APPENDIX 11C. MARKET SEGMENT SENSITIVITY ANALYSIS 

TABLE OF CONTENTS 

11C.1 INTRODUCTION ...............................................................................................................1 

11C.2 COMMERCIAL CLOTHES WASHER SHIPMENTS BY MARKET SEGMENT 

IN THE SENSITIVITY CASE............................................................................................1 

11C.3 IMPACT MARKET SEGMENT BREAKDOWN ON COMMERCIAL 

CLOTHES WASHER USAGE AND SHIPMENTS IN THE SENSITIVITY 

CASE ...................................................................................................................................5
 

11C.4 SCENARIO USED TO EVALUATE THE SENSITIVITY CASE....................................6
 

11C.5 NATIONAL ENERGY AND WATER SAVINGS IN THE SENSITIVITY CASE..........7
 

11C.6 NATIONAL IMPACTS IN THE SENSITIVITY CASE....................................................7
 

11C.7 MANUFACTURER IMPACT ANALYSIS RESULTS IN THE SENSITIVITY 

CASE ...................................................................................................................................8
 

LIST OF TABLES 

Table 11C.2.1 Estimate of Alliance’s 2008 Revenue by Commercial Laundry Segment.......11C-2 

Table 11C.2.2 Estimate of Alliance’s Revenue Split for Each Market Channel.....................11C-3 

Table 11C.2.3 Estimate of Alliance’s 2008 Revenue Breakdown by Segment and 

Equipment Types .............................................................................................11C-3 

Table 11C.3.1 Top-Loading Commercial Clothes Washers: Comparison of Base Case and 

Standards Case Shipment-Weighted Average Per-Unit Annual Energy and 

Water Consumption in 2013 for the Default Case and Sensitivity Case .........11C-6 

Table 11C.3.2 Front-Loading Commercial Clothes Washers: Comparison of Base Case 

and Standards Case Shipment-Weighted Average Per-Unit Annual Energy 

and Water Consumption in 2013 for the Default Case and Sensitivity Case ..11C-6 

Table 11C.4.1 Comparison of NES and NWS for Commercial Clothes Washers under the 

Default Case and Sensitivity Case ...................................................................11C-7 

Table 11C.5.1 Comparison of NPV for Commercial Clothes Washers under the Default 

Case and Sensitivity Case ................................................................................11C-8 

Table 11C.6.1 Change in Industry Net Present Value for Top-Loading and Front-Loading 

Commercial Clothes Washers in the Default Case (Preservation of Gross 

Margin Percentage Markup – Price Elasticity of Demand Shipments) ...........11C-9 

Table 11C.6.2 Changes in Industry Net Present Value for Top-Loading and FrontLoading Commercial Clothes Washers in the Sensitivity Case 

(Preservation of Gross Margin Percentage Markup – Price Elasticity of 

Demand Shipments).........................................................................................11C-9
 

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APPENDIX 11C. MARKET SEGMENT SENSITIVITY ANALYSIS 

11C.1 INTRODUCTION 

As described in the national impact analysis (NIA) (chapter 11 of this TSD), the U.S. 

Department of Energy (DOE) used the Consortium for Energy Efficiency’s (CEE’s) report to 

segment commercial clothes washer (CCW) shipments among laundromats, multi-family 

housing, and on-premise laundry.1 For this sensitivity analysis, DOE calculated an alternative 

split of CCW shipments among the three distribution channels. The purpose of this appendix is 

to clarify how DOE made its estimates for the split used in the sensitivity analysis, describe how 

the analysis was conducted, and to present the results for the NIA and manufacturer impact 

analysis (MIA) under the sensitivity. The scenario using the alternative market segment 

breakdown is referred to as the sensitivity case throughout this appendix. 

11C.2 COMMERCIAL CLOTHES WASHER SHIPMENTS BY MARKET 

SEGMENT IN THE SENSITIVITY CASE 

As stated in the CEE report, 85 percent of CCW shipments are associated with multifamily housing while the remaining 15 percent are for laundromats. In response to the November 

9, 2009 supplemental notice of proposed rulemaking (SNOPR) (the November 2009 SNOPR), 

the Joint Comment stated that using information from Alliance Laundry System’s (Alliance’s) 

U.S. Securities and Exchange Commission Form 10-K as of December 31, 2008 (the 2008 10-K) 

suggests a split of 40 percent to multi-family housing and 60 percent to laundromats.2

 The Joint 

Comment acknowledged that this split describes dollar values, not shipments, and that 

commercial clothes dryers are also included in the estimates. Because laundromats also purchase 

large capacity clothes washers, the Joint Comment believed a split of 55 percent of CCW 

shipments to laundromats and 45 percent to multi-family venues was more reasonable and 

should be evaluated by DOE for the final rule.a Alliance agreed with the split shown in the CEE 

report.b 

a

 The Joint Comment was filed on behalf of Appliance Standards Awareness Project, the American Council for an 

Energy-Efficient Economy, American Rivers National Consumer Law Center, the Natural Resources Defense 

Council, the Northeast Energy Efficiency Partnerships, and the Seattle Public Utilities. The comment was submitted 

in the docket for this rulemaking (Docket No. EE–2006–STD–0127) and is maintained in the Resource Room of the 

Building Technologies Program. This particular citation refers to the comment (1) recorded as document number 

67.10 and (2) which appears on pages 1–9 of document number 67.10. The specific information regarding the split 

between laundromats and multi-family housing can be found on pages 3–4. 

b

 Alliance’s written comment was entitled “Response to DOE Commercial Clothes Washer SNOPR.” This 

document was entered as comment number 66.4 in the docket for this rulemaking, along with a letter submitted by 

Alliance entitled “Is Top-Loading a Feature Within the Meaning of EPCA?” The comment was submitted in the 

docket for this rulemaking (Docket No. EE–2006–STD–0127) and is maintained in the Resource Room of the 

Building Technologies Program. The specific information regarding the split between laundromats and multi-family 

housing can be found on page 2. 

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EERE-2006-STD-0127 COMMENT 69.1
 

Because of the significant difference between the market split values provided by the 

Joint Comment and Alliance, DOE conducted an analysis using the 2008 10-K and the 

information calculated as part of the MIA (see appendix 13A and 13C of this TSD) to estimate 

the possible mix of Alliance’s shipments to the different distribution channels. This sensitivity 

analysis was conducted before DOE received comments from Alliance confirming the 85/15 

percentage shipment split for laundromats and multi-family housing and was intended to 

determine how far the CCW shipments could be skewed towards laundromats versus multifamily housing. As such, it is an extreme case meant to explore the impacts of how different 

usage patterns in CCW market segments could change the impacts on the nation, not explore 

actual usage patterns. DOE notes that no interested parties have supplied actual data that directly 

contradicts the current market channel mix. 

First, DOE used the 2008 10-K to estimate Alliance’s revenue for laundromats, multifamily housing, and on-premise laundry. The 2008 10-K shows that Alliance earned a total of 

$337.9 million from commercial laundry. To calculate Alliance’s revenue in the three 

commercial laundry segments, DOE assumed that Alliance’s revenue also matched the industry 

revenue percentages shown in the 2008 10-K. Table 11C.2.1 shows the estimates for the total 

revenue Alliance earned in each segment. 

Table 11C.2.1 Estimate of Alliance’s 2008 Revenue by Commercial Laundry Segment 

Commercial Laundry 

Channel 

Percentage of Commercial Laundry 

by Channel from Alliance’s 2008 10-K 

(%) 

Estimate of Alliance’s 2008 

Revenue by Segment 

($ million) 

Laundromat 43 145.3 

Multi-Family Housing 28 94.6 

On-Premise Laundry 29 98.0 

Total 100 337.9 

 Along with its suggestion to use a 55/45 percentage shipment split between multi-family 

housing and laundromats, the Joint Comment acknowledges that estimating unit shipments using 

revenues is problematic. DOE notes that Alliance ships a wide variety of commercial laundry 

equipment and DOE research, Federal tax credits, and past Alliance Form 10-Ks indicate that 

CCWs represent less than a quarter of Alliance’s total revenues. For example, in addition to 

clothes dryers, Alliance also supplies washer-extractors, high-capacity dryers, and other 

professional laundry equipment. 

DOE estimated a shipment split for CCWs based on prior research (see appendix 13A 

and 13C), statements made by Alliance in its Form 10-Ks, and DOE’s industry experience. The 

2008 10-K states that laundromats typically purchase washer-extractors and tumbler dryers; 

multi-family housing laundry typically purchase small-chassis washers and dryers; and onpremise laundries typically purchase washer-extractors, tumbler dryers and flatwork finishers. 

Based on these statements, DOE determined that the multi-family housing market would feature 

less “large” equipment (consisting of high-capacity washers, washer-extractors, and tumbler 

dryers) and more “small” equipment (consisting of CCWs covered by this rulemaking and small11C-2
 

EERE-2006-STD-0127 COMMENT 69.1
 

chassis dryers) while the laundromat and on-premise laundry market channels would purchase 

mostly “large” equipment. 

Based on the analysis presented in appendix 13A and the its evaluation of Federal tax 

credits in appendix 13C, DOE estimates that Alliance’s 2008 CCW sales amounted to 

approximately $74 million out of a total of $110 million in total “small” equipment sales. Based 

on the statements in the 2008 10-K, DOE allocated large and small equipment by the three 

market channels in order to disaggregate sales revenue by equipment type and hence estimate 

small equipment shipment volumes. DOE research suggests the revenue splits as shown in Table 

11C.2.2 as one possible scenario. However, DOE recognizes that there is significant uncertainty 

in the revenue estimates by segment and equipment due to the limited information DOE has 

received. 

Table 11C.2.2 Estimate of Alliance’s Revenue Split for Each Market Channel 

Commercial Laundry 

Channel 

Large Equipment 

(%) 

Small Equipment 

(%) 

Total Per Channel 

(%) 

Laundromat 80 20 100 

Multi-Family Housing 15 85 100 

On-Premise Laundry 99 1 100 

The equipment sales revenue estimates by market channel in Table 11C.2.2 were then 

multiplied by the total revenues per market channel to produce Table 11C.2.3. DOE research 

suggests that the revenue splits in Table 11C.2.2 could be valid since the product of overall 

equipment sales splits and equipment type revenue allocation by market segment and equipment 

type result in small equipment sales that are consistent with independently-derived small 

equipment revenue sales projections for 2008 based on extrapolating data from appendix 13A 

and appendix 13C. 

Table 11C.2.3 Estimate of Alliance’s 2008 Revenue Breakdown by Segment and Equipment 

Types 

Commercial Laundry 

Channel 

Large 

Equipment 

Revenue 

Breakdown* 

($ millions) 

Large 

Equipment 

Revenue 

Breakdown 

(%) 

Small 

Equipment 

Revenue 

Breakdown† 

($ millions) 

Small 

Equipment 

Revenue 

Breakdown 

(%) 

Laundromat 116.2 51.1 29.1 26.3 

Multi-Family Housing 14.2 6.2 80.4 72.8 

On-Premise Laundry 97.0 42.7 1.0 0.9 

Totals 227.4 100.0 110.5†† 100.0 

*Large Equipment refers to non-covered equipment (large-capacity washers, washer-extractors, and tumbler dyers). 

† Small Equipment refers to both covered CCWs and small-chassis dryers. 

†† In appendix 13C, DOE estimates that $73.6 million of the total small equipment purchased in the three segments 

are covered CCWs. 

To calculate the CCW shipment breakdown by commercial laundry segment, DOE 

estimated that CCW shipments matched the revenue breakdowns calculated for small equipment 

shown in Table 11C.2.3. Because usage patterns for on-premise laundry more closely mirror 

laundromats, DOE allocated the small percentage of these on-premise laundry shipments to 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

laundromats. This information suggests that Alliance’s shipments could be weighted as heavily 

as 74 percent of shipments to multi-family housing and 26 percent to laundromats. However, 

DOE cautions that even if these splits are correct, actual unit shipments could vary significantly 

based on the mix of CCWs being supplied. 

In its market research, DOE noted that front-loading CCWs typically cost almost twice as 

much as top-loading CCWs. Thus, unless the product mix going into each market channel is 

similar, there could be significant differences in actual unit shipments by market channel. Route 

operator comments received by DOE in response to the November 2009 SNOPR (referred to the 

“Multiple Route Operators” comment in the final rulec

) included anecdotal evidence that frontload shipments to the multi-family market are significantly lower than the overall 30/70 percent 

front-loading/top-loading CCW mix currently found in the industry. If this anecdotal evidence is 

an accurate reflection of route operators overall, it suggests a higher percentage of front-loading 

CCWs being sold into the laundromat channel than into the multi-family housing market 

channel. Thus, it is possible that even with Alliance’s market channel revenues split at an 

estimated 74 percent and 26 percent between multi-family housing and laundromats, 

respectively, that the actual unit shipments are closer to the 85/15 percentage split between 

multi-family housing and laundromats that DOE used in its analysis. 

In response to DOE’s request for comment for unit shipment information in the 

November 2009 SNOPR, Whirlpool suggested that its shipments were not as heavily weighted 

toward the 85 percent of shipments to multi-family channel and 15 percent to laundromats shown 

in the CEE report.d

 However, Whirlpool did not specify any other shipment ratio. Alliance 

responded that the 85/15 percentage shipments split was representative. 

For the purpose of exploring a sensitivity analysis at the extreme of potential market 

channel shipments, DOE assumed a 40/60 percentage split for Whirlpool’s unit shipments to the 

laundromat/multi-family housing channels, respectively. Additionally, DOE assumed a similar 

shipment mix of front-loading and top-loading CCWs into each channel for Alliance and 

Whirlpool even though anecdotal evidence suggests that laundromats buy more front-loading 

equipment (and hence would receive fewer unit shipments). DOE used a shipment-weighted 

average between these two manufacturers with the largest market share as a proxy to estimate 

shipments for the remainder of the industry. Thus, DOE proposes an industry average shipment 

split of 66 percent to multi-family housing and 34 percent to the laundromat channel for this 

sensitivity analysis. However, DOE cautions that based on the analysis above, it is unlikely that 

the actual shipment split is skewed this far towards laundromats. 

c

 Twenty route operators provided letters to Alliance, and these letters were submitted as part of Alliance’s written 

comment in the docket for this rulemaking (Docket No. EE–2006–STD–0127). The comment is maintained in the 

Resource Room of the Building Technologies Program. The comment was entered as comment number 67.8 in the 

docket for this rulemaking. 

d Whirlpool Corporation’s written comment was submitted in the docket for this rulemaking (Docket No. EE–2006– 

STD–0127) and is maintained in the Resource Room of the Building Technologies Program. The comment was 

entered as comment number 67.11 in the docket for this rulemaking. The specific information regarding the split 

between laundromats and multi-family housing can be found on page 4. 

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EERE-2006-STD-0127 COMMENT 69.1
 

11C.3 IMPACT MARKET SEGMENT BREAKDOWN ON COMMERCIAL 

CLOTHES WASHER USAGE AND SHIPMENTS IN THE SENSITIVITY 

CASE 

The split of industry shipments to the multi-family housing and laundromat channels 

impacts the overall usage of CCWs and their associated lifetime in the building stock. Because 

CCWs in laundromats are used more frequently than in multi-family housing, a higher 

percentage of industry shipments to laundromats results in an increase in the average CCW usage 

in the building stock and a decrease in the average CCW lifetime. 

The weighted-average combined CCW usage equals 1,567 cycles per year under the 

sensitivity case, i.e., a market share split of 66 percent for multi-family housing and 34 percent 

for laundromats (referred to hereafter as the 66/34 split). This compares to 1,388 cycles per year 

under the default case, i.e., a market share split of 85 percent for multi-family housing and 15 

percent for laundromats (referred to hereafter as the 85/15 split). Increased CCW usage leads to a 

greater energy and water savings potential for CCW energy conservation standards. 

The weighted-average combined CCW lifetime equals 9.9 years under the sensitivity case 

based on a 66/34 split. This compares to a lifetime of 10.6 years under the default case based on 

an 85/15 split. Decreasing equipment lifetime leads to more replacements and higher annual 

CCW shipments. 

Using the relationship between CCW modified energy factor (MEF) and water factor 

(WF) and the annual energy and water consumption described in Chapter 8, Table 11C.3.1 and 

Table 11C.3.2 present the per-unit annual electrical and gas energy use and water consumption, 

based on the shipment-weighted efficiencies (SWEFs) corresponding to the base case and each 

trial standard level (TSL) for top-loading and front-loading CCWs, respectively. Because 

establishments that use CCWs use either electric or gas water heaters and dryers, the per-unit 

annual energy use values in the tables below are provided by fuel type. The energy and water use 

values shown in Table 11C.3.1 and Table 11C.3.2 are weighted-average values reflecting the 

market share of CCWs in multi-family housing and laundromats. The tables below present 

values based on the default case of the 85/15 split and the sensitivity case based on the 66/34 

split. The water heating and drying energy consumption data reflect the percentage of gas and 

electric water heaters and dryers in the combined multi-family and laundromat market. In the 

combined market under the default case with the 85/15 split, 17 and 83 percent of water heaters 

are electric and gas, respectively, while 34 and 66 percent of dryers are electric and gas, 

respectively. Under the sensitivity case with the 66/34 split, 13 and 87 percent of water heaters 

are electric and gas, respectively, while 26 and 74 percent of dryers are electric and gas, 

respectively. Under the sensitivity case with the 66/34 split, the values in Table 11C.3.1 and 

Table 11C.3.2 reflect the greater annual usage of CCWs and the greater reliance on gas water 

heating and drying. 

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EERE-2006-STD-0127 COMMENT 69.1
 

Table 11C.3.1 Top-Loading Commercial Clothes Washers: Comparison of Base Case and 

Standards Case Shipment-Weighted Average Per-Unit Annual Energy and Water 

Consumption in 2013 for the Default Case and Sensitivity Case 

Base 

Case 

Trial Standard Level 

1 2 3 4 5 

SWEF (MEF) 1.32 1.42 1.42 1.60 1.60 1.60 

SWEF (WF) 9.49 9.49 9.49 8.50 8.50 8.50 

Default Case: 85/15 Split 

Annual 

Energy Use 

Electric (kilowatthour/year (kWh/yr)) 950 902 902 812 812 812 

Gas (million British 

thermal units 

(MMBtu)/yr) 

8.30 7.52 7.52 6.60 6.60 6.60 

Annual Water Use (1000 gallons (ga)l/ yr) 36.9 36.9 36.9 33.0 32.2 33.0 

Sensitivity Case: 66/34 Split 

Annual 

Energy Use 

Electric (kWh/yr) 879 837 837 752 752 752 

Gas (MMBtu/yr) 10.14 9.21 9.21 8.10 8.10 8.10 

Annual Water Use (1000 gal/ yr) 41.6 41.62 41.62 37.29 37.29 37.29 

Table 11C.3.2 Front-Loading Commercial Clothes Washers: Comparison of Base Case and 

Standards Case Shipment-Weighted Average Per-Unit Annual Energy and Water 

Consumption in 2013 for the Default Case and Sensitivity Case 

Base 

Case 

Trial Standard Level 

1 2 3 4 5 

SWEF (MEF) 2.04 2.04 2.05 2.05 2.20 2.35 

SWEF (WF) 5.50 5.48 5.41 5.41 5.10 4.40 

Default Case: 85/15 Split 

Annual 

Energy Use 

Electric (kWh/yr) 683 682 680 680 643 610 

Gas (MMBtu/yr) 4.96 4.94 4.92 4.92 4.51 4.19 

Annual Water Use (1000 gal/ yr) 21.4 21.3 21.0 21.3 19.8 17.1 

Sensitivity Case: 66/34 Split 

Annual 

Energy Use 

Electric (kWh/yr) 639 638 637 637 604 574 

Gas (MMBtu/yr) 6.12 6.10 6.07 6.07 5.58 5.18 

Annual Water Use (1000 gal/ yr) 24.12 24.04 23.73 23.73 22.38 19.31 

11C.4 SCENARIO USED TO EVALUATE THE SENSITIVITY CASE 

For the sensitivity case, DOE used the same scenario used to drive the results in chapter 

11 (the default case). As described in chapter 11, the default scenario uses the reference case for 

economic growth and accounts for the impacts of higher first costs on consumer purchases (the 

relative price elasticity scenario). 

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EERE-2006-STD-0127 COMMENT 69.1
 

 

 

 

 

 

 

11C.5 NATIONAL ENERGY AND WATER SAVINGS IN THE SENSITIVITY CASE 

Table 11C.5.1 compares the national energy savings (NES) results and national water 

savings (NWS) results for the TSLs analyzed for CCWs for the default (85/15 split) and 

sensitivity (66/34 split) cases. Results for top-loading and front-loading CCWs are provided. The 

NES results are cumulative to 2043 and are shown as primary energy savings, expressed in 

quadrillion (1013) Btu (quads). NWS results are expressed in billions of gallons. 

Table 11C.5.1 Comparison of NES and NWS for Commercial Clothes Washers under the 

Default Case and Sensitivity Case 

Trial Standard Level 

1 2 3 4 5 

Top-Load (MEF/WF) 1.42/9.50 1.42/9.50 1.60/8.50 1.60/8.50 1.60/8.50 

Front-Load (MEF/WF) 1.80/7.50 2.00/5.50 2.00/5.50 2.20/5/10 2.35/4.40 

Default Case: 85/15 Split 

Top-Load NES (quads) 0.04 0.04 0.10 0.10 0.10 

Front-Load NES (quads) 0.00 0.00 0.00 0.01 0.02 

Total NES (quads) 0.04 0.04 0.10 0.11 0.12 

Sensitivity Case: 66/34 Split 

Top-Load NES (quads) 0.05 0.05 0.11 0.11 0.11 

Front-Load NES (quads) 0.00 0.00 0.00 0.01 0.02 

Total NES (quads) 0.05 0.05 0.11 0.12 0.13 

Change in Total NES 

Increase (%) 9 9 9 8 9 

Default Case: 85/15 Split 

Top-Load NWS (billion gal) 0.00 0.00 0.14 0.14 0.14 

Front-Load NWS (billion gal) 0.00 0.01 0.01 0.03 0.07 

Total NWS (billion gal) 0.00 0.01 0.14 0.16 0.21 

Sensitivity Case: 66/34 Split 

Top-Load NWS (billion gal) 0.00 0.00 0.14 0.15 0.15 

Front-Load NWS (billion gal) 0.00 0.01 0.01 0.03 0.08 

Total NWS (billion gal) 0.00 0.01 0.16 0.18 0.23 

Change in Total NWS 

Increase (%) 9 9 11 10 11 

11C.6 NATIONAL IMPACTS IN THE SENSITIVITY CASE 

Table 11C.6.1 compares the net present value (NPV) results for the TSLs analyzed for 

CCWs for the default (85/15 split) and sensitivity (66/34 split) cases. Results for top-loading and 

front-loading CCWs are provided. NPV results are based on discount rates of 7 percent and 3 

percent and are expressed in billions of dollars. 

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Table 11C.6.1 Comparison of NPV for Commercial Clothes Washers under the Default 

Case and Sensitivity Case 

Trial Standard Level 

1 2 3 4 5 

Top-Load (MEF/WF) 1.42/9.50 1.42/9.50 1.60/8.50 1.60/8.50 1.60/8.50 

Front-Load (MEF/WF) 1.80/7.50 2.00/5.50 2.00/5.50 2.20/5/10 2.35/4.40 

Default Case: 85/15 Split, 7% discount rate 

Top-Load NPV (2008$ billion) 0.01 0.01 0.34 0.34 0.34 

Front-Load NPV (2008$ billion) 0.00 0.01 0.01 0.07 0.17 

Total NPV (2008$ billion) 0.01 0.02 0.36 0.41 0.51 

Sensitivity Case: 66/34 Split, 7% discount rate 

Top-Load NPV (2008$ billion) 0.02 0.02 0.39 0.39 0.39 

Front-Load NPV (2008$ billion) 0.00 0.02 0.02 0.08 0.19 

Total NPV (2008$ billion) 0.02 0.03 0.41 0.47 0.58 

Change in Total NPV, 7% discount rate 

Increase (%) 61 36 14 13 15 

Default Case: 85/15 Split, 3% discount rate 

Top-Load NPV (2008$ billion) 0.07 0.07 0.86 0.86 0.86 

Front-Load NPV (2008$ billion) 0.01 0.03 0.03 0.17 0.39 

Total NPV (2008$ billion) 0.08 0.10 0.89 1.03 1.25 

Sensitivity Case: 66/34 Split, 3% discount rate 

Top-Load NPV (2008$ billion) 0.08 0.08 0.96 0.96 0.96 

Front-Load NPV (2008$ billion) 0.01 0.04 0.04 0.18 0.43 

Total NPV (2008$ billion) 0.09 0.12 0.99 1.14 1.38 

Change in Total NPV, 3% discount rate 

Increase (%) 21 17 11 11 11 

11C.7 MANUFACTURER IMPACT ANALYSIS RESULTS IN THE SENSITIVITY 

CASE 

Industry shipments impact the total industry revenue and the industry net present value 

(INPV). As described in section 11C.3, the alternative split of CCW shipments between multifamily housing and laundromats impact shipments due to different replacement rates in the two 

channels. To compare the MIA results in the sensitivity case, Table 11C.7.1 shows the original 

results that correspond to the MIA results in chapter 13 and Table 11C.7.2 shows the MIA results 

in the sensitivity case. 

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Table 11C.7.1 Change in Industry Net Present Value for Top-Loading and Front-Loading 

Commercial Clothes Washers in the Default Case (Preservation of Gross Margin 

Percentage Markup – Price Elasticity of Demand Shipments) 

Units Base Trial Standard Level 

Case 1 2 3 4 5 

INPV (2008$ 

million) 62 64 62 55 51 39 

Change in INPV 

(2008$ 

million) - 3 0 (7) (10) (23) 

(%) - 4.50 0.76 -11.39 -16.57 -37.30 

Table 11C.7.2 Changes in Industry Net Present Value for Top-Loading and Front-Loading 

Commercial Clothes Washers in the Sensitivity Case (Preservation of Gross Margin 

Percentage Markup – Price Elasticity of Demand Shipments) 

Units Base Trial Standard Level 

Case 1 2 3 4 5 

INPV (2008$ 

million) 63 65 63 56 53 40 

Change in INPV 

(2008$ 

million) - 3 1 (7) (10) (23) 

(%) - 4.50 0.83 -11.01 -16.08 -36.50 

The results in Table 11C.7.1 and Table 11C.7.2 show that the sensitivity scenario has 

minimal impact on CCW INPV. Because shipments increase slightly under the sensitivity 

scenario, the impacts on INPV are marginally lower. However, since total shipments do not 

greatly change in the sensitivity case, the MIA results are extremely close to the results under the 

standard scenarios shown in chapter 13. 

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REFERENCES 

1	 Consortium for Energy Efficiency. “Commercial Family-Sized Washers: An Initiative 

Description of the Consortium for Energy Efficiency,” 1998. Boston, MA. 

2	 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);” Proposed Rule, 

Federal Register, 74 FR 57738. November 9, 2009. 

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EERE-2006-STD-0127 COMMENT 69.1