CHAPTER 1. INTRODUCTION 

TABLE OF CONTENTS 

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

1.2 OVERVIEW OF STANDARDS FOR RESIDENTIAL DISHWASHERS, 

DEHUMIDIFIERS, AND COOKING PRODUCTS AND COMMERCIAL 

CLOTHES WASHERS ................................................................................................... 1-1 

1.3 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS...................... 1-2 

1.4 STRUCTURE OF THE DOCUMENT............................................................................ 1-8 

LIST OF TABLES 

Table 1.3.1 Analyses Under the Process Rule ........................................................................ 1-5 

Table 1.3.2 Proposed Energy Conservation Standards for Cooking Products and 

Commercial Clothes Washers.............................................................................. 1-7 

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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 in support of the information presented in the final rule for establishing 

energy conservation standards for residential dishwashers, dehumidifiers, cooking products and 

commercial clothes washers (also referred to as “the considered products”). 

1.2 OVERVIEW OF STANDARDS FOR RESIDENTIAL DISHWASHERS, 

DEHUMIDIFIERS, AND COOKING PRODUCTS AND COMMERCIAL 

CLOTHES WASHERS 

The Energy Policy and Conservation Act (EPCA) of 1975 (42 U.S.C. 6291–6309) 

established an energy conservation program for major household appliances. The National 

Energy Conservation Policy Act of 1978 (NECPA) amended EPCA to add Part C of Title III (42 

U.S.C. 6311–6317), which established an energy conservation program for certain industrial 

equipment. Additional amendments to EPCA have given the Department of Energy (DOE) the 

authority to regulate the energy efficiency of several products, including residential dishwashers, 

dehumidifiers, and cooking products and commercial clothes washers—the products that are the 

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

Conservation Act of 1987 (NAECA) established prescriptive energy conservation standards for 

dishwashers and cooking products, as well as requirements for determining whether these 

standards should be amended. (42 U.S.C. 6291–6309) The amendments to EPCA in the Energy 

Policy Act of 2005 (EPACT 2005), P.L. 109-58, included provisions that expanded DOE’s 

energy conservation program to include certain residential products and commercial equipment, 

including dehumidifiers and commercial clothes washers. 

NAECA established prescriptive standards for gas cooking products, requiring gas ranges 

and ovens with an electrical supply cord not to be equipped with constant burning pilots, and 

directed DOE to conduct two cycles of rulemakings to determine if more stringent standards are 

justified.a (42 U.S.C. 6295(h)(1)–(2)) DOE initially analyzed standards for cooking products as 

part of an eight-product standards rulemaking. It issued a notice of proposed rulemaking 

(NOPR) on March 4, 1994, proposing performance standards for gas and electric residential 

cooking products, including microwave ovens. 59 FR 10464. In accordance with the July 15, 

1996, Procedures for Consideration of New or Revised Energy Conservation Standards for 

Consumer Products (the “Process Rule”), 61 FR 36974 (July 15, 1996), DOE refined its 

standards analysis of cooking products. With regard to gas cooking products, DOE focused on 

a DOE is required to conduct two cycles of rulemakings for both gas and electric cooking products. 

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EERE-2006-STD-0127 COMMENT 64.2
the economic justification for eliminating standing pilots. Partially due to the difficulty of 

conclusively demonstrating that elimination of standing pilots was economically justified, DOE 

issued a final rule on September 8, 1998, that covered only electric cooking products, including 

microwave ovens. 63 FR 48038. The final rule found that no standards were justified for 

electric cooking products. DOE never completed its standards rulemaking for gas cooking 

products. 

NAECA also established prescriptive standards for dishwashers, requiring that they be 

equipped with an option to dry without heat, and further required that DOE conduct two cycles 

of rulemakings to determine if more stringent standards are justified. (42 U.S.C. 6295(g)(1), (4), 

(5)) On May 14, 1991, DOE issued a final rule establishing the first set of performance 

standards for dishwashers; the new standards became effective on May 14, 1994. 56 FR 22250. 

DOE initiated a second standards rulemaking for dishwashers by issuing an advance notice of 

proposed rulemaking (ANOPR) on November 14, 1994. 59 FR 56423. As a result of the 

priority-setting process outlined in the Process Rule, DOE suspended the standards rulemaking 

for dishwashers. The Energy Independence and Security Act of 2007 (EISA 2007; Pub. L. No. 

110-140) amended EPCA to establish revised energy conservation standards for residential 

dishwashers. (42 U.S.C. 6295(g)(9)) These EISA 2007 amendments set energy efficiency 

standards for these products, effective January 1, 2010; therefore, DOE is not adopting standards 

for residential dishwashers in this final rule and instead will codify these statutory standards in a 

separate final rule. 

Dehumidifiers are products first covered by EPACT 2005, which established standards 

for these products with an effective date of October 1, 2007. (Section 135(c)(4)) EPACT 2005 

also required that DOE issue a final rule by October 1, 2009, to determine whether these 

standards should be amended. If amended standards were justified, EPACT 2005 required them 

to become effective by October 1, 2012. In the event that DOE failed to publish a final rule by 

October 1, 2009, EPACT 2005 specified a new set of amended standards with an effective date 

of October 1, 2012. EISA 2007 amended EPCA to establish revised energy conservation 

standards for dehumidifiers, effective October 1, 2012. (42 U.S.C. 6295(cc)) As with 

dishwashers, DOE is not adopting standards for dehumidifiers in this final rule and instead will 

codify these statutory standards in a separate final rule. 

Like dehumidifiers, commercial clothes washers are equipment first covered by EPACT 

2005. EPACT 2005 established standards for commercial clothes washers with an effective date 

of January 1, 2007. (Section 136(e)) EPACT 2005 also requires that DOE issue a final rule by 

January 1, 2010, to determine whether these standards should be amended. 

1.3 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS 

Under EPCA, when DOE evaluates 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); 42 U.S.C. 

6316(a)): 

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EERE-2006-STD-0127 COMMENT 64.2
1) the economic impact of the standard on the manufacturers and on the consumers of the 

products subject to such a standard; 

2) the savings in operating costs throughout the estimated average life of the covered 

product in the type (or class) compared to any increases in the price of, or in the initial 

charges for, or maintenance expenses of, the covered products which are likely to result 

from the imposition of the standard; 

3) the total projected amount of energy, or as applicable, water, savings likely to result 

directly from the imposition of the standard; 

4) any lessening of the utility or the performance of the covered 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 and water 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), 

(3)–(4) and 42 U.S.C. 6316(a). 

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

setting energy conservation standards. 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. 

In conducting energy conservation standards rulemakings, DOE involves stakeholders 

through formal public notifications (i.e., Federal Register notices). For this rulemaking, DOE 

employed the procedures set forth in the Process Rule to the extent they were appropriate for 

developing energy conservation standards for the considered products. The Process Rule greatly 

enhances opportunities for public input and improved analytic approaches, and encourages 

adoption of consensus-based standards. The Process Rule provides policies and guidelines for 

early public review and consultation with interested parties with regard to identifying and 

screening design options, selecting a proposed standard, and establishing the final standard. The 

factors for screening design options include: (1) technological feasibility; (2) practicability to 

manufacture, install, and service; (3) adverse impacts on product utility or product availability; 

and (4) adverse impacts on health or safety (Process Rule at section 4(a)(4)). 61 FR 36982. 

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The Process Rule requires DOE to evaluate uncertainty and variability through the use of 

scenario or probability analysis, and provides for review by experts and interested parties of the 

analyses used, including: (1) qualitative and quantitative analytical methods; (2) economic, 

engineering, and life-cycle cost (LCC) analyses; and (3) impacts on manufacturers and 

consumers, national energy savings, the economy, and the environment. Although the Process 

Rule specifically applies only to the development of energy conservation standards for consumer 

products, DOE has decided to apply its procedures to the development of energy conservation 

standards for commercial and industrial equipment as well. See appendix A to subpart C of Title 

10 of the Code of Federal Regulations Part 430 (10 CFR Part 430). 

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(o)(2)(B)(i)) 

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

energy and be technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) 

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

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

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

After the publication of the framework document, the standards rulemaking process 

involves three additional formal, major public notices, which DOE publishes in the Federal 

Register. The first of the rulemaking notices is an ANOPRb

, which is designed to publicly vet 

the models and tools used in the rulemaking, and to facilitate public participation before the 

proposed rule stage. The second notice is a NOPR, which presents a discussion of comments 

received in response to the ANOPR; analysis of the impacts of standards on consumers, 

manufacturers, and the nation; DOE’s weighting of these impacts; and the proposed standards. 

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

to the NOPR; the revised analysis of the impacts of standards; DOE’s weighting of these 

impacts; the standards DOE is adopting; and the effective dates of the standards. 

In April, 2006, DOE published a Rulemaking Framework for Commercial Clothes 

Washers and Residential Dishwashers, Dehumidifiers, and Cooking Products, describing the 

procedural and analytical approaches DOE anticipated using to evaluate the establishment of 

energy conservation standards for these products. This document is available at 

www.eere.energy.gov/buildings/appliance_standards/. DOE held a public meeting on April 27, 

2006, to discuss procedural and analytical approaches to the rulemaking, and to inform and 

facilitate interested parties’ involvement in the rulemaking process. The analytical framework 

presented at the public meeting described different analyses, such as the engineering analysis and 

b

 In energy conservation standards rulemakings in the past, and for this rulemaking, DOE issued an ANOPR 

following publication of the framework document. The Energy Independence and Security Act of 2007 eliminated 

the requirement that DOE issue ANOPRs as part of the standards rulemaking process; see EISA 2007, at sec. 307. 

DOE is now using an alternative process known as the preliminary activities and analyses. The preliminary activities 

and analyses will provide the same information and ability for public comment as the ANOPR, but without 

publication of analyses in the Federal Register. 

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the LCC and payback period (PBP) analysis, the methods proposed for conducting them, and the 

relationships among the various analyses. Table 1.3.1 lists the analyses undertaken and reported 

in each of the formal public rulemaking documents. 

Table 1.3.1 Analyses Under the Process Rule 

ANOPR NOPR Final Rule 

Market and technology assessment 

Screening analysis 

Revised ANOPR analyses 

Life-cycle cost sub-group 

analysis 

Revised analyses 

Engineering analysis Manufacturer impact analysis 

Energy and water use determination Utility impact analysis 

Markups for equipment price 

determination 

Environmental assessment 

Life-cycle cost and payback period 

analysis 

Employment impact analysis 

Shipments analysis 

National impact analysis 

Regulatory impact analysis 

Preliminary manufacturer impact analysis 

During the April, 2006, public meeting, interested parties commented about the following 

issues related to the rulemaking: (1) the existing DOE test procedure for microwave ovens; (2) 

baseline unit definitions for the considered products; (3) number of product classes for the 

considered products; (4) consideration of limiting standby power as a design option for all 

considered products; (5) technology options for improving efficiency for all considered products; 

(6) type of approach to employ for the engineering analysis; (6) efficiency levels to consider for 

all of the considered products; (7) implications of clothes container volume on commercial 

clothes washer efficiency; (8) proposed approaches for specifying typical annual energy and 

water consumption for all considered products; (9) potential data sources for characterizing 

variability in annual energy and water consumption; (10) typical distribution channels and 

markups for the considered products; (11) data sources for retail prices; (12) type of approach to 

employ for the LCC and PBP analyses; (13) variability of forecasted energy and water prices; 

(14) repair, maintenance, and installation cost relationship to product efficiency; (15) product 

lifetimes; (16) development of consumer discount rates; (17) purchase price impacts on product 

shipments; (18) forecasted saturation rates of commercial clothes washers; (19) consumer 

subgroups; (20) water and wastewater utility impacts; and (21) wastewater discharge impacts. 

Interested parties’ comments submitted during the Framework Document comment period 

elaborated on the issues raised at the public meeting. DOE worked with its contractors to 

address these issues in the analyses. 

After the April, 2006, public meeting, as part of the information gathering and sharing 

process, DOE organized and held interviews with manufacturers of the considered products. 

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EERE-2006-STD-0127 COMMENT 64.2
DOE selected companies that represented production of all types of equipment, ranging from 

small to large manufacturers, and included both Association of Home Appliance Manufacturers 

(AHAM) member companies and non-AHAM member companies. DOE had four objectives for 

these interviews: (1) Solicit feedback on the draft engineering analysis (including methodology, 

production costs, manufacturing processes, and findings); (2) solicit feedback on topics related to 

the preliminary manufacturer impact analysis (MIA); (3) provide an opportunity, early in the 

rulemaking process, to express specific concerns to DOE; and (4) foster cooperation between the 

manufacturers and DOE. There were six general topics related to the preliminary manufacturer 

impact analysis discussed during each of the interviews: (1) general key issues; (2) shipment 

projections; (3) capital conversion costs; (4) product mix and profitability; (5) market shares and 

industry consolidation; and (6) cumulative regulatory burden. DOE incorporated the information 

gathered at the interviews into its engineering analysis (see chapter 5 of the ANOPR TSD) and 

the preliminary manufacturer impact analysis (see chapter 13 of the ANOPR TSD). Following 

the publication of the ANOPR and the ANOPR public meeting, DOE held additional meetings 

with manufacturers as part of the consultative process for the MIA conducted during the NOPR 

phase of the rulemaking. 

DOE developed spreadsheets for the LCC, PBP, and national impact analyses for each of 

the considered products in an effort to meet the objectives of the Process Rule. For each product, 

DOE developed an LCC spreadsheet that calculates the LCC and PBP at various energy 

efficiency levels. DOE also developed a national impact analysis (NIA) spreadsheet that 

calculates the national energy savings (NES) and national net present values (NPVs) at various 

energy efficiency levels. This spreadsheet includes a model that forecasts the impacts of energy 

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

available on the DOE website (www.eere.energy.gov/buildings/appliance_standards), within the 

specific pages for each of the considered products. 

On November 15, 2007, DOE published an ANOPR to consider establishing new or 

revised energy conservation standards for the covered products, and to announce a public 

meeting to receive comments on a variety of issues. 72 FR 64432. This document is available at 

www.eere.energy.gov/buildings/appliance_standards/. DOE held a public meeting on December 

13, 2007, to provide interested parties the opportunity to comment on topics including: (1) the 

proposed product classes; (2) the analytical framework, models, and tools (e.g., LCC and NES 

spreadsheets) that DOE used to perform analyses of the impacts of energy conservation 

standards; (3) the results of the preliminary analyses; and (4) the candidate energy conservation 

standard levels. 

After the publication of the ANOPR and the presentation of the ANOPR to interested 

parties at the public meeting, DOE conducted interviews with manufacturers of the covered 

products as part of the MIA for the NOPR. There were thirteen general topics discussed during 

each of the interviews: (1) general key issues; (2) company overview and organizational 

characteristics; (3) company financial parameters; (4) production cost breakdown; (5) shipment 

projections and market shares; (6) equipment mixes; (7) conversion costs; (8) markups and 

profitability; (9) cumulative regulatory burden; (10) exports, foreign competition, and 

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EERE-2006-STD-0127 COMMENT 64.2
outsourcing; (11) direct employment impact assessment; (12) market consolidation; and (13) 

baseline products and different design options. 

Subsequent to the ANOPR, DOE revised its preliminary analyses to address public 

comments it had received on its ANOPR. In addition, DOE conducted all of the analyses 

identified in Table 1.3.1 that are required for the NOPR phase of the rulemaking. 

On October 17, 2008, DOE published a NOPR proposing energy conservation standards 

for the covered products, and to announce a public meeting to receive comments on a variety of 

issues. 73 FR 62034. In conjunction with the NOPR, DOE also published on its website the 

complete TSD for the proposed rule, which incorporated the analyses DOE conducted and 

technical documentation of each analysis, as well as the LCC and NIA spreadsheets. These 

documents are available at www.eere.energy.gov/buildings/appliance_standards/. For the 

reasons discussed above in section 1.2, DOE did not consider energy conservation standards for 

dishwashers and dehumidifiers, and is instead codifying in a separate final rule the standards set 

by EISA 2007 for these products. The energy conservation standards proposed in the NOPR for 

the remaining covered products were as follows: 

Table 1.3.2 Proposed Energy Conservation Standards for Cooking Products and 

Commercial Clothes Washers 

Product Class 

Proposed Energy Conservation 

Standards 

Conventional Cooking Products 

Gas cooktops/conventional burners No constant burning pilot lights 

Electric cooktops/low or high wattage open (coil) elements No standard 

Electric cooktops/smooth elements No standard 

Gas ovens/standard oven No constant burning pilot lights 

Gas ovens/self-clean oven No change to existing standard 

Electric ovens No standard 

Microwave ovens Maximum standby power = 1.0 watt 

Commercial clothes washers 

Top-loading commercial clothes washers 1.76 Modified Energy Factor / 8.3 

Water Factor 

Front-loading commercial clothes washers 2.00 Modified Energy Factor / 5.5 

Water Factor 

The NOPR also included additional background information on the history of this 

rulemaking and on DOE’s use in this rulemaking of the procedures, interpretations, and policies 

set forth in the Process Rule. 73 FR 62034, 62038–41 (Oct. 17, 2008). DOE held a public 

meeting on November 13, 2008, to hear oral comments on and solicit information relevant to the 

proposed rule. 

Based on information provided by interested parties at the public meeting and in 

subsequent written comments, DOE determined that additional analyses would be required to 

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EERE-2006-STD-0127 COMMENT 64.2
further evaluate energy conservation standards for commercial clothes washers and microwave 

ovens as to standby power. The EISA 2007 amendments to EPCA require DOE to amend the 

ranges and ovens and microwave oven test procedure to incorporate standby and off mode 

energy consumption no later than March 31, 2011. (42 U.S.C. 6295(gg)(2)(B)(vi)) For 

commercial clothes washers, EPCA requires that DOE issue a final rule by January 1, 2010, to 

determine whether the existing energy conservation standards should be amended. (42 U.S.C. 

6313(e)(2)(A)) Because additional analyses are required to resolve issues concerning 

commercial clothes washer and microwave oven standby power energy conservation standards 

and EPCA does not require DOE to take action on these products by March 2009 (as is required 

under a Consent Decreec for the cooking efficiency for residential electric and gas kitchen ranges 

and ovens and microwave ovens), DOE is continuing the rulemaking for these products at this 

time. 

According to the rulemaking timeline, DOE plans to issue a final rule for energy 

conservation standards pertaining to cooking efficiency for residential electric and gas kitchen 

ranges and ovens and microwave ovens in March 2009. The effective date for these new 

standards would be in March 2012. Separate final rules for commercial clothes washers and 

microwave ovens pertaining to standby power are planned to be issued as soon as the revised 

analyses are complete. 

1.4 STRUCTURE OF THE DOCUMENT 

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

consists of seventeen 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: determines which design options are viable for 

consideration in the engineering analysis. 

c

 “Consent Decree” refers to the consolidated Consent Decree in New York v. Bodman, No. 05 Civ. 7807 (S.D.N.Y. 

filed Sept. 7, 2005) and Natural Resources Defense Council v. Bodman, No. 05 Civ. 7808 (S.D.N.Y. filed Sept. 7, 

2005) 

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EERE-2006-STD-0127 COMMENT 64.2
Chapter 5 Engineering Analysis: discusses the methods used for developing the 

relationship between increased manufacturer cost and increased 

efficiency. 

Chapter 6 Energy and Water Use Determination: discusses the process used for 

generating energy- and water-use estimates for the considered products 

as a function of standard levels. 

Chapter 7 Markups for Equipment Price Determination: discusses the methods 

used for establishing markups for converting manufacturer costs to 

customer retail prices. 

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 energy 

conservation standards. 

Chapter 9 Trial Standard Levels: discusses the trial standard levels and methods 

used to derive the energy-efficiency equations corresponding to the 

proposed energy conservation standards. 

Chapter 10 Shipments Analysis: discusses the methods used for forecasting 

shipments with and without higher efficiency standards, including how 

equipment purchase decisions are economically influenced and how 

DOE models this relationship with econometric equations. 

Chapter 11 National Impact Analysis: discusses the methods used for forecasting 

national energy consumption and national economic impacts based on 

estimates of future equipment efficiency, new construction and building 

starts, and annual equipment sales in the absence and presence of higher 

efficiency standards. 

Chapter 12 Life-Cycle Cost Subgroup Analysis: discusses the effects of standards 

on different subgroups of consumers and compares the LCC and PBP of 

products with and without higher efficiency standards for these 

consumers. 

Chapter 13 Manufacturer Impact Analysis: discusses the financial impact of new 

energy conservation standards on manufacturers. 

Chapter 14 Utility Impact Analysis: discusses the effects of standards on electric 

and gas utilities. 

Chapter 15 Employment Impact Analysis: discusses the effects of standards on 

national employment. 

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EERE-2006-STD-0127 COMMENT 64.2
Chapter 16 Environmental Assessment: discusses the effects of amended energy 

conservation standards on three pollutants—sulfur dioxide (SO2), 

nitrogen oxides (NOx), and mercury—as well as carbon emissions. 

Chapter 17 Regulatory Impact Analysis: discusses the present regulatory actions as 

well as the impact of non-regulatory alternatives to setting new energy 

conservation standards. 

Appendix 5A AHAM Data Submittal: presents the data provided by AHAM to DOE 

for microwave ovens. 

Appendix 6A Cooktops and Ovens: Determination of Energy-Using Components: 

discusses the method for determining the energy use by energy-using 

components of cooktops and ovens including cooking, ignition, selfcleaning, and clock energy. 

Appendix 8A User Instructions for LCC and PBP Spreadsheets: briefly describes the 

LCC and PBP spreadsheets for each of the considered products and 

provides brief user instructions on how to operate the spreadsheets. 

Appendix 8B Uncertainty and Variability: discusses how DOE uses uncertainty and 

variability to characterize the inputs to the LCC and PBP analysis. 

Appendix 8C Lifetime Distributions: discusses how product lifetimes are 

characterized with Weibull probability distributions. 

Appendix 8D Household Discount Rate Distributions: provides the probability 

distributions for various household debt classes and asset holdings used 

to develop discount rates for household appliances in the LCC analysis. 

Appendix 10A Relative Price Elasticity of Demand for Appliances: describes the 

analysis that DOE conducted to determine the consumer sensitivity to 

appliance purchase price changes as well as operating cost changes and 

household income. 

Appendix 11A User Instructions for Shipments and NIA Spreadsheets: briefly 

describes the shipments and national impact analysis (NIA) spreadsheets 

for each of the considered products and provides brief user instructions 

on how to operate the spreadsheets. 

Appendix 11B National Equipment and Operating Costs: provides the components to 

the NPV for each of the considered products, namely, the present value 

of the equipment costs and the present value of the operating costs. 

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EERE-2006-STD-0127 COMMENT 64.2
Appendix 13A Manufacturer Interview Guides: presents questionnaires used to guide 

DOE interviews with residential cooking product manufacturers. 

Appendix 13B Government Regulatory Impact Model (GRIM): discusses the method to 

estimate the change in value of an industry or manufacturers(s) 

following a regulation or a series of regulations. 

Appendix 14A Interpolation of Utility and Environmental Results from NEMS-BT 

Output: describes the methodology for using output from NEMS-BT to 

estimate the utility impact and environmental impact results for product 

standards. 

Appendix 17A Regulatory Impact Analysis Supporting Material: provides more 

detailed information on the data used to conduct the Regulatory Impact 

Analysis. 

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