1 | Building Technologies Program eere.energy.gov

The Parker Ranch installation in Hawaii

BUILDING TECHNOLOGIES PROGRAM

Energy Conservation Standards for 

Commercial Clothes Washers: 

Framework Public Meeting 

September 24, 2012

Stephen Witkowski

Department of Energy

Energy Efficiency & Renewable Energy
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Welcome and Introduction

 Introductions

 Role of the Facilitator

 Ground Rules (Norms)

• Listen as an ally

• Use short, succinct statements/keep to the point

• Hold sidebar conversations outside the room

• Focus on issues, not personalities

• One person speak at a time (raise hand to be recognized; state your 

name for the record)

• Set cell phones to silent/vibrate

 Housekeeping Items

 Agenda Review

 Opening Remarks
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Morning Agenda

9:00 – 9:15 am Welcome, Opening Remarks, and Agenda Review

Doug Brookman

9:15 – 9:20 am Rulemaking Introduction

Stephen Witkowski

9:20 – 9:45 am Regulatory History, Test Procedure Issues, Rulemaking Process Overview

Timothy Sutherland

9:45 – 10:20 am Market and Technology Assessment, Screening Analysis, and Engineering 

Analysis

Timothy Sutherland

10:20 – 10:30 am Manufacturer Impact Analysis

Ben Barrington

10:30 – 10:45 am Break

10:45 – 11:45 am Markups Analysis, Energy and Water Use Analysis, Life-Cycle Cost and Payback 

Period Analysis, Shipments Analysis, National Impact Analysis, Consumer 

Subgroup Analysis, Utility Impact Analysis, Employment Impact Analysis, 

Emissions Analysis, and Regulatory Impact Analysis

Maithili Iyer

11:45 – 12:00 pm Other Issues and Comments, Closing Remarks

Stephen Witkowski
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Opening Remarks

Interested parties who contacted DOE to request 

an opportunity to issue an opening statement 

should speak now.
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Rulemaking Process Overview

Regulatory History

Test Procedure

1 Introduction

5 NOPR Analyses

Public Meeting Agenda

6 Closing Remarks
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Purpose of the Framework Document Public Meeting

 Present the analytical approaches to be 

used to evaluate energy conservation 

standards for commercial clothes washers

 Provide a forum for public discussion of 

rulemaking issues

 Encourage interested parties to submit data, 

information, and written comments

Introduction
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Requests for Comment

DOE solicits comment on a range of specific 

issues throughout the Framework Document.

• Throughout this presentation, these issues will be highlighted for 

discussion in comment boxes such as this.

• Comment numbers correspond to those in the Framework 

Document.

• DOE welcomes comments concerning these specific issues and 

any other issues related to the this rulemaking.

Introduction
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Instructions for Submitting Comments

 In all correspondence, please refer to this Commercial Clothes Washer 

Rulemaking by:

• Docket # EERE-2012-BT-STD-0020, and/or RIN 1904-AC77

 Email: CommClothesWashers-2012-STD-0020@ee.doe.gov

 Postal Mail: Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE-2J

1000 Independence Avenue, SW.

Washington, D.C. 20585-0121

 Courier: Ms. Brenda Edwards, 950 L’Enfant Plaza, SW., Suite 600

 Phone: (202) 586-2945

Introduction

Comment period closes October 12, 2012
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Rulemaking Process Overview

Regulatory History

Test Procedure

1 Introduction

5 NOPR Analyses

Public Meeting Agenda

6 Closing Remarks
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Legislative History

 The Energy Policy Act of 2005 (EPACT 2005) amended the 

Energy Policy and Conservation Act of 1975 (EPCA) to include 

commercial clothes washers (CCW) as a covered product.

• Established first energy conservation standards for CCWs

• Required DOE to complete two rulemaking cycles to determine 

whether to amend CCW standards:

- First final rule required by Jan. 1, 2010

– Issued Dec. 18, 2009 (75 FR 1122, Jan. 8, 2010)

- Second final rule required by Jan. 1, 2015

Regulatory History

Current rulemaking
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Definition of Covered Products

 EPACT 2005 defines commercial clothes washers as follows: 

Regulatory History

The term “commercial clothes washer” means a soft-mount frontloading or soft-mount top-loading clothes washer that—

(A) has a clothes container compartment that—

(i) for horizontal-axis clothes washers, is not more than 

3.5 cubic feet; and

(ii) for vertical-axis clothes washers, is not more than 4.0 

cubic feet; and

(B) is designed for use in—

(i) applications in which the occupants of more than one 

household will be using the clothes washer, such as multifamily housing common areas and coin laundries; or

(ii) other commercial applications. (42 U.S.C. 6311(21)) 
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Energy Conservation Standards History

 EPACT 2005 established the following standards for CCW, 

effective Jan. 1, 2007:

 The first DOE rulemaking cycle amended these standards 

according to product class, effective Jan. 8, 2013:

Regulatory History

Metric Standard

Modified Energy Factor (MEF) [ft3/kwh/cycle] 1.26 (minimum)

Water Factor (WF) [gal/cycle/ft3] 9.5 (maximum)

Product Class MEF (minimum) WF (maximum)

Top-Loading 1.60 8.5

Front-Loading 2.00 5.5
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Rulemaking Process Overview

Regulatory History

Test Procedure

1 Introduction

5 NOPR Analyses

Public Meeting Agenda

6 Closing Remarks
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DOE Test Procedure

 EPCA requires that commercial clothes washers use the same test 

procedures as residential clothes washers. (42 U.S.C. 6314(a)(8))

 On March 7, 2012, DOE published a final rule amending its test 

procedures for residential clothes washers. (77 FR 13888) 

• Minor amendments to Appendix J1

• New test procedure at Appendix J2

 Appendix J2 retains MEF/WF metrics and establishes new metrics:

Test Procedure

Integrated modified energy factor (IMEF): incorporates standby power

Integrated water factor (IWF): incorporates water consumption from all 

wash temperatures, rather than only the cold wash/cold rinse cycle.
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Appendix J2 Test Procedure

 Use of Appendix J2 will be required beginning March 7, 2015

• Applies to both residential clothes washers and CCWs

 Current CCW standards are based on MEF and WF as measured 

according to Appendix J1

 DOE is considering developing correction factors for translating 

Appendix J1 MEF/WF values into Appendix J2 MEF/WF values

• Would apply beginning March 7, 2015 to determine compliance with 

2013 standard levels.

• Would remain effective until the date of any new standards from the 

current rulemaking

Test Procedure

Appendix J1

MEF/WF

Appendix J2

MEF/WF
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Test Procedures and Standards Timeline

* Metrics for 2018 standards, if amended, to be determined during 

the course of this rulemaking (MEF or IMEF; WF or IWF)

Test Procedure

Appendix J1 – MEF, WF

RESIDENTIAL CLOTHES WASHERS

COMMERCIAL CLOTHES WASHERS

Appendix J1 – MEF, WF App. J2 – MEF, WF 

w/ conversion factors

2011 2012 2013 2014 2015 2016 2017 2018 2019

Appendix J2 – IMEF, IWF

Appendix J2*
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Request for Comment

• Item 1-1: DOE invites comment on developing 

correction factors for translating Appendix J1 

MEF/WF values into Appendix J2 MEF/WF values 

that would apply beginning March 7, 2015, at 

which time CCW manufacturers will be required 

to use the Appendix J2 test procedure.

DOE also welcomes any data on the appropriate 

correction factors. 

Test Procedure
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Request for Comment

• Item 1-2: DOE invites comment on whether to 

establish new energy efficiency standards for 

CCWs based on the IMEF metric, which would 

incorporate standby and off mode power.

• Item 1-3: DOE invites comment on its whether to 

establish new water efficiency standards based 

on the IWF metric, which would incorporate 

water consumption from all the temperature 

cycles included as part of the energy test cycle 

in Appendix J2.

Test Procedure
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Test Procedure

Additional Note

• DOE will consider any other test procedure 

issues relating to the use of Appendix J2 for 

commercial clothes washers.
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Rulemaking Process Overview

Regulatory History

Test Procedure

1 Introduction

5 NOPR Analyses

Public Meeting Agenda

6 Closing Remarks
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Technological Feasibility and Economic Justification

 New or amended standards must be designed to achieve the 

maximum improvement in energy or water efficiency that is 

technologically feasible and economically justified.

 DOE performs the following analyses to determine 

technological feasibility:

Rulemaking Process Overview

EPCA Requirement Corresponding DOE Analyses

Technological Feasibility

 Market and Technology Assessment

 Screening Analysis

 Engineering Analysis
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 DOE must consider seven factors to determine whether new or 

amended standards are economically justified:

Rulemaking Process Overview

EPCA Requirement Corresponding DOE Analyses

1. Economic impact on consumers and 

manufacturers

• Life-Cycle Cost Analysis

• Manufacturer Impact Analysis

2. Lifetime operating cost savings 

compared to increased product cost • Life-Cycle Cost Analysis

3. Total projected energy savings • National Impact Analysis 

4. Impact on utility or performance • Engineering Analysis

• Screening Analysis

5. Impact of any lessening of competition • Manufacturer Impact Analysis

6. Need for national energy conservation • National Impact Analysis

7. Other factors the Secretary considers 

relevant

• Environmental Assessment

• Utility Impact Analysis

• Employment Impact Analysis
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Commercial Clothes Washer Rulemaking Schedule

Rulemaking Process Overview

2012 2013 2014 2015

2013 Standards

1/8/13

*NOPR: Notice of Proposed Rulemaking 

Framework

8/13/12

NOPR*

1/31/14

Final Rule

12/31/14

 DOE plans to leverage the analyses performed during the previous 

CCW rulemaking to proceed directly to the NOPR stage.
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Analyses Conducted to Develop NOPR

Rulemaking Process Overview

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact Analysis

Utility Impact 

Analysis

Employment 

Impact Analysis

Emissions 

Analysis

Regulatory 

Impact Analysis

NOPR Analyses

Framework NOPR Final Rule
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NOPR Publication

 Preliminary determination of whether standards should be 

amended, and if so, the proposed new levels

 Results of NOPR analyses presented in Technical Support 

Document (TSD)

 Public meeting and comment period following NOPR 

publication

Rulemaking Process Overview

Framework NOPR Final Rule
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Final Rule Analyses

 Revision of NOPR analyses as necessary based on public 

comments

 Consideration of Department of Justice determination of 

impacts on market competition

Rulemaking Process Overview

Framework NOPR Final Rule
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Final Rule Publication

 Final determination of whether standards should be amended, 

and if so, the new standard levels

 Compliance date of any new standards

 Results of Final Rule analyses presented in Technical Support 

Document (TSD)

Rulemaking Process Overview

Framework NOPR Final Rule
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Rulemaking Process Overview

Regulatory History

Test Procedure

1 Introduction

5 NOPR Analyses

Public Meeting Agenda

6 Closing Remarks
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Analyses Conducted to Develop NOPR

NOPR Analyses

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact Analysis

Utility Impact 

Analysis

Employment 

Impact Analysis

Emissions 

Analysis

Regulatory 

Impact Analysis

NOPR Analyses
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Market and Technology Assessment

Market and Technology Assessment

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact Analysis

Utility Impact 

Analysis

Employment 

Impact Analysis

Emissions 

Analysis

Regulatory 

Impact Analysis

NOPR Analyses
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Market and Technology Assessment

 Purpose:

• Characterize CCW industry and market

• Gather historical shipments and other relevant data

• Identify technology options for improving efficiency

Market and Technology Assessment

Year

Sales
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Request for Comment

• Item 3-1: DOE requests information that would 

contribute to the market assessment for 

commercial clothes washers covered in this 

rulemaking, including:

• Current product features and efficiencies

• Product feature and efficiency trends

• Historical product shipments and prices

Market and Technology Assessment
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Product Classes

 In the 2010 CCW standards rulemaking, DOE 

established two separate product classes:

• Top-Loading

• Front-Loading

 DOE considering retaining these two product 

classes during this rulemaking

Market and Technology Assessment
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Request for Comment

• Item 3-2: DOE seeks comment on the merits of 

retaining two product classes for commercial 

clothes washers based on the location of 

access:

• Top-Loading

• Front-Loading

Market and Technology Assessment
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Technology Assessment

 DOE will consider technology options from previous 

rulemaking, plus any new available technologies

Market and Technology Assessment

Adaptive water fill Polymer bead cleaning

Advanced agitation concepts for 

top-loading washers

Spray rinse or similar water-reducing 

rinse technology

Capacity increase Thermostatically controlled mixing 

valves

Direct-drive motor Water extraction improvements to 

reduce remaining moisture content

Motor efficiency improvements Water fill sensors with greater 

accuracy/precision

Ozonated laundering Water recirculation loop
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Request for Comment

• Item 3-3: DOE seeks comment on whether any of 

the technologies listed in the table should be 

removed from consideration, or whether any 

other technologies not listed in the table should 

be considered.

Market and Technology Assessment
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Screening Analysis

Screening Analysis

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact Analysis

Utility Impact 

Analysis

Employment 

Impact Analysis

Emissions 

Analysis

Regulatory 

Impact Analysis

NOPR Analyses
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Screening Analysis

 Purpose:

• Screen out technology options that DOE

will not consider during the rulemaking

 Criteria:

• Technological feasibility

• Practicability to manufacture, install, and service

• Adverse impacts on product utility or availability

• Adverse impacts on health or safety

Screening Analysis
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Request for Comment

• Item 4-1: DOE seeks comment on whether any of 

the technologies listed should be removed from 

consideration based on any of the screening 

criteria.

If so, please provide details regarding specific 

screening criteria that would preclude DOE from 

considering such technology options.

Screening Analysis
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Engineering Analysis

Engineering Analysis

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact Analysis

Utility Impact 

Analysis

Employment 

Impact Analysis

Emissions 

Analysis

Regulatory 

Impact Analysis

NOPR Analyses
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Engineering Analysis

 Purpose:

• Determine the relationship between manufacturer 

cost and energy efficiency

Engineering Analysis

Efficiency

Cost
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Efficiency Levels for Consideration

Engineering Analysis

*CEE: Consortium for Energy Efficiency

 Top-Loading: DOE is unaware of any top-loading CCWs on the 

market that exceed the Jan. 2013 baseline efficiency level.

 Front-Loading:

Level Description MEF WF

Baseline 2013 DOE Standard 2.00 5.5

Level 1 CEE* Tier 2 2.20 4.5

Level 2 CEE Tier 3 2.40 4.0

Level 3 Maximum Available 2.60 3.7

Level Description MEF WF

Baseline 2013 DOE Standard 1.60 8.5
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Request for Comment

• Item 5-1: DOE seeks input on whether the 

January 8, 2013 amended standard levels are 

appropriate for characterizing the baseline 

efficiency levels for this rulemaking.

• Item 5-2: DOE seeks input on whether any higher 

efficiency levels should be considered for toploading commercial clothes washers, and if so, 

the basis for such consideration.

Engineering Analysis
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Request for Comment

• Item 5-3: DOE seeks input on the 

appropriateness of the higher efficiency levels 

identified for front-loading commercial clothes 

washers.

• Item 5-4: DOE seeks input on appropriate 

maximum technologically feasible efficiency 

levels and the basis for why those levels should 

be selected.

Engineering Analysis
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Approach for Determining Cost-Efficiency Relationship

 “Efficiency-Level Approach”

• Solicit industry-aggregated incremental

manufacturing costs for achieving each higher

efficiency level

 “Design-Option Approach”

• DOE will perform reverse-engineering

teardowns to validate cost-efficiency

relationships

 Proprietary designs will only be considered if they do not 

present a unique path to a given efficiency level.

Engineering Analysis

Image source: http://genuineaid.com/wp-content/uploads/speed-queen/aws44nw-diagram.jpg
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Request for Comment

• Item 5-5: DOE requests feedback on the use of an 

efficiency-level approach to determine the costefficiency relationship for CCWs, supplemented, as 

needed, by a design-option approach.

• Item 5-6: Are there proprietary designs or 

technologies for CCWs of which DOE should be 

aware in this rulemaking? If so, what are these 

designs or technologies and how should DOE 

acquire the cost data necessary for evaluating them?

Engineering Analysis
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Impacts on Consumer Utility

 EPCA requires DOE to consider any lessening of utility or 

performance likely to result from a new standard.

(42 USC 6295(o)(2)(B)(i)(IV), 42 USC 6316(a))

 DOE will consider whether new standards may impact 

consumer utility of commercial clothes washers.

Engineering Analysis
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Request for Comment

• Item 5-7: DOE seeks comment on whether any 

new standards may impact the utility of 

commercial clothes washers.

If such impacts exist, can the effects be 

quantified? If so, how?

Engineering Analysis
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Manufacturer Impact Analysis

Manufacturer Impact Analysis

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact Analysis

Utility Impact 

Analysis

Employment 

Impact Analysis

Emissions 

Analysis

Regulatory 

Impact Analysis

NOPR Analyses
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Legislative Requirements

 The Manufacturer Impact Analysis (MIA) partially fulfills EPCA 

requirement to determine if a proposed standard is 

economically justified:

• Economic impact of standards on manufacturers

• Impacts of any lessening of competition in the industry

 MIA format changes described in the 2006 report to Congress, 

at:

http://www1.eere.energy.gov/buildings/appliance_standards/

pdfs/congressional_report_013106.pdf

Manufacturer Impact Analysis
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MIA Methodology

 Industry Profile

• Identify current and past industry structure

• Evaluate market characteristics and current trends

• Develop industry average financial parameters using publicly available 

information

• Identify manufacturer sub-groups including small business manufacturers

 Framework for Analysis

• DOE will tailor the Governmental Regulatory Impact Model (GRIM) to 

reflect the industry structure

• DOE will use this framework to determine what additional information is 

required to fully analyze the potential impacts to manufacturers 

Manufacturer Impact Analysis

Develop MIA 

Interview 

Guides

Conduct MIA 

Interviews

Assess 

Impacts to 

Industry

Develop Industry 

Profile

Develop 

Framework 

for Analyses
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MIA Methodology

 MIA Interview Guides

• DOE will develop an interview guide designed to collect responses that 

will help inform further analyses and develop key inputs to the GRIM

• Topics include: key issues, market share, markup structure, shipments, 

financial parameters, capital and non-capital expenditures, cumulative 

regulatory burden, direct employment, manufacturing capacity, and the 

anticipated impacts to competition and manufacturer subgroups 

 MIA Interviews

• DOE will conduct confidential interviews with manufacturers to discuss 

the topics outlined in the interview guide, as well as any other topics that 

manufacturers would like to address that pertain to preparing the analysis 

Manufacturer Impact Analysis

Develop Industry 

Profile

Develop 

Framework 

for Analyses

Assess 

Impacts to 

Industry

Develop MIA 

Interview 

Guides

Conduct MIA 

Interviews
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MIA Methodology

 Impacts to Industry

• DOE evaluates the impact to industry both quantitatively and 

qualitatively

• Key quantitative metrics include the estimated impacts to industry netpresent value (INPV) and domestic employment 

• Additionally, DOE will assess the cumulative regulatory burden 

associated with this rulemaking, the effect of the rulemaking on 

competition in the industry, and the disproportionate effects of the 

rulemaking on any previously identified manufacturer subgroups 

including small-business manufacturers 

Manufacturer Impact Analysis

Develop Industry 

Profile

Develop 

Framework 

for Analyses

Develop MIA 

Interview 

Guides

Conduct MIA 

Interviews

Assess 

Impacts to 

Industry
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Manufacturer Subgroups

 Groups of manufacturers that may be disproportionately 

affected by efficiency standards:

• DOE has identified one small business manufacturer of 

commercial clothes washers

• DOE has identified one low-volume manufacturer of commercial 

clothes washers

 Regulations that could affect the industries impacted by this 

rulemaking include:

• DOE standards for residential clothes washers, clothes dryers, 

and room air conditioners (existing and upcoming)

• Reduction of Hazardous Substances (RoHS) directive

Manufacturer Impact Analysis

Cumulative Regulatory Burden
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Request for Comment

• Item 12-1: DOE seeks to identify small businesses 

and low volume manufacturers that could be 

impacted by energy conservation standards for 

commercial clothes washers.

• Item 12-2: DOE seeks comment on any additional 

manufacturer subgroups, if any, that DOE should 

consider in a manufacturer subgroup analysis for 

commercial clothes washers. DOE seeks to 

understand how the impact of potential standards 

may differ for each subgroup.

Manufacturer Impact Analysis
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Request for Comment

• Item 12-3: What other regulations or pending 

regulations should DOE consider in its 

examination of cumulative regulatory burden?

Manufacturer Impact Analysis
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Markups Analysis

Markups Analysis

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact Analysis

Utility Impact 

Analysis

Employment 

Impact Analysis

Emissions 

Analysis

Regulatory 

Impact Analysis

NOPR Analyses
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Markups Analysis

LCC and PBP Analysis Inputs

Energy and 

Water Use

Energy and 

Water Prices

From Energy 

and Water Use 

Analysis

(Use is a 

function of 

Efficiency)

Installation 

Cost

Equipment 

Price

From 

Engineering 

Analysis

(Price is a 

function of 

Efficiency)

From 

Markups 

Analysis

Baseline 

Manufacturer 

Price

Std-Level 

Manufacturer 

Price

Consumer 

Retail Price 

Markup

Sales Tax

Repair Cost

Maintenance 

Cost

Annual Energy 

and Water 

Expense

Lifetime

Discount Rate

Energy and 

Water Price

Annual 

Operating 

Expense

Total Installed 

Cost

Lifetime 

Operating 

Expense

Payback Life-Cycle 

Cost

Data Inputs

Intermediate Analysis

Output Results
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Markups Analysis

Distribution Channel for CCW
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Types of Markups in Distribution Chain

 Baseline Markups:

• Markups relate consumer price to cost of goods sold (CGS).

• Baseline markups relate price to cost prior to a change in efficiency.

• Baseline markups indicate a consumer price that covers all of a 

distributor’s or contractor’s expenses plus profit

 Incremental Markups:

• Incremental markups relate the incremental change in consumer price 

to the incremental change in CGS.

• Certain costs, such as direct labor costs (salaries, payroll, rental and 

occupancy), do not vary with efficiency induced changes in CGS and 

remain constant in the calculation of incremental markups.

• Incremental markups cover only expenses that vary with CGS –

expenses that increase due to an increase in equipment efficiency

Markups Analysis
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Request for Comment

• Item 7-1: DOE welcomes comments on whether 

the distribution channels described above are 

the same.

• Item 7-2: DOE seeks input on data sources for 

establishing the mark-ups.

Markups Analysis
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Markups Analysis

Markups Analysis

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact Analysis

Utility Impact 

Analysis

Employment 

Impact Analysis

Emissions 

Analysis

Regulatory 

Impact Analysis

NOPR Analyses
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Energy and Water Use Analysis

 Purpose:

• Develop annual energy and water use data for the life-cycle cost 

and payback period analyses to calculate annual operating 

costs.

 Method:

• DOE will develop average energy and water use values.

• Test procedure utilizes single value based on residential use

• DOE will establish appropriate range of usage specific to CCW 

in the field for two applications: 

- Multi-family buildings

- Laundromats

• DOE will investigate variability.

Energy and Water Use Analysis
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 DOE requests per-cycle energy and water use for each efficiency level.

Front-Loading Clothes Washers:

Top-Loading Clothes Washers:

 Convert per-cycle values into annual values using cycles per year

• Multi-Housing: Multi-housing Laundry Association (MLA) provides various 

sources to establish cycles/day (1-11 cycles/day).

• Laundromats: Coin Laundry Association (CLA) provides 3-8 cycles/day.

• DOE may investigate other establishments with on-site laundry facilities.

Energy and Water Use Analysis

Level

Efficiency Level 

Source

Efficiency Level Energy Use (kWh/cycle)

Water Use

MEF Water Factor (gal/cycle)

Hot 

Water Machine Dryer

Baseline DOE Standard 2.0 5.5

1 CEE Tier 2 2.2 4.5

2 CEE Tier 3 2.4 4.0

3 Maximum Available* 2.6 3.7

* Provide the clothes container volume in cubic feet

Level

Efficiency Level 

Source

Efficiency Level Energy Use (kWh/cycle)

Water Use

MEF Water Factor (gal/cycle)

Hot 

Water Machine Dryer

Baseline DOE Standard 1.60 8.5
65 | Building Technologies Program eere.energy.gov

Annual Usage

per Application Type

(cycles/year)

x

Machine, 

Water Heater

& Dryer 

Fuel Types 

Consumption

Per Cycle

Annual Energy Use 

by Efficiency Level 

and Application Type

Approach

Energy and Water Use Analysis
66 | Building Technologies Program eere.energy.gov

Request for Comment

• Item 6-1: DOE seeks stakeholder input on the 

approaches considered for specifying the typical 

annual energy and water consumption. Most 

importantly, DOE is interested in new sources of 

data that can assist in characterizing the cycles 

per year for commercial clothes washers.

Energy and Water Use Analysis
67 | Building Technologies Program eere.energy.gov

Life-Cycle Cost and Payback Period Analysis

LCC and PBP Analysis

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact Analysis

Utility Impact 

Analysis

Employment 

Impact Analysis

Emissions 

Analysis

Regulatory 

Impact Analysis

NOPR Analyses
68 | Building Technologies Program eere.energy.gov

 Purpose:

• Assess the net life-cycle cost (LCC) impacts of differing efficiency levels on the 

consumer.

 Method:

• LCC equals consumer price plus the sum of annual operating costs (including 

repair and maintenance costs) discounted to a particular base year.

• Economic evaluation from the consumer perspective.

• Analysis implemented in an Excel® spreadsheet.

• Results are expressed as LCC difference (baseline minus standard level).

• Payback Period (PBP) is also calculated and reported in this analysis.

• Simple payback equals the incremental first cost divided by the operating cost 

savings for 1 year.

LCC and PBP Analysis

Consumer LifeCycle Cost

(Baseline and 

Standards Cases)

LCC Impacts

(Difference between

Operating Cost Baseline and Standard)

(Sum & Discount to 

Present Value)

First Cost

(Consumer price & 

Installation)
69 | Building Technologies Program eere.energy.gov

Approach

 Monte Carlo simulation analysis to be used

• Characterize the variability and uncertainty associated with the inputs 

using probability distributions.

• Studies will be used to characterize the variability in washer usage in 

Multi-family and Laundromat applications.

• Probability distributions will be used to characterize the uncertainty in 

other operating cost inputs (e.g., discount rates, equipment lifetimes) 

and manufacturing costs.

 One LCC and PBP analysis result per product class

• Analysis to be conducted for each proposed product class to be 

analyzed in detail in the Engineering Analysis.

 Develop base case efficiency distributions to avoid overstating the 

benefits from increasing product efficiency.

• Market share data (or base case efficiency distributions) show the 

percentage of consumers already purchasing efficient products.

• DOE will develop efficiency distributions based on historical data.

LCC and PBP Analysis
70 | Building Technologies Program eere.energy.gov

Request for Comment

• Item 8-1: DOE seeks input on the extent to which 

purchasers of CCWs are able to either pass on 

the higher purchase costs of more efficient 

CCWs, or otherwise recover those costs.

• Item 8-6: DOE requests data from interested 

parties to characterize the current mix of 

commercial clothes washer efficiencies in the 

market.

LCC and PBP Analysis
71 | Building Technologies Program eere.energy.gov

LCC and PBP Analysis

Efficiency Distributions Example from 2010 CCW LCC Analysis
72 | Building Technologies Program eere.energy.gov

Energy Prices

 Electricity, Natural Gas and Oil prices are used to convert energy use 

to energy costs. 

 DOE will develop electricity prices from DOE-Energy Information 

Administration (EIA) Form 861 data. 

 DOE will develop natural gas and oil prices from “Natural Gas 

Monthly” and “Petroleum Navigator.”

 DOE will use the DOE-EIA Annual Energy Outlook (AEO) for 

projections of future average energy prices (reference, high, and low 

scenarios). 

 DOE may evaluate other quantitative price projections provided by 

stakeholders as sensitivities.

LCC and PBP Analysis
73 | Building Technologies Program eere.energy.gov

Water and Wastewater Prices

 Water and Wastewater prices are used to convert water use to water 

costs. 

 DOE will develop water and wastewater prices from AWWA and 

Raftelis Financial Consultants (RFC). 

 DOE will use historical Bureau of Labor’s Consumer Price Index for 

Water and Sewerage for projections of future average water prices and 

historical RFC data. 

 DOE may evaluate other quantitative price projections provided by 

stakeholders as sensitivities.

LCC and PBP Analysis
74 | Building Technologies Program eere.energy.gov

Request for Comment

• Item 8-2: DOE seeks input from interested 

parties on the planned approach for estimating 

current and forecasted energy, water, and 

wastewater prices.

LCC and PBP Analysis
75 | Building Technologies Program eere.energy.gov

Discount Rates

 DOE uses discount rates (DR) to discount future operating 

costs savings.

 DOE will use similar approach as for other commercial product 

standards rulemakings.

• Derived from estimates of the cost of capital for companies that 

purchase commercial clothes washers.

 Finance cost based on:

• Financial cost of any debt incurred to purchase products (e.g., 

debt and equity capital)

• Opportunity cost of any equity to purchase products

• Damodaran Online and Ibbotson’s Associates are sources for 

much of the equity and debt data.

LCC and PBP Analysis
76 | Building Technologies Program eere.energy.gov

Request for Comment

• Item 8-5: DOE seeks stakeholder input on the 

planned approach for estimating discount rates 

for commercial customers.

LCC and PBP Analysis
77 | Building Technologies Program eere.energy.gov

Maintenance, Repair, Installation Costs

 DOE does not currently have information indicating that routine 

repair and maintenance costs are different for more and less 

efficient commercial clothes washers.

 DOE assumes that increases in installation costs are negligible 

for more efficient units.

LCC and PBP Analysis
78 | Building Technologies Program eere.energy.gov

Request for Comment

• Item 8-3: DOE seeks stakeholder input on 

whether it is correct to assume that changes in 

maintenance, repair, and installation costs will 

be negligible for more efficient commercial 

clothes washers. If it is incorrect, DOE is 

interested in the reasons why this is so and 

specific ways to correct this assumption.

LCC and PBP Analysis
79 | Building Technologies Program eere.energy.gov

Product Lifetimes

 Past DOE analyses have used the following lifetimes:

• Laundromats (7.13)

• Multi-family Laundry (11.25 years)

Based on the following sources:

LCC and PBP Analysis

Lifetime (years) Source

7 to 10 CEE (1998)

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

a

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

Coin Laundry Association. Industry 

Overview. Downers Grove, IL.

8 to 9

c

ACEEE (2001) 

5 (high-use)ato 13 (low-use)bSouthern California Edison (2000) 

15b †

California Measurement Advisory 

Committee (CALMAC) (2000)

a

Used to establish Laundromat lifetime only; bUsed to establish multi-family lifetime only; 

c

Depending on the usage rate, the life can be shorter; † Based on engineering judgment.
80 | Building Technologies Program eere.energy.gov

Request for Comment

• Item 8-4: DOE seeks stakeholder input on 

appropriate lifetimes for the commercial clothes 

washer classes covered in this rulemaking.

LCC and PBP Analysis
81 | Building Technologies Program eere.energy.gov

Shipments Analysis

Shipments Analysis

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact Analysis

Utility Impact 

Analysis

Employment 

Impact Analysis

Emissions 

Analysis

Regulatory 

Impact Analysis

NOPR Analyses
82 | Building Technologies Program eere.energy.gov

Shipments Analysis

 Purpose:

• Quantify changes in product shipments due to potential new 

energy efficiency standards.

 Method:

• The shipments model will rely on a range of data sources.

• The model will only consider shipments of covered products.

Shipments Analysis
83 | Building Technologies Program eere.energy.gov

Approach – Accounting Methodology

 The base case projection: 

• Depicts the situation where new standards are not adopted

• Serves as a reference point from which to evaluate the impacts 

of standards

• Projection accounts for products going to replace failed units, 

and those going to establishments due to new construction

 Data needed to develop base case projection: 

• Historical shipments

• Historical saturation rates to properly account for existing stock 

of products.

• Market share efficiencies

Shipments Analysis
84 | Building Technologies Program eere.energy.gov

Historical Shipments Data

Based on publicly-available data sources

 DOE projected flat shipments in the last rulemaking due to a 

decline observed in the data.

Shipments Analysis

0.00

0.05

0.10

0.15

0.20

0.25

0.30

1985 1990 1995 2000 2005 2010 2015 Million

Appliance Magazine Statistical Review

AHAM Data Submittal

Quantity Index based Trend
85 | Building Technologies Program eere.energy.gov

Historical Sales Data

 DOE requests historical shipment data.

 DOE requests market share efficiency data.

Shipments Analysis

Year

Shipments, Domestic + Imports

Top-Loading 

(Thousands of Units)

Front-Loading 

(Thousands of Units)

1990

1991

2011

Top-Loading Front-Loading

Efficiency Bins Market Share

(Percent)

Efficiency Bins Market Share

(Percent)

(MEF) (WF) 2009 2010 2011 (MEF) (WF) 2009 2010 2011

< 1.42 > 9.5 < 2.0 >5.5

1.42 – 1.6 9.5 – 8.5 2.0 – 2.2 5.5 – 4.5

> 1.6 < 8.5 2.2 – 2.4 4.5 – 4.2

2.4 – 2.6 4.2 – 3.7

>2.6 <3.7
86 | Building Technologies Program eere.energy.gov

Request for Comment

• Item 9-1: DOE seeks historical shipments data 

broken down by product class.

• Item 9-2: DOE seeks input on whether 

conversions from apartments to 

condos/townhouses are still occurring.

Shipments Analysis
87 | Building Technologies Program eere.energy.gov

Standards Impacts on Product Shipments

 DOE develops Standards Case Projections from the same data it used 

to develop the Base Case Projections.

 Standards Case Projections also use purchase price increases and 

operating cost savings to estimate shipments impacts.

• DOE may utilize RCW elasticities if no new data becomes available

 It is difficult to obtain data showing sensitivity of shipments to 

purchase price and operating costs.

• DOE may estimate Standards Case shipments projections with 

scenarios (i.e., specific percentage drops in annual shipments for 

particular efficiency levels).

• DOE will consider cross-price elasticity to project changes in market 

shares across product classes

Shipments Analysis
88 | Building Technologies Program eere.energy.gov

Request for Comment

• Item 9-3: DOE requests input from 

manufacturers and other stakeholders on 

historical shipments by efficiency, historical 

prices of CCW for specific product categories.

• Item 9-4: DOE seeks input from manufacturers 

and other stakeholders on the potential impact 

of amended CCW energy conservation 

standards on equipment shipments, and 

whether the elasticities developed for RCW 

would be appropriate for CCW.

Shipments Analysis
89 | Building Technologies Program eere.energy.gov

National Impact Analysis

National Impact Analysis

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact Analysis

Utility Impact 

Analysis

Employment 

Impact Analysis

Emissions 

Analysis

Regulatory 

Impact Analysis

NOPR Analyses
90 | Building Technologies Program eere.energy.gov

 Purpose:

• Determine the projected national energy, water, and wastewater savings 

and consumer national net present value.

 Method:

• Develop annual series of national energy, water, and wastewater and 

economic impacts.

• Utilize the shipments model to estimate the total stock of appliances in 

service each year.

• Utilize the LCC to estimate cost and energy and water use per unit in 

any given year.

• Aggregate the costs and energy and water use for all years in the 

analysis period.

• Report national energy savings (NES) and national water savings 

(NWS).

• Report estimates for economic impact as change in consumer National 

Net Present Value (NPV) (in constant year dollars).

• Account for the time-value of money though defined discount rates.

National Impact Analysis
91 | Building Technologies Program eere.energy.gov

National Impact Analysis

National Energy and Water Savings Flow Diagram

Base Case

Annual Energy

Consumption

2047

Base Case

Annual Energy

Consumption

2020

Base Case

Annual Energy

Consumption

2019

Base Case

Annual Energy 

& Water

Consumption

2018

Shipments

Analysis StandardsCase Projection

Base-Case 

Projection

Base Case

Annual Energy

Consumption

2047

Base Case

Annual Energy

Consumption

2020

Base Case

Annual Energy

Consumption

2019

Standards Case

Annual Energy

& Water

Consumption

2018

Base-Case

Cumulative

Energy 

& Water Use

Standards-Case 

Cumulative

Energy 

& Water Use

Site to Source

Energy

Conversion

National Energy

& Water

Savings
92 | Building Technologies Program eere.energy.gov

National Impact Analysis

National Consumer Net Present Value Flow Diagram

Shipments

Analysis StandardsCase Projection

Energy & Water

Cost

(2018 –

2047)

Base-Case 

Projection

Cumulative

Operating Cost 

Savings

Cumulative

Total Equipment

Cost Increase

Discount 

Rate

Net Present

Value

Maint &

Repair Cost

(2018 –

2047)

Equipment

Cost

(2018 –

2047)

Energy

& Water Cost

(2018 –

2047)

Maint &

Repair Cost

(2018 –

2047)

Equipment

Cost

(2018 –

2047)
93 | Building Technologies Program eere.energy.gov

Shipment-Weighted Efficiency and Market Share 

Efficiency Data

 Shipment-weighted efficiency data:

• Key components of the national impact analysis are dependent on 

shipment-weighted efficiencies.

- Per-unit annual energy and water consumption—needed to determine NES, NWS.

- Retail price and per-unit annual operating costs—needed to determine NPV.

• Historical trends in product efficiency help project future product 

efficiencies for the base-case.

- DOE may consider impacts from market pull programs

 Market share efficiency data:

• Historical market share efficiency data help estimate how standards will 

impact base-case efficiencies.

• Market share data (or base-case efficiency distributions) will also be 

used in the national impact analysis.

- DOE has assumed a “roll up” scenario to project standards impacts in past standards 

rulemakings.

National Impact Analysis
94 | Building Technologies Program eere.energy.gov

 Full fuel cycle (FFC) measure of energy and greenhouse gas 

and other emissions will now be measured in this and future 

conservation standards rulemakings.

• NEMS will be the model used to determine FFC

• FFC multipliers will be presented and discussed in the NOPR 

TSD.

National Impact Analysis
95 | Building Technologies Program eere.energy.gov

Commercial Clothes Washer Historical Efficiency Data

 DOE requests historical shipment-weighted average efficiency data by 

product class in order to calculate NES, NWS, and NPV.

National Impact Analysis

Year

Shipment-Weighted Average Efficiency 

Top-Loading Front-Loading

(MEF ) (WF) (MEF) (WF)

1997

1998

1999

2000

2001

2002

2003

2004

2006

2007

2008

2009

2010

2011
96 | Building Technologies Program eere.energy.gov

Request for Comment

• Item 10-1: DOE seeks historical SWEF data by 

product class. DOE also seeks historical market 

share data showing the percentage of equipment 

shipments by efficiency level for as many 

product classes as possible.

National Impact Analysis
97 | Building Technologies Program eere.energy.gov

Consumer Subgroup Analysis

Consumer Subgroup Analysis

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact Analysis

Utility Impact 

Analysis

Employment 

Impact Analysis

Emissions 

Analysis

Regulatory 

Impact Analysis

NOPR Analyses
98 | Building Technologies Program eere.energy.gov

Consumer Subgroup Analysis

 Purpose:

• Analyze the economic impacts of standards on consumers, 

including subgroups who may be disproportionately impacted 

compared with the general user population.

 Method:

• Extend the LCC analysis to examine the impacts for defined 

subgroups.

Consumer Subgroup Analysis
99 | Building Technologies Program eere.energy.gov

Request for Comment

• Item 11-1: DOE requests input on any consumer 

subgroups it should consider when analyzing 

standards for commercial clothes washers.

Consumer Subgroup Analysis
100 | Building Technologies Program eere.energy.gov

Utility Impact Analysis

Utility Impact Analysis

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact 

Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact 

Analysis

Utility Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Regulatory 

Impact 

Analysis

NOPR Analyses
101 | Building Technologies Program eere.energy.gov

Utility Impact Analysis

 Purpose:

• Assess the overall impacts on domestic energy supplies that 

would result from the imposition of standards. 

 Method:

• Uses NEMS-BT, a variant of the NEMS (National Energy 

Modeling System) developed and used by DOE/EIA for their 

Annual Energy Outlook (AEO).

• Analysis consists of a comparison between model results for the 

most recent AEO Reference Case and for cases in which energy 

use is decremented to reflect the impact of standards.

Utility Impact Analysis
102 | Building Technologies Program eere.energy.gov

Request for Comment

• Item 13-1: DOE seeks input from stakeholders 

regarding its plan to use NEMS-BT to conduct 

the utility impact analysis. Is the NEMS-BT 

model appropriate for assessing utility impacts 

of energy conservation standards? If not, why? 

What would be a more appropriate model for 

DOE to use?

Utility Impact Analysis
103 | Building Technologies Program eere.energy.gov

Employment Impact Analysis

Employment Impact Analysis

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact 

Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact 

Analysis

Utility Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Regulatory 

Impact 

Analysis

NOPR Analyses
104 | Building Technologies Program eere.energy.gov

Employment Impact Analysis

 Purpose:

• Assess the overall impact on national employment from the 

imposition of efficiency standards at differing levels.

• Include both direct and indirect employment impacts.

- Direct employment impacts are estimated in the manufacturer 

impact analysis.

- Indirect employment impacts result from shifting consumer 

expenditures among goods and services ( “substitution effect”) and 

changing equipment and energy costs (“income effect”).

 Method:

• DOE intends to use the ImSET (Impact of Sector Energy 

Technologies) model for the evaluation of indirect employment 

impacts. 

Employment Impact Analysis
105 | Building Technologies Program eere.energy.gov

Request for Comment

• Item 14-1: DOE welcomes feedback on its 

approach to assessing national employment 

impacts.

Employment Impact Analysis
106 | Building Technologies Program eere.energy.gov

Emissions Analysis

Emissions Analysis

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact 

Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact 

Analysis

Utility Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Regulatory 

Impact 

Analysis

NOPR Analyses
107 | Building Technologies Program eere.energy.gov

Emissions Analysis

 Purpose:

• Estimate emissions impacts from amended energy conservation 

standards for commercial clothes washers, including changes in Full 

Fuel Cycle (FFC) emissions as well as site emissions from use of gas 

and oil (for water heating) 

 Method:

• DOE bases the emission factors for FFC on EIA’s Annual Energy 

Outlook, supplemented by data from other sources. The following 

emissions are assessed: 

- Carbon dioxide (CO2)

- Sulfur dioxide (SO2) 

– SO2 emissions from affected electric generating units are subject to nationwide 

and regional emissions cap and trading programs; thus no impact from standards

- Nitrogen oxides (NOx)

– Clean Air Interstate Rule (CAIR) permanently caps NOx emissions in 28 eastern 

States and DC; DOE considers impacts in remaining States

- Methane (CH4)

- Nitrous Oxide (N2O)

- Mercury (Hg)

Emissions Analysis
108 | Building Technologies Program eere.energy.gov

Monetization of Emission Reductions

 DOE intends to use the most current Social Cost of Carbon (SCC) 

values developed by interagency reviews.

• SCC is intended to be a monetary measure of the incremental damage 

resulting from greenhouse gas (GHG) emissions, including but not 

limited to agricultural productivity loss, human health effects, property 

damage from rising sea level, and changes in the ecosystem.

 At present, the most recent interagency estimates of the potential 

global benefits resulting from reduced CO2 emissions in 2015, 

expressed in 2011$, were $6.1, $25.4, $41.0, and $77.7 per metric ton 

avoided. 

• For emission reductions that occur in later years, these values grow in 

real terms over time.

 DOE will also estimate the potential monetary benefit of reduced NOx

emissions resulting from the considered standard levels.

Emissions Analysis
109 | Building Technologies Program eere.energy.gov

Request for Comment

• Item 15-1: DOE seeks input on its plans to use 

NEMS-BT and other sources to analyze 

emissions impacts of potential standards on 

commercial clothes washers.

Emissions Analysis
110 | Building Technologies Program eere.energy.gov

Regulatory Impact Analysis

Regulatory Impact Analysis

Market and 

Technology 

Assessment

Screening 

Analysis

Engineering 

Analysis

Markups 

Analysis

Energy and 

Water Use 

Analysis

Life Cycle Cost 

and Payback 

Period Analysis 

Shipments 

Analysis

National 

Impact 

Analysis

Consumer 

Sub-group 

Analysis

Manufacturer 

Impact 

Analysis

Utility Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Regulatory 

Impact 

Analysis

NOPR Analyses
111 | Building Technologies Program eere.energy.gov

Regulatory Impact Analysis

 This analysis estimates the potential for non-regulatory 

approaches to supplant or augment efficiency standards to 

improve product efficiency.

 DOE will evaluate past, existing, and expected non-regulatory 

programs.

Regulatory Impact Analysis
112 | Building Technologies Program eere.energy.gov

4

3

2

Rulemaking Process Overview

Regulatory History

Test Procedure

1 Introduction

5 NOPR Analyses

Public Meeting Agenda

6 Closing Remarks
113 | Building Technologies Program eere.energy.gov

Instructions for Submitting Comments

 In all correspondence, please refer to this Commercial Clothes Washer 

Rulemaking by:

• Docket # EERE-2012-BT-STD-0020, and/or RIN 1904-AC77

 Email: CommClothesWashers-2012-STD-0020@ee.doe.gov

 Postal Mail: Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE-2J

1000 Independence Avenue, SW.

Washington, D.C. 20585-0121

 Courier: Ms. Brenda Edwards, 950 L’Enfant Plaza, SW., Suite 600

 Phone: (202) 586-2945

Introduction

Comment period closes October 12, 2012