2-3

Analysis Of New DOE Design Options

1. Remove Oven Door Window

Design Option. The removal of the oven door window will eliminate heat loss

through the window glass. However, the window serves a useful function by allowing the

cook to monitor cooldng progress without opening the door. Some of the energy saved by

the removal of the window would be offset by door openings to check on the cooking

progress. This option was assumed by DOE to have no added cost for the purposes of

analysis; however, in most cases this option would represent a savings in manufacturer's

cost over a non-windowed door.

Experimental Tests. The DOE test procedure3 for oven efficiency was performed

using two typical, current production (1992-1993), gas ranges. One range was equipped

with a standard oven, and the other was equipped with a self-cleaning oven. The first test,

repeated four times for statistical validity, was without a door window. For the second test,

the door was replaced with a windowed door and the measurements repeated four times.

For the particular models chosen, each is manufactured both with and without an oven door

window. This assures that the oven characteristics are identical for each efficiency measurement test; the only variable is the presence or absence of the window. The results of the

four tests for each range were averaged and are shown in Table 2-2. For this set of

experiments, the oven door was not opened during the test.

For perspective, the annual energy savings expressed as cost is 42 cents for a standard

oven and 20 cents for a self-cleaning oven. This assumes a gas cost of $6.00/mmBtu,

which is typical for the first year that any standard would be in effect, based on DOE

projections.10"

DOE, in its Technical Support Document (TSD),12 assumes that opening the door

during the course of a cooking cycle does not have a significant effect on the energy savings.

EE-RM-90-201 COMMENT OOR13

2-3 

Analysis Of New DOE Design Options 

1. Remove Oven Door Window 

Design Option. The removal of the oven door window will eliminate heat loss 

through the window glass. However, the window serves a useful function by allowing the 

cook to monitor cooking progress without opening the door. Some of the energy saved by 

the removal of the window would be offset by door openings to check on the cooking 

progress. This option was assumed by DOE to have no added cost for the purposes of 

analysis; however, in most cases this option would represent a savings in manufacturer's 

cost over a non-windowed door. 

Experimental Tests. The DOE test procedure(3) for oven efficiency was performed 

using two typical, current production (1992-1993), gas ranges. One range was equipped 

with a standard oven, and the other was equipped with a self-cleaning oven. The first test, 

repeated four times for statistical validity, was without a door window. For the second test, 

the door was replaced with a windowed door and the measurements repeated four times. 

For the particular models chosen, each is manufactured both with and without an oven door 

window. This assures that the oven characteristics are identical for each efficiency measurement test; the only variable is the presence or absence of the window. The results of the 

four tests for each range were averaged and are shown in Table 2-2. For this set of 

experiments, the oven door was not opened during the test. 

For perspective, the annual energy savings expressed as cost is 42 cents for a standard 

oven and 20 cents for a self-cleaning oven. This assumes a gas cost of $6.00/mmBtu, 

which is typical for the first year that any standard would be in effect, based on DOE 

projections. (10,11) 

DOE, in its Technical Support Document (TSD), (12) assumes that opening the door 

during the course of a cooking cycle does not have a significant effect on the energy savings. 
2-4

Table 2-2. Effect on Energy Consumption of Windowed vs. Non-Windowed Doors

(No Door Openings During Test)

Test Energy Test Energy

Efficiency Efficiency With Without Annual

With Without Window Window Energy

Oven Window Window (Btu) (Btu) Savings

Type (%) (%) Average Average (kBtu)

Standard 6.13 6.42 7503 7155 69.8

Self-Clean 8.09 8.33 5679 5515 32.9

(Pyrolytic)

____________ ___________ ______________ ______________ ____________

DOE concluded that the window could be removed and the cook could open the door to

check on the cooking progress without significant energy loss.

To test this hypothesis, the DOE test procedure was performed on both the standard

and self-cleaning ovens without windows, but including two different sets of door openings.

The ranges used were the same ranges used for the window versus non-window oven tests.

For the first test, the oven door was fully opened seventeen times for four seconds at one

minute intervals between door openings. Seventeen openings was picked as a starting value

since the DOE stated4 that the loss from the door window is equilavent to seventeen door

openings. The procedure was repeated, except that eight door openings were used during

the DOE test procedure. Graphs 2-1 and 2-2 are plots of the data obtained from these tests

showing the efficiency of a standard or self-cleaning oven without a window as a function of

the number of door openings. The data clearly indicate that the energy lost per door

opening is significant.

If the DOE design option of eliminating the oven door window were to be adopted, it

is reasonable to assume that a cook would open the door during the cooking cycle to check

on cooking progress. Certain food items would require this to determine the optimum

degree of cooking, from both appearance and quality standpoints. A minimum of four door

openings was assumed to be a reasonable estimate of consumer actions in the absence of a

window. Expert home economists have confirmed that this is a reasonable estimate (see

EE-RM-90-201 COMMENT OOR13

2-4 

Table 2-2. Effect on Energy Consumption of Windowed vs. Non-Windowed Doors 

(N 0 Door Openings During Test) 

Test Energy Test Energy 

Efficiency Efficiency With Without Annual 

With Without Window Window Energy 

Oven Window Window (Btu) (Btu) Savings 

Type (%) (%) Average Average (kBtu) 

Standard 6.13 6.42 7503 7155 69.8 

Self-Clean 8.09 8.33 5679 5515 32.9 

(Pyrolytic) 

DOE concluded that the window could be removed and the cook could open the door to 

check on the cooking progress without significant energy loss. 

To test this hypothesis, the DOE test procedure was performed on both the standard 

and self-cleaning ovens without windows, but including two different sets of door openings. 

The ranges used were the same ranges used for the window versus non-window oven tests. 

For the first test, the oven door was fully opened seventeen times for four seconds at one 

minute intervals between door openings. Seventeen openings was picked as a starting value 

since the DOE stated(4) that the loss from the door window is equilavent to seventeen door 

openings. The procedure was repeated, except that eight door openings were used during 

the DOE test procedure. Graphs 2-1 and 2-2 are plots of the data obtained from these tests 

showing the efficiency of a standard or self-cleaning oven without a window as a function of 

the number of door openings. The data clearly indicate that the energy lost per door 

opening is significant. 

If the DOE design option of eliminating the oven door window were to be adopted, it 

is reasonable to assume that a cook would open the door during the cooking cycle to check 

on cooking progress. Certain food items would require this to determine the optimum 

degree of cooking, from both appearance and quality standpoints. A minimum of four door 

openings was assumed to be a reasonable estimate of consumer actions in the absence of a 

window. Expert home economists have confirmed that this is a reasonable estimate (see 
65

6m4

o

>

C-)

6.2

C)

61 w

5Q9

No window

6

o 2 4 6 8 10 12 14 16 18

Number of Oven Door Openings

•,!1%

Graph 2-1. Efficiency of a standard oven without a window as a function of the number of door openings

EE-RM-90-201 COMMENT OOR13

6.5 

6.4 

o 

~6.3 ~ 

o 

ffi 6.2 -

o 

~ 6.1 

w 

6 

5.9 

No window 

Window 

o 2 4 6 8 10 12 14 16 18 

Number of Oven Door Openings 

Graph 2-1. Efficiency of a standard oven without a window as a function of the number of door openings 

N 

~ 
8.4

8.2

7.6

No window

Window

7.4

7.2

o 2 4 6 8 10 12 14 16 18

Number of Oven Door Openings

Graph 2-2. Efficiency of a self-cleaning oven without a window as a function of the number of door openings

a'

EE-RM-90-201 COMMENT OOR13

8.4 

8.2 No window 

~ 0 

... 8 

>- 0 

Window 

ffi 7.8 

.-0 • ~ 7.6 

w 

7.4 • 

7.2 

0 2 4 6 8 10 12 14 16 18 

Number of Oven Door Openings 

Graph 2-2. Efficiency of a self-cleaning oven without a window as a function of the number of door openings 

N 

I 

0'\ 
2-7

Appendix C, Exhibit 1). It is quite likely that the time interval may be longer for actual

consumer use than that assumed for the experimental data, thus further reducing any

potential energy savings.

The experimental measurements reported here are expected to be typical of current

ranges on the market; however, extensive tests using ranges from several different manufacturers were not possible within the limited time between the publication of the NOPR and

the end of the comment period. Some variation in results for ranges from different manufacturers could be expected; however, this variation would not be expected to invalidate the

conclusion that energy loss from door opening is significant.

Economics. With four door openings per test as described above, the self-cleaning

oven without a window (the DOE design option) costs about 2 cents more per year to

operate than the same range ith a window (see Table 2-3). This means that for a selfcleaning oven, the DOE design option without a window will lose energy. The non-selfcleaning oven without a window (the DOE design option) saves about 24 cents per year (see

Table 2-3). This means that for a standard oven, the DOE design option without a window

does save a small amount of energy.

Table 2-3. Economic Analysis of Design Option: Remove Oven Door Window

Design Option

Net Energy Saved,

kBtu/yr

Annualized Net Savings,

$

Standard Oven, no door openings 60 0.43

Self-Clean Oven, no door openings 35 0.25

Standard Oven, 4 door openings 34 0.24

Self-Clean Oven, 4 door openings -3 -0.02

It is clear that this energy savings would not offset the decreased utility of the oven by

eliminating a feature that is important to cooks. This is supported by the fact that consumers

EE-RM-90-201 COMMENT OOR13

2-7 

Appendix C, Exhibit 1). It is quite likely that the time interval may be longer for actual 

consumer use than that assumed for the experimental data, thus further reducing any 

potential energy savings. 

The experimental measurements reported here are expected to be typical of current 

ranges on the market; however, extensive tests using ranges from several different manufacturers were not possible within the limited time between the publication of the NOPR and 

the end of the comment period. Some variation in results for ranges from different manufacturers could be expected; however, this variation would not be expected to invalidate the 

conclusion that energy loss from door opening is significant. 

Economics. With four door openings per test as described above, the self-cleaning 

oven without a window (the DOE design option) costs about 2 cents more per year to 

operate than the same range with a window (see Table 2-3). This means that for a selfcleaning oven, the DOE design option without a window will lose energy. The non-selfcleaning oven without a window (the DOE design option) saves about 24 cents per year (see 

Table 2-3). This means that for a standard oven, the DOE design option without a window 

does save a small amount of energy. 

Table 2-3. Economic Analysis of Design Option: Remove Oven Door Window 

Net Energy Saved, Annualized Net Savings, 

Design Option kBtu/yr $ 

Standard Oven, no door openings 60 0.43 

Self-Clean Oven, no door openings 35 0.25 

Standard Oven, 4 door openings 34 0.24 

Self-Clean Oven, 4 door openings -3 -0.02 

It is clear that this energy savings would not offset the decreased utility of the oven by 

eliminating a feature that is important to cooks. This is supported by the fact that consumers 
2-8

(cooks) are willing to pay extra for a windowed oven door, as these models are usually more

expensive than the same unit without a window.

Cooking Quality Concerns. The oven window is a feature appreciated by most

consumers. The effects of this DOE design option on cooking quality were not addressed in

the NOPR or the TSD. If a design option affects the cooking ability of an oven or produces

results that are unacceptable to the consumer, it should not be mandated. The small amount

of energy saved does not justify design options that impact food and cooking quality. The

cost of ruining of meals because the cook could not observe the cooking process, or the

modification of traditional or ethnic recipes to fit new oven characteristics that do not

produce the expected results has greater cost implications than these projected potential

energy savings.

The window allows inspection without door openings that may cause failure of delicate

food items, such as souffles, or unacceptable results for some foods. Elimination of the

window can cause increased cooking time due to the heat losses per opening and, as shown,

may actually result in an energy loss.

Safety Concerns. In addition to cooking quality concerns, of equal or perhaps greater

importance are the safety issues. Each additional door opening while the oven is in use

increases the risk of burns from exposed hot surfaces or steam. This is of special concern

where children or physically limited individuals are nearby.

Other Issues. Under Section 325 (l)(4) of NAECA,' 42 U.S.C. Section 6295 (l)(4)

and House Report No. 100-1 1,(13) the intent of the law "ensures that energy savings are not

achieved through the loss of significant consumer features . . . This precludes DOE from

promulgating a standard . . . that eliminates performance characteristics." Safety is included

in examples of performance characteristics.

The ORTECH14 study cited in the TSD4 to justify an efficiency increase for

removing the door window states:

EE-RM-90-201 COMMENT OOR13

2-8 

(cooks) are willing to pay extra for a windowed oven door, as these models are usually more 

expensive than the same unit without a window. 

Cooking Quality Concerns. The oven window is a feature appreciated by most 

consumers. The effects of this DOE design option on cooking quality were not addressed in 

the NOPR or the TSD. If a design option affects the cooking ability of an oven or produces 

results that are unacceptable to the consumer, it should not be mandated. The small amount 

of energy saved does not justify design options that impact food and cooking qUality. The 

cost of ruining of meals because the cook could not observe the cooking process, or the 

modification of traditional or ethnic recipes to fit new oven characteristics that do not 

produce the expected results has greater cost implications than these projected potential 

energy savings. 

The window allows inspection without door openings that may cause failure of delicate 

food items, such as souffles', or unacceptable results for some foods. Elimination of the 

window can cause increased cooking time due to the heat losses per opening and, as shown, 

may actually result in an energy loss. 

Safety Concerns. In addition to cooking quality concerns, of equal or perhaps greater 

importance are the safety issues. Each additional door opening while the oven is in use 

increases the risk of bums from exposed hot surfaces or steam. This is of special concern 

where children or physically limited individuals are nearby. 

Other Issues. Under Section 325 (1)(4) of NAECA,(I) 42 U.S.C. Section 6295 (1)(4) 

and House Report No. 100-11,(13) the intent of the law "ensures that energy savings are not 

achieved through the loss of significant consumer features ... This precludes DOE from 

promUlgating a standard . . . that eliminates performance characteristics." Safety is included 

in examples of performance characteristics. 

The ORTECH(14) study cited in the TSD(4) to justify an efficiency increase for 

removing the door window states: 
2-9

It is highly questionable, however, whether elimination of the oven

window would be acceptable in the marketplace or would even result

in any real energy savings, since the only way to check cooking

progress would then be to open the oven door, which would increase

energy losses.

DOE's own 1980 Engineering Analysis'5 states:

DOE believes that it is not necessa,y to propose separate classes for

conventional ovens with solid doors and ovens with windows because

the differences in energy efficiency are small enough so that basic

models of each group can meet the minimum efficiency levels

proposed.

2. Eiectric Ignition

Design Option. Electric ignition is a proposed design option for both cooktops and

ovens. In the TSD, DOE analyzed cooktops and ovens as separate appliances, although

more than 90 percent of the market is for the combined appliance or range. The economic

analysis of this option should be considered for both cooktops and ovens together because

electric ignition would be added to both or neither since ranges are sold as the combined

unit. In determining life-cycle costs for this option, DOE applied maintenance costs to only

the cooktop. The oven electric ignition system will also require maintenance and the

probability of failure over the 19-year range life is expected to be similar for both the

cooktop and the oven electric ignition devices. DOE assumed a maintenance cost of $80.91

for the gas cooktop due to the addition of electric ignition. This same cost was added to the

oven in the economic analysis presented in this report.

For cooktops, spark ignition is added. Efficiency, as measured by the DOE test

procedure, does not change for cooktops with this option. The energy savings are obtained

by the removal of the pilot light, increaseing the energy factor (EF) and decreasing overall

gas consumption. However, because the ignition system on an oven is usually a "gb"

system, which consumes about 47.8 kwh per year of electricity, the efficiency, as measured

by the DOE test procedure, does decrease slightly for this option. Again, the EF will

increase and overall gas consumption will decrease for this design option.

EE-RM-90-201 COMMENT OOR13

2-9 

It is highly questionable, however, whether elimination of the oven 

window would be acceptable in the marketplace or would even result 

in any real energy savings, since the only way to check cooking 

progress would then be to open the oven door, which would increase 

energy losses. 

DOE's own 1980 Engineering Analysis(15) states: 

DOE believes that it is not necessary to propose separate classes for 

conventional ovens with solid doors and ovens with windows because 

the differences in energy efficiency are small enough so that basic 

models of each group can meet the minimum efficiency levels 

proposed. 

2. Electric Ignition 

Design Option. Electric ignition is a proposed design option for both cooktops and 

ovens. In the TSD, DOE analyzed cooktops and ovens as separate appliances, although 

more than 90 percent of the market is for the combined appliance or range. The economic 

analysis of this option should be considered for both cooktops and ovens together because 

electric ignition would be added to both or neither since ranges are sold as the combined 

unit. In determining life-cycle costs for this option, DOE applied maintenance costs to only 

the cooktop. The oven electric ignition system will also require maintenance and the 

probability of failure over the 19-year range life is expected to be similar for both the 

cooktop and the oven electric ignition devices. DOE assumed a maintenance cost of $80.91 

for the gas cooktop due to the addition of electric ignition. This same cost was added to the 

oven in the economic analysis presented in this report. 

For cooktops, spark ignition is added. Efficiency, as measured by the DOE test 

procedure, does not change for cooktops with this option. The energy savings are obtained 

by the removal of the pilot light, increaseing the energy factor (EF) and decreasing overall 

gas consumption. However, because the ignition system on an oven is usually a "glo" 

system, which consumes about 47.8 kwh per year of electricity, the efficiency, as measured 

by the DOE test procedure, does decrease slightly for this option. Again, the EF will 

increase and overall gas consumption will decrease for this design option. 
2-10

The National Electrical Code'6 requires a three-prong, grounded outlet within 6 feet

of an appliance. Therefore, for a majority of cases where a piloted range would be replaced

by an electric ignition range, as well as for new installations, an electric outlet would have

to be installed behind the range. For ranges, an electrical outlet installation cost of $96.00

was used in this report for the life-cycle costing. For ovens and cooktops treated as separate

appliances, the full cost of an electrical outlet installation was used.

The life-cycle costing was also conducted without the cost of an electrical outlet

included (see Appendix A). The proportion of installations needing a grounded electrical

outlet is unknown; however, according to AHAM, 23.4 percent of all gas ranges and

8.3 percent of gas cooktops shipped in 1993 had piloted ignition. This indicates that a

significant portion of the range replacement market would require new or updated electrical

outlet installation. Many rural and low-income housing units use piloted ranges because of

their lower initial cost.

Economics. The economic analysis was first performed for the cooktop and oven

separately for more direct comparison to DOE's analysis. Two additional cases were

analyzed to include the cost of an outlet installation for cooktop and oven. Two summary

cases were also analyzed for the combined cooktop and oven range (with and without outlet

installation) since, as mentioned above, this represents 90 percent of the market. Manufacturers' cost estimates from AHAM for electric ignition of $7.24 for cooktops and $13.38 for

ovens (in 1994 dollars) were used in the economic analysis.

This option is not economically justified for ovens, cooktops, or ranges if the cost of

an electric outlet is included in the analysis (see Table 2-4).

If the cost of an outlet is not included, a cooktop, considered as a separate appliance,

shows an annualized net savings of $5.14. An oven, considered as a separate appliance,

shows an annualized net savings' of- -$2.09 (a net loss). The combined cooktop and oven

(range) shows an annualized net savings of $3.05 (see Appendix A for complete life-cycle

analysis of all combinations).

EE-RM-90-201 COMMENT OOR13

2-10 

The National Electrical Code(16) requires a three-prong, grounded outlet within 6 feet 

of an appliance. Therefore, for a majority of cases where a piloted range would be replaced 

by an electric ignition range, as well as for new installations, an electric outlet would have 

to be installed behind the range. For ranges, an electrical outlet installation cost of $96.00 

was used in this report for the life-cycle costing. For ovens and cooktops treated as separate 

appliances, the full cost of an electrical outlet installation was used. 

The life-cycle costing was also conducted without the cost of an electrical outlet 

included (see Appendix A). The proportion of installations needing a grounded electrical 

outlet is unknown; however, according to AHAM, 23.4 percent of all gas ranges and 

8.3 percent of gas cooktops shipped in 1993 had piloted ignition. This indicates that a 

significant portion of the range replacement market would require new or updated electrical 

outlet installation. Many rural and low-income housing units use piloted ranges because of 

their lower initial cost. 

Economics. The economic analysis was first performed for the cooktop and oven 

separately for more direct comparison to DOE's analysis. Two additional cases were 

analyzed to include the cost of an outlet installation for cooktop and oven. Two summary 

cases were also analyzed for the combined cooktop and oven range (with and without outlet 

installation) since, as mentioned above, this represents 90 percent of the market. Manufacturers' cost estimates from AHAM for electric ignition of $7.24 for cooktops and $13.38 for 

ovens (in 1994 dollars) were used in the economic analysis. 

This option is not economically justified for ovens, cooktops, or ranges if the cost of 

an electric outlet is included in the analysis (see Table 2-4). 

If the cost of an outlet is not included, a cooktop, considered as a separate appliance, 

shows an annualized net savings of $5.14. An oven, considered as a separate appliance, 

shows an annualized net savings of-$2.09 (a net loss). The combined cooktop and oven 

(range) shows an annualized net savings of $3.05 (see Appendix A for complete life-cycle 

analysis of all combinations). 
2-11

As shown in Table 2-4, no cases are economically justified if installation and

maintenance costs are included in the life-cycle costing.

Table 2-4. Economic Analysis of Design Option: Electric Ignition

Including Installation and Maintenance Costs

Design Option

Net Energy

Saved, kBtu/yr

Annualized

Net Savings, $

Cooktop (stand alone appliance) 2050 -2.92

Standard Oven (stand alone appliance) 1489 -10.15

Combined Cooktop & Oven (Range) 3539 -5.01

3. Improved Door Seals

Design Option. Consultations with manufacturers indicate that oven door seals have

been greatly improved since the 1977 SAl report'7 cited by DOE.'4 The 7 percent

(0.41 percentage points for standard ovens and 0.5 percentage points for self-cleaning ovens)

efficiency improvement associated with improved door seals is not applicable for gas ovens,

based on a thorough review of DOE's cited documentation. The SAl report states:

This improvement applies primarily to standard electric ovens with

little impact on gas-fired standard ovens or self-cleaning ovens.

For gas ovens, the amount of air coming through the door seals is

small compared to the combustion products flowing through the

oven. Therefore, improvement of door seals has a negligible effect

on gas oven efficiency. (17) [page 6-23]

The SAl report17 [Executive Summary, p. 11] lists improved oven door seals as

"infeasible" for gas standard ovens and "not applicable" for gas self-clean ovens.

Economics. Even if a 1 percent improvement could be achieved, this option is not

economically justified using the DOE's estimates for the cost of implementing this design

option and the other fixed assumptions in this study (see Table 2-5).

EE-RM-90-201 COMMENT OOR13

2-11 

As shown in Table 2-4, no cases are economically justified if installation and 

maintenance costs are included in the life-cycle costing. 

Table 2-4. Economic Analysis of Design Option: Electric Ignition 

Including Installation and Maintenance Costs 

Net Energy Annualized 

Design Option Saved, kBtu/yr Net Savings, $ 

Cooktop (stand alone appliance) 2050 -2.92 

Standard Oven (stand alone appliance) 1489 -10.15 

Combined Cooktop & Oven (Range) 3539 -5.01 

3. Improved Door Seals 

Design Option. Consultations with manufacturers indicate that oven door seals have 

been greatly imprOVed since the 1977 SAl report(17) cited by DOE. (14) The 7 percent 

(0.41 percentage points for standard ovens and 0.5 percentage points for self-cleaning ovens) 

efficiency improvement associated with improved door seals is not applicable for gas ovens, 

based on a thorough review of DOE's cited documentation. The SAl report states: 

This improvement applies primarily to standard electric ovens with 

little impact on gas-fired standard ovens or self-cleaning ovens . . . 

For gas ovens, the amount of air coming through the door seals is 

small compared to the combustion products flowing through the 

oven. Therefore, improvement of door seals has a negligible effect 

on gas oven ejJiciencyJ17) [page 6-23J . 

The SAl report(l7) [Executive Summary, p. 11] lists improved oven door seals as 

"infeasible" for gas standard ovens and "not applicable" for gas self-clean ovens. 

Economics. Even if a 1 percent improvement could be achieved, this option is not 

economically justified using the DOE's estimates for the cost of implementing this design 

option and the other fixed assumptions in this study (see Table 2-5). 
2-12

Table 2-5. Economic Analysis of Design Option: Improved Door SeaLs

Design Option

Net Energy Saved,

kBtu/yr

Annualized Net Savings,

$

Standard Oven 13 -0.18

Self-Clean Oven 11 -0.21

Cooking Quality. Oven door seals have been optimized over many years by the

manufacturers to provide desired cooking quality. Some flow through the door seai is

required in a gas oven. Reducing or eliminating this air flow would provide unacceptable

cooking results, primarily in the uniformity of baked products such as cookies and breads

where multiple racks of product are cooked. Consultations with the manufacturers confirmed that the energy savings proposed by DOE resulting from improved oven door seals

are not possible without detriment to the quality of the cooked food.

4. Forced Convection

Design Option. This design option adds a fan and control components to circulate

heated air in the oven cavity to increase heat transfer to the items being cooked. Forced

convection gas ovens are a very small fraction of the residential market (currently available

on commercial-look ranges only). Gas range manufacturers are considering the introduction

of new gas ovens that incorporate convection as a cooking option, but not as a required

mode of cooking.

Economics. The cost of manufacturing a gas convection oven is considerably more

than its electric counterpart since forced convection can interfere with the combustion

process, requiring partial isolation of the combustion chamber from the oven cavity. Simply

adding a fan and controls, as is the case for electric convection ovens, is not practical for

gas ovens. Cost estimates for gas convection ovens were submitted by manufacturers to

EE-RM-90-201 COMMENT OOR13

2-12 

Table 2-5. Economic Analysis of Design Option: Improved Door Seals 

Net Energy Saved, Annualized Net Savings, 

Design Option kBtu/yr $ 

Standard Oven 13 -0.18 

Self-Clean Oven 11 -0.21 

Cooking Quality. Oven door seals have been optimized over many years by the 

manufacturers to provide desired cooking quality. Some flow through the door seal is 

required in a gas oven. Reducing or eliminating this air flow would provide unacceptable 

cooking results, primarily in the uniformity of baked products such as cookies and breads 

where multiple racks of product are cooked. Consultations with. the manufacturers confirmed that the energy savings proposed by DOE resulting from improved oven door seals· 

are not possible without detriment to the quality of the cooked food. 

4. Forced Convection 

Design Option. This design option adds a fan and control components to circulate 

heated air in the oven cavity to increase heat transfer to the items being cooked. Forced 

convection gas ovens are a very small fraction of the residential market (currently available 

on commercial-look ranges only). Gas range manufacturers are considering the introduction 

of new gas ovens that incorporate convection as a cooking option, but not as a required 

mode of cooking. 

Economics. The cost of manufacturing a gas convection oven is considerably more 

than its electric counterpart since forced convection can interfere with the combustion 

process, requiring partial isolation of the combustion chamber from the oven cavity. Simply 

adding a fan and controls, as is the case for electric convection ovens, is not practical for 

gas ovens. Cost estimates for gas convection ovens were submitted by manufacturers to 
2-13

AHAM and subsequently transmitted to Battelle as an average. The averaged added cost of

this forced convection design option is $51.77 to manufacturers in 1994 dollars (converted to

1990 dollars for the life-cycle cost analysis).

In addition, the fan will probably not last the entire life of the range (19 years), so

maintenance costs, estimated to be about $65.00, must also be considered in life-cycle

calculations.

Based on manufacturers' measurements using the DOE efficiency test procedure,3 the

efficiency of an electric forced convection oven increases by about 5.5 percent. Because

there is more natural convection in a standard gas oven than in a standard electric oven, the

efficiency increase for a gas oven is expected to be less than that for an electric oven.

However, even using the increased efficiency value for an electric oven, this design option is

not life-cycle cost justified (see Table 2-6 and Chapter 5).

Table 2-6. Economic Analysis of Design Option: Forced Convection

Net Energy Annualized Net

Design Option Saved, kBtu/yr Savings, $

Forced Convection, Standard Oven (assuming 68 -14.67

electric ignition)

Cooking Quality. No residential oven manufacturer is considering a unit that offers

convection as the only cooking mode. Cooking with convection has advantages for some

foods and disadvantages for others. In many cases, foods will cook more quickly and at a

lower temperature than in a conventional oven, which usually will save a small quantity of

energy. Other foods will cook unacceptably using convection and will not produce the

desired results from traditional recipes. As a general statement, cooking with convection

produces results that are different from conventional cooking, arid the consumer must have

the option of choosing the cooking mode that suits the particular food being cooked.

EE-RM-90-201 COMMENT OOR13

2-13 

AHAM and subsequently transmitted to Battelle as an average. The averaged added cost of 

this forced convection design option is $51. 77 to manufacturers in 1994 dollars (converted to 

1990 dollars for the life-cycle cost analysis). 

In addition, the fan will probably not last the entire life of the range (19 years), so 

maintenance costs, estimated to be about $65.00, must also be considered in life-cycle 

calculations. 

Based on manufacturers' measurements using the DOE efficiency test procedure, (3) the 

efficiency of an electric forced convection oven increases by about 5.5 percent. Because 

there is more natural convection in a standard gas oven than in a standard electric oven, the 

efficiency increase for a gas oven is expected to be less than that for an electric oven. 

However, even using the increased efficiency value for an electric oven, this design option is 

not life-cycle cost justified (see Table 2-6 and Chapter 5). 

Table 2-6. Economic Analysis of Design Option: Forced Convection 

Net Energy Annualized Net 

Design Option Saved, kBtu/yr Savings, $ 

Forced Convection, Standard Oven (assuming 68 -14.67 

electric ignition) 

Cooking Quality. No residential oven manufacturer is considering a unit that offers 

convection as the only cooking mode. Cooking with convection has advantages for some 

foods and disadvantages for others. In many cases, foods will cook more quickly and at a 

lower temperature than in a conventional oven, which usually will save a small quantity of 

energy. Other foods will cook unacceptably using convection and will not produce the 

desired results from traditional recipes. As a general statement, cooking with convection 

produces results that are different from conventional cooking, and the consumer must have 

the option of choosing the cooking mode that suits the particular food being cooked. 
2-14

Even if forced convection were determined to be economically justified, requiring it as

a mandated design option would greatly affect cooking quality (see Chapter 6 and Appendix C, Exhibits 2 and 3) and consumer expectations. As proposed, the DOE design option

of full-time convection would be required on all standard gas ovens. Although forced

convection is a good method to reduce the cooking times and temperatures on some foods,

not all foods should be cooked using this method. According to the operating manual'8 for

an electric convection oven currently on the market:

• . . because of variations in food density, suiface texture and

consistency, there are a few foods that may be prepared more

successfidly in the radiant-heat Standard Bake mode. For this

reason, Standard Bake mode is recommended when preparing baked

goods such as pumpkin pie and custard. The user may find other

foods that are also prepared more consistently in Standard Bake

mode. This is perfectly normal.

In addition, energy consumption and food quality using convection ovens has been

shown to be quite variable,19 depending on the particular food being cooked. Some foods

cooked in a convection oven can actually use more energy than in a standard oven. (20)

Requiring this option for standard (radiant-heat) ovens may eliminate this product

class, because standard ovens would then become more expensive than self-cleaning ovens.

Forced convection ovens offer distinct cooking options and should be a separate product

class due to their unique cooking characteristics.

5. Reduce Burner Excess Air

Design Option. This design option applies only to cooktops. The amount of

increased efficiency achievable with this option is unknown and not measurable based on the

DOE citations. The engineering analysis cited'5 claims an efficiency increase of 7.5 percent

over the baseline range (3 points above the baseline); however, the efficiency improvement

results from unknown redesign and shrouding.

The DOE reference claims that the percentage improvements cited were based on

more efficient units on the market at the time of the report. The analysis is unclear as to

EE-RM-90-201 COMMENT OOR13

2-14 

Even if forced convection were determined to be economically justified, requiring it as 

a mandated design option would greatly affect cooking quality (see Chapter 6 and Appendix C, Exhibits 2 and 3) and consumer expectations. As proposed, the DOE design option 

of full-time convection would be required on all standard gas ovens. Although forced 

convection is a good method to reduce the cooking times and temperatures on some foods,· 

not all foods should be cooked using this method. According to the operating manual(18) for 

an electric convection oven currently on the market: 

. . . because of variations in food density, surface texture and 

consistency, there are a few foods that may be prepared more 

successfully in the radiant-heat Standard Bake mode. For this 

reason, Standard Bake mode is recommended when preparing baked 

goods such as pumpkin pie and custard. The user may find other 

foods that are also prepared more consistently in Standard Bake 

mode. This is perfectly normal. 

In addition, energy consumption and food quality using convection ovens has been 

shown to be quite variable, (19) depending on the particular food being cooked. Some foods 

cooked in a convection oven can actually use more energy than in a standard oven. (20) 

Requiring this option for standard (radiant-heat) ovens may eliminate this product 

class, because standard ovens would then become more expensive than self-cleaning ovens. 

Forced convection ovens offer distinct cooking options and should be a separate product 

class due to their unique cooking characteristics. 

5. Reduce Burner Excess Air 

Design Option. This design option applies only to cooktops. The amount of 

increased efficiency achievable with this option is unknown and not measurable based on the 

DOE citations. The engineering analysis cited(lS) claims an efficiency increase of 7.5 percent 

over the baseline range (3 points above the baseline); however, the efficiency improvement 

results from unknown redesign and shrouding. 

The DOE reference claims that the percentage improvements cited were based on 

more efficient units on the market at the time of the report. The analysis is unclear as to 

. \ 
2-15

whether the units used to determine the efficiency improvement were actual burners with

reduced excess air or if the efficiency improvement is from a theoretical analysis.

Safety Concerns. The potential for increased carbon monoxide exists for burners

with reduced excess air. This option needs to be analyzed in detail because of safety and

indoor air quality considerations.

Economics. No economic analysis of this design option is possible, based on the

limited information available. Since this option cannot be evaluated using the DOE test

procedure, it cannot be justified as a mandated option for cooktops.

Conclusions Concerning The New DOE Design Options

The analyses reported here show that none of the new DOE design options proposed in

the NOPR3 can be justified based on life-cycle cost, loss of consumer utility, safety,

technical considerations, or food quality considerations. One design option, reduce burner

excess air, cannot be evaluated with available information. Therefore, none of these new

design options show justification to be mandated for kitchen ranges or ovens.

EE-RM-90-201 COMMENT OOR13

2-15 

whether the units used to determine the efficiency improvement were actual burners with 

reduced excess air or if the efficiency improvement is from a theoretical analysis. 

Safety Concerns. The potential for increased carbon monoxide exists for burners 

with reduced excess air. This option needs to be analyzed in detail because of safety and 

indoor air quality considerations. 

Economics. No economic analysis of this design option is possible, based on the 

limited information available. Since this option cannot be evaluated using the DOE test 

procedure, it cannot be justified as a mandated option for cooktops. 

Conclusions Concerning The New DOE Design Options 

The analyses reported here show that none of the new DOE design options proposed in 

the NOPR(3) can be justified based on life-cycle cost, loss of consumer utility, safety, 

technical considerations, or food quality considerations. One design option, reduce burner 

excess air, cannot be evaluated with available information. Therefore, none of these new 

design options show justification to be mandated for kitchen ranges or ovens. 
3. OTHER DOE DESIGN OPTIONS

This chapter analyzes the design options that were first published in the ANOPR9 and

that DOE determined to be life-cycle justified in the NOPR.3 The previously issued GRI

report8 analyzed these design options in detail. Additional analysis completed since the

publication of the NOPR is presented in this chapter. The life-cycle cost analysis results

from the GRI report have been updated for all of the DOE design options determined by

DOE to be cost-effective. This was done so that all of the life-cycle cost information uses

the same economic assumptions and is reported in one document.

The design options covered in this chapter, all related to ovens, are:

1. Reduced Vent Rate (Standard Ovens)

2. Reflective Surfaces (Standard and Self-Cleaning Ovens)

3. Added Insulation (Standard and Self-Cleaning Ovens)

4. Reduced Thermal Mass (Standard and Self-Cleaning Ovens)

5. Improved Insulation (Standard Ovens).

Table 3-1 summarizes the results of the analysis of the above design options.

1. Reduced Vent Rate

Design Option. Energy efficiency is expected to be increased by reducing the oven

vent size so as to lower the oven vent rate. This option was proposed for the standard oven

only. The added cost to the consumer of this design option, according to DOE, is $4.74.

Experimental Tests. Parallel experimental and analytical studies were conducted to

determine the effects on oven energy consumption of reduced vent rate by reduction of vent

size.8 Good agreement was obtained between the measured values of energy consumption

and those predicted by analytical means. The analytical study correctly predicted that gross

reduction of vent cross section did indeed save energy, but did not deal with other

EE-RM-90-201 COMMENT OOR13

3. OTHER DOE DESIGN OPTIONS 

This chapter analyzes the design options that were first published in the ANOPR(9) and --

that DOE determined to be life-cycle justified in the NOPR. (3) The previously issued GRI 

report(8) analyzed these design options in detail. Additional analysis completed since the 

publication of the NOPR is presented in this chapter. The life-cycle cost analysis results 

from the GRI report have been updated for all of the DOE design options determined by 

DOE to be cost-effective. This was done so that all of the life-cycle cost information uses 

the same economic assumptions and is reported in one document. 

The design options covered in this chapter, all related to ovens, are: 

1. Reduced Vent Rate (Standard Ovens) 

2. Reflective Surfaces (Standard and Self-Cleaning Ovens) 

3. Added Insulation (Standard and Self-Cleaning Ovens) 

4. Reduced Thermal Mass (Standard and Self-Cleaning Ovens) 

5. Improved Insulation (Standard Ovens). 

Table 3-1 summarizes the results of the analysis of the above design options. 

1, Reduced Vent Rate 

Design Option. Energy efficiency is expected to be increased by red ucing the oven 

vent size so as to lower the oven vent rate. This option was proposed for the standard oven 

only. The added cost to the consumer of this design option, according to DOE, is $4.74. 

Experimental Tests. Parallel experimental and analytical studies were conducted to 

determine the effects on oven energy consumption of reduced vent rate by reduction of vent 

size. (8) Good agreement was obtained between the measured values of energy consumption 

and those predicted by analytical means. The analytical study correctly predicted that gross 

reduction of vent cross section did indeed save energy, but did not deal with other 
3-2

Table 3-1. Summary of Impacts of ANOPR Design Options on Gas Kitchen Ranges

and Ovens

DOE Design Option

Reduce vent rate,

standard oven

Reflective surtace,

ovens a

Added insulation,

ovens a

Reduced thermal

mass, ovens a

Improved insulation,

ovens a

Potential Issues

,

4. 0.03 N (0.36)

t (12.6) N

std (6.15)

sc (5.74) U

0 0 N

std (1.77)

sc(1.77) U

1. 0.58 b N (Loss) I

t (0.05) N (Loss) U

a. Both standard and self-cleaning

b. For removal of 5.52 lbs

= -,

• m

• • •

EE-RM-90-201 COMMENT OOR13

3-2 

Table 3-1. Summary of Impacts of ANOPR Design Options on Gas Kitchen Ranges 

and Ovens 

DOE Design Option 

Reduce vent rate, 

standard oven J. 0.03 N (0.36) • • • 

Reflective surface, 

i 

std (6.15) 

ovens a (12.6) N sc (5.74) • • • 

Added insulation, std (1.77) 

ovens a 0 0 N sc (1.77) • • 

Reduced thermal 

mass, ovens a J. O.58 b N (Loss) • • • • 

Improved insulation, 

ovens a i (0.05) N (Loss) • 

a. Both standard and self-cleaning 

b. For removal of 5.52 Ibs 
3-3

parameters such as performance, utility, emissions, and safety standards. When the vent size

was reduced to the point where the energy savings began to increase dramatically, it was

observed that the oven showed increased venting around the door bottom and seal, which

increased external surface temperatures. Also, carbon monoxide levels began to increase

rapidly with reduced vent size. Figure 3-1 shows the effect of reducing vent size on both

oven energy consumption and surface temperatures.

At reduced vent sizes that result in acceptable combustion, surface temperatures below

standards requirements, and no venting around the door seal, experimental tests show no

significant savings.8 The tests showed an increase in efficiency of about 0.03 percentage

point rather than the 0.62 percentage point increase estimated in the Technical Support

Document (TSD). (4)

The TSD quoted the 0.62 percentage point increase as an average from AHAM data

and ADM Associates ana1ysis. The AHAM data showed an increase of less than 1 percent but AHAM also stated:'

• . . the reduction in vent size could seriously effect JsicJ combustion

products as well as cookability and have a much more negative effect

on the environment (and the ability to pass AGA test) than any

positive effects one would gain from slightly improved efficiency.

The ADM document does report an energy efficiency improvement of 0.7 percentage point, but only for electric standard ovens. According to ADM, the reduced vent

option:

• . is not applicable for natural gas ovens. The difference in vent

diameters between standard and self-cleaning gas ovens is not

significantly d?fferent, as a satisfactory combustion environment must

be maintained [pg. 9-9].

Economics. This design option was determined not to be justified in the GRI report8

[pgs. 7-19 to 7-20] on the basis of the experimental measurements. With an efficiency

increase of 0.03 percentage points and cost increase as described above, this design option is

not economically justified (see Chapter 5, Economic Analysis, and Table 3-2).

EE-RM-90-201 COMMENT OOR13

3-3 

parameters such as performance, utility, emissions, and safety standards. When the vent size 

was reduced to the point where the energy savings began to increase dramatically, it was 

observed that the oven showed increased venting around the door bottom and seal, which 

increased external surface temperatures. Also, carbon monoxide levels began to increase 

rapidly with reduced vent size. Figure 3-1 shows the effect of reducing vent size on both 

oven energy consumption and surface temperatures. 

At reduced vent sizes that result in acceptable combustion, surface temperatures below 

standards requirements, and no venting around the door seal, experimental tests show no 

significant savings. (8) The tests showed an increase in efficiency of about 0.03 percentage 

point rather than the 0.62 percentage point increase estimated in the Technical Support 

Document (TSD). (4) 

The TSD quoted the 0.62 percentage point increase as an average from AHAM data 

and ADM Associates analysis. (22) The AHAM data showed an increase of less than 1 percent but AHAM also stated: (21) 

... the reduction in vent size could seriously effect [sic] combustion 

products as well as cookability and have a much more negative effect 

on the environment (and the ability to pass AGA test) than any 

positive effects one would gain from slightly improved efficiency. 

The ADM(22) document does report an energy efficiency improvement of 0.7 percentage point, but only for electric standard ovens. According to ADM, the reduced vent 

option: 

... is not applicable for natural gas ovens. The difference in vent 

diameters between standard and self-cleaning gas ovens is not 

significantly different, as a satisfactory combustion environment must 

be maintained [pg. 9-9]. 

Economics. This design option was determined not to be justified in the GRI report(8) 

[pgs. 7-19 to 7-20] on the basis of the experimental measurements. With an efficiency 

increase of 0.03 percentage points and cost increase as described above, this design option is 

not economically justified (see Chapter 5, Economic Analysis, and Table 3-2). 
3-4

C

0

0.

E

C

0

0

C

'U

C

0

a -1

C

0

9 1d

-1'

0 10 20 30 40 50 60 70 80 90

Area Reduction, %

Figure 3-1. Effect of reducing vent size on energy consumption and

surface temperature

210_

200

190

ci.

180 E

0

I-.

0

170

160

150

140

EE-RM-90-201 COMMENT OOR13

3-4 

2 

'it 

c - Energy Consumption J + 

0 

--

-Co 

E 

;::, 

G -4 

c 

0 

CJ Door Temperatures >0- -6 

eft 

... 

0 • • c 

w -8 

• c 152 F Standards limit 

CD 01-10 

c 

G • .c 

CJ .. 12 

• 

-14 

0 10 20 30 40 50 60 70 80 

Area Reduction, % 

Figure 3-1. Effect of reducing vent size on energy consumption and 

surface temperature 

210 

200 

190 u.. 

. 

-

Q. 

180 e 

CD 

ICD 

170 0 

-

• ... 

:2 

160 fI) 

... 

0 

0 

c 

130 

90 

- \ 
3-5

Table 3-2. Economic Analysis of Design Option: Reduced Vent Rate

Design Option

Net Energy Saved,

kBtu/yr

Annualized Net Savings,

$

Standard Oven [

7 -0.36

Cooking Quality Concerns. Even if this option had provided significant energy

savings, additional testing and analysis would be needed to address areas of cooking performance and moisture venting. This option affects air flow, heat distribution, and moisture

retention in the oven, which are all crucial to cooking quality. The primary function of the

vent (for a gas oven) is to exhaust the products of combustion and the moisture produced by

both the foods and the gas combustion during the cooking process. If the vent size is

reduced or restricted, moisture and heat can collect near the vent outlet with the possibility of

overcooking foods situated in that area.

Over the past several decades, oven and range manufacturers have optimized the vent

size and position to provide acceptable cooking quality for a wide variety of food products.

Any design changes to either the oven vent or the door seal would affect food quality and,

for some foods, make the cooking results unacceptable to the consumer.

Safety. Restricting the vent will also influence venting through the door seal, which is

an undesirable effect that can increase oven surface temperatures and lead to oven safety

problems.

Safety concerns associated with reducing the vent rate include increased surface

temperatures, increased levels of carbon monoxide and other combustion products, and

accumulation of steam, which would pose an increased risk of burns when the oven door

is opened.

EE-RM-90-201 COMMENT OOR13

3-5 

Table 3-2. Economic Analysis of Design Option: Reduced Vent Rate 

Net Energy Saved, Annualized Net Savings, 

Design Option kBtu/yr $ 

I Standard Oven I 7 I -0.36 I 

Cooking Quality Concerns. Even if this option had provided significant energy 

savings, additional testing and analysis would be needed to address areas of cooking performance and moisture venting. This option affects air flow, heat distribution, and moisture 

retention in the oven, which are all crucial to cooking quality. The primary function of the 

vent (for a gas oven) is to exhaust the products of combustion and the moisture produced by 

both the foods and the gas combustion during the cooking process. If the vent size is 

reduced or restricted, moisture and heat can collect near the vent outlet with the possibility of 

overcooking foods situated in that area. 

Over the past several decades, oven and range manufacturers have optimized the vent 

size and position to provide acceptable cooking quality for a wide variety of food products. 

Any design changes to either the oven vent or the door seal would affect food quality and, 

for some foods, make the cooking results unacceptable to the consumer. 

Safety. Restricting the vent will also influence venting through the door seal, which is 

an undesirable effect that can increase oven surface temperatures and lead to oven safety 

problems. 

Safety concerns associated with reducing the vent rate include increased surface 

temperatures, increased levels of carbon monoxide and other combustion products, and 

accumulation of steam, which would pose an increased risk of bums when the oven door 

is opened. 
3-6

2. Reflective Surfaces

Design Option. Reflective surfaces have been claimed to increase oven efficiency by

"reflecting and retaining infrared radiation within the oven cavity, thus increasing the -

percentage of useful heat."4 [pg. 1-251 This option would cost an additional $57.38

(AHAM) to consumers based on manufacturers' estimates and an appropriate markup to

consumer. (8)

Experimental Tests. Experimental data show that adding reflective surfaces in gas

ovens does not result in increased efficiency. Chrome plating the inner surfaces of the oven

resulted in a 12.61 percent decrease in energy efficiency.8 The increased reflectance caused

repeated thermostat cycling, which might have contributed to the higher energy consumption.

As DOE recognized for gas cooktops, concern about maintaining the reflectivity of

oven surfaces is an important factor to consider3 [pg. 10518]. This would be an even

greater problem for ovens, especially self-cleaning ovens, since the high self-cleaning

temperatures would destroy any known usable reflective surface during the first self-cleaning

cycle. Food spills, darkening from heat, and cleaning compounds would affect the reflective

surfaces, making cooking results unpredictable.

Cooking Quality. Extensive cooking tests would be required to accurately determine

the effects of this option on food quality. Overbrowning of surfaces with subsequent

underdone interiors for meat products is certainly a possibility. This option would cause

unpredictable cooking results and require extensive monitoring of the cooking process. Since

the surface would soon lose its reflective quality, which is not likely to be able to be restored

by conventional cleaning methods, this design option seems impractical while showing

increased energy usage, as indicated from the experimental study.

Economic Analysis. Because this design option increases gas consumption, it cannot

be economically justified (see Table 3-3).

EE-RM-90-201 COMMENT OOR13

3-6 

2. Reflective Surfaces 

Design Option. Reflective surfaces have been claimed to increase oven efficiency by 

"reflecting and retaining infrared radiation within the oven cavity, thus increasing the 

percentage of useful heat. ,,(4) [pg. 1-25] This option would cost an additional $57.38 

(AHAM) to consumers based on manufacturers' estimates and an appropriate markup to 

consumer. (8) 

Experimental Tests. Experimental data show that adding reflective surfaces in gas 

ovens does not result in increased efficiency. Chrome plating the inner surfaces of the oven 

resulted in a 12.61 percent decrease in energy efficiency. (8) The increased reflectance caused 

repeated thermostat cycling, which might have contributed to the higher energy consumption. 

As DOE recognized for gas cooktops, concern about maintaining the reflectivity of 

oven surfaces is an important factor to consider(3) [pg. 10518]. This would be an even 

greater problem for ovens, especially self-cleaning ovens, since the high self-cleaning 

temperatures would destroy any known usable reflective surface during the first self-cleaning 

cycle. Food spills, darkening from heat, and cleaning compounds would affect the reflective 

surfaces, making cooking results unpredictable. 

Cooking Quality. Extensive cooking tests would be required to accurately determine 

the effects of this option on food quality. Overbrowning of surfaces with subsequent 

underdone interiors for meat products is certainly a possibility. This option would cause 

unpredictable cooking results and require extensive monitoring of the cooking process. Since 

the surface would soon lose its reflective quality, which is not likely to be able to be restored 

by conventional cleaning methods, this design option seems impractical while showing 

increased energy usage, as indicated from the experimental study. 

Economic Analysis. Because this design option increases gas consumption, it cannot 

be economically justified (see Table 3-3). 
3-7

Table 3-3. Economic Analysis of Design Option: Reflective Surfaces

Design Option

Net Energy Saved,

kBtu/yr

Annualized Net Savings,

$

rStandard Oven -185 -6.15

Self-Clean Oven -129 -5.74

3. Added Insulation

Design Option. Increasing the insulation thickness (from 2 inches to 4 inches) is

proposed as a means to improve the energy efficiency of ovens. The sources used in the

TSD4 are the 1980 DOE Engineering Ana1ysis'5 and AHAM data. However, AHAM

stated:

Typically, the duration of the DOE bake test is under one hour.

Medium density insulation of approximately 1 inch thickness, or less

should hold the heat just as sufficiently for this period of time as

more &pensive high density and/or thicker insulation. . . Extra

insulation is added presently to retain the cavity heat, for faster

cooking, but to protect against ove[r] temperature of oven

components and kitchen wall surfaces.

The Engineering Analysis does include information for added insulation for gas ovens

but it shows significantly lower efficiency increases than those cited for electric ovens. The

TSD indicates that an increase of 1.4 percentage points is an average of AHAM data

(<0.1 percent) and Engineering Analysis data (for electric standard oven = 2.3 points).

This average is the value DOE used in its analysis. However, for gas ovens the Engineering

Analysis reports only a 0.4 percentage point increase for standard gas ovens resulting from

implementing bQth 4 inches of insulation 4 reducing the vent rate15 [pg. D7-9]. Hence,

the percentage increase in efficiency for standard gas ovens for the addition of insulation

must be less than 0.4 points. A value less than 0.4 percentage points was not used by DOE

in its analysis for gas ovens.

EE-RM-90-201 COMMENT OOR13

3-7 

Table 3-3. Economic Analysis of Design Option: Reflective Surfaces 

Net Energy Saved, Annualized Net Savings, 

Design Option kBtu/yr $ 

I Standard Oven 

I 

-185 

I 

-6.15 

: Self-Clean Oven -129 -5.74 

3. Added Insulation 

Design Option. Increasing the insulation thickness (from 2 inches to 4 inches) is 

proposed as a means to improve the energy efficiency of ovens. The sources used in the 

TSD(4) are the 1980 DOE Engineering Analysis(15) and AHAM data. However, AHAM 

stated: 

Typically, the duration of the DOE bake test is under one hour. 

Medium density insulation of approximately 1 inch thickness, or less 

should hold the heat just as sufficiently for this period of time as 

more expensive high density and/or thicker insulation. . . Extra 

insulation is added presently not to retain the cavity heat, for faster 

cooking, but to protect against ove[r] temperature of oven 

components and kitchen wall sUrfaces. (23) 

I 

The Engineering Analysis does include information for added insulation for gas ovens 

but it shows significantly lower efficiency increases than those cited for electric ovens. The 

TSD indicates that an increase of 1.4 percentage points is an average of AHAM data 

«0.1 percent) and Engineering Analysis data (for electric standard oven = 2.3 points) .. 

This average is the value DOE used in its analysis. However, for gas ovens the Engineering 

Analysis reports only a 0.4 percentage point increase for standard gas ovens resulting from 

implementing QQ!h 4 inches of insulation and reducing the vent rate(15) [pg. D7-9]. Hence, 

the percentage increase in efficiency for standard gas ovens for the addition of insulation 

must be less than 0.4 points. A value less than 0.4 percentage points was not used by DOE 

in its analysis for gas ovens. 
3-8

In addition, ADM [pg. 9-111 reported that:

• . . fiJncreased insulation thickness was not considered a viable

option, as it requires a reduction in cavity size and a corresponding

reduction in conswner utility.

Adding insulation to an oven will not directly affect food quality except that it may

require a reduced oven capacity. Most of the ranges produced today are made to fit in a

30-inch space and the only way to add insulation would be to decrease the oven cavity size.

This would result in a loss of utility to the consumer. A large oven size is one of the most

significant advertised marketing features for ovens and is valued by the consumer.

Analytical Modeling. Analytical modeling indicated that there would be n. increase

in energy efficiency when comparing 3- or 4-inch insulation with the 2-inch insulation in the

baseline gas oven.

Experimental Tests. Experimental data indicated that a slight efficiency increase

could be achieved by adding insulation in the broiler compartment of a conventional gas oven

where typically there is no insulation.8 This option does not exist for a self-cleaning oven.

The GRI report provides additional details about these tests. As was mentioned previously,

thicker insulation is added to ovens for surface temperature considerations, not for heat

retention or faster cooking cycles. Insulation has little effect on these parameters, and the

DOE test procedure is insensitive to increased insulation due to the short time frame of the

test where the insulation never reaches thermal equilibrium. Actually, increased or improved

insulation can lead to decreased efficiency because it will act as a thermal heat sink during

the early stages of cooking.

Economics. The design option of increasing the insulation thickness from 2 inches to

4 inches will not result in an increase in efficiency for gas ovens. Therefore, the option is

not economically justified under any cost consideration (See Table 3-4).

EE-RM-90-201 COMMENT OOR13

3-8 

In addition, ADM(22) [pg. 9-11] reported that: 

. . . [ilncreased insulation thickness was not considered a viable 

option, as it requires a reduction in cavity size and a corresponding 

reduction in consumer utility. 

Adding insulation to an oven will not directly affect food quality except that it may 

require a reduced oven capacity. Most of the ranges produced today are made to fit in a 

3D-inch space and the only way to add insulation would be to decrease the oven cavity size. 

This would result in a loss of utility to the consumer. A large oven size is one of the most 

significant advertised marketing features for ovens and is valued by the consumer. 

Analytical Modeling. Analytical modeling indicated that there would be ll.Q increase 

in energy efficiency when comparing 3- or 4-inchinsulation with the 2-inch insulation in the 

baseline gas oven. 

Experimental Tests. Experimental data indicated that a slight efficiency increase 

could be achieved by adding insulation in the broiler compartment of a conventional gas oven 

where typically there is no insulation. (8) This option does not exist for a self-cleaning oven. 

The GRI report provides additional details about these tests. As was mentioned previously, 

thicker insulation is added to ovens for surface temperature considerations, not for heat 

retention or faster cooking cycles. Insulation has little effect on these parameters, and the 

DOE test procedure is insensitive to increased insulation due to the short time frame of the 

test where the insulation never reaches thermal equilibrium. Actually, increased or improved 

insulation can lead to decreased efficiency because it will act as a thermal heat sink during 

the early stages of cooking. 

Economics. The design option of increasing the insulation thickness from 2 inches to 

4 inches will not result in an increase in efficiency for gas ovens. Therefore, the option is 

not economically justified under any cost consideration (See Table 3-4). 
3-9

Table 3-4. Economic Analysis of Design Option: Added Insulation

Design Option

Net Energy Saved,

kBtu/yr

Annualized Net Savings,

$

Standard Oven 0 -1.77

Self-Clean Oven 0 -1.77

4, Reduced Thermal Mass

Design Option. This design option is intended to reduce the energy absorbed by oven

components to increase the energy efficiency. According to DOE, the added cost to

consumers would be $4.82 and $7.47 for standard and self-cleaning ovens, respectively. Not

considered in these cost estimates was the increased maintenance cost from failure of the

thinner and weaker material.

Experimental Tests. Experimental tests found only a 0.58 percent (or 0.04 percentage point) increase in energy efficiency for a self-cleaning range with an equivalent of

5.52 pounds of wall material removed (compared with walls of approximately 25 pounds in a

standard gas oven)8 {pg. 7-33]. The reduction in thermal mass was obtained by removing

one rack and the waist-high broiler from the oven. This, of course, would not be possible in

a production range and the mass would have to be reduced by use of a lighter metal gauge or

a lighter material for the oven racks. The thermal mass effects would be comparable,

however.

The use of porcelain coatings on the oven walls is standard practice for oven

construction. The use of thinner walls would not allow the use of this coating. The

porcelain would crack and craze or even flake off if thinner walls were used, and this would

be unacceptable to the consumer.

EE-RM-90-201 COMMENT OOR13

3-9 

Table 3-4. Economic Analysis of Design Option: Added Insulation 

Net Energy Saved, Annualized Net Savings, 

Design Option kBtu/yr $ 

I Standard Oven 

I 

0 

I 

-1.77 

I : Self-Clean Oven 0 -1.77 

4. Reduced Thermal Mass 

Design Option. This design option is intended to reduce the energy absorbed by oven 

components to increase the energy efficiency. According to DOE, the added cost to 

consumers would be $4.82 and $7.47 for standard and self-cleaning ovens, respectively. Not 

considered in these cost estimates was the increased maintenance cost from failure of the 

thinner and weaker material. 

Experimental Tests. Experimental tests found only a 0.58 percent (or 0.04 percentage point) increase in energy efficiency for a self-cleaning range with an equivalent of 

5.52 pounds of wall material removed (compared with walls of approximately 25 pounds in a 

standard gas oven)(8) [pg. 7-33]. The reduction in thermal mass was obtained by removing 

one rack and the waist-high broiler from the oven. This, of course, would not be possible in 

a production range and the mass would have to be reduced by use of a lighter metal gauge or 

a lighter material for the oven racks. The thermal mass effects would be comparable, 

however. 

The use of porcelain coatings on the oven walls is standard practice for oven 

construction. The use of thinner walls would not allow the use of this coating. The 

porcelain would crack and craze or even flake off if thinner walls were used, and this would 

be unacceptable to the consumer. 
3-10

Other Sources. The TSD4 references AHAM,' and ORTECH14 for the

efficiency improvement numbers. AHAM claims less than 0.1 percent increase in efficiency.

ADM [pgs. 9-18 and 9-19] suggested a 0.5 percentage point increase but said that the option

is "not feasible due to extensive retooling requirement" for both standard and self-clean gas

ovens. ORTECH references the 1977 Science Applications, Inc. ,17) report for the 8 percent

improvement for electric standard and self-cleaning ovens. However, SAl reports only a

3.4 percent improvement for gas standard ovens and says this option is "not applicable" to

gas self-cleaning ovens'7 [pg. 11].

Consumer Utility. If the reduction in thermal mass is to be accomplished with a

smaller oven cavity, the utility of the oven would be decreased. Consumers prefer larger

oven cavities as documented by oven ratings in Consumer Reports'24 and advertising

material related to gas ranges (See Appendix C, Exhibit 3).

Safety Concerns. The GRI analysis and subsequent manufacturer consensus indicate

that the magnitude of thermal mass reduction assumed by DOE is not possible without

serious degradation in range strength and durability, particularly for shipping. The mass of

ranges has been reduced to a practical limit, evidenced by the need for safety brackets to

prevent the range from tipping from someone leaning on it or from a heavy load on the oven

door. Reduction of thermal mass raises questions of product utility, safety, and stability and

is not practical for the typical consumer range.

Economic Analysis. This option is not technically feasible without reduction of the

oven cavity size. Since this would remove a consumer-desired feature and would not allow

preparation of large, multi-course family meals, it should not be mandated. Life-cycle costs

using the DOE cost to consumer and an efficiency improvement of 0.5 percent show that this

option is not economically justified (see Appendix A).

EE-RM-90-201 COMMENT OOR13

3-10 

Other Sources. The TSD(4) references AHAM, (2\) ADM, (22) and ORTECH(l4) for the 

efficiency improvement numbers. AHAM claims less than 0.1 percent increase in efficiency. 

ADM [pgs. 9-18 and 9-19] suggested a 0.5 percentage point increase but said that the option 

is "not feasible due to extensive retooling requirement" for both standard and self-clean gas ---

ovens. ORTECH references the 1977 Science Applications, Inc., (17) report for the 8 percent 

improvement for electric standard and self-cleaning ovens. However, SAl reports only a 

3.4 percent improvement for gas standard ovens and says this option is "not applicable" to 

gas self-cleaning ovens(17) [pg. 11]. 

Consumer Utility. If the reduction in thermal mass is to be accomplished with a 

smaller oven cavity, the utility of the oven would be decreased. Consumers prefer larger 

oven cavities as documented by oven ratings in Consumer Reports(24) and advertising 

material related to gas ranges (See Appendix C, Exhibit 3). 

Safety Concerns. The GRI analysis and subsequent manufacturer consensus indicate 

that the magnitude of thermal mass reduction assumed by DOE is not possible without 

serious degradation in range strength and durability, particularly for shipping. The mass of 

ranges has been reduced to a practical limit, evidenced by the need for safety brackets to 

prevent the range from tipping from someone leaning on it or from a heavy load on the oven 

door. Reduction of thermal mass raises questions of product utility, safety, and stability and 

is not practical for the typical consumer range. 

Economic Analysis. This option is not technically feasible without reduction of the 

oven cavity size. Since this would remove a consumer-desired feature and would not allow 

preparation of large, multi-course family meals, it should not be mandated. Life-cycle costs 

using the DOE cost to consumer and an efficiency improvement of 0.5 percent show that this 

option is not economically justified (see Appendix A). 
3-11

5. Improved Insulation

Design Option. Improving the density of insulation in standard ovens to the level in

self-clean ovens (1.09 ibm/ft3 to 1.91 ibm/ft3) was proposed as an option to increase the -

efficiency of ovens.

Experimental Tests. Experimental tests were performed on both standard and selfcleaning gas ovens with improved insulation (lower thermal conductivity). Both resulted in

decreased energy efficiency. The standard oven had an energy efficiency decrease of

0.05 percentage points. The self-cleaning oven had a decrease of 0. 15 percentage points.8

Tests performed on standard ovens with higher insulation densities showed an efficiency

decrease, also.

As mentioned in the section discussing the effects of added insulation, with the current,

relatively short duration DOE test procedure, the improved (higher density) insulation acts as

additional thermal mass. The benefits of improved insulation would only be seen after long

periods of cooking, which are not representative of typical consumer use. Higher levels of

insulation are used on self-cleaning ovens to maintain low surface temperatures (code

compliance), safety, and protect control components and kitchen cabinets. Adding insulation

around the broiler compartment of a standard oven did increase the efficiency; however, this

was not cost-effective on a life-cycle cost basis.

Economics. Since this option reduces energy efficiency, it would result in added cost

to the consumer and is not life-cycle cost effective.

EE-RM-90-201 COMMENT OOR13

3-11 

S. Improved Insulation 

Design Option. Improving the density of insulation in standard ovens to the level in 

self-clean ovens (1.09 Ibm/ft3 to 1.91 Ibm/ft3

) was proposed as an option to increase the 

efficiency of ovens. 

Experimental Tests. Experimental tests were performed on both standard and selfcleaning gas ovens with improved insulation (lower thermal conductivity). Both resulted in 

decreased energy efficiency. The standard oven had an energy efficiency decrease of 

0.05 percentage points. The self-cleaning oven had a decrease of 0.15 percentage points. (8) 

Tests performed on standard ovens with higher insulation densities showed an efficiency 

decrease, also. 

As mentioned in the section discussing the effects of added insulation, with the current, 

relatively short duration DOE test procedure, the improved (higher density) insulation acts as 

additional thermal mass. The benefits of improved insulation would only be seen after long 

periods of cooking, which are not representative of typical consumer use. Higher levels of 

insulation are used on self-cleaning ovens to maintain low surface temperatures (code 

compliance), safety, and protect control components and kitchen cabinets. Adding insulation 

around the broiler compartment of a standard oven did increase the efficiency; however, this 

was not cost-effective on a life-cycle cost basis. 

Economics. Since this option reduces energy efficiency, it would result in added cost 

to the consumer and is not life-cycle cost effective. 
3-12

EE-RM-90-201 COMMENT OOR13

3-12 
4. OPTIONS REJECTED BY THE DOE

This chapter discusses the design options that DOE rejected in its NOPR. (3) Analysis -

supports the rejection of each of these options because none is economically justified. The

options covered in this chapter are:

1. Forced Convection (Self-Cleaning Oven)

2. Oven Separator (Standard and Self-Cleaning Oven)

3. Reduced Conduction Losses (Standard and Self-Cleaning Oven)

4. Sealed Burners (Cooktops)

5. Reflective Surfaces (Cooktops)

6. Thermostatic Burners (Cooktops).

Table 4-1 summarizes the results for the design options rejected by DOE.

1. Forced Convection (Self-Clean Oven)

Design Option. Forced convection for a self-cleaning oven was rejected by DOE but

determined to be cost-effective for standard ovens. Life-cycle economic analysis rejects

forced convection for both standard and self-cleaning ovens because of the high cost of

implementing this option for a gas oven. If a gas convection oven does become available,

consumers might be willing to pay an increased price for the features offered by a convection

oven, but it is unlikely that a decision to purchase would be made using energy savings as a

basis. Detailed discussion of this option for standard ovens is presented in Chapter 2.

2. Oven Separator

Design Option. For small oven loads, an oven separator would effectively reduce the

oven cavity size because less energy would be required to heat a smaller cavity. An oven

separator would need to be designed for easy and safe installation and removal by the

EE-RM-90-201 COMMENT OOR13

4. OPTIONS REJECTED BY THE DOE 

This chapter discusses the design options that DOE rejected in its NOPR. (3) Analysis 

supports the rejection of each of these options because none is economically justified. The 

options covered in this chapter are: 

1. Forced Convection (Self-Cleaning Oven) 

2. Oven Separator (Standard and Self-Cleaning Oven) 

3. Reduced Conduction Losses (Standard and Self-Cleaning Oven) 

4. Sealed Burners (Cooktops) 

5. Reflective Surfaces (Cooktops) 

6. Thermostatic Burners (Cooktops). 

Table 4-1 summarizes the results for the design options rejected by DOE. 

1. Forced Convection (Self-Clean Oven) 

Design Option. Forced convection for a self-cleaning oven was rejected by DOE but 

determined to be cost-effective for standard ovens. Life-cycle economic analysis rejects 

forced convection for both standard and self-cleaning ovens because of the high cost of 

implementing this option for a gas oven. If a gas convection oven does become available, 

consumers might be willing to pay an increased price for the features offered by a convection 

oven, but it is unlikely that a decision to purchase would be made using energy savings as a 

basis. Detailed discussion of this option for standard ovens is presented in Chapter 2. 

2. Oven Separator 

Design Option. For small oven loads, an oven separator would effectively reduce the 

oven cavity size because less energy would be required to heat a smaller cavity. An oven 

separator would need to be designed for easy and safe installation and removal by the 
4-2

Table 4-1. Summary of Impacts of Rejected DOE Design Options on Gas Ranges

and Ovens

Potential Issues

., DOE Design Option 0 S

Forced convection,

self-clean oven 4. •5 a N (Loss) b b

Oven separator,

ovens c 4. 39.8 N (Loss) • •

Reduced conduction

losses, ovens C 4. 20.3 N (Loss)

Sealed burners,

cooktops 0 0 N (Loss)

Reflective surfaces,

cooktops 4. 0.07 N (Loss)

Thermostatic

burners, cooktops 0 - N (Loss) U

a. Estimate based on manufacturers testing

electric forced convection ovens

b. If required for all cooking

c. Both standard and self-cleaning

EE-RM-90-201 COMMENT OOR13

4-2 

Table 4-1. Summary of bnpacts of Rejected DOE Design Options on Gas Ranges 

and Ovens 

DOE Design Option 

Forced convection, 

self-clean oven .1. 5.5 8 N (Loss) • • .b .b 

Oven separator, 

ovens C .1. 39.8 N (Loss) • • • • • • 

Reduced conduction 

losses, ovens C .1. 20.3 N (Loss) 

Sealed burners, 

cooktops a a N (Loss) 

Reflective surfaces, 

cooktops .1. 0.07 N (Loss) • 

Thermostatic 

burners, cooktops a N (Loss) • • 

8. Estimate based on manufacturers testing 

electric forced convection ovens 

b. If required for all cooking 

c. Both standard and self-cleaning 
4-3

consumer. This option was proposed for both standard and self-cleaning ovens. The

increased cost to consumers was estimated by DOE to be $25.38 for a standard oven and

$32.95 for a self-cleaning oven. GRE-estimated costs using input from manufacturers

averaged $124.59.(8) This estimate is considerably higher than the DOE estimate since, in a

gas oven, it is technically difficult to implement this design option. Changes must be made

in the thermostat location, reduced burner input, oven vent construction, and required

controls interlocks.

Experimental Tests. Experimental tests did show that the rated energy efficiency of

the oven would increase when an oven separator is used.8 If it is not used, obviously there

is no reduction in energy consumption. The efficiency increased by about 39.8 percent (or

2.5 percentage points) when a separator was used. Further details of the experimental test

can be found in Reference 8.

However, the actual impact on energy consumption is difficult to estimate due to the

expected discretionary use by the consumer of this option. Toaster ovens and microwaves

are already available and are used for smaller cooking loads. These options are much more

attractive than the use of a partition that must be stored when not in use.

Economics. For the economic analysis, the oven separator was assumed to be used for

only 50 percent of cooking. Even using the DOE cost assumptions, this option would not be

life-cycle cost justified. Our analysis agrees with the DOE result that this design option

should not be adopted.

Cooking Concerns. This option reduces consumer utility of the oven because it

requires more consumer interaction and knowledge. An oven separator may also create

difficulties with temperature control that would affect cooking quality. This option would

make meeting standards difficult because of safety concerns and performance issues.

EE-RM-90-201 COMMENT OOR13

4-3 

consumer. This option was proposed for both standard and self-cleaning ovens. The 

increased cost to consumers was estimated by DOE to be $25.38 for a standard oven and 

$32.95 for a self-cleaning oven. GRI-estimated costs using input from manufacturers 

averaged $124.59.(8) This estimate is considerably higher than the DOE estimate since, in a 

gas oven, it is technically difficult to implement this design option. Changes must be made 

in the thermostat location, reduced burner input, oven vent construction, and required 

controls interlocks. 

Experimental Tests. Experimental tests did show that the rated energy efficiency of 

the oven would increase when an oven separator is used. (8) If it is not used, obviously there 

is no reduction in energy consumption. The efficiency increased by about 39.8 percent (or 

2.5 percentage points) when a separator was used. Further details of the experimental test 

can be found in Reference 8. 

However, the actual impact on energy consumption is difficult to estimate due to the 

expected discretionary use by the consumer of this option. Toaster ovens and microwaves 

are already available and are used for smaller cooking loads. These options are much more 

attractive than the use of a partition that must be stored when not in use. 

Economics. For the economic analysis, the oven separator was assumed to be used for 

only 50 percent of cooking. Even using the DOE cost assumptions, this option would not be 

life-cycle cost justified. Our analysis agrees with the DOE result that this design option 

should not be adopted. 

Cooking Concerns. This option reduces consumer utility of the oven because it 

requires more consumer interaction and knowledge. An oven separator may also create 

difficulties with temperature control that would affect cooking qUality. This option would 

make meeting standards difficult because of safety concerns and performance issues. 
4-4

Safety Concerns. Safety is a concern because of the increased likelihood for burns

from removIng the bulky and potentially hot separator from the oven. System interlocks may

be required.

Due to the high added cost, consumer utility concerns, and safety concerns, this option

is not justified.

3. Reduced Conduction Losses

Design Option. This option seeks to reduce conduction paths in the oven to reduce

heat losses. DOE suggested that this could be accomplished by improving the oven door by

adding an "additional thermal break and a modified inner panel. "4)

Experimental Tests. This option was evaluated by comparing the efficiency of a

standard gas oven with a self-cleaning oven that had design features that reduce conduction

loss. Testing the option in this manner did not isolate the effect of reduced conduction losses

because the higher efficiency of self-cleaning ovens is partially due to greater insulation in

and around the oven cavity and the oven door, and to differences in the oven door window

glass. Building a standard oven like a self-cleaning oven does increase its efficiency and

decrease its gas consumption. See Reference 8, page 7-24, for a full discussion of this

design option.

Economics. While this option did demonstrate higher efficiencies, the added cost of

$93.82 far outweighed the energy savings, maldng the option not economically justified.

Self-cleaning ovens already incorporate design features that reduce conduction losses and

achieve greater efficiency. The consumer is willing to pay the costs associated with the selfcleaning feature that automatically provides the added advantage of increased efficiency.

Judged only as an energy-saving design option, there is no life-cycle cost justification8 for

this design option.

EE-RM-90-201 COMMENT OOR13

4-4 

. Safety Concerns. Safety is a concern because of the increased likelihood for bums 

from removing the bulky and potentially hot separator from the oven. System interlocks may 

be required. 

Due to the high added cost, consumer utility concerns, and safety concerns, this option --

is not justified. 

3. Reduced Conduction Losses 

Design Option. This option seeks to reduce conduction paths in the oven to reduce 

heat losses. DOE suggested that this could be accomplished by improving the oven door by 

adding an "additional thermal break and a modified inner panel. .. (4) 

Experimental Tests. This option was evaluated by comparing the efficiency of a 

standard gas oven with a self-cleaning oven that had design features that reduce conduction 

loss. Testing the option in this manner did not isolate the effect of reduced conduction losses 

because the higher efficiency of self-cleaning ovens is partially due to greater insulation in 

and around the oven cavity and the oven door, and to differences in the oven door window 

glass. Building a standard oven like a self-cleaning oven does increase its efficiency and 

decrease its gas consumption. See Reference 8, page 7-24, for a full discussion of this 

design option. 

Economics. While this option did demonstrate higher efficiencies, the added cost of 

$93.82 far outweighed the energy savings, making the option not economically justified. 

Self-cleaning ovens already incorporate design features that reduce conduction losses and 

achieve greater efficiency. The consumer is willing to pay the costs associated with the selfcleaning feature that automatically-provides the added advantage of increased efficiency. 

Judged only as an energy-saving design option, there is no life-cycle cost justification(8) for 

this design option. 

. \ 
4-5

4, Sealed Burners

Design Option. Sealed burners offer the feature of the cooktop surface extending

around the burners, which makes cleaning much easier. Conventional burners, by contrast,

have an open area around the burner. Most high-end ranges already incorporate sealed

burners as standard equipment. Consumers have been adopting this design option at a rapid

rate, indicating their willingness to pay the added cost for the convenience of easier cleaning.

Experimental Tests. Experimental data comparing efficiencies of conventional

burners and sealed burners obtained during the GRI experimental study8 show essentially no

changes in efficiency for sealed burners. Additionally, large efficiency variations were found

among both conventional and sealed burners, even among burners with the same input rating

on the same cooktop. These variations were greater than any measured efficiency

differences.

Other Sources. The International Gas Research Conference (IGRC) study cited in

the TSD4 used boiling water tests, which are not comparable to the DOE test procedure. In

addition, the IGRC report was misquoted in the TSD on page 1-12 as stating "that the

reduction in secondary air results in more primary aeration to the sealed burner. "(4) The

IGRC report says "it has been necessary to increase the primary aeration" because of the

reduced secondary air associated with the sealed burner.' These two statements are not

technically the same. Reduction in secondary air does not "result" in more primary aeration,

but requires design changes to provide increased primary air for proper combustion. This

has implications of additional cost, complexity, and maintenance.

Economics. In addition to showing no statistically valid efficiency increase, the added

cost to consumers of $43.82, determined by DOE,4 makes this design option not justified by

life-cycle cost analysis. However, more and more consumers are willing to pay the added

cost for sealed burners because of the added utility of easier cleaning, not because of any

potential energy savings.

EE-RM-90-201 COMMENT OOR13

4-5 

4. Sealed Burners 

Design Option. Sealed burners offer the feature of the cooktop surface extending 

around the burners, which makes cleaning much easier. Conventional burners, by contrast, 

have an open area around the burner. Most high-end ranges already incorporate sealed 

burners as standard equipment. Consumers have been adopting this design option at a rapid 

rate, indicating their willingness to pay the added cost for the convenience of easier cleaning. 

Experimental Tests. Experimental data comparing efficiencies of conventional 

burners and sealed burners obtained during the GRI experimental study(8) show essentially no 

changes in efficiency for sealed burners. Additionally, large efficiency variations were found 

among both conventional and sealed burners, even among burners with the same input rating 

on the same cooktop. These variations were greater than any measured efficiency 

differences. 

Other Sources. The International Gas Research Conference (IGRC) study(25) cited in 

the TSD(4) used boiling w~ter tests, which are not comparable to the DOE test procedure. In 

addition, the IGRC report was misquoted in the TSD on page 1-12 as stating "that the 

reduction in secondary air results in more primary aeration to the sealed burner. ,,(4) The 

IGRC report says "it has been necessary to increase the primary aeration" because of the 

reduced secondary air associated with the sealed burner. (21) These two statements are not 

technically the same. Reduction in secondary air does not "result" in more primary aeration, 

but requires design changes to provide increased primary air for proper combustion. This 

has implications of additional cost, complexity, and maintenance. 

Economics. In addition to showing no statistically valid efficiency increase, the added 

cost to consumers of $43.82, determined by DOE, (4) makes this design option not justified by 

life-cycle cost analysis. However, more and more consumers are willing to pay the added 

cost for sealed burners because of the added utility of easier cleaning, not because of any 

potential energy savings. 
4-6

5. Reflective Surfaces (Cooktos)

Design Option. Adding highly polished or chrome pans beneath the burner was

rejected as a cooktop design option by DOE due to a concern for the longevity of the

surfaces. (4

Experimental Tests. For gas cooktops, experimental data confirm that the efficiency

increase resulting from adding reflective surfaces is very small, about only 0.1 percent or

0.04 percentage points. See Reference 8, page 7-9, for a complete discussion of this option.

This design option was not life-cycle cost justified. Testing supports DOE's concern about

the longevity of reflective surfaces.

6. Thermostatic Burners

Design Option. Thermostatically controlled burners use a sensing element to monitor

and control the temperature of the cooking pot. The system, as implemented in the past, had

poor reaction time and was relatively expensive. This option was available in the l950s and

1960s but manufacturers discontinued the feature because of numerous maintenance

problems, inaccurate results, and consumer complaints.

Analysis8 confirms the DOE conclusion that the use of thermostatically controlled

burners would not result in an efficiency increase and should not be considered as a proposed

design option for improved energy efficiency.

EE-RM-90-201 COMMENT OOR13

4-6 

5. Reflective Surfaces (Cooktopsl 

Design Option. Adding highly polished or chrome pans beneath the burner was 

rejected as a cooktop design option by DOE due to a concern for the longevity of the 

surfaces. (4) 

Experimental Tests. For gas cooktops, experimental data confirm that the efficiency 

increase resulting from adding reflective surfaces is very small, about only 0.1 percent or 

0.04 percentage points. See Reference 8, page 7-9, for a complete discussion of this option. 

This design option was not life-cycle cost justified. Testing supports DOE's concern about 

the longevity of reflective surfaces. 

6. Thennostatic Burners 

Design Option. Thermostatically controlled burners use a sensing element to monitor 

and control the temperature of the cooking pot. The system, as implemented in the past, had 

poor reaction time and was relatively expensive. This option was available in the 1950s and 

1960s but manufacturers discontinued the feature because of numerous maintenance 

problems, inaccurate results, and consumer complaints. 

Analysis(8) confirms the DOE conclusion that the use of thermostatically controlled 

burners would not result in an efficiency increase and should not be considered as a proposed 

design option for improved energy efficiency. 
5• METHODOLOGY FOR ECONOMIC ANALYSIS

An economic analysis was conducted for each of the design options evaluated, using

the consumer costs and savings expected to occur over the life of the range. This analysis is

called a life-cycle analysis. The results of the life-cycle cost analysis are summarized below.

Detailed results are presented in Appendix A.

Assumptions

Energy costs are based on the DOE/EIA residential projections for the Reference Case

published in DOE's Annual Energy Outlook, J994) and Average Regional End-Use Energy

Price Projections to the Year 2030(1D Prices were converted to 1990 dollars using the GDP

Implicit Price Deflator (Deflator 1990, 113.3; 1992, 12.1). Dollars were converted to 1990

values to make direct comparison with the DOE analysis4 easier.

The DOE analysis multiplies average national gas prices by 1.2, presumably to reflect

an assumption that range gas prices should reflect the first, and "highest priced," block of

gas. However, gas utilities do not distinguish between residential gas destined to ranges

versus other gas equipment. There are no "time of day" or appliance-specific rates applied

to the fuel. Given the non-specific nature of gas delivery, the only justifiable pricing

rationale is to assume average-priced fuel to each of the residential appliances. There is no

basis to assume consumers place a higher value on fuel delivered for particular applications.

For these reasons, this study does not use the 1.2 factor and it 'is recommended that DOE

also not use this multiplier.

Range energy use is based on the metered appliance study27 for a range with electric

ignition, the DOE Technical Support Document,4 and the DOE procedures given in the

Code of Federal Regulations.6 Gas use for ovens was estimated to be 1.092 million Btu

and for cooktops, 1.148 million Btu. Details on the derivation, how the useful gas amounts

were estimated, and how efficiencies are calculated are given Appendix D. In the calculations, the energy used by the oven pilot(s) and electric oven igniter(s) during the test is

EE-RM-90-201 COMMENT OOR13

5. METHODOLOGY FOR ECONOMIC ANALYSIS 

An economic analysis was conducted for each of the design options evaluated, using 

the consumer costs and savings expected to occur over the life of the range. This analysis is 

called a life-cycle analysis. The results of the life-cycle cost analysis are summarized below. 

Detailed results are presented in Appendix A. 

Assumptions 

Energy costs are based on the DOE/EIA residential projections for the Reference Case 

published in DOE's Annual Energy Outlook, 1994<10) and Average Regional End-Use Energy 

Price Projections to the Year 2030. (11) Prices were converted to 1990 dollars using the GOP 

Implicit Price Deflator (Deflator 1990, 113.3; 1992, 12.1). Dollars were converted to 1990 

values to make direct comparison with the DOE analysis(4) easier. 

The DOE analysis multiplies average national gas prices by 1.2, presumably to reflect 

an assumption that range gas prices should reflect the first, and "highest priced," block of 

gas. However, gas utilities do not distinguish between residential gas destined to ranges 

versus other gas equipment. There are no "time of day" or appliance-specific rates applied 

to the fuel. Given the non-specific nature of gas delivery, the only justifiable pricing 

rationale is to assume average-priced fuel to each of the residential appliances. There is no 

basis to assume consumers place a higher value on fuel delivered for particular applications. 

For these reasons, this study does not use the 1.2 factor and it is recommended that DOE 

also not use this multiplier. 

Range energy use is based on the metered appliance study(27) for a range with electric 

ignition, the DOE Technical Support Document,(4) and the DOE procedures given in the 

Code of Federal Regulations. (26) Gas use for ovens was estimated to be 1.092 million Btu 

and for cooktops, 1.148 million Btu. Details on the derivation, how the useful gas amounts 

were estimated, and how efficiencies are calculated are given Appendix D. In the calculations, the energy used by the oven pilot(s) and electric oven igniter(s) during the test is 
5-2

included in the analyzed data. Energy for a standing pilot or for self-cleaning during

noncooking periods and the clock and/or fan for self-cleaning was included in calculating the

annual usage. Energy for the clock is assigned to the oven, as specified in the DOE test

method.

Consumer Cost

The incremental cost to the consumer for a range unit with a specific design option was

based on estimates made by manufacturers and industry consultants (Reference 8, Appendix E) or DOE estimates were used.4 Costs were converted to constant 1990 dollars using

the GDP Implicit Price Deflator (1990, 113.3; 1992, 121. 1; 1994 First Quarter, 125.7).

Incremental cost is defined as the difference in consumer price between a range unit with a

specific DOE design option and the baseline unit. Detailed inputs and analyses are provided

in the tables in Appendix A for each of the cases examined within a given category of design

options. The retail costs were based on a factory floor manufacturing cost and a markup

factor of 2.81, based on estimates prepared by an industry consultant in conjunction with a

survey by AHAM.8

Maintenance costs for the baseline and modified units have been included only for

intermittent ignition devices (lID) (based on DOE's national cost estimate for a cooktop lID,

which was used for both cooktop and oven lIDs) and for forced convection to cover fan

maintenance. The Technical Support Document4 cautions that the value should be lower for

ovens, but using this cost is probably better than ignoring the cost. (The national value,

which was estimated from San Francisco survey results and the Means regional cost factors,

may be too low since the Means factors apply to commercial construction, which is highly

unionized in the Bay Area.)

Costs to the consumer as a result of any required certification program are not

included. Preliminary estimates for the costs associated with a certification program are

given in Reference 8, Appendix G, but are not included in the consumer cost.

EE-RM-90-201 COMMENT OOR13

5-2 

included in the analyzed data. Energy for a standing pilot or for self-cleaning during 

noncooking periods and the clock and/or fan for self-cleaning was included in calculating the 

annual usage. Energy for the clock is assigned to the oven, as specified in the DOE test 

method. 

Consumer Cost 

The incremental cost to the consumer for a range unit with a specific design option was 

based on estimates made by manufacturers and industry consultants (Reference 8, Appendix E) or DOE estimates were used. (4) Costs were converted to constant 1990 dollars using 

the GDP Implicit Price Deflator (1990, 113.3; 1992, 121.1; 1994 First Quarter, 125.7). 

Incremental cost is defined as the difference in consumer price between a range unit with a 

specific DOE design option and the baseline unit. Detailed inputs and analyses are provided 

in the tables in Appendix A for each of the cases examined within a given category of design 

options. The retail costs were based on a factory floor manufacturing cost and a markup 

factor of 2.81, based on estimates prepared by an industry consultant in conjunction with a 

survey by AHAM.(8) 

Maintenance costs for the baseline and modified units have been included only for 

intermittent ignition devices (110) (based on DOE's national cost estimate for a cooktop 110, 

which was used for both cooktop and oven lIDs) and for forced convection to cover fan 

maintenance. The Technical Support Document<4) cautions that the value should be lower for 

ovens, but using this cost is probably better than ignoring the cost. (The national value, 

which was estimated from San Francisco survey results and the Means regional cost factors, 

may be too low since the Means factors apply to commercial construction, which is highly 

unionized in the Bay Area.) 

Costs to the consumer as a result of any required certification program are not 

included. Preliminary estimates for the costs associated with a certification program are 

given in Reference 8, Appendix G, but are not included in the consumer cost. 
5-3

Life-Cycle Cost Analysis

The discounted cash flow (DCF) technique is a commonly used method for making

economic comparisons between alternative ways of accomplishing a given long-term task or

function. It is particularly useful when the different proposals being evaluated have different

cash flow patterns, i.e., the costs and savings associated with each proposal differ in both

magnitude and time of occurrence. Valid comparisons may be made between economically

diverse proposals because the DCF technique uses discount factors to account for the "time

value of money." The concept of the time value of money recognizes that a dollar spent or

received today can be compared to a dollar spent or received at a point in the future only

when provision is made to account for the effect of compounded interest. The input

information needed for an economic comparison by DCF analysis is (1) the magnitude of and

time of occurrence of the costs and benefits related to each proposal, and (2) the appropriate

discount or interest rate.

Approach and Financial Assumptions

The life-cycle cost model employed for the analysis is similar to the approach that

Lawrence Berkeley Laboratory (LBL) used in its analysis for DOE.9 Specific assumptions

used in the study are as follows:

• Life of the range unit was assumed to be 19 years, DOE data. (An AHAM

survey gives 18 years.)

• All costs are in constant 1990 dollars to make comparison with the DOE

analysis4 easier.

• Where data from other years were used, they were transformed to 1990 dollars

using the GDP Implicit Price Deflator.

• The discount rates are real discount rates, i.e., they are market rates adjusted for

inflation. Real rates of 2, 6, and 15 percent were used as stipulated by DOE. A

7 percent rate was also used because it was previously used by DOE.

• All cash flows are assumed to occur at year end.

EE-RM-90-201 COMMENT OOR13

5-3 

Life-Cycle Cost Analysis 

The discounted cash flow (DCF) technique is a commonly used method for making 

economic comparisons between alternative ways of accomplishing a given long-term task or 

function. It is particularly useful when the different proposals being evaluated have different 

cash flow patterns, i.e., the costs and savings associated with each proposal differ in both 

magnitude and time of occurrence. Valid comparisons may be made between economically 

diverse proposals because the DCF technique uses discount factors to account for the "time 

value of money." The concept of the time value of money recognizes that a dollar spent or 

received today can be compared to a dollar spent or received at a point in the future only 

when provision is made to account for the effect of compounded interest. The input 

information needed for an economic comparison by DCF analysis is (1) the magnitude of and 

time of occurrence of the costs and benefits related to each proposal, and (2) the appropriate 

discount or interest rate. 

Approach and Financial Assumptions 

The life-cycle cost model employed for the analysis is similar to the approach that 

Lawrence Berkeley Laboratory (LBL) used in its analysis for DOE. (9) Specific assumptions 

used in the study are as follows: 

• Life of the range unit was assumed to be 19 years, DOE data. (An AHAM 

survey gives 18 years.) 

• All costs are in constant 1990 dollars to make comparison with the DOE 

analysis(4) easier. 

• Where data from other years were used, they were transformed to 1990 dollars 

using the GDP Implicit Price Deflator . 

.. The discount rates are real discount rates, i.e., they are market rates adjusted for 

inflation. Real rates of 2, 6, and 15 percent were used as stipulated by DOE. A 

7 percent rate was also used because it was previously used by DOE . 

.. All cash flows are assumed to occur at year end. 
5-4

No salvage value is assumed.

e All fuel energy values are higher heating values.

Future residential fuel costs are from the DOE Energy Information Administration's -

Annual Energy Outlook, 1994(10) (Reference Case) and, beyond 2010, growth rates from

Average Regional End-Use Energy Price Projections to the Year 20011) The natural gas

fuel cost projections and electricity cost projections used in the economic analyses are shown

in Figure 5-1.

RESIDENTIAL PRICES OF NATURAL GAS AND ELECTRICITY

NATIONAL REFERENCE CASE. DOE 1994 PRO.ECTION

30

0

27.36

20

10

8.59

0

1998 2001 2006 2011 2016

Figure 5-1. Fuel cost projections in the economic analyses based on DOE's Annual Energy

Outlook, 1994, converted to 1990 dollars

EE-RM-90-201 COMMENT OOR13

5-4 

• No salvage value is assumed. 

• All fuel energy values are higher heating values. 

Future residential fuel costs are from the DOE Energy Information Administration's 

Annual Energy Outlook, 1994 (10) (Reference Case) and, beyond 2010, growth rates from 

Average Regional End-Use Energy Price Projections to the Year 2030.01) The natural gas 

fuel cost projections and electricity cost projections used in the economic analyses are shown 

in Figure 5-1. 

O~~------~--------~-------L--------~ 2011 2018 

Figure 5-1. Fuel cost projections in the economic analyses based on DOE's Annual Energy 

Outlook, 1994, converted to 1990 dollars 
5-5

Output of Analysis

The life-cycle approach converts each year's cash flow to a present value by dividing

by the quantity (1 + market rate) raised to the power of the difference year number. This is

similar to calculating a future value by using the compound interest formula. The sum of

these values including the Year 0 investment is the net present value. The following figures

of merit were calculated:

Annualized Net Savings. This is the annual cost or savings,

including the impact of amortizing the initial investment calculated so

as to be the same each year in constant dollar terms. The net

present value of all cash flows, including those in Year 0 (initial

costs), were converted to an annualized equal amount using the

ordinary annuity formula.

• Net Present Value of Savings/Initial Cost Ratio. This is a form of

benefit/cost ratio that is consistent with the DCF analysis considered

in this study. The net present value of future cash flows was divided

by the initial investment.

Internal Rate of Return. This is the return on investment, assuming

that all flows are invested at the internal rate. The discount rate that

makes the net present value of all savings equal to the net present

value of investments was calculated.

Simple Payback. Simple Years to Payback or "Simple Payback"

was included in this analysis because it is commonly used in rough

economic analysis. Note that it does not incorporate the time value

of money and does not reflect expected changes in the value of

energy savings beyond the payback year resulting from forecasted

energy price increases.

• Net Energy Saved. Gas and electricity saved is reported in kBtu per

year. Electric energy was calculated as 3,412 Btu/kWh.

• Annualized Value of Gas Savings. The annual savings in

expenditures for natural gas were converted to levelized annual

amounts using the 6 percent discount factor.

Sensitivities were determined for the following factors:

• Discount rate, 2, 7, and 15 percent (6 percent is the base percent)

EE-RM-90-201 COMMENT OOR13

5-5 

Output of Analysis 

The life-cycle approach converts each year's cash flow to a present value by dividing 

by the quantity (l + market rate) raised to the power of the difference year number. This is 

similar to calculating a future value by using the compound interest formula. The sum of 

these values including the Year 0 investment is the net present value. The following figures 

of merit were calculated: 

• Annualized Net Savings. This is the annual cost or savings, 

including the impact of amortizing the initial investment calculated so 

as to be the same each year in constant dollar terms. The net 

present value of all cash flows, including those in Year 0 (initial 

costs), were converted to an annualized equal amount using the 

ordinary annuity formula. 

• Net Present Value of SavingslIoitial Cost Ratio. This is a form of 

benefit/cost ratio that is consistent with the DCF analysis considered 

in this study. The net present value of future cash flows was divided 

by the initial investment. 

• Internal Rate of Return. This is the return on investment, assuming 

that all flows are invested at the internal rate. The discount rate that 

makes the net present value of all savings equal to the net present 

value of investments was calculated. 

• Simple Payback. Simple Years to Payback or "Simple Payback" 

was included in this analysis because it is commonly used in rough 

economic analysis. Note that it does not incorporate the time value 

of money and does not reflect expected changes in the value of 

energy savings beyond the payback year resulting from forecasted 

energy price increases. 

• Net Energy Saved. Gas and electricity saved is reported in kBtu per 

year. Electric energy was calculated as 3,412 Btu/kWh. 

• Annualized Value of Gas Savings. The annual savings in 

expenditures for natural gas were converted to levelized annual 

amounts using the 6 percent discount factor. 

Sensitivities were determined for the following factors: 

• Discount rate, 2, 7, and 15 percent (6 percent is the base percent) 
5-6

• Annual gas energy use, from 80 to 210 percent of standard value

• First cost, 75 to 150 percent of standard value

Appliance life, plus and minus 2 years

Gas cost, 80 and 120 percent of standard value.

Appendix D discusses how the metered appliance study gas usage results have been

correlated with the DOE procedure's useful consumption values to be used in the calculation.

Although the metered gas usage values are lower than those inferred from the DOE procedure, sensitivity values are included in the tables in Appendix A using the DOE values.

Gas Use Sensitivity Values

• The 80 and 125 percent values were chosen to reflect a spread that

might be expected in individual usage where the metered gas study

values, as derived in Appendix D, were the averages.

• The higher values were chosen to reflect the values used in DOE's

current and proposed regulations, which are shown in the Table 5.1

- the 150 percent value corresponds roughly to the

proposed (NOPR) cooktop standard's useful energy

consumption

- the 165 percent, the proposed (NOPR) oven regulation

- the 215 percent, the current (10 CFR 430) cooktop and

oven regulations.

Table 5.1. Useful Energy Consumption Values Derived from the Metered Gas Study

Compared with Values in DOE Range Regulations

Cooktop Oven

Source kBtu/yr Ratio kBtu/yr Ratio

Metered Gas Study 483.1 __________

76.0 __________

DOE Current Regu1ation6 947.5 2.11 160.7 2.18

DOE Proposed Regulation4 732.5 1.52 124.2 1.63

EE-RM-90-201 COMMENT OOR13

5-6 

• Annual gas energy use, from 80 to 210 percent of standard value 

• First cost, 75 to 150 percent of standard value 

• Appliance life, plus and minus 2 years 

• Gas cost, 80 and 120 percent of standard value. 

Appendix D discusses how the metered appliance study gas usage results have been 

correlated with the DOE procedure's useful consumption values to be used in the calculation. 

Although the metered gas usage values are lower than those inferred from the DOE procedure, sensitivity values are included in the tables in Appendix A using the DOE values. 

Gas Use Sensitivity Values 

I 

• The 80 and 125 percent values were chosen to reflect a spread that 

might be expected in individual usage where the metered gas study 

values, as derived in Appendix D, were the averages. 

• The higher values were chosen to reflect the values used in DOE's 

current and proposed regulations, which are shown in the Table 5.1 

the 150 percent value corresponds roughly to the 

proposed (NOPR) cooktop standard's useful energy 

consumption 

the 165 percent, the proposed (NOPR) oven regulation 

the 215 percent, the current (10 CFR 430) cooktop and 

oven regulations. 

Table 5.1. Useful Energy Consumption Values Derived from the Metered Gas Study 

Compared with Values in DOE Range Regulations 

I 

Cooktop 

I 

Oven 

I Source kBtu/yr I Ratio kBtu/yr I Ratio 

Metered Gas Study(27) 483.1 76.0 

DOE Current Regulation(26) 947.5 2.11 160.7 2.18 

DOE Proposed Regulation(4) 732.5 1.52 124.2 1.63 
5-7

Results

Table 5-2 summarizes the results for all design options that DOE included in the

NOPR and which were considered technically feasible. Reducing the mass of the oven to

save energy was considered infeasible, as discussed in Chapter 3. The reduced burner excess

air design option could not be analyzed because it is not sufficiently defined. This table

provides the following information:

Inputs

- cooking energy for baseline ranges and modified ranges

- total gas use and electricity use for base and modified ranges

- added first cost

• Annual energy savings in kBtu/yr

Annualized Net Savings (or Loss) realized from each case at a

6 percent discount rate.

• Annualized value of gas saved, assuming 6 percent discount rate

• Energy factor for baseline and modified ranges

• Cooking efficiency for baseline and modified ranges

The tables in Appendix A show the individual year-by-year cash flows for each of the

cases and include the input parameters. Also tabulated are the sensitivities of the annualized

cost and benefitlcost ratio to the selected discount rates, the first cost, gas cost, unit life and

gas consumption.

EE-RM-90-201 COMMENT OOR13

5-7 

Results 

Table 5-2 summarizes the results for all design options that DOE included in the 

NOPR and which were considered technically feasible. Reducing the mass of the oven to 

save energy was considered infeasible, as discussed in Chapter 3. The reduced burner excess 

air design option could not be analyzed because it is not sufficiently defined. This table 

provides the following information: 

• Inputs 

cooking energy for baseline ranges and modified ranges 

total gas use and electricity use for base and modified ranges 

added first cost 

• Annual energy savings in kBtu/yr 

• Annualized Net Savings (or Loss) realized from each case at a 

6 percent discount rate. 

• Annualized value of gas saved, assuming 6 percent discount rate 

• Energy factor for baseline and modified ranges 

• Cooking efficiency for baseline and modified ranges 

The tables in Appendix A show the individual year-by-year cash flows for each of the 

cases and include the input parameters. Also tabulated are the sensitivities of the annualized 

cost and benefit/cost ratio to the selected discount rates, the first cost, gas cost, unit life and 

gas consumption. 
Table 5-2. Summary of Results of life-Cycle Cost Analysis

Range Modlt cation

AnriuaIz

NatSavinga

$t'yr

Enrgy

Saved

hltt'yr

Gas Sev.d

Annualized

S/yr

Added

let Cost

$

Gas Use

Base

kBtyr

Elect.

Ba,.

kWt,r

Cooking

En, Bat.

kBtLWr

Gas Us.

Mod.

kBtt.yr

Elect.

Mod.

kWh/yr

Cooking

En. Mod,

kBttWr

Cooking

Efficiency

Baseline

Cooking

Efficiency

Modified

Energy

Factor

Baseline

Energy

Factor

Modified

I Nooven000rWlndow, NoDoorOpenings 043 61) 0,43 0.00 2,792 1,204 2,732 1,224 5.92% 0.21% 2.72% 2.70%

Standard Oven

2 No Oven Door Window, No 000rOpenlnga 025 35 0.25 0.00 1,139 01.5 1,066 1,104 61.5 1,031 7.13% 7.37% 5.64% 5.70%

8.6-Cleaning Oven

3 NoOvenDoorWlndow,4000rOpenlngs 024 34 0.24 0,00 2,792 1,284 2,750 1,250 5.92% 0.08% 2.72% 2.76%

Standard Oven

4 NoOvenOoorWlndow, 4000rOpeninga '-002 3 '-002 0.00 1,130 01.5 1,000 1,142 01.5 1,069 7.13% 7.11% 5.04% 5.63%

Self-Cleaning Oven

5 8tendlngPlIotsRspfacedwlthEiedronlctgnttIon,ExlstlngOr.taf 614 2,050 14.70 18.34 3,142 1,092 1,092 1,092 39.90% 39.90% 13.80% 39.90%

Cooktc,

6 St.ndkrg Pilots Rtac.d wifhElectronlc IgnItion, 1/2 NewOutl*lCoat Ill 2,050 14.76 03.33 3,142 1,092 1,092 1,092 39.90% 39.90% 13.86% 39.90%

Coolctq

7 StandIng PllotsRIacedwfthEiedonclgnitlon,N.wOuillet '-292 2.050 14.70 108.25 3,142 1,092 1,092 1,092 39,90% 39.90% 13.80% 39,90%

Cooktop

8 StandIng PIlots R,taced wIlhEI.dronlc Ignition, ExlstingOuII.t -209 1,450 11.44 33.89 2,792 1,2U 1,204 29,2 1,304 5.92% 5.83% 2.72% 5,83%

Standard Oven

O StandingPilotsRlecedwfthEiectronlcIgnltlon,1/2NewOutietCost -0.12 ,469 11.44 78.69 2,702 1,284 1,204 29.2 1,304 5.02% 5.83% 2.72% 5.83%

Standard Oven

10 8tendIng Pilots Rlaced wilhEledronlc Ignition, New Outlet ' -1015 1 489 11.44 123.88 2,792 1,204 1,204 29.2 1,304 5.92% 5.83% 2.72% 5.83%

Standard Oven

II knprovedDoorseats -018 1 0.09 3.06 2,792 1,284 2,780 1,271 5.92% 5.98% 2.72% 2.73%

Standard Own

12 knprov.d000rSeals -021 11 0.06 3.15 1,139 61.5 1,066 1,129 01.5 1,056 7.13% 7.20% 5.64% 8.08%

Self-Cleaning Oven

13 ForcsdConvedlon.ddedto8tandard-PIus-Electrlclgnltlon -1487 88 0.55 131.12 1,204 29.2 1,304 1,127 31.7 1,238 5.03% 0.15% 5.83% 0.15%

Standard Oven

14 Reduced Ventflate -036 7 0.05 4.58 2792 1,264 2,786 1,277 5.92% 5.95% 2.72% 2.73%

Stendard Oven

15 Reftedlv.Surf.c.a--Chrome-Piated OvonCavity -815 -185 -1.33 53.66 2,792 1,284 2,978 1,469 5.02% 5.17% 2.72% 2.55%

Standard Oven

to Refte.dlveSurtacea--CPrrorne-PiatedOvenCavtty -574 -129 -0.93 53.68 1,139 61.5 1,066 1,268 61.5 1,195 7.13% 6.36% 8.04% 5.15%

Self-Cleaning Oven

17 Added Insulation forth. CdrlnetEnvelope -1 11 0 0.00 19.79 2,792 1,264 2,792 1,284 5.02% 5.92% 2.72% 2.72%

Standard Oven

18 AddedtnsuIaIlonforthaClnslEnvalope -1 77 0 0.00 19.70 1,139 81.5 1,066 1,139 01.5 1,066 7.13% 7.13% 5.64% 5.84%

S.lf-Cleanlng Oven

19 rlnsulatlonoutsld.otCombustlonCharnber -021 35 0.27 5.42 2,792 1,284 2,754 1,240 5,92% 0.10% 2.12% 2.76%

Standard Oven

20 ReducedCorductlonLoa..e--PyrolyitcOvenConstructlon -685 211 1.56 93.82 2,792 1,284 2,576 1,068 5.92% 7.12% 2.72% 2.05%

Standard Oven

00

EE-RM-90-201 COMMENT OOR13

Table 5-2. Summary of Results of Ufe-Cycle Cost Analysis 

red Added Gaa U •• Elect. Cooking GIIU .. Elect. Cooking Cooking 1 Cooking 1 Energy Energy Ringe ModKlcatlon Neil$avll'lil SIi_ Annualized 10t Coat Ba •• B ... En. e ••• Mod. Mod. En. Mod. Emclenc:y Emclenc:y Factor Factor 

Sf'i~:.':· : .ltBtLwI.· Styr S kBtulyr kWlVyr kBtulyr kBtulyr kWlVyr kBtulyr Baaellne ModKIed B ... llne ModKIed 

No O\'In Door WIndow, No Door Oponlnga ~.431) ':'" .. :eo 0.~3 0.00 2,792 1,2e~ 

S tlndOrd O\'In 

2 No O\'In Door WIndow, No Door Openlnga .'.: .. :::::!l.251 •. ::: ::':::< •.•. 351 0.251 0.001 1,1391 61.51 1,0881 1.1041 81.5 SII-Clelnlng O\'In 

3 No O\'In DoorWlndow, ~ DoorOpanlnga I':::';:;:' ·.:.0.241·."""')}" 341 0.2~1 0.001 2,71121 1,2~ 

S tlndlrd O\'In 

~ No O\'In Door WIndow, ~ Door Openlnga •• .,..;':'O:02L "::::'::/":";"1 -0.021 0.001 1,1391 81.51 1,0881 1.1421 81 Sel-Cleanlng O\'In 

5 Stlndlng Pliota Repillced wIIh Elodronlc Ign~lon, Exlltlng OUtlot I •. ':::;:.:.8:141::;:: :'A.~I 1~.7111 18·~1 3,H21 1,0112 

Cooktap 

8 Stondlng Pliota Replaced wRh Elodronic Ignition, 1/2 N_ OUtlot COlt .... :: .•. '::,J,1f r·. :'" ,:,.11.*1 1~.7111 113.331 3,1~21 1,0112 

Cooktcp 

7 Standing Pliota Replaced wIIh Elodronlc Ign~lon, N_ Outlot ···:i:.~:·~r«2,~1 1~.7111 108.251 3,1~21 1,092 1 1,01121 1,01121 30.90%1 30.90%1 13.88%1 30.90% Cooktap 

8 Stondlng Pliota Replaced w~h Elodronic Ignition, Exlltlng OUtlot .}}}~l!:~I:'~ ••• :{<t."~1 11·~1 3UOI 2,71121 1,2~1 1,~1 29.21 1,3041 5.112%1 5.83%1 2.72%1 5.83% Stlndlrd O\'In 

II Stlndlng Pilot. Replaced wIIh Elodronlc IgnRlon, 1/2 N_ OUtlot COlt 

;!i:~:]);[I:I~~il 11'~~1 78.110 1 2,

7112

1 1,2MI 1'2O~1 29.21 1'~1 5·112%1 5.83%1 2.72%1 5.83%1 VI Siandird o..n I 

00 

10 Btlndlng Pilot. Replaced wRh Elodronic Ignnlon, N_ Outlot 11.~~ 123.l1li 2,7112 1,28~ 1,~ 29.2 1,~ 5.112% 5.83'" 2.72% 5.83% Standlrd o..n 

11 Impro_DoorS.a" •. {.~.~ ,,:;-'1,1.81 /,.:: ':;::;::'/"'1 0.091 3.081 2,7112 1 1,2MI 2,7801 1,2711 5.112%1 5.98%1 2.72%1 2.73% S tlndord O\'In 

12 Improved DoorS.I" I : .,:::~ -"O:~t I ••••• }::/J, I 0.08 1 3.151 1,130/ 81.51 1,0881 1,1291 81.51 1.0581 7.13% S.I-Clelnlng O\'In 

13 Forcod ColMIdlon edded to Btandard-PIuo-Eloetrlc IgnRlon .• 'i\-".14.~~ 1:':::, ::::::;: ..... iflSl 0.551 131.121 1,~1 29.21 1,~1 1,1271 31.71 1.2381 5.83% Btondlrd o..n 

1 ~ Reduced V.nt RII. :'::::.' :.,.O·ae.I •• :'''''::::'::>.'11 0.051 4.581 2,71121 1,2MI 2,7l1li1 1.2771 5.112% Stondord o..n 

15 RofIoctlvo SUlfOCH- -Chrome-Plated O\'In Cavity ::.<.:,:::--"6,1,51, :·.{;"J~I -1.33/ 53.l1li 1 2,71121 1,2MI 2,0781 1,4801 5.112% S landlrd O\'In 

18 RofIoctIvoSUlfICH--Chrome-Plated O\'InCavtty ':?:~ '<;:~Ai:ill.:·:..:::"'l 291 -0.031 53·l1li1 1,130 / 81.51 1,0881 1,2881 81.51 1.IOSI 7.13% S .1-Clelnlng O\'In 

17 Added Irwuletlon lor thl Cmmet Envelope 1··.:'::::··:;;'.P~I::::···.:·:::,°1 0.001 10.701 2,702 1 1,2~1 2,7021 1.2MI 5.112% Standard O\'In 

18 Added I""uletion lor IhI Cmmet Envelope '.:':"1:!7I ':.: .DI 0.001 10.701 1,139 1 81.51 1,0881 1,130/ 81.51 1.0881 7.13% S.I-Cleanlng O\'In 

19 :zo Irwuletlon outalda 01 Combuotlon Chlmber >""::SO:21 I: :..:\::361 0.271 5.~21 2,7112 1 1,2MI 2,75~1 1.2481 5.02"- Stlndard o..n 

20 Reduced Conduction LOII"-- Pyrolytc O\'In CorwlllJcllon :::);"1.85 1 \: .• 2FI 1.581 93.112 1 2,71121 1,2MI 2,5761 1.08111 5.112% S landord O\'In 
6. COOKING PERFORMANCE AND

OTHER QUALITATIVE CONSIDERATIONS

In considering the cooking performance of kitchen ranges and ovens, it must be

recognized that the primary function of a range is to prepare food in a manner that provides

acceptable and reproducible results for the consumer. Energy savings and designs that

promote energy conservation are commendable, but this goal must be secondary to the

primary function, particularly for an appliance that uses so little energy. The range/oven is

an appliance of creativity, often more art than science, that must cook a wide spectrum of

foods and provide appealing results with respect to appearance, flavor or taste, texture, odor,

sanitation, "doneness," traditional recipes, ethnic considerations, and many other factors that

are subjective in nature.

There is no one single function for a range as there is, for example, for a water heater.

A water heater simply heats water for the home. There is little, if any, user interaction with

the appliance as long as it provides hot water at the right temperature and quantity. A

furnace/air conditioner is another example; the only consumer interaction is adjustment of the

thermostat and maintenance when required.

The range, in contrast, has many interactions with the user. For example, there are

literally thousands of ways to cook chicken, and each may require subtle adjustments of time,

temperature, and preparation. Methods of preparation that require range interaction include

variations in warming, holding, appearance, broiling, grilling, poaching, and sautéing. Even

variations in sauces, food cutting, or dicing may require individual range adjustments

dependent on the type and form of preparation. All of these functions require a range design

capable of adjustment for many variations and the interaction of the cook. Ranges deliver

energy that the cook must control to create a meal. This means that the range must produce

expected performance when a food is prepared and energy saving criteria must be secondary

to cooking performance. Many of the DOE design options have the potential to adversely

affect the cooking process and produce undesirable results.

EE-RM-90-201 COMMENT OOR13

6. COOKING PERFORMANCE AND 

OTHER OUALITATIVE CONSIDERATIONS 

In considering the cooking performance of kitchen ranges and ovens, it must be 

recognized that the primary function of a range is to prepare food in a manner that provides 

acceptable and reproducible results for the consumer. Energy savings and designs that 

promote energy conservation are commendable, but this goal must be secondary to the 

primary function, particularly for an appliance that uses so little energy. The range/oven is 

an appliance of creativity, often more art than science, that must cook a wide spectr.Jm of 

foods and provide appealing results with respect to appearance, flavor or taste, texture, odor, 

sanitation, "doneness," traditional recipes, ethnic considerations, and many other factors that 

are SUbjective in nature. 

There is no one single function for a range as there is, for example, for a water heater. 

A water heater simply heats water for the home. There is little, if any, user interaction with 

the appliance as long as it provides hot water at the right temperature and quantity. A 

furnace/air conditioner is another example; the only consumer interaction is adjustment of the 

thermostat and maintenance when required. 

The range, in contrast, has many interactions with the user. For example, there are 

literally thousands of ways to cook chicken, and each may require subtle adjustments of time, 

temperature, and preparation. Methods of preparation that require range interaction include 

variations in warming, holding, appearance, broiling, grilling, poaching, and sauteing. Even 

variations in sauces, food cutting, or dicing may require individual range adjustments 

dependent on the type and form of preparation. All of these functions require a range design 

capable of adjustment for many variations and the interaction of the cook. Ranges deliver 

energy that the cook must control to create a meal. This means that the range must produce 

expected performance when a food is prepared and energy saving criteria must be secondary 

to cooking performance. Many of the DOE design options have the potential to adversely 

affect the cooking process and produce undesirable results. 
6-2

This section evaluates each of the design options that DOE analysis indicates will have

energy savings potential from the perspective of the effects of the design option on food

quality and cooking performance, rather than energy savings. Of necessity, this discussion

will be more subjective than scientific because definitive experimental data are difficult to

obtain in this area.

New DOE Design Options

1. Remove Oven Door Window

Today, approximately one half or more of the ranges produced in the United States

have a window in the oven door. (See Appendix C, Exhibits 2 and 4.) This a popular

consumer feature for which the consumer is willing to pay extra when buying a range.

There is no question that a windowed door loses more energy than a door without a window,

providing that the door is not opened to inspect the food while cooking (see discussion in

Chapter 2). If the door is opened several times, however, the energy savings decrease and

may eventually produce an overall increase in energy consumption if the cook opens the door

more than three or four times.

A view of the cooking process is important to many cooks. The window does provide

a valuable feature since the cook can glance in through the window and feel confident that

the food is cooking properly, not boiling over, and most important, not burning or becoming

overdone.

A consulting home economist (Appendix C, Exhibit 2) testified in the DOE oral

hearings that:

My observations from cooking tests, where the oven door is opened

repeatedly, show that foods situated at the front of the oven do not

brown as well or cook evenly as those located in the center or back

of the oven. Some testing has been done and the results show that

cooking peiformance is not acceptable. Rearrangement of the food

in the oven may be necessary in order to cook or bake it properly

and evenly. My past experience tells me that many foods, in

EE-RM-90-201 COMMENT OOR13

6-2 

"This section evaluates each of the design options that DOE analysis indicates will have 

energy savings potential from the perspective of the effects of the design option on food 

quality and cooking performance, rather than energy savings. Of necessity, this discussion 

will be more subjective than scientific because definitive experimental data are difficult to 

obtain in this area. 

New DOE Design Options 

1. Remove Oven Door Window 

Today, approximately one half or more of the ranges produced in the United States 

have a window in the oven door. (See Appendix C, Exhibits 2 and 4.) This a popular 

consumer feature for which the consumer is willing to pay extra when buying a range. 

There is no question that a windowed door loses more energy than a door without a window, 

providing that the door is not opened to inspect the food while cooking (see discussion in 

Chapter 2). If the door is opened several times, however, the energy savings decrease and 

may eventually produce an overall increase in energy consumption if the cook opens the door 

more than three or four times. 

A view of the cooking process is important to many cooks. The window does provide 

a valuable feature since the cook can glance in through the window and feel confident' that 

the food is cooking properly, not boiling over, and most important, not burning or becoming 

overdone. 

A consulting home economist (Appendix C, Exhibit 2) testified in the DOE oral 

hearings that: 

My observations from cooking tests, where the oven door is opened 

repeatedly, show that foods situated at the front of the oven do not 

brown as well or cook evenly as those located in the center or back 

of the oven. Some testing has been done and the results show that 

cooking performance is not acceptable. Rearrangement of the food 

in the oven may be necessary in order to cook or bake it properly 

and evenly. My past experience tells me that many foods, in 
6-3

particular, popular baked foods such as cookies and muffins would

be adversely affected.

The ORTECH report'4 cited by DOE in the Technical Support Document4 states:

"it is highly questionable, however, whether elimination of the oven window would be

acceptable in the marketplace or would even result in any real energy savings." The analysis

outlined in Chapter 2 supports this conclusion.

From a food quality perspective, the window allows inspection of the cooking process

without door openings that may cause failure of delicate food items such as souffles. No

doubt a professional cook can prepare these items without a door window (commercial

cooking ranges usually do not have windows), but the window is certainly a desirable feature

for less accomplished home cooks who want to prepare such foods and reduce the risk of

failure. The failure of just one recipe may well have more cost associated with it than the

potential yearly energy savings from eliminating the door window (see Chapter 2 discussion).

There is also the question of decreased safety. The presence of a window allows

inspection without opening the door, thus reducing the probability of contacting hot surfaces

or being scalded from steam that is present in some cooking operations. This is of special

concern for homes with children or physically limited individuals.

2. Electric Ignition

The piloted range has some inherent advantages, and is often used in rural areas with

frequent power outages. It also is often used in low-income areas because of its lower first

cost.

From a cooking performance standpoint there is no effect on the cooking quality from

the use of electric ignition; however, the rangetop area directly above a pilot is sometimes

used for warming purposes - melting butter, bread raising, etc. - at low heat levels that

cannot be achieved using the conventional burners. A piloted oven is also often used for

bread raising purposes or for drying of iron cooking pots after washing.

EE-RM-90-201 COMMENT OOR13

6-3 

. particular, popular baked foods such as cookies and mUffins would 

be adversely affected. 

The ORTECH report(l4) cited by DOE in the Technical Support Document(4) states: 

"it is highly questionable, however, whether elimination of the oven window would be 

acceptable in the marketplace or would even result in any real energy savings." The analysis 

outlined in Chapter 2 supports this conclusion. 

From a food quality perspective, the window allows inspection of the cooking process 

without door openings that may cause failure of delicate food items such as souffles. No 

doubt a professional cook can prepare these items without a door window (commercial 

cooking ranges usually do not have windows), but the window is certainly a desirable feature 

for less accomplished home cooks who want to prepare such foods and reduce the risk of 

failure. The failure of just one recipe may well have more cost associated with it than the 

potential yearly energy savings from eliminating the door window (see Chapter 2 discussion). 

There is also the question of decreased safety. The presence of a window allows 

inspection without opening the door, thus reducing the probability of contacting hot surfaces 

or being scalded from steam that is present in some cooking operations. This is of special 

concern for homes with children or physically limited individuals. 

2. Electric Ignition 

The piloted range has some inherent advantages, and is often used in rural areas with 

frequent power outages. It also is often used in low-income areas because of its lower first 

cost. 

From a cooking performance standpoint there is no effect on the cooking quality from 

the use of electric ignition; however, the rangetop area directly above a pilot is sometimes 

used for warming purposes - melting butter, bread raising, etc. - at low heat levels that 

cannot be achieved using the conventional burners. A piloted oven is also often used for 

bread raising purposes or for drying of iron cooking pots after washing. 
6-4

3. Improved Door SealsfReduced Vent Rate

These two design options are combined in this discussion since they are related. A

change in one will affect the other and each is important for good cooking performance.

A complete door seal is not practical on a gas oven because the introduction of some

air into the oven cavity is necessary for proper combustion, cooking performance, and

internal convection.

The function of the vent is to exhaust the products of combustion and the moisture

produced by foods during the cooking process. If the vent is restricted, moisture and heat

can collect near the top of the oven and cause unacceptable results such as the overcooking

of foods situated in that area of the oven.

Over many years, range manufacturers have optimized the size and vent rates in an

oven to cover a wide variety of foods with varying moisture content. As was discussed in

Chapter 2, at the point where energy savings become significant, serious problems with food

quality have already occurred and problems with combustion, carbon monoxide production,

safety, and range surface temperatures begin to arise.

The energy savings cited by DOE are not applicable to gas ovens. To quote the

DOE's cited documentation:'4

This improvement [Improved Door Seals] applies primarily to

standard electric ovens with little impact on gas-fired standard or

self-cleaning ovens. . . For gas ovens, the amount of air coming in

through the door seals is small compared to the combustion products

flowing through the oven. Therefore, improvement of door seals has

a negligible effect on gas oven efficiency.

4, Forced Convection (Standard Ovens)

Forced convection gas ovens are a very small fraction of the residential market and are

currently available on only high-end, commercial-look ranges. Several range manufacturers

are currently considering introducing a residential gas range with a convection feature.

There is little doubt that a well engineered gas oven capable of convection baking or cooking

EE-RM-90-201 COMMENT OOR13

6-4 

3. Improved Door SealslReduced Vent Rate 

These two design options are combined in this discussion since they are related. A 

change in one will affect the other and each is important for good cooking performance. 

A complete door seal is not practical on a gas oven because the introduction of some 

air into the oven cavity is necessary for proper combustion, cooking performance, and 

internal convection. 

The function of the vent is to exhaust the products of combustion and the moisture 

produced by foods during the cooking process. If the vent is restricted, moisture and heat 

can collect near the top of the oven and cause unacceptable results such as the overcooking 

of foods situated in that area of the oven. 

Over many years, range manufacturers have optimized the size and vent rates in an 

oven to cover a wide variety of foods with varying moisture content. As was discussed in 

Chapter 2, at the point where energy savings become significant, serious problems with food 

quality have already occurred and problems with combustion, carbon monoxide production, 

safety, and range surface temperatures begin to arise. 

The energy savings cited by DOE are not applicable to gas ovens. To quote the 

DOE's cited documentation:(14) 

This improvement [Improved Door Seals] applies primarily to 

standard electric ovens with little impact on gas-fired standard or 

self-cleaning ovens . .. For gas ovens, the amount of air coming in 

through the door seals is small compared to the combustion products 

flowing through the oven. Therefore, improvement of door seals has 

a negligible effect on gas oven efficiency. 

4. Forced Convection (Standard Ovens) 

Forced convection gas ovens are a very smaIl fraction of the residential market and are 

currently available on only high-end, commercial-look ranges. Several range manufacturers 

are currently considering introducing a residential gas range with a convection feature. 

There is little doubt that a well engineered gas oven capable of convection baking or cooking 
6-5

would provide useful functions to enhance and extend the cooking process. It must be

emphasized that convection cooking is considerably different from conventional oven cooking

and the results usually are different.

There are obvious problems with consumer acceptance because a lifetime of cooking

habits, passed down from generation to generation, would have to be changed if this design

option were mandated for standard ovens. Full-time forced convection should not be

mandated since considerable recipe conversions would have to be made, and sometimes,

identical results cannot be obtained.

To quote a home economist (Appendix C, Exhibit 2):

Favorite family recipes will be affected by time/temperature changes

required for convection cooking. For example, in baked goods, the

temperature adjustment is critical to the texture. If the outside crust

solid jfies before the interior has a chance to rise, a heavy and dense

product will result and Grandma's Old Fashioned Sponge Cake may

never be the same again.

Arthur D. Little (ADL) (see Appendix C, Exhibit 5) has conducted a literature review

on the effects of convection ovens on cooking quality. From peer-reviewed journals and

individual research papers, the findings were as follows:

• Cookies baked in a convection oven were significantly different

from those baked in standard or infrared ovens (actually judged

better but "different").

• More energy was used in the convection baking process.

• Heating [in a conventional oven] of ready-prepared or commissary

type food yielded food of higher sensory quality with lower energy

input than food prepared in a convection oven.

• In a convection oven, the rate of moisture loss increases with

temperature increase due to the increased driving forces for heat and

mass transfer. However, for products with low moisture content, the

convection oven is not advantageous because the diffusion process is

slow.

• Food prepared by convection was identifiable [i.e. "different"].

EE-RM-90-201 COMMENT OOR13

6-5 

would provide useful functions to enhance and extend the cooking process. It must be 

emphasized that convection cooking is considerably different from conventional oven cooking 

and the results usually are different. 

There are obvious problems with consumer acceptance because a lifetime of cooking 

habits, passed down from generation to generation, would have to be changed if this design 

option were mandated for standard ovens. Full-time forced convection should not be 

mandated since considerable recipe conversions would have to be made, and sometimes, 

identical results cannot be obtained. 

To quote a home economist (Appendix C, Exhibit 2): 

Favorite family recipes will be affected by time/temperature changes 

requiredfor convection cooking. For example, in baked goods, the 

temperature adjustment is critical to the texture. If the outside crust 

solidifies before the interior has a chance to rise, a heavy and dense 

product will result and Grandma's Old Fashioned Sponge Cake may 

never be the same again. 

Arthur D. Little (ADL) (see Appendix C, Exhibit 5) has conducted a literature review 

on the effects of convection ovens on cooking qUality. From peer-reviewed journals and 

individual research papers, the findings were as follows: 

• Cookies baked in a convection oven were significantly different 

from those baked in standard or infrared ovens (actually judged 

better but "different"). 

• More energy was used in the convection baking process. 

• Heating [in a conventional oven] of ready-prepared or commissary 

type food yielded food of higher sensory quality with lower energy 

input than food prepared in a convection oven. . 

• In a convection oven, the rate of moisture loss increases with 

temperature increase due to the increased driving forces for heat and 

mass transfer. However, for products with low moisture content, the 

convection oven is not advantageous because the diffusion process is 

slow. 

• Food prepared by convection was identifiable [i.e. "different"]. 
6-6

• Cookies and chicken varied more than cakes and beef when

comparing convection and radiant [standard oven] modes.

5. Reduce Burner Excess Air (Cooktops)

It is difficult to determine if this design option would have any effect on cooking

quality, since the design option itself is so inadequately defined that it could not be evaluated

(see discussion in Chapter 2). "Shrouding" is quoted as one way of implementing this option

but no details of the type or extent of shrouding are given. It might be assumed that some

sort of metal partition to direct the heat up along the sides of the cooking vessel is implied.

If this is the case, such an arrangement would only be suitable for specific pan or pot sizes,

and it may not be possible to use a variety of sizes suitable for the food being cooked. This

would greatly decrease the utility of the cooktop and might require specially made pots and

pans designed to fit the burner rather than the many types of cookware currently used to

prepare different foods. For example, a poaching pan that is long and narrow might not be

able to be positioned for proper use.

The issue of safety for the cook and household members also must be considered. The

potential for increased carbon monoxide production exists for burners with reduced excess air

as well as other combustion problems such as flame stability, especially at low flame

settings. Without further details or a specific design, it is impossible to evaluate this option.

No DOE test procedure data are available for an evaluation.

6. Reduced Vent Rate

The cooking performance implications of this option were covered under Item 3,

above. Experimental data from Reference 8 show that reducing the vent size in a gas oven

will not result in significant energy savings.

EE-RM-90-201 COMMENT OOR13

6-6 

• Cookies and chicken varied more than cakes and beef when 

comparing convection and radiant [standard oven] modes. 

Sf Reduce Burner Excess Air (Cooktops) 

It is difficult to determine if this design option would have any effect on cooking 

quality, since the design option itself is so inadequately defined that it could not be evaluated 

(see discussion in Chapter 2). "Shrouding" is quoted as one way of implementing this option 

but no details of the type or extent of shrouding are given. It might be assumed that some 

sort of metal partition to direct the heat up along the sides of the cooking vessel is implied. 

If this is the case, such an arrangement would only be suitable for specific pan or pot sizes, 

and it may not be possible to use a variety of sizes suitable for the food being cooked. This 

would greatly decrease the utility of the cooktop and might require specially made pots and 

pans designed to fit the burner rather than the many types of cookware currently used to 

prepare different foods. For example, a poaching pan that is long and narrow might not be 

able to be positioned for proper use. 

The issue of safety for the cook and household members also must be considered. The 

potential for increased carbon monoxide production exists for burners with reduced excess air 

as well as other combustion problems such as flame stability, especially at low flame 

settings. Without further details or a specific design, it is impossible to evaluate this option. 

No DOE test procedure data are available for an evaluation. 

6. Reduced Vent Rate 

The cooking performance implications of this option were covered under Item 3, 

above. Experimental data from Reference 8 show that reducing the vent size in a gas oven 

will not result in significant energy savings. 
6-7

7. Reflective Surfaces (Ovens)

The most likely effect on food quality from reflective surfaces would be uneven

distribution of heat, resulting in hot spots in the oven. Due to the possibility of unpredictable

cooking results, the consumer would have to monitor the position of the food and the overall

cooking performance of the oven constantly. Overbrowning of surfaces with subsequent

underdone interiors for meat products is certainly a possibility. This raises the question of

food safety because the food's interior many not reach proper sterilization temperatures.

The TSD4 states:

The reflective materials degrade after the first baking function and

continue to degrade through the itfe of the product. This is especially

true of self-cleaning ovens as the self-cleaning process damages the

reflective walls and negates any possible energy savings.

The experimental study8 shows that this design option actually loses energy and is

therefore not viable as a mandated design option. Currently, about 29 percent of gas ranges

and 58 percent of electhc ovens are self-cleaning (AHAM). There is no known cost-effective

material that will maintain reflective features after self-cleaning cycles.

8. Added Insulation (Ovens)

Adding insulation to an oven will not directly affect food quality except that it may

dictate reduced oven capacity, since most of the ranges produced today are made to fit in a

30-inch space and the only way to add insulation would be to decrease the size of the oven

cavity.

One of the features consumers want most is a large oven cavity. Thus, any reduction

would have to be considered a significant loss of feature for the consumer. For instance,

even if a household is considered small, with one or two people, it is generally thought

desirable to have a large oven for the one or two times a year that a special or family meal is

produced, such as at Thanksgiving or Christmas.

EE-RM-90-201 COMMENT OOR13

6-7 

7. Reflective Surfaces (Ovens) 

The most likely effect on food quality from reflective surfaces would be uneven 

distribution of heat, resulting in hot spots in the oven. Due to the possibility of unpredictable -

cooking results, the consumer would have to monitor the position of the food and the overall 

cooking performance of the oven constantly. Overbrowning of surfaces with subsequent 

underdone interiors for meat products is certainly a possibility. This raises the question of 

food safety because the food's interior many not reach proper sterilization temperatures. 

The TSD(4) states: 

The reflective materials degrade after the first baking .funCTion and 

continue to degrade through the life of the product. This is especiaUy 

true of self-cleaning ovens as the self-cleaning process damages the 

reflective waIls and negates any possible energy savings. 

The experimental study(8) shows that this design option actually loses energy and is 

therefore not viable as a mandated design option. Currently, about 29 percent of gas ranges 

and 58 percent of electric ovens are self-cleaning (AHAM). There is no known cost-effective 

material that will maintain reflective features after self-cleaning cycles. 

8. Added Insulation (Ovens) 

Adding insulation to an oven will not directly affect food quality except that it may 

dictate reduced oven capacity, since most of the ranges produced today are made to fit in a 

30-inch space and the only way to add insulation would be to decrease the size of the oven 

cavity. 

One of the features consumers want most is a large oven cavity. Thus, any reduction 

would have to be considered a significant loss of feature for the consumer. For instance, 

even if a household is considered small, with one or two people, it is generally thought 

desirable to have a large oven for the one or two times a year that a special or family meal is 

produced, such as at Thanksgiving or Christmas. 
6-8

The microwave oven and countertop toaster have taken over much of the small oven

food preparation, but the consumer wants a larger oven for the times, for example, when a

large turkey or multi-item menu must be prepared.

9. Reduced Thermal Mass

The same arguments for added insulation are applicable for reduced thermal mass.

Under current manufacturing processes, reduction of sheet metal to thinner gauges is

impractical. Crazing of the porcelain and denting of the oven walls would occur. The only

way to effectively reduce thermal mass in modern ovens is to make them smaller, which

leads to the problems of oven capacity that have been previously discussed. There would be

no appreciable effect on food quality except that large portions could not be cooked or

multiple items could not be cooked together as is commonly done now.

10. ImDroved Insulation (Ovens)

There would be no effect on food quality from improved insulation. If the improved

insulation were thicker and required the reduction of oven cavity volume, the same

arguments as stated above (Items 8 and 9) would apply.

11. Other Options Rejected by DOE

DOE rejected the design options of oven separator, reduced conduction losses, forced

convection for self-cleaning ovens, sealed burners, reflective surfaces for cooktops, and

added insulation for cooktops. Of these, the oven separator and forced convection would

have the most impact on food quality. As wasmentioned, cooking uniformity, temperature

distribution, and venting are issues with an oven separator in a gas oven. Forced convection

produces cooking results that are different from standard cooking that may not be acceptable

in all cases.

EE-RM-90-201 COMMENT OOR13

6-8 

The microwave oven and countertop toaster have taken over much of the small oven 

food preparation, but the consumer wants a larger oven for the times, for example, when a 

large turkey or multi-item menu must be prepared. 

9. Reduced Thermal Mass 

The same arguments for added insulation are applicable for reduced thermal mass. 

Under current manufacturing processes, reduction of sheet metal to thinner gauges is 

impractical. Crazing of the porcelain and denting of the oven walls would occur. The only 

way to effectively reduce thermal mass in modern ovens is to make them smaller, which 

leads to the problems of oven capacity that have been previously discussed. There would be 

no appreciable effect on food quality except that large portions could not be cooked or 

multiple items could not be cooked together as is commonly done now. 

1Q. Improved Insulation (Ovens) 

There would be no effect on food quality from improved insulation. If the improved 

insulation were thicker and required the reduction of oven cavity volume, the same 

arguments as stated above (Items 8 and 9) would apply. 

11. Other Options Rejected by DOE 

DOE rejected the design options of oven separator, reduced conduction losses, forced 

convection for self-cleaning ovens, sealed burners, reflective surfaces for cooktops, and 

added insulation for cooktops. Of these, the oven separator and forced convection would 

have the most impact.on food qUality. As was.mentioned, cooking uniformity, temperature 

distribution, and venting are issues with an oven separator in a gas oven. Forced convection 

produces cooking results that are different from standard cooking that may not be acceptable 

in all cases. 
6-9

Reflective surfaces for cooktops do not have any appreciable effect on food quality,

and most manufacturers currently supply chromed reflectors. Sealed burner cooking

characteristics are so similar to those of standard burners that it is not likely that there will

be any observable difference in food quality. Reduced conduction losses would also not -

affect cooking quality.

EE-RM-90-201 COMMENT OOR13

6-9 

Reflective surfaces for cooktops do not have any appreciable effect on food quality, 

and most manufacturers currently supply chromed reflectors. Sealed burner cooking 

characteristics are so similar to those of standard burners that it is not likely that there will 

be any observable difference in food quality. Reduced conduction losses would also not 

affect cooking qUality. 
6-10

EE-RM-90-201 COMMENT OOR13

6-10 

- , 
7. IMPLICATIONS OF THE NATIONAL APPLIANCE

ENERGY CONSERVATION ACT (NAECA)

NAECA' is the culmination of a series of events, including energy legislation,

efficiency standards rulemaldng, and litigation that began with the Energy Policy and

Conservation Act of 1975 (EPCA),( which was a response to the energy crisis that occurred

in the early 1970s. EPCA was a broad piece of legislation that covered issues as diverse as

the strategic petroleum reserve and automotive efficiency, and of which appliance efficiency

was a relatively small part. EPCA instituted the development of efficiency test procedures

and established the appliance labeling program, which are important parts of the legislation

that play key roles in current efficiency standards activities. Nevertheless, under EPCA,

appliance efficiency standards were not mandated.

The National Energy Conservation and Policy Act of 1978 (NECPA)' succeeded

EPCA. Like EPCA, NECPA was sweeping energy legislation, but unlike EPCA, NECPA

mandated DOE to carry out rulemakings to establish minimum efficiency standards for many

appliances (commonly referred to as NAECA). At the end of the rulemaking, DOE

concluded that efficiency standards for appliances were not justified, thereby establishing

what is commonly referred to as the "no-standard" standard for appliance efficiency.

Furthermore, DOE's final rule prevented individual states from establishing appliance

efficiency standards.

As a result of DOE's actions in the NECPA rulemaking, DOE was sued by a coalition

led by the Natural Resources Defence Council (NRDC) (NRDC vs. Herrington, 1985) for

violating the intent of Congress with the no-standard standard and the preemption of state

standards. The court ruled against DOE and overturned the no-standard standard and the

preemption provision. Following this ruling, several states began establishing minimum

efficiency standards for appliances. Faced with the prospect of a patchwork of local

efficiency standards, manufacturers cooperated with NRDC to support NAECA.

The key provisions of NAECA are the establishment of initial minimum efficiency

standards for covered products, a schedule for the review and amendment of these standards,

EE-RM-90-201 COMMENT OOR13

7. IMPLICATIONS OF THE NATIONAL APPLIANCE 

ENERGY CONSERVATION ACT (NAECA) 

NAECA (1) is the culmination of a series of events, including energy legislation, 

efficiency standards rulemaking, and litigation that began with the Energy Policy and 

Conservation Act of 1975 (EPCA),<2) which was a response to the energy crisis that occurred 

in the early 1970s. EPCA was a broad piece of legislation that covered issues as diverse as 

the strategic petroleum reserve and automotive efficiency, and of which appliance efficiency 

was a relatively small part. EPCA instituted the development of efficiency test procedures 

and established the appliance labeling program, which are important parts of the legislation 

that play key roles in current efficiency standards activities. Nevertheless, under EPCA, 

appliance efficiency standards were not mandated. 

The National Energy Conservation and Policy Act of 1978 (NECPA)(I) succeeded 

EPCA. Like EPCA, NECPA was sweeping energy legislation, but unlike EPCA, NECPA 

mandated DOE to carry out rulemakings to establish minimum efficiency standards for many 

appliances (commonly referred to as NAECA). At the end of the rulemaking, DOE 

concluded that efficiency standards for appliances were not justified, thereby establishing 

what is commonly referred to as the "no-standard" standard for appliance efficiency. 

Furthermore, DOE's final rule prevented individual states from establishing appliance 

efficiency standards. 

As a result of DOE's actions in the NECPA rulemaking, DOE was sued by a coalition 

led by the Natural Resources Defence Council (NRDC) (NRDC vs. Herrington, 1985) for 

violating the intent of Congress with the no-standard standard and the preemption of state 

standards. The court ruled against DOE and overturned the no-standard standard and the 

preemption provision. Following this ruling, several states began establishing minimum 

efficiency standards for appliances. Faced with the prospect of a patchwork of local 

efficiency standards, manufacturers cooperated with NRDC to support NAECA. 

The key provisions of NAECA are the establishment of initial minimum efficiency 

standards for covered products, a schedule for the review and amendment of these standards, 
7-2

a basic rulemaking procedure to follow in the review and amendment process, and

preemption of state efficiency standards. The initial efficiency standards were established

through negotiations between manufacturers and public interest groups, such as NRDC. The

procedure for review and amendment of these standards was designed to account for the

economic impacts of proposed standards on both industry and consumers. NAECA was

intended to recognize the burdens that successive rulemaldngs place on manufacturers, so the

rulemaking schedules were designed to provide time for manufacturers to meet higher

minimum standards. And finally, the preemption of state standards made it possible for

manufacturers to avoid the need to supply products that meet the requirements of multiple

local standards.

In addition to these provisions, NAECA was designed to adapt to changes in

technology and to ensure that the imposition of more stringent minimum efficiency standards

would not reduce the usefulness of appliances to consumers. The issue of changes in

technology is addressed in NAECA by the provision for the review and amendment of the

DOE test procedures4 that are used to determine the performance of covered appliances.

By changing the relevant test procedures, DOE can ensure that the minimum efficiency

standards appropriately represent the performance of contemporary appliances with representative user behavior. The issue of preserving the usefulness of regulated appliances is

addressed by the establishment of appropriate appliance classes and the recognition of the

value of features and performance characteristics, or utility, to consumers. The eightproduct NOPR, which covers ranges and ovens, raises important issues related to both test

procedures and to the interpretation of the important issue of appliance utility. The following

sections address the implications of these issues in more detail as they relate to the proposed

efficiency standards for ranges and ovens.

Test Procedure Implications

Test procedures are the foundation of efficiency standards under NAECA. The test

procedure for each appliance is used to determine the efficiency of the appliance and

specifies how the annual energy consumption of the appliance is calculated. The appliance

EE-RM-90-201 COMMENT OOR13

7-2 

a basic rulemaking procedure to follow in the review and amendment process, and 

preemption of state efficiency standards. The initial efficiency standards were established 

through negotiations between manufacturers and public interest groups, such as NRDC. The 

procedure for review and amendment of these standards was designed to account for the 

economic impacts of proposed standards on both industry and consumers. NAECA was 

intended to recognize the burdens that successive rulemakings place on manufacturers, so the 

rulemaking schedules were designed to provide time for manufacturers to meet higher 

minimum standards. And finally, the preemption of state standards made it possible for 

manufacturers to avoid the need to supply products that meet the requirements of multiple 

local standards. 

In addition to these provisions, NAECA was designed to adapt to changes in 

technology and to ensure that the imposition of more stringent minimum efficiency standards 

would not reduce the usefulness of appliances to consumers. The issue of changes in 

technology is addressed in NAECA by the provision for the review and amendment of the 

DOE test procedures(4) that are used to determine the performance of covered appliances. 

By changing the relevant test procedures, DOE can ensure that the minimum efficiency 

standards appropriately represent the performance of contemporary appliances with representative user behavior. The issue of preserving the usefulness of regulated appliances is 

addressed by the establishment of appropriate appliance classes and the recognition of the 

value of features and performance characteristics, or utility, to consumers. The eightproduct NOPR, which covers ranges and ovens, raises important issues related to both test 

procedures and to the interpretation of the important issue of appliance utility. The following 

sections address the implications of these issues in more detail as they relate to the proposed 

efficiency standards for ranges and ovens. 

Test Procedure Implications 

Test procedures are the foundation of efficiency standards under NAECA. The test 

procedure for each appliance is used to determine the efficiency of the appliance and 

specifies how the annual energy consumption of the appliance is calculated. The appliance 
7-3

efficiency is based on the operating characteristics of the appliance and the annual energy

consumption is based on assumptions of how the appliance is used in "average" applications.

The usage behavior assumptions play a critical role in the determination of the economic

justifiability of increased efficiency levels because the level of usage is used to calculate the

energy savings that would result from the implementation of more stringent efficiency

standards. The amount of energy savings due to higher standards is used to estimate the

operating cost savings to consumers, which, along with first costs and maintenance costs, is

used to estimate the life-cycle cost to consumers for appliances at various candidate

efficiency levels. In general, the higher the energy consumption of the baseline appliance,

the greater the potential savings available from increased efficiency standards. Thus, the

appliance usage assumptions have an important impact on the economic justification of higher

efficiency standards.

It is important that DOE take the necessary steps throughout the rulemaking process to

ensure that the public has an adequate opportunity to review the assumptions, analysis, and

conclusions that support DOE's decisions at each stage of the process. Since test procedures

are such a critical part of the evaluation of candidate standard levels, it is imperative that

DOE's intentions relating to changes in test procedures be absolutely clear during the

efficiency standard rulemaking process. Furthermore, since the conclusions regarding future

efficiency standards are based on the test procedure, it is important that the test procedure

used in the analysis produce results similar to the results that would be obtained from the test

procedure in effect when the standards take effect. If this relationship is not assured, the

conclusions of DOE's rulemaking analysis may be subject to question.

Appliance Utility Issues

NAECA rulemaking analysis has historically focused on quantifiable technical and

economic issues, such as efficiency and life-cycle cost. This approach is often reasonable

because the law is relatively clear about the technical and economic criteria required for

establishing more stringent efficiency standards. From a rulemaking perspective, the

quantifiable issues of technological feasibility and economic justifiability are relatively

EE-RM-90-201 COMMENT OOR13

7-3 

efficiency is based on the operating characteristics of the appliance and the annual energy 

consumption is based on assumptions of how the appliance is used in "average" applications. 

The usage behavior assumptions play a critical role in the determination of the economic 

justiflability of increased efflciency levels because the level of usage is used to calculate the 

energy savings that would result from the implementation of more stringent efflciency 

standards. The amount of energy savings due to higher standards is used to estimate the 

operating cost savings to consumers, which, along with flrst costs and maintenance costs, is 

used to estimate the life-cycle cost to consumers for appliances at various candidate 

efficiency levels. In general, the higher the energy consumption of the baseline appliance, 

the greater the potential savings available from increased efflciency standards. Thus, the 

appliance usage assumptions have an important impact on the economic justiflcation of higher 

efficiency standards. 

It is important that DOE take the necessary steps throughout the rulemaking process to 

ensure that the public has an adequate opportunity to review the assumptions, analysis, and 

conclusions that support DOE's decisions at each stage of the process. Since test procedures 

are such a critical part of the evaluation of candidate standard levels, it is imperative that 

DOE's intentions relating to changes in test procedures be absolutely clear during the 

efflciency standard rulemaking process. Furthermore, since the conclusions regarding future 

efflciency standards are based on the test procedure, it is important that the test procedure 

used in the analysis produce results similar to the results that would be obtained from the test 

procedure in effect when the standards take effect. If this relationship is not assured, the 

conclusions of DOE's rulemaking analysis may be subject to question. 

Appliance Utility Issues 

NAECA rulemaking.analysis has historically focused on quantiflable technical and 

economic issues, such as efficiency and life-cycle cost. This approach is often reasonable 

because the law is relatively clear about the technical and economic criteria required for 

establishing more stringent efflciency standards. From a rulemaking perspective, the 

quantiflable issues of technological feasibility and economic justifiability are relatively 
7-4

objective, so the results of the analysis can be more readily defended against public criticism.

The Technical Support Documents (TSDs) that accompany the NOPR and Final Rule stages

of each rulemaking provide a detailed, objective record of the assumptions and analytical

approach used to identify appropriate standards levels. By focusing on the types of technical

issues that are readily addressed by objective technical analysis, DOE has sought to avoid

issues that may be subject to broader subjective criticism.

However, in addition to addressing these key objective technical and economic issues,

NAECA also was intended to ensure that efficiency standards only increase the efficiency of

covered products without reducing the usefulness of those products to consumers. NAECA

includes clear provisions for maintaining the utility of covered appliances to consumers. The

first of these provisions is included as one of the seven criteria for economic justifiability,

which states that the benefits of an efficiency standard exceed the burdens considering several

criteria, including". . . any lessening of utility or the performance of the covered products

likely to result from the imposition of the standard. "(1) [Sec. 325(1)(2)(B)(i)(IV)]

In addition, criteria for establishing appliance classes are provided to preserve

appliances that have performance features not available in other appliance classes that

warrant higher or lower efficiency standards' [Sec. 325(n)]. This provision is used to

create separate appliance classes, such as self-cleaning and non-self-cleaning ovens, which

have different features and utility for consumers and different performance characteristics.

The issue of appliance utility is often one of the more contentious issues in a

rulemaking since it can be difficult to quantify the value or benefits of a feature. Although

the law specifically states that the availability of performance characteristics and features

must be maintained, it also states that the burden of proof is the responsibility of interested

parties, and that the Secretary makes the final decision regarding the value of particular

utility to the consumer. It is evident that commenters to DOE rulemakings often have not

provided the preponderance of.evidence necessary to .maintaincertain features. This may

reflect a certain degree of ambiguity in the provisions of NAECA.

The discussion of utility in the House of Representatives Report on NAECA (House of

Representatives Report No. 100-11) provides additional insights that clarify the intent of

congress with respect to appliance utility. The House Report states that DOE must not

EE-RM-90-201 COMMENT OOR13

7-4 

objective, so the results of the analysis can be more readily defended against public criticism. 

The Technical Support Documents (TSDs) that accompany the NOPR and Final Rule stages 

of each rulemaking provide a detailed, objective record of the assumptions and analytical 

approach used to identify appropriate standards levels. By focusing on the types of technical .--

issues that are readily addressed by objective technical analysis, DOE has sought to avoid 

issues that may be subject to broader subjective criticism. 

However, in addition to addressing these key objective technical and economic issues, 

NAECA also was intended to ensure that efficiency standards only increase the efficiency of 

covered products without reducing the usefulness of those products to consumers. NAECA 

includes clear provisions for maintaining the utility of covered appliances to consumers. The 

first of these provisions is included as one of the seven criteria for economic justifiability, 

which states that the benefits of an efficiency standard exceed the burdens considering several 

criteria, including ". . . any lessening of utility or the performance of the covered products 

likely to result from the imposition of the standard. ,,(1) [Sec. 325(l)(2)(B)(i)(IV)] 

In addition, criteria for establishing appliance classes are provided to preserve 

appliances that have performance features not available in other appliance classes that 

warrant higher or lower efficiency standards(l) [Sec. 325(n)]. This provision is used to 

create separate appliance classes, such as self-cleaning and non-self-cleaning ovens, which 

have different features and utility for consumers and different performance characteristics. 

The issue of appliance utility is often one of the more contentious issues in a 

rulemaking since it can be difficult to quantify the value or benefits of a feature. Although 

the law specifically states that the availability of performance characteristics and features 

must be maintained, it also states that the burden of proof is the responsibility of interested 

parties, and that the Secretary makes the final decision regarding the value of particular 

utility to the consumer. It is evident that commenters to DOE rulemakings often have not 

provided the preponderance -of evidence necessary to maintain-certain features. This may 

reflect a certain degree of ambiguity in the provisions of NAECA. 

The discussion of utility in the House of Representatives Report on NAECA (House of 

Representatives Report No. 100-11) provides additional insights that clarify the intent of 

congress with respect to appliance utility. The House Report states that DOE must not 
7-5

promulgate". . . a standard that manufacturers are only able to meet by adopting

engineering changes that eliminate performance characteristics. "(13) [pg. 231 The report goes

on to state that:

A standard would result in the 'unavailability' of characteristics,

etc., f as a result of the standard, a product containing such

characteristic would become prohibitively expensive, i.e., if there

would be minimal demand for the product having such characteristic.'3

The report also offers specific examples of performance characteristics and features

that should be preserved. The examples of performance characteristics include "safety

ability to clean or dry without adverse effects; serviceability; and incidence and cost or [sic]

repair. (13) Examples of features include through-the-door ice service on refrigerators and

noise levels'3 Although the exact characteristic or feature need not be kept, NAECA

requires that "substantially the same" characteristics and features remain available. These

specifications and examples clearly illustrate that congress intended NAECA to increase

efficiency without sacrificing utility and without dramatically increasing the cost to

consumers of particular features.

Although manufacturers are not constrained to use any particular engineering approach

in order to meet minimum efficiency requirements for performance-based standards, DOE's

rulemaldng analysis is based on design options; therefore, efficiency impacts are directly tied

to the presence or absence of particular design elements. This consideration is particularly

important in cases where the addition or deletion of a particular feature is credited with a

significant efficiency impact in the DOE analysis. For example, in the range and oven

rulemaking, elimination of the oven door window was credited with a significant efficiency

increase. However, the oven door window is an important feature to consumers that is

similar to the through-the-door ice service feature for refrigerators cited by congress as an

example of a useful feature. The analysis states that consumers obtain essentially the same

functionality provided by the oven door window by simply opening the door, but this action

has its own energy impact and may pose an unnecessary safety hazard. Although manufacturers may be able to meet the higher efficiency standard without eliminating the oven door

EE-RM-90-201 COMMENT OOR13

7-5 

promulgate" ... a standard that manufacturers are only able to meet by adopting 

engineering changes that eliminate performance characteristics. "(13) [pg. 23] The report goes 

on to state that: 

A standard would result in the 'unavailability' of characteristics, 

etc., if, as a result of the standard, a product containing such 

characteristic would become prohibitively expensive, i. e., if there 

would be minimal demand for the product having such characteristic. (13) 

The report also offers specific examples of performance characteristics and features 

that should be preserved. The examples of performance characteristics include "safety ... 

ability to clean or dry without adverse effects; serviceability; and incidence and cost or [sic] 

repair. ,,(13) Examples of features include through-the-door ice service on refrigerators and 

noise levels·(l3) Although the exact characteristic or feature need not be kept, NAECA 

requires that "substantially the same" characteristics and features remain available. These 

specifications and examples clearly illustrate that congress intended NAECA to increase 

efficiency without sacrificing utility and without dramatically increasing the cost to 

consumers of particular features. 

Although manufacturers are not constrained to use any particular engineering approach 

in order to meet minimum efficiency requirements for performance-based standards, DOE's 

rulemaking analysis is based on design options; therefore, efficiency impacts are directly tied 

to the presence or absence of particular design elements. This consideration is particularly 

important in cases where the addition or deletion of a particular feature is credited with a 

significant efficiency impact in the DOE analysis. For example, in the range and oven 

rulemaking, elimination of the oven door window was credited with a significant efficiency 

increase. However, the oven door window is an important feature to consumers that is 

similar to the through-the-door ice service feature for refrigerators cited by congress as an 

example of a useful feature. The analysis states . that consumers obtain essentially the same 

functionality provided by the oven door window by simply opening the door, but this action 

has its own energy impact and may pose an unnecessary safety hazard. Although manufacturers may be able to meet the higher efficiency standard without eliminating the oven door 
7-6

window, doing so would be likely to greatly increase the life-cycle cost of the oven, thereby

reducing or eliminating the benefits to consumers of the higher efficiency.

The issue of utility is particularly important for ranges and ovens because the perceived

usefulness of these appliances is judged by their cooking quality, which is a highly subjective

criterion. Thus, simple heat delivery is not a sufficient measure of the utility of cooking

appliances. A design option may increase the energy efficiency of a cooking appliance, but

if use of the design option alters the products of that appliance, consumer expectations may

not be satisfied. For example, food cooked in convection ovens may or may not be

satisfactory because, due to the nature of the heat transfer process in convection ovens, the

characteristics of food cooked in these ovens may be different from those of food cooked in

conventional ovens. In addition, cooking times and techniques specified in recipes may need

to be substantially modified to yield successful results with convection ovens. Thus, even

though a given design option may provide satisfactory results while saving energy, an

appliance equipped with that option may not provide performance compatible with consumer

expectations, thereby altering the utility of the appliance in an unacceptable way.

To satisfy the requirements of NAECA, DOE not only must consider purely

quantitative technical and economic data, but also must carefully evaluate the impacts of the

proposed standards on the continued availability of useful features and performance characteristics. Although the proposed standards for cooking appliances do not prescribe which

design options manufacturers must use to meet the standards, they may implicitly preclude

the use of features that consumers find beneficial or require the use of options that change

the quality of food prepared with these appliances. The fact that the nature of the cooking

process is not simply a matter of effective heat transfer and that food quality is the most

important, though purely subjective, measure of the usefulness of cooking appliances

suggests that DOE must give careful consideration to the issue of appliance utility in the

range and oven rulemaking.

EE-RM-90-201 COMMENT OOR13

7-6 

window, doing so would be likely to greatly increase the life-cycle cost of the oven, thereby 

reducing or eliminating the benefits to consumers of the higher efficiency. 

The issue of utility is particularly important for ranges and ovens because the perceived 

usefulness of these appliances is judged by their cooking quality, which is a highly subjective· --

criterion. Thus, simple heat delivery is not a sufficient measure of the utility of cooking 

appliances. A design option may increase the energy efficiency of a cooking appliance, but 

if use of the design option alters the products of that appliance, consumer expectations may 

not be satisfied. For example, food cooked in convection ovens mayor may not be 

satisfactory because, due to the nature of the heat transfer process in convection ovens, the 

characteristics of food cooked in these ovens may be different from those of food cooked in 

conventional ovens. In addition, cooking times and techniques specified in recipes may need 

to be substantially modified to yield successful results with convection ovens. Thus, even 

though a given design option may provide satisfactory results while saving energy, an 

appliance equipped with that option may not provide performance compatible with consumer 

expectations, thereby altering the utility of the appliance in an unacceptable way. 

To satisfy the requirements of NAECA, DOE not only must consider purely 

quantitative technical and economic data, but also must carefully evaluate the impacts of the 

proposed standards on the continued availability of useful features and performance characteristics. Although the proposed standards for cooking appliances do not prescribe which 

design options manufacturers must use to meet the standards, they may implicitly preclude 

the use of features that consumers find beneficial or require the use of options that change 

the quality of food prepared with these appliances. The fact that the nature of the cooking 

process is not simply a matter of effective heat transfer and that food quality is the most 

important, though purely subjective, measure of the usefulness of cooking appliances 

suggests that DOE must give careful consideration to the issue of appliance utility in the 

range and oven rulemaking. 

. , 
8. CONCLUSIONS

Of the DOE design options evaluated for kitchen ranges, none are justified based on -

life-cycle cost; loss of consumer utility; or safety, technical, or food qualilty considerations.

This is primarily due to the low level of gas usage that is typical in today's cooking process.

A range uses so little gas during the year (approximately $14 for a self-cleaning range at

current gas rates) that it is difficult to justify design modifications for energy savings, since

the cost of the modifications proposed by DOE cannot be recovered on the basis of energy

saved.

Life-cycle cost analysis shows only the use of electric ignition on stand-alone cooktops

can be justified. Stand-alone cooktops are a small fraction of total gas cooking appliance

production.

The following recommendations are offered to DOE and the appliance industry, based

on the research conducted to date.

o Use a recent metered study27 as basis to determine Annual Gas

Cooking Energy Consumption usage levels. Do not use Conditional

Demand Analysis (CDA) estimates to determine usage for low gasconsuming appliances such as ranges.

• Use current average energy costs without markup factors.

• Assumptions of efficiency increases need to be reexamined by DOE

based on the experimental data in this and the previous GRI report.8

• Consumer utility and cooking quality must be considered when

analyzing design options, as intended by NAECA.

• A 2.81 markup from manufacturer was used throughout this analysis

as a simple alternative to a variety of markups based on complex

modeling. Because 90 percent of the market is the combined range

product, one markup is more representative of today's marketplace

than separate numbers for various pieces (cooktops, ovens).

• At least four door openings during each test period should be

considered when evaluating the energy savings of removing the oven

door window.

EE-RM-90-201 COMMENT OOR13

8. CONCLUSIONS 

Of the DOE design options evaluated for kitchen ranges, none are justified based on 

life-cycle cost; loss of consumer utility; or safety, technical, or food qUalilty considerations. 

This is primarily due to the low level of gas usage that is typical in today's cooking process. 

A range uses so little gas during the year (approximately $14 for a self-cleaning range at 

current gas rates) that it is difficult to justify design modifications for energy savings, since 

the cost of the modifications proposed by DOE cannot be recovered on the basis of energy 

saved. 

Life-cycle cost analysis shows only the use of electric ignition on stand-alone cooktops 

can be justified. Stand-alone cooktops are a small fraction of total gas cooking appliance 

production. 

The following recommendations are offered to DOE and the appliance industry, based 

on the research conducted to date. 

• Use a recent metered study(27) as basis to determine Annual Gas 

Cooking Energy Consumption usage levels. Do not use Conditional 

Demand Analysis (CDA) estimates to determine usage for low gasconsuming appliances such as ranges. 

• Use current average energy costs without markup factors. 

• Assumptions of efficiency increases need to be reexamined by DOE 

based on the experimental data in this and the previous GRI report. (8) 

• Consumer utility and cooking quality must be considered when 

analyzing design options, as intended by NAECA. 

• A 2.81 markup from manufacturer was used throughout this analysis 

as a simple alternative to a variety of markups based on complex 

modeling. Because 90 percent of the market is the combined range 

product, one markup is more representative of today's marketplace 

than separate numbers for various pieces (cooktops, ovens). 

• At least four door openings during each test period should be 

considered when evaluating the energy savings of removing the oven 

door window. 
8-2

• Reduce the number of self-clean cycles per year in the DOE test

procedure from seven to, at most, four.

• Use current forecasts of future fuel costs.'°' 11)

• Include maintenance costs and installation costs where necessary

(e.g., both maintenance and installation costs for electric ignition,

and maintenance costs for forced convection).

Given the low gas usage of ranges, the very small benefits of any proposed efficiency

standard must be weighed against the lost utility to the consumer and the increased cost of

compliance to the manufacturer.

EE-RM-90-201 COMMENT OOR13

8-2 

• Reduce the number of self-clean cycles per year in the DOE test 

procedure from seven to, at most, four . 

• Use current forecasts of future fuel costs. (10, 11) 

• Include maintenance costs and installation costs where necessary 

(e.g., both maintenance and installation costs for electric ignition, 

and maintenance costs for forced convection). 

Given the low gas usage of ranges, the very small benefits of any proposed efficiency 

standard must be weighed against the lost utility to the consumer and the increased cost of 

compliance to the manufacturer. 

, " 
9. REFERENCES

1. Public Law 100-12, "National Appliance Energy Conservation Act of 1987,"

January 6, 1987.

2. Public Law 94-163, "Energy Policy and Conservation Act (EPCA)," December 22,

1975.

3. U.S. Department of Energy (DOE), "Final Energy Conservation Test Procedures,

Conventional Ranges, Cooking Tops, Ovens, Microwave Ovens, Microwave/Conventional Ranges, Furnaces and Vented and Unvented Home Heating Equipment," Federal

Register, Vol. 43, No. 91, Wednesday, May 10, 1978, Part 11, Federal Energy

Administration, Part 430, Energy Conservation Program for Appliances, Final Rule.

4. DOE, Technical Support Docwnent: Energy Efficiency Standards for Conswner

Products: Room Air Conditioners, Water Heaters, Direct Heating Equipment, Mobile

Home Furnaces, Kitchen Ranges and Ovens, Pool Heaters, Fluorescent Lamp Ballasts

& Television Sets, Volume E. Ranges and Ovens, DOE Report No. DOEIEE-0009,

November 1993.

5. DOE, "Energy Conservation Program for Consumer Products: Proposed Rule,"

Docket No. EE-RM-90-201, Federal Register, Vol. 59, No. 43, Friday March 4,

1994, Part II, Office of Energy Efficiency and Renewable Energy, 10 CFR Part 430.

6. DOE, op. cit., Technical Support Document. . . Vol. E, p. A-S (Southern California

Edison, 1988). Data from Residential Energy Usage Comparison project by Southern

California Edison Company and EPRI. It is based on a sample of 92 households in

Orange County, California. Derived from B. A. Smith, R. T. Uhlaner, and T. N.

Cason, Residential Energy Usage Comparison Project: An Overview, Quantum

Consulting, Inc., Berkeley CA, October 1990.

7. Electhc Power Research Institute (EPRI), Residential Energy Usage Comparison:

Findings, EPRI Report No CU-7392, Project 2863-3, Final Report, prepared by

Quantum Consulting, Inc., Berkeley CA, August 1991.

8. Battelle, et al., Technical Input to NAECA Rulemaking for Gas-Fired Ranges, GRI

Interim Report No. GRI-93/0319, July 1993.

9. DOE, "Energy Conservation Program for Consumer Products; Advance Notice of

Proposed Rulemaking Regarding Energy Conservation Standards for 9 Types of

Consumer Products," Federal Register, Vol. 55, No. 189, September 28, 1990.

EE-RM-90-201 COMMENT OOR13

9. REFERENCES 

1. Public Law 100-12, "National Appliance Energy Conservation Act of 1987," 

January 6, 1987. 

2. Public Law 94-163, "Energy Policy and Conservation Act (EPCA) , " December 22, 

1975. 

3. u.s. Department of Energy (DOE), "Final Energy Conservation Test Procedures, 

Conventional Ranges, Cooking Tops, Ovens, Microwave Ovens, Microwave/Conventional Ranges, Furnaces and Vented and Unvented Home Heating Equipment," Federal 

Register, Vol. 43, No. 91, Wednesday, May 10, 1978, Part 11, Federal Energy 

Administration, Part 430, Energy Conservation Program for Appliances, Final Rule. 

4. DOE, Technical Suppon Document: Energy Efficiency Standards for Consumer 

Products: Room Air Conditioners, Water Heaters, Direct Heating Equipment, Mobile 

Home Furnaces, Kitchen Ranges and Ovens, Pool Heaters, Fluorescent Lamp Ballasts 

& Television Sets, Volume E. Ranges and Ovens, DOE Report No. DOE/EE-0009, 

November 1993. 

5. DOE, "Energy Conservation Program for Consumer Products: Proposed Rule," 

Docket No. EE-RM-90-201, Federal Register, Vol. 59, No. 43, Friday March 4, 

1994, Part n, Office of Energy .Efficiency and Renewable Energy, 10 CFR Part 430. 

6. DOE, op. cit., Technical Suppon Document. . . Vol. E, p. A-5 (Southern California 

Edison, 1988). Data from Residential Energy Usage Comparison project by Southern 

California Edison Company and EPRI. It is based on a sample of 92 households in 

Orange County, California. Derived from B. A. Smith, R. T. Uhlaner, and T. N. 

Cason, Residential Energy Usage Comparison Project: An Overview, Quantum 

Consulting, Inc., Berkeley CA, October 1990. 

7. Electric Power Research Institute (EPRI), Residential Energy Usage Comparison: 

Findings, EPRI Report No CU-7392, Project 2863-3, Final Report, prepared by 

Quantum Consulting, Inc., Berkeley CA, August 1991. 

8. Battelle, et al., Technical Input to NAECA Rulemaking for Gas-Fired Ranges, GRI 

Interim Report No. GRI-93/0319, July 1993. 

9. DOE, "Energy Conservation Program for Consumer Products; Advance Notice of 

Proposed Rulemaking Regarding Energy Conservation Standards for 9 Types of 

Consumer Products," Federal Register, Vol. 55, No. 189, September 28, 1990. 
9-2

10. Energy Information Administration (EIA), Annual Energy Outlook 1994 With

Projections to 2010, Report No. DOE/EIA-0383(94), January 18, 1994. Office of

Integrated Analysis and Forecasting, U.S. Department of Energy, Washington D.C.

20585.

11. EIA, Average Regional End-Use Energy Price Projections to the Year 2030, Report

No. SR/EDID-91-03, Prepared for the Office of Federal Energy Management

Programs, U.S. Department of Energy.

12. DOE, op. cit., Technical Support Docwnent. . . Vol. E, p. 1-23.

13. H.R. Report No. 100-11, 100± Congress, 1st Session, pp. 22-23.

14. ORTECH International, Energy-Efficient Electrical Product Knowledge Base. Prepared

by ORTECH International, Mississauga, Ontario, Canada, for the Canadian Electrical

Association, C.E.A., No. 821 U 678, October 1989, p. 27.

15. DOE, Engineering Analysis, Washington D.C., DOE/CS-0166, June 1980, pp. D7-3 to

D7-4.

16. National Electrical Code, National Fire Protection Associates (NFPA), Batterymarch

Park, Quincy MA, NFPA7O, August 14, 1993, Section 210-50(c).

17. SAl, Energy Efficiency Program for Kitchen Ranges and Ovens, Science Applications,

Inc., La Jolla CA, Report No. HCP/M60727-01, prepared for DOE under Contract

CR-04-60727-0O, 1977, p. 6.

18. Dacor, Convection Plus: Single and Double Electric Ovens Use and Care, User's

Manual, May 1992.

19. Lovingood, R.P., E.A. DeMerchant and L.J. Hines, "Oven Performance in

Convection vs. Radiant Mode," Proceedings of the 45th Annual International

Appliance Technical Conference, Madison WI, May 9-11, 1994.

20. Heist, J., and M.L. Cresser, "Sensory Quality and Energy Use for Baking of Molasses

Cookies Prepared with Bleached and Unbleached Flour and Baked in Infrared, Forced

Air Convection, and Conventional Deck Ovens," Journal of Food Science, Vol. 55,

No. 4, 1990, pp. 1095-1100.

21. AHAM, letter from Craig A. Schulz, Director, Marketing and Economics, AHAM, to

Isaac Turiel, Staff Scientist, Lawrence Berkeley Laboratory, February 15, 1991, p. 3.

EE-RM-90-201 COMMENT OOR13

9-2 

10. Energy Information Administration (EIA), Annual Energy Outlook 1994 With 

Projections to 2010, Report No. DOE/EIA-0383(94), January 18, 1994. Office of 

Integrated Analysis and Forecasting, U.S. Department of Energy, Washington D.C. 

20585. 

11. EIA, Average Regional End-Use Energy Price Projections to the Year 2030, Report 

No. SRIEDID-91-03, Prepared for the Office of Federal Energy Management 

Programs, U.S. Department of Energy. 

12. DOE, op. cit., Technical Suppon Document . .. Vol. E, p. 1-23. 

13. H.R. Report No. 100-11, looth Congress, 1st Session, pp. 22-23. 

14. ORTECH International, Energy-Efficient Electrical Product Knowledge Base. Prepared 

by ORTECH International, Mississauga, Ontario, Canada, for the Canadian Electrical 

Association, C.E.A., No. 821 U 678, October 1989, p. 27. 

15. DOE, Engineering Analysis, Washington D.C., DOE/CS-0166, June 1980, pp. D7-3 to 

D7-4. 

16. National Electrical Code, National Fire Protection Associates (NFPA) , Batterymarch 

Park, Quincy MA, NFPA70, August 14, 1993, Section 21O-50(c). 

17. SAl, Energy Efficiency Program for Kitchen Ranges and Ovens, Science Applications, 

Inc., La Jolla CA, Report No. HCP/M60727-01, prepared for DOE under Contract 

CR-04-60727-oo, 1977, p. 6. 

18. Dacor, Convection Plus: Single and Double Electric Ovens Use and Care, User's 

Manual, May 1992. 

19. Lovingood, R.P., E.A. DeMerchant and L.J. Hines, "Oven Performance in 

Convection vs. Radiant Mode," Proceedings of the 45th Annual International 

Appliance Technical Conference, Madison WI, May 9-11, 1994. 

20. Heist, J., and M.L. Cresser, "Sensory Quality and Energy Use for Baking of Molasses 

Cookies Prepared with Bleached and Unbleached Flour and Baked in Infrared, Forced 

Air Convection, and Conventional Deck Ovens," Journal of Food Science, Vol. 55, 

No.4, 1990, pp. 1095-1100. 

21. AHAM, letter from Craig A. Schulz, Director, Marketing and Economics, AHAM, to 

Isaac Turiel, Staff Scientist, Lawrence Berkeley Laboratory, February 15, 1991, p. 3. 
9-3

22. ADM, Costing Analysis of Design Options for Residential Appliances and Space

Conditioning Equipment, Final Report, prepared by ADM Associates, Inc., Sacramento

CA, for Lawrence Berkeley Laboratory, December 1987.

23. AHAM, op. cit., p. 2, Section e.

24. Conswner Reports, "Guide to Choosing a Gas Range," January 1994, pp. 12-17.

25. Flood, J., and T. Enga, "Energy Conservation Aspects of Cooking Appliances,"

Proceedings of the 1983 International Gas Research Conference, Watson House,

British Gas Corp., 1983, pp. 741-754.

26. Code of Federal Regulations, Title 10, Part 430, Subpart B, Appendix I.

27. Battelle, Metered Ranges, Cooktops and Ovens in the Northern Illinois Gas Residential

Load Study Data Base, GRI Topical Report No. GRI-93/0204, July 1993. (This report

was also included as Appendix F in Reference 8.)

EE-RM-90-201 COMMENT OOR13

9-3 

22. ADM, Costing Analysis of Design Options for Residential Appliances and Space 

Conditioning Equipment, Final Report, prepared by ADM Associates, Inc., Sacramento 

CA, for Lawrence Berkeley Laboratory, December 1987. 

23. AHAM, op. cit., p. 2, Section e. 

24. Consumer Repons, "Guide to Choosing a Gas Range," January 1994, pp. 12-17. 

25. Flood, J., and T. Enga, "Energy Conservation Aspects of Cooking Appliances," 

Proceedings of the 1983 International Gas Research Conference, Watson House, 

British Gas Corp., 1983, pp. 741-754. 

26. Code of Federal Regulations, Title 10, Part 430, Subpart B, Appendix I. 

27. Battelle, Metered Ranges, Cooktops and Ovens in the Nonhem Illinois Gas Residential 

Load Study Data Base, GRI Topical Report No. GRI-93/0204, July 1993. (This report 

was also included as Appendix F in Reference 8.) 
9-4

EE-RM-90-201 COMMENT OOR13

9-4 
Appendix A

Results of Life-Cycle Cost Analysis

EE-RM-90-201 COMMENT OOR13

Appendix A 

Results of Life-Cycle Cost Analysis 
A-i

APPENDIX A. RESULTS OF LIFE-CYCLE COST ANALYSIS

Tables A-i through A-20 show the inputs, outputs, and year-by-year cash flows for -

each design option analyzed. The block in the upper left shows the added installed cost for

the design option, the energy usage for the modified range, and the cooking efficiency and

energy factor. The next block to the right shows assumptions about fuel cost scenario,

discount rate, appliance life and markup from factory floor manufacturing cost to retail sale.

Below these are the inputs for the base case range, energy use, and efficiencies for the base

case range.

The last two blocks show the figures of merit for the modified case and the sensitivities to gas cost, life, discount rate, equipment cost, and energy usage. The energy usage

sensitivity values of 165 and 215 percent correspond roughly to the ratio of gas use inferred

for ovens from the DOE proposed (NOPR) and current (10 CFR 430) procedures to the gas

use found in the metered appliance study. The 150 and 215 percent values correspond

roughly to the ratios calculated for cooktops for the proposed and current DOE rules. See

Chapter 5 for details on the assumptions.

The section at the bottom of the spreadsheet shows the cash flows by year for the

modified range and base case range.

EE-RM-90-201 COMMENT OOR13

A-I 

APPENDIX A. RESULTS OF LIFE-CYCLE COST ANALYSIS 

Tables A-I through A-20 show the inputs, outputs, and year-by-year cash flows for 

each design option analyzed. The block in the upper left shows the added installed cost for 

the design option, the energy usage for the modified range, and the cooking efficiency and 

energy factor. The next block to the right shows assumptions about fuel cost scenario, 

discount rate, appliance life and markup from factory floor manufacturing cost to retail sale. 

Below these are the inputs for the base case range, energy use, and efficiencies for the base 

case range. 

The last two blocks show the figures of merit for the modified case and the sensitivities to gas cost, life, discount rate, equipment cost, and energy usage. The energy usage 

sensitivity values of 165 and 215 percent correspond roughly to the ratio of gas use inferred 

for ovens from the DOE proposed (NOPR) and current (10 CFR 430) procedures to the gas 

use found in the metered appliance study. The 150 and 215 percent values correspond 

roughly to the ratios calculated for cooktops for the proposed and current DOE rules. See 

Chapter 5 for details on the assumptions. 

The section at the bottom of the spreadsheet shows the cash flows by year for the 

modified range and base case range. 
Table A-O. Summary of Results of Life-Cycle Cost Analysis

ReModUjcelIon

AIVUOZCd

Ne-

$,r

Erorgy

doved

Ut'yr

Get Saved

Aiviuñzed

9/yr

Added

letCost

$

Ove Use

Bus

kffittyr

Elect.

Bate

kWh/yr

Cooking

EnBa,.

kB(Wyr

G.e Use

Mod.

kB1i,r

Eled.

Mod.

kWtyr

Cooldng

En.Mod.

kBhyr

Cooking

Efficiency

Baselne

Cooking

Efficiency

Modtled

Energy

Factor

Basetne

Energy

Factor

ModOled

I NesnooorW!ndow,No000rOpaninga 041 60 0.43 0.00 2,792 1284 2,132 1,224 892% 02I% 2.72% 2.78%

81.,derd Oven

2 NoOvenDoorWlndow,N0000rOpenlngs 023 35 0.25 0.00 1,130 81.5 1,008 1,104 01.8 1,031 1.13% 7.31% 5.84% 5.70%

Sd-Cleaning Oven

3 NoOvonDoorWndow,4DoorOp*nings 021 34 0.24 0.00 2.702 1,284 2,750 1,250 8.92% 0,00% 2.72% 2.70%

Otaidard Oven

4 NoOvenOoorWlndow,4000rCper*ige 00i -3 -0.02 0.00 1,130 01.8 1,060 1,142 01.5 1,060 7.13% 7.11% 8.04% 8.03%

Sd-CIeer*rg Oven

8 8tagPaflqstacedw9hEledronlEaIetingOctls4 -314 2,0410 *4,70 10.34 S,142 1,092 1,002 1,002 3900% 39.00% 13.86% 39,90%

Cooktop

0 Ole gPllotsfliecadwRhE bn,1/2NewOlstCoat ill 3.050 14.78 03.33 3,142 1,002 1,002 1,002 3900% 3900% 13.66% 3900%

Cooktcp

1 StandingP0otsRsptsnedwhEledmnlcflN.wOtAls4 -29 3.050 14.70 108.25 3,142 1,002 1,002 1,002 3990% 30.90% 13.88% 30.00%

Cool0

• OgPotsRnedw$hEledclgnffion.EsI$tIngOsdlet -2C2 1,492 11.44 33.89 2,702 1,284 1,204 29.2 1,304 8.02% 6.03% 2.72% 8.63%

Staiderd Oven

0 Standing POols Replaced w6hEledronlc $gr8lon, 1/2 NewOIet Cost - II Il 1,450 11.44 10.80 2,702 1,284 1,204 20.2 1,304 8.02% 6.03% 2.72% 5.83%

Standard Oven

10 SleqPNotsRepdwIhEl.dctgnhlIon,N.wOiAlet -1013 1.469 11.44 123.08 2,702 1,264 1,204 20.2 1,304 8.02% 8.83% 2.72% 8,83%

Standard Oven

II ksprovedDoor8e.ls -010 13 000 3.08 2,702 1,284 2,780 1,271 5.02% 810% 2.72% 2.73%

Staintard Oven

12 knproved000r8aals -021 II 0.00 3.15 1,130 8I.8 1,088 1,129 01.8 1,050 7.13% 7.20% 8.84% 5.08%

SeO-Ctsanlng Oven

13 Forc,dConvsctlonaddsdtoslend&rd-PIue-EladrlctgnOlon -1401 60 055 131.12 1,204 292 1,304 1,127 31.7 1,230 8.03% 0.18% 8.03% 6.15%

Standard Oven

14 Reduced VeedRate -03. P 0.05 4.68 2,792 1,284 2,768 *277 8.02% 8.95% 2.72% 2.73%

Standard Oven

18 ReOodtve8ialicee--Clwoene-PIatndOvflCav6y -013 -105 -1.33 63.88 2,792 1,264 2,078 1,480 6.02% 8.17% 2.72% 2.85%

Standard Oven

18 Re41sde8waces--Clwoine--PietedOvSnCan$y -57.1 -129 -0.03 83.88 1,130 01.5 1,088 1,288 81.5 *105 1.13% 630% 8.04% 5,15%

Sel-Cteanltg Oven

17 AddedlnsutantortheCdkle*EflVOlops -1 77 0 0.00 10.70 2,702 1,284 2,702 1,284 8,02% 6,02% 2.72% 2.72%

Standard Oven

IS Added Insulation br the CdtnetEnvelope -I 17 0 0.00 10.70 1,130 01.5 1,006 1,130 81.5 1,068 7.13% 7.13% 8.04% 5.64%

Sd-Cleaning Oven

10 rlneulatlonoul.IdeofConibustlenChwrblr -021 38 0.27 5.42 2,702 1,284 2,754 1,240 002% 0.10% 2.72% 2.70%

Standard Oven

20 RartucedCorductlonLo.seI--PyrOIyICOVOnCOflattIon -88.. 217 1.58 03.82 2,792 1,254 2,578 1,066 5,92% 7,12% 2.72% 2,05%

Standard Oven

EE-RM-90-201 COMMENT OOR13

Range Mod.leallon 

No o..n 000' WIndow. No 000' Op.nIng' 

StorIIa,d o..n 

2 No o..n Doo'WIndo .... No Doo'Oponlngl 

SI.-Cloaning o..n 

3 No o..n 000' WIndow. 4 Doo, Opening. 

StorIIerd 0.." 

No o..n 000' WIndow. 4 Doo, Opining. 

S.I-C".nIng o..n 

8 Bllnd~ PIoII Roplaced wlh ElocIronic Ignllon. E ... I~ o..c ... Coold ... 

• Blllnd~ PIoI. RopIoclKl wlh ElocIronic Ignllon. 1/2 _ o..clol COil 

Cooldop 

7 Blllnd~ PIGII RoploclKl wlh ElocIronic Ignllon. _ a.. ... Cooldop 

• Blllnd~ PIola Roplacad will ElocIronic Ignllon. E ... I~ o..c ... BtorIIanl o..n 

• Blllnd~ PIGI. Roplaced wlhElocIronic Ignllon. 1/2 _o..c ... COil 

, IIlonderd o..n 

1 0 Btond~ PIotI RoploclKl will ElocIronic Ignllon. _ o..c ... I Ionderd 0.." 

11 ImproYOd 000'1 .... 

llonderd o..n 

12 ImproYOd Doo'I .... 1 .. -CIoanIng o..n 

13 Forc:al Co_Ion addod 10 BI.nderd - ptuo - EIocI,Ic Ignllo" 

I Ionderd o..n 

14 Roducad Ven! Roll 

IlIInderdo..n 

II ReIIacI .... BurI_--CIIrorno-P!alod o..n CavIy 

llonderd o..n 

18 ReIIacI .... lurI .... --CIIrorno-P!alod o..nClvty 

"'-C"1nIng o..n 

17 AddId !noulollon 10, "'" Cmln'" Envelope 

8 tanlerd o..n 

1 B Addod !noulallo" 10, lho Cmln'" ElMllopl 

1"-C"1nIng o..n 

II r !noulallon oUllld. 01 Combuollon Chamb., 

llardlnl o..n 

20 Roducad Conduellon lOlln--l'yrolVlc o..n Conolrucllon 

ltorIIanl o..n 

Table A-O. Summary of Results of Life-Cycle Cost Analysis 

Elocl. COOking 

En. a ••• kBllW' 

1.012 

1.012 

1.012 

1.304 

1.088 

Cooking 

Eftlclancy 

Ba ..... 

COOking 

Eftlclancy 

Mod.1ad 

Energ)' 

Flelo, 

Mod.1ad 

> t!.> 
Table A-i. No Oven Door Window, No Door Openings--Standard Oven

COST CALCULATION DOLLARS ASSUMPTIONS FIESULTS @6% DIac. Rt.

Al CauIaIIona are In Constant 1990 Dollars Fuel Coil Scenario DOE, Rs.tdantat, Ret. Ca.. Annusized Net Say. 043 SAir

Discount Rate (R.a 0.0% Benett/Cost(.) NA

MODIFIED RANGE Applance UI., Year. 10 hInt Rate of Relom NA

Mark Up fran Manulsctuttng Cost 2.61 SImple Payback NA

Added kiataled Cost $ 0.00 Net Energy Saved 60 ltBtu/yr

BASE CASE RANGE Annusized Gee 8av. 0.43 SNr

MaIntenance Cost, 8, NPV @6% 0.00 MaIntenance Cost, 8, NPV @6% 0.00

Os., Annual Cooldng Us., 1000 Bttflrr 1,224 Gas, AnnualCooldng Use, 1000 Btrrr 1,264

Gas, Non-Cooking PIlate, 1000 BtJ4rr 1506 0.., Non-Cooldng Plot., 1000 Btj'r 1,508 SENSITIVITY

Gsa, 8.6 Clean, 1000 Blu/yr, 0 Cycles 0 0.., 8.11 Clean, 1000 Btu/yr, 0 Cycles 0

Gas,Total Uae, l0000tu/yr 2,732 Oa.,Total Use, l000Btu4,r 2,702 . GAS COST An Say, $ BR/Cat

SensltMty 60% 0.35 NA

to Ga. 120% 0.52 NA

Cost

APPLIANCE LIFE An Say, $ BIt/Cat

Energy, Annual Cooldng Us., 1000 Blu 1,224 Energy, kulual Cooking U.., 1000 Btujyr 1,264

Cooking Eflclsncy 8.2l Cooking Ef%clsncy 5.92% SensitIvity -2 0.43 NA

Energy, Total Annual Us., 1000 BItt/yr 2.732 Energy, Total Annual U.., 1000 Blu/yr 2,792 toYrs. Ut. 2 0.44 NA

Energy Fsctor 2.78% Energy Fsctor 2.72% CitIng.

Year 1997 1908 1Q00 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

DISCOUNT RATE An Say, $ BR/Cat

SensitIvity 2.0% 0.44 NA

to Dlac'nt 7.0% 0.43 NA

Rate 15.0% 0.42 NA

FiRST COST

SensitIvity 75%

to FIrst 65%

Coat 120%

150%

GAS QUANTITY

SenittMty 60%

to Amount 125%

olGa., 150%

Base& 105%

Modilled 215%

An Say, $ BR/Cit

0.43 NA

0.43 NA

0,43 NA

0.43 NA

MSav,$ BR/Cal

0.35 NA

0.54 NA

0.65 NA

0.71 NA

0.93 NA

2012 2013 2014 2015 2016 2017

MODIFIED RANGE

Installed Cost, Addtlonal 0.00

Maintenance Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

MnualNatjralGaaCost 17.10 11.56 16.02 18.30 18.50 16.88 19.18 19.46 10.62 20.18 20.50 20.86 21.22 21.60 21.99 22.38 22.70 23.20 23.48 0.00

Annual Electricity Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TotalCoats 0.00 17.10 17.58 16.02 16.30 16.80 18.66 10.16 19.46 10.62 20.16 20.50 20.66 21.22 21.00 21.00 22.38 22.70 23.20 23.48 0.00

BASE CASE RANGE

Maintenance Coat 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

AnnualNa*.ralGaaCo.t 11.48 11,94 18.42 18.71 10.00 10.30 19.80 10.01 20.25 20.60 20.95 21.32 21.68 22.07 22.47 22.88 23.20 23.71 23.99 0.00

MnualElactilclty Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TotalCoats 11.48 11.04 16,42 18,71 10.00 19.30 19.60 10.01 20.25 20.60 20.05 21.32 21.68 22.07 22.47 22.88 23.29 23.11 23.90 0.00

IESLLT8

Net8aitnga,ModltiedRang. 0.00 0.38 0.30 0.40 0.40 0.41 0.41 0.42 0.43 0.43 0.44 0.45 0.48 0.41 0.41 0.48 0.49 0.50 0.51 0.52 0.00

(a) ItInlIalcost positive, net present valu, at future aavlngsflnltlalcost; It nltlalcost negatIve, Inlial .Ivlnge/NPV of futursco.ta. DATA SET No. A-i (DOE-I) 05/20/94

EE-RM-90-201 COMMENT OOR13

Table A-l. No Oven Door Window, No Door Openings--Standard Oven 

COST CAlCUlATION DOLLARS ASSUMPTIONS RESULTS @ ~ Dloc. RI. 

An CllcuIaUon. Ira In Conllant 1990 Dona .. Fuel ColI Sc."a~o DOE, Resld81'al, Ret. c ••• Annu •• zed Not Sav. 0.43 Sly, DISCOUNT RATE An Sav, S BnICII 

Dlocount Rata (Ra.~ 8.0% Beneftt/ColI( a) NA 

MODIFIED RANGE Applonc. lJIe, v .... 18 Int.,1 Rate 01 Rallm N ... SenllUoAty 2.0% 0.44 N ... 

Mark 4> !ram Manufacturing ColI 2.81 Simple Poyba:k N ... to Dloc'nt 7.0% 0.43 N ... 

Added InIl.ftIed ColI, S 0.00 Net Energy Saved 80 kBtuly' Rat. 15.0% 0.42 NA 

BASE CASE RANGE Annullized Ga. Say. 0.43 Sly, 

MaintenlnCO ColI, ., NPV@ 8% 0.00 MaintenlnCO ColI, " NPV@ 8% 0.00 FIRST COST An Sav, S Bn/CII 

GIl, Annuli CookIng IJI., 1000 BlJlyr 1,224 Ga., Annual Cooldng UIa, 1000 BlJIy' 1,284 

Ga., Non-Cooking Pliol., 1000 BlJIy' 1,508 Ga., Non-CookIng PlIoI.,I000BIJIy' 1,508 SENSITIVITY SenlllMty 75% 0.43 N ... 

Ga., son Clean, 1000 Bluly', 0 eyelet 0 G •• , s.r Clean, 1000 Blulyr, 0 eyelet 0 toRrII 85% 0.43 NA 

Ga., ToIalUla, 1000 Bluly' 2,732 Ga., ToIallJle, l000Blu/yr 2,782 GAS COST An Sav,' Bn/CII Coli 120% 0.43 N ... 

150% 0.43 N ... 

Senoltlvlty 80% 0.35 NA 

toG •• 120% 0.52 NA GAS QUANTITY An Sav, S Bn/CII Coot 

S81111Mty 80% 0.35 No<. APPLIANCE UFE An Sav,' Bn/CII to Amount 125% 0.54 No<. 

Enorgy. 1rInu.1 Cooking UIa, 1000 Blul\ 1.224 Energy. IrInu al CookIng UIa. 1000 Blu/yr 1.284 of G •• , lSO'1C. 0.85 NA 

CookIng Ellclency 8.21% Cooldng Ellclency 5._ Sonoltlvlty -2 0.43 NA 80 •• & 185% 0.71 No<. 

Energy. Tolal """"aiUla, 10lIl Bluly' 2.732 Energy. ToI.1 """"aIUla. 10lIl Bluly' 2,782 to V ... Ule 2 0.44 N ... Modifted 215% 0.83 NA 

Energy FEto, 2.78% Energy FEto' 2.72% Chango 

V •• , 1887 lDD8 ,_ 2000 2001 2002 2003 2004 2005 200S 2007 2008 200G 2010 2011 2012 2013 2014 2015 2018 2017 > I 

W 

MOOtFIED RANGE 

Inllaftled ColI. AddIfonll 0.00 

MoInt811nCO ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annu.1 N.ll .. 1 Ga. ColI 17.10 17.58 18.02 18.30 18.50 18.88 10.18 111.48 10.82 20.18 20.50 20.88 21.22 21.80 21.88 22.38 22.70 23.20 23.48 0.00 

Annu.1 ElecloIcIty ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

ToI.ICoab 0.00 17.10 17.58 18.02 18.30 18.50 18.88 10.18 10.48 10.82 20.18 20.50 20.88 21.22 21.80 21.88 22.38 22.70 23.20 23.48 0.00 

BASE CASE RANGE 

Mlllnt811nCO ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annuli Nall .. 1 Gu ColI 17.48 17.04 18.42 18.71 10.00 10.30 18.80 10.01 20.25 20.80 20.05 21.32 21.88 22.07 22.47 22.88 23.28 23.71 23.88 0.00 

Annuli ElecloIcIty ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

ToIalCoab 17.48 17.04 18.42 18.71 10.00 10.30 111.80 lD.Ol 20.25 20.80 20.05 21.32 21.88 22.07 22.47 22.88 23.28 23.71 23.88 0.00 

RESULTS 

N .. Sa>Ang •• ModftIed Range 0.00 0.38 0.311 0.40 0.40 0.41 0.41 0.42 0.43 0.43 0.44 0.45 0.48 0.47 0.47 0.48 0.40 0.50 0.51 0.52 0.00 

(.) KlnI'alcoot pooltlva.n .. preunt v.llo 01 Mura u>Ango,1nltl.lcoat; K lnItIalcoatneg_.InI •• lu>Ang./NPV 01 IUtura coot •. D ... TASET No .... -l (DOE-I) 08!2~ 
Table A-2. No Oven Door Window, No Door Openings- -Self-Cleaning Oven

COST CALCULATION DOLLARS

AlICalculatlon, araln Constant 1990 Doflars

MODIFIED RANGE

Mded ln.le8sd Coat, $ 0.00

Malntananc. Coat, S. NPV @ 8% 89.05

Gas, Annual Cooldng Us., l000Bta/yr 932

Gas, Non-Cooldng Pilots, 1000 RU/yr 0

Gas, 8.8 Clean, 1000 Etu/yr, 4 Cycle. 173

Gas,TotalUs, I000Btu/yr 1104

Electclty, Annual Cooldng Us., Wh/yr 29.2

Elecl4clty, Clock, kWh/yr 31.5

EIeClclty, 808 Clean, kWh/yr 4 Cycles 0.7

Electilclty, Total, kWh/yr 01.5

Energy, Annual Cooldng 1.1.., 1000 BtuA 1,031

Cooldng Etfictsncy 7.37%

Energy, Total Annual U$, 1000 Stu/yr 1,314

Energy Fsctor 5.79%

Year 1997

ASSUMPTIONS

Fuel Coat 8cenao DOE, Rasldantel, Rat. Case

Discount Rate (Real) 0.0%

Applanc. life,Years 19

Mark Lfl, Iron, Mmulscturlng Coat 251

BASE CASE RANGE

ISU1TS @6% DIsc. Rt.

Annualzed Net 8ev. 0.25 S/yr

BOneR/Cost(s) NA

kThnI Rat. of Rdjm NA

Siniple Psybsck NA

Net Energy Saved 35 kBtu/yr

Annuslzsd Gas 8ev. 0.25 S/yr

MsInIOnanCe Cost, 5, NFV @ 8% 89.05

Gas, MnualCooldng Use, 1000 BtJ/yr 908

Gas, Non-Cooldng PIlot,, 1000 Sti/yr 0 SENSITIVITY

Ge,, 8.8 Clean, 1000 Blu/yr, 4 Cycle. 173

Gas, Total Ii,., 1000 Btu/yr 1,139 GAS COST An 8ev, $ 03/Cat

Eleclcfty, Annual Cooldng Us., kW1/yr 29.2 SanallIvity 80% 0.20 NA

EleC1elty, Clock. kWh/yr 31.5 to Ga. 120% 0.30 NA

ElectrIcIty, SoIl Clean, kWh/yr 4 Cycle. 0.7 Coat

ElectrIcIty, Total, kWh/yr 01.5

APPLIANCE UFE An Say, S Bit/Cit

Energy, Annual Cooldng Us., 1000 Btu/yr 1,000

Cooldng EffIcIency 7.13% San slttvtty -2 0.25 NA

Energy, Total Annual Use, 1000 RU/yr 1,349 to Yr.. UI. 2 0.25 NA

Energy Fsctor 5.04% Change

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

DISCOUNT RATE An 5ev, 5 BIt/Cat

San a4tJ.lty 2.0% 0.25 NA

to OIsc'nt 7.0% 0.25 NA

Rate 15.0% 0.24 NA

FiRST COST An Say, S Bft/Cst

Smsllntty 75% 0.25 NA

to FIrst 85% 0.25 NA

Cost 120% 0.25 NA

150% 0.25 NA

GAS QUANTITY An 8ev, 5 Bit/Cat

SmaItI4ty 80% 0.20 NA

toAmcunl 125% 0.31 NA

olGa,, 150% 0.38 NA

Base& 165% 0.41 NA

ModII.d 215% 0.54 NA

2012 2013 2014 2015 2010 2017

MODIFIED RANGE

Installed Coat, Addtlonal 0.00

Malntanance Coat 0.00 1.62 1.62 1.82 1.62 1.82 1.82 3.19 5.01 6.19 10.47 1365 15.93 19.11 20.93 22.30 23.21 24.57 24.57 0.00 AnnualNetiralGasCoat 0.91 7.10 7.28 7.40 7.51 7.03 7.75 7.87 8.01 8.15 8.29 8.43 8.58 8.73 8.89 9.05 9.21 9.36 9.49 0.00 AnnuslElactilclty Coat 4.90 4.94 498 5.03 5.00 5.13 5.18 5.23 5.30 5.38 5.45 5.53 5.01 5.83 5.05 5.66 5.70 5.72 5.74 0.00 TotalCoet, 0.00 11.81 13.86 14.09 14.25 14.41 14.58 14.75 16.29 18.32 21.72 24.21 27.61 30,11 33.47 35.47 37.02 38.11 39.67 39.80 0.00

BASE CASE RANGE

Malntanance Coat 0.00 1.82 1.82 1.82 1.82 1.52 1.62 3.19 5.01 8.19 10.47 13,65 15.93 19.11 20.93 22.30 23.21 24.57 24.57 0.00 AnnualNatrralGseCo.t 7.13 7.32 7.51 7.83 7.75 7.81 8.00 8.12 8.20 8.40 8.55 8.70 8.85 9,00 9.17 0.33 9.50 9.67 9.79 0.00 AnnualEleclilotty Coat 4.00 4.94 4.08 5.03 5.08 5.13 5.18 5.23 5.30 5.38 5.45 5.53 5.61 5.83 5.85 5.68 5.70 5.72 5.74 0.00 lotalCoeta 12.03 14.08 14,32 14.48 14.05 14.82 15,00 16.54 18.57 21.97 24.47 27.68 30.38 33.74 35.75 37.30 38.40 39.90 40.09 0,00

FIESULTS

Nat8asfngs,Modl5edRang. 0.00 0.22 0.22 0.23 0.23 0.24 0.24 0.24 0.25 0.25 0.28 0.26 0.27 0.27 0.27 0.28 0.26 0.20 0.29 0.30 0.00

(a) ItkrItaI coat positive, not pruelt veIn. of future sartngsflnltlalcost; II InItIal coatnegitlva, InItal aedngs/NPV of future coats. DATA SET No. A-3 (DOE-I) 00125,'94

EE-RM-90-201 COMMENT OOR13

TableA-2. No Oven Door Window, No Door Openings--Self-C\eaning Oven 

COST CALClAA TION DOLlARS ASSUMPTIONS RESULTS @ 8'JI. Dlee. FIt. 

Aft C.IcuIaHon. I .. In Conllanl I IKKl Dalla .. Fu.1 Coot 8conodo DOE. _d ...... I. ReI. Ca •• Annuolzed Nal SIV. 0.25 Styr DISCOUNT RATE AnSav. S Bll/CII Dleeounl Ral. (Ra19 8.0'lI0 eenoftVCoII(o) NA 

MODIFIED RANGE ApplllnCllJle. V.I .. lD 1n1.,1 RaI.oI RotJm NA SanallMty 2.0'lI0 0.25 NA Milk L\O !ram Manutoctur1ng Coot 2.81 Simple PaybS::k NA to DlIe'nt 7.0'lI0 0.25 NA Added InlllRed Coot •• 0.00 Nol Energy Soved 35 kStutyr Ral. 15.0'" 0.24 NA 

BASE CASE RANGE Annullzed Ga. Sav. 0.25 Styr 

Molnt .... onc. Coot. '. NPV@ 8'JI. eD.OS MoInl .... onco Coot. S. NPV@ 8'" 8D.OS FlRBTCOOT An Sav.S Bll/CII G ••• Annu.1 CooI<Ing u... 1000 IIlItyr 032 G ••• """""I Cooldng u... 1000 IIlItyr 1188 

Gal. Non-Cooldng Pilot., 1000 IIlItyr 0 GI •• Non-Cooldng Pilot •• 1000 IIlItyr 0 SENSITIVITY S",.ltMty 75'" 0.25 NA 

Gil. B •• Clean. 1000 Blutyr. 4 Cyc""' 173 GI •• S •• Clean. 1000 Blutyr. 4 Cyc,,", 173 10Fl,., 85'" 0.25 NA 

Gal, Total u.., l000Blutyr 1.104 GI •• Total u... 1000 Blutyr 1.13D GAS COOT AnSav. S Bll/CII Cool 120'lI0 0.25 NA 

150'lI0 0.25 NA 

EIoctIlcl1y,ImuII Cooldng u... _tyr 211.2 EIoctIlcl1y.lmual Cooldng u... _tyr 211.2 SanalUYity 80'lIo 0.20 NA 

Eloctdctty. Clock, kWhtyr 31.5 EIoctIlcl1y. Clock, kWhtyr 31.5 loG •• 120'lI0 0.30 NA GAS QUANTITY AnSav •• BftICII 

EIoctIlcl1y, B •• Clean. kWhtyr. 4 Cycle. 0.7 EIoctIlcl1y. BoW Clean. kWhtyr. 4 Cyc,,", 0.7 Cool 

EIoctIlcl1y. Total. kWhtyr 81.5 EIoctIlcl1y, Tot.~ kWhtyr 81.5 BanlHlYlty 80'lIo 0.20 NA APPUANCE UFE AnSIV.S Blt/CII 10A/11ounl 125'" 0.31 NA 

Energy. Imu II Cooldng u.., 1000 BluJ\ 1,031 Enervv,lmuilCooklng u...l000Blutyr 1.088 olGa •• 150'lI0 0.38 NA 

CookIng Eftlcloncy 7.37'" Cooldng EftIcIoncy 7.13'" B .... 1HIYIty -2 0.25 NA ea •• & 185'" 0.41 NA 

Enervv. Totallmull u... 1O!D Blutyl 1.314 Enervv. Total Annual u... 1O!D Blutyr 1.34D 10 V ... lJIe 2 0.25 NA ModIfted 215'" 0.54 NA 

Enorvv Foetor 5.711% Enervv Foetor 5.84'" Chang. 

Vaar 1997 I_ I_ 2000 2001 2002 2003 2004 2005 200!1 2007 200!1 200II 2010 2011 2012 2013 2014 2015 2018 2017 > I 

~ 

MODIFIED RANGE 

InIl.Red Coot. Ad_al 0.00 

M.tnt.,onco Coot 0.00 1.82 1.82 1.82 1.82 1.82 1.82 3.1D 5.01 8.1D 10.47 13.85 15.D3 lD.ll 2O.D3 22.30 23.21 24.57 24.57 0.00 

""",,"I NIIl.Jral Ga. Coot 8.Dl 7.10 7.28 7.40 7.51 7.83 7.75 7.87 8.01 8.15 8.211 8.43 8.58 8.73 8.8D D.OS D.21 D.38 D.4D 0.00 

""",,"I EIoctIlcl1y Coot 4.110 4.114 4.18 6.03 5.08 5.13 5.18 5.23 5.30 5.38 5.45 5.53 5.81 5.83 5.85 5.88 5.70 5.72 5.74 0.00 

TotIICooI. 0.00 11.81 13.88 14.oe 14.25 14.41 14.58 14.75 18.211 18.32 21.72 24.21 27.81 30.11 33.47 35.47 37.02 38.11 3D.87 39.80 0.00 

BASE CASE RANGE 

M.tnt.,onco Coot 0.00 1.82 1.82 1.82 1.82 1.82 1.82 3.1D 5.01 8.1D 10.47 13.85 15.D3 lD.ll 2O.D3 22.30 23.21 24.57 24.57 0.00 

""",,"I NIlIral Ga. Coot 7.13 7.32 7.51 7.83 7.75 7.87 8.00 8.12 8.28 8.40 8.55 8.70 8.85 D.OO D.17 D.33 D.SO D.87 D.7D 0.00 

""",,"I EIoctIlcl1y Coot 4.110 4.114 4.18 5.03 5.08 5.13 5.18 5.23 5.30 5.38 5.45 5,53 5.81 5.83 5.85 5.88 5.70 5.72 5.74 0.00 

TotllCooII 12.03 14.08 14.32 14.48 14.85 14.82 15.00 18.54 18.57 21.D7 24.47 27.88 30.38 33.74 35.75 37.30 38.40 3D.18 40.oe 0.00 

REBULTB 

Nal Blvlng •• _ed Rangl 0.00 0.22 0.22 0.23 0.23 0.24 0.24 0.24 0.25 0.25 0.28 0.211 0.27 0.27 0.27 0.28 0.28 0.211 0.211 0.30 0.00 

(I) 1I1nI."lcOll pOli1lve,nal pNl8n1 va". 0I1utu .. aa.mgo,1nltlllcool;H lnIUalcoolnagllllve.InI'"1 oavIngl/NPV 01 Iutu .. COlli. DATASET No.A-3(DOE-l) 08/21V94 
Table A-3. No Oven Door Window, 4 Door Openings- -Standard Oven

COST CALCLLATION DOUARS ASSUMPTIONS FE8UIT8 @8% DIsc. RI.

N Calculations ar.In Constant 1990 Dollars Fuel Cost Scen01o DOE, Residonlal, Ret. Case Annualzed Net 8ev. 0.24 S/yr DISCOUNT RATE An 8ev, $ Bit/Cat

Discount Rate (Real) 80% Ben.Ilt/Cosl(a) NA

MODIFIEDRANGE AppIancsLllS,Yaars to InlrnlRaI.of Return NA SonslItuty

'

2.0% 0.25 NA

MerIcL,fromMonutsctuPin9COlt 2.81 SImplePaybk NA toDlsc nt 7.0% 0.24 NA

MdsdlnstaIledCosl S 000 NetEnergyBaved 34kBtu/yr Rate 15.0% 0.23 NA,

BASE CASE RANGE Annusized Gas Say. 0.24 S/yr

Mslntmence Cost, 8, NPV @ 0% 0.00 Malntaance Cost, 8, NPV @6% 0.00 FIRST COST An 8ev, S Bit/Cat

Gas, Annual Cooldng Use, 1000 Bti/yr

PIl t 1000 ELi r

1,250

1 508

Gas, Annual Cooldng Use, 1000 ELi/yr

Gas Non-Cooldng Pilots 1000 ELi/yr

1,284

1,508 SENSITIVITY Smsttlvfty 75% 0.24 NA

Ga., Non-Cooldng o s, /y

O.s S5SCI.an l000BIU/yr OCyCISS

,

0

, ,

Gss,S&tCl..n,l000BtU/yr.OCYCISS 0

. laFlrsi 85% 0.24 NA

, , .

G.s,Total Use, l000Btu/yr 2,759 GasTotal Us, l000Btutyr 2,792 GAS COST An Say, S Bit/Cat Coat 120%

150%

0.24

0.24

NA

NA

SansItF4ty 80% 0.19 NA

to Gas 120% 0.29 NA GAS QUANTITY An 8ev, S Bit/Cal

Coat

BonsltMty 80% 0.19 NA

APPUPNCE UI'S An Say, S ElI/Cal toAniount 125% 0.30 NA

Energy, Annual Cooldng Use, 1000Btu 1,250 Energy, Annual Cocldng LIsa, 1000 ELi/yr 1,284

ItM 2 0 24 NA

ot Gas,

Bas.&

150%

165%

0.35

0 40

NA

NA

Cooldng Ethldsncy

Energy, Total Annual Us., 1000 ELi/yr

6.08%

2,759

Ccoldng EllIdincy

Energy, Total Annual Use, 1000 ELi/yr

5.92%

2,792

S,i, ty -

to Yrs. UI. 2

.

0.24 NA ModIH.d 215%

.

0.52 NA

Energy Fsctof 2.76% Energy Ftoc 2.72% Change

Year 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

MODIFIED RANGE

Installed Cost, Aduttlonal 0.00

0 00 0 00 0 00 0 00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Malnturance Cost .

17 27

.

17 73

.

18 20

.

16 48 18.77 19.00 19.36 19.67 20.01 20.35 20.70 21,06 21.42 2181 22.20 22.60 23.01 23.42 23.70 0.00

Mnu.lNatlralGsiColt .

0 00

.

0 00

.

0 00

.

0 00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Annual Electilcity Cost .

0 00 17 27

.

17 73

.

18 20

.

18.48 18.17 1Q06 19.36 19.87 20.01 20.35 20.70 21.06 21.42 21.81 22.20 22.60 23.01 23.42 23.70 0.00

TotalCost. . . . .

BASE CASE RANGE

0 00 0 00 0 00 0 00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Milntsnsnce Cost .

11 48

.

17 94

.

18 42

.

18 71 19.00 19.30 1060 19.91 20.25 20.60 20.95 21.32 21.68 22.07 22.47 22.88 23.29 23.71 23.99 0.00

AnnualNatiralGasCost .

0 00

.

0 00

.

0 00

.

0 00 0 00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Annual Electilcity Cost .

17 48

.

17 94

.

15 42

.

18 71

.

19 00 10.30 19.00 19.91 20.25 20.60 20.95 21.32 21.58 22.07 22.47 22.88 23.29 23.71 23.99 0,00

TotalCosts . . . . .

IESILTS

Net 8a*igs, Modified Rang. 0.00 0.21 0.22 0.22 0.23 0.23 0.23 0.24 0.24 0.24 0.25 0.25 0.26 0.26 0.27 0.27 0.28 0.28 0.29 0.29 0,00

tlt

a) H Inlial cost positive, net pruant vatue 01 future aasingsflnltlalcost; It InItial costnegsllve, InItial satngs/NPV of future costs. - DATA SET No. A-2 (DOE-i) 06/28(94

EE-RM-90-201 COMMENT OOR13

Table A-3. No Oven Door Window, 4 Door Openings- -Standard Oven 

COST CALCUlATION DOLlARS ASSUMPTIONS RESUlTS @8%Dloc. RI. 

.... C.lculation .... In Contl.." 1090 Oolla .. Fuol ColI 8con.~o DOE, ReDld..,'al, ReI. Ca._ Annualzed Nol Sa •. 0.24 Styr DISCOUNT RATE An So., S Bft/Ctl Dlocounl ReI. (Rel~ O.!l'I. eenoftVCo.'( a) NA 

MODIFIED RANGE Applonce UIII, V .... 18 Inlml ReI. of Re"m NA S.,1I1M1y 2.!l'I. 0.25 NA 

Mark Up !ram Monulacturing ColI 2.81 Simple PoybllCk NA 10 Dloc'nl 7.!l'I. 0.24 NA 

Added Intlilled Cotl, S 0.00 Nol Enorgy Saved 34 kBlutyr Ral. 15.!l'I. 0.23 NA 

BASE CASE RANaE Annualzed G •• SlY. 0.24 Styr 

MoInl.,onc_ ColI, S, NPV @ 8% 0.00 MoInl.,onc. ColI, S, NPV @ 8% 0.00 ARSTCOST An Sov, S Bft/Ctl G •• , Annual CookIng Un, 1000 Blltyr 1,250 a •• , Annual Cooking Un, 1000 Blltyr 1,284 

ao., Non-Cooking Pilot., 1000 Blltyr 1,!508 a •• , Non-CookIng Pilot., 1000 Blltyr 1,!508 SENSITIVITY s..,oItIvIty 75% 0.24 NA 

aa., SorClean, 1000 Btutyr, 0 Cyclol 0 Ga., s.n Clean, 1000 Blutyr, 0 Cyclol 0 loAm 85% 0.24 NA 

Ga., Total Un, 1000 Btutyr 2,750 al., Tolal Un, l000Btutyr 2,7112 aASCOST AnSa., S Bft/Ctl ColI 12!l'1o 0.24 NA 

15!l'1o 0.24 NA S.,IIti>1ty I!O'!Io 0.18 NA 

toG •• 12!l'1o 0.28 NA aAS QUANTITY An Sa., S Bft/Ctl ColI 

S..,oItIvIty I!O'!Io 0.18 NA APPUANCE UFE An So., S Bft/Ctl 10Amounl 125% 0.30 NA 

En_IVY, Innu al Cooking Un, 1000 Btufl 1,250 EnolVY, Innull CookIng uaa, 1000 Blutyr 1,284 of G •• , 15!l'1o 0.38 NA 

Cooking Efilcloncy 8.08% Cooking Efilcloncy 5._ Sa1ll11v1ty -2 0.24 NA ea ••• 185% 0.40 NA 

EneIVY, Tolallnnual uaa, 1000 Btutyr 2,758 En.IVY, ToI.llnnual uaa, 1000 Btutyr 2,7112 10 V ... UIII 2 0.24 NA Modiftod 215% 0.52 NA 

Ener;yFICIOf 2.78% EneIVYFICtOf 2.72% Chong. 

Va.r 1l1li7 I_ I_ 2000 2001 2002 2003 2004 2005 2008 2007 2008 2009 2010 2011 2012 2013 2014 2015 2018 2017 > I 

VI 

MODIFIED RANGE 

Intlilled ColI, AddIIonal 0.00 

MoInI.,once ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annuli Na",.1 a •• ColI 17.27 17.73 18.20 18.48 18.n 18.08 18.38 18.87 20.01 20.35 20.70 21.08 21.42 21.81 22.20 22.80 23.01 23.42 23.70 0.00 

Annual Eloctilclty ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

ToIalCooII 0.00 17.27 17.73 18.20 18.48 18.n 18.08 18.38 18.87 20.01 20.35 20.70 21.08 21.42 2Ul 22.20 22.80 23.01 23.42 23.70 0.00 

BASE CASE RANGE 

MoInI..once ColI 0.00 0.00 0.00 0.00 0.00 O.QO 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annuli No" .. 1 aa. ColI 17.48 17.94 18.42 18.71 18.00 18.30 18.80 18.81 20.25 20.80 20.85 21.32 21.88 22.07 22.47 22.88 23.28 23.71 23.l1li 0.00 

Annual Eloctilclty ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

ToIalCoiIl 17.48 17.94 18,42 lUI 1'.00 18.30 18.80 18.111 20.25 20.80 20.85 21.32 21.88 22.07 22.47 22.88 23.28 23.71 23l1li 0.00 

RESUlTS 

Nat Saq., -.cI Range 0.00 0.21 0.22 0.22 0.23 0.23 0.23 0.24 0.24 0.24 0.25 0.25 0.28 0.28 0.27 0.27 0.28 0.28 0.28 0.28 0.00 

(0) "InItol coli pooltiY8, n at preoll1l .0"_ of MIl .. lOw.go,1nltlal cool; " initial cool n og_,lnIt.1 IIVIngl/NPV of MIl .. cool •. DATASET No.A-2(DOE-l) OO/21V\14 
Table A-4. No Oven Door Window, 4 Door Openings- -Self-Cleaning Oven

COST CALCULATION DOLLARS ASSUMPTIONS

At Calculations arsin Constant 1990 Doter. FuelCost8cenedo DOE, Realdankl, Ref. Case

DIscount Rate (Reel)

MODIFED RANGE Applanc. Ut., Veer,

Merit Ll) froni Maiulsctudng Coat

Added Installed Cost, $ 0.00

BASE CASE RANGE

Malnianance Coat, S. NPV@ 8% 89.05 Malntanance Coat, S. NPV@ 6%

Ga., Annual Cootdng Use, 1000 BUtyr 069 Ga., Annu.tCootdng U.., 1000 BUtyr

FESULTS @0% DIsc. RI.

Annuslzed Net 8ev. -0.02 $fyr

6.0% Bendt/Co.t(a) NA

19 mImI Rat. at Ratim NA

2.81 SImple Peybsck NA

Net Enargy Saved -3 kBtu/yr

Annuetzed GasSes. -0.02 S/yr

80.05

966

DISCOUNT RATE An Say, $ BR/Cit

Ct.., Non-Coolring PIlota, 1000 itsirr U GI, Non-Coolting PIlots, 1000 Btifyr 0 SENSITIVITY

Gas, 8.11 Clean, 1000 Btu/yr, 4 Cycle. 173 0.., 8.8 Clean, 1000 Btu/yr, 4 Cycle. 173

Ga.,TotslUs.,l000Btu/yr 1,142 Gsa,TotatUa.,I000B*u/yr 1,130 GASCOST AnSav,$ BR/Cat

Electricity, Annual Cooldng Use, kWr/yr 29.2 ElectrIcity, Annual Cooking U,., loMi/yr 20.2 SarsilMty 80% -0,02 NA

ElectrIcity, Clock, I@h/yr 31.5 Electricity, Clock, lThArr 31.5 to Gas 120% -0.02 NA

Electricity, Sell Clean, I/yr, 4 Cycles 0.7 ElectrIcity, Salt Clean, kWhlyr, 4 Cycle. 0.7 Cost

Electricity, Total, kWh/yr 81.5 ElectrIcity, Total, kWh/yr 61.5

APPUANCE UFE An Say, $ BR/Cat

Enargy, Annual Cooldng Us., 1000Btu 1,069 Energy, AnnuelCooldng Use, l0008tu/yr 1,066

Cooking Eltlclancy 1.11% Cooldng EIfld.ncy 7.13% Seislllvtty -2 -0.02 NA

Energy, Total Annual Use, 1000 Otu/yr 1,351 Enargy, Total Annual (i.e 1000 Btu4mr 1,349 to Yr.. Ui. 2 -0.02 NA

Energy Foctor 5.63% Energy Feclor 5.04% Change

Year 1907 1908 1900 2000 2001 2002 2003 2004 2005 2006 2007 2008 2000 2010 2Ott

Sansltlvlty 2.0% -0.02 NA

to Dloc'nt 7.0% -0.02 NA

Rat, 15.0% -0.02 NA

FIRST COST An 8ev, $ BR/Cat

SmsltMty 75% -0.02 NA

to FIrst 85% -0.02 NA

Cost 120% -0.02 NA

150% -0.02 NA

GAS QUANTITY An 5ev, $ BR/Cat

SonsltMty 80% -0.02 • NA

toMiount 125% -0.02 NA

01 Ga., 150% -0.03 NA

Bes.8, t65% -0.03 NA

ModIfIed 215% -0.04 NA

2012 2013 2014 2015 2016 20t7

C'

MODIFIED RANGE

Instated Cost, Addtlanal 0.00

Malnt.,anc. Cost 0.00 1.82 1.62 1.62 1.82 1.82 1.82 3.10 5.01 6.10 10.47 13.85 15.03 tOll 20.03 22.30 23.21 24,57 24.57 0.00

Annual Nat.rrat 0.. Cost 7.15 7.34 7.53 7.85 7.77 7.89 8.01 8.14 8.28 8.42 8.57 8.72 8.87 9.03 9.19 9.35 0.52 0.80 0.81 0.00

AnnualElactdcltyCost 4.90 4.94 4.98 5.03 5.08 5.13 5.16 5.23 5.30 5.38 5.45 5.53 5.61 5.63 5.65 5.88 5.70 5.72 5.74 0.00

TotelCo.ts 0.00 12.05 14.10 14.33 14.50 14.67 14,84 15.01 18.58 18.59 21.90 24.40 27.90 30.40 33.77 35.77 37.32 38.42 39.98 40.12 0.00

BASE CASE RANGE

MalnlanceCo.t 0.00 1.82 1.62 1.82 1.82 1.82 1.82 3.tO 5.01 8.19 10.47 13.65 15.03 10.11 20.03 22.30 23.21 24.57 24.57 0.00

MnualN.trralG.sCost 7.13 7.32 7.51 7.63 7.75 7.87 8.00 8.t2 8.28 8.40 8.55 8.70 8.65 9.00 9.17 0.33 0.50 o:ei 9.70 0.00

AnnuelElectllclty Cost 4.90 4.94 4.98 5.03 5.08 5.13 5.t8 5.23 5.30 5.38 5.45 5.53 5.6t 5.63 5.65 5.88 5.70 5.72 5.74 0.00

TotalCoats 12.03 14.08 14.32 14.48 14.85 14.82 15.00 18.54 18.57 21.07 24.47 27.85 30.38 33.74 35.75 31.30 35.40 39.96 40.00 0.00

lESl.LTS

NetSa4ngs,ModIt.dRang. 0.00 -0,02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 '0.02 '-0,02 -0.02 0.02 '-0,02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 0.00

(a) tilnllal cost posItive, net presert vakre of future aa'.lng./Inltl.lcoat; It Initial co.tnegMlve, lnlllal e.vlngafNPV ot luturecosta. DATASET No. A-4 (DOE-I) 00(28/04

EE-RM-90-201 COMMENT OOR13

TableA-4. No Oven Door Window, 4 Door Openings- -Self-Cleaning Oven 

COST CALCUlATION DOUARS ASSUMPTIONS RESUlTS @5%llIoe. Rt 

An ColcuIoUon .... In Conltonl 1990 DoRa ... Fuel Coat Scen.~o DOE. Raold.,tal. Rat. Ca.o Annualzed Net Sa •. -0.02 Styr DISCOUNT RATE AnSa •• S Bll/Cit Dlocount Ral. (Raa~ 8.0% Bene1lt/Colt( a) NA 

MODIFIED RANGE Applance llIIt. Y ..... 18 Int.,1 Rat. 01 Ra\Jm NA SenaltMty 2.0% -0.02 NA Mark Up from ManutlClurlng Coat 2.81 Simple PoyblCk NA 10 llIoc'nt 7.0'" -0.02 NA 

Added Inlta_ Coat. S 0.00 Net Energy Saved -3 kBtutyr Rate 15.0% -0.02 NA 

BASE CASE RANGE Annualzed Gal Sav. -0.02 Styr 

Maintenance Coat. S. NPV@ 8'" 88.05 Malnlenonce Coat. S. NPV@ 8'" 89.05 FIRST COST An So •• S Bll/Cit ao •• AnnUlI Cooldng u.... 1000 BlJtyr 1188 a ••• Annu.ICooIOng u.... l000BlJtyr IMI8 

Ga •• Non-Cooking PII," •• 1000 BlJtyr 0 G ••• Non-CooIOng PlkII •• 1000 BlJtyr 0 SENSITIVITY Son "ItMty 75'" -0.02 NA 

Ga •• SI. Clton. 1000 Blutyr. 4 Cyc:1oo 173 a ••• S •• Clton. 1000 Blutyr. 4 Cyc:1oo 173 10Rm 85'" -0.02 NA 

a ••• ToIII u.e. l000Btutyr 1.142 al •• ToIII u.... 1000 Blutyr 1.139 GAS COST AnS ••• S Bll/Cit Coat 120% -0.02 NA 

150% -0.02 NA 

EIoctIk:lty.lnnual Cooldng u.... _tyr 29.2 EIoctIk:lty.lnnual Cooldng u.... _tyr 29.2 SonolUvIty 80% -0.02 NA 

Eloctoldty. Clock, Wihtyr 31.5 E Ioctoldty. Clock, Wihtyr 31.5 10 Ga. 120'" -0.02 NA GAS QUANTITY An So •• S Bll/Cit 

EIoctIk:lty. SI. Clton. kWh/yr. 4 Cyc:1oo 0.7 EIoctIk:lty. S •• Clton. kWh/yr. 4 Cyc:1oo 0.7 Coat 

EIoctIk:lty. Totll. Wihtyr 81.5 EIoctIk:lty. Totll. kWhtyr n5 SonoltMty 80% -0.02 • NA APPUANCE UFE An So •• S Bll/Cit to Amount 125'" -0.02 NA 

Enlrgy.Innu.1 Cooldng u.... 1000 Bluh 1.088 Enlrgy. 1nnu.1 Cooldng u.... 1000 Blutyr 1.088 of Gal. 150% -0.03 NA 

Cooking Elllclenc:y 7.1'''' Cooldng Elllclenc:y 7.13'" SonolUvlty -2 -0.02 NA BUIa. 185'" -0.03 NA 

Energy. ToI.l ....... u.1 u.e. 1000 Blutyr 1.351 Enlrgy. Tot.11nnu 01 u.... 1000 Blutyr 1.348 to Yra. llIIt 2 -0.02 NA Modlned 215'" -0.04 NA 

Enlrgy Foctor 5.83'" Energy Foctor 5.84'" Chan8" 

Y •• r 1887 1888 ,- 2000 2001 2002 2003 2004 2005 2008 2007 2008 2009 2010 2011 2012 2013 2014 2015 2018 2017 » 

I 

0'1 

MODIFIED RANGE 

Inltallod Coat. AddtIonol 0.00 

Malnt.,ancl Coat 0.00 1.82 1.82 1.82 1.82 1.82 1.82 3.10 5.01 8.18 10.47 13.85 15.83 10.11 20.03 22.30 23.21 24.57 24.57 0.00 

Annuol NI"rll Ga. Coat 7.15 7.34 7.53 7.85 7.71 7.88 8.01 8.14 8.28 8.42 8.57 8.72 U7 0.03 0.10 9.35 0.52 0.80 0.81 0.00 

AnnulI EIoctIk:lty Coat 4.00 4.04 4.08 5.03 5.08 5.13 5.18 5.23 5.30 5.38 5,45 5.53 5.81 5.83 5.85 5.l1li 5.70 5.72 5.74 0.00 

Total Coo II 0.00 12.05 14.10 14,33 14.50 14.117 14.84 15.01 lUll 18.58 21.88 24,40 27.00 30.40 33.71 35.77 37.32 38.42 30.08 40.12 0.00 

BASE CASE RANGE 

Malntenancl Coat 0.00 1.82 1.82 1.82 1.82 1.82 1.82 3.10 5.01 8.10 10.47 13.85 15.03 10.11 20.03 22.30 23.21 24.57 24.57 0.00 

Annu.1 NalJr.1 G •• Colt 7.13 7.32 7.51 7.83 7.75 7.87 8.00 11.12 11.211 11.40 8.55 11.70 U5 0.00 8.17 0.33 0.50 0:87 0.70 0.00 

Annu.1 EIoctIk:lty Coat 4.00 4.04 4.08 5.03 5.08 5.13 5.111 5.23 5.30 5.38 5.45 5.53 5.81 5.83 5.85 5.l1li 5.70 5.72 5.74 0.00 

TotalCooIi 12.03 14.08 14.32 14,48 14.85 14.82 15.00 111.54 111.57 2U7 24,47 27.l1li 30.38 33.74 35.75 37.30 38.40 39.011 40.00 0.00 

RESUlTS 

Net Saving •• ModHIed Rango 0.00 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 0.00 

(a) nlnllalcoat pOlltlve. net p ... .,t .0". 0I1utu ... aYlngll1nltlolcool; N lnItIolcootneg_.lnllaIIlYlngojNPV oIluturoco.t •. DATASET No.A-4(DOE-l) O8/2tVM 
Table A-5. Standing Pilots Replaced with Electronic Ignition, Existing Outlet- -Cooktop

-

COST CALCULATION DOLLARS ASSUMPTIONS RSSULTS @8% DIsc. RI.

AM Calouletlons rshi Constant 1990 Dollars FLisi Cost Bccnaulo DOE, Realdanlel, Ref. Cu. Annusfeed Net 8ev. 5.14 S/yr DISCOUNT RATE An 8ev $ BS/Cst

DIscount Rate (Re9 6.0% Ben.fttlCost(e) 4.13

MODIFED RANGE Applenc. life, Years 10 rtml Rat. of Rebm 65.7% SmsItI4ty 2.0% 4.19 4.58

Marftl.fromManufsctudngCost 2.81 SlmplePaybsck 2.Syeecs toDlscnl 7.0% 5.33 4.01

AddhnteTledCos1,$ 16.34 NatEnergySeved 2,O5OkStu/yr Rate 15.0% 0.21 3.10

BASE CASE RANGE Annuslz.d Gas 8ev. 14.76 S/yr

Ustnterance Cost, $, NPV@ 6% 89.05 Malntanance CostS, NPV@ 6% 0.00 FiRST COST An 5ev, $ Ott/Cat

Gas, AnnustCooldng lies, 1000Gb/yr 1,092 Gas, Mnuil Cooldng Us., 100005,/yr . 1,092

Gas, Non-Cooldng PIlots, 1000 Bb/yr 0 Gsa, Ncn-Cooldng PIlots, 1000 OSi/yr 2,050 SENSITIVITY SmsIIMty 15% 5.55 5.50

to First 05% 5.39 4.88

Gas,Tot.t Us., l0006tu/yr 1,092 Gss,Totel Us., l000Blu/yr 3,142 GAS COST An 8ev, S BIt/Cat Coal 120% 4,61 3.44

150% 4.32 2.75

SansIIfvlty 80% 2,19 2.33

to Gas 120% 8.09 5.92 GAS QUANTITY An 8ev, 5 OIl/Cat

Cost

Sai sliMly 60% 2.19 2.33

APPUANCE liFE An 8ev, $ Bit/Cat to Anmunl 125% 8.63 0.37

Energy, MnuatCooldng Use, 1000Btu/ 1,092 Energy, PnnuelCooldng Use, l000Blu/yr 1,092 of Gas, 150% 12.52 8.02

Cooldng Eltlclsncy 39.90% Cootdng EtMclsncy 39.90% 8&i sliMly -2 5.93 4.39 Base & 105% 14.74 9.97

Energy, Total Annual Use, 1000 Btu/yr 1,092 Energy. Total Annual Use, 1000 alu/yr 3,142 tovra. LII. 2 4.53 3.91 Modltled 215% 22.12 14,46

Energy Fsctor 39.90% Energy Fsctor 13.86% Change

Year 1997 1996 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2018 2017

MODIFIED RANGE

Installed Cost, Addttonal 18,34

MatntananceCost 0.00 1.82 1.62 1.82 1.82 1.82 1.82 3.19 5.01 8.19 10,47 13.65 15.93 10.11 20.93 22.30 23.21 24.57 24.57 0.00

AnnuelNebratGssCost 683 7.01 7.20 1.31 7.43 1.54 1.06 7.78 7.92 8.05 8.19 633 8.48 8.03 8.78 6.94 9.10 9.27 9.38 0.00

Annual EI.ct4cIty Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TotelCosts 18,34 8.83 8.83 9.02 9.13 9.25 9.36 9.48 tOO? 12.92 16.24 18.66 21.98 24.40 27.74 29.71 31.24 32.31 33.84 33.95 0.00

BASE CASE RANGE

U*tterance Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

AnnualNabralGasCoal 19.61 20.19 20.72 21.05 21.38 21.71 22.05 22.40 22.78 23.18 23.58 23.98 24.40 24.84 25.28 25.74 26.20 26.87 26.99 0.00

Annual Elact$dty Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TotelCoita 10.87 20.19 20.72 21.05 21.38 21.71 22.05 22.40 22.78 23.16 23.58 23.98 24.40 24.84 25.28 25.74 26.20 26.87 26.99 0.00

FESULTS

Net8avlngs,ModlltedRangs -18.34 12.83 11.35 11.70 11.91 12.13 12.35 12.57 11.43 9.86 6.93 4.92 2.00 -0.01 -2.90 -4.43 -5,50 -6,11 -7.17 -6.96 0.00

(a) If Inlialcost positive net prssant vakie at tuture aavlngsflnhltalco.t; If lnltlalco.tnegattve, hillel sailngs/NPV of futurscosts. DATA SET No. 0-10 (DOE-2) 06/26194

EE-RM-90-201 COMMENT OOR13

TableA-5. Standing Pilots Replaced with Electronic Ignition, Existing Outlet--Cooktop 

COST CALCUlATION OOUARS ASSUMPTIONS ~SUlTS @ 8% OIoc. RI. 

Al! CIIt:llIIIUon .... In Conat.." I IHIO DoIIII .. Fuel ColI ScenI~O DOE. _d ..... I. ReI. C ... Annu .... d NOI Sov. 5.14 Styr DISCOUNT RA.TE MSOV.S Bft/Cat OI0c0unI RIle lReaQ 8.11"4 Blnellt/COlll·) 4.13 

MOOIFlED RA.NGE Appl"""" UIe. Y.I .. 10 Inlml Ral. 01 Rellm 85.7'" S .. ,.ltMIy 2.11"4 4.10 4.58 

Mark Up !rom MonuIlICIurtng ColI 2.81 Simple Paybs:k 2.S y .... 10 OIoc'nl 7.11"4 5.33 4.01 

Addad Inatilled ColI. S 18.34 NOI En.rgy S.VId 2.050 kBlutyr Ral. 1S.11"4 8.21 3.10 

BASE CASE RA.NGE AnnualZad G .. SI •. 14.78 $ty, 

Malntananc. ColI. $. NPV@ 8'" 80.05 Malnlan"""" ColI. S. NPV@ 8% 0.00 RRSTCOST MSa •• S Bft/Cat GI •• Annuli CooIIIn9 UII. 1000 BlIty' 1.002 Ga •• Annu.1 CooIIIn9 UII. 1000 BlItyr 1.002 

GI •• Non-Cooking Pilot •• 1000 BlIty, 0 GI •• Non-CooIIIn9 Pilot •• 1000 BlIty, 2.050 SENSITMTY Smo/Uvily 75'" 5.55 S.5O 

loAm 85'" 5.30 4.1111 

Ga •• ToIIl UII. l000Bluty, 1.002 Go •• Total UII. l000Blutyr 3.142 GAS COST MSIV.S Bft/Cat Coat 120% 4.81 3.44 

150% 4.32 2.75 

S..,oIUvlly 110'" 2.10 2.33 

toG •• 120% 8.09 5.112 GAS QUANTITY MSav.S Bft/Cat CoOl 

S..,oiUvily 8D"4 2.18 2.33 

APPUANCE UFE MSI'.S Bft/Cat 10 Amounl 125'" 8.83 8.37 

Ener;y. Innu II Cooking Use. 1000 BIu/l 1.092 Eoor;y. Innu al Cooking UII. 1000 Blutyr 1,002 01 G ••• 150% 12.52 8.82 

CooIdng Elllcloncy 38.90'" Cooking EIIIcIoncy 38._ SanolUvily -2 5.83 4.38 B ... & 18S'" 14.74 8.87 

Eoor;y. Totlllnnu.1 UII, 1000 Bluty' 1.002 Eoor;y. ToIallnnull UII. 1000 Bluty' 3,142 loY ... UIe 2 4.53 3.01 Modillad 21S'" 22.12 14.48 

Enlr;y Foetor 38._ Eno<gy Foetor 13.811'" Chang. 

Y .. , 1007 I- I- 2000 2001 2002 2003 2004 2005 200Il 2007 2008 2009 2010 2011 2012 2013 2014 2015 2018 2017 > I 

....J 

MOOIFlED RA.NGE Inatilled ColI, AcIcIIlonal 18.34 

Malnl ... ...,. ColI 0.00 1.82 U2 1.112 1.112 1.82 1.112 3.18 S.01 8.18 10.47 13.85 15.83 18.11 20.83 22.30 23.21 24.S7 24.57 0.00 

Annuli NIlI'" Ga. ColI 8.83 7.01 7.20 7.31 7.43 7.54 7.811 7.78 7.112 8.05 8.18 8.33 8.48 8.83 8.78 8.84 8.10 8.27 8.38 0.00 

Annual ElocIoIcIIy ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

TotalCoab 18.34 8.83 8.83 8.02 8.13 8.25 8.311 8.48 10.87 12.112 18.24 18.811 21.88 24.40 27.74 28.71 31.24 32.31 33.84 33.85 0.00 

BASE CASE RA.NGE 

Malntananca ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annuli NIlIr.1 GI. ColI 18.87 20.18 20.72 21.05 21.311 21.71 22.05 22.40 22.78 23.18 23.58 23.88 24.40 24.84 25.28 25.74 28.20 28.87 28.00 0.00 

Annuli ElocIoIcIIy ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

TotilCoab 18.87 20.18 20.72 21.05 21.311 21.71 22.05 22.40 22.78 23.18 23.58 23.88 24.40 24.84 25.28 25.74 28.20 28.87 28.00 0.00 

~BUlTB 

NOI SavIngt, ModHIad Ranga -18.34 12.83 11.35 11.70 lUI 12.13 12.3S 12.S7 11.43 8.811 8.83 4.112 2.00 -0.01 -2.80 -4.43 -S.5O -8.11 -7.17 -8.88 0.00 

la) MlnllllcoOI poo/UW, nOlpl8IBn1 .a"" 01 lulu ... lvlngl/lnlllalcool;H lnIIIalcooln"llIlllve.InI'alllvingI/NPV oIlu1u .. cOOb. DATA SET No. B-l0 lDOE-2) 0II!21!/94 
Table A-6. Standing Pilots Replaced with Electronic Ignition, 1/2 New Outlet Cost- -Cooktop

COST CALCULATION DOLLARS ASSUMPTIONS FESULTS @6% DIsc RI.

AS C ulallon, areln Conslant 1990 Dollars Fuel Cost 8cenao DOE, R.aldIaI, Rat. Case Annuafzed Net 8ev. 1.11 S/yr

DIscount Rate (R.a 6.0% Benett/Cost(C) 119

MODIFIED RANGE Applanc. Ut., Year. 19 Intinl Retool Return 11.7%

Mark L from Manufscturlng Cost 2.81 SImple Paybsck 6.3 year.

Added Installed COst, $ 63.33 Not Energy Saved 2,050 kBIu/yr

BASE CASE RANGE Annualzed Gas Say. 14.76 S/yr

MaIntenance Coal, S. NPV@ 6% 89.05 MaIntenance Coat, S. NPV@ 6% 0.00

Gas, MnualCooldng Ui., 1000 BtJ/yr 1,092 Gas, Annual Ccotdng Use, 10008W/yr 1,092

Gas, Non-Cooldng PIlots, 1000 BU/yr 0 Gas, Non-Cooldng PIlots, 1000 8W/yr 2,050 SENSITMTY

Gas, Total Us., 1000 Blu/yr 1,092 0.,, Total Use, 1000 8W/yr 3,142 GAS COST An Say, $ Bit/Cat

Senaltldly 80% -1.85 0.67

to Gas 120% 4.08 1.72

Cost

APPUANCE UFE An 8ev, S Bit/Cat

Energy, Annuat Cooldng Us., 1000 Blu 1,092 Energy, Annual Cooldng Use, 1000 8W/yr 1,092

Cooking Ef9dency 39.90% Cooldng Efdeocy 39.90% SeisltI1ty -2 1.64 1.27

Energy,TotalknustUs.,lO00Btu/yr 1,092 Energy,TotalMnualus.,lO00Btu/yr 3,142 toYrs.Ule 2 0.71 1.13

Energy Fsctor 39.90% Energy Fsctor 13.86% Changs

Year 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

DISCOUNT RATE An 8ev, S Bit/Cat

SalsltMty 2.0% 1.32 1.33

toDlac'nl 7.0% 0.98 1.18

Rate 15.0% -1.05 0.90

FIRST COST An Say, S Bit/Cat

SanittMty 75% 2.53 1.59

toRrsl 65% 1.96 1.41

Cost 120% -0.03 1.00

150% -1.73 0.80

GAS QUANTITY An Say, S Bit/Cat

SensItIvity 60% -1.85 0.67

toAinount 125% 4.80 1.85

of Gas, 150% 8.49 2.50

Ease& 165% 10.70 2.89

ModItled 215% 18.08 4.19

2012 2013 2014 2015 2016 2017

00

MODIFIED RANGE

Installed Cost, AddItional 63.33

MalntenancsCost 0.00 1.82 1.82 1.82 1.82 1.82 1.82 3.19 5.01 8.19 10.47 13.65 15.93 19.11 20.93 22.30 23.21 24.57 24.57 0.00

Annual Natural Gas Cost 6.83 7.01 1.20 1.31 7.43 7.54 1.66 1.78 7.92 8.05 8.19 8.33 8.48 6.63 8.78 8.94 9.10 9.27 9.38 0.00

Annual Elacttlclty Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TofalCo.t. 63.33 6.83 8.83 9.02 9.13 9.25 9.38 9.48 10.97 12.92 16.24 18.66 21,98 24.40 27.74 29.71 31,24 32.31 33.84 33.95 0.00

BASE CASE RANGE

Maintenance Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

MnuatNatjral0ssCost 19.67 20.19 20.72 21.05 21.38 21.71 22.05 22.40 22.78 23.18 23.58 23.98 24.40 24.84 25.28 25.74 26.20 26.67 28.09 0.00

Annual El.cntclty Coil 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TotalCost. 19.67 20.10 20.72 21.05 21.38 21.71 22.05 22.40 22.78 23.18 23.58 23.98 24.40 24.84 25.28 25.74 26.20 28.67 28.99 0.00

FESULT8

NetSavings, Modlfed Range -63.33 12.63 11.35 11.70 11.91 12.13 12.35 12.57 11.43 9.86 6.93 4.92 2.00 -0.01 -2.90 -4.43 -5.50 -6.11 -7.17 -6.96 0.00

(a) If Inlialcoet posItIve, net present value of future aavingaflrtltlltcost; It Inltlalco.tn.gdIlve, Inhtal sailngsfNPv of future coal. DATA SET No. B-Il (DCE- O6/294

EE-RM-90-201 COMMENT OOR13

TableA-6. Standing Pilots Replaced with Electronic Ignition, 1/2 New Outlet Cost--Cooktop 

COST CALCUlATION DOLLARS ASSUMPTIONS RESULTS @S%Dloc. FII. 

AI COlculaUonl oreln Conotan! 11190 Dona .. Fuel Coot Sc."odo DOE, _denlol, f\of. Ca •• Annualzed Net So •. 1.11 S/yr DISCOUNT RATE An Sa., S BftICot 

Dlocoun1 Rale (Re.~ 6.0% Benonl/Coot( 0) 1.19 

MODIFIED RANGE Appl"""a UIe, V .... 10 Inlml Rale 01 f\ofum 11.7% SenolUvtIy 2.0% 1.32 1.33 

MI"'l%> from MIInUIEIu~ng Coot 2.81 Simple PaybEk 6.3 ya ... 10 Dloc'nl 7.0% 0.98 1.18 

Added Inotallod Coot, S 63.33 Nol Energy Saved 2,050 kBlu/yr Rale 15.0% -1.05 0.90 

BASE CASE RANGE Annualzed Gao So •. 14.75$1'1' 

MoIntenanco Cool, S, NPV @ 8% 89.05 Mllnlenance Coot, S, NPV @ s% 0.00 FIRST COST An Sa.,S BftICot 

a .. , AnnUli Cooking U .. , 1000 BlJ/yr 1,092 00', Annual Cooking U.a, 1000 BlJ/yr 1,092 

a .. , Non-Cooking Pilot., 1000 BlJ/yr 0 a •• , Non-CookIng Pilot., 1000 BlJ/yr 2,050 SENSITMTY SenolUvtIy 75% 2.53 1.59 

10Flm 85% 1.l1li 1.41 

a .. , Totol Uoo, loooBlu/yr 1,092 a •• , Totol Uoo, loooBlu/yr 3,142 GAS COST An SI., S BftICot Coot 120% -0.03 1.00 

150% -1.73 0.80 

Sen.ItMty 80% -1.85 0.87 

loG .. 120% 4.DIi 1.72 GAS QUANTITY An Sa., S BftICot 

Cool 

Senolttvtly 80% -1.85 0.87 

APPUNICE UFE An SO" S BftICot lomounl 125% 4.80 1.85 

Enorgy,lnnullCooking Uoo,loooBlut\ 1,092 Enargy,lnnualCooking U.a,loooBlu/yr 1,092 01 G •• , 150% 8.40 2.50 

CookIng Elllcfency 30.90% Cooking Elllcfency 30.90% SenlltlYiIy -2 1.84 1.27 8o.a& 185% 10.70 2.80 

Energy, Totallnnual Uoo, 1000 BIu/yr 1,092 Energy, Tot_llnnuol Uoo, 1000 BIu/yr 3,142 10 V ... UIe 2 0.71 1.13 ModItIed 215% 18.08 4.10 

Enorgy Factor 39.90% Enorgy Factor 13.88% Chang. 

V •• r 1997 I- I_ 2000 2001 2002 2003 2004 2005 200S 2007 2008 2000 2010 2011 2012 2013 2014 2015 2016 2017 )-

f 

00 

MODIFIED RANGE 

Inotollod Coot, _II 53.33 

Malnlenance Coot 0.00 1.82 1.82 1.82 1.82 1.82 1.82 3.10 5.01 8.10 10.47 13.85 15.93 10.11 20.03 22.30 23.21 24.57 24.57 0.00 

Annu.1 Noll'ol 00' Coot 11.53 7.01 7.20 7.31 7.43 7.54 7.88 7.78 7.92 8.05 8.10 8.33 8.48 8.63 8.78 8.G4 11.10 0.27 0.38 0.00 

Annual EIoctIlctty Coot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Tot.ICoot. 63.33 11.83 8.53 0.02 0.13 0.25 0.38 0.4S 10.07 12.92 18.24 18.88 21.08 24.40 27.74 211.71 31.24 32.31 33.84 33.95 0.00 

BASE CASE RANaE 

Maintenance Coot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annu_1 Nollrel aa. Coot 10.87 20.111 20.72 21.05 21.38 21.71 22.05 22.40 22.78 23.18 23.58 23.08 24.40 24.84 25.28 25.74 211.20 211.87 211.99 0.00 

Annual EIoctIlctty Coot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Tot.ICooII 111.87 20.111 20.72 21.05 21.38 21.71 22.05 22.40 22.78 23.18 23.58 23.98 24.40 24.84 25.28 25.74 211.20 211.87 211.99 0.00 

RESULTS 

Net Slvtng., ModItIed Rang. -63.33 12.83 11.35 11.70 l1.Gl 12.13 12.35 12.57 11.43 0.88 8.93 4.92 2.00 -0.01 -2.90 -4.43 -5.50 -6.11 -7.17 -8.l1li 0.00 

(a) Hlnllalcoll p_, netpre.ent .aklo 01 fUture IIYlngo,1nltlolcool; H lnIItolcoolnog_,lnIlolaoYlngl/NPV 01 fUture coot •. DATASET NO.8-II (DOE-2) 08!2~4 
; o.0

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6-V

EE-RM-90-201 COMMENT OOR13

ng Pilots Replaced with Electronic Ignition, New Outlet--Cooktop 

ASSUMPTIONS RESUlTS @O%OIoc. RI. 

Fuol Cott DOE, _onlal, Ref. C ... Annua!zed Nil So •. -2.112 Sly, DISCOUNT RATE An Sa., $ Bft/CII 

OIocount RIlle 0.0% Beneftl/COll( a) 0.70 

Applonce Ufo, V .... 18 Inlml RIIt.oI Retlm NA SonliUvIty 2.0% -1.55 0.78 

Merk from MonuIlCIuring Cott 2.81 Simple PayblCk 27.1 y •• ,. to OIoc'nt 7.0% -3.37 0.08 

Nil Enorgy S.Ved 2,050 kBluly' RIIt. 15.0% -0.21 0.53 

BASE CASE RANGE Annualzed Gil SI •. 14.7Hlyr 

Malntononc:e Cott, S, NPV@ 8% 0.00 FIRST COST An Sa., $ Bft/CII 

G •• , Annuli Cooking 1JIa, 1000 BlJlyr 1,0112 

G •• , Non-CookIng Pilot., 1000 BlJIy' 2,050 SENSITMTY SonoltMty 75% -0.49 0.93 

10Rm 85% -1.40 0.82 

G •• , Tolal 1JIa, l000Blu/y' 3,142 GAS COST An SO" S Bft/CII Cott 120% -4.80 0.58 

150% -7.77 0.47 

SonoltMty 80% -5.87 0.39 

loGo. 120% 0.03 1.00 GAB QUANTITY An So., S Bft/CII 

Cott 

SonoltMty 80% -5.07 0.38 

APPLWICE UFE An Sa., S Bft/CII to Amount 125% 0.77 1.08 

Energy, lMual Cooking 1JIa, 1000 Btulyr 1,0112 of 0." 150% 4.40 1.40 

Cooking EfIIcIoncy 39._ SonoltMty -2 -2.85 0.74 Sa .. & 105% 0.08 1.09 

Energy, T oIollMu 01 1JIa, 1000 Btuly' 3,142 toVro. Ufo 2 -3.11 0.08 ModIfted 215% 14.08 2.45 

Energy FlCtor 13.88% Chongo 

I- I- 2000 z001 2002 2003 2004 2005 2008 z007 2008 200II 2010 2011 ZOl2 Z013 Z014 Z015 2010 2017 > I \0 

0.00 1.52 1.52 U2 1.82 U2 1.52 3.18 5.01 8.10 10.47 13.85 15.03 10.11 ZO.03 22.30 23.21 24.57 24.57 0.00 

U3 7.01 7.ZO 7.31 7.43 7.54 7.08 7.78 7.112 8.05 8.10 8.33 8.48 8.83 8.70 0.D4 0.10 0.27 0.38 0.00 

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

8.83 8.83 0.02 0.13 11.25 0.38 11.48 10.07 12.112 10.24 10.08 21.118 24.40 27.74 21.71 31.24 32.31 33.04 33.115 0.00 

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

11.87 ZO.18 ZO.72 21.05 21.38 21.71 22.05 22.40 22.78 23.18 23.58 23.118 24.40 24.84 25.28 25.74 28.ZO 28.87 28.00 0.00 

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

1l1.li7 ZO.1" ZO.72 21.05 21.38 21.71 22.05 22.40 22.78 23.18 23.58 23.118 24.40 24.84 25.28 25.74 28.ZO 28.87 28.00 0.00 12.83 11.35 11.70 11.01 12.13 12.35 12.57 11.43 0.08 o.n 4.112 2.00 -0.01 -2.00 -4.43 -5.50 -0.11 -7.17 -0.08 0.00 

. vlngl/Wllolcoot;" lnItIolcoolneg_,lnIlal .. vlngI/NPV 01 Mu .. cooto. DATASET No. B-llA(DOE-2) 0III21W4 
Table A-8. Standing Pilots Replaced with Electronic Ignition, Existing Outlet- -Standard Oven

COST CA CULATION DOUARS ASSUMPTIONS I8UI.TS @ 0% DIsc. At.

All CalculatIons irs In Constant 1990 Dollars Fuel Cost Sc.na4o DOE, Resldatht, P,.l. Ca,. Annualzsd Nil Say. -2.09 S/yr DISCOUNT RATE An 8ev, $ BIt/Cit

DIscount Rats (Raa 0.0% B.nalIl/Co,l(a) 0.31

MOCIFED RANGE Applance Ut., Vials 19 kitint Rat. of Refum NA Sonsittuly 2.0% -2.13 NA

Markt.fronMeufdtudngCoat 2.81 SlmplaPaybsck 21.4yoaii toDtsc'nt 1.0% -1.98 0.39

Add.dlnstatlsdCoit,$ 33.89 NetEnsrgy8sv.d t,469k81u/yr Rats 15.0% -1.96 0.64

BASE CASE RANGE Annuatzed Gas Say. 11.44 S/yr

Malnlsianc. Coat, 5, NPV @6% 89.05 Malntonance Cost, 5, NPV @ 6% 0.00 FiRST COST An Say, S BA/Cit

Gas, Annual Cooldng Us., 1000 Bti/yr 1,204 Gas, Annual Cooldn9 Lisa, 1000 Btl/yr 1,284

Gaa,Non-CooldngPllots,l0000ti/yr 0 Gas,Non-CooldngPtlota,l0000b/yr 1,508 SENSITMTY Smsltkitty 75% -1.33 0.42

Gas, 8s8 Clean, 1000 Btu/yr, 0 CycIsa 0 Gas, 8.0 Clean, 1000 Blu/yr, 0 Cycls. 0 to First 05% -1,63 0.37

Gas,Totalua., l000Btu/yr 1,204 Gaa,Tdtal Us., l000eiu/yr 2,192 GAS COST An Say, $ BA/Cat Cost 120% -2.69 0.26

150% -3.61 0.21

Elactdclty, Annual Cooldng Use. lMki/yr 29.2 Sonsllntty 80% -4.31 NA

EIactcIty, Clock, I&b/yr 0.0 to Gas 120% 0.20 1.07 GAS QUANTITY An Say, S BA/Cat

EIectcIty, 5.8 Clean, lA'lh/yr. 0 Cycles 0.0 Cost

EISCIIICIIY. Total, lATh/yr 29.2 8.1sftI$ty 80% -4.37 NA

APPUANCE UFE An 8ev. 5 Sf1/Cat to Antount 125% 0.77 1.26

Ensrgy, Annual Cooldng Us., 1000 Ptu 1,304 En.rg Annual Cooldng U**, 1000 Etu/yr 1,284 of Gas, 150% 3.83 2.20

Cooldng EfOdency 5.83% 000tdng Eltldency 5.92% SonsltMty -2 -1.33 0.59 Base & 165% 5.35 2.76

Ensrgy, Total Annual Use, 1000 Btu/yr 1,304 Energy, Total Annual Us., 1000 Btu/yr 2,792 to Vt.. UI. 2 -2.67 0.07 Modlllsd 215% 11.07 4.64

Ensrgy Foctor 5.83% Energy Foclor • 2.72% Changs

Year 1991 1998 1999 2000 2001 2002 2003 2004 2005 2006 2001 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

MODIFIED RANGE

Installed Cost, Adottloral 33.89

Malnt.nanc.COst 0.00 1.62 1.82 1.82 1.62 1.82 1,82 3.19 5.01 8.19 10.41 13.65 15.93 19.11 20.93 22.30 23.21 24.51 24.57 0.00

Annual Natiral Gas Cost 7.54 1.74 7.94 8.07 8.19 8.32 8.45 8.58 8.73 8.58 9.03 9.19 9.35 9.52 9.69 9.60 10.04 10.22 10.34 0.00

Annual EI..ctcIty Coat 2.33 2.35 2.37 2.39 2.42 2.44 2.46 2.49 2.52 2.50 2.59 2.63 2.67 2.86 2.69 2.10 2.71 2.72 2.73 0.00

TotalCoala 33.89 9.81 11.91 12.13 12.28 12.43 12.58 12.74 14.28 16.26 19.63 22.09 25.47 27.94 31.31 33.31 34.86 35.96 37.51 37.84 0.00

BASE CASE RANGE

Malnlanance Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

AnnualNatiralGasCoat 11.48 11.94 18.42 18.71 19.00 19.30 19.60 19.91 20.25 20.60 20.95 21.32 21.68 22.07 22.41 22.68 23.29 23.71 23.99 0.00

Annual ElactcIty Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TotalCost. 17.48 17.94 16.42 18.71 19.00 19.30 19.60 19.91 20.25 20.60 20.95 21.32 21.68 22.01 22.41 22.88 23.29 23.71 23.99 0.00

IESt.LT8

N.tsatfngs,Modltlsdflange -33.89 7.61 8.04 0.29 6.43 6.51 6.72 6.86 5.85 3.99 0.97 -1.14 -4.18 6.26 9.23 -10.84 11.98 12,67 13.81 13.65 0.00

(a) tlktlfalcosl posItIve, nut pr.sett vaUs of future saitngaflntdalccet; If InItial costnsgotivs, inhial sa*tgs/NPV of futur, costs. DATA SEF No. A-S (DOE-2) 06/2a'94

EE-RM-90-201 COMMENT OOR13

TableA-8. Standing Pilots Replaced with Electronic Ignition, Existing Outlet - - Standard Oven 

COST CAlCUlATION DOllARS ASSUMPTIONS RESUlTS @ 8% Dloc. RI. 

AI C.IcuIaUon. a .. In Conllanl 11190 Dolla,. Full Cost Scen._o DOE, _don 'ai, Flat. C ••• Annual.ad Not So •. -2.09 Sty, DISCOUNT RATE An Sa., S Bft/CII Dlocount RIll. IRlla~ 11.0'lI0 Bonlftl/ColIl a) 0.31 

MODIFIED RANGE App'ance UIo, V .. ,. 18 Inlml Rale 01 Rallm NA SonoltMty 2.0'lI0 -2.73 NA 

Mark 4> Irom ManullICIu~ng Cost 2.81 Simple PaybllCk 21.4 yea .. 10 Dlsc'nl 7.0% -1.88 0.38 

Added Inllallad Cost, S 33.88 Not Energy SaYed 1,488 kBtuty, RIll. 15.0% -1.1M! 0.84 

BABE CASE RANGE AnnuII.ad Ga. SI •. 11.44 Sty, 

Malnla",nc. Cost, S, NPV@II% 88.05 Moint.,ance Cost, " NPV@ S'!Io 0.00 FIRST COST An Sa.,S Bft/C., a •• , Annual Cooking \Joe, 1000 B\lty, 1,204 aa., Annuli CookIng Uta, 1000 B\lty, 1,284 

a •• , Non-Cooking Pilot., 1000 B\lty, 0 a .. , Non-CookInIl Pilot., 1000 B\lty, 1,_ SENSITMTY SonlltMty 75% -1.33 0.42 

G •• , SefCII .. , 1000 Btuty" OCycIot 0 a •• , S.' CII .. , 1000 Btuty" 0 Cyclot 0 loR.., a5% -1.113 0.37 

aa., T 0111 \Joe, 1000 Btuty, 1,204 aa., Tolal Ute, 1000 Btuty, 2,782 GAB COST AnSa., • Bft/CII Cost 120% -2.88 0.28 

150'lI0 -3.81 0.21 

Eloctilclty, Innual CookIng \Joe, kWhty' H.2 SonoilMty 80'lIo -4.37 NIl 

Eloctilclty, Clock, t(Nhty, 0.0 10 Ga. 120% 0.20 1.07 GAS QUANTITY AnSa., • Bft/CII 

Eloctilclty, S.' Cllan, t(Nhty" 0 Cyclot 0.0 Cost 

Eloctilclty, ToIal, t(Nh(yr H.2 SlIlsllMty 80% -4.37 NIl APPUANCE UFE An SaY,S Bft/CII 10 Amount 125% 0.77 1.25 

Energy, Innual Cooldng \Joe, 1000 BtuJ\ 1,304 EnelllY, Innu al CookIng Ute, 1000 Btuty, 1,284 olGa., 150'lI0 3.83 2.20 

Cooldng EIldGflC)' 5.83% Cooldng EIftciGfIC)' 5._ SlIlsllMty -2 -1.33 0.58 ea .. & 185% 5.35 2.78 

Energy, Tolallnnual Ute, 1000 Btuty, 1,304 En_IllY, Tolallnnual Ute, 1000 Btuty, 2,782 10 V,.. UIo 2 -2.87 0.07 ModI1Iad 215% 11.07 4.84 

EnelllY Faclor 5.83% Energy Factor • 2.72% Change 

» 

Yea, 18117 I_ I_ 2000 2001 2002 2003 2004 2005 2008 2007 2008 2009 2010 2011 2012 2013 2014 2015 2018 2017 I 

-

0 

MODIFIED RANGE 

Inllallocl Cost, AddtJonal 33.8g 

Malnlenance Cost 0.00 1.82 1.82 1.82 U2 1.82 U2 3.111 5.01 8.18 10.47 13.85 15.83 10.11 20.83 22.30 23.21 24.57 24.57 0.00 

Annual Nall,.1 a •• Cost 7.54 7.74 7.04 8.07 8.18 8.32 8.45 8.58 8.73 8.88 8.03 11.18 U5 8.52 8.80 8.88 10.04 10.22 10.34 0.00 

Annuli Eloctilcity Cost 2.33 2.35 2.37 2.30 2.42 2.44 2.48 2.48 2.52 2.58 2.58 2.83 2.87 2.88 2.88 2.70 2.71 2.72 2.73 0.00 

ToIllCoII. 33.88 0.87 11.81 12.13 12.28 12.43 12.58 12.74 14.28 18.28 18.83 22.09 25.47 27.04 31.31 33.31 34.88 35.1M! 37.51 37.84 0.00 

BABE CASE RANGE 

Malnlenance Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annual Nall,.1 aa. Cost 17.48 17.04 18.42 18.71 10.00 18.30 18.80 18.81 20.25 20.80 20.05 21.32 21.88 22.07 22.47 22.88 23.H 23.71 23.811 0.00 

Annuel Eloctilcity Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

ToIelColII 17.48 17.04 18.42 18.71 111.00 18.30 18.80 111.111 20.25 20.80 20.05 21.32 21.88 22.07 22.47 22.88 23.H 23.71 23.811 0.00 

RESUlTS 

NoISaql, _ad Allng" -33.88 7.111 8.04 8.H 11.43 11.57 8.72 8.88 5.85 3.811 0.87 -1.14 -4.18 -8.28 -8.23 -10.84 -11.88 -12.87 -13.81 -13.85 0.00 

la) H lnI'alcoot pooItIve, not p_ .au. 01 futU .. oaq~aICOlI;" initial coolnlll_,InI'.1 oaql/NPV 01 futU .. cool •. DATA SET No. A-5 lDOE-2) 08/21't'94 
Table A-9. Standing Pilots Replaced with Electronic Ignition, 1/2 New Outlet Cost--Standard Oven

COST CALCULATION DOU..ARS ASSUMPTIONS FE8ILTS @6% (DIsc. Rt.

N CauIetIone scsI,, Constant 1990 Doter. Fuel Coal Scenario DOE. Paalder tat, Rat Cat. Annuatced Not 9ev. -612 S/yr DISCOUNT RATE An 8ev, $ BII/C,t

DIscount Rat. (Roam 9.0% Bensttt/Cost(a) 0.13

MODIFiED RANGE Appuanc. Ut., Years 19 In(n,I Rate ol Retim NA S.tdtMly 2.0% -5.60 NA

M.rkLfromManufscturingCost 2.81 SIrnpI.Paybsck Never IoDIscnt 7.0% -6.34 0.11

Add.dlnsletedCost,$ 78.69 NetEnergySeved l,469kB*u/yr Rate 15.0% -9.22 0.28

BASE CASE RANGE Annuatzed Ga. 8ev. 11.44 S/yr

Malnterance Coal, 8, NPV @6% 69.05 Maintananca Coat, 8, NPV @ 8% 0.00 FIRST COST An 5ev, $ Ott/Cat

Ge., Annual CookIng U.., 1000 BtI/yr 1,204 Ge., Annual CookIng Ut., 1000 Oti/yr 1,284

GaiN n-CooldngPlIot.,I0008IJ/yr 0 Gea,Non-COOIdngPlIot.,l000BtI/yr 1,508 SENSITMTY BanslIMly 75% -4.35 0.16

Ge.,BeIICIe.n,l0008tu/yr,OCyclos 0 Oee,8dCIsen,l000Blu/yr,OCyclee 0 loRrst 85% -5.09 0.16

Gee, Total U.., 1000 Otu/yr 1,204 Gee, Total Ut., 1000 Blu/yr 2792 GAS COST An 5ev, S Oft/Cal Coat 120% -7.53 0.11

150% -9.85 0.09

ElectricIty, nnualCootdng Use, IAMi/yr 29.2 BanallIvity 80% -8.41 NA

Electricity, ClocIç kWh/yr 0,0 to Gas 120% -3.83 0.46 GAS QUANTITY An 8ev, S 8th/Cat

Electricity, 8.6 Clean, kWh/yr, 0 Cycles 0.0 Coil

Electricity, Total, Wilt/yr 29.2 SatatuvIty 80% -6.41 NA

APPLIANCE UFE An 8ev, $ 86/Cat toAntount 125% -3.26 0.54

Energy, Mnuel CookIng U.., 1000 8lu 1304 Energy, Mnuel CookIng Us., 1000 OtU/yr 1,284 of Gee, 150% -0.40 0.04

Cooling Ettciency 5.83% Cooling Et8dcncy 8.92% Bursltlvtty -2 -5.62 0.25 Bes.& 185% 1.32 1.19

Energy, Total rnual U.., 1000 Btu/yr 1304 Energy. Total ftatnuel U.., 1000 Btu/yr 2,702 tO Yr.. Ut. 2 -650 0.03 ModIIt.d 215% 7.04 2.00

Energy Fector 5.63% Energy Fector 2.72% Ctteng.

Year 1997 1098 1000 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

MODIFIED RANGE

Instated Coal, Addttcn.l 76.89

UalntanancCo.t 0.00 1.82 1.82 1.82 1.62 1.82 1.62 3.19 5.01 8.19 10.47 13.65 15.93 19.11 20.03 22.30 23.21 24.51 24.51 0.00

AnrrualNakjralGeeCost 7.54 7,74 7.94 8.07 8.19 8.32 6.45 6.58 8.73 6.68 9.03 0.19 9.35 9.52 9.69 0.60 10.04 10.22 10.34 0.00

Annual Electricity Coal 2.33 2.35 2.31 2.39 2.42 2.44 2.46 2.49 2.52 2.56 2.59 2.63 2.61 2.68 2.69 2.70 2.71 2.72 2.73 0.00

101.100.1. 78.60 0.67 11.01 12.13 12.26 12.43 12.58 12.74 14.26 16.26 19.63 22.00 25.47 21.04 31.31 33.31 34.86 35.06 37.51 37.64 0.00

BASE CASE RANGE

Malnturanco Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Nw,uaIN.krrelG.sCoat 17.46 17.04 18.42 18.71 19.00 ¶9.30 19.60 19.91 20.25 20.60 20.95 21.32 21.68 22.01 22.41 22.88 23.29 23.71 23.99 0.00

AnnuelElsctric$tyCoat 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0100 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

lotalCoat. 17.46 11.04 16.42 16.71 19.00 ¶9.30 19.60 19.91 20.25 20.60 20,95 21.32 21.68 22.01 22.47 22.86 23.29 23.71 23.99 0.00

I'€BULTS

Nel8evlnga,Moott.dRcnga -78.69 7.61 8.04 8.29 6.43 6.57 6.72 6.66 5.65 3.99 0.97 -1.14 -4.16 -6,26 -9.23 -10.64 -11.96 -12.67 -13.61 -13.65 0.00

(a) If Inllelcoet posItIve, net pr.sant vakia ottuture savtngsilnttlalco.t; If InitIal co.tn.gaitve, Intlal eav$ngs/NPV 04 tutur.cost.. DATA SET No. A-8 (DOE-2) 03/26/04

EE-RM-90-201 COMMENT OOR13

Table A-9. Standing Pilots Replaced with Electronic Ignition, 1/2 New Outlet Cost- -Standard Oven 

COST CAlCUlATION DOllARS ASSUMPTIONS RESUlTS @8% Dloc. AI. 

Al! Calculation' ... In Canll,,", 11190 00110,. Fu., Cool _ado DOE, ReoIdfn'"I, ReI. ca .. Annualzad NtII Sav. -812 SlYr DISCOUNT AATE MSav,S Bft/CII Dlocounl Rot. (Rel~ 8.0% BenetltJCoII( .) 0.13 

MODtFlED AANGE Applonco 1JIe, Y.I" 18 1n1.,1 Rollo of Re"m NA afnllllll1ty 2.0% -5.80 NA Mork ~ 110m MonufllCluring Cool 2.81 SImple PayblCk Novar 10 DllC'nl 7.0% -8.34 0.17 Addad Inllllled Cool, S 78.80 NtII Enor;y Saved 1,488 kBlulYr Roll. 15.0% -9.22 0.28 BASE CASE RANGE Annualzad G •• SlY. 11.44 SlY' 

Malntfnonco Cool, $, NPV@ 8% 88.05 Malnlfn....,. Cool, S, NPV@ 8% 0.00 FIRST COST MSav,S Bft/CII 

GI., AnnulI CooIdng u.., 1000 BIlJ/'ir 1,204 GI., AnnulI Cooking u.., 1000 BIlJ/'ir 1,284 

Ga., Hon-Cooklng PIlot., 1000 BIlJ/'ir 0 GI., Hon-Cooldng PIlot., 1000 BIlJ/'ir 1,508 SENSn-MTY Sfnllll'ol1ly 75% -4.35 0.18 G •• , So. CIe ... , 1000 Btu/'ir, 0 eye ... 0 G •• , a., Clean, 1000 Btu/'ir, 0 eye ... 0 loRm 85% -5.08 0.18 

GI., Tot.1 u.., lOOOBtu/'i' 1,204 G •• , Totll u.., loooBtu/yr 2,702 GAS COST MalV,S Bft/CII Cool 120% -7.53 0.11 

150% -8.85 0.09 

EIectIlclt}',"""""ICooking u'a,-Wr 211.2 SfnoltMly 80% -8.41 HA 

Electlicit}', Clock, 1<WI1IY' 0.0 loG •• 120% -3.83 0.48 GAS QUANTITY MSav,S Bft/CI1 

Electlicit}', all Clean,l<WI1IYr, 0 eye ... 0.0 Cool 

Electlicit}', Total, kWh/'ir 211.2 Sfnllllll1ty 80% -8.41 NA APPlIANCE UFE MSIV,S Bft/CII loAmounl 125% -3.28 0.84 

Enar;y, ........ II CooIdng u.., 1000 BIuII 1,304 Enar;y, Innual CooIdng u.., 1000 Btu/yr 1,284 ofG .. , 150% -0.40 0.94 

Cooking E1IIcIency 5.83% CooIdng EIIcI"",,, 5.112% Sfnllllll1ty -2 -5.82 0.25 ea .. & 185% 1.32 1.18 

Enar;y, Totll"""".1 u.., 1000 Btu/'ir 1,304 Enarvv, Totol"""""1 u.., 1000 Btu/yr 2,702 10 Y".1JIe 2 -8.50 0.03 Modi1Iad 215% 7.04 2.00 

Enar;y Foelor 5.83% Enarvv Foetor 2.72% Chango 

> V •• , 1l1li7 I_ I_ 2000 2001 2002 2003 2004 2005 200S 2007 200S 200G 2010 2011 2012 2013 2014 2015 2018 2017 I 

MODlFlEDRANGE 

-- Inllllled Cool, AddIIonII 78.89 

Malntfn....,. Cool 0.00 1.82 1.82 1.82 1.82 1.82 1.82 3.1' 5.01 8.1' 10.47 13.85 15.83 1'.11 20.83 22.30 23.21 24.57 24.57 0.00 

AnnulI HI" .. 'Gil Cool 7.84 7.74 7.14 B.07 8.1' 8.32 8.45 8.58 8.73 8.88 '.03 '.1' '.35 '.52 UG 8.88 10.04 10.22 10.34 0.00 

AnnulI Electlicit}' Cool 2.33 2.35 2.37 2.38 2.42 2.44 2.48 2.4' 2.52 2.88 2.58 2.83 2.87 2.88 2.80 2.70 2.71 2.72 2.73 0.00 

TotllCooII 78.80 D.87 11.11 12.13 12.28 12.43 12.88 12.74 14.28 18.28 19.83 22.09 25.47 27.84 31.31 33.31 34.88 35.115 37.51 37.84 0.00 

BASE CASE RANGE 

Malnt .. anca Cool 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annu., HI" .. 'GI, Cool 17.48 17.14 18.42 18.71 19.00 10.30 111.80 1 •.• 1 20.25 20.80 20.115 21.32 21.88 22.07 22.47 22.88 23.211 23.71 23.l1li 0.00 

Annual Electlicit}' Cool 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0000 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Total Cool. 17.48 17.94 18.42 18.71 111.00 111.30 111.80 111.111 20.25 20.80 20.115 21.32 21.88 22.07 22.47 22.88 23.211 23.71 23.l1li 0.00 

RESUlTS 

HtII Saving', _ Rengo -78.811 7.81 8.04 8.211 8.43 8.57 8.72 8.88 !I.85 3.l1li 0.'7 -1.14 -4.18 -8.28 -11.23 -10.84 -11.118 -12.87 -13.81 -13.85 0.00 

(I) KlnlillcOll poIIIIva, ntll p ..... , va". of MY .. lIw.gollnlllllcool;" Inlllllcoolnog_,lnIlallllllngl/NPV of MY .. c:ool •. DATA SET No. A-8 (DOE-2) 0812~4 
Table A-1O. Standing Pilots Replaced with Electronic Ignition, New Outlet- -Standard Oven

COST CALCUtATION DOLLARS ASSUMPTIONS ISULTS @6% DIsc. RI.

AS Ceulalfons ar.kr Constant 1990 Dollars Fuel Cost Scenaño DOE, Residantal, Ret. Case Annuatzed Net 8ev. -10.15 5/yr DISCOUNT RATE An Say, $ Ba/Cat

DIscount Rate (Ree 8.0% Benefit/Cost(s) 0.09

MODIFIEDRANGE ApplancoLlte,Yoers 19 kmnlRat.otRetirn NA SensItIvity 2.0% -8.47 NA

Mekl,,fromMmUfsc.tuilngCost 2.61 SlmplePaybsck Never toDlsc'nt 1.0% -10.69 0.11

AddadlnstalledCost,$ 123.86 NetEnergySeved 1,489k8tu/yr Rate 15.0% -18.48 0.18

BASE CASE RANGE Mnualzed Gas Say. 11.44 5/yr

MaIntenance Cost, 5, NPV@ 8% 69.05 MaIntenance Coat, 5, NPV@ 6% . 0.00 FiRST COST An 8ev, $ BIt/Cat

Gee, Annual 000ldng Use, 1000 RU/yr 1.204 0cC, AnnUal Cootig Us., 1000 RU/yr 1,284

Gas,Non-000ldngPllots,t000etihrr 0 Gee,Non-Coogts,10008U/yr 1,506 SENSITIViTY SensItivity 75% -7.38 0.11

Gas,SelfClean,t000Rtu/yr,OCycles 0 Gea,SeltClean,l000Btu/yr,OCycles 0 loFirit 85% -8.49 0.10

Gas, Total Use, 10008W/yr 1,204 Gas, Total Uae, 10008W/yr 2,792 GAS COST An 8ev, $ BIt/Cat Cost 120% -12.37 0.01

150% -15.70 0.06

ElectrIcity, PctnualCooklng Use, l*/yr 29.2 SensitIvity 80% -12.44 NA

ElectrIcIty, Claclç kWtVyr 0.0 to Gas 120% -7.68 0.29 GAS QUANTITY An Say, $ Rft/Cst

EleCtrICity, Sell Clean, I/Mr/yr. 0 Cycles 0.0 Cost

Electrlclty,Totel,k'Mr/yr 29.2 SialtIvIty 60% -12.44 NA

APPUANCE UFE An Say, $ RB/Cit to Amount 125% -1.29 0.34

Energy, MnualCooldng Us., l000Btu4 1,304 Energy, Mnual000ldng U., 10008W/yr 1,284 of Gsa, 150% -4.43 0.80

CooldngElltcl.ncy 5.83% Cooldng EffIciency 5.92% SensItIvIty -2 -9.92 0.16 Base& 165% -2.72 0.16

Energy, Total Mnual Use, 1000 Rtu/yr 1,304 Energy, Total Mnual Use, 10008W/yr 2,792 to Yri. lii. 2 -10.32 0,02 ModIfIed 215% 3.00 1.27

Energy Fector 5.63% Energy Fector 2.72% Change

Year 1991 1998 1999 2000 2001 2002 2003 2004 2005 2006 2001 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

MODIFIED RANGE

rntafled Cost, AddlIonet 123.88

Malntaranc.Cost 0.00 1.82 1.82 1.82 1.82 1.62 1.82 3.19 5.01 8.19 10.47 13.65 15.93 19.11 20.93 22.30 23.21 24.57 24.51 0.00

AnnualNatiralGasCost 7.54 7.14 7.94 8.07 8.19 6.32 8.45 8.58 8.73 8.88 9.03 9.10 9.35 9.52 9.69 9.88 10.04 10.22 10.34 0.00

AnnualElsctilcltyCost 2.33 2.35 2.37 2.39 2.42 2.44 2.46 2.49 2.52 2.56 2.50 2.83 2.67 2.88 2.69 2.70 2.71 2.72 2.73 0.00

TotatCosts 123.88 0.87 11.91 12.13 12.28 12.43 12.58 12.74 14.28 18.28 19.63 22,09 25.47 27.94 31.31 33.31 34.86 35.96 37.51 37.64 0.00

BASE CASE RANGE

MaIntenance Coat 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

MnuatNetiralGasCo$t 17.48 17.94 18.42 18.71 19.00 19.30 19.60 19.01 20.25 20.60 20.95 21.32 21.66 22.07 22.47 22.88 23.29 23.11 23,99 0.00

Annual ElectrIcity Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TolalCoita 17.48 17.94 18.42 18.71 19.00 19.30 19,60 19.91 20.25 20.60 20.95 21.32 21.66 22,07 22.47 22,88 23.29 23.71 23.99 0.00

FESULTS

Net8avlnga,ModlltadRangs -123,88 7.61 8.04 6.29 6,43 6.57 6.72 6.88 5.65 3.99 0.97 -1.14 -4.18 -6,28 -9.23 -10.84 -11.96 -12.67 -13.81 -13.65 0.00

(a) If Inliat cost posItive, not present vaIce of future sodngs,lnltlslcost; If InItial costnegstlv., kitlel aavingIJNPV of *.jttrr. cost.. DATA SET No. A-8A (005-2) 03/25194

EE-RM-90-201 COMMENT OOR13

TableA-lO. Standing Pilots Replaced with Electronic Ignition, New Outlet - -Standard Oven 

COST CALCUlATION DOUARS ASSUMPTIONS RESULTS @8""Dloc. RI. 

AR Cal::uIaUon .... In Conl1enl li90 DoHa ... Fuel ColI Bc..,a~o DOE, _donlal, Rot. Co •• Annu.heel Not So •. -10.15 Sty, DISCOUNT RATE An So., S Bft/CI1 Diocount Rala (Ra19 8.0% Beno1lI/Col1(a) 0.09 

MODIFIED RANGE Applance Ln_, Yal", 19 Inlml Rale 01 Ratlm NA Senolfl\1ty 2.0% -8.47 NA Mor1c ~!rom MonuIlCIurtng ColI 2.81 Simple Plybock Navar 10 Dloc'nl 7.0"" -10.89 0.11 Added 1n11111ed Coli, S 123.811 Nel Energy Saved 1,489 kBtutyr Rale 15.0"" -18.48 0.18 

BASE CASE RANGE Annufllzed Gaa Sav. 11.44 Styr 

Malnl., ..... ColI, " NPV@ 8"" e9.05 MainI., ..... ColI, " NPV@ 8% 0.00 FIRST COST An Sa., S Bft/C11 GI., Annuli Coo"'ng U.e, 1000 Btlty, 1,_ Go., Annuli Cooldng uaa, 1000 Btltyr 1,284 

GI., Non-Cooldng PIlot., 1000 Btltyr 0 G •• , Non-Cooldng PlIotI, 1000 Btltyr 1,508 SENSITIVITY S.,oIU\1ty 75"" -7.36 0.11 Ga., So. Cllan, 1000 Btuty" 0 eye ... 0 Go., So. Clean, 1000 Btutyr, 0 eye ... 0 loRi'll 85"" -8.49 0.10 

GI., Total uaa, l000BlUty' 1,_ G •• , Total uaa, l000Btutyr 2,792 GAS COST An SO" S Bft/C.I ColI 120% -12.37 0.07 

150% -15.70 0.08 

EIoctIldty, """'alCooldng U.e, Wfnty' 29.2 SlI101U\1ty 80% -12.44 NA 

EIoctIldty, Clock, tl!Nhtyr 0.0 toG •• 120% -7.811 0.29 GAS QUANTITY An Sa., S Bft/C11 EIoctIldty, So. Cllan, tl!Nhtyr, 0 eye ... 0.0 Coli 

EIoctIldty, Totol, tl!Nhty, 29.2 B.,oId\1ty 80"" -12.44 NA APPUANCE UFt An Sa.,S Bft/C11 10Amounl 125"" -7.29 0.34 

Enargy, """'"I Coo"'ng u.., 1000 BlUIl 1,304 Enargy, ""'" al Cooldng uaa, 1000 BlUty, 1,284 olGa., 150"" -4.43 0.80 

CooIdng Etllcloncy 5.113"" Coo"'ng Etllcloncy 5.92% SlI101U\1ty -2 -0.92 0.18 ea.o& 185"" -2.72 0.78 

Energy, Totll""""al u.., 1000 etutyr 1,304 Energy, Total...."...1 uaa, 1000 BlUtyr 2,792 10Y .... ~ 2 -10.32 0.02 Modlftad 215"" 3.00 1.27 

Enargy FElor 5.113"" Enorgy FElor 2.72% Change 

> v •• , 1997 1_ 1999 2000 2001 2002 2003 2004 2005 2008 2007 2008 200D 2010 2011 2012 2013 2014 2015 2018 2017 I 

-

N 

MOOF1ED RANGE 

1n11111ed ColI, Addllonll 123.811 

MainI., ..... ColI 0.00 1.82 1.82 1.82 1.82 1.82 1.82 3.111 5.01 8.19 10.47 13.85 15.93 19.11 20.93 22.30 23.21 24.57 24.57 0.00 

Annual N ..... I GI. ColI 7.54 7.74 7.114 e.o7 8.19 8.32 8.45 8.58 8.73 8.811 11.03 11.19 11.35 0.52 11.89 0.811 10.04 10.22 10.34 0.00 

Annual EIoctIldty ColI 2.33 2.35 2.37 2.39 2.42 2.44 2.48 2.49 2.52 2.58 2.511 2.83 2.87 2.811 2.811 2.70 2.71 2.72 2.73 0.00 

TotIICot .. 123.811 9.87 11.111 12.13 12.28 12.43 12.58 12.74 14.28 18.28 19.83 22.09 25.47 27.94 31.31 33.31 34.811 35.118 37.51 37.84 0.00 

BASE CASE RANGE 

MainI.,anc. ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annual N"","I Ga. ColI 17.48 17.114 18.42 18.71 111.00 111.30 111.80 111.91 20.25 20.80 20.05 21.32 21.811 22.07 22.47 22.88 23.29 23.71 23.99 0.00 

Annuli EIoctIldty ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Total Cot .. 17._ 17.114 18.42 18.71 111.00 19.30 19.80 111.91 20.25 20.80 20.05 21.32 21.811 22.07 22.47 22.811 23.20 23.71 23.99 0.00 

RESULTS 

Not Saving., ModHIad Range -123.811 7.81 8.04 8.29 8.43 8.57 8.72 8.811 5.85 3.99 0.97 -1.14 -4.18 -8.28 -9.23 -10.84 -11.118 -12.87 -13.81 -13.85 0.00 

(a) Wlnllalcol1 poIlU .. , nllp ... .,1 v .... 01 Mo .... vlngl/lnillolcool;H InIUllcoolnoglllvo,lnIlol.avlngl/NPV 01 Mo .. COl". DATA SET No. A-8A(DOE-2) 08!2~ 
0

0

ICI)

I

88 88 2

0 C

88 88 2

88 88

oo o6 a

2.

oo eo oo 6

2 2 2 88 88 2

10 0 00 S 00 oo oo 0

8 oä oä 0

88 828 2

0 0 C -

§ 8 88 8&8 2

iI 00 00 0

88; 8?8 8

óó ó6 6

8!8 88 8

oo o2ó a

g?; 8° 88 8;8; 8

c. - oG6 6G6 a

o0o oó.

88 88 8

6

C)

88 8882 8

a, -

oo. oo6 a

U, § § 8;8; 8888 8

©--. -

ecäc 66. a

88 Sz8 8

ooa ös,o 0

!! !

88E 8Z8 8

- oep. o,..5i- 6

88? 88! 8

- 00P 0I-6- a

-- -a,e I

§ r-i

C- (' ;C)

TableA-ll. Improved Door Seals - -Standard Oven COST CALCUlATION DOllARS ASSUMPTIONS RESULTS @ 8'" Dloc. Rt .0.8 CilculaUona .roln eon.,.", I ego DoRa" Fuel Cool Scenl.o DOE, _danlal, ReI. Ca.a Annualzed Net Say. -0.18 Styr 

Dlocounl Rela 8.0"- Benoftt/COlI(a) 0.33 MODIFIED RANGE Applance UIa, V .... 19 Inl.,1 Rllo 01 RI"m -4.7'" Se

lola'" Up from MlnUIlICIurtng Coli 2.81 Simpia PaybEk Naver to 

Added InlllaRed Colli, S 3.011 Net Energy SaYed 13 kBtutyr R

BASE CASE RANGE AnnUI'Zed Ga. Say. 0.09 Styr 

Malntenonc:e Colli, S, NPV@ 8'" 0.00 Malnlenance Cool, S, NPV@ 8"- 0.00 

GI., Annual CookIng Un, 1000 B1Jtyr 1,271 G .. , Annual CooIdng Un, 1000 B1Jtyr 1,2M 

Ga., Non -Cooldng Pilot., 1000 B1Jtyr 1,508 GI., Non-CooIdng Pilot., 1000 B1Jtyr 1,508 SENSITMTY SeGa., S •• Cia"", 1000 Btutyr, O<:}ela. 0 Ga., B •• Cia"", 1000 Btutyr, 0 <:}elet 0 1Ga., Tot.1 Un, l000BlUtyr 2,780 Gil, Total Un, l000BlUtyr 2,7112 GAS COST An SaY,S Bft/CII C

SanoHlYity 80'" -0.20 0.27 

10Ga. 120"- -0.18 0.40 

Cool 

B

APPlJ.IHCE UFE An SaY,S Bft/CII lo

Energy, InnUII Cooldng Un, 1000 !!lUll 1,271 Enlrgy,MnuIlICooIdng Un, l000BlUtyr 1,284 01 

Cooldng Efllcloncy 5.98'" Cooldng EfIIcIoncy 5.92'110 SenoHlYity -2 -0.20 0.31 e

En.rgy, Total Mnual Un, IDa) BlUtyr 2,750 En.rgy, ToIal ......... 1 Un, IDa) BlUtyr 2,7112 10 V". UIa 2 -0.17 0.38 MEnargy FlClor 2.73'" Enargy FlCtor 2.72'110 Chango 

Voor 1997 I_ I_ 2000 2001 2002 2003 2004 2005 2008 2007 2008 2009 2010 2011 2012 2013 

MODIFIED RANGE 

InllloRed Cool, AddUonal 3.011 

Moinlenance Cool 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annuli Na"rll Gu Cool 17.40 17.l1li 18.33 lU2 18.91 19.21 19.51 19.82 20.18 20.51 20.l1li 21.22 21.58 2U7 22.37 22.77 

Annual EIocIIIcIIy Cool 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

TotllCoaIo 3.011 17.40 17.l1li 18.33 18.82 18.91 19.21 10.51 19.82 20.18 20.51 20.l1li 21.22 21.58 2U7 22.37 22.77 

BASE CASE RANGE 

Maintenance Cool 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annuli NI"rll GI. Cool 17.48 17.94 18.42 18.71 19.00 19.30 19.50 19.91 20.25 20.50 20.95 21.32 21.68 22.07 22.47 22.68 

Annual EIocIIIcIIy Cool 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

TotIICoaI. 17.411 17.94 18.42 18.71 19.00 19.30 19.80 19.91 20.25 20.80 .20.95 21.32 21.68 22.07 22.47 22.68 

REBUlTS 

Net S.Ylng., _ed RIngo -3.011 0.08 0.08 0.08 0.09 0.09 0.09 0.09 0.09 0.09 0.09 0.10 0.10 0.10 0.10 0.10 0.10 

(I) HInIlalcolli p_,net p ...... , ya". oIlUIuro H InIUalcoalnog_, InIlalaaYlng./NPV oIlUIurocoalo. DATA SET N
Table A-12. Improved Door Seals--Self-Cleaning Oven

COST CALCULATION DOLLARS ASSUMPTIONS IESULTS @6% CIsc. RI.

AS Ca ulflns ar.In Constant 1990 Dollar, Fuel Cost $cena4o DOE, Resldantel, Ret, Case Annualzed Net Say. -0.21 $,r DISCOUNT RATE An Say, $ 08/Cit

DIscount Rat, (R.a 6.0% BerrefttICoyt(s) 0.27

MODIFIEDRANGE AppIanceLIte,Years 19 lntrnlRataolRetjrn -6.3% Se1sItl1ty 2.0% -0.12 0.39

MakLtromManutscturIngCoat 2.61 SlmplePaybsck Never loCtsc'nt 7.0% -0.23 0.25

MdedlnstafledCost, $ 3.15 NelEnergySavad 11 kAtu/yr Rat. 15.0% -0.43 0.14

BASE CASE RANGE Annualzed Gas Say. 0.08 S/yr

Malnturance Cost, 5, NPV@ 8% 89.05 Meinturenc. Cost, 5, NPV@ 5% 89.06 FiRST COST An Say, $ BtVCst

Gas Annual Cooldng Ui., 1000 01.1/yr 956 Gaa,AnnualCooWng Use, 1000 Oh/yr 966

Gas,Non-CooldngPtlote.l0000ti/yr 0 Gas,Non-CooldngPllota,l0008tr/yr 0 SENSITIVIIY SensItIvIty 75% -0.14 0.38

Gas,$.NCleen,l000Btu/yr,4Cyclea 173 Gaa,SellCleen,l0000tu/yr,4Cycles 173 toRrst 65% -0.16 0.32

Gas,Total Us., l0000tu/yr 1129 GiaTotal Use, l0009tu/yr 1,139 GAS COST An Say, S BR/Cat Cost 120% -0.26 0.22

150% -0.35 0.18

Elechtctty, Annual Cooldng Use, k%Mr/yr 29.2 Elechlctty, Annual Cooldng Use, W.hfyr 29.2 SenalIMty 50% -0.22 0.22

ElectrIcIty, ClOCk, IMr/yr 31.5 ElectrIcIty, Clock, kWh/yr 31.5 to Gas 120% -0.19 0.32 GAS QUANTITY An Say, $ EliCit

ElectrIcity, Sell Clean, kM,Nr, 4 Cycles 0.7 ElectrIcity, Sell Clean, kWhA,r, 4 Cycles 0.7 Cost

ElectrIcity, Total, kWh/yr 81.5 ElectrIcity, Total, kWh/yr 81.5 . SmeilIty 80% -0.22 0.22

APPUANCEUFE AnSav,$ BIt/Cut toAnrount 125% -0.19 0.34

Energy, Annual Cooldng Use, 1000 GlUtI 1,056 Energy, Annual Cooldng U., 1000 Btu/yr 1,066 at Gas, 150% -0.17 0.40

Cooldng Ettlcl.ncy 7.20% Cooldng Elllclsncy 713% SursltMty -2 -0.23 0.25 Baaa& 165% -0.16 0.44

Energy,TotalAnnualUae,lO00Btu/yr 1,338 En.rgy,TotalAnnu.lUae,tO00Btu/yr 1,349 toYrs.Llte 2 -0.19 0.29 ModIfied 215% -0.12 0.58

Energy Fector 5.68% Energy Feclor 5.84% Change

Year 1997 1998 1999 2000 2001 2002 2003 2004 2005 2008 2007 2008 2009 2010 2011 2012 2013 2014 2015 2018 2017

MODIFiED RANGE

Installed Cost, Aoldtlonal 3.15

Maintutence Cost 0.00 1.52 1.52 1.52 152 1.82 1.62 3.19 5.01 8.19 10.47 13.85 15.93 19.11 20.93 22.30 23,21 24.57 24.57 0.00

AnnuelNakrrelGesCost 7.00 7.25 7.44 7.50 7.88 790 7.92 8.05 6,18 6.33 8.47 8.61 8.76 8.92 9.08 9.25 9.41 9.58 9.70 0.00

AnnuelElectrIcityCost 4.90 4.94 4.96 8.03 8.08 5.13 5.16 5.23 5.30 5.38 5.45 5.53 5.81 5.63 5.65 5.68 5.70 8.72 5.74 0.00

TolalCoete 3,15 11.96 14.01 14.25 14.41 14.58 14.75 14.92 16.48 18,49 21.59 24.39 27.80 30.30 33.68 35.60 37.22 38.31 39.87 40.00 0.00

BASE CASE RANGE

Malnt.,enceCoet 0.00 1.82 1.82 1.82 112 112 112 3.19 5.01 8.19 10.47 13.85 15.93 19.11 20.93 22.30 23.21 24.57 24.57 0.00

AnnuelNakiralGesCost 7.13 7.32 7.51 7.63 7.75 7.87 6.00 6.t2 8.20 6.40 8.55 6.70 6.85 9.00 9.17 9.33 9.50 9.87 9.79 0.00

AnnuilElectricltyCost 4.90 4.94 498 5.03 5.08 5.13 5.18 5.23 5.30 5.38 5.45 5.53 5.81 5.83 5.65 5.68 5.70 5.72 5.74 0.00

TotalCoets 12.03 14.08 14.32 14.46 14.65 14.82 15.00 16.54 18.57 2197 24.47 27.86 30.36 33.74 35.75 37.30 38.40 39.90 40.09 0.00

IESILIS

N.tSevlngs,ModlkdRang. -3.15 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.08 0.08 0.06 0.08 0.08 0.08 0.08 0.08 0.09 0.09 0.09 0.09 0.00

(a) filnilalcost posItive, n*t present Vaki. 01 Itur. saitngaflnlllelcoet; II hittlalcoetnegsliv., Inilal savtnga/NPV of future costs. DATABET No. A-S (DCE-2)

EE-RM-90-201 COMMENT OOR13

Table A-12. Improved Door Seals--Self-Cleaning Oven 

COST CAlCUlATION DOLlARS ASSUMPTIONS RESUlTB @8%Dlsc. RI. 

AI CaIcuIoHon. ar.1n Conllanll D90 Dollo .. Fu.1 ColI Bcenallo DOE, _donlal, ReI. COla Annualled Not Sav. -0.21 Sf'lr DISCOUtoIT MTE An Sov,S Bft/CII Dlocoun1 Ral. (Ral~ 8.0% Benonl/Cosl( 0) 0.27 

MODIFIED MNGE Applance UIit, Y .... 18 Inlml Ral. of Rellm -8.3% Bon.IU'II1y 2.0% -0.12 0.38 

Mark Up from Manula::turfng ColI 2.81 Simple Paybl!Ck Nover to Dlsc'nl 7.0% -0.23 0.25 

Added Inllalled ColI, S 3.15 Net Energy Saved 11 kBtuf'lr Rala 15.0% -0.43 0.14 

BASE CASE MNGE Annualzed Ga. Sav. 0.085f'1r 

Malnlonance ColI, S, NPV@ 8% e8.05 MaIn1ononca ColI, S, NPV@ 11% a8.05 FIRST COST An Bav,S Bft/CII G •• , Annu.1 Cooldng Us., 1000 BlJf'lr 1158 GI., Annual Cooldng Usa, 1000 BlJf'lr 

Ga., Non-Cooldng Pilot., 1000 BlJf'lr 0 Ga., Non-CooIdng Pilot., 1000 BlJf'lr -0 SENSITIVITY Bonoltlvlly 75% -0.14 0.38 

Ga., S •• Clean, 1000 FJluf'lr, 4 Cycloo 173 Ga., Sa. Clean, 1000 FJluf'lr, 4 Cycloo 173 10RrIII 85% -0.18 0.32 

Ga., Talil Usa, l000FJluf'lr 1,1211 Ga., Talil Us., l000FJluf'lr 1,138 GAS COST AnSav, S Bft/CII ColI 120% -0.28 0.22 

150% -0.35 0.18 

Eloctolclly, Innull Cooldng Us., -f'lr 211.2 Eloctolclly,lnnual Cooldng Us., _f'lr 211.2 SonolH'II1y 80% -0.22 0.22 

Eloctolclly, Clock, kWhf'lr 31.5 Eloctolclly, Clock, kWhf'lr 31.5 loG .. 120% -0.18 0.32 GAS QUANTITY AnSDV,S Bft/CII 

Eloctolclly, BoW Clean, kWhf'lr, 4 Cycle. 0.7 Eloctolclly, Bo. Clean, kWhf'lr, 4 Cycloo 0.7 Coli 

Eloctolclly, Talll, kWhf'lr 81.5 Eloctolclly, ToIal, kWhf'Ir 81.5 BonIllU'II1y 80% -0.22 0.22 APPUANCE UFE AnSav,S Bft/CII 10l\mount 125% -0.18 0.34 

Enargy,lnnualCooldng Usa,I000FJluh 1,058 Enorgy,lnnu.1 Cooldng Usa, 1000 FJluf'lr l,ose olGa., 150"'- -0.17 0.40 

Cooldng Efllcloncy 7.20% Cooking Efllcloncy 7.13% SonollJvlly -2 -0.23 0.25 Ba.o& 185% -0.18 0.44 

Energy, Tallllnnu.1 Usa, 10Q) FJluf'lr 1,338 Energy, Talallnnu.1 Usa, 10Q) FJluf'lr 1,348 10 Y ... UIit 2 -0.18 0.211 Modlfted 215% -0.12 0.58 

Energy Foetor 5.88% Energy Foe .... 5.84% Chang. 

> Year 1997 1_ llK111 2000 2001 2002 2003 2004 2005 2008 2007 2008 200Q 2010 2011 2012 2013 2014 2015 2018 2017 I 

..... 

~ 

MODIFIED RANGE 

Inllolled ColI, AcIdItonal 3.15 

Malnlononca ColI 0.00 1.82 1.82 1.82 1.82 1.82 1.82 3.18 5.01 8.18 10.47 13.85 15.83 18.11 20.93 22.30 23.21 24.57 24.57 0.00 

AnnUli NOllral GI. Cool 7.011 7.25 7.44 7.58 7.88 7.80 7.92 8.05 8.18 8.33 8.47 8.81 8.78 8.92 8.08 8.25 8.41 8.58 8.70 0.00 

Annual Eloctolclly ColI 4.80 4.84 4.88 6.03 5.08 5.13 5.18 5.23 5.30 5.38 5.45 5.53 5.81 5.83 5.85 5.88 5.70 5.72 5.74 0.00 

TalolCool1 3.15 11.l1li 14.01 14.25 14.41 14.58 14.75 14.92 18.48 18.48 21.88 24.38 27.80 30.30 33.88 35.88 37.22 38.31 39.87 40.00 0.00 

BASE CASE MNGE 

Malnlononc. ColI 0.00 1.82 1.82 1.82 1.82 1.82 1.82 3.18 5.01 8.18 10.47 13.85 15.83 18.11 20.83 22.30 23.21 24.57 24.57 0.00 

Annual Noll,"1 Go. ColI 7.13 7.32 7.51 7.83 7.75 7.87 8.00 8.12 8.28 8.40 8.55 8.70 8.85 8.00 8.17 8.33 8.50 8.87 8.78 0.00 

Annuli Eloctolclly ColI 4.80 4.84 4.88 5.03 5.08 5.13 5.18 5.23 5.30 5.38 5.45 5.53 5.81 5.83 5.85 5.88 5.70 5.72 5.74 0.00 

ToIalCooII 12.03 14.011 14.32 14.48 14.85 14.82 15.00 18.54 18.57 21.117 24.47 27.88 30.38 33.74 35.75 37.30 38.40 38.l1li 40.011 0.00 

REBUlTS 

Net SloAngl, ModIIed Rang. -3.15 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.011 0.011 0.011 0.011 0.00 

(0) "1nIlllcoll poolllva,nlll praoont •• ". 01 MIl .. lOoAngI/inlUolcool;" lnIHalcoolnagBllve,lnIlollOoAngl/NPV 01 MII,a cool •. DATASET No. A-8 (DOE-2) 08/21VD4 
Table A-13. Forced Convection added to Standard-Plus-Electric Ignition- -Standard Oven

COST CALCULATION DOUAT ASSUMPTIONS llESUT.TS @6% DIsc. Pt.

N Celouletlons er.lo Constant 1990 Dollars Fuel Cost Scsneo DOE, Resldeilel, P01. Case Annustzed Net S.v. -14,61 S/yr DISCOUNT RATE An 8ev, S Bit/Cit

Discount Rate (Res 6.0% Benallt/Cost(a) NA

MODW1EDRANGE ApplsnceLfle,Years 19 kitntlRet.otRetjm NA SeistlIvity 2.0% -11.42 NA

MskL,tromManutsctirtngCoat 2.81 SlmplaPaybsck Never loDtsc'nt 7.0% -15.55 NA

Added Installed Cost, $ 131.12 Nat Energy Saved 66 kBtu/yr Rat. 15.0% -23.43 NA

BASE CASE RANGE Annudzed Gas 5ev, 0.55 S/yr

Malnt.ience Cost, 5, NPV@ 5% 125.34 Malntaw.nce Cost, S. NPV@ 6% 89.05 FiRST COST An 8ev, S Bit/Cit

Gas Annual Cooldng Use, 1000 Bti/yr 1,127 Ga., AnnualCooldng Use, l000B*i/yr 1,204

Gsa,Non-CooldngPllol$,l000Bth/yr 0 Gaa,Non-CooldngPllots,t000Bti/yr 0 SENSIITVITV Si&tMty 75% -11.73 NA

Gs.,Se8Cl.en,l000Btu/yr,OCycIes 0 Gsa,SellCIean,l000Btu/yr,OCyclea 0 toFlrst 65% -12.90 NA

Ga., Total Use, 1000 Btu/yr 1.121 Ge., Total Usa, 1000 Btu/yr 1,204 GAS COST An 8ev, S Bit/Cat Coat 120% -17.02 NA

150% -20.54 NA

Elactklty, AnnualCooldng Use, kwh/yr 31.7 Elsctlclty, AnnuelCooldng Use, W*i/yr 29.2 SmoltKIty 60% -14.76 NA

EI.CtdCfty, Clock, kwh/yr 0.0 Elsct4clly, Clock, kwh/yr 0.0 to Gas 120% -14.58 NA GAS QUANTITY An 8ev, S Bit/Cal

Electklty, 8e8 Clean, kWh/yr. 0 Cycles 0.0 EISCtIICIIy, 8.8 Clean, kWh/yr, 0 Cycles 0.0 Coat

Electtlctty,Totsl,kWh/yr 31,7 Elsctdclty,Totel,kwh/yr 29.2 Sanstitty 60% -14.76 NA

APPUANCE UF An Ssv, S Bit/Cit to Miount 125% -14.53 NA

Energy, Annual Cooldng Use, l000Btu4 1238 Energy, Annual Cooldng Use, 1000 Btu/yr 1.304 Gas, 150% -14.39 NA

Cooldng Efficiency 6.15% CoOIdng Efficiency 5.63% Seidthlty -2 -15.65 NA Bes.& 165% -14.31 NA

Energy, Total Annual Ut., 1000 Btu/yr 1,236 Energy, Total Annual Use, 1000 Blu/yr 1,304 to Yr.. UI. 2 -13.89 NA ModIfied 215% -14.03 NA

Energy Fsctor 8.15% Energy Foctor 5.63% Change

Year 1997 1908 1009 2000 2001 2002 2003 2004 2005 2008 2001 2008 2009 2010 2011 2012 2013 2014 2015 2018 2017

MODIFIED RANGE

Installed Coat, Addtlon.l 131.12

MalntenanceCost 0.00 1.82 1.62 1.62 1.62 1.82 1.62 3.19 5.01 73.19 10.47 13.65 15.93 tOll 20.93 22,30 23.21 24.57 24.87 0.00

Mnu.lNstjralGaaCost 7.08 7.24 7.44 7.55 7.67 7.79 7.91 6.04 6.16 832 8.46 8.51 8.15 6.01 9.07 9.24 9.40 9.57 9.69 0.00

Annual El.cttlclty Cost 2.53 2.55 2.57 2.80 2.62 2.65 2.67 2.70 2.74 2.76 2.62 2.86 2.90 2.91 2.92 2.93 2.94 2.95 2.96 0.00

TotalCo.t$ 131.12 9.50 11.62 11.53 11.97 12.11 12.26 12.41 13.92 15.92 84.26 21.74 25.l1 27.58 30.03 32.02 34.46 35.55 37.10 37.22 0.00

BASE CASE RANGE

MaIntenance Cost 0.00 1.62 1.62 1.62 1.62 1.62 1.62 3.19 5.01 6.19 10.47 l3.65 15.93 19.11 20.03 22.30 23.21 24.57 24.51 0.00

AnnualNakiralGasCost 7.54 7.74 7.94 8.07 6.19 6.32 6.45 8.58 8.73 6.68 9.03 0.19 9.35 9.52 9.69 9.66 10.04 10,22 10,34 0.00

Annual Electddty Cost 2.33 2.35 2.37 2.39 2.42 2.44 2.46 2.49 2.52 2.56 2.59 2.63 2.67 2.68 2.80 2.70 2.71 2.72 2.73 0.00

TotslCoeta 9.87 11.91 12.13 12.26 12.43 12.58 12.74 14.26 16.28 10.63 22.09 25.47 21.94 31.31 33,31 34.68 35.06 37.51 37.64 0.00

8LLTS

N.t8evtngs,Modlfi.dPengS -131.12 0.26 0.20 0.30 0.31 0.31 0.32 0.33 0.33 0.34 -64.55 0.35 0.36 0.37 0.38 0.39 0.40 0.41 0.42 0.42 0,00

U'

(a) Bkflulcost posItIve, net pr.s.lt vekia of future aedngsftitlatcoet: If Inltlafcoetn.gtdv., InitIal ae.fngs/NPV ci tuture colts. DATASET No. A-a (DOE-i) 03126'04

EE-RM-90-201 COMMENT OOR13
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Table A-14. Reduced Vent Rate- -Standard Oven COST CALCUlATION DOLLARS ASSUMPTIONS AESUl TS @ 8.,. DlI<:. RI. AI! Cll:uI.lHan. areln Canll."t 1990 Dollaro Fuel ColI Seenldo DOE, Relddon'ol, Ref. Ca .. Annualzed Net a.v, -0.38 Slyr D

Dll<:ount Rala 8.0% Benonl/CoII( 0) 0.12 MODIAED RANGE Aflplance 1JIe, v .... 10 Intml Rail of Re\Jm -12.1'" Sen

M.rt< Up 110m MonuIlC!urlng ColI 2.81 Simple POybllCk Novar to 

Added In .. allad ColI, S 4.58 Net Enargy Saved 7 kBtulyr Ra

BASE CASE RANGE Annual!ed Gaa Sav. 0.05 Slyr 

Malntenanco ColI, S, NPV@ 8% 0.00 Maintenance ColI, S, NPV@ 8% 0.00 

G •• , Annu.1 Cooking lIM, 1000 Blllyr 1,277 G •• , Annual Cooking lIM, 1000 Blllyr 1,284 

Gil, Non-Cooking Pilot., 1000 Blllyr 1,508 GI., Nan-Cooldng Pilot., l000Blllyr 1,508 SENSITMTY So

Gao, 801 CIe.", 1000 Btulyr, 0 Cyc"," 0 G •• , 80' CIe.", 1000 Btulyr, 0 Cyc"," 0 to 

Ga., Total u.., l000Btulyr 2,788 Ga., Total lIM, l000Btulyr 2,702 GAS COST MSa.,S Bft/CII CO

SonldHvIty 80% -0.37 0.00 

toG •• 120% -0.35 0.14 

ColI 

Se

APPUANCE UFE MSa.,S Bft/CII toA

Enorgy, "'nual Cooking Ut., 1000 Btull 1,277 En.rgy, Innu II Cooking lIM, 1000 Btulyr 1,284 ol

Cooking Efttcloncy 5.115% Cooking Efttcloncy 5.1I2'JIo 80nldHvIty -2 -0.30 0.11 B .

Enorgy, Toiallnnual lIM, 1000 Btulyr 2,788 Energy, ToIlllnnull u.., 1000 Btulyr 2,702 toVro.1JIe 2 -0.34 0.12 M

Energy Fetor 2.73% Energy Fetor 2.72% Olanga 

Y.ar 1l1li7 1l1li8 ,_ 2000 2001 2002 2003 2004 2005 2008 2007 2008 2000 2010 2011 2012 2013 

MODIFIED RANGE 

Inlllllad ColI, AddHonol 4.58 

Mllntenanco ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annual No'"al Ga. ColI 17.44 17.90 18.37 lB.88 18.115 10.25 10.55 10.88 20.20 20.55 20.90 21.27 21.83 22.02 22.42 22.82 

Annuli EIoc1I1cHy ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

ToillCoItI 4.58 17.44 17.90 18.37 18.88 18.115 19.25 10.55 19.88 20.20 20.55 20.90 21.27 21.83 22.02 22.42 22.82 

BASE CASE RANGE 

Mllntenance ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annuli NI'"al GI. ColI 17.48 17." 111.42 18.71 10.00 10.30 10.80 10.01 20.25 20.80 20.115 21.32 21.88 22.07 22.47 22.88 

Annuli EIoc1I1cHy ColI 0.00 0.00 0,00 0.00 0.00 0,00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

ToillCoIt. 17.48 17." 18.42 18.71 10.00 10.30 10.80 10.01 20.25 20.80 20.115 21.32 21.88 22.07 22.47 22.88 

FE8ULTS 

Net Saving" ModttIod Rango -4.58 0.04 0.04 0.04 0.04 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 

(I) "1nt1.1 cool pool1lw, net p.....,t .1". of future aavingl/lnlttaICOlt;" 1nItI.lcoot nogllllva,lnIlallOvingl/NPV of futuro co.t •. DATASET N
Table A- 15. Reflective Surfaces--Chrome -Plated Oven Cavity- -Standard Oven

COST CALCULATION DOLLARS ASSUMPTIONS ESI.&TS @5%DI.c. RI.

N CalculatIons areln Constant l0900oItar. FUel Colt 8c.nido DOE, R..IdalaI, Rat. Case Annusized Nat Say, -415 S/yr DISCOUNT RATE An Say, $ BR/Cat

DIscount Rate (R.a 6.0% Bsrrel%I/Cost(a) NA

MODIFIED RANGE Applance Ut., Year. 19 InIfnI Rate 01 Retjrn NA Sanllthity 2.0% -4.78 NA

Uadc , 1mm Manulscturtng Colt 2.81 8tmpIo Paybsclc Never to Dlsc'nt 7.0% -6.52 NA

Added Installed Cost, $ 53.68 Net Energy Sav.d -185 IcEtu/yr Rat, 15,0% -9.95 NA

BASE CASE RANGE Annusized (3cc 8.1. -1.33 S/yr

Malntanance Coat, S. NPV@ 8% 0.00 Matntanance Cost, 5, NPV@ 8% 0.00 FIRST COST An SCy, S BR/Cat

Gas, Nsiual Cooldng Us., 1000 Bti/yr 1.469 Gas, Annual Cooldng U.., 1000 Bli/yr 1284

8ENSIflV1TY SansltNtty 75% -4 94 NA Gas, Non-Cooldng PRota, 1000 Bl/yr 1,508 Gas. Non-Cooldng PIlot., 1000 851/yr 1,506

. toRrat 85%

.

-5 42 NA Ga.,8.WCI.an,1000BtU/yr,OCyClSl 0

2 978

Gas,8.VCIean,100001u/yr,OCycl.s

Gea Total Use l000Btu/yr

0

2 792 GAS COST An Say, S BEt/Cat Coat 120%

.

-7.11 NA G..,ToIuI Us., i000Btufyr , , .

,

150% -8.55 NA

8.tsItIfty 80% -5.85 NA

to Gas 120% -6.41 NA GAS QUANTITY An 8ev, $ BR/Cat

Coat

SeisIlivIty 80% -5.68 NA

APPLIANCE UFE An Say, S BR/Cat to Amount 125% -5.45 NA

Energy, Annual Cooldng Us., 1000 Btu/ 1,489 Energy, Annual Cootdng U.., 1000 BIU/yr 1,284 of Gas, 150%

165%

-5.81

7 01

NA

NA Cooldng EftcI.ncy 5.17% Cooldng Effldsncy 5.92% SeisItMty -2 -8.44 NA Bee. & - .

En.rgy,TotelMnualUse,lO00BtUNr 2,918 En.rgy,ToIsIPnnuaIUae,10008tu/yr 2,792 toYrs.Ufa 2 -5.91 NA ModIfIed 215% -1.68 NA

Energy Fsctor 2.55% Energy Fsctor 2.72% Change

Y.pr 1991 1998 1099 2000 2001 2002 2003 2004 2005 2006 2007 2005 2009 2010 2011 2012 2013 2014 2015 2018 2017

MODIFIED RANGE

Inata0sd Cost, AddItIonal 53.68

0 00 0 00 0 00 0 00 0 00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 M&nterance Cost

AnnualNatIralGacCoit

.

15.54

.

19.13

.

19.64

.

19.95

.

20.26 20.58 20.90 21.23 21.59 21.97 22.34 22.73 23.12 23.54 23.96 24.39 24.83 25.28 25.55 0.00

Annual ElscIllctty Cast 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0,00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TotalCoata 53.68 18.64 19.13 19.54 19,95 20.26 20.56 20,00 21.23 21.59 21.91 22.34 22.13 23.12 23.54 23.95 24,30 24.83 25.26 25.58 0.00

BASE CASE RANGE

0 00 0 00 0 00 0 00 0 00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Milntanance Cost .

17 48

.

17 94

.

18 42

.

18 71

.

19 00 19.30 10.60 19.91 20.25 20.50 20.05 21.32 21.58 22.07 22.41 22.88 23.29 23.71 23.99 0.00 AnnuelNataratGiaCo$t .

0 00

.

0 00

.

0 00

.

0 00

.

0 00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 AwualElsctiicttyCoet .

17 48

.

17 94

.

15 42

.

18 11

.

19 00 19.30 19.60 19.91 20.25 20.50 20.95 21.32 21.68 22.07 22.47 22.88 23.29 23,71 23.99 0.00

TotalCosts . . . . .

IEBULTS

Nst8avlngs,UodIfISdRange -53.68 -1.16 -1.19 -1.22 -1.24 -1.26 -1.26 -1.30 -1.32 -1.34 -1.37 -1.39 -1.41 -1.44 -1.46 -1.49 -1.52 -1.55 -1.57 -1.59 0.00

a) If Inlial cost poiflive, nat pr.sant vatz. of future sevtngsflnttlalcoet; If InitIal co.tn.gilIw, Inlial saWcge/NPV of futurocosta DATA BET No. I-i (C-i) 05/28/94

EE-RM-90-201 COMMENT OOR13
Table A-16. Reflective Surfaces- -Chrome-Plated Oven Cavity- -Self-Cleaning Oven

COST CALCLAAIION DOLLARS ASSUMPTIONS IESULTS @8% DIsc. RI.

Alt CalouMons are In Constant 1990 Dollars Fuel Cost ScenarIo DOE, Reildanlal, Rat Ca,. Annualz.d Net 9ev. -5.74 $,r DISCOUNT RATE An Say, $ 86/Cat

DIscount Rats (Ream 0.0% BeneItlJCost(a) NA

MODIF1EDRANGE AçrplwrceUte,Yoars tO hrlinlRateofRetjm NA BelsItMty 2.0% -4.31 NA

Ma frnManutscturlng Cost 2.81 SlmplePaybsck Never toDtic'nt 7.0% -6.12 NA

AddedInstalledCost,$ 53.66 NetEnergysavad -l29kBtutyr Rate 15.0% -9.55 NA

BASE CASE RANGE Annusized Gas 9ev. -0.03 fI'

Malntgaance Cost, $, NPV@ 6% 89.05 Maintuiance Cost, 8, NPV@ 6% 80.05 FiRST COST An Say, $ 86/Cit

Gas, Annual Cooldng Ui., 1000 B%rn,r 1,095 Gas, Annual Cooldng Us., 1000 Bti/yr 066

Ga., Non-Cooldng PIlots, 1000 Bt/yr 0 Gas, Non-CookIng PIlotS, 1000 Bkrnr 0 SENSItIViTY Sonsltlvfty 75% -4.54 NA

Gas,8.tVClean,10008tU4'r,4CyCIes 173 Oas,8eNCl.an,10008tucr,4Cyctes 173 . toFlrst 85% -5.02 NA

Gas, Total Use, 1000810/yr 1268 Gas,Total Use, l000Blu/yr 1,130 GAS COST An Say, $ 86/Cit Cost 120% -8.70 NA

150% -8.14 NA

ElectrIcIty, Annual CookIng Use, ttr/yr 29.2 EIsCtItCtty, Annual CookIng Use, kYlti/yr 20.2 Sanaltlntly 80% -5.55 NA

ElectrIcIty, Clock, kYh/yr 31.5 ElectrIcIty, Clock, kWtr/yr 31.8 to Gas 120% -5.92 NA GAS QUANTITY An Ssv, $ 86/Cat

ElectrIcIty, Sell Clean, lTh/yr, 4 Cycles 0.7 ElectrIcIty, Bitt Clean, kYh/yr, 4 Cycles 0.1 Cost

Electrlclty,Total.lMh/yr 61.5 ElactrIclty,Iotsl,kYm/yr 61.8 Sonslth4ty 80% -5.55 NA

APPUANCE UPS An Say, S 86/Cit to Amount 125% -5.97 NA

Energy, MnuslCooldng Us., t000Blu 1,105 Energy, nnualCooldng Us., l0008tu/yr 1,066 of Ga,, 150% -6.20 NA

CooldngElltctency 6.36% CooldngElllclency 7.13% SasltItty -2 -0.04 NA Base& 165% -634 NA

En.rgyTotalMnualUse, lO00Btu/yr 1,477 En.rgy,Tot.lMnuelUse. 1000810/yr 1,349 loYrs.LJt. 2 -5.50 NA ModIIt.d 215% -6.80 NA

Energy Fectoq 5.15% Energy Fector 5.64% Change

Year 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2001 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

MODIFIED RANGE

Instated Cost, Addtlonal 53.68

MaIntenance Cost 0.00 1.62 1.82 1.82 1.82 1.02 1.82 3.19 8.01 8.19 10.47 13.05 15.93 19.11 20.93 22.30 23.21 24.57 24.57 0.00

AnnualNatiralGaaCoet 7.94 8.15 8.36 8.40 8.63 8.76 8.90 9.04 9,19 0.35 0.51 9.68 9.84 10.02 10.20 10.39 10,57 10.70 10.89 0.00

AnnualElectitclty Cost 4.90 4.94 4.08 5.03 5.08 5.13 5.18 5.23 5.30 5.38 5.45 5.53 5.61 5.83 5.65 5.86 5.10 5.72 5.14 0.00

TotalCosta 53.60 12.84 14.91 15.16 15.34 15.53 15.71 15.00 17.45 19.50 22.02 25.43 28.86 31.38 34.76 36.78 38.36 39.48 41.05 41.20 0,00

BASE CASE RANGE

Malnt.nanceCoet 0.00 1.82 1.62 1.02 1.82 1.82 1.82 3.19 5.01 8.19 10.47 13,05 15.93 19.11 20.93 22.30 23.21 24.51 24.57 0.00

MnualNa*iralGasCost 7.13 7.32 7.51 7.03 7.75 7.87 8.00 8.12 8.26 8.40 8.55 8.70 0.85 9.00 0.17 9.33 0,50 0.67 0.70 0.00

AnnuslElectddty Cost 4.00 4.94 4.98 5.03 8.08 5.13 5.10 5.23 5.30 5.38 5.45 5.53 5.61 5.63 5.65 5.68 5.70 5.72 5.74 0,00

TatalCost. 12.03 14.08 14.32 14.40 14.65 14,82 15.00 16.54 18.57 21.01 24.47 27.08 30.38 33.74 35,75 31.30 38.40 39.96 40.09 0.00

rESULTS

Net5anlrrgs,ModllledRange -53.68 -0.81 -0.83 -0.85 -0.86 -0.88 0.89 0.00 0.92 -0.93 0.95 -0.97 0,98 1.00 1.02 1.04 -1.05 -1.01 1.09 1.11 0.00

(a) Illnliatcost posItIve, n.tpr.sait vaIn. otluture eallngslWtlalcoet; If lnltlalcostn.getlve, InIIaI santngs/NPV of lutur.cOsta. DATA SEt' No.1-3 (from I-i) 08/28'94

EE-RM-90-201 COMMENT OOR13

Table A-16. Reflective Surfaces- -Chrome-Plated Oven Cavity- -Self-Cleaning Oven 

COST CAlClAATION DOLlARS ASSUMPTIONS FESULTS @6"'Dlsc. RI. 

AIICal:ulollan. a .. In Conllant l1K1ODoIla ... Fuel Cool 8cGn.~a DOE, Anld..,lal, RIll. Co .. Annualzed NoISa •. -5.74 Styr DISCOUNT RATE AnSa., S BftJCII Dlscounl Rale (Raa~ 6.0% eeneftl/Call( a) NA 

MODIFIED RANGE Appl""". ute, Vaa ... 10 Inlml Rala of Ralum NA B..,oIUIoiIy 2.0% -4.37 NA MarkUp from Menu1lC\Urtng Cool 2.81 Simple Paybll:k N_r 10 Dlac'nl 7.0% -6.12 NA 

Add .. Inllalled Cool, S 53.116 Nol Energy Saved -120 kBlutyr Ral. 15.0% -9.55 NA 

BASE CASE RANGE Annuolzed Ga. Sa •. -0.93 Styr 

Maln1..,...,. Cool, S, NPV@ 6'" 60.OS Maln1..,...,. Cool, S, NPV @ 6'" 60.OS ARSTCOST An Ba.,S BftJCII 

Ga., Annual Cooldng u.., 1000 BtJtyr 1,095 GI., Annual Cooldng u.., 1000 BtJtyr gee 

Ga., Nan-Cooldng Pilat., 1000 BtJtyr 0 Gal, Nan-Cooldng Pilat., 1000 BtJtyr 0 BENSrrMTY SlI101UIoity 75'" -4.54 NA 

Ga., Sell Clean, 1000 Blutyr, 4 Cyclel 173 Ga., BaN Clean, 1000 Blutyr, 4 Cyclel 173 10 Am 65'" -5.02 NA 

Ga., ToIII u.., l000Blutyr 1,286 Ga., Tolal u.., l000Blutyr 1,130 GAS COST AnSa., S BftJCII Cool 120'" -6.70 NA 

150'" -6.14 NA 

ElecloIdIy, hlnual Cooldng U.s, INthtyr 20.2 ElecloIdIy, Annual Cooking u.., INthtyr 20.2 SlI101t1loity BO% -5.55 NA 

ElecloIdIy, Clack, INIhtyr 31.5 ElecloIdIy, Clack, INIhtyr 31.5 laG •• 120'" -5.02 NA GAS QUANTITY AnSa., S BftJC.1 

ElecloIdIy, Bd CIeIltl,lNIhtyr, 4 Cyclel 0.7 ElecldcIIy, Sd Clean, INIhtyr, 4 Cyclel 0.7 Call 

ElecloIdIy, ToIal,lNIh/yr 61.5 ElecloIdIy, T oIal, INIhtyr 61.5 S..,oIU1oity BO% -5.55 NA APPUANCE UFE AnS •• , S BftJCII 10 Amount 125'" -5.07 NA 

Energy, Annu II Cooldng u.., 1000 Bluh 1,105 Energy, hlnuslCooldng u..,l000Blutyr 1,0118 olGa., 150% -6.20 NA 

CookIng Ellidency 6.36'" Cooldng Ellidency 7.13'" S..,oItiloity -2 -e.o4 NA ea •• & 165'" -6.34 NA 

Energy, Tolal hlnual u.., 1000 Blu/yr 1,477 Energy, ToIllhlnualu..,loooBlutyr 1,348 10 V .... Uta 2 -5.50 NA Madlfted 215'" -6.60 NA 

Energy Foelor 5.15'" Energy Foetor 5.64'" Chang. 

> Y •• , 11197 11196 1_ 2000 2001 2002 2003 2004 200S 2006 2007 2006 2000 2010 2011 2012 2013 2014 2015 2016 2017 I 

...... 

00 

MODIFIED RANGE 

Inllalled Cool, Adcttlanll 53.116 

MoInIlI1anc:e Cool 0.00 1.82 1.62 1.62 1.62 1.B2 1.62 3.10 5.01 6.19 10.47 13.65 15.03 10.11 20.03 22.30 23.21 24.57 24.57 0.00 

AnnUli NI .. rsl Gu Cool 7.94 6.15 6.36 6.40 6.63 6.76 6.90 0.04 8.10 0.35 0.51 0.116 0.64 10.02 10.20 10.30 10.57 10.76 10.60 0.00 

Annual ElecldcIIy Cool 4.90 4.94 4.98 5.03 5.08 5.13 5.16 5.23 5.30 5.38 5.45 5.53 5.61 5.63 5.65 5.116 5.70 5.72 5.74 0.00 

ToIliCooI. 53.116 12.64 14.01 15.16 15.34 15.53 15.71 15.90 17.45 10.50 22.02 25.43 26.116 31.38 34.76 38.76 38.38 30.46 nos 41.20 0.00 

BASE CASE RANGE 

Malnl..,...,. Cool 0.00 1.62 1.62 1.62 1.62 1.62 1.62 3.10 5.01 6.10 10.47 13.65 15.03 10.11 20.03 22.30 23.21 24.57 24.57 0.00 

Annuli Na .. ,.1 Gu Cool 7.13 7.32 7.51 7.63 7.75 7.67 6.00 6.12 6.26 6.40 6.55 6.70 6.65 8.00 0.17 0.33 0.50 0.67 0.70 0.00 

Annual ElecldcIIy Cool 4.90 4.94 4.98 5.03 5.08 5.13 5.16 5.23 5.30 5.38 5.45 5.53 5.61 5.63 5.65 5.116 5.70 5.72 5.74 0.00 

ToIllCooII 12.03 14.08 14.32 14.46 14.65 14.62 15.00 16.54 16.57 21.07 . 24.47 27.116 30.38 33.74 35.75 37.30 38.40 30.118 40.00 0.00 

FEBUlTB 

Net Baloing., Madtled Rang. -53.116 -0.61 -0.113 -0.85 -0.116 -0.116 -0.60 -0.90 -0.02 -0.03 -0.05 -0.87 -0.98 -1.00 -1.02 -1.04 -l.OS -1.07 -1.00 -1.11 0.00 

(I) "1I1I1al call p_, not praoant .a .. a oIlU1urs .aIoino./lnllfalcaal;" lnIUal caalnag_,lI1Ilaluloing./NPV oIlU1ure cotl •. DATA SET No. 1-3 (from 1-1) 06/28/94 
Table A-17. Added Insulation for the Cabinet Envelope- -Standard Oven

COST CALCULATION DOLI.ARS ASSUMPTIONS FESUCT9 @8% DIsc. RI.

N Cebilatlons ur.In Constant 1990 Dollars Fuel Cost Bcenaño DOE, R.sldanIaL Rat. Case Mnualzed Net 5ev. -1.77 5/yr DISCOUNT RATE An 5ev, $ BIt/Cit

DIscount Rate (Rea 6.0% 9.neIlt(Cost(a) 0.00

MODIFIED RANGE Applance Lila, Years 19 html Rate of RMim NA SanoitMty 2.0% -1.26 0.00

Mark Lt from Uwufscturtng Cost 2.81 SImpI. Paybsck Nevor to DIac'nt 7.0% -1.91 0.00

Added Installed Cost, S 19.79 Nat Energy Saved 0 k8tu/yr Rate 15.0% -3.19 0.00

BASE CASE RANGE Annua5zed Gsa 9ev. 0.00 S/yr

Melnlulanc. Cost, 5, NPV @8% 0.00 Nelntanance Cost, 5, NPV @8% 0.00 FiRST COST An 5ev, 5 911/Cit

Gee, Annual Cooking Us., 1000 Ott/yr 1,284 Gee, Annual Cooking Us., 1000 Bti/yr t,284

Gee, Non-Cooking Pilots, 10009W/yr 1508 Gee, Non-Cooking PIlots, 10009W/yr 1,508 SENSrFMTY SsnsllIrAly 75% -1.33 0.00

Gaa,8e6C1.an,l0008tu/yr,OCyclee 0 Gaa,SeMCla.n,t000Btu/yr,OCyclu 0 toRrst 85% -1.51 0.00

Gas, Total Us., 1000 8W/yr 2,792 Gas, Total Use, 10009W/yr 2,792 GAS COST An 9ev, S 911/Cat Cost 120% -2.13 0.00

150% -2.86 0.00

SeisltMty 60% -1.77 0.00

to Gas 120% -1.71 0.00 GAS QUANTITY An 9ev, 5 811/Cit

Cost

SmeltMty 80% -1.77 0.00

APPUANCE LIRS An 9ev, $ 811/Cat to Aroount 125% -1.77 0.00

Energy, Annual Cooking Use, 1000 9Wd 1,284 Energy, Annual Cooking Uae, 1000 9W/yr 1,284 olGa,, 150% -1.77 0.00

Cooking EfficIency 5.92% Cooking EfficIency 5.92% SanoltIvIty -2 -1.89 0.00 Base & 165% -1.71 0,00

Energy, Total Annual U.., 1000 9W/yr 2,792 Energy, Total Annual Lice, 10009W/yr 2,792 to Yrs. LII. 2 -1.86 0.00 Modified 215% -1.77 0,00

Energy Fsctor 2.12% Energy Fsctor 2.72% Change

Year 1Q91 1998 1999 2000 2001 2002 2003 2004 2005 2006 2001 2008 2009 2010 2011 2012 2013 2014 2015 2018 2017

MODIFIED RANGE

Installed Cost, Mdtlonal 19.19

Malntanance Coat 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

AnnualNatlrelGasCost 17.48 17.94 18.42 18.71 19.00 19.30 19,60 19.01 20.25 20.80 20.95 21.32 21.86 22.07 22.47 22.86 23.29 23.71 23.99 0,00

MnualElacttlctty Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TotalCoets 19.19 17.48 11.94 18.42 1811 10.00 19,30 1980 19.91 20.25 20.60 2005 21.32 21.66 22.01 22.47 22.86 23.20 23,11 23.99 0.00

BASE CASE RANGE

MaIntenance Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

AnnualNetiralGaaCost 17.46 17.94 18.42 ltlt 19.00 19.30 19.60 19.91 20.25 20.60 20.95 21.32 21.66 22.01 22.47 22.88 23.29 23.71 23.99 0.00

MnualEl.Ctclty Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 000 0.00 0.00 0.00 0.00 0.00 0.00

TotelColt, 17.46 17.94 18.42 18,71 19.00 10,30 19.80 19,91 20,25 20.60 20,95 21.32 21,68 22.07 22.47 22.86 23.29 23.71 23.99 0,00

FESUtIB

Net Savings, Modhkd Range -19.79 0.00 0.00 0.00 0.00 0.00 0,00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0,00 0,00 0,00 0.00 0.00 0.00

(a) lllolklcoet posItIve, net present vekie of tuture aavlnge/lnlttalcost; It Inltlalcostn.getve, Irrifat ae*rgs/NPV offuture costs. DATA SET No.8-8 06/24

EE-RM-90-201 COMMENT OOR13

Table A-17. Added Insulation for the Cabinet Envelope- -Standard Oven 

COST C"LCUlATION DOLLARS ASSUMPTIONS RESULTS @ 8'110 OtIC. RI. 

.... Clt:ulatton ..... In eonllanl I ggo 00111 .. Fuat ColI 8cenlolo DOE, _don la~ Ret. Call I\nnUlized Net S.v. -1.77 Styr DISCOUNT RATE MSOV, S Elft/CIt OtlCoun1 Rale (Re.~ 6.0'lI0 eonollt/COII(.) 0.00 

MODIFIED RANGE Applonce 1..118, v .... 111 Inlml Rala 01 Rellm N" S .... oiUvlty 2.0'lI0 -1.26 0.00 

M.r\( Up irani Monuf aclurtng COlt 2.81 SImple P'yblCk Naver 10 OtIC'nl 7.0'lI0 -!.III 0.00 

Added 1n1l.1Ied ColI, S 111.78 Net Ene'VY Saved o kBtutyr Rale 15.0'lI0 -3.111 0.00 

BASE CASE RANGE Annualzed Gal Say. 0.00 Styr 

Mllnlon"""" ColI, S, NPV@ 8'110 0.00 Mllntononce ColI, S, NPV@ 8'110 0.00 ARSTCOST MSOV,S Elft/CIt 

Gil, """"aI Cooking U.I, 1000 Blltyr 1,284 Gil, Annu.1 Cooldng u.., 1000 Blltyr 1,284 

Gil, Non-Cooking PIlot., 1000 Blltyr 1,508 G .. , Non-CookIng PIlot., lOOOBlltyr 1,508 SENSrrMTY SonoitMty 75'110 -1.33 0.00 

G •• , Bel Clean, 1000 Btutyr, 0 Cyc"," 0 Gil, 61. CIotan, 1000 Btutyr, 0 Cyc"," 0 loAm 85'110 -1.51 0.00 

Gil, ToIIl u.., l000Btutyr 2,7112 GI., ToIa' u.., 1000 Btutyr 2,7112 GAS COST MSOV,S Elft/CIt ColI 120'lI0 -2.13 0.00 

150'lI0 -2.M 0.00 

SonoitMty eO'!Io -1.77 0.00 

toG .. 120'lI0 -1.77 0.00 GAS QUANITITY MSev,S Elft/CIt COlt 

SonoitMty eO'!Io -1.77 0.00 

"PPUNoICE LIFE M6ev,S Blt/CIt lomounl 125'110 -1.77 0.00 

Ene'VY, ,.".., II Cooking U.o, 1000 Btul\ 1,284 En.rgy, ,."..,., Cooking U.e, 1000 Btutyr 1,284 01 G •• , 150'lI0 -1.77 0.00 

Cooking EfIlcIency 5.li2'ii0 Cooking El\lclency 5.li2'ii0 Sonoidvlty -2 -l.ell 0.00 ea •• & 165'110 -1.77 0.00 

Energy, Tol., Innual LIotI, 1000 Btutyr 2,7112 Enlrgy, ToIIllnnuo' LIotI, 1000 Btutyr 2,7112 10 V ... 1..118 2 -I.M 0.00 Modified 215'110 -1.77 0.00 

Energy Foetor 2.72'110 Energy Foetor 2.72'110 Chongl 

> V •• r 1l1li7 111M 

,_ 2000 2001 2002 2003 2004 2005 2008 2007 2008 200II 2010 2011 2012 2013 2014 2015 2018 2017 I 

..... 

\0 

MODIFIED RANGE 

Inltilled ColI, AddtIonII 111.711 

Mllnlon"""" ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annul' N .... rel G •• ColI 17.411 17.114 18.42 18.71 111.00 111.30 111.80 111.111 20.25 20.80 20.115 21.32 21.M 22.07 22.47 22.M 23.211 23.71 23.l1li 0.00 

Annu.1 EIlclIIdty ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

ToI.ICoota 111.711 17.411 17.114 18.42 18.71 111.00 111.30 111.80 111.111 20.25 20.80 20.115 21.32 21.M 22.07 22.47 22.M 23.211 23.71 23.l1li 0.00 

BASE CASE RANGE 

Mllnlon"""" ColI 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annul' N .... r.1 Gil ColI 17.411 17.114 18.42 18.71 111.00 19.30 111.80 111.111 20.25 20.80 20.115 21.32 21.M 22.07 22.47 22.M 23.211 23.71 23.l1li 0.00 

""""al EIlclIIdty Colt 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

ToII'Coota 17.411 17.114 18.42 18.71 111.00 111.30 lD.80 lD.1I1 20.25 20.80 20.115 21.32 21.M 22.07 22.47 22.M 23.211 23.71 23.l1li 0.00 

RESULT6 

Net Saving., ModIIIed Rang. -111.711 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

(.) "Inlt.1 cOlt pooltlw, net p .... ont v.lll 01 MIl ... IIv1ngl/lnllllICOlt;" lnIUal COlt nog_, InIla' IIv1ngl/NPV 01 MIl ... COlt •. D"T" SET No. E-8 06/2\V114 
Table A-18. Added Insulation for the Cabinet Envelope- -Self-Cleaning Oven

COST CALCULATION DOLLARS ASSUMPTIONS IESULT9 @8% DIsc. RI.

All Calculations arek, Constant 1990 Dollars Fuel Coat Sc.nao DOE, Residanlal, Ref. Case Annualzsd Net 8ev. -1.77 S/yr DISCOUNT RATE An 9ev, S Ott/Cat

DIscount Rate(R.. 6,0% Benefl/Cost(a) 0.00

MODIFEDRANGE AppIanceUle,Yeara 10 Intn,lRat.otRetjm NA SansitNtly 2.0% -1.26 0.00

MaL,fromManutsctuitngCost 2.81 BlmplePeybsck Never toDlec'nl 7.0% -1.91 0.00

MdialledCost,$ 19.79 NetEnargySav.d OkOtu/yr Rate 15.0% -3.19 0.00

BASE CASE RANGE Annualzed Gas 6ev. 0.00 S/yr

Maintanance Cost, 5, NPV@ 6% 89.05 Malntiance Cost, 5, NPV@ 6% 89.05 FiRST COST An 6ev, $ 88/Cat

Gas, Annual Cooldng Us., 1000 Ski/yr 066 Gas, Annual Cooldng Use, 1000 Ski/yr 966

GasNon-CooldngPllots,I000B8J4Ir 0 Gai,Non-CooldngPllots,l0008tI/yr 0 SENSITIViTY SetsltMty 75% -1.33 0.00

Gas,SetiClean,l000Btu/yr,4Cyclel 173 Gas,SeltClean,l000BIu/yr,4Cycl.s 173 toFlrst 85% -1.51 0.00

Gas TotalUse,l000OtuIyr 1,139 Gas,TotatUee,l0005tu/yr 1,130 GASCOST AnSav,$ 88/Cat Cost 120% -2.13 0.00 ,

150% -2.88 0.00

Electilcity, Annual Cooldng Use, l&,/yr 29.2 Electtlclty, Annual Cooldng Use, k%Mi/yr 26.2 SanaltMty 80% -1.77 0.00

ElectlcIty, Clock, lh/yr 31.8 Electilctty, Clock, Wih/yr 3I.5 to Gas 120% -1.77 0.00 GAS QUANTITY An 8ev, S Oil/Cat

Electilcity, 5.11 Clean, lh/yr, 4 Cycle. 0.7 EloctilcIty, Sell Clean, l411/yr, 4 Cycles 0.1 Cost

Ele.ctilclty Total, kWh/yr 81.5 Electilclty,Totsl, kWh/yr 81.5 Sansltl.4ty 80% -1.77 0.00,

APPUN4CE URS An 8ev, $ 88/Cat to Antount 125% -1.17 0.00

Energy, Annual Cooking Use lOGO Btu4 1,066 Energy, Annual Cooking Us., 1000 Ski/yr 1,068 at Gas, 150% -1.77 0.00

Cooking Elllclency 7.13% Cooldng Elllctsncy 7.13% Seisltlvtty -2 -1.80 0.00 Base& 165% -lii 0.00

Energy, Total Annual Use, lOGO Ski/yr 1,340 Energy, Total Annual Use, lOGO Btu/yr 1,349 toYrs. (it. 2 -1.86 0.00 ModIfied 215% -1.17 0.00

Energy Foctor 5.64% Energy Fector 5.64% Chang.

Veer 1991 lOGS 1099 2000 2001 2002 2003 2004 2005 2008 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

MODIFIED RANGE

h,stalled Cost, Addtlonal ¶9.79

Malntananc.Cost 0.00 1.82 1.82 1.82 1.82 1.82 l.82 3.19 5.01 8.19 10.47 13.65 15.93 lOll 20.93 22.30 23.21 24.57 24.57 0.00

Annual Natural Gas Coat 7.13 7.32 7.51 7.63 7.75 7.87 8.00 8.12 8.26 8.40 8.55 8.70 8.85 9.00 9.17 9.33 9.50 9.67 0.19 0.00

AnnualElectilclty Cost 4.90 4.94 4.98 5.03 5.08 5.13 5.18 5.23 8.30 5.38 5.45 5.53 5.6l 5.83 5.65 5.68 5.70 5.72 5.74 0.00

TotalCoeta 19.79 12.03 14.08 14.32 14.48 14.85 14.62 15.00 16.54 18.51 21.97 24.41 27.88 30.38 33.74 35.75 37.30 35.40 39.96 40.09 0.00

BASE CASE RANGE

Maint.,enceCost 0.00 1.82 1.82 1.82 1.82 l.82 1.82 3.19 5.01 8.10 10.47 13.65 ¶5.93 10.11 20.93 22.30 23.21 24.57 24.57 0.00

AnnualNatiralGasCost 7.13 7.32 7,51 7.83 7.75 7.87 8.00 8.12 8.26 8.40 8.55 8.70 8.85 9.00 9.17 9.33 9.50 9.67 9.10 0.00

MnualElectildtyCost 4.90 4.04 4.98 5.03 5.06 5.13 5.18 5.23 5.30 5.38 5.45 5.53 5.61 5.83 5.65 5.68 5.70 5.72 5.74 0.00

TotalCosta 12.03 14.05 14.32 14.48 ¶4.65 14.62 15.00 16.54 18.51 21.97 24.41 27.88 30.38 33.74 35.15 37.30 38.40 39.96 40.09 0.00

1SULT8

NetSavlngs,ModifiSdRsnga -19.70 0,00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

t)

0

(a) It Willal cost positive, net presult vakie of fiutur, ssvlngs/lnltlalcost; If Initial coatnegotlve. InihI .avlngs/NPV ottuturecosta. DATA SET No. E-9 00(28/94

EE-RM-90-201 COMMENT OOR13
Table A-19. 2" Insulation outside of Combustion Chamber- -Standard Oven

COST CAI.CtLATION DOUJBS AS8UMPTIONS I8UUIS @6% DIsc. RI.

U CalculatIons era In Ccnstant 1990 Dollar, Fuel Cost Scenaño DOE, Rsslde1aI, Rat, Case Annualied Net 8ev. -0.21 S/yr DISCOUNT RATE An 8ev, S Bit/Cat

Discount Rate (R.a 6.0% Beneftt/Cost(e) CM

MODIFIED RANGE Applance UI., Years 19 mImI Ratsof Retim -0.1% SaaItMty 2.0% -0.07 0.81

MsrkttromMa,u?scturlngCosI 2.51 Slrnplepsybsck Never toD(ec'nt 7.0% -0.25 0.52

Added lnstsfled Cost, $ 5.42 Nd Energy Saved 38 kB*u/yr Rate 15.0% -0.81 0.30

BASE CASE RANGE Annualzed Gas 8ev. 0.27 S/yr

Malnlaiancs Cost, 5, NPV @6% 0.00 Malntmance Cost, 5, NPV @6% 0.00 F1FIET COST An 8ev, S OIl/Cit

G.s,ArinualCooldng Use, 1000 Bti/yr 1,246 Gas, AnnuslCootdng Us, 1000 NJ/yr I,284

Gas, Non-Cooldng PIlots, 1000 8th/yr 1,508 Gas, Nan-Cooldng PIlots, 1000 Osi/yr 1,508 8ENSITMTY Sdth4ty 75% -0.09 0.75

Gss,SeSClsan,l0008tu/yr,OCyclss 0 Oas,8.NCIsan,1000Blu/yr,00yclss 0 toFlrst 85% -0.14 0.86

Gas,Totel Use, l0008tujyr 2,754 Gi., Total Use, l0008tu/yr 2,792 GAS COST An 8ev, S Blt/Cst Cast 120% -0.31 0.47

150% -0.45 0.38

8tslIMty 50% -0.27 0.45

to Gas 120% -0.16 0.88 GAS QUANTITY An 8ev, S 85/Cat

Cost

SmeftMty 80% -0.27 0.45

APPUANCE UFE An 8ev, S Ba/Cat to Amount 125% -0.14 0.70

Energy, PnnuelCooldng Us, 1000Btu/ 1,246 Energy, Annual Cooldng Use, 1000 Stir/yr 1,284 alGae, 150% -0.07 0.85

Cooldng EfficIency 6.10% Cooldag EfficIency 892% SensltMty -2 -0.25 0.52 Bas.& l65% -0.03 0.93

Enlrgy,Total Annual Us., 1000810/yr 2,754 Energy, Total Annual Use, 1000 Otu/yr 2,792 toYrs. UI. 2 -0.18 0.80 ModIf.d 215% 0.10 1.21

Energy Fsctor 2.78% Energy Fsctat 2.12% Change

Ys.r 1997 I996 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

MODIFIED RANGE

Installed Cost, Adaltlonal 5.42

Makitetwmce Cost 0.00 0.00 0,00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0,00 0.00 0.00 0,00 0.00

Mau.lNs*iralGaaCcst 11.24 11.70 16.17 18.45 18.14 19.03 19.33 19.64 19.97 20.32 20.81 21.03 21.39 21.77 22.11 22.56 22,91 23.38 23.66 0.00

Annual ElactElty Cost 0.00 0.00 0.00 0,00 0,00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TotalCosta 5.42 17.24 17.70 18.11 18.45 18,74 19.03 19.33 19.64 19.91 20.32 20.87 21.03 21,39 21.77 22.17 22.56 22.97 23.38 23.86 0.00

BASE CASE RANGE

Mahntwance Cost 0.00 0.00 000 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0,00 0.00 0.00

AnnualNatiralGasCoet 11.48 17.94 -18.42 18.71 19.00 19.30 19.60 19.91 20.25 20.60 20.95 21.32 21.68 22.01 22,47 22.88 23.29 23,71 23.99 0.00

Annual Ehactaclly Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TotalCosts 17,48 17.94 18.42 18.71 19.00 19.30 19.60 19.91 20.25 20.60 20,95 21.32 21.68 22.07 22,47 22.68 23.29 23.71 23.99 0.00

FESLLTS

Net8avtngs,Moll*.dRenge -5.42 0.24 0.24 0.25 0.25 0.26 0.25 0.27 0.21 0.28 0.28 0.29 0,29 0.30 0.30 0.31 0.31 0,32 0.32 0.33 0.00

(a) IllnNalcast positIve, net present vakas of future saningeMllalcost; It Initial coetnsgmlv., InItal savlngs/NPV of *rlureco.ls. DATA SET No. E-4 (A-I & C-i) 06/2'94

EE-RM-90-201 COMMENT OOR13

Table A-19. 2" Insulation outside of Combustion Chamber- -Standard Oven 

COST CALCUATION DOllARS ASSUMPTIONS RESUI. TS @ 8'" Dloc. RI. 

Al! C.lculallono .reln Conllant 1090 Oolla ... Fuel eo.t Sceno~o DOE. RMld81lal. ReI. C ... Annualzed Not S ••. -0.21 SlY' DISCOUNT RATE An So •• S Bft/CII Dlocaunl Rate (Raa9 8.0"- eeneftt/Colt( 0) O.se 

MODIFIED RANGE Applenca UIe. Y.I ... 111 Int.,1 Rat. 01 Aatlm -0.1'" S,,"ltlvtly 2.0"- -0.07 0.81 

Morie Up '""" MA'IIIIa:turing eo.t 2.81 Simple Paybock Naver to Dloc'nt 7.0'" -0.25 0.52 

Added !nllaled eo.t. $ 5.42 Not Enargy Saved 38 kBtuIY' Rato 15.0"- -0.81 0.30 

IWIE CASE RANGE Annualzed Go. Sa •. 0.27 SlY' 

Malnt81encO eo.t. S. NPV@ 8'" 0.00 MaInI81enco eo.t. S. NPV@ 8"- 0.00 ARSTCOST An Say. S Bft/CII Gil. Annual Cooking Uoa. 1000 !!lilY' 1.248 G ... AnnuaICooking Uoa.IOOO!!llIY' 1.284 

Gil. Non-CookIng PlIotI. 1000 !!lilY' 1.508 GI •• Nan-CookIng Pilot •• 1000 !!lilY' 1.508 SENSITMTY S81l1ltMty 75"" -0.011 0.75 

Gil. S.ICIe .... IOOOBtufY'. OCyc"'" 0 GI •• S.I CIe .... 1000 BtuIY'. 0 Cyc"," 0 toAm 85"" -0.14 0.88 

Ga •• Total Uoa. 1000 BtufY' 2.754 Ga •• TaIIIl Uoa. 1000 BtuIY' 2.7112 GAS COST An SOy. S Bft/CII eo.t 120"- -0.31 0.47 150"- -0.45 0.38 

S81I1lUvtIy 80% -0.27 0.45 

to G •• 120"- -0.18 0.88 GAS QUANTITY AnSa •• S Bft/CII Coli 

S81t11M1y 80% -0.27 0.45 APPUHlCE UFE AnSa •• S Bft/CII 10 Amount 125"" -0.14 0.70 

Energy.llnnualCooking Uoa. 1000Btufl 1.248 Enorgy.lnnUalCooldng Uoa.IOOOBtuIY' 1.284 of G •• , 150"- -0.07 0.85 

Cooking EtIIcIanc:y 8.10"- CookIng EtIIcIanc:y 5.112"- S81I1lUvtIy -2 -0.25 0.52 8018& 185"" -0.03 0.113 

Energy. Tot.lllnnual Uoa. 1000 BtuIY' 2.754 Energy. TotlllnnUal Uoa. 1000 BtuIY' 2.7112 loY .... UIe 2 -0.18 0.80 ModI.ed 215"" 0.10 1.21 

EnorgyF1C1o< 2.78"- EnergyFlC1o< 2.72"" Ch ... g. > N 

I-' 

Y .. , 1l1li7 I- I- 2000 2001 2002 2003 2004 2005 2008 2007 2008 200II 2010 2011 2012 2013 2014 2015 2018 2017 

MODIFIED RANGE 

!nlloled eo.t. AddtIonal 5.42 

Malnl81enco eo.t 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annual NI",.I GI. eo.t 17.24 17.70 18.17 18.45 18.74 10.03 10.33 10.84 10.07 20.32 20.87 21.03 21.311 21.77 22.17 22.se 22.07 23.38 23.88 0.00 

Annuli Electolclly eo.t 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

TotaICooII 5.42 17.24 17.70 18.17 18.45 18.74 10.03 111.33 10.84 10.07 20.32 20.87 21.03 21.311 21.77 22.17 22.se 22.07 23.38 23.88 0.00 

IWIE CASE RANGE 

MaIntonenco eo.t 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annual Na","1 Gil eo.t 17.48 17.114 '18.42 18.71 10.00 10.30 10.80 10.01 20.25 20.80 20.115 21.32 21.88 22.07 22.47 22.88 23.20 23.71 23.l1li 0.00 

Annuli Electolclly eo.t 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

TaIIIlCooII 17.48 17.114 18.42 18.71 10.00 111.30 10.80 10.111 20.25 20.80 20.115 21.32 21.88 22.07 22.47 22.88 23.20 23.71 23.l1li 0.00 

RESUlTS 

Nat Saving'. ModItIed Rang. -5.42 0.24 0.24 0.25 0.25 0.28 0.28 0.27 0.27 0.28 0.28 0.20 0.20 0.30 0.30 0.31 0.31 0.32 0.32 0.33 0.00 

(0) "Inllol Coli polllUva. nat p....,1 ...... 01 MIlre 18Y1ngo,1nl1lllcool; K InItIII COOl noglllvo.InIIII18Y1ngolNPV 01 MIlrecooll. DATASET No. E-4(A-l & C-l) 08!2t\'M 
Table A-20. Reduced Conduction Losses- -Pyrolytic Oven Construction- -Standard Oven

COST CALCUlATION DOLLARS ASSUMPTIONS FESULTS @8% DIsc. RI.

At Catutetloni erein Constant 1990 Dollar, FUel Cost Scenailo DOE, RssIdcnSsI, Ref. Case Annualzed Net 5ev. -685 S/yr DISCOUNT RATE An 5ev, $ 8ff/Cat

DIscount Rate (Real) 6.0% BenetljCost(a) 0.19

MODIFIED RANGE Applenco UI., Year, IS Intrnl Rate of Retim -9.0% 8msltMty 2.0% -4.39 0.27

MakLktrccnManufscturtngCoat 2.81 SlmplePaybsck Never toDtsc'nt 7.0% -7.52 0.17

AddedlnstaffedCoat,$ 93,82 NetEnergySaved 2l7kBtu/yr Rate 15.0% -13.63 0.10

BASE CASE RANGE Mnuelzed Gas 5ev. 1.56 S/yr

Malntaranca Coat, 8, NPV@ 8% 0.00 Msintaianco Cost, S, NPV@ 0% 0.00 FIRST COST An 8ev, S Ba/Cat

Gas, Annual Cooldng Us., 1000 BtI/yr 1,068 Gas, Annual Cooldng Us., 1000 811/yr 1,284

Ga,,PJon-Cooldng Pilots, 1000811/yr 1,508 Gsa, Non-Cooldng PIlots, 1000 Eli/yr 1,508 SENSITIVITY SsisftMty 75% -4.75 0.25

Gas, 0.11 Clean, 1000 Btu/yr, 0 Cycles 0 Gas, 8.11 Clean, 1000 Btu/yr, 0 Cycles 0 ' to FIrst 85% -5.59 0.22

Gas,Total Us., l000Btu4rr 2,816 Oss,Total Uao, l000Blu/yr 2,792 GAS COST An 8ev, 5 Ba/Cat Cost 120% -8.53 0.15

150% -11.05 0.12

SansilivIty 80% -7.18 0.15

to Ga. 120% -654 0.22 GAS OUANTTT'Y An Say, $ Bfl/Cst

Coat

5osltMty 80% -7.10 0.15

APPUANCE LIFE An 8ev, $ Ba/Cat to knount 125% -6.40 0.23

Energy, Annual Cooldng U*, 1000 Btufr 1,068 Energy, Annual CookIng Use, 1000 Blu/yr 1284 olGa., 150% -6.07 0.28

CookIng EfficIency 7.12% CookIng EffIcIency 5.92% s.lslam -2 -7.41 0.17 Base& 165% -5.84 0.31

Energy, Total Annual Use, 1000 Eli/yr 2,578 Energy, Total Annual Us., 1000 Blu/yr 2,792 to Yra. LIfe 2 -6.40 0.20 Moditled 215% -5.06 0.40

Energy Fsctor 2.95% Energy Ftor 2.72% Change

Year 1097 1998 1900 2000 2001 2002 2003 2004 2005 2008 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

MODIFIED RANGE

Installed Coat, Addtlonal 93.82

Malnteiance Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

AnnualNatiralGasCost 18.12 1655 1699 17.28 17.53 17.80 16.08 10.36 16.08 19.00 19.33 19.66 20.00 20.36 20.73 21.10 21.48 21.87 22.13 0.00

Annual EIsCtdCIty Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

lotalCosts 93.82 16.12 16.55 18.99 17.28 17.53 t7.80 18.08 16.36 18.88 19.00 19.33 19.66 20.00 20.30 20.73 21.10 21.48 21.87 22.13 0.00

BASE CASE RANGE

Malntanance Coat 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

AnnuelNatiralOasCout 17.48 17.94 18.42 18.71 19.00 19.30 19.60 19.91 20.25 20.60 20.95 21.32 21.88 22.07 22.47 22.88 23.29 23.71 23.99 0.00

MnualElsctdcttyCost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

TotalCosla 17.48 17.94 18.42 18.71 19.00 19.30 19.60 19.91 20.25 20.60 20.95 21.32 21.68 22.07 22.47 22.88 23.29 23.11 23.99 0.00

IESILTS

N.t8aatng.,UodlkdRange -93.82 1.36 1.39 1.43 1.45 1.47 1.50 1.52 1.54 1.57 1.60 1.62 1.85 168 1.71 1.74 1.77 1.81 1.84 1.88 0.00

l')

(a) If InlisI cost posItIve, net preaant vakie of future sa*rgsfinltlalcost; If Initial costnegative, InitIal uvlngs/NPV of future costs. DATA SET No. G-l 0e/2a'94

EE-RM-90-201 COMMENT OOR13

TableA-20. Reduced Conduction Losses - - PyroJytic Oven Construction - - Standard Oven 

COST CALCUlATION DOLLARS ASSUMPTIONS "'SUllS @ 8% Dloc. RI. 

AI Cal:ulatlon •• reln Conltant tlKKl Dalla .. FUel Coot Ilcenado DOE, _d..".I, FIoI. Ca •• AnnualZed No! Sav. -8.85 Sty, DISCOUNT RATE AnSav, S Blt/CIt Dlocount Rato (Aaa~ 8.0% Benont/Colt( 0) 0.111 

MODIFIED RANGE Applonce Ufo, Y .... til Intml Rate 01 Rellm -11.0% SIIl.ltl-.1ty 2.0% -4.311 0.27 

Mlrk l.\> !rom M..,ut &:luling Coot 2.81 Simple PaybEk Novo, to Dloc'nt 7.0% -7.52 0.t7 

Addad Inltaltod Coot, S 113.82 No! Energy Saved 217 kBtuty' Rata 15.0% -13.83 0.10 

BASE CASE RANGE Annualzed Gal Sav. 1.58 Sty, 

Malnt..,anco Coot, S, NPV@ 8% 0.00 MaInt..,anco Coot, S, NPV@ 8% 0.00 FIRST COST AnSav, S Blt/CIt G .. , Annuli! CooIdng lJae, t 000 BlJty, t,OII8 GI., Annuli Cooking lJae, 1000 BlJty, t,284 

G .. , Non-Cooking Pilot., tooo BlJty, t,508 GI., Non-CookIng Pilot., 1000 BlJty, 1,508 SENSITIVITY SIIlIIttvIty 75"" -4.75 0.25 

Gal, s.r Cleen, 1000 Btuty" 0 Cycle. 0 GI., s.rClaan, 1000 Btuty" 0 Cyclao 0 to A rot 85"" -5.511 0.22 

Ga., TotollJae, loooBtuty' 2,578 GI., TotallJae, loooBtuty' 2,7112 GAS COST AnSav,S Bft/C1t Coot 120"" -8.53 0.15 

150% -11.05 0.12 

S..,IlU-.1ty 80% -7.18 0.15 

to Gal 120"'- -8.54 0.22 GAS QUANTITY AnSav, S Blt/CIt Coot 

SIIlIIttvIty 80% -7.18 0.15 APPUANCE UFE AnSav,S Blt/CIt to mount 125"" -8.48 0.23 

Energy, Annuli CooIdng lJae, 1000 BtuA 1,0118 Energy, Annual Cooking lJae, 1000 Btuty, 1,284 of G •• , 150"" -8.07 0.28 

Cooking Ellldency 7.12"'- Cooking EIIIdency 11.112"'- SIIlIlH-.1ty -2 -7.41 0.17 ea •• & 185"" -5.84 0.31 

Energy, Totll AnnulllJae, 1000 Btuty, 2,578 Energy, Totol Annu II!lJae, 1000 Btuty, 2,7112 toY ... Ufo 2 -8.40 0.20 Modl'ad 215"" -5.08 0.40 

Energy FlCtor 2.115"" Energy FlCtor 2.72"'- ChIng. > I 

vo., 10117 I_ I_ 2000 200t 2002 2003 2004 2005 2008 2007 2008 2009 2010 2011 2012 2013 2014 2015 2018 2017 N 

N 

MODIFIED RANGE 

1n1t.11od Coot, Addtfonll 113.82 

Malntonanco Coot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annuli NIll,al GI. Coot 18.12 18.55 18.011 17.211 17.53 17.110 18.05 18.311 111.08 111.00 111.33 111.1la 20.00 20.311 20.73 21.10 21.48 21.87 22.13 0.00 

Annuli ElocloIcIty Coot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

TotllCoatl 113.82 111.12 18.55 111.011 17.211 17.53 17.80 111.05 111.311 18.1la 111.00 111.33 111.1la 20.00 20.311 20.73 21.10 21.48 21.87 22.13 0.00 

BASE CASE RANGE 

Malntonanco Coot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Annuli N"ll,"1 Ga. Coot 17.48 17.114 111.42 111.71 111.00 111.30 111.110 111.111 20.25 20.110 20.115 21.32 21.1la 22.07 22.47 22.1la 23.211 23.71 23.011 0.00 

Annuli ElocloIcIty Coot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

TotllCoat. 17.48 17.114 18.42 18.71 111.00 111.30 111.110 111.111 20.25 20.110 20.115 21.32 21.1la 22.07 22.47 22.118 23.211 23.71 23.011 0.00 

"'SUlTS 

Nil Saving., ModtIad Rang. -113.112 1.311 1.311 1.43 1.45 1.47 1.50 1.52 1.54 1.57 1.110 1.112 1.115 1.118 1.71 1.74 l.n 1.111 1.114 1.1la 0.00 

(I) Klnlilicoll poilU .. , nil pmont VI"O 01 future oavlngo(lnltlalcoot; K IntUllcootnag_,lnIlal oavIng./NPV 01 futurecoot •. DATASET NO.G-l 08/2Pt114 
Appendix B

Oral Testimony Given by D. K. Landstrom to DOE

April and June 1994

EE-RM-90-201 COMMENT OOR13

Appendix B 

Oral Testimony Given by D. K. Landstrom to DOE 

April and June 1994 
B-i

Oral Testimony

DOE Public Hearings on the Notice of Proposed Rulemaking

Concerning the Residential Range/Oven Efficiency Standard

"Eight Products Rulemaking"

(Docket No. EE-RM-90-201)

April 5-7, 1994

Washington D.C.

Speaker Information

Name: D. Karl Landstrom

Employer: Battelle Columbus Operations

505 King Avenue

Columbus, Ohio 43201-2693

Tel: (614) 424-4803

Fax: (614) 424-3534

Position: Deputy for Administration of the Gas Appliance Technology Center

(GATC) Operations at Battelle. The GATC receives its funding

from the Gas Research Institute (Chicago, Illinois).

Representing: Technical analyses performed on behalf of the Gas Research Institute

(Rodney C. Rinholm, GRI Project Monitor) pertinent to DOE's

rulemaking concerning ranges/ovens.

EE-RM-90-201 COMMENT OOR13

B-1 

Oral Testimony 

DOE Public Hearings on the Notice of Proposed Rulemaking 

Concerning the Residential Range/Oven Efficiency Standard 

Speaker Infonnation 

Name: 

Employer: 

Position: 

Representing: 

"Eight Products Rulemaking" 

(Docket No. EE-RM-90-201) 

April 5-7, 1994 

Washington D.C. 

D. Karl Landstrom 

Battelle Columbus Operations 

505 King Avenue 

Columbus, Ohio 43201-2693 

Tel: (614) 424-4803 

Fax: (614) 424-3534 

Deputy for Administration of the Gas Appliance Technology Center 

(GATC) Operations at Battelle. The GA TC receives its funding 

from the Gas Research Institute (Chicago, Illinois). 

Technical analyses performed on behalf of the Gas Research Institute 

(Rodney C. Rinholm, GR! Project Monitor) pertinent to DOE's 

rulemaking concerning ranges/ovens. 
B-2

Oral Comments

I am Karl Landstrom, a projects manager at Battelle's Columbus Operations. I

am the manager of a study funded by Gas Research Institute in Chicago to analyze the DOE

design options described in the Advanced Notice of Proposed Rulemaking (ANOPR) for -

kitchen ranges and ovens that was published in the Federal Register on September 28, 1990

(Vol. 55, No. 189). I am speaking in my capacity as manager of that study.

I want to thank the Department of Energy for the opportunity today to comment

on the portion of the Notice of Proposed Rulemaking (NOPR) that covers kitchen ranges and

ovens.

The DOE is to be congratulated for the extensive technical analysis that supports

the NOPR and gathering the best information that was available at the time the document

was written. Since that time, GRI has contributed to the technical data base available for

rulemaking under the National Appliance Energy Conservation Act (NAECA) for water

heaters,' furnaces and boilers, and kitchen ranges and ovens.3 The study I will speak of

today is limited to kitchen ranges and ovens and is intended to provide additional analysis

that we request DOE consider before the publication of the final rule. The study provides

up-to-date and accurate information on the various design options for increasing the energy

efficiency of residential ranges and ovens.

During an early phase of the study, GRI established a Technical Advisory

Group (TAG) consisting of manufacturers, trade associations, and gas utility representatives

to guide the project. Work was conducted to develop survey data, analytical models, cost

data, and to evaluate experimental modifications to existing ranges to assess the technological

feasibility and economic justification of the design options published by DOE in the ANOPR.

The intent of the analytical and experimental investigations was to assure that the best data

available is used in the rulemaking process. Areas of greatest data needs were identified and

a comprehensive and careful analysis was undertaken.

The work was carried out by an expert team made up of staff from Battelle

Columbus Operations, American Gas Association Laboratories (A.G.A.L.), and Arthur D.

Little Corporation (ADL) under funding of GRI. The TAG helped to guide the project by

assuring realistic costs, approaches and issues were considered.

The study approach was to use the same analysis methodology applied by DOE's

contractors in past NAECA rulemaking cycles. This included assessments of (1) the technical feasibility of the DOE-specified design options, (2) the practical application of the

design options, (3) the effects of the design options on appliance efficiency, (4) the impacts

of the design options on installation and appliance utility, and (5) the life-cycle cost impacts

on the consumer of the design options.

EE-RM-90-201 COMMENT OOR13

B-2 

OralComrnents 

I am Karl Landstrom, a projects manager at Battelle's Columbus Operations. I 

am the manager of a study funded by Gas Research Institute in Chicago to analyze the DOE 

design options described in the Advanced Notice of Proposed Rulemaking (ANOPR) for 

kitchen ranges and ovens that was published in the Federal Register on September 28, 1990 

(Vol. 55, No. 189). I am speaking in my capacity as manager of that study. 

I want to thank the Department of Energy for the opportunity today to comment 

on the portion of the Notice of Proposed Rulemaking (NOPR) that covers kitchen ranges and 

ovens. 

The DOE is to be congratulated for the extensive technical analysis that supports 

the NOPR and gathering the best information that was available at the time the document 

was written. Since that time, GRI has contributed to the technical data base available for 

rulemaking under the National Appliance Energy Conservation Act (NAECA) for water 

heaters, (1) furnaces and boilers, (2) and kitchen ranges and ovens. (3) The study I will speak of 

today is limited to kitchen ranges and ovens and is intended to provide additional analysis 

that we request DOE consider before the publication of the final rule. The study provides 

up-to-date and accurate information on the various design options for increasing the energy 

efficiency of residential ranges and ovens. 

During an early phase of the study, GRI established a Technical Advisory 

Group (TAG) consisting of manufacturers, trade associations, and gas utility representatives 

to guide the project. Work was conducted to develop survey data, analytical models, cost 

data, and to evaluate experimental modifications to existing ranges to assess the technological 

feasibility and economic justification of the design options published by DOE in the ANOPR. 

The intent of the analytical and experimental investigations was to assure that the best data 

available is used in the rulemaking process. Areas of greatest data needs were identified and 

a comprehensive and careful analysis was undertaken. 

The work was carried out by an expert team made up of staff from Battelle 

Columbus Operations, American Gas Association Laboratories (A.G.A.L.), and Arthur D. 

little Corporation (ADL) under funding of GRI. The TAG helped to guide the project by 

assuring realistic costs, approaches and issues were considered. 

The study approach was to use the same analysis methodology applied by DOE's 

contractors in past NAECA rulemaking cycles. This included assessments of (1) the technical feasibility of the DOE-specified design options, (2) the practical application of the 

design options, (3) the effects of the design options on appliance efficiency, (4) the impacts 

of the design options on installation and appliance utility, and (5) the life-cycle cost impacts 

on the consumer of the design options. 
B-3

An interim report3 was published in July 1993 and reviewed with DOE staff at

a meeting in September of 1993. Previous contact with DOE was used to assure that the

analysis methodology was consistent with the DOE test procedures for ranges and ovens.

We also verified that the life-cycle costing parameters were consistent with DOE procedures

and basic assumptions. Due to time constraints, it is understandable that DOE was unable to

incorporate the results of our study into the NOPR. However, we respectfully request that

this information be considered and analyzed before a final rule is published.

Before I comment on specific design options, I would like to address several

general issues that impact the economic, safety, and utility attributes of the gas range.

Metered experimental data gathered on Annual Gas Cooking Energy Consumption usage factors show much lower usage than in the past. This is partially a result

of lifestyle changes, more use of microwave ovens and other new convenience cooking

products. In our interim report, we submitted data to DOE from an extensive metered study

of gas ranges and ovens that was conducted from 1990 to 1992. This study determined that

Annual Gas Cooking Energy Consumption usage factors have dramatically decreased from

the baseline 1977 to 1988 data used in the DOE's analysis. Also, the number of self-clean

cycles assumed by DOE seem unrealistic for current levels of oven use. The metered data

we have gathered is consistent with that of other recent sources. We request that this

additional data be considered in the rulemaking process.

We are in general agreement with the DOE concerning the life-cycle cost

methodology; however, manufacturers' data do not support the DOE's first cost assumptions

for many of the design options. In addition, we believe that the life-cycle cost data should

be updated by DOE to use current DOE Energy Information Administration estimates of

future fuel cost projections rather than 1991 estimated projections. Other criteria that need to

be adequately addressed are the effects of the design options on cooking quality, consumer

safety, and product utility.

Let me now address a few specifics on the design options themselves. Of the 12

range and oven design options originally proposed by the DOE, 10 are applicable to gas-fired

ranges (Figure 1).

I will briefly describe the areas where the technical data in the GRI report may

be used to more accurately assess the design options. We plan to comment more fully in the

written submission.

A. Thermostatically Controlled Gas Burners. The GRI analysis confirms the

DOE analysis that the use of thermostatically controlled burners would not result in an

efficiency increase and should not be considered.

EE-RM-90-201 COMMENT OOR13

B-3 

An interim report(3) was published in July 1993 and reviewed with DOE staff at 

a meeting in September of 1993. Previous contact with DOE was used to assure that the 

analysis methodology was consistent with the DOE test procedures for ranges and ovens. 

We also verified that the life-cycle costing parameters were consistent with DOE procedures 

and basic assumptions. Due to time constraints, it is understandable that DOE was unable to --

incorporate the results of our study into the NOPR. However, we respectfully request that 

this information be considered and analyzed before a final rule is published. 

Before I comment on specific design options, I would like to address several 

general issues that impact the economic, safety, and utility attributes of the gas range. 

Metered experimental data gathered on Annual Gas Cooking Energy Consumption usage factors show much lower usage than in the past. This is partially a result 

of lifestyle changes, more use of microwave ovens and other new convenience cooking 

products. In our interim report, we submitted data to DOE from an extensive metered study 

of gas ranges and ovens that was conducted from 1990 to 1992. This study determined that 

Annual Gas Cooking Energy Consumption usage factors have dramatically decreased from 

the baseline 1977 to 1988 data used in the DOE's analysis. Also, the number of self-clean 

cycles assumed by DOE seem unrealistic for current levels of oven use. The metered data 

we have gathered is consistent with that of other recent sources. We request that this 

additional data be considered in the rulemaking process. 

We are in general agreement with the DOE concerning the life-cycle cost 

methodology; however, manufacturers' data do not support the DOE's first cost assumptions 

for many of the design options. In addition, we believe that the life-cycle cost data should 

be updated by DOE to use current DOE Energy Information Administration estimates of 

future fuel cost projections rather than 1991 estimated projections. Other criteria that need to 

be adequately addressed are the effects of the design options on cooking quality, consumer 

safety, and product utility. 

Let me now address a few specifics on the design options themselves. Of the 12 

range and oven design options originally proposed by the DOE, 10 are applicable to gas-frred 

ranges (Figure 1). 

I will briefly describe the areas where the technical data in the GRI report may 

be used to more accurately assess the design options. We plan to comment more fully in the 

written submission. 

A. Thermostatically Controlled Gas Burners. The GRI analysis confirms the 

DOE analysis that the use of thermostatically controlled burners would not result in an 

efficiency increase and should not be considered. 
B-4

B. Insulation/Reflective

Surfaces. I will combine Design

Options E (Improved Insulation of the

Cabinet), H (Insulation with Lower Conductivities), and I (Use of Reflective

Surfaces) with Option B in the following

discussion, with separate observations for

cooktops and ovens, as has been done in

the DOE support document.

1. Gas Cooktops - Insulation. For gas cooktops, experimental

data confirm the DOE analysis that added

insulation would not result in an

efficiency increase.

2. Gas Cooktops -Reflective Surfaces. For gas cooktops,

experimental data confirm that the efficiency increase resulting from adding

reflective surfaces is very small and, in

fact, show that the increase is considerably smaller than that assumed by DOE.

A. Thermostatically Controlled Gas

Burners

B. Insulation/Reflective Surfaces

E. Improved Insulation of the Cabinet

F. Reduced Vent Size

G. Reduced Conduction Losses

H. Insulation with Lower Conductivities

I. Use of Reflective Surfaces

J. Reduction of Thermal Mass

K. Forced Convection During Cleaning

L. Oven Separator

(Design Options C and D applied to electric

ranges only and were not evaluated in the study.)

Figure 1. Table of DOE design options as

published in the ANOPR.

3. Ovens - Insulation. The experimental data confirm that adding insulation to

a standard oven to the level currently used in self-cleaning ovens will result in a slight

increase in efficiency. The data show much smaller increases than that assumed by DOE.

Increasing/improving the insulation level beyond that already used in self-cleaning ovens does

not result in a significant efficiency increase, based on the DOE test procedure. The experimental data indicated that a slight efficiency increase could be achieved by adding additional

insulation in the broiler compartment of a conventional gas oven. This option does not exist

for a self-cleaning oven. Increasing the thickness of insulation to 4 inches as proposed by

DOE would reduce the utility of an oven by reducing its size and capacity, would require

extensive retooling by manufacturers, would increase first costs, and would not result in a

significant efficiency increase. Life-cycle cost calculations indicate that adding insulation

would not be cost-effective.

4. Ovens - Reflective Surfaces. The data show that adding reflective surfaces

in gas ovens does not result in an efficiency increase. Measurements show an efficiency

decrease resulting from this option.

F. Reduced Vent Size. The experimental data show that reducing the vent

in a gas oven will not result in a significant energy savings. As the vent te is decreased by

reducing the vent size to where the energy savings begin to increase dramatically, it was

EE-RM-90-201 COMMENT OOR13

B. InsulationfRefiective 

Surfaces. I will combine Design 

Options E (Improved Insulation of the 

Cabinet), H (Insulation with Lower Conductivities), and I (Use of Reflective 

Surfaces) with Option B in the following 

discussion, with separate observations for 

cooktops and ovens, as has been done in 

the DOE support document. 

1. Gas Cooktops - Insulation. For gas cooktops, experimental 

data confirm the DOE analysis that added 

insulation would not result in an 

efficiency increase. 

2. Gas Cooktops - Reflective Surfaces. For gas cooktops, 

experimental data confirm that the efficiency increase resulting from adding 

reflective surfaces is very small and, in 

fact, show that the increase is considerably smaller than that assumed by DOE. 

B-4 

A. Thermostatically Controlled Gas 

Burners 

B. Insulation/Reflective Surfaces 

E. Improved Insulation of the Cabinet 

F. Reduced Vent Size 

G. Reduced Conduction Losses 

H. Insulation with Lower Conductivities 

I. Use of Reflective Surfaces 

J. Reduction of Thermal Mass 

K. Forced Convection During Cleaning 

L. Oven Separator 

(Design Options C and D applied to electric 

ranges only and were not evaluated in the study.) 

Figure 1. Table of DOE design options as 

published in the ANOPR. 

3. Ovens - Insulation. The experimental data confirm that adding insulation to 

a standard oven to the level currently used in self-cleaning ovens will result in a slight 

increase in efficiency. The data show much smaller increases than that assumed by DOE. 

Increasing/improving the insulation level beyond that already used in self-cleaning ovens does 

not result in a significant efficiency increase, based on the DOE test procedure. The experimental data indicated that a slight efficiency increase could be achieved by adding additional 

insulation in the broiler compartment of a conventional gas oven. This option does not exist 

for a self-cleaning oven. Increasing the thickness of insulation to 4 inches as proposed by 

DOE would reduce the utility of an oven by reducing its size and capacity, would require 

extensive retooling by manufacturers, would increase first costs, and would not result in a 

significant efficiency increase. Life-cycle cost calculations indicate that adding insulation 

would not be cost-effective. 

4. Ovens - Reflective Surfaces. The data show that adding reflective surfaces 

in gas ovens does not result in an efficiency increase. Measurements show an efficiency 

decrease resulting from this option. 

F. Reduced Vent Size. The experimental data show that reducing the vent size 

in a gas oven will not result in a significant energy savings. As the vent rate is decreased by 

reducing the vent size to where the energy savings begin to increase dramatically, it was 
B-5

observed that the carbon monoxide levels also increased rapidly and venting through the door

seals occurred. At reduced vent sizes that provide acceptable combustion, low surface

temperatures, and no venting around the door seal, energy consumption tests using the DOE

test procedure indicated no significant energy savings. We believe that this option needs

further analysis by DOE.

G. Reduced Conduction Losses. Experimental data confirm the DOE analysis

that shows there is no significant efficiency increase from adopting this option for selfcleaning ovens. Experimental data also show a slight increase in efficiency is possible if a

conventional oven were built like a self-cleaning oven. However, analysis indicates this

would not be cost-effective.

.1. Reduction of Thermal Mass. Experimental data confirm the DOE analysis

that reduction of thermal mass will increase the efficiency; however, experimental measurements indicate a much smaller efficiency improvement than that assumed by DOE. The GRI

analysis and subsequent manufacturer consensus indicate that the magnitude of thermal mass

reduction assumed by DOE is not possible without serious degradation in range strength and

durability, particularly for shipping. Reduction of thermal mass also raises questions of

product safety and stability. We request that this option be re-examined.

K. Forced Convection Durin2 Cleaning. We believe that the DOE has

changed this design option and now considers forced convection as a new design option that

was not published in the ANOPR. I will discuss this under New Design Options.

L. Oven Separator. The analysis shows that the oven separator should not be

considered as a design option due to high cost, consumer utility, and safety concerns.

New Design Options

The DOE has introduced several new design options that were not included in

the ANOPR publication. Thus, we have not had an opportunity to examine these options in

detail. I will make a few preliminary remarks concerning these options. We plan to submit

additional information in the written comment.

1. Remove Oven Door Window. We plan to examine the assumptions used by

DOE in determining the heat loss associated with removing the oven door window. Elimination of the door window will remove a feature appreciated by cooks who prepare delicate

food items such as souffles and many types of cakes. The window allows inspection without

door opening that may cause failure or unacceptable results for these foods. We believe that

the DOE should re-examine this option with regard to the potential increase in efficiency and

reduction in utility that might result.

2. Electronic I2nition. As the DOE noted, actual burner efficiency is not

affected by eliminating the standing pilot. Experimental data confirm that the electricity

EE-RM-90-201 COMMENT OOR13

B-5 

observed that the carbon monoxide levels also increased rapidly and venting through the door 

seals occurred. At reduced vent sizes that provide acceptable combustion, low surface 

temperatures, and no venting around the door seal, energy consumption tests using the DOE 

test procedure indicated no significant energy savings. We believe that this option needs 

further analysis by DOE. 

G. Reduced Conduction Losses. Experimental data confirm the DOE analysis 

that shows there is no significant efficiency increase from adopting this option for selfcleaning ovens. Experimental data also show a slight increase in efficiency is possible if a 

conventional oven were built like a self-cleaning oven. However, analysis indicates this 

would not be cost-effective. 

J. Reduction of Thennal Mass. Experimental data confirm the DOE analysis 

that reduction of thermal mass will increase the efficiency; however, experimental measurements indicate a much smaller efficiency improvement than that assumed by DOE. The GRI 

analysis and subsequent manufacturer consensus indicate that the magnitude of thermal mass 

reduction assumed by DOE is not possible without serious degradation in range strength and 

durability, particularly for shipping. Reduction of thermal mass also raises questions of 

product safety and stability. We request that this option be re-examined. 

K. Forced Convection Durinl: Cleaninl:. We believe that the DOE has 

changed this design option and now considers forced convection as a new design option that 

was not published in the ANOPR. I will discuss this under New Design Options. 

L. Oven Separator. The analysis shows that the oven separator should not be 

considered as a design option due to high cost, consumer utility, and safety concerns. 

New Desil:n Options 

The DOE has introduced several new design options that were not included in 

the ANOPR publication. Thus, we have not had an opportunity to examine these options in 

detail. I will make a few preliminary remarks concerning these options. We plan to submit 

additional information in the written comment. 

1. Remove Oven Door Window. We plan to examine the assumptions used by 

DOE in determining the heat loss associated with removing the oven door window. Elimination of the door window will remove a feature appreciated by cooks who prepare delicate 

food items such as souffles and many types of cakes. The window allows inspection without 

door opening that may cause failure or unacceptable results for these foods. We believe that 

the DOE should re-examine this option with regard to the potential increase in efficiency and 

reduction in utility that might result. 

2. Electronic Il:nition. As the DOE noted, actual burner efficiency is not 

affected by eliminating the standing pilot. Experimental data confirm that the electricity 
B-6

consumption of spark-ignition systems is negligible for gas cooktops. If "gb" type ignition

systems are used, the electrical consumption should be considered.

3. Improved Door Seals. Preliminary analysis shows that the magnitude of

efficiency achievable by improving door seals for gas ovens is much lower than that assumed -

by DOE. Under ANSI standards, to prevent excessive surface temperatures, door seals are

not allowed to vent. This is not a major heat loss source. We request that this option be reexamined.

4. Forced Convection. Forced convection gas ovens are a very small fraction of

the residential market and are extremely expensive when compared to conventional ovens.

Past efforts by manufacturers to produce a low-cost gas convection oven were unsuccessful,

since the convection process often interferes with the combustion process itself, requiring

isolation of the combustion process from the oven cavity. This increases costs dramatically.

It is unlikely that the energy savings will compensate for the realistic cost increase to

manufacture a gas convection oven. In addition, convection oven cooking results in quality

and appearance differences when compared to conventional oven cooking. Some of these

differences may not be acceptable to the consumer. These factors have not been adequately

addressed in the DOE analysis.

5. Sealed Burners. Experimental data confirm that sealed burners should not be

included as a design option. The data for these burners show little or no efficiency increase.

We plan to address this issue further in our written comments.

6. Reduce Excess Air at Burner for Gas Cooktops. Preliminary analysis

shows that the magnitude of efficiency increase achievable with this option is unknown and

not measurable at this time. We do not believe that the engineering analysis cited supports

the DOE conclusion. Such a burner as described by DOE does not exist on the market and

there are no designs that can be evaluated. The potential for increased carbon monoxide

production needs to be analyzed. We request that this option be re-examined. We will

address this issue further in our written comments.

Closure

Unlike other appliances, the utility of a range/oven depends heavily on the

interaction between the user and the appliance. Cooking is much more of an art than a

science. Energy use is typically of far less importance than food quality to the consumer. In

cooking, the consumer invests time, effort, and a significant amount of dollars to ensure that

the fmished food product is acceptable. Changes in appliances designed to boost efficiency

do not make sense if the finished product is affected in a way that changes consumer

expectations. In most cases, the above-mentioned factors are much more important than

the $15.00 the average household spends each year to operate a self-cleaning gas range.

Furthermore, as we have seen in recent metered load studies, the amount of energy used in

EE-RM-90-201 COMMENT OOR13

B-6 

consumption of spark-ignition systems is negligible for gas cooktops. If "glo" type ignition 

systems are used, the electrical consumption should be considered. 

3. Improved Door Seals. Preliminary analysis shows that the magnitude of 

efficiency achievable by improving door seals for gas ovens is much lower than that assumed 

by DOE. Under ANSI standards, to prevent excessive surface temperatures, door seals are 

not allowed to vent. This is not a major heat loss source. We request that this option be reexamined. 

4. Forced Convection. Forced convection gas ovens are a very small fraction of 

the residential market and are extremely expensive when compared to conventional ovens. 

Past efforts by manufacturers to produce a low-cost gas convection oven were unsuccessful, 

since the convection process often interferes with the combustion process itself, requiring 

isolation of the combustion process from the oven cavity. This increases costs dramatically. 

It is unlikely that the energy savings will compensate for the realistic cost increase to 

manufacture a gas convection oven. In addition, convection oven cooking results in quality 

and appearance differences when compared to conventional oven cooking. Some of these 

differences may not be acceptable to the consumer. These factors have not been adequately 

addressed in the DOE analysis. 

5. Sealed Burners. Experimental data confirm that sealed burners should not be 

included as a design option. The data for these burners show little or no efficiency increase. 

We plan to address this issue further in our written comments. 

6. Reduce Excess Air at Burner for Gas Cooktops. Preliminary analysis 

shows that the magnitude of efficiency increase achievable with this option is unknown and 

not measurable at this time. We do not believe that the engineering analysis cited supports 

the DOE conclusion. Such a burner as described by DOE does not exist on the market and 

there are no designs that can be evaluated. The potential for increased carbon monoxide 

production needs to be analyzed. We request that this option be re-examined. We will 

address this issue further in our written comments. 

Closure 

Unlike other appliances, the utility of a range/oven depends heavily on the 

interaction between the user and the appliance. Cooking is much more of an art than a 

science. Energy use is typically of far less importance than food quality to the consumer. In 

cooking, the consumer invests time, effort, and a significant amount of dollars to ensure that 

the fmished food product is acceptable. Changes in appliances designed to boost efficiency 

do not make sense if the finished product is affected in a way that changes consumer 

expectations. In most cases, the above-mentioned factors are much more important than 

the $15.00 the average household spends each year to operate a self-cleaning gas range. 

Furthermore, as we have seen in recent metered load studies, the amount of energy used in 
B-7

residential ranges has been steadily decreasing due to shifts in lifestyle, changed eating

habits, supplementary cooking appliances and convenience food products.

Reproducibility of results, food appearance and quality, ease of use, and

cleanability remain the major consumer concerns in range cooking. Utility and performance

are much more important for ranges and ovens than for many other appliances. Any

modification made to increase efficiency must not negatively impact these features, thereby

decreasing the usefulness of the range to the consumer. Many DOE design options have the

potential to affect the cooking process and this must therefore be carefully considered.

I have given a brief summary to describe GRI's project on ranges and ovens and

to enumerate several important elements of a complete and objective analysis of efficiency

levels and the way in which they uniquely impact gas appliances.

In closing, we request that the DOE consider the experimental and analytical

results presented in the GRI report3 as we believe that this information is the most thorough

and up-to-date currently available.

Thank you for your kind consideration and attention.

(1) Assessment of Technology for Improving the Efficiency of Residential Gas Water Heaters,

D. D. Paul et al., GRI Topical Report No. GRI-9110298, December 1991.

(2) Technical Input to NAECA Rulemaking for Gas-Fired Ranges, Battelle, GRI Interim Report

No. GRI-93/0319, July 1993.

(3) Assessment of Technology for Improving the Efficiency of Residential Gas Furnaces and

Boilers, F. E. Jakob et a!., GRI Interim Topical Report No. GRI-9410039, January 1994.

EE-RM-90-201 COMMENT OOR13

B-7 

residential ranges has been steadily decreasing due to shifts in lifestyle, changed eating 

habits, supplementary cooking appliances and convenience food products. 

Reproducibility of results, food appearance and quality, ease of use, and 

cleanability remain the major consumer concerns in range cooking. Utility and performance _. 

are much more important for ranges and ovens than for many other appliances. Any 

modification made to increase efficiency must not negatively impact these features, thereby 

decreasing the usefulness of the range to the consumer. Many DOE design options have the 

potential to affect the cooking process and this must therefore be carefully considered. 

I have given a brief summary to describe GRI's project on ranges and ovens and 

to enumerate several important elements of a complete and objective analysis of efficiency 

levels and the way in which they uniquely impact gas appliances. 

In closing, we request that the DOE consider the experimental and analytical 

results presented in the GRI report(3) as we believe that this information is the most thorough 

and up-to-date currently available. 

Thank you for your kind consideration and attention. 

(1) Assessment of Technology for Improving the Efficiency Of Residential Gas Water Heaters, 

D. D. Paul et al., GRI Topical Report No. GRI-9110298, December 1991. 

(2) Technical Input to NAECA Rulemaking for Gas-Fired Ranges, Battelle, GRI Interim Report 

No. GRI-93/0319, July 1993. 

(3) Assessment of Technology for Improving the Efficiency Of Residential Gas Furnaces and 

Boilers, F. E. Jakob et al., GRI Interim Topical Report No. GRI-94/0039, January 1994. 
B-8

EE-RM-90-201 COMMENT OOR13

B-8 
B-9

Oral Testimony

DOE Public Hearings on the Notice of Proposed Rulemaking

Concerning the Residential Range/Oven Efficiency Standard

"Eight Products Rulemaking"

(Docket No. EE-RM-90-201)

June 7-8, 1994

Washington D.C.

Speaker Information

Name: D. Karl Landstrom

Employer: Battelle Columbus Operations

505 King Avenue

Columbus, Ohio 4320 1-2693

Tel: (614) 424-4803

Fax: (614) 424-3534

Position: Deputy for Administration of the Gas Appliance Technology Center

(GATC) Operations at Battelle. The GATC receives its funding

from the Gas Research Institute (Chicago, Illinois).

Representing: Technical analyses performed on behalf of the Gas Research Institute

(Rodney C. Rinhoim, GRI Project Monitor) pertinent to DOE's

rulemaking concerning ranges/ovens.

EE-RM-90-201 COMMENT OOR13

B-9 

Oral Testimony 

DOE Public Hearings on the Notice of Proposed Rulemaking 

Concerning the Residential Range/Oven Efficiency Standard 

Speaker Information 

~: 

Employer: 

Position: 

Representin~: 

"Eight Products Rulemaking" 

(Docket No. EE-RM-90-20l) 

June 7-8, 1994 

Washington D.C. 

D. Karl Landstrom 

Battelle Columbus Operations 

505 King Avenue 

Columbus, Ohio 43201-2693 

Tel: (614) 424-4803 

Fax: (614) 424-3534 

Deputy for Administration of the Gas Appliance Technology Center 

(GATC) Operations at Battelle. The GATC receives its funding 

from the Gas Research Institute (Chicago, Illinois). 

Technical analyses performed on behalf of the Gas Research Institute 

(Rodney C. Rinholm, GRI Project Monitor) pertinent to DOE's 

rulemaking concerning ranges/ovens. 
B-b

Oral Comments

I am Karl Landstrom, a projects manager at Battelle's Columbus Operations. I

am the manager of a study funded by Gas Research Institute in Chicago to analyze the DOE

design options described in the Advanced Notice of Proposed Rulemaking (ANOPR) for

kitchen ranges and ovens that was published in the Federal Register on September 28, 1990

(Vol. 55, No. 189). In addition, the study has been extended to include the new design

options that were published in the Federal Register on March 4, 1994 (Vol. 59, No. 43).

I want to thank the Department of Energy for the opportunity today to comment

a second time on the DOE Notice of Proposed Rulemaking (NOPR) that covers kitchen

ranges and ovens.

The information I will present today is limited to kitchen ranges and ovens and is

intended to provide additional data and analysis that we request DOE consider before the

publication of the final rule.

The work was carried out by an expert team made up of staff from Battelle

Columbus Operations (BCO), American Gas Association Laboratories (A.G.A.L.), and

Arthur D. Little Corporation (ADL) under funding of GRI. A Technical Advisory Group

(TAG), consisting of manufacturers, trade associations, and gas utility representatives helped

to guide the project by assuring realistic costs, approaches and issues were considered.

As I mentioned in my previous testimony, an interim report' was published in

July 1993 and reviewed with DOE staff at a meeting in September of 1993. Due to time

constraints, DOE was unable to incorporate the results of our study into the NOPR. We plan

to submit an additional report covering the new design options as our July 18, 1994, written

submission. We respectfully request that both of these reports be considered and analyzed

before a final rule is published.

Before I comment on the specific design options, I would like to address several

general issues that impact the economic, safety, and utility attributes of the gas range.

Annual Gas Usa2e

At the core of the economic analysis is the value used for the Annual Useful

Cooking Energy Output in the DOE Test Procedure. In the 1970s, this value was established

as 947.5 kBtu/yr for gas cooktops and 160.7 kBtu/yr for gas ovens. Recognizing that

cooking habits have drastically changed since the time the DOE values were established,

DOE averaged four estimates of gas range annual energy use published between 1984 to

1988. Only one of these studies (Southern California Edison-1988) was based upon metered

data. All three of the other non-metered conditional demand analysis (CDA) studies were

higher than the metered data (actual values, 34.4 therms for the metered data, 44, 42, and

46.7 therms respectively for the CDA studies). DOE obtained an average of 41.8 therms

EE-RM-90-201 COMMENT OOR13

B-lO 

Oral Comments 

I am Karl Landstrom, a projects manager at Battelle's Columbus Operations. I 

am the manager of a study funded by Gas Research Institute in Chicago to analyze the DOE 

design options described in the Advanced Notice of Proposed Rulemaking (ANOPR) for 

kitchen ranges and ovens that was published in the Federal Register on September 28, 1990 

(Vol. 55, No. 189). In addition, the study has been extended to include the new design 

options that were published in the Federal Register on March 4, 1994 (Vol. 59, No. 43). 

I want to thank the Department of Energy for the opportunity today to comment 

a second time on the DOE Notice of Proposed Rulemaking (NOPR) that covers kitchen 

ranges and ovens. 

The information I will present today is limited to kitchen ranges and ovens and is 

intended to provide additional data and analysis that we request DOE consider before the 

publication of the final rule. 

The work was carried out by an expert team made up of staff from Battelle 

Columbus Operations (BCO), American Gas Association Laboratories (A.G.A.L.), and 

Arthur D. Little Corporation (ADL) under funding of GR!. A Technical Advisory Group 

(TAG), consisting of manufacturers, trade associations, and gas utility representatives helped 

to guide the project by assuring realistic costs, approaches and issues were considered. 

As I mentioned in my previous testimony, an interim report(1) was published in 

July 1993 and reviewed with DOE staff at a meeting in September of 1993. Due to time 

constraints, DOE was unable to incorporate the results of our study into the NOPR. We plan 

to submit an additional report covering the new design options as our July 18, 1994, written 

submission. We respectfully request that both of these reports be considered and analyzed 

before a final rule is published. 

Before I comment on the specific design options, I would like to address several 

general issues that impact the economic, safety, and utility attributes of the gas range. 

Annual Gas Usage 

At the core of the economic analysis is the value used for the Annual Useful 

Cooking Energy Output in the DOE Test Procedure. In the 1970s, this value was established 

as 947.5 kBtu/yr for gas cooktops and 160.7 kBtu/yr for gas ovens. Recognizing that 

cooking habits have drastically changed since the time the DOE values were established, 

DOE averaged four estimates of gas range annual energy use published between 1984 to 

1988. Only one of these studies (Southern California Edison-1988) was based upon metered 

data. All three of the other non-metered conditional demand analysis (CDA) studies were 

higher than the metered data (actual values, 34.4 therms for the metered data, 44, 42, and 

46.7 therms respectively for the CDA studies). DOE obtained an average of 41.8 therms 
B-li

from this data to determine an "adjusted" cooking energy output value of 732.5 kBtu/yr for

gas cooktops and 124.2 kBtu/yr for gas ovens. If only the metered data had been used, the

adjusted cooking energy output for cooktops would be 602 kBtu/yr and 102 kBtu/yr for

ovens.

Southern California Edison Study (1988). The Southern California Edison

study was probably the best data available at that time for gas ranges. There is some

question that this data excluded all pilot lights as DOE assumed. The assumption was made

that, since California banned ranges with pilots in 1978, no ranges with pilots were included

in the study. Since gas ranges have about a 19-year life, it is possible that some piloted

ranges were included in the study. It is not clear that all ranges with pilots were excluded

from the study.

GRI Gas Metered Study. Recent experimental data gathered on gas ranges1

show much lower usage than in the past. This is partially a result of lifestyle changes, more

use of microwave ovens, and other new convenience cooking products. For example, in

1984, microwave ovens were at 42 percent market saturation, but by 1988 (the year of the

Southern California Edison Study) they had reached 76 percent saturation. Currently,

microwave ovens have reached an 85 percent market saturation.2

In our interim report', we submitted data to DOE from an extensive metered

study of gas ranges and ovens that was conducted from 1990 to 1992 (see Appendix F of the

GRI report). This study determined that Annual Gas Cooking Energy Consumption usage

factors have dramatically decreased from the baseline 1984 to 1988 data used in the DOE's

NOPR analysis. The current data indicate that the Annual Useful Cooking Energy Output

should be further reduced to about 429.5 kBtu/yr for gas cooktops and 91.8 kBtu/yr for gas

ovens (see Appendix D of the GRI report).

Also, the number of self-clean cycles for gas ovens assumed by DOE seems

unrealistic for current levels of oven use. For gas ovens, if the number of self-clean cycles

were reduced in the same ratio as the reduction in annual gas usage, the value would drop

from 7 to 4. An effort is being made to obtain some actual consumer usage data for selfcleaning and this data is expected to show an average value for about 2 to 3 cleaning cycles

per year. We request that the GRI metered study data be considered in the rulemaking

process.

Design Option First Cost

We are in general agreement with the DOE concerning the life-cycle cost

methodology; however, DOE's estimates of first cost for some of the gas design options are

low. Specific examples of low first cost estimates will be included in our written comments,

and some remarks will be included later when talking about specific design options.

In our interim report' we supplied updated incremental cost information from

manufacturers for each of the ANOPR design options.

EE-RM-90-201 COMMENT OOR13

B-ll 

from this data to determine an "adjusted" cooking energy output value of 732.5 kBtu/yr for 

gas cooktops and 124.2 kBtu/yr for gas ovens. If only the metered data had been used, the 

adjusted cooking energy output for cooktops would be 602 kBtu/yr and 102 kBtu/yr for 

ovens. 

Southern California Edison Study (1988). The Southern California Edison 

study was probably the best data available at that time for gas ranges. There is some 

question that this data excluded all pilot lights as DOE assumed. The assumption was made 

that, since California banned ranges with pilots in 1978, no ranges with pilots were included 

in the study. Since gas ranges have about a 19-year life, it is possible that some piloted 

ranges were included in the study. It is not clear that all ranges with pilots were excluded 

from the study. 

GRI Gas Metered Study. Recent experimental data gathered on gas ranges(l) 

show much lower usage than in the past. This is partially a result of lifestyle changes, more 

use of microwave ovens, and other new convenience cooking products. For example, in 

1984, microwave ovens were at 42 percent market saturation, but by 1988 (the year of the 

Southern California Edison Study) they had reached 76 percent saturation. Currently, 

microwave ovens have reached an 85 percent market saturation. (2) 

In our interim report(l), we submitted data to DOE from an extensive metered 

study of gas ranges and ovens that was conducted from 1990 to 1992 (see Appendix F of the 

GRI report). This study determined that Annual Gas Cooking Energy Consumption usage 

factors have dramatically decreased from the baseline 1984 to 1988 data used in the DOE's 

NOPR analysis. The current data indicate that the Annual Useful Cooking Energy Output 

should be further reduced· to about 429.5 kBtu/yr for gas cooktops and 91.8 kBtu/yr for gas 

ovens (see Appendix D of the GRI report). 

Also, the number of self-clean cycles for gas ovens assumed by DOE seems 

unrealistic for current levels of oven use. For gas ovens, if the number of self-clean cycles 

were reduced in the same ratio as the reduction in annual gas usage, the value would drop 

from 7 to 4. An effort is being made to obtain some actual consumer usage data for selfcleaning and this data is expected to show an average value for about 2 to 3 cleaning cycles 

per year. We request that the GRI metered study data be considered in the rulemaking 

process. 

Design Option First Cost 

We are in general agreement with the DOE concerning the life-cycle cost 

methodology; however, DOE's estimates of first cost for some of the gas design options are 

low. Specific examples of low first cost estimates will be included in our written comments, 

and some remarks will be included later when talking about specific design. options. 

In our interim report(l) we supplied updated incremental cost information from 

manufacturers for each of the ANOPR design options. 
B-12

Gas Fuel Price Projections

We believe that the life-cycle cost data should be updated by DOE to use current

DOE Energy Information Administration estimates of future fuel cost projections rather than

the 1991 estimated projections that were used in the NOPR. Further, we can find no

justification for the price multiplier of 1.2 for gas and 1.04 for electricity that was used in

the NOPR (see Vol. E, Appendix B and Vol. 1, pg. 5-5 of the Technical Support Document,

TSD). Almost every home that has a gas range also has a gas furnace or water heater or

both. The consumer gets a single bill that does not separate range gas use from the other

appliances. For gas ranges, the DOE multiplier amounts to a 20 percent fuel cost penalty

over the cost per therm paid for gas. We see no reason to single out ranges as using more

expensive fuel. We suggest that these multipliers be eliminated for life-cycle cost

calculations.

Cooking Ouality

The effect of the DOE design options on cooking quality were not addressed in

the NOPR or the TSD. This is probably the area of greatest impact and concern to the

consumer. If a design option affects the cooking ability of a range or produces results that

are not expected or acceptable to the consumer, it should not be mandated. Many of the

DOE design options do have the potential to affect the cooking process or eliminate useful

cooking features. The small amounts of energy saved simply do not justify design options

that impact on food and cooking quality. Consumers expect that traditional and family

recipes be reproducible, have expected quality, be easy to prepare, and do not require

mathematical conversions to offset changes in oven performance dictated by design option

changes. Ranges have reached a state of maturity that allows quality cooking for a wide

variety of foods. Any modification made to increase efficiency must not negatively impact

expected cooking performance or features, thereby decreasing the usefulness of the range to

the consumer. Many DOE design options have the potential to affect the cooking process or

eliminate useful features. These factors must therefore be carefully considered.

Other Criteria

Other criteria that were not adequately addressed in the NOPR or TSD are the

effects of the design options on consumer safety, cost of compliance, and product utility.

New Design Options

Let me now address a few specifics on the five new design options that were

published in the NOPR (Figure 1) and determined by DOE to be cost effective for gas

ranges. I will briefly describe the areas where new data may be used to more accurately

assess the design options. Details will be submitted in the written input on July 18, 1994.

1. Remove Oven Door Window. The GRI analysis based on DOE test

procedure measurements of two typical residential gas ranges (standard and self-cleaning

EE-RM-90-201 COMMENT OOR13

B-12 

Gas Fuel Price Projections 

We believe that the life-cycle cost data should be updated by DOE to use current 

DOE Energy Information Administration estimates of future fuel cost projections rather than 

the 1991 estimated projections that were used in the NOPR. Further, we can find no 

justification for the price multiplier of 1.2 for gas and 1.04 for electricity that was used in 

the NOPR (see Vol. E, Appendix B and Vol. 1, pg. 5-5 of the Technical Support Document, 

TSD). Almost every home that has a gas range also has a gas furnace or water heater or 

both. The consumer gets a single bill that does not separate range gas use from the other 

appliances. For gas ranges, the DOE multiplier amounts to a 20 percent fuel cost penalty 

over the cost per therm paid for gas. We see no reason to single out ranges as using more 

expensive fuel. We suggest that these multipliers be eliminated for life-cycle cost 

calculations. 

Cooking Ouality 

The effect of the DOE design options on cooking quality were not addressed in 

the NOPR or the TSD. This is probably the area of greatest impact and concern to the 

consumer. If a design option affects the cooking ability of a range or produces results that 

are not expected or acceptable to the consumer, it should not be mandated. Many of the 

DOE design options do have the potential to affect the cooking process or eliminate useful 

cooking features. The small amounts of energy saved simply do not justify design options 

that impact on food and cooking qUality. Consumers expect that traditional and family 

recipes be reproducible, have expected quality, be easy to prepare, and do not require 

mathematical conversions to offset changes in oven performance dictated by design option 

changes. Ranges have reached a state of maturity that allows quality cooking for a wide 

variety of foods. Any modification made to increase efficiency must not negatively impact 

expected cooking performance or features, thereby decreasing the usefulness of the range to 

the consumer. Many DOE design options have the potential to affect the cooking process or 

eliminate useful features. These factors must therefore be carefully considered. 

Other Criteria 

Other criteria that were not adequately addressed in the NOPR or TSD are the 

effects of the design options on consumer safety, cost of compliance, and product utility. 

New Design Options 

Let me now address a few specifics on the five new design options that were 

published in the NOPR (Figure 1) and determined by DOE to be cost effective for gas 

ranges. I will briefly describe the areas where new data may be used to more accurately 

assess the design options. Details will be submitted in the written input on July 18, 1994. 

1. Remove Oven Door Window. The GRI analysis based on DOE test 

procedure measurements of two typical residential gas ranges (standard and self-cleaning 
B-13

oven, with and without a windowed door

in each case) show less energy savings

than that assumed by DOE. Since tests

were conducted using only two ranges,

these results may not be representative of

an industry average.

DOE recognized in their -

Technical Support Document that elimi- 5. Reduce Burner Excess Air

nating the oven door would require the

cook to periodically open the door to Figure 2. Table of new DOE design options

view the cooking progress. However, as published in the NOPR and

DOE estimated energy savings assuming determined by DOE to be cost

no oven door openings, claiming the effective

energy losses per opening were very

small. GRI tests show energy losses per door opening are significant. Table 1 gives a

comparison of the DOE calculations of the energy saved by eliminating the window with the

GRI test results.

Energy Saved (Btu/yr)

Type of

Range DOE TSD* GRI Tests**

(no door (4 door

openings/cycle) openings/cycle)

______________

Btu/yr Btu/yr

Gas, Non 80,700 38,600

Self-Cleaning _________________

Gas, Self

_________________

67,000 -9,200

Cleaning

________________ ________________

*TJses DOE Adjusted annual gas usage **Tjses GRI annual gas usage

Table 1. Energy Saved by Eliminating Oven Window

The ORTECH3 study used in the TSD to obtain the efficiency increase for

removing the door window states, "it is highly questionable, however, whether elimination of

the oven window would be acceptable in the marketplace or would even result in any real

energy savings. . ." We agree with this conclusion.

1. Remove Oven Door Window

2. Electric Ignition

3. Improved Door Seals

4. Forced Convection

For perspective, Graph 1 shows the energy cost savings for gas ovens without

windows as a function of the number of door openings. Eliminating a window from a non

EE-RM-90-201 COMMENT OOR13

oven, with and without a windowed door 

in each case) show less energy savings 

than that assumed by DOE. Since tests 

were conducted using only two ranges, 

these results may not be representative of 

an industry average. 

DOE recognized in their 

Technical Support Document that eliminating the oven door would require the 

cook to periodically open the door to 

view the cooking progress. However, 

DOE estimated energy savings assuming 

no oven door openings, claiming the 

energy losses per opening were very 

B-13 

1. Remove Oven Door Window 

2. Electric Ignition 

3. Improved Door Seals 

4. Forced Convection 

5. Reduce Burner Excess Air 

Figure 2. Table of new DOE design options 

as published in the NOPR and 

detennined by DOE to be cost 

effective 

small. GR! tests show energy losses per door opening are significant. Table 1 gives a 

comparison of the DOE calculations of the energy saved by eliminating the window with the 

GR! test results. . 

Energy Saved (Btu/yr) 

Type of 

Range DOE TSD* GRI Tests** 

(no door (4 door 

openings/ cycle) openings/ cycle) 

Btu/yr Btu/yr 

Gas, Non 80,700 38,600 

Self-Cleaning 

Gas, Self 67,000 -9,200 

Cleaning 

*Uses DOE Adjusted annual gas usage **Uses GRI annual gas usage 

Table 1. Energy Saved by Eliminating Oven Window 

The ORTECH(3) study used in -the TSD to obtain the efficiency increase for 

removing the door window states, "it is highly questionable, however, whether elimination of 

the oven window would be acceptable in the marketplace or would even result in any real 

energy savings ... " We agree with this conclusion. 

For perspective, Graph 1 shows the energy cost savings for gas ovens without 

windows as a function of the number of door openings. Eliminating a window from a non 
B-14

self-cleaning oven saves about 23 cents per year with four door openings per cycle, but this

is totally insignificant when the decreased utility of the oven is considered. As shown, with

a self-cleaning oven, there is an actual energy loss amounting to about 5 cents per year by

eliminating the oven window.

The oven window is a feature appreciated by most consumers. The window

allows inspection of the cooking process without door openings that may cause failure of

delicate food items such as souffles, variability in timing, or unacceptable results for some

foods. Of equal, or perhaps greater importance, are the safety issues. Each additional door

opening while the oven is in use provides an increased probability for contact with hot

surfaces or steam. This is of special concern for children or physically limited individuals.

0.50

0.40

0.30

.5 0.20

0.10

D)

.E 0.00

j

-0.30

-0.40

-0.50

012345678910

No. of Oven Door Openings per Test

Graph 1. Energy Cost Savings for Gas Ovens Without Windows

2. Electric Ignition. For this design option, DOE treated cooktops and ovens

as separate appliances, even though over 90 percent of the market is for the combined

appliance or range. In determining life-cycle costs for this option, DOE applied maintenance

costs only to the cooktop. This is incorrect, as the oven will also require maintenance of an

lID device and the chance of failure over the 19-year range life is expected to be similar for

both the cooktop and the oven electric ignition devices.

EE-RM-90-201 COMMENT OOR13

B-14 

self-cleaning oven saves about 23 cents per year with four door openings per cycle, but this 

is totally insignificant when the decreased utility of the oven is considered. As shown, with 

a self-cleaning oven, there is an actual energy loss amounting to about 5 cents per year by 

eliminating the oven window. 

The oven window is a feature appreciated by most consumers. The window 

allows inspection of the cooking process without door openings that may cause failure of 

delicate food items such as souffles, variability in timing, or unacceptable results for some 

foods. Of equal, or perhaps greater importance, are the safety issues. Each additional door 

opening while the oven is in use provides an increased probability for contact with hot 

surfaces or steam. This is of special concern for children or physically limited individuals. 

'i:' 

= i 

as 

--'0 

:E-

" OJ 

c 

1 

fI) 

t; 

o 

o 

>a 

0.50 .......... ......,..-""I""'"'"--r-...,........,r--....,...-or--...... - ...... --. 

0.40 Energy Cost Savings for Gas Ovens 

Without Windows 

0.30 Non-Self-Cleaning Oven 

0.20 

0.10 

0.00 

-0.10 

-0.20 

~ -0.30 

c 

w -0.40 

Self-Cleaning 

Oven 

-0.50 ...... ----....... ---................ -.-"--------...... o 1 2 3 4 5 6 7 8 9 10 

No. of Oven Door Openings per Test 

Graph 1. Energy Cost Savings for Gas Ovens Without Windows 

2. Electric lenition. For this design option, DOE treated cooktops and ovens 

as separate appliances, even though over 90 percent of the market is for the combined 

appliance or range. In determining life-cycle costs for this option, DOE applied maintenance 

costs only to the cooktop. This is incorrect, as the oven will also require maintenance of an 

lID device and the chance of failure over the 19-year range life is expected to be similar for 

both the cooktop and the oven electric ignition devices. 
B-15

•The installation of an electric outlet behind the range will probably be required to

operate the electric ignition devices for a majority of cases where a piloted range will be

replaced with an electric ignition range or even for new installations. DOE did not factor

this cost into the analysis. Currently, about 24 percent of the gas ranges produced in the

United States are piloted. Preliminary analysis indicates that when maintenance, outlet

modification costs, and realistic annual gas usage are considered, this design option is not

economically justified for either the cooktop or the oven. We will be providing additional

information in the written submission.

3. Improved Door Seals. Consultations with manufacturers indicate that oven

door seals have been greatly improved since the 1977 reference cited by DOE3 For

improved door seals, the 7 percent efficiency improvement is not applicable for gas ovens,

based on a thorough review of DOE's cited documentation. To quote, "This improvement

applies primarily to standard electric ovens with little impact on gas-fired standard ovens or

self-cleaning ovens. . . For gas ovens, the amount of air coming in through the door seals is

small compared to the combustion products flowing through the oven. Therefore, improvement of door seals has a negligible effect on gas oven efficiency, "(3) and improved door seals

for gas standard ovens are "infeasible" and "not applicable" for gas self-clean ovens.4

Therefore, this option is not technically or economically justified.

4. Forced Convection. Forced convection gas ovens are a very small fraction

of the residential market (currently only available on commercial-look ranges). The cost of

producing a gas convection oven is considerably more than its electric counterpart since

forced convection interferes with the combustion process, requiring partial isolation of the

combustion chamber from the oven cavity. DOE cost estimates are low for gas convection

and we are currently gathering realistic cost estimates for this design option and will submit

them with the written comments.

Forced convection ovens have unique cooking characteristics that are not

acceptable for all foods. To require all standard ovens to use forced convection would

produce unacceptable results for some traditional foods and the consumer should be able to

choose to use it only when needed. There is also great uncertainty as to the amount of

energy potentially saved by this option. There is great variability in energy savings and food

quality(') depending on the particular food being cooked. Some foods cooked with

convection ovens can actually use more energy than in a standard oven.6

Our preliminary analysis shows that this option will not be economically justified

if realistic first costs and energy savings are used. We will be providing additional

information in the written submission.

5. Reduce Burner Excess Air. The magnitude of efficiency increase achievable

with this option cannot be determined from the TSD or the cited DOE documentation.7 The

burner, as described by DOE, does not exist on the market. The DOE engineering analysis7

gives an efficiency increase of 3 percentage points above the baseline based on an unknown

EE-RM-90-201 COMMENT OOR13

B-15 

The installation of an electric outlet behind the range will probably be required to 

operate the electric ignition devices for a majority of cases where a piloted range will be 

replaced with an electric ignition range or even for new installations. DOE did not factor 

this cost into the analysis. Currently, about 24 percent of the gas ranges produced in the 

United States are piloted. Preliminary analysis indicates that when maintenance, outlet 

modification costs, and realistic annual gas usage are considered, this design option is not 

economically justified for either the cooktop or the oven. We will be providing additional 

information in the written submission. 

3. Improved Door Seals. Consultations with manufacturers indicate that oven 

door seals have been greatly improved since the 1977 reference cited by DOE(3) For 

improved door seals, the 7 percent efficiency improvement is not applicable for gas ovens, 

based on a thorough review of DOE's cited documentation. To quote, "This improvement 

applies primarily to standard electric ovens with little impact on gas-fired standard ovens or 

self-cleaning ovens ... For gas ovens, the amount of air coming in through the door seals is 

small compared to the combustion products flowing through the oven. Therefore, improvement of door seals has a negligible effect on gas oven efficiency, ,,(3) and improved door seals 

for gas standard ovens are "infeasible" and "not applicable" for gas self-clean ovens. (4) 

Therefore, this option is not technically or economically justified. 

4. Forced Convection. Forced convection gas ovens are a very small fraction 

of the residential market (currently only available on commercial-look ranges). The cost of 

producing a gas convection oven is considerably more than its electric counterpart since 

forced convection interferes with the combustion process, requiring partial isolation of the 

combustion chamber from the oven cavity. DOE cost estimates are low for gas convection 

and we are currently gathering realistic cost estimates for this design option and will submit 

them with the written comments. 

Forced convection ovens have unique cooking characteristics that are not 

acceptable for all foods. To require all standard ovens to use forced convection would 

produce unacceptable results for some traditional foods and the consumer should be able to 

choose to use it only when needed. There is also great uncertainty as to the amount of 

energy ~tentially saved by this option. There is great variability in energy savings and food 

quality{ ) depending on the particular food being cooked. Some foods cooked with 

convection ovens can actually use more energy than in a standard oven. (6) 

Our preliminary analysis shows that this option will not be economically justified 

if realistic first costs and energy savings are used. We will be providing additional 

information in the written submission. 

5. Reduce Burner Excess Air. The magnitude of efficiency increase achievable 

with this option cannot be determined from the TSD or the cited DOE documentation. (7) The 

burner, as described by DOE, does not exist on the market. The DOE engineering analysis(7) 

gives an efficiency increase of 3 percentage points above the baseline based on an unknown 
B-16

redesign and shrouding that is also unspecified based upon the references that were given in

the TSD. If DOE has any additional information available for this design option, we request

that it be made available for analysis.

The potential for increased carbon monoxide production exists for burners with -

reduced excess air, which needs to be considered in conjunction with any increased efficiency. This design option cannot be properly evaluated without additional design and

performance information.

Other DOE Design Options

The other DOE proposed design options were discussed in my previous oral

testimony (April 5-7, 1994) and are analyzed in detail in the GRI report1 that has been

submitted to DOE. We will expand this document in the written submission of July 18,

1994, to cover the new DOE design options. To summarize, there were no other DOE

design options that were life-cycle cost justified.

Closure

It is important to realize that a range/oven represents an appliance that has

considerable consumer interaction and expectations. The prime function of a range is to

cook food in an acceptable manner with consistent results. Energy use is typically of far less

importance than food quality to the consumer. Changes in ranges designed to boost efficiency

often change the way the food is cooked and do not make sense if the finished product is

affected in a way that changes consumer expectations and requirements. In most cases, the

above-mentioned factors are much more important than the $15.00 the average household

spends each year to operate a self-cleaning gas range. Furthermore, as we have seen in

recent metered load studies, the amount of energy used in residential ranges has been steadily

decreasing due to shifts in lifestyle, changed eating habits, microwave oven saturation,

supplementary cooking appliances and convenience food products.

Reproducibility of results, food appearance and quality, ease of use, and

cleanability remain the major consumer concerns in range cooking. The ruin of one meal

because the cook could not observe the cooking process, or having to modify traditional or

ethnic recipes to fit new oven characteristics that do not produce the expected results has

greater cost implications than any projected potential energy savings. Any modification

made to increase efficiency must not negatively impact expected cooking performance or

features, thereby decreasing the usefulness of the range to the consumer. Many DOE design

options have the potential to affect the cooking process or eliminate useful features. These

factors must therefore be carefully considered.

I have given a brief summary that describes GRE's project on ranges and ovens

and that enumerates several important elements of a complete and objective analysis of

efficiency levels and the way in which they uniquely impact gas appliances.

EE-RM-90-201 COMMENT OOR13

B-16 

redesign and shrouding that is also unspecified based upon the references that were given in 

the TSD. If DOE has any additional information available for this design option, we request 

that it be made available for analysis. 

The potential for increased carbon monoxide production exists for burners with 

reduced excess air, which needs to be considered in conjunction with any increased efficiency. This design option cannot be properly evaluated without additional design and 

performance information. 

Other DOE Desi::n Options 

The other DOE proposed design options were discussed in my previous oral 

testimony (April 5-7, 1994) and are analyzed in detail in the GRI report(l) that has been 

submitted to DOE. We will expand this document in the written submission of July 18, 

1994, to cover the new DOE design options. To summarize, there were no other DOE 

design options that were life-cycle cost justified. 

Closure 

It is important to realize that a range/oven represents an appliance that has 

considerable consumer interaction and expectations. The prime function of a range is to 

cook food in an acceptable manner with consistent results. Energy use is typically of far less 

importance than food quality to the consumer. Changes in ranges designed to boost efficiency 

often change the way the food is cooked and do not make sense if the finished product is 

affected in a way that changes consumer expectations and requirements. In most cases, the 

above-mentioned factors are much more important than the $15.00 the average household 

spends each year to operate a self-cleaning gas range. Furthermore, as we have seen in 

recent metered load studies, the amount of energy used in residential ranges has been steadily 

decreasing due to shifts in lifestyle, changed eating habits, microwave oven saturation, 

supplementary cooking appliances and convenience food products. 

Reproducibility of results, food appearance and quality, ease of use, and 

cleanability remain the major consumer concerns in range cooking. The ruin of one meal 

because the cook could not observe the cooking process, or having to modify traditional or 

ethnic recipes to fit new oven characteristics that do not produce the expected results has 

greater cost implications than any projected potential energy savings. Any modification 

made to increase efficiency must not negatively impact expected cooking performance or 

features, thereby decreasing the usefulness of the range to the consumer. Many DOE design 

options have the potential to affect the cooking process or eliminate useful features. These 

factors must therefore be carefully considered. 

I have given a brief summary that describes GRI's project on ranges and ovens 

and that enumerates several important elements of a complete and objective analysis of 

efficiency levels and the way in which they uniquely impact gas appliances. 
B-17

In closing, we request that the DOE consider the experimental and analytical

results presented in the GRI report'' the oral testimony, and the written report to be

submitted as we believe that this information is the most thorough and up to date currently

available.

Thank you for your kind consideration and attention.

References

1. Battelle, et aL, Technical Input to NAECA Rulemaking for Gas-Fired Ranges, GRI Interim

Report, GPJ-9310319, July 1993.

2. Appliance Magazine, Annual Survey 1983-1993.

3. ORTECH International. 1989. Energy-Efficient Electrical Product Knowledge Base, Prepared

by ORTECH International, Mississauga, Ontario, Canada, for the Canadian Electrical

Association, C.E.A., No. 821 U 678, October 1989. Citing SAl, 1977, Energy Efficiency

Program for Kitchen Ranges and Ovens, Science Applications, Inc., La Jolla CA. Report No.

HCP/M60727-01, Prepared for DOE under contract CR-04-60727-00. Page 6-23.

4. ORTECH International. 1989. Op. cit. SAl report, Executive Summary, pg. 11, Table D.

5. Lovingood, R. P., DeMerchant, E. A., and Hines, L. J., "Oven Performance in Convection

vs. Radiant Mode," Proceedings of the 45th Annual International Appliance Technical

Conference, May 9-11, 1994, Madison WI.

6. Heist, J., & Cresser, M. L., "Sensory quality and energy use for baking of molasses cookies

prepared with bleached & unbleached flour and baked in infrared, forced air convection, and

conventional deck ovens," Journal of Food Science, Vol. 55, No. 4, 1990, Pg. 1095-1100.

7. U.S. DOE. 1980. Engineering Analysis. Washington, D.C., DOE/CS-0166, June 1980.

EE-RM-90-201 COMMENT OOR13

B-17 

In closing, we request that the DOE consider the experimental and analytical 

results presented in the GRI report(}), the oral testimony, and the written report to be 

submitted as we believe that this information is the most thorough and up to date currently 

available. 

Thank you for your kind consideration and attention. 

References 

1. Battelle, et al., Technical Input to NAECA Rulemaking for Gas-Fired Ranges, GRI Interim 

Report, GRI-93/0319, July 1993. 

2. Appliance Magazine, Annual Survey 1983-1993. 

3. ORTECH International. 1989. Energy-Efficient Electrical Product Knowledge Base, Prepared 

by ORTECH International, Mississauga, Ontario, Canada, for the Canadian Electrical 

Association, C.E.A., No. 821 U 678, October 1989. Citing SAl, 1977, Energy Efficiency 

Program/or Kitchen Ranges and Ovens, Science Applications, Inc., La Jolla CA. Report No. 

HCP/M60727-01, Prepared for DOE under contract CR-04-60727-OO. Page 6-23. 

4. ORTECH International. 1989. Op. cit. SAl report, Executive Summary, pg. 11, Table D. 

5. Lovingood, R. P., DeMerchant, E. A., and Hines, L. J., "Oven Performance in Convection 

vs. Radiant Mode," Proceedings of the 45th Annual International Appliance Technical 

Conference, May 9-11, 1994, Madison WI. 

6. Heist, J., & Cresser, M. L., "Sensory quality and energy use for baking of molasses cookies 

prepared with bleached & unbleached flour and baked in infrared, forced air convection, and 

conventional deck ovens," Journal 0/ Food Science, Vol. 55, No.4, 1990, Pg. 1095-1100. 

7. U.S. DOE. 1980. Engineering Analysis. Washington, D.C., DOE/CS-OI66, June 1980. 

- , 
B-18

EE-RM-90-201 COMMENT OOR13

B-18 

- \ 
Appendix C

Supporting Material

Exhibit 1. Frigidaire Letter

Exhibit 2. Testimony of Lyn Cook

Exhibit 3. Testimony of Russell Zipkin

and Bill Hughes

Exhibit 4. Sears Ad

Exhibit 5. ADL Report

EE-RM-90-201 COMMENT OOR13

Appendix C 

Supporting Material 

Exhibit 1. Frigidaire Letter 

Exhibit 2. Testimony of Lyn Cook 

Exhibit 3. Testimony of Russell Zipkin 

and Bill Hughes 

Exhibit 4. Sears Ad 

. Exhibit 5. ADL Report 
c-i

APPENDIX C. SUPPORTING MATERIAL

Exhibit 1. Frigidaire letter

FRIG!1R

TOt W. Miller

Z, W&.ksr/A. E..tzer

)ay 3,. 1994

uJ& I'tfma.tia or CE

- -

EE-RM-90-201 COMMENT OOR13

C-l 

APPENDIX C. SUPPORTING MATERIAL 

Exhibit 1. Frigidaire letter 

w. Hiller 

z. W&l.ker/A. Uizer 

Hay 3, 1994 

Intn:au:t.i.aa £o~ t)QE 

'1'be toJ..J.gw;j"Dg ~oru.ti.OA ill per yoar request frc:a ~ 

c:azmsc:t.:i.o1:t. bllul til Opcla'Ce KeetiDCj • 

....... 1:' G~ :u.. J)oazt .,.,. .... _ Coakiav~ 

1f.b.ila oar li'tUat.ura azu:l that at CJ1U" cc.petital:1r' ( aetachmeat l~ Jt:I.tctaeDA;d) sUlJq1UIt that· 1M .haa1d. not -0V1ID .a people v.Ul ccmt.iDlIO to do it. Saei.D1J ill de't1ni:tal.y baU.aricIJ :Ul 

t.au. caa.. w. dOll # 'to .aut to 1 .. ". oar coaki ng aUarta to 

ehilDCll ¥bather it 1& 'tha u-. va a:e speDd. to baka QZ" the 

lIOIUIf WIlt PU1; iDto pw:clzaaiD9 • ::oa.t.. 

'bon; S;RPk 'tiM ('RAb II biscuit,« c;gplcw 1" at leaR 2 or 3 

1:.iJIiuaI fill toUCN8 & 

1. wbIq f.u-at az:'QIIIl 1a nO'bId 

3. c .~z';"pm ead. ot au.qg_t:8d caak time 

3. a~ &dditi.crD&l oaalc tiJIa it D •• dlld buad on second 

lock 

Steps 1 uc! Z lllight be switched Vl.th no neeci for sup 3. 

Mdt- S:og~ Time {'USb A'S'.' t Qia.. sal.rele,. SOMd 1 at 

lAiIwuIt lor" ti..- 48 foUowal 

1" 'II'.b.cm fi:Bt a.rt1IM iJI DG'tecl 

2. at. 'IiDllll1Dl ea.d of .~tac:L cook time .. 3. ~ add1t;ozaA1 cook t1mIa U ..sed. huad all sacoDd 

look 

4. ~ adclit.ioDa1 cook ~:lma if aeeclecl ~_ OD 1:h1:cl 

leak 

ApiJa" .~ 1 ud 2 llipt be tnri;tc:becl • .At laut amp 3 will 

ba _adad beaaua o~ 'tbt8 loDq1l%' cook ti1Ie .a that tha ctcma-.. eaa ba tIIUIa:eG. 
C-2

EE-RM-90-201 COMMENT OOR13

C-2 
C-3

COMMENTS BY:

LYN COOK P.H.Ec.

Consulting Home Economist

TO:

THE UNITED STATES DEPARTMENT OF ENERGY

REGARD]NG:

PROPOSED APPLIANCE ENERGY EFFICIENCY STANDARDS FOR

RANGES

JUNE 7, 1994

EE-RM-90-201 COMMENT OOR13

C-3 

COlv.iMENTS BY: 

L YN COOK P.H.Ec. 

Consulting Home Economist 

TO: 

THE UNITED STATES DEPARTMENT OF ENERGY 

REGARDING: 

PROPOSED APPLIANCE ENERGY EffiCIENCY STANDARDS FOR 

RANGES 

JUNE 7,1994 
C-4

WHO AM I

Lyn Cook, a Consulting Professional Home Economist, with 24 years

of diversified experience in consumers affairs, appliance testing

and food service management. I am also a homemaker who enjoys

cooking and baking for my family and friends. I am testifying on

behalf of the Association of Home Appliance Manufacturers.

WHAT AN I TALKING ABOUT

The proposed Department of Energy appliance energy efficiency

standards for ranges. My comments apply to both electric and gas

ranges. The data referred to focuses primarily on electric

ranges.

WHY AM I TESTIFYING

The proposed standards are stringent and impractical. They could

have a major and significant impact on the consumer with regards

to reduced consumer utility, diminished cooking performance,

change of cooking habits, and increased retail cost. My concerns

are with the recommended design options and I will proceed to

discuss why.

EE-RM-90-201 COMMENT OOR13

C-4 

WHO AM I 

Lyn Cook, a Consulting Professional Home Economist, with 24 years 

of diversified experience in consumers affairs, appliance testing 

and food service management. I am also a homemaker who enjoys 

cooking and baking for my family and friends. I am testifying on 

behalf of the Association of Home Appliance Manufacturers. 

WHAT AM I TALKING ABOUT 

The proposed Department of Energy appliance energy efficiency 

standards for ranges. My comments apply to both electric and gas 

ranges. The data referred to focuses primarily on electric 

ranges. 

WHY AM I TESTIFYING 

The proposed standards are stringent and impractical. They could 

have a major and significant impact on the consumer with regards 

to reduced consumer utility, diminished cooking performance, 

change of cooking habits, and increased retail cost. My concerns 

are with the recommended design options and I will proceed to 

discuss why. 
C-5

NO OVEN DOOR WI2OW

"It is highly questionable, however, whether elimination of the

window would be acceptable in the marketplace. . ..' states the

Ortech report from the Canadian Electrical Association -

Independent Lab (1989). To my ]cnwledge, more than half of all

ranges produced today have a window on the oven door. It is a

popular consumer driven feature. To view the cooking process, to

be able to feel confident about and to determine if the food is

cooking properly and to their satisfaction are important

considerations for the consumer. The most effective way to do

this is through the oven door window. It is interesting to note

that this point is specifically referred to in the publication

Consumer Guide to Home Energy Savings, published by the American

Council for an Energy-Efficient Economy.

If the oven window is eliminated, opening the oven door and

peeking into the oven will cause heat loss, longer cooking times

and unsatisfactory baking and cooking results. My observations

from cooking tests, where the oven door is opened repeatedly,

show that foods situated at the front of the over do not brown as

well or cook evenly as those located in the center or back of the

oven. Some testing has been done and the results show that

cooking performance is not acceptable. Rearrangement of the food

in the oven may be necessary in order to cook or bake it properly

and evenly. My past experience tells me that many foods, in

particular, popular baked foods such as cookies and muffins would

be adversely affected.

EE-RM-90-201 COMMENT OOR13

C-5 

NO OVEN DOOR WINDOW 

nIt is highly questionable, however, whether elimination of the 

window would be acceptable in the marketplace .... n states the 

Ortech report fram the Canadian Electrical Association - Independent Lab (~989). To my knowledge, more than half of all 

ranges produced today have a window on the oven door. It is a 

popular consumer driven feature. To view the cooking process, to 

be able to feel confident about and to determine if the food is 

cooking properly and to their satisfaction are important 

considerations for the consumer. The most effective way to do 

this is through the oven door window. It is interesting to note 

that this point is specifically referred to in the publication 

Consumer Guide to Hame Energy Savings, published by the American 

Council for an Energy-Efficient Economy. 

If the oven window is eliminated, opening the oven door and 

peeking into the oven will cause heat loss, longer cooking times 

and unsatisfactory baking and cooking results. My observations 

from cooking tests, where the oven door is opened repeatedly, 

show that foods situated at the front of the ovea do not brown as 

well or cook evenly as those located in the center or back of the 

oven. Some testing has been done and the results show that 

cooking performance is not acceptable. Rearrangement of the food 

in the oven may be necessary in order to cook or bake it properly 

and evenly. My past experience tells me that many foods, in 

particular, popular baked foods such as cookies and muffins would 

be adversely affected. 
C-6

USE OF REFLECTIVE SRPACES

I am concerned with the GR.I report that reflective oven surfaces

are likely to cause an uneven distribution of heat resulting in

hot spots in the oven. Due to the possibility of unpredictable

cooking results, the consumer would have to constantly monitor

the cooking performance of the oven.

I concur with the TSD statement, and I quote, "The reflective

materials degrade after the first baking function and continue to

degrade through the life of the product. This is especially true

of self-cleaning ovens as the self-cleaning process damages the

reflective walls and negates any possible energy savings." It

can be expected that the resulting discoloration would draw

negative consumer reaction. DOE, TSD and .AIThN numbers indicate

that approximately 55 to 58% of all ovens have the self-clean

feature. If implemented, this design option would have limited

appeal to the consumer.

I am also concerned, as is the DOE when they stated in the NPR

for cooktops, and I quote, "... . the Department is concerned about

the longevity of the design option, reflective surfaces,

required to meet this standard." I feel this concern for

longevity is also warranted for oven cavities.

EE-RM-90-201 COMMENT OOR13

C-6 

USE 01' REPLEC'l':IVE Stm.PACES 

I am concerned with the GRI report t~t reflective oven surfaces 

are likely to cause an uneven distribution of heat resulting in 

hot spots in the oven. Due to the possibility of unpredictable 

cooking results, the consumer would have to constantly monitor 

the cooking performance of the oven. 

I concur with the TSD statement, and I quote, "The reflective 

materials degrade after the first baking function and continue to 

degrade through the life of the product. This is especially true 

of self-cleaning ovens as the self-cleaning process damages the 

reflective walls and negates any possible energy savings." It 

can be expected that the resulting- discoloration would draw 

negative consumer reaction. DOE, TSD and AHAM numbers indicate 

that approximately 55 to sst of all ovens have the self-clean 

feature. If implemented, this design option would have limited 

appeal to the consumer. 

I am also concerned, as is the DOE when they staced in the NPR 

for cooktops, and I quote," .... the Department is concerned about 

the longevity of the design option, reflective surfaces, 

required to meet this standard." I feel this concern for 

longevity is also warranted for oven cavities. 

- \ 
C-7

IMPROVED DOOR SEALS / REDUCED VT RATE

I address these two design options together because each is

dependant on the other for good cooking performance.

A complete door seal is not practical on an oven because the

introduction of some air into the oven cavity is necessary for

proper cooking performance.

The primary functions of the vent tube are to exhaust the

products of combustion and the moisture produced by foods during

the cooking process.

If the vent size is restricted, moisture and heat can collect

below the vent area and cause a concentration of heat with the

possibility of overcooking foods situated in that area of the

oven. For example, a tray of cookies would be baked to varying

degrees, some may be overdone, some may be only partially cooked.

In current oven, a proper balance of these two design options has

been established, for a variety of foods with different moisture

contents, so that acceptable cooking performance is achieved.

Any design changes to either the vent tube or the door seal would

have to be subjected to cooking performance tests to determine

whether acceptable results are still being achieved.

EE-RM-90-201 COMMENT OOR13

C-7 

IMPR.OVED POOR. SEALS / "REDUCED VENT RATE 

I address these two design options together because each is 

dependant on the other for good cooking performance. 

A complete door seal is not practical on an oven because the 

introduction of some air into the oven cavity is necessary for 

proper cooking performance. 

The primary functions of the vent tube are to exhaust the 

products of combustion and the moisture produced by foods during 

the cooking process. 

If the vent size is restricted, moisture and heat can collect 

below the vent area and cause a concentration of heat with the 

possibility of overcooking foods situated in that area of the 

oven. For example, a tray of cookies would be baked to varying 

degrees, some may be overdone, some may be only partially cooked . . 

In current oven, a proper balance of these two design options has 

been established, for a variety of foods with different moisture 

contents, so that acceptable cooking p$rfor.mance is achieved. 

Any design changes to either the vent tube or the door seal would 

have to be subjected to cooking perfor.mance tests to determine 

whether acceptable results are still being achieved. 
C-8

REDUCED THERMAL MASS

It has been indicated in the Ortech report that one way of

reducing thermal mass is by going to a 30'c smaller oven cavity.

According tO the publication Consumer Reports, consumers prefer a

larger oven cavity. When I have talked to consumers at Home

shows and in Dealers' showrooms, a large oven cavity is

desirable, whether they are shopping for a new or replacement

oven.

If the oven cavity size is reduced, this would have to be

considered to be a significant loss of use for the consumer. For

instance, even if a household is considered small, with one or

two people, the perception by most consumers is that a large oven

is needed for the few times a year they prepare special meals,

such as family birthday parties or a turkey dinner with all the

trixrnings at Thanksgiving and Christmas.

EE-RM-90-201 COMMENT OOR13

C-8 

It has been indicated in the Ortech report that one way of 

reducing ther.ma1 mass is by going to a 30t smaller oven cavity. 

According to the publication Consumer Reports, consumers prefer a 

larger oven cavity. When I have talked to consumers at Home 

shows and in Dealers' showrooms, a large oven cavity is 

desirable, whether they are shopping for a new or replacement 

oven. 

If the oven cavity size is reduced, this would have to be 

considered to be a significant loss of use for the consumer. For 

instance, even if a household is considered small, with one or 

two people, the perception by most consumers is that a large oven 

is needed for the few times a year they prepare special meals, 

such as family birthday parties or a turkey dinner with a11 the 

trimmings at Thanksgiving and Christmas. 
C-9

FORCED CONVECTION

Consumer resistance is-- expected because a lifetime of cooking

habits which are often passed down from generation to generation

must be changed. The majority of today's consumers are not

willing to spend the time to learn how to convert recipes to

convection temperatures and times.

Favorite family recipes will be affected by time/temperature

changes required for convection cooking. For example, in baked

goods, the temperature adjustment is critical to the texture. If

the outside crust solidifies before the interior has a chance to

rise, a heavy and dense product will result and Grandma's Old

Fashioned Sponge Cake may never be the same again.

In addition, it may be necessary for the consumer to purchase

special pans and racks to achieve maximum browning and even

cooking, adding an additional expense to the purchase of the

oven.

Cookbooks, magazines and newspapers contain recipes which are

written and presented using conventional oven temperatures, times

and instructions. All media communications and presentations

would have to list both conventional and convection instructions.

Preparation and cooking instructions on packaged goods would

require changes. Forced convection cooking would make a

significant impact in all of these areas and may cause the same

type of confusion that occurs when both Metric and Imperial

measurements are listed for a recipe.

If the consumer is not satisfied with the convection cooking

results, the time to cook and the temperature used must be

manipulated in order to obtain the desired cooked product. This

takes time and money for food and can be a frustrating experience

for people who enjoy cooking and take pride in their results.

Give the consumer the option to cook conventionally or by

convection. Otherwise, I feel a major educational program for

all consumers would be a definite necessity.

EE-RM-90-201 COMMENT OOR13

C-9 

PORCED CONVECTION 

Consumer resistance is,· expected because a lifetime of cooking 

habits which are often passed down fram generation to generation 

must be changed. The ,majority of today's consumers are not 

willing to spend the time to learn how to convert recipes to 

convection temperatures and times. 

Favorite family recipes will be affected by time/temperature 

changes required for convection cooking. For example, in baked 

goods, the temperature adjustment is critical to the texture. If 

the outside crust solidifies before the interior has a chance to 

rise, a heavy and dense product will result and Grandma's Old 

Fashioned Sponge Cake may never be the same again. 

In addition, it may be necessary for the consumer to purchase 

special pans and racks to achieve maximum browning and even 

cooking, adding an additional expense to the purchase of the 

oven. . 

Cookbooks, magazines and newspapers contain recipes which are 

written and presented using conventional oven temperatures, times 

and instructions. All media communications and presentations 

would have to list 'both conventional and convection instructions. 

Preparation and cooking instructions on packaged goods would 

require changes. Forced convection cooking would make a 

significant impact in all of these areas and may cause the same 

type of confusion that occurs when both Metric and Imperial 

measurements are listed for a recipe. 

If the consumer is not satisfied with the convection cooking 

results, the time to cook and the temperature used must be 

manipulated in order to obtain the desired cooked product. This 

takes time and money for food and can be a frustrating experience 

for people who enjoy cooking and take pride in their results. 

Give the consumer the option to cook conventionally or by 

convection. Otherwise, I feel a major educational program for 

all consumers would be a definite necessity. 
c-b

In conclusion, I question if these changes were proposed by

anyone who cooks. I suggest you ask the person who does the

cooking in your home how they feel about these changes and how

they will affect the foods you enjoy eating.

On behalf of AHAM and the consumer, thank you for the opportunity

to put forth our concerns about the proposed DOE recommended

design options.

EE-RM-90-201 COMMENT OOR13

C-IO 

In conclusion, I question if these changes were proposed by 

anyone who cooks. I suggest you ask the person who does the 

cooking in your home how they feel abqut these changes and how 

they will affect the foods you enjoy eating. 

on behalf of AHAM and the consumer, thank you for the opportun;ty 

to put forth our concerns about the proposed DOE recommended 

design options. 
c-il

I am Russell. Zipkin, co-founder of the Russell Range Co., based near San Francisco.

It is an honor to be hear today. As an American and a consumer of energy myself, I

would like to say that I respect highly, the principaLs behind your attempt to reduce

energy waste.

Russell Range is part of a new segment of the appliance industry. We manufacture

high capacity cooking products which offer the utility of restaurant equipment to the

home chef. Russell Range is a pure example of small American Entrepreneurial

Companies which manufacture products created purely out of consumer demand.

The small group of manufacturers in this niche market, not to mention the other

support companies such as shippers, distributors, dealerships and advertising

coinparues will all suffer greatly when we and our products disappear. Which will

happen because of this particular rulemaking.

Our niche was created when consumers began purchasing the same tools and

equipment that professional chefs in restaurants have been using for many years.

Large and small companies all over the world such as, Cuisinart, Krups, General

Housewares, Viking Range and others began supplying products such as food

processors, large heavy duty aluminum cookware, fine cutlery, hand held blenders

and high powered multi featured cooktops, ovens and ranges. The simple fact is,

that our small niche market was created because our consumers, desire products

that deliver as much energy as possible.

This growing "Gourmet Industry" is coupled with tremendous sales in associated

industries such as fine wines, cookbooks, sauces, gadgets, dinnerware and much

more. At the forefront of this culinary renaissance, are companies such as VIKING

RANGE, WOLF RANGE, GARLAND RANGE, FIVE STAR, SUB-ZERO,

NORTHLAND and RUSSELL RANGE. All of these companies can trace their

origins to the restaurant equipment industry where professional chefs are free to

create food works of art because of the tools available to them and the full range of

power they deliver.

What we and the other companies created, are products that offer similar utility, but

pass much stricter safety and efficiency standards for home installation, than do

regular restaurant ranges. No continuous burning pilot lights, slightly lower BTIJ

burners, zero clearance cabinets, push to turn knobs and more, are all examples of

the efforts we put into improving the basic concept for the home owner. Now,

consumers whom choose to have the cooking power and benefits of a professional

range in their home kitchen, can. This is a critical point We are talking about the

freedom to choose a high energy delivering product, because it suits their lifestyle.

The fastest growing and most successful segment of the home building industry, in

the past few years, is remodeling. Architects, designers and custom builders alike

have recognized the flexibility, importance and demand for our high powered, high

capacity products. Statistically, the most commonly remodeled room in the home

is the kitchen. That has been true for some time, however, now they are larger, on

average, then ever before, often including work islands, pot racks, double ovens, big

EE-RM-90-201 COMMENT OOR13

C-ll 

I am Russell Zipkin, co-founder of the Russell Range Co., based near San Francisco. 

It is an honor to be hear today. As an American and a consumer of energy myself, I 

would like to say that I respect highly, the principals behind your attempt to reduce 

energy waste. 

Russell Range is part of a new segment of the appliance industry. We manufacture 

high capacity cooking products which offer the utility of restaurant equipment to the 

home chef. Russell Range is a pure example of small American Entrepreneurial -~ 

Companies which manufacture products created purely out of consumer, demand. 

The small group of manufacturers in this niche market, not to mention the other 

support companies such as shippers, distributors, dealerships and advertising 

companies will all suffer greatly when we and our products disappear. Which will 

happen because of this particular rulemaking. 

Our niche was created when consumers began purchasing the same tools and 

equipment that professional chefs in restaurants have been using for many years. 

Large and small companies all over the world such as, Cuisinart, Krups, General 

Housewares, Viking Range and others began supplying products such as food 

processors, large heavy duty aluminum cookware, fine cutlery, hand held blenders 

.and high powered multi featured cooktops, ovens and ranges. The simple fact is, 

that our small niche market was created because our consumers, desire products 

that deliver as much energy as possible. 

This growing "Gourmet Industry" is coupled with tremendous sales in associated 

industries such as fine wines, cookbooks, sauces, gadgets, dinnerware and much 

more. At the forefront of this culinary renaissance, are companies such as V1I<ING 

RANGE, WOLF RANGE, GARLAND RANGE, FIVE STAR, SUB-ZERO, 

NORmLAND and RUSSELL RANGE. All of these companies can trace their 

origins to the restaurant equipment industry where professional chefs are free to 

create food works of art because of the tools available to them and the full range of 

power they deliver. 

What we and the other companies created, are products that offer similar utility, but 

pass much stricter safety and efficiency standards for home installation, than do 

regular restaurant ranges. No continuous burning pilot lights, slightly lower BTIJ 

burners, zero clearance cabinets, push to turn knobs and more, are all examples of 

the efforts we put into improving the basic concept for the home owner. Now, 

consumers whom choose to have the cooking power and benefits of a professional 

range in their home kitchen, can. This is a critical point. We are talking about the 

freedom to choose a high energy delivering product, because it suits their lifestyle. 

The fastest growing and most successful segment of the home building industry, in 

the past few years, is remodeling. Architects, designers and custom builders alike 

have recognized the flexibility, importance and demand for our high powered, high 

capacity products. Statistically, the most commonly remodeled room in the home 

is the kitchen. That has been true for some time, however, now they are larger, on 

average, then ever before, often including work islands, pot racks, double ovens, big 
C-12

refrigerators, extra sinks arid most of all room to entertain in. Articles have been

written about the "Cocooning of America", where, more and more good

entertainment means friends and families gathering at the dinner table. The

cooking enthusiast, is our customer and they demand the tools the professionals

use.

I have been told by my colleagues in the industry, that this energy use issue will not

just go away and that my presentation should be about the pending elimination of

Russell Range as a company if the test procedure, as outlined in the rulemaking is

instituted. This test, by the way, was devised in a laboratory in 1977, a full 10 years

before the first high powered household range was introduced. it is simply not an

appropriate test procedure for our type of product We, as a small niche

manufacturer in the appliance industry, need to inform you that we now exist and

should be given a separate classification, so that new test procedures can be devised.

That having been said, my executive chef and I wish to spend our small remaining

amount of time here submitting to you that regulating the energy availability of a

cooking appliance and the freedom to choose these products is akin to telling all

painters that they can only use red from now on or that you can only have one tool

in your workshop. It could also be dangerous. Who amongst you, wants the

responsibility of making sure that people are cooking their chicken or pork

thoroughly. Do you remember the problem that '7ack-In-The-Box" had recently

because their griddles were not hot enough? And, if you say that they can just cook

it longer on the lower flame, then what energy are you saving?

Cooking is pure creativity. The equipment we make delivers only energy, which

the chef must harness and manipulate to create a meal. For thousands of years all

around the world, people have devised different cooking methods using differnt

energy sources, cookware, and ingredients.

I am sure you have enjoyed Chinese, Italian, Mexican, and French foods. All of

which are wonderful but each of which is different. The variables involved in

cooking are complex and many. Every culture has developed their own styles and

flavors. Convienience appliances around the world, on the other hand, all produce

the same result. We don't go out of our way for ethnic refrigerators like we do for

their food.

Here is my main point.

There are appliances of creativity, such as cook tops and ovens, and there are

appliances of convenience, such as dishwashers, refrigerators, water heaters and

clothes washers. The resulting utility of convenience appliances is universally

accepted by all consumers. A clean dish is a clean dish. Now, if the convenience

appliance industry can achieve those universal results more efficiently, it is good for

everybody. However, cooking appliances cannot and must not be lumped into that

same appliance category. The process of cooking escapes rigid standardization.

How many ways do you know to cook a chicken?

EE-RM-90-201 COMMENT OOR13

C-12 

refrigerators, extra sinks and most of all room to entertain in. Articles have been 

written about the "Cocooning of America", where, more and more good 

entertainment means friends and families gathering at the dinner table. The 

cooking enthusiast, is our customer and they demand the tools the professionals 

use. 

I have been told by my colleagues in the industry, that this energy use issue will not 

just go away and that my presentation should be about the pending elimination of --

Russell Range as a company if the test procedure, as outlined in the rulemaking is 

instituted. This test, by the way, was devised in a laboratory in 1977, a full 10 years 

before the first high powered household range was introduced. It is simply not an 

appropriate test procedure for our type of product. We, as a small niche . 

manufacturer in the appliance industry, need to inform you that we now exist and 

should be given a separate classification, so that new test procedures can be devised. 

That having been said, my executive chef and I wish to spend our small remaining 

amount of time here submitting to you that regulating the energy availability of a 

cooking appliance and the freedom to choose these products is akin to telling all 

painters that they can only use red from now on or that you can only have one tool 

in your workshop. It could also be dangerous. Who amongst you, wants the 

responsibility of making sure that people are cooking their chicken or pork 

thoroughly. Do you remember the problem that ''Jack-In-The-Box'' had recently 

because their griddles were not hot enough? And, if you say that they can just cook 

it longer on the lower flame, then what energy are you saving? 

Cooking is pure creativity. The equipment we make delivers only energy, which 

the chef must harness and manipulate to create a meal. For thousands of years all 

around the world, people have devised different cooking methods using differnt 

energy sources, cookware, and ingredients. 

I am sure you have enjoyed Chinese, Italian, Mexican, and French foods. All of 

which are wonderful but each of which is different. The variables involved in 

cooking are complex and many. Every culture has developed their own styles and 

flavors. Convienience appliances around the world, on the other hand, all produce 

the same result. We don't go out of our way for ethnic refrigerators like we do for 

their food. 

Here is my main point. 

There are appliances of creativity, such as cook tops and ovens, and there are 

appliances of convenience, such as dishwashers, refrigerators, water heaters and 

clothes washers. The resulting utility of convenience appliances is universally 

accepted by all consumers. A clean dish is a clean dish. Now, if the convenience 

appliance industry can achieve those universal results more efficiently, it is good for 

everybody. However, cooking appliances cannot and must not be lumped into that 

same appliance category. The process of cooking escapes rigid standardization. 

How many ways do you know to cook a chicken? 
APPLIANCES

[UniversalBy

OF CONVENIENCE

accepted results]

9

EE-RM-90-201 COMMENT OOR13

APPLIANCES OF CREATIVITY.IAPPLIANCES OF CONVENIENCE 

[lnnnately variable results] 

• Cooktops 

• Ovens 

[Universally accepted results] 

• Dishwashers 

• Garbage Disposals 

• Compactors 

• Clothes Washer 

• Clothes Dryer I 

• Refrigerators 

• Food Warmers 

• Countertop Appliances 

(Toaster, blender, food 

processor) 

(') 

I 

I-' 

Vl 
C-14

Having the freedom to choose a high capacity cooking product gives the cooking

enthusiast the full range of heat energy they need to be as creative as their favorite

restaurant chef.

In cooking, high power burners are only used at maximum output for particular

cooking operations and when cooking large quantities of food in large cookware. It

is that power availability on demand that our customers want and is a special utility

that all great chefs will tell you is a mu.t.

I would now like the executive chef at Russell Range, Mr. Bill Hughes to comment

on the special utility we offer the consumer and its importance in cooking.

(After Mr. Hughes)

In summary, the entire segment of the market we call "high-capacity" cooking

products is very unique. Consumer driven, they are products chosen because they

deliver cooking abilities impossible to achieve with low energy consuming products

and suit the lifestyle of a growing segment of the population.

Certainly, if nothing else, high capacity products like ours must be judged and tested

under different considerations.

The test criteria as written in 1977 simply did. not anticipate the oversized burners

and extra large capacity ovens that we now make. This graphic illustrates the simple

fact that much of our burners usable energy is lost when a 9" block is placed on our

burner in the high position.

It is the opinion of Russell Range, however, that the Department of Energy should

reanalyze the wisdom of mandating restrictions on all creativity appliances. Indeed,

the enthusiasm for great cooking that products like ours make possible, is perhaps

one of the best ways that we as a country can get back the family values we seem to

be losing. Look into your own past and I'm sure that many great memories are of

your family at the dinner table. Limiting the creative freedoms in cooking whether

professionally or for ones family and friends would be a mistake.

Thank you

EE-RM-90-201 COMMENT OOR13

C-14 

Having the freedom to choose a high capacity cooking product gives the cooking 

enthusiast the full range of heat energy they need to be as creative as their favorite 

restauran t chef. 

In cooking, high power burners are only used at maximum output for particular 

cooking operations and when cooking large quantities of food in large cookware. It 

is that power availability on demand that our customers want and is a special utility -' 

that all great chefs will tell you is a m~t. 

I would now like the executive chef at Russell Range, Mr. Bill Hughes to comment 

on the special utility we offer the consumer and its importance in cooking. 

(After Mr. Hughes) 

In summary, the entire segment of the market we call "high-capacity" cooking 

products is very unique. Consumer driven, they are products chosen because they 

deliver cooking abilities impossible to achieve with low energy consuming products 

and suit the lifestyle of a growing segment of the population. 

Certainly, if nothing else, high capacity products like ours must be judged and tested 

under different considerations. 

The test criteria as written in 1977 simply did not anticipate the oversized burners 

and extra large capacity ovens that we now make. This graphic illustrates the simple 

fact that much of our burners usable energy is lost when a 9" block is placed on our 

burner in the high position. 

It is the opinion of Russell Range, however, that the Department of Energy should 

reanalyze the wisdom of mandating restrictions on all creativity appliances. Indeed, 

the enthusiasm for great cooking that products like ours make possible, is perhaps 

one of the best ways that we as a country can get back the family values we seem to 

be lOSing. Look into your own past and I'm sure that many great memories are of 

your family at the dinner table. Untiting the creative freedoms in cooking whether 

professionally or for ones family and friends would be a mistake. 

Thank you 
C-15

Good afternoon. I am Bill Hughes, executive chef for Russell Range. I appear before

you today as a cook not a scientist It would be more natural for me to speak of a

favorite recipe, a memorable lunch or a great dinner.

Yet, cooking is science, too. Consider that each of the basic principles of heat

transfer- conduction, convection, and radiation-p combined with a specific cooking

method- roasting, sauté, stir-fry-achieve unique results. What happens to food

when we begin to cook appears to be quite simple. Browning is anything but simple.

It involves sugars- both complex and simple- their molecules and polymers

reacting in hundreds of different ways.

Browning produces flavors that are characteristic of the cooking process, rather than

enhancing or modifying the flavors that are intrinsic to the food itself as one

achieves through seasoning.

Browning takes place at a significant rate only at relative high temperature. Large

amounts of energy are required to force the initial molecular interactions. In other

words, the surface temperature must rise fast enough to sear the outside of the food

and not allow the internal temperature to reach 212 degrees F. These surface

temperatures vary between 300 and 500 degrees.

The simple act of heating a pan of water on the stove involves radiation and

convection from a gas flame, conduction through the pan and convection in the

water. it is therefore difficult to understand how heating a block of aluminum

using conduction only- can begin to assess the kind of heat required in order to

cook properly.

Techniques such as baking and griddle cooking have reference made to them as far

back as 6,000 b.c. Pan frying, stir-frying, and sautéing all enjoy long histories. All

have been refined with subtleties developed, nuances enjoyed. All require the

application of high heat at sometime during the cooking process. Peanut oil used in

stir fry heats to 440 degrees before it begins to smoke. Safflower oil to 510 degrees.

The demand for our product comes from the simple fact that low power

conventional cook tops are incapable for producing the same desired result as high

power cooktops. This is why our stirfry vegetable at home never measure up to

those at our favorite Asian restaurant. Insufficient heat to maintain temperature

high enough to sear the out side before the interior reaches 212 degrees and begins to

give off their liquids.

Irene Kuo in The Key to Chinese Cooking states that 'The importance of capturing

and retaining the heat of the pan and the energy of fast stirring within the dish

cannot be overemphasized.

And Barbara Tropp writes in The Modem Art of Chinese Cooking that "without a

steady source of truly high heat with which to begin, stir-frying is next to impossible.

EE-RM-90-201 COMMENT OOR13

C-15 

Good afternoon. I am Bill Hughes, executive chef for Russell Range. I appear before 

you today as a cook not a scientist. It would be more natural for me to speak of a 

favorite recipe, a memorable lunch or a great dinner. 

Yet, cooking is science, too. Consider that each of the basic principles of heat 

transfer- conduction, convection, and radiation ... combined with a specific cooking 

method- roasting, saute, stir-tty-achieve unique results. What happens to food 

when we begin to cook appears to be quite simple. Browning is anything but simple. -' 

It involves sugars- both complex and simple- their molecules and polymers 

reacting in hundreds of different ways. .. 

Browning produces flavors that are characteristic of the cooking process, rather than 

enhancing or modifying the flavors that are intrinsic to the food itself as one 

achieves through seasoning. 

Browning takes place at a significant rate only at relative high temperature. Large 

amounts of energy are required to force the initial molecular interactions. In other 

words, the surface temperature must rise fast enough to sear the outside of the food 

and not allow the internal temperature to reach 212 degrees F. These surface 

temperatures vary between 300 and 500 degrees. 

The simple act of heating a pan of water on the stove involves radiation and 

convection from a gas flame, conduction through the pan and·convection in the 

water. It is therefore difficult to understand how heating a block of aluminum 

using conduction only- can begin to assess the kind of heat required in order to 

cook properly. 

Techniques such as baking and griddle cooking have reference made to them as far 

back as 6,000 b.c. Pan frying, stir-frying, and sauteing all enjoy long histories. All 

have been refined with subtleties developed, nuances enjoyed. All require the 

application of high heat at sometime during the cooking process. Peanut oil used in 

stir fry heats to 440 degrees before it begins to smoke. Safflower oil to 510 degrees. 

The demand for our product comes from the simple fact that low power 

conventional cook tops are incapable for producing the same desired result as high 

power cooktops. This is why our stirfry vegetable at home never measure up to 

those at our favorite Asian restaurant. Insufficient heat to maintain temperature 

high enough to sear the out side before the interior reaches 212 degrees and begins to 

give off their liquids. 

Irene Kuo in The Key to Chinese Cooking states that ''The importance of capturing 

and retaining the heat of the pan and the energy of fast stirring within the dish 

cannot be overemphasized. 

And Barbara Tropp writes in The Modern Art of Chinese Cooking that "without a 

steady source of truly high heat with which to begin, stir-frying is next to impossible. 
C-16

The use of high heat is called for at some time every cuisine. Paul Prudhomme

writes in The Louisiana Kitchen of using high heat to achieve the results of his

famous blacken redflsh.

As a cook I am concerned that my ability to call upon the tools of the trade may be

restricted. There are homes throughout the country that, out of want or necessity,

use large, oversized cookware. It is not unusual in the preparation of Mexican food

to use a 15 to 20 quart stock pot. The ability to cook small amounts of food faststirfry and sauté- or to cook large amounts of food efficiently and economically is

the spedflc utility that is endangered. To attain safe levels of heat, maintain those

levels and to cook evenly the cook must call upon the unique utility of high heat

capability. Imagine trying to cook a couple of chickens in a 14 inch skillet over a 2

1/2 inch burner.

Virtually all recipes- designed for the home or the restaurant professional chefemploy the use of timing. Why?- because certain taste, flavors, and textures are

sought. It takes time, coupled with heat, combined with ingredients to make the

food we eat everyday.

Fmally, having the high energy/high flame utility available is akin to using the

passing gear in your car. You use it when its called for, not a 100 % of the time.

EE-RM-90-201 COMMENT OOR13

C-16 

The use of high heat is called for at some time every cwsme. Paul Prudhomme 

writes in The Louisiana Kitchen of using high heat to achieve the results of his 

famous blacken redfish. 

As a cook I am concerned that my ability to call upon the tools of the trade may be 

restricted. There are homes throughout the country that, out of want or necessity, 

use large, oversized cookware. It is not unusual in the preparation of Mexican food 

to use a 15 to 20 quart stock pot. The ability to cook small amounts of food faststirfry and saute- or to cook large amounts of food effidently and economically is 

the specific utility that is endangered. To attain safe levels of heat, maintain those 

levels and to cook evenly the cook must call upon the unique utility of high heat 

capability. Imagine trying to cook a couple of chickens in a 14 inch skillet over a 2 

1/2 inch burner. 

Virtually all redpes- designed for the home or the restaurant professional chefemploy the use of timing. Why?- because certain taste, flavors, and textures are 

sought. It takes time, coupled with heat, combined with ingredients to make the 

food we eat everyday. 

Fmally, having the high energy/high flame utility available is akin to using the 

passing gear in your car. You use it when its called for, not a 100 % of the time. 
ALUMINUM TEST BLOCK

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EE-RM-90-201 COMMENT OOR13

ALUMINUM TEST BLOCK 

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C-18

EE-RM-90-201 COMMENT OOR13

C-18