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CHAPTER 1. INTRODUCTION

TABLE OF CONTENTS

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

1.2 SUMMARY OF NATIONAL BENEFITS (ANNUALIZED)........................................ 1-1

1.3 OVERVIEW OF STANDARDS FOR RESIDENTIAL REFRIGERATORS, 

REFRIGERATOR-FREEZERS, AND FREEZERS ....................................................... 1-3

1.4 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS ................... 1-4

1.5 STRUCTURE OF THE DOCUMENT............................................................................ 1-7

LIST OF TABLES

Table 1.2.1 Annualized Benefits and Costs of Proposed Standards for Refrigeration 

Products for 2014-2043 Period ............................................................................ 1-2

Table 1.4.1 Analyses Under the Process Rule ........................................................................ 1-6
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CHAPTER 1. INTRODUCTION

1.1 PURPOSE OF THE DOCUMENT

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

analyses and results supporting the development of the notice of proposed rulemaking (NOPR) 

of this rulemaking for residential refrigeration products.

1.2 SUMMARY OF NATIONAL BENEFITS (ANNUALIZED)

The benefits and costs of today’s proposed standards can also be expressed in terms of 

annualized values over the 30-year analysis period (2014–2043). Estimates of annualized values 

are shown in Table 1.2.1 The annualized monetary values are the sum of (1) the annualized 

national economic value, expressed in 2009$, of the benefits from operating products that meet 

the proposed standards (consisting primarily of operating cost savings from using less energy, 

minus increases in equipment purchase costs, which is another way of representing consumer 

NPV), and (2) the monetary value of the benefits of emission reductions, including CO2 emission 

reductions. The value of the CO2 reductions, otherwise known as the Social Cost of Carbon 

(SCC), is calculated using a range of values per metric ton of CO2 developed by a recent 

interagency process. The monetary costs and benefits of cumulative emissions reductions are 

reported in 2009$ to permit comparisons with the other costs and benefits in the same dollar 

units. The derivation of the SCC values is discussed in chapter 15 of this TSD. 

Although combining the values of operating savings and CO2 reductions provides a 

useful perspective, two issues should be considered. First, the national operating savings are 

domestic U.S. consumer monetary savings that occur as a result of market transactions while the 

value of CO2 reductions is based on a global value. Second, the assessments of operating cost 

savings and CO2 savings are performed with different methods that use quite different time 

frames for analysis. The national operating cost savings is measured for the lifetime of 

refrigeration products shipped in 2014–2043. The SCC values, on the other hand, reflect the 

present value of all future climate-related impacts resulting from the emission of one ton of 

carbon dioxide in each year. These impacts go well beyond 2100.
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Table 1.2.1 Annualized Benefits and Costs of Proposed Standards for Refrigeration 

Products for 2014-2043 Period

Discount 

Rate

Primary 

Estimate*

Low Estimate* High Estimate*

Monetized (million 2009$/year)

Benefits

Operating Cost Savings

7% 2112 1852 2377

3% 2929 2520 3335

CO2 Reduction at $4.7/t** 5% 85 85 85

CO2 Reduction at $21.4/t** 3% 316 316 316

CO2 Reduction at $35.1/t** 2.5% 492 492 492

CO2 Reduction at $64.9/t** 3% 963 963 963

NOX Reduction at $2,519/t** 7% 7 7 7

3% 33 33 33

Total (Operating Cost 

Savings, CO2 Reduction and 

NOx Reduction)†

7% plus CO2

range 2204 - 3082 1944 - 2822 2469 - 3348

7% 2435 2175 2700

3% 3278 2869 3684

3% plus CO2

range 3047 - 3925 2638 - 3516 3453 - 4331

Costs

Incremental Product Costs

7% 1841 1733 1950

3% 1849 1729 1969

Net Benefits/Costs

Total (Operating Cost 

Savings, CO2 Reduction and 

NOx Reduction, minus 

Incremental Product Costs)†

7% plus CO2

range 363 - 1241 211 - 1089 519 - 1397

7% 594 442 750

3% 1429 1140 1714

3% plus CO2

range 1198 - 2076 909 - 1787 1483 - 2362

* The Primary, Low, and High Estimates utilize forecasts of energy prices and housing starts from the AEO2010 

Reference case, Low Economic Growth case, and Low Economic Growth case, respectively.

** The CO2 values represent global monetized values (in 2007$) of the social cost of CO2 emissions in 2010 under 

several scenarios. The values of $4.70, $21.40, and $35.10 per ton are the averages of SCC distributions calculated 

using 5%, 3%, and 2.5% discount rates, respectively. The value of $64.90 per ton represents the 95th percentile of 

the SCC distribution calculated using a 3% discount rate. The value for NOX (in 2009$) is the average of the low 

and high values used in DOE’s analysis. NOx savings are in addition to the regulatory emissions reductions modeled 

in the Annual Energy Outlook forecast.
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† Total Benefits for both the 3% and 7% cases are derived using the SCC value calculated at a 3% discount rate, 

which is $21.40/ton in 2010 (in 2007$). In the rows labeled as “7% plus CO2 range” and “3% plus CO2 range,” the

operating cost and NOX benefits are calculated using the labeled discount rate, and those values are added to the full 

range of CO2 values with the $4.70/ton value at the low end, and the $64.90/ton value at the high end.

1.3 OVERVIEW OF STANDARDS FOR RESIDENTIAL REFRIGERATORS, 

REFRIGERATOR-FREEZERS, AND FREEZERS

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

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

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

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

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

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

residential refrigerators, refrigerator-freezers, and freezers—the products that are the focus of 

this document. The amendments to EPCA in the National Appliance Energy Conservation Act of 

1987 (NAECA), Pub. L. 100-12, established energy conservation standards for refrigerators, 

refrigerator-freezers, and freezers, as well as requirements for determining whether these 

standards should be amended. (42 U.S.C. 6295(b))

NAECA first established performance standards for residential refrigerators, refrigeratorfreezers, and freezers, and further required that DOE conduct two cycles of rulemakings to 

determine if more stringent standards are justified.b (42 U.S.C. 6295(b)) On November 17, 1989, 

DOE published a final rule in the Federal Register updating the performance standards; the new 

standards became effective on January 1, 1993. 54 FR 47916. Subsequent to this final rule, DOE

determined that new standards for some of the product classes were based on incomplete data 

and incorrect analysis. As a result, DOE published a correction that amended the new standards 

for three product classes: (1) refrigerators and refrigerator-freezers with manual defrost, (2) 

refrigerator-freezers—automatic defrost with bottom-mounted freezer but without through-thedoor (TTD) ice service, and (3) chest freezers and all other freezers. 55 FR 42845 (Oct. 24, 

1990). DOE updated the performance standards once again for refrigerators, refrigeratorfreezers, and freezers by publishing a final rule in the Federal Register on April 28, 1997. 62 FR 

23102. The new standards became effective on July 1, 2001. By completing a second standards 

rulemaking, DOE had fulfilled its legislative requirement to conduct two cycles of standards 

rulemakings.

Stakeholders submitted a petition in 2004 requesting that DOE conduct another 

rulemaking to amend the standards for residential refrigerator-freezers. In April 2005, DOE 

granted the petition and conducted a limited set of analyses to assess the potential energy savings 

 

a Part C has been redesignated Part A-1

b Definition of “refrigerators”, “refrigerator-freezers”, and “freezers” is provided in chapter 3 of the TSD.
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and economic benefit of new standards. DOE issued a report in October 2005 detailing the 

analyses.1 The analysis examined the technological and economic feasibility of new standards 

set at Energy Star levels effective in 2005 for the two most popular product classes of 

refrigerators: top-mount refrigerator-freezers without TTD features and side-mount refrigeratorfreezers with TTD features. DOE confined its updated analysis to these two classes because they 

accounted for a majority of current product shipments. Depending on assumptions about the 

impact that standards would have on market efficiency, DOE estimated that amended standards 

at the 2005 Energy Star levels would yield between 2.4 to 3.4 quads,

c with an associated 

economic impact to the Nation ranging from a burden or cost of $1.2 billion to a benefit or 

savings of $3.3 billion.d

DOE published draft data sheets containing energy-savings potentials for refrigeratorfreezers in October 2005 as part of its fiscal year 2006 schedule-setting process. These data 

sheets summarized the following in table format: (1) the potential energy savings from 

regulatory action in cumulative quads from 2010 to 2035, (2) the potential economic benefits or 

burdens, (3) the potential environmental or energy security benefits, (4) the status of required 

changes to test procedures, (5) other regulatory actions, (6) recommendations by interested 

parties, (7) evidence of market-driven or voluntary efficiency improvements, (8) regulatory 

issues, and (9) the 2005 priority. The data sheets for refrigerators and refrigerator-freezers were 

based on the October 2005 draft technical report analyzing potential new amended energy 

conservation standards for residential refrigerator-freezers described above. This report and the 

associated data sheets provided input to the setting of priorities for rulemakings activities. Other 

products were given a higher priority, and limited rulemaking work on refrigerators and freezers 

was carried out in the following years prior to the enactment of the Energy Independence and 

Security Act of 2007 (EISA).

EISA, signed into law on December 19, 2007, requires that DOE publish a final rule no 

later than December 31, 2010, to determine whether to amend the standards in effect for 

refrigerators, refrigerator-freezers, and freezers manufactured on or after January 1, 2014. As a 

result, DOE embarked on a standards rulemaking for these products to comply with the 

requirements of EISA.

1.4 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS

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

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

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

products; 

 

c A quad represents a quadrillion Btu (or 1015Btu). 

d Economic impact based on a discount rate of 7 percent real.
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2) the savings in operating costs throughout the estimated average life of the product 

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

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

of the standard; 

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

imposition of the standard; 

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

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

6) the need for national energy conservation; and 

7) other factors the Secretary considers relevant. 

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

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

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

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

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

comment period in each stage of the rulemaking. Beginning with the Framework Document and 

during subsequent comment periods, interactions among stakeholders provide a balanced 

discussion of the information that is required for the standards rulemaking.

Before DOE determines whether or not to adopt a proposed energy conservation 

standard, it must first solicit comments on the proposed standard. (42 U.S.C. 6313(a)(6)(B)(i))

Any new or amended standard must be designed to achieve significant additional conservation of 

energy and be technologically feasible and economically justified. (42 U.S.C. 6313(a)(6)(A)) To 

determine whether economic justification exists, DOE must review comments on the proposal 

and determine that the benefits of the proposed standard exceed its burdens to the greatest extent 

practicable, weighing the seven factors listed above. (42 U.S.C. 6295 (o)(2)(B)(i))

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

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

Federal Register. The first of the rulemaking notices is a NOPM, which is designed to publicly 

vet the models and tools used in the preliminary rulemaking and to facilitate public participation 

before the NOPR stage. The second notice is the NOPR, which presents a discussion of

comments received in response to the NOPM and the preliminary analyses and analytical tools; 

analyses of the impacts of potential amended energy conservation standards on consumers, 

manufacturers, and the Nation; DOE’s weighting of these impacts of amended energy 

conservation standards; and the proposed energy conservation standards for each product. The 

third notice is the final rule, which presents a discussion of the comments received in response to 

the NOPR; the revised analyses; DOE’s weighting of these impacts; the amended energy 
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conservation standards DOE is adopting for each product; and the effective dates of the amended 

energy conservation standards.

In September 2008, DOE published a notice of public meeting and availability of the 

framework document. 73 FR 54089 (September 18, 2008). The framework document, 

Rulemaking Framework for Residential Refrigerators, Refrigerator-Freezers, and Freezers, 

describes the procedural and analytical approaches DOE anticipated using to evaluate the 

establishment of amended energy conservation standards for these products. This document is 

available at: 

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

_framework.pdf.

Subsequently, DOE held a public meeting on September 29, 2008, to discuss procedural 

and analytical approaches to the rulemaking. In addition, DOE used the public meeting to inform 

and facilitate involvement of interested parties in the rulemaking process. The analytical 

framework presented at the public meeting described the different analyses, such as the 

engineering analysis and the consumer economic analyses (i.e., the life-cycle cost (LCC) and 

payback period (PBB) analyses), the methods proposed for conducting them, and the 

relationships among the various analyses.

During the September 2008 public meeting, interested parties commented about 

numerous issues relating to each one of the analyses listed in Table 1.4.1. Comments from 

interested parties submitted during the framework document comment period elaborated on the 

issues raised during the public meeting. DOE attempted to address these issues during its 

preliminary analyses and summarized the comments and DOE’s responses in chapter 2 of the 

preliminary TSD.

Table 1.4.1 Analyses Under the Process Rule

Preliminary Analyses NOPR Final Rule

Market and technology assessment Revised preliminary analyses Revised analyses

Screening analysis Consumer sub-group analysis

Engineering analysis Manufacturer impact analysis

Energy use analysis Utility impact analysis

Markups analysis Environmental assessment

Life-cycle cost and payback period 

analysis

Employment impact analysis

Shipments analysis Regulatory impact analysis

National impact analysis

Preliminary manufacturer impact analysis
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As part of the information gathering and sharing process, DOE organized and held 

interviews with manufacturers of the residential refrigerators, refrigerator-freezers, and freezers 

considered in this rulemaking as part of the engineering analysis. DOE selected companies that 

represented production of all types of products, ranging from small to large manufacturers, and 

included the Association of Home Appliance Manufacturers (AHAM) member companies. DOE 

had four objectives for these interviews: (1) solicit manufacturer feedback on the draft inputs to 

the engineering analysis; (2) solicit feedback on topics related to the preliminary manufacturer 

impact analysis; (3) provide an opportunity, early in the rulemaking process, to express 

manufacturers’ concerns to DOE; and (4) foster cooperation between manufacturers and DOE.

DOE incorporated the information gathered during the engineering interviews with 

manufacturers into its engineering analysis (Chapter 5) and the preliminary manufacturer impact 

analysis (Chapter 12). Following the publication of the preliminary analyses and the preliminary 

public meeting, DOE held additional meetings with manufacturers as part of the consultative 

process for the manufacturer impact analysis conducted during the NOPR phase of the 

rulemaking.

DOE developed spreadsheets for the engineering, LCC, PBP, and national impact 

analyses for each product. For each product, DOE developed an LCC spreadsheet that calculates 

the LCC and PBP at various energy efficiency levels. DOE also developed a national impact 

analysis spreadsheet that calculates the national energy savings (NES) and national net present 

values (NPVs) at various energy efficiency levels. This spreadsheet includes a model that 

forecasts the impacts of amended energy conservation standards at various levels on product 

shipments. All of these spreadsheets are available on the DOE website for refrigerators and 

freezers 

(http://www1.eere.energy.gov/buildings/appliance_standards/residential/refrigerators_freezers.ht

ml).

1.5 STRUCTURE OF THE DOCUMENT

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

consists of sixteen chapters and seventeen appendices.

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

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

document.

Chapter 2 Analytical Framework: describes the rulemaking process.

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

considered products and the technologies available for increasing 

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

efficiency of the considered products, and determines which technology 

options are viable for consideration in the engineering analysis.

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

relationship between increased manufacturer price and increased 

efficiency.

Chapter 6 Markups for Equipment Price Determination: discusses the methods 

used for establishing markups for converting manufacturer prices to 

customer equipment prices.

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

levels.

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

standards on individual customers and users of the equipment and 

compares the LCC and PBP of equipment with and without higher 

efficiency standards.

Chapter 9 Shipments Analysis: estimates shipments of the refrigeration products 

over the 30-year analysis period (2014-2043), which is used in 

performing the national impact analysis (NIA).

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

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

to result from specific, potential energy conservation standards for 

refrigeration products.

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

different subgroups of consumers.

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

finances and profitability of product manufacturers.

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

national employment.

Chapter 14 Utility Impact Analysis: discusses selected effects of standards on 

electric and gas utilities.

Chapter 15 Environmental Assessment: discusses the effects of standards on

emission of carbon dioxide, nitrogen oxides (NOx), and mercury.
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Chapter 16 Regulatory Impact Analysis: discusses the impact of non-regulatory 

alternatives to efficiency standards.

Appendix 4-A Investigation of VIP Supply

Appendix 5-A Engineering Data

Appendix 5-B ERA Model Development and WinERA User Manual

Appendix 7-A Literature Survey of Energy Consumption by Residential RefrigeratorFreezers

Appendix 7-B Data for Estimating Distribution of Refrigerator and Freezer Size in the 

RECS Sample

Appendix 8-A User Instructions for LCC and PBP Spreadsheets

Appendix 8-B Uncertainty and Variability

Appendix 8-C Consumer Retail Prices for Baseline Residential Refrigerator-Freezers 

and Freezers

Appendix 8-D Household Discount Rate Distributions 

Appendix 9-A Relative Price Elasticity of Demand for Appliances

Appendix 10-A User Instructions for Shipments and NIA Spreadsheets

Appendix 10-B National Equipment and Operating Costs

Appendix 12-A Manufacturer Impact Analysis Interview Guides 

Appendix 12-B Government Regulatory Impact Model Overview

Appendix 12-C Federal Production Tax Credits

Appendix 15-A Social Cost of Carbon

Appendix 16-A RIA Supporting Materials
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REFERENCES

 1 U.S. Department of Energy. Technical Report: Analysis of Amended Energy Conservation 

Standards for Residential Refrigerator-Freezers. October 2005. 

<http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/refrigerator_report_1.pdf >
i

CHAPTER 2. ANALYTICAL FRAMEWORK

TABLE OF CONTENTS

2.1 INTRODUCTION ........................................................................................................... 2-1

2.2 BACKGROUND ............................................................................................................. 2-4

2.3 MARKET AND TECHNOLOGY ASSESSMENT........................................................ 2-5

2.3.1 Product Classes.................................................................................................... 2-5

2.3.2 Technology Assessment....................................................................................... 2-6

2.4 SCREENING ANALYSIS .............................................................................................. 2-6

2.5 ENGINEERING ANALYSIS.......................................................................................... 2-7

2.6 MARKUPS TO DETERMINE PRODUCT PRICE........................................................ 2-8

2.7 ENERGY USE ANALYSIS............................................................................................ 2-8

2.8 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES .................................... 2-9

2.9 SHIPMENTS ANALYSIS ............................................................................................ 2-10

2.10 NATIONAL IMPACT ANALYSIS.............................................................................. 2-10

2.10.1 National Energy Savings Analysis..................................................................... 2-11

2.10.2 Net Present Value Analysis ............................................................................... 2-11

2.11 CONSUMER SUBGROUP ANALYSIS ...................................................................... 2-12

2.12 MANUFACTURER IMPACT ANALYSIS.................................................................. 2-12

2.13 EMPLOYMENT IMPACT ANALYSIS....................................................................... 2-13

2.14 UTILITY IMPACT ANALYSIS................................................................................... 2-13

2.15 ENVIRONMENTAL IMPACT ANALYSIS................................................................ 2-14

2.15.1 Carbon Dioxide.................................................................................................. 2-14

2.15.2 Sulfur Dioxide.................................................................................................... 2-14

2.15.3 Nitrogen Oxides................................................................................................. 2-15

2.15.4 Mercury.............................................................................................................. 2-15

2.15.5 Particulate Matter............................................................................................... 2-15

2.15.6 Monetization of Emissions Reductions ............................................................. 2-16

2.16 REGULATORY IMPACT ANALYSIS ....................................................................... 2-17

LIST OF FIGURES

Figure 2.1.1 Flow Diagram of Analyses for the Energy Conservation Standards 

Rulemaking Analysis Process........................................................................ 2-2
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CHAPTER 2. ANALYTICAL FRAMEWORK

2.1 INTRODUCTION

Section 6295(o)(2)(A) of 42 United States Code (U.S.C.) requires the U.S. Department of 

Energy (DOE) to set forth energy conservation standards that are technologically feasible and 

economically justified, and would achieve the maximum improvement in energy efficiency. This 

chapter provides a description of the general analytical framework that DOE uses in developing 

such standards. The analytical framework is a description of the methodology, the analytical 

tools, and relationships among the various analyses that are part of this rulemaking. For example, 

the methodology that addresses the statutory requirement for economic justification includes 

analyses of life-cycle cost (LCC), economic impact on manufacturers and users, national 

benefits, impacts, if any, on utility companies, and impacts, if any, from lessening competition 

among manufacturers.

Figure 2.1.1summarizes the stages and analytical components of the rulemaking process. 

The focus of this figure is the center column, which lists the analyses that DOE conducts. The 

figure shows how the analyses fit into the rulemaking process, and how they relate to each other. 

Key inputs are the types of data and information that the analyses require. Some key inputs exist 

in public databases; DOE collects other inputs from stakeholders or persons with special 

knowledge. Key outputs are analytical results that feed directly into the standards-setting 

process. Arrows connecting analyses show types of information that feed from one analysis to 

another.
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Figure 2.1.1 Flow Diagram of Analyses for the Energy Conservation Standards 

Rulemaking Analysis Process
2-3

The analyses performed prior to the notice of proposed rulemaking (NOPR) stage as part 

of the preliminary analyses and described in the preliminary technical support document (TSD) 

are listed below. These analyses were revised for the NOPR based in part on comments received, 

and are reported in this NOPR TSD. The analyses will be revised once again for the final rule 

based on any new comments or data received in response to the NOPR.

• A market and technology assessment to characterize the relevant product markets and 

existing technology options, including prototype designs.

• A screening analysis to review each technology option and determine if it is 

technologically feasible; is practical to manufacture, install, and service; would adversely 

affect product utility or product availability; or would have adverse impacts on health and 

safety.

• An engineering analysis to develop cost-efficiency relationships that show the 

manufacturer’s cost of achieving increased efficiency. 

• An energy use analysis to determine the annual energy use in the field of the considered 

products as a function of efficiency level.

• An LCC and payback period (PBP) analysis to calculate, at the consumer level, the 

relationship between savings in operating costs compared to any increase in the installed 

cost for products at higher efficiency levels.

• A shipments analysis to forecast product shipments, which then are used to calculate the 

national impacts of standards and future manufacturer cash flows.

• A national impact analysis (NIA) to assess the impacts at the national level of potential 

energy conservation standards for each of the considered products, as measured by the 

net present value (NPV) of total consumer economic impacts and the national energy 

savings (NES).

• A preliminary manufacturer impact analysis to assess the potential impacts of energy 

conservation standards on manufacturers, such as impacts on capital conversion 

expenditures, marketing costs, shipments, and research and development costs.

The additional analyses DOE performed for the NOPR stage of the rulemaking analysis include 

those listed below. DOE further revises the analyses for the final rule based on comments 

received in response to the NOPR.

• A consumer subgroup analysis to evaluate impacts of standards on particular consumer 

sub-populations, such as low-income households.
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• A manufacturer impact analysis to estimate the financial impact of standards on 

manufacturers and to calculate impacts on competition, employment, and manufacturing 

capacity.

• An employment impact analysis to assess the indirect impacts of amended energy 

conservation standards on national employment.

• A utility impact analysis to estimate the effects of amended energy conservation

standards on installed electricity generation capacity and electricity generation.

• An environmental impact analysis to provide estimates of the effects of amended energy 

conservation standards on emissions of carbon dioxide (CO2), nitrogen oxides (NOx), 

and mercury (Hg).

• A regulatory impact analysis to assess alternatives to amended energy conservation 

standards that could achieve substantially the same regulatory goal.

2.2 BACKGROUND

DOE developed this analytical framework and documented it in the Rulemaking 

Framework Document for Refrigerators, Refrigerator-Freezers, and Freezers (September 18, 

2008). DOE presented the analytical approach to interested parties during a public meeting held 

on September 29, 2008. The framework document is available at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/refrigerators_freezers.ht

ml. At the meeting and during the related comment period, DOE received many comments that 

helped it identify and resolve issues involved in this rulemaking.

DOE then gathered additional information and performed preliminary analyses to help 

develop the potential energy conservation standards for refrigeration products. This process 

culminated in DOE’s announcement of a preliminary analysis public meeting to discuss and 

receive comments on the following matters: The product classes DOE analyzed; the analytical 

framework, models, and tools that DOE was using to evaluate standards; the results of the 

preliminary analyses performed by DOE; and potential standard levels that DOE could consider. 

74 FR 58915 (November 16, 2009). DOE also invited written comments on these subjects and 

announced the availability on its website of a preliminary technical support document 

(preliminary TSD) it had prepared to inform interested parties and enable them to provide 

comments. Id. (The preliminary TSD is available at 

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

lim_tsd.pdf)

The preliminary analysis public meeting announced in the November 2009 notice took 

place on December 10, 2009. At this meeting, DOE presented the methodologies and results of 
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the analyses set forth in the preliminary TSD. DOE also discussed plans for conducting the 

NOPR analyses. The comments received since publication of the November 2009 notice, 

including those received at the preliminary analysis public meeting, have contributed to DOE’s 

proposed resolution of the issues in this rulemaking and the analysis conducted in support of the 

NOPR.

The following sections provide a general description of the different analytical 

components of the rulemaking analytical plan. DOE has used the most reliable data available at 

the time of each analysis in this rulemaking. DOE has also considered submissions of additional 

data from interested parties during the rulemaking process.

2.3 MARKET AND TECHNOLOGY ASSESSMENT

When initiating a standards rulemaking, DOE develops information on the present and 

past industry structure and market characteristics for the equipment concerned. This activity 

assesses the industry and equipment both quantitatively and qualitatively based on publicly 

available information and encompasses the following: (1) manufacturer market share and 

characteristics, (2) existing regulatory and non-regulatory equipment efficiency improvement 

initiatives, and (3) trends in product characteristics and retail markets. This information serves as 

resource material throughout the rulemaking.

DOE reviewed existing literature and interviewed manufacturers to get an overall picture 

of the residential refrigeration product industry serving the United States market. Industry 

publications and trade journals, government agencies, and trade organizations provided the bulk 

of the information, including: (1) manufacturers and their approximate market shares, (2) 

shipments by capacity and equipment class, (3) equipment information, and (4) industry trends. 

The appropriate sections of the NOPR describe the analysis and resulting information leading up 

to the proposed trial standard level while the supporting documentation is provided in the 

different chapters of the TSD.

The market and technology assessment also addresses applicable test procedures. DOE 

initiated a test procedure rulemaking for refrigeration products and published a test procedure 

NOPR on May 27, 2010. 75 FR 29824 The test procedure rulemaking is discussed briefly in 

Chapter 3 of the NOPR TSD.

2.3.1 Product Classes

DOE categorizes covered products into separate product classes and formulates a 

separate energy conservation standard for each product class. The criteria for separation into 

different classes are type of energy used, capacity, and other performance-related features such 

as those that provide utility to the consumer or others deemed appropriate by the Secretary that 
2-6

would justify the establishment of a separate energy conservation standard. (42 U.S.C. 6295(q) 

and 6316(a))

DOE is proposing several new product classes for refrigeration products as part of this 

rulemaking. The new product classes include product classes made effective through the Office 

of Hearing and Appeal’s exception relief process, and based on performance and utility 

differences associated with all-refrigerators, products with automatic icemakers, and built-in 

products. This is described briefly in Chapter 3 of the NOPR TSD, and in greater detail in the 

NOPR.

2.3.2 Technology Assessment

As part of the market and technology assessment, DOE developed a list of technologies 

for consideration for improving the efficiency of residential refrigeration products. DOE 

typically uses information about existing and past technology options and prototype designs to 

determine which technologies manufacturers use to attain higher performance levels. In 

consultation with interested parties, DOE develops a list of technologies for consideration. 

Initially, these technologies encompass all those DOE believes are technologically feasible.

DOE developed its list of technologically feasible design options for refrigeration 

products from trade publications, technical papers, the TSD for the previous refrigeration product 

rulemaking, and through consultation with manufacturers of components and systems. Since 

many options for improving product efficiency are available in existing products, product 

literature and direct examination provided additional information. Chapter 3 of the NOPR TSD 

includes the detailed list of all technology options identified.

2.4 SCREENING ANALYSIS

After DOE identified the technologies in the technology assessment that could potentially 

improve the energy efficiency of residential refrigeration products, DOE conducted the screening 

analysis. The purpose of the screening analysis is to evaluate the technologies to determine 

which options to consider further and which options to screen out. DOE consults with industry, 

technical experts, and other interested parties in developing a list of technologies for 

consideration. DOE then applies the screening criteria to determine which technologies are 

unsuitable for further consideration in this rulemaking. Chapter 4 of the NOPR TSD, the 

screening analysis, contains details on the criteria that DOE uses.

The screening analysis examines whether various technologies (1) are technologically 

feasible; (2) are practicable to manufacture, install, and service; (3) have an adverse impact on 

product utility or availability; and (4) have adverse impacts on health and safety. In consultation 
2-7

with interested parties, DOE reviews the list to determine if the technologies described in chapter 

3 of the NOPR TSD are practicable to manufacture, install, and service; would adversely affect 

product utility or availability; or would have adverse impacts on health and safety. In the

engineering analysis, DOE further considers the efficiency enhancement options (i.e., 

technologies) that it did not screen out in the screening analysis.

2.5 ENGINEERING ANALYSIS

The engineering analysis (chapter 5) establishes the relationship between the 

manufacturing production cost and the efficiency for each residential refrigeration product. This 

relationship serves as the basis for cost/benefit calculations in terms of individual consumers, 

manufacturers, and the Nation. Chapter 5 discusses product classes DOE analyzed, the 

representative baseline units, the efficiency levels analyzed, the methodology DOE used to 

develop the manufacturing production costs, and the cost-efficiency curves.

In the engineering analysis, DOE evaluates a range of product efficiency levels and their 

associated manufacturing costs. The purpose of the analysis is to estimate the incremental 

manufacturer selling prices (MSPs) for a product that would result from increasing efficiency 

levels above the level of the baseline model in each product class. The engineering analysis 

considers technologies not eliminated in the screening analysis. The LCC analysis uses the costefficiency relationships developed in the engineering analysis.

The proposed changes to the test procedure will result in changes in the measured energy 

use of most refrigeration products, and also in the adjusted volume of these products. The 

adjusted volume measurement directly impacts the energy conservation standards, since the 

standards are expressed in terms of this parameter. Chapter 5 of the NOPR TSD describes 

conversion of the energy standard equations for baseline-efficiency products from representation 

based on the current test procedure to the proposed new test procedure. The chapter also presents 

calculations showing the adjustment of the energy use equation slope for three product classes.

DOE typically structures its engineering analysis around one of three methodologies: (1) 

the design-option approach, which calculates the incremental costs of adding specific design 

options to a baseline model; (2) the efficiency-level approach, which calculates the relative costs 

of achieving increases in energy efficiency levels without regard to the particular design options 

used to achieve such increases; and/or (3) the reverse-engineering or cost-assessment approach, 

which involves a “bottom-up” manufacturing cost assessment based on a detailed bill of 

materials derived from teardowns of the product being analyzed.

For the NOPR analysis, DOE used a combination of all three of these approaches. DOE 

developed a manufacturing cost model for refrigeration products based on reverse engineering of 

purchased products. DOE determined the potential for efficiency improvement of design options 

and groups of design options using energy modeling. DOE estimated costs for these efficiency 
2-8

improvements based on the manufacturing cost model, information from component vendors, 

and information obtained through discussions with manufacturers. However, DOE based the 

cost-efficiency curves developed for the downstream analyses on specific efficiency levels 

representing percent energy use reductions in 5 percent increments. Chapter 5 of the NOPR TSD 

describes the methodology that DOE used to perform the efficiency level analysis and derive the 

cost-efficiency relationship.

2.6 MARKUPS TO DETERMINE PRODUCT PRICE

DOE used markups to convert the manufacturer selling prices estimated in the 

engineering analysis to customer prices, which then were used in the life-cycle cost (LCC) and 

payback period (PBP) and manufacturer impact analyses. DOE calculates separate markups for 

baseline products (baseline markups) and for more efficient products (incremental markups). The 

incremental markup relates the change in the manufacturer sales price of higher-efficiency 

models (the incremental cost increase) to the change in the retailer or distributor sales price. 

To develop markups, DOE identifies how the products are distributed from the 

manufacturer to the customer. After establishing appropriate distribution channels, DOE relied 

on economic data from the U.S. Census Bureau and other sources to define how prices are 

marked up as the products pass from the manufacturer to the customer. See Chapter 6 for details 

on the development of markups.

2.7 ENERGY USE ANALYSIS 

The energy use analysis, which assesses the energy savings potential from higher 

efficiency levels, provides the basis for the energy savings values used in the LCC and 

subsequent analyses. The goal of the energy use analysis is to generate a range of energy use 

values that reflects actual product use in American homes. The analysis uses information on use 

of actual products in the field to estimate the energy that would be used by new products at 

various efficiency levels.

Studies show that measurements of field energy use often vary considerably from the 

rated usage as determined by the DOE test procedure. To determine the field energy use by 

products that would meet possible energy efficiency standards, DOE developed “usage 

adjustment factors’ (UAFs) that relate estimated field energy consumption for each sample 

household to the estimated test energy use. DOE developed such UAFs for standard-size units.

In its preliminary analysis, DOE treated the field energy consumption reported for 

households in the Energy Information Administration’s 2005 Residential Energy Consumption 

Survey (RECS) as the actual consumption of the refrigeration product(s) in that household.

RECS is a national sample survey of housing units that collects statistical information on the 

consumption of and expenditures for energy in housing units along with data on energy-related 
2-9

characteristics of the housing units and occupants. DOE used RECS to estimate the field energy 

usage of standard-sized refrigerator-freezers and freezers on a representative sample of housing 

units using these products. 

For the NOPR, DOE developed a new approach to derive UAFs for the RECS sample 

households. This approach involved collection of field metered electricity use data for residential 

refrigeration products. DOE was able to obtain data from seven studies, including about 100 data 

points that DOE collected itself. From identifying information about each unit, its test energy 

consumption was estimated and the UAF was calculated as the ratio of metered energy use to test 

energy use. For each product category, DOE performed regressions on numerous variables of 

potential interest in order to construct a function that predicts the UAF based on household and 

climate variables. Within each of the product categories modeled, DOE used the appropriate set 

of regression coefficients, along with values for the relevant variables specific to each household,

to generate UAF estimates for each RECS household. For compact refrigeration products, a UAF 

of 1 was used.

Chapter 7 of this TSD provides more detail about DOE’s approach for characterizing 

energy use of refrigeration products.

2.8 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES

New or amended energy conservation standards affect products’ operating expenses—

usually decreasing them—and consumer prices for the products—usually increasing them. DOE 

analyzed the net effect of amended standards on consumers by evaluating the net LCC. To 

evaluate the net LCC, DOE used the cost-efficiency relationship derived in the engineering 

analysis, along with the energy costs derived from the energy use characterization. Inputs to the 

LCC calculation include the installed cost of a product to the consumer (consumer purchase price 

plus installation cost), operating expenses (energy expenses and maintenance costs), the lifetime 

of the unit, and a discount rate.

Because the installed cost of a product typically increases while operating cost typically 

decreases in response to new standards, there is a time in the life of products having higher-thanbaseline efficiency when the net operating-cost benefit (in dollars) since the time of purchase is 

equal to the incremental first cost of purchasing the higher-efficiency product. The length of time 

required for products to reach this cost-equivalence point is known as the payback period (PBP).

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

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

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

distributions. DOE developed LCC and PBP spreadsheet models incorporating both Monte Carlo 

simulation and probability distributions by using Microsoft Excel spreadsheets combined with 

Crystal Ball (a commercially available add-in program).
2-10

Using information in RECS, DOE developed samples of individual households that use 

the considered standard-size refrigeration products. By developing household samples, DOE was 

able to perform the LCC and PBP calculations for each household to account for the variability 

in energy consumption and electricity price associated with each household. As noted above, 

DOE did not develop a household sample for compact refrigerators and freezers since a large 

number of such products are used in lodging, dormitories and other commercial establishments. 

DOE identified several other input values for estimating the LCC, including: retail prices; 

discount rates; and product lifetimes. DOE characterized these values with probability 

distributions. 

DOE developed discount rates separately for residential consumers and commercial 

consumers. Because some compact refrigerators and freezers are used in commercial 

applications, DOE developed commercial discount rates and for those commercial consumers

that purchase compact refrigerators and freezers. DOE developed discount rates from estimates 

of the interest rate, or finance cost, applied to purchases of residential and commercial products. 

Following accepted principles of financial theory, the finance cost of raising funds to purchase 

such products can be interpreted as: (1) the financial cost of any debt incurred to purchase 

products, principally interest charges on debt; or (2) the opportunity cost of any equity used to 

purchase products, principally interest earnings on household equity. 

2.9 SHIPMENTS ANALYSIS

Forecasts of product shipments are needed to calculate the national impacts of standards 

on energy use, NPV, and future manufacturer cash flows. DOE developed shipment forecasts 

based on an analysis of key market drivers for each considered product. In DOE’s shipments 

model, shipments of products are driven by new construction as well as stock replacements.

The shipments models take an accounting approach, tracking market shares of each 

product class and the vintage of units in the existing stock. Stock accounting uses product 

shipments as inputs to estimate the age distribution of in-service product stocks for all years. The 

age distribution of in-service product stocks is a key input to calculations of both the NES and 

NPV, because operating costs for any year depend on the age distribution of the stock. 

Chapter 9 of the TSD provides additional details on the shipments analysis.

2.10 NATIONAL IMPACT ANALYSIS

The national impact analysis assesses the aggregate impacts at the national level of 

potential energy conservation standards for each of the considered products, as measured by the 

net present value (NPV) of total consumer economic impacts and the national energy savings 

(NES). DOE determined both the NPV and NES for the efficiency levels considered for the 
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product classes analyzed. To make the analysis more accessible and transparent to all interested 

parties, DOE prepared a Microsoft Excel spreadsheet model to forecast NES and the national 

consumer economic costs and savings resulting from new standards. The spreadsheet model uses 

as inputs typical values (as opposed to probability distributions). To assess the effect of input 

uncertainty on NES and NPV results, DOE conducted sensitivity analyses by running scenarios 

on specific input variables, which are described in chapter 10. 

Several of the inputs for determining NES and NPV depend on the product efficiency. 

DOE developed efficiency trends for the base case and standards cases. These trends specify the 

average annual historical and forecasted shipments-weighted product efficiencies. In developing 

the energy efficiencies forecasted over time for each of the standards cases, DOE used a “roll-up 

+ ENERGY STAR” scenario to establish the distribution of efficiencies for the year that revised 

standards are assumed to become effective (i.e., 2014) and subsequent years. In this scenario, 

product efficiencies in the base case that did not meet the standard level under consideration 

would roll-up to meet the new standard level in 2014. DOE assumed that new criteria would be 

established for ENERGY STAR refrigeration products, and that such products would gradually 

gain a larger market share. The details of the approach are described in Chapter 10.

2.10.1 National Energy Savings Analysis

The inputs for determining the national energy savings (NES) for each product analyzed 

are: (1) annual energy consumption per unit; (2) shipments; (3) product stock; (4) national 

energy consumption; and (5) site-to-source conversion factors. DOE calculated the national 

energy consumption by multiplying the number of units, or stock, of each product (by vintage, or 

age) by the unit energy consumption (also by vintage). DOE calculated annual NES based on the 

difference in national energy consumption for the base case (without new efficiency standards) 

and for each considered efficiency level. DOE estimated energy consumption and savings based 

on site energy, and converted the electricity consumption and savings to source (primary) 

energy. Cumulative energy savings are the sum of the NES for each year.

2.10.2 Net Present Value Analysis

The inputs for determining net present value (NPV) of consumer benefits are: (1) total 

annual installed cost; (2) total annual savings in operating costs; (3) a discount factor; (4) present 

value of costs; and (5) present value of savings. DOE calculated net savings each year as the 

difference between the base case and each standards case in total savings in operating costs and 

total increases in installed costs. DOE calculated savings over the life of each product, 

accounting for differences in yearly energy rates. DOE calculated NPV as the difference between 

the present value of operating cost savings and the present value of total installed costs. DOE 

used a discount factor based on real discount rates of 3% and 7% to discount future costs and 

savings to present values.

DOE calculated increases in total installed costs as the difference in total installed cost 

between the base case and standards case (i.e., once the standards take effect). Because the more 
2-12

efficient products bought in the standards case usually cost more than products bought in the 

base case, cost increases appear as negative values in the NPV.

DOE expressed savings in operating costs as decreases associated with the lower energy 

consumption of products bought in the standards case compared to the base efficiency case. 

Total savings in operating costs are the product of savings per unit and the number of units of 

each vintage that survive in a given year.

Chapter 10 of this TSD provides additional details regarding the national impacts 

analysis.

2.11 CONSUMER SUBGROUP ANALYSIS

The consumer subgroup analysis evaluates economic impacts on selected groups of 

consumers who might be adversely affected by a change in the national energy conservation 

standards for the considered products. DOE evaluates impacts on particular subgroups of 

consumers primarily by analyzing the LCC impacts and PBP for those particular consumers

using the LCC spreadsheet model.

For the NOPR, DOE evaluated impacts of standards on low-income and fixed-income 

(i.e., senior) consumers.

2.12 MANUFACTURER IMPACT ANALYSIS 

DOE performed a manufacturer impact analysis (MIA) to estimate the financial impact of 

amended energy conservation standards on manufacturers of residential refrigeration products, 

and to calculate the impact of such standards on employment and manufacturing capacity. The 

MIA has both quantitative and qualitative aspects. The quantitative part of the MIA relies on the 

government regulatory impact model (GRIM), an industry-cash-flow model customized for this 

rulemaking. The GRIM inputs are information regarding the industry cost structure, shipments, 

and revenues. This includes information from many of the analyses described above, such as 

manufacturing costs and prices from the engineering analysis and shipments forecasts. The key 

GRIM output is the industry net present value (INPV). Different sets of assumptions (scenarios) 

will produce different results. The qualitative part of the MIA addresses factors such as product 

characteristics, characteristics of particular firms, and market and product trends, and includes 

assessment of the impacts of standards on subgroups of manufacturers. The complete MIA is 

described in chapter 12 of the NOPR TSD.

DOE conducted each MIA in this rulemaking in three phases. In Phase I, DOE created an 

industry profile to characterize the industry and identify important issues that require 

consideration. In Phase II, DOE prepared an industry cash-flow model and an interview 

questionnaire to guide subsequent discussions. In Phase III, DOE interviewed manufacturers, and 

assessed the impacts of standards both quantitatively and qualitatively. DOE assessed industry 
2-13

and subgroup cash flow and NPV using the GRIM. DOE then assessed impacts on competition, 

manufacturing capacity, employment, and regulatory burden based on manufacturer interview 

feedback and discussions.

2.13 EMPLOYMENT IMPACT ANALYSIS

The imposition of standards can affect employment both directly and indirectly. Direct 

employment impacts are changes, produced by new standards, in the number of employees at 

plants that produce the covered products. DOE evaluated direct employment impacts in the 

manufacturer impact analysis. Indirect employment impacts that occur because of the imposition 

of standards may result from consumers shifting expenditures between goods (the substitution 

effect) and from changes in income and overall expenditure levels (the income effect). DOE 

utilizes Pacific Northwest National Laboratory’s ImSET model to investigate the combined 

direct and indirect employment impacts. The ImSET model, which was developed for DOE’s 

Office of Planning, Budget, and Analysis, estimates the employment and income effects energysaving technologies produced in buildings, industry, and transportation. In comparison with 

simple economic multiplier approaches, ImSET allows for more complete and automated 

analysis of the economic impacts of energy conservation investments.

2.14 UTILITY IMPACT ANALYSIS

The utility impact analysis estimates the effects of amended energy conservation

standards on installed electricity generation capacity and electricity generation. For this analysis, 

DOE adapted NEMS, which is a large multi-sectoral, partial-equilibrium model of the U.S. 

energy sector that the EIA has developed throughout the past decade, primarily for preparing 

EIA’s AEO. In previous rulemakings, a variant of NEMS (currently termed NEMS-BT, BT 

referring to DOE’s Building Technologies Program), was developed to better address the 

specific impacts of an energy conservation standard. NEMS, which is available in the public 

domain, produces a widely recognized baseline energy forecast for the United States through the 

year 2030. The typical NEMS outputs include forecasts of electricity sales, prices, and electric 

generating capacity. DOE conducts the utility impact analysis as a scenario that departs from the 

latest AEO reference case. In other words, the energy savings impacts from amended energy 

conservation standards are modeled using NEMS-BT to generate forecasts that deviate from the 

AEO reference case.

As part of the utility impact analysis, DOE analyzed the potential impact on electricity 

prices resulting from amended standards on refrigeration products and the associated benefits for 

all electricity users in all sectors of the economy.
2-14

2.15 ENVIRONMENTAL IMPACT ANALYSIS

The intent of the environmental assessment is to quantify and consider the environmental 

effects of amended energy conservation standards for the products covered in this rulemaking. 

The primary environmental effects of these standards would be reduced power plant emissions 

resulting from reduced consumption of electricity. DOE will assess these environmental effects 

by using NEMS-BT to provide key inputs to its analysis. The portion of the environmental 

assessment that will be produced by NEMS-BT considers carbon dioxide (CO2), nitrogen oxides 

(NOX), and mercury (Hg). The environmental assessment also considers impacts on SO2

emissions. 

2.15.1 Carbon Dioxide

In the absence of any Federal emissions control regulation of power plant emissions of 

CO2, a DOE standard is likely to result in reductions of these emissions. The CO2 emission 

reductions likely to result from a standard will be estimated using NEMS-BT and national energy 

savings estimates drawn from the NIA spreadsheet model. The net benefit of the standard is the 

difference between emissions estimated by NEMS-BT at each standard level considered and the 

AEO Reference Case. NEMS-BT tracks CO2 emissions using a detailed module that provides 

results with broad coverage of all sectors and inclusion of interactive effects.

2.15.2 Sulfur Dioxide

DOE has preliminarily determined that SO2 emissions from affected Electric Generating 

Units (EGUs) are subject to nationwide and regional emissions cap and trading programs that are 

likely to eliminate the standards’ impact on SO2 emissions. The costs of meeting such emission

cap requirements are reflected in the electricity prices and forecasts used in DOE’s analysis of 

the standards. Title IV of the Clean Air Act sets an annual emissions cap on SO2 for all affected 

EGUs. SO2 emissions from 28 eastern States and the District of Columbia (DC) are also limited 

under the Clean Air Interstate Rule (CAIR, published in the Federal Register on May 12, 2005. 

70 FR 25162 (May 12, 2005)), which creates an allowance-based trading program that will 

gradually replace the Title IV program in those States and DC. (The recent legal history 

surrounding CAIR is discussed below.) The attainment of the emissions caps is flexible among 

EGUs and is enforced through the use of emissions allowances and tradable permits. Under 

existing EPA regulations, any excess SO2 emission allowances resulting from the lower 

electricity demand caused by the imposition of an efficiency standard could be used to permit 

offsetting increases in SO2 emissions by any regulated EGU. However, if the standard resulted in 

a permanent increase in the quantity of unused emission allowances, there would be an overall 

reduction in SO2 emissions from the standards. While there remains some uncertainty about the 

ultimate effects of efficiency standards on SO2 emissions covered by the existing cap and trade 

system, the NEMS-BT modeling system that DOE plans to use to forecast emissions reductions 

currently indicates that no physical reductions in power sector emissions would occur for SO2. 
2-15

2.15.3 Nitrogen Oxides

NEMS-BT also has an algorithm for estimating NOX emissions from power generation. 

The impact of these emissions, however, will be affected by the CAIR, which the Environmental 

Protection Agency (EPA) issued on May 12, 2005. CAIR will permanently cap emissions of 

NOX in 28 eastern states and the District of Columbia. 70 FR 25162 (May 12, 2005).

Much like SO2 emissions, a cap on NOX emissions means that amended energy 

conservation standards may have little or no physical effect on these emissions in the 28 eastern 

States and the DC covered by CAIR. Although CAIR has been remanded to the EPA by the DC 

Circuit, it will remain in effect until it is replaced by a rule consistent with the Court’s July 11, 

2008, opinion in North Carolina v. EPA. 531 F.3d 896 (DC Cir. 2008); see also North Carolina 

v. EPA, 550 F.3d 1176 (DC Cir. 2008). Because all States covered by CAIR opted to reduce 

NOX emissions through participation in cap-and-trade programs for electric generating units, 

emissions from these sources are capped across the CAIR region.

DOE uses NEMS-BT to estimate the emissions reductions from possible standards in the 

22 States where emissions are not capped.

2.15.4 Mercury

Similar to emissions of SO2 and NOX, future emissions of Hg would have been subject to 

emissions caps. In May 2005, EPA issued the Clean Air Mercury Rule (CAMR). 70 FR 28606 

(May 18, 2005). CAMR would have permanently capped emissions of mercury for new and 

existing coal-fired power plants in all States by 2010. However, on February 8, 2008, the DC 

Circuit issued its decision in New Jersey v. Environmental Protection Agency, in which the DC 

Circuit, among other actions, vacated the CAMR. 517 F.3d 574 (DC Cir. 2008). EPA has 

decided to develop emissions standards for power plants under the Clean Air Act (Section 112), 

consistent with the DC Circuit’s opinion on the CAMR. See 

http://www.epa.gov/air/mercuryrule/pdfs/certpetition_withdrawal.pdf. Pending EPA's 

forthcoming revisions to the rule, DOE is excluding the CAMR from its Environmental 

Analysis. In the absence of CAMR, a DOE standard would likely reduce Hg emissions and DOE 

plans to use NEMS-BT to estimate these emission reductions. However, DOE continues to 

review the impact of rules that reduce energy consumption on Hg emissions, and may revise its 

assessment of Hg emission reductions in future rulemakings.

2.15.5 Particulate Matter

DOE acknowledges that particulate matter (PM) impacts are of concern due to human 

exposures that can impact health. However, impacts of PM emissions reduction are much more 

difficult to estimate than other emissions reductions due to the complex interactions between 

PM, other power plant emissions, meteorology, and atmospheric chemistry that impact human 

exposure to particulates. Human exposure to PM usually occurs at a significant distance from the 

power plants that are emitting particulates and particulate precursors. When power plant 

emissions travel this distance, they undergo highly complex atmospheric chemical reactions. 
2-16

Although the EPA does keep inventories of direct PM emissions of power plants, in its source 

attribution reviews, the EPA does not separate direct PM emissions from power plants from the 

sulfate particulates indirectly produced through complex atmospheric chemical reactions. The 

great majority of PM emissions from power plants are of these secondary particles (secondary 

sulfates). Thus, it is not useful to examine how the amended standard impacts direct PM 

emissions independent of indirect PM production and atmospheric dynamics. Therefore, DOE is 

not planning to assess the impact of these standards on particulate emissions. Further, even the 

cumulative impact of PM emissions from power plants and indirect emissions of pollutants from 

other sources is unlikely to be significant.

2.15.6 Monetization of Emissions Reductions 

For those emissions for which real national emission reductions are anticipated (CO2, Hg, 

and NOX for 22 states), only ranges of estimated economic values based on environmental 

damage studies of varying quality and applicability are available. Therefore, DOE intends to

report estimates of monetary benefits derived using these values and consider these benefits in 

weighing the costs and benefits of each of the standard levels considered. 

In order to estimate the monetary value of benefits resulting from reduced emissions of 

CO2 emissions, it is DOE’s intent to use in its analysis the most current Social Cost of Carbon 

(SCC) values developed and/or agreed to by interagency reviews. The SCC is intended to be a 

monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions, 

including, but not limited to, net agricultural productivity loss, human health effects, property 

damage from sea level rise, and changes in ecosystem services. Any effort to quantify and to 

monetize the harms associated with climate change will raise serious questions of science, 

economics, and ethics. But with full regard for the limits of both quantification and monetization, 

the SCC can be used to provide estimates of the social benefits of reductions in GHG emissions. 

At the time of this notice, the most recent interagency estimates of the potential global 

benefits resulting from reduced CO2 emissions in 2010 were $4.7, $21.4, $35.1, and $64.9 per 

metric ton in 2007 dollars. These values are then adjusted to 2009$ using the appropriate 

standard GDP deflator values. For emissions reductions that occur in later years, these values 

grow in real terms over time. Additionally, the interagency group determined that a range of 

values from 7 percent to 23 percent should be used to adjust the global SCC to calculate 

domestic effects, although DOE will give preference to consideration of the global benefits of 

reducing CO2 emissions. See appendix 15A of this TSD for the full range of annual SCC 

estimates from 2010 to 2050. To calculate a present value of the stream of monetary values, 

DOE discounted the values in each of the four cases using the discount rates that had been used 

to obtain the SCC values in each case.

DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to 

the contribution of CO2 and other GHG to changes in the future global climate and the potential 

resulting damages to the world economy. Thus, these values are subject to change. 
2-17

DOE also estimates the potential monetary benefit of reduced NOX emissions resulting 

from the standard levels it considers. For NOX emissions, available estimates suggest a very wide 

range of monetary values for NOX emissions, ranging from $370 per ton to $3,800 per ton of 

NOX from stationary sources, measured in 2001$ (equivalent to a range of $447 to $4,591 per 

ton in 2009$). Refer to the OMB, Office of Information and Regulatory Affairs, “2006 Report to 

Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on State, 

Local, and Tribal Entities,” for additional information. In accordance with U.S. Office of 

Management and Budget (OMB) guidance, DOE will conduct two calculations of the monetary 

benefits derived using each of the economic values used for NOX, one using a real discount rate 

of 3 percent and another using a real discount rate of 7 percent.a 

DOE does not plan to monetize estimates of Hg in this rulemaking. DOE is aware of 

multiple agency efforts to determine the appropriate range of values used in evaluating the 

potential economic benefits of reduced Hg emissions. DOE has decided to await further guidance 

regarding consistent valuation and reporting of Hg emissions before it once again monetizes Hg 

in its rulemakings.

2.16 REGULATORY IMPACT ANALYSIS

In the NOPR stage, DOE prepared a regulatory impact analysis (RIA) pursuant to 

Executive Order 12866, Regulatory Planning and Review, 58 FR 51735, October 4, 1993, which 

is subject to review by the Office of Information and Regulatory Affairs at the Office of 

Management and Budget. The RIA addresses the potential for non-regulatory approaches to 

supplant or augment energy conservation standards in order to improve the energy efficiency or 

reduce the energy consumption of the products covered under this rulemaking.

DOE recognizes that voluntary or other non-regulatory efforts by manufacturers, utilities, 

and other interested parties can substantially affect energy efficiency or reduce energy 

consumption. DOE bases its assessment on the actual impacts of any such initiatives to date, but 

also considers information presented by interested parties regarding the impacts existing 

initiatives might have in the future.

 a

 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).
3-i

CHAPTER 3: MARKET AND TECHNOLOGY ASSESSMENT

TABLE OF CONTENTS

3.1 INTRODUCTION ........................................................................................................... 3-1

3.1.1 Product Definitions.......................................................................................................... 3-1

3.1.1.1 Refrigerators, Refrigerator-Freezers, and Freezers........................................ 3-1

3.1.1.2 Wine Coolers ................................................................................................. 3-2

3.2 MARKET ASSESSMENT.............................................................................................. 3-2

3.2.1 Product Classes................................................................................................................ 3-2

3.2.1.1 Product Classes Listed in the CFR................................................................. 3-2

3.2.1.2 Product Classes Modifications....................................................................... 3-2

3.2.2 Product Test Procedures .................................................................................................. 3-5

3.2.3 Manufacturer Information................................................................................................ 3-6

3.2.3.1 Refrigerator, Refrigerator-Freezer, and Freezer Manufacturers.................... 3-6

3.2.3.2 Refrigerator, Refrigerator-Freezer, and Freezer Manufacturer Market 

Shares ............................................................................................................ 3-9

3.2.3.3 Mergers and Acquisitions............................................................................ 3-11

3.2.3.4 Distribution Channels.................................................................................. 3-12

3.2.3.5 Manufacturer Trade Groups......................................................................... 3-13

3.2.3.6 Compressor Manufacturers and Market Shares........................................... 3-13

3.2.4 Regulatory Programs ..................................................................................................... 3-13

3.2.4.1 Federal Energy Conservation Standards...................................................... 3-14

3.2.4.2 State Energy Conservation Standards.......................................................... 3-16

3.2.4.3 Canadian Energy Conservation Standards................................................... 3-16

3.2.4.4 Mexican Energy Conservation Standards.................................................... 3-17

3.2.4.5 Efficiency Standards Outside North America.............................................. 3-17

3.2.5 Voluntary and other Federal and State Programs.......................................................... 3-18

3.2.5.1 ENERGY STAR.......................................................................................... 3-18

3.2.5.2 Federal Energy Management Program ........................................................ 3-20

3.2.5.3 Consortium for Energy Efficiency............................................................... 3-21

3.2.5.4 ENERGY STAR, FEMP, CEE Summary.................................................... 3-22

3.2.5.5 Manufacturer Tax Credits for Energy-Efficient Appliances ....................... 3-22

3.2.5.6 Rebates for Highly Energy-Efficient Products............................................ 3-23

3.2.5.7 State Tax Incentives for Highly Energy-Efficient Products........................ 3-24

3.2.6 Historical Shipments and Efficiencies........................................................................... 3-24

3.2.6.1 Historical Shipments.................................................................................... 3-24

3.2.6.2 Historical Efficiencies.................................................................................. 3-26

3.2.6.3 Imports and Exports..................................................................................... 3-28

3.2.7 Saturation in U.S. Homes............................................................................................... 3-28

3.2.8 Product Retail Prices...................................................................................................... 3-32

3.2.8.1 Historical Retail Prices ................................................................................ 3-32

3.2.8.2 Refrigerator-Freezer 2004 Retail Prices ...................................................... 3-32

3.2.8.3 2007 Manufacturer-Suggested Retail Prices................................................ 3-34

3.2.8.4 Refrigerator-Freezer and Freezer 2008 Retail Prices................................... 3-39
3-ii

3.3 TECHNOLOGY ASSESSMENT.................................................................................. 3-40

3.3.1 Product Operation and Components.............................................................................. 3-40

3.3.1.1 Product Operation ........................................................................................ 3-40

3.3.1.2 Primary Components ................................................................................... 3-41

3.3.2 Technology Options....................................................................................................... 3-45

3.3.2.1 Insulation...................................................................................................... 3-46

3.3.2.2 Gasket and Door Design .............................................................................. 3-50

3.3.2.3 Anti-Sweat Heater........................................................................................ 3-52

3.3.2.4 Compressor .................................................................................................. 3-53

3.3.2.5 Evaporator.................................................................................................... 3-57

3.3.2.6 Condenser .................................................................................................... 3-58

3.3.2.7 Fan and Fan Motor....................................................................................... 3-60

3.3.2.8 Expansion Valve .......................................................................................... 3-60

3.3.2.9 Cycling Losses............................................................................................. 3-61

3.3.2.10 Defrost System............................................................................................. 3-61

3.3.2.11 Control System............................................................................................. 3-62

3.3.2.12 Other Technologies...................................................................................... 3-63

3.3.2.13 Alternative Refrigeration Cycles ................................................................. 3-64

3.3.2.14 Alternative Refrigeration Systems............................................................... 3-67

3.3.3 Energy Efficiency .......................................................................................................... 3-67

REFERENCES .......................................................................................................................... 3-79

LIST OF TABLES

Table 3.2.1 Product Classes for Refrigerators, Refrigerator-Freezers, and Freezers .................. 3-3

Table 3.2.2 Refrigerator, Refrigerator-Freezer, and Freezer Manufacturers............................... 3-7

Table 3.2.3 Standard-Size Refrigerator-Freezer Manufacturer Market Shares........................... 3-9

Table 3.2.4 Compact Refrigerator Manufacturer Market Shares .............................................. 3-10

Table 3.2.5 Built-In Undercounter Refrigerator Manufacturer Market Shares......................... 3-10

Table 3.2.6 Chest/Upright Freezer Manufacturer Market Shares.............................................. 3-11

Table 3.2.7 Major Appliance Sales by Channel ........................................................................ 3-12

Table 3.2.8 Compressor Manufacturers and World and U.S. Market Shares............................ 3-13

Table 3.2.9 Federal Energy Efficiency Standards for Refrigerators, Refrigerator-Freezers, 

and Freezers....................................................................................................... 3-15

Table 3.2.10 California Standards for Wine Chillers ................................................................ 3-16

Table 3.2.11 California Standards for Freezers with Volume Greater than 30 cubic feet......... 3-16

Table 3.2.12 Canadian Energy Standards for Added Refrigerator and Freezer Product 

Classes................................................................................................................ 3-17

Table 3.2.13 Canadian Standards for Wine Chillers.................................................................. 3-17

Table 3.2.14 History of ENERGY STAR Energy Use Criteria for Residential 

Refrigerators and Freezers................................................................................. 3-19

Table 3.2.15 Efficiency of Standard Refrigerators and Refrigerator-Freezers on the 

Market Relative to Current Federal Standard .................................................... 3-20
3-iii

Table 3.2.16 Performance Requirement for Federal Purchases of Refrigerators and 

Freezers.............................................................................................................. 3-21

Table 3.2.17 CEE Tier Levels Refrigerators and Refrigerator-Freezers................................... 3-22

Table 3.2.19 Manufacturer Tax Credits for Energy-Efficient Appliances in EESA 2008 ........ 3-23

Table 3.2.20 Rebates Offered for Highly Energy-Efficient Refrigerators and Recycled 

Refrigerators in 2010 ......................................................................................... 3-23

Table 3.2.21 Market Shares of Standard Refrigerator-Freezer Product Classes ....................... 3-26

Table 3.2.22 Sales of ENERGY STAR Labeled Refrigerator-Freezers.................................... 3-27

Table 3.2.23 Standard Refrigerator Saturation in U.S. Homes in 1987–2008 Period ............... 3-29

Table 3.2.24 Compact Refrigerator Saturation in U.S. Homes in 1987–2008 Period............... 3-30

Table 3.2.25 Freezer Saturation in U.S. Homes in 1987-2008 Period....................................... 3-31

Table 3.2.26 Refrigerator and Freezer Saturation in New U.S. Homes..................................... 3-32

Table 3.2.27 Refrigerator-Freezer and Freezer Average Retail Prices...................................... 3-32

Table 3.2.28 Baseline Unit Retail Prices from 2005 DOE Report (2004$)............................... 3-33

Table 3.2.30 Regression Analysis of the Incremental Price of ENERGY STAR and other 

Attributes based on 2007 Manufacturer-Suggested Retail Prices (2007$)........ 3-39

Table 3.2.31 Residential Refrigeration Products: Average Baseline Retail Price..................... 3-40

Table 3.3.1 Technology Options for Refrigerators, Refrigerator-Freezers, and Freezers......... 3-46

Table 3.3.2 Thermal Conductivity of Freshly-Sliced Foam Specimens at 75 oF (23.9 oC)....... 3-47

Table 3.3.3 Comparison of Various VIP Core Materials .......................................................... 3-48

Table 3.3.4 Center-of-Panel Thermal Conductivity of VIPs..................................................... 3-49

Table 3.3.5 Comparison of Various Gas-Filled Panel Core Materials...................................... 3-50

Table 3.3.6 Overall Cabinet Loads............................................................................................ 3-51

Table 3.3.7 Compressor Rating Conditions............................................................................... 3-54

Table 3.3.8 Estimated 1998 Maximum Compressor Efficiencies ............................................. 3-55

Table 3.3.9 Efficiencies of Some of Embraco’s Variable-Speed Compressor Models............. 3-56

Table 3.3.10 Efficiencies of LG’s Current Linear Compressor Models.................................... 3-57

LIST OF FIGURES

Figure 3.2.1 Annual Shipments of Refrigerators and Refrigerator-Freezers............................. 3-25

Figure 3.2.2 Annual Shipments of Freezers............................................................................... 3-25

Figure 3.2.3 Average Annual Electricity Use of New Refrigerator-Freezers and Freezers...... 3-27

Figure 3.2.4 2007 Manufacturer-Suggested Retail Price Distribution of Side-Mount 

Refrigerator-Freezers with and without ENERGY STAR (2007$)................... 3-35

Figure 3.2.5 2007 Manufacturer-Suggested Retail Price Distribution of Top-Mount 

Refrigerator-Freezers with and without ENERGY STAR (2007$)................... 3-36

Figure 3.2.6 2007 Manufacturer-Suggested Retail Price Distribution of Bottom-Mount 

Refrigerator-Freezers with and without ENERGY STAR (2007$)................... 3-36

Figure 3.2.7 2007 Manufacturer-Suggested Retail Price Distribution of Upright Freezers 

with and without ENERGY STAR (2007$) ...................................................... 3-37

Figure 3.2.8 2007 Manufacturer-Suggested Retail Price Distribution of Chest Freezers 

with and without ENERGY STAR (2007$) ...................................................... 3-37

Figure 3.3.1 Refrigeration Circuit.............................................................................................. 3-41
3-iv

Figure 3.3.2 Top-Mount Refrigerator-Freezer Components...................................................... 3-42

Figure 3.3.3 Annual Energy Consumption for Refrigerators and Refrigerator-Freezers 

with Manual Defrost (Product Class 1) ............................................................. 3-69

Figure 3.3.4 Annual Energy Consumption for Refrigerator-Freezers with Partial 

Automatic Defrost (Product Class 2)................................................................. 3-69

Figure 3.3.5 Annual Energy Consumption for Top-Mount Refrigerator-Freezers with 

Automatic Defrost without TTD Ice Service and All-Refrigerators with 

Automatic Defrost (Product Class 3)................................................................. 3-70

Figure 3.3.6 Annual Energy Consumption for Side-Mount Refrigerator-Freezers with 

Automatic Defrost without TTD Ice Service (Product Class 4)........................ 3-70

Figure 3.3.7 Annual Energy Consumption for Bottom-Mount Refrigerator-Freezers with 

Automatic Defrost without TTD Ice Service (Product Class 5)........................ 3-71

Figure 3.3.8 Annual Energy Consumption for Bottom-Mount Refrigerator-Freezers with 

Automatic Defrost with TTD Ice Service (Product Class 5A) .......................... 3-71

Figure 3.3.9 Annual Energy Consumption for Top-Mount Refrigerator-Freezers with 

Automatic Defrost with TTD Ice Service (Product Class 6)............................. 3-72

Figure 3.3.10 Annual Energy Consumption for Side-Mount Refrigerator-Freezers with 

Automatic Defrost with Through-the-Door Ice Service (Product Class 7) ....... 3-72

Figure 3.3.11 Annual Energy Consumption for Upright Freezers with Manual Defrost 

(Product Class 8)................................................................................................ 3-73

Figure 3.3.12 Annual Energy Consumption for Upright Freezers with Automatic Defrost 

(Product Class 9)................................................................................................ 3-73

Figure 3.3.13 Annual Energy Consumption for Chest Freezers and all other Freezers 

except Compact Freezers (Product Class 10) .................................................... 3-74

Figure 3.3.14 Annual Energy Consumption for Chest Freezers with Automatic Defrost 

(Product Class 10A)........................................................................................... 3-74

Figure 3.3.15 Annual Energy Consumption for Compact Refrigerators and RefrigeratorFreezers with Manual Defrost (Product Class 11)............................................. 3-75

Figure 3.3.16 Annual Energy Consumption for Compact Refrigerator-Freezers with 

Partial Automatic Defrost (Product Class 12) ................................................... 3-75

Figure 3.3.17 Annual Energy Consumption for Compact Top-Mount RefrigeratorFreezers with Automatic Defrost and All-Refrigerators with Automatic 

Defrost (Product Class 13)................................................................................. 3-76

Figure 3.3.18 Annual Energy Consumption for Compact Side-Mount RefrigeratorFreezers with Automatic Defrost (Product Class 14) ........................................ 3-76

Figure 3.3.19 Annual Energy Consumption for Compact Bottom-Mount RefrigeratorFreezers with Automatic Defrost (Product Class 15) ........................................ 3-77

Figure 3.3.20 Annual Energy Consumption for Compact Upright Freezers with Manual 

Defrost (Product Class 16)................................................................................. 3-77

Figure 3.3.21 Annual Energy Consumption for Compact Upright Freezers with 

Automatic Defrost (Product Class 17)............................................................... 3-78

Figure 3.3.22 Annual Energy Consumption for Compact Chest Freezers (Product Class 

18) ...................................................................................................................... 3-78
3-1

CHAPTER 3.MARKET AND TECHNOLOGY ASSESSMENT

3.1 INTRODUCTION

This report provides a profile of the residential refrigerator and freezer product industries 

in the United States. The U.S. Department of Energy (DOE) developed the preliminary market 

and technology assessment presented in this chapter primarily from publicly available 

information. This assessment identifies the major manufacturers and their product characteristics, 

which form the basis for the engineering and the life-cycle cost (LCC) analyses. Present and past 

industry structure and industry financial information help DOE in the process of conducting the 

manufacturer impact analysis.

3.1.1 Product Definitions

3.1.1.1 Refrigerators, Refrigerator-Freezers, and Freezers

The Code of Federal Regulations (CFR) establishes the product definitions for 

refrigerators, refrigerator-freezers, and freezers as follows:1

• The term Refrigerator means an electric refrigerator and the term Refrigerator-freezer means 

an electric refrigerator-freezer. 

• Electric refrigerator means a cabinet designed for the refrigerated storage of food at 

temperatures above 32 degrees Fahrenheit (°F) and below 39 °F, configured for general 

refrigerated food storage, and having a source of refrigeration requiring single phase, alternating 

current electric energy input only. An electric refrigerator may include a compartment for 

freezing and storage of food at temperatures below 32 °F, but does not provide a separate low 

temperature compartment designed for the freezing and storage of food at temperatures below 8

°F.

• Electric refrigerator-freezer means a cabinet which consists of two or more compartments 

with at least one of the compartments designed for the refrigerated storage of food at 

temperatures above 32 °F. and with at least one of the compartments designed for the freezing 

and storage of food at temperatures below 8 °F. which may be adjusted by the user to a 

temperature of 0 °F. or below. The source of refrigeration requires single phase, alternating 

current electric energy input only.

• Compact refrigerator, refrigerator-freezer, and freezer means any refrigerator, refrigeratorfreezer or freezer with total volume less than 7.75 ft3 (220 L) and 36 inches (0.91 meters) or less 

in height.

• Freezer means a cabinet designed as a unit for the freezing and storage of food at 

temperatures of 0 °F or below, and having a source of refrigeration requiring single phase, 

alternating current electric energy input only.
3-2

DOE has proposed changes to some of these definitions in the refrigeration product test 

procedure NOPR (75 CFR 29824 (May 27, 2010)) and in the refrigeration product energy 

conservation standards NOPR.

3.1.1.2 Wine Coolers

DOE amended the definition of “electric refrigerator”, effective December 19, 2001, to 

include a maximum temperature of the fresh food storage compartment, and to exclude certain 

appliances whose physical configuration makes them unsuitable for general storage of perishable 

foods.2

3.2 MARKET ASSESSMENT

Because wines coolers maintain storage temperature above 39 oF, they are exempted 

from existing refrigerator product classifications and are not required to meet minimum 

efficiency standards.

3.2.1 Product Classes

3.2.1.1 Product Classes Listed in the CFR

The CFR establishes the product classes for refrigerators, refrigerator-freezers, and 

freezers.3 As per the CFR, there are 18 product classes. The product classes are based on the 

following characteristics: type of unit (refrigerator, refrigerator-freezer, or freezer), size of the 

cabinet (standard or compact), type of defrost system (manual, partial, or automatic), presence or 

absence of through-the-door (TTD) ice service, and placement of the fresh food and freezer 

compartments for refrigerator-freezers.

DOE established separate product classes for compact products (<220 L or <7.75 ft3) 

because fewer opportunities are available for reducing energy consumption in these products.

Space is limited in compact units, so increasing the wall thickness is undesirable. Limited highefficiency compressor options are available in the capacity ranges appropriate for compact 

refrigerators. These units typically use natural convection evaporators and condensers and, 

therefore, cannot employ better fan motors as an energy-saving option.

3.2.1.2 Product Classes Modifications

Table 3.2.1 below shows 19 proposed new product classes. The additional product 

classes are proposed to address the following:

• Product classes made effective through the Office of Hearing and Appeal’s exception relief 

process.

• All-refrigerators.

• Products with automatic icemakers.

• Built-in products.
3-3

Table 3.2.1 Product Classes for Refrigerators, Refrigerator-Freezers, and Freezers

No. Product Class

Classes listed in the CFR

1 Refrigerators and refrigerator-freezers with manual defrost

2 Refrigerator-freezers—partial automatic defrost

3 Refrigerator-freezers—automatic defrost with top-mounted freezer without through-thedoor ice service

4 Refrigerator-freezers—automatic defrost with side-mounted freezer without through-thedoor ice service

5 Refrigerator-freezers—automatic defrost with bottom-mounted freezer without through-thedoor ice service

6 Refrigerator-freezers—automatic defrost with top-mounted freezer with through-the-door 

ice service

7 Refrigerator-freezers—automatic defrost with side-mounted freezer with through-the-door 

ice service 

8 Upright freezers with manual defrost

9 Upright freezers with automatic defrost

10 Chest freezers and all other freezers except compact freezers

11 Compact refrigerators and refrigerator-freezers with manual defrost

12 Compact refrigerator-freezers—partial automatic defrost

13 Compact refrigerator-freezers—automatic defrost with top-mounted freezer 

14 Compact refrigerator-freezers—automatic defrost with side-mounted freezer

15 Compact refrigerator-freezers—automatic defrost with bottom-mounted freezer

16 Compact upright freezers with manual defrost

17 Compact upright freezers with automatic defrost

18 Compact chest freezers

Product Classes Proposed to be Established During this Rulemaking

1A All-refrigerators—manual defrost

3A All-refrigerators—automatic defrost

5A Refrigerator-freezers—automatic defrost with bottom-mounted freezer with TTD ice 

service

10A Chest freezers with automatic defrost

11A Compact all-refrigerators—manual defrost

13A Compact all-refrigerators—automatic defrost

3-BI Built-in refrigerator-freezer—automatic defrost with top-mounted freezer without an 

automatic icemaker

3I Refrigerator-freezers—automatic defrost with top-mounted freezer with an automatic 

icemaker without through-the-door ice service

3I-BI Built-in refrigerator-freezers—automatic defrost with top-mounted freezer with an 

automatic icemaker without through-the-door ice service

3A-BI Built-in all-refrigerators—automatic defrost

4I Refrigerator-freezers—automatic defrost with side-mounted freezer with an automatic 

icemaker without through-the-door ice service

4-BI Built-in refrigerator-freezers—automatic defrost with side-mounted freezer without an 

automatic icemaker
3-4

No. Product Class

4I-BI Built-in refrigerator-freezers—automatic defrost with side-mounted freezer with an 

automatic icemaker without through-the-door ice service

5I Refrigerator-freezers—automatic defrost with bottom-mounted freezer with an automatic 

icemaker without through-the-door ice service

5-BI Built-in refrigerator-freezers—automatic defrost with bottom-mounted freezer without an 

automatic icemaker

5I-BI Built-in refrigerator-freezers—automatic defrost with bottom-mounted freezer with an 

automatic icemaker without through-the-door ice service

5A-BI Built-in refrigerator-freezer—automatic defrost with bottom-mounted freezer with throughthe-door ice service

7-BI Built-in refrigerator-freezers—automatic defrost with side-mounted freezer with throughthe-door ice service 

9-BI Built-in upright freezers with automatic defrost without an automatic icemaker

Two of these new product classes, currently called product class 5A, automatic defrost 

refrigerator-freezers with bottom-mounted freezer with TTD ice service, and product class 10A, 

chest freezers with automatic defrost, were identified in the framework document as product 

classes 19 and 20. DOE proposes to establish these two new product classes pursuant to its 

decision order to grant exemptions to standards for these specific product categories. DOE 

proposes to adopt the product class designations for these products which have been adopted by 

Canada in order to maintain international consistency. 

DOE’s Office of Hearings and Appeals granted five exceptions for refrigerator-freezer 

products with bottom-mounted freezer and TTD ice service, to Maytag Corporation (Maytag),

LG Electronics, Inc. (LG), Samsung Electronics, Electrolux Home Products, and BSH Home 

Appliances Corporation (BSH). DOE granted Maytag its exception on August 11, 2005 (case 

number TEE-0022), LG’s exception on November 9, 2005 (case number TEE-0025), Samsung’s

exception on July 26, 2007 (case number TEE-0047), Electrolux’s exception on December, 2008 

(case number TEE-0056), and BSH’s exception on April 23, 2010 (case number TEE-0070).

Before these rulings, there was no appropriately-defined category for this type of product, since 

the minimum standard for product class 5 (refrigerator-freezers with automatic defrost with 

bottom-mounted freezer without TTD ice service) was established to cover only products 

without TTD ice-service at the time of its development. The actual energy consumption of this 

new product (i.e., with TTD ice-service) is higher than that of product class 5 due to the added 

heat loss through the door to the fresh-food space, the reduced temperatures of the space reserved 

in the fresh food compartment for ice storage, which is maintained at lower temperatures than the 

rest of the fresh food compartment, and the energy consumed by the fan used to cool the space 

used for ice production and storage.

DOE’s Office of Hearings and Appeals granted an exception to Electrolux Home 

Products (Electrolux) for a specific brand of chest freezer with automatic defrost (case number 

TEE-0012). The Association of Home Appliance Manufacturers (AHAM) filed a letter 

supporting this exemption and recommended that DOE use the direct final rule process to 

establish a new class of chest freezers that would correspond to the minimum efficiency standard 
3-5

for automatic defrost chest freezers. The minimum standard for product class 10 (chest freezers 

and all other freezers) was established to cover products without automatic defrost at the time of 

its development. The actual energy consumption of the new product (i.e., with automatic defrost) 

is higher than that of product class 10 due to the added energy consumption associated with the 

automatic defrost system.

Five of the additional new product classes are all-refrigerator products which DOE 

proposes to separate from their current product classes, which currently include refrigerators 

with freezer compartments, refrigerator-freezers, and/or all-refrigerators. The proposed test 

procedure changes described in section 3.2.2 will result in significantly higher energy use for 

refrigerators with freezer compartments and refrigerator-freezers and somewhat less energy use 

for all-refrigerators. Hence, maintaining meaningful but fair energy standards requires the 

separation of all-refrigerators from the other product types.

DOE proposes six of the additional new product classes to distinguish products with 

automatic icemakers from those that do not have automatic icemakers. The proposed 

incorporation of icemaking energy use into the test procedure for products with automatic 

icemakers requires this step.

Ten of the additional new product classes are built-in products. Built-in products 

represent a small percentage of total refrigeration product shipments, in the range 1 to 2 percent. 

These products are designed to be integrated seamlessly into the kitchen cabinetry. Achieving 

this functionality requires design features that limit the potential to improve efficiency. DOE has 

concluded that creating separate product classes for these products is justifiable under EPCA’s 

requirements for separate product classes (42 U.S.C. 6295(q)). 

3.2.2 Product Test Procedures

The CFR establishes the test procedures for refrigerators, refrigerator-freezers, and 

freezers. (10 CFR Part 430, Subpart B, Appendices A1 and B1) DOE initiated a test procedure 

rulemaking in late 2008 to address test procedure issues identified at the framework workshop 

associated with this energy conservation standard rulemaking and to address recent test 

procedure waivers. A test procedure NOPR was published May 27, 2010. 75 FR 29824 

The NOPR proposed the following test procedure amendments to apply to products 

manufactured prior to the energy conservation standard compliance date (January 1, 2014): 

1. Modified procedures for test sample preparation

2. Clarification of procedures for establishing product clearances to walls during testing

3. Special requirements in case non-standard compartment temperature sensor locations are 

used during testing.

4. Clarification of how to set the median temperature settings for electronic control products

5. Modified test procedures for convertible compartments and special compartments

6. Establishment of a temperature-averaging procedure for auxiliary compartments

7. Modified definition for anti-sweat heater so that the definition applies to heaters preventing 

interior as well as exterior condensation.

8. Clarification that averaging of tests with the anti-sweat heater switch turned on and off
3-6

applies to energy use measurements as well as annual energy cost measurements.

9. Incorporation of test procedures for products with variable anti-sweat heating control, 

currently addressed in waivers

10. Modification of the long-time and variable defrost test method to capture precooling energy

11. Establishing test procedures measure all defrost energy use for products with multiple defrost 

cycle types

12. Elimination of the optional Part 3 of the variable defrost test

13. Corrections and other test procedure language changes

14. Requirements to include in certification reports some additional information to clarify energy 

measurements

The test procedure NOPR also proposed changes to apply to products manufactured on or 

after the energy conservation standard compliance date, as follows.

1. Update the AHAM standard reference from AHAM HRF-1-1979 to HRF-1-2008 

2. Establishing new compartment temperatures

3. Establishing a new volume calculation method

4. Clarification and adjustments to requirements for control settings for refrigerators and 

refrigerator-freezers during testing

5. Incorporation of a fixed-value placeholder representing icemaking energy use for products 

with automatic icemakers.

DOE proposed the first of these two groups of changes without an expectation that they 

would require changes in the energy conservation standards. The expected measurement changes 

for the second group of changes are associated primarily with the compartment temperature 

changes and the change in the volume calculation method. Chapter 5 discusses these 

measurement changes in greater detail, in section 5.4.2.

3.2.3 Manufacturer Information

This section provides information on domestic manufacturers of residential refrigerators, 

refrigerator-freezers, and freezers, including their brand names and products sold in the United 

States (section 3.2.3.1), estimated market shares (section 0), industry mergers and acquisitions 

(section 3.2.3.3), and product distribution channels (section 3.2.3.4). The section also discusses 

manufacturer trade groups (section 3.2.3.5) and manufacturers of compressors (section 3.2.3.6), 

as this is one of the most important components of residential refrigeration products.

3.2.3.1 Refrigerator, Refrigerator-Freezer, and Freezer Manufacturers

Table 3.2.2 lists refrigerator, refrigerator-freezer, and freezer manufacturers selling 

products in the United States. The second column indicates whether the manufacturer is a 

member of AHAM, and the third column indicates whether the manufacturer produces products 

that are ENERGY STAR compliant. Manufacturers that are a member of AHAM are listed first 

in the table and generally have the largest U.S. market shares. There are also several smaller 

manufacturers supplying products to the U.S. Those smaller manufacturers that produce

ENERGY STAR-compliant products are listed directly after AHAM member manufacturers.
3-7

Table 3.2.2 Refrigerator, Refrigerator-Freezer, and Freezer Manufacturers

Manufacturer Name

AHAM 

Member

E*

Products

Std RefrigFreezer FreezerCompact Built-InCustom 

Door/Inter.

Under 

Counter Luxury Unitoo Other′′

Aga Foodservice Group* Y - - - - - - - - -

 Marvel Industries - - Y Y - Y - Y Y (BI,SS,SI) Y

 Northland Corp. - - - Y - - Y - Y (BI,SS,CDD,SI) -

Bosch Home Appliances Corp. Y Y Y Y - - Y - Y (CDD,SS) -

Electrolux Home Products** Y Y - - - Y Y Y Y (CDD,SS,BI) -

 Frigidaire - Y Y Y - - - - - -

Fisher & Paykel Appliances Inc. Y - Y - - - - - Y (SS) -

GE Appliances*** Y Y Y Y Y - - - Y (SS,SI) -

 Hotpoint - Y Y Y Y - - - - -

 Monogram - Y Y Y - Y - - Y (BI,SS,SI) Y

Haier Group Y Y Y - Y - - - Y (CB,SS,SI) Y

LG Electronics Y Y Y - - - - - Y (TD,SI, SS) Y

Liebherr Y Y Y - - Y - - Y (BI,SS)

Samsung Electronics America Y Y Y - - - - - - -

Sanyo North America Corp. Y Y Y Y Y - - Y - Y

Sub-Zero Freezer Company Y Y - Y - Y Y Y Y (BI,CDD) Y

U-Line Corporation Y Y - Y Y - - Y - Y

Viking Range Corporation Y Y - Y - Y Y - Y (BI,CDD,SS) -

Whirlpool†† Y Y Y - - - - - - -

 Amana Appliances - Y Y Y - - - - Y (SS) Y

 Maytag - Y Y Y - - - - Y (SI,SS) -

 Estate Appliances - - Y - - - - - - -

 Magic Chef & Ewave - - Y Y Y - - - - -

 Gladiator Garage Works - Y Y - - - - - - -

 Ikea - Y Y - - - - - - -

 Inglis Home Appliances - Y Y - - - - - - -

 Jenn-Air - Y Y - - Y Y - Y (SS,SI,PI,CDD,BI) -

 Kitchen Aid - Y Y - - Y - Y Y (BI,SS,PI) Y

 Roper Appliances - - Y - - - - - - -

Daewoo Electronics Co. - Y - - Y - - - - -

Gorenje USA, Inc. - Y NA NA NA NA NA NA NA NA

Organizacion Mabe # - Y Y - Y - - - - -

 Camco Inc. - Y Y Y Y - - - Y (SI,SS,PI) -

 Moffat - Y Y - - - - - - -

Summit Appliances - Y Y Y Y - - Y - Y

Atlas Eléctrica## - - NA NA NA NA NA NA NA NA

Indesit Company### - - Y - - - - Y - -
3-8

Manufacturer Name

AHAM 

Member

E*

Products

Std RefrigFreezer FreezerCompact Built-InCustom 

Door/Inter.

Under 

Counter Luxury Unitoo Other′′

WiniaMando Inc. - - - - - - - - - Kimchi

Kenmore^^ - Y Y Y Y - - - - -

* Owns Marvel Industries and Northland Corp.

** Includes Frigidaire and White Westinghouse brands.

*** Includes Hotpoint and Monogram brands.

†† Includes the following brands: Amana Appliances, Maytag, Estate Appliances, Magic Chef & Ewave, 

Gladiator Garage Works, Ikea, Inglis Home Appliances, Jenn-Air, Kitchen Aid, Roper Appliances. # 48 percent owned by GE. Includes Moffat brand. Owns Camco Inc. ## 20 percent owned by Electrolux.

### Includes Aritson brand. ^^ Brand names that are produced by more than one mfg.

oo SS=Stainless Steel; BI=Built-In; CDD=Customized Designed Door; TD=TV in Door; 

SI=Size; CB=Convertible; PI=Price

′′ Units included: units with more than three doors, units for ‘compact kitchens’; 

refrigerated drawers; commercial-size units
3-9

Table 3.2.2 also indicates the types of products that each manufacturer produces. Product 

types include: standard-size refrigerator-freezers, freezers, compact units, built-in units, custom 

units, undercounter units, luxury units, and other types. Other types include: units with more than 

three doors, units for ‘compact kitchens’ other than compact refrigerators, refrigerated drawers, 

and commercial-size units.

3.2.3.2 Refrigerator, Refrigerator-Freezer, and Freezer Manufacturer Market 

Shares

Appliance magazine provides market share data for the most significant manufacturers 

(i.e., manufacturers with the greatest sales) for the following four product types: (1) standard-size

refrigerators and refrigerator-freezers, (2) compact refrigerators, (3) built-in/undercounter 

refrigerators, and (4) freezers.4 Table 3.2.3 through Table 3.2.6 show how market shares have 

changed over at least a ten-year period. Market shares among the largest manufacturers of 

standard-size refrigerator-freezers have remained relatively stable. Whirlpool Corporation 

(Whirlpool)’s 2006 acquisition of Maytag Corporation (Maytag) (discussed below) now gives 

Whirlpool the largest U.S. market share. Also, Haier America Trading, LLC (Haier), a relatively 

recent entrant to the market, captured six percent of the market in 2008. 

Table 3.2.3 Standard-Size Refrigerator-Freezer Manufacturer Market Shares

The market for compact refrigerators has seen a dramatic shift since 1993 (Table 3.2.4).

SANYO North America Corporation (Sanyo) had the largest market share by far in 1993, but 

now accounts for only seven percent of the market. Haier now has the largest compact 

refrigerator market share, followed by the joint venture between GE and Mexican appliance 

company Grupo P.I. Mabe S.A. (Mabe).

Company

Market Share

2008 2007 2006 2005 2004 2002 2000 1995

GE 27% 29% 29% 29% 29% 36% 34% 35%

Electrolux 23% 25% 25% 25% 25% 26% 21% 17%

Whirlpool 33% 25% 25% 25% 25% 23% 24% 27%

 Maytag NA 10% 10% 11% 11% 13% 14% 10%

 Goodman/Raytheon 

 (Amana)

NA NA 0% 0% 0% 0% 5% 10%

Haier 6% 4% 3% 2% 2% 2% 0% 0%

W.C. Wood 1% 1% 1% 1% 0% 0% 0% 0%

Other 10% 6% 7% 7% 8% 0% 2% 1%

Source: Appliance magazine
3-10

Table 3.2.4 Compact Refrigerator Manufacturer Market Shares

The reported market for built-in undercounter units has remained relatively stable over 

the past ten years (Table 3.2.5). The data show that U-Line Corporation (U-Line) has the greatest 

market share. Note that this market share distribution does not include full-size built-in products.

Table 3.2.5 Built-In Undercounter Refrigerator Manufacturer Market Shares

Company

Market Share

2007 2006 2005 2004 2002 2000 1995*

U-Line 69% 70% 69% 67% 65% 75% 58%

Marvel 21% 21% 21% 22% 25% 14% 27%

Sub-Zero 6% 6% 6% 7% 6% 10% 12%

Others 4% 3% 4% 4% 4% 1% 3%

Source: Appliance magazine; * 1995 data includes compact refrigerators.

Market share data for full-size built-in refrigerators and refrigerator-freezers is not

publicly available. Key manufacturers in this product category include Sub-Zero, General

Electric’s Monagram line, Whirlpool’s Kitchenaid line, Viking, and Northland. Manufacturers

providing imported products for this market include Liebherr, Bosch, and Miele. AHAM has 

recently begun collecting shipment data on built-in products. The percentage of overall 

shipments represented by built-in products has fluctuated between 2005 and 2007 between 1.6% 

and 2.2%. This includes both full-size and compact (undercounter) built-in products. This data 

was provided by AHAM as part of the pre-NOPR phase of this rulemaking.

Company

Market Share

2007 2006 2005 2004 2002 1997 1993

Haier 22% 21% 20.1% 20% NA 15% 0%

GE/Mabe 16% 16% 16.7% 17% NA 18% 17%

Sanyo 7% 7% 7.3% 8% NA 58% 61%

U-Line 5% 5% 4.8% 0% NA 0% 0%

Danby 3% 3% 2.9% 3% NA 0% 0%

Avanti 1% 2% 2.5% 0% NA 0% 0%

Whirlpool/Consul 1% 2% 1.9% 0% NA 2% 2%

Marvel 2% 2% 1.6% 0% NA 0% 0%

Wanbao NA 0% 0% 0% NA 5% 12%

Others 43% 42% 42.2% 52% NA 2% 8%

Source: Appliance magazine
3-11

For chest and upright freezers, Electrolux has retained the largest market share for ten 

years (Table 3.2.6). Haier, which was not in the market in 1995, now captures 16 percent of the 

market.

Table 3.2.6 Chest/Upright Freezer Manufacturer Market Shares

3.2.3.3 Mergers and Acquisitions

The appliance manufacturing industry has had a continuous history of consolidation.

Maytag acquired Jenn-Air Corporation (Jenn-Air) in 1982, Magic Chef, Inc. (Magic Chef) in 

1986, and Amana Appliances (Amana) in 2001. Whirlpool acquired the KitchenAid division of 

Hobart Corporation (KitchenAid) in 1986. White Consolidated Industries (WCI) acquired 

Frigidaire in 1979, and AB Electrolux acquired WCI (including Frigidaire) in 1986.

Mergers and acquisitions have two purposes. First, they produce large corporations with 

the financial resources and stability to be successful in a competitive market. Second, mergers 

and acquisitions mean manufacturers can have a complete line of home appliances. This product 

diversification allows firms to offer a complete set of appliances to consumers, an important 

feature in the builder market. There is also increasing worldwide competition in the major 

appliance market, so mergers and acquisitions are likely to continue.

On August 22, 2005, Whirlpool and Maytag announced plans to merge in a deal worth 

$2.7 billion.5 Maytag shareholders approved the merger on December 22, 2005. The U.S. 

Department of Justice (DOJ) Antitrust Division initiated an investigation into the effects of the 

merger, including potential lessening of competition or the creation of a monopoly. Opponents of 

the merger asserted that the combined companies would control as much as 70 percent of the 

residential laundry market and as much as 50 percent of the residential dishwasher market.6

Whirlpool claimed that its large potential residential laundry market share was skewed because 

the company produces washing machines for Sears, which sells them under its Kenmore inhouse brand. Whirlpool further stated that it must periodically bid with other manufacturers to 

keep the Kenmore contract and that Sears controls the pricing of the Kenmore units.7

In early January 2006, U.S. Senator Tom Harkin and U.S. Representative Leonard 

Boswell called on the DOJ to block the merger, claiming it would give Whirlpool an unfair 

advantage in the home appliance industry. On March 29, 2006, DOJ closed its investigation and 

approved the merger. DOJ stated that “the proposed transaction is not likely to reduce 

competition substantially. The combination of strong rival suppliers with the ability to expand 

Company

Market Share

2008 2007 2006 2005 2004 2002 2000 1995

Electrolux 

(Frigidaire) 64% 66% 66% 67% 68% 68% 69% 67%

W.C. Wood 19% 20% 21% 21% 22% 21% 27% 30%

Haier 16% 13% 12% 11% 9% 9% 3% 0%

Sanyo 1% 1% 1% 1% 1% 2% 1% 1%

Whirlpool 0% NA 0% 0% 0% 0% 0% 1%

Others 0% NA 0% 0% 0% 0% 0% 1%

Source: Appliance magazine
3-12

sales significantly and large cost savings and other efficiencies that Whirlpool appears likely to 

achieve indicates that this transaction is not likely to harm consumer welfare.”8

The DOJ Antitrust Division focused its investigation on residential laundry, although it 

considered impacts across all products offered by the two companies. DOJ determined that the 

merger would not give Whirlpool market power in the sale of its products and that any attempt to 

raise prices would likely be unsuccessful. To support this claim, DOJ provided reasons 

including: (1) other U.S. brands, including Kenmore, GE, and Frigidaire, are well established; 

(2) foreign manufacturers, including LG and Samsung, are gaining market share; (3) existing 

U.S. manufacturers are below production capacity; (4) the large home appliance retailers have 

alternatives available to resist price increase attempts; and (5) Whirlpool and Maytag 

substantiated large cost savings and other efficiencies to benefit consumers.8

Whirlpool and Maytag completed the merger on March 31, 2006.

In May 2009, W.C. Wood, a major freezer manufacturer, declared bankruptcy in Canada 

and the U.S. Attempts to sell W.C. Wood were unsuccessful, and on November 16, 2009, W.C. 

Wood entered liquidation. W.C. Wood had a long-standing relationship with Whirlpool as its 

freezer supplier. Whirlpool purchased the W.C. Wood facility and assets in Ottawa, OH in 

December 2009. W.C. Wood had the second largest market share of all freezer manufacturers at 

the time of its exit from the industry, so the competitive landscape for standard size freezers will 

change in 2010 and beyond.

3.2.3.4 Distribution Channels

Most residential refrigerators and freezers move directly from manufacturers to retail 

outlets. Table 3.2.7 identifies the types of retail stores through which major appliances, including 

refrigerators and freezers, are sold based on data from AHAM 2005 Fact Book.

9

Table 3.2.7 Major Appliance Sales by Channel

Type of Store Percentage of Appliance Purchases

Department Store (such as Sears or Kohls) 34.7%

Appliance Store or Consumer Electronics Store 30.9%

Home Improvement Store (such as Lowe’s or Home Depot) 23.8%

Discount Store (such as Wal-Mart or K-Mart) 2.0%

Membership Warehouse Club/Store (such as Sam’s or Costco) 1.8%

Another type of store 6.8%

Source: AHAM Fact Book

A certain share of shipments is purchased through channels other than retail outlets, e.g., 

by multi-family home builders for installation in new homes. The Consortium for Energy 

Efficiency (CEE) estimates that 20 to 30 percent of home appliance sales are commercial sales, 

i.e., sales to single/multi-family builders, contractors, government, public housing, and multifamily property managers.10 Because single-family builders typically do not include refrigeratorfreezers as part of a home sale, the 20 to 30 percent estimate by CEE is probably too high for the 

refrigerator market.
3-13

3.2.3.5 Manufacturer Trade Groups

AHAM is the primary manufacturer trade group representing most manufactures of 

refrigerators, refrigerator-freezers, and freezers. AHAM provides services to its members 

including government relations; certification programs for room air conditioners, dehumidifiers, 

and room air cleaners; an active communications program; and technical services and research.

In addition, AHAM conducts other market and consumer research studies and publishes a 

biennial Major Appliance Fact Book. AHAM also develops and maintains technical test 

procedures for various appliances to provide uniform, repeatable procedures for measuring

specific product characteristics and performance features. 

3.2.3.6 Compressor Manufacturers and Market Shares

Because the compressor is a key energy-using component of refrigerators, it is important 

to determine which compressor manufacturers are supplying the U.S. refrigerator market.

According to three sources, Embraco is the compressor manufacturer with the largest global 

market share, although several other manufacturers have significant global market share as 

well.

11, 12 For the U.S. refrigerator market, based on data from Embraco, it has by far the largest 

market share.13

Table 3.2.8

Besides Embraco, there are five other major compressor manufacturers 

supplying the world refrigerator and freezer market: Appliances Components Companies (ACC), 

Tecumseh Compressor Company (Tecumseh), Danfoss Compressors GmbH, Matsushita Electric 

Industrial Co., Ltd. (Matsushita), and LG Electronics, Inc. (LG). lists the compressor 

manufacturers and their estimated global and U.S. market shares.

Table 3.2.8 Compressor Manufacturers and World and U.S. Market Shares

Manufacturer

World Market Share U.S. Market Share

2005* Year not specified** 2006*** 2001†

Embraco 19.5% ~23% 25% 56%

ACC 15.0% ~20% NA NA

Tecumseh 13.5% ~8% NA NA

Matsushita 12.9% ~9% 18% NA

LG 10.8% ~8% NA NA

Danfoss 8.9% ~9% 15% <1%

Others 19.4% ~23% NA NA

Sources: *Universidade Federal de Santa Catarina, 2006; **Institute for Materials Science, Welding and 

Forming; ***Unable to cite source; †Embraco, 2001.

3.2.4 Regulatory Programs

The following section details current regulatory programs mandating energy conservation 

standards for refrigerator/freezers. It covers U.S. Federal energy conservation standards, State 

standards, standards in Canada and Mexico (which may impact the companies servicing the 

North American market), and international standards.
3-14

3.2.4.1 Federal Energy Conservation Standards

The National Appliance Energy Conservation Act of 1987 (NAECA) (42 U.S.C. 6291–

6309) established efficiency standards for refrigerators and refrigerator-freezers with a total 

refrigerated volume of less than 1104 L (39 ft3

) and for freezers with a total refrigerated volume 

of less than 850 L (30 ft3). Compact refrigerators and freezers represent separate product classes 

and have a volume less than 220 L (7.75 ft3) and a height of 0.91 meters (36 inches) or less. The 

minimum efficiency levels depend on product class and adjusted volume. The adjusted volume is 

equal to the fresh food internal volume plus an adjustment factor which depends on the product 

type times the freezer internal volume. The adjustment factor is 1.63 for refrigerator-freezers, 

1.44 for refrigerators with freezer compartments, 1.00 for all-refrigerators (which may have a 

freezer compartment with less than 0.5 ft3 volume), and 1.73 for freezers. Maximum annual 

energy use is expressed as kilowatt-hours (kWh) per year (yr). Note the these adjustment factors 

would change under the test procedure proposed to be required for testing of products when new 

energy conservation standards take effect in 2014. 75 FR 29824 (May 27, 2010)

NAECA initially established energy conservation standards for refrigerator-freezers that 

became effective in 1990. DOE amended NAECA with new standards that went into effect in 

1993, followed by the current amended standards that became effective in July 2001. 

Refrigerator-freezers manufactured to meet the 2001 standard typically consume about 30 

percent less energy than required under the 1993 efficiency regulations. The 1993 and 2001 

standards are summarized in Table 3.2.9 below.
3-15

Table 3.2.9 Federal Energy Efficiency Standards for Refrigerators, Refrigerator-Freezers, 

and Freezers

Product Class

Energy Standard Equations for 

Maximum Energy Use (kWh/yr)

Effective

January 1, 1993

Effective

July 1, 2001

1. Refrigerators and refrigerator-freezers with manual defrost. 13.5AV+299

0.48av+299

8.82AV+248.4

0.31av+248.4

2. Refrigerator-freezer—partial automatic defrost. 10.4AV+398

0.37av+398

8.82AV+248.4

0.31av+248.4

3. Refrigerator-freezer—automatic defrost with top-mounted 

freezer without through-the-door ice service and allrefrigerator—automatic defrost.

16.0AV+355

0.57av+355

9.80AV+276.0

0.35av+276.0

4. Refrigerator-freezers—automatic defrost with side-mounted 

freezer without through-the-door ice service.

11.8AV+501

0.42av+501

4.91AV+507.5

0.17av+507.5

5. Refrigerator-freezers—automatic defrost with bottom-mounted 

freezer without through-the-door ice service.

16.5AV+367

0.58av+367

4.60AV+459.0

0.16av+459.0

6. Refrigerator-freezers—automatic defrost with top-mounted 

freezer with through-the-door ice service.

17.6AV+391

0.62av+391

10.20AV+356.0

0.36av+356.0

7. Refrigerator-freezers—automatic defrost with side-mounted 

freezer with through-the-door ice service. 

16.3AV+527

0.58av+527

10.10AV+406.0

0.36av+406.0

8. Upright freezers with manual defrost. 10.3AV+264

0.36av+264

7.55AV+258.3

0.27av+258.3

9. Upright freezers with automatic defrost. 14.9AV+391

0.53av+391

12.43AV+326.1

0.44av+326.1

10. Chest freezers and all other freezers except compact freezers. 11.0AV+160

0.39av+160

9.88AV+143.7

0.35av+143.7

11. Compact refrigerators and refrigerator-freezers with manual 

defrost.

13.5AV+299*

0.48av+299*

10.70AV+299.0

0.38av+299.0

12. Compact refrigerator-freezer—partial automatic defrost. 10.4AV+398*

0.37av+398*

7.00AV+398.0

0.25av+398.0

13. Compact refrigerator-freezers—automatic defrost with topmounted freezer and compact all-refrigerator—automatic defrost.16.0AV+355*

0.57av+355*

12.70AV+355.0

0.45av+355.0

14. Compact refrigerator-freezers—automatic defrost with sidemounted freezer.11.8AV+501*

0.42**+501*

7.60AV+501.0

0.27av+501.0

15. Compact refrigerator-freezers—automatic defrost with bottommounted freezer.16.5AV+367*

0.58av+367*

13.10AV+367.0

0.46av+367.0

16. Compact upright freezers with manual defrost. 10.3AV+264*

0.36av+264*

9.78AV+250.8

0.35av+250.8

17. Compact upright freezers with automatic defrost. 14.9AV+391*

0.53av+391*

11.40AV+391.0

0.40av+391.0

18. Compact chest freezers. 11.0AV+160*

0.39av+160*

10.45AV+152.0

0.37av+152.0

5A. Refrigerator-freezer—automatic defrost with bottom-mounted 

freezer with through-the-door ice service. NA 5.0AV+539.00.18av+539.0

10A. Chest freezers with automatic defrost. NA 14.76AV+211.5

0.52av+211.5

AV: Adjusted Volume in ft3; av: Adjusted Volume in L

* Applicable standards for compact refrigerator products manufactured before July 1, 2001. Compact refrigerator 

products are not separate product categories under the standards effective January 1, 1993.
3-16

As discussed in section 3.2.1, two of the product classes listed in the table were made 

effective through the exception relief process of the Office of Hearings and Appeals. These 

product classes include (5A) automatic defrost refrigerator-freezers with bottom-mounted freezer 

and TTD ice service, and (10A) automatic defrost chest freezers. 

The Energy Independence and Security Act of 2007 (EISA) (P.L. 110-140), requires that 

DOE publish a final rule no later than December 31, 2010 to determine whether to amend the 

standards in effect for refrigerators, refrigerator-freezers, and freezers manufactured on or after 

January 1, 2014. 

3.2.4.2 State Energy Conservation Standards

As part of its Title 20 Appliance Efficiency Regulations, the California Energy 

Commission (CEC) has established standards for consumer refrigeration products that are not 

covered by Federal standards. CEC set standards for wine chillers (Table 3.2.10) and freezers

that have a total refrigerated volume greater than 850 L (30 ft3

) (Table 3.2.11).14 The standards 

for freezers with volume greater than 30 ft3 are numerically identical to the federal standards for 

smaller freezers—the California standards simply extend the federal standards beyond the 

federal size limitation.

Table 3.2.10 California Standards for Wine Chillers

Appliance Maximum Annual Energy Consumption 

(kWh)

Wine chillers with manual defrost 13.7V + 267

Wine chillers with automatic defrost 17.4V + 344

V = volume in ft3.

Table 3.2.11 California Standards for Freezers with Volume Greater than 30 cubic feet

Appliance Maximum Annual Energy Consumption 

(kWh)

Upright Freezers with manual defrost 7.55AV + 258.3

Upright Freezers with automatic defrost 12.43AV + 326.1

Chest Freezers 9.88AV + 143.7

AV = adjusted total volume, expressed in ft3, which is 1.73 times freezer volume (in ft3).

3.2.4.3 Canadian Energy Conservation Standards

Refrigerators and freezers are regulated products in Canada under the Canadian Energy 

Efficiency Regulations. The regulations reference Canadian Standards Association (CSA) 

CAN/CSA-C300-00, Energy Performance and Capacity of Household Refrigerators, 

Refrigerator-Freezers, and Freezers, for the testing procedure and for maximum annual energy 

consumption (MAEC) limits for residential refrigerators, refrigerator-freezers, and freezers. The 

product classes and MAEC limits in the Canadian regulations are the same as in the U.S. Federal 

standards.
3-17

In November 2006, Canada added two new product types to its Regulations (Amendment 

9) to harmonize with recent U.S. rulings with respect to these products.15

Table 3.2.12

These product types are 

refrigerator-freezers with automatic defrost and with a bottom-mounted freezer with TTD ice 

service and chest freezers with automatic defrost system. The maximum energy use regulations, 

listed in below, are identical to the energy standards that DOE’s Office of Hearings 

and Appeals assigned to these classes.

Table 3.2.12 Canadian Energy Standards for Added Refrigerator and Freezer Product 

Classes

Appliance Maximum Annual Energy Consumption 

(kWh)

Product Class 5A: refrigerator-freezers with 0.18av+539

automatic defrost and with bottom-mounted 

freezers with TTD ice service

Product Class 10A: chest freezers with 0.52av + 211.5

automatic defrost system

av = adjusted volume in liters

Natural Resources Canada (NRCan)’s Office of Energy Efficiency (OEE) amended

Canada's Energy Efficiency Regulations to add energy performance standards for residential 

wine chillers (or wine coolers).16

Table 3.2.13

The proposed standard includes a test procedure and minimum 

energy performance standard levels for wine chillers harmonized with those in effect in 

California. below shows the maximum annual energy consumption limits (in kWh) 

for residential wine chillers.

Table 3.2.13 Canadian Standards for Wine Chillers

Appliance Maximum Annual Energy Consumption 

(kWh)

Wine chillers with manual defrost 0.48av + 267

Wine chillers with automatic defrost 0.61av + 344

av = adjusted volume in L.

3.2.4.4 Mexican Energy Conservation Standards

The Mexican Official Standard establishes the maximum energy consumption limits for 

household refrigerators and freezers using hermetic motor-driven compressors, specifies the test 

methods for determining such energy consumption and the total refrigerated volume, and 

provides energy consumption label requirements. This standard applies to household 

refrigerators up to 1,104 cubic decimeters (39 ft3

) and household freezers of up to 850 cubic 

decimeters (30 ft3) using hermetic motor-driven compressors.17

3.2.4.5 Efficiency Standards Outside North America

The new standard levels (NOM015-ENER-2002) became effective in May 2003.

According to the Collaborative Labeling and Appliance Standards Program (CLASP) 

database, all 15 original European Union (EU) member countries, plus 16 other countries outside 
3-18

North America, have mandatory energy efficiency standards for refrigerator-freezers.18 The 

countries other than the original EU member countries are: Algeria, Australia, Bahrain, Chile, 

China, Chinese Taipei, Costa Rica, Hungary, Indonesia, Iran, Israel, New Zealand, Philippines, 

Republic of Korea, Thailand, and Viet Nam. 

In 2005, the European Parliament adopted a Commission proposal for a directive on 

establishing a framework for setting eco-design requirements (such as energy efficiency 

requirements) for all energy-using products in the residential, tertiary (services), and industrial 

sectors.19 EU-wide rules for eco-design are intended to ensure that disparities among national 

regulations do not become obstacles to intra-EU trade. The directive does not directly introduce 

binding requirements for specific products, but does define conditions and criteria for setting 

requirements regarding environmentally relevant product characteristics (such as energy 

consumption), and allows these requirements to be improved quickly and efficiently. The 

directive will be followed by implementing measures that will establish the eco-design 

requirements.

It is difficult to compare the standards in other countries with those in the U.S. due to 

differences in test procedures. The development of an international test procedure under the 

auspices of the International Electrotechnical Commission has international test procedure 

harmonization as a key objective. Establishment of Standard IEC 62552, which is currently 

under development, should make it easier in future to compare international refrigeration product 

energy standard levels.

3.2.5 Voluntary and other Federal and State Programs

In addition to mandatory standards, there are voluntary programs—e.g., the Federal 

Energy Management Program (FEMP) and CEE—as well as other Federal and State policies that 

affect the efficiency of new refrigerators and freezers.

3.2.5.1 ENERGY STAR

Historical ENERGY STAR Requirements 

ENERGY STAR is a voluntary program administered by the U.S. government to 

promote energy efficient consumer products. Table 3.2.14 below shows the history of ENERGY 

STAR energy use criteria for each of the three covered product categories. 
3-19

Table 3.2.14 History of ENERGY STAR Energy Use Criteria for Residential Refrigerators 

and Freezers

Product Group 1997

Initial 

Criteria

2001

Revision #1

2003

Addition of 

Freezers 

and 

Compacts

2004

Revision #2

2008

Revision #3

Standard-size 

Refrigerators & 

RefrigeratorFreezers

20% below

1993 Federal 

Standard

10% below

2001 Federal 

Standard

10% below 

2001 Federal 

Standard

15% below 

2001 Federal 

Standard

20% below 

2001 Federal 

Standard

Standard-size 

Freezers -------- --------

10% below 

2001 Federal 

Standard

10% below 

2001 Federal 

Standard

10% below 

2001 Federal

Standard

Compact 

Refrigerators & 

Freezers

-------- --------

20% below 

2001 Federal 

Standard

20% below 

2001 Federal 

Standard

20% below 

2001 Federal 

Standard

As of 2006, the market share of ENERGY STAR-compliant full-size refrigerators and 

refrigerator-freezers was just under 30%.20 Within this category, approximately 20 percent of 

top- and bottom-mount and 50 percent of side-mount refrigerator-freezer units sold in the U.S.

were ENERGY STAR compliant. Some States (i.e., Massachusetts, Michigan) have waived state 

sales tax for purchase of appliances that meet ENERGY STAR levels.

New ENERGY STAR requirements effective in 2008

The current ENERGY STAR criteria, drafted with input from stakeholders and two 

rounds of public comments, went into effect on April 28, 2008. To support the change,

ENERGY STAR released a market analysis20 and a final report on proposed program 

requirements.21 Table 3.2.15 shows the number of models that met the current Federal standard 

for refrigerators and available models with efficiencies 15 percent, 20 percent, and 25 percent 

higher than the Federal standard, as of April 2007 (prior to the 2008 revision). ENERGY STAR

program staff deemed the number of models offered to consumers at the higher efficiencies to be 

sufficient to warrant changing the labeling criteria. 
3-20

Table 3.2.15 Efficiency of Standard Refrigerators and Refrigerator-Freezers on the Market 

Relative to Current Federal Standard

Efficiency Level Number of Available Models

(prior to 2008 criteria revision)

Percent of Available Models

(prior to 2008 criteria revision)

Current Federal Standard 

(effective July 2001) 2,524 100%

2004 ENERGY STAR Criteria 

(15% better than Federal 

Standard)

1,441 57%

2008 ENERGY STAR Criteria 

(20% better than Federal 

Standard)

121 4.8%

25% better than Federal Standard 14 0.6%

Source: ENERGY STAR, April 27, 200720

3.2.5.2 Federal Energy Management Program

DOE’s FEMPa works to reduce the cost and environmental impact of the Federal 

government by advancing energy efficiency and water conservation, promoting the use of 

distributed and renewable energy, and improving utility management decisions at Federal sites.

FEMP helps Federal buyers identify and purchase energy-efficient equipment, including 

residential refrigerators and freezers.

Federal agencies are required by the Energy Policy Act of 2005 (EPACT 2005, P.L. 109-

58) and Federal Acquisition Regulations (FAR) Subpart 23.2 to specify and buy ENERGY 

STAR-qualified products or, in categories with no ENERGY STAR label, FEMP-designated 

products which are among the highest 25 percent of equivalent products for energy efficiency.

Table 3.2.16 below shows refrigerator and freezer performance requirements for Federal 

purchases.

 

a For more information, please visit www.eere.energy.gov/femp.
3-21

Table 3.2.16 Performance Requirement for Federal Purchases of Refrigerators and

Freezers

Product Class

Total Volume*

(ft3)

Product Class 

Number(s)*** Annual Energy Use**

Single–Door Manual Defrost <2.4 11 255 kWh/year or less

Single–Door Manual Defrost 2.5 to 4.4 11 275 kWh/year or less

Single–Door Manual Defrost 4.5 to 6.4 11 295 kWh/year or less

Single–Door Manual Defrost >6.5 1 or 11 315 kWh/year or less

Single–Door Automatic Defrost <2.4 13 305 kWh/year or less

Single–Door Automatic Defrost 2.5 to 4.4 13 325 kWh/year or less

Single–Door Automatic Defrost 4.5 to 6.4 13 345 kWh/year or less

Single–Door Automatic Defrost >6.5 3 or 13 365 kWh/year or less

Bottom–Mount Freezer <18.4 5, 5A, or 15 475 kWh/year or less

Bottom–Mount Freezer 18.5 to 20.4 5 or 5A 485 kWh/year or less

Bottom–Mount Freezer >20.4 5 or 5A 495 kWh/year or less

Top–Mount Freezer <10.4 3, 6, or 13 340 kWh/year or less

Top–Mount Freezer 10.5 to 12.4 3 or 6 360 kWh/year or less

Top–Mount Freezer 12.5 to 14.4 3 or 6 380 kWh/year or less

Top–Mount Freezer 14.5 to 16.4 3 or 6 400 kWh/year or less

Top–Mount Freezer 16.5 to 18.4 3 or 6 420 kWh/year or less

Top–Mount Freezer 18.5 to 20.4 3 or 6 440 kWh/year or less

Top–Mount Freezer 20.5 to 22.4 3 or 6 460 kWh/year or less

Top–Mount Freezer 22.5 to 24.4 3 or 6 480 kWh/year or less

Top–Mount Freezer >24.5 3 or 6 500 kWh/year or less

Side-mount Freezer <20.4 4, 7, or 14 560 kWh/year or less

Side-mount Freezer 20.5 to 22.4 4 or 7 580 kWh/year or less

Side-mount Freezer 22.5 to 24.4 4 or 7 600 kWh/year or less

Side-mount Freezer >25.5 4 or 7 620 kWh/year or less

* Total volume is the sum of the refrigerator and freezer volumes.

** Annual Energy Use is based on DOE test procedure (10 CFR 430, subpart B, appendix A1).

*** Possible Product Class numbers based on Product Class Descriptions

3.2.5.3 Consortium for Energy Efficiency

The Consortium for Energy Efficiency (CEE) is a nonprofit corporation that promotes the 

manufacture and purchase of energy-efficient products and services. CEE promotes energyefficient refrigerators that use significantly less electricity than the Federal standard. These 

energy-efficient refrigerators represent the upper end of the ENERGY STAR efficiency levels.

Effective January 1, 2007, CEE identifies three tiers for “super-efficient” refrigerators and 

refrigerator-freezers. Table 3.2.17 below provides the specifications for the CEE.
3-22

Table 3.2.17 CEE Tier Levels Refrigerators and Refrigerator-Freezers

Efficiency level Percent Energy Use below Federal Standard

Standard Refrigerators Compact Refrigerators

CEE Tier 1 (Current 

ENERGY STAR) 20 20

CEE Tier 2 25 25

CEE Tier 3 30 30

3.2.5.4 ENERGY STAR, FEMP, CEE Summary

Table 3.2.18 below presents maximum unit energy consumption (UEC) values for the 

current Federal standard and the ENERGY STAR and CEE voluntary standards for (1) a topmount refrigerator-freezer with automatic defrost with no TTD ice features and 21.4 ft3 adjusted 

volume, and (2) a side-mount refrigerator freezer with TTD features and 26.2 ft3 adjusted 

volume. 

Table 3.2.18 Annual Energy Consumption for Refrigerator-Freezers with Different 

Specifications

Efficiency Level Top Mount* Side-Mount**

2001 Federal Standard 486 671

Former ENERGY STAR (15% below standard) 413 570

CEE Tier 1, current ENERGY STAR (20% below standard) 389 537

CEE Tier 2 (25% below standard) 364 503

CEE Tier 3 (30% below standard) 340 469

* Auto defrost, no TTD features, 18.2 ft3 total volume, and 21.4 ft3 adjusted volume.

** Auto defrost, TTD features, 21.7 ft3 total volume, and 26.2 ft3 adjusted volume.

Source: DOE FY-2005 Priority Setting TSD; based on ENERGY STAR (2004),22 FEMP (2005)23 CEE (2004)24

3.2.5.5 Manufacturer Tax Credits for Energy-Efficient Appliances

EPACT 2005 provided tax credits to manufacturers for the production of energy-efficient 

residential refrigerators. These credits were intended to help manufacturers meet the costs of 

producing appliances that exceed the Federal standards. The credit program was modified by the 

Emergency Economic Stabilization Act of 2008 (EESA 2008) and extended through 2010.25 The 

credit for residential refrigerators is a per-product credit (see Table 3.2.19). For more information 

on manufacturer tax credits, refer to appendix 12-C.
3-23

Table 3.2.19 Manufacturer Tax Credits for Energy-Efficient Appliances in EESA 2008

Savings relative to 2001 Federal 

Standard

Applicable Credit Amount Applicable Years

20% to 22.9% $50 2008

23% to 24.9% $75 2008, 2009

25% to 29.9% $100 2008, 2009, 2010 30% or more $200

Notes: ‘Refrigerators’ refers to residential automatic defrost refrigerator-freezers with an internal volume of at 

least 16.5 ft3. 

3.2.5.6 Rebates for Highly Energy-Efficient Products

Electric utilities and other organizations promote the purchase of highly energy-efficient 

refrigerators through consumer rebates. Typically, these programs offer rebates for products 

meeting existing ENERGY STAR efficiency levels. Some utilities also offer incentives to retire 

old and inefficient appliances by offering rebates and disposal services for recycling old units in 

order to encourage consumers to purchase new, more efficient units and to ensure the safe 

disposal of hazardous waste. Table 3.2.20 below lists some rebates that are offered in 2010.

Table 3.2.20 Rebates Offered for Highly Energy-Efficient Refrigerators and Recycled 

Refrigerators in 2010

Utility/Organization* Rebate Level

Ameren Illinois Utilities $35 (recycling)

Avista Utilities $25 (ENERGY STAR)

BC Hydro $50 (ENERGY STAR), $30 (recycling)

Bonneville Power Administration $25 (ENERGY STAR), $125 (recycling)

City of Palo Alto Utilities $50 (ENERGY STAR), $35 (recycling)

Commonwealth Edison $50 (ENERGY STAR)

Efficiency Maine $75 (ENERGY STAR)

Efficiency Vermont $25 (ENERGY STAR), $50 (CEE Tier 2), $30 (recycling)

Energy Trust of Oregon $50 (ENERGY STAR and CEE Tier 1)

Eugene Water & Electric Board $25 (ENERGY STAR), $30 (recycling)

Idaho Power Company $30 (ENERGY STAR)

Long Island Power Authority $75 (ENERGY STAR), $35 (recycling)

Midwest Energy Efficiency Alliance –

Illinois

15% off (ENERGY STAR), $75 (recycling)

Midwest Energy Efficiency Alliance –

Indiana

$30 (recycling)

Public Service Company of New Mexico $30 (recycling)

Puget Sound Energy $30 (recycling)

San Diego Gas and Electric $25 (ENERGY STAR)

Seattle City Light $30 (recycling)

Snohomish Public Utility District $50 (ENERGY STAR), $30 (recycling)

Tacoma Power $30 (recycling)

* The table includes those programs listed as providing specified rebates for ENERGY STAR refrigerators in the 

publication “Summary of Residential Appliance Programs in the United States and Canada,” by CEE, April 2010.

Additional programs may exist.
3-24

3.2.5.7 State Tax Incentives for Highly Energy-Efficient Products

According to the Database of State Incentives for Renewables & Efficiency (DSIRE)

26

3.2.6 Historical Shipments and Efficiencies

, 

Michigan and Oregon offer personal tax credits for the purchase of premium-efficiency

refrigerators. Missouri, North Carolina, Virginia, and West Virginia offer sales tax incentives for 

premium-efficiency refrigerators by offering 100% sales tax exemptions at certain times 

throughout the year.

3.2.6.1 Historical Shipments

Two public sources of information provide historical shipments data on residential 

refrigerators, refrigerator-freezers, and freezers: Appliance magazine27

9

and the AHAM Fact

Book. Appliance magazine breaks down refrigerator and refrigerator-freezer shipments into 

three groups: (1) standard-size units, (2) built-in units, and (3) compact units. Both sources break 

down freezer shipments into chest and upright units. Unfortunately, neither source provides any 

further level of disaggregation. As discussed below, standard-size shipments can be broken down 

into two broad groups: (1) top- and bottom-mount refrigerators and refrigerator-freezers, and (2) 

side-mount units.

Figure 3.2.1 shows historical shipments of refrigerators and refrigerator-freezers. Figure 

3.2.2 shows historical shipments of freezers. In the past decade, annual shipments of standard 

refrigerator-freezers have grown from 8 million to 11 million, although shipments have dropped 

off significantly in 2007 and 2008 in response to poor economic conditions. Annual shipments of 

compact refrigerators grew from one million to roughly 3 million, but shipments dropped starting 

in 2006. Note that the data for refrigerators include products used in non-residential settings 

(e.g., hotels and offices), but the size of this market segment is unknown.

Shipments of chest and upright freezers have grown less rapidly than those of standard 

refrigerator-freezers. These shipments rose from 1.5 million in 1997 to 2.5 million in 2002, but 

shipments dropped starting in 2005 and are now at 2 million annually. Shipments of compact 

freezers are roughly 0.5 million.
3-25

Figure 3.2.1 Annual Shipments of Refrigerators and Refrigerator-Freezers

Figure 3.2.2 Annual Shipments of Freezers

0

2

4

6

8

10

12

1990199119921993199419951996199719981999200020012002200320042005200620072008

Annual Shipments (millions)

Year

Standard-Size

Compact

0.0

0.5

1.0

1.5

2.0

2.5

3.0

1990199119921993199419951996199719981999200020012002200320042005200620072008

Annual Shipments (millions)

Year

Standard-Size

Compact
3-26

For DOE’s 2005 technical analysis of amended energy conservation standards for 

residential refrigerator-freezers, AHAM provided historical shipments data for the time period 

1998–2004, broken down into three broad groups: (1) top- and bottom-mount refrigeratorfreezers, (2) side-mount units, and (3) single-door units.28 Table 3.2.21 below shows market 

share data for only two of the above three groups—top- or bottom-mount refrigerator-freezers 

and side-mount refrigerator-freezers. According to DOE’s 2005 technical analysis, these two 

product groupings account for over 99 percent of standard-size refrigerator-freezer shipments.

Data provided by AHAM as part of the pre-NOPR phase shows that in recent years single-door 

units accounted for 0.2% or less of shipments of standard-size refrigerators and refrigeratorfreezers. This data also shows a strong shift towards bottom-mount refrigerator-freezers in the 

last few years, coinciding with reduction in market share of both side-mount and top-mount 

refrigerator-freezers.

Table 3.2.21 Market Shares of Standard Refrigerator-Freezer Product Classes

Year

Top- Mount 

Refrigerator- Freezer

(percent)

Bottom- Mount 

Refrigerator- Freezer

(percent)

Side-Mount RefrigeratorFreezer

(percent)

1998 69.3 29.9

1999 68.8 30.8

2000 68.3 31.3

2001 67.5 32.1

2002 66.6 32.8

2003 63.7 34.5

2004 63.4 35.1

2005 62.5 2.0 35.2

2006 54.5 10.6 34.6

2007 53.9 13.6 32.4

Source: AHAM

Based on data from The NPD Group for 2004,

29 DOE estimated that (1) top-mount 

refrigerator-freezers without TTD ice service in the size category range of 14 to 21 ft3 b

3.2.6.2 Historical Efficiencies

comprise 

81 percent of total top- and bottom-mount refrigerators, and (2) side-mount refrigerator-freezers 

with TTD ice service in the size category range of 21 to 30 ft3 comprise 98 percent of total sidemount refrigerator-freezer shipments. 

The average efficiency of new refrigerators and freezers has increased greatly since the 

1980s. Figure 3.2.3 below (which shows annual electricity consumption) indicates the changes in 

efficiency resulting from the Federal standards that took effect in 1990, 1993, and 2001. Note 

that the average efficiency trends shown in the chart reflect changes in product size and features 

as well as changes in the efficiency within specific types of products. In particular, the growing 

 

b Size category is based on ft3 of total refrigerated volume (fresh food volume plus freezer volume).
3-27

market share of side-mount refrigerator-freezers placed upward pressure on the average annual 

electricity use of new refrigerator-freezers.

Figure 3.2.3 Average Annual Electricity Use of New Refrigerator-Freezers and Freezers

Source: AHAM

ENERGY STAR sales data are an indicator of the demand for very energy-efficient 

products. The market share of ENERGY STAR labeled refrigerator-freezers grew from 17 

percent in 2001 to 33 percent in 2004 (Table 3.2.22) and held steady in the low 30 percent range 

in the following two years.

30

Table 3.2.22 Sales of ENERGY STAR Labeled Refrigerator-Freezers

Year Energy Star Criteria Percent of Total

1998 20% below 1993 Standard 19%

1999 24%

2000 27%

2001 10% below 2001 Standard 17%

2002 20%

2003 26%

2004 15% below 2001 Standard 33%

2005 33%

2006 31%

Source: ENERGY STAR

0

200

400

600

800

1000

1200

1400

1600

1800

1970 1975 1980 1985 1990 1995 2000 2005 2010

Year 

Annual Energy Use (kWh/year)

Standard-Sized Refrigerator-Freezer

Freezer

1990 

Standards 

announced

1993 

Standards

2001 

Standards
3-28

3.2.6.3 Imports and Exports

The share of domestic shipments of refrigerators and freezers accounted for by imports 

grew significantly in the 1994-2004 period. Refrigerator imports totaled nearly six million units 

in 2004. Over one-third of the imports came from Mexico. Freezer imports totaled around one 

million units in 2004.9

Annual refrigerator exports—mostly to Canada—were in the 1.0 to 1.1 million units 

range in the 1994-2004 period, while annual freezer exports ranged between 200,000 and 

250,000 units.

9

3.2.7 Saturation in U.S. Homes

Saturation refers to the percentage of homes with a given product. DOE used four

primary sources of information on the saturation and ownership of refrigerators, refrigeratorfreezers, and freezers in U.S. homes: (1) a 2001 report prepared for AHAM by NFO Research, 

Inc.,31 (2) Appliance magazine, (3) the Energy Information Administration (EIA)’s Residential 

Energy Consumption Survey (RECS),32,33,34 and (4) a 2005 AHAM report entitled Major 

Appliance Saturation & Marketing Factors Study.35 Only RECS provides market saturations for 

recently-built housing; this information is useful for forecasting future shipments to new 

housing.

The saturation of standard refrigerators has been close to 100 percent for two decades 

(Table 3.2.23). The RECS data show that the share of households with two or more refrigerators 

grew from 13 percent in 1993 to 15 percent in 2001 and to 19 percent in 2005 (the current 

percentage with two or more is likely even higher).
3-29

Table 3.2.23 Standard Refrigerator Saturation in U.S. Homes in 1987–2008 Period

Year

Refrigerators, Standard

Appliance

Magazine NFO 2001

RECS

All 1 unit 2 or more

1987 99.9%

1988

1989

1990 96.7%

1991

1992 99.0%

1993 99.3% 98.6% 85.8% 12.8%

1994 99.5%

1995 99.7%

1996 99.8% 93.9%

1997 99.8% 98.9% 85.8% 13.2%

1998 99.8%

1999 99.8%

2000 99.9%

2001 99.0% 93.1% 99.3% 82.9% 14.6%

2002 99.0%

2003 99.0%

2004 99.0%

2005 99.0% 99.9% 77.7% 19.2%

2006 99.0%

2007 99.0%

2008 99.0%

The data on saturation of compact refrigerators vary greatly (Table 3.2.24). The estimates 

for 2005 vary from a low of 3.7 percent (RECS) to a high of 17.0 percent (Appliance magazine).

Comparatively, NFO’s estimate for 2001 is 5.6 percent.
3-30

Table 3.2.24 Compact Refrigerator Saturation in U.S. Homes in 1987–2008 Period

Year

Refrigerators, Compact

Appliance

Magazine NFO 2001

RECS

All 1 unit 2 or more

1987

1988

1989

1990 7.4%

1991

1992 7.4%

1993 8.7% 3.2% 3.2% 0.0%

1994 9.2%

1995 9.7%

1996 11.2% 5.8%

1997 12.1% 2.8% 2.8% 0.1%

1998 12.6%

1999 14.5%

2000 16.0%

2001 16.5% 5.6% 3.1% 3.0% 0.1%

2002 16.5%

2003 16.5%

2004 17.0%

2005 17.0% 3.7% 3.1% 0.6%

2006 18.0%

2007 19.0%

2008 19.0%

The data on freezer saturation are also somewhat varied (Table 3.2.25). Appliance

magazine reports that freezer saturation has risen from 40 percent in 1993 to 45 percent in 2005, 

but the NFO study reports that the 2001 level (41 percent) was lower than in 1990 (45 percent).

RECS shows a much lower freezer saturation in 2001 (32 percent) than the other sources, and 

also shows a declining trend.
3-31

Table 3.2.25 Freezer Saturation in U.S. Homes in 1987-2008 Period

Year

Freezers

Appliance

Magazine NFO 2001

RECS

All 1 unit 2 or more

1987 40.7%

1988

1989

1990 45.4%

1991

1992 38.2%

1993 40.0% 34.5% 30.5% 4.0%

1994 40.0%

1995 41.2%

1996 42.5% 42.4%

1997 42.4% 33.2% 30.2% 2.9%

1998 42.8%

1999 42.9%

2000 44.0%

2001 47.0% 41.0% 32.0% 28.8% 3.2%

2002 47.5%

2003 47.5%

2004 47.0%

2005 45.0% 31.6% 29.0% 2.6%

2006 43.0%

2007 42.0%

2008 43.0%

As shown in Table 3.2.26, RECS data indicate that in new housing (1) the saturation of 

freezers is lower, and (2) the share of households with two or more refrigerators is higher in 

recently-built homes than in the total population of homes. For freezers, this result is in 

accordance with the declining saturation of freezers in the total population seen in Table 3.2.25.
3-32

Table 3.2.26 Refrigerator and Freezer Saturation in New U.S. Homes

Year

Standard Refrigerators Freezers

New Homes* New Homes*

All 1 unit 2 or more All 1 unit 2 or more

1993 99.7% 90.4% 9.2% 30.3% 27.8% 2.5%

1994

1995

1996

1997 99.6% 85.8% 13.8% 35.9% 33.1% 2.6%

1998

1999

2000

2001 100% 82.5% 15.6% 28.4% 26.3% 2.1%

2002

2003

2004

2005 100% 75.0% 26.1% 27.2% 23.9% 3.3%

Source: RECS surveys; * “New homes” refers to homes built in the 1988-1993 period for the 1993 RECS, the 

1992-1997 period for the 1997 RECS, and the 1996-2001 period for the 2001 RECS, and the 2001-2005 period for 

the 2005 RECS.

3.2.8 Product Retail Prices

3.2.8.1 Historical Retail Prices

AHAM has reported average consumer retail prices for refrigerator-freezers and freezers 

in past Fact Books. Table 3.2.27 lists the prices for eight years spanning 1980–2002. The real 

price of refrigerator-freezers and freezers (expressed in 2008 $) declined during the 1980s and 

1990s. However, in 2002, the prices of both types of products increased relative to the year 1998.

Table 3.2.27 Refrigerator-Freezer and Freezer Average Retail Prices

Product Price

Year

1980 1985 1986 1991 1993 1994 1998 2002

RefrigeratorFreezers

nominal $ $598 $702 $684 $732 $692 $713 $657 $788

2008 $ $1,563 $1,405 $1,344 $1,157 $1,031 $1,036 $868 $943

Freezers nominal $ $426 $479 $449 $434 $334 $344 $315 $405

2008 $ $1,113 $958 $882 $686 $498 $500 $416 $485

Source: AHAM Fact Books.

3.2.8.2 Refrigerator-Freezer 2004 Retail Prices

DOE’s most recent technical analysis of amended energy conservation standards for 

residential refrigerator-freezers published in October 2005 provided the retail price of the two 

largest product classes of refrigerator-freezers: top-mount refrigerator-freezers without TTD 

features and side-mount refrigerator-freezers with TTD features.

28 The analysis also established 

the retail price of products meeting existing ENERGY STAR levels.
3-33

Baseline Retail Prices

DOE determined the retail price of baseline-efficiency top-mount refrigerator-freezers 

without TTD features and side-mount refrigerator-freezers with TTD features from data 

purchased from NPD Group. The NPD Group dataset included information about the average 

price of more than 2000 refrigerator models sold in 2004 in the United States.c Table 3.2.28

below summarizes the retail price data for three capacity sizes for each of the product types. The 

retail prices correspond to baseline-efficiency products, i.e., products that just meet the existing 

energy conservation standards.

Table 3.2.28 Baseline Unit Retail Prices from 2005 DOE Report (2004$)

Product Type 14-17 ft

3 18-20 ft3 21-22 ft3

Top-Mount without TTD $329 $386 $457

21-23 ft3 24-26 ft3 27-30 ft3

Side-Mount with TTD $702 $789 $926

Source: The NPD Group/NPD Houseworld – POS.

Price of ENERGY STAR

DOE’s October 2005 report also provided incremental retail price estimates of ENERGY 

STAR products relative to baseline products. At the time, ENERGY STAR levels specified 15 

percent lower energy consumption than the federal energy standard level. DOE used two 

approaches to estimate the retail prices: (1) the application of manufacturer and retailer markups 

to manufacturer costs, and (2) a retail price analysis of ENERGY STAR compliant products 

based on data from the NPD Group. Table 3.2.29 below summarizes the retail price increments 

associated with meeting ENERGY STAR relative to baseline models of several different 

capacity sizes. Note that the two approaches yield roughly the same average retail price 

increment of meeting ENERGY STAR with the exception of the 27–30 ft3 side-mount 

refrigerator.

Table 3.2.29 Average Retail Price Increment of ENERGY STAR from 2005 DOE Report 

(2004$)

Product Type Approach 14-17 ft3 18-20 ft3 21-22 ft3

Top-Mount without 

TTD

Markups $38 $35 $42

Retail Prices $28 $49 $63

Product Type Approach 21-23 ft3 24-26 ft3 27-30 ft3

Side-Mount with TTD Markups $54 $35 $183

Retail Prices $47 $66 $88

Source: DOE, 2005.

 

c The data also included information about the refrigerator brand, manufacturer, attributes (e.g., total refrigerated 

volume, number and type of shelves), and sales, and whether each model has an Energy Star rating. The data cost 

$25,000 to purchase. 
3-34

3.2.8.3 2007 Manufacturer-Suggested Retail Prices

DOE collected retail price data for several refrigerator-freezer and freezer models from 

five manufacturers’ Internet web sites: General Electric, Whirlpool, Frigidaire, Maytag, and LG 

Electronics. The price data reflect manufacturer-suggested retail prices and, therefore, may not 

reflect actual sales prices. Even so, DOE conducted a statistical analysis of the data to determine 

the effect of certain attributes, including the impact of meeting existing ENERGY STAR levels.

DOE collected data on 1,268 refrigerator-freezer and freezer models. The collected data 

set included information about the retail price and model number of refrigerator-freezers and 

freezers sold in 2007 in the U.S., coupled with information about the brand, attributes (i.e., color, 

stainless steel, built-in, French doors), and whether the product met existing ENERGY STAR

levels. DOE sorted the data into the following product types: (1) side-mount refrigerator-freezers

consisting of 523 models, (2) top-mount refrigerator-freezers consisting of 340 models, (3) 

bottom-mount refrigerator-freezers consisting of 281 models, (4) chest freezers consisting of 46 

models, and (5) upright freezers consisting of 54 models.

Figure 3.2.4 through Figure 3.2.8 present price distributions for each product type, 

showing variation in price of products which do not meet ENERGY STAR criteria as well as 

variation in price for products with comply with ENERGY STAR. The price distributions of 

side-mount and top-mount refrigerator-freezers in Figure 3.2.4 and Figure 3.2.5 indicate that 

ENERGY STAR generally increases the price and that there is a wider price variation for 

ENERGY STAR products. Also, both refrigerator-freezer types exhibit skewed price 

distributions, i.e., more models are low-priced with relatively few high-priced models (as an 

example, fewer than 10 models were priced above $1,300 for top-mounts). The price 

distributions for bottom-mount refrigerator-freezers, Figure 3.2.6 below, show that French-door 

configurations are more of a factor in contributing to high price than ENERGY STAR efficiency 

levels. Most bottom-mount models already meet ENERGY STAR, and those models configured 

with French doors are distinctly more expensive. The price distributions for upright freezers 

show that ENERGY STAR models are generally more expensive (Figure 3.2.7). For chest 

freezers, there are several models with and without ENERGY STAR that are priced similarly, 

but there are no low-priced models that qualify for ENERGY STAR (Figure 3.2.8).
3-35

Figure 3.2.4 2007 Manufacturer-Suggested Retail Price Distribution of Side-Mount 

Refrigerator-Freezers with and without ENERGY STAR (2007$)

1000 2000 3000 4000 5000 6000 7000

90

80

70

60

50

40

30

20

10

0

Retail Price per Unit ($)

# of Models

0

1

Estar

Distribution of Side-Mount Refrigerator Models

EStar 0 refers to Non-Energy Star models 1 refers to Energy Star models.
3-36

Figure 3.2.5 2007 Manufacturer-Suggested Retail Price Distribution of Top-Mount 

Refrigerator-Freezers with and without ENERGY STAR (2007$)

Figure 3.2.6 2007 Manufacturer-Suggested Retail Price 

Distribution of Bottom-Mount Refrigerator-Freezers 

with and without ENERGY STAR (2007$)

400 600 800 1000 1200 1400 1600 1800

60

50

40

30

20

10

0

Retail Price per Unit ($)

# of Models

0

1

EStar

Distribution of Top-Mount Refrigerator Models

EStar 0 refers to Non-Energy Star models and 1 refers to Energy Star models.

800 1200 1600 2000 2400 2800

20

15

10

5

0

Retail Price per Unit ($)

# of Models

0 0

0 1

1 0

1 1

Star

Energy

Doors

French

Distribution of Bottom-Mount Refrigerator Models

0 refers to a feature being absent and 1 refers to a feature being present.
3-37

Figure 3.2.6 2007 Manufacturer-Suggested Retail Price Distribution of Upright 

Freezers with and without ENERGY STAR (2007$)

Figure 3.2.7 2007 Manufacturer-Suggested Retail Price Distribution of Chest 

Freezers with and without ENERGY STAR (2007$)

300 600 900 1200 1500

16

14

12

10

8

6

4

2

0

Retail Price per Unit ($)

# of Models

0

1

Star

Energy

Distribution of Upright Freezer Models

0 refers to Non-Energy Star models and 1 refers to Energy Star models.

200 300 400 500 600 700 800

9

8

7

6

5

4

3

2

1

0

Retail Price per Unit ($)

# of Models

0

1

Star

Energy

Distribution of Chest Freezer Models

0 refers to Non-Energy Star models and 1 refers to Energy Star models.
3-38

DOE also performed regression analysis on each of the five product types to estimate the 

incremental price of the different attributes. For the regression analysis, DOE confined the 

sample to models with prices within two standard deviations of the mean value. DOE did this to 

remove outliers from the sample. Removing the outliers lowered the sample size to 92 to 95 

percent of the original size, depending on the product type. Specifically, the side-mount 

refrigerator-freezer sample was reduced from 523 to 502, the top-mount refrigerator-freezer 

sample was reduced from 340 to 321, the bottom-mount refrigerator-freezer sample was reduced 

from 281 to 272, the upright freezer sample was reduced from 54 to 53, and the chest freezer 

sample was reduced from 46 to 43. DOE performed the regression analysis with two types of 

regression equations that it formulated to determine the price increment due to each attribute: (1) 

a ‘basic’ equation where price is a function of only ENERGY STAR qualifying levels (the focus 

variable); and (2) a ‘complete variable’ equation where price is a function of ENERGY STAR

(the focus variable), product attributes (stainless steel, built-in, French doors), and the brand. 

Table 3.2.30 presents the summary results of the regression analysis. The first column in 

the table indicates the product type and the second column presents the ‘constant’ price (i.e., the 

price without any of the attributes under consideration, also referred to as a baseline model) for

each product type. The ‘coefficients’ represent the price adder for a product with a specific 

attribute (i.e., ENERGY STAR, French doors for bottom-mount products, stainless steel cabinet, 

and brand). If the value is positive, than the ‘coefficient’ for the attribute is added to the 

‘constant’ price. If the value is negative, than the ‘coefficient’ for the attribute is subtracted from 

the ‘constant’ price. For example, for side-mount refrigerator-freezers, the ‘coefficient’ for

ENERGY STAR is $208. Therefore, the added retail price of an ENERGY STAR side-mount 

refrigerator-freezer is $208, raising the baseline price from $1128 to $1336. Also presented in 

Table 3.2.30 are the adjusted R-squared value and the number in the sample. In a multiple linear 

regression model, adjusted R square measures the proportion of the variation in the dependent 

variable (retail price) accounted for by the explanatory variables.d

DOE found that the incremental price effect of meeting ENERGY STAR levels is 

significant at a 95 percent confidence level for all product types with the exception of bottommount refrigerator-freezers. In the case of side-mount refrigerator-freezers, qualifying for

ENERGY STAR adds $208 to the price of the baseline model, while for top-mount refrigeratorfreezers it adds $63. These price increments are significantly higher than those from DOE’s 

October 2005 technical report (see Table 3.2.29 above). Because the analysis conducted for the 

2005 technical report was more rigorous (for example, DOE conducted the 2005 retail price 

analysis using sales-weighted point-of-sale data), the price increments for meeting ENERGY 

STAR based on the 2007 manufacturer suggested retail price data are likely not as accurate a 

price indication of meeting ENERGY STAR. Rather, the analysis based on the 2007 prices 

simply confirms that ENERGY STAR products are more expensive than baseline products. In 

the case of upright and chest freezers, the analysis shows that the price increase associated with 

meeting ENERGY STAR is $107 and $121, respectively.

 

d Unlike R squared, adjusted R squared allows for the degrees of freedom associated with the sums of the squares in 

its calculation. Therefore, even though the residual sum of squares decreases or remains the same as new 

explanatory variables are added, the residual variance does not. For this reason, adjusted R square is generally 

considered to be a more accurate goodness-of-fit measure than R square.
3-39

For bottom-mount refrigerator-freezers, meeting ENERGY STAR levels is not a 

significant factor at a 95 percent confidence level. The French door attribute is significant and 

adds over $330 to the price of a baseline unit. This is consistent with the price distributions of 

bottom-mount models presented in Figure 3.2.6 above.

The analysis suggests that stainless steel plays a significant role in the price of sidemount, top-mount, and bottom-mount refrigerator-freezers and upright freezers. The ‘coefficient’ 

of brand suggests an effect similar to stainless steel. Brand is significant for the three 

refrigerator-freezer product types but is not significant in the case of freezers. 

Table 3.2.30 Regression Analysis of the Incremental Price of ENERGY STAR and other 

Attributes based on 2007 Manufacturer-Suggested Retail Prices (2007$)

Product 

Type

Constant

(Baseline)

Coefficients (Price Adder)

Adj 

R2

Number 

in 

Sample

Energy

Star

French 

Door

Stainless

Brand

Frigidaire GE Whirlpool Maytag LG

SideMount $1128 $208 NA $156 -245 $375 -$231 -$252 $431 0.65 502

TopMount $660 $63 NA $97 -$54 $80 $28 $49 NA 0.40 321

BottomMount $1285 -$31* $332 $143 NA $283 -$83 $70 -$212 0.58 272

Upright 

Freezer $495 $107 NA $215 $56* $40* -$41* -$40* NA 0.35 53

Chest 

Freezer $352 $121 NA NA $116* $116* -$100* -$99* NA 0.17 43

* Although numerical values are provided, the regression analysis indicated that these attributes were not significant 

factors in determining the incremental product price at a 95 percent confidence interval.

3.2.8.4 Refrigerator-Freezer and Freezer 2008 Retail Prices

To determine retail prices for the year 2008, DOE drew upon proprietary retail price data 

collected by The NPD Group.

36 These data reflect prices and sales at many retail outlets in the 

United States, representing more than 50 percent of retail sales nationwide. The data include 

model number, refrigerated volume, configuration of doors and ice-making, and whether the unit 

is an ENERGY STAR product. Based on these data DOE developed a sales-weighted price 

distribution for non-ENERGY STAR appliances for seven of the 20 product classes.

e

 Additional 

details about this price data are provided in Chapter 8 of this TSD. The average baseline retail 

prices before sales tax for each of the seven product classes are shown in Table 3.2.31. With the 

exception of product class 3 (top-mount refrigerator-freezers), the retail prices in Table 3.2.31 

are relatively close to the manufacturer-suggested retail prices in Table 3.2.30.

 

e DOE assumed that prices for non-ENERGY STAR models are a reasonable approximation of prices for the 

baseline models.
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Table 3.2.31 Residential Refrigeration Products: Average Baseline Retail Price

Product Class Baseline Retail Price

2008$

Product class 3: Top-mount refrigerator-freezer 1,005

Product class 5: Bottom-mount refrigerator-freezer 1,313

Product class 7: Side-by-side refrigerator-freezer with TTD* 1,333

Product class 9: Upright freezer 469

Product class 10: Chest freezer 483

Product class 11: Compact refrigerator 151

Product class 18: Compact freezer 193

* Through-the-door ice service.

3.3 TECHNOLOGY ASSESSMENT

This section provides a technology assessment for refrigerators, refrigerator-freezers, and 

freezers. Contained in this technology assessment are details about product operations and 

components (section 3.3.1), an examination of possible technological improvements for each 

product (section 3.3.2), and a characterization of the product efficiency levels currently 

commercially available (section 3.3.3).

3.3.1 Product Operation and Components

This section provides a brief description of the components and operation of refrigerators, 

refrigerator-freezers, and freezers. These descriptions provide a basis for understanding the 

technologies used to improve product efficiency.

3.3.1.1 Product Operation

Refrigerators, refrigerator-freezers, and freezers are household appliances designed for 

the refrigerated storage of food products. Definitions for these product types and their operating 

temperature ranges are discussed in section 3.2.1.

Figure 3.3.1 shows a schematic representation of a typical refrigeration circuit used in 

residential refrigeration products. As described by the American Society of Heating, 

Refrigerating and Air-Conditioning Engineers (ASHRAE) Refrigeration Handbook,

37 the 

refrigeration process consists of the following steps:

1. Electrical energy is supplied to a motor that drives a compressor, which draws cold, lowpressure refrigerant vapor for the evaporator and compresses it.

2. The resulting high-pressure, high-temperature discharge gas then passes through the 

condenser, where it is cooled to saturation condition, condensed to a liquid, and possibly 

subcooled while heat is rejected to the ambient air.

3. Liquid refrigerant passes through a metering (pressure-reducing) capillary tube to the 

evaporator, which is at low pressure.
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4. The low-pressure, low-temperature liquid in the evaporator absorbs heat from its 

surroundings, evaporating to a gas, which is again withdrawn by the compressor.

Figure 3.3.1 Refrigeration Circuit

In Figure 3.3.1 above, the metering or flow control device pictured is a non-adiabatic 

capillary tube. In this configuration, the capillary tube is soldered to the suction line to evaporate 

the residual liquid in the suction line and warm the vapor. This suction line heat exchanger (or 

the non-adiabatic capillary) increases the refrigeration capacity of the system by the amount of 

heat being transferred from the capillary to the suction side. Non-adiabatic capillary tubes are the 

most common type of metering device in refrigerator-freezers. The other type of metering 

device, an adiabatic capillary tube, is used in some refrigeration products. In this configuration, 

the capillary tube does not exchange heat with the suction line and the refrigerant expands from 

the high pressure to the low pressure adiabatically.

3.3.1.2 Primary Components

The illustration in Figure 3.3.2 (from RemodelGuide.com38) shows the components and 

layout of a typical top-mount refrigerator-freezer. The components and layout are similar in sidemount and bottom-mount refrigerator-freezers. Freezers also have a similar layout and 

components, but are slightly less complicated due to the fact that they have no fresh food 

compartment. The text that follows describes the following operations or components: automatic 

defrost, cooling, temperature control, lighting, ice maker, ice and water dispenser, and door seals 

and hinges.

CONDENSER EVAPORATOR

COMPRESSOR

SUCTION LINE

CAPILLARY TUBE

HEAT EXCHANGER

STRAINER-DRIER
3-42

Source: RemodelGuide.com

Figure 3.3.2 Top-Mount Refrigerator-Freezer Components

Automatic defrost

Almost all standard-size refrigerator-freezers are self-defrosting. Manual defrost is still 

used in chest freezers, some upright freezers, and in compact refrigerators and freezers. Selfdefrosting refrigerator-freezers and freezers automatically melt frost that accumulates in the 

freezer compartment. The typical automatic defrost system has three functional components: a 

defrost timer, a defrost heater, and a defrost thermostat.

• Defrost timer: The timer is a clock that is energized with the compressor. The timer 

initiates defrost after a set interval of compressor operation, typically twelve hours.

• Defrost heater: The defrost heater is an electric resistance heating element. It is located 

just beneath or on the side of the evaporator coil, which is concealed behind a panel in the 

freezer compartment. The heater melts any ice or frost that builds up. A heater is 

typically also energized in the drip pan to prevent freeze of melted condensate and 

clogging of the drip pan drain.
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• As the frost and ice melt, the resulting water drips into a drip pan. The pan is connected 

to a tube that drains the water into a shallow pan at the bottom of the refrigerator-freezer

or freezer. The water is then evaporated by air which is drawn by a fan through the 

condenser and over the compressor shell. In some products which do not use forced 

convection condensers, particularly freezers, a special pan is mounted on top of the 

compressor shell and the water is evaporated using heat from the compressor.

• Defrost thermostat: The process ends when the defrost thermostat mounted on the 

evaporator tubing senses that a sufficiently high temperature has been attained.

Cooling

All residential refrigerators, refrigerator-freezers, and freezers work by removing heat 

from the air in the cabinet. They all have the key components shown in Figure 3.3.1: a

compressor, a condenser, a metering or flow control device (usually a capillary tube), and an 

evaporator.

• Compressor: The compressor compresses refrigerant, providing the energy input 

necessary to drive the cycle. In most residential refrigeration products, the compressor is 

located at the bottom rear of the unit. In built-in refrigerator-freezers the compressor is 

often located on top of the refrigerator behind a grill or grate. The compressor runs 

whenever the refrigerator thermostat calls for cooling. 

• Condenser: The condenser is a heat exchanger located on the outside of the unit. The 

three most prevalent condenser configurations are as follows: 

– Forced-convention condensers use fans to move air through them to provide cooling.

These condensers are usually located under the unit near the compressor. They can be 

fabricated of steel tubes with steel wire fins or copper tubes with aluminum fins.

– Natural convection “static” condensers which don’t use fans are mounted to the back 

of the unit. They generally have steel tubes and steel wire fins.

– Hot wall condensers are integrated into the outer shell of the unit. A serpentine of 

tubing is attached to the inside of the shell and provided with good thermal contact to 

the shell. This is the common configuration in freezers and it is common in compact 

refrigerators.

• Metering or Flow Control Device (Capillary Tube): The metering device in most 

household refrigerator-freezers is a capillary tube. As discussed above in section 3.3.1.1, 

there are two common types of capillary tubes—adiabatic and non-adiabatic, although 

non-adiabatic are the most common. The capillary tube controls the pressure and flow of 

the refrigerant as it enters the evaporator.

• Evaporator: The evaporator is a heat exchanger located inside the unit. Similar to the 

condenser, there are three main configurations for evaporators:

– Forced convection evaporators use fans to move air through them to provide cooling.

They are constructed of aluminum tubes and aluminum fins or copper tubes and 

aluminum fins. They are generally located on the rear wall of the freezer 
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compartment behind a panel. They can also be located in the mullion separating the 

freezer and fresh food compartments, as shown in Figure 3.3.2. The evaporator fan 

circulates air through the evaporator and into both the freezer and fresh food

compartments. Because the evaporator absorbs heat, it is very cold, thereby causing 

any water vapor in the air to freeze on it as frost. Most refrigerator-freezers using this 

type of evaporator employ automatic defrost.

– Roll bond evaporators fabricated from layers of aluminum sheet primarily use natural 

convection cooling. The refrigerant passages are formed into the evaporator walls.

They are used in single-door refrigerators and are configured either as a flat plate at 

the rear of the cabinet or a rectangular box. In the latter configuration, the interior of 

the box is the freezer compartment. While these evaporators generally use natural 

convection and do not use an evaporator fan, some products with rear-mounted flat 

roll bond evaporators use fans for performance enhancement. Manual defrosting is 

required to defrost these evaporators.

– Cold wall evaporators are integrated within the walls of the freezer. This 

configuration is used in nearly all chest freezers and in many upright freezers. The 

evaporator consists of tube serpentines attached to the insulation side of the cabinet 

interior liner. These evaporators use natural convection heat transfer.

Temperature control

All refrigerators, refrigerator-freezers, and freezers have a thermostat or electronic 

temperature control to maintain the proper temperature. Thermostats are mechanical devices

which interrupt the electricity connection to the compressor when the temperature is sufficiently 

low. Electronic control systems generally use thermistors as temperature sensors, using relays 

mounted on the circuit boards to activate the compressor and other components such as the 

evaporator and condenser fans.

Lighting

Refrigerators, refrigerator-freezers, and freezers with internal lighting normally have only 

one functional lighting component—the switch—which is usually a white push-button mounted 

to be depressed by operation of the door. Closing the door turns off the light. Refrigerators 

traditionally used standard appliance incandescent light bulbs, but many new designs are using 

LED lighting.

Ice maker

Many standard-size refrigerator-freezers come equipped with an ice maker, and nearly all 

are convertible to installation of an ice maker. The ice maker is a located within the freezer

compartment. Ice maker systems have two basic functional components: the icemaker itself, and 

the water fill valve. The most common ice makers operate as follows:

• The ice maker sends a signal to the water fill valve (normally located on the outside back 

of the refrigerator, near the bottom) to open and let water into the ice maker tray (or 

mold). Water fill control is usually by timed opening of the valve (usually 7-10 seconds).
3-45

• When the ice has frozen and reached a sufficiently low temperature (10 to 15 °F), sensed

with a thermostat located in thermal connection with the ice tray, the ice maker begins to 

harvest (eject) the cubes.

• To harvest the cubes, the ice maker first turns on a small heater beneath the tray. The 

heater warms the tray, to help release the ice cubes. Then a sweep fork rotates and pushes 

the cubes up and out of the tray.

• While the ice maker is dumping the cubes into a the ice storage bin, a metal wire similar 

to a coat hanger swings up to let the cubes drop below it. When the cubes have dropped, 

the wire rotates back down. If the holding bin is full of ice, the wire rotate far enough, 

which stops further production of ice. If the sensing wire can rotate down fully, the ice 

maker refills with water and repeats the process.

Ice and water dispenser

Many standard-size refrigerator-freezers have a through-the-door (TTD) ice and/or water 

dispenser. There are several different systems for delivering ice and water through the 

refrigerator door. What follows is an explanation of the common attributes of all of the systems.

• Ice dispenser: For a refrigerator-freezer to provide ice through the door, the ice maker 

first dumps the ice it produces into a large bin, as discussed above. To request ice at the 

door, the user presses a lever that activates a switch. The switch turns on a motor that 

rotates an auger which pushes ice out of the bin, through a chute to the user. Some 

dispensers also have blades which chop the ice to allow delivery of crushed ice.

• Water dispenser: The water dispenser is activated much like the ice dispenser. To request 

water at the door, the user presses a lever on the front of the refrigerator that activates a 

switch. The switch turns on an electric water valve at the back of the refrigerator-freezer. 

Water flows through the valve into a tube, then flows into a reservoir located in the fresh 

food compartment in which the water is chilled. As new water enters the reservoir, the 

water that is displaced flows through a separate tube through the dispenser.

Door Seals 

All refrigerator, refrigerator-freezer, and freezer doors have a seal—a vinyl gasket 

attached to the door(s). The seal prevents infiltration of warm ambient air into the cabinet. The 

seal is lined with a magnet which helps to hold the door closed and create a tight seal. The 

magnetic portion of the gasket is aligned to face the steel extension of the cabinet’s external shell 

which wraps partially around the front face of the cabinet. Some gasket systems use opposing 

magnets on the cabinet side to improve door sealing force.

3.3.2 Technology Options

Table 3.3.1 lists the technology options for improving the efficiency of residential 

refrigeration products. The technology options are categorized by their associated component or 

system. Each technology option category and the options available for improving the component 

or system category are discussed below.
3-46

Table 3.3.1 Technology Options for Refrigerators, Refrigerator-Freezers, and Freezers

Insulation Expansion Valve

Improved resistivity of insulation Improved expansion valves

Increased insulation thickness Cycling Losses

Vacuum-insulated panels Fluid control or solenoid valve

Gas-filled panels Defrost System

Gasket and Door Design Reduced energy for automatic defrost

Improved gaskets Adaptive defrost

Double door gaskets

Improved door face frame Condenser hot gas

Reduced heat load for TTD feature Control System

Anti-Sweat Heater Temperature control

Condenser hot gas Air-distribution control

Electric heater sizing Other Technologies

Electric heater controls Alternative refrigerants 

Compressor Component location

Improved compressor efficiency

Variable-speed compressors Alternative Refrigeration Cycles

Linear compressors Lorenz-Meutzner cycle

Evaporator Dual-loop system

Increased surface area Two-stage system

Improved heat exchange Control valve system

Condenser Ejector refrigerator

Increased surface area Tandem system

Improved heat exchange Alternative Refrigeration Systems

Force convection condenser Stirling cycle

Fans and Fan Motor Thermoelectric

Evaporator fan and fan motor improvements Thermoacoustic

Condenser fan and fan motor improvements

3.3.2.1 Insulation

The primary thermal load on a refrigerator or freezer is the heat transfer through the walls 

and doors into the cabinet. In one study of an 18.6 ft3 top-mount refrigerator-freezer, the wall and 

door heat loads were estimated to account for almost 60 percent of the total thermal load.39

Nearly all residential refrigeration products use polyurethane (PU) foam insulation for 

both the cabinets and the doors. Through the 1980s, CFC-11, a chlorofluorocarbon (CFC), was 

used as a blowing agent in almost all PU foam insulation. However, under the Montreal Protocol, 

all CFCs were banned from use by the mid 1990s due to their high ozone depletion potential 

(ODP). In the 1990s, most manufacturers adopted use of HCFC-141b, a

hydrochlorofluorocarbon (HCFC), which has significantly less ODP. However, because HCFC141b has non-zero ODP, it was banned from production in the U.S. after January 1, 2003. In 

response to the phase-out of HCFC-141b, AHAM’s Appliance Research Consortium (ARC) 

investigated several alternatives, including two hydrofluorocarbons (HFCs), HFC-134a and 

HFC-245fa, and cyclopentane, a hydrocarbon (HC). HFCs and HCs both have zero ODP. HCs 

have a much lower global warming potential (GWP) than HFCs, but they are flammable. ARC, 

DOE, and EPA sponsored research at Oak Ridge National Laboratory (ORNL) to determine the 
3-47

thermal conductivities of the three alternatives and of HCFC-141b. Based on thermal 

conductivity, ORNL identified HFC-245fa as the most attractive substance because it had the 

lowest energy penalty relative to HCFC-141b (see Table 3.3.2).40 In addition, accelerated 

lifetime performance tests conducted by ORNL indicated that the thermal conductivity of HFC245fa foam insulation increases by a smaller percentage than either HFC-134a or cyclopentane

foams. Finally, despite the fact that HCs are used in Europe, flammability and volatile organic 

compound concerns led ARC to determine that HFCs were a more suitable replacement blowing 

agent.41 As a result, many manufacturers are currently using HFC-245fa blowing agent for PU 

foam insulation. However, refrigerators and freezers sold in the U.S. also are using HFC-134a, 

cyclopentane, and HCFC-141b blowing agent. The HCFC blowing agent is still allowed for 

refrigerators imported into the U.S. 

Table 3.3.2 Thermal Conductivity of Freshly-Sliced Foam Specimens at 75 oF (23.9 oC)

Blowing Agent

Slice Thickness

0.4 inch (1.0 cm) 1.5 in (3.8 cm)

Btu-in/hr-ft2-oF mW/m-K Btu-in/hr-ft2-oF mW/m-K

HCFC-141b 0.132 19.0 0.128 18.4

HFC-245fa 0.138 19.9 0.132 19.0

Cyclopentane 0.150 21.6 0.145 20.9

HFC-134a 0.160 23.1 0.155 22.3

Source: ORNL, 2003.40

Improved Resistivity of Insulation

Past research has investigated improving the resistivity of PU foam insulation through the 

use of additives in the foam.

Research conducted in 1996 demonstrated that adding carbon black provides a means of 

improving the thermal insulation properties of PU foam. The research showed that PU foam 

systems using carbon black in conjunction with either HCFC-141b or cyclopentane was able to 

lower k-factors by six to nine percent in panels and in cabinets.42

Increased Insulation Thickness

Based on DOE’s 1995 technical support document (TSD) for refrigerators, refrigeratorfreezers, and freezers, the insulation thickness range for refrigerator-freezers in the mid-1990s 

was 1.5 to 2.75 inches (3.81 to 7.0 cm) in the doors and 1.5 to 3 inches (3.81 to 7.62 cm) in the 

cabinet walls. Walls of freezers and freezer compartments tended to be near the higher end while 

walls of refrigerators and fresh food compartments were nearer the lower end.43

Also based on the DOE 1995 TSD, adding 0.5 to 1 inch (1.27 to 2.54 cm) more insulation 

increases the overall efficiency of the product. Energy reductions associated with these wall 

thickness increases range from a few percent to over 10 percent. Therefore, DOE considered the 

addition of more insulation as a technology option to improve efficiency. Although the 

technology to implement this change is readily available, manufacturers indicated during the 

rulemaking leading to the April 27, 1997 final rule establishing the current minimum efficiency 

levels that adding insulation would not be the first technology option they would choose to 

improve efficiency. Significant investments would be required in foaming systems, tooling, and 
3-48

molding to accommodate thicker insulation. Increased packaging and shipping costs must also be 

considered. Greater insulation thickness results in either decreased interior volumes, increased 

exterior dimensions, or some combination of both. Since kitchen dimensions and designed 

spaces for refrigerator-freezers are limited, there are restrictions on increasing the exterior size of 

the product. Reducing interior volume is considered undesirable because it impacts consumer 

utility.

Vacuum-Insulated Panels

Vacuum-insulated panel (VIPs) technology is based on the reduction in conductivity 

which occurs in a low vacuum, the same concept which is used to reduce heat leakage in thermos 

bottles. VIPs used in refrigeration products consist of a sealed package with a fill material which 

provides support to prevent the panel from collapsing and interferes with molecular mean free 

path as the intermolecular spacing increases at lower vacuum levels. VIPs can be foamed in 

place between the cabinet liner and wrapper to decrease the heat leakage and energy required to 

maintain the cabinet at low temperature. Different configurations are commercially available 

through advances in manufacturing technologies. As a result, VIPs are available in a variety of 

geometries (e.g., flat, curved, cylindrical) with added features (e.g., holes, cut-outs).44 Typical 

VIPs generally consist of a core material and an airtight envelope. Some VIPs also include

absorber to absorb gas which leaks through the envelope.

Several core materials have been used in the manufacture of VIPs including polystyrene, 

open-cell PU, silica powder, and glass fiber. Research sponsored by the European Commission 

has evaluated these core materials based on their cost and characteristics, including density and 

manufacturing time. Table 3.3.3 below summarizes the VIP characteristics manufactured with 

the above core materials.45 Each of the core materials has associated advantages and 

disadvantages that dictate their acceptability for an appliance application.

Table 3.3.3 Comparison of Various VIP Core Materials

Property Polystyrene Open-cell PU Silica Powder Glass Fiber

Thermal Conductivity 

at 10 Pascals (Pa) abs. 

(0.1 millibar (mbar))

(mW/m-K) 4.8 – 5.8 9.7 5.8 2.4

(Btu-in/hr-ft2-oF) 0.033 – 0.040 0.067 0.040 0.017

Manufacturing Time Fast Medium Medium Long

Density (kilogram(kg)/cubic meter (m

3

)) 80 – 144 64 192 128

Drying Need No Yes Yes No

Thermal Stability Low Medium Good Very Good

Recyclability Yes Difficult Yes NA

Cost Low Medium High Very High

Source: European Commission, 2000.45

ORNL also has evaluated the performance of three types of VIPs: a silica powder filler 

encapsulated in a polymer barrier film; a fibrous glass insulation filler encapsulated in a stainless 

steel barrier; and an undisclosed insulation filler encapsulated in a stainless steel barrier.46 Table 

3.3.4 summarizes the center-of-panel thermal conductivities of the panels. For the silica powder

and glass fiber filled VIPs, the thermal conductivities in Table 3.3.4 are comparable to those in 

Table 3.3.3.
3-49

Table 3.3.4 Center-of-Panel Thermal Conductivity of VIPs

Property Silica Powder Glass Fiber Unknown

Thermal Conductivity* (mW/m-K) 5.2 – 5.4 2.0 – 2.6 2.7 – 3.1

(Btu-in/hr-ft2-oF) 0.034 – 0.038 0.014 – 0.018 0.019 – 0.022

* For each filler, the reported thermal conductivities are a range of values from nine separate VIPs.

Source: Vineyard et al, 1998.46

ORNL also determined the thermal performance of the VIPs it studied as part of a 

composite panel. The composite panel consisted of a one-inch VIP surrounded by PU foam 

insulation to form a two-inch-thick panel. The PU foam insulation was blown with a variety of 

bowing agents, but, due to the age of the study (from the mid-1990s), ORNL considered neither 

HFC- nor HC-based blowing agents. For the three VIPs presented in Table 3.3.4, silica power, 

glass fiber, and unknown, the average composite panel thermal resistances were 21.5, 20.7, and 

20.9 hr-ft2-oF/Btu, respectively.46 The lower thermal conductivities reported in Table 3.3.4 for 

the glass fiber and unknown filled VIPs relative to the silica powder VIP were offset by the heat 

conduction through their stainless steel encapsulation material.

Of significant concern for VIPs is their long-term thermal conductivity integrity. VIP

thermal conductivity increases dramatically as the pressure within the VIP exceeds 100 Pa abs. 

(1 mbar). The pressure increase in the VIP over time is related to several factors, including: 

residual gases in the VIP after vacuum, degassing from the VIP core material, and gas diffusion 

through the envelope pores. Improved envelopes and absorbers have been developed to prevent 

pressure increases from occurring in VIPs. For example, for the three composite VIPs that it 

analyzed, ORNL measured only a five-percent reduction in overall thermal resistance over a 

three-year period. ORNL demonstrated that this reduction in thermal resistance was less than the 

corresponding reduction for a panel without any VIPs, i.e., panels consisting only of PU foam 

insulation.46

Recent announcements regarding VIPs include the following. Matsushita’s VIP 

technology (trade name of “U-Vacua”) was awarded the Minister of Economy, Trade and 

Industry Prize at the 17th Energy Conservation Awards sponsored by the Energy Conservation 

Center of Japan in January, 2007.47 Matsushita claims that its VIP technology has achieved the 

world’s highest level of insulation efficiency with a thermal conductivity of 1.2 mW/m-K (0.008 

Btu-in/hr-ft2-oF) at 24 oC (75.2 oF).

48 Electrolux announced in 2003 the use of VIP technology in 

a freezer that they claimed reduced energy use by 35 percent relative to PU foam insulation.49

Va-Q-tek has recently introduced its va-Q-plus VIP technology.50

Gas-Filled Panels

Gas-filled panels (GFPs) use thin polymer films and low-conductivity gas to create a 

device with excellent thermal insulation properties. GFPs are essentially hermetic plastic bags 

that can take on a variety of shapes and sizes. Inside the outer barrier is a cellular structure called 

a baffle which is filled with the low-conductivity gas.

Research conducted at LBNL in the mid-1990s has demonstrated the effectiveness of 

GFPs based on the use of different gases, including xenon and krypton. Table 3.3.5 below 

summarizes the thermal performance characteristics of different GFPs, based on their center-of-
3-50

panel and whole-panel performance.51 LBNL has also conducted research to demonstrate that 

GFPs, when used in refrigerator-freezers, can reduce energy consumption by approximately 

eight percent relative to PU foam insulation.52

Table 3.3.5 Comparison of Various Gas-Filled Panel Core Materials

Gas Fill

Center of Panel 

Performance Whole Panel Performance

Thermal Conductivity Panel Thickness Mean Temp. Thermal Conductivity

mW/m-K Btu-in/hr-ft2-oF mm inches oC oF mW/m-K Btu-in/hr-ft2-oF

Xenon 7.4 0.051 24.1 0.95 6.8 44.2 7.4 0.051

Krypton 11.6 0.080 25.2 0.99 11.9 53.4 10.77 0.074

49.8 1.96 12.3 54.1 1.17 0.008

Argon 19.9 0.138 NA NA NA NA NA NA

Air 28.1 0.195 NA NA NA NA NA NA

Source: LBNL51

In addition, ORNL determined the thermal conductivity of an insulation panel containing 

radiation baffles within a polymer barrier film and filled with krypton gas at atmospheric 

pressure. The range of thermal conductivities of nine of these GFPs ranged from 0.088 to 0.092 

Btu-in/hr-ft2

-oF (12.6 to 13.2 mW/m-K). ORNL also analyzed the GFPs as part of a composite 

assembly consisting of a one-inch panel surrounded by PU foam insulation to form a two-inchthick panel. The average composite panel thermal resistance was determined to be 18.2 hr-ft2

-

oF/Btu. Finally, ORNL measured only a five-percent reduction in overall thermal resistance over 

a three-year period, which was less than the reduction observed in a panel consisting only of PU 

foam insulation.46

Although research has demonstrated that GFPs have better thermal performance than PU 

foam insulation, no known refrigeration products are using the technology. A significant problem 

in using GFPs is their lack of structural integrity in the resulting product.

3.3.2.2 Gasket and Door Design

A significant portion of the heat gain to refrigerators and freezers occurs around the edges 

of the doors and through the gaskets on the door edges. An analysis of thermal loads on an 18.6 

ft3 top-mount refrigerator-freezer revealed that over 28 percent of the total heat load into the 

cabinet came from ‘edge’ loads, i.e., loads due to heat transfer into the food compartments via 

paths around the perimeter of the cabinet aperture.39 Table 3.3.6 summarizes the various ‘edge’ 

loads as well as the heat loads through the walls and doors and other sources. If the ‘edge’ effect 

losses can be reduced, the efficiency of the refrigerator can be increased. This section only 

addresses the ‘edge’ effect loads from the wall and door flanges and the door gasket. Heat loads 

from the anti-sweat heaters are discussed in the following section (section 3.11.2.3).
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Table 3.3.6 Overall Cabinet Loads

Component Percent of Total

‘Edge’ Effect Loads 28.5%

Heat gain due to conduction along the wall steel flange 5.3%

Heat input due to conduction along the door steel flange 7.1%

Heat conduction directly through the door gasket or seal 2.7%

Heat input due to conduction in the mullion region 1.7%

Heat input due to mullion region anti-sweat heater 7.7%

Heat input due to cabinet anti-sweat condenser tube 4.0%

Wall and Door Loads 59.1%

Miscellaneous Loads (heat inputs due to evap fan, defrost heaters, and compressor) 12.4%

Source: Boughton et al, 1996.39

Improved Gaskets

Design of door gaskets is a balance between improving the thermal-efficiency 

performance of the gasket and ensuring that the door is not difficult to open. If the gasket magnet 

force is too strong, it becomes difficult to open the door. Based on a European Commission 

study, door handles have been designed specifically to facilitate door openings by providing 

leverage and relieving the pressure differential which can build up by freeing a small section of 

the gasket before the door is opened.45 Although materials and designs for improving the air 

tightness of door gaskets exist, apparently no general criteria have been established to enable 

different designs to be classified.

An EPA report from 1992 describes theoretical modeling and experimental research on 

gasket heat loads and concludes that replacing about half of either the metal door flange or 

cabinet flange with plastic can reduce the heat flow through the gasket region by 25 percent.53

43

However, this study did not address the impacts on the convection on the cabinet side of the 

gasket associated with different geometries of the “throat” region between the door dikes and the 

cabinet wedge or with different evaporator air flow rates. Based on DOE’s 1995 TSD, 

improvements in gasket design can reduce refrigerator-freezer annual energy consumption by 

one to three percent. Due to the age of both the EPA and DOE research, it is uncertain how 

much further gaskets can be improved.

Double Door Gaskets

A double door gasket is an additional inner door seal gasket that is added to the gasket 

design. This further reduces heat leakage and infiltration into the refrigerator and freezer.

Based on information drawn from DOE’s 1995 TSD, manufacturers did not introduce 

double door gaskets in the mid-1990s because of performance problems and cost. Ice can form 

between the gaskets, greatly reducing their effectiveness. In addition, the gaskets are visually 

unattractive and they increase the difficulty of meeting safety regulations for minimum dooropening force.
3-52

Improved Door Face Frame

As discussed above, cabinet heat loads stem not only from conduction though the 

refrigerator walls but also from conduction along the external metal casing. The metal shell 

provides the structural integrity; however, its presence means that heat loads are transferred 

along the metal shell into the cabinet. This heat transfer into the cabinet is also referred to as the 

‘edge effect.’

Using a plastic cover on the internal flange can reduce the ‘edge effect’ heat losses by 

approximately 50 percent.39 It is expected that the use of low-conductivity plastics to reduce 

conduction losses in this area are already being employed in most current U.S. refrigeratorfreezer designs.

Reduced Heat Load for TTD Feature

Through-the-door features that provide ice and/or water service displace insulation in the 

door. These features can make it difficult to apply foam in the doors. This technology option, 

which is applicable only to those product classes that include TTD ice service, utilizes improved 

design methods to reduce the heat load of TTD features.

Based on the DOE 1995 TSD, door-design improvements that reduce the heat load from 

TTD features can reduce refrigerator-freezer annual energy consumption from two to four 

percent.43 The TSD provided little explanation of the details of these design changes, citing only 

“foam insulation” and “improved design methods”.

3.3.2.3 Anti-Sweat Heater

Anti-sweat heaters are commonly used in standard-size refrigerator-freezers. In general, 

compact refrigerators, compact refrigerator-freezers, and compact freezers do not use anti-sweat 

heat. These heaters apply heat to external surfaces near door gaskets, including the mullion 

region between the freezer and fresh food compartments and along the perimeter of the cabinet.

If electric resistance heaters are used for this purpose, the heaters contribute to energy 

consumption both with their wattage input and with the heat load they generate that enters the 

cabinet. Most modern refrigerator-freezers use refrigerant tubes inserted in the cabinets in close 

proximity to the regions requiring heat. Both hot discharge gas from the compressor and warm 

liquid leaving the condenser are used to provide this heat, although a majority of products use 

warm liquid. As reported above in section 3.11.2.2, the heat loads from both electric and 

refrigerant type anti-sweat heaters can be significant. For the example illustrated in Table 3.3.6, 

the contribution of the mullion anti-sweat heater represents 7.7 percent of the total cabinet heat 

load. However, the load associated with the anti-sweat heater of modern designs may be lower 

due to evolution of design practices to reduce such loads.

Hot Gas or Warm Liquid

The direct electricity consumption of the anti-sweat heaters can be eliminated by using a 

hot gas or warm liquid refrigerant loop to warm external surfaces to eliminate moisture buildup.

This approach is used extensively in residential refrigerator-freezers to reduce energy use—the 

technology is already part of all or nearly all standard-size refrigerator-freezers.
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Electric Heater Sizing

For those products using electric resistance anti-sweat heaters, unnecessarily highwattage heaters may be used. Therefore, energy use can be decreased by reducing the heater 

wattage. For those products that still use electric resistance anti-sweat heaters, DOE is unaware 

to what extent the wattage of the heater is excessive.

Electric Heater Controls including Variable Antisweat

For those products using electric resistance anti-sweat heaters, control schemes can be 

used to limit the amount of energy used. One option, which is included on some current 

refrigerator-freezer models, is to use an on-off switch that allows the user to turn off the heater if 

“sweating” is not an issue. The DOE Energy test procedure calls for testing with the switch in the 

on position in order to measure annual energy use.54 However, DOE understands that most 

manufacturers measure annual energy use as an average of a test with the heater on and a test 

with the heater off.

Another option is to control the anti-sweat heater based on temperature and humidity 

conditions. As discussed in section 3.2.2, DOE is considering incorporating into the test 

procedure for refrigerators and refrigerator-freezers an adaptation of a test procedure for which a 

waiver was granted to GE. The waiver provides a method for calculating the annual energy use 

contribution of electric anti-sweat heaters which are controlled to operate only as much as 

needed to avoid moisture accumulation, based on the input of ambient temperature and/or 

humidity sensors. 73 FR 10425 (February 27, 2008)

3.3.2.4 Compressor

The compressor is the primary energy-consuming component in a refrigerator, 

refrigerator-freezer, or freezer. Therefore, technologies that can advance compressor efficiency 

have a significant effect on overall product efficiency.

Residential refrigeration products use positive-displacement compressors in which the 

entire motor-compressor is hermetically sealed in the welded steel shell. Two types of 

compressors have been used in residential refrigeration products over the years—reciprocating 

and rotary. However, predominantly reciprocating compressors are now used in U.S. products.

Almost all compressors are directly driven by two-pole squirrel-cage induction motors

running at approximately 3,000 rpm on 60 Hz power. Three types of induction motors have been 

used in refrigerator compressors: resistance start/induction run (RSIR), capacitor start/induction 

run (CSIR), and resistance start/capacitor run (RSCR). Of the three motor types, the RSIR motor 

is the least efficient. As a result of the U.S. energy efficiency standards that took effect in 1993

and 2001, the vast majority of compressor motors now use the RSCR type. 

Refrigerator compressor capacities range from as low as 125 Btu/hr (for compact 

refrigerators) to as high as 2,000 Btu/hr, although maximum capacities are more typically 950 

Btu/hr for U.S. residential refrigerator-freezers. Two organizations have established conditions 

for rating the performance of refrigerator compressors: ASHRAE and Comité Européen des 
3-54

Constructeurs de Matériel Frigorifique (CECOMAF).f Table 3.3.7 below shows the rating 

conditions of these two organizations. The rating conditions are almost identical, except for the 

liquid temperature—this is the temperature leaving the condenser or any subcooling loop such as 

an anti-sweat heating loop. Because the CECOMAF liquid temperature is higher, compressor 

capacities and efficiencies under ASHRAE rating conditions are approximately 30 percent 

higher than for CECOMAF conditions. The actual operating conditions for compressors in 

residential refrigeration products under DOE energy test conditions can be significantly different 

than these rating conditions. Most notably, the condensing temperatures are generally 

significantly lower than 130  ̊F.

Table 3.3.7 Compressor Rating Conditions

Rating Condition ASHRAE CECOMAF

Evaporator -10 oF (-23.3 oC) -10 oF (-23.3 oC)

Condenser 130 oF (54.4 oC) 131 oF (55 oC)

Ambient 90 oF (32.2oC) 89.6 oF (32 oC)

Suction Gas 90 oF (32.2oC) 89.6 oF (32 oC)

Liquid 90 oF (32.2 oC) 131 oF (55 oC)

Compressor efficiency is also a function of refrigeration capacity. Based on data from 

DOE’s 1995 TSD, maximum expected compressor efficiencies for the year 1998 demonstrated 

that efficiency drops off with decreasing cooling capacity.43 The expected maximum compressor 

efficiencies for the year 1998 as reported in the 1995 TSD are shown below in Table 3.3.8

below. A year 2000 European Commission study to support energy standards of domestic 

refrigeration appliances also noted the drop in efficiency as capacity drops.

45 The reduced 

efficiency for lower-capacity compressors has been attributed to optimization of performance for 

higher-capacity compressors55 and to the higher importance of mechanical losses and losses 

associated with re-expansion of gases left in the clearance volume as the swept volume of the 

reciprocating piston decreases.

 

f CECOMAF is a European appliance manufacturer trade association formed in 1958. It merged with EUROVENT 

in 1996 to become EUROVENT/CECOMAF. This organization is now called EUROVENT.
3-55

Table 3.3.8 Estimated 1998 Maximum Compressor Efficiencies

Product Class Served

Capacity Range* Maximum Efficiency by 1998*

W Btu/hr

Coefficient of 

Performance 

(COP)

Energy 

Efficiency 

Ratio (EER), 

Btu/hr-W

The Five Standard RefrigeratorFreezers

220 to 278 750 to 950 1.64 5.60

176 to 205 600 to 700 1.60 5.45

Auto Defrost Upright Freezers 250 to 278 850 to 950 1.64 5.60

Manual Defrost Upright Freezers 161 to 176 550 to 600 1.51 5.15

Manual Defrost Chest Freezers 147 to 161 500 to 550 1.45 4.95

Compacts

117 400 1.38 4.70

103 350 1.26 4.30

59 200 1.04 3.55

41 140 0.76 2.6

Source: DOE, 1995 TSD.

* Performance based on ASHRAE rating conditions. Performance based on the use of refrigerant R-134a.

More recent compressor performance data was collected as part of the engineering 

analysis, and the results of this investigation is presented in Chapter 5. The highest efficiency 

single-speed compressors available for standard-size refrigerator-freezers have EER near 6.25 

Btu/hr-W.

Improved Compressor Efficiency

Conversion to high-efficiency compressors is fairly straightforward for manufacturers to 

implement as long as the appropriate compressors are available. As indicated above, maximum 

efficiencies for compressors that are utilized in the most common types of U.S. refrigeratorfreezers range to near 6.25 Btu/hr-W.

Variable-Speed Compressors

Variable-speed compressors allow efficiency improvement as compared to single-speed 

compressors since they can provide a better match of thermal loads during the vast majority of 

hours when the loads are low. Most of the time, the compressor would operate at low speed with 

a high percentage of on-time. This would lower energy consumption by reducing off-cycle losses

and by allowing the heat exchangers to operate with lower mass flow, thus boosting their 

effectiveness. However, careful consideration must be given to how variable speed compressors 

are implemented, because increased fan run times could negate compressor energy savings.

Electronics are used by variable-speed compressors to vary the speed. They use either inverterdriven induction motors or permanent magnet motors. Most U.S. residential refrigeration 

products do not currently use variable-speed compressors, but the use of these compressors is 

becoming more common. 

Various past studies have illustrated a range of energy savings achievable through use of 

variable speed compressors. Arthur D. Little reported savings of approximately 25 percent 

compared to single-speed motor systems in 1999.

56 Research conducted by Tecumseh Products 

Company demonstrated that energy savings of 15 percent as well as reduction of sound and 
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vibration levels.57 Simulation analyses conducted at the University of Illinois demonstrated that 

steady-energy savings ranging from four to 14 percent could be realized through the use of a 

two-speed compressor in concert with multiple-speed evaporator and condenser fans. The 

research also demonstrated that an additional 0.5 to four percent in energy consumption could be 

saved through the reduction of cycling frequency, i.e. the number of starts.

58

Embraco has developed its third generation variable-speed compressor that utilizes a

permanent magnet motor controlled by a programmable electronic unit.59 Table 3.3.9 presents 

the rated performance of some of Embraco’s variable-speed compressors. The rated efficiencies 

of these variable-speed compressors are not necessarily higher than the best efficiencies of 

single-speed compressors--evaluation of the benefits of variable-speed compressors requires 

consideration of the system performance rather than just rated performance. 

Table 3.3.9 Efficiencies of Some of Embraco’s Variable-Speed Compressor Models

Model

Capacity Range* Efficiency*

W Btu/hr COP EER

VEGY6H (1600-4500 

revolutions per minute (rpm)) 98 – 281 676 – 959 Up to 1.78 Up to 6.07

VEGY7H (1600-4500 rpm) 111 – 314 379 – 1071 Up to 1.81 Up to 6.18

VEGY8C (1600-4000 rpm) 132 – 319 450 – 1088 Up to 1.79 Up to 6.11

Source: Embraco, 2006.

* Performance based on ASHRAE rating conditions. Models utilize refrigerant R-134a.

Linear Compressors

Linear compressors employ a different design than either reciprocating or rotary 

compressors and are reportedly more efficient than either. These compressors use a linear rather 

than rotary motor, thus eliminating the crankshaft and linkage which converts the rotary motion 

to the linear motion of the piston of a reciprocating compressor. Elimination of the mechanical 

linkage reduces friction and side-forces. The linear motor requires power electronics and a 

controller to assure proper piston throw. Most linear compressor designs use a free piston 

arrangement and can be controlled for a range of capacities through adjustment of piston 

displacement. Early work on the concept suggested that the compressors can operate without 

requiring oil, which could provide additional energy benefit by improving heat transfer in the 

evaporator. Refrigerator noise levels can also be reduced by utilizing linear compressors in the 

same way that this can be done with variable-speed compressors, by operating most of the time 

at low capacity.60

An early version of the linear compressor design was developed by Sunpower for 

integration into refrigerators for the European market using isobutene (R-600a) as a refrigerant.61

LG has developed a linear compressor for household refrigerators which does require use of oil.

LG claims that its line of linear compressors is up to 20 percent more efficient than reciprocating 

designs.62 Table 3.3.10 presents the rated efficiencies of LG’s linear compressors.63 LG reports 

the efficiency of its linear compressors only at “LG Reference Conditions,” which are 

significantly different than the ASHRAE rating conditions. Under ASHRAE conditions, 

compressors are rated with evaporating and condensing temperatures of -10oF (-23.3oC) and 

130oF (54.4oC), respectively, while the “LG Reference Conditions” are based on evaporating and 
3-57

condensing temperatures of -14.8oF (-26oC) and 100.4oF (38oC), respectively. It is not clear what 

the liquid and suction vapor temperatures for the LG conditions are—these temperatures also 

impact capacity and power input. At the same evaporating and condensing temperatures and with 

liquid and suction vapor conditions consistent with the ASHRAE test conditions, a high 

efficiency rotating-shaft reciprocating compressor such as the Embraco EGX70HLC would have 

an operating EER of about 6.9 Btu/hr-W. Hence, the LG linear compressor may be about 9% 

more efficient than the best current-technology rotating-shaft reciprocating compressors.

Table 3.3.10 Efficiencies of LG’s Current Linear Compressor Models

Model

Capacity Range* Efficiency*

W Btu/hr COP EER

DLF81LACT 310 1058 2.14 7.3

FA81LACT 293 1000 2.20 7.5

FA72LACT 276 941 2.20 7.5

FA63LACT 241 823 2.20 7.5

FA54LACT 207 706 2.20 7.5

Source: LG, 2007.

* Performance based on ‘LG Reference’ rating conditions. Models utilize refrigerant R-134a.

In the trade press, LG has expressed willingness to license the linear compressor 

technology to competitors.64

3.3.2.5 Evaporator

However, because the LG design is proprietary, the widespread use

of linear compressors is uncertain.

The evaporator is a key component of the refrigeration system. As discussed earlier in 

section 3.11.2, there are three basic evaporator designs depending on the refrigeration product: 

standard-size refrigerator-freezers and upright freezers with automatic defrost typically use a 

forced-convection finned-tube design; compact refrigerators and refrigerator-freezers and smallsize standard refrigerator-freezers generally use a roll-bond design; and chest freezers and 

upright freezers with manual defrost typically use a coil design that is integrated within the walls 

of the unit. Some manual defrost freezers also use evaporators which are integrated with the wire 

shelving. In the case of the finned-tube designs used in standard-size refrigerator-freezers, 

design, modeling, and experimental studies have been conducted to evaluate their heat transfer 

performance.65, 66

Increased Surface Area

Evaporator performance can be enhanced by increasing the heat exchanger 

surface area or improving the heat exchange performance.

Increasing the heat exchanger surface area can be achieved by increasing the face area of 

the evaporator or adding more tube rows. These measures are limited by the geometry of the 

refrigeration product. There is a tradeoff between increasing the volume occupied by the heat 

exchanger and reducing the interior volume of the refrigerator.

In its 1995 TSD, DOE considered increasing the evaporator surface area for most of the 

product classes analyzed; this resulted in an estimated one to two percent reduction in annual 

energy consumption.43 In the 1995 TSD, DOE based cost and efficiency improvements for this 
3-58

technology on estimates by manufacturers. No details were provided on how exactly the 

evaporator surface area was increased. Therefore, it is uncertain to what extent design efforts to 

increase the evaporator surface area have been employed in current U.S. refrigerator-freezer 

designs.

Improved Heat Exchange

Improving heat exchanger performance can be achieved through the use of enhanced fins 

and/or tubes. These types of fin and tube enhancements are common in air-conditioning 

applications where slit and louvered designs are used to enhance the fin surface and different 

types of internally-grooved surfaces are used to enhance the tubing. In its 1995 TSD, DOE 

considered enhancing the evaporator’s heat exchange performance for many of the product 

classes analyzed; this resulted in an estimated one to two percent reduction in annual energy 

consumption.43 In the 1995 TSD, DOE based cost and efficiency improvements for this 

technology on estimates by manufacturers. No details were provided on how exactly the 

evaporator heat exchange performance was enhanced. Therefore, it is uncertain to what extent 

design efforts to enhance the evaporator heat exchange performance have been employed in 

current U.S. refrigerator, refrigerator-freezer, and freezer designs.

Heat exchanger technologies that could potentially improve evaporator performance are

microchannel heat exchangers, electrohydrodynamic enhancement, and the adoption of phasechange materials. In the case of microchannel heat exchangers, past research has demonstrated 

that the use of such heat exchangers in domestic refrigerators can provide system efficiencies 

comparable to current technologies while reducing refrigerant charge.67

45

Electrohydrodynamic 

enhancement employs high-voltage fields to improve the heat exchange performance. However, 

safety issues involved in using such high voltages in domestic appliances have not yet been 

resolved. In addition, no prototypes are available to test and evaluate this technology for 

domestic refrigerators and freezers. Finally, with regard to phase-change materials, Thomson (a 

French manufacturer) has integrated into its heat exchangers a phase-change material that 

enables higher average evaporation temperatures than conventional designs, thereby yielding 

energy savings. It is unclear for any of these technologies whether they will ever achieve 

widespread use in refrigerator-freezers.

Research has also been conducted on the use of a ground-source heat exchanger as a 

means of rejecting heat from the cabinet and improving the efficiency of a refrigerator-freezer.

Although the use of such a design reduced energy consumption considerably, it is likely not 

practical for most domestic refrigeration products.68

3.3.2.6 Condenser

The condenser, like the evaporator, is a key component of the refrigeration system and is 

located on the outside of the unit. As discussed in section 11.1.2, there are three basic condenser 

designs depending on the refrigeration product: Standard-size refrigerator-freezers typically use a 

forced-convection finned-tube design; compact refrigerators and refrigerator-freezers generally 

use a wire-and-tube “static” design which uses natural convection cooling; and freezers typically 

use a hot wall condenser that is integrated within the shell of the unit. In the case of the static 

condensers used in compact units, modeling studies have been conducted to evaluate their heat 
3-59

transfer performance.69 Modeling studies have also been performed on hot-wall condensers.70, 71

Increased Surface Area

Condenser performance can be enhanced by increasing the heat exchanger surface area or 

improving the heat exchange performance.

Increasing the heat exchanger surface area can be achieved by increasing the face area of 

the condenser or adding more tube rows. These measures can be limited by the geometry of the 

refrigeration product. There may be a tradeoff between increasing the volume occupied be by the 

heat exchanger and reducing the interior volume of the refrigerator.

In its 1995 TSD, DOE considered increasing the condenser surface area for many of the 

product classes analyzed; this resulted in an estimated one to two percent reduction in annual 

energy consumption.43 In the 1995 TSD, DOE based cost and efficiency improvements for this 

technology on estimates by manufacturers. No details were provided on how exactly the 

condenser surface area was increased. Therefore, it is uncertain to what extent design efforts to 

increase the condenser surface area have been employed in current U.S. refrigerator-freezer 

designs.

Improved Heat Exchange

Improving heat exchanger performance can be achieved through the use of enhanced fins 

and/or tubes. These types of fin and tube enhancements are common in air-conditioning 

applications where slit and louvered designs are used to enhance the fin surface and different 

types of internally grooved surfaces are used to enhance the tubing. In its 1995 TSD, DOE 

considered enhancing the condenser’s heat exchange performance for some freezer and compact 

unit product classes; this resulted in approximately a two percent estimated reduction in annual 

energy consumption.43 In the 1995 TSD, DOE based cost and efficiency improvements for this 

technology on estimates by manufacturers. No details were provided on how exactly the 

condenser heat exchange performance was enhanced. Therefore, it is uncertain to what extent 

design efforts to enhance the condenser heat exchange performance have been employed in 

current U.S. refrigerator, refrigerator-freezer, and freezer designs.

As with evaporators, other heat exchanger technologies could be employed to improve 

condenser performance. Microchannel heat exchangers, electrohydrodynamic enhancement, and 

the adoption of phase-change materials are all applicable to condensers, although phase-change 

materials have only been used in evaporators. It is unclear for any of these technologies whether 

they will ever achieve widespread use in refrigerator-freezers.

The same research that investigated the use of ground-source heat exchangers as means 

of rejecting heat for the cabinet also examined its application for rejecting heat from the 

condenser. The technology was demonstrated to be effective at reducing the energy use of a 

refrigerator-freezer, but is likely not practical for most domestic refrigeration products.45

Forced-Convection Condenser

Most standard-size refrigerator-freezers use forced-convection condensers. In contrast, most 

standard-size freezers use hot wall condensers. The forced convection configuration can provide 
3-60

higher heat transfer effectiveness. However, space for housing a forced convection condenser 

and its associated fan is not always available. The consideration of conversion to forcedconvection condensers will depend on whether a particular product class is designed in a way 

that allows housing of the condenser and fan in a suitable location.

3.3.2.7 Fan and Fan Motor

Fans are used to increase evaporator and condenser heat transfer. Because most 

refrigerator-freezers use forced-convection condensers which rely on fans for air movement, fan 

and fan-motor technology options for the condenser are applicable. However, many manualdefrost refrigerators and freezers—specifically chest freezers and small, under-counter-type 

refrigerators—use static condensers and/or natural convection evaporators and, as a result, do not 

use fans and fan motors.

For those refrigeration products that do utilize fans, refrigerator manufacturers purchase 

fans and fan motors from outside vendors. Therefore, conversion to more-efficient fan motors 

can be accomplished relatively easily when more-efficient fans and fan motors are available.

Fan and Fan Motor Improvements

Evaporator can condenser fans are typically of axial design. Evaporator fan blades are 

typically either 100mm or 110mm in diameter. Because the evaporator fan and fan motor are 

located within the refrigerated cabinet and the electric energy input adds to the refrigeration load, 

more-efficient evaporator fan or evaporator fan motor designs contribute to efficiency 

improvements in two ways: (1) reducing the power consumption of the fan motor and (2) 

reducing the power consumption of the compressor due to decreased heat losses into the cabinet 

from the fan motor.

One source of inefficiency for axial fans lies in their tendency to throw air outward. The 

Pax GroupTM has developed a fan (PAX fan) that employs streamlined blades with patented 

geometrical shapes which reportedly provide better airflow direction and improved efficiency.

Tests performed with the PAX fan have demonstrated a reduction in fan-motor power of 23 

percent and an overall reduction in refrigerator energy consumption of 3.9 percent relative to a 

refrigerator with a typical axial fan blade design.72 However, because the PAX fan is proprietary, 

the widespread use of the design is highly uncertain.

Before the 1993 U.S. energy efficiency standards took effect, most evaporator and 

condenser fan motors were shaded pole induction designs, with efficiencies between 10 and 15

percent and power input of about 15 Watts (W). Higher-efficiency motor designs include 

permanent split capacitor motors (PSC) induction motors with 20 to 30 percent efficiency, and 

brushless DC motors, with near 65 percent efficiency.

3.3.2.8 Expansion Valve

The metering device in most household refrigerator-freezers is a capillary tube. As 

discussed above in section 11.1.1, there are two common types of capillary tubes—adiabatic and 

non-adiabatic. In the non-adiabatic configuration, the capillary tube is soldered to the suction line
3-61

to evaporate the residual liquid in the suction line and to warm the vapor to near-ambient 

temperature. The suction line heat exchanger (or the non-adiabatic capillary) improves efficiency 

because it increases the refrigeration capacity of the system by the amount of heat being 

transferred from the capillary to the suction side. Non-adiabatic capillary tubes are the most 

common type of metering device in refrigerator-freezers. The other type of metering device, an 

adiabatic capillary tube, is used in some refrigeration products. In this configuration, the 

capillary tube does not exchange heat with the suction line and the refrigerant expands from the 

high pressure to the low pressure adiabatically. Research has been conducted to develop models 

to study the performance of both types of capillary tubes.73, 74

Improved Expansion Valve 

Automatic, adjustable thermostatic or electronic expansion valves may provide improved 

performance. The technology for this design option is available; however, a modification in 

system design is required. DOE has not be able to identify any data demonstrating that improved 

expansion valves will save energy in domestic refrigerators.

3.3.2.9 Cycling Losses

Off-cycle refrigerant migration reduces a refrigeration product’s efficiency by 

transferring heat from outside the cabinet into the evaporator. Changes in refrigerator design that 

reduce this aspect of cycling losses can increase the unit’s efficiency.

Fluid Control or Solenoid Valve

A fluid control or solenoid valve installed after the condenser to effectively isolate the 

evaporator from the condenser during the off-cycle can be used to prevent any refrigerant 

migration. Research has demonstrated that solenoid valves can yield substantial energy 

savings.75

3.3.2.10 Defrost System

However, there are drawbacks to using solenoid valves. First, refrigeration migration 

allows the system pressure to equalize, reducing the required starting torque of the compressor 

motor. A solenoid valve would increase the required starting torque of the compressor motor.

Second, adding such a valve could negatively affect system reliability.

Section 3.11.1.2 provides a description of typical automatic defrost systems for 

refrigerator-freezers. Most units use electric heaters to defrost the ice buildup on the evaporator 

located in the freezer section of a refrigerator-freezer. Energy use associated with defrost 

includes the energy input for the heater and also the refrigeration system energy used to remove 

the defrost heat from the cabinet.

Reduced Energy for Automatic Defrost

In some cases, the defrost heat supplied is more than required. Thus, energy savings can 

be achieved by reducing the defrost heat by either using a smaller heater, reducing the heater ontime, reducing the frequency of defrost, or a combination of these. 

In its 1995 TSD, DOE found that most manufacturers had already significantly reduced 

the electric heat for auto defrost in order to comply with the energy efficiency standards that 
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became effective in 1993.43 There may be limited additional energy savings possible through 

optimization of automatic defrost. 

Adaptive Defrost

To reduce the energy used for defrost, adaptive defrost can be used. An adaptive defrost 

system can control both the defrost time and the amount of defrost heat. Adaptive defrost 

systems make use of controls to adjust the time between defrost cycles to the appropriate amount 

for the door opening frequency, ambient conditions, and other consumer usage patterns which 

affect the introduction of moisture into the cabinet. In a typical automatic defrost system, a 

mechanical timer initiates defrost after a specified time period, usually 10 to 12 hours of 

compressor on-time. By allowing adjustment of the time between defrosts, energy use can be 

reduced. The DOE energy test procedure includes modified test procedures for evaluating the 

energy use of products with adaptive defrost. In its 1995 TSD, DOE estimated that energy 

consumption can be reduced by three to four percent with adaptive defrost.43 It is unclear what 

percentage of the refrigerator market currently uses adaptive defrost.

Condenser Hot Gas

Another method of reducing the energy required for defrost is to eliminate the need for 

electric heaters by substituting condenser hot gas in their place. In a condenser hot gas defrost 

system, the compressor continues to run and a valve opens allowing hot compressed refrigerant 

to flow to the evaporator. Many frost-free refrigerator-freezers in the 1960s and 1970s used such 

a defrost system.

3.3.2.11 Control System

The control systems discussed here pertain to those controlling the temperature and airdistribution within the refrigeration product. 

Temperature Control

Conventional thermostats are thermomechanical devices that are not very accurate. The 

inaccuracy of these devices may produce large temperature fluctuations within the cabinet and, 

in turn, thermodynamic inefficiencies. Electronic thermostats are available that can provide more 

precise and repeatable temperature control than conventional thermostats. This can result in

improved efficiency. Electronic thermostat systems can also account for more parameters than 

just the cabinet temperature, such as the room temperature, to better regulate product operation 

and reduce compressor run times.

Air-Distribution Control

For refrigerator-freezers, better air distribution between the freezer and fresh food 

compartments can improve temperature control and reduce energy consumption. Improving the 

distribution of cold air within the refrigerator-freezer allows the temperature difference between 

the air and foodstuffs to be minimized, enabling the evaporation temperature to be raised and, 

thereby, reducing energy consumption. It is uncertain to what degree the air distribution control 

in current refrigerator-freezer models can be improved. However, the fact that several patents 
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have been issued in the U.S. since 1995 regarding air distribution implies that improvements in 

air distribution control are possible.45

3.3.2.12 Other Technologies

Alternative refrigerants and changing the location of refrigeration components can also 

improve the efficiency of refrigeration products. These two technology options are discussed 

below.

Alternative Refrigerants

Through the 1980s, CFC-12, a chlorofluorocarbon, was used as the refrigerant in almost 

all refrigerators, refrigerator-freezers, and freezers. However, under the Montreal Protocol, all 

CFCs were banned from use by the mid-1990s due to their high ozone depletion potential (ODP).

In the early 1990s, many alternative refrigerants were evaluated as a replacement for CFC-12. Of 

the alternatives considered, the industry settled on HFC-134a as the replacement for CFC-12.

Although initial research demonstrated that HFC-134a as a drop-in replacement yielded 

efficiencies which were four to 10 percent less than CFC-12, further work showed that with the 

appropriate superheat and subcooling taken into consideration, HFC-134a could yield essentially 

equivalent system efficiencies as CFC-12.76

Because HFC-134a exhibits some global warming potential (GWP), research continued 

to find an alternative refrigerant with less or no GWP. For example, R-152a has a lower GWP 

than HFC-134a but, primarily due to flammability concerns and the potential liability issues it 

posed to refrigerator manufacturers, it was dismissed as a potential alternative.

Naturally occurring substances such as carbon dioxide, ammonia, and hydrocarbons are 

all considered to be environmentally safe refrigerants with very low GWP. Hydrocarbons in 

particular are attractive due to their similar thermodynamic properties to CFC-12. Much research 

has been conducted showing the efficiency benefits of hydrocarbons. For example, the 

performance of propane/isobutane and propane/butane mixtures in domestic refrigerators has 

been shown to be equal to or better than products using CFC-12.77, 78 Hydrocarbon flammability 

has been pointed out as a significant drawback and has prevented their adoption in U.S. products.

In contrast, European refrigerator manufacturers started manufacturing products with isobutane 

in the 1990s. However, recently the General Electric Company announced the intention to 

introduce this refrigerant in the U.S.79

Component Location

In its 1995 TSD, DOE saw energy savings potential in more optimal placement of certain 

components. For example, if the compressor and condenser are located on the top of the 

refrigerator-freezer, DOE determined that they can operate more efficiently because heat is more 

readily convected away from the system and, in addition, the condenser fan can be eliminated.

As described previously, traditionally, the compressor and condenser are located at the bottom 

rather than the top of the refrigerator-freezer so the user can have easy access to the food 

compartments, to key center of gravity low, and to provide air flow and a heat source near the 

tray which collects defrost water to assure quick re-evaporation of water. Locating the condenser 

and compressor at the top of the unit would require modification of traditional practice and 
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consumer preference. It would also require product redesign, which could potentially increase 

manufacturing costs.

Another option is to locate the evaporator fan motor outside the cabinet to reduce internal loads 

from the heat loss of the motor. However, it is difficult to prevent air leakage where the motor 

shaft penetrates the cabinet wall. The 1995 TSD concluded that the lack of experimental data 

prevented the evaluation of component relocation.43

3.3.2.13 Alternative Refrigeration Cycles

Alternative refrigeration cycles may have the potential to improve system efficiency.

Several alternative refrigeration cycles for refrigerator-freezers are described below. Dual-loop 

refrigerator-freezers using two independent refrigeration cycles (one for the fresh food 

compartment and the other for the freezer compartment) are available on the market. Also, dualevaporator units likely utilizing a control valve system are also being marketed. The other 

alternatives listed below have been demonstrated in prototypes to reduce energy consumption but 

it is uncertain as to whether they can be mass produced as a practical alternative to today’s 

current conventional refrigeration systems.

Lorenz-Meutzner Cycle

In a conventional refrigerator-freezer, the temperature of the freezer and fresh food 

compartments are around 5oF (-15oC) and 38oF (3.3oC), respectively. This suggests that the fresh 

food compartment with a smaller temperature lift (i.e., the temperature difference between the 

evaporator and condenser) can operate with a higher efficiency than that of the freezer. By using 

zeotropicg refrigerant mixtures, the Lorenz-Meutzner cycle exploits the inherent thermodynamic 

advantages of the temperature glide exhibited during evaporation or condensation of the 

refrigerant mixture. By choosing a refrigerant mixture with very wide temperature glide, the 

refrigerant mixture can pass sequentially through the freezer and fresh food compartment 

evaporators, providing refrigeration at the two evaporating temperature levels using a single 

compressor. As compared to a conventional refrigerator-freezer, the hardware differences 

include a high-temperature evaporator for the fresh food compartment and a low-temperature 

heat exchanger between the fresh food and freezer evaporators. Lorenz and Meutzner in their 

research determined that their cycle using an R-22/R-11 refrigerant mixture (50 percent of each) 

achieved up to 20 percent energy savings compared to a conventional refrigerator-freezer using 

R-12 only.

80

Subsequent research validated Lorenz and Meutzner’s findings and demonstrated the 

viability of the cycle based on the use of different zeotropic refrigerant mixtures, including 

mixtures composed of hydrocarbons. For example, as compared to a conventional refrigeratorfreezer, experimentation on an 18 ft3 top-mount refrigerator-freezer demonstrated that a modified 

 

g A zeotropic mixture consists of two or more refrigerant components. Zeotropic mixtures have what is referred to as 

a temperature glide when they boil and condense: at a fixed pressure, the temperature is higher for higher quality 

(i.e. vapor fraction). Unlike zeotropes, azeotropic mixtures consist of two or more refrigerant components that 

behave like a single refrigerant, exhibiting no temperature glide.
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Lorenz-Meutzner cycle yielded 16.6 percent, 14.6 percent, and 16.7 percent energy savings with 

binary mixtures of R-22/R-123, propane/n-pentane, and propane/n-butane, respectively.81

Because the industry settled on the use of HFC-134a to replace CFC-12, interest in the

Lorenz-Meutzner cycle as an alternative to conventional refrigeration cycles declined.

Dual-Loop System

One of the best methods to reduce the thermodynamic irreversibilities resulting from the 

operation with a single evaporator in a refrigerator-freezer is to employ two separate 

refrigeration cycles. This system, referred to as a dual-loop system, has two completely separate 

refrigeration cycles which provide cooling for the freezer and fresh food compartments 

independently. In practice, the theoretical benefits of such a cycle are not achieved due to the use 

of two compressors that are smaller and less efficient than the original single compressor. Also, 

dual-loop systems are physically larger and would either increase the product’s external 

dimensions or decrease the usable refrigerator volume.

Research has demonstrated that the energy savings due to a dual-loop system are a 

function of the cabinet load ratio (defined as the ratio of the fresh food to the freezer cabinet 

loads) and the ratio of the freezer and refrigerator cycle efficiencies. Depending on these two 

parameters, a dual-loop system using HFC-134a can reduce energy consumption by up to 30 

percent compared to a conventional refrigerator-freezer.82

There are numerous products currently on the market that incorporate dual-compressor 

systems, including Bosch’s Integra line of bottom-mount refrigerator-freezers,

83 Sun Frost’s 

RF19 model,84 Northland’s 48-inch side-mount refrigerator-freezer,85 Sub-Zero’s built-in line of 

refrigerator-freezers,

86 Liebherr refrigerators,87

Two-Stage System

etc. 

The two-stage system employs one condenser, two evaporators, two compressors, and at 

least one suction-line heat exchanger. The increased efficiency of this system over a 

conventional system is obtained due to a smaller work requirement that results from the lowpressure ratio for each of the two compressors.88

Control Valve System

The two-stage system offers the advantage of 

having one fewer component (a condenser) than the dual-loop system, but has many of the same 

disadvantages (e.g., either increased external dimensions or decreased internal volume).

The control valve system has two evaporators, one for the fresh food compartment and 

one for the freezer compartment, but only one compressor and one condenser. Two different 

length capillary tubes and a control valve are installed between the fresh food and freezer 

evaporator inlets and the condenser outlet. The valve directs the flow of the refrigerant through 

one of the evaporators at a time. That is, only one of the two compartments is cooled at any 

given time. With this configuration, the fresh food compartment is cooled at a higher evaporator 

temperature than the freezer compartment. Experimental research conducted on this system 

configuration indicated that the energy efficiency can be improved by 8.5 percent over that of a 

conventional refrigerator-freezer.

89
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GE offers a refrigerator-freezer system called the ClimateKeeper2TM system that uses two 

evaporators.90 Also, KitchenAid and Jenn-Air both offer under-counter compact refrigeratorfreezers that use dual evaporators.91 92

Ejector Refrigerator

The system details of none of these products is clearly 

described in the product literature.

One of the intrinsic losses in a conventional refrigeration cycle is the throttling of the 

refrigerant in the capillary tube. Throttling is an isenthalpic process in which work that could be 

extracted in the expansion process is not captured. In the ejector refrigerator, some of this work 

can be captured and used to raise the pressure of refrigerant entering the compressor above that 

of the evaporator. Simulation research has been conducted on an ejector refrigerator that consists 

of one compressor, one condenser, two capillary tubes, two evaporators (one for the fresh food 

compartment and the other for the freezer compartment), and an ejector. In this refrigerator, 

saturated liquid refrigerant exits the condenser and expands in the capillary tube to the fresh food 

evaporator. In the fresh-food compartment, the refrigerant is partially evaporated. At the outlet of 

the evaporator, the liquid refrigerant is separated from the vapor in a separator. The vapor flows 

to the ejector, where it is accelerated to high velocity. The liquid expands in a second capillary 

tube to the freezer evaporator, where it evaporates entirely. The vapor leaving the freezer 

evaporator is entrained in the high-velocity flow of the vapor which left the fresh food 

evaporator. The mixed flow is decelerated to increase its pressure. The mixed flow higher 

pressure flow passes to the compressor suction port to be compressed. This particular ejector 

refrigerator was shown to have an efficiency which is 12.4 percent higher than a conventional 

refrigerator-freezer.93

Tandem System

Like the control valve system and the ejector refrigerator, the tandem system uses two 

evaporators (one for the fresh food compartment and another for the freezer compartment), one 

condenser, and one compressor. Refrigerant flows in series first through the fresh food 

evaporator, then the freezer evaporator, and it passes a second time through the fresh food 

evaporator. The warm liquid refrigerant leaves the condenser and flows to fresh food evaporator

without a first expansion. In the fresh food evaporator the refrigerant liquid undergoes heat 

exchange with the evaporating refrigerant which has passed through the freezer evaporator. The 

temperature of the liquid is reduced by this heat exchange. The liquid then passes through the

capillary tube where its pressure is reduced. The two-phase refrigerant then passes through the 

freezer evaporator and absorbs heat from the freezer compartment. This vaporization process 

only occurs when the freezer evaporator fan is turned on by the freezer thermostat. The 

refrigerant then passes back through the fresh food evaporator. Here, if the refrigerant has not 

already been vaporized (i.e., the freezer compartment does not require cooling), it vaporizes as a 

result of absorbing heat from the fresh food compartment and the warm liquid. The superheated 

refrigerant then flows to the compressor suction port. At the beginning of the compressor run, the 

fresh-food compartment fan is turned on first. Thus, the fresh food compartment is cooled before 

the system reaches steady state. As a result, the system uses the pull-down period of each cycle, 

which is generally not suitable for cooling the freezer, to cool the fresh food compartment. This 

particular tandem system was shown to reduce energy use by 18 percent compared to a 

conventional refrigerator-freezer.94
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3.3.2.14 Alternative Refrigeration Systems

Alternative refrigeration systems do not use vapor compression to provide refrigeration.

Three alternative refrigeration systems are discussed below: the Stirling cycle, thermoelectric 

cooling, and thermoacoustic cooling. Although research and development has been conducted on 

each of these systems, and thermoelectric compact refrigerators and wine coolers are currently 

being marketed, none are a viable alternative for standard-size refrigerators, refrigerator-freezers, 

and freezers.

Stirling Cycle

A Stirling-cycle machine is a device that operates on a closed regenerative 

thermodynamic cycle, with cyclic compression and expansion of the working fluid at different 

temperature levels, and where the flow is controlled by volume changes, so that there is a net 

conversion of heat to work or vice versa. ‘Regenerative’ refers to the use of an internal heat 

exchanger, the regenerator, which is an essential part of the Stirling cycle. A Stirling 

refrigeration cycle compresses and expands an inert gas in a single cylinder. Heat is rejected at 

one end of the cylinder and absorbed at the opposite end. In the absence of all thermodynamic 

losses, the efficiency could be higher than for vapor compression systems, but there are various 

technical difficulties that have so far limited the use of Stirling-cycle cooling to small prototype 

domestic refrigerators. There is no circulating refrigerant fluid and the hot and cold heat areas are 

relatively small, which creates heat exchange challenges for any but the lowest-capacity systems.

Thermoelectric

Thermoelectric cooling occurs when a current is passed across the junction of two 

dissimilar metals. One side of the device becomes hot and the other cold. Materials 

(semiconductors) have relatively recently been developed that have allowed for the use of this 

type of cooling in some applications. Thermoelectric cooling devices have no moving parts, do 

not age, and have extremely long lifetimes. There are several compact refrigerators and wine 

coolers using thermoelectric cooling that are being marketed, including several models offered 

by Avanti Products.95

Thermoacoustic

However, they have very low efficiency and are not yet suitable for 

standard-size domestic refrigerator-freezers.

Acoustic cooling uses a sound generator inside a closed tube to vibrate a gas and cause 

alternate compression and expansion and therefore heating and cooling. The efficiency of 

prototypes have not been as high as vapor compression systems and the devices have been 

physically large for the amount of cooling produced.

3.3.3 Energy Efficiency

DOE gathered data on the energy efficiency of residential refrigerators, refrigeratorfreezers, and freezers currently available in the marketplace. DOE created a database of the 

current models by surveying manufacturers’ websites. The data provide an overview of the 

energy efficiency of each product class covered by this rulemaking.
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For the models in the DOE database, Figure 3.3.3 through Figure 3.3.22 present by 

product class the relationship between rated annual energy use and adjusted volume. In each 

figure, lines representing the maximum allowable energy consumption (i.e., the current 

minimum efficiency standard) and the current ENERGY STAR level (that took effect in April

2008 for standard-size refrigerators and refrigerator-freezers), are provided. This allows for a

quick visual inspection of the number of models that met the ENERGY STAR level.

The data representing all-refrigerators are highlighted in the figures for product classes 1, 

3, 11, and 13. For product classes 1 and 11, the products which are not all-refrigerators could be 

either basic refrigerators or manual defrost refrigerator-freezers. For product classes 3 and 13, 

the products which are not all-refrigerators are refrigerator-freezers. The percentage of allrefrigerators is high for product class 11 and very high for product class 13.

The DOE survey found no current models in product class 6, top-mount refrigeratorfreezers with through the door ice and with automatic defrost. DOE still provides a figure for this 

class to show the maximum allowable energy consumption for this product class. Many of the 

other product classes also have few products.
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Figure 3.3.3 Annual Energy Consumption for Refrigerators and Refrigerator-Freezers 

with Manual Defrost (Product Class 1)

Figure 3.3.4 Annual Energy Consumption for Refrigerator-Freezers with Partial 

Automatic Defrost (Product Class 2)

0

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200

300

400

500

600

700

800

0 5 10 15 20 25 30 35 40 45

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Federal Minimum Standard

Energy Star

All-Refrigerators

Basic Refrigerators & 

Refrigerator-Freezers

0

100

200

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400

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800

0 5 10 15 20 25 30 35 40 45

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Federal Minimum 

Standard

Energy Star
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Figure 3.3.5 Annual Energy Consumption for Top-Mount Refrigerator-Freezers with 

Automatic Defrost without TTD Ice Service and All-Refrigerators with Automatic Defrost 

(Product Class 3)

Figure 3.3.6 Annual Energy Consumption for Side-Mount Refrigerator-Freezers with 

Automatic Defrost without TTD Ice Service (Product Class 4)

0

100

200

300

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500

600

700

800

0 5 10 15 20 25 30 35 40 45

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Federal Minimum Standard

Energy Star

Refrigerator-Freezers

All-Refrigerators

0

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0 5 10 15 20 25 30 35 40 45

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Federal Minimum 

Standard

Energy Star
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Figure 3.3.7 Annual Energy Consumption for Bottom-Mount Refrigerator-Freezers with 

Automatic Defrost without TTD Ice Service (Product Class 5)

Figure 3.3.8 Annual Energy Consumption for Bottom-Mount Refrigerator-Freezers with 

Automatic Defrost with TTD Ice Service (Product Class 5A)

0

100

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800

0 5 10 15 20 25 30 35 40 45

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Federal Minimum 

Standard

Energy Star

0

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800

0 5 10 15 20 25 30 35 40 45

Annual Energy Consumption (kWh/yr)

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Federal Minimum 

Standard

Energy Star
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Figure 3.3.9 Annual Energy Consumption for Top-Mount Refrigerator-Freezers with 

Automatic Defrost with TTD Ice Service (Product Class 6)

Figure 3.3.10 Annual Energy Consumption for Side-Mount Refrigerator-Freezers with 

Automatic Defrost with Through-the-Door Ice Service (Product Class 7)

0

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200

300

400

500

600

700

800

0 5 10 15 20 25 30 35 40 45

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Note that no current products within this 

category could be found.

0

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300

400

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600

700

800

0 5 10 15 20 25 30 35 40 45

Annual Energy Consumption (kWh/yr)

Adjusted Volume ft3)

Federal Minimum 

Standard

Energy Star
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Figure 3.3.11 Annual Energy Consumption for Upright Freezers with Manual Defrost 

(Product Class 8)

Figure 3.3.12 Annual Energy Consumption for Upright Freezers with Automatic Defrost 

(Product Class 9)

0

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0 5 10 15 20 25 30 35 40 45

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Federal Minimum 

Standard

Energy Star

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1000

0 5 10 15 20 25 30 35 40 45

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Federal Minimum 

Standard

Energy Star
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Figure 3.3.13 Annual Energy Consumption for Chest Freezers and all other Freezers 

except Compact Freezers (Product Class 10)

Figure 3.3.14 Annual Energy Consumption for Chest Freezers with Automatic Defrost 

(Product Class 10A)

0

100

200

300

400

500

600

700

800

0 5 10 15 20 25 30 35 40 45

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Federal Minimum 

Standard

Energy Star

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0 5 10 15 20 25 30 35 40 45

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Federal Minimum 

Standard

Energy Star
3-75

Figure 3.3.15 Annual Energy Consumption for Compact Refrigerators and RefrigeratorFreezers with Manual Defrost (Product Class 11)

Figure 3.3.16 Annual Energy Consumption for Compact Refrigerator-Freezers with 

Partial Automatic Defrost (Product Class 12)

0

100

200

300

400

500

600

700

800

0 2 4 6 8 10 12 14

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Federal Minimum Standard

Energy Star

All-Refrigerators

Basic Refrigerators & 

Refrigerator-Freezers

0

100

200

300

400

500

600

700

800

0 2 4 6 8 10 12 14

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Federal Minimum 

Standard

Energy Star
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Figure 3.3.17 Annual Energy Consumption for Compact Top-Mount Refrigerator-Freezers 

with Automatic Defrost and All-Refrigerators with Automatic Defrost (Product Class 13)

Figure 3.3.18 Annual Energy Consumption for Compact Side-Mount Refrigerator-Freezers 

with Automatic Defrost (Product Class 14)

0

100

200

300

400

500

600

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800

0 2 4 6 8 10 12 14

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Federal Minimum Standard

Energy Star

All-Refrigerators

Refrigerator-Freezers

0

100

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0 2 4 6 8 10 12 14

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Federal Minimum 

Standard

Energy Star
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Figure 3.3.19 Annual Energy Consumption for Compact Bottom-Mount RefrigeratorFreezers with Automatic Defrost (Product Class 15)

Figure 3.3.20 Annual Energy Consumption for Compact Upright Freezers with Manual 

Defrost (Product Class 16)

0

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0 2 4 6 8 10 12 14

Annual Energy Consumption (kWh/yr)

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Federal Minimum 

Standard

Energy Star

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0 2 4 6 8 10 12 14

Annual Energy Consumption (kWh/yr)

Adjusted Volume (ft3)

Federal Minimum 

Standard

Energy Star
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Figure 3.3.21 Annual Energy Consumption for Compact Upright Freezers with Automatic 

Defrost (Product Class 17)

Figure 3.3.22 Annual Energy Consumption for Compact Chest Freezers (Product Class 18)

0

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Adjusted Volume (ft3)

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Standard

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Federal Minimum 

Standard

Energy Star
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 1 Title 10—Energy, Chapter II—Department of Energy, Part 430—Energy Conservation 

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3-81

 

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4-i

CHAPTER 4. SCREENING ANALYSIS

TABLE OF CONTENTS

4.1 INTRODUCTION ...........................................................................................................4-1

4.2 SCREENED-OUT TECHNOLGIES...............................................................................4-2

4.2.1 Improved Resistivity of Insulation.......................................................................4-2

4.2.2 Gas-Filled Panels.................................................................................................4-3

4.2.3 Improved Gaskets, Double Gaskets, Improved Door Face Frame ......................4-3

4.2.4 Reduced Heat Load for TTD Feature ..................................................................4-3

4.2.5 Warm Liquid or Hot Gas Refrigerant Anti-Sweat Heating .................................4-4

4.2.6 Electric Anti-Sweat Heater Sizing.......................................................................4-4

4.2.7 Linear Compressors.............................................................................................4-4

4.2.8 Improved Evaporator Heat Exchange..................................................................4-5

4.2.9 Improved Condenser Heat Exchange...................................................................4-5

4.2.10 Fan Blade Improvements.....................................................................................4-6

4.2.11 Improved Expansion Valve..................................................................................4-6

4.2.12 Off-Cycle Valve...................................................................................................4-7

4.2.13 Reduced Energy for Automatic Defrost ..............................................................4-7

4.2.14 Condenser Hot Gas Defrost .................................................................................4-7

4.2.15 Electronic Temperature Control ..........................................................................4-8

4.2.16 Air-Distribution Control ......................................................................................4-8

4.2.17 Alternative Refrigerants.......................................................................................4-9

4.2.18 Component Location............................................................................................4-9

4.2.19 Lorenz-Meutzner Cycle .....................................................................................4-10

4.2.20 Dual-Loop System .............................................................................................4-10

4.2.21 Two-Stage System .............................................................................................4-10

4.2.22 Control Valve System and Tandem System ......................................................4-10

4.2.23 Ejector Refrigerator ...........................................................................................4-11

4.2.24 Stirling Cycle .....................................................................................................4-11

4.2.25 Thermoelectric ...................................................................................................4-12

4.2.26 Thermoacoustic..................................................................................................4-12

4.3 REMAINING TECHNOLOGIES .................................................................................4-13

LIST OF TABLES

Table 4.2.1 LG Linear Compressor Performance Data ...............................................................4-5

LIST OF FIGURES

Figure 4.2.1 Comparison of Stirling and Vapor Compression Technologies............................4-12
4-1

CHAPTER 4. SCREENING ANALYSIS

4.1 INTRODUCTION

This chapter details the screening analysis that the U.S. Department of Energy (DOE)

conducted in support of the ongoing energy conservation standards rulemakings for refrigerators, 

refrigerator-freezers, and freezers.

In chapter 3, the market and technology assessment (MTA), DOE presented an initial list 

of technologies that can improve the energy efficiency of residential refrigeration products. The 

purpose of the screening analysis is to evaluate the technologies that improve equipment 

efficiency to determine which technologies to consider further and which to screen out. DOE 

consulted with a range of parties, including industry, technical experts, and others to develop a 

list of technologies for consideration. DOE evaluated the technologies pursuant to the criteria set 

out in the Energy Policy and Conservation Act (EPCA), as amended. (42 U.S.C. 6311-6317)

Section 325(o) EPCA establishes criteria for prescribing new or amended standards

designed to achieve the maximum improvement in energy efficiency. Further, EPCA directs the 

Secretary of Energy to determine whether a standard is technologically feasible and 

economically justified. (42 U.S.C. 6295(o)(2)(A), as directed by 42 U.S.C. 6316(a)(1)-(3)).

EPCA also establishes guidelines for determining whether a standard is economically justified.

(42 U.S.C. 6295(o)(2)(B)) Appendix A to subpart C of Title 10, Code of Federal Regulations,

Part 430 (10 CFR Part 430), “Procedures, Interpretations and Policies for Consideration of New 

or Revised Energy Conservation Standards for Consumer Products” (the Process Rule), sets forth 

procedures to guide DOE in its consideration and promulgation of new or revised equipment

energy conservation standards. These procedures elaborate on the statutory criteria provided in 

42 U.S.C. 6295(o) and, in part, eliminate problematic technologies early in the process of 

prescribing or amending an energy efficiency standard. In particular sections 4(b)(4) and 5(b) of 

the Process Rule guide DOE in determining whether to eliminate from consideration any 

technology that presents unacceptable problems with respect to the following criteria:

Technological feasibility. Technologies incorporated in commercial equipment or in 

working prototypes will be considered technologically feasible.

Practicability to manufacture, install, and service. If mass production of a technology 

in commercial equipment and reliable installation and servicing of the technology could be 

achieved on the scale necessary to serve the relevant market at the time of the effective date of 

the standard, then that technology will be considered practicable to manufacture, install, and 

service.

Impacts on equipment utility or equipment availability. If a technology is determined 

to have significant adverse impact on the utility of the equipment to significant subgroups of 

customers, or result in the unavailability of any covered equipment type with performance 

characteristics (including reliability), features, sizes, capacities, and volumes that are 

substantially the same as equipment generally available in the United States at the time, it will 

not be considered further.
4-2

Adverse impacts on health or safety. If it is determined that a technology will have 

significant adverse impacts on health or safety, it will not be considered further.

In sum, if DOE determines that a technology, or a combination of technologies, has 

unacceptable impacts on the policies stated in section 5(b) of the Process Rule, it will be 

eliminated from consideration. If a particular technology fails to meet one or more of the four 

criteria, it will be screened out. Section 4.2 documents the reasons for eliminating any 

technology.

4.2 SCREENED-OUT TECHNOLGIES

This section describes the technologies that DOE eliminated for failure to meet one of the 

following four factors: (1) technological feasibility; (2) practicability to manufacture, install, and 

service; (3) impacts on equipment utility or equipment availability; and (4) adverse impacts on 

health or safety.

DOE also eliminated some technologies that were determined to provide little or no 

potential for energy use reduction for one of the following additional reasons: (a) technology 

already used in baseline products and incapable of generating additional energy efficiency or 

reducing energy consumption, (b) technology does not reduce energy use, and (c) insufficient 

data available demonstrating benefit of the technology.

4.2.1 Improved Resistivity of Insulation

Past research has demonstrated that the resistivity of polyurethane (PU) foam insulation 

can be improved through the use of additives that reduce the thermal conductivity of the foam.

Research conducted in 1996 demonstrated that adding carbon black provides a means of 

improving the thermal insulation properties of PU foam using both HCFC-141b or cyclopentane 

blowing agents.

1 However, DOE is not aware that this process has been adopted by any supplier 

of PU foam insulation or any refrigerator manufacturer. Manufacturers have reported that it 

darkens the interior of a refrigerator lined with white plastic, and it stains anything it contacts.

Discussion with PU foam insulation vendors indicates that there is work ongoing which 

may lead to improvement in insulation performance but that any such technology would not 

likely be ready for introduction to the market by 2014. Discussion with manufacturers has 

confirmed that there are no available options for improvement in PU foam insulation 

performance (other than reverting to use of banned blowing agents). Due to the lack of available 

information and predictions that there is no significant benefit to be expected from PU foam 

improvements, DOE has eliminated this option from consideration in the engineering analysis.

Stakeholders at the preliminary analysis public meeting indicated that DOE should 

consider in the analysis a trend away from use of HFC blowing agents, in response to concerns 

about their global warming potential (GWP), and the possibility that climate change legislation 

may be enacted that would limit use of HFCs. DOE has put an analytic structure in place to 
4-3

allow for the rapid evaluation of efficiency improvement and trial standard levels for products 

using alternative foam insulation materials, if legislation banning HFCs should be enacted.

4.2.2 Gas-Filled Panels

Investigation of the status of gas-filled panels suggests that there has been some 

evaluation of this technology by manufacturers of residential refrigeration equipment, but that no 

manufacturers are using it in their products. The costs are reported to be as high as for vacuum 

insulation panels (VIPs), with less reduction in thermal load. DOE has not been able to identify a 

credible supplier that would provide gas filled panel products to the refrigeration industry. DOE 

has eliminated this technology from further consideration.

4.2.3 Improved Gaskets, Double Gaskets, Improved Door Face Frame

Past investigation on reduction of heat load in the gasket and door face frame area has 

focused on (1) limiting the conduction of heat through metal casing material passing underneath

the gasket magnet on the cabinet side or in the region of the gasket clip on the door side into the 

cabinet interior, (2) using a gasket which provides additional cover of frame surfaces towards the 

interior of the magnet to prevent cold air from reaching the high-conductivity metal casing near 

the gasket magnet, and (3) providing a long thin “throat” area between the gasket and the interior 

to limit convection heat transfer. Most current designs are effective in addressing these issues.

Limited information is publicly available which would allow quantification of additional 

improvement potential for the door frame/gasket area of refrigerators. Some manufacturers use 

extra-strong gasket magnets to limit infiltration and thermal loss, but it is unclear whether 

significant thermal improvement is possible with such systems. Manufacturers indicated during 

pre-NOPR discussions that properly designed and installed gasket systems provide a tight seal 

and that there isn’t any further reduction in air leakage that could be achieved with 

improvements in the gasket system such as increasing the magnetic force. In addition, consumer 

safety laws preclude use of excessive door sealing force.

Based on information drawn from DOE’s 1995 TSD, double door gaskets were not 

adopted by many manufacturers in the mid-1990s because of performance problems and cost. Ice 

has a tendency to form between the gaskets, greatly reducing their effectiveness. In addition, the 

gaskets tend to be visually unattractive and they make it more difficult to meet the consumer 

safety regulations for minimum door-opening force.

It is expected that incremental improvement may be possible for some products, however, 

the lack of good quantified information on general improvement potential in this area makes this 

technology option unsuitable for consideration as a design option.

4.2.4 Reduced Heat Load for TTD Feature

During Pre-NOPR analysis discussions, manufacturers indicated that there is little or no 

reduction in load which can be achieved through redesign of TTD features. DOE inspected the 

TTD system of a side-by-side refrigerator and concluded that the load impact of this feature is 

modest. The door insulation thickness is maintained behind the recess except within an inch or 
4-4

two of the chute opening, and low-conductivity plastic is used on all surfaces. The chute door 

closes reliably. A calculation of the thermal load suggests that it is on the order of 3W (10

Btu/hr). The reverse engineering of this feature shows that a 2W electric anti-sweat heater is used 

to prevent condensation of the exterior surfaces nearest the ice chute opening. Manufacturers 

indicated that these load levels are typical for TTD features. Even if the chute door was insulated 

with 1⁄2-inch of insulation (which would likely interfere with chute door operation), the load 

impact would be minimal, due to the very low surface area of this door. Based on the very low 

potential for improvement, DOE has eliminated reduced heat load TTD features as an option for 

further analysis.

4.2.5 Warm Liquid or Hot Gas Refrigerant Anti-Sweat Heating

Although some refrigerators do still use electric anti-sweat heating, the typical anti-sweat 

heater for baseline units, according to the reverse engineering work and discussion with 

manufacturers, is warm liquid refrigerant. A possible exception is French door refrigerators. In 

these products, providing heat to the gasket surfaces which seal between the French doors (or to 

the flip-mullion used in some designs for sealing in this region) is not possible using warm 

refrigerant liquid or hot gas. French door refrigerators may use electric anti-sweat heaters in this 

region, but for these products conversion to refrigerant line anti-sweat is impractical. Due to the 

current use of refrigerant-line anti-sweat in situations where it can be used, DOE has eliminated 

this option from further consideration.

4.2.6 Electric Anti-Sweat Heater Sizing

Because the baseline products considered in the engineering analysis predominantly use 

warm liquid anti-sweat, the consideration of adjustment of the sizing of electric anti-sweat

heaters is not relevant.

4.2.7 Linear Compressors

While promising potential has been reported for linear compressors, there is very little 

information available for commercialized linear compressors that allows confident prediction of 

performance and cost impacts of this technology. Information for some LG linear compressors 

has been reported at “LG Reference Conditions,” which are significantly different than the 

standard ASHRAE rating conditions. Under ASHRAE conditions, compressors are rated at -10 

oF (-23.3 oC) evaporating temperature and 130 oF (54.4 oC) condensing temperature. The “LG 

Reference Conditions” are based on -14.8 oF (-26 oC) evaporating and 100.4 oF (38 oC) 

condensing temperatures. It is not clear what the liquid and suction vapor temperatures for the 

LG conditions are—these temperatures also impact capacity and power input. The performance 

of some of LG’s linear compressors at the LG conditions is presented in Table 4.2.1 below. At 

the same evaporating and condensing temperatures and with liquid and suction vapor conditions 

consistent with the ASHRAE test conditions, a high efficiency rotating-shaft reciprocating 

compressor such as the Embraco EGX70HLC would have an operating EER of about 6.9 Btu/hrW. Hence, the LG linear compressor may be about 9% more efficient than the best currenttechnology rotating-shaft reciprocating compressors.
4-5

Table 4.2.1 LG Linear Compressor Performance Data

Model

Capacity Range* Efficiency*

W Btu/hr COP EER

DLF81LACT 310 1058 2.14 7.3

FA81LACT 293 1000 2.20 7.5

FA72LACT 276 941 2.20 7.5

FA63LACT 241 823 2.20 7.5

FA54LACT 207 706 2.20 7.5

Source: LG, 2007.

* Performance based on ‘LG Reference’ rating conditions. Models utilize refrigerant R134a.

In the trade press, LG has expressed willingness to license the linear compressor 

technology to competitors.2

4.2.8 Improved Evaporator Heat Exchange

However, because the LG design is proprietary, the widespread use 

of linear compressors is highly uncertain. Use of linear compressors in LG refrigerators is less 

explicit in LG product data than it was a few years ago, so it is unclear how many products are 

actually using these compressors. Other compressor manufacturers who have indicated that they 

have investigated linear technology have stated that linear compressor technology does not 

provide a clear path to improved efficiency, and some have indicated that they are no longer 

actively pursuing this technology. Hence, availability of linear compressor technology as an 

option for improved efficiency is uncertain. Further, DOE was not able to obtain cost estimates 

for linear compressors. For these reasons, DOE has eliminated linear compressors from further 

consideration in the analyses.

Improving heat exchanger performance can be achieved through the use of enhanced fins 

and/or tubes. These types of fin and tube enhancements are common in air-conditioning 

applications where slit and louvered designs are used to enhance the fin surface and different 

types of internally-grooved surfaces are used to enhance the tubing. Application of similar 

enhancements in refrigerator evaporators is complicated by frost accumulation on the 

evaporators. Effectiveness of the fine slit and louver features for refrigerator evaporators is 

dubious because they would be blocked quickly with frost. In order to avoid the energy use 

associated with frequent defrost, fin spacing in refrigerator evaporators is comparatively sparse.

This allows the evaporator to work effectively without blocking airflow with a considerable 

accumulation of frost. During defrost, the typical flat fin design of these evaporators assures that 

the frost slides rapidly off the fins and doesn’t get stuck on fin enhancement features. During 

discussions with manufacturers, little indication was provided that efficiency could significantly 

be enhanced through the use of fin or tube enhancements. DOE has eliminated this option from 

consideration in subsequent analysis.

4.2.9 Improved Condenser Heat Exchange

Use of heat exchanger enhancements for the condenser is complicated by the need for 

adequate performance when the heat exchanger has not been cleaned. Most refrigerator 

condensers (other than hot wall condensers integrated into the outer shells of the products) are 

made of steel tubes and steel wire fins. These condensers have a very open construction which 
4-6

allows dust to flow through easily and which reduces blockage of air flow if dust does collect on 

the condenser surfaces. Flat fin condensers used in refrigerators are known to require more 

careful attention to cleaning. Use of high fin densities is more accepted in air-conditioning 

applications because periodic maintenance is expected and because size would get enormous if 

aggressive fin spacing wasn’t employed, whereas cleaning of refrigerator condensers occurs 

infrequently or never, and the loads are small enough so that maximizing use of space is not 

critical. DOE has eliminated this option from consideration in subsequent analysis.

4.2.10 Fan Blade Improvements

Refrigerator fan blades use an axial design. They are typically injection molded plastic 

with a three-dimensional shape for improved performance as compared with older stamped sheet 

metal designs. One source of inefficiency for axial fans lies in their tendency to throw air 

outward, necessitating a shroud to collect and redirect airflow along the axis as intended. The

Pax GroupTM has developed a fan (PAX fan) that employs streamlined blades with patented 

geometrical shapes derived from a naturalistic design approach, providing better airflow 

direction and improved efficiency. Tests performed when replacing existing motor combinations 

with A.O.Smith motors and PAX fan blades show power input reductions in the range of roughly 

10% to 35%.3

4.2.11 Improved Expansion Valve 

It is impossible to tell how much of this benefit is associated with the fan blade 

and how much with the motor. Also, because the PAX fan is proprietary, the widespread use of 

the design is highly uncertain. There is in general little data available to quantify the energy 

benefit possible with improvement in fan blade design in today’s refrigeration products. Fan 

performance is highly dependent on details of integration with the system: orifice geometry, 

tolerance of blade/orifice gap, match of system flow impedance to fan performance, etc. Hence, 

making credible estimates of energy savings potential through fan blade replacement requires 

testing fan blade swaps in baseline products. The cost of fabrication of improved fan blade

geometries should be low, so most of the cost increase associated with this technology option 

would be associated with paying for the blade development and/or licensing fees. It is very 

difficult to predict what these costs would be unless specific vendors of high efficiency fan 

blades can be identified who provide complete information. During discussions with 

manufacturers, no information was provided which would allow credible calculation of savings 

and costs associated with improved fan blades. Hence, DOE has eliminated this option from 

further consideration.

Residential refrigeration products exclusively use capillary tubes for refrigerant flow 

metering. These tubes are inexpensive and they lend themselves easily to low-cost fabrication of 

suction line heat exchangers by brazing the capillary to the suction line. Automatic, adjustable 

thermostatic or electronic expansion valves are available, but they generally are oversized for 

residential refrigeration. Furthermore, it is unclear whether there is any potential for energy 

savings using alternative expansion devices. The DOE Energy test is conducted with a single set 

of standardized temperatures for the ambient air (90 °F) and for the compartments. A capillary 

tube can be designed to provide optimized performance for this set of temperatures. Systems are 

generally designed to operate with evaporator exit conditions having little or no superheat during 

energy testing, thus maximizing use of the evaporator. In the lower ambient temperature typical 

in homes, the pressure available to move refrigerant through the capillary tube is lower, thus 
4-7

possibly leading to increased superheat and less than optimum performance. An automatic valve 

could provide optimum performance for a wider range of operating conditions, but such 

improvement is not reflected in current energy testing. DOE has eliminated this option from 

further consideration.

4.2.12 Off-Cycle Valve

Off-cycle refrigerant migration reduces a refrigeration product’s efficiency by allowing 

warm and/or vapor-phase refrigerant to pass into the cabinet. A fluid control or solenoid valve 

installed after the condenser to effectively isolate the evaporator from the condenser during the 

off-cycle can be used to prevent refrigerant migration. Research has demonstrated that solenoid 

valves can yield substantial energy savings.4

4.2.13 Reduced Energy for Automatic Defrost

Such a solenoid valve represents a possible 

reliability issue, although many wine storage products use similar solenoid valves to allow 

control of multiple compartments with a single compressor. Also, operation with an off-cycle 

valve requires that the compressor motor can start up against a substantial pressure difference.

The starting windings of compressors that can do this reliably over the life of a refrigerator draw 

more power and hence reduce the compressor’s steady-state efficiency. The different efficiency 

levels of commercial refrigeration compressors designed for instant restart versus restart after 

pressure equalization have EER ratings which differ by 10% or more. Such a difference would 

be expected for residential compressors operating with an off cycle valve, and this difference 

would more than neutralize any benefit accrued from using the off-cycle valve. Hence, DOE has 

eliminated this option from further consideration.

In some cases, the defrost heat supplied is more than required. Thus, energy savings can 

be achieved by reducing the defrost heat by either using smaller heaters, reducing the heater ontime, reducing the frequency of defrost, or a combination of these. In its 1995 TSD, DOE found 

that most manufacturers had already significantly reduced the electric heat for auto defrost in 

order to comply with the energy efficiency standards that became effective in 1993.5

4.2.14 Condenser Hot Gas Defrost

The percent 

of energy represented by defrost for the refrigerator-freezers tested as part of this rulemaking 

ranged from 4% to 5% for products without adaptive defrost and from 1% to 5% for products 

with adaptive defrost. It is unlikely that significant energy savings are achievable by further 

reducing the energy for automatic defrost without compromising defrost performance, except 

through use of adaptive defrost. 

Another method of reducing the energy required for defrost is to eliminate the need for 

electric heaters by substituting condenser hot gas in their place. In a condenser hot gas defrost 

system, the compressor continues to run and a valve opens allowing hot compressed refrigerant 

to flow to the evaporator. Many frost-free refrigerator-freezers in the 1960s and 1970s used a 

condenser hot gas defrost system. In its 1995 TSD, DOE was not able to identify data that

demonstrated that the condenser hot gas method was more cost-effective than adaptive defrost.

Therefore, DOE dropped the condenser gas defrost as a technology option in favor of adaptive 

defrost. 6 Hot gas defrost would potentially save energy because a large portion of the heat for 

defrost could be provided by heat generated by the compressor motor during the on-cycle rather 
4-8

than from new electricity use. The compressor is at an elevated temperature with respect to 

ambient during the on-cycle and is certainly much warmer than freezing temperature. The heat 

would be transported to the evaporator with circulating refrigerant during the defrost cycle.

However, in spite of this potential reduction in use of electricity to provide defrost heat, the 

energy savings potential is not well documented. Also, there are concerns regarding reliability of 

the required valve.

4.2.15 Electronic Temperature Control

DOE has not identified any relevant information showing the energy benefit of electronic 

temperature control. Potential benefits of electronic control when operating with single-speed 

compressors are fine-tuning of the run times and fine-tuning of the cut-in and cut-out 

temperatures. While there may be potential for incremental improvement associated with such 

fine-tuning, the lack of data supporting claims for energy savings make it difficult to properly 

analyze this option.

4.2.16 Air-Distribution Control

Air temperature distribution in refrigeration products with fan-forced evaporator air flow 

is generally good, in contrast with some products with cold wall or roll bond evaporators. Hence, 

it is not clear that improvements in air distribution will provide significant reduction in energy 

use. Redirection of air flows in a cabinet could potentially provide a false indication of efficient 

operation, for instance if the coldest air from the evaporator discharge is directed at the locations 

used for the energy test thermocouples. It is conceivable that valid reduction in energy use could 

occur if the air flow distribution keeps cold air away from the walls of the cabinet. However, 

there is insufficient information regarding the designs of air flow distribution systems to quantify 

potential energy savings.
4-9

4.2.17 Alternative Refrigerants

DOE eliminated alternative refrigerants as a design option for most product classes 

because the available alternatives are either banned, have lower thermodynamic efficiencies, or, 

as in the case of hydrocarbons, are only allowed in limited quantities due to safety regulations. 

Isobutane is the most logical alternative to HFC-134a, the refrigerant currently used in U.S. 

residential refrigeration products. Isobutane is a hydrocarbon refrigerant with a higher theoretical 

efficiency than that of HFC-134a. It has been used for many years in refrigeration products in 

Europe and other foreign countries. The U.S. refrigeration industry has not adopted hydrocarbon 

refrigerants (likewise for the U.S. air conditioning industry) due to concerns regarding 

flammability.

UL Standard 250, “Household Refrigerators and Freezers”, includes requirements for use 

of hydrocarbon refrigerants in residential refrigeration products, including a limit of 50 g that can 

be released in case of a breach of the sealed refrigeration system.7

4.2.18 Component Location

Isobutane has not yet been 

placed on EPA’s Significant New Alternatives Program (SNAP) list of allowed alternative 

refrigerants. However, EPA recently published a notice proposing inclusion of isobutane on this 

list. 75 FR 25799 (May 10, 2010) The proposal limits the total charge of isobutane to 57 g. This 

quantity is nearly equivalent to the current UL 250 requirement, which specifies maximum 

leaked charge—some of the refrigerant remains in the system, thus accounting for the higher 

total charge specified in the EPA proposal. DOE estimated that the 57 g limit is sufficient to 

allow use in compact refrigerators, but use of heat exchangers with reduced internal volume 

would be required for this limit to be sufficient for the other product classes analyzed. Hence, 

DOE considered conversion to isobutane as a design option, but only for compact refrigerators.

Locating the compressor at the top of the refrigerator was noted as a potential technology 

option. However, this change would increase structural requirement for the refrigerator cabinet, 

increase risk of product tip-over, and provide much less practical use of space from the consumer 

perspective. It also makes design for re-evaporation of defrost water more challenging. It is 

unlikely that the savings would justify all of these drawbacks.

Another option is to locate the evaporator fan motor outside the cabinet to reduce internal 

loads from the heat loss of the motor. Evaporator fan motor input wattages are now in the range 

3W to 7W, with fan blade efficiency in the range 20% to 30% and motor efficiency in the range 

20% to 50%. Hence, load reduction, associated with moving the motor loss outside the cabinet, 

is only in the range 1W to 5W for the typically less than 50% of the time that the evaporator fan 

is in operation. The loss associated with the added infiltration and conduction is likely to be 

comparable to this level. Additional issues with this approach include reliability, reduced design 

flexibility, and the fact that reduction of motor losses (by using more efficient fan motors) may 

be a more effective approach to reducing the impact of the fan motor power input.

No options for relocation of components have been identified which merit further 

consideration in the engineering analysis.
4-10

4.2.19 Lorenz-Meutzner Cycle

Research on Lorenz-Meutzner cycles reported in the literature involve binary mixtures 

HCFC-22/CFC-11, HCFC-22/HCFC-123, propane/n-pentane, and propane/n-butane. These 

systems achieved efficiency levels from 15 to 20 percent better than the baseline systems with 

which they were compared.8,9

4.2.20 Dual-Loop System

Because the industry settled on the use of HFC-134a to replace 

CFC-12, interest in the Lorenz-Meutzner cycle as an alternative to conventional refrigeration 

cycles declined. All of the refrigerant combinations discussed above have specific problems, the 

first two with phaseout of constituent refrigerants CFC-11 and HCFC-22, and the last two with 

flammability of the hydrocarbon blends involved. While it is possible that HFC mixtures could 

be developed to create a viable Lorenz-Meutzner cycle refrigerator, DOE is not aware that such a 

prototype has been built and tested successfully. Hence, DOE has not considered this technology 

in the engineering analysis.

Dual-loop systems have difficulty achieving their theoretical improvement potential due 

to the significantly reduced efficiency for smaller-capacity compressors. If the two compressors 

of a dual-loop system serving a refrigerator-freezer were sized appropriately for their respective 

loads, the freezer compressor capacity would nominally be roughly half that of a single-system 

compressor. A fresh food compressor typically operates at a capacity significantly higher than its 

nominal capacity because of the higher evaporating temperature when cooling just the fresh food 

compartment. Hence, the nominal capacity of a fresh food compartment compressor serving a 

dual-loop system is generally 30 to 40 percent that of the single-system compressor. Even with 

the efficiency improvement associated with higher evaporating temperature operation of the 

fresh food compartment compressor, this compressor still would not operate at an efficiency 

level better than that of the single-system compressor for freezer conditions. Hence, with the 

efficiency characteristics of available compressors, it is not clear that the dual-loop architecture 

will provide any energy savings. Hence, DOE has not considered this technology in the 

engineering analysis.

4.2.21 Two-Stage System

In practice, a two-stage system would suffer the same disadvantages associated with a 

dual-loop system. Furthermore, it is not clear that a suitable compressor is available for the lower 

stage of such a system. DOE is not aware of any prototypes of such a system using compressors 

which their manufacturers would warrantee for such a product. Hence, DOE has not considered 

this technology in the engineering analysis.

4.2.22 Control Valve System and Tandem System

There are many patents covering dual-evaporator refrigerator designs. It is not clear how 

many of these were developed to improve system efficiency, since one of the benefits of using 

dual evaporators is avoiding excessively low humidity levels in the fresh food compartment.

While there is research involving laboratory testing which shows that these technology options

can save energy, DOE is not aware of any commercialized refrigerators using either of these

approaches. In discussions with manufacturers none identified these options as being interesting 
4-11

approaches for energy use reduction. Further, due to the extensive patent literature discussing 

dual-evaporator systems, it is likely that products requiring dual evaporator designs would be 

restricted to the patentholders. Hence, DOE has not considered this technology in the 

engineering analysis.

4.2.23 Ejector Refrigerator

Energy savings have been reported for use of an ejector system in laboratory testing. In 

discussions with manufacturers there was limited familiarity with this concept and no 

acknowledgement that it has been proven through prototype testing and/or that it is an interesting 

concept for improving efficiency. Hence, DOE has not considered this technology in the 

engineering analysis.

4.2.24 Stirling Cycle

In principle, the efficiency of Stirling cycles could be higher than for vapor 

compression systems, but there are various technical difficulties that have so far limited the use 

of Stirling-cycle cooling to small prototype domestic refrigerators. There is no circulating 

refrigerant fluid and the hot and cold end areas are very small, which creates heat exchange 

difficulties. Heat pipes may be required to transfer heat to and from the system. A comparison of 

the performance of Stirling cycle with vapor compression compressors is shown in Figure 4.2.1

below. The Stirling cycle data was obtained from the Global Cooling website10 and from data 

presented at the Purdue Refrigeration Conference in 2002.11 The figure shows that Stirling 

technology is not currently ready to improve upon the efficiency of conventional technology. 

Hence, DOE has not considered this technology in the engineering analysis.
4-12

Figure 4.2.1 Comparison of Stirling and Vapor Compression Technologies

4.2.25 Thermoelectric

Thermoelectric cooling technologies currently do not achieve efficiency levels which 

make them attractive as a design option for improving residential refrigeration energy efficiency.

As an example, DOE tested a thermoelectric refrigerator as part of the reverse engineering effort

of this rulemaking. This refrigerator was a Haier model HRT02WNC, a 1.7 cubic foot allrefrigerator. In an 80 °F ambient with the system operating at full power, this unit was able to 

cool the interior to 47 °F while drawing 50W total. The fans serving the inside and outside heat 

sinks of the thermoelectric unit are rated at a voltage of 12 Volts and currents of 0.13 Amps and 

0.16 Amps respectively, and a control board power input of 1W is assumed. The thermal load for 

the cabinet was estimated as 12 W. Hence the thermoelectric module EER was 0.9 at a 

temperature lift of at most 33 °F, an order of magnitude less than is achieved by conventional 

technology. Hence, DOE has not considered this technology in the engineering analysis.

4.2.26 Thermoacoustic

While research suggests that thermoacoustic cooling systems could achieve respectable 

efficiencies, the technology has not reached a level of maturity sufficient for serious 

consideration as the basis for efficiency improvement in residential refrigeration products.

Hence, DOE has not considered this technology in the engineering analysis.

0

2

4

6

8

10

12

40 60 80 100 120 140 160

Temperature Lift (F)

EER (Btu/hr-W)

Conventional: Danfoss TTE4.6FK, Nominal 4.62 EER

Conventional: Tecumseh TPG1370YXA, Nominal 5.82 EER

Stirling: Purdue 2002 Paper

Stirling: Global Cooling M100
4-13

4.3 REMAINING TECHNOLOGIES

After eliminating those technologies that have no effect or do not increase EER and 

screening out those technologies that that do not meet the requirements of sections 4(a)(4) and 

5(b) of the Process Rule, DOE is considering the technologies in the following list.

• Increased Insulation Thickness

• Vacuum Insulation Panels (VIPs)

• Variable Anti-sweat Heating

• Improved Compressor Efficiency

• Variable Speed Compressors

• Increased heat exchanger area (extension of surface area or addition of coil rows).

• Use of forced convection condenser (for upright freezers)

• Improved efficiency fan motors (brushless DC)

• Adaptive Defrost

During the preliminary analysis public meeting, stakeholders commented on several aspects of 

VIP technology, suggesting that this technology should be screened out. DOE’s investigation of 

one of these issues, uncertainty of VIP supply, is presented in appendix 4-A.
4-14

REFERENCES

 

1 Pisipati, J.S. and Godbey, J.A. “Performance of Carbon Black-Containing Polyurethane 

Foam in Domestic Refrigerators,” Journal of Cellular Plastics, 1996. Vol. 32, No. 2, 108-

138. <http://cel.sagepub.com/cgi/content/abstract/32/2/108>

2 American Council for an Energy-Efficient Economy. "One kWh/day Refrigerator," Emerging 

Technologies & Practices, 2004. Washington, DC.

3 Belko, John. Novel Fan Design Offers Energy Savings to Refrigeration Market, 2007. A.O. 

Smith Electrical Products Company.

<http://www.aosmithmotors.com/pdf/documents/pax%20fan%20evap%20%20technical%20

paper%20_j%20belko_-2007.pdf> (Accessed September 26, 2007.)

4 Coulter, W.H. and Bullard, C.W. “ An Experimental Analysis of Cycling Losses in Domestic 

Refrigerator-Freezers,” ASHRAE Transactions, 1997. Vol. 103, Pt. 1.

5 U.S. Department of Energy-Office of Codes and Standards. Technical Support Document: 

Energy Efficiency Standards for Consumer Products: Refrigerators, Refrigerator-Freezers, 

and Freezers, July 1995. Washington, DC. DOE/EE-0064. p. 3-8.

6 U.S. Department of Energy-Office of Codes and Standards. Technical Support Document: 

Energy Efficiency Standards for Consumer Products: Refrigerators, Refrigerator-Freezers, 

and Freezers, July 1995. Washington, DC. DOE/EE-0064. p. 3-8.

7 Underwriters Laboratories, Standard 250, “Household Refrigerators and Freezers”, Edition 

10, November 1, 1993.

8 Lorenz, A. and Meutzner, K. “On application of non-azeotropic two component refrigerants 

in domestic refrigerator and home freezers,” Proceedings of the XIV International Congress 

of Refrigeration, 1975. Moscow.

9 Liu, Z., Haider, I., and Radermacher, R. “Simulation and Test Results of Hydrocarbon 

Mixtures in a Modified-Lorenz-Meutzner Cycle Domestic Refrigerator,” HVAC&R 

Research, Vol. 1, No. 2, April,, 1995.

10 http://www.globalcooling.nl/technologyoverview.html#perform

11 Janssen, M. and P.Beks, “Measurement and Application of Performance Characteristics of a 

Free Piston Stirling Cooler”, presented at the Ninth International Refrigeration and Air 

Conditioning Conference at Purdue, 2002.
5-i

CHAPTER 5: ENGINEERING ANALYSIS

TABLE OF CONTENTS

5.1 INTRODUCTION ........................................................................................................... 5-1

5.2 PRODUCT CLASSES ANALYZED.............................................................................. 5-1

5.3 METHODOLOGY OVERVIEW.................................................................................... 5-2

5.4 EFFICIENCY LEVELS................................................................................................... 5-4

5.4.1 Baseline Units based on the Current Test Procedure........................................... 5-4

5.4.2 Baseline Efficiency Definitions Based on the Proposed Test Procedure ............ 5-6

5.4.2.1 Data Illustrating the Impact of Test Procedure Changes......................... 5-7

5.4.2.2 Establishment of Baseline Energy—Adjusted Volume Relationships 

Based on the New Test Procedure ..................................................................... 5-11

5.4.2.3 Preliminary Investigation of the Slope of the Energy Use Curve.......... 5-15

5.4.2.4 Energy Use Curve Slope Changes for Product Classes 4, 5, and 5A .... 5-16

5.4.2.5 Adjusted Baseline Energy Use Equations.............................................. 5-20

5.4.3 Incremental Efficiency Levels........................................................................... 5-20

5.4.4 Maximum Technology Level............................................................................. 5-22

5.5 DATA COLLECTION .................................................................................................. 5-24

5.5.1 Manufacturer-Submitted Shipment and Cost Data from AHAM...................... 5-24

5.5.2 Component Vendor Data ................................................................................... 5-25

5.5.3 Reverse Engineering .......................................................................................... 5-26

5.5.3.1 Selection of Products for Reverse Engineering ..................................... 5-26

5.5.3.2 Collection of Energy Modeling Data..................................................... 5-27

5.5.4 Manufacturer Interviews.................................................................................... 5-29

5.5.5 Energy testing .................................................................................................... 5-29

5.6 MANUFACTURING COST MODELING................................................................... 5-31

5.6.1 Generation of Bills of Materials ........................................................................ 5-31

5.6.2 Cost Structure of the Spreadsheet Models......................................................... 5-31

5.6.3 Cost Model and Definitions............................................................................... 5-32

5.6.3.1 Cost Definitions..................................................................................... 5-32

5.6.4 Cost Model Assumptions Overview .................................................................. 5-33

5.6.4.1 Fabrication Estimates............................................................................. 5-34

5.6.4.2 Production Volumes Assumptions......................................................... 5-34

5.6.4.3 Factory Parameters Assumptions........................................................... 5-35

5.6.4.4 Material Cost Assumptions.................................................................... 5-35

5.6.5 Manufacturing Production Cost......................................................................... 5-35

5.6.6 Incremental Cost Estimates................................................................................ 5-36

5.6.6.1 Overhead and Depreciation Costs.......................................................... 5-37

5.6.6.2 Depreciation Costs for Insulation Thickness Increases......................... 5-38

5.6.6.3 G&A and Profit...................................................................................... 5-39

5.7 ENERGY MODELING................................................................................................. 5-39

5.7.1 Energy Model development............................................................................... 5-40

5.7.2 Supplemental Spreadsheet Models.................................................................... 5-41

5.7.3 Development and Calibration of ERA Current Energy Test Models................ 5-42
5-ii

5.7.4 Adjustments to Energy Models to Represent Baseline Products Tested Under the 

Proposed Test Procedure................................................................................................ 5-46

5.8 DESIGN OPTIONS....................................................................................................... 5-48

5.8.1 Increased Insulation Thickness.......................................................................... 5-49

5.8.2 Isobutane Compressor........................................................................................ 5-50

5.8.3 Vacuum-Insulated Panels................................................................................... 5-52

5.8.4 Improved Compressor Efficiency...................................................................... 5-53

5.8.5 Variable-Speed Compressor .............................................................................. 5-56

5.8.6 Increased Evaporator Surface Area ................................................................... 5-58

5.8.7 Increased Condenser Surface Area .................................................................... 5-59

5.8.8 Brushless DC Fan Motors.................................................................................. 5-59

5.8.9 Adaptive Defrost................................................................................................ 5-60

5.8.10 Variable Anti-Sweat Heater Control.................................................................. 5-61

5.8.11 Forced Convection Condenser........................................................................... 5-62

5.9 ENGINEERING ANALYSIS RESULTS ..................................................................... 5-62

5.9.1 DOE Cost-Efficiency Curves............................................................................. 5-62

LIST OF TABLES

Table 5.2.1 Product Classes Analyzed in Engineering Analysis................................................. 5-2

Table 5.4.1 Refrigeration Product Current Energy Conservation Standards (Baseline Energy Use 

under Current Test Procedure)..................................................................................................... 5-5

Table 5.4.2 Proposed Cabinet Temperature Changes for the DOE Test Procedure .................... 5-6

Table 5.4.3 Volume Adjustment Factors..................................................................................... 5-6

Table 5.4.4 Compartment Volume Calculation Changes ............................................................ 5-7

Table 5.4.5 Compartment Temperature and Adjusted Volume Change Data provided by 

AHAM—Current Test ................................................................................................................. 5-8

Table 5.4.6 Compartment Temperature and Adjusted Volume Change Data provided by AHAM-

-Proposed Test ............................................................................................................................. 5-9

Table 5.4.7 Compartment Temperature and Adjusted Volume Change Data provided by 

AHAM—Impact ........................................................................................................................ 5-10

Table 5.4.8 Energy Use Impact of Compartment Temperature Changes: Data Developed by DOE

.................................................................................................................................................... 5-10

Table 5.4.9 Approach for Establishing Baseline Energy--Adjusted Volume Relationships..... 5-12

Table 5.4.10 Preliminary Baseline Energy Consumption based on Proposed Test Procedure.. 5-14

Table 5.4.11 DOE Preliminary Assessment of the Slope of the Energy Use Curve ................. 5-15

Table 5.4.12 Adjusted Baseline Energy Use Equations ............................................................ 5-20

Table 5.4.13 Incremental Efficiency Levels for Freestanding Products (% Energy Use Less than 

Baseline) .................................................................................................................................... 5-21

Table 5.4.14 Incremental Efficiency Levels for Built-In Products............................................ 5-21

Table 5.4.15 Maximum Available Levels (%Energy Use Less than Baseline)........................ 5-22

Table 5.4.16 Maximum Technology Levels and Design Options............................................. 5-24

Table 5.5.1 Component Vendors Contacted by DOE during Engineering Analysis................. 5-26

Table 5.5.2 Selected Units for Reverse-Engineering and Energy Testing ................................ 5-27
5-iii

Table 5.5.3 Additional Thermocouple Locations for Preliminary Analysis Energy Tests........ 5-30

Table 5.5.4 High-Efficiency Refrigeration Product Test Results.............................................. 5-31

Table 5.6.1 Cost Model In-House Manufacturing Operation Assumptions.............................. 5-34

Table 5.6.2 Refrigerator & Freezer Factory Parameter Assumptions ....................................... 5-35

Table 5.6.3 Preliminary Analysis Overhead and Depreciation Cost Ratios.............................. 5-38

Table 5.6.4 Greenfield Depreciation Costs per Product ............................................................ 5-39

Table 5.8.1 Design Options by Product Class ........................................................................... 5-49

Table 5.8.2 Teardown Product Fan Power Input ....................................................................... 5-60

Table 5.9.1 Incremental Manufacturer Selling Price Results for Standard-Size RefrigeratorFreezers...................................................................................................................................... 5-63

Table 5.9.2 Incremental Manufacturer Selling Price Results for Standard-Size Freezers......... 5-63

Table 5.9.3 Incremental Manufacturer Selling Price Results for Compact Refrigerators and 

Freezers...................................................................................................................................... 5-64

Table 5.9.4 Incremental Manufacturer Selling Price Results for Built-In 

Refrigeration Products............................................................................................................... 5-64

LIST OF FIGURES

Figure 5.3.1 Flow Diagram of Engineering Analysis Methodology ........................................... 5-3

Figure 5.4.1 Comparison of Preliminary and Adjusted-Slope Energy Use Curves 

(Product Class 4)........................................................................................................................ 5-17

Figure 5.4.2 Product Class 5 Energy Use Equation Slope Data ................................................ 5-18

Figure 5.4.3 Comparison of Preliminary and Adjusted-Slope Energy Use Curves 

(Product Class 5)........................................................................................................................ 5-19

Figure 5.4.4 Maximum Efficiency Levels Available by Product Class .................................... 5-23

Figure 5.6.1 Full Production Costs............................................................................................ 5-36

Figure 5.7.1 ERA Analysis for Refrigerator-Freezers Compared with EnergyGuide Labels and 

Energy Test Measurements........................................................................................................ 5-44

Figure 5.7.2 ERA Analysis for Freezers Compared with EnergyGuide Labels and Energy Test 

Measurements............................................................................................................................ 5-45

Figure 5.7.3 ERA Analysis for Compact Refrigerators and Freezers Compared with 

EnergyGuide Labels and Energy Test Measurements............................................................... 5-45

Figure 5.8.1 Energy Benefit of Isobutane Compared with HFC-134a ...................................... 5-51

Figure 5.8.2 Compressor Efficiency Data.................................................................................. 5-54

Figure 5.8.3 Incremental Cost for Single-Speed Compressors for Standard-Size Products...... 5-55

Figure 5.8.4 Efficiency Curve for Low Capacity Compressors................................................. 5-56
5-1

CHAPTER 5. ENGINEERING ANALYSIS

5.1 INTRODUCTION

The engineering analysis establishes the relationship between manufacturer production 

cost and energy consumption for the refrigerators, refrigerator-freezers, and freezers 

covered in this rulemaking. The “cost-efficiency” relationship serves as the basis for costbenefit calculations in terms of individual customers, manufacturers, and the Nation, 

from which the most economically-justified, technically feasible standard level is 

ultimately determined.

The inputs into the engineering analysis include baseline characteristics for each product 

class addressed in the market and technology assessment (chapter 3), the design options 

from the screening analysis (chapter 4), as well as cost and energy use data collected 

from manufacturers, component vendors, reverse-engineering, and energy testing. The 

output of the engineering analysis is the cost-efficiency relationship for each product 

class independent of cabinet volume, which will be used in the life-cycle and payback 

period analyses (chapter 8).

This chapter covers the product classes DOE analyzed, and the methodology used by 

DOE to develop manufacturing costs, energy consumption, and extend the analysis to 

low-volume product classes, as well as the results of these analyses. 

5.2 PRODUCT CLASSES ANALYZED

In the preliminary engineering analysis, DOE analyzed the seven product classes listed in 

the top portion of Table 5.2.1. DOE considers these classes to be representative of 

products currently shipped by the residential refrigerator, freezer, and refrigerator-freezer 

industry based on total shipments. These product classes represent close to 90% of the 

shipments of refrigerators, refrigerator-freezers, and freezers. DOE did not directly 

analyze all covered product classes in order to carry out the analysis as efficiently as 

possible. DOE proposes extrapolation of energy standards to the remaining product 

classes as described in section 2.15 of chapter 2 of the TSD (this discussion of 

extrapolation of the standards, initially presented in the preliminary TSD, has been 

revised to reflect the proposed approach for the NOPR).

DOE also analyzed four product classes of built-in products for the NOPR analysis. DOE 

selected one representative built-in product for analysis for each of these product classes. 

DOE judged the representativeness of these product selections based on discussions with 

manufacturers regarding design option groupings required to meet key efficiency levels 

with built-in products.
5-2

Table 5.2.1 Product Classes Analyzed in Engineering Analysis

Product 

Class Equipment Description

Product Classes Analyzed in Preliminary Analysis

3 Refrigerator-freezers—automatic defrost with top-mounted freezer without 

through-the-door ice service 

5 Refrigerator-freezers—automatic defrost with bottom-mounted freezer without 

through-the-door ice service

7 Refrigerator-freezers—automatic defrost with side-mounted freezer with 

through-the-door ice service 

9 Upright freezers with automatic defrost

10 Chest freezers and all other freezers except compact freezers

11 Compact refrigerators and refrigerator-freezers with manual defrost

18 Compact chest freezers

Additional Product Classes Analyzed in NOPR Analysis

3A-BI Built-in all-refrigerators—automatic defrost

5-BI Built-in refrigerator-freezers—automatic defrost with bottom-mounted freezer 

without an automatic icemaker

7-BI Built-in refrigerator-freezers—automatic defrost with side-mounted freezer 

with through-the-door ice service

9-BI Built-in upright freezers with automatic defrost without an automatic icemaker

5.3 METHODOLOGY OVERVIEW

This section describes the analytical methodology DOE used in the engineering analysis. 

In this rulemaking, DOE has adopted a combined efficiency level/design option/reverse 

engineering approach to developing cost-efficiency curves. DOE established efficiency 

levels defined as percent energy use lower than that of baseline efficiency products, 

considering just the energy use that is not associated with production of ice. DOE took 

this approach in order to allow comparison of information developed from different 

sources. However, DOE’s analysis is based on the efficiency improvements associated 

with groups of design options. Also, DOE developed manufacturing cost models based 

heavily on reverse engineering of products to calculate some of the incremental costs 

associated with improvement of efficiency.

Figure 5.3.1 presents the steps in the analysis and illustrates how they contributed to 

developing the cost-efficiency curves. The process began with data collection and ended 

with the incremental cost curve results.

As input to the analysis, DOE requested incremental cost-efficiency data from the 

industry. The Association of Home Appliance Manufacturers (AHAM) provided 

aggregated incremental cost data for a number of the product classes under analysis. 

Questions about the collection and aggregation process for this data arose during the 

preliminary analysis public meeting and comment period, thus increasing the emphasis 

for use of the DOE analysis results for the downstream rulemaking analyses. The DOE 
5-3

engineering analysis consisted of analytically-derived cost-efficiency curves for the 

product classes listed in Table 5.2.1. 

To develop the analytically-derived cost-efficiency curves, DOE collected information 

from various sources on the manufacturing cost and energy use reduction characteristics 

of each of the design options. DOE reviewed product literature, conducted reverseengineering of current products, and interviewed component vendors of compressors, fan 

motors, insulation, and heat exchangers. For the built-in product classes analyzed, DOE 

obtained detailed design data and specifications for the products analyzed from their 

manufacturer rather than conducting reverse engineering on purchased products. DOE 

also conducted interviews with manufacturers, the first during the preliminary analysis 

and the second in conjunction with the manufacturer impact analysis interviews. The 

engineering questionnaires associated with both of these sets of discussions are 

reproduced in appendix 12-A.

Figure 5.3.1 Flow Diagram of Engineering Analysis Methodology

Cost information from the vendor interviews and engineering questionnaires provided 

input to the manufacturing cost model. Incremental costs associated with specific design 

options were calculated using the cost model. Energy use reduction was modeled with a 

modified version of the established EPA Refrigerator Analysis (ERA) program which 

was used in the previous refrigerator rulemaking. The reverse engineering, vendor 

interviews, and manufacturer interviews provided input for the energy analysis. The 

incremental cost estimates and the energy modeling results together constitute the energy 

efficiency curves presented in this chapter.
5-4

5.4 EFFICIENCY LEVELS

5.4.1 Baseline Units based on the Current Test Procedure

DOE selected baseline units as reference points for all of the product classes, against 

which DOE determined changes resulting from use of energy saving design options. The 

baseline unit in each product class represents the basic characteristics of equipment in 

that class. A baseline unit is a unit that just meets current required energy conservation 

standards and provides basic consumer utility.

As discussed in chapter 3, DOE has proposed revising the energy test procedure for 

refrigerators, refrigerator-freezers, and freezers. Some of the proposed changes to the test 

procedure such as changes in compartment temperatures would result in changes in the 

measured energy consumption. The proposed test procedure changes would also affect 

the measured size of the refrigerators, expressed as adjusted volume. Since the maximum 

energy use for residential refrigeration products is expressed as a function of adjusted 

volume, the change in adjusted volume also would affect the definition of baseline 

products. This section discusses definitions of baseline units for the engineering analysis 

based on the current test procedure, while the next section discusses modified definitions 

for baseline refrigeration products based on the proposed revised test procedure.

For this rulemaking, DOE established baseline efficiency levels as the current federal 

energy conservation standards, expressed as maximum annual energy consumption as a 

function of the product’s adjusted volume, as shown in Table 5.4.1. These definitions are 

based on testing according to the current energy test procedure. The table does not show

all of the product classes proposed for this rulemaking. The baseline energy use 

characteristics for the product classes DOE proposes to separate from their current 

product classes (all-refrigerators, built-in products, and products with automatic 

icemakers) cannot be distinguished from other products of their current product classes 

because there is no baseline energy difference under the current test procedure.
5-5

Table 5.4.1 Refrigeration Product Current Energy Conservation Standards 

(Baseline Energy Use under Current Test Procedure)

Product Class Equations for Maximum 

Energy Use (kWh/yr)

1. Refrigerators and refrigerator-freezers with manual defrost. 8.82AV + 248.4

0.31av + 248.4

2. Refrigerator-freezer—partial automatic defrost. 8.82AV + 248.4

0.31av + 248.4

3. Refrigerator-freezer—automatic defrost with top-mounted freezer without 

through-the-door ice service and all-refrigerator—automatic defrost.

9.80AV + 276.0

0.35av + 276.0

4. Refrigerator-freezers—automatic defrost with side-mounted freezer without 

through-the-door ice service.

4.91AV + 507.5

0.17av + 507.5

5. Refrigerator-freezers—automatic defrost with bottom-mounted freezer 

without through-the-door ice service.

4.60AV + 459.0

0.16av + 459.0

6. Refrigerator-freezers—automatic defrost with top-mounted freezer with 

through-the-door ice service.

10.20AV + 356.0

0.36av + 356.0

7. Refrigerator-freezers—automatic defrost with side-mounted freezer with 

through-the-door ice service. 

10.10AV + 406.0

0.36av + 406.0

8. Upright freezers with manual defrost. 7.55AV + 258.3

0.27av + 258.3

9. Upright freezers with automatic defrost. 12.43AV + 326.1

0.44av + 326.1

10. Chest freezers and all other freezers except compact freezers. 9.88AV + 143.7

0.35av + 143.7

11.Compact refrigerators and refrigerator-freezers with manual defrost. 10.70AV + 299.0

0.38av + 299.0

12. Compact refrigerator-freezer—partial automatic defrost. 7.00AV + 398.0

0.25av + 398.0

13. Compact refrigerator-freezers—automatic defrost with top-mounted 

freezer and compact all-refrigerator—automatic defrost.

12.70AV + 355.0

0.45av + 355.0

14. Compact refrigerator-freezers—automatic defrost with side-mounted 

freezer.

7.60AV + 501.0

0.27av + 501.0

15. Compact refrigerator-freezers—automatic defrost with bottom-mounted 

freezer.

13.10AV + 367.0

0.46av + 367.0

16. Compact upright freezers with manual defrost. 9.78AV + 250.8

0.35av + 250.8

17. Compact upright freezers with automatic defrost. 11.40AV + 391.0

0.40av + 391.0

18. Compact chest freezers. 10.45AV + 152.0

0.37av + 152.0

5A. Refrigerator-freezer—automatic defrost with bottom-mounted freezer with 

through-the-door ice service.

5.0AV + 539.0

0.18av + 539.0

10A. Chest freezers with automatic defrost. 14.76AV + 211.5

0.52av + 211.5

AV= adjusted volume in cubic feet; av = adjusted volume in liters;

Refrigerator-Freezers: AV = fresh food internal volume + 1.63 * freezer internal volume

Freezers: AV = 1.73 * freezer internal volume

Refrigerators (single-door): AV = fresh food internal volume + 1.44 * freezer internal volume

All-Refrigerators: AV = internal volume
5-6

5.4.2 Baseline Efficiency Definitions Based on the Proposed Test Procedure 

As discussed in chapter 3, DOE has proposed revisions in the energy test procedure to 

harmonize with expected test temperatures under consideration for IEC test procedure 

62552 and to simplify calculation of refrigerated volumes. The proposed test temperature 

changes are summarized in Table 5.4.2 below. 

Table 5.4.2 Proposed Cabinet Temperature Changes for the DOE Test Procedure

Equipment Type Fresh Food Compartment 

Temperature °F

Freezer Compartment 

Temperature °F

Current Proposed Current Proposed

Refrigerator-Freezer 45 39 5 0

All-Refrigerator 38 39 Not Applicable

Refrigerator w/ 

Freezer Compartment 45 39 15 15 (No Change)

Freezer Not Applicable 0 0 (No Change)

The temperature changes also impact the volume adjustment factor used to determine the 

adjusted volume. This factor is multiplied by the freezer compartment volume in the 

adjusted volume calculation. Current and proposed volume adjustment factors are 

summarized in Table 5.4.3 below.

Table 5.4.3 Volume Adjustment Factors

Product Current Test Procedure Proposed Test Procedure

Revisions

Refrigerator-Freezer 1.63 1.76

Basic Refrigerator* 1.44 1.47

Freezer 1.73 1.76

All-Refrigerator** 1.00 1.00

*A basic refrigerator is a refrigerator with a freezer compartment with volume greater 

than 0.5 ft3

.

**An all-refrigerator can have a freezer compartment with volume less than 0.5 ft3

.

The key changes in the volume measurement calculation between the current test 

procedure (which references the volume calculation procedure in AHAM standard HRF1-1979) and the proposed revised test procedure (which references the new procedure in 

AHAM standard HRF-1-2008) are summarized in Table 5.4.4 below. Adjusted volume 

would be impacted both by the change in the volume adjustment factor discussed above

and the change in the volume measurement.
5-7

Table 5.4.4 Compartment Volume Calculation Changes

Item AHAM HRF-1-1979 AHAM HRF-1-2008

Expected 

Effect on 

Volume

Automatic Ice Maker 

Storage Bin Included (4.2.1.1a)

Would be included 

under “removable 

containers” but 

dispenser MAY NOT

be included

None*

Ice Makers Included (4.2.1.1a) No Mention None*

Water Coolers Included (4.2.1.1a) No Mention None*

Door Shelf Fronts and 

Bottoms Included (4.2.1.1b)

Shelves molded into 

the inner door panel 

NOT included (4.2.2)

Decrease

Volume between the 

Deductible Door Dikes 

and Cabinet Breaker 

Strips or Adjacent 

Liner Wall

Not Included 

(4.2.1.2d)

No mention of 

exclusion, so probably 

included.

Increase

Shelf Hangers & Shelf 

and Pan Rails

Not included for 

fixed projections if 

collective volume is 

>0.05 ft3 (4.2.1.2e)

Could be interpreted as 

part of shelving and 

would thus be 

included.

Increase

*AHAM HRF-1-2008 doesn’t mention this item or is not fully clear regarding its 

treatment for the volume calculation, but it is expected that manufacturers would use the 

AHAM HRF-1-1979 approach. The proposed test procedure revision explicitly includes

the automatic icemaker and storage bin in the volume calculation.

5.4.2.1 Data Illustrating the Impact of Test Procedure Changes

The different compartment temperatures of the proposed revised energy test procedure 

would change test energy use for refrigerators and refrigerator-freezers. In addition, both 

the impact of the modified temperatures on the adjusted volume and the modified volume 

calculation method would change adjusted volumes. For these reasons, it is necessary to 

establish modified relationships between energy use and adjusted volume to define 

baseline products. AHAM provided data for a number of the product classes, presented in 

Table 5.4.5 through Table 5.4.7 below (this is referred to as the AHAM TP Change data).

The data illustrates the impact of the compartment temperature changes and the volume 

calculation method changes of the proposed new test procedure, but does not consider 

energy use associated with production of ice, which has been integrated with the 

proposed test procedure energy use metric.

The AHAM TP Change data for product classes 11 and 13 both show energy use 

reductions, indicating that the products represented by these data are primarily all-
5-8

refrigerators. AHAM was not able to separately provide data for the all-refrigerators and 

the refrigerators of these product classes that have freezer compartments larger than 0.5 

cu. ft., because insufficient data was provided by manufacturers for separate aggregation.

Additional data sources which provide indication of the impacts of the test temperature 

changes for standard-size refrigerator-freezers include (1) energy test measurements for 

the refrigerator-freezers tested as part of this rulemaking, and (2) calculation of the 

energy impacts using ERA, the energy modeling tool used for this rulemaking. The 

energy use impacts indicated by these sources are shown in Table 5.4.8. DOE conducted 

these energy tests and calculations for three products of each of the seven product classes 

analyzed during the preliminary analysis (see Section 5.5.3.1 for discussion on selection 

of products for reverse engineering and energy testing).

Table 5.4.5 Compartment Temperature and Adjusted Volume Change Data provided by 

AHAM—Current Test

Product 

Class

Fresh Food 

Volume

Freezer 

Volume

Adjusted 

Volume

Energy 

Use

3 (R-F)

Average

Standard Deviation

Number of Samples

12.82 5.02 20.92 420

3.54 1.82 6.53 55

19 19 19 19

3A (AR)

Average

Standard Deviation

Number of Samples

19.26

Not 

Applicable

19.26 374

3.4 3.4 54

11 11 11

5

Average

Standard Deviation

Number of Samples

14.21 5.15 22.62 493

1.85 1.02 3 55

18 18 18 18

7

Average

Standard Deviation

Number of Samples

15.77 9.32 30.95 617

1.61 0.87 2.53 68

24 24 24 24

9

Average

Standard Deviation

Number of Samples

Not 

Applicable

16.85 29.14 603

4.88 8.45 136

18 18 18

11

Average

Standard Deviation

Number of Samples

4.38

Not 

Provided

4.65 334

1.38 1.38 44

13 13 13

13

Average

Standard Deviation

Number of Samples

4.75

Not 

Provided

4.77 296

1.18 1.15 77

12 12 12

Note: R-F refers to refrigerator-freezers; AR refers to all-refrigerators.
5-9

Table 5.4.6 Compartment Temperature and Adjusted Volume Change Data 

provided by AHAM--Proposed Test

Product 

Class

Fresh Food 

Volume

Freezer

Volume

Adjusted 

Volume

Energy 

Use

3 (R-F)

Average

Standard Deviation

Number of Samples

12.79 4.96 21.44 472

3.51 1.78 6.59 53

19 19 19 18

3A (AR)

Average

Standard Deviation

Number of Samples

19.51

Not 

Applicable

19.51 364

3.51 3.51 53

11 11 11

5

Average

Standard Deviation

Number of Samples

14.42 5.25 23.12 582

1.88 1 3.01 68

18 18 18 18

7

Average

Standard Deviation

Number of Samples

15.95 9.01 31.45 702

1.79 0.75 2.49 82

24 24 24 24

9

Average

Standard Deviation

Number of Samples

Not 

Applicable

16.84 29.47 603

5.04 8.73 136

18 18 18

11

Average

Standard Deviation

Number of Samples

4.34

Not 

Provided

4.61 324

1.36 1.36 48

13 13 13

13

Average

Standard Deviation

Number of Samples

4.8

Not 

Provided

4.83 285

1.23 1.2 73

12 12 12

Note: R-F refers to refrigerator-freezers; AR refers to all-refrigerators.
5-10

Table 5.4.7 Compartment Temperature and Adjusted Volume Change Data 

provided by AHAM—Impact

Product 

Class

Fresh Food 

Volume

Freezer 

Volume

Adjusted 

Volume

Energy 

Use

3 (R-F)

Average

Standard Deviation

Number of Samples

-0.1% -1.1% 2.8% 12.4%

0.6% 0.9% 2.3% 6.9%

19 19 19 18

3A (AR)

Average

Standard Deviation

Number of Samples

1.2%

Not 

Applicable

1.2% -2.6%

1.0% 1.0% 1.1%

11 11 11

5

Average

Standard Deviation

Number of Samples

1.5% 2.2% 2.2% 18.2%

1.2% 2.2% 1.2% 3.7%

18 18 18 18

7

Average

Standard Deviation

Number of Samples

1.0% -3.1% 1.6% 14.0%

2.0% 4.6% 2.0% 6.7%

24 24 24 24

9

Average

Standard Deviation

Number of Samples

Not 

Applicable

-0.4% 0.9% 0.0%

2.5% 2.2% 0.0%

18 18 18

11

Average

Standard Deviation

Number of Samples

-0.7%

Not 

Provided

-0.6% -3.1%

1.9% 1.6% 1.4%

13 13 13

13

Average

Standard Deviation

Number of Samples

0.9%

Not 

Provided

1.0% -3.6%

1.6% 1.4% 0.8%

12 12 12

Note: R-F refers to refrigerator-freezers; AR refers to all-refrigerators.

Table 5.4.8 Energy Use Impact of Compartment Temperature Changes: Data 

Developed by DOE

Product 

Class

Product Description Impact based on energy 

measurements

Impact based on 

ERA modeling

3 16 ft3 Top-Mount R-F 19.1% 14.2%

21 ft3 Top-Mount R-F 27.7% 15.5%

21 ft3 E* Top-Mount R-F 26.6% 14.1%

5 18.5 ft3 E* Bottom-Mount R-F 12.5% 13.6%

25 ft3 E* Bottom-Mount R-F 1 27.6% 13.8%

25 ft3 E* Bottom-Mount R-F 2 17.3% 14.4%

4 22 ft3 Side-Mount R-F† 17.7% 12.5%

7 26 ft3 Side-Mount R-F 24.5% 12.9%

26 ft3 E* Side-Mount R-F 25.0% 12.2%

11 1.7 ft3 Compact Refrigerator -4.5% -2.3%

4.0 ft3 Compact Refrigerator Not Tested 13.7%

†This product was thought to be product class 7 when purchased.
5-11

The AHAM TP Change data shows reasonable agreement with the DOE modeled energy 

use impacts. However, the DOE energy measurements indicate a higher sensitivity to the 

temperature change of the new test procedure. The AHAM data shows that there can be 

significant variation in the sensitivity of different refrigerator-freezer products to the test 

temperature changes, particularly for product classes 3 and 7. The two compact 

refrigerators of Table 5.4.8 exhibit different responses to the compartment temperature 

change because the 1.7 ft3 refrigerator has a freezer compartment smaller than 0.5 ft3 and 

is tested as an all-refrigerator, while the 4.0 ft3 refrigerator has a freezer compartment just 

larger than 0.5 ft3, requiring that it be tested as a basic refrigerator.

5.4.2.2 Establishment of Baseline Energy—Adjusted Volume Relationships Based on 

the New Test Procedure

The available data to inform the establishment of baseline energy versus adjusted volume 

relationships based on the proposed revised test procedure is discussed in Section 5.4.2.1. 

While this data does not address every product class, DOE proposes to use it as the basis 

for establishing the baseline relationships. The approach DOE used to develop these 

relationships for all the product classes is summarized in Table 5.4.9 below. Note that 

product classes 1, 3, 11, and 13 are split because, while the all-refrigerators have reduced 

energy use with the proposed new test procedure, the products which include freezers 

have significantly higher energy use. This applies to many products of product class 11

and some of product class 1 that have freezer compartments smaller than 0.5 ft3

, which 

allows them to be classified and tested as all-refrigerators rather than basic refrigerators. 

The test procedure impact of this classification is that the refrigerator compartment 

temperature would be raised for all-refrigerators, while it would be reduced for basic 

refrigerators under the proposed test procedure.
5-12

Table 5.4.9 Approach for Establishing Baseline Energy--Adjusted Volume 

Relationships 

Product Class Approach

1 Use modeling with ERA for temperature, assume negligible 

adjusted volume impact based on AHAM data for PC11.

1A 

(All-Refrigerators)

Use AHAM TP Change aggregated data of product class 3 allrefrigerators.

3 (RefrigeratorFreezers)Use AHAM TP Change aggregated data.

3A 

(All-Refrigerators)

Use AHAM TP Change aggregated data.

4 Use AHAM TP Change aggregated data of product class 7. **

5 Use AHAM TP Change aggregated data. **

5A Use AHAM TP Change aggregated data of product class 5. **

6 Use AHAM TP Change aggregated data of product class 3 

refrigerator-freezers.

7 Use AHAM TP Change aggregated data.

8 (volume only) Assume negligible volume impact due to simplicity of manual 

defrost freezer interior.

9 (volume only) Use AHAM TP Change aggregated data.

10 (volume only) Assume negligible impact due to simplicity of manual defrost 

freezer interior.

10A (volume only) Use AHAM TP Change aggregated data for PC9.

11 Use modeling with ERA for temperature, assume negligible 

adjusted volume impact based on AHAM data.*

11A

(All-Refrigerators)

Use modeling with ERA for temperature, assume negligible 

adjusted volume impact based on AHAM data.*

13 (RefrigeratorFreezers)Use AHAM TP Change aggregated data of product class 3 

refrigerator-freezers.*

13A

(All-Refrigerators)

Use AHAM TP Change aggregated data of product class 3 allrefrigerators.*

14 Use AHAM TP Change aggregated data of product class 7.

15 Use AHAM TP Change aggregated data of product class 5.

16 (volume only) Assume negligible volume impact due to simplicity of manual 

defrost freezer interior.

17 (volume only) Use AHAM TP Change aggregated data for PC9.

18 (volume only) Assume negligible volume impact due to simplicity of manual 

defrost freezer interior.

*The AHAM energy use increase data cannot be used for this product class, because it is 

not known how many of the products represented by the AHAM data are all-refrigerators.

**DOE subsequently modified the proposed baseline energy use equations for these 

product classes to adjust their slopes (see sections 5.4.2.4 and 5.4.2.5 below).
5-13

Note: For product classes 8, 10, 16, and 18, while the volume impact is assumed to be 

negligible, the adjusted volume increases according to the increase in the volume 

adjustment factor.

The methodology for determining new baseline energy—adjusted volume curves given 

the data indicating the impacts on the energy use and adjusted volume for a given product 

class is as follows. The proposed energy use and the current energy use for a product are 

represented as being proportional using an Energy Standard Adjustment Factor (ESAF).

BECNEWTP = ESAF × BECCURTP Equation 5.4.1

Where:

BECNEWTP = Baseline energy consumption using the new test procedure;

BECCURTP = Baseline energy consumption using the current test procedure.

The ESAF is considered to be a function only of product class. Dependence on adjusted 

volume or efficiency level cannot be determined based on the available data.

Similarly, the adjusted volume for a product under the proposed test procedure is related 

to the adjusted volume under the current test procedure using a Volume Calculation 

Adjustment Factor (VCAF).

AVNEWTP = VCAF × AVCURTP Equation 5.4.2

Where:

AVNEWTP = Adjusted Volume using the new test procedure;

AVCURTP = Adjusted Volume using the current test procedure.

The VCAF, like the ESAF, is considered to be a function only of product class. Baseline 

energy use for the current test procedure is expressed as follows, where the constants A 

and B are a function of product class.

BECCURTP = A × AVCURTP + B Equation 5.4.3

Combining Equations 5.4.1 through 5.4.3 gives the following relationship for the baseline 

energy consumption based on the new test procedure.

A AV (ESAF B) VCAF

ESAF B

VCAF

AV BEC ESAF A NEWTP

NEWTP

NEWTP × + ×



 



  = ×



 



 = × × +

Hence, the baseline energy consumption for the product class for the new test procedure 

can be represented as a straight-line relationship based on new constants ANEW and BNEW, 

where the new constants are related to the current constants as follows.
5-14

A B ESAF B

VCAF

ESAF ANEW  × NEW = ×



 



 = ;

The baseline energy use based on the expected revised test procedure is presented in 

Table 5.4.10 below for each of the product classes. This baseline energy use includes 

energy use not associated with icemaking. A placeholder with a value of 84 kWh/year 

has been integrated in the proposed test procedure as additional energy use for production 

of ice. This placeholder would be added to the baseline energy curves for products with 

through-the-door ice to obtain the total baseline energy use of these product classes. Also, 

the placeholder would be added to some of the product classes (those which may or may 

Table 5.4.10 Preliminary Baseline Energy Consumption based on Proposed Test 

Procedure

Product Class ESAF VCAF Current Baseline

Energy Use 

(kWh/year)

Proposed Test Procedure 

Baseline Energy Use not 

Including Icemaking 

Energy Use (kWh/year)

1 1.132 1 8.82 AV + 248.4 9.98 AV + 281.2

1A 0.974 1.012 8.82 AV + 248.4 8.49 AV + 241.9

2 1.132 1 8.82 AV + 248.4 9.98 AV + 281.2

3, 3I, 3-BI, 3I-BI 1.124 1.028 9.80 AV + 276.0 10.72 AV + 310.2

3A, 3A-BI 0.974 1.012 9.80 AV + 276.0 9.43 AV + 268.8

4, 4I, 4-BI, 4I-BI 1.14 1.016 4.91 AV + 507.5 5.51 AV + 578.6

5, 5I, 5-BI, 5I-BI 1.182 1.022 4.60 AV + 459.0 5.32 AV + 542.5

5A, 5A-BI 1.182 1.022 5.00 AV + 539.0 5.78 AV + 637.1

6 1.124 1.028 10.20 AV + 356.0 11.15 AV + 400.1

7, 7-BI 1.14 1.016 10.10 AV + 406.0 11.33 AV + 462.8

8 1 1.017 7.55 AV + 258.3 7.42 AV + 258.3

9, 9-BI 1 1.009 12.43 AV + 326.1 12.32 AV + 326.1

10 1 1.017 9.88 AV + 143.7 9.71 AV + 143.7

10A 1 1.009 14.76 AV + 211.5 14.63 AV + 211.5

11 1.125 1 10.70 AV + 299.0 12.04 AV + 336.4

11A 0.977 1 10.70 AV + 299.0 10.45 AV + 292.1

12 1.125 1 7.00 AV + 398.0 7.88 AV + 447.8

13 1.124 1.028 12.70 AV + 355.0 13.89 AV + 399.0

13A 0.974 1.012 12.70 AV + 355.0 12.22 AV + 345.8

14 1.14 1.016 7.60 AV + 501.0 8.53 AV + 571.1

15 1.182 1.022 13.10 AV + 367.0 15.15 AV + 433.8

16 1 1.017 9.78 AV + 250.8 9.61 AV + 250.8

17 1 1.009 11.40 AV + 391.0 11.30 AV + 391.0

18 1 1.017 10.45 AV + 152.0 10.27 AV + 152.0

Note: In the “Current Baseline” equations, AV is calculated using the current volume 

calculation method and adjustment factor, while in the “Proposed” equations, AV is 

calculated using the proposed volume calculation method and adjustment factor (see 

Table 5.4.3)
5-15

not have an icemaker) to represent the total baseline energy use for the corresponding 

product classes that have automatic icemakers. For example, the baseline energy use 

equation for product class 3I is equal to 84 kWh/year plus the baseline energy use 

equation for product class 3. The baseline energy use equations for built-in products are 

equal to the baseline equations for their corresponding freestanding product classes.

5.4.2.3 Preliminary Investigation of the Slope of the Energy Use Curve

During the preliminary analysis, DOE conducted calculations to confirm whether the 

slopes of the baseline energy use—adjusted volume curves for the product classes 

analyzed in depth as part of the engineering analysis are representative of the energy use 

of typical products. DOE conducted these analyses based on the proposed revised test 

procedure. The analysis started with an energy model of a minimally-compliant product 

and examined the trend in calculated energy use as the product size changes with constant 

insulation thickness. For the analysis of compact refrigerators, DOE considered the 

change in efficiency of typically available compressors sized appropriately for the 

product. For standard-size products, the DOE used a constant compressor efficiency in 

the analysis, based on observation that compressor efficiency does not vary significantly 

in the capacity range suitable for most standard-size products (this is discussed in greater 

detail in section 5.8.4). The energy—adjusted volume slopes calculated in this analysis 

are presented in Table 5.4.11 below. The table also shows the slopes of the proposed 

baseline energy use—adjusted volume relationships of Table 5.4.10 above. The 

comparison provides an indication of whether adjustment might be required to the 

proposed baseline energy use relationships, which are based on the current energy 

conservation standards and the expected impacts of the expected revised test procedure. 

Table 5.4.11 DOE Preliminary Assessment of the Slope of the Energy Use Curve

Product Class

Calculated

Energy Curve Slope from 

ERA Models*

Slope from Proposed 

Baseline Energy Use 

Equation (Table 5.4.10)

3 13.3 10.7

5 12.3 5.3

7 11.9 11.3

9 9.4 12.3

10 7.7 9.7

11 16.4 12.0

11A 20 to 35** 10.5

18 4.5 10.3

* Analysis was conducted for both the small and large units analyzed for product 

classes 3, 5, 7, 9, 10, 18. Values shown are averages of slopes for the two ERA 

models.

** The energy use—adjusted volume relationship is nonlinear, with higher slope 

at lower volumes. The slopes indicated are applicable for a range of adjusted 

volumes from 1.7 to 3.6 ft3.
5-16

DOE requested comment on the need for adjustment of the energy use curve slopes and 

requested information supporting such comments during the preliminary analysis phase 

of the rulemaking. 

5.4.2.4 Energy Use Curve Slope Changes for Product Classes 4, 5, and 5A

DOE adjusted the energy equation slopes for product classes 4 (refrigerator-freezers—

automatic defrost with side-mounted freezers without through-the-door ice service) and 5

(refrigerator-freezers—automatic defrost with bottom-mounted freezers without throughthe-door ice service). This section describes the development of the modified baseline 

energy use equations for these products.

Product Class 4

DOE did not obtain data to allow determination of the appropriate slope of the energy use 

equation for product class 4. However, DOE proposes that the slope of the baseline 

energy use equation for product class 7 (refrigerator-freezers—automatic defrost with 

side-mounted freezers with through-the-door ice service) is appropriate also for product 

class 4. This slope is equal to 11.3 (see Table 5.4.10 above).

DOE observed that the range of product total volumes for these products is 20 to 30 cu. 

ft., (based on the database used to develop the information in TSD Chapter 3, section 

3.3.3) representing a range of adjusted volume from 25.1 to 37.7 cu. ft. using the current 

test procedure.

DOE selected a new intercept for the baseline energy use equation for product class 4 so 

that the average energy use impact would be neutral. Since shipment data for the product 

class correlated with volume was not available, DOE selected an intercept that would 

result in the same average energy use for the products at the ends of the size range for the 

product class described above. The resulting equation is 11.3 × AV + 395.3. The new 

curve is compared with the current energy standard and with the preliminary curve in 

Figure 5.4.1 below.
5-17

Figure 5.4.1 Comparison of Preliminary and Adjusted-Slope Energy Use Curves 

(Product Class 4)

Product Class 5

For this product class, DOE obtained data for two pairs of products which allowed 

determination of the energy/adjusted volume slope. For each of these product pairs, (1) 

the refrigeration system designs of the two products of the pair are identical, (2) wall 

thicknesses in corresponding portions of the cabinet are identical, and (3) the two 

products of the pair have different total and adjusted volume. The energy use slope 

associated with these pairs of products is compared with the current energy standard in 

Figure 5.4.2 below. The product data shows that the energy use dependence on adjusted 

volume (i.e. the appropriate slope of the baseline energy use line) is at least twice as high 

as expressed by the current standard.

0

100

200

300

400

500

600

700

800

900

20 25 30 35 40

Annual Energy Usage (kWh/year)

Adjusted Volume (cubic feet)

Current Standard

Preliminary Analysis New Test Baseline

New Test With Adjusted Slope

Slope 4.91

Slope 11.3

Slope 5.51
5-18

Figure 5.4.2 Product Class 5 Energy Use Equation Slope Data

When adjusted for the new test procedure, the slope of 4.6 of the current standard 

increases to 5.32 (see Table 5.4.10 above). In contrast, the slopes for other standard-size 

refrigerator-freezer product classes such as 3 (refrigerator-freezers—automatic defrost 

with top-mounted freezer without through-the-door ice service) and 7 (refrigeratorfreezers—automatic defrost with side-mounted freezer with through-the-door ice service) 

are 10.72 and 11.33. DOE proposes to adjust the slope of the baseline energy use 

equation to 11.0 for product class 5, nearly equal to the average of the slopes for these 

other two product classes.

DOE further proposes to adjust the intercept for the baseline energy use equation for 

product class 5 to a level that would result in neutral impact on the average energy use of 

products within this class. DOE does not have shipment data for every configuration of 

product of the class and for this reason cannot determine exactly the appropriate intercept 

that would provide the same shipment weighted average baseline energy use for both 

low-slope and adjusted-slope equations. Instead, DOE chose an intercept so that the 

average energy use of the two reverse engineered products for product class 5 (with total 

volumes 18.5 and 25 cu. ft.) was the same for the preliminary baseline curve and the new 

adjusted-slope curve. The adjusted-slope curve is shown in Figure 5.4.3 below. The 

adjusted slope equation is 11.0 × AV + 394.2.

0

100

200

300

400

500

600

700

18 20 22 24 26

Annual Energy Usage (kWh/year)

Adjusted Volume (cubic feet)

Product Group 1

Product Group 2

Current Standard

Slope 4.6

Slopes 10.4, 13.1
5-19

Figure 5.4.3 Comparison of Preliminary and Adjusted-Slope Energy Use Curves 

(Product Class 5)

Product Class 5A

DOE proposes adjustment of the slope for product class 5A (refrigerator-freezer—

automatic defrost with bottom-mounted freezer with through-the-door ice service) based 

on the adjusted baseline energy use equation for product class 5. DOE made this 

adjustment in the same way that the current energy standard for this product class was 

established for product class 5A through the exception relief process administered by the 

Office of Hearings and Appeals.1

 1 See, for example, the Decision and Order of the Office of Hearings and Appeals in case TEE-0022, 

Maytag Corporation, published August 11, 2005

This adjustment involves adding to the energy use of 

product class 5 the difference in energy use between product classes 6 (refrigeratorfreezer—automatic defrost with top-mounted freezer with through-the-door ice service) 

and 3 (refrigerator-freezer—automatic defrost with top-mounted freezer without throughthe-door ice service). The resulting baseline energy use equation for product class 5A is 

11.44 × AV + 484.1.

0

100

200

300

400

500

600

700

800

15 20 25 30 35

Annual Energy Usage (kWh/year)

Adjusted Volume (cubic feet)

Current Standard

Preliminary Analysis New Test Baseline

New Test With Adjusted Slope

Slope 4.6

Slope 11

Slope 5.3

The small arrows show the energy use curve adjustment 

for the reversed engineered products
5-20

5.4.2.5 Adjusted Baseline Energy Use Equations

The adjusted baseline energy use equations are summarized in Table 5.4.12 below. DOE 

made changes in the equations as compared with Table 5.4.10 for the following product 

classes.

• 4 (see discussion of slope change above)

• 5 (see discussion of slope change above)

• 5A (see discussion of slope change above)

• 16, 18 (adjustment made due to round-off errors in previous calculation)

Table 5.4.12 Adjusted Baseline Energy Use Equations

Product Class Proposed Test Procedure Baseline Energy Use not 

Including Icemaking Energy Use (kWh/year)

1 9.98 AV + 281.2

2 9.98 AV + 281.2

1A 8.49 AV + 241.9

3, 3I, 3-BI, 3I-BI 10.72 AV + 310.2

3A, 3A-BI 9.43 AV + 268.8

4, 4I, 4-BI, 4I-BI 11.30 AV + 395.3

5, 5I, 5-BI, 5I-BI 11.00 AV + 394.2

5A, 5A-BI 11.44 AV + 484.1

6 11.15 AV + 400.1

7, 7-BI 11.33 AV + 462.8

8 7.42 AV + 258.3

9, 9-BI 12.32 AV + 326.1

10 9.71 AV + 143.7

10A 14.63 AV + 211.5

11 12.04 AV + 336.4

11A 10.45 AV + 292.1

12 7.88 AV + 447.8

13 13.89 AV + 399.0

13A 12.22 AV + 345.8

14 8.53 AV + 571.1

15 15.15 AV + 433.8

16 9.62 AV + 250.8

17 11.30 AV + 391.0

18 10.28 AV + 152.0

5.4.3 Incremental Efficiency Levels

DOE established a series of incremental efficiency levels, for which it has developed 

incremental cost data and quantified the cost-efficiency relationship for each of the seven 

analyzed product classes. The incremental efficiency levels for freestanding products are 

shown in Table 5.4.13 below. The energy use reductions indicated in this table represent 

reductions only in the energy use not associated with icemaking. Maximum available 
5-21

efficiency levels for the analyzed product classes, which are based on a survey of product 

databases and manufacturer websites, are tabulated in Table 5.4.15 below. Maximum 

technology levels, which are based on DOE energy modeling using all applicable design 

options, are discussed in Section 5.4.4.

Table 5.4.13 Incremental Efficiency Levels for Freestanding Products (% Energy 

Use Less than Baseline)

Level Standard-Size 

Refrigerator-Freezers

Standard-Size 

Freezers

Compact Refrigerators 

and Freezers

PC3 PC5 PC7 PC9 PC10 PC11 PC18

1 10% 10% (Current 

ENERGY STAR) 10%

2 15% (Former 

ENERGY STAR) 15% 15%

3 20% (Current 

ENERGY STAR *) 20% 20% (Current ENERGY STAR *)

4 25% (CEE Tier 2) 25% 25% (CEE Tier 2)

5 30% (CEE Tier 3) 30% 30% (CEE Tier 3)

6 36% 33% 35% 35%

7 40% 41% 40% 42%

8 44% 45%

50%

59%

*Current ENERGY STAR is equivalent to CEE Tier 1 for standard-size refrigerators 

and refrigerator-freezers and for all compact products.

Table 5.4.14 Incremental Efficiency Levels for Built-In Products

Product Class

Level

3A-BI

All-Refrigerator

5-BI

Bottom-Mount 

RefrigeratorFreezer

7-BI

Side-Mount 

RefrigeratorFreezer

9-BI

Upright Freezer

1 10% 10% 10% 10% (Current ENERGY 

STAR)

2 15% 15% 15% 15%

3

20% (Current 

ENERGY 

STAR)

20% (Current 

ENERGY 

STAR)

20% (Current 

ENERGY 

STAR)

20%

4 25% 25% 22% 25%

5 29% 27% 27%
5-22

Table 5.4.15 Maximum Available Levels (%Energy Use Less than Baseline)

Product 

Class

Maximum Available Level

Percent Volume (ft3) Brand & Model Number

3 30% 18 Frigidaire LGUI1849L*

5 33% 21 LG LFC21776**

7 32% 26 Whirlpool GSS26C4XX*0*

9, 9-BI 27% 9 Gaggenau RF411700

10 15% 11 Summit CF11ES

11 27% 3 Avanti RM3251B-1

18 23% 7 Haier ESCM071EA

3A-BI 31% 13 Thermador T24BR70***

5-BI 27% 17 Sub-Zero BI30US*

7-BI 21% 22 Fisher & Paykel RX216*T*XV2

Sources: ENERGY STAR Refrigerator & Freezer Database (7/29/2010), ENERGY STAR 

Freezer Database (7/19/2010), CEE Database (7/15/2010), CEC Database (4/28/2010), 

Manufacturer websites

5.4.4 Maximum Technology Level 

DOE defines a maximum technology level to represent the theoretical maximum possible 

efficiency if all available design options are incorporated. The maximum technology 

level is not to be confused with the maximum available level, which is the highest 

efficiency unit currently available on the market. In many cases the maximum technology

level is not commercially available because it is not economically feasible. Figure 5.4.4

below shows the maximum available efficiency levels, based on the ENERGY STAR 

databases from 7/19/10 (freezers) and 7/29/10 (refrigerators and freezers), with 

adjustments including deleting products which are no longer for sale based on the CEC 

database and manufacturers’ and retailers’ websites. 

As mentioned, the maximum technology level may not represent available products 

because they may not be economically feasible. DOE determined maximum technology 

levels using energy modeling. The energy models for the maximum technology levels 

were based on use of all design options applicable for the specific product classes. While 

these product configurations have not likely been tested as prototypes, all of the 

individual design options have been incorporated in available products. The maximum 

technology efficiency levels for the analyzed product classes are presented in Table 

5.4.14 below. These efficiency levels are in some cases higher than the maximum 

available products. The costs of the maximum technology efficiency level designs are 

also quite high, being based on extensive use of high-cost design options such as vacuum 

insulating panels as well as all applicable lower-cost design options. Table 5.4.14 

indicates which design options were used for each of the product classes.
5-23

Figure 5.4.4 Maximum Efficiency Levels Available by Product Class

*No active model available with better than baseline efficiency

3%

0%

51%

30%

72%

23%

33%

30%

28%

32%

20%

27%

15%

27%

27%

31%

0%

52%

2%

21%

36%

29%

23%

0% 10% 20% 30% 40% 50% 60% 70% 80%

1

1A*

2

3

3A

4

5

5A

6

7

8

9

10

11

11A

12

13*

13A

14

15

16

17

18

Efficiency Level (%)

Product Class
5-24

Table 5.4.16 Maximum Technology Levels and Design Options Product Class % Lower Energy 

Design Options Used

Brushless DC FansForced ConvectionCondenser Larger EvaporatorLarger CondenserThicker InsulationVIPsVariable Speed CompressorAdaptive DefrostVariable AntiSweatIsobutane Refrigerant

3 36%      

5 36%       

7 33%       

9 44%       

10 41%     

11 59%      

18 42%   

3A-BI 29%    

5-BI 27%     

7-BI 22%      

9-BI 27%     

Note: Levels indicated are the average of the levels determined for the two products of 

each product class analyzed in detail for product classes 3, 5, 7, 9, 10, 11, and 18.

5.5 DATA COLLECTION

DOE collected data from a number of sources to support the engineering analysis. The 

key sources include the following.

• AHAM

• Component Vendors

• Reverse-Engineering of Products

• Manufacturer Interviews

• Energy Tests

The data collection process is described in greater detail in the following sections.

5.5.1 Manufacturer-Submitted Shipment and Cost Data from AHAM

DOE included draft data requests sheets to support the engineering and other DOE 

analyses in the framework document as Tables A1 through A10 of that document. Some 

of these tables were revised based on comments received during the framework comment 

period. For example, incremental cost data was provided for up to 35% efficiency level, 

and included a 10% efficiency level, which replaced the 15% efficiency level of the draft 

tables. Other requests DOE made to AHAM in addition to the requests made in the 

framework document include the following.
5-25

• Historical shipment data for Wine Coolers, broken out by key types: manual 

defrost/auto defrost.

• Historical shipment data for Built-in Refrigerators, disaggregated by product class.

• Recent shipment data for products incorporating a wine cooler compartment with 

either (1) a fresh food compartment, (2) a freezer compartment, or (3) both a fresh 

food and a freezer compartment.

• Recent shipment data for French Door refrigerators broken out between products with 

and without through-the-door (TTD) ice service.

• Recent shipment data for convertible-bottom-drawer refrigerators (products with 

three doors configured as a side-by-side arrangement on top with a single drawer 

below, and for which the upper compartments are freezer and fresh food 

compartments and the drawer is convertible).

• Percent of refrigerator-freezers shipped with ice makers for applicable product classes 

(3, 4, 5, 13, 14, 15), historical data if possible.

• Total shipments of ice makers (any breakdown by (a) installed at factory, (b) installed 

by dealer, (c) installed by homeowner?), historical data if possible.

• For as many refrigerator, refrigerator-freezer, and freezer models as practical, data on 

the impact of the proposed changes in compartment temperature and volume 

calculation method:

• Compartment Volumes: volumes calculated according to the current procedure and 

according to the new procedure, with indication of product class.

• Energy use (for refrigerators and refrigerator-freezers only): Annual energy use 

measurements for units tested for both temperatures (i.e. not Energy Label data—this 

should be energy test values calculated based on test data for the old temperatures and 

the new temperatures for sequential tests of the same unit. This will typically require 

three tests to make sure that both sets of temperatures are bracketed. 

• It is anticipated that data for product classes 3 and 13 would be separated according to 

whether the product is a refrigerator-freezer or all-refrigerator.

AHAM supported the rulemaking by supplying much of this data. AHAM supplied DOE 

with aggregated shipment-weighted average data for many of the submittals in order to 

avoid divulging data submitted by individual manufacturers. 

5.5.2 Component Vendor Data

DOE directly contacted major suppliers of key refrigerator and freezer components to 

obtain performance and cost data to support its design option analysis. The data received 

from vendors was compared with information received from manufacturers during the 

manufacturer interviews in order to develop input values for performance and cost 

parameters for the energy modeling and manufacturing cost modeling. This vendor 

solicitation effort consisted of phone interviews, email correspondence, and in-person 

interviews. Table 5.5.1 lists the vendors contacted.

DOE also obtained from the compressor vendors or their websites complete performance 

data for compressors used in many of the energy analyses, including analyses for baseline 

and improved-efficiency configurations.
5-26

Table 5.5.1 Component Vendors Contacted by DOE during Engineering Analysis

Component Type Vendors

Compressors Embraco

Tecumseh

Matsushita

Danfoss

LG

Huayi

ACC (ZEL)

Jiangsu Baixue Electric Appliances Co.,Ltd

Fan Motors Matsushita

VIPs va-Q-tec

Matsushita

Porextherm

ThermoCor

NanoPore Insulation LLC

Glacier Bay

Thermal Visions

Foam Insulation BASF

Foam Supplies

Aerogel Insulation Aspen Aerogels

Heat Exchangers Brazeway

5.5.3 Reverse Engineering

DOE purchased a number of representative refrigerators and freezers as part of the 

engineering analysis in order to examine design and fabrication details. This reverseengineering included detailed measurement of dimensions, system and component-level 

power measurements, measurement of air flows for products with forced convection heat 

exchangers, and physical teardowns. The results of the reverse engineering process were 

used as input to the manufacturing cost modeling and the energy use modeling. This 

section describes the selection of products for reverse-engineering as well as some of the 

measurements made to support subsequent modeling. Section 5.6 provides a more 

thorough description of the physical teardown process used to support manufacturing cost 

modeling. 

5.5.3.1 Selection of Products for Reverse Engineering

Table 5.5.2 below lists descriptions of the products selected for reverse engineering and 

indicates for which products DOE conducted energy tests (see Section 5.5.5 for more on 

energy testing). DOE performed reverse engineering on units rated at baseline and 

improved (i.e., ENERGY STAR) energy consumption levels for the seven analyzed

product classes. DOE chose at least one representative small-size and one large-size unit 

to cover the range of volumes within each product class. In order to best examine the 

design choices associated with efficiency improvements, DOE selected baseline
5-27

Table 5.5.2 Selected Units for Reverse-Engineering and Energy Testing

PC Product Description

Energy % 

Less than 

Baseline

Energy 

Test

Physical 

Teardown

Energy Use 

Model

3

16 ft3 Top-Mount R-F 0%   

21 ft3 Top-Mount R-F 0%   

21 ft3 E* Top-Mount R-F 20%   

4 22 ft3 Side-Mount R-F† 0%   

5

18.5 ft3 E* Bottom-Mount R-F 15%*   

25 ft3 E* Bottom-Mount R-F 1 20%  

25 ft3 E* Bottom-Mount R-F 2 20%  

5A

25 ft3 French Door E* BottomMount R-F 20%



26 ft3 French Door E* BottomMount R-F 20%

7 26 ft3 Side-Mount R-F 0%   

26 ft3 E* Side-Mount R-F 20%   

9

14 ft3 Upright Freezer 0%  

20 ft3 Upright Freezer 2%   

20 ft3 E* Upright Freezer 1 12%  

20 ft3 E* Upright Freezer 2 10%

10

15 ft3 Chest Freezer 1%   

15 ft3 E* Chest Freezer 11%  

20 ft3 Chest Freezer 0%  

11

1.7 ft3 Compact Refrigerator 7%   

4 ft3 Compact Refrigerator 2%  

4 ft3 E* Compact Refrigerator 22%  

18

3.4 ft3 Compact Chest Freezer 0%  

7 ft3 Compact Chest Freezer 1 1%  

7 ft3 Compact Chest Freezer 2 1%  

*Exact efficiency level is not known because product literature did not include indication 

of separate compartment volumes.

†This product was thought to be product class 7 when purchased.

efficiency/ENERGY STAR product pairs if possible, for which the two products were 

identical other than the differences necessary for the ENERGY STAR-rated product to 

achieve higher efficiency. Such product pairs included the 21 ft3 Top-Mount refrigeratorfreezers, the 26 ft3 Side-Mount refrigerator-freezers, the 20 ft3 upright freezers, and the 4 

ft3 compact refrigerators.

5.5.3.2 Collection of Energy Modeling Data 

DOE examined each unit prior to teardown to record details to be used as input for the 

energy modeling. The key measurements are described in this section.
5-28

The rated refrigerated volumes for each product’s compartments and its rated energy use 

were based on product literature or the ENERGY GUIDE. In the case of the 3.4 ft3 chest 

freezer, the product literature did not provide an indication of energy use, and the product 

did not arrive with an ENERGY GUIDE. For this product, DOE assumed that energy use 

was exactly equal to maximum allowable energy use for the product class. 

Power input for the product was measured for a period of 24 or more hours. This 

measurement was not intended to be an energy test, but provided useful information 

regarding the product controls, including off-cycle wattage, defrost heater on-time, and 

defrost interval (or indication of variable defrost). The power measurements for the 

products were made in the reverse engineering test laboratory, whose ambient 

temperature may have covered a broad range from 65  ̊F to 85  ̊F during the time that 

these measurements were carried out. Also, careful attention was not paid to the 

temperature set points for this measurement—the set points generally were left in the asshipped positions. 

Component-level power measurements were carried out for fans, defrost heaters, and 

manual defrost controls for the products which had these components. Power was also 

measured for some products’ anti-sweat heaters.

Air flow measurements were made for all forced-convection heat exchangers. These 

measurements were made with a hot wire anemometer. The location of these 

measurements varied depending on the heat exchanger type and configuration. The 

determination of air flows based on these measurements is not very reliable, so this 

measurement was used as an indication of air flow trends more than exact indication of 

air flow for the various products.

Details of the cabinet size and insulation thickness were based on direct physical 

measurements. Most of these measurements were made prior to the teardown, but 

measurements of some parameters, such as outer shell thickness, inner liner thickness, 

and insulation thickness, were made during the teardown process. Use of insulation other 

than polyurethane foam was noted as part of the teardown process. Frame area details 

including gasket details were observed, and recorded with pictures as part of the 

teardown process. 

Heat exchanger details were recorded, including type, configuration, numbers of tubes 

and fins, dimensions, etc. For cold wall and hot wall heat exchangers this data was 

recorded during the product teardown process. The details of anti-sweat heaters were also 

determined during the teardown process, including the layout for refrigerant anti-sweat

loops. The details of suction line heat exchangers were similarly determined during 

teardown.

Component manufacturer and model data were recorded for key components such as 

compressors, fans, and controls. 

Design data for the analyzed built-in products were obtained directly from a built-in 

product manufacturer.
5-29

The energy modeling data for the teardown products are presented in detail in appendix 

5-A.

5.5.4 Manufacturer Interviews

DOE’s contractor discussed engineering issues with manufacturers during the pre-NOPR 

interviews. The engineering questions were consolidated into an engineering 

questionnaire, which guided the interview process for all of these discussions. The 

engineering questionnaire is shown in appendix 5-A. Key technical topics addressed 

during these discussions include the following:

• Typical characteristics of components and typical design details (i.e. such as 

insulation thicknesses) used for key product classes.

• Typical design differences between baseline and ENERGY STAR products.

• Differences in design pathways and incremental costs across different product classes

• Viability of technology options, and their typical costs.

All of these interviews were conducted under non-disclosure agreements with the 

manufacturers. Hence, none of the individual responses can be reported. However, values 

for many of the parameters and costs used in the engineering analysis were based on 

aggregated input from these discussions.

After the preliminary analysis comment period, DOE’s contractor again visited 

manufacturers and discussed engineering issues. Some of this discussion responded 

directly to comments made during the preliminary analysis public meeting and in written 

submittals from stakeholders. Some of the technical data discussed during the preliminary 

analysis discussions was revisited. Much of the discussion also addressed differences 

between DOE’s preliminary analysis results and the manufacturers’ information 

regarding the design changes required to achieve higher efficiency levels, including the 

30% efficiency levels achieved by some standard-size refrigerator-freezer products. 

These discussions were also conducted under non-disclosure agreements and hence the 

findings cannot be reported in detail. However, DOE adjusted many of its engineering 

analysis model inputs for better consistency with the information obtained during these 

interviews.

5.5.5 Energy testing

DOE conducted energy testing to verify energy use of many of the products obtained for 

reverse engineering, to provide refrigeration system data to support energy use modeling, 

and to evaluate the difference in energy use between current energy test compartment

temperatures and the new temperatures associated with the expected revised test 

procedure. 

Twelve of the 24 units were tested, as indicated in Table 5.5.2, including all of the 

refrigerator-freezer models and one each of the upright freezers, chest freezers, and 

compact refrigerators. No compact chest freezers were tested.
5-30

Energy testing was carried out by an independent test lab according to the DOE Energy 

Test Procedure as described in 10 CFR Part 430 Subpart B, Appendix A1 or B1, with 

reference to AHAM Standard HRF-1-1979 as applicable. In addition to the standard 

energy test results, DOE requested specific temperature measurements to be taken in 

various locations during the test to better understand the refrigeration system operating 

characteristics. Specifically, low-mass thermocouples were mounted in good thermal 

contact with the surface of refrigerant tubing, insulated externally from local ambient air. 

Table 5.5.3 lists the additional measurements.

Table 5.5.3 Additional Thermocouple Locations for Preliminary Analysis Energy 

Tests

Thermocouple Location RefrigeratorFreezers

Upright 

Freezer

Chest 

Freezer

Compact 

Refrigerator

Discharge 4” from shell    

Condenser Inlet 

Condenser Mid 

Condenser Outlet    

Evaporator Inlet   

Evaporator Outlet    

Suction 4” from shell    

Condenser Air Inlet 

Pan Heater In 

Pan Heater Out 

Hot Wall Condenser 

Surface   

Compressor 

Compartment Air   

Cold Wall Evaporator 

Surface  

Note: Two units of the 1.7 ft3 compact refrigerator were tested because the first of these 

was not able to hold proper internal temperatures.

During the NOPR phase of the work, DOE also arranged for testing of some products 

having efficiency levels at or near the max available. These tests, conducted only 

according to the current test procedure and not incorporating the additional measurements 

described in Table 5.5.3, confirmed that these products achieved their rated efficiency 

levels. The results of the tests are summarized in Table 5.5.4 below.
5-31

Table 5.5.4 High-Efficiency Refrigeration Product Test Results

Product 

Class

Total 

Volume 

(cu. ft.)

Adjusted 

Volume 1

(cu. ft.)

Rated 

Energy 

(kWh/year)

Rated

Percent 

Below 

Standard

Measured 

Energy Use 

(kWh/year)

3 18.89 22.04 343 30% 336

5 18.51 22.03 392 30% 371

7 22.11 26.66 473 30%

3A 16.14 16.14 204 53%

1 As measured during test.

5.6 MANUFACTURING COST MODELING

5.6.1 Generation of Bills of Materials

The end result of each teardown is a structured bill of materials (BOM). DOE developed 

structured BOMs for each of the physical teardowns. Structured BOMs describe each 

product part and its relationship to the other parts in the estimated order in which 

manufacturers assembled them. The BOMs describe each fabrication and assembly 

operation in detail, including the type of equipment needed (e.g., presses, drills), the 

process cycle times, and the labor associated with each manufacturing step. The result is 

a thorough and explicit model of the production process, which includes space, conveyor, 

and equipment requirements by planned production level.

The BOMs incorporate all materials, components, and fasteners classified as either raw 

materials or purchased parts and assemblies. The classifications into raw materials or 

purchased parts were based on DOE’s previous industry experience, recent information in 

trade publications, and discussions with high- and low-volume original equipment 

manufacturers (OEMs). DOE also visited manufacturing plants to reinforce its 

understanding of the industry’s current manufacturing practices for each of the three 

product categories.

For purchased parts, the purchase price is estimated based on volume-variable price 

quotations and detailed discussions with manufacturers and component suppliers. For 

fabricated parts, the prices of “raw” metals (e.g., tube, sheet metal) are estimated on the 

basis of 5-year averages (see Section 5.6.4.4) while all other materials and purchased 

parts reflect current market costs. The cost of transforming the intermediate materials into 

finished parts is estimated based on current industry pricing. DOE shared major estimates 

with manufacturers during the engineering manufacturer interviews to gain feedback on 

the analysis, its methodology, and preliminary results.

5.6.2 Cost Structure of the Spreadsheet Models

The manufacturing cost assessment methodology used is a detailed, component-focused 

technique for calculating the manufacturing cost of a product (direct materials, direct 
5-32

labor, and the overhead costs associated with production). The first step in the 

manufacturing cost assessment was the creation of a complete and structured BOM from 

the disassembly of the units selected for teardown. The units were dismantled, and each 

part was characterized according to weight, manufacturing processes used, dimensions, 

material, and quantity. The BOM incorporates all materials, components, and fasters with 

estimates of raw material costs and purchased part costs. Assumptions on the sourcing of 

parts and in-house fabrication were based on industry experience, information in trade 

publications, and discussions with manufacturers. Interview and plant visits were 

conducted with manufacturers to add industry experience on the methodology and 

pricing.

The last step was to convert this information into dollar values. To perform this task, 

DOE collected information on labor rates, tooling costs, raw material prices, and other 

factors. DOE assumed values for these parameters using internal expertise and 

confidential information available to DOE contractors. Although most of the assumptions 

are manufacturer specific and cannot be revealed, Section 5.6.4.3 provides a discussion of 

the values used for each assumption.

In summary, DOE assigned costs of labor, materials, and overhead to each part whether 

purchased or produced in-house. DOE then aggregated single-part costs into major 

assemblies (e.g., door assembly, heat exchanger assembly, shelving, packaging, controls, 

bottom components assembly, wiring harnesses, inner/outer wrapper assembly, etc.) and 

summarized these costs in a worksheet. During engineering interviews with 

manufacturers, DOE showed key estimates from the cost model and asked for feedback. 

DOE considered any information manufacturers gave that was relevant to the cost model 

and incorporated it into the analysis, if appropriate.

5.6.3 Cost Model and Definitions

Once DOE disassembled selected units, gathered information from manufacturer catalogs 

on additional products, and identified technologies, DOE created an appropriate 

manufacturing cost model that could translate physical information into manufacturer 

production costs (MPCs). The cost model is based on production activities and divides 

factory costs into the following categories:

• Materials: Purchased parts (i.e. compressor, fan motors, control boards, door handles, 

shelf frames, etc.), raw materials (i.e., cold rolled steel, copper tube, etc.), and indirect 

materials that are used for processing and fabrication.

• Labor: Fabrication, assembly, indirect, and supervisor labor. Fabrication and 

assembly labor cost are burdened with benefits and supervisory costs.

• Overhead: Equipment, tooling, and building depreciation, as well as utilities, 

equipment and tooling maintenance, insurance, and property taxes.

5.6.3.1 Cost Definitions

Because there are many different accounting systems and methods to monitor costs, DOE 

defined the above terms as follows:
5-33

• Direct material: Purchased parts (out-sourced) plus manufactured parts (made inhouse from raw materials).

• Indirect material: Material used during manufacturing (e.g., welding rods, adhesives).

• Fabrication labor: Labor associated with in-house piece manufacturing.

• Assembly labor: Labor associated with final assembly.

• Indirect labor: Labor costs that scaled with fabrication and assembly labor. This 

included the cost of technicians, manufacturing engineering support, stocking, etc. 

that were assigned on a span basis.

• Equipment and plant depreciation: Money allocated to pay for initial equipment 

installation and replacement as the production equipment wears out.

• Tooling depreciation: Cost for initial tooling (including nonrecurring engineering and 

debugging of the tools) and tooling replacement as it wears out.

• Building depreciation: Money allocated to pay for the building space and the 

conveyors that feed and/or make up the assembly line.

• Utilities: Electricity, gas, telephones, etc.

• Maintenance: Annual money spent on maintaining tooling and equipment.

• Insurance: Appropriated as a function of unit cost.

• Property Tax: Appropriated as a function as unit cost.

5.6.4 Cost Model Assumptions Overview

As discussed in the previous section, assumptions about manufacturer practices and cost 

structure played an important role in estimating the final product cost. Some assumptions 

were different for specific manufacturers, depending on their market position, 

manufacturing practices, and size.

In converting physical information about the product into cost information, DOE 

reconstructed manufacturing processes for each component using internal expertise and 

knowledge of the methods used by the industry. DOE used assumptions regarding the 

manufacturing process parameters (e.g., equipment use, labor rates, tooling depreciation, 

and cost of purchased raw materials) to determine the value of each component. DOE 

then summed the values of the components into assembly costs and, finally, the total 

product cost. The product cost included the material, labor, and overhead costs associated 

with the manufacturing facility. The material costs included both direct and indirect 

materials. The labor costs included fabrication, assembly, indirect, direct, and supervisor 

labor rates, including the associated overhead.

The labor costs included assembly, fabrication, supervisor, and indirect labor. Overhead 

costs included equipment depreciation, tooling depreciation, building depreciation, 

utilities, equipment, tooling maintenance, insurance, property, and taxes.

DOE used the information gathered from manufacturer interviews to make updates to the 

cost model. These changes involved updating component and material pricing.

The next sections discuss specific assumptions about outsourcing, factory parameters, 

production volumes, and material prices. When the assumptions are manufacturer-
5-34

specific, they are presented as industry averages to prevent disclosure of confidential 

information.

5.6.4.1 Fabrication Estimates

DOE characterized parts based on whether manufacturers purchased them from outside 

suppliers or fabricated them in-house. For purchased parts, DOE estimated the purchase 

price. For fabricated parts, DOE estimated the price of raw materials (e.g., tube, sheet 

metal) and the cost of transforming them into finished parts. Whenever possible, DOE 

obtained price quotes directly from the manufacturers’ suppliers.

DOE based the manufacturing operations assumptions on internal expertise, interviews 

with manufacturers, and manufacturing facilities site visits. The major manufacturer 

processes identified and developed for the spreadsheet model are listed in Table 5.6.1.

Fabrication process cycle times were estimated and entered into the BOM. 

Table 5.6.1 Cost Model In-House Manufacturing Operation Assumptions

Fabrication Finishing Assembly/Joining Quality Control

Fixturing

Stamping/Pressing

Turret Punch

Tube Forming

Brake Forming

Cutting & Shearing

Insulating & 

 Insulation Injection

Tube/Wire Bending

Brazing

Vacuum Forming

Blow Molding

Washing

Painting

Powder Coating

De-burring

Polishing

Refrigerant Charging

Adhesive Bonding

Spot Welding

Seam Welding

Packaging

Inspecting & Testing

5.6.4.2 Production Volumes Assumptions

A manufacturer’s production volumes vary depending on several factors, including 

market share, the type of product produced (i.e., standard- size refrigerator-freezer, 

compact refrigerator-freezer, etc.), and if the manufacturer produces other similar 

products. DOE based production volume assumptions for these residential refrigeration 

products on shipment data, industry knowledge, and engineering manufacturer 

interviews. The manufacturing plant annual production capacities used for the analyses 

differ by product class as follows.

• Product Classes 3 and 6: 1.5 million

• Product Classes 5 and 5A: 0.5 million

• Product Classes 4 and 7: 1 million

• Product Class 9: 150,000

• Product Class 10: 100,000
5-35

• Product Class 11: 0.5 million

• Product Class 18: 100,000

5.6.4.3 Factory Parameters Assumptions

DOE used information gathered from publicly available literature, manufacturer 

interviews, and analysis of common industry practices to formulate factory parameters 

for each type of manufacturer. DOE first made assumptions about a set of preliminary 

factory parameters before the manufacturer interviews. DOE then revised the 

assumptions using comments and information gathered during the interviews. Table 5.6.2

lists DOE’s assumptions for refrigerator manufacturers. 

Table 5.6.2 Refrigerator & Freezer Factory Parameter Assumptions

Parameter Assumption

Plant Capacity (units/yr) see section 5.6.4.2

Actual Annual Production Volume (units/yr) 5/6 of plant capacity

Fabrication Labor Wages ($/hr) 16.00

Fringe Benefits Ratio 50%

5.6.4.4 Material Cost Assumptions

DOE determined the cost of raw materials using publicly available information such as 

the American Metals Market2

, interviews with manufacturers, and direct discussions with 

material suppliers. Common metals used in the fabrication of residential refrigerator 

products include plain cold rolled steel (CRS), copper tubing, and aluminum. There have 

been large fluctuations in metal prices over the last few years. To account for these 

fluctuations, DOE used a 5-year average of metal prices from the Bureau of Labor 

Statistics Producer Price Indices (PPIs) spanning 2003 to 2008 with an adjustment to 

2008$.3 DOE used the PPIs for copper rolling, drawing, and extruding and steel mill 

products, and made the adjustments to 2008$ using the gross domestic product implicit 

price deflator.4 For resins used in the fabrication of these refrigeration products, DOE 

used current resin prices gathered from industry research, publications such as Plastics 

News,

5

5.6.5 Manufacturing Production Cost

and interviews with manufacturers.

Once the cost estimate for each teardown unit was finalized, a detailed summary was 

prepared for relevant components, subassemblies, and processes. The BOM thus details 

all aspects of product costs. DOE totaled the cost of materials, labor, and direct overhead 

 2 American Metals Market. Last accessed November 2008. <http://www.amm.com>.

3 U.S. Department of Labor, Bureau of Labor Statistics, Producer Price Indices. Last accessed November 

2008. <http://www.bls.gov/ppi>.

4 U.S. Department of Commerce, Bureau Economic Analysis, Gross Domestic Product Implicit Price 

Deflator. Last accessed November 2008. <https://bea.gov/bea/dn/nipaweb/TableView.asp#Mid>.

5 Plastic News, Resin Pricing. Last accessed March 21, 2008. 

<http://www.plasticsnews.com/subscriber/headlines.phtml>.
5-36

used to manufacture a product in order to calculate the manufacturing production cost.

6

Figure 5.6.1 shows the general breakdown of costs associated with manufacturing a 

product.

Figure 5.6.1 Full Production Costs

The full cost of product is broken down into two main costs, the full production cost or 

MPC, and the non-production cost. The non-production cost is equal to the manufacturer 

markup minus profits.

Technologies used in the units subject to teardown are noted in the summary sheet of 

each cost model and are cost-estimated individually. Thus, various implementations of 

technologies can be accommodated, ranging from assemblies that are entirely purchased 

to units that are entirely from raw materials. Hybrid assemblies, consisting of purchased 

parts and parts made on site are thus also accommodated.

5.6.6 Incremental Cost Estimates

Incremental costs were determined for design options applied to the baseline-efficiency 

refrigerator models. The approach for estimating the incremental costs varied depending 

 6 When viewed from the companywide perspective, the sum of all material, labor, and overhead costs 

equals the company’s sales cost, also referred to as the cost of goods sold (COGS).

Manufacturer 

Selling Price

Full Cost of 

Product

Manufacturer 

Production Cost

Direct 

Labor

Direct 

Material Overhead

Indirect Labor

Indirect Material

Maintenance

Depreciation

Taxes

Insurance related 

to assets

Non-Production 

Cost

Selling

Market 

Research

Advertising

POS Promotion

Salesperson 

Comp & Travel

Logistics 

(Warehousing, 

Delivery, RecordKeeping, Order 

Processing)

General & 

Admin.

Costs of 

Service & 

Staff Units

General 

Corporate 

Costs 

(Comp, etc)

R & D

Costs associated 

with finding new 

and improved 

products or 

processes

Code 

Compliance

Modernization

Interest

Cost of 

borrowing 

funds

Profit
5-37

on the design option. Details in this calculation which are specific to individual design 

options are discussed in Section 5.8, which discusses design options. Aspects of the 

incremental cost calculation which were generally applied to multiple design options are 

discussed in this section.

Many of the design options involve replacement of a current component with a higherefficiency component. For these design options, the increased price paid by the OEM for 

the new component represents the manufacturing cost increase—other elements of 

product cost such as overhead and capital expenditures would be insignificantly affected 

by these design changes. The appropriate price increases are discussed in Section 5.8 by 

design option.

For some design changes, calculating the cost impact of the design change required direct 

use of the manufacturing cost model to determine changes to a number of parts. The 

baseline manufacturing cost was subtracted from the manufacturing cost of the modified 

design to determine the incremental cost of the design option. This approach was used in 

particular for insulation thickness increases and heat exchanger size increases for cold 

wall and hot wall heat exchangers.

5.6.6.1 Overhead and Depreciation Costs

Some design options involve costs in addition to the price increase associated with a new 

component. For such options, there may be overhead and capital expenses which must be 

added to the direct costs associated with the design option. Estimates of typical additional 

costs associated with overhead and depreciation for manufacture of refrigeration products 

were made for the reverse-engineering models, using estimates of these costs provided by 

the manufacturing cost model. These calculations were carried out based on proposed 

typical production plant capacities, with actual production volumes estimated to be 5/6 of 

plant capacities. The annual plant capacities for the product classes used in these 

calculations are as indicated in section 5.6.4.2.

The additional costs are presented as percentage of direct material and labor costs in 

Table 5.6.3 below. The averages for the listed product class categories were used to 

increase direct material and labor costs for some design options for which this adjustment 

was necessary. DOE initially conducted this calculation during the preliminary analysis. 

As a result of changes to the manufacturing cost model during the NOPR phase, some of 

the numbers changed slightly. However, the overall average percent cost ratios did not 

change significantly. DOE continued use of the values calculated for these parameters 

during the preliminary analysis.
5-38

Table 5.6.3 Preliminary Analysis Overhead and Depreciation Cost Ratios

Product Class 

Group

Product 

Class

Product Percent 

Cost 

Ratio

Average 

Percent Cost 

Ratio for 

Product Class 

Group

StandardSize 

RefrigeratorFreezers

3

16 ft3 Top-Mount R-F 31.2%

23.4%

21 ft3 Top-Mount R-F 23.2%

21 ft3 E* Top-Mount R-F 23.2%

4 22 ft3 Side-Mount R-F† 22.0%

5

19 ft3 E* Bottom-Mount R-F 23.5%

25 ft3 E* Bottom-Mount R-F 1 20.9%

25 ft3 E* Bottom-Mount R-F 2 23.3%

7 26 ft3 Side-Mount R-F 20.7%

26 ft3 E* Side-Mount R-F 22.5%

StandardSize Freezers 914 ft3 Upright Freezer 28.6%

28.5%

20 ft3 Upright Freezer 26.2%

20 ft3 E* Upright Freezer 1 25.0%

10

15 ft3 Chest Freezer 35.5%

15 ft3 E* Chest Freezer 33.2%

20 ft3 Chest Freezer 22.5%

Compact 

Refrigerators, 

RefrigeratorFreezers, and 

Freezers

11

1.7 ft3 Compact Refrigerator 40.2%

39.2%

4 ft3 Compact Refrigerator 35.6%

4 ft3 E* Compact Refrigerator 36.5%

18

3.4 ft3 Compact Chest Freezer 42.3%

7 ft3 Compact Chest Freezer 1 36.6%

7 ft3 Compact Chest Freezer 2 44.2%

The manufacturing cost model estimates are consistent with overall industry trends. 

Census data shows that the average value of this cost adder for NAICS code 335222 

(Household Refrigerator and Home Freezer Manufacturing) is 27.7%. 

5.6.6.2 Depreciation Costs for Insulation Thickness Increases

DOE considered that increases in cabinet wall and door thicknesses would require 

redesign of the entire refrigerator or freezer platform and would likely lead to the 

building of a new production plant. This conservative approach to the analysis was based 

on input from manufacturers. For such design changes, the difference in Greenfield costs7

 7 Greenfield costs are defined as the costs associated with building a new manufacturing facility, to be 

distinguished from the costs required to upgrade or modify a facility.

of two designs would not capture the depreciation costs which would be incurred by the 

manufacturer and which would add to the product cost after such a platform conversion. 

DOE conservatively used the Greenfield depreciation costs per product determined by the 

manufacturing cost model as an additional cost for wall thickness increases. The 
5-39

calculation of manufacturing costs for all of the teardown products based on typical plant 

capacities described above was used as the basis for the determination of Greenfield 

depreciation costs per product. The results of the calculations are summarized in Table 

5.6.4 below. Average depreciation costs were applied in the engineering analyses for all 

of the analyzed products of a product class. The depreciation costs also were separately 

allocated to the cabinet or door, as indicated in the table.

Table 5.6.4 Greenfield Depreciation Costs per Product

Product 

Class

Product Depreciation Cost

Total Average Average 

Cabinet

Average 

Door(s)

9

14 ft3 Upright Freezer $29.48 $30 $23 $7

20 ft3 Upright Freezer $31.40

20 ft3 E* Upright 

Freezer 1

$30.44

10

15 ft3 Chest Freezer $32.70 $33 $26 $7

15 ft3 E* Chest Freezer $34.12

20 ft3 Chest Freezer $30.73

18

3.4 ft3 Compact Chest 

Freezer 

$35.99 $32 $26 $6

7 ft3 Compact Chest 

Freezer 1

$30.99

7 ft3 Compact Chest 

Freezer 2 

$29.68

11

1.7 ft3 Compact 

Refrigerator 

$11.95 $13 $10 $3

4 ft3 Compact 

Refrigerator 

$13.27

4 ft3 E* Compact 

Refrigerator 

$13.27

5.6.6.3 G&A and Profit

DOE estimated the further addition to the manufacturer selling price associated with 

G&A and profit for the appliance industry as 26% of manufacturer production cost. This 

adder was applied to all of the MPC estimates in order to determine manufacturer selling 

price (MSP) numbers. This markup is described in more detail in chapter 6.

5.7 ENERGY MODELING

DOE carried out detailed energy modeling of representative baseline and ENERGY 

STAR refrigeration products, and on design variations of these products that included one 

or more of the design options considered for the engineering analysis. This energy 

modeling work served as the basis of estimates of energy savings potential associated 

with the design options. The products selected for reverse engineering provided the basis 
5-40

for the energy modeling. Energy model input was determined for these products from the 

data collected during the reverse engineering work, described in Section 5.5.3. Additional 

data, used both as input, and for calibration of individual product energy models, was 

provided by energy testing as described in Section 5.5.5. Using the energy modeling 

results and manufacturing cost modeling results for these designs allowed DOE to 

develop incremental cost estimates for multiple efficiency levels based on each of the 

baseline products analyzed.

DOE carried out energy modeling during this rulemaking using an improved version of 

the EPA Refrigerator Analysis (ERA) program, earlier versions of which have been used 

in previous refrigerator rulemakings. Section 5.7.1 describes the ERA model 

development briefly. A more detailed description of the program and its recent 

development is presented in appendix 5-B. 

5.7.1 Energy Model development

ERA is a steady-state energy model that calculates heat leakage into a cabinet and 

determines the energy needed by the refrigeration system to maintain the interior 

temperatures as specified by the user. Total energy used includes the energy from the 

compressor, fan motors, defrost heater, electronic control, and anti-sweat heaters, if 

applicable. See appendix 5-B for a detailed explanation of the ERA model. 

The DOS version of ERA was developed initially under EPA-sponsorship during the late 

1980s. This was undertaken by the EPA as part of its involvement in the establishment of 

energy standards for refrigerators, refrigerator-freezers, and freezers under the National 

Appliance Energy Conservation Act of 1987 (NAECA). A developmental version of the 

program was used by the DOE as a partial basis for the energy standard established in 

1989 (effective in 1993). The work also involved extensive testing of the model against 

manufacturer-supplied refrigeration appliance design and test data. Based on these 

comparisons and manufacturer review comments through its industry organization 

(AHAM), development of the model continued until its release in 1997.1

ERA combined an analysis of the refrigeration load requirements of the cabinet with a 

simulation of the capacity and efficiency of the refrigeration cycle. The cabinet loads 

module was a modest enhancement of a program developed for the DOE during the late 

1970s,2 including the consideration of door-opening effects on the load and an ability to 

deal with complex insulation systems. The cycle module was a derivative of the NIST 

CYCLE 7 program,3 which used the CSD equation of state to represent the 

thermodynamic properties of pure and mixed refrigerants,4 adapting routines for 

calculating refrigerant properties from REFPROP3.5 The program, and its User’s 

Manual, were first released to the public in 1993, and for a few years were downloadable 

from the EPA website.6

1

Subsequent to the 1993 final rule, DOE published updated 

standards for refrigerators, refrigerator-freezers and freezers in 1997, becoming effective 

in 2001. Analysis carried out in support of the 1997 final rule involved use of the final 

released EPA version of ERA.
5-41

The DOS version of ERA was subsequently modified as described in appendix 5-B, but 

these revisions were not made available to the public. During the course of this 

rulemaking, further development of the model was carried out in order to allow use of the 

model for calculation of energy use of modern residential refrigeration products and to 

allow a modern version of the program to be made available to stakeholders to validate 

DOE analysis. Key modifications made include the following.

• Enhancement of the user-interface to a Windows environment

• Employment of the most current refrigerant property routines

• Incorporation of a broad range of evaporator and condenser algorithms that 

correspond to the technologies now found in modern refrigerators

• Improved compressor modeling, with built-in procedures for validating supplied 

compressor maps

• Improvements where desirable in the cabinet loads analysis and cycle performance 

algorithms.

• Preparation of internal documentation of the program through extensive contextsensitive Help files.

DOE made many of the preliminary analysis phase energy model calculations described 

in this chapter using a DOS version of the ERA program prior to the completion of the 

Windows version. During the NOPR phase of this rulemaking, DOE converted all of the 

original energy model calculations used for development of cost-efficiency curves to the 

Windows version of ERA.

The development history and capabilities of the program are described in more detail in 

appendix 5-B.

5.7.2 Supplemental Spreadsheet Models 

Spreadsheet analysis tools were developed and used as part of some of the energy model 

development and calculations in order to (1) calculate airside heat transfer performance 

of spine fin evaporators, (2) determine appropriate composite insulated wall thermal 

resistivity when calculating cabinet thermal performance using vacuum panel insulation, 

(3) adjust of ERA analysis results of vacuum panel design options, and (4) calculate the 

condenser fan energy consumption for condensers serving two refrigeration circuits..

Spine fin evaporator airside heat transfer performance was calculated using a spreadsheet. 

Equations for the model were based on the work of Holtzapple and Carranza.7,8

When modeling use of vacuum insulation panels (VIPs), the cabinet walls or door have 

two regions of differing thermal resistivity. Average values of resistivity were calculated 

The ERA 

heat exchanger models (the ERAEVAP program) provided heat transfer coefficients for 

refrigerant-side heat transfer in the two-phase and superheated regimes. Using these 

values, the spreadsheet model provided the overall heat transfer coefficients for the two 

regimes of the evaporator and the effective heat transfer area, which were the inputs for 

DOS version of ERA.
5-42

and entered into ERA to model these composite insulation systems. In addition, as 

discussed in section 5.8.3, energy benefits reported by manufacturers using vacuum 

panels have generally been less than calculated in this fashion by ERA. Adjustments were 

made to the ERA results to compensate for this difference. This is discussed in greater 

detail in section 5.8.3.

For some product classes (e.g. 3A-BI, 5-BI, 7-BI), the representative products selected 

for energy modeling featured dual-loop refrigeration systems, i.e. two separate 

refrigeration circuits sharing a single dual-circuit condenser with a single fan. ERA

calculates energy use for dual-loop systems, but assumes that these systems have no 

common components. In order to model the dual-circuit condensers of the selected 

products, the condenser model for each refrigeration system was based on only that 

portion of the condenser tubing and fins allocated to it. Because of overlap of system 

operation, proper calculation of condenser fan run time was not possible using ERA.

Instead, the condenser fan run time and power input was calculated separately, taking 

into consideration the run time of each of the two systems. This calculation assumed that 

there was no correlation between one system’s duty cycle and whether the other system 

was running.

.

5.7.3 Development and Calibration of ERA Current Energy Test Models

ERA modeling during the engineering analysis involved the following three phases.

• Modeling of existing reverse-engineered products based on the current energy test 

procedure.

• Adjustment of models to represent baseline products tested under the expected 

revised test procedure. DOE made some adjustments in this step in product designs to 

adjust from the reverse-engineered product configuration to the desired 

configurations to represent the analyzed product classes (e.g. adjustment of efficiency 

level, conversion to French doors, addition of a through-the-door ice service feature). 

• Iterative modeling with multiple series of adjustments to calculate the energy savings 

which can be achieved with different combinations of design options.

This section focuses on the first phase of the ERA modeling work, namely establishing 

models for the teardown products based on the current energy test procedure. These 

models were later adjusted to represent baseline energy use under the new test 

procedures, and these models were used subsequently to calculate energy savings 

potential. The baseline analysis results were compared with available data to assure that 

the models provide accurate representation of product energy use. This section discusses 

the creation and calibration of the ERA energy models, the metrics which were

compared, and the adjustments which were made in some cases in order to improve 

calibration. 

Input data for energy modeling was collected during the reverse engineering phase of the 

project. Collection of this data is discussed in Section 5.5.3.2 above. For products which 
5-43

DOE arranged to have energy tested, additional information was available for certain 

model parameters, such as defrost heater on times, compressor run time between defrosts, 

evaporator exit superheat, etc. Performance data was obtained from compressor vendors 

for the compressors used in the teardown products, as well as for compressors which 

could be considered as alternative options to reduce energy use.

Initial energy models were created, and the models were subsequently adjusted to provide 

a best match with available data for product performance. Key sources of information 

used for calibration of the energy models were the product EnergyGuide labels and data 

from energy tests carried out for a number of the reverse-engineered units (Section 5.5.5). 

Energy test parameters besides energy use which were examined include compressor 

running power input, duty cycle, evaporating temperature, and condensing temperature. 

Since not all ERA input parameters can be determined definitively based on available 

information, some of the inputs were adjusted within reasonable ranges in order to 

provide good matches between model results and other performance indicators. It is 

recognized that energy levels reported in the EnergyGuide can be conservative to provide 

margin for variation in the production process. Hence, it is expected that ERA results 

would more likely be lower than the EnergyGuide value than higher.

In some cases the directly modeled energy use was initially significantly lower than 

actual product energy use. In some of these cases in which the system operating 

parameters could be well calibrated based on test data, DOE attributed the high actual 

duty cycle and energy use to high actual cabinet thermal load. A number of factors could 

possibly explain such results, including greater impact than expected of thermal short 

circuits associated with wiring harnesses and other design details, excess gasket region 

load, and consistently lower insulation thermal performance than expected. A 

consistently underperforming compressor model could also explain such a discrepancy, 

but DOE concluded that this explanation is less likely than factors which would increase 

cabinet thermal load. Hence, for these cases, additional cabinet load was added to result 

in an energy use and compressor duty cycle which provided reasonable agreement with 

the available data. The side-mount refrigerator-freezers (product classes 4 and 7) were 

adjusted using this approach, for example.

In some cases, DOE concluded that ERA was not modeling particular heat exchangers

properly. DOE adjusted the calculated effective surface area of the heat exchanger 

upwards or downwards to represent heat transfer performance different than modeled to 

achieve more reasonable match of evaporating or condensing temperatures, as measured 

during energy test work. DOE made similar adjustments in some cases to evaporator 

pressure drop to adjust for an apparent discrepancy between measured evaporator surface 

temperature and compressor power input.

The ERA analysis results after adjustments of the model input for the seven key product 

classes analyzed are compared with the EnergyGuide data and Energy test results in 

Figure 5.7.1 for refrigerator-freezers, in Figure 5.7.2 for standard-size freezers, and in 

Figure 5.7.3 for compact refrigerators and freezers. Energy testing was performed on a 

limited group of freezers and compact products: one upright freezer, one chest freezer, 
5-44

and one compact refrigerator. For these figures, the energy use of the freezers has been 

adjusted consistent with the energy test by applying the 0.85 correction factor for upright 

freezers and the 0.7 correction factor for chest freezers. The energy models are within a 

few percent of the EnergyGuide labeled energy. 

Figure 5.7.1 ERA Analysis for Refrigerator-Freezers Compared with EnergyGuide 

Labels and Energy Test Measurements

0.0

0.5

1.0

1.5

2.0

2.5

16 ft3 Top Mount21 ft3 Top Mount

21 ft3 E* Top Mount

18.5 ft3 E* Bottom 

Mount

25 ft3 E* Bottom 

Mount 1

25 ft3 E* Bottom 

Mount 2

22 ft3 Side Mount

26 ft3 Side Mount

26 ft3 E* SideMount

Daily Energy Use (kWh/day)

ERA 

Energy Guide 

Energy Test
5-45

Figure 5.7.2 ERA Analysis for Freezers Compared with EnergyGuide Labels and 

Energy Test Measurements

Figure 5.7.3 ERA Analysis for Compact Refrigerators and Freezers Compared with 

EnergyGuide Labels and Energy Test Measurements

0.0

0.5

1.0

1.5

2.0

2.5

14 ft3 Upright Freezer20 ft3 Upright Freezer

20 ft3 E* Upright Freezer

15 ft3 Chest Freezer

15 ft3 E* Chest Freezer

20 ft3 Chest Freezer

Daily Energy Use (kWh/day)

ERA 

Energy Guide 

Energy Test

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.7 ft3 Compact 

Refrigerator

4 ft3 Compact 

Refrigerator

4 ft3 E* Compact 

Refrigerator

3.4 ft3 Compact Chest 

Freezer

7 ft3 Compact Chest 

Freezer 1

7 ft3 Compact Chest 

Freezer 2

Daily Energy Use (kWh/day)

ERA 

Energy Guide 

Energy Test
5-46

5.7.4 Adjustments to Energy Models to Represent Baseline Products Tested Under 

the Proposed Test Procedure

This section discusses adjustment of the calibrated baseline ERA models to address two 

issues: (1) modification of some of the modeled product designs so they represent 

baseline-efficiency products of the desired product classes, and (2) adjustment for the 

proposed test procedure changes.

Modifications were made to some of the modeled product designs so that they represent 

baseline products of the product classes of interest with appropriate typical 

characteristics. The changes made are discussed in the following paragraphs.

Some of the teardown products purchased were not available as baseline-efficiency

products, i.e. products with energy use that is minimally compliant with the current 

energy standards. This was true primarily for product class 5, refrigerator-freezers with 

automatic defrost and bottom-mounted freezers without TTD ice service. As indicated 

above in Table 5.5.2, one of these products had energy use roughly 15% below the 

maximum allowable energy use (the former ENERGY STAR level), and the others had 

energy use at 20% below (the current ENERGY STAR level). In order to allow the 

engineering analysis to examine the cost associated with the efficiency improvement 

from the 0% to the 15% and 20% efficiency levels, DOE created baseline models for 

products which would be minimally compliant with the standards. DOE did this by 

carrying out the analysis in reverse, removing the less cost-effective design options first, 

in order to achieve calculated energy levels consistent with the baseline energy standard. 

For product class 5, DOE established baseline models representing products with French 

Doors. Comments made at the framework meeting and submitted to DOE as part of the 

framework comment period addressed this issue, as discussed in chapter 2 of the 

preliminary TSD. Most of the teardown products were purchased prior to the framework 

meeting, so DOE was not able to consider this issue when selecting these products. The 

two French Door products (see Table 5.5.2) were purchased later, to allow investigation 

of the different design details for these products. However, these French Door products 

are not product class 5, since they have TTD ice service. During the preliminary 

manufacturer interviews, DOE learned that more than half the sales of product class 5 

currently have French Doors. As a result, DOE used a French Door design as the basis for 

the engineering analysis for this product class. Because neither the products initially 

purchased for teardown, nor the French Door products purchased later, strictly fit the 

intended baseline design configuration, DOE made adjustments to establish product class 

5 French Door designs for the engineering analysis. DOE did this for one of the 25 ft3 

product class 5A reverse engineered units by “removing” the TTD features, and for the 

18.5 ft3 product by “adding” French Door design features. Additional detail regarding 

development of the product class 5 French Door models is discussed below.

French door refrigerator-freezers generally require electric anti-sweat heaters to prevent 

condensation of moisture on the gaskets and/or flip-mullions which seal between the 

French doors, since refrigerant-line anti-sweat heating is not possible in this region. DOE 
5-47

set the electric anti-sweat heater average power input to 2.5 W for the 18.5 ft3 model and 

2 W for the 25 ft3 model. These averages are based on a 10W heater load cycling with the 

compressor, and averaging to account for test procedure treatment of electric anti-sweat 

heaters (energy use is the average of tests with the anti-sweat heater on during one test 

and off during another). The compressor duty cycle was close to 40% for the 25 ft3 model 

and close to 50% for the 18.5 ft3 model. These loads were not present for the models 

representing the reverse engineered products because the 18.5 ft3 product had a single 

door and because DOE understands that the 25 ft3 product was tested with the anti-sweat 

heater not energized.

DOE adjusted the per-length gasket load for the fresh food compartments for the 

preliminary analysis energy models of product class 5 to account for the additional gasket 

region length associated with the French Doors. The modified Windows version of the 

ERA model used in the NOPR analysis did not require this adjustment, since it includes a 

provision to indicate that the product has French Doors. 

The freezer compartment of the 25 ft3 product class 5A teardown model had two 

drawers. Hence, the preliminary analysis energy model representing this product as 

received incorporated an increase in the freezer compartment per-length gasket load to 

account for the increased gasket length. The Windows version of the energy model 

allows indication that the freezer has a double drawer. When establishing the baseline 

ERA model for subsequent design option analysis, DOE readjusted the model for 

consistency with a single-drawer design. DOE took this step in order to establish a 

baseline model representing a single freezer drawer.

DOE eliminated the loads associated with the TTD ice system of the 25 ft3 product class 

5A baseline to create the 25 ft3 product class 5 with French Doors model. This includes 

the loads of the ice chute penetration, as well as the loads associated with the duct which 

conveys cold freezer air to the ice maker compartment. Additional loads and energy use 

associated with heaters in the region of this duct never entered into the model, because 

DOE understands that the teardown product was tested in a fashion which prevented 

activation of these heaters.

After adjustment for the design features for consistency with the desired feature set to 

represent the product class, DOE selected different compressor efficiency levels and/or 

different fan motor types for the baseline energy models in order to achieve modeled 

energy use consistent with the energy conservation standard.

DOE obtained the product class 4 teardown unit (refrigerator-freezer with automatic 

defrost and side-mounted freezer without TTD ice service) with the understanding that it 

had TTD ice service. To address this discrepancy in the energy modeling work, the initial 

baseline model for the product was modified to represent product class 7 (refrigeratorfreezer with automatic defrost and side-mounted freezer with TTD ice service). DOE did 

this by adding load and additional electric anti-sweat heat appropriate for the TTD 

feature.
5-48

DOE conducted the engineering analysis based on the expected revised energy test 

procedure, which includes modified cabinet temperatures as discussed in Section 5.4.2. 

After calibration of the ERA models with EnergyGuide and energy test data according to 

the current energy test procedure, and after the adjustment to the models to better 

represent the products under investigation as described above, DOE adjusted the ERA 

models to represent operation under the new energy test procedure. This adjustment did 

not apply to the freezers, since there are no proposed changes to the freezer compartment 

temperatures. The calculated impact of the compartment temperature changes on the 

energy use is discussed in Section 5.4.2.1 and is shown in Table 5.4.8 of that section. 

This calculated impact of the temperature changes is fairly consistent with the results 

provided by AHAM, although it is less than the impact measured during DOE testing of 

the teardown products.

5.8 DESIGN OPTIONS

After conducting the screening analysis described in chapter 4, DOE considered the 

remaining technologies in the design option analysis. Table 5.8.1 lists the design options 

DOE considered for each product classes. Some design options are only applicable to 

certain types of equipment. Following the table is a description of how DOE applied each 

of the design options during the engineering analysis. See chapter 3 for background 

descriptions of the technologies.
5-49

Table 5.8.1 Design Options by Product Class

Design Option PC3 PC5 PC7 PC9 PC10 PC11 PC18

Increased Insulation 

Thickness



1 in



1 in



3/4 in



3/4 in

Isobutane Refrigerant 

Vacuum-Insulated 

Panels       

Improved Compressor 

Efficiency       

Variable-Speed 

Compressor

      

Increased Evaporator 

Surface Area

     

Increased Condenser 

Surface Area     

Forced Convection 

Condenser 

Brushless DC 

Evaporator Fan

   

Brushless DC 

Condenser Fan    

Adaptive Defrost    

Variable Anti-Sweat 

Heater Control  

5.8.1 Increased Insulation Thickness

Manufacturers stated during discussions that the potential for insulation thickness 

increases is very limited for many product classes. Greater insulation thickness would 

result in either decreased interior volumes, increased exterior dimensions, or some 

combination of both. They cited the high percentage of the market associated with 

replacements and the fixed sizes available for replacement refrigerators in consumers’ 

kitchens. The 1995 TSD supporting the 1997 refrigerator energy conservation standard 

final rule provided information regarding the reduction in served market associated with 

exterior size increases.9

There is some more flexibility in the potential to increase insulation thickness for 

freezers, since freezers are less likely to be placed in fixed-dimension spaces in kitchens. 

Reduction in internal volume is undesirable because this is a key 

selling feature. As a result, DOE did not consider insulation thickness increase in the 

analysis for standard-size refrigerator-freezers.
5-50

DOE considered insulation thickness increases of up to 1 inch for standard-size freezers, 

with a limitation on maximum wall thickness of 3.5 inches.

Compact refrigerators often have limitations on potential for size increase. However, 

many compact refrigerator products currently have insulation thickness no more than an 

inch. The potential energy benefit of insulation thickness increases for these products is 

significant. Hence, DOE considered increases of up to 3/4 inch for these products. DOE 

considered increase up to 3⁄4 inch also for compact freezers.

A manufacturer’s approach to implementing insulation thickness increase would likely 

involve a combination of reduced internal volume and increased external dimensions.

DOE used just external dimension increase, to assure that the product size (represented 

by adjusted volume) and the associated baseline energy use for the product did not 

change for different groups of design options. 

DOE calculated costs associated with insulation thickness increases using the 

manufacturing cost model. As discussed in Section 5.6.6, DOE applied a conservative 

treatment of depreciation costs in which it added the additional cost equal to the 

Greenfield depreciation cost per product in order to reflect the likely build of a new 

production facility. DOE assumed that the depreciation cost would be incurred for any 

increase in insulation thickness. However, DOE allowed for increases in the door 

thickness without applying depreciation costs associated with the cabinet, and vice versa.

The development of these depreciation costs is discussed in section 5.6.6.2 above.

5.8.2 Isobutane Compressor

Comments received at the preliminary public meeting and during the subsequent 

comment period called for use of alternative refrigerants as a design option. As 

mentioned in Chapter 3, R-600a (isobutane) is used predominantly for residential 

refrigeration products in Europe, and it is also used extensively in Asia. Isobutane has the 

potential for higher efficiency than the HFC-134a refrigerant that is used in residential 

refrigeration products in the U.S. DOE did not consider isobutane as a design option in its 

preliminary analyses because it is a hydrocarbon, is subject to charge limits by UL, and is 

not currently on EPA’s Significant New Alternatives Program (SNAP) list of allowed 

refrigerant alternatives to CFCs and HCFCs. DOE has considered isobutane in its NOPR 

analysis because EPA has proposed to add isobutane to the SNAP list. 75 FR 25799 (May 

10, 2010) However, the EPA proposal allows use of isobutane under a charge limitation

of 57 grams for residential refrigeration products. While this quantity of refrigerant is not 

sufficient for most residential refrigeration products manufactured for the U.S. market 

without significant redevelopment of heat exchangers, it is sufficient for use in compact 

refrigerators. Hence, DOE applied this design option only to compact refrigerators 

(Product Class 11).

DOE conducted a theoretical analysis across a range of evaporating and condensing 

temperatures to compare the performance of isobutane refrigerant with HFC-134a. DOE 
5-51

conducted this analysis using the REFPROP database developed by NIST10

• Equal compressor efficiencies for both refrigerants (ratio of power input for 

adiabatic isentropic compression to actual power input).

, with the 

following assumptions.

• Liquid and return gas temperatures both 90  ̊F.

 The results are shown in Figure 5.8.1 below.

Figure 5.8.1 Energy Benefit of Isobutane Compared with HFC-134a

DOE also obtained information regarding the efficiency improvement potential using 

isobutane from compressor vendors and manufacturer discussions. Based on the results of 

its theoretical analysis and the additional information received, DOE assigned a five

percent energy benefit to the conversion to isobutane compressors. DOE implemented 

this in the ERA analysis by reducing the compressor power multiplier from 1.0 to 0.95 

for the HFC-134a compressor model.

Based on discussions with compressor vendors, DOE concluded that the cost impact 

associated with use of isobutane compressors is negligible. Further, DOE concluded that 

the cost impact on the remainder of the sealed system is also negligible. DOE considered 

a cost increase of $1 per product for this design option associated with plant and 

equipment modifications to allow safe charging of isobutane refrigerant. DOE also 
5-52

considered cost increases for use of sealed electrical components in order to safeguard 

against electrical sparks within the electrical components providing an ignition source in 

case of a refrigerant leak. DOE used in its analysis cost increases of $4 per product for 

the baseline simple thermostatic control and an additional $4 to address additional 

electrical content if a variable-speed compressor system is used in the product. 

5.8.3 Vacuum-Insulated Panels

Vacuum-insulated panels (VIPs) increase efficiency by significantly increasing the 

thermal resistivity of the cabinet walls, and therefore decreasing heat penetration into the 

cabinet. DOE considered the addition of 1⁄2-inch thick VIPs to the walls and doors of the 

cabinet for all product classes, and the remainder of the insulation thickness was filled 

with PU foam. Data for VIP thermal characteristics and costs were provided by va-Q-tec, 

a VIP manufacturer. The cost information was confirmed through discussions with 

manufacturers. In these discussions, manufacturers pointed out that edge effects can 

result in actual performance significantly less than predicted. However, DOE considers 

that thermal performance estimates based on the va-Q-tec technology are more accurate 

than for other VIP options because this technology has a more modest mid-panel thermal 

resistance and a significantly thinner metallic layer than other options. The mid-panel 

conductivity of this VIP technology is 3.5 mW/m-C (0.024 Btu-in/sqft-hr- ̊F).11

As mentioned in Section 

In 

contrast, the conductivity of PU foam is in the range 0.13 to 0.14 Btu-in/sqft-hr- ̊F. 

5.7.2, DOE modeled the thermal performance of composite 

walls including VIPs using composite wall average thermal resistivities. The composite 

wall resistivity Rw was calculated as follows.

( )

( ) VIP PU

VIP VIP PU PU

w t t

R t R t R

+

+ =

Where RVIP and RPU are the thermal resistivities of the VIP and the PU foam, and tVIP and 

tPU are the thicknesses of the VIP and PU foam layers. The thermal resistivities for the 

materials are the inverses of the conductivities.

DOE analysis using ERA of cabinet load reduction achievable through the use of VIPs 

using this analysis approach is consistent with analysis carried out by va-Q-tec and also 

consistent with prototype testing using VIP technology. The reduction in cabinet load 

possible using VIPs for a refrigerator-freezer with typical wall thickness is roughly 30%, 

which is consistent with results reported by Electrolux for use of vacuum insulation in 

freezers.

12 However, during NOPR phase discussions with manufacturers, DOE learned 

that different manufacturers have had widely varying levels of success in applying VIPs 

to refrigeration products. The levels of performance benefit reported by manufacturers 

ranged roughly from 0 to 100 percent of the levels predicted by the ERA analysis. DOE 

used a performance degradation factor of 50% in its NOPR analysis to account for this 

variation in experience.
5-53

The quantity of VIP that can be added to the cabinet is limited by the structural design 

requirements. Based on discussions with manufacturers, DOE applied a limit of 50% of 

the cabinet surface area in its analysis. DOE allowed full (100%) coverage of door 

surface area.

The following cost information, which va-Q-tec provided and/or which DOE developed 

based on subsequent discussions, formed the basis of the applied costs for VIPs.

• Average panel cost $3.08/ft2 at 1.2 cm thickness.

• Fill cost as a percent of panel cost 60%.

• Added glue cost for adhering the panel to cabinet surfaces 5% of panel cost.

• Cost savings associated with displaced PU foam 2.5% of panel cost.

In order to allow calculation of costs for other VIP thicknesses, DOE considered the fill 

cost to be proportional to the thickness, and the remaining cost per square foot to be

constant. In addition, DOE calculated direct labor cost associated with application of the 

panel to cabinet and door surfaces based on the $24/hr wage rate (including fringe 

benefits) discussed in section 5.6, and time for application of 10 minutes for a 

compartment and 1 minute for a door. The direct material and labor costs associated with 

use of the VIP must be adjusted to account for capital expenses and overhead associated 

with incorporation of VIPs into the production process. Because the material cost of VIPs 

is currently high in relation to the costs of other materials used in the manufacture of 

refrigerators and freezers, the cost adders for overhead and depreciation discussed in 

Section 5.6.6.1 and shown in Table 5.6.3 were divided by two in order to provide more 

reasonable representation of these costs for this technology. Hence, DOE used the 

following percent additions: 11.7% for standard-size refrigerator-freezers, 14.2% for 

standard-size freezers, and 19.6% for compact refrigerators.

See appendix 4-A for information developed in response to preliminary analysis phase 

comments questioning the ability of VIP suppliers to meet the demand for VIPs that 

might be required by potential DOE standards.

5.8.4 Improved Compressor Efficiency

DOE considered the substitution of higher efficiency compressors for all product classes. 

DOE often applied this design option in two stages if there was a large gap between the 

baseline energy efficiency ratio (EER) and the maximum available EER for a given 

compressor capacity. DOE acquired compressor performance data from compressor 

vendors for use in the energy analysis, including capacity and power input for the 

applicable range of combinations of suction and discharge pressure conditions. As an 

example of the potential for improvement, standard-size baseline refrigerator-freezers 

typically use compressors with a rated EER of 5.0 to 5.5 Btu/h-W. DOE considered 

improved EERs of 5.75 through 6.25 Btu/h-W. 

DOE considered improved-efficiency compressors with EERs up to roughly 6.25 Btu/hW for standard- size refrigerator-freezers. The range of available compressor efficiencies 

is illustrated in Figure 5.8.2 below. 
5-54

The peak available efficiency level does not vary significantly for the range of capacities 

typical for standard-size refrigerator-freezers (600 to 800 Btu/h). However, efficiency 

level drops off considerably for smaller capacity compressors that are generally used in 

compact refrigerators and freezers.

Figure 5.8.2 Compressor Efficiency Data

DOE received estimates for increased cost of higher-efficiency compressors used for 

standard-size refrigerator-freezers and standard-size freezers from compressor vendors. 

These estimates were also discussed with manufacturers. Based on this information, DOE 

developed a curve for the cost premium associated with higher efficiency compressors. 

This curve is shown in Figure 5.8.3 below. 

0

1

2

3

4

5

6

7

0 200 400 600 800 1000

EER (Btu/h-W)

Capacity (Btu/h)

Single Speed

Variable Speed at Lowest Speed

Variable Speed at 3000 rpm
5-55

Figure 5.8.3 Incremental Cost for Single-Speed Compressors for Standard-Size 

Products

When considering compressor efficiency improvement for standard-size products, DOE 

used the performance data of specific higher-efficiency compressors in the energy 

analysis. DOE selected the alternative compressors to have nearly the same capacity as 

the baseline compressors, in order to assure nearly identical performance except for 

compressor power input.

In the analysis of compressor efficiency improvements for compact products, DOE used 

an approach that addressed the reduction of compressor efficiency as the capacity is 

reduced. DOE developed a curve roughly representing the maximum available EER for 

smaller compressors. This curve is compared in Figure 5.8.4 below with the data for 

commercially available compressors.
5-56

Figure 5.8.4 Efficiency Curve for Low Capacity Compressors

To model energy use of higher efficiency low-capacity compressors, DOE reduced the 

power input data for the baseline compressor by a selected factor so that the rated EER 

matches the maximum EER of the above curve. The baseline compressors of the products 

analyzed had EERs typically 0.5 to 1 Btu/h-W lower than the maximum curve shown in 

the figure above.

DOE received vendor cost estimates for efficiency improvements for low-capacity 

compressors. DOE also received information on the typical cost increase during 

discussions with manufacturers of products which use these compressors. A 

representative cost estimate of $10 per 1.0 Btu/h-W efficiency improvement was used in 

the analysis.

5.8.5 Variable-Speed Compressor

Variable speed compressors (VSCs) operate at multiple speeds to allow variation of 

compressor capacity. They also generally use permanent magnet motors, which can be 

more efficient than induction motors for the power level required for residential 

refrigerator compressors. They improve efficiency by (1) use of the higher-efficiency 

motor technology, (2) increasing the operating effectiveness of heat exchangers because 

there is lower mass flow being cooled or warmed by a fixed-size heat exchanger, and (3) 

reducing cycling losses by reducing the number of cycles. VSC technology has been 

0

1

2

3

4

5

6

0 100 200 300 400 500 600

EER (Btu/h-W)

Capacity (Btu/h)

Compressor Data

Maximum EER Curve
5-57

available for many years and a number of refrigerator-freezer products currently use the 

technology. Currently nearly all of these products use Embraco VSCs. DOE obtained 

compressor performance data for the range of sizes of Embraco VSCs. This information 

was used in the energy analysis. DOE selected VSCs so that the VSC capacity when 

operating at 3,000 rpm nearly matched the capacity of the replaced single speed 

compressor. The lowest available speed for the Embraco VSCs is 1,600 rpm. The 

compressor typically cycles at the low speed to maintain internal set points for energy test 

conditions. DOE primarily used the performance data for 1,600 rpm in the energy 

analyses. The performance of VSCs at the lowest speed and at 3,000 rpm is shown in 

Figure 5.8.2 above.

In order to maximize the energy benefit of a VSC, a design needs to address the potential 

increase in energy use associated with longer fan run time. The increase in fan energy use 

can negate much of the reduction in compressor energy use. As a result, it is often 

necessary to use brushless DC fan motors. In addition, brushless DC fan motors can 

operate at different speeds, depending on the design configuration. DOE is not aware of 

brushless DC fan motors designed for 120 VAC power input at representative capacities 

for refrigerator duty that allow adjustment of fan speed, although such a design should be 

viable. Most designs incorporating fan speed control use DC-input power for the fans and 

require a control system which can provide the DC power and vary it to adjust fan speed. 

DOE’s analysis did not involve optimization of fan speed and power with the variable 

speed compressor system. Instead, DOE selected a fan speed to achieve roughly 50% 

power input, using the cube law for fan power to calculate power input (The cube law 

states that for a given fan and air flow system geometry, air flow is proportional to fan 

speed and power input is proportional to the cube of fan speed).

DOE obtained estimates of the cost increase for switching to VSCs from Embraco, and 

from discussions with manufacturers. An average of the estimates of this cost increase 

provided by the manufacturers weighted by manufacturer market share is near $56. This 

includes the compressor and its motor controller, but does not include additional changes 

which might be required to implement a variable speed system. DOE used the $56 cost 

increase in the analyses. Additional costs associated with conversion of a refrigeration 

system to variable speed operation are associated with a switch to brushless DC fan 

motors and the use of a control system sophisticated enough to provide adequate or 

optimized control. The Embraco VSC design includes a control system that can be used 

with a conventional mechanical thermostat. This system has been implemented in a 

commercially available freezer.13 The Embraco control adjusts speed based on the 

response of the mechanical thermostat. DOE considers that this approach is suitable for 

products with manual defrost. For products with automatic defrost and especially 

adaptive defrost, it is not reasonable to expect that the Embraco system alone would be 

suitable. DOE included in cost estimates an additional $30 for addition of an electronic 

control system for products with automatic defrost. For product classes for which a 

significant portion of current models already have electronic control (product classes 5 

and 7), analysis was conducted for an electronic control unit and a mechanical control 

unit. DOE also considered use of brushless DC fan motors necessary when switching to 

VSCs. However, the DOE analysis incorporated switch to brushless DC fan motors as a 
5-58

design option earlier than VSCs in the progressive layering of design options, because 

brushless DC fan motors are more cost effective than a full conversion to variable speed.

DOE also considered the additional standby power consumption associated with the 

electronic control board required for conversions to variable speed operation. DOE 

attributed 1.5 W of standby power to electronic controls. Use of electronic controls with a 

VSC makes dedicated controllers for adaptive defrost and variable anti-sweat 

unnecessary. In cases where a VSC was added after either the adaptive defrost or variable 

anti-sweat design options were utilized, DOE removed the 0.5 W of standby power

assumed for each of these self-contained controllers. The costs of the self-contained 

controllers were then also removed, assuming these design options preceded 

implementation of VSCs in the analysis.

DOE also adjusted the compressor run time between defrosts when applying a VSC. 

Since the compressor duty cycle typically increases significantly when switching to a 

VSC, the appropriate compressor run time between defrosts should increase to maintain 

equivalent defrost performance. DOE increased this parameter in the ERA model to 

achieve the same defrost frequency when applying the VSC design option. 

5.8.6 Increased Evaporator Surface Area

The evaporator is necessary for transferring heat from the cabinet to the refrigerant. 

Larger surface area allows the heat transfer to occur more efficiently. DOE considered an 

increase in evaporator surface area for all products analyzed. In some cases the size 

increase was limited by available space. This was true especially for the chest freezers 

and compact refrigerators. DOE reviewed the space available in the teardown products 

that served as the basis for the energy modeling to determine how much size increase 

would be possible without requiring significant modifications to the cabinet design. In 

some cases, DOE determined that no size increase was possible. 

In the preliminary analyses, evaporator size increases were implemented in the energy 

analysis for forced convection evaporators through the use of adjustment factors applied 

to the overall UA factor (heat transfer coefficient times surface area) and to the 

refrigerant side pressure drop. These factors were proportional to the intended heat 

exchanger surface area increases. DOE modified this methodology in the NOPR stage, 

using instead direct adjustment of the input parameters describing the evaporator 

geometry. DOE increased either the number or length of tube rows as appropriate for the 

space available for size increase. In cases where DOE increased the length of the 

evaporator in the direction of airflow, it also increased the fan power input by a factor 

equal to half the evaporator size increase (this reflects evaporator pressure drop increase 

proportional to the size increase and an assumption that the evaporator pressure drop 

represents half of the system airside pressure drop). 

Treatment of the cost of the evaporator size increase depended on the evaporator type. 

For forced convention and roll bond evaporators, DOE adjusted the baseline costs of the 
5-59

evaporators upwards by the size increase factor. For cold wall evaporators, DOE directly 

calculated the cost increase using the manufacturing cost model by increasing the tube 

lengths and materials associated with providing good tube/liner thermal contact.

5.8.7 Increased Condenser Surface Area

The condenser transfers heat from the refrigerant to the ambient air. Larger surface area 

allows the heat transfer to occur more efficiently. DOE considered increase in condenser 

surface area for all products analyzed. In some cases the size increase was limited by 

available space. This was true especially for hot wall or static condensers. DOE reviewed 

the space available in the teardown products that served as the basis for the energy 

modeling to determine how much size increase would be possible without requiring 

significant modifications to the cabinet design. In some cases, DOE determined that no 

size increase was possible. 

In the preliminary analyses, condenser size increases were implemented in the energy 

analysis for forced convection condensers through the use of adjustment factors applied 

to the overall UA factor (heat transfer coefficient times surface areas) and to the 

refrigerant side pressure drop. These factors were proportional to the intended heat 

exchanger surface area increases. DOE modified this methodology in the NOPR stage, 

using instead direct adjustment of the input parameters describing the condenser 

geometry. DOE increased either the number or length of tube rows as appropriate for the 

space available for size increase. In cases where DOE increased the length of the 

condenser in the direction of airflow, it also increased the fan power input by a factor 

equal to the condenser size increase (this reflects condenser pressure drop increase 

proportional to the size increase and an assumption that the condenser pressure drop 

represents all of the system airside pressure drop). 

Treatment of the cost of the condenser size increase depended on the condenser type. For 

forced convention and static condensers, DOE adjusted the baseline costs of the 

condensers upwards by the size increase factor. For hot wall condensers, DOE directly 

calculated the cost increase using the manufacturing cost model by increasing the tube 

lengths and materials associated with providing good tube/shell thermal contact.

5.8.8 Brushless DC Fan Motors

Brushless DC fan motors are more efficient than the shaded pole motors which are often 

used in baseline model refrigerators. 

For the 1997 refrigerator energy conservation standard final rule, DOE analysis included 

reduction of motor power input from initial values in a range from 8 to 12 W for shaded 

pole fan motors to 4.5 W for brushless DC motors.9 This is a reduction in power ranging 

from 44 to 57%.

The fan power input measured for the teardown products are summarized in Table 5.8.2

below. For the baseline/ENERGY STAR product pairs, the table presents power input for 
5-60

both sets of each applicable fan. The fan motor power reduction associated with the 

switch to brushless DC motors based on this data is in the range 60% to 65%.

Table 5.8.2 Teardown Product Fan Power Input

Product Evaporator Fans Condenser Fans

Shaded Pole Brushless 

DC

Shaded Pole Brushless 

DC

21 ft3 Top-Mount** 5.7, 6.1 NA 9.4 3.3

26 ft3 Side-Mount** 5.6, 5.8 NA 8.5 3.4

25 ft3 Bottom Mount 1 6.5 NA NA 3.7

18.5 ft3 Bottom Mount 6.2 NA NA 3.8

25 ft3 Bottom Mount 2 NA 3.25* NA 2.2*

22 ft3 Side-Mount NA 3.25* 9.1 NA

20 ft3 Upright Freezer** 11.5 4.5 NA NA

14 ft3 Upright Freezer 7.4 NA NA NA

*DC-input fan. The listed wattage is nominal.

**Data provided for a baseline/ENERGY STAR product pair.

DOE also obtained information on typical fan motor power reduction associated with a 

switch to brushless DC motors during discussions with manufacturers. The responses 

indicated that the reductions would be more modest than suggested by the 1995 TSD 

values or the measurements of teardown products. DOE selected a compromise power 

reduction of 50% when the possible reduction was not already clearly illustrated by the 

measurements of the baseline/ENERGY STAR teardown product pairs under analysis.

DOE obtained incremental cost estimates for the switch to brushless DC motors through 

discussion with Matsushita, a key vendor supplying these motors, and through 

discussions with manufacturers. DOE used incremental cost estimates of $4.30 for 

condenser fans and $4.10 for evaporator fans.

5.8.9 Adaptive Defrost

An adaptive defrost system adjusts the time interval between defrosts based on some 

indication of the need for defrost. A common indicator is the length of time required to 

complete the previous defrost. Other indicators could include the number of door 

openings or a measurement of ambient humidity. DOE considered this design option for 

product classes which have automatic defrost (product classes 3, 5, 7, and 9). The ERA 

model allows input of compressor run time between defrost. To model this option, DOE 

increased the compressor run time between defrosts to 24 hours, as compared to the 

typical range for baseline products of 10-15 hours. For the preliminary analyses, DOE 

used a compressor run time between defrosts of 38 hours. The 38 hours is the default 

time interval specified by the test procedure assuming default values of the minimum and 

maximum compressor run intervals of 12 and 84 hours, allowed if an algorithm does not 

have specific values of these parameters. Manufacturer interviews conducted during the 

NOPR stage suggested that minimum and maximum intervals of 6 and 96 hours are more 
5-61

reflective of adaptive defrost systems. Using these minimum and maximum compressor 

run values in the test procedure yields the 24 hours used in the NOPR analyses.

In cases in which DOE applied adaptive defrost in the analysis to a product that did not 

already have electronic controls, DOE assumed use of a standalone adaptive defrost 

controller. DOE used a standby power consumption of 0.5 W for this type of controller.

Based on discussions with manufacturers, DOE used an incremental cost of $8 in the 

energy analysis for adaptive defrost, if a standalone adaptive defrost controller was used. 

Refrigerators which already have electronic control can implement adaptive defrost with 

programming changes which incur no per-unit cost. 

In cases where both adaptive defrost and variable speed compressor design options were 

analyzed, the cost of the adaptive defrost was eliminated, because the introduction of 

electronic controls would make use of a standalone adaptive defrost controller 

unnecessary.

5.8.10 Variable Anti-Sweat Heater Control

Variable anti-sweat heater control adjusts the time-average wattage of an electric antisweat heater based on ambient temperature and humidity conditions so that all surfaces 

are just above the ambient dew point. DOE considered this option for bottom-mount 

French-door refrigerator-freezers (product class 5) and for side-mount refrigeratorfreezers with TTD ice (product class 7). French-door products generally use electric antisweat heaters in the region of the seal between the two fresh food doors to control 

condensation because warm liquid anti-sweat heating cannot easily be applied in this 

region. Similarly, products with TTD ice generally use electric anti-sweat heaters in the 

region around the ice dispenser opening. Most modern refrigeration products use warm 

liquid anti-sweat heating in most regions susceptible to condensation of moisture (i.e. the 

door gaskets and nearby door frame areas). However, the French Door and TTD 

dispenser regions mentioned above are typical exceptions. To model the energy use 

reduction associated with this design option, DOE established a curve representing the 

heater power input as a function of ambient humidity. DOE then calculated annual 

average electric anti-sweat heater wattage based on the frequency distribution of 

humidity levels established in the GE waiver describing a test procedure for this control 

scheme.14

Implementation of variable anti-sweat heater control requires use of a humidity sensor 

and an electronic controller which can adjust the time-average heater wattage 

appropriately. For products which already have electronic control, DOE used the cost just 

of a humidity sensor. DOE used a cost of $9.48 for a Honeywell humidity sensor based 

on high-quantity pricing.

The selected DOE curves are based on power levels of 0W at 50% RH and 9W 

at 100% RH for product class 5 and 0W at 50% RH and 2W at 100% RH for product 

class 7. 

15 No product currently exists which provides standalone 

variable anti-sweat heater control. However, DOE considers the $8 example of the 

standalone adaptive defrost controller to be representative of the incremental cost of such 

a product. DOE also considered standby power consumption for this design option in the 
5-62

revised NOPR analysis: 0.2 W of standby power consumption for the humidity sensor, 

and 0.5 W of standby power consumption for a self-contained electronic controller. For 

the case of a product already having electronic controls, DOE added just the 0.2 W 

standby power load associated with the sensor.

5.8.11 Forced Convection Condenser

A forced convection condenser can be more efficient than a hot wall condenser, because 

it enables more effective heat transfer from the refrigerant to the ambient air. DOE 

considered this option for upright freezers only (product class 9). This conversion 

involves the addition of a typical wire-tube condenser, a fan assembly, wiring to power 

the fan, and a warm liquid anti-sweat heating loop, and the elimination of hot wall tubing 

on the insulation side of the outer shell. In the case of the upright freezer products 

examined for the reverse engineering work, there was ample space underneath the cabinet 

for the condenser and fan assembly. In addition, these products incorporated hot gas 

condensate pan heaters. These heaters could be eliminated in a forced-convection 

arrangement, because the condenser heat and air flow of the forced convection 

arrangement would be sufficient to evaporate the condensate, as is generally done for 

refrigerator-freezers. DOE used a net incremental cost of $12 for this conversion, 

assuming use of a brushless DC fan motor—most of the cost of the added components 

would be saved through elimination of the hot wall condenser. DOE analyzed this design 

option both with shaded pole and brushless DC condenser fans. The option provided an 

energy benefit in combined design option analysis only when using the brushless DC fan 

motor. 

5.9 ENGINEERING ANALYSIS RESULTS

This section shows the incremental cost curves developed by DOE.

5.9.1 DOE Cost-Efficiency Curves 

DOE generated cost-efficiency curves for two product volumes in each of the seven 

analyzed freestanding (non-built-in) product classes based on combinations of individual 

design options. For the built-in product classes, DOE analyzed one product of each class. 

DOE normalized the curves by converting to costs at specific efficiency levels (every 5% 

energy use reduction up to max tech) for simplified downstream analysis. 

Conversion of cost curves to the specified efficiency levels was complicated by the 

characteristics of the design options required to provide further efficiency improvement. 

Some design options can be partially applied, while others cannot. For instance, the cost 

for compressor efficiency improvement, illustrated in Figure 5.8.3, varies as the 

efficiency varies. Because intermediate efficiency level compressors are generally 

available, the cost to achieve a portion of the efficiency improvement calculated in the 

energy model would be a portion of the total design option cost. However, in some cases, 

such as implementation of a variable speed compressor, the design option cannot be 

partially implemented. For these cases, DOE applied the entire cost of the design option 
5-63

at the intermediate efficiency level, even though the design might overshoot the 

efficiency level. This causes some of the incremental cost curves to have slopes which 

don’t increase monotonically.

The DOE incremental MSP costs are presented in the tables below: Table 5.9.1 for 

standard-size refrigerator-freezers, Table 5.9.2 for standard-size freezers, Table 5.9.3 for 

compact refrigeration products, and Table 5.9.4 for built-in products. DOE analyzed two 

sizes of each product for all but the built-in products. DOE averaged the results for each 

of these pairs of products to derive the final values presented in the tables. 

Table 5.9.1 Incremental Manufacturer Selling Price Results for Standard-Size 

Refrigerator-Freezers

Efficiency Level 

(percent less than 

baseline energy use)

Product Class

3: Refrigeratorfreezers —

automatic defrost 

with top-mounted 

freezer without TTD 

ice service

5: Refrigeratorfreezers —

automatic defrost 

with bottommounted freezer 

without TTD ice 

service

7: Refrigeratorfreezers —

automatic defrost 

with side-mounted 

freezer with TTD 

ice service

10% $11.81 $12.99 $9.90 

15% $19.73 $21.64 $19.03 

20% $73.13 $37.54 $42.45 

25% $106.73 $89.52 $94.21 

30% $180.46 $175.05 $206.85 

Max Tech (% -- Cost) 36% -- $286.19 36% -- $293.47 33% -- $295.21 

Table 5.9.2 Incremental Manufacturer Selling Price Results for Standard-Size 

Freezers

Efficiency Level 

(percent less than 

baseline energy use)

Product Class

9: Upright freezers with 

automatic defrost

10: Chest freezers and all other 

freezers except compact freezers

10% $11.19 $6.44 

15% $28.46 $14.68 

20% $43.77 $24.19 

25% $67.00 $62.33 

30% $88.22 $79.17 

35% $135.70 $127.07 

40% $201.92 

Max Tech (% -- Cost) 44% -- $348.61 41% -- $223.55
5-64

Table 5.9.3 Incremental Manufacturer Selling Price Results for Compact 

Refrigerators and Freezers

Efficiency Level 

(percent less than 

baseline energy use)

Product Class

11: Compact refrigerators and 

refrigerator-freezers with 

manual defrost

18: Compact chest freezers

10% $4.64 $5.99 

15% $8.17 $16.70 

20% $13.19 $52.73 

25% $23.22 $61.54 

30% $31.20 $87.84 

35% $53.61 $94.47 

40% $60.14 

45% $87.47 

50% $102.35 

Max Tech (% -- Cost) 59% -- $155.96 42% -- $157.09

Table 5.9.4 Incremental Manufacturer Selling Price Results for Built-In 

Refrigeration Products

Efficiency Level 

(percent less than 

baseline energy 

use)

Product Class

3A-BI: BuiltIn AllRefrigerators5-BI: Built-In 

Bottom-Mount 

RefrigeratorFreezers 

without TTD 

ice service

7-BI: Built-In 

Side-Mount 

RefrigeratorFreezers with 

TTD ice 

service 

9-BI: Built-In 

Upright 

Freezers

10% $7.14 $21.47 $51.45 $15.68

15% $18.90 $85.82 $123.47 $27.44

20% $127.10 $165.89 $281.53 $99.23

25% $272.09 $295.28 $211.74

Max Tech (%--cost) 29%--$381.70 27%--$370.22 22%--$371.27 27%--$297.56
5-65

5.9.2 REFERENCES

 

1 “ERA 1.2E, EPA Refrigerator Analysis Program, User’s Manual, Report to the 

Environmental Protection Agency Atmospheric Pollution Prevention Division,” Arthur 

D. Little, Inc., February 1997

2 "Engineering Computer Models for Refrigerators, Freezers, Furnaces, Water Heaters, 

Room and Central Air Conditioners," Report to U.S. DOE, by Arthur D. Little, Inc., 

November 1982.

3 McLinden, M., "Theoretical Vapor Compression Cycle, CYCLE7," unpublished.

4 Morrison, G., and McLinden, M., "Application of a Hard Sphere Equation of State to 

Refrigerants and Refrigerant Mixtures," National Bureau of Standards Technical Note 

1218, 1986.

5 "NIST Standard Reference Database 23: NIST Thermodynamic Properties of 

Refrigerants and Refrigerant Mixtures Database, Version 3.0," NIST, December 1991.

6 EPA Refrigerator Analysis (ERA) Program: User’s Manual, Version 1.0. United States 

Environmental Protection Agency. EPA-430-R-93-007. June 1993. with Version 1.2 

Update, November 1994.

7 M. T. Holtzapple and R. G. Carranza, “Heat Transfer and Pressure Drop of Spined Pipe 

in Cross-Flow – Part I: Pressure Drop Studies”, ASHRAE Transactions, 1990.

8 Holtzapple, M.T., A.L.Allen, and K.Lin, “Heat Transfer and Pressure Drop of Spined 

Pipe in Cross-Flow – Part II: Heat Transfer Studies, AHSRAE Transactions, 1990.

9 U.S. Department of Energy-Office of Codes and Standards. Technical Support 

Document: Energy Efficiency Standards for Consumer Products: Refrigerators, 

Refrigerator-Freezers, and Freezers, July 1995. Washington, DC. DOE/EE-0064.

10 REFPROP, “Reference Fluid Thermodynamic and Transport Properties”, NIST 

Standard Reference Database 23, Version 8.0, E.W. Lemmon, M.L. Huber, and M.O. 

McLinden, Physical and Chemical Properties Division, U.S. Secretary of Commerce, 

2007.

11 Va-q-plus data sheet, http://www.va-q-tec.com/produkte/en/pplus/prod/va-qplus_pdb_en.pdf

12 “Electrolux's New Vacuum Insulated Freezer Technology,” Appliance Magazine, 

August 2003. 

<http://www.appliancemagazine.com/new_products.php?article=4971&zone=204&first=1>
5-66

 13 Personal communication with Embraco, March 2009.

14 Energy Conservation Program for Consumer Products: Decision and Order Granting a 

Waiver to the General Electric Company From the Department of Energy Residential 

Refrigerator and Refrigerator-Freezer Test Procedure, Notice of decision and order, 

February 27, 2008. 73 FR 10425.
6-i

CHAPTER 6. MARKUPS FOR PRODUCT PRICE DETERMINATION

TABLE OF CONTENTS

6.1 INTRODUCTION ........................................................................................................... 6-1

6.1.1 Distribution Channels...................................................................................................... 6-1

6.1.2 Markup Calculation Procedure ........................................................................................ 6-1

6.2 MANUFACTURER MARKUP ...................................................................................... 6-2

6.3 RETAILER MARKUP .................................................................................................... 6-3

6.3.1 Approach for Retailer Markups....................................................................................... 6-3

6.3.1.1 Baseline Retailer Markup .............................................................................. 6-3

6.3.1.2 Incremental Retailer Markup ......................................................................... 6-4

6.4 SALES TAXES ............................................................................................................... 6-8

6.5 SUMMARY OF MARKUPS .......................................................................................... 6-8

LIST OF TABLES

Table 6.2.1 Major Appliance Manufacturer Markups ............................................................ 6-2

Table 6.3.1 Data for Baseline Markup Calculation: Electronics and Appliance Stores 

(2002)................................................................................................................... 6-4

Table 6.3.2 Data for Incremental Markup Calculation: Electronics and Appliance 

Stores (2002)........................................................................................................ 6-6

Table 6.3.3 Electronics and Appliance Stores, Concentration by Four Large Firms ............. 6-7

Table 6.4.1 Average Sales Tax Rates by Census Division and Large State ........................... 6-8

Table 6.4.2 Average Sales Tax Rates by Product................................................................... 6-8

Table 6.5.1 Summary of Markups .......................................................................................... 6-9
6-1

CHAPTER 6. MARKUPS FOR PRODUCT PRICE DETERMINATION

6.1 INTRODUCTION

To carry out its analyses, DOE needed to determine the cost to the consumer of baseline 

products and the cost of more-efficient units. As discussed in chapter 8, DOE developed retail 

prices for baseline products using proprietary retail price data collected by The NPD Group. For 

products with higher-than-baseline efficiency, DOE estimated the consumer prices by applying 

appropriate markups to the incremental manufacturing costs estimated in the engineering 

analysis. 

6.1.1 Distribution Channels

The appropriate markups for determining consumer equipment prices depend on the type 

of distribution channels through which products move from manufacturers to purchasers. At 

each point in the distribution channel, companies mark up the price of the equipment to cover 

their business costs and profit margin. 

Data from the Association of Home Appliance Manufacturers (AHAM)1

6.1.2 Markup Calculation Procedure

indicate that an 

overwhelming majority of residential appliances are sold through retail outlets. Because DOE is 

not aware of any other distribution channel that plays a significant role for residential 

refrigeration products, DOE assumed that all of the refrigeration products are purchased by 

consumers from retail outlets. DOE did not include a separate distribution channel for 

refrigeration products included as part of a new home, as it did not have information on the 

extent to which these products are “pre-installed” by builders in new homes.

As just discussed, at each point in the distribution channel, companies mark up the price 

of the equipment to cover their business costs and profit margin. In financial statements, gross 

margin is the difference between the company revenue and the company cost of sales or cost of 

goods sold (CGS). The gross margin includes the expenses of companies in the distribution 

channel—including overhead costs (sales, general, and administration); research and 

development (R&D) and interest expenses; depreciation, and taxes—and company profits. To 

cover costs and to contribute positively to company cash flow, the price of products must include 

a markup. Products command lower or higher markups, depending on company expenses

associated with the product and the degree of market competition. In developing markups for 

manufacturers and retailers, DOE obtained data about the revenue, CGS, and expenses of firms 

that produce and sell the products of interest. 
6-2

6.2 MANUFACTURER MARKUP

DOE uses manufacturer markups to transform a manufacturer’s production costs into a 

manufacturer selling price. DOE used CGS and gross margin to calculate the manufacturer 

markup (MUMFG) with the following equation:

MFG

MFG MFG

MFG CGS

CGS GM

MU

+ =

where:

MUMFG = Manufacturer markup,

CGSMFG = Manufacturer’s cost of goods sold or Manufacturer Production Cost 

(MPC), and

GMMFG = Manufacturer’s gross margin.

The manufacturer’s CGS (or MPC) plus its GM equals the manufacturer selling price 

(MSP).

In developing the initial baseline manufacturer markup, DOE used the same markup as 

the 2009 cooking products final rule and the 2010 commercial clotheswashers final rule. DOE 

used this baseline manufacturer markup because all publicly traded companies that manufacture 

residential refrigeration equipment also manufacture a number of other appliances, and because 

the 1.26 baseline manufacturer markup had already been vetted during the rulemakings for these 

other products. DOE developed this average manufacturer markup by examining the annual 

Securities and Exchange Commission (SEC) 10-K reports filed by three publicly-traded 

manufacturers primarily engaged in appliance manufacturing.2 Because these companies are 

typically diversified, producing a range of different appliances, an industry average markup was 

assumed by DOE to be representative for the manufacture of refrigeration products. DOE 

evaluated markups for the years 1999─2006. Table 6.2.1 lists the average corporate gross margin 

during the years 1999─2006, and corresponding markups, for each of the three manufacturers. 

Table 6.2.1 Major Appliance Manufacturer Markups

Mfr A Mfr B Mfr C

Average Net Revenues (Million) $290 $4,444 $12,499

Average Cost of Goods Sold $215 $3,150 $10,017

Markup 1.35 1.41 1.35

Source: SEC 10-K reports (1999-2006)

The average markup value based on these three companies is 1.26, which is the initial 

value that DOE used for standard-size refrigerator-freezers, standard-size freezers, and compact 

refrigeration products. DOE requested manufacturer feedback on the accuracy of this estimate 

and other financial assumptions during DOE’s confidential manufacturer impact analysis 

interviews and continues to use this value for the NOPR. For built-in refrigeration products, 
6-3

DOE used a baseline manufacturer markup of 1.40. DOE calculated the built-in refrigeration 

manufacturer markup using the weighted average market share of information also submitted 

during manufacturer interviews. 

6.3 RETAILER MARKUP 

6.3.1 Approach for Retailer Markups

DOE based the retailer markups for residential refrigeration products on financial data for 

Electronics and Appliance Stores from the 2002 U.S. Census Business Expenditure Survey

(BES), which is the most recent available survey.

3 DOE organized the financial data into 

statements that break down cost components incurred by firms in this category. DOE assumes 

that the income statements faithfully represent the various average costs incurred by firms selling 

home appliances. Although Electronics and Appliance Stores handle multiple commodity lines, 

the data provide the most accurate available indication of expenses for selling home appliances.

The BES data provided for Electronics and Appliance Stores only contain total sales and 

detailed operating expenses. In order to construct a complete data set to estimate markups, DOE 

needed to estimate CGS and gross margin. The 1997 Business Expenses Survey provides total 

sales, gross margin and detailed operating expenses of Household Appliance Stores. The CGS 

and gross margin account for around 70% and 30% of the total sales, respectively. DOE found 

that gross margin as percent of sales has been roughly constant in this category from 1993 to 

2007.

a

6.3.1.1 Baseline Retailer Markup

Therefore, DOE assumed that the fractions of CGS and gross margin as percent of sales 

in 2002 are the same as in 1997. Following this assumption, DOE calculated the CGS, gross 

margin and net profit for Electronics and Appliance Stores in the 2002 BES. 

b

The baseline markup relates the manufacturer sales price of baseline products to the 

retailer sales price. DOE considers baseline models to be equipment sold under existing market 

conditions (i.e., without new energy efficiency standards). DOE calculated the baseline markup 

(MUBASE) for retailers as an average markup using the following equation:

RTL

RTL RTL

BASE CGS

CGS GM MU + =

where:

 

a U.S. Census, 2007 Annual Retail Trade Report: Electronics and Appliance Stores Sales and Gross Margin 

b As described in section 6.1, the baseline retail markup was not used in the analysis for refrigeration products. DOE 

presents the derivation of this markup so it can be contrasted with the incremental retail markup.
6-4

MUBASE = Baseline retailer markup,

CGSRTL = Retailer’s cost of goods sold,

GMRTL = Retailer’s gross margin, 

Table 6.3.1 shows the calculation of the baseline retailer markup.

Table 6.3.1 Data for Baseline Markup Calculation: Electronics and Appliance Stores 

(2002)

Kind of business item

Amount 

($1,000)

Sales $83,896,811

Cost of Goods Sold (CGS) $57,888,800

Gross Margin (GM) $26,008,011

Baseline Markup = (CGS+GM)/CGS 1.45

Source: U.S. Census, 2002 Business Expenses Survey (for Sales) and 1997 Business Expenses Survey (for CGS and 

GM shares)

6.3.1.2 Incremental Retailer Markup

Incremental markups are coefficients that relate the change in the manufacturer sales 

price of higher-efficiency models to the change in the retailer sales price. DOE considers higherefficiency models to be equipment sold under market conditions with new efficiency standards. 

The incremental markup reflects a situation in which the retailer faces an increase in CGS for a 

particular product due to new or amended standards.

Unfortunately, empirical evidence regarding appliance retailer markup practices when a 

product increases in cost (due to increased efficiency or other factors) is lacking. DOE 

understands that real-world markup practices will vary depending on the market conditions faced 

by retailers, on the magnitude of the change in CGS associated with an efficiency increase and 

on any associated changes in retail costs. Pricing in retail stores may also involve rules of thumb 

that are difficult to know and to incorporate into DOE’s analysis.

Given the uncertainty about actual markup practices in appliance retailing, DOE uses an 

approach that reflects the following key concepts:

 

1. Changes in the efficiency of the goods sold are not expected to increase economic profits. 

Thus, DOE calculates markups/gross margins to allow cost recovery for retail companies 

in the distribution chain (including changes in the cost of capital) without changes in 

company profits. 
6-5

2. Efficiency improvements impact some distribution costs but not others. DOE sets

markups and retail prices to cover the distribution costs expected to change with 

efficiency but not the distribution costs that are not expected to change with efficiency. 

The incremental markup approach is described in more detail in Dale et al. (2004).4

To estimate incremental retailer markups, DOE divides retailers’ operating expenses into 

two categories: (1) Those that do not change when CGS increases due to amended efficiency 

standards (“fixed”), and (2) Those that increase proportionately with CGS (“variable”). DOE

defines fixed costs to include labor and occupancy expenses because these costs are not likely to 

increase as a result of a rise in CGS due to amended efficiency standards. All other expenses, as 

well as the net profit, are assumed to vary in proportion to CGS. Although it is possible that 

some of the other expenses may not scale with CGS, DOE is inclined to take a more conservative 

position and include these as variable costs. (Note: Under DOE’s approach, a high fixed cost 

component yields a low incremental markup.) 

DOE calculated the incremental markup (MUINCR) for retailers using the following 

equation:

RTL

RTL RTL

INCR CGS

CGS VC MU + =

where:

MUINCR = Incremental retailer markup,

CGSRTL = Retailer’s cost of goods sold, and

VCRTL = Retailer’s variable costs.

Table 6.3.2 shows the breakdown of operating expenses using the 2002 BES data. The 

incremental markup is calculated as 1.17.
6-6

Table 6.3.2 Data for Incremental Markup Calculation: Electronics and Appliance Stores 

(2002)

Amount 

($1,000)

Sales $83,896,811

Cost of Goods Sold (CGS) $57,888,800

Gross Margin (GM) $26,008,011

Labor & Occupancy Expenses (“Fixed”)

Annual payroll $10,267,605

Employer costs for fringe benefit $1,407,970

Contract labor costs including temporary help $160,094

Purchased utilities, total $427,809

Cost of purchased repair and maintenance services $308,789

Cost of purchased management consulting administrative services and other 

professional services $300,548

Purchased communication services $400,598

Lease and rental payments $2,655,286

Taxes and license fees (mostly income taxes) $385,538

Subtotal: $16,314,237

Other Operating Expenses & Profit (“Variable”)

Expensed computer related supplies $86,751

Cost of purchased packaging and containers $41,866

Other materials and supplies not for resale $611,361

Cost of purchased transportation, shipping and warehousing services $500,233

Cost of purchased printing services $285,012

Cost of purchased advertising and promotional services $1,840,898

Cost of purchased legal services $90,020

Cost of purchased accounting, auditing, and bookkeeping services $86,292

Cost of purchased custom coded original software (expensed) including adaption of 

off-the-shelf software $18,944

Cost of system support design and services including web design $35,748

Cost of insurance $393,201

Cost of data processing and other purchased computer services, except 

communications $41,056

Depreciation and amortization charges $1,229,110

Commissions paid $106,061

Other operating expenses $2,929,906

Cost of contract work $21,955

Net profit before taxes $1,375,360

Subtotal: $9,693,774

Incremental Markup = (CGS+Total Other Operating Expenses and Profit)/CGS 1.17

Source: U.S. Census, 2002 Business Expenses Survey

By dividing expenses into fixed and variable components, the incremental markup 

approach envisions that retailers cover costs without changing profits. Although retailers may be 
6-7

able to reap higher profits for a time, DOE’s approach assumes that competition in the appliance 

retail market, combined with relatively inelastic demand (i.e., the demand is not expected to 

decrease significantly with a relatively small increase in price), will tend to pressure retail 

margins back down. 

To measure the degree of competition in appliance retailing, DOE estimated the four firm 

concentration ratio (FFCR) of major appliance sales in three retail channels: Electronics and 

Appliance Stores, Building and Material and Supplies Dealers, and General Merchandise Stores.

The FFCR represents the market share of the four largest firms in the relevant sector. Generally, 

an FFCR of less than 40% indicates that the sector is not concentrated and an FFCR of more than 

70% indicates that a sector is highly concentrated.c d

The FFCR of sub-sector appliance sales within each channel is equal to the sector FFCR 

times the percent of total sales within each channel accounted for by major appliances. As shown 

in Table 6.3.3, the results indicate that appliance sales in Electronics and Appliance Stores, 

Household Appliance Stores, Building Material Supplies Dealers and General Merchandise 

Stores have a FFCR well under the 40% threshold. Moreover, the Electronics and Appliance 

Stores sector includes “Household Appliance Stores” as a subsector. Because there are many 

stores in this subsector, it has a FFCR of only 16.8%. 

Table 6.3.3 Electronics and Appliance Stores, Concentration by Four Large Firms

Sector

Four Firm 

Concentration Ratio

(Percent of Sector Sales)

Percent of Sales

Accounted for by 

Major Appliances

Four Firm 

Concentration Ratio

(Percent of Major 

Appliance Sales)

Electronics and Appliance 

Stores 43.9 39.4 17.3

Household Appliance 

Stores subsector 16.8 - -

Building Material and 

Supplies Dealers 41.7 15.7 6.5

General Merchandise 

Stores 65.1 35.4 23.0

Source: U.S. Economic Census, Establishment and Firm Size: (Including Legal Form of Organization), 1997, 2002.

*Note: The assumption used here is that major appliance sales are uniformly distributed within all firms in each 

sector. 

 c University of Maryland University College

http://info.umuc.edu/mba/public/AMBA607/IndustryStructure.html

d Quick MBA

http://www.quickmba.com/econ/micro/indcon.shtml
6-8

6.4 SALES TAXES

The sales tax represents state and local sales taxes that are applied to the consumer 

equipment price. The sales tax is a multiplicative factor that increases the consumer equipment 

price.

DOE derived state and local taxes from data provided by the Sales Tax Clearinghouse.

5

 

DOE derived population-weighted average tax values for each Census division and large state, as 

shown in Table 6.4.1.

Table 6.4.1 Average Sales Tax Rates by Census Division and Large State

Census Division/State Tax Rate

New England 6.1%

Mid Atlantic 6.6%

East North Central 6.9%

West North Central 6.9%

South Atlantic 6.6%

East South Central 7.9%

West South Central 8.4%

Mountain 6.8%

Pacific 7.5%

New York State 8.5%

California 9.2%

Texas 8.1%

Florida 6.7%

DOE then derived U.S. average tax values for each product (as shown in Table 6.4.2 

below) based on the product’s saturation within each Census division and large state. It 

determined the saturations from the DOE Energy Information Administration (EIA)’s 2005

Residential Energy Consumption Survey.6

 

Table 6.4.2 Average Sales Tax Rates by Product

Product Tax Rate

Refrigerators (Standard-size and compact) 7.3%

Freezers (Standard-size and compact) 7.2%

6.5 SUMMARY OF MARKUPS

Table 6.5.1 summarizes the markups at each stage in the distribution channel and the 

average sales tax.
6-9

Table 6.5.1 Summary of Markups

Markup Baseline Incremental

Manufacturer 1.26

Retailer 1.45 1.17

Sales Tax 1.073
6-10

REFERENCES

 1 Association of Home Appliance Manufacturers. AHAM 2003 Fact Book, 2003. Washington, 

DC. p. 25.

2 Security Exchange Commission, SEC 10-K Reports, Various dates, 1999-2006, Security 

Exchange Commission. <http://www.sec.gov/> 

3 U.S. Census Bureau. 2002 Economic Census, Business Expenses Survey, Retail Trade, 

Household Appliance Stores, 2002. Washington, DC. 

<http://www.census.gov/csd/bes/bes97.htm>

4 Dale, Larry et al., “An Analysis of Price Determination and Markups in the Air-Conditioning 

and Heating Equipment Industry”, LBNL-52791, January 2004. 

5

 Sales Tax Clearinghouse, Inc. State sales tax rates along with combined average city and 

county rates. <http://thestc.com/STrates.stm>

6 U.S. Department of Energy-Energy Information Administration. Residential Energy 

Consumption Survey, 2005Public Use Data Files. Washington, DC. 

<http://www.eia.doe.gov/emeu/recs/recspubuse05/pubuse05.html>
7-i

CHAPTER 7. ENERGY USE ANALYSIS

TABLE OF CONTENTS

7.1 INTRODUCTION ........................................................................................................... 7-1

7.1.1 Overview of Approach Used in the Preliminary Analysis.................................... 7-1

7.1.2 Overview of Approach Used for the NOPR.......................................................... 7-2

7.2 HOUSEHOLD SAMPLES FOR REFRIGERATION PRODUCTS............................... 7-3

7.3 FIELD METERED DATASETS AND UAF FUNCTION DETERMINATION........... 7-6

7.3.1 Field Metered Data Sources.................................................................................. 7-6

7.3.2 Determination of Test Energy Use of Field Units................................................. 7-7

7.3.3 Field-Metered UAF Regressions........................................................................... 7-8

7.3.3.1 Temperature Regressions....................................................................... 7-8

7.3.3.2 Primary Refrigerator-Freezers.............................................................. 7-11

7.3.3.3 Secondary Refrigerator-Freezers.......................................................... 7-14

7.3.3.4 Standard-Sized Freezers....................................................................... 7-15

7.4 ESTIMATING FIELD ENERGY USE FOR NEW STANDARD-SIZE 

PRODUCTS................................................................................................................... 7-16

7.4.2 Usage Adjustment Factors of Standard-Size Products in RECS Households..... 7-18

7.4.2.1 Conversion to Secondary Refrigerators ............................................... 7-18

7.4.2.2 UAF Results by Product Class............................................................. 7-19

7.4.3 Test Energy Consumption of Standard-Size Products in RECS Households..... 7-21

7.4.3.1 Determination of Total Interior Volume or “Size” .............................. 7-22

7.4.3.2 Calculation of Adjusted Volume.......................................................... 7-23

7.4.3.3 Calculation of Test Energy Consumption ............................................ 7-24

7.5 ENERGY USE OF COMPACT REFRIGERATION PRODUCTS.............................. 7-24

7.6 ANNUAL ENERGY CONSUMPTION BY EFFICIENCY LEVEL ........................... 7-25

LIST OF TABLES

Table 7.2.1 Refrigeration Products in Households by Product Class..................................... 7-4

Table 7.3.1 Field Metered Datasets ........................................................................................ 7-7

Table 7.3.2 Temperature Parameters .................................................................................... 7-10

Table 7.3.3 Final UAF Regression Model for Primary Standard-Sized RefrigeratorFreezers.............................................................................................................. 7-14

Table 7.3.4 Final UAF Model for Secondary Standard-Sized Refrigerator-Freezers .......... 7-15

Table 7.3.5 Final UAF Model for Standard-Sized Freezers................................................. 7-16

Table 7.4.1 Efficiency Standard Adjustment Factors (ESAF) for Refrigerator-Freezers 

and Freezers....................................................................................................... 7-17

Table 7.4.2 Comparison of Usage Adjustment Factors in Preliminary and Current 

Analysis.............................................................................................................. 7-19
7-ii

Table 7.4.3 Size Bins for Refrigerators and Freezers........................................................... 7-22

Table 7.4.4 Scaling Ratios of Total Interior Volumes for Standard-Size RefrigeratorFreezers (cu. ft.)................................................................................................. 7-23

Table 7.4.5 Parameters for Calculating Adjusted Volume from Total Interior Volume 

of Refrigerator-Freezers..................................................................................... 7-23

Table 7.4.6 Energy Conservation Standards for Refrigeration Products.............................. 7-24

Table 7.5.1 Parameters for Calculating Adjusted Volume from Total Volume for 

Compact Refrigerators....................................................................................... 7-25

Table 7.6.1 Standard-Size Refrigerator-Freezers: Average Annual Energy Use by 

Efficiency Level................................................................................................. 7-25

Table 7.6.2 Standard-Size Freezers: Average Annual Energy Use by Efficiency Level...... 7-26

LIST OF FIGURES

Figure 7.1.1 Flowchart for Determining Field Energy Consumption ...................................... 7-3

Figure 7.4.1 Product Class 3, Top Mount Refrigerator-Freezers: Distribution of UAF in 

the first year of the Refrigerator......................................................................... 7-20

Figure 7.4.2 Product Class 3, Top Mount Refrigerator-Freezers: Distribution of UAF in 

the 20th year of the Refrigerator......................................................................... 7-20

Figure 7.4.3 Product Class 3, UAF as a Function of Age ...................................................... 7-21

Figure 7.4.4 Product Class 9, Upright Freezers: Distribution of UAF................................... 7-21
7-1

CHAPTER 7. ENERGY USE ANALYSIS

7.1 INTRODUCTION

To perform the life-cycle cost (LCC) and payback period (PBP) calculations described in 

chapter 8, the U.S. Department of Energy (DOE) determines the savings in operating cost that 

consumers would result from more efficient products. DOE uses data on annual energy 

consumption, along with energy prices, to develop the most significant component of consumer 

operating cost. (Maintenance and repair costs are the other components.) This chapter describes 

how DOE determined the annual energy consumption of refrigeration products for the LCC and 

PBP analysis.

The goal of the energy use analysis is to generate a range of energy use values that 

reflects actual product use in American homes. The analysis uses information on use of actual 

products in the field to estimate the energy that would be used by new products at various 

efficiency levels.

The DOE test procedure produces standardized results that can be used to assess or 

compare the performance of products operating under specified conditions. Actual energy usage 

in the field often differs from that estimated by the test procedure because of variation in 

operating conditions, the behavior of users, and other factors. In the case of refrigerator-freezers,

researchers have conducted studies that measure the field consumption and compare it to the 

DOE test results for the measured models. DOE’s review of several such studies, which is 

described in appendix 7-A, confirmed that energy use measured in the field often differs 

considerably from the usage measured by the DOE test procedure.

7.1.1 Overview of Approach Used in the Preliminary Analysis

In its preliminary analysis, DOE treated the field energy consumption reported for 

households in the Energy Information Administration’s 2005 Residential Energy Consumption 

Survey (RECS)1 as the actual consumption of the refrigeration product(s) in that household. 

RECS queries a national sample of households to collect statistical information on household 

consumption of and expenditures for energy, along with data on energy-related characteristics of 

the housing units and households. RECS provides enough information to establish the type of

refrigeration product (the product class) used in each household, and provides an estimate of the 

household energy consumption attributable to refrigerators or freezers. DOE estimated the test 

energy use of the refrigerators or freezers in RECS homes, and then derived a “usage adjustment 

factor’ (UAF) as the ratio of the reported field energy consumption for each sample household to 

the estimated test energy use. DOE developed such UAFs for standard-size units, but not for 

compact units because many of those products are used outside the residential sector, such as in 

college dormitories, hotels and motels, and offices.
7-2

For each considered efficiency level, DOE calculated field-adjusted annual energy 

consumption for each home by multiplying the tested energy consumption of a new refrigeration 

product, measured using the existing test procedures, by the efficiency standard adjustment 

factor (ESAF) and the UAF for that household.

7.1.2 Overview of Approach Used for the NOPR

During the preliminary analysis, stakeholders raised several concerns over the use of the 

field energy consumption reported in RECS to derive UAFs. Therefore, for the NOPR, DOE 

developed a new approach to derive UAFs for the RECS sample households. This approach 

involved collection of field metered electricity use data for residential refrigeration products. 

DOE was able to obtain data from seven studies, including about 100 data points that 

DOE collected itself. A total of 1,967 data points were collected that included units from all 

representative product classes except compact freezers, and spanned a variety of collection years, 

unit ages, U.S. locations and household populations, including some units used in commercial 

settings (e.g., offices and hotels). DOE made various adjustments to the raw data, including 

extrapolation to annual electricity consumption where necessary.

From identifying information about each unit, its test energy consumption was estimated

and the UAF was calculated as the ratio of metered energy use to test energy use. The data were 

pooled into four categories: primary refrigerators, secondary refrigerators, freezers and compact 

refrigerators. Although DOE considered including data for compact refrigerators in the final 

analysis, it decided not to include those data due to concerns over data quality and 

representativeness. 

For each category, DOE performed weighted least-squares regressions on numerous 

variables of potential interest in order to construct a function that predicts the UAF based on 

household and climate variables. DOE selected for final evaluation a small number of variables 

for which the regression results had sufficient statistical significance, and that could be obtained 

or reasonably inferred from RECS variables. Within each of the three product categories

modeled, DOE used the appropriate set of regression coefficients, along with values for the 

relevant variables specific to each household, to generate UAF estimates for each RECS 

household. For compact refrigeration products, a UAF of 1 was used.

Using the UAF derived for each RECS household, DOE determined the field energy 

consumption in each household of a new refrigeration product at each considered efficiency level 

using the following equation:

FECEL = FECRECS • (1 – R) = UAFRECS • TECRECS • (1 – R) Eq. 7.1

where:
7-3

FECEL = new refrigeration product’s field energy consumption at a given efficiency level;

FECRECS = new refrigeration product’s field energy consumption at baseline efficiency level;

R = reduction in energy consumption (expressed as fraction) due to efficiency 

improvements;

UAFRECS = usage adjustment factor specific to RECS household;

TECRECS = maximum allowable test energy consumption for the new baseline refrigeration 

product.

Figure 7.1.1 illustrates the data analysis process flow graphically. The items in rectangles 

represent data sets, while the items in circles represent major calculation procedures.

Figure 7.1.1 Flowchart for Determining Field Energy Consumption

7.2 HOUSEHOLD SAMPLES FOR REFRIGERATION PRODUCTS

DOE developed household samples for refrigeration products from the 2005 RECS. The 

survey, which sampled 4,382 housing units, was constructed to represent the household 

population throughout the United States. 

RECS results indicate whether a household uses a standard-size refrigerator or freezer. 

For households that have a standard-size refrigerator, RECS specifies whether the freezer is topor bottom-mounted, or is side-mounted. Units in the sample that have top-mounted freezers 
7-4

(product class 3) cannot be distinguished from those having bottom-mounted freezers (product 

class 5). Therefore, DOE used the same household sample for product classes 3 and 5. For a 

household’s primary (or “first”) refrigerator, RECS specifies whether there is through-the-door 

(TTD) ice service. For households that have standard-size freezers, RECS specifies whether the 

unit is upright or a chest-type. With the above data, DOE was able to assign each product class 

considered for potential new efficiency standards to a set of household records (Table 7.2.1). For 

each of the representative built-in product classes, DOE used the sample that corresponds most 

closely to the type of built-in product (e.g., for product class 3A-BI, DOE used the sample for 

product class 3).

Table 7.2.1 Refrigeration Products in Households by Product Class

Product Class Number of 

Household 

Records*

Percent of Total 

Household 

Records*

Relative Standard 

Error Due to 

Sampling*

3. Refrigerator-freezer: 

automatic defrost with topmounted freezer and no TTD†

ice service 2,303 52.6% 2.1% 5. Refrigerator-freezer: 

automatic defrost with 

bottom-mounted freezer and 

no TTD ice service

7. Refrigerator-freezer: 

automatic defrost with sidemounted freezer and TTD ice 

service 

1,026 23.4% 3.1%

9. Upright freezer with 

automatic defrost 248 5.7% 6.4%

10. Chest freezer and all other 

freezers except compact 

models

369 8.4% 5.2%

* From the Energy Information Administration’s 2005 Residential Energy Consumption Survey (RECS).

† Through-the-door.

The relative standard errors associated with the subsamples that contain specific product 

classes are not considered so large as to affect the validity of the derived results presented in this 

chapter. Specifically, the relative standard error of a sample of size N, expressed as a percentage, 

is approximated closely as 100 divided by the square root of (N-1). For the full 2005 RECS 

sample, the associated relative standard error due to sampling is 1.5 percent. For the subsamples 

containing product classes 9 and 10, the associated relative standard errors are 6.4 percent and 

5.2 percent, respectively. Although the standard error for the smallest subsample is more than 

four times the error for the entire 2005 RECS, it still is less than 10 percent, a relative standard 

error considered small enough to yield meaningful results. Therefore, DOE believes the results 

generated from the household samples for refrigeration products are representative of U.S. 

households using those appliances.
7-5

For the NOPR analysis, DOE made adjustments to the statistical weightings of RECS 

samples for product classes 3 and 5 based on relationships between income and product class 

ownership provided by AHAM.a Therefore, even though the same RECS households are used to 

represent both product classes 3 and 5, the statistical contribution of these households to the 

economic analyses differed. Table 7.2.2 provides the resulting shares by income group. 

Table 7.2.2 RECS Shares of Top-Mount and Bottom-Mount Refrigerator-Freezers

Values Used in NOPR Analysis

Annual Income Values Used in 

Preliminary Analysis for 

Top- and Bottom-Mount

Refrigerator-Freezers

Top-Mount 

RefrigeratorFreezers

(Product Class 3)

Bottom-Mount 

RefrigeratorFreezers

(Product Class 5)

<$25,000 36.9% 40.1% 25.1%

$25,000-$49,000 29.4% 31.1% 30.0%

$50,000-$99,999 24.2% 21.5% 28.7%

$100,000-$119,999 3.9% 3.1% 6.6%

$120,000+ 5.6% 4.2%* 9.6%*

Sum 100.0% 100.0% 100.0%

* Because AHAM data only provided ownership fractions in two bins ($100,000-$149,999 and $150,000+), 

ownership for the $120,000+ income level was calculated by weighting data from these above two bins by data from 

the American Housing Survey (2005) indicating the fraction of households in each bin (62% between $100,000-

$149,999, and 38% at $150,000 or above).

For built-in products (product classes 3A-BI, 5-BI, 7-BI and 9-BI), DOE used a single 

relationship between income and built-in ownership provided by AHAM to weight the RECS 

ownership of each built-in product class, shown in Table 7.2.3.

Table 7.2.3 Ownership Fraction of Built-In Refrigeration Equipment

Annual Income Ownership Fraction of 

Built-ins

<$25,000 2%

$25,000-$49,000 2%

$50,000-$99,999 2%

$100,000-$119,999 3%

$120,000+ 6%*

* Because AHAM data only provided ownership fractions in two bins ($100,000-$149,999 and $150,000+), 

ownership for the $120,000+ income level was calculated by weighting data from these above two bins by data from 

the American Housing Survey (2005) indicating the fraction of households in each bin (62% between $100,000-

$149,999, and 38% at $150,000 or above).

 

a Association of Home Appliance Manufacturers (AHAM), “Product Saturation by Income,” personal 

communication, April 1, 2010.
7-6

7.3 FIELD METERED DATASETS AND UAF FUNCTION DETERMINATION

DOE used field-metered energy use data, combined with estimates of the test energy use 

of each field-metered unit, to calculate the UAF for each data point from the following formula:

UAFi = FECi / TECi Eq. 7.2

Where:

UAFi = usage adjustment factor specific to the field-metered data point;

FECi = field-metered annualized electricity use;

TECi = test energy consumption annual electricity use.

DOE divided the data into four categories: standard-sized primary refrigerator-freezers, 

standard-sized secondary refrigerator-freezers, standard-sized freezers, and compact 

refrigerators. For each category, DOE performed weighted least-squares regressions on 

numerous variables of potential interest in order to construct a function that predicts the UAF 

based on household and climate variables. DOE selected for final evaluation a small number of 

variables for which the regression results had sufficient statistical significance and that could be 

obtained or reasonably inferred from RECS variables.

7.3.1 Field Metered Data Sources

DOE obtained metered electricity use data on refrigeration products from seven datasets,

shown in Table 7.3.1 below, including more than 100 data points which DOE collected itself. A 

total of 1,967 data points were collected that included units from all representative product 

classes except compact freezers, and spanned a variety of collection years, unit ages, U.S. 

locations and household populations, including some units used in commercial settings (e.g., 

offices and hotels).
7-7

Table 7.3.1 Field Metered Datasets 

In addition to metered electricity use, the data sets included some identifying information 

about each unit (such as brand, model number, year manufactured, door style, presence/absence 

of through-the-door ice service, and interior volume), as well as some household characteristics 

and geographic location. DOE omitted about 16% of the data points due to missing information 

and/or data quality issues. For compact refrigerators, all 96 data points were analyzed but DOE 

decided not to use the resulting fits in the final analysis due to a concern that the data were not 

sufficiently representative.

7.3.2 Determination of Test Energy Use of Field Units

The test (i.e., rated) energy use for each unit in the analysis was determined by a twotiered process. 

Number of data points

Study Popula

-tion State Period metered

Average 

duration

Average 

unit age

(years)

Standard-sized 

refrigeratorfreezers

Standardsized 

freezers

Compact 

refrigeratorsTotal

Primary 

units

Secondary units

Proctor 

Engineering 

Group

New 

rebated 

units

CA 1992-

1993 8 mos. 0.5 129 0 0 0 129

Comelec General MA 1995-

1996 2.2 hrs. 9.2 802 93 52 0 947

Dalhoff & 

Associates

Lowincome IA 1998-

1999 10 days 5.3 44 2 10 0 56

Energy 

Center of 

Wisconsin

Singlefamily 

homes

WI 1999 2.4 hrs. 7.4 204 17 123 0 344

Energy 

Center of 

Wisconsin

Renters WI 2003 2.0 hrs. 7.9 186 0 0 0 186

NSTAR General MA 

+ RI

2003-

2004 21 days 14.4 141 41 0 0 182

LBNL Offices/ 

hotels CA 2009-2010 8 days 6.5 27 0 0 96 123

Total 1,533 153 185 96 1,967

Total used 

for analysis 1,358 109 185 0 1,652
7-8

First, DOE looked up the recorded model number of each study unit in several published 

databases of test results. Data sources included the California Energy Commission, the Federal 

Trade Commission, the Environmental Protection Agency, and a compilation database hosted by 

Home Energy Magazine. Given the possibilities of typographical errors in the recorded model 

numbers and the use of wildcard values by manufacturers within model numbers, a fuzzy string 

matching algorithm was employed to identify the closest matches to each reported model 

number. These matches were then checked based on product class, volume, and year of 

manufacture in addition to manual inspection. This process resulted in confirmed matches for 

63% of all units: 1,235 of the total 1,967. The overall matching rate was 70% for the analysis 

sample (since some units were omitted) and 76% for the primary refrigerators. 

For units that could not be matched based on the recorded model number, the Federal 

efficiency standard for the year of manufacture was used as the estimate, calculated based on 

product class, adjusted volume and year of manufacture. For units manufactured prior to the 

1990 standards, the 1990 standards values were multiplied by year-specific efficiency factors 

from AHAM. Since the efficiency standard is a maximum value for energy use, it may overestimate the actual rated use of the units. The extent of the over-estimation was assessed by 

comparing reported values for matched units to the standards. This analysis found that the 

average unit built in 1990 or later was rated to use 6.1% less than the Federal standard. For units 

built prior to 1990 that included a vintage multiplier, the actual rated use averaged just 0.7% less 

than this estimate. However, in neither case were the rated energy use results scaled or altered.

7.3.3 Field-Metered UAF Regressions

7.3.3.1 Temperature Regressions

Because of the primary role that temperature plays in refrigerator/freezer electricity use 

(from thermodynamics, about 2.5% to 3.0% per °F temperature difference between inside and 

outside the unit), it was desirable to obtain correlations of energy use with ambient (indoor) 

temperature. However, such data were only available for a limited number of data points. By 

contrast, heating and cooling degree-days were readily available for all data from a historic U.S.

weather database, and is already included in RECS data. Previous work including the NSTAR 

study listed in the table, has found a consistent relationship between indoor and outdoor 

temperatures that varies with whether space conditioning is needed and used. In addition, the 

Proctor Engineering study found a similar relationship between refrigerator energy use and 

outdoor temperature. At outdoor temperatures below approximately 60°F, average indoor 

temperature decreases by about 0.02 to 0.05°F per outdoor °F, whereas above 70°F, average 

indoor temperature increases by about 0.1 to 0.4°F per outdoor °F depending on the use of air 

conditioning. In the range of about 60°F to 70°F, indoor temperature tends to more closely 

follow outdoor temperature variations as space conditioning is often not used and windows may 

be open. 
7-9

Given these relationships between weather, indoor temperature, and refrigerator energy 

use, DOE decided to model refrigerator energy use using three climate variables: heating degree 

days base 59°F (HDD59), average outdoor temperature (minus 65°F to approximately center the 

values), and cooling degree days base 70°F (CDD70). However, RECS provided only heating 

and cooling degree days calculated with base of 65°F (HDD65 and CDD65, respectively), which 

unfortunately falls right in the middle of the sensitive portion of the indoor-outdoor temperature 

relationship. Therefore, DOE developed a model to convert HDD65 and CDD65 values into 

estimates of HDD59 and CDD70. The average outdoor temperature was also easily obtained 

from the difference between HDD65 and CDD65.

The estimation of CDD70 and HDD59 from CDD65 and HDD65 was based on 

calculating each of these four values for each of the 1,020 weather stations included in the 

Typical Meteorological Year (TMY) 3 weather datasets produced by the National Renewable 

Energy Laboratory. Regression models of HDD59 and CDD70 were developed that included 

HDD65, CDD65 and the square roots of each of these values. The resulting regression models 

provided an excellent fit to the data with R-squared values of 0.9957 for CDD70 and 0.9995 for 

HDD59. These equations were then used with the RECS data on HDD65 and CDD65 to model 

the weather impacts of the units. Note that heating and cooling degree days (per year) were 

converted to heating or cooling degrees (denoted by HD or CD, respectively) by dividing the 

quantity by the average number of days in a year. Table 7.3.2 shows the temperature parameters.
7-10

Table 7.3.2 Temperature Parameters

Symbol Coefficient Standard deviation

(1σ)

HD59 (°F)

parameters

T-value

Constant aH -2.30145 0.057953 -39.7

HD65 (°F) bH 1.1933 0.003702 302.3

CD65 (°F) cH -0.21377 0.008593 -24.9

HD65(°F) dH -1.32905 0.028216 -47.1

CD65(°F) eH 1.500784 0.027742 54.1

CD70 (°F)

parameters

Constant aC -1.714641 0.0502549 -34.1

HD65 (°F) bC -0.0977721 0.0032106 -30.5

CD65 (°F) cC 1.038835 0.0074511 139.4

HD65(°F) dC 0.8797741 0.0244682 36.0

CD65(°F) eC -1.008089 0.0240571 -41.9

Average outside 

temperature (Tout) 

minus 65°F 

parameters

Constant aT 0 Not applicable

HD65 (°F) bT -1 Not applicable

CD65 (°F) cT 1 Not applicable

Formulas:

HD65 (°F) = HDD65 (°F days) / 365.25 days Eq. 7.3

CD65 (°F) = CDD65 (°F days) / 365.25 days Eq. 7.4

HD59 (°F) = aH + bH • HD65 (°F) + cH • CD65 (°F)

+ dH • HD65(°F) + eH • CD65(°F) Eq. 7.5

CD70 (°F) = aC + bC • HD65 (°F) + cC • CD65 (°F)

+ dC • HD65(°F) + eC • CD65(°F) Eq. 7.6

Tout – 65 (°F) = aT + bT • HD65 (°F) + cT • CD65 (°F)

= CD65 (°F) – HD65 (°F) Eq. 7.7
7-11

7.3.3.2 Primary Refrigerator-Freezers

For standard-sized primary refrigerator-freezers, which contained the largest number of 

sample points, the following primary predictor variables were used in the final model: unit age, 

heating and cooling degree days, outdoor temperature, presence/absence of a TTD icemaker, and 

number of household occupants. All variables except the last one were obtained from the full set 

of primary refrigerator-freezer data. 

In addition to these predictor variables, the model included control variables to capture 

other factors related to metered refrigerator energy use including a dummy variable to indicate 

units manufactured prior to 1993, a dummy variable to indicate units metered for less than a day 

(typically 2-3 hours), and a dummy variable to indicate a low-income household (identified in 

just two of the studies). The analysis found that each of these factors was associated with a 

difference in UAF. 

Units built prior to 1993 tended to have a lower UAF than those built later by about 15%. 

Units that were only metered for a few hours tended to use about 10% more energy 

relative to their rating than those metered for longer periods. This finding is believed to reflect a 

bias from short-term metering since all such metering occurs during the daytime and when 

occupants are home. 

Units in low income households (all units in the Dalhoff Iowa study and some units in the 

ECW single family Wisconsin study) use on average about 17% more relative to their rating than 

those not identified as low income. It was concluded that the bias must reflect the prevalence in 

low-income households of units that are bought used, and tend to run less efficiently than 

similarly-aged models that were bought new. However, there may have also been a bias in the 

sample of households metered, because the purpose of the metering program was to identify 

households with high energy-consumption units in order to qualify them for free replacement. 

DOE decided not to include this effect as a predictive variable for new units, because it was felt 

that any “low income” effect in the general population is likely to be much lower than that 

observed in a sample of high energy use units among low income residents.

DOE explored a number of regression modeling approaches. For the approach finally 

selected, data were weighted based on the duration of metering, with the weight defined as the 

square root of the number of metered hours. This weighting reflects the greater variability 

inherent in short-term data, separate from the bias previously discussed. 

The impact of unit age on energy use was explored using several approaches. The data 

generally supported the hypothesis that a decrease in performance (e.g., increase in energy use) 

manifested quickly approximately over the first year, and over subsequent years a steady but 

slower decrease occurred. This type of degradation should be expected due to the degradation in 

effective R-value of the foam insulation. One dataset (Proctor Engineering Group) provided a 

little less than a year of continuous data on 129 newer refrigerators. A regression analysis of that 

data found a first year annual degradation rate of 8.9% (±2.4% at 1σ confidence interval). But 
7-12

the result varied under differing model specifications. Some long-term data on a smaller sample 

of refrigerators provided by BC Hydro (not included in Table 7.3.1) revealed an annual 

degradation rate of about 1% per year for older existing units. But the largest sample size and 

most consistent estimate of degradation came from including an age variable into the larger 

cross-sectional regression model. The model estimated an annual degradation rate of 1.60% 

(±0.20%). This figure is fairly close to the 1.37% estimated by Pratt and Miller (“The New York 

Power Authority’s Energy-Efficient Refrigerator Program for the New York City Housing 

Authority—1997 Savings Evaluation”, PNNL-11990, 1998). Attempts to fit differing 

degradation rates at differing ages were not successful, most likely due to a lack of metered data 

from refrigerators between 1 and 5 years old. 

About half of the primary refrigerator data contained information about the number of 

household occupants. DOE performed a regression on this subset to obtain a relationship 

between UAF and number of occupants. DOE tested a regression model where each occupant 

received its own separate coefficient, and found that the correlation with UAF was linear for 1-3 

occupants. Above 3 occupants, the correlation was very weak and inconsistent depending on 

other variable choices, so that variable was dropped. The final model consisted of a single 

coefficient times the number of occupants up to 3. Results are shown below in Table 7.3.3.

The presence of through-the-door (TTD) icemaking was found to be statistically 

significant. While a percentage energy use model was considered, DOE found that slightly better 

model agreement resulted when TTD icemaking was fitted in absolute (energy) terms, so this 

variable was treated somewhat differently from the other variables

The TTD variable is strongly correlated with the side-by-side door variable (denoting 

product class 7), but separate correlations with door style (side-by-side or otherwise) are 

extremely weak, and were therefore not included in the final model. The large magnitude of the 

TTD coefficient (about twice the placeholder energy consumption value of 84 kWh/yr associated 

with the proposed new test procedure) is indicative of older units; but represents approximately 

12% of non-TTD icemaking energy consumption as measured by UECtest, consistent with 

previous estimates of the size of this term.

2

The UAF function was calculated in two stages, using the set of best-fit coefficients 

shown in Table 7.3.3. The first stage was based entirely on deterministic variables derived from 

RECS:

UAFint (%) = aP + bP • AGE + cP • HD59 + dP • CD70 + eP • (Tout – 65°F)

+ fP • OCCUP3 + (gP / TECRECS) • TTD Eq. 7.8

Where:

UAFint = intermediate UAF function for primary refrigerators;

AGE = age of refrigerator in years;

HD59 = as defined above;
7-13

CD70 = as defined above;

Tout = as defined above;

OCCUP3 = number of occupants up to and including three;

TTD = presence of through-the-door icemaking (=1);

TECRECS = test energy consumption of unit (kWh).

The UAFint function did not capture all the observed variability in the metered data. In 

order to represent this additional variability, a Weibull function was fitted to the residual 

distribution of ratios of predicted to observed UAF values. DOE used this function as a 

probability distribution to sample from, and multiplied the resulting scaling factor by the above 

UAF function: 

UAFP (%) = UAFint • rP Eq. 7.9

Where:

UAFP = UAF of primary refrigerators;

rP = random draw from residual Weibull distribution (with standard parameters).
7-14

Table 7.3.3 Final UAF Regression Model for Primary Standard-Sized RefrigeratorFreezers

Symbol Coefficient Standard 

deviation (1σ)

Parameters

T-value

Constant aP 72.9% 4.33% 16.83

Unit age (years) bP 1.60% 0.20% 8.16

Heating degrees base 59°F 

(HD59)

cP 1.89% 0.54% 3.47

Cooling degrees base 70°F 

(CD70)

dP -0.81% 0.89% -0.91

Average outside temperature 

(Tout) minus 65°F

eP 2.00% 0.46% 4.37

Number of occupants ≤ 3 fP 12.09% 2.48% 4.87

Through-the-door (TTD) 

icemaking (= 1)

gP* 170.5 kWh 43.5 kWh 3.92

Residual rP See below

Dummy parameters (not used 

in RECS UAF calculations)

Unit built before 1993 (= 1) hP -12.51% 4.05% -3.09

Low income (= 1) iP 16.64% 6.35% 2.62

Short-term (≤ 1 day) metering

(= 1)

jP 10.25% 2.36% 4.34

Residual Weibull parameters

Scale αP 1.0234 Not available

Shape βP 4.0343 Not available

* Note that for new refrigerators, rather than this icemaking energy coefficient, the placeholder 

energy consumption value of 84 kWh/yr was used.

7.3.3.3 Secondary Refrigerator-Freezers

For secondary refrigerator-freezers, the number of statistically significant variables was 

much smaller, and there was no correlation with number of household occupants. The location of 

the unit in the home, which is frequently in a room other than the kitchen and often experiences a 

different mean annual temperature, was found to be statistically important. After exploring a 

number of alternate models, DOE chose a model based on the presence of a basement and/or 

heated space. If a basement exists in the home, the secondary unit was assumed to reside there, 

with RECS data providing information on whether the basement is heated or not. If no basement 

exists, a probability of being located in a heated space was used, based on a statistical 

distribution derived from the metered data. 
7-15

The UAF function was calculated from the set of best-fit coefficients shown in Table

7.3.4, and multiplied by a residual scaling factor as for primary refrigerator-freezers:

UAFS (%) = [aS + bS • (Tout – 65°F) + cS • (Tout – 65°F) • BASEMENT

+ dS • HEATED] • rS Eq. 7.10

Where:

UAFS = UAF of secondary refrigerator;

Tout = as defined above;

BASEMENT = existence of a basement (=1);

HEATED = heated space, defined as follows: if BASEMENT = 1, defined as 1 if basement is 

heated, 0 if unheated. If BASEMENT = 0, probability of 1 is 75% (random draw);

rS = random draw from residual Weibull distribution (with standard parameters).

Table 7.3.4 Final UAF Model for Secondary Standard-Sized Refrigerator-Freezers

Symbol Coefficient Standard deviation

(1σ)

Parameters

T-value

Constant aS 100.5% 7.5% 13.5

Average outside 

temperature minus 65°F

bS 0.76% 0.36% 2.13

Average outside 

temperature minus 65°F 

times Basement (= 1)

cS -0.32% 0.39% -0.82

Heated space (= 1)* dS 21.5% 9.4% 2.29

Residual rS See below

Residual Weibull 

parameters

Scale αS 0.9809 Not available

Shape βS 2.6767 Not available

*See equation 7.10.

7.3.3.4 Standard-Sized Freezers

For standard-sized freezers, DOE found very few variables with statistical significance, 

and only a single heated space variable was used in the final model. The heated space variable 

was treated similarly to that for secondary refrigerator-freezers, but with a different probability 

for being in a heated space if not in a basement (again based on the metered data). 

The UAF function was calculated from the set of best-fit coefficients shown in Table

7.3.5, and multiplied by a residual scaling factor as for primary refrigerator-freezers:
7-16

UAFF (%) = (aF + bF • HEATED) • rF Eq. 7.11

Where:

UAFF = UAF of freezer;

HEATED = heated space, defined as follows: if basement exists (= 1), defined as 1 if 

basement is heated, 0 if unheated. If basement is not present, probability of 1 is 

46% (random draw);

rF = random draw from residual Weibull distribution (with standard parameters).

Table 7.3.5 Final UAF Model for Standard-Sized Freezers

Symbol Coefficient Standard deviation

(1σ)

Parameters

T-value

Constant aF 80.2% 3.8% 21.1

Heated space (= 1)* bF 14.3% 7.7% 1.86

Residual rF See below

Residual Weibull 

parameters

Scale αF 1.0787 Not available

Shape βF 2.5535 Not available

*See equation 7.11.

7.4 ESTIMATING FIELD ENERGY USE FOR NEW STANDARD-SIZE

PRODUCTS

To determine the field energy consumption in each RECS household of a new 

refrigeration product at each considered efficiency level, DOE used the following equation:

FECEL = FECRECS • (1 – R) = UAFRECS • TECRECS • (1 – R) Eq. 7.12

where:

FECEL = new refrigeration product’s field energy consumption at a given efficiency level;

FECRECS = new refrigeration product’s field energy consumption at baseline efficiency level;

R = reduction in energy consumption (expressed as fraction) due to efficiency 

improvements;

UAFRECS = usage adjustment factor specific to RECS household;

TECRECS = maximum allowable test energy consumption for the new baseline refrigeration 

product.
7-17

Note that, for standard-size refrigerator-freezers, UAFRECS, and hence FECRECS and FECEL, are 

functions of time. 

DOE conducted its analysis with an awareness of proposed revisions to the DOE test 

procedure for refrigerator-freezers, which will stipulate lower temperatures for the fresh food 

compartment and the freezer than those the currently prescribed. DOE has not identified how the 

tested energy consumption under the new procedure will compare to that determined under the 

current procedure, but expects this adjustment to take the form of a multiplicative factor termed 

the “efficiency standard adjustment factor,” or ESAF. The ESAF is expected to be multiplicative, 

because the energy use for a refrigeration unit is close to proportional to the difference between 

its interior and exterior temperatures. For the current analysis, DOE assumed that this factor is 

constant for each product class, and does not vary with product efficiency or adjusted volume, 

with the exception of product class 5. For product class 5, the ESAF is a function of adjusted 

volume. See chapter 5 for a complete discussion of the derivation of these values. To be general, 

therefore, the ESAF is referred to by ESAF(AV) in subsequent equations.

Table 7.4.1 provides the value of the ESAF for refrigerator-freezers and freezers.

Table 7.4.1 Efficiency Standard Adjustment Factors (ESAF) for RefrigeratorFreezers and Freezers

Product 

Class

ESAF

3 1.124

5 1.125*

7 1.140

9 1.000

10 1.000

* At average adjusted volume (24.68 cu. ft.) for this product class.

Fundamentally, the value of the ESAF does not affect estimates of field energy use, 

because changes in the test procedure do not affect consumer behavior or operation of an 

appliance within a household. Field energy consumption of future appliances built to meet a 

national standard, however, may be affected by the test procedure used to define the standard. 

For this reason, DOE assumed that the effects of consumer behavior and operating conditions, 

characterized by the UAF, are separate from the effects of the test procedure, characterized by 

the ESAF. However, in order to convert to the new test energy consumption while keeping the 

derived field energy consumption FECRECS the same, an adjustment needed to be made to 

equation 7.12:

FECEL = UAFNEW–RECS • TECNEW–RECS • (1 – R) Eq. 7.13

Where:
7-18

UAFNEW −RECS = UAFRECS

ESAF(AV) Eq. 7.14

TECNEW–RECS = ESAF(AV) • TECRECS Eq. 7.15

DOE assumed that the UAF for a given household would be the same for products that 

meet some future energy efficiency standard as it is for their current appliance. In conducting the 

life-cycle cost analysis (chapter 8), DOE substituted the refrigeration product recorded in RECS 

with a new product of identical product class and size that the household is assumed to purchase 

in the year when the new standard goes into effect. 

If R is the reduction (expressed as a percent) in energy use by the new standard from the 

current standard (e.g., a 10-percent efficiency improvement would mean R = 0.1), then assuming 

the ESAF is a multiplicative factor, as DOE did for this analysis, the field energy consumption 

scales simply with (1 – R), regardless of the value of ESAF(AV). A multiplicative ESAF 

therefore is not needed to calculate energy savings related to a higher efficiency standard.

7.4.2 Usage Adjustment Factors of Standard-Size Products in RECS Households

To determine UAFNEW–RECS for each RECS household, DOE used the appropriate set of 

regression coefficients (primary refrigerator-freezer, secondary refrigerator-freezer, or freezer), 

along with values for the necessary variables for the specific household, to generate a UAF 

estimate for each type of refrigeration product, using equations 7.8 to 7.11 (UAF definitions) and

7.14 (ESAF correction).

7.4.2.1 Conversion to Secondary Refrigerators

When a household purchases a new refrigerator, some first units become second units. 

(See chapter 8 for a discussion of how DOE modeled the conversion of refrigerators from first to 

second units.) A second refrigerator, generally located in a basement or garage, enters a new 

operating environment and may be used less than year-round. For those units that become a 

second refrigerator, therefore, the annual energy consumption changes, presumably remaining at 

the new level for the rest of its lifetime. 

The UAF over a refrigerator’s lifetime can be expressed as the sum of two components:

( )

,

( ),

( ) ESAF AV

UAF y y

UAF y y y

UAF y

S conv

P conv







≥

<

= Eq. 7.16

Where:
7-19

UAF(y) = overall usage adjustment factor (year-dependent);

UAFP(y) = usage adjustment factor for primary refrigerator phase (year-dependent);

UAFS = usage adjustment factor for secondary refrigerator phaseb

yconv = year of conversion from primary to secondary refrigerator;

(year-independent);

ESAF(AV) = ESAF correction factor.

7.4.2.2 UAF Results by Product Class

Table 7.4.2 shows average overall UAFs, as well as UAFs in year 1 and year 20, by 

product class for the current analysis. For comparison, it also shows average UAFs by product 

class used in the preliminary analysis. Note UAFs have been divided by ESAF(AV) to reflect the 

new test procedure.

Table 7.4.2 Comparison of Usage Adjustment Factors in Preliminary and Current 

Analysis

Product Class

Sample 

Size

Current Analysis

Preliminary 

Analysis

Mean UAF Mean UAF

Top-mount refrigerator-freezer

(PC 3) 2,303 0.93 (0.82 to 1.04)* 1.23

Bottom-mount refrigeratorfreezer (PC 5) 2,303 0.92 (0.81 to 1.02)* 1.09

Side-by-side refrigeratorfreezer with TTD (PC 7) 1,026 0.94 (0.84 to 1.03)* 1.44

Upright freezer (PC 9) 248 0.85 1.37

Chest freezer (PC 10) 369 0.89 1.48

Top-mount built-in refrigeratorfreezer (PC 3A-BI) 2,303 0.94 (0.83 to 1.07)* N/A

Bottom-mount built-in 

refrigerator- freezer (PC 5-BI) 2,303 0.96 (0.85 to 1.07)* N/A

Side-by-side built-in 

refrigerator-freezer (PC 7-BI) 1,026 0.94 (0.84 to 1.03)* N/A

Upright built-in freezer (PC 9-

BI) 248 0.85 N/A

* Averages are based on lifetime distribution and include conversion to 2nd refrigerators. Range indicates average 

UAF in year 1 (minimum) and year 20 (maximum).

 

b This UAF accounts for the changed operating environment during the second phase.
7-20

Figures 7.4.1 and 7.4.2 show the distribution of UAFs for the RECS households in the 

subsample for product class 3 (top-mount refrigerator-freezers) in year 1 and year 20, 

respectively. Each figure shows the distribution of UAFs used for the LCC analysis. For other 

standard-size product classes, the UAF distributions appear very similar. Figure 7.4.3 shows the 

average UAF by year for product class 3. Figure 7.4.4 shows the distribution of UAFs for the 

RECS households in the subsample for product class 9 (upright freezers), which is the same for 

all years. The UAF distribution for product class 10 (chest freezers) is almost identical.

Figure 7.4.1 Product Class 3, Top Mount Refrigerator-Freezers: Distribution of UAF 

in the first year of the Refrigerator

Figure 7.4.2 Product Class 3, Top Mount Refrigerator-Freezers: Distribution of UAF 

in the 20th year of the Refrigerator
7-21

Figure 7.4.3 Product Class 3, UAF as a Function of Age

Figure 7.4.4 Product Class 9, Upright Freezers: Distribution of UAF 

7.4.3 Test Energy Consumption of Standard-Size Products in RECS Households

It was necessary to develop a unique TECRECS value for each RECS household because 

DOE assumed that the new refrigeration product has the same characteristics as the existing-in2005 product with respect to total interior volume (also referred to as “size”), door style, and 

presence of TTD ice service. The latter two items determine the product class and hence the 

formula to calculate test energy consumption. The size is a variable in the formula.

0.60

0.65

0.70

0.75

0.80

0.85

0.90

0.95

1.00

1.05

1.10

0 5 10 15 20 25 30 35

Mean UAF

Age
7-22

7.4.3.1 Determination of Total Interior Volume or “Size”

The possible answers to the RECS question regarding the size of the first refrigerator or 

freezer are shown in Table 7.4.3. The distribution of actual sizes is not uniform within the RECS 

size bins. To estimate the actual size of each unit, DOE estimated the distribution of sizes within 

each bin. To approximate that distribution, DOE used data on refrigerator models from the 2009 

California Energy Commission (CEC) appliance model database. The figures in appendix 7-B

show the number of models by size within each RECS size bin for each considered product 

classes. The size assigned to a sample refrigerator within a RECS size bin was assigned 

randomly using probabilities derived from the CEC data.

Table 7.4.3 Size Bins for Refrigerators and Freezers

Bin* Total Interior Volume (Size) of First Refrigerator 

cu ft†

1 Very small (10 or fewer)

2 Small (11 to 14)

3 Medium (15 to 18)

4 Large (19 to 22)

5 Very large (more than 22)

* Bins defined in Residential Energy Consumption Survey, 2005.

† Cubic feet.

DOE noted significant differences in the average total interior volume of product classes 

5 and 7 as obtained from the above approach, relative to consumer data provided by CEC and 

other sources.

c,d Therefore, DOE scaled the resulting average total interior volumes for these 

product classes by the ratios shown in Table 7.4.4.

 

c The NPD Group, Inc., The NPD Group/NPD Houseworld – POS, Refrigerators, January 2007 – December 2008. 

Port Washington, NY.

d Association of Home Appliance Manufacturers (AHAM), “Additional data request from DOE/LBNL,” personal 

communication with DOE, May 14, 2010.
7-23

Table 7.4.4 Scaling Ratios of Total Interior Volumes for Standard-Size RefrigeratorFreezers (cu. ft.)

Product 

class

Data source:

Preliminary 

analysis 

(RECS and 

CEC) CEC NPD AHAM

Correction 

factor for 

RECS/CEC 

(using NPD 

data)

Full data 

range:

2005 

(RECS), 

1998-2009 

(CEC)

1998-

2009

2007-

2008

2005-

2008

Range used for 

average: 1998-2009

2007-

2009

2007-

2008

2007-

2008

5 17.96 20.75 20.87 21.59 1.16

7 21.07 24.58 24.76 n/a 1.18

7.4.3.2 Calculation of Adjusted Volume

For a refrigerator-freezer, the adjusted volume is defined as the interior volume of the 

fresh food compartment plus 1.63 times the interior volume of the freezer compartment.3 Using 

the CEC database, DOE used the following linear regression to calculate the adjusted volume 

(Voladj) from the total interior volume (Voltot, defined as the sum of fresh food and freezer 

interior volumes):

Voladj = Voltot • Slope + Intercept Eq. 7.17

Table 7.4.5 Parameters for Calculating Adjusted Volume from Total Interior Volume of 

Refrigerator-Freezers 

Product Class Slope Intercept R2 † Count

3. Refrigerator-freezers: automatic defrost 

with top-mounted freezer and no TTD* ice 

service 

1.2205 -1.1049 0.9691 1,803

5. Refrigerator-freezers: automatic defrost 

with bottom-mounted freezer and no TTD 

ice service

1.1851 0.0159 0.9929 778

7. Refrigerator-freezers: automatic defrost 

with side-mounted freezer and TTD ice 

service 

1.3170 -1.9992 0.9906 1,866

*Through-the-door.

† R2 is the coefficient of determination, a measure of how well the model fits the data.
7-24

7.4.3.3 Calculation of Test Energy Consumption

The RECS door style and TTD ice service variables together determine the product class, 

aside from distinguishing top- from bottom-mount refrigerator-freezers. Table 7.4.6 lists the 

current energy efficiency standards. The formula that expresses the standard is for maximum 

allowable kWh per year as a linear function of adjusted volume (AV).4, 5

 

Table 7.4.6 Energy Conservation Standards for Refrigeration Products

Product Class 2001 Standard

3. Top-mount refrigerator-freezers 

without TTD* ice service 9.80AV+276.0

5. Bottom-mount refrigerator-freezers 

without TTD ice service 4.6AV+459.0

7. Side-by-side refrigerator-freezers 

with TTD ice service 10.10AV+406.0

9. Upright freezers with automatic 

defrost 12.43AV+326.1

10. Chest freezers 9.88AV+143.7

*Through-the-door.

7.5 ENERGY USE OF COMPACT REFRIGERATION PRODUCTS

As mentioned in the introduction to this chapter, compact refrigerators and freezers are 

used in homes, college dormitories, hotels and motels, and some commercial buildings. While 

DOE was able to collect about 100 sample points from compact refrigerators used in hotel 

rooms, concerns over data quality and representativeness prevented DOE from using the data to 

help determine field energy use. It therefore assumed that the average field energy use of 

compact refrigerators (and freezers) of a given size is the same as the maximum energy use 

allowed by the DOE standard, as measured in the DOE test procedure. In effect, DOE assumed 

that variation in field energy use of compact products is a function solely of volume. To 

represent the distribution of volumes in the field, DOE used data from the 2008 CEC appliance 

model database. Figures in appendix 7-B show the distribution of appliance sizes represented 

within the database.

DOE used the CEC database to develop a linear equation relating listed total volume to

adjusted volume for product class 11. The parameters of the equation are listed in Table 7.5.1. 

For compact freezers, the adjusted volume is equal to 1.73 times the volume.3 DOE then used the 

relation between adjusted volume and energy use described by the DOE test procedure to relate 

the distribution of volumes in the CEC database to a distribution of energy use values. 
7-25

Table 7.5.1 Parameters for Calculating Adjusted Volume from Total Volume for Compact 

Refrigerators

Product Category Slope Intercept R2 Count

Compact Refrigerators 1.0458 -0.0905 0.9822 187

7.6 ANNUAL ENERGY CONSUMPTION BY EFFICIENCY LEVEL

This section reports the annual energy consumption calculated for refrigeration products 

at various efficiency levels if they were used in RECS 2005 homes.

As discussed in chapter 5, DOE analyzed specific efficiency levels for the considered 

product classes. Tables 7.6.1 through 7.6.4 show the considered efficiency levels and 

corresponding average annual energy consumption for each representative product class. 

Table 7.6.1 Standard-Size Refrigerator-Freezers: Average Annual Energy Use by 

Efficiency Level

Product Class 3: 

Top-Mount RefrigeratorFreezer

Product Class 5: 

Bottom-Mount RefrigeratorFreezer

Product Class 7: 

Side-by-Side Refrigerator-Freezer 

with TTD*

Efficiency Level

(% less than baseline 

energy use) kWh**

Efficiency Level

(% less than baseline 

energy use) kWh**

Efficiency Level

(% less than baseline 

energy use) kWh**

Baseline 501 Baseline 613 Baseline 768

1 (10) 451 1 (10) 551 1 (10) 691

2 (15) 426 2 (15) 521 2 (15) 653

3 (20) 401 3 (20) 490 3 (20) 614

4 (25) 376 4 (25) 459 4 (25) 576

5 (30) 351 5 (30) 429 5 (30) 538

6 (36) 323 6 (36) 391 6 (33) 515

*Through-the-door ice service.

**Average energy use calculated over the lifetime of the product, not including icemaker energy (for product class 

7).
7-26

Table 7.6.2 Standard-Size Freezers: Average Annual Energy Use by Efficiency Level

Product Class 9: 

Upright Freezer

Product Class 10: 

Chest Freezer

Efficiency Level

(% less than baseline energy use) kWh*

Efficiency Level

(% less than baseline energy use) kWh*

Baseline 600 Baseline 370

1 (10) 540 1 (10) 333

2 (15) 510 2 (15) 315

3 (20) 480 3 (20) 296

4 (25) 450 4 (25) 278

5 (30) 420 5 (30) 259

6 (35) 390 6 (35) 241

7 (40) 360 7 (41) 217

8 (44) 338

*Average energy use calculated over the lifetime of the product.

Table 7.6.3 Compact Refrigeration Products: Average Annual Energy Use by Efficiency 

Level

Product Class 11: 

Compact Refrigerator

Product Class 18: 

Compact Freezer

Efficiency Level

(% less than baseline energy 

use) kWh*

Efficiency Level

(% less than baseline energy 

use) kWh*

Baseline 325 Baseline 313

1 (10) 292 1 (10) 281

2 (15) 276 2 (15) 266

3 (20) 260 3 (20) 250

4 (25) 244 4 (25) 235

5 (30) 227 5 (30) 219

6 (35) 211 6 (35) 203

7 (40) 195 7 (42) 182

8 (45) 179

9 (50) 162

10 (59) 134

*Average energy use calculated over the lifetime of the product.
7-27

Table 7.6.4 Built-In Refrigeration Products: Average Annual Energy Use by Efficiency 

Level

Product Class 3A-BI: 

Built-in All 

Refrigerator

Product Class 5-BI: 

Built-In Bottom-Mount 

Refrigerator-Freezer

Product Class 7-BI: 

Built-In Side-by-Side 

Refrigerator-Freezer with 

TTD*

Product Class 9-BI: 

Built-In Upright Freezer

Efficiency 

Level

(% less than 

baseline 

energy use) kWh*

Efficiency 

Level

(% less than 

baseline 

energy use) kWh*

Efficiency 

Level

(% less than 

baseline 

energy use) kWh*

Efficiency 

Level

(% less than 

baseline 

energy use) kWh*

Baseline 519 Baseline 619 Baseline 758 Baseline 580

1 (10) 467 1 (10) 557 1 (10) 681 1 (10) 522

2 (15) 441 2 (15) 526 2 (15) 643 2 (15) 493

3 (20) 415 3 (20) 495 3 (20) 605 3 (20) 464

4 (25) 389 4 (25) 464 4 (22) 594 4 (25) 435

5 (29) 370 5 (27) 450 5 (27) 421

*Average energy use calculated over the lifetime of the product, not including icemaker energy (for product class 7-

BI).
7-28

REFERENCES

 1 U.S. Department of Energy–Energy Information Administration. Residential Energy 

Consumption Survey, 2005 Public Use Data Files. 2009. U.S. Department of Energy: 

Washington, D.C. <www.eia.doe.gov/emeu/recs/recspubuse05/pubuse05.html> 

2 Meier, A. and M. Martinez. Energy Use of Icemaking in Domestic Refrigerators. ASHRAE 

Transactions: Symposia. 1996. AT-96-19-2.

3 Title 10—Energy, Chapter II—Department of Energy, Part 430—Energy Conservation 

Program for Consumer Products, Subpart B—Test Procedures, Appendix A1 and B1.

4 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Energy 

Conservation Program for Consumer Products: Proposed Rulemaking Regarding Energy 

Conservation Standards for Refrigerators, Refrigerator-Freezers, and Freezers. Federal 

Register. July 20, 1995. 60 FR 37388.

5 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Energy 

Conservation Program for Consumer Products: Energy Conservation Standards for 

Refrigerators, Refrigerator-Freezers, and Freezers; Final Rule. Finding of No Significant 

Impact; Notice. Federal Register. April 28, 1997. 62 FR 23102. 

<www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/refrig_final.pdf>
8-i

CHAPTER 8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS

TABLE OF CONTENTS

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

8.1.1 Approach.......................................................................................................................... 8-1

8.1.2 Summary of Inputs........................................................................................................... 8-2

8.2 INPUTS TO LIFE-CYCLE COST ANALYSIS ............................................................. 8-7

8.2.1 Inputs to Product Cost...................................................................................................... 8-8

8.2.1.1 Baseline Retail Prices .................................................................................... 8-8

8.2.1.2 Increases in Manufacturer Selling Price ........................................................ 8-9

8.2.1.3 Markup and Sales Tax ................................................................................. 8-12

8.2.1.4 Installation Cost ........................................................................................... 8-12

8.2.1.5 Consumer Product Cost ............................................................................... 8-12

8.2.2 Inputs to Operating Cost ................................................................................................ 8-14

8.2.2.1 Annual Energy Consumption....................................................................... 8-15

8.2.2.2 Energy Prices............................................................................................... 8-18

8.2.2.3 Energy Price Trends..................................................................................... 8-19

8.2.2.4 Repair and Maintenance Costs..................................................................... 8-19

8.2.3 Product Lifetimes........................................................................................................... 8-25

8.2.3.1 Estimated Survival Function........................................................................ 8-25

8.2.3.2 Conversion of First to Second Refrigerators ............................................... 8-31

8.2.3.3 Standard-Size Freezers................................................................................. 8-33

8.2.3.4 Compact Refrigeration Products.................................................................. 8-35

8.2.4 Discount Rates............................................................................................................... 8-36

8.2.4.1 Discount Rates for Residential Consumers.................................................. 8-36

8.2.4.2 Assignment of Discount Rates to Sample Households................................ 8-39

8.2.4.3 Discount Rates for Commercial Purchasers ................................................ 8-39

8.2.5 Compliance Date of Standard ........................................................................................ 8-42

8.2.6 Base-Case Energy Efficiencies...................................................................................... 8-43

8.3 INPUTS TO PAYBACK PERIOD ANALYSIS........................................................... 8-47

8.4 RESULTS OF ANALYSES .......................................................................................... 8-48

8.4.1 Standard-Size Refrigerator-Freezers.............................................................................. 8-49

8.4.1.1 Summary of Results..................................................................................... 8-49

8.4.1.2 Distributions of Impacts............................................................................... 8-50

8.4.2 Standard-Size Freezers................................................................................................... 8-55

8.4.2.1 Summary of Results..................................................................................... 8-55

8.4.2.2 Distributions of Impacts............................................................................... 8-56

8.4.3 Compact Refrigeration Products.................................................................................... 8-60

8.4.3.1 Summary of Results..................................................................................... 8-60

8.4.3.2 Distributions of Impacts............................................................................... 8-61

8.4.4 Built-In Refrigeration Products...................................................................................... 8-65

8.4.4.1 Summary of Results..................................................................................... 8-65

8.4.4.2 Distributions of Impacts............................................................................... 8-67
8-ii

8.5 REBUTTABLE PAYBACK PERIOD.......................................................................... 8-73

8.5.1 Results............................................................................................................................ 8-74

LIST OF TABLES

Table 8.1.1 Standard-Size Refrigerator-Freezers: Summary of Inputs to Calculations.......... 8-5

Table 8.1.2 Standard-Size Freezers: Summary of Inputs to Calculations .............................. 8-6

Table 8.1.3 Compact Refrigeration Products: Summary of Inputs to Calculations................ 8-7

Table 8.2.1 Residential Refrigeration Products: Average Baseline Retail Price .................... 8-9

Table 8.2.2 Standard-Size Refrigerator-Freezers: Increase in Manufacturer Selling 

Prices Relative to Baseline................................................................................. 8-10

Table 8.2.3 Standard-Size Freezers: Increases in Manufacturer Selling Prices Relative 

to Baseline.......................................................................................................... 8-10

Table 8.2.4 Compact Refrigeration Products: Increases in Manufacturer Selling Prices 

Relative to Baseline ........................................................................................... 8-11

Table 8.2.5 Built-In Refrigeration Products: Increases in Manufacturer Selling Prices 

Relative to Baseline ........................................................................................... 8-11

Table 8.2.6 Standard-Size Refrigerator-Freezers: Average Consumer Cost ........................ 8-12

Table 8.2.7 Standard-Size Freezers: Average Consumer Cost ............................................. 8-13

Table 8.2.8 Compact Refrigeration Products: Average Consumer Cost .............................. 8-13

Table 8.2.9 Built-In Refrigeration Products: Average Consumer Cost ................................ 8-13

Table 8.2.10 Standard-Size Refrigerator-Freezers: Average Annual Energy Use by 

Efficiency Level................................................................................................. 8-16

Table 8.2.11 Standard-Size Freezers: Average Annual Energy Use by Efficiency Level...... 8-16

Table 8.2.12 Compact Refrigeration Products: Average Annual Energy Use by 

Efficiency Level................................................................................................. 8-17

Table 8.2.13 Built-In Refrigeration Products: Average Annual Energy Use by 

Efficiency Level................................................................................................. 8-17

Table 8.2.14 Average Electricity Prices in 2007 .................................................................... 8-18

Table 8.2.15 Repair Rates Estimated From Commercial Refrigeration Rulemaking............. 8-20

Table 8.2.16 Rates of Repair by Product Class and Year, With Icemaking Separately 

Calculated .......................................................................................................... 8-21

Table 8.2.17 Annual Repair Rates Estimated for Residential Refrigerator-Freezers............. 8-21

Table 8.2.18 Markups Used in Determining Incremental Repair Costs................................. 8-22

Table 8.2.19 Average National Baseline Repair Costs for Standard-Sized Residential 

Refrigerator-Freezers......................................................................................... 8-22

Table 8.2.20 Baseline Annual Repair Cost Estimates ............................................................ 8-23

Table 8.2.21 Annual Repair Cost For Standard-Size Refrigerator-Freezers .......................... 8-23

Table 8.2.22 Annual Repair Cost For Standard-Size Freezers............................................... 8-24

Table 8.2.23 Annual Repair Cost For Compact Refrigeration Products ................................ 8-24

Table 8.2.24 Annual Repair Cost For Built-In Refrigeration Products.................................. 8-24

Table 8.2.25 Standard-Size Refrigerator-Freezers: Comparison of Survey and 

Shipments Data with Modeled Stock................................................................. 8-29
8-iii

Table 8.2.26 Standard-Size Freezers: Comparison of Survey and Shipments Stock to 

Modeled Stock ................................................................................................... 8-34

Table 8.2.27 Percent of Total Value for Considered Household Debt and Equity Classes.... 8-37

Table 8.2.28 Average Nominal Interest Rates for Household Debt ....................................... 8-37

Table 8.2.29 Average Real Effective Interest Rates for Household Debt .............................. 8-38

Table 8.2.30 Average Nominal and Real Interest Rates for Household Equity ..................... 8-38

Table 8.2.31 Average Interest on Household Debt and Equity .............................................. 8-39

Table 8.2.32 Data for Calculating Weighted-Average Cost of Capital for Commercial 

Sectors................................................................................................................ 8-41

Table 8.2.33 Weighted-Average Cost of Capital for Commercial Sectors............................. 8-42

Table 8.2.34 Discount Rates for Commercial Sectors............................................................ 8-42

Table 8.2.35 Standard-Size Refrigerator-Freezers: Historic and Base-Case Efficiency 

Distributions....................................................................................................... 8-44

Table 8.2.36 Standard-Size Freezers: Historic and Base-Case Efficiency Distributions ....... 8-45

Table 8.2.37 Compact Refrigeration Products: Historic and Base-Case Efficiency 

Distributions....................................................................................................... 8-46

Table 8.2.38 Market Share of ENERGY STAR Products...................................................... 8-47

Table 8.4.1 Product Class 3, Top-Mount Refrigerator-Freezers: LCC and PBP Results..... 8-49

Table 8.4.2 Product Class 5, Bottom-Mount Refrigerator-Freezers: LCC and PBP 

Results................................................................................................................ 8-49

Table 8.4.3 Product Class 7, Side-by-Side Refrigerator-Freezers with Through-theDoor Ice Service: LCC and PBP Results........................................................... 8-50

Table 8.4.4 Product Class 9, Upright Freezers: LCC and PBP Results................................ 8-55

Table 8.4.5 Product Class 10, Chest Freezer: LCC and PBP Results................................... 8-55

Table 8.4.6 Product Class 11, Compact Refrigerators: LCC and PBP Results.................... 8-60

Table 8.4.7 Product Class 18, Compact Freezers: LCC and PBP Results............................ 8-60

Table 8.4.8 Product Class 3A-BI, Built-In All Refrigerators: LCC and PBP Results.......... 8-65

Table 8.4.9 Product Class 5-BI, Built-In Bottom-Mount Refrigerator-Freezers: LCC 

and PBP Results................................................................................................. 8-66

Table 8.4.10 Product Class 7-BI, Built-In Side-by-Side Refrigerator-Freezers with 

Through-the-Door Ice Service: LCC and PBP Results...................................... 8-66

Table 8.4.11 Product Class 9-BI, Built-In Upright Freezers: LCC and PBP Results............. 8-67

Table 8.5.1 Standard-Size Refrigerator-Freezers: Rebuttable Payback Periods................... 8-74

Table 8.5.2 Standard-Size Freezers: Rebuttable Payback Periods........................................ 8-75

Table 8.5.3 Compact Refrigeration Products: Rebuttable Payback Periods......................... 8-75

Table 8.5.4 Built-In Refrigeration Products: Rebuttable Payback Periods........................... 8-76

LIST OF FIGURES

Figure 8.1.1 Flow Diagram of Inputs for Life-Cycle Cost and Payback Period Analyses...... 8-4

Figure 8.2.1 Residential and Commercial Electricity Price Trends Indexed on 2007 

Price ................................................................................................................... 8-19

Figure 8.2.2 Comparison of Modeled Refrigerator Age Distribution with Data from 

Residential Energy Consumption Surveys......................................................... 8-30
8-iv

Figure 8.2.3 Survival Function for Standard-Size Refrigerator-Freezers.............................. 8-30

Figure 8.2.4 Function for Conversion of First to Second Refrigerator-Freezers................... 8-33

Figure 8.2.5 Survival Function for Standard-Size Freezers................................................... 8-35

Figure 8.4.1 Product Class 3, Top-Mount Refrigerator-Freezers: Distribution of LifeCycle Cost Impacts for Efficiency Level 4........................................................ 8-51

Figure 8.4.2 Product Class 3, Top-Mount Refrigerator-Freezers: Distribution of 

Payback Periods for Efficiency Level 4............................................................. 8-51

Figure 8.4.3 Product Class 3, Top-Mount Refrigerator-Freezers: Range of Life-Cycle 

Cost Savings by Efficiency Level...................................................................... 8-52

Figure 8.4.4 Product Class 5, Bottom-Mount Refrigerator-Freezers: Range of LifeCycle Cost Savings by Efficiency Level ........................................................... 8-52

Figure 8.4.5 Product Class 7, Side-by-Side Refrigerator-Freezers: Range of Life-Cycle 

Cost Savings by Efficiency Level...................................................................... 8-53

Figure 8.4.6 Product Class 3, Top-Mount Refrigerator-Freezers: Range of Payback 

Periods by Efficiency Level............................................................................... 8-53

Figure 8.4.7 Product Class 5, Bottom-Mount Refrigerator-Freezers: Range of Payback 

Periods by Efficiency Level............................................................................... 8-54

Figure 8.4.8 Product Class 7, Side-by-Side Refrigerator-Freezers: Range of Payback 

Periods by Efficiency Level............................................................................... 8-55

Figure 8.4.9 Product Class 9, Upright Freezers: Distribution of Life-Cycle Cost 

Impacts for Efficiency Level 7 .......................................................................... 8-56

Figure 8.4.10 Product Class 9, Upright Freezers: Distribution of Payback Periods for 

Efficiency Level 7.............................................................................................. 8-57

Figure 8.4.11 Product Class 9, Upright Freezers: Range of Life-Cycle Cost Savings by 

Efficiency Level................................................................................................. 8-58

Figure 8.4.12 Product Class 10, Chest Freezers: Range of Life-Cycle Cost Savings by 

Efficiency Level................................................................................................. 8-58

Figure 8.4.13 Product Class 9, Upright Freezers: Range of Payback Periods by 

Efficiency Level................................................................................................. 8-59

Figure 8.4.14 Product Class 10, Chest Freezers: Range of Payback Periods by Efficiency 

Level .................................................................................................................. 8-59

Figure 8.4.15 Product Class 11, Compact Refrigerators: Distribution of Life-Cycle Cost 

Impacts for Efficiency Level 5 .......................................................................... 8-61

Figure 8.4.16 Product Class 11, Compact Refrigerators: Distribution of Payback Period 

for Efficiency Level 5 ........................................................................................ 8-62

Figure 8.4.17 Product Class 11, Compact Refrigerators: Range of Life-Cycle Cost 

Savings by Efficiency Level .............................................................................. 8-63

Figure 8.4.18 Product Class 18, Compact Freezers: Range of Life-Cycle Cost Savings 

by Efficiency Level............................................................................................ 8-63

Figure 8.4.19 Product Class 11, Compact Refrigerators: Range of Payback Periods by 

Efficiency Level................................................................................................. 8-64

Figure 8.4.20 Product Class 18, Compact Freezers: Range of Payback Periods by 

Efficiency Level................................................................................................. 8-65

Figure 8.4.21 Product Class 7-BI, Built-In Side-by-Side Refrigerator-Freezers: 

Distribution of Life-Cycle Cost Impacts for Efficiency Level 1 ....................... 8-67
8-v

Figure 8.4.22 Product Class 7-BI, Built-In Side-by-Side Refrigerator-Freezers: 

Distribution of Payback Period for Efficiency Level 1 ..................................... 8-68

Figure 8.4.23 Product Class 3A-BI, Built-In All Refrigerators: Range of Life-Cycle Cost 

Savings by Efficiency Level .............................................................................. 8-69

Figure 8.4.24 Product Class 5-BI, Built-In Bottom-Mount Refrigerator-Freezers: Range 

of Life-Cycle Cost Savings by Efficiency Level ............................................... 8-69

Figure 8.4.25 Product Class 7-BI, Built-In Side-by-Side Refrigerator-Freezers with 

Through-the-Door Ice Service: Range of Life-Cycle Cost Savings by 

Efficiency Level................................................................................................. 8-70

Figure 8.4.26 Product Class 9-BI, Built-In Upright Freezers: Range of Life-Cycle Cost 

Savings by Efficiency Level .............................................................................. 8-71

Figure 8.4.27 Product Class 3A-BI, Built-In All Refrigerators: Range of Payback 

Periods by Efficiency Level............................................................................... 8-71

Figure 8.4.28 Product Class 5-BI, Built-In Bottom-Mount Refrigerator-Freezers: Range 

of Payback Periods by Efficiency Level............................................................ 8-72

Figure 8.4.29 Product Class 7-BI, Built-In Side-by-Side Refrigerator-Freezers with 

Through-the-Door Ice Service: Range of Payback Periods by Efficiency 

Level .................................................................................................................. 8-73

Figure 8.4.30 Product Class 9-BI, Built-In Upright Freezers: Range of Payback Periods 

by Efficiency Level............................................................................................ 8-73
8-1

CHAPTER 8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS

8.1 INTRODUCTION

This chapter describes the Department of Energy (DOE)’s method and metrics for 

analyzing the economic impacts on individual consumers of potential energy efficiency 

standards for refrigeration products. The effects of standards on individual consumers include a 

change (usually a decrease) in operating cost and a change (usually an increase) in product cost. 

For each of the 11 representative product classes analyzed in this rulemaking, DOE examined the 

life-cycle cost, payback period, and rebuttable payback period of all of the considered efficiency 

levels. The terms used in this analysis are defined below.

• Life-cycle cost (LCC) is the total cost consumers incur during the life of an appliance, 

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

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

lifetime of a product.

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

assumed higher purchase cost of more energy efficient products through lower 

operating costs.

• Rebuttable payback period, a special case of the payback period, is based on 

laboratory conditions (specifically, those that reflect the DOE test procedure) for 

energy use. Its other inputs (including electricity prices) reflect representative realworld operating conditions.

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

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

discussed in section 8.5. Key variables and calculations are presented for each of the three 

metrics listed above. DOE performed the calculations discussed here using a series of Microsoft 

Excel spreadsheets that are accessible on the Internet 

(www.eere.energy.gov/buildings/appliance_standards/). Details regarding and instructions for 

using the spreadsheets are discussed in appendix 8-A. 

8.1.1 Approach

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

variable or uncertain, DOE used Monte Carlo simulation and probability distributions to model 

both the uncertainty and variability of inputs. Appendix 8-B provides a detailed explanation of 

Monte Carlo simulation and the use of probability distributions. DOE developed LCC and PBP 

spreadsheet models that incorporate both Monte Carlo simulation and probability distributions 

by using Microsoft Excel® spreadsheets combined with Crystal Ball®, a commercially available 

add-in program. 
8-2

In addition to using probability distributions to characterize several of the inputs to the 

calculation, DOE developed samples of individual households that use standard-size 

refrigeration products. DOE performed the LCC and PBP calculations for each household in the 

sample to account for the variability in energy consumption and/or energy price associated with a 

range of households.

As described in chapter 7, DOE used the DOE Energy Information Administration 

(EIA)’s 2005 Residential Energy Consumption Survey (RECS) to develop household samples 

for standard-size refrigeration products.1 EIA constructed the 2005 RECS to represent the range 

of households throughout the United States. 

DOE used the 2005 RECS to establish the variability in the annual energy use of 

refrigeration products and in energy prices. DOE was able to assign a unique annual energy use 

and/or energy price to each household in the sample. Because of the large sample of households 

considered in the LCC and PBP analyses, annual energy use and/or energy prices vary greatly. 

Thus, although the annual energy use and/or energy prices are known for any particular 

household, their variability across all households contributes to the range of LCCs and PBPs 

calculated for any particular possible standard.

DOE did not develop a household sample for compact refrigeration products, because 

many such products are used in lodging, dormitories, and other commercial establishments. DOE 

estimated the fractions of shipments of compact refrigeration products used in the residential and 

commercial sectors, then used appropriate inputs for those fractions.

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

conditions. Results, presented in section 8.4, were derived from 10,000 samples for each Monte 

Carlo simulation run. To illustrate the implications of the analysis, DOE generated a frequency 

chart that depicts the variation in LCC and PBP for each standard level considered for 

refrigeration products.

8.1.2 Summary of Inputs

The LCC represents the total consumer cost during the life of a product, including 

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

cost to the time of purchase, then sums them over the lifetime of each product. The PBP is the 

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

operating cost that results from the standard. The PBP represents the number of years it will take 

the customer to recover the increased purchase cost through decreased operating cost. 

DOE uses two types of inputs to the calculation of LCC and PBP: (1) inputs for 

establishing the purchase cost, otherwise known as the consumer product cost, and (2) inputs for 

determining the operating cost. 
8-3

The following are the primary inputs for establishing the consumer product cost at each 

efficiency level.

• Baseline selling price: The price at which a manufacturer sells a product identified as 

a baseline model. 

• Increases in manufacturer selling price (MSP): The change in manufacturer selling 

price associated with product that meets a particular efficiency level.

• Markups and sales tax: The costs associated with converting increases in the MSP 

into consumer product cost. 

The following are the primary inputs for calculating the operating cost at each efficiency 

level.

• Product energy consumption: The site energy use associated with operating a given 

product. 

• Energy prices: The prices consumers paid for energy (electricity) in a recent year.

• Energy price trends. Energy prices forecasted into the future. 

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

components that fail. Maintenance costs are associated with maintaining the operation 

of a product.

• Lifetime: The age at which a product is retired from service. 

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

their present value. 

Figure 8.1.1 graphically depicts the relationships among the inputs for installed cost and 

operating cost used to calculate the LCC and PBP. The yellow boxes in Figure 8.1.1 indicate 

inputs; the green boxes indicate intermediate outputs; and the blue boxes indicate the final 

outputs of LCC and PBP.
8-4

Figure 8.1.1 Flow Diagram of Inputs for Life-Cycle Cost and Payback Period 

Analyses

Tables 8.1.1 through 8.1.3 summarize the input values that DOE used to calculate the 

LCC and PBP for refrigeration products. The inputs for calculating total installed and operating 

costs included the product lifetime, discount rate, and energy price trends. DOE used single-point 

values to characterize all inputs to total cost, but used probability distributions to capture the 

uncertainty and/or variability of several inputs to operating cost. For those inputs characterized 

using probability distributions, the values in the following tables are average or typical values. 

Baseline

Manufacturer

Selling Price

Std-Level

Manufacturer

Selling Price

Retailer

Markup

Sales Tax

Installation

Cost

Total Installed

Cost

 Energy

Consumption

Equipment

Price

Lifetime

Operating

Cost

Annual Energy

Cost

Product

Lifetime

Repair and

Maintenance

Cost

Discount Rate

Energy Price

Trends

Annual

Operating

Cost

Payback

Period

Life-Cycle

Cost

Energy Prices
8-5

Table 8.1.1 Standard-Size Refrigerator-Freezers: Summary of Inputs to Calculations

Input Product Class Average or Typical Value Characterization

Baseline retail 

price*

Top-mount refrigeratorfreezer 496 2009$ Custom distribution

Bottom-mount 

refrigerator-freezer 849 2009$ Custom distribution

Side-by-side refrigeratorfreezer with TTD† 1,046 2009$ Custom distribution

Increase in 

manufacturer 

selling price**

All Varies by efficiency level Single-point value

Retailer 

markup All Baseline = 1.45Incremental = 1.17 Single-point value

Sales tax All 7.3% Varies depending on region

Annual energy 

use

Top-mount refrigeratorfreezer Baseline use = 501 kWh‡ Varies depending on age 

and usage

Bottom-mount 

refrigerator-freezer Baseline use = 613 kWh Varies depending on age and usage

Side-by-side refrigeratorfreezer with TTD† Baseline use = 768 kWh Varies depending on age 

and usage

Energy prices All 11.4 cents per kWh Varies depending on region

Energy price 

trend All AEO 2010 reference case Two additional scenarios:AEO high and low growth§

Lifetime All 16.2 years (median) Weibull distribution

Discount rate All 5.1% Custom distribution

* Retail price before sales tax.

† Through-the-door ice service.

** Includes manufacturer markup.

‡ Kilowatt hours

§ See section 8.2.2.3. 
8-6

Table 8.1.2 Standard-Size Freezers: Summary of Inputs to Calculations

Input Product Class Average or Typical Value Characterization

Baseline retail price* Upright 518 2009$ Custom distribution

Chest 378 2009$ Custom distribution

Increase in manufacturer 

selling price† All Varies by efficiency level Single-point value

Retailer markup All Baseline = 1.45

Incremental = 1.17 Single-point value

Sales tax All 7.2% Varies depending on region

Annual energy use Upright Baseline use = 600 kWh** Varies depending on usage

Chest Baseline use = 370 kWh Varies depending on usage

Energy prices All 11.4 cents per kWh Varies depending on region

Energy price trend All AEO 2010 reference case Two additional scenarios:

AEO high and low growth‡

Lifetime All 21.7 years (median) Weibull distribution

Discount rate All 5.1% Custom distribution

* Retail price before sales tax.

† Includes manufacturer markup.

** Kilowatt hours.

‡ See section 8.2.2.3.
8-7

Table 8.1.3 Compact Refrigeration Products: Summary of Inputs to Calculations

Input Product Class Average or Typical Value Characterization

Baseline retail price* Refrigerator 139 2009$ Custom distribution

Freezer 188 2009$ Custom distribution

Increase in manufacturer 

selling price†

All Varies by efficiency level Single-point value

Retailer markup All Baseline = 1.45

Incremental = 1.17 Single-point value

Sales tax All 7.3% Varies depending on region

Annual energy use Refrigerator Baseline use = 325 kWh** Varies depending on usage

Freezer Baseline use = 313 kWh Varies depending on usage

Energy prices All 10.8 cents per kWh Varies depending on region

Energy price trend All AEO 2010 reference case

Two additional scenarios:

AEO high- and lowgrowth‡

Lifetime

Refrigerator 5.6 years (mean) Weibull distribution

Freezer 7.5 years (mean) Weibull distribution

Discount rate All 5.1% (residential users)

6.2% (commercial users) Custom distribution

* Retail price before sales tax.

† Includes manufacturer markup.

** Kilowatt- hours.

‡ See section 8.2.2.3.

8.2 INPUTS TO LIFE-CYCLE COST ANALYSIS

Life-cycle cost (LCC) is the total consumer cost during the life of an appliance, including 

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

the time of purchase, then sums them over the lifetime of the product. DOE uses the following 

equation to define LCC.

( ) ∑= + = +

N

t t

t

r

OC LCC PC

1 1

Where:

LCC = life-cycle cost in dollars;

PC = consumer product cost in dollars;
8-8

∑ = sum over the lifetime, from year 1 to year N;

N = lifetime of appliance in years;

OC = operating cost in dollars;

r = discount rate; and

t = year for which operating cost is being determined.

DOE expresses dollar values in 2009$ because it gathered most of its data for the LCC and PBP 

analysis in 2009. 

8.2.1 Inputs to Product Cost 

DOE calculated the cost consumers pay for baseline products based on the following 

equation.

PC (RSP ) (TAX ) BASE = BASE ×

Where:

PCBASE = consumer cost for baseline product,

RSPBASE = retail selling price for baseline product, and

TAX= sales tax.

DOE calculated the consumer cost for products having higher efficiency levels based on the 

following equation.

PC PC ( MSP MU TAX ) STD = BASE + ∆ STD × RETINCR ×

Where:

PCSTD = consumer product cost for higher-efficiency products,

PCBASE = consumer cost for baseline product

ΔMSPSTD = change in MSP for more efficient model,

MURET_INCR = incremental retailer markup,

TAX= sales tax.

8.2.1.1 Baseline Retail Prices

DOE’s engineering analysis (see chapter 5) did not attempt to estimate the manufacturing 

sales price (MSP) for baseline models. Instead, it developed incremental increases in MSP 

associated with increases in efficiency level. This approach required DOE to estimate retail 

prices for the baseline model in each product class. 
8-9

DOE drew upon proprietary retail price data collected by The NPD Group.2 These data 

reflect prices and sales at many retail outlets in the United States, representing more than 50 

percent of retail sales nationwide. The data include model number, refrigerated volume, 

configuration of doors and ice-making, and whether the unit is an ENERGY STAR product. 

Based on these data DOE developed a sales-weighted price distribution for non-ENERGY STAR 

appliances in each product class.a For the LCC and PBP analyses of standard-sized products, 

DOE assigned a baseline price from that distribution to each household sampled from the EIA’s 

2005 Residential Energy Consumption Survey (RECS).1 For compact product classes, DOE 

assigned a baseline price from the distribution to each sampled product. Appendix 8-C presents 

the distribution histograms DOE developed for each product class. The average baseline retail 

prices before sales tax for each refrigeration product class are shown in Table 8.2.1. 

Table 8.2.1 Residential Refrigeration Products: Average Baseline Retail Price

Product Class Baseline Retail Price*

2009$

Product class 3: Top-mount refrigerator-freezer 496

Product class 5: Bottom-mount refrigerator-freezer 849

Product class 7: Side-by-side refrigerator-freezer with TTD† 1046

Product class 9: Upright freezer 518

Product class 10: Chest freezer 378

Product class 11: Compact refrigerator 139

Product class 18: Compact freezer 188

Product class 3A-BI: Built-in all refrigerator 4434

Product class 5-BI: Built-in bottom-mount refrigerator-freezer 4965

Product class 7-BI: Built-in side-by-side refrigerator-freezer 

with TTD† 7187

Product class 9-BI: Built-in upright freezer 4048

* Retail price before sales tax.

† Through-the-door ice service.

8.2.1.2 Increases in Manufacturer Selling Price 

DOE used a combination of cost data submitted by the Association of Home Appliance 

Manufacturers (AHAM)3

 

a DOE assumed that prices for non-ENERGY STAR models are a reasonable approximation of 

prices for the baseline models.

and a reverse engineering analysis to estimate increases to 

manufacturing cost associated with increases in efficiency levels for refrigeration products. Refer 

to chapter 5, Engineering Analysis, for details. Adding the manufacturer markup described in 

chapter 6 yielded the MSP increases for each considered efficiency level and product class 

shown in Tables 8.2.2 through 8.2.5. 
8-10

Table 8.2.2 Standard-Size Refrigerator-Freezers: Increase in Manufacturer Selling Prices 

Relative to Baseline

Product Class 3:

Top-Mount RefrigeratorFreezer

Product Class 5:

Bottom-Mount RefrigeratorFreezer

Product Class 7:

Side-Mount RefrigeratorFreezer with TTD* ice

Efficiency 

Level

(% less than 

baseline 

energy use)

Increase in 

Manufacturer 

Selling Price 

(2009$)

Efficiency 

Level

(% less than 

baseline energy 

use)

Increase in 

Manufacturer 

Selling Price 

(2009$)

Efficiency 

Level

(% less than 

baseline 

energy use)

Increase in 

Manufacturer 

Selling Price 

(2009$)

1 (10) $11.81 1 (10) $12.99 1 (10) $9.90

2 (15) $19.73 2 (15) $21.64 2 (15) $19.03

3 (20) $73.13 3 (20) $37.54 3 (20) $42.45

4 (25) $106.73 4 (25) $89.52 4 (25) $94.21

5 (30) $180.46 5 (30) $175.05 5 (30) $206.85

6 (36) $286.19 6 (36) $293.47 6 (33) $295.21

* Through-the-door.

Table 8.2.3 Standard-Size Freezers: Increases in Manufacturer Selling Prices Relative to 

Baseline

Product Class 9: 

Upright Freezer 

Product Class 10: 

Chest Freezer 

Efficiency Level

(% less than baseline 

energy use)

Increase in 

Manufacturer 

Selling Price 

(2009$)

Efficiency Level

(% less than 

baseline energy 

use)

Increase in 

Manufacturer 

Selling Price 

(2009$)

1 (10) $11.19 1 (10) $6.44

2 (15) $28.46 2 (15) $14.68

3 (20) $43.77 3 (20) $24.19

4 (25) $67.00 4 (25) $62.33

5 (30) $88.22 5 (30) $79.17

6 (35) $135.70 6 (35) $127.07

7 (40) $201.92 7 (41) $223.55 

8 (44) $348.61
8-11

Table 8.2.4 Compact Refrigeration Products: Increases in Manufacturer Selling Prices 

Relative to Baseline

Product Class 11: 

Compact Refrigerator or Refrigerator-Freezer 

Product Class 18: 

Compact Chest Freezer

Efficiency Level

(% less than baseline 

energy use)

Increase in 

Manufacturer 

Selling Price 

(2009$)

Efficiency Level

(% less than 

baseline energy 

use)

Increase in 

Manufacturer 

Selling Price (2009$)

1 (10) $4.64 1 (10) $5.99

2 (15) $8.17 2 (15) $16.70

3 (20) $13.19 3 (20) $52.73

4 (25) $23.22 4 (25) $61.54

5 (30) $31.20 5 (30) $87.84

6 (35) $53.61 6 (35) $94.47

7 (40) $60.14 7 (42) $157.09

8 (45) $87.47

9 (50) $102.35

10 (59) $155.96 

Table 8.2.5 Built-In Refrigeration Products: Increases in Manufacturer Selling Prices 

Relative to Baseline

Product Class 3A-BI: Built-in All 

Refrigerators

Product Class 5-BI: Built-in BottomMount Refrigerator-Freezers

Efficiency Level

(% less than 

baseline energy 

use)

Increase in 

Manufacturer 

Selling Price 

(2009$)

Efficiency Level

(% less than 

baseline energy 

use)

Increase in 

Manufacturer 

Selling Price 

(2009$)

1 (10) $7.14 1 (10) $21.47

2 (15) $18.90 2 (15) $85.82

3 (20) $127.10 3 (20) $165.89

4 (25) $272.09 4 (25) $295.29

5 (29) $381.70 5 (27) $370.21

Product Class 7-BI: Built-in Side-bySide Refrigerator-FreezersProduct Class 9-BI: Built-in Upright 

Freezers

Efficiency Level

(% less than 

baseline energy 

use)

Increase in 

Manufacturer 

Selling Price 

(2009$)

Efficiency Level

(% less than 

baseline energy 

use)

Increase in 

Manufacturer 

Selling Price 

(2009$)

1 (10) $51.45 1 (10) $15.68
8-12

2 (15) $123.47 2 (15) $27.44

3 (20) $281.53 3 (20) $99.23

4 (22) $371.27 4 (25) $211.73

5 (27) $297.56

8.2.1.3 Markup and Sales Tax

To derive the incremental increase in consumer product cost for each efficiency level, 

DOE applied an incremental retail markup and sales tax to the MSP increases shown above. 

Refer to Chapter 6, Markups for Equipment Price Determination, for details. DOE also applied 

sales tax to the baseline retail prices.

8.2.1.4 Installation Cost

Because the cost to install refrigeration products does not change as efficiency increases, 

DOE did not incorporate installation costs in its analysis.

8.2.1.5 Consumer Product Cost

Tables 8.2.6 through 8.2.9 present the shipment-weighted consumer product cost at each 

considered efficiency standard level for the refrigeration product classes under consideration for 

new standards. These costs reflect the market efficiency distributions discussed in section 8.2.6.

Table 8.2.6 Standard-Size Refrigerator-Freezers: Average Consumer Cost

Product Class 3: 

Top-Mount Refrigerator-Freezer

Product Class 5: BottomMount Refrigerator-FreezerProduct Class 7: Side-bySide Refrigerator-Freezer

Efficiency Level

(% less than 

baseline energy 

use)

Average 

Consumer Cost

(2009$)

Efficiency 

Level

(% less than 

baseline energy 

use)

Average 

Consumer 

Cost

(2009$)

Efficiency 

Level

(% less than 

baseline 

energy use)

Average 

Consumer 

Cost

(2009$)

Baseline $543 Baseline $945 Baseline $1,152

1 (10) $555 1 (10) $947 1 (10) $1,155

2 (15) $563 2 (15) $949 2 (15) $1,160

3 (20) $624 3 (20) $955 3 (20) $1,179

4 (25) $667 4 (25) $1,020 4 (25) $1,244

5 (30) $759 5 (30) $1,127 5 (30) $1,385

6 (36) $892 6 (36) $1,276 6 (33) $1,496
8-13

Table 8.2.7 Standard-Size Freezers: Average Consumer Cost

Product Class 9: 

Upright Freezer

Product Class 10: 

Chest Freezer

Efficiency Level

(% less than baseline 

energy use)

Average Consumer 

Cost (2009$)

Efficiency Level

(% less than baseline 

energy use)

Average Consumer 

Cost (2009$)

Baseline $560 Baseline $407

1 (10) $571 1 (10) $414

2 (15) $592 2 (15) $424

3 (20) $611 3 (20) $436

4 (25) $640 4 (25) $483

5 (30) $667 5 (30) $504

6 (35) $727 6 (35) $565

7 (40) $810 7 (41) $687

8 (44) $994

Table 8.2.8 Compact Refrigeration Products: Average Consumer Cost

Product Class 11: Compact Refrigerator

Product Class 18: 

Compact Freezer

Efficiency Level

(% less than baseline 

energy use)

Average Consumer 

Cost (2009$)

Efficiency Level

(% less than 

baseline energy 

use)

Average Consumer 

Cost (2009$)

Baseline $146 Baseline $202

1 (10) $151 1 (10) $209

2 (15) $156 2 (15) $223

3 (20) $162 3 (20) $268

4 (25) $174 4 (25) $279

5 (30) $184 5 (30) $312

6 (35) $212 6 (35) $320

7 (40) $221 7 (42) $399

8 (45) $255

9 (50) $274

10 (55) $341

Table 8.2.9 Built-In Refrigeration Products: Average Consumer Cost

Product Class 3A-BI: Built-in All 

Refrigerators

Product Class 5-BI: Built-in BottomMount Refrigerator-Freezers
8-14

Efficiency Level

(% less than 

baseline energy 

use)

Average 

Consumer Cost

(2009$)

Efficiency Level

(% less than 

baseline energy 

use)

Average 

Consumer Cost

(2009$)

Baseline $4,676 Baseline $5,386

1 (10) $4,683 1 (10) $5,390

2 (15) $4,696 2 (15) $5,401

3 (20) $4,826 3 (20) $5,435

4 (25) $5,017 4 (25) $5,607

5 (29) $5,162 5 (27) $5,706

Product Class 7-BI: Built-in Side-bySide Refrigerator-FreezersProduct Class 9-BI: Built-in Upright 

Freezers

Efficiency Level

(% less than 

baseline energy 

use)

Average 

Consumer Cost

(2009$)

Efficiency Level

(% less than 

baseline energy 

use)

Average 

Consumer Cost

(2009$)

Baseline $7,887 Baseline $4,383

1 (10) $7,902 1 (10) $4,400

2 (15) $7,947 2 (15) $4,415

3 (20) $8,078 3 (20) $4,509

4 (22) $8,197 4 (25) $4,657

5 (27) $4,770

8.2.2 Inputs to Operating Cost 

DOE defines operating cost (OC) by the following equation.

OC = EC + RC + MC

Where:

EC = energy cost associated with operating the product, 

RC = repair cost associated with component failure, and 

MC = cost for maintaining appliance operation.

DOE used the following equation to calculate the annual operating cost for baseline 

products.

OCBASE = AECBASE × PRICEENERGY + RCBASE + MCBASE ( )

Where:

OCBASE = operating cost for baseline product,

AECBASE = annual energy consumption for baseline product, 
8-15

PRICEENERGY = energy price,

RCBASE = repair costs associated with component failure for baseline product, and

MCBASE = maintenance costs for baseline product.

DOE used the following equation to calculate the annual operating cost for higher 

efficiency products.

OCSTD = AECSTD × PRICEENERGY + RCSTD + MCSTD ( )

Where:

OCSTD = operating cost of higher-efficiency product,

AECSTD = annual energy consumption of higher-efficiency product, 

PRICEENERGY = energy price in each year,

RCSTD = repair costs associated with component failure for higher-efficiency product, 

and

MCSTD = maintenance costs for higher-efficiency product.

8.2.2.1 Annual Energy Consumption

As described in Chapter 7, Energy Use Determination, DOE developed samples of 

individual households that use each of the standard-sized refrigeration products considered 

herein. By developing the samples, DOE was able to calculate the LCC and PBP for each 

household to account for the variability in both energy use and energy price associated with that 

household. 

Tables 8.2.10 through 8.2.13 are derived from the analysis described in chapter 7. The 

values shown for annual energy consumption are averages in the field. For compact products, 

DOE did not use the RECS sample, and the energy consumption is as measured using the DOE 

test procedure. DOE captured the variability in energy consumption by using a range of values in 

its LCC and PBP analyses.
8-16

Table 8.2.10Standard-Size Refrigerator-Freezers: Average Annual Energy Use by 

Efficiency Level

Product Class 3: 

Top-Mount RefrigeratorFreezer

Product Class 5: 

Bottom-Mount RefrigeratorFreezer

Product Class 7: 

Side-by-Side RefrigeratorFreezer with TTD*

Efficiency Level

(% less than baseline 

energy use)

Energy 

Use

kWh

Efficiency Level

(% less than 

baseline energy use)

Energy 

Use

kWh

Efficiency Level

(% less than 

baseline energy use)

Energy 

Use

kWh†

Baseline 501 Baseline 613 Baseline 768

1 (10) 451 1 (10) 551 1 (10) 691

2 (15) 426 2 (15) 521 2 (15) 653

3 (20) 401 3 (20) 490 3 (20) 614

4 (25) 376 4 (25) 459 4 (25) 576

5 (30) 351 5 (30) 429 5 (30) 538

6 (36) 323 6 (36) 391 6 (33) 515 *

Through-the-door ice service.

†

Not including ice maker energy.

Table 8.2.11Standard-Size Freezers: Average Annual Energy Use by Efficiency Level

Product Class 9: 

Upright Freezer

Product Class 10: 

Chest Freezer

Efficiency Level

(% less than baseline 

energy use)

Energy Use

kWh

Efficiency Level

(% less than baseline 

energy use)

Energy Use

kWh

Baseline 600 Baseline 370

1 (10) 540 1 (10) 333

2 (15) 510 2 (15) 315

3 (20) 480 3 (20) 296

4 (25) 450 4 (25) 278

5 (30) 420 5 (30) 259

6 (35) 390 6 (35) 241

7 (40) 360 7 (41) 217

8 (44) 338
8-17

Table 8.2.12 Compact Refrigeration Products: Average Annual Energy Use by Efficiency 

Level

Product Class 11: 

Compact Refrigerator

Product Class 18: 

Compact Freezer

Efficiency Level

(% less than baseline 

energy use)

Energy Use

kWh

Efficiency Level

(% less than baseline 

energy use)

Energy Use

kWh

Baseline 325 Baseline 313

1 (10) 292 1 (10) 281

2 (15) 276 2 (15) 266

3 (20) 260 3 (20) 250

4 (25) 244 4 (25) 235

5 (30) 227 5 (30) 219

6 (35) 211 6 (35) 203

7 (40) 195 7 (42) 182

8 (45) 179

9 (50) 162

10 (59) 134

Table 8.2.13 Built-In Refrigeration Products: Average Annual Energy Use by Efficiency 

Level

Built-in All Refrigerators (3A-BI) Built-in Bottom-Mount RefrigeratorFreezers (5-BI)

Efficiency Level

(% less than 

baseline energy 

use)

Energy Use

(kWh)

Efficiency Level

(% less than 

baseline energy 

use)

Energy Use

(kWh)

Baseline 519 Baseline 619

1 (10) 467 1 (10) 557

2 (15) 441 2 (15) 526

3 (20) 415 3 (20) 495

4 (25) 389 4 (25) 464

5 (29) 370 5 (27) 450

Built-in Side-by-Side RefrigeratorFreezers (7-BI) Built-in Upright Freezers (9-BI)

Efficiency Level

(% less than 

baseline energy 

use)

Energy Use

(kWh)*

Efficiency Level

(% less than 

baseline energy 

use) Energy Use (kWh)

Baseline 758 Baseline 580

1 (10) 681 1 (10) 522

2 (15) 643 2 (15) 493

3 (20) 605 3 (20) 464
8-18

4 (22) 594 4 (25) 435

5 (27) 521

* Not including ice maker energy.

8.2.2.2 Energy Prices

Using data from EIA Form 8614

, DOE derived average energy prices for 13 geographic 

areas in the United States: the nine U.S. Census divisions, plus four large states (New York, 

Florida, Texas, and California) considered individually. For Census divisions containing one of 

those large states, DOE left out data for the large state when calculating average regional values. 

For example, the Pacific region average excludes California, and the West South Central region 

excludes Texas. Using the modified regional data, DOE assigned an appropriate energy price to 

each household in the sample. 

DOE used data from EIA to estimate electricity prices for residential consumers in each 

of the 13 geographic areas These data, which are published annually, include annual electricity 

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

sector for every utility that serves final consumers. The calculation of an area-average residential 

or commercial electricity price proceeds in two steps.

1. For each utility, an average sector (residential or commercial) price is estimated by 

dividing sector revenues by sector sales.

2. An average regional price is calculated, whereby each utility having customers in a 

region is weighted by the number of residential consumers served in that region.

The calculation used the most recent EIA data available at the time the analysis was conducted. 

Table 8.2.14 shows the average residential and commercial electricity price in 2007 for each 

Census division and large state.

Table 8.2.14 Average Electricity Prices in 2007

Geographic Area

Average Residential Price 

2009$/kWh

Average Commercial Price 

2009$/kWh

New England 0.162 $0.153

Middle Atlantic 0.127 $0.111

East North Central 0.102 $0.091

West North Central 0.088 $0.075

South Atlantic 0.098 $0.085

East South Central 0.087 $0.086

West South Central 0.093 $0.085

Mountain 0.097 $0.083

Pacific 0.099 $0.094

New York State 0.178 $0.168

California 0.150 $0.136
8-19

Texas 0.128 $0.118

Florida 0.116 $0.101

Source: U.S. Department of Energy–Energy Information Administration EIA Form 861.

8.2.2.3 Energy Price Trends

To estimate energy prices in future years, DOE multiplied the average prices listed in 

Table 8.2.14 by the forecast of annual average price changes in EIA’s Annual Energy Outlook 

2010 (AEO 20105

). To estimate the trend after 2035, DOE followed guidelines that the EIA had 

provided to the Federal Energy Management Program, which called for using the average rate of 

change for electricity during 2025–2035.

Figure 8.2.1 shows the projected trends in residential and commercial electricity prices 

based on the AEO 2010 reference case. For the LCC results presented in this chapter, DOE used 

only the energy price forecasts from the AEO reference case. 

Source: Energy Information Administration, Annual Energy Outlook. 2010.

Figure 8.2.1 Residential and Commercial Electricity Price 

Trends Indexed on 2007 Price

8.2.2.4 Repair and Maintenance Costs

DOE estimated the increase in repair costs due to the use of specific technology in some 

higher efficiency design options. DOE found no evidence that maintenance costs change as the 

efficiency of refrigeration products increases, however, and thus excluded those costs from its 

analysis.

The estimated average repair cost can be expressed as the product of two elements: the 

average rate of repair of a component times the incremental cost of repair or replacement 

compared to the baseline. While detailed incremental component costs were readily available 

Electricity Price Trends

0.8

0.9

1.0

1.1

1.2

2000 2005 2010 2015 2020 2025 2030

AEO 2010 Reference Res Elec

AEO 2010 Reference Com Elec
8-20

from the detailed engineering cost models that DOE developed for two sizes per product class, 

DOE needed to estimate component repair rates.

DOE obtained relative component repair rates from a prior rulemaking for commercial 

refrigeration equipment.b In this rulemaking, the total repair rates of the compressor, evaporator, 

condenser, evaporator fan, and condenser fan were reported over the 10-year equipment lifetime. 

These were converted to constant annual rates, and a rate for electronics component repair was 

estimated to be the same as that of the compressor. Table 8.2.15 shows the assumed annual 

repair rates.

Table 8.2.15 Repair Rates Estimated From Commercial Refrigeration Rulemaking

Component 10-year repair 

rate

Assumed 

annual repair 

rate

Compressor 25% 2.5%

Evaporator + 

condenser*

5% 0.5%

Evaporator fan 50% 5.0%

Condenser fan 25% 2.5%

Electronics** 2.5%

Total 13%

*DOE assumed these repair rates are equally shared between evaporator and condenser, e.g., each at a 0.25% annual 

rate.

**Assumed same repair rate as compressor.

To evaluate whether the above commercial total repair rate (sum of individual rates) is 

applicable for residential refrigerator-freezers, DOE sought data for total repair rates from 

Consumers Union, which conducts an annual survey of approximately 100,000 members in the 

U.S. The survey gathered in April-June 2009 provided total repair rates for standard-size 

refrigerator-freezer product classes, both with and without automatic icemaking, for units sold in 

2005 or later. For products with automatic icemaking, repairs due to icemaking were separated in 

the data, and could be subtracted from total repairs to obtain a non-icemaking total repair rate for 

the first 4.4 years of a product’s life. Icemaking repair rates, while important to consumers, were 

not needed for this analysis since this rulemaking does not specifically address icemaking energy 

reductions and the design options do not change any icemaking-specific components.

Consumers Union provided cumulative rates of repair in 2005-2009 by asking consumers 

whether the appliance “has ever been repaired,” and from this data DOE was able to extract 

annual rates of repair by year. Because there was no consistent trend in repair rates over time, 

 

b Commercial Refrigeration Equipment Final Rule Technical Support Document. Available at: 

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

_tsd.html
8-21

DOE assumed that annual repair rates were constant. Without additional data, this assumption 

was also extended to ages 5 years and beyond for subsequent analysis.

DOE used the total annual non-icemaking repair rates to scale the commercial 

refrigerator component-specific repair rates (Table 8.2.15) to obtain residential componentspecific repair rates for standard-size refrigerator-freezer product classes (3, 5 and 7). The 

scaling factor is the ratio of the average annual non-icemaking repair rate to the total commercial 

refrigerator repair rate (13%). To derive the scaling factor for standard-size freezers and compact 

refrig products, DOE used the shipment-weighted average repair rate for product classes 3, 5 and 

7. Total repair rates excluding icemaking ranged from 2.1%/yr for PC3 to 5.7%/yr for PC5, 

equivalent to about 16-44% of the commercial refrigeration equipment total repair cost. See 

Table 8.2.16.

Table 8.2.16 Rates of Repair by Product Class and Year, With Icemaking Separately 

Calculated

Non-icemaking annualized repair rate

Product 

class

2008-2009 

(17 

months)

2007 2006 2005 Average Scaling 

factor for 

commercial 

rates*

3 3.8% 1.9% 0.6% 1.5% 2.12% 0.163

5 4.0% 8.0% 7.2% 4.2% 5.68% 0.437

7 3.9% 3.5% 3.5% 4.5% 3.86% 0.297

Weighted 

Average

3.9% 4.4% 3.4% 3.2% 3.75% 0.288

Icemaking annualized repair rate

3 0.8% 0.6% 0.5% 0.6% 0.64%

5 1.1% 2.0% 1.8% 1.3% 1.51%

7 3.9% 3.5% 3.5% 4.5% 3.86%

Table 8.2.17 shows the annual repair rates estimated for residential refrigerator-freezers.

Table 8.2.17 Annual Repair Rates Estimated for Residential Refrigerator-Freezers 

Component

Product Class 3:

Top-Mount 

RefrigeratorFreezer

Product Class 5:

Bottom-Mount 

RefrigeratorFreezer

Product Class 7:

Side-Mount 

RefrigeratorFreezer with 

TTD* icemaker

Other Product 

Classes

Compressor 0.41% 1.09% 0.74% 0.72%

Evaporator 0.04% 0.11% 0.07% 0.07%

Evaporator fan 0.82% 2.18% 1.48% 1.44%

Condenser 0.04% 0.11% 0.07% 0.07%

Condenser fan 0.41% 1.09% 0.74% 0.72%
8-22

Electronics 0.41% 1.09% 0.74% 0.72%

Total 2.12% 5.68% 3.86% 3.75%

* Through-the-door

Component repair costs were estimated from the incremental cost models developed in 

Chapter 5, and multiplied by the above repair rates to come up with annual costs by component 

for each size and product class. Incremental manufacturer’s costs were scaled by the 

manufacturer markup, incremental retail markup, average sales tax markup and repair markup 

representative of the residential repair and maintenance industry and provided by RSMeans. See 

Table 8.2.18.

Table 8.2.18 Markups Used in Determining Incremental Repair Costs

Type of Markup

Value

Conventional Built-in Reference

Manufacturer markup 1.26 1.40 TSD Chapter 6

Incremental retail 

markup

1.17 TSD Chapter 6

Sales tax markup 1.069 TSD Chapter 6

Repair markup 1.10 RSMeans 2010

Total markup 1.734 1.926

Finally, baseline repair costs were obtained from data provided by Best Buy Co., Inc.

[2010, “Geek Squad Black Tie Protection,” data provided by Chartis Insurance]; they reflect 

average national repair cost. No markups were applied to these end-consumer based costs. See 

Table 8.2.19.

Table 8.2.19 Average National Baseline Repair Costs for Standard-Sized Residential 

Refrigerator-Freezers

Component Repair cost

Compressor $535

Evaporator fan $215

Condenser $310

Condenser fan $215

Thermostat $205

Icemaker $295

Source: Best Buy, 2010, "Geek Squad Black Tie Protection". Data provided by Chartis Insurance 

(www.chartisinsurance.com). Pricing reflects average national repair cost.

Average annual repair costs were obtained by multiplying the baseline repair costs by the 

repair rate for product classes 3, 5, and 7. As the Best Buy data was only applicable to product 

classes 3, 5 and 7, DOE extrapolated to other product classes by examining the ratio of annual 

cost to initial purchase price for product classes 3, 5, and 7. DOE found that for all three product 
8-23

classes, this ratio was close to 1%. Therefore, DOE assumed a similar ratio holds for product 

classes 9, 10, 11 and 18, and used these to assign annual baseline repair costs to these product 

classes. For built-in product classes 3A, 5, 7 and 9, DOE used the same annual repair costs as for 

the corresponding conventional product classes 3, 5, 7 and 9, respectively. See Table 8.2.20.

Tables 8.2.21 through 8.2.24 show the estimated annual repair costs by efficiency level

for each product group.

Table 8.2.20 Baseline Annual Repair Cost Estimates

Product class

Annual repair 

cost excluding 

icemaking

Icemaking 

repair cost

Total 

annual 

repair cost

3 $5.77 $1.89 $7.66

5 $15.47 $4.45 $19.92

7 $10.51 $11.39 $21.90

9 $4.37 $4.37

10 $2.83 $2.83

11 $1.43 $1.43

18 $1.80 $1.80

Table 8.2.21 Annual Repair Cost For Standard-Size Refrigerator-Freezers

Product Class 3:

Top-Mount Refrigerator-Freezer

Product Class 5:

Bottom-Mount RefrigeratorFreezer

Product Class 7:

Side-Mount RefrigeratorFreezer with TTD* 

icemaking

Efficiency 

Level

(% less than 

baseline 

energy use)

Total annual 

repair cost

Efficiency 

Level

(% less than 

baseline energy 

use)

Total annual 

repair cost

Efficiency 

Level

(% less than 

baseline 

energy use)

Total 

annual 

repair cost

1 (10) $7.70 1 (10) $20.14 1 (10) $21.99

2 (15) $7.74 2 (15) $20.25 2 (15) $22.11

3 (20) $8.03 3 (20) $20.35 3 (20) $22.26

4 (25) $8.06 4 (25) $20.68 4 (25) $22.62

5 (30) $8.09 5 (30) $21.24 5 (30) $22.99

6 (36) $8.34 6 (36) $21.68 6 (33) $22.99

* Through-the-door
8-24

Table 8.2.22 Annual Repair Cost For Standard-Size Freezers

Product Class 9: 

Upright Freezer 

Product Class 10: 

Chest Freezer 

Efficiency Level

(% less than 

baseline energy use)

Total annual repair 

cost

Efficiency Level

(% less than baseline 

energy use)

Total annual repair 

cost

1 (10) $4.53 1 (10) $2.89

2 (15) $4.66 2 (15) $2.93

3 (20) $4.74 3 (20) $2.95

4 (25) $4.74 4 (25) $2.95

5 (30) $4.74 5 (30) $2.95

6 (35) $5.17 6 (35) $3.54

7 (40) $5.65 7 (41) $3.54

8 (44) $5.65

Table 8.2.23 Annual Repair Cost For Compact Refrigeration Products

Product Class 11:

Compact Refrigerator or RefrigeratorFreezer Product Class 18:

Compact Chest Freezer

Efficiency Level

(% less than baseline 

energy use)

Total annual repair 

cost

Efficiency Level

(% less than baseline 

energy use)

Total annual repair 

cost

1 (10) $1.47 1 (10) $1.86

2 (15) $1.50 2 (15) $1.88

3 (20) $1.50 3 (20) $1.88

4 (25) $1.50 4 (25) $1.88

5 (30) $1.50 5 (30) $2.50

6 (35) $1.82 6 (35) $2.50

7 (40) $1.82 7 (42) $2.50

8 (44) $2.15

9 (50) $2.15

10 (59) $2.15

Table 8.2.24 Annual Repair Cost For Built-In Refrigeration Products

Product Class 3A-BI: Built-in All 

Refrigerators

Product Class 5-BI: Built-in Bottom-Mount 

Refrigerator-Freezers

Efficiency Level

(% less than baseline 

energy use)

Total annual repair 

cost

Efficiency Level

(% less than baseline 

energy use)

Total annual repair 

cost

1 (10) $7.73 1 (10) $20.16
8-25

2 (15) $7.83 2 (15) $21.26

3 (20) $7.83 3 (20) $21.26

4 (25) $8.30 4 (25) $22.51

5 (29) $8.76 5 (27) $22.51

Product Class 7-BI: Built-in Side-by-Side 

Refrigerator-Freezers Product Class 9-BI: Built-in Upright Freezers 

Efficiency Level

(% less than baseline 

energy use)

Total annual repair 

cost

Efficiency Level

(% less than baseline 

energy use)

Total annual repair 

cost

1 (10) $22.38 1 (10) $4.54

2 (15) $23.32 2 (15) $4.72

3 (20) $23.32 3 (20) $5.38

4 (22) $23.32 4 (25) $5.38

5 (27) $5.38

8.2.3 Product Lifetimes

DOE estimated product lifetimes by fitting a survival probability function to data of 

historical shipments and age distributions of products. DOE performed separate modeling for 

standard size refrigerator-freezers, standard size freezers, and compact refrigeration products. 

The conversion from primary to secondary refrigerator-freezers was also modeled as part of the 

lifetime determination for standard size refrigerator-freezers.

8.2.3.1 Estimated Survival Function

The Energy Information Agency (EIA)’s Residential Energy Consumption Survey 

(RECS)1 of occupied primary housing units records the presence of various appliances in each 

household, and places the age of each appliance into bins comprising several years. Data from 

the U.S. Census’s American Housing Survey (AHS),6 which surveys all housing including vacant 

and second homes, enabled DOE to adjust the RECS data to reflect some appliance use outside 

of primary residences. By combining the results of both surveys with the known history of 

appliance shipments (collected from Appliance magazine or directly from manufacturer trade 

associations), DOE estimated the percentage of appliances of a given age still in operation. This 

survival function, which DOE assumed has the form of a cumulative Weibull distribution, 

provides an average and a median appliance lifetime.

The Weibull distribution is a probability distribution commonly used to measure failure 

rates.c

 

c For reference on the Weibull distribution, see sections 1.3.6.6.8 and 8.4.1.3 of the 

NIST/SEMATECH e-Handbook of Statistical Methods, <

Its form is similar to an exponential distribution, which models a fixed failure rate, except 

www.itl.nist.gov/div898/handbook/>.
8-26

that a Weibull distribution allows for a failure rate that changes over time in a particular fashion. 

The cumulative Weibull distribution takes the form:

e x

P x

β

α

θ 



 



 − −

( ) = for x > θ and

P(x) = 1 for x ≤ θ

Where:

P(x) = probability that the appliance is still in use at age x;

x = appliance age;

α = scale parameter, which would be the decay length in an exponential distribution;

β = shape parameter, which determines the way in which the failure rate changes through 

time; and

θ = delay parameter, which allows for a delay before any failures occur.

When β = 1, the failure rate is constant over time, giving the distribution the form of a 

cumulative exponential distribution. In the case of appliances, β commonly is greater than 1, 

reflecting an increasing failure rate as appliances age. 

The RECS survey is DOE’s primary resource for appliance ages. For several appliances, 

including refrigerators and freezers, the survey asks respondents to identify the appliance’s age 

as:

• less than 2 years old,

• 2 to 4 years old,

• 5 to 9 years old,

• 10 to19 years old, or

• more than 20 years old.

The RECS survey has been conducted every three or four years for the past several 

decades. For this analysis, DOE used the surveys conducted in 1990, 1993, 1997, 2001, and 

2005. DOE used the AHS count of housing units that contain refrigerators to scale the RECS 

data to better match the total installed stock. The U.S. Census AHS does not include data on 

freezers. DOE used the RECS micro-data to exclude from this analysis refrigerators that are both 

“half-height” and less than 10 cubic feet in capacity, because such refrigerators are not standardsized. To determine overall refrigerator lifetime, DOE included all appropriately sized 

refrigerators, whether the household’s first (primary) or second refrigerator. Households that did 

not know the age of their appliance were allocated among the remaining age bins according to 

the distribution of respondents who did report the appliance age.

Refrigerator ownership exhibits complex consumer behavior, which is not adequately 

reflected in AHS. In particular, AHS records only whether a housing unit contains a refrigerator, 

not the number of refrigerators. In addition, AHS may record a unit as containing a refrigerator 
8-27

when it contains a compact, rather than standard-size, appliance. Therefore, DOE used AHS only 

to scale the number of first refrigerators recorded by RECS. The baseline number of refrigerators 

reported in each RECS age bin is the sum of the AHS-scaled first refrigerators and the un-scaled, 

standard-size second refrigerators.

DOE adjusted the RECS survey data to account for the fact that the RECS survey begins 

its reference year with July, whereas shipments data are provided for each calendar year. DOE 

adjusted the data by using the survival function to model the additional retirement and 

replacement of appliances that takes place in the latter half of a survey year (after a given 

respondent is surveyed).

DOE used the RECS data on appliance ages, combined with the history of appliance 

shipments, to develop survival functions for refrigeration products. For example, DOE summed 

the total shipments from 5 to 9 years before each RECS survey, then compared this number with 

the number of units still in use at the time of the survey to approximate the percentage of 

surviving appliances within that age bin. By combining the age bins from the five RECS surveys 

with shipments data, DOE had enough data to use a least-squares method to build a fit to a 

Weibull distribution and find the parameters (α, β, θ) that best approximate the number of 

surviving units. Because the first two (youngest) RECS bins tend to have a large scatter relative 

to the shipments in those years, DOE combined the RECS and shipments data in the first two 

bins. Refrigerators and freezers generally do not fail during their first four years, so combining 

bins did not lower appreciably the accuracy of the distribution. DOE weighted each bin’s 

contribution to the sum of squares by the inverse of the variance in RECS survey results, which 

controls for the changes in sample size between bins and through time.d RECS has a complex 

error model. DOE used only the error due to finite sample size to determine the variance for 

weighting the age bins. The equation for the sum of squares that DOE minimized is:

( ) ∑ −

i i RECS

RECSi Survi

2

,

2

σ ,

Where:

i = the identifier for a bin from a single RECS;

RECSi = the number of appliances reported by RECS in bin I;

Survi = the number of surviving appliances in bin i predicted by the Weibull distribution 

applied to the number of appliances shipped (a function of α, β, and θ); and 

σi,RECS = the standard error (square root of the variance) of the RECS data point for bin i.

Table 8.2.25 shows the RECS data for refrigerators, the associated total shipments, and 

the best-fit Weibull calculation of stock by age bin. Figure 8.2.2 plots the data from the third and 

fourth columns of Table 8.2.25 against each other to show the quality of the fit. DOE allowed the 

 

d See sections 4.1.4.3, 4.4.3.2, and 4.4.5.2 of NIST/SEMATECH e-Handbook of Statistical 

Methods, <www.itl.nist.gov/div898/handbook/>.
8-28

delay parameter, θ, to vary only between 1 and 5 years, which corresponds to common warranty 

periods (see discussion below). For refrigerators and freezers, the best fit within this range is 5 

years. 

The Weibull distribution, shown in Figure 8.2.3, is characterized by the parameters α = 

13.91, β = 1.68, and θ = 5.0. This distribution has a mean refrigerator lifetime of 17.43 years 

and a median lifetime of 16.18 years.
8-29

Table 8.2.25 Standard-Size Refrigerator-Freezers: Comparison of Survey and Shipments 

Data with Modeled Stock 

RECS 2005

All Refrigerators Second Refrigerators

Age Bin years Shipments RECS Stock

Modeled 

Stock RECS Stock

Modeled 

Stock

0 to 4 51,119,128 56,880,896 51,119,128 5,311,005 3,041,016

5 to 9 42,988,500 40,150,841 41,031,292 4,983,112 3,524,129

10 to 19 68,088,000 36,771,769 40,997,548 8,672,157 6,942,353

20 or more 165,800,000 10,337,608 12,039,872 4,139,841 4,628,220

RECS 2001

All Refrigerators Second Refrigerators

Age Bin years Shipments RECS Stock

Modeled 

Stock RECS Stock

Modeled 

Stock

0 to 4 44,319,100 46,312,479 44,319,100 2,460,510 2,637,703

5 to 9 36,982,000 39,491,335 35,298,172 3,868,224 3,031,985

10 to 19 60,556,000 35,970,898 36,813,807 6,572,685 6,198,453

20 or more 144,325,000 11,301,203 11,920,574 3,955,496 4,580,842

RECS 1997

All Refrigerators Second Refrigerators

Age Bin years Shipments RECS Stock

Modeled 

Stock RECS Stock

Modeled 

Stock

0 to 4 38,185,000 44,356,564 38,185,000 2,047,982 2,274,485

5 to 9 32,698,000 36,760,359 31,123,487 2,782,204 2,695,071

10 to 19 56,244,000 31,056,224 33,972,064 5,078,190 5,724,270

20 or more 122,660,000 10,989,427 11,832,244 3,879,197 4,475,841

RECS 1993

All Refrigerators Second Refrigerators

Age Bin years Shipments RECS Stock

Modeled 

Stock RECS Stock

Modeled 

Stock

0 to 4 33,088,000 37,322,759 33,088,000 1,605,544 1,972,965

5 to 9 31,584,000 35,001,768 30,138,108 2,289,052 2,591,010

10 to 19 52,400,000 32,735,032 30,891,143 4,695,960 5,348,774

20 or more 101,577,000 13,119,858 11,723,329 5,708,862 4,296,210

RECS 1990

All Refrigerators Second Refrigerators

Age Bin years Shipments RECS Stock

Modeled 

Stock RECS Stock

Modeled 

Stock

0 to 4 32,670,000 38,098,670 32,670,000 1,784,095 1,950,717

5 to 9 26,419,000 30,724,176 25,249,353 2,227,766 2,158,527

10 to 19 56,584,000 34,088,557 33,242,186 5,316,297 5,767,417

20 or more 82,797,000 12,571,836 10,159,632 4,869,236 3,737,018

Source: U.S. Department of Energy–Energy Information Agency. Residential Energy Consumption Survey. 1990, 

1993, 1997, 2001, and 2005. 
8-30

Figure 8.2.2 Comparison of Modeled Refrigerator Age Distribution with Data 

from Residential Energy Consumption Surveys

Figure 8.2.3 Survival Function for Standard-Size Refrigerator-Freezers 

0

10000000

20000000

30000000

40000000

0 10000000 20000000 30000000 40000000

RECS reported number of refrigerators by bin

Calculated number of refrigerators by bin

bins

ideal

16.18

17.43

0.0

0.2

0.4

0.6

0.8

1.0

1.2

0 5 10 15 20 25 30 35 40 45 50

Age (years)

Fraction surviving

Survival function

Median lifetime

Mean lifetime
8-31

The method DOE used to calculate product lifetimes incorporates several assumptions:

• Appliance lifetime can be modeled by a survival function. In particular, a Weibull 

distribution is an appropriate survival function.

• The appliance survival function does not change through time.

• The survival function is independent of other household factors (such as household 

size or geographic region) as well as product class (within standard-size refrigerators 

or freezers).

• RECS respondents neither systematically overestimated nor underestimated the 

current age of their appliance.

• The historical shipment data are accurate.

• The shipped appliances are installed exclusively (or almost exclusively) in residences.

• The Weibull delay parameter, θ, is limited to between 1 and 5 years.

Three of these assumptions reflect analytical choices made by DOE. The first is the 

assumption that a Weibull distribution is the appropriate distribution to use for rates of appliance 

retirement. This distribution is the standard one used in lifetime analyses, but it is not guaranteed 

to reflect actual real-world experience. The second assumption is that consumer behavior and 

mechanical appliance lifetime have not changed over time. This assumption required DOE to 

treat equally all data from the several RECS surveys. Using only recent surveys (which may 

better reflect recent consumer behavior and appliance lifetime) would provide only a few data 

points for attempting least-squares fits, producing large statistical uncertainty.

The third assumption concerns the Weibull delay parameter. DOE limited the delay 

parameter to between 1 and 5 years to reflect the range of common appliance warranties. A delay 

of less than 1 year would imply that some appliances fail or are replaced within their first year of 

use. A delay of more than 5 years would imply that no appliances are replaced for some time 

after the end of the longest standard warranty. Fits using θ > 5 also commonly show 

nonsensical behavior, with sharp changes in consumer behavior or appliance survival 

immediately following the delay period.

8.2.3.2 Conversion of First to Second Refrigerators

When a household purchases a new refrigerator, sometimes it uses its original unit as a 

secondary appliance in the basement or garage. DOE modeled the process by which first 

refrigerators are converted to second refrigerators as a Weibull process having a cumulative 

distribution of the form:















 = + − × − 



 



 − −

e x

P x

β

α

θ

( ) δ (1 δ ) 1 for x > θ and

P(x) = δ for x ≤ θ
8-32

Where:

P(x) = probability that the appliance has been converted at age x;

x = appliance age;

α = the scale parameter, which would be the decay length in an exponential distribution;

β = the shape parameter, which determines the way in which the conversion rate changes 

through time;

δ = the percentage of shipments that are used immediately as second refrigerators; and

θ = the delay parameter, which allows for a delay before any conversions occur.

Rather than comparing second refrigerators to shipments, DOE compared them with the 

existing total installed base of refrigerators of a certain age, as measured by RECS. As with 

calculating appliance lifetime, the RECS data were adjusted with AHS data. In essence, DOE 

constructed a Weibull distribution to model a conversion function rather than a survival function. 

In addition, the model allows for the direct purchase of a new second refrigerator. A refrigerator 

bought to be a second refrigerator is modeled as being converted from first to second 

immediately at purchase; the offset parameter δ represents those units. Refrigerators commonly 

are bought to be second units, as indicated by the relatively large number of young second 

refrigerators reported by in RECS surveys.

DOE fit the conversion function using results from the 1990, 1993, 1997, 2001, and 2005 

RECS. The RECS micro-data again enabled removing refrigerators that are not standard size, 

which has a significant effect given that many compact refrigerators are used as second units. In 

Table 8.2.25 the fifth column shows the RECS-derived stock of second refrigerators by age bin, 

and the sixth column shows the best fit from a Weibull distribution. Figure 8.2.4 shows the 

Weibull distribution. The best-fit Weibull parameters for the conversion function are α = 38.12, 

β = 2.03, and θ = 0.0, with an offset of 5.6 percent (meaning that 5.6 percent of shipments are 

sold as new second refrigerators). Roughly 1.5 percent of surviving refrigerators are converted 

from first to second refrigerator status each year, and roughly 20 percent of surviving 

refrigerators are converted to second refrigerators before they reach 15 years of age.
8-33

Figure 8.2.4 Function for Conversion of First to Second Refrigerator-Freezers

8.2.3.3 Standard-Size Freezers

DOE assumed relatively simple consumer behavior related to freezers. DOE did not 

model the conversion from first to second freezer for households having more than one freezer, 

but simply used all freezer data from RECS. Standard-sized freezers were assumed to have a 

capacity greater than 10 cubic feet. As with refrigerators, RECS bins were adjusted for units 

replaced in the second half of a year to synchronize the RECS and shipments data. RECS did not 

collect freezer lifetime data in 1990, so DOE used results from only the 1993, 1997, 2001, and 

2005 surveys. The U.S. Census AHS survey does not report data on freezers, so the RECS bins 

were not scaled by the AHS total as for refrigerators. Before 2005, RECS reported the age 

distribution only for a household’s first freezer, so DOE assumed that second and third freezers 

have the same age distribution as first freezers.

The best-fit Weibull parameters for freezer lifetime are α = 19.49, β = 2.40, and θ = 

5.0. The resulting calculated mean freezer lifetime is 22.28 years; the median is 21.73 years. 

Table 8.2.26 lists the (adjusted) number of freezers reported in each RECS age bin, along with 

the modeled stock based on the best-fit Weibull survival function and the manufacturer-provided 

shipments history. Figure 8.2.5 shows the survival function used for standard-size freezers in the 

LCC and national impact analyses.

0.0

0.2

0.4

0.6

0.8

1.0

0 10 20 30 40 50

Age (years)

Fraction converted to 2nd refrigerator

Conversion function
8-34

Table 8.2.26 Standard-Size Freezers: Comparison of Survey and Shipments Stock to 

Modeled Stock 

RECS 2005

Age Bin years Shipments RECS Stock Modeled Stock

0–4 12,003,000 9,378,328 12,003,000

5–9 8,617,000 8,118,709 8,557,502

10–19 13,571,000 9,886,011 11,269,325

20 or more 47,672,000 7,607,227 6,973,305

RECS 2001

Age Bin years Shipments RECS Stock Modeled Stock

0–4 9,284,000 8,462,128 9,284,000

5–9 7,615,000 6,939,187 7,557,289

10–19 12,648,000 12,144,649 10,366,534

20 or more 42,528,000 7,494,606 7,817,703

RECS 1997

Age Bin years Shipments RECS Stock Modeled Stock

0–4 7,580,000 7,192,449 7,580,000

5–9 6,578,000 7,527,447 6,529,381

10–19 13,920,000 12,591,552 11,241,688

20 or more 36,203,000 6,561,157 8,045,004

RECS 1993

Age Bin years Shipments RECS Stock Modeled Stock

0–4 6,700,000 6,018,630 6,700,000

5–9 6,250,000 6,924,204 6,202,243

10–19 17,801,000 13,279,168 14,110,780

20 or more 27,388,000 8,277,900 6,374,921
8-35

Figure 8.2.5 Survival Function for Standard-Size Freezers 

8.2.3.4 Compact Refrigeration Products

As mentioned previously, compact refrigeration products are used in the residential and 

commercial sectors. RECS micro-data identify households that have refrigerators that are “halfheight” and less than 10 cubic feet in capacity. DOE considered those households as potentially 

using compact refrigerators. EIA’s Commercial Building Energy Consumption Survey (CBECS) 

survey of 20037 notes the presence of a residential-style refrigerator in an establishment. 

However, CBECS provides no further detail regarding the size of the refrigerator. Thus, RECS 

and CBECS data together do not provide enough detail on compact refrigerators to develop a 

survival function similar to the ones developed for standard-sized refrigerator-freezers and 

freezers. 

DOE assumed that a Weibull distribution remains the appropriate functional form to 

represent retirement rates of compact refrigeration products. DOE initially used the average 

value of lifetime and historical shipments data from Appliance magazine to estimate Weibull 

parameters for compact refrigerators. When DOE applied the average lifetime of 10 years, given 

in Appliance magazine, to historical shipments, the model yielded a stock of compact 

refrigerators that was more than double the stock indicated by RECS and CBECS. DOE

21.73

22.28

0.0

0.2

0.4

0.6

0.8

1.0

1.2

0 5 10 15 20 25 30 35 40 45 50

Age (years)

Fraction surviving

Survival function

Median lifetime

Mean lifetime
8-36

therefore calibrated the average lifetime to match the stock of compact refrigerators as reported 

by the surveys (see chapter 9 for further details).

The estimated Weibull parameters for compact refrigerator lifetime are α = 5.75 and β

= 1.75. The resulting calculated mean lifetime is 5.62 years. For determining the lifetime of 

compact freezers, DOE used a scaling factor proportional to the ratio of the lifetimes of standardsized refrigerators and standard-sized freezers. The calculated mean lifetime of a compact freezer 

is 7.46 years.

8.2.4 Discount Rates 

To discount future operating cost expenditures to establish their present value, DOE uses 

consumer (or customer) discount rates. DOE derived discount rates for the LCC and PBP 

analyses from estimates of the cost to finance purchase of the considered products. In addition to 

estimating discount rates for appliances bought directly by residential consumers, DOE also 

estimated discount rates for purchasers of compact refrigerators and freezers in the commercial 

sector.

8.2.4.1 Discount Rates for Residential Consumers

Households use various methods to finance the purchase of major appliances. In 

principle, one could estimate the interest rates on the actual financing vehicles used to purchase 

appliances. The frequency with which each financing vehicle is used to purchase an appliance is 

unknown, however. 

DOE’s approach involves identifying all possible debt or asset classes that might be used 

to purchase the considered appliances or that might be affected indirectly. An indirect effect 

would arise if a household sold assets in order to pay off a loan or credit card debt that might 

have been used to finance the appliance purchase. 

To develop a weighting for the debt or asset classes, DOE estimated the average 

percentage shares of the various types of debt and equity in the average U.S. household using 

data from the Federal Reserve Board’s Survey of Consumer Finances (SCF) for 1989, 1992, 

1995, 1998, 2001, 2004, and 2007.8 (The survey is conducted every three years.) DOE excluded 

debt from primary mortgages and assets considered non-liquid (such as retirement accounts), 

because the magnitude of these classes is great, and they are unlikely to be used for or affected 

by purchase of appliances. Table 8.2.27 shows the average percentages of each considered type 

of debt or equity in each survey, as well as the mean percentage of each source of financing 

throughout the 7 years surveyed. The mean shares are the basis for the weight given to each 

class.
8-37

Table 8.2.27 Percent of Total Value for Considered Household Debt and Equity Classes

Type of Debt or Equity 1989 % 1992 % 1995 % 1998 % 2001 % 2004 % 2007 % Mean %

Home equity loan 4.3 4.5 2.7 2.8 2.8 4.4 4.6 3.7

Credit card 1.6 2.1 2.6 2.2 1.7 2.0 2.4 2.1

Other installment loan 2.8 1.7 1.4 1.7 1.1 1.3 1.1 1.6

Other residential loan 4.4 6.9 5.2 4.3 3.1 5.8 7.1 5.3

Other line of credit 1.1 0.6 0.4 0.2 0.3 0.5 0.3 0.5

Checking account 5.8 4.7 4.9 3.9 3.6 4.2 3.4 4.4

Savings or money market 

account 19.2 18.8 14.0 12.8 14.2 15.1 13.0 15.3

Certificate of deposit 14.5 11.7 9.4 7.0 5.4 5.9 6.5 8.6

Savings bond 2.2 1.7 2.2 1.1 1.2 0.9 0.7 1.4

Bonds 13.8 12.3 10.5 7.0 7.9 8.4 6.7 9.5

Stocks 22.4 24.0 25.9 36.9 37.5 28.0 28.6 29.0

Mutual funds 8.0 11.1 20.9 20.1 21.3 23.4 25.5 18.6

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0

Sources: Federal Reserve Board. Survey of Consumer Finances (SCF) for 1989, 1992, 1995, 1998, 2001, 2004, and 

2007.

The source for interest rates for loans, credit cards, and lines of credit was the Federal 

Reserve Board’s SCF for 1989, 1992, 1995, 1998, 2001, 2004, and 2007. Table 8.2.28 shows the 

average nominal rates in each year and the inflation factors used to calculate real rates. DOE 

calculated effective interest rates for home equity loans by taking into account that interest on 

such loans is tax deductible. Table 8.2.29 shows the average effective real rates in each year and 

the mean rate across years. Because the interest rates for each type of household debt reflect 

economic conditions throughout numerous years, they are expected to be representative of rates 

that may be in effect in 2014. 

Table 8.2.28 Average Nominal Interest Rates for Household Debt 

Type of Debt 1989 % 1992 % 1995 % 1998 % 2001 % 2004 % 2007 % Mean %

Home equity loans 11.5 9.6 9.6 9.8 8.7 5.7 7.9% 9.0%

Credit cards* - - 14.2 14.5 14.2 11.7 12.6% 13.4%

Other installment loans 9.0 7.8 9.3 7.8 8.7 7.4 10.4% 8.6%

Other residential loans 8.8 7.6 7.7 7.7 7.5 6.0 6.3% 7.4%

Other line of credit 14.8 12.7 12.4 11.9 14.7 8.8 12.7% 12.6%

Inflation rate 4.82 3.01 2.83 1.56 2.85 2.66 2.85

Sources: Federal Reserve Board. Survey of Consumer Finances (SCF) for 1989, 1992, 1995, 1998, 2001, 2004, and 

2007.

* No data on interest rates available for credit cards in 1989 or 1992.
8-38

Table 8.2.29 Average Real Effective Interest Rates for Household Debt 

Type of Debt 1989 % 1992 % 1995 % 1998 % 2001 % 2004 % 2007 % Mean %

Home equity loans 3.8 4.3 4.4 5.8 3.8 1.9 3.3 3.9

Credit cards* - - 11.0 12.7 11.1 9.1 9.7 10.7

Other installment loans 4.9 5.8 7.0 6.6 6.1 5.4 5.8 6.0

Other residential loans 4.0 4.7 4.8 6.0 4.6 3.3 3.4 4.4

Other line of credit 9.6 9.4 9.3 10.2 7.3 6.0 9.7 8.8

Sources: Federal Reserve Board. Survey of Consumer Finances (SCF) for 1989, 1992, 1995, 1998, 2001, 

2004, and 2007.

* No data on interest rates available for credit cards in 1989 or 1992.

Rate data are not available from the SCF for classes of assets, so DOE derived a 

distribution of rates for each class from other sources. The interest rates associated with 

certificates of deposit,9 savings bonds,10 and bonds (AAA corporate bonds)11 were collected 

from Federal Reserve Board time-series data for 1977–2008. DOE assumed rates on checking 

accounts to be zero. Rates on savings and money market accounts came from Cost of Savings 

Index data covering 1984–2008.12 The rates for stocks are the annual returns on the Standard and 

Poor’s 500 for 1977–2008.13 Rates for mutual funds are a weighted average of the stock rates 

(two-thirds weight) and the bond rates (one-third weight) in each year for 1977–2008. DOE 

adjusted the nominal rates to real rates using the annual inflation rate for each year. 

Average nominal and real interest rates for the classes of household assets are listed in 

Table 8.2.30. Because the interest and return rates for each type of asset reflect economic 

conditions throughout numerous years, they are expected to be representative of rates that may 

be in effect in 2014.

Table 8.2.30 Average Nominal and Real Interest Rates for Household Equity 

Type of Equity Average Nominal Rate % Average Real Rate %

Checking accounts - 0.0

Savings and money market 5.4 2.2 

CDs 6.6 2.3 

Savings bonds 7.7 3.3 

Bonds 8.5 4.1

Stocks 11.6 7.1 

Mutual funds 10.3 5.8 

Table 8.2.31 summarizes the mean real effective rates of each type of equity or debt, and 

also shows the weights for each class derived from the SCF data. The average rate across all 

types of household debt and equity, weighted by the share of each type, is 5.1 percent.
8-39

Table 8.2.31 Average Interest on Household Debt and Equity 

Type of Debt or Equity

Average % of Household 

Debt plus Equity*

Mean Effective Real Rate 

%**

Home equity loan 3.7 3.0%

Credit card 2.1 3.9%

Other installment loan 1.6 10.7%

Other residential loan 5.3 6.0%

Other line of credit 0.5 4.4%

Checking account 4.4 0.0%

Savings and money market account 15.3 2.3%

Certificate of deposit 8.6 2.2%

Savings bond 1.4 3.4%

Bonds 9.5 4.1%

Stocks 29.0 7.7%

Mutual funds 18.6 6.2%

Total/weighted-average discount rate 100.0 5.1%

* Not including primary mortgage or retirement accounts.

** Adjusted for inflation and, for home equity loans, tax deduction of interest.

8.2.4.2 Assignment of Discount Rates to Sample Households

To account for variations among households, DOE assigned each sampled RECS 

household a rate from the distribution of rates developed for each type of debt and equity. 

Appendix 8-D presents the distributions that DOE used in the LCC and PBP analyses.

8.2.4.3 Discount Rates for Commercial Purchasers

DOE derived the discount rate for commercial-sector compact refrigeration products 

from the cost of capital of publicly-traded firms in the sectors that purchase those products 

(lodging and other commercial sectors).e The firms typically finance equipment purchases 

through debt and/or equity capital. DOE estimated the cost of the firms’ capital as the weighted 

average of the cost of equity financing and the cost of debt financing for each year between 2001 

and 2008. The costs of debt and equity financing are publicly available for firms in the sectors 

that purchase compact refrigeration products. 

DOE estimated the cost of equity using the capital asset pricing model (CAPM).14

 

e The “other commercial” sector includes financial institutions and all services other than lodging 

(SIC 6-8).

The 

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

risk faced by that company, whereby high risk is associated with a high cost of equity and low 

risk is associated with a low cost of equity. The systematic risk facing a firm is determined by 
8-40

several variables: the risk coefficient of the firm (β), the expected return on risk-free assets 

(Rf), and the equity risk premium (ERP). The risk coefficient of a firm describes the risk 

associated with that firm represented by standard deviations in the firm’s stock price. The 

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

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

To estimate the expected return on risk-free assets and the equity risk premium, DOE used stock 

and bond data from Damodaran Online, a widely used source of information about debt and 

equity financing for most types of firms. 15,16 The Damodaran Online data were adjusted for 

annual inflation using deflator data for the gross domestic product from the Bureau of Economic 

Analysis’ National Income and Product Accounts Tables.

17

The cost of equity financing is estimated using the following equation:

k R ( ERP) e = f + β ×

Where:

ke = cost of equity,

Rf = inflation-adjusted expected return on risk-free assets,f

β = risk coefficient of the firm, and

ERP = equity risk premium.

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

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

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

in the firm’s stock price. Thus for firm i, the cost of debt financing is:

di Rf Rai k = +

Where:

kd = cost of debt financing for firm i,

Rf = expected return on risk-free assets, and

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

DOE estimates the weighted-average cost of capital using the following equation.

e e d wd WACC = k ×w + k ×

Where:

WACC = weighted average cost of capital,

 

f Ibbotson Associates argues that the arithmetic mean equates the expected future value with the 

present value and should be used in calculating the risk-free rate and equity risk premium when 

using CAPM to estimate discount rates (Stocks, Bonds, Bills, and Inflation 2009 Yearbook, 

Ibbotson Associates, p. 60).
8-41

we = proportion of equity financing, and

wd = proportion of debt financing.

The values of the parameters used in the calculations are shown in Table 8.2.32.

Table 8.2.32 Data for Calculating Weighted-Average Cost of Capital for Commercial 

Sectors

Sector Year β Rf

%

ERP

%

Ra

%

we

%

wd

%

Lodging 

2001 1.18 3.25 5.17 1.50 88 12

2002 1.27 3.55 3.66 1.50 89 11

2003 1.71 3.40 4.70 1.25 93 7

2004 0.98 3.43 4.34 1.00 89 11

2005 1.45 3.36 4.08 1.25 93 7

2006 1.24 3.36 4.13 1.25 93 7

2007 1.25 3.54 4.33 1.00 96 4

2008 1.23 4.10 2.33 2.00 86 14

Other 

Commercial 

2001 0.87 3.25 5.17 3.50 77 23

2002 0.92 3.55 3.66 3.50 77 23

2003 0.87 3.40 4.70 1.50 81 19

2004 0.90 3.43 4.34 1.25 84 16

2005 0.88 3.36 4.08 1.50 82 18

2006 0.91 3.36 4.13 2.00 84 16

2007 0.87 3.54 4.33 1.25 79 21

2008 0.93 4.10 2.33 3.00 68 32

Note: Parameters are defined on the preceding two pages.

Using the procedure described above and the data in Table 8.2.32, DOE developed the 

real weighted-average cost of capital for the two commercial sectors that purchase compact 

refrigeration products. Those costs are listed in Table 8.2.33.
8-42

Table 8.2.33 Weighted-Average Cost of Capital for Commercial Sectors 

Year Lodging % Other Commercial %

2001 5.69 6.75

2002 5.11 6.21

2003 5.49 6.64

2004 5.82 6.62

2005 5.95 6.24

2006 6.04 6.46

2007 6.42 6.40

2008 5.74 5.60

Sector average 5.78 6.37

DOE developed a distribution of discount rates within each sector. The standard 

deviation of the distribution for each sector is provided in Table 8.2.34. Weighting each sector’s 

discount rate by its share of compact refrigerator purchases,g DOE estimated that the average 

discount rate for companies that purchase compact refrigeration products is 6.2 percent. 

Table 8.2.34 Discount Rates for Commercial Sectors

Sector

Discount Rate

Average % Max. % Min. % Standard Deviation % % of Purchases

Lodging 5.78 11.98 2.35 1.26 29

Other commercial 6.37 15.65 2.48 1.72 71

Weighted average 6.20 - - - 100

To account for variations in discount rates within each sector, DOE applied a normal 

probability distribution to the average values and standard deviations in Table 8.2.34. DOE 

truncated the normal distribution using the maximum and minimum values presented in Table 

8.2.34.

8.2.5 Compliance Date of Standard

The compliance date of a potential new standard is the date when it would become 

operative. Based on DOE’s implementation report for energy conservation standards activities 

submitted pursuant to section 141 of the Energy Policy Act of 2005, a final rule pertaining to the 

appliances being considered for this rulemaking is scheduled for December 2010.18

 

g The approach for estimating the share of total purchases by each of the two commercial sectors 

is described in chapter 9.

The 

compliance date of any new energy efficiency standards for the products is 3 years after the final 

rule is published, or January 2014. The Department calculated the LCC and PBP for all 

consumers as if each would purchase a new appliance in 2014. 
8-43

8.2.6 Base-Case Energy Efficiencies 

To estimate the percentage of consumers who would be affected by a standard at any of 

the potential efficiency levels, in its LCC analysis DOE considers the projected distribution of 

efficiencies for products that consumers purchase under the base case (the case without new 

energy efficiency standards). DOE refers to this distribution of product energy efficiencies as the 

base-case efficiency distribution. Using the projected distribution of efficiencies for each product 

class, DOE assigned a specific efficiency to each sample household. If a household is assigned 

an efficiency that is greater than or equal to the efficiency of the standard level under 

consideration, the LCC calculation would show that this household would not be affected by that 

standard level. 

DOE began with the distribution (market shares) of energy efficiency levels for 

refrigeration products in 2007 and, where available, 2008, based on data provided by AHAM 

(see Table 8.2.35).19 In 2007, efficiency level 2 for refrigerator-freezers (15 percent less energy 

use than the DOE standard) corresponded to the efficiency required for ENERGY STAR 

certification. In 2008, the criteria changed so that efficiency level 3 (20 percent less energy use 

than the DOE standard) corresponded to the efficiency required for ENERGY STAR 

certification. 

Efforts to promote ENERGY STAR refrigerator-freezers through various means, 

including consumer rebates, are expected to increase their market share by 2014. Although it is 

difficult to predict appliance sales in 2014, it is not unreasonable to assume that the increase in 

market shares of ENERGY STAR products will generally follow a similar pattern as it did in the 

period before 2008. However, because the ENERGY STAR efficiency level is higher than it was 

before, the growth in market share may be slower. Thus, DOE assumed that the projected market 

share of ENERGY STAR models in 2014 (under current requirements) is equal to the average of 

ENERGY STAR market shares in 2007 (under the old requirements) and 2008 (under current 

requirements). In this way, the ENERGY STAR market shares for product classes 3 and 5 grow 

more slowly between 2008 and 2014 than they had grown under the old requirements before 

2008. For product class 7, the method yields a slight decline in share because a large share of 

sales already qualified for ENERGY STAR in the first year of the current requirements (2008).
8-44

Table 8.2.35 Standard-Size Refrigerator-Freezers: Historic and Base-Case Efficiency 

Distributions

Product Class 3: 

Top-Mount Refrigerator-Freezer

Product Class 5:

Bottom-Mount Refrigerator-Freezer

Efficiency Level

(% less than 

baseline energy use)

Market Share

%

Efficiency Level

(% less than 

baseline energy use)

Market Share

%

2007 2008 2014 2007 2008 2014

Baseline 80.6 75.7 78.2 Baseline 11.8 14.2 13.0

1 (10) 5.9 2.4 4.2 1 (10) 0.1 0.0 0.1

2 (15) 13.2 18.7 9.4 2 (15) 69.8 38.6 19.3

3 (20)† 0.2 3.2 8.3 3 (20)† 18.3 47.2 67.7

4 (25) 0.0 0.0 0.0 4 (25) 0.0 0.0 0.0

5 (36) 0.0 0.0 0.0 5 (36) 0.0 0.0 0.0

Product Class 7: 

Side-by-Side Refrigerator-Freezer with TTD*

Efficiency Level

(% less than 

baseline energy use)

Market Share

%

2007 2008 2014

Baseline 25.0 18.4 21.7

1 (10) 43.0 9.7 26.4

2 (15) 30.3 30.1 15.0

3 (20)† 1.7 41.9 37.0

4 (25) 0.0 0.0 0.0

5 (33) 0.0 0.0 0.0

* Through-the-door ice service.

†

 Meets current (2008) ENERGY STAR criteria.

ENERGY STAR requirements for standard-size freezers and compact products were 

initiated in 2003, and have not changed since then. Those ENERGY STAR requirements 

correspond to efficiency level 1 for standard-size freezers and level 3 for compact products. 

Because the ENERGY STAR requirements for these products have not changed and because 

these products are less impacted by rebate programs than standard-size refrigerator-freezers, 

DOE assumed that the market shares of ENERGY STAR products would remain the same 

between 2007 (or, for product class 11, the average of 2007 and 2008)h

 

h 2008 AHAM data was only available for one product class (11).

and 2014 (Tables 8.2.36 

and 8.2.37).
8-45

Table 8.2.36 Standard-Size Freezers: Historic and Base-Case Efficiency Distributions

Product Class 9:

Upright Freezer

Product Class 10:

Chest Freezer

Efficiency Level

(% less than baseline 

energy use)

Market Share

%

Efficiency Level

(% less than 

baseline energy use)

Market Share

%

2007 2014 2007 2014

Baseline 81.5 81.5 Baseline 84.6 84.6

1 (10)* 17.0 17.0 1 (10)* 14.3 14.3

2 (15) 1.0 1.0 2 (15) 0.8 0.8

3 (20) 0.1 0.1 3 (20) 0.0 0.0

4 (25) 0.2 0.2 4 (25) 0.0 0.0

5 (30) 0.2 0.2 5 (30) 0.0 0.0

6 (35) 0.0 0.0 6 (35) 0.4 0.4

7 (40) 0.0 0.0 7 (41) 0.0 0.0

8 (44) 0.0 0.0

* Meets current ENERGY STAR criteria.
8-46

Table 8.2.37 Compact Refrigeration Products: Historic and Base-Case Efficiency 

Distributions

Product Class 11:

Compact Refrigerator

Product Class 18:

Compact Freezer

Efficiency Level

(% less than baseline 

energy use)

Market Share

%

Efficiency Level

(% less than baseline 

energy use)

Market Share

%

2007 2008 2014 2007 2014

Baseline 97.1 99.8 98.5 Baseline 95.4 95.4

1 (10) 0.3 0.2 0.3 1 (10) 4.6 4.6

2 (15) 0.0 0.0 0.0 2 (15) 0.0 0.0

3 (20)* 0.9 0.0 0.5 3 (20)* 0.0 0.0

4 (25) 0.2 0.0 0.1 4 (25) 0.0 0.0

5 (30) 1.5 0.0 0.8 5 (30) 0.0 0.0

6 (35) 0.0 0.0 0.0 6 (35) 0.0 0.0

7 (40) 0.0 0.0 0.0 7 (42) 0.0 0.0

8 (45) 0.0 0.0 0.0

9 (50) 0.0 0.0 0.0

10 (59) 0.0 0.0 0.0

Although RECS 2005 provides information on ownership of ENERGY STAR 

refrigerators purchased between 2001 and 2005, the data seem to greatly overestimate the stock 

of ENERGY STAR refrigerators compared to data regarding shipments made during those years. 

In assigning product efficiencies to the households in the sample for each product class, DOE 

therefore developed a method that predicts ENERGY STAR ownership in the RECS sample 

based on annual average market shares of ENERGY STAR refrigerators and on household 

income. DOE based its approach on a study from Natural Resources Canada20 that reported 

ENERGY STAR buyers based on three income categories. DOE assumed that the relative 

behavior of each income category is the same in the United States as for Canadian consumers. 

After matching the three income categories to RECS income bins, DOE assigned a probability of 

owning an ENERGY STAR unit to each household record as a function of its income. This 

probability was then scaled to reflect income levels in the RECS sample and national ENERGY 

STAR sales. The following equation was used.

Estaryear = scaleyear × (Flow × P _ Estarlow + Fmid × P _ Estarmid + Fhigh × P _ Estarhigh)

Where:

Estaryear = percent of annual national refrigerator sales that were ENERGY STAR 

qualified;
8-47

Flow|mid|high = percent of weighted number of RECS 2005 households in low, medium, 

and high income bins; 

P_Estarlow|mid|high = probability of households in an income bin buying an ENERGY STAR 

appliance; and

scaleyear = scaling factor to obtain the appropriate percent of ENERGY STAR 

refrigerators for each vintage.

Table 8.2.38 shows the market shares of ENERGY STAR refrigerators (Estaryear), which were 

obtained from the ENERGY STAR program.21 The market shares of ENERGY STAR freezers 

are estimates. 

Table 8.2.38 Market Share of ENERGY STAR Products

Year 1997 1998 1999 2000 2001 2002 2003 2004 2005

Refrigerators 25.3% 19.0% 25.0% 27.0% 17.3% 20.1% 25.7% 33.2% 32.9%

Freezers - - - - - - 10% 10% 10%

The scaling factor for each year was calculated as:

( low _ low mid _ mid high _ high)

year

year F P Estar F P Estar F P Estar

Estar scale

× + × + × =

A household in the low-income bin that purchased a refrigerator in a given year was a 

assigned a probability Scaleyear times P_Estarlow for having an ENERGY STAR refrigerator. A 

similar approach was taken for households in the mid- and-high income bins.

8.3 INPUTS TO PAYBACK PERIOD ANALYSIS 

The payback period (PBP) refers to the time it takes a consumer to recover, through 

lower operating costs, the assumed higher purchase cost of more energy efficient products. 

Numerically, the PBP is the ratio of the increase in purchase cost (from a less to a more efficient 

design) to the decrease in annual average operating cost. This calculation does not use a discount 

rate to discount future operating costs. 

The equation for determining PBP is:

OC

IC

PBP

∆

∆ =
8-48

Where:

ΔIC = the difference in total installed cost between the more efficient design based on a 

potential standard level and the base case product, and 

ΔOC = the difference in annual average operating cost between the two products. 

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

mean that the increase in total installed cost is not recovered through reduced operating cost.

The data inputs to calculating PBP are the total installed cost to the consumer for each 

product at each efficiency level and the average annual operating cost for each efficiency level. 

The inputs to calculating total installed cost are the product and installation costs. The inputs to 

calculating operating cost are the annual energy, repair, and maintenance costs. The annual 

average operating cost includes an annualized value for repair and maintenance costs. 

8.4 RESULTS OF ANALYSES 

This section presents the results of the life-cycle cost (LCC) and payback period (PBP) 

analyses for the considered efficiency levels for the representative refrigeration product classes. 

As discussed in section 8.1.1, DOE’s approach to the LCC analysis involved developing a 

sample of consumers who use each product. DOE also used probability distributions to 

characterize the uncertainty in many of the analytical inputs. DOE used a Monte Carlo 

simulation technique to perform the LCC calculations on data pertaining to the consumers in 

each sample. For each set of sample consumers who use the appliance in each product class, 

DOE calculated the average LCC, the LCC savings, and the median PBP for each standard level. 

LCC and PBP calculations were performed 10,000 times on the sample of consumers 

developed for each product. Each calculation was performed on a single consumer who was 

selected from the sample based on its weight in the RECS. Each LCC and PBP calculation also 

sampled from the probability distributions that DOE developed to characterize many of the 

inputs to the analysis. 

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

DOE calculated the percentage of consumers who would experience a net LCC benefit, a net 

LCC cost, or no impact. DOE considered a consumer to receive no impact at a given efficiency 

level if the base-case product DOE assigned to that consumer had the same or higher efficiency 

than that of the new standard being evaluated. Note that the average LCC savings and the median 

PBP at each efficiency level are relative to the base-case efficiency distribution, not the baseline 

efficiency level. For that reason, average LCC impacts are not equal to the difference between 

the LCC of a specific efficiency level and the LCC of the baseline product. DOE calculated the 

average LCC savings and median PBPs at each efficiency level by excluding those households 

that would not be affected by the standard.
8-49

The following subsections summarize results of the LCC and PBP analyses for each 

representative product class. Tables present average results. Figures show the distribution of 

LCC impacts and the distribution of PBPs (probabilities of occurrence) for specific efficiency 

levels. Other figures showing show the range of LCC savings and PBPs for all the efficiency 

levels considered for each product class. 

8.4.1 Standard-Size Refrigerator-Freezers

8.4.1.1 Summary of Results

Tables 8.4.1 through 8.4.3 show the LCC and PBP results for each standard-size 

refrigerator-freezer representative product class. 

Table 8.4.1 Product Class 3, Top-Mount Refrigerator-Freezers: LCC and PBP 

Results

Trial 

Standard 

Level

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $543 $750 $1,293

1 (10) $555 $696 $1,251 $42 1. 7% 21.6% 76.8% 2.7

2 (15) $563 $668 $1,231 $62 2.3% 17.4% 80.3% 3.0

1, 2 3 (20) $624 $640 $1,264 $29 42.3% 8.1% 49.6% 9.2

3 4 (25) $667 $605 $1,272 $22 54.9% 0.0% 45.1% 10.9

4 5 (30) $759 $571 $1,330 -$37 73.8% 0.0% 26.2% 15.4

5 6 (36) $892 $535 $1,427 -$133 85.4% 0.0% 14.6% 20.5

Table 8.4.2 Product Class 5, Bottom-Mount Refrigerator-Freezers: LCC and PBP 

Results

Trial 

Standard 

Level

Efficiency 

Level

(% less than 

baseline 

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating LCC

Average 

Savings 

% of Households that 

Experience Median
8-50

energy use) Cost 2009$ Net

Cost

No 

Impact

Net 

Benefit

Baseline $945 $917 $1,862

1 (10) $947 $908 $1,856 $8 0.2% 86.9% 12.9% 2.5

2 (15) $949 $904 $1,853 $12 0.3% 86.9% 12.9% 2.7

1, 2,3 3 (20) $955 $892 $1,847 $19 4.5% 67.8% 27.7% 4.9

4 (25) $1,020 $853 $1,873 -$8 75.0% 0.0% 25.0% 17.5

4 5 (30) $1,127 $817 $1,945 -$79 88.2% 0.0% 11.8% 24.8

5 6 (36) $1,276 $770 $2,046 -$180 93.3% 0.0% 6.7% 29.0

Table 8.4.3 Product Class 7, Side-by-Side Refrigerator-Freezers with Through-theDoor Ice Service: LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $1,152 $1,178 $2,330

1 (10) $1,155 $1,156 $2,310 $20 0.1% 78.1% 21.8% 1.5

2 (15) $1,160 $1,132 $2,292 $40 0.5% 51.7% 47.8% 2.4

1 3 (20) $1,179 $1,100 $2,279 $53 7.3% 36.9% 55.8% 4.8

2, 3 4 (25) $1,244 $1,051 $2,295 $37 50.8% 0.0% 49.2% 10.9

4 5 (30) $1,385 $1,002 $2,387 -$55 77.7% 0.0% 22.3% 18.6

5 6 (33) $1,496 $970 $2,466 -$134 86.2% 0.0% 13.9% 22.6

8.4.1.2 Distributions of Impacts 

Figure 8.4.1 presents a frequency chart that shows the distribution of LCC impacts for the 

case of efficiency level 4 for top-mount refrigerator-freezers. DOE could generate a similar 

frequency chart for every efficiency level.
8-51

Figure 8.4.1 Product Class 3, Top-Mount Refrigerator-Freezers: Distribution of 

Life-Cycle Cost Impacts for Efficiency Level 4 

Figure 8.4.2 is an example of a frequency chart showing the distribution of payback 

periods for efficiency level 4 for top-mount refrigerator-freezers. DOE could generate a similar 

frequency chart for every efficiency level.

Figure 8.4.2 Product Class 3, Top-Mount Refrigerator-Freezers: Distribution of 

Payback Periods for Efficiency Level 4 

Figures 8.4.3 through 8.4.5 show the range of LCC savings for all the efficiency levels 

considered for each refrigerator-freezer product class. For each efficiency level, the top and 

bottom of the box in the figure indicate the 75th and 25th percentiles, respectively. The bar at the 

middle of the box indicates the median: 50 percent of households have LCC savings that exceed 

this value. The horizontal lines above and below each box indicate the 95th and 5th percentiles, 

respectively. The small box indicates the average LCC savings for each efficiency level. 
8-52

Figure 8.4.3 Product Class 3, Top-Mount Refrigerator-Freezers: Range of Life-Cycle 

Cost Savings by Efficiency Level 

Figure 8.4.4 Product Class 5, Bottom-Mount Refrigerator-Freezers: Range of LifeCycle Cost Savings by Efficiency Level 

Life-Cycle Cost Savings

-350

-300

-250

-200

-150

-100

-50

0

50

100

150

200

1 2 3 4 5 6

Efficiency Level

 ($2009

25% 75%

Median Average

Life-Cycle Cost Savings

-300

-250

-200

-150

-100

-50

0

50

100

150

1 2 3 4 5 6

Efficiency Level

($2009

Median

Average
8-53

Figure 8.4.5 Product Class 7, Side-by-Side Refrigerator-Freezers: Range of Life-Cycle 

Cost Savings by Efficiency Level 

Figures 8.4.6 through 8.4.8 show the range of PBPs for all efficiency levels considered 

for each analyzed refrigerator-freezer product class. For each efficiency level, the top and bottom 

of the box in the figure indicate the 75th and 25th percentiles, respectively. The bar at the middle 

of the box indicates the median: 50 percent of the households have a PBP above this value. The 

horizontal lines above and below each box indicate the 95th and 5th percentiles, respectively. The 

small box indicates the average PBP for each efficiency level. 

Figure 8.4.6 Product Class 3, Top-Mount Refrigerator-Freezers: Range of Payback 

Periods by Efficiency Level 

-300

-200

-100

0

100

200

300

1 2 3 4 5 6

Cost ($2009)

Efficiency Level

Life-Cycle Cost Savings

75%

Media

n

Payback Period

0

10

20

30

40

50

60

1 2 3 4 5 6

Efficiency Level

Years

75%

Median

25%

Mean
8-54

Figure 8.4.7 Product Class 5, Bottom-Mount Refrigerator-Freezers: Range of Payback 

Periods by Efficiency Level 

Payback Period

0

10

20

30

40

50

60

70

80

1 2 3 4 5 6

Efficiency Level

Years

25% Median

75% Mean

Payback Period

0

10

20

30

40

50

60

1 2 3 4 5 6

Efficiency Level

Years

75%

Median

25%

Mean
8-55

Figure 8.4.8 Product Class 7, Side-by-Side Refrigerator-Freezers: Range of Payback 

Periods by Efficiency Level 

8.4.2 Standard-Size Freezers

8.4.2.1 Summary of Results

Tables 8.4.4 and 8.4.5 show the LCC and PBP results for each representative standardsize freezer product class. 

Table 8.4.4 Product Class 9, Upright Freezers: LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $560 $969 $1,529

1 (10) $571 $897 $1,468 $62 1.7% 19.9% 78.5% 2.3

2 (15) $592 $852 $1,445 $85 9.7% 1.7% 88.6% 4.3

1 3 (20) $611 $807 $1,418 $111 11.7% 0.6% 87.8% 4.8

4 (25) $640 $760 $1,401 $128 16.2% 0.4% 83.4% 5.8

2 5 (30) $667 $714 $1,381 $148 18.7% 0.2% 81.1% 6.2

3 6 (35) $727 $673 $1,399 $130 30.8% 0.0% 69.2% 8.4

4 7 (40) $810 $632 $1,442 $87 45.0% 0.0% 55.0% 11.0

5 8 (44) $994 $599 $1,593 -$63 70.2% 0.0% 29.8% 17.4

Table 8.4.5 Product Class 10, Chest Freezer: LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $407 $578 $985
8-56

1 (10) $414 $533 $946 $38 0.0% 16.2% 83.8% 2.1

2 (15) $424 $506 $930 $55 0.7% 1.2 98.1% 3.4

1 3 (20) $436 $479 $915 $70 1.6% 0.2% 98.2% 4.2

2 4 (25) $483 $451 $935 $50 25.8% 0.2% 74.0% 8.7

3 5 (30) $504 $424 $928 $56 28.3% 0.2% 71.5% 9.1

4 6 (35) $565 $404 $968 $17 53.5% 0.0% 46.5% 13.1

5 7 (41) $687 $369 $1,055 -$71 79.0% 0.0% 21.0% 19.3

8.4.2.2 Distributions of Impacts 

Figure 8.4.9 presents a frequency chart showing the distribution of LCCs for the case of 

standard level 7 for upright freezers. DOE could generate a similar frequency chart for every 

efficiency level.

Figure 8.4.9 Product Class 9, Upright Freezers: Distribution of Life-Cycle Cost 

Impacts for Efficiency Level 7 

Figure 8.4.10 presents a frequency chart showing the distribution of payback periods for 

standard level 7 for upright freezers. DOE could generate a similar frequency chart for every 

efficiency level within each product class.
8-57

Figure 8.4.10 Product Class 9, Upright Freezers: Distribution of Payback 

Periods for Efficiency Level 7 

Figures 8.4.11 and 8.4.12 show the range of LCC savings for the efficiency levels 

considered for each freezer product class. For each standard level, the top and bottom of the box 

indicate the 75th and 25th percentiles, respectively. The bar at the middle of the box indicates the 

median: 50 percent of the households have LCC savings that exceed this value. The horizontal 

lines above and below the box indicate the 95th and 5th percentiles, respectively. The small box 

shows the average LCC savings for each efficiency level. 

Life-Cycle Cost Savings

-400

-200

0

200

400

600

800

1 2 3 4 5 6 7 8

Efficiency Level

Cost ($2009)

75%

Median

25%

Mean
8-58

Figure 8.4.11 Product Class 9, Upright Freezers: Range of Life-Cycle Cost Savings by 

Efficiency Level 

Figure 8.4.12 Product Class 10, Chest Freezers: Range of Life-Cycle Cost Savings by 

Efficiency Level 

Figures 8.4.13 and 8.4.14 show the range of PBPs for the efficiency levels considered for 

each freezer product class. For each standard level, the top and bottom of the box indicate the 

75th and 25th percentiles, respectively. The bar at the middle of the box indicates the median: 50 

percent of the households have PBPs that exceed this value. The horizontal lines above and 

below the box indicate the 95th and 5th percentiles, respectively. The small box shows the 

average PBP for each efficiency level. 

Life-Cycle Cost Savings

-250

-200

-150

-100

-50

0

50

100

150

200

250

1 2 3 4 5 6 7

Efficiency Level

Cost ($2009)

75%

Median

25%

Mean
8-59

Figure 8.4.13 Product Class 9, Upright Freezers: Range of Payback Periods by 

Efficiency Level

Figure 8.4.14 Product Class 10, Chest Freezers: Range of Payback Periods by 

Efficiency Level 

Payback Period

0

10

20

30

40

50

60

1 2 3 4 5 6 7 8

Efficiency Level

Years

75%

Median

25%

Mean

Payback Period

0

5

10

15

20

25

30

35

1 2 3 4 5 6 7

Efficiency Level

Years
8-60

8.4.3 Compact Refrigeration Products

8.4.3.1 Summary of Results

Tables 8.4.6 and 8.4.7 show the results of LCC and PBP analyses for compact 

refrigerators and freezers. 

Table 8.4.6 Product Class 11, Compact Refrigerators: LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $146 $165 $311

1 (10) $151 $150 $301 $10 11.9% 1.6% 86.5% 2.0

2 (15) $156 $142 $297 $13 17.0% 1.4% 81.6% 2.3

1 3 (20) $162 $134 $296 $15 24.4% 1.4% 74.2% 2.8

2 4 (25) $174 $126 $300 $10 43.3% 1.0% 55.7% 3.9

3 5 (30) $184 $118 $302 $8 50.6% 0.9% 48.5% 4.4

6 (35) $212 $111 $324 -$13 77.2% 0.0% 22.8% 6.7

4 7 (40) $221 $103 $324 -$13 76.1% 0.0% 23.9% 6.5

8 (45) $255 $97 $351 -$41 87.4% 0.0% 12.6% 8.6

9 (50) $274 $88 $362 -$51 88.8% 0.0% 11.2% 9.0

5 10 (59) $341 $75 $416 -$105 93.8% 0.0% 6.2% 11.6

Table 8.4.7 Product Class 18, Compact Freezers: LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $202 $200 $402

1,2 1 (10) $209 $182 $391 $11 9.9% 4.7% 85.4% 2.5
8-61

3 2 (15) $223 $172 $395 $7 40.6% 0.0% 59.4% 4.6

3 (20) $268 $163 $430 -$29 91.1% 0.0% 8.9% 10.9

4 4 (25) $279 $153 $432 -$30 88.5% 0.0% 11.5% 10.0

5 (30) $312 $146 $458 -$57 94.6% 0.0% 5.4% 12.6

6 (35) $320 $137 $457 -$55 92.7% 0.0% 7.3% 11.5

5 7 (42) $399 $124 $523 -$121 97.8% 0.0% 2.3% 15.9

8.4.3.2 Distributions of Impacts 

Figure 8.4.15 presents a frequency chart showing the distribution of LCCs for the case of 

efficiency level 5 for compact refrigerators. DOE could generate a similar frequency chart for 

each efficiency level. 

Figure 8.4.15 Product Class 11, Compact Refrigerators: Distribution of Life-Cycle Cost 

Impacts for Efficiency Level 5 

Figure 8.4.16 presents a frequency chart showing the distribution of payback periods for 

efficiency level 5 for compact refrigerators. DOE could generate a similar frequency chart for 

each considered efficiency level for each product class.
8-62

Figure 8.4.16 Product Class 11, Compact Refrigerators: Distribution of 

Payback Period for Efficiency Level 5 

Figures 8.4.17 and 8.4.18 show the range of LCC savings for the standard levels 

considered for compact refrigerators and freezers. For each standard level, the top and bottom of 

the box indicate the 75th and 25th percentiles, respectively. The bar at the middle of the box 

indicates the median: 50 percent of the households have LCC savings that exceed this value. The 

horizontal lines above and below the box indicate the 95th and 5th percentiles, respectively. The 

small box shows the average LCC savings for each efficiency level. Figures 8.4.19 and 8.4.20 

show the range of PBPs for each efficiency level considered.
8-63

Figure 8.4.17 Product Class 11, Compact Refrigerators: Range of Life-Cycle Cost 

Savings by Efficiency Level 

Figure 8.4.18 Product Class 18, Compact Freezers: Range of Life-Cycle Cost Savings 

by Efficiency Level 

Figures 8.4.19 and 8.4.20 show the range of PBPs for the standard levels considered for 

compact refrigerators and freezers. For each standard level, the top and bottom of the box 

Life-Cycle Cost Savings

-200

-150

-100

-50

0

50

100

1 2 3 4 5 6 7 8 9 10

Efficiency Level

Cost ($2009)

75%

Median

25%

Mean

Life-Cycle Cost Savings

-200

-150

-100

-50

0

50

1 2 3 4 5 6 7

Efficiency Level

Cost ($2009)

75%

Median

25%

Mean
8-64

indicate the 75th and 25th percentiles, respectively. The bar at the middle of the box indicates the 

median: 50 percent of the households have PBPs that exceed this value. The horizontal lines 

above and below the box indicate the 95th and 5th percentiles, respectively. The small box shows 

the average PBP for each efficiency level. 

Figure 8.4.19 Product Class 11, Compact Refrigerators: Range of Payback Periods by 

Efficiency Level

Payback Period

0

2

4

6

8

10

12

14

16

1 2 3 4 5 6 7 8 9 10

Efficiency Level

Years

75%

Median

25%

Mean
8-65

Figure 8.4.20 Product Class 18, Compact Freezers: Range of 

Payback Periods by Efficiency Level 

8.4.4 Built-In Refrigeration Products

8.4.4.1 Summary of Results

Tables 8.4.8 through 8.4.11 show the results of LCC and PBP analyses for the 

representative built-in refrigeration product classes.

Table 8.4.8 Product Class 3A-BI, Built-In All Refrigerators: LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $4,676 $776 $5,451

1 1 (10) $4,683 $721 $5,404 $47 0.3% 22.6% 77.2% 1.6

2 2 (15) $4,696 $693 $5,388 $63 2.6% 18.4% 79.0% 3.0

3 3 (20) $4,826 $660 $5,486 -$34 69.1% 9.1% 21.9% 15.9

Payback Period

0

5

10

15

20

25

1 2 3 4 5 6 7

Efficiency Level

Years
8-66

4 4 (25) $5,017 $629 $5,646 -$195 94.5% 0.0% 5.5% 29.7

5 5 (29) $5,162 $607 $5,769 -$318 97.2% 0.0% 2.8% 36.7

Table 8.4.9 Product Class 5-BI, Built-In Bottom-Mount Refrigerator-Freezers: LCC 

and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $5,386 $908 $6,294

1 1 (10) $5,390 $899 $6,289 $7 1.2% 87.1% 11.7% 4.4

2,3 2 (15) $5,401 $906 $6,307 $0 8.2% 87.0% 4.8% 12.9

3 (20) $5,435 $892 $6,328 -$21 29.3% 67.5% 3.3% 26.2

4 4 (25) $5,607 $864 $6,471 -$164 99.0% 0.0% 1.1% 62.8

5 5 (27) $5,706 $845 $6,551 -$244 99.3% 0.0% 0.7% 61.8

Table 8.4.10 Product Class 7-BI, Built-In Side-by-Side Refrigerator-Freezers with 

Through-the-Door Ice Service: LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $7,887 $1,293 $9,180

1,2 1 (10) $7,902 $1,276 $9,178 $7 8.0% 78.5% 13.5% 8.7

2 (15) $7,947 $1,261 $9,208 -$18 39.8% 52.4% 7.8% 21.0

3,4 3 (20) $8,078 $1,228 $9,306 -$116 60.2% 37.2% 2.5% 36.7

5 4 (22) $8,197 $1,211 $9,409 -$219 98.8% 0.0% 1.2% 60.0
8-67

Table 8.4.11 Product Class 9-BI, Built-In Upright Freezers: LCC and PBP Results

Trial 

Standard 

Level

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $4,383 $947 $5,330

1 1 (10) $4,400 $876 $5,276 $54 4.3% 19.9% 75.8% 3.4

2 (15) $4,415 $834 $5,249 $82 8.6% 1.7% 89.7% 4.3

2 3 (20) $4,509 $797 $5,306 $24 53.1% 0.6% 46.3% 12.8

3,4 4 (25) $4,657 $752 $5,409 -$78 78.2% 0.5% 21.3% 21.1

5 5 (27) $4,770 $730 $5,500 -$169 87.1% 0.3% 12.6% 26.8

8.4.4.2 Distributions of Impacts 

Figure 8.4.21 presents a frequency chart showing the distribution of LCCs for the case of 

efficiency level 1 for built-in side-by-side refrigerator-freezers. DOE could generate a similar 

frequency chart for every efficiency level. 

Figure 8.4.21 Product Class 7-BI, Built-In Side-by-Side 

Refrigerator-Freezers: Distribution of Life-Cycle 

Cost Impacts for Efficiency Level 1 
8-68

Figure 8.4.22 presents a frequency chart showing the distribution of payback periods for 

efficiency level 1 for built-in side-by-side refrigerator-freezers. DOE could generate a similar 

frequency chart for every efficiency level within each product class.

Figure 8.4.22 Product Class 7-BI, Built-In Side-by-Side RefrigeratorFreezers: Distribution of Payback Period for Efficiency Level 1 

Figures 8.4.23 through 8.4.30 show the range of LCC savings for the efficiency levels 

considered for built-in refrigeration products. For each efficiency level, the top and bottom of the 

box indicate the 75th and 25th percentiles, respectively. The bar at the middle of the box indicates 

the median: 50 percent of the households have LCC savings that exceed this value. The 

horizontal lines above and below the box indicate the 95th and 5th percentiles, respectively. The 

small box shows the average LCC savings for each efficiency level. Figures 8.4.19 through 

8.4.20 show the range of PBPs for each efficiency level considered.
8-69

Figure 8.4.23 Product Class 3A-BI, Built-In All Refrigerators: 

Range of Life-Cycle Cost Savings by Efficiency 

Level

Figure 8.4.24 Product Class 5-BI, Built-In Bottom-Mount 

Refrigerator-Freezers: Range of Life-Cycle Cost 

Savings by Efficiency Level

-500

-400

-300

-200

-100

0

100

200

1 2 3 4 5

Cost ($2009)

Efficiency Level

Life-Cycle Cost Savings

75%

Median

25%

Mean

-400

-350

-300

-250

-200

-150

-100

-50

0

50

100

1 2 3 4 5

Cost ($2009)

Efficiency Level

Life-Cycle Cost Savings

75%

Median

25%

Mean
8-70

Figure 8.4.25 Product Class 7-BI, Built-In Side-by-Side 

Refrigerator-Freezers with Through-the-Door Ice 

Service: Range of Life-Cycle Cost Savings by 

Efficiency Level

-450

-400

-350

-300

-250

-200

-150

-100

-50

0

50

100

1 2 3 4

Cost ($2009)

Efficiency Level

Life-Cycle Cost Savings

75%

Median

25%

Mean

-400

-300

-200

-100

0

100

200

300

1 2 3 4 5

Cost ($2009)

Efficiency Level

Life-Cycle Cost Savings

75%

Median

25%

Mean
8-71

Figure 8.4.26 Product Class 9-BI, Built-In Upright Freezers: 

Range of Life-Cycle Cost Savings by Efficiency 

Level

Figure 8.4.27 Product Class 3A-BI, Built-In All Refrigerators: 

Range of Payback Periods by Efficiency Level

0

20

40

60

80

100

120

1 2 3 4 5

Years

Efficiency Level

Payback Period

75%

Median

25%

Mean
8-72

Figure 8.4.28 Product Class 5-BI, Built-In Bottom-Mount 

Refrigerator-Freezers: Range of Payback Periods by 

Efficiency Level

0

50

100

150

200

250

300

1 2 3 4 5

Years

Efficiency Level

Payback Period

75%

Median

25%

Mean

0

20

40

60

80

100

120

140

160

180

1 2 3 4

Years

Efficiency Level

Payback Period
8-73

Figure 8.4.29 Product Class 7-BI, Built-In Side-by-Side 

Refrigerator-Freezers with Through-the-Door Ice 

Service: Range of Payback Periods by Efficiency 

Level

Figure 8.4.30 Product Class 9-BI, Built-In Upright Freezers: 

Range of Payback Periods by Efficiency Level

8.5 REBUTTABLE PAYBACK PERIOD

DOE presents rebuttable PBPs to provide information for considering the legally 

established rebuttable presumption that an energy efficiency standard is economically justified if 

the additional product costs attributed to the standard are less than three times the value of the 

first-year savings in energy costs. (42 U.S.C. §6295 (o)(2)(B)(iii))

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

Analysis of Payback Period. Unlike the analyses described in sections 8.2 and 8.3, however, the 

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

Rather, it is based on discrete, single-point values. For example, although DOE uses a probability 

distribution of regional energy prices in the analysis of payback period, it uses only the national 

0

10

20

30

40

50

60

70

80

90

100

1 2 3 4 5

Years

Efficiency Level

Payback Period

75%

Median

25%

Mean
8-74

average energy price to determine the rebuttable PBP. DOE calculated rebuttable PBPs for each 

standard level relative to the purchase and operating costs of an average baseline product.

Other than the use of single-point values, the key difference between the distribution PBP 

and the rebuttable PBP is the latter’s reliance on the DOE test procedure to determine a product’s 

annual energy consumption. 

8.5.1 Results

Table 8.5.1 through Table 8.5.4 present the rebuttable PBPs for each group of 

refrigeration products.

Table 8.5.1 Standard-Size Refrigerator-Freezers: Rebuttable Payback Periods

Product Class 3: 

Top-Mount RefrigeratorFreezer

Product Class 5: 

Bottom-Mount RefrigeratorFreezer

Product Class 7: 

Side-by-Side Refrigerator-Freezer 

with TTD*

Efficiency Level

(% less than baseline 

energy use)

PBP

years

Efficiency Level

(% less than baseline 

energy use)

PBP

years

Efficiency Level

(% less than baseline 

energy use)

PBP

years

1 (10) 2.4 1 (10) 2.1 1 (10) 1.4

2 (15) 2.6 2 (15) 2.4 2 (15) 1.7

3 (20) 7.3 3 (20) 3.1 3 (20) 2.9

4 (25) 8.5 4 (25) 5.9 4 (25) 5.1

5 (30) 12.0 5 (30) 9.6 5 (30) 9.4

6 (36) 16.1 6 (36) 13.3 6 (33) 12.2

*Through-the-door ice service.
8-75

Table 8.5.2 Standard-Size Freezers: Rebuttable Payback Periods

Product Class 9: 

Upright Freezer

Product Class 10: 

Chest Freezer

Efficiency Level

(% less than baseline 

energy use)

PBP

years

Efficiency Level

(% less than baseline 

energy use)

PBP

years

1 (10) 1.9 1 (10) 1.8

2 (15) 3.3 2 (15) 2.7

3 (20) 3.8 3 (20) 3.3

4 (25) 4.7 4 (25) 6.9

5 (30) 5.1 5 (30) 7.3

6 (35) 6.8 6 (35) 10.0

7 (40) 8.8 7 (39) 14.9

8 (43) 13.9

Table 8.5.3 Compact Refrigeration Products: Rebuttable Payback Periods

Product Class 11: 

Compact Refrigerator

Product Class 18: 

Compact Freezer

Efficiency Level

(% less than baseline 

energy use)

PBP

years

Efficiency Level

(% less than baseline 

energy use)

PBP

years

1 (10) 1.8 1 (10) 2.0

2 (15) 2.1 2 (15) 3.8

3 (20) 2.5 3 (20) 9.0

4 (25) 3.6 4 (25) 8.4

5 (30) 4.0 5 (30) 10.0

6 (35) 5.9 6 (35) 9.2

7 (40) 5.7 7 (42) 12.9

8 (45) 7.4

9 (50) 7.8

10 (59) 8.5
8-76

Table 8.5.4 Built-In Refrigeration Products: Rebuttable Payback Periods

Product Class 3A-BI:

Built-in All 

Refrigerator

Product Class 5-BI:

Built-In Bottom-Mount 

Refrigerator-Freezer

Product Class 7-BI:

Built-In Side-by-Side 

Refrigerator-Freezer 

with TTD*

Product Class 9-BI:

Built-In Upright Freezer

Efficiency 

Level

(% less than 

baseline 

energy use)

PBP

years

Efficiency 

Level

(% less than 

baseline 

energy use)

PBP

years

Efficiency 

Level

(% less than 

baseline 

energy use)

PBP

years

Efficiency 

Level

(% less than 

baseline 

energy use)

PBP

years

1 (10) 1.5 1 (10) 3.8 1 (10) 7.4 1 (10) 2.7

2 (15) 2.6 2 (15) 10.2 2 (15) 11.9 2 (15) 3.1

3 (20) 13.1 3 (20) 14.8 3 (20) 20.4 3 (20) 8.4

4 (25) 22.5 4 (25) 21.1 4 (22) 25.0 4 (25) 14.3

5 (29) 27.4 5 (27) 24.3 5 (27) 18.4
8-77

REFERENCES

 1 U.S. Department of Energy–Energy Information Administration. Residential Energy 

Consumption Survey, 2005 Public Use Data Files. 2009. U.S. Department of Energy: 

Washington, D.C. <www.eia.doe.gov/emeu/recs/recspubuse05/pubuse05.html>

2 The NPD Group, Inc., The NPD Group/NPD Houseworld – POS, Refrigerators, January –

December 2007, 2007. Port Washington, NY.

3 Association of Home Appliance Manufacturers. Aggregated Refrigerator‐Freezer 

Incremental Cost Data for DOE Refrigerator‐Freezer Energy Efficiency Standards 

Rulemaking, March 2, 2009. Memo to Detlef Westphalen, Navigant Consulting, Inc.

4

 U.S. Department of Energy–Energy Information Administration. Form EIA-861. 

Washington, D.C. <www.eia.doe.gov/cneaf/electricity/page/eia861.html> 

5 U.S. Department of Energy–Energy Information Administration. Annual Energy 

Outlook 2010 with Projections to 2035. April 2010. U.S. DOE–EIA: Washington, D.C. 

DOE/EIA-0383(2010).

6 U.S. Census Bureau, Housing and Household Economic Statistics Division. American 

Housing Survey. Washington, DC. 

<http://www.census.gov/hhes/www/housing/ahs/ahs.html> 

7 U.S. Department of Energy–Energy Information Administration. Commercial Building

Energy Consumption Survey, 2003 Public Use Data Files. 2008. U.S. Department of Energy: 

Washington, D.C. 

<http://www.eia.doe.gov/emeu/cbecs/cbecs2003/public_use_2003/cbecs_pudata2003.ht

ml>

8

 The Federal Reserve Board. Survey of Consumer Finances. 1989, 1992, 1995, 1998, 2001, 

and 2004. <www.federalreserve.gov/pubs/oss/oss2/scfindex.html>

9

 The Federal Reserve Board. Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: CDs (secondary market), Maturity: 6-month, Frequency: 

Annual, Description: Average rate on 6-month negotiable certificates of deposit (secondary 

market), quoted on an investment basis. 2009. Washington, D.C. 

<www.federalreserve.gov/releases/H15/data.htm>

10 The Federal Reserve Board. Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: State and local bonds, Maturity: 20-year, Frequency: Monthly, 

Description: Bond buyer go 20-bond municipal bond index. 2009. Washington, D.C. 

<www.federalreserve.gov/releases/H15/data.htm>
8-78

 11 The Federal Reserve Board. Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: Corporate bonds/Moody’s Seasoned AAA, Frequency: Annual, 

Description: Moody’s yield on seasoned corporate bonds—all industries, AAA. 2009. 

Washington, D.C. <www.federalreserve.gov/releases/H15/data.htm>

12 Mortgage-X, Mortgage Information Service. Cost of Savings Index (COSI), Index History. 

2009. <http://mortgage-x.com/general/indexes/default.asp> (Last accessed, February 25, 

2009.)

13 Damodaran Online. The Data Page: Historical Returns on Stocks, Bonds, and Bills—United 

States. 2009. <http://pages.stern.nyu.edu/~adamodar/> 

14 Ibbotsons Associates. SBBI Valuation Edition 2009 Yearbook. 2009. Chicago, IL. pp. 45–48.

15 Damodaran Online. The Data Page: Cost of Capital by Industry Sector. 2001–2008. 

<http://pages.stern.nyu.edu/~adamodar/>

16 Damodaran Online. The Data Page: Historical Returns on Stocks, Bonds and Bills—United 

States. <http://pages.stern.nyu.edu/~adamodar/>

17 Bureau of Economic Analysis–National Income and Product Accounts Tables. Table 1.1.9. 

Implicit Price Deflators for Gross Domestic Product.

<www.bea.gov/national/nipaweb/SelectTable.asp?Selected=N>

18 U.S. Department of Energy. Implementation Report: Energy Conservation Standards 

Activities. Submitted Pursuant to Section 141 of the Energy Policy Act of 2005. August 2006. 

Washington, D.C. 

<www.eere.energy.gov/buildings/appliance_standards/pdfs/implementation_report_0806.pdf

> 

19 Association of Home Appliance Manufacturers. Aggregated Refrigerator‐Freezer 

Shipments and Efficiency Data for DOE Refrigerator‐Freezer Energy Efficiency Standards 

Rulemaking, January 16, 2009. Memo to Detlef Westphalen, Navigant Consulting, Inc.

20 Ipsos-Reid Corporation. Tracking Study: Awareness of ENERGY STAR/EnerGuide 

Symbols Final Report. Natural Resources Canada. September 2006

21 Karney, R. ENERGY STAR Criteria for Refrigerators: Overview of ENERGY STAR

Criteria Setting Process and History of Refrigerator Criteria. June 4, 2007. (Last accessed 

April 15, 2009.) 

<www.energystar.gov/ia/partners/prod_development/revisions/downloads/refri

g/Karney_RefrigeratorCriteriaRevision_6.4.07.pdf> 
9-i

CHAPTER 9. SHIPMENTS ANALYSIS

TABLE OF CONTENTS

9.1 INTRODUCTION ........................................................................................................... 9-1

9.2 SHIPMENTS MODEL GENERAL METHODOLOGY ................................................ 9-1

9.2.1 Stock Accounting Approach............................................................................................ 9-2

9.2.2 Market Segments ............................................................................................................. 9-2

9.3 PRODUCT-SPECIFIC MODELS................................................................................... 9-3

9.3.1 Standard-Size Refrigerator-Freezers................................................................................ 9-4

9.3.1.1 Market Segments ........................................................................................... 9-4

9.3.1.2 Disaggregation into Refrigerator-Freezer Product Classes............................ 9-7

9.3.2 Standard-Size Freezers................................................................................................... 9-13

9.3.2.1 Market Segments ......................................................................................... 9-14

9.3.2.2 Disaggregation into Freezer Product Classes .............................................. 9-16

9.3.3 Compact Refrigerators................................................................................................... 9-17

9.3.3.1 Market Segments ......................................................................................... 9-17

9.3.3.2 Disaggregation into Compact Refrigerator Product Classes ....................... 9-20

9.3.4 Compact Freezers........................................................................................................... 9-21

9.3.4.1 Market Segments ......................................................................................... 9-21

9.3.4.2 Disaggregation into Compact Freezer Product Classes............................... 9-23

9.4 IMPACT OF ENERGY CONSERVATION STANDARDS ON SHIPMENTS.......... 9-24

9.4.1 Application of Relative Price Elasticity......................................................................... 9-26

9.5 AFFECTED STOCK ..................................................................................................... 9-26

9.6 SHIPMENTS FORECASTS IN STANDARDS CASES.............................................. 9-27

LIST OF TABLES

Table 9.3.1 Market Shares of Side-by-Side Refrigerator-Freezers......................................... 9-8

Table 9.3.2 Modeled Homeowner Side-by-Side Market Share .............................................. 9-9

Table 9.3.3 Product Class Market Shares for Standard-size Freezers.................................. 9-17

Table 9.3.4 Product Class Market Shares of Compact Refrigerators ................................... 9-21

Table 9.3.5 Product Class Market Shares of Compact Freezers........................................... 9-24

Table 9.4.1 Change in Relative Price Elasticity Following a Purchase Price Change ......... 9-26

LIST OF FIGURES

Figure 9.3.1 Historical and Forecasted U.S. Housing Starts.................................................... 9-4

Figure 9.3.2 Standard-size Refrigerator-Freezers: Survival and Retirement Functions .......... 9-5
9-ii

Figure 9.3.3 Standard-Size Refrigerator-Freezers: Historical and Base Case Shipments 

Forecast by Market Segment ............................................................................... 9-7

Figure 9.3.4 Projected Market Share of Side- and Bottom-Freezer Product Classes ............ 9-11

Figure 9.3.5 Standard-size Refrigerator-Freezers: Base Case Shipments Forecast by 

Product Class Group .......................................................................................... 9-13

Figure 9.3.6 Standard-size Freezers: Survival and Retirement Functions............................. 9-15

Figure 9.3.7 Standard-Size Freezers: Historical and Base Case Shipments Forecast by 

Market Segment................................................................................................. 9-16

Figure 9.3.8 Compact Refrigerators: Survival and Retirement Functions............................. 9-18

Figure 9.3.9 Forecast of Saturation of Compact Refrigerators in New Construction 

Market Segments ............................................................................................... 9-19

Figure 9.3.10 Compact Refrigerators: Base Case Shipments Forecast by Market 

Segment.............................................................................................................. 9-20

Figure 9.3.11 Compact Freezers: Survival and Retirement Functions..................................... 9-22

Figure 9.3.12 Compact Freezers: Historical and Base Case Shipments Forecast by 

Market Segment................................................................................................. 9-23

Figure 9.6.1 Standard-Size Refrigerator-Freezers: Base Case and Standards Case 

Shipments Forecasts........................................................................................... 9-28

Figure 9.6.2 Standard-size Freezers: Base Case and Standards Case Shipments 

Forecasts ............................................................................................................ 9-29

Figure 9.6.3 Compact Refrigerators: Base Case and Standards Case Shipments 

Forecasts ............................................................................................................ 9-30
9-1

CHAPTER 9. SHIPMENTS ANALYSIS

9.1 INTRODUCTION

Estimates of future product shipments are a necessary input to calculations of the national 

energy savings (NES) and net present value (NPV), as well as to the manufacturer impact 

analysis (MIA). This chapter describes the data and methods the U.S. Department of Energy 

(DOE) used to forecast annual product shipments and presents results for each of the 

refrigeration product classes being considered in this analysis.

DOE defined four refrigeration product types, and developed models to estimate 

shipments for each type. The four types are: (1) standard-size refrigerator-freezers, (2) standardsize freezers, (3) compact refrigerators, and (4) compact freezers. Each model considers specific 

market segments to estimate shipments of each product type. The results from these segments are 

aggregated to estimate total shipments for each product type. DOE then used various data and 

assumptions to disaggregate total shipments into the product classes considered in this 

rulemaking. Note that built-in refrigeration products are initially included in the models for 

standard-size refrigerator-freezers and standard-size freezers, and then are separated out from the 

forecast.

To estimate the effects of potential standard levels on product shipments, each shipments 

model accounts for the combined effects on consumer purchase decisions of changes in product 

price, annual operating cost, and household income.

The shipments models were developed as Microsoft Excel spreadsheets that are 

accessible on the Internet 

(http://www1.eere.energy.gov/buildings/appliance_standards/residential/refrigerators_freezers.ht

ml). Appendix 10-A discusses how to access and utilize the shipments model spreadsheets, 

which are integrated into spreadsheets for the National Impact Analysis. The rest of this chapter 

explains the shipments models in more detail. Section 9.2 presents methodology behind the 

models; section 9.3 describes the data inputs and calibration of each model; section 9.4 discusses 

impacts on shipments from standards; section 9.5 discusses the affected stock; and section 9.6 

presents the shipments forecast for different energy conservation standard levels.

9.2 SHIPMENTS MODEL GENERAL METHODOLOGY

DOE developed a model of the national stock of in-service appliances for estimating 

annual shipments for each of the product types considered for this standards rulemaking. Rather 

than simply extrapolating a shipments trend, the shipments models used in this rulemaking take 

an accounting approach, tracking the vintage of units in the existing stock.
9-2

9.2.1 Stock Accounting Approach

Stock accounting provides an estimate of the age distribution of product stocks for all 

years, using product shipments, a retirement function, and initial product stock as inputs. The age 

distribution of product stocks is a key input to both the NES and NPV calculations because the 

operating costs for any year depend on the age distribution of the stock. Older, less efficient units 

may have higher operating costs, while younger, more-efficient units have lower operating costs.

DOE calculates the total stock of each product by integrating historical shipments data 

beginning with a specific year. The start year depends on the historical data available for the 

product. As units are added to the stock, some of the older ones retire and exit the stock. To 

estimate future shipments, DOE developed a series of equations that define the dynamics and 

accounting of stocks. For new units, the equation is:

( , 1) ( 1) _ Stock j age = = Ship j

Where: 

Stock(j, age) =number of units of a particular age,

j = year for which the stock is being estimated, and

Ship (j) = number of units purchased in year j.

The above equation states that the number of one-year-old units is simply equal to the 

number of new units purchased the previous year. Slightly more complicated equations, such as 

the following equation, describe how the model accounts for the existing stock of units. 

( 1, 1) ( , ) [1 ( )] _ Stock j age Stock j age prob age + + = × Rtr

In this equation, as the year is incremented from j to j+1, the age is also incremented 

from age to age+1. Over time, a fraction of the stock is removed; that fraction is determined by a 

retirement probability function, probRtr(age), which is described below.

9.2.2 Market Segments

The model considers specific market segments in developing a shipments forecast. The 

two primary market segments are replacements and installations in new homes. 

For common appliances that have been used by U.S. consumers for a long time, 

replacements typically constitute the majority of shipments. To estimate shipments of 

replacement units, the models utilize shipments data from previous years and estimates of the

lifetime of each product. Estimated shipments of replacement units in a given year are equal to 

the total stock of the appliance minus those units shipped in previous years that remain in the 

stock. DOE determines the useful service life of each product class to estimate the number of 
9-3

years products are likely to remain in the stock. The following equation shows how DOE 

estimates shipments of replacement units.

( ) ( 1) ∑ ∑ ( )

0

1

_ _

_

Rpl j Stock j Ship prob age Rtr

ageMax

age

j

j N

p = p j ×

= =

Where:

Stockp (j-1) = total stock of appliances in year j-1,

probRtr (age) = probability that an appliance of a particular age will be retired, and

N = year in which the model begins its stock accounting.

To forecast annual shipments for the new construction market, the model uses forecasts 

of new housing and the saturation of the product in new housing. The forecast of market shares 

involves knowledge of historical trends, as well as the important drivers of consumer choice and 

their relative impacts.

For many products, DOE models a third market segment. For standard-size refrigeratorfreezers, DOE estimated purchases driven by the conversion of an existing unit from first to 

second refrigerator. For standard-size freezers, DOE estimated purchases driven by existing 

households who enter the market as new owners.

9.3 PRODUCT-SPECIFIC MODELS 

This section describes the models used to forecast shipments of the four refrigeration 

product types described in section 9.1. For each model, the section describes the sources for 

historical shipments data, the market segments considered, the approach for disaggregating total 

shipments into the appropriate product classes, and presents the forecast of base case shipments.

Forecasts of new housing are used in the shipments models. New housing includes newly 

constructed single- and multi-family units, termed “new housing completions,” and mobile home 

placements. For new housing completions and mobile home placements, DOE used recorded 

data through 2007, and adopted the projections from the DOE Energy Information 

Administration (EIA)’s Annual Energy Outlook 2010 (AEO2010) for the period 2008–2035.1

Figure 9.3.1 presents historical and forecasted new housing starts. For 2031−2043, DOE kept

completions at the 2035 level.
9-4

Figure 9.3.1 Historical and Forecasted U.S. Housing Starts 

9.3.1 Standard-Size Refrigerator-Freezers

DOE’s shipments model uses the aggregate shipments of standard-size refrigeratorfreezers as the basis for its forecasts. For the shipments analysis, the category “standard-size 

refrigerator-freezers” includes built-in refrigerator-freezers. DOE used various data and 

assumptions to disaggregate total shipments of standard-size refrigerator-freezers into the 

product classes of standard-size refrigerator-freezers and built-in refrigerator-freezers considered 

in its analysis. 

To start, DOE used the following sources to establish historical shipments for standardsize refrigerator-freezers: Appliance magazine’s Statistical Review,2,3,4 AHAM Factbooks,

5,6 and 

an Association of Home Appliance Manufacturers (AHAM) data submittal related to this 

rulemaking.7

9.3.1.1 Market Segments

The shipments data from 1990 onward are shown in Figure 9.3.2 below. (The 

complete historical time series may be found in the shipments model spreadsheet for standardsize refrigerator-freezers.)

The market for standard-size refrigerator-freezers is primarily comprised of units for new 

construction, replacement units for products that have been retired, and additional refrigerator 

purchases driven by conversion of a first refrigerator to a second refrigerator. Total shipments 

are represented by the following equation:

0.00

0.50

1.00

1.50

2.00

2.50

3.00

1990 1995 2000 2005 2010 2015 2020 2025 2030 2035

Millions

Historical and Reference Case

High Economic Growth Case

Low Economic Growth Case
9-5

Ship ( j) Rpl ( j) NH ( j) Conv ( j) SRRF = SRRF + SRRF + SRRF

Where:

ShipSRRF (j) = total shipments of standard-size refrigerator-freezers in year j, 

RplSRRF (j) = replacement shipments in year j, 

NH SRRF(j) = shipments to new homes in year j, and 

ConvSRRF (j)= shipments due to additional refrigerator purchase (conversion of first to second 

refrigerator) in year j. 

The following sections discuss these three market segments in further detail. 

Replacements. DOE determined refrigerator-freezer shipments to the replacement market 

using an accounting method that tracks the total stock of units by vintage. Over time, some units 

are retired and removed from the stock, thereby triggering the shipment of replacement units. A

certain percentage of units will fail each year and need to be replaced. To determine when a unit 

fails, DOE used a survival function based on a product lifetime distribution with an average 

value of 17.1 years. Chapter 8 provides a discussion of product lifetime. Figure 9.3.2 shows the 

survival and retirement functions that DOE used to estimate replacement shipments for standardsize refrigerator-freezers.

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

0 5 10 15 20 25 30 35 40 45 50

Age

% Surviving

% Retiring

Figure 9.3.2 Standard-size Refrigerator-Freezers: Survival and Retirement 

Functions
9-6

New Construction Shipments. To estimate shipments for new residential construction, 

DOE multiplied the housing starts forecast for each year by the estimated saturation of standardsize refrigerator-freezers in new housing. DOE estimated the saturation in 2008 to be 1.3 per new 

home based on the calculated appliance stock from shipments data and the retirement function. 

DOE used the 2008 saturation for the entire forecast period. The following equation describes 

the method used for calculating saturation for new construction: 

Sat ( j) Stock( j)/ HStock( j) NC =

SatNC ( j) = SatNC (2008)∀j > 2008

Where:

SatNC(j) = market saturation of standard-size refrigerator-freezers in the new housing market 

segment in year j,

Stock(j) = total stock of standard-size refrigerator-freezers in year j,

HStock(j) = total number of housing units in year j, and 

SatNC(2008) = market saturation of standard-size refrigerator-freezers in the new housing market 

segment in 2008. 

Shipments Due to Additional Refrigerator Purchase. DOE included a market segment 

corresponding to purchases of additional standard-size refrigerator-freezers that are not intended 

as replacements. Because such purchases involve converting a first unit to a second refrigerator, 

DOE estimated shipments to this market segment by applying the probability of conversion 

(developed in chapter 8) to the stock of surviving refrigerators. To determine when a household 

converts a first refrigerator to a second one, DOE used a conversion function based on the total 

installed stock of refrigerators of a certain age. Chapter 8 provides a detailed discussion of the 

conversion function. The following equation shows how DOE calculated shipments to this 

market segment.

( ) ∑ ∑ ( ) ( )

0

1_

SNew j C Stock age prob age conv

ageMax

age

j

j N

SRRF = j × j ×

= =

Where:

SNewSRRF (j )= shipments due to additional refrigerator purchase (conversion of first to second 

refrigerator) in year j, 

Cj = a calibration factor, equal to the ratio of new shipments in year j to the installed 

stock in that year, and

Probconv(age) = probability that the refrigerator has been converted at a given age
9-7

Shipments Forecast by Market Segment. Figure 9.3.3 shows the forecasted shipments in 

the base case (without new energy conservation standards) and the historical shipments (through 

2008). The figure presents shipments due to retirements, shipments to new housing, and 

shipments due to conversion from first to second units. 

Figure 9.3.3 Standard-Size Refrigerator-Freezers: Historical and Base 

Case Shipments Forecast by Market Segment

9.3.1.2 Disaggregation into Refrigerator-Freezer Product Classes

DOE examined the historical trends in the market shares of various refrigerator-freezer 

configurations to disaggregate the total shipments of refrigerator-freezers into shipments to each 

of the three considered refrigerator-freezer product categories (top-mount, bottom-mount and 

side-by-side configurations). The market share of side-by-side refrigerator-freezers models has 

grown significantly during the past two decades. Bottom-freezer models historically had a small 

market share, but that share has grown in recent years. To forecast the market share for these 

three configurations throughout the 30-year analysis period (beginning in 2014), DOE built a 

simple model of aggregate consumer behavior, fit its model to the historical growth in side-byside market share, and then used its model to estimate future market shares for all three 

configurations. 

DOE assumed that bottom-freezer models were an insignificant portion of the market 

prior to 2005, and that consumer behavior related to these models in the future would mirror 

behavior regarding side-by-side models. Therefore, DOE forecast the combined market share for 
9-8

side-by-side and bottom-freezer products, and assumed that the ratio between the market shares

of bottom-mount and side-by-side products would remain fixed at its 2008 value.

DOE based its model on the market share of each product category as reported by 

households in the Energy Information Administration’s Residential Energy Consumption 

Survey8 (RECS) and as reported by AHAM.7 RECS reports whether a household owns a sideby-side refrigerator, but does not distinguish between top- and bottom-mount units. For the 

purpose of this model, DOE assumed that all recently-purchased top-or-bottom-mount 

refrigerators reported in the RECS surveys conducted in 1990, 1993, 1997, 2001, and 2005 are 

top-mount units. 

DOE used RECS data first to estimate the maximum (“limiting”) market share that sideby-side and bottom-mount product classes would attain in the future. RECS reports the income 

of each household in its sample. DOE assumed that households that have annual incomes greater 

than $100,000 and that own their own homes are able to select the appliance that best meets their 

needs and preferences. The market share of side-by-side units in these households is significantly 

higher than the current overall market share of side-by-side products. DOE determined market 

shares for recent purchases from RECS by considering only households which reported 

purchasing their appliance within two years prior to the survey. The market share of side-by-side 

refrigerator purchases in the selected household group from each RECS survey is shown in Table 

9.3.3. Over time, DOE assumed that all homeowners will be free to choose the product of their 

choice, as DOE assumed high-income homeowners can today. As a result, DOE assumed that 

market share of side-by-side units among all homeowners will increase until it equals the mean 

market share among high-income home-owning households, 66.4 percent.

Table 9.3.1 Market Shares of Side-by-Side Refrigerator-Freezers

RECS Survey Year

Market Share of Side-by-Side Units for HighIncome Homeowners (%)

1990 57.7

1993 71.7

1997 73.4

2001 61.6

2005 67.5

Mean 66.4

Source: EIA, Residential Energy Consumption Survey, for the years listed.

DOE used RECS to determine what percent of side-by-side units is sold to home-owners 

in order to convert a limiting market share among home-owning households into a market share 

for all shipments. This percentage was roughly constant in the five most recent RECS surveys, 

and DOE assumed that it would remain equal to their mean, 90.9 percent, throughout the forecast 

period. DOE also assumed that the percent of American households that own their home would 

return to its historical level of roughly 65 percent by 2025. (Home ownership ranged between 63 
9-9

percent and 66 percent from 1962 to 1997, peaked at 69 percent in 2004, and fell to 67.8 percent 

in 2008.)

DOE combined the three factors (the observed preference of high-income consumers, 

percent of side-by-side refrigerator-freezers purchased by homeowners, and homeownership) to 

predict the limiting market share for the side- and bottom-freezer product classes. This limit is

= 47.45%

× = −

−

HO

HO LIM LIM

SF LIM SF

MS HO MS

Where:

MSSF-LIM = limiting market share for side-by-side and bottom-mount product classes,

MSHO-LIM = limiting market share for side-by-side and bottom- mount product classes among 

homeowners (66.4 percent),

HOLIM = DOE’s assumed value for the eventual percentage of households that will own 

their own home (65 percent), and 

SFHO = the percentage of side-by-side and bottom-mount products sold to homeowners 

(90.9 percent).

DOE modeled the approach to this limiting value as a logistic curve, and fit the model 

parameters to data from RECS and AHAM in order to determine the rate at which the market 

will approach the limit. RECS micro-data enabled DOE to determine the approximate market 

share of side-by-side products among all homeowners in the years preceding each RECS survey 

(1989, 1992, 1996, 2000, and 2004). DOE also calculated the market share among homeowners 

from the AHAM data by multiplying by 90.9 percent (SFHO) and dividing by the homeownership 

(HO) for each year. The resulting estimates for market shares of side-by-side products among 

homeowners are shown in Table 9.3.2.

Table 9.3.2 Modeled Homeowner Side-by-Side Market Share

Survey Year Market Share

AHAM 1998 41.0%

1999 41.9%

2000 42.2%

2001 43.0%

2002 43.9%

2003 45.9%

2004 46.2%

2005 49.1%

2006 59.8%

2007 61.4%

2008 65.1%

RECS 1989 32.5%
9-10

Survey Year Market Share

1992 31.9%

1996 41.1%

2000 48.9%

2004 53.0%

DOE fit a logistic curve to the data in Table 9.3.2, approaching the limiting value MSSFLIM:

( )

e year

HO LIM

HO year

MS MS −

−

−

+ = α β

1

,

Where:

MSHO-year = market share of side-by-side and bottom-mount refrigerator-freezers among all 

homeowners in a given year,

α, β = fit parameters, and

MSHO-LIM = limiting market share for side- and bottom-freezer product classes among 

homeowners (66.4 percent).

The best fit parameters are: α = 0.10504 and β = 1992.38.

The R-squared value for the fit is 0.795, indicating that the model is a relatively good fit. 

DOE multiplied the best-fit estimate of MSHO-year by homeownership in each year, and then 

divided by SFHO to account for side- and bottom-mount refrigerators sold to non-homeowners. 

The results are estimated market shares of side-by-side or bottom-mount products throughout the 

analysis period. This estimate, along with the markets shares derived from the RECS and AHAM 

data, is shown in Figure 9.3.4.
9-11

0.2

0.25

0.3

0.35

0.4

0.45

0.5

1985 1995 2005 2015 2025 2035 2045

Year

Side- and Bottom-freezer Market Share

Forecast market share

AHAM Shipments Share

RECS Side-freezer

Limiting fraction

Figure 9.3.4 Projected Market Share of Side- and Bottom-Freezer 

Product Classes

DOE disaggregated the side and bottom-mount freezer classes into their respective 

product classes based on the AHAM data submittal for 2005-2008. For future years, DOE 

maintained the market shares of the product classes within each considered category of side-byside and bottom-mount, and top-mount refrigerator-freezer as they existed in 2008. 

For built-in product classes, DOE assumed that the market shares will move in step with 

market shares of the closest corresponding conventional product class (e.g., product class 3A-BI 

follows conventional product class 3), and it maintained the ratios between built-in and 

conventional products found in 2008. 

Table 9.3.3 presents the market share forecast DOE used to disaggregate total standardsize refrigerator-freezer shipments.
9-12

Projected Product Class Market Shares of Standard-Size Refrigerator-Freezers

Year PC3

(Top)

PC1+PC2

+PC6

(Top)

PC4

(S/S)

PC7

(S/S)

PC5

(Bottom)

PC5A

(Bottom)

PC4-BI+

PC7-BI

(Built-in S/S)

PC3A-BI+

PC5-BI

(Built-in)

2008 50.6% 0.7% 0.8% 26.9% 12.5% 5.7% 1.6% 1.2%

2009 54.5% 0.7% 0.8% 24.7% 11.5% 5.2% 1.5% 1.1%

2010 58.0% 0.8% 0.7% 22.8% 10.6% 4.8% 1.3% 1.0%

2011 57.7% 0.8% 0.7% 23.0% 10.7% 4.9% 1.3% 1.0%

2012 57.5% 0.8% 0.7% 23.1% 10.8% 4.9% 1.4% 1.1%

2013 57.2% 0.8% 0.7% 23.3% 10.8% 4.9% 1.4% 1.1%

2014 56.9% 0.8% 0.7% 23.4% 10.9% 5.0% 1.4% 1.1%

2015 56.6% 0.8% 0.7% 23.6% 11.0% 5.0% 1.4% 1.1%

2016 56.4% 0.8% 0.7% 23.7% 11.1% 5.0% 1.4% 1.1%

2017 56.1% 0.8% 0.7% 23.9% 11.1% 5.1% 1.4% 1.1%

2018 55.9% 0.8% 0.7% 24.0% 11.2% 5.1% 1.4% 1.1%

2019 55.7% 0.8% 0.7% 24.1% 11.2% 5.1% 1.4% 1.1%

2020 55.4% 0.7% 0.7% 24.2% 11.3% 5.1% 1.4% 1.1%

2021 55.3% 0.7% 0.7% 24.3% 11.3% 5.2% 1.4% 1.1%

2022 55.1% 0.7% 0.7% 24.4% 11.4% 5.2% 1.4% 1.1%

2023 55.0% 0.7% 0.8% 24.5% 11.4% 5.2% 1.4% 1.1%

2024 54.8% 0.7% 0.8% 24.6% 11.4% 5.2% 1.4% 1.1%

2025 54.7% 0.7% 0.8% 24.7% 11.5% 5.2% 1.4% 1.1%

2026 54.5% 0.7% 0.8% 24.8% 11.5% 5.2% 1.5% 1.1%

2027 54.3% 0.7% 0.8% 24.8% 11.6% 5.3% 1.5% 1.1%

2028 54.2% 0.7% 0.8% 24.9% 11.6% 5.3% 1.5% 1.1%

2029 54.0% 0.7% 0.8% 25.0% 11.7% 5.3% 1.5% 1.1%

2030 53.9% 0.7% 0.8% 25.1% 11.7% 5.3% 1.5% 1.1%

2031 53.7% 0.7% 0.8% 25.2% 11.7% 5.3% 1.5% 1.1%

2032 53.6% 0.7% 0.8% 25.2% 11.8% 5.3% 1.5% 1.1%

2033 53.5% 0.7% 0.8% 25.3% 11.8% 5.4% 1.5% 1.1%

2034 53.4% 0.7% 0.8% 25.4% 11.8% 5.4% 1.5% 1.1%

2035 53.3% 0.7% 0.8% 25.4% 11.8% 5.4% 1.5% 1.1%

2036 53.2% 0.7% 0.8% 25.5% 11.9% 5.4% 1.5% 1.1%

2037 53.1% 0.7% 0.8% 25.5% 11.9% 5.4% 1.5% 1.1%

2038 53.0% 0.7% 0.8% 25.6% 11.9% 5.4% 1.5% 1.1%

2039 52.9% 0.7% 0.8% 25.6% 11.9% 5.4% 1.5% 1.1%

2040 52.8% 0.7% 0.8% 25.7% 12.0% 5.4% 1.5% 1.1%

2041 53.1% 0.7% 0.8% 25.5% 11.9% 5.4% 1.5% 1.1%

2042 52.8% 0.7% 0.8% 25.7% 12.0% 5.4% 1.5% 1.1%

2043 52.7% 0.7% 0.8% 25.8% 12.0% 5.5% 1.5% 1.1%
9-13

Shipments Forecast by Market Segment. Figure 9.3.5 presents forecasted refrigeratorfreezer shipments disaggregated by product class group.

Figure 9.3.5 Standard-size Refrigerator-Freezers: Base Case Shipments 

Forecast by Product Class Group

9.3.2 Standard-Size Freezers

DOE’s shipments model uses the aggregate shipments of standard-size freezers as the 

basis for its forecasts. For the shipments analysis, the category “standard-size freezers” includes 

built-in freezers. DOE used various data and assumptions to disaggregate total shipments of 

standard-size freezers into the product classes of standard-size freezers and built-in freezers 

considered in its analysis.

To start, DOE used data on historical shipments (i.e., domestic shipments and imports) 

from Appliance magazine’s Statistical Review,

9 AHAM Factbook,5 and an AHAM data 

submittal7 to populate and calibrate its shipments model. The shipments data from 1990 onward 

are shown in Figure 9.3.7 below. (The complete historical time series may be found in the 

shipments model spreadsheet for standard-size freezers.)
9-14

9.3.2.1 Market Segments

The shipments market for standard-size freezers is primarily comprised of replacement 

units for products that have been retired and units in new homes. DOE’s shipments model also 

assumes that some households enter the market as new freezer owners. Total shipments are 

represented by the following equation:

Ship ( j) Rpl ( j) NH ( j) EHA ( j) SF = SF + SF + SF

Where:

ShipSF (j) = total shipments of standard-size freezers in year j, 

RplSF (j) = replacement shipments in year j, 

NH SF(j) = shipments to new households in year j, and 

EHASF (j)= shipments to existing households without the appliance in year j. 

The following sections discuss all three of these markets in further detail. 

Replacements. DOE determined shipments to the replacement market using an 

accounting method that tracks the total stock of units by vintage. Over time, some units are

retired and removed from the stock, triggering the shipment of a replacement unit. A certain 

percentage (depending on the age) of units will fail each year and need to be replaced. To 

determine when a unit fails, DOE used a survival function based on a product lifetime 

distribution that had an average value of 22.7 years. Chapter 8 describes the derivation of the 

lifetime of standard-size freezers. Figure 9.3.6 shows the survival and retirement functions that 

DOE used to estimate shipments of replacement freezers.
9-15

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

0 5 10 15 20 25 30 35 40 45 50

Age

% Surviving

% Retiring

Figure 9.3.6 Standard-size Freezers: Survival and Retirement Functions

New Construction. To forecast the shipments of standard-size freezers for new 

construction for any given year, DOE multiplied the forecasted housing starts by the forecasted 

saturation of standard-size freezers for new housing. DOE determined the saturation in new 

homes by using a sample of RECS household records whose home is less than 5 years old, with 

freezers of age less than 5 years. DOE used the growth in saturation between the 2001 and 2005 

RECS surveys8 to estimate saturation in 2007 new homes of 12%. It used that level for the entire 

forecast period.

New Owners. DOE introduced a third market segment that consists of households that 

currently do not own a freezer. DOE estimated historical shipments to this market segment as the 

residual shipments after modeled shipments for new housing and replacements were subtracted 

from total actual shipments. DOE used a moving average of the previous 3 years of the percent 

of households who purchase freezers as new owners to estimate the percent for each year in 

2008-2043. The following equation illustrates the calculations.

Where:

EHASF (j) = number of freezers shipped to existing households without the appliance in year j,

StockSatj = stock saturation of freezers in year j,

HStockj = housing stock in year j, and

EHAfracj = fraction of housing units without the appliance who obtain a freezer in year j.

SF StockSat j HStock j EHAfrac j EHA ( j) = (1− )× ×
9-16

Shipments Forecast by Market Segment. Figure 9.3.7 shows the forecasted shipments of 

standard-size freezers in the base case (without amended energy conservation standards), 

disaggregated into the three modeled market segments, and the historical shipments, which DOE 

used to calibrate the forecast. 

Figure 9.3.7 Standard-Size Freezers: Historical and Base Case 

Shipments Forecast by Market Segment

9.3.2.2 Disaggregation into Freezer Product Classes

To disaggregate the total shipments of standard-size freezers into shipments of each of 

the freezer product classes, DOE used the market share information submitted by AHAM.7

These data provided an aggregated market share in 2007 of 50.6 percent for product classes 8, 10 

and 10A. Using data from the 2005 AHAM Fact Book5 and Appliance magazine,2 DOE 

concluded that the market shares for product classes 8 and 10A are near zero. Therefore, DOE 

attributed the combined market share of product classes 8, 10 and 10A from the AHAM data 

submittal (50.6 percent) entirely to product class 10. The remainder, 49.4 percent, is comprised 

of shipments of upright freezers with auto defrost. Based on the AHAM data submittal, DOE 

estimated that built-in freezers (product class 9-BI) account for 2.2% of total shipments of 

upright freezers with auto defrost. 
9-17

Table 9.3.4 presents the market shares used for disaggregating modeled shipments of 

standard-size freezers. Because a reliable method for projecting market share changes was 

lacking, DOE used these estimated market shares throughout the forecast period.

Table 9.3.3 Product Class Market Shares for Standard-size Freezers

PC8 PC9 PC10 PC10A PC9-BI

0.0% 48.3% 50.6% 0.0% 1.1

9.3.3 Compact Refrigerators 

DOE’s shipments model uses the aggregate shipments of compact refrigerators as the 

basis for its forecasts. DOE used various data and assumptions to disaggregate total shipments 

into the five product classes of compact refrigerators considered in this analysis.

To start, DOE developed historical shipments data (domestic shipments and imports) 

based on data submitted by AHAM7 and various issues of Appliance magazine.

2,9 These data are 

shown in Figure 9.3.9 below.

9.3.3.1 Market Segments

The market for compact refrigerators is primarily comprised of units that replace products 

that have been retired from service, and units installed in new housing, new lodging in the 

commercial sector (such as hotel rooms and dormitories), and in other new construction in the 

commercial sector. Total compact refrigerator shipments are represented by the following 

equation:

Ship ( j) Rpl ( j) NH ( j) NLodg ( j) NOthComm ( j) CRRF = CRRF + CRRF + CRRF + CRRF

Where:

ShipCRRF (j) = total shipments of compact refrigerators in year j, 

RplCRRF(j) = replacement shipments in year j, 

NHCRRF (j) = shipments to new households in year j, 

NLodgCRRF (j) = shipments to new lodging units in year j, and 

NOthCommCRRF (j) = shipments to other new commercial establishments in year j.

The following sections discuss these markets. 

Replacements. DOE determined shipments to the replacement market using an 

accounting method that tracks the total stock of units by vintage. Over time, some of the units are 

retired and removed from the stock, triggering the shipment of a new unit. A certain percentage 

of units will fail each year and need to be replaced. To determine when a compact refrigerator 

fails, DOE used a product survival function based on a lifetime distribution with an average 
9-18

value of 5.6 years. Chapter 8 presents a more thorough discussion of product lifetimes for 

compact refrigerators. Figure 9.3.8 shows the survival and retirement functions that DOE used to 

estimate replacement shipments.

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

0 5 10 15 20 25 30

Age

% Surviving

% Retiring

Figure 9.3.8 Compact Refrigerators: Survival and Retirement 

Functions

New Housing. To estimate shipments to new housing in each year, DOE multiplied 

forecasted housing starts by the estimated saturation of compact refrigerators in new housing

units. DOE estimated market saturation for this segment using the saturation of compact 

refrigerators in newly-built homes in RECS 2001 and RECS 2005 (2.7 percent and 3.2 percent, 

respectively). For years beyond 2005, DOE maintained the growth in new housing saturation 

measured between 2001 and 2005. 

New Lodging and Other Commercial New Construction. To estimate shipments to new 

commercial establishments, DOE used forecasts of new construction in lodging and other 

commercial establishments coupled with saturation data (in terms of units per building). DOE 

used total-stock saturation data from the American Lodging Association (ALA)10 and the EIA’s 

Commercial Building Energy Consumption Survey (CBECS).11 For lodging, DOE used

saturations from ALA for the years 1998, 2003, and 2008. For future years, DOE maintained the 

growth in saturation rates seen between 2003 and 2008. For other commercial applications, 

DOE used saturations from CBECS for the years 1999 and 2003. DOE maintained the growth in 

saturation seen between 1999 and 2003 for subsequent years.
9-19

Figure 9.3.9 presents the forecast for saturation of compact refrigerators (in terms of 

percent of new buildings with 1 or more units) for the three market segments for new 

construction. 

2003 - 72%

2003 - 48%

2005 - 3.2%

0%

20%

40%

60%

80%

100%

120%

199019931996199920022005200820112014201720202023202620292032203520382041

Lodging

Other Commercial

Residential

Figure 9.3.9 Forecast of Saturation of Compact Refrigerators in New 

Construction Market Segments

 

Model Calibration. To better match modeled shipments with the historical shipments 

data, DOE first estimated the compact refrigerator stock (number of units) for 2003. DOE 

estimated the 2003 residential stock from various years of RECS. As mentioned earlier, DOE 

obtained the compact refrigerator saturation data for the lodging sector from the ALA. For other 

commercial applications, DOE utilized saturations from CBECS for the years 1999 and 2003. 

CBECS data does not specify the size of the residential style refrigerators in commercial 

establishments. In order to put an upper bound on the saturations, DOE considered the case 

wherein all residential style refrigerators in these establishments are compact refrigerators. This 

upper bound determined the maximum possible stock of compact refrigerators in other 

commercial establishments. 

Using the above stock estimate, DOE estimated the maximum average life of a compact 

refrigerator to be 5.6 years.a

 

a In DOE’s stock accounting model based on historical shipments and stock in residential and lodging sectors, a 

lower saturation of compacts in other commercial establishments would imply a shorter average life for a compact 

refrigerator.

In the absence of additional information, DOE made the 
9-20

conservative assumption of 5.6 years as the average life of a compact refrigerator. This lifetime 

provides a better match between modeled and historical shipments (see figure below).

Based on the above sources, DOE estimated that in 2003 the compact refrigerator stock 

was split 30 percent, 18 percent, and 52 percent between residential, lodging, and other 

commercial sectors, respectively.

Shipments Forecast by Market Segment. Figure 9.3.10 shows the forecasted shipments 

of compact refrigerators in the base case, disaggregated into modeled market segments, along 

with the historical shipments. DOE did not attempt to match its total modeled shipments with the 

spike in historical shipments seen in 2003-2006.

Figure 9.3.10 Compact Refrigerators: Base Case Shipments 

Forecast by Market Segment 

9.3.3.2 Disaggregation into Compact Refrigerator Product Classes

DOE based its product class market shares for compact refrigerators on data submitted by 

AHAM7 and California Energy Commission (CEC) data12

Table 9.3.5

on available compact refrigerator 

models. presents the market share forecast used for disaggregating total modeled 

shipments. DOE used these estimated market shares throughout the forecast period.
9-21

Table 9.3.4 Product Class Market Shares of Compact Refrigerators

Year PC11 PC12 PC13 PC13A PC14 PC15

2008 84.4% 5.9% 0.9% 8.1% 0.3% 0.3%

9.3.4 Compact Freezers

DOE’s shipments model uses the aggregate shipments of compact freezers as the basis 

for its forecasts. DOE used various data and assumptions to disaggregate total shipments into the 

three product classes of compact freezers considered in this analysis.

To start, DOE developed historical shipments data (domestic shipments and imports) 

based on data submitted by AHAM7 and various issues of Appliance magazine.

2,9 These data are 

shown in Figure 9.3.12 below.

9.3.4.1 Market Segments

The market for compact freezers is primarily comprised of replacement units for products 

that have been retired from service and units purchased by new owners (not just new 

construction) in both residential and commercial sectors. Total compact freezer shipments are 

represented by the following equation:

Ship ( j) Rpl ( j) NR ( j) NC ( j) CF = CF + CF + CF

Where:

ShipCF (j) = total shipments of compact freezers in year j, 

RplCF (j) = replacement shipments in year j, 

NR CF(j) = shipments to new residential owners in year j, and 

NCCF (j)= shipments to new commercial owners in year j. 

The following sections discuss these markets in further detail. 

Replacements. DOE determined shipments to the replacement market using an 

accounting method that tracks the total stock of units by vintage. DOE integrated historical 

shipments to estimate each year’s stock of compact freezers by vintage. Over time, some units 

are retired and removed from the stock, triggering the shipment of a replacement unit. A certain 

percentage of units will fail each year and need to be replaced. To determine when a compact 

freezer fails, DOE used a product survival function based on a lifetime distribution with an 

average value of 7.5 years. Chapter 8 provides a more thorough discussion of product lifetimes

for compact freezers. Figure 9.3.11 shows the survival and retirement functions that DOE used to 

estimate shipments of replacement units.
9-22

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

0 5 10 15 20 25 30

Age

% Surviving

% Retiring

Figure 9.3.11 Compact Freezers: Survival and Retirement Functions
9-23

New Owners. In the absence of data on saturation of compact freezers in homes or 

commercial applications, DOE estimated historical shipments to new owners based on the 

difference between total historical shipments of compact freezers and estimated replacement 

shipments. DOE forecast new owner shipments in each year using a 3-year moving average 

method. DOE assumed an even split between residential and commercial new owners for this 

segment.

Shipments Forecast by Market Segment. Figure 9.3.12 shows the forecasted shipments 

of compact freezers in the base case (without amended energy conservation standards), 

disaggregated into modeled market segments, along with the historical shipments.

Figure 9.3.12 Compact Freezers: Historical and Base Case Shipments 

Forecast by Market Segment

9.3.4.2 Disaggregation into Compact Freezer Product Classes

DOE used CEC data on the number of available freezer models13 to estimate market 

shares of product classes 16, 17, and 18. Table 9.3.6 presents the market share forecast used 

throughout the forecast period for disaggregating total modeled shipments. 
9-24

Table 9.3.5 Product Class Market Shares of Compact Freezers

PC16 PC17 PC18

50.0% 30.0% 20.0%

9.4 IMPACT OF ENERGY CONSERVATION STANDARDS ON SHIPMENTS

DOE projects that appliance standards often result in an increase in the price of the 

product. Economic theory suggests that, all else being equal, an increase in the price of a normal 

good would lead to a decrease in demand for it. DOE conducted a literature review and an 

analysis of appliance price and efficiency data to estimate the effects on product shipments from 

increases in product price. DOE also considered the decreases in operating costs from higher 

energy efficiency and changes over time in household income. Appendix 9-A provides a detailed 

explanation of the methodology DOE used to quantify the impacts of these variables on 

shipments.

In the literature, DOE found only a few studies of appliance markets that are relevant to 

the issue at hand. DOE identified no studies that use time-series data of product price and 

shipments data after 1980. The information that can be summarized from the literature suggests 

that the demand for appliances is price-inelastic. Other information in the literature suggests that 

appliances are a normal good, such that rising incomes increase the demand for appliances. 

Finally, the literature suggests that market behavior indicates relatively high “implicit discount 

rates” when comparing appliance prices and appliance operating costs.

b

DOE found insufficient data on product purchase price and operating cost to perform a 

thorough analysis of dynamic changes in the appliance market. Instead, it used purchase price 

and efficiency data specific to residential refrigerators, clothes washers, and dishwashers over the 

period 1980–2002 to evaluate broad market trends and conduct simple regression analyses.

These data indicate that there has been a rise in appliance shipments and a decline in appliance 

purchase price and operating costs over the time period. Household income has also risen during 

this time. 

To simplify the analysis, DOE combined the available economic information into one 

variable, termed the relative price, and used this variable in an analysis of market trends, as well 

as to conduct a regression analysis. The relative price is defined with the following expression:

Income

PP PVOC

Income

TP

RP

+ = =

 

b A high implicit discount rate with regard to operating costs means that, based on market behavior, consumers 

appear to put relatively low economic value on the operating cost savings realized from more-efficient appliances. A 

high value may indicate lack of information, risk aversion and other factors as well as the value consumers place on 

savings accrued in the future.
9-25

Where:

RP = Relative price,

TP = Total price,

Income = Household income,

PP = Appliance purchase price, and

PVOC = Present value of operating cost.

DOE used an “implicit discount rate” of 37 percent to determine the present value of 

operating costs. This value is an average from values derived by several studies described in a 

1985 journal article.14

DOE’s regression analysis yields a relative price elasticity of demand, averaged over the 

three appliances, of -0.34. For example, a relative price increase of 10 percent results in a 3.4 

percent decrease in shipments. Note that because the relative price elasticity incorporates the 

impacts from three effects (i.e., purchase price, operating cost, and household income), the 

impact from any single effect is somewhat mitigated by changes from the other two effects. 

The relative price elasticity of -0.34 is consistent with estimates in the literature.

Nevertheless, DOE stresses that the measure is based on a small data set, using simple statistical 

analysis. More importantly, the measure is based on an assumption that economic variables, 

including purchase price, operating costs, and household income, explain most of the trend in 

appliances per household in the United States since 1980. Changes in appliance quality and 

consumer preferences may have occurred during this period, but DOE did not account for them 

in this analysis. Despite these uncertainties, DOE believes that its estimate of the relative price 

elasticity of demand provides a reasonable assessment of the impact that purchase price, 

operating cost, and household income have on product shipments.

DOE considers the relative price elasticity provided by the preceding analysis to be a 

short-run value. Because DOE’s forecasts of shipments and national impacts due to standards is 

over a 30-year time period, it needed to consider how the relative price elasticity is affected once 

a new standard takes effect. It was unable to identify sources specific to household durable 

goods, such as appliances, to indicate how short-run and long-run price elasticities differ. To 

estimate how the relative price elasticity changes over time, DOE relied on a study pertaining to 

automobiles.15 This study shows that the automobile price elasticity of demand changes in the 

years following a purchase price change. With increasing years after the purchase price change, 

the price elasticity becomes smaller (more inelastic) until it reaches a terminal value around the 

tenth year after the price change. Table 9.4.7 shows the relative change in the price elasticity of 

demand for automobiles over time. DOE developed a time series of relative price elasticities for 

home appliances based on the relative change in the automobile price elasticity of demand. For 

years not shown in the table, DOE performed a linear interpolation to obtain the relative price

elasticity.
9-26

Table 9.4.1 Change in Relative Price Elasticity Following a Purchase Price Change

Years Following Price Change

1 2 3 5 10 20

Change in Elasticity 

Relative to 1st year

1.00 0.78 0.63 0.46 0.35 0.33

Relative Price Elasticity -0.34 -0.26 -0.21 -0.16 -0.12 -0.11

9.4.1 Application of Relative Price Elasticity

DOE estimated shipments in each standards case using the relative price elasticities 

described above, along with the change in the relative price between a standards case and the 

base case. Because household income is the same in the standards case and the base case, it does 

not figure into the calculation of the change in the relative price. Note that in the following 

equation, the relative price and the relative price elasticity are functions of the year because both 

change with time.c 

( ) ( ( ) ( ) ( )) (1 ( ) ( )) _

_ _ _ _ Ship j Rpl j NI j M j e j RP j STD p = BASE p + BASE p + BASE p × RP ×∆

Where:

ShipSTD_p(j) = total shipments under the standards case of product p in year j, 

RplBASE_p(j) = units of product p under the base case retired and replaced in year j,

NIBASE_p(j) = number of new construction installations under the base case of product p in year 

j,

MBASE_p(j) = units installed in market M under the base case of product p in year j (M

represents purchases for existing homes for standard-size freezers, and purchase 

of an additional refrigerator for standard-size refrigerators),

eRP(j)= relative price elasticity in year j (equals -0.34 for year 1), and 

ΔRP(j)= change in relative price due to a standard level in year j.

9.5 AFFECTED STOCK

In addition to the forecast of product shipments under both the base case and the 

standards case, the affected stock is a key output of DOE’s shipments models. The affected stock 

(stock that is affected by a standards level) consists of those in-service units that are purchased in 

or after the year the standard has taken effect, as described by the following equation:

∑

_

1

_

( ) ( ) ( )

j Std yr

age

p p p Aff Stock j Ship j Stock age

=

= +

 

c The relative price changes slightly over time because the lifetime operating costs are different for each vintage in 

the forecast period. Operating costs change slightly because forecasted energy prices are changing.
9-27

Where:

Aff Stockp(j) = affected stock of units of product p of all vintages that are in service in year j,

Shipp(j) = shipments of product p in year j, 

Stockp(j) = stock of units of product p of all vintages that are in service in year j,

age = age of the units (years), and

Std_yr = effective date of the standard.

For its analysis, DOE assumed that amended energy conservation standards will become 

effective in 2014. Thus, all appliances purchased starting in 2014 are affected by the standard 

level. 

9.6 SHIPMENTS FORECASTS IN STANDARDS CASES

This section presents the shipments forecasts for the trial standard levels that DOE 

considered for each of the refrigeration product types, as well as for the base case. The TSLs, 

which consist of a combination of specific efficiency levels for each product class, are described 

in chapter 10. The differences between the base case and standards case shipments forecasts 

represent the annual shipments reductions attributable to the standard levels.

Figure 9.6.1 shows the standard-size refrigerator-freezer shipment forecasts for the base 

case and for two standard levels for which an impact is evident. 
9-28

Figure 9.6.1 Standard-Size Refrigerator-Freezers: Base Case and 

Standards Case Shipments Forecasts

Figure 9.6.2 shows the standard-size freezer shipment forecasts for the base case and for 

several standard levels for which an impact is evident.
9-29

Figure 9.6.2 Standard-size Freezers: Base Case and Standards Case 

Shipments Forecasts

Figure 9.6.3 shows the compact refrigerator shipment forecasts for the base case and the 

considered TSLs. Similar impacts are seen for compact freezers (details may be found in the 

NIA spreadsheet for compact freezers).
9-30

0.0

1.0

2.0

3.0

4.0

5.0

6.0

7.0

199019931996

1999

2002200520082011

2014

201720202023

2026

2029

2032

2035

2038

2041

Miliions

CSL6

CSL7

CSL8

Base

Figure 9.6.3 Compact Refrigerators: Base Case and Standards Case 

Shipments Forecasts
9-31

REFERENCES

 1

 U.S. Department of Energy-Energy Information Administration. Annual Energy Outlook 

2010 With Projections to 2035.April 2010. Washington, DC. DOE/EIA-0383(2010). 

<http://www.eia.doe.gov/oiaf/aeo/pdf/0383(2010).pdf>

2 Statistical Review. Appliance Magazine, April, 1993.

3 Statistical Review. Appliance Magazine, April, 1990.

4 Statistical Review. Appliance Magazine, April, 1982.

5 Association of Home Appliance Manufacturers. AHAM 2005 Fact Book, 2005. Washington, 

DC. 

6 Association of Home Appliance Manufacturers. AHAM 2003 Fact Book, 2003. Washington, 

DC. 

7 Association of Home Appliance Manufacturers. Aggregated Refrigerator‐ Freezer Shipments 

and Efficiency Data for DOE Refrigerator‐ Freezer Energy Efficiency Standards 

Rulemaking, January 16, 2009. Memo to Detlef Westphalen, Navigant Consulting, Inc.

8 U.S. Department of Energy–Energy Information Administration. Residential Energy 

Consumption Survey. Washington, D.C. Surveys for 1990, 1993, 1997, 2001, and 2005. 

<www.eia.doe.gov/emeu/recs/contents.html>

9 Statistical Review. Appliance Magazine, April, 1997.

10 American Hotel & Lodging Association. 2008 Lodging Survey: Lodging Services, Facilities, 

and Trends, 2008. Washington, DC. p. 52, Percentage of Hotels with Refrigerators in 

Room.

11 U.S. Department of Energy–Energy Information Administration. Commercial Building

Energy Consumption Survey. Washington, D.C. Surveys for 1999 and 2003. 

<http://www.eia.doe.gov/emeu/cbecs/>

12 California Energy Commission. Appliances Database—Refrigeration. 

<www.energy.ca.gov/appliances/database/excel_based_files/Refrigeration/> (Last accessed 

April 25, 2009.)

13 California Energy Commission. Appliances Database—Refrigeration. 

<www.energy.ca.gov/appliances/database/excel_based_files/Refrigeration/> (Last accessed 

April 25, 2009.)

14 Train, K., "Discount Rates in Consumers' Energy-Related Decisions," Energy: The 

International Journal, Vol. 10, No. 12, 1985, pp. 1243-1253.
9-32

 15 S. Hymans. Consumer Durable Spending: Explanation and Prediction, Brookings Papers on 

Economic Activity, 1971. Vol. 1971, No. 1, pp. 234-239.
10-i

CHAPTER 10: NATIONAL IMPACT ANALYSIS

TABLE OF CONTENTS

10.1 INTRODUCTION .......................................................................................................... 10-1

10.1.1 Alternative Scenarios..................................................................................................... 10-2

10.2 FORECASTED EFFICIENCIES FOR BASE AND STANDARDS CASES ............... 10-2

10.2.1 Method and Assumptions .............................................................................................. 10-3

10.2.1.1 Base Case ...................................................................................................... 10-3

10.2.1.2 Standards Cases ............................................................................................ 10-7

10.3 NATIONAL ENERGY SAVINGS .............................................................................. 10-14

10.3.1 Definition ..................................................................................................................... 10-14

10.3.2 Inputs............................................................................................................................ 10-15

10.3.2.1 Shipments.................................................................................................... 10-16

10.3.2.2 Equipment Stock......................................................................................... 10-16

10.3.2.3 Annual Energy Consumption per Unit ....................................................... 10-16

10.3.2.4 National Annual Energy Consumption....................................................... 10-17

10.3.2.5 Site-to-Source Conversion Factors............................................................. 10-17

10.4 NET PRESENT VALUE.............................................................................................. 10-18

10.4.1 Definition ..................................................................................................................... 10-18

10.4.2 Inputs............................................................................................................................ 10-20

10.4.2.1 Average Annual Product Cost .................................................................... 10-20

10.4.2.2 Annual Operating Cost Savings per Unit.................................................... 10-22

10.4.2.3 Total Annual Increases in Product Cost...................................................... 10-22

10.4.2.4 Total Annual Savings in Operating Cost .................................................... 10-22

10.4.2.5 Discount Factor........................................................................................... 10-22

10.4.2.6 Present Value of Costs................................................................................ 10-23

10.4.2.7 Present Value of Savings............................................................................ 10-23

10.5 NES AND NPV RESULTS.......................................................................................... 10-23

10.5.1 Summary of Inputs....................................................................................................... 10-23

10.5.2 National Energy Savings Results by Efficiency Level................................................ 10-24

10.5.3 Annual Costs and Savings ........................................................................................... 10-29

10.5.4 Consumer Net Present Value Results by Efficiency Level ......................................... 10-30

10.6 NES AND NPV RESULTS BY TRIAL STANDARD LEVEL .................................. 10-32

10.6.1 Trial Standard Levels................................................................................................... 10-32

10.6.2 National Energy Savings Results by Trial Standard Level.......................................... 10-35

10.6.3 Consumer Net Present Value Results by Trial Standard Level ................................... 10-37

LIST OF TABLES

Table 10.2.1 Standard-Size Refrigerator-Freezers: Average Payback Period Relative to 

Current Standard Level by Efficiency Level ..................................................... 10-3
10-ii

Table 10.2.2 Standard-Size Freezers: Average Payback Period Relative to Current 

Standard Level by Efficiency Level .................................................................. 10-4

Table 10.2.3 Compact Refrigeration Products: Average Payback Period Relative to 

Current Standard Level by Efficiency Level ..................................................... 10-5

Table 10.2.4 Standard-Size Refrigerator-Freezers: Base-Case Efficiency Distributions....... 10-5

Table 10.2.5 Standard-Size Freezers: Base-Case Efficiency Distributions............................ 10-6

Table 10.2.6 Compact Refrigeration Products: Base-Case Efficiency Distributions............. 10-7

Table 10.2.7 Top-Mount Refrigerator-Freezers: Efficiency Distributions in 2014 for 

Standards Cases ................................................................................................. 10-8

Table 10.2.8 Top-Mount Refrigerator-Freezers: Efficiency Distributions in 2021 for 

Candidate Standard Levels ................................................................................ 10-9

Table 10.2.9 Bottom-Mount Refrigerator-Freezers: Efficiency Distributions in 2014 for 

Candidate Standard Levels ................................................................................ 10-9

Table 10.2.10 Bottom-Mount Refrigerator-Freezers: Efficiency Distributions in 2021 for 

Candidate Standard Levels .............................................................................. 10-10

Table 10.2.11 Side-by Side Refrigerator-Freezers: Efficiency Distributions in 2014 for 

Candidate Standard Levels .............................................................................. 10-10

Table 10.2.12 Side-by Side Refrigerator-Freezers: Efficiency Distributions in 2021 for 

Candidate Standard Levels .............................................................................. 10-11

Table 10.2.13 Upright Freezers: Efficiency Distributions in 2014 for Candidate Standard 

Levels............................................................................................................... 10-11

Table 10.2.14 Upright Freezers: Efficiency Distributions in 2021 for Candidate Standard 

Levels............................................................................................................... 10-12

Table 10.2.15 Chest Freezers: Efficiency Distributions in 2014 for Candidate Standard 

Levels............................................................................................................... 10-12

Table 10.2.16 Chest Freezers: Efficiency Distributions in 2021 for Candidate Standard 

Levels............................................................................................................... 10-12

Table 10.2.17 Compact Refrigerators: Efficiency Distributions in 2014 and 2021 for 

Candidate Standard Levels .............................................................................. 10-13

Table 10.2.18 Compact Freezers: Efficiency Distributions in 2014 and 2021 for 

Candidate Standard Levels .............................................................................. 10-13

Table 10.3.1 Standard-Size Refrigerator-Freezers: Shipment-Weighted Average Annual 

Energy Use in 2014 for Base and Standards Cases......................................... 10-16

Table 10.3.2 Standard-Size Freezers: Shipment-Weighted Average Annual Energy 

Consumption in 2014 for Base and Standards Cases....................................... 10-17

Table 10.3.3 Compact Refrigeration Products: Shipment-Weighted Average Energy 

Consumption in 2014 for Base and Standards Cases....................................... 10-17

Table 10.4.1 Standard-Size Refrigerator-Freezers: Shipment-Weighted Average 

Product Cost in 2014 for Base and Candidate Standard Levels ...................... 10-20

Table 10.4.2 Standard-Size Freezers: Shipment-Weighted Average Product Cost in 

2014 for Base and Candidate Standard Levels................................................ 10-21

Table 10.4.3 Compact Refrigerators and Freezers: Shipment-Weighted Average 

Product Cost in 2014 for Base and Candidate Standard Levels ...................... 10-21

Table 10.5.1 Inputs to Calculation of National Energy Savings and Net Present Value...... 10-24

Table 10.5.2 Standard-Size Refrigerator-Freezers: Cumulative National Energy Savings.. 10-25
10-iii

Table 10.5.3 Standard-Size Refrigerator-Freezers: Discounted Cumulative National 

Energy Savings ................................................................................................ 10-25

Table 10.5.4 Standard-Size Freezers: Cumulative National Energy Savings....................... 10-26

Table 10.5.5 Standard-Size Freezers: Discounted Cumulative National Energy Savings.... 10-26

Table 10.5.6 Compact Refrigeration Products: Cumulative National Energy Savings........ 10-27

Table 10.5.7 Compact Refrigeration Products: Discounted Cumulative National Energy 

Savings............................................................................................................. 10-27

Table 10.5.8 Built-In Refrigeration Products: Cumulative National Energy Savings.......... 10-28

Table 10.5.9 Built-In Refrigeration Products: Discounted Cumulative National Energy 

Savings............................................................................................................. 10-28

Table 10.5.10 Standard-Size Refrigerator-Freezers: Cumulative Net Present Value of 

Consumer Benefit ............................................................................................ 10-30

Table 10.5.11 Standard-Size Freezers: Cumulative Net Present Value of Consumer 

Benefit.............................................................................................................. 10-31

Table 10.5.12 Compact Refrigeration Products: Cumulative Net Present Value of 

Consumer Benefit ............................................................................................ 10-31

Table 10.5.13 Built-In Refrigeration Products: Cumulative Net Present Value of 

Consumer Benefit ............................................................................................ 10-32

Table 10.6.1 Trial Standard Levels for Standard-Size Refrigerator-Freezers ...................... 10-33

Table 10.6.2 Trial Standard Levels for Standard-Size Freezers........................................... 10-34

Table 10.6.3 Trial Standard Levels for Compact Refrigeration Products ............................ 10-34

Table 10.6.4 Trial Standard Levels for Built-in Refrigeration Products .............................. 10-35

Table 10.6.5 Standard-Size Refrigerator-Freezers: Cumulative National Energy Savings 

in Quads........................................................................................................... 10-36

Table 10.6.6 Standard-Size Freezers: Cumulative National Energy Savings in Quads ....... 10-36

Table 10.6.7 Compact Refrigeration Products: Cumulative National Energy Savings in 

Quads ............................................................................................................... 10-36

Table 10.6.8 Built-In Refrigeration Products: Cumulative National Energy Savings in 

Quads ............................................................................................................... 10-37

Table 10.6.9 Cumulative Net Present Value of Consumer Benefits for Standard-Size 

Refrigerator-Freezers, 3-Percent Discount Rate .............................................. 10-37

Table 10.6.10 Cumulative Net Present Value of Consumer Benefits for Standard-Size 

Refrigerator-Freezers, 7-Percent Discount Rate .............................................. 10-38

Table 10.6.11 Cumulative Net Present Value of Consumer Benefits for Standard-Size 

Freezers, 3-Percent Discount Rate................................................................... 10-38

Table 10.6.12 Cumulative Net Present Value of Consumer Benefits for Standard-Size 

Freezers, 7-Percent Discount Rate................................................................... 10-38

Table 10.6.13 Cumulative Net Present Value of Consumer Benefits for Compact 

Refrigeration Products, 3-Percent Discount Rate ............................................ 10-39

Table 10.6.14 Cumulative Net Present Value of Consumer Benefits for Compact 

Refrigeration Products, 7-Percent Discount Rate ............................................ 10-39

Table 10.6.15 Cumulative Net Present Value of Consumer Benefits for Built-In 

Refrigeration Products, 3-Percent Discount Rate ............................................ 10-40

Table 10.6.16 Cumulative Net Present Value of Consumer Benefits for Built-In 

Refrigeration Products, 7-Percent Discount Rate ............................................ 10-40
10-iv

LIST OF FIGURES

Figure 10.5.1 Non-Discounted Annual Increases in Installed Cost and Savings in 

Operating Cost for Product Class 3 at Efficiency Level 3............................... 10-29
10-1

CHAPTER 10. NATIONAL IMPACT ANALYSIS

10.1 INTRODUCTION

This chapter describes the method the U.S. Department of Energy (DOE) used to conduct 

a national impacts analysis (NIA) of potential standard levels for residential refrigeration 

products. DOE evaluated the following impacts: (1) national energy savings (NES) attributable 

to each possible standard, (2) monetary value of those energy savings to consumers of the 

considered products, (3) increased total installed cost of the products because of standards, and 

(4) net present value (NPV) of energy savings (the difference between the value of energy 

savings and increased total installed cost). 

DOE determined both the NES and NPV for all the efficiency levels considered for 

residential refrigeration products. DOE performed all calculations for each considered product 

using a Microsoft Excel spreadsheet model, which is accessible on the Internet.

<www.eere.energy.gov/buildings/appliance_standards/> The spreadsheets combine the 

calculations for determining the NES and NPV for each considered product with input from the 

appropriate shipments model. As discussed in chapter 16, the NIA model also performs the 

calculations for the Regulatory Impact Analysis. Details and instructions for using the NIA

model are provided in appendix 10-A. 

Chapter 9 provides a detailed description of the shipments models that DOE used to 

forecast future purchases of the considered products. Chapter 9 includes a description of the 

sensitivity of shipments to total installed cost and operating cost, and how DOE captured those 

sensitivities within the model. 

In its NOPR analysis, DOE studied 11 representative product classes in detail. For the 

NIA, each of these classes represents a product category that also contains other product classes. 

DOE assigned each of the product classes to one of these 11 product categories. To estimate the 

national impacts of potential standards for all the product classes considered in this rulemaking, 

DOE applied the product cost and annual energy consumption of each representative product 

class to all product classes within its category. The following list indicates which product classes 

are associated with each product category for purposes of analysis. In each case, the cost curve 

for the representative product class provided the best match for the other classes with which it is 

associated.

• Top-mount refrigerator-freezers: product classes 1, 1A, 2, 3, 3A, 3I and 6; 

represented by product class 3.

• Bottom-mount refrigerator-freezers: product classes 5, 5A and 5I; represented by 

product class 5.

• Side-by-side refrigerator-freezers: product classes 4, 4I and 7; represented by product 

class 7.

• Upright freezers: product class 9 only.
10-2

• Chest freezers: product classes 8,

a

• Compact refrigerators: product classes 11, 11A, and 12; represented by product class 

11.

10, and 10A; represented by product class 10.

• Compact freezers: product classes 16, 17, and 18, and also 13, 13A, 14, and 15b

• Built-in all refrigerators: product class 3A-BI only.

; 

represented by product class 18.

• Built-in bottom-mount refrigerator-freezers: product classes 5-BI and 5I-BI; 

represented by product class 5-BI.

• Built-in side-by-side refrigerator-freezers: product classes 4-BI, 4I-BI and 7-BI; 

represented by product class 7-BI.

• Built-in upright freezers: product class 9-BI only.

In the presentation of NIA results, DOE groups the product classes according to type of 

refrigeration product and door style. That is, upright freezers are all grouped together, as are 

compact refrigerators.

10.1.1 Alternative Scenarios

The results in this chapter were calculated using selected inputs from the Reference case 

in EIA’s Annual Energy Outlook 2010 (AEO 2010).

1

10.2 FORECASTED EFFICIENCIES FOR BASE AND STANDARDS CASES 

DOE also calculated NIA results using 

inputs from the High Economic Growth case and the Low Economic Growth case in AEO 2010. 

Appendix 10-B presents the NIA results in the alternative economic growth cases.

A key factor in estimating NES and NPV is the trend in energy efficiency forecasted for 

the base case (without new standards) and each of the standards cases. In calculating the NES, 

per-unit annual energy consumption is a direct function of product efficiency. For the NPV, two 

inputs depend on efficiency. The first input, the per-unit total installed cost, is a direct function 

of efficiency. The per-unit annual operating cost, because it is a function of the per-unit annual 

consumption, is indirectly dependent on product efficiency. This section describes the method 

DOE used to forecast the energy efficiency distribution of the considered products under the base 

case and each of the potential standards cases. 

 

a Product class 8, “upright freezers with manual defrost,” is grouped with the “chest freezer” category because 

products in this class are more technologically similar to chest freezers.

b Product classes 13, 13A, 14, and 15 (compact refrigerators and refrigerator-freezers) are grouped with the 

“compact freezer” category because products in this class are more technologically similar to compact freezers.
10-3

10.2.1 Method and Assumptions

10.2.1.1 Base Case

The base-case efficiency distribution projected for 2014 was described in chapter 8. The 

distribution was largely based on ENERGY STAR market shares for each product class. To 

project the distribution after 2014, DOE considered the potential for changes in ENERGY STAR 

qualification levels. DOE assumed that, in the absence of a new standard, the ENERGY STAR 

program would consider revision of its qualification levels regardless of the market share in 

2014. The ENERGY STAR program uses several criteria when setting a minimum product 

efficiency level for qualification. One important factor is that the average payback period 

compared to the current standard level should not exceed 5 years. Using the payback period 

calculation described in chapter 8, DOE applied this criterion to all product classes in order to 

evaluate whether the current ENERGY STAR efficiency levels might be increased in the future.

Tables 10.2.1, 10.2.2 and 10.2.3 show the payback period relative to the baseline 

efficiency level (current standard). For standard-sized refrigerator-freezers, the highest efficiency 

level with a payback period of 5 years or less corresponds to the current ENERGY STAR level 

for product classes 5 and 7, but for product class 3, it corresponds to the 15% efficiency level, 

which is lower than the current ENERGY STAR level. Because it is unlikely that the ENERGY 

STAR program would reduce its qualifying efficiency level, DOE assumed the efficiency level 

would not be reduced (from 20% less than baseline) for product class 3. Thus, for standard-sized 

refrigerator-freezers, DOE assumed no change in the ENERGY STAR levels in the base case.

Table 10.2.1 Standard-Size Refrigerator-Freezers: Average Payback Period Relative to 

Current Standard Level by Efficiency Level

Payback period (years)

Efficiency Level

(% less than baseline 

energy use

Product Class 3:

Top-Mount 

RefrigeratorFreezer

Product Class 5:

Bottom-Mount 

RefrigeratorFreezer

Product Class 7:

Side-by-Side 

Refrigerator-Freezer 

with TTD

1 (10) 2.2 1.9 2.3

2 (15) 2.5†† 2.1 2.3

3 (20)* 7.0 2.9†† 3.5††

4 (25) 8.1 5.4 5.7

5 (30) 11.3 8.7 9.3

6 (36/36/33)† 12.7 9.8 10.1

* Meets current ENERGY STAR criteria. 

† Energy savings relative to baseline varies with product class.

†† Indicates maximum efficiency level with payback period of 5 years or less.
10-4

For standard-sized freezers, DOE found that an efficiency level of 20% below baseline 

was justified using the 5-year payback criterion, higher than the current ENERGY STAR level of 

10%. Thus, for standard-sized freezers, DOE assumed the ENERGY STAR efficiency level 

would increase to level 3 starting in 2014.

For compact refrigeration products, DOE found that for product class 11, an efficiency 

level of 30% below baseline was justified using the 5-year payback criterion, higher than the 

current 20% qualifying level. For product class 18, an efficiency level of only 15% was justified. 

However, as for product class 3 above, DOE assumed the ENERGY STAR level for product 

class 18 would not be reduced from the current 20% level. Thus, DOE assumed the ENERGY 

STAR efficiency level will increase to level 5 for product class 11, but will not change for

product class 18.

Table 10.2.2 Standard-Size Freezers: Average Payback Period Relative to Current 

Standard Level by Efficiency Level

Payback period (years)

Efficiency Level

(% less than baseline 

energy use

Product Class 9:

Upright Freezer

Product Class 10:

Chest Freezer

1 (10)* 2.3 3.1

2 (15) 3.9 3.9

3 (20) 4.5** 4.5**

4 (25) 5.5 8.9

5 (30) 6.0 9.1

6 (35) 8.1 13.0

7 (40/41)

† 10.8 16.5

8 (44) 16.4 n/a

* Meets current ENERGY STAR criteria. 

** Indicates maximum efficiency level with payback period of 5 

years or less.

† Energy savings relative to baseline varies with product class
10-5

Table 10.2.3 Compact Refrigeration Products: Average Payback Period Relative to 

Current Standard Level by Efficiency Level

Payback period (years)

Efficiency Level

(% less than 

baseline energy use)

Product Class 11:

Compact 

Refrigerators

Product Class 18:

Compact Freezers

1 (10) 1.9 2.2

2 (15) 2.2 4.1**

3 (20)* 2.7 9.6

4 (25) 3.8 9.0

5 (30) 4.3** 8.6

6 (35) 6.3 8.1

7 (40/42) † 6.2 11.4

8 (45) 8.0 n/a

9 (50) >8.0 n/a

10 (59) >8.0 n/a

* Meets current ENERGY STAR criteria. 

**Indicates maximum efficiency level with payback period of 5 years 

or less.

† Energy savings relative to baseline varies with product class

In projecting the market shares for ENERGY STAR standard-sized refrigerator-freezers 

beyond 2014, DOE examined historical trends, and estimated that ENERGY STAR market 

shares would reach the 2007 levels (at the older ENERGY STAR efficiency level) by 2021, 

except in the case of product class 7, where the projected 2014 market share exceeds the 2007 

market share. In the latter case, DOE assumed no change in ENERGY STAR market shares. The 

projected shares are given in Table 10.2.4.

Table 10.2.4 Standard-Size Refrigerator-Freezers: Base-Case Efficiency Distributions

Efficiency 

Level

(% less 

than 

baseline 

energy 

use)

Product Class 3: 

Top-Mount 

Refrigerator-Freezer

Product Class 5:

Bottom-Mount RefrigeratorFreezer

Product Class 7: 

Side-by-Side RefrigeratorFreezer with TTD*

Market Share

%

Market Share

%

Market Share

%

2007 2014 2021 2007 2014 2021 2007 2014 2021
10-6

Baseline 80.6 78.2 80.6 11.8 13.0 11.8 25.0 21.7 21.7

1 (10) 5.9 4.2 5.9 0.1 0.1 0.1 43.0 26.4 26.4

2 (15) 13.2 9.4 0.1 69.8 19.3 0.0 30.3 15.0 15.0

3 (20) 0.2† 8.3† 13.4† 18.3† 67.7† 88.1† 1.7† 37.0† 37.0†

4 (25) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

5 and 

higher 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

* Through-the-door ice service.

† Meets current (2008) ENERGY STAR criteria.

For standard-sized freezers, DOE assumed there would be a linear increase in ENERGY 

STAR market share, reaching in 2021 the average of the 2007 shares (at the older ENERGY 

STAR efficiency level) and the projected new ENERGY STAR market share levels in 2014. See 

Table 10.2.5.

Table 10.2.5 Standard-Size Freezers: Base-Case Efficiency Distributions

Efficiency 

Level

(% less 

than 

baseline 

energy 

use)

Product Class 9:

Upright Freezer

Product Class 10:

Chest Freezer

Market Share

%

Market Share

%

2007 2014 2021 2007 2014 2021

Baseline 81.5 81.5 81.5 84.6 84.6 84.6

1 (10) 17.0* 17.0 8.5 14.3* 14.3 7.2

2 (15) 1.0 1.0 0.5 0.8 0.8 0.4

3 (20) 0.1 0.1† 9.1† 0.0 0.0† 7.6†

4 (25) 0.2 0.2 0.2 0.0 0.0 0.0

5 (30) 0.2 0.2 0.2 0.0 0.0 0.0

6 (35) 0.0 0.0 0.0 0.4 0.4 0.4

7 and 

higher 0.0 0.0 0.0 0.0 0.0 0.0

* Meets current ENERGY STAR criteria.

† Meets projected new ENERGY STAR criteria.

For compact refrigeration products, for product class 11, DOE assumed there would be 

only a slight increase in ENERGY STAR market share between 2014 and 2021 because of the 

relatively high ENERGY STAR level (30% below baseline). For product class 18, DOE 

assumed no change in market share beyond 2014. See Table 10.2.6.
10-7

Table 10.2.6 Compact Refrigeration Products: Base-Case Efficiency Distributions

Efficiency 

Level

(% less 

than 

baseline 

energy 

use)

Product Class 11: 

Compact Refrigerator

Product Class 18: 

Compact Freezer

Market Share

%

Market Share

%

2007 2014 2021 2007 2014 2021

Baseline 97.1 98.5 98.5 95.4 95.4 95.4

1 (10) 0.3 0.3 0.3 4.6 4.6 4.6

2 (15) 0.0 0.0 0.0 0.0 0.0 0.0

3 (20) 0.9* 0.5 0.2 0.0* 0.0* 0.0*

4 (25) 0.2 0.1 0.1 0.0 0.0 0.0

5 (30) 1.5 0.8 † 1.0 † 0.0 0.0 0.0

6 and 

higher 0.0 0.0 0.0 0.0 0.0 0.0

* Meets current ENERGY STAR criteria.

† Meets projected new ENERGY STAR criteria.

For all product classes, rather than make long-run projections based on limited 

information, DOE assumed there would be no further change in market shares between 2021 and 

the end of the forecast period. DOE recognizes that some change in shares is likely to occur in 

reality. However, since DOE uses the same assumption in the standards cases, the accuracy of 

the assumption makes no difference to the analysis of energy savings.

10.2.1.2 Standards Cases

To determine efficiency distributions for cases in which a potential standard applies for 

2014 and beyond, DOE assumed that product efficiencies in the base case that did not meet the 

standard under consideration would roll up to meet the new standard in 2014. DOE further 

assumed that the ENERGY STAR program will continue to promote high-efficiency appliances 

after revised standards are introduced in 2014, and that product market shares above a given 

standard level may shift.

As it did for the base case, DOE assumed that in the case of amended standards, the 

ENERGY STAR program would re-evaluate its qualifying levels for all product classes in 2014 

using the 5-year payback period criterion. For each candidate standard level (CSL), DOE 

identified the maximum efficiency level with a payback of 5 years or less, relative to the lowest 

efficiency level at each CSL. If such a level was below the current ENERGY STAR level, DOE 

maintained the current level. At higher CSLs, there becomes a point at which no efficiency level 

has a payback period of less than 5 years. DOE assumed that the ENERGY STAR program 

would be suspended with standards at higher CSLs on a product-class specific basis. This occurs 

for all product classes at CSL 3 and above; for product classes 9 and 10, it occurs at lower CSLs.
10-8

In projecting ENERGY STAR market shares beyond 2014, DOE used a similar approach 

as described above for the base case. To maintain consistency with the base case, for the 

standards cases DOE assumed that after 2021 the market shares at each efficiency level would 

remain constant at the 2021 values.

Tables 10.2.7 through 10.2.12 show the efficiency distributions for 2014 and 2021 that 

DOE used for the standard-size refrigerator-freezer product classes under each standards case. 

The tables include the shipment-weighted energy use factor (SWEUF) associated with each 

standards case.

Table 10.2.7 Top-Mount Refrigerator-Freezers: Efficiency Distributions in 2014 for 

Standards Cases

Efficiency 

Level 

(% less 

than 

baseline 

energy use)

Energy 

Use 

Factor

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6

Baseline 1.00 78.2 - - - - - -

1 (10) 0.90 4.2 82.3 - - - - -

2 (15) 0.85 9.4 9.4 91.7 - - - -

3 (20) 0.80 8.3 8.3 8.3 100.0 - - -

4 (25) 0.75 0.0 0.0 0.0 0.0 100.0 - -

5 (30) 0.70 0.0 0.0 0.0 0.0 0.0 100.0 -

6 (36) 0.64 0.0 0.0 0.0 0.0 0.0 0.0 100.0

SWEUF 0.965 0.887 0.846 0.800 0.750 0.700 0.640
10-9

Table 10.2.8 Top-Mount Refrigerator-Freezers: Efficiency Distributions in 2021 for 

Candidate Standard Levels

Efficiency 

Level 

(% less 

than

baseline 

energy 

use)

Energy 

Use 

Factor

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6

Baseline 1.00 80.6 - - - -

1 (10) 0.90 5.9 86.5 - - - -

2 (15) 0.85 0.1 0.1 86.6 - - - -

3 (20) 0.80 13.4 13.4 13.4 100.0 - - -

4 (25) 0.75 0.0 0.0 0.0 0.0 100.0 - -

5 (30) 0.70 0.0 0.0 0.0 0.0 0.0 100.0 -

6 (36) 0.64 0.0 0.0 0.0 0.0 0.0 0.0 100.0

SWEUF 0.967 0.887 0.843 0.800 0.750 0.700 0.640

Table 10.2.9 Bottom-Mount Refrigerator-Freezers: Efficiency Distributions in 2014 for 

Candidate Standard Levels

Efficiency 

Level 

(% less 

than 

baseline 

energy 

use)

Energy 

Use 

Factor

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6

Baseline 1.00 13.0 - - - - - -

1 (10) 0.90 0.1 13.1 - - - - -

2 (15) 0.85 19.3 19.3 32.4 - - - -

3 (20) 0.80 67.7 67.7 67.7 100.0 - - -

4 (25) 0.75 0.0 0.0 0.0 0.0 100.0 - -

5 (30) 0.70 0.0 0.0 0.0 0.0 0.0 100.0 -

6 (36) 0.64 0.0 0.0 0.0 0.0 0.0 0.0 100.0

SWEUF 0.836 0.823 0.816 0.800 0.750 0.700 0.640
10-10

Table 10.2.10 Bottom-Mount Refrigerator-Freezers: Efficiency Distributions in 2021 

for Candidate Standard Levels

Efficiency 

Level 

(% less 

than 

baseline 

energy 

use)

Energy 

Use 

Factor

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6

Baseline 1.00 11.8 - - - -

1 (10) 0.90 0.1 11.9 - - - -

2 (15) 0.85 0.0 0.0 11.9 - - - -

3 (20) 0.80 88.1 88.1 88.1 100.0 - - -

4 (25) 0.75 0.0 0.0 0.0 0.0 100.0 - -

5 (30) 0.70 0.0 0.0 0.0 0.0 0.0 100.0 -

6 (36) 0.64 0.0 0.0 0.0 0.0 0.0 0.0 100.0

SWEUF 0.824 0.812 0.806 0.800 0.750 0.700 0.640

Table 10.2.11 Side-by Side Refrigerator-Freezers: Efficiency Distributions in 2014 for 

Candidate Standard Levels

Efficiency 

Level 

(% less 

than 

baseline 

energy 

use)

Energy 

Use 

Factor

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6

Baseline 1.00 21.7 - - - - - -

1 (10) 0.90 26.4 48.1 - - - - -

2 (15) 0.85 15.0 15.0 63.1 - - - -

3 (20) 0.80 37.0 37.0 37.0 100.0 - - -

4 (25) 0.75 0.0 0.0 0.0 0.0 100.0 - -

5 (30) 0.70 0.0 0.0 0.0 0.0 0.0 100.0 -

6 (33) 0.67 0.0 0.0 0.0 0.0 0.0 0.0 100.0

SWEUF 0.877 0.856 0.832 0.800 0.750 0.700 0.670
10-11

Table 10.2.12 Side-by Side Refrigerator-Freezers: Efficiency Distributions in 2021 for 

Candidate Standard Levels

Efficiency 

Level 

(% less 

than 

baseline 

energy 

use)

Energy 

Use 

Factor

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6

Baseline 1.00 21.7 - - - - - -

1 (10) 0.90 26.4 48.1 - - - - -

2 (15) 0.85 15.0 15.0 63.1 - - - -

3 (20) 0.80 37.0 37.0 37.0 100.0 - - -

4 (25) 0.75 0.0 0.0 0.0 0.0 100.0 - -

5 (30) 0.70 0.0 0.0 0.0 0.0 0.0 100.0 -

6 (33) 0.67 0.0 0.0 0.0 0.0 0.0 0.0 100.0

SWEUF 0.877 0.856 0.832 0.800 0.750 0.700 0.670

Tables 10.2.13 through 10.2.16 show the efficiency distributions in 2014 and 2021 that 

DOE used for each standards case for the standard-sized freezer product classes. The tables 

include the shipment-weighted energy use factor (SWEUF) associated with each standards case.

Table 10.2.13 Upright Freezers: Efficiency Distributions in 2014 for Candidate 

Standard Levels

Efficiency 

Level

(% less 

than 

baseline 

energy use)

Energy 

Use 

Factor

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6 7 8

Baseline 1.00 81.5 - - - - - - - -

1 (10) 0.90 17.0 98.5 - - - - - - -

2 (15) 0.85 1.0 1.0 99.5 - - - - - -

3 (20) 0.80 0.1 0.1 0.1 99.6 - - - - -

4 (25) 0.75 0.2 0.2 0.2 0.2 99.8 - - - -

5 (30) 0.70 0.2 0.2 0.2 0.2 0.2 100.0 - - -

6 (35) 0.65 0.0 0.0 0.0 0.0 0.0 0.0 100.0 - -

7 (40) 0.60 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 -

8 (44) 0.56 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0

SWEUF 0.980 0.899 0.849 0.800 0.750 0.700 0.650 0.600 0.560
10-12

Table 10.2.14 Upright Freezers: Efficiency Distributions in 2021 for Candidate 

Standard Levels

Efficiency 

Level

(% less

than 

baseline 

energy use)

Energy 

Use 

Factor

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6 7 8

Baseline 1.00 81.5

1 (10) 0.90 8.5 98.5

2 (15) 0.85 0.5 1.0 99.5

3 (20) 0.80 9.1 0.1 0.1 99.6

4 (25) 0.75 0.2 0.2 0.2 0.2 99.8

5 (30) 0.70 0.2 0.2 0.2 0.2 0.2 100.0

6 (35) 0.65 0.0 0.0 0.0 0.0 0.0 0.0 100.0

7 (40) 0.60 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0

8 (44) 0.56 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0

SWEUF 0.971 0.899 0.849 0.800 0.750 0.700 0.650 0.600 0.560

Table 10.2.15 Chest Freezers: Efficiency Distributions in 2014 for Candidate Standard 

Levels

Efficiency 

Level

(% less 

than 

baseline 

energy use)

Energy 

Use 

Factor

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6

7

Baseline 1.00 84.6

1 (10) 0.90 14.3 98.9

2 (15) 0.85 0.8 0.8 99.7

3 (20) 0.80 0.0 0.0 0.0 99.7

4 (25) 0.75 0.0 0.0 0.0 0.0 99.7

5 (30) 0.70 0.0 0.0 0.0 0.0 0.0 99.7

6 (35) 0.65 0.4 0.4 0.4 0.4 0.4 0.4 100.0

7 (41) 0.59 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0

SWEUF 0.983 0.899 0.849 0.799 0.750 0.700 0.650 0.590

Table 10.2.16 Chest Freezers: Efficiency Distributions in 2021 for Candidate Standard 

Levels

Efficiency 

Level

(% less than 

Energy 

Use 

Factor

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6 7
10-13

baseline 

energy use)

Baseline 1.00 84.6

1 (10) 0.90 7.2 98.8

2 (15) 0.85 0.4 0.8 99.6

3 (20) 0.80 7.6 0.0 0.0 99.6

4 (25) 0.75 0.0 0.0 0.0 0.0 99.6

5 (30) 0.70 0.0 0.0 0.0 0.0 0.0 99.6

6 (35) 0.65 0.4 0.4 0.4 0.4 0.4 0.4 100.0

7 (41) 0.59 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0

SWEUF 0.976 0.899 0.849 0.799 0.750 0.700 0.650 0.590

Tables 10.2.17 and 10.2.18 show the efficiency distributions in 2014 and 2021 that DOE 

used for all potential standards cases for compact refrigeration product classes. The tables 

include the shipment-weighted energy use factor (SWEUF) associated with each standards case.

Table 10.2.17 Compact Refrigerators: Efficiency Distributions in 2014 and 2021 for 

Candidate Standard Levels

Table 10.2.18 Compact Freezers: Efficiency Distributions in 2014 and 2021 for 

Candidate Standard Levels

Efficiency Energy Market Share %

Efficiency 

Level

(% less 

than 

baseline 

energy 

use)

Energy 

Use 

Factor

Market Share (%)

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6 7 8 9 10

Baseline 1.00 98.5 - - - - - - - - - -

1 (10) 0.90 0.3 98.7 - - - - - - - - -

2 (15) 0.85 0.0 0.0 98.7 - - - - - - - -

3 (20) 0.80 0.5 0.5 0.5 99.2 - - - - - - -

4 (25) 0.75 0.1 0.1 0.1 0.1 99.3 - - - - - -

5 (30) 0.70 0.8 0.8 0.8 0.8 0.8 100.0 - - - - -

6 (35) 0.65 0.0 0.0 0.0 0.0 0.0 0.0 100.0 - - - -

7 (40) 0.60 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 - - -

8 (45) 0.55 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 - -

9 (50) 0.50 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 -

10 (59) 0.41 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0

SWEUF 0.996 0.898 0.849 0.799 0.750 0.700 0.650 0.600 0.550 0.500 0.410
10-14

Level

(% less than 

baseline 

energy use)

Use 

Factor

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6 7

Baseline 1.00 95.4 - - - - - - -

1 (10) 0.90 4.6 100.0 - - - - - -

2 (15) 0.85 0.0 0.0 100.0 - - - - -

3 (20) 0.80 0.0 0.0 0.0 100.0 - - - -

4 (25) 0.75 0.0 0.0 0.0 0.0 100.0 - - -

5 (30) 0.70 0.0 0.0 0.0 0.0 0.0 100.0 - -

6 (35) 0.65 0.0 0.0 0.0 0.0 0.0 0.0 100.0 -

7 (42) 0.58 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0

SWEUF 0.995 0.900 0.850 0.800 0.750 0.700 0.650 0.580

10.3 NATIONAL ENERGY SAVINGS

DOE calculated the national energy savings associated with the difference between the 

base case and the case associated with each potential standard for the refrigeration products 

considered herein. DOE calculated cumulative energy savings throughout the forecast period, 

which extends from 2014 to 2044.

10.3.1 Definition 

The following equation shows that DOE calculated annual national energy savings (NES) 

as the difference between two projections: a base case (without new standards) and a standards 

case. Positive values of NES represent energy savings (that is, national annual energy 

consumption (AEC) under a standard is less than in the base case).

STD

_

BASE NESy = AEC AEC

Cumulative energy savings are the sum of annual national energy savings throughout the 

forecast period, which extends from the assumed effective date of new standards (2014) to 30 

years after that date (through 2043). 

DOE calculated the national annual site energy consumption by multiplying the number 

or stock of each product class (by vintage) by its unit energy consumption (UEC; also by 

vintage). The calculation of national annual energy consumption is represented by the following 

equation.

y = ∑ V ×UECV AEC STOCK

DOE defined the quantities for the above expressions as follows.
10-15

AEC = national annual energy consumption each year in quadrillion British thermal units 

(quads), summed over vintages of the product stock, STOCKV;

NES = annual national energy savings (quads);

STOCKV = stock of product (millions of units) of vintage V that survive in the year for which 

DOE calculated annual energy consumption;

UECV = annual energy consumption per product in kilowatt-hours (kWh);

V = year in which the product was purchased as a new unit; and 

y = year in the forecast.

Electricity consumption is converted from site energy to source energy (quads) by applying a 

time-dependent conversion factor.

The stock of a product depends on annual shipments and the lifetime of the product. As 

described in chapter 9, DOE projected product shipments under the base case and the standards 

cases. DOE projected that shipments under the standards cases would be slightly lower than 

under the base case, because DOE believes that the higher purchase cost of more efficient 

products would cause some consumers to forego purchasing new products. 

To avoid including savings attributable to shipments displaced because of standards, 

DOE used the projected standards-case shipments and, in turn, the standards-case stock, to 

calculate the annual energy consumption for the base case. 

10.3.2 Inputs 

The inputs to the calculation of national energy savings (NES) are:

• Shipments;

• product stock (STOCKV);

• annual energy consumption per unit (UEC);

• national annual energy consumption (AEC); and

• site-to-source conversion factor (src_conv).
10-16

10.3.2.1 Shipments

DOE forecasted shipments of each considered product class under the base case and all 

standards cases. Several factors affect forecasted shipments, including purchase cost, operating 

cost, and household income. As noted earlier, the increased cost of more efficient products 

causes some consumers to forego buying the products. Consequently, shipments forecasted 

under the standards cases are lower than under the base case. The method DOE used to calculate 

and generate the shipments forecasts for each considered product class is described in detail in 

Chapter 9, Shipments Analysis.

10.3.2.2 Equipment Stock

The equipment stock in a given year is the number of products shipped from earlier years 

that survive in that year. The NIA model tracks the number of the number of units shipped each 

year. DOE assumes that products have an increasing probability of retiring as they age. The 

probability of survival as a function of years since purchase is the survival function. Chapter 9 

provides additional details on the survival functions that DOE used for each product.

10.3.2.3 Annual Energy Consumption per Unit

DOE used the shipment-weighted energy use factors (SWEUFs) presented in section 10.2 

for the base case and standards cases, along with the data on annual energy consumption 

presented in chapters 7 and 8, to estimate the shipment-weighted average annual per-unit energy 

consumption under the base and each standards case. The average annual per-unit energy 

consumption projected for 2014 for each product category is shown in Tables 10.3.1 through 

10.3.3.

Table 10.3.1 Standard-Size Refrigerator-Freezers: Shipment-Weighted Average 

Annual Energy Use in 2014 for Base and Standards Cases

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6

Top-Mount

 SWEUF 0.965 0.887 0.846 0.800 0.750 0.700 0.640

 Avg. Energy Use (kWh)* 520 478 456 431 404 377 347

Bottom-Mount

 SWEUF 0.836 0.823 0.816 0.800 0.750 0.700 0.640

 Avg. Energy Use (kWh)* 556 548 543 533 499 466 425

Side-by-Side

 SWEUF 0.877 0.856 0.832 0.800 0.750 0.700 0.670

 Avg. Energy Use (kWh)* 717 699 679 654 613 572 547

SWEUF = shipment-weighted energy use factor

* Before applying UAF correction (which varies with product age).
10-17

Table 10.3.2 Standard-Size Freezers: Shipment-Weighted Average Annual Energy 

Consumption in 2014 for Base and Standards Cases

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6 7 8

Upright

 SWEUF 0.980 0.899 0.849 0.800 0.750 0.700 0.650 0.600 0.560

 Avg. Energy Use (kWh) 588 539 510 480 450 420 390 360 338

Chest

 SWEUF 0.983 0.899 0.849 0.799 0.750 0.700 0.650 0.590 -

 Avg. Energy Use (kWh) 364 333 314 296 278 259 241 217 -

SWEUF = shipment-weighted energy use factor

Table 10.3.3 Compact Refrigeration Products: Shipment-Weighted Average Energy 

Consumption in 2014 for Base and Standards Cases

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6 7 8 9 10

Refrigerator

 SWEUF 0.996 0.898 0.849 0.799 0.750 0.700 0.650 0.600 0.550 0.500 0.410

 Avg. 

Energy Use 

(kWh)

324 292 276 260 244 227 211 195 179 162 134

Freezer

 SWEUF 0.995 0.900 0.850 0.800 0.750 0.700 0.650 0.580 - - -

 Avg. 

Energy Use 

(kWh)

311 281 266 250 235 219 203 182 - - -

SWEUF = shipment-weighted energy use factor

10.3.2.4 National Annual Energy Consumption

The national annual energy consumption (AEC) is the product of the annual energy 

consumption per unit and the number of units of each vintage. This method of calculation 

accounts for differences in unit energy consumption from year to year. In determining national 

annual energy consumption, DOE first calculated annual energy consumption at the site, then 

applied a conversion factor, described below, to calculate primary energy consumption. 

10.3.2.5 Site-to-Source Conversion Factors

In determining national annual energy consumption, DOE initially calculated the annual 

energy consumption at the site (for electricity, the energy in kWh consumed at the household or 

establishment). It then used site energy consumption to calculate primary (source) energy 

consumption by applying a conversion factor to account for losses associated with the 
10-18

generation, transmission, and distribution of electricity. The site-to-source conversion factor is a 

multiplicative factor used to convert site energy consumption into primary or source energy 

consumption, expressed in quads (quadrillion Btu’s). DOE used annual site-to-source conversion 

factors based on the version of the National Energy Modeling System (NEMS)c

10.4 NET PRESENT VALUE

that corresponds 

to AEO 2010. The factors are marginal values, which represent the response of the system to an 

incremental decrease in consumption. For electricity, the conversion factors change over time in 

response to projected changes in generation sources (i.e., the types of power plants projected to 

provide electricity to the Nation). The values derived from the AEO2010 NEMS end in 2035. 

DOE assumed that conversion factors remain at the 2035 values throughout the rest of the 

forecast.

DOE calculated the net present value (NPV) of the increased product cost and reduced 

operating cost associated with the difference between the base case and each potential standards 

case for the considered refrigeration products. 

10.4.1 Definition

The NPV is the value in the present of a time-series of costs and savings. The NPV is 

described by the equation:

NPV PVS PVC _ =

Where:

PVS = present value of savings in operating cost, and 

PVC = present value of increased total product cost to consumers. 

DOE determined the PVS and PVC according to the following expressions.

PVS = ∑OCSy× DFy

PVC =∑TICy × DFy

 

c For more information on NEMS, please refer to the U.S. Department of Energy, Energy Information 

Administration documentation. A useful summary is National Energy Modeling System: An Overview 2000, 

DOE/EIA-0581(2000), March 2000. EIA approves use of the name NEMS to describe only an official version of 

the model without any modification to code or data. Because this analysis entails some minor code modifications 

and the model is run under various policy scenarios that are variations on EIA assumptions, DOE refers to the model 

by the name NEMS-BT (BT is DOE’s Building Technologies Program, under whose aegis this work has been 

performed). NEMS-BT was previously called NEMS-BRS.
10-19

Where:

OCS = total annual savings in operating cost each year summed over vintages of the product 

stock, STOCKV;

TIC = total annual increases in product cost each year summed over years of the product 

shipments, SHIPy;

DF = discount factor in each year; and 

y = year in the forecast.

DOE calculated the total annual consumer savings in operating cost by multiplying the 

number or stock of a given product class (by vintage) by its per-unit operating cost savings (also 

by vintage). DOE calculated the total annual increases in consumer product cost by multiplying 

the number or shipments of the given product class (by vintage) by its per-unit increase in 

consumer product cost (also by vintage). The calculation of total annual operating cost savings 

and total annual product cost increases is represented by the following equations.

OCSy = ∑STOCKV ×UOCSV

TICy = ∑SHIPy×UTICy

Where:

STOCKV = stock of products of vintage V that survive in the year for which DOE calculated 

annual energy consumption,

UOCSV = annual per-unit savings in operating cost,

V = year in which the product was purchased as a new unit,

SHIPy = shipments of products in year y, and

UTICy = annual per-unit increase in installed product cost in year y.

DOE determined the total increased product cost for each year from the effective date of 

a potential standard to 2044. It determined the present value of operating cost savings for each 

year from the effective date of the standard to the year when all units purchased by 2044 have 

been retired. DOE calculated costs and savings as the difference between a standards case and a 

base case without new standards. 

DOE developed a discount factor from the national discount rate and the number of years 

between the present (i.e., year to which the sum is being discounted) and the year in which the

costs and savings occur. The NPV is the sum over time of the discounted net savings.
10-20

10.4.2 Inputs

The inputs to calculation of the net present value (NPV) are: 

• Average annual product cost;

• average annual savings in operating cost,;

• total annual increases in product cost;

• total annual savings in operating cost; 

• discount factor;

• present value of costs; and

• present value of savings.

The increase in total annual product cost is equal to the annual change in the average 

annual product cost (difference between base case and standards case) multiplied by the 

shipments forecasted in the standards case. As with the calculation of the NES, DOE did not 

calculate total annual product costs using base-case shipments. To avoid including savings due to 

displaced shipments (by consumers deciding not to buy higher-cost products), DOE used the 

standards-case projection of shipments and, in turn, the standards-case stock, to calculate product 

costs. 

The total annual savings in operating cost are equal to the change in annual operating cost 

(difference between base case and standards case) per unit multiplied by the shipments

forecasted in the standards case. 

10.4.2.1 Average Annual Product Cost

The average annual product cost is directly dependent on efficiency. DOE therefore used 

the SWEUFs presented in section 10.2 for the base case and each standards case, along with the

product costs at various efficiency levels (presented in chapter 8), to estimate the shipmentweighted average annual product cost under the base and standards cases. Tables 10.4.1 through 

10.4.3 show the shipment-weighted average consumer product cost based on the SWEUFs that

correspond to the base case and each standards case in 2014.

Table 10.4.1 Standard-Size Refrigerator-Freezers: Shipment-Weighted Average 

Product Cost in 2014 for Base and Candidate Standard Levels

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6

Top-Mount

 SWEUF 0.965 0.887 0.846 0.800 0.750 0.700 0.640

 Avg. Prod Cost (2009$) $543 $555 $563 $625 $667 $759 $892 

Bottom-Mount

 SWEUF 0.836 0.823 0.816 0.800 0.750 0.700 0.640
10-21

Avg. Prod Cost (2009$) $948 $950 $952 $958 $1,024 $1,131 $1,280 

Side-by-Side

 SWEUF 0.877 0.856 0.832 0.800 0.750 0.700 0.670

Avg. Prod Cost (2009$) $1,152 $1,155 $1,160 $1,179 $1,244 $1,385 $1,496 

Table 10.4.2 Standard-Size Freezers: Shipment-Weighted Average Product Cost in 

2014 for Base and Candidate Standard Levels

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6 7 8

Upright

 SWEUF 0.980 0.899 0.849 0.800 0.750 0.700 0.650 0.600 0.560

 Avg. Prod Cost (2009$) $558 $570 $591 $610 $639 $666 $725 $809 $993

Chest

 SWEUF 0.983 0.899 0.849 0.799 0.750 0.700 0.650 0.590 -

Avg. Prod Cost (2009$) $407 $414 $424 $436 $484 $505 $565 $687 -

Table 10.4.3 Compact Refrigerators and Freezers: Shipment-Weighted Average 

Product Cost in 2014 for Base and Candidate Standard Levels

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6 7 8 9 10

Refrigerator

SWEUF 0.996 0.898 0.849 0.799 0.750 0.700 0.650 0.600 0.550 0.500 0.410

 Avg. Prod 

Cost (2009$)

$146 $151 $156 $162 $174 $184 $212 $221 $255 $274 $341

Freezer

 SWEUF 0.995 0.900 0.850 0.800 0.750 0.700 0.650 0.580 - - -

 Avg. Prod 

Cost (2009$)

$202 $209 $222 $268 $279 $312 $320 $399 - - -
10-22

10.4.2.2 Annual Operating Cost Savings per Unit

The average annual operating cost includes the costs for energy, repair, and maintenance. 

As described in chapter 8, for all the considered products DOE assumed that potential standards 

would produce no increase in maintenance or repair costs. For all the considered products, 

therefore, DOE determined the per-unit annual savings in operating cost based only on the 

savings in energy costs attributable to a standard. DOE determined the per-unit annual savings in 

operating cost by multiplying the per-unit annual savings in energy consumption developed for 

each product class by the appropriate energy price. As described in chapter 8, DOE forecasted 

energy prices based on EIA’s AEO2010. 

10.4.2.3 Total Annual Increases in Product Cost 

The total annual increase in product cost for any given standards case is the product of 

the average cost increase per unit due to the standard and the number of units of each vintage 

shipped. This method accounts for differences in product cost from year to year. The equation 

for determining the total annual increase in product cost for a given standards case, which was 

shown in section 10.4.1, is repeated here.

TICy = ∑SHIPy×UTICy

10.4.2.4 Total Annual Savings in Operating Cost 

The total annual savings in operating cost for any given standards case is the product of 

the annual savings in operating cost per unit attributable to the standard and the number of units 

of each vintage. This method accounts for differences in annual savings in operating cost from 

year to year. The equation for determining the total annual savings in operating cost for a given 

standards case, which was presented in section 10.4.1, is repeated here. 

OCS =∑STOCKV ×UOCSV

10.4.2.5 Discount Factor

DOE multiplied monetary values in future years by a discount factor to determine the 

present value. The discount factor (DF) is described by the equation:

( y yp ) _

( r )

DF

1+

1 =

Where:

r = discount rate, 

y = year in which the monetary value exists, and 

yP = year in which the present value is being determined.
10-23

Although DOE used consumer discount rates to determine the life-cycle cost of 

refrigeration products (chapter 8), it used national discount rates to calculate national NPV. DOE 

estimated NPV using both a 3-percent and a 7-percent real discount rate, in accordance with the

Office of Management and Budget’s guidance to Federal agencies on the development of 

regulatory analysis, particularly section E therein: Identifying and Measuring Benefits and 

Costs.

2

10.4.2.6 Present Value of Costs

DOE defined the present year as 2010.

The present value of increased product costs is the annual total cost increase in each year 

(the difference between a standards case and the base case), discounted to the present and 

summed throughout the period in which DOE is considering the installation of products (2014

through 2044). DOE calculated annual increases in installed cost as the difference in total 

product cost for new appliances purchased each year, multiplied by the shipments in the 

standards case.

10.4.2.7 Present Value of Savings

The present value of savings in operating cost is the annual savings on operating cost (the 

difference between the base case and a standards case), discounted to the present and summed 

from the effective date to the time when the last unit installed in 2043 is retired from service.

Savings are decreases in operating cost associated with the higher energy efficiency of products 

purchased in the standards case compared to the base case. Total annual savings in operating cost 

are the savings per unit multiplied by the number of units of each vintage that survive in a 

particular year. 

10.5 NES AND NPV RESULTS 

The NIA model produces estimates of the NES and NPV attributable to a given candidate 

standard level. The inputs to the NIA model were discussed in sections 10.3.2 (inputs to NES) 

and 10.4.2 (inputs to NPV). DOE generated the NES and NPV results using a Microsoft Excel 

spreadsheet, which is accessible on the Internet 

<www.eere.energy.gov/buildings/appliance_standards/> Details regarding and instructions for 

using the spreadsheet are provided in appendix 10-A.

Appendix 10-B presents the NIA results calculated using inputs from the High Economic 

Growth case and the Low Economic Growth case from AEO 2010. 

10.5.1 Summary of Inputs

Table 10.5.1 summarizes the inputs to the NIA model. 
10-24

Table 10.5.1 Inputs to Calculation of National Energy Savings and Net Present Value 

Input Description

Shipments Annual shipments from shipments model. (See chapter 9.)

Compliance date of standard 2014.

Base-case forecasted efficiencies See section 10.2.

Standards-case efficiencies See section 10.2.

Annual energy consumption per unit Annual weighted-average values are a function of SWEUF. 

(See section 10.3.2.1.)

Total installed cost per unit Annual weighted-average values are a function of the 

efficiency distribution. (See section 10.4.2.1.)

Energy cost per unit Annual weighted-average values are a function of annual 

energy consumption per unit and energy prices. (See chapter 8 

for energy prices.)

Repair and maintenance costs per unit Annual weighted-average values are a function of the 

efficiency distribution.

Forecast of energy prices Energy prices: EIA AEO2010 forecasts (to 2035) and 

extrapolation thereafter. (See chapter 8.)

Site-to-source conversion factor A time-series conversion factor that includes electric 

generation, transmission, and distribution losses. Conversion, 

which changes yearly, is generated by DOE-EIA’s NEMS* 

program.

Discount rates 3% and 7% real.

Present year Future expenses are discounted to 2010.

* Chapter 13, Utility Impact Analysis, provides more detail on the National Energy Modeling System (NEMS).

10.5.2 National Energy Savings Results by Efficiency Level

The following section provides results of calculating NES for standards at each of the 

efficiency levels analyzed for the considered products. NES results, which are cumulative from 

2014 through 2043, are expressed as primary energy savings. DOE based the inputs on weightedaverage values, yielding results that are discrete point values, rather than a distribution of values 

as in the life-cycle cost and payback period analyses. The results in this section represent all the 

product classes that DOE included in each of the 11 representative product categories, not only 

the primary product class that accounts for the bulk of shipments in each category. This section 

also presents results that show the magnitude of the NES if the savings are discounted at rates of 

3 percent and 7 percent.
10-25

Table 10.5.2 Standard-Size Refrigerator-Freezers: Cumulative National Energy 

Savings

Efficiency Level

(% less than 

baseline energy use)

Top-Mount 

RefrigeratorFreezers*

quads

Bottom-Mount 

RefrigeratorFreezers**

quads

Side-by-Side 

RefrigeratorFreezers†

quads

1 (10) 0.79 0.04 0.15

2 (15) 1.21 0.07 0.32 

3 (20) 1.62 0.09 0.54 

4 (25) 2.08 0.27 0.88 

5 (30) 2.49 0.45 1.20

6 (36/36/33)†† 2.90 0.65 1.39 

* Includes product classes 1, 1A, 2, 3A, 3I and 6 as well as product class 3.

** Includes product classes 5A and 5I as well as product class 5.

† Includes product classes 4 and 4I as well as product class 7.

†† Energy savings relative to baseline varies with product class.

Table 10.5.3 Standard-Size Refrigerator-Freezers: Discounted Cumulative National 

Energy Savings

Efficiency 

Level

(% less than 

baseline energy 

use)

Top-Mount 

Refrigerator-Freezers*

quads

Bottom-Mount 

Refrigerator-Freezers**

quads

Side-by-Side 

Refrigerator-Freezers†

quads

3% 

Discount 

Rate

7% 

Discount 

Rate

3% 

Discount 

Rate

7% 

Discount 

Rate

3% 

Discount 

Rate

7% 

Discount 

Rate

1 (10) 0.42 0.20 0.02 0.01 0.08 0.04

2 (15) 0.64 0.30 0.04 0.02 0.17 0.08

3 (20) 0.86 0.41 0.05 0.02 0.28 0.13 

4 (25) 1.10 0.52 0.15 0.07 0.46 0.22

5 (30) 1.32 0.62 0.24 0.11 0.63 0.30

6 (36/36/33)†† 1.53 0.72 0.34 0.16 0.73 0.34 

* Includes product classes 1, 1A, 2, 3A, 3I and 6 as well as product class 3.

** Includes product classes 5A and 5I as well as product class 5.

† Includes product classes 4 and 4I as well as product class 7.

†† Energy savings relative to baseline varies with product class.
10-26

Table 10.5.4 Standard-Size Freezers: Cumulative National Energy Savings

Efficiency Level

(% less than baseline energy use)

Upright Freezers*

quads

Chest Freezers**

quads

1 (10) 0.19 0.13

2 (15) 0.31 0.21 

3 (20) 0.43 0.28

4 (25) 0.54 0.36

5 (30) 0.66 0.43

6 (35) 0.77 0.49

7 (40/41) † 0.86 0.56

8 (44) 0.89

* Includes product class 8 as well as representative product class 9.

** Includes product class 10A as well as representative product class 10.

† Energy savings relative to baseline varies with product class.

Table 10.5.5 Standard-Size Freezers: Discounted Cumulative National Energy Savings

Efficiency Level

(% less than baseline 

energy use)

Upright Freezers*

quads

Chest Freezers**

quads

3% Discount

Rate

7% Discount 

Rate

3% Discount 

Rate

7% Discount 

Rate

1 (10) 0.10 0.05 0.07 0.03 

2 (15) 0.16 0.08 0.11 0.05

3 (20) 0.22 0.10 0.15 0.07

4 (25) 0.28 0.13 0.19 0.09 

5 (30) 0.34 0.16 0.22 0.10 

6 (35) 0.40 0.19 0.26 0.12

7 (40/41) † 0.45 0.21 0.29 0.13 

8 (44) 0.46 0.21 

* Includes product class 8 as well as representative product class 9.

** Includes product class 10A as well as representative product class 10.

† Energy savings relative to baseline varies with product class.
10-27

Table 10.5.6 Compact Refrigeration Products: Cumulative National Energy Savings

Efficiency Level

(% less than baseline energy use)

Compact Refrigerators*

quads

Compact Freezers**

quads

1 (10) 0.15 0.03

2 (15) 0.22 0.04

3 (20) 0.28 0.05

4 (25) 0.34 0.07

5 (30) 0.40 0.07

6 (35) 0.44 0.09

7 (40/42) † 0.48 0.09

8 (45) 0.49

9 (50) 0.52

10 (59) 0.50

* Includes product classes 11A, 12, 13, 13A, 14, and 15 as well as product class 11.

** Includes product classes 16 and 17 as well as product class 18.

† Energy savings relative to baseline varies with product class.

Table 10.5.7 Compact Refrigeration Products: Discounted Cumulative National 

Energy Savings

Efficiency Level

(% less than 

baseline energy 

use)

Compact Refrigerators*

quads

Compact Freezers**

quads

3% Discount 

Rate

7% Discount 

Rate

3% Discount 

Rate

7% Discount 

Rate

1 (10) 0.08 0.04 0.02 0.01

2 (15) 0.12 0.06 0.02 0.01

3 (20) 0.16 0.08 0.03 0.02

4 (25) 0.19 0.10 0.04 0.02

5 (30) 0.22 0.11 0.04 0.02

6 (35) 0.24 0.12 0.05 0.03

7 (40/42) † 0.27 0.14 0.05 0.03

8 (45) 0.27 0.14

9 (50) 0.29 0.15

10 (59) 0.28 0.14

* Includes product classes 11A, 12, 13, 13A, 14, and 15 as well as product class 11.

** Includes product classes 16 and 17 as well as product class 18.

† Energy savings relative to baseline varies with product class.
10-28

Table 10.5.8 Built-In Refrigeration Products: Cumulative National Energy Savings

Efficiency Level

(% less than 

baseline energy 

use)

Built-in All 

Refrigerators 

(3A-BI)

quads

Built-in 

BottomMount 

RefrigeratorFreezers*

quads

Built-in Sideby-Side 

RefrigeratorFreezers**

quads

Built-in 

Upright 

Freezers (9-

BI)

quads

1 (10) 0.00 0.00 0.01 0.00

2 (15) 0.01 0.00 0.02 0.01

3 (20) 0.01 0.01 0.03 0.01

4 (25) 0.01 0.01 0.04 0.01

5 (29/27/22/27) † 0.01 0.02 0.01

* Includes product class 5I-BI as well as product class 5-BI.

** Includes product classes 4-BI and 4I-BI as well as product class 7-BI.

† Energy savings relative to baseline varies with product class.

Table 10.5.9 Built-In Refrigeration Products: Discounted Cumulative National Energy 

Savings

Efficiency Level

(% less than 

baseline energy 

use)

Built-in All Refrigerators (3A-BI)

quads

Built-in Bottom-Mount 

Refrigerator-Freezers*

quads

3% Discount 

Rate

7% Discount 

Rate 3% Discount Rate 7% Discount Rate

1 (10) 0.00 0.00 0.00 0.00

2 (15) 0.00 0.00 0.00 0.00

3 (20) 0.00 0.00 0.00 0.00

4 (25) 0.01 0.00 0.01 0.00

5 (29/27)† 0.01 0.00 0.01 0.01

Efficiency Level

(% less than 

baseline energy 

use)

Built-in Side-by-Side RefrigeratorFreezers**

quads

Built-in Upright Freezers (9-BI)

quads

3% Discount 

Rate

7% Discount 

Rate 3% Discount Rate 7% Discount Rate

1 (10) 0.00 0.00 0.00 0.00

2 (15) 0.01 0.00 0.00 0.00

3 (20) 0.02 0.01 0.01 0.00

4 (22/25)† 0.02 0.01 0.01 0.00

5 (27) 0.01 0.00

* Includes product class 5I-BI as well as product class 5-BI.

** Includes product classes 4-BI and 4I-BI as well as product class 7-BI.

† Energy savings relative to baseline varies with product class.
10-29

10.5.3 Annual Costs and Savings

Figure 10.5.1 illustrates the basic inputs to the calculation of net present value (NPV) by 

showing the non-discounted annual increases in product cost and annual savings in operating 

cost at the national level for efficiency level 3 for product class 3 (refrigerator-freezers–

automatic defrost with top-mounted freezer and without through-the-door ice service). The figure 

also shows the net savings, which is the difference between the savings and costs for each year. 

The annual increase in product cost is the total cost for products purchased each year in the 

forecast period. The annual savings in operating cost applies to products operating in each year. 

The NPV is the difference between the cumulative annual discounted savings and cumulative 

annual discounted costs. DOE could create figures like Figure 10.5.1 for each of the considered 

efficiency levels for each product class.

Figure 10.5.1 Non-Discounted Annual Increases in Installed Cost and Savings 

in Operating Cost for Product Class 3 at Efficiency Level 3

-0.5

0

0.5

1

1.5

2

2.5

2010 2015 2020 2025 2030 2035 2040 2045 2050 2055 2060 2065 2070

Year

Billions of 2008 Dollars

Operating Cost Savings

Incremental Product Cost

Net Savings
10-30

10.5.4 Consumer Net Present Value Results by Efficiency Level

This section provides results of calculating net present value (NPV) of consumer benefit 

for standards at each of the considered efficiency levels for the considered refrigeration products. 

Results, which are cumulative, are shown as the discounted value of the net savings in dollar 

terms. DOE based the inputs to the NIA model on weighted-average values, yielding results that 

are discrete point values, rather than a distribution of values as in the life-cycle cost and payback 

period analysis.

The present value of increased total installed cost is the total annual increase in installed 

cost (the difference between the standards case and base case), discounted to the present and 

summed throughout the period for which DOE evaluated the impact of standards.

Savings are decreases in operating cost associated with the higher energy efficiency of 

products purchased in the standards case compared to the base case. Total savings in operating 

cost are the savings per unit multiplied by the number of units of each vintage (i.e., year of 

manufacture) that survive in a particular year. The operating cost includes expenditures until the 

last unit purchased during the forecast period is retired from service.

Tables 10.5.10 though 10.5.13 show the consumer NPV associated with standards at the 

considered efficiency levels for each group of refrigeration products. As was the case with NES 

results, the results for NPV refer to all the product classes that DOE included in each of the 

representative product class categories, not simply to the primary product class that accounts for 

the bulk of shipments in each case.

Table 10.5.10 Standard-Size Refrigerator-Freezers: Cumulative Net Present Value of 

Consumer Benefit

Efficiency 

Level

(% less than 

baseline energy 

use)

Top-Mount 

Refrigerator-Freezers*

Bottom-Mount 

Refrigerator-Freezers**

Side-by-Side 

Refrigerator-Freezers†

3% 

Discount 

Rate

7% 

Discount 

Rate

3% 

Discount 

Rate

7% 

Discount 

Rate

3% 

Discount 

Rate

7% 

Discount 

Rate

billion 2009$

1 (10) 7.43 2.66 0.42 0.15 1.59 0.59

2 (15) 11.02 3.88 0.61 0.22 3.14 1.14

3 (20) 6.68 0.85 0.79 0.27 4.37 1.42

4 (25) 5.99 (0.33) (0.23) (0.57) 3.62 0.46

5 (30) (1.95) (5.36) (3.22) (2.43) (2.35) (3.26) 

6 (36/36/33)†† (14.63) (12.87) (7.32) (4.95) (7.38) (6.26) 

* Includes product classes 1, 1A, 2, 3A, 3I and 6 as well as product class 3.

** Includes product classes 5A and 5I as well as product class 5.

† Includes product classes 4 and 4I as well as product class 7.
10-31

†† Energy savings relative to baseline varies with product class.

Table 10.5.11 Standard-Size Freezers: Cumulative Net Present Value of Consumer 

Benefit

Efficiency Level

(% less than baseline 

energy use)

Upright Freezers* Chest Freezers**

3% Discount 

Rate

7% Discount 

Rate

3% Discount 

Rate

7% Discount 

Rate

billion 2009$

1 (10) 2.03 0.72 1.41 0.50

2 (15) 2.93 0.97 2.09 0.71

3 (20) 3.91 1.25 2.74 0.90

4 (25) 4.63 1.39 2.37 0.54

5 (30) 5.42 1.57 2.75 0.59

6 (35) 5.13 1.22 1.82 (0.00) 

7 (40/41) † 4.20 0.55 (0.16) (1.21) 

8 (44) 0.67 (1.42) 

* Includes product class 8 as well as representative product class 9.

** Includes product class 10A as well as representative product class 10.

† Energy savings relative to baseline varies with product class.

Table 10.5.12 Compact Refrigeration Products: Cumulative Net Present Value of 

Consumer Benefit

Efficiency Level

(% less than 

baseline energy 

use)

Compact Refrigerators* Compact Freezers**

3% Discount 

Rate

7% Discount 

Rate

3% Discount 

Rate

7% Discount 

Rate

billion 2009$

1 (10) 0.83 0.36 0.17 0.07 

2 (15) 1.07 0.44 0.14 0.05 

3 (20) 0.97 0.35 (0.25) (0.18)

4 (25) 0.67 0.16 (0.25) (0.19) 

5 (30) 0.42 0.00 (0.50) (0.33) 

6 (35) (0.83) (0.67) (0.46) (0.32) 

7 (40/42) † (1.07) (0.83) (0.96) (0.60)

8 (45) (2.40) (1.54) 

9 (50) (2.80) (1.76) 

10 (59) (4.49) (2.68) 
10-32

* Includes product classes 11A, 12, 13, 13A, 14, and 15 as well as product class 11.

** Includes product classes 16 and 17 as well as product class 18.

† Energy savings relative to baseline varies with product class.

Table 10.5.13 Built-In Refrigeration Products: Cumulative Net Present Value of 

Consumer Benefit

Efficiency Level

(% less than 

baseline energy 

use)

Built-in All Refrigerators (3A-BI)

Built-in Bottom-Mount 

Refrigerator-Freezers*

3% Discount 

Rate

7% Discount 

Rate 3% Discount Rate

7% Discount 

Rate

billion 2009$

1 (10) 0.03 0.01 0.02 0.01

2 (15) 0.05 0.02 (0.00) (0.00)

3 (20) (0.01) (0.02) (0.02) (0.02)

4 (25) (0.10) (0.07) (0.36) (0.21)

5 (29/27) † (0.17) (0.11) (0.54) (0.32)

Efficiency Level

(% less than 

baseline energy 

use)

Built-in Side-by-Side RefrigeratorFreezers** Built-in Upright Freezers (9-BI)

3% Discount 

Rate

7% Discount 

Rate 3% Discount Rate

7% Discount 

Rate

billion 2009$

1 (10) 0.04 0.01 0.04 0.02

2 (15) (0.05) (0.06) 0.07 0.02

3 (20) (0.43) (0.28) 0.04 0.00

4 (25/22) † (0.83) (0.51) (0.02) (0.03)

5 (27) (0.07) (0.06)

* Includes product class 5I-BI as well as product class 5-BI.

** Includes product classes 4-BI and 4I-BI as well as product class 7-BI.

† Energy savings relative to baseline varies with product class.

10.6 NES AND NPV RESULTS BY TRIAL STANDARD LEVEL

10.6.1 Trial Standard Levels

In considering amended standards for the NOPR, DOE created trial standard levels 

(TSLs) that combine specific efficiency levels across product classes. DOE analyzed the benefits 

and burdens of a number of TSLs for the refrigeration products that are the subject of this 
10-33

rulemaking. A description of each TSL DOE analyzed is provided below. DOE attempted to 

limit the number of TSLs considered for the NOPR by excluding efficiency levels that do not 

exhibit significantly different economic and/or engineering characteristics from the efficiency 

levels already selected as a TSL.

Table 10.6.1 presents the TSLs and the corresponding product class efficiencies for 

standard-size refrigerator-freezers. TSL 1 consists of those efficiency levels that meet current 

ENERGY STAR criteria. TSL 2 consists of the highest efficiency levels for which the consumer 

NPV is positive, using a 7-percent discount rate. TSL 3 consists of the highest efficiency levels 

for which the consumer NPV is positive, using a 3-percent discount rate, as well as the levels 

recommended in the Joint Comments.d TSL 4 consists of those efficiency levels that yield 

energy use 30 percent below the baseline products. TSL 5 consists of the max-tech efficiency 

levels.

Table 10.6.1 Trial Standard Levels for Standard-Size Refrigerator-Freezers

Trial 

Standard 

Level

Top-Mount 

Refrigerator-Freezers

Bottom-Mount 

Refrigerator-Freezers

Side-by-Side 

Refrigerator-Freezers

Product classes 1, 1A, 

2, 3, 3A, 3I and 6

Product classes 5, 5A, 

and 5I

Product classes 4, 4I, 

and 7

Efficiency Level (% less than baseline energy use)

1 3 (20) 3 (20) 3 (20)

2 3(20) 3 (20) 4 (25)

3 4 (25)* 3 (20) 4 (25)

4 5 (30) 5 (30) 5 (30)

5 6 (36) 6 (36) 6 (33)

* Level for product classes 1, 1A, and 2 is 20%.

Table 10.6.2 presents the TSLs and the corresponding product class efficiencies for 

standard-size freezers. TSL 1 consists of those efficiency levels that yield energy use 20 percent 

below the baseline products. TSL 2 consists of the levels recommended in the Joint Comments. 

TSL 3 consists of incrementally higher efficiency levels than the preceding TSL. TSL 4 consists 

of the efficiency levels for which the consumer NPV is positive, using a 7-percent discount rate. 

TSL 5 consists of the max-tech efficiency levels, which are also the efficiency levels for which 

the consumer NPV is positive, using a 3-percent discount rate. 

 

d DOE received comment from a group of refrigerator manufacturers, electric utilities, and energy conservation 

advocates (referred to as the “Joint Comments”) who, acting on its own initiative, negotiated intensively for several 

months to develop a common recommendation for an energy conservation standard that meets the EPCA 

requirements for refrigerators, refrigerator-freezers and freezers.
10-34

Table 10.6.2 Trial Standard Levels for Standard-Size Freezers

Trial Standard 

Level

Upright Freezers Chest Freezers

Product class 9 Product class 8

Product classes 

10 and 10A

Efficiency Level (% less than baseline energy use)

1 3 (20) 3 (20) 3 (20)

2 5 (30) 4 (25) 4 (25)*

3 6 (35) 5 (30) 5 (30)

4 7 (40) 6 (35) 6 (35)

5 8 (44) 7 (41) 7 (41)

* Level for product class 10A is 30%.

Table 10.6.3 presents the TSLs and the corresponding product class efficiencies for 

compact refrigeration products. TSL 1 consists of efficiency levels that meet current ENERGY 

STAR criteria for compact refrigerators, and efficiency levels that are 10 percent below the

baseline energy use for compact freezers. TSL 2 consists of the levels recommended in the Joint 

Comments. TSL 3 consists of the highest efficiency levels for which the consumer NPV is 

positive, using both a 3-percent and a 7-percent discount rate. TSL 4 consists of incrementally 

higher efficiency levels than TSL 3. TSL 5 consists of the max-tech efficiency levels. 

Table 10.6.3 Trial Standard Levels for Compact Refrigeration Products

Trial Standard 

Level

Compact Refrigerators and 

Refrigerator-Freezers

Compact Freezers

Product classes 

11, 11A, 12, and 

13A

Product classes 

13, 14,and 15

Product classes 16, 

17, 18

Efficiency Level (% less than baseline energy use)

1 3 (20) 1 (10) 1 (10)

2 4 (25) 2 (15)* 1 (10)

3 5 (30) 2 (15) 2 (15)

4 7 (40) 4 (25) 4 (25)

5 10 (59) 7 (42) 7 (42)

* Level for product class 14 is 20%.
10-35

Table 10.6.4 presents the TSLs and the corresponding product class efficiencies for builtin refrigeration products. TSL 1 consists of the efficiency levels that are 10 percent better than 

the current standard. TSL 2 consists of the highest efficiency levels for which the consumer NPV 

is positive, using both a 3-percent and a 7-percent discount rate. TSL 3 consists of the levels 

recommended in the Joint Comments. TSL 4 consists of incrementally higher efficiency levels 

than TSL 3. TSL 5 consists of the max-tech efficiency levels. 

Table 10.6.4 Trial Standard Levels for Built-in Refrigeration Products

Trial Standard 

Level

Built-in AllRefrigerators 

Built-in BottomMount 

RefrigeratorFreezers

Built-in Side-bySide RefrigeratorFreezersBuilt-in 

Upright 

Freezers 

Product class 

3A-BI

Product classes 

5-BI and 5I-BI

Product classes 

4-BI, 4I-BI and 

7-BI

Product class 

9-BI

Efficiency Level (% less than baseline energy use)

1 1 (10) 1 (10) 1 (10) 1 (10)

2 2 (15) 2 (15) 1 (10) 3 (20)

3 3 (20) 2 (15) 3 (20) 4 (25)

4 4 (25) 4 (25) 3 (20) 4 (25)

5 5 (29) 5 (27) 4 (22) 5 (27)

10.6.2 National Energy Savings Results by Trial Standard Level

The tables below show the cumulative national energy savings associated with standards 

at the considered TSLs for each group of refrigeration products.
10-36

Table 10.6.5 Standard-Size Refrigerator-Freezers: Cumulative National Energy 

Savings in Quads

Trial Standard 

Level

Top-Mount 

Refrigerator-Freezers

Bottom-Mount 

Refrigerator-Freezers

Side-by-Side 

RefrigeratorFreezers

Product classes 1, 1A, 2, 

3, 3A, 3I and 6

Product classes 5, 5A, 

and 5I

Product classes 4, 4I, 

and 7

1 1.62 0.09 0.54

2 1.62 0.09 0.88

3 2.07 0.09 0.88

4 2.49 0.45 1.20

5 2.90 0.65 1.39

Table 10.6.6 Standard-Size Freezers: Cumulative National Energy Savings in Quads

Trial Standard 

Level

Upright Freezers Chest Freezers

Product classes 8 and 9 Product classes 10 and 10A

1 0.43 0.28

2 0.66 0.36

3 0.77 0.43

4 0.86 0.49

5 0.89 0.56

Table 10.6.7 Compact Refrigeration Products: Cumulative National Energy Savings in 

Quads

Trial Standard 

Level

Compact Refrigerators Compact Freezers

Product classes 11, 11A, 12, 13, 

13A, 14, and 15 Product classes 16, 17, 18

1 0.27 0.03

2 0.34 0.03

3 0.39 0.04

4 0.47 0.07

5 0.50 0.09
10-37

Table 10.6.8 Built-In Refrigeration Products: Cumulative National Energy Savings in 

Quads

Trial Standard 

Level

Built-in All 

Refrigerators 

Built-in BottomMount 

RefrigeratorFreezers

Built-in Side-bySide

RefrigeratorFreezersBuilt-in Upright 

Freezers 

Product class 3ABIProduct classes 5-

BI and 5I-BI

Product classes

4-BI, 4I-BI and

7-BI

Product class

9-BI

1 0.00 0.00 0.01 0.00

2 0.01 0.00 0.01 0.01

3 0.01 0.00 0.03 0.01

4 0.01 0.01 0.03 0.01

5 0.01 0.02 0.04 0.01

10.6.3 Consumer Net Present Value Results by Trial Standard Level

The tables below show the consumer NPV associated with standards at the considered 

TSLs for each group of refrigeration products.

Table 10.6.9 Cumulative Net Present Value of Consumer Benefits for Standard-Size 

Refrigerator-Freezers, 3-Percent Discount Rate

Trial Standard 

Level

Top-Mount 

Refrigerator-Freezers

Bottom-Mount 

Refrigerator-Freezers

Side-by-Side 

Refrigerator-Freezers

Product classes 1, 1A, 

2, 3, 3A, 3I and 6

Product classes 5, 5A, 

and 5I

Product classes 4, 4I, 

and 7

billion 2009 dollars

1 6.68 0.79 4.37

2 6.68 0.79 3.62

3 6.00 0.79 3.62

4 (1.95) (3.22) (2.35)

5 (14.63) (7.32) (7.38)

* Values in parentheses are negative values.
10-38

Table 10.6.10 Cumulative Net Present Value of Consumer Benefits for Standard-Size 

Refrigerator-Freezers, 7-Percent Discount Rate

Trial Standard 

Level

Top-Mount 

Refrigerator-Freezers

Bottom-Mount 

Refrigerator-Freezers

Side-by-Side 

Refrigerator-Freezers

Product classes 1, 1A, 

2, 3, 3A, 3I and 6

Product classes 5, 5A, 

and 5I

Product classes 4, 4I, 

and 7

billion 2009 dollars

1 0.85 0.27 1.42

2 0.85 0.27 0.46

3 (0.32) 0.27 0.46

4 (5.36) (2.43) (3.26)

5 (12.86) (4.95) (6.26)

* Values in parentheses are negative values.

Table 10.6.11 Cumulative Net Present Value of Consumer Benefits for Standard-Size 

Freezers, 3-Percent Discount Rate

Trial Standard 

Level

Upright Freezers Chest Freezers

Product classes 8 and 9 Product classes 10 and 10A

billion 2009 dollars

1 3.91 2.74

2 5.42 2.37

3 5.13 2.75

4 4.20 1.82

5 0.67 (0.16)

* Values in parentheses are negative values.

Table 10.6.12 Cumulative Net Present Value of Consumer Benefits for Standard-Size 

Freezers, 7-Percent Discount Rate

Trial Standard 

Level

Upright Freezers Chest Freezers

Product classes 8 and 9 Product classes 10 and 10A

billion 2009 dollars
10-39

1 1.25 0.90

2 1.57 0.54

3 1.22 0.59

4 0.55 0.00

5 (1.42) (1.21)

* Values in parentheses are negative values.

Table 10.6.13 Cumulative Net Present Value of Consumer Benefits for Compact 

Refrigeration Products, 3-Percent Discount Rate

Trial Standard 

Level

Compact Refrigerators Compact Freezers

Product classes 11, 11A, 12, 13, 

13A, 14, and 15 Product classes 16, 17, 18

billion 2009 dollars

1 1.25 0.17

2 0.69 0.17

3 0.82 0.14

4 (0.64) (0.25)

5 (4.49) (0.96)

* Values in parentheses are negative values.

Table 10.6.14 Cumulative Net Present Value of Consumer Benefits for Compact 

Refrigeration Products, 7-Percent Discount Rate

Trial Standard 

Level

Compact Refrigerators Compact Freezers

Product classes 11, 11A, 12, 13, 

13A, 14, and 15 Product classes 16, 17, 18

billion 2009 dollars

1 0.50 0.07

2 0.18 0.07

3 0.22 0.04

4 (0.59) (0.19)

5 (2.68) (0.60)

* Values in parentheses are negative values.
10-40

Table 10.6.15 Cumulative Net Present Value of Consumer Benefits for Built-In 

Refrigeration Products, 3-Percent Discount Rate

Trial Standard 

Level

Built-in All 

Refrigerators 

Built-in BottomMount 

RefrigeratorFreezers

Built-in Side-bySide 

RefrigeratorFreezersBuilt-in Upright 

Freezers 

Product class 3ABIProduct classes 5-

BI and 5I-BI

Product classes

4-BI, 4I-BI and

7-BI

Product class

9-BI

billion 2009 dollars

1 0.03 0.02 0.04 0.04

2 0.05 0.00 0.04 0.04

3 (0.01) 0.00 (0.43) (0.02)

4 (0.10) (0.36) (0.43) (0.02)

5 (0.17) (0.54) (0.83) (0.07)

* Values in parentheses are negative values.

Table 10.6.16 Cumulative Net Present Value of Consumer Benefits for Built-In 

Refrigeration Products, 7-Percent Discount Rate

Trial Standard 

Level

Built-in All 

Refrigerators 

(3A-BI)

Built-in BottomMount 

RefrigeratorFreezers

Built-in Side-bySide 

RefrigeratorFreezers

Built-in Upright 

Freezers (9-BI)

Product class 3ABIProduct classes 5-

BI and 5I-BI

Product classes

4-BI, 4I-BI and

7-BI

Product class

9-BI

billion 2009 dollars

1 0.01 0.01 0.01 0.02

2 0.02 (0.00) 0.01 0.00

3 (0.02) (0.00) (0.28) (0.03)

4 (0.07) (0.21) (0.28) (0.03)

5 (0.11) (0.32) (0.51) (0.06)

* Values in parentheses are negative values.
10-41

REFERENCES

 1 U.S. Department of Energy–Energy Information Administration. Annual Energy Outlook 

2010 with Projections to 2035. April 2010. U.S. DOE–EIA: Washington, D.C. DOE/EIA0383(2010).

2 Office of Management and Budget. OMB Circular A-4, Regulatory Analysis. 2003. OMB: 

Washington, D.C. September 17, 2003. 

<www.whitehouse.gov/omb/assets/omb/circulars/a004/a-4.pdf> 
11-i

CHAPTER 11. CONSUMER SUBGROUP ANALYSIS

TABLE OF CONTENTS

11.1 INTRODUCTION ......................................................................................................... 11-1

11.2 SUBGROUPS DESCRIPTION..................................................................................... 11-1

11.2.1 Senior-Only Households................................................................................................ 11-1

11.2.2 Low-Income Households............................................................................................... 11-1

11.2.3 Multi-Family Households.............................................................................................. 11-2

11.2.4 Subgroup Populations.................................................................................................... 11-2

11.3 RESULTS ...................................................................................................................... 11-3

11.3.1 Standard-Size Refrigerator-Freezers.............................................................................. 11-3

11.3.2 Standard-Size Freezers................................................................................................... 11-6

11.3.3 Built-In Refrigeration Products...................................................................................... 11-9
11-1

CHAPTER 11. CONSUMER SUBGROUP ANALYSIS

11.1 INTRODUCTION

The consumer subgroup analysis evaluates impacts on any identifiable groups or 

customers who may be disproportionately affected by any national energy conservation standard. 

DOE evaluates impacts on particular sub-groups of consumers primarily by analyzing the LCC 

impacts and PBP for those particular consumers from alternative standard levels. For the NOPR, 

DOE analyzed the impacts of the considered standard levels on low-income consumers and 

senior citizens for standard-size refrigerator-freezers and freezers. DOE did not estimate impacts 

for compact refrigeration products because the household sample sizes were not large enough to 

yield meaningful results.

DOE determines the impact on consumer subgroups using the LCC Spreadsheet Model. 

Chapter 8 explains in detail the inputs to the model used in determining LCC impacts and PBPs.

This chapter describes the subgroup identification in further detail and gives the results of 

the LCC and PBP analyses for the considered subgroups.

11.2 SUBGROUPS DESCRIPTION

11.2.1 Senior-Only Households

Senior-only households have occupants who are all at least 65 years of age. Based on the 

DOE Energy Information Administration (EIA)’s Residential Energy Consumption Survey of 

2005 (RECS), senior-only households comprise 17 percent of the country’s households.1

11.2.2 Low-Income Households

As defined in the RECS survey, low-income households are considered to be those at or

below the “poverty line.” The “poverty line” varies with household size, head of household age, 

and family income. Table 11.2.1 summarizes the income level baselines for selecting lowincome households from the RECS sample. The RECS survey classifies 15 percent of the 

country’s households as low-income.
11-2

Table 11.2.1 RECS 2005 Definitions of Low-Income Households by Yearly Income

Average Income in $

Household Size 48 Contiguous States 

and D.C.

Alaska Hawaii

1 9,570 11,950 11,010

2 12,830 16,030 14,760

3 16,090 20,100 18,510

4 19,350 24,190 22,260

5 22,610 28,270 26,010

6 25,870 32,350 29,760

7 29,130 36,430 33,510

8 32,390 40,510 37,260

9 35,650 44,590 41,010

10 38,910 48,670 44,760

11 42,170 52,750 48,510

12 45,430 56,830 52,260

13 48,690 60,910 56,010

14 51,950 64,990 59,760

15 55,210 69,070 63,510

11.2.3 Multi-Family Households

Multi-family households are located in buildings with 2 or more units. According to the 

RECS survey, multi-family households comprise 22 percent of the country’s households. This 

subgroup was only analyzed for water heaters. It comprises 11.1 percent of the sample used for 

gas-fire storage water heaters, and 17.2 percent of the sample used for electric storage water 

heaters.

11.2.4 Subgroup Populations

Table 11.2.2 summarizes the subgroup populations for standard-size refrigerator-freezers 

and freezers, while Table 11.2.3 summarizes the average annual energy use for the households 

analyzed in the consumer subgroup analyses. These values are compared against the average 

values for the national sample.

Table 11.2.2 Household Population Data for Refrigeration Products

Standard-Size 

RefrigeratorFreezersStandard-Size 

Freezers

Count Weight Count Weight

All Households 3329

 

84,886,289 616

 

15,329,541 

Senior Only 505 162 
11-3

10,526,643 3,045,340 

Senior Only % 15% 12% 26% 20%

Low Income

535

 

8,606,765 83

 

1,589,276 

Low Income % 16% 10% 13% 10%

Table 11.2.3 Average Annual Energy Use for Baseline Refrigeration Products

Standard-Size

Top-Mount 

RefrigeratorFreezers*

(kWh)

Standard-Size 

Upright Freezers

(kWh)

Senior Only 403 600

Low Income 443 575

All Households 444 600

* In first year of operation.

11.3 RESULTS

11.3.1 Standard-Size Refrigerator-Freezers

Tables 11.4.1 through 11.4.6 summarize the LCC and PBP results for low-income 

consumers and senior citizens for the standard-size refrigerator-freezer representative product 

classes. Table 11.4.7 compares the average LCC savings at each efficiency level for the two 

consumer subgroups with the average LCC savings for the entire sample for each representative 

product class.

Table 11.3.1 Product Class 3, Top-Mount Refrigerator-Freezers: LCC and PBP

Results for Senior-Only Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $540 $704 $1,245

1 (10) $552 $653 $1,205 $40 1.80% 19.19% 79.01% 2.9

2 (15) $561 $626 $1,187 $58 2.83% 14.93% 82.24% 3.3
11-4

3 (20) $624 $599 $1,223 $22 47.38% 5.24% 47.38% 10.0

4 (25) $667 $567 $1,233 $12 58.86% 0.00% 41.14% 11.7

5 (30) $759 $535 $1,294 -$49 76.74% 0.00% 23.26% 16.4

6 (36) $892 $502 $1,394 -$149 87.86% 0.00% 12.14% 22.0

Table 11.3.2 Product Class 5, Bottom-Mount Refrigerator-Freezers: LCC and PBP

Results for Senior-Only Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $911 $910 $1,820

1 (10) $926 $842 $1,768 $53 0.00% 0.00% 100.00% 2.5

2 (15) $935 $808 $1,743 $77 0.00% 0.00% 100.00% 2.7

3 (20) $957 $774 $1,731 $90 0.00% 0.00% 100.00% 3.8

4 (25) $1,016 $743 $1,758 $62 0.00% 0.00% 100.00% 7.0

5 (30) $1,109 $713 $1,822 -$2 55.97% 0.00% 44.03% 11.3

6 (36) $1,154 $695 $1,849 -$29 84.99% 0.00% 15.01% 12.7

Table 11.3.3 Product Class 7, Side-by-Side Refrigerator-Freezers with Through-theDoor Ice Service: LCC and PBP Results for Senior-Only Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $1,149 $1,178 $2,327

1 (10) $1,152 $1,156 $2,308 $20 0.09% 78.09% 21.82% 1.5

2 (15) $1,157 $1,132 $2,289 $40 0.49% 51.69% 47.82% 2.4

3 (20) $1,176 $1,100 $2,276 $53 7.31% 36.90% 55.79% 4.8

4 (25) $1,241 $1,051 $2,292 $37 50.78% 0.00% 49.22% 10.9

5 (30) $1,383 $1,002 $2,384 -$55 77.70% 0.00% 22.30% 18.6

6 (33) $1,494 $970 $2,463 -$134 86.15% 0.00% 13.85% 22.6
11-5

Table 11.3.4 Product Class 3, Top-Mount Refrigerator-Freezers: LCC and PBP

Results for Low-Income Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $541 $766 $1,307

1 (10) $553 $709 $1,263 $44 1.53% 19.33% 79.14% 2.6

2 (15) $562 $680 $1,242 $65 2.24% 15.00% 82.76% 3.0

3 (20) $625 $650 $1,275 $32 43.58% 5.29% 51.13% 9.1

4 (25) $668 $615 $1,283 $25 53.99% 0.00% 46.01% 10.6

5 (30) $760 $580 $1,340 -$33 71.67% 0.00% 28.33% 14.9

6 (36) $893 $543 $1,436 -$129 84.69% 0.00% 15.31% 19.9

Table 11.3.5 Product Class 5, Bottom-Mount Refrigerator-Freezers: LCC and PBP

Results for Low-Income Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $953 $916 $1,870

1 (10) $956 $907 $1,863 $9 0.24% 86.21% 13.55% 2.5

2 (15) $957 $902 $1,860 $13 0.36% 86.14% 13.50% 2.8

3 (20) $964 $889 $1,853 $20 4.90% 65.28% 29.82% 4.9

4 (25) $1,030 $851 $1,880 -$7 74.35% 0.00% 25.65% 17.4

5 (30) $1,137 $815 $1,952 -$78 88.09% 0.00% 11.91% 24.6

6 (36) $1,286 $767 $2,053 -$180 93.24% 0.00% 6.76% 29.0

Table 11.3.6 Product Class 7, Side-by-Side Refrigerator-Freezers with Through-theDoor Ice Service: LCC and PBP Results for Low-Income Households

Efficiency 

Level

(% less than 

baseline 

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating LCC

Average 

Savings 

% of Households that 

Experience Median
11-6

energy use) Cost 2009$ Net

Cost

No 

Impact

Net 

Benefit

Baseline $1,147 $1,138 $2,286

1 (10) $1,150 $1,115 $2,265 $21 0.02% 76.16% 23.82% 1.6

2 (15) $1,156 $1,090 $2,246 $41 0.54% 46.76% 52.70% 2.5

3 (20) $1,177 $1,056 $2,233 $55 8.78% 30.32% 60.90% 5.0

4 (25) $1,242 $1,010 $2,252 $36 50.56% 0.00% 49.44% 11.0

5 (30) $1,384 $963 $2,347 -$59 78.74% 0.00% 21.26% 18.9

6 (33) $1,495 $933 $2,428 -$140 87.34% 0.00% 12.66% 23.0

Table 11.3.7 Standard-Size Refrigerator-Freezers: Comparison of Average LCC 

Savings for Consumer Subgroups and All Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Top-Mount RefrigeratorFreezers (PC 3)Bottom-Mount RefrigeratorFreezers (PC 5)Side-by-Side RefrigeratorFreezers (PC 7)

Senior

LowIncome All SeniorLowIncome All SeniorLowIncome All

1 (10) $40 $44 $42 $53 $9 $8 $20 $21 $20

2 (15) $58 $65 $62 $77 $13 $12 $40 $41 $40

3 (20) $22 $32 $29 $90 $20 $19 $53 $55 $53

4 (25) $12 $25 $22 $62 -$7 -$8 $37 $36 $37

5 (30) -$49 -$33 -$37 -$2 -$78 -$79 -$55 -$59 -$55

6 (36/36/33) -$149 -$129 -$133 -$29 -$180 -$180 -$134 -$140 -$134

11.3.2 Standard-Size Freezers

Tables 11.4.8 through 11.4.11 summarize the LCC and PBP results for low-income 

consumers and senior citizens for the standard-size freezer representative product classes. Table 

11.4.12 compares the average LCC savings at each efficiency level for the two consumer 

subgroups with the average LCC savings for the entire sample for each representative product 

class.
11-7

Table 11.3.8 Product Class 9, Upright Freezers: LCC and PBP Results for SeniorOnly Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $559 $969 $1,528

1 (10) $570 $897 $1,466 $62 1.68% 19.85% 78.47% 2.3

2 (15) $591 $852 $1,443 $85 9.74% 1.67% 88.59% 4.3

3 (20) $610 $807 $1,417 $111 11.65% 0.59% 87.76% 4.8

4 (25) $639 $760 $1,400 $128 16.24% 0.41% 83.35% 5.8

5 (30) $666 $714 $1,380 $148 18.66% 0.22% 81.12% 6.2

6 (35) $725 $673 $1,398 $130 30.83% 0.00% 69.17% 8.4

7 (40) $809 $632 $1,441 $87 45.02% 0.00% 54.98% 11.0

8 (44) $993 $599 $1,591 -$63 70.19% 0.00% 29.81% 17.4

Table 11.3.9 Product Class 10, Chest Freezer: LCC and PBP Results for Senior-Only 

Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $407 $578 $985

1 (10) $413 $533 $946 $38 0.00% 16.18% 83.82% 2.1

2 (15) $424 $506 $930 $55 0.71% 1.18% 98.11% 3.4

3 (20) $436 $479 $914 $70 1.56% 0.22% 98.22% 4.2

4 (25) $483 $451 $935 $50 25.76% 0.22% 74.02% 8.7

5 (30) $504 $424 $928 $56 28.30% 0.22% 71.48% 9.1

6 (35) $564 $404 $968 $17 53.52% 0.00% 46.48% 13.1

7 (41) $686 $369 $1,055 -$71 78.99% 0.00% 21.01% 19.3

Table 11.3.10 Product Class 9, Upright Freezers: LCC and PBP Results for LowIncome Households

Efficiency 

Level

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)
11-8

(% less than 

baseline 

energy use) Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $559 $969 $1,478

1 (10) $570 $897 $1,420 $58 1.82% 19.07% 79.11% 2.4

2 (15) $592 $852 $1,400 $79 10.44% 1.60% 87.96% 4.5

3 (20) $611 $807 $1,376 $102 12.31% 0.58% 87.11% 5.0

4 (25) $640 $760 $1,361 $117 17.49% 0.42% 82.09% 6.0

5 (30) $666 $714 $1,344 $134 19.99% 0.21% 79.80% 6.5

6 (35) $726 $673 $1,365 $113 33.06% 0.00% 66.94% 8.7

7 (40) $809 $632 $1,410 $68 47.85% 0.00% 52.15% 11.4

8 (44) $994 $599 $1,563 -$85 72.25% 0.00% 27.75% 18.0

Table 11.3.11 Product Class 10, Chest Freezer: LCC and PBP Results for Low-Income 

Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $407 $578 $973

1 (10) $414 $533 $936 $37 0.00% 16.05% 83.95% 2.1

2 (15) $424 $506 $920 $53 0.85% 1.19% 97.96% 3.4

3 (20) $436 $479 $905 $68 1.68% 0.23% 98.09% 4.2

4 (25) $484 $451 $926 $47 26.98% 0.23% 72.79% 8.6

5 (30) $505 $424 $920 $53 29.21% 0.23% 70.56% 9.0

6 (35) $566 $404 $961 $12 55.24% 0.00% 44.76% 12.9

7 (41) $688 $369 $1,049 -$76 80.02% 0.00% 19.98% 19.1

Table 11.3.12 Standard-Size Freezers: Comparison of Average LCC Savings for 

Consumer Subgroups and All Households

Efficiency 

Level

(% less than 

baseline 

energy use) Upright Freezers (PC 9) Chest Freezers (PC 10)

Senior Low- All Senior Low- All
11-9

Income Income

1 (10) $62 $58 $62 $38 $37 $38

2 (15) $85 $79 $85 $55 $53 $55

3 (20) $111 $102 $111 $70 $68 $70

4 (25) $128 $117 $128 $50 $47 $50

5 (30) $148 $134 $148 $56 $53 $56

6 (35) $130 $113 $130 $17 $12 $17

7 (40/41) $87 $68 $87 -$71 -$76 -$71

8 (44) -$63 -$85 -$63

11.3.3 Built-In Refrigeration Products

Tables 11.4.13 through 11.4.20 summarize the LCC and PBP results for low-income 

consumers and senior citizens for the built-in refrigeration product representative product 

classes. Table 11.4.21 compares the average LCC savings at each efficiency level for the two 

consumer subgroups with the average LCC savings for the entire sample for each representative 

product class.

Table 11.3.13 Product Class 3A-BI, Built-In All Refrigerators: LCC and PBP Results

for Senior-Only Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $4,768 $710 $5,479

1 (10) $4,776 $659 $5,435 $44 0.32% 19.55% 80.13% 1.8

2 (15) $4,789 $632 $5,421 $58 3.42% 15.35% 81.23% 3.3

3 (20) $4,924 $602 $5,526 -$47 75.70% 5.50% 18.80% 17.6

4 (25) $5,116 $574 $5,690 -$211 95.86% 0.00% 4.14% 32.1

5 (29) $5,260 $555 $5,816 -$337 98.07% 0.00% 1.93% 39.9

Table 11.3.14 Product Class 5-BI, Built-In Bottom-Mount Refrigerator-Freezers: LCC 

and PBP Results for Senior-Only Households

Efficiency 

Level

(% less than 

baseline 

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating LCC

Average 

Savings 

% of Households that 

Experience Median
11-10

energy use) Cost 2009$ Net

Cost

No 

Impact

Net 

Benefit

Baseline $5,491 $841 $6,333

1 (10) $5,495 $834 $6,329 $6 1.80% 86.08% 12.12% 4.9

2 (15) $5,507 $841 $6,348 -$3 10.11% 86.03% 3.86% 14.7

3 (20) $5,544 $828 $6,372 -$26 31.95% 65.59% 2.46% 28.5

4 (25) $5,715 $804 $6,518 -$173 99.35% 0.00% 0.65% 72.1

5 (27) $5,813 $787 $6,600 -$255 99.66% 0.00% 0.34% 70.2

Table 11.3.15 Product Class 7-BI, Built-In Side-by-Side Refrigerator-Freezers with 

Through-the-Door Ice Service: LCC and PBP Results for Senior-Only 

Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $7,900 $1,293 $9,193

1 (10) $7,915 $1,276 $9,191 $7 8.01% 78.49% 13.50% 8.7

2 (15) $7,960 $1,261 $9,222 -$18 39.80% 52.43% 7.77% 21.0

3 (20) $8,092 $1,228 $9,319 -$116 60.24% 37.23% 2.53% 36.7

4 (22) $8,210 $1,211 $9,422 -$219 98.82% 0.00% 1.18% 60.0

Table 11.3.16 Product Class 9-BI, Built-In Upright Freezers: LCC and PBP Results for 

Senior-Only Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $4,350 $947 $5,297

1 (10) $4,366 $876 $5,242 $54 4.34% 19.90% 75.76% 3.4

2 (15) $4,381 $834 $5,215 $82 8.63% 1.70% 89.67% 4.3

3 (20) $4,476 $797 $5,273 $24 53.14% 0.57% 46.29% 12.8

4 (25) $4,623 $752 $5,375 -$78 78.19% 0.49% 21.32% 21.1

5 (27) $4,737 $730 $5,466 -$169 87.14% 0.27% 12.59% 26.8
11-11

Table 11.3.17 Product Class 3A-BI, Built-In All Refrigerators: LCC and PBP Results

for Low-Income Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $4,775 $776 $5,551

1 (10) $4,783 $719 $5,502 $49 0.23% 18.98% 80.79% 1.7

2 (15) $4,796 $690 $5,486 $65 3.04% 14.54% 82.42% 3.0

3 (20) $4,933 $656 $5,588 -$37 72.47% 4.75% 22.78% 16.3

4 (25) $5,124 $625 $5,749 -$198 94.15% 0.00% 5.85% 29.4

5 (29) $5,269 $603 $5,873 -$321 97.15% 0.00% 2.85% 36.2

Table 11.3.18 Product Class 5-BI, Built-In Bottom-Mount Refrigerator-Freezers: LCC 

and PBP Results for Low-Income Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $5,501 $911 $6,412

1 (10) $5,505 $902 $6,407 $7 1.47% 85.94% 12.59% 4.5

2 (15) $5,517 $908 $6,425 -$1 9.15% 85.89% 4.96% 13.2

3 (20) $5,554 $894 $6,448 -$24 31.65% 65.07% 3.28% 26.1

4 (25) $5,725 $866 $6,591 -$167 98.87% 0.00% 1.13% 62.2

5 (27) $5,824 $847 $6,671 -$247 99.31% 0.00% 0.69% 61.3

Table 11.3.19 Product Class 7-BI, Built-In Side-by-Side Refrigerator-Freezers with 

Through-the-Door Ice Service: LCC and PBP Results for Low-Income 

Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $7,884 $1,242 $9,126
11-12

1 (10) $7,900 $1,224 $9,124 $6 10.20% 75.93% 13.87% 9.2

2 (15) $7,951 $1,208 $9,159 -$24 45.73% 46.86% 7.41% 22.9

3 (20) $8,097 $1,173 $9,270 -$135 67.94% 30.06% 2.00% 39.0

4 (22) $8,216 $1,158 $9,374 -$239 98.99% 0.00% 1.01% 59.4

Table 11.3.20 Product Class 9-BI, Built-In Upright Freezers: LCC and PBP Results for 

Low-Income Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Life-Cycle Cost 2009$ Life-Cycle Cost Savings

Payback 

Period 

(years)

Installed 

Cost

Discounted 

Operating 

Cost LCC

Average 

Savings 

2009$

% of Households that 

Experience

Median

Net

Cost

No 

Impact

Net 

Benefit

Baseline $4,351 $885 $5,236

1 (10) $4,368 $819 $5,186 $50 5.04% 18.99% 75.97% 3.7

2 (15) $4,383 $779 $5,162 $74 9.89% 1.63% 88.48% 4.5

3 (20) $4,477 $746 $5,223 $13 57.04% 0.54% 42.42% 13.6

4 (25) $4,625 $703 $5,329 -$93 81.53% 0.47% 18.00% 22.4

5 (27) $4,738 $683 $5,422 -$185 89.56% 0.25% 10.19% 28.3

Table 11.3.21 Built-In Refrigeration Products: Comparison of Average LCC Savings 

for Consumer Subgroups and All Households

Efficiency 

Level

(% less than 

baseline 

energy use)

Built-in All 

Refrigerators

(PC 3A-BI)

Built-in Bottom-Mount 

Refrigerator-Freezers

(PC 5-BI)

Built-in Side-by-Side 

Refrigerator-Freezers

(PC 7-BI)

Built-in Upright 

Freezers

(PC 9-BI)

Senior

LowIncome All SeniorLowIncome All SeniorLowIncome All SeniorLowIncome All

1 (10) $44 $49 $47 $6 $7 $7 $7 $6 $7 $54 $50 $54

2 (15) $58 $65 $63 -$3 -$1 $0 -$18 -$24 -$18 $82 $74 $82

3 (20) -$47 -$37 -$34 -$26 -$24 -$21 -$116 -$135 -$116 $24 $13 $24

4 (25) -$211 -$198 -$195 -$173 -$167 -$164 -$219 -$239 -$219 -$78 -$93 -$78

5 

(29/27/22/27) -$337 -$321 -$318 -$255 -$247 -$244 -$169 -$185 -$169
12-i

CHAPTER 12. MANUFACTURER IMPACT ANALYSIS

12.1 INTRODUCTION ............................................................................................. 12-1

12.2 METHODOLOGY ............................................................................................ 12-1

12.2.1 Phase I: Industry Profile ............................................................................. 12-2

12.2.2 Phase II: Industry Cash-Flow Analysis and Interview Guide .................... 12-3

12.2.2.1 Industry Cash-Flow Analysis ....................................................... 12-3

12.2.2.2 Interview Guides........................................................................... 12-3

12.2.3 Phase III: Subgroup Analysis ..................................................................... 12-4

12.2.3.1 Manufacturing Interviews............................................................. 12-4

12.2.3.2 Revised Industry Cash-Flow Analysis.......................................... 12-4

12.2.3.3 Manufacturer Subgroup Analysis................................................. 12-4

12.2.3.3.1 Small-Business Manufacturer Subgroup ....................... 12-5

12.2.3.3.2 Built-in Refrigeration Manufacturer Subgroup ............. 12-6

12.2.3.4 Manufacturing Capacity Impact ................................................... 12-6

12.2.3.5 Employment Impact...................................................................... 12-6

12.2.3.6 Cumulative Regulatory Burden .................................................... 12-7

12.3 MANUFACTURER IMPACT ANALYSIS KEY ISSUES.............................. 12-7

12.3.1 Potential for Significant Changes to Manufacturing Facilities................... 12-7

12.3.2 VIPs ........................................................................................................ 12-8

12.3.3 Impact on U.S. Production and Jobs........................................................... 12-8

12.3.4 Impacts to Product Utility........................................................................... 12-8

12.3.5 Technical Difficulty to Achieve New Standards........................................ 12-9

12.3.6 Changes in Consumer Behavior ................................................................. 12-9

12.3.7 Separate Product Classes for Built-In Products........................................ 12-10

12.3.8 Test Procedure Concerns.......................................................................... 12-10

12.4 GRIM INPUTS AND ASSUMPTIONS.......................................................... 12-10

12.4.1 Overview of the GRIM............................................................................. 12-11

12.4.2 Sources for GRIM Inputs.......................................................................... 12-11

12.4.2.1 Corporate Annual Reports.......................................................... 12-11

12.4.2.2 Standard and Poor Credit Ratings............................................... 12-12

12.4.2.3 Shipment Model.......................................................................... 12-12

12.4.2.4 Engineering Analysis.................................................................. 12-12

12.4.2.5 Manufacturer Interviews............................................................. 12-13

12.4.3 Financial Parameters................................................................................. 12-13

12.4.4 Corporate Discount Rate........................................................................... 12-15

12.4.5 Trial Standard Levels................................................................................ 12-17

12.4.6 NIA Shipment Forecast ............................................................................ 12-21

12.4.6.1 Shipments Forecast..................................................................... 12-22

12.4.6.2 Default Standards-Case NIA Scenario ....................................... 12-27

12.4.7 Production Costs....................................................................................... 12-28

12.4.8 Conversion Costs...................................................................................... 12-32

12.4.8.1 Capital Conversion Costs ........................................................... 12-33

12.4.8.2 Product Conversion Costs........................................................... 12-44

12.4.9 Markup Scenarios..................................................................................... 12-55
12-ii

12.4.9.1 Flat Markup Scenario ................................................................. 12-55

12.4.9.2 Preservation of Operating Profit Scenario.................................. 12-56

12.4.10 Federal Production Tax Credits.................................................... 12-63

12.5 INDUSTRY FINANCIAL IMPACTS ............................................................ 12-63

12.5.1 Introduction............................................................................................... 12-63

12.5.2 Industry Financial Impacts ....................................................................... 12-65

12.6 IMPACTS ON SMALL RESIDENTIAL REFRIGERATION 

MANUFACTURERS ...................................................................................... 12-71

12.7 OTHER IMPACTS.......................................................................................... 12-72

12.7.1 Employment.............................................................................................. 12-72

12.7.1.1 Methodology............................................................................... 12-72

12.7.1.2 Standard-Size Refrigerator-Freezers Employment Impacts....... 12-74

12.7.1.3 Standard-Size Freezers Employment Impacts............................ 12-76

12.7.1.4 Compact Refrigeration Products Employment Impacts............. 12-78

12.7.1.5 Built-In Refrigeration Products Employment Impacts............... 12-79

12.7.2 Production Capacity.................................................................................. 12-81

12.7.3 Cumulative Regulatory Burden ................................................................ 12-81

12.7.3.1 DOE Regulations for Other Products Produced by Residential 

Refrigeration Manufacturers......................................................... 12-82

12.7.3.2 Other Federal Regulations.......................................................... 12-85

Unites States Clean Air Act ..................................................... 12-85

Potential Climate Change and Greenhouse Gas Legislation ... 12-86

12.7.3.3 Other Regulations That Could Impact Residential Refrigeration 

Manufacturers............................................................................... 12-86

State Energy Conservation Standards...................................... 12-86

International Energy Conservation Standards ......................... 12-87

12.8 CONCLUSION................................................................................................ 12-87

12.8.1 Standard-Size Refrigerator-Freezers ........................................................ 12-88

12.8.2 Standard-Size Freezers ............................................................................. 12-92

12.8.3 Compact Refrigeration Products............................................................... 12-95

12.8.4 Built-In Refrigeration Products ................................................................ 12-99

LIST OF TABLES

Table 12.2.1 SBA and NAICS Classification of Small Businesses Potentially Affected by 

This Rulemaking............................................................................................................ 12-5

Table 12.4.1 GRIM Financial Parameters Based on 1999–2006 Weighted Company 

Financial Data .............................................................................................................. 12-14

Table 12.4.2 GRIM Freestanding Residential Refrigeration Industry Financial Parameters

...................................................................................................................................... 12-14

Table 12.4.3 GRIM Built-In Refrigeration Industry Financial Parameters................. 12-15

Table 12.4.4 Cost of Equity Calculation...................................................................... 12-16

Table 12.4.5 Cost of Debt Calculation......................................................................... 12-17

Table 12.4.6 Trial Standard Levels for Standard-Size Refrigerator-Freezers............. 12-18

Table 12.4.7 Trial Standard Levels for Standard-Size Freezers.................................. 12-19
12-iii

Table 12.4.8 Trial Standard Levels for Compact Refrigeration Products ................... 12-20

Table 12.4.9 Trial Standard Levels for Built-in Refrigeration Products ..................... 12-21

Table 12.4.10 Total Base Case NIA Shipments Forecast in 2014 in the Main NIA 

Shipment Scenario ....................................................................................................... 12-22

Table 12.4.11 Standard-Size Refrigerator-Freezers: Base-Case Efficiency Distributions

...................................................................................................................................... 12-23

Table 12.4.12 Top-Mount Refrigerator-Freezers: Efficiency Distributions in 2014 by 

Efficiency Level........................................................................................................... 12-23

Table 12.4.13 Bottom-Mount Refrigerator-Freezers: Efficiency Distributions in 2014 by 

Efficiency Level........................................................................................................... 12-24

Table 12.4.14 Side-by Side Refrigerator-Freezers: Efficiency Distributions in 2014 by 

Efficiency Level........................................................................................................... 12-24

Table 12.4.15 Standard-Size Freezers: Base-Case Efficiency Distributions............... 12-25

Table 12.4.16 Upright Freezers: Efficiency Distributions in 2014 by Efficiency Level. 12-

25

Table 12.4.17 Chest Freezers: Efficiency Distributions in 2014 by Efficiency Level 12-26

Table 12.4.18 Compact Refrigeration Products: Base-Case Efficiency Distributions 12-26

Table 12.4.19 Compact Refrigerators: Efficiency Distributions in 2014 by Efficiency 

Level ............................................................................................................................ 12-27

Table 12.4.20 Compact Freezers: Efficiency Distributions in 2014 by Efficiency Level12-

27

Table 12.4.21 MPC Breakdown for Refrigerator-Freezers for Product Class 3 (Automatic 

Defrost with Top-Mounted Freezer without Through-the-Door Ice Service) ............. 12-29

Table 12.4.22 MPC Breakdown for Refrigerator-Freezers for Product Class 5 (Automatic 

Defrost with Bottom-Mounted Freezer without Through-the-Door Ice Service)........ 12-29

Table 12.4.23 MPC Breakdown for Refrigerator-Freezers for Product Class 7 (Automatic 

Defrost with Side-Mounted Freezer with Through-the-Door Ice Service).................. 12-30

Table 12.4.24 MPC Breakdown for Product Class 9 (Upright Freezers with Automatic 

Defrost) ........................................................................................................................ 12-30

Table 12.4.25 MPC Breakdown for Product Class 10 (Chest Freezers and All Other 

Freezers Except Compact Freezers)............................................................................. 12-30

Table 12.4.26 MPC Breakdown for Product Class 11 (Compact Refrigerators and 

Refrigerator-Freezers with Manual Defrost) ............................................................... 12-31

Table 12.4.27 MPC Breakdown for Product Class 18 (Compact Chest Freezers)...... 12-31

Table 12.4.28 MPC Breakdown for Product Class 3A-BI (Built-In All-RefrigeratorsAutomatic Defrost) ...................................................................................................... 12-31

Table 12.4.29 MPC Breakdown for Product Class 5-BI (Built-In Refrigerator-Freezers—

Automatic Defrost with Bottom-Mounted Freezer without an Automatic Icemaker). 12-32

Table 12.4.30 MPC Breakdown for Product Class 7-BI (Built-In Refrigerator-Freezers—

Automatic Defrost with Side-mounted Freezer with Through-the-Door Ice Service) 12-32

Table 12.4.31 MPC Breakdown for Product Class 9-BI (Built-In Upright Freezers with 

Automatic Defrost Without an Automatic Icemaker).................................................. 12-32

Table 12.4.32 Capital Conversion Costs for Product Class 3 (Automatic Defrost with 

Top-Mounted Freezer Without Through-the-Door Ice Service) by TSL .................... 12-35

Table 12.4.33 Capital Conversion Costs for Product Class 5 (Automatic Defrost with 

Bottom-Mounted Freezer without Through-the-Door Ice Service) by TSL................ 12-36
12-iv

Table 12.4.34 Capital Conversion Costs for Product Class 7 (Automatic Defrost with 

Side-Mounted Freezer with Through-the-Door Ice Service) by TSL.......................... 12-37

Table 12.4.35 Capital Conversion Costs for Product Class 9 (Upright Freezers with 

Automatic Defrost) by TSL ......................................................................................... 12-38

Table 12.4.36 Capital Conversion Costs for Product Class 10 (Chest Freezers and All 

Other Freezers Except Compact Freezers) by TSL ..................................................... 12-39

Table 12.4.37 Capital Conversion Costs for Product Class 11 (Compact Refrigerators and 

Refrigerator-Freezers with Manual Defrost) by TSL .................................................. 12-40

Table 12.4.38 Capital Conversion Costs for Product Class 18 (Compact Chest Freezers) 

by TSL ......................................................................................................................... 12-41

Table 12.4.39 Capital Conversion Costs for Product Class 3A-BI (Built-In AllRefrigerators-Automatic Defrost) by TSL................................................................... 12-42

Table 12.4.40 Capital Conversion Costs for Product Class 5-BI (Built-In RefrigeratorFreezers—Automatic Defrost with Bottom-Mounted Freezer without an Automatic 

Icemaker) by TSL ........................................................................................................ 12-43

Table 12.4.41 Capital Conversion Costs for Product Class 8-BI (Built-In RefrigeratorFreezers—Automatic Defrost with Side-mounted Freezer with Through-the-Door Ice 

Service) by TSL........................................................................................................... 12-43

Table 12.4.42 Capital Conversion Costs for Product Class 9-BI (Built-In Upright 

Freezers with Automatic Defrost Without an Automatic Icemaker)........................... 12-44

Table 12.4.43 Product Conversion Costs for Product Class 3 (Automatic Defrost with 

Top-Mounted Freezer Without Through-the-Door Ice Service) by TSL .................... 12-46

Table 12.4.44 Product Conversion Costs for Product Class 5 (Automatic Defrost with 

Bottom-Mounted Freezer without Through-the-Door Ice Service) by TSL................ 12-47

Table 12.4.45 Product Conversion Costs for Product Class 7 (Automatic Defrost with 

Side-Mounted Freezer with Through-the-Door Ice Service) by TSL.......................... 12-48

Table 12.4.46 Product Conversion Costs for Product Class 9 (Upright Freezers with 

Automatic Defrost) by TSL ......................................................................................... 12-49

Table 12.4.47 Product Conversion Costs for Product Class 10 (Chest Freezers and All 

Other Freezers Except Compact Freezers) by TSL ..................................................... 12-50

Table 12.4.48 Product Conversion Costs for Product Class 11 (Compact Refrigerators 

and Refrigerator-Freezers with Manual Defrost) by TSL............................................ 12-51

Table 12.4.49 Product Conversion Costs for Product Class 18 (Compact Chest Freezers) 

by TSL ......................................................................................................................... 12-52

Table 12.4.50 Product Conversion Costs for Product Class 3A-BI (Built-In AllRefrigerators-Automatic Defrost) by TSL................................................................... 12-53

Table 12.4.51 Product Conversion Costs for Product Class 5-BI (Built-In RefrigeratorFreezers—Automatic Defrost with Bottom-Mounted Freezer without an Automatic

Icemaker) by TSL ........................................................................................................ 12-54

Table 12.4.52 Product Conversion Costs for Product Class 7-BI (Built-In RefrigeratorFreezers—Automatic Defrost with Side-mounted Freezer with Through-the-Door Ice 

Service) by TSL........................................................................................................... 12-54

Table 12.4.53 Product Conversion Costs for Product Class 9-BI (Built-In Upright 

Freezers with Automatic Defrost Without an Automatic Icemaker) by TSL.............. 12-55

Table 12.4.54 Preservation of Operating Profit Markups for Product Class 3 (Automatic 

Defrost with Top-Mounted Freezer Without Through-the-Door Ice Service) ............ 12-57
12-v

Table 12.4.55 Preservation of Operating Profit Markups for Product Class 5 (Automatic 

Defrost with Bottom-Mounted Freezer without Through-the-Door Ice Service)........ 12-57

Table 12.4.56 Preservation of Operating Profit Markups for Product Class 7 (Automatic 

Defrost with Side-Mounted Freezer with Through-the-Door Ice Service).................. 12-58

Table 12.4.57 Preservation of Operating Profit Markups for Product Class 9 (Upright 

Freezers with Automatic Defrost)................................................................................ 12-58

Table 12.4.58 Preservation of Operating Profit Markups for Product Class 10 (Chest 

Freezers and All Other Freezers Except Compact Freezers)....................................... 12-59

Table 12.4.59 Preservation of Operating Profit Markups for Product Class 11 (Compact 

Refrigerators and Refrigerator-Freezers with Manual Defrost)................................... 12-60

Table 12.4.60 Preservation of Operating Profit Markups for Product Class 18 (Compact 

Chest Freezers)............................................................................................................. 12-61

Table 12.4.61 Preservation of Operating Profit Markups for Product Class 3A-BI (BuiltIn All-Refrigerators-Automatic Defrost)..................................................................... 12-61

Table 12.4.62 Preservation of Operating Profit Markups for Product Class 5-BI (Built-In 

Refrigerator-Freezers—Automatic Defrost with Bottom-Mounted Freezer without an 

Automatic Icemaker) ................................................................................................... 12-62

Table 12.4.63 Preservation of Operating Profit Markups for Product Class 7-BI (Built-In 

Refrigerator-Freezers—Automatic Defrost with Side-mounted Freezer with Through-theDoor Ice Service)......................................................................................................... 12-62

Table 12.4.64 Preservation of Operating Profit Markups for Product Class 9-BI (Built-In 

Upright Freezers with Automatic Defrost Without an Automatic Icemaker).............. 12-63

Table 12.5.1 Changes in Industry Net Present Value for Standard-Size RefrigeratorFreezers (Flat Markup Scenario) ................................................................................. 12-65

Table 12.5.2 Changes in Industry Net Present Value for Standard-Size RefrigeratorFreezers (Preservation of Operating Profit Markup Scenario) .................................... 12-65

Table 12.5.3 Changes in Industry Net Present Value for Standard-Size Freezers (Flat 

Markup Scenario)......................................................................................................... 12-67

Table 12.5.4 Changes in Industry Net Present Value for Standard-Size Freezers 

(Preservation of Operating Profit Markup Scenario)................................................... 12-67

Table 12.5.5 Changes in Industry Net Present Value for Compact Refrigeration Products 

(Flat Markup Scenario)................................................................................................ 12-68

Table 12.5.6 Changes in Industry Net Present Value for Compact Refrigeration Products 

(Preservation of Operating Profit Markup Scenario)................................................... 12-68

Table 12.5.7 Changes in Industry Net Present Value for Built-In Refrigeration Products 

(Flat Markup Scenario)................................................................................................ 12-70

Table 12.5.8 Changes in Industry Net Present Value for Built-In Refrigeration Products 

(Preservation of Operating Profit Markup Scenario)................................................... 12-70

Table 12.7.1 Potential Changes in the Total Number of Domestic Standard-Size 

Refrigerator-Freezers Production Workers in 2014..................................................... 12-75

Table 12.7.2 Potential Changes in the Total Number of Domestic Standard-Size Freezers 

Production Workers in 2014 ........................................................................................ 12-77

Table 12.7.3 Potential Changes in the Total Number of Domestic Compact Refrigeration 

Products Production Workers in 2014 ......................................................................... 12-78

Table 12.7.4 Potential Changes in the Total Number of Domestic Built-In Refrigeration 

Products Production Workers in 2014 ......................................................................... 12-80
12-vi

Table 12.7.5 Other DOE and Federal Actions Affecting the Residential Refrigeration 

Industry ........................................................................................................................ 12-83

Table 12.7.6 DOE Regulations on Products For Which Residential Refrigeration 

Manufacturers Hold Significant Market Share ............................................................ 12-85

LIST OF FIGURES

Figure 12.4.1 Using the GRIM to Calculate Cash Flow.............................................. 12-11

Figure 12.5.1 Annual Industry Net Cash Flows for Standard-Size Refrigerator-Freezers 

(Flat Markup Scenario)................................................................................................ 12-66

Figure 12.5.2 Annual Industry Net Cash Flows for Standard-Size Refrigerator-Freezers 

(Preservation of Operating Profit Markup Scenario)................................................... 12-66

Figure 12.5.3 Annual Industry Net Cash Flows for Standard-Size Freezers (Flat Markup 

Scenario) ...................................................................................................................... 12-67

Figure 12.5.4 Annual Industry Net Cash Flows for Standard-Size Freezers (Preservation 

of Operating Profit Markup Scenario)......................................................................... 12-68

Figure 12.5.5 Annual Industry Net Cash Flows for Compact Refrigeration Products (Flat 

Markup Scenario)......................................................................................................... 12-69

Figure 12.5.6 Annual Industry Net Cash Flows for Compact Refrigeration Products 

(Preservation of Operating Profit Markup Scenario)................................................... 12-69

Figure 12.5.7 Annual Industry Net Cash Flows for Built-In Refrigeration Products (Flat 

Markup Scenario)......................................................................................................... 12-70

Figure 12.5.8 Annual Industry Net Cash Flows for Built-In Refrigeration Products 

(Preservation of Operating Profit Markup Scenario)................................................... 12-71

Figure 12.7.1 Total Standard-Size Refrigerator-Freezers Industry Domestic Employment 

by Year......................................................................................................................... 12-75

Figure 12.7.2 Total Standard-Size Freezers Industry Domestic Employment by Year... 12-

77

Figure 12.7.3 Total Compact Refrigeration Products Industry Domestic Employment by 

Year.............................................................................................................................. 12-79

Figure 12.7.4 Total Built-In Refrigeration Products Industry Domestic Employment by 

Year.............................................................................................................................. 12-80
12-1

CHAPTER 12. MANUFACTURER IMPACT ANALYSIS

12.1 INTRODUCTION

In determining whether a standard is economically justified, the U.S. Department 

of Energy (DOE) is required to consider “the economic impact of the standard on the 

manufacturers and on the consumers of the products subject to such a standard.” (42 

U.S.C. 6313(a)(6)(B)(i)) The law also calls for an assessment of the impact of any 

lessening of competition as determined in writing by the Attorney General. Id. DOE 

conducted a manufacturer impact analysis (MIA) to estimate the financial impact of 

amended energy conservation standards on manufacturers of residential refrigerators, 

freezers, and refrigerator-freezers, and assessed the impact of such standards on direct 

employment and manufacturing capacity. 

The MIA has both quantitative and qualitative aspects. The quantitative part of 

the MIA primarily relies on the Government Regulatory Impact Model (GRIM), an 

industry cash-flow model adapted for each product in this rulemaking. The GRIM inputs 

include information on industry cost structure, shipments, and pricing strategies. The 

GRIM’s key output is the industry net present value (INPV). The model estimates the 

financial impact of more stringent energy conservation standards for each product by 

comparing changes in INPV between a base case and the various trial standard levels 

(TSLs) in the standards case. The qualitative part of the MIA addresses product 

characteristics, manufacturer characteristics, market and product trends, as well as the 

impact of standards on subgroups of manufacturers. 

12.2 METHODOLOGY

DOE conducted the MIA in three phases. Phase I, “Industry Profile,” consisted of 

preparing an industry characterization for the residential refrigerators, freezers, and 

refrigerator-freezers industry, including data on market share, sales volumes and trends, 

pricing, employment, and financial structure. In Phase II, “Industry Cash Flow,” DOE 

used the GRIM to assess the impacts of amended energy conservation standards on four

major product types for this rulemaking:

1) Standard-Size Refrigerator-Freezers

2) Standard-Size Freezers

3) Compact Refrigeration Products

4) Built-in Refrigeration Products

In Phase II, DOE created a GRIM for residential refrigeration products and an 

interview guide to gather information on the potential impacts on manufacturers. DOE 

presented the MIA results for standard-size refrigerator-freezers, standard-size freezers, 

compact refrigeration products, and built-in refrigeration products separately. Each of the 

four groups of product classes and results is based on a unique set of considered TSLs.

These TSLs are described in Section 12.4.5 below.
12-2

In Phase III, “Subgroup Impact Analysis,” DOE interviewed manufacturers 

representing more than 95 percent of standard-size refrigerator-freezer sales, 

approximately 95 percent of standard-size freezer sales, about 75 percent of compact 

refrigeration product sales, and more than 95 percent of built-in refrigeration products 

sales. Interviewees included large and small manufacturers with various market shares 

and market focus, providing a representative cross-section of the industries. During 

interviews, DOE discussed financial topics specific to each manufacturer and obtained 

each manufacturer’s view of the industry. The interviews provided DOE with valuable 

information for evaluating the impacts of amended energy conservation standards on 

manufacturer cash flows, investment requirements, and employment. 

DOE groups the MIA results by product classes that are made by the same 

manufacturers. As stated above, DOE presents separate results for standard-size 

refrigerator-freezers, standard-size freezers, compact refrigeration products, and built-in 

refrigeration products.

12.2.1 Phase I: Industry Profile

In Phase I of the MIA, DOE prepared a profile of the residential refrigeration 

industry that built upon the market and technology assessment prepared for this 

rulemaking. (See chapter 3 of this Technical Support Document (TSD).) Before initiating 

the detailed impact studies, DOE collected information on the present and past structure 

and market characteristics of each industry. This information included market share data, 

product shipments, manufacturer markups, and the cost structure for various 

manufacturers. The industry profile includes: (1) further detail on the overall market and 

product characteristics; (2) estimated manufacturer market shares; (3) financial 

parameters such as net plant, property, and equipment; selling, general and administrative 

(SG&A) expenses; cost of goods sold, etc.; and (4) trends in the number of firms, market, 

and product characteristics. The industry profile included a top-down cost analysis of 

residential refrigeration manufacturers that DOE used to derive preliminary financial 

inputs for the GRIM (e.g., revenues, depreciation, SG&A, and research and development 

(R&D) expenses).

DOE also used public information to further calibrate its initial characterization of 

the residential refrigeration industry, including Securities and Exchange Commission 

(SEC) 10–K reports,

1 Standard & Poor’s (S&P) stock reports,2 corporate annual reports, 

and the U.S. Census Bureau’s 2007 Annual Survey of Manufacturers (2007 ASM).

3 DOE 

also characterized these industries using information from its engineering analysis and 

the life-cycle cost analysis.
12-3

12.2.2 Phase II: Industry Cash-Flow Analysis and Interview Guide

Phase II focused on the financial impacts of potential amended energy 

conservation standards on manufacturers of standard-size refrigerator-freezers, standardsize freezers, compact refrigeration products, and built-in refrigeration products. More

stringent energy conservation standards can affect manufacturer cash flows in three 

distinct ways: (1) create a need for increased investment, (2) raise production costs per 

unit, and (3) alter revenue due to higher per-unit prices and/or possible changes in sales 

volumes. To quantify these impacts, DOE used the GRIM to perform a cash-flow 

analysis for residential refrigerators, freezers, and refrigerator-freezers. In performing 

these analyses, DOE used the financial values derived during Phase I and the shipment 

scenarios used in the NIA. In Phase II, DOE performed these preliminary industry cashflow analyses and prepared written guides for manufacturer interviews.

12.2.2.1 Industry Cash-Flow Analysis

The GRIM uses several factors to determine a series of annual cash flows from 

the announcement year of amended energy conservation standards until several years 

after the standards’ compliance date. These factors include annual expected revenues, 

costs of sales, SG&A, taxes, and capital expenditures related to the amended standards. 

Inputs to the GRIM include manufacturing production costs, selling prices, and 

shipments forecasts developed in other analyses. DOE derived the manufacturing costs 

from the engineering analysis and information provided by the industry and estimated 

typical manufacturer markups from public financial reports and interviews with 

manufacturers. DOE developed alternative markup scenarios for each GRIM based on 

discussions with manufacturers. DOE’s shipments analysis, presented in chapter 9 of this 

TSD, provided the basis for the shipment projections in the GRIM. The financial 

parameters were developed using publicly available manufacturer data and were revised 

with information submitted confidentially during manufacturer interviews. The GRIM 

results are compared to base case projections for the industry. The financial impact of 

amended energy conservation standards is the difference between the discounted annual 

cash flows in the base case and standards case at each TSL.

12.2.2.2 Interview Guides

During Phase III of the MIA, DOE interviewed manufacturers to gather 

information on the effects of amended energy conservation on revenues and finances, 

direct employment, capital assets, and industry competitiveness. Before the interviews, 

DOE distributed an interview guide for the residential refrigeration industry. The 

interview guide provided a starting point to identify relevant issues and help identify the 

impacts of amended energy conservation standards on individual manufacturers or 

subgroups of manufacturers. Most of the information DOE received from these meetings 

is protected by non-disclosure agreements and resides with DOE’s contractors. Before 

each telephone interview or site visit, DOE provided company representatives with an 

interview guide that included the topics for which DOE sought input. The MIA interview 

topics included (1) key issues to this rulemaking; (2) a company overview and 

organizational characteristics; (3) engineering and life cycle cost analysis follow-up; (4) 
12-4

manufacturer markups and profitability; (5) shipment projections and market shares; (6) 

financial parameters; (7) conversion costs; (8) cumulative regulatory burden; (9) impacts 

of potential HFC regulations; (10) direct employment impact assessment; (11) exports, 

foreign competition, and outsourcing; (12) consolidation; and (13) impacts on small 

business. The interview guides are presented in appendix 12-A.

12.2.3 Phase III: Subgroup Analysis

For its analysis, DOE presented the impacts on standard-size refrigerator-freezers, 

standard-size freezers, compact refrigeration products, and built-in refrigeration products 

separately. While conducting the MIA, DOE interviewed a representative cross-section of 

residential refrigeration manufacturers. The MIA interviews broadened the discussion to 

include business-related topics. DOE sought to obtain feedback from industry on the 

approaches used in the GRIMs and to isolate key issues and concerns. During interviews, 

DOE defined two manufacturer subgroups (small businesses and built-in refrigeration 

manufacturers) that could be disproportionately impacted by amended energy 

conservation standards. These subgroups are described in detail below. 

12.2.3.1 Manufacturing Interviews

The information gathered in Phase I and the cash-flow analysis performed in 

Phase II are supplemented with information gathered from manufacturer interviews in 

Phase III. The interview process provides an opportunity for interested parties to express 

their views on important issues privately, allowing confidential or sensitive information 

to be considered in the rulemaking process.

DOE used these interviews to tailor the GRIM to reflect unique financial 

characteristics of each product group. Within each manufacturer group, DOE contacted 

companies from its database of manufacturers. Small and large companies, subsidiaries 

and independent firms, and public and private corporations were interviewed to provide a 

representation of the industry. Interviews were scheduled well in advance to provide 

every opportunity for key individuals to be available for comment. Although a written 

response to the questionnaire was acceptable, DOE sought interactive interviews, which 

help clarify responses and identify additional issues. The resulting information provides 

valuable inputs to the GRIM developed for the product classes.

12.2.3.2 Revised Industry Cash-Flow Analysis

In Phase II of the MIA, DOE provided manufacturers with preliminary GRIM 

input financial figures for review and evaluation. During the interviews, DOE requested 

comments on the values it selected for the parameters. DOE revised its industry cashflow models based on this feedback. Section 12.4.3 provides more information on how 

DOE calculated the parameters.

12.2.3.3 Manufacturer Subgroup Analysis 

Using average cost assumptions to develop an industry-cash-flow estimate may 

not adequately assess differential impacts of amended energy conservation standards 
12-5

among manufacturer subgroups. For example, small manufacturers, niche players, or 

manufacturers exhibiting a cost structure that largely differs from the industry average 

could be more negatively affected. To address this possible impact, DOE used the results 

of the industry characterization analysis in Phase I to group manufacturers that exhibit 

similar characteristics. During the manufacturer interviews, DOE discussed financial 

topics specific to each manufacturer and obtained each manufacturer’s view of the 

industry as a whole. As described in section 12.2.3, DOE presents the industry impacts by 

major product groupings. DOE presents the industry impacts by the major product types 

(standard-size refrigerator-freezers, standard-size freezers, compact refrigeration 

products, and built-in refrigeration products). These product groupings represent markets 

that are served by the same manufacturers. By segmenting the results into these product 

types, DOE is able to discuss how these subgroups of manufacturers will be impacted by 

amended energy conservation standards. Grouping these product categories reduced the 

need for a subgroup analysis to the consideration of built-in refrigeration product

manufacturers because the impacts of each group are characterized by the MIA 

separately. DOE identified one small business manufacturer but did not analyze a 

separate subgroup of small business manufacturers for the reasons discussed below.

12.2.3.3.1 Small-Business Manufacturer Subgroup

DOE investigated whether small business manufacturers should be analyzed as a 

manufacturer subgroup. DOE used the Small Business Administration (SBA) small 

business size standards published on August 22, 2008, as amended, and the North 

American Industry Classification System (NAICS) code, presented in Table 12.2.1 , to 

determine whether any small entities would be affected by the rulemaking.a

Table 12.2.1 SBA and NAICS Classification of Small Businesses Potentially Affected 

by This Rulemaking

For the 

product classes under review, the SBA bases its small business definition on the total 

number of employees for a business, its subsidiaries, and its parent companies. An 

aggregated business entity with fewer employees than the listed limit is considered a 

small business.

Industry Description Revenue Limit Employee Limit NAICS

Household Refrigerator and Home Freezer

Manufacturing N/A 1,000 335222

DOE used the Association of Home Appliance Manufacturers4 member directory 

to identify manufacturers of residential refrigeration products. DOE also reviewed public 

certification databases such as the Federal Trade Commission5 database. DOE asked 

interested parties and industry representatives if they were aware of other small business 

manufacturers. Then, DOE consulted publicly available data, product databases like 

ENERGY STAR6 and the California Energy Commission (CEC)7

a The size standards are available on the SBA’s website at 

www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf.

, and manufacturers to 

determine which manufacturers meet SBA’s definition of a small business. 
12-6

During its research, DOE identified only one company which manufactures 

products covered by this rulemaking and qualifies as small business per the applicable 

SBA definition. DOE contacted the small business to solicit feedback on the potential 

impacts of energy conservation standards. In addition to posing the standard MIA 

interview questions, DOE solicited data from other manufacturers on differential impacts 

this company and other small companies might experience from amended energy 

conservation standards. Because only one manufacturer qualified as a small business, 

DOE did not analyze a separate subgroup of small business manufacturer for this NOPR.

12.2.3.3.2 Built-in Refrigeration Manufacturer Subgroup

Built-in refrigeration product manufacturers are a second potential subgroup. 

However, because DOE is establishing separate product classes for built-in products, 

DOE is already presenting separate results and impacts for this potential manufacturer 

subgroup. The impacts on the manufacturers of these niche products are therefore already 

characterized in the broader MIA and do not require an explicit subgroup analysis.

12.2.3.4 Manufacturing Capacity Impact

One significant outcome of amended energy conservation standards could be the 

obsolescence of existing manufacturing assets, including tooling and investment. The 

manufacturer interview guides have a series of questions to help identify impacts of 

amended standards on manufacturing capacity, specifically capacity utilization and plant 

location decisions in the United States and North America, with and without amended 

standards; the ability of manufacturers to upgrade or remodel existing facilities to 

accommodate the new requirements; the nature and value of any stranded assets; and 

estimates for any one-time changes to existing plant, property, and equipment (PPE). 

DOE’s estimates of the one-time capital changes and stranded assets affect the cash flow 

estimates in the GRIM. These estimates can be found in section 12.4.8; DOE’s discussion 

of the capacity impact can be found in section 12.7.2.

12.2.3.5 Employment Impact 

The impact of amended energy conservation standards on employment is an 

important consideration in the rulemaking process. To assess how domestic direct 

employment patterns might be affected, the interviews explored current employment 

trends in the residential refrigeration industry. The interviews also solicited manufacturer 

views on changes in employment patterns that may result from more stringent standards. 

The employment impacts section of the interview guide focused on current employment 

levels associated with manufacturers at each production facility, expected future 

employment levels with and without amended energy conservation standards, and 

differences in workforce skills and issues related to the retraining of employees. The 

employment impacts are reported in section 12.7.1. 
12-7

12.2.3.6 Cumulative Regulatory Burden

DOE seeks to mitigate the overlapping effects on manufacturers due to amended 

energy conservation standards and other regulatory actions affecting the same products. 

DOE analyzed the impact on manufacturers of multiple, product-specific regulatory 

actions. Based on its own research and discussions with manufacturers, DOE identified 

regulations relevant to residential refrigeration manufacturers, such as State regulations 

and other Federal regulations that impact other products made by the same

manufacturers. Discussion of the cumulative regulatory burden can be found in section 

12.7.3. 

12.3 MANUFACTURER IMPACT ANALYSIS KEY ISSUES

Each MIA interview starts by asking: “What are the key issues for your company 

regarding the energy conservation standard rulemaking?” This question prompts 

manufacturers to identify the issues they feel DOE should explore and discuss further 

during the interview. The following sections describe the most significant issues 

identified by manufacturers. These summaries are provided in aggregate to protect 

manufacturer confidentiality. 

12.3.1 Potential for Significant Changes to Manufacturing Facilities

A number of manufacturers indicated that conversion costs would be 

exponentially greater if the adopted standards require significant rather than incremental 

increases in efficiency. While DOE does not analyze design options that would lower 

consumer utility, manufacturers indicated that for some product classes they would 

consider wall thickness increases if they resulted in lower per unit costs. However, 

manufacturers also indicated that wall thickness increases in response to more stringent 

energy standards would be extremely capital intensive. Changing the wall thickness 

would require extensive investments to completely replace injection molding equipment, 

interior fabrication feeder lines and equipment, and foaming fixtures on every production 

line. Such substantial changes would require many times the investment of incremental 

efficiency improvements. By comparison, the design and implementation of a new heat 

exchanger design would only possible require new fabrication tooling for the component 

and slight adjustments to production line tooling but would leave most of the existing 

production equipment intact. Smaller manufacturers were generally concerned that 

conversion costs would disproportionately impact their operations since comparable 

product and capital conversion costs would be spread over a smaller shipment volume.

Additionally, several manufacturers stated that new standards could increase the 

total steady state invested capital necessary to maintain current production levels. As an 

example, many plants leverage economies of scope by utilizing a shared front end of 

production (cabinet and door bending, for example) to serve multiple product lines. These 

economies would be forfeited if amended standards disproportionately affected one 

product class utilizing the shared front end. As such, manufacturing plants could have 

relatively lower capital intensity following standards. 
12-8

12.3.2 VIPs

Manufacturers were also concerned about potential issues with a standard that 

effectively required the widespread adoption of VIPs. In particular, the material costs of 

VIPs would add significant costs to the products, especially at the retail level. 

Manufacturers were concerned that using this design option in product classes that 

historically have been low-cost options could have unintended consequences such as 

inducing consumers to prolong the life of the products or switch to less profitable 

products. Manufacturers were also concerned about the additional labor that is required to 

install VIPs. Additional production steps would be required with VIPs, which require 

greater care in handling to prevent damaging the components. While less of a concern on 

lower volume products, the additional production steps on high-speed production lines 

would add tremendous complexity. The additional production steps and slower line rates 

would lengthen the production lines and require additional equipment. 

Manufacturers were also concerned about the ability of VIP suppliers to ramp up 

production to meet necessary demand from more stringent standards. Finally, 

manufacturers indicated that their experience with VIPs has shown a range of efficiency 

improvements lower than the theoretical benefit of VIPs. They are also concerned about 

the degradation of the panels over the lifetime of their products. Because of the range of 

efficiency improvements in practice, some manufacturers indicated they could elect to 

employ other design pathways that would eliminate these potential problems with the 

technology. 

12.3.3 Impact on U.S. Production and Jobs

Manufacturers generally agreed that standards that required substantial capital 

conversion costs would lower U.S. production and employment. Depending on the level 

of these expenditures, some manufacturers stated that new investments would not be 

made in the U.S., given the lower labor costs overseas. Margins are already thin for 

certain product classes, and manufacturers believed that higher standards could further 

reduce profitability. The lower labor costs could offset some of the impact on 

profitability, especially for their lower margin product lines. Some manufacturers stated 

they could also choose to source or drop altogether certain product lines they currently 

manufacture if they did not believe they could recoup the capital investments required to 

meet amended energy conservation standards on those lines. Any decision to drop or 

source more product lines would also lead to less domestic production and jobs. 

12.3.4 Impacts to Product Utility 

Several manufacturers expressed concern that more stringent energy standards

could impact the utility of their products. Most residential kitchens have standardized size 

openings for refrigerators, which would force any wall thickness growth inward and 

lower internal volume. While this was not analyzed as a design option for all products, 

manufacturers indicated some in the industry could elect to use thicker walls to meet new 

standards for full size refrigerator-freezers. Finally, several manufacturers indicated that 

other product features currently available may have to be removed in order to both meet 
12-9

new standard levels and maintain product prices that would be acceptable to consumers. 

Examples of these features include ice and water dispensers, glass doors, soda can 

dispensers, crisper compartments, anti-sweat features, and food preservation capabilities.

Manufacturers are also concerned that the energy savings from more stringent 

energy conservation standards would not be great enough to justify passing through the 

added costs to consumers. Currently, manufacturers bundle higher efficiency with other 

desirable features to justify higher prices for those ENERGY STAR models. According 

to manufacturers, if amended standards cause prices to rise even higher, the lower 

operating costs do not justify higher prices, since the savings as a percentage of the 

purchase price are very low. Therefore, the increased cost of meeting efficiency 

requirements may cause manufacturers to reduce the amount of other features bundled 

with these products in order to retain a reasonable price point, causing consumer utility to 

decline.

The value of future ENERGY STAR levels is also a concern for manufacturers. 

Many retailers and other distribution channels require ENERGY STAR products. Since 

the features bundled with ENERGY STAR are the biggest justification of the added 

costs, manufacturers were concerned that a higher ENERGY STAR level after standards 

would offer less value to consumers. Consumers would save less energy relative to the 

added efficiency costs or would have a product with fewer features.

Manufacturers also stated that the financial burden of developing products to meet 

amended energy conservation standards has an opportunity cost due to limited capital and 

R&D dollars. Investments incurred to meet amended standards reflect foregone 

investments in innovation and the development of new features that consumers value and 

on which manufacturers earn a premium.

12.3.5 Technical Difficulty to Achieve New Standards

Many manufacturers expressed concerns about the technical difficulty to achieve 

new standards that are significantly more stringent than current levels. Supply of 

particular components, notably high efficiency compressors and VIPs, were a concern for 

all product classes, especially at higher efficiency levels that would increase the demand 

for these components many times over current levels. They also stated that there are 

fewer low-cost technology improvements available than there were during past 

rulemakings. Compact units, in general, pose an additional challenge because there are 

fewer low-capacity compressors with sufficiently high EER ratings. Specifically, 

compact freezers were cited as a product class in which it will be especially difficult to 

make significant energy improvements. The standards for compact freezers are already 

more stringent relative to capacity than are standards for compact refrigerators. 

12.3.6 Changes in Consumer Behavior

Several manufacturers noted that higher prices to consumers resulting from 

amended energy conservation standards could result in product switching between lines 

of standard-size refrigerator-freezers. Currently, top-mounted refrigerator-freezers are 
12-10

inexpensive commodity products, on which manufacturers said they make little to no 

profit margin. Instead, manufacturers earn a profit on more expensive and more featureloaded side-mounted and bottom-mounted refrigerator-freezers. Manufacturers are 

concerned that if amended energy conservation standards cause retail prices to increase 

across product classes, many consumers will no longer be willing to pay the premium for 

side-mounted and bottom-mounted refrigerator-freezers and will switch to buying the less 

expensive and less profitable top-mounted refrigerator-freezers.

Similarly, a number of manufacturers expressed concern that higher retail prices 

could alter consumers’ decisions to repair or replace their standard-size refrigeratorfreezers. Many consumers who in the base case would buy a new refrigerator when their 

current unit fails would instead opt to repair their existing units in the standards case due 

to the higher cost of purchasing a new unit. This decision would result in lower shipments 

for manufacturers and would leave less efficient units in the existing stock.

12.3.7 Separate Product Classes for Built-In Products

Most manufacturers expressed their support for separate product classes for builtin refrigerators and freezers. Manufacturers stated that built-in units are inherently less 

efficient than their free-standing counterparts for several reasons, including more limited 

air flow. Because of the limitations, the incremental costs of improving efficiency are 

higher at every efficiency level. Built-in manufacturers also believed that their 

components costs per unit were higher than for conventional products due to less bulk 

purchasing power. Built-in manufacturers also argued that their products offer distinct 

utility, justifying the need for separate product classes for built-ins. Without separate 

product classes for built-ins, depending on the stringency of new standards, some or all 

built-in models could be obsolesced. Built-in manufacturers also suggested that an 

average correction off of conventional products could be an appropriate means of 

accounting for the inherently lower efficiency of built-in products.

12.3.8 Test Procedure Concerns

Many manufacturers expressed concerns over the test procedures for refrigerators 

and freezers. Several stated that icemaking energy use, which represents a large portion 

of unit energy consumption, should be included in the amended test procedure to reward 

more efficient icemakers. However, manufacturers acknowledged that testing icemaker 

energy use is difficult. All manufacturers want to ensure that tests for icemaking energy 

are repeatable and implemented correctly. Manufacturers also do not want a test for 

icemaking energy use to result in the elimination of TTD units.

12.4 GRIM INPUTS AND ASSUMPTIONS

The GRIM serves as the main tool for assessing the impacts on industry due to 

amended energy conservation standards. DOE relies on several sources to obtain inputs 

for the GRIM. Data and assumptions from these sources are then fed into an accounting 

model that calculates the industry cash flow both with and without amended energy 

conservation standards.
12-11

12.4.1 Overview of the GRIM

The basic structure of the GRIM, illustrated in Figure 12.4.1 , is an annual cash 

flow analysis that uses manufacturer prices, manufacturing costs, shipments, and industry 

financial information as inputs, and accepts a set of regulatory conditions such as changes 

in costs, investments, and associated margins. The GRIM spreadsheet uses a number of 

inputs to arrive at a series of annual cash flows, beginning with the base year of the 

analysis, 2010, and continuing to 2043. The model calculates the INPV by summing the 

stream of annual discounted cash flows during this period and adding a discounted 

terminal value.

8

Figure 12.4.1 Using the GRIM to Calculate Cash Flow

The GRIM projects cash flows using standard accounting principles and compares 

changes in INPV between the base case and the standard-case scenario induced by 

amended energy conservation standards. The difference in INPV between the base case 

and the standard case(s) represents the estimated financial impact of the amended energy 

conservation standard on manufacturers. Appendix 12-B provides more technical details 

and user information for the GRIM.

12.4.2 Sources for GRIM Inputs

The GRIM uses several different sources for data inputs in determining industry 

cash flow. These sources include corporate annual reports, company profiles, Census 

data, credit ratings, the shipments model, the engineering analysis, and the manufacturer 

interviews.

12.4.2.1 Corporate Annual Reports

Corporate annual reports to the SEC (SEC 10-Ks) provided many of the initial 

financial inputs to the GRIM. These reports exist for publicly held companies and are 

freely available to the general public. DOE developed initial financial inputs to the GRIM 

by examining the annual SEC 10-K reports filed by publicly-traded manufacturers that 

manufacture residential refrigeration products and whose combined product range 

includes standard-size refrigerator-freezers, standard-size freezers, compact refrigeration 
12-12

products, and built-in refrigeration products. Since these companies do not provide 

detailed information about their individual product lines, DOE used the financial 

information for the entire companies as its initial estimates of the financial parameters in 

the GRIM analysis. These primary figures were derived using the same information used 

to develop the financial parameters for commercial clothes washers and cooking 

products, since no other publicly available SEC 10-K reports for refrigeration product 

manufacturers were available. These figures were later revised using feedback from 

interviews to be representative of manufacturing for each product grouping. DOE used 

corporate annual reports to derive the following initial inputs to the GRIM: 

• Tax rate

• Working capital

• SG&A

• R&D

• Depreciation

• Capital expenditures

• Net PPE

12.4.2.2 Standard and Poor Credit Ratings

S&P provides independent credit ratings, research, and financial information. 

DOE relied on S&P reports to determine the industry’s average cost of debt when 

calculating the cost of capital.

12.4.2.3 Shipment Model

The GRIM used shipment projections derived from DOE’s shipments model in 

the national impact analysis (NIA). The model relied on historical shipments data for 

standard-size refrigerator-freezers, standard-size freezers, and compact refrigeration 

products. Chapter 9 of the TSD describes the methodology and analytical model DOE 

used to forecast shipments.

12.4.2.4 Engineering Analysis 

The engineering analysis establishes the relationship between manufacturer 

production cost and energy consumption for the products covered in this rulemaking. 

DOE has adopted a combined efficiency level/design option/reverse engineering 

approach to developing cost-efficiency curves. DOE established efficiency levels defined 

as percentage energy use lower than that of baseline efficiency products. To develop the 

analytically-derived cost-efficiency curves, DOE collected information from various 

sources on the manufacturing cost and energy use reduction characteristics of each of the 

design options. Energy use reduction was modeled with a modified version of the 

established EPA Refrigerator Analysis (ERA) program which was used in the previous 

refrigerator rulemaking. DOE used the reverse engineering information in combination 

with the incremental costs for each design option to derive the labor, materials, overhead, 

and total production costs for products at each efficiency level. The engineering analysis 

also estimated a manufacturer markup to provide the manufacturer selling price (MSP) 
12-13

for each product at every efficiency level. See chapter 5 for a complete discussion of the 

engineering analysis. 

12.4.2.5 Manufacturer Interviews

During the course of the MIA, DOE conducted interviews with a representative 

cross-section of manufacturers. DOE also interviewed manufacturers representing a 

significant portion of sales in every product class. During these discussions, DOE 

obtained information to determine and verify GRIM input assumptions in each industry. 

Key topics discussed during the interviews and reflected in the GRIM include:

• capital conversion costs (one-time investments in PPE);

• product conversion costs (one-time investments in research, product 

development, testing, and marketing);

• product cost structure, or the portion of the MPCs related to materials, 

labor, overhead, and depreciation costs;

• possible profitability impacts; and

• cost-efficiency curves calculated in the engineering analysis.

12.4.3 Financial Parameters

In the manufacturer interviews, DOE used the financial parameters from the April 

2009 cooking products final rule and the January 2010 commercial clothes washers final 

ruleb

Table 

12.4.1

as a starting point for determining the residential refrigeration industry financial 

parameters. These initial estimates were used because the same white goods 

manufacturers produce both clothes washers, cooking products, and refrigeration 

products and no other publicly available SEC 10-K reports for refrigeration product 

manufacturers were available. These financial parameters were determined by averaging 

the values in the annual reports of three publicly traded companies engaged in 

manufacturing and selling clothes washers over an 8-year period (1999-2006). 

below shows the data used to determine the initial financial parameter estimates.

b The final rule for commercial clothes washers was published in the Federal Register on January 8, 2010 

(75 FR1122). The final rule for cooking products was published in the Federal Register on April 8, 2009 

(74 FR 16040). More information on these rulemakings can be found at 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/clothes_washers.html and 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/cooking_products.html. 
12-14

Table 12.4.1 GRIM Financial Parameters Based on 1999–2006 Weighted Company 

Financial Data

Parameter

IndustryWeighted 

Average

Manufacturer

A B C

Tax Rate (% of Taxable Income) 33.9 6.6 34.1 34.5

Working Capital (% of Revenue) 2.9 9.6 5.6 2.0

SG&A (% of Revenue) 12.5 12.7 12.3 13.2

R&D (% of Revenues) 2.2 2.3 2.0 2.4

Depreciation (% of Revenues) 3.4 3.9 3.4 3.3

Capital Expenditures (% of Revenues) 3.5 1.9 3.4 3.6

Net Property, Plant, and Equipment 

(% of Revenues) 19.9 17.3 21.6 19.4

During interviews, residential refrigeration manufacturers were asked to provide 

their own figures for the parameters listed in Table 12.4.1. Where applicable, DOE 

adjusted the parameters in the GRIM using this feedback and data from publicly traded 

companies to reflect manufacturing residential refrigeration products. Table 12.4.2

presents the revised residential refrigeration parameters for freestanding refrigeration 

product manufacturers. Many freestanding residential refrigeration product manufacturers 

sell standard-size refrigerator-freezers, standard-size freezers, and compact refrigeration 

products. DOE used one set of financial parameters to characterize all three of these 

product groupings.

Table 12.4.2 GRIM Freestanding Residential Refrigeration Industry Financial 

Parameters

Parameter

Revised Estimate 

(excluding Built-In

Product Classes)

Tax Rate % of taxable income 33.9

Working Capital % of revenues 2.9

SG&A % of revenues 12.5

R&D % of revenues 2.2

Depreciation % of revenues 3.3

Capital Expenditures % of revenues 3.6

Net PPE % of revenues 19.9

For built-in refrigeration product manufacturers, DOE developed separate 

estimates for financial parameters. The built-in refrigeration product market is served by 

a different set of manufacturers. Even where manufacturers produce both freestanding 

and built-in products, the manufacturing process is sufficiently different to warrant a 

varying cost structure from larger freestanding residential refrigeration product 

manufacturers. As such, DOE revised its estimates to utilize different financial 

parameters to analyze the impacts of amended energy conservation standards on built-in 

refrigeration products in the GRIM. These estimates were revised based on feedback 

from built-in refrigeration manufacturers during manufacturer interviews and are shown 

in Table 12.4.3 below.
12-15

Table 12.4.3 GRIM Built-In Refrigeration Industry Financial Parameters

Parameter

Revised Estimate for

Built-In

Refrigeration 

Products

Tax Rate % of taxable income 33.9

Working Capital % of revenues 2.9

SG&A % of revenues 19.0

R&D % of revenues 3.5

Depreciation % of revenues 4.5

Capital Expenditures % of revenues 4.7

Net PPE % of revenues 23.0

12.4.4 Corporate Discount Rate

DOE used the weighted-average cost of capital (WACC) as the discount rate to 

calculate the INPV. A company’s assets are financed by a combination of debt and 

equity. The WACC is the total cost of debt and equity weighted by their respective 

proportions in the capital structure of the industry. DOE estimated the WACC for the 

residential refrigeration industry based on several representative companies, using the 

following formula:

WACC = After-Tax Cost of Debt x (Debt Ratio) + Cost of Equity x (Equity 

Ratio) Eq. 1

The cost of equity is the rate of return that equity investors (including, potentially, 

the company) expect to earn on a company’s stock. These expectations are reflected in 

the market price of the company’s stock. The capital asset pricing model (CAPM) 

provides one widely used means to estimate the cost of equity. According to the CAPM, 

the cost of equity (expected return) is:

Cost of Equity = Riskless Rate of Return + β x Risk Premium Eq. 2

where:

Riskless rate of return is the rate of return on a “safe” benchmark investment, 

typically considered the short-term Treasury Bill (T-Bill) yield.

Risk premium is the difference between the expected return on stocks and the 

riskless rate.

Beta (β) is the correlation between the movement in the price of the stock and that 

of the broader market. In this case, Beta equals one if the stock is perfectly correlated 

with the S&P 500 market index. A Beta lower than one means the stock is less volatile 

than the market index.

DOE determined that the industry average cost of equity for the residential 

refrigeration industry is 17.9 percent (Table 12.4.4). The representative data was taken 
12-16

from the commercial clothes washers final rule since several of the representative 

manufacturers are the same as in the residential refrigeration industry.

Table 12.4.4 Cost of Equity Calculation

Parameter

IndustryWeighted 

Average 

%

Manufacturer

A B C

(1) Average Beta

(2002-2006 year) 1.31 1.0* 1.77 1.17

(2) Yield on 10-Year 

T-Bill (1990-2006) 5.9 - - -

(3) Market Risk Premium 

(1926-1999) 9.2 - - -

Cost of Equity (2)+[(1)*(3)] 17.9 - - -

Equity/Total Capital 37.2 23.7 -49.8 64.6

* Estimated Beta

Bond ratings are a tool to measure default risk and arrive at a cost of debt. Each 

bond rating is associated with a particular spread. One way of estimating a company’s 

cost of debt is to treat it as a spread (usually expressed in basis points) over the risk-free 

rate. DOE used this method to calculate the cost of debt for all three manufacturers by 

using S&P ratings and adding the relevant spread to the risk-free rate. 

In practice, investors use a variety of different maturity Treasury bonds to 

estimate the risk-free rate. DOE used the 10-year Treasury bond return because it 

captures long-term inflation expectations and is less volatile than short-term rates. The 

risk free rate is estimated to be approximately 6 percent, which is the average 10-year 

Treasury bond return between 1990 and 2006 (the analysis period used in the initial 

estimate for commercial clothes washers).

For the cost of debt, S&P’s Credit Services provided the average spread of 

corporate bonds for the three public manufacturers between 2002 and 2006. As stated 

above, the representative data was taken from the commercial clothes washers final rule 

since several of the representative manufacturers are the same as in the residential 

refrigeration industry. DOE added the industry-weighted average spread to the average TBill yield over the same period. Since proceeds from debt issuance are tax deductible, 

DOE adjusted the gross cost of debt by the industry average tax rate to determine the net 

cost of debt for the industry. Table 12.4.5 presents the derivation of the cost of debt and 

the capital structure of the industry (i.e. the debt ratio (debt/total capital)).
12-17

Table 12.4.5 Cost of Debt Calculation

Parameter

IndustryWeighted 

Average 

%

Manufacturer

A B C

S&P Bond Rating -- B- BBB BBB

(1) Yield on 10-Year 

T-Bill (1990-2006) 5.9 - - -

(2) Gross Cost of Debt 8.2 13.9 8.1 8.1

(3) Tax Rate 34 6.6 34.1 34.5

Net Cost of Debt 

(2) x ((1)-(3)) 5.4 - - -

Debt/Total Capital 62.8 76.3 149.8 35.4

Using public information for these three companies from the commercial clothes 

washers final rule, the initial estimate for the residential refrigeration industry’s WACC 

was approximately 10.1 percent. Subtracting an inflation rate of 2.9 percent over the 

analysis period used in the initial estimate, the inflation-adjusted WACC and the initial 

estimate of the discount rate used in the straw-man GRIM is 7.2 percent. DOE also asked 

for feedback on the 7.2 percent discount during manufacturer interviews and used this 

feedback to determine that 7.2 percent was an appropriate discount rate for use in the 

GRIM.

12.4.5 Trial Standard Levels 

DOE developed TSLs for standard-size refrigerator-freezers, standard-size 

freezers, compact refrigeration products, and built-in refrigeration products. Consistent 

with the engineering analysis, DOE analyzed representative product classes for each 

product grouping. For freestanding products, DOE analyzed seven product classes that 

comprise approximately 90 percent of all shipments. DOE also analyzed four built-in 

product classes. Table 12.4.6 through Table 12.4.9 show the TSLs for the product 

groupings analyzed by DOE. For each representative product class, DOE considered 

percentage decreases from the baseline energy usage according to the proposed test 

procedure, up to max-tech efficiency levels. DOE extrapolates the amended energy 

standards to the remaining product classes as described in section 2.15 of chapter 2 of the 

TSD. Table 12.4.6 through Table 12.4.9 also show which unanalyzed product classes are 

grouped with each analyzed product. Chapter 2 explains this process in greater detail. 

Table 12.4.6 through Table 12.4.9 present the efficiency level at each TSL used in 

the GRIM. Table 12.4.6 presents the TSLs and the corresponding product class 

efficiencies for standard-size refrigerator-freezers. TSL 1 consists of those efficiency 

levels that meet current ENERGY STAR criteria. TSL 2 consists of the highest efficiency 

levels for which the consumer NPV is positive, using a 7-percent discount rate. TSL 3 

consists of the highest efficiency levels for which the consumer NPV is positive, using a 
12-18

3-percent discount rate, as well as the levels recommended in the Joint Commentsc

. TSL 

4 consists of those efficiency levels that yield energy use 30 percent below the baseline 

products. TSL 5 consists of the max-tech efficiency levels.

Table 12.4.6 Trial Standard Levels for Standard-Size Refrigerator-Freezers

Trial 

Standard

Level

Representative Product Class

3

(automatic defrost with topmounted freezer without 

through-the-door ice service)

5

(automatic defrost with 

bottom-mounted freezer 

without through-the-door ice 

service)

7 

(automatic defrost with sidemounted freezer with 

through-the-door ice service)

Scaled Product Classes

1, 1A, 2, 3A, 3I and 6 5A and 5I 4 and 4I

Efficiency Level (% less than baseline energy use)

1 3 (20) 3 (20) 3 (20)

2 3(20) 3 (20) 4 (25)

3 4 (25)* 3 (20) 4 (25)

4 5 (30) 5 (30) 5 (30)

5 6 (36) 6 (36) 6 (33)

* Efficiency level for product classes 1, 1A, and 2 is 20%.

Table 12.4.7 presents the TSLs and the corresponding efficiencies for standardsize freezers. TSL 1 consists of those efficiency levels that yield energy use 20 percent 

below the baseline products. TSL 2 consists of the levels recommended in the Joint 

Comments. TSL 3 consists of incrementally higher efficiency levels than the preceding 

TSL. TSL 4 consists of the efficiency levels for which the consumer NPV is positive, 

using a 7-percent discount rate. TSL 5 consists of the max-tech efficiency levels, which 

are also the efficiency levels for which the consumer NPV is positive, using a 3-percent 

discount rate.

c The Joint Comments were submitted by a group of interested parties representing a number of different 

interests and throughout DOE’s standards rulemaking process. The Joint Comments included 

recommended levels for the product classes covered by this rulemaking. The Joint Comments is Comment 

49 submitted to DOE Docket No. EERE-2008-BT-STD-0012. DOE considered the Joint Comments to 

supersede earlier comments by the listed parties regarding issues subsequently discussed in the Joint 

Comments.
12-19

Table 12.4.7 Trial Standard Levels for Standard-Size Freezers

Trial Standard

Level

Representative Product Class

9

(upright freezers with 

automatic defrost)

10

(chest freezers and all 

other freezers except 

compact freezers)

Scaled Product Classes

- 8, 10A

Efficiency Level (% less than baseline energy 

use)

1 3 (20) 3 (20)

2 5 (30) 4 (25)*

3 6 (35) 5 (30)

4 7 (40) 6 (35)

5 8 (44) 7 (41)

* Efficiency level for product class 10A is 30%.

Table 12.4.8 presents the TSLs and the corresponding product class efficiencies 

for compact refrigeration products. TSL 1 consists of efficiency levels that meet current 

ENERGY STAR criteria for compact refrigerators, and efficiency levels that are 10 

percent below the baseline energy use for compact freezers. TSL 2 consists of the levels 

recommended in the Joint Comments. TSL 3 consists of the highest efficiency levels for 

which the consumer NPV is positive, using both a 3-percent and a 7-percent discount 

rate. TSL 4 consists of incrementally higher efficiency levels than TSL 3. TSL 5 consists 

of the max-tech efficiency levels.
12-20

Table 12.4.8 Trial Standard Levels for Compact Refrigeration Products

Trial Standard

Level

Representative Product Class

11 

(compact refrigerators and 

refrigerator-freezers with 

manual defrost)

18

(compact chest freezers)

Scaled Product Classes

11A, 12 13, 13A, 14, 15 16, 17

Efficiency Level (% less than baseline energy 

use)

1 3 (20) 1 (10)

2 4 (25) 1 (10)*

3 5 (30) 2 (15)

4 7 (40) 4 (25)

5 10 (59) 7 (42)

* Efficiency level for product class 13 and 15 is 15%, efficiency level for product class 14 is 20%, and 

efficiency level for product class 13A is 25%. 

Table 12.4.9 presents the TSLs and the corresponding product class efficiencies 

for built-in refrigeration products. TSL 1 consists of the efficiency levels that are 10 

percent better than the current standard. TSL 2 consists of the highest efficiency levels 

for which the consumer NPV is positive, using both a 3-percent and a 7-percent discount 

rate. TSL 3 consists of the levels recommended in the Joint Comments. TSL 4 consists of 

incrementally higher efficiency levels than TSL 3. TSL 5 consists of the max-tech 

efficiency levels.
12-21

Table 12.4.9 Trial Standard Levels for Built-in Refrigeration Products

Trial Standard

Level

Representative Product Class

3A-BI 

(built-in allrefrigerators—

automatic defrost)

5-BI 

(built-in 

refrigeratorfreezers—

automatic defrost 

with bottommounted freezer 

without an 

automatic 

icemaker)

7-BI

(built-in refrigeratorfreezers—automatic 

defrost with sidemounted freezer with 

through-the-door ice 

service)

9-BI

(built-in upright 

freezers with 

automatic defrost 

without an 

automatic 

icemaker)

Scaled Product Classes

3-BI 5I-BI 4-BI and 4I-BI

Efficiency Level (% less than baseline energy use)

1 1 (10) 1 (10) 1 (10) 1 (10)

2 2 (15) 2 (15) 1 (10) 3 (20)

3 3 (20) 2 (15) 3 (20) 4 (25)

4 4 (25) 4 (25) 3 (20) 4 (25)

5 5 (29) 5 (27) 4 (22) 5 (27)

12.4.6 NIA Shipment Forecast

The GRIM estimates manufacturer revenues based on total-unit-shipment 

forecasts and the distribution of these values by efficiency level. Changes in the 

efficiency mix at each standard level are a key driver of manufacturer finances. For this 

analysis, the GRIM used the NIA shipments forecasts. However, only the shipments in 

2010 and beyond have an impact on INPV because 2010 is the base year to which future 

cash flows are summed. Chapter 9 of the TSD explains DOE’s calculations of total 

shipments in detail. Table 12.4.10 shows total shipments forecasted in the shipment 

analysis for standard-size refrigerator-freezers, standard-size freezers, compact 

refrigeration products, and built-in refrigeration products in 2014. In order to aggregate 

shipments in the GRIM, DOE assigned each of the product classes to one of the 11 

representative product classes shown in Table 12.4.6 to Table 12.4.9. DOE aggregated 

the shipments for all the scaled product classes under the corresponding representative 

product class and used the cost curve for the representative product class with which it is 

associated.
12-22

Table 12.4.10 Total Base Case NIA Shipments Forecast in 2014d

Analyzed 

Product Class

 in the Main NIA 

Shipment Scenario

Product Class Description Total Industry 

Shipments 

(thousands)

3 Automatic defrost with top-mounted freezer without through-thedoor ice service 7,081

5 Automatic defrost with bottom-mounted freezer without through-thedoor ice service 1,950

7 Automatic defrost with side-mounted freezer with through-the-door 

ice service 2.966

9 Upright freezers with automatic defrost 1,171

10 Chest freezers and all other freezers except compact freezers 1,228

11 Compact refrigerators and refrigerator-freezers with manual defrost 2,547

18 Compact chest freezers 879

3A-BI Built-in all-refrigerators—automatic defrost 28

5-BI Built-in refrigerator-freezers—automatic defrost with bottommounted freezer without an automatic icemaker 102

7-BI Built-in refrigerator-freezers—automatic defrost with side-mounted 

freezer with through-the-door ice service 169

9-BI Built-in upright freezers with automatic defrost without an automatic 

icemaker 26

12.4.6.1 Shipments Forecast

As part of the shipments analysis, DOE estimated the base-case shipment 

distribution by efficiency level for standard-size refrigerator-freezers, standard-size 

freezers, compact refrigeration products, and built-in refrigeration products. In the 

standards case, DOE determined efficiency distributions for cases in which a potential 

standard applies for 2014 and beyond. DOE assumed that product efficiencies in the base 

case that did not meet the standard under consideration would roll up to meet the new 

standard in 2014. DOE further assumed that the ENERGY STAR program will continue 

to promote high-efficiency appliances after revised standards are introduced in 2014, and 

that product market shares above a given standard level may shift. DOE describes how it 

calculated the ENERGY STAR and standards-case distribution in chapter 10. The 

efficiency distributions used in the base and standards case are shown in Table 12.4.11

through Table 12.4.20 below.

d The compliance date for the residential refrigeration energy conservation standard is estimated to be 

January 2014.
12-23

Table 12.4.11 Standard-Size Refrigerator-Freezers: Base-Case Efficiency 

Distributions

Efficiency 

Level

(% less 

than

baseline 

energy 

use)

Product Class 3:

Top-Mount 

Refrigerator-Freezer

Product Class 5:

Bottom-Mount 

Refrigerator-Freezer

Product Class 7:

Side-by-Side RefrigeratorFreezer with TTD*

Market Share

%

Market Share

%

Market Share

%

2007 2014 2021 2007 2014 2021 2007 2014 2021

Baseline 80.6 78.2 80.6 11.8 13.0 11.8 25.0 21.7 21.7

1 (10) 5.9 4.2 5.9 0.1 0.1 0.1 43.0 26.4 26.4

2 (15) 13.2 9.4 0.1 69.8 19.3 0.0 30.3 15.0 15.0

3 (20) 0.2† 8.3† 13.4† 18.3† 67.7† 88.1† 1.7† 37.0† 37.0†

4 (25) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

5 (30) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

6 (MaxTech) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

* Through-the-door ice service.

† Meets current (2008) ENERGY STAR criteria.

Table 12.4.12 Top-Mount Refrigerator-Freezers: Efficiency Distributions in 2014 by 

Efficiency Level

Efficiency 

Level 

(% less 

than 

baseline 

energy use)

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6

Baseline 78.2 - - - - - -

1 (10) 4.2 82.3 - - - - -

2 (15) 9.4 9.4 91.7 - - - -

3 (20) 8.3 8.3 8.3 100.0 - - -

4 (25) 0.0 0.0 0.0 0.0 100.0 - -

5 (30) 0.0 0.0 0.0 0.0 0.0 100.0 -

6 (36) 0.0 0.0 0.0 0.0 0.0 0.0 100.0
12-24

Table 12.4.13 Bottom-Mount Refrigerator-Freezers: Efficiency Distributions in 

2014 by Efficiency Level

Efficiency 

Level 

(% less than 

baseline 

energy use)

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6

Baseline 13.0 - - - - - -

1 (10) 0.1 13.1 - - - - -

2 (15) 19.3 19.3 32.4 - - - -

3 (20) 67.7 67.7 67.7 100.0 - - -

4 (25) 0.0 0.0 0.0 0.0 100.0 - -

5 (30) 0.0 0.0 0.0 0.0 0.0 100.0 -

6 (36) 0.0 0.0 0.0 0.0 0.0 0.0 100.0

Table 12.4.14 Side-by Side Refrigerator-Freezers: Efficiency Distributions in 2014 

by Efficiency Level

Efficiency 

Level 

(% less 

than 

baseline 

energy use)

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6

Baseline 21.7 - - - - - -

1 (10) 26.4 48.1 - - - - -

2 (15) 15.0 15.0 63.1 - - - -

3 (20) 37.0 37.0 37.0 100.0 - - -

4 (25) 0.0 0.0 0.0 0.0 100.0 - -

5 (30) 0.0 0.0 0.0 0.0 0.0 100.0 -

6 (33) 0.0 0.0 0.0 0.0 0.0 0.0 100.0
12-25

Table 12.4.15 Standard-Size Freezers: Base-Case Efficiency Distributions

Efficiency 

Level

(% less 

than 

baseline 

energy 

use)

Product Class 9:

Upright Freezer

Product Class 10:

Chest Freezer

Market Share

%

Market Share

%

2007 2014 2021 2007 2014 2021

Baseline 81.5 81.5 81.5 84.6 84.6 84.6

1 (10) 17.0* 17.0 8.5 14.3* 14.3 7.2

2 (15) 1.0 1.0 0.5 0.8 0.8 0.4

3 (20) 0.1 0.1† 9.1† 0.0 0.0† 7.6†

4 (25) 0.2 0.2 0.2 0.0 0.0 0.0

5 (30) 0.2 0.2 0.2 0.0 0.0 0.0

6 (35) 0.0 0.0 0.0 0.4 0.4 0.4

7 (40;41) 0.0 0.0 0.0 0.0 0.0 0.0

8 (44) 0.0 0.0 0.0 - - -

* Meets current ENERGY STAR criteria.

† Meets projected new ENERGY STAR criteria.

Table 12.4.16 Upright Freezers: Efficiency Distributions in 2014 by Efficiency Level

Efficiency 

Level

(% less 

than 

baseline 

energy use)

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6 7 8

Baseline 81.5 - - - - - - - -

1 (10) 17.0 98.5 - - - - - - -

2 (15) 1.0 1.0 99.5 - - - - - -

3 (20) 0.1 0.1 0.1 99.6 - - - - -

4 (25) 0.2 0.2 0.2 0.2 99.8 - - - -

5 (30) 0.2 0.2 0.2 0.2 0.2 100.0 - - -

6 (35) 0.0 0.0 0.0 0.0 0.0 0.0 100.0 - -

7 (40) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 -

8 (44) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0
12-26

Table 12.4.17 Chest Freezers: Efficiency Distributions in 2014 by Efficiency Level

Efficiency 

Level

(% less 

than 

baseline 

energy use)

Market Share %

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6 7

Baseline 84.6

1 (10) 14.3 98.9

2 (15) 0.8 0.8 99.7

3 (20) 0.0 0.0 0.0 99.7

4 (25) 0.0 0.0 0.0 0.0 99.7

5 (30) 0.0 0.0 0.0 0.0 0.0 99.7

6 (35) 0.4 0.4 0.4 0.4 0.4 0.4 100.0

7 (41) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0

Table 12.4.18 Compact Refrigeration Products: Base-Case Efficiency Distributions

Efficiency 

Level

(% less 

than 

baseline 

energy 

use)

Product Class 11: 

Compact Refrigerator

Product Class 18:

Compact Freezer

Market Share

%

Market Share

%

2007 2014 2021 2007 2014 2021

Baseline 97.1 98.5 98.5 95.4 95.4 95.4

1 (10) 0.3 0.3 0.3 4.6 4.6 4.6

2 (15) 0.0 0.0 0.0 0.0 0.0 0.0

3 (20) 0.9* 0.5 0.2 0.0* 0.0* 0.0*

4 (25) 0.2 0.1 0.1 0.0 0.0 0.0

5 (30) 1.5 0.8 † 1.0 † 0.0 0.0 0.0

6 (35) 0.0 0.0 0.0 0.0 0.0 0.0

7 (40;42) 0.0 0.0 0.0 0.0 0.0 0.0

8 (45) 0.0 0.0 0.0 - - -

9 (50) 0.0 0.0 0.0 - - -

10 (59) 0.0 0.0 0.0 - - -

* Meets current ENERGY STAR criteria.

† Meets projected new ENERGY STAR criteria.
12-27

Table 12.4.19 Compact Refrigerators: Efficiency Distributions in 2014 by Efficiency 

Level

Efficiency Level

(% less than 

baseline energy 

use)

Market Share (%)

Base Case

Standard at Efficiency Level:

1 2 3 4 5 6 7 8 9 10

Baseline 98.5 - - - - - - - - - -

1 (10) 0.3 98.7 - - - - - - - - -

2 (15) 0.0 0.0 98.7 - - - - - - - -

3 (20) 0.5 0.5 0.5 99.2 - - - - - - -

4 (25) 0.1 0.1 0.1 0.1 99.3 - - - - - -

5 (30) 0.8 0.8 0.8 0.8 0.8 100.0 - - - - -

6 (35) 0.0 0.0 0.0 0.0 0.0 0.0 100.0 - - - -

7 (40) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 - - -

8 (45) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0

9 (50) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 -

10 (59) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0

Table 12.4.20 Compact Freezers: Efficiency Distributions in 2014 by Efficiency 

Level

Efficiency 

Level

(% less than 

baseline 

energy use)

Market Share (%)

Base 

Case

Standard at Efficiency Level:

1 2 3 4 5 6 7

Baseline 95.4 - - - - - - -

1 (10) 4.6 100.0 - - - - - -

2 (15) 0.0 0.0 100.0 - - - - -

3 (20) 0.0 0.0 0.0 100.0 - - - -

4 (25) 0.0 0.0 0.0 0.0 100.0 - - -

5 (30) 0.0 0.0 0.0 0.0 0.0 100.0 - -

6 (35) 0.0 0.0 0.0 0.0 0.0 0.0 100.0 -

7 (42) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0

12.4.6.2 Default Standards-Case NIA Scenario 

DOE used the default NIA scenario to calculate the INPV results presented in this 

chapter. The default NIA scenario used selected inputs from the Reference case in EIA’s 

Annual Energy Outlook 2010.

9 The default NIA scenario also accounts for a relative 

price elasticity of -0.34. For example, a relative price increase of 10 percent results in a 

3.4 percent decrease in shipments. In the GRIM, the user can also calculate INPV 

impacts without incorporating the elasticity effect. See chapter 9 for a description of the 

relative price elasticity.
12-28

12.4.7 Production Costs

Manufacturing a higher-efficiency product is typically more costly than 

manufacturing a baseline product due to the use of more complex components and 

higher-cost raw materials. The changes in the MPCs of the analyzed products can affect 

revenues, gross margins, and cash flow of the industry, making these data a key GRIM 

input for DOE’s analysis.

For the MIA, DOE used the cost efficiency curves derived in the engineering 

analysis (detailed in chapter 5 and appendix 5-A of the TSD) using appropriate 

production volume estimates. For instance, more efficient products sold under existing 

energy conservation standards are manufactured at lower production volumes than 

baseline efficiency products. Enacting more stringent energy conservation standards will 

increase production volumes for more efficient units. Because DOE developed two cost 

efficiency curves for most product classes based on a smaller-sized unit and a largersized unit, the cost estimates in these two curves were averaged for each product class to 

obtain a representative MPC. 

To calculate baseline MPCs, DOE followed a three step process. First, DOE 

derived each of the baseline products’ retail prices from NPD market data (described in 

chapter 8 of the TSD). Next, DOE discounted these baseline retail prices by the sales tax 

and retail markup to arrive at the baseline MSPs. Next, DOE discounted the baseline 

MSPs by the manufacturer markup to arrive at the average baseline MPCs. For all nonbuilt-in product classes, DOE used a 1.26 manufacturer markup to calculate baseline 

MPCs and MSPs. Because built-in product classes are high-end products that are made in 

much lower production volumes, DOE used a different cost structure for these products 

than for the other product classes. DOE used information submitted during manufacturer 

interviews to estimate that a typical baseline manufacturer markup for built-in products is 

1.40. To calculate baseline MPCs for the built-in product classes, DOE discounted the 

NPD baseline retail prices by the 1.40 manufacturer markup and also a distributor 

markup to account for products sold through that distribution chain. 

DOE also used the information from its tear-down analysis to verify the accuracy 

of the markup information and cost data for the units it tore down. In addition, DOE used 

the tear-down cost data to disaggregate the MPCs into material, labor, and overhead 

costs. DOE developed different depreciation values for freestanding products and built-in 

refrigeration products by using a depreciation value that is consistent with historical 

information in SEC 10-Ks. The remainder of total overhead was allocated to factory 

overhead. To calculate the incremental MPCs for products above the baseline, DOE 

added the incremental material, labor, and overhead costs from the engineering cost 

efficiency curves to the baseline MPCs. Because DOE did not tear down built-in 

refrigeration products, DOE based its material, labor, and overhead estimates on the most 

similar freestanding product classes. DOE also assumed that the labor content was twice 

as great for built-in refrigeration products compared to the most similar freestanding 

product classes. 
12-29

As stated in section 12.4.6, DOE allocated shipments for the unanalyzed product 

classes to the product class for which the amended energy conservation standard is 

scaled. That way, the total revenue and INPV impacts for each representative product 

class is also representative of the INPV impacts on the unanalyzed product classes used 

to promulgate the amended energy conversation standards.

Table 12.4.21 through Table 12.4.31 show the production cost estimates used in 

the GRIM for each analyzed product class.

Table 12.4.21 MPC Breakdown for Refrigerator-Freezers for Product Class 3

(Automatic Defrost with Top-Mounted Freezer without Through-the-Door Ice 

Service)

TSL

(Efficiency 

Level)

Efficiency 

Level

(% less 

than 

baseline 

energy 

use)

Labor

$

Material

$

Overhead

$

Depreciation

$

MPC

$

Manufacturer 

Markup

MSP

$

Baseline Baseline 47.92 181.04 32.06 11.32 272.34 1.26 343.15 

TSL 1 EL 3 (20) 47.92 239.08 29.64 13.74 330.38 1.26 416.28 

TSL 2 EL 3 (20) 47.92 239.08 29.64 13.74 330.38 1.26 416.28 

TSL 3 EL 4 (25)* 50.00 261.09 31.11 14.85 357.05 1.26 449.88 

TSL 4 EL 5 (30) 53.24 310.65 34.39 17.28 415.56 1.26 523.61 

TSL 5 EL 6 (36) 55.28 387.29 36.14 20.77 499.48 1.26 629.34 

*Efficiency level for product classes 1, 1A, and 2 is 20%.

Table 12.4.22 MPC Breakdown for Refrigerator-Freezers for Product Class 5

(Automatic Defrost with Bottom-Mounted Freezer without Through-the-Door Ice 

Service)

TSL

(Efficiency 

Level)

Efficiency 

Level

(% less 

than 

baseline 

energy 

use)

Labor

$

Material

$

Overhead

$

Depreciation

$

MPC

$

Manufacturer 

Markup

MSP

$

Baseline Baseline 70.79 335.96 39.87 19.38 465.99 1.26 587.15 

TSL 1 EL 3 (20) 70.79 365.76 38.63 20.62 495.79 1.26 624.70 

TSL 2 EL 3 (20) 70.79 365.76 38.63 20.62 495.79 1.26 624.70 

TSL 3 EL 3 (20) 70.79 365.76 38.63 20.62 495.79 1.26 624.70 

TSL 4 EL 5 (30) 73.29 467.28 39.21 25.15 604.92 1.26 762.20 

TSL 5 EL 6 (36) 79.95 544.76 45.14 29.06 698.91 1.26 880.63 
12-30

Table 12.4.23 MPC Breakdown for Refrigerator-Freezers for Product Class 7

(Automatic Defrost with Side-Mounted Freezer with Through-the-Door Ice Service)

TSL

(Efficiency 

Level)

Efficiency 

Level

(% less 

than 

baseline 

energy 

use)

Labor

$

Material

$

Overhead

$

Depreciation

$

MPC

$

Manufacturer 

Markup

MSP

$

Baseline Baseline 97.48 415.42 37.36 23.87 574.13 1.26 723.40 

TSL 1 EL 3 (20) 97.69 447.90 36.96 25.27 607.82 1.26 765.85 

TSL 2 EL 4 (25) 98.29 487.55 36.08 26.98 648.90 1.26 817.61 

TSL 3 EL 4 (25) 98.29 487.55 36.08 26.98 648.90 1.26 817.61 

TSL 4 EL 5 (30) 101.94 566.95 38.72 30.70 738.30 1.26 930.26 

TSL 5 EL 6 (33) 106.65 625.01 43.15 33.61 808.43 1.26 1,018.62 

Table 12.4.24 MPC Breakdown for Product Class 9 (Upright Freezers with 

Automatic Defrost)

TSL

(Efficiency 

Level)

Efficiency 

Level

(% less 

than 

baseline 

energy 

use)

Labor

$

Material

$

Overhead

$

Depreciation

$

MPC

$

Manufacturer 

Markup

MSP

$

Baseline Baseline 45.72 198.99 27.22 11.80 283.73 1.26 357.50 

TSL 1 EL 3 (20) 45.72 230.23 29.28 13.24 318.47 1.26 401.27 

TSL 2 EL 5 (30) 45.72 239.00 54.31 14.71 353.75 1.26 445.72 

TSL 3 EL 6 (35) 45.72 276.69 52.74 16.28 391.43 1.26 493.20 

TSL 4 EL 7 (40) 45.84 327.80 51.88 18.46 443.98 1.26 559.42 

TSL 5 EL 8 (44) 48.22 427.36 61.52 23.30 560.40 1.26 706.11 

Table 12.4.25 MPC Breakdown for Product Class 10 (Chest Freezers and All Other 

Freezers Except Compact Freezers)

TSL

(Efficiency 

Level)

Efficiency 

Level

(% less 

than 

baseline 

energy 

use)

Labor

$

Material

$

Overhead

$

Depreciation

$

MPC

$

Manufacturer 

Markup

MSP

$

Baseline Baseline 29.43 149.40 19.71 8.61 207.16 1.26 261.02 

TSL 1 EL 3 (20) 29.43 161.60 25.91 9.41 226.36 1.26 285.22 

TSL 2 EL 4 (25)* 29.43 165.87 50.66 10.67 256.63* 1.26 323.36 

TSL 3 EL 5 (30) 29.74 177.84 51.20 11.23 270.00 1.26 340.20 

TSL 4 EL 6 (35) 29.43 217.25 48.52 12.81 308.01 1.26 388.10 

TSL 5 EL 7 (41) 31.24 282.66 54.69 15.99 384.58 1.26 484.57 

*Efficiency level for product class 10A is 30%.
12-31

Table 12.4.26 MPC Breakdown for Product Class 11 (Compact Refrigerators and 

Refrigerator-Freezers with Manual Defrost)

TSL

(Efficiency 

Level)

Efficiency 

Level

(% less 

than 

baseline 

energy 

use)

Labor

$

Material

$

Overhead

$

Depreciation

$

MPC

$

Manufacturer 

Markup

MSP

$

Baseline Baseline 2.33 61.15 5.61 3.00 72.10 1.26 90.84 

TSL 1 EL 3 (20) 2.33 68.62 8.18 3.43 82.57 1.26 104.04 

TSL 2 EL 4 (25) 2.33 71.08 13.35 3.76 90.53 1.26 114.06 

TSL 3 EL 5 (30) 2.33 72.42 18.08 4.03 96.86 1.26 122.05 

TSL 4 EL 7 (40) 2.33 101.38 11.13 4.98 119.83 1.26 150.99 

TSL 5 EL 10 (59) 6.92 159.57 21.25 8.14 195.88 1.26 246.80 

Table 12.4.27 MPC Breakdown for Product Class 18 (Compact Chest Freezers)

TSL

(Efficiency 

Level)

Efficiency 

Level

(% less 

than 

baseline 

energy use)

Labor

$

Material

$

Overhead

$

Depreciation

$

MPC

$

Manufacturer 

Markup

MSP

$

Baseline Baseline 2.74 82.38 13.51 4.28 102.90 1.26 129.66 

TSL 1 EL 1 (10) 2.74 87.13 13.31 4.48 107.65 1.26 135.64 

TSL 2 EL 1 (10)* 2.74 87.13 13.31 4.48 107.65* 1.26 135.64 

TSL 3 EL 2 (15) 2.74 89.63 18.96 4.83 116.16 1.26 146.36 

TSL 4 EL 4 (25) 3.43 97.72 44.29 6.31 151.75 1.26 191.20 

TSL 5 EL 7 (42) 4.54 168.19 45.39 9.46 227.58 1.26 286.75 

*Efficiency level for product class 13 and 15 is 15%, efficiency level for product class 14 is 20%, and 

efficiency level for product class 13A is 25%.

Table 12.4.28 MPC Breakdown for Product Class 3A-BI (Built-In All-RefrigeratorsAutomatic Defrost)

TSL

(Efficiency 

Level)

Efficiency 

Level

(% less 

than 

baseline 

energy use)

Labor

$

Material

$

Overhead

$

Depreciation

$

MPC

$

Manufacturer 

Markup

MSP

$

Baseline Baseline 95.84 1,615.36 208.81 115.41 2,035.42 1.40 2,849.59

TSL 1 EL 1 (10) 95.84 1,620.46 208.52 115.70 2,040.52 1.40 2,856.73

TSL 2 EL 2 (15) 95.84 1,628.86 208.05 116.17 2,048.92 1.40 2,868.49

TSL 3 EL 3 (20) 98.73 1,695.16 211.76 120.56 2,126.21 1.40 2,976.69

TSL 4 EL 4 (25) 104.59 1,787.89 210.87 126.43 2,229.77 1.40 3,121.68

TSL 5 EL 5 (29) 105.00 1,863.42 208.77 130.87 2,308.06 1.40 3,231.28
12-32

Table 12.4.29 MPC Breakdown for Product Class 5-BI (Built-In RefrigeratorFreezers—Automatic Defrost with Bottom-Mounted Freezer without an Automatic 

Icemaker)

TSL

(Efficiency 

Level)

Efficiency 

Level

(% less 

than 

baseline 

energy use)

Labor

$

Material

$

Overhead

$

Depreciation

$

MPC

$

Manufacturer 

Markup

MSP

$

Baseline Baseline 141.57 1,847.90 160.55 129.23 2,279.26 1.40 3,190.97 

TSL 1 EL 1 (10) 141.64 1,862.79 160.06 130.10 2,294.60 1.40 3,212.44 

TSL 2 EL 2 (15) 141.57 1,909.20 157.08 132.71 2,340.56 1.40 3,276.79 

TSL 3 EL 2 (15) 141.57 1,909.20 157.08 132.71 2,340.56 1.40 3,276.79 

TSL 4 EL 4 (25) 146.16 2,044.43 158.40 141.19 2,490.18 1.40 3,486.25 

TSL 5 EL 5 (27) 150.74 2,087.76 160.97 144.23 2,543.70 1.40 3,561.18 

Table 12.4.30 MPC Breakdown for Product Class 7-BI (Built-In RefrigeratorFreezers—Automatic Defrost with Side-mounted Freezer with Through-the-Door 

Ice Service)

TSL

(Efficiency 

Level)

Efficiency 

Level

(% less 

than 

baseline 

energy use)

Labor

$

Material

$

Overhead

$

Depreciation

$

MPC

$

Manufacturer 

Markup

MSP

$

Baseline Baseline 194.97 2,812.72 168.15 190.89 3,366.73 1.40 4,713.43 

TSL 1 EL 1 (10) 195.22 2,847.34 167.95 192.98 3,403.48 1.40 4,764.88 

TSL 2 EL 1 (10) 195.22 2,847.34 167.95 192.98 3,403.48 1.40 4,764.88 

TSL 3 EL 3 (20) 199.55 2,997.40 168.57 202.30 3,567.83 1.40 4,994.96 

TSL 4 EL 3 (20) 199.55 2,997.40 168.57 202.30 3,567.83 1.40 4,994.96 

TSL 5 EL 4 (22) 204.13 3,050.21 171.65 205.93 3,631.93 1.40 5,084.70 

Table 12.4.31 MPC Breakdown for Product Class 9-BI (Built-In Upright Freezers 

with Automatic Defrost Without an Automatic Icemaker)

TSL

(Efficiency 

Level)

Efficiency 

Level

(% less 

than 

baseline 

energy use)

Labor

$

Material

$

Overhead

$

Depreciation

$

MPC

$

Manufacturer 

Markup

MSP

$

Baseline Baseline 91.45 1,558.58 154.61 108.47 1,913.11 1.40 2,678.35 

TSL 1 EL 1 (10) 91.45 1,569.78 153.97 109.11 1,924.31 1.40 2,694.03 

TSL 2 EL 3 (20) 91.51 1,628.82 151.16 112.49 1,983.99 1.40 2,777.58 

TSL 3 EL 4 (25) 94.84 1,697.43 155.02 117.05 2,064.35 1.40 2,890.09 

TSL 4 EL 4 (25) 94.84 1,697.43 155.02 117.05 2,064.35 1.40 2,890.09 

TSL 5 EL 5 (25) 100.62 1,746.54 157.97 120.52 2,125.65 1.40 2,975.91 

12.4.8 Conversion Costs

Amended energy conservation standards typically cause manufacturers to incur 

one-time conversion costs to bring their production facilities and product designs into 
12-33

compliance with new regulations. For the MIA, DOE classified these one-time 

conversion costs into two major groups: capital conversion costs and product conversion 

costs. Capital conversion costs are one-time investments in PPE to adapt or change 

existing production facilities so that new product designs can be fabricated and assembled 

under the new regulation. Product conversion costs are one-time investments in research, 

development, testing, marketing and other costs to make product designs comply with 

amended energy conservation standards. The following sections describe the inputs DOE 

used in the GRIM in greater detail. 

12.4.8.1 Capital Conversion Costs

To calculate industry cash flow impacts DOE evaluated the level of capital 

conversion costs manufacturers would incur to comply with amended energy 

conservation standards. This evaluation drew from multiple data sources and 

methodologies. Table 12.4.32 through Table 12.4.42 show DOE’s estimates of the capital 

conversion costs necessary for each product class at each TSL. The methodology DOE 

used to calculate the capital conversion costs is described below.

During the MIA interviews, DOE asked manufacturers to estimate the capital 

conversion costs required to expand the production of higher-efficiency products that 

may be required by standards. In turn, many manufacturers provided estimates and 

descriptions of the required tooling and plant changes that would be necessary to upgrade 

product lines to meet various potential efficiency levels. DOE based its capital 

conversion cost estimates on the information gathered in these interviews as well as

assumptions from the engineering analysis. 

Using the interviews and the engineering analysis’s design options at each 

efficiency level for each product class, DOE determined what changes would be required 

at existing production facilities if manufacturers implemented those design options. DOE 

used information from manufacturer interviews to determine the level of capital 

conversion costs that these changes would require. For all freestanding product classes, 

DOE segmented its capital conversion costs equally between the two product sizes 

analyzed in the engineering analysis to get a representative total capital conversion cost 

for each efficiency level for each analyzed product class. Because DOE analyzed one 

product for the built-in product classes, DOE calculated the capital conversion costs for 

each built-in product class using the design options for the one analyzed product. 

For each product at each efficiency level, DOE assumed that most component 

swaps, while requiring moderate product conversion costs, would not require changes to 

existing production lines and equipment, and therefore not require additional capital 

expenditures. However, for larger condensers and evaporators DOE calculated the tooling 

investment required for both the fabrication equipment and the tooling changes because 

these options would cause slight changes to the interiors of existing products. These 

tooling changes would likely include purchasing new dies or molds for a small change in 

internal dimensions or shelving.

DOE assumed the major capital conversion costs would occur when 
12-34

manufacturers would have to redesign their existing product lines. For standard-size 

freezers and compact refrigeration products, DOE analyzed design options that would 

require changes to insulation thickness, an instance explicitly requiring the redesign of 

existing lines. For these product classes, DOE used information from manufacturer 

interviews to determine the cost of the production equipment necessary to implement 

complete redesigns. DOE allocated these costs to both product sizes analyzed in the 

engineering analysis for each product class and assumed that one quarter of the total 

redesign cost would be required for changes to door insulation thickness while the 

remaining three-quarters of the redesign cost would be required for changes to wall 

insulation thickness. For standard-size refrigerator-freezers and built-in refrigeration 

products, DOE understands that a limited number of existing products currently use VIPs. 

For freestanding standard-size refrigerator-freezers, DOE notes that these current 

products benefited from a tax credit that allowed a more labor-intensive solution and 

slower production speed. However, if the standard were set at levels that necessitated

VIPs, it would be extremely disruptive to current operations, even those facilities that 

make a limited number of products with VIPs, due to the high production volumes 

required. Incorporating VIPs in high volume production would require major changes to 

the manufacturing processes and equipment currently used for the low-volume products 

that use VIPs. Therefore, DOE assumed that if the energy conservation standard were set 

at levels that were analyzed with VIPs as design options, the changes to production 

facilities would be substantial despite some limited current use of the technology. 

Because of the changes required to implement these design options would greatly change 

existing products, DOE expects that the capital conversion costs would approximate the 

purchase of new production equipment. DOE used the implementation of the first VIP as 

a proxy for the level that would require new production lines. 

For all product classes, DOE used the assumptions from the engineering analysis 

about the incremental depreciation costs associated with additional VIPs to calculate the 

additional production equipment that would be required to add additional steps in the 

manufacturing process. DOE used the incremental per unit depreciation cost assumptions 

in the engineering analysis for additional VIPs and multiplied that figure by each 

manufacturer’s estimated shipments over an average equipment lifetime of 15 years. 

DOE calculated each manufacturer’s estimated shipments using market share data for 

each product class that was also requested during manufacturer interviews. 

DOE followed this methodology for each product class that interviewed 

manufacturers produced. DOE then scaled its estimates to account for the rest of the 

market. DOE interviewed an average of 90 percent of the market across the seven 

freestanding and four built-in product classes analyzed. 

Finally, DOE assumed that the design options that would require capital 

conversion costs would strand PPE that was not fully depreciated and would have had a 

longer life if the amended energy conservation standards were not implemented. DOE did 

not receive quantitative information on the magnitude of stranded assets. However, 

because net PPE is approximately half of gross PPE in a mature industry and because not 

all existing assets would need to be replaced if products were completely redesigned, 

DOE assumed that stranded assets would be 50 percent of the capital conversion costs at 
12-35

each efficiency level. 

DOE’s estimates of the capital conversion costs for all of the residential 

refrigeration products can be found in Table 12.4.32 through Table 12.4.42 below.

Table 12.4.32 Capital Conversion Costs for Product Class 3 (Automatic Defrost with 

Top-Mounted Freezer Without Through-the-Door Ice Service) by TSL

TS

L

Efficiency 

Level (% 

reduction 

from 

baseline 

energy use)

Design Options 

Considered for the 

16 Cubic Foot PC 3 

Unit

Capital 

Conversion 

Costs for the 

16 Cubic Foot 

PC 3 Unit

2009$ millions

Design Options 

Considered for the 

21 Cubic Foot PC 3 

Unit

Capital 

Conversion 

Costs for the 

21 Cubic Foot 

PC 3 Unit

2009$ millions

TSL 

1, 

TSL

2

EL 3 (20)

Increase Condenser 

Size by 100%

Increase Compressor 

EER from 5.55 

to 6.26

Brushless DC 

Condenser Fan 

Motor

Increase Evaporator 

Size by 14%

Adaptive Defrost

Variable Speed 

Compressor

$26.0

Increase Compressor 

EER from 5.94 to 

6.08

Increase Evaporator 

Size by 25%

Brushless DC 

Condenser Fan 

Motor

$11.6

TSL 

3 EL 4 (25)*

TSL 1, TSL 2 Design 

Options +

12.2 sqft VIP in 

FZR Cabinet

$252.3

TSL 1, TSL 2 Design 

Options +

Brushless DC 

Evaporator Fan 

Motor

$11.6

TSL 

4 EL 5 (30)

TSL 3 Design 

Options +

2.9 sqft VIP in FZR 

Door

7.1 sqft VIP in FF 

Door

6.7 sqft VIP in FF 

Cabinet

$395.4

TSL 3 Design Options 

+

Adaptive Defrost

3.6 sqft VIP in FZR 

Door

7.6 sqft VIP in FZR 

Cabinet

$298.3

TSL 

5 EL 6 (36)

TSL 4 Design 

Options +

1.9 sqft more VIP in 

FF 

$412.2

TSL 4 Design Options 

+

Variable Speed 

Compressor

8.5 sqft VIP in FF 

Door

10.9 sqft VIP in FF 

Cabinet

$488.9

*Efficiency level for product classes 1, 1A and 2 is 20%.
12-36

Table 12.4.33 Capital Conversion Costs for Product Class 5 (Automatic Defrost with 

Bottom-Mounted Freezer without Through-the-Door Ice Service) by TSL

TSL

Efficiency 

Level (% 

reduction 

from 

baseline 

energy use)

Design Options 

Considered for the 

18.5 Cubic Foot PC 5 

Unit

Capital 

Conversion 

Costs for the 

18.5 Cubic Foot 

PC 5 Unit

2009$ millions

Design Options 

Considered for the 25 

Cubic Foot PC 5 Unit

Capital 

Conversion 

Costs for the 

25 Cubic Foot 

PC 5 Unit

2009$ millions

TSL 1, 

TSL 2, 

TSL 3

EL 3 (20)

Increase Compressor 

EER from 5.61 to 

6.26

Brushless DC 

Evaporator Fan 

Motor

Adaptive Defrost

Brushless DC 

Condenser Fan 

Motor

Variable Antisweat 

Heat Control

Increase Evaporator 

Size by 25%

$11.9

Increase Compressor 

EER from 5.00 to 

6.26

-

TSL 4 EL 5 (30)

TSL 1, 2, 3 Design 

Options +

Variable Speed 

Compressor

4.8 sqft VIP in FZR 

Door

6.8 sqft VIP in FF 

Door

13.7 sqft VIP in FZR 

Cabinet

$262.1

TSL 1, 2, 3 Design 

Options +

Brushless DC 

Evaporator Fan 

Motor

Variable Anti-Sweat 

Heater Control

Brushless DC 

Condenser Fan 

Motor

Variable Speed 

Compressor

-

TSL 5 EL 6 (36)

TSL 4 Design Options 

+

7.2 sqft VIP in FF 

Cabinet

$280.4

TSL 4 Design Options 

+

9.2 sqft VIP in FF 

Door

5.9 sqft VIP in FZR 

Door

14.8 sqft VIP in FZR 

Cabinet

10.3 sqft VIP in FF 

Cabinet

$265.2
12-37

Table 12.4.34 Capital Conversion Costs for Product Class 7 (Automatic Defrost with 

Side-Mounted Freezer with Through-the-Door Ice Service) by TSL

TSL

Efficiency 

Level (% 

reduction 

from 

baseline 

energy use)

Design Options 

Considered for the 

22 Cubic Foot PC 7 

Unit

Capital 

Conversion 

Costs for the 

22 Cubic Foot 

PC 7 Unit

2009$

millions

Design Options 

Considered for the 

26 Cubic Foot PC 7 

Unit

Capital 

Conversion 

Costs for the 

26 Cubic Foot 

PC 7 Unit

2009$

millions

TSL 1 EL 3 (20)

Increase Compressor 

EER from 5.51 to 

6.26

Brushless DC 

Condenser Fan 

Motor

Increase Evaporator 

Area 19%

Increase Condenser 

Size by 27%

Variable Anti-Sweat 

Heater Control 

for Ice Dispenser

5.1 sqft VIP in FZR 

Door

$179.3

Increase Compressor 

EER from 5.21 

to 6.11

Brushless DC 

Evaporator Fan 

Motor

Brushless DC 

Condenser Fan 

Motor

-

TSL 2, 

TSL 3 EL 4 (25)

TSL 1 Design 

Options +

Remove 5.1 sqft VIP 

FZR Door

Variable Speed 

Compressor

3.0 sqft VIP in FZR 

Cabinet

$179.3

TSL 1 Design 

Options +

Increase Compressor 

EER from 6.11 

to 6.26

Variable Anti-Sweat 

Heater Control 

for Ice 

Dispenser

Increase Condenser 

Size by 10%

6.2 sqft VIP in FZR 

Door

$164.4

TSL 4 EL 5 (30)

TSL 2 and 3 Design 

Options +

7.4 sqft more VIP in 

FZR Cabinet

5.1 sqft VIP in FZR 

Door

8 sqft VIP in FF Door

7.8 sqft VIP in FF 

Cabinet

$275.8

TSL 2 and 3 Design 

Options +

Variable Speed 

Compressor

2.6 sqft VIP in FZR 

Cabinet

$173.1

TSL 5 EL 6 (33)

TSL 4 Design 

Options +

4.9 sqft more VIP in 

FF Cabinet

$293.0

TSL 4 Design 

Options +

9.1 sqft more VIP in 

FZR Cabinet

8.2 sqft VIP in FF 

$273.2
12-38

Door

13.4 sqft VIP in FF 

Cabinet

Table 12.4.35 Capital Conversion Costs for Product Class 9 (Upright Freezers with 

Automatic Defrost) by TSL

TSL

Efficiency 

Level (% 

reduction 

from 

baseline 

energy use)

Design Options 

Considered for the 14 

Cubic Foot PC 9 Unit

Capital 

Conversion 

Costs for the 

14 Cubic Foot 

PC 9 Unit

2009$ millions

Design Options 

Considered for the 20 

Cubic Foot PC 9 Unit

Capital 

Conversion 

Costs for the 

20 Cubic Foot 

PC 9 Unit

2009$ millions

TSL 1 EL 3 (20)

Brushless DC Evaporator 

Fan Motor

Increase Compressor EER 

from 5.04 to 6.08

Add 1 inch Insulation to 

Door

Adaptive Defrost

$9.6

Brushless DC 

Evaporator Fan 

Motor

Increase Compressor 

EER from 5.73 to 

6.24

Adaptive Defrost

Increase Evaporator Size 

by 22%

Forced Convection 

Condenser with 

Brushless DC 

Condenser Fan

$11.2

TSL 2 EL 5 (30)

TSL 1 Design Options +

Add 0.56 inch Insulation 

to Cabinet

$38.4

TSL 1 Design Options +

Add 0.7 inch Insulation 

to Door

Add 0.5 inch Insulation 

to Cabinet

$48.8

TSL 3 EL 6 (35)

TSL 2 Design Options +

Remove 0.06 inch 

Cabinet Insulation

Variable Speed 

Compressor

$38.4

TSL 2 Design Options +

Add 0.5 inch Insulation 

to Cabinet

$48.8

TSL 4 EL 7 (40)

TSL 3 Design Options +

Add 0.5 Inch Insulation to 

Cabinet

5.7 sqft VIP in Door

$46.6

TSL 3 Design Options +

Variable Speed 

Compressor

$48.8

TSL 5 EL 8 (44)

TSL 4 Design Options +

4.6 sqft more VIP in Door

18.9 sqft VIP in Cabinet

$81.3

TSL 4 Design Options +

14.4 sqft VIP in Door

23.1 sqft VIP in Cabinet

$103.8
12-39

Table 12.4.36 Capital Conversion Costs for Product Class 10 (Chest Freezers and 

All Other Freezers Except Compact Freezers) by TSL

TSL

Efficiency 

Level (% 

reduction 

from 

baseline 

energy use)

Design Options 

Considered for the 15 

Cubic Foot PC 10 Unit

Capital 

Conversion 

Costs for the 

15 Cubic Foot 

PC 10 Unit

2009$ millions

Design Options 

Considered for the 20 

Cubic Foot PC 10 Unit

Capital 

Conversion 

Costs for the 

20 Cubic Foot 

PC 10 Unit

2009$ millions

TSL 1 EL 3 (20)

Increase Compressor EER 

from 4.92 to 6.08

Add 0.24 inch Insulation 

to Door

$9.8

Increase Condenser Size 

by 24%

Increase Compressor 

EER from 5.71 to 

6.25

Convert Door Insulation 

to PU Foam

Add 1 inch Insulation to 

Door

$19.6

TSL 2 EL 4 (25)*

TSL 1 Design Options +

Add 0.76 inch Insulation 

to Door

Add 0.15 inch Insulation 

to Cabinet

$39.0

TSL 1 Design Options +

Add 0.35 inch Insulation 

to Cabinet

$48.8

TSL 3 EL 5 (30)

TSL 2 Design Options +

Add 0.35 inch Insulation 

to Cabinet

$39.0

TSL 2 Design Options +

Add 0.4 inch Insulation 

to Cabinet

4.5 sqft VIP in Bottom 

Wall

$55.9

TSL 4 EL 6 (35)

TSL 3 Design Options +

Variable Speed 

Compressor

$39.0

TSL 3 Design Options +

Remove 4.5 sqft VIP 

Bottom Wall

Variable Speed 

Compressor

$48.8

TSL 5 EL 7 (41)

TSL 4 Design Options +

Add 0.25 inch Insulation 

to Cabinet

8.2 sqft VIP on bottom

8.8 sqft VIP on door

$51.7

TSL 4 Design Options +

10.2 sqft VIP in Bottom 

Wall

12 sqft VIP in Door

$83.0

*Efficiency level for product class 10A is 30%.
12-40

Table 12.4.37 Capital Conversion Costs for Product Class 11 (Compact 

Refrigerators and Refrigerator-Freezers with Manual Defrost) by TSL

TSL

Efficiency 

Level (% 

reduction 

from 

baseline 

energy use)

Design Options 

Considered for the 1.7 

Cubic Foot PC 11 Unit

Capital 

Conversion 

Costs for the 

1.7 Cubic Foot 

PC 11 Unit

2009$ millions

Design Options 

Considered for the 4 

Cubic Foot PC 11 Unit

Capital 

Conversion 

Costs for the 

4 Cubic Foot 

PC 11 Unit

2009$ millions

TSL 1 EL 3 (20)

Increase Evaporator Size 

by 20%

Increase Compressor EER 

from 3.02 to 3.47

Increase Condenser Size 

by 19%

Add 3/4 inch Insulation in 

Door

$12.4

Increase Compressor 

EER from 4.57 to 

5.3

Increase Condenser Size 

by 22%

Add 3/4 inch Insulation 

to Door

$11.2

TSL 2 EL 4 (25)

TSL 1 Design Options +

Add 0.18 inch Insulation 

in Cabinet

$34.6

TSL 1 Design Options +

Convert to Isobutane 

Refrigerant

Add 1/4 inch Insulation 

to Door

$11.2

TSL 3 EL 5 (30)

TSL 2 Design Options +

Add 0.57 inch Insulation 

in Cabinet

$34.6

TSL 2 Design Options +

Add 0.22 inch Insulation 

to Cabinet

Remove 1/4 inch 

Insulation from 

Door

$33.4

TSL 4 EL 7 (40)

Eliminate all previous 

Design Options

Variable Speed 

Compressor

Convert to Isobutane 

Refrigerant

-

TSL 3 Design Options +

Add 0.53 inch Insulation 

to Cabinet

$33.4

TSL 5 EL 10 (59)

TSL 4 Design Options +

Increase Evaporator Size 

by 20%

Increase Condenser Size 

by 19%

Add 3/4 inch Insulation in 

Door

Add 3/4 inch Insulation in 

Cabinet

Add 4.7 sqft VIP in 

Cabinet

Add 2.2 sqft VIP in Door

$71.8

TSL 4 Design Options +

Variable Speed 

Compressor

Remove 0.2 inch Cabinet 

Insulation

7.2 sqft VIP Cabinet

4.2 sqft VIP Door

$90.9
12-41

Table 12.4.38 Capital Conversion Costs for Product Class 18 (Compact Chest 

Freezers) by TSL

TSL

Efficiency 

Level (% 

reduction 

from 

baseline 

energy use)

Design Options 

Considered for the 3.4 

Cubic Foot PC 18 Unit

Capital 

Conversion 

Costs for the 

3.4 Cubic Foot 

PC 18 Unit

2009$ millions

Design Options 

Considered for the 7 

Cubic Foot PC 18 Unit

Capital 

Conversion 

Costs for the 

7 Cubic Foot 

PC 18 Unit

2009$ millions

TSL 1, 

TSL 2 EL 1 (10)* Increase Compressor EER 

from 3.74 to 4.17 -

Increase Compressor 

EER from 4.50 to 

5.02

-

TSL 3 EL 2 (15)

TSL 1 and 2 Design 

Options +

Increase Compressor EER 

from 4.17 to 4.29

Add 1 inch Insulation to 

Door

$4.2

TSL 1 and 2 Design 

Options +

Increase Compressor 

EER from 5.02 to 

5.27

Add 0.12 inch Insulation 

to Door

$4.2

TSL 4 EL 4 (25)

TSL 3 Design Options +

Remove 1/4 inch 

Insulation from Door

Add 0.75 inch Insulation 

to Cabinet

Add 2.1 sqft VIP in 

Bottom Wall

$20.5

TSL 3 Design Options +

Add 0.63 inch Insulation 

to Door

Add 0.62 inch Insulation 

to Cabinet

$16.9

TSL 5 EL 7 (42)

Remove all previous 

Design Options

Variable Speed 

Compressor

Add 0.75 inch Insulation 

to Door

Add 0.75 inch Insulation 

to Cabinet

Add 2.1 sqft VIP in 

Bottom Wall

Add 3.3 sqft VIP in Door

$22.8

Remove all previous 

Design Options

Variable Speed 

Compressor

Add 0.76 inch Insulation 

to Cabinet

Add 3/4 inch Insulation 

to Door

Add 4.1 sqft VIP to 

Cabinet Bottom

Add 5.1 sqft VIP to Door

$34.9

*Efficiency level for product class 13 and 15 is 15%, efficiency level for product class 14 is 20%, and 

efficiency level for product class 13A is 25%.
12-42

Table 12.4.39 Capital Conversion Costs for Product Class 3A-BI (Built-In AllRefrigerators-Automatic Defrost) by TSL

TSL

Efficiency Level 

(% reduction from 

baseline energy 

use)

Design Options Considered for the PC 3ABI Unit

Capital Conversion 

Costs for the PC 3A-BI

Unit

2009$ millions

TSL 1 EL 1 (10)

Decrease Both Compressor Capacity (same 

EER)

10% Increase to Condenser Area

Brushless DC Evaporator Fan Upper 

Evaporator

$0.5

TSL 2 EL 2 (15)

TSL 1 Design Options +

Brushless DC Evaporator Fan Lower 

Evaporator

Brushless DC Condenser Fan

$0.5

TSL 3 EL 3 (20)

TSL 2 Design Options +

Full VIP--Upper Door

Partial VIP--Lower Cabinet

$14.9

TSL 4 EL 4 (25)

TSL 3 Design Options +

Full VIP--Lower Cabinet

Full VIP--Upper Cabinet

Upper System Variable Speed Compressor

$15.5

TSL 5 EL 5 (29)

TSL 4 Design Options +

Full VIP--Lower Door

Lower System Variable Speed Compressor

$15.8
12-43

Table 12.4.40 Capital Conversion Costs for Product Class 5-BI (Built-In 

Refrigerator-Freezers—Automatic Defrost with Bottom-Mounted Freezer without 

an Automatic Icemaker) by TSL

TSL

Efficiency Level 

(% reduction from 

baseline energy 

use)

Design Options Considered for the PC 5-BI

Unit

Capital Conversion 

Costs for the PC 5-BI

Unit

2009$ millions

TSL 1 EL 1 (10)

Decrease FF Compressor Capacity (same 

EER)

10% Increase to Condenser Area

Increase FRZ Compressor EER to 6.26

1.0 sqft VIP--FRZ Door

$16.9

TSL 

2, 

TSL 3

EL 2 (15)

TSL 1 Design Options +

Remove 1.0 sqft VIP -- FZR Door

FRZ Variable Speed Compressor with 

Brushless DC Condenser Fan

$0.6

TSL 4 EL 4 (25)

TSL 2 and 3 Design Options +

14.6 sqft VIP--FRZ Cabinet (Partial Coverage)

Add 3.6 sqft VIP -- FZR Cabinet (Full 

Coverage)

6.0 sqft VIP--FRZ Door (Full Coverage)

FF Variable Speed Compressor with Brushless 

DC Condenser Fan

$19.1

TSL 5 EL 5 (27)

TSL 4 Design Options +

9.4 sqft VIP -- FF Door (Full Coverage)

3.8 sqft VIP -- FF Cabinet (Full Coverage)

$22.5

Table 12.4.41 Capital Conversion Costs for Product Class 8-BI (Built-In 

Refrigerator-Freezers—Automatic Defrost with Side-mounted Freezer with 

Through-the-Door Ice Service) by TSL

TSL

Efficiency Level (% 

reduction from 

baseline energy use)

Design Options Considered for PC 7-BI Unit

Capital Conversion Costs 

for the PC 7-BI Unit

2009$ millions

TSL 1, 

TSL 2 EL 1 (10)

High Efficiency Compressor

Heat Exchanger Improvement

Variable Anti-Sweat Heater Control

Partial VIP to Freezer Door

$22.4

TSL 3, 

TSL 4 EL 3 (20)

TSL 1 and 2 Design Options +

Eliminate VIP to Freezer Door

Variable Speed Compressor

VIP to Freezer Door

VIP to Freezer Cabinet

$23.8

TSL 5 EL 4 (22)

TSL 3 and 4 Design Options +

VIP to Fresh Food Cabinet

VIP to Fresh Food Door

$29.3
12-44

Table 12.4.42 Capital Conversion Costs for Product Class 9-BI (Built-In Upright 

Freezers with Automatic Defrost Without an Automatic Icemaker)

TSL

Efficiency Level (% 

reduction from 

baseline energy use)

Design Options Considered for PC 9-BI Unit

Capital Conversion Costs 

for the PC 9-BI Unit

2009$ millions

TSL 1 EL 1 (10) Increase Compressor EER to 6.29 -

TSL 2 EL 3 (20)

TSL 1 Design Options +

Brushless DC Fan for Evaporator

Brushless DC Fan for Condenser

10% Increase to Condenser Area

Variable Speed Compressor with Brushless DC 

Fans

1.5 sqft VIP Upper Door

$14.3

TSL 3, 

TSL 4 EL 4 (25)

TSL 2 Design Options +

VIP Upper Door (Full Coverage)

13.1 sqft VIP Lower Cabinet

$15.3

TSL 5 EL 5 (27)

TSL 3 and 4 Design Options +

VIP Lower Cabinet (Full Coverage)

VIP--Lower Door

VIP--Upper Cabinet

$16.1

12.4.8.2 Product Conversion Costs 

DOE based its estimates of the product conversion costs that would be required to 

meet each TSL on information obtained from manufacturer interviews, the design 

pathways analyzed in the engineering analysis, and market information about the number 

of platform and product families for each manufacturer. Similar to how it calculated 

capital conversion costs, for all freestanding product classes DOE segmented product 

conversion costs equally between the two product sizes analyzed in the engineering 

analysis for each efficiency level for each analyzed product class. Because DOE analyzed 

one product for the built-in product classes, DOE calculated the product conversion costs 

for each built-in product class using the design options for the one analyzed product. 

DOE assigned estimates for the total product development required for each 

design option based on the necessary engineering resources required to implement each 

design option across a product platform. DOE assumed that each estimate of the product 

development effort included engineering resources for R&D, testing, trade costs, and 

marketing costs to recast product literature. DOE multiplied the estimate by the number 

of platforms and product families for each manufacturer. DOE assumed that more 

efficient compressors, larger condensers, more efficient fan motors, adaptive defrost, and 

variable anti-sweat would be the least costly design options to implement across a 

product platform because they constitute direct component swapouts. However, DOE 

assumed that forced convection and larger evaporators would take a slightly greater 

effort. DOE assumed that variable speed compressors would be a more difficult 

component to implement because of the interaction with other systems. DOE assigned a 

greater weight to this design option and also added engineering time if the baseline unit 
12-45

analyzed in the engineering analysis did not have electronic controls. DOE also added a 

significant cost for manufacturers to train servicers if isobutane were used as a design 

option. DOE also assumed that VIP use and/or wall thickness increases would require 

more significant changes to existing platforms than the above-mentioned design options 

that amount to component swaps. For wall thickness increases, DOE used product 

development efforts that were analogous to designing a new platform. Because VIPs are 

not currently common at large scale to most products in the industry, DOE assumed more 

substantial product development costs for that than other component swaps. However, 

DOE also assumed that manufacturers’ recent experience with the technology would 

require less effort than designing completely new products, and implementing additional 

VIPs would require a less substantial effort than the first VIP panel. 

Finally, DOE estimated industry product conversion costs by extrapolating the 

interviewed manufacturers’ product conversion costs for each product class to account 

for the market share of companies that were not interviewed. DOE’s estimates of the 

product conversion costs for all of the refrigeration products addressed in this rulemaking 

can be found in Table 12.4.43 through Table 12.4.53 below.
12-46

Table 12.4.43 Product Conversion Costs for Product Class 3 (Automatic Defrost 

with Top-Mounted Freezer Without Through-the-Door Ice Service) by TSL

TSL

Efficiency 

Level (% 

reduction 

from 

baseline 

energy 

use)

Design Options 

Considered for the 

16 Cubic Foot PC 3 

Unit

Product

Conversion 

Costs for the 

16 Cubic Foot 

PC 3 Unit

2009$ millions

Design Options 

Considered for the 

21 Cubic Foot PC 3 

Unit

Product

Conversion 

Costs for the 

21 Cubic Foot 

PC 3 Unit

2009$ millions

TSL 

1, 

TSL 2

EL 3 (20)

Increase Condenser 

Size by 100%

Increase Compressor 

EER from 5.55 

to 6.26

Brushless DC 

Condenser Fan 

Motor

Increase Evaporator 

Size by 14%

Adaptive Defrost

Variable Speed 

Compressor

$45.2

Increase Compressor 

EER from 5.94 to 

6.08

Increase Evaporator 

Size by 25%

Brushless DC 

Condenser Fan 

Motor

$21.7

TSL 3 EL 4 (25)*

TSL 1, TSL 2 Design 

Options +

12.2 sqft VIP in 

FZR Cabinet

$72.2

TSL 1, TSL 2 Design 

Options +

Brushless DC 

Evaporator Fan 

Motor

$26.7

TSL 4 EL 5 (30)

TSL 3 Design 

Options +

2.9 sqft VIP in FZR 

Door

7.1 sqft VIP in FF 

Door

6.7 sqft VIP in FF 

Cabinet

$88.5

TSL 3 Design Options 

+

Adaptive Defrost

3.6 sqft VIP in FZR 

Door

7.6 sqft VIP in FZR 

Cabinet

$61.6

TSL 5 EL 6 (36)

TSL 4 Design 

Options +

1.9 sqft more VIP in 

FF 

$88.5

TSL 4 Design Options 

+

Variable Speed 

Compressor

8.5 sqft VIP in FF 

Door

10.9 sqft VIP in FF 

Cabinet

$85.1

*Efficiency level for product classes 1, 1A, and 2 is 20%.
12-47

Table 12.4.44 Product Conversion Costs for Product Class 5 (Automatic Defrost 

with Bottom-Mounted Freezer without Through-the-Door Ice Service) by TSL

TSL

Efficiency 

Level (% 

reduction 

from baseline 

energy use)

Design Options 

Considered for 

the 18.5 Cubic 

Foot PC 5 Unit

Product

Conversion 

Costs for the 

18.5 Cubic Foot 

PC 5 Unit

2009$ millions

Design Options 

Considered for 

the 25 Cubic 

Foot PC 5 Unit

Product

Conversion 

Costs for the 25 

Cubic Foot PC 5 

Unit

2009$ millions

TSL 1, 

TSL 2, 

TSL 3

EL 3 (20)

Increase 

Compressor 

EER from 

5.61 to 6.26

Brushless DC 

Evaporator 

Fan Motor

Adaptive Defrost

Brushless DC 

Condenser 

Fan Motor

Variable 

Antisweat

Heat Control

Increase 

Evaporator 

Size by 25%

$20.8

Increase 

Compressor 

EER from 

5.00 to 6.26

$4.9

TSL 4 EL 5 (30)

TSL 1, 2, 3 

Design 

Options +

Variable Speed 

Compressor

4.8 sqft VIP in 

FZR Door

6.8 sqft VIP in 

FF Door

13.7 sqft VIP in 

FZR Cabinet

$45.0

TSL 1, 2, 3 

Design 

Options +

Brushless DC 

Evaporator 

Fan Motor

Variable AntiSweat Heater 

Control

Brushless DC 

Condenser 

Fan Motor

Variable Speed 

Compressor

$18.9

TSL 5 EL 6 (36)

TSL 4 Design 

Options +

7.2 sqft VIP in 

FF Cabinet

$47.6

TSL 4 Design 

Options +

9.2 sqft VIP in 

FF Door

5.9 sqft VIP in 

FZR Door

14.8 sqft VIP in 

FZR Cabinet

10.3 sqft VIP in 

FF Cabinet

$41.4
12-48

Table 12.4.45 Product Conversion Costs for Product Class 7 (Automatic Defrost 

with Side-Mounted Freezer with Through-the-Door Ice Service) by TSL

TSL

Efficiency 

Level (% 

reduction 

from 

baseline 

energy use)

Design Options 

Considered for the 

22 Cubic Foot PC 7 

Unit

Product

Conversion 

Costs for the 

22 Cubic Foot 

PC 7 Unit

2009$

millions

Design Options 

Considered for the 

26 Cubic Foot PC 7 

Unit

Product

Conversion 

Costs for the 

26 Cubic Foot 

PC 7 Unit

2009$

millions

TSL 1 EL 3 (20)

Increase Compressor 

EER from 5.51 to 

6.26

Brushless DC 

Condenser Fan 

Motor

Increase Evaporator 

Area 19%

Increase Condenser 

Size by 27%

Variable Anti-Sweat 

Heater Control 

for Ice Dispenser

5.1 sqft VIP in FZR 

Door

$45.6

Increase Compressor 

EER from 5.21 

to 6.11

Brushless DC 

Evaporator Fan 

Motor

Brushless DC 

Condenser Fan 

Motor

$15.4

TSL 2, 

TSL 3 EL 4 (25)

TSL 1 Design 

Options +

Remove 5.1 sqft VIP 

FZR Door

Variable Speed 

Compressor

3.0 sqft VIP in FZR 

Cabinet

$57.7

TSL 1 Design 

Options +

Increase Compressor 

EER from 6.11 

to 6.26

Variable Anti-Sweat 

Heater Control 

for Ice 

Dispenser

Increase Condenser 

Size by 10%

6.2 sqft VIP in FZR 

Door

$46.4

TSL 4 EL 5 (30)

TSL 2 and 3 Design 

Options +

7.4 sqft more VIP in 

FZR Cabinet

5.1 sqft VIP in FZR 

Door

8 sqft VIP in FF Door

7.8 sqft VIP in FF 

Cabinet

$72.3

TSL 2 and 3 Design 

Options +

Variable Speed 

Compressor

2.6 sqft VIP in FZR 

Cabinet

$62.0

TSL 5 EL 6 (33)

TSL 4 Design 

Options +

4.9 sqft more VIP in 

FF Cabinet

$72.3

TSL 4 Design 

Options +

9.1 sqft more VIP in 

FZR Cabinet

8.2 sqft VIP in FF 

$70.9
12-49

Door

13.4 sqft VIP in FF 

Cabinet

Table 12.4.46 Product Conversion Costs for Product Class 9 (Upright Freezers with 

Automatic Defrost) by TSL

TSL

Efficiency 

Level (% 

reduction 

from 

baseline 

energy use)

Design Options 

Considered for the 14 

Cubic Foot PC 9 Unit

Product

Conversion 

Costs for the 

14 Cubic Foot 

PC 9 Unit

2009$ millions

Design Options 

Considered for the 20 

Cubic Foot PC 9 Unit

Product

Conversion 

Costs for the 

20 Cubic Foot 

PC 9 Unit

2009$ millions

TSL 1 EL 3 (20)

Brushless DC Evaporator 

Fan Motor

Increase Compressor EER 

from 5.04 to 6.08

Add 1 inch Insulation to 

Door

Adaptive Defrost

$6.1

Brushless DC 

Evaporator Fan 

Motor

Increase Compressor 

EER from 5.73 to 

6.24

Adaptive Defrost

Increase Evaporator Size 

by 22%

Forced Convection 

Condenser with 

Brushless DC 

Condenser Fan

$7.6

TSL 2 EL 5 (30)

TSL 1 Design Options +

Add 0.56 inch Insulation 

to Cabinet

$12.8

TSL 1 Design Options +

Add 0.7 inch Insulation 

to Door

Add 0.5 inch Insulation 

to Cabinet

$16.5

TSL 3 EL 6 (35)

TSL 2 Design Options +

Remove 0.06 inch 

Cabinet Insulation

Variable Speed 

Compressor

$15.6

TSL 2 Design Options +

Add 0.5 inch Insulation 

to Cabinet

$16.5

TSL 4 EL 7 (40)

TSL 3 Design Options +

Add 0.5 Inch Insulation to 

Cabinet

5.7 sqft VIP in Door

$16.5

TSL 3 Design Options +

Variable Speed 

Compressor

$19.3

TSL 5 EL 8 (44)

TSL 4 Design Options +

4.6 sqft more VIP in Door

18.9 sqft VIP in Cabinet

$17.5

TSL 4 Design Options +

14.4 sqft VIP in Door

23.1 sqft VIP in Cabinet

$21.2
12-50

Table 12.4.47 Product Conversion Costs for Product Class 10 (Chest Freezers and 

All Other Freezers Except Compact Freezers) by TSL

TSL

Efficiency 

Level (% 

reduction 

from 

baseline 

energy use)

Design Options 

Considered for the 15 

Cubic Foot PC 10 Unit

Product

Conversion 

Costs for the 

15 Cubic Foot 

PC 10 Unit

2009$ millions

Design Options 

Considered for the 20 

Cubic Foot PC 10 Unit

Product

Conversion 

Costs for the 

20 Cubic Foot 

PC 10 Unit

2009$ millions

TSL 1 EL 3 (20)

Increase Compressor EER 

from 4.92 to 6.08

Add 0.24 inch Insulation 

to Door

$3.9

Increase Condenser Size 

by 24%

Increase Compressor 

EER from 5.71 to 

6.25

Convert Door Insulation 

to PU Foam

Add 1 inch Insulation to 

Door

$4.9

TSL 2 EL 4 (25)*

TSL 1 Design Options +

Add 0.76 inch Insulation 

to Door

Add 0.15 inch Insulation 

to Cabinet

$10.4

TSL 1 Design Options +

Add 0.35 inch Insulation 

to Cabinet

$11.5

TSL 3 EL 5 (30)

TSL 2 Design Options +

Add 0.35 inch Insulation 

to Cabinet

$10.4

TSL 2 Design Options +

Add 0.4 inch Insulation 

to Cabinet

4.5 sqft VIP in Bottom 

Wall

$12.4

TSL 4 EL 6 (35)

TSL 3 Design Options +

Variable Speed 

Compressor

$13.2

TSL 3 Design Options +

Remove 4.5 sqft VIP 

Bottom Wall

Variable Speed 

Compressor

$14.3

TSL 5 EL 7 (41)

TSL 4 Design Options +

Add 0.25 inch Insulation 

to Cabinet

8.2 sqft VIP on bottom

8.8 sqft VIP on door

$14.8

TSL 4 Design Options +

10.2 sqft VIP in Bottom 

Wall

12 sqft VIP in Door

$16.2

*Efficiency level for product class 10A is 30%.
12-51

Table 12.4.48 Product Conversion Costs for Product Class 11 (Compact 

Refrigerators and Refrigerator-Freezers with Manual Defrost) by TSL

TSL

Efficiency 

Level (% 

reduction 

from 

baseline 

energy use)

Design Options 

Considered for the 1.7 

Cubic Foot PC 11 Unit

Product

Conversion 

Costs for the 

1.7 Cubic Foot 

PC 11 Unit

2009$ millions

Design Options 

Considered for the 4 

Cubic Foot PC 11 Unit

Product

Conversion 

Costs for the 

4 Cubic Foot 

PC 11 Unit

2009$ millions

TSL 1 EL 3 (20)

Increase Evaporator Size 

by 20%

Increase Compressor EER 

from 3.02 to 3.47

Increase Condenser Size 

by 19%

Add 3/4 inch Insulation in 

Door

$7.1

Increase Compressor 

EER from 4.57 to 

5.3

Increase Condenser Size 

by 22%

Add 3/4 inch Insulation 

to Door

$4.7

TSL 2 EL 4 (25)

TSL 1 Design Options +

Add 0.18 inch Insulation 

in Cabinet

$10.3

TSL 1 Design Options +

Convert to Isobutane 

Refrigerant

Add 1/4 inch Insulation 

to Door

$20.8

TSL 3 EL 5 (30)

TSL 2 Design Options +

Add 0.57 inch Insulation 

in Cabinet

$10.3

TSL 2 Design Options +

Add 0.22 inch Insulation 

to Cabinet

Remove 1/4 inch 

Insulation from 

Door

$24.6

TSL 4 EL 7 (40)

Eliminate all previous 

Design Options

Variable Speed 

Compressor

Convert to Isobutane 

Refrigerant

$8.2

TSL 3 Design Options +

Add 0.53 inch Insulation 

to Cabinet

$24.6

TSL 5 EL 10 (59)

TSL 4 Design Options +

Increase Evaporator Size 

by 20%

Increase Condenser Size 

by 19%

Add 3/4 inch Insulation in 

Door

Add 3/4 inch Insulation in 

Cabinet

Add 4.7 sqft VIP in 

Cabinet

Add 2.2 sqft VIP in Door

$17.3

TSL 4 Design Options +

Variable Speed 

Compressor

Remove 0.2 inch Cabinet 

Insulation

7.2 sqft VIP Cabinet

4.2 sqft VIP Door

$30.5
12-52

Table 12.4.49 Product Conversion Costs for Product Class 18 (Compact Chest 

Freezers) by TSL

TSL

Efficiency 

Level (% 

reduction 

from 

baseline 

energy use)

Design Options 

Considered for the 3.4 

Cubic Foot PC 18 Unit

Product

Conversion 

Costs for the 

3.4 Cubic Foot 

PC 18 Unit

2009$ millions

Design Options 

Considered for the 7 

Cubic Foot PC 18 Unit

Product

Conversion 

Costs for the 

7 Cubic Foot 

PC 18 Unit

2009$ millions

TSL 1, 

TSL 2 EL 1 (10)* Increase Compressor EER 

from 3.74 to 4.17 $1.3

Increase Compressor 

EER from 4.50 to 

5.02

$2.3

TSL 3 EL 2 (15)

TSL 1 and 2 Design 

Options +

Increase Compressor EER 

from 4.17 to 4.29

Add 1 inch Insulation to 

Door

$2.8

TSL 1 and 2 Design 

Options +

Increase Compressor 

EER from 5.02 to 

5.27

Add 0.12 inch Insulation 

to Door

$3.6

TSL 4 EL 4 (25)

TSL 3 Design Options +

Remove 1/4 inch 

Insulation from Door

Add 0.75 inch Insulation 

to Cabinet

Add 2.1 sqft VIP in 

Bottom Wall

$8.0

TSL 3 Design Options +

Add 0.63 inch Insulation 

to Door

Add 0.62 inch Insulation 

to Cabinet

$7.4

TSL 5 EL 7 (42)

Remove all previous 

Design Options

Variable Speed 

Compressor

Add 0.75 inch Insulation 

to Door

Add 0.75 inch Insulation 

to Cabinet

Add 2.1 sqft VIP in 

Bottom Wall

Add 3.3 sqft VIP in Door

$8.5

Remove all previous 

Design Options

Variable Speed 

Compressor

Add 0.76 inch Insulation 

to Cabinet

Add 3/4 inch Insulation 

to Door

Add 4.1 sqft VIP to 

Cabinet Bottom

Add 5.1 sqft VIP to Door

$10.4

*Efficiency level for product class 13 and 15 is 15%, efficiency level for product class 14 is 20%, and 

efficiency level for product class 13A is 25%.
12-53

Table 12.4.50 Product Conversion Costs for Product Class 3A-BI (Built-In AllRefrigerators-Automatic Defrost) by TSL

TSL

Efficiency Level 

(% reduction from 

baseline energy 

use)

Design Options Considered for the PC 3ABI Unit

Product Conversion 

Costs for the PC 3A-BI

Unit

2009$ millions

TSL 1 EL 1 (10)

Decrease Both Compressor Capacity (same 

EER)

10% Increase to Condenser Area

Brushless DC Evaporator Fan Upper 

Evaporator

$4.2

TSL 2 EL 2 (15)

TSL 1 Design Options +

Brushless DC Evaporator Fan Lower 

Evaporator

Brushless DC Condenser Fan

$6.2

TSL 3 EL 3 (20)

TSL 2 Design Options +

Full VIP--Upper Door

Partial VIP--Lower Cabinet

$12.2

TSL 4 EL 4 (25)

TSL 3 Design Options +

Full VIP--Lower Cabinet

Full VIP--Upper Cabinet

Upper System Variable Speed Compressor

$14.2

TSL 5 EL 5 (29)

TSL 4 Design Options +

Full VIP--Lower Door

Lower System Variable Speed Compressor

$16.2
12-54

Table 12.4.51 Product Conversion Costs for Product Class 5-BI (Built-In 

Refrigerator-Freezers—Automatic Defrost with Bottom-Mounted Freezer without 

an Automatic Icemaker) by TSL

TSL

Efficiency Level 

(% reduction from 

baseline energy 

use)

Design Options Considered for the PC 5-BI

Unit

Product Conversion 

Costs for the PC 5-BI

Unit

2009$ millions

TSL 1 EL 1 (10)

Decrease FF Compressor Capacity (same 

EER)

10% Increase to Condenser Area

Increase FRZ Compressor EER to 6.26

1.0 sqft VIP--FRZ Door

$12.6

TSL 

2, 

TSL 3

EL 2 (15)

TSL 1 Design Options +

Remove 1.0 sqft VIP -- FZR Door

FRZ Variable Speed Compressor with 

Brushless DC Condenser Fan

$7.7

TSL 4 EL 4 (25)

TSL 2 and 3 Design Options +

14.6 sqft VIP--FRZ Cabinet (Partial Coverage)

Add 3.6 sqft VIP -- FZR Cabinet (Full 

Coverage)

6.0 sqft VIP--FRZ Door (Full Coverage)

FF Variable Speed Compressor with Brushless 

DC Condenser Fan

$15.8

TSL 5 EL 5 (27)

TSL 4 Design Options +

9.4 sqft VIP -- FF Door (Full Coverage)

3.8 sqft VIP -- FF Cabinet (Full Coverage)

$19.1

Table 12.4.52 Product Conversion Costs for Product Class 7-BI (Built-In 

Refrigerator-Freezers—Automatic Defrost with Side-mounted Freezer with 

Through-the-Door Ice Service) by TSL

TSL

Efficiency Level (% 

reduction from 

baseline energy use)

Design Options Considered for PC 7-BI Unit

Product Conversion 

Costs for the PC 7-BI

Unit

2009$ millions

TSL 1, 

TSL 2 EL 1 (10)

High Efficiency Compressor

Heat Exchanger Improvement

Variable Anti-Sweat Heater Control

Partial VIP to Freezer Door

$22.3

TSL 3, 

TSL 4 EL 3 (20)

TSL 1 and 2 Design Options +

Eliminate VIP to Freezer Door

Variable Speed Compressor

VIP to Freezer Door

VIP to Freezer Cabinet

$29.0

TSL 5 EL 4 (22)

TSL 3 and 4 Design Options +

VIP to Fresh Food Cabinet

VIP to Fresh Food Door

$33.5
12-55

Table 12.4.53 Product Conversion Costs for Product Class 9-BI (Built-In Upright 

Freezers with Automatic Defrost Without an Automatic Icemaker) by TSL

TSL

Efficiency Level (% 

reduction from 

baseline energy use)

Design Options Considered for PC 9-BI Unit

Product Conversion 

Costs for the PC 9-BI

Unit

2009$ millions

TSL 1 EL 1 (10) Increase Compressor EER to 6.29 $2.2

TSL 2 EL 3 (20)

TSL 1 Design Options +

Brushless DC Fan for Evaporator

Brushless DC Fan for Condenser

10% Increase to Condenser Area

Variable Speed Compressor with Brushless DC 

Fans

1.5 sqft VIP Upper Door

$14.7

TSL 3, 

TSL 4 EL 4 (25)

TSL 2 Design Options +

VIP Upper Door (Full Coverage)

13.1 sqft VIP Lower Cabinet

$15.9

TSL 5 EL 5 (27)

TSL 3 and 4 Design Options +

VIP Lower Cabinet (Full Coverage)

VIP--Lower Door

VIP--Upper Cabinet

$18.4

12.4.9 Markup Scenarios

DOE used several standards case markup scenarios to represent the uncertainty 

about the impacts of amended energy conservation standards on prices and profitability. 

In the base case, DOE used the same baseline markups calculated in the engineering 

analysis for all product classes. In the standards case, DOE modeled two markup 

scenarios to represent the uncertainty about the potential impacts on prices and 

profitability following the implementation of amended energy conservation standards: (1) 

a flat markup scenario, and (2) a preservation of operation profit scenario. These 

scenarios lead to different markups values, which, when applied to the inputted MPCs, 

result in varying revenue and cash flow impacts.

12.4.9.1 Flat Markup Scenario

The flat markup scenario assumes that the cost of goods sold for each product is 

marked up by a flat percentage to cover standard SG&A expenses, R&D expenses, and 

profit. The flat markup scenario uses the baseline manufacturer markup (discussed in 

chapter 6) for all products in both the base case and the standards case. To derive this 

percentage, DOE evaluated publicly available financial information for manufacturers of 

white goods. DOE also requested feedback on this value during manufacturer interviews.

DOE used a markup of 1.26 for freestanding refrigeration products (standard-size

refrigerator-freezers, standard-size freezers, and compact refrigeration products) and 1.40 

for built-in refrigeration products. This scenario represents the upper bound of industry 
12-56

profitability in the standards case because manufacturers are able to fully pass through 

additional costs due to standards to their customers.

12.4.9.2 Preservation of Operating Profit Scenario

DOE also modeled a lower bound profitability scenario. During interviews, 

multiple manufacturers stated that the higher production costs could severely harm 

profitability. Because of the highly competitive market, several manufacturers suggested 

that the additional costs required at higher efficiencies could not be fully passed through 

to customers. In particular, several manufacturers noted their customer base is composed 

of a limited number of retailers that have substantial buying power and are resistant to 

price increases. They also noted that the average costs of refrigeration products have been 

fairly constant or fallen within product classes even as new products and additional 

features have been added. Finally, manufacturers noted that retail customers price 

products at fixed price points with jumps in feature bundles accounting for the different 

price points.

Because of the market dynamics among manufacturers and retailers and because 

of the pressure to keep the current price points fixed for a given bundle, DOE also 

modeled the preservation of operating profit markup scenario. In this scenario, the 

manufacturer markups are lowered so that, in the standards case, manufacturers are only 

able to maintain the base-case total operating profit in absolute dollars, despite higher 

product costs and investment. DOE implemented this scenario in the GRIM by lowering 

the manufacturer markups at each TSL to yield approximately the same earnings before 

interest and taxes in the standards case in the year after the compliance date of the 

amended standards, as in the base case. This scenario represents the lower bound of 

industry profitability following amended energy conservation standards because higher 

production costs and the investments required to comply with the amended energy 

conservation standard do not yield additional operating profit. 

DOE implemented this scenario by calculating a markup that yielded the same 

EBIT in the base case and the standards case for each product class. For most TSLs, DOE 

only calibrated a lower markup for the efficiency level that was minimally compliant to 

the amended energy conservation standards (since products that exceed the standard 

would not be impacted by the standards). However, for TSLs that analyzed the levels 

recommended in the Joint Comments, shipments for some of the unanalyzed product 

classes corresponded to different percentage reductions in baseline energy use. For these 

TSLs, DOE calculated a markup for each efficiency level impacted by an efficiency level 

that was different than the analyzed product class. Each of these markups maintained the 

base case EBIT for the analyzed product class at the efficiency level recommended by the 

Joint Comments. In this way, amended energy conservation standards would also impact 

the profitability of these products in the preservation of operating profit scenario. 

However, for all TSLs the base case operating profit is maintained as production costs 

rise, leading to profitability impacts in the standard case under the preservation of 

operating profit markup scenario. Table 12.4.54 through Table 12.4.64 lists the products 

DOE analyzed with the corresponding markups at each TSL.
12-57

Table 12.4.54 Preservation of Operating Profit Markups for Product Class 3 

(Automatic Defrost with Top-Mounted Freezer Without Through-the-Door Ice 

Service)

Efficiency Level

(% reduction 

from baseline 

energy use)

Baseline TSL 1 TSL 2 TSL 3* TSL 4 TSL 5

Baseline 

(0) 1.2600 - - - - -

EL 1

(10) 1.2600 - - - - -

EL 2

(15) 1.2600 - - - - -

EL 3

(20) 1.2600 1.2464 1.2464 1.2446 - -

EL 4

(25) 1.2600 1.2600 1.2600 1.2409 - -

EL 5

(30) 1.2600 1.2600 1.2600 1.2600 1.2312 -

EL 6

(36) 1.2600 1.2600 1.2600 1.2600 1.2600 1.2213

*Efficiency level for product classes 1, 1A, and 2 is 20%.

Table 12.4.55 Preservation of Operating Profit Markups for Product Class 5 

(Automatic Defrost with Bottom-Mounted Freezer without Through-the-Door Ice 

Service)

Efficiency Level 

(% reduction 

from baseline 

energy use)

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Baseline 

(0) 1.2600 - - - - -

EL 1

(10) 1.2600 - - - - -

EL 2

(15) 1.2600 - - - - -

EL 3

(20) 1.2600 1.2590 1.2590 1.2590 - -

EL 4

(25) 1.2600 1.2600 1.2600 1.2600 - -

EL 5

(30) 1.2600 1.2600 1.2600 1.2600 1.2433 -

EL 6

(36) 1.2600 1.2600 1.2600 1.2600 1.2600 1.2338
12-58

Table 12.4.56 Preservation of Operating Profit Markups for Product Class 7 

(Automatic Defrost with Side-Mounted Freezer with Through-the-Door Ice Service)

Efficiency Level 

(% reduction 

from baseline 

energy use)

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Baseline 

(0) 1.2600 - - - - -

EL 1

(10) 1.2600 - - - - -

EL 2

(15) 1.2600 - - - - -

EL 3

(20) 1.2600 1.2576 - - - -

EL 4

(25) 1.2600 1.2600 1.2522 1.2522 - -

EL 5

(30) 1.2600 1.2600 1.2600 1.2600 1.2425 -

EL 6

(33) 1.2600 1.2600 1.2600 1.2600 1.2600 1.2364

Table 12.4.57 Preservation of Operating Profit Markups for Product Class 9 

(Upright Freezers with Automatic Defrost)

Efficiency Level 

(% reduction 

from baseline 

energy use)

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Baseline 

(0) 1.2600 - - - - -

EL 1

(10) 1.2600 - - - - -

EL 2

(15) 1.2600 - - - - -

EL 3

(20) 1.2600 1.2510 - - - -

EL 4

(25) 1.2600 1.2600 - - - -

EL 5

(30) 1.2600 1.2600 1.2432 - - -

EL 6

(35) 1.2600 1.2600 1.2600 1.2364 - -

EL 7

(40) 1.2600 1.2600 1.2600 1.2600 1.2288 -

EL 8

(44) 1.2600 1.2600 1.2600 1.2600 1.2600 1.2171
12-59

Table 12.4.58 Preservation of Operating Profit Markups for Product Class 10 

(Chest Freezers and All Other Freezers Except Compact Freezers)

Efficiency Level 

(% reduction 

from baseline 

energy use)

Baseline TSL 1 TSL 2* TSL 3 TSL 4 TSL 5

Baseline 

(0) 1.2600 - - - - -

EL 1

(10) 1.2600 - - - - -

EL 2

(15) 1.2600 - - - - -

EL 3

(20) 1.2600 1.2529 - - - -

EL 4

(25) 1.2600 1.2600 1.2434 - - -

EL 5

(30) 1.2600 1.2600 1.2396 1.2399 - -

EL 6

(35) 1.2600 1.2600 1.2600 1.2600 1.2317 -

EL 7

(41) 1.2600 1.2600 1.2600 1.2600 1.2600 1.2199

*Efficiency level for product class 10A is 30%.
12-60

Table 12.4.59 Preservation of Operating Profit Markups for Product Class 11 

(Compact Refrigerators and Refrigerator-Freezers with Manual Defrost)

Efficiency Level 

(% reduction 

from baseline 

energy use)

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Baseline 

(0) 1.2600 - - - - -

EL 1

(10) 1.2600 - - - - -

EL 2

(15) 1.2600 - - - - -

EL 3

(20) 1.2600 1.2489 - - - -

EL 4

(25) 1.2600 1.2600 1.2422 - - -

EL 5

(30) 1.2600 1.2600 1.2600 1.2378 - -

EL 6

(35) 1.2600 1.2600 1.2600 1.2600 - -

EL 7

(40) 1.2600 1.2600 1.2600 1.2600 1.2253 -

EL 8

(45) 1.2600 1.2600 1.2600 1.2600 1.2600 -

EL 9

(50) 1.2600 1.2600 1.2600 1.2600 1.2600 -

EL 10

(58) 1.2600 1.2600 1.2600 1.2600 1.2600 1.2047
12-61

Table 12.4.60 Preservation of Operating Profit Markups for Product Class 18 

(Compact Chest Freezers)

Efficiency Level 

(% reduction 

from baseline 

energy use)

Baseline TSL 1 TSL 2* TSL 3 TSL 4 TSL 5

Baseline 

(0) 1.2600 - - - - -

EL 1

(10) 1.2600 1.2564 1.2564 - - -

EL 2

(15) 1.2600 1.2600 1.2500 1.2502 - -

EL 3

(20) 1.2600 1.2600 1.2347 1.2600 - -

EL 4

(25) 1.2600 1.2600 1.2318 1.2600 1.2319 -

EL 5

(30) 1.2600 1.2600 1.2600 1.2600 1.2600 -

EL 6

(35) 1.2600 1.2600 1.2600 1.2600 1.2600 -

EL 7

(42) 1.2600 1.2600 1.2600 1.2600 1.2600 1.2121

*Efficiency level for product class 13 and 15 is 15%, efficiency level for product class 14 is 20%, and 

efficiency level for product class 13A is 25%.

Table 12.4.61 Preservation of Operating Profit Markups for Product Class 3A-BI 

(Built-In All-Refrigerators-Automatic Defrost)

Efficiency Level 

(% reduction 

from baseline 

energy use)

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Baseline 

(0) 1.4000 - - - - -

EL 1

(10) 1.4000 1.3997 - - - -

EL 2

(15) 1.4000 1.4000 1.3994 - - -

EL 3

(20) 1.4000 1.4000 1.4000 1.3958 - -

EL 4

(25) 1.4000 1.4000 1.4000 1.4000 1.3909 -

EL 5

(29) 1.4000 1.4000 1.4000 1.4000 1.4000 1.3875
12-62

Table 12.4.62 Preservation of Operating Profit Markups for Product Class 5-BI 

(Built-In Refrigerator-Freezers—Automatic Defrost with Bottom-Mounted Freezer 

without an Automatic Icemaker)

Efficiency Level 

(% reduction 

from baseline 

energy use)

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Baseline 

(0) 1.4000 - - - - -

EL 1

(10) 1.4000 1.3993 - - - -

EL 2

(15) 1.4000 1.4000 1.3987 1.3987 - -

EL 3

(20) 1.4000 1.4000 1.4000 1.4000 - -

EL 4

(25) 1.4000 1.4000 1.4000 1.4000 1.3948 -

EL 5

(27) 1.4000 1.4000 1.4000 1.4000 1.4000 1.3926

Table 12.4.63 Preservation of Operating Profit Markups for Product Class 7-BI 

(Built-In Refrigerator-Freezers—Automatic Defrost with Side-mounted Freezer 

with Through-the-Door Ice Service)

Efficiency Level 

(% reduction 

from baseline 

energy use)

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Baseline 

(0) 1.4000 - - - - -

EL 1

(10) 1.4000 1.3995 1.3995 - - -

EL 2

(15) 1.4000 1.4000 1.4000 - - -

EL 3

(20) 1.4000 1.4000 1.4000 1.3968 1.3968 -

EL 4

(22) 1.4000 1.4000 1.4000 1.4000 1.4000 1.3949
12-63

Table 12.4.64 Preservation of Operating Profit Markups for Product Class 9-BI 

(Built-In Upright Freezers with Automatic Defrost Without an Automatic 

Icemaker)

Efficiency Level 

(% reduction 

from baseline 

energy use)

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Baseline 

(0) 1.4000 - - - - -

EL 1

(10) 1.4000 1.3995 - - - -

EL 2

(15) 1.4000 1.4000 - - - -

EL 3

(20) 1.4000 1.4000 1.3962 - - -

EL 4

(25) 1.4000 1.4000 1.4000 1.3921 1.3921 -

EL 5

(27) 1.4000 1.4000 1.4000 1.4000 1.4000 1.3892

12.4.10 Federal Production Tax Credits

In the GRIM, DOE allows the user to include the estimates of the benefit of the 

Federal production tax credits found in title I section 1334 (c)(1)(B) of the Energy Policy 

Act of 2005 and updated by the Energy Improvement and Extension Act of 2008 (Pub. L. 

No. 110-343). For the results presented in this chapter, DOE included these benefits as a 

direct cash benefit to the industry in 2010. See appendix 12-C for a description of how 

DOE estimated the Federal production tax credits and its impacts on INPV results.

12.5 INDUSTRY FINANCIAL IMPACTS

Using the inputs and scenarios described in the previous sections, the GRIM 

estimated indicators of financial impacts on the residential refrigeration industry. The 

following sections detail additional inputs and assumptions for standard-size refrigeratorfreezers, standard-size freezers, compact refrigeration products, and built-in refrigeration 

products. The main results of the MIA are also reported in this section. The MIA consists 

of two key financial metrics: INPV and annual cash flows.

12.5.1 Introduction

The INPV measures the industry value and is used in the MIA to compare the 

economic impacts of different TSLs in the standards case. The INPV is different from 

DOE’s net present value, which is applied to the U.S. economy. The INPV is the sum of 

all net cash flows discounted at the industry’s cost of capital, or discount rate. The 

residential refrigeration products GRIM estimates cash flows from 2010 to 2043. This 

timeframe models both the short-term impacts on the industry from the announcement of 

the standard until the compliance date (2010 until an estimated compliance date of 
12-64

January 2014) and a long-term assessment over the 30 year analysis period used in the 

NIA (2014 – 2043).

In the MIA, DOE compares the INPV of the base case (no amended energy 

conservation standards) to that of each TSL in the standards case. The difference between 

the base case and a standards case INPV is an estimate of the economic impacts that 

implementing that particular TSL would have on the industry. For the residential 

refrigeration industry, DOE examined the two markup scenarios described above: the flat 

markup and the preservation of operating profit.While INPV is useful for evaluating the 

long-term effects of amended energy conservation standards, short-term changes in cash 

flow are also important indicators of the industry’s financial situation. For example, a 

large investment over one or two years could strain the industry’s access to capital. 

Consequently, the sharp drop in financial performance could cause investors to flee, even 

though recovery may be possible. Thus, a short-term disturbance can have long-term 

effects that the INPV cannot capture. To get an idea of the behavior of annual net cash 

flows, Figure 12.5.1 through Figure 12.5.8 below present the annual net or free cash 

flows from 2010 through 2024 for the base case and different TSLs in the standards case. 

Because the same markup scenarios are used for each group of refrigeration 

products, each of the figures below has a similar shape. Annual cash flows are discounted 

to the base year, 2010. Between 2010 and the 2014 compliance date of the amended 

energy conservation standard, cash flows are driven by the level of conversion costs and 

the proportion of these investments spent every year. After the standard announcement 

date (i.e., the publication date of the final rule), industry cash flows begin to decline as 

companies use their financial resources to prepare for the amended energy conservation 

standard. The more stringent the amended energy conservation standard, the greater the 

impact on industry cash flows in the years leading up to the compliance date, as product 

conversion costs lower cash inflows from operations and capital conversion costs 

increase cash outflows for capital expenditures. 

Free cash flow in the year the amended energy conservation standards take effect 

is driven by two competing factors. In addition to capital and product conversion costs, 

amended energy conservation standards could create stranded assets, i.e., tooling and 

equipment that would have enjoyed longer use if the energy conservation standard had 

not made them obsolete. In this year, manufacturers write down the remaining book value 

of existing tooling and equipment whose value is affected by the amended energy 

conservation standard. This one time write down acts as a tax shield that alleviates 

decreases in cash flow from operations in the year of the write-down. In this year, there is 

also an increase in working capital that reduces cash flow from operations. A large 

increase in working capital is needed due to more costly production components and 

materials, higher inventory carrying to sell more expensive products, and higher accounts 

receivable for more expensive products. Depending on these two competing factors, cash 

flow can either be positively or negatively affected in the year the standard takes effect. 

In the years following the compliance date of the standard, the impact on cash 

flow depends on the operating revenue. More stringent TSLs typically have a positive 

impact on cash flows relative to the base case under the flat markup scenario because 
12-65

manufacturers are able to earner higher operating profit at each TSL in the standards 

case, which increases cash flow from operations. There is very little impact on cash flow 

from operations under the preservation of operating profit scenario because this scenario 

is calibrated to have the same operating income in the standards case at each TSL as the 

base case as in the year after the standard takes effect. In this scenario, the industry value 

is impacted because production costs increase, but operating profit remains 

approximately equal to the base case which decreases profit margins as a percentage of 

revenue.

12.5.2 Industry Financial Impacts

Table 12.5.1 through Table 12.5.8 provide the INPV estimates for the residential 

refrigeration industry. Figure 12.5.1 through Figure 12.5.8 present the annual net cash 

flows for standard-size refrigerator-freezers, standard-size freezers, compact refrigeration 

products, and built-in refrigeration products under each markup scenario.

Table 12.5.1 Changes in Industry Net Present Value for Standard-Size RefrigeratorFreezers (Flat Markup Scenario)

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009$

millions) 3,173 3,088 2,997 2,886 2,530 2,344 

Change 

in INPV

(2009$

millions) - (84.8) (175.9) (287.5) (643.0) (828.9)

(%) - -2.7% -5.5% -9.1% -20.3% -26.1%

*For tables in section 12.5.2, values in parenthesis indicate negative numbers 

Table 12.5.2 Changes in Industry Net Present Value for Standard-Size RefrigeratorFreezers (Preservation of Operating Profit Markup Scenario)

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009$

millions) 3,173 2,871 2,713 2,511 1,676 1,018 

Change 

in INPV

(2009$

millions) - (301.7) (459.8) (662.1) (1,496.8) (2,154.7)

(%) - -9.5% -14.5% -20.9% -47.2% -67.9%
12-66

Figure 12.5.1 Annual Industry Net Cash Flows for Standard-Size RefrigeratorFreezers (Flat Markup Scenario)

Figure 12.5.2 Annual Industry Net Cash Flows for Standard-Size RefrigeratorFreezers (Preservation of Operating Profit Markup Scenario)

-800.00

-600.00

-400.00

-200.00

0.00

200.00

400.00

600.00

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

2009$ Millions

Year

Net Cash Flow Totals

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Markup Scenario: 

Energy Conservation 

Standards Compliance Date

January 2014

Flat Markup Selected Products: Standard-Size RefrigeratorFreezers

-800.00

-600.00

-400.00

-200.00

0.00

200.00

400.00

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

2009$ Millions

Year

Net Cash Flow Totals

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Markup Scenario: 

Energy Conservation 

Standards Compliance Date

January 2014

Preservation of 

Operating Profit Selected Products: Standard-Size RefrigeratorFreezers
12-67

Table 12.5.3 Changes in Industry Net Present Value for Standard-Size Freezers 

(Flat Markup Scenario)

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009$

millions) 403 378 292 308 344 300 

Change 

in INPV

(2009$

millions) - (24.9) (110.6) (94.5) (59.0) (102.4)

(%) - -6.2% -27.5% -23.5% -14.6% -25.4%

Table 12.5.4 Changes in Industry Net Present Value for Standard-Size Freezers

(Preservation of Operating Profit Markup Scenario)

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009$

millions) 403 345 217 202 184 37 

Change 

in INPV

(2009$

millions) - (57.3) (186.0) (201.1) (218.9) (365.1)

(%) - -14.2% -46.2% -49.9% -54.4% -90.7%

Figure 12.5.3 Annual Industry Net Cash Flows for Standard-Size Freezers (Flat

Markup Scenario)

-140.00

-120.00

-100.00

-80.00

-60.00

-40.00

-20.00

0.00

20.00

40.00

60.00

80.00

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

2009$ Millions

Year

Net Cash Flow Totals

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Markup Scenario: 

Energy Conservation 

Standards Compliance Date

January 2014

Flat Markup Selected Products: Standard-Size Freezers
12-68

Figure 12.5.4 Annual Industry Net Cash Flows for Standard-Size Freezers

(Preservation of Operating Profit Markup Scenario)

Table 12.5.5 Changes in Industry Net Present Value for Compact Refrigeration 

Products (Flat Markup Scenario)

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009$

millions) 200 185 169 143 170 67 

Change 

in INPV

(2009$

millions) - (14.3) (30.8) (56.8) (29.6) (133.0)

(%) - -7.2% -15.4% -28.4% -14.8% -66.6%

Table 12.5.6 Changes in Industry Net Present Value for Compact Refrigeration 

Products (Preservation of Operating Profit Markup Scenario)

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009$

millions) 200 168 133 101 85 (96)

Change 

in INPV

(2009$

millions) - (32.1) (66.7) (99.2) (114.4) (295.6)

(%) - -16.1% -33.4% -49.6% -57.3% -148.0%

-140.00

-120.00

-100.00

-80.00

-60.00

-40.00

-20.00

0.00

20.00

40.00

60.00

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

2009$ Millions

Year

Net Cash Flow Totals

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Markup Scenario: 

Energy Conservation 

Standards Compliance Date

January 2014

Preservation of 

Operating Profit Selected Products: Standard-Size Freezers
12-69

Figure 12.5.5 Annual Industry Net Cash Flows for Compact Refrigeration Products

(Flat Markup Scenario)

Figure 12.5.6 Annual Industry Net Cash Flows for Compact Refrigeration Products

(Preservation of Operating Profit Markup Scenario)

-120.00

-100.00

-80.00

-60.00

-40.00

-20.00

0.00

20.00

40.00

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

2009$ Millions

Year

Net Cash Flow Totals

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Markup Scenario: 

Energy Conservation 

Standards Compliance Date

January 2014

Flat Markup Selected Products: Compact Refrigeration Products

-120.00

-100.00

-80.00

-60.00

-40.00

-20.00

0.00

20.00

40.00

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

2009$ Millions

Year

Net Cash Flow Totals

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Markup Scenario: 

Energy Conservation 

Standards Compliance Date

January 2014

Preservation of 

Operating Profit Selected Products: Compact Refrigeration Products
12-70

Table 12.5.7 Changes in Industry Net Present Value for Built-In Refrigeration 

Products (Flat Markup Scenario)

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009$

millions) 658 607 604 593 579 574 

Change 

in INPV

(2009$

millions) - (51.7) (54.7) (65.8) (79.7) (84.9)

(%) - -7.9% -8.3% -10.0% -12.1% -12.9%

Table 12.5.8 Changes in Industry Net Present Value for Built-In Refrigeration 

Products (Preservation of Operating Profit Markup Scenario)

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009$

millions) 658 606 601 578 555 538 

Change 

in INPV

(2009$

millions) - (52.9) (57.0) (80.5) (103.0) (120.3)

(%) - -8.0% -8.7% -12.2% -15.6% -18.3%

Figure 12.5.7 Annual Industry Net Cash Flows for Built-In Refrigeration Products

(Flat Markup Scenario)

-20.00

-10.00

0.00

10.00

20.00

30.00

40.00

50.00

60.00

70.00

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

2009$ Millions

Year

Net Cash Flow Totals

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Markup Scenario: 

Energy Conservation 

Standards Compliance Date

January 2014

Flat Markup Selected Products: Built-In Refrigeration Products
12-71

Figure 12.5.8 Annual Industry Net Cash Flows for Built-In Refrigeration Products

(Preservation of Operating Profit Markup Scenario)

12.6 IMPACTS ON SMALL RESIDENTIAL REFRIGERATION

MANUFACTURERS

DOE conducted a more focused inquiry of the companies that could be small 

business manufacturers of products covered by this rulemaking. During its market 

survey, DOE used all available public information to identify potential small 

manufacturers. DOE’s research involved industry trade association membership 

directories (including AHAM), product databases (e.g.

DOE initially identified at least 65 distinct brands of residential refrigeration 

products sold in the U.S. by 47 parent companies. Out of these 47 companies, DOE 

determined that the majority (31 of 47) were distributors or sold branded products (were 

not the original equipment manufacturer). Of the 16 manufacturers, DOE found 15 to 

, FTC, The Thomas Register, 

CEC, and ENERGY STAR databases), individual company websites, and marketing 

research tools like Dun and Bradstreet reports to create a list of every company that 

manufactures or sells residential refrigeration products covered by this rulemaking. DOE 

also asked stakeholders and industry representatives if they were aware of any other 

small manufacturers during manufacturer interviews and at previous DOE public 

meetings. DOE reviewed all publicly-available data and contacted select companies on its 

list, as necessary, to determine whether they met the SBA’s definition of a small business 

manufacturer of covered residential refrigeration products. DOE screened out companies 

that did not offer products covered by this rulemaking, did not meet the definition of a 

“small business,” or are foreign owned and operated. 

-20.00

-10.00

0.00

10.00

20.00

30.00

40.00

50.00

60.00

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

2009$ Millions

Year

Net Cash Flow Totals

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Markup Scenario: 

Energy Conservation 

Standards Compliance Date

January 2014

Preservation of 

Operating Profit Selected Products: Built-In Refrigeration Products
12-72

exceed the SBA’s size limit or were foreign-owned and operated. Thus, DOE identified 

one small residential refrigeration product manufacturer that produces covered products 

and can be considered a small business. 

Based on its market research, the one small business manufacturer of residential 

refrigeration products identified by DOE is a niche manufacturer that produces premium 

undercounter units. Undercounter refrigerator and freezers are high-end products that are 

meant to be either freestanding or recessed. The small business manufacturer identified 

by DOE primarily manufactures products that are covered by this rulemaking, such as 

undercounter refrigerators and refrigerator-freezers, plus several products outside of the 

scope of coverage for this rulemaking, such as ice makers and wine coolers. However, 

most compact refrigeration products are imported with market share split among multiple 

domestic and foreign manufacturers. Several manufacturers who still produce compact 

products domestically focus on the premium niche market of undercounter refrigerators 

and freezers. 

DOE did not conduct a more in-depth analysis of the potential impacts on small 

business manufacturers because only one small business manufacturer would potentially 

be impacted by the proposed energy conservation standards. In addition, that 

manufacturer would not likely be differentially harmed by the proposed energy 

conservation standards compared to its most direct competitors. The small business 

manufacturer has the largest market share of undercounter refrigerator and freezers. Since 

undercounter units are a very small segment of compact refrigerators and freezers, the 

small business manufacturer is the market leader of a very small segment of compact 

products. Many of the other undercounter manufacturers, while not technically small 

businesses by the SBA definition, also have low overall production volumes. Finally, the 

undercounter market is a niche market that does not compete with overall compact 

refrigeration sales. Undercounter products are luxury items purchased by consumers that 

typically are less concerned about first costs compared to purchasers of other residential 

refrigeration products. While most compact sales are inexpensive products with retail 

prices in the low hundreds of dollars, undercounter products typically cost many times 

that. While this niche market is small, the much higher sales price and lower volumes 

indicate that profit margins could be higher than the industry average. 

12.7 OTHER IMPACTS

12.7.1 Employment

12.7.1.1 Methodology

To quantitatively assess the impacts of amended energy conservation standards on 

residential refrigeration manufacturing employment, DOE used the GRIM to estimate the 

domestic labor expenditures and number of domestic production workers in the base case 

and at each TSL from 2010 to 2043. DOE used statistical data from the most recent U.S. 

Census Bureau’s 2007 Economic Census, the results of the engineering analysis, and 

interviews with manufacturers to determine the inputs necessary to calculate industrywide labor expenditures and domestic employment levels. Labor expenditures involved 
12-73

with the manufacture of the product are a function of the labor intensity of the product, 

the sales volume, and an assumption that wages remain fixed in real terms over time.

In the GRIM, DOE used the labor content of each product and the MPCs from the 

engineering analysis to estimate the annual labor expenditures for each product grouping. 

In the GRIMs, the labor expenditures in each year are calculated by multiplying the 

MPCs by the labor percentage of each product from the engineering analysis. DOE used 

Census data and interviews with manufacturers to estimate the portion of the total labor 

expenditures that is attributable to U.S. (i.e.

The estimates of production workers in this section only cover workers up to the 

line-supervisor level that are directly involved in fabricating and assembling a product 

within the Original Equipment Manufacturer (OEM) facility. Workers that perform 

services that are closely associated with production operations, such as material handing 

with a forklift, are also included as production labor. DOE’s estimates only account for 

production workers who manufacture the specific products covered by this rulemaking. 

For example, a worker on a wine cooler line would not be included with the estimate of 

the number of residential refrigeration workers.

, domestic) labor. 

DOE multiplied the total annual labor expenditures in the GRIM by the 

percentage of U.S. production for domestic consumption to calculate domestic labor 

expenditures for production labor in each industry. The domestic annual labor 

expenditures in the GRIM were converted to domestic production employment levels by 

dividing production labor expenditures by the annual payment per production worker 

(production worker hours times the labor rate found in the 2007 ASM).

e

DOE calculated the domestic annual labor expenditures and employment levels 

for the base case and at each TSL. The impacts on domestic employment due to standards 

can be assessed by comparing the employment results in the base case to the results at 

each TSL. In the GRIM analyses, the estimates shown are the maximum potential 

employment in the industry because they assume manufacturers would continue to 

produce the same scope of covered products in the same production facilities. 

Consequently, the upper bound of the employment impacts calculated in the GRIM 

assumes that domestic production is not shifted to lower-labor-cost countries. Because 

there is a real risk of manufacturers exiting the market or no longer offering the same 

scope of covered products in response to amended energy conservation standards, the 

lower end of the range of employment results in this section include the estimate of the 

total number of U.S. production workers in the industry that could lose their jobs if all 

existing production were to no longer be made domestically. Consequently, the lower 

DOE calculated 

the number of non-production employees by multiplying the number of production 

workers by the ratio of non-production workers to production workers calculated using 

the employment data in the 2007 ASM.

e The labor rates and production hours per year per employee found in the Census Bureau’s 2007 report are 

similar to figures reported in the engineering analysis. DOE used 2007 ASM figures to ensure a consistent 

set of publicly available data for the manufacturing employment analysis. 
12-74

bound of the potential negative employment analysis does not account for some 

manufacturers’ dependence on the total production volume of all products produced in a 

facility to achieve an adequate scale. For example, should a standard-size refrigeratorfreezers manufacturer move part of its production abroad, its domestic production facility 

may no longer have the manufacturing scale to get volume discounts on its purchases or 

be able to justify maintaining major capital equipment. Thus, the impact on a 

manufacturing facility due to a line closure can affect far more employees than just the 

production workers directly associated with a covered product.

While the results present a range of employment impacts following the 

compliance date of amended energy conservation standards, the discussion below also 

includes a qualitative discussion of the likelihood of negative employment impacts at the 

various TSLs.

12.7.1.2 Standard-Size Refrigerator-Freezers Employment Impacts

The GRIM forecasts the standard-size refrigerator-freezers domestic labor 

expenditure for production labor in 2014 will be approximately $322 million. Using the 

$18.60 wage rate and 2,032 production hours per year per employee found in the 2007 

ASM, the GRIM estimates there will be approximately 8,517 domestic production 

employees involved in manufacturing standard-size refrigerator-freezers covered by this 

rulemaking. In addition, DOE estimates that 1,113 non-production employees in the 

United States will support standard-size refrigerator-freezers production.f

Table 12.7.1

The 

employment spreadsheet of the GRIM shows the annual domestic employment impacts in 

further detail. Approximately 42 percent of standard-size refrigerator-freezers sold in the 

United States are manufactured domestically.

illustrates the range of potential impacts of amended energy 

conservation standards on domestic production employment levels at each TSL for the 

standard-size refrigerator-freezers market.

f As defined in the 2007 ASM, production workers number include “workers (up through the linesupervisor level) engaged in fabricating, processing, assembling, inspecting, receiving, storing, 

handling, packing, warehousing, shipping (but not delivering), maintenance, repair, janitorial and 

guard services, product development, auxiliary production for plant's own use (e.g., power plant), 

recordkeeping, and other services closely associated with these production operations at the 

establishment covered by the report. Employees above the working-supervisor level are excluded 

from this item.” Non-production workers are defined as “employees of the manufacturing 

establishment including those engaged in factory supervision above the line-supervisor level. It 

includes sales (including driver-salespersons), sales delivery (highway truck drivers and their 

helpers), advertising, credit, collection, installation and servicing of own products, clerical and 

routine office functions, executive, purchasing, financing, legal, personnel (including cafeteria, 

medical, etc.), professional, and technical employees. Also included are employees on the payroll of 

the manufacturing establishment engaged in the construction of major additions or alterations utilized 

as a separate work force.” 
12-75

Table 12.7.1 Potential Changes in the Total Number of Domestic Standard-Size 

Refrigerator-Freezers Production Workers in 2014

Trial Standard Level

Base Case 1 2 3 4 5

Total Number of Domestic 

Production Workers in 

2014 (without changes in 

production locations)

8,517 8,300 8,258 8,309 8,236 8,088

Potential Changes in 

Domestic Production 

Workers in 2014*

- (217) -

(8,517)

(259) -

(8,517)

(208) -

(8,517)

(281) -

(8,517)

(429) -

(8,517)

*DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative 

numbers.

Figure 12.7.1 below shows total annual domestic employment levels for each TSL 

calculated by the GRIM.

Figure 12.7.1 Total Standard-Size Refrigerator-Freezers Industry Domestic 

Employment by Year

All examined TSLs show relatively minor impacts on domestic employment 

levels at the lower end of the range. Most of the design options used in the engineering 

analysis involve the swapping of components in baseline units with more efficient parts 

for top-mounted, side-by-side, and bottom-mounted refrigerator-freezers. These 

component swaps for these design options add primarily material costs and do not greatly 

impact the labor content of the baseline products. The relatively small decreases in 

domestic production employment for the lower end of the range of the employment 

impacts arise from higher product prices lowering shipments the year the standard 

0 

2,000 

4,000 

6,000 

8,000 

10,000 

12,000 

14,000 

16,000 

18,000 

Total Domestic Employment (# of workers)

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Energy Conservation 

Standards Compliance Date

January 2014
12-76

becomes effective. At these higher TSLs, the effects of lower shipments more than offset 

the additional product labor that is required to manufacture products that use VIP panels. 

During interviews, manufacturers indicated that their domestic employment levels 

could be impacted under two scenarios: (1) the widespread adoption of VIPs or (2) 

significant capital conversion costs that would force them to consider non-domestic 

manufacturing locations once the compliance date for the amended energy conservation 

standards arrive. The widespread adoption of VIPs would increase the labor content of 

today’s products. The labor content of products with VIPs increases because of the extra 

handling steps that would be required to ensure that VIPs are not damaged during 

production. Because of the competitive nature of the industry, manufacturers believed the 

extra labor costs could force them to move their remaining domestic production to 

Mexico to take advantage of the cheaper labor. 

Manufacturers also indicated that large conversion costs would likely force them 

to consider investing in lower-labor-cost countries. For most product categories, there is a 

range of efficiency levels that can be met with relatively low-cost components (as 

analyzed in the engineering analysis). Beyond these levels, manufacturers would need to 

decide to follow the MPC design options analyzed in the engineering analysis for each 

product category. Manufacturers indicated the analyzed design options the use multiple 

VIPs would involve significant capital conversion costs and add very large material cost 

to their products and would likely result in relocation. However, manufacturers indicated 

they would face even larger capital conversion costs at lower efficiencies if they 

redesigned their products with thicker walls. While not analyzed as a design option for 

standard-size refrigerator-freezers, increasing wall thickness would likely result in 

moving domestic production outside of the U.S. at lower efficiency levels. 

12.7.1.3 Standard-Size Freezers Employment Impacts

The GRIM calculates that the standard-size freezers domestic labor expenditure 

for production labor in 2014 will be approximately $72 million. Using the $18.60 wage 

rate and 2,032 production hours per year per employee found in the 2007 ASM, the 

GRIM estimates there will be approximately 1,904 U.S. production employees involved 

in manufacturing standard-size freezers covered by this rulemaking. In addition, DOE 

estimates that 249 non-production employees in the United States will support standardsize freezers production and manufacturer sales. The employment spreadsheet of the

GRIM shows the annual domestic employment impacts in further detail. Approximately 

80 percent of standard-size freezers sold in the United States are manufactured 

domestically.

Table 12.7.2 illustrates the range of potential impacts of amended energy 

conservation standards on domestic production employment levels at each TSL for the 

standard-size freezers market.
12-77

Table 12.7.2 Potential Changes in the Total Number of Domestic Standard-Size 

Freezers Production Workers in 2014

Trial Standard Level 

Base Case 1 2 3 4 5

Total Number of 

Domestic Production 

Workers in 2014

(without changes in 

production locations)

1,904 1,850 1,781 1,734 1,634 1,508

Potential Changes in 

Domestic Production 

Workers in 2014*

- (54) -

(1,904)

(123) -

(1,904)

(170) -

(1,904)

(270) -

(1,904)

(396) -

(1,904)

*DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative 

numbers. 

Figure 12.7.2 below shows total annual domestic employment levels for each TSL 

calculated by the GRIM.

Figure 12.7.2 Total Standard-Size Freezers Industry Domestic Employment by Year

Similar to standard-size refrigerator-freezers, there are relatively small decreases 

in employment at the lower end of the range of employment impacts. These slight 

declines are caused by higher prices that drive lower shipments once manufacturers must 

meet the amended energy conservation standard. Standard-size freezers manufacturers 

also indicated that domestic production could be shifted abroad any efficiency level that 

required large capital conversion costs. At TSL 1, DOE does not expect substantial 

changes to domestic employment in the standard-size freezer market if manufacturers use 

the design options listed in the engineering analysis to reach the efficiency requirements 

at this TSL. However, at TSL 2 through TSL 5, manufacturers indicated that there could 

0 

500 

1,000 

1,500 

2,000 

2,500 

3,000 

3,500 

4,000 

Total Domestic Employment (# of workers)

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Energy Conservation 

Standards Compliance Date

January 2014
12-78

be domestic employment impacts depending on the design pathway used to reach the 

required efficiencies. At TSL 2 and above, the engineering analysis assumes that 

manufacturers would have to use wall thickness changes to reach the required 

efficiencies. Manufacturers indicated that because these products are typically low-end, 

they would likely follow the design pathways in the engineering analysis and increase the 

wall insulation thickness to reach higher efficiencies in order to avoid having to pass 

large price increases on to consumers. While this would result in extremely large 

conversion costs and would more likely lead to manufacturers moving production 

offshore, manufacturers believed this strategy would help to maintain sales volumes.

12.7.1.4 Compact Refrigeration Products Employment Impacts

DOE’s research suggests that a limited percentage of compact refrigerators and 

refrigerator-freezers are made domestically. The overwhelming majority of products are 

imported. Manufacturers with domestic manufacturing facilities tend to source or import 

their compact products. The small employment numbers are mostly from remaining 

domestic production of compact chest freezers. As a result, amended energy conservation 

standards for compact refrigerators or refrigerator-freezers are unlikely to noticeably alter 

domestic employment levels. 

Table 12.7.3 illustrates the range of potential impacts of amended energy 

conservation standards on domestic production employment levels at each TSL for the 

compact refrigeration products market.

Table 12.7.3 Potential Changes in the Total Number of Domestic Compact 

Refrigeration Products Production Workers in 2014

Trial Standard Level 

Base

Case

1 2 3 4 5

Total Number of 

Domestic Production 

Workers in 2014

(without changes in 

production locations)

31 30 29 29 28 46 

Potential Changes in 

Domestic Production 

Workers in 2014*

- (1) -

(31)

(2) -

(31)

(2) -

(31)

(3) -

(31) 15 - (31)

*DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative 

numbers.

Figure 12.7.3 below shows total annual domestic employment levels for each TSL 

calculated by the GRIM.
12-79

Figure 12.7.3 Total Compact Refrigeration Products Industry Domestic 

Employment by Year

12.7.1.5 Built-In Refrigeration Products Employment Impacts

The GRIM forecasts the built-in refrigeration products domestic labor expenditure 

for production labor in 2014 will be approximately $50 million. Using the $18.60 wage 

rate and 2,032 production hours per year per employee found in the 2007 ASM, the 

GRIM estimates there will be approximately 1,320 U.S. production employees involved 

in manufacturing built-in refrigeration products covered by this rulemaking. In addition, 

DOE estimates that 173 non-production employees in the United States will support 

built-in refrigeration products production. The employment spreadsheet of the GRIM 

shows the annual domestic employment impacts in further detail. Approximately 94

percent of built-in refrigeration products sold in the United States are manufactured 

domestically.

Table 12.7.4 illustrates the range of potential impacts of amended energy 

conservation standards on domestic production employment levels at each TSL for the 

built-in refrigeration products market.

0 

20 

40 

60 

80 

100 

120 

Total Domestic Employment (# of workers)

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Energy Conservation 

Standards Compliance Date

January 2014
12-80

Table 12.7.4 Potential Changes in the Total Number of Domestic Built-In 

Refrigeration Products Production Workers in 2014

Trial Standard Level

Base 

Case

1 2 3 4 5

Total Number of 

Domestic Production 

Workers in 2014 (without 

changes in production 

locations)

1,320 1,320 1,319 1,327 1,331 1,357

Potential Changes in 

Domestic Production 

Workers in 2014*

- 0 -

(1,320)

(1) -

(1,320)

7 -

(1,320)

11 -

(1,320)

37 -

(1,320)

*DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative 

numbers.

Figure 12.7.4 below shows total annual domestic employment levels for each TSL 

calculated by the GRIM.

Figure 12.7.4 Total Built-In Refrigeration Products Industry Domestic Employment 

by Year

Employment in the built-in refrigeration market follows a pattern similar to that 

seen in the market for standard-size refrigerator-freezers and standard-size freezers at 

lower TSLs. At TSL 1 and TSL 2, higher prices result in fewer shipments, and a 

consequent reduction in labor expenditures that more than offsets the additional labor 

required to manufacturer products with VIPs. However, at TSL 3 and above, the use of 

additional VIPs in built-in refrigeration products requires enough additional labor to 

cause a slight increase in the number of domestic production workers. Because built-in 

0 

500 

1,000 

1,500 

2,000 

2,500 

3,000 

Total Domestic Employment (# of workers)

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Energy Conservation 

Standards Compliance Date

January 2014
12-81

products are high-end products with far fewer shipments, it is less likely that 

manufacturers would chose to move all production facilities in response to amended 

energy conservation standards. The higher margins and profit earned in this market also 

make it more likely that manufacturers could earn a return on the investments required to 

reach the amended energy conservation standards and invest in existing facilities rather 

than move production.

12.7.2 Production Capacity

Manufacturers indicated that design changes involving thicker walls or multiple 

VIP panels would require substantial changes to their current manufacturing process. 

While these technologies would require the purchase of millions of dollars of production 

equipment, most manufacturers indicated they could likely make the required changes in 

between the announcement of the final rule and compliance date of an amended energy 

conservation standard. For most product classes, the design changes and investments 

required by the proposed rule are similar in magnitude to the introduction of a new 

product line. Manufacturers have experience with the design options involving VIPs, but 

not at the scale that would be required if the proposed rule’s provisions are adopted. The 

primary capacity concern of manufacturers is the ability of their suppliers, particularly 

manufacturers of VIPs and more efficient compressors, to ramp up production in time to 

meet the amended energy conservation standard. DOE analyzed VIP supply in appendix

4-A.

12.7.3 Cumulative Regulatory Burden 

While any one regulation may not impose a significant burden on manufacturers, 

the combined effects of several impending regulations may have serious consequences 

for some manufacturers, groups of manufacturers, or an entire industry. Assessing the 

impact of a single regulation may overlook this cumulative regulatory burden. For the 

cumulative regulatory burden analysis, DOE looks at other significant product-specific 

regulations that could affect residential refrigeration manufacturers that will take effect 3 

years before or after the compliance date of amended energy conservation standards for 

these products.g

12.7.3.3

In addition to the amended energy conservation regulations on 

residential refrigeration products, several other Federal regulations apply to these 

products and other equipment produced by the same manufacturers. While the cumulative 

regulatory burden focuses on the impacts on manufacturers of other Federal 

requirements, DOE also has described a number of other regulations in section 

because it recognizes that these regulations also impact the products covered by this 

rulemaking.

Companies that produce a wide range of regulated products may be faced with 

more capital and product development expenditures than competitors with a narrower 

scope of products. Regulatory burdens can prompt companies to exit the market or reduce 

g The compliance date for residential refrigeration products is 3 years from the date of publication of the 

final rule (approximately January 2014). 
12-82

their product offerings, potentially reducing competition. Smaller companies in particular 

can be affected by regulatory costs since these companies have lower sales volumes over 

which they can amortize the costs of meeting new regulations. A proposed standard is not 

economically justified if it contributes to an unacceptable level of cumulative regulatory 

burden. 

12.7.3.1 DOE Regulations for Other Products Produced by Residential 

Refrigeration Manufacturers

In addition to the amended energy conservation standards on residential 

refrigeration products, several other Federal regulations and pending regulations apply to 

other products produced by the same manufacturers. DOE recognizes that each regulation 

can significantly affect a manufacturer’s financial operations. Multiple regulations 

affecting the same manufacturer can quickly strain manufacturers’ profits and possibly 

cause an exit from the market. Table 12.7.5 lists the other DOE energy conservation 

standards that could also affect manufacturers of residential refrigeration products in the 

3 years leading up to and after the compliance date of amended energy conservation 

standards for these products. 
12-83

Table 12.7.5 Other DOE and Federal Actions Affecting the Residential 

Refrigeration Industry

Regulation

Approximate 

Compliance 

Date*

Number of Impacted 

Companies from the Market 

and Technology Assessment 

(MTA) (See Chapter 3)

Estimated Total 

Industry 

Conversion Costs

ASHRAE Products 2012 1 N/A

Packaged Terminal Air 

Conditioners and Packaged 

Terminal Heat Pumps 2012 5

$17.3 million 

(2007$)h

Cooking Products 2012 13

$22.6 million 

(2006$)i

Residential Boilers 2012 0 N/A†

General Service 

Fluorescent Lamps and 

Incandescent Reflector 

Lamps 2012 2

$363.1 million 

(2008$)j

Dehumidifiers 2012 5 N/A†††

Beverage Vending 

Machines 2012 1

$14.5 million 

(2008$)k

Commercial Clothes 

Washers 2013 4

$20.4 million 

(2008$)l

Direct Heating Equipment 2013 0

$5.39 million 

(2009$)m

h Estimated industry conversion expenses were published in the TSD for the October 2008 packaged 

terminal air conditioners and packaged terminal heat pumps final rule. 73 FR 58772. The TSD for the 2008

packaged terminal air conditioners and packaged terminal heat pumps final rule can be found at 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/ptacs_pthps_final_tsd.html. i

Estimated industry conversion expenses were published in the TSD for the April 2009 residential cooking 

products final rule. 74 FR 16040. The TSD for the 2009 residential cooking products final rule can be 

found at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/cooking_products_final_rule_tsd.ht

ml. j

Estimated industry conversion expenses were published in the TSD for the July 2009 general service 

fluorescent lamps and incandescent reflector lamps final rule. 74 FR 34080. The TSD for the 2009 lamps

final rule can be found at

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

l_rule_tsd.html. k Estimated industry conversion expenses were published in the TSD for the August 2009 beverage vending 

machines final rule. 74 FR 44914. The TSD for the 2009 beverage vending machines final rule can be 

found at

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

d.html. l

Estimated industry conversion expenses were published in the TSD for the January 2010 commercial 

clothes washers final rule. 75 FR 1122. The TSD for the 2010 commercial clothes washers final rule can be 

found at

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

sd.html

m Estimated industry conversion expenses were published in the TSD for the April 2010 heating products 

final rule. 75 FR 20112. The TSD for the 2010 heating products final rule can be found at

http://www1.eere.energy.gov/buildings/appliance_standards/residential/heating_products_fr_tsd.html.
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Residential Pool Heaters 2013 0

$0.3 million 

(2009$)n

Battery Chargers and 

External Power Supplies 2013* 4 N/A††

Room Air Conditioners 2014* 9 N/A††

Residential Clothes Dryers 2014* 9 N/A††

Fluorescent Lamp Ballasts 2014* 2 N/A††

Walk-In Freezers and 

Coolers 2015* 0 N/A††

Metal Halide Lamp 

Fixtures 2015* 0 N/A††

Residential Clothes 

Washers 2015* 10 N/A††

Small Electric Motors 2015 0

$51.2 million 

(2009$)o

Residential Water Heaters 2015 2

$95.9 million 

(2009$)p

Commercial Electric 

Motors 2015* 2 N/A††

Residential Furnaces 2015* 2 N/A††

Commercial Distribution 

Transformers 2016* 2 N/A††

Commercial Refrigeration 

Equipment 2016* 1 N/A††

Residential Central Air 

Conditioners 2016* 3 N/A††

*The dates listed are an approximation. The exact dates are pending final DOE action.

† Energy conservation standards and compliance dates for residential boilers can be found at 10 CFR 

430.32(e)(2)(ii)-(iv). 

†† For energy conservation standards for rulemakings awaiting DOE final action, DOE does not have a 

finalized estimated total industry conversion cost. 

††† For minimum performance requirements prescribed by the Energy Independence and Security Act of 

2007 (EISA 2007), DOE did not estimate total industry conversion costs because an MIA was not 

completed as part of a rulemaking. Pub. L. 110-140. EISA 2007 made numerous amendments to the Energy 

Policy and Conservation Act (EPCA) of 1975, Pub. L. 94-163, (42 U.S.C. 6291–6309), which established 

an energy conservation program for major household appliances and industrial and commercial equipment.

Some Federal DOE regulations have a more significant impact on manufacturers 

of residential refrigeration products than others because manufacturers hold a significant 

market share in those covered products. Table 12.7.6 below shows the DOE energy 

conservation standards with compliance dates within three years of residential 

refrigeration products where manufacturers are expected to be most impacted due to their 

n Estimated industry conversion expenses were published in the TSD for the April 2010 heating products 

final rule. 75 FR 20112. The TSD for the 2010 heating products final rule can be found at

http://www1.eere.energy.gov/buildings/appliance_standards/residential/heating_products_fr_tsd.html. o Estimated industry conversion expenses were published in the TSD for the March 2010 small motors final 

rule. 75 FR 10874. The TSD for the 2010 small motors final rule can be found at

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/sem_finalrule_tsd.html. p Estimated industry conversion expenses were published in the TSD for the April 2010 heating products 

final rule. 75 FR 20112. The TSD for the 2010 heating products final rule can be found at

http://www1.eere.energy.gov/buildings/appliance_standards/residential/heating_products_fr_tsd.html.
12-85

market positions. For these rulemakings, residential refrigeration manufacturers would 

likely be burdened by a significant portion of the estimated industry conversion costs. In 

some cases, specific market share data was not available, but manufacturers were 

identified as major or minor manufacturers in the given market when this information 

was publicly available.

Table 12.7.6 DOE Regulations on Products For Which Residential Refrigeration 

Manufacturers Hold Significant Market Share

Manufacturer Market Share in DOE Regulated Product

Regulation

Estimated 

Industry 

Total 

Conversion 

Expenses 

(millions)

GE Whirlpool Electrolux LG Samsung Haier

Packaged Terminal 

Air Conditioners 

and Packaged 

Terminal Heat 

Pumps

$17.3 

million 

(2007$)

N/A 

(major)

N/A 

(major)

N/A 

(major)

Ranges and Ovens

$22.6 

million 

(2006$)

47% 

(electric); 

37% 

(gas)

29% 

(electric); 

25% (gas)

8% 

(electric); 

23% (gas)

N/A 

(major)

N/A 

(minor)

N/A 

(minor)

General Service 

Fluorescent Lamps 

and Incandescent 

Reflector Lamps

$363.1 

million 

(2008$)

N/A 

(major)

Dehumidifiers N/A 35% 6% 35% 3%

Commercial 

Clothes Washers

$20.4 

million 

(2008$)

N/A 

(major)

N/A 

(major)

N/A 

(minor)

N/A 

(minor)

Room Air 

Conditioners N/A 13% 13% 32% 5% 8%

Residential Clothes 

Dryers N/A

16% 

(electric); 

10% 

(gas)

70% 

(electric); 

74% (gas)

8% 

(electric); 

5% (gas)

N/A 

(minor)

N/A 

(minor)

N/A 

(minor)

Fluorescent Lamp 

Ballasts N/A N/A (major)

Residential Clothes 

Washers N/A 16% 64% 6% 6%

12.7.3.2 Other Federal Regulations

Unites States Clean Air Act

The Clean Air Act is defines the EPA's responsibilities for protecting and 

improving the nation's air quality and the stratospheric ozone layer. The most significant 

of these additional regulations are the EPA mandated phase-out of hydro 

chlorofluorocarbons (HCFCs). The Act demands on a quarterly basis that any person who 

produced, imported, or exported certain substances, including HCFC refrigerants, must 
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report the amount produced, imported and exported. Additionally, effective January 1, 

2015, selling, manufacturing, and using any such substance is banned unless such 

substance has been used, recovered, and recycled; is used and entirely consumed in the 

production of other chemicals; or is used as a refrigerant in appliances manufactured 

prior to January 1, 2020. Finally, production phase-outs will continue until January 1, 

2030 when such production will be illegal. These bans could trigger design changes to 

natural or low global warming potential refrigerants and could impact the insulation used 

in products covered by this rulemaking.

Potential Climate Change and Greenhouse Gas Legislation

Many manufacturers expressed concern about potential climate change 

legislation. One proposed regulation that would exacerbate the manufacturer burden 

caused by more stringent energy conservation standards on refrigeration products is H.R. 

2454, the American Clean Energy and Security Act of 2009. This legislation would 

initiate a phase-down of hydrofluorocarbons (HFCs) and would make the amended 

energy conservation standard levels considered in this rulemaking more difficult to 

achieve. Converting facilities to use cyclopentane would be disruptive to manufacturing 

facilities because of the plant changes required to use a flammable foam blowing agent 

safely.

A further complication of an HFC phase-down for manufacturers is that 

isobutane, the most likely refrigerant replacement of HFCs, is itself currently restricted 

by UL safety rules. UL 250 limits the amount of charge in refrigerators and would 

prevent its use in most residential refrigeration products. While isobutane is more 

efficient than typical HFC refrigerants, some manufacturers were concerned that its 

adoption would cause a significant cost to train their servicers to avoid safety problems 

with the new refrigerant. Several other manufacturers would like to see the current charge 

limits increased, allowing them consistency with factories overseas that already use these 

more flammable hydrocarbons.

12.7.3.3 Other Regulations That Could Impact Residential Refrigeration 

Manufacturers

While the cumulative regulatory burden focuses on the impacts on manufacturers 

of other Federal requirements, in this section DOE has described a number of other 

regulations below that could also impact the residential refrigeration products covered by 

this rulemaking

State Energy Conservation Standards

Manufacturers indicated that California has several programs that are either 

already in place or are currently in development that affect manufacturers of residential 

refrigeration products. Various building, electrical, mechanical, and plumbing codes in 

California affect residential refrigeration products, and products are also subject to 

California’s laws on the Restriction on the use of certain Hazardous Substances (RoHS). 

California’s RoHS law took effect January 1, 2007 and was modeled after the EU’s 
12-87

directive (described below), which bans certain hazardous substances from electrical and 

electronic equipment. California and Washington also have energy conservation 

standards for wine chillers. Connecticut, Maine, Minnesota, New York, Rhode Island, 

Vermont, and Washington all prohibit the sale or distribution of products containing 

intentionally-added mercury without a label. In Oregon, Penta- and Octa-BDE have been 

restricted since 2006, and Oregon banned Deca-BDE in June 2009. These substances 

belong to a group of brominated flame retardants (BFRs) commonly known as 

Polybrominated Diphenyl Ethers (PBDEs). In Maryland, a ban on Deca-BDE will be 

phased-in beginning October 1, 2010.

International Energy Conservation Standards

Residential refrigeration manufacturers that sell products outside of the United 

States are subject to several international energy conservation standards. In the European 

Union, refrigerators and other appliances must carry the EU Energy Label. The energy 

efficiency of the product is rated in energy levels ranging from A to G on the outside 

label, with ‘A’ being the most energy efficient. Recently, A+ and A++ qualifications 

were also introduced for refrigerated appliances. This labeling system enables consumers 

to compare the energy efficiency of products, and it incentivizes manufacturers to 

improve the energy performance of their products. In the EU, products are also subject to 

RoHS. This regulation bans the sale of new equipment in the EU that contains more than 

agreed levels of lead, cadmium, mercury, hexavalent chromium, polybrominated 

biphenyl (PBB) and PBDE flame retardants. Waste Electrical and Electronic Equipment 

(WEEE) and the Registration, Evaluation, Authorization, and restriction of Chemicals 

(REACH) are additional regulations that create compliance costs for manufacturers that 

compete in Europe. REACH deals with chemicals and their safe use and has provisions 

that will be phased-in over eleven years, beginning June 1, 2007. The EU also sets limits 

for the amount of energy consumed by equipment when it is in standby mode and off 

mode. Additionally, HFCs are banned in refrigerants in several countries, such as Austria, 

Denmark, and Switzerland.

Canada also has several regulations that affect manufacturers of residential 

refrigeration products. Ontario’s Product Safety Regulation 438/07 ensures the safety of 

electrical products and equipment sold and used in Ontario. The manufacture of PBDE is 

banned in Canada, including the controversial Deca-BDE. The import of products 

containing Octa-BDE and Penta-BDE is also banned.

Several other foreign countries, such as Australia and South Korea, have energy 

conservation standards in place for residential refrigeration products or are in the process 

of establishing standards for these products. Other countries, such as India and Saudi 

Arabia, have labeling requirements for refrigerators.

12.8 CONCLUSION

The following sections summarize the impacts for the scenarios DOE believes are 

most likely to capture the range of impacts on residential refrigeration product 

manufacturers as a result of amended energy conservation standards. DOE also notes that 

while these scenarios bound the range of most plausible impacts on manufacturers, there 
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potentially could be circumstances which cause manufacturers to experience impacts 

outside of this range. 

12.8.1 Standard-Size Refrigerator-Freezers

TSL 1 represents the current ENERGY STAR level for standard-size refrigeratorfreezers or a 20 percent reduction in measured energy consumption over the current 

energy conservation standards for the analyzed product class 3 (automatic defrost with 

top-mounted freezer without through-the-door ice service), product class 5 (automatic 

defrost with bottom-mounted freezer without through-the-door ice service), and product 

class 7 (automatic defrost with side-mounted freezer with through-the-door ice service). 

At TSL 1, DOE estimates impacts on INPV to range -$84.8 million to -$301.7 million, or 

a change in INPV of -2.7 percent to -9.5 percent. At this proposed level, industry free 

cash flow is estimated to decrease by approximately 64.8 percent to $71.3 million, 

compared to the base-case value of $202.6 million in the year leading up to the proposed 

energy conservation standards.

The INPV impacts at TSL 1 are relatively minor, in part because the vast majority 

of manufacturers produce ENERGY STAR units in significant volumes, particularly for 

product class 5 and 7. Approximately 42 percent of product class 7 shipments and 47 

percent of product class 5 shipments currently meet this TSL. By contrast, the vast 

majority of product class 3 shipments are baseline units. Additionally, most of the design 

options DOE analyzed at this proposed level are one-for-one component swaps, including 

more efficient compressors and brushless DC condenser and evaporator fan motors, 

which require only modest changes to the manufacturing process at TSL 1. As such, DOE 

estimated total product conversion costs of $153 million and capital conversion costs of 

$229 million. 

While substantial on a nominal basis, the total conversion costs are relatively low 

compared to the industry value of $3.2 billion. The total conversion costs at TSL 1 are 

mostly driven by the design options that manufacturers could use to improve the 

efficiency of the smaller-sized units of the product classes analyzed. For example, the 

analyzed design options for the 22 cubic foot product class 7 unit included a VIP in the 

freezer door, while the 26 cubic foot product class 7 unit only analyzed less costly 

component swaps. VIP implementation would require significant capital and product 

conversion costs because additional production steps are required to hold and bind each 

panel in its location before the product is foamed. Each additional step requires more 

equipment to lengthen production lines and, because of lower throughput, more 

production lines for each manufacturer to maintain similar shipment volumes. Some 

manufacturers have experience with VIPs, but DOE expects substantial engineering and 

testing resources would be required for their use in new platforms and/or at higher 

production volumes. 

Similarly, the 16 cubic foot product class 3 unit uses a variable speed compressor 

as a design option. While not a capital intensive solution, variable speed compressors 

would require substantial engineering time to integrate the complex component, 

especially if electronic control systems would also be required. Because these changes 
12-89

are more complex than the other analyzed design options, more than three-quarters of the 

conversion costs for TSL 1 are attributable to the use of the VIPs and variable speed 

compressors in the smaller-volume product class 7 and product class 3 units, respectively. 

The flat markup scenario shows slightly negative impacts at TSL 1, indicating 

that the outlays for conversion costs marginally outweigh any additional profit earned on 

incrementally higher variable costs. On a shipment-weighted basis, the average MPC for 

standard-size refrigerator-freezers increases by 10 percent at TSL 1. These small 

component cost changes are not significant enough to fully recoup these investments 

even if manufacturers earn additional profit on these costs, as the flat markup scenario 

assumes. Hence, there is a slight negative impact, even in the upper-bound scenario, at 

TSL 1. 

The efficiency requirements for product class 3 and product class 5 refrigeratorfreezers are the same at TSL 2 as TSL 1. However, the efficiency requirements for 

product class 7 increase to a 25 percent reduction in measured energy consumption from 

current energy conservation standards. DOE estimates the INPV impacts at TSL 2 range 

from -$175.9 million to -$459.8 million, or a change in INPV of -5.5 percent to -14.5

percent. At this proposed level, the industry cash flow is estimated to decrease by 

approximately 102.8 percent to -$5.7 million, compared to the base-case value of $202.6 

million in the year leading up to the proposed energy conservation standard.

The additional impacts at TSL 2 relative to TSL 1 result from the further 

improvements manufacturers must make to product class 7 refrigerator-freezers to 

achieve a 25 percent energy reduction, as very few shipments of product class 7 currently 

exceed the ENERGY STAR level. Specifically, for the 22-cubic foot product, the design 

options DOE analyzed include a variable speed compressor and a VIP in the freezer 

cabinet, instead of the door as in TSL 1. For the 26-cubic foot product class 7 unit, the 

design options analyzed include a VIP in the freezer door in addition to additional 

component swaps and the component swaps needed to meet TSL 1. Total conversion 

costs increase by $208 million compared to TSL 1, which is largely driven by the initial 

use of VIPs in the 26-cubic foot product class 7 unit. Besides these specific changes to 

side-by-side units, at TSL 2 most production lines of standard-size refrigerator-freezers 

do not use of VIPs or other very costly components, mitigating some of the disruption to 

current facilities. Consequently, the INPV impacts, while greater than at TSL 1, are still 

relatively moderate compared to the value of the industry. 

At TSL 2, the INPV in the flat markup is lower than at TSL 1, which means the 

additional conversion costs to add more VIPs leaves manufacturers worse off even if they 

can earn additional profit on these costly components. In the preservation of operating 

profit markup scenario, the industry earns no additional profit on this greater investment, 

lowering cash flow from operations in the standards case and resulting in greater INPV 

impacts. 

The efficiency requirements for product class 5 and product class 7 refrigeratorfreezers are the same at TSL 3 as TSL 2. However, the efficiency requirements for 

product class 3 increase to a 25 percent reduction in measured energy consumption from 
12-90

current energy conservation standards. TSL 3 represents a 25 percent reduction in 

measured energy consumption over the current energy conservation standards both 

product class 3 and product class 7. In addition, TSL 3 represents a 20 percent reduction 

in measured energy consumption for the unanalyzed product classes 1, 1A, and 2. DOE 

estimates the INPV impacts at TSL 3 to range from -$287.5 million to -$662.1 million, or 

a change in INPV of -9.1 percent to -20.9 percent. At this proposed level, the industry 

cash flow is estimated to decrease by approximately 151.6 percent to -$104.5 million, 

compared to the base-case value of $202.6 million in the year leading up to the standards.

The additional negative impacts on industry cash flow result from the changes to 

product class 3 refrigerator-freezers to reach a 25 percent reduction in energy use (sideby-side products met this proposed level at TSL 2). Specifically, the design options DOE 

analyzes at TSL 3 for 16 cubic foot top-mount refrigerator-freezers include the use of 

VIPs for the first time (in the freezer cabinet), in addition to the component swaps 

discussed above. In total, DOE estimates product conversion costs of $229 million and 

capital conversion costs of $620 million at TSL 3. The high cost to purchase new 

production equipment and the large engineering effort to manufacture new platforms for 

these smaller-sized product class 3 units drive the vast majority of this additional $258 

million in conversion costs that DOE estimates manufacturers would incur at TSL 3.

Because the smaller size top-mounts account for a large percentage of total shipments, 

the production equipment necessary to implement new platforms for these products is 

costly. 

While production of units meeting TSL 3 is fairly limited, several manufacturers 

have introduced products that meet this proposed level in response to Federal production 

tax credits. This experience mitigates some of the product conversion costs by giving 

manufacturers some experience with the newer technologies. However, the more severe 

impacts at TSL 3, relative to TSL 2, are due to the incremental outlays for conversion 

costs to make the changes described above. In particular, any experience with VIPs on 

some products does not lower the substantial capital conversion necessary to purchase 

production equipment necessary to manufacturer products that are substantially different 

from existing products. 

As mentioned above, the preservation of operating profit markup scenario 

assumes no additional profit is earned on the higher production costs, which lower profit 

margins as a percentage of revenue and leads to worse impacts on INPV. In the flat 

markup scenario, the impact of the investments is mitigated by the assumption that 

manufacturers can earn a similar profit margin as a percentage of revenues on their higher 

variable costs. At TSL 3 MPCs increase by an average of 16 percent over the base case, 

leading to additional per-unit profit in this scenario in this scenario. However, the 

magnitude of the conversion investments still leads to negative INPV impacts even if 

additional profit is earned on the incremental manufacturing costs. The lower industry 

shipments driven by the relative price elasticity assumption account for approximately 19 

percent of the impact in the flat markup scenario. 

TSL 4 represents a 30 percent reduction in measured energy consumption over the 

current energy conservation standards for product class 3, product class 5, and product 
12-91

class 7. DOE estimates the INPV impacts at TSL 4 to range from -$643.0 million to -

$1,496.8 million, or a change in INPV of -20.3 percent to -47.2 percent. At this proposed

level, the industry cash flow is estimated to decrease by approximately a factor of 3.2 to -

$449.6 million, compared to the base-case value of $202.6 million in the year leading up 

to the proposed energy conservation standards.

At TSL 4, significant changes to the manufacturing process are necessary for all 

refrigerator-freezers. A 30 percent reduction in energy consumption is the max available 

top-mount on the market; the maximum available side-by-side and bottom-mount only 

slightly exceed a 30 percent reduction. The design options DOE analyzed for all 

standard-size products—with the exception of the 25 cubic foot product class 5 unit—use 

multiple VIPs in the fresh food compartment, freezer doors, and cabinets to reach 30 

percent efficiency level. The design options also include the use of variable speed 

compressors for all units analyzed except the 21 cubic foot product class 3 unit. These 

product changes substantially increase the variable costs across nearly all platforms at 

this TSL. 

While products that meet the efficiency requirements of TSL 4 are not in 

widespread production, several manufacturers produce units at these efficiencies due to 

tax credit incentives. However, at TSL 4 most manufacturers expect to completely 

redesign existing production lines if the proposed energy conservation standards were set 

at levels that necessitated these changes across most or all of their products. 

Manufacturers would need to purchase injection molding equipment, cabinet bending 

equipment, and other equipment for interior tooling as they would need to create new 

molds for these production lines. These changes drive DOE’s estimate of the large 

product and capital conversion costs at TSL 4 ($348 million and $1,405 million, 

respectively). The significant incremental investment relative to TSL 3 results, in large 

part, from the design option of adding VIPs to the 21 cubic foot analyzed product class 3 

unit. This top-mounted refrigerator-freezer represents a substantial portion of the market 

and manufacturers would have to completely redesign these platforms. 

As a result of the large investment necessary to meet this proposed level, some 

manufacturers could move production to Mexico or other lower-labor-costs countries to 

achieve cost savings for labor expenditures. In addition to the large capital conversion 

costs, the shipment-weighted average MPC increases by approximately 36 percent at TSL 

4 compared to the base case. However, the magnitude of the conversion costs at TSL 4 

are so large that even if manufacturers can reap additional profit from these higher 

product costs (as in the flat markup scenario), they would still be substantially impacted, 

as shown by the negative INPV results in the flat markup scenario. Additionally, the 36 

percent increase in MPC drives shipments lower due to the price elasticity. Lower 

industry volume due to the decline in shipments accounts for approximately one-quarter 

of the change in industry value in the flat markup scenario. The large, negative impact on 

INPV is even greater under the preservation of operating profit markup scenario due to 

the inability to pass on the higher costs of expensive design options such as variable 

speed compressors and VIPs. 
12-92

TSL 5 represents max tech for all standard-size refrigerator-freezers. The maxtech level corresponds to reductions in measured energy consumption of 36 percent, 36

percent, and 33 percent over the current energy conservation standards for product class 

3, product class 5, and product class 7, respectively. DOE estimates the INPV impacts at 

TSL 5 to range from -$828.9 million to -$2,154.7 million, or a change in INPV of -26.1 

percent to -67.9 percent. At this proposed level, the industry cash flow is estimated to 

decrease by a factor of approximately 4.5 to -$707.8 million, compared to the base-case 

value of $202.6 million in the year leading up to the proposed energy conservation 

standards.

No products that meet TSL 5 are currently offered on the U.S. market. At TSL 5, 

the changes required to meet this proposed level are similar to those at TSL 4, as 

complete redesigns of all platforms would be required.TSL 5 requires much more 

extensive use of VIPs, however. The higher conversion costs at TSL 5 are primarily due 

to the use of VIPs in additional locations in the door, cabinet and freezer, whereas at TSL 

4 some of the analyzed design options of the larger-sized units included limited or no VIP 

use. This would require manufacturers to further lengthen assembly lines and even 

modify or move their entire facilities, driving the $2,419 million conversion cost estimate 

at this proposed level. As with TSL 4, at TSL 5 some manufacturers could elect to move 

production out of the U.S. to offset some of the addition product costs. At TSL 5, DOE 

estimates MPCs increase by approximately 58 percent compared to the base case. Similar 

to TSL 4, this substantially reduces shipments due to the price elasticity effect and 

exacerbates the industry impacts in both markup scenarios.

As with other TSLs, the impact on INPV is mitigated under the flat markup 

scenario because manufacturers are able to fully pass on the large increase in MPC to 

consumers, thereby increasing manufacturers’ gross profit in absolute terms. However, 

even assuming manufacturers could earn the same gross margin percentage per unit on 

those higher costs, the capital and product conversion costs cause negative INPV impacts, 

as shown by the 26.15 percent decline in INPV in the flat markup scenario. This large 

impact even in the lower bound scenario demonstrates that the large conversion costs to 

redesign all existing platforms results in substantial harm even if manufacturers earn a 

historical margin on these additional costs. Due to the extremely large cost increases at 

the max-tech level, it is more unlikely at TSL 5 that manufacturers could fully pass 

through the increase production costs. If margins are impacted, TSL 5 would result in a 

substantial INPV loss under this scenario.

12.8.2 Standard-Size Freezers

TSL 1 represents a 20 percent reduction in measured energy use over the current 

energy conservation standards for the analyzed product class 9 (upright freezers with 

automatic defrost) and product class 10 (chest freezers and all other freezers except 

compact freezers). DOE estimates the INPV impacts at TSL 1 to range from -$24.9

million to -$57.3 million, or a change in INPV of -6.2 percent to -14.2 percent. At this 

proposed level, the industry cash flow is estimated to decrease by approximately 100.4
12-93

percent to -$0.1 million, compared to the base-case value of $25.7 million in the year 

leading up to the proposed energy conservation standards.

While products meeting TSL 1 are only currently produced in limited volumes, 

the changes in the manufacturing process would not require completely new platforms to 

meet the energy requirements at this TSL. For most standard-size freezer platforms, the 

design options DOE analyzed include the use of brushless DC evaporator fan motors and 

compressors with higher EERs. However, the design options to meet this efficiency level 

also include increasing door insulation thickness for all analyzed products except the 20 

cubic foot product class 10 unit. Increasing door insulation thickness drives the majority 

of the conversion cost outlay DOE estimates manufacturers would incur at TSL 1. To 

increase door insulation thickness, manufacturers would need to purchase new equipment 

tooling equipment for their door assembly. DOE estimates that these changes would 

result in product conversion costs of $22 million and capital conversion costs of $50 

million at TSL 1. However, the conversion costs are somewhat mitigated at TSL 1 

because the design options analyzed would not change the production equipment for the 

cabinet. 

At TSL 1, variable costs increase by approximately 10 percent relative to base 

case MPCs. The flat markup scenario shows less severe impacts because it assumes 

manufacturers can pass on these substantially higher product costs and maintain gross 

margin percentages. Additionally, the reduction in shipments due to the price elasticity 

has only a marginally negative effect at this proposed level. The relatively large 

conversion costs decrease industry value under both markup scenarios and account for a 

substantial portion of the INPV impacts especially if manufacturers are not able to earn 

any additional profit on the higher production costs (the preservation of operating profit 

scenario).

TSL 2 represents a 30 percent reduction in measured energy consumption over the 

current energy conservation standards for product class 9 and 25 percent for product class 

10. TSL 2 also represents a 25 percent reduction in measured energy consumption for the 

unanalyzed product class 8 (upright freezers with manual defrost) and a 30 percent 

reduction for the analyzed product class 10A (chest freezers with automatic defrost). 

DOE estimates the INPV impacts at TSL 2 to range from -$110.6 million to -$186.0

million, or a change in INPV of -27.5 percent to -46.2 percent. At this proposed level, the 

industry cash flow is estimated to decrease by approximately a factor of 3.2 to -$57.5

million, compared to the base-case value of $25.7 million in the year leading up to the 

proposed energy conservation standards.

The vast majority of the standard-size freezer market does not currently meet the 

efficiency requirements at TSL 2. DOE’s design options assume that, in addition to the 

component swaps noted above, manufacturers would increase the insulation thickness of

both the door and cabinet. As a result, product redesigns are expected across most 

platforms, which could substantially disrupting current manufacturing processes. These 

changes account for the majority of DOE’s estimates for total product conversion costs of 

$51 million and capital conversion costs of $175 million, an increase over TSL 1 of $29 

million and $125 million, respectively. The magnitude of the investments, relative to the 
12-94

industry value, results in severe INPV impacts. Even if manufacturers are able to pass on 

the estimated 24 percent increase in product costs onto their customers, the large product 

and capital conversion costs resulting from increased insulation thickness decrease INPV. 

If manufacturers are not able to pass on these costs, as shown by the preservation of 

operating profit scenario, INPV impacts are projected to be severe.

TSL 3 represents a 35 percent reduction in measured energy use over the current 

energy conservation standards for product class 9 and a 30 percent reduction for product 

class 10. DOE estimates the INPV impacts at TSL 3 to range from -$94.5 million to -

$201.1 million, or a change in INPV of -23.5 percent to -49.9 percent. At this proposed 

level, the industry cash flow is estimated to decrease by a factor of approximately 3.4 to -

$61.3 million, compared to the base-case value of $25.7 million in the year leading up to 

the proposed energy conservation standards.

The efficiency requirements at TSL 3 are more stringent than the max available 

products in the market for product class 9 and product class 10. The impacts at TSL 3 are 

similar to those at TSL 2 because the design options analyzed by DOE already required 

platform redesigns at TSL 2. However, the additional design options analyzed at TSL 3 

also include a variable speed compressor in the 14-cubic foot product class 9 unit and 

VIPs in the bottom wall of the 20-cubic foot product class 10 unit. These design options 

substantially increase the variable costs associated with these products but do not greatly 

change the product and capital conversion costs. The average MPC of a standard-size 

freezer shipped at TSL 3 is estimated to be approximately 34 percent more expensive 

than in the base case, leading to a 9 percent decline in shipments due to the price 

elasticity assumption in 2014 alone. 

The impacts at TSL 3 under the flat markup scenario become less severe than at 

TSL 2 because the scenario assumes manufacturers can fully pass on the added cost to 

consumers, while investments do not significantly increase from TSL 2 to TSL 3. 

However, under the preservation of operating profit markup scenario, manufacturers do 

not receive any extra profit on units of higher cost, resulting in worse INPV impacts at 

TSL 3 than at TSL 2. 

TSL 4 represents a 40 percent reduction in measured energy use over the current 

energy conservation standards for product class 9 and a 35 percent reduction for product 

class 10. DOE estimates the INPV impacts at TSL 4 to range from -$59.0 million to -

$218.9 million, or a change in INPV of -14.6 percent to -54.4 percent. At this proposed 

level, the industry cash flow is estimated to decrease by a factor of approximately 3.5 to -

$64.0 million, compared to the base-case value of $25.7 million in the year leading up to 

the proposed energy conservation standards.

At TSL 4, the design options DOE analyzed include the addition of a variable 

speed compressor for the 20-cubic foot product class 9 unit, the 15-cubic foot product 

class 10 unit, and the 20-cubic foot product class 10 unit. For the 14 cubic foot product 

class 9 unit, the design options analyzed were even thicker wall cabinet insulation and the 

implementation of VIPs. 
12-95

The relative impacts at TSL 4 are also caused by the incremental MPCs compared 

to the conversion costs to implement these design options. Outlays for conversion costs 

increase only slightly at TSL 4 (by 4 percent, compared to TSL 3) while variable costs 

increase substantially (by approximately 50 percent compared to the baseline) due to the 

addition of variable speed compressors and VIPs. Because manufacturers earn 

incrementally more profit on each unit at TSL 4 compared to TSL 3 in the flat markup 

scenario—without substantial changes to conversion costs—further declines in industry 

value, though still substantial, are mitigated in this scenario. However, manufacturers 

expressed skepticism that such large cost increases could be passed on. This view is 

reflected by the severely negative results in the preservation of operating profit scenario.

TSL 5 represents max tech for the standard-size freezer product classes. This TSL 

reflects a 44 percent reduction in measured energy use for product class 9 and a 41

percent reduction for product class 10. DOE estimates the INPV impacts at TSL 5 to 

range from -$102.4 million to -$365.1 million, or a change in INPV of -25.4 percent to -

90.7 percent. At this proposed level, the industry cash flow is estimated to decrease by a 

factor of approximately 5.7 to -$120.3 million, compared to the base-case value of $25.7

million in the year leading up to the proposed energy conservation standards.

To achieve the max-tech level at TSL 5, DOE analyzed design options that 

include the widespread implementation of multiple VIPs on all standard-size freezers, in 

addition to the use of more efficient components and thicker insulation already necessary 

to achieve the efficiency requirements at TSL 4. DOE estimated that TSL 5 would 

require product and capital conversion costs of $70 million and $320 million, 

respectively. These large conversion costs result from the changes associated with 

multiple VIP implementation and wall thickness increases. In addition, DOE estimates 

that product costs would almost double base-case MPCs, driven by the use of variable 

speed compressors and VIPs in the doors and cabinet of all product lines. As a result, 

INPV decreases substantially from TSL 4 to TSL 5.

12.8.3 Compact Refrigeration Products

TSL 1 represents a 20 percent reduction in measured energy use over the current 

energy conservation standards for product class 11 (compact refrigerators and 

refrigerator-freezers with manual defrost) and a 10 percent reduction for product class 18 

(compact chest freezers). DOE estimates the INPV impacts at TSL 1 to range from -

$14.3 million to -$32.1 million, or a change in INPV of -7.2 percent to -16.1 percent. At 

this proposed level, industry cash flow is estimated to decrease by approximately 112.9

percent to -$1.5 million, compared to the base-case value of $11.9 million in the year 

leading up to the proposed energy conservation standards. A small percentage of product 

class 18 shipments currently meet this TSL, but most product class 11 shipments are 

baseline units.

The design options analyzed by DOE at TSL 1 assumed that more significant 

changes in the manufacturing process would be required for product class 11, while 

product class 18 would only require increased compressor efficiency. For product class 

11, DOE analyzed several design options that represent component changes, such as a 
12-96

more efficient compressor and increased heat exchanger area, which do not have a 

significant impact on consumer prices or conversion costs. However, DOE also analyzed 

increasing door insulation thickness for product class 11, which drives the bulk of the 

estimated $15 million and $24 million outlays for product conversion and capital 

conversion costs, respectively. As described for standard-size refrigerator-freezers and 

standard-size freezers, increasing insulation thickness requires manufacturers to invest in 

injection molding equipment and other equipment for interior tooling to manufacturer 

products with different door dimensions. The overall impacts at TSL 1 are relatively 

moderate because the conversion costs are still small compared to the industry value of 

$200 million. 

The higher production costs at TSL 1 do not have a substantial impact on INPV at 

TSL 1. The MPC of compact refrigeration products on a shipment-weighted basis 

increases 11 percent over the base case at TSL 1. The combined INPV impacts are 

greater under the preservation of operating profit scenario since manufacturers cannot 

pass on any of the added cost to consumers under that scenario, resulting in lower cash 

flows from operations. However, because production costs do not greatly increase at TSL 

1, the impacts on INPV are relatively low under this scenario as well. 

TSL 2 represents a 25 percent reduction in measured energy use over the current 

energy conservation standards for product class 11 and a 10 percent reduction for product 

class 18. TSL 2 also represents a 15 percent reduction in measured energy consumption 

for the analyzed product classes 13 and 15, and a 20 percent reduction for the unanalyzed 

product class 14. DOE estimates the INPV impacts at TSL 2 to range from -$30.8 million 

to -$66.7 million, or a change in INPV of -15.4 percent to -33.4 percent. At this proposed 

level, the industry cash flow is estimated to decrease by approximately 230.1 percent to -

$15.4 million, compared to the base-case value of $11.9 million in the year leading up to 

the proposed energy conservation standards.

At TSL 2, further changes are required for product class 11. In addition to 

component swaps, the design options analyzed by DOE also include thicker cabinet 

insulation. As discussed for TSL 1, increasing insulation thickness significantly impacts 

product and capital conversion costs, but much more so when adding insulation to the 

cabinet (as opposed to the door). To increase the insulation thickness of the cabinet, 

manufacturers must replace virtually all stamping equipment which greatly increases the 

capital conversion costs. Additionally, DOE analyzed the use of isobutane refrigerant as a 

design option for the 4-cubic foot product class 11 unit. At TSL 2, a substantial portion of 

the investment to reach TSL 2 would likely go towards training service technicians to 

handle the explosive refrigerant. As a result of thicker cabinet insulation and conversion 

to isobutane, product conversion and capital conversion costs roughly double at TSL 2 (to 

$35 million for product conversion costs and $46 million for capital conversion costs). 

The shipment-weighted MPC increased 22 percent at TSL 2 compared to baseline costs, 

which also contributed to the more severe impacts projected under the preservation of 

operation profit scenario if manufacturers do not earn additional profit on these higher 

costs. 
12-97

TSL 3 represents a 30 percent reduction in measured energy use over the current 

energy conservation standards for product class 11 and a 15 percent reduction for product 

class 18. DOE estimates the INPV impacts at TSL 3 to range from -$56.8 million to -

$99.2 million, or a change in INPV of -28.4 percent to -49.6 percent. At this proposed 

level, the industry cash flow is estimated to decrease by a factor of approximately 3.5 to -

$29.4 million, compared to the base-case value of $11.9 million in the year leading up to 

the proposed energy conservation standards.

At TSL 3, the design options analyzed for both product class 18 units include 

thicker door insulation, which further increases the capital conversion costs over TSL 1 

and TSL 2, where this was not analyzed as a design option. The additional impacts at 

TSL 3 are also due to more stringent requirements for product class 11. A 30 percent 

reduction for product class 11 is greater than the most efficient units on the market today. 

For both analyzed sizes of product class 11, DOE analyzed the design option of thicker 

insulation in the cabinet for both units analyzed. The net effect is a large increase in 

conversion costs due to the much higher cost of the equipment necessary to manufacture 

the cabinet. At TSL 3, DOE estimated total product conversion costs of $41 million and 

capital conversion costs of $76 million, a 46 percent total increase in conversion costs 

over TSL 2. The effect of the design changes at TSL 3 on shipment-weighted unit cost is 

a 27 percent increase over the baseline MPC. The magnitude of the investments relative 

to the industry value leads to significant impacts, although they are moderated somewhat 

in the flat markup because manufacturers earn additional profit on the investments.

TSL 4 represents a 40 percent reduction in measured energy use over the current 

energy conservation standards for product class 11 and a 25 percent reduction for product 

class 18. DOE estimates the INPV impacts at TSL 4 to range from -$29.6 million to -

$114.4 million, or a change in INPV of -14.8 percent to -57.3 percent. At this proposed 

level, the industry cash flow is estimated to decrease by approximately 344.1 percent to -

$29.0 million, compared to the base-case value of $11.9 million in the year leading up to 

the proposed energy conservation standards. 

The design options analyzed at TSL 4 would also severely disrupt current 

manufacturing processes. For the 1.7-cubic foot product class 11 unit, DOE analyzed a 

variable speed compressor and isobutane refrigerant as design options. For the 4 cubic 

foot product class 11 unit and the 7-cubic foot product class 18 unit, DOE analyzed 

thicker insulation in the cabinets. For 3.4-cubic foot product class 18 unit, DOE analyzed 

both an increase to cabinet insulation thickness and VIPs in the bottom wall as design 

options. Although increasing insulation thickness, converting to isobutane, and 

implementing VIPs all would necessitate large conversion costs, capital conversion costs 

decrease slightly from TSL 3 to TSL 4 because of the removal of all previous design 

options in the 1.7-cubic foot unit. In other words, the design options analyzed for this unit 

cause less substantial changes to existing production equipment, but would also require a 

large investment by manufacturers to train service technicians to deal with the explosive 

refrigerant. Because this would require a large outlay for product conversion costs, total 

conversion costs are roughly the same at TSL 3 and TSL 4. The addition of a variable 

speed compressor in the smaller product class 11 unit analyzed also has a substantial 

impact on unit price because of its high component cost. At TSL 4, the shipment-
12-98

weighted MPC is 60 percent higher than the baseline MPC. These cost increases are 

projected to cause a 16 percent decrease in shipments at TSL 4 in 2014 alone. Over time, 

the decline in shipments is a big contributor to the negative impacts on INPV in both 

markup scenarios. 

The large conversion costs and higher prices leading to lower shipments cause a 

decrease in INPV from TSL 3 to TSL 4 under the preservation of operating profit markup 

scenario (since this scenario assumes higher production costs are not passed on to 

consumers). However, under the flat markup scenario, manufacturers are able to earn 

additional profit on the new high-cost components such as variable speed compressors, 

resulting in an increase in INPV from TSL 3 to TSL 4. 

TSL 5 represents max tech for both product classes 11 and 18. The max-tech level 

corresponds to a 59 percent and 42 percent reduction in measured energy use for product 

class 11 and product class 18, respectively. DOE estimates the INPV impacts at TSL 5 to 

range from -$133.0 million to -$295.6 million, or a change in INPV of -66.6 percent to -

148.0 percent. At this proposed level, the industry cash flow is estimated to decrease 

approximately nine-fold to -$95.7 million, compared to the base-case value of $11.9 

million in the year leading up to the proposed energy conservation standards.

The design options DOE analyzed include the use of VIPs for all analyzed 

product class 11 and 18 units to reach max-tech efficiency levels. Additionally, the 

design options analyzed for some products also included other costly changes. For the 

1.7- cubic foot product class 11 unit, the design options analyzed included multiple VIPs, 

a larger heat exchanger, and thicker insulation. The design options analyzed for the 4-

cubic foot product class 11 unit also included a variable speed compressor and thicker 

insulation. For product class 18, DOE assumed that manufacturers would remove the 

design options necessary to meet TSLs 1 through 4 and add a variable speed compressor 

and thicker insulation for both analyzed products. These significant changes greatly 

increase the investment required to manufacture standards-compliant products. DOE 

estimated that product conversion costs would be $67 million at TSL 5, an increase of 

almost 40 percent over TSL 4. DOE also estimated that capital conversion costs would be 

$220 million, a more than three-fold increase over TSL 4. This drastic increase in 

conversion costs demonstrates the significant investments required by implementing 

widespread use of VIPs and increasing wall thickness. 

At TSL 5, the shipment-weighted MPC increases by over 150 percent over the 

baseline due to the high material costs of VIPs and variable speed compressors. These 

large jumps cause shipments to decrease by 42 percent due to the price elasticity in 2014 

alone. As a result of lower industry shipments and extremely high conversion costs, 

INPV decreases substantially from TSL 4 to TSL 5 and becomes negative under the 

preservation of operating profit scenario, which indicates the industry loses more than its 

base-case value in the standards case under this scenario. 
12-99

12.8.4 Built-In Refrigeration Products

TSL 1 represents a 10 percent reduction in measured energy use over the current 

energy conservation standards for product class 3A-BI (built-in all-refrigerators—

automatic defrost), product class 5-BI (built-in refrigerator-freezers—automatic defrost 

with bottom-mounted freezer without an automatic icemaker), product class 7-BI (builtin refrigerator-freezers—automatic defrost with side-mounted freezer with through-thedoor ice service), and product class 9-BI (built-in upright freezers with automatic defrost 

without an automatic icemaker). DOE estimates the INPV impacts at TSL 1 to range 

from -$51.7 million to -$52.9 million, or a change in INPV of -7.9 percent to -8.0

percent. At this proposed level, the industry cash flow is estimated to decrease by 

approximately 63.9 percent to $15.0 million, compared to the base-case value of $41.5

million in the year leading up to the proposed energy conservation standards.

At TSL 1, the design options that DOE analyzes result in moderate changes in the 

manufacturing process for built-in refrigeration products. For product classes 3A-BI and 

9-BI, the design options that DOE analyzed to reach TSL 1 included the use of more 

efficient components that do not require significant changes to the manufacturing 

process. However, for product class 5-BI and product class 7-BI, the design options DOE 

analyzed also include the use of VIPs in the freezer door. While these components add to 

the overall costs of production, the added costs represent a small percentage of the total 

cost of a built-in refrigeration product. These cost deltas are low compared to the overall 

cost of the products and result in small impacts even if no additional profit is earned on 

the incremental MPCs. The estimated product conversion costs for all built-in 

refrigeration products at TSL 1 are $41 million and the estimated capital conversion costs 

are $40 million. The implementation of VIPs represents a substantial part of the 

conversion costs, but several built-in refrigeration manufacturers have products that use 

similar technology, which helps to mitigate some of the product conversion costs that 

would be required to design products from the ground up. 

TSL 2 represents a 15 percent reduction in measured energy use for product class 

3A-BI and product class 5-BI. For product classes 7-BI and 9-BI, TSL 2 represents a 

reduction of 10 percent and 20 percent, respectively. DOE estimates the INPV impacts at 

TSL 2 to range from -$54.7 million to -$57.0 million, or a change in INPV of -8.3

percent to -8.7 percent. At this proposed level, the industry cash flow is estimated to 

decrease by approximately 68.0 percent to $13.3 million, compared to the base-case 

value of $41.5 million in the year leading up to the proposed energy conservation 

standards.

The efficiency requirements for product class 7-BI refrigerator-freezers do not 

change from TSL 1 to TSL 2, but the efficiency requirements for all other analyzed builtin product classes increase. The design options that DOE analyzes at TSL 2 for product 

classes 3A-BI and 7-BI still only include component swaps to reach a 15 percent 

efficiency improvement. Product class 5-BI uses a variable speed compressor in the 

freezer with a brushless DC condenser fan motor, but no longer use the VIPs used to 

reach TSL 1. The design options analyzed for product class 9-BI include a brushless DC 

evaporator and condenser fan motor, a larger condenser, a variable speed compressor, 
12-100

and a VIP in the upper door. Because product class 5-BI no longer uses VIPs and fewer 

changes to existing products are necessary, the overall impact is a slight decrease in 

capital conversion costs from $40 million at TSL 1 to $38 million at TSL 2. Product 

conversion costs increase to $51 million at TSL 2 because additional engineering time 

would be required to implement the additional component changes. However, because 

the complexity of the changes to the products and production facilities are similar at TSL 

1 and TSL 2, there is only a small decrease in INPV from TSL 1 to TSL 2.

TSL 3 represents a 20 percent reduction in measured energy use for product class 

3A-BI and product class 7-BI. For product classes 5-BI and 9-BI, TSL 2 represents a 

reduction of 15 percent and 25 percent, respectively. DOE estimates the INPV impacts at 

TSL 3 to range from -$65.8 million to -$80.5 million, or a change in INPV of -10.0

percent to -12.2 percent. At this proposed level, the industry cash flow is estimated to 

decrease by approximately 93.0 percent to $2.9 million, compared to the base-case value 

of $41.5 million in the year leading up to the proposed energy conservation standards.

The efficiency requirements for product class 5-BI do not change from TSL 2 to 

TSL 3. However, the design options for all other built-in refrigeration products at TSL 3 

include the implementation of VIPs. The widespread implementation of VIPs increases 

product and capital conversion costs, which are estimated to be $65 million and $55

million at TSL 3, respectively. Substantial changes to existing production facilities would 

be required to manufacture products that meet the required efficiencies at TSL 3. Most of 

the capital conversion costs involve purchasing new production equipment and would 

result in high stranded assets. The extensive changes that manufacturers would be 

required to make to existing facilities and the projected erosion of profitability if the 

additional production cost of implementing VIPs does not yield additional profit result in 

a projected decrease in INPV from TSL 3 to TSL 4. However, the industry value is high 

relative to the required capital conversion costs and the cost of the additional VIP panels 

is relatively small compared to the overall cost of the products, which helps to mitigate 

some of the negative impacts caused by these changes.

TSL 4 represents a 25 percent reduction in measured energy use over the current 

energy conservation standards for the following product classes: 3A-BI, 5-BI, and 9-BI. 

For product class 7-BI, TSL 4 represents a 20 percent reduction in measured energy use 

from current energy conservation standards. DOE estimates the INPV impacts at TSL 4 

to range from -$79.7 million to -$103.0 million, or a change in INPV of -12.1 percent to -

15.6 percent. At this proposed level, the industry cash flow is estimated to decrease by 

approximately 117.8 percent to -$7.4 million, compared to the base-case value of $41.5

million in the year leading up to the proposed energy conservation standards.

The efficiency requirements for product class 7-BI do not change from TSL 3 to 

TSL 4. The design options for the other built-in refrigeration products all include the 

addition of more VIPs to reach TSL 4. The design options analyzed for product classes 

3A-BI and 5-BI also include using a variable speed compressor. The complexity of 

implementing multiple component swaps and the additional production equipment 

necessary to use additional VIPs increases both the product and capital conversion costs. 
12-101

These costs are estimated to be $75 million and $74 million at TSL 4, respectively, and 

result in a decrease in INPV from TSL 3 to TSL 4.

TSL 5 represents max tech for the four built-in product classes. This proposed 

level represents a reduction in measured energy use of 29 percent, 27 percent, 22 percent, 

and 27 percent, respectively, for product classes 3A-BI, 5-BI, 7-BI, and 9-BI. DOE 

estimates the INPV impacts at TSL 5 to range from -$84.9 million to -$120.3 million, or 

a change in INPV of -12.9 percent to -18.3 percent. At this proposed level, the industry 

cash flow is estimated to decrease by approximately 135.1 percent to -$14.6 million, 

compared to the base-case value of $41.5 million in the year leading up to the proposed 

energy conservation standards.

The design options analyzed by DOE include the widespread use of VIPs to 

achieve the max-tech efficiency levels at TSL 5. Additionally, product class 3A-BI uses 

multiple variable speed compressors. Since the implementation of VIPs is both research 

and capital intensive, product and capital conversion costs increase to $87 million and 

$84 million, respectively. The complexity of implementing multiple component swaps 

and the additional production equipment necessary to use additional VIPs increases both 

the product and capital costs.
12-102

REFERENCES

 

1 Securities and Exchange Commission, Annual 10-K Reports, Various Years,

Washington DC. <www.sec.gov>.

2 Standard and Poors Financial Services LLC, Company Credit Ratings, Various 

Companies, New York, NY. < www2.standardandpoors.com>.

3 Annual Survey of Manufacturing: 2007. American FactFinder. 2010. Bureau of 

the Census. < http://factfinder.census.gov/servlet/IBQTable?_bm=y&-

ds_name=EC0731I1&-ib_type=NAICS2007&-NAICS2007=335222 >.

4 Association of Home Appliance Manufacturers. Current Members. Last Accessed 

December 2, 2009. < http://www.aham.org/ht/d/Organizations/divisions/Y/pid/2344>.

5 Federal Trade Commission. Appliance Energy Data. 

<http://www.ftc.gov/bcp/conline/edcams/eande/appliances/fridge.htm>

6 ENERGY STAR. Qualified Refrigerators & Freezers. 

<http://www.energystar.gov/index.cfm?fuseaction=refrig.display_products_html>

7 California Energy Commission. Appliance Efficiency Database.

<http://www.appliances.energy.ca.gov/QuickSearch.aspx>

8 McKinsey & Company, Inc. Valuation: Measuring and Managing the Value of

Companies, 3rd Edition, Copeland, Koller, Murrin. New York: John Wiley & Sons, 

2000.

9 U.S. Department of Energy–Energy Information Administration. Annual Energy 

Outlook 2010 with Projections to 2035. April 2010. U.S. DOE–EIA: Washington, 

D.C. DOE/EIA-0383(2010).
13-i

CHAPTER 13. EMPLOYMENT IMPACT ANALYSIS

TABLE OF CONTENTS

13.1 INTRODUCTION ......................................................................................................... 13-1

13.2 ASSUMPTIONS............................................................................................................ 13-1

13.3 METHODOLOGY ........................................................................................................ 13-1

13.4 RESULTS ...................................................................................................................... 13-2

LIST OF TABLES

Table 13.4.1 Standard-Size Refrigerator-Freezers Net National Change in Employment ... 13-12

Table 13.4.2 Standard-Size Freezers Net National Change in Employment........................ 13-13

Table 13.4.3 Compact Refrigeration Products Net National Change in Employment ......... 13-13

Table 13.4.4 Built-in Refrigeration Products Net National Change in Employment ........... 13-13

LIST OF FIGURES

Figure 13.4.1 Refrigerator-Freezer Employment Impact of Increased Equipment Cost ......... 13-3

Figure 13.4.2 Compact Refrigeration Products Employment Impact of Increased 

Equipment Cost.................................................................................................. 13-3

Figure 13.4.3 Freezer Employment Impact of Increased Equipment Cost .............................. 13-4

Figure 13.4.4 Built-in Refrigeration Products Employment Impact of Increased 

Equipment Cost.................................................................................................. 13-4

Figure 13.4.5 Refrigerator-Freezer Employment Impact of Operating Cost Savings.............. 13-5

Figure 13.4.6 Compact Refrigeration Products Employment Impact of Operating Cost 

Savings............................................................................................................... 13-6

Figure 13.4.7 Freezer Employment Impact of Operating Cost Savings .................................. 13-6

Figure 13.4.8 Built-in Refrigeration Products Employment Impact of Operating Cost 

Savings............................................................................................................... 13-7

Figure 13.4.9 Refrigerator-Freezer Employment Impact of Operations and Maintenance 

Cost Increase...................................................................................................... 13-8

Figure 13.4.10Compact Refrigeration Products Employment Impact of Operations and 

Maintenance Cost Increase ................................................................................ 13-8

Figure 13.4.11 Freezer Employment Impact of Operations and Maintenance Cost Increase.... 13-9

Figure 13.4.12Built-in Refrigeration Products Employment Impact of Operations and 

Maintenance Cost Increase ................................................................................ 13-9

Figure 13.4.13 Standard-Size Refrigerator-Freezers Net National Change in Employment ... 13-10

Figure 13.4.14 Standard-Size Freezers Net National Change in Employment........................ 13-11

Figure 13.4.15Compact Refrigeration Products Net National Change in Employment ......... 13-11

Figure 13.4.16Built-in Refrigeration Products Net National Change in Employment ........... 13-12
13-1

CHAPTER 13. EMPLOYMENT IMPACT ANALYSIS

13.1 INTRODUCTION

DOE conducted an employment impact analysis for the NOPR. DOE’s employment 

impact analysis is designed to estimate indirect national job creation or elimination resulting 

from possible standards, due to reallocation of the associated expenditures for purchasing and 

operating residential refrigeration products. 

13.2 ASSUMPTIONS

DOE expects energy conservation standards to decrease energy consumption, and 

therefore to reduce energy expenditures. The savings in energy expenditures may be spent on 

new investment or not at all (i.e., they may remain “saved”). The standards may increase the 

purchase price of appliances, including the retail price plus sales tax, and increase installation 

costs. 

Using an input/output econometric model of the U.S. economy, this analysis estimated 

the year-to-year effect of these expenditure impacts on net economic output and employment. 

DOE intends this analysis to quantify the indirect employment impacts of these expenditure 

changes. It evaluated direct employment impacts at manufacturers’ facilities in the manufacturer 

impact analysis (see Chapter 12).

13.3 METHODOLOGY

The Department based its analysis on an input/output model of the U.S. economy that 

estimates the effects of standards on major sectors of the economy related to buildings and the

net impact of standards on jobs. The Pacific Northwest National Laboratory developed the 

model, ImSET 3.1.11 (Impact of Sector Energy Technologies) as a successor to ImBuild2

, a 

special-purpose version of the IMPLAN3 national input/output model. ImSET estimates the 

employment and income effects of building energy technologies. In comparison with simple 

economic multiplier approaches, ImSET allows for more complete and automated analysis of the 

economic impacts of energy-efficiency investments in buildings.

In an input/output model, the level of employment in an economy is determined by the 

relationship of different sectors of the economy and the spending flows among them. Different 

sectors have different levels of labor intensity and so changes in the level of spending (e.g., due 

to the effects of an efficiency standard) in one sector of the economy will affect flows in other 

sectors, which affects the overall level of employment.

ImSET uses a 187-sector model of the national economy to predict the economic effects 

of residential and commercial buildings technologies. ImSET collects estimates of initial 

investments, energy savings, and economic activity associated with spending the savings 

resulting from standards (e.g., changes in final demand in personal consumption, business 

investment and spending, and government spending). It provides overall estimates of the change 

in national output for each input-output sector. The model applies estimates of employment and 
13-2

wage income per dollar of economic output for each sector and calculates impacts on national 

employment and wage income.

Energy-efficiency technology primarily affects the U.S. economy along three spending 

pathways. First, general investment funds are diverted to sectors that manufacture, install, and 

maintain energy-efficient appliances. The increased cost of appliances leads to higher 

employment in the appliance manufacturing sectors and lower employment in other economic 

sectors. Second, commercial firm and residential spending are redirected from utilities toward 

firms that supply production inputs. Third, electric utility sector investment funds are released 

for use in other sectors of the economy. When consumers use less energy, electric utilities 

experience relative reductions in demand which leads to reductions in utility sector investment 

and employment.

13.4 RESULTS

The results in this section refer to impacts of residential refrigeration product standards 

relative to the base case for each appliance. DOE disaggregated the impact of standards on 

employment into three component effects: increased capital investment costs, decreased energy 

and water costs, and changes in operations and maintenance costs. These component effects and 

a summary impact are presented for residential standard-size refrigerator-freezers, standard-size 

freezers, compact refrigeration products, and built-in refrigeration products.

Figures 13.4.1-13.4.4 summarize the employment impacts of the increased investment 

and spending on higher-efficiency equipment. Because appliance manufacturing is relatively 

capital-intensive compared to other sectors of the economy, the net result is a small loss of 

employment.
13-3

Figure 13.4.1 Refrigerator-Freezer Employment Impact of Increased Equipment Cost

Figure 13.4.2 Compact Refrigeration Products Employment Impact of Increased 

Equipment Cost

-25

-20

-15

-10

-5

0

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1

TSL 2

TSL 3

TSL 4

TSL 5

-3.0

-2.5

-2.0

-1.5

-1.0

-0.5

0.0

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1

TSL 2

TSL 3

TSL 4

TSL 5
13-4

Figure 13.4.3 Freezer Employment Impact of Increased Equipment Cost

Figure 13.4.4 Built-in Refrigeration Products Employment Impact of Increased 

Equipment Cost

-4.5

-4.0

-3.5

-3.0

-2.5

-2.0

-1.5

-1.0

-0.5

0.0

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1

TSL 2, 3

TSL 4

TSL 5

-0.7

-0.6

-0.5

-0.4

-0.3

-0.2

-0.1

0.0

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1

TSL 2

TSL 3

TSL 4

TSL 5
13-5

Figures 13.4.5-13.4.8 show the employment impact of redirected spending made possible 

by appliance operating cost savings. In this case, the employment impact is strongly positive. 

Figure 13.4.5 Refrigerator-Freezer Employment Impact of Operating Cost Savings

0

5

10

15

20

25

30

35

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1

TSL 2

TSL 3

TSL 4

TSL 5
13-6

Figure 13.4.6 Compact Refrigeration Products Employment Impact of Operating Cost 

Savings

Figure 13.4.7 Freezer Employment Impact of Operating Cost Savings

0.0

0.5

1.0

1.5

2.0

2.5

3.0

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1

TSL 2

TSL 3

TSL 4

TSL 5

0

1

2

3

4

5

6

7

8

9

10

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1

TSL 2, 3

TSL 4

TSL 5
13-7

Figure 13.4.8 Built-in Refrigeration Products Employment Impact of Operating Cost 

Savings

Figures 13.4.9 – 13.4.12 show the employment impacts of non-energy operations and 

maintenance cost increases for residential refrigeration products.

0.0

0.1

0.2

0.3

0.4

0.5

0.6

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1

TSL 2

TSL 3

TSL 4

TSL 5
13-8

Figure 13.4.9 Refrigerator-Freezer Employment Impact of Operations and Maintenance 

Cost Increase

Figure 13.4.10 Compact Refrigeration Products Employment Impact of Operations and 

Maintenance Cost Increase

-0.14

-0.12

-0.10

-0.08

-0.06

-0.04

-0.02

0.00

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1

TSL 2

TSL 3

TSL 4

TSL 5

-0.008

-0.006

-0.004

-0.002

0.000

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1 - 3

TSL 4

TSL 5
13-9

Figure 13.4.11 Freezer Employment Impact of Operations and Maintenance Cost Increase

Figure 13.4.12 Built-in Refrigeration Products Employment Impact of Operations and 

Maintenance Cost Increase

-0.040

-0.035

-0.030

-0.025

-0.020

-0.015

-0.010

-0.005

0.000

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1

TSL 2, 3

TSL 4

TSL 5

-0.005

-0.004

-0.003

-0.002

-0.001

0.000

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1

TSL 2

TSL 3

TSL 4

TSL 5
13-10

Figures 14.4.13-14.4.16 show the estimated net national employment impacts of the 

residential refrigeration product trial standard levels. For any given year, these figures show the 

net change in the number of jobs in the economy relative to if there were no change in standards 

(and thus no resulting change in spending and cash flow patterns throughout the economy). 

These figures show the combined effects of equipment cost, operations and maintenance cost, 

and energy use changes due to standards. 

Figure 13.4.13 Standard-Size Refrigerator-Freezers Net National Change in Employment

-15

-10

-5

0

5

10

15

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

year

TSL 1

TSL 2

TSL 3

TSL 4

TSL 5
13-11

Figure 13.4.14 Standard-Size Freezers Net National Change in Employment

Figure 13.4.15 Compact Refrigeration Products Net National Change in Employment

-2

-1

0

1

2

3

4

5

6

7

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1

TSL 2, 3

TSL 4

TSL 5

-1.5

-1.0

-0.5

0.0

0.5

1.0

1.5

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1

TSL 2

TSL 3

TSL 4

TSL 5
13-12

Figure 13.4.16 Built-in Refrigeration Products Net National Change in Employment

Tables 13.4.1-13.4.4 show the net national employment impact in specific years for each 

product. The initial decrease in net employment is caused by the dominance of capital costs in 

early years, while the impacts of operating cost savings from reduced energy use build up slowly 

over time, resulting in a net positive impact on employment in later years. 

Table 13.4.1 Standard-Size Refrigerator-Freezers Net National Change in Employment

Trial Standard 

Level

2014

(thousands)

2020 

(thousands)

2030 

(thousands)

2043

(thousands)

1 -1.80 1.30 6.39 10.99

2 -2.39 1.07 6.83 12.05

3 -3.21 0.74 7.47 13.49

4 -7.31 -2.87 5.60 12.95

5 -11.16 -7.16 2.34 10.34

-0.40

-0.30

-0.20

-0.10

0.00

0.10

0.20

2014 2019 2024 2029 2034 2039

Incremental Jobs (1000)

Year

TSL 1

TSL 2

TSL 3

TSL 4

TSL 5
13-13

Table 13.4.2 Standard-Size Freezers Net National Change in Employment

Trial Standard 

Level

2014

(thousands)

2020 

(thousands)

2030 

(thousands)

2043

(thousands)

1 -0.19 0.72 2.44 4.34

2 -0.53 0.69 3.11 5.79

3 -0.53 0.69 3.11 5.79

4 -1.22 0.18 3.34 6.77

5 -2.01 -0.97 2.29 5.80

Table 13.4.3 Compact Refrigeration Products Net National Change in Employment

Trial Standard 

Level

2014

(thousands)

2020 

(thousands)

2030 

(thousands)

2043

(thousands)

1 -0.05 0.46 0.78 1.24

2 -0.18 0.43 0.78 1.26

3 -0.22 0.49 0.89 1.44

4 -0.56 0.29 0.70 1.21

5 -1.16 -0.45 -0.11 0.14

Table 13.4.4 Built-in Refrigeration Products Net National Change in Employment

Trial Standard 

Level

2014

(thousands)

2020 

(thousands)

2030 

(thousands)

2043

(thousands)

1 -0.01 0.02 0.06 0.10

2 -0.02 0.01 0.07 0.13

3 -0.15 -0.10 -0.01 0.08

4 -0.24 -0.18 -0.07 0.01

5 -0.36 -0.31 -0.20 -0.13
13-14

REFERENCES

1. Roop, J. M., M. J. Scott, and R. W. Schultz, ImSET 3.1: Impact of Sector Energy 

Technologies, 2008. Pacific Northwest National Laboratory. Richland, WA. Report No. 

PNNL- 18412. 

2. Scott, M. J., D. J. Hostick, and D. B. Belzer, ImBuild: Impact of Building Energy 

Efficiency Programs, April, 1998. Pacific Northwest National Laboratory. Richland, WA. 

Report No. PNNL-11884. Prepared for the U.S. Department of Energy under Contract 

DE-AC06-76RLO 1830. 

3. Minnesota IMPLAN Group Inc., IMPLAN Professional: User's Guide, Analysis Guide, 

Data Guide, 1997. Stillwater, MN. 
14-i

CHAPTER 14. UTILITY IMPACT ANALYSIS

TABLE OF CONTENTS

14.1 INTRODUCTION ......................................................................................................... 14-1

14.2 METHOD ...................................................................................................................... 14-1

14.3 RESULTS ...................................................................................................................... 14-2

14.4 SUMMARY OF UTILITY IMPACT ANALYSIS ..................................................... 14-24

14.5 IMPACT OF STANDARDS ON ELECTRICITY PRICES AND ASSOCIATED 

BENEFITS FOR CONSUMERS................................................................................. 14-24

14.5.1 Impact on Electricity Prices......................................................................................... 14-25

14.5.2 Impact of Changes in Electricity Price on Electricity Users........................................ 14-26

14.5.3 Discussion of Savings in Electricity Expenditures...................................................... 14-27

LIST OF TABLES

Table 14.3.1 AEO2010 Reference Case Forecast................................................................... 14-3

Table 14.3.2 Standard-Size Refrigerator-Freezers Trial Standard Level 1 Forecast.............. 14-4

Table 14.3.3 Standard-Size Refrigerator-Freezers Trial Standard Level 2 Forecast.............. 14-5

Table 14.3.4 Standard-Size Refrigerator-Freezers Trial Standard Level 3 Forecast.............. 14-6

Table 14.3.5 Standard-Size Refrigerator-Freezers Trial Standard Level 4 Forecast.............. 14-7

Table 14.3.6 Standard-Size Refrigerator-Freezers Trial Standard Level 5 Forecast.............. 14-8

Table 14.3.7 Standard-Size Freezers Trial Standard Level 1 Forecast................................... 14-9

Table 14.3.8 Standard-Size Freezers Trial Standard Level 2 Forecast................................. 14-10

Table 14.3.9 Standard-Size Freezers Trial Standard Level 3 Forecast................................. 14-11

Table 14.3.10 Standard-Size Freezers Trial Standard Level 4 Forecast................................. 14-12

Table 14.3.12 Standard-Size Freezers Trial Standard Level 5 Forecast................................. 14-13

Table 14.3.13 Compact Refrigeration Products Trial Standard Level 1 Forecast .................. 14-14

Table 14.3.14 Compact Refrigeration Products Trial Standard Level 2 Forecast .................. 14-15

Table 14.3.15 Compact Refrigeration Products Trial Standard Level 3 Forecast .................. 14-16

Table 14.3.16 Compact Refrigeration Products Trial Standard Level 4 Forecast .................. 14-17

Table 14.3.17 Compact Refrigeration Products Trial Standard Level 5 Forecast .................. 14-18

Table 14.3.18 Built-In Refrigeration Products Trial Standard Level 1 Forecast.................... 14-19

Table 14.3.19 Built-In Refrigeration Products Trial Standard Level 2 Forecast.................... 14-20

Table 14.3.20 Built-In Refrigeration Products Trial Standard Level 3 Forecast.................... 14-21

Table 14.3.21 Built-In Refrigeration Products Trial Standard Level 4 Forecast.................... 14-22

Table 14.3.22 Built-In Refrigeration Products Trial Standard Level 5 Forecast.................... 14-23

Table 14.4.1 Reduction in Total U.S. Electricity Generation in 2043 Under 

Refrigeration Product TSLs............................................................................. 14-24

Table 14.4.2 Reduction in Electric Generating Capacity in 2043 Under Refrigeration 

Product TSLs ................................................................................................... 14-24

Table 14.5.1 Cumulative NPV of the Economy-Wide Savings in Electricity 

Expenditures Due to the Projected Decline in Electricity Prices Resulting 

from Amended Standards for Refrigerators*................................................... 14-27
14-ii

LIST OF FIGURES

Figure 14.5.1 Change in U.S. Electricity Consumption Associated with Proposed 

Refrigeration Product Energy Conservation Standards................................... 14-25

Figure 14.5.2 Effect of Proposed Refrigeration Product Energy Conservation Standards 

on Average U.S. Electricity Price (All Users)................................................. 14-26
14-1

CHAPTER 14. UTILITY IMPACT ANALYSIS

14.1 INTRODUCTION

DOE analyzed the effects of residential refrigerator standard levels on the electric utility 

industry using a variant of the DOE/Energy Information Administration (EIA)’s National Energy 

Modeling System (NEMS).

a NEMS is a public domain, multi-sectored, partial equilibrium 

model of the U.S. energy sector. Each year, DOE/EIA uses NEMS to produce an energy forecast 

for the United States, the Annual Energy Outlook (AEO). The AEO for 2010 (AEO2010)

forecasts energy supply and demand through 2035.

1 DOE used a variant of this model, referred 

to here as NEMS-BT,

b to account for the impacts of refrigerator energy conservation standards.

DOE’s utility impact analysis consists of a comparison between model results for the AEO2010

Reference Case and for cases in which standards are in place, and applies the same basic set of 

assumptions as the AEO2010. The AEO2010 reference case corresponds to medium economic 

growth.

The utility impact analysis reports the changes in electric installed capacity and 

generation that result for each trial standard level (TSL) by plant type, as well as changes in 

residential electricity consumption. 

NEMS-BT has several advantages that have led to its adoption as the forecasting tool in 

the analysis of energy conservation standards. NEMS-BT uses a set of assumptions that are well 

known and fairly transparent, due to the exposure and scrutiny each AEO receives. In addition, 

the comprehensiveness of NEMS-BT permits the modeling of interactions among the various 

energy supply and demand sectors, producing a complete picture of the effects of energy

conservation standards. Perhaps most importantly, NEMS-BT can be used to estimate marginal 

effects, which yield a better estimate of the actual impact of energy conservation standards than 

considering only average effects.

14.2 METHOD

The utility impact analysis uses the assumptions of the AEO2010 and treats refrigeration

conservation standards as variations in policy. The effects of the policy are calculated as the 

difference between the AEO2010 Reference Case and each proposed standard case, which is 

described as a trial standard level (TSL). 

 

a For more information on NEMS, refer to the U.S. Department of Energy, Energy Information Administration 

documentation. A useful summary is National Energy Modeling System: An Overview 2003, DOE/EIA-0581(2003), 

March, 2003.

b DOE/EIA approves use of the name NEMS to describe only an official version of the model without any 

modification to code or data. Because this analysis entails some minor code modifications and the model is run 

under various policy scenarios that are variations on DOE/EIA assumptions, DOE refers to it by the name NEMSBT (BT is DOE’s Building Technologies Program, under whose aegis this work has been performed). NEMS-BT 

was previously called NEMS-BRS.
14-2

DOE used the site energy savings developed in the national impact analysis (chapter 10) 

for each TSL as input to NEMS-BT. The magnitude of the energy decrement that would be 

required for NEMS-BT to produce stable results out of the range of numerical noise is larger 

than the highest efficiency standard under consideration. Therefore, DOE estimated results 

corresponding to each TSL using interpolation. DOE ran higher energy use reduction levels in 

NEMS-BT, representing multipliers of each TSL, and used these outputs to linearly interpolate 

the results to estimate actual changes in generation and capacity due to the standard.

Policy runs are executed by reducing electricity consumption in the NEMS-BT 

Residential Demand Module. Energy use reductions are applied to the refrigeration end use. The

reductions are divided amongst the nine U.S. Census divisions based upon the share of 

refrigeration and freezer energy end use consumption in each division, as given in NEMS.

Although the current time horizon of NEMS-BT is 2035, other parts of the energy

conservation standards analysis extend to the year 2043. It is not feasible to extend the forecast 

period of NEMS-BT for the purposes of this analysis, nor does DOE/EIA have an approved 

method for extrapolation of many outputs beyond 2035. While it might seem reasonable to make 

simple linear extrapolations of results, in practice this is not advisable because outputs could be 

contradictory. An analysis of various trends sufficiently detailed to guarantee consistency is 

beyond the scope of this work, and, in any case, would involve a great deal of uncertainty.

Therefore, all extrapolations beyond 2035 are simple replications of year 2035 results. To 

emphasize the extrapolated results wherever they appear, they are shaded in gray to distinguish 

them from actual NEMS-BT results.

14.3 RESULTS

This utility impact analysis reports NEMS-BT forecasts for residential-sector electricity

consumption, total electricity generation by fuel type, and installed electricity generation 

capacity by fuel type. Results are presented in five-year increments to year 2035. Beyond year 

2035, an extrapolation to 2043 for each proposed TSL represents a simple replication of the year 

2035 results.

The results from the AEO2010 Reference Case are shown in Table 14.3.1. 

A separate set of TSLs is modeled for each product grouping. The results for the 

standard-size refrigerator-freezer TSLs are presented in Tables 14.3.2 through 14.3.6, the results 

for standard-size freezer TSLs are presented in Tables 14.3.7 through 14.3.12, the results for the

compact refrigeration product TSLs are presented in Tables 14.3.13 through 14.3.17, and the 

results for the built-in refrigeration product TSLs are presented in Tables 14.3.18 to 14.3.22. 

Each table shows forecasts using interpolated results, as described in section 14.2, for total U.S. 

electricity generation and installed capacity.
14-3

The considered residential refrigerator TSLs reduce only electricity consumption 

compared to the AEO2010 Reference Case. The electricity savings predicted by the NIA Model 

for all refrigeration products considered range from 1.26 to 2.73 percent of total residential 

electricity consumption in the year 2035.

Table 14.3.1 AEO2010 Reference Case Forecast 

NEMS-BT Results: AEO2010 Reference

2005 2010 2015 2020 2025 2030 2035

Residential Sector Energy Consumption 1

Electricity Sales (TWh)2 1,359 1,388 1,400 1,472 1,553 1,637 1,707

Total U.S. Electric Generation 3

Coal (TWh) 2,013 1,828 2,038 2,090 2,130 2,209 2,305

Gas (TWh) 759 857 690 769 886 1,018 1,095

Petroleum (TWh) 122 45 46 47 48 48 49

Nuclear (TWh) 782 813 834 883 886 886 895

Renewables (TWh) 358 462 649 714 797 850 890

Total (TWh)4 4,034 4,005 4,257 4,503 4,746 5,012 5,234

Installed Generating Capacity 5

Coal (GW) 314 321 325 326 326 330 337

Other Fossil (GW)6 439 468 445 446 467 501 534

Nuclear (GW) 100 102 105 111 111 111 113

Renewables (GW) 99 133 171 177 186 196 209

Total (GW)7 952 1,024 1,046 1,059 1,091 1,138 1,192

1

Comparable to Table A2 of AEO2010: Energy Consumption, Residential

2

Comparable to Table A8 of AEO2010: Electricity Sales by Sector

3

Comparable to Table A8 of AEO2010: Electric Generators and Cogenerators

4

Excludes "Other Gaseous Fuels" cogenerators and "Other" cogenerators

5

Comparable to Table A9 of AEO2010: Electric Generators and Cogenerators Capability

6

Includes "Other Gaseous Fuels" cogenerators

7

Excludes Pumped Storage and Fuel Cells
14-4

Table 14.3.2 Standard-Size Refrigerator-Freezers: Trial Standard Level 1 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,399 1,466 1,544 1,625 1,693 Electricity Sales (TWh) 0.00 0.00 -1.40 -5.36 -9.25 -12.41 -14.86 -16.79 -17.81

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,089 2,128 2,206 2,301 Coal (TWh) 0.00 0.05 0.21 -1.06 -1.58 -3.31 -3.59 -3.59 -3.59

Gas (TWh) 759 858 691 767 880 1,012 1,089 Gas (TWh) 0.00 0.37 0.88 -1.84 -5.37 -5.87 -5.98 -5.98 -5.98

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.00 0.00 0.00 -0.02 -0.03 -0.06 -0.07 -0.07 -0.07

Nuclear (TWh) 782 813 834 883 886 886 894 Nuclear (TWh) 0.00 0.00 0.00 0.00 0.00 0.00 -0.57 -0.57 -0.57

Renewables (TWh) 358 462 646 711 794 847 886 Renewables (TWh) 0.00 -0.40 -2.59 -2.51 -3.17 -3.28 -4.31 -4.31 -4.31

Total (TWh) 4,034 4,005 4,256 4,497 4,736 4,999 5,219 Total (TWh) 0.00 0.01 -1.51 -5.42 -10.16 -12.51 -14.52 -14.52 -14.52

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 336 Coal (GW) 0.000 0.000 -0.090 -0.080 -0.082 -0.174 -0.145 -0.145 -0.145

Other Fossil (GW) 439 468 445 445 466 500 533 Other Fossil (GW) 0.000 -0.001 -0.246 -0.364 -0.788 -1.005 -1.091 -1.091 -1.091

Nuclear (GW) 100 102 105 111 111 111 112 Nuclear (GW) 0.000 0.000 0.000 0.000 0.000 0.000 -0.078 -0.078 -0.078

Renewables (GW) 99 133 171 176 186 195 208 Renewables (GW) 0.000 -0.117 -0.727 -0.734 -0.680 -0.717 -0.971 -0.971 -0.971

Total (GW) 952 1,024 1,045 1,058 1,089 1,136 1,190 Total (GW) 0.000 -0.118 -1.064 -1.178 -1.549 -1.896 -2.285 -2.285 -2.285

Extrapolation
14-5

Table 14.3.3 Standard-Size Refrigerator-Freezers: Trial Standard Level 2 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,399 1,465 1,543 1,623 1,690 Electricity Sales (TWh) 0.00 0.00 -1.60 -6.13 -10.61 -14.28 -17.13 -19.40 -20.61

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,089 2,128 2,205 2,301 Coal (TWh) 0.00 0.05 0.24 -1.21 -1.81 -3.81 -4.14 -4.14 -4.14

Gas (TWh) 759 858 691 767 879 1,011 1,088 Gas (TWh) 0.00 0.42 1.00 -2.10 -6.16 -6.75 -6.90 -6.90 -6.90

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.00 0.00 0.00 -0.02 -0.04 -0.07 -0.08 -0.08 -0.08

Nuclear (TWh) 782 813 834 883 886 886 894 Nuclear (TWh) 0.00 0.00 0.00 0.00 0.00 0.00 -0.65 -0.65 -0.65

Renewables (TWh) 358 462 646 711 793 846 885 Renewables (TWh) 0.00 -0.46 -2.96 -2.87 -3.64 -3.77 -4.98 -4.98 -4.98

Total (TWh) 4,034 4,005 4,255 4,496 4,734 4,997 5,217 Total (TWh) 0.00 0.01 -1.72 -6.21 -11.66 -14.40 -16.75 -16.75 -16.75

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 336 Coal (GW) 0.00 0.00 -0.10 -0.09 -0.09 -0.20 -0.17 -0.17 -0.17

Other Fossil (GW) 439 468 445 445 466 500 533 Other Fossil (GW) 0.00 0.00 -0.28 -0.42 -0.90 -1.16 -1.26 -1.26 -1.26

Nuclear (GW) 100 102 105 111 111 111 112 Nuclear (GW) 0.00 0.00 0.00 0.00 0.00 0.00 -0.09 -0.09 -0.09

Renewables (GW) 99 133 171 176 185 195 208 Renewables (GW) 0.00 -0.13 -0.83 -0.84 -0.78 -0.82 -1.12 -1.12 -1.12

Total (GW) 952 1,024 1,045 1,058 1,089 1,136 1,190 Total (GW) 0.00 -0.13 -1.21 -1.35 -1.78 -2.18 -2.63 -2.63 -2.63

Extrapolation
14-6

Table 14.3.4 Standard-Size Refrigerator-Freezers: Trial Standard Level 3 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,398 1,464 1,541 1,620 1,687 Electricity Sales (TWh) 0.00 0.00 -1.87 -7.21 -12.48 -16.80 -20.15 -22.81 -24.21

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,089 2,128 2,205 2,300 Coal (TWh) 0.00 0.06 0.28 -1.42 -2.14 -4.48 -4.86 -4.86 -4.86

Gas (TWh) 759 858 691 767 878 1,010 1,087 Gas (TWh) 0.00 0.49 1.17 -2.47 -7.25 -7.94 -8.11 -8.11 -8.11

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.00 0.00 0.00 -0.03 -0.05 -0.08 -0.10 -0.10 -0.10

Nuclear (TWh) 782 813 834 883 886 886 894 Nuclear (TWh) 0.00 0.00 0.00 0.00 0.00 0.00 -0.77 -0.77 -0.77

Renewables (TWh) 358 462 645 710 793 846 884 Renewables (TWh) 0.00 -0.54 -3.45 -3.37 -4.28 -4.44 -5.85 -5.85 -5.85

Total (TWh) 4,034 4,005 4,255 4,495 4,732 4,995 5,214 Total (TWh) 0.00 0.01 -2.01 -7.29 -13.72 -16.94 -19.70 -19.70 -19.70

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 336 Coal (GW) 0.00 0.00 -0.12 -0.11 -0.11 -0.24 -0.20 -0.20 -0.20

Other Fossil (GW) 439 468 445 445 466 500 532 Other Fossil (GW) 0.00 0.00 -0.33 -0.49 -1.06 -1.36 -1.48 -1.48 -1.48

Nuclear (GW) 100 102 105 111 111 111 112 Nuclear (GW) 0.00 0.00 0.00 0.00 0.00 0.00 -0.11 -0.11 -0.11

Renewables (GW) 99 133 171 176 185 195 208 Renewables (GW) 0.00 -0.16 -0.97 -0.99 -0.92 -0.97 -1.32 -1.32 -1.32

Total (GW) 952 1,024 1,045 1,057 1,089 1,136 1,189 Total (GW) 0.00 -0.16 -1.42 -1.58 -2.09 -2.57 -3.10 -3.10 -3.10

Extrapolation
14-7

Table 14.3.5 Standard-Size Refrigerator-Freezers: Trial Standard Level 4 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,398 1,462 1,537 1,614 1,680 Electricity Sales (TWh) 0.00 0.00 -2.46 -9.65 -16.87 -22.85 -27.51 -31.24 -33.20

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,088 2,127 2,203 2,298 Coal (TWh) 0.00 0.08 0.37 -1.91 -2.89 -6.09 -6.64 -6.64 -6.64

Gas (TWh) 759 858 692 766 876 1,007 1,084 Gas (TWh) 0.00 0.63 1.54 -3.31 -9.80 -10.80 -11.08 -11.08 -11.08

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.00 0.00 0.00 -0.04 -0.06 -0.11 -0.14 -0.14 -0.14

Nuclear (TWh) 782 813 834 883 886 886 894 Nuclear (TWh) 0.00 0.00 0.00 0.00 0.00 0.00 -1.05 -1.05 -1.05

Renewables (TWh) 358 462 644 709 791 844 882 Renewables (TWh) 0.00 -0.70 -4.54 -4.51 -5.79 -6.03 -7.99 -7.99 -7.99

Total (TWh) 4,034 4,005 4,255 4,493 4,727 4,989 5,207 Total (TWh) 0.00 0.01 -2.64 -9.76 -18.54 -23.03 -26.90 -26.90 -26.90

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 336 Coal (GW) 0.00 0.00 -0.16 -0.14 -0.15 -0.32 -0.27 -0.27 -0.27

Other Fossil (GW) 439 468 445 445 466 499 532 Other Fossil (GW) 0.00 0.00 -0.43 -0.66 -1.44 -1.85 -2.02 -2.02 -2.02

Nuclear (GW) 100 102 105 111 111 111 112 Nuclear (GW) 0.00 0.00 0.00 0.00 0.00 0.00 -0.14 -0.14 -0.14

Renewables (GW) 99 132 170 175 185 194 208 Renewables (GW) 0.00 -0.20 -1.28 -1.32 -1.24 -1.32 -1.80 -1.80 -1.80

Total (GW) 952 1,024 1,044 1,057 1,088 1,135 1,188 Total (GW) 0.00 -0.21 -1.87 -2.12 -2.83 -3.49 -4.23 -4.23 -4.23

Extrapolation
14-8

Table 14.3.6 Standard-Size Refrigerator-Freezers: Trial Standard Level 5 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,397 1,460 1,533 1,610 1,674 Electricity Sales (TWh) 0.00 0.00 -2.82 -11.34 -20.02 -27.27 -32.94 -37.48 -39.87

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,039 2,088 2,126 2,202 2,297 Coal (TWh) 0.00 0.09 0.43 -2.24 -3.43 -7.27 -7.95 -7.95 -7.95

Gas (TWh) 759 858 692 765 874 1,005 1,082 Gas (TWh) 0.00 0.72 1.76 -3.88 -11.63 -12.89 -13.27 -13.27 -13.27

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.00 0.00 0.00 -0.04 -0.08 -0.13 -0.16 -0.16 -0.16

Nuclear (TWh) 782 813 834 883 886 886 893 Nuclear (TWh) 0.00 0.00 0.00 0.00 0.00 0.00 -1.26 -1.26 -1.26

Renewables (TWh) 358 462 643 708 790 843 881 Renewables (TWh) 0.00 -0.79 -5.21 -5.31 -6.87 -7.20 -9.57 -9.57 -9.57

Total (TWh) 4,034 4,005 4,254 4,491 4,724 4,984 5,202 Total (TWh) 0.00 0.02 -3.03 -11.47 -22.00 -27.49 -32.21 -32.21 -32.21

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 336 Coal (GW) 0.00 0.00 -0.18 -0.17 -0.18 -0.38 -0.32 -0.32 -0.32

Other Fossil (GW) 439 468 445 445 466 499 531 Other Fossil (GW) 0.00 0.00 -0.50 -0.77 -1.71 -2.21 -2.42 -2.42 -2.42

Nuclear (GW) 100 102 105 111 111 111 112 Nuclear (GW) 0.00 0.00 0.00 0.00 0.00 0.00 -0.17 -0.17 -0.17

Renewables (GW) 99 132 170 175 185 194 207 Renewables (GW) 0.00 -0.23 -1.46 -1.55 -1.47 -1.58 -2.15 -2.15 -2.15

Total (GW) 952 1,024 1,044 1,056 1,087 1,134 1,187 Total (GW) 0.00 -0.23 -2.14 -2.49 -3.35 -4.16 -5.07 -5.07 -5.07

Extrapolation
14-9

Table 14.3.7 Standard-Size Freezers: Trial Standard Level 1 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,400 1,470 1,551 1,633 1,703 Electricity Sales (TWh) 0.00 0.00 -0.41 -1.53 -2.70 -3.84 -4.81 -5.60 -5.98

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,129 2,208 2,303 Coal (TWh) 0.00 0.01 0.06 -0.30 -0.46 -1.02 -1.16 -1.16 -1.16

Gas (TWh) 759 857 691 769 884 1,016 1,093 Gas (TWh) 0.00 0.11 0.26 -0.52 -1.57 -1.81 -1.94 -1.94 -1.94

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.00 0.00 0.00 -0.01 -0.01 -0.02 -0.02 -0.02 -0.02

Nuclear (TWh) 782 813 834 883 886 886 895 Nuclear (TWh) 0.00 0.00 0.00 0.00 0.00 0.00 -0.18 -0.18 -0.18

Renewables (TWh) 358 462 648 713 796 849 889 Renewables (TWh) 0.00 -0.12 -0.76 -0.71 -0.93 -1.01 -1.40 -1.40 -1.40

Total (TWh) 4,034 4,005 4,257 4,501 4,743 5,008 5,229 Total (TWh) 0.00 0.00 -0.44 -1.55 -2.97 -3.87 -4.71 -4.71 -4.71

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 336 Coal (GW) 0.000 0.000 -0.027 -0.023 -0.024 -0.054 -0.047 -0.047 -0.047

Other Fossil (GW) 439 468 445 446 467 501 533 Other Fossil (GW) 0.000 0.000 -0.073 -0.104 -0.230 -0.310 -0.353 -0.353 -0.353

Nuclear (GW) 100 102 105 111 111 111 112 Nuclear (GW) 0.000 0.000 0.000 0.000 0.000 0.000 -0.025 -0.025 -0.025

Renewables (GW) 99 133 171 176 186 196 209 Renewables (GW) 0.000 -0.035 -0.215 -0.209 -0.199 -0.222 -0.315 -0.315 -0.315

Total (GW) 952 1,024 1,046 1,059 1,090 1,137 1,191 Total (GW) 0.000 -0.035 -0.314 -0.336 -0.453 -0.586 -0.740 -0.740 -0.740

Extrapolation
14-10

Table 14.3.8 Standard-Size Freezers: Trial Standard Level 2 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,400 1,470 1,551 1,633 1,703 Electricity Sales (TWh) 0.00 0.00 -0.41 -1.53 -2.70 -3.84 -4.81 -5.60 -5.98

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,129 2,208 2,303 Coal (TWh) 0.00 0.01 0.06 -0.30 -0.46 -1.02 -1.16 -1.16 -1.16

Gas (TWh) 759 857 691 769 884 1,016 1,093 Gas (TWh) 0.00 0.11 0.26 -0.52 -1.57 -1.81 -1.94 -1.94 -1.94

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.00 0.00 0.00 -0.01 -0.01 -0.02 -0.02 -0.02 -0.02

Nuclear (TWh) 782 813 834 883 886 886 895 Nuclear (TWh) 0.00 0.00 0.00 0.00 0.00 0.00 -0.18 -0.18 -0.18

Renewables (TWh) 358 462 648 713 796 849 889 Renewables (TWh) 0.00 -0.12 -0.76 -0.71 -0.93 -1.01 -1.40 -1.40 -1.40

Total (TWh) 4,034 4,005 4,257 4,501 4,743 5,008 5,229 Total (TWh) 0.00 0.00 -0.44 -1.55 -2.97 -3.87 -4.71 -4.71 -4.71

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 336 Coal (GW) 0.000 0.000 -0.027 -0.023 -0.024 -0.054 -0.047 -0.047 -0.047

Other Fossil (GW) 439 468 445 446 467 501 533 Other Fossil (GW) 0.000 0.000 -0.073 -0.104 -0.230 -0.310 -0.353 -0.353 -0.353

Nuclear (GW) 100 102 105 111 111 111 112 Nuclear (GW) 0.000 0.000 0.000 0.000 0.000 0.000 -0.025 -0.025 -0.025

Renewables (GW) 99 133 171 176 186 196 209 Renewables (GW) 0.000 -0.035 -0.215 -0.209 -0.199 -0.222 -0.315 -0.315 -0.315

Total (GW) 952 1,024 1,046 1,059 1,090 1,137 1,191 Total (GW) 0.000 -0.035 -0.314 -0.336 -0.453 -0.586 -0.740 -0.740 -0.740

Extrapolation
14-11

Table 14.3.9 Standard-Size Freezers: Trial Standard Level 3 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,400 1,469 1,549 1,631 1,699 Electricity Sales (TWh) 0.00 0.00 -0.67 -2.54 -4.54 -6.48 -8.14 -9.46 -10.11

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,129 2,208 2,303 Coal (TWh) 0.00 0.02 0.10 -0.50 -0.78 -1.73 -1.97 -1.97 -1.97

Gas (TWh) 759 857 691 768 883 1,015 1,092 Gas (TWh) 0.00 0.17 0.42 -0.87 -2.64 -3.06 -3.28 -3.28 -3.28

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.00 0.00 0.00 -0.01 -0.02 -0.03 -0.04 -0.04 -0.04

Nuclear (TWh) 782 813 834 883 886 886 894 Nuclear (TWh) 0.00 0.00 0.00 0.00 0.00 0.00 -0.31 -0.31 -0.31

Renewables (TWh) 358 462 647 713 795 848 888 Renewables (TWh) 0.00 -0.19 -1.23 -1.19 -1.56 -1.71 -2.37 -2.37 -2.37

Total (TWh) 4,034 4,005 4,256 4,500 4,741 5,005 5,226 Total (TWh) 0.00 0.00 -0.72 -2.57 -4.99 -6.53 -7.96 -7.96 -7.96

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 336 Coal (GW) 0.00 0.00 -0.04 -0.04 -0.04 -0.09 -0.08 -0.08 -0.08

Other Fossil (GW) 439 468 445 446 467 501 533 Other Fossil (GW) 0.00 0.00 -0.12 -0.17 -0.39 -0.52 -0.60 -0.60 -0.60

Nuclear (GW) 100 102 105 111 111 111 112 Nuclear (GW) 0.00 0.00 0.00 0.00 0.00 0.00 -0.04 -0.04 -0.04

Renewables (GW) 99 133 171 176 186 195 209 Renewables (GW) 0.00 -0.06 -0.35 -0.35 -0.33 -0.37 -0.53 -0.53 -0.53

Total (GW) 952 1,024 1,045 1,058 1,090 1,137 1,191 Total (GW) 0.00 -0.06 -0.51 -0.56 -0.76 -0.99 -1.25 -1.25 -1.25

Extrapolation
14-12

Table 14.3.10 Standard-Size Freezers: Trial Standard Level 4 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,399 1,469 1,548 1,630 1,698 Electricity Sales (TWh) 0.00 0.00 -0.74 -2.85 -5.14 -7.36 -9.25 -10.74 -11.47

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,129 2,207 2,302 Coal (TWh) 0.00 0.02 0.11 -0.56 -0.88 -1.96 -2.23 -2.23 -2.23

Gas (TWh) 759 857 691 768 883 1,015 1,091 Gas (TWh) 0.00 0.19 0.46 -0.98 -2.99 -3.48 -3.72 -3.72 -3.72

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.00 0.00 0.00 -0.01 -0.02 -0.03 -0.05 -0.05 -0.05

Nuclear (TWh) 782 813 834 883 886 886 894 Nuclear (TWh) 0.00 0.00 0.00 0.00 0.00 0.00 -0.35 -0.35 -0.35

Renewables (TWh) 358 462 647 712 795 848 888 Renewables (TWh) 0.00 -0.21 -1.36 -1.34 -1.76 -1.94 -2.69 -2.69 -2.69

Total (TWh) 4,034 4,005 4,256 4,500 4,740 5,004 5,225 Total (TWh) 0.00 0.00 -0.79 -2.89 -5.65 -7.42 -9.04 -9.04 -9.04

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 336 Coal (GW) 0.00 0.00 -0.05 -0.04 -0.05 -0.10 -0.09 -0.09 -0.09

Other Fossil (GW) 439 468 445 445 467 501 533 Other Fossil (GW) 0.00 0.00 -0.13 -0.19 -0.44 -0.60 -0.68 -0.68 -0.68

Nuclear (GW) 100 102 105 111 111 111 112 Nuclear (GW) 0.00 0.00 0.00 0.00 0.00 0.00 -0.05 -0.05 -0.05

Renewables (GW) 99 133 171 176 186 195 209 Renewables (GW) 0.00 -0.06 -0.38 -0.39 -0.38 -0.42 -0.60 -0.60 -0.60

Total (GW) 952 1,024 1,045 1,058 1,090 1,137 1,191 Total (GW) 0.00 -0.06 -0.56 -0.63 -0.86 -1.12 -1.42 -1.42 -1.42

Extrapolation
14-13

Table 14.3.12 Standard-Size Freezers: Trial Standard Level 5 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,399 1,469 1,548 1,629 1,697 Electricity Sales (TWh) 0.00 0.00 -0.74 -3.00 -5.48 -7.88 -9.92 -11.50 -12.25

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,129 2,207 2,302 Coal (TWh) 0.00 0.02 0.11 -0.59 -0.94 -2.10 -2.39 -2.39 -2.39

Gas (TWh) 759 857 691 768 882 1,014 1,091 Gas (TWh) 0.00 0.19 0.46 -1.03 -3.19 -3.73 -3.99 -3.99 -3.99

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.00 0.00 0.00 -0.01 -0.02 -0.04 -0.05 -0.05 -0.05

Nuclear (TWh) 782 813 834 883 886 886 894 Nuclear (TWh) 0.00 0.00 0.00 0.00 0.00 0.00 -0.38 -0.38 -0.38

Renewables (TWh) 358 462 647 712 795 848 887 Renewables (TWh) 0.00 -0.21 -1.37 -1.40 -1.88 -2.08 -2.88 -2.88 -2.88

Total (TWh) 4,034 4,005 4,256 4,500 4,740 5,004 5,224 Total (TWh) 0.00 0.00 -0.80 -3.03 -6.02 -7.95 -9.70 -9.70 -9.70

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 336 Coal (GW) 0.00 0.00 -0.05 -0.04 -0.05 -0.11 -0.10 -0.10 -0.10

Other Fossil (GW) 439 468 445 445 467 501 533 Other Fossil (GW) 0.00 0.00 -0.13 -0.20 -0.47 -0.64 -0.73 -0.73 -0.73

Nuclear (GW) 100 102 105 111 111 111 112 Nuclear (GW) 0.00 0.00 0.00 0.00 0.00 0.00 -0.05 -0.05 -0.05

Renewables (GW) 99 133 171 176 186 195 209 Renewables (GW) 0.00 -0.06 -0.39 -0.41 -0.40 -0.46 -0.65 -0.65 -0.65

Total (GW) 952 1,024 1,045 1,058 1,090 1,137 1,191 Total (GW) 0.00 -0.06 -0.56 -0.66 -0.92 -1.20 -1.53 -1.53 -1.53

Extrapolation
14-14

Table 14.3.13 Compact Refrigeration Products: Trial Standard Level 1 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,400 1,471 1,552 1,635 1,706 Electricity Sales (TWh) 0.000 0.000 -0.365 -1.029 -1.327 -1.539 -1.759 -1.991 -2.136

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,130 2,209 2,304 Coal (TWh) 0.000 0.012 0.055 -0.203 -0.227 -0.410 -0.425 -0.425 -0.425

Gas (TWh) 759 857 691 769 885 1,017 1,094 Gas (TWh) 0.000 0.097 0.228 -0.352 -0.771 -0.728 -0.708 -0.708 -0.708

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.000 0.000 -0.001 -0.004 -0.005 -0.007 -0.009 -0.009 -0.009

Nuclear (TWh) 782 813 834 883 886 886 895 Nuclear (TWh) 0.000 0.000 0.000 0.000 0.000 0.000 -0.067 -0.067 -0.067

Renewables (TWh) 358 462 648 713 796 850 890 Renewables (TWh) 0.000 -0.107 -0.673 -0.481 -0.455 -0.406 -0.511 -0.511 -0.511

Total (TWh) 4,034 4,005 4,257 4,502 4,744 5,010 5,232 Total (TWh) 0.000 0.002 -0.391 -1.041 -1.459 -1.551 -1.720 -1.720 -1.720

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 337 Coal (GW) 0.000 0.000 -0.023 -0.015 -0.012 -0.022 -0.017 -0.017 -0.017

Other Fossil (GW) 439 468 445 446 467 501 534 Other Fossil (GW) 0.000 0.000 -0.064 -0.070 -0.113 -0.125 -0.129 -0.129 -0.129

Nuclear (GW) 100 102 105 111 111 111 113 Nuclear (GW) 0.000 0.000 0.000 0.000 0.000 0.000 -0.009 -0.009 -0.009

Renewables (GW) 99 133 171 176 186 196 209 Renewables (GW) 0.000 -0.031 -0.189 -0.141 -0.098 -0.089 -0.115 -0.115 -0.115

Total (GW) 952 1,024 1,046 1,059 1,091 1,138 1,192 Total (GW) 0.000 -0.032 -0.277 -0.226 -0.222 -0.235 -0.271 -0.271 -0.271

Extrapolation
14-15

Table 14.3.14 Compact Refrigeration Products: Trial Standard Level 2 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,400 1,470 1,552 1,635 1,705 Electricity Sales (TWh) 0.00 0.00 -0.44 -1.25 -1.60 -1.85 -2.11 -2.38 -2.55

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,129 2,209 2,304 Coal (TWh) 0.00 0.01 0.07 -0.25 -0.27 -0.49 -0.51 -0.51 -0.51

Gas (TWh) 759 857 691 769 885 1,017 1,094 Gas (TWh) 0.00 0.12 0.28 -0.43 -0.93 -0.87 -0.85 -0.85 -0.85

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.00 0.00 0.00 0.00 -0.01 -0.01 -0.01 -0.01 -0.01

Nuclear (TWh) 782 813 834 883 886 886 895 Nuclear (TWh) 0.00 0.00 0.00 0.00 0.00 0.00 -0.08 -0.08 -0.08

Renewables (TWh) 358 462 648 713 796 850 890 Renewables (TWh) 0.00 -0.13 -0.81 -0.58 -0.55 -0.49 -0.61 -0.61 -0.61

Total (TWh) 4,034 4,005 4,257 4,501 4,744 5,010 5,232 Total (TWh) 0.00 0.00 -0.47 -1.26 -1.76 -1.86 -2.06 -2.06 -2.06

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 336 Coal (GW) 0.000 0.000 -0.028 -0.019 -0.014 -0.026 -0.021 -0.021 -0.021

Other Fossil (GW) 439 468 445 446 467 501 534 Other Fossil (GW) 0.000 0.000 -0.077 -0.085 -0.136 -0.150 -0.155 -0.155 -0.155

Nuclear (GW) 100 102 105 111 111 111 113 Nuclear (GW) 0.000 0.000 0.000 0.000 0.000 0.000 -0.011 -0.011 -0.011

Renewables (GW) 99 133 171 176 186 196 209 Renewables (GW) 0.000 -0.038 -0.228 -0.171 -0.118 -0.107 -0.138 -0.138 -0.138

Total (GW) 952 1,024 1,046 1,059 1,091 1,138 1,192 Total (GW) 0.000 -0.038 -0.334 -0.274 -0.268 -0.283 -0.324 -0.324 -0.324

Extrapolation
14-16

Table 14.3.15 Compact Refrigeration Products: Trial Standard Level 3 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,400 1,470 1,551 1,635 1,705 Electricity Sales (TWh) 0.00 0.00 -0.52 -1.49 -1.91 -2.19 -2.49 -2.80 -2.99

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,129 2,209 2,304 Coal (TWh) 0.00 0.02 0.08 -0.29 -0.33 -0.59 -0.60 -0.60 -0.60

Gas (TWh) 759 857 691 769 884 1,017 1,094 Gas (TWh) 0.00 0.14 0.33 -0.51 -1.11 -1.04 -1.00 -1.00 -1.00

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.00 0.00 0.00 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01

Nuclear (TWh) 782 813 834 883 886 886 895 Nuclear (TWh) 0.00 0.00 0.00 0.00 0.00 0.00 -0.10 -0.10 -0.10

Renewables (TWh) 358 462 648 713 796 850 890 Renewables (TWh) 0.00 -0.15 -0.97 -0.70 -0.65 -0.58 -0.72 -0.72 -0.72

Total (TWh) 4,034 4,005 4,257 4,501 4,744 5,010 5,231 Total (TWh) 0.00 0.00 -0.56 -1.51 -2.10 -2.21 -2.44 -2.44 -2.44

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 336 Coal (GW) 0.000 0.000 -0.034 -0.022 -0.017 -0.031 -0.024 -0.024 -0.024

Other Fossil (GW) 439 468 445 446 467 501 534 Other Fossil (GW) 0.000 0.000 -0.092 -0.101 -0.163 -0.178 -0.183 -0.183 -0.183

Nuclear (GW) 100 102 105 111 111 111 113 Nuclear (GW) 0.000 0.000 0.000 0.000 0.000 0.000 -0.013 -0.013 -0.013

Renewables (GW) 99 133 171 176 186 196 209 Renewables (GW) 0.000 -0.045 -0.272 -0.204 -0.140 -0.127 -0.163 -0.163 -0.163

Total (GW) 952 1,024 1,046 1,059 1,091 1,138 1,192 Total (GW) 0.000 -0.045 -0.398 -0.327 -0.320 -0.335 -0.383 -0.383 -0.383

Extrapolation
14-17

Table 14.3.16 Compact Refrigeration Products: Trial Standard Level 4 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,400 1,470 1,551 1,634 1,704 Electricity Sales (TWh) 0.00 0.00 -0.67 -1.92 -2.44 -2.76 -3.09 -3.43 -3.64

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,129 2,209 2,304 Coal (TWh) 0.00 0.02 0.10 -0.38 -0.42 -0.74 -0.75 -0.75 -0.75

Gas (TWh) 759 857 691 768 884 1,017 1,094 Gas (TWh) 0.00 0.18 0.42 -0.66 -1.42 -1.31 -1.24 -1.24 -1.24

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.00 0.00 0.00 -0.01 -0.01 -0.01 -0.02 -0.02 -0.02

Nuclear (TWh) 782 813 834 883 886 886 895 Nuclear (TWh) 0.00 0.00 0.00 0.00 0.00 0.00 -0.12 -0.12 -0.12

Renewables (TWh) 358 462 647 713 796 849 889 Renewables (TWh) 0.00 -0.19 -1.23 -0.90 -0.84 -0.73 -0.90 -0.90 -0.90

Total (TWh) 4,034 4,005 4,256 4,501 4,743 5,009 5,231 Total (TWh) 0.00 0.00 -0.72 -1.94 -2.68 -2.79 -3.02 -3.02 -3.02

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 336 Coal (GW) 0.000 0.000 -0.043 -0.029 -0.022 -0.039 -0.030 -0.030 -0.030

Other Fossil (GW) 439 468 445 446 467 501 534 Other Fossil (GW) 0.000 -0.001 -0.117 -0.131 -0.208 -0.224 -0.227 -0.227 -0.227

Nuclear (GW) 100 102 105 111 111 111 113 Nuclear (GW) 0.000 0.000 0.000 0.000 0.000 0.000 -0.016 -0.016 -0.016

Renewables (GW) 99 133 171 176 186 196 209 Renewables (GW) 0.000 -0.056 -0.346 -0.263 -0.179 -0.160 -0.202 -0.202 -0.202

Total (GW) 952 1,024 1,045 1,059 1,090 1,138 1,192 Total (GW) 0.000 -0.057 -0.506 -0.423 -0.409 -0.422 -0.475 -0.475 -0.475

Extrapolation
14-18

Table 14.3.17 Compact Refrigeration Products: Trial Standard Level 5 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,399 1,469 1,551 1,634 1,704 Electricity Sales (TWh) 0.00 0.00 -0.73 -2.26 -2.80 -3.04 -3.29 -3.55 -3.70

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,129 2,208 2,304 Coal (TWh) 0.00 0.02 0.11 -0.45 -0.48 -0.81 -0.79 -0.79 -0.79

Gas (TWh) 759 857 691 768 884 1,017 1,094 Gas (TWh) 0.00 0.18 0.45 -0.77 -1.62 -1.44 -1.33 -1.33 -1.33

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.00 0.00 0.00 -0.01 -0.01 -0.01 -0.02 -0.02 -0.02

Nuclear (TWh) 782 813 834 883 886 886 895 Nuclear (TWh) 0.00 0.00 0.00 0.00 0.00 0.00 -0.13 -0.13 -0.13

Renewables (TWh) 358 462 647 713 796 849 889 Renewables (TWh) 0.00 -0.20 -1.34 -1.06 -0.96 -0.80 -0.96 -0.96 -0.96

Total (TWh) 4,034 4,005 4,256 4,500 4,743 5,009 5,231 Total (TWh) 0.00 0.00 -0.78 -2.28 -3.07 -3.07 -3.22 -3.22 -3.22

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 336 Coal (GW) 0.000 0.000 -0.047 -0.034 -0.025 -0.043 -0.032 -0.032 -0.032

Other Fossil (GW) 439 468 445 446 467 501 534 Other Fossil (GW) 0.000 -0.001 -0.127 -0.153 -0.238 -0.246 -0.242 -0.242 -0.242

Nuclear (GW) 100 102 105 111 111 111 112 Nuclear (GW) 0.000 0.000 0.000 0.000 0.000 0.000 -0.017 -0.017 -0.017

Renewables (GW) 99 133 171 176 186 196 209 Renewables (GW) 0.000 -0.058 -0.377 -0.309 -0.206 -0.176 -0.215 -0.215 -0.215

Total (GW) 952 1,024 1,045 1,058 1,090 1,138 1,192 Total (GW) 0.000 -0.058 -0.551 -0.497 -0.469 -0.465 -0.506 -0.506 -0.506

Extrapolation
14-19

Table 14.3.18 Built-In Refrigeration Products: Trial Standard Level 1 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,400 1,472 1,553 1,637 1,707 Electricity Sales (TWh) 0.000 0.000 -0.011 -0.042 -0.073 -0.099 -0.121 -0.138 -0.148

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,130 2,209 2,305 Coal (TWh) 0.000 0.000 0.002 -0.008 -0.012 -0.026 -0.029 -0.029 -0.029

Gas (TWh) 759 857 690 769 885 1,018 1,095 Gas (TWh) 0.000 0.003 0.007 -0.014 -0.042 -0.047 -0.049 -0.049 -0.049

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.000 0.000 0.000 0.000 0.000 0.000 -0.001 -0.001 -0.001

Nuclear (TWh) 782 813 834 883 886 886 895 Nuclear (TWh) 0.000 0.000 0.000 0.000 0.000 0.000 -0.005 -0.005 -0.005

Renewables (TWh) 358 462 648 714 797 850 890 Renewables (TWh) 0.000 -0.003 -0.021 -0.020 -0.025 -0.026 -0.035 -0.035 -0.035

Total (TWh) 4,034 4,005 4,257 4,503 4,746 5,012 5,234 Total (TWh) 0.000 0.000 -0.012 -0.042 -0.080 -0.100 -0.118 -0.118 -0.118

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 337 Coal (GW) 0.000 0.000 -0.001 -0.001 -0.001 -0.001 -0.001 -0.001 -0.001

Other Fossil (GW) 439 468 445 446 467 501 534 Other Fossil (GW) 0.000 0.000 -0.002 -0.003 -0.006 -0.008 -0.009 -0.009 -0.009

Nuclear (GW) 100 102 105 111 111 111 113 Nuclear (GW) 0.000 0.000 0.000 0.000 0.000 0.000 -0.001 -0.001 -0.001

Renewables (GW) 99 133 171 177 186 196 209 Renewables (GW) 0.000 -0.001 -0.006 -0.006 -0.005 -0.006 -0.008 -0.008 -0.008

Total (GW) 952 1,024 1,046 1,059 1,091 1,138 1,192 Total (GW) 0.000 -0.001 -0.008 -0.009 -0.012 -0.015 -0.019 -0.019 -0.019

Extrapolation
14-20

Table 14.3.19 Built-In Refrigeration Products: Trial Standard Level 2 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,400 1,472 1,553 1,637 1,707 Electricity Sales (TWh) 0.000 0.000 -0.016 -0.060 -0.105 -0.144 -0.176 -0.202 -0.216

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,130 2,209 2,305 Coal (TWh) 0.000 0.001 0.002 -0.012 -0.018 -0.038 -0.043 -0.043 -0.043

Gas (TWh) 759 857 690 769 885 1,018 1,095 Gas (TWh) 0.000 0.004 0.010 -0.021 -0.061 -0.068 -0.071 -0.071 -0.071

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.000 0.000 0.000 0.000 0.000 -0.001 -0.001 -0.001 -0.001

Nuclear (TWh) 782 813 834 883 886 886 895 Nuclear (TWh) 0.000 0.000 0.000 0.000 0.000 0.000 -0.007 -0.007 -0.007

Renewables (TWh) 358 462 648 714 797 850 890 Renewables (TWh) 0.000 -0.005 -0.029 -0.028 -0.036 -0.038 -0.051 -0.051 -0.051

Total (TWh) 4,034 4,005 4,257 4,503 4,746 5,012 5,234 Total (TWh) 0.000 0.000 -0.017 -0.061 -0.115 -0.145 -0.172 -0.172 -0.172

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 337 Coal (GW) 0.000 0.000 -0.001 -0.001 -0.001 -0.002 -0.002 -0.002 -0.002

Other Fossil (GW) 439 468 445 446 467 501 534 Other Fossil (GW) 0.000 0.000 -0.003 -0.004 -0.009 -0.012 -0.013 -0.013 -0.013

Nuclear (GW) 100 102 105 111 111 111 113 Nuclear (GW) 0.000 0.000 0.000 0.000 0.000 0.000 -0.001 -0.001 -0.001

Renewables (GW) 99 133 171 177 186 196 209 Renewables (GW) 0.000 -0.001 -0.008 -0.008 -0.008 -0.008 -0.012 -0.012 -0.012

Total (GW) 952 1,024 1,046 1,059 1,091 1,138 1,192 Total (GW) 0.000 -0.001 -0.012 -0.013 -0.018 -0.022 -0.027 -0.027 -0.027

Extrapolation
14-21

Table 14.3.20 Built-In Refrigeration Products: Trial Standard Level 3 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,400 1,471 1,553 1,637 1,707 Electricity Sales (TWh) 0.000 0.000 -0.032 -0.120 -0.210 -0.288 -0.351 -0.403 -0.431

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,130 2,209 2,305 Coal (TWh) 0.000 0.001 0.005 -0.024 -0.036 -0.077 -0.085 -0.085 -0.085

Gas (TWh) 759 857 690 769 885 1,018 1,095 Gas (TWh) 0.000 0.008 0.020 -0.041 -0.122 -0.136 -0.141 -0.141 -0.141

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.000 0.000 0.000 0.000 -0.001 -0.001 -0.002 -0.002 -0.002

Nuclear (TWh) 782 813 834 883 886 886 895 Nuclear (TWh) 0.000 0.000 0.000 0.000 0.000 0.000 -0.013 -0.013 -0.013

Renewables (TWh) 358 462 648 714 797 850 890 Renewables (TWh) 0.000 -0.009 -0.058 -0.056 -0.072 -0.076 -0.102 -0.102 -0.102

Total (TWh) 4,034 4,005 4,257 4,502 4,746 5,011 5,233 Total (TWh) 0.000 0.000 -0.034 -0.122 -0.230 -0.290 -0.343 -0.343 -0.343

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 337 Coal (GW) 0.000 0.000 -0.002 -0.002 -0.002 -0.004 -0.003 -0.003 -0.003

Other Fossil (GW) 439 468 445 446 467 501 534 Other Fossil (GW) 0.000 0.000 -0.006 -0.008 -0.018 -0.023 -0.026 -0.026 -0.026

Nuclear (GW) 100 102 105 111 111 111 113 Nuclear (GW) 0.000 0.000 0.000 0.000 0.000 0.000 -0.002 -0.002 -0.002

Renewables (GW) 99 133 171 177 186 196 209 Renewables (GW) 0.000 -0.003 -0.016 -0.016 -0.015 -0.017 -0.023 -0.023 -0.023

Total (GW) 952 1,024 1,046 1,059 1,091 1,138 1,192 Total (GW) 0.000 -0.003 -0.024 -0.026 -0.035 -0.044 -0.054 -0.054 -0.054

Extrapolation
14-22

Table 14.3.21 Built-In Refrigeration Products: Trial Standard Level 4 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,400 1,471 1,553 1,637 1,707 Electricity Sales (TWh) 0.000 0.000 -0.040 -0.151 -0.262 -0.357 -0.435 -0.498 -0.532

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,130 2,209 2,305 Coal (TWh) 0.000 0.001 0.006 -0.030 -0.045 -0.095 -0.105 -0.105 -0.105

Gas (TWh) 759 857 690 769 885 1,018 1,095 Gas (TWh) 0.000 0.010 0.025 -0.052 -0.152 -0.169 -0.175 -0.175 -0.175

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.000 0.000 0.000 -0.001 -0.001 -0.002 -0.002 -0.002 -0.002

Nuclear (TWh) 782 813 834 883 886 886 895 Nuclear (TWh) 0.000 0.000 0.000 0.000 0.000 0.000 -0.017 -0.017 -0.017

Renewables (TWh) 358 462 648 714 797 850 890 Renewables (TWh) 0.000 -0.012 -0.074 -0.071 -0.090 -0.094 -0.126 -0.126 -0.126

Total (TWh) 4,034 4,005 4,257 4,502 4,746 5,011 5,233 Total (TWh) 0.000 0.000 -0.043 -0.153 -0.288 -0.360 -0.425 -0.425 -0.425

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 337 Coal (GW) 0.000 0.000 -0.003 -0.002 -0.002 -0.005 -0.004 -0.004 -0.004

Other Fossil (GW) 439 468 445 446 467 501 534 Other Fossil (GW) 0.000 0.000 -0.007 -0.010 -0.022 -0.029 -0.032 -0.032 -0.032

Nuclear (GW) 100 102 105 111 111 111 113 Nuclear (GW) 0.000 0.000 0.000 0.000 0.000 0.000 -0.002 -0.002 -0.002

Renewables (GW) 99 133 171 177 186 196 209 Renewables (GW) 0.000 -0.003 -0.021 -0.021 -0.019 -0.021 -0.028 -0.028 -0.028

Total (GW) 952 1,024 1,046 1,059 1,091 1,138 1,192 Total (GW) 0.000 -0.003 -0.030 -0.033 -0.044 -0.055 -0.067 -0.067 -0.067

Extrapolation
14-23

Table 14.3.22 Built-In Refrigeration Products: Trial Standard Level 5 Forecast

NEMS-BT Results: Difference from AEO2010 Reference Case

2005 2010 2015 2020 2025 2030 2035 2005 2010 2015 2020 2025 2030 2035 2040 2043

Residential Sector Energy Consumption Residential Sector Energy Consumption

Electricity Sales (TWh) 1,359 1,388 1,400 1,471 1,553 1,637 1,707 Electricity Sales (TWh) 0.000 0.000 -0.047 -0.180 -0.313 -0.427 -0.520 -0.596 -0.637

Total U.S. Electric Generation Total U.S. Electric Generation

Coal (TWh) 2,013 1,828 2,038 2,090 2,130 2,209 2,305 Coal (TWh) 0.000 0.002 0.007 -0.036 -0.054 -0.114 -0.126 -0.126 -0.126

Gas (TWh) 759 857 690 769 885 1,018 1,095 Gas (TWh) 0.000 0.012 0.030 -0.062 -0.182 -0.202 -0.209 -0.209 -0.209

Petroleum (TWh) 122 45 46 47 48 48 49 Petroleum (TWh) 0.000 0.000 0.000 -0.001 -0.001 -0.002 -0.003 -0.003 -0.003

Nuclear (TWh) 782 813 834 883 886 886 895 Nuclear (TWh) 0.000 0.000 0.000 0.000 0.000 0.000 -0.020 -0.020 -0.020

Renewables (TWh) 358 462 648 714 797 850 890 Renewables (TWh) 0.000 -0.014 -0.088 -0.084 -0.107 -0.113 -0.151 -0.151 -0.151

Total (TWh) 4,034 4,005 4,257 4,502 4,746 5,011 5,233 Total (TWh) 0.000 0.000 -0.051 -0.182 -0.344 -0.431 -0.509 -0.509 -0.509

Installed Generating Capacity Installed Generating Capacity

Coal (GW) 314 321 325 326 326 330 337 Coal (GW) 0.000 0.000 -0.003 -0.003 -0.003 -0.006 -0.005 -0.005 -0.005

Other Fossil (GW) 439 468 445 446 467 501 534 Other Fossil (GW) 0.000 0.000 -0.008 -0.012 -0.027 -0.035 -0.038 -0.038 -0.038

Nuclear (GW) 100 102 105 111 111 111 113 Nuclear (GW) 0.000 0.000 0.000 0.000 0.000 0.000 -0.003 -0.003 -0.003

Renewables (GW) 99 133 171 177 186 196 209 Renewables (GW) 0.000 -0.004 -0.025 -0.025 -0.023 -0.025 -0.034 -0.034 -0.034

Total (GW) 952 1,024 1,046 1,059 1,091 1,138 1,192 Total (GW) 0.000 -0.004 -0.036 -0.040 -0.052 -0.065 -0.080 -0.080 -0.080

Extrapolation
14-24

14.4 SUMMARY OF UTILITY IMPACT ANALYSIS

The following tables present a summary of utility impact results for all refrigeration 

product TSLs in the final year of the analysis period, 2043. Table 14.4.1 presents the reduction in 

total U.S. electricity generation in 2043. Table 14.4.2 presents the reduction in total U.S. electric 

generating capacity in 2043.

Table 14.4.1 Reduction in Total U.S. Electricity Generation in 2043 Under 

Refrigeration Product TSLs

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Standard-Size Refrigerator-Freezers

TWh

14.5 16.7 19.7 26.9 32.2

Standard-Size Freezers 4.71 4.71 7.96 9.04 9.70

Compact Refrigeration Products 1.72 2.06 2.44 3.02 3.22

Built-In Refrigeration Products 0.118 0.172 0.343 0.425 0.509

Table 14.4.2 Reduction in Electric Generating Capacity in 2043 Under Refrigeration 

Product TSLs

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Standard-Size Refrigerator-Freezers

Gigawatts

2.28 2.63 3.10 4.23 5.07

Standard-Size Freezers 0.740 0.740 1.25 1.42 1.53

Compact Refrigeration Products 0.271 0.324 0.383 0.475 0.506

Built-In Refrigeration Products 0.019 0.027 0.054 0.067 0.080

14.5 IMPACT OF STANDARDS ON ELECTRICITY PRICES AND ASSOCIATED 

BENEFITS FOR CONSUMERS

Using the framework of the utility impact analysis, DOE analyzed the potential impact on 

electricity prices resulting from the proposed standards on refrigeration products. Associated 

benefits for all electricity users in all sectors of the economy are then derived from these price 

impacts.

DOE’s analysis of energy price impacts used NEMS-BT in a similar manner as described 

in section 14.2. Like other widely-used energy-economic models, NEMS uses elasticities to 

estimate the energy price change that would result from a change (increase or decrease) in 

energy demand. The elasticity of price to a decrease in demand is the “inverse price elasticity.” 

The calculated inverse price elasticity based on NEMS-BT simulations differs throughout the 

forecast period in response to the dynamics of supply and demand for electricity.
14-25

14.5.1 Impact on Electricity Prices

DOE analyzed the electricity price effect of all refrigeration products together. The 

results for the proposed TSL for each of the four refrigeration product types were summed 

together to produce combined energy savings.c This allows for a single regression that represents 

the total impact of all refrigeration products. After generating results using higher decrements to 

electricity consumption, a regressed interpolation toward the origin derived the price effects 

associated with the combined energy savings of the proposed TSLs.

Figure 14.5.1 shows the annual change in U.S. electricity consumption for the proposed 

standards, relative to the base case which involves no new standards.

Figure 14.5.1 Change in U.S. Electricity Consumption Associated 

with Proposed Refrigeration Product Energy 

Conservation Standards

 

c The proposed standards consist of TSL 3 for standard-size refrigerator-freezers, TSL 2 for standard-size freezers, 

TSL 2 for compact refrigeration products, and TSL 3 for built-in refrigeration products.

-30.0

-25.0

-20.0

-15.0

-10.0

-5.0

0.0

2015 2020 2025 2030 2035

TWH

Change in Electricity Consumption

Proposed
14-26

Figure 14.5.2 shows the annual change in average U.S. price for electricity, relative to the 

Reference case, projected to result from the proposed standards. The price reduction averages 

0.011 cents per kWh (in 2009$). This average price reduction equals 0.11 percent.

Figure 14.5.2 Effect of Proposed Refrigeration Product Energy 

Conservation Standards on Average U.S. Electricity

Price (All Users)

14.5.2 Impact of Changes in Electricity Price on Electricity Users

Using the estimated electricity price impacts, DOE calculated the nominal savings in total 

electricity expenditures in each year by multiplying the annual change in the average-user price

for electricity by the total annual U.S. electricity consumption forecast by NEMS, adjusted for 

the impact of the standards. The amended standards would continue to reduce demand for 

electricity after 2035 (which is the last year in the NEMS forecast). DOE’s estimate for 2036–

2043 (the period used to estimate the NPV of the national consumer benefits from amended 

standards) multiplied the average electricity price reduction in 2015–2035 by estimated total 

annual electricity consumption in 2036–2043.

d DOE then discounted the stream of reduced 

expenditures to calculate a NPV.

 

d The estimation of electricity consumption after 2035 uses the average annual growth rate in 2031-2035 of total 

U.S. electricity consumption forecasted by NEMS. This forecast includes the impact of the standards.

-0.00025

-0.00020

-0.00015

-0.00010

-0.00005

0.00000

0.00005

2015 2020 2025 2030 2035

2009$/KWH

Change in Electricity Prices

Proposed
14-27

Table 14.5.1 shows the calculated NPV of the economy-wide savings in electricity 

expenditures for each considered TSL at 3-percent and 7-percent discount rates. The need to 

extrapolate price effects and electricity consumption beyond 2035 suggests that one should 

interpret the post-2035 results as a rough indication of the benefits to electricity users in the post2035 period. 

Table 14.5.1 Cumulative NPV of the Economy-Wide Savings in Electricity 

Expenditures Due to the Projected Decline in Electricity Prices Resulting 

from the Proposed Standards for Refrigeration Products* 

Discount Rate billion $2009

3 percent 7.778

7 percent 3.667

* Impacts for units sold from 2014 to 2044

14.5.3 Discussion of Savings in Electricity Expenditures

Although the aggregate benefits for all electricity users are potentially large, there may be 

negative effects on the actors involved in electricity supply. The electric power industry is a 

complex mix of power plant providers, fuel suppliers, electricity generators, and electricity 

distributors. While the distribution of electricity is regulated everywhere, the institutional 

structure of the power sector varies, and has changed over time. For these reasons, an assessment 

of impacts on the actors involved in electricity supply from reduction in electricity demand 

associated with energy conservation standards is beyond the scope of this rulemaking. 

In considering the potential benefits to electricity users, DOE takes under advisement the 

provided by the Office of Management and Budget (OMB) to Federal agencies on the 

development of regulatory analysis (OMB Circular A-4 (Sept. 17, 2003), section E, “Identifying 

and Measuring Benefits and Costs”). Specifically, at page 38, Circular A-4 instructs that 

transfers should be excluded from the estimates of the benefits and costs of a regulation. DOE is 

continuing to investigate the extent to which change in electricity prices projected to result from 

standards represents a net gain to society.
14-28

REFERENCES

1. Energy Information Administration, Annual Energy Outlook 2010 with Projections to 

2035, 2010. Washington, DC. Report No. DOE/EIA-0383(2010). 

<http://www.eia.doe.gov/oiaf/aeo/>
15-i

CHAPTER 15. ENVIRONMENTAL IMPACTS ANALYSIS

TABLE OF CONTENTS

15.1 INTRODUCTION ...............................................................................................................1

15.2 AIR EMISSIONS ANALYSIS............................................................................................1

15.2.1 Air Emissions Descriptions................................................................................1

15.2.2 Air Quality Regulation.......................................................................................4

15.2.3 Global Climate Change......................................................................................5

15.2.4 Analytical Methods for Air Emissions ..............................................................9

15.2.5 Effects on Power Plant Emissions...................................................................10

15.2.6 Effects on Upstream Fuel-Cycle Emissions ....................................................14

15.3 SOCIAL COST OF CARBON DIOXIDE EMISSIONS ..................................................15

15.3.1 Social Cost of Carbon Values Used in Past Regulatory Analyses...................17

15.3.2 Approach and Key Assumptions .....................................................................18

15.4 WETLAND, ENDANGERED AND THREATENED SPECIES, AND 

CULTURAL RESOURCES..............................................................................................19

15.5 SOCIOECONOMIC IMPACTS........................................................................................19

15.6 ENVIRONMENTAL JUSTICE IMPACTS......................................................................20

15.7 NOISE AND AESTHETICS .............................................................................................20

15.8 SUMMARY OF ENVIRONMENTAL IMPACTS...........................................................20

LIST OF TABLES

Table 15.2.1 Reduction in Cumulative Energy-Related Emissions of CO2 from 2014 

through 2043 from Residential Refrigeration Products Energy 

Conservation Standards ..................................................................................... 15-8

Table 15.2.2 Power Sector Emissions Forecast from AEO2010 Reference Case................. 15-10

Table 15.2.3 Power Sector Emissions Impacts Forecasts for Standard-Size RefrigeratorFreezer TSLs.................................................................................................... 15-11

Table 15.2.4 Power Sector Emissions Impact Forecasts for Standard-Size Freezer TSLs... 15-12

Table 15.2.5 Power Sector Emissions Impact Forecasts for Compact Refrigeration 

Product TSLs ................................................................................................... 15-13

Table 15.2.6 Power Sector Emissions Impact Forecasts for Built-In Refrigeration 

Product TSLs ................................................................................................... 15-14

Table 15.2.7 Estimated Upstream Emissions of Air Pollutants as a Percentage of Direct 

Power Plant Combustion Emissions................................................................ 15-15

Table 15.3.1 Social Cost of CO2, 2010 – 2050 (in 2007 dollars) ......................................... 15-17

Table 15.8.1 Cumulative Emissions Reductions Under Refrigeration Product TSLs*........ 15-21
15-1

CHAPTER 15. ENVIRONMENTAL IMPACTS ANALYSIS

15.1 INTRODUCTION

This chapter describes potential environmental effects that may result from amended 

energy conservation standards for residential refrigeration products. The U.S. Department of 

Energy (DOE)’s energy conservation standards are not site-specific, and would apply to all 50 

States and U.S. territories. Therefore, none of the standards would impact land uses, cause any 

direct disturbance to the land, or directly affect biological resources in any one area. 

All of the trial standard levels (TSLs) are expected to reduce energy consumption in 

comparison to the base case. These changes in energy consumption are the primary drivers in 

analyzing environmental effects. The estimates of energy savings that serve as inputs to the 

environmental impacts analysis can be found in the utility impact analysis in chapter 14 of this 

technical support document (TSD). 

The primary impact of the TSLs is on air emissions resulting from power plant 

operations. Therefore, much of this chapter describes the air emissions analysis, and the latter 

part of the chapter describes potential impacts to other environmental resources. 

15.2 AIR EMISSIONS ANALYSIS

A primary focus of the environmental analysis is the impact on air emissions of amended 

energy conservation standards for residential refrigeration products. The outcomes of the 

environmental analysis are largely driven by changes in power plant types and quantities of 

electricity generated under each of the alternatives. Changes in electricity generation are 

described in the utility impact analysis in chapter 14. 

15.2.1 Air Emissions Descriptions

For each of the TSLs, DOE calculated total power-sector emissions based on output from 

the NEMS-BT model (see chapter 14 for description of the model). This analysis considers three 

pollutants: sulfur dioxide (SO2), nitrogen oxides (NOX), and mercury (Hg). An air pollutant is 

any substance in the air that can cause harm to humans or the environment. Pollutants may be 

natural or man-made (i.e., anthropogenic) and may take the form of solid particles (i.e., 

particulates or particulate matter), liquid droplets, or gases.a This analysis also considers carbon 

dioxide (CO2). 

Sulfur Dioxide. Sulfur dioxide, or SO2, belongs to the family of sulfur oxide gases 

(SOx). These gases dissolve easily in water. Sulfur is prevalent in all raw materials, including 

crude oil, coal, and ore that contains common metals like aluminum, copper, zinc, lead, and iron. 

SOx gases are formed when fuel containing sulfur, such as coal and oil, is burned, and when 

gasoline is extracted from oil, or metals are extracted from ore. SO2 dissolves in water vapor to 

 

a More information on air pollution characteristics and regulations is available on the U.S. Environment Protection 

Agent (EPA)’s website at www.epa.gov.
15-2

form acid, and interacts with other gases and particles in the air to form sulfates and other 

products that can be harmful to people and their environment.1

DOE has determined that SO2 emissions from affected Electric Generating Units (EGUs) 

are subject to nationwide and regional emissions cap and trading programs that create 

uncertainty about the standards’ impact on SO2 emissions. Title IV of the Clean Air Act sets an 

annual emissions cap on SO2 for all affected EGUs. SO2 emissions from 28 eastern States and 

the District of Columbia (D.C.) are also limited under the Clean Air Interstate Rule (CAIR, 

published in the Federal Register on May 12, 2005. 70 FR 25162 (May 12, 2005), which creates 

an allowance-based trading program that will gradually replace the Title IV program in those 

States and D.C. (The recent legal history surrounding CAIR is discussed below.) The attainment 

of the emissions caps is flexible among EGUs and is enforced through the use of emissions 

allowances and tradable permits. Under existing EPA regulations, any excess SO2 emission 

allowances resulting from the lower electricity demand caused by the imposition of an efficiency 

standard could be used to permit offsetting increases in SO2 emissions by any regulated EGU. 

However, if the standard resulted in a permanent increase in the quantity of unused emission 

allowances, there would be an overall reduction in SO2 emissions from the standards. While 

there remains some uncertainty about the ultimate effects of efficiency standards on SO2

emissions covered by the existing cap and trade system, the NEMS-BT modeling system that 

DOE uses to forecast emissions reductions currently indicates that no physical reductions in 

power sector emissions would occur for SO2. 

Even if there is no significant reduction in the overall emissions of SO2 that results from 

the standard, there may still be some economic benefit from reduced demand for SO2 emission 

allowances that is not fully reflected in the cost savings experienced by individual consumers. 

Electricity savings that decrease the overall demand for SO2 emissions allowances could lower 

allowance prices and thereby result in some economic benefits for all electricity consumers, not 

just those that reduced their electricity use as a result of an efficiency standard. DOE does not 

plan to monetize this particular benefit because the effect on the SO2 allowance price from any 

single energy conservation standard is likely to be small and highly uncertain.

Nitrogen Oxides. Nitrogen oxides, or NOX, is the generic term for a group of highly 

reactive gases, all of which contain nitrogen and oxygen in varying amounts. Many of the 

nitrogen oxides are colorless and odorless. However, one common pollutant, nitrogen dioxide 

(NO2), along with particles in the air can often be seen as a reddish-brown layer over many urban 

areas. NO2 is the specific form of NOX reported in this document. NOX is one of the main 

ingredients involved in the formation of ground-level ozone, which can trigger serious 

respiratory problems. It can contribute to the formation of acid rain, and can impair visibility in 

areas such as national parks. NOX also contributes to the formation of fine particles that can 

impair human health.1

Nitrogen oxides form when fossil fuel is burned at high temperatures, as in a combustion 

process. The primary manmade sources of NOX are motor vehicles, electric utilities, and other 

industrial, commercial, and residential sources that burn fossil fuels. NOX can also be formed 

naturally. Electric utilities account for about 22 percent of NOX emissions in the United States.2
15-3

Mercury. Coal-fired power plants emit mercury (Hg) found in coal during the burning 

process. While coal-fired power plants are the largest remaining source of human-generated Hg 

emissions in the United States, they contribute very little to the global Hg pool or to 

contamination of U.S. waters.1 U.S. coal-fired power plants emit Hg in three different forms: 

oxidized Hg (likely to deposit within the United States); elemental Hg, which can travel 

thousands of miles before depositing to land and water; and Hg that is in particulate form. 

Atmospheric Hg is then deposited on land, lakes, rivers, and estuaries through rain, snow, and 

dry deposition. Once there, it can transform into methylmercury and accumulate in fish tissue 

through bioaccumulation. 

Americans are exposed to methylmercury primarily by eating contaminated fish. Because 

the developing fetus is the most sensitive to the toxic effects of methylmercury, women of 

childbearing age are regarded as the population of greatest concern. Children exposed to 

methylmercury before birth may be at increased risk of poor performance on neurobehavioral 

tasks, such as those measuring attention, fine motor function, language skills, visual-spatial 

abilities, and verbal memory.3

Carbon Dioxide. Carbon dioxide (CO2) is not a criteria pollutant (see below), but it is of 

interest because of its classification as a greenhouse gas (GHG). GHGs trap the sun’s radiation 

inside the Earth’s atmosphere and either occur naturally in the atmosphere or result from human 

activities. Naturally occurring GHGs include water vapor, CO2, methane (CH4), nitrous oxide 

(N2O), and ozone (O3). Human activities, however, add to the levels of most of these naturally 

occurring gases. For example, CO2 is emitted to the atmosphere when solid waste, fossil fuels 

(oil, natural gas, and coal), wood, and wood products are burned. In 2007, over 90 percent of 

anthropogenic (i.e., human-made) CO2 emissions resulted from burning fossil fuels.4

Concentrations of CO2 in the atmosphere are naturally regulated by numerous processes, 

collectively known as the “carbon cycle.” The movement of carbon between the atmosphere and 

the land and oceans is dominated by natural processes, such as plant photosynthesis. While these 

natural processes can absorb some of the anthropogenic CO2 emissions produced each year, 

billions of metric tons are added to the atmosphere annually. In the United States, in 2007, CO2

emissions from electricity generation accounted for 39 percent of total U.S. GHG emissions.4

Particulate Matter. Particulate matter (PM) also known as particle pollution, is a 

complex mixture of extremely small particles and liquid droplets. Particle pollution is made up 

of a number of components, including acids (such as nitrates and sulfates), organic chemicals, 

metals, and soil or dust particles.

PM impacts are of concern due to human exposures that can impact health. Particle 

pollution - especially fine particles - contains microscopic solids or liquid droplets that are so 

small that they can get deep into the lungs and cause serious health problems. Numerous 

scientific studies have linked particle pollution exposure to a variety of problems, including: 

increased respiratory symptoms, such as irritation of the airways, coughing, or difficulty 

breathing, for example; decreased lung function; aggravated asthma; development of chronic 
15-4

bronchitis; irregular heartbeat; nonfatal heart attacks; and premature death in people with heart or 

lung disease.

Power plant emissions can have either direct or indirect impacts on PM. A portion of the 

pollutants emitted by a power plant are in the form of particulates as they leave the smoke stack. 

These are direct PM emissions. In addition, other pollutants such as SO2 and NOX interact with 

other elements in the atmosphere to produce PM at some distance from the power plant. 

In general, the relative impacts of direct PM emissions reduction compared to other 

pollutants on PM exposures are much more difficult to estimate than other emissions reductions. 

This is due to the complex interactions between PM, other power plant emissions, meteorology 

and atmospheric chemistry that impact human exposure to particulates. Human exposure to PM 

usually occurs at a significant distance from the power plants that are emitting particulates and 

particulate precursors. When power plant emissions travel this distance they undergo highly 

complex atmospheric chemical reactions and the proportion of impacts and exposures 

attributable to different emissions can vary dramatically for different emissions sources and types 

of particulate precursors. These variations in emissions impacts depend on the distance to the 

source, land use and land cover, and the local and regional meteorology responsible for pollutant 

transport, deposition and atmospheric chemistry. 

The Environmental Protection Agency (EPA) has compiled and summarized technical 

studies regarding PM source apportionment.5 In this compilation of studies, sources are 

classified into seven categories: (1) Secondary sulfate/coal, (2) Secondary organic matter/mobile 

sources, (3) Nitrate dominated sources, (4) Biomass burning, (5) Industrial, (6) Crustal and salt 

(7) Other. In these studies, the PM exposures attributed to coal power plants are not 

disaggregated between direct particulate emissions and SO2 emissions from these power plants. 

This is because both SO2 and direct PM emissions aggregate and interact with water droplets and 

emissions from other sources to create final particulates that are a complex mixture of different 

constituents. Both the SO2 and direct PM are emitted from the power plant at the same time and 

if the final aerosol particle contains both sulfur compounds and other PM components it is not 

possible to attribute that aerosol particle to one source or the other. Therefore, DOE is not 

currently able to perform modeling that can make reliable estimates of the impact of direct PM 

emissions on air quality at this time.

15.2.2 Air Quality Regulation

The Clean Air Act Amendments of 1990 list 188 toxic air pollutants that EPA is required 

to control.6 EPA has set national air quality standards for six common pollutants (also referred to 

as “criteria” pollutants), two of which are SO2 and NOX. Also, the Clean Air Act Amendments of 

1990 gave EPA the authority to control acidification and to require operators of electric power 

plants to reduce emissions of SO2 and NOX. Title IV of the 1990 amendments established a capand-trade program for SO2 intended to help control acid rain.6 This cap-and-trade program serves 

as a model for more recent programs with similar features.
15-5

In 2005, EPA issued the Clean Air Interstate Rule (CAIR) under sections 110 and 111 of 

the Clean Air Act (40 CFR Parts 51, 96, and 97).7 b CAIR will permanently cap emissions of 

SO2 and NOX in eastern States of the United States. CAIR achieves large reductions of SO2

and/or NOX emissions across 28 eastern States and the District of Columbia. States must achieve 

the required emission reductions using one of two compliance options: 1) meet an emission 

budget for each regulated state by requiring power plants to participate in an EPA-administered 

interstate cap-and-trade system that caps emissions in two stages, or 2) meet an individual state 

emissions budget through measures of the state’s choosing. Phase 1 caps for NOX have been in

place since 2009. Phase 1 caps for SO2 are to be in place beginning in 2010. The Phase 2 caps for 

both NOX and SO2 are due in 2015. 

Also in 2005, EPA issued the final rule entitled “Standards of Performance for New and 

Existing Stationary Sources: Electric Steam Generating Units,” under sections 110 and 111 of 

the Clean Air Act (40 CFR Parts 60, 63, 72, and 75) 8

. This rule, called the Clean Air Mercury 

Rule (CAMR), was closely related to the CAIR and established standards of performance for Hg 

emissions from new and existing coal-fired electric utility steam generating units. The CAMR 

regulated Hg emissions from coal-fired power plants. 

On February 8, 2008, the U.S. Court of Appeals for the District of Columbia Circuit 

(D.C. Circuit) issued its decision in State of New Jersey, et al. v. Environmental Protection 

Agency,

c in which the Court, among other actions, vacated the CAMR referenced above. 

On July 11, 2008, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. 

Circuit) issued its decision in North Carolina v. Environmental Protection Agency, which 

vacated the CAIR issued by the U.S. Environmental Protection Agency on March 10, 2005.d

CAIR was the vehicle for capping NOX emissions.

e On December 23, 2008, the D.C. Circuit 

decided to allow CAIR to remain in effect until it is replaced by a rule consistent with the court’s 

earlier opinion. North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008) (remand of vacatur).f

15.2.3 Global Climate Change

Climate change has evolved into a matter of global concern because it is expected to have 

widespread, adverse effects on natural resources and systems. A growing body of evidence 

points to anthropogenic sources of greenhouse gases, such as carbon dioxide (CO2), as major 

contributors to climate change. Because this Rule, if finalized, will likely decrease CO2 emission 

rates from the fossil fuel sector in the United States, the Department here examines the impacts 

and causes of climate change and then the potential impact of the Rule on CO2 emissions and 

global warming. 

 

b See http://www.epa.gov/cleanairinterstaterule/.

c 517 F.3d 574, 583 (D.C. Cir. 2008).

d See http://www.epa.gov/cleanairinterstaterule/.

e See id. at 903. 

f State of North Carolina, et al. v. Environmental Protection Agency, 550 F.3d 1176 (D.C. Cir. 2008). 
15-6

Impacts of Climate Change on the Environment. Climate is usually defined as the 

average weather, over a period ranging from months to many years. Climate change refers to a 

change in the state of the climate, which is identifiable through changes in the mean and/or the 

variability of its properties (e.g., temperature or precipitation) over an extended period, typically 

decades or longer.9

The World Meteorological Organization and United Nations Environment Programme 

(UNEP) established the Intergovernmental Panel on Climate Change (IPCC) to provide an 

objective source of information about climate change. According to the IPCC Fourth Assessment 

Report (IPCC Report), published in 2007, climate change is consistent with observed changes to 

the world’s natural systems; the IPCC expects these changes to continue.9

Changes that are consistent with warming include warming of the world’s oceans to a 

depth of 3000 meters; global average sea level rise at an average rate of 1.8 mm per year from 

1961 to 2003; loss of annual average Arctic sea ice at a rate of 2.7 percent per decade, changes in 

wind patterns that affect extra-tropical storm tracks and temperature patterns, increases in intense 

precipitation in some parts of the world, as well as increased drought and more frequent heat 

waves in many locations worldwide, and numerous ecological changes.9

Looking forward, the IPCC describes continued global warming of about 0.2 °C per 

decade for the next two decades under a wide range of emission scenarios for carbon dioxide 

(CO2), other greenhouse gases (GHGs), and aerosols. After that period, the rate of increase is 

less certain. The IPCC Report describes increases in average global temperatures of about 1.1 °C 

to 6.4 °C at the end of the century relative to today. These increases vary depending on the model 

and emissions scenarios.9

The IPCC Report describes incremental impacts associated with the rise in temperature. 

At ranges of incremental increases to the global average temperature, IPCC reports, with either 

high or very high confidence, that there is likely to be an increasing degree of impacts such as 

coral reef bleaching, loss of wildlife habitat, loss to specific ecosystems, and negative yield 

impacts for major cereal crops in the tropics, but also projects that there likely will be some 

beneficial impacts on crop yields in temperate regions. 

Causes of Climate Change. The IPCC Report states that the world has warmed by about 

0.74 °C in the last 100 years. The IPCC Report finds that most of the temperature increase since 

the mid-20th century is very likely due to the increase in anthropogenic concentrations of CO2

and other long-lived greenhouse gases such as methane and nitrous oxide in the atmosphere, 

rather than from natural causes. 

Increasing the CO2 concentration partially blocks the earth’s re-radiation of captured 

solar energy in the infrared band, inhibits the radiant cooling of the earth, and thereby alters the 

energy balance of the planet, which gradually increases its average temperature. The IPCC 
15-7

Report estimates that currently, CO2 makes up about 77 percent of the total CO2-equivalentg

global warming potential in GHGs emitted from human activities, with the vast majority (74 

percent) of the CO2 attributable to fossil fuel use.10 For the future, the IPCC Report describes a 

wide range of GHG emissions scenarios, but under each scenario CO2 would continue to 

comprise above 70 percent of the total global warming potential.10

Stabilization of CO2 Concentrations. Unlike many traditional air pollutants, CO2 mixes 

thoroughly in the entire atmosphere and is long-lived. The residence time of CO2 in the 

atmosphere is long compared to the emission processes. Therefore, the global cumulative 

emissions of CO2 over long periods determine CO2 concentrations because it takes hundreds of 

years for natural processes to remove the CO2. Globally, 49 billion metric tons of CO2 –

equivalent of anthropogenic (man-made) greenhouse gases are emitted every year. Of this annual 

total, fossil fuels contribute about 29 billion metric tons of CO2.

11 h

Researchers have focused on considering atmospheric CO2 concentrations that likely will 

result in some level of global climate stabilization, and the emission rates associated with 

achieving the “stabilizing” concentrations by particular dates. They associate these stabilized 

CO2 concentrations with temperature increases that plateau in a defined range. For example, at 

the low end, the IPCC Report scenarios target CO2 stabilized concentrations range between 350 

ppm and 400 ppm (essentially today’s value)—because of climate inertia, concentrations in this 

low-end range would still result in temperatures projected to increase 2.0 °C to 2.4 °C above preindustrial levelsi

(about 1.3 °C to 1.7 °C above today’s levels). To achieve concentrations 

between 350 ppm to 400 ppm, the IPCC scenarios present that there would have to be a rapid 

downward trend in total annual global emissions of greenhouse gases to levels that are 50 to 85 

percent below today’s annual emission rates by no later than 2050. Since it is assumed that there 

would continue to be growth in global population and substantial increases in economic 

production, the scenarios identify required reductions in greenhouse gas emissions intensity 

(emissions per unit of output) of more than 90 percent. However, even at these rates, the 

scenarios describe some warming and some climate change is projected due to already 

accumulated CO2 and GHGs in the atmosphere.12

The Beneficial Impact of the Rule on CO2 Emissions. It is anticipated that the Rule will 

reduce energy-related CO2 emissions, particularly those associated with energy consumption in 

buildings. The U.S. Energy Information Administration (EIA) reports in its 2010 Annual Energy 

Outlook (AEO2010)

13 that U.S. annual energy-related emissions of CO2 in 2007 were about 6.0 

billion metric tons, of which 1.2 billion tons were attributed to the residential buildings sector 

 g GHGs differ in their warming influence (radiative forcing) on a global climate system due to their different 

radiative properties and lifetimes in the atmosphere. These warming influences may be expressed through a common 

metric based on the radiative forcing of CO2, i.e., CO2-equivalent. CO2 equivalent emission is the amount of CO2

emission that would cause the same- time integrated radiative forcing, over a given time horizon, as an emitted 

amount of other long- lived GHG or mixture of GHGs.

h Other non-fossil fuel contributors include CO2 emissions from deforestation and decay from agriculture biomass; 

agricultural and industrial emissions of methane; and emissions of nitrous oxide and fluorocarbons.

i

IPCC Working Group 3 Table TS 2
15-8

(including related energy–using products such as residential refrigeration products). Most of the 

greenhouse gas emissions attributed to residential buildings are emitted from fossil fuel-fired 

power plants that generate electricity used in this sector. In the AEO2010 Reference Case, EIA 

projected that annual energy-related CO2 emissions would grow from 5.7 billion metric tons in 

2015 to 6.3 billion metric tons in 2035, an increase of 10 percent (see AEO2010), while 

residential emissions would grow to from 1.2 billion metric tons to 1.3 billion metric tons, an 

increase of 12 percent.

The estimated cumulative CO2 emission reductions from residential refrigeration 

products efficiency standards (shown as a range of alternative TSLs) during the 30-year analysis 

period are indicated in Table 15.2.1. Estimated CO2 emission reductions in Table 15.2.1 only 

come from electricity generation (i.e., power plants). The estimated CO2 emission reductions 

from electricity generation are calculated using the NEMS-BT model.

Table 15.2.1 Reduction in Cumulative Energy-Related Emissions of CO2 from 2014

through 2043 from Residential Refrigeration Products Energy Conservation Standards

Trial Standard Levels

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Million Metric Tons 

Standard-Size RefrigeratorFreezers 154 177 208 283 338

Standard-Size Freezers 48.0 68.8 81.1 92.0 98.5

Compact Refrigeration Products 19.6 23.6 28.0 35.2 38.8

Built-In Refrigeration Products 1.23 1.79 3.58 4.45 5.32

Total 223 271 321 415 481

Percent of Total Cumulative 

Emissions Reduction compared 

with the AEO2010 Reference 

Case in 2015-2043

0.30 0.36 0.43 0.56 0.65

The Incremental Impact of the Rule on Climate Change. It is difficult to correlate 

specific emission rates with atmospheric concentrations of CO2 and specific atmospheric 

concentrations with future temperatures because the IPCC Report describes a clear lag in the 

climate system between any given concentration of CO2 (even if maintained for long periods) 

and the subsequent average worldwide and regional temperature, precipitation, and extreme 

weather regimes. For example, a major determinant of climate response is “equilibrium climate 

sensitivity”, a measure of the climate system response to sustained radioactive forcing. It is 

defined as the global average surface warming following a doubling of carbon dioxide 

concentrations. The IPCC Report describes its estimated, numeric value as about 3 °C, but the 

likely range of that value is 2 °C to 4.5 °C, with cloud feedbacks the largest source of 

uncertainty. Further, as illustrated above, the IPCC Report scenarios for stabilization rates are 
15-9

presented in terms of a range of concentrations, which then correlates to a range of temperature 

changes. Thus, climate sensitivity is a key uncertainty for CO2 mitigation scenarios that aim to 

meet specific temperature levels. 

Because of how complex global climate systems are, it is difficult to know to what extent 

and when particular CO2 emissions reductions will impact global warming. However, as Table 

15.2.1 indicates, the rule is expected to reduce CO2 emissions associated with energy 

consumption in buildings. 

15.2.4 Analytical Methods for Air Emissions 

NEMS-BT incorporates capabilities to assess compliance with SO2 restrictions specified 

in the Clean Air Act and its amendments. Clean Air Act provisions include New Source 

Performance Standards, and Revised New Source Performance Standards. The version of 

NEMS-BT in 2008 included provisions for the CAIR, which imposes stricter restrictions on SO2

and NOX for some states, and the CAMR, which imposed a national Hg constraint. As discussed 

earlier is section 15.2.2, on December 23, 2008, the D.C. Circuit decided to allow CAIR to 

remain in effect until it is replaced by a rule consistent with the court’s earlier opinion. Carolina 

v. Environmental Protection Agency, 550 F.3d 1176 (D.C. Cir. 2008) (remand of vacatur). But , 

EPA has not promulgated a rule to replace CAMR, which the D.C. Circuit vacated in 2008 . 

Thus, the version of NEMS-BT used in this analysis does not include provisions for the CAMR.

Coal-fired electric generation is the single largest source of electricity in the United 

States. Because the mix of coals used significantly affects the emissions produced, the model 

includes a detailed representation of coal supply. The model considers the rank of the coal as 

well as the sulfur contents of the fuel used when determining optimal dispatch.14

Within the NEMS-BT model, planning options for achieving emissions restrictions in the 

Clean Air Act Amendments include installing pollution control equipment on existing power 

plants and building new power plants with low emission rates. These methods for reducing 

emission are compared to dispatching options such as fuel switching and allowance trading. 

Environmental regulations also affect capacity expansion decisions. For instance, new plants are 

not allocated SO2 emissions allowances according to the Clean Air Act Amendments.

Consequently, the decision to build a particular capacity type must consider the cost (if any) of 

obtaining sufficient allowances. This could involve purchasing allowances or over complying at 

an existing unit.

DOE’s analysis assumed the presence of nationwide emission caps on SO2 and caps on 

NOX emissions in the 28 States covered by the CAIR. Any emissions reductions in NOX

calculated by the NEMS-BT modeling system that DOE plans to use are in addition to the 

regulatory emissions reductions modeled in AEO. The NEMS-BT modeling system currently 

indicates that no physical reductions in power sector emissions would occur for SO2. However, 

remaining uncertainty prevents DOE from estimating or reporting SO2 reductions from energy 

conservation standards at this time. It should be noted that the standards could put slight 

downward pressure on the prices of emissions allowances in cap-and-trade markets. 
15-10

In contrast to the modeling forecasts of NEMS-BT that SO2 emissions reductions will 

remain at the cap, during the years 2007 and 2008, SO2 emissions have been below the trading 

cap. The difference between the emissions levels that NEMS-BT forecasts and those that EPA 

forecasts is an indicator of the uncertainties associated with long-range energy sector forecasts. 

Because of such uncertainties, DOE is unable to estimate the economic and physical benefit from 

SO2 emissions reductions at this time.

As noted in chapter 14, NEMS-BT model forecasts end in year 2035. Emissions impacts 

beyond 2035 are assumed to be equal to the impacts in 2035.

15.2.5 Effects on Power Plant Emissions

Table 15.2.2 shows AEO2010 reference case power plant emissions in selected years. 

The Reference Case emissions are the emissions shown by the NEMS-BT model to result if none 

of the TSLs are promulgated (the base case). 

Table 15.2.2 Power Sector Emissions Forecast from AEO2010 Reference Case

NEMS-BT Results 2010 2015 2020 2025 2030 2035

CO2 (million metric tons) 2,218 2,278 2,341 2,421 2,534 2,636

NOX (million tons) 2.24 2.06 2.02 2.03 2.06 2.07

Hg (tons) 40.6 30.6 30.1 30.0 30.2 30.3

Table 15.2.3 through Table 15.2.6 show the estimated changes in power plant emissions 

of CO2, NOX, and Hg in selected years for each of the TSLs. As in Table 15.2.2, values are given 

in metric tons.
15-11

Table 15.2.3 Power Sector Emissions Impacts Forecasts for Standard-Size RefrigeratorFreezer TSLs

NEMS-BT Results* Difference from AEO2010 Reference Case

Total

2010 2015 2020 2025 2030 2035 2040 2043 2014-2043

Standard Level 1

CO2 (Mt/yr) 0.33 0.89 -2.35 -5.52 -7.15 -7.37 -7.37 -7.37 -154

NOx (kt/yr) 0.34 0.81 -2.02 -4.64 -5.80 -5.78 -5.78 -5.78 -124

Hg (t/yr) 0.00 0.00 -0.02 -0.02 -0.04 -0.04 -0.04 -0.04 -0.787

Standard Level 2

CO2 (Mt/yr) 0.38 1.02 -2.69 -6.34 -8.22 -8.50 -8.50 -8.50 -177

NOx (kt/yr) 0.38 0.92 -2.32 -5.32 -6.67 -6.66 -6.66 -6.66 -142

Hg (t/yr) 0.00 0.00 -0.02 -0.02 -0.05 -0.05 -0.05 -0.05 -0.91

Sandard Level 3

CO2 (Mt/yr) 0.44 1.19 -3.16 -7.46 -9.67 -10.00 -10.00 -10.00 -208

NOx (kt/yr) 0.45 1.07 -2.72 -6.26 -7.85 -7.83 -7.83 -7.83 -168

Hg (t/yr) 0.00 0.00 -0.03 -0.02 -0.05 -0.05 -0.05 -0.05 -1.07

Standard Level 4

CO2 (Mt/yr) 0.58 1.56 -4.23 -10.07 -13.15 -13.65 -13.65 -13.65 -283

NOx (kt/yr) 0.58 1.41 -3.64 -8.46 -10.68 -10.70 -10.70 -10.70 -228

Hg (t/yr) 0.01 -0.01 -0.04 -0.03 -0.07 -0.07 -0.07 -0.07 -1.45

Standard Level 5

CO2 (Mt/yr) 0.66 1.79 -4.97 -11.96 -15.70 -16.34 -16.34 -16.34 -338

NOx (kt/yr) 0.66 1.62 -4.28 -10.05 -12.74 -12.81 -12.81 -12.81 -272

Hg (t/yr) 0.01 -0.01 -0.04 -0.04 -0.09 -0.09 -0.09 -0.09 -1.73

*CO2 results are in metric tons, NOX and Hg results are in short tons.

Extrapolation
15-12

Table 15.2.4 Power Sector Emissions Impact Forecasts for Standard-Size Freezer TSLs

NEMS-BT Results* Difference from AEO2010 Reference Case

Total

2010 2015 2020 2025 2030 2035 2040 2043 2014-2043

Standard Level 1

CO2 (Mt/yr) 0.10 0.26 -0.67 -1.61 -2.21 -2.39 -2.39 -2.39 -48.0

NOx (kt/yr) 0.10 0.24 -0.58 -1.36 -1.79 -1.87 -1.87 -1.87 -38.6

Hg (t/yr) 0.001 -0.001 -0.006 -0.005 -0.012 -0.013 -0.013 -0.013 -0.245

Standard Level 2

CO2 (Mt/yr) 0.14 0.37 -0.95 -2.30 -3.16 -3.42 -3.42 -3.42 -68.8

NOx (kt/yr) 0.14 0.33 -0.82 -1.94 -2.57 -2.68 -2.68 -2.68 -55.3

Hg (t/yr) 0.002 -0.001 -0.008 -0.007 -0.018 -0.019 -0.019 -0.019 -0.351

Sandard Level 3

CO2 (Mt/yr) 0.16 0.42 -1.11 -2.71 -3.73 -4.04 -4.04 -4.04 -81.1

NOx (kt/yr) 0.16 0.38 -0.96 -2.28 -3.03 -3.17 -3.17 -3.17 -65.1

Hg (t/yr) 0.002 -0.002 -0.009 -0.008 -0.021 -0.022 -0.022 -0.022 -0.413

Standard Level 4

CO2 (Mt/yr) 0.17 0.47 -1.25 -3.07 -4.23 -4.59 -4.59 -4.59 -92.0

NOx (kt/yr) 0.18 0.42 -1.08 -2.58 -3.44 -3.60 -3.60 -3.60 -73.9

Hg (t/yr) 0.002 -0.002 -0.010 -0.010 -0.024 -0.025 -0.025 -0.025 -0.469

Standard Level 5

CO2 (Mt/yr) 0.17 0.47 -1.31 -3.27 -4.54 -4.92 -4.92 -4.92 -98.5

NOx (kt/yr) 0.17 0.43 -1.13 -2.75 -3.68 -3.86 -3.86 -3.86 -79.2

Hg (t/yr) 0.002 -0.002 -0.011 -0.010 -0.026 -0.027 -0.027 -0.027 -0.501

*CO2 results are in metric tons, NOX and Hg results are in short tons.

Extrapolation
15-13

Table 15.2.5 Power Sector Emissions Impact Forecasts for Compact Refrigeration 

Product TSLs

NEMS-BT Results* Difference from AEO2010 Reference Case

Total

2010 2015 2020 2025 2030 2035 2040 2043 2014-2043

Standard Level 1

CO2 (Mt/yr) 0.089 0.232 -0.451 -0.793 -0.886 -0.872 -0.872 -0.872 -19.6

NOx (kt/yr) 0.090 0.210 -0.389 -0.666 -0.719 -0.684 -0.684 -0.684 -15.8

Hg (t/yr) 0.001 -0.001 -0.004 -0.002 -0.005 -0.005 -0.005 -0.005 -0.104

Standard Level 2

CO2 (Mt/yr) 0.107 0.280 -0.546 -0.956 -1.065 -1.046 -1.046 -1.046 -23.6

NOx (kt/yr) 0.108 0.253 -0.470 -0.803 -0.864 -0.820 -0.820 -0.820 -19.0

Hg (t/yr) 0.001 -0.001 -0.005 -0.003 -0.006 -0.006 -0.006 -0.006 -0.125

Sandard Level 3

CO2 (Mt/yr) 0.127 0.333 -0.652 -1.140 -1.263 -1.235 -1.235 -1.235 -28.0

NOx (kt/yr) 0.128 0.301 -0.562 -0.958 -1.026 -0.968 -0.968 -0.968 -22.5

Hg (t/yr) 0.001 -0.001 -0.005 -0.004 -0.007 -0.007 -0.007 -0.007 -0.148

Standard Level 4

CO2 (Mt/yr) 0.160 0.424 -0.842 -1.457 -1.590 -1.533 -1.533 -1.533 -35.2

NOx (kt/yr) 0.161 0.384 -0.726 -1.224 -1.291 -1.202 -1.202 -1.202 -28.3

Hg (t/yr) 0.002 -0.002 -0.007 -0.005 -0.009 -0.008 -0.008 -0.008 -0.186

Standard Level 5

CO2 (Mt/yr) 0.165 0.462 -0.990 -1.670 -1.753 -1.633 -1.633 -1.633 -38.8

NOx (kt/yr) 0.166 0.418 -0.853 -1.403 -1.423 -1.280 -1.280 -1.280 -31.4

Hg (t/yr) 0.002 -0.002 -0.008 -0.005 -0.010 -0.009 -0.009 -0.009 -0.206

*CO2 results are in metric tons, NOX and Hg results are in short tons.

Extrapolation
15-14

Table 15.2.6 Power Sector Emissions Impact Forecasts for Built-In Refrigeration Product 

TSLs

15.2.6 Effects on Upstream Fuel-Cycle Emissions

Upstream fuel-cycle emissions refer to the emissions associated with the amount of 

energy used in the upstream production and downstream consumption of electricity, including 

energy used at the power plant.17 Upstream processes include the mining of coal or extraction of 

natural gas, physical preparatory and cleaning processes, and transportation to the power plant. 

The NEMS-BT does a thorough accounting of emissions at the power plant due to downstream 

energy consumption, but does not account for upstream emissions (i.e., emissions from energy 

losses during coal and natural gas production). Thus, this analysis reports only power plant 

emissions.

However, previous DOE environmental assessment documents have developed 

approximate estimates of effects on upstream fuel-cycle emissions. These emissions factors 

provide the reader with a sense of the possible magnitude of upstream effects. These upstream 

emissions would be in addition to emissions from direct combustion. 

NEMS-BT Results* Difference from AEO2010 Reference Case

Total

2010 2015 2020 2025 2030 2035 2040 2043 2014-2043

Standard Level 1

CO2 (Mt/yr) 0.003 0.007 -0.018 -0.043 -0.057 -0.060 -0.060 -0.060 -1.23

NOx (kt/yr) 0.003 0.006 -0.016 -0.036 -0.046 -0.047 -0.047 -0.047 -0.99

Hg (t/yr) 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 -0.006

Standard Level 2

CO2 (Mt/yr) 0.004 0.010 -0.026 -0.062 -0.083 -0.087 -0.087 -0.087 -1.79

NOx (kt/yr) 0.004 0.009 -0.023 -0.052 -0.067 -0.068 -0.068 -0.068 -1.44

Hg (t/yr) 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 -0.009

Sandard Level 3

CO2 (Mt/yr) 0.008 0.020 -0.053 -0.125 -0.166 -0.174 -0.174 -0.174 -3.58

NOx (kt/yr) 0.008 0.018 -0.045 -0.105 -0.134 -0.137 -0.137 -0.137 -2.88

Hg (t/yr) 0.000 0.000 0.000 0.000 -0.001 -0.001 -0.001 -0.001 -0.018

Standard Level 4

CO2 (Mt/yr) 0.010 0.025 -0.066 -0.156 -0.206 -0.216 -0.216 -0.216 -4.45

NOx (kt/yr) 0.010 0.023 -0.057 -0.131 -0.167 -0.169 -0.169 -0.169 -3.58

Hg (t/yr) 0.000 0.000 -0.001 0.000 -0.001 -0.001 -0.001 -0.001 -0.023

Standard Level 5

CO2 (Mt/yr) 0.011 0.030 -0.079 -0.187 -0.246 -0.258 -0.258 -0.258 -5.32

NOx (kt/yr) 0.011 0.027 -0.068 -0.157 -0.200 -0.202 -0.202 -0.202 -4.28

Hg (t/yr) 0.000 0.000 -0.001 -0.001 -0.001 -0.001 -0.001 -0.001 -0.027

*CO2 results are in metric tons, NOX and Hg results are in short tons.

Extrapolation
15-15

Relative to the entire fuel cycle, estimates based on the work of Dr. Mark DeLuchi, and 

reported in earlier DOE environmental assessment documents, find that an amount 

approximately equal to eight percent, by mass, of emissions (including SO2) from coal 

production are due to mining, preparation that includes cleaning the coal, and transportation from 

the mine to the power plant.18 Transportation emissions include emissions from the fuel used by 

the mode of transportation that moves the coal from the mine to the power plant. In addition, 

based on Dr. DeLuchi’s work, DOE estimated that an amount equal to approximately 14 percent 

of emissions from natural gas production result from upstream processes. 

Emission factor estimates and corresponding percentages of contributions of upstream 

emissions from coal and natural gas production, relative to power plant emissions, are shown in 

Table 15.2.7 for CO2 and NOX. The percentages provide a means to estimate upstream emission 

savings based on changes in emissions from power plants. This approach does not address Hg 

emissions.

Table 15.2.7 Estimated Upstream Emissions of Air Pollutants as a Percentage of Direct 

Power Plant Combustion Emissions

Pollutant

Percent of Coal

Combustion Emissions

Percent of Natural Gas

Combustion Emissions

CO2 2.7 11.9

NOX 5.8 40

15.3 SOCIAL COST OF CARBON DIOXIDE EMISSIONS

The “social cost of carbon” (SCC) is an estimate of the monetized damages 

associated with an incremental increase in carbon emissions in a given year. It is intended 

to include (but is not limited to) changes in net agricultural productivity, human health, 

property damages from increased flood risk, and the value of ecosystem services. Estimates 

of the social cost of carbon are provided in dollars per metric ton of carbon dioxide.j

 

When attempting to assess the incremental economic impacts of carbon dioxide 

emissions, the analyst faces a number of serious challenges. A recent report from the National 

Research Council (Hidden Costs of Energy: Unpriced Consequences of Energy Production and 

Use. National Academies Press. 2009) points out that any assessment will suffer from 

uncertainty, speculation, and lack of information about (1) future emissions of greenhouse gases, 

(2) the effects of past and future emissions on the climate system, (3) the impact of changes in 

climate on the physical and biological environment, and (4) the translation of these 

environmental impacts into economic damages. As a result, any effort to quantify and monetize 

 

j

In this document, DOE presents all values of the SCC as the cost per metric ton of CO2 emissions. Alternatively, 

one could report the SCC as the cost per metric ton of carbon emissions. The multiplier for translating between mass 

of CO2 and the mass of carbon is 3.67 (the molecular weight of CO2 divided by the molecular weight of carbon = 

44/12 = 3.67).
15-16

the harms associated with climate change will raise serious questions of science, economics, and 

ethics and should be viewed as provisional. 

Despite the serious limits of both quantification and monetization, SCC estimates can be 

useful in estimating the social benefits of reducing carbon dioxide emissions. Under Executive 

Order 12866, agencies are required, to the extent permitted by law, “to assess both the costs and 

the benefits of the intended regulation and, recognizing that some costs and benefits are difficult 

to quantify, propose or adopt a regulation only upon a reasoned determination that the benefits of 

the intended regulation justify its costs.” The purpose of the SCC estimates presented here is to 

make it possible for agencies to incorporate the social benefits from reducing carbon dioxide 

emissions into cost-benefit analyses of regulatory actions that have small, or “marginal,” impacts 

on cumulative global emissions. Most federal regulatory actions can be expected to have 

marginal impacts on global emissions.

For such policies, the benefits from reduced (or costs from increased) emissions in any 

future year can be estimated by multiplying the change in emissions in that year by the SCC 

value appropriate for that year. The net present value of the benefits can then be calculated by 

multiplying each of these future benefits by an appropriate discount factor and summing across 

all affected years. This approach assumes that the marginal damages from increased emissions 

are constant for small departures from the baseline emissions path, an approximation that is 

reasonable for policies that have effects on emissions that are small relative to cumulative global 

carbon dioxide emissions. For policies that have a large (non-marginal) impact on global 

cumulative emissions, there is a separate question of whether the SCC is an appropriate tool for 

calculating the benefits of reduced emissions; DOE does not attempt to answer that question 

here.

An interagency group convened on a regular basis to consider public comments, explore 

the technical literature in relevant fields, and discuss key inputs and assumptions in order to 

generate SCC estimates. Agencies that actively participated in the interagency process include 

the Environmental Protection Agency, and the Departments of Agriculture, Commerce, Energy, 

Transportation, and Treasury. This process was convened by the Council of Economic Advisers 

and the Office of Management and Budget, with active participation and regular input from the 

Council on Environmental Quality, National Economic Council, Office of Energy and Climate 

Change, and Office of Science and Technology Policy. The main objective of this process was 

to develop a range of SCC values using a defensible set of input assumptions that are grounded 

in the existing literature. In this way, key uncertainties and model differences can more 

transparently and consistently inform the range of SCC estimates used in the rulemaking process. 

The interagency group selected four SCC estimates for use in regulatory analyses. For 

2010, these estimates are $4.7, $21.4, $35.1, and $64.9 (in 2007 dollars). The first three estimates 

are based on the average SCC across models and socio-economic and emissions scenarios at the 

5, 3, and 2.5 percent discount rates, respectively. The fourth value is included to represent the 

higher-than-expected impacts from temperature change further out in the tails of the SCC 

distribution. For this purpose, the interagency group selected the SCC value for the 95th 

percentile at a 3 percent discount rate. 
15-17

The “central” value is the average SCC across models at the 3 percent discount rate. For 

purposes of capturing the uncertainties involved in regulatory impact analysis, we emphasize the 

importance and value of considering the full range. These SCC estimates also grow over time

(see Table 15.3.1). For instance, the central value increases to $24 per ton of CO2 in 2015 and 

$26 per ton of CO2 in 2020. 

Appendix 15-A presents the interagency report “Social Cost of Carbon for Regulatory 

Impact Analysis Under Executive Order 12866,” which provides further information.

Table 15.3.1 Social Cost of CO2, 2010 – 2050 (in 2007 dollars)

Discount Rate

5% 3% 2.5% 3%

Year Avg Avg Avg 95th

2010 4.7 21.4 35.1 64.9

2015 5.7 23.8 38.4 72.8

2020 6.8 26.3 41.7 80.7

2025 8.2 29.6 45.9 90.4

2030 9.7 32.8 50.0 100.0

2035 11.2 36.0 54.2 109.7

2040 12.7 39.2 58.4 119.3

2045 14.2 42.1 61.7 127.8

2050 15.7 44.9 65.0 136.2

It is important to emphasize that the interagency process is committed to updating these 

estimates as the science and economic understanding of climate change and its impacts on 

society improves over time. Specifically, the interagency group set a preliminary goal of 

revisiting the SCC values within two years or at such time as substantially updated models 

become available, and to continue to support research in this area. In the meantime, we will 

continue to explore the issues raised by this analysis and consider public comments as part of the 

ongoing interagency process. 

15.3.1 Social Cost of Carbon Values Used in Past Regulatory Analyses

To date, economic analyses for Federal regulations have used a wide range of values to 

estimate the benefits associated with reducing carbon dioxide emissions. In the final model year 

2011 CAFE rule, the Department of Transportation (DOT) used both a “domestic” SCC value of 

$2 per ton of CO2 and a “global” SCC value of $33 per ton of CO2 for 2007 emission reductions 

(in 2007 dollars), increasing both values at 2.4 percent per year. It also included a sensitivity 

analysis at $80 per ton of CO2. A domestic SCC value is meant to reflect the value of damages 

in the United States resulting from a unit change in carbon dioxide emissions, while a global 

SCC value is meant to reflect the value of damages worldwide.
15-18

A 2008 regulation proposed by DOT assumed a domestic SCC value of $7 per ton CO2

(in 2006 dollars) for 2011 emission reductions (with a range of $0-$14 for sensitivity analysis), 

also increasing at 2.4 percent per year. A regulation finalized by DOE in October of 2008 used a 

domestic SCC range of $0 to $20 per ton CO2 for 2007 emission reductions (in 2007 dollars). In 

addition, EPA’s 2008 Advance Notice of Proposed Rulemaking for Greenhouse Gases identified 

what it described as “very preliminary” SCC estimates subject to revision. EPA’s global mean 

values were $68 and $40 per ton CO2 for discount rates of approximately 2 percent and 3 

percent, respectively (in 2006 dollars for 2007 emissions).

In 2009, an interagency process was initiated to offer a preliminary assessment of how 

best to quantify the benefits from reducing carbon dioxide emissions. To ensure consistency in 

how benefits are evaluated across agencies, the Administration sought to develop a transparent 

and defensible method, specifically designed for the rulemaking process, to quantify avoided 

climate change damages from reduced CO2 emissions. The interagency group did not undertake 

any original analysis. Instead, it combined SCC estimates from the existing literature to use as 

interim values until a more comprehensive analysis could be conducted.

The outcome of the preliminary assessment by the interagency group was a set of five 

interim values: global SCC estimates for 2007 (in 2006 dollars) of $55, $33, $19, $10, and $5 per 

ton of CO2. The $33 and $5 values represented model-weighted means of the published 

estimates produced from the most recently available versions of three integrated assessment 

models—DICE, PAGE, and FUND—at approximately 3 and 5 percent discount rates. The $55 

and $10 values were derived by adjusting the published estimates for uncertainty in the discount 

rate (using factors developed by Newell and Pizer (2003)) at 3 and 5 percent discount rates, 

respectively. The $19 value was chosen as a central value between the $5 and $33 per ton 

estimates. All of these values were assumed to increase at 3 percent annually to represent 

growth in incremental damages over time as the magnitude of climate change increases.

These interim values represent the first sustained interagency effort within the U.S. 

government to develop an SCC for use in regulatory analysis. The results of this preliminary 

effort were presented in several proposed and final rules and were offered for public comment in 

connection with proposed rules, including the joint EPA-DOT fuel economy and CO2 tailpipe 

emission proposed rules.

15.3.2 Approach and Key Assumptions

Since the release of the interim values, interagency group reconvened on a regular basis 

to generate improved SCC estimates considered for this final rule. Specifically, the group 

considered public comments and further explored the technical literature in relevant fields. 

It is important to recognize that a number of key uncertainties remain, and that current 

SCC estimates should be treated as provisional and revisable since they will evolve with 

improved scientific and economic understanding. The interagency group also recognizes that the 

existing models are imperfect and incomplete. The National Academy of Science (2009) points 

out that there is tension between the goal of producing quantified estimates of the economic 
15-19

damages from an incremental ton of carbon and the limits of existing efforts to model these 

effects. There are a number of concerns and problems that should be addressed by the research 

community, including research programs housed in many of the agencies participating in the 

interagency process to estimate the SCC. 

The U.S. Government will periodically review and reconsider estimates of the SCC used 

for cost-benefit analyses to reflect increasing knowledge of the science and economics of climate 

impacts, as well as improvements in modeling. In this context, statements recognizing the 

limitations of the analysis and calling for further research take on exceptional significance. The 

interagency group offers the new SCC values with all due humility about the uncertainties 

embedded in them and with a sincere promise to continue work to improve them.

In summary, in considering the potential global benefits resulting from reduced CO2

emissions, DOE used the most recent values identified by the interagency process, adjusted to 

2009$ using the standard GDP deflator values for 2008 and 2009. For each of the four cases 

specified, the values for emissions in 2010 used were approximately $4.9, $22.1, $36.3, and 

$67.1 per metric ton avoided (values expressed in 2009$). To monetize the CO2 emissions 

reductions expected to result from amended standards for refrigeration products, DOE used the 

values identified in Table A1 of the “Social Cost of Carbon for Regulatory Impact Analysis 

Under Executive Order 12866,” which is reprinted in Appendix15- A, appropriately escalated to 

2009$.

15.4 WETLAND, ENDANGERED AND THREATENED SPECIES, AND 

CULTURAL RESOURCES

Because residential refrigeration products are not water-consuming products, more 

efficient refrigeration would not reduce the amount of water discharged into the waste stream. As 

a result, refrigeration energy conservation standards do not have the effect of improving the 

quality of wetlands, nor threatened or endangered species that reside in these wetlands. This 

action is also not expected to impact cultural resources such as historical or archaeological sites.

15.5 SOCIOECONOMIC IMPACTS 

DOE's analysis has shown that the increase in the first cost of purchasing more efficient 

refrigeration products at the proposed standard levels is, in most cases, completely offset by a 

reduction in the life-cycle cost (LCC) of owning a more efficient product for the average 

consumer. In other words, the consumer will pay less operating costs over the life of the product 

even through the first cost increases. The complete LCC analysis and its conclusions are 

presented in chapter 8 of the TSD.

For subgroups of low-income and senior consumers that purchase refrigeration products, 

DOE determined that the average LCC impact of the standards is similar to that for the full 

sample of consumers. Therefore, DOE concludes that the proposed standards would have no 

significant adverse socioeconomic impact. For a complete discussion on the LCC impacts on 

consumer subgroups, see chapter 11 of the TSD.
15-20

15.6 ENVIRONMENTAL JUSTICE IMPACTS

In view of Executive Order 12898 of February 11, 1994, “Federal Actions to Address

Environmental Justice in Minority Populations and Low-Income Populations,” DOE examined 

the effect of the energy conservation standards on low-income households. As described in the 

LCC subgroup analysis in Chapter 11 of the TSD, DOE found that there were no 

disproportionately high and adverse human health or environmental effects on low-income 

populations that would result from the proposed energy conservation standards.

15.7 NOISE AND AESTHETICS

Improvements in efficiency of residential refrigerators are expected to result from 

changes in the choice of components and other design features. These changes are described in 

chapter 5 of this TSD. These design changes are not expected to change noise levels in 

comparison to products in today’s market. Products that are currently manufactured in the 

existing market that would meet the standards are no louder than less efficient products. Changes 

to the design to improve the efficiency levels are not anticipated to affect the product aesthetics.

15.8 SUMMARY OF ENVIRONMENTAL IMPACTS

Table 15.8.1 summarizes the estimated emissions impacts for each of the TSLs for 

refrigeration products. It shows cumulative changes in emissions for CO2, NOX, and Hg for 2014 

through 2043 for each of the refrigeration product TSLs. Cumulative CO2, NOX, and Hg 

emissions are reduced compared to the Reference case for all TSLs. For comparison, the 

cumulative power sector emissions in the AEO2010 Reference case, over the period 2014 

through 2043, are 74,571 Mt for CO2, 61,625 kt for NOX, and 917 tons for Hg.

Upstream fuel cycle emission of CO2 and NOX are described but not quantified in section 

15.2.6. The text describes potential reductions in fuel cycle emissions as percentage of decreases 

in power plant emissions. This approach suggests that upstream fuel cycle emissions would 

decrease and provides a sense for the magnitude of effects; however DOE does not report actual 

estimates of the effects. 

For subgroups of low-income and senior consumers that purchase refrigeration products, 

DOE determined that the average LCC impact of the standards is similar to that for the full 

sample of consumers. Therefore, DOE concludes that the proposed standards would have no 

significant adverse socioeconomic impact.

No impacts are anticipated in the areas of environmental justice, wetlands, endangered 

and threatened species, and cultural resources; or noise and aesthetics.
15-21

Table 15.8.1 Cumulative Emissions Reductions Under Refrigeration Product TSLs*

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Standard-Size Refrigerator-Freezers

 CO2 (Mt)

 NOX (kt)

 Hg (t)

154

124

0.79

177

142

0.91

208

168

1.07

283

228

1.45

338

272

1.73

Standard-Size Freezers

 CO2 (Mt)

 NOX (kt)

 Hg (t)

48

39

0.245

69

55

0.351

81

65

0.413

92

74

0.469

99

79

0.501

Compact Refrigeration Products

 CO2 (Mt)

 NOX (kt)

 Hg (t)

20

16

0.10

24

19

0.12

28

23

0.15

35

28

0.19

39

31

0.21

Built-In Refrigeration Products

 CO2 (Mt)

 NOX (kt)

 Hg (t)

1.23

0.99

0.006

1.79

1.44

0.009

3.58

2.88

0.018

4.45

3.58

0.023

5.32

4.28

0.027

* Values for CO2 are in metric tons; values for NOX and Hg are in short tons.
15-22

REFERENCES

1. U.S. Environmental Protection Agency, Nitrogen Oxides Health and Environmental 

Impacts of NOx (Posted May 26th, 2009) 

<http://www.epa.gov/air/urbanair/nox/hlth.html>

2. U.S. Environmental Protection Agency, Nitrogen Oxides, 2002.

<
15-23

13. Energy Information Administration, Updated Annual Energy Outlook 2009 Reference 

Case Service Report, 2009. Washington, DC. Report No. DOE/EIA-0383(2009). 

<http://www.eia.doe.gov/oiaf/aeo/>

14. Environmental Protection Agency, Human-Related Sources and Sinks of Carbon 

Dioxide, 2009. <http://www.epa.gov/climatechange/emissions/co2_human.html>

15. U.S. Environmental Protection Agency, Emission Inventory Improvement Program, 

Technical Report Series Volume 3, Area Sources, 

<http://www.epa.gov/ttn/chief/eiip/techreport/volume03/>

16. American Gas Association, Source Energy and Emission Factors for Residential Energy 

Consumption, August, 2000. Washington, DC. 

<http://www.aga.org/NR/rdonlyres/F17F15FC-FC7D-4469-B8E2-

14F26FFAC440/0/0008ENERGYEMISSIONFACTORSRESCONSUMPTION.pdf>

17. Herzog, H. a. K. S., IPCC Special Report on Carbon dioxide Capture and Storage. 

Chapter 8: Cost and economic potential, 2005. Intergovernmental Panel on Climate 

Change. Cambridge. 

18. DeLuchi, M. A., Emissions of Greenhouse Gases from the Use of Transportation Fuels 

and Electricity, Volume 2: Appendixes A-S, November, 1993. Argonne National 

Laboratory. Argonne, IL. Report No. ANL/ESD/TM-22-Vol.2. 
16-i

CHAPTER 16. REGULATORY IMPACT ANALYSIS

TABLE OF CONTENTS

16.1 INTRODUCTION ................................................................................................... 16-1

16.2 NON-REGULATORY POLICIES.......................................................................... 16-2

16.2.1 Methodology............................................................................................................ 16-2

16.2.2 Assumptions Regarding Non-Regulatory Policies .................................................. 16-3

16.2.3 Policy Interactions ................................................................................................... 16-5

16.3 NON-REGULATORY POLICIES.......................................................................... 16-5

16.3.1 No New Regulatory Action ..................................................................................... 16-6

16.3.2 Consumer Rebates ................................................................................................... 16-6

16.3.2.1 Standard-Size Refrigerator-Freezers...................................................... 16-7

16.3.2.2 Standard-Size Freezers......................................................................... 16-11

16.3.2.3 Compact Refrigeration Products.......................................................... 16-13

16.3.2.4 Built-In Refrigeration Products............................................................ 16-15

16.3.3 Consumer Tax Credits........................................................................................... 16-17

16.3.4 Manufacturer Tax Credits...................................................................................... 16-20

16.3.5 Voluntary Energy Efficiency Targets.................................................................... 16-22

16.3.5.1 Standard-Size Refrigerator-Freezers.................................................... 16-23

16.3.5.2 Standard-Size Freezers......................................................................... 16-24

16.3.5.3 Compact Refrigeration Products.......................................................... 16-24

16.3.5.4 Built-in Refrigeration Products............................................................ 16-24

16.3.6 Early Replacement................................................................................................. 16-25

16.3.7 Bulk Government Purchases.................................................................................. 16-29

16.3.7.1 Standard-Size Refrigerator-Freezers.................................................... 16-30

16.3.7.2 Standard-Size Freezers......................................................................... 16-31

16.3.7.3 Compact Refrigeration Products.......................................................... 16-31

16.3.7.4 Built-in Refrigeration Products............................................................ 16-32

16.4 IMPACTS OF NON-REGULATORY ALTERNATIVES................................... 16-32

16.5 SUMMARY OF RESULTS FOR NON-REGULATORY ALTERNATIVES .... 16-36

16.6 SUPER-EFFICIENT VOLUNTARY TARGETS................................................. 16-39

LIST OF TABLES

Table 16.1.1 Non-Regulatory Alternatives to National Standards................................... 16-1

Table 16.2.1 Efficiency Levels in Proposed Standard Levels for Standard-Size 

Refrigerator-Freezers................................................................................... 16-4

Table 16.2.2 Efficiency Levels in Proposed Standard Levels for Standard-Size 

Freezers........................................................................................................ 16-4

Table 16.2.3 Efficiency Levels in Proposed Standard Levels for Compact 

Refrigeration Products................................................................................. 16-4

Table 16.2.4 Efficiency Levels in Proposed Standard Levels for Built-In 

Refrigeration Products................................................................................. 16-5
16-ii

Table 16.3.1 Benefit/Cost Ratios Without and With Rebates for Standard-Size 

Refrigerator-Freezers (2009$) ..................................................................... 16-8

Table 16.3.2 Market Penetrations in 2014 Without and With Rebates for StandardSize Refrigerator-Freezers......................................................................... 16-11

Table 16.3.3 Benefit/Cost Ratios Without and With Rebates for Standard-Size 

Freezers...................................................................................................... 16-12

Table 16.3.4 Market Penetration in 2014 Without and With Rebates for StandardSize Freezers.............................................................................................. 16-13

Table 16.3.5 Benefit/Cost Ratios Without and With Rebates for Compact 

Refrigeration Products (PC 11).................................................................. 16-14

Table 16.3.6 Market Penetration in 2014 Without and With Rebates for Compact 

Refrigeration Products............................................................................... 16-15

Table 16.3.7 Benefit/Cost Ratios Without and With Rebates for Built-in 

Refrigeration Products (2009$).................................................................. 16-16

Table 16.3.8 Market Penetrations in 2014 Without and With Rebates for Built-in 

Refrigeration Products............................................................................... 16-17

Table 16.3.9 Market Penetrations in 2014 Attributable to Consumer Tax Credits for 

Standard-Size Refrigerator-Freezers.......................................................... 16-19

Table 16.3.10 Market Penetrations in 2014 Attributable to Consumer Tax Credits for 

Standard-Size Freezers............................................................................... 16-19

Table 16.3.11 Market Penetrations in 2014 Attributable to Consumer Tax Credits for 

Compact Refrigeration Products................................................................ 16-19

Table 16.3.12 Market Penetrations in 2014 Attributable to Consumer Tax Credits for 

Built-in Refrigeration Products.................................................................. 16-20

Table 16.3.13 Market Penetrations in 2014 Attributable to Manufacturer Tax Credits 

for Standard-Size Refrigerator-Freezers.................................................... 16-21

Table 16.3.14 Market Penetrations in 2014 Attributable to Manufacturer Tax Credits 

for Standard-Size Freezers......................................................................... 16-21

Table 16.3.15 Market Penetrations in 2014 Attributable to Manufacturer Tax Credits 

for Compact Refrigeration Products.......................................................... 16-22

Table 16.3.16 Market Penetrations in 2014 Attributable to Manufacturer Tax Credits 

for Built-in Refrigeration Products............................................................ 16-22

Table 16.5.1 Impacts of Non-Regulatory Alternatives for Standard-Size 

Refrigerator-Freezers that Meet the Proposed Standard (TSL 3).............. 16-37

Table 16.5.2 Impacts of Non-Regulatory Alternatives for Standard-Size Freezers 

that Meet the Proposed Standard (TSL 2).................................................. 16-37

Table 16.5.3 Impacts of Non-Regulatory Alternatives for Compact Refrigeration 

Products that Meet the Proposed standard (TSL 2) ................................... 16-38

Table 16.5.4 Impacts of Non-Regulatory Alternatives for Built-in Refrigeration 

Products that Meet the Proposed standard (TSL 3) ................................... 16-38

Table 16.5.5 Summary of Impacts of Non-Regulatory Alternatives for All 

Refrigeration Products that Meet the Proposed Standards ........................ 16-39

Table 16.6.1 Super-efficient Voluntary Targets Program Parameters for StandardSize Refrigerator-Freezers......................................................................... 16-40
16-iii

Table 16.6.2 Super-efficient Voluntary Targets Program Incremental Manufacturer 

Selling Price for Standard-Size Refrigerator-Freezers .............................. 16-41

Table 16.6.3 Super-efficient Voluntary Targets Program: Additional Savings 

Relative to Proposed Standards for Standard-Size RefrigeratorFreezers...................................................................................................... 16-41

LIST OF FIGURES

Figure 16.3.1 Market Penetration Curve for Top-Mount Refrigerator-Freezers ............... 16-9

Figure 16.3.2 Market Penetration Curve for Bottom-Mount Refrigerator-Freezers........ 16-10

Figure 16.3.3 Market Penetration Curve for Side-by-Side Refrigerator-Freezers........... 16-10

Figure 16.3.4 Estimated Replacement Shipments of Standard-Size RefrigeratorFreezers With and Without an Early Replacement Program..................... 16-27

Figure 16.3.5 Estimated Replacement Shipments of Standard-Size Freezers With and 

Without an Early Replacement Program ................................................... 16-28

Figure 16.3.6 Estimated Replacement Shipments of Compact Refrigerators With and 

Without an Early Replacement Program ................................................... 16-29

Figure 16.3.7 Estimated Replacement Shipments of Compact Freezers With and 

Without an Early Replacement Program ................................................... 16-29

Figure 16.4.1 Market Penetration of Standard-Size Refrigerator-Freezers Meeting 

Target Level in Policy Cases ..................................................................... 16-33

Figure 16.4.2 Market Penetration of Standard-Size Freezers Meeting Target Level in 

Policy Cases............................................................................................... 16-34

Figure 16.4.3 Market Penetration of Compact Refrigeration Products Meeting Target 

Level in Policy Cases................................................................................. 16-35

Figure 16.4.4 Market Penetration of Built-in Refrigeration Products Meeting Target 

Level in Policy Cases................................................................................. 16-36
16-1

CHAPTER 16. REGULATORY IMPACT ANALYSIS

16.1 INTRODUCTION

The U.S. Department of Energy (DOE) has determined that energy conservation 

standards for residential refrigerators, refrigerator-freezers, and freezers constitute an 

“economically significant regulatory action” under Executive Order (E.O.) 12866, Regulatory

Planning and Review. 58 FR 51735, Volume 58, No. 190, page 51735. (October 4, 1993). Under 

10 CFR part 430, subpart C, appendix A, section III.12, DOE committed to evaluating nonregulatory alternatives to proposed standards by performing a regulatory impact analysis (RIA). 

61 FR 36981, Volume 61, No. 136, page 36978. (July 15, 1996). This RIA, which DOE has 

prepared pursuant to E.O. 12866, evaluates potential non-regulatory alternatives, comparing the 

costs and benefits of each to those of the proposed standards. 58 FR 51735, page 51741. As 

noted in E.O. 12866, this RIA is subject to review by the Office of Management and Budget’s 

Office of Information and Regulatory Affairs. 58 FR 51735, page 51740.

For this Regulatory Impact Analysis, DOE used an integrated NIA-RIA integrated model

built on the NIA model discussed in chapter 10 for its analysis. DOE studied the impacts of the 

non-regulatory policies on the 11 representative product classes analyzed for the NOPR. It then 

applied the assumptions of the impacts of each policy on these representative product classes to 

the shipments of the remaining product classes associated with each representative class. Thus, 

the savings reported in this chapter represent the savings for all the considered product classes.

DOE identified six non-regulatory policy alternatives that feasibly could provide 

incentives for the same energy efficiency levels as the proposed standards for the products that 

are the subject of this rulemaking. The non-regulatory policy alternatives are listed in Table 

16.1.1. DOE evaluated each alternative in terms of its ability to achieve significant energy 

savings at a reasonable cost, and compared the effectiveness of each to the effectiveness of the 

proposed standard. 

Table 16.1.1 Non-Regulatory Alternatives to National Standards 

No New Regulatory Action

Consumer Rebates

Consumer Tax Credits

Manufacturer Tax Credits

Voluntary Energy Efficiency Targets

Early Replacement

Bulk Government Purchases

In addition to the above six non-regulatory policy alternatives, specifically for this 

rulemaking DOE evaluated a super-efficient voluntary targets (SEVT) program. Sections 16.2 

and 16.3 discuss the analysis of the six policies listed above, with a description of the SEVT

policy in section 16.3.8. Sections 16.4 and 16.5 present the results of the six policy alternatives, 

and section 16.6 describes the analysis of the SEVT policy and presents the results.
16-2

16.2 NON-REGULATORY POLICIES

This section describes the method DOE used to analyze the energy savings and cost 

effectiveness of the six non-regulatory policy alternatives (excluding the alternative of no new 

regulatory action) for the identified residential refrigerators, refrigerator-freezers, and freezers. 

This section also describes the assumptions underlying the analysis. 

16.2.1 Methodology 

DOE used its integrated national impact analysis–regulatory impact analysis (NIA-RIA)

spreadsheet models to calculate the national energy savings (NES) and net present value (NPV) 

associated with each non-regulatory policy alternative. Chapter 10 of the technical support 

document (TSD) describes the NIA spreadsheet models. Appendix 16-A, sections 16-A.2 and 

16-A.3, document the new NIA-RIA integrated model approach.

DOE quantified the effect of each alternative on the purchase of products that meet target 

levels, which are defined as the efficiency levels in the proposed standards. After establishing the 

quantitative assumptions underlying each alternative, DOE appropriately revised inputs to the 

NIA-RIA spreadsheet models. The primary model inputs revised were market shares of products 

meeting target efficiency levels and equipment replacement rates. The shipments of products for 

any given year reflect a distribution of efficiency levels. DOE assumed that the proposed 

standards would affect 100 percent of the shipments of products that did not meet target levels in 

the base case,a whereas the non-regulatory policies would affect a smaller percentage of those

shipments. DOE made certain assumptions about the percentage of shipments affected by each 

alternative policy. DOE used those percentages to calculate the shipment-weighted average 

energy consumption and costs of residential refrigerators, refrigerator-freezers, and freezers 

attributable to each policy alternative. 

Increasing the efficiency of a product often increases its average installed cost. On the 

other hand, operating costs generally decrease because energy consumption declines. DOE 

therefore calculated an NPV for each non-regulatory alternative in the same way it did for the 

proposed standards. In some scenarios, increases in total installed cost are mitigated by 

government rebates or tax credits. Because DOE assumed that consumers would re-pay credits 

and rebates in some way (such as additional taxes), DOE did not include rebates or tax credits as 

a consumer benefit when calculating national NPV. DOE’s analysis also excluded any 

administrative costs for the non-regulatory policies; including such costs would decrease the

NPVs slightly.

The following are key measures for evaluating the impact of each alternative. 

• National energy savings, given in quadrillion Btus (quads), describes the cumulative 

national primary energy savings for products bought during the period from the 

effective date of the policy (2104) through the end of the analysis period (2043).

 

a The base case for the NIA is a market-weighted average of units at several efficiency levels.
16-3

• Net present value represents the value in 2009$ (discounted to 2010)b of net monetary 

savings from products bought during the period from the effective date of the policy 

(2014) through the end of the analysis period (2043). 

• DOE calculated the NPV as the difference between the present value of installed 

equipment cost and operating expenditures in the base case and the present value of 

those costs in each policy case. DOE calculated operating expenses (including energy

costs) for the life of the product.

16.2.2 Assumptions Regarding Non-Regulatory Policies 

The effects of non-regulatory policies are by nature uncertain, because they depend on 

program implementation and marketing efforts and on consumers’ responses to a program. 

Because the projected effects depend on assumptions regarding the rate of consumer 

participation, they are subject to more uncertainty than are the impacts of mandatory standards, 

which DOE assumes will meet with full compliance. To increase the robustness of the analysis, 

DOE conducted a literature review regarding each non-regulatory policy and consulted with 

recognized experts to gather information on similar incentive programs that have been 

implemented in the United States. By studying experiences with the various types of programs,

DOE sought to make credible assumptions regarding potential market impacts. Section 16.3

presents the sources DOE relied on in developing assumptions about each alternative policy and 

reports DOE’s conclusions as they affected the assumptions that underlie the modeling of each 

policy.

Each non-regulatory policy that DOE considered would improve the average efficiency 

of new residential refrigerators, refrigerator-freezers, and freezers relative to their base case

efficiency scenarios (which involve no new regulatory action). The analysis considered that each 

alternative policy would induce consumers to purchase units having the same efficiency levels as 

required by the proposed standards (the target levels). As opposed to the standards case, 

however, the policy cases may not lead to 100 percent market penetration of units that meet 

target levels.

Tables 16.2.1 through 16.2.4 show the efficiency levels stipulated in the proposed 

standards for the products in this rulemaking. 

 

b The Final Rule for refrigeration products is expected to be published in 2010.
16-4

Table 16.2.1 Efficiency Levels in Proposed Standard Levels for Standard-Size 

Refrigerator-Freezers

Trial 

Standard

Level

Top-Mount 

Refrigerator-Freezers

Bottom-Mount 

Refrigerator-Freezers

Side-by-Side 

RefrigeratorFreezers

Product classes 1, 1A, 2, 

3, 3A, 3I and 6

Product classes 5, 5A, 

and 5I

Product classes 

4, 4I, and 7

Efficiency Level (% less than baseline energy use)

3 4 (25)* 3 (20) 4 (25)

* Level for product classes 1, 1A, and 2 is 20%.

Table 16.2.2 Efficiency Levels in Proposed Standard Levels for Standard-Size 

Freezers

Trial 

Standard

Level

Upright Freezers Chest Freezers

Product class 9 Product class 8

Product classes 

10 and 10A

Efficiency Level (% less than baseline energy use)

2 5 (30) 4 (25) 4 (25)*

* Level for product class 10A is 30%.

Table 16.2.3 Efficiency Levels in Proposed Standard Levels for Compact Refrigeration 

Products

Trial 

Standard

Level

Compact Refrigerators and RefrigeratorFreezersCompact Freezers

Product classes 11, 

11A, 12, and 13A

Product classes 

13, 14,and 15

Product classes 16, 17, 

18

Efficiency Level (% less than baseline energy use)

2 4 (25) 2 (15)* 1 (10)

* Level for product class 14 is 20%.
16-5

Table 16.2.4 Efficiency Levels in Proposed Standard Levels for Built-In Refrigeration 

Products

Trial 

Standard

Level

Built-in AllRefrigerators 

Built-in 

Bottom-Mount 

RefrigeratorFreezers

Built-in Side-by-Side 

Refrigerator-Freezers

Built-in Upright 

Freezers 

Product class 

3A-BI

Product classes 

5-BI and 5I-BI

Product classes 

4-BI, 4I-BI and 

7-BI

Product class 

9-BI

Efficiency Level (% less than baseline energy use)

3 3 (20) 2 (15) 3 (20) 4 (25)

In addition to the above policy alternatives, DOE evaluated a policy where a new, twotiered voluntary efficiency targets program was implemented in addition to the proposed 

standards. These voluntary efficiency targets would feature speculative “super-efficient” 

products at efficiency levels above the current max-tech levels. The program would target 

consumers in the highest electricity price regions of the country, to make the products maximally 

cost-effective. For the purpose of evaluating the program, only standard-sized refrigeratorfreezers were considered. 

DOE assumed that the effects of non-regulatory policies would last from the effective 

date of standards—2014—through the end of the analysis period, which is 2043. 

16.2.3 Policy Interactions 

DOE calculated the effects of each non-regulatory policy separately from those of the 

other policies. In practice, some policies are most effective when implemented in combination, 

such as early replacement implemented with consumer rebates, or early replacement 

implemented with bulk government purchases. However, DOE attempted to make conservative 

assumptions to avoid double-counting policy impacts. The resulting policy impacts are not 

additive: the combined effect of several or all policies cannot be inferred from summing their 

results. 

Section 16.3 presents graphs that show the market penetration estimated under each nonregulatory policy for residential refrigerators, refrigerator-freezers, and freezers.

16.3 NON-REGULATORY POLICIES

The following subsections describe DOE’s analysis of the impacts of the six nonregulatory policy alternatives to proposed standards for refrigerators, refrigerator-freezers, and 

freezers. (Because the alternative of No New Regulatory Action has no energy or NPV impacts, 

essentially representing the NIA base case, DOE did not perform additional analysis for that 

alternative.) DOE developed estimates of the market penetration of high-efficiency products both 

with and without each of the non-regulatory policy alternatives. 
16-6

16.3.1 No New Regulatory Action 

The case in which no new regulatory action is taken with regard to the energy efficiency 

of residential refrigeration products constitutes the base case, as described in chapter 10,

National Impact Analysis. The base case provides the basis of comparison for all other policies. 

By definition, no new regulatory action yields zero energy savings and an NPV of zero dollars.

16.3.2 Consumer Rebates

DOE considered this scenario in which the Federal government would provide financial 

incentives in the form of rebates to consumers for purchasing energy efficient appliances. This 

policy provides a consumer rebate for purchasing refrigeration products that operate at (or 

above) the same efficiencies as stipulated in proposed standards (target levels).

To inform its estimate of the market impacts of consumer rebates, DOE performed a 

thorough search for existing rebate programs nationwide. It gathered data on hundreds of utility 

or agency rebates for refrigeration products throughout the country. DOE also reviewed the 

current State Energy Efficient Appliance Rebate Program (SEEARP) funded by the American 

Recovery and Reinvestment Act (ARRA).

1

, c This program may be considered a combination of 

a consumer rebate and an early replacement program, with intention to induce appliance sales 

during the economic recession. DOE analyzed summary material from DOE on SEEARP rebates 

for refrigerators and freezers.2

DOE based its evaluation methodology for consumer rebates on a comprehensive study 

of California’s potential for achieving energy efficiency. This study, performed by XENERGY,

Inc.,d summarized experiences with various utility rebate programs.3 XENERGY’s analytical 

method utilized graphs, or penetration curves, that estimate the market penetration of a 

technology based on its benefit/cost (B/C) ratio. DOE consulted with experts and reviewed other 

methods of estimating the effect of consumer rebate programs on the market penetration of 

efficient technologies. The other methods, developed after the referenced XENERGY report was 

published,4, 5, 6, 7, 8,9 used different approaches: other economic parameters (e.g., payback period), 

expert surveys, or calibration of a model with specific program data rather than using generic 

penetration curves. Some models in use by energy efficiency program evaluation experts were so 

client-specific that generic relationships between economic parameters and consumer response 

could not be established.4 DOE decided that the most appropriate available method for this RIA 

analysis was the XENERGY approach of penetration curves based on B/C ratio, which 

incorporates lifetime operating cost savings.

 

c DOE provided funding for State-run rebate programs for consumer purchases of new ENERGY STAR® qualified 

home appliances. The resulting SEEARP was implemented beginning in late 2009 by the 50 States and six U.S. 

territories, each selecting its own appliances, rebate levels, efficiency levels, appliance recycling requirements, and 

eligible populations.

d XENERGY is now owned by KEMA, Inc. (www.kema.com)
16-7

XENERGY’s model estimates market impacts induced by financial incentives based on 

the premise that two types of information diffusion drive the adoption of new technologies. 

Internal sources of information encourage consumers to purchase new products primarily 

through word-of-mouth from early adopters. External sources affect consumer purchase 

decisions through marketing efforts and information from outside the consumer group. Appendix 

16-A, section 16-A.3, contains additional details on internal and external information diffusion.

XENERGY’s model equation accounts for the influences of both internal and external 

sources of information by superimposing the two components. Combining the two mechanisms 

for information diffusion, XENERGY’s model generates a set of penetration (or implementation) 

curves for a measure. XENERGY then calibrated the curves based on participation data from 

utility rebate programs. The curves illustrate the increased penetration (i.e., increased market 

share) of efficient products driven by consumer response to changes in B/C ratio induced by 

rebate programs. The penetration curves depict various diffusion patterns based on perceived 

barriers (from no barriers to extremely high barriers) to consumer purchase of high-efficiency 

products.

DOE adjusted the XENERGY penetration curves based on expert advice founded on 

more recent utility program experience.7,10 DOE also devised an interpolation method to create 

penetration curves based on relationships between the actual base case market penetrations and 

actual B/C ratios for each representative product class. Appendix 16-A, sections 16-A.3.2 and 

16-A.3.3, contain discussion on DOE’s methodology for adjusting and interpolating the curves.

DOE modeled the effects of a consumer rebate policy for refrigerators, refrigeratorfreezers, and freezers by determining the increase in market penetration of products meeting the 

target level relative to their market penetration in the base case. It did this using the interpolated 

penetration curves created for each representative product class based on the XENERGY

methodology to best reflect the market barrier levels faced by each product class. The next 

section (on standard-size refrigerator-freezers) shows examples of these interpolated curves. 

Appendix 16-A, section 16-A.3.4, displays the curves developed for the remaining product 

groups.e

16.3.2.1 Standard-Size Refrigerator-Freezers

For standard-size refrigerator-freezers, DOE estimated the effect of increasing the B/C 

ratio via a rebate that would pay part or all of the increased installed cost of a unit that met the 

target efficiency level compared to one meeting the baseline efficiency level.

f

 

e The four product groups are Standard-Size Refrigerator-Freezers, Standard-Size Freezers, Compact Refrigeration 

Products, and Built-in Refrigeration Products.

DOE based the

rebate amounts on a large sample of utility and agency rebate programs for refrigerator-freezers. 

f The baseline technology for each product class is defined in the engineering analysis, chapter 5, as the technology 

that represents the basic characteristics of products in that class. A baseline unit typically is one that just meets 

current Federal energy conservation standards and provides basic consumer utility. 
16-8

For standard-size refrigerator-freezers, DOE gathered data on 129 rebate programs 

initiated by 115 utilities or agencies in States throughout the country. (Appendix 16-A, section 

16-A.5.1, identifies the rebate programs.) To represent the rebate level for standard-size

refrigerator-freezers, DOE used the simple average of the rebate amounts in these 129 programs. 

DOE assumed that this average would apply to models at all efficiency levels at or above the 

target level for each representative product class. For each of these efficiency levels, the rebate 

amount represented a certain percent of the increase in total installed cost.

Since nearly all the utility/agency rebate programs had an efficiency requirement at the 

ENERGY STAR level, while the proposed standard levels for standard-size refrigerators were 

set at a higher efficiency level, DOE sought data on rebates requiring levels higher than 

ENERGY STAR to determine whether to adjust this average rebate level amount. The sample 

size of utility/agency rebates above the ENERGY STAR level was very small. From the set of

SEEARP rebates for States whose programs included refrigerators, DOE compared the average 

rebate amounts for units meeting ENERGY STAR levels to the average rebate amounts for units 

meeting CEE Tier 2 and CEE Tier 3 levels. It found that the national average rebate amounts for 

ENERGY STAR refrigerators were actually higher than those for rebates at either of the CEE 

levels (both of which comprised a much smaller sample than the set of SEEARP rebates for the 

ENERGY STAR level). Based on this anomalous result, DOE did not perform an adjustment to 

the utility/agency rebate amount reported above, but rather assumed that the average rebate 

amount would not vary significantly by efficiency level. 

DOE assumed that rebates would remain in effect at the same levels throughout the 

forecast period (2014–2043). 

For standard-size refrigerator-freezers, DOE first calculated B/C ratios without a rebate 

using the difference in total installed costs and lifetime operating cost savings between the unit 

meeting the target level and the baseline unit. It then calculated B/C ratios given a rebate for the 

unit meeting the target efficiency level. Because the rebate reduced the incremental cost, the unit 

receiving the rebate had a larger B/C ratio. Table 16.3.1 shows the effects of consumer rebates 

on B/C ratios for standard-size refrigerator-freezers. Each B/C ratio value for units with rebates 

represents a weighted averageg of the values for the efficiency levels at or above the target level 

to which the rebate would apply.

Table 16.3.1 Benefit/Cost Ratios Without and With Rebates for Standard-Size 

Refrigerator-Freezers (2009$)

Top-Mount 

Refrigerator 

Freezers

Bottom-Mount 

RefrigeratorFreezers

Side-by-Side 

RefrigeratorFreezers

B/C Ratio Without Rebate 3.7 9.3 10.2

Rebate Amount $52 $52 $52

 g The weighting factor is the 2014 base case market share of each of the corresponding efficiency levels. 
16-9

B/C Ratio With Rebate 8.6 Inf. Inf.

Calculated Market Barrier Curve

Moderate –

High No - Low Moderate - High

Inf. = infinite B/C ratio, which occurs when the rebate pays the full incremental cost.

DOE used the B/C ratios along with the penetration curves shown in Figures 16.3.1

through 16.3.3 to estimate the percentage of consumers who would purchase standard-size 

refrigerator- freezers that meet the target levels both with and without a rebate incentive.

Figure 16.3.1 Market Penetration Curve for Top-Mount RefrigeratorFreezers
16-10

Figure 16.3.2 Market Penetration Curve for Bottom-Mount RefrigeratorFreezers

Figure 16.3.3 Market Penetration Curve for Side-by-Side RefrigeratorFreezers
16-11

The curve calculated by DOE to represent the market behavior for top-mount 

refrigerator-freezers was in between the moderate barriers and high barriers penetration curves. 

For bottom-mount refrigerator-freezers the curve was close to the low barriers penetration curve. 

For side-by-side refrigerator-freezers the curve was between the moderate and high barriers

penetration curves. 

For each product class, DOE next estimated the percent increase represented by the 

change in penetration rate shown on the penetration curve. It then added that percent increase to 

the market share of units that meet the target level in the base case to obtain the market share of 

units that meet the target level in the rebate case. Table 16.3.2 summarizes the market shares of

standard-size refrigerator-freezers in 2014. 

Table 16.3.2 Market Penetrations in 2014 Without and With Rebates for StandardSize Refrigerator-Freezers

Top-Mount

RefrigeratorFreezers

Bottom-Mount 

Refrigerator-

% Freezers %

Side-by-Side 

RefrigeratorFreezers

Base-Case Market Share of Units that 

Meet Target Levels

%

0 68 0

Market Share of Units that Meet Target 

Levels With Rebates 18 82 28

Increased Market Share of Units that 

Meet Target Level With Rebates 18 14 28

See Appendix 16-A, Table 16-A.4.1, for the annual increases in market shares for 

standard-size refrigerator-freezers meeting target efficiency levels under a rebate policy. DOE

used these increases in market shares as inputs to represent the policy case scenarios in its NIARIA model. Section 16.4 presents the resulting efficiency trends for the policy case of consumer 

rebates for refrigerator-freezers.

16.3.2.2 Standard-Size Freezers

For standard-size freezers, DOE estimated the effect of increasing the B/C ratio via a 

rebate that would pay part or all of the increased installed cost of a unit that met the target 

efficiency level compared to the cost of a unit meeting the baseline level. DOE based the rebate 

amounts on a large sample of utility and agency rebate programs for standard-size freezers. 

DOE gathered data on 62 rebate programs provided by 59 utilities or agencies in various

States. (Appendix 16-A, section 16-A.5.2, identifies the rebate programs.) To represent the 

rebate level for standard-size freezers, DOE used the simple average of the rebate amounts in 

these 62 programs. DOE assumed that this average amount would apply to models at all 

efficiency levels at or above the target level for each representative product class. For each of 

these efficiency levels, the rebate amount represented a certain percent of the increase in total 

installed cost. Since all of the utility/agency rebates were for freezers at the ENERGY STAR 

level, while the proposed standard levels for standard-size freezers were set at a higher efficiency 

level, DOE again sought data on rebates requiring levels higher than ENERGY STAR to 
16-12

determine whether to adjust this average rebate level amount. However, all of the SEEARP 

freezer rebates were also for the ENERGY STAR efficiency level. Hence DOE did not have any 

data with which to adjust the rebate amount, but rather assumed that the average rebate amount 

would not vary significantly by efficiency level.

DOE assumed that rebates would remain in effect until the market had been transformed; 

that is, the shift in market share of efficient units seen in the first year of the rebate program 

would be maintained throughout the forecast period (2014–2043). 

For standard-size freezers, DOE first calculated B/C ratios without a rebate using the 

difference in lifetime operating costs and total installed costs between the unit meeting the target 

level and the baseline unit. It then calculated B/C ratios given a rebate for the unit meeting the 

target efficiency. Because the rebate reduced the incremental cost, the unit receiving the rebate 

had a larger B/C ratio. Table 16.3.3 shows the effects of consumer rebates on B/C ratios for 

standard-size freezers. Each B/C ratio value for units with rebates represents a weighted averageh

of the values for the efficiency levels at or above the target level to which the rebate would 

apply.

Table 16.3.3 Benefit/Cost Ratios Without and With Rebates for Standard-Size 

Freezers

Upright 

Freezers Chest Freezers

B/C Ratio Without Rebate 5.4 7.6

Rebate Amount $43 $43

B/C Ratio With Rebate 8.9 Inf.

Calculated Market Barrier Curve Extremely 

High

Extremely 

High

Inf. = infinite B/C ratio, which occurs when the rebate pays the full incremental cost.

DOE used these B/C ratios, along with the penetration curves shown in Appendix 16-A, 

section 16-A.3.4, to estimate the percentage of consumers who would purchase standard-size 

freezers that meet the target efficiency level both with and without a rebate incentive. The curves

calculated by DOE to represent the market behavior for upright freezers and for chest freezers 

were close to the extremely high barriers penetration curve. 

For each product class, DOE next estimated the percent increase represented by the 

change in penetration rate shown on the penetration curve. It then added that percent increase to 

the market share of units that meet the target level in the base case to obtain the market share of 

units that meet the target level in the rebate case. Table 16.3.4 summarizes market shares of 

target-level standard-size freezers estimated for 2014. 

 

h The weighting factor is the 2014 base case market share of each of the corresponding efficiency levels. 
16-13

Table 16.3.4 Market Penetration in 2014 Without and With Rebates for Standard-Size 

Freezers

Upright 

Freezers

%

Chest 

Freezers

%

Base-Case Market Share of Units that 

Meet Target Levels 0.2 0.4

Market Share of Units that Meet 

Target Levels With Rebates 3.2 46.5

Increased Market Share of Units that 

Meet Target Level With Rebates 3.0 46.1

See Appendix 16-A, Table 16-A.4.1, for the annual increases in market shares for 

standard-size freezers meeting target efficiency levels under a rebate policy. DOE used the 

increased market shares attributable to the rebate policy as inputs to the NIA-RIA model. Section 

16.4 presents the resulting efficiency trends for the policy case of consumer rebates for standardsize freezers.

16.3.2.3 Compact Refrigeration Products

For compact refrigeration products, DOE estimated the effect of increasing the B/C ratio 

via a rebate that would pay part or all of the increased installed cost of a unit that met the target 

efficiency level compared to the cost of a unit meeting the baseline level. DOE based the rebate 

amounts on a sample of utility and agency rebate programs for compact refrigeration products. 

For compact refrigerators, DOE gathered data on 12 rebate programs provided by utilities 

or agencies in several States. (Appendix 16-A, sections 16-A.5.1 and 16-A5.2, identify the rebate 

programs.) To represent the rebate level for compact refrigerators, DOE used the simple average 

of the rebate amounts in these 12 programs. For compact freezers, the corresponding sample 

included only two rebate programs, whose simple average was higher than the average rebate for 

compact refrigerators; in contrast, the average rebate for standard-size freezers was lower than 

that for standard-size refrigerator-freezers. Rather than rely on such a small sample, DOE instead 

estimated the compact freezer rebate amount by multiplying the compact refrigerator amount 

($37) by the ratio of the standard-size freezer rebate amount to the standard-size refrigeratorfreezer rebate amount, resulting in an estimate of $30. DOE assumed that these rebate amounts 

would apply to models at all efficiency levels at or above the target level for each representative 

product class. For each of these efficiency levels, the rebate amount represented a certain percent 

of the increase in total installed cost.

DOE assumed that rebates would remain in effect until the market had been transformed; 

that is, the shift in market share of efficient units seen in the first year of the rebate program 

would be maintained throughout the forecast period (2014–2043). 

For compact refrigeration products, DOE first calculated B/C ratios without a rebate 

using the difference in lifetime operating costs and total installed costs between the unit meeting 

the target level and the baseline unit. It then calculated B/C ratios given a rebate for the unit 
16-14

meeting the target efficiency. Because the rebate reduced the incremental cost, the unit receiving 

the rebate had a larger B/C ratio. Tables 16.3.5 shows the effects of consumer rebates on B/C 

ratios for compact refrigeration products. Each B/C ratio value for units with rebates represents a 

weighted averageiof the values for the efficiency levels at or above the target level to which the 

rebate would apply.

Table 16.3.5 Benefit/Cost Ratios Without and With Rebates for Compact 

Refrigeration Products (PC 11)

Compact 

Refrigerators

(PC 11)

Compact 

Refrigerators

(PC13, PC14) 

Compact 

Freezers

B/C Ratio Without Rebate 10.5 12.6 13.0

Rebate Amount $38 $38 $31

B/C Ratio With Rebate Inf. Inf. Inf.

Calculated Market Barrier Curve Extremely High Extremely High Extremely High

Inf. = infinite B/C ratio, which occurs when the rebate pays the full incremental cost.

DOE used these B/C ratios, along with the penetration curves shown in Appendix 16-A, 

section 16-A.3.4, to estimate the percentage of consumers who would purchase compact 

refrigeration products that meet the target efficiency level both with and without a rebate 

incentive. The curves calculated by DOE to represent the market behavior for compact 

refrigerators and for compact freezers were close to the extremely high barriers penetration 

curve. 

For each product class, DOE next estimated the percent increase represented by the 

change in penetration rate shown on the penetration curve. It then added that percent increase to 

the market share of units that meet the target level in the base case to obtain the market share of 

units that meet the target level in the rebate case. Table 16.3.7 summarizes market shares of 

target-level compact refrigeration products estimated for 2014. 

 

i

The weighting factor is the 2014 base case market share of each of the corresponding efficiency levels. 
16-15

Table 16.3.6 Market Penetration in 2014 Without and With Rebates for Compact 

Refrigeration Products

Compact 

Refrigerators 

(PC11) %

Compact 

Refrigerators 

(PC13, PC14) 

%

Compact 

Freezers

%

Base-Case Market Share of Units that 

Meet Target Levels 1 0 4.6

Market Share of Units that Meet Target 

Levels With Rebates 44 41 45.2

Increased Market Share of Units that 

Meet Target Level With Rebates 43 41 40.6

See Appendix 16-A, Table 16-A.4.1, for the annual increases in market shares for 

compact refrigeration products meeting target efficiency levels under a rebate policy. DOE used 

the increased market shares attributable to the rebate policy as inputs to the NIA-RIA model. 

Section 16.4 presents the resulting efficiency trends for the policy case of consumer rebates for 

standard-size freezers.

16.3.2.4 Built-In Refrigeration Products

For built-in refrigeration products, DOE estimated the effect of increasing the B/C ratio 

via a rebate that would pay part or all of the increased installed cost of a unit meeting the target 

efficiency level compared to one meeting the baseline level. DOE based the rebate amounts on

the same sample of utility and agency rebate programs as it used for standard-size refrigeratorfreezers, shown in Appendix 16-A, section 16-A.5.1. Since this sample did not indicate separate 

rebates for built-in products, DOE assumed that the rebate amount would be the same as that 

calculated for standard-size refrigerator freezers. DOE assumed that this rebate amount would 

apply to models at all efficiency levels at or above the target level for each representative product 

class. For each of these efficiency levels, the rebate amount represented a certain percent of the 

increase in total installed cost. 

DOE assumed that rebates would remain in effect at the same levels throughout the 

forecast period (2014–2043). 

For built-in refrigeration products, DOE first calculated B/C ratios without a rebate using 

the difference in total installed costs and lifetime operating cost savings between the unit meeting 

the target level and the baseline unit. It then calculated B/C ratios given a rebate for the unit 

meeting the target efficiency level. Because the rebate reduced the incremental cost, the unit 

receiving the rebate had a larger B/C ratio. Table 16.3.8 shows the effects of consumer rebates 

on B/C ratios for built-in refrigeration products that meet target efficiency levels. Each B/C ratio 

value for units with rebates represents a weighted averagej

of the values for the efficiency levels 

at or above the target level to which the rebate would apply.

 

j

The weighting factor is the 2014 base case market share of each of the corresponding efficiency levels. 
16-16

Table 16.3.7 Benefit/Cost Ratios Without and With Rebates for Built-in Refrigeration 

Products (2009$)

Built-in All 

Refrigerators

Built-in 

BottomMount 

RefrigeratorFreezers

Built-in Sideby-Side 

RefrigeratorFreezers

Built-in 

Upright 

Freezers

B/C Ratio without Rebate 2.2 1.9 1.4 1.5

Rebate Amount $52 $52 $52 $43

B/C Ratio with Rebate 3.2 2.8 1.6 1.7

Calculated Market Barrier Curve

LowModerate No No-LowHigh - 

Ext. High

Inf. = infinite B/C ratio, which occurs when the rebate pays the full incremental cost.

DOE used these B/C ratios, along with the penetration curves shown in Appendix 16-A, 

section 16-A.3.4, to estimate the percentage of consumers who would purchase built-in 

refrigeration products that meet the target efficiency level both with and without a rebate 

incentive. The curve calculated by DOE to represent the market behavior for built-in top-mount 

refrigerator-freezers was close to the moderate barriers penetration curve. For built-in bottommount refrigerator-freezers and for built-in side-by-side refrigerator-freezers the curve was close 

to the no barriers penetration curve. For built-in side-by-side refrigerator-freezers the curve was 

between the no and low barriers penetration curves. For built-in upright freezers the curve was 

between the high barriers and extremely high barriers penetration curve.

For each product class, using the penetration curves, DOE estimated that a rebate policy

would result in a certain percent market share of products that meet the target efficiency level.

DOE estimated the percent market share increase represented by the change in penetration rate 

shown on the penetration curve. It then added that percent increase to the market share of units 

that meet the target level in the base case to obtain the market share of units that meet the target 

level in the rebate case. 

Table 16.3.9 summarizes market shares of target-level built-in refrigeration products 

estimated for 2014. 
16-17

Table 16.3.8 Market Penetrations in 2014 Without and With Rebates for Built-in 

Refrigeration Products

Built-in All 

Refrigerators

Built-in 

BottomMount 

Refrigerator

-Freezers

Built-in 

Side-by-Side 

Refrigerator

-Freezers

Built-in 

Upright 

Freezers

Base-Case Market Share of 

Units that Meet Target Levels 8 87 37 0.40

Market Share of Units that 

Meet Target Levels With 

Rebates 15 96 40 0.55

Increased Market Share of 

Units that Meet Target Level 

With Rebates 7 9 4 0.15

See Appendix 16-A, Table 16-A.4.1, for the annual increases in market shares for built-in 

refrigeration products meeting target efficiency levels under a rebate policy. DOE used these

increases in market shares as inputs to represent the policy case scenarios in its NIA-RIA model.

Section 16.4 presents the resulting efficiency trends for the policy case of consumer rebates for

built-in refrigerator-freezers.

16.3.3 Consumer Tax Credits

DOE estimated the effects of tax credits on consumer purchases based on its previous 

analysis of consumer participation in tax credits. DOE supported its approach using data from 

Oregon State’s tax credit program for energy efficient appliances. DOE also incorporated 

previous research that disaggregated the effect of rebates and tax credits into a direct price effect, 

which derives from the savings in purchase price, and an announcement effect, which is 

independent of the amount of the incentive.

11, 12 The announcement effect derives from the 

credibility that a technology receives from being included in an incentive program, as well as 

changes in product marketing and modifications in markup and pricing. DOE assumed that the 

rebate and consumer tax credit policies would encompass both direct price effects and 

announcement effects, and that half the increase in market penetration associated with either 

policy would be due to the direct price effect and half to the announcement effect.

In estimating the effects of a tax credit on purchases of consumer products that meet new 

efficiency standards, DOE assumed the amount of the tax credits for each product class would be 

the same as the corresponding rebate amounts discussed above. 

DOE estimated that fewer consumers would participate in a tax credit program than 

would take advantage of a rebate. Research has shown that the delay required for a consumer to 

receive a tax credit, plus the added time and cost in preparing the tax return, make a tax credit 

incentive less effective than a rebate received at the time of purchase. Based on previous 

analyses, DOE assumed that only 60 percent of the consumers who would take advantage of a 

rebate would take advantage of a tax credit.13
16-18

In preparing its assumptions, DOE also reviewed other tax credit programs that have been 

offered at both the Federal and State levels for energy efficient appliances.

The Energy Policy Act of 2005 (EPACT 2005) included Federal tax credits for 

consumers who purchase energy efficient equipment, including water heaters, furnaces, and 

furnace fans for new or existing homes.14 Those tax credits were in effect in 2006 and 2007, 

expired in 2008, and were reinstated for 2009–2010 by ARRA.1, 15 DOE reviewed Internal 

Revenue Service data on the numbers of taxpayers who claimed the tax credits during tax years 

2006 and 2007. DOE also reviewed data from an earlier Federal energy conservation tax credit 

program in place in the 1980s. However, DOE did not find data specific enough to refrigerators 

to warrant adjusting its analysis method for the Consumer Tax Credits policy case. Appendix 16-

A, section 16-A.6.1, contains more information on Federal consumer tax credits. 

DOE reviewed data on Oregon State’s tax credit program for standard-size refrigerators. 

However, the data series for this product exhibited too much annual variation, due to periodic 

updates in efficiency requirements and other program changes, to show a meaningful trend. 

DOE also reviewed its previous analysis on Oregon’s tax credits for clothes washers.16

DOE compared the market shares of ultra-high efficiency (UHE) residential clothes washers in 

Oregon, which offered both State tax credits and utility rebates, with those in Washington State, 

which offered only utility rebates during the same period. Based on this analysis, DOE estimated 

that in Oregon the impact of tax credits was 62 percent of the impact of rebates for UHE clothes 

washers having equivalent efficiency. This finding supports the original assumption that 

participation in a tax credit program would be about 60 percent of participation in a rebate 

program. Additional discussion of State tax credits for Oregon and other states is in Appendix 

16-A, section 16-A.6.3.

In summary, DOE identified no data on Federal or State consumer tax credits for 

refrigeration products to directly use in estimating the impacts of consumer tax credits for those 

products. As mentioned above, however, DOE used its analysis of Oregon data for residential 

clothes washers as support for its assumption that tax credits induce the participation of about 60 

percent as many consumers as rebates inspire. DOE used that percentage in its analysis of 

consumer tax credits for all refrigeration products.

DOE applied the assumed 60 percent participation described above to the penetration 

rates estimated for the rebate policy to estimate penetration rates attributable to consumer tax 

credits. In doing so, DOE incorporated the assumptions for consumer response to financial 

incentives from the penetration curves selected for each product class. 

Tables 16.3.10 through 16.3.13 summarize DOE’s assumptions for each refrigeration 

product group regarding the market penetration of units in 2014 that meet target efficiency levels 

given a consumer tax credit. 
16-19

Table 16.3.9 Market Penetrations in 2014 Attributable to Consumer Tax Credits for 

Standard-Size Refrigerator-Freezers

Top-Mount

RefrigeratorFreezers

BottomMount 

RefrigeratorFreezers % %

Side-by-Side 

RefrigeratorFreezers

Base-Case Market Share of Units that Meet 

Target Levels

%

0 68 0

Market Share of Units that Meet Target 

Levels With Consumer Tax Credits 11 76 17

Increased Market Share of Units that Meet 

Target Level With Consumer Tax Credits 11 8 17

Table 16.3.10 Market Penetrations in 2014 Attributable to Consumer Tax Credits for 

Standard-Size Freezers

Upright 

Freezers

%

Chest 

Freezers

%

Base-Case Market Share of Units that Meet 

Target Levels 0.2 0.4

Market Share of Units that Meet Target 

Levels With Consumer Tax Credits 2.0 28.1

Increased Market Share of Units that Meet 

Target Level With Consumer Tax Credits 1.8 27.7

Table 16.3.11 Market Penetrations in 2014 Attributable to Consumer Tax Credits for 

Compact Refrigeration Products

Compact 

Refrigerators

(PC11) %

Compact 

Refrigerators

(PC13, PC14) 

%

Compact 

Freezers

%

Base-Case Market Share of Units that Meet 

Target Levels 1 0 5

Market Share of Units that Meet Target 

Levels With Consumer Tax Credits 27 25 29

Increased Market Share of Units that Meet 

Target Level With Consumer Tax Credits 26 25 24
16-20

Table 16.3.12 Market Penetrations in 2014 Attributable to Consumer Tax Credits for 

Built-in Refrigeration Products

Built-in All 

Refrigerators

Built-in 

BottomMount 

Refrigerator

-Freezers

Built-in 

Side-by-Side 

Refrigerator

-Freezers

Built-in 

Upright 

Freezers

Base-Case Market Share of 

Units that Meet Target Levels 8 87 37 0.40

Market Share of Units that 

Meet Target Levels With 

Consumer Tax Credits 12 92 39 0.49

Increased Market Share of 

Units that Meet Target Level 

With Consumer Tax Credits 4 5 2 0.09

DOE assumed that this policy would transform the market permanently, so that the 

increase in market share seen in the first year of the program for refrigeration products would be 

maintained throughout the forecast period. See Appendix 16-A, Table 16-A.4.1, for the annual 

increases in market shares for refrigeration products that meet target efficiency levels. 

The increased market shares attributable to consumer tax credits shown in Tables 16.3.10

through 16.3.13 and 16-A.4.1 were used as inputs to the NIA-RIA model. Section 16.4 presents

the resulting efficiency trends for the policy case of consumer tax credits for refrigeration 

products that meet target efficiency levels.

16.3.4 Manufacturer Tax Credits 

To analyze the potential effects of a policy that offers tax credits to manufacturers that 

produce refrigeration products that meet target efficiency levels, DOE assumed that a 

manufacturer tax credit would lower the consumer’s purchase cost by an amount equivalent to 

that provided by the consumer rebates or tax credits described above. DOE further assumed that 

manufacturers would pass on some of their reduced costs to consumers, causing a direct price 

effect. DOE assumed that no announcement effect would occur, because the program would not 

be visible to consumers.k Because the direct price effect is approximately equivalent to the 

announcement effect.11 DOE estimated that a manufacturer tax credit would induce half the 

number of consumers assumed to take advantage of a consumer tax credit to purchase more 

efficient products. This assumed participation rate is equal to 30 percent of the number of 

consumers who would participate in a rebate program. 

 

k Note that this is a conservative assumption, since it is possible that manufacturers or utility/agency efficiency 

programs might promote the models for which manufacturers increase production due to the tax credits, which in 

turn might induce some announcement effect. However, DOE found no data on such programs on which to base an 

estimate of the magnitude of this possible announcement effect on consumer behavior.
16-21

DOE attempted to investigate manufacturer response to the Energy Efficient Appliance 

Credits for manufacturers mandated by EPACT 2005.17 Those manufacturer tax credits were in 

effect for models produced in 2006 and 2007 and reinstated for 2009 and 2010. DOE was unable 

to locate data from the Internal Revenue Service or other sources on manufacturer response to 

the Federal credits. Appendix 16-A, section 16-A.6.2, presents details on Federal manufacturer 

tax credits.

DOE applied the assumption of 30 percent participation to the penetration rates predicted 

for the rebate policy to estimate the effects of a manufacturer tax credit policy. In doing so, the 

Department incorporated the assumptions for consumer response to financial incentives from the 

penetration curves selected for each product class. 

Tables 16.3.14 through 16.3.17 summarize DOE’s assumptions for each refrigeration 

product group regarding the market penetration of units in 2014 meeting target efficiency levels 

given a manufacturer tax credit.

Table 16.3.13 Market Penetrations in 2014 Attributable to Manufacturer Tax Credits

for Standard-Size Refrigerator-Freezers

Top-Mount

RefrigeratorFreezers

BottomMount 

RefrigeratorFreezers % %

Side-by-Side 

RefrigeratorFreezers

Base-Case Market Share of Units that Meet 

Target Levels

%

0 68 0

Market Share of Units that Meet Target 

Levels With Manufacturer Tax Credits 5 72 8

Increased Market Share of Units that Meet 

Target Level With Manufacturer Tax Credits 5 4 8

Table 16.3.14 Market Penetrations in 2014 Attributable to Manufacturer Tax Credits

for Standard-Size Freezers

Upright 

Freezers

%

Chest 

Freezers

%

Base-Case Market Share of Units that Meet 

Target Levels 0.2 0.4

Market Share of Units that Meet Target 

Levels With Manufacturer Tax Credits 1.1 14.2

Increased Market Share of Units that Meet 

Target Level With Manufacturer Tax 

Credits 0.9 13.8
16-22

Table 16.3.15 Market Penetrations in 2014 Attributable to Manufacturer Tax Credits

for Compact Refrigeration Products

Compact 

Refrigerators

(PC11) %

Compact 

Refrigerators

(PC13, PC14) 

%

Compact 

Freezers

%

Base-Case Market Share of Units that Meet 

Target Levels 1 0 5

Market Share of Units that Meet Target 

Levels With Manufacturer Tax Credits 14 12 17

Increased Market Share of Units that Meet 

Target Level With Manufacturer Tax 

Credits 13 12 12

Table 16.3.16 Market Penetrations in 2014 Attributable to Manufacturer Tax Credits

for Built-in Refrigeration Products

Built-in All 

Refrigerators

Built-in 

BottomMount 

Refrigerator

-Freezers

Built-in 

Side-by-Side 

Refrigerator

-Freezers

Built-in 

Upright 

Freezers

Base-Case Market Share of 

Units that Meet Target Levels 8 87 37 0.40

Market Share of Units that 

Meet Target Levels With 

Manufacturer Tax Credits 10 90 38 0.44

Increased Market Share of 

Units that Meet Target Level 

With Manufacturer Tax 

Credits 2 3 1 0.04

DOE assumed that this policy would transform the market permanently, so that the 

increase in market share seen in the first year of the program for refrigeration products would be 

maintained throughout the forecast period. See Appendix 16-A, Table 16-A.4.1, for the annual 

increases in market shares for units that meet target efficiency levels. 

The increased market shares attributable to a manufacturer tax credit, shown in Tables

16.3.14 through 16.3.17 and 16-A.4.1 were used as inputs to the NIA-RIA model. Section 16.4 

presents the resulting efficiency trends for the policy case of manufacturer tax credits for 

refrigeration products.

16.3.5 Voluntary Energy Efficiency Targets 

For each product, DOE assumed that voluntary energy efficiency targets would be 

achieved as manufacturers gradually stopped producing units that operated below the target 
16-23

efficiency levels. DOE assumed that the impetus for phasing out production of low-efficiency 

units would be a program similar to the ENERGY STAR labeling program conducted by the 

Environmental Protection Agency (EPA) and DOE. The ENERGY STAR program specifies the 

minimum energy efficiencies that various products, including refrigeration products, must have 

to receive the ENERGY STAR label. ENERGY STAR encourages consumers to purchase

efficient products via marketing that promotes consumer label recognition, various incentive 

programs that adopt the ENERGY STAR specifications, and manufacturers’ promotion of their 

qualifying appliances. ENERGY STAR projects market penetration of compliant appliances and 

estimates the percentage of sales of compliant appliances that are attributable to the ENERGY 

STAR program. 

Researchers have analyzed the ENERGY STAR program’s effects on sales of several 

consumer products. Program efforts generally involve a combination of information 

dissemination and utility or agency rebates. The analyses have been based on State-specific data 

on percentages of shipments of various appliances that meet ENERGY STAR specifications. The 

analyses generally have concluded that the market penetration of ENERGY STAR-qualifying 

appliances is higher in regions or States where ancillary promotional programs have been 

active.18, 19, 20

16.3.5.1 Standard-Size Refrigerator-Freezers

To model the effects of a voluntary energy efficiency policy for standard-size 

refrigerator-freezers, DOE assumed that such a program would be an expansion of existing

ENERGY STAR efforts for this product. The ENERGY STAR program developed projections 

for 1996–2025 of increased market penetration attributable to its program for standard-size 

refrigerators.

21 DOE estimated that an expanded ENERGY STAR program would increase the 

annual market share of efficient units by 50 percent more than the increase that was attributable 

to the existing ENERGY STAR program for refrigerators, which began in 1996. Using 

ENERGY STAR’s forecast for 1996 – 2025, DOE first performed a linear regression to smooth 

out fluctuations due to periodic program specification updates. From this adjusted forecast, DOE

calculated the annual percent increases in market share for refrigerators represented by an

additional 50 percent market share that would result from an enhanced program. DOE added 

those percent increases to the market shares of standard-size refrigerator-freezers that meet the 

target level in the RIA base case, l

starting in 2014, to obtain the annual market shares of units 

meeting the target efficiency level in the voluntary efficiency targets policy case. DOE assumed

that the programs resulting from the expanded voluntary efficiency targets policy would produce 

the projected increases in market share shown in Appendix 16-A, Table 16-A.4.2. 

DOE estimated that the programs developed in support of the voluntary efficiency targets 

policy would increase market shares of efficient units by the percentages shown in Appendix 16-

A, Table 16-A.4.2. Section 16.4 presents the resulting efficiency trends for the policy case of 

 

l

The base case projections for refrigeration products incorporate assumptions on the percentage of qualifying 

shipments under the current ENERGY STAR program.
16-24

voluntary energy efficiency targets for standard-size refrigerator-freezers that meet target 

efficiency levels.

16.3.5.2 Standard-Size Freezers

While there is an ENERGY STAR program for standard-size freezers that began in 2003, 

DOE was unable to obtain a projection of the program impacts for this product. DOE instead 

based its estimates of market penetration for standard-size freezers on the ENERGY STAR 

projections for standard-size refrigerators of market penetration attributable to its program for 

2003–2025.21 DOE estimated that the percentage of market shares attributable to the existing 

ENERGY STAR program for standard-size freezers would be half of the percentages attributable 

to standard-size refrigerator-freezers, based on the relative size of the market shares for these two 

products in its shipments analysis for the national impact analysis. DOE then estimated that an 

expanded ENERGY STAR program for standard-size freezers would increase the annual market 

share of efficient units by 50 percent more than the increase attributable to the existing ENERGY 

STAR program, starting in 2003, in the projection that was calculated as described above. It 

assumed that an enhanced program would produce the same patterns of annual increases in 

market penetration beginning in 2014; from 2037 – 2043 the market penetration is extrapolated 

as equivalent to the penetration in 2036. From this forecast DOE calculated the annual percent 

increases in market share for units represented by the shipments attributed to ENERGY STAR. 

DOE added those percent increases to the market shares of standard-size freezers that met the 

target levels in the RIA base case, starting in 2014, to obtain the annual market shares of units 

meeting the target efficiency level in the voluntary efficiency targets case. Appendix 16-A, Table 

16-A.4.2, shows the annual projected increases in market shares of standard-size freezers that 

would result from a voluntary energy efficiency policy. Section 16.4 presents the resulting 

efficiency trends for the policy case of voluntary energy efficiency targets for standard-size 

freezers.

16.3.5.3 Compact Refrigeration Products 

DOE did not analyze the potential effects of voluntary energy efficiency targets for 

compact refrigeration products because it was unable to obtain an ENERGY STAR forecast for 

these products.

16.3.5.4 Built-in Refrigeration Products

DOE did not analyze the potential effects of voluntary energy efficiency targets on builtin refrigeration products because it was unable to obtain an ENERGY STAR forecast for these

products.
16-25

16.3.6 Early Replacement

The non-regulatory policy of early replacement refers to a program to replace residential 

appliances before the ends of their useful lives. The purpose of such a policy is to replace old, 

inefficient units with higher efficiency units. The economic feasibility of early replacement

depends on the vintage of the unit being replaced, the installed cost of the new unit, and the 

energy cost savings.

DOE examined several reports on field experience with early replacement programs to 

inform its analysis of the policy. The most recent set of reports evaluated residential appliance 

recycling programs conducted by California utilities that targeted refrigerators and 

freezers.

22,23,24 These studies evaluated data from programs carried out by Southern California 

Edison, Pacific Gas and Electric, and San Diego Gas and Electric in 2004 - 2008. DOE analyzed 

the number of units collected by these programs and compared them to the eligible population of 

refrigerators or freezers in each utility service territory to estimate the percentage reached by 

each program. For refrigerators, the percentages for the three utilities ranged from 7.1 percent to 

1.3 percent, with an average of 4.2 percent. For freezers, the percentages for the three utilities 

ranged from 4.1 percent to 0.6 percent, with an average of 2.8 percent. 

Another report detailed the Connecticut Retirement Program (ARP), which was

conducted June through December 2004 by Nexus Market Research, Inc., and RLW Analytics, 

Inc., for Northeast Utilities–Connecticut Light and Power and the United Illuminating 

Company’s State programs.

25 The purpose of the ARP was to help Connecticut utility customers 

overcome barriers to recycling room air conditioners (RACs), secondary refrigerators, and 

freezers. The program picked up used appliances at customers’ homes or at turn-in events, paid 

participants to retire their units, and educated customers about the costs of operating older 

appliances. In addition, the program provided consumers with financial incentives to replace 

inefficient RACs with ENERGY STAR-qualified units. DOE considered the RAC program to 

most closely resemble the early replacement policy scenario for the four refrigeration products

considered herein, because consumers replaced primary units rather than retiring second units. 

Nexus/RLW used program data and surveys to estimate the number of RACs retired by ARP 

participants, the percentage of retired units that were replaced with an ENERGY STAR model, 

and the number of RACs replaced by non-participants during the program. According to the 

Nexus/RLW analysis, about 7 percent of all RACs retired during the program were retired 

through the ARP, and 63 percent of those were replaced with ENERGY STAR models. Thus the

program resulted directly in about 4 percent of total eligible RAC consumers deciding on early 

replacement of inefficient units. 

In 2006, GDS Associates, Inc performed a study of the potentials for electric energy 

efficiency for the State of Vermont.26 The report estimated the potentials for reducing electricity 

use and peak demand through energy efficiency and fuel conversion measures. The study took an 

aggressive, multi-program approach, one aspect of which was early replacement of 

appliances. GDS considered that under the program residential appliances, including RACs, 

would be replaced during four years (2006–2009). GDS estimated achievable market 

penetrations assuming that consumers would receive a financial incentive equal to 50 percent of 
16-26

the incremental cost of each measure. GDS assumed an 80 percent penetration limit. For early 

replacement of RACs, GDS estimated a maximum achievable participation of 5 percent of 

eligible single-family or multi-family homes in the year before the program began (2005).

DOE also reviewed an earlier study it conducted in the 1990s, under Energy Policy Act 

of 1992 (EPACT 1992), which analyzed the feasibility of a Federal program to promote early 

replacement of appliances.27 The study identified policy options for early replacement that 

included a direct national program; replacement of Federally-owned appliances; and promotion 

through equipment manufacturers, consumer incentives, incentives to utilities, and building 

regulations.m

While the SEEARP rebate program has been an early replacement program, the program 

was still in process during the preparation of this TSD. The amount of money available for 

rebates for each State, apportioned between several appliances per State, may not have been 

adequate to demonstrate the full market potential of an early replacement program targeted at 

one appliance. 

For this RIA analysis, DOE analyzed a program that would target installed units having

efficiency levels that are lower than target levels and encourage their early replacement with 

products that perform at target levels. For each product, DOE modeled the effects of the early 

replacement policy by increasing by a certain percentage per year the retirement rate of units that 

were in the stock in the first year of the analysis period (2014). For standard-sized and compact 

refrigerators DOE used the 4.2 percent rate from the California studies, because they were based 

on the recent actual program experience, noting that this rate was bounded by the Connecticut 

and the Vermont analysis results. For standard-sized and compact freezers, DOE assumed that 

the accelerated replacement rate would by 2.8 percent, based on the recent California experience 

with freezer replacement programs. 

DOE assumed that the early replacement program would continue until it had facilitated 

the replacement of all eligible residential refrigerators, refrigerator-freezers, and freezers in the 

stock in the year the program began (2014). Shipments of new units in 2014 and beyond were 

not affected by the program, but remained at base-case efficiency levels. After the stock of 

inefficient units was completely replaced, the policy would produce no additional impacts. 

An early replacement policy would create a fairly immediate jump in shipments of 

products that meet target efficiency levels relative to the base case, as shown in Figures 16.3.4

through 16.3.7. High-efficiency units would be brought quickly into the stock, leading to an 

immediate gain in the market share of efficient units compared to the base case. As opposed to 

the policy cases discussed previously, however, an early replacement policy results in market 

 m The analysis concluded that, although cost-effective opportunities for early replacement exist, a widespread 

Federal program was not justified economically. Because early retirement means that a unit may be replaced by an 

appliance less efficient than the eventual replacement would have been, energy savings would be less than 

anticipated. Early replacement programs also could increase long-term sales volatility by encouraging a temporary 

increase in production, followed by a lull in demand. Early replacement could be economical in localities subject to

high energy costs or environmental constraints; when replacement appliances are much more efficient than existing 

stock; or when a major technology breakthrough has occurred, creating the need for a ready market.
16-27

shares of efficient units returning to base-case percentages as the eligible market is depleted. In 

addition, as the figures illustrate, because units removed early from the stock would have been 

replaced later (at the ends of their useful lives) without the program, the number of shipments in 

later years drops slightly below the base-case shipments forecast for a period of years. The 

shipments shown in Figures 16.3.4 through 16.3.7 represent units that replace existing units 

(replacement shipments). Section 16.4 presents the resulting efficiency trends for the policy case 

of early replacement for refrigeration products. (Note that built-in refrigeration products were 

analyzed together with standard-size refrigerator-freezers and standard-size freezers for this 

policy, so separate shipment graphs are not available for built-ins.)

Appendix 16.A, Table 16-A.4.2, shows the projected market shares due to the early 

replacement policy.

Figure 16.3.4 Estimated Replacement Shipments of Standard-Size 

Refrigerator-Freezers With and Without an Early Replacement 

Program

0.0

2.0

4.0

6.0

8.0

10.0

12.0

2010 2015 2020 2025 2030 2035 2040

Millions

Shipments - Early Replacement vs Base Case

Base Case

Early Replacement
16-28

Figure 16.3.5 Estimated Replacement Shipments of Standard-Size Freezers 

With and Without an Early Replacement Program

0.8

1.0

1.2

1.4

1.6

1.8

2.0

2010 2015 2020 2025 2030 2035 2040

Millions

Shipments - Early Replacement vs Base Case

Base Case

Early Replacement

0.00

0.01

0.01

0.02

0.02

0.03

2010 2015 2020 2025 2030 2035 2040

Millions

Shipments - Early Replacement vs Base Case

Base Case

Early Replacement
16-29

Figure 16.3.6 Estimated Replacement Shipments of Compact Refrigerators 

With and Without an Early Replacement Program

Figure 16.3.7 Estimated Replacement Shipments of Compact Freezers With 

and Without an Early Replacement Program

16.3.7 Bulk Government Purchases 

DOE assumed that a policy requiring bulk government purchases would lead to Federal, 

State, and local governments purchasing products that meet target efficiency levels. Combining 

the market demands of multiple public sectors also would provide a market signal to 

manufacturers and vendors that some of their largest customers seek products that meet an 

efficiency target at favorable prices. Such a program also could induce “market pull,” whereby 

manufacturers and vendors would achieve economies of scale for high-efficiency products.

Most of the previous bulk government purchase (procurement) initiatives at the Federal, 

State, and municipal levels have not tracked data on number of purchases or degree of 

compliance with procurement specifications. In many cases, procurement programs are 

decentralized, being part of larger State or regional initiatives. DOE based its assumptions 

regarding the effects of a policy calling for bulk government purchases on studies the Federal 

Energy Management Program (FEMP) performed regarding the savings potential of its 

procurement specifications for appliances and other equipment. FEMP, however, does not track 

purchasing data, because of the range of complex the purchasing systems, number of vendors, 

etc. States, counties, and municipalities have demonstrated increasing interest and activity in 

0.20

0.25

0.30

0.35

0.40

0.45

2010 2015 2020 2025 2030 2035 2040

Millions

Shipments - Early Replacement vs Base Case

Base Case

Early Replacement
16-30

“green purchasing." Although many of the programs target office equipment, the growing 

infrastructure for developing and applying efficient purchasing specifications indicates that bulk 

government purchase programs are feasible.28, 29

DOE assumed that government agencies, such as the Department of Housing and Urban 

Development, would administer a bulk purchasing program for refrigeration products. The bulk 

purchasing policy also could be incorporated at the Federal level into the FEMP program, which 

has established procurement guidelines. Federal construction requirements include the FEMP 

guidelines for installing or replacing equipment. The FEMP program currently has procurement 

guidelines in place for standard-size and compact refrigerators and for standard-size and compact 

freezers.

30

DOE also reviewed its own previous research on the potential for market transformation 

through bulk government purchases. Its major study analyzed several scenarios based on the 

assumption that 20 percent of Federal equipment purchases in the year 2000 already incorporated 

energy efficiency requirements based on FEMP guidelines. One scenario in the DOE report 

showed energy efficient Federal purchasing ramping up during 10 years from 20 percent to 80 

percent of all Federal purchases.31 

16.3.7.1 Standard-Size Refrigerator-Freezers

Based on its study described above, DOE estimated that a bulk government purchase

program instituted within a 10-year period would result in 80 percent of government-purchased 

standard-size refrigerator-freezers meeting target efficiency levels. 

DOE assumed that bulk government purchases would affect a subset of housing units for 

which government agencies purchased or influenced the purchase of standard-size refrigeratorfreezers. This subset would consist primarily of public housing and housing on military bases. 

DOE defined this subset based on publicly owned housing identified in the American Housing 

Survey (AHS) for 2009, which was 1.8 million households, or about 1.4 percent of all U.S. 

households.

32 (The AHS reports 130.0 million U.S. households.37

) According to the 2005

Residential Energy Consumption Survey (RECS 2005), 97.5 percent of publicly owned 

households had refrigerators.

34 DOE therefore estimated that 1.4 percent of U.S. housing units 

represent publicly owned households using standard-size refrigerator-freezers, which constitutes

the populations to which this policy would apply.

Based on the above percentages, DOE estimated that, by the end of the first year of the 

bulk government purchase policy (2014), an additional 0.1 percent of shipments of governmentpurchased standard-size refrigerator-freezers beyond the base case would meet target efficiency 

levels. DOE estimated that by 2024 bulk government purchasing programs would result in 80 

percent of the standard-size refrigerator market for publicly owned housing meeting target levels. 

DOE modeled the bulk government purchase program assuming that the market share for each 

product achieved in 2024 would be maintained throughout the rest of the forecast period. Section 

16.4 presents the resulting efficiency trends for the policy case of bulk government purchase of
16-31

standard-size refrigerator-freezers. Appendix 16.A, Table 16-A.4.2, shows the projected market 

shares due to the bulk government purchases policy.

16.3.7.2 Standard-Size Freezers

DOE did not analyze the potential effects of bulk government purchases of standard-size 

freezers, because the market share of those products in publicly owned housing is small. 

According to RECS 2005, only 6.4 percent of publicly owned housing units use standard-size 

freezers.

16.3.7.3 Compact Refrigeration Products 

DOE analyzed the market for compact refrigeration products and determined that 

compact refrigerators are sold to the residential, commercial lodging, and commercial “other” 

building types. DOE did not analyze the potential impacts of bulk government purchases of 

compact freezers, because it assumed that the penetration of this product in publicly owned 

buildings was very small. RECS 2005 reports that the percentage of compact freezers in use in 

publicly owned housing units is very low and DOE lacked data to estimate their percentages in 

publicly owned commercial buildings.

Based on its study described above, DOE estimated that a bulk government purchase

program instituted within a 10-year period eventually would result in 80 percent of governmentpurchased compact refrigerators meeting target efficiency levels. 

For the residential sector, DOE assumed that bulk government purchases would affect a 

subset of housing units for which government agencies purchased or influenced the purchase of 

compact refrigerators. DOE defined this subset based on publicly owned housing identified in 

the American Housing Survey (AHS) for 2009, which was 1.8 million households, or about 1.4 

percent of all U.S. households.

32 (The AHS reports 130.0 million U.S. households.33

) According 

to the 2005 Residential Energy Consumption Survey (RECS 2005), 2.6 percent of publicly 

owned households used compact refrigerators.

34 DOE therefore estimated that 0.04 percent of 

U.S. housing units represent publicly owned households using compact refrigerators, to which 

this policy would apply.

For the commercial sector, DOE assumed that bulk government purchases would affect a 

subset of buildings for which government agencies purchased or influenced the purchase of 

compact refrigerators. DOE defined this subset based on publicly owned buildings identified in 

the 2003 Commercial Buildings Energy Consumption Survey.

35 DOE assumed that compact 

refrigerators were used in lodging (including hotels, motels, and dormitories) and in “other 

commercial” building types, such as offices. According to CBECS, 0.3 percent of lodging 

buildings’ floor space and 24 percent of other commercial buildings’ floor space was publicly 

owned. From CBECS, 39 percent of publicly owned lodging building floor space and 63 percent 

of publicly owned other commercial building floor space had compact refrigerators. DOE 

therefore estimated that 0.1 percent of U.S. lodging floor space and 15 percent of U.S. other 
16-32

commercial building floor space represent publicly owned building floor space using compact 

refrigerators, to which this policy would apply.

DOE further calculated that of the 2014 building stock with compact refrigerators, 29 

percent were in the residential sector, 18 percent in commercial lodging and 54 percent in other 

commercial buildings. Using stock as a proxy for shipments, and the public building percentages 

and saturations reported above, DOE estimated that 0.7 percent of shipments of compact 

refrigerators beyond the base case would meet target efficiency levels in the first year of the bulk 

government purchase policy (2014) for each product class. DOE estimated that by 2024 bulk 

government purchasing programs would result in 80 percent of the compact refrigerator market 

for publicly owned buildings meeting target levels. DOE modeled the bulk government purchase 

program assuming that the market share for each product achieved in 2024 would be maintained 

throughout the rest of the forecast period. Section 16.4 presents the resulting efficiency trends for 

the policy case of bulk government purchase of compact refrigerators. Appendix 16.A, Table 16-

A.4.2, shows the projected market shares due to the bulk government purchases policy.

16.3.7.4 Built-in Refrigeration Products

DOE did not analyze the potential impacts of bulk government purchases of built-inrefrigeration products, because those products are not used in publicly owned housing. RECS 

2005 does not report any built-in-refrigeration products in use in publicly owned housing units.

16.4 IMPACTS OF NON-REGULATORY ALTERNATIVES 

Figures 16.4.1 through 16.4.4 show the effects of each of the non-regulatory policy cases 

on market shares of units meeting the target level for standard-size refrigerator-freezers, 

standard-size freezers, compact refrigeration products and built-in refrigeration products, 

respectively. 

Figure 16.4.1 shows the effects of each non-regulatory policy on market penetration for 

standard-size refrigerator-freezers. Note that the market share of products that meet the target 

level is forecasted to increase over time in the base case (i.e., the case with neither standards nor 

non-regulatory policies). Relative to the base case, every policy case increases the market share 

of products that meet the target level. As shown in Figure 16.4.1, consumer rebates are most 

effective in increasing the market share of standard-size refrigerators that meet the target level,

while early replacement is least effective. Recall that the standards (not shown in Figure 16.4.1) 

would result in a 100 percent market penetration of products that meet target efficiency levels.
16-33

Figure 16.4.1 Market Penetration of Standard-Size Refrigerator-Freezers 

Meeting Target Level in Policy Cases

0%

5%

10%

15%

20%

25%

30%

35%

40%

201420152016201720182019202020212022202320242025202620272028202920302031203220332034203520362037203820392040204120422043

Base Case Rebate Cons Tax Cred

Manf Tax Cred Vol Eff Target Early Repl

Bulk Purch
16-34

Figure 16.4.2 shows the effects of each non-regulatory policy on market penetration for

standard-size freezers. The market share of products that meet the target level is forecasted to 

increase over time in the base case. Relative to the base case, all policy cases increase the market 

share of standard-size freezers that meet the target level, with consumer rebates being the most 

effective and early replacement the least effective of the policy cases analyzed. Recall that the 

proposed standards (not shown in Figure 16.4.2) would result in a 100 percent market 

penetration of products that meet the target efficiency level.

Figure 16.4.2 Market Penetration of Standard-Size Freezers Meeting Target 

Level in Policy Cases 

0%

5%

10%

15%

20%

25%

30%

201420152016201720182019202020212022202320242025202620272028202920302031203220332034203520362037203820392040204120422043

Base Case Rebate Cons Tax Credit

Manf Tax Credit Vol Eff Target Early Repl
16-35

Figure 16.4.3 shows the effects of each non-regulatory policy on the market penetration 

for compact refrigeration products. In the base case, the market share of products that meet the 

target level is forecasted to be constant over time. Relative to the base case, all policy cases 

increase the market share of compact refrigeration products that meet target efficiency levels, 

with consumer rebates being the most effective throughout the forecast period and early 

replacement the least effective. Recall that the proposed standards (not shown in Figure 16.4.3) 

would result in a 100 percent market penetration of products that meet the target efficiency level.

Figure 16.4.3 Market Penetration of Compact Refrigeration Products Meeting 

Target Level in Policy Cases

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

50%

201420152016201720182019202020212022202320242025202620272028202920302031203220332034203520362037203820392040204120422043

Base Case Rebate Cons Tax Credit

Manf Tax Credit Early Repl Bulk Purch
16-36

Figure 16.4.4 shows the effects of each non-regulatory policy on the market penetration 

for built-in refrigeration products. In the base case, the market share of products that meet the 

target level is forecasted to be constant over time. Relative to the base case, the non-regulatory 

policy cases increase the market share of build-in refrigeration products that meet the target

efficiency level. Consumer rebates are the most effective policy throughout the forecast period, 

and early replacement is the least effective. Recall that the proposed standards (not shown in 

Figure 16.4.4) would result in a 100 percent market penetration of products that meet the target 

efficiency level.

Figure 16.4.4 Market Penetration of Built-in Refrigeration Products Meeting 

Target Level in Policy Cases

16.5 SUMMARY OF RESULTS FOR NON-REGULATORY ALTERNATIVES 

Tables 16.5.1 through 16.5.4 show the national energy savings and net present value 

(NPV) for each of the six non-regulatory policies analyzed in detail for residential refrigerators, 

refrigerator-freezers, and freezers, where the target level for each policy equals the efficiency

level in the corresponding proposed standard. Table 16.5.5 shows the results for all refrigeration 

products together. 

The cases in which no regulatory action is taken with regard to residential refrigerators, 

refrigerator-freezers, and freezers constitute the base cases (or "No New Regulatory Action" 

scenarios), in which energy savings and NPV zero by definition. For comparison, the tables 

include the impacts of the proposed standards. Energy savings are given in quadrillion British 

thermal units (quads). The NPVs shown in Tables 16.5.1 through 16.5.5 are based on two 

discount rates, 7 percent and 3 percent. Negative NPVs are shown in parentheses.

42%

44%

46%

48%

50%

52%

54%

56%

201420152016201720182019202020212022202320242025202620272028202920302031203220332034203520362037203820392040204120422043

Base Case Rebate Cons Tax Cred

Manf Tax Cred Early Repl
16-37

Table 16.5.1 Impacts of Non-Regulatory Alternatives for Standard-Size RefrigeratorFreezers that Meet the Proposed Standard (TSL 3) 

Policy Alternative

Primary Energy

Savings

Net Present Value*

quads

7% discount 

rate

billion 2009$

3% discount 

rate

Consumer Rebates 0.71 0.30 2.81

Consumer Tax Credits 0.43 0.20 1.75

Manufacturer Tax Credits 0.22 0.10 0.88

Voluntary Energy Efficiency Targets 0.33 0.07 1.23

Early Replacement 0.001 0.0001 0.002

Bulk Government Purchases 0.03 0.01 0.10

Proposed Standards 3.05 0.41 10.40

* For products shipped in 2014─ 2043

Table 16.5.2 Impacts of Non-Regulatory Alternatives for Standard-Size Freezers that 

Meet the Proposed Standard (TSL 2)

Policy Alternative

Primary Energy

Savings

Net Present Value*

quads

7% discount 

rate

billion 2009$

3% discount 

rate

Consumer Rebates 0.26 0.05 1.05

Consumer Tax Credits 0.16 0.03 0.63

Manufacturer Tax Credits 0.08 0.01 0.32

Voluntary Energy Efficiency Targets 0.07 0.14 0.52

Early Replacement 0.0001 0.0002 0.0004

Bulk Government Purchases†

Proposed Standards 1.01 2.12 7.78

* For products shipped in 2014─ 2043

† DOE did not evaluate the bulk government purchase policy for standard-size freezers because the market share 

associated with publicly owned housing is minimal.
16-38

Table 16.5.3 Impacts of Non-Regulatory Alternatives for Compact Refrigeration 

Products that Meet the Proposed Standard (TSL 2)

Policy Alternative

Primary Energy

Savings

Net Present Value*

quads

7% discount 

rate

billion 2009$

3% discount 

rate

Consumer Rebates 0.19 0.13 0.45

Consumer Tax Credits 0.12 0.08 0.28

Manufacturer Tax Credits 0.06 0.04 0.14

Voluntary Energy Efficiency Targets†

Early Replacement 0.00002 0.00003 0.00006

Bulk Government Purchases 0.02 0.02 0.06

Proposed Standards 0.37 0.25 0.86

* For products shipped in 2014─ 2043

† DOE did not evaluate the voluntary energy efficiency target policy for compact refrigeration products because it 

had no market data on which to base an analysis.

Table 16.5.4 Impacts of Non-Regulatory Alternatives for Built-in Refrigeration 

Products that Meet the Proposed Standard (TSL 3)

Policy Alternative

Primary Energy

Savings

Net Present Value*

quads

7% discount 

rate

billion 2009$

3% discount 

rate

Consumer Rebates 0.005 -0.03 -0.036

Consumer Tax Credits 0.003 -0.02 -0.021

Manufacturer Tax Credits 0.002 -0.01 -0.011

Voluntary Energy Efficiency Targets

Early Replacement 0.00001 -0.000051 -0.000048

Bulk Government Purchases†

Proposed Standards 0.053 -0.33 -0.45

* For products shipped in 2014─ 2043

† DOE did not evaluate the bulk government purchase alternative for built-in refrigeration products because the

market share associated with publicly owned housing is minimal.
16-39

Table 16.5.5 Summary of Impacts of Non-Regulatory Alternatives for All 

Refrigeration Products that Meet the Proposed Standards

Policy Alternative

Primary Energy

Savings

Net Present Value*

quads

7% discount 

rate

billion 2009$

3% discount 

rate

Consumer Rebates 1.162 0.444 4.266

Consumer Tax Credits 0.709 0.288 2.640

Manufacturer Tax Credits 0.356 0.145 1.325

Voluntary Energy Efficiency Targets 0.407 0.186 1.770

Early Replacement 0.001 0.000 0.002

Bulk Government Purchases 0.048 0.021 0.155

Proposed Standards 4.657 2.261 18.905

* For products shipped in 2014─ 2043

16.6 SUPER-EFFICIENT VOLUNTARY TARGETS

In addition to the above policy alternatives, DOE evaluated a policy where a new, twotiered voluntary efficiency target program was implemented in addition to the proposed 

standards. The voluntary efficiency targets would feature speculative “super-efficient” products 

at two efficiency levels (designated Tier 1 and Tier 2) above the current max-tech levels. The 

program would target consumers in the highest electricity price regions of the country, to make 

the products maximally cost-effective. For the purpose of evaluating the program, only standardsized refrigerator-freezers were considered. Table 16.6.1 shows the targeted efficiency levels and 

assumed market shares of shipments in 2014 and in 2019 and beyond, as well as the assumed 

level of electricity prices relative to the national average.36, 37
16-40

Table 16.6.1 Super-efficient Voluntary Targets Program Parameters for StandardSize Refrigerator-Freezers

Product Class

Top-Mount 

RefrigeratorFreezers*

Bottom-Mount 

RefrigeratorFreezers**

Side-by-Side 

RefrigeratorFreezers†

Efficiency Level (% below 

baseline)

Proposed Standards (TSL 3) 25% 20% 25%

Super-efficient Tier 1 35% 35% 35%

Super-efficient Tier 2 45% 45% 41%

Market share of shipments

2014

Super-efficient Tier 1 4% 4% 4%

Super-efficient Tier 2 2% 2% 2%

2019+

Super-efficient Tier 1 20% 20% 20%

Super-efficient Tier 2 10% 10% 10%

Relative electricity price (% of 

national average)

Super-efficient Tier 1 120% 120% 120%

Super-efficient Tier 2 150% 150% 150%

* Includes product classes 1, 1A, 2, 3A, 3I and 6 as well as product class 3

** Includes product classes 5A and 5I as well as product class 5

† Includes product classes 4 and 4I as well as product class 7

Because the products modeled under this super-efficient voluntary targets program rely 

on advanced technology, DOE adopted a learning model approach whereby the cost of the 

advanced technology (“high-tech”) components decreases as a function of cumulative 

production of these products, but the mature technology (“low-tech”) components remain 

constant over time:

∆Ctotal = ∆Chigh-tech (declining) + ∆Clow-tech (constant)

∆Chigh-tech = ∆Chigh-tech,0 • (Q/Q0)

b

Where:

∆Ctotal = Total incremental cost;

∆Chigh-tech = High-tech incremental cost;

∆Clow-tech = Low-tech incremental cost (at proposed standard level);
16-41

∆Chigh-tech,0 = High-tech incremental cost in 2014;

Q = Cumulative production of Tier 1 + Tier 2 products since 2014;

Q0 = Production of Tier 1 + Tier 2 products in 2014;

b = Learning rate coefficient (<0), equal to ln(PR)/ln(2), where PR = progress ratio = 

85%.

Table 16.6.2 shows the total incremental manufacturer selling price of super-efficient 

products in selected model years.

Table 16.6.2 Super-efficient Voluntary Targets Program Incremental Manufacturer 

Selling Price for Standard-Size Refrigerator-Freezers

Product Class

Incremental Manufacturer Selling 

Price (MSP)

Top-Mount 

RefrigeratorFreezers*

BottomMount 

Refrigerator

-Freezers**

Side-by-Side 

RefrigeratorFreezers†

Proposed Standards (TSL 3) (constant) $106 $37 $94

Super-efficient Tier 1

2014 $160 $166 $195

2019 $119 $125 $124

2029+ $106 $113 $102

Super-efficient Tier 2

2014 $330 $367 $328

2019 $204 $224 $190

2029+ $166 $112 $149

* Includes product classes 1, 1A, 2, 3A, 3I and 6 as well as product class 3

** Includes product classes 5A and 5I as well as product class 5

† Includes product classes 4 and 4I as well as product class 7

Additional savings from the super-efficient voluntary targets program in addition to the 

proposed standards (TSL 3) are shown in Table 16.6.3. Overall, DOE estimates that an 

additional 1.68 quads of energy savings and an additional NPV of consumer benefit of $7.66 

billion (at 7 percent discount rate) would be realized under this program beyond the savings 

from the proposed standards.

Table 16.6.3 Super-efficient Voluntary Targets Program: Additional Savings Relative 

to Proposed Standards for Standard-Size Refrigerator-Freezers [changes 

made to this table]

Product Class
16-42

Top-Mount 

Refrigerator

-Freezers

BottomMount 

RefrigeratorFreezers

Side-by-Side 

Refrigerator

-Freezers

All StandardSized

RefrigeratorFreezers*

Energy Savings (Cumulative 

through 2043) (quads)

0.92 0.27 0.49 1.68

Discounted Incremental 

Equipment Cost (billion 2009$)†

1.83 1.64 -1.74 1.73

Discounted Operating Cost 

Savings (billion 2009$)†

5.33 1.27 2.80 9.40

Net Present Value (billion 2009$)† 3.49 -0.37 4.54 7.66

* Includes product classes 1, 1A, 2, 3, 3A, 3I, 4, 4I, 5, 5A, 5I , 6 as well as product class 7

† Using 7-percent discount rate
16-43

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(Customer count data by utility)
4-A-i

APPENDIX 4-A. INVESTIGATION OF VIP SUPPLY

TABLE OF CONTENTS

4-A.1 INTRODUCTION .................................................................................................4-A-1

4-A.2 VIP DEMAND.......................................................................................................4-A-1

4-A.3 ABILITY OF VIP SUPPLIERS TO MEET DEMAND .......................................4-A-4

LIST OF TABLES

Table 4-A-1: U.S. Demand at Proposed Standard Levels .......................................................4-A-2

Table 4-A-2: Current and Projected VIP Demand...................................................................4-A-3

Table 4-A-3: New Manufacturing Facility Ramp-Up Time ....................................................4-A-5
4-A-1

APPENDIX 4-A. INVESTIGATION OF VIP SUPPLY

4-A.1 INTRODUCTION

This appendix discusses DOE’s investigation of potential supply issues for vacuuminsulated panels (VIPs), a consideration in deciding that this technology passes screening and can 

be considered as a design option in the engineering analysis. DOE had received comments 

concerning the viability of VIPs as a design option following the preliminary analysis. In 

particular, stakeholders pointed out that achieving cost-effective efficiency levels as determined 

by the DOE preliminary analysis depended on increase of VIP supply to a level of millions of 

panels per year, which stakeholders asserted the VIP industry could not achieve and/or would 

lead to significant price increase. DOE conducted an assessment of the VIP market and the 

required ramp-up of VIP production and concluded that the market does not show ramp-up to be 

a critical issue leading to price pressure.

DOE contacted several VIP suppliers to better assess the current production capacity and 

the ability of the industry to ramp up to expected demand by 2014. These suppliers include 

Porextherm (Germany)1

, Va-Q-tec (Germany)2, ThermoCor (U.S.)3, NanoPore Insulation LLC 

(U.S.)4, Glacier Bay (U.S.)5, and ThermalVisions (U.S.)6

4-A.2 VIP DEMAND

. DOE did not receive a response from 

any Asian companies it attempted to contact during this phase, but Porextherm estimated that 

there are five VIP producers based in China and Japan.

VIPs have been used in refrigerators for more than 20 years, but only in high-end models 

until recent years. In the U.S., major refrigerator manufacturers have started using VIPs in 

commodity models, driven by the manufacturer tax credit available in 2008-2010.

a DOE 

estimates that the current worldwide VIP market is in the range of 2.5 to 5 million square meters 

based on input from VIP manufacturers. This is a wide range due to the variation in estimates 

provided by vendors providing information and also due to the lack of information obtained from 

Asian suppliers, particularly from Japan, which is reported to have experienced the greatest use 

of VIPs to date. Va-Q-tec estimated that world production is approximately 2 million square 

meters. ThermoCor estimated it to be about 5 million square meters. Other vendors interviewed 

declined to provide estimates.

DOE used its NOPR analysis results to estimate the projected VIP demand in the U.S. in 

2014 based on the proposed standard levels. DOE first estimated the VIP surface area required 

per unit for each of the eleven directly-analyzed product classes at the proposed standard level.

The estimates are based on use of VIPs as determined in the engineering analysis. 

 

a Energy Improvement and Extension Act of 2008 (EIEA 2008; Public Law 110-343). Manufacturers can receive 

$200 per unit for units at least 30 percent more efficient than the standard.
4-A-2

For the conventional products, DOE conducted thorough energy and cost analysis for two 

products of each product class. The reported estimate of VIP demand for these product classes is 

based on the average of the surface areas required at the proposed standard level for the two 

analyzed products. For built-in products, DOE assumed that the product analyzed in the 

engineering analysis was representative of all products in that class. DOE used the product 

shipment projections for 2014 as calculated in the shipments analysis to convert the per-unit 

demand to national demand in terms of VIP surface area. The resulting demand estimate is 5.8

million square meters of VIPs in 2014. Table 4-A-1 shows the breakdown of this estimate by 

product class. The demand could be lower or higher depending on the decisions manufacturers 

make regarding use of design options in designs to meet the new standards. 

Table 4-A-1: U.S. Demand at Proposed Standard Levels

Product Classes Estimated Total VIP 

Demand in 2014 

(million m2)

3 4.0

5 0.0

7 1.3

9 0.0

10 0.0

11 0.0

18 0.0

3- Built-In 0.1

5- Built-In 0.0

7- Built-In 0.3

9- Built-In 0.2

Total: 5.8

DOE also considered the potential increase in demand for VIPs in Europe and India. As 

part of this examination, DOE reviewed European directives aimed at improving energy 

efficiency. The European Energy Labeling Directive (94/2/EC) for cold appliances, which was 

issued by the European Commission on January 21, 1994, established 7 efficiency levels for 

these products, from least efficient G to most efficient A. In 2003, additional higher efficiency 

levels A+ and A++ were established. These levels all represent different percentages of reference 

energy use, called Energy Efficiency Index (EEI), from less than 30 for A++ (the most efficient) 

to 125 for G. The European Union established efficiency standards for residential refrigeration 

products with EU Council Directive 96/57/EC dated 3 September 1996. Maximum energy use 

standards were established for 10 “product categories”, the equivalent to different product 

classes associated with DOE regulations. Commission Regulation (EC) No 643/2009 requires 

that the maximum allowable EEI will become 55 starting July 1, 2010. This level will drop to 44 

on July 1, 2012, and to 42 (equivalent to current efficiency level A+) on July 1, 2014. 

DOE received estimates from various VIP manufacturers that European demand is 

expected to rise to a level in a range from 2 to 5 million square meters in response to the new 
4-A-3

standards. Information obtained from a manufacturer that has used VIPs in multiple products 

suggests that VIPs will be used primarily for A++ products, which may be considered the 

equivalent of the current U.S. ENERGY STAR products. The 2 to 5 million square meter 

estimate is consistent with the use of VIPs primarily for A++ products, assuming that these 

products will represent 10 to 20 percent of the market.

Along similar lines, India introduced a labeling program in 2006 that was initially 

voluntary but became mandatory in January 2010. The program establishes efficiency levels 

represented by ranges of energy use. The product label is required to indicate the product’s 

efficiency level. The allowable maximum energy use values associated with the efficiency levels 

are scheduled to be reduced in three steps between 2010 and 2014. However, based on 

discussions with manufacturers, India’s proposed standards for 2014 are not expected to be as 

stringent as in the U.S. or Europe and are not expected to require use of VIPs.

Taking into account the markets discussed above, worldwide VIP demand is expected to 

reach a level in the range 10 to 15 million square meters, based on available information as 

shown in Table 4-A-2. DOE’s understanding of the Asian market is limited. DOE expects that 

demand will be small in other markets such as Australia and New Zealand and India due to less 

stringent standards and/or much lower population. 

Table 4-A-2: Current and Projected VIP Demand

Key Markets Current Demand 

in 2010 

(million m2)

Projected Demand 

in 2014 (million m2)

United States 1 to 3 6

Europe 0.5 2 to 5

Asia 1 to 2 2 to 4

Total 2.5 to 5.5 10 to 15
4-A-4

4-A.3 ABILITY OF VIP SUPPLIERS TO MEET DEMAND

The projected demand of 10 to 15 million m2 represents a growth factor in the range of 2

to 6, depending on which ends of the current and projected ranges are most accurate. While the 

high end of this range represents dramatic growth, it is not inconsistent with the growth that the 

market has experienced recently for which VIP vendors have successfully ramped up their 

production.

Several VIP manufacturers are currently expanding their facilities, while others have 

plans to expand if the demand becomes more reliable. Overall, the VIP manufacturers 

interviewed were confident that neither the time nor the capital investment is a limiting factor as 

long as they have a stable backlog. Five of the manufacturers commented on their recent 

expansion efforts:

• Manufacturer 1 has increased its production capacity by 10 times between 2008 and 

Spring 2010 to reach a level of about 1.5 million m2

. 

• Manufacturer 2 has doubled its capacity to about 120,000 m2 in the last 6 months.

• Manufacturer 3 has doubled its capacity to about 1 million m2 in the last 9 months. 

• Manufacturer 4 has taken 1.5 years to reach capacity of about 300,000 m2. 

• Manufacturer 5 has recently doubled its capacity and has plans to expand to 0.9 million

m

2 capacity by 2010.

In total, the production capacity of the VIP vendors that participated in the discussions

has increased from about 0.1 million m

2 prior to 2008 to about 3 million m2 in 2010, suggesting 

an order-of-magnitude increase at a rate of nearly 1.5 million m2 per year, not including vendors 

from whom DOE did not receive capacity growth information. In order to meet the estimates of 

projected demand above, an overall growth rate of production capacity serving the US and EU 

markets of 1.5 to 4 million m2 per year is needed.

Estimates by VIP manufacturers of the time required to bring a new minimum-capacity 

efficient plant on-line range from 6 to 18 months, as shown in Table 4-A-3.

b If each of the six 

manufacturers interviewed expanded at their stated minimum rate, they could generate an 

increase of over 9 million m

2 by 2014. This estimated expansion falls within the range of 

estimates of required ramp-up without considering other existing manufacturers, or factoring in 

the potential for new manufacturers to enter the market.

 

b A minimum-capacity efficient plant is a plant with a capacity at the low end of the range needed to achieve costs 

that are sufficiently minimized to be competitive.
4-A-5

Table 4-A-3: New Manufacturing Facility Ramp-Up Time

Minimum-Capacity

Efficient Plant Size 

(million m2 annual 

capacity)

Time to Bring On-line 

(months)

Manufacturer 1 1.5 12

Manufacturer 2 0.2 6

Manufacturer 3 0.4 9

Manufacturer 4 0.3 12

Manufacturer 5 0.5 18

The variation in the time to build a new plant depends on whether existing production 

technology is replicated, or whether further improvements in production technology are designed 

into new plants. Possible improvements to lower cost and increase production capacity include 

more automation of the panel assembly and a switch to continuous processing. Automation may 

be applied to the drying of the core material and the cutting of the bag and core. DOE visited a 

VIP production facility during the course of this investigation and concluded that the estimates 

provided by VIP vendors of time required to bring new production capacity online are consistent 

with the production process, given the equipment used.

Several VIP manufacturers have considered joint ventures and licensing opportunities 

with refrigerator manufacturers. Manufacturers of VIPs suggest that transferring the knowledge 

and expertise of VIP production would be a straightforward process. A new VIP fabrication 

facility would need to have a production capacity between 300,000 and 1.5 million square meters 

per year to be cost-effective at today’s VIP price levels. The capacity will typically vary based 

on the manufacturer, the panel type, and the facility location. 

VIP manufacturers do not anticipate the supply of raw materials to be an issue as 

production ramps up. The industry uses multiple suppliers for both the barrier film and the fill 

material. Materials used for the fill include glass fiber, fumed silica, and aerogel. Glass fiber is 

produced for a wide range of applications worldwide. Fumed silica, used as fill by some VIP 

manufacturers, is currently produced on a much smaller scale. Asked if the more limited range of 

uses of fumed silica could present material supply issues due to capacity ramp-up delays or 

intellectual property issues, Porextherm noted that intellectual property would not be a barrier for 

suppliers to building new fumed silica plants, citing several new production facilities that have 

come online recently in Asia. They also noted that the solar collector business in particular is 

helping to expand the production of pure silica, of which fumed silica is a by-product. Va-Q-tec 

estimates that there is enough fumed silica production today to produce 100 million m2 of VIPs, 

and a new fumed silica plant would require 2.5 years to be built. Thermal Visions did not 

anticipate suppliers needing more than one year to respond to the ramp-up in production. 

In summary, DOE concludes that the VIP industry has the ability to ramp up to meet the 

potential demand for VIPs within the three year gap between the rulemaking final rule and the 

date the standard takes effect. 
4-A-6

 1 Personal communication with Porextherm, February & August 2010.

2 Personal communication with Va-Q-tec, February & August 2010.

3 Personal communication with ThermoCor, February & August 2010.

4 Personal communication with NanoPore, March 2010.

5 Personal communication with Glacier Bay, February 2010.

6 Personal communication with Thermal Visions, February & August 2010.
5-A-i

APPENDIX 5-A. ENGINEERING DATA

TABLE OF CONTENTS

5-A.1 INTRODUCTION .................................................................................................5-A-1

5-A.2 ERA INPUTS.........................................................................................................5-A-1

5-A.3 INCREMENTAL COST DETAIL ......................................................................5-A-45

5-A.4 PRELIMINARY ANALYSIS ENGINEERING QUESTIONNAIRE................5-A-64

LIST OF TABLES

Table 5-A.2.1: ERA Inputs for Top-Mount Refrigerator-Freezers (Product Class 3).............5-A-3

Table 5-A.2.2: ERA Inputs for Built-in All-Refrigerators (Product Class 3A-BI) .................5-A-7

Table 5-A.2.3: ERA Inputs for Bottom-Mount Refrigerator-Freezers (Product Class 5) .....5-A-12

Table 5-A.2.4: ERA Inputs for Built-In Bottom-Mount Refrigerator-Freezers (Product 

Class 5-BI) ...............................................................................................5-A-16

Table 5-A.2.5: ERA Inputs for Bottom-Mount Refrigerator-Freezers w/TTD Ice (Product 

Class 5A)..................................................................................................5-A-21

Table 5-A.2.6: ERA Inputs for Side-Mount Refrigerator-Freezers (Product Classes 4 and 

7) ..............................................................................................................5-A-25

Table 5-A.2.7: ERA Inputs for Upright Freezers with Automatic Defrost (Product Class 

9) ..............................................................................................................5-A-29

Table 5-A.2.8: ERA Inputs for Built-In Upright Freezers (Product Class 9-BI)...................5-A-32

Table 5-A.2.9: ERA Inputs for Chest Freezers with Manual Defrost (Product Class 10).....5-A-36

Table 5-A.2.10: ERA Inputs for Compact Refrigerators (Product Class 11)........................5-A-39

Table 5-A.2.11: ERA Inputs for Compact Chest Freezers (Product Class 18)......................5-A-42

Table 5-A.3.1: Incremental Cost Detail for 16 ft3 Top-Mount Refrigerator-Freezer 

(Product Class 3)......................................................................................5-A-46

Table 5-A.3.2: Incremental Cost Detail for 21 ft3 Top-Mount Refrigerator-Freezer 

(Product Class 3)......................................................................................5-A-47

Table 5-A.3.3: Incremental Cost Detail for 21 ft3 Built-in All-Refrigerator (Product Class 

3A-BI)......................................................................................................5-A-48

Table 5-A.3.4: Incremental Cost Detail for 18.5 ft3 Bottom-Mount Refrigerator-Freezer 

(Product Class 5)......................................................................................5-A-49

Table 5-A.3.5: Incremental Cost Detail for 25 ft3 Bottom-Mount Refrigerator-Freezer 

(Product Class 5)......................................................................................5-A-50

Table 5-A.3.6: Incremental Cost Detail for 21 ft3 Built-In Bottom-Mount RefrigeratorFreezer (Product Class 5-BI) ...................................................................5-A-51

Table 5-A.3.7: Incremental Cost Detail for 22 ft3 Side-Mount Refrigerator-Freezer with 

TTD Ice (Product Class 7).......................................................................5-A-52

Table 5-A.3.8: Incremental Cost Detail for 26 ft3 Side-Mount Refrigerator-Freezer with 

TTD Ice (Product Class 7).......................................................................5-A-53
5-A-ii

Table 5-A.3.9: Incremental Cost Detail for 28 ft3 Built-In Side-Mount RefrigeratorFreezer with TTD ice service (Product Class 7-BI).................................5-A-54

Table 5-A.3.10: Incremental Cost Detail for 14 ft3 Upright Freezer with Auto Defrost 

(Product Class 9)......................................................................................5-A-55

Table 5-A.3.11: Incremental Cost Detail for 20 ft3 Upright Freezer with Auto Defrost 

(Product Class 9)......................................................................................5-A-56

Table 5-A.3.12: Incremental Cost Detail for 22 ft3 Built-In Upright Freezer (Product 

Class 9-BI) ...............................................................................................5-A-57

Table 5-A.3.13: Incremental Cost Detail for 15 ft3 Chest Freezer (Product Class 10)..........5-A-58

Table 5-A.3.14: Incremental Cost Detail for 20 ft3 Chest Freezer (Product Class 10)..........5-A-59

Table 5-A.3.15: Incremental Cost Detail for 1.7 ft3 Compact Refrigerator (Product Class 

11) ............................................................................................................5-A-60

Table 5-A.3.16: Incremental Cost Detail for 4.0 ft3 Compact Refrigerator (Product Class 

11) ............................................................................................................5-A-61

Table 5-A.3.17: Incremental Cost Detail for 3.4 ft3 Compact Chest Freezer (Product 

Class 18)...................................................................................................5-A-62

Table 5-A.3.18: Incremental Cost Detail for 7.0 ft3 Compact Chest Freezer (Product 

Class 18)...................................................................................................5-A-63
5-A-1

APPENDIX 5-A. ENGINEERING DATA

5-A.1 INTRODUCTION

The Energy-efficient Refrigerator Analysis Program (ERA) was used to calculate energy 

use for baseline and energy-saving configurations for the various product classes of refrigeration 

products. Inputs to this program were generated from reverse-engineering teardowns of select 

refrigerator and refrigerator-freezer models currently available. The values for the input variables

are shown in tabular format in section 5-A.2. The input is provided to the extent possible in the 

format required for the Windows version of ERA. Because analysis was carried out with the 

DOE version of ERA for most of the products, in some cases the input format may not translate 

directly, and the output values may not match exactly.

The incremental cost curves describing costs to attain each analyzed efficiency level are 

based on the energy use output from the ERA program. Development of costs for these curves is 

described in chapter 5. The tables in section 5-A.3 show these incremental cost curves in tabular 

format, with identification of the design options required to reach each efficiency level shown. 

As part of the engineering analysis, DOE solicited input from manufacturers on a range 

of technical topics affecting energy use in refrigeration products. The questionnaire used to 

facilitate these interviews is shown in section 5-A.4.

5-A.2 ERA INPUTS

The ERA inputs for each of the units selected for reverse-engineering analysis are shown 

below. Some general notes regarding the data include the following:

1. Compressor compartment insulation thickness is specified directly in Windows ERA, 

while DOS ERA used bottom wall thickness. 

2. The ERA input for door openings is not provided, since DOE conducted analysis 

based on closed doors.

3. Windows ERA includes separate input for the air in the compressor compartment.

DOS ERA used the air temperature underneath the cabinet for this region.

4. DOE conducted all analyses using single evaporator system configuration with HFC134a refrigerant.

5. The tube and fin heat exchanger configuration implies forced convection air flow.

6. See the Windows ERA program for definitions of air flow directions for forced 

convection wire fin condensers.
5-A-2

7. Some products analyzed had spine fin evaporators, which are not supported by ERA. 

Input for a separate spine fin analysis spreadsheet calculation is provided in the tables 

below for these products.

8. Windows ERA does not allow superheat or subcooling input of 0  ̊C, although DOS 

ERA does. Suggested input is 0.5  ̊C in cases where input of 0  ̊C is indicated.

 
5-A-3

Table 5-A.2.1: ERA Inputs for Top-Mount Refrigerator-Freezers (Product Class 3)

Top-Mount Refrigerator-Freezers 16 ft3 Baseline 21 ft3 Baseline 21 ft3 E*

General Data

Fresh Food Volume (ft3) 11.6 15.3 15.3

Freezer Volume (ft3) 4.1 5.3 5.3

Total Volume (ft3) 15.7 20.6 20.6

Adjusted Volume (ft3) 18.3 23.9 23.9

Rated Energy Use (kWh/yr) 455 509 408

Calculated Max. Energy Use (kWh/yr) 455 511 511

Rated Energy Use Below Maximum (%) 0.0 0.3 20.1

Cabinet Dimensions

Category Top-mount Top-mount Top-mount

Cabinet Height (cm) 146.7 165.6 165.6

Cabinet Width (cm) 70.8 75.3 75.3

Depth, from Door Flange (cm) 62.6 74.3 74.3

Depth, from Door Outer Surface (cm) 71.1 80.7 80.7

Liner Properties

Outer Liner Thickness (mm) 0.4 0.4 0.4

Outer Liner Conductivity (W/m-C) 44.7 44.7 44.7

Inner Liner Thickness (mm) 1.0 1.5 2.0

Liner Conductivity (W/m-C) 0.16 0.16 0.16

Compressor Compartment Dimensions

Top Depth (cm) 12.7 12.4 12.4

Bottom Depth (cm) 21.6 25.8 25.8

Height (cm) 26.0 16.0 16.0

Wall (vertical) (cm) 43 5.9 5.9

Wall (horizontal) (cm) 4.3 6.4 6.4

Freezer Section

 Insulation Thickness

 Top Wall (cm) 5.3 7.1 7.1

 Side Wall (cm) 5.5 7.5 7.5

 Back Wall (cm) 7.0 7.9 7.9

 Door (cm) 6.2 7.2 7.2

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.50 0.50 0.50

 Wedge/Flange Dimensions

 Freezer Wedge Depth (cm) 7.6 7.0 7.0

 Freezer Flange Width (cm) 3.8 3.8 3.8

 Heat Paths

 Freezer Gasket Heat Leak (W/m-100C) 9.0 9.0 9.0

 Fzr Cabinet Penetration Heat Leak (W) 1.5 0.0 0.0

Fresh Food Section

 Insulation Thickness 

 Side Wall (cm) 3.8 4.8 4.8
5-A-4

Top-Mount Refrigerator-Freezers 16 ft3 Baseline 21 ft3 Baseline 21 ft3 E*

 Back Wall (cm) 5.0 4.9 4.9

 Bottom Wall (cm) 4.3 5.1 5.1

 Door (cm) 4.1 4.7 4.7

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.50 0.50 0.50

 Wedge/Flange Dimensions

 Fresh Food Wedge Depth (cm) 0.1 7.6 7.6

 Fresh Food Flange Width (cm) 3.8 3.8 3.8

 Heat Paths

 FF Gasket Heat Leak (W/m-100C) 9.0 9.0 9.0

 FF Cabinet Penetration Heat Leak (W) 1.5 0.0 0.0

Mullion

 Distance to Top (cm) 44.5 50.8 50.8

 Thickness w/Liners (cm) 5.7 7.1 7.1

 Resistivity w/Liners (m2-C/W-cm) 0.5 0.5 0.5

Air and Cabinet Temperatures 

 Room Air (°C) 32.2 32.2 32.2

 Freezer Section (°C) -15 -15 -15

 Fresh Food Section (°C) 7.2 7.2 7.2

 Air Under Cabinet (°C) 35.0 35.0 35.0

 Compressor Compartment ( ̊C) 35.0 35.0 35.0

 Air Entering Condenser (°C) 32.2 33.0 33.0

Defrost and Controls Energy

Defrost Type (Automatic, Manual) Automatic Automatic Automatic

 Timer Interval (Hr) 14.0 10.5 10.5

 Heater On-Time (Min) 8.0 4.8 4.8

 Defrost Power (W) 390 413 413

Other Cycle-Dependent Loads

 Freezer Section (W) 0 0 0

 Fresh Food Section (W) 0.3 0.3 0.3

 Outside Cabinet (W) 0 0 0

Constant Electrical Loads

 Freezer Section (W) 0 0 0

 Fresh Food Section (W) 0 0 0

 Outside Cabinet (W) 0 0 0

Liquid Refrigerant Line Anti-Sweat

Freezer Door Flange

 Cycle Average Energy (W) 4 3.8 3.8

 Fraction Heat Leak (0-1) 0.5 0.3 0.3

Fresh Food Door Flange

 Cycle Average Energy (W) 0 0 0

 Fraction Heat Leak (0-1) 0 0 0

Mullion
5-A-5

Top-Mount Refrigerator-Freezers 16 ft3 Baseline 21 ft3 Baseline 21 ft3 E*

 Cycle Average Energy (W) 1.5 1.3 1.3

 Heat Leak to Freezer (0-1) 0.25 0.25 0.25

 Heat Leak to Fresh Food (0-1) 0.25 0.25 0.25

Evaporator Design

 Exit Superheat 2 2 0

 Fin Type (plain, wavy, herringbone) Spine Plain Plain

 Fan Motor Type AC-Input 

BLDC Shaded Pole Shaded Pole

 Fan Power (W) 3.5 6.1 5.7

 Air Flow Rate (Liter/s) 16.6 21.3 21.3

Tube Characteristics

 Width of Tube Row 52.1 45.7 45.7

 Tube OD (mm) 9.4 7.9 7.9

 Tube Wall Thickness (mm) 0.76 0.6 0.6

 # of Tubes Deep 7 4 4

 Tube Pitch (cm) 2.5 3.8 3.8

 # of Tubes Normal to Airflow 2 6 6

 Normal Tube Pitch (cm) 2.5 1.9 1.9

Fin Characteristics

 Fin Thickness (mm) 0.25 0.13 0.13

 Fin Pitch (mm) 9.5 6.3 6.3

 Fin Conductivity (W/m-K) 190 190 190

 Fraction Finned (0-1) 0.93 0.89 0.89

Spine Fin Input Data

 Spine Height (mm) 10.5 NA NA

 Spine Width (mm) 0.79 NA NA

Condenser Design a a

 Exit Subcooling (°C) 2 0 0

 Configuration (Static, Hot-wall, Tube 

& Fin, Microchannel) Tube & Fin Tube & Fin Tube & Fin

 Air-side Configuration (wire, plain, 

smooth wavy, herringbone, slit, louver) Wire Wire Wire

 Fan Motor Type Shaded Pole Shaded Pole AC-input 

BLDC

 Fan Power (W) 11.2 9.4 3.3

 Air Flow Rate (Liter/s) 30.0 26.0 31.2

Tube Characteristics

 Airflow Direction (W, L, H) W W W

 Tube OD (mm) 4.8 4.8 4.8

 Tube Wall Thickness (mm) 0.8 0.6 0.6

 

a Surface areas calculated by the condenser routine were increased by a factor of 2.56 for the 21 ft3 top-mount 

refrigerators to calibrate with test data for condensing temperatures.
5-A-6

Top-Mount Refrigerator-Freezers 16 ft3 Baseline 21 ft3 Baseline 21 ft3 E*

 Length of Tube in “L” Direction 59.6 20.1 20.1

 # of Tubes in H Direction 1 8 8

 Tube Pitch (cm) 2.5 2.5 2.5

 # of Tubes in W Direction 14 6 6

 Tube Pitch (cm) 2.5 2.5 2.5

 Fraction Air through Exchanger (0-1) 0.6 0.9 0.9

Fin Characteristics

 Wire OD (mm) 1.5 1.1 1.1

 # of Wires on 1-side per layer 95 29 29

 Wire Mounting (1-side, 2-sides) 2-sides 2-sides 2-sides

 Wire Fin Pitch (mm) 5.1 5.1 5.1

 Wire Length (cm) 34.9 14.0 14.0

 Wire Conductivity (W/m-K) 44.7 44.7 44.7

Compressor Data

 Manufacturer Matsushita Matsushita Matsushita

 Model # DGS57C84RAU SF51C97RAU6 DHS57C85RAU

 Cycles per hour 1.0 1.0 1.0

Interchanger

 Effectiveness (0-1) 0.9 0.95 0.95

Component Adjustment Factors

 Condenser UA Multiplier 1.0 2.56 2.56
5-A-7

Table 5-A.2.2: ERA Inputs for Built-in All-Refrigerators (Product Class 3A-BI)

Built-in All-Refrigerators 21 ft3 E*

General Data

 Upper Compartment Volume (ft3) 13.4

 Lower Compartment Volume (ft3) 7.5

 Total Volume (ft3) 20.9

 Adjusted Volume (ft3) 20.9

 Rated Energy Use (kWh/yr) 376

 Calculated Max. Energy Use (kWh/yr) 480

 Rated Energy Use Below Maximum (%) 21.7

Cabinet Dimensions

 Category (from ERA selection) Bottom-Mount

 Cabinet Height (cm) 172.9

 Cabinet Width (cm) 90.8

 Depth, from Door Flange (cm) 57.2

 Depth, from Door Outer Surface (cm) 61.0

Liner Properties

 Outer Liner Thickness (mm) 1.5

 Outer Liner Conductivity (W/m-C) 44.7

 Inner Liner Thickness (mm) 0.9

 Liner Conductivity (W/m-C) 190

Lower Compartment Cabinet

 Insulation Thickness

 Side Wall (cm) 4.9

 Back Wall (cm) 4.4

 Bottom (cm) 4.2

 Door (cm) 5.2

 Insulation Resistivity 

 Side Wall (m2-C/W-cm) 0.73

 Back Wall (m2-C/W-cm) 0.88

 Bottom (m2-C/W-cm) 0.76

 Door (m2-C/W-cm) 0.68

 Wedge/Flange Dimensions

 Lower Compartment Flange Width (cm) 3.6

 Lower Compartment Wedge Depth (cm) 6.7

 Resistivity (m2-C/W-cm) 0.5

 Heat Paths

 Lower Compartment Gasket Heat Leak 

(W/m-100C) 9.0

 Lower Compartment Penetration Heat Leak 

(W) 0.0

Upper Compartment Cabinet

 Insulation Thickness 

 Top Wall (cm) 3.6
5-A-8

Built-in All-Refrigerators 21 ft3 E*

 Side Wall (cm) 4.9

 Back Wall (cm) 4.4

 Door (cm) 3.6

 Insulation Resistivity 

 Top Wall (m2-C/W-cm) 0.50

 Side Wall (m2-C/W-cm) 0.50

 Back Wall (m2-C/W-cm) 0.50

 Door (m2-C/W-cm) 0.87

 Wedge/Flange Dimensions

 Upper Compartment Flange Width (cm) 3.6

 Upper Compartment Wedge Depth (cm) 6.7

 Resistivity (m2-C/W-cm) 0.5

 Heat Paths

 Upper Gasket Heat Leak (W/m-100C) 9.0

 Upper Cabinet Penetration Heat Leak (W) 0.0

Mullion

 Distance to Top (cm) 102.9

 Thickness w/Liners (cm) 10.1

 Resistivity w/Liners (m2-C/W-cm) 0.50

Air and Cabinet Temperatures 

 Room Air (°C) 32.2

 Lower Compartment Section (°C) 3.3

 Upper Compartment Section (°C) 3.4

 Air Under Cabinet (°C) 33.0

 Compressor Compartment ( ̊C) 33.0

 Air Entering Condenser (°C) 32.2

Defrost and Controls Energy

 Defrost Type (Automatic, Manual) Manual

 Other Cycle-Dependent Loads

 Lower Compartment Section (W) 0

 Upper Compartment Section (W) 0

 Outside Cabinet (W) 0

 Constant Electrical Loads

 Lower Compartment Section (W) 0

 Upper Compartment Section (W) 0

 Outside Cabinet (W) 1.3

Liquid Refrigerant Line Anti-Sweat

 Lower Compartment Door Flange

 Cycle Average Energy (W) 2.9

 Fraction Heat Leak (0-1) 0.5

 Upper Compartment Door Flange

 Cycle Average Energy (W) 3.0

 Fraction Heat Leak (0-1) 0.5
5-A-9

Built-in All-Refrigerators 21 ft3 E*

 Mullion

 Cycle Average Energy (W) 1.8

 Heat Leak to Lower Compartment (0-1) 0.4

 Heat Leak to Upper Compartment (0-1) 0.4

Cycle Parameters

 Cycle Type Dual loop

 Cycling Losses YES

 Cycles/hr 1.5

 Refrigerant R-134a

Evaporator Design (Lower Compartment)

 Exit Superheat (°C) 0.8

 Fin Type (plain, wavy, herringbone) Plain

 Fan Motor Type (Shaded Pole, AC-Input 

BLDC, DC-Input BLDC) AC-Input BLDC

 Fan Power (W) 3.1

 Air Flow Rate (Liter/s) 20.2

 Tube Characteristics

 Width of Tube Row 48.8

 Tube OD (mm) 9.3

 Tube Wall Thickness (mm) 0.64

 # of Tubes Normal to Airflow 2

 Normal Tube Pitch (cm) 1.1

 # of Tubes Deep 9

 Tube Pitch (cm) 1.9

 Fin Characteristics

 Fin Thickness (mm) 0.13

 Fin Pitch (mm) 5.1

 Fin Conductivity (W/m-K) 190

 Fraction Finned (0-1) 0.90

Evaporator Design (Upper Compartment)

 Exit Superheat (°C) 0.8

 Fin Type (plain, wavy, herringbone) Plain

 Fan Motor Type (Shaded Pole, AC-Input 

BLDC, DC-Input BLDC) AC-Input BLDC

 Fan Power (W) 3.1

 Air Flow Rate (Liter/s) 13.5

 Tube Characteristics

 Width of Tube Row 48.8

 Tube OD (mm) 9.3

 Tube Wall Thickness (mm) 0.64

 # of Tubes Normal to Airflow 2

 Normal Tube Pitch (cm) 1.1

 # of Tubes Deep 9
5-A-10

Built-in All-Refrigerators 21 ft3 E*

 Tube Pitch (cm) 1.9

 Fin Characteristics

 Fin Thickness (mm) 0.13

 Fin Pitch (mm) 5.1

 Fin Conductivity (W/m-K) 190

 Fraction Finned (0-1) 0.90

Condenser Design (Lower Compartment)

 Exit Subcooling (°C) 0.7

 Configuration (Static, Hot-wall, Tube & 

Fin, Microchannel) Tube & Fin

 Air-side Configuration (wire, plain, smooth 

wavy, herringbone, slit, louver) Plain

 Fan Motor Type (Shaded Pole, AC-Input 

BLDC, DC-Input BLDC) AC-Input BLDC

 Fan Power in Fan Energy Calculations (W) 41

 Air Flow Rate (Liter/s) 16.4

 Tube Characteristics

 Width of Tube Row 34.0

 Tube OD (mm) 6.4

 Tube Wall Thickness (mm) 0.46

 # of Tubes Deep 8

 Tube Pitch (cm) 1.3

 # of Tubes Normal to Airflow 2

 Normal Tube Pitch (cm) 2.2

 Faction of Air through Condenser 1

 Fin Characteristics

 Fin Thickness (mm) 0.19

 Fin Pitch (mm) 3.6

 Fin Conductivity (W/m-K) 190

 Fraction Finned (0-1) 0.86

Condenser Design (Upper Compartment)

 Exit Subcooling (°C) 0.7

 Configuration (Static, Hot-wall, Tube & 

Fin, Microchannel) Tube & Fin

 Air-side Configuration (wire, plain, smooth 

wavy, herringbone, slit, louver) Plain

 Fan Motor Type (Shaded Pole, AC-Input 

BLDC, DC-Input BLDC) AC-Input BLDC

 Fan Power in Fan Energy Calculations (W) 41

 Air Flow Rate (Liter/s) 16.4

 Tube Characteristics

 Width of Tube Row 34.0

 Tube OD (mm) 6.4
5-A-11

Built-in All-Refrigerators 21 ft3 E*

 Tube Wall Thickness (mm) 0.46

 # of Tubes Deep 8

 Tube Pitch (cm) 1.3

 # of Tubes Normal to Airflow 2

 Normal Tube Pitch (cm) 2.2

 Faction of Air through Condenser 1

 Fin Characteristics

 Fin Thickness (mm) 0.19

 Fin Pitch (mm) 3.6

 Fin Conductivity (W/m-K) 190

 Fraction Finned (0-1) 0.86

Compressor Data (Lower Compartment)

 Manufacturer Embraco

 Model EM20HSC

 Capacity Multiplier 1.0

 Power Multiplier 1.0

 Speed Multiplier 1.0

Compressor Data (Upper Compartment)

 Manufacturer Embraco

 Model EM20HSC

 Capacity Multiplier 1.0

 Power Multiplier 1.0

 Speed Multiplier 1.0

Interchangers

 Effectiveness (0-1, Lower Compartment) 0.75

 Effectiveness (0-1, Upper Compartment) 0.75

 Compressor Shell Inlet Temperature (°C) Calculated 1

This product has a single condenser with a separate circuit for each of the two 

refrigeration systems. The single fan operates when one or two of the 

compressors are operating. The condenser fan power was set to 0W for each of 

these systems in ERA, and a post-processing spreadsheet was used to calculate 

fan energy use with consideration of the overlap of the two system on-cycles.
5-A-12

Table 5-A.2.3: ERA Inputs for Bottom-Mount Refrigerator-Freezers (Product Class 5)

Bottom-Mount Refrigerator-Freezers 18.5 ft3 25 ft3 E*, #1 25 ft3 E*, #2

General Data

 Fresh Food Volume (ft3) 13.1 17.8 17.6

 Freezer Volume (ft3) 5.4 7.3 7.7

 Total Volume (ft3) 18.5 25.1 25.3

 Adjusted Volume (ft3) 21.9 29.6 30.2

 Rated Energy Use (kWh/yr) 476 475 478

 Calculated Max. Energy Use (kWh/yr) 560 595 598

 Rated Energy Use Below Maximum (%) 15.0 20.2 20.0

Cabinet Dimensions

 Category Bottom-Mount Bottom-Mount Bottom-Mount

 Cabinet Height (cm) 160.7 168.3 168.0

 Cabinet Width (cm) 75.3 90.5 90.8

 Depth, from Door Flange (cm) 69.2 72.4 71.3

 Depth, from Door Outer Surface (cm) 76.8 79.4 78.3

Liner Properties

 Outer Liner Thickness (mm) 0.5 0.6 0.5

 Outer Liner Conductivity (W/m-C) 44.7 43.3 44.7

 Inner Liner Thickness (mm) 1.3 1.9 1.4

 Liner Conductivity (W/m-C) 0.16 0.16 0.16

Compressor Compartment Dimensions

 Top Depth (cm) 16.5 17.1 12.7

 Bottom Depth (cm) 27.0 27.3 25.4

 Height (cm) 24.5 24.1 22.9

 Wall (vertical) (cm) 7.0 6.9 6.6

 Wall (horizontal) (cm) 7.0 6.9 6.6

Freezer Cabinet

 Insulation Thickness

 Side Wall (cm) 6.9 7.5 6.8

 Back Wall (cm) 7.9 6.5 7.6

 Bottom (cm) 7.0 6.9 6.6

 Door (cm) 6.3 6.0 6.9

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.50 0.50 0.53

 Wedge/Flange Dimensions

 Freezer Flange Width (cm) 3.8 3.8 5.4

 Freezer Wedge Depth (cm) 5.1 6.4 5.1

 Resistivity (m2-C/W-cm) 0.5 0.5 0.5

Heat Paths

 Freezer Gasket Heat Leak (W/m-100C) 9.5 8.0 8.0

 Fzr Cabinet Penetration Heat Leak (W) 5 3 0

Fresh Food Cabinet

 Insulation Thickness 
5-A-13

Bottom-Mount Refrigerator-Freezers 18.5 ft3 25 ft3 E*, #1 25 ft3 E*, #2

 Top Wall (cm) 5.2 3.9 4.2

 Side Wall (cm) 4.2 5.1 3.5

 Back Wall (cm) 5.7 6.8 4.1

 Door (cm) 4.3 4.9 6.9

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.50 0.50 0.53

 Wedge/Flange Dimensions

 Fresh Food Flange Width (cm) 3.8 3.8 3.4

 Fresh Food Wedge Depth (cm) 10.2 11.4 0.0

 Resistivity (m2-C/W-cm) 0.5 0.5 0.5

 Heat Paths

 FF Gasket Heat Leak (W/m-100C) 9.5 8.0 8.0

 FF Cabinet Penetration Heat Leak (W) 0.0 3.0 0.0

Mullion

 Distance to Top (cm) 92.7 100.0 94.3

 Thickness w/Liners (cm) 5.4 5.4 7.3

 Resistivity w/Liners (m2-C/W-cm) 0.50 0.51 0.5

Air and Cabinet Temperatures 

 Room Air (°C) 32.2 32.2 32.2

 Freezer Section (°C) -15.0 -15.0 -15.0

 Fresh Food Section (°C) 7.2 7.2 7.2

 Air Under Cabinet (°C) 36.6 35.0 35.0

 Compressor Compartment ( ̊C) 36.6 35.0 35.0

 Air Entering Condenser (°C) 32.2 33.0 34.5

Defrost and Controls Energy

 Defrost Type (Automatic, Manual) Automatic Automatic Automatic

 Timer Interval (Hr) 7.5 38.0 38.0

 Heater On-Time (Min) 7.0 7.0 24.0

 Defrost Power (W) 375 450 440

 Other Cycle-Dependent Loads

 Freezer Section (W) 0 0 0

 Fresh Food Section (W) 3 0 0

 Outside Cabinet (W) 0 0 0

 Constant Electrical Loads

 Freezer Section (W) 0.7 0.0 4.2

 Fresh Food Section (W) 0.0 0.4 0.0

 Outside Cabinet (W) 0.0 0.0 1.5

Liquid Refrigerant Line Anti-Sweat

 Freezer Door Flange

 Cycle Average Energy (W) 1.0 3.8 3.0

 Fraction Heat Leak (0-1) 0.75 0.5 0.75

 Fresh Food Door Flange

 Cycle Average Energy (W) 0 0 0
5-A-14

Bottom-Mount Refrigerator-Freezers 18.5 ft3 25 ft3 E*, #1 25 ft3 E*, #2

 Mullion

 Cycle Average Energy (W) 2 1.3 1.0

 Heat Leak to Freezer (0-1) 0.75 0.5 0.5

 Heat Leak to Fresh Food (0-1) 0.15 0.25 0.25

Evaporator Design

 Exit Superheat (°C) 0.8 4.0 1.0

 Fin Type (plain, wavy, herringbone) Plain Plain Spine Fin

 Fan Motor Type (Shaded Pole, AC-Input 

BLDC, DC-Input BLDC) Shaded Pole Shaded Pole DC-Input BLDC

 Fan Power (W) 6.2 6.5 3.8

 Air Flow Rate (Liter/s) 20 30 16.6

Tube Characteristics

 Width of Tube Row 48.9b 71.1c 76.2

 Tube OD (mm) 7.9 7.9 9.7

 Tube Wall Thickness (mm) 0.5 0.5 1.1

 # of Tubes Deep 4.5b 4.5c 7

 Tube Pitch (cm) 3.8 3.6 2.5

 # of Tubes Normal to Airflow 4 4 2

 Normal Tube Pitch (cm) 1.9 1.9 2.5

Fin Characteristics

 Fin Thickness (mm) 0.13 0.13 0.25

 Fin Pitch (mm) 5.1 5.1 9.5

 Fin Conductivity (W/m-K) 190 190 190

 Fraction Finned (0-1) 0.98 0.89 1.0

Spine Fin Input Data

 Spine Height (mm) NA NA 10.5

 Spine Width (mm) NA NA 0.8

Condenser Design

 Exit Subcooling (°C) 0.7 1.0 1.5

 Configuration (Static, Hot-wall, Tube & 

Fin, Microchannel) Tube & Fin Tube & Fin Tube & Fin

 Air-side Configuration (wire, plain, 

smooth wavy, herringbone, slit, louver) Wire Wire Wire

 Fan Motor Type (Shaded Pole, AC-Input 

BLDC, DC-Input BLDC)

AC-Input 

BLDC

AC-Input 

BLDC

DC-Input 

BLDC

 Fan Power (W) 3.8 3.7 2.6

 Air Flow Rate (Liter/s) 30 30.8 23.7

 Tube Characteristics

 

b Number of tubes in the air flow direction alternate 4 and 5, averaging 4.5. ERA analysis was conducted by 

selecting 4 rows deep and increasing the tube row width to 55.0 cm to compensate for the missing tubes.

c Number of tubes in the air flow direction alternate 4 and 5, averaging 4.5. ERA analysis was conducted by 

selecting 4 rows deep and increasing the tube row width to 80.0 cm to compensate for the missing tubes.
5-A-15

Bottom-Mount Refrigerator-Freezers 18.5 ft3 25 ft3 E*, #1 25 ft3 E*, #2

 Airflow Direction (W, L, H) L L H

 Tube OD (mm) 4.8 4.8 5.0

 Tube Wall Thickness (mm) 0.5 0.6 0.64

 Length of Tube in “L” Direction (cm) 34.9 34.9 52.4

 # of Tubes in H Direction 2 2 3

 Tube Pitch (cm) 2.2 3.8 0.8

 # of Tubes in W Direction 26 30 10

 Tube Pitch (cm) 2.2 2.2 2.5

 Fraction Air through Exchanger (0-1) 0.8 1.0 1

 Fin Characteristics

 Wire OD (mm) 1.3 1.3 1.4

 # of Wires on 1-side 55 51 206

 Wire Mounting (1-side, 2-sides) 2-sides 2-sides 2-sides

 Wire Fin Pitch (mm) 4.8 4.8 2.5

 Wire Length (cm) 57.1 66.7 23.5

 Wire Conductivity (W/m-K) 44.7 44.7 44.7

Compressor Data

 Manufacturer Embraco Tecumseh Embraco

 Model EMX70HSC TPG1370YXA VEGY 8H

 Cycles per hour 1.0 1.5 0.45

Interchanger

 Effectiveness (0-1) NA 0.95 0.98

 Compressor Shell Inlet Temperature (°C) 33.3 Unspecified Unspecified
5-A-16

Table 5-A.2.4: ERA Inputs for Built-In Bottom-Mount Refrigerator-Freezers (Product 

Class 5-BI)

Built-In Bottom-Mount Refrigerator-Freezer 21 ft3 Baseline

General Data

 Fresh Food Volume (ft3) 13.3

 Freezer Volume (ft3) 7.1

 Total Volume (ft3) 20.4

 Adjusted Volume (ft3) 24.9

 Rated Energy Use (kWh/yr) 562

 Calculated Max. Energy Use (kWh/yr) 573

 Rated Energy Use Below Maximum (%) 1.9

Cabinet Dimensions

 Category (from ERA selection) Bottom-Mount

 Cabinet Height (cm) 172.9

 Cabinet Width (cm) 90.8

 Depth, from Door Flange (cm) 57.2

 Depth, from Door Outer Surface (cm) 61.0

Liner Properties

 Outer Liner Thickness (mm) 1.5

 Outer Liner Conductivity (W/m-C) 44.7

 Inner Liner Thickness (mm) 0.9

 Liner Conductivity (W/m-C) 190

Freezer Cabinet

 Insulation Thickness

 Side Wall (cm) 4.9

 Back Wall (cm) 4.4

 Bottom (cm) 4.2

 Door (cm) 4.6

 Insulation Resistivity 

 Side Wall (m2-C/W-cm) 0.50

 Back Wall (m2-C/W-cm) 0.50

 Bottom (m2-C/W-cm) 0.50

 Door (m2-C/W-cm) 0.50

 Wedge/Flange Dimensions

 Freezer Width (cm) 3.6

 Freezer Wedge Depth (cm) 6.7

 Resistivity (m2-C/W-cm) 0.5

 Heat Paths

 Freezer Gasket Heat Leak (W/m-100C) 9.0

 Freezer Penetration Heat Leak (W) 0.0

Fresh Food Cabinet

 Insulation Thickness 

 Top Wall (cm) 3.6

 Side Wall (cm) 4.9
5-A-17

Built-In Bottom-Mount Refrigerator-Freezer 21 ft3 Baseline

 Back Wall (cm) 4.4

 Door (cm) 4.6

 Insulation Resistivity 

 Top Wall (m2-C/W-cm) 0.50

 Side Wall (m2-C/W-cm) 0.50

 Back Wall (m2-C/W-cm) 0.50

 Door (m2-C/W-cm) 0.50

 Wedge/Flange Dimensions

 Fresh Food Flange Width (cm) 3.6

 Fresh Food Wedge Depth (cm) 6.7

 Resistivity (m2-C/W-cm) 0.5

 Heat Paths

 Fresh Food Gasket Heat Leak (W/m-100C) 9.0

 Fresh Food Cabinet Penetration Heat Leak (W) 0.0

Mullion

 Distance to Top (cm) 102.9

 Thickness w/Liners (cm) 10.1

 Resistivity w/Liners (m2-C/W-cm) 0.50

Air and Cabinet Temperatures 

 Room Air (°C) 32.2

 Freezer Section (°C) -15.0

 Fresh Food Section (°C) 7.2

 Air Under Cabinet (°C) 33.0

 Compressor Compartment ( ̊C) 33.0

 Air Entering Condenser (°C) 32.2

Defrost and Controls Energy

 Defrost Type (Automatic, Manual) Automatic

 Timer Interval (hr) 24

 Heater On-time (min) 10.0

 Defrost Power (W) 484.2

 Other Cycle-Dependent Loads

 Freezer Section (W) 0

 Fresh Food Section (W) 0

 Outside Cabinet (W) 0

 Constant Electrical Loads

 Freezer Section (W) 0

 Fresh Food Section (W) 0

 Outside Cabinet (W) 1.3

Liquid Refrigerant Line Anti-Sweat

 Freezer Door Flange

 Cycle Average Energy (W) 3.7

 Fraction Heat Leak (0-1) 0.5

 Fresh Food Door Flange
5-A-18

Built-In Bottom-Mount Refrigerator-Freezer 21 ft3 Baseline

 Cycle Average Energy (W) 2.2

 Fraction Heat Leak (0-1) 0.5

 Mullion

 Cycle Average Energy (W) 1.7

 Heat Leak to Freezer (0-1) 0.5

 Heat Leak to Fresh Food (0-1) 0.3

Cycle Parameters

 Cycle Type Dual loop

 Cycling Losses YES

 Cycles/hr 1.5

 Refrigerant R-134a

Evaporator Design (Freezer)

 Exit Superheat (°C) 0.8

 Fin Type (plain, wavy, herringbone) Plain

 Fan Motor Type (Shaded Pole, AC-Input BLDC, DCInput BLDC)AC-Input 

BLDC

 Fan Power (W) 4

 Air Flow Rate (Liter/s) 16.5

 Tube Characteristics

 Width of Tube Row 46.4

 Tube OD (mm) 9.5

 Tube Wall Thickness (mm) 0.64

 # of Tubes Normal to Airflow 2

 Normal Tube Pitch (cm) 1.8

 # of Tubes Deep 14

 Tube Pitch (cm) 1.3

 Fin Characteristics

 Fin Thickness (mm) 0.19

 Fin Pitch (mm) 4.2

 Fin Conductivity (W/m-K) 190

 Fraction Finned (0-1) 0.88

Evaporator Design (Fresh Food)

 Exit Superheat (°C) 0.8

 Fin Type (plain, wavy, herringbone) Plain

 Fan Motor Type (Shaded Pole, AC-Input BLDC, DCInput BLDC)AC-Input 

BLDC

 Fan Power (W) 3.1

 Air Flow Rate (Liter/s) 14.2

 Tube Characteristics

 Width of Tube Row 50.6

 Tube OD (mm) 9.3

 Tube Wall Thickness (mm) 0.64

 # of Tubes Deep 2
5-A-19

Built-In Bottom-Mount Refrigerator-Freezer 21 ft3 Baseline

 Tube Pitch (cm) 1.1

 # of Tubes Normal to Airflow 9

 Normal Tube Pitch (cm) 1.9

 Fin Characteristics

 Fin Thickness (mm) 0.13

 Fin Pitch (mm) 5.1

 Fin Conductivity (W/m-K) 190

 Fraction Finned (0-1) 0.90

Condenser Design (Freezer)

 Exit Subcooling (°C) 0.7

 Configuration (Static, Hot-wall, Tube & Fin, 

Microchannel) Tube & Fin

 Air-side Configuration (wire, plain, smooth wavy, 

herringbone, slit, louver) Plain

 Fan Motor Type (Shaded Pole, AC-Input BLDC, DCInput BLDC) Shaded Pole

 Fan Power in Fan Energy Calculations (W) 61

 Air Flow Rate (Liter/s) 18.9

 Tube Characteristics

 Width of Tube Row 34.0

 Tube OD (mm) 6.4

 Tube Wall Thickness (mm) 0.46

 # of Tubes Normal to Airflow 8

 Normal Tube Pitch (cm) 1.3

 # of Tubes along Airflow 2

 Along Tube Pitch (cm) 2.2

 Fraction Air through Exchanger (0-1) 1

 Fin Characteristics

 Fin Thickness (mm) 0.19

 Fin Pitch (mm) 3.6

 Fin Conductivity (W/m-K) 190

 Fraction Finned (0-1) 0.86

Condenser Design (Fresh Food)

 Exit Subcooling (°C) 0.7

 Configuration (Static, Hot-wall, Tube & Fin, 

Microchannel) Tube & Fin

 Air-side Configuration (wire, plain, smooth wavy, 

herringbone, slit, louver) Plain

 Fan Motor Type (Shaded Pole, AC-Input BLDC, DCInput BLDC) Shaded Pole

 Fan Power in Fan Energy Calculations (W) 61

 Air Flow Rate (Liter/s) 18.9

 Tube Characteristics
5-A-20

Built-In Bottom-Mount Refrigerator-Freezer 21 ft3 Baseline

 Width of Tube Row 34.0

 Tube OD (mm) 6.4

 Tube Wall Thickness (mm) 0.46

 # of Tubes Normal to Airflow 8

 Normal Tube Pitch (cm) 1.3

 # of Tubes along Airflow 2

 Along Tube Pitch (cm) 2.2

 Fraction Air through Exchanger (0-1) 1

 Fin Characteristics

 Fin Thickness (mm) 0.19

 Fin Pitch (mm) 3.6

 Fin Conductivity (W/m-K) 190

 Fraction Finned (0-1) 0.86

Compressor Data (Freezer)

 Manufacturer Embraco

 Model EGU70HLC

 Capacity Multiplier 1.0

 Power Multiplier 1.0

 Speed Multiplier 1.0

Compressor Data (Fresh Food)

 Manufacturer Embraco

 Model EMT30HSC

 Capacity Multiplier 1.0

 Power Multiplier 1.0

 Speed Multiplier 1.0

Interchangers

 Effectiveness (0-1, Freezer) 0.95

 Effectiveness (0-1, Fresh Food) 0.95

 Compressor Shell Inlet Temperature (°C) Calculated 1

This product has a single condenser with a separate circuit for each of the two refrigeration 

systems. The single fan operates when one or two of the compressors are operating. The 

condenser fan power was set to 0W for each of these systems in ERA, and a post-processing 

spreadsheet was used to calculate fan energy use with consideration of the overlap of the two 

system on-cycles.
5-A-21

Table 5-A.2.5: ERA Inputs for Bottom-Mount Refrigerator-Freezers w/TTD Ice (Product 

Class 5A)

Bottom-Mount Refrigerator-Freezers w/TTD Ice 25 ft3

General Data

 Fresh Food Volume (ft3) 17.6

 Freezer Volume (ft3) 7.1

 Total Volume (ft3) 24.7

 Adjusted Volume (ft3) 29.2

 Rated Energy Use (kWh/yr) 547

 Calculated Max. Energy Use (kWh/yr) 685

 % Rated Energy Use Below Maximum (%) 20.0

Cabinet Dimensions

 Category Bottom-Mount

 Cabinet Height (cm) 171.1

 Cabinet Width (cm) 91.4

 Depth, from Door Flange (cm) 68.6

 Depth, from Door Outer Surface (cm) 76.2

Liner Properties

 Outer Liner Thickness (mm) 0.5

 Outer Liner Conductivity (W/m-C) 44.7

 Inner Liner Thickness (mm) 1.4

 Liner Conductivity (W/m-C) 0.16

Compressor Compartment Dimensions

 Top Depth (cm) 13.5

 Bottom Depth (cm) 26.7

 Height (cm) 24.5

 Wall (vertical) (cm) 6.8

 Wall (horizontal) (cm) 6.8

Freezer Cabinet

 Insulation Thickness

 Side Wall (cm) 6.8

 Back Wall (cm) 7.9

 Bottom (cm) 6.8

 Door (cm) 7.1

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.48d

 Wedge/Flange Dimensions

 Freezer Flange Width (cm) 4.5

 Freezer Wedge Depth (cm) 2.5

 Resistivity (m2-C/W-cm) 0.5

Heat Paths

 Freezer Gasket Heat Leak (W/m-100C) 8e

 

d Product has insulation using cyclopentane blowing agent.
5-A-22

Bottom-Mount Refrigerator-Freezers w/TTD Ice 25 ft3

 Freezer Cabinet Penetration Heat Leak (W) 0

Fresh Food Cabinet

 Insulation Thickness 

 Top Wall (cm) 5.2

 Side Wall (cm) 5.1

 Back Wall (cm) 4.7

 Door (cm) 5.1

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.48

 Wedge/Flange Dimensions

 Fresh Food Flange Width (cm) 4.8

 Fresh Food Wedge Depth (cm) 11.4

 Resistivity (m2-C/W-cm) 0.5

 Heat Paths

 Fresh Food Gasket Heat Leak (W/m-100C) 8f

 Fresh Food Cabinet Penetration Heat Leak (W) 3.0

Mullion

 Distance to Top (cm) 102.2

 Thickness w/Liners (cm) 5.1

 Resistivity w/Liners (m2-C/W-cm) 0.47

Air and Cabinet Temperatures 

 Room Air (°C) 32.2

 Freezer Section (°C) -15.0

 Fresh Food Section (°C) 7.2

 Air Under Cabinet (°C) 35.0

 Compressor Compartment ( ̊C) 35.0

 Air Entering Condenser (°C) 32.2

Defrost and Controls Energy

 Defrost Type (Automatic, Manual) Automatic

 Timer Interval (Hr) 38.0

 Heater On-Time (Min) 12.7

 Defrost Power (W) 396

 Other Cycle-Dependent Loads

 Freezer Section (W) 0

 Fresh Food Section (W) 0

 Outside Cabinet (W) 0

 Constant Electrical Loads

 Freezer Section (W) 0

 Fresh Food Section (W) 0

 

e The checkbox indicating that the product has two drawers is checked.

f The checkbox indicating that the product has French doors is checked.
5-A-23

Bottom-Mount Refrigerator-Freezers w/TTD Ice 25 ft3

 Outside Cabinet (W) 4.0

Liquid Refrigerant Line Anti-Sweat

 Freezer Door Flange

 Cycle Average Energy (W) 3.8

 Fraction Heat Leak (0-1) 0.5

 Fresh Food Door Flange

 Cycle Average Energy (W) 0

 Fraction Heat Leak (0-1) 0

 Mullion

 Cycle Average Energy (W) 1.3

 Heat Leak to Freezer (0-1) .5

 Heat Leak to Fresh Food (0-1) .25

Evaporator Design

 Exit Superheat (°C) 0.8

 Fin Type (plain, wavy, herringbone) Plain

 Fan Motor Type (Shaded Pole, AC-Input BLDC, DC-Input BLDC) DC-Input BLDC

 Fan Power (W) 1.5

 Air Flow Rate (Liter/s) 16.0

 Tube Characteristics

 Width of Tube Row 70.5g

 Tube OD (mm) 7.9

 Tube Wall Thickness (mm) 0.7

 # of Tubes Deep 4.5g

 Tube Pitch (cm) 3.8

 # of Tubes Normal to Airflow 4

 Normal Tube Pitch (cm) 2.5

 Fin Characteristics

 Fin Thickness (mm) 0.15

 Fin Pitch (mm) 5.1

 Fin Conductivity (W/m-K) 190

 Fraction Finned (0-1) 0.90

Condenser Design

 Exit Subcooling (°C) 0.7

 Configuration (Static, Hot-wall, Tube & Fin, Microchannel) Tube & Fin

 Air-side Configuration (wire, plain, smooth wavy, herringbone, slit, 

louver) Wire

 Fan Motor Type (Shaded Pole, AC-Input BLDC, DC-Input BLDC) DC-Input BLDC

 Fan Power (W) 1.56

 Air Flow Rate (Liter/s) 24.0

 Tube Characteristics

 

g Number of tubes in the air flow direction alternate 4 and 5, averaging 4.5. ERA analysis was conducted by 

selecting 4 rows deep and increasing the tube row width to 79.3 cm to compensate for the missing tubes.
5-A-24

Bottom-Mount Refrigerator-Freezers w/TTD Ice 25 ft3

 Airflow Direction (W, L, H) W

 Tube OD (mm) 5.0

 Tube Wall Thickness (mm) 0.64

 Length of Tube in “L” Direction (cm) 15.2

 # of Tubes in H Direction 12

 Tube Pitch (cm) 2.2

 # of Tubes in W Direction 10

 Tube Pitch (cm) 2.5

 Fraction Air through Exchanger (0-1) 0.9

 Fin Characteristics

 Wire OD (mm) 1.4

 # of Wires on 1-side 22

 Wire Mounting (1-side, 2-sides) 2-sides

 Wire Fin Pitch (mm) 6.4

 Wire Length (cm) 18.0

 Wire Conductivity (W/m-K) 44.7

Compressor Data

 Manufacturer Embraco

 Model # EGX90HLC_BM25

 Cycles per Hour 1.0

Interchanger

 Effectiveness (0-1) 0.95
5-A-25

Table 5-A.2.6: ERA Inputs for Side-Mount Refrigerator-Freezers (Product Classes 4 and 

7)

Side-Mount Refrigerator-Freezers PC7 26 ft3 PC7 26 ft3 E* PC4 22 ft3

General Data

 Fresh Food Volume (ft3) 16.5 16.5 14.8

 Freezer Volume (ft3) 9.5 9.5 7.0

 Total Volume (ft3) 26.0 26.0

 Adjusted Volume (ft3) 32.0 32.0 26.3

 Rated Energy Use (ft3) 728 582 635

 Calculated Max. Energy Use (kWh/yr) 729 729 637

 % Rated Energy Use Below Maximum 

(%) 0.2 20.2 0.3

Cabinet Dimensions

Category Side-Mount Side-Mount Side-Mount

Cabinet Height (cm) 165.9 165.9 162.6

Cabinet Width (cm) 90.2 90.2 85.1

Depth, from Door Flange (cm) 72.0 72.0 69.3

Depth, from Door Outer Surface (cm) 80.3 80.3 77.8

Liner Properties

Outer Shell Thickness (mm) 0.5 1 0.4

Shell Conductivity (W/m-C) 44.7 44.7 44.7

Inner Liner Thickness (mm) 0.5 1 0.4

Liner Conductivity (W/m-C) 0.16 0.16 44.7

Compressor Compartment Dimensions

Top Depth (cm) 15.9 15.9 24.1

Bottom Depth (cm) 27.9 27.9 30.5

Height (cm) 23.5 23.5 25.1

Wall (vertical) (cm) 8.3 8.3 5.8

Wall (horizontal) (cm) 8.3 8.3 5.8

Freezer Cabinet

 Insulation Thickness – Freezer

 Top Wall (cm) 7.2 7.2 6.2

 Side Wall (cm) 5.7 5.7 7.3

 Back Wall (cm) 7.8 7.8 5.7

 Bottom (cm) 8.3 8.3 5.8

 Door (cm) 6.4 6.4 5.7

Insulation Resistivity - Freezer

 All Walls (m2-C/W-cm) 0.50 0.50 0.5

Wedge/Flange Dimensions

 Freezer Wedge Depth (cm) 0.1 0.1 7.0

 Freezer Flange Width (cm) 5.7 5.7 3.8

 Heat Paths

 Fzr Gasket Heat Leak (W/m-100C) 9.0 9.0 9.0

 Fzr Cabinet Penetration Heat Leak (W) 7.0 7.0 8.0
5-A-26

Side-Mount Refrigerator-Freezers PC7 26 ft3 PC7 26 ft3 E* PC4 22 ft3

Fresh Food Cabinet

 Insulation Thickness – Fresh Food

 Top Wall (cm) 4.0 4.0 4.0

 Side Wall (cm) 3.6 3.6 3.8

 Back Wall (cm) 3.6 3.6 4.8

 Bottom (cm) 6.2 6.2 4.7

 Door (cm) 6.4 6.4 5.7

 Insulation Resistivity – Fresh Food

 All Walls (m2-C/W-cm) 0.50 0.50 0.5

 Wedge/Flange Dimensions

 Fresh Food Wedge Depth (cm) 0.1 0.1 11.4

 Fresh Food Flange Width (cm) 3.6 3.6 3.8

 Heat Paths

 FF Gasket Heat Leak (W/m-100C) 9.0 9.0 9.0

 FF Cabinet Penetration Heat Leak (W) 4.0 4.0 5.0

 Mullion

 Distance to Right Side Wall (cm) 49.2 49.2 49.4

 Thickness w/Liners (cm) 3.5 3.5 3.7

 Resistivity w/Liners (m2-C/W-cm) 0.53 0.53 0.52

Air and Cabinet Temperatures 

 Room Air (°C) 32.3 32.2 32.3

 Freezer Section (°C) -15.0 -15.0 -15.0

 Fresh Food Section (°C) 7.2 7.2 7.2

 Air Under Cabinet (°C) 35.0 35.0 35.0

 Compressor Compartment ( ̊C) 35.0 35.0 35.0

 Air Entering Condenser (°C) 33.0 33.0 33.0

Defrost and Controls Energy

Defrost Type (Automatic, Manual) Automatic Automatic Automatic

 Timer Interval (Hr) 24.0 24.0 24

 Heater On-Time (Min) 5.0 5.0 18.0

 Defrost Power (W) 500 500 535

Other Cycle-Dependent Loads

 Freezer Section (W) 0 0 0

 Fresh Food Section (W) 0 0 0

 Outside Cabinet (W) 0 0 0

Constant Electrical Loads

 Freezer Section (W) 0 0 0

 Fresh Food Section (W) 0.5 0.4 0

 Outside Cabinet (W) 0 0 1.3

Electric Anti-Sweat Heat

Freezer Door Flange

 Cycle Average Energy (W) 2.1 2.1 0

 Fraction Heat Leak (0-1) 0.5 0.5 0.5
5-A-27

Side-Mount Refrigerator-Freezers PC7 26 ft3 PC7 26 ft3 E* PC4 22 ft3

Liquid Refrigerant Line Anti-Sweat

Freezer Door Flange

 Cycle Average Energy (W) 3.0 3.0 3.8

 Fraction Heat Leak (0-1) 0.5 0.5 0.5

Fresh Food Door Flange

 Cycle Average Energy (W) 0 0 0

 Fraction Heat Leak (0-1) 0 0 0

Mullion

 Cycle Average Energy (W) 3.0 3.0 1.3

 Heat Leak to Freezer (0-1) 0.5 0.5 0.25

 Heat Leak to Fresh Food (0-1) 0.25 0.25 0.25

Evaporator Design

 Exit Superheat (°C) 4.0 4.0 2.0

 Fin Type (plain, wavy, herringbone) Plain Plain

Specify air-side 

area and heat 

transfer 

 Fan Motor Type (Shaded Pole, ACInput BLDC, DC-Input BLDC) Shaded Pole Shaded Pole DC-Input BLDC

 Fan Power (W) 5.8 5.8 3.3

 Air Flow Rate (Liter/s) 21.3 21.3 21.3

Tube Characteristics

 Width of Tube Row 27.9h 27.9h 24.1

 Tube OD (mm) 7.9 7.9 9.3

 Tube Wall Thickness (mm) 0.7 0.7 0.8

 # of Tubes Deep 7.5h 7.5h 16

 Tube Pitch (cm) 3.8 3.8 2.9

 # of Tubes Normal to Airflow 8 8 2

 Normal Tube Pitch (cm) 1.3 1.3 5.1

Fin Characteristics

 Fin Thickness (mm) 0.2 0.2 0.25

 Fin Pitch (mm) 5.1 5.1 9.5

 Fin Conductivity (W/m-K) 190 190 190

 Fraction Finned (0-1) 0.77 0.77 1

Fin Data (for spine fin only)

 Air-side effective area (m2) NA NA 1.52

 Air-side U-Value (W/m2-C) NA NA 30

Condenser Design i i j

 

h Number of tubes in the air flow direction alternate 7 and 8, averaging 7.5. ERA analysis was conducted by 

selecting 8 rows deep and decreasing the tube row width to 26.2 cm to compensate for the added tubes.

i

Surface areas calculated by the condenser routine were increased by a factor of 2.63 for the 26 ft3 side-mount 

refrigerators to calibrate with test data for condensing temperatures.
5-A-28

Side-Mount Refrigerator-Freezers PC7 26 ft3 PC7 26 ft3 E* PC4 22 ft3

 Exit Subcooling (°C) 0.0 0.0 0.0

 Configuration (Static, Hot-wall, Tube & 

Fin, Microchannel) Tube & Fin Tube & Fin Tube & Fin

 Air-side Configuration (wire, plain, 

smooth wavy, herringbone, slit, louver) Wire Wire Wire

 Fan Motor Type (Shaded Pole, ACInput BLDC, DC-Input BLDC) Shaded Pole AC-Input 

BLDC Shaded Pole

 Fan Power (W) 8.5 3.4 9.1

 Air Flow Rate (Liter/s) 26 26 26

Tube Characteristics

 Airflow Direction (W, L, H) W W H

 Tube OD (mm) 4.8 4.8 4.7

 Tube Wall Thickness (mm) 0.6 0.6 0.63

 Length of Tube in “L” Direction 18.2 18.2 58.0

 # of Tubes in H Direction 9 9 2

 Tube Pitch (cm) 2.3 2.3 2.5

 # of Tubes in W Direction 10 10 10

 Tube Pitch (cm) 2.5 2.5 2.5

Fin Characteristics

 Wire OD (mm) 1.1 1.1 1.3

 # of Wires on 1-side 23 23 111

 Wire Mounting (1-side, 2-sides) 2-sides 2-sides 2-sides

 Wire Fin Pitch (mm) 5.6 5.6 5.2

 Wire Length (cm) 24.1 24.1 23.5

 Wire Conductivity (W/m-K) 44.7 44.7 44.7

 Fraction Air through Exchanger (0-1) 1 1 1

Compressor Data

 Manufacturer Tecumseh Embraco Matsushita

 Model # TSA1374YAS EGX70HLC DC57C84RCU6

 Cycles per Hour 1.12 1.16 0.7

Interchanger

 Effectiveness (0-1) 0.95 0.95 0.85

Component Adjustment Factors

 Condenser UA Multiplier 2.63 2.63 1.4

 

j

Surface area calculated by the condenser routine was increased by a factor of 1.4 for the 22 ft3 side-mount 

refrigerator to calibrate with test data for condensing temperatures.
5-A-29

Table 5-A.2.7: ERA Inputs for Upright Freezers with Automatic Defrost (Product Class 9)

Upright Freezers 14 ft3 Baseline 20 ft3 Baseline 20 ft3 E*

General Data

 Freezer Volume (ft3) 13.7 20.1 20.1

 Adjusted Volume (ft3) 23.7 34.8 34.8

 Rated Energy Use (kWh/yr) 621 745 671

 Calculated Max. Energy Use 

(kWh/yr) 621 758 758

 % Rated Energy Use Below 

Maximum (%) 0.0 1.8 11.5

Cabinet Dimensions

Category Upright Freezer Upright Freezer Upright Freezer

Cabinet Height (cm) 130.2 156.2 156.2

Cabinet Width (cm) 71.3 83.8 83.8

Depth, from Door Flange (cm) 66.7 64.5 64.5

Depth, from Door Outer Surface (cm) 72.4 71.1 71.1

Liner Properties

Outer Liner Thickness (mm) 0.4 0.9 0.9

Outer Liner Conductivity (W/m-C) 44.7 44.7 44.7

Inner Liner Thickness (mm) 0.4 2.2 2.2

Liner Conductivity (W/m-C) 44.7 0.16 0.16

Compressor Compartment 

Compressor Compartment part of 

cabinet? NO NO NO

Insulation

 Insulation Thickness

 Top Wall (cm) 6.4 4.8 4.8

 Side Wall (cm) 6.4 5.7 5.7

 Back Wall (cm) 6.4 5.1 5.1

 Bottom Wall (cm) 6.2 6.2 6.2

 Door Average Thickness (cm) 3.8 7.1 7.1

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.50 0.50 0.50

 Wedge/Flange Dimensions

 Wedge Depth (cm) 9.5 8.9 8.9

 Flange Width (cm) 5.9 4.7 4.7

 Heat Paths

 Gasket Heat Leak (W/m-100C) 12 9 9

 Cabinet Penetration Heat Leak (W) 8 17 17

Air and Cabinet Temperatures 

 Room Air (°C) 32.2 32.2 32.2

 Air Under Cabinet (°C) 35.0 35.5 35.5

 Air Entering Condenser (°C) 32.2 32.2 32.2

 Compressor Compartment ( ̊C) 35.0 35.5 35.5
5-A-30

Upright Freezers 14 ft3 Baseline 20 ft3 Baseline 20 ft3 E*

 Cabinet (°C) -17.8 -17.8 -17.8

Defrost and Controls Energy

Defrost Type (Automatic, Manual) Automatic Automatic Automatic

 Timer Interval (Hr) 12.0 9.0 9.0

 Heater On-Time (Min) 5.1 18.0 18.0

 Defrost Power (W) 425 370 370

Other Cycle-Dependent Loads

 Outside Cabinet (W) 0 0 0

 Cabinet (W) 1.6 0.3 0.3

Constant Electrical Loads

 Outside Cabinet (W) 0 0 0

 Cabinet (W) 0 0 0

Refrigerant Line Anti-Sweat None None None

Evaporator Design

 Exit Superheat 5.0 0.0 0.0

 Fin Type (plain, wavy, herringbone) Plain Plain Plain

 Fan Motor Type (Shaded Pole, ACInput BLDC, DC-Input BLDC) Shaded Pole Shaded Pole AC-Input BLDC

 Fan Power (W) 7.4 11.2 4.5

 Air Flow Rate (Liter/s) 26.0 23.7 23.7

Tube Characteristics

 Width of Tube Row 55.9k 50.2 50.2

 Tube OD (mm) 7.8 8.6 8.6

 Tube Wall Thickness (mm) 0.8 0.9 0.9

 # of Tubes Deep 4.5k 9 9

 Tube Pitch (cm) 3.8 3.2 3.2

 # of Tubes Normal to Airflow 4 2 2

 Normal Tube Pitch (cm) 1.3 2.5 2.5

Fin Characteristics

 Fin Thickness (mm) 0.18 0.24 0.24

 Fin Pitch (mm) 4.6 5.1 5.1

 Fin Conductivity (W/m-K) 190 190 190

 Fraction Finned (0-1) 0.9 0.9 0.9

Condenser Design

 Exit Subcooling (°C) 3 1 1

 Configuration (Static, Hot-wall, 

Tube & Fin, Microchannel) Hot-wall Hot-wall Hot-wall

Design Data

 Total Area (sides) (m2) 2.0 2.1 2.1

 Width, Side Normal to Tubes (cm) 288 333 333

 

k Number of tubes in the air flow direction alternate 4 and 5, averaging 4.5. ERA analysis was conducted by 

selecting 4 rows deep and increasing the tube row width to 62.9 cm to compensate for the missing tubes.
5-A-31

Upright Freezers 14 ft3 Baseline 20 ft3 Baseline 20 ft3 E*

 Number of Legs 26 30 30

 Length of Tubing on Wall (m) 20.3 22.0 22.0

 Tube OD (mm) 4.7 6.4 6.4

 Tube Wall Thickness (mm) 0.8 0.8 0.8

 Thickness of Liner (mm) 0.38 0.9 0.9

 Thermal Conductivity (W/m-K) 44.7 44.7 44.7

 Number of other Hot Walls (0-2) 1 1 1

Second Hotwall (Top)

 Total Area (m2) 0.47 0.52 0.52

 Width, Side Normal to Tubes (cm) 71 84 84

 Number of Legs 7 8 8

 Length of Tubing on Wall (m) 5.4 5.8 5.8

Compressor Data

 Manufacturer Embraco Matsushita Matsushita

 Model # EMY60HER DG73C12RAU6 DG73C12RAU6 

 Cycles per Hour 1.4 1.5 1.5

Interchanger

 Effectiveness (0-1) 0.7 0.98 0.98
5-A-32

Table 5-A.2.8: ERA Inputs for Built-In Upright Freezers (Product Class 9-BI)

Built-In Upright Freezer 21 ft3 E*

General Data

 Upper Compartment Volume (ft3) 13.6

 Lower Compartment Volume (ft3) 7.9

 Total Volume (ft3) 21.5

 Adjusted Volume (ft3) 37.1

 Rated Energy Use (kWh/yr) 613

 Calculated Max. Energy Use (kWh/yr) 787

 Rated Energy Use Below Maximum (%) 22.1

Cabinet Dimensions

 Category (from ERA selection) Bottom-Mount

 Cabinet Height (cm) 172.9

 Cabinet Width (cm) 90.8

 Depth, from Door Flange (cm) 57.2

 Depth, from Door Outer Surface (cm) 61.0

Liner Properties

 Outer Liner Thickness (mm) 1.5

 Outer Liner Conductivity (W/m-C) 44.7

 Inner Liner Thickness (mm) 0.9

 Liner Conductivity (W/m-C) 190

Lower Compartment Cabinet

 Insulation Thickness

 Side Wall (cm) 4.9

 Back Wall (cm) 4.4

 Bottom (cm) 4.2

 Door (cm) 5.2

 Insulation Resistivity

 Side Wall (m2-C/W-cm) 0.73

 Back Wall (m2-C/W-cm) 0.88

 Bottom (m2-C/W-cm) 0.76

 Door (m2-C/W-cm) 0.68

 Wedge/Flange Dimensions

 Lower Compartment Flange Width (cm) 3.6

 Lower Compartment Wedge Depth (cm) 6.7

 Resistivity (m2-C/W-cm) 0.5

Heat Paths

 Lower Compartment Gasket Heat Leak (W/m-100C) 9.0

 Lower Compartment Penetration Heat Leak (W) 0.0

Upper Compartment Cabinet

 Insulation Thickness 

 Top Wall (cm) 3.6

 Side Wall (cm) 4.9

 Back Wall (cm) 4.4
5-A-33

Built-In Upright Freezer 21 ft3 E*

 Door (cm) 3.6

 Insulation Resistivity 

 Top Wall (m2-C/W-cm) 0.50

 Side Wall (m2-C/W-cm) 0.50

 Back Wall (m2-C/W-cm) 0.50

 Door (m2-C/W-cm) 0.87

 Wedge/Flange Dimensions

 Upper Compartment Flange Width (cm) 3.6

 Upper Compartment Wedge Depth (cm) 6.7

 Resistivity (m2-C/W-cm) 0.5

 Heat Paths

 Upper Gasket Heat Leak (W/m-100C) 9.0

 Upper Cabinet Penetration Heat Leak (W) 0.0

Mullion

 Distance to Top (cm) 102.9

 Thickness w/Liners (cm) 10.1

 Resistivity w/Liners (m2-C/W-cm) 0.001

Air and Cabinet Temperatures 

 Room Air (°C) 32.2

 Lower Compartment Section (°C) -17.7

 Upper Compartment Section (°C) -17.8

 Air Under Cabinet (°C) 33.0

 Compressor Compartment ( ̊C) 33.0

 Air Entering Condenser (°C) 32.2

Defrost and Controls Energy

 Defrost Type (Automatic, Manual) Automatic

 Timer Interval (hr) 24

 Heater On-time (min) 10.0

 Defrost Power (W) 762

 Other Cycle-Dependent Loads

 Lower Compartment Section (W) 0

 Upper Compartment Section (W) 0

 Outside Cabinet (W) 0

 Constant Electrical Loads

 Lower Compartment Section (W) 0

 Upper Compartment Section (W) 0

 Outside Cabinet (W) 1.3

Liquid Refrigerant Line Anti-Sweat

 Lower Compartment Door Flange

 Cycle Average Energy (W) 3.7

 Fraction Heat Leak (0-1) 0.5

 Upper Compartment Door Flange

 Cycle Average Energy (W) 3.7
5-A-34

Built-In Upright Freezer 21 ft3 E*

 Fraction Heat Leak (0-1) 0.5

 Mullion

 Cycle Average Energy (W) 2.2

 Heat Leak to Lower Compartment (0-1) 0.4

 Heat Leak to Upper Compartment (0-1) 0.4

Cycle Parameters

 Cycle Type Single 

Evaporator

 Cycling Losses YES

 Cycles/hr 1.5

 Refrigerant R-134a

Evaporator Design

 Exit Superheat (°C) 0.8

 Fin Type (plain, wavy, herringbone) Plain

 Fan Motor Type (Shaded Pole, AC-Input BLDC, DCInput BLDC)AC-Input 

BLDC

 Fan Power (W) 3.1

 Air Flow Rate (Liter/s) 21.2

 Tube Characteristics

 Width of Tube Row 65.1

 Tube OD (mm) 9.5

 Tube Wall Thickness (mm) 0.31

 # of Tubes Normal to Airflow 1

 Normal Tube Pitch (cm) 2.5

 # of Tubes Deep 20

 Tube Pitch (cm) 2.5

 Fin Characteristics

 Fin Thickness (mm) 0.19

 Fin Pitch (mm) 4.2

 Fin Conductivity (W/m-K) 190

 Fraction Finned (0-1) 0.92

Condenser Design

 Exit Subcooling (°C) 0.7

 Configuration (Static, Hot-wall, Tube & Fin, 

Microchannel) Tube & Fin

 Air-side Configuration (wire, plain, smooth wavy, 

herringbone, slit, louver) Plain

 Fan Motor Type (Shaded Pole, AC-Input BLDC, DCInput BLDC)AC-Input 

BLDC

 Fan Power (W) 4

 Air Flow Rate (Liter/s) 37.8

 Tube Characteristics

 Width of Tube Row 46.2
5-A-35

Built-In Upright Freezer 21 ft3 E*

 Tube OD (mm) 6.4

 Tube Wall Thickness (mm) 0.46

 # of Tubes Normal to Airflow 8

 Normal Tube Pitch (cm) 1.3

 # of Tubes along Airflow 2

 Along Tube Pitch (cm) 2.2

 Fraction Air through Exchanger (0-1) 1

 Fin Characteristics

 Fin Thickness (mm) 0.19

 Fin Pitch (mm) 3.6

 Fin Conductivity (W/m-K) 190

 Fraction Finned (0-1) 0.87

Compressor Data

 Manufacturer Embraco

 Model EGX90HLC

 Capacity Multiplier 1.0

 Power Multiplier 1.0

 Speed Multiplier 1.0

Interchangers

 Effectiveness (0-1) 0.95

 Compressor Shell Inlet Temperature (°C) Calculated
5-A-36

Table 5-A.2.9: ERA Inputs for Chest Freezers with Manual Defrost (Product Class 10)

Chest Freezers 15 ft3 Baseline 15ft3 E* 20 ft3 Baseline

General Data

 Freezer Volume (ft3) 14.8 14.8 19.9

 Adjusted Volume (ft3) 25.6 25.6 34.4 

 Rated Energy Use (kWh/yr) 394 354 480

 Calculated Max. Energy Use (kWh/yr) 397 397 484

 Rated Energy Use Below Maximum (%) 0.7 10.8 0.8

Cabinet Dimensions

 Category (from ERA selection) Chest Freezer Chest Freezer Chest Freezer

 Cabinet Height (cm) 116.8 116.8 155.9

 Cabinet Width (cm) 68.6 68.6 69.9

 Depth, from Door Flange (cm) 81.1 81.1 81.6

 Depth, from Door Outer Surface (cm) 86.8 86.8 87.0

Liner Properties

 Outer Liner Thickness (mm) 0.5 0.5 0.5

 Outer Liner Conductivity (W/m-C) 44.7 44.7 44.7

 Inner Liner Thickness (mm) 1.3 1.3 0.4

 Liner Conductivity (W/m-C) 44.7 44.7 44.7

Compressor Compartment Dimensionsl

 Height (cm) 27.9 27.9 22.9

 Depth (cm) 9.1 9.1 22.2

 Fractional width of compartment (cm) 1 1 1

 Top Wall Insulation Thickness (cm) 6.9 6.9 7.7

 Front Wall Insulation Thickness (cm) 5.1 5.1 7.7

Insulation Thickness

 Side Wall (cm) 6.6 6.6 6.7

 Bottom (cm) 6.4 6.4 7.0

 Door (cm) 4.8 4.8 5.1

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.5 0.5 0.5

 Door (m2-C/W-cm) 0.5 0.5 0.33

 Wedge/Flange Dimensions

 Wedge Depth (cm) 1.3 1.3 1.0

 Flange Width (cm) 4.6 4.6 5.4

 Wedge Depth (cm) 1.3 1.3 1.0

 Resistivity (m2-C/W-cm) 0.5 0.5 0.5

Heat Paths

 Gasket Heat Leak (W/m-100C) 9 9 9

 Cabinet Penetration Heat Leak (W) 0.0 0.0 6.5

Air and Cabinet Temperatures 

 

l

Windows ERA allows incorporation of the compressor compartment either into the long or the short wall. DOS 

ERA allowed incorporation only into the short wall, so the short wall option should be entered for Windows ERA.
5-A-37

Chest Freezers 15 ft3 Baseline 15ft3 E* 20 ft3 Baseline

 Room Air (°C) 32.2 32.2 32.2

 Air Under Cabinet (°C) 38.0 38.0 36.0

 Air Entering Condenser (°C) 32.2 32.2 33.0

 Compressor Compartment (°C) 38.0 38.0 36.0

 Cabinet (°C) -17.8 -17.8 -17.8

Defrost and Controls Energy

 Defrost Type (Automatic, Manual) Manual Manual Manual

 Other Cycle-Dependent Loads

 Outside Cabinet (W) 0 0 0

 Inside Cabinet (W) 0 0 0

 Constant Electrical Loads

 Outside Cabinet (W) 0.4 0.4 0.1

 Inside Cabinet (W) 0 0 0

Refrigerant Line Anti-Sweat None None None

Evaporator Design (Cold Wall)

 Exit Superheat 0.5 0.5 0.5

 Tube OD (mm) 6.4 6.4 7.9

 Tube Wall Thickness (mm) 0.8 0.8 0.8

 Side Walls (perimeter)

 Total Area of Side Walls (m2) 1.57 1.57 2.73

 Number of Tube Legs 9 9 9

 Width Normal to Tubes 49.1 49.1 73

 Liner Thickness (mm) 1.3 1.3 0.4

 Liner Conductivity (W/mK) 44.7 44.7 44.7

 Bottom Surface

 Area of Bottom Surface (m2) 0.17 0.17 0.3

 Number of Tube Legs 3 3 2

 Width Normal to Tubes 16.4 16.4 15

Condenser Design

 Exit Subcooling (°C) 0.5 0.5 0.5

 Configuration Hot-wall Hot-wall Hot-wall

 Total Area (m2) 2.0 2.0 2.6

 Width of Side Normal to Tubes (cm) 53.3 53.3 50.6

 Number of Legs 6 6 6

 Length of Tubing on Wall (m) 22.3 22.3 32.2

 Tube OD (mm) 4.8 4.8 4.8

 Tube Wall Thickness (mm) 0.8 0.8 0.8

 Thickness of Liner (mm) 0.5 0.5 0.5

 Thermal Conductivity (W/m-K) 44.7 44.7 44.7

 Number of other Hot Walls (0-2) 0 0 0

 Second Hotwall None None None

Compressor Data

 Manufacturer Matsushita Matsushita Matsushita
5-A-38

Chest Freezers 15 ft3 Baseline 15ft3 E* 20 ft3 Baseline

 Model # SF51C97RAU6 DG57C84RAU6 DGH66C94RAU

 Cycles per Hour 1.0 1.0 1.0

Interchanger

 Effectiveness (0-1) 0.9 0.9 0.7
5-A-39

Table 5-A.2.10: ERA Inputs for Compact Refrigerators (Product Class 11)

Compact Refrigerators 4 ft3 Baseline 4 ft3 E* 1.7 ft3

General Data

 Fresh Food Volume (ft3) 3.3 3.65 1.5

 Freezer Volume (ft3) 0.7m 0.44 0.2

 Total Volume (ft3) 4.0 4.1 1.7

 Adjusted Volume (ft3) 4.3 4.3 1.7n

 Rated Energy Use (kWh/yr) 340 270 296

 Calculated Max. Energy Use (kWh/yr) 345 345 317

 Rated Energy Use Below Maximum (%) 1.5 22 6.8

Cabinet Dimensions

 Category Single Door 

w/ Ice Box

Single Door 

w/ Ice Box

Single Door 

w/ Ice Box

 Cabinet Height (cm) 83.5 83.8 47.0

 Cabinet Width (cm) 47.3 49.5 44.5

 Depth, from Door Flange (cm) 40.4 45.6 40.6

 Depth, from Door Outer Surface (cm) 44.5 50.2 44.8

Liner Properties

 Outer Liner Thickness (mm) 0.8 0.5 0.4

 Outer Liner Conductivity (W/m-C) 44.7 44.7 44.7

 Inner Liner Thickness (mm) 1.3 1.1 1.3

 Liner Conductivity (W/m-C) 0.16 0.16 0.16

Compressor Compartment Dimensions

 Height (cm) 21.6 20.3 19.1

 Horizontal Wall Thickness (cm) 3.4 4.3 3.8

 Top Depth (cm) 16.2 12.7 13.0

 Vertical Wall Thickness (cm) 3.3 3.0 2.8

 Bottom Depth (cm) 16.2 12.7 13.0

Insulation Thickness – Fresh Food

 Top Wall (cm) 2.5 4.1 3.4

 Side Wall (cm) 2.7 4.1 3.4

 Back Wall (cm) 3.3 5.8 3.5

 Bottom (cm) 2.5 4.8 3.1

 Door (cm) 2.8 4.3 3.3

Insulation Resistivity – Fresh Food

 All Walls (m2-C/W-cm) 0.50 0.50 0.50

Wedge/Flange Dimensions

 Fresh Food Flange Width (cm) 2.3 3.3 2.5

 Fresh Food Wedge Depth (cm) 0 0 0.6

 

m The rated freezer volume is 0.7 ft3 as indicated, but the volume based on observed freezer dimensions is 0.4 ft3

n This product is classified as an all-refrigerator for testing and rating purposes, since its freezer compartment is less 

than 0.5 ft3 in volume. It is not clear wheter the 4 ft3 E* product was also rated as an all-refrigerator based on 

available data. DOE analyzed both 4 ft3 products as basic refrigerators and the 1.7 ft3 product as an all-refrigerator.
5-A-40

Compact Refrigerators 4 ft3 Baseline 4 ft3 E* 1.7 ft3

 Resistivity (m2-C/W-cm) 0.5 0.5 0.5

Heat Paths

 Gasket Heat Leak (W/m-100C) 12.0 9.0 12.0

 Cabinet Penetration Heat Leak (W) 0 0 2.5

Air and Cabinet Temperatures 

 Room Air (°C) 32.2 32.2 32.2

 Freezer Section (°C) -9.4 -9.4 -3.9

 Fresh Food Section (°C) 7.2 7.2 3.3

 Air Under Cabinet (°C) 35.0 36.6 35.0

 Compressor Compartment (°C) 35.0 36.6 35.0

 Air Entering Condenser (°C) 32.2 32.2 32.2

Defrost and Controls Energy

 Defrost Type (Manual, Cycle) Manual Manual Manual

 Cycle-Dependent Loads

 Inside Cabinet (W) 0 0 0

 Outside Cabinet (W) 0 0 0

 Constant Electrical Loads

 Inside Cabinet (W) 0 0 0

 Outside Cabinet (W) 0 0 0

Anti-Sweat Heat None None None

Evaporator Design

 Exit Superheat (°C) 0.5 0.1 2.0

 Tube Height (mm)

 Width (mm)

 Hydraulic Diameter (mm)

4.4

9.5

6.1

4.7

9.5

6.3

4.3

9.5

5.9

 Refrigerant Tube Length (m) 6.7 6.1 3.1

 Number of Legs 11 10 8

 Freezer Surfaces: Present (Y/N), Spacing 

to Cabinet Wall (cm)

 Top N N N

 Left Y 1.4 Y 1.6 Y 15

 Right Y 1.4 Y 1.6 Y 1.3

 Freezer Box Dimensions

 Width (cm) 38.7 38.4 21.0

 Height (cm) 11.4 12.7 8.9

 Depth (cm) 25.4 24.8 21.0

 Inner Door (Y or N) Y Y Y

Condenser Design

 Exit Subcooling (°C) 1.0 1.0 0.5

 Heat Transfer Type (Static, Hot-wall, 

Tube & Fin, Microchannel) Static Static Hot-wall

 Static Condenser Details

 Fin Type Wire Wire NA
5-A-41

Compact Refrigerators 4 ft3 Baseline 4 ft3 E* 1.7 ft3

 Tube OD (mm) 4.8 4.8 NA

 Tube Wall Thickness (mm) 0.6 0.6 NA

 Number of Tube Rows 9 9 NA

 Tube Pitch (mm) 6.0 6.0 NA

 Width of Tube Row (cm) 43.2 43.2 NA

 Wire OD (mm) 1.5 1.5 NA

 Wire Length (cm) 60.3 60.3 NA

 # of Wires 98 98 NA

 Wire Conductivity (W/m-K) 44.7 44.7 NA

 Hot Wall Condenser Details

 First Hot Wall (sides)

 Total Area of Side Panels (m2) NA NA 0.33

 Width of Side Normal to Tubes (cm) NA NA 94.0

 Number of Legs NA NA 16

 Length of Tubing on Wall (m) NA NA 6.0

 Tube OD (cm) NA NA 3.9

 Tube Wall (mm) NA NA 0.76

 Liner Thickness (mm) NA NA 0.38

 Thermal Conductivity (W/mK) NA NA 44.7

 Second Hot Wall (top)

 Total Area (m2) NA NA 0.10

 Width Normal to Tubes (cm) NA NA 23.5

 Number of Legs NA NA 4

 Length of Tubing on Wall (m) NA NA 1.7

Compressor Data

 Manufacturer ZEL LG Huayi 

 Model # GVT44AD NSA36LACG AES25DS

 Cycles per Hour 4.0 5.0 3.0

Interchanger

 Effectiveness (0-1) 0.8 0.98 0.7
5-A-42

Table 5-A.2.11: ERA Inputs for Compact Chest Freezers (Product Class 18)

Compact Chest Freezers 3.4 ft3 7.0 ft3, #1 7.0 ft3, #2

General Data

 Freezer Volume (ft3) 3.4 7.0 7.0

 Adjusted Volume (ft3) 5.9 12.1 12.1

 Rated Energy Use (kWh/yr) 213 277 276

 Calculated Max. Energy Use (kWh/yr) 213 279 279

 Rated Energy Use Below Maximum (%) 0 0.6 0.9

Cabinet Dimensions

 Category Chest Freezer Chest Freezer Chest Freezer

 Cabinet Length (cm) 53.3 92.7 94.0

 Cabinet Width (cm) 58.4 51.8 58.4

 Depth, from Door Flange (cm) 76.2 74.6 73.3

 Depth, from Door Outer Surface (cm) 81.3 80.0 78.7

Liner Properties

 Outer Liner Thickness (mm) 0.5 0.6 0.9

 Outer Liner Conductivity (W/m-C) 44.7 44.7 44.7

 Inner Liner Thickness (mm) 0.4 0.4 1.0

 Liner Conductivity (W/m-C) 190 190 190

Compressor Compartment Dimensionso

 Height (cm) 21.0 28.6 22.9

 Depth (cm) 19.7 18.1 22.9

 Fractional width of compartment (0-1) 1 1 1

 Top Wall Insulation Thickness (cm) 6.6 7.0 6.4

 Front Wall Insulation Thickness (cm) 6.4 7.0 7.3

 Location Short Wall Short Wall Short Wall

Insulation Thickness – Freezer

 Side Wall (cm) 6.7 6.0 6.4

 Bottom Wall (cm) 6.3 5.1 7.3

 Door (cm) 5.8 6.4 5.5

Insulation Resistivity – Freezer

 All Walls (m2-C/W-cm) 0.5 0.5 0.53

Wedge/Flange Dimensions

 Wedge Depth (cm) 1.0 1.0 1.9

 Flange Width (cm) 3.8 4.0 4.4

 Heat Paths

 Gasket Heat Leak (W/m-100C) 7.5 7.5 7.5

 Cabinet Penetration Heat Leak (W) 0 0 0

Air and Cabinet Temperatures 

 Room Air (°C) 32.2 32.2 32.2

 Air Under Cabinet (°C) 35.0 35.0 35.0

 

o Windows ERA allows incorporation of the compressor compartment either into the long or the short wall. DOS 

ERA allowed incorporation only into the short wall, so the short wall option should be entered for Windows ERA.
5-A-43

Compact Chest Freezers 3.4 ft3 7.0 ft3, #1 7.0 ft3, #2

 Air Entering Condenser (°C) 32.2 32.2 32.2

 Compressor Compartment (°C) 35.0 35.0 35.0

 Cabinet Setpoint (°C) -17.8 -17.8 -17.8

Defrost and Controls Energy

 Defrost Type (Manual, Auto) Manual Manual Manual

Cycle-Dependent Loads

 Inside Cabinet (W) 0 0 0

 Outside Cabinet (W) 0 0 0

Constant Electrical Loads

 Inside Cabinet (W) 0 0 0

 Outside Cabinet (W) 0.4 0.2 0.1

Anti-Sweat Heat None None None

Evaporator Design

 Exit Superheat (°C) 0.5 0.5 0.0

 Tube OD (mm) 8.0 7.6 6.4

 Tube Wall Thickness (mm) 0.6 0.6 0.6

 Liner Thickness (mm) 0.4 0.4 1.0

 Liner Conductivity (W/m-K) 190 190 190

 Total Area of Side Walls (m2) 1.1 1.43 1.5

 Number of Legs 10 9 12

 Width Normal to Tubes (cm) 68.3 72 64.8

Condenser Design

 Exit Subcooling (°C) 0.5 0.5 0.0

 Heat Transfer Type (Static, Hot-wall, 

Tube & Fin, Microchannel) Static Hot-wall Hot-wall

 Static Condenser Details

 Fin Type Wire NA NA

 Tube OD (mm) 6.0 NA NA

 Tube Wall Thickness (mm) 0.64 NA NA

 Number of Tube Rows 14 NA NA

 Tube Pitch (mm) 4.6 NA NA

 Width of Tube Row (cm) 47.0 NA NA

 Wire OD (mm) 1.4 NA NA

 Wire Length (cm) 64.5 NA NA

 # of Wires 110 NA NA

 Wire Conductivity (W/m-K) 44.7 NA NA

 Hot Wall Condenser Details

 Total Area of Side Panels (m2) NA 1.5 1.72

 Width of Side Normal to Tubes (cm) NA 53.3 241

 Number of Legs NA 7 32

 Length of Tubing on Wall (m) NA 20.2 19.6

 Tube OD (mm) NA 4.6 3.9

 Tube Wall Thickness (mm) NA 0.6 0.5
5-A-44

Compact Chest Freezers 3.4 ft3 7.0 ft3, #1 7.0 ft3, #2

 Liner Thickness (mm) NA 0.64 0.9

 Thermal Conductivity (W/mK) NA 44.7 44.7

Compressor Data

 Manufacturer Jiangsu Baixuep Danfoss ZEL

 Model # QDH3511G TTE4.6GFK GVY44AD

 Cycles per Hour 2.25 1.3 2.0

Interchanger

 Effectiveness (0-1) 0.95 0.95 0.95

 

p Jiangsu Baixue Electric Appliances Co. Ltd.
5-A-45

5-A.3 INCREMENTAL COST DETAIL

The tables in this section identify the groups of design options and their associated costs 

for all analyzed efficiency levels for the reverse-engineering units for which the full incremental 

cost analysis was conducted.
5-A-46

Table 5-A.3.1: Incremental Cost Detail for 16 ft3 Top-Mount Refrigerator-Freezer (Product Class 3)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10%

Increase Condenser Size by 

100% $8.46 $0.00 $0.00 $0.00 $2.20 $10.66 $20.44 $20.44

Increase Compressor EER from 

5.55 to 6.1 $7.76 $0.00 $0.00 $0.00 $2.02 $9.78

15%

Increase Compressor EER from 

6.1 to 6.26 $3.00 $0.00 $0.00 $0.00 $0.78 $3.78 $9.20 $29.64

Brushless DC Condenser Fan 

Motor $4.30 $0.00 $0.00 $0.00 $1.12 $5.42

20%

Increase Evaporator Size by 

14% $0.84 $0.00 $0.00 $0.00 $0.22 $1.06

$95.85 $125.50 Adaptive Defrost $8.00 $0.00 $0.00 $0.00 $2.08 $10.08

Variable Speed Compressor $67.23 $0.00 $0.00 $0.00 $17.48 $84.71

25% 12.2 sqft VIP in FZR Cabinet $39.92 $4.17 $5.16 $12.80 $62.05 $62.05 $187.54

30% 2.9 sqft VIP in FZR Door $9.50 $0.42 $1.16 $2.88 $13.96

7.1 sqft VIP in FF Door $23.08 $0.42 $2.75 $6.82 $33.07 $82.58 $270.12

6.7 sqft VIP in FF Cabinet $22.00 $3.25 $2.96 $7.34 $35.55

30.6% 1.9 sqft more VIP in FF Cabinet $6.19 $0.91 $0.83 $2.06 $9.99 $9.99 $280.12
5-A-47

Table 5-A.3.2: Incremental Cost Detail for 21 ft3 Top-Mount Refrigerator-Freezer (Product Class 3)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10% Increase Compressor EER from 

4.92 to 5.57 $2.52 $0.00 $0.00 $0.00 $0.66 $3.18 $3.18 $3.18

15% Increase Compressor EER from 

5.57 to 5.96 $5.27 $0.00 $0.00 $0.00 $1.37 $6.63 $6.63 $9.81

20%

Increase Compressor EER from 

5.94 to 6.08 $2.38 $0.00 $0.00 $0.00 $0.62 $3.00

Increase Evaporator Size by $10.95 $20.76

25% $2.01 $0.00 $0.00 $0.00 $0.52 $2.53

Brushless DC Condenser Fan 

Motor $4.30 $0.00 $0.00 $0.00 $1.12 $5.42

25% Brushless DC Evaporator Fan 

Motor $4.10 $0.00 $0.00 $0.00 $1.07 $5.17 $5.17 $25.92

30% Adaptive Defrost $8.00 $0.00 $0.00 $0.00 $2.08 $10.08

3.6 sqft VIP in FZR Door $11.73 $0.42 $1.42 $3.53 $17.09 $64.87 $90.80

7.6 sqft VIP in FZR Cabinet $24.82 $1.97 $3.13 $7.78 $37.70

35.5% Remove 0.9 sqft VIP FZR 

Cabinet -$2.79 -$0.22 -$0.35 -$0.87 -$4.23 $81.24 $172.03

Variable Speed Compressor $67.84 $0.00 $0.00 $0.00 $17.64 $85.47

40.5% 7.6 sqft VIP in FZR Cabinet $18.73 $1.49 $2.37 $5.87 $28.45

8.5 sqft VIP in FF Door $27.76 $0.42 $3.30 $8.18 $39.65 $120.24 $292.27

10.9 sqft VIP in FF Cabinet $35.56 $1.48 $4.33 $10.76 $52.13
5-A-48

Table 5-A.3.3: Incremental Cost Detail for 21 ft3 Built-in All-Refrigerator (Product Class 3A-BI)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10%

Decrease Both Compressor 

Capacities (same EER) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

10% Increase to Condenser Area $1.00 $0.00 $0.00 $0.00 $0.40 $1.40 $7.14 $7.14

BLDC Evaporator Fan Upper 

Evaporator $4.10 $0.00 $0.00 $0.00 $1.64 $5.74

15%

BLDC Evaporator Fan Lower 

Evaporator $4.10 $0.00 $0.00 $0.00 $1.64 $5.74 $11.76 $18.90

BLDC Condenser Fan $4.30 $0.00 $0.00 $0.00 $1.72 $ 6.02

20% VIP--Upper Door $30.80 $0.42 $3.65 $13.95 $48.82 $108.20 $127.10 VIP--Lower Cabinet $35.49 $2.48 $4.44 $16.97 $59.38

25%

VIP--Lower Cabinet $24.20 $1.69 $3.03 $11.57 $40.48

VIP--Upper Cabinet $12.53 $4.17 $1.95 $7.46 $26.11 $144.99 $272.09

Upper SystemVSC $56.00 $0.00 $0.00 $0.00 $22.40 $78.40

29% VIP--Lower Doors $19.54 $0.42 $2.33 $8.92 $31.20 $109.60 $381.70 Lower System VSC $56.00 $0.00 $0.00 $0.00 $22.40 $78.40
5-A-49

Table 5-A.3.4: Incremental Cost Detail for 18.5 ft3 Bottom-Mount Refrigerator-Freezer (Product Class 5)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10%

Increase Compressor EER from 

5.61 to 6.26 $9.98 $0.00 $0.00 $0.00 $2.60 $12.58

$20.89 $20.89 Brushless DC Evaporator Fan 

Motor $4.10 $0.00 $0.00 $0.00 $1.07 $5.17

Increase Evaporator Size by 

25% $2.50 $0.00 $0.00 $0.00 $0.65 $3.15

15%

Adaptive Defrost $8.00 $0.00 $0.00 $0.00 $2.08 $10.08

$12.35 $33.24

Brushless DC Condenser Fan 

Motor $4.30 $0.00 $0.00 $0.00 $1.12 $5.42

Remove Evaporator Size 

Increase -$2.50 $0.00 $0.00 $0.00 -$0.65 -$3.15

20%

Variable Antisweat Heat Control $17.48 $0.00 $0.00 $0.00 $4.54 $22.02

Increase Evaporator Size by $25.17 $58.42

25% $2.50 $0.00 $0.00 $0.00 $0.65 $3.15

25% Variable Speed Compressor $60.02 $0.00 $0.00 $0.00 $15.60 $75.62 $86.84 $145.26 2.4 sqft VIP in FZR Door $7.76 $0.21 $0.93 $2.31 $11.22

30%

6.8 sqft VIP in FF Door $22.09 $0.42 $2.63 $6.54 $31.68

2.4 sqft more VIP in FZR Door $7.76 $0.21 $0.93 $2.31 $11.22 $111.75 $257.01

13.7 sqft VIP in FZR Cabinet $44.76 $4.17 $5.72 $14.21 $68.86

32% 7.2 sqft VIP in FF Cabinet $23.49 $4.17 $3.24 $8.03 $38.93 $38.93 $295.94
5-A-50

Table 5-A.3.5: Incremental Cost Detail for 25 ft3 Bottom-Mount Refrigerator-Freezer (Product Class 5)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10% Increase Compressor EER from 

5.00 to 5.67 $4.04 $0.00 $0.00 $0.00 $1.05 $5.08 $5.08 $5.08

15% Increase Compressor EER from 

5.67 to 5.97 $3.93 $0.00 $0.00 $0.00 $1.02 $4.95 $4.95 $10.03

20% Increase Compressor EER from 

5.97 to 6.26 $5.27 $0.00 $0.00 $0.00 $1.37 $6.64 $6.64 $16.67

25%

Brushless DC Evaporator Fan 

Motor $4.10 $0.00 $0.00 $0.00 $1.07 $5.17

$17.11 $33.78 Variable Anti-Sweat Heater 

Control $9.48 $0.00 $0.00 $0.00 $2.46 $11.94

30%

Brushless DC Condenser Fan 

Motor $4.30 $0.00 $0.00 $0.00 $1.12 $5.42 $59.30 $93.09

Variable Speed Compressor $42.77 $0.00 $0.00 $0.00 $11.12 $53.89

40.5%

9.2 sqft VIP in FF Door $30.12 $0.42 $3.57 $8.87 $42.98

$197.92 $291.01 5.9 sqft VIP in FZR Door $19.34 $0.42 $2.31 $5.74 $27.81

14.8 sqft VIP in FZR Cabinet $48.43 $4.17 $6.15 $15.28 $74.03

10.3sqft VIP in FF Cabinet $33.57 $4.17 $4.41 $10.96 $53.10
5-A-51

Table 5-A.3.6: Incremental Cost Detail for 21 ft3 Built-In Bottom-Mount Refrigerator-Freezer (Product Class 5-BI)

Efficiency 

Level

Design Options Added Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10%

Decrease FF Compressor 

Capacity (same EER) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

$21.47 $21.47 10% Increase to Condenser Area $1.00 $0.00 $0.00 $0.00 $0.40 $1.40

Increase Freezer Compressor 

EER to 6.26 $10.71 $0.00 $0.00 $0.00 $4.28 $14.99

1.0 sqft VIP--FZR Door $3.18 $0.07 $0.38 $1.45 $5.09

15% Remove 1.0 sqft VIP--FZR Door -$3.18 -$0.07 -$0.38 -$1.45 -$5.09 $64.35 $85.82 FZR System VSC $49.60 $0.00 $0.00 $0.00 $19.84 $69.43

20% 14.6 sqft VIP--FZR 

Compartment $47.86 $3.34 $5.99 $22.88 $80.07 $80.07 $165.89

25%

Add 3.6 sqft VIP -- FZR 

Compartment $11.83 $0.83 $1.48 $5.65 $19.79

$129.39 $295.28 6.0 sqft VIP--FZR Door $19.54 $0.42 $2.33 $8.92 $31.20

FF System VSC $56.00 $0.00 $0.00 $0.00 $22.40 $78.40

27% 9.4 sqft VIP -- FF Door $30.80 $0.42 $3.65 $13.95 $48.82 $74.93 $370.22 3.8 sqft VIP -- FF Cabinet $12.53 $4.17 $1.95 $7.46 $26.11
5-A-52

Table 5-A.3.7: Incremental Cost Detail for 22 ft3 Side-Mount Refrigerator-Freezer with TTD Ice (Product Class 7)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10%

Increase Compressor EER from 

5.51 to 5.85 $4.45 $0.00 $0.00 $0.00 $1.16 $5.60

Brushless DC Condenser Fan $12.54 $12.54

Motor $4.30 $0.00 $0.00 $0.00 $1.12 $5.42

Increase Evaporator Area 19% $1.21 $0.00 $0.00 $0.00 $0.31 $1.52

15% Increase Compressor EER from 

5.85 to 6.22 $6.09 $0.00 $0.00 $0.00 $1.58 $7.68 $7.68 $20.22

20%

Increase Compressor EER from 

6.22 to 6.26 $0.75 $0.00 $0.00 $0.00 $0.20 $0.95

$41.92 $62.14 Increase Condenser Size by 27% $3.91 $0.00 $0.00 $0.00 $1.02 $4.92

Variable Anti-Sweat Heater 

Control for Ice Dispenser $9.48 $0.00 $0.00 $0.00 $2.46 $11.94

5.1 sqft VIP in FZR Door $16.71 $0.42 $2.00 $4.98 $24.11

25%

Remove 5.1 sqft VIP FZR Door -$16.71 -$0.42 -$2.00 -$4.98 -$24.11

Variable Speed Compressor $44.71 $0.00 $0.00 $0.00 $11.62 $56.34 $47.49 $109.64

3.0 sqft VIP in FZR Cabinet $9.66 $1.19 $1.27 $3.15 $15.27

30%

7.4 sqft more VIP in FZR

Cabinet $24.15 $2.98 $3.17 $7.88 $38.17

5.1 sqft VIP in FZR Door $16.71 $0.42 $2.00 $4.98 $24.11 $139.49 $249.13

8 sqft VIP in FF Door $26.28 $0.42 $3.12 $7.75 $37.57

7.8 sqft VIP in FF Cabinet $25.60 $2.56 $3.30 $8.18 $39.64

31% 4.9 sqft more VIP in FF Cabinet $16.08 $1.61 $2.07 $5.14 $24.89 $24.89 $274.02
5-A-53

Table 5-A.3.8: Incremental Cost Detail for 26 ft3 Side-Mount Refrigerator-Freezer with TTD Ice (Product Class 7)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10% Increase Compressor EER from 

5.21 to 5.86 $5.76 $0.00 $0.00 $0.00 $1.50 $7.26 $7.26 $7.26

15%

Brushless DC Evaporator Fan

Motor $4.10 $0.00 $0.00 $0.00 $1.07 $5.17 $10.58 $17.84

Brushless DC Condenser Fan 

Motor $4.30 $0.00 $0.00 $0.00 $1.12 $5.42

20% Increase Compressor EER from 

5.86 to 6.11 $3.90 $0.00 $0.00 $0.00 $1.01 $4.91 $4.91 $22.75

25%

Increase Compressor EER from 

6.11 to 6.26 $2.82 $0.00 $0.00 $0.00 $0.73 $3.55

Variable Anti-Sweat Heater $56.03 $78.78

Control for Ice Dispenser $17.48 $0.00 $0.00 $0.00 $4.54 $22.02

Increase Condenser Size by 10% $1.21 $0.00 $0.00 $0.00 $0.31 $1.53

6.2 sqft VIP in FZR Door $20.14 $0.42 $2.41 $5.97 $28.93

30% Variable Speed Compressor $57.55 $0.00 $0.00 $0.00 $14.96 $72.51 $85.79 $164.57

2.6 sqft VIP in FZR Cabinet $8.51 $0.93 $1.10 $2.74 $13.29

35%

9.1 sqft more VIP in FZR 

Cabinet $29.71 $3.24 $3.86 $9.57 $46.38

$151.83 $316.41 8.2 sqft VIP in FF Door $26.65 $0.42 $3.17 $7.86 $38.09

13.4 sqft VIP in FF Cabinet $43.70 $4.17 $5.60 $13.90 $67.36
5-A-54

Table 5-A.3.9: Incremental Cost Detail for 28 ft3 Built-In Side-Mount Refrigerator-Freezer with TTD ice service (Product 

Class 7-BI)

Efficiency 

Level

Design Options Added Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10%

High Efficiency Compressor $7.31 $0.00 $0.00 $0.00 $2.92 $10.23

$51.45 $51.45 Heat Exchanger Improvement $2.00 $0.00 $0.00 $0.00 $0.80 $2.80

Variable Anti-sweat $9.50 $0.00 $0.00 $0.00 $3.80 $13.30

Partial VIP to Freezer Door $15.81 $0.25 $1.88 $7.18 $25.12

15% Eliminate VIP to Freezer Door -$15.81 -$0.25 -$1.88 -$7.18 -$25.12 $72.02 $123.47 Variable Speed Compressor $69.38 $0.00 $0.00 $0.00 $27.75 $97.14

20% VIP to Freezer Door $26.36 $0.42 $3.13 $11.96 $41.86 $158.06 $281.53 VIP to Freezer Cabinet $70.14 $4.17 $8.69 $33.20 $116.20

22% VIP to Fresh Food Cabinet $11.59 $4.17 $1.84 $7.04 $24.64 $89.74 $371.27 VIP to Fresh Food Door $41.22 $0.42 $4.87 $18.60 $65.10
5-A-55

Table 5-A.3.10: Incremental Cost Detail for 14 ft3 Upright Freezer with Auto Defrost (Product Class 9)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10%

Brushless DC Evaporator Fan 

Motor $4.10 $0.00 $0.00 $0.00 $1.07 $5.17

$10.40 $10.40 Increase compressor efficiency 

from 5.04 to 5.69 $4.15 $0.00 $0.00 $0.00 $1.08 $5.23

15%

Increase compressor efficiency 

from 5.69 to 6.08 $9.03 $0.00 $0.00 $0.00 $2.35 $11.38

$21.14 $31.54 Door Insulation Thickness 

Increase of 0.21 inches $0.75 $0.00 $0.00 $7.00 $2.02 $9.77

20%

Door Insulation Thickness 

Increase of 0.79 inches $2.83 $0.00 $0.00 $0.00 $0.74 $3.56 $13.64 $45.18

Adaptive Defrost $8.00 $0.00 $0.00 $0.00 $2.08 $10.08

25% Add 0.22" Insulation to Walls $2.59 $0.00 $0.00 $23.00 $6.65 $32.24 $32.24 $77.43

30% Add 0.34" more Insulation to 

Walls $3.92 $0.00 $0.00 $0.00 $1.02 $4.94 $4.94 $82.37

35% Remove 0.06" Wall Insulation -$0.68 $0.00 $0.00 $0.00 -$0.18 -$0.86 $85.18 $167.56 Variable Speed Compressor $68.29 $0.00 $0.00 $0.00 $17.76 $86.05

40% Add 0.5" Wall Insulation $5.76 $0.00 $0.00 $0.00 $1.50 $7.26 $34.16 $201.71 5.7 sqft VIP in Door $18.46 $0.23 $2.65 $5.55 $26.90

43% 4.6 sqft more VIP in Door $14.94 $0.19 $2.15 $4.49 $21.76 $113.38 $315.09 18.9 sqft VIP in Cabinet $61.59 $2.08 $9.04 $18.90 $91.61
5-A-56

Table 5-A.3.11: Incremental Cost Detail for 20 ft3 Upright Freezer with Auto Defrost (Product Class 9)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10%

Brushless DC Evaporator Fan 

Motor $4.10 $0.00 $0.00 $0.00 $1.07 $5.17 $11.98 $11.98

Increase Compressor EER from 

5.73 to 6.1 $5.41 $0.00 $0.00 $0.00 $1.41 $6.82

15% Increase Compressor EER from 

6.1 to 6.24 $2.63 $0.00 $0.00 $0.00 $0.68 $3.31 $13.39 $25.37

Adaptive Defrost $8.00 $0.00 $0.00 $0.00 $2.08 $10.08

20%

Increase Evaporator Size by 

22% $1.47 $0.00 $0.00 $0.00 $0.38 $1.86

$16.98 $42.35 Forced Convection Condenser 

with Brushless DC Condenser 

Fan

$12.00 $0.00 $0.00 $0.00 $3.12 $15.12

25% Add 0.9 inch Insulation to Door $4.28 $0.00 $0.00 $7.00 $2.93 $14.22 $14.22 $56.57

30%

Remove 0.2 inch Insulation from 

Door -$0.95 $0.00 $0.00 $0.00 -$0.25 -$1.20 $37.50 $94.06

Add 0.5 inch Insulation to 

Cabinet $7.71 $0.00 $0.00 $23.00 $7.98 $38.69

35% Add 0.5 inch Insulation to 

Cabinet $7.76 $0.00 $0.00 $0.00 $2.02 $9.78 $9.78 $103.84

40% Variable Speed Compressor $78.00 $0.00 $0.00 $0.00 $20.28 $98.28 $98.28 $202.12

44.0% 14.4 sqft VIP in Door $46.97 $0.42 $6.73 $14.07 $68.18 $180.00 $382.12 23.1 sqft VIP in Cabinet $75.63 $2.08 $11.03 $23.07 $111.82
5-A-57

Table 5-A.3.12: Incremental Cost Detail for 22 ft3 Built-In Upright Freezer (Product Class 9-BI)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10% Increase Compressor EER to 

6.29 $11.20 $0.00 $0.00 $0.00 $4.48 $15.68 $15.68 $15.68

15% BLDC Fan for Evaporator $4.10 $0.00 $0.00 $0.00 $1.64 $5.74 $11.76 $27.44 BLDC Fan for Condenser $4.30 $0.00 $0.00 $0.00 $1.72 $6.02

20%

10% Increase to Condenser Area $1.00 $0.00 $0.00 $0.00 $0.40 $1.40

Variable Speed Compressor $44.80 $0.00 $0.00 $0.00 $17.92 $62.72 $71.80 $99.23

1.5 sqft VIP Upper Door $4.84 $0.07 $0.57 $2.19 $7.67

25% VIP Upper Door (Full Coverage) $25.96 $0.35 $3.08 $11.76 $41.15 $112.50 $211.74 13.1 sqft VIP Lower Cabinet $42.65 $2.98 $5.34 $20.39 $71.36

27%

VIP Lower Cabinet (Full 

Coverage) $17.04 $1.19 $2.13 $8.14 $28.50

$85.82 $297.56 VIP--Lower Door $19.54 $0.42 $2.33 $8.92 $31.20

VIP--Upper Cabinet $12.53 $4.17 $1.95 $7.46 $26.11
5-A-58

Table 5-A.3.13: Incremental Cost Detail for 15 ft3 Chest Freezer (Product Class 10)

Efficiency 

Level

Design Options Added Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10% Increase Compressor EER from 

4.92 to 5.48 $1.74 $0.00 $0.00 $0.00 $0.45 $2.19 $2.19 $2.19

15% Increase Compressor EER from 

5.48 to 5.81 $4.39 $0.00 $0.00 $0.00 $1.14 $5.53 $5.53 $7.72

20%

Increase Compressor EER from 

5.81 to 6.08 $3.99 $0.00 $0.00 $0.00 $1.04 $5.02 $14.66 $22.39

Add 0.24 inch Insulation to Door $0.65 $0.00 $0.00 $7.00 $1.99 $9.64

25%

Add 0.76 inch Insulation to Door $2.11 $0.00 $0.00 $0.00 $0.55 $2.66

Add 0.15 inch Insulation to $37.50 $59.89

Cabinet $1.66 $0.00 $0.00 $26.00 $7.19 $34.85

30% Add 0.35 inch Insulation to 

Cabinet $3.78 $0.00 $0.00 $0.00 $0.98 $4.77 $4.77 $64.66

35% Variable Speed Compressor $46.15 $0.00 $0.00 $0.00 $12.00 $58.14 $58.14 $122.80

44%

Add 0.25 inch Insulation to 

Cabinet $2.65 $0.00 $0.00 $0.00 $0.69 $3.33

$85.87 $208.67 8.2 sqft VIP on bottom $26.66 $1.39 $3.98 $8.33 $40.36

8.8 sqft VIP on door $28.89 $0.42 $4.16 $8.70 $42.17
5-A-59

Table 5-A.3.14: Incremental Cost Detail for 20 ft3 Chest Freezer (Product Class 10)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10%

Increase Condenser Size by 24% $1.68 $0.00 $0.00 $0.00 $0.44 $2.12

Increase Compressor EER from $10.68 $10.68

5.71 to 6.16 $6.80 $0.00 $0.00 $0.00 $1.77 $8.56

15%

Increase Compressor EER from 

6.16 to 6.25 $1.69 $0.00 $0.00 $0.00 $0.44 $2.13

$10.95 $21.63 Convert Door Insulation to PU 

Foam $0.00 $0.00 $0.00 $7.00 $1.82 $8.82

20% Add 1 inch Insulation to Door $3.47 $0.00 $0.00 $0.00 $0.90 $4.37 $4.37 $26.00

25% Add 0.35 inch Insulation to 

Cabinet $4.77 $0.00 $0.00 $26.00 $8.00 $38.78 $38.78 $64.78

30%

Add 0.4 inch Insulation to 

Cabinet $5.32 $0.00 $0.00 $0.00 $1.38 $6.70 $28.91 $93.69

4.5 sqft VIP in Bottom Wall $14.82 $0.62 $2.19 $4.58 $22.21

35%

Remove 4.5 sqft VIP Bottom 

Wall -$14.82 -$0.62 -$2.19 -$4.58 -$22.21 $37.65 $131.34

Variable Speed Compressor $47.51 $0.00 $0.00 $0.00 $12.35 $59.87

39% 10.2 sqft VIP in Bottom Wall $33.46 $1.39 $4.95 $10.35 $50.14 $107.09 $238.43 12 sqft VIP in Door $39.16 $0.42 $5.62 $11.75 $56.95
5-A-60

Table 5-A.3.15: Incremental Cost Detail for 1.7 ft3 Compact Refrigerator (Product Class 11)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10%

Increase Evaporator Size by 

20% $0.27 $0.00 $0.00 $0.00 $0.07 $0.34

$2.61 $2.61 Increase Compressor EER from 

3.02 to 3.20 $1.80 $0.00 $0.00 $0.00 $0.47 $2.27

15% Increase Compressor EER from 

3.20 to 3.47 $2.70 $0.00 $0.00 $0.00 $0.70 $3.40 $3.40 $6.01

20% Increase Condenser Size by 19% $0.39 $0.00 $0.00 $0.00 $0.10 $0.49 $5.12 $11.13 Add 3/4 inch Insulation in Door $0.67 $0.00 $0.00 $3.00 $0.95 $4.62

25% Add 0.18 inch Insulation in 

Cabinet $0.60 $0.00 $0.00 $10.00 $2.76 $13.36 $13.36 $24.49

30% Add 0.57 inch Insulation in 

Cabinet $2.00 $0.00 $0.00 $0.00 $0.52 $2.51 $2.51 $27.00

35%

Eliminate all previous Design 

Options -$8.43 $0.00 $0.00 -$13.00 -$5.57 -$27.00 $43.56 $70.56

Variable Speed Compressor $56.00 $0.00 $0.00 $0.00 $14.56 $70.56

40% Convert to Isobutane Refrigerant $8.00 $0.00 $0.00 $1.00 $2.34 $11.34 $11.34 $81.90

45%

Increase Evaporator Size by 

20% $0.27 $0.00 $0.00 $0.00 $0.07 $0.34

$5.46 $87.36 Increase Condenser Size by 19% $0.39 $0.00 $0.00 $0.00 $0.10 $0.49

Add 3/4 inch Insulation in Door $0.67 $0.00 $0.00 $3.00 $0.95 $4.62

50% Add 3/4 inch Insulation in 

Cabinet $2.60 $0.00 $0.00 $10.00 $3.28 $15.88 $15.88 $103.23

55% Add 4.7 sqft VIP in Cabinet $15.38 $4.17 $3.83 $6.08 $29.45 $41.06 $144.29 Add 2.2 sqft VIP in Door $7.29 $0.42 $1.51 $2.39 $11.61
5-A-61

Table 5-A.3.16: Incremental Cost Detail for 4.0 ft3 Compact Refrigerator (Product Class 11)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10% Increase Compressor EER from 

4.57 to 5.1 $5.30 $0.00 $0.00 $0.00 $1.38 $6.68 $6.68 $6.68

15%

Increase Compressor EER from 

5.1 to 5.3 $2.30 $0.00 $0.00 $0.00 $0.60 $2.90 $3.65 $10.32

Increase Condenser Size by 22% $0.59 $0.00 $0.00 $0.00 $0.15 $0.75

20% Add 3/4 inch Insulation to Door $0.92 $0.00 $0.00 $3.00 $1.02 $4.94 $4.94 $15.26

25% Convert to Isobutane Refrigerant $4.00 $0.00 $0.00 $1.00 $1.30 $6.30 $6.69 $21.95 Add 1/4 inch Insulation to Door $0.31 $0.00 $0.00 $0.00 $0.08 $0.39 $14.23

30%

Add 0.22 inch Insulation to 

Cabinet $0.98 $0.00 $0.00 $10.00 $2.86 $13.84

$13.45 $35.40 Remove 1/4 inch Insulation from 

Door -$0.31 $0.00 $0.00 $0.00 -$0.08 -$0.39

35% Add 0.22 inch Insulation to 

Cabinet $0.99 $0.00 $0.00 $0.00 $0.26 $1.25 $1.25 $36.66

40% Add 0.31 inch Insulation to 

Cabinet $1.37 $0.00 $0.00 $0.00 $0.36 $1.73 $1.73 $38.38

45%

Variable Speed Compressor $52.40 $0.00 $0.00 $0.00 $13.62 $66.02

Remove 3/4 inch Cabinet $49.20 $87.59

Insulation -$3.35 $0.00 $0.00 -$10.00 -$3.47 -$16.82

50% Add 0.23 inch Insulation to 

Cabinet $1.02 $0.00 $0.00 $10.00 $2.87 $13.89 $13.89 $101.47

62%

Add 0.32 inch Insulation to 

Cabinet $2.33 $0.00 $0.00 $0.00 $0.61 $2.93

$66.16 $167.63 7.2 sqft VIP Cabinet $23.57 $4.17 $5.44 $8.62 $41.79

4.2 sqft VIP Door $13.81 $0.42 $2.79 $4.42 $21.43
5-A-62

Table 5-A.3.17: Incremental Cost Detail for 3.4 ft3 Compact Chest Freezer (Product Class 18)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10% Increase Compressor EER from 

3.74 to 4.17 $4.30 $0.00 $0.00 $0.00 $1.12 $5.42 $5.42 $5.42

15% Increase Compressor EER from 

4.17 to 4.29 $1.20 $0.00 $0.00 $0.00 $0.31 $1.51 $10.45 $15.87

Add 1 inch Insulation to Door $1.09 $0.00 $0.00 $6.00 $1.84 $8.94

20%

Remove 1/4 inch Insulation from 

Door -$0.27 $0.00 $0.00 $0.00 -$0.07 -$0.34 $35.22 $51.09

Add 0.48 inch Insulation to 

Cabinet $2.23 $0.00 $0.00 $26.00 $7.34 $35.57

25%

Add 0.27 inch Insulation to 

Cabinet $1.22 $0.00 $0.00 $0.00 $0.32 $1.54 $13.96 $65.05

Add 2.1 sqft VIP in Bottom 

Wall $6.85 $1.39 $1.62 $2.56 $12.42

30% Remove all design options 

through 25% Level -$16.62 -$1.39 -$33.62 -$13.42 -$65.05 $5.51 $70.56

Variable Speed Compressor $56.00 $0.00 $0.00 $0.00 $14.56 $70.56

35% Add 0.75 inch Insulation to Door $0.82 $0.00 $0.00 $6.00 $1.77 $8.59 $8.59 $79.15

43.3%

Add 0.75 inch Insulation to 

Cabinet $3.45 $0.00 $0.00 $26.00 $7.66 $37.11

Add 2.1 sqft VIP in Bottom $66.56 $145.71

Wall $6.85 $1.39 $1.62 $2.56 $12.42

Add 3.3 sqft VIP in Door $10.89 $0.42 $2.22 $3.51 $17.03
5-A-63

Table 5-A.3.18: Incremental Cost Detail for 7.0 ft3 Compact Chest Freezer (Product Class 18)

Efficiency 

Level Design Options Added

Design Option Costs Incremental Costs

Material Labor Overhead Depreciation G&A, 

Profit Total Added Cumulative

10% Increase Compressor EER from 

4.50 to 5.02 $5.20 $0.00 $0.00 $0.00 $1.35 $6.55 $6.55 $6.55

15%

Increase Compressor EER from 

5.02 to 5.27 $2.50 $0.00 $0.00 $0.00 $0.65 $3.15 $10.98 $17.53

Add 0.12 inch Insulation to Door $0.22 $0.00 $0.00 $6.00 $1.62 $7.83

20%

Add 0.63 inch Insulation to Door $1.14 $0.00 $0.00 $0.00 $0.30 $1.44

Add 0.26 inch Insulation to $36.84 $54.37

Cabinet $2.09 $0.00 $0.00 $26.00 $7.30 $35.39

25% Add 0.36 inch Insulation to 

Cabinet $2.91 $0.00 $0.00 $0.00 $0.76 $3.66 $3.66 $58.03

30%

Remove all design options 

through 25% Level -$14.06 $0.00 $0.00 -$32.00 -$11.97 -$58.03

Variable Speed Compressor $56.00 $0.00 $0.00 $0.00 $14.56 $70.56 $47.08 $105.11

Add 0.18 inch Insulation to 

Cabinet $1.42 $0.00 $0.00 $26.00 $7.13 $34.55

35% Add 0.47 inch Insulation to 

Cabinet $3.71 $0.00 $0.00 $0.00 $0.96 $4.67 $4.67 $109.79

40%

Add 0.11 inch Insulation to 

Cabinet $0.85 $0.00 $0.00 $0.00 $0.22 $1.07

$58.69 $168.47 Add 3/4 inch Insulation to Door $1.36 $0.00 $0.00 $6.00 $1.91 $9.27

Add 4.1 sqft VIP to Cabinet 

Bottom $13.50 $1.39 $2.92 $4.63 $22.43

Add 5.1 sqft VIP to Door $16.78 $0.42 $3.37 $5.35 $25.91
5-A-64

5-A.4 PRELIMINARY ANALYSIS ENGINEERING QUESTIONNAIRE

DOE used the preliminary analysis engineering questionnaire as a guide for engineering 

discussions during manufacturer interviews. Some of the information provided in the 

questionnaire has been redacted to protect vendor information.
5-A-65

DESIGN FOR ENERGY IMPROVEMENT INFORMATION REQUEST

DOE would like to confirm information on the incremental costs of increasing product efficiency 

by understanding the design options involved in the efficiency improvement. 

1. Market Share of products you sell

To help DOE discover manufacturer sub-groups and the relative importance of various product 

classes to specific manufacturers, please disaggregate your annual unit shipments for each 

product category as shown below. Please also indicate whether you purchase these products 

from other manufacturers (i.e. private label), and whether the factory that supplies the product 

is located in the USA.

Product Class (response for PC1 through PC20 not 

including built-in products)

% Private 

Label?

% Made 

in USA?

Yearly Unit 

Shipments

1. Refrigerators and refrigerator-freezers with 

manual defrost.

2. Refrigerator-freezer—partial automatic defrost.

3a. Refrigerator-freezer—automatic defrost with topmounted freezer without through-the-door ice 

service 

3b. All-refrigerator—automatic defrost.

4. Refrigerator-freezers—automatic defrost with 

side-mounted freezer without through-the-door 

ice service.

5. Refrigerator-freezers—automatic defrost with 

bottom-mounted freezer without through-the-door 

ice service.

6. Refrigerator-freezers—automatic defrost with 

top-mounted freezer with through-the-door ice 

service.

7. Refrigerator-freezers—automatic defrost with 

side-mounted freezer with through-the-door ice 

service. 

8. Upright freezers with manual defrost.

9. Upright freezers with automatic defrost. 

10. Chest freezers and all other freezers except 

compact freezers.

11. Compact refrigerators and refrigerator-freezers 

with manual defrost.

12. Compact refrigerator-freezer—partial automatic 

defrost.

13a. Compact refrigerator-freezers—automatic 

defrost with top-mounted freezer compact allrefrigerator—automatic defrost.

13b. Compact all-refrigerator—automatic defrost.
5-A-66

14. Compact refrigerator-freezers—automatic defrost 

with side-mounted freezer.

15. Compact refrigerator-freezers—automatic defrost 

with bottom-mounted freezer.

16. Compact upright freezers with manual defrost.

17. Compact upright freezers with automatic defrost.

18. Compact chest freezers.

19. Refrigerator-freezer—automatic defrost with 

bottom-mounted freezer with through-the-door 

ice service.

20. Chest freezers with automatic defrost.

21. Wine Coolers

22. Built-in Refrigerators, Refrigerator-Freezers, and 

Freezers

(please provide percentage breakdown by Product 

Class for units presenting at least 5% of unit 

sales)

a. What percentage of products classified as product class 4 or 7 (side-by-sides) have convertible 

bottom drawers?

b. What percentage of product class 5 and what percentage of product class 19 products are 

French-door?

2. Product Technical Descriptions

The following series of exhibits and questions address technical characteristics of key 

refrigerator and freezer components for both baseline and improved-efficiency products.

Compressors

Please comment on the typical capacities of compressors used in the indicated products.
5-A-67

• Should there be differences in capacity levels for auto-defrost and manual defrost freezers?

• What capacity/volume relationship is representative for standard-sized manual-defrost 

refrigerators?

Please comment on the indicated typical EER of compressors used in standard and Energy Star 

products.

• Should there be differences between compressor EER used in auto-defrost and manual defrost 

freezers?

Typical EER trend for compressors used in compact refrigerators and freezers: 
5-A-68

• Is variation in compressor EER in compact products dependent primarily on capacity, as 

illustrated in the line in the plot below? 

• Note that while a range of EER is offered by compressor vendors, it is not clear that the range of 

EER’s actually being used in products is as broad--Is this driven by cost pressures for compact 

products?
5-A-69

Is the Illustrated Typical Cost vs. Capacity for Baseline Product compressors accurate?

Is the Illustrated Curve for incremental cost for higher EER compressors for standard-sized 

refrigerator-freezers accurate?
5-A-70

• What percentage of your baseline unit shipments use variable-speed compressors, and what 

percentage of Energy Star-rated products do?

• If you use variable-speed compressors in your products, do you run them at two or three 

speeds, or do you modulate the speed based on demand? 

• Is $30 an appropriate cost increase for a variable-speed compressor as compared to a baseline 

efficiency single-speed compressor purchased from the vendor for standard-sized 

refrigerator-freezers? What other costs need to be considered?

Evaporator Heat Exchanger Characteristics

In the following table, please comment on the typical key details of evaporator heat exchangers. 

Product Type Type Core 

Volume 

(cuft)

Tube 

Outer Dia 

(inch)

Tube 

Length 

(ft)

Fin Surface 

or cold 

plate 

surface

(sqft)

Standard-Sized 

RefrigeratorFreezers 

Forced 

Convection

0.21 0.33

(0.008 wall)

37 18

Standard-Sized 

Upright Freezers

Forced 

Convection

0.18 0.33

(0.008 wall)

32 18

Product Type Type Tube 

Outer Dia 

(inch)

Specific 

Tube 

Length 

(inch per 

Btu/hr 

compressor 

capacity)

Fin Surface 

(sqin per 

Btu/hr 

compressor 

capacity)

Standard-Sized 

Chest Freezers

Cold Wall 0.3 1.7 

Compact Basic 

Refrigerators

Roll Bond Channels 

0.18 high 

x 0.38 

wide

0.55 0.6

Compact Chest 

Freezers

Cold Wall 0.3 2.0 

• All forced-convention evaporators use aluminum tubes?

• Typical forced-convection evaporator fin style is flat aluminum with oval gaps to slide over 

tube serpentine?

• Any use of internally-enhanced tubes?

• Any use of enhanced fins?

• What percentage of refrigerator/freezers use more than one evaporator?

• What percentage of refrigerator/freezers use other than forced-convection evaporators?

• Do you employ wide fin spacing and lack of fin surface enhancements for frost tolerance and 

quick melt runoff? 
5-A-71

• Is there a typical evaporator air flow rate vs. compressor capacity relationship? If so, can you 

detail it?

• Are you aware of any further significant system improvements that may be possible through 

evaporator heat exchanger changes? (for example, via eggcrate evaporators, spine-fin?)

• If you use spine-fin heat exchangers, is their performance for volume/fan power better than 

for flat-fin heat exchangers? Or was your decision driven by cost? What about frost 

tolerance and internal enhancements?

Condenser Heat Exchanger Characteristics

In the following table, please comment on the typical key details of evaporator heat exchangers. 

Product Type Type Tube 

Outer 

Dia

(inch)

Tube 

Length 

(ft)

Wire Fin 

Diameter

(inch)

Wire Fin 

Total Length

(ft)

Standard-Sized 

RefrigeratorFreezers 

Forced 

Convection 

Steel Tube 

Wire Fin

0.19

(0.025 

wall)

50 0.05 300

Product Type Type Tube 

Outer 

Dia

(inch)

Tube 

Wall 

(inch)

Specific 

Tube Length 

(inch per 

Btu/hr 

compressor 

capacity)

Specific Wire 

Fin Length

(foot per 

Btu/hr 

compressor 

capacity)

Standard-Sized 

Upright Freezers

Hot Wall 0.19 0.03 1.0 N/A

Standard-Sized 

Chest Freezers

Hot Wall 0.19 0.03 1.3 N/A

Compact Basic 

Refrigerators

Static or 

Hot Wall

0.19 0.025 Hot Wall 1.5

Static 0.4 

0.4 

Compact Chest 

Freezers

Hot Wall 

or Static

0.19 0.025 Hot Wall 1.7 

Static 0.9

0.7

• Any use of internally-enhanced tubes?

• Most external condenser heat exchangers designs appear to be based on steel wire fins. What 

are the key drivers leading to this design choice? 

o Is in-field dust-covered performance a consideration?

o Are enhanced-surface designs too expensive? 

o Or perhaps not worthwhile because there is enough space for lower-cost wire fin 

design? 

o Performance degradation when dirty? 

o Or can’t do better than wire fin for a given volume and the typically low fan power? 

• Is there a relationship between typical condenser air flow rate vs. the compressor capacity? If 

so, can you detail it?
5-A-72

• During teardowns we noted that some manufacturers use “rolled up” heat exchangers vs. the 

typical flat external condenser heat exchangers. What are the benefits and drawbacks of such 

heat exchangers?

Evaporator and Condenser Fans

• Are the indicated characteristics for fan motors typical for refrigerator-freezers?

• Is there any room for further, significant energy efficiency improvement via fan blade/air 

flow path design improvements (i.e. PAX fan)?

• Do you consider PSC fan motors a viable intermediary step between SP and BLDC fan 

motors?

• Do any of your fans run at multiple speeds, for example to match the output of a variablespeed compressor? 

• What are the benefits or drawbacks associated with using BLDC motors that are based on 

DC-power input vs. AC-power input? What is the cost difference between such motors?

Cabinet Insulation Characteristics (as applicable)

In the following table, please comment on the typical average insulation thicknesses.

Product Type Insulation Thickess (inches)

Standard-Sized Refrigerator-Freezers with 

Automatic Defrost—Fresh Food 

Compartment

1.9

Standard-Sized Refrigerator-Freezers with 

Automatic Defrost—Freezer Compartment

2.7

Standard-Sized Upright Freezers 2.3

Standard-Sized Chest Freezers 2.5

Compact Basic Refrigerators 1.2

Compact Chest Freezers 2.5

What typical insulation thickness would be used for the following product types?

• Standard-sized refrigerator with manual or partial automatic defrost?

• Compact refrigerator-freezers?
5-A-73

• Standard-sized all-refrigerators?

• Compact all-refrigerators?

• Differences in typical average insulation thicknesses for built-in products?

• Is the state-of-the-art current insulation system based on HFC-245fa blowing agent with 

cabinet preheating and high pressure injection? Is the conductivity typically achieved for this 

system 0.13 Btu-in/hr-ft2

-oF at room temperature? Do you use any other insulation systems?

• Is there any significant further cabinet load reduction possible through lower conductivity 

foam? 

• Have you considered switching to low Global-Warming-Potential (GWP) blowing agents? If 

so, what are the drivers for these changes? What are the conductivity, cost impacts?

• Are you using any vacuum-insulated panels (VIPs) in any products? 

• If you have or were considering the adoption of VIPs can you detail how you would 

incorporate them into your products, what the capital costs, and what the marginal product 

costs of such a step would be? 

• Have you considered gas-filled panels? If so, what drove you to adopt, or not to adopt them? 

Door Frame:

• What are the key aspects of good state-of-the-art door frame/gasket area design? To what 

extent does a typical product adhere to this? What is the range of load impact of poor door 

frame region designs (i.e. in Btu/hr-ft)?

• Is there any value to using double-gaskets?

• Some refrigerators have extra-strong magnets requiring special handle designs to assist with 

door-opening. How much load reduction is possible with such an approach?

Through-the-Door Dispensers: 

• Today’s TTD systems don’t appear to represent thermal loads as high as suggested by the 

energy allowance associated with this feature, based for example on max energy difference 

between product classes 7 and 4. Is there more to the energy impact than the thermal load 

difference? How much anti-sweat heating wattage is typically used around your TTDs?

Anti-sweat Heaters:

• Most anti-sweat heaters appear to use hot liquid. Is this correct? Is there any continued use 

of hot gas anti-sweat systems? 

• Is there data available indicating average duty cycle of such heaters for typical in-home 

installation? Does this depend on use of anti-sweat heater for freezer door frame, mullion 

door frame, ducts, etc.?

• For example, do your products use resistance heaters within the fresh food return air duct to 

prevent frost accumulation? If so, is it always on or controlled based on humidity?

Defrost:

• What are your thoughts about benefits and drawbacks of precool prior to the defrost cycle?
5-A-74

• The DOE energy test energy impact of defrost is small, particularly with variable defrost. Is 

this a good reflection of in-field defrost impacts?

• Are dedicated controllers available to allow variable defrost to be used in products which 

otherwise use non-electronic controls?

Expansion Devices: 

• Is there any performance improvement potential with expansion devices other than capillary 

tube? What about for variable-speed compressor systems?

• Do you use any expansion device besides capillary tubes?

Energy Efficiency Conversion Costs

• What design changes are typically associated with converting baseline products mentioned 

above in Question 1 to Energy Star? 

• What are the marginal costs of the individual design options selected?

• When considering energy efficiency improvements to achieve or exceed Energy Star, do 

different product classes take different pathways or are pathways similar? 

• Are the cost increments higher for some classes than others for a given performance 

improvement over baseline? (think 10%, 15%, 20%, 25%, 30%, 35%, 35+ improvement over 

today’s baseline) 

Thoughts/feedback on alternative refrigeration cycles/implementations:

• Dual-evaporator systems attempting to cool fresh food compartment at higher evaporator 

temperatures.

• Ejector system.

• Stirling.

• Thermoacoustic.

• Thermoelectric.
7A-i

APPENDIX 7-A. LITERATURE SURVEY OF ENERGY CONSUMPTION BY 

RESIDENTIAL REFRIGERATOR-FREEZERS 

TABLE OF CONTENTS

7-A.1 INTRODUCTION .................................................................................................7-A-1

7-A.2 TEST PROCEDURE AND FIELD STUDIES......................................................7-A-2

7A.2.1 DOE Test Procedure ..............................................................................................7-A-2

7A.2.2 Field Studies...........................................................................................................7-A-3

7A.2.2.1 KEMA-Xenergy Findings....................................................................7-A-3

7-A.3 LITERATURE ANALYSIS ..................................................................................7-A-5

7-A.4 SUMMARY...........................................................................................................7-A-6

7-A.5 BIBLIOGRAPHY..................................................................................................7-A-6

LIST OF TABLES

Table 7-A.2.1 Refrigerator Energy Consumption Data by Year.......................................7-A-3

Table 7-A.2.2 Literature summary....................................................................................7-A-4
7-A-1

APPENDIX 7-A. LITERATURE SURVEY OF ENERGY CONSUMPTION BY 

RESIDENTIAL REFRIGERATOR-FREEZERS

7-A.1 INTRODUCTION

Efficient refrigerator-freezers reduce peak energy consumption as well as total household 

energy use. As a result, electric utilities regard replacement programs for these appliances as an 

attractive and effective way to reduce residential energy consumption. To estimate the amount of

electricity savings attributable to an energy-efficient refrigerator-freezer program, utilities must 

evaluate the difference between the pre- and post-program energy consumption of the appliance 

stock. The challenge to accurately estimate the electricity savings of a refrigerator-freezer 

replacement program lies in estimating the real-life consumption of the original and replacement 

units.

Estimation of appliance energy consumption may be undertaken in three ways, all of 

which are represented in the literature:

A) The labeled energy consumption on a new appliance, based on the U.S. Department 

of Energy (DOE) test procedure undertaken on a sample of several identical 

appliances, and reported by the appliance manufacturer

B) The DOE test procedure applied to a particular appliance (often not a new appliance), 

and

C) Measurement for some period of time in situ in a household.

Most studies compare two of these measurements in order to evaluate energy use. For example, 

a study might compare the results of the DOE test procedure on an old refrigerator with the 

labeled energy consumption when new to isolate the effect of appliance age, while eliminating 

possible effects due to user behavior. This appendix refers to such a study as comparing (B) to 

(A).

Researchers have conducted studies that measure the field consumption of refrigeratorfreezers to compare in situ measurements to the DOE test results, represented either by the 

labeled results ((C) to (A)), or through direct testing under DOE conditions ((C) to (B)). When 

such field studies are evaluated, the lack of consistency among study conditions (such as 

geographic location, housing type, and the number and type of units), limited time of direct 

measurements, and the degradation of efficiency throughout the lifetime of a refrigerator-freezer 

contribute to the challenge of estimating potential energy consumption savings from new units.

This appendix summarizes available literature regarding the comparison of different 

measurement methods for refrigerator-freezers in order to evaluate reasonable possible values for 

the ‘usage adjustment factor’ (UAF), which is an estimate of the ratio of (C) to (A). There are 

very few published measurements of freezers or compact appliances, so DOE addresses only 

refrigerator-freezers in this summary. Section 2 summarizes the DOE test procedure and lists and 

characterizes the field studies which DOE used in its analyses. Section 3 discusses these studies 

and their implications for the UAF parameter used in Chapter 6, particularly regarding variation 

with season and climate, and efficiency degradation with unit age.
7-A-2

7-A.2 TEST PROCEDURE AND FIELD STUDIES

This section describes the DOE test procedure, then lists field studies of energy 

consumption by refrigerator-freezers and distills their results.

7A.2.1 DOE Test Procedure

“The DOE test is a compromise between realism and minimizing the costs of performing 

a reliable, repeatable laboratory test” (Meier, 1993). The DOE procedure for evaluating the 

annual energy consumption of refrigerator-freezers comprises the following features (10 CFR, 

Chapter II, Part 430, Appendix A1).

• The standard test temperature for the fresh food compartment is 45°F.

• The standard test temperature for the freezer compartment is 5°F.

• The test is performed in a chamber that is maintained at an ambient temperature of 90°F.

• The temperatures of the freezer and fresh food compartments are measured using three 

independent thermocouples, one for each compartment. Five thermocouples are used 

when the refrigerator height is over 40”.

• The appliance’s energy consumption is calculated by interpolating test results that 

bracket the standard freezer temperature (5°F). Interpolation is done around the 5°F 

temperature (freezer compartment) and the 45°F temperature (fresh food compartment).

• Ambient relative humidity is not specified.

• Doors are not opened during the test.

• The fresh food and freezer compartments are empty.

• Ice making capability, if present, is not powered on or evaluated by the test.

The DOE test procedure is currently undergoing a rulemaking process which may change 

some of the above details. In particular, changes have been proposed to the test temperatures for 

the refrigerator and freezer compartments.

The DOE test procedure does not measure the effects of door opening, cooling warm 

food, or ice making. However, this test procedure provides standardized results that can serve as 

the basis for comparing the performance of appliances. Although the DOE test does not precisely 

mirror any single unit’s performance in situ, it serves as a foundation to which field 

measurements may be compared to develop estimates that account for a range of real-life 

circumstances (KEMA, 2004).

A summary of new refrigerator-freezer unit energy consumption values provided by 

manufacturers by year shows the annual variation of shipment-weighted refrigerator energy 

consumption from 1960s to the year 2006 (Table 2.1). These data are based on “nameplate” 

values. For the model years before the DOE energy standards (1989 and earlier), the test 

conditions are unknown in which energy consumption quantities were measured, although it is 

likely that manufacturers used the American Home Appliance Manufacturers (AHAM) test 

procedure or the test procedure prescribed by California state energy conservation standards.
7-A-3

Table 7-A.2.1 Refrigerator Energy Consumption Data by Year

Model Year

Shipment Weighted Average 

Use (kWh/yr) Model Year

Shipment Weighted Average 

Use (kWh/yr)

2006 564 1990 988

2005 550 1989 1006

2004 559 1988 1049

2003 589 1987 1052

2002 576 1986 1165

2001 611 1985 1147

2000 779 1984 1139

1999 762 1983 1160

1998 738 1982 1191

1997 728 1981 1190

1996 708 1980 1278

1995 693 1975 – 1979 1530†

1994 693 1970 – 1974 1730†

1993 699 1965 – 1969 1540†

1992 877 1961 – 1964 1150†

1991 918

Source: AHAM Fact Books

†: Approximate

7A.2.2 Field Studies

In situ conditions account for several important factors including: ambient air 

temperature; the number and duration of door openings; the temperature of food loaded into the 

unit; the placement of the unit in relation to walls, ovens, and stoves; the temperature setting in 

the field; and the ice maker setting in the field.

Since the early 1980s, utilities and government agencies have collected data on fieldmeasured refrigerator-freezer energy consumption in order to evaluate the effects of refrigerator 

“early replacement” programs. The collected data varies tremendously by sample size, the type 

of refrigerator-freezer studied, the length of time each appliance was monitored, and their 

operating conditions. The studies summarized in Table 2.2 describe the performance of 

refrigerator-freezers as measured in various ways. 

7A.2.2.1 KEMA-Xenergy Findings

The private consulting firm KEMA-Xenergy in 2002 reviewed numerous reports of in 

situ performance studies for Southern California Edison. Several reports were summarized by 

KEMA-Xenergy but are not available to be reviewed by DOE. These reports are indicated by a 

“#” in Table 2.2.
7-A-4

Table 7-A.2.2 Literature summary

Authors(s) Year Ratio Averagea Ratio Range

Comparison 

Type Location Refrigerator Type

Adjusted for 

climate or season

No. of 

Refrigerators

Arthur D. Little, Inc. # 1982 >1.2 C to A Florida unknown No unknown

Topping & Vineyard 1982 0.85 to 1.5b C to A Norfolk, VA New Noa 47

Meier & Jansky 1993 0.85 is “typical” 0.56 to 1.17 C to A Cold climates (many in 

Pacific Northwest) Relatively new No 209

Meier et al. 1993 B to A: 0.99,

C to A: 0.87

B to A: 0.89 to 

1.10 B and C to A Rochester, NY New, “energy efficient”, frost-free No 20

Bos # 1993 “considerably” > 1 B to A Sacramento, CA At replacement N/A 79

Quantum Consulting 1994

0.87 for “highefficiency”, 1 for 

“super-efficiency”

95% between 

roughly 0.7 

and 1.25

C to A Southern CA (SCE) 1-3 years old No 98

Proctor Engineering 

(Dutt et al.) 1994 Between 0.86 and 0.9c C to A Northern CA (PG&E) New, “energy efficient” Yesd 256

Goett # 1995 approx. 1 Unknown CA (PG&E and SCE) New No unknown

Barakat & Chamberlin 

# 1996 “significantly more” 

than 1 B to A Unknown At replacement N/A unknown

Miller & Pratt 1998 1.1 0.72 to 1.2e C to A New York City (multifamily public housing)

Some new, some 

older No 324

Kinney & Belshe 2001 0.96 (new);

1.3 (mixture) C to A New York City (multifamily public housing) 220 old, 56 new No 276

ICF Consulting 2003 approx. 0.5 C to statistical 

model of C CA (Bay Area) At replacement No 40

Mowris # 2003 1.06 wide variation C to A Northern CA (6 cities) At replacement unknown 91

KEMA 2004 1.46 (median) 0.85 to > 3 B to A California At replacement N/A 136

Peterson et al. 2007 median 1.4, mean 1.5 B to A California At replacement N/A 193

ADM, Athens, et al. 2008

0.81 to 0.88, 

depending on weather 

model

C to B California At replacement Yes 184

 

a A value greater than 1 for this ratio for a C to A comparison implies that energy use in the field (C) was greater than the labeled energy consumption (A). # KEMA-Xenergy (2004) is DOE’s only reference for the results of this study. b Seasonal variation for a single model c Ratio of average C to average A over sample

d Adjusted for typical meteorological year (TMY) at location e Variation in the mean of various types of refrigerators in various use environments
7-A-5

7-A.3 LITERATURE ANALYSIS

DOE’s interest in surveying the refrigerator-freezer energy use literature is to evaluate the 

range of possible appropriate values for the ‘usage adjustment factor’, or UAF. The UAF is a 

“(C) to (A)”-type measurement, relating energy use in situ to the DOE test result for a new 

appliance. 

Studies of new appliances include Meier & Jansky (1993), Meier et al. (1993), Dutt et al. 

(1994), Quantum (1994), Goett (1995), Miller & Pratt (1998), and Kinney & Belshe (2001). The 

average (or typical) values of the ratio of (C) to (A) for these studies range from 0.85 to 1.1, and 

there is significant variation, with ratios ranging from 0.56 to 1.25. The majority of these studies 

are not adjusted for ambient temperature variations or climate (although several use year-long 

samples to eliminate seasonal effects). The only of these studies which is adjusted (Dutt et al.) is 

normalized to the climate of the particular location of the measurements, rather than to a national 

average climate model. Taken collectively, these studies do not allow DOE to draw conclusions 

regarding possible national variation in new-refrigerator energy use, particularly due to 

variations in climate. They do indicate that the labeled energy consumption of a new appliance is 

likely to be accurate in situ to within 40%, as suggested by Meier (1995).

Studies of refrigerators at the time of replacement by utility programs show higher energy 

use relative to the labeled energy consumption than do new refrigerators. For older refrigerators, 

studies predominantly take two forms: (B) to (A) or (C) to (A). (B) to (A) studies isolate the 

effects of age from any other effects (such as behavior or ambient temperature in situ), while (C) 

to (A) studies give a direct indication of the ‘UAF’ of old appliances. These studies are not 

necessarily representative of all older refrigerators, because they study only those units and 

households participating in utility refrigerator recycling programs.

Test-procedure-only comparison studies include Bos (1993), Barakat & Chamberlin 

(1996), KEMA (2004) and Peterson et al. (2007). All four of these studies show significant 

energy use increase in the DOE test procedure; KEMA and Peterson both indicate an energy use 

increase of close to 50%, with wide variation. Only 7% of the refrigerators measured by KEMA 

used less than their labeled consumption. 25% of the refrigerators measured by Peterson et al. 

used more than 70% more that their labeled consumption.

Miller & Pratt (1998), Kinney & Belshe (2001), and Mowris (2003) undertook direct 

evaluation of the ratio of in situ to labeled consumption for older refrigerators. The average ratio 

in all three studies was measured to be larger than one, although smaller than the test-procedurebased comparisons. Mowris indicated wide variation in energy use relative to the label, and 

Miller & Pratt’s sub-categories show a range of energy consumptions from 28% below the label 

to 20% above. 

Only one study reviewed by DOE compared in situ energy use to the DOE test on the 

same appliance (ADM, Athens, et al., 2008), a (C) to (B) comparison. Depending on the weather 
7-A-6

model used to adjust the in situ measurements, they found that on average the DOE test 

procedure overestimated the in situ use by 13 to 23%. This study does not include an indication 

of how the DOE test consumption compared with the labeled consumption.

Testing has confirmed that age, in combination with other refrigerator characteristics, 

accounts for the degradation of refrigerator energy efficiency (KEMA, 2004; Peterson, 2007). 

Therefore, energy efficiency degradation is a factor in calculating the savings between new and 

replacement units. Energy use increases when barriers to cabinet air and heat leakage degrade. 

For example, door seals no longer close tightly, damaged walls allow air flow, and wet or 

degraded insulation no longer performs its function.

Two studies (KEMA, 2004 and Miller & Pratt, 1998) used regression analysis to measure 

the average effect of annual degradation on appliance energy use. KEMA determined an energy 

use growth rate of roughly 40 kWh/year, depending on model characteristics. Miller & Pratt’s 

regression model predicts a 1.37% increase in energy use each year. Smit (2006) reports that 

Athens (1998) calculated a degradation rate of 0.6% per year.

7-A.4 SUMMARY

This appendix summarizes current literature pertaining to the difference between DOEtest based measurements (when new or at retirement) and field-based measurements of 

refrigerator-freezer energy consumption. In situ energy use was found to be close to labeled 

consumption for new refrigerators, but higher than labeled at the time of replacement. This 

appendix has examined the mean values and variability from the literature; the variability across 

a national sample is likely much greater than the range addressed here.

Degradation of the refrigerator unit contributes to the discrepancy between the DOE test 

and field measured energy consumption data. However, the precise rate of efficiency decrease 

(and particularly its variability) cannot be determined from the literature.

7-A.5 BIBLIOGRAPHY

ADM Associates, Inc. 2004. Southern California Edison 1994 Residential Appliance Efficiency 

Incentive Program Ninth Year Retention Study. CEC Study ID #546A. Prepared for 

Southern California Edison Company. July 2004.

ADM Associates, Inc.; et al. 2008. Evaluation Study of the 2004-05 Statewide Residential 

Appliance Recycling Program; 2004-2005 Programs #1114, #1157, #1232 and #1348

Final Report and Appendices. Prepared by ADM Associates, Inc.; Athens Research; 

Hiner & Partners; and Innovologie LLC. Prepared for Southern California Edison. April, 

2008.
7-A-7

Athens Research, 1998. Refrigerator/Freezer UEC Estimation, 1996 ARCA/SCE Turn-In 

Program. In Support of Xenergy Inc’s Evaluation of the 1996 Appliance Recycling 

Program.

Dohrmann, Donald R. et al. Net Savings Estimation in Appliance Recycling Programs: A Review 

and Empirical Analysis with Recent California Data ADM Associates, Inc., Athens 

Research, Innovologie LLC for Southern California Edison.

Dutt, Guatam, et al., 1994. “Large Scale Residential Refrigerator Field Metering”, in 1994 

ACEEE Summer Study in Energy Efficiency in Buildings, pp. 2.77.

ICF Consulting, 2003. Evaluation of the Energy and Environmental Effects of the California 

Appliance Early Retirement and Recycling Program: Final Report. Prepared for: 

California Public Utilities Commission and Appliance Recycling Centers of America. 

May 12, 2003.

KEMA. 2004. 2003 EM&V RARP Study:Degradation and Market Potential Analysis. Prepared 

for Southern California Edison, Rosemead, CA. Prepared by KEMA Inc., Madison, WI.

December 23, 2004. CALMAC STUDY ID SCE0205 ma:project:scee0015 rarp 03 

evaluation:report:title.

KEMA, 2004. Final Report: Measurement and Evaluation Study of the 2002 Statewide 

Residential Appliance Recycling Program. February, 2004. Prepared for: Southern 

California Edison. February 13, 2004.

Kinney, Larry and Rana Belshe. 2001. Refrigerator Replacement in the Weatherization 

Program: Putting a Chill on Energy Waste: A special report for the Weatherization 

Assistance Program. E Source. September, 2001.

Market Transformation Programme. 2007. BNC11: Domestic Refrigerator Test Standard Vs 

Real-Use Energy Consumption. April 30, 2007. 

http://www.mtprog.com/SelectProductStrategy.aspx?intSelection=1&intSector=1

Meier, Alan, 1995. “Refrigerator energy use in the laboratory and in the field,” Energy and 

Buildings, 22, pp. 233-243.

Meier, A.. and R. Jansky. Field Performance of Residential Refrigerators: A Comparison with 

the Laboratory Test. 1991. Lawrence Berkeley Laboratory: Berkeley, CA. Report No.

LBL-31795.

Meier, A. and M. Martinez. Energy Use of Icemaking in Domestic Refrigerators. ASHRAE 

Transactions: Symposia. 1996. AT-96-19-2.
7-A-8

Meier. A., A. Megowan, B. Litt, and B. Pon. The New York State Residential Refrigerator 

Electrical Energy Monitoring Project: Final Report. 1993. Lawrence Berkeley National 

Laboratory: Berkeley, CA. Report No. LBL-33708.

Miller, J.D. and R.G. Pratt. Estimates of Refrigerator Loads in Public Housing Based on Metered 

Consumption Data. 1998. Pacific Northwest National Laboratory. Report No. PNNL11991.

Peterson, J., D. Dohrmann, T. Alereza, S. Samiullah, S. Westberg, and J.H. Redd. Gross Savings 

Estimation for Appliance Recycling Programs: the Lab Versus in situ Measurement 

Imbroglio and Related Issues. Proceedings of the 2007 International Energy Performance 

Evaluation Conference (IEPEC). 2007. Chicago, IL. August. Report 653. 17 pp.

Quantum Consulting. 1994. 1991 Refrigerator Rebate Program Metering Study for Southern 

California Edison, Final Report. P646.070.

Smit, Kevin L. 2006. 2005 Refrigerator/Freezer Recycling Program Evaluation. Snohomish 

County Public Utility District No. 1. March.

Topping, Richard F. and Edward A. Vineyard. 1982. Field Test of a High-Efficiency, AutomaticDefrost Refrigerator Freezer. Prepared by AD Little and ORNL for the ASHRAE SemiAnnual Meeting, Toronto Canada. June 27-July 1, 1982.
7B-i

APPENDIX 7-B. DATA FOR ESTIMATING DISTRIBUTION OF 

REFRIGERATOR AND FREEZER SIZE IN THE RECS SAMPLE

TABLE OF CONTENTS

7-B.1 INTRODUCTION ................................................................................................. 7-B-1

7-B.2 RESULTS .............................................................................................................. 7-B-1

LIST OF FIGURE

Figure 7-B.2.1 Models of Top Mount Freezer without through-the-door ice (Product 

Class 3)....................................................................................................... 7-B-2

Figure 7-B.2.2 Models of Bottom Mount Freezer without through-the-door ice 

(Product Class 5)........................................................................................ 7-B-3

Figure 7-B.2.3 Models of Side Mount Freezer with through-the-door ice (Product 

Class 7)....................................................................................................... 7-B-4

Figure 7-B.2.4 Models of Upright Freezer with automatic defrost (Product Class 9)....... 7-B-5

Figure 7-B.2.5 Models of Chest Freezers (Product Class 10)............................................ 7-B-6

Figure 7-B.2.6 Models of Compact Refrigerator and Refrigerator-Freezer with manual 

defrost (Product Class 11).......................................................................... 7-B-7

Figure 7-B.2.7 Models of Compact Chest Freezer (Product Class 18).............................. 7-B-8
7-B-1

APPENDIX 7-B. DATA FOR ESTIMATING DISTRIBUTION OF REFRIGERATOR 

AND FREEZER SIZE IN THE RECS SAMPLE

7-B.1 INTRODUCTION

DOE used the California Energy Commission (CEC) appliance database1 to determine 

the distribution of refrigerator and freezer volumes in the market. The Energy Information 

Administration’s (EIA) Residential Energy Consumption Surveys (RECS)2 provides the volumes 

of household refrigerators only within bins (ranges). In order to estimate the labeled energy 

consumption of a household’s standard-sized appliance, DOE selected a volume from within the 

appropriate RECS bin. DOE then selected a more precise volume randomly from the distribution 

of volumes within the RECS bin, basing the probability of selecting each volume on the number 

of models in the CEC database having that volume. The figures in this appendix show the 

volume distributions by number of models in the CEC database (narrower, solid bars in figures) 

and the distributions of refrigerator volumes reported by RECS respondents (wider, empty bars 

in figures). For each standard-sized refrigeration product DOE first identified the appropriate 

RECS bin and product class, then chose a more precise volume from the relevant part of the CEC 

distribution.

For compact products (product classes 11 and 18), for which DOE did not use a 

household sample, DOE used the distribution of volumes from the CEC database to characterize 

the distribution of volumes sold in the market and determine the distribution of energy use.

7-B.2 RESULTS

Figures 7-B.2.1 through 7-B.2.7 depict the volume distributions on the number of models 

in the CEC database and the distribution of refrigerator and freezer volumes reported in RECS.
7-B-2

0

100

200

300

400

500

600

700

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Total Volume (cu ft )

Frequency

CEC directory

RECS bins

Figure 7-B.2.1 Models of Top Mount Freezer without through-thedoor ice (Product Class 3)
7-B-3

0

20

40

60

80

100

120

140

160

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Total Volume (cu ft )

Frequency

CEC directory

RECS bins

Figure 7-B.2.2 Models of Bottom Mount Freezer without throughthe-door ice (Product Class 5)
7-B-4

0

100

200

300

400

500

600

700

800

900

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

Total Volume (cu ft )

Frequency

CEC directory

RECS bins

Figure 7-B.2.3 Models of Side Mount Freezer with through-thedoor ice (Product Class 7)
7-B-5

0

5

10

15

20

25

30

35

40

45

50

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Total Volume (cu ft )

Frequency

CEC directory

RECS bins

Figure 7-B.2.4 Models of Upright Freezer with automatic defrost 

(Product Class 9)
7-B-6

0

10

20

30

40

50

60

70

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Total Volume (cu ft )

Frequency

CEC directory

RECS bins

Figure 7-B.2.5 Models of Chest Freezers (Product Class 10)
7-B-7

0

10

20

30

40

50

60

70

1 2 3 4 5 6 7 8 9 10

Total Volume (cu ft )

Frequency

CEC directory

Figure 7-B.2.6 Models of Compact Refrigerator and RefrigeratorFreezer with manual defrost (Product Class 11)
7-B-8

0

5

10

15

20

25

30

1 2 3 4 5 6 7 8 9 10

Total Volume (cu ft )

Frequency

CEC directory

Figure 7-B.2.7 Models of Compact Chest Freezer (Product Class 

18)
7-B-9

REFERENCES

 1 California Energy Commission. Appliances Database—Refrigeration.

<www.energy.ca.gov/appliances/database/excel_based_files/Refrigeration/> (Last accessed April 25,

2009.)

2 U.S. Department of Energy–Energy Information Administration. Residential Energy 

Consumption Survey, 2005 Public Use Data Files. 2009. U.S. Department of Energy: 

Washington, D.C. <www.eia.doe.gov/emeu/recs/recspubuse05/pubuse05.html>
8A-i

APPENDIX 8-A. USER INSTRUCTIONS FOR LCC AND PBP SPREADSHEETS

TABLE OF CONTENTS

8-A.1 INTRODUCTION .................................................................................................8-A-1

8-A.1.1 Standard Size Refrigerator-Freezers and Freezers.................................................8-A-1

8-A.1.2 Compact Refrigerators and Compact Freezers......................................................8-A-2

8-A.2 BASIC INSTRUCTIONS......................................................................................8-A-3
8-A-1

APPENDIX 8-A. USER INSTRUCTIONS FOR LCC AND PBP SPREADSHEETS

8-A.1 INTRODUCTION

It is possible to examine and reproduce the detailed results of the life-cycle cost (LCC) 

and payback period (PBP) analyses using Microsoft Excel spreadsheets available on the U.S. 

Department of Energy’s website at:

To fully execute the spreadsheets requires both Microsoft Excel and Crystal Ball software. Both 

applications are commercially available. Crystal Ball is available at: 

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

http://www.decisioneering.com. 

The seven spreadsheets posted on the DOE website represent the latest versions and have

been tested with Microsoft Excel 2003. 

8-A.1.1 Standard Size Refrigerator-Freezers and Freezers

The Standard Size Refrigerator-Freezers and Freezers LCC and PBP spreadsheets or

workbooks consist of the following worksheets:

LCC Summary Contains the input selections and a summary table of energy use,

operating costs, LCC, and Payback. This worksheet also works as 

an interface between user inputs and the rest of the worksheets —

do not modify this sheet.

RECS Households For each RECS household being sampled, contains the equipment 

usage data, along with product characteristics (i.e., size, volume, 

product age) and household characteristics (e.g., Census division, 

income).

RECS UAF Contains the unit adjustment factor calculation which converts

tested energy consumption into field energy consumption.

Base Case Eff Dist Contains market efficiency distribution in the year the standard

takes effect.

Equipment Price Contains manufacturer price data for the considered design 

options. Also includes the manufacturer and retail mark-ups, sales 

tax.

Energy Use Contains unit energy use data (tested and field).

Energy Price Contains regional electricity prices for the reference year.
8-A-2

Energy Price Trend Contains the electricity price trends for the reference, high, and 

low economic growth scenarios based on AEO 2009.

Discount Rate Contains data from which an average discount rate and a 

distribution of discount rates are determined.

Lifetime Contains the survival function and average lifetime in years.

Standards Contains past and existing standards by product class along with 

historical trends of energy consumption prior to first standards.

AV Equations Contains average relation between volume and adjusted volume by 

product class.

ESAF Contains efficiency standard adjustment factor.

UAF Range Contains parameters allowing for the sample selection, and 

minimum and maximum UAF assignments. 

EStarModel Contains Energy Star model assigning energy star to households 

based on income.

8-A.1.2 Compact Refrigerators and Compact Freezers

The Compact Refrigerators and Compact Freezers LCC and PBP spreadsheet or

workbook consists of the following worksheets:

LCC Summary Contains the input selections and a summary table of energy use,

operating costs, LCC, and Payback. This worksheet also works as 

an interface between user inputs and the rest of the worksheets —

do not modify this sheet.

Base Case Eff Dist Contains market efficiency distribution in the year the standard

takes effect.

Division Contains number of customers for residential and commercial 

sector by region.

Equipment Price Contains manufacturer price data for the considered design 

options. Also includes the manufacturer and retail mark-ups, sales 

tax.

Energy Use Contains unit energy use data (tested and field).

Energy Price Contains regional electricity prices for the reference year.
8-A-3

Energy Price Trend Contains the electricity price trends for the reference, high, and 

low economic growth scenarios based on AEO 2009.

Discount Rate Contains data from which an average discount rate and a 

distribution of discount rates are determined.

Lifetime Contains the survival function and average lifetime in years.

AV Equations Contains average relation between volume and adjusted volume by 

product class.

8-A.2 BASIC INSTRUCTIONS

Basic instructions for operating the LCC spreadsheets are as follows:

1. Once you have downloaded the LCC file from the Web, open the file using Excel. At the

bottom, click on the tab for sheet ‘LCC Summary’. 

2. Use Excel’s “View/Zoom” commands at the top menu bar to change the size of the

display to make it fit your monitor.

3. The user interacts with the spreadsheet by clicking choices or entering data using the

graphical interface that comes with the spreadsheet. Select choices from the various

inputs listed under "User Options" heading.

4. Under the "User Options" heading, select choices from the selection buttons and boxes

for the following: (1) type of calculation (Sample or Crystal Ball®), (2) energy price

Trend, (3) start year, and (4) efficiency market share scenario. By overwriting the code in 

the LCC summary sheet, a new discount rate or lifetime can be entered if a value other 

than the default value is wanted . The Department does not recommend saving the 

spreadsheet after the code is changed. 

5. To change inputs listed under "User Input", select the input you wish to change by either 

clicking on the appropriate button or selecting the appropriate input from the input box.

6. This spreadsheet gives the user two types of calculation methods:

a. If the "Sample Calc" is selected, then all calculations are performed for single input 

values, usually an average. The new results are shown on the same sheet as soon as 

the new values are entered.

b. Alternately, if the "CB Calculation" is selected, the spreadsheet generates results that 

are distributions. Some of the inputs are also distributions. The results from the LCC 

distribution are shown as single values and refer only to the results from the last 
8-A-4

Monte Carlo sample and are therefore not meaningful. To run the distribution version 

of the spreadsheet, the Microsoft Excel® add-in software called Crystal Ball® must 

be enabled.

To produce sensitivity results using Crystal Ball, simply select Run from the Run menu

(on the menu bar). To make basic changes in the run sequence, including altering the number of

trials, select Run Preferences from the Run menu. After each simulation run, the user needs to

select Reset (also from the Run menu) before Run can be selected again. Once Crystal Ball has

completed its run sequence it will produce a series of distributions. Using the menu bars on the

distribution results, it is possible to obtain further statistical information. The time taken to

complete a run sequence can be reduced by minimizing the Crystal Ball window in Microsoft

Excel. A step-by-step summary of the procedure for running a distribution analysis is outlined

below:

1. Find the Crystal Ball toolbar (at top of screen)

2. Click on Run from the menu bar

3. Select Run Preferences and choose from the following choices:

a. Monte Carloa

b. Latin Hypercube (recommended)

c. Initial seed choices and whether you want it to be constant between runs

d. Select number of Monte Carlo Trials (DOE suggests 10,000).

4. To run the simulation, follow the following sequence (on the Crystal Ball toolbar)

Run

Reset

Run

5. Now wait until the program informs you that the simulation is completed.

The following instructions are provided to view the output generated by Crystal Ball.

1. After the simulation has finished, to see the distribution charts generated, click on the

Windows tab bar that is labeled Crystal Ball.

2. The life-cycle cost savings and payback periods are defined as Forecast cells. The

frequency charts display the results of the simulations, or trials, performed by Crystal

Ball. Click on any chart to bring it into view. The charts show the low and high endpoints 

of the forecasts. The View selection on the Crystal Ball toolbar can be used to specify 

whether you want cumulative or frequency plots shown.

 

a Because of the nature of the program, there is some variation in results due to random sampling when Monte Carlo

or Latin Hypercube sampling is used.
8-A-5

3. To calculate the probability that a particular value of LCC savings will occur, either type

0 in the box by the left arrow, or move the arrow key with the cursor to 0 on the scale.

The value in the Certainty box shows the likelihood that the LCC savings will occur. To

calculate the certainty of payback period being below a certain number of years, choose

that value as the high endpoint. 

4. To generate a printout report, select Create Report from the Run menu. The toolbar 

choice of Forecast Windows allows you to select the charts and statistics in which you

are interested. For further information on Crystal Ball outputs, please refer to

Understanding the Forecast Chart in the Crystal Ball manual.
8B-i

APPENDIX 8-B. UNCERTAINTY AND VARIABILITY IN LCC ANALYSIS

TABLE OF CONTENTS

8-B.1 INTRODUCTION ................................................................................................. 8-B-1

8-B.2 UNCERTAINTY ................................................................................................... 8-B-1

8-B.3 VARIABILITY...................................................................................................... 8-B-1

8-B.4 APPROACHES TO UNCERTAINTY AND VARIABILITY ............................. 8-B-2

8-B.5 PROBABILITY ANALYSIS AND THE USE OF CRYSTAL BALL................. 8-B-2

LIST OF FIGURES

Figure 8-B.5.1 Normal Probability Distribution ................................................................ 8-B-3

Figure 8-B.5.2 Triangular Probability Distribution............................................................ 8-B-3

Figure 8-B.5.3 Uniform Probability Distribution............................................................... 8-B-3
8-B-1

APPENDIX 8-B. UNCERTAINTY AND VARIABILITY IN LCC ANALYSIS

8-B.1 INTRODUCTION

Analysis of an energy-efficiency standard involves calculations of impacts, for example, 

the impact of a standard on consumer life-cycle cost (LCC). In order to perform the calculation, 

the analyst must first: 1) specify the equation or model that will be used; 2) define the quantities 

in the equation; and 3) provide numerical values for each quantity. In the simplest case, the 

equation is unambiguous (contains all relevant quantities and no others), each quantity has a 

single numerical value, and the calculation results in a single value. However, unambiguity and 

precision are rarely the case. In almost all cases, the model and/or the numerical values for each 

quantity in the model are not completely known (i.e., there is uncertainty) or the model and/or 

the numerical values for each quantity in the model depend upon other conditions (i.e., there is 

variability).

Thorough analysis involves accounting for uncertainty and variability. While the 

simplest analysis involves a single numerical value for each quantity in a calculation, arguments 

can arise about what the appropriate value is for each quantity. Explicit analysis of uncertainty 

and variability is intended to provide more complete information to the decision-making process.

8-B.2 UNCERTAINTY

When making observations of past events or speculating about the future, imperfect 

knowledge is the rule rather than the exception. For example, the energy actually consumed by a 

particular appliance type (such as the average U.S. commercial air conditioner or heat pump) is 

not directly recorded, but rather estimated based upon available information. Even direct 

laboratory measurements have some margin of error. When estimating numerical values 

expected for quantities at some future date, the exact outcome is rarely known in advance.

8-B.3 VARIABILITY

Variability means that different applications or situations produce different numerical 

values when calculating a quantity. Specifying an exact value for a quantity may be difficult 

because the value depends on something else. For example, the number of hours an air 

conditioner is operated by a household depends upon the specific circumstances and behaviors of 

the occupants (e.g., number of persons, personal habits about how comfortable the person wants 

to be, etc.). Variability makes specifying an appropriate population value more difficult in as 

much as any one value may not be representative of the entire population. Surveys can be 

helpful here, and analysis of surveys can relate the variable of interest (e.g., hours of use) to 

other variables that are better known or easier to forecast (e.g., persons per household).
8-B-2

8-B.4 APPROACHES TO UNCERTAINTY AND VARIABILITY

This section describes two approaches to uncertainty and variability: 

• scenario analysis, and 

• probability analysis.

Scenario analysis uses a single numerical value for each quantity in a calculation, then 

changes one (or more) of the numerical values and repeats the calculation. A number of 

calculations are done, which provide some indication of the extent to which the result depends 

upon the assumptions. For example, the life-cycle cost of an appliance could be calculated for 

energy rates of 2, 8, and 14¢ per kWh. 

The advantages of scenario analysis are that each calculation is simple; a range of 

estimates is used; and crossover points can be identified. (An example of a crossover point is the 

energy rate above which the life-cycle cost is reduced, holding all other inputs constant. That is, 

the crossover point is the energy rate at which the consumer achieves savings in operating 

expense that more than compensate for the increased purchase expense.) The disadvantage of 

scenario analysis is that there is no information about the likelihood of each scenario.

Probability analysis considers the probabilities within a range of values. For quantities 

with variability (e.g., electricity rates in different households), surveys can be used to generate a 

frequency distribution of numerical values (e.g., the number of households with electricity rates 

at particular levels) to estimate the probability of each value. For quantities with uncertainty, 

statistical or subjective measures can be used to provide probabilities (e.g., manufacturing cost to 

improve energy efficiency to some level may be estimated to be $10 ± $3). 

The major disadvantage of the probability approach is that it requires more information, 

namely information about the shapes and magnitudes of the variability and uncertainty of each 

quantity. The advantage of the probability approach is that it provides greater information about 

the outcome of the calculations, that is, it provides the probability that the outcome will be in a 

particular range. 

Scenario and probability analysis provide some indication of the robustness of the policy 

given the uncertainties and variability. A policy is robust when the impacts are acceptable over a 

wide range of possible conditions.

8-B.5 PROBABILITY ANALYSIS AND THE USE OF CRYSTAL BALL

To quantify the uncertainty and variability that exist in inputs to the engineering, LCC, 

and payback period (PBP) analyses, the Department used Microsoft Excel spreadsheets 

combined with Crystal Ball, a commercially available add-in, to conduct probability analyses. 

The probability analyses used Monte Carlo simulation and probability distributions.
8-B-3

Simulation refers to any analytical method meant to imitate a real-life system, especially 

when other analyses are too mathematically complex or too difficult to reproduce. Without the 

aid of simulation, a spreadsheet model will only reveal a single outcome, generally the most 

likely or average scenario. Spreadsheet risk analysis uses both a spreadsheet model and 

simulation to automatically analyze the effect of varying inputs on outputs of the modeled 

system. One type of spreadsheet simulation is Monte Carlo simulation, which randomly 

generates values for uncertain variables again and again to simulate a model. Monte Carlo 

simulation was named for Monte Carlo, Monaco, where the primary attractions are casinos 

containing games of chance. Games of chance such as roulette wheels, dice, and slot machines, 

exhibit random behavior. The random behavior in games of chance is similar to how Monte 

Carlo simulation selects variable values at random to simulate a model. When you roll a die, you 

know that either a 1, 2, 3, 4, 5, or 6 will come up, but you do not know which for any particular 

roll. It's the same with the variables that have a known range of values but an uncertain value for 

any particular time or event (e.g., equipment lifetime, discount rate, and installation cost). 

For each uncertain variable (one that has a range of possible values), possible values are 

defined with a probability distribution. The type of distribution selected is based on the 

conditions surrounding that variable. Probability distribution types include: 

Figure 8-B.5.1 Normal Probability Figure 8-B.5.2 Triangular Figure 8-B.5.3 Uniform Probability

Distribution Probability Distribution

Distribution

During a simulation, multiple scenarios of a model are calculated by repeatedly sampling 

values from the probability distributions for the uncertain variables and using those values for the 

cell. Crystal Ball simulations can consist of as many trials (or scenarios) as desired—hundreds or 

even thousands. During a single trial, Crystal Ball randomly selects a value from the defined 

possibilities (the range and shape of the probability distribution) for each uncertain variable and 

then recalculates the spreadsheet.

NORMAL TRIANGULAR UNIFORM
8C-i

APPENDIX 8-C. CONSUMER RETAIL PRICE DISTRIBUTIONS FOR 

BASELINE REFRIGERATOR-FREEZERS AND FREEZERS 

TABLE OF CONTENTS

8-C.1 INTRODUCTION ................................................................................................. 8-C-1

8-C.2 DISTRIBUTION HISTOGRAMS......................................................................... 8-C-2

LIST OF FIGURES

Figure 8-C.2.1 Baseline Retail Price Distribution for Product Class 3 (Standard-sized 

Top-mount Refrigerator-Freezers without Through-the-door Service)..... 8-C-2

Figure 8-C.2.2 Baseline Retail Price Distribution for Product Class 5 (Standard-sized 

Bottom-mount Refrigerator-Freezers without Through-the-door 

Service) ...................................................................................................... 8-C-3

Figure 8-C.2.3 Baseline Retail Price Distribution for Product Class 7 (Standard-sized 

Side-mount Refrigerator-Freezers with Through-the-door Service) ......... 8-C-4

Figure 8-C.2.4 Baseline Retail Price Distribution for Product Class 9 (Standard-sized 

Upright Freezers) ....................................................................................... 8-C-5

Figure 8-C.2.5 Baseline Retail Price Distribution for Product Class 10 (Standard-sized 

Chest Freezers)........................................................................................... 8-C-6

Figure 8-C.2.6 Baseline Retail Price Distribution for Product Class 11 (Compact 

Refrigerators)............................................................................................. 8-C-7

Figure 8-C.2.7 Baseline Retail Price Distribution for Product Class 18 (Compact 

Freezers)..................................................................................................... 8-C-8
8-C-1

APPENDIX 8-C. CONSUMER RETAIL PRICE DISTRIBUTIONS FOR BASELINE 

REFRIGERATOR-FREEZERS AND FREEZERS

8-C.1 INTRODUCTION

DOE’s engineering analysis did not attempt to estimate the manufacturing cost for 

baseline models. Instead, it developed incremental increases in manufacturer selling price 

associated with increases in efficiency levels. This approach required DOE to estimate retail 

prices for the baseline model in each product class. 

DOE drew upon proprietary retail price data collected by The NPD Group.1 These data 

reflect retail prices and sales at a large number of retail outlets in the United States (including 

over 50 percent of retail sales), and include information regarding model number, refrigerated 

volume, configuration of doors and ice-making, and whether the unit is an ENERGY STAR 

product. The data include enough information to assign each model to the correct product class. 

Standard-size refrigerators and freezers only contain models with capacity greater than 7.75 

cubic feet, whereas compact refrigerators consist of any types of refrigerators with capacity less 

than 7.75 cubic feet. DOE first converted all the selling prices to 2008 dollar value and then 

developed a sales-weighted price distribution for non-ENERGY STAR appliances in each 

product class from this data. For the purpose of developing retail price distribution for baseline 

products only, DOE excluded the built-in models under product classes 5, 7 and 9.a DOE 

grouped models by selling price in bins of varying width (generally $25 for compact products 

and $50 to $100 for standard-sized products) in order to balance the accuracy and usability of the 

distributions. These distributions are shown in the following section. 

DOE assumed that prices for non-ENERGY STAR models are a reasonable 

approximation of prices for the baseline models. These models may be “baseline” in efficiency, 

but span a wide range of other features and materials, and therefore have a broad distribution of 

prices. DOE also excluded sales above price threshold that was considered similar to built-in 

prices for product classes 7 and 11 (at $4,950 and $550 respectively), which removed less than 1 

percent of sales in each case. DOE chose not to develop volume-dependent baseline retail prices 

because the data did not show a strong relationship between volume and retail price. The price 

distributions within most volume ranges and product classes are almost as broad as the volumeindependent distributions DOE chose to use, and regression analysis indicated very weak 

dependence of average price on volume.

 

a

Based on the guidance from industry experts, built-ins include all models from Subzero, Viking and Thermador. 

Other manufacturers of built-ins also produce non-built-in products, so those could not be excluded based on brand, 

and were included in the distributions.
8-C-2

8-C.2 DISTRIBUTION HISTOGRAMS

Figure 8-C.2.1 Baseline Retail Price Distribution for Product Class 

3 (Standard-sized Top-mount Refrigerator-Freezers 

without Through-the-door Service)

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

$150$250$350$450$550$650$750$850$950

$1,050$1,150$1,250$1,350$1,450$1,550$1,650$1,750$1,850$1,950$2,050$2,150$2,250$2,350$2,450$2,550$2,650$2,750$2,850$2,950$3,500$4,500

Percent of Sales

Selling Price
8-C-3

Figure 8-C.2.2 Baseline Retail Price Distribution for Product Class 

5 (Standard-sized Bottom-mount RefrigeratorFreezers without Through-the-door Service)

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

35.00%

40.00%

45.00%

50.00%

$150$350$550$750$950

$1,150$1,350$1,550$1,750$1,950$2,150$2,350$2,550$2,750$2,950$3,150$3,350$3,550$3,750$3,950$4,150$4,350$4,550$4,750$4,950$5,300$5,700

Percent of Sales

Selling Price
8-C-4

Figure 8-C.2.3 Baseline Retail Price Distribution for Product Class 

7 (Standard-sized Side-mount Refrigerator-Freezers 

with Through-the-door Service)

0.00%

2.00%

4.00%

6.00%

8.00%

10.00%

12.00%

14.00%

16.00%

18.00%

20.00%

$150$350$550$750$950

$1,150$1,350$1,550$1,750$1,950$2,150$2,350$2,550$2,750$2,950$3,150$3,350$3,550$3,750$3,950$4,150$4,350$4,550$4,750$4,950

Percent of Sales

Selling Price
8-C-5

Figure 8-C.2.4 Baseline Retail Price Distribution for Product Class 

9 (Standard-sized Upright Freezers)

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

$75

$175$275$375$475$575$675$775$875$975

$1,075$1,175$1,275$1,375$1,475$1,650$1,850$2,050$2,250$2,450$2,650$2,850$3,250$4,250$5,250$6,250

Percent of Sales

Selling Pirce
8-C-6

Figure 8-C.2.5 Baseline Retail Price Distribution for Product Class 

10 (Standard-sized Chest Freezers)

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

35.00%

40.00%

Percent of Sales

Selling Price
8-C-7

Figure 8-C.2.6 Baseline Retail Price Distribution for Product Class 

11 (Compact Refrigerators)

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

Percent of Sales

SellingPrice
8-C-8

Figure 8-C.2.7 Baseline Retail Price Distribution for Product Class 

18 (Compact Freezers)

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

$25$50$75

$100$125$150$175$200$225$250$275$300$325$350$375$400$425$450$475$500$750

$1,500$2,500$3,500

Percent of Sales

Selling Price
8-C-9

REFERENCES

 1 The NPD Group, Inc., The NPD Group/NPD Houseworld – POS, Refrigerators, Freezers 

January – December 2007, 2008. Port Washington, NY.
8-D-i

APPENDIX 8-D. DISTRIBUTIONS USED FOR DISCOUNT RATES

TABLE OF CONTENTS

8-D.1 INTRODUCTION .................................................................................................8-D-1

8-D.2 DISTRIBUTION OF MORTGAGE INTEREST RATES ....................................8-D-1

8-D.3 DISTRIBUTION OF RATES FOR TYPES OF DEBT AND EQUITY USED 

TO FINANCE REPLACEMENT HEATING PRODUCTS .................................8-D-1

8-D.4 DISTRIBUTION OF RATES FOR TYPES OF EQUITY USED TO 

FINANCE REPLACEMENT HEATING PRODUCTS .......................................8-D-4

LIST OF FIGURES

Figure 8-D.2.1 Distribution of New Home Mortgage Interest Rates.................................8-D-1

Figure 8-D.3.1 Distribution of Home Equity Loan Interest Rates .....................................8-D-2

Figure 8-D.3.2 Distribution of Credit Card Interest Rates.................................................8-D-2

Figure 8-D.3.3 Distribution of Installment Loan Interest Rates.........................................8-D-3

Figure 8-D.3.4 Distribution of Other Residence Loan Interest Rates................................8-D-3

Figure 8-D.3.5 Distribution of Other Lines of Credit Loan Interest Rates ........................8-D-4

Figure 8-D.4.1 Distribution of Annual Rate of Return on CDs .........................................8-D-5

Figure 8-D.4.2 Distribution of Annual Rate of Return on Savings Bonds.........................8-D-5

Figure 8-D.4.3 Distribution of Annual Rate of Return on Corporate AAA Bonds............8-D-6

Figure 8-D.4.4 Distribution of Annual Rate of Savings Accounts.....................................8-D-6

Figure 8-D.4.5 Distribution of Annual Rate of Return on S&P 500..................................8-D-7

Figure 8-D.4.6 Distribution of Annual Rate of Return on Mutual Funds..........................8-D-7
8-D-1

APPENDIX 8-D. DISTRIBUTIONS USED FOR DISCOUNT RATES

8-D.1 INTRODUCTION

DOE derived discount rates for the LCC analysis using data on interest or return rates for 

various types of debt and equity. To account for variation among households in rates for each of 

the types, DOE sampled a rate for each household from a distribution of rates for each debt and 

equity type. This appendix describes the distributions used.

8-D.2 DISTRIBUTION OF MORTGAGE INTEREST RATES

Figure 8-D.2.1 shows the distribution of real interest rates for new home mortgages.

The data source DOE used for mortgage interest rates is the Federal Reserve Board’s Survey of 

Consumer Finances (SCF) in 1989, 1992, 1995, 1998, 2001, 2004, and 2007.

1 Using the 

appropriate SCF data for each year, DOE adjusted the nominal mortgage interest rate for each 

relevant household in the SCF for mortgage tax deduction and inflation. In cases where the 

effective interest rate is equal to or below the inflation rate (resulting in a negative real interest 

rate), DOE set the real effective interest rate to zero.

Figure 8-D.2.1 Distribution of New Home Mortgage Interest Rates

8-D.3 DISTRIBUTION OF RATES FOR TYPES OF DEBT AND EQUITY USED 

TO FINANCE REPLACEMENT HEATING PRODUCTS

Figure 8-D.3.1 through Figure 8-D.3.5 show the distribution of real interest rates for 

different types of debt used to finance replacement heating products. The data source for the 

0%

5%

10%

15%

20%

25%

30%

Probability

Real Interest Rate
8-D-2

interest rates for home equity loans, credit cards, installment loans, other residence loans, and 

other lines of credit is the Federal Reserve Board’s SCF in 1989, 1992, 1995, 1998, 2001, 2004, 

and 2007.

1 DOE adjusted the nominal rates to real rates using the annual inflation rate in each 

year. For home equity loans, DOE calculated effective interest rates in a similar manner as for 

mortgage rates, since interest on such loans is tax deductible.

Figure 8-D.3.1 Distribution of Home Equity Loan Interest Rates

Figure 8-D.3.2 Distribution of Credit Card Interest Rates

0%

5%

10%

15%

20%

25%

30%

Probability

Real Interest Rate

0%

1%

2%

3%

4%

5%

6%

7%

8%

9%

10%

Probability

Real Interest Rate
8-D-3

Figure 8-D.3.3 Distribution of Installment Loan Interest Rates

Figure 8-D.3.4 Distribution of Other Residence Loan Interest Rates

0%

5%

10%

15%

20%

25%

30%

35%

40%

Probability

Real Interest Rate

0%

2%

4%

6%

8%

10%

12%

14%

16%

18%

20%

Probability

Real Interest Rate
8-D-4

Figure 8-D.3.5 Distribution of Other Lines of Credit Loan Interest 

Rates

8-D.4 DISTRIBUTION OF RATES FOR TYPES OF EQUITY USED TO 

FINANCE REPLACEMENT HEATING PRODUCTS

Figure 8-D.4.1 through Figure 8-D.4.6 show the distribution of real interest rates for 

different types of equity used to finance replacement furnaces. Data for equity classes are not 

available from the Federal Reserve Board’s SCF, so DOE derived data for these classes from 

national-level historical data. The interest rates associated with certificates of deposit (CDs),2

savings bonds,3 and AAA corporate bonds4 are from Federal Reserve Board time-series data 

covering 1977 to 2009. DOE assumed rates on checking accounts to be zero. Rates on savings 

and money market accounts are from Cost of Savings Index data covering 1984 to 2009.

5 The 

rates for stocks are the annual returns on the Standard and Poor’s (S&P) 500 from 1977 to 2009.

6

The mutual fund rates are a weighted average of the stock rates (two-thirds weight) and the bond 

rates (one-third weight) in each year from 1977 to 2009. DOE adjusted the nominal rates to real 

rates using the annual inflation rate in each year.

0%

2%

4%

6%

8%

10%

12%

14%

Probability

Real Interest Rate
8-D-5

Figure 8-D.4.1 Distribution of Annual Rate of Return on CDs

Figure 8-D.4.2 Distribution of Annual Rate of Return on Savings 

Bonds

-2%

0%

2%

4%

6%

8%

Annual Rate of Return

Year

-2%

0%

2%

4%

6%

8%

Annual Rate of Return

Year
8-D-6

Figure 8-D.4.3 Distribution of Annual Rate of Return on Corporate 

AAA Bonds

Figure 8-D.4.4 Distribution of Annual Rate of Savings Accounts

-2%

0%

2%

4%

6%

8%

Annual Rate of Return

Year

-2%

0%

2%

4%

6%

8%

Annual Rate of Return

Year
8-D-7

Figure 8-D.4.5 Distribution of Annual Rate of Return on S&P 500

Figure 8-D.4.6 Distribution of Annual Rate of Return on Mutual 

Funds

-40%

-30%

-20%

-10%

0%

10%

20%

30%

40%

Annual Rate of Return

Year

-30%

-20%

-10%

0%

10%

20%

30%

Annual Rate of Return

Year
8-D-8

REFERENCES

1. The Federal Reserve Board, Survey of Consumer Finances 1989, 1992, 1995, 1998, 2001, 

2004, 2007. <http://www.federalreserve.gov/pubs/oss/oss2/scfindex.html>

2. The Federal Reserve Board, Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: CDs (secondary market), Maturity: 6-month, Frequency: 

Annual, Description: Average rate on 6-month negotiable certificates of deposit 

(secondary market), quoted on an investment basis, 2010. (Last accessed 2/25/10, 

<http://www.federalreserve.gov/releases/H15/data.htm>

3. The Federal Reserve Board, Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: State and local bonds, Maturity: 20-year, Frequency: 

Monthly, Description: Bond buyer go 20-bond municipal bond index, 2010. (Last 

accessed 2/25/10, <http://www.federalreserve.gov/releases/H15/data.htm>

4. The Federal Reserve Board, Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: Corporate bonds/Moody's Seasoned AAA, Frequency: 

Annual, Description: Moody's yield on seasoned corporate bonds - all industries, AAA, 

2010. (Last accessed 2/25/10, <http://www.federalreserve.gov/releases/H15/data.htm>

5. Mortgage-X - Mortgage Information Service, Cost of Savings Index (COSI) Index 

History, 2010. (Last accessed February 25, 2010.) <http://mortgagex.com/general/indexes/default.asp>

6. Damodaran Online Data Page, Historical Returns on Stocks, Bonds and Bills-United 

States, 2010. Damodaran. (Last accessed February 25, 2010.) 

<http://pages.stern.nyu.edu/~adamodar/>
9-A-i

APPENDIX 9-A. RELATIVE PRICE ELASTICITY OF DEMAND FOR 

APPLIANCES

TABLE OF CONTENTS

9-A.1 INTRODUCTION .................................................................................................9-A-1

9-A.2 LITERATURE REVIEW ......................................................................................9-A-1

9-A.2.1 Price .......................................................................................................................9-A-1

9-A.2.2 Income....................................................................................................................9-A-1

9-A.2.3 Appliance Efficiency and Discount Rates .............................................................9-A-2

9-A.3 VARIABLES DESCRIBING THE MARKET FOR REFRIGERATORS, 

CLOTHES WASHERS, AND DISHWASHERS .................................................9-A-3

9-A.3.1 Physical Household/Appliance Variables..............................................................9-A-3

9-A.3.2 Economic Variables...............................................................................................9-A-3

9-A.4 REGRESSION ANALYSIS OF VARIABLES AFFECTING APPLIANCE 

SHIPMENTS .........................................................................................................9-A-4

9-A.4.1 Broad Trends..........................................................................................................9-A-5

9-A.4.2 Model Specification...............................................................................................9-A-8

9-A.4.3 Model Discussion...................................................................................................9-A-9

9-A.4.4 Analysis Results.....................................................................................................9-A-9

9A.4.4.1 Individual Appliance Model ................................................................9-A-9

9A.4.4.2 Combined Appliance Model..............................................................9-A-10

9-A.4.5 Additional Regression Specifications and Results ..............................................9-A-11

9A.4.5.1 Lower Consumer Discount Rate........................................................9-A-11

9A.4.5.2 Disaggregated Variables....................................................................9-A-11

9-A.5 LONG RUN IMPACTS.......................................................................................9-A-12

9-A.6 SUMMARY.........................................................................................................9-A-13

9-A.7 DATA USED IN THE ANALYSIS ....................................................................9-A-14

LIST OF TABLES

Table 9-A.2.1 Estimates of the Impact of Price, Income and Efficiency on 

Automobile and Appliance Sales...............................................................9-A-2

Table 9-A.3.1 Physical Household/Appliance Variables..................................................9-A-3

Table 9-A.3.2 Economic Variables...................................................................................9-A-4

Table 9-A.4.1 Simple Estimate of Total Price Elasticity of Demand ...............................9-A-7

Table 9-A.4.2 Tabular Estimate of Relative Price Elasticity of Appliance Demand........9-A-8

Table 9-A.4.3 Individual Appliance Model Results .......................................................9-A-10

Table 9-A.4.4 Combined Appliance Model Result.........................................................9-A-10

Table 9-A.4.5 Combined and Individual Results, 20 percent discount rate....................9-A-11

Table 9-A.4.6 Disaggregated Regression Results, 37 percent discount rate...................9-A-12
9-A-ii

Table 9-A.5.1 Change in Price Elasticity of Demand for Automobiles following a 

Purchase Price Change.............................................................................9-A-13

Table 9-A.5.2 Change in Relative Price Elasticity for Home Appliances following a 

Purchase Price Change.............................................................................9-A-13

LIST OF FIGURE

Figure 9-A.3.1 Trends in Appliance Shipment, Housing Starts and Replacements...........9-A-4

Figure 9-A.4.1 Residual Shipments and Appliance Price ..................................................9-A-7
9-A-1

APPENDIX 9-A. RELATIVE PRICE ELASTICITY OF DEMAND FOR APPLIANCES

9-A.1 INTRODUCTION

This appendix summarizes DOE’s study of the price elasticity of demand for home 

appliances, including refrigerators, clothes washers and dishwashers. DOE chose this particular 

set of appliances because of the availability of data to determine a price elasticity. This appendix 

begins with a review of the existing economics literature describing the impact of economic 

variables on the sale of durable goods in section 9A.2. In section 9A.3, the market for home 

appliances and changes in it over the past 20 years is described. In section 9A.4, DOE

summarizes the results of its regression analysis and presents estimates of the price elasticity of 

demand for the three appliances. In section 9A.5, DOE presents development of an ‘effective’ 

purchase price elasticity. DOE’s interpretation of its results is presented in section 9A.6. 

Finally, section 9A.7 describes the data used in DOE’s analysis.

9-A.2 LITERATURE REVIEW

There are relatively few studies measuring the impact of price, income and efficiency on 

the sale of household appliances. In this section DOE provides a short review of this literature 

which suggests the likely importance of these variables.

9-A.2.1 Price

The goal of many of the studies covered in this review is to measure the impact of price 

on sales in a dynamic market. One study of the automobile market prior to 1970 finds the price 

elasticity of demand to decline over time. The author explains this as the result of buyers 

delaying purchases after a price increase but eventually making the purchase (Table 9A.2.1).1

 A 

contrasting study of household white goods also prior to 1970, finds the elasticity of demand to 

increase over time as more price-conscious buyers enter the market.2 A recent analysis of 

refrigerator market survey data finds that consumer purchase probability decreases with survey 

asking price.3

 Estimates of the price elasticity of demand for different brands of the same 

product tend to vary. A review of 41 studies of the impact of price on market share found the 

average price elasticity to be -1.75.4

9-A.2.2 Income

 The average estimate of price elasticity of demand reported 

in these studies is -0.33 in the appliance market and -0.47 in the combined automobile and 

appliance markets. 

Higher income households are more likely to own household appliances.5

 The impact of 

income on appliance shipments is explored in two econometric studies of the automobile and 

appliance markets. 1,2 The average income elasticity of demand is 0.50 in the appliance study 

cited in the literature review, much larger in the automobile study (Table 9.A.2.1).
9-A-2

9-A.2.3 Appliance Efficiency and Discount Rates

Many studies estimate the impact of appliance efficiency on consumer appliance choice. 

Typically, this impact is summarized by the implicit discount rate, i.e., the rate consumers appear 

to use to compare future appliance operating cost savings against an appliance purchase price 

premium.a One early and much cited study concludes that consumer behavior reflects a 20 

percent implicit discount rate when purchasing room air conditioners (Table 9A.2.1).6 A survey 

of several studies of different appliances suggests that the consumer implicit discount rate has a 

broad range and averages about 37 percent.

7

Table 9-A.2.1 Estimates of the Impact of Price, Income and Efficiency on Automobile 

and Appliance Sales

Durable Good

Price 

Elasticity

Income 

Elasticity

Brand 

Price 

Elasticity

Implicit 

Discount 

Rate Model

Data 

Years

Time 

Period

Automobiles1 -1.07 3.08 - - Linear Regression, stock 

adjustment - Short run

Automobiles1 -0.36 1.02 - - Linear Regression, stock 

adjustment - Long run

Clothes Dryers2 -0.14 0.26 - - Cobb-Douglas, diffusion 1947-1961 Mixed

Room Air 

Conditioners2 -0.378 0.45 - - Cobb-Douglas, diffusion 1946-1962 Mixed

Dishwashers2 -0.42 0.79 - - Cobb-Douglas, diffusion 1947-1968 Mixed

Refrigerators3 -0.37 - - 39% Logit probability, survey 

data 1997 Short run

Various4 - - -1.769 - Multiplicative regression - Mixed

Room Air 

Conditioners5 - - -1.72 - Non-linear diffusion 1949-1961 Short run

Clothes Dryers5 - - -1.32 - Non-linear diffusion 1963-1970 Short run

Room Air 

Conditioners6 - - - 20% Qualitative choice, survey data - -

Household 

Appliances7 - - - 37%10 Assorted - -

Sources: 1 S. Hymens. 1971; 2 P. Golder and G. Tellis, 1998; 3 D. Revelt and K. Train, 1997; 4 G. Tellis, 1988; 5 D. Jain and R. Rao; 6 J. Hausman; 7 K. Train, 1985.

Notes: 8 Logit probability results are not directly comparable to other elasticity estimates in this table.

9 Average brand price elasticity across 41 studies.

10 Averaged across several household appliance studies referenced in this work.

 

a A high implicit discount rate with regard to operating costs means that, based on market behavior, consumers 

appear to put relatively low economic value on the operating cost savings realized from more-efficient appliances. A 

high value may indicate lack of information, risk aversion and other factors as well as the value consumers place on 

savings accrued in the future.
9-A-3

9-A.3 VARIABLES DESCRIBING THE MARKET FOR REFRIGERATORS, 

CLOTHES WASHERS, AND DISHWASHERS

In this section DOE evaluates variables that appear to account for refrigerator, clothes 

washer and dishwasher shipments, including physical household/appliance variables, and 

economic variables.

9-A.3.1 Physical Household/Appliance Variables

Several variables influence the sale of refrigerators, clothes washers and dishwashers. 

The most important for explaining appliance sales trends are the annual number of new 

households formed (housing starts) and the number of appliances reaching the end of their 

operating life (replacements). Housing starts influence sales because new homes are often 

provided with, or soon receive, new appliances, including dishwashers and refrigerators. 

Replacements are correlated with sales because new appliances are typically purchased when old 

ones wear out. In principle, if households maintain a fixed number of appliances, shipments 

should equal housing starts plus appliance replacements. 

9-A.3.2 Economic Variables

Appliance price, appliance operating cost and household income are important economic 

variables affecting shipments. Low prices and costs encourage household appliance purchases 

and a rise in income increases householder ability to purchase appliances. In principle, changes 

in economic variables should explain changes in the number of appliances per household. 

During the 1980–2002 study period, annual shipments grew 69 percent for clothes 

washers, 81 percent for refrigerators and 105 percent for dishwashers (Table 9A.3.1). This rising 

shipments trend is explained in part by housing starts, which increased 6 percent and by 

appliance replacements, which rose between 49 percent and 90 percent, depending on the 

appliance, over the period (Table 9A.3.1).b

 For mature markets such as these, replacements 

exceed appliance sales associated with new housing construction.

Table 9-A.3.1 Physical Household/Appliance Variables 

Shipments1 (millions) Housing Starts2 (millions) Replacements3 (millions)

Appliance 1980 2002 Change 1980 2002 Change 1980 2002 Change

Refrigerators 5.124 9.264 81% 1.723 1.822 6% 3.93 5.84 49%

Clothes Washers 4.426 7.492 69% 1.723 1.822 6% 3.66 5.50 50%

Dishwashers 2.738 5.605 105% 1.723 1.822 6% 1.99 3.79 90% 1

Shipments: Number of units sold. Sources: AHAM Fact Book and Appliance Magazine. 2

Housing Starts: Annual number of new homes constructed. Source: U.S. Census. 3

Replacements: Average of annual lagged shipments, with lag equal to expected appliance operating life, ± 5 years.

 

b Appliance replacements are determined from the expected operating life of refrigerators (19 years), clothes 

washers (14 years), and dishwashers (12 years) and from past shipments. Replacements are further discussed in 

section 9A.3.
9-A-4

Nevertheless, it is apparent that appliance shipments increased somewhat more rapidly 

than housing starts and replacements. This is shown by comparing the beginning and end points 

of lines representing “starts plus replacements” (uppermost solid line in Figure 9A.3.1) and 

“shipments” (diamond linked line in Figure 9A.3.1). In 1980 the “shipment” line begins below 

the “starts plus replacements” line. In 2002, the “shipments” line ends above the “starts plus 

replacements” line. This more rapid increase in shipments, compared to housing starts plus 

replacements, suggests that the appliance per household ratio increased over the study period. 

Refrigerator Shipments

0

1

2

3

4

5

6

7

8

9

10

1980 1984 1988 1992 1996 2000

Millions 

New Housing

Retirements

Shipments

Clothes Washer Shipments

0

1

2

3

4

5

6

7

8

1980 1984 1988 1992 1996 2000

Millions 

Dishwasher Shipments

0

1

2

3

4

5

6

1980 1984 1988 1992 1996 2000

Millions 

Figure 9-A.3.1 Trends in Appliance Shipment, Housing Starts and 

Replacements

Economic variables, including price, cost and income, may explain this increase in 

appliances per household. Over the period, appliance prices decreased 40 percent to 50 percent, 

operating costs fell between 33 percent and 72 percent, and median household income rose 16 

percent (Table 9A.3.2). 

Table 9-A.3.2 Economic Variables

Price1 (1999$) Operating Cost2 (1999$) Household Income3 (1999$)

Appliance 1980 2002 Change 1980 2002 Change 1980 2002 Change

Refrigerators 1208 726 -40% 333 94 -72% 37,447 43,381 16%

Clothes Washers 779 392 -50% 262 175 -33% 37,447 43,381 16%

Dishwashers 713 369 -48% 183 95 -48% 37,447 43,381 16% 1

Price: Shipment weighted retail sales price. Sources: AHAM Fact Book and Appliance Magazine. 2

Operating Cost: Annual electricity price times electricity consumption. Source: AHAM Fact Book. 3

Income: Mean Household income. Source: U.S. Census.

9-A.4 REGRESSION ANALYSIS OF VARIABLES AFFECTING APPLIANCE 

SHIPMENTS

Little data is available for estimating the impact of economic variables on the demand for 

appliances. Industry operating cost data is incomplete—appliance energy use data is available 
9-A-5

for only 12 years of the 1980-2002 study period. Industry price data is also incomplete—

available for only 8 years of the study period for each of the appliances. 

The lack of data suggests that regression analysis can at best evaluate broad data trends, 

utilizing relatively few explanatory variables. This section begins by describing broad trends 

apparent in the economic and physical household data sets and then specifies a simple regression 

model to measure these trends, making assumptions to minimize the number of explanatory 

variables. Finally, results are presented of the regression analysis and the estimate of the price 

elasticity of demand for appliances. In this section (specifically section 9A.4.5), DOE also 

presents the results of regression analysis performed with more complex models, and used to test 

assumptions made to specify the simple model. These results support the simple model 

specification, and estimates of the price elasticity of appliance demand measured with that 

model. 

9-A.4.1 Broad Trends

In this section DOE reviews trends in the physical household and economic data sets and 

posit a simple approach for estimating the price elasticity of appliance demand. As noted above, 

the physical household variables (starts and appliance replacements), explain most of the 

variability in appliance shipments over the period.c

 DOE assumes the rest of the variability in 

shipments (referred to as “residual shipments”) is explained by economic variables, and present a 

tabular method for measuring price elasticities described below. 

To illustrate this tabular approach, DOE defines two new variables—residual shipments 

and total price. Residual shipments are defined as the difference between shipments and 

physical household demand (starts plus replacements). Total price, represented by the following 

equation, is defined as appliance price plus the present value of lifetime appliance operating 

cost:

d

 

TP = PP + PVOC

where:

TP = Total price,

PP = Appliance purchase price, and

PVOC = Present value of operating cost.

 

c A log regression of the form: Shipments = a + b • Housing Starts + c • Retirements, indicates that these two 

variables explain 89 percent of the variation in refrigerator shipments, 97 percent of the variation in clothes washer 

shipments, and 97 percent of the variation in dishwasher shipments.

d Present value operating cost is calculated assuming a 19 year operating life for refrigerators, 14 year operating life 

for clothes washers, and a 12 year operating life for dishwashers. A 37 percent discount rate is used to sum annual 

operating costs into a present value operating cost.
9-A-6

Over the study period, residual shipments increase 30 percent for refrigerators, 19 percent for 

clothes washers, and 23 percent for dishwashers in proportion to total shipments. At the same 

time, total prices decline 47 percent, 45 percent and 48 percent for refrigerators, clothes washers,

and dishwashers, respectively. Assuming that total price explains the entire change in per 

household appliance usage, a rough estimate is calculated of the total price elasticity of demand 

equal to -0.48 for refrigerators, -0.32 for clothes washers and -0.37 for dishwashers (Table 

9A.4.1). 
9-A-7

Table 9-A.4.1 Simple Estimate of Total Price Elasticity of Demand

Residual Shipments (millions) Total Price (199$)

Appliance 1980 2002 Difference Change 1980 2002 Change Elasticity

Refrigerators -0.5 1.6 2.1 30% 1541 820 -61% -0.48

Clothes Washers -1.0 0.2 1.1 19% 1042 567 -59% -0.32

Dishwashers -1.0 -0.01 1.0 23% 896 464 -64% -0.37

The negative correlation between total price and residual shipments suggested by these 

negative price elasticities is illustrated in a graph of residual shipments on the y-axis and total 

price on the x-axis (Figure 9A.4.1). 

Refrigerators

400

800

1200

1600

2000

-2.0 -1.0 0.0 1.0 2.0

Total Price

Residual Shipments 

Clothes Washers

400

600

800

1000

1200

-1.5 -1.0 -0.5 0.0 0.5

Total Price

Residual Shipments 

Dishwashers

200

400

600

800

1000

-2.0 -1.5 -1.0 -0.5 0.0 0.5

Total Price

Residual Shipments 

Yellow points are observed price data; red points are interpolated price data.

Figure 9-A.4.1 Residual Shipments and Appliance Price

Household income rose during the study period, making it easier for households to 

purchase appliances. Assuming that a rise in income has a similar impact on shipments as a 

decline in price, the impact of income is incorporated by defining a third variable, termed 

relative price, calculated as total price divided by household income and represented by the 

following equation:e 

Income

TP

RP =

where:

RP = Relative price,

TP = Total price, and

Income = Household income.

 

e Recall that the income elasticity of demand cited in the literature review is 0.50 and the price elasticity of demand 

cited in the review averages -0.35. This suggests that combining the effects of income and price will yield an

elasticity less negative than price elasticity alone.
9-A-8

The percent decline in relative price for the three appliances divided by the percent decline in 

residual shipments suggests a rough estimate of relative price elasticity equal to -0.40 for 

refrigerators, -0.26 for clothes washers and -0.30 for dishwashers (Table 9A.4.2). 

Table 9-A.4.2 Tabular Estimate of Relative Price Elasticity of Appliance Demand

Residual Shipments (millions) Relative Price (1999$)

Appliance 1980 2002 Change 1980 2002 Change Elasticity

Refrigerators -0.532 1.597 30% 0.041 0.019 -74% -0.40

Clothes Washers -0.953 0.174 19% 0.028 0.013 -72% -0.26

Dishwashers -0.974 -0.005 23% 0.024 0.011 -76% -0.30

9-A.4.2 Model Specification

The limited price data suggests using a simple regression model to estimate the impact of 

economic variables on shipments, using few explanatory variables. The following equation 

chosen for this analysis includes one physical household variable (starts plus replacements) and 

one relative price variable (the sum of purchase price plus operating cost, divided by income). 

Ship = a + b× RP + c ×[Starts + Rplc] Eq. 9A.1

where:

Ship = Quantity of appliance sold,

RP = Relative price,

Starts = Number of new homes, and

Rplc = Number of appliances at the end of their operating life.

The natural logs are taken of all variables so that the estimated coefficients for each 

variable in the model may be interpreted as the percent change in shipments associated with the 

percent change in the variable. Thus, the coefficient b in this model is interpreted as the relative

price elasticity of demand for the three appliances. 

The following combined regression equation is used to estimate an average price 

elasticity of demand across the three appliances, using pooled data in a single regression. A 

combined regression specification is justified, given limited data availability and similarity in 

price and shipment behavior across appliances (see Figure 9A.4.1). Thus, the model represented 

by the combined regression equation is considered the basic model in DOE’s analysis of 

appliance shipments.

Ship = a + b× RP + c ×[Starts + Rplc]+ d ×CW + e × DW Eq. 9A.2

where:

CW = Quantity of clothes washers sold, and

DW = Quantify of dishwashers sold.
9-A-9

9-A.4.3 Model Discussion

The most important assumption used to specify this model is that changes in economic 

variables over the study period—income, price, and operating cost—are responsible for all 

observed growth in residual appliance shipments. In other words, DOE assumes other possible 

explanations, such as changing consumer preferences and increases in the quality of 

appliances—had no impact. This assumption seems unlikely but without additional data, the 

impact of this assumption on the price elasticity of demand cannot be measured. DOE effectively 

assumes that changes in consumer preferences and appliance characteristics, while affecting 

which specific models are purchased, have relatively little impact on the total number of 

appliances purchased in a year.

Three additional assumptions used to specify this model deserve comment. The relative

price variable is specified in the model, assuming that (1) the correct implicit discount rate is 

used to combine appliance price and operating cost and that (2) rising income has the same 

impact on shipments as falling total price. The “starts + replacements” variable is specified, 

assuming (3) that starts and replacements have similar impacts on shipments. 

To investigate the first assumption about discount rates, DOE calculated “present value 

operating cost” using a 20 percent implicit discount rate and performed a second regression 

analysis based on the models described in equations. 9A.1 and 9A.2. The results of this analysis, 

presented in section 9A.4.5, indicate that the elasticity of relative price is relatively insensitive to 

changes in the discount rate. 

To investigate the second and third assumptions, DOE specified a regression model 

separating income from total price and replacements from starts, thus adding two additional 

explanatory variables to the basic model as shown in the following equation:

Ship = a + b×TP + c × Incone + d × Start + e × Rplc + f ×CW + g × DW Eq. 9A.3

The results of the regression analysis of this model are also presented in section 9A.4.5. 

These results suggest that the elasticity of total price (coefficient b) is relatively insensitive to 

changes in the treatment of income and “starts + replacements” in the model. 

9-A.4.4 Analysis Results

9A.4.4.1 Individual Appliance Model

The individual appliance regression equations are specified as followed (as shown earlier 

as Eq. 9A.1):

Ship = a + b× RP + c ×[Starts + Rplc]

In regression analysis of this model, the elasticity of relative price (b) is estimated to be
9-A-10

-0.40 for refrigerators, -0.31 for clothes washers and -0.32 for dishwashers (Table 9A.4.3), 

averaging -0.35. These elasticities are similar to those reported in the literature survey for 

appliances (Table 9A.2.1). They are remarkably similar to the price elasticity calculated using a 

tabular approach presented above (Table 9A.4.2). 

The estimated coefficient associated with the “starts + replacements” variable is close to 

one. A coefficient equal to one for this variable would imply that shipments increase in direct 

proportion to an increase in “starts + replacements”, holding economic variables constant. The 

high R squared values (above 95) and t statistics (above 5) in the results provide a measure of 

confidence in this analysis, despite the very small data set.

Table 9-A.4.3 Individual Appliance Model Results

Refrigerator Clothes Washer Dishwasher

Variable Coefficient t-stat Coefficient t-stat Coefficient t-stat

Intercept -1.51 -7.26 -1.47 -8.23 -2.08 -16.78

Relative Price -0.40 -6.60 -0.31 -5.69 -0.32 -7.03

Starts + Replacements 1.05 5.90 1.08 6.41 1.35 11.46

R2 0.954 0.954 0.975

Observations 23 23 23

9A.4.4.2 Combined Appliance Model

The combined appliance regression equation is specified as follows (as shown earlier as 

Eq. 9A.2):

Ship = a + b× RP + c ×[Starts + Rplc]+ d ×CW + e × DW

This regression analysis indicates that the model fits the existing shipments data well 

(high R squared) and that the variables included in the model are statistically significant (Table 

9A.4.4). The elasticity of relative price estimated with this model is -0.34, close to the average 

value estimated in the individual appliance models (-0.35). It is also similar to elasticity 

estimates reported in the literature survey and calculated using the tabular approach above. 

Table 9-A.4.4 Combined Appliance Model Result

Variable Coefficient t-stat

Intercept -1.60 -15.54

Relative Price -0.34 -10.74

Starts + Replacements 1.21 13.95

CW -0.20 -9.04

DW -0.32 -6.58

R2 0.983

Observations 69
9-A-11

9-A.4.5 Additional Regression Specifications and Results

As described above in section 9A.4.3, DOE used three assumptions to specify its 

appliance models. The first is that the implicit price variable in the basic regression model is 

specified using a 37 percent implicit discount rate, to aggregate appliance price and operating 

cost. The second states that the implicit price variable is defined assuming that rising income has 

the same impact on shipments as falling total price. The third states that the “starts +

replacements” variable is defined assuming that housing starts have a similar impact on 

shipments as appliance replacements. 

9A.4.5.1 Lower Consumer Discount Rate

To investigate the first assumption about discount rates, DOE calculated “present value

operating cost” using a 20 percent implicit discount rate and performed a second regression 

analysis based on the models described in equations 9A.1 and 9A.2. The estimated coefficient 

associated with the relative price variable in these regressions is almost identical to the 

coefficients estimated for same variable reported above using a 37 percent implicit discount rate. 

The elasticity of relative price calculated using a 20 percent discount rate is -0.33 in the 

combined regression and averages -0.35 for the three appliances (Table 9A.4.5). The elasticity 

of price calculated using a 37 percent discount rate is -0.34 in the combined regression and 

averages -0.35 for the three appliances. DOE concludes from this analysis that the elasticity of 

relative price is relatively insensitive to changes in the discount rate. 

Table 9-A.4.5 Combined and Individual Results, 20 percent discount rate

Three Appliances

Variable Coefficient t-Stat

Intercept -1.53 -14.61

Total Price / Income -0.33 -10.69

Starts + Retirements 1.20 13.65

CW -0.18 -8.69

DW -0.32 -6.57

R2 0.982

Observations 69

Refrigerator Clothes Washers Dishwasher

Variable Coefficient t-Stat Coefficient t-Stat Coefficient t-Stat

Intercept -1.36 -6.26 -1.41 -7.49 -2.04 -17.23

Total Price / Income -0.38 -6.50 -0.32 -5.29 -0.33 -7.30

Starts + Retirements 1.04 5.73 1.06 5.83 1.34 11.64

R2 0.953 0.950 0.977

Observations 23 23 23

9A.4.5.2 Disaggregated Variables

To investigate the second and third assumptions, DOE constructed a regression model 

separating income from total price and replacements from starts, thus adding two additional 

explanatory variables to the basic model (as shown earlier as Eq. 9A.3).
9-A-12

Ship = a + b×TP + c × Incone + d × Start + e × Rplc + f ×CW + g × DW

The estimated coefficient associated with the total price variable in these regressions is 

almost identical to the coefficients estimated for the relative price variable reported above. The 

elasticity of total price in the above equation is -0.36 in the combined appliance regression and 

averages -0.35 for the three appliances (Table 9A.4.6). The elasticity of relative price based on 

the model described in equation 9A.2 is -0.34 in the combined regression (Table 9A.4.4) and 

averages -0.35 across the individual appliances (Table 9A.4.3). DOE concludes that the price 

elasticity calculated in this analysis is relatively insensitive to the specification of household 

income and “starts + replacements” variables in the model. 

Table 9-A.4.6 Disaggregated Regression Results, 37 percent discount rate

Three Appliances

Variable Coefficient t-Stat

Intercept -2.92 -1.26

Income 0.58 2.92

Total Price -0.36 -7.06

Housing Starts 0.44 10.02

Retirements 0.62 8.12

CW -0.24 -9.25

DW -0.46 -7.68

R2 0.985

Observations 69

Refrigerator Clothes Washers Dishwasher

Variable Coefficient t-Stat Coefficient t-Stat Coefficient t-Stat

Intercept -6.19 -2.24 -6.64 -1.63 1.00 0.23

Income 0.89 3.80 0.87 2.31 0.20 0.52

Total Price -0.35 -5.48 -0.27 -2.51 -0.43 -5.18

Housing Starts 0.41 7.38 0.25 3.29 0.62 8.24

Retirements 0.56 6.06 0.56 2.09 0.65 5.86

R2 0.984 0.958 0.979

Observations 23 23 23

9-A.5 LONG RUN IMPACTS

As noted above in Table 9A.2.1 in section 9A.2, the literature review provides price 

elasticities over short and long time periods, also referred to as short run and long run price 

elasticities. As noted in the first two rows of Table 9A.2.1, one source (i.e., Hymans) shows that 

the price elasticity of demand is significantly different over the short run and long run for 

automobiles.

1

 Because DOE’s forecasts of shipments and national impacts due to standards is 

over a 30-year time period, consideration must be given as to how the relative price elasticity is 

affected once a new standard takes effect. 

DOE considers the relative price elasticities determined above in section 9A.4 to be short 

run elastcities. DOE was unable to identify sources specific to household durable goods, such as 

appliances, to indicate how short run and long run price elasticities differ. Therefore, to estimate 

how the relative price elasticity changes over time, DOE relied on the Hymans study pertaining 

to automobiles. Based on the Hymans study, Table 9A.5.1 shows how the automobile price 
9-A-13

elasticity of demand changes in the years following a purchase price change. With increasing 

years after the price change, the price elasticity becomes more inelastic until it reaches a terminal 

value around the tenth year after the price change.

Table 9-A.5.1 Change in Price Elasticity of Demand for Automobiles following a Purchase 

Price Change

Years Following Price Change

1 2 3 5 10 20

Price Elasticity of Demand -1.20 -0.93 -0.75 -0.55 -0.42 -0.40

Relative Change in 

Elasticity to 1st year

1.00 0.78 0.63 0.46 0.35 0.33

Source: Hymans, 1971.

Based on the relative change in the automobile price elasticity of demand shown in Table 

9A.5.1, DOE developed a time series of relative price elasticities for home appliances. Table 

9A.5.2 presents the time series. 

Table 9-A.5.2 Change in Relative Price Elasticity for Home Appliances following a 

Purchase Price Change

Years Following Price Change

1 2 3 5 10 20

Relative Change in 

Elasticity to 1st year

1.00 0.78 0.63 0.46 0.35 0.33

Relative Price Elasticity -0.34 -0.26 -0.21 -0.16 -0.12 -0.11

9-A.6 SUMMARY

This appendix describes the results of a literature search, tabular analysis and regression 

analysis of the impact of price and other variables on appliance shipments. In the literature, 

DOE finds only a few studies of appliance markets that are relevant to this analysis, and no 

studies using time series price and shipments data after 1980. The information that can be 

summarized from the literature, suggests that the demand for appliances is price inelastic. Other 

information in the literature suggests that appliances are a normal good, such that rising incomes 

increase the demand for appliances. Finally, the literature suggests that consumers use relatively 

high implicit discount rates, when comparing appliance prices and appliance operating costs. 

There is not enough price and operating cost data available to perform complex analysis 

of dynamic changes in the appliance market. In this analysis, DOE uses data available for 

refrigerators, clothes washers and dishwashers to evaluate broad market trends and to perform 

simple regression analysis. 

These data indicate that there has been a rise in appliance shipments and a decline in 

appliance price and operating cost over the period. Household income has also risen during this 

time. To simplify the analysis, DOE combined the available economic information into one 
9-A-14

variable, termed relative price, and used this variable in a tabular analysis of market trends, and a 

regression analysis.

DOE’s tabular analysis of trends in the number of appliances per household suggests that 

the price elasticity of demand for the three appliances is inelastic. Our regression analysis of 

these same variables suggests that the relative price elasticity of demand is -0.34. The price 

elasticity is consistent with estimates in the literature. Nevertheless, DOE stresses that the 

measure is based on a small data set, using very simple statistical analysis. More important, the 

measure is based on an assumption that economic variables, including price, income and 

operating costs, explain most of the trend in appliances per household in the United States since 

1980. Changes in appliance quality and consumer preferences may have occurred during this 

period, but they are not accounted for in this analysis. 

9-A.7 DATA USED IN THE ANALYSIS

• Appliance Shipments: Shipments are defined as the annual number of units shipped in 

millions. These data were collected from the Association of Home Appliance Manufacturers 

(AHAM)

8 and Appliance Magazine9 as annual values for each year, 1980–2002. AHAM 

was used for the period 1989–2002 while Appliance Magazine was used for the period 1980–

1988.

• Appliance Price: Price is defined as the shipments weighted retail sales price of the unit in 

1999 dollars. Price values for 1980, 1985, 1986, 1991, 1993, 1994, 1998, and 2002 were 

collected from AHAM Fact Books.

10 Price values for other years were interpolated from 

these eight years of data.

• Housing Starts: Housing starts data were collected from U.S. Census construction statistics 

(C25 reports) as annual values for each year, 1980–2002.11

• Replacements: Retirement-driven replacements are estimated with the assumption that some 

fraction of sales arise from consumers replacing equipment at the end of its useful life. Since 

each appliance has a different expected lifespan (19 years for refrigerators12, 14 years for 

clothes washers13, 12 years for dishwashers14), replacements are calculated differently for 

each appliance type. Replacements are estimated as the average of shipments 14–24 years 

previous for refrigerators, 9–19 years previous for clothes washers, and 7–17 years previous 

for dishwashers. Historical shipments data were collected from AHAM and Appliance 

Magazine.

• Annual Electricity Consumption: Electricity Use (UEC) is defined as the energy 

consumption of the unit in kilowatt-hours. Electricity consumption is dependent on appliance 

capacity and efficiency. These data were provided by AHAM for 1980, 1990–1997 and 

1999–2002.15 Data were interpolated in the years for which data were not available.
9-A-15

• Operating Cost: Operating Cost is the present value of the electricity consumption of an 

appliance over its expected lifespan. The lifespans of refrigerators, clothes washers and 

dishwashers are assumed to be 19, 14, and 12 years respectively. Discount rates of 20 

percent6 and 37 percent16 were used, producing similar estimates of price elasticity. A study 

by Hausman recommended a discount rate of “about 20 percent” in its introduction, and 

presented results ranging from 24.1 percent to 29 percent based on his calculations for room 

air conditioners. A study by Train suggests a range of implicit discount rates averaging 35 

percent for appliances.

• Income: Median annual household income in 2003 dollars. This data was collected for each 

year, 1980–2002, from Table H-6 of the U.S. Census.

17
9-A-16

REFERENCES

 1 S. Hymans. Consumer Durable Spending: Explanation and Prediction, Brookings Papers on 

Economic Activity, 1971. Vol. 1971, No. 1, pp. 234-239.

2 P. Golder and G. Tellis. Beyond Diffusion: An Affordability Model of the Growth of New 

Consumer Durables, Journal of Forecasting, 1998.

3 D. Revelt and K. Train. Mixed Logit with Repeated Choices: Household's Choice of 

Appliance Efficiency Level, Review of Economics and Statistics,1997.

4 G. Tellis. The Price Elasticity of Selective Demand: A Meta-Analysis of Econometric 

Models of Sales, Journal of Marketing Research, 1988.

5 U.S. Department of Energy-Energy Information Agency. The Effect of Income on Appliances 

in U.S. Households, 2002. Washington, DC. 

<http://www.eia.doe.gov/emeu/recs/appliances/appliances.html> 

6 J. Hausman. Individual discount rates and the purchase and utilization of energy using 

durables, The Bell Journal of Economics,1979.

7 K. Train. Discount rates in consumer' energy related decisions: a review of the literature, 

Energy, Vol. 10, No. 12, 1985, pp. 1243-1253.

8 Association of Home Appliance Manufacturers. AHAM Fact Books, 2000 and 2003. 

Washington, DC. 

9 Statistical Review. Appliance Magazine, April, 1990.

10 Association of Home Appliance Manufacturers. AHAM Fact Books, 1987, 1988, 1993, 1995, 

2000, and 2003. Washington, DC. 

11 U.S. Census Bureau. Current Construction Reports, C25 – New One-Family Houses Sold. 

Washington, DC. <http://www.census.gov/prod/www/abs/c25.html> 

12 Duemling, Reubin. Product Life of Refrigerators, 1999. University of California, Berkeley, 

Energy and Resources Group masters thesis.

13 U.S. Department of Energy-Office of Building Research and Standards. Final Rule Technical 

Support Document (TSD): Energy Efficiency Standards for Consumer Products: Clothes 

Washers, December, 2000. Washington, DC. Chapter 7.

14 U.S. Department of Energy-Office of Codes and Standards. Technical Support Document: 

Energy Conservation Standards for Consumer Products: Dishwashers, Clothes Washers, and 

Clothes Dryers, December, 1990. Washington, DC. DOE/CE-02999P. Chapter 4.
9-A-17

 

15 Association of Home Appliance Manufacturers. AHAM 2003 Fact Book, 2003. Washington, 

DC. 

16 K.E. Train and T. Atherton. Rebates, loans, and customers’ choice of appliance efficiency 

level: combining stated- and revealed-preference data. The Energy Journal, Vol. 16, No. 1, 

1995, pp. 55-69.

17 U.S. Census Bureau. Income, Historical Income Tables – Households, Table H-6. 

Washington, DC. <http://www.census.gov/hhes/www/income/histinc/inchhtoc.html>
10A-i

APPENDIX 10-A. USER INSTRUCTIONS FOR SHIPMENTS AND NIA 

SPREADSHEETS

TABLE OF CONTENTS

10-A.1 INTRODUCTION ...............................................................................................10-A-1

10-A.1.1 Standard-Size Refrigerator-Freezers....................................................................10-A-1

10-A.1.2 Standard-Size Freezers.........................................................................................10-A-2

10-A.1.3 Compact Refrigerators.........................................................................................10-A-3

10-A.1.4 Compact Freezers.................................................................................................10-A-4

10-A.2 BASIC INSTRUCTIONS....................................................................................10-A-5
10-A-1

APPENDIX 10-A. USER INSTRUCTIONS FOR SHIPMENTS AND NIA 

SPREADSHEETS

10-A.1 INTRODUCTION

The results obtained for the shipments analysis and the national impact analysis (NIA)

can be examined and reproduced using the Microsoft Excel spreadsheet available on the U.S. 

Department of Energy Building Technologies website

at: http://www.eere.energy.gov/buildings/appliance_standards/. 

There are a total of four NIA spreadsheets, one each for the following product types: 

standard-size refrigerator-freezers, standard-size freezers, compact refrigerators, and commercial 

compact freezers. The four spreadsheets posted on the DOE website represent the latest versions

and have been tested with Microsoft Excel 2003. 

To execute the spreadsheet requires Microsoft Excel 2003 or a later version. The NIA 

spreadsheet performs calculations to forecast the change in national energy use and net present 

value due to an energy conservation standard. The energy use and associated costs for a given 

standard are determined first by calculating the shipments and then calculating the energy use 

and costs for all equipment shipped under that standard. The differences between the standards 

and base cases can then be compared and the overall energy savings and present values 

determined. 

10-A.1.1 Standard-Size Refrigerator-Freezers

The standard-size refrigerator-freezer NIA spreadsheet or workbook consists of the 

following worksheets:

Input and Summary Contains user input selections under “User Inputs” and a summary

table, Cumulative Energy Savings and NPV for the selected 

standard level efficiency distribution. The sheet contains the 

efficiency levels being considered for standard-size refrigeratorfreezers and the associated incremental prices. This sheet also 

contains base and standards case efficiency trends for standard-size 

refrigerator-freezers, and efficiency weighted average energy use 

and equipment price for the base and standards cases.

Historical Shipment & Contains data for historical sales of standard-size refrigeratorMarket Share freezers by product class. The forecast market share between topmount and side/bottom-mount refrigerator-freezers is provided.

Base Case Contains the calculations for determining the shipments, energy 

consumption, and operating costs for the base case. The sheet starts 

with the stock accounting of the equipment and uses the survival 
10-A-2

function to calculate the surviving stock. It then performs 

calculations of replacements, and shipments going into new 

housing. The sheet calculates replacement units, shipments going 

into new units, and early replacement shipments, and aggregates 

them into total shipments.

Base Energy Calc Contains additional stock accounting calculations to properly 

allocate shipments, energy use, and costs to top-mount and 

side/bottom-mount refrigerator-freezers for the base case.

Standards Case Contains stock accounting of the equipment that calculates annual 

shipments estimates, energy savings, and operating cost savings for 

the standards case. The energy and cost savings in a single year are 

the difference between the base case energy use and costs and the

standard case energy use and costs for that year.

Standards Energy Calc Contains additional stock accounting calculations to properly 

allocate shipments, energy use, and costs to top-mount and 

side/bottom-mount refrigerator-freezers for the standards case.

Housing Projections Contains the projected new housing construction starts and total 

housing stock for the three economic scenarios (Reference, Low 

Growth, and High Growth). Also provides the early replacement 

rate.

Fuel Prices Contains projected average energy prices for the three economic 

scenarios. 

Heat Rates Contains the marginal site to source conversion factors that are 

used in the source energy savings calculations, for both electricity 

and gas.

Lifetime Contains the probability of survival of a standard-size refrigeratorfreezer at a given age and the average lifetime of a unit.

10-A.1.2 Standard-Size Freezers

The standard-size freezer NIA spreadsheet or workbook consists of the following 

worksheets:

Input and Summary Contains user input selections under “User Inputs” and a summary

table, Cumulative Energy Savings and NPV for the selected 

standard level efficiency distribution. The sheet contains the 

efficiency levels being considered for standard-size freezers and 

the associated incremental prices. This sheet also contains base 
10-A-3

and standards case efficiency trends for standard-size freezers, and 

efficiency weighted average energy use and equipment price for 

the base and standards cases.

Historical Shipment Contains data for historical sales of standard-size freezers by 

product class.

Base Case Contains the calculations for determining the shipments, energy 

consumption, and operating costs for the base case. The sheet starts 

with the stock accounting of the equipment and uses the survival 

function to calculate the surviving stock. It then performs 

calculations of replacements, and shipments going into new 

housing. The sheet calculates replacement units, shipments going 

into new units, and shipments going to first time owners (existing 

households that do not already own the product), and aggregates 

them into total shipments.

Standards Case Contains stock accounting of the equipment that calculates annual 

shipments estimates, energy savings, and operating cost savings for 

the standards case. The energy and cost savings in a single year are 

the difference between the base case energy use and costs and the

standard case energy use and costs for that year.

Housing Projections Contains the projected new housing construction starts and total 

housing stock for the three economic scenarios (Reference, Low 

Growth, and High Growth). Also provides the early replacement 

rate.

Fuel Prices Contains projected average energy prices for the three economic 

scenarios. 

Heat Rates Contains the marginal site to source conversion factors that are 

used in the source energy savings calculations, for both electricity 

and gas.

Lifetime Contains the probability of survival of a standard-size refrigeratorfreezer at a given age and the average lifetime of a unit.

10-A.1.3 Compact Refrigerators

The compact refrigerator NIA spreadsheet or workbook consists of the following 

worksheets:

Input and Summary Contains user input selections under “User Inputs” and a summary

table, Cumulative Energy Savings and NPV for the selected 
10-A-4

standard level efficiency distribution. The sheet contains the 

efficiency levels being considered for compact refrigerators and 

the associated incremental prices. This sheet also contains base 

and standards case efficiency trends for compact refrigerators, and 

efficiency weighted average energy use and equipment price for 

the base and standards cases.

Historical Shipment Contains data for historical sales of compact refrigerators by 

product class. Also provides historical saturations of compact 

refrigerators in lodging, residential, and commercial buildings.

Base Case Contains the calculations for determining the shipments, energy 

consumption, and operating costs for the base case. The sheet starts 

with the stock accounting of the equipment and uses the survival 

function to calculate the surviving stock. It then performs 

calculations of replacements, and shipments going into new 

housing, new lodging, and new commercial buildings, and 

aggregates them into total shipments.

Standards Case Contains stock accounting of the equipment that calculates annual 

shipments estimates, energy savings, and operating cost savings for 

the standards case. The energy and cost savings in a single year are 

the difference between the base case energy use and costs and the

standard case energy use and costs for that year.

Housing & Comm Flrspc Contains the projected new housing construction starts, total

Project housing stock, projected new commercial floorspace projections, 

and total lodging and commercial floorspace stock for the three 

economic scenarios (Reference, Low Growth, and High Growth).

Fuel Prices Contains projected average energy prices for the three economic 

scenarios. 

Heat Rates Contains the marginal site to source conversion factors that are 

used in the source energy savings calculations, for both electricity 

and gas.

Lifetime Contains the probability of survival of a standard-size refrigeratorfreezer at a given age and the average lifetime of a unit.

10-A.1.4 Compact Freezers

The compact freezer NIA spreadsheet or workbook consists of the following worksheets:
10-A-5

Input and Summary Contains user input selections under “User Inputs” and a summary

table, Cumulative Energy Savings and NPV for the selected 

standard level efficiency distribution. The sheet contains the 

efficiency levels being considered for compact freezers and the 

associated incremental prices. This sheet also contains base and 

standards case efficiency trends for compact freezers, and 

efficiency weighted average energy use and equipment price for 

the base and standards cases.

Historical Shipment Contains data for historical sales of compact freezers by product 

class. 

Base Case Contains the calculations for determining the shipments, energy 

consumption, and operating costs for the base case. The sheet starts 

with the stock accounting of the equipment and uses the survival 

function to calculate the surviving stock. It then performs 

calculations of replacements, and shipments going to first time 

owners (existing households that do not already own the product),

and aggregates them into total shipments.

Standards Case Contains stock accounting of the equipment that calculates annual 

shipments estimates, energy savings, and operating cost savings for 

the standards case. The energy and cost savings in a single year are 

the difference between the base case energy use and costs and the

standard case energy use and costs for that year.

Housing Projections Contains the projected new housing construction starts and total 

housing stock for the three economic scenarios (Reference, Low 

Growth, and High Growth). Housing data used solely to determine 

a compact freezer saturation in new housing.

Fuel Prices Contains projected average energy prices for the three economic 

scenarios. 

Heat Rates Contains the marginal site to source conversion factors that are 

used in the source energy savings calculations, for both electricity 

and gas.

Lifetime Contains the probability of survival of a standard-size refrigeratorfreezer at a given age and the average lifetime of a unit.

10-A.2 BASIC INSTRUCTIONS

Basic instructions for operating the NIA spreadsheets are as follows:
10-A-6

1. Once the NIA spreadsheets have been downloaded from the Web, open the file using

Excel. At the bottom, click on the tab for the worksheet ‘Input and Summary’.

2. Use Excel’s View/Zoom commands at the top menu bar to change the size of the display

to make it fit your monitor.

3. The user can change the model parameters listed in the grey box labelled “User Inputs”. 

The parameters are:

a. Lifetime: To change value, type in the desired value that lies within the maximum 

lifetime indicated.

b. Discounting future values: To change the value used for discounting NPV and 

national energy savings, and the year in which to discount to. 

c. Relative Price Elasticity: To change value, use the drop-down arrow and select 

the desired impact (this parameter is not considered in the cooking products 

analysis).

d. Economic Growth: To the change value, use the drop-down arrow and select the 

desired Growth level (Reference, Low, or High).

4. Once the parameters have been set, there are two options;

a. Click the “Select CSL’ button to choose which candidate standard level to 

analyze. The associated efficiency distributions and growth trends are fixed as 

specified in Chapter 10 of this preliminary technical support document. Once the 

CSL has been selected, click the “OK” button to make your selected CSL 

effective. (This option is not available for compact freezers.)

b. Click the “Set base case/Standards Case” button and define the efficiency 

distribution of the market, and the efficiency growth rate for both the base case 

and the standards case. Once the distribution and the growth rate have been set, 

click the “update” button to make your defined distribution effective.

5. The results are automatically updated and are reported in the summary table for each 

product class to the right of the “User Inputs” box.
10-B-i

APPENDIX 10-B. NATIONAL ENERGY SAVINGS AND NET PRESENT 

VALUE USING ALTERNATIVE ECONOMIC GROWTH SCENARIOS

TABLE OF CONTENTS

10-B.1 INTRODUCTION ...............................................................................................................1

10-B.2 NIA RESULTS IN HIGH ECONOMIC GROWTH SCENARIO......................................2

10-B.2.1 NES Results in High Economic Growth Scenario.............................................2

10-B.2.2 NPV Results in High Economic Growth Scenario ............................................4

10-B.3 NIA RESULTS IN LOW ECONOMIC GROWTH SCENARIO.......................................8

10-B.3.1 NES Results in Low Economic Growth Scenario .............................................8

10-B.3.2 NPV Results Using Low Economic Growth Scenario ......................................9

LIST OF TABLES

Table 10-B.2.1 Standard-Size Refrigerator-Freezers: Cumulative National 

Energy Savings in Quads, High Economic Growth Scenario..................................3

Table 10-B.2.2 Standard-Size Freezers: Cumulative National Energy Savings 

in Quads, High Economic Growth Scenario............................................................3

Table 10-B.2.3 Compact Refrigeration Products: Cumulative National Energy 

Savings in Quads, High Economic Growth Scenario ..............................................3

Table 10-B.2.4 Built-In Refrigeration Products: Cumulative National Energy 

Savings in Quads, High Economic Growth Scenario ..............................................4

Table 10-B.2.5 Cumulative Net Present Value of Consumer Benefits for 

Standard-Size Refrigerator-Freezers, 3-Percent Discount Rate, 

High Economic Growth Scenario ............................................................................4

Table 10-B.2.6 Cumulative Net Present Value of Consumer Benefits for 

Standard-Size Refrigerator-Freezers, 7-Percent Discount Rate, 

High Economic Growth Scenario ............................................................................5

Table 10-B.2.7 Cumulative Net Present Value of Consumer Benefits for 

Standard-Size Freezers, 3-Percent Discount Rate, High Economic 

Growth Scenario ......................................................................................................5

Table 10-B.2.8 Cumulative Net Present Value of Consumer Benefits for 

Standard-Size Freezers, 7-Percent Discount Rate, High Economic 

Growth Scenario ......................................................................................................5

Table 10-B.2.9 Cumulative Net Present Value of Consumer Benefits for 

Compact Refrigeration Products, 3-Percent Discount Rate, High 

Economic Growth Scenario .....................................................................................6

Table 10-B.2.10 Cumulative Net Present Value of Consumer Benefits for 

Compact Refrigeration Products, 7-Percent Discount Rate, High 

Economic Growth Scenario .....................................................................................6

Table 10-B.2.11 Cumulative Net Present Value of Consumer Benefits for BuiltIn Refrigeration Products, 3-Percent Discount Rate, High 

Economic Growth Scenario .....................................................................................7
10-B-ii

Table 10-B.2.12 Cumulative Net Present Value of Consumer Benefits for BuiltIn Refrigeration Products, 7-Percent Discount Rate, High 

Economic Growth Scenario .....................................................................................7

Table 10-B.3.1 Standard-Size Refrigerator-Freezers: Cumulative National 

Energy Savings in Quads, Low Economic Growth Scenario ..................................8

Table 10-B.3.2 Standard-Size Freezers: Cumulative National Energy Savings 

in Quads, Low Economic Growth Scenario ............................................................8

Table 10-B.3.3 Compact Refrigeration Products: Cumulative National Energy 

Savings in Quads, Low Economic Growth Scenario...............................................8

Table 10-B.3.4 Built-In Refrigeration Products: Cumulative National Energy 

Savings in Quads, Low Economic Growth Scenario...............................................9

Table 10-B.3.5 Cumulative Net Present Value of Consumer Benefits for 

Standard-Size Refrigerator-Freezers, 3-Percent Discount Rate, 

Low Economic Growth Scenario.............................................................................9

Table 10-B.3.6 Cumulative Net Present Value of Consumer Benefits for 

Standard-Size Refrigerator-Freezers, 7-Percent Discount Rate, 

Low Economic Growth Scenario...........................................................................10

Table 10-B.3.7 Cumulative Net Present Value of Consumer Benefits for 

Standard-Size Freezers, 3-Percent Discount Rate, Low Economic 

Growth Scenario ....................................................................................................10

Table 10-B.3.8 Cumulative Net Present Value of Consumer Benefits for 

Standard-Size Freezers, 7-Percent Discount Rate, Low Economic 

Growth Scenario ....................................................................................................10

Table 10-B.3.9 Cumulative Net Present Value of Consumer Benefits for 

Compact Refrigeration Products, 3-Percent Discount Rate, Low 

Economic Growth Scenario ...................................................................................11

Table 10-B.3.10 Cumulative Net Present Value of Consumer Benefits for 

Compact Refrigeration Products, 7-Percent Discount Rate, Low 

Economic Growth Scenario ...................................................................................11

Table 10-B.3.11 Cumulative Net Present Value of Consumer Benefits for BuiltIn Refrigeration Products, 3-Percent Discount Rate, Low 

Economic Growth Scenario ...................................................................................12

Table 10-B.3.12 Cumulative Net Present Value of Consumer Benefits for BuiltIn Refrigeration Products, 7-Percent Discount Rate, Low 

Economic Growth Scenario ...................................................................................12

LIST OF FIGURES

Figure 10-B.1.1 Housing Starts Forecast Under Alternative AEO2010

Economic Growth Scenarios....................................................................................1

Figure 10-B.1.2 Average Residential Electricity Price Forecasts under 

Alternative AEO2010 Economic Growth Scenarios................................................2
10-B-1

APPENDIX 10-B. NATIONAL ENERGY SAVINGS AND NET PRESENT 

VALUE USING ALTERNATIVE ECONOMIC GROWTH SCENARIOS

10-B.1 INTRODUCTION

This appendix presents national energy savings (NES) and net present value 

(NPV) results using inputs from alternative economic growth scenarios. The scenarios 

use the energy price and housing starts forecasts in the High Economic Growth case and 

the Low Economic Growth case from EIA’s Annual Energy Outlook 2010 (AEO 2010).

i

Figures 10-B.1.1 and 10-B.1.2 show the forecasts for housing starts and 

residential electricity prices under the different economic growth scenarios. AEO2010

provides a forecast to 2035. To estimate the trend after 2035, DOE followed guidelines 

that the EIA had provided to the Federal Energy Management Program, which called for 

using the average rate of change for electricity during 2025–2035.

Figure 10-B.1.1 Housing Starts Forecast Under Alternative

AEO2010 Economic Growth Scenarios

0.00

0.50

1.00

1.50

2.00

2.50

3.00

1990 1995 2000 2005 2010 2015 2020 2025 2030 2035

Millions

Historical and Reference Case

High Economic Growth Case

Low Economic Growth Case
10-B-2

Figure 10-B.1.2 Average Residential Electricity Price 

Forecasts under Alternative AEO2010

Economic Growth Scenarios

10-B.2NIA RESULTS IN HIGH ECONOMIC GROWTH SCENARIO

10-B.2.1 NES Results in High Economic Growth Scenario

0

2

4

6

8

10

12

14

2005 2010 2015 2020 2025 2030 2035

cts/kWh

Reference High Growth Low Growth
10-B-3

Table 10-B.2.1 Standard-Size Refrigerator-Freezers: Cumulative National 

Energy Savings in Quads, High Economic Growth Scenario

Trial Standard 

Level

Top-Mount 

Refrigerator-Freezers

Bottom-Mount 

Refrigerator-Freezers

Side-by-Side 

RefrigeratorFreezers

Product classes 1, 1A, 

2, 3, 3A, 3I and 6

Product classes 5, 5A, 

and 5I

Product classes 4, 

4I, and 7

1 1.72 0.10 0.57

2 1.72 0.10 0.94

3 2.21 0.10 0.94

4 2.66 0.48 1.28

5 3.09 0.70 1.48

Table 10-B.2.2 Standard-Size Freezers: Cumulative National Energy Savings

in Quads, High Economic Growth Scenario

Trial Standard 

Level

Upright Freezers Chest Freezers

Product classes 8 and 9 Product classes 10 and 10A

1 0.44 0.29

2 0.68 0.37

3 0.79 0.44

4 0.89 0.51

5 0.92 0.58

Table 10-B.2.3 Compact Refrigeration Products: Cumulative National Energy 

Savings in Quads, High Economic Growth Scenario

Trial Standard 

Level

Compact Refrigerators Compact Freezers

Product classes 11, 11A, 12, 13, 

13A, 14, and 15 Product classes 16, 17, 18

1 0.30 0.03

2 0.37 0.03

3 0.42 0.04

4 0.52 0.07

5 0.55 0.09
10-B-4

Table 10-B.2.4 Built-In Refrigeration Products: Cumulative National Energy 

Savings in Quads, High Economic Growth Scenario

Trial Standard 

Level

Built-in All 

Refrigerators 

Built-in 

Bottom-Mount 

RefrigeratorFreezers

Built-in Side-bySide 

RefrigeratorFreezers

Built-in 

Upright 

Freezers 

Product class 

3A-BI

Product classes 

5-BI and 5I-BI

Product classes

4-BI, 4I-BI and

7-BI

Product class

9-BI

1 0.00 0.00 0.01 0.00

2 0.01 0.00 0.01 0.01

3 0.01 0.00 0.03 0.01

4 0.01 0.02 0.03 0.01

5 0.01 0.02 0.04 0.01

10-B.2.2 NPV Results in High Economic Growth Scenario

Table 10-B.2.5 Cumulative Net Present Value of Consumer Benefits for

Standard-Size Refrigerator-Freezers, 3-Percent Discount Rate, 

High Economic Growth Scenario

Trial Standard 

Level

Top-Mount 

Refrigerator-Freezers

Bottom-Mount 

Refrigerator-Freezers

Side-by-Side 

Refrigerator-Freezers

Product classes 1, 1A, 

2, 3, 3A, 3I and 6

Product classes 5, 5A, 

and 5I

Product classes 4, 4I, 

and 7

1 

billion 2009 dollars

8.55 0.92 5.15

2 8.55 0.92 4.65

3 8.22 0.92 4.65

4 0.10 (3.05) (1.44)

5 (13.10) (7.25) (6.66)
10-B-5

Table 10-B.2.6 Cumulative Net Present Value of Consumer Benefits for

Standard-Size Refrigerator-Freezers, 7-Percent Discount Rate, 

High Economic Growth Scenario

Trial Standard 

Level

Top-Mount 

Refrigerator-Freezers

Bottom-Mount 

Refrigerator-Freezers

Side-by-Side 

Refrigerator-Freezers

Product classes 1, 1A, 

2, 3, 3A, 3I and 6

Product classes 5, 5A, 

and 5I

Product classes 4, 4I, 

and 7

1 

billion 2009 dollars

1.40 0.31 1.68

2 1.40 0.31 0.77

3 0.30 0.31 0.77

4 (4.93) (2.45) (3.09)

5 (12.78) (5.07) (6.23)

Table 10-B.2.7 Cumulative Net Present Value of Consumer Benefits for

Standard-Size Freezers, 3-Percent Discount Rate, High 

Economic Growth Scenario

Trial Standard 

Level

Upright Freezers Chest Freezers

Product classes 8 and 9 Product classes 10 and 10A

billion 2009 dollars

1 4.45 3.10

2 6.23 2.78

3 6.03 3.25

4 5.16 2.35

5 1.52 0.35

Table 10-B.2.8 Cumulative Net Present Value of Consumer Benefits for

Standard-Size Freezers, 7-Percent Discount Rate, High 

Economic Growth Scenario

Trial Standard 

Level

Upright Freezers Chest Freezers

Product classes 8 and 9 Product classes 10 and 10A

billion 2009 dollars
10-B-6

1 1.42 1.01

2 1.83 0.67

3 1.50 0.75

4 0.83 0.15

5 (1.19) (1.08)

Table 10-B.2.9 Cumulative Net Present Value of Consumer Benefits for

Compact Refrigeration Products, 3-Percent Discount Rate, 

High Economic Growth Scenario

Trial Standard 

Level

Compact Refrigerators Compact Freezers

Product classes 11, 11A, 12, 13, 

13A, 14, and 15 Product classes 16, 17, 18

1 

billion 2009 dollars

1.54 0.19

2 0.99 0.19

3 1.16 0.16

4 (0.37) (0.21)

5 (4.57) (0.90)

Table 10-B.2.10 Cumulative Net Present Value of Consumer Benefits for

Compact Refrigeration Products, 7-Percent Discount Rate, 

High Economic Growth Scenario

Trial Standard 

Level

Compact Refrigerators Compact Freezers

Product classes 11, 11A, 12, 13, 

13A, 14, and 15 Product classes 16, 17, 18

1 

billion 2009 dollars

0.62 0.08

2 0.29 0.08

3 0.35 0.06

4 (0.50) (0.17)

5 (2.76) (0.58)
10-B-7

Table 10-B.2.11 Cumulative Net Present Value of Consumer Benefits for BuiltIn Refrigeration Products, 3-Percent Discount Rate, High 

Economic Growth Scenario

Trial Standard 

Level

Built-in All 

Refrigerators 

Built-in 

Bottom-Mount 

RefrigeratorFreezers

Built-in Side-bySide 

RefrigeratorFreezers

Built-in 

Upright 

Freezers 

Product class 

3A-BI

Product classes 

5-BI and 5I-BI

Product classes

4-BI, 4I-BI and

7-BI

Product class

9-BI

1 

billion 2009 dollars

0.04 0.02 0.05 0.05

2 0.05 0.01 0.05 0.05

3 (0.00) 0.01 (0.43) (0.01)

4 (0.10) (0.37) (0.43) (0.01)

5 (0.18) (0.57) (0.86) (0.06)

Table 10-B.2.12 Cumulative Net Present Value of Consumer Benefits for BuiltIn Refrigeration Products, 7-Percent Discount Rate, High 

Economic Growth Scenario

Trial Standard 

Level

Built-in All 

Refrigerators 

(3A-BI)

Built-in 

Bottom-Mount 

RefrigeratorFreezers

Built-in Side-bySide 

RefrigeratorFreezers

Built-in 

Upright 

Freezers (9-BI)

Product class 

3A-BI

Product classes 

5-BI and 5I-BI

Product classes

4-BI, 4I-BI and

7-BI

Product class

9-BI

1 

billion 2009 dollars

0.01 0.01 0.01 0.02

2 0.02 (0.00) 0.01 0.01

3 (0.02) (0.00) (0.29) (0.03)

4 (0.07) (0.22) (0.29) (0.03)

5 (0.12) (0.33) (0.53) (0.06)
10-B-8

10-B.3NIA RESULTS IN LOW ECONOMIC GROWTH SCENARIO

10-B.3.1 NES Results in Low Economic Growth Scenario

Table 10-B.3.1 Standard-Size Refrigerator-Freezers: Cumulative National 

Energy Savings in Quads, Low Economic Growth Scenario

Trial Standard 

Level

Top-Mount 

Refrigerator-Freezers

Bottom-Mount 

Refrigerator-Freezers

Side-by-Side 

RefrigeratorFreezers

Product classes 1, 1A, 2, 

3, 3A, 3I and 6

Product classes 5, 5A, 

and 5I

Product classes 4, 4I, 

and 7

1 1.52 0.09 0.50

2 1.52 0.09 0.82

3 1.94 0.09 0.82

4 2.33 0.42 1.12

5 2.72 0.61 1.30

Table 10-B.3.2 Standard-Size Freezers: Cumulative National Energy Savings

in Quads, Low Economic Growth Scenario

Trial Standard 

Level

Upright Freezers Chest Freezers

Product classes 8 and 9 Product classes 10 and 10A

1 0.41 0.27

2 0.64 0.34

3 0.74 0.41

4 0.83 0.48

5 0.86 0.54

Table 10-B.3.3 Compact Refrigeration Products: Cumulative National Energy 

Savings in Quads, Low Economic Growth Scenario

Trial Standard 

Level

Compact Refrigerators Compact Freezers

Product classes 11, 11A, 12, 13, 

13A, 14, and 15 Product classes 16, 17, 18

1 0.25 0.03

2 0.31 0.03

3 0.35 0.04

4 0.43 0.07

5 0.45 0.09
10-B-9

Table 10-B.3.4 Built-In Refrigeration Products: Cumulative National Energy 

Savings in Quads, Low Economic Growth Scenario

Trial Standard 

Level

Built-in All 

Refrigerators 

Built-in 

Bottom-Mount 

RefrigeratorFreezers

Built-in Side-bySide 

RefrigeratorFreezers

Built-in 

Upright 

Freezers 

Product class 

3A-BI

Product classes 

5-BI and 5I-BI

Product classes

4-BI, 4I-BI and

7-BI

Product class

9-BI

1 0.00 0.00 0.01 0.00

2 0.01 0.00 0.01 0.01

3 0.01 0.00 0.03 0.01

4 0.01 0.01 0.03 0.01

5 0.01 0.02 0.03 0.01

10-B.3.2 NPV Results in Low Economic Growth Scenario

Table 10-B.3.5 Cumulative Net Present Value of Consumer Benefits for

Standard-Size Refrigerator-Freezers, 3-Percent Discount Rate, 

Low Economic Growth Scenario

Trial Standard 

Level

Top-Mount 

Refrigerator-Freezers

Bottom-Mount 

Refrigerator-Freezers

Side-by-Side 

RefrigeratorFreezers

Product classes 1, 1A, 

2, 3, 3A, 3I and 6

Product classes 5, 5A, 

and 5I

Product classes 4, 4I, 

and 7

1 

billion 2009 dollars

4.81 0.65 3.58

2 4.81 0.65 2.58

3 3.78 0.65 2.58

4 (4.00) (3.39) (3.26)

5 (16.18) (7.40) (8.10)
10-B-10

Table 10-B.3.6 Cumulative Net Present Value of Consumer Benefits for

Standard-Size Refrigerator-Freezers, 7-Percent Discount Rate, 

Low Economic Growth Scenario

Trial Standard 

Level

Top-Mount 

Refrigerator-Freezers

Bottom-Mount 

Refrigerator-Freezers

Side-by-Side 

RefrigeratorFreezers

Product classes 1, 1A, 

2, 3, 3A, 3I and 6

Product classes 5, 5A, 

and 5I

Product classes 4, 4I, 

and 7

1 

billion 2009 dollars

0.31 0.22 1.17

2 0.31 0.22 0.17

3 (0.91) 0.22 0.17

4 (5.77) (2.41) (3.41)

5 (12.92) (4.83) (6.28)

Table 10-B.3.7 Cumulative Net Present Value of Consumer Benefits for

Standard-Size Freezers, 3-Percent Discount Rate, Low

Economic Growth Scenario

Trial Standard 

Level

Upright Freezers Chest Freezers

Product classes 8 and 9 Product classes 10 and 10A

billion 2009 dollars

1 3.33 2.35

2 4.55 1.92

3 4.16 2.21

4 3.18 1.26

5 (0.25) (0.72)

Table 10-B.3.8 Cumulative Net Present Value of Consumer Benefits for

Standard-Size Freezers, 7-Percent Discount Rate, Low

Economic Growth Scenario

Trial Standard 

Level

Upright Freezers Chest Freezers

Product classes 8 and 9 Product classes 10 and 10A

billion 2009 dollars
10-B-11

1 1.07 0.77

2 1.31 0.41

3 0.93 0.44

4 0.25 (0.16)

5 (1.66) (1.35)

Table 10-B.3.9 Cumulative Net Present Value of Consumer Benefits for

Compact Refrigeration Products, 3-Percent Discount Rate, Low

Economic Growth Scenario

Trial Standard 

Level

Compact Refrigerators Compact Freezers

Product classes 11, 11A, 12, 13, 

13A, 14, and 15 Product classes 16, 17, 18

1 

billion 2009 dollars

0.96 0.15

2 0.41 0.15

3 0.50 0.11

4 (0.89) (0.29)

5 (4.38) (1.02)

Table 10-B.3.10 Cumulative Net Present Value of Consumer Benefits for

Compact Refrigeration Products, 7-Percent Discount Rate, Low

Economic Growth Scenario

Trial Standard 

Level

Compact Refrigerators Compact Freezers

Product classes 11, 11A, 12, 13, 

13A, 14, and 15 Product classes 16, 17, 18

1 

billion 2009 dollars

0.39 0.07

2 0.07 0.07

3 0.10 0.03

4 (0.67) (0.20)

5 (2.58) (0.62)
10-B-12

Table 10-B.3.11 Cumulative Net Present Value of Consumer Benefits for BuiltIn Refrigeration Products, 3-Percent Discount Rate, Low

Economic Growth Scenario

Trial Standard 

Level

Built-in All 

Refrigerators 

Built-in 

Bottom-Mount 

RefrigeratorFreezers

Built-in Side-bySide 

RefrigeratorFreezers

Built-in 

Upright 

Freezers 

Product class 

3A-BI

Product classes 

5-BI and 5I-BI

Product classes

4-BI, 4I-BI and

7-BI

Product class

9-BI

1 

billion 2009 dollars

0.03 0.01 0.03 0.04

2 0.04 (0.00) 0.03 0.03

3 (0.01) (0.00) (0.43) (0.03)

4 (0.10) (0.35) (0.43) (0.03)

5 (0.17) (0.52) (0.81) (0.08)

.

Table 10-B.3.12 Cumulative Net Present Value of Consumer Benefits for BuiltIn Refrigeration Products, 7-Percent Discount Rate, Low

Economic Growth Scenario

Trial Standard 

Level

Built-in All 

Refrigerators 

(3A-BI)

Built-in 

Bottom-Mount 

RefrigeratorFreezers

Built-in Side-bySide 

RefrigeratorFreezers

Built-in 

Upright 

Freezers (9-BI)

Product class 

3A-BI

Product classes 

5-BI and 5I-BI

Product classes

4-BI, 4I-BI and

7-BI

Product class

9-BI

1 

billion 2009 dollars

0.01 0.01 0.00 0.01

2 0.01 (0.01) 0.00 (0.00)

3 (0.02) (0.01) (0.27) (0.04)

4 (0.07) (0.20) (0.27) (0.04)

5 (0.11) (0.31) (0.49) (0.07)
10-B-13

REFERENCES

 i U.S. Department of Energy–Energy Information Administration. Annual Energy 

Outlook 2010 with Projections to 2035. April 2010. U.S. DOE–EIA: Washington, 

D.C. DOE/EIA-0383(2010).
12-A-i

APPENDIX 12-A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDES

TABLE OF CONTENTS

12-A.1 RESIDENTIAL REFRIGERATION PRODUCTS MANUFACTURER IMPACT 

ANALYSIS INTERVIEW GUIDE................................................................................................ 1

12-A.2 COMPACT REFRIGERATORS AND FREEZERS MANUFACTURER IMPACT 

ANALYSIS INTERVIEW GUIDE.............................................................................................. 14

12-A.3 STANDARD SIZE REFRIGERATION PRODUCTS MANUFACTURER IMPACT 

ANALYSIS INTERVIEW GUIDE.............................................................................................. 27
12-A-1

APPENDIX 12-A MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDES

12-A.1 RESIDENTIAL REFRIGERATION PRODUCTS MANUFACTURER IMPACT 

ANALYSIS INTERVIEW GUIDE

January 13, 2010
12-A-2

The Department of Energy (DOE) conducts the manufacturer impact analysis (MIA) as part of 

the rulemaking process for amended energy conservation standards for refrigerators, refrigeratorfreezers, and freezers. In this analysis, DOE uses publicly available information and information 

provided by manufacturers during interviews to assess possible impacts on manufacturers due to 

amended energy conservation standards.

DOE explicitly analyzes the seven product classes in the tables below. For all product classes, 

DOE is currently considering eight efficiency levels (ELs) that correspond to percentage 

improvements over the existing standards. In responding to this questionnaire, please refer to the 

efficiency levels in the table below. DOE explains how it intends to determine the minimum 

efficiencies for the remaining product classes in the engineering chapter of the technical support 

document.1

 

Baseline Efficiencies for Analyzed Product Classes

Product 

Class 

Number

Product Type Product Class Description Equation for maximum 

energy use (kWh/yr))*

3 Refrigerator-Freezers

Automatic Defrost with Top-Mounted 

Freezer Without Through the Door (TTD)

Ice Service

10.72 AV + 310.2

5 Refrigerator-Freezers Automatic Defrost with Bottom-Mounted 

Freezer Without TTD Ice Service 5.32 AV + 542.5

7 Refrigerator-Freezers Automatic Defrost with Side-Mounted 

Freezer With TTD Ice Service 11.33 AV + 462.8

9 Freezers Upright Freezers with Automatic Defrost 12.32 AV + 326.1

10 Freezers Chest Freezers and all Other Freezers 

Except Compact Freezers

9.71 AV + 143.7

11 Compact Refrigerators 

and Freezers 

Compact Refrigerators and RefrigeratorFreezers with Manual Defrost 12.04 AV + 336.4

18 Compact Refrigerators 

and Freezers Compact Chest Freezers 10.27 AV + 152

AV= adjusted volume in cubic feet

* These definitions are based on testing according to the current energy test procedure. DOE expects to propose 

revisions in the energy test procedure to harmonize with expected test temperatures under consideration for IEC test 

procedure 62552 and will adjust the equations accordingly. However, for the purpose of identifying the efficiency 

levels of products in the table below, it is assumed that the percent efficiency level (i.e. the difference between 

baseline energy use and improved product energy use divided by baseline energy use and multiplied by 100%) does 

not depend on which test procedure is used to determine energy use.

Efficiency Levels Under Consideration for all Product Classes

Percentage Decrease in kWh/yr from Calculated Baseline 

Efficiency

EL 1 EL 2 EL 3 EL 4 EL 5 EL 6 EL 7 EL 8

10% 15% 20% 25% 30% 35% 40% 45%

 1 Please see 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/refrigerators_freezers_prelim_tsd_mtg.html 

for a complete description. 
12-A-3

1 KEY ISSUES

1.1 In general, what are the key issues for your company regarding amended energy 

conservation standards for residential refrigeration products and this rulemaking?

1.2 For the issues identified, does the severity change for different product classes? Do some 

issues become more significant at higher efficiency levels? Are certain issues more of a concern 

for certain product classes?

1.3 How can DOE most effectively incorporate these issues in the MIA?

2 COMPANY OVERVIEW AND ORGANIZATIONAL CHARACTERISTICS

DOE is interested in understanding manufacturer impacts at the plant or profit center level 

directly pertinent to residential refrigeration production. However, the context within which the 

plant operates and the details of plant production and costs are not always readily available from 

public sources. Therefore, DOE invites you to provide these details confidentially in your own 

words to the extent possible and practical. Understanding the organizational setting around the 

residential refrigeration industry profit center will help DOE understand the probable future of 

the manufacturing activity with and without amended energy conservation standards.

2.1 Do you have a parent company, and/or any subsidiaries relevant to the residential 

refrigeration industry?

2.2 Do you manufacture any products other than residential refrigeration products? If so, 

what other products do you manufacture? What percentage of your total manufacturing revenue 

corresponds to residential refrigeration products?

2.3 What product classes of refrigeration products do you manufacturer? 

2.4 Where are your residential refrigeration production facilities located, and what types of 

products are manufactured at each location? Could you provide annual shipment figures for your 

company’s residential refrigeration manufacturing at each location by product line (i.e., topmount refrigerator-freezers, bottom-mount refrigerator-freezers, etc.)?

2.5 At your manufacturing facilities, would potential residential refrigeration product 

redesigns be difficult to implement? If so, would your company modify the existing facility or 

develop a new facility?

2.6 What are your employment levels at each of these facilities?

2.7 What is your company’s approximate market share in the standard-size refrigerator-
12-A-4

freezer, standard-size freezer, and compact refrigerator and freezers markets?

3 ENGINEERING AND LIFE CYCLE COST ANALYSIS FOLLOW-UP

3.1 For the products directly analyzed for the Engineering Analysis that represent the bulk of 

residential refrigeration product sales, can you comment on the progressive use of design options 

for achieving the successively higher efficiency levels (compared with the design option 

information presented by efficiency level in Appendix 5A of the preliminary TSD)?

3.2 Are the incremental design option costs used in the Engineering Analysis and described 

in Chapter 5 of the preliminary TSD representative of costs your company pays for these design 

options? If not, please provide a quantitative indication of the differences.

3.3 How would the cost-efficiency curves of low-production-volume product classes differ 

from those developed for the directly-analyzed product classes most closely related to them? The 

table below provides an indication of expectations for representation of low-volume product 

classes. Please comment for your key products of the low-volume product classes.

Low-volume 

Product 

Classes

1A, 1, 2, 

3A 4 5A 6 8 10A 11A, 12, 13, 

13A, 14, 15 16,17

Representative 

Product Class 3 7 5 3 10 9 11 18

3.4 Do you sell any standard-size all-refrigerators with manual (not off-cycle) defrost?

3.5 Do you sell any compact upright freezers with automatic defrost (PC 17)? If so, can you 

describe your product line(s) for this class and provide shipment estimates?

3.6 Do you have warrantee and/or maintenance cost data illustrating the impact of any of the 

following design options on maintenance cost: electronic controls, high-efficiency single-speed 

compressors, variable-speed compressors, brushless DC fans, VIPs, and humidity sensors?

3.7 What are the expected differences in cost per unit area of VIP applied to a product 

between application to the door and application to the cabinet? Are these costs differences for 

labor costs, material costs, capital costs, or other types of costs?

3.8 What is your company’s level of operation (by shipment volume) in other world markets 

where significant reductions in energy use have been or are expected to be mandated, 

particularly India and the EU?

3.9 How would repair and maintenance costs be impacted by more stringent energy 

conservation standards? How would the frequency of repair and maintenance be affected? How 
12-A-5

would the nature of the repair and maintenance work needed change with more stringent energy 

conservation standards?

3.10 Can you provide any information on consumer placement of built-in undercounter 

products and built-in upright freezers and on implications of possible wall thickness increases?

3.11 For standard size refrigerator-freezers, what percent reduction in internal volume would 

you implement prior to use of VIPs in order to maintain external dimensions?

3.12 Which product classes might be candidates for energy/adjusted volume curve slope 

changes? Do you have any information that would inform DOE’s development of a response to 

this issue?

3.13 What information can be provided to provide a better understanding of the variation of 

costs to achieve efficiency levels? What information can be provided to provide a better 

understanding of how cost-efficiency curves for the low-volume product classes not directly 

analyzed are different?

3.14 What platform differences exist between product class 4 and product class 7? Between 

product class 6 and product class 3? Between product class 5 and product class 5A?

3.15 Can you provide engineering details for baseline efficiency built-in units and ENERGY 

STAR built-in units, such as typical wall thickness, insulation used, evaporator and condenser 

description, fan types and wattages, and compressor model or capacity? Can you provide specific 

data for a representative model for each applicable product class?

3.16 Do you see any possible loopholes in the proposed AHAM built-in definition? 

“Refrigerators, freezers and refrigerators with freezer units that are 7.75 cubic feet or greater; are 

totally encased by cabinetry or panels by either accepting a custom front panel or being equipped 

with an integral factory-finished face; are intended to be securely fastened to adjacent cabinetry, 

walls or floor; has sides which are not fully finished and are not intended to be visible after 

installation.”

3.17 Can you provide any data showing how much of the expected benefits of VIPs are 

actually achieved in prototypes or manufactured products? Can you provide any data regarding 

panel failures in the field? Can you provide any data on scrap rates at the factory (what 

percentage of delivered VIPs must be scrapped)? Can you provide any data regarding resistivity 

decline of “good” panels over a span of years up to typical product lifetime?

3.18 How do the design option costs for your company compare to the values DOE used in its 

analysis as described in the preliminary TSD?

3.19 How do the bulk materials costs for your company compare to the values DOE used in its 

analysis as described in the preliminary TSD?
12-A-6

3.20 For variable anti-sweat heaters, what is the typical maximum wattage for a French door 

product and what is a typical control algorithm?

3.21 For variable defrost used with single-compressor/dual-evaporator systems, is it common 

to have more than one defrost cycle? How is this treated in the energy test? For products with 

more than one defrost cycle, do the defrost cycles ever overlap?

4 MARKUPS AND PROFITABILITY

DOE estimated the manufacturer production costs for the seven analyzed product classes of 

refrigeration products. DOE defines manufacturer production cost as all direct costs associated 

with manufacturing a product. It includes direct labor, direct materials, and overhead (which 

includes depreciation costs).

Manufacturer selling price is the average cost manufacturers charge their first consumers, but 

does not include additional costs along the distribution channels. The manufacturer selling price 

includes non-production costs including research and development; selling, general, and 

administrative expenses; shipping cost; and profit. The manufacturer markup is a multiplier 

applied to manufacturer production cost to cover these non-production costs and yield a profit. 

DOE estimated a baseline markup of 1.26 for refrigeration products. 

One of the primary objectives of the MIA is to assess the impact of amended energy 

conservation standards on industry profitability. In this section, DOE would like to understand 

the current markup structure of the industry and how setting an amended energy conservation 

standard would impact your company’s markup structure and profitability.

4.1 Is there a significant difference between the baseline markup DOE calculated and your 

company’s baseline markups for standard-size refrigerator-freezers, standard-size freezers, and

compact refrigerators and freezers? Is the 1.26 baseline markup factor representative of an 

average industry markup? 

4.2 Do profit levels currently vary by product class or product line? 

4.3 DOE would like to understand how the baseline manufacturer markup changes at higher 

efficiency levels. Do you currently earn a premium for more efficient products (i.e., ENERGY 

STAR or higher)? Please explain why or why not.

4.4 Does your markup change with selected design options? Is the markup on incremental 

costs for more efficient designs different than the markup on the baseline models (as is assumed 

for retailer markups used in the analyses)?

4.5 Would you expect changes in your estimated profitability following an amended energy 

conservation standard? If so, please explain why. 
12-A-7

5 SHIPMENT PROJECTIONS

An amended energy conservation standard can change overall shipments by altering product

attributes, marketing approaches, product availability, and prices. The industry revenue 

calculations are based on the shipment projections developed in DOE’s shipments model. The 

shipments model includes forecasts for the base case shipments (i.e., total industry shipments 

absent amended energy conservation standards) and the standards case shipments (i.e., total 

industry shipments with amended energy conservation standards).

To determine efficiency distributions after the effective date of the standard, DOE used a “rollup + market shift” scenario for 2014 and subsequent years. DOE assumed that product 

efficiencies in the base case that did not meet the standard under consideration would roll up to 

meet the new standard in 2014. DOE further assumed that the ENERGY STAR program would 

continue to promote efficient appliances after revised standards are introduced in 2014, resulting 

in a gradual market shift to higher efficiencies after the compliance date of the standard.

5.1 How do you think amended energy conservation standards will impact the sales of more 

efficient products? For example, would customers continue to buy products that exceed the 

energy conservation standard level? Would your response change for higher mandated efficiency 

levels?

5.2 DOE assumed that revised standards would cause product purchase prices to increase, 

resulting in reduced demand or shipments (price elasticity effect). DOE assumed an elasticity 

coefficient of -0.40, meaning a 10% increase in price would result in a 4% decrease in 

shipments. Do you agree with this assumption? How sensitive do you think shipments will be to 

price changes? Does it vary with product class?

6 FINANCIAL PARAMETERS

DOE’s contractor has developed a “strawman” model of the residential refrigeration products

industry financial performance called the Government Regulatory Impact Model (GRIM) using 

publicly available data. This section attempts to understand how your company’s financial 

situation differs from the industry aggregate picture.

6.1 Please compare your financial parameters to the GRIM parameters tabulated below.
12-A-8

Table 6.1 Financial Parameters for Residential Refrigeration Product Manufacturers

GRIM Input Definition Industry 

Estimated

Value

Your Actual (If 

Significantly 

Different from 

DOE’s 

Estimate)

Income Tax 

Rate

Corporate effective income tax paid (percentage of 

earnings before taxes, EBT) 33.9

Discount Rate

Weighted average cost of capital (inflationadjusted weighted average of corporate cost of 

debt and return on equity)

7.2

Working 

Capital

Current assets less current liabilities (percentage of 

revenues) 2.9

Net PPE Net plant property and equipment (percentage of 

revenues) 19.9

SG&A Selling, general, and administrative expenses 

(percentage of revenues) 12.5

R&D Research and development expenses (percentage 

of revenues) 2.2

Depreciation Amortization of fixed assets (percentage of 

revenues) 3.4

Capital 

Expenditures

Outlay of cash to acquire or improve capital assets 

(percentage of revenues, not including acquisition 

or sale of business units)

3.5

Cost of Goods 

Sold

Includes material, labor, overhead, and 

depreciation (percentage of revenues) 79.4

6.2 Are the figures in Table 6.1 representative of residential refrigeration manufacturing?

6.3 Do any of the financial parameters in Table 6.1 change based on product type or product 

class? Please describe any differences. 

6.4 How would you expect an amended energy conservation standard to impact any of the 

financial parameters for the industry?

7 CONVERSION COSTS

Amended energy conservation standards may cause your company to incur capital and product 

conversion costs to redesign existing products and make changes to existing production lines to 

be compliant with the amended energy conservation standard. Capital conversion costs are onetime investments in plant, property, and equipment (PPE) necessitated by an amended energy 

conservation standard. These may be incremental changes to existing PPE or the replacement of 

existing PPE. In addition to capital conversion costs, product conversion costs are costs related 

research, product development, testing, marketing and other costs for redesigning products 

necessitated by an amended energy conservation standard. Depending on their magnitude, the 

conversion costs can have a substantial impact on the outputs used by DOE to evaluate the 

industry impacts. Understanding the nature and magnitude of the conversion costs is critical 
12-A-9

portion of the MIA. Table 7.1 shows the design options used to research higher efficiencies for 

the major product categories covered by this rulemaking. Please refer to Table 7.1 when 

considering your response to the following questions. 

Table 7.1 Design Options Used to Improve Efficiency for each Major Product Category

Product Type Design Options

Top-Mount RefrigeratorFreezersMore efficient compressors, larger evaporators, larger condensers, brushless DC 

fan motors, adaptive defrost, and VIPs in the cabinet

Side-Mount RefrigeratorFreezersMore efficient compressors, brushless DC fan motors, adaptive defrost, larger 

evaporators, larger condensers, VIPs in the cabinet, VIPs in the door, and 

variable speed compressors

Bottom-Mount RefrigeratorFreezersMore efficient compressors, brushless DC fan motors, variable anti-sweat heater 

control, adaptive defrost, larger condensers, larger evaporators, and VIPs in the 

cabinet

Upright Freezers Brushless DC fan motors, thicker insulation, adaptive defrost, more efficient 

compressors, larger evaporators, forced convection condensers, VIPs in the 

cabinet, and VIPs in the door

Chest Freezers Larger condensers, larger evaporators, thicker insulation, more efficient 

compressors, variable speed compressors, VIPs in the bottom wall, and VIPs in 

the door

Compact Refrigerator-Freezers Larger evaporators, thicker insulation, more efficient compressors, larger 

condensers, VIPs in the cabinet, and VIPs in the door

Compact Chest Freezers More efficient compressors, thicker insulation, VIPs in the bottom wall, and 

variable speed compressors

7.1 Are there certain efficiency levels for which the design changes would require relatively 

minor changes to existing products? Are there certain efficiency levels where the capital or 

product conversion costs significantly increase? Would your answer change for different product 

categories? Please describe these changes qualitatively. 

7.2 For each of the product categories shown in Table 7.1, which design options could be 

made within existing cabinet designs and which would result in major product redesigns? 

7.3 For the design options in Table 7.1, what kind of changes would need to be implemented

to production lines for each major product category? How much would these changes and other 

capital expenses cost? 

7.4 Would the changes in 7.3 be similar across all of your production lines and factories for 

each product category?

7.5 For each of the product categories, please qualify the number of and cost of new 

production equipment, molds, foaming fixtures, etc. that would be required to implement the 

specified design changes. Please consider which design changes would require changes to 

existing cavity designs/wrapper shells. 
12-A-10

7.6 What level of product development and other product conversion costs would you expect 

to incur for each of these design changes for each major product category?

7.7 For any design changes that would require new production equipment, please describe 

how much downtime would be required. What impact would downtime have on your business? 

Are there any design changes that could not be implemented before the compliance date of the 

final rule for certain product classes?

7.8 Please provide additional qualitative information to help DOE understand the types and

nature of your investments, including the plant and tooling changes and the product development 

effort required at different efficiency levels.

8 CUMULATIVE REGULATORY BURDEN

Cumulative regulatory burden refers to the burden that industry faces from overlapping effects of 

new or revised DOE standards, voluntary standards, and/or other regulatory actions affecting the 

same product or industry.

8.1 Are there other recent or impending regulations that residential refrigeration 

manufacturers face (from DOE or otherwise)? If so, could you identify the regulation and the 

corresponding possible effective dates for those regulations? Below is a list of regulations that 

could possibly affect manufacturers of residential refrigerators, refrigerator-freezers, and 

freezers. Please provide any comments on the listed regulations in addition to other regulations.

Table 8.1 Other Regulations Identified by DOE

Regulation Estimated or Actual Effective 

Date(s) Comments

DOE’s Energy Conservation Standards for 

Other Products and Equipment

International Energy-Efficiency Standards

Climate Change Legislation limiting or 

banning hydrofluorocarbons (discussed in 

section 9)

8.2 What level of expense are you expecting to incur as a result of these regulations?

8.3 Under what circumstances would you be able to coordinate any expenditure related to 

these other regulations with an amended energy conservation standard, thereby lessening the 

cumulative burden?

8.4 DOE research has identified the production tax credits in Table 8.2 for manufacturers of 

residential refrigeration products. Similar tax credits have also been proposed in the current 

version of the House energy bill. Has your company received benefit from the tax credits under 

the Energy Policy Act of 2005 (EPACT 2005) and Energy Improvement and Extension Act of 
12-A-11

2008 (EIEA 2008)? Do you know of any current or future tax credits or other benefits available 

to your company for manufacturing more efficient refrigeration products? If so, please describe.

Table 8.2 Federal Production Tax Credits Identified by DOE

Tax Credit 

Program

Effective Date Rolling Average 

Basis

Efficiency

Improvement 

Requirements

Tax Credit per 

Unit

Start End

EPACT 2005 2006 2006 3 years 15% $75 

2006 2007 3 years 20% $125 

2006 2007 3 years 25% $175 

EIEA 2008 2008 2008 2 years 20% $50 

2008 2009 2 years 23% $75 

2008 2010 2 years 25% $100 

2008 2010 2 years 30% $200 

9 IMPACTS OF POTENTIAL HFC REGULATIONS

9.1 Do you have data indicating the thermal performance of insulation foam using 

cyclopentane blowing agent? How does this compare with information you have seen regarding 

the performance of foam blown with HFC-245fa?

9.2 What are your expectations regarding the shift away from HFC foam blowing agents and 

away from HFC-134a refrigerant? Please indicate the percentage of your production using each 

of these as a function of year. If this depends on a specific key event, such as passage of 

greenhouse gas legislation, please provide an alternative curve assuming the occurrence of this 

event.

9.3 What are your expectations regarding the UL initiative to reconsider HC limits in 

refrigeration products? Can you comment on the efficiency of refrigerators that use HCs 

compared to those that do not?

9.4 What are your expectations of added capital and one-time costs associated with full 

conversion away from HFC blowing agents? Added capital and one-time costs associated with 

full conversion away from HFC-134a refrigerant? Added per-product cost associated with each 

of these conversions? What kinds of changes to your existing factories would be required to 

handle the blowing agents or refrigerants required if you stopped using HFCs? What would these 

changes cost? What level of product development would such a change require and what would 

this effort cost?
12-A-12

10 DIRECT EMPLOYMENT IMPACT ASSESSMENT

The impact of amended energy conservation standards on employment is an important 

consideration in the rulemaking process. This section of the interview guide seeks to explore 

current trends in refrigerator, refrigerator-freezer, and freezer employment and solicit 

manufacturer views on how domestic employment patterns might be affected by amended energy 

conservation standards.

10.1 Would your domestic employment levels be expected to change significantly under 

amended energy conservation standards? If so, please explain how they would change if higher 

efficiency levels are required.

10.2 Would the workforce skills necessary under amended energy conservation standards 

require extensive retraining or replacement of employees at your manufacturing facilities?

10.3 Would amended energy conservation standards require extensive retraining of your 

service/field technicians? If so, could you expand on how your service infrastructure would be 

impacted in general as a result of amended energy conservation standards?

11 EXPORTS / FOREIGN COMPETITION / OUTSOURCING

Disparity between domestic and foreign energy conservation standards could impact exports or 

imports. Labor content and material changes, resulting from amended energy conservation

standards, may impact sourcing decisions.

11.1 What percentage of your company’s residential refrigeration sales are in the United 

States? What percentage of your residential refrigeration sales are produced in the United 

States? 

11.2 Are there any foreign companies with North American production facilities?

 

11.3 Would amended energy conservation standards impact your domestic vs. foreign 

manufacturing or sourcing decisions? Is there an efficiency level that would cause you to move 

exiting domestic production facilities outside the U.S.?

11.4 What percentage of the U.S. market for residential refrigerator-freezers, standard-size 

freezers, and compact refrigerators and freezers manufacturers is made outside the U.S.?

12 CONSOLIDATION

Amended energy conservation standards can alter the competitive dynamics of the market. This 

can include prompting companies to enter or exit the market, or to merge. DOE and the 
12-A-13

Department of Justice are both interested in any potential reduction in competition that would 

result from an amended energy conservation standard.

12.1 Please comment on industry consolidation and related trends over the last 5 years.

12.2 In the absence of amended energy conservation standards, do you expect any further 

industry consolidation? Please describe your expectations.

12.3 How would amended energy conservation standards affect your or other companies’ 

ability to compete?

13 IMPACTS ON SMALL BUSINESS

13.1 The Small Business Administration (SBA) denotes a small business in the residential 

refrigeration manufacturing industry as having less than 1,000 total employees, including the 

parent company and all subsidiaries.2 By this definition, is your company considered a small 

business?

13.2 Are there any reasons that a small business manufacturer might be at a disadvantage 

relative to a larger business under amended energy conservation standards? Please consider such 

factors as technical expertise, access to capital, bulk purchasing power for materials/components, 

engineering resources, and any other relevant issues.

13.3 Are there any niche manufacturers, small businesses manufacturers, and/or component 

manufacturers for which the adoption of amended energy conservation standards would have a 

severe impact? If so, would manufacturers of these products have different incremental impacts 

from implemented amended energy conservation standards than from the rest of the industry?

 2 DOE uses the small business size standards published on August 22, 2008, as amended, by the SBA to determine 

whether a company is a small business. To be categorized as a small business, a household refrigerator and home 

freezer manufacturers and its affiliates may employ a maximum of 1,000 employees. The 1,000 employee threshold 

includes all employees in a business’s parent company and any other subsidiaries. 
12-A-14

12-A.2 COMPACT REFRIGERATORS AND FREEZERS MANUFACTURER IMPACT 

ANALYSIS INTERVIEW GUIDE

January 13, 2010
12-A-15

The Department of Energy (DOE) conducts the manufacturer impact analysis (MIA) as part of

the rulemaking process for amended energy conservation standards for refrigerators, refrigeratorfreezers, and freezers. In this analysis, DOE uses publicly available information and information 

provided by manufacturers during interviews to assess possible impacts on manufacturers due to 

amended energy conservation standards.

DOE explicitly analyzes the compact product classes in the tables below. For all product classes, 

DOE is currently considering eight efficiency levels (ELs) that correspond to percentage 

improvements over the existing standards. In responding to this questionnaire, please refer to the 

efficiency levels in the table below. DOE explains how it intends to determine the minimum 

efficiencies for the remaining product classes in the engineering chapter of the technical support 

document.3

 

Baseline Efficiencies for Analyzed Product Classes

Product 

Class 

Number

Product Type Product Class Description Equation for maximum 

energy use (kWh/yr))*

11 Compact Refrigerators 

and Freezers 

Compact Refrigerators and RefrigeratorFreezers with Manual Defrost 12.04 AV + 336.4

18 Compact Refrigerators 

and Freezers Compact Chest Freezers 10.27 AV + 152

AV= adjusted volume in cubic feet

* These definitions are based on testing according to the current energy test procedure. DOE expects to propose 

revisions in the energy test procedure to harmonize with expected test temperatures under consideration for IEC test 

procedure 62552 and will adjust the equations accordingly. However, for the purpose of identifying the efficiency 

levels of products in the table below, it is assumed that the percent efficiency level (i.e. the difference between 

baseline energy use and improved product energy use divided by baseline energy use and multiplied by 100%) does 

not depend on which test procedure is used to determine energy use.

Efficiency Levels Under Consideration for all Product Classes

Percentage Decrease in kWh/yr from Calculated Baseline 

Efficiency

EL 1 EL 2 EL 3 EL 4 EL 5 EL 6 EL 7 EL 8

10% 15% 20% 25% 30% 35% 40% 45%

1 KEY ISSUES

1.1 In general, what are the key issues for your company regarding amended energy 

conservation standards for residential refrigeration products and this rulemaking?

 3 Please see 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/refrigerators_freezers_prelim_tsd_mtg.html 

for a complete description. 
12-A-16

1.2 For the issues identified, does the severity change for different product classes? Do some 

issues become more significant at higher efficiency levels? Are certain issues more of a concern 

for certain product classes?

1.3 How can DOE most effectively incorporate these issues in the MIA?

2 COMPANY OVERVIEW AND ORGANIZATIONAL CHARACTERISTICS

DOE is interested in understanding manufacturer impacts at the plant or profit center level 

directly pertinent to residential refrigeration production. However, the context within which the 

plant operates and the details of plant production and costs are not always readily available from 

public sources. Therefore, DOE invites you to provide these details confidentially in your own 

words to the extent possible and practical. Understanding the organizational setting around the 

residential refrigeration industry profit center will help DOE understand the probable future of 

the manufacturing activity with and without amended energy conservation standards.

2.1 Do you have a parent company, and/or any subsidiaries relevant to the residential 

refrigeration industry?

2.2 Do you manufacture any products other than residential refrigeration products? If so, 

what other products do you manufacture? What percentage of your total manufacturing revenue 

corresponds to residential refrigeration products?

2.3 What product classes of refrigeration products do you manufacturer? 

2.4 Where are your residential refrigeration production facilities located, and what types of 

products are manufactured at each location? Could you provide annual shipment figures for your 

company’s residential refrigeration manufacturing at each location by product line?

2.5 At your manufacturing facilities, would potential residential refrigeration product 

redesigns be difficult to implement? If so, would your company modify the existing facility or 

develop a new facility?

2.6 What are your employment levels at each of these facilities?

2.7 What is your company’s approximate market share in the compact refrigerator and 

freezers markets?

3 ENGINEERING AND LIFE CYCLE COST ANALYSIS FOLLOW-UP

3.1 For the products directly analyzed for the Engineering Analysis that represent the bulk of 

residential refrigeration product sales, can you comment on the progressive use of design options 

for achieving the successively higher efficiency levels (compared with the design option 
12-A-17

information presented by efficiency level in Appendix 5A of the preliminary TSD)?

3.2 Are the incremental design option costs used in the Engineering Analysis and described 

in Chapter 5 of the preliminary TSD representative of costs your company pays for these design 

options? If not, please provide a quantitative indication of the differences.

3.3 How would the cost-efficiency curves of low-production-volume product classes differ 

from those developed for the directly-analyzed product classes most closely related to them? The 

table below provides an indication of expectations for representation of low-volume product 

classes. Please comment for your key products of the low-volume product classes.

Low-volume 

Product 

Classes

11A, 12, 13, 

13A, 14, 15 16,17

Representative 

Product Class 11 18

3.4 Do you sell any standard-size all-refrigerators with manual (not off-cycle) defrost?

3.5 Do you sell any compact upright freezers with automatic defrost (PC 17)? If so, can you 

describe your product line(s) for this class and provide shipment estimates?

3.6 Do you have warrantee and/or maintenance cost data illustrating the impact of any of the 

following design options on maintenance cost: electronic controls, high-efficiency single-speed 

compressors, variable-speed compressors, brushless DC fans, VIPs, and humidity sensors?

3.7 What are the expected differences in cost per unit area of VIP applied to a product 

between application to the door and application to the cabinet? Are these costs differences for 

labor costs, material costs, capital costs, or other types of costs?

3.8 What is your company’s level of operation (by shipment volume) in other world markets 

where significant reductions in energy use have been or are expected to be mandated, 

particularly India and the EU?

3.9 How would repair and maintenance costs be impacted by more stringent energy 

conservation standards? How would the frequency of repair and maintenance be affected? How 

would the nature of the repair and maintenance work needed change with more stringent energy 

conservation standards?

3.10 Can you provide any information on consumer placement of built-in undercounter 

products and built-in upright freezers and on implications of possible wall thickness increases?

3.11 Which product classes might be candidates for energy/adjusted volume curve slope 

changes? Do you have any information that would inform DOE’s development of a response to 
12-A-18

this issue?

3.12 What information can be provided to provide a better understanding of the variation of 

costs to achieve efficiency levels? What information can be provided to provide a better 

understanding of how cost-efficiency curves for the low-volume product classes not directly 

analyzed are different?

3.13 Can you provide engineering details for baseline efficiency built-in units and ENERGY 

STAR built-in units, such as typical wall thickness, insulation used, evaporator and condenser 

description, fan types and wattages, and compressor model or capacity? Can you provide specific 

data for a representative model for each applicable product class?

3.14 Do you see any possible loopholes in the proposed AHAM built-in definition? 

“Refrigerators, freezers and refrigerators with freezer units that are 7.75 cubic feet or greater; are 

totally encased by cabinetry or panels by either accepting a custom front panel or being equipped 

with an integral factory-finished face; are intended to be securely fastened to adjacent cabinetry, 

walls or floor; has sides which are not fully finished and are not intended to be visible after 

installation.”

3.15 Can you provide any data showing how much of the expected benefits of VIPs are 

actually achieved in prototypes or manufactured products? Can you provide any data regarding 

panel failures in the field? Can you provide any data on scrap rates at the factory (what 

percentage of delivered VIPs must be scrapped)? Can you provide any data regarding resistivity 

decline of “good” panels over a span of years up to typical product lifetime?

3.16 How do the design option costs for your company compare to the values DOE used in its 

analysis as described in the preliminary TSD?

3.17 How do the bulk materials costs for your company compare to the values DOE used in its 

analysis as described in the preliminary TSD?

3.18 For variable defrost used with single-compressor/dual-evaporator systems, is it common 

to have more than one defrost cycle? How is this treated in the energy test? For products with 

more than one defrost cycle, do the defrost cycles ever overlap?

4 MARKUPS AND PROFITABILITY

DOE estimated the manufacturer production costs for the analyzed product classes of 

refrigeration products. DOE defines manufacturer production cost as all direct costs associated 

with manufacturing a product. It includes direct labor, direct materials, and overhead (which 

includes depreciation costs).

Manufacturer selling price is the average cost manufacturers charge their first consumers, but 
12-A-19

does not include additional costs along the distribution channels. The manufacturer selling price 

includes non-production costs including research and development; selling, general, and 

administrative expenses; shipping cost; and profit. The manufacturer markup is a multiplier 

applied to manufacturer production cost to cover these non-production costs and yield a profit. 

DOE estimated a baseline markup of 1.26 for refrigeration products. 

One of the primary objectives of the MIA is to assess the impact of amended energy 

conservation standards on industry profitability. In this section, DOE would like to understand 

the current markup structure of the industry and how setting an amended energy conservation 

standard would impact your company’s markup structure and profitability.

4.1 Is there a significant difference between the baseline markup DOE calculated and your 

company’s baseline markups for compact refrigerators and freezers? Is the 1.26 baseline markup 

factor representative of an average industry markup? 

4.2 Do profit levels currently vary by product class or product line? 

4.3 DOE would like to understand how the baseline manufacturer markup changes at higher 

efficiency levels. Do you currently earn a premium for more efficient products (i.e., ENERGY 

STAR or higher)? Please explain why or why not.

4.4 Does your markup change with selected design options? Is the markup on incremental 

costs for more efficient designs different than the markup on the baseline models (as is assumed 

for retailer markups used in the analyses)?

4.5 Would you expect changes in your estimated profitability following an amended energy 

conservation standard? If so, please explain why. 

5 SHIPMENT PROJECTIONS

An amended energy conservation standard can change overall shipments by altering product

attributes, marketing approaches, product availability, and prices. The industry revenue 

calculations are based on the shipment projections developed in DOE’s shipments model. The 

shipments model includes forecasts for the base case shipments (i.e., total industry shipments 

absent amended energy conservation standards) and the standards case shipments (i.e., total 

industry shipments with amended energy conservation standards).
12-A-20

To determine efficiency distributions after the effective date of the standard, DOE used a “rollup + market shift” scenario for 2014 and subsequent years. DOE assumed that product 

efficiencies in the base case that did not meet the standard under consideration would roll up to 

meet the new standard in 2014. DOE further assumed that the ENERGY STAR program would 

continue to promote efficient appliances after revised standards are introduced in 2014, resulting 

in a gradual market shift to higher efficiencies after the compliance date of the standard.

5.1 How do you think amended energy conservation standards will impact the sales of more 

efficient products? For example, would customers continue to buy products that exceed the 

energy conservation standard level? Would your response change for higher mandated efficiency 

levels?

5.2 DOE assumed that revised standards would cause product purchase prices to increase, 

resulting in reduced demand or shipments (price elasticity effect). DOE assumed an elasticity 

coefficient of -0.40, meaning a 10% increase in price would result in a 4% decrease in 

shipments. Do you agree with this assumption? How sensitive do you think shipments will be to 

price changes? Does it vary with product class?

6 FINANCIAL PARAMETERS

DOE’s contractor has developed a “strawman” model of the residential refrigeration products

industry financial performance called the Government Regulatory Impact Model (GRIM) using 

publicly available data. This section attempts to understand how your company’s financial 

situation differs from the industry aggregate picture.

6.1 Please compare your financial parameters to the GRIM parameters tabulated below.
12-A-21

Table 6.1 Financial Parameters for Residential Refrigeration Product Manufacturers

GRIM Input Definition Industry 

Estimated

Value

Your Actual (If 

Significantly 

Different from 

DOE’s 

Estimate)

Income Tax 

Rate

Corporate effective income tax paid (percentage of 

earnings before taxes, EBT) 33.9

Discount Rate

Weighted average cost of capital (inflationadjusted weighted average of corporate cost of 

debt and return on equity)

7.2

Working 

Capital

Current assets less current liabilities (percentage of 

revenues) 2.9

Net PPE Net plant property and equipment (percentage of 

revenues) 19.9

SG&A Selling, general, and administrative expenses 

(percentage of revenues) 12.5

R&D Research and development expenses (percentage 

of revenues) 2.2

Depreciation Amortization of fixed assets (percentage of 

revenues) 3.4

Capital 

Expenditures

Outlay of cash to acquire or improve capital assets 

(percentage of revenues, not including acquisition 

or sale of business units)

3.5

Cost of Goods 

Sold

Includes material, labor, overhead, and 

depreciation (percentage of revenues) 79.4

6.2 Are the figures in Table 6.1 representative of residential refrigeration manufacturing?

6.3 Do any of the financial parameters in Table 6.1 change based on product type or product 

class? Please describe any differences. 

6.4 How would you expect an amended energy conservation standard to impact any of the 

financial parameters for the industry?

7 CONVERSION COSTS

Amended energy conservation standards may cause your company to incur capital and product 

conversion costs to redesign existing products and make changes to existing production lines to 

be compliant with the amended energy conservation standard. Capital conversion costs are onetime investments in plant, property, and equipment (PPE) necessitated by an amended energy 

conservation standard. These may be incremental changes to existing PPE or the replacement of 

existing PPE. In addition to capital conversion costs, product conversion costs are costs related 

research, product development, testing, marketing and other costs for redesigning products 

necessitated by an amended energy conservation standard. Depending on their magnitude, the 

conversion costs can have a substantial impact on the outputs used by DOE to evaluate the 

industry impacts. Understanding the nature and magnitude of the conversion costs is critical 
12-A-22

portion of the MIA. Table 7.1 shows the design options used to research higher efficiencies for 

the major compact product categories covered by this rulemaking. Please refer to Table 7.1 when 

considering your response to the following questions. 

Table 7.1 Design Options Used to Improve Efficiency for each Major Compact Product 

Category

Product Type Design Options

Compact Refrigerator-Freezers Larger evaporators, thicker insulation, more efficient compressors, larger 

condensers, VIPs in the cabinet, and VIPs in the door

Compact Chest Freezers More efficient compressors, thicker insulation, VIPs in the bottom wall, and 

variable speed compressors

7.1 Are there certain efficiency levels for which the design changes would require relatively 

minor changes to existing products? Are there certain efficiency levels where the capital or 

product conversion costs significantly increase? Would your answer change for different product 

categories? Please describe these changes qualitatively. 

7.2 For each of the product categories shown in Table 7.1, which design options could be 

made within existing cabinet designs and which would result in major product redesigns? 

7.3 For the design options in Table 7.1, what kind of changes would need to be implemented

to production lines for each major product category? How much would these changes and other 

capital expenses cost? 

7.4 Would the changes in 7.3 be similar across all of your production lines and factories for 

each product category?

7.5 For each of the product categories, please qualify the number of and cost of new 

production equipment, molds, foaming fixtures, etc. that would be required to implement the 

specified design changes. Please consider which design changes would require changes to 

existing cavity designs/wrapper shells. 

7.6 What level of product development and other product conversion costs would you expect 

to incur for each of these design changes for each major product category?

7.7 For any design changes that would require new production equipment, please describe 

how much downtime would be required. What impact would downtime have on your business? 

Are there any design changes that could not be implemented before the compliance date of the 

final rule for certain product classes?

7.8 Please provide additional qualitative information to help DOE understand the types and

nature of your investments, including the plant and tooling changes and the product development 

effort required at different efficiency levels.
12-A-23

8 CUMULATIVE REGULATORY BURDEN

Cumulative regulatory burden refers to the burden that industry faces from overlapping effects of 

new or revised DOE standards, voluntary standards, and/or other regulatory actions affecting the 

same product or industry.

8.1 Are there other recent or impending regulations that residential refrigeration 

manufacturers face (from DOE or otherwise)? If so, could you identify the regulation and the 

corresponding possible effective dates for those regulations? Below is a list of regulations that 

could possibly affect manufacturers of residential refrigeration products. Please provide any 

comments on the listed regulations in addition to other regulations.

Table 8.1 Other Regulations Identified by DOE

Regulation Estimated or Actual Effective 

Date(s) Comments

DOE’s Energy Conservation Standards for 

Other Products and Equipment

International Energy-Efficiency Standards

Climate Change Legislation limiting or 

banning hydrofluorocarbons (discussed in 

section 9)

8.2 What level of expense are you expecting to incur as a result of these regulations?

8.3 Under what circumstances would you be able to coordinate any expenditure related to 

these other regulations with an amended energy conservation standard, thereby lessening the 

cumulative burden?

8.4 DOE research has identified the production tax credits in Table 8.2 for manufacturers of 

residential refrigeration products. Similar tax credits have also been proposed in the current 

version of the House energy bill. Has your company received benefit from the tax credits under 

the Energy Policy Act of 2005 (EPACT 2005) and Energy Improvement and Extension Act of 

2008 (EIEA 2008)? Do you know of any current or future tax credits or other benefits available 

to your company for manufacturing more efficient refrigeration products? If so, please describe.
12-A-24

Table 8.2 Federal Production Tax Credits Identified by DOE

Tax Credit 

Program

Effective Date Rolling Average 

Basis

Efficiency

Improvement 

Requirements

Tax Credit per 

Unit

Start End

EPACT 2005 2006 2006 3 years 15% $75 

2006 2007 3 years 20% $125 

2006 2007 3 years 25% $175 

EIEA 2008 2008 2008 2 years 20% $50 

2008 2009 2 years 23% $75 

2008 2010 2 years 25% $100 

2008 2010 2 years 30% $200 

9 IMPACTS OF POTENTIAL HFC REGULATIONS

9.1 Do you have data indicating the thermal performance of insulation foam using 

cyclopentane blowing agent? How does this compare with information you have seen regarding 

the performance of foam blown with HFC-245fa?

9.2 What are your expectations regarding the shift away from HFC foam blowing agents and 

away from HFC-134a refrigerant? Please indicate the percentage of your production using each 

of these as a function of year. If this depends on a specific key event, such as passage of 

greenhouse gas legislation, please provide an alternative curve assuming the occurrence of this 

event.

9.3 What are your expectations regarding the UL initiative to reconsider HC limits in 

refrigeration products? Can you comment on the efficiency of refrigerators that use HCs 

compared to those that do not?

9.4 What are your expectations of added capital and one-time costs associated with full 

conversion away from HFC blowing agents? Added capital and one-time costs associated with 

full conversion away from HFC-134a refrigerant? Added per-product cost associated with each 

of these conversions? What kinds of changes to your existing factories would be required to 

handle the blowing agents or refrigerants required if you stopped using HFCs? What would these 

changes cost? What level of product development would such a change require and what would 

this effort cost?

10 DIRECT EMPLOYMENT IMPACT ASSESSMENT

The impact of amended energy conservation standards on employment is an important 

consideration in the rulemaking process. This section of the interview guide seeks to explore 
12-A-25

current trends in employment and solicit manufacturer views on how domestic employment 

patterns might be affected by amended energy conservation standards.

10.1 Would your domestic employment levels be expected to change significantly under 

amended energy conservation standards? If so, please explain how they would change if higher 

efficiency levels are required.

10.2 Would the workforce skills necessary under amended energy conservation standards 

require extensive retraining or replacement of employees at your manufacturing facilities?

10.3 Would amended energy conservation standards require extensive retraining of your 

service/field technicians? If so, could you expand on how your service infrastructure would be 

impacted in general as a result of amended energy conservation standards?

11 EXPORTS / FOREIGN COMPETITION / OUTSOURCING

Disparity between domestic and foreign energy conservation standards could impact exports or 

imports. Labor content and material changes, resulting from amended energy conservation

standards, may impact sourcing decisions.

11.1 What percentage of your company’s residential refrigeration sales are in the United 

States? What percentage of your residential refrigeration sales are produced in the United 

States? 

11.2 Are there any foreign companies with North American production facilities?

 

11.3 Would amended energy conservation standards impact your domestic vs. foreign 

manufacturing or sourcing decisions? Is there an efficiency level that would cause you to move 

exiting domestic production facilities outside the U.S.?

11.4 What percentage of the U.S. market for compact refrigerators and freezers manufacturers 

is made outside the U.S.?

12 CONSOLIDATION

Amended energy conservation standards can alter the competitive dynamics of the market. This 

can include prompting companies to enter or exit the market, or to merge. DOE and the 

Department of Justice are both interested in any potential reduction in competition that would 

result from an amended energy conservation standard.

12.1 Please comment on industry consolidation and related trends over the last 5 years.

12.2 In the absence of amended energy conservation standards, do you expect any further 
12-A-26

industry consolidation? Please describe your expectations.

12.3 How would amended energy conservation standards affect your or other companies’ 

ability to compete?

13 IMPACTS ON SMALL BUSINESS

13.1 The Small Business Administration (SBA) denotes a small business in the residential 

refrigeration manufacturing industry as having less than 1,000 total employees, including the 

parent company and all subsidiaries.4 By this definition, is your company considered a small 

business?

13.2 Are there any reasons that a small business manufacturer might be at a disadvantage 

relative to a larger business under amended energy conservation standards? Please consider such 

factors as technical expertise, access to capital, bulk purchasing power for materials/components, 

engineering resources, and any other relevant issues.

13.3 Are there any niche manufacturers, small businesses manufacturers, and/or component 

manufacturers for which the adoption of amended energy conservation standards would have a 

severe impact? If so, would manufacturers of these products have different incremental impacts 

from implemented amended energy conservation standards than from the rest of the industry?

 4 DOE uses the small business size standards published on August 22, 2008, as amended, by the SBA to determine 

whether a company is a small business. To be categorized as a small business, a household refrigerator and home 

freezer manufacturers and its affiliates may employ a maximum of 1,000 employees. The 1,000 employee threshold 

includes all employees in a business’s parent company and any other subsidiaries. 
12-A-27

12-A.3 STANDARD SIZE REFRIGERATION PRODUCTS MANUFACTURER IMPACT 

ANALYSIS INTERVIEW GUIDE

January 13, 2010
12-A-28

The Department of Energy (DOE) conducts the manufacturer impact analysis (MIA) as part of 

the rulemaking process for amended energy conservation standards for refrigerators, refrigeratorfreezers, and freezers. In this analysis, DOE uses publicly available information and information 

provided by manufacturers during interviews to assess possible impacts on manufacturers due to 

amended energy conservation standards.

DOE explicitly analyzes the standard-size product classes in the tables below. For all product 

classes, DOE is currently considering eight efficiency levels (ELs) that correspond to percentage 

improvements over the existing standards. In responding to this questionnaire, please refer to the 

efficiency levels in the table below. DOE explains how it intends to determine the minimum 

efficiencies for the remaining product classes in the engineering chapter of the technical support 

document.5

 

Baseline Efficiencies for Analyzed Product Classes

Product 

Class 

Number

Product Type Product Class Description Equation for maximum 

energy use (kWh/yr))*

3 Refrigerator-Freezers

Automatic Defrost with Top-Mounted 

Freezer Without Through the Door (TTD)

Ice Service

10.72 AV + 310.2

5 Refrigerator-Freezers Automatic Defrost with Bottom-Mounted 

Freezer Without TTD Ice Service 5.32 AV + 542.5

7 Refrigerator-Freezers Automatic Defrost with Side-Mounted 

Freezer With TTD Ice Service 11.33 AV + 462.8

9 Freezers Upright Freezers with Automatic Defrost 12.32 AV + 326.1

10 Freezers Chest Freezers and all Other Freezers 

Except Compact Freezers

9.71 AV + 143.7

AV= adjusted volume in cubic feet

* These definitions are based on testing according to the current energy test procedure. DOE expects to propose 

revisions in the energy test procedure to harmonize with expected test temperatures under consideration for IEC test 

procedure 62552 and will adjust the equations accordingly. However, for the purpose of identifying the efficiency 

levels of products in the table below, it is assumed that the percent efficiency level (i.e. the difference between 

baseline energy use and improved product energy use divided by baseline energy use and multiplied by 100%) does 

not depend on which test procedure is used to determine energy use.

Efficiency Levels Under Consideration for all Product Classes

Percentage Decrease in kWh/yr from Calculated Baseline 

Efficiency

EL 1 EL 2 EL 3 EL 4 EL 5 EL 6 EL 7 EL 8

10% 15% 20% 25% 30% 35% 40% 45%

1 KEY ISSUES

 5 Please see 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/refrigerators_freezers_prelim_tsd_mtg.html 

for a complete description. 
12-A-29

1.1 In general, what are the key issues for your company regarding amended energy 

conservation standards for residential refrigeration products and this rulemaking?

1.2 For the issues identified, does the severity change for different product classes? Do some 

issues become more significant at higher efficiency levels? Are certain issues more of a concern 

for certain product classes?

1.3 How can DOE most effectively incorporate these issues in the MIA?

2 COMPANY OVERVIEW AND ORGANIZATIONAL CHARACTERISTICS

DOE is interested in understanding manufacturer impacts at the plant or profit center level 

directly pertinent to residential refrigeration production. However, the context within which the 

plant operates and the details of plant production and costs are not always readily available from 

public sources. Therefore, DOE invites you to provide these details confidentially in your own 

words to the extent possible and practical. Understanding the organizational setting around the 

residential refrigeration industry profit center will help DOE understand the probable future of 

the manufacturing activity with and without amended energy conservation standards.

2.1 Do you have a parent company, and/or any subsidiaries relevant to the residential 

refrigeration industry?

2.2 Do you manufacture any products other than residential refrigeration products? If so, 

what other products do you manufacture? What percentage of your total manufacturing revenue 

corresponds to residential refrigeration products?

2.3 What product classes of refrigeration products do you manufacturer? 

2.4 Where are your residential refrigeration production facilities located, and what types of 

products are manufactured at each location? Could you provide annual shipment figures for your 

company’s residential refrigeration manufacturing at each location by product line (i.e., topmount refrigerator-freezers, bottom-mount refrigerator-freezers, etc.)?

2.5 At your manufacturing facilities, would potential residential refrigeration product 

redesigns be difficult to implement? If so, would your company modify the existing facility or 

develop a new facility?

2.6 What are your employment levels at each of these facilities?

2.7 What is your company’s approximate market share in the standard-size refrigeratorfreezer and standard-size freezer markets?
12-A-30

3 ENGINEERING AND LIFE CYCLE COST ANALYSIS FOLLOW-UP

3.1 For the products directly analyzed for the Engineering Analysis that represent the bulk of 

residential refrigeration product sales, can you comment on the progressive use of design options 

for achieving the successively higher efficiency levels (compared with the design option 

information presented by efficiency level in Appendix 5A of the preliminary TSD)?

3.2 Are the incremental design option costs used in the Engineering Analysis and described 

in Chapter 5 of the preliminary TSD representative of costs your company pays for these design 

options? If not, please provide a quantitative indication of the differences.

3.3 How would the cost-efficiency curves of low-production-volume product classes differ 

from those developed for the directly-analyzed product classes most closely related to them? The 

table below provides an indication of expectations for representation of low-volume product 

classes. Please comment for your key products of the low-volume product classes.

Low-volume 

Product 

Classes

1A, 1, 2, 

3A 4 5A 6 8 10A

Representative 

Product Class 3 7 5 3 10 9

3.4 Do you sell any standard-size all-refrigerators with manual (not off-cycle) defrost?

3.5 Do you sell any compact upright freezers with automatic defrost (PC 17)? If so, can you 

describe your product line(s) for this class and provide shipment estimates?

3.6 Do you have warrantee and/or maintenance cost data illustrating the impact of any of the 

following design options on maintenance cost: electronic controls, high-efficiency single-speed 

compressors, variable-speed compressors, brushless DC fans, VIPs, and humidity sensors?

3.7 What are the expected differences in cost per unit area of VIP applied to a product 

between application to the door and application to the cabinet? Are these costs differences for 

labor costs, material costs, capital costs, or other types of costs?

3.8 What is your company’s level of operation (by shipment volume) in other world markets 

where significant reductions in energy use have been or are expected to be mandated, 

particularly India and the EU?

3.9 How would repair and maintenance costs be impacted by more stringent energy 

conservation standards? How would the frequency of repair and maintenance be affected? How 

would the nature of the repair and maintenance work needed change with more stringent energy 

conservation standards?
12-A-31

3.10 Can you provide any information on consumer placement of built-in undercounter

products and built-in upright freezers and on implications of possible wall thickness increases?

3.11 For standard size refrigerator-freezers, what percent reduction in internal volume would 

you implement prior to use of VIPs in order to maintain external dimensions?

3.12 Which product classes might be candidates for energy/adjusted volume curve slope 

changes? Do you have any information that would inform DOE’s development of a response to 

this issue?

3.13 What information can be provided to provide a better understanding of the variation of 

costs to achieve efficiency levels? What information can be provided to provide a better 

understanding of how cost-efficiency curves for the low-volume product classes not directly 

analyzed are different?

3.14 What platform differences exist between product class 4 and product class 7? Between 

product class 6 and product class 3? Between product class 5 and product class 5A?

3.15 Can you provide engineering details for baseline efficiency built-in units and ENERGY 

STAR built-in units, such as typical wall thickness, insulation used, evaporator and condenser 

description, fan types and wattages, and compressor model or capacity? Can you provide specific 

data for a representative model for each applicable product class?

3.16 Do you see any possible loopholes in the proposed AHAM built-in definition? 

“Refrigerators, freezers and refrigerators with freezer units that are 7.75 cubic feet or greater; are 

totally encased by cabinetry or panels by either accepting a custom front panel or being equipped 

with an integral factory-finished face; are intended to be securely fastened to adjacent cabinetry, 

walls or floor; has sides which are not fully finished and are not intended to be visible after 

installation.”

3.17 Can you provide any data showing how much of the expected benefits of VIPs are 

actually achieved in prototypes or manufactured products? Can you provide any data regarding 

panel failures in the field? Can you provide any data on scrap rates at the factory (what 

percentage of delivered VIPs must be scrapped)? Can you provide any data regarding resistivity 

decline of “good” panels over a span of years up to typical product lifetime?

3.18 How do the design option costs for your company compare to the values DOE used in its 

analysis as described in the preliminary TSD?

3.19 How do the bulk materials costs for your company compare to the values DOE used in its 

analysis as described in the preliminary TSD?

3.20 For variable anti-sweat heaters, what is the typical maximum wattage for a French door 

product and what is a typical control algorithm?
12-A-32

3.21 For variable defrost used with single-compressor/dual-evaporator systems, is it common 

to have more than one defrost cycle? How is this treated in the energy test? For products with 

more than one defrost cycle, do the defrost cycles ever overlap?

4 MARKUPS AND PROFITABILITY

DOE estimated the manufacturer production costs for the analyzed product classes of 

refrigeration products. DOE defines manufacturer production cost as all direct costs associated 

with manufacturing a product. It includes direct labor, direct materials, and overhead (which 

includes depreciation costs).

Manufacturer selling price is the average cost manufacturers charge their first consumers, but 

does not include additional costs along the distribution channels. The manufacturer selling price 

includes non-production costs including research and development; selling, general, and 

administrative expenses; shipping cost; and profit. The manufacturer markup is a multiplier 

applied to manufacturer production cost to cover these non-production costs and yield a profit. 

DOE estimated a baseline markup of 1.26 for refrigeration products. 

One of the primary objectives of the MIA is to assess the impact of amended energy 

conservation standards on industry profitability. In this section, DOE would like to understand 

the current markup structure of the industry and how setting an amended energy conservation 

standard would impact your company’s markup structure and profitability.

4.1 Is there a significant difference between the baseline markup DOE calculated and your 

company’s baseline markups for standard-size refrigerator-freezers and standard-size freezers? Is 

the 1.26 baseline markup factor representative of an average industry markup? 

4.2 Do profit levels currently vary by product class or product line? 

4.3 DOE would like to understand how the baseline manufacturer markup changes at higher 

efficiency levels. Do you currently earn a premium for more efficient products (i.e., ENERGY 

STAR or higher)? Please explain why or why not.

4.4 Does your markup change with selected design options? Is the markup on incremental 

costs for more efficient designs different than the markup on the baseline models (as is assumed 

for retailer markups used in the analyses)?

4.5 Would you expect changes in your estimated profitability following an amended energy 

conservation standard? If so, please explain why. 

5 SHIPMENT PROJECTIONS

An amended energy conservation standard can change overall shipments by altering product
12-A-33

attributes, marketing approaches, product availability, and prices. The industry revenue 

calculations are based on the shipment projections developed in DOE’s shipments model. The 

shipments model includes forecasts for the base case shipments (i.e., total industry shipments 

absent amended energy conservation standards) and the standards case shipments (i.e., total 

industry shipments with amended energy conservation standards).

To determine efficiency distributions after the effective date of the standard, DOE used a “rollup + market shift” scenario for 2014 and subsequent years. DOE assumed that product 

efficiencies in the base case that did not meet the standard under consideration would roll up to 

meet the new standard in 2014. DOE further assumed that the ENERGY STAR program would 

continue to promote efficient appliances after revised standards are introduced in 2014, resulting 

in a gradual market shift to higher efficiencies after the compliance date of the standard.

5.1 How do you think amended energy conservation standards will impact the sales of more 

efficient products? For example, would customers continue to buy products that exceed the 

energy conservation standard level? Would your response change for higher mandated efficiency 

levels?

5.2 DOE assumed that revised standards would cause product purchase prices to increase, 

resulting in reduced demand or shipments (price elasticity effect). DOE assumed an elasticity 

coefficient of -0.40, meaning a 10% increase in price would result in a 4% decrease in 

shipments. Do you agree with this assumption? How sensitive do you think shipments will be to 

price changes? Does it vary with product class?

6 FINANCIAL PARAMETERS

DOE’s contractor has developed a “strawman” model of the residential refrigeration products

industry financial performance called the Government Regulatory Impact Model (GRIM) using 

publicly available data. This section attempts to understand how your company’s financial 

situation differs from the industry aggregate picture.

6.1 Please compare your financial parameters to the GRIM parameters tabulated below.
12-A-34

Table 6.1 Financial Parameters for Residential Refrigeration Product Manufacturers

GRIM Input Definition Industry 

Estimated

Value

Your Actual (If 

Significantly 

Different from 

DOE’s 

Estimate)

Income Tax 

Rate

Corporate effective income tax paid (percentage of 

earnings before taxes, EBT) 33.9

Discount Rate

Weighted average cost of capital (inflationadjusted weighted average of corporate cost of 

debt and return on equity)

7.2

Working 

Capital

Current assets less current liabilities (percentage of 

revenues) 2.9

Net PPE Net plant property and equipment (percentage of 

revenues) 19.9

SG&A Selling, general, and administrative expenses 

(percentage of revenues) 12.5

R&D Research and development expenses (percentage 

of revenues) 2.2

Depreciation Amortization of fixed assets (percentage of 

revenues) 3.4

Capital 

Expenditures

Outlay of cash to acquire or improve capital assets 

(percentage of revenues, not including acquisition 

or sale of business units)

3.5

Cost of Goods 

Sold

Includes material, labor, overhead, and 

depreciation (percentage of revenues) 79.4

6.2 Are the figures in Table 6.1 representative of residential refrigeration manufacturing?

6.3 Do any of the financial parameters in Table 6.1 change based on product type or product 

class? Please describe any differences. 

6.4 How would you expect an amended energy conservation standard to impact any of the 

financial parameters for the industry?

7 CONVERSION COSTS

Amended energy conservation standards may cause your company to incur capital and product 

conversion costs to redesign existing products and make changes to existing production lines to 

be compliant with the amended energy conservation standard. Capital conversion costs are onetime investments in plant, property, and equipment (PPE) necessitated by an amended energy 

conservation standard. These may be incremental changes to existing PPE or the replacement of 

existing PPE. In addition to capital conversion costs, product conversion costs are costs related 

research, product development, testing, marketing and other costs for redesigning products 

necessitated by an amended energy conservation standard. Depending on their magnitude, the 

conversion costs can have a substantial impact on the outputs used by DOE to evaluate the 

industry impacts. Understanding the nature and magnitude of the conversion costs is critical 
12-A-35

portion of the MIA. Table 7.1 shows the design options used to research higher efficiencies for 

the major product categories covered by this rulemaking. Please refer to Table 7.1 when 

considering your response to the following questions. 

Table 7.1 Design Options Used to Improve Efficiency for each Major Standard-Size 

Product Category

Product Type Design Options

Top-Mount RefrigeratorFreezersMore efficient compressors, larger evaporators, larger condensers, brushless DC 

fan motors, adaptive defrost, and VIPs in the cabinet

Side-Mount RefrigeratorFreezersMore efficient compressors, brushless DC fan motors, adaptive defrost, larger 

evaporators, larger condensers, VIPs in the cabinet, VIPs in the door, and 

variable speed compressors

Bottom-Mount RefrigeratorFreezersMore efficient compressors, brushless DC fan motors, variable anti-sweat heater 

control, adaptive defrost, larger condensers, larger evaporators, and VIPs in the 

cabinet

Upright Freezers Brushless DC fan motors, thicker insulation, adaptive defrost, more efficient 

compressors, larger evaporators, forced convection condensers, VIPs in the 

cabinet, and VIPs in the door

Chest Freezers Larger condensers, larger evaporators, thicker insulation, more efficient

compressors, variable speed compressors, VIPs in the bottom wall, and VIPs in 

the door

7.1 Are there certain efficiency levels for which the design changes would require relatively 

minor changes to existing products? Are there certain efficiency levels where the capital or 

product conversion costs significantly increase? Would your answer change for different product 

categories? Please describe these changes qualitatively. 

7.2 For each of the product categories shown in Table 7.1, which design options could be 

made within existing cabinet designs and which would result in major product redesigns? 

7.3 For the design options in Table 7.1, what kind of changes would need to be implemented

to production lines for each major standard-size product category? How much would these 

changes and other capital expenses cost? 

7.4 Would the changes in 7.3 be similar across all of your production lines and factories for 

each product category?

7.5 For each of the standard-size product categories, please qualify the number of and cost of 

new production equipment, molds, foaming fixtures, etc. that would be required to implement 

the specified design changes. Please consider which design changes would require changes to 

existing cavity designs/wrapper shells. 

7.6 What level of product development and other product conversion costs would you expect 

to incur for each of these design changes for each major standard-size product category?

7.7 For any design changes that would require new production equipment, please describe 

how much downtime would be required. What impact would downtime have on your business? 
12-A-36

Are there any design changes that could not be implemented before the compliance date of the 

final rule for certain product classes?

7.8 Please provide additional qualitative information to help DOE understand the types and

nature of your investments, including the plant and tooling changes and the product development 

effort required at different efficiency levels.

8 CUMULATIVE REGULATORY BURDEN

Cumulative regulatory burden refers to the burden that industry faces from overlapping effects of 

new or revised DOE standards, voluntary standards, and/or other regulatory actions affecting the 

same product or industry.

8.1 Are there other recent or impending regulations that residential refrigeration 

manufacturers face (from DOE or otherwise)? If so, could you identify the regulation and the 

corresponding possible effective dates for those regulations? Below is a list of regulations that 

could possibly affect manufacturers of residential refrigeration products. Please provide any 

comments on the listed regulations in addition to other regulations.

Table 8.1 Other Regulations Identified by DOE

Regulation Estimated or Actual Effective 

Date(s) Comments

DOE’s Energy Conservation Standards for 

Other Products and Equipment

International Energy-Efficiency Standards

Climate Change Legislation limiting or 

banning hydrofluorocarbons (discussed in 

section 9)

8.2 What level of expense are you expecting to incur as a result of these regulations?

8.3 Under what circumstances would you be able to coordinate any expenditure related to 

these other regulations with an amended energy conservation standard, thereby lessening the 

cumulative burden?

8.4 DOE research has identified the production tax credits in Table 8.2 for manufacturers of 

residential refrigeration products. Similar tax credits have also been proposed in the current 

version of the House energy bill. Has your company received benefit from the tax credits under 

the Energy Policy Act of 2005 (EPACT 2005) and Energy Improvement and Extension Act of 

2008 (EIEA 2008)? Do you know of any current or future tax credits or other benefits available 

to your company for manufacturing more efficient refrigeration products? If so, please describe.
12-A-37

Table 8.2 Federal Production Tax Credits Identified by DOE

Tax Credit 

Program

Effective Date Rolling Average 

Basis

Efficiency

Improvement 

Requirements

Tax Credit per 

Unit

Start End

EPACT 2005 2006 2006 3 years 15% $75 

2006 2007 3 years 20% $125 

2006 2007 3 years 25% $175 

EIEA 2008 2008 2008 2 years 20% $50 

2008 2009 2 years 23% $75 

2008 2010 2 years 25% $100 

2008 2010 2 years 30% $200 

9 IMPACTS OF POTENTIAL HFC REGULATIONS

9.1 Do you have data indicating the thermal performance of insulation foam using 

cyclopentane blowing agent? How does this compare with information you have seen regarding 

the performance of foam blown with HFC-245fa?

9.2 What are your expectations regarding the shift away from HFC foam blowing agents and 

away from HFC-134a refrigerant? Please indicate the percentage of your production using each 

of these as a function of year. If this depends on a specific key event, such as passage of 

greenhouse gas legislation, please provide an alternative curve assuming the occurrence of this 

event.

9.3 What are your expectations regarding the UL initiative to reconsider HC limits in 

refrigeration products? Can you comment on the efficiency of refrigerators that use HCs 

compared to those that do not?

9.4 What are your expectations of added capital and one-time costs associated with full 

conversion away from HFC blowing agents? Added capital and one-time costs associated with 

full conversion away from HFC-134a refrigerant? Added per-product cost associated with each 

of these conversions? What kinds of changes to your existing factories would be required to 

handle the blowing agents or refrigerants required if you stopped using HFCs? What would these 

changes cost? What level of product development would such a change require and what would 

this effort cost?

10 DIRECT EMPLOYMENT IMPACT ASSESSMENT

The impact of amended energy conservation standards on employment is an important 

consideration in the rulemaking process. This section of the interview guide seeks to explore 
12-A-38

current trends in residential refrigeration employment and solicit manufacturer views on how 

domestic employment patterns might be affected by amended energy conservation standards.

10.1 Would your domestic employment levels be expected to change significantly under 

amended energy conservation standards? If so, please explain how they would change if higher 

efficiency levels are required.

10.2 Would the workforce skills necessary under amended energy conservation standards 

require extensive retraining or replacement of employees at your manufacturing facilities?

10.3 Would amended energy conservation standards require extensive retraining of your 

service/field technicians? If so, could you expand on how your service infrastructure would be 

impacted in general as a result of amended energy conservation standards?

11 EXPORTS / FOREIGN COMPETITION / OUTSOURCING

Disparity between domestic and foreign energy conservation standards could impact exports or 

imports. Labor content and material changes, resulting from amended energy conservation

standards, may impact sourcing decisions.

11.1 What percentage of your company’s residential refrigeration sales are in the United 

States? What percentage of your residential refrigeration sales are produced in the United 

States? 

11.2 Are there any foreign companies with North American production facilities?

 

11.3 Would amended energy conservation standards impact your domestic vs. foreign 

manufacturing or sourcing decisions? Is there an efficiency level that would cause you to move 

exiting domestic production facilities outside the U.S.?

11.4 What percentage of the U.S. market for standard size refrigerators, refrigerator-freezers,

and freezers is made outside the U.S.?

12 CONSOLIDATION

Amended energy conservation standards can alter the competitive dynamics of the market. This 

can include prompting companies to enter or exit the market, or to merge. DOE and the 

Department of Justice are both interested in any potential reduction in competition that would 

result from an amended energy conservation standard.

12.1 Please comment on industry consolidation and related trends over the last 5 years.

12.2 In the absence of amended energy conservation standards, do you expect any further 
12-A-39

industry consolidation? Please describe your expectations.

12.3 How would amended energy conservation standards affect your or other companies’ 

ability to compete?

13 IMPACTS ON SMALL BUSINESS

13.1 The Small Business Administration (SBA) denotes a small business in the residential 

refrigeration manufacturing industry as having less than 1,000 total employees, including the 

parent company and all subsidiaries.6 By this definition, is your company considered a small 

business?

13.2 Are there any reasons that a small business manufacturer might be at a disadvantage 

relative to a larger business under amended energy conservation standards? Please consider such 

factors as technical expertise, access to capital, bulk purchasing power for materials/components, 

engineering resources, and any other relevant issues.

13.3 Are there any niche manufacturers, small businesses manufacturers, and/or component 

manufacturers for which the adoption of amended energy conservation standards would have a 

severe impact? If so, would manufacturers of these products have different incremental impacts 

from implemented amended energy conservation standards than from the rest of the industry?

 6 DOE uses the small business size standards published on August 22, 2008, as amended, by the SBA to determine 

whether a company is a small business. To be categorized as a small business, a household refrigerator and home 

freezer manufacturers and its affiliates may employ a maximum of 1,000 employees. The 1,000 employee threshold 

includes all employees in a business’s parent company and any other subsidiaries. 
12-B-i

APPENDIX 12-B. GOVERNMENT REGULATORY IMPACT MODEL (GRIM)

OVERVIEW

TABLE OF CONTENTS

12-B.1 INTRODUCTION AND PURPOSE.................................................................................. 1

12-B.2 MODEL DESCRIPTION ................................................................................................... 1

12-B.3 DETAILED CASH FLOW EXAMPLE............................................................................. 4
12-B-1

APPENDIX 12-B. GOVERNMENT REGULATORY IMPACT MODEL (GRIM)

OVERVIEW

12-B.1 INTRODUCTION AND PURPOSE

The purpose of the Government Regulatory Impact Model (GRIM) is to help quantify the 

impacts of energy conservation standards and other regulations on manufacturers. The basic 

mode of analysis is to estimate the change in the value of the industry or manufacturers(s) 

following a regulation or a series of regulations. The model structure also allows an analysis of 

multiple products with regulations taking effect over a period of time, and of multiple regulations 

on the same products.

Industry net present value is defined, for the purpose of this analysis, as the discounted 

sum of industry free cash flows plus a discounted terminal value. The model calculates the actual 

cash flows by year and then determines the present value of those cash flows both without an 

energy conservation standard (i.e., the base case) and under different trial standard levels (TSLs) 

(i.e., the standards case).

Output from the model consists of summary financial metrics, graphs of major variables, 

and, when appropriate, access to the complete cash flow calculation.

12-B.2 MODEL DESCRIPTION

The basic structure of the GRIM is a standard annual cash flow analysis that uses 

manufacturer selling prices, manufacturing costs, a shipments forecast, and financial parameters 

as inputs and accepts a set of regulatory conditions as changes in costs and investments. The cash 

flow analysis is separated into two major blocks: income and cash flow. The income calculation 

determines net operating profit after taxes. The cash flow calculation converts net operating 

profit after taxes into an annual cash flow by including investment and non-cash items. Below 

are definitions of listed items on the printout of the output sheet (see Section 12A.6.3).

(1) Unit Sales: Total annual shipments for the industry were obtained from the National Impact 

Analysis Spreadsheet;

(2) Revenues: Annual revenues - computed by multiplying products’ unit prices at each 

efficiency level by the appropriate manufacturer markup;

(3) Labor: The portion of cost of goods sold (COGS) that includes direct labor, commissions, 

dismissal pay, bonuses, vacation, sick leave, social security contributions, fringe, and 

assembly labor up-time; 

(4) Material: The portion of COGS that includes materials;
12-B-2

(5) Overhead: The portion of COGS that includes indirect labor, indirect material, energy use, 

maintenance, depreciation, property taxes, and insurance related to assets. While included 

in overhead, the depreciation is shown as a separate line item;

(6) Depreciation: The portion of overhead that includes an allowance for the total amount of 

fixed assets used to produce that one unit. Annual depreciation computed as a percentage of

COGS. While included in overhead, the depreciation is shown as a separate line item;

(7) Stranded Assets: In the year the standard becomes effective, a one time write-off of 

stranded assets is accounted for;

(8) Standard SG&A: Selling, general, and administrative costs are computed as a percentage of 

Revenues (2);

(9) R&D: GRIM separately accounts for ordinary research and development (R&D) as a 

percentage of Revenues (2);

(10) Product Conversion Costs: Product conversion costs are one-time investments in research, 

development, testing, marketing, and other costs focused on making products designs 

comply with the new energy conservation standard. The GRIM allocates these costs over 

the period between the standard’s announcement and compliance dates;

(11) Earnings Before Interest and Taxes (EBIT): Includes profits before deductions for interest 

paid and taxes;

(12) EBIT as a Percentage of Sales (EBIT/Revenues): GRIM calculates EBIT as a percentage 

of sales to compare with the industry’s average reported in financial statements;

(13) Taxes: Taxes on EBIT (11) are calculated by multiplying the tax rate contained in Major 

Assumptions by EBIT (11).

(14) Net Operating Profits After Taxes (NOPAT): Computed by subtracting Cost of Goods 

Sold ((3) to (6)), SG&A (8), R&D (9), Product Conversion Costs (10), and Taxes (13)

from Revenues (2).

(15) NOPAT repeated: NOPAT is repeated in the Statement of Cash Flows;

(16) Depreciation repeated: Depreciation and Stranded Assets are added back in the Statement 

of Cash Flows because they are non-cash expenses;

(17) Change in Working Capital: Change in cash tied up in accounts receivable, inventory, and 

other cash investments necessary to support operations is calculated by multiplying 

working capital (as a percentage of revenues) by the change in annual revenues. 

(18) Cash Flow From Operations: Calculated by taking NOPAT (15), adding back non-cash 

items such as a Depreciation (16), and subtracting the Change in Working Capital (17);
12-B-3

(19) Ordinary Capital Expenditures: Ordinary investments in property, plant, and equipment to 

maintain and replace existing production assets, computed as a percentage of Revenues (2);

(20) Capital Conversion Costs: Capital conversion costs are one-time investments in property, 

plant, and equipment to adapt or change existing production facilities so that new product 

designs can be fabricated and assembled under the new regulation; The GRIM allocates 

these costs over the period between the standard’s announcement and compliance dates;

(21) Capital Investment: Total investments in property, plant, and equipment are computed by 

adding Ordinary Capital Expenditures (19) and Capital Conversion Costs (20);

(22) Free Cash Flow: Annual cash flow from operations and investments; computed by 

subtracting Capital Investment (21) from Cash Flow from Operations (18);

(23) Terminal Value: Estimate of the continuing value of the industry after the analysis period. 

Computed by growing the Free Cash Flow at the beginning of 2045 at a constant rate in 

perpetuity;

(24) Present Value Factor: Factor used to calculate an estimate of the present value of an 

amount to be received in the future;

(25) Discounted Cash Flow: Free Cash Flows (22) multiplied by the Present Value Factor 

(24). For the end of 2043, the discounted cash flow includes the discounted Terminal Value 

(23); and

(26) Industry Value thru the end of 2043: The sum of Discounted Cash Flows (25).
12-B-4

12-B.3 DETAILED CASH FLOW EXAMPLE

Standards Case Income and Cash Flow Statements

This tab computes key parameters from an income statement based on unit sales, revenues and COGS, and initial financial inputs (parameters as a % of revenue). It also computes an INPV based on a discounted cash flow model.

Base Year

Announcement 

Year Standard Year

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Industry Income Statement (Base Case)

Unit Sales 9.061 8.990 9.639 10.683 11.356 11.743 9.926 10.637 11.196 11.572 11.966 12.252 12.516 12.708 12.918 13.166 13.400

Revenues $ 4,645.8 $ 4,487.3 $ 4,692.5 $ 5,212.5 $ 5,552.0 $ 5,753.0 $ 7,527.5 $ 8,046.3 $ 8,457.7 $ 8,739.9 $ 9,036.4 $ 9,258.8 $ 9,465.2 $ 9,614.1 $ 9,776.7 $ 9,968.3 $ 10,151.5

Cost of Sales

Labor $ 601.6 $ 583.0 $ 611.7 $ 679.3 $ 723.3 $ 749.3 $ 728.1 $ 777.7 $ 817.1 $ 844.3 $ 872.9 $ 894.6 $ 914.7 $ 929.1 $ 944.9 $ 963.6 $ 981.4

Material $ 2,618.3 $ 2,520.8 $ 2,628.0 $ 2,920.0 $ 3,111.0 $ 3,224.4 $ 4,748.9 $ 5,076.5 $ 5,336.3 $ 5,514.4 $ 5,701.5 $ 5,841.7 $ 5,971.8 $ 6,065.6 $ 6,168.2 $ 6,289.0 $ 6,404.5

Overhead $ 314.0 $ 309.4 $ 329.7 $ 365.7 $ 388.9 $ 402.3 $ 392.9 $ 420.6 $ 442.4 $ 457.3 $ 472.8 $ 484.3 $ 494.9 $ 502.5 $ 510.9 $ 520.9 $ 530.2

Depreciation $ 153.3 $ 148.1 $ 154.9 $ 172.0 $ 183.2 $ 189.8 $ 254.7 $ 272.2 $ 286.2 $ 295.7 $ 305.7 $ 313.3 $ 320.2 $ 325.3 $ 330.8 $ 337.2 $ 343.4

Stranded Assets $ - $ - $ - $ - $ - $ - $ 1,006.5 $ - $ - $ - $ - $ - $ - $ - $ - $ - $ -

Selling, General, & Administrative Expenses

Standard SG&A $ 580.7 $ 560.9 $ 586.6 $ 651.6 $ 694.0 $ 719.1 $ 940.9 $ 1,005.8 $ 1,057.2 $ 1,092.5 $ 1,129.6 $ 1,157.4 $ 1,183.1 $ 1,201.8 $ 1,222.1 $ 1,246.0 $ 1,268.9

R&D $ 102.2 $ 98.7 $ 103.2 $ 114.7 $ 122.1 $ 126.6 $ 165.6 $ 177.0 $ 186.1 $ 192.3 $ 198.8 $ 203.7 $ 208.2 $ 211.5 $ 215.1 $ 219.3 $ 223.3

Product Conversion Costs $ - $ - $ - $ 99.4 $ 139.2 $ 159.1 $ 8.1 $ - $ - $ - $ - $ - $ - $ - $ - $ - $ -

Earnings Before Interest and Taxes (EBIT) $ 275.7 $ 266.3 $ 278.5 $ 209.9 $ 190.3 $ 182.3 $ (718.1) $ 316.5 $ 332.5 $ 343.5 $ 355.1 $ 364.0 $ 372.3 $ 378.2 $ 384.7 $ 392.3 $ 399.7

EBIT/Revenues 5.9% 5.9% 5.9% 4.0% 3.4% 3.2% -9.5% 3.9% 3.9% 3.9% 3.9% 3.9% 3.9% 3.9% 3.9% 3.9% 3.9%

Taxes $ 93.5 $ 90.3 $ 94.4 $ 71.2 $ 64.5 $ 61.8 $ - $ 107.3 $ 112.7 $ 116.5 $ 120.4 $ 123.4 $ 126.2 $ 128.2 $ 130.4 $ 133.0 $ 135.5

Net Operating Profit after Taxes (NOPAT) $ 182.3 $ 176.0 $ 184.1 $ 138.8 $ 125.8 $ 120.5 $ (718.1) $ 209.2 $ 219.8 $ 227.1 $ 234.7 $ 240.6 $ 246.1 $ 250.0 $ 254.3 $ 259.3 $ 264.2

Cash Flow Statement (Base Case)

NOPAT $ 182.3 $ 176.0 $ 184.1 $ 138.8 $ 125.8 $ 120.5 $ (718.1) $ 209.2 $ 219.8 $ 227.1 $ 234.7 $ 240.6 $ 246.1 $ 250.0 $ 254.3 $ 259.3 $ 264.2

Depreciation $ 153.3 $ 148.1 $ 154.9 $ 172.0 $ 183.2 $ 189.8 $ 1,261.1 $ 272.2 $ 286.2 $ 295.7 $ 305.7 $ 313.3 $ 320.2 $ 325.3 $ 330.8 $ 337.2 $ 343.4

Change in Working Capital $ 134.7 $ 4.6 $ (6.0) $ (15.1) $ (9.8) $ (5.8) $ (51.5) $ (15.0) $ (11.9) $ (8.2) $ (8.6) $ (6.4) $ (6.0) $ (4.3) $ (4.7) $ (5.6) $ (5.3)

Cash Flow from Operations $ 470.3 $ 328.7 $ 333.0 $ 295.7 $ 299.1 $ 304.5 $ 491.6 $ 466.4 $ 494.0 $ 514.6 $ 531.9 $ 547.4 $ 560.3 $ 570.9 $ 580.3 $ 591.0 $ 602.3

Ordinary Capital Expenditure $ (167.2) $ (161.5) $ (168.9) $ (187.6) $ (199.9) $ (207.1) $ (271.0) $ (289.7) $ (304.5) $ (314.6) $ (325.3) $ (333.3) $ (340.7) $ (346.1) $ (352.0) $ (358.9) $ (365.5)

Capital Conversion Costs $ - $ - $ - $ (503.2) $ (704.5) $ (805.2) $ - $ - $ - $ - $ - $ - $ - $ - $ - $ - $ -

Capital Investments $ (167.2) $ (161.5) $ (168.9) $ (690.9) $ (904.4) $ (1,012.3) $ (271.0) $ (289.7) $ (304.5) $ (314.6) $ (325.3) $ (333.3) $ (340.7) $ (346.1) $ (352.0) $ (358.9) $ (365.5)

Federal Production Tax Benefit $ 36.56

Free Cash Flow $ 303.0 $ 167.2 $ 200.6 $ (395.2) $ (605.3) $ (707.8) $ 220.6 $ 176.7 $ 189.5 $ 199.9 $ 206.6 $ 214.1 $ 219.6 $ 224.8 $ 228.4 $ 232.1 $ 236.8

Terminal Value $ - $ - $ - $ - $ - $ - $ - $ - $ - $ - $ - $ - $ - $ - $ - $ - $ -

Present Value Factor 0.00 0.00 1.00 0.93 0.87 0.81 0.76 0.71 0.66 0.61 0.57 0.53 0.50 0.47 0.43 0.41 0.38

Discounted Cash Flow $ - $ - $ 200.6 $ (368.7) $ (526.7) $ (574.5) $ 167.0 $ 124.8 $ 124.9 $ 122.9 $ 118.4 $ 114.5 $ 109.6 $ 104.6 $ 99.1 $ 94.0 $ 89.5

Industry Value through 2043 $ 1,018.29
12-C-i

APPENDIX 12-C. FEDERAL PRODUCTION TAX CREDIT

TABLE OF CONTENTS

12-C.1 INTRODUCTION ...............................................................................................................1

12-C.2 ELIGIBILITY REQUIREMENTS ......................................................................................1

12-C.3 ELIGIBLE REFRIGERATION PRODUCTS.....................................................................2

12-C.4 ESTIMATED FEDERAL TAX CREDIT BENEFITS........................................................3

12-C.5 IMPACTS ON INDUSTRY NET PRESENT VALUE.......................................................3

LIST OF TABLES

Table 12-C.2.1 Refrigerator Tax Credit Eligibility Requirements..................................................2

Table 12-C5.1 Industry Net Present Value for Standard Size Refrigerator-Freezers 

Including Federal Production Tax Credits (Flat Markup Scenario) ........................4

Table 12-C5.2 Industry Net Present Value for Standard Size Refrigerator-Freezers 

Excluding Federal Production Tax Credits (Flat Markup Scenario) .......................4

Table 12-C5.3 Industry Net Present Value for Standard Size Refrigerator-Freezers 

Including Federal Production Tax Credits (Preservation of Operating 

Profit Markup Scenario) ..........................................................................................4

Table 12-C5.4 Industry Net Present Value for Standard Size Refrigerator-Freezers 

Excluding Federal Production Tax Credits (Preservation of Operating 

Profit Markup Scenario) ..........................................................................................5

Table 12-C5.5 Industry Net Present Value for Built-In Refrigeration Products Including 

Federal Production Tax Credits (Flat Markup Scenario).........................................5

Table 12-C5.6 Industry Net Present Value for Built-In Refrigeration Products Excluding 

Federal Production Tax Credits (Flat Markup Scenario).........................................5

Table 12-C5.7 Industry Net Present Value for Built-In Refrigeration Products Including 

Federal Production Tax Credits (Preservation of Operating Profit Markup 

Scenario) ..................................................................................................................5

Table 12-C5.8 Industry Net Present Value for Built-In Refrigeration Products Excluding 

Federal Production Tax Credits (Preservation of Operating Profit Markup 

Scenario) ..................................................................................................................6
12-C-1

APPENDIX 12-C. FEDERAL PRODUCTION TAX CREDIT

12-C.1INTRODUCTION

The purpose of this appendix is to clarify how the Department of Energy (DOE) made its 

estimates of the Federal production tax credits (“tax credits”) that would benefit residential 

refrigeration manufacturers. These tax credits have been made available to residential 

refrigeration manufacturers by the enactment of the Energy Improvement and Extension Act of 

2008 (EIEA 2008), Pub. L. No. 110-343, Div. B, Sec. 305 (Oct. 3, 2008). EIEATo make its 

estimates, DOE relied primarily on market research and information provided by manufacturers. 

12-C.2ELIGIBILITY REQUIREMENTS

Multiple tax credit programs have been enacted in order to stimulate the adoption of 

higher efficiency products and equipment. The first to impact the residential refrigeration

industry was the Energy Policy Act of 2005 (EPACT 2005), followed by EIEA 2008. Both 

programs share some eligibility requirements:

• EPACT 2005 included a $75 million cap on the total tax credit that any one manufacturer 

can receive across all eligible products and equipment it manufactures during the 

effective dates of the program. For refrigerators that consume at least 15 percent but not 

more than 20 percent less kilowatt hours per year than the 2001 energy conservation 

standards, the aggregate amount of the credit cannot exceed $20 million. EIEA 2008 also 

has a $75 million limit per taxpayer for all taxable years beginning after December 31, 

2007. However, refrigerators qualifying for the highest tier are not counted towards the 

cap. 

• Appliances or equipment that meet the efficiency requirements must be manufactured in 

the United States. The tax credit only applies to the original equipment manufacturer; i.e.

tax-credits for private-labeled goods sourced from other domestic manufacturers accrue 

to the source, not the reseller.

• Tax credits accrue on the basis of how many additional eligible appliances the 

manufacturer has sold than in years past. The calculation is based on a rolling average of 

qualifying shipments, the length of which varies by the tax credit program.

• Products or equipment must meet certain efficiency metrics that vary by program. For 

refrigerators, targets were set based on a percentage reduction of energy usage of the 

2001 energy conservation standards.

• Only residential model automatic defrost refrigerator-freezers with an internal volume of 

at least 16.5 cubic feet meet the definition of “refrigerator” for the purpose of these tax 

credits.
12-C-2

Some differences between the tax credits in EPACT 2005 and EIEA 2008 are shown in 

Table 12-C.2.1. Principal differences include the effective dates, the length of the rolling average 

period over which marginal qualifying units are calculated, the minimum efficiency 

requirements, and the per-unit tax credits that accrue to the original equipment manufacturer. 

Table 12-C.2.1 Refrigerator Tax Credit Eligibility Requirements

Tax Credit 

Program

Effective Date Rolling Average 

Basis

Efficiency 

Requirements

Tax Credit per 

Unit

Start End

EPACT 2005 2006 2006 3 years 15% $75 

2006 2007 3 years 20% $125 

2006 2007 3 years 25% $175 

EIEA 2008 2008 2008 2 years 20% $50 

2008 2009 2 years 23% $75 

2008 2010 2 years 25% $100 

2008 2010 2 years 30% $200 

12-C.3ELIGIBLE REFRIGERATION PRODUCTS

For the residential refrigeration products rulemaking, DOE sums the discounted annual 

cash flows from the base year through the end of the 30 year analysis period (2010 to 2043). 

Because 2010 is the base year to which industry cash flows are discounted, any Federal 

production tax credits prior to 2010 are not considered in the industry net present value (INPV)

analysis that analyzes the impact of amended energy conservation standards on manufacturers. 

However, any tax benefit in 2010 falls within the timeframe that impacts INPV and hence 

increases industry value (potentially decreasing the impacts on manufacturers due to energy 

conservation standards). Therefore, DOE is only concerned with the tax benefit of EPACT 2005 

and EIEA 2008 in 2010. In 2010, units that qualify for tax credits are those that meet efficiency 

levels of 25 percent and 30 percent, as shown in Table 12-C.2.1.

DOE used a Consortium for Energy Efficiency (CEE) databasea

 

a http://www.cee1.org/resid/seha/refrig/refrig-main.php3

to identify refrigerator 

models that are at least 25 percent and 30 percent more efficient than baseline efficiency levels, 

since these are the levels at which tax credits can be earned in 2010. CEE promotes energyefficient refrigerators by identifying models that exist at certain tiers: Tier 1 designates models 

that are at least 20 percent more efficient than the federal minimum standard, Tier 2 designates 

models that are at least 25 percent more efficient, and Tier 3 designates models that are at least 

30 percent more efficient. Therefore, DOE used the CEE database to identify models that meet 

CEE Tier 2 (25 percent efficiency improvement over baseline) and Tier 3 (30 percent efficiency 

improvement over baseline. DOE identified one qualifying model at the 25 percent efficiency 

level. Qualifying models must be manufactured in the U.S. and must have internal volume of at 

least 16.5 cubic feet. The CEE database also provided product specifications which DOE used to 

establish which models met the volume criteria. DOE used information it obtained during 
12-C-3

manufacturer interviews to determine which models were manufactured domestically. Several 

models that meet these criteria exist on the market at the 25 percent efficiency level, but DOE 

assumed that all major U.S. manufacturers met their total tax benefit cap of $75 million prior to 

2010. DOE identified only one manufacturer who had not met this cap and produced a qualifying 

model.

Using the same CEE database discussed above and information from manufacturer 

interviews, DOE also identified 63 qualifying models at the 30 percent efficiency level. Even 

though each of these models is made by a major U.S. manufacturer, these models all qualify for 

the tax credit under EIEA 2008 because the $75 million benefit cap does not apply to the highest 

efficiency tier.

12-C.4ESTIMATED FEDERAL TAX CREDIT BENEFITS

DOE used several information sources to calculate the benefits received by residential 

refrigeration manufacturers from the tax credit programs in 2010. DOE first estimated the 

qualifying manufacturers’ market shares for each product class for which they had qualifying 

models by using publicly available information and information obtained from manufacturer 

interviews. DOE then totaled the shipments estimated for each product class in 2010 in the NIA. 

Each manufacturer’s 2010 shipments for a product class were calculated by multiplying its 

market share in that product class by total 2010 shipments. 

DOE then estimated the percentage of qualifying shipments for each manufacturer by 

dividing the total number of qualifying models according to the CEE database of higher 

efficiency products by the total number of models offered by the manufacturer in that product 

class according to a Federal Trade Commission (FTC) product databaseb

12-C.5IMPACTS ON INDUSTRY NET PRESENT VALUE

. DOE used the FTC 

product database to determine the total number of models for each product class for 

manufacturers that also produced qualifying products in 2010. DOE then calculated the total 

number of qualifying shipments for each manufacturer and product class by multiplying the 

manufacturer’s total 2010 shipments by the percentage of qualifying shipments. Since each unit 

at the 25 percent efficiency level receives a $100 tax credit and each unit at the 30 percent

efficiency level receives a $200 tax credit, DOE multiplied these values where appropriate by the 

total number of qualifying shipments to determine the total benefit of the tax credits for the 

industry. DOE’s estimates suggest that manufacturers will collect approximately $36.6 million in 

Federal production tax credits in 2010 from the provisions of EIEA 2008.

To determine the impacts of the tax credit on the INPV, DOE implemented the tax credit 

in the Government Regulatory Impact Model (GRIM). The calculated tax credit was added as a 

cash flow item in the base case and standards case. The impact of the Federal production tax 

credit is included in the main MIA results shown in Chapter 12 of the TSD. Of the $36.6 million 

 

b http://www.ftc.gov/bcp/conline/edcams/eande/appliances/fridge.htm
12-C-4

total tax benefit anticipated to be collected by the residential refrigeration industry, $36.566 

million is expected to be earned by standard size refrigerator-freezer manufacturers from the 63 

identified qualifying 30 percent models, and $0.042 million is expected to be earned by built-in 

refrigeration product manufacturers from the one identified qualifying 25 percent model. The tax 

credit does not apply to the remaining two subgroups of manufacturers, standard size freezer 

manufacturers and compact refrigeration product manufacturers. Table 12-C5.1 through Table 

12-C5.8 provide the INPV estimates for the two manufacturer subgroups impacted by tax credits 

under the two markup scenarios analyzed with and without the incorporation of tax credits.

Table 12-C5.1 Industry Net Present Value for Standard Size Refrigerator-Freezers

Including Federal Production Tax Credits (Flat Markup Scenario)

Flat Markup Scenario

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009 $ 

millions) 3,173 3,088 2,997 2,886 2,530 2,344 

Change in INPV

(2009 $ 

millions) - (84.8) (175.9) (287.5) (643.0) (828.9)

(%) - -2.7% -5.5% -9.1% -20.3% -26.1%

Table 12-C5.2 Industry Net Present Value for Standard Size Refrigerator-Freezers

Excluding Federal Production Tax Credits (Flat Markup Scenario)

Flat Markup Scenario

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009 $ 

millions) 3,136 3,052 2,961 2,849 2,493 2,308 

Change in INPV

(2009 $ 

millions) - (84.8) (175.9) (287.5) (643.0) (828.9)

(%) - -2.7% -5.6% -9.2% -20.5% -26.4%

Table 12-C5.3 Industry Net Present Value for Standard Size Refrigerator-Freezers

Including Federal Production Tax Credits (Preservation of Operating Profit Markup 

Scenario)

Preservation of Operating Profit Markup Scenario

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009 $ 

millions) 3,173 2,871 2,713 2,511 1,676 1,018 

Change in INPV

(2009 $ 

millions) - (301.7) (459.8) (662.1) (1,496.8) (2,154.7)

(%) - -9.5% -14.5% -20.9% -47.2% -67.9%
12-C-5

Table 12-C5.4 Industry Net Present Value for Standard Size Refrigerator-Freezers 

Excluding Federal Production Tax Credits (Preservation of Operating Profit Markup 

Scenario)

Preservation of Operating Profit Markup Scenario

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009 $ 

millions) 3,136 2,835 2,677 2,474 1,640 982 

Change in 

INPV

(2009 $ 

millions) - (301.7) (459.8) (662.1) (1,496.8) (2,154.7)

(%) - -9.6% -14.7% -21.1% -47.7% -68.7%

Table 12-C5.5 Industry Net Present Value for Built-In Refrigeration Products Including 

Federal Production Tax Credits (Flat Markup Scenario)

Flat Markup Scenario

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009 $ 

millions) 658 607 604 593 579 574 

Change in 

INPV

(2009 $ 

millions) - (51.7) (54.7) (65.8) (79.7) (84.9)

(%) - -7.9% -8.3% -10.0% -12.1% -12.9%

Table 12-C5.6 Industry Net Present Value for Built-In Refrigeration Products Excluding 

Federal Production Tax Credits (Flat Markup Scenario)

Flat Markup Scenario

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009 $ 

millions) 658 607 604 593 579 573 

Change in 

INPV

(2009 $ 

millions) - (51.7) (54.7) (65.8) (79.7) (84.9)

(%) - -7.9% -8.3% -10.0% -12.1% -12.9%

Table 12-C5.7 Industry Net Present Value for Built-In Refrigeration Products Including 

Federal Production Tax Credits (Preservation of Operating Profit Markup Scenario)

Preservation of Operating Profit Markup Scenario

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009 $ 

millions) 658 606 601 578 555 538 

Change in 

INPV

(2009 $ 

millions) - (52.9) (57.0) (80.5) (103.0) (120.3)

(%) - -8.0% -8.7% -12.2% -15.6% -18.3%
12-C-6

Table 12-C5.8 Industry Net Present Value for Built-In Refrigeration Products Excluding 

Federal Production Tax Credits (Preservation of Operating Profit Markup Scenario)

Preservation of Operating Profit Markup Scenario

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2009 $ 

millions) 658 605 601 578 555 538 

Change in 

INPV

(2009 $ 

millions) - (52.9) (57.0) (80.5) (103.0) (120.3)

(%) - -8.0% -8.7% -12.2% -15.6% -18.3%

The results from the GRIM show that the estimated Federal production tax credit has a 

minimal impact on residential refrigeration INPV impacts in the standards case. Depending on 

the markup scenario and product classes analyzed, the tax credit lowers the impacts of energy 

conservation standards by up to 0.8 percent. This small decrease is not enough to substantially 

mitigate the impacts on the residential refrigeration industry due to energy conservation 

standards.
15-A-i

APPENDIX 15-A. SOCIAL COST OF CARBON FOR REGULATORY IMPACT 

ANALYSIS UNDER EXECUTIVE ORDER 12866

TABLE OF CONTENTS

15-A.1 EXECUTIVE SUMMARY .................................................................................15-A-1

15-A.2 MONETIZING CARBON DIOXIDE EMISSIONS...........................................15-A-2

15-A.3 SOCIAL COST OF CARBON VALUES USED IN PAST REGULATORY 

ANALYSES.........................................................................................................15-A-4

15-A.4 APPROACH AND KEY ASSUMPTIONS ........................................................15-A-5

15-A.4.1 Integrated Assessment Models ............................................................................15-A-6

15-A.4.2 Global versus Domestic Measures of SCC........................................................15-A-12

15-A.4.3 Valuing Non-CO2 Emissions.............................................................................15-A-14

15-A.4.4 Equilibrium Climate Sensitivity ........................................................................15-A-14

15-A.4.5 Socio-Economic and Emissions Trajectories.....................................................15-A-17

15-A.4.6 Discount Rate.....................................................................................................15-A-20

15-A.5 REVISED SCC ESTIMATES ...........................................................................15-A-27

15-A.6 LIMITATIONS OF THE ANALYSIS ..............................................................15-A-33

15-A.7 A FURTHER DISCUSSION OF CATASTROPHIC IMPACTS AND 

DAMAGE FUNCTIONS ..................................................................................15-A-35

15-A.8 CONCLUSION..................................................................................................15-A-38

15-A.9 ANNEX..............................................................................................................15-A-44

15-A.9.1 Other (non-CO2) gases......................................................................................15-A-45

15-A.9.2 Extrapolating Emissions Projections to 2300 ....................................................15-A-47

LIST OF TABLES

Table 15-A.1.1 Social Cost of CO2, 2010 – 2050 (in 2007 dollars) .................................15-A-2

Table 15-A.4.1 Summary Statistics for Four Calibrated Climate Sensitivity 

Distributions...........................................................................................15-A-15

Table 15-A.4.2 Socioeconomic and Emissions Projections from Select EMF-22 

Reference Scenarios...............................................................................15-A-19

Table 15-A.5.1 Disaggregated Social Cost of CO2 Values by Model, Socio-Economic 

Trajectory, and Discount Rate for 2010 (in 2007 dollars).....................15-A-30

Table 15-A.5.2 Social Cost of CO2, 2010 – 2050 (in 2007 dollars) ...............................15-A-32

Table 15-A.5.3 Changes in the Average Annual Growth Rates of SCC Estimates 

between 2010 and 2050 .........................................................................15-A-32

Table 15-A.7.1 Probabilities of Various Tipping Points from Expert Elicitation...........15-A-36

Table 15-A.9.1 Annual SCC Values: 2010–2050 (in 2007 dollars) ...............................15-A-44

Table 15-A.9.2 2010 Global SCC Estimates at 2.5 Percent Discount Rate (2007$/ton 

CO2) .......................................................................................................15-A-54

Table 15-A.9.3 Table A3. 2010 Global SCC Estimates at 3 Percent Discount Rate 

(2007$/ton CO2).....................................................................................15-A-55

Table 15-A.9.4 2010 Global SCC Estimates at 5 Percent Discount Rate (2007$/ton 

CO2) .......................................................................................................15-A-56
15-A-ii

Table 15-A.9.5 Additional Summary Statistics of 2010 Global SCC Estimates............15-A-57

LIST OF FIGURES

Figure 15-A.4.1 Annual Consumption Loss as a Fraction of Global GDP in 2100 Due 

to an Increase in Annual Global Temperature in the DICE, FUND, and 

PAGE models.........................................................................................15-A-11

Figure 15-A.4.2 Annual Consumption Loss for Lower Temperature Changes in DICE, 

FUND, and PAGE .................................................................................15-A-12

Figure 15-A.4.3 Estimates of the Probability Density Function for Equilibrium Climate 

Sensitivity (°C) ......................................................................................15-A-17

Figure 15-A.5.1 Level of Global GDP across EMF Scenarios ........................................15-A-31

Figure 15-A.9.1 Sulphur Dioxide Emission Scenarios.....................................................15-A-47

Figure 15-A.9.2 Global Population, 2000-2300 (Post-2100 extrapolations assume the 

population growth rate changes linearly to reach a zero growth rate by 

2200.) .....................................................................................................15-A-49

Figure 15-A.9.3 World GDP, 2000-2300 (Post-2100 extrapolations assume GDP per 

capita growth declines linearly, reaching zero in the year 2300) ..........15-A-50

Figure 15-A.9.4 Global Fossil and Industrial CO2 Emissions, 2000-2300 (Post-2100 

extrapolations assume growth rate of CO2 intensity (CO2/GDP) over 

2090-2100 is maintained through 2300.)...............................................15-A-50

Figure 15-A.9.5 Global Net Land Use CO2 Emissions, 2000-2300 (Post-2100 

extrapolations assume emissions decline linearly, reaching zero in the 

year 2200) ..............................................................................................15-A-51

Figure 15-A.9.6 Global Non-CO2 Radiative Forcing, 2000-2300 (Post-2100 

extrapolations assume constant non-CO2 radiative forcing after 2100) 15-A-52

Figure 15-A.9.7 Global CO2 Intensity (fossil & industrial CO2 emissions/GDP), 2000-

2300 (Post-2100 extrapolations assume decline in CO2/GDP growth 

rate over 2090-2100 is maintained through 2300).................................15-A-53

Figure 15-A.9.8 Histogram of Global SCC Estimates in 2010 (2007$/ton CO2), by 

discount rate ...........................................................................................15-A-56
15-A-1

APPENDIX 15-A. SOCIAL COST OF CARBON FOR REGULATORY IMPACT 

ANALYSIS UNDER EXECUTIVE ORDER 12866

Interagency Working Group on Social Cost of Carbon, United States Government

With participation by

Council of Economic Advisers 

Council on Environmental Quality 

Department of Agriculture

Department of Commerce

Department of Energy

Department of Transportation

Environmental Protection Agency

National Economic Council

Office of Energy and Climate Change

Office of Management and Budget

Office of Science and Technology Policy 

Department of the Treasury

15-A.1 EXECUTIVE SUMMARY

Under Executive Order 12866, agencies are required, to the extent permitted by law, “to 

assess both the costs and the benefits of the intended regulation and, recognizing that some costs 

and benefits are difficult to quantify, propose or adopt a regulation only upon a reasoned 

determination that the benefits of the intended regulation justify its costs.” The purpose of the 

“social cost of carbon” (SCC) estimates presented here is to allow agencies to incorporate the 

social benefits of reducing carbon dioxide (CO2) emissions into cost-benefit analyses of 

regulatory actions that have small, or “marginal,” impacts on cumulative global emissions. The 

estimates are presented with an acknowledgement of the many uncertainties involved and with a 

clear understanding that they should be updated over time to reflect increasing knowledge of the 

science and economics of climate impacts.

The SCC is an estimate of the monetized damages associated with an incremental 

increase in carbon emissions in a given year. It is intended to include (but is not limited to) 

changes in net agricultural productivity, human health, property damages from increased flood 

risk, and the value of ecosystem services due to climate change. 

This document presents a summary of the interagency process that developed these SCC 

estimates. Technical experts from numerous agencies met on a regular basis to consider public 

comments, explore the technical literature in relevant fields, and discuss key model inputs and 

assumptions. The main objective of this process was to develop a range of SCC values using a 

defensible set of input assumptions grounded in the existing scientific and economic literatures. 
15-A-2

In this way, key uncertainties and model differences transparently and consistently inform the 

range of SCC estimates used in the rulemaking process. 

The interagency group selected four SCC values for use in regulatory analyses. Three 

values are based on the average SCC from three integrated assessment models, at discount rates 

of 2.5, 3, and 5 percent. The fourth value, which represents the 95th percentile SCC estimate 

across all three models at a 3 percent discount rate, is included to represent higher-than-expected 

impacts from temperature change further out in the tails of the SCC distribution.

Table 15-A.1.1 Social Cost of CO2, 2010 – 2050 (in 2007 dollars)

Discount Rate

5% 3% 2.5% 3%

Year Avg Avg Avg 95th

2010 4.7 21.4 35.1 64.9

2015 5.7 23.8 38.4 72.8

2020 6.8 26.3 41.7 80.7

2025 8.2 29.6 45.9 90.4

2030 9.7 32.8 50.0 100.0

2035 11.2 36.0 54.2 109.7

2040 12.7 39.2 58.4 119.3

2045 14.2 42.1 61.7 127.8

2050 15.7 44.9 65.0 136.2

15-A.2 MONETIZING CARBON DIOXIDE EMISSIONS

The “social cost of carbon” (SCC) is an estimate of the monetized damages associated 

with an incremental increase in carbon emissions in a given year. It is intended to include (but is 

not limited to) changes in net agricultural productivity, human health, property damages from 

increased flood risk, and the value of ecosystem services. We report estimates of the social cost 

of carbon in dollars per metric ton of carbon dioxide throughout this document.1

 

When attempting to assess the incremental economic impacts of carbon dioxide 

emissions, the analyst faces a number of serious challenges. A recent report from the National 

Academies of Science (NRC 2009) points out that any assessment will suffer from uncertainty, 

speculation, and lack of information about (1) future emissions of greenhouse gases, (2) the 

effects of past and future emissions on the climate system, (3) the impact of changes in climate 

 

1 In this document, we present all values of the SCC as the cost per metric ton of CO2 emissions. Alternatively, one 

could report the SCC as the cost per metric ton of carbon emissions. The multiplier for translating between mass of 

CO2 and the mass of carbon is 3.67 (the molecular weight of CO2 divided by the molecular weight of carbon = 44/12 

= 3.67). 
15-A-3

on the physical and biological environment, and (4) the translation of these environmental 

impacts into economic damages. As a result, any effort to quantify and monetize the harms 

associated with climate change will raise serious questions of science, economics, and ethics and 

should be viewed as provisional. 

Despite the serious limits of both quantification and monetization, SCC estimates can be 

useful in estimating the social benefits of reducing carbon dioxide emissions. Under Executive 

Order 12866, agencies are required, to the extent permitted by law, “to assess both the costs and 

the benefits of the intended regulation and, recognizing that some costs and benefits are difficult 

to quantify, propose or adopt a regulation only upon a reasoned determination that the benefits of 

the intended regulation justify its costs.” The purpose of the SCC estimates presented here is to 

make it possible for agencies to incorporate the social benefits from reducing carbon dioxide 

emissions into cost-benefit analyses of regulatory actions that have small, or “marginal,” impacts 

on cumulative global emissions. Most federal regulatory actions can be expected to have 

marginal impacts on global emissions. 

For such policies, the benefits from reduced (or costs from increased) emissions in any 

future year can be estimated by multiplying the change in emissions in that year by the SCC 

value appropriate for that year. The net present value of the benefits can then be calculated by 

multiplying each of these future benefits by an appropriate discount factor and summing across 

all affected years. This approach assumes that the marginal damages from increased emissions 

are constant for small departures from the baseline emissions path, an approximation that is 

reasonable for policies that have effects on emissions that are small relative to cumulative global 

carbon dioxide emissions. For policies that have a large (non-marginal) impact on global 

cumulative emissions, there is a separate question of whether the SCC is an appropriate tool for 

calculating the benefits of reduced emissions; we do not attempt to answer that question here.

An interagency group convened on a regular basis to consider public comments, explore 

the technical literature in relevant fields, and discuss key inputs and assumptions in order to 

generate SCC estimates. Agencies that actively participated in the interagency process include 

the Environmental Protection Agency, and the Departments of Agriculture, Commerce, Energy, 

Transportation, and Treasury. This process was convened by the Council of Economic Advisers 

and the Office of Management and Budget, with active participation and regular input from the 

Council on Environmental Quality, National Economic Council, Office of Energy and Climate 

Change, and Office of Science and Technology Policy. The main objective of this process was 

to develop a range of SCC values using a defensible set of input assumptions that are grounded 

in the existing literature. In this way, key uncertainties and model differences can more 

transparently and consistently inform the range of SCC estimates used in the rulemaking process. 

The interagency group selected four SCC estimates for use in regulatory analyses. For 

2010, these estimates are $5, $21, $35, and $65 (in 2007 dollars). The first three estimates are 

based on the average SCC across models and socio-economic and emissions scenarios at the 5, 3, 

and 2.5 percent discount rates, respectively. The fourth value is included to represent the higherthan-expected impacts from temperature change further out in the tails of the SCC distribution. 

For this purpose, we use the SCC value for the 95th percentile at a 3 percent discount rate. The 

central value is the average SCC across models at the 3 percent discount rate. For purposes of 

capturing the uncertainties involved in regulatory impact analysis, we emphasize the importance 
15-A-4

and value of considering the full range. These SCC estimates also grow over time. For instance, 

the central value increases to $24 per ton of CO2 in 2015 and $26 per ton of CO2 in 2020. See 

Appendix A for the full range of annual SCC estimates from 2010 to 2050.

It is important to emphasize that the interagency process is committed to updating these 

estimates as the science and economic understanding of climate change and its impacts on 

society improves over time. Specifically, we have set a preliminary goal of revisiting the SCC 

values within two years or at such time as substantially updated models become available, and to 

continue to support research in this area. In the meantime, we will continue to explore the issues 

raised in this document and consider public comments as part of the ongoing interagency 

process.

15-A.3 SOCIAL COST OF CARBON VALUES USED IN PAST REGULATORY 

ANALYSES

To date, economic analyses for Federal regulations have used a wide range of values to 

estimate the benefits associated with reducing carbon dioxide emissions. In the final model year 

2011 CAFE rule, the Department of Transportation (DOT) used both a “domestic” SCC value of 

$2 per ton of CO2 and a “global” SCC value of $33 per ton of CO2 for 2007 emission reductions 

(in 2007 dollars), increasing both values at 2.4 percent per year. It also included a sensitivity 

analysis at $80 per ton of CO2. A domestic SCC value is meant to reflect the value of damages 

in the United States resulting from a unit change in carbon dioxide emissions, while a global 

SCC value is meant to reflect the value of damages worldwide. 

A 2008 regulation proposed by DOT assumed a domestic SCC value of $7 per ton CO2

(in 2006 dollars) for 2011 emission reductions (with a range of $0-$14 for sensitivity analysis), 

also increasing at 2.4 percent per year. A regulation finalized by DOE in October of 2008 used a 

domestic SCC range of $0 to $20 per ton CO2 for 2007 emission reductions (in 2007 dollars). In 

addition, EPA’s 2008 Advance Notice of Proposed Rulemaking for Greenhouse Gases identified 

what it described as “very preliminary” SCC estimates subject to revision. EPA’s global mean 

values were $68 and $40 per ton CO2 for discount rates of approximately 2 percent and 3 

percent, respectively (in 2006 dollars for 2007 emissions).

In 2009, an interagency process was initiated to offer a preliminary assessment of how 

best to quantify the benefits from reducing carbon dioxide emissions. To ensure consistency in 

how benefits are evaluated across agencies, the Administration sought to develop a transparent 

and defensible method, specifically designed for the rulemaking process, to quantify avoided 

climate change damages from reduced CO2 emissions. The interagency group did not undertake 

any original analysis. Instead, it combined SCC estimates from the existing literature to use as 

interim values until a more comprehensive analysis could be conducted. 

The outcome of the preliminary assessment by the interagency group was a set of five 

interim values: global SCC estimates for 2007 (in 2006 dollars) of $55, $33, $19, $10, and $5 per 

ton of CO2. The $33 and $5 values represented model-weighted means of the published 

estimates produced from the most recently available versions of three integrated assessment 

models—DICE, PAGE, and FUND—at approximately 3 and 5 percent discount rates. The $55 
15-A-5

and $10 values were derived by adjusting the published estimates for uncertainty in the discount 

rate (using factors developed by Newell and Pizer (2003)) at 3 and 5 percent discount rates, 

respectively. The $19 value was chosen as a central value between the $5 and $33 per ton 

estimates. All of these values were assumed to increase at 3 percent annually to represent 

growth in incremental damages over time as the magnitude of climate change increases.

These interim values represent the first sustained interagency effort within the U.S. 

government to develop an SCC for use in regulatory analysis. The results of this preliminary 

effort were presented in several proposed and final rules and were offered for public comment in 

connection with proposed rules, including the joint EPA-DOT fuel economy and CO2 tailpipe 

emission proposed rules.

15-A.4 APPROACH AND KEY ASSUMPTIONS

Since the release of the interim values, interagency group has reconvened on a regular 

basis to generate improved SCC estimates. Specifically, the group has considered public 

comments and further explored the technical literature in relevant fields. This section details the 

several choices and assumptions that underlie the resulting estimates of the SCC. 

It is important to recognize that a number of key uncertainties remain, and that current 

SCC estimates should be treated as provisional and revisable since they will evolve with 

improved scientific and economic understanding. The interagency group also recognizes that the 

existing models are imperfect and incomplete. The National Academy of Science (2009) points 

out that there is tension between the goal of producing quantified estimates of the economic 

damages from an incremental ton of carbon and the limits of existing efforts to model these 

effects. Throughout this document, we highlight a number of concerns and problems that should 

be addressed by the research community, including research programs housed in many of the 

agencies participating in the interagency process to estimate the SCC. 

The U.S. Government will periodically review and reconsider estimates of the SCC used 

for cost-benefit analyses to reflect increasing knowledge of the science and economics of climate 

impacts, as well as improvements in modeling. In this context, statements recognizing the 

limitations of the analysis and calling for further research take on exceptional significance. The 

interagency group offers the new SCC values with all due humility about the uncertainties 

embedded in them and with a sincere promise to continue work to improve them.
15-A-6

15-A.4.1 Integrated Assessment Models 

We rely on three integrated assessment models (IAMs) commonly used to estimate the 

SCC: the FUND, DICE, and PAGE models.2

 

 These models are frequently cited in the peerreviewed literature and used in the IPCC assessment. Each model is given equal weight in the 

SCC values developed through this process, bearing in mind their different limitations (discussed 

below).

These models are useful because they combine climate processes, economic growth, and 

feedbacks between the climate and the global economy into a single modeling framework. At 

the same time, they gain this advantage at the expense of a more detailed representation of the 

underlying climatic and economic systems. DICE, PAGE, and FUND all take stylized, reducedform approaches (see NRC 2009 for a more detailed discussion; see Nordhaus 2008 on the 

possible advantages of this approach). Other IAMs may better reflect the complexity of the 

science in their modeling frameworks but do not link physical impacts to economic damages. 

There is currently a limited amount of research linking climate impacts to economic damages, 

which makes this exercise even more difficult. Underlying the three IAMs selected for this 

exercise are a number of simplifying assumptions and judgments reflecting the various modelers’ 

best attempts to synthesize the available scientific and economic research characterizing these 

relationships.

The three IAMs translate emissions into changes in atmospheric greenhouse 

concentrations, atmospheric concentrations into changes in temperature, and changes in 

temperature into economic damages. The emissions projections used in the models are based on 

specified socio-economic (GDP and population) pathways. These emissions are translated into 

concentrations using the carbon cycle built into each model, and concentrations are translated 

into warming based on each model’s simplified representation of the climate and a key 

parameter, climate sensitivity. Each model uses a different approach to translate warming into 

damages. Finally, transforming the stream of economic damages over time into a single value 

requires judgments about how to discount them.

Each model takes a slightly different approach to model how changes in emissions result 

in changes in economic damages. In PAGE, for example, the consumption-equivalent damages 

in each period are calculated as a fraction of GDP, depending on the temperature in that period 

relative to the pre-industrial average temperature in each region. In FUND, damages in each 

period also depend on the rate of temperature change from the prior period. In DICE, 

temperature affects both consumption and investment. We describe each model in greater detail 

here. In a later section, we discuss key gaps in how the models account for various scientific and 

 2 The DICE (Dynamic Integrated Climate and Economy) model by William Nordhaus evolved from a series of 

energy models and was first presented in 1990 (Nordhaus and Boyer 2000, Nordhaus 2008). The PAGE (Policy 

Analysis of the Greenhouse Effect) model was developed by Chris Hope in 1991 for use by European decisionmakers in assessing the marginal impact of carbon emissions (Hope 2006, Hope 2008). The FUND (Climate 

Framework for Uncertainty, Negotiation, and Distribution) model, developed by Richard Tol in the early 1990s, 

originally to study international capital transfers in climate policy. is now widely used to study climate impacts (e.g., 

Tol 2002a, Tol 2002b, Anthoff et al. 2009, Tol 2009).
15-A-7

economic processes (e.g. the probability of catastrophe, and the ability to adapt to climate change 

and the physical changes it causes).

The parameters and assumptions embedded in the three models vary widely. A key 

objective of the interagency process was to enable a consistent exploration of the three models 

while respecting the different approaches to quantifying damages taken by the key modelers in 

the field. An extensive review of the literature was conducted to select three sets of input 

parameters for these models: climate sensitivity, socio-economic and emissions trajectories, and 

discount rates. A probability distribution for climate sensitivity was specified as an input into all 

three models. In addition, the interagency group used a range of scenarios for the socioeconomic parameters and a range of values for the discount rate. All other model features were 

left unchanged, relying on the model developers’ best estimates and judgments. In DICE, these 

parameters are handled deterministically and represented by fixed constants; in PAGE, most 

parameters are represented by probability distributions. FUND was also run in a mode in which 

parameters were treated probabilistically.

The sensitivity of the results to other aspects of the models (e.g. the carbon cycle or 

damage function) is also important to explore in the context of future revisions to the SCC but 

has not been incorporated into these estimates. Areas for future research are highlighted at the 

end of this document.

The DICE Model

The DICE model is an optimal growth model based on a global production function with 

an extra stock variable (atmospheric carbon dioxide concentrations). Emission reductions are 

treated as analogous to investment in “natural capital.” By investing in natural capital today 

through reductions in emissions—implying reduced consumption—harmful effects of climate 

change can be avoided and future consumption thereby increased. 

For purposes of estimating the SCC, carbon dioxide emissions are a function of global 

GDP and the carbon intensity of economic output, with the latter declining over time due to 

technological progress. The DICE damage function links global average temperature to the 

overall impact on the world economy. It varies quadratically with temperature change to capture 

the more rapid increase in damages expected to occur under more extreme climate change, and is 

calibrated to include the effects of warming on the production of market and nonmarket goods 

and services. It incorporates impacts on agriculture, coastal areas (due to sea level rise), “other 

vulnerable market sectors” (based primarily on changes in energy use), human health (based on 

climate-related diseases, such as malaria and dengue fever, and pollution), non-market amenities 

(based on outdoor recreation), and human settlements and ecosystems. The DICE damage 

function also includes the expected value of damages associated with low probability, high 

impact “catastrophic” climate change. This last component is calibrated based on a survey of 

experts (Nordhaus 1994). The expected value of these impacts is then added to the other market 

and non-market impacts mentioned above.

No structural components of the DICE model represent adaptation explicitly, though it is 

included implicitly through the choice of studies used to calibrate the aggregate damage function. 
15-A-8

For example, its agricultural impact estimates assume that farmers can adjust land use decisions 

in response to changing climate conditions, and its health impact estimates assume 

improvements in healthcare over time. In addition, the small impacts on forestry, water systems, 

construction, fisheries, and outdoor recreation imply optimistic and costless adaptation in these 

sectors (Nordhaus and Boyer, 2000; Warren et al., 2006). Costs of resettlement due to sea level 

rise are incorporated into damage estimates, but their magnitude is not clearly reported. 

Mastrandrea’s (2009) review concludes that “in general, DICE assumes very effective 

adaptation, and largely ignores adaptation costs."

Note that the damage function in DICE has a somewhat different meaning from the 

damage functions in FUND and PAGE. Because GDP is endogenous in DICE and because 

damages in a given year reduce investment in that year, damages propagate forward in time and 

reduce GDP in future years. In contrast, GDP is exogenous in FUND and PAGE, so damages in 

any given year do not propagate forward.3

The PAGE Model

PAGE2002 (version 1.4epm) treats GDP growth as exogenous. It divides impacts into 

economic, non-economic, and catastrophic categories and calculates these impacts separately for 

eight geographic regions. Damages in each region are expressed as a fraction of output, where 

the fraction lost depends on the temperature change in each region. Damages are expressed as 

power functions of temperature change. The exponents of the damage function are the same in 

all regions but are treated as uncertain, with values ranging from 1 to 3 (instead of being fixed at 

2 as in DICE).

PAGE2002 includes the consequences of catastrophic events in a separate damage subfunction. Unlike DICE, PAGE2002 models these events probabilistically. The probability of a 

“discontinuity” (i.e., a catastrophic event) is assumed to increase with temperature above a 

specified threshold. The threshold temperature, the rate at which the probability of experiencing 

a discontinuity increases above the threshold, and the magnitude of the resulting catastrophe are 

all modeled probabilistically.

Adaptation is explicitly included in PAGE. Impacts are assumed to occur for temperature 

increases above some tolerable level (2°C for developed countries and 0°C for developing 

countries for economic impacts, and 0°C for all regions for non-economic impacts), but 

adaptation is assumed to reduce these impacts. Default values in PAGE2002 assume that the 

developed countries can ultimately eliminate up to 90 percent of all economic impacts beyond 

the tolerable 2°C increase and that developing countries can eventually eliminate 50 percent of 

their economic impacts. All regions are assumed to be able to mitigate 25 percent of the noneconomic impacts through adaptation (Hope 2006). 

 3 Using the default assumptions in DICE 2007, this effect generates an approximately 25 percent increase in the 

SCC relative to damages calculated by fixing GDP. In DICE2007, the time path of GDP is endogenous.

Specifically, the path of GDP depends on the rate of saving and level of abatement in each period chosen by the 

optimizing representative agent in the model. We made two modifications to DICE to make it consistent with EMF 

GDP trajectories (see next section): we assumed a fixed rate of savings of 20%, and we re-calibrated the exogenous 

path of total factor productivity so that DICE would produce GDP projections in the absence of warming that 

exactly matched the EMF scenarios.
15-A-9

The FUND Model

Like PAGE, the FUND model treats GDP growth as exogenous. It includes separately 

calibrated damage functions for eight market and nonmarket sectors: agriculture, forestry, water, 

energy (based on heating and cooling demand), sea level rise (based on the value of land lost and 

the cost of protection), ecosystems, human health (diarrhea, vector-borne diseases, and 

cardiovascular and respiratory mortality), and extreme weather. Each impact sector has a 

different functional form, and is calculated separately for sixteen geographic regions. In some 

impact sectors, the fraction of output lost or gained due to climate change depends not only on 

the absolute temperature change but also on the rate of temperature change and level of regional 

income.4

 In the forestry and agricultural sectors, economic damages also depend on CO2

concentrations.

Tol (2009) discusses impacts not included in FUND, noting that many are likely to have a 

relatively small effect on damage estimates (both positive and negative). However, he 

characterizes several omitted impacts as “big unknowns”: for instance, extreme climate 

scenarios, biodiversity loss, and effects on economic development and political violence. With 

regard to potentially catastrophic events, he notes, “Exactly what would cause these sorts of 

changes or what effects they would have are not well-understood, although the chance of any one 

of them happening seems low. But they do have the potential to happen relatively quickly, and if 

they did, the costs could be substantial. Only a few studies of climate change have examined 

these issues.”

Adaptation is included both implicitly and explicitly in FUND. Explicit adaptation is 

seen in the agriculture and sea level rise sectors. Implicit adaptation is included in sectors such 

as energy and human health, where wealthier populations are assumed to be less vulnerable to 

climate impacts. For example, the damages to agriculture are the sum of three effects: (1) those 

due to the rate of temperature change (damages are always positive); (2) those due to the level of 

temperature change (damages can be positive or negative depending on region and temperature); 

and (3) those from CO2 fertilization (damages are generally negative but diminishing to zero). 

Adaptation is incorporated into FUND by allowing damages to be smaller if climate 

change happens more slowly. The combined effect of CO2 fertilization in the agricultural sector, 

positive impacts to some regions from higher temperatures, and sufficiently slow increases in 

temperature across these sectors can result in negative economic damages from climate change.

Damage Functions

To generate revised SCC values, we rely on the IAM modelers’ current best judgments of 

how to represent the effects of climate change (represented by the increase in global-average 

surface temperature) on the consumption-equivalent value of both market and non-market goods 

 

4 In the deterministic version of FUND, the majority of damages are attributable to increased air conditioning 

demand, while reduced cold stress in Europe, North America, and Central and East Asia results in health benefits in 

those regions at low to moderate levels of warming (Warren et al., 2006).
15-A-10

(represented as a fraction of global GDP). We recognize that these representations are 

incomplete and highly uncertain. But given the paucity of data linking the physical impacts to 

economic damages, we were not able to identify a better way to translate changes in climate into 

net economic damages, short of launching our own research program. 
15-A-11

Figure 15-A.4.1 Annual Consumption Loss as a Fraction of Global 

GDP in 2100 Due to an Increase in Annual Global 

Temperature in the DICE, FUND, and PAGE 

models5

The damage functions for the three IAMs are presented in Figures 16A.4.1 and 16A.4.2, 

using the modeler’s default scenarios and mean input assumptions. There are significant 

differences between the three models both at lower (figure 16A.4.2) and higher (figure 16A.4.1) 

increases in global-average temperature. 

The lack of agreement among the models at lower temperature increases is underscored 

by the fact that the damages from FUND are well below the 5th percentile estimated by PAGE, 

while the damages estimated by DICE are roughly equal to the 95th percentile estimated by 

PAGE. This is significant because at higher discount rates we expect that a greater proportion of 

the SCC value is due to damages in years with lower temperature increases. For example, when 

the discount rate is 2.5 percent, about 45 percent of the 2010 SCC value in DICE is due to 

damages that occur in years when the temperature is less than or equal to 3 °C. This increases to 

approximately 55 percent and 80 percent at discount rates of 3 and 5 percent, respectively.

These differences underscore the need for a thorough review of damage functions—in 

particular, how the models incorporate adaptation, technological change, and catastrophic 

 5 The x-axis represents increases in annual, rather than equilibrium, temperature, while the y-axis represents the 

annual stream of benefits as a share of global GDP. Each specific combination of climate sensitivity, socioeconomic, and emissions parameters will produce a different realization of damages for each IAM. The damage 

functions represented in Figures 1A and 1B are the outcome of default assumptions. For instance, under alternate 

assumptions, the damages from FUND may cross from negative to positive at less than or greater than 3 °C.
15-A-12

damages. Gaps in the literature make modifying these aspects of the models challenging, which 

highlights the need for additional research. As knowledge improves, the Federal government is 

committed to exploring how these (and other) models can be modified to incorporate more 

accurate estimates of damages.

Figure 15-A.4.2 Annual Consumption Loss for Lower Temperature 

Changes in DICE, FUND, and PAGE

15-A.4.2 Global versus Domestic Measures of SCC

Because of the distinctive nature of the climate change problem, we center our current 

attention on a global measure of SCC. This approach is the same as that taken for the interim 

values, but it otherwise represents a departure from past practices, which tended to put greater 

emphasis on a domestic measure of SCC (limited to impacts of climate change experienced 

within U.S. borders). As a matter of law, consideration of both global and domestic values is 

generally permissible; the relevant statutory provisions are usually ambiguous and allow 

selection of either measure.6

Global SCC

 6 It is true that federal statutes are presumed not to have extraterritorial effect, in part to ensure that the laws of the 

United States respect the interests of foreign sovereigns. But use of a global measure for the SCC does not give 

extraterritorial effect to federal law and hence does not intrude on such interests.
15-A-13

Under current OMB guidance contained in Circular A-4, analysis of economically 

significant proposed and final regulations from the domestic perspective is required, while 

analysis from the international perspective is optional. However, the climate change problem is 

highly unusual in at least two respects. First, it involves a global externality: emissions of most 

greenhouse gases contribute to damages around the world even when they are emitted in the 

United States. Consequently, to address the global nature of the problem, the SCC must 

incorporate the full (global) damages caused by GHG emissions. Second, climate change 

presents a problem that the United States alone cannot solve. Even if the United States were to 

reduce its greenhouse gas emissions to zero, that step would be far from enough to avoid 

substantial climate change. Other countries would also need to take action to reduce emissions if 

significant changes in the global climate are to be avoided. Emphasizing the need for a global 

solution to a global problem, the United States has been actively involved in seeking 

international agreements to reduce emissions and in encouraging other nations, including 

emerging major economies, to take significant steps to reduce emissions. When these 

considerations are taken as a whole, the interagency group concluded that a global measure of 

the benefits from reducing U.S. emissions is preferable. 

When quantifying the damages associated with a change in emissions, a number of 

analysts (e.g., Anthoff, et al. 2009a) employ “equity weighting” to aggregate changes in 

consumption across regions. This weighting takes into account the relative reductions in wealth 

in different regions of the world. A per-capita loss of $500 in GDP, for instance, is weighted 

more heavily in a country with a per-capita GDP of $2,000 than in one with a per-capita GDP of 

$40,000. The main argument for this approach is that a loss of $500 in a poor country causes a 

greater reduction in utility or welfare than does the same loss in a wealthy nation. 

Notwithstanding the theoretical claims on behalf of equity weighting, the interagency group 

concluded that this approach would not be appropriate for estimating a SCC value used in 

domestic regulatory analysis.7

 For this reason, the group concluded that using the global (rather 

than domestic) value, without equity weighting, is the appropriate approach.

Domestic SCC

As an empirical matter, the development of a domestic SCC is greatly complicated by the 

relatively few region- or country-specific estimates of the SCC in the literature. One potential 

source of estimates comes from the FUND model. The resulting estimates suggest that the ratio 

of domestic to global benefits of emission reductions varies with key parameter assumptions.

For example, with a 2.5 or 3 percent discount rate, the U.S. benefit is about 7-10 percent of the 

global benefit, on average, across the scenarios analyzed. Alternatively, if the fraction of GDP 

lost due to climate change is assumed to be similar across countries, the domestic benefit would 

be proportional to the U.S. share of global GDP, which is currently about 23 percent.8

 7 It is plausible that a loss of $X inflicts more serious harm on a poor nation than on a wealthy one, but development 

of the appropriate "equity weight" is challenging. Emissions reductions also impose costs, and hence a full account 

would have to consider that a given cost of emissions reductions imposes a greater utility or welfare loss on a poor 

nation than on a wealthy one. Even if equity weighting—for both the costs and benefits of emissions reductions—is 

appropriate when considering the utility or welfare effects of international action, the interagency group concluded 

that it should not be used in developing an SCC for use in regulatory policy at this time. 

8 Based on 2008 GDP (in current US dollars) from the World Bank Development Indicators Report.
15-A-14

On the basis of this evidence, the interagency workgroup determined that a range of 

values from 7 to 23 percent should be used to adjust the global SCC to calculate domestic 

effects. Reported domestic values should use this range. It is recognized that these values are 

approximate, provisional, and highly speculative. There is no a priori reason why domestic 

benefits should be a constant fraction of net global damages over time. Further, FUND does not 

account for how damages in other regions could affect the United States (e.g., global migration, 

economic and political destabilization). If more accurate methods for calculating the domestic 

SCC become available, the Federal government will examine these to determine whether to 

update its approach.

15-A.4.3 Valuing Non-CO2 Emissions

While CO2 is the most prevalent greenhouse gas emitted into the atmosphere, the U.S. 

included five other greenhouse gases in its recent endangerment finding: methane, nitrous oxide, 

hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. The climate impact of these 

gases is commonly discussed in terms of their 100-year global warming potential (GWP). GWP 

measures the ability of different gases to trap heat in the atmosphere (i.e., radiative forcing per 

unit of mass) over a particular timeframe relative to CO2. However, because these gases differ in 

both radiative forcing and atmospheric lifetimes, their relative damages are not constant over 

time. For example, because methane has a short lifetime, its impacts occur primarily in the near 

term and thus are not discounted as heavily as those caused by longer-lived gases. Impacts other 

than temperature change also vary across gases in ways that are not captured by GWP. For 

instance, CO2 emissions, unlike methane and other greenhouse gases, contribute to ocean 

acidification. Likewise, damages from methane emissions are not offset by the positive effect of 

CO2 fertilization. Thus, transforming gases into CO2-equivalents using GWP, and then 

multiplying the carbon-equivalents by the SCC, would not result in accurate estimates of the 

social costs of non-CO2 gases. 

In light of these limitations, and the significant contributions of non-CO2 emissions to 

climate change, further research is required to link non-CO2 emissions to economic impacts. 

Such work would feed into efforts to develop a monetized value of reductions in non-CO2

greenhouse gas emissions. As part of ongoing work to further improve the SCC estimates, the 

interagency group hopes to develop methods to value these other greenhouse gases. The goal is 

to develop these estimates by the time we issue revised SCC estimates for carbon dioxide 

emissions. 

15-A.4.4 Equilibrium Climate Sensitivity

Equilibrium climate sensitivity (ECS) is a key input parameter for the DICE, PAGE, and 

FUND models.9

 9 The equilibrium climate sensitivity includes the response of the climate system to increased greenhouse gas 

concentrations over the short to medium term (up to 100-200 years), but it does not include long-term feedback 

effects due to possible large-scale changes in ice sheets or the biosphere, which occur on a time scale of many 

hundreds to thousands of years (e.g. Hansen et al. 2007).

 It is defined as the long-term increase in the annual global-average surface 
15-A-15

temperature from a doubling of atmospheric CO2 concentration relative to pre-industrial levels 

(or stabilization at a concentration of approximately 550 parts per million (ppm)). Uncertainties 

in this important parameter have received substantial attention in the peer-reviewed literature.

The most authoritative statement about equilibrium climate sensitivity appears in the 

Fourth Assessment Report of the Intergovernmental Panel on Climate Change (IPCC):

Basing our assessment on a combination of several independent lines of evidence...including 

observed climate change and the strength of known feedbacks simulated in [global climate 

models], we conclude that the global mean equilibrium warming for doubling CO2, or 

‘equilibrium climate sensitivity’, is likely to lie in the range 2 °C to 4.5 °C, with a most likely 

value of about 3 °C. Equilibrium climate sensitivity is very likely larger than 1.5 °C. 10 

For fundamental physical reasons as well as data limitations, values substantially higher 

than 4.5 °C still cannot be excluded, but agreement with observations and proxy data is 

generally worse for those high values than for values in the 2 °C to 4.5 °C range. (Meehl et 

al., 2007, p 799)

After consulting with several lead authors of this chapter of the IPCC report, the 

interagency workgroup selected four candidate probability distributions and calibrated them to 

be consistent with the above statement: Roe and Baker (2007), log-normal, gamma, and Weibull. 

Table 16A.4.1 included below gives summary statistics for the four calibrated distributions.

Table 15-A.4.1 Summary Statistics for Four Calibrated Climate Sensitivity Distributions

Roe & Baker Log-normal Gamma Weibull

Pr(ECS < 1.5°C) 0.013 0.050 0.070 0.102

Pr(2°C < ECS < 4.5°C) 0.667 0.667 0.667 0.667

5th percentile 1.72 1.49 1.37 1.13

10th percentile 1.91 1.74 1.65 1.48

Mode 2.34 2.52 2.65 2.90

Median (50th percentile) 3.00 3.00 3.00 3.00

Mean 3.50 3.28 3.19 3.07

90th percentile 5.86 5.14 4.93 4.69

95th percentile 7.14 5.97 5.59 5.17

Each distribution was calibrated by applying three constraints from the IPCC:

 

10 This is in accord with the judgment that it “is likely to lie in the range 2 °C to 4.5 °C” and the IPCC definition of 

“likely” as greater than 66 percent probability (Le Treut et al.2007). “Very likely” indicates a greater than 90 percent 

probability.
15-A-16

(1) a median equal to 3°C, to reflect the judgment of “a most likely value of about 3 °C”;11

(2) two-thirds probability that the equilibrium climate sensitivity lies between 2 and 4.5 °C; 

and

(3) zero probability that it is less than 0°C or greater than 10°C (see Hegerl et al. 2006, p. 

721).

We selected the calibrated Roe and Baker distribution from the four candidates for two 

reasons. First, the Roe and Baker distribution is the only one of the four that is based on a 

theoretical understanding of the response of the climate system to increased greenhouse gas 

concentrations (Roe and Baker 2007, Roe 2008). In contrast, the other three distributions are 

mathematical functions that are arbitrarily chosen based on simplicity, convenience, and general 

shape. The Roe and Baker distribution results from three assumptions about climate response: 

(1) absent feedback effects, the equilibrium climate sensitivity is equal to 1.2 °C; (2) feedback 

factors are proportional to the change in surface temperature; and (3) uncertainties in feedback 

factors are normally distributed. There is widespread agreement on the first point and the second 

and third points are common assumptions. 

Second, the calibrated Roe and Baker distribution better reflects the IPCC judgment that 

“values substantially higher than 4.5°C still cannot be excluded.” Although the IPCC made no 

quantitative judgment, the 95th percentile of the calibrated Roe & Baker distribution (7.1 °C) is 

much closer to the mean and the median (7.2 °C) of the 95th percentiles of 21 previous studies 

summarized by Newbold and Daigneault (2009). It is also closer to the mean (7.5 °C) and 

median (7.9 °C) of the nine truncated distributions examined by the IPCC (Hegerl, et al., 2006) 

than are the 95th percentiles of the three other calibrated distributions (5.2-6.0 °C).

Finally, we note the IPCC judgment that the equilibrium climate sensitivity “is very 

likely larger than 1.5°C.” Although the calibrated Roe & Baker distribution, for which the 

probability of equilibrium climate sensitivity being greater than 1.5°C is almost 99 percent, is not 

inconsistent with the IPCC definition of “very likely” as “greater than 90 percent probability,” it 

reflects a greater degree of certainty about very low values of ECS than was expressed by the 

IPCC. 

 11 Strictly speaking, “most likely” refers to the mode of a distribution rather than the median, but common usage 

would allow the mode, median, or mean to serve as candidates for the central or “most likely” value and the IPCC 

report is not specific on this point. For the distributions we considered, the median was between the mode and the 

mean. For the Roe and Baker distribution, setting the median equal to 3°C, rather than the mode or mean, gave a 95th

percentile that is more consistent with IPCC judgments and the literature. For example, setting the mean and mode 

equal to 3°C produced 95th percentiles of 5.6 and 8.6 °C, respectively, which are in the lower and upper end of the 

range in the literature. Finally, the median is closer to 3°C than is the mode for the truncated distributions selected 

by the IPCC (Hegerl, et al., 2006); the average median is 3.1 °C and the average mode is 2.3 °C, which is most 

consistent with a Roe and Baker distribution with the median set equal to 3 °C.
15-A-17

Figure 15-A.4.3 Estimates of the Probability Density Function for 

Equilibrium Climate Sensitivity (°C)

To show how the calibrated Roe and Baker distribution compares to different estimates 

of the probability distribution function of equilibrium climate sensitivity in the empirical 

literature, Figure 16A.4.3 (above) overlays it on Figure 9.20 from the IPCC Fourth Assessment 

Report. These functions are scaled to integrate to unity between 0 °C and 10 °C. The horizontal 

bars show the respective 5 percent to 95 percent ranges; dots indicate the median estimate.12

15-A.4.5 Socio-Economic and Emissions Trajectories

Another key issue considered by the interagency group is how to select the set of socioeconomic and emissions parameters for use in PAGE, DICE, and FUND. Socio-economic 

pathways are closely tied to climate damages because, all else equal, more and wealthier people 

tend to emit more greenhouse gases and also have a higher (absolute) willingness to pay to avoid 

climate disruptions. For this reason, we consider how to model several input parameters in 

tandem: GDP, population, CO2 emissions, and non-CO2 radiative forcing. A wide variety of 

scenarios have been developed and used for climate change policy simulations (e.g., SRES 2000, 

 12 The estimates based on instrumental data are from Andronova and Schlesinger (2001), Forest et al. (2002; dashed 

line, anthropogenic forcings only), Forest et al. (2006; solid line, anthropogenic and natural forcings), Gregory et al. 

(2002a), Knutti et al. (2002), Frame et al. (2005), and Forster and Gregory (2006). Hegerl et al. (2006) are based on 

multiple palaeoclimatic reconstructions of north hemisphere mean temperatures over the last 700 years. Also shown 

are the 5-95 percent approximate ranges for two estimates from the last glacial maximum (dashed, Annan et al. 

2005; solid, Schneider von Deimling et al. 2006), which are based on models with different structural properties.
15-A-18

CCSP 2007, EMF 2009). In determining which scenarios are appropriate for inclusion, we 

aimed to select scenarios that span most of the plausible ranges of outcomes for these variables. 

To accomplish this task in a transparent way, we decided to rely on the recent Stanford 

Energy Modeling Forum exercise, EMF-22. EMF-22 uses ten well-recognized models to 

evaluate substantial, coordinated global action to meet specific stabilization targets. A key 

advantage of relying on these data is that GDP, population, and emission trajectories are 

internally consistent for each model and scenario evaluated. The EMF-22 modeling effort also is 

preferable to the IPCC SRES due to their age (SRES were developed in 1997) and the fact that 3 

of 4 of the SRES scenarios are now extreme outliers in one or more variables. Although the 

EMF-22 scenarios have not undergone the same level of scrutiny as the SRES scenarios, they are 

recent, peer-reviewed, published, and publicly available.

To estimate the SCC for use in evaluating domestic policies that will have a small effect 

on global cumulative emissions, we use socio-economic and emission trajectories that span a 

range of plausible scenarios. Five trajectories were selected from EMF-22 (see Table 16A.4.2

below). Four of these represent potential business-as-usual (BAU) growth in population, 

wealth, and emissions and are associated with CO2 (only) concentrations ranging from 612 to 

889 ppm in 2100. One represents an emissions pathway that achieves stabilization at 550 ppm 

CO2e (i.e., CO2-only concentrations of 425 – 484 ppm or a radiative forcing of 3.7 W/m2) in 

2100, a lower-than-BAU trajectory.13 Out of the 10 models included in the EMF-22 exercise, we 

selected the trajectories used by MiniCAM, MESSAGE, IMAGE, and the optimistic scenario 

from MERGE. For the BAU pathways, we used the GDP, population, and emission trajectories 

from each of these four models. For the 550 ppm CO2e scenario, we averaged the GDP, 

population, and emission trajectories implied by these same four models. 

 

13 Such an emissions path would be consistent with widespread action by countries to mitigate GHG emissions, 

though it could also result from technological advances. It was chosen because it represents the most stringent case 

analyzed by the EMF-22 where all the models converge: a 550 ppm, not to exceed, full participation scenario.
15-A-19

Table 15-A.4.2 Socioeconomic and Emissions Projections from Select EMF-22 Reference 

Scenarios

Reference Fossil and Industrial CO2 Emissions (GtCO2/yr)

EMF – 22 Based Scenarios 2000 2010 2020 2030 2050 2100

IMAGE 26.6 31.9 36.9 40.0 45.3 60.1

MERGE Optimistic 24.6 31.5 37.6 45.1 66.5 117.9

MESSAGE 26.8 29.2 37.6 42.1 43.5 42.7

MiniCAM 26.5 31.8 38.0 45.1 57.8 80.5

550 ppm average 26.2 31.1 33.2 32.4 20.0 12.8

Reference GDP (using market exchange rates in trillion 2005$)14

EMF – 22 Based Scenarios 2000 2010 2020 2030 2050 2100

IMAGE 38.6 53.0 73.5 97.2 156.3 396.6

MERGE Optimistic 36.3 45.9 59.7 76.8 122.7 268.0

MESSAGE 38.1 52.3 69.4 91.4 153.7 334.9

MiniCAM 36.1 47.4 60.8 78.9 125.7 369.5

550 ppm average 37.1 49.6 65.6 85.5 137.4 337.9

Global Population (billions)

EMF – 22 Based Scenarios 2000 2010 2020 2030 2050 2100

IMAGE 6.1 6.9 7.6 8.2 9.0 9.1

MERGE Optimistic 6.0 6.8 7.5 8.2 9.0 9.7

MESSAGE 6.1 6.9 7.7 8.4 9.4 10.4

MiniCAM 6.0 6.8 7.5 8.1 8.8 8.7

550 ppm average 6.1 6.8 7.6 8.2 8.7 9.1

We explore how sensitive the SCC is to various assumptions about how the future will 

evolve without prejudging what is likely to occur. The interagency group considered formally 

assigning probability weights to different states of the world, but this proved challenging to do in 

an analytically rigorous way given the dearth of information on the likelihood of a full range of 

future socio-economic pathways. 

 14 While the EMF-22 models used market exchange rates (MER) to calculate global GDP, it is also possible to use 

purchasing power parity (PPP). PPP takes into account the different price levels across countries, so it more 

accurately describes relative standards of living across countries. MERs tend to make low-income countries appear 

poorer than they actually are. Because many models assume convergence in per capita income over time, use of 

MER-adjusted GDP gives rise to projections of higher economic growth in low income countries. There is an 

ongoing debate about how much this will affect estimated climate impacts. Critics of the use of MER argue that it 

leads to overstated economic growth and hence a significant upward bias in projections of greenhouse gas 

emissions, and unrealistically high future temperatures (e.g., Castles and Henderson 2003). Others argue that 

convergence of the emissions-intensity gap across countries at least partially offset the overstated income gap so that 

differences in exchange rates have less of an effect on emissions (Holtsmark and Alfsen, 2005; Tol, 2006). 

Nordhaus (2007b) argues that the ideal approach is to use superlative PPP accounts (i.e., using cross-sectional PPP 

measures for relative incomes and outputs and national accounts price and quantity indexes for time-series 

extrapolations). However, he notes that it important to keep this debate in perspective; it is by no means clear that 

exchange-rate-conversion issues are as important as uncertainties about population, technological change, or the 

many geophysical uncertainties.
15-A-20

There are a number of caveats. First, EMF BAU scenarios represent the modelers’ 

judgment of the most likely pathway absent mitigation policies to reduce greenhouse gas 

emissions, rather than the wider range of possible outcomes. Nevertheless, these views of the 

most likely outcome span a wide range, from the more optimistic (e.g. abundant low-cost, lowcarbon energy) to more pessimistic (e.g. constraints on the availability of nuclear and 

renewables).15 Second, the socio-economic trajectories associated with a 550 ppm CO2e 

concentration scenario are not derived from an assessment of what policy is optimal from a 

benefit-cost standpoint. Rather, it is indicative of one possible future outcome. The emission 

trajectories underlying some BAU scenarios (e.g. MESSAGE’s 612 ppm) also are consistent 

with some modest policy action to address climate change.16 We chose not to include socioeconomic trajectories that achieve even lower GHG concentrations at this time, given the 

difficulty many models had in converging to meet these targets.

For comparison purposes, the Energy Information Agency in its 2009 Annual Energy 

Outlook projected that global carbon dioxide emissions will grow to 30.8, 35.6, and 40.4 

gigatons in 2010, 2020, and 2030, respectively, while world GDP is projected to be $51.8, $71.0 

and $93.9 trillion (in 2005 dollars using market exchange rates) in 2010, 2020, and 2030, 

respectively. These projections are consistent with one or more EMF-22 scenarios. Likewise, 

the United Nations’ 2008 Population Prospect projects population will grow from 6.1 billion 

people in 2000 to 9.1 billion people in 2050, which is close to the population trajectories for the 

IMAGE, MiniCAM, and MERGE models.

In addition to fossil and industrial CO2 emissions, each EMF scenario provides 

projections of methane, nitrous oxide, fluorinated greenhouse gases, and net land use CO2

emissions out to 2100. These assumptions also are used in the three models while retaining the 

default radiative forcings due to other factors (e.g. aerosols and other gases). See the Appendix 

for greater detail.

15-A.4.6 Discount Rate

The choice of a discount rate, especially over long periods of time, raises highly 

contested and exceedingly difficult questions of science, economics, philosophy, and law. 

Although it is well understood that the discount rate has a large influence on the current value of 

future damages, there is no consensus about what rates to use in this context. Because carbon 

dioxide emissions are long-lived, subsequent damages occur over many years. In calculating the 

SCC, we first estimate the future damages to agriculture, human health, and other market and 

non-market sectors from an additional unit of carbon dioxide emitted in a particular year in terms 

of reduced consumption (or consumption equivalents) due to the impacts of elevated 

temperatures, as represented in each of the three IAMs. Then we discount the stream of future 

 15 For instance, in the MESSAGE model’s reference case total primary energy production from nuclear, biomass, 

and non-biomass renewables is projected to increase from about 15 percent of total primary energy in 2000 to 54 

percent in 2100. In comparison, the MiniCAM reference case shows 10 percent in 2000 and 21 percent in 2100. 

16 For example, MiniCAM projects if all non-US OECD countries reduce CO2 emissions to 83 percent below 2005 

levels by 2050 (per the G-8 agreement) but all other countries continue along a BAU path CO2 concentrations in 

2100 would drop from 794 ppmv in its reference case to 762 ppmv.
15-A-21

damages to its present value in the year when the additional unit of emissions was released using 

the selected discount rate, which is intended to reflect society's marginal rate of substitution 

between consumption in different time periods. 

For rules with both intra- and intergenerational effects, agencies traditionally employ 

constant discount rates of both 3 percent and 7 percent in accordance with OMB Circular A-4. 

As Circular A-4 acknowledges, however, the choice of discount rate for intergenerational 

problems raises distinctive problems and presents considerable challenges. After reviewing 

those challenges, Circular A-4 states, “If your rule will have important intergenerational benefits 

or costs you might consider a further sensitivity analysis using a lower but positive discount rate 

in addition to calculating net benefits using discount rates of 3 and 7 percent.” For the specific 

purpose of developing the SCC, we adapt and revise that approach here.

Arrow et al. (1996) outlined two main approaches to determine the discount rate for 

climate change analysis, which they labeled “descriptive” and “prescriptive.” The descriptive 

approach reflects a positive (non-normative) perspective based on observations of people’s 

actual choices—e.g., savings versus consumption decisions over time, and allocations of savings 

among more and less risky investments. Advocates of this approach generally call for inferring 

the discount rate from market rates of return “because of a lack of justification for choosing a 

social welfare function that is any different than what decision makers [individuals] actually use” 

(Arrow et al. 1996). 

One theoretical foundation for the cost-benefit analyses in which the social cost of carbon 

will be used—the Kaldor-Hicks potential-compensation test—also suggests that market rates 

should be used to discount future benefits and costs, because it is the market interest rate that 

would govern the returns potentially set aside today to compensate future individuals for climate 

damages that they bear (e.g., Just et al. 2004). As some have noted, the word “potentially” is an 

important qualification; there is no assurance that such returns will actually be set aside to 

provide compensation, and the very idea of compensation is difficult to define in the 

intergenerational context. On the other hand, societies provide compensation to future 

generations through investments in human capital and the resulting increase in knowledge, as 

well as infrastructure and other physical capital.

The prescriptive approach specifies a social welfare function that formalizes the 

normative judgments that the decision-maker wants explicitly to incorporate into the policy 

evaluation—e.g., how inter-personal comparisons of utility should be made, and how the welfare 

of future generations should be weighed against that of the present generation. Ramsey (1928), 

for example, has argued that it is “ethically indefensible” to apply a positive pure rate of time 

preference to discount values across generations, and many agree with this view. 

Other concerns also motivate making adjustments to descriptive discount rates. In 

particular, it has been noted that the preferences of future generations with regard to 

consumption versus environmental amenities may not be the same as those today, making the 

current market rate on consumption an inappropriate metric by which to discount future climaterelated damages. Others argue that the discount rate should be below market rates to correct for 

market distortions and uncertainties or inefficiencies in intergenerational transfers of wealth, 
15-A-22

which in the Kaldor-Hicks logic are presumed to compensate future generations for damage (a 

potentially controversial assumption, as noted above) (Arrow et al. 1996, Weitzman 1999).

Further, a legitimate concern about both descriptive and prescriptive approaches is that 

they tend to obscure important heterogeneity in the population. The utility function that 

underlies the prescriptive approach assumes a representative agent with perfect foresight and no 

credit constraints. This is an artificial rendering of the real world that misses many of the 

frictions that characterize individuals’ lives and indeed the available descriptive evidence 

supports this. For instance, many individuals smooth consumption by borrowing with credit 

cards that have relatively high rates. Some are unable to access traditional credit markets and 

rely on payday lending operations or other high cost forms of smoothing consumption. Whether 

one puts greater weight on the prescriptive or descriptive approach, the high interest rates that 

credit-constrained individuals accept suggest that some account should be given to the discount 

rates revealed by their behavior. 

We draw on both approaches but rely primarily on the descriptive approach to inform the 

choice of discount rate. With recognition of its limitations, we find this approach to be the most 

defensible and transparent given its consistency with the standard contemporary theoretical 

foundations of benefit-cost analysis and with the approach required by OMB’s existing guidance. 

The logic of this framework also suggests that market rates should be used for discounting future 

consumption-equivalent damages. Regardless of the theoretical approach used to derive the 

appropriate discount rate(s), we note the inherent conceptual and practical difficulties of 

adequately capturing consumption trade-offs over many decades or even centuries. While 

relying primarily on the descriptive approach in selecting specific discount rates, the interagency 

group has been keenly aware of the deeply normative dimensions of both the debate over 

discounting in the intergenerational context and the consequences of selecting one discount rate 

over another. 

Historically Observed Interest Rates

In a market with no distortions, the return to savings would equal the private return on 

investment, and the market rate of interest would be the appropriate choice for the social 

discount rate. In the real world risk, taxes, and other market imperfections drive a wedge 

between the risk-free rate of return on capital and the consumption rate of interest. Thus, the 

literature recognizes two conceptual discount concepts—the consumption rate of interest and the 

opportunity cost of capital. 

According to OMB’s Circular A-4, it is appropriate to use the rate of return on capital 

when a regulation is expected to displace or alter the use of capital in the private sector. In this 

case, OMB recommends Agencies use a discount rate of 7 percent. When regulation is expected 

to primarily affect private consumption—for instance, via higher prices for goods and services—

a lower discount rate of 3 percent is appropriate to reflect how private individuals trade-off 

current and future consumption. 

The interagency group examined the economics literature and concluded that the 

consumption rate of interest is the correct concept to use in evaluating the benefits and costs of a 
15-A-23

marginal change in carbon emissions (see Lind 1990, Arrow et al 1996, and Arrow 2000). The 

consumption rate of interest also is appropriate when the impacts of a regulation are measured in 

consumption (-equivalent) units, as is done in the three integrated assessment models used for 

estimating the SCC. 

Individuals use a variety of savings instruments that vary with risk level, time horizon, 

and tax characteristics. The standard analytic framework used to develop intuition about the 

discount rate typically assumes a representative agent with perfect foresight and no credit 

constraints. The risk-free rate is appropriate for discounting certain future benefits or costs, but 

the benefits calculated by IAMs are uncertain. To use the risk-free rate to discount uncertain 

benefits, these benefits first must be transformed into "certainty equivalents," that is the 

maximum certain amount that we would exchange for the uncertain amount. However, the 

calculation of the certainty-equivalent requires first estimating the correlation between the 

benefits of the policy and baseline consumption.

If the IAM projections of future impacts represent expected values (not certaintyequivalent values), then the appropriate discount rate generally does not equal the risk-free rate. 

If the benefits of the policy tend to be high in those states of the world in which consumption is 

low, then the certainty-equivalent benefits will be higher than the expected benefits (and vice 

versa). Since many (though not necessarily all) of the important impacts of climate change will 

flow through market sectors such as agriculture and energy, and since willingness to pay for 

environmental protections typically increases with income, we might expect a positive (though 

not necessarily perfect) correlation between the net benefits from climate policies and market 

returns. This line of reasoning suggests that the proper discount rate would exceed the riskless 

rate. Alternatively, a negative correlation between the returns to climate policies and market 

returns would imply that a discount rate below the riskless rate is appropriate.

This discussion suggests that both the post-tax riskless and risky rates can be used to 

capture individuals’ consumption-equivalent interest rate. As a measure of the post-tax riskless 

rate, we calculate the average real return from Treasury notes over the longest time period 

available (those from Newell and Pizer 2003) and adjust for Federal taxes (the average marginal 

rate from tax years 2003 through 2006 is around 27 percent).17 This calculation produces a real 

interest rate of about 2.7 percent, which is roughly consistent with Circular A-4’s 

recommendation to use 3 percent to represent the consumption rate of interest.18

 17 The literature argues for a risk-free rate on government bonds as an appropriate measure of the consumption rate 

of interest. Arrow (2000) suggests that it is roughly 3-4 percent. OMB cites evidence of a 3.1 percent pre-tax rate 

for 10-year Treasury notes in the A-4 guidance. Newell and Pizer (2003) find real interest rates between 3.5 and 4 

percent for 30-year Treasury securities. 

 A measure of 

the post-tax risky rate for investments whose returns are positively correlated with overall equity 

18 The positive approach reflects how individuals make allocation choices across time, but it is important to keep in 

mind that we wish to reflect preferences for society as a whole, which generally has a longer planning horizon.
15-A-24

market returns can be obtained by adjusting pre-tax rates of household returns to risky 

investments (approximately 7 percent) for taxes yields a real rate of roughly 5 percent.19 

The Ramsey Equation

Ramsey discounting also provides a useful framework to inform the choice of a discount 

rate. Under this approach, the analyst applies either positive or normative judgments in selecting 

values for the key parameters of the Ramsey equation: η (coefficient of relative risk aversion or 

elasticity of the marginal utility of consumption) and ρ (pure rate of time preference).20 These 

are then combined with g (growth rate of per-capita consumption) to equal the interest rate at 

which future monetized damages are discounted: ρ + η∙g.

21 In the simplest version of the 

Ramsey model, with an optimizing representative agent with perfect foresight, what we are 

calling the “Ramsey discount rate,” ρ + η∙g, will be equal to the rate of return to capital, i.e., the 

market interest rate.

A review of the literature provides some guidance on reasonable parameter values for the 

Ramsey discounting equation, based on both prescriptive and descriptive approaches. 

• η. Most papers in the climate change literature adopt values for η in the range of 0.5 to 3 

(Weitzman cites plausible values as those ranging from 1 to 4), although not all authors 

articulate whether their choice is based on prescriptive or descriptive reasoning.22 

Dasgupta (2008) argues that η should be greater than 1 and may be as high as 3, since η

equal to 1 suggests savings rates that do not conform to observed behavior. 

 19 Cambell et al (2001) estimates that the annual real return from stocks for 1900-1995 was about 7 percent. The 

annual real rate of return for the S&P 500 from 1950 – 2008 was about 6.8 percent. In the absence of a better way to 

population-weight the tax rates, we use the middle of the 20 – 40 percent range to derive a post-tax interest rate 

(Kotlikoff and Rapson 2006).

20 The parameter ρ measures the pure rate of time preference: people’s behavior reveals a preference for an increase 

in utility today versus the future. Consequently, it is standard to place a lower weight on utility in the future. The 

parameter η captures diminishing marginal utility: consumption in the future is likely to be higher than consumption 

today, so diminishing marginal utility of consumption implies that the same monetary damage will cause a smaller 

reduction of utility for wealthier individuals, either in the future or in current generations. If η = 0, then a one dollar 

increase in income is equally valuable regardless of level of income; if η = 1, then a one percent increase in income 

is equally valuable no matter the level of income; and if η > 1, then a one percent increase in income is less valuable 

to wealthier individuals. 

21 In this case, g could be taken from the selected EMF socioeconomic scenarios or alternative assumptions about 

the rate of consumption growth.

22 Empirical estimates of η span a wide range of values. A benchmark value of 2 is near the middle of the range of 

values estimated or used by Szpiro (1986), Hall and Jones (2007), Arrow (2007), Dasgupta (2006, 2008), Weitzman 

(2007, 2009), and Nordhaus (2008). However, Chetty (2006) developed a method of estimating η using data on 

labor supply behavior. He shows that existing evidence of the effects of wage changes on labor supply imposes a 

tight upper bound on the curvature of utility over wealth (CRRA < 2) with the mean implied value of 0.71 and 

concludes that the standard expected utility model cannot generate high levels of risk aversion without contradicting 

established facts about labor supply. Recent work has jointly estimated the components of the Ramsey equation. 

Evans and Sezer (2005) estimate η = 1.49 for 22 OECD countries. They also estimate ρ = 1.08 percent per year 

using data on mortality rates. Anthoff, et al. (2009b) estimate η = 1.18, and ρ = 1.4 percent. When they multiply the 

bivariate probability distributions from their work and Evans and Sezer (2005) together, they find η = 1.47, and ρ = 

1.07. 
15-A-25

• ρ. With respect to the pure rate of time preference, most papers in the climate change 

literature adopt values for ρ in the range of 0 to 3 percent per year. The very low rates 

tend to follow from moral judgments involving intergenerational neutrality. Some have 

argued that to use any value other than ρ = 0 would unjustly discriminate against future 

generations (e.g., Arrow et al. 1996, Stern et al. 2006). However, even in an intergenerational setting, it may make sense to use a small positive pure rate of time 

preference because of the small probability of unforeseen cataclysmic events (Stern et al. 

2006).

• g. A commonly accepted approximation is around 2 percent per year. For the socioeconomic scenarios used for this exercise, the EMF models assume that g is about 1.5-2 

percent to 2100. 

Some economists and non-economists have argued for constant discount rates below 2 

percent based on the prescriptive approach. When grounded in the Ramsey framework, 

proponents of this approach have argued that a ρ of zero avoids giving preferential treatment to 

one generation over another. The choice of η has also been posed as an ethical choice linked to 

the value of an additional dollar in poorer countries compared to wealthier ones. Stern et al. 

(2006) applies this perspective through his choice of ρ = 0.1 percent per year, η = 1 and g = 1.3 

percent per year, which yields an annual discount rate of 1.4 percent. In the context of 

permanent income savings behavior, however, Stern’s assumptions suggest that individuals 

would save 93 percent of their income.23

Recently, Stern (2008) revisited the values used in Stern et al. (2006), stating that there is 

a case to be made for raising η due to the amount of weight lower values place on damages far in 

the future (over 90 percent of expected damages occur after 2200 with η = 1). Using Stern’s 

assumption that ρ = 0.1 percent, combined with a η of 1.5 to 2 and his original growth rate, 

yields a discount rate greater 2 percent. 

We conclude that arguments made under the prescriptive approach can be used to justify 

discount rates between roughly 1.4 and 3.1 percent. In light of concerns about the most 

appropriate value for η, we find it difficult to justify rates at the lower end of this range under the 

Ramsey framework. 

Accounting for Uncertainty in the Discount Rate

While the consumption rate of interest is an important driver of the benefits estimate, it is 

uncertain over time. Ideally, we would formally model this uncertainty, just as we do for climate 

sensitivity. Weitzman (1998, 2001) showed theoretically and Newell and Pizer (2003) and 

Groom et al. (2006) confirm empirically that discount rate uncertainty can have a large effect on 

net present values. A main result from these studies is that if there is a persistent element to the 

uncertainty in the discount rate (e.g., the rate follows a random walk), then it will result in an 

effective (or certainty-equivalent) discount rate that declines over time. Consequently, lower 

 23 Stern (2008) argues that building in a positive rate of exogenous technical change over time reduces the implied 

savings rate and that η at or above 2 are inconsistent with observed behavior with regard to equity. (At the same 

time, adding exogenous technical change—all else equal—would increase g as well.)
15-A-26

discount rates tend to dominate over the very long term (see Weitzman 1998, 1999, 2001; 

Newell and Pizer 2003; Groom et al. 2006; Gollier 2008; Summers and Zeckhauser 2008; and 

Gollier and Weitzman 2009). 

The proper way to model discount rate uncertainty remains an active area of research. 

Newell and Pizer (2003) employ a model of how long-term interest rates change over time to 

forecast future discount rates. Their model incorporates some of the basic features of how 

interest rates move over time, and its parameters are estimated based on historical observations 

of long-term rates. Subsequent work on this topic, most notably Groom et al. (2006), uses more 

general models of interest rate dynamics to allow for better forecasts. Specifically, the volatility 

of interest rates depends on whether rates are currently low or high and variation in the level of 

persistence over time.

While Newell and Pizer (2003) and Groom et al (2006) attempt formally to model 

uncertainty in the discount rate, others argue for a declining scale of discount rates applied over 

time (e.g., Weitzman 2001, and the UK’s “Green Book” for regulatory analysis). This approach 

uses a higher discount rate initially, but applies a graduated scale of lower discount rates further 

out in time.24 A key question that has emerged with regard to both of these approaches is the 

trade-off between potential time inconsistency and giving greater weight to far future outcomes 

(see the EPA Science Advisory Board’s recent comments on this topic as part of its review of 

their Guidelines for Economic Analysis).25

The Discount Rates Selected for Estimating SCC

In light of disagreement in the literature on the appropriate market interest rate to use in 

this context and uncertainty about how interest rates may change over time, we use three 

discount rates to span a plausible range of certainty-equivalent constant discount rates: 2.5, 3, 

and 5 percent per year. Based on the review in the previous sections, the interagency workgroup 

determined that these three rates reflect reasonable judgments under both descriptive and 

prescriptive approaches.

The central value, 3 percent, is consistent with estimates provided in the economics 

literature and OMB’s Circular A-4 guidance for the consumption rate of interest. As previously 

mentioned, the consumption rate of interest is the correct discounting concept to use when future 

damages from elevated temperatures are estimated in consumption-equivalent units. Further, 3 

percent roughly corresponds to the after-tax riskless interest rate. The upper value of 5 percent is 

 24 For instance, the UK applies a discount rate of 3.5 percent to the first 30 years; 3 percent for years 31 - 75; 2.5 

percent for years 76 - 125; 2 percent for years 126 - 200; 1.5 percent for years 201 - 300; and 1 percent after 300 

years. As a sensitivity, it recommends a discount rate of 3 percent for the first 30 years, also decreasing over time. 

25 Uncertainty in future damages is distinct from uncertainty in the discount rate. Weitzman (2008) argues that 

Stern’s choice of a low discount rate was “right for the wrong reasons.” He demonstrates how the damages from a 

low probability, catastrophic event far in the future dominate the effect of the discount rate in a present value 

calculation and result in an infinite willingness-to-pay for mitigation today. Newbold and Daigneault, (2009) and 

Nordhaus (2009) find that Weitzman’s result is sensitive to the functional forms chosen for climate sensitivity, 

utility, and consumption. Summers and Zeckhauser (2008) argue that uncertainty in future damages can also work in 

the other direction by increasing the benefits of waiting to learn the appropriate level of mitigation required. 
15-A-27

included to represent the possibility that climate damages are positively correlated with market 

returns. Additionally, this discount rate may be justified by the high interest rates that many 

consumers use to smooth consumption across periods.

The low value, 2.5 percent, is included to incorporate the concern that interest rates are 

highly uncertain over time. It represents the average certainty-equivalent rate using the meanreverting and random walk approaches from Newell and Pizer (2003) starting at a discount rate 

of 3 percent. Using this approach, the certainty equivalent is about 2.2 percent using the random 

walk model and 2.8 percent using the mean reverting approach.26

15-A.5 REVISED SCC ESTIMATES

 Without giving preference to a 

particular model, the average of the two rates is 2.5 percent. Further, a rate below the riskless 

rate would be justified if climate investments are negatively correlated with the overall market 

rate of return. Use of this lower value also responds to certain judgments using the prescriptive 

or normative approach and to ethical objections that have been raised about rates of 3 percent or 

higher.

Our general approach to estimating SCC values is to run the three integrated assessment 

models (FUND, DICE, and PAGE) using the following inputs agreed upon by the interagency 

group:

• A Roe and Baker distribution for the climate sensitivity parameter bounded between 0 

and 10 with a median of 3 °C and a cumulative probability between 2 and 4.5 °C of twothirds.

• Five sets of GDP, population and carbon emissions trajectories based on EMF-22.

• Constant annual discount rates of 2.5, 3, and 5 percent.

Because the climate sensitivity parameter is modeled probabilistically, and because PAGE and 

FUND incorporate uncertainty in other model parameters, the final output from each model run 

is a distribution over the SCC in year t. 

For each of the IAMS, the basic computational steps for calculating the SCC in a particular year t

are:

1. Input the path of emissions, GDP, and population from the selected EMF-22 

scenarios, and the extrapolations based on these scenarios for post-2100 years.

2. Calculate the temperature effects and (consumption-equivalent) damages in each 

year resulting from the baseline path of emissions. 

a. In PAGE, the consumption-equivalent damages in each period are 

calculated as a fraction of the EMF GDP forecast, depending on the 

 

26 Calculations done by Pizer et al. using the original simulation program from Newell and Pizer (2003).
15-A-28

temperature in that period relative to the pre-industrial average 

temperature in each region. 

b. In FUND, damages in each period depend on both the level and the rate of 

temperature change in that period. 

c. In DICE, temperature affects both consumption and investment, so we 

first adjust the EMF GDP paths as follows: Using the Cobb-Douglas 

production function with the DICE2007 parameters, we extract the path of 

exogenous technical change implied by the EMF GDP and population 

paths, then we recalculate the baseline GDP path taking into account 

climate damages resulting from the baseline emissions path. 

3. Add an additional unit of carbon emissions in year t. (The exact unit varies by 

model.)

4. Recalculate the temperature effects and damages expected in all years beyond t

resulting from this adjusted path of emissions, as in step 2. 

5. Subtract the damages computed in step 2 from those in step 4 in each year. 

(DICE is run in 10 year time steps, FUND in annual time steps, while the time 

steps in PAGE vary.)

6. Discount the resulting path of marginal damages back to the year of emissions 

using the agreed upon fixed discount rates.

7. Calculate the SCC as the net present value of the discounted path of damages 

computed in step 6, divided by the unit of carbon emissions used to shock the 

models in step 3. 

8. Multiply by 12/44 to convert from dollars per ton of carbon to dollars per ton of 

CO2 (2007 dollars) in DICE and FUND. (All calculations are done in tons of CO2 

in PAGE).

The steps above were repeated in each model for multiple future years to cover the time horizons 

anticipated for upcoming rulemaking analysis. To maintain consistency across the three IAMs, 

climate damages are calculated as lost consumption in each future year. 

It is important to note that each of the three models has a different default end year. The 

default time horizon is 2200 for PAGE, 2595 for DICE, and 3000 for the latest version of FUND. 

This is an issue for the multi-model approach because differences in SCC estimates may arise 

simply due to the model time horizon. Many consider 2200 too short a time horizon because it 

could miss a significant fraction of damages under certain assumptions about the growth of 

marginal damages and discounting, so each model is run here through 2300. This step required a 

small adjustment in the PAGE model only. This step also required assumptions about GDP, 

population, and greenhouse gas emission trajectories after 2100, the last year for which these 

data are available from the EMF-22 models. (A more detailed discussion of these assumptions is 

included in the Appendix.)
15-A-29

This exercise produces 45 separate distributions of the SCC for a given year, the product 

of 3 models, 3 discount rates, and 5 socioeconomic scenarios. This is clearly too many separate 

distributions for consideration in a regulatory impact analysis. 

To produce a range of plausible estimates that still reflects the uncertainty in the 

estimation exercise, the distributions from each of the models and scenarios are equally weighed 

and combined to produce three separate probability distributions for SCC in a given year, one for 

each assumed discount rate. These distributions are then used to define a range of point estimates 

for the global SCC. In this way, no integrated assessment model or socioeconomic scenario is 

given greater weight than another. Because the literature shows that the SCC is quite sensitive to 

assumptions about the discount rate, and because no consensus exists on the appropriate rate to 

use in an intergenerational context, we present SCCs based on the average values across models 

and socioeconomic scenarios for each discount rate. 

The interagency group selected four SCC values for use in regulatory analyses. Three 

values are based on the average SCC across models and socio-economic and emissions scenarios 

at the 2.5, 3, and 5 percent discount rates. The fourth value is included to represent the higherthan-expected economic impacts from climate change further out in the tails of the SCC 

distribution. For this purpose, we use the SCC value for the 95th percentile at a 3 percent discount 

rate. (The full set of distributions by model and scenario combination is included in the 

Appendix.) As noted above, the 3 percent discount rate is the central value, and so the central 

value that emerges is the average SCC across models at the 3 percent discount rate. For purposes 

of capturing the uncertainties involved in regulatory impact analysis, we emphasize the 

importance and value of considering the full range.

As previously discussed, low probability, high impact events are incorporated into the 

SCC values through explicit consideration of their effects in two of the three models as well as 

the use of a probability density function for equilibrium climate sensitivity. Treating climate 

sensitivity probabilistically results in more high temperature outcomes, which in turn lead to 

higher projections of damages. Although FUND does not include catastrophic damages (in 

contrast to the other two models), its probabilistic treatment of the equilibrium climate sensitivity 

parameter will directly affect the non-catastrophic damages that are a function of the rate of 

temperature change.

In Table 16A.5.1, we begin by presenting SCC estimates for 2010 by model, scenario, 

and discount rate to illustrate the variability in the SCC across each of these input parameters. 

As expected, higher discount rates consistently result in lower SCC values, while lower discount 

rates result in higher SCC values for each socioeconomic trajectory. It is also evident that there 

are differences in the SCC estimated across the three main models. For these estimates, FUND 

produces the lowest estimates, while PAGE generally produces the highest estimates. 
15-A-30

Table 15-A.5.1 Disaggregated Social Cost of CO2 Values by Model, Socio-Economic 

Trajectory, and Discount Rate for 2010 (in 2007 dollars)

Discount rate: 5% 3% 2.5% 3%

Model Scenario Avg Avg Avg 95th DICE

IMAGE 10.8 35.8 54.2 70.8

MERGE 7.5 22.0 31.6 42.1

Message 9.8 29.8 43.5 58.6

MiniCAM 8.6 28.8 44.4 57.9

550 Average 8.2 24.9 37.4 50.8

PAGE

IMAGE 8.3 39.5 65.5 142.4

MERGE 5.2 22.3 34.6 82.4

Message 7.2 30.3 49.2 115.6

MiniCAM 6.4 31.8 54.7 115.4

550 Average 5.5 25.4 42.9 104.7

FUND

IMAGE -1.3 8.2 19.3 39.7

MERGE -0.3 8.0 14.8 41.3

Message -1.9 3.6 8.8 32.1

MiniCAM -0.6 10.2 22.2 42.6

550 Average -2.7 -0.2 3.0 19.4

These results are not surprising when compared to the estimates in the literature for the 

latest versions of each model. For example, adjusting the values from the literature that were 

used to develop interim SCC values to 2007 dollars for the year 2010 (assuming, as we did for 

the interim process, that SCC grows at 3 percent per year), FUND yields SCC estimates at or 

near zero for a 5 percent discount rate and around $9 per ton for a 3 percent discount rate. There 

are far fewer estimates using the latest versions of DICE and PAGE in the literature: Using 

similar adjustments to generate 2010 estimates, we calculate a SCC from DICE (based on 

Nordhaus 2008) of around $9 per ton for a 5 percent discount rate, and a SCC from PAGE 

(based on Hope 2006, 2008) close to $8 per ton for a 4 percent discount rate. Note that these 

comparisons are only approximate since the literature generally relies on Ramsey discounting, 

while we have assumed constant discount rates.27

 27 Nordhaus (2008) runs DICE2007 with ρ = 1.5 and η = 2. The default approach in PAGE2002 (version 1.4epm) 

treats ρ and η as random parameters, specified using a triangular distribution such that the min, mode, and max = 

0.1, 1, and 2 for ρ, and 0.5, 1, and 2 for η, respectively. The FUND default value for η is 1, and Tol generates SCC 

estimates for values of ρ = 0, 1, and 3 in many recent papers (e.g. Anthoff et al. 2009). The path of per-capita 

consumption growth, g, varies over time but is treated deterministically in two of the three models. In DICE, g is 
15-A-31

The SCC estimates from FUND are sensitive to differences in emissions paths but 

relatively insensitive to differences in GDP paths across scenarios, while the reverse is true for 

DICE and PAGE. This likely occurs because of several structural differences among the models. 

Specifically in DICE and PAGE, the fraction of economic output lost due to climate damages 

increases with the level of temperature alone, whereas in FUND the fractional loss also increases 

with the rate of temperature change. Furthermore, in FUND increases in income over time 

decrease vulnerability to climate change (a form of adaptation), whereas this does not occur in 

DICE and PAGE. These structural differences among the models make FUND more sensitive to 

the path of emissions and less sensitive to GDP compared to DICE and PAGE. 

Figure 16A.5.2 shows that IMAGE has the highest GDP in 2100 while MERGE 

Optimistic has the lowest. The ordering of global GDP levels in 2100 directly corresponds to the 

rank ordering of SCC for PAGE and DICE. For FUND, the correspondence is less clear, a result 

that is to be expected given its less direct relationship between its damage function and GDP.

Figure 15-A.5.1 Level of Global GDP across EMF Scenarios

Table 16A.5.2 shows the four selected SCC values in five year increments from 2010 to 

2050. Values for 2010, 2020, 2040, and 2050 are calculated by first combining all outputs 

(10,000 estimates per model run) from all scenarios and models for a given discount rate. Values 

for the years in between are calculated using a simple linear interpolation.

 endogenous. Under Ramsey discounting, as economic growth slows in the future, the large damages from climate 

change that occur far out in the future are discounted at a lower rate than impacts that occur in the nearer term.

0

50

100

150

200

250

300

350

400

450

2000 2010 2020 2030 2050 2100

Global 

GDP

(trillions

of U.S. 

dollars)

IMAGE

MERGE Optimistic

MESSAGE

MiniCAM

3.7 W/m2 radiative forcing
15-A-32

Table 15-A.5.2 Social Cost of CO2, 2010 – 2050 (in 2007 dollars)

Discount 5% 3% 2.5% 3%

Year Avg Avg Avg 95th

2010 4.7 21.4 35.1 64.9

2015 5.7 23.8 38.4 72.8

2020 6.8 26.3 41.7 80.7

2025 8.2 29.6 45.9 90.4

2030 9.7 32.8 50.0 100.0

2035 11.2 36.0 54.2 109.7

2040 12.7 39.2 58.4 119.3

2045 14.2 42.1 61.7 127.8

2050 15.7 44.9 65.0 136.2

The SCC increases over time because future emissions are expected to produce larger 

incremental damages as physical and economic systems become more stressed in response to 

greater climatic change. Note that this approach allows us to estimate the growth rate of the SCC 

directly using DICE, PAGE, and FUND rather than assuming a constant annual growth rate as 

was done for the interim estimates (using 3 percent). This helps to ensure that the estimates are 

internally consistent with other modeling assumptions. Table 16A.5.3 illustrates how the growth 

rate for these four SCC estimates varies over time. The full set of annual SCC estimates between 

2010 and 2050 is reported in the Appendix.

Table 15-A.5.3 Changes in the Average Annual Growth Rates of SCC Estimates between 

2010 and 2050

Average Annual 

Growth Rate (%)

5% 3% 2.5% 3.0%

Avg Avg Avg 95th

2010-2020 3.6% 2.1% 1.7% 2.2%

2020-2030 3.7% 2.2% 1.8% 2.2%

2030-2040 2.7% 1.8% 1.6% 1.8%

2040-2050 2.1% 1.4% 1.1% 1.3%

While the SCC estimate grows over time, the future monetized value of emissions 

reductions in each year (the SCC in year t multiplied by the change in emissions in year t) must 

be discounted to the present to determine its total net present value for use in regulatory analysis. 

Damages from future emissions should be discounted at the same rate as that used to calculate 

the SCC estimates themselves to ensure internal consistency—i.e., future damages from climate 

change, whether they result from emissions today or emissions in a later year, should be 

discounted using the same rate. For example, climate damages in the year 2020 that are 
15-A-33

calculated using a SCC based on a 5 percent discount rate also should be discounted back to the 

analysis year using a 5 percent discount rate.28 

15-A.6 LIMITATIONS OF THE ANALYSIS

As noted, any estimate of the SCC must be taken as provisional and subject to further 

refinement (and possibly significant change) in accordance with evolving scientific, economic, 

and ethical understandings. During the course of our modeling, it became apparent that there are 

several areas in particular need of additional exploration and research. These caveats, and 

additional observations in the following section, are necessary to consider when interpreting and 

applying the SCC estimates.

Incomplete treatment of non-catastrophic damages. The impacts of climate change are 

expected to be widespread, diverse, and heterogeneous. In addition, the exact magnitude of these 

impacts is uncertain because of the inherent complexity of climate processes, the economic 

behavior of current and future populations, and our inability to accurately forecast technological 

change and adaptation. Current IAMs do not assign value to all of the important physical, 

ecological, and economic impacts of climate change recognized in the climate change literature 

(some of which are discussed above) because of lack of precise information on the nature of 

damages and because the science incorporated into these models understandably lags behind the 

most recent research. Our ability to quantify and monetize impacts will undoubtedly improve 

with time. But it is also likely that even in future applications, a number of potentially significant 

damage categories will remain non-monetized. (Ocean acidification is one example of a 

potentially large damage from CO2 emissions not quantified by any of the three models. Species 

and wildlife loss is another example that is exceedingly difficult to monetize.) 

Incomplete treatment of potential catastrophic damages. There has been considerable 

recent discussion of the risk of catastrophic impacts and how best to account for extreme 

scenarios, such as the collapse of the Atlantic Meridional Overturning Circulation or the West 

Antarctic Ice Sheet, or large releases of methane from melting permafrost and warming oceans. 

Weitzman (2009) suggests that catastrophic damages are extremely large—so large, in fact, that 

the damages from a low probability, catastrophic event far in the future dominate the effect of 

the discount rate in a present value calculation and result in an infinite willingness-to-pay for 

mitigation today. However, Nordhaus (2009) concluded that the conditions under which 

Weitzman's results hold “are limited and do not apply to a wide range of potential uncertain 

scenarios." 

Using a simplified IAM, Newbold and Daigneault (2009) confirmed the potential for 

large catastrophe risk premiums but also showed that the aggregate benefit estimates can be 

highly sensitive to the shapes of both the climate sensitivity distribution and the damage function 

at high temperature changes. Pindyck (2009) also used a simplified IAM to examine high-

 

28 However, it is possible that other benefits or costs of proposed regulations unrelated to CO2 emissions will be 

discounted at rates that differ from those used to develop the SCC estimates. 
15-A-34

impact low-probability risks, using a right-skewed gamma distribution for climate sensitivity as 

well as an uncertain damage coefficient, but in most cases found only a modest risk premium. 

Given this difference in opinion, further research in this area is needed before its practical 

significance can be fully understood and a reasonable approach developed to account for such 

risks in regulatory analysis. (The next section discusses the scientific evidence on catastrophic 

impacts in greater detail.)

Uncertainty in extrapolation of damages to high temperatures: The damage functions in 

these IAMs are typically calibrated by estimating damages at moderate temperature increases 

(e.g., DICE was calibrated at 2.5 °C) and extrapolated to far higher temperatures by assuming 

that damages increase as some power of the temperature change. Hence, estimated damages are 

far more uncertain under more extreme climate change scenarios. 

Incomplete treatment of adaptation and technological change: Each of the three 

integrated assessment models used here assumes a certain degree of low- or no-cost adaptation. 

For instance, Tol assumes a great deal of adaptation in FUND, including widespread reliance on 

air conditioning ; so much so, that the largest single benefit category in FUND is the reduced 

electricity costs from not having to run air conditioning as intensively (NRC 2009). 

Climate change also will increase returns on investment to develop technologies that 

allow individuals to cope with adverse climate conditions, and IAMs to do not adequately 

account for this directed technological change.29 For example, scientists may develop crops that 

are better able to withstand higher and more variable temperatures. Although DICE and FUND 

have both calibrated their agricultural sectors under the assumption that farmers will change land 

use practices in response to climate change (Mastrandrea, 2009), they do not take into account 

technological changes that lower the cost of this adaptation over time. On the other hand, the 

calibrations do not account for increases in climate variability, pests, or diseases, which could 

make adaptation more difficult than assumed by the IAMs for a given temperature change. 

Hence, models do not adequately account for potential adaptation or technical change that might 

alter the emissions pathway and resulting damages. In this respect, it is difficult to determine 

whether the incomplete treatment of adaptation and technological change in these IAMs under or 

overstate the likely damages.

Risk aversion: A key question unanswered during this interagency process is what to 

assume about relative risk aversion with regard to high-impact outcomes. These calculations do 

not take into account the possibility that individuals may have a higher willingness to pay to 

reduce the likelihood of low-probability, high-impact damages than they do to reduce the 

likelihood of higher-probability but lower-impact damages with the same expected cost. (The 

inclusion of the 95th percentile estimate in the final set of SCC values was largely motivated by 

this concern.) If individuals do show such a higher willingness to pay, a further question is 

whether that fact should be taken into account for regulatory policy. Even if individuals are not 

risk-averse for such scenarios, it is possible that regulatory policy should include a degree of 

risk-aversion.

 29 However these research dollars will be diverted from whatever their next best use would have been in the absence 

of climate change (so productivity/GDP would have been still higher).
15-A-35

Assuming a risk-neutral representative agent is consistent with OMB’s Circular A-4, 

which advises that the estimates of benefits and costs used in regulatory analysis are usually 

based on the average or the expected value and that “emphasis on these expected values is 

appropriate as long as society is ‘risk neutral’ with respect to the regulatory alternatives. While 

this may not always be the case, [analysts] should in general assume ‘risk neutrality’ in [their] 

analysis.” 

Nordhaus (2008) points to the need to explore the relationship between risk and income 

in the context of climate change across models and to explore the role of uncertainty regarding 

various parameters in the results. Using FUND, Anthoff et al (2009) explored the sensitivity of 

the SCC to Ramsey equation parameter assumptions based on observed behavior. They conclude 

that “the assumed rate of risk aversion is at least as important as the assumed rate of time 

preference in determining the social cost of carbon.” Since Circular A-4 allows for a different 

assumption on risk preference in regulatory analysis if it is adequately justified, we plan to 

continue investigating this issue.

15-A.7 A FURTHER DISCUSSION OF CATASTROPHIC IMPACTS AND 

DAMAGE FUNCTIONS

As noted above, the damage functions underlying the three IAMs used to estimate the 

SCC may not capture the economic effects of all possible adverse consequences of climate 

change and may therefore lead to underestimates of the SCC (Mastrandrea 2009). In particular, 

the models’ functional forms may not adequately capture: (1) potentially discontinuous “tipping 

point” behavior in Earth systems, (2) inter-sectoral and inter-regional interactions, including 

global security impacts of high-end warming, and (3) limited near-term substitutability between 

damage to natural systems and increased consumption. 

It is the hope of the interagency group that over time researchers and modelers will work 

to fill these gaps and that the SCC estimates used for regulatory analysis by the Federal 

government will continue to evolve with improvements in modeling. In the meantime, we 

discuss some of the available evidence.

Extrapolation of climate damages to high levels of warming

The damage functions in the models are calibrated at moderate levels of warming and 

should therefore be viewed cautiously when extrapolated to the high temperatures found in the 

upper end of the distribution. Recent science suggests that there are a number of potential 

climatic “tipping points” at which the Earth system may exhibit discontinuous behavior with 

potentially severe social and economic consequences (e.g., Lenton et al, 2008, Kriegler et al., 

2009). These tipping points include the disruption of the Indian Summer Monsoon, dieback of 

the Amazon Rainforest and boreal forests, collapse of the Greenland Ice Sheet and the West 

Antarctic Ice Sheet, reorganization of the Atlantic Meridional Overturning Circulation, 

strengthening of El Niño-Southern Oscillation, and the release of methane from melting 

permafrost. Many of these tipping points are estimated to have thresholds between about 3 °C 
15-A-36

and 5 °C (Lenton et al., 2008). Probabilities of several of these tipping points were assessed 

through expert elicitation in 2005–2006 by Kriegler et al. (2009); results from this study are 

highlighted in Table 16A.7.1. Ranges of probability are averaged across core experts on each 

topic.

As previously mentioned, FUND does not include potentially catastrophic effects. DICE 

assumes a small probability of catastrophic damages that increases with increased warming, but 

the damages from these risks are incorporated as expected values (i.e., ignoring potential risk 

aversion). PAGE models catastrophic impacts in a probabilistic framework (see Figure 16A.4.1), 

so the high-end output from PAGE potentially offers the best insight into the SCC if the world 

were to experience catastrophic climate change. For instance, at the 95th percentile and a 3 

percent discount rate, the SCC estimated by PAGE across the five socio-economic and emission 

trajectories of $113 per ton of CO2 is almost double the value estimated by DICE, $58 per ton in 

2010. We cannot evaluate how well the three models account for catastrophic or noncatastrophic impacts, but this estimate highlights the sensitivity of SCC values in the tails of the 

distribution to the assumptions made about catastrophic impacts. 

Table 15-A.7.1 Probabilities of Various Tipping Points from Expert Elicitation

Possible Tipping Points

Duration before

effect is fully

realized (in years)

Additional Warming by 2100

0.5-1.5 C 1.5-3.0 C 3-5 C

Reorganization of Atlantic Meridional 

Overturning Circulation about 100 0-18% 6-39% 18-67%

Greenland Ice Sheet collapse at least 300 8-39% 33-73% 67-96%

West Antarctic Ice Sheet collapse at least 300 5-41% 10-63% 33-88%

Dieback of Amazon rainforest about 50 2-46% 14-84% 41-94%

Strengthening of El Niño-Southern Oscillation about 100 1-13% 6-32% 19-49%

Dieback of boreal forests about 50 13-43% 20-81% 34-91%

Shift in Indian Summer Monsoon about 1 Not formally assessed

Release of methane from melting permafrost Less than 100 Not formally assessed.

PAGE treats the possibility of a catastrophic event probabilistically, while DICE treats it 

deterministically (that is, by adding the expected value of the damage from a catastrophe to the 

aggregate damage function). In part, this results in different probabilities being assigned to a 

catastrophic event across the two models. For instance, PAGE places a probability near zero on a 

catastrophe at 2.5 °C warming, while DICE assumes a 4 percent probability of a catastrophe at 

2.5 °C. By comparison, Kriegler et al. (2009) estimate a probability of at least 16-36 percent of 

crossing at least one of their primary climatic tipping points in a scenario with temperatures 

about 2-4 °C warmer than pre-Industrial levels in 2100. 
15-A-37

It is important to note that crossing a climatic tipping point will not necessarily lead to an 

economic catastrophe in the sense used in the IAMs. A tipping point is a critical threshold across 

which some aspect of the Earth system starts to shifts into a qualitatively different state (for 

instance, one with dramatically reduced ice sheet volumes and higher sea levels). In the IAMs, a 

catastrophe is a low-probability environmental change with high economic impact.

Failure to incorporate inter-sectoral and inter-regional interactions

The damage functions do not fully incorporate either inter-sectoral or inter-regional 

interactions. For instance, while damages to the agricultural sector are incorporated, the effects 

of changes in food supply on human health are not fully captured and depend on the modeler’s 

choice of studies used to calibrate the IAM. Likewise, the effects of climate damages in one 

region of the world on another region are not included in some of the models (FUND includes 

the effects of migration from sea level rise). These inter-regional interactions, though difficult to 

quantify, are the basis for climate-induced national and economic security concerns (e.g., 

Campbell et al., 2007; U.S. Department of Defense 2010) and are particularly worrisome at 

higher levels of warming. High-end warming scenarios, for instance, project water scarcity 

affecting 4.3-6.9 billion people by 2050, food scarcity affecting about 120 million additional 

people by 2080, and the creation of millions of climate refugees (Easterling et al., 2007; 

Campbell et al., 2007).

Imperfect substitutability of environmental amenities

Data from the geological record of past climate changes suggests that 6 °C of warming 

may have severe consequences for natural systems. For instance, during the Paleocene-Eocene 

Thermal Maximum about 55.5 million years ago, when the Earth experienced a geologically 

rapid release of carbon associated with an approximately 5 °C increase in global mean 

temperatures, the effects included shifts of about 400-900 miles in the range of plants (Wing et 

al., 2005), and dwarfing of both land mammals (Gingerich, 2006) and soil fauna (Smith et al., 

2009).

The three IAMs used here assume that it is possible to compensate for the economic 

consequences of damages to natural systems through increased consumption of non-climate 

goods, a common assumption in many economic models. In the context of climate change, 

however, it is possible that the damages to natural systems could become so great that no 

increase in consumption of non-climate goods would provide complete compensation (Levy et 

al., 2005). For instance, as water supplies become scarcer or ecosystems become more fragile 

and less bio-diverse, the services they provide may become increasingly more costly to replace. 

Uncalibrated attempts to incorporate the imperfect substitutability of such amenities into IAMs 

(Sterner and Persson, 2008) indicate that the optimal degree of emissions abatement can be 

considerably greater than is commonly recognized. 
15-A-38

15-A.8 CONCLUSION

The interagency group selected four SCC estimates for use in regulatory analyses. For 

2010, these estimates are $5, $21, $35, and $65 (in 2007 dollars). The first three estimates are 

based on the average SCC across models and socio-economic and emissions scenarios at the 5, 3, 

and 2.5 percent discount rates, respectively. The fourth value is included to represent the higherthan-expected impacts from temperature change further out in the tails of the SCC distribution. 

For this purpose, we use the SCC value for the 95th percentile at a 3 percent discount rate. The 

central value is the average SCC across models at the 3 percent discount rate. For purposes of 

capturing the uncertainties involved in regulatory impact analysis, we emphasize the importance 

and value of considering the full range. These SCC estimates also grow over time. For instance, 

the central value increases to $24 per ton of CO2 in 2015 and $26 per ton of CO2 in 2020.

We noted a number of limitations to this analysis, including the incomplete way in which 

the integrated assessment models capture catastrophic and non-catastrophic impacts, their 

incomplete treatment of adaptation and technological change, uncertainty in the extrapolation of 

damages to high temperatures, and assumptions regarding risk aversion. The limited amount of 

research linking climate impacts to economic damages makes this modeling exercise even more 

difficult. It is the hope of the interagency group that over time researchers and modelers will 

work to fill these gaps and that the SCC estimates used for regulatory analysis by the Federal 

government will continue to evolve with improvements in modeling. 
15-A-39

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15-A-44

15-A.9 ANNEX

Table 15-A.9.1 Annual SCC Values: 2010–2050 (in 2007 dollars)

Discount Rate 5% 3% 2.5% 3%

Year Avg Avg Avg 95th

2010 4.7 21.4 35.1 64.9

2011 4.9 21.9 35.7 66.5

2012 5.1 22.4 36.4 68.1

2013 5.3 22.8 37.0 69.6

2014 5.5 23.3 37.7 71.2

2015 5.7 23.8 38.4 72.8

2016 5.9 24.3 39.0 74.4

2017 6.1 24.8 39.7 76.0

2018 6.3 25.3 40.4 77.5

2019 6.5 25.8 41.0 79.1

2020 6.8 26.3 41.7 80.7

2021 7.1 27.0 42.5 82.6

2022 7.4 27.6 43.4 84.6

2023 7.7 28.3 44.2 86.5

2024 7.9 28.9 45.0 88.4

2025 8.2 29.6 45.9 90.4

2026 8.5 30.2 46.7 92.3

2027 8.8 30.9 47.5 94.2

2028 9.1 31.5 48.4 96.2

2029 9.4 32.1 49.2 98.1

2030 9.7 32.8 50.0 100.0

2031 10.0 33.4 50.9 102.0

2032 10.3 34.1 51.7 103.9

2033 10.6 34.7 52.5 105.8

2034 10.9 35.4 53.4 107.8

2035 11.2 36.0 54.2 109.7

2036 11.5 36.7 55.0 111.6

2037 11.8 37.3 55.9 113.6

2038 12.1 37.9 56.7 115.5

2039 12.4 38.6 57.5 117.4

2040 12.7 39.2 58.4 119.3

2041 13.0 39.8 59.0 121.0

2042 13.3 40.4 59.7 122.7

2043 13.6 40.9 60.4 124.4

2044 13.9 41.5 61.0 126.1

2045 14.2 42.1 61.7 127.8

2046 14.5 42.6 62.4 129.4

2047 14.8 43.2 63.0 131.1

2048 15.1 43.8 63.7 132.8

2049 15.4 44.4 64.4 134.5

2050 15.7 44.9 65.0 136.2

This Appendix also provides additional technical information about the non-CO2

emission projections used in the modeling and the method for extrapolating emissions forecasts 

through 2300, and shows the full distribution of 2010 SCC estimates by model and scenario 

combination. 
15-A-45

15-A.9.1 Other (non-CO2) gases

In addition to fossil and industrial CO2 emissions, each EMF scenario provides 

projections of methane (CH4), nitrous oxide (N2O), fluorinated gases, and net land use CO2

emissions to 2100. These assumptions are used in all three IAMs while retaining each model’s 

default radiative forcings (RF) due to other factors (e.g., aerosols and other gases). Specifically, 

to obtain the RF associated with the non-CO2 EMF emissions only, we calculated the RF 

associated with the EMF atmospheric CO2 concentrations and subtracted them from the EMF 

total RF.30 This approach respects the EMF scenarios as much as possible and at the same time 

takes account of those components not included in the EMF projections. Since each model treats 

non-CO2 gases differently (e.g., DICE lumps all other gases into one composite exogenous 

input), this approach was applied slightly differently in each of the models. 

FUND: Rather than relying on RF for these gases, the actual emissions from each 

scenario were used in FUND. The model default trajectories for CH4, N20, SF6, and the CO2

emissions from land were replaced with the EMF values. 

PAGE: PAGE models CO2, CH4, sulfur hexafluoride (SF6), and aerosols and contains an 

"excess forcing" vector that includes the RF for everything else. To include the EMF values, we 

removed the default CH4 and SF6 factors31, decomposed the excess forcing vector, and 

constructed a new excess forcing vector that includes the EMF RF for CH4, N20, and fluorinated 

gases, as well as the model default values for aerosols and other factors. Net land use CO2

emissions were added to the fossil and industrial CO2 emissions pathway. 

DICE: DICE presents the greatest challenge because all forcing due to factors other than 

industrial CO2 emissions is embedded in an exogenous non-CO2 RF vector. To decompose this 

exogenous forcing path into EMF non-CO2 gases and other gases, we relied on the references in 

DICE2007 to the Intergovernmental Panel on Climate Change’s (IPCC) Fourth Assessment 

Report (AR4) and the discussion of aerosol forecasts in the IPCC’s Third Assessment Report 

(TAR) and in AR4, as explained below. In DICE2007, Nordhaus assumes that exogenous 

forcing from all non-CO2 sources is -0.06 W/m2 in 2005, as reported in AR4, and increases 

linearly to 0.3 W/m2 in 2105, based on GISS projections, and then stays constant after that time.

According to AR4, the RF in 2005 from CH4, N20, and halocarbons (approximately 

similar to the F-gases in the EMF-22 scenarios) was 0.48 + 0.16 + 0.34 = 0.98 W/m2 and RF 

from total aerosols was -1.2 W/m2. Thus, the -.06 W/m2 non-CO2 forcing in DICE can be 

decomposed into: 0.98 W/m2 due to the EMF non-CO2 gases, -1.2 W/m2 due to aerosols, and the 

remainder, 0.16 W/m2, due to other residual forcing. 

 30 Note EMF did not provide CO2 concentrations for the IMAGE reference scenario. Thus, for this scenario, we fed 

the fossil, industrial and land CO2 emissions into MAGICC (considered a "neutral arbiter" model, which is tuned to 

emulate the major global climate models) and the resulting CO2 concentrations were used. Note also that MERGE 

assumes a neutral biosphere so net land CO2 emissions are set to zero for all years for the MERGE Optimistic 

reference scenario, and for the MERGE component of the average 550 scenario (i.e., we add up the land use 

emissions from the other three models and divide by 4).

31 Both the model default CH4 emissions and the initial atmospheric CH4 is set to zero to avoid double counting the 

effect of past CH4 emissions.
15-A-46

For subsequent years, we calculated the DICE default RF from aerosols and other nonCO2 gases based on the following two assumptions:

(1) RF from aerosols declines linearly from 2005 to 2100 at the rate projected by the TAR 

and then stays constant thereafter, and 

(2) With respect to RF from non-CO2 gases not included in the EMF-22 scenarios, the share 

of non-aerosol RF matches the share implicit in the AR4 summary statistics cited above and 

remains constant over time. 

Assumption (1) means that the RF from aerosols in 2100 equals 66 percent of that in 2000, 

which is the fraction of the TAR projection of total RF from aerosols (including sulfates, black 

carbon, and organic carbon) in 2100 vs. 2000 under the A1B SRES emissions scenario. Since 

the SRES marker scenarios were not updated for the AR4, the TAR provides the most recent 

IPCC projection of aerosol forcing. We rely on the A1B projection from the TAR because it 

provides one of the lower aerosol forecasts among the SRES marker scenarios and is more 

consistent with the AR4 discussion of the post-SRES literature on aerosols: 

Aerosols have a net cooling effect and the representation of aerosol and aerosol precursor 

emissions, including sulphur dioxide, black carbon and organic carbon, has improved in the 

post-SRES scenarios. Generally, these emissions are projected to be lower than reported in 

SRES. {WGIII 3.2, TS.3, SPM}.32

Assuming a simple linear decline in aerosols from 2000 to 2100 also is more consistent 

with the recent literature on these emissions. For example, Figure A1 shows that the sulfur 

dioxide emissions peak over the short-term of some SRES scenarios above the upper bound 

estimates of the more recent scenarios.33 Recent scenarios project sulfur emissions to peak 

earlier and at lower levels compared to the SRES in part because of new information about 

present and planned sulfur legislation in some developing countries, such as India and China.34 

The lower bound projections of the recent literature have also shifted downward slightly 

compared to the SRES scenario (IPCC 2007). 

With these assumptions, the DICE aerosol forcing changes from -1.2 in 2005 to -0.792 in 

2105 W/m2; forcing due to other non-CO2 gases not included in the EMF scenarios declines from 

0.160 to 0.153 W/m2. 

 32 AR4 Synthesis Report, p. 44, http://www.ipcc.ch/pdf/assessment-report/ar4/syr/ar4_syr.pdf

33 See Smith, S.J., R. Andres, E. Conception, and J. Lurz, 2004: Historical sulfur dioxide emissions, 1850-2000: 

methods and results. Joint Global Research Institute, College Park, 14 pp.

34 See Carmichael, G., D. Streets, G. Calori, M. Amann, M. Jacobson, J. Hansen, and H. Ueda, 2002: Changing 

trends in sulphur emissions in Asia: implications for acid deposition, air pollution, and climate. Environmental 

Science and Technology, 36(22):4707- 4713; Streets, D., K. Jiang, X. Hu, J. Sinton, X.-Q. Zhang, D. Xu, M. 

Jacobson, and J. Hansen, 2001: Recent reductions in China’s greenhouse gas emissions. Science, 294(5548): 1835-

1837.
15-A-47

.

Figure 15-A.9.2 Sulphur Dioxide Emission Scenarios

Notes: Thick colored lines depict the four SRES marker scenarios and black dashed lines 

show the median, 5th and 95th percentile of the frequency distribution for the full 

ensemble of 40 SRES scenarios. The blue area (and the thin dashed lines in blue) 

illustrates individual scenarios and the range of Smith et al. (2004). Dotted lines indicate 

the minimum and maximum of SO2 emissions scenarios developed pre-SRES.

Source: IPCC (2007), AR4 WGIII 3.2, 

http://www.ipcc.ch/publications_and_data/ar4/wg3/en/ch3-ens3-2-2-4.html.

Although other approaches to decomposing the DICE exogenous forcing vector are 

possible, initial sensitivity analysis suggests that the differences among reasonable alternative 

approaches are likely to be minor. For example, adjusting the TAR aerosol projection above to

assume that aerosols will be maintained at 2000 levels through 2100 reduces average SCC values 

(for 2010) by approximately 3 percent (or less than $2); assuming all aerosols are phased out by 

2100 increases average 2010 SCC values by 6-7 percent (or $0.50-$3)–depending on the 

discount rate. These differences increase slightly for SCC values in later years but are still well 

within 10 percent of each other as far out as 2050. 

Finally, as in PAGE, the EMF net land use CO2 emissions are added to the fossil and 

industrial CO2 emissions pathway. 

15-A.9.2 Extrapolating Emissions Projections to 2300

To run each model through 2300 requires assumptions about GDP, population, 

greenhouse gas emissions, and radiative forcing trajectories after 2100, the last year for which 

these projections are available from the EMF-22 models. These inputs were extrapolated from 

2100 to 2300 as follows:

1. Population growth rate declines linearly, reaching zero in the year 2200.

2. GDP/ per capita growth rate declines linearly, reaching zero in the year 2300.
15-A-48

3. The decline in the fossil and industrial carbon intensity (CO2/GDP) growth rate over 

2090-2100 is maintained from 2100 through 2300.

4. Net land use CO2 emissions decline linearly, reaching zero in the year 2200.

5. Non-CO2 radiative forcing remains constant after 2100.

Long run stabilization of GDP per capita was viewed as a more realistic simplifying 

assumption than a linear or exponential extrapolation of the pre-2100 economic growth rate of 

each EMF scenario. This is based on the idea that increasing scarcity of natural resources and 

the degradation of environmental sinks available for assimilating pollution from economic 

production activities may eventually overtake the rate of technological progress. Thus, the 

overall rate of economic growth may slow over the very long run. The interagency group also 

considered allowing an exponential decline in the growth rate of GDP per capita. However, 

since this would require an additional assumption about how close to zero the growth rate would 

get by 2300, the group opted for the simpler and more transparent linear extrapolation to zero by 

2300. 

The population growth rate is also assumed to decline linearly, reaching zero by 2200. 

This assumption is reasonably consistent with the United Nations long run population forecast, 

which estimates global population to be fairly stable after 2150 in the medium scenario (UN 

2004).35 The resulting range of EMF population trajectories (Figure A2) also encompass the 

UN medium scenario forecasts through 2300 – global population of 8.5 billion by 2200, and 9 

billion by 2300. 

Maintaining the decline in the 2090-2100 carbon intensity growth rate (i.e., CO2 per 

dollar of GDP) through 2300 assumes that technological improvements and innovations in the 

areas of energy efficiency and other carbon reducing technologies (possibly including currently 

unavailable methods) will continue to proceed at roughly the same pace that is projected to occur 

towards the end of the forecast period for each EMF scenario. This assumption implies that total 

cumulative emissions in 2300 will be between 5,000 and 12,000 GtC, which is within the range 

of the total potential global carbon stock estimated in the literature.

 

Net land use CO2 emissions are expected to stabilize in the long run, so in the absence of 

any post 2100 projections, the group assumed a linear decline to zero by 2200. Given no a priori 

reasons for assuming a long run increase or decline in non-CO2 radiative forcing, it is assumed to 

remain at the 2100 levels for each EMF scenario through 2300. 

Figures A2-A7 show the paths of global population, GDP, fossil and industrial CO2

emissions, net land CO2 emissions, non-CO2 radiative forcing, and CO2 intensity (fossil and 

industrial CO2 emissions/GDP) resulting from these assumptions. 

 35 United Nations. 2004. World Population to 2300. 

http://www.un.org/esa/population/publications/longrange2/worldpop2300final.pdf
15-A-49

Figure 15-A.9.3 Global Population, 2000-2300 (Post-2100 

extrapolations assume the population growth rate 

changes linearly to reach a zero growth rate by 

2200.)

Note: In the fifth scenario, 2000-2100 population is equal to the average of the population under 

the 550 ppm CO2e, full-participation, not-to-exceed scenarios considered by each of the four 

models. 

5.5

6.5

7.5

8.5

9.5

10.5

11.5

2000 2050 2100 2150 2200 2250 2300

IMAGE

MERGE

MESSAGE

MiniCAM

5th scenario

Extrapolations

Global Population [billion]

Year
15-A-50

Figure 15-A.9.4 World GDP, 2000-2300 (Post-2100 extrapolations 

assume GDP per capita growth declines linearly, 

reaching zero in the year 2300)

Note: In the fifth scenario, 2000-2100 GDP is equal to the average of the GDP under the 550 

ppm CO2e, full-participation, not-to-exceed scenarios considered by each of the four models. 

Figure 15-A.9.5 Global Fossil and Industrial CO2 Emissions, 2000-

2300 (Post-2100 extrapolations assume growth rate 

of CO2 intensity (CO2/GDP) over 2090-2100 is 

maintained through 2300.)

0

500

1000

1500

2000

2000 2050 2100 2150 2200 2250 2300

IMAGE

MERGE

MESSAGE

MiniCAM

5th scenario

Extrapolations

Year

World GDP [$trillion]

0

50

100

150

200

2000 2050 2100 2150 2200 2250 2300

IMAGE

MERGE

MESSAGE

MiniCAM

5th scenario

Extrapolations

Fossil&Industrial CO2 Emissions [GtCO2/decade]

Year
15-A-51

Note: In the fifth scenario, 2000-2100 emissions are equal to the average of the emissions under 

the 550 ppm CO2e, full-participation, not-to-exceed scenarios considered by each of the four 

models. 

Figure 15-A.9.6 Global Net Land Use CO2 Emissions, 2000-2300 

(Post-2100 extrapolations assume emissions decline 

linearly, reaching zero in the year 2200)

36

Note: In the fifth scenario, 2000-2100 emissions are equal to the average of the emissions under 

the 550 ppm CO2e, full-participation, not-to-exceed scenarios considered by each of the four 

models. 

 36 MERGE assumes a neutral biosphere so net land CO2 emissions are set to zero for all years for the MERGE 

Optimistic reference scenario, and for the MERGE component of the average 550 scenario (i.e., we add up the land 

use emissions from the other three models and divide by 4).

-3.00

-2.00

-1.00

0.00

1.00

2.00

3.00

4.00

2000 2050 2100 2150 2200 2250 2300

IMAGE

MERGE

MESSAGE

MiniCAM

5th scneario

Extrapolations

Net land CO2 emissions [GtCO2/yr]

Year

z
15-A-52

Figure 15-A.9.7 Global Non-CO2 Radiative Forcing, 2000-2300 

(Post-2100 extrapolations assume constant non-CO2

radiative forcing after 2100)

Note: In the fifth scenario, 2000-2100 emissions are equal to the average of the emissions under

the 550 ppm CO2e, full-participation, not-to-exceed scenarios considered by each of the four 

models. 

0.00

0.75

1.50

2.25

3.00

3.75

2000 2050 2100 2150 2200 2250 2300

IMAGE

MERGE

MESSAGE

MiniCAM

5th scenario

Extrapolations

nonCO2 RF [W/m^2]

Year
15-A-53

Figure 15-A.9.8 Global CO2 Intensity (fossil & industrial CO2

emissions/GDP), 2000-2300 (Post-2100 

extrapolations assume decline in CO2/GDP growth 

rate over 2090-2100 is maintained through 2300)

Note: In the fifth scenario, 2000-2100 emissions are equal to the average of the emissions under 

the 550 ppm CO2e, full-participation, not-to-exceed scenarios considered by each of the four 

models. 

0

0

0

0

0

1

1

1

1

2000 2050 2100 2150 2200 2250 2300

IMAGE

MERGE

MESSAGE

MiniCAM

5th scenario

Extrapolations

Fossil & Industrial CO2 intensity [GtCO2/trillion $]

Year
15-A-54

Table 15-A.9.2 2010 Global SCC Estimates at 2.5 Percent Discount Rate (2007$/ton CO2)

Percentile 1st 5th 10th 25th 50th Avg 75th 90th 95th 99th

Scenario PAGE

IMAGE 3.3 5.9 8.1 13.9 28.8 65.5 68.2 147.9 239.6 563.8

MERGE optimistic 1.9 3.2 4.3 7.2 14.6 34.6 36.2 79.8 124.8 288.3

Message 2.4 4.3 5.8 9.8 20.3 49.2 50.7 114.9 181.7 428.4

MiniCAM base 2.7 4.6 6.4 11.2 22.8 54.7 55.7 120.5 195.3 482.3

5th scenario 2.0 3.5 4.7 8.1 16.3 42.9 41.5 103.9 176.3 371.9

Scenario DICE

IMAGE 16.4 21.4 25 33.3 46.8 54.2 69.7 96.3 111.1 130.0

MERGE optimistic 9.7 12.6 14.9 19.7 27.9 31.6 40.7 54.5 63.5 73.3

Message 13.5 17.2 20.1 27 38.5 43.5 55.1 75.8 87.9 103.0

MiniCAM base 13.1 16.7 19.8 26.7 38.6 44.4 56.8 79.5 92.8 109.3

5th scenario 10.8 14 16.7 22.2 32 37.4 47.7 67.8 80.2 96.8

Scenario FUND

IMAGE -33.1 -18.9 -13.3 -5.5 4.1 19.3 18.7 43.5 67.1 150.7

MERGE optimistic -33.1 -14.8 -10 -3 5.9 14.8 20.4 43.9 65.4 132.9

Message -32.5 -19.8 -14.6 -7.2 1.5 8.8 13.8 33.7 52.3 119.2

MiniCAM base -31.0 -15.9 -10.7 -3.4 6 22.2 21 46.4 70.4 152.9

5th scenario -32.2 -21.6 -16.7 -9.7 -2.3 3 6.7 20.5 34.2 96.8
15-A-55

Table 15-A.9.3 Table A3. 2010 Global SCC Estimates at 3 Percent Discount Rate 

(2007$/ton CO2)

Percentile 1st 5th 10th 25th 50th Avg 75th 90th 95th 99th

Scenario PAGE

IMAGE 2.0 3.5 4.8 8.1 16.5 39.5 41.6 90.3 142.4 327.4

MERGE optimistic 1.2 2.1 2.8 4.6 9.3 22.3 22.8 51.3 82.4 190.0

Message 1.6 2.7 3.6 6.2 12.5 30.3 31 71.4 115.6 263.0

MiniCAM base 1.7 2.8 3.8 6.5 13.2 31.8 32.4 72.6 115.4 287.0

5th scenario 1.3 2.3 3.1 5 9.6 25.4 23.6 62.1 104.7 222.5

Scenario DICE

IMAGE 11.0 14.5 17.2 22.8 31.6 35.8 45.4 61.9 70.8 82.1

MERGE optimistic 7.1 9.2 10.8 14.3 19.9 22 27.9 36.9 42.1 48.8

Message 9.7 12.5 14.7 19 26.6 29.8 37.8 51.1 58.6 67.4

MiniCAM base 8.8 11.5 13.6 18 25.2 28.8 36.9 50.4 57.9 67.8

5th scenario 7.9 10.1 11.8 15.6 21.6 24.9 31.8 43.7 50.8 60.6

Scenario FUND

IMAGE -25.2 -15.3 -11.2 -5.6 0.9 8.2 10.4 25.4 39.7 90.3

MERGE optimistic -24.0 -12.4 -8.7 -3.6 2.6 8 12.2 27 41.3 85.3

Message -25.3 -16.2 -12.2 -6.8 -0.5 3.6 7.7 20.1 32.1 72.5

MiniCAM base -23.1 -12.9 -9.3 -4 2.4 10.2 12.2 27.7 42.6 93.0

5th scenario -24.1 -16.6 -13.2 -8.3 -3 -0.2 2.9 11.2 19.4 53.6
15-A-56

Table 15-A.9.4 2010 Global SCC Estimates at 5 Percent Discount Rate (2007$/ton CO2)

Percentile 1st 5th 10th 25th 50th Avg 75th 90th 95th 99th

Scenario PAGE

IMAGE 0.5 0.8 1.1 1.8 3.5 8.3 8.5 19.5 31.4 67.2

MERGE optimistic 0.3 0.5 0.7 1.2 2.3 5.2 5.4 12.3 19.5 42.4

Message 0.4 0.7 0.9 1.6 3 7.2 7.2 17 28.2 60.8

MiniCAM base 0.3 0.6 0.8 1.4 2.7 6.4 6.6 15.9 24.9 52.6

5th scenario 0.3 0.6 0.8 1.3 2.3 5.5 5 12.9 22 48.7

Scenario DICE

IMAGE 4.2 5.4 6.2 7.6 10 10.8 13.4 16.8 18.7 21.1

MERGE optimistic 2.9 3.7 4.2 5.3 7 7.5 9.3 11.7 12.9 14.4

Message 3.9 4.9 5.5 7 9.2 9.8 12.2 15.4 17.1 18.8

MiniCAM base 3.4 4.2 4.7 6 7.9 8.6 10.7 13.5 15.1 16.9

5th scenario 3.2 4 4.6 5.7 7.6 8.2 10.2 12.8 14.3 16.0

Scenario FUND

IMAGE -11.7 -8.4 -6.9 -4.6 -2.2 -1.3 0.7 4.1 7.4 17.4

MERGE optimistic -10.6 -7.1 -5.6 -3.6 -1.3 -0.3 1.6 5.4 9.1 19.0

Message -12.2 -8.9 -7.3 -4.9 -2.5 -1.9 0.3 3.5 6.5 15.6

MiniCAM base -10.4 -7.2 -5.8 -3.8 -1.5 -0.6 1.3 4.8 8.2 18.0

5th scenario -10.9 -8.3 -7 -5 -2.9 -2.7 -0.8 1.4 3.2 9.2

Figure 15-A.9.9 Histogram of Global SCC Estimates in 2010 

(2007$/ton CO2), by discount rate 

* The distribution of SCC values ranges from -$5,192 to $66,116 but the X-axis has been 

truncated at approximately the 1st and 99th percentiles to better show the data.

0

2000

4000

6000

8000

10000

12000

14000

16000

-25-12

1

14274053667992

105118131144157170183196209222235248261274

All 2010, 5.0% All 2010, 3.0% All 2010, 2.5%
15-15-A-57

Table 15-A.9.5 Additional Summary Statistics of 2010 Global SCC Estimates 

Discount 5% 3% 2.5%

Scenario Mea Varianc Skewnes Kurtosi Mea Varianc Skewnes Kurtosi Mea Variance Skewnes Kurtosi

DICE 9.0 13.1 0.8 0.2 28.3 209.8 1.1 0.9 42.2 534.9 1.2 1.1

PAGE 6.5 136.0 6.3 72.4 29.8 3,383.7 8.6 151.0 49.3 9,546.0 8.7 143.8

FUND -1.3 70.1 28.2 1,479.0 6.0 16,382.

5

128.0 18,976.

5

13.6 150,732.

6

149.0 23,558.

3
16-A-i

APPENDIX 16-A. REGULATORY IMPACT ANALYSIS: SUPPORTING 

MATERIALS

TABLE OF CONTENTS

16-A.1 INTRODUCTION ............................................................................................16-A-1

16-A.2 NIA-RIA INTEGRATED MODEL..................................................................16-A-1

16-A.3 CONSUMER REBATE POLICY MARKET PENETRATION CURVES.....16-A-2

16-A.3.1 Introduction.......................................................................................................16-A-2

16-A.3.2 Adjustment of XENERGY Penetration Curves................................................16-A-3

16-A.3.3 Interpolation of Penetration Curves..................................................................16-A-4

16-A.3.3.1 Market Implementation Rate Function and Curves.....................16-A-5

16-A.3.3.2 Calibrating the Market Implementation Rate Function ...............16-A-8

16-A.3.3.3 Limits to the Interpolation Approach.........................................16-A-10

16-A.3.4 Interpolated Penetration Curves for Standard-Size Freezers, Compact 

Refrigeration Products, and Built-in Refrigeration Products..........................16-A-11

16-A.4 MARKET SHARE ANNUAL INCREASES BY POLICY...........................16-A-16

16-A.5 UTILITY REBATE PROGRAMS.................................................................16-A-19

16-A.5.1 Rebate Programs for Standard-Size Refrigerator-Freezers and Compact 

Refrigerator-Freezers......................................................................................16-A-19

16-A.5.2 Rebate Programs for Standard-Size Freezers and Compact Freezers.............16-A-26

16-A.6 FEDERAL AND STATE TAX CREDITS ....................................................16-A-30

16-A.6.1 Federal Tax Credits for Consumers of Residential Appliances......................16-A-30

16-A.6.2 Federal Tax Credits for Manufacturers...........................................................16-A-31

16-A.6.3 State Tax Credits.............................................................................................16-A-31

LIST OF TABLES

Table 16-A.3.1 Parameter Values for Reference Curves..................................................16-A-6

Table 16-A.3.2 Correspondence between Discrete and Continuous Values of Market 

Barrier Levels...........................................................................................16-A-8

Table 16-A.3.3 Coefficients of Continuous-value Functions of max, mid, fit and r.........16-A-9

Table 16-A.4.1 Annual Increases in Market Shares Attributable to Rebate and Tax 

Credit Policies for Refrigeration Products.............................................16-A-17

Table 16-A.4.2 Annual Increases in Market Shares Attributable to Voluntary Energy 

Efficiency Targets, Early Replacement, and Bulk Government 

Purchases Policies for Refrigeration Products.......................................16-A-18

Table 16-A.5.1 Rebates for Standard-Size and Compact Refrigerator-Freezers............16-A-20

Table 16-A.5.2 Rebates for Standard-Size and Compact Freezers.................................16-A-27

LIST OF FIGURES

Figure 16-A.3.1 S-Curves Showing Effects of External and Internal Sources on 

Adoption of New Technologies...............................................................16-A-3
16-A-ii

Figure 16-A.3.2 Market Implementation Curves for Five Market Barriers Reference 

Levels.......................................................................................................16-A-5

Figure 16-A.3.3 Discrete-value Functions of Parameters Driving Implementation Curve 

Shape........................................................................................................16-A-7

Figure 16-A.3.4 Continuous-value Functions of Parameters Driving Implementation 

Curve Shape ...........................................................................................16-A-10

Figure 16-A.3.5 Market Penetration Curve for Upright Freezers ....................................16-A-12

Figure 16-A.3.6 Market Penetration Curve for Chest Freezers........................................16-A-12

Figure 16-A.3.7 Market Penetration Curve for Compact Refrigerators (PC11) ..............16-A-12

Figure 16-A.3.8 Market Penetration Curve for Compact Refrigerators (PC13 & PC14) 16-A-13

Figure 16-A.3.9 Market Penetration Curve for Compact Freezers ..................................16-A-13

Figure 16-A.3.10 Market Penetration Curve for Built-in All Refrigerators.......................16-A-14

Figure 16-A.3.11 Market Penetration Curve for Built-in Bottom-Mount RefrigeratorFreezers..................................................................................................16-A-14

Figure 16-A.3.12 Market Penetration Curve for Built-in Side-by-Side RefrigeratorFreezers..................................................................................................16-A-15

Figure 16-A.3.13 Market Penetration Curve for Built-in Upright Freezer ........................16-A-15
16-A-1

APPENDIX 16-A. REGULATORY IMPACT ANALYSIS: SUPPORTING 

MATERIALS

16-A.1 INTRODUCTION

This appendix contains sections discussing the following topics:

• NIA-RIA Integrated Models

• XENERGY penetration curves used to analyze consumer rebates, including:

o Background material,

o DOE’s adjustment of these curves for this analysis,

o DOE’s new method for interpolating the curves, and 

o Presentation of the interpolated curves by product class

• Projections of annual market share increases for the six alternative policies

• Detailed tables of rebates offered for the considered products

• Background material on Federal and state tax credits for appliances

16-A.2 NIA-RIA INTEGRATED MODEL

For this analysis, DOE developed an integrated NIA-RIAa model approach that built on 

the NIA models discussed in Chapter 10 and documented in Appendix 10-A.The resulting four 

NIA-RIA models (one for each product group)b

 

a NIA = national impact analysis; RIA = regulatory impact analysis

featured both the NIA analysis inputs and results 

and the RIA inputs with capability to generate results for each of the RIA policies. A separate 

module produced summaries of inputs for the rebate policy, generated their penetration curves 

(discussed in section 16-A.3.3 below), reported shipment and market share increase data by 

product class, and produced summary tables for the national energy savings and net present 

value results reported in chapter 16, sections 16.4 and 16.5. This module also generated tables of 

market share increases for each policy reported in section 16-A.4 of this Appendix.

b The four product groups are Standard-Size Refrigerator-Freezers, Standard-Size Freezers, Compact Refrigeration 

Products, and Built-in Refrigeration Products.
16-A-2

16-A.3 CONSUMER REBATE POLICY MARKET PENETRATION CURVES

This section first discusses the theoretical basis for the market penetration curves that 

DOE used to analyze the Consumer Rebates policy. Next it discusses the adjustments it made to 

the maximum penetration rates. It then presents the method it developed to create interpolated 

penetration curves for each specific product class and efficiency level in the analysis. Examples 

of the resulting curves for standard-size refrigerator-freezer product classes are in the chapter’s 

section 16.3.2.1. The curves for the product classes in the remaining product groups -- standardsize freezers, compact refrigeration products, and built-in refrigeration products -- are in section 

16-A.3.4 below.

16-A.3.1 Introduction

XENERGY, Inc.c

, developed a re-parameterized, mixed-source information diffusion 

model to estimate market impacts induced by financial incentives for purchasing energy efficient 

appliances.1 The basic premise of the mixed-source model is that information diffusion drives the

adoption of technology. 

Extensive economic literature describes the diffusion of new products as technologies 

evolve. Some research focuses primarily on developing analytical models of diffusion patterns 

applicable to individual consumers or to technologies from competing firms.2, 3, 4 One study 

records researchers’ attempts to investigate the factors that drive diffusion processes.5 Because a 

new product generally has its own distinct characteristics, few studies have been able 

conclusively to conclusively develop a universally applicable model. Some key findings, 

however, generally are accepted in academia and industry. 

One accepted finding is that, regardless of their economic benefits and technological 

merits, new technologies are unlikely to be adopted by all potential users. For many products, a 

ceiling must be placed on the adoption rate. A second conclusion is that not all adopters purchase 

new products at the same time: some act quickly after a new product is introduced; others wait 

for the product to mature. Third, diffusion processes can be characterized approximately by 

asymmetric S-curves that depict three stages of diffusion: starting, accelerating, and decreasing 

(as the adoption ceiling is approached).

A so-called epidemic model of diffusion is used widely in marketing and social studies. 

The epidemic model assumes that (1) all consumers place identical value on the benefits of a 

new product, and (2) the cost of a new product is constant or declines monotonically over time. 

What induces a consumer to purchase a new product is information about the availability and 

benefits of the product. In other words, information diffusion drives consumers’ adoption of a 

new product.3 The model incorporates information diffusion from both internal sources (spread 

by word of mouth from early adopters to prospective adopters) and external sources (the 

“announcement effect” produced by government agencies, institutions, or commercial 

 

c XENERGY is now owned by KEMA, Inc. (www.kema.com)
16-A-3

advertising). The model incorporates both internal and external sources by combining a logistic 

function with an exponential function.4, 5

The relative degree of influence from the internal and external sources determines the 

general shape of the diffusion curve for a specific product.4, 5 If adoption of a product is 

influenced primarily by external sources of information (the announcement effect), for instance, 

a high rate of diffusion occurs at the beginning of the process. In this scenario, external sources 

provide immediate information exposure to a significant number of prospective adopters. In 

contrast, internal sources (such as a network of prospective adopters) are relatively small in size 

and reach, producing a more gradual exposure to prospective adopters. Graphically speaking, 

information diffusion dominated by external sources is represented by a concave curve (the 

exponential curve in Figure 16-A.3.1). If adoption of a new product is influenced most strongly 

by internal sources of information, the number of adopters increases gradually, forming a convex 

curve (the logistic curve in Figure 16-A.3.1).

Figure 16-A.3.1 S-Curves Showing Effects of External and Internal Sources on 

Adoption of New Technologies

16-A.3.2 Adjustment of XENERGY Penetration Curves

In consultation with the primary authors of the 2002 XENERGY study who later 

conducted similar California studies, DOE made some adjustments to XENERGY’s original 
16-A-4

implementation (penetration) curves.6 The experiences with utility programs since the 

XENERGY study indicate that incentive programs have difficulty achieving penetration rates as 

high as 80 percent. Consumer response is limited by barriers created by consumer utility issues 

and other non-economic factors. DOE therefore adjusted the maximum penetration parameters 

for some of the curves from 80 percent to the following levels:

Moderate Barriers: 70%

High Barriers: 60%

Extremely High Barriers: 50%

The low barriers and no barriers curves (the latter used only when a product has a very 

high base-case-market share) remained, respectively, with 80 percent and 100 percent as their

maximum penetration rates. For the interpolated penetration curves (discussed below), DOE set 

the no barriers and extremely high barriers curves as the upper and lower bounds, respectively, 

for any benefit/cost ratio points higher or lower than the curves. It set another constraint such 

that the policy case market share cannot be great than 100 percent, as might occur for products 

with high base case market shares of the target-level technology.

16-A.3.3 Interpolation of Penetration Curves

As discussed above, the XENERGY penetration (implementation) curves followed a 

functional form to estimate the market implementation rate caused by energy efficiency 

measures such as consumer rebates.

d The XENERGY report presents five reference market 

implementation curves that vary according to the level of market barriers to technology 

penetration.1 Such curves have been used by DOE in the Regulatory Impact Analyses for 

rulemakings for appliance energy efficiency standards to estimate market share increases in

response to rebate programs.e They provide a framework for evaluating technology penetration, 

yet require matching the studied market to the curve that best represents it. This approximate 

matching can introduce some inaccuracy to the analysis.

This section presents an alternative approach to such evaluation: a method to estimate market 

implementation rates more accurately by performing interpolations of the reference curves. The 

following describes the market implementation rate function and the reference curves; the

method to calibrate the function to a given market; and the limitations of the method. 

 

d The RIA chapter refers to these curves as penetration curves. This section, in references to the original source, uses 

the term implementation curve.

e DOE has also used this method to estimate market share increases resulting from consumer tax credit and 

manufacturer tax credit programs, since the effects of tax credits on markets can be considered proportional to the 

rebate impacts. 
16-A-5

16-A.3.3.1 Market Implementation Rate Function and Curves

The XENERGY curves employ the following functional form to estimate the percentage of 

the informed marketf that will accept each energy-efficiency measure based on the participant’s 

benefit/cost ratio: 

[1]

where:

imp implementation rate

bc benefit/cost ratio

max maximum annual acceptance rate for the technology

mid inflection point of the curve

fit parameter that determines the general shape (slope) of the curve.

In recent efficiency standards rulemakings, DOE has been adopting a slightly different 

functional form of Equation [1], where the constant value 1/4 is replaced by a parameter r. By 

introducing this parameter in Equation [1] and rewriting it without the exponential and 

logarithmic operators, the market implementation rate of rebate programs can be evaluated using

the following equation:

[2]

In XENERGY’s report, Equation [1] is used to generate five primary (reference) curves. 

These curves produce initial theoretical results that are calibrated to actual measure 

implementation results associated with the first year of major utility energy efficiency programs. 

Different curves, generated using distinct values of the parameters max, mid, fit and r, reflect 

different levels of market barriers for different efficiency measures. 

DOE has been using similar curves in the appliance efficiency standards rulemaking. The 

curves characterize market implementation rates for five reference levels of market barriers: No 

Barriers, Low Barriers, Moderate Barriers, High Barriers, and Extremely High Barriers. Figure 

16-A.3.2 presents the five reference curves. 

Figure 16-A.3.2 Market Implementation Curves for Five Market Barriers 

Reference Levels

 

f The informed market refers to the portion of the market aware and informed about the energy efficiency measure.
16-A-6

No Barriers

Low Barriers

Moderate 

Barriers

High Barriers

Extremely High 

Barriers

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1.0

0 20 40 60 80 100

implementation rate

benefit-cost ratio

They build on the following functional form:

[3]

where:

 bd = [barrier type]

and maxd(bd), midd(bd), fitd(bd) and rd(bd) are as shown in Table 16-A.3.1. The four 

parameters are also presented in Figure 16-A.3.3 as discrete-value functions.

Table 16-A.3.1 Parameter Values for Reference Curves

Market Barriers Level

No Barriers Low Barriers Moderate 

Barriers High Barriers Extremely High Barriers
16-A-7

maxd 1.0 0.8 0.7g 0.6g 0.5

midd 10 2 0.3 0.1 0.04

fitd 1 1.7 1.7 1.7 1.7

rd 1 0.5 0.25 0.25 0.25

0.0

0.2

0.4

0.6

0.8

1.0

1.2

No Low Moderate High X-High

Max

0.0

2.0

4.0

6.0

8.0

10.0

12.0

No Low Moderate High X-High

Mid

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

1.6

1.8

2.0

No Low Moderate High X-High

Fit

0.0

0.2

0.4

0.6

0.8

1.0

1.2

No Low Moderate High X-High

r

Figure 16-A.3.3 Discrete-value Functions of Parameters Driving Implementation 

Curve Shape

To estimate the barrier level of a given market, in the past DOE sought the reference 

curve that most closely represented the pair (base case market share, benefit/cost ratio) of the 

technology corresponding to the mandatory standard’s chosen efficiency level. It then estimated 

the effect of a rebate program on the technology market penetration using that curve. For this 

estimation, DOE calculated the increase in market share that an increase in the benefit/cost ratio 

– driven by a rebate program – would produce. It then assumed that the relative increase in 

market share calculated from the reference curve was a proxy to the effects of a rebate program 

on the studied market.

 

g DOE adopted these parameters after consultation with the implementation curve authors. For the RIAs for the 

rulemakings for Cooking Products and Commercial Clothes Washers the max value adopted for the moderate 

barriers and high barriers market barrier levels was 0.5. RIAs developed during prior rulemakings for Furnaces and 

Boilers, Commercial Unitary Air Conditioners and Heat Pumps, and Distribution Transformers adopted a max value 

of 0.8 for all but the no barriers curve, based on the original penetration curve values from XENERGY’s report. 
16-A-8

16-A.3.3.2 Calibrating the Market Implementation Rate Function

The procedure previously described lacks accuracy when the studied market penetration 

point based on the actual benefit/cost ratio does not lie close to one of the reference curves. This 

section presents an interpolation approach to eliminate such inaccuracy. The interpolation 

process provides intermediate, continuous values for the four parameters (max, mid, fit and r) 

driving the market implementation curves. These intermediate values are obtained after linear 

interpolation of their corresponding reference values. 

The four parameters (max, mid, fit and r) were previously defined as discrete-value functions 

(maxd(bd), midd(bd), fitd(bd) and rd(bd)) of the market barriers level (Table 16-A.3.1, Figure 16-

A.3.2). To facilitate the interpolation, it is necessary to transform the four discrete-value 

functions into continuous functions, the latter being thus capable of associating each of the four 

parameters to a real number denoting the market barrier level (bc∈R). A numeric, continuous 

scale for the market barriers level is proposed, ranging from 0 to 5 (bc∈[0,5]).The 

correspondence between the discrete-values of market barrier levels and bc are shown in Table 

16-A.3.2.

Based on the continuous-value market barriers level, the parameters max, mid, fit and r are 

interpolated using the following functions:

[4]

[5]

[6]

[7]

where and are given by Table 16-A.3.3.

The continuous-value functions defined for max, mid, fit and r, as expressed by Equations 

[4]-[7], are then substituted in Equation [3], leading to the following functional form for the 

market implementation rate of rebate programs:

[8]

Table 16-A.3.2 Correspondence between Discrete and Continuous Values of Market 

Barrier Levels

Market Barriers Level

No 

Barriers

Low 

Barriers

Moderate 

Barriers

High 

Barriers

Extremely 

High 

Barriers
16-A-9

bc 0.0 1.0 2.5 4.0 5.0

Table 16-A.3.3 Coefficients of Continuous-value Functions of max, mid, fit and r

Market Barriers Level Intervals

No-Low 

Barriers

Low-Moderate 

Barriers

Moderate-High

Barriers

High-Extremely 

High Barriers

b∈[0,1] b∈[1,2.5] b∈[2.5,4] b∈[4,5]

max

-0.200 -0.075 -0.075 -0.075

1.000 0.875 0.875 0.875

mid

-8.000 -1.133 -0.133 -0.060

10.000 3.133 0.633 0.340

fit

0.700 0.000 0.000 0.000

1.000 1.700 1.700 1.700

r

-0.500 -0.167 0.000 0.000

1.000 0.667 0.250 0.250

Figure 16-A.3.4 presents the four continuous-value functions.

0.0

0.2

0.4

0.6

0.8

1.0

1.2

0 1 2 3 4 5

Max

0

2

4

6

8

10

12

0 1 2 3 4 5

Mid
16-A-10

1.0

1.2

1.4

1.6

1.8

2.0

0 1 2 3 4 5

Fit

0.0

0.2

0.4

0.6

0.8

1.0

1.2

0 1 2 3 4 5

r

Figure 16-A.3.4 Continuous-value Functions of Parameters Driving 

Implementation Curve Shape

Hence, estimating the market effects of a rebate program relies on finding the interpolated

implementation curve that best represents the studied market. In other words, it involves finding 

bc such that the pair (imp(bc,bc), bc) equals the pair (base case market share, benefit/cost ratio) 

of the technology corresponding to the mandatory standard’s efficiency level. Once the 

appropriate value of bc is found (e.g. ), the market penetration of the technology under a 

rebate program can be calculated by the following equation:

[9]

where:

market barriers level corresponding to the studied market

benefit/cost ratio with rebate.

16-A.3.3.3 Limits to the Interpolation Approach

The approach presented above increases the accuracy of the estimate of the market 

implementation rate resulting from a rebate program. Consequently, it improves the analysis of 

the market effects of rebate programs. However, whereas it is feasible to develop interpolated 

implementation curves between the reference ones, there is no empirical support to extrapolate 

them beyond the No Barriers and the Extremely High Barriers curves. In fact, the theoretical 

boundaries for the market barriers level would be:

(a) Zero Barriers (b0): With the assumption of the rational consumer, a tiny increase in the 

benefit/cost ratio of a technology with that ratio greater than 1 would be sufficient to make the 

technology widely adopted.h This would result in the following implementation rate function:

 

h When the benefit/cost ratio is 1 the participant is indifferent to adopting the technology or not, and the

implementation rate, in this case, would be undetermined.
16-A-11

(b) Infinite Barriers (b∞): In this case, even an extremely high benefit/cost ratio would not be 

sufficient to cause the market to adopt a technology. This would result in the following 

implementation rate function: 

However, notwithstanding the existence of such theoretical boundaries, the analysis of 

market implementation rates in cases of markets where the base case market share is either 

higher than the market share in the No Barriers curve (for the corresponding benefit/cost ratio), 

or lower than the one in the Extremely High Barriers curve (idem), should follow the former 

analysis approach (as described at the end of section 16-A.3.3.2). It should rely, respectively, on 

the No Barriers or the Extremely High Barriers curves to estimate a relative market increase due 

to the rebate program.

16-A.3.4 Interpolated Penetration Curves for Standard-Size Freezers, Compact 

Refrigeration Products, and Built-in Refrigeration Products

Figures 16-A.3.5 through 16-A.3.13 show the interpolated penetration curves for the 

product classes in the product groups of Standard-Size Freezers, Compact Refrigeration 

Products, and Built-in Refrigeration Products. Chapter 16, Figures 16.3.1 through 16.3.3 show 

the interpolated penetration curves for the product classes of Standard-Size RefrigeratorFreezers. 
16-A-12

Figure 16-A.3.5 Market Penetration Curve for Upright Freezers

Figure 16-A.3.6 Market Penetration Curve for Chest Freezers

Figure 16-A.3.7 Market Penetration Curve for Compact Refrigerators (PC11) 
16-A-13

Figure 16-A.3.8 Market Penetration Curve for Compact Refrigerators (PC13 & 

PC14) 

Figure 16-A.3.9 Market Penetration Curve for Compact Freezers 
16-A-14

Figure 16-A.3.10 Market Penetration Curve for Built-in All Refrigerators

Figure 16-A.3.11 Market Penetration Curve for Built-in Bottom-Mount 

Refrigerator-Freezers
16-A-15

Figure 16-A.3.12 Market Penetration Curve for Built-in Side-by-Side RefrigeratorFreezers

Figure 16-A.3.13 Market Penetration Curve for Built-in Upright Freezer
16-A-16

16-A.4 MARKET SHARE ANNUAL INCREASES BY POLICY

For the consumer rebate, consumer tax credit, and manufacturer tax credit policies, Table 

16-A.4.1 shows the annual increases in market shares for refrigeration products meeting target 

efficiency levels. DOE used these market share increases as inputs to the NIA-RIA spreadsheet 

model.
16-A-17

Table 16-A.4.1 Annual Increases in Market Shares Attributable to Rebate and Tax 

Credit Policies for Refrigeration Products

Year

Consumer

Rebates

Consumer

Tax Credits

Manufacturer

Tax Credits

StdSize 

R/F

%

StdSize 

Frz

%

Compact

%

Builtin %

StdSize 

R/F %

StdSize 

Frz

%

Compact

%

Builtin %

StdSize 

R/F

%

StdSize 

Frz

%

Compact 

%

Builtin %

2014 18.3 43.3 42.6 6.6 10.5 26.0 25.6 3.9 4.9 12.9 12.8 2.0

2015 18.2 43.3 42.6 6.6 10.5 26.0 25.6 3.9 4.9 12.9 12.8 2.0

2016 18.0 43.4 42.6 6.6 10.4 26.0 25.6 3.9 4.9 12.9 12.8 2.0

2017 17.8 43.4 42.6 6.6 10.4 26.0 25.6 3.9 4.8 12.9 12.8 2.0

2018 17.6 43.4 42.7 6.6 10.3 26.0 25.6 3.9 4.8 12.9 12.8 2.0

2019 17.4 43.4 42.7 6.6 10.3 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2020 17.2 43.4 42.7 6.6 10.3 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2021 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2022 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2023 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2024 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2025 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2026 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2027 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2028 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2029 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2030 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2031 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2032 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2033 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2034 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2035 16.9 43.4 42.7 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2036 16.9 43.4 42.8 6.6 10.2 26.0 25.6 4.0 4.8 12.9 12.8 2.0

2037 16.9 43.4 42.8 6.6 10.2 26.0 25.7 4.0 4.8 12.9 12.8 2.0

2038 16.9 43.4 42.8 6.6 10.2 26.0 25.7 4.0 4.8 12.9 12.8 2.0

2039 16.9 43.4 42.8 6.6 10.2 26.0 25.7 4.0 4.8 12.9 12.8 2.0

2040 16.9 43.4 42.8 6.6 10.2 26.0 25.7 4.0 4.8 12.9 12.8 2.0

2041 16.9 43.4 42.8 6.6 10.2 26.0 25.7 4.0 4.8 12.9 12.8 2.0

2042 16.9 43.4 42.8 6.6 10.2 26.0 25.7 4.0 4.8 12.9 12.8 2.0

2043 16.9 43.4 42.8 6.6 10.2 26.0 25.7 4.0 4.8 12.9 12.8 2.0

For the voluntary efficiency targets, early replacement and bulk government purchases 

policies, Table 16-A.4.2 shows the annual increases in market shares for refrigeration products 

meeting target efficiency levels. DOE did not consider the voluntary efficiency targets policy for 

compact refrigeration products nor for built-in refrigeration products. It did not consider the bulk 

government purchases policy for standard-size freezers nor for built-in refrigeration products.

DOE used these market share increases as inputs to the NIA-RIA spreadsheet model.
16-A-18

Table 16-A.4.2 Annual Increases in Market Shares Attributable to Voluntary Energy 

Efficiency Targets, Early Replacement, and Bulk Government Purchases 

Policies for Refrigeration Products

Year

Voluntary Energy Efficiency 

Targets Early Replacement Bulk Government Purchases

StdSize 

R/F

%

StdSize 

Frz

%

Compact 

%

Builtin %

StdSize 

R/F %

StdSize 

Frz

%

Compact

%

Builtin %

StdSize 

R/F

%

StdSize 

Frz

%

Compact 

%

Builtin %

2014 1.5 4.2 1.6 1.7 3.2 1.2 0.0 0.4

2015 1.8 4.5 1.2 1.5 2.2 1.0 0.0 0.9

2016 2.1 4.8 1.0 1.4 1.3 0.9 0.1 1.5

2017 2.4 5.1 0.8 1.3 0.6 0.8 0.1 2.1

2018 2.7 5.4 0.6 1.2 0.2 0.7 0.1 2.7

2019 3.0 5.7 0.5 1.1 0.0 0.6 0.1 3.3

2020 3.3 6.0 0.3 1.0 0.0 0.5 0.1 4.0

2021 3.6 6.3 0.2 0.9 0.0 0.4 0.2 4.6

2022 3.9 6.6 0.1 0.8 0.0 0.3 0.2 5.3

2023 4.3 6.9 0.1 0.7 0.0 0.2 0.2 5.9

2024 4.7 6.9 0.0 0.6 0.0 0.1 0.2 5.9

2025 5.1 6.9 0.0 0.5 0.0 0.0 0.2 5.9

2026 5.5 6.9 0.0 0.4 0.0 0.0 0.2 5.9

2027 5.9 6.9 0.0 0.2 0.0 0.0 0.2 5.9

2028 6.3 6.9 0.0 0.1 0.0 0.0 0.2 6.0

2029 6.7 6.9 0.0 0.0 0.0 0.0 0.2 6.0

2030 7.1 6.9 0.0 0.0 0.0 0.0 0.2 6.0

2031 7.1 6.9 0.0 0.0 0.0 0.0 0.2 6.0

2032 7.1 6.9 0.0 0.0 0.0 0.0 0.2 6.0

2033 7.1 6.9 0.0 0.0 0.0 0.0 0.2 6.0

2034 7.1 6.9 0.0 0.0 0.0 0.0 0.2 6.0

2035 7.1 6.9 0.0 0.0 0.0 0.0 0.2 6.0

2036 7.1 6.9 0.0 0.0 0.0 0.0 0.2 6.0

2037 7.1 6.9 0.0 0.0 0.0 0.0 0.2 6.0

2038 7.1 6.9 0.0 0.0 0.0 0.0 0.2 6.0

2039 7.1 6.9 0.0 0.0 0.0 0.0 0.2 6.1

2040 7.1 6.9 0.0 0.0 0.0 0.0 0.2 6.1

2041 7.1 6.9 0.0 0.0 0.0 0.0 0.2 6.1

2042 7.1 6.9 0.0 0.0 0.0 0.0 0.2 6.1

2043 7.1 6.9 0.0 0.0 0.0 0.0 0.2 6.1
16-A-19

16-A.5 UTILITY REBATE PROGRAMS 

This section presents data on rebate programs in effect nationwide for refrigeration 

products. The two tables organize the data for the rebates offered for refrigerators/refrigeratorfreezers and for freezers.

16-A.5.1 Rebate Programs for Standard-Size Refrigerator-Freezers and Compact 

Refrigerator-Freezers

DOE found 115 organizations, comprising electric utilities and municipal and regional 

agencies, that have rebate programs for refrigerator-freezers. The organizations offer more than 

127 rebates for models that meet various efficiency criteria. Table 16-A.5.1 provides the 

organizations’ names, states, rebate amounts, whether the rebate applies to standard-size or 

compact units, efficiency levels, and program websites. If there is more than one entry for an 

organization, that organization offers different rebate amounts depending on efficiency level.

Some rebate programs include both standard-size and compact refrigerators, as shown in the 

table. The average rebate amounts for standard-size refrigerators and for compact refrigerators, 

given in 2009$ at the end of the table, are simple averages of the individual amounts (rather than 

being population-weighted). 
16-A-20

Table 16-A.5.1 Rebates for Standard-Size and Compact Refrigerator-Freezers

Utility or Agency State

Amount 

2009$ Std Cpct Effic Website

LADWP CA 65 √ E* http://www.ladwp.com/ladwp/cms/ladwp000478.jsp

SCE CA 50 √ E*

http://www.sce.com/residential/rebates-savings/appliance/fridge-freezerrecycling.htm

SDG&E CA 25 √ E* http://www.sdge.com/residential/refrigerators.shtml

Alameda Municipal Power CA 100 √ E*

http://www.alamedamp.com/index.php?option=com_content&view=article&id=

52:refrigerator-rebate-program&catid=18:save-energy-at-home-&Itemid=46

Anaheim Public Utilities CA 50 √ E* http://www.anaheim.net/utilities/adv_svc_prog/nrg_star/flyer.pdf

Burbank Water & Power CA 150 √ E*

http://www.burbankwaterandpower.com/download/Home-Rewards-RebateForm-Web.pdf

Burbank Water & Power CA 100 √ E*

http://www.burbankwaterandpower.com/download/Home-Rewards-RebateForm-Web.pdf

City of Palo Alto Utilities CA 50 √ E* http://www.cityofpaloalto.org/civica/filebank/blobdload.asp?BlobID=4365

Glendale Water and Power CA 60 √ E*

http://www.glendalewaterandpower.com/save_money/residential/sh_energy_sav

ing_rebates.aspx

Glendale Water and Power CA 80 √ E*

http://www.glendalewaterandpower.com/save_money/residential/sh_energy_sav

ing_rebates.aspx

Hercules Municipal Utility CA 100 √ E* http://www.ci.hercules.ca.us/index.aspx?page=157

IID Energy CA 80 √ E* http://www.iid.com/Media/rewards_instruct_residential10_Eng.pdf

Lassen Municipal Utility District CA 50 √ E* http://www.lmud.org/documents/appliancerebate.pdf

Lodi Electric Utility CA 50 √ E* http://lodielectric.com/residential/rebateoffer.asp?id=2

Pacific Power CA 20 √ E* http://www.homeenergysavings.net/Downloads/CA_ApplianceForm2010a.pdf

Pasadena Water and Power CA 150 √ E* http://ww2.cityofpasadena.net/waterandpower/EnergyStar/default.asp

Plumas-Sierra REC CA 125 √ E* http://www.psrec.coop/energy_rebates.php?sec=enersol&pag=enerreb

Redding Electric CA 75 √ E* http://www.reupower.com/energysvc/documents/2010/Jan10EnergyStar.pdf

Redding Electric CA 35 √ E* http://www.reupower.com/energysvc/documents/2010/Jan10EnergyStar.pdf

Riverside Public Utilities CA 200 √ E* http://www.riversideca.gov/utilities/resi-energystar.asp

Roseville Electric CA 100 √ E* http://www.roseville.ca.us/electric/home/rebates/appliances.asp

Silicon Valley Power CA 85 √ E* http://www.siliconvalleypower.com/pdf/res_rebates_09.pdf

Truckee Donner Public Utility 

District CA 100 √ E* http://www.tdpud.org/pdf/Rebate%20program%20pamphlet,5-09.pdf

Turlock Irrigation District CA 35 √ E* http://www.tid.org/stellentdmz/groups/public/documents/tidweb_content/tidweb
16-A-21

Utility or Agency State

Amount 

2009$ Std Cpct Effic Website

_energy_efficiency_broch.pdf

Delta-Montrose Electric 

Association CO 40 √ E* http://www.dmea.com/Portals/0/refrigeratorrebate1-20-2010.pdf

Gunnison County Electric CO 20 √ E* http://www.gcea.coop/EE/rebate_program.cfm

Holy Cross Energy CO 75 √ E* http://www.holycross.com/green-programs/appliance-rebates

La Plata Electric Association CO 40 √ E* http://www.lpea.coop/programs_services/ApplianceRebate.pdf

Morgan County REA CO 75 √ E* http://www.mcrea.org/Services/Electric_Appliances.html

United Power CO 40 √ √ E* http://www.unitedpower.com/ApplianceRebate.aspx#recycle

Groton Utilities CT 60 √ E* http://www.grotonutilities.com/files/conservation_forms/Appliance_Rebate.pdf

Norwich Public Utilities CT 60 √ E*

http://www.norwichpublicutilities.com/energyefficiency/efficiencyres.html#res-electric

City of Tallahassee Utilities FL 75 √ E* http://www.talgov.com/you/energy/energy_programs.cfm#appl

Lake Worth Utilities FL 100 √ E*

http://www.lakeworth.org/vertical/Sites/%7B5E6FE119-0228-4C9B-B2DB067168049C16%7D/uploads/%7B5348F2F5-5F25-464C-873C87948A60D480%7D.PDF

Ames Electric Department IA 100 √ E*

http://www.cityofames.org/SmartEnergy/Documents/EfficientApplianceClaimF

orm%207.9.09.pdf

Ames Electric Department IA 50 √ E*

http://www.cityofames.org/SmartEnergy/Documents/EfficientApplianceClaimF

orm%207.9.09.pdf

Ames Electric Department IA 25 √ √ E*

http://www.cityofames.org/SmartEnergy/Documents/EfficientApplianceClaimF

orm%207.9.09.pdf

Interstate Power and Light IA 50 √ E*

http://alliantenergy.com/wcm/groups/wcm_internet/@int/documents/contentpag

e/022811.pdf

Linn County REC IA 25 √ E*

http://www.linncountyrec.com/cgiscript/csarticles/uploads/334/Energy%20Star%20Appliances%20LCREC.pdf

MidAmerican Energy IA 50 √ E* http://www.midamericanenergy.com/ee/include/pdf/ia_res_equip_brochure.pdf

Muscatine Power and Water IA 75 √ E* http://www.mpw.org/residential_rebates.aspx

Waverly Light & Power IA 150 √ √ E* http://wlp.waverlyia.com/appliance_programs.asp

Idaho Falls Power ID 25 √ E*

http://www.idahofallsidaho.gov/city/city-departments/idaho-falls-power/energyefficiency/energy-star-appliance-program.html

Idaho Power ID 30 √ √ E*

http://www.idahopower.com/EnergyEfficiency/Residential/Programs/HomePro

ducts/default.cfm

Kootenai Electric Cooperative ID 25 √ √ E* http://www.kec.com/rebates.php

Rocky Mountain Power ID 20 √ E* http://www.homeenergysavings.net/Downloads/ID_ApplianceForm2010.pdf
16-A-22

Utility or Agency State

Amount 

2009$ Std Cpct Effic Website

City Water Light and Power IL 50 √

http://www.cwlp.com/energy_services/ESO_services_programs/refrigerator_reb

ate.htm

Commonwealth Edison IL 50 √ E*

Munihelps

https://www.comed.com/sites/HomeSavings/Pages/appliancerecycling.aspx; 

http://www.cee1.org/files/CEEApplianceProgramSummaryApril2010.pdf 

MA 50 √ E*

http://www.munihelps.org/2010%20rebate%20forms/MailinformAshburnham.p

df

Belmont Municipal Light 

Department MA 100 √ E*

http://www.town.belmont.ma.us/public_documents/BelmontMA_LightNews/A

nnouncements/2010%20Appliance%20Rebate%20Program%20&%20Form%2

0Brochure.pdf

Concord Municipal Light Plant MA 100 √ E* http://www.concordma.gov/Pages/ConcordMA_LightPlant/appliance

Mansfield Municipal Electric MA 100 √ E*

Marblehead Light Department

http://www.mansfieldelectric.com/consumerforms/Appliance-Rebate-App.pdf

MA 100 √ E* http://www.marbleheadelectric.com/9-6_Rebate_guide_for_MMLD.pdf

NSTAR (part of Cape Light 

Compact) MA 50 √ E*

Reading Municipal Light 

http://www.nstaronline.com/docs3/ee-rebateforms/fridge.pdf?unique=20100402200503

MA 50 √ E*

Shrewsbury Electric & Cable 

Operations

http://www.rmld.com/Pages/rmldma_residential/rebate.pdf

MA 50 √ E*

Wakefield Municipal Gas & 

Light Department

http://www.shrewsbury-ma.gov/egov/docs/1263402562_742065.pdf

MA 50 √ E*

Allegheny Power

http://www.wakefield.ma.us/Public_Documents/WakefieldMA_MGLD/WMGL

DRebateForm.pdf

MD 50 √ E* http://www.nxtbook.com/nxtbooks/garrisonhughes/empowermaryland2010/#/4

Baltimore Gas & Electric 

Company MD 50 √ E*

Delmarva Power

http://conservation.bgesmartenergy.com/residential/lightingappliances/appliance-rebates

MD 50 √ E*

PEPCO

http://www.delmarva.com/energy/conservation/appliance/default.aspx

MD 50 √ √ E* http://homeenergysavings.pepco.com/dc/appliance-rebate

Efficiency Maine ME 75 √ E* http://www.efficiencymaine.com/at-home/appliance_rebate_program

Anoka Municipal Utility MN 25 √ E*

http://www.ci.anoka.mn.us/index.asp?Type=B_BASIC&SEC={03DDAD7BEC66-4214-97D8-EB42DA396059}

Southern Minnesota Municipal 

Power Agency MN 25 √ E*

http://www.smmpa.org/upload/Res%202010%20Rebate%20Program%20Fact%

20Sheet-BP.pdf

City of North St. Paul Electric 

Utility MN 25 √ E*

http://www.ci.north-saintpaul.mn.us/index.asp?Type=B_BASIC&SEC={F5C1E5FE-1ADD-49AFACD8-59C3FB4192FF}

Crow Wing Power MN 100 √ E* http://www.cwpower.com/heatingcoolingoptions.shtml

Minnesota Power MN 25 √ E*

http://www.mnpower.com/powerofone/one_home/energystar/special_offers/ind

ex.php
16-A-23

Utility or Agency State

Amount 

2009$ Std Cpct Effic Website

Shakopee Public Utilities MN 35 √ E* http://www.shakopeeutilities.com/Residential_Rebate_Packet.pdf

Stearns Electric MN 50 √ E* https://www.stearnselectric.org/energystarres.htm

Stearns Electric MN 75 √ E* https://www.stearnselectric.org/energystarres.htm

New Ulm Public Utilities MN 30 √ E*

http://www.ci.new-ulm.mn.us/index.asp?Type=B_BASIC&SEC={743A5650-

3018-4B6E-B7B0-662834287912}&DE={89E00F68-1EF5-4A75-BECEE3DE07703621}

New Ulm Public Utilities MN 10 √ √ E*

http://www.ci.new-ulm.mn.us/index.asp?Type=B_BASIC&SEC={743A5650-

3018-4B6E-B7B0-662834287912}&DE={89E00F68-1EF5-4A75-BECEE3DE07703621}

White River Valley Electric 

Cooperative MO 75 √ E* http://whiteriver.org/residential_rebate_program.aspx

Flathead Electric MT 25 √ E* http://www.flatheadelectric.com/energy/Rebates.html

Yellowstone Valley Electric 

Cooperative MT 25 √ E* http://www.yvec.com/UserFiles/File/Energy%20Star%20Rebate.pdf

Four-County EMC NC 150 √ E* http://www.fourcty.org/news.php?id=39&p=7

South River EMC NC 25 √ E* http://www.sremc.com/ESRebates.aspx

Central New Mexico Electric 

Cooperative NM 80 √ E* http://www.cnmec.org/pdfs/waterheater_rebate_guidelines.pdf

Long Island Power Authority NY 75 √ E* http://www.lipower.org/residential/efficiency/rebates/rebates-refrigerators.html

Ashland Electric Utility OR 25 √ E* http://www.ashland.or.us/Files/RefridgeratorRebateForm.pdf

Ashland Electric Utility OR 35 √

CEE 

Tier 

3 http://www.ashland.or.us/Files/RefridgeratorRebateForm.pdf

Central Electric Cooperative OR 25 √ E* http://www.cec-co.com/custserv/energy_info/brochures/energy_star.pdf

Central Lincoln People's Utility 

District OR 70 √ E*

http://www.clpud.org/pdf/Rebate%20Forms/CLPUD%20Applnc%20Rebate%2

0form%2005-09.pdf

Columbia River PUD OR 25 √ E* http://www.crpud.net/residential/efficiency/appliances

Consumers Power, Inc OR 25 √ E* http://www.cpi.coop/rebates/appliance.php

Douglas Electric Cooperative OR 25 √ E* http://www.douglaselectric.com/programs/Rebate_Form.pdf

Emerald P.U.D. OR 25 √ E* http://www.epud.org/documents/ApplianceRebate_000.pdf

Energy Trust of Oregon OR 50 √ E*

http://energytrust.org/residential/incentives/Appliances/NewRefrigeratorsandFre

ezers

Eugene Water & Electric Board OR 25 √ E* http://www.eweb.org/public/documents/energy/home_appliance_rebate.pdf

Forest Grove L&P OR 50 √ E* http://www.forestgrove-
16-A-24

Utility or Agency State

Amount 

2009$ Std Cpct Effic Website

or.gov/images/stories/services/lightandpower/pdf/mar2010appliancerebateform.

pdf

Idaho Power OR 30 √ E*

http://www.idahopower.com/EnergyEfficiency/Residential/Programs/HomePro

ducts/default.cfm

McMinnville Water and Light OR 25 √ E* http://www.mc-power.com/rebates.aspx

Midstate Electric Cooperative OR 25 √ E* http://www.midstateelectric.coop/Refrig%20Rebate%20Form.pdf

Monmouth Power & Light OR 25 √ E*

http://www.ci.monmouth.or.us/vertical/Sites/%7BCE78EAE1-6CA4-4610-

BDB0-A9B3B0A8BB71%7D/uploads/%7BF66F3203-CD45-406C-89BFADE93D1D975D%7D.PDF

OTEEC OR 25 √ E* http://www.otecc.com/residentialprograms.aspx

Salem Electric OR 60 √ E*

http://www.salemelectric.com/residential/pdfs/rebates_programs/ApplianceBroc

hure.pdf

Springfield Utility Board OR 25 √ E*

http://www.subutil.com/files/static_page_files/E3DD085D-078B-420B267070C0638CD317/RebateForm10.pdf

Tillamook County PUD OR 50 √ E* http://www.tpud.org/nrg_appliance.html

Allegheny Power PA 50 √ E*

http://www.alleghenypower.com/EngConserv/PA/WattWatchers/RebateREF.as

p

Duquesne Light PA 10 √ E* http://www.duquesnelight.com/wattchoices/#RE

PPL Electric Utilities PA 50 √ E* http://www.rebate-zone.com/ppl/pdf/PEJ.pdf

National Grid RI 50 √ E* https://www.powerofaction.com/rirefridge/

Guadalupe Valley Electric 

Cooperative TX 100 √ E* http://www.gvec.org/safety_con/Home%20Improvement.pdf

City of St. George UT 20 √ E*

http://www.sgcity.org/energyservices/ES%20Appliance%20Rebate%20Applicat

ion.pdf

Rocky Mountain Power UT 20 √ √ E* http://www.homeenergysavings.net/Downloads/UT_ApplianceForm2010.pdf

Efficiency Vermont VT 25 √ √ E*

http://efficiencyvermont.com/pages/Residential/Lightingandappliances/ENERG

YSTARAppliances/RefrigeratorsandFreezers/

Efficiency Vermont VT 50 √ √

CEE 

Tier 

2

http://efficiencyvermont.com/pages/Residential/Lightingandappliances/ENERG

YSTARAppliances/RefrigeratorsandFreezers/

Avista Utilities WA 25 √ E*

https://www.avistautilities.com/savings/rebates/Documents/HighEfficiencyReba

te_OREnergyStar-R2.1.5.2009.pdf

Benton PUD WA 25 √ E*

http://www.bentonpud.org/pdf/CRC/REEP/October%201,%202009/Appliance

%20Rebate%20Application%209-1-09.pdf

Clallam PUD WA 50 √ E* http://www.clallampud.net/uploadedFiles/conservation/documents/energy_star_
16-A-25

Utility or Agency State

Amount 

2009$ Std Cpct Effic Website

appliance_rebate.pdf

Clark Public Utilities WA 25 √ E* http://www.clarkpublicutilities.com/yourhome/conservation/rebates

Columbia Rural Electric 

Association WA 25 √ E* http://www.columbiarea.com/programs/Res%20Rebate%20Application.pdf

Cowlitz County PUD WA 25 √ E* http://www.cowlitzpud.org/pdf/RebateBrochureRevised10-6-08.pdf

Franklin PUD WA 25 √ E* http://www.franklinpud.com/pdfs/REBATE_PROGRAM_V_10.2.pdf

Grant County Public Utility 

District WA 25 √ E* http://www.gcpud.org/conservation/rebates/index.htm

Grays Harbor PUD WA 25 √ E*

https://www.ghpud.org/index.php?option=com_content&task=view&id=89&Ite

mid=113

Inland Power and Light Co WA 25 √ E* http://www.inlandpower.com/pdf/appliancerebateform.pdf

Mason PUD WA 25 √ E* http://www.masonpud3.org/powerSupply/applianceRebates.aspx

Okanogan PUD WA 25 √ E* http://www.okanoganpud.org/consrebates.htm

Orcas Power and Light 

Cooperative WA 25 √ E* http://www.opalco.com/energy-efficiency/rebates/

Pacific Power WA 20 √ √ E* http://www.homeenergysavings.net/Washington/appliances/refrigerators.html

City of Port Angeles WA 100 √ E* https://www.cityofpa.us/pwConserv.htm

Richland Energy Services WA 25 √ E* http://www.ci.richland.wa.us/RICHLAND/Electric/index.cfm?PageNum=89

Snohomish County Public 

Utility District No. 1 WA 50 √ E* http://www.snopud.com/conservation/appliances.ashx?p=1139

Barron Electric Cooperative WI 25 √ √ E* http://www.barronelectric.com/Appliance%20&%20Lighting%20Program.pdf

Eau Claire Energy Cooperative WI 25 √ E* http://www.ecec.com/programs/incentives

Riverland Energy Cooperative WI 25 √ E* http://riverlandenergy.com/RIVERLAND%20HOMEPAGE/rebates.htm

Montana-Dakota Utilities WY 10 √ E*

http://www.montanadakota.com/Wyoming/Conservation/Pages/ElectricIncentivePrograms.aspx

Rocky Mountain Power WY 20 √ √ E* http://www.homeenergysavings.net/Wyoming/appliances/refrigerators.html

Average Rebate Amount 

(2009$) 52 34
16-A-26

16-A.5.2 Rebate Programs for Standard-Size Freezers and Compact Freezers

DOE found 59 organizations, comprising electric utilities and municipal and regional agencies 

that offered 62 rebate programs for standard-size and compact freezers. The organizations offer rebates 

for units that meet a range of efficiency criteria. Table 16-A.5.2 lists the organizations’ names, states,

rebate amounts, whether the rebate applies to standard-size or compact units, efficiency levels, and 

program websites. Some rebate programs include both standard-size and compact refrigerators, as 

shown in the table. If there is more than one entry for an organization, that organization offers different 

rebates based on efficiency level. The average rebate amounts, given in 2009$ at the end of the table, 

are simple averages of the individual amounts (rather than being population-weighted). The table also 

shows the adjusted rebate amount for compact freezers, as discussed in chapter 16, section 16.3.2.3. 
16-A-27

Table 16-A.5.2 Rebates for Standard-Size and Compact Freezers

Utility State

Rebate 

Amount 

2009$ Std Cpct Effic Website

Montana-Dakota Utilities WY 10 √ E*

http://www.montanadakota.com/Wyoming/Conservation/Pages/ElectricIncentivePrograms.aspx

Barron Electric Cooperative WI 25 √ E* http://www.barronelectric.com/Appliance%20&%20Lighting%20Program.pdf

Eau Claire Energy 

Cooperative WI 25 √ E* http://www.ecec.com/programs/incentives

Riverland Energy 

Cooperative WI 25 √ E* http://riverlandenergy.com/RIVERLAND%20HOMEPAGE/rebates.htm

Avista Utilities WA 20 √ E*

https://www.avistautilities.com/savings/rebates/Documents/HighEfficiencyRebate

_OREnergyStar-R2.1.5.2009.pdf

Clallam PUD WA 25 √ E*

http://www.clallampud.net/uploadedFiles/conservation/documents/energy_star_ap

pliance_rebate.pdf

Clark Public Utilities WA 25 √ E* http://www.clarkpublicutilities.com/yourhome/conservation/rebates

Columbia Rural Electric 

Association WA 25 √ E* http://www.columbiarea.com/programs/Res%20Rebate%20Application.pdf

Cowlitz County PUD WA 25 √ E* http://www.cowlitzpud.org/pdf/RebateBrochureRevised10-6-08.pdf

Franklin PUD WA 25 √ E* http://www.franklinpud.com/pdfs/REBATE_PROGRAM_V_10.2.pdf

Grant County Public Utility 

District WA 25 √ E* http://www.gcpud.org/conservation/rebates/index.htm

Grays Harbor PUD WA 25 √ E*

https://www.ghpud.org/index.php?option=com_content&task=view&id=89&Itemi

d=113

Inland Power and Light Co WA 25 √ E* http://www.inlandpower.com/pdf/appliancerebateform.pdf

Mason PUD WA 25 √ E* http://www.masonpud3.org/powerSupply/applianceRebates.aspx

Orcas Power and Light 

Cooperative WA 25 √ E* http://www.opalco.com/energy-efficiency/rebates/

Guadalupe Valley Electric 

Cooperative TX 100 √ E* http://www.gvec.org/safety_con/Home%20Improvement.pdf

National Grid RI 50 √ E* https://www.powerofaction.com/rirefridge/

Allegheny Power PA 25 √ E* http://www.alleghenypower.com/EngConserv/PA/WattWatchers/RebateFR.asp

Duquesne Light PA 11 √ E* http://www.duquesnelight.com/wattchoices/#RE

Central Electric Cooperative OR 25 √ E* http://www.cec-co.com/custserv/energy_info/brochures/energy_star.pdf

Central Lincoln People's 

Utility District OR 70 √ E*

http://www.clpud.org/pdf/Rebate%20Forms/CLPUD%20Applnc%20Rebate%20f

orm%2005-09.pdf

Columbia River PUD OR 25 √ E* http://www.crpud.net/residential/efficiency/appliances
16-A-28

Utility State

Rebate 

Amount 

2009$ Std Cpct Effic Website

Consumers Power, Inc OR 25 √ E* http://www.cpi.coop/rebates/appliance.php

Emerald P.U.D. OR 25 √ E* http://www.epud.org/documents/ApplianceRebate_000.pdf

Energy Trust of Oregon OR 50 √ √ E*

http://energytrust.org/residential/incentives/Appliances/NewRefrigeratorsandFreez

ers

Eugene Water & Electric 

Board OR 25 √ E* http://www.eweb.org/public/documents/energy/home_appliance_rebate.pdf

Forest Grove L&P OR 50 √ E*

http://www.forestgroveor.gov/images/stories/services/lightandpower/pdf/mar2010appliancerebateform.pd

f

McMinnville Water and 

Light OR 25 √ E* http://www.mc-power.com/rebates.aspx

Monmouth Power & Light OR 25 √ E*

http://www.ci.monmouth.or.us/vertical/Sites/%7BCE78EAE1-6CA4-4610-BDB0-

A9B3B0A8BB71%7D/uploads/%7BF66F3203-CD45-406C-89BFADE93D1D975D%7D.PDF

OTEEC OR 25 √ E* http://www.otecc.com/residentialprograms.aspx

Salem Electric OR 60 √ E*

http://www.salemelectric.com/residential/pdfs/rebates_programs/ApplianceBroch

ure.pdf

Springfield Utility Board OR 25 √ E*

http://www.subutil.com/files/static_page_files/E3DD085D-078B-420B267070C0638CD317/RebateForm10.pdf

Tillamook County PUD OR 50 √ E* http://www.tpud.org/nrg_appliance.html

Four-County EMC NC 150 √ E* http://www.fourcty.org/news.php?id=39&p=7

South River EMC NC 25 √ E* http://www.sremc.com/ESRebates.aspx

Central New Mexico Electric 

Cooperative NY 80 √ E* http://www.cnmec.org/pdfs/waterheater_rebate_guidelines.pdf

Flathead Electric MT 25 √ E* http://www.flatheadelectric.com/energy/Rebates.html

Yellowstone Valley Electric 

Cooperative MT 25 √ E* http://www.yvec.com/UserFiles/File/Energy%20Star%20Rebate.pdf

Anoka Municipal Utility MN 50 √ E*

http://www.ci.anoka.mn.us/index.asp?Type=B_BASIC&SEC={03DDAD7BEC66-4214-97D8-EB42DA396059}

Southern Minnesota 

Municipal Power Agency MN 26 √

http://www.smmpa.org/upload/Res%202010%20Rebate%20Program%20Fact%20

Sheet-BP.pdf

Crow Wing Power MN 100 √ E* http://www.cwpower.com/heatingcoolingoptions.shtml

Shakopee Public Utilities MN 35 √ E* http://www.shakopeeutilities.com/Residential_Rebate_Packet.pdf

Stearns Electric MN 50 √ E* https://www.stearnselectric.org/energystarres.htm

Stearns Electric MN 75 √ E* https://www.stearnselectric.org/energystarres.htm
16-A-29

Utility State

Rebate 

Amount 

2009$ Std Cpct Effic Website

Cape Light Compact MA 50 √ E*

http://myenergystar.com/documents/RebateForms/2010/MA_FridgeFreezer_Rebat

e_CLC.pdf

Concord Municipal Light 

Plant MA 100 √ E* http://www.concordma.gov/Pages/ConcordMA_LightPlant/appliance

Allegheny Power MD 25 √ E* http://www.nxtbook.com/nxtbooks/garrisonhughes/empowermaryland2010/#/4

Ames Electric Department IA 50 √ √ E*

http://www.cityofames.org/SmartEnergy/Documents/EfficientApplianceClaimFor

m%207.9.09.pdf

Interstate Power and Light IA 50 √ E*

http://alliantenergy.com/wcm/groups/wcm_internet/@int/documents/contentpage/

022811.pdf

Linn County REC IA 25 √ E*

http://www.linncountyrec.com/cgiscript/csarticles/uploads/334/Energy%20Star%20Appliances%20LCREC.pdf

MidAmerican Energy IA 25 √ E* http://www.midamericanenergy.com/ee/include/pdf/ia_res_equip_brochure.pdf

Idaho Falls Power ID 25 √ E*

http://www.idahofallsidaho.gov/city/city-departments/idaho-falls-power/energyefficiency/energy-star-appliance-program.html

Kootenai Electric 

Cooperative ID 25 √ E* http://www.kec.com/rebates.php

City of Tallahassee Utilities FL 40 √ E* http://www.talgov.com/you/energy/energy_programs.cfm#appl

Groton Utilities CT 60 √ E* http://www.grotonutilities.com/files/conservation_forms/Appliance_Rebate.pdf

Norwich Public Utilities CT 60 √ E*

http://www.norwichpublicutilities.com/energyefficiency/efficiency-res.html#reselectric

Delta-Montrose Electric 

Association CO 40 √ E* http://www.dmea.com/Portals/0/refrigeratorrebate1-20-2010.pdf

Gunnison County Electric CO 20 √ E* http://www.gcea.coop/EE/rebate_program.cfm

Morgan County REA CO 75 √ E* http://www.mcrea.org/miscellaneous/pdf/APPLIANCE.pdf

United Power CO 40 √ E*

Burbank Water & Power

http://www.unitedpower.com/ApplianceRebate.aspx#recycle

CA 150 √ E*

http://www.burbankwaterandpower.com/download/Home-Rewards-Rebate-FormWeb.pdf

Burbank Water & Power CA 100 √ E*

http://www.burbankwaterandpower.com/download/Home-Rewards-Rebate-FormWeb.pdf

Averages (2009$) 43 50 

Adjusted Average (2009$) 28 
16-A-30

16-A.6 FEDERAL AND STATE TAX CREDITS

This section summarizes the Federal and State tax credits available to consumers who 

purchase energy efficient appliances. This section also describes tax credits available to 

manufacturers who produce certain energy efficient appliances.

16-A.6.1 Federal Tax Credits for Consumers of Residential Appliances

EPACT 2005 included Federal tax credits for consumers who installed efficient air 

conditioners or heat pumps; gas or oil furnaces; furnace fans; and/or gas, oil, or electric heat 

pump water heaters in new or existing homes.7, 8 These tax credits were in effect in 2006 and 

2007, expired in 2008, and were reinstated for 2009–2010 by the American Recovery and 

Reinvestment Act (ARRA). 9 These tax credits did not apply to consumers who purchased energy 

efficient refrigerators or freezers.

Although this tax credit did not include efficient refrigeration products, in an effort to 

evaluate the potential impact of a Federal appliance tax credit program, DOE reviewed Internal 

Revenue Service (IRS) data on the numbers of taxpayers who claimed the tax credits during tax 

years 2006 and 2007. It estimated the percentage of taxpayers who filed Form 5695, Residential 

Energy Credits.10 It also estimated the percentage of taxpayers with entries under Form 5695’s 

Line 3, Residential energy property costs, which included (3a) energy-efficient building property 

(including water heaters), (3b) qualified natural gas, propane, or oil furnace or hot water boiler, 

and (3c) advanced main air circulating fan used in a natural gas, propane, or oil furnace. While 

none of these three items corresponds exactly to refrigeration products, DOE reasoned that the 

percentage of taxpayers with at least one entry under Line 3 could serve as a rough indication of 

the potential of taxpayer participation in a Federal tax credit program for an efficient appliance 

during the initial program years. It found that of all residential taxpayers filing tax returns in

2006 and 2007, 2.1 percent each year claimed at least one credit under Line 3. DOE further 

found that the percentages of those filing Form 5695 for any qualifying energy property 

expenditure (which also included installation of efficient windows, doors and roofs) were 3.1 and 

3.2 percent in 2006 and 2007 respectively. 

DOE also reviewed data from an earlier Federal energy conservation tax credit program 

in place in the 1980s. While this tax credit was available from 1979 through 1985, DOE located 

data for only the first three years of the program.11, 12, 13 For those three years, the percentages of 

taxpayers filing Form 5695 were 6.4 percent, 5.2 percent, and 4.9 percent in 1979, 1980, and 

1981. Given that the data from this earlier tax credit program were not disaggregated by type of 

energy property, this data series served only to indicate a possible trend of greater participation 

in the initial program year, followed by slightly smaller participation in subsequent years. 

However, DOE did not find detailed analysis of this program to indicate the possible reasons for 

such a trend. Also, this trend varies from the more stable trend shown in the EPAct 2005 energy 

tax credit program data for its first two program years.

As discussed in chapter 16, section 16.3.3, DOE analyzed the percentage of participation 

in consumer tax credit programs using its estimates of consumer participation in rebate programs 

that was based on benefit/cost data specific to each refrigeration product class. Hence it was 
16-A-31

difficult to compare these detailed estimates to the more general data analysis described above 

from the existing Federal tax credit program, or to use the IRS data analysis in its consumer tax 

credit analysis.

16-A.6.2 Federal Tax Credits for Manufacturers

EPACT 2005 provided Federal Energy Efficient Appliance Credits to manufacturers that 

produced high-efficiency refrigerators, clothes washers, and dishwashers in 2006 and 2007.14

The Emergency Economic Stabilization Act of 200815 amended the credits and extended them 

through 2010. Manufacturers receive the credits for increasing their production of qualifying 

appliances relative to a two-year rolling baseline. Each manufacturer is limited to a certain 

amount for all credits. Manufacturers were eligible for Energy Efficient Appliance Credits for 

qualifying models of residential refrigerators, residential and commercial clothes washers, , and 

residential dishwashers. The credits listed below were available for refrigerator models produced 

in 2008, 2009, and 2010. These credit amounts and criteria applied to manufacturers who 

produce these appliances. The amounts listed are for each unit manufactured. However, the 

maximum credit that a manufacturer could receive for qualifying equipment was $75 million for 

2008–2010, with the exceptions that the most efficient refrigerator (30 percent) models were not 

subject to the cap.16

• $50 for models manufactured in 2008 that consume at least 20 percent but not more 

than 22.9 percent fewer kilowatt hours per year than the 2001 energy conservation 

standards. 

• $75 for models manufactured in 2008 or 2009 that consume at least 23 percent but no 

more than 24.9 percent fewer kilowatt hours per year than the 2001 energy 

conservation standards.

• $100 for models manufactured in 2008, 2009, or 2010 that consume at least 25 

percent but not more than 29.9 percent fewer kilowatt hours per year than the 2001 

energy conservation standards. 

• $200 for models manufactured in 2008, 2009, or 2010 that consume at least 30 

percent less energy than the 2001 energy conservation standards.

16-A.6.3 State Tax Credits

The States of Oregon and Montana have offered consumer tax credits for efficient 

appliances for several years, and the States of Indiana, Kentucky and Michigan began offering 

such credits in 2009. The Oregon Department of Energy (ODOE) has disaggregated data on 

taxpayer participation in credits for eligible products. (See the discussion in chapter 16, section 

16.3.3, on data for refrigerators and clothes washers.) Montana’s Department of Revenue does 

not disaggregate participation data by appliance, although DOE reviewed Montana's overall 

participation trend that were congruent with its analysis of Oregon's clothes washer tax credits. 

DOE was unable to obtain state tax credit data from Indiana, Kentucky or Michigan. 
16-A-32

Oregon’s Residential Energy Tax Credit (RETC) was created in 1977. After the Oregon 

legislature expanded the RETC program in 1997 to include residential refrigerators, clothes 

washers, and dishwashers, participation in the program increased significantly. For standardsized refrigerators the program offers two levels of rebates for units between 12 and 30 ft.3 The 

required efficiency levels are 20 percent above Federal standard (ENERGY STAR) and 30 

percent above Federal standard (CEE Tier 3). The program subsequently added credits for highefficiency heat pump systems, air conditioners, and water heaters (2001); furnaces and boilers

(2002); and duct/air sealing, fuel cells, heat recovery, and renewable energy equipment. For 

heating, ventilating, and air conditioning equipment; residential appliances; and water heaters, 

the credit is $0.40 per kilowatt saved in the first year, or 25 percent of the net purchase price, 

whichever is less. The credit limit for energy efficient appliances and heating and cooling 

systems is $1,000 per calendar year; excess credit may be carried forward for 5 years.17

Montana has had an Energy Conservation Tax Credit for residential measures since 

1998.18, 19 The tax credit covers various residential energy and water efficient products, including 

ENERGY STAR heating/cooling equipment, water heaters, low-flow showerheads and faucets, 

and light fixtures and controls. In 2002 the amount of the credit was increased from 5 percent of 

product costs (up to $150) to 25 percent (up to $500) per taxpayer. The credit can be used for 

products installed in new construction or remodeling projects. The tax credit covers only that 

part of the cost and materials that exceed established standards of construction.

Beginning in 2009 Indiana offered a tax credit to individuals and small businesses for 

costs associated with purchasing ENERGY STAR-qualified central air conditioners, room air 

conditioners, furnaces, programmable thermostats, and water heaters. The credit may be claimed 

against state income tax, insurance premium tax, or financial institutions tax. The amount of the 

credit is 20 percent of the expenditure for qualified heating and cooling equipment, to a 

maximum of $100 per taxable year. The credit applies to expenditures made in 2009 and 2010; 

there is no carryover.20, 21 

Beginning in 2009 Kentucky offered a 30 percent state income tax credit for taxpayers 

who install certain energy efficiency measures in their principal residence or residential rental 

property. The qualifying products include water heaters, heat pumps, central air conditioners, and 

advanced main air circulating fans. A product must meet the same energy efficiency guidelines

as specified for the Federal tax credit for that residential product. The tax credit may not exceed 

$250. The credit, which applies to products purchased in taxable years 2009–2015, may be 

carried forward for 1 year.22, 23

Beginning in 2009, certain Michigan low-income taxpayers became eligible for a tax 

credit for the purchase and installation of qualifying energy efficient home improvements. The 

definition of qualifying home improvements is limited to the following categories: insulation, 

water heaters, furnaces, windows, refrigerators, clotheswashers, and dishwashers. All equipment 

must meet the EPA Energy Star efficiency criteria. The amount of the credit is 10% of the 

installed cost of each improvement, up to $75 for single filers and $150 for joint filers. A 

taxpayer may not make more than one claim under each equipment category during a single tax 
16-A-33

year. The credit only applies to equipment purchased in 2009 - 2011. If the amount of the credit 

exceeds a taxpayer's tax liability for a given year, the balance is refunded. 24, 25
16-A-34

REFERENCES

1. Rufo, M. and Fred Coito., California's Secret Energy Surplus: The Potential for Energy 

Efficiency., 2002. XENERGY Inc. Oakland, CA. Prepared for The Energy Foundation 

and The Hewlett Foundation. (Last accessed August, 2010.)

<http://www.ef.org/documents/Secret_Surplus.pdf>

2. Hall, B. H. and B. Khan, Adoption of New Technology. Working Paper No. E03-330, 

2003. Department of Economics, University of California, Berkeley, CA. 

3. Lekvall. P and C. Wahlbin, "A Study of Some Assumptions Underlying Innovation 

Diffusion Functions". Swedish Journal of Economics, 1973

4. Geroski, P. A., Models of Technology Diffusion. Research Policy, 2000. 29: pp. 603-625 

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<www.energytaxincentives.org/consumers/heating-cooling.php>

8. Energy Policy Act of 2005, 119 STAT. 594 Public Law 109–58. Section 1333, 26 USC 

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<http://energytaxincentives.org/general/legislative.php> 

10. Internal Revenue Service. SOI Tax Stats - Individual Income Tax Returns, Estimated 

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12. Internal Revenue Service. 1980 Annual Report, Commissioner of Internal Revenue. (Last 

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13. Internal Revenue Service. 1981 Annual Report: Commissioner of Internal Revenue and 

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<http://www.irs.gov/pub/irs-soi/81dbcomplete.pdf>

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15. Emergency Economic Stabilization Act of 2008, (Last accessed August, 2010.) 

<http://frwebgate.access.gpo.gov/cgibin/getdoc.cgi?dbname=110_cong_bills&docid=f:h1424enr.txt.pdf>

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17. Oregon Department of Energy–Conservation Division, Residential Energy Tax Credits, 

(Last accessed August, 2010.) 

<http://egov.oregon.gov/ENERGY/CONS/RES/RETC.shtml>

18. Montana Department of Environmental Quality, Tax Incentives, (Last accessed August, 

2010.) <http://deq.mt.gov/Energy/warmhomes/taxincentives.mcpx>

19. Montana Department of Revenue, Energy Related Tax Relief, (Last accessed August, 

2010.) <http://mt.gov/REVENUE/energyconservation.asp>

20. Indiana Department of Revenue, Information Bulletin #100: Income Tax, 2007. (Last 

accessed August, 2010.) <www.in.gov/dor/files/ib100.pdf>

21. Database of State Incentives for Renewables and Efficiency (DSIRE), Indiana Incentives 

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2010.) 

<www.dsireusa.org/library/includes/incentive2.cfm?Incentive_Code=IN50F&state=IN&

CurrentPageID=1&RE=0&EE=1>

22. Kentucky Department of Revenue, 2009 Energy Efficiency Credits, (Last accessed

August, 2010.) <http://revenue.ky.gov/NR/rdonlyres/E2DAFC0B-4F18-4D76-91F8-

C6766A3843EE/0/2009EnergyEfficiencyCredits.pdf>

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<www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=KY29F&re=0&ee=1>

24. Database of State Incentives for Renewables and Efficiency (DSIRE), Michigan 

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16-A-36

<http://www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=MI20F&re=0&ee=1

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25. Michigan Department of Treasury, Michigan Energy Efficiency / Renewable Energy Tax 

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