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CHAPTER 1. INTRODUCTION

TABLE OF CONTENTS

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

1.2 OVERVIEW OF STANDARDS FOR COMMERCIAL CLOTHES WASHERS ......... 1-1

1.3 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS ................... 1-1

1.4 STRUCTURE OF THE DOCUMENT............................................................................ 1-5

LIST OF TABLES

Table 1.3.1 Analyses Under the Process Rule ........................................................................ 1-3
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CHAPTER 1. INTRODUCTION

1.1 PURPOSE OF THE DOCUMENT

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

analyses and results supporting the information presented in the final rule for commercial clothes 

washers.

1.2 OVERVIEW OF STANDARDS FOR COMMERCIAL CLOTHES WASHERS

Title III of the Energy Policy and Conservation Act of 1975 (42 U.S.C.6291, et seq; 

“EPCA”), Pub. L. 94-163, sets forth a variety of provisions designed to improve energy 

efficiency.a Part C of title III, which for editorial reasons was re-designated as Part A-1 upon 

incorporation into the U.S. Code (42 U.S.C. 6311–6317, as codified), establishes the "Energy 

Conservation Program for Certain Industrial Equipment." These include commercial clothes 

washers, the subject of this rulemaking. (42 U.S.C. 6311(1)(H)).

The Energy Policy Act of 2005 (EPACT) established the first energy conservation 

standards for commercial clothes washers. (42 U.S.C. 6313(e)(1)) EPACT directed DOE to 

conduct two rulemakings to determine whether the established standards should be amended. 

DOE published its first final rule amending commercial clothes washer standards on January 8, 

2010, which apply to commercial clothes washers manufactured on or after January 8, 2013. 

EPACT required the second final rule to be published by January 1, 2015, which will apply to 

commercial clothes washers manufactured three years after the date on which the final amended 

standard is published. (42 U.S.C. 6313(e)(2)(B)) This current rulemaking satisfies the 

requirement to publish the second final rule by January 1, 2015.

1.3 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS

Under EPCA, when DOE is analyzing whether to establish new or amended standards, it 

must consider, to the greatest extent practicable, the following seven factors (42 U.S.C. 6295 

(o)(2)(B)(i) and 6316(a)):

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

products; 

 

a All references to EPCA refer to the statute as amended through the American Energy Manufacturing Technical 

Corrections Act, Pub. L. 112-210 (Dec. 18, 2012).
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2) the savings in operating costs throughout the estimated average life of the product 

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

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

of the standard; 

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

imposition of the standard; 

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

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

6) the need for national energy conservation; and 

7) other factors the Secretary considers relevant.

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

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

DOE considers stakeholder participation to be an important part of the process for setting 

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

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

comment period in each stage of the rulemaking. Beginning with the framework document and 

during subsequent comment periods, interactions among stakeholders provide a balanced 

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

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

standard, it must first solicit comments on the proposed standard. (42 U.S.C. 6295(m)(2)(B); 

6295(p)(2); and 6316(a)) Any new or amended standard must be designed to achieve significant 

additional conservation of energy and be technologically feasible and economically justified. (42 

U.S.C. 6295(o)(2)(A) and 6316(a)) To determine whether economic justification exists, DOE 

must review comments on the proposal and determine that the benefits of the proposed standard 

exceed its burdens to the greatest extent practicable, weighing the seven factors listed above. (42 

U.S.C. 6295 (o)(2)(B)(i) and 6316(a))

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

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

Federal Register. The first of the rulemaking notices is a notice of public meeting (NOPM), 

which is designed to publicly vet the models and tools used during the rulemaking and to 

facilitate public participation before the next stage. The second notice is the notice of proposed 

rulemaking (NOPR), which presents a discussion of comments received in response to the 

NOPM, the results of the analyses performed, and the proposed energy conservation standards 

for the product. The third notice is the final rule, which presents a discussion of the comments 

received in response to the NOPR; the revised analyses; DOE’s weighting of these impacts; the 
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amended energy conservation standards DOE is adopting for the product; and the compliance 

dates of the amended energy conservation standards.

DOE initiated the current rulemaking on August 13, 2012 by publishing a notice 

announcing the availability of the framework document, the Energy Conservation Standards 

Rulemaking Framework Document for Commercial Clothes Washers. In this notice, DOE also 

announced a public meeting and requested comment on the matters raised in the framework 

document. 77 FR 48108 (August 13, 2012). The framework document described the procedural 

and analytical approaches that DOE anticipated using to evaluate energy conservation standards 

for commercial clothes washers and identified various issues to resolve during the rulemaking.

The NOPM is available at http://www.regulations.gov/#!documentDetail;D=EERE-2012-BTSTD-0020-0002 and the framework document is available at 

http://www.regulations.gov/#!documentDetail;D=EERE-2012-BT-STD-0020-0001.

On September 24, 2012, DOE held the framework document public meeting and 

discussed the issues detailed in the framework document. DOE also described the analyses that it 

planned to conduct during the rulemaking, listed in Table 1.3.1. Through the public meeting, 

DOE sought feedback from interested parties on these subjects and provided information 

regarding the rulemaking process that DOE would follow. DOE received comments from 

interested stakeholders regarding the August 2012 notice, including those received at the 

September 2012 framework public meeting.

Table 1.3.1 Analyses Under the Process Rule

Preliminary Analyses1 NOPR Final Rule

Market and technology assessment Revised preliminary analyses Revised NOPR analyses

Screening analysis Life-cycle cost sub-group 

analysis

Engineering analysis Manufacturer impact analysis

Energy use analysis Utility impact analysis

Markups for equipment price 

determination

Emissions analysis

Life-cycle cost and payback period 

analysis

Employment impact analysis

Shipments analysis Regulatory impact analysis

National impact analysis

Preliminary manufacturer impact 

analysis

1. In the current rulemaking, DOE conducted the analyses listed under Preliminary 

Analyses as part of the NOPR analysis.
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Following the framework meeting, DOE gathered additional information, held 

discussions with manufacturers, performed product testing and teardowns, and performed the 

various analyses described in the framework document, including the engineering, life-cycle 

cost, payback period, manufacturer impact, and national impact analyses. On March 4, 2014, 

DOE published a NOPR (“the March 2014 NOPR”) and notice of public meeting. 79 FR 12301. 

In the March 2014 NOPR, DOE presented the results of its initial analyses, addressed comments 

received in response to the framework document and public meeting, and proposed amended 

standards for commercial clothes washers. DOE also published an accompanying technical 

support document (TSD) that described the results of each analysis in greater detail.

On April 21, 2014, DOE held the NOPR public meeting and discussed the issues detailed 

in the NOPR. Interested parties commented on various aspects of the proposed rule and 

submitted supplemental written comments. Following the public meeting, DOE gathered 

additional information and performed additional analysis to supplement the analyses presented in 

the NOPR, including the engineering, life-cycle cost, payback period, manufacturer impact, and 

national impact analyses. The results of these analyses are detailed in this TSD. DOE considered 

the comments received since publication of the March 2014 NOPR, including those received at 

the NOPR public meeting, in developing the amended standards for commercial clothes washers.

As part of the information gathering and sharing process, DOE organized and held 

interviews with manufacturers of the commercial clothes washers considered in this rulemaking 

as part of the engineering analysis. DOE selected companies that represented production of all 

types of products on the market, ranging from small to large manufacturers, and included the 

Association of Home Appliance Manufacturers (AHAM) member companies. DOE had four 

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

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

(3) provide an opportunity, early in the rulemaking process, to express manufacturers’ concerns 

to DOE; and (4) foster cooperation between manufacturers and DOE. DOE incorporated the 

information gathered during the engineering interviews with manufacturers into its engineering 

analysis (chapter 5) and the manufacturer impact analysis (chapter 12).

DOE developed spreadsheets for the engineering, Life-Cycle Cost (LCC) Payback Period 

(PBP), and national impact analyses for each product. The LCC spreadsheet calculates the LCC 

and PBP at various energy efficiency levels. The national impact analysis spreadsheet calculates 

the national energy savings and national net present values at various energy efficiency levels. 

This spreadsheet includes a model that forecasts the impacts of amended energy conservation 

standards at various levels on product shipments. All of these spreadsheets are available on the 

DOE website for commercial clothes washers at:

http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/46.

DOE can also provide quantitative outputs from its analyses in machine-readable format 

upon request. For example, outputs from trial runs of the LCC Monte Carlo simulations can be 

provided in such a format.
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1.4 STRUCTURE OF THE DOCUMENT

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

the following chapters and appendices:

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

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

document.

Chapter 2 Analytical Framework: describes the rulemaking process.

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

considered products and the technologies available for increasing 

product efficiency.

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

efficiency of the considered products, and determines which technology 

options are viable for consideration in the engineering analysis.

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

relationship between increased manufacturer price and increased 

efficiency.

Chapter 6 Markups for Equipment Price Determination: discusses the methods 

used for establishing markups for converting manufacturer prices to 

customer product costs.

Chapter 7 Energy and Water Use Determination: discusses the process used for 

generating energy-use estimates for the considered products as a 

function of standard levels.

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

standards on individual customers and users of the products and 

compares the LCC and PBP of products with and without higher 

efficiency standards.

Chapter 9 Shipments Analysis: estimates shipments of the products over the 30-

year analysis period that is used in performing the national impact 

analysis (NIA).

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

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

to result from specific, potential energy conservation standards.
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Chapter 11 Life-Cycle Cost Subgroup Analysis: discusses the effects of standards 

on different subgroups of consumers.

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

finances and profitability of product manufacturers.

Chapter 13 Emissions Analysis: discusses the effects of standards on three 

pollutants—sulfur dioxide (SO2), nitrogen oxides (NOx), and mercury—

as well as carbon dioxide emissions.

Chapter 14 Monetization of Emission Reductions Benefits

Chapter 15 Utility Impact Analysis: discusses certain effects of the considered 

standards on electric and gas utilities.

Chapter 16 Employment Impact Analysis: discusses the effects of standards on 

national employment.

Chapter 17 Regulatory Impact Analysis: discusses the impact of non-regulatory 

alternatives to efficiency standards.

Appendix 5-A AHAM Data Request

Appendix 6-A Detailed Data for Markups

Appendix 7-A Load Usage Factor in Commercial Laundry Applications

Appendix 8-A User Instructions for Life-Cycle Cost and Payback Period Spreadsheets

Appendix 8-B Uncertainty and Variability

Appendix 8-C Lifetime Distributions

Appendix 9-A Relative Price Elasticity of Demand for Clothes Washers

Appendix 10-A Full-Fuel-Cycle Multipliers

Appendix 10-B User Instructions for Shipments and National Impact Analysis

Spreadsheets

Appendix 10-C National Energy Savings and Net Present Value Using Alternative 

Growth Scenarios
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Appendix 10-D National Net Present Value of Consumer Benefits Using Alternative 

Product Price Forecasts

Appendix 12-A Manufacturer Interview Guide

Appendix 12-B Government Regulatory Impact Model

Appendix 14-A Social Cost of Carbon for Regulatory Impact Analysis Under Executive 

Order 12866

Appendix 14-B Technical Update of Social Cost of Carbon for Regulatory Impact 

Analysis Under Executive Order 12866

Appendix 17-A Regulatory Impact Analysis: Supporting Materials