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### APPENDIX 5-B. DATA SUBMITTAL

TABLE OF CONTENTS

5-B.1 INTRODUCTION ................................................................................................. 5-B- 1

5-B.2 WHIRLPOOL PROPOSED AMENDMENTS TO DOE CLOTHES DRYER

TEST PROCEDURE ............................................................................................. 5-B- 1

5-B.3 AHAM DE-IDENTIFIED CLOTHES DRYER DATA

– COLLECTED

DECEMBER 2007 FOR DOE RULEMAKING ................................................. 5-B- 13

5-B.4 DOE RESIDENTIAL CLOTHES DRYER ENGINEERING ANALYSIS

DATA REQUESTS

–

AHAM DATA SUBMITTAL ......................................... 5-B- 15

5-B.5 DOE ROOM AIR CONDITIONER ENGINEERING ANALYSIS DATA

REQUESTS

–

AHAM DATA SUBMITTAL ..................................................... 5-B- 20

5-B.6 DOE DATA REQUESTS FOR RESIDENTIAL CLOTHES DRYERS AND

ROOM AIR CONDITIONER S

– AHAM DATA SUBMITTAL 01/09/2009 .... 5-B- 25

LIST OF TABLES

Table 5B.3.1 Residential Clothes Dryer Shipments (in Thousands of Units) ....................... 5-B-13

Table 5B.3.2 Residential Clothes Dryer Market Share Efficiency Data ............................... 5-B-13

Table 5B.3.3 Effect of RMC on Residential Clothes Dryer Energy Factor .......................... 5-B-14

Table 5B.4.1 Residential Clothes Dryer Shipment and Shipment-Weight Average

Efficiency Data ........................................................................................ 5-B-15

Table 5B.4.2 Residential Clothes Dryer Market Share Efficiency Data: Vented Electric

Standard ................................................................................................... 5-B-16

Table 5B.4.3 Residential Clothes Dryer Manufacturer Cost Data: Vented Electric

Standard and Electric Compact 120V ...................................................... 5-B-17

Table 5B.4.4 Residential Clothes Dryer Manufacturer Cost Data: Vented Electric

Compact 240V and Gas ........................................................................... 5-B-18

Table 5B.6.1 AHAM Weighted RMC for Front-Load and Top-Load Clothes Washer

Units, 2000-2008...................................................................................... 5-B-25

LIST OF FIGURES

Figure 5B.5.1 AHAM Room Air Conditioner Market Share, Shipment-Weight Efficiency

Data, Market Share Efficiency Data Submittal ........................................ 5-B-21

Figure 5B.5.2 AHAM Room Air Conditioner Market Share Efficiency Data Submittal ...... 5-B-215

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### APPENDIX 5-B. DATA SUBMISSIONS

5-B.1 INTRODUCTION

This appendix presents the shipments and incremental cost data submitted to the U.S.

Department of Energy (DOE) by the interested parties in support of the engineering analysis for

this rulemaking. This appendix presents the Whirlpool Corporation (Whirlpool) proposed

amendments to the DOE test procedure for clothes dryers to include methods for the testing of

condensing dryers. Information was provided for residential clothes dryers in response to data

request sheets generated by DOE and provided to the Association of Home Appliance

Manufacturers ( AHAM ). See chapter 5 of the preliminary technical support document

(preliminary TSD) for details of the engineering analysis for which these data were used.

5-B.2 WHIRLPOOL PROPOSED AMENDMENTS TO DOE CLOTHES DRYER

TEST PROCEDURE

Whirlpool submitted the following proposed amendments to the DOE clothes dryer test

procedure to include methods for the testing of condensing dryers to DOE on Sept. 4, 2007.5

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### 5-B.3 AHAM DE -IDENTIFIED CLOTHES DRYER DATA

– COLLECTED

DECEMBER 2007 FOR DOE RULEMAKING

AHAM supplied shipments, market share efficiency data, and data on the effects of

remaining moisture content (RMC) on residential clothes dryer energy factor, representing the

aggregated inputs from manufacturers which produce the significant majority of residential

clothes dryers. Table 5-B.3.1 through Table 5-B.3.3 reproduces the tables of clothes dryer data

submitted to DOE by AHAM.

Table 5-B.3.1 Residential Clothes Dryer Shipments (in Thousands of Units)

Year Clothes Dryers

Electric Standard

Electric Compact

Electric Gas Total

2006 6,360 6,246 114 1,614 7,974

2005 6,408 6,330 78 1,707 8,115

2004 6,262 6,159 103 1,660 7,922

2003 5,718 5,622 96 1,616 7,334

2002 5,402 1,490 6,892

2001 5,117 1,384 6,501

2000 5,095 1,480 6,575

1999 4,865 1,444 6,309

1998 4,482 1,307 5,789

1997 4,115 1,195 5,310

1996 3,947 1,193 5,140

1995 3,823 1,169 4,992

1994 3,838 1,239 5,077

1993 3,674 1,156 4,830

* Original version of Table 5-B.3.1 was sent on April 11, 2008, but was revised on Aug. 20, 2008 (shown above).

** AHAM Note: Compact Electric shipments are not available prior to 2003. Standard electric shipments are

determined from the difference in overall electric shipments and compact electric shipments.



### Table 5-B.3.2 Residential Clothes Dryer Market Share Efficiency Data

Vented Electric Standard Vented Gas

EF Range,

lb/kWh Mark et Share

for 2005 (%) Market Share

for 2006 (%) EF Range,

lb/kWh Market Share

for 2005 (%) Market Share

for 2006 (%)

3.01

- 3.09 26 33 2.67

- 2.74 25 28

3.10

- 3.29 74 67 2.75

- 2.84 42 44

3.20

- 3.29 >2.85 32 27

>3.295

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### Table 5-B.3.3 Effect of RMC on Residential Clothes Dryer Energy Factor

RMC into Dryer

(%) Baseline

Model Test Target Actual

1

70 70 3.1

2 70.08 3.08

3 70.08 2.99

4 70.24 3.11

5 70.33 3.08

6 70.17 3.07

7 69.7 3.07

8 71.6 3.27

9 70.5 3.03

10 70.9 3.13

11 70 3.04

12

56 56 3.77

13 55.99 3.73

14 55.99 3.85

15 55.99 3.74

16 58.43 3.73

17 58.58 3.8

18 58.58 3.82

19 55.4 3.8

20 55.8 3.78

21 55.7 3.83

22 56 3.59



### Target RMC into Dryer 70 56

Average RMC into Dryer 70.3 56.6

Average EF 3.09 3.77

Standard Deviation 0.07 0.07

Percent EF Change 22%5

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### 5-B.4 DOE RESIDENTIAL CLOTHES DRYER ENGINEERING ANALYSIS

DATA REQUESTS

– AHAM DATA SUBMITTAL

AHAM supplied shipments, average energy and water use, and incremental cost data to

DOE, representing the aggregated inputs from manufacturers which produce the significant

majority of residential clothes dryers. Table 5-B.4.1 through Table 5-B.4.4 reproduces the tables

of residential clothes dryer data submitted to DOE by AHAM in response to DOE’s engineering

analysis data request (See appendix 5A).

Table 5-B.4.1 Residential Clothes Dryer Shipment and Shipment-Weight Average

Efficiency Data

Year Shipments, Domestic + Imports

(Thousands of Units) Shipment

- Weighted Average Efficiency

(EF, cycles/kWh )

Vented Vent

- less Vented

Electric

Gas Electric Electric

Gas All

Electric St andard All

Compact Compact

240 V Combo Standard Compact

120 V Compact

240 V

1993 3,674 1,156

1994 3,838 1,239

1995 3,823 1,169

1996 3,947 1,193

1997 4,115 1,195

1998 4,482 1,307

1999 4,865 1,444

2000 5,095 1,480

2001 5,117 1,384

2002 5,402 1,490

2003 5,718 5,622 96 1,616

2004 6,262 6,159 103 1,660

2005 6,408 6,330 78 1,707 3.10 2.70

2006 6,360 6,246 114 1,614 3.10 2.70



### Comments to Table 5-B.4.1 from AHAM:

1. Shipments are from AHAM Fact Book. AHAM only collects shipment data on Standard

Electric and Standard Gas vented residential clothes dryers. These are shown as All

Electric and Gas.

2. Members provided information on compact shipments, but this is a small market and

aggregated data for both compact classes is not available. Therefore, compact shipments

include shipments of both 120V and 240V vented residential dryers after 2003. These

values are slightly different than those provided in August 2008, as I had not incorporated

both classes into the total.

3. The Standard column shows the difference between the aggregated member-supplied

compact shipments (120V and 240V) and the All Electric published in the AHAM Fact

Book. The source of and breakdown of the shipment information is slightly different, but

we believe it is consistent.

4. Aggregated shipment weighted average efficiencies are only available for 2005 and 2006

for Standard Electric and Gas dryers. We did not receive enough input to provide data for

years earlier than 2005 or for compact vented units.5

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### Table 5-B.4.2 Residential Clothes Dryer Market Share Efficiency Data: Vented Electric

Standard

Vented Elec tric Standard Vented Gas

EF Range,

lb/kWh Market Share

for 2005 (%) Market Share

for 2006 (%) EF Range,

lb/kWh Market Share

for 2005 (%) Market Share

for 2006 (%)

3.01

- 3.09

(Baseline = 3.01) 26 33 2.67

- 2.74

(Baseline = 2.67) 25 28

3.10

- 3.29 74 67 2.75

- 2 .84 42 44

3.20

- 3.29 >2.85 32 27

>3.29

* AHAM Note: Total Market Share percentages should equal 100%.



### Comments to Table 5-B.4.2 from AHAM:

1. To maintain confidentiality, market share between EF of 3.20 and 3.29 have been

incorporated into the EF range between 3.10 and 3.19.

2. To maintain confidentiality, market share for EF > 2.94 have been incorporated into EF

> 2.85.

3. We were not able to obtain sufficient data for Vented compact 120V and 240V.

4. We have provided data for both 2005 and 2006.

5. Values have not changed from original submission.5

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### Table 5-B.4.3 Residential Clothes Dryer Manufacturer Cost Data: Vented Electric Standard and Electric Compact 120V

Product Class  Vented Electric Standard Vented Electric Compact 120V



### Efficiency Level 1 2 3 1 2 3

EF (lb/KWh) 3.10 3.16 3.39

- - 3.79

Design Options

Average Incremental Costs ($ Per Unit)

Material 9 42 140

Labor 2 11 45

Overhead# 2 4 12

Minimum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Maximum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Conversion Capital Expenditures ($, Millions)

Building CAPX 0.25 9 .02 50.18

Tooling/ Equipment CAPX 5.25 37.68 118.93

One

- Time Product Conversion Expenses ($, Millions)

R&D 3.62 15.87 58.97

Marketing

+Manufacturer respondents should suggest the design option or design option combinations that they believe should be associated with each efficiency level.

++ DOE was unable to obtain data for any clothes dryers with efficiencies between the standard level of EF = 3.13 and the max available level of EF = 3.79. Therefore, manufacturer respondents should

su ggest representative intermediate efficiency levels.

# 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 baseli ne unit complies with the current federal standard for residential clothes dryers

.



### Comments on Table 5-B.4.3 from AHAM:

1. Shaded cells indicate that AHAM did not receive enough input to aggregate incremental cost data. No data are available for

vented electric compact 120V, minimum/maximum incremental costs or marketing expenses.

2. Values are shipment weighted.

3. AHAM members provided the incremental cost to obtain the requested EF. To determine these costs, design options would

have been considered, but these were not shared with AHAM. AHAM recommends that DOE talk to manufacturers

individually to further understand the design options available for reaching these efficiency targets.5

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### Table 5-B.4.4 Residential Clothes Dryer Manufacturer Cost Data: Vented Electric Compact 240V and Gas

Product Class  Vented Electric Compact 240 V Vented Gas



### Efficiency Level 1 2 3 1 2 3

EF (lb/KWh) 2.98 3.09 3.2 2.75 2.85 3.44

Design Opti ons

Average Incremental Costs ($ Per Unit)*

Material 20 60 81

Labor 2 6 32

Overhead# 2 4 12

Minimum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Maximum Incremental Costs ($ Per Unit)*

Material

Labor

Overhead#

Conversion Capital Expenditures ($, Millions)

Building CAPX 0.46 29.83

Tooling/ Equipment CAPX 2.62 37.24 16.15

One

- Time Product Conversion Expenses ($, Millions)

R&D 2.99 15.46 12.91

Marketing

# 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 curr ent federal standard for residential clothes dryers. The Average Incremental

Cost should be reported as a shipment weighted average value. The Minimum and Maximum Incremental Costs presumably reflect the costs 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 may

be 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 labor includes the fringe benefits of direct laborers such as group

health 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 on

assets, 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) + Depreciation

Full Cost of Product = Full Production Cost + Non-production Costs (SG&A, R&D, interest, and profit)5 B

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### Comments on Table 5-B.4.4 from AHAM:

1. Shaded cells indicate that AHAM did not receive enough input to aggregate incremental

cost data. No data are available for vented electric compact 240V, minimum/maximum

incremental costs or marketing expenses or Building CAPX for EF 3.02 vented gas.

2. Values are shipment weighted.

3. AHAM members provided the incremental cost to obtain the requested EF. To determine

these costs, design options would have been considered, but these were not shared with

AHAM. AHAM recommends that DOE talk to manufacturers individually to further

understand the design options available for reaching these efficiency targets.

4. One respondent stated that design options were not available to reach an EF of 3.02 on

vented gas dryers, therefore, no incremental cost data were provided. Values shown are

calculated without this respondent

– but weighted basis is different. While all members

use straight-line depreciation, AHAM was not able to obtain a consistent response on the

years used in the calculation.5 B

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### 5-B.5 DOE ROOM AIR CONDITIONER ENGINEERING ANALYSIS DATA

REQUESTS

– AHAM DATA SUBMITTAL

AHAM supplied market share data, shipment-weighted efficiency data, and market share

ef ficiency data to DOE, representing the aggregated inputs from manufacturers which produce

the significant majority room air conditioners. Figure 5-B.5.1 through Figure 5-B.5.2 reproduces

Table A2-1 through Table A2-6 of the room air conditioner data submitted to DOE by AHAM in

response to DOE’s engineering analysis data request (See appendix 5A)

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### Figure 5-B.5.1 AHAM Room Air Conditioner Market Share, Shipment-Weight Efficiency Data, Market Share Efficiency Data

Submittal

Figure 5-B.5.2 AHAM Room Air Conditioner Market Share Efficiency Data Submittal5 B

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### Comments on Figure 5-B.5.1 and Figure 5-B.5.2 from AHAM:

Comments on Table A2-1:

1. Shipment data by product class is not available prior to 2005. Only overall shipments of

room air conditioners are available.

2. Shipments for units without reverse cycle and without louvered sides were combined, as

there were not sufficient data for each capacity range to maintain confidentiality.

3. Shipments for units with RC and without LS are combined, as are shipments for units

with RC and with LS in 2006, as there were not sufficient data for each capacity range to

report and maintain confidentiality.

4. No data can be provided for with RC and with/without LS in 2007.

Comments on Table A2-2:

1. As noted above, shipment data by product class is not available prior to 2005; therefore,

no shipment-weighted EER information can be provided for these years.

2. A double asterisk (**) indicates that AHAM cannot provide data for these capacity

ranges and or product classes since there is not enough data.

Comments on Tables A2 -3 through A2-5:

1. In several cases, efficiency bins were combined to provide as much information as

possible, while maintaining confidentiality.

2. When efficiency bins could not be combined, no data are provided. This is indicated by a

double asterisk (**).

Additional Comments from AHAM on Tables A2-7 through A2- 10 in DOE’s Engineering

Analysis Data Request:

Comments on Tables A2 -7 through A2-8:

AHAM was not able to obtain room air conditioner incremental cost data from members

for aggregation. In addition, many of our members purchase and sell their brands through OEMs,

and do not have access to this type of cost information.

Comments on Table A2-9:

While AHAM collected data on Portable Air Conditioner shipments, we do not feel our

information is representative of actual shipments. We are currently assuming that PAC

shipments are roughly 10 percent of RAC shipments. Shipment values received were

substantially lower than this estimate. We will begin collecting PAC shipment data in 2009.5 B

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### Comments on Table A2-10:

AHAM does not feel it is appropriate to provide capacity values for Portable Air

Conditioners at this time. There is not currently a standard that measures “true” PAC capacity –

as the procedures currently being used for testing are not designed for small, residential units.

AHAM has developed a Portable Air Conditioner standard (AHAM PAC-1), which is in its final

stages of approval. In January 2009, AHAM will commence a PAC certification program, in

which capacities will be reported and verified for both single and dual ducted units. These data

will be available on a public website.5 B

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### 5-B.6 DOE DATA REQUESTS FOR RESIDENTIAL CLOTHES DRYERS AND

ROOM AIR CONDITIONER S

– AHAM DATA SUBMITTAL 01/09/2009

AHAM submitted the following data and responses to DOE on Jan. 9, 2009 in response

to DOE’s data request (See appendix 5A).



# Data Requests for Standards Rulemaking for Residential Clothes

Dryers and Room Air-Conditioners

– 01/09/2009

Clothes Dryers

1. Sh ipment-weighted average remaining moisture content (RMC) over time for residential

clothes washers for top-loading units, front-loading units, and combined.

The file attached below [reproduced in Table 5-B.6.1 ] su mmarizes total shipments for

front-loading and top-loading units from 2002 through 2008. Shipment-weighted RMC

values are also shown for the front-load and top-load configurations. Note that the total

shipments shown in this table were the shipments used to calculate the weighted RMC

values. These shipments will be lower than those typically reported, as members did not

provide RMC values for all units.

Table 5-B.6.1 AHAM Weighted RMC for Front-Load and Top- Lo ad Clothes Washer Units, 2000-2008

Year Clothes Washer Shipments for Which

RMC was Reported Shipment

- Weighted RMC ( % )

Front

Loading Top

Loading Total Front

Loading Top

Loading Overall

2000 232,714 686,440 919,154 43.6 57.4 53.9

2001 235,989 473,629 709 ,618 41.3 57.7 52.2

2002 280,667 529,265 809,932 41.5 58.1 52.3

2003 351,411 1,676,877 2,028,288 43.1 54.5 52.5

2004 1,179,813 5,270,285 6,450,098 42.2 52.8 50.9

2005 1,563,108 5,394,511 6,957,619 40.8 52.7 50.1

2006 1,851,218 15,528,279 17,379,497 39 .3 51.8 50.5

2007 1,973,825 15,271,142 17,244,967 38.3 51.8 50.2

2008 2,043,024 4,492,059 6,535,083 38.1 51.0 47.0

* Original version of Table 5-B.6.1 was sent on Jan. 9, 2009, but was revised on July 7, 2009 (s hown above).



### 2. Data regarding consumer usage patterns for residential clothes dryers- the # of annual use

cycles. Preferably the number of dryer use cycles independent of wash cycles. If not, then

the percent of loads washed that are machine dried.

AHAM does not collect data on patterns of residential clothes dryer use. Confidential

industry data suggests that DOE’s proposed value of 329 cycles per year is more

representative than the current 416 cycles per year, but still on the high end. While dated,

1997 information from Natural Resources Canada (NRCan) on winter dryer use (5.85 B

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### loads per week; 302 cycles per year) is a realistic value for the United States

. (http://www.oee.nrcan.gc.ca/publications/infosource/pub/energy_use/sheu_e/sheu_5.cfm)

.

3. Has AHAM made any progress on the development of a clothes dryer test procedure

which tests dryer operation using automatic termination?

AHAM HLD-1 is currently undergoing revision. We expect the standard to be finalized

in 2 nd 

### quarter 2009. The revised standard addresses automatic termination by terminating

the test immediately prior to the start of the cool down period. Timer-dryers are set to a

specific time. Heat and total energy are both measured.

4. Is AHAM developing test methodology for condensing dryers?

AHAM is not currently developing a test methodology for condensing dryers. There is an

IEC standard for this technology; however, we expect that it would need to be modified

for use in the U.S. (effect on HVAC is one area of concern).

Room Air Conditioners

1. Data regarding consumer usage patterns

– room air-conditioner annual hours of

operation.

AHAM does not collect data on consumer usage patterns of room air conditioners or

hours of operation.