APPENDIX 5-C. ENGINEERING QUESTIONNAIRES

TABLE OF CONTENTS

5-C.1 RESIDENTIAL CLOTHES DRYER ENGINEERING QUESTIONNAIRE....... 5-C-1

5-C.2 ROOM AIR CONDITIONER ENGINEERING QUESTIONNAIRE................ 5-C-11

5-C-iAPPENDIX 5-C. ENGINEERING QUESTIONNAIRES

5-C.1 RESIDENTIAL CLOTHES DRYER ENGINEERING

QUESTIONNAIRE

The engineering questionnaire used as a guide for engineering discussions during

manufacturer interviews is shown in this sec tion. Some of the information provided in

the questionnaire has been red acted to protect vendor information.

5-C-1DESIGN FOR ENERGY IMPROVEME NT INFORMATION REQUEST

The United States Department of Energy (DOE) is currently reviewing energy

conservation standards for residential clothes dryers. DOE would like to confirm

information on the incremental costs of increasing product efficiency by understanding

the design options involved in the efficiency improvement.

1. Market Share of products you sell

To help DOE discover manufacturer sub-groups and the relative importance of various

product classes to specific manuf acturers, please disaggregate your annual unit shipments

for each product category as shown below. Please also indicate whether you purchase

these products from other manufacture rs (i.e. private label), and whether the factory that

supplies the product is located in the United States.

Product Class % Private

Label % Made in US Yearly Unit

Shipments

Vented Electric Standard

Vented Electric Compact, 120V

Vented Electric Compact, 240V

Vented Gas

Vent

- less Electric Compact, 240V

Vent-less Electric Combination

Washer/Dryer

2. Product Design Features

The following series of exhibits and questions a ddress technical characteristics of key

residential clothes dryer components for both baselin e and improved-efficiency products.

Baseline Clothes Dryers

Which design features impacting energy use are generally incorporated into a

“baseline” clothes dryer (i.e. one that just meets existing energy factor standards,

if any) in the following product classes:

o Vented Electric Standard?

o Vented Electric Compact, 120V?

o Vented Electric Compact, 240V?

o Gas?

o Vent-less Electric Compact, 240V?

o Vent-less Electric Combination Washer/Dryer?

5-C-2Vented Clothes Dryers

DOE has updated the efficiency levels for the ve nted clothes dryer analysis that were

presented in the Framework Document, base d upon the more recent November 2008

California Energy Commission (CEC) direc tory and 2008 Natural Resources Canada

(NRCAN) directory (for electric compact (240V) only). Values that are different than

those in the Framework Document are highlighted in blue in the table below.

Since insufficient product data was available fo r electric compact (120V) clothes dryers,

the efficiency levels for this product class were generated by applying a scaling factor

developed using the relationship between the curr ent standards for the electric standard

and electric compact (120V) produc t classes (equal to 3.13/3.01 = 1.04).

Are the updated maximum availa ble efficiency levels appropriate?

Do you agree with the methodology that was used to generate the electric

compact (120 V) efficiency levels?

Do you believe that the gap-fill efficienc y levels defined by DOE for vented

electric standard, electric compact, and gas clothes dryers are representative? If

not, can you suggest appropriate gap-fill values?

Level Efficiency Level Source Efficiency Level (lb/kWh)

Electric

Standard Electric

Compact

(120V) Electric

Compact

(240V) Gas

baseline DOE Standard 3.01 3.13 2.90 2.67

1 Gap Fill 3.10 3.22 * 2.98 2.75

2 Gap Fill 3.16 3.29 * 3.09 2.85

3 Max imum Available 3.4 3.54 * 3.2 3.44

* Estimated by scaling from electric standard clothes dryer efficiency levels.

What design changes are associated with c onverting a baseline unit to the updated

efficiency levels for each vented clothes dryer product class (see Tables below)?

What are the costs of the individual design options selected? When considering

energy efficiency improvements, do di fferent product classes take different

pathways or are pathways similar?

Are the aggregated industry costs submitted by AHAM (highlighted in red in the

Tables below) for the efficiency levels presented in the framework document

representative of your firm’s costs? Please edit these values as appropriate.

Are there fundamental differences between required design changes that make the

cost increment much higher for some product classes than others?

Would you help DOE understand and esti mate the conversion capital investments

that would be necessary at each candidate sta ndard level? What is the nature of

the capital investments?

5-C-3Product Class�Vented Electric StandardVented Electric Compact 120VEfficiency Level123123Updated EF (lb/KWh)3.103.163.43.223.293.54Framework Document EF (lb/KWh)3.103.163.39--3.79Design OptionsAverage Incremental Costs ($ Per Unit)Material942140Labor21145Overhead#2412Minimum Incremental Costs ($ Per Unit)*MaterialLaborOverhead#Maximum Incremental Costs ($ Per Unit)*MaterialLaborOverhead#Conversion Capital Expenditures ($, Millions)Building CAPX0.259.0250.18Tooling/ Equipment CAPX5.2537.68118.93One-Time Product Conversion Expenses ($, Millions)R&D3.6215.8758.97Marketing# Depreciation on the conversion capital expenditure should NOT be included in the incremental overhead.*Incremental costs per unit should be reported relative to the baseline unit’s cost. Thebaseline unit complies with the current federal standard for residential clothes dryers. The Average IncrementalCost should be reported as a shipment weighted average value. The Minimum and Maximum Incremental Costs presumably reflect thecosts associated with changes to different product platforms.Redhighlighted text indicates AHAM submitted data for the efficiency levels presented in the framework document.Other Information:1. What depreciation method would your company use to depreciate the conversion capital expenditures? _______________________________________________.Direct material–Costs of raw materials including scrap that can be traced to final or end products. Direct material costs do not include indirect material costs which are attributed to supplies that maybe used in the production process but are not assigned to final products (e.g., lubricating oil for production machinery).Direct labor–The earnings of workers who assemble parts into a finished good for operate machines in the production process. Direct laborincludes the fringe benefits of direct laborers such as grouphealth care, as well as overtime pay. Direct labor does not include indirect labor which is defined as the earnings of employees who do not work directly in assembling a product, such as supervisors,janitors, stockroom personnel, inspectors, and forklift operators.Overhead–Factory overhead excluding depreciation. Factory overhead includes indirect labor, downtime, set-up costs, indirect material,expendable tools, maintenance, property taxes, insurance onassets, and utility costs. Factory overhead does not include selling, general, and administrative costs (SG&A); research and development (R&D); interest; or profit (accounted for by DOE separately).Full Production Cost= Direct Material + Direct Labor + Overhead (factory) + DepreciationFull Cost of Product= Full Production Cost + Non-production Costs (SG&A, R&D, interest, and profit)5-C-4Product Class�Vented Electric Compact 240 VVented GasEfficiency Level123123Updated EF (lb/KWh)2.983.093.22.752.853.44Framework Document EF (lb/kWh)2.983.073.232.752.773.02Design OptionsAverage Incremental Costs ($ Per Unit)*Material206081Labor2632Overhead#2412Minimum Incremental Costs ($ Per Unit)*MaterialLaborOverhead#Maximum Incremental Costs ($ Per Unit)*MaterialLaborOverhead#Conversion Capital Expenditures ($, Millions)Building CAPX0.4629.83Tooling/ Equipment CAPX2.6237.2416.15One-Time Product Conversion Expenses ($, Millions)R&D2.9915.4612.91Marketing# Depreciation on the conversion capital expenditure should NOT be included in the incremental overhead.*Incremental costs per unit should be reported relative to the baseline unit’s cost. The baseline unit complies with the current federal standard for residential clothes dryers. The Average IncrementalCost should be reported as a shipment weighted average value. The Minimum and Maximum Incremental Costs presumably reflect thecosts associated with changes to different product platforms.Redhighlighted text indicates AHAM submitted data for the efficiency levels presented in the framework document.Other Information:1. What depreciation method would your company use to depreciate the conversion capital expenditures? _______________________________________________.Direct material–Costs of raw materials including scrap that can be traced to final or end products. Direct material costs do not include indirect material costs which are attributed to supplies that maybe used in the production process but are not assigned to final products (e.g., lubricating oil for production machinery).Direct labor–The earnings of workers who assemble parts into a finished good for operate machines in the production process. Direct laborincludes the fringe benefits of direct laborers such as grouphealth care, as well as overtime pay. Direct labor does not include indirect labor which is defined as the earnings of employees who do not work directly in assembling a product, such as supervisors,janitors, stockroom personnel, inspectors, and forklift operators.Overhead–Factory overhead excluding depreciation. Factory overhead includes indirect labor, downtime, set-up costs, indirect material,expendable tools, maintenance, property taxes, insurance onassets, and utility costs. Factory overhead does not include selling, general, and administrative costs (SG&A); research and development (R&D); interest; or profit (accounted for by DOE separately).Full Production Cost= Direct Material + Direct Labor + Overhead (factory) + DepreciationFull Cost of Product= Full Production Cost + Non-production Costs (SG&A, R&D, interest, and profit)5-C-5Vent-less Clothes Dryers

DOE derived efficiency levels for the analysis of vent-less electric compact (240V) and

vent-less combination (washer/dryer) product classes using existing test data and

available data from the CEC 2008 directory. DOE believes that the data derived from

each of these sources was obtained using the DOE test procedure with the requirement

for the exhaust simulator eliminated.

Are the baseline and maximum available le vels for vent-less electric clothes

dryers representative? Can you suggest baseline, gap-fill, and max-tech efficiency

levels for vent-less electric clothes dryers?

Level Efficiency Level Source Efficiency Level (lb/kWh)

Vent-less

Electric

Compact (240V) Vent-less

Combination

(Washer/Dryer)

baseline Bas eline 2.37* 1.95*

1 Gap Fill 2.39** 3.23 ††

2 Gap Fill 2.49 3.51

3 Max imum Available 2.59 † 3.79 ††

*Based on DOE test data.

**Determined by scaling the existing standard for vented electric compact (240V) based

on Miele’s voluntary plan to maintain its c ondenser clothes dryer EF within 82.5 percent

of the existing non-condenser clothes dryer standard. 60 FR 9332.

† Based on NIST test data. 1

†† Based on CEC model data.

What design changes are implemented to achieve higher efficiency levels for

vent-less electric compact clothes dryers? Are these design changes comparable

for vent-less electric combination washer/drye rs? What are the costs of the

individual design options selected?

Are there fundamental differences between required design changes that make the

cost increment much higher for some product classes than others?

Would you help DOE understand and esti mate the conversion capital investments

that would be necessary at each candidate sta ndard level? What is the nature of

the capital investments?

1 Kao, J. “Energy Test Results of a Conventional Clothes Dryer and a Condenser Clothes Dryer”, National

Institute of Standards and Technology, Gaithersburg, MD, 1998.

5-C-6Product Class�Vent-less Electric Compact (240V)Vent-less Combination (Washer/Dryer)Efficiency Level123123EF (lb/KWh)2.392.492.593.233.513.79Design OptionsAverage Incremental Costs ($ Per Unit)*MaterialLaborOverhead#Minimum Incremental Costs ($ Per Unit)*MaterialLaborOverhead#Maximum Incremental Costs ($ Per Unit)*MaterialLaborOverhead#Conversion Capital Expenditures ($, Millions)Building CAPXTooling/ EquipmentCAPXOne-Time Product Conversion Expenses ($, Millions)R&DMarketing# Depreciation on the conversion capital expenditure should NOT be included in the incremental overhead.*Incremental costs per unitshould be reported relative to the baseline unit’s cost. The baseline unit complies with the current federal standard for residential clothes dryers. The Average IncrementalCost should be reported as a shipment weighted average value. The Minimum and Maximum Incremental Costs presumably reflect thecosts associated with changes to different product platforms.Other Information:1. What depreciation method would your company use to depreciate the conversion capital expenditures? _______________________________________________.Direct material–Costs of raw materials including scrap that can be traced to final or end products. Direct material costs do not include indirect material costs which are attributed to supplies that maybe used in the production process but are not assigned to final products (e.g., lubricating oil for production machinery).Direct labor–The earnings of workers who assemble parts into a finished good for operate machines in the production process. Direct laborincludes the fringe benefits of direct laborers such as grouphealth care, as well as overtime pay. Direct labor does not include indirect labor which is defined as the earnings of employees who do not work directly in assembling a product, such as supervisors,janitors, stockroom personnel, inspectors, and forklift operators.Overhead–Factory overhead excluding depreciation. Factory overhead includes indirect labor, downtime, set-up costs, indirect material,expendable tools, maintenance, property taxes, insurance onassets, and utility costs. Factory overhead does not include selling, general, and administrative costs (SG&A); research and development (R&D); interest; or profit (accounted for by DOE separately).Full Production Cost= Direct Material + Direct Labor + Overhead (factory) + DepreciationFull Cost of Product= Full Production Cost + Non-production Costs (SG&A, R&D, interest, and profit5-C-7Fans and Motors

Is there any room for further, significant en ergy efficiency improvement via fan blade/air

flow design improvements? If so, how much improvement can be achieved?

What types of fan/drum motors do you currently employ in your clothes dryers?

Do any of your fan motors run at multiple speeds, for example to match the output of a

modulating burner or heater?

Have you considered improved fan/drum motor ef ficiency as a design option? If so, how

much improvement can be achieved?

What are the manufacturing costs asso ciated with improved fan/drum motor efficiency?

Automatic Termination Technologies

What percentage of your clothes dryer shipments for each product class use automatic

termination? What percentage of your shipments for each product class use moisture

sensors? Temperature sensors? What drives your decision of what sensor technology to

incorporate in a given platform?

Are consumers aware of the specific sensor techn ology being used inside a clothes dryer?

o If so, are consumers demanding specific sensor technologies?

o If not, are they drawn principally to the pr esence of an automatic termination

system and care less about how it is achieved?

How are the sensor functions implemented by co nsumers on your clothes dryers? Are

they enabled by default for some drying operations?

For what percentage of dry cycles do consum ers use automatic ter mination? How many

of these cycles are actively selected as sensor drying?

Do certain sensor technologies have better pe rformance characteristics than others? If so,

please elaborate on which sensor types?

Have you performed or are you aware of any research/studies that show the effects on

energy efficiency or annual energy consum ption associated with the use of automatic

termination sensors? In particular, is there an y data indicating that one sensor technology

performs better than another?

What are the manufacturing costs assoc iated with each of your automatic termination

sensor technologies?

What are the standby power requirements for the sensor that you use? Do the sensors

that you use have a warm-up time, and if so, what is the warm-up time? Are you aware

of any automatic termination sensors that do not consume standby power? If not, what

would you consider to be the lowest achievable standby power level associated with these

sensors?

Are you aware of any other sensor or alternative technologies you would consider for

automatically terminating the drying cycle?

How wide of a supplier base can you c hoose from when sourcing sensors, or do you

make your own?

Are you aware of any intellectual property or patent infringement issues that might affect

your choice of sensor technologies?

5-C-8Other Dryer Control or Drum Upgrades

Have you considered increased insulation as a design option? If so, what thicknesses and

insulation materials have you considered? How much efficiency improvement can be

achieved? What would be the incremental manufacturing cost?

Have you explored any ways of improving the ai r circulation in your dryers (i.e. directing

and maintaining heat more efficiently)? If so, how much efficiency improvement can be

achieved? What would be the incremental manufacturing cost?

Do you have any data showing any effic iency improvements associated with reverse

tumble (during the drying cycle, as opposed to after the cycle as wrinkle prevention)?

What is the incremental manufacturing cost of this design option?

DOE’s re search showed that the efficiency of a clothes dryer can be improved slightly by

the design of the drum (e.g., internal vane de sign or enhanced surf ace textures). Have

you considered improvements to the drum design? If so how much efficiency

improvement can be achieved? What would be the incremental manufacturing cost?

Exhaust Heat Recovery and Infilt ration Abatement (vented models)

Do you manufacture vented clothes dryers with an outdoor air supply? If not, what are

the reasons? If you do offer models with an outdoor air supply option, do they feature

sealed combustion?

Do you manufacture any dryers that recycle ex haust heat? If so, please elaborate on how

this is done? For example, is some of the exhaust air recycled to the inlet during a certain

portion of the drying cycle or is a heat exchanger used to recover exhaust heat energy and

to preheat inlet air? How much efficiency improvement can be achieved? What is the

incremental manufa cturing cost?

Modulating Heater Designs

Do any of your gas dryer models use modulating gas burners? Have you considered this

design option?

Do you have any data showing the efficiency improvements associated with modulating

gas burners? DOE’s research shows that a modulating gas dryer design can reduce

energy consumption by up to 25% for small and medium sized loads, and 10% for larger

loads. Would you consider this accurate?

Do any of your clothes dryers use a multi-step or modulating electric heater? What is the

associated efficiency improvement with using a modulating or stepped electric heater

versus a standard on/off electric heater?

Heat Pump Dryers

Do you manufacture heat pump dryers? If not, have you considered this technology?

What type of refrigerant is used? What type of compressor? What types of heat

exchangers are used?

DOE’s research shows that this design option can achieve 50 -68% efficiency

improvement compared to conventional elec tric dryers. Would you consider this

accurate?

5-C-9What are the manufacturing costs associated with this design option?

Standby Power

What are the consumer utilities associated with each type of display used in clothes

dryers? (Example, cycle/temperature select ion, delay start time, cycle time, etc.)

What types of display technologies do you use in your clothes dryer product line? What

are the standby power requirements for each display type assuming a comparable display

(size and capability)?

Are you aware of consumers demanding specific displ ay types or is it other clothes dryer

features that attract them?

What are the manufacturing costs asso ciated with various display technologies?

What drives the costs for each display technology?

What would be the manufacturing costs assoc iated with adding a feature to dim or turn

off the displays? How much could t his potentially decrease power consumption?

What clothes dryer features other than displa ys contribute to standby power, and what is

the standby power requirement associated with each of them?

3. Test Procedure Issues

Have you observed significant test-to- test variation in EF measurements for a given

clothes dryer unit? If so, how much is this variation?

Do you have any data showing the effects of altering the ambient conditions on the

measured EF for a give clothes dryer unit? The current DOE test procedure requires an

ambient temperature of 75 ± 3°C and relative humidity of 50 ± 10%.

Have you tested your clothes dryers with lower starting RMC of the test cloth load than is

currently specified in the DOE test procedure (no minally 70%)? If so, how did EF vary

with RMC?

5-C-105-C.2 ROOM AIR CONDITIONER ENGINEERING QUESTIONNAIRE

The engineering questionnaire used as a guide for engineering discussions during

manufacturer interviews is shown in this secti on. Some of the information provided in the

questionnaire has been redacted to protect vendor information.

5-C-11DESIGN FOR ENERGY IMPROVEME NT INFORMATION REQUEST

ROOM AIR CONDITIONERS

DOE would like to confirm information on the incr emental costs of increasing product efficiency

by understanding the design options involved in the efficiency improvement.

1. Market Share of products you sell

To help DOE discover manufacturer sub-groups and the relative importance of various product

classes to specific manufacturers, please disaggrega te your annual unit shipments for each

product category as shown below. Please also indicate whether you purchase these products

from other manufacturers (i.e. private label), and whether the fac tory that supplies the product

is located in the USA.

5-C-12Product Class % Private

Label? % Made in

USA? Yearly Unit

Shipments

1. Without reverse cycle, with LS, and less

than 6,000 Btu/h

2. Without reverse cycle, with LS and

6,000 to 7,999 Btu/h

3. Without reverse cycle, with LS and

8,000 to 13,999 Btu/h

4. Without reverse cycle, with LS and

14,000 to 19,999 Btu/h

5. Without reverse cycle, with LS and

20,000 Btu/h or more

6. Without reverse cycle, without LS, and

less than 6,000 Btu/h

7. Without reverse cycle, without LS and

6,000 to 7,999 Btu/h

8. Without reverse cycle, without LS and

8,000 to 13,999 Btu/h

9. Without reverse cycle, without LS and

14,000 to 19,999 Btu/h

10. Without reverse cycle, without LS and

20,000 Btu/h or more

11. With reverse cycle, with LS, and less

than 20,000 Btu/h

12. With reverse cycle, without LS, and

less than 14,000 Btu/h

13. With reverse cycle, with LS, and

20,000 Btu/h or more

14. With reverse cycle, without LS, and

14,000 Btu/h or more

15. Casement-Only

16. Casement-Slider

5-C-132. Product Technical Descriptions

The following series of exhibits and questions a ddress technical characteristics of key

refrigerator and freezer components for both base line and improved-efficiency products.

Compressors

Are the suggested compressor EERs represe ntative for the Product Class and Efficiency?

Product Class Typical Nominal

Compressor EER for

Minimum Efficiency Typical Nominal

Compressor EER for

EnergyStar

1. Without reverse cycle, with

LS, and less than 6,000 Btu/h 10 to 11 11

3. Without reverse cycle, with

LS and 8,000 to 13,999 Btu/h 10 to 11 11

5. Without reverse cycle, with

LS and 20,000 Btu/h or more 10.5 11

8. Without reverse cycle,

without LS and 8,000 to

13,999 Btu/h 10 10.5 to 11

Is the Illustrated Typical Cost vs. Capacity for HCFC-22 Baseli ne Product compressors (10

EER) accurate (note that the plot is based on RAC capacity, not compressor rating point

capacity)?

Is 15% a good estimate of cost premium for 11 EER as compared with 10 EER compressors?

5-C-14Do any room air-conditioners use variable-sp eed compressors? Any other modulating or

part-loading approaches?

What are reasonable impacts for use of R-410 on compressor characteristics?

Cost premium 10%? Expected trend in coming years?

Rating point EER range 9.5 to 10.5 rather than 10 to 11?

Different performance trends than HCFC-22 at varying condensing or evaporating

temperatures?

Maturity of product offerings?

R-410a Conversion

Expected change in EER of room air c onditioners designed with refrigerant velocities

appropriate for R-410A but with equivalent heat exchanger core sizes and air flow?

Cost impacts of conversion (compre ssor, refrigerant, other?)?

Evaporator and Cond enser Heat Exchanger Characteristics

Please comment on the typical key details of heat exchangers.

Evaporators Condensers

Tube Outer Diameter (inch) 0.28 0.25

Tube Wall (inch) 0.015 0.020

Tubes Always Rifled? Yes Yes

Fin Type? Louvered or Lanced Louvered or Lanced

Fins per inch? 18 18

Standard-Efficiency Air

flow (cfm/ton)? 275 800

Standard-Efficiency Air

face velocity (fpm)? 450 500

Tubes always copper? Fins always aluminum?

Limitations of boosting fin density?

Trends in Air flow variation by capacity, efficiency level, product class differences: window

vs. thru-wall vs. reversible-cycle vs. casement/slider?

Are you aware of any further significant sy stem improvements that may be possible through

heat exchanger changes?

Benefits of reduced tube diameters?

In spite of efforts to minimize room air conditioner size, typical coil depth is two rows: does

the fan power increase with greater de pth make additional rows counterproductive?

Benefits of microchannel heat exchangers?

Benefits of coil coatings to improve efficiency?

Coil fabrication usually outsourced or in-house?

Is air flow through the condenser always from inside out to assure cooling benefit of the

condensate?

5-C-15At rating conditions, is all of the condensate evap orated prior to air leaving the coil, with no

spillage from the pan?

Subcoolers using Condensate for Cooling

Are these standard on Energy Star products?

Do their designs take full a dvantage of possible pan counterflow?

Evaporator Blowers and Condenser Fans

Typical blower geometry: backward-inclined blades using plug fan arrangement, using

Styrofoam “scroll” to direct air from lower part of blower?

Typical blower efficiency? Typical fan efficiency?

Power requirement associated with water slinging function at design rating conditions? Are

there more efficient ways to distribute the condensate?

Is there any room for significant energy efficiency improvement via blower or fan design

improvements?

Blower/Fan Motors

Please comment on blower/ fan motor characteristics.

Generally use double-shafted PSC? Typical number of speeds?

Shaft Power output 8W per 1000 Btu/hr capacity?

Typical efficiency roughly 60% for standard-efficiency products?

Motor cost $X for 75W shaft out put? Variation vs. shaft output?

Higher efficiency PSC levels up to 65% for Energ y Star? What is the peak efficiency

commonly available for RAC-sized PSC motors? What is the cost premium?

Brushless DC motor efficiency for RAC size 80%? Does this technology provide a viable

option for efficiency improvement? What is the efficiency improvement, cost impact, and

size/weight impact? Typical motor vendor/model?

Are there any other motor technologies which co uld contribute to efficiency improvement?

Partition Insulation

Usually 1⁄4 inch Styrofoam or 1/10 inch polystyrene?

Air Leakage

Is this a factor in rating point performance?

Expansion Devices:

Is there any performance improvement potential with expansion devices other than capillary

tube?

Do you use any expansion device besides capillary tubes? If so, what are the benefits and the

cost impacts?

Energy Efficiency Conversion Costs

5-C-16What design changes are typically associated with converting baseline products to Energy

Star?

When considering energy efficiency improve ments to achieve or exceed Energy Star, do

different product classes take different pathways or are pathways similar?

Are the cost increments higher for some classes than others for a given performance

improvement over baseline?

5-C-17