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 Energy2 | Building Technologies Program eere.energy.gov



## 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 Remarks3 | Building Technologies Program eere.energy.gov 

## 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 Witkowski4 | Building Technologies Program eere.energy.gov 

## Opening Remarks

Interested parties who contacted DOE to request an opportunity to issue an opening statement

should speak now.5 | 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 Remarks6 | Building Technologies Program eere.energy.gov 

## 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 

## Introduction7 | Building Technologies Program eere.energy.gov



## 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 cor respond to those in the Framework Document

.

• DOE welcomes comments concerning these specific issues and 

### any other issues related to the this rulemaking. 

## Introduction8 | 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, 20129 | 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 Remarks10 | Building Technologies Program eere.energy.gov 

## 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 rulemaking11 | Building Technologies Program eere.energy.gov



## Definition of Covered Products

 EPACT 2005 defines commercial clothes washers as follows: 

## Regulatory History

The term “commercial clothes washer” means a soft

- mount front

loading 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 multi

family housing common areas and coin laundries ; or ( ii) other commercial applications. (42 U.S.C. 6311(21))12 | Building Technologies Program eere.energy.gov



## 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 ) [ ft 3 /kwh/cycle] 1.26 (minimum) Water Factor (WF ) [ gal/cycle/ft 3 ] 9.5 (maximum)

Product Class MEF (minimum) WF (maximum)
Top

- Loading 1.60 8.5

Front

- Loading 2.00 5.513 | 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 Remarks14 | Building Technologies Program eere.energy.gov 

## 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.15 | Building Technologies Program eere.energy.gov



## 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/WF16 | Building Technologies Program eere.energy.gov



## 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 2012 2013 2014 2015 2016 2017 2018 2019 2011 Appendix J2

– IMEF, IWF

Appendix J2*17 | Building Technologies Program eere.energy.gov



## 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 Procedure18 | Building Technologies Program eere.energy.gov



## 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 Procedure19 | Building Technologies Program eere.energy.gov 

## Test Procedure

Additional Note

• DOE will consider any other test procedure issues relating to the use of Appendix J2 for 

## commercial clothes washers.20 | 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 Remarks21 | Building Technologies Program eere.energy.gov 

## Technological Feasibility and Economic Justification

 N ew 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 Analysis22 | Building Technologies Program eere.energy.gov 

###  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 Analysis23 | Building Technologies Program eere.energy.gov 

## Commercial Clothes Washer Rulemaking Schedule 

## Rulemaking Process Overview

2013 2014 2012 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.24 | Building Technologies Program eere.energy.gov



## 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 Rule25 | Building Technologies Program eere.energy.gov 

## 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 m eeting and comment period following NOPR publication 

## Rulemaking Process Overview

Framework NOPR Final Rule26 | Building Technologies Program eere.energy.gov 

## 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 Rule27 | Building Technologies Program eere.energy.gov



## 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 Rule28 | 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 Remarks29 | Building Technologies Program eere.energy.gov



## 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 Analyses30 | Building Technologies Program eere.energy.gov



## 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 Analyses31 | Building Technologies Program eere.energy.gov



## 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 Sales32 | Building Technologies Program eere.energy.gov



## 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 Assessment33 | Building Technologies Program eere.energy.gov 

## 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 Assessment34 | Building Technologies Program eere.energy.gov



## 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 Assessment35 | Building Technologies Program eere.energy.gov



## 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 loop36 | Building Technologies Program eere.energy.gov



## 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 Assessment37 | Building Technologies Program eere.energy.gov 

## 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 Analyses38 | Building Technologies Program eere.energy.gov 

## 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 Analysis39 | Building Technologies Program eere.energy.gov



## 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 Analysis40 | Building Technologies Program eere.energy.gov 

## 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 Analyses41 | Building Technologies Program eere.energy.gov 

## Engineering Analysis

 Purpose:

• Determine the relationship between manufacturer cost and energy efficiency 

## Engineering Analysis

Efficiency Cost42 | Building Technologies Program eere.energy.gov



## 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 8.543 | Building Technologies Program eere.energy.gov



## 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 top

loading commercial clothes washers, and if so, the basis for such consideration. 

## Engineering Analysis44 | Building Technologies Program eere.energy.gov



## 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 Analysis45 | Building Technologies Program eere.energy.gov 

## 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.jpg46 | Building Technologies Program eere.energy.gov



## Request for Comment

• Item 5

- 5: DOE requests feedback on the use of an efficiency

- level approach to determine the cost

efficiency 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 Analysis47 | Building Technologies Program eere.energy.gov



## 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 Analysis48 | Building Technologies Program eere.energy.gov



## 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 Analysis49 | Building Technologies Program eere.energy.gov



## 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 Analyses50 | Building Technologies Program eere.energy.gov



## 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 Analysis51 | Building Technologies Program eere.energy.gov 

## 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 Analyses52 | Building Technologies Program eere.energy.gov 

## 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

Interviews53 | Building Technologies Program eere.energy.gov 

## MIA Methodology

 Impacts to Industry

• DOE evaluates the impact to industry both quantitatively and qualitatively

• Key quantitative metrics include the estimated impacts to industry net

present 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 Industry54 | Building Technologies Program eere.energy.gov



## 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 Burden55 | Building Technologies Program eere.energy.gov



## 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 Analysis56 | Building Technologies Program eere.energy.gov



## Request for Comment

• Item 12

- 3: 

## What other regulations or pending regulations should DOE consider in its examination of cumulative regulatory burden ? 

## Manufacturer Impact Analysis57 | Building Technologies Program eere.energy.gov 

## 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 Analyses58 | Building Technologies Program eere.energy.gov 

## 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 Results59 | Building Technologies Program eere.energy.gov 

## Markups Analysis

Distribution Channel for CCW60 | Building Technologies Program eere.energy.gov



## 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 Analysis61 | Building Technologies Program eere.energy.gov



## 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 Analysis62 | Building Technologies Program eere.energy.gov 

## 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 Analyses63 | Building Technologies Program eere.energy.gov



## 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 Analysis64 | Building Technologies Program eere.energy.gov  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 (gal/cycle) MEF Water Factor 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 (gal/cycle) MEF Water Factor Hot Water Machine Dryer

Baseline DOE Standard 1.60 8.565 | 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 Analysis66 | 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 Analysis67 | 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 Analyses68 | 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 Life

Cycle Cost (Baseline and Standards Cases) LCC Impacts (Difference between Baseline and Standard ) Operating Cost (Sum & Discount to Present V alue ) 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 Analysis70 | 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 Analysis71 | Building Technologies Program eere.energy.gov 

## LCC and PBP Analysis

Efficiency Distributions Example from 2010 CCW LCC Analysis72 | 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 Analysis73 | 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 Analysis74 | 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 Analysis75 | 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 Analysis76 | 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 Analysis77 | 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 Analysis78 | 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 Analysis79 | 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 15 b Coin Laundry Association. Industry Overview. Downers Grove, IL.
8 to 9 c ACEEE (2001) 5 ( high

- use) a to 13 ( low

- use) b Southern California Edison (2000)

15 b † California Measurement Advisory Committee (CALMAC) (2000)

a Used to establish Laundromat lifetime only; b Used 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 Analysis81 | 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 Analyses82 | 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 Analysis83 | 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 Analysis84 | 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 Analysis85 | 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 <3.786 | 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 Analysis87 | 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 Analysis88 | 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 Analysis89 | 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 Analyses90 | 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 Analysis91 | 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 Standards

Case 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 Savings92 | Building Technologies Program eere.energy.gov 

## National Impact Analysis

National Consumer Net Present Value Flow Diagram

Shipments Analysis Standards

Case 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 Analysis94 | 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 Analysis95 | 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
201196 | 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 Analysis97 | 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 Analyses98 | 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 Analysis99 | 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 Analysis100 | 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 Analyses101 | 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 Analysis102 | 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 Analysis103 | 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 Analyses104 | 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 Analysis105 | 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 Analysis106 | 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 Analyses107 | 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 Analysis108 | 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 Analysis109 | 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 Analysis110 | 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 Analyses111 | 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 Analysis112 | 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 Remarks113 | 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