes Washers, Multi-Family 

300 

Life-cycle Cost Savings ($) 

200 

100 

0 

-100 

Median Mean 

\ 

CSL 1 CSL 2
 

Candidate Standard Level
 

Figure 8.4.8 Range of LCC Savings for Top-Loading Commercial 

Clothes Washers, Laundromat 

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EERE-2006-STD-0127 COMMENT 69.1
0 

100 

200 

300 

400 

500 

600 

Life-cycle Cost Savings ($) 

Median Mean 

\ 

CSL 1 CSL 2 CSL 3 CSL 4 

Candidate Standard Level 

Figure 8.4.9	 Range of LCC Savings for Front-Loading 

Commercial Clothes Washers, Multi-Family 

250 

Life-cycle Cost Savings ($) 

200 

150 

100 

50 

0 

Median Mean 

\ 

CSL 1 CSL 2 CSL 3 CSL 4
 

Candidate Standard Level
 

Figure 8.4.10 Range of LCC Savings for Front-Loading 

Commercial Clothes Washers, Laundromat 

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EERE-2006-STD-0127 COMMENT 69.1
60 

Payback Period (years) Payback Period (years) 

50 

40 

30 

20 

10 

0 

Figure 8.4.11	 Range of Payback Periods for Top-Loading 

Commercial Clothes Washers, Multi-Family 

20 

Median Mean 

\ 

CSL 1 CSL 2
 

Candidate Standard Level
 

Median Mean 

\ 

CSL 1 CSL 2
 

Candidate Standard Level
 

15 

10 

5 

0 

Figure 8.4.12 Range of Payback Periods for Top-Loading 

Commercial Clothes Washers, Laundromat 

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EERE-2006-STD-0127 COMMENT 69.1
0 

1 

2 

3 

4 

5 

6 

7 

8 

CSL 1 CSL 2 CSL 3 CSL 4 

Candidate Standard Level 

Payback Period (years) 

Median Mean 

\ 

Figure 8.4.13 Range of Payback Periods for Front-Loading 

Commercial Clothes Washers, Multi-Family 

0.0 

0.5 

1.0 

1.5 

2.0 

2.5 

3.0 

CSL 1 CSL 2 CSL 3 CSL 4 

Candidate Standard Level 

Payback Period (years) 

Median Mean 

\ 

Figure 8.4.14	 Range of Payback Periods for Front-Loading 

Commercial Clothes Washers, Laundromat 

8-44 

EERE-2006-STD-0127 COMMENT 69.1
 

8.5 REBUTTABLE PAYBACK PERIOD 

DOE presents rebuttable PBPs to provide the legally established rebuttable presumption 

that an energy efficiency standard is economically justified if the additional product costs 

attributed to the standard are less than three times the value of the first-year energy cost savings. 

(42 U.S.C. §6295 (o)(2)(B)(iii)) 

8.5.1 Metric 

The basic equation for rebuttable PBP is the same as that shown in section 8.3, Payback 

Period Inputs. Unlike the analyses described in sections 8.2 and 8.3, however, the rebuttable 

PBP is not based on the use of household samples and probability distributions. Rather than 

distributions, the rebuttable PBP is based on discrete single-point values. For example, while 

DOE uses a probability distribution of regional energy prices in the distributional payback period 

analysis, it uses only the national average energy price from the probability distribution to 

determine the rebuttable PBP. 

Other than the use of single-point values, the most notable difference between the 

distribution PBP and the rebuttable PBP is the latter’s reliance on the DOE test procedure to 

determine a product’s annual energy and water consumption. The following identifies the 

differences between the annual energy and water consumptions determined for the distribution 

PBP and the rebuttable PBP. 

DOE based the annual energy and water consumption values that it used to determine the 

rebuttable PBP on the number of cycles per year specified in the DOE test procedure. 26 The 

commercial clothes washer test procedure cites the residential clothes washer test procedure to 

establish efficiency ratings as well as annual energy and water consumption. As a result, the 

annual number of use cycles, 392 cycles per year, for determining the annual energy and water 

consumption of commercial clothes washers is representative of residential use, not commercial 

use. Because residential use is significantly lower than the average usage for commercial 

applications—1241 cycles per year in multi-family buildings and 2190 cycles per year in 

laundromats—the average annual energy and water consumption used to determine rebuttable 

PBP will be significantly less than the consumption associated with actual usage. As a result, the 

rebuttable PBP will be significantly longer than the distribution PBPs for both multi-family and 

laundromat applications. 

8.5.2 Inputs 

Inputs for the rebuttable PBP differ from the distribution PBP in that the calculation uses 

discrete values, rather than distributions, for inputs. Note that for the calculation of distribution 

PBP, because inputs for the determination of total installed cost were based on single-point 

values, only the variability and/or uncertainty in the inputs for determining operating cost 

contributed to variability in the distribution PBPs. The following summarizes the single-point 

values that DOE used in the determination of the rebuttable PBP. 

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EERE-2006-STD-0127 COMMENT 69.1
•	 Manufacturing costs, markups, sales taxes, and installation costs were all based on the 

single-point values used in the distributional LCC and PBP analysis. 

•	 As described in section 8.5.1, annual energy and water consumption is based on the DOE 

test procedure. 

•	 Energy and water prices are based on national average values for the year that new 

standards are assumed to take effect. 

•	 An average discount rate or lifetime is not required in the rebuttable PBP calculation. 

•	 The effective date of the standard is assumed to be 2013. 

8.5.3 Results 

DOE calculated rebuttable PBPs for each CSL relative to the distribution of product 

efficiencies assumed for the base case (refer back to section 8.2.6 for more details on the base 

case efficiency distributions for each product). In other words, DOE did not determine the 

rebuttable PBP relative to the baseline efficiency level, but relative to the current distribution of 

product efficiencies DOE determined for the base case (i.e., the case without new standards). 

The following sections present the results for the sets of products being analyzed for this 

standards rulemaking. 

Tables 8.5.1 and 8.5.2 present the rebuttable PBPs for top-loading commercial clothes 

washers under both product applications; multi-family buildings and laundromats. Tables 8.5.3 

and 8.5.4 present the rebuttable PBPs for front-loading commercial clothes washers under both 

product applications; multi-family buildings and laundromats. 

Table 8.5.1	 Top-Loading Commercial Clothes Washers, Multi-Family Application: 

Rebuttable Payback Periods 

CSL MEF WF 

PBP 

years 

Baseline 1.26 9.50 -

1 1.42 9.50 895 

2 1.60 8.50 24 

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EERE-2006-STD-0127 COMMENT 69.1
Table 8.5.2 Top-Loading Commercial Clothes Washers, Laundromat Application: 

Rebuttable Payback Periods 

CSL MEF WF 

PBP 

years 

Baseline 1.26 9.50 -

1 1.42 9.50 Infinity 

2 1.60 8.50 226 

Table 8.5.3 Front-Loading Commercial Clothes Washers, Multi-Family Application: 

Rebuttable Payback Periods 

CSL MEF WF 

PBP 

years 

Baseline 1.72 8.00 -

1 1.80 7.50 0 

2 2.00 5.50 1.2 

3 2.20 5.10 9.4 

4 2.35 4.40 10.0 

Table 8.5.4 Front-Loading Commercial Clothes Washers, Laundromat Application: 

Rebuttable Payback Periods 

CSL MEF WF 

PBP 

years 

Baseline 1.72 8.00 -

1 1.80 7.50 0 

2 2.00 5.50 1.3 

3 2.20 5.10 17.3 

4 2.35 4.40 17.6 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

 

 

 

 

 

 

REFERENCES 

1	 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, 

Energy Conservation Standards for Certain Consumer Products (Dishwashers, 

Dehumidifiers, Microwave Ovens, and Electric and Gas Kitchen Ranges and Ovens) 

and for Certain Commercial and Industrial Equipment (Commercial Clothes 

Washers); Final Rule. Federal Register, 2009. 74(66): pp. 16040-16096. 

2	 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy. 

Technical Support Document: Energy Efficiency Program for Consumer Products and 

Commercial and Industrial Equipment: Residential Dishwashers, Dehumidifiers, Cooking 

Products, and Commercial Clothes Washers, March, 2009. Washington, DC. 

<http://www1.eere.energy.gov/buildings/appliance_standards/residential/cooking_prod 

ucts_final_rule_tsd.html> 

3	 Association of Home Appliance Manufacturers. AHAM 2005 Fact Book, 2005. Washington, 

DC. 

4	 RS Means. Mechanical Cost Data, 31st Annual Edition, 2008. Kingston, MA. 

5	 Consortium for Energy Efficiency. Commercial, Family-Sized Washers: An Initiative 

Description of the Consortium for Energy Efficiency, 1998. Boston, MA. 

<http://www.cee1.org/com/cwsh/cwsh-main.php3> 

6	 U.S. Department of Energy-Energy Information Administration. Form EIA-861 for 2007, 

2007. Washington, DC. <http://www.eia.doe.gov/cneaf/electricity/page/eia861.html> 

7	 U.S. Census Bureau. Population estimates, Population, Population change and estimated 

components of population change: April 1, 2000 to July 1, 2005, 2006. Washington, DC. 

<http://www.census.gov/popest/datasets.html> 

8	 U.S. Department of Energy-Energy Information Administration. Natural Gas Monthly, 

2007. Washington, DC. 

<http://www.eia.doe.gov/oil_gas/natural_gas/data_publications/natural_gas_monthly/ngm.htm> 

9	 Raftelis Financial Consultants, Inc. 2006 RFC/AWWA Water and Wastewater Rate Survey, 

2006. Charlotte, NC, Kansas City, MO, and Pasadena, CA. 

<http://www.raftelis.com/ratessurvey.html> 

10	 U.S. Department of Energy-Energy Information Administration. An Updated Annual Energy 

Outlook 2009 Reference Case Reflecting Provisions of the American Recovery and 

Reinvestment Act and Recent Changes in the Economic Outlook, April, 2009. Washington, 

DC. SR/OIAF/2009-03. 

<http://www.eia.doe.gov/oiaf/servicerpt/stimulus/pdf/sroiaf(2009)03.pdf> 

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11	 U.S. Department of Energy-Energy Information Administration. Annual Energy Outlook 

2009 with Projections to 2030, March, 2009. Washington, DC. DOE/EIA-0383(2009). 

<http://www.eia.doe.gov/oiaf/aeo/pdf/0383(2009).pdf> 

12	 U.S. Department of Labor-Bureau of Labor Statistics. Consumer Price Indexes, Item: Water 

and sewerage maintenance, Series Id: CUUR0000SEHG01, U.S. city average (not seasonally 

adjusted), 2008. Washington, DC. <http://www.bls.gov/cpi/home.htm#data> 

13	 Whirlpool Corporation. Comment of Whirlpool Corporation Regarding the ANOPR for 

Cooking Products and Commercial Clothes Washers, Docket Number EE-206-STD-2007, 

RIN 1904-AB49. 

14	 U.S. Department of Energy. Technical Support Document: Energy Efficiency Standards for 

Consumer Products: Residential Central Air Conditioners and Heat Pumps, May 2002. 

Washington, DC. Chapter 5. 

<http://www.eere.energy.gov/buildings/appliance_standards/residential/ac_central_1000_r.html> 

15	 Coin Laundry Association. Industry Overview. Downers Grove, IL. 

<http://www.coinlaundry.org/resources/industryoverview.cfm> 

16	 Southern California Edison. 2004-2005 Database for Energy Efficiency Resources (DEER) 

Update Study, Final Report, December, 2005. Prepared for Southern California Edison by 

Itron, Inc., Vancouver, WA. 

<http://www.calmac.org/publications/2004-05_DEER_Update_Final_Report-Wo.pdf> 

17	 Sullivan, G.P., J. W. Currie, T.C. Hillman, and G.B. Parker. High-Performance Clothes 

Washer Demonstration at Leisure World Laguna Woods Final Report, December, 2000. 

Prepared for Southern California Edison Company by Battelle Pacific Northwest Laboratory, 

Richland, WA. 

<http://eere.pnl.gov/building-technologies/doc/scefinal%202-22-01.pdf> 

18	 California Measurement Advisory Committee. CALMAC Protocols, Appendix F, Effective 

Useful Live Values for Major Energy Efficiency Measures, September, 2000. 

<http://www.calmac.org/events/APX_F.pdf> 

19	 Ibbotsons Associates. Cost of Capital 2001 Yearbook, Data Through March 2001, 2001. 

Chicago, IL. 

20	 Damodaran Online. The Data Page: Cost of Capital by Industry Sector, 2006. 

<http://pages.stern.nyu.edu/~adamodar/> 

21	 Ibbotsons Associates. Statistics for SIC code 72, 2006. <http://www.ibbotson.com> 

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22	 Ibbotsons Associates. SBBI Valuation Edition 2001 Yearbook, 2001. Chicago, IL. pp. 38, 44. 

23	 U.S. Government Printing Office. Economic Report of the President 2006, 2006. 

Washington, DC. <http://www.gpoaccess.gov/eop/index.html> 

24	 Association of Home Appliance Manufacturers. AHAM Data on Commercial Clothes 

Washers for DOE Efficiency Standards Rulemaking, October 12, 2006. Letter to Building 

Technologies Program, U.S. Department of Energy. 

25	 California Energy Commission. Appliances Databases – Clothes Washers, 2009. 

Sacramento, CA. 

<http://www.energy.ca.gov/appliances/database/excel_based_files/Clothes_Washers/> 

(Last Accessed February 5, 2009) 

26	 U.S. Office of the Federal Register. Code of Federal Regulations, Title 10, Part 431 -

Energy Conservation Program for Certain Commercial and Industrial Equipment, Subpart 

I—Commercial Clothes Washers, January 1, 2007. Washington, DC. 

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