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UNITED STATES DEPARTMENT OF ENERGY 

PUBLIC MEETING ON THE PRELIMINARY ANALYSES FOR 

RESIDENTIAL REFRIGERATORS, REFRIGERATOR–FREEZERS, AND 

FREEZERS

U.S. Department of Energy 

 Room 8E–089 

1000 Independence Avenue, Southwest 

 Washington, D.C. 

Thursday, December 10, 2009 

 9:00 a.m. 

Participants

 DOUG BROOKMAN, Facilitator 

 AMANDA STEVENS 

 Pacific Gas and Electric Company 

 STEVEN ROSENSTOCK 

 Edison Electric Institute 

 TIM BALLO 

 Earth Justice 

 DEBRA BRUNK 

 Association of Home Appliance Manufacturers 

 STEVEN CHURCH 

 Whirlpool 

 MARTIN SEVERANCE 

 General Electric 

 KELLY KLINE 

 General Electric 

 RON LEWIS 

 Department of Energy 

 STEVEN STODDARD 

 Navigant Consulting, Inc. 

 ASA HOPKINS 

 Lawrence Berkeley National Laboratory 

 GREG ROSENQUIST 

 Lawrence Berkeley National Laboratory 

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Participants

 CONSTANTIN VON WENTZEL 

 Navigant Consulting, Inc. 

 DETLEF WESTPHALEN 

 Navigant Consulting, Inc. 

 JENNIFER AMANN 

 American Council for an Energy Efficient 

 Economy 

 DAVID HALL 

 Electrolux 

 RICHARD TOPPING 

 Subzero 

 ANDREW DELASKI 

 Appliance Standards Awareness Project 

 TOM ECKMAN 

 Northwest Power and Conservation Council 

 CHRISTOPHER JOHNSON 

 LG Electronics USA 

 CLAUDETTE PAPATHANASOPOULOS 

 Greenpeace Research Department 

 CHRIS KENT 

 U.S. Environmental Protection Agency 

 NOAH HOROWITZ 

 Natural Resources Defense Council 

 JEFF HARRIS 

 Alliance to Save Energy 

 JEFFREY KINGMAN 

 Navigant Consulting, Inc. 

 MICHAEL KIDO 

 Office of General Counsel 

 Department of Energy 

 LUCAS ADIN 

 Department of Energy 

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Participants

 JEFFREY GREENBLATT 

 Lawrence Berkeley National Laboratory 

 KERT DAVIES 

 Greenpeace Research Department 

 GRAHAM PARKER 

 Pacific Northwest National Laboratory 

 SEAN GOUW 

 Southern California Edison 

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A G E N D A 

AGENDA ITEM: PAGE: 

Welcome 

 Doug Brookman 6 

 Lucas Adin 6 

Opening Remarks, Introductions and Agenda Review 7 

 Doug Brookman 

Rulemaking Overview 11 

 Lucas Adin 

Brief Opening Remarks from Interested Parties 

 Debra Brunk 16 

 Association of Home Appliance Manufacturers 

Market and Technology Assessment, Screening 21 

Analysis, and Engineering Analysis 

 Detlef Westphalen 

Markups to Determine Product Price Analysis, 109 

Energy Use Characterization, and Lifecycle 

Cost Analysis 

 Greg Rosenquist 

 Asa Hopkins 

Afternoon Session

Shipments Analysis and National Impact Analysis 186 

 Asa Hopkins 

Preliminary Manufacturer Analysis 203 

 Steven Stoddard 

NOPR Analyses 214 

 Jeff Kingman 

 Greg Rosenquist 

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A G E N D A 

AGENDA ITEM: PAGE: 

Discussion of Other Issues and Final Remarks 239 

From Interested Parties 

 Debra Brunk 

 Association of Home Appliance Manufacturers 

Next Steps and Closing Remarks 241 

 Lucas Adin 

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 9:06 a.m. 

WELCOME 

DOUG BROOKMAN 

MR. BROOKMAN: Good morning, everybody, and 

welcome. This is the U.S. Department of Energy’s 

Public Meeting on the Preliminary Analysis for 

Residential Refrigerators, Refrigerator–Freezers, and 

Freezers. My name is Doug Brookman. Glad to see you 

here this morning. We’re going to have welcoming 

remarks from Lucas Adin. 

WELCOME 

LUCAS ADIN 

MR. ADIN: Good morning, everyone. I’ll keep 

this rather brief, but as Doug said, I’m Lucas Adin 

from the Department of Energy. I’m the project manager 

for the residential refrigerators rulemaking. I just 

wanted to welcome everyone. Thank you for coming 

today. This is a very important part of the rulemaking 

process. They’re all important, but this particular 

stage essentially lays the analytical foundation for 

the rulemaking that we’re going to be doing. Getting 

feedback from everyone here is very important. 

We appreciate you coming, and we look forward 

to hearing what you have to say about it. 

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1 OPENING REMARKS, INTRODUCTIONS, AND AGENDA REVIEW 

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DOUG BROOKMAN 

MR. BROOKMAN: Thank you. Let’s start off by 

doing introductions, as we typically do. We’ll start 

with you. Your name and organizational affiliation. 

MS. STEVENS: Sure. Hi. I’m Amanda Stevens. 

 I’m with Energy Solutions, here on behalf of Pacific 

Gas and Electric Company. 

MR. BROOKMAN: Thank you. 

MR. ROSENSTOCK: Steve Rosenstock, Edison 

Electric Institute. 

MR. BALLO: Tim Ballo, Earth Justice. 

MS. BRUNK: Debra Brunk, Association of Home 

Appliance Manufacturers. 

MR. CHURCH: Steve Church with Whirlpool. 

MR. SEVERANCE: Marty Severance, General 

Electric. 

MS. KLINE: Kelly Kline, General Electric. 

MR. KIDO: Michael Kido, DOE, Office of the 

General Counsel. 

MR. LEWIS: Ron Lewis, DOE. 

MR. BROOKMAN: Adin introduced himself. 

Please. 

MR. KINGMAN: Jeff Kingman, Navigant 

Consulting. 

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MR. BROOKMAN: I don’t think we need that. 

Just talk loudly, please. 

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MR. STODDARD: Steve Stoddard, Navigant 

Consulting. 

MR. ROSENQUIST: Greg Rosenquist, Lawrence 

Berkeley National Laboratory. 

MR. von WENTZEL: Constantin von Wentzel, 

Navigant Consulting. 

MR. WESTPHALEN: Detlef Westphalen, Navigant 

Consulting. 

MR. BROOKMAN: Please. 

MR. HOPKINS: Asa Hopkins, Lawrence Berkeley 

National Laboratory. 

MR. GREENBLATT: Jeffrey Greenblatt, Lawrence 

Berkeley National Laboratory. 

MR. JOHNSON: Christopher Johnson, LG 

Electronics USA. 

MR. ECKMAN: Tom Eckman, Northwest Power and 

Conservation Council. 

MR. HALL: David Hall, Electrolux. 

MR. TOPPING: Dick Topping, Subzero. 

MR. GOUW: Sean Gouw, Southern California 

Edison. 

MS. SULLIVAN: – Sullivan, DOE. 

MR. HENRY–RHOADS: Jack Henry–Rhoads, D & R 

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MR. FOGLE: Ryan Fogle, D & R International. 

MR. BROOKMAN: Okay. So, again, thanks to 

all of you for being here on time so we can get an 

early start on it today. 

I think all of you received a packet when you 

registered at the registration desk. I’m going to run 

through the agenda very briefly. I think most of you, 

or many of you at least, are familiar with these 

proceedings and the general form of this. 

In addition to the agenda, you have in your 

packet the presentation slides that will be the basis 

for both presentation and discussion today. That will 

be the principal thing that you can be referring to, in 

addition to what is broadcast up on the screen. 

You can see we’re going to start off first 

thing with a rulemaking overview. Following that, 

there’s an opportunity for each of you, or anybody that 

wishes to do so, to make brief summary remarks about 

issues of concern to you. 

Following that, immediately we’ll be moving 

into market and technology assessment, screening 

analysis, and engineering analysis. We will probably 

take a break mid–morning, round about 11:00 or so. 

Then, from there, we’re going to be doing markups to 

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determine price analysis, energy use characterization, 

lifecycle analysis, which may take us as far as 1:00. 

Round about there, 12:30 or one–ish, we’ll pause for 

lunch. 

Then, following lunch, shipments analysis, 

national impact analysis, preliminary manufacturer 

analysis. We’ll take a break mid–afternoon. We’ll go 

from there to the NOPR analyses and discussion of other 

issues and final remarks, another opportunity for you 

to make comments at the end of the day, discuss the 

next steps and other closing comments. 

That’s the general plan for today. Questions 

and comments on that? 

 (No response) 

MR. BROOKMAN: Okay. I think, then, we’ll 

proceed. I’d ask for your consideration. If you 

would, as we’re going along today, please speak one at 

a time. Please say your name for the record. There 

will be a transcript of this meeting provided, and it 

will be posted on the EERE website. What’s it take; a 

week, 10 days? 

MR. ADIN: A week. 

MR. BROOKMAN: Or so. Yeah, a week or so. 

Please, each time you speak, please say your name for 

the record. You don’t need to say your organizational 

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affiliation. We can trace it back to you one way or 

the other. 

I’m going to be queuing people as best I can 

by name to speak. I’m also wishing to encourage 

follow–on comments, so please feel free to do that. 

If you’d keep the focus here. Please limit 

your sidebar conversations. These microphones have 

improved and we can hear you. You need to push the 

button. It needs to have a bright green rather than a 

dull green in order for us to pick you up on the sound 

system, the little LED button. But if you’d limit your 

sidebar conversations. 

Also, be concise. Share the airtime. 

There’s a lot to cover here in this day, and if we can 

keep it focused, that would be helpful. 

Then, let’s proceed with a rulemaking 

overview. 

RULEMAKING OVERVIEW 

LUCAS ADIN 

 (PowerPoint presentation) 

MR. ADIN: I’m going to go ahead and start by 

just giving a brief overview of the rulemaking process. 

 A lot of these things many of you are probably 

familiar with already, so I’m not going to get into too 

much detail, particularly since we’re going to be 

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getting into a lot of detail over the course of today 

on many of these things. 

These are just the basic items that we cover 

with the public meeting and its purpose. I won’t go 

through those points specifically. 

Throughout the presentation, there will be 

some issues that we are specifically requesting comment 

on, so these issue boxes will come up from time to time 

in the presentation. We will be discussing them. 

Those are things that we’re specifically soliciting 

comment on, so we just put those in there to make it a 

little more obvious which items we’re looking for input 

on. 

The agenda. Doug pretty much went through 

this already, so I’m not going to belabor this point 

too much. 

This slide covers some of the previous 

rulemakings on refrigerators before today. The first 

one was published in 1989, and that was as a result of 

1987 amendments to the Energy Policy and Conservation 

Act, or EPCA, as we more commonly refer to it. That 

was the first actual requirement for refrigerator 

standards, and those standards first went into effect 

January 1st, 1993. That was the first round, so to 

speak. 

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There was a correction for three product 

classes in 1990, and then a second round of final rule 

for conservation standards was published in 1997. It 

went into effect July 1st, 2001. Those are the 

standards that are in effect today. 

There was an analysis published in October 

2005, to set priorities for the next rulemaking, and 

then the Energy Independence and Security Act of 2007, 

required publication of new standards by December 31st

of 2010, so next year, and then they would take effect 

January 1st of 2014. 

This slide basically shows the rulemaking 

process overall. We went through the framework 

document process last year and had a meeting towards 

the end of 2008. Today, we are having the public 

meeting for the preliminary analysis. 

Some people who are familiar with this 

process as it was will probably know this stage as the 

advanced notice of proposed rulemaking. The Energy 

Independence and Security Act of 2007, actually removed 

the requirement for us to do that, so the ANOPR, as we 

typically called it, is actually no longer required by 

law. We kept this stage in there because the input 

that we get at this stage really is very important. We 

found that it was really important to keep it in there. 

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 That was something that was mentioned at the framework 

document meeting last year, and that’s how we’re going 

to continue. 

That’s where we are today. This slide just 

basically shows kind of an expanded version of this 

stage and all the things that are included there. 

These are the things that we’ll be discussing today, 

the things that make up the Technical Support Document. 

 I’m not going to go through them individually, but 

that just shows the general flow of all those analyses. 

Some key documents describing the preliminary 

activities. The Technical Support Document has a 

number of sections which give an overview and describe 

how the analysis actually is laid out and how it works. 

 There is an executive summary which pretty much just 

gives an umbrella overview of everything. Chapter 2 

describes the analytical approach in detail. 

Then, the notice of public meeting. This is 

essentially what replaced the advance notice of 

proposed rulemaking, was the notice for today’s 

meeting. I take it most of the people here probably 

saw that. We did pass that out today. Then, the 

preliminary TSD. We’ve posted that on the website as 

well. 

The next stage will be the notice of proposed 

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rulemaking stage. This slide shows the flow of the 

steps that are included in accomplishing that stage. I 

won’t go through them one by one, but you have them on 

the handout, and that basically shows how that stage 

works. That stage does include the proposal of 

possible standards that we might set, so we would be 

soliciting input on those at that time. 

Then, in the final rule stage, we’d just 

revise the proposed rulemaking analysis, conduct a 

final review, and then the publishing of the final rule 

would set the standards that would take effect on 

January 1st, 2014. 

What this slide shows are the factors that we 

have to consider by law in EPCA. They are those seven 

factors on the left. Then, the analyses on the right 

side are just the corresponding analyses that we 

conduct in order to satisfy those requirements. 

They’re all pretty straightforward, and we do them for 

every rulemaking. 

Then, of course, we solicit comments from 

participants via statements or questions and comments 

at the public meetings like we’re having today. 

The comment period for this particular 

rulemaking will be open through January 15th, 2010, so 

we can receive comments on this particular stage up 

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until that day. 

I think that covers my overview. I’ll turn 

it back over to Doug. 

MR. BROOKMAN: Thank you. Questions here 

based on any of this material? 

 (No response) 

MR. BROOKMAN: Let me mention we do have 

quite a few seats up here at the front table. Any of 

you that wish to join us up here would be welcome to do 

so, especially if you intend to talk a lot. 

Okay. Now the Department would provide an 

opportunity for anybody to make brief summary opening 

remarks, raise issues of concern to you, and we’ll just 

have you turn on the microphone and say your name and 

then speak. Who’d like to start us off? Debra. 

BRIEF OPENING REMARKS FROM INTERESTED PARTIES 

REMARKS BY DEBRA BRUNK 

ASSOCIATION OF HOME APPLIANCE MANUFACTURERS 

MS. BRUNK: Debra Brunk with AHAM. Just a 

couple of things to summarize. First of all, I want to 

say that we really appreciate DOE scheduling this pre–

NOPR stage here. We really think it’s important for 

stakeholders and DOE to communicate at this stage when 

so much of the engineering analysis has been done. 

Again, we appreciate that with the way things have been 

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reorganized with the ANOPR no longer really being a 

requirement. Again, we appreciate that. I think it’s 

very helpful. 

Second, I do want to recognize that this is a 

very complicated rulemaking. There’s a lot going on, 

and part of it we’re not even really talking about 

today, which is the whole test procedure. We’re 

talking about it in an indirect way but not directly in 

terms of what the specific changes are, but more how 

that test procedure actually affects the standard. 

This is making it a little bit difficult for 

us as an industry to do this now before we go through 

all the changes in the test procedure, but again, we 

recognize it’s complicated. There’s a lot going on 

here. There is substantial analysis completed. It 

looks very thorough. 

I think our concerns are around the impact to 

energy use with the proposed test procedure. We will 

be talking a little bit more about that in terms of 

some of the ice–making energy that I know is a new 

issue for comment in this presentation. 

We just want to make sure that – we support 

the proposed changes, but we want to make sure that all 

the analysis is completed in a thorough and full way. 

This is really just too important. This is a huge 

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change from 1979 to today. It’s too important to risk 

any shortcuts in the analysis or anything like that, of 

course recognizing the time frame we’re under. 

Finally, we do continue to have specific 

concerns about upcoming regulations and legislation on 

the phase–down of HFCs. We will get into just a little 

bit more detail on that, but do want to just 

reemphasize that that may have a substantial impact in 

terms of cost and efficiency on the industry. 

MR. BROOKMAN: Thank you. Can you simply 

state what the status of the test procedure is, Adin? 

No? You can’t state. I just thought, since she raised 

it, we’d figure out what it is. 

MR. ADIN: We’re focused on the standard. 

However – 

MR. BROOKMAN: Yeah. However. Adin, go 

ahead. 

MR. ADIN: I can’t comment specifically on 

what the status of the test procedure rulemaking is in 

itself because we’re really trying to stay focused on 

this particular rulemaking and the conservation 

standard. It’s in the notice of proposed rulemaking 

stage. That’s about as – 

MR. BROOKMAN: That’s what I wanted to know. 

 Thank you. I couldn’t remember how they’re all 

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aligned. 

Yes, Steve Rosenstock. 

MR. ROSENSTOCK: Steve Rosenstock, EEI. If 

it’s in the NOPR stage, has a NOPR been published for 

the test procedure? Again, I haven’t – 

MR. ADIN: The NOPR has not yet been 

published for the test procedure. 

MR. ROSENSTOCK: Okay. Thank you. 

MR. BROOKMAN: Other summary remarks here at 

the outset? 

 (No response) 

MR. BROOKMAN: No additional remarks here at 

the outset? If we’re not careful, we’ll finish ahead 

of schedule today. 

Okay. Then, of course we do invite and 

expect that you’ll have plenty to say as we’re going 

through the analytic slides. Let’s, then, proceed with 

the market and technology assessment, screening 

analysis, and engineering analysis. Debra. 

MS. BRUNK: This is Debra Brunk. I noticed 

there is a number of folks that have joined us. I was 

wondering if we could just have introductions of those 

folks who have joined us. 

MR. BROOKMAN: Okay. A few people did. 

Please. 

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MS. AMANN: Jennifer Amann, American Council 

for an Energy Efficient Economy. 

MR. BURT: Lane Burt from the Natural 

Resources Defense Council. 

MR. DELASKI: Andrew DeLaski, Appliance 

Standards Awareness Project. 

MR. BROOKMAN: Christopher, you joined us, 

right? You introduced yourself already. 

MR. JOHNSON: Yeah. 

MR. BROOKMAN: Say your name for the record? 

MR. HALL: Yes. David Hall with Electrolux. 

MR. BROOKMAN: Thank you, David. Who else 

joined us? Tom, did you introduce yourself? 

MR. ECKMAN: Yeah. 

MR. BROOKMAN: And Dick, both. Yes. Please 

say your name? 

MR. DAVIES: Kert Davies, Greenpeace Research 

Department. 

MR. BROOKMAN: Thank you. Yes? Anybody 

else? Did we miss anybody? Yes. 

MR. HOROWITZ: Noah Horowitz with the Natural 

Resources Defense Council, NRDC. 

MR. BROOKMAN: Thank you. Yes? 

MR. PARKER: Graham Parker with Pacific 

Northwest National Laboratory. 

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MR. BROOKMAN: Thank you. 

MARKET AND TECHNOLOGY ASSESSMENT, SCREENING ANALYSIS, 

AND ENGINEERING ANALYSIS 

DETLEF WESTPHALEN 

 (PowerPoint presentation) 

MR. WESTPHALEN: Thanks, Doug. Again, my 

name is Detlef Westphalen. I’m with Navigant 

Consulting. I was very heavily involved with the MTI 

parts of the analysis, the market and technical 

assessment, the screening analysis, and the engineering 

analysis. 

I’ll start with this chevron here, the market 

and tech assessment and the screening analysis. I 

guess I’ll be talking for the better part of the 

morning. I’ll try to be quick. If I’m too quick, slow 

me down. Don’t slow me down too much because I want to 

make sure there’s enough time for all of you to be 

talking because this is intended to be an exchange. 

The market and technology assessment purpose 

is to characterize the market: who are the 

manufacturers, what are the products, what are the 

efficiency levels available, what are the shipments by 

product classes, and also a look at the technologies 

that are available to improve efficiency. 

We really only have one slide on the top–

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level of market characteristics. This is broken out by 

the four key product categories that were carried 

through the analyses, separated by refrigerators and 

refrigerator–freezers on the one hand and freezers on 

the other, and also separated by standard size and 

compact. Compact products are those that are less than 

seven and three–quarter cubic feet with refrigerated 

volume and less than 36 inches in height. 

The total shipments of all these products 

were a little bit higher early in the decade. Now 

they’re a little bit less than 15 million per year. 

Most of that is standard size refrigerators and 

refrigerator–freezers. The compact refrigerators and 

standard size freezers represent currently roughly 2 

million shipments each for those categories and about a 

half million for compact freezers. 

The markets for the standard size products 

are characterized by being heavily dominated by a small 

number of manufacturers. That’s particularly so for 

freezers, for which 85 percent of the market was held 

by two North American manufacturers. We saw news that 

one of these manufacturers was liquidated recently. 

The compact markets are much more diverse in 

terms of manufacturer representation and have a bit 

different issues as a result. 

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Moving on to test procedures, as mentioned, 

there is a concurrent test procedure rulemaking 

ongoing. It currently has not reached publication of 

the NOPR phase but is approaching. The current test 

procedures are found in the Code of Federal Regulations 

at 10 C.F.R. 430, Subpart B, Section 23, and also 

Appendix A1 for refrigerators and refrigerator–

freezers, Appendix B1 for freezers. 

In the test procedure rulemaking, DOE expects 

to make a number of changes. Some of these changes 

we’ll have to talk about a little bit because they 

directly impact the analyses. These changes are 

intended to take effect in two phases, the first phase 

to take effect shortly after the final rule for the 

test procedure rulemaking, the second to take effect 

simultaneously with this energy conservation standard 

rulemaking. The preliminary analyses that we’ll be 

discussing are based on DOE’s expectation for the full 

set of events. 

The key test procedure amendments that are 

expected to affect the preliminary analyses are as 

listed below, the first being compartment temperature 

changes, which were discussed at the framework workshop 

and are part of the international standard that is also 

under development. 

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Temperatures for refrigerator–freezers and 

refrigerators in the compartments will be going down. 

As I say, this is expectation at this point, since 

we’re not even at a NOPR stage. Temperatures for all 

refrigerators would be going up. 

Just to clarify “all refrigerators,” that 

does not mean every refrigerator. That means 

refrigerator products that have a freezer compartment 

that’s either less than half a cubic foot in size or no 

freezer compartment. 

As a result of the temperature changes, the 

volume adjustment factors will also change. That also 

affects freezers, even though the compartment 

temperature for the freezers does not change. 

Other test procedure changes that affect the 

preliminary analyses. The variable anti–sweat heater 

control. This is a modified test procedure that has 

been the topic of several waivers of the test 

procedure. This plays into one of the analyses for one 

of the product classes. 

Modified volume calculation method. That’s 

another change that was discussed at the framework 

meeting. 

That takes us to ice–makers. Ice–making 

energy has not been incorporated into the analyses that 

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we’ll be presenting today. Currently, there is no 

measurement of ice–making energy in the test procedure. 

I think we have – 

MR. BROOKMAN: Steve Rosenstock. 

MR. ROSENSTOCK: Steve Rosenstock, Edison 

Electric Institute. Actually, this was about the 

previous slide. I’m sorry. I didn’t – 

MR. WESTPHALEN: Okay. Sorry. 

MR. ROSENSTOCK: A quick follow–up. It says 

in here about two–step timing about certain amendments 

shortly after the test procedure and then coincident 

with the standard. The final rule has to be done and 

published in December of next year. You’ve got one 

year before the final rule comes out. In terms of the 

test procedure, since – and again, there are 

significant changes that are definitely going to have 

an impact on the engineering test procedure and energy 

output of the different products and the annual energy 

usage. 

I think the timing of this is very critical 

just because it sounds like things are being done in 

parallel, but then the key pivot point, especially, 

I’ll say, just in terms of interior temperatures change 

in the second stage, that changes the lifecycle 

analysis, possibly considerably. 

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I guess I’m a little concerned that there’s 

this parallel path and then, all of a sudden, it’s like 

the test procedure changed in November of 2010 as a 

final rule and then all the other analysis has to 

change. I don’t know in terms of timing how it’s – I 

think, ideally, the test procedures would be finalized 

and finished early next year, all of the stages, and 

then everything else can proceed. I’m worried about a 

parallel processing where things kind of go back and 

forth. 

MR. WESTPHALEN: You’re right. We have 

schedule issues. The only other thing I’ll say is that 

our expectations are that energy use would not be 

affected by the first phase of test procedure changes. 

 So, our expectations for the test procedure changes 

that will affect energy use have been outlined here, 

and they are part of the analyses, including the 

lifecycle analysis and the national impact analysis. 

MR. BROOKMAN: Andrew DeLaski. 

MR. DELASKI: My recollection is that the 

Department’s practice in the past has been to issue the 

final test procedure rule by the time the NOPR is 

published. It seems to me that’s still perfectly 

possible in this docket and that the approach being 

taken is reasonable. 

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MR. BROOKMAN: Okay. Thank you. Yes, Tom 

Eckman. 

MR. ECKMAN: The statement that ice–maker 

requirements are not included, but the field 

utilization adjustment that’s made in the analysis to 

get from the test procedure to in situ performance 

incorporates ice–maker consumption. 

MR. WESTPHALEN: When I say ice–making is not 

included, I mean the energy used to produce the ice is 

not included in the analysis. 

MR. ECKMAN: Well, it certainly is in the 

lifecycle cost analysis. If ice–makers are included in 

that markup, it’s a field use. 

MR. WESTPHALEN: That is a good point, and 

Greg can talk about that a little bit more when he gets 

into the lifecycle cost analysis. The engineering – 

MR. ECKMAN: I know you’re not attempting to 

regulate that usage, but certainly, it’s being 

incorporated in that analysis. 

MR. WESTPHALEN: In the lifecycle cost 

analysis, yes. That’s a good point. It has not been 

incorporated into the engineering analysis. Greg will 

talk about how the engineering analysis results relate 

to field energy use. That’s part of every rulemaking. 

MR. BROOKMAN: Other comments on this point? 

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MR. BROOKMAN: Okay. 

MR. WESTPHALEN: I guess we were in the 

middle of this slide here. As mentioned, the current 

test procedure has no measurement of ice–making energy. 

 That is, energy required to produce the ice. 

At the framework workshop and the associated 

comment period, there were no comments explicitly 

calling for measurement of ice–making energy. 

AHAM began working on a test procedure for 

ice–making energy use last summer, and DOE will 

consider all these factors in the development of the 

rules for the test procedure and for the energy 

conservation standards. 

MR. BROOKMAN: Yes, Andrew. 

MR. DELASKI: I don’t want to slow you down, 

but I do want to set the record straight. In the joint 

comments filed by ASAP, ACEEE, NRDC, PG&E, and the 

Power and Conservation Council, as well as others, we 

wrote, “Where is the Department’s updated test 

procedure to explicitly address the energy consumption 

for ice–making functions and to address the associated 

heat losses?” So, your second bullet there is wrong. 

We did explicitly ask for that. 

MR. WESTPHALEN: Okay. 

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MR. BROOKMAN: Thank you, thank you. 

MR. DELASKI: Doug, I hope at some point 

there can be some explanation because there’s no 

response to that. Since the document didn’t respond to 

our comment, if we could get some response today as to 

why you decided not to address ice–making energy 

consumption. We would appreciate the feedback on that. 

MR. BROOKMAN: Dick Topping. 

MR. TOPPING: Yeah. I’m actually the chair 

of the AHAM subcommittee looking at ice–making as well 

as test procedure issues. I’ll just make the point I 

think everyone should put a big star on this slide 

because this is a huge issue upcoming in the rulemaking 

in terms of scheduling. Everyone needs to be working 

with DOE on this in the very near future, and weeks, 

not months, to try to address this and to see where we 

go with this. It’s not an easy issue. 

MR. BROOKMAN: Dick, can you characterize 

briefly the progress that you’re making in your working 

group? 

MR. TOPPING: I think we’re making good 

progress. The measurements have shown wide variability 

in the results, and it’s not an easy thing to add to 

the test procedure without a lot of vetting and 

feedback from various parties. This has never been 

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done before. 

This isn’t the time to go into the details, 

but there are many details to discuss. 

MR. BROOKMAN: Okay. 

MR. WESTPHALEN: Dick, I guess you got one 

slide ahead of us here, but that’s okay. 

At this point, we request comment on ice–

making energy use. We’ve broken this down, actually, 

into four points. There may be other points to 

address. Dick already spoke to the expected schedule 

for finalizing an accurate and repeatable test 

procedure. 

Another question is what kind of energy use 

metric should be developed for these products that 

incorporates the ice–making energy use. 

Third, what would be a fair way of 

establishing maximum ice–making energy use as a 

function of different product characteristics? 

Fourth, what technology options would exist 

to reduce energy use associated with ice–making. 

MR. BROOKMAN: Debra Brunk. 

MS. BRUNK: Debra Brunk from AHAM. I’ll just 

try to briefly address each one of those. The first 

one really is a reiteration of what Dick said. 

Obviously, we’ve been working the last six months on 

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developing this test procedure. It has been more 

difficult, I think, than we all expected when we first 

started. There are a lot of details in terms of how 

you have to deal with the cycles and all of this with 

the compressors that are little details like that that 

we need to work out. 

Again, as Dick noted, the variability right 

now is high. We have shared this information with DOE 

and had some discussions on that. We are keeping them 

updated on our progress. 

I think regarding timeline, as Dick stated, 

we need to work together to figure out something that 

will work on this. If we were to do this as a standard 

type of test procedure development, we’d be looking at 

probably a couple of years. I think we’re looking at 

trying to shrink this down into one year, and so we 

would be looking for sometime the middle of next year 

to feel like we might have something that is good, 

repeatable, and a strong test procedure. 

I think we can’t emphasize that enough. 

Anything that we add in here needs to be strong and 

reliable. We don’t want to add a lot of variability to 

this test procedure or to the numbers that we’re 

getting so that there are more questions than there 

are, actually, answers. 

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I think, regarding the second question, we 

would look at incorporating the ice–maker energy as a 

kilowatt–hour–per–year number. Right now, with the 

test procedure that we have, we have a means to do 

that, where we are basically converting the amount of 

ice that is made. We normalize it to an amount of 

pounds, and we can convert that into kilowatt–hours per 

year. Again, it would be basically additive with the 

current energy use. 

Then, third is a good question regarding how 

is a fair way to add this adjusted volume. I think 

we’ve – I’m sorry, not adjusted volume. This ice–maker 

energy. We’ve found that it doesn’t make sense to just 

add some number to all the products. That really 

doesn’t work. That’s something that we need to 

continue to do. This is an area, really, where we 

would be looking at significantly more data to 

understand the impact of volume and the ice–making 

energy use. 

Again, I should mention here automatic ice–

maker energy use and ice–maker energy use are two 

different things which also need to be addressed. 

Then, finally, to just address the fourth, I 

think we’re working hard to look at incorporating this 

into the test procedure. The technology options that 

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exist, I think we think that question is a little bit 

premature. 

I think what we would like to see is to get 

the test procedure done and if it could be an add–on, 

perhaps, to the energy efficiency standard. We get 

some baseline data, we understand how the test 

procedure is doing, and then, in the next rulemaking, 

we could start to incorporate analysis on what might be 

some of the design options or different things that 

could be done to reduce automatic ice–making energy, 

again the key being automatic ice–maker energy. You 

cannot reduce ice–making energy in general, which is 

just the thermodynamic energy required to turn water 

into ice. 

Hopefully, I didn’t speak too long on that. 

MR. BROOKMAN: Thank you. You see four 

specific queries there. Additional comments? Steve 

Rosenstock. 

MR. ROSENSTOCK: Steve Rosenstock, Edison 

Electric Institute. First question, I guess I’m a 

little – the expected schedule for finalizing the test 

procedure. As a stakeholder, there’s no way for me to 

know what the expected schedule is. I’m sorry. 

DOE is responsible for the test procedure, 

so, again, as a stakeholder, I have no idea. I would 

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hope sooner rather than later, but that’s as much as I 

would comment because I would hope that DOE and all the 

other stakeholders, especially AHAM, would be able to 

finalize something as soon as possible. We don’t know 

what the schedule is. 

On Question Number 3 on ice–making energy 

usage, isn’t it really a function of volume versus – 

again, I don’t have the data, but I would assume that 

it’s really more of a function of occupancy behavior 

and the number of occupants rather than adjusted 

volume, when you get right down to it. The more ice 

you use, the more ice that’s going to be made, 

especially for the manual ones. Probably automatic 

ones, too. 

Again, I don’t know how you do that in a test 

procedure. Just, maybe, typical number of occupants 

and amount of ice used per week or per month, maybe, 

somehow. I don’t think volume has as much to do with 

it as occupancy. 

MR. BROOKMAN: Thank you. Other comments on 

these four issues listed as 20? 

 (No response) 

MR. BROOKMAN: No additional comments? Okay. 

MR. WESTPHALEN: This next topic is product 

classes. First, going back to some of the discussion 

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that was had at the framework workshop, at that time 

new product classes were suggested: 19, for 

refrigerator–freezers with automatic defrost and 

bottom–mounted freezers with through–the–door ice 

service, and also Product Class 20, just freezers with 

automatic defrost. At this point, DOE proposes to 

redesignate those as Product Classes 5A and 10A, for 

consistency with Canadian standards. 

Convertible bottom–door refrigerator–freezers 

were discussed at the framework workshop. However, it 

is our understanding that the product that led to that 

discussion is no longer on the market. At this point, 

no proposed new product class is proposed. 

Wine coolers were discussed at the framework 

workshop, and DOE’s position is that these products are 

not refrigerators and hence there is no authority to 

regulate them. 

Built–in products were also discussed at the 

framework workshop and the associated comment period. 

DOE has conducted some preliminary analyses associated 

with built–ins, and we’ll be showing some of that 

information later. At this point, DOE has not made a 

firm decision on an approach with regard to built–ins. 

MR. BROOKMAN: Debra. 

MS. BRUNK: Debra Brunk with AHAM. I just 

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want to make a comment on that third bullet point, the 

wine coolers. AHAM continues to support DOE coverage 

of wine coolers in this rulemaking. We think this is 

important. We disagree that DOE does not have 

jurisdiction over wine coolers and that these are not 

federally covered products. 

DOE can make a finding that these products 

contribute to U.S. energy use and that energy could be 

saved by implementing a federal standard. We believe 

that wine coolers do contribute to U.S. energy use and 

there are opportunities for energy savings in these 

products. 

We also think it’s very important that this 

product has federal jurisdiction so we don’t end up in 

a situation where there are multiple state 

requirements. 

MR. BROOKMAN: Thank you. Yes. Amanda. 

MS. STEVENS: Hi. This is Amanda Stevens, 

Energy Solutions. I just wanted to follow on that PG&E 

supports DOE not covering wine coolers at this time. 

It’s currently covered by California efficiency 

standards, and now we’re looking, actually, at 

potentially amending that standard. We’d be very eager 

to work with AHAM to discuss potential standard levels, 

if they’re interested. 

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MR. BROOKMAN: Okay. Thank you. Steve 

Rosenstock. 

MR. ROSENSTOCK: Steve Rosenstock, EEI. In 

terms of the wine cooler issue, there are the 

residential versus commercial product classes for that. 

 Again, this is just, I’ll say, for the residential 

product class or commercial that DOE said no authority, 

or both, basically. We’re not going to touch it. 

There was a separate rulemaking for commercial 

refrigeration projects over the last few years, so just 

to clarify. Whether residential or commercial, DOE is 

saying, we don’t have the authority to regulate them, 

basically? 

MR. WESTPHALEN: This addresses residential. 

MR. ROSENSTOCK: Okay. Not commercial? 

MR. WESTPHALEN: Because this is a rulemaking 

on residential refrigeration products. 

MR. ROSENSTOCK: Okay, okay. Thank you. 

MR. BROOKMAN: Thanks for that clarification. 

 Other comments on these? I’m not quite sure you’re 

done with this slide. Maybe you are. 

Other comments on Slide 20? 

 (No response) 

MR. WESTPHALEN: Current developments on 

product classes. The key issue that came up during the 

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course of the preliminary analysis has to do with all 

refrigerators. As mentioned, these are refrigerators 

that have either no freezer compartment or a small 

freezer compartment, less than a half a cubic foot in 

size. 

When we discussed the compartment temperature 

changes, you’ll recall that compartment temperatures 

during testing for refrigerators and refrigerator–

freezers – when I use the term “refrigerators” without 

the “all,” what I mean there is what’s sometimes 

referred to as a basic refrigerator, a refrigerator 

that has a freezer compartment larger than half a cubic 

foot but that freezer compartment does not get down to 

temperatures such as eight Fahrenheit, which is the 

cutoff point for the refrigerator–freezer definition. 

Compartment temperatures for refrigerators 

and refrigerator–freezers will go down, so the energy 

use will go up, maybe in the range of 10 to 20 percent. 

 The compartment temperature for all refrigerators will 

go up, so energy use goes down maybe 2 or 3 percent. 

It’s clear that in order to have meaningful 

standards for all refrigerators, they would have to 

come out of those product classes where there are 

currently both types of products. 

Another issue that came up in the thought 

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process on establishing these alternative product 

classes was the question of manual defrost. You’ll see 

why this is important in the next slide. 

The definition for manual defrost from HRF-1- 

1979 is shown. This relates to all refrigerators that 

have no freezer compartment which typically can defrost 

with an off–cycle defrost requiring no manual 

intervention. Is that automatic or is that manual? 

Another of the current developments that is 

under consideration is the combination of some of the 

product classes that are not well represented and the 

combination of Product Class 12 with 11, 12 not being 

very well represented at this time. 

This table gives a list of the proposed new 

product classes. As mentioned, Product Class 1A, these 

are standard size products which, if they have a 

freezer compartment, most likely would not be less than 

half a cubic foot in size. One question is, do these 

products really exist, but these are the product 

classes that are proposed. There may be some 

recombination, as mentioned, with the 1 and 2 and the 

11 and 12. 

MR. BROOKMAN: So, comments on these product 

classes? 

MR. WESTPHALEN: The next slide keys in 

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particular questions associated with the product 

classes. First of all, asking again about the 

designation for Product Classes 5A and 10A, the 

establishment of separate product classes for all 

refrigerators, some possible product class 

combinations, and also the issue for all refrigerators 

associated with the manual defrost and whether there 

really should be a Product Class 1A. 

MR. BROOKMAN: Debra. 

MS. BRUNK: Debra Brunk with AHAM. AHAM 

supports DOE’s proposal to use the 5A and 10A 

designations, consistent with Canada. It’s important 

to continue to harmonize. 

Regarding Issue 2, AHAM supports the 

establishment of the separate product classes for all 

refrigerators. Again, with the test procedure changes, 

that makes the most sense. 

And Issue 3; AHAM supports the combination of 

Product Classes 1 and 2 and 11 and 12. Our analysis 

would suggest that that’s a reasonable thing to do. 

Finally, I believe it was Issue 15. AHAM 

agrees with DOE’s interpretation that off–cycle defrost 

is a form of automatic defrost for all refrigerators, 

and we are not aware of any of the all–refrigerator 

products on the market that use manual defrost. 

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MR. BROOKMAN: Thank you. Andrew. 

MR. DELASKI: We’ll review these points and 

respond to them in our written comments, but I want to 

make a general point about product classes, which is 

that I think DOE should be very cautious in general 

about creating additional product classes. 

The trouble that we start running into, and I 

think it’s one that we’re familiar with from many 

dockets, is we want technologies to compete in as broad 

a range as possible to get to the highest levels of 

efficiency that are justified. The more that we are 

creating product classes that are designed to allow for 

designs that are inefficient to persist, that runs 

counter to the intent of the statute. 

So, as you go forward in this docket, I think 

it’s important that we’re keeping an eye on the product 

class issue as an area where streamlining the product 

classes tends to result in general in greater savings 

in the long run, as we keep an eye on avoiding a 

proliferation of additional product classes. 

MR. BROOKMAN: Okay. Yes, please. Steve. 

Steve, say your name. 

MR. CHURCH: This is Steve Church. Just a 

quick note about that all–refrigerator being separated 

out as a product class. That is something that, if 

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you’re going to do the change to the test procedure, 

has to take place because, right now, a Type 3 is a 

top–mount, which will be changed to a 39 and zero, and 

an all–refrigerator is going to be changed from 38 to 

39. It would need to be separated out. That’s my only 

comment. 

MR. BROOKMAN: Thank you. Okay. Additional 

comments? Several questions here. 

Detlef, you have not really laid out Issue 

15, although Debra addressed it. Why don’t you do that 

now? 

MR. WESTPHALEN: Issue 15 here? This asks 

about the question of whether an off–cycle defrost, 

which would typically be used in an all–refrigerator 

without a freezer, whether that’s manual defrost or 

automatic defrost and, also, whether that then means 

that there would not be any standard size all–

refrigerators that would have manual defrost, thereby 

potentially eliminating the proposed Product Class 1A. 

MR. BROOKMAN: So, I want it to be in 

sequence with the comments as much as possible here, 

for the record. Additional comments on Issue 15? 

 (No response) 

MR. BROOKMAN: Okay. 

MR. WESTPHALEN: All right. Next topic is 

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technology assessment. We talked about this at the 

framework workshop and listed out all the technologies 

identified. 

These were identified for the products from a 

number of sources, both TSDs, literature view, product 

teardowns, and input from interested parties. The full 

list of technologies are identified and discussed in 

the TSD. We didn’t feel it was necessary to go through 

that again. 

The screening analysis then takes this list 

of technologies and screens out the technologies that 

are really inappropriate to be looking at as part of 

the engineering analysis. There is a list of four 

criteria that are used to do that screening: 

technology feasibility; practicability to manufacture, 

install, and service; adverse impacts on product 

utility; product availability or adverse impacts on 

health and safety. 

Again, Chapter 4 gets in–depth on discussions 

of reasons for screening out some of the technologies. 

 I’m not going to go into the details of that. 

However, here we’re presenting the technologies that 

were screened in as part of the screening process. 

Now, I have these presented as a matrix of 

the design options. They’re called design options once 

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they’ve been screened in. On the horizontal axis are 

the product classes that were analyzed in detail as 

part of the engineering analysis. This shows which of 

the technologies were considered for each of the 

product classes. 

There are two technologies or design options 

listed here that were not mentioned in the framework 

phase. Those are forced convection condenser. That 

one applies to upright freezers, which currently 

typically have hot wall condensers and have space for 

forced convection condensers. Also, variable anti–

sweat heater control, which is applicable to one of the 

product classes. 

MR. BROOKMAN: Steve. 

MR. CHURCH: Why would that variable anti–

sweat heater control only be limited to Type 5s? Why 

would it not also, for instance, to be able to be used 

on a Type 7 product? 

MR. WESTPHALEN: It would be possible to be 

used. The prototypical products that we looked at and 

examined that were Product Class 7 did not have a 

significant amount of anti–sweat heat control, so the 

energy savings – 

MR. CHURCH: There are still sweat heater 

controls around the dispenser area. 

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MR. WESTPHALEN: Correct. 

MR. CHURCH: On a large number of products. 

MR. WESTPHALEN: That’s something that we may 

want to consider. 

MR. BROOKMAN: In that one class, in 7, or 

many classes? 

MR. CHURCH: Well, I know it is in 7. I 

would guess it would also be applicable to 6 as well. 

I don’t know that. We don’t have one of those 

products. 

MR. BROOKMAN: Thank you. Amanda. 

MS. STEVENS: I was wondering; did DOE 

consider the use of LEDs in lighting? I think, if I’m 

not mistaken, the current test procedure, the door 

isn’t open, so potentially that’s why I was 

hypothesizing that it was not looked at. 

MR. WESTPHALEN: DOE did not consider LEDs. 

Even if you consider door openings and the time that 

the lights are on, the amount of time involved is 

really very small. LEDs are great in commercial 

refrigeration, where there’s a lot of on time. 

MS. STEVENS: What about the heat load from – 

I don’t know; is it a 40–watt lamp in there? I just 

wasn’t sure if that would add to the load for the 

compressor. I didn’t know if that would be very 

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significant. 

MR. WESTPHALEN: Well, I guess there are two 

aspects of this question. One is, is it a significant 

load. The feeling would be that, most likely, it 

wouldn’t be. The other aspect is that the engineering 

analysis is generally conducted on the basis of the 

test procedure, which, as you say, does have a closed 

door. 

MR. BROOKMAN: Yes, Chris. Chris, you need 

to turn your mic on. 

MR. JOHNSON: I’m sorry. Is the technology 

assessment based on only that which is available in the 

U.S. domestically, or did you look at products and 

technology globally that are not necessarily available 

in the U.S.? 

MR. WESTPHALEN: Well, if there are 

technologies that are available globally, one might ask 

the question why wouldn’t they be available in the U.S. 

 If they’re not available for U.S. products, then they 

wouldn’t be suitable for consideration. 

MR. BROOKMAN: Additional comments on these 

screened–in technologies before we proceed? 

 (No response) 

MR. WESTPHALEN: Some comments on the 

screening analysis from the framework phase. The key 

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comment here had to do with consideration of 

alternative foam–blowing agents and refrigerants in the 

analysis. DOE’s interpretation of this comment was 

that DOE should consider the potential climate change 

legislation or regulations that might lead to reduced 

availability of HFCs rather than these alternative 

agents or refrigerants being efficiency–improving 

technologies as compared with current practice. 

There are issues both with foam–blowing 

agents and with alternative refrigerants. That was 

something that Debra already mentioned. We’ve done 

some preliminary investigation of what would happen to 

our engineering analysis if, for instance, foam–blowing 

agents that were less effective had to be used. We 

have not yet seriously addressed alternative 

refrigerants. There are further details in the TSD on 

this. 

MR. BROOKMAN: Kelly. 

MS. KLINE: Kelly Kline from GE. Just to 

note here that, from our perspective, we really think 

that climate change legislation is one piece of it but 

there’s also the administration position on including 

HFCs in the Montreal Protocol or regulation by EPA. 

The point is, I think there are a number of 

different drivers which will be pushing the industry to 

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move into alternative refrigerants and foam–blowing 

agents over the coming years. GE, in particular, we 

have compiled a SNAP petition on R600 to have that 

approved for use as a refrigerant in the U.S. 

We just think that this is a critical point 

for DOE to be considering for the purposes of this 

rulemaking because we do think this is going to be an 

important trend over the next few years. We would just 

urge you to really give it full consideration because 

we think that the administration and EPA are really 

looking at ways to push for a decrease in HFC usage 

over time. We think that this rulemaking should be 

taking that into account. 

MR. BROOKMAN: Thank you. Steve Rosenstock. 

MR. ROSENSTOCK: Steve Rosenstock, EEI. Just 

under that third bullet where you discuss current UL 

standards, I’m assuming Isobutane is considered one of 

those hydrocarbons where it’s quantities under 50 

grams. Is that in any sort of a product that’s in the 

marketplace? Again, I’m sure it’s probably in the TSD, 

but if you could expand on that for clarification, that 

would help. 

MR. WESTPHALEN: Some of the manufacturers 

might have a better understanding of the UL 

regulations, but my understanding is that, for these 

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residential refrigeration products, 50 grams is the 

limit. That makes it very difficult, certainly, for a 

standard size refrigerator or refrigerator–freezer or 

freezer to meet all the design objectives. 

MR. ROSENSTOCK: Steve Rosenstock. It could 

not get the UL label if it used more than 50 grams in 

the refrigerator? 

MR. WESTPHALEN: Well, it’s a little bit more 

complicated than that. 

MR. BROOKMAN: I see we have some industry 

folks who wanted to comment. Debra. 

MS. BRUNK: Debra Brunk with AHAM. Just a 

couple of things around that. Yes, right now the 

current UL standard limits the hydrocarbon quantities 

to 50 grams. That is total. That suggests that you 

may not be able to use it as a refrigerant. It may be 

able to possibly be used as a blowing agent. 

Basically, what that means is, if you’re over 

that, you could not sell your products in the U.S. It 

could not meet the safety requirements. 

However, I would also mention, I think to 

Kelly’s point, as an additional thing that’s going on 

here, UL did just reopen their test procedure for 

refrigerator–freezers. I think they sent out a 

document last week where they are proposing a higher 

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level of R600a in their test procedure and are looking 

for comments on that. 

MR. BROOKMAN: Kelly. 

MS. KLINE: I would just add to that point. 

I do not think that we should look at the UL standard 

as preclusive of using R600 in the U.S. I think it 

makes it more difficult. I don’t think that’s an 

absolute bar. To Debra’s point, they are, I think, 

considering raising it currently. 

MR. BROOKMAN: Okay. Dick Topping. 

MR. TOPPING: I agree with Kelly. A further 

point: there’s obviously the efficiency issue. It 

also has a significant manufacturing impact in terms of 

the capital equipment or investment required to 

transition a plant in the U.S. into hydrocarbon 

refrigerants and blowing agents. That will have a big 

impact on the manufacturing impact analysis. 

MR. BROOKMAN: Thank you for those comments. 

 Additional comments? Yes. Please say your name for 

the record. 

MS. PANATHANASOPOULOS: Claudette 

Panathanasopoulos from Greenpeace Research Department. 

 I wanted to reiterate what Kelly said from GE. We 

feel that there are 400 million of these refrigerators 

that use hydrocarbons on the market worldwide. Almost 

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half of them produced worldwide use hydrocarbons. This 

is a direction that, clearly, industry is moving. 

There’s a lot of movement. UL, as was said, is 

reconsidering their standards. EPA is moving to give 

SNAP approval and has already signed at least one 

letter of intent to list a hydrocarbon blend as 

acceptable under SNAP rules. 

Clearly, it’s moving in this direction. We 

wanted to encourage DOE to reconsider this position to 

not include this and also to do a thorough analysis on 

the efficiency because, in our research, these 

hydrocarbon refrigerators are much more efficient. 

I think by not including it you almost run 

the risk of creating a standard that’s going to be 

outdated before it’s even implemented because these 

refrigerators are coming, and coming quickly. We’ve 

talked to many manufacturers on this. 

I also want to reiterate that HFC regulations 

are coming, not just in the U.S. but internationally. 

I think it’s important for companies to know that and 

to move ahead because it will be more complicated and 

more expensive to use HFCs in the future. 

MR. BROOKMAN: Thank you, thank you. 

Additional comments on this point? There are a series 

of points here. The Department would like to hear from 

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you if you have anything additional to say. 

 (No response) 

MR. BROOKMAN: Okay. 

MR. WESTPHALEN: That completes the market 

and technology assessment and screening analysis part 

of the discussion. I don’t know if we want to just 

keep on moving here or – 

MR. BROOKMAN: Yes. 

MR. WESTPHALEN: Okay. Good. The next part 

of the discussion is the engineering analysis. The 

purpose of the engineering analysis is to develop a 

relationship between manufacturing cost and efficiency 

of the product, the so–called cost–efficiency curves. 

These cost–efficiency curves are then used in all of 

the downstream analyses: the lifecycle cost, the 

national impacts, and the manufacturer impact analysis. 

This chart gives a flow map of how the 

engineering analysis was conducted, this part of this 

rulemaking, the preliminary analysis portion. At the 

bottom you see the cost–efficiency curves. That’s the 

endpoint. Coming into that, we have incremental costs 

associated with different design changes and 

differences in energy use associated with the different 

design changes. 

The cost estimate differences are determined 

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using manufacturing cost models. The approach used to 

develop the manufacturing cost models is as we have 

done in many other rulemakings. We’ll talk a little 

bit more about that. 

The energy models are based on an upgrade of 

the old EPA Refrigerator Analysis program, which was 

developed as part of this rulemaking. The upgrade was 

developed. Energy models were established for the 

baseline products and then for the different design 

configurations off those baselines. 

Input for these models are from a variety of 

sources: energy testing and reverse engineering of 

select, representative products, discussions with 

manufacturers, discussions with vendors, and 

investigation and other research that would provide 

pertinent information. 

At the top, we have select representative 

products. That’s the next topic of the discussion 

here. It’s all based on essentially what are these 

representative products that we did the detailed 

analysis for. 

This chart shows shipments of different 

product classes. DOE’s approach was to select 

initially the representative product classes. DOE 

chose seven product classes to focus on for this 

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analysis which represent more than 90 percent of 

overall shipments of the covered products. 

Within each representative product class, DOE 

selected three products for detailed analysis, and 

these three products represented two different sizes of 

refrigerator. For one of those sizes, DOE selected two 

models that were nearly identical except that one was 

an Energy Star and one was a baseline refrigerator. 

This table just shows the definition of those 

product classes for the product classes analyzed in 

detail and also how that breaks out into the four 

product categories that we talked about before. It 

also provides the refrigerated volume capacity of the 

products that were selected. 

During the framework workshop, we presented 

some of the products that we expected to consider as 

representative, and there were some comments, but 

overall the comments seemed to support our selection of 

the particular products. 

Now, having gone through the analysis, one 

question that arises, and obviously, with 18 product 

classes, seven studied in detail, one of the questions 

always arises of whether any variation in 

characteristics might be more significant than what the 

actual representative product is telling you. We’d 

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like to get some feedback from the stakeholders on this 

question. 

MR. BROOKMAN: I’m going to read this comment 

box. “DOE conducted detailed analysis on products 

considered typical for the representative product 

classes. This approach did not provide much 

information regarding variation in product design and 

the resulting variation in costs to achieve different 

efficiency levels. DOE requests comment on the 

variation of refrigeration product designs and 

distribution of incremental costs to achieve energy use 

reductions.” 

So, comments on that? Yes, Debra. 

MS. BRUNK: Debra Brunk from AHAM. Really, 

just a quick comment. We recognize that DOE had asked 

for information on this in the framework document. 

AHAM is unable to provide detailed design data for our 

manufacturers because it’s impossible to aggregate 

that. 

Our suggestion is that in the upcoming 

manufacturer interviews that DOE incorporate some 

questions to address these concerns and to try to 

understand this variation better. 

MR. BROOKMAN: Okay. I thought this was a 

complicated question. I thought it was. Can we get 

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additional comment on this? 

 (Laughter) 

MR. JOHNSON: You could do research on the 

Web, right? 

MR. BROOKMAN: What, Chris? 

MR. JOHNSON: I was just going to say, you 

could do research on the Web and find all the different 

designs. 

MR. BROOKMAN: Okay. So, nothing additional 

that we’re going to hear right now? Okay. 

MR. WESTPHALEN: The next topic is baseline 

efficiency levels. In most rulemakings in which there 

is an existing energy conservation standard, this is 

very straightforward. The baseline is simply the 

existing standard. However, because of the test 

procedure changes discussed previously, the actual 

numbers associated with those baselines will have to 

change. 

The baseline products are considered to be 

those that meet the current energy efficiency standards 

with no additional savings. DOE then developed 

numerical definitions of what these baselines would 

mean under the expected new test procedure. 

AHAM provided data showing changes in energy 

use and also adjusted volume for some of the key 

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product classes under the current and new test 

procedures to guide some of this analysis. DOE also 

did some energy modeling using the ERA energy model in 

order to gain some additional understanding of the 

energy use differences associated with the test 

procedure change. New equations were derived 

describing the baseline product energy use based on the 

expected new test procedures. 

Here are a lot of equations. You can go 

through the detail in the TSD. But essentially, the 

energy standards for refrigerators are a linear 

function of adjusted volume. We now have a new 

adjusted volume. We have two coefficients, A and B, 

and they need to be modified based on the 

characteristics of these products in terms of what is 

the new energy use under the new test procedure and 

what would the new volume calculation be. The last 

bullet there shows the adjustment based on these 

factors that describe changes in the energy and volume. 

I wonder if there are any questions about 

this? 

 (No response) 

MR. WESTPHALEN: The next slide illustrates 

this for Product Class 7. The AHAM data suggests a 14 

percent increase in energy use with the new compartment 

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temperatures and a 1.6 percent increase in adjusted 

volume. The current energy standard is 10.1 adjusted 

volume plus 406, and this then converts to 11.33, new 

adjusted volume, plus 462.8. These are then the 

baseline equations under the new test procedures. 

This didn’t play – 

MR. CHURCH: Excuse me. You’re saying that a 

Type 7 with the new adjusted volumes has more volume 

that the old? The way they do the dispenser area 

provides more volume? I’m just asking for 

clarification. Is that true? 

MR. WESTPHALEN: DOE did not do detailed 

volume calculations to come up with their own 

determination of the differences in the volume 

calculation. DOE received information on that point 

from AHAM. These are the results that we received from 

AHAM. 

MR. BROOKMAN: Steve, follow on here. What 

do you think the DOE should be doing with this volume 

calculation? 

MR. CHURCH: Well, I was just trying to 

understand the analysis. If you’re talking about the 

Type 7, they’re going to have less volume under the new 

procedure than they would under the old procedure 

because of the way they were calculating volume 

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concerning the dispenser area. You no longer get 

credit for that hump and you no longer get credit for 

the caved–out portion in the front, which is the 

dispenser. So, you have really significantly less 

volume with the Type 7. 

MR. BROOKMAN: Ron Lewis. 

MR. LEWIS: Since this was based on data from 

AHAM, I wonder if Debra could perhaps give us a little 

clarification or help us out. 

MS. BRUNK: Debra Brunk from AHAM. We’ll 

take a look at this data and try to understand better 

what may have happened here. 

MR. WESTPHALEN: From my part, I’d like to 

say we welcome more data. 

 (Laughter) 

MR. WESTPHALEN: The data that we received 

was good, but we’d like to see more. 

MR. BROOKMAN: Okay. Thank you. 

MR. WESTPHALEN: This slide basically prompts 

for comment on the approach used to develop the 

baselines. As I was about to say, this plays not so 

much into the engineering analysis so much as it does 

into setting the standard levels later on. 

MR. BROOKMAN: Christopher. 

MR. JOHNSON: Chris Johnson. I’m not an 

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engineer, but how do you develop a baseline energy 

standard without calculating ice–maker energy unless 

you’re doing it for products without ice–makers? Just 

a straight question. I don’t understand that. How 

does that work? 

If ice–maker energy is going to be included, 

how do you – and a test is going to be developed to 

calculate that ice–maker energy, how do you develop, 

before that process is completed, a baseline energy 

use, unless you’re specifically excluding ice–maker 

energy, for whatever reason, which I don’t know why you 

would do that. 

MR. WESTPHALEN: As I mentioned previously, 

these analyses do not consider the energy use for 

production of ice. 

MR. JOHNSON: But then the question is why? 

Why not? 

MR. WESTPHALEN: Because the test procedure 

currently does not have that and the process to develop 

that ice production energy use test is still in 

process. 

MR. JOHNSON: Right. So, that’s a problem, 

it would seem to me. If you’re developing a new energy 

efficiency standard, unless you’re specifically doing 

two separate standards, one for products with ice–maker 

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energy and one for products not counting ice–maker 

energy, then you would have to count it. You would 

have to develop a test to include it as part of the 

baseline energy use. 

MR. WESTPHALEN: Well, we’ll consider the 

comment. As I mentioned previously, the ice–making 

energy was not considered in the analyses and is not 

part of the existing test and is, at this point, not 

part of what is being considered to be proposed. 

MR. JOHNSON: I think that’s part of the 

timeline problem. 

MR. BROOKMAN: Okay. Thanks, Chris. 

MR. JOHNSON: Okay. 

MR. BROOKMAN: Yes, Debra. 

MS. BRUNK: Debra Brunk from AHAM regarding 

Issue 4. I just want to say that AHAM supports DOE’s 

approach for modifying the baseline energy use and the 

adjusted volume relationship under the proposed test 

procedure. We feel like this is a well summarized and 

sufficiently rigorous approach. Thank you. 

MR. BROOKMAN: Additional comments on Issue 4 

as listed here on Slide 38? Yes, please. 

MR. HALL: Yes. David Hall. Throughout the 

executive summary and the Technical Support Document, 

there are some charts as it goes through, and it 

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references baseline energy. I just want to confirm or 

ask, when it’s comparing and referencing baseline, is 

that for current or for the new with these adjustments? 

MR. WESTPHALEN: Well, I would hope that 

would have been clear where it was referenced. There’s 

a part of the engineering analysis chapter which 

discusses this development of the baseline energy use. 

 From that point forward, it could be interpreted, if 

not defined, to be according to these new equations. 

The understanding is that this would be the energy use 

associated with these prototypical products under this 

test procedure. 

MR. LEWIS: Ron Lewis, DOE. I’ll suggest 

that if you want to see an example of how that’s laid 

out in the TSD, perhaps when we’re taking a break, one 

of the team members may have a copy on their computer 

and we could walk you through that and point to where 

those distinctions are made or the pointers that may 

not have been as evident as we had thought they were. 

MR. HALL: When I’m reading through it, I’m 

thinking that it references current, but I wanted to 

confirm that because, as a result of the – there is one 

chart that actually has current versus new baseline 

where it includes these adjustments as noted on Page 

37, for example. But I didn’t want to make a false 

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assumption that these increments, as it’s showing for 

quads and net present value and LCC, LLC, that it – I’m 

just wanting to be certain that what I’m seeing is that 

it is really referencing what I’m thinking it’s 

referencing as the current baseline. That’s all. 

MR. LEWIS: We don’t want you making any 

false assumptions, either. As I say, we would be glad 

to call up a copy of the document and take a look at 

the specifics and try to clarify. 

MR. BROOKMAN: We’re going to take a break in 

about 10 or 15 minutes. Do you want to comment? Then 

I’ll go to you next, Dick. 

MR. HOPKINS: Asa Hopkins, LBL. We’ll go 

through a lot of this in more detail in the coming 

sections on energy use and it’ll be a little more clear 

there. That may help as well, but we can also talk 

with you on the break. 

MR. BROOKMAN: Who back here has got the TSD 

on your hard drive? Has anybody got a copy with them? 

 Yes, you do? Okay. This gentleman. Dick? 

MR. TOPPING: Unfortunately, it’s not clear 

at all. In fact, a bunch of us were looking at it 

yesterday trying to figure it out. Particularly, just 

so we’re on the same page, on all the cost–efficiency 

curves that you have shown by product class, are those 

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based on improvements over the current baseline levels? 

We were assuming that these were improvements 

over the current baseline levels and then, ultimately, 

you would then correct that up to accommodate the new 

test procedure. Is that not true? 

MR. WESTPHALEN: That’s not true. Well, it 

is true and it’s not true. 

 (Laughter) 

MR. TOPPING: That’s why it’s not clear. 

MR. BROOKMAN: It’s about as clear as mud. 

Go ahead, Detlef. 

MR. WESTPHALEN: The assumption made, and we 

haven’t been given enough data to refute this, that a 

product that is a 20 percent product under the old test 

procedure, would be a 20 percent product, on average, 

under the new test procedure. If we say 10 percent, if 

we say 20 percent, the assumption is that, under the 

current test procedure, that would be 25 percent; under 

the new test procedure, that would be 25 percent. 

We ask for data to try to discern is that 

really so or is it not. 

MR. TOPPING: Okay. That’s okay until you 

start talking about specific levels in terms of 

kilowatt–hours a year because, as you know, there’s a 

significant difference in the kilowatt–hours a year of 

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the baseline product with the existing test procedure 

versus the old test procedure. 

I’m afraid there’s a little bit of apples and 

oranges here in terms of whether we’re talking about 

thermodynamic improvement levels or changes in 

kilowatt–hours a year from now to then. It’s a 

significant issue that we just need to be on the same 

page. 

MR. WESTPHALEN: We had this discussion at 

the framework workshop. We welcome information that 

would perhaps shed light on the issue. 

MR. TOPPING: I think you’re asking a 

different question. I think you’re asking would a 

design option suite that gives you 20 percent 

improvement in efficiency under the current test 

procedure also provide you 20 percent efficiency 

increase under the new test procedure. I think that’s 

what you’re asking. 

That’s not what we’re talking about. We’re 

looking – I guess it comes down to the fact that we’re 

to the point now of looking at improvements in terms of 

efficiency improvements over baseline. For example, 

Energy Star today. Energy Star is 20 percent 

improvement over current baseline. If you were to test 

that same unit that is Energy Star today under the new 

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test procedure, the kilowatt–hours a year would only be 

about 5 percent improvement over the current baseline 

because of the change in the test procedure. 

MR. WESTPHALEN: However, if you tested a 

baseline product – 

MR. TOPPING: That’s right. 

MR. WESTPHALEN: – and compared that with the 

Energy Star under the new test procedure – 

MR. TOPPING: I understand that. 

MR. WESTPHALEN: – would that be a 20 

percent? What would it be? 

MR. TOPPING: I understand that. I hear 

where you’re coming from. I think we need to make sure 

we’re all on the same page as we go through and provide 

comments to you. 

MR. BROOKMAN: Dick, I don’t want to put you 

on the spot. Will you restate where you’re coming from 

here? 

MR. TOPPING: Point of clarification. We are 

interested in knowing precisely at what levels are we 

talking improvement under what test procedure. 

MR. BROOKMAN: Yes? You don’t need to 

respond. 

MR. TOPPING: No. I wouldn’t expect you to. 

MR. WESTPHALEN: I don’t fully understand the 

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question, but perhaps – 

MR. BROOKMAN: Maybe at the break you could 

talk that over as well. We’ll be going there before 

too long. Let’s proceed, Detlef. 

MR. WESTPHALEN: Another thing that was 

investigated as we looked at these baseline energy use 

curves was the slope of the curve. This data here is 

for the current standard under the current test 

procedure, but the same relationships and issues appear 

if you convert it to the new test procedure. You see 

that some of the product classes have a dramatically 

lower slope. 

We conducted some analysis using the energy 

model, and some of these questions were confirmed by 

the energy modeling as well. 

We’d like to raise this issue and try to get 

some more input on the topic in regard to some of these 

product classes for which the current slope of the 

maximum energy use curve might be lower than would 

really be representative for the type of product. 

MR. BROOKMAN: I’m going to read this one 

into the record as well. “DOE invites comment on 

whether an adjustment to the slopes of the baseline 

energy use relationships based on the proposed test 

procedures is warranted for any of the product classes 

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and by how much. DOE requests information and 

supporting comments that indicate the need for such 

slope changes.” Debra. 

MS. BRUNK: Debra Brunk with AHAM. A couple 

of points here. First of all, I’d say, in general, 

AHAM supports DOE’s efforts to ensure that the slopes 

are consistent and realistic for each product class. 

We also recognize there are new technologies out there, 

so slopes may change over time. 

I think, first of all, we want to just 

pinpoint Product Class 5 in particular. Our historical 

information does show that, back in 1993, Product Class 

5 had a slope of 16 and a half. Somehow, in 2001, that 

slope became 4.6. So, there’s always been some 

question there, and there is historical precedent that 

that slope for Product Class 5 was quite a bit higher. 

The second point I guess I’d like to make is 

DOE does show modeling data from ERA. I’m just 

wondering if there is any way that that data can 

somehow be validated somewhat with either units that 

are on the market or if there’s something there so we 

could understand a little bit better that those slopes 

are realistic. 

Second, DOE proposes a change to the slope 

for a number of product classes. The question is does 

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the intercept remain the same or is it also changing? 

That is not clear from the Technical Support Document. 

MR. WESTPHALEN: That has not been decided. 

There hasn’t been a whole lot of thought put into that, 

either. We’re kind of asking for feedback. That’s 

something that does need to be established. 

MS. BRUNK: I had one more comment, which is 

how did DOE select the product classes for slope 

evaluation? You show eight, I believe, in the TSD. We 

noticed that Product Class 17 was not on there. There 

are some concerns there that that slope, which is for a 

compact freezer class, currently has minimum energy 

requirements that are very similar to a refrigerator–

freezer. That seems to not make a lot of sense, 

either. 

Then, there’s a question also on all of the 

additional product classes that we added, the 3As, the 

5As, the 10As, and the 11A. We’re just wondering if 

the slopes would be considered to be consistent with 

the proposed slope changes or how that might be 

addressed. 

MR. BROOKMAN: Do you want to try and address 

some of those? 

MR. WESTPHALEN: At this point, that looks to 

me like a comment that needs to be considered to 

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determine what will be done moving forward. Clearly, 

there are a lot of things to consider, as you say. 

MR. BROOKMAN: Since Debra raised this host 

of issues, let’s see if there’s any other comment from 

manufacturers, Steve, and then we’ll – any other 

comments about that range of – okay. Steve Rosenstock. 

MR. ROSENSTOCK: Steve Rosenstock, EEI. 

Looking at the table on the preceding slide, you’re 

showing calculated energy curve slopes, and then, 11A, 

you show a range, and it’s quite – it’s a significant 

range. It’s not plus or minus 10 percent, it’s almost 

a doubling and an order of magnitude. Is there 

something unique about that product class? 

You show just single values for all the other 

product classes, but then for 11A you show this range 

of 20 to 35. When you compare it to the baseline, it’s 

an order of magnitude. That just kind of came out at 

me as like what’s going on? Is there a range for other 

classes that are in the TSD and these are the midpoint 

values? Again, it just struck me just because, again, 

the order of magnitude difference. 

MR. WESTPHALEN: For Product Class 11, that’s 

probably the product class with the widest range of 

adjusted volume. It may be that for that product class 

a linear relationship is not quite appropriate. Not 

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that we’re signing up to do a curve at this point, but 

I think that’s what technically is happening there. 

MR. BROOKMAN: I refer you again to Issue 

Number 5, Slide 41. Any additional comments on this 

issue box? 

 (No response) 

MR. BROOKMAN: Okay. 

MR. WESTPHALEN: Next topic, incremental 

efficiency levels. I guess this speaks to some of the 

discussion already put forth. 

The incremental efficiency levels were 

defined by percentage energy use less than the 

baseline, whether that baseline is defined under the 

old test procedure or the new test procedure. The 

interpretation is that a 25 percent product would be a 

25 percent product under either test procedure. We 

don’t have enough data to determine otherwise at this 

point. 

Looking at max available and max tech, max 

available efficiency levels were identified by looking 

at some of the databases that list product 

characteristics. They range from 1 percent below the 

standard for 13, to 51 percent below for Product Class 

2, which doesn’t include a Product Class 3 allrefrigerator, which was at 53 percent. 

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The max tech levels were determined using the 

energy modeling. This is a point that was discussed 

also at the framework meeting. In some cases, or in a 

lot of cases, the max tech wouldn’t necessarily be 

something that was available because the costs of 

achieving the max tech would likely be very high and 

would not be typically considered a marketable product 

in the current market. 

DOE conducted engineering analyses for the 

efficiency level up to 45 percent. Initially, the 

discussion was up to 35 percent. Some of this analysis 

suggested that raising that level would be appropriate 

in order to fully examine the potential ranges. It was 

felt that higher than 45 percent would not be cost 

effective. 

MR. TOPPING: Question. 

MR. BROOKMAN: Yes, Dick. 

MR. TOPPING: What’s the level of maturity 

assumed for the design options that go into max tech? 

MR. WESTPHALEN: Well, those are design 

options that pass through the screening analysis and 

hence would be considered appropriate for the 

engineering analysis. 

MR. TOPPING: So, for example, if a variable–

speed compressor is not available in a size range for 

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one of these product classes of interest, would it 

still be included? A commercially available. 

MR. WESTPHALEN: There’s a possibility that 

it wouldn’t. In our analysis, it wasn’t clear to us 

that we’d run into that issue. 

MR. TOPPING: I guess what I mean is, are all 

these components expected to be available on the open 

market? 

MR. WESTPHALEN: That’s part of the criteria 

for the screening analysis, yes. 

MR. BROOKMAN: Debra. 

MS. BRUNK: Debra Brunk from AHAM. I just 

have a question. In these simulations, was DOE able to 

address the cabinet size limitations that might be 

affected by combining a number of these design options? 

MR. WESTPHALEN: Can you point to specific 

groups of design options that might have an issue 

there? 

MR. TOPPING: Heat exchangers. Larger heat 

exchangers. 

MR. WESTPHALEN: For the larger heat 

exchangers, the analysis did not go into the specifics 

of each product and what are the details of the product 

changes that would be required. In many of these 

cases, there is ample space. That was the initial 

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observation. We didn’t go into a detailed engineering 

analysis. There may be some questions there, and we’d 

welcome additional data that might shed light on that. 

MR. BROOKMAN: Kelly. 

MS. KLINE: We can provide some more 

specifics in our written comments, but that was our 

concern as we looked at this, that not all of these 

technologies would really be additive or could 

necessarily be additive to reach the levels that you 

modeled here. 

MR. WESTPHALEN: Now, when you say 

“additive,” what exactly do you mean? Do you mean 

adding the savings? 

MS. KLINE: Based primarily on cabinet size, 

things like that, that you may not be able to just 

physically accomplish. 

MR. WESTPHALEN: That you couldn’t combine 

all of those product classes regardless of what the 

energy use would be. 

MS. KLINE: That’s right. 

MR. WESTPHALEN: Okay. 

MR. HALL: David Hall here. For example, 

Product Class 11. It’s showing a percentage there, and 

then there are five checkmarks. That’s a compact 

product. 

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MR. WESTPHALEN: Correct. 

MR. HALL: So, getting back to a comment 

raised originally, if under the variable–speed 

compressor column and in that cell it is not 

technically available currently, is this assuming that, 

since it is available in some other categories, like 

particularly 7 or 5A, that it would be available by the 

time of rulemaking for 11? 

MR. WESTPHALEN: Well, we conducted the 

analyses for all the products using data for 

compressors that are commercially available. The 

results we get for Product Class 11 are based on 

existing compressors that are commercially available 

now. 

MR. CHURCH: This is Steve Church. When he 

says size, I think he’s referring to the BTUs of the 

compressor. Did you check and make sure that you had 

the small BTU compressor available for a compact? 

MR. WESTPHALEN: For the smallest compact, 

the approach was to use a variable–speed compressor 

that you probably wouldn’t use at full speed, you’d use 

at low speed. 

MR. BROOKMAN: Go ahead, Dave. 

MR. HALL: That would reflect some knowledge 

of a capacity at EER for that component in order to 

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render a simulation. We’re just questioning the 

validity of that cell for that category, recognizing 

that it would be demonstrated at a lower energy 

consumption level at the lower RPM, as you’re 

mentioning. We’re not questioning that. But since it 

is significantly different in level than all the other 

classes listed, and that’s a specific cell of interest 

that is of question to us, as a result of that lack of 

information, for example. 

MR. BROOKMAN: Okay. Thanks. Additional 

comments on this slide referring to the engineering 

analysis max available and max tech and these design 

options listed? 

MR. HALL: I have one more question. The ERA 

used, has it been – it was already asked. I’m going to 

kind of repeat it. Has it been confirmed by other 

simulation or by products or by some kind of screening 

itself to confirm its accuracy? Because within each of 

these energy levels demonstrated, there’s an accuracy 

of sort, since it’s a simulation. There’s no rendering 

in this for what this accuracy and how it’s established 

since this is purely an energy consumption technical 

matter. Can that be made available? 

MR. WESTPHALEN: Well, the program is 

intended to be made available. I don’t know the status 

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of that at this point. 

MR. ADIN: With respect to making the ERA 

program available, that is something that we’re 

definitely considering. I can’t tell you where exactly 

we are. Basically, we just want to put it together in 

a way that will be usable by all interested parties. 

We’re working on figuring out the best way to do that 

right now, so I can’t tell you when that will happen. 

MR. BROOKMAN: Thanks, Lucas. Kelly? 

MS. KLINE: Yeah, just one more question or 

observation. I’m wondering here; what seems to be 

missing is a description or an analysis of what is the 

max tech actually available on the market versus the 

more theoretical, what could be max available. I’m 

wondering about that. I’m wondering why there’s not 

specifically a focus on what’s the maximum available on 

the market and if there could be some modifications 

here to really focus on what is clearly already 

available. Just an observation. 

MR. BROOKMAN: Thank you. So, a host of 

issues here. Final comments on this slide? 

 (No response) 

MR. BROOKMAN: I’m going to suggest we take a 

break at this point. It’s 10:45. Let’s resume at 

11:00. Walking around in the Forrestal Building, you 

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need to have your visitor’s pass badge visible. 

 (Brief recess) 

MR. BROOKMAN: We’ve covered a lot of ground 

already, and we’re going to resume. We’re on Slide 44. 

MR. WESTPHALEN: Okay. The next part of this 

engineering analysis chart that we’re looking at is the 

energy model. As mentioned, the EPA Refrigerator 

Analysis program was upgraded as part of the rulemaking 

effort. There were updated algorithms put in for heat 

exchanger modeling based on some of the work that has 

gone on since the ‘90s, upgraded to a Windows platform, 

internal iteration of heat exchanger performance. 

For anybody that’s familiar with the old 

program, the heat exchanger performance iteration was a 

nasty part of running it. We actually did that 

throughout most of the work because the Windows version 

wasn’t ready until later. 

As I mentioned before, the intent was that 

this would be available to all stakeholders to be able 

to check our results. We already talked about that, 

that we’re working on that. 

The flow and the modeling process. 

Information, as mentioned previously, was provided from 

reverse engineering, discussions with manufacturers, 

discussions with component vendors, and then also 

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laboratory energy tests on most of the representative 

products that were subsequently torn down as part of 

the reverse engineering. 

The first step in the modeling was to model 

the current products as is under current test 

procedures and calibrate in order to match those 

numbers. Then, make a model based on the new test 

procedure looking at potentially design changes in 

order to develop a model of a baseline product. 

The reason I mention that is, for instance, 

Product Class 5. We were not able to find any 

representative products that were baseline, so we had 

to model backwards in order to get a baseline and 

define that as our baseline model. 

The third step is to look at individual 

design options applied to the baseline models. Again, 

this is based on the new energy test procedure. And, 

determine which of those design options are the most 

cost effective. 

Then, finally, energy modeling of groups of 

design options to define the energy savings associated 

with each of those. 

Some adjustments were made, and these are 

described in detail in the TSD. I mentioned Product 

Class 5. We had to go backwards to less efficient 

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components in order to model what we felt was the 

baseline. 

Also, because of some of the products that we 

actually used as the basis for these models, we made 

some adjustments. One thing that was discussed at the 

framework workshop was that a product with French doors 

would be more representative than a single fresh–food 

door, and this is for Product Class 5. We’re not 

talking about Product Class 5A here. 

Some of the information obtained during the 

manufacturer interviews suggested that shipments for 

French doors, even for Product Class 5, are higher than 

single–door and hence we did base the analysis on 

French door design. 

So, the product that we initially purchased 

for examination did not have French doors, and we had 

to adjust the model for that design appropriately in 

order to have an appropriate baseline. 

A similar thing happened with Product Class 

7, where the product that was obtained did not have the 

through–the–door feature, and we had to add that 

additional energy use into the model. 

Some supplemental spreadsheet calculations 

were made. Some of these things are associated with 

features that the ERA model did not have, in particular 

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air side thermal resistance for spine fin evaporators, 

since some of the products that we looked at had spine 

fin evaporators. Thermal resistance of composite 

vacuum panel foam walls. 

I’m not going to dwell too much on the third 

bullet. Some adjustment we needed to make because of 

other issues with the way ERA was configured for input 

and output. 

We also did spreadsheet summary calculations 

combining the outputs from the energy model and the 

outputs from the manufacturing cost model in order to 

develop, initially, cost efficiency curves based on 

design options. We resolved those into cost–efficiency 

curves based on efficiency levels so that it’s easier 

to have more consistent comparison between different 

information sources and across product classes. 

The next topic is manufacturing cost models. 

 The process we used to determine incremental 

manufacturing costs has been well documented in many 

other rulemakings. It’s well documented in the TSD. 

It involves purchasing representative products; 

developing a detailed bill of materials; identifying 

the processes used to fabricate the fabricated 

materials; for the purchased parts, estimating the 

price based on discussions with the manufacturers and 

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also with the component vendors; and then to develop 

manufacturer production costs. 

The incremental cost estimates were then 

developed from the manufacturing cost models by 

adjusting the manufacturing cost models appropriately 

for the different design options and looking at the 

results. Typically, when looking at more efficient 

components, for instance the move to a higher 

efficiency compressor, the key cost increment there is 

associated with the higher price for the component. 

Some of the design options’ impact on overhead and 

depreciation was added in. 

Typical markup for overhead and depreciation 

was developed based on the manufacturing cost models. 

In some cases, this was applied to represent additional 

costs associated with implementing that particular 

design. 

The depreciation costs for insulation 

thickness increase. Based in part on discussions with 

manufacturers, DOE determined that the impact on the 

manufacturing plant would be significant enough when 

implementing an insulation thickness increase that for 

many months you really couldn’t be in production and so 

you really would have to set up a new plant or else go 

out of business temporarily. We included depreciation 

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costs for insulation thickness increase based on 

setting up a new plant. Again, those depreciation 

costs were calculated using the manufacturing cost 

model. 

In the results presented for the engineering 

analysis, we did include the manufacturer markup, 

including G&A and profit. We converted the 

manufacturing and production costs to manufacturer 

selling prices. In some cases, where we do some 

comparisons, we take that markup out in order to get 

apples–to–apples comparisons, but that should be clear 

in the TSD. Again, let me know if it wasn’t. 

Then, with all this input, we developed the 

cost efficiency curves. This slide essentially goes 

through the blow–by–blow again of most of the 

information that I’ve already related. The baseline 

energy use is based on proposed energy test procedures 

and the design options added from the baseline to the 

max tech as a pathway for improving energy efficiency. 

 The costs for those design options were determined 

from the manufacturing cost model, which had various 

inputs. The cost effectiveness of those design options 

could be determined. 

Then, a design path representing successively 

increasing efficiency and successively increasing costs 

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was developed based on design options, and that was 

converted to curves based on efficiency level. 

This illustrates some of that information for 

top–mount refrigerator–freezers, Product Class 3. As 

mentioned, we looked at two different sizes for each 

product class. The curves for the different sizes are 

shown in the red and blue. The design option points 

are shown with the purple dots, and you can see that 

that’s for the blue curve. Those purple dots were then 

resolved to the appropriate curve based on the actual 

efficiency levels in increments of 5 percent. 

In some cases, determining the cost to get to 

the next higher efficiency level required adding the 

full cost of the next design option. For instance, if 

you’re going to switch from a shaded–pole fan to a 

brushless DC fan, you can’t put in half of that. You 

have to put in the whole thing. In some cases, like in 

an insulation thickness increase, if you’ve already 

accounted for the capital costs associated with adding 

more, you could add half or a full inch or whatever. 

You could look at different gradations of that and 

interpolate between them. That was the approach used. 

Initially, the plan was to resolve variation 

associated with product volume by looking at the 

different sizes of product. It became clear when we 

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looked at the details of the designs that the 

differences in these cost–efficiency curves have much 

more to do with the specific design choices made than 

with their sizes. Instead of developing a variation 

associated with product size, we decided it would be 

more appropriate to average the two curves to develop 

the curve that would then be passed on to the 

downstream analyses. 

The next few slides – 

MR. BROOKMAN: Please, Marty. 

MR. SEVERANCE: Martin Severance, General 

Electric. I was curious, on the labeling of 7, 8, 9, 

and 10, if those are correct. Looking at the 

efficiency changes from each of those factors, if 

they’re labeled correctly or not. In other words, I’m 

questioning the percent gain of adding vacuum panels to 

the freezer versus the fresh food. Also, 9 and 10 I 

think are labeled the same. 

MR. WESTPHALEN: You’re right; they are 

labeled the same. I don’t recall at this point which 

is which. Appendix 5A gives the details of all of this 

for all of the products analyzed. 

At this point, I would probably venture to 

say that the labeling of 7 and 8 is correct. 

MR. SEVERANCE: I guess that’s where I was 

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having a difficulty understanding how adding vacuum 

panels to a fresh food was going to provide more energy 

improvement than adding vacuum panels to the freezer. 

Because adding vacuum panels to the fresh food is also 

going to have an effect on evaporator temperature, 

which is going to have a negative impact on energy. 

MR. WESTPHALEN: Well, as I said, the data is 

in Appendix 5A. We welcome any comment based on the 

details of what’s in there. Hopefully, we can resolve 

the issues with the ERA model so that you can take a 

look and see what exactly was misrepresented. 

MR. BROOKMAN: The logic is useful. 

Additional comments on this series of slides? 

 (No response) 

MR. WESTPHALEN: The next series of slides 

basically show the results of the curves for each of 

the two products for each of the product classes and 

the average. I’m not going to dwell on these in 

particular. If you have any particular questions, feel 

free to ask. 

This is Product Class 5. Product Class 7. 

For Product Class 7, you notice one of the product 

classes, we didn’t feel that it would get past 40 

percent efficiency level. Product Class 9, the upright 

freezers. Product Class 10, chest freezers. 

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Some of these sawtooth shapes in the curves 

are associated with – this is looking at the freezers – 

adding a large impact in cost associated with capital 

cost, initially at 20 percent for that one product in 

order to increase the wall thickness. Then, higher up, 

making the cost impact of a variable–speed compressor, 

which would then get you past two efficiency levels so 

that the cost didn’t increase from 35 to 40. Those are 

the types of things that affect the sawtooth shape 

there. 

Product Class 11, and then Product Class 18, 

compact chest freezers. 

Any other comments or questions on these 

curves? 

 (No response) 

MR. WESTPHALEN: The detailed analysis is 

really what – as we explain the process, there’s a lot 

of information and analysis that goes into developing 

these. Obviously, we’d have to really pull it apart. 

We don’t have time for that right now, but certainly I 

encourage everybody to look at the detail in the TSD 

and look at some of the modeling. If there are 

particular issues, certainly we’d be open to listening 

to any of that. 

Next thing to talk about is comparison with 

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the AHAM data. As is usually done for a rulemaking 

process, some of the data is collected by a trade 

organization, in this case AHAM, and aggregated and 

presented to DOE. This was done for Product Classes 3, 

5, 7, 9, and 11. 

In order to make comparisons with the AHAM 

data, the AHAM data was based on the MPC, manufacturing 

product cost, rather than the selling price. We 

removed the manufacturer markup from our curves to make 

the comparison. The AHAM curves did include material, 

labor, overhead, depreciation, and one–time expenses to 

get what should be considered a true manufacturing 

production cost. 

This fourth bullet, I guess, is a little bit 

subjective: reasonable agreement between the AHAM and 

DOE curves, with a few caveats. Additional details, 

obviously, are in the TSD. 

The first curve here shows Product Class 3. 

I don’t know if we should get in this forum into the 

details of how the AHAM sampling and aggregation 

process worked, but what you see here to some extent is 

impacted by the way that process worked. 

The min/max curve for this product class, it 

doesn’t make sense that that’s lower than the average, 

but that has to do with the way that process worked. 

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However, it does indicate that for at least some of 

these responses, that which is represented, our feeling 

is that curve is very close to the results DOE 

obtained. 

Product Class 5. Agreement except at 25 and 

30 percent. 

MR. BROOKMAN: Do you have a question or 

comment? Yes, Debra. 

MS. BRUNK: Debra Brunk from AHAM. I just 

wanted to follow up on Detlef’s comments just regarding 

the aggregation. We do what we can in terms of pulling 

data from our members, and we have several requirements 

that we can maintain our manufacturers’ 

confidentiality, particularly when it gets into this 

kind of cost information. We can only report 

aggregated data if we have information from three 

manufacturers or more. 

In this kind of an exercise, what we may end 

up with is a certain number of manufacturers reporting 

for a certain number of, say, efficiency levels and 

then maybe manufacturers dropping out as you get to 

higher levels and not providing data. We also don’t 

get 100 percent response when it gets to the max/min 

information, which is why that often looks a little bit 

strange. I felt, when I put that together, it would be 

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better to provide as much information as we had to DOE 

as opposed to making assumptions. 

I wanted to make that point. I think the 

other point I would like to make here is, as we further 

reviewed these curves, we have some concerns. I’ve 

heard some concerns from members that they may not have 

actually used the correct baseline for calculating 

cost. We need to go back and look at that. We may try 

to do a little bit better job in terms of this max/min 

evaluation. 

MR. BROOKMAN: Thank you. Andrew. 

MR. DELASKI: If I could just follow up 

Debra. When we’re looking at this curve, for example, 

for Product Class 3, are you saying that it may be that 

for the max/min data we may have a different set of 

manufacturers who provided data to that input than data 

for what they call DOE average here? 

MS. BRUNK: This is Debra Brunk from AHAM. 

That’s correct. Basically, your subset of 

manufacturers’ reporting is different for the two. 

MR. DELASKI: So, we may have 10 

manufacturers gave data here but only five gave you 

data for that. 

MS. BRUNK: You’re essentially comparing 

apples and oranges right here. 

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MR. DELASKI: Then the other question I have 

is, how do you weight it? How do you weight the 

manufacturer data? 

MS. BRUNK: All weighting is done by 

shipments. It’s percentage of market share. 

MR. DELASKI: In this particular market, 

where one manufacturer has enormous market share – if a 

manufacturer has 70 percent market share, they’re 70 

percent of what’s going on here. If they have 2 

percent market share, they’re 2 percent of what’s going 

on here. 

MS. BRUNK: That’s correct. 

MR. BROOKMAN: Okay. Andrew? 

MR. DELASKI: Thanks. 

MR. WESTPHALEN: Moving on to the comparison 

for Product Class 5, there is discrepancy at 25 percent 

and 30 percent levels. Elsewhere it’s reasonable. 

Product Class 7. The DOE estimate is 

actually higher than the AHAM estimates. There may be 

some questions here about number of manufacturers 

responding above 25 percent because of the way that one 

curve flattens out. It doesn’t really look all that 

believable. 

Product Class 9. Some of the efficiency 

levels agreement is reasonable. For others, 20 percent 

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is discrepancy. 

Product Class 11. There’s significant 

difference, and without understanding better what went 

into the AHAM data, it’s hard to say what the 

differences are. 

MR. BROOKMAN: Debra. 

MS. BRUNK: Debra Brunk with AHAM. I just 

have one clarification question here. We’re going 

through this evaluation. In some areas, there’s 

agreement; in others, there’s not. I guess I’m just 

wondering, in terms of moving forward with the 

analysis, is the Department looking at going with the 

curves as simulated or are they looking at trying to 

get more information in terms of the true manufacturer 

incremental cost? How would DOE expect to move forward 

on this? 

MR. WESTPHALEN: Well, the information that 

was fed to the downstream analyses was the DOE 

analysis. You did go through the exercise, and 

certainly we don’t want to just push aside those 

numbers and say they’re meaningless, but we do have 

problems understanding what the differences are. 

Without more information, it’s hard to know where to go 

with it. 

You suggested maybe additional questioning 

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during the MIA visits, and that’s certainly something 

that we’ll follow up on. 

One thing that we felt was important to 

address in this public meeting and the comment period 

is the impact of vacuum insulation panels. The 

efficiency levels attainable using vacuum insulation 

panels are significantly beyond current Energy Star 

levels, but there is, according to our analysis, 

significant cost involved. 

The LCC analysis, which Greg and Asa will get 

into, shows that some portion of this high cost could 

be justified by the cost savings. Thus, new standard 

levels could require significant use of VIPs, much more 

so than has been done to date. 

As we mentioned before, vacuum panels were 

not screened out. They were not screened out in ’97. 

The analyses for ’97, obviously, were done before that. 

 Maybe that’s 13 years ago. However, we felt that we 

should raise this issue as something for which we 

request comment and request additional information on. 

MR. BROOKMAN: Yes, Debra. 

MS. BRUNK: Debra Brunk with AHAM. I think 

we would like to note that DOE relies pretty heavily on 

VIPs in their analysis. If we go back to the cost 

versus efficiency chart for Product Class 3 with the 

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purple dots, there are four data points there that rely 

on VIPs. 

AHAM strongly cautions DOE that the 

availability of vacuum insulation panels would be an 

issue, certainly, for the near future if that is a 

technology that is required to meet the new efficiency 

levels. In addition to DOE’s interest in this, the new 

standards in Europe and India, which are quite 

stringent, will likely put pressure on the vacuum 

insulation panel market, also. It would not just be an 

increased U.S. demand but also worldwide demand for 

these products. 

I think AHAM also wants to note that the cost 

curves developed by DOE do not take scarcity of supply 

into account. We do recommend that DOE evaluate their 

cost–energy curves incorporating the higher costs of 

vacuum insulation panels, at least in the short term. 

Finally, just a few other issues regarding 

vacuum insulation panels that may not deal directly 

with the question on supply. One is that this 

technology incorporated into cabinets are more 

difficult to install than in doors. Has this 

additional cost been taken into account? 

Finally, what is the average life of a vacuum 

insulation panel? In terms of the newer ones, they 

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have not been on the market a long time. How do those 

compare to the refrigerator–freezer’s life? I think 

there is the question of how stable they are or how 

sensitive they are to damage. Basically, if you do 

lose one of these panels in a product, you no longer 

have anything there to deal with the heat load. So, 

just a few extra comments on vacuum insulation panels. 

MR. BROOKMAN: Thank you. Additional 

comments on this issue? 

MR. DELASKI: This is Andrew DeLaski. Could 

you comment on what the European and Indian 

requirements are? 

MR. CHURCH: Well, they’re in process. India 

is going to be coming out with a new standard about the 

same time that we are, so that’s all in process right 

now. There’s not a firm standard out. 

MR. DELASKI: But they’re looking at levels 

that in Europe would require VIPs. 

MR. CHURCH: They’re going through a fairly 

stringent change to their standard, much like we are. 

MR. DELASKI: Same with the Europeans? 

MR. CHURCH: I don’t know what the new 

standard is in Europe. I haven’t seen those numbers. 

MR. BROOKMAN: Thanks, Steve and Andrew both. 

 Yes, thank you. 

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MR. DELASKI: If I could just quibble with 

your prior slide for a moment, I know it’s part of the 

process here in showing technical feasibility and 

economic justification to do this analysis. You used 

the phrase the levels “could require more widespread 

use of VIPs.” Just to quibble with the phrasing here, 

you’re trying to estimate what the most cost–effective 

way to comply with the standard would be. It wouldn’t 

require it in a legal sense. 

That is, these are performance standards, and 

our historical experience has been that once the 

standard is set, DOE’s predictions or DOE’s estimates 

are usually wrong because you’ve got a lot of 

engineering experience at the manufacturers who are 

very capable of finding new and better ways to comply 

with standards. 

I think just to caution the use of the notion 

of requiring. These are performance standards, and 

we’ve got to keep that in mind. 

MR. TOPPING: Doug? 

MR. BROOKMAN: Yes? Yes, Dick. 

MR. TOPPING: As Debra said, this is clearly 

a sea change in the vacuum panel business that’s being 

proposed here. At our company, we’ve been using vacuum 

panels in small quantities I think for about 10 years, 

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so they aren’t a new technology. But the levels or the 

numbers that we’re talking about here are gigantic. 

They’re huge. 

Someone has to do it, and I think it has to 

be DOE, has to do a very well done market availability 

study to look at what would happen with the need for 

millions, literally, of vacuum panels where now it’s 

nowhere close to that. 

This is major. This is an introduction into 

mass production of a technology that really is not 

mass–produced. 

MR. BROOKMAN: Thank you. Additional 

comments on vacuum–insulated panels? 

 (No response) 

MR. WESTPHALEN: The next slide talks about 

low–volume products. As mentioned in the market and 

tech assessment – actually, that was the beginning of 

the engineering analysis section. The analysis was 

based on seven product classes, which represent most of 

the production. 

DOE proposes to extend the rulemaking to the 

other product classes after establishing standard 

levels for the analyzed classes. For example, the 

proposal might be to use the same required percent 

energy use reduction for Product Class 6 as was used 

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for Product Class 3. 

The TSD describes possible methodology for 

each of the low–volume product classes for achieving 

this. I don’t want to go into all the details. It is 

available in the TSD. But I would like to open the 

floor for any comments at this stage on those 

proposals. 

MR. BROOKMAN: Debra. 

MS. BRUNK: Debra Brunk with AHAM. Based on 

the data presented in the Technical Support Document, 

AHAM does believe that cost–efficiency curves should be 

developed for all product classes. Certainly, the 

analysis right now already is utilizing DOE’s 

simulations in terms of those curves. We think this is 

important because we’re talking about low–volume 

products here. The products that were evaluated are 

all high–volume. We’re talking about around 90 percent 

of the market, perhaps. 

When we start getting into cost efficiency 

curves for some of these lower volume products, you 

have potentially niche manufacturers and you have niche 

products. Essentially, because of their low–volume 

nature, the cost–efficiency curves are going to look 

different. We would expect that you would have a 

higher cost versus efficiency just to implement a 

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similar type of technology. 

Our preliminary proposal would be that DOE 

develop cost–efficiency curves keeping that low–volume 

component in mind. As we work on our comments, we’ll 

see if we might be able to suggest anything in 

addition. 

MR. WESTPHALEN: The next topic is, as 

promised, another look at built–in products. As 

mentioned, this was discussed in the framework meeting 

and in the framework comment period. 

The table on this slide presents a very 

initial look at what the potential cost differences 

might be between conventional products and built–in 

products. This is based on discussions with 

manufacturers during some of the visits made last year. 

 A difference of $43 was estimated, typical back–of–

the–envelope type of analysis based on the design 

option differences. 

We did receive some detailed data of designs 

for some built–in products and conducted more in–depth 

analysis. The next two slides compare some of those 

curves with the curves for the conventional products. 

You can see that, according to these analyses anyway, 

there are some differences in costs. 

Pretty close to the $43 at the 20 percent 

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Energy Star level for this particular product class. A 

little bit more than the $43 for Product Class 7. 

MR. DELASKI: Excuse me. What’s the source 

on the data? 

MR. WESTPHALEN: This is data for three 

actual built–in products, very detailed design 

information. We can’t divulge any more than that. 

MR. DELASKI: But it was data based on – it 

wasn’t a tear–down analysis. It was data supplied to 

you by a manufacturer. 

MR. WESTPHALEN: That’s correct. 

MR. DELASKI: As opposed to data that you 

calculated yourself based on engineering or reverse 

engineering or any other approach. 

MR. WESTPHALEN: Correct. But it went into 

very detailed drawings showing insulation thicknesses, 

heat exchanger sizes, specification of components, et 

cetera. 

MR. DELASKI: Thank you. 

MR. WESTPHALEN: We have a request for 

comments on built–ins. Basically, we still need to 

resolve this issue. Any information that can be 

provided to shed more light on it certainly is welcome. 

MR. BROOKMAN: Yes, Dick. 

MR. TOPPING: Just a point of order, Doug. 

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Is there an opportunity for the various participants to 

make more formal comments later, or are we going to do 

this through this, or what? What I’m saying is I have 

comments on built–in products, a couple minutes’ worth. 

 I’m just wondering what’s the best time. 

MR. BROOKMAN: I think what works best in 

terms of the flow of the conversation and also for the 

record is to make your comments at this point in the 

agenda. 

MR. TOPPING: Okay. All right. Well, I have 

a script, but this isn’t that kind of group, so I’ll 

try to paraphrase it. 

MR. BROOKMAN: Thank you. 

MR. TOPPING: All right. And it’ll be very 

brief. But this is comments from my company, Subzero 

Freezer Company, which makes almost exclusively built–

in products. 

In earlier comments, we did provide 

information to DOE justifying the need for separate 

product classes for built–in refrigeration products. 

We subsequently provided detailed design and cost data 

to DOE in meetings conducted at our facilities. 

The cost–efficiency curves that you just saw, 

I think, confirm that the cost to meet each energy 

improvement level are significantly higher for built–

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ins than for freestanding products. Also, DOE’s 

estimate of the cost increment to meet Energy Star 

shows $43, as we just saw, three times the amount 

needed for a conventional unit, and that number 

actually could be a little low. 

The cost differences occur because built–ins 

use more energy than freestanding units due to inherent 

design differences, including restricted condenser air 

flow, longer door gasket length per unit of storage 

volume, limits to insulation thickness, and complicated 

door hinging that increases cabinet heat load. 

The overall difference in efficiency averages 

out to be about 15 percent. However, these products 

provide very important utility for a small segment of 

consumers. While built–ins comprise only about 1 and a 

half percent of annual shipments, the buyer segment 

strongly desires kitchens designed to accept built–in 

appliances. 

DOE’s criteria for separate product classes 

include in the statute, and I quote, “Capacity or other 

performance–related features such as those that provide 

utility to the consumer,” end quote. Built–ins offer 

unique utility to their buyers. Therefore, separate 

product classes are justified in accordance with these 

criteria. 

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Andrew, you mentioned later the proliferation 

of product classes, and I understand that. At the same 

time, the statute does protect the consumer utility, 

clearly. In this case, there’s a utility associated 

with built–ins that cannot be provided by freestanding 

units. 

Also, the number of design options available 

for built–ins to meet the 2014 standard is limited. 

Our company already uses in our products some 

combination, and I underlined this, of every one of the 

qualified design options that you saw up there earlier 

that are considered by DOE in the TSD. Not every one 

in every unit, but a combination of every one of those 

is already being used, including vacuum–insulated 

panels, variable–speed compressors, and DC fan motors. 

Because of inherent higher energy use, we’ve 

had to do more and incur more costs to meet every 

previous round of standards. Basically, the number of 

silver bullets in our holster is dwindling quickly. 

DOE’s data confirms this by showing that built–ins 

cannot achieve the same levels of max tech improvement 

by any practical means. 

Going forward, if built–ins are required to 

meet the same standards as freestanding units, 

achieving Energy Star levels becomes almost impossible, 

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therefore eliminating that option as well for the 

segment of consumers who desire it. 

In these comments today, I have not even 

mentioned the challenges faced by Subzero, a small, 

privately owned company manufacturing solely in the 

United States. There are other companies like ours in 

the same situation. The difficulty is for companies 

such as ours to remain competitive in today’s world, 

which is changing rapidly. 

DOE’s decision on whether to establish 

separate product classes for built–ins will really be 

pivotal in our company’s ability to remain a viable 

competitor in the international refrigerator business 

in the future. 

We’ll certainly provide more detail in our 

written comments in some of these areas, but I did want 

– this is of particular interest and importance to us. 

 Given that you are asking for information, we wanted 

to provide some more today. 

MR. BROOKMAN: Thanks, Dick. Thanks for that 

summary. That’s helpful. Other comments on this 

before moving on? Yes, Debra. 

MS. BRUNK: Debra Brunk with AHAM. I just 

want to provide an industry comment here. AHAM does 

support separate product classes for built–in products. 

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 As we mentioned before, these are low–volume products. 

 As discussed before, they have substantially different 

cost requirements. That’s one reason. 

One thing we have done, I think, as we’ve 

worked to actually support built–ins as a separate 

product class is to develop a definition for these 

products. We will provide that in our formal comments 

because we recognize that that is an important piece of 

developing any new product class. 

MR. BROOKMAN: Thank you. Yes. Please say 

your name for the record. 

MR. HOROWITZ: Noah Horowitz with NRDC. If 

you could quickly talk about – I think I heard you say 

that you’re currently using vacuum insulation panels in 

your units. We heard from the trade association 

potential concerns. Are you able to procure those, and 

are they working well over time? 

MR. BROOKMAN: Dick Topping? 

MR. TOPPING: Yes, we are able to procure, 

but we’re only buying very, very small quantities. So 

far, the service record has been good, but you do have 

to realize that with vacuum panels, if there is a 

failure of the vacuum panel, then you’re not in a 

repair situation, you’re in a replace situation. Over 

time, regardless of how reliable the panels are, there 

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will be some failures, even if a serviceman puts a 

screwdriver through one of them. In that situation, 

you have to basically replace the refrigerator. That 

impacts the maintenance cost aspect of this as well. 

Again, vacuum panels are a great energy–

saving option. They come with some of their own 

baggage, including that and whether the world has the 

capability to make enough of them to meet the 

requirements that we’ve been talking about today. 

MR. BROOKMAN: Thank you. 

MR. WESTPHALEN: The next couple of slides I 

guess I don’t want to dwell on too much. We talked 

about the potential rules that would limit the 

availability of HFCs. DOE did some preliminary 

analysis looking at what would happen to an engineering 

analysis if we were forced to use blowing agents that 

would make less thermally resistive foam. This set of 

– 

MR. BROOKMAN: Debra? 

MS. BRUNK: Debra Brunk with AHAM. I just 

wanted to take issue with the first bullet point here 

and just clarify for the record. Legislation is not 

looking at banning the use of HFCs. It’s looking at a 

phase–down, which is different. Also, it’s looking at 

a phase–down of HFCs in general, not just specifically 

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as foam–blowing agents. 

I just wanted to make sure that we get the 

record straight on that. 

MR. BROOKMAN: Thank you. 

MR. WESTPHALEN: This set of curves is 

associated with two different analyses that differ only 

in the thermal resistivity of the insulation. Here a 

10 percent difference in resistivity was assumed. What 

you see is the curve shifts over to lower efficiency by 

roughly 5 percent. Clearly, this is something that 

certainly could be revisited for a number of the 

analyses. However, one of the important things is to 

make sure we get all the information correct. That 

leads to the request for comment, Issue 17, associated 

with technical data for alternative foam–blowing 

agents. 

In that preliminary look, we were using a 10 

percent number. Is that the real number? Does anybody 

have data on resistivity of different foams that is 

credible that we could use in the analysis? Also, 

speaking to Debra’s point, it would be useful to have 

information on likely scenarios for alternative foam–

blowing agents so that we better understand that it’s 

not cold turkey no HFCs but how that would really work 

and affect the industry. 

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MR. BROOKMAN: Comments on these two issue 

boxes? Andrew? 

 (No response) 

MR. BROOKMAN: Any additional comments in 

writing I think would be helpful to the Department. 

That ends this segment, yes? 

MR. WESTPHALEN: Yeah. 

MR. BROOKMAN: Okay. Before we move on, 

additional comments, final comments on this whole 

cluster? Because we’re moving on to a different 

section here, markups. 

 (No response) 

MR. BROOKMAN: Okay. We’re moving on. Yes, 

Dick. 

MR. TOPPING: I just have one comment that 

goes way back on something that Amanda said a couple 

hours ago, I guess. That is regarding wine coolers. 

Our company also does produce wine coolers. The 

situation here I think that we’re dealing with is 

whether to have a national standard for wine coolers or 

a de facto national standard based on the California 

standard. 

I guess the point is, our feeling is that 

this process we’re going through here is the correct 

way to come up with national standards for products. 

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In California, they’re analyzed based on a state 

impact, which is what they need to do, but then that 

standard in fact becomes the standard for the rest of 

the country. 

That’s, again, the reason that, as Debra 

mentioned, AHAM and certainly my company would very 

much appreciate national standards for wine coolers. 

MR. BROOKMAN: Okay. Thank you. We’re going 

to hear from Asa Hopkins next. Markups to determine 

product price analysis, energy use characterization, 

lifecycle cost analysis. For those of you that are 

keeping track, we’re probably going to go at least 

another half an hour before we pause for lunch, round 

about 12:30. 

MARKUPS TO DETERMINE PRODUCT PRICE ANALYSIS, ENERGY USE 

CHARACTERIZATION, AND LIFECYCLE COST ANALYSIS 

ASA HOPKINS AND GREG ROSENQUIST 

 (PowerPoint presentation) 

MR. HOPKINS: Thank you. As Doug said, my 

name is Asa Hopkins. I work at Lawrence Berkeley 

National Laboratory. 

Moving on to the energy use and markup 

analysis. A reminder of where we stand in going 

through this chevron chart. The markups and energy use 

are the critical inputs to the lifecycle cost analysis, 

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which follows this presentation. The markups are 

applied to those cost–efficiency curves that Detlef 

just spoke about, and then the energy use plays into 

the operating costs. 

The purpose of the markup analysis is to 

determine customer prices under a standard scenario 

based on the manufacturing costs that Detlef just 

described. We need to characterize the product 

distribution channels and the market segments and 

describe the retailer direct cost expenses and profits. 

The inputs to the market analysis for the 

manufacturer markups, the results of which Detlef has 

already included, are SEC 10-K reports for four large 

appliance manufacturers from earlier this decade. We 

also examined population–weighted average sales tax 

rates for each census division and large state, a total 

of 13 regions, and examined the economics of the 

appliance retail market using the U.S. Census Bureau 

Business Expenses Survey for household appliance 

stores. The outputs of this markups analysis are both 

baseline and incremental markups. 

Based on data from AHAM, DOE used a single, 

simple distribution chain. Data from AHAM indicates 

that an overwhelming majority of refrigerators and 

freezers are sold following such a pattern. DOE is not 

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aware of any other significant distribution channel and 

assumed that all customers purchased appliances in this 

manner. This accounts for the competitive nature of 

the appliance market that the costs that consumers face 

through some other channel would be comparable to the 

cost that they face through this channel. 

So, definitions of baseline and incremental 

markups. Markups relate the customer price to the 

retailer’s cost of goods sold. Baseline markups relate 

price to cost prior to any change in efficiency. They 

cover all of a retailer’s expenses, including the 

retailer’s profit, and they include direct labor costs 

such as salary, payroll, rental, et cetera. 

Incremental markups cover only incremental 

changes in the customer price that are related to 

incremental changes in the cost of goods sold. Some 

distribution costs remain constant as the cost of goods 

sold changes. For example, direct labor costs do not 

vary with efficiency–induced changes in cost of goods 

sold. DOE assumes that other operating costs and 

retailer profit will scale proportionally with the cost 

of goods sold. 

The output of this analysis. Again, the 

manufacturer markup was mentioned earlier, 26 percent. 

 These are multipliers. You would take the cost and 

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multiply by each of these numbers as you move down the 

chart. 

The retailer baseline markup is 1.45. That’s 

45 percent markup. The incremental markup is 15 

percent. The national average sales tax value is a 

little under 7 percent. Resulting in an overall 

baseline markup of 1.95 and an overall incremental 

markup of 1.55. 

MR. TOPPING: Question. 

MR. BROOKMAN: Please, Dick. 

MR. HOPKINS: Before we go on to the other. 

MR. TOPPING: DOE has concluded that, for the 

retailer, a two–markup structure is appropriate: 

baseline and incremental. Why doesn’t that same 

rationale apply to the manufacturer? 

MR. HOPKINS: Perhaps Detlef can describe 

that more. I’m not sure about the manufacturer markup 

process of developing that number. 

MR. BROOKMAN: Detlef, yeah, please. Turn it 

on. 

MR. WESTPHALEN: I have to be honest. I’m a 

little bit surprised by the question. It’s not clear 

to me that there’s a differential on the manufacturer 

side. 

MR. BROOKMAN: Dick, maybe you could say a 

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little more. Expand your question a little bit. 

MR. TOPPING: If you go back to the slide 

before that, basically, it says baseline markups relate 

to indicate – where is it? There was something there 

where it talked about labor costs and whatever being 

covered in the baseline markup. 

MR. BROOKMAN: That’s 84, middle of the page. 

MR. TOPPING: I guess what I’m saying is, the 

assumption is that as manufacturers improve efficiency, 

then all the costs associated with increasing that 

efficiency can be passed on to the next stage to the 

retailer. 

MR. HOPKINS: Right. I believe that that’s 

the assumption, that manufacturers are assumed to pass 

their costs along. 

MR. BROOKMAN: Do you want some additional 

comment in addition to what Asa has said? 

MR. TOPPING: Well, maybe we can talk about 

that. 

MR. BROOKMAN: Okay. Ron Lewis. 

MR. LEWIS: I may have just missed something 

because I was responding to something on the 

BlackBerry. My comment really was a couple minutes 

back, Dick, to your issue and your question. We’re yet 

to do the manufacturer interviews, and during that MIA 

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stage in the development, that would be an excellent 

time to give any input. That’s exactly what it’s for. 

We’re starting out with premises, 

assumptions, history of how we’ve done things, and any 

precision you can give to that would be most helpful. 

MR. BROOKMAN: Thank you. 

MR. HOPKINS: DOE’s goal in this process is 

to most accurately characterize exactly what the prices 

that customers will face will be, so any data that 

anyone may have that is useful for that process would 

be welcome. 

Moving on to the energy use determination, 

which then plays into the operating cost. The purpose 

of the energy determination, of course, is to develop 

annual energy use data that can then be used in the 

lifecycle cost and payback period analyses to calculate 

their annual operating costs. 

DOE used two distinct methods, one for 

standard size products and a separate method for 

compact products. For standard size products, DOE used 

household samples from the Energy Information 

Administration’s 2005 Residential Energy Consumption 

Survey for the five standard size product classes that 

have been the subject of all of the discussion earlier 

this morning. Those classes are, again, Product 

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Classes 3, 5, 7, 9, and 10. 

The Residential Energy Consumption Survey 

includes estimates of the energy use attributable to 

refrigerators and to freezers in each home within their 

household survey. DOE was able to use those end–use 

energy estimates to evaluate field energy use. 

For compact products, DOE used the 

engineering analysis data to develop the annual energy 

use for the two compact product classes analyzed in 

detail. That’s Product Classes 11 and 18. That is, 

DOE assumed – we can touch on this again in a moment – 

that the field in–use energy use of these compact 

products is equal to their performance under the test 

procedure. 

In more detail for standard size products, 

the fundamental question that DOE is addressing is the 

question of how energy use in the field in an 

individual household’s kitchen or garage, or wherever 

their refrigeration products may be, how that energy 

use may compare with the energy use under the official 

DOE test procedure. 

DOE carried out an energy use analysis on a 

per–household basis from RECS. RECS is a survey of 

approximately a little over 4,000 households across the 

United States. For each household that owns one or 

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more refrigerators, for each of those refrigerators, 

the survey includes both the age of the unit and the 

volume of the unit, as well as the field energy 

consumption of those units. 

Based on the unit age and its volume, DOE can 

estimate when that unit was produced and therefore what 

standard was in effect at the time of its production, 

use the volume of the product to calculate what the 

test energy consumption of that product was when it was 

new. That’s the second box, the yellow box, 

calculating the test energy consumption of the existing 

product in the year 2005 in that household’s kitchen. 

MR. TOPPING: Doug? 

MR. BROOKMAN: Yes? 

MR. TOPPING: Is that submeter data? 

MR. HOPKINS: It is developed using a 

statistical technique. RECS does not submeter the 

households that it is reporting the energy use for. 

MR. BROOKMAN: Tom Eckman. 

MR. ECKMAN: Do you know what the standard 

error on that measurement is? 

MR. HOPKINS: RECS doesn’t report it, so I 

can’t speak for the EIA. They report each number as 

their best estimate. 

MR. ECKMAN: When we get to the field 

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adjustment factors, I’ll be back to that question. But 

it would include ice–making data, though, if the 

product had an ice–maker. 

MR. HOPKINS: Right. Yeah. The technique 

includes data about the refrigerator, about its age, 

about whether it includes an ice–maker, et cetera. 

That’s input into their calculation process. 

MR. BROOKMAN: Previously, that was Dick. 

Okay. Proceed. 

MR. HOPKINS: DOE wants to take into account 

the test procedure that’s under development, and so for 

each of these households after DOE calculates the 

estimated test energy consumption of the product in 

that household, DOE then needs to adjust that to 

account for what that product likely would have tested 

– what its test energy consumption would have been 

under the new proposed test procedure. This follows 

the same – yeah. 

MR. JOHNSON: Chris Johnson. Did 

geographical location and socioeconomic level factor 

in? 

MR. HOPKINS: I believe RECS takes many 

different points of data that they collect from each of 

these households into account in developing those 

estimates, including those factors. 

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MR. BROOKMAN: Let me just restate for the 

record. Your mic wasn’t on there, Chris. You asked 

about socioeconomic status and income factors as to how 

they relate to RECS. 

MR. HOPKINS: Geographic. 

MR. BROOKMAN: Geographic, thank you. 

MR. JOHNSON: Geographic locations, yeah. 

So, the south, the north, the east, the west, the 

weather, all that stuff. 

MR. BROOKMAN: He did say his name. Okay. 

MR. HOPKINS: DOE adjusts its estimate of the 

test energy consumption of the refrigerator in that 

household using the energy standards adjustment factor 

developed in the engineering analysis based on the data 

provided by AHAM. If you want to look back, those are 

the equations that Detlef mentioned that are on Slides 

36 and 37. 

The output of that first line of this process 

is the test energy consumption under the test procedure 

under development that would correspond to the – the 

test procedure under development as analyzed in the 

engineering analysis, disregarding any ice–making 

changes, et cetera. That provides a measure of what 

the test energy consumption of such a product would be. 

Then, DOE could look at the field energy 

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consumption of that product as reported by RECS in that 

household and look at the ratio between those two 

values. That’s what we call a usage adjustment factor, 

or a UAF. It’s simply field energy consumption divided 

by the test energy consumption. 

MR. BROOKMAN: Debra. 

MS. BRUNK: This is Debra Brunk from AHAM. I 

just have a very basic question here as I’ve worked 

through the TSD on this and everything. I guess I’m 

confused, and I’ll get into more of this later when you 

have the specific questions, but what is the purpose of 

this analysis and how does it get used later on in the 

evaluation? 

I guess I’m concerned because I just see 

there’s a lot of apples–and–oranges comparisons going 

on here. We’re bringing stuff back using a test 

procedure but we’re using field data. I guess I don’t 

quite understand the purpose of the comparison in this 

case. I’m just trying to understand how it actually 

feeds into the rest of the evaluation. 

Maybe you’ll cover that, but a little 

clarification would be really helpful. 

MR. HOPKINS: I’m happy to go through that 

now. In determining the operating cost for an 

appliance in a household, the relevant number is the 

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field energy use for that product. But in order to 

adjust that field energy consumption to reflect new 

products that would meet the standard that might come 

into effect in 2014, products that have not yet been 

manufactured, DOE needs to understand how factors 

within a home might impact that energy use. 

The goal of this analysis is to determine 

what the field energy consumption of a new product in 

2014 or whenever might actually be in the home so that 

DOE can then calculate the lifecycle cost of that 

product. So, the final output here is this TEC–new. 

It’s the test energy consumption for a product that 

might be sold in 2014 or 2015. The output that matters 

for the downstream analysis is what the energy 

consumption in the home of that product would be. 

MR. BROOKMAN: Let’s see if Debra wants to 

follow on. 

MS. BRUNK: Yes. Debra Brunk. Thank you for 

that explanation. I now understand how that’s wrapped 

into the analysis. I guess I just have a question, 

though. We’re looking at, I think, a lot of 

variability. You’re pulling products that may be 10, 

15, whatever, years old back into a 2014 scenario. I 

think there’s a lot of error in that evaluation. 

I guess I’d be interested in some sort of 

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analysis or evaluation on what is that error compared 

to what you would actually measure with the test 

procedure. Is there an advantage to actually doing it 

this way as opposed to knowing roughly what the error 

on the test procedure is? 

I guess I’m just wondering if by – actually, 

again, I’m, I guess, maybe getting ahead of myself 

here, but you look at the field use factor. Is the 

error on that so large that you could actually do this 

analysis with just using the test procedure data, which 

would then be much more consistent with the engineering 

analysis? 

MR. BROOKMAN: Dick? 

MR. TOPPING: Well, yeah. The FEC–new, is 

that the number that goes into the lifecycle cost 

analysis? 

MR. HOPKINS: Yes. 

MR. TOPPING: Has that ever been done before? 

MR. HOPKINS: No. This is a new process. 

MR. TOPPING: Yeah. So, in the past, the 

energy use that went into the lifecycle cost was from 

the test procedure. 

MR. HOPKINS: I believe that’s true, yes. 

MR. TOPPING: Okay. And so then you are 

adding ice–maker energy in this number already. 

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MR. HOPKINS: This number includes any number 

of factors that apply to products in people’s homes, 

which would include the use of ice–makers. 

MR. TOPPING: So you can see why this number 

is so much larger than the test procedure number. It’s 

apples and oranges. You’re adding something that’s not 

being tested in the test procedure. 

MR. HOPKINS: The assumption that DOE carries 

forward is that, say, a 10 percent improvement relative 

to the current product under the test procedure would 

also carry forward as a 10 percent improvement in the 

field energy use. That scaling can be carried forward. 

MR. TOPPING: But we don’t know what that 

number is. I think this is a big change. What DOE is 

basically doing here is substituting energy consumption 

that it’s done by established test procedures with data 

gotten from the field with a lot of variability and 

then using that number to come up with lifecycle costs, 

which make the lifecycle costs look good from the 

standpoint of energy–saving efficiencies because what 

you’re basically saying is units are using a lot more 

energy than the test procedure says they are. 

I guess the point is, is it true? You’re 

using data for refrigerators that’s not submeter data, 

it’s statistical. It is units that are in all kinds of 

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applications of all sorts of ages in different 

geographic locations. We don’t understand any of that. 

 Some of them have ice–makers; some of them don’t. 

MR. HOPKINS: Just a quick point on that last 

point. 

MR. TOPPING: Yeah. 

MR. HOPKINS: RECS allows us to distinguish 

by product class which have ice–makers and which don’t. 

MR. TOPPING: Okay. But you’re taking a big, 

huge number and dividing it and saying, well, this is 

what energy consumption is. 

All I’m saying is in terms of precision, this 

is a far less precise process than it used to be. 

MR. HOPKINS: One of the goals of DOE’s 

analysis is to understand and characterize the 

distribution in energy use across different end uses. 

This survey is one way that DOE can get a handle on 

that. If DOE were to use only the test procedure 

energy use, it would not characterize energy use 

variability by, say, socioeconomic status or region of 

the country. 

I just want to give a preview that during the 

actual lifecycle cost discussion my colleague Greg 

Rosenquist will show an example of the impact of the 

fact that the mean values of this usage adjustment 

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factor are greater than one on what those lifecycle 

cost outputs are. 

MR. BROOKMAN: Andrew, let me hear from Steve 

first. 

MR. CHURCH: Just a quick question. Just a 

clarification. You said you can tell by product class 

which ones have ice–makers and which ones don’t? 

MR. HOPKINS: Sorry. RECS asks the 

households that are surveyed whether their appliance 

containers an ice–maker, or particularly whether it’s a 

through–the–door ice–maker, which allows DOE to develop 

household samples, which I will show on the next slide 

– or maybe the following slide; I’m not sure – be able 

to say this household in a particular region with a 

particular field energy use has a side–by–side format 

refrigerator with through–the–door ice and therefore we 

can use that household as an example for Product Class 

7, et cetera, for each household. 

MR. CHURCH: I understand that. But if I 

have a Type 3 or a Type 4, they may well have an ice–

maker. They don’t have a dispenser, but they may well 

have an ice–maker, so the product is still making ice. 

MR. HOPKINS: Greg, do you know exactly what 

the question in RECS is? 

MR. ROSENQUIST: This is Greg Rosenquist, 

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Lawrence Berkeley National Laboratory. It just asks 

the question whether it has through–the–door ice 

service. No, it doesn’t ask specifically if there’s an 

ice–maker in the refrigerator–freezer. 

MR. HOPKINS: That allows us to distinguish 

as best as DOE can which class is represented in that 

household. 

MR. CHURCH: Yeah, I understand. I just 

don’t want it to be represented as the Type 7 has an 

ice–maker, the Type 4 does not, because that’s not an 

accurate statement. 

MR. HOPKINS: Thank you for that. 

MR. BROOKMAN: Andrew, do you wish to 

comment? 

MR. DELASKI: Yeah. Just a couple comments. 

 One is that it may not have been done before for 

refrigerators, but I think in other dockets DOE has 

taken a similar approach, and I think the approach 

makes sense. The attempt here is to show what happens 

to consumers, and the government ultimately has to 

estimate impacts on consumers. 

Sure, RECS is imperfect. The test method is 

imperfect. I think that the challenge here is to find 

a way forward that helps to address issues that have 

been described here in terms of variability and in 

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terms of impacts on consumers. I think the general 

approach that you’ve outlined is an appropriate 

approach to get that overall impact on consumers. 

MR. BROOKMAN: Thank you. Yes, Amanda. 

That’s not on. Thank you. 

MS. STEVENS: Thank you. I just want to say 

I support what Andrew just said. Just to add to that, 

I think that this complexity here with this analysis 

really underscores the importance of moving to a test 

procedure that really is truly representative of the 

average energy use in the field. Keeping that in mind 

as the test procedure revisions are considered is an 

important thing as well. 

MR. BROOKMAN: Thank you. Debra. 

MS. BRUNK: This is Debra Brunk from AHAM. 

In response to that comment, I want to caution DOE and 

others against looking – obviously, there are 

differences in the test procedure and field use. I 

think one of the reasons the test procedure is how it 

is – it’s already a complicated test procedure, but 

there are a lot of issues that happen in a household 

that are very difficult to test or to model. You have 

the whole issue of door openings, ambient temperatures, 

ice–maker use, and all these different things. The 

test procedure is done essentially to provide an 

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apples–to–apples comparison. 

Again, I would caution looking too closely at 

all of those variables because, first of all, you make 

the procedure even more complex, which means it’s more 

difficult to follow. Japan actually did this. They 

had issues with the test procedure and what happened in 

the field, and they basically were mandated by their 

government to go back and create a test procedure that 

was representative of consumer use. They did that, and 

the results were a mess. Now they actually are working 

back through IEC to try to come up with something that 

is more like what we’re doing here. 

All I would say is it’s important and, 

certainly, we recognize that the consumer is important. 

 They’re our customer. But I think it’s just a 

question of what becomes a representative use of energy 

and that we have to just find the balance between a 

test procedure that gives a good representation of the 

energy use versus one that is so detailed that the 

burden and even just the results that you obtain from 

that test are questionable when applied to different 

geographic areas, et cetera. 

MR. BROOKMAN: Is it Martin? 

MR. SEVERANCE: Yes. This is Martin 

Severance. I was curious if the UAF was looked at at 

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the age of the product. In other words, did that have 

a slope that followed up with the age and used the 

average value? How was that achieved? 

MR. HOPKINS: The UAF for each household is 

simply a constant over time. DOE did take the age of 

the product in the consumer’s household into account 

when calculating the UAF so that a product that was 

produced, say, in the mid 1990s, its energy use was 

compared to the energy use in the test procedure – the 

tested energy consumption for the standard that was in 

effect at that time. But for a given household in the 

lifecycle cost analysis, the UAF is simply constant. 

DOE would welcome any information regarding 

how – 

MR. SEVERANCE: I guess I was curious if you 

looked at – for example, foam changes insulation factor 

as it ages. Was the UAF graphed like this group of 

products is eight years old, this group of products are 

two years old, and look at that value, if it changes 

with time? 

Also, there are other things that – products 

back, for example, in the ‘80s had switches that turned 

heaters off and on. When we tested back then, the 

standard was you tested it on and off, and then we 

averaged and did a 50 percent. Where were these 

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switches set on these units? Were they actually in an 

energy consumption for sweat? There are a lot of 

factors that could change this differential that you’re 

estimating. 

MR. HOPKINS: DOE looked at the UAF as a 

function of age and was not able to determine that 

there was any significant slope to take into account. 

The economic literature and studies have indicated some 

different measures of what that level of change might 

be over time, but there is no consistent answer that 

DOE felt confident applying. 

In effect, if one of the things – I’m just 

going to go on here to this slide, if that’s all right. 

 If product degradation, as foam ages or other factors 

– there’s a study that ice–making energy may change as 

an ice–maker ages. If those are occurring, perhaps DOE 

is – well, DOE has chosen not to include such a slope 

because DOE didn’t have a value that it could use. The 

value for a given household is an average over the age 

of the lifetime of the product. 

MR. BROOKMAN: Tom, are you on this point? 

Because Dave is. 

MR. ECKMAN: Yeah, I have several issues on 

this, but – 

MR. BROOKMAN: Go ahead, Dave. 

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MR. HALL: David Hall. With the field energy 

factor being considered in the calculation procedure 

here, that is describing to me that it’s part of this 

rulemaking process. My reason for saying that is it’s 

also either basing or assuming the energy consumed on 

those products and those classes by the current test 

procedure. 

The point there is, knowing that there’s a 

test procedure rulemaking going on, this could serve as 

an overlap or an overstatement of energy consumption if 

a test procedure includes all these other attributes as 

Debra has mentioned to better reflect energy 

consumption and a field factor is applied to it. 

Somehow, that will have to be reconciled between the 

level and the test procedure. 

MR. ECKMAN: Tom Eckman. I think that he’s 

got the same point that I have. I think there’s a 

methodological problem here. If you were using the new 

test procedure to directly correct to get the field 

energy consumption, I think you’re double–counting some 

of the effects because, generally speaking, the new 

test procedure will create higher consumption for these 

same units. You’re going to double–count that unless 

you’re using the field energy consumption multiplier. 

The UAF is getting created using the new test procedure 

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based on what those vintages were. Is that what was 

done? 

MR. HOPKINS: That’s correct. That’s this 

teal–ish box. It’s an adjustment for the energy 

standards adjustment factor. ESAF is an adjustment for 

the new test procedure. 

MR. ECKMAN: Before you went to RECS to find 

out the match. 

MR. HOPKINS: Before going to RECS. So, the 

test energy consumption is higher than it would have 

been under the old test – 

MR. ECKMAN: Under the prior test procedure. 

MR. HOPKINS: – under the prior test 

procedure by 15 or so percent, which means that the UAF 

is lower than it would have been by 15 or so percent. 

MR. ECKMAN: I think, if that’s a clean path, 

the second issue is that when you make a percent 

improvement which includes degradation, that’s probably 

reasonable. But if it includes these other features 

that we’re not regulating at least to date with the 

ice–maker, it assumes that you’re getting a 10 percent 

improvement, whatever ice–maker consumption there is. 

So, there’s an overlap to the extent that 

that field energy consumption represents ice–maker 

consumption. We’re not touching that in this 

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rulemaking, but you’re basically saying as a percentage 

of the total lifecycle cost analysis, assuming you’re 

getting that. Because it’s 10 percent of the absolute 

number. 

MR. HOPKINS: That’s correct. We welcome 

comment on how to adjust for that. 

MR. BROOKMAN: Dick. 

MR. TOPPING: Just one more maybe 

philosophical point. I understand what you’re saying 

about national impact. I understand that. But this is 

what I think we’re doing; correct me if I’m wrong. 

Navigant and DOE are doing this very good work looking 

at the minutia of fans, condensers, compressors, vacuum 

panels, and all this sort of stuff, and teardown 

analyses and everything else, to try to figure out how 

much efficiency you’re going to get with this 

improvement or that improvement. 

We come up with a number, and then we 

multiply it by just some incredibly fuzzy number. An 

incredibly fuzzy number. It kind of defies logic to 

me. 

MR. BROOKMAN: Thank you. Jeff. Please say 

your name for the record. Use the microphone, Jeff. 

MR. HARRIS: Jeff Harris. I had a question 

which I don’t see in the slides here. Pardon me if 

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you’ve discussed it earlier, before I came in. We’re 

talking about a single size refrigerator. One of the 

things I’m curious about and I think might even be 

possible to tease out of RECS data is differences in 

this adjustment factor as a function of refrigerator 

box size proxy by capacity. 

The underlying thought is this, that if you 

think about kitchens, there are standard openings, 30–

inch, 36–inch. The more you’re trying to squeeze into 

that opening, the larger the box is – it extrudes into 

the kitchen, you push it back – the less you can get 

air circulation. I think there may be a factor that 

one could tease out of large numbers like this that 

would correlate with refrigerator size in suggesting a 

different adjustment factor for larger boxes. 

I think there would be direct implications 

for how we look at the standard for large boxes 

compared to modest size boxes. I wonder if that’s 

something you’ve thought about. 

MR. HOPKINS: DOE did look briefly at the 

variation in the usage adjustment factor by volume and 

did not find a strong and significant correlation that 

DOE could rely upon to carry forward in the analysis. 

That doesn’t mean it’s not there, only that DOE’s 

analysis didn’t find it. 

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We thank you for your comment and can 

reexamine it. 

MR. HARRIS: There might be something that 

could be done as a side study just looking at a few 

boxes and putting them in cabinets of different 

dimensions for short–term measurements. 

MR. BROOKMAN: Thanks, Jeff. Debra, do you 

want to comment here? No. Okay. 

MR. HOPKINS: Do you want to try to finish 

energy use before lunch? 

MR. BROOKMAN: Yeah, let’s do that. 

MR. HOPKINS: So, just some details of the 

things that DOE took into account in the calculation of 

the UAF. 

Some households contain more than one 

refrigerator, where RECS reports only the total energy 

consumption for all refrigerators. DOE has assumed 

that a given household would have the same usage 

adjustment factor for both refrigerators, with the 

caveat that the UAF was adjusted down by a factor of 

0.7 for second refrigerators in cold climates which 

were assumed to reside in a basement or some other, 

more favorable operating environment. 

DOE also adjusted the UAF to account for the 

presence of Energy Star refrigerators whose test energy 

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consumption is thereby lower than the test energy 

consumption for the standard that was in effect at the 

time that the product was new. 

DOE used engineering data and modeling to 

define minimum and maximum plausible unit usage 

adjustment factors for each household and used these to 

remove outliers from the data. 

It should be noted, as you are all clearly 

aware, that the average usage adjustment factor for 

each product class analyzed is greater than one, 

indicating that, on average, field energy use exceeds 

energy use under the test procedure. As you also have 

noted, there are factors on field energy use that are 

not reflected in the test procedure, such as energy use 

for ice–making and the potential that refrigerators’ 

energy consumption may increase over time for a given 

product. 

Here are the final mean, minimum, and maximum 

usage adjustment factors for each of the five standard 

size product classes. The sample size on the far right 

is the number of households in RECS that are used for 

each. It should be noted that, the way the RECS survey 

is asked, it cannot distinguish between bottom–mount 

and top–mount products. It simply asks whether the 

freezer is above or below the fresh food cabinet. It 

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is our hope that the 2009 survey will ask a more 

precise question. That explains how the Product Class 

5 sample size is as large as it is. 

I gave an example of the variability in this 

usage adjustment factor. This is a histogram of the 

usage adjustment factor for Product Class 3. 

MR. CHURCH: This is Steve Church. Just a 

quick note. You said you couldn’t distinguish bottom–

mounts because they simply asked if the freezer was 

above or below? 

MR. HOPKINS: Correct. 

MR. CHURCH: Did you actually mean side–by–

sides? Because if my freezer is above or my freezer is 

below, you’ve just distinguished tops and bottoms. 

MR. HOPKINS: Oh, no. Sorry. RECS presents 

the householder with a couple of pictures and says 

which of these looks like your refrigerator? One of 

the pictures is a side–by–side and one of them has the 

freezer above or below the fresh food compartment. So, 

RECS cannot distinguish whether it is above or below. 

It simply, in effect, asks is it above or below, or to 

the side. Those are the distinguishing 

characteristics. Sorry for the unclarity. 

An example of the variability of this usage 

adjustment factor for Product Class 3. It’s clearly a 

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very wide distribution and a somewhat different shape 

for Product Class 7. It’s a somewhat flatter 

distribution but still quite broad. 

Just to be clear, in the lifecycle cost 

analysis to come, each of these households is sampled 

individually in a Monte Carlo calculation. Some 

households have quite low energy use corresponding to 

their refrigerator and some have quite high. Each of 

those households is analyzed individually, which allows 

DOE to more accurately characterize the variability in 

the impacts of proposed standards. 

This slide presents the average energy use in 

each of the five standard size product classes that DOE 

analyzed in detail, taking into account the range of 

volumes, et cetera. 

MR. ECKMAN: Given the histogram, was the 

data check for normality, and is it normal? 

MR. HOPKINS: This data did not fall in a 

Gaussian distribution. It’s not a normal distribution. 

MR. ECKMAN: So, is using the average a good 

way of looking at the data? 

MR. HOPKINS: The averages are presented here 

only for informational purposes. As I said, in the 

Monte Carlo analysis, each household is sampled 

individually based on the weights assigned by RECS. In 

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the lifecycle cost analysis, DOE does not use the 

average value of the usage adjustment factor at all. 

It’s presented only to tell you a little bit about this 

distribution in a single parameter. 

MR. BROOKMAN: Jeff Harris. 

MR. HARRIS: Jeff Harris, Alliance to Save 

Energy. As I recall, there aren’t any actual 

measurements of end uses in the RECS data set. It’s 

all statistically inferred, right? 

MR. HOPKINS: That’s correct. 

MR. HARRIS: And one of the problems, it 

seems to me, with refrigerators is they’re pretty much 

everywhere. The only question is do you have one, two, 

or three, to help you get the coefficients. 

I’m wondering whether it might be worth it at 

some point to see how much you can rely on these as 

actual end use values to make this adjustment factor, 

perhaps by doing the same kind of statistical inference 

that was done with RECS to get those end use values 

with an end use measure data set like the California 

residential data set. I don’t know if you’ve thought 

about that as a way of just getting a little more 

reliability on these numbers. 

MR. HOPKINS: I’m personally not aware of 

that California data set that you described. I’d love 

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to ask you about that. 

Sorry. I lost the earlier part of your 

question. Could you repeat it? Sorry. 

MR. HARRIS: I just was confirming that the 

end use values in RECS are really based at this point 

on statistical inference rather than measurements. I 

know that there has been discussion on and off for 

quite a while about spot measurements. One of the 

problems with statistically inferring something that’s 

in every house is you can’t see its absence. All you 

can see is one, two, or multiples. 

MR. HOPKINS: Right. That is correct that 

it’s a statistical method. DOE welcomes any and all 

data regarding what energy refrigerators or freezers 

use in the field. 

One of the challenges that DOE faced in 

developing this method and this analysis was the lack 

of recent studies of refrigerator energy use in the 

field. Most of the literature is quite old. As folks 

in the room have discussed, refrigerators and freezers 

have changed over time. The technologies used, the 

prevalence of ice–making, et cetera, have changed. DOE 

would welcome any and all recent data, studies, et 

cetera, on what these products use in the field so that 

we can take that into account. 

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MR. BROOKMAN: Debra, then Chris. 

MS. BRUNK: Debra Brunk from AHAM. I just 

had a couple of questions, actually, on your table on 

Slide 92. The first is just clarification for me. 

When you say “proposed test,” is that using your 

calculations where you’ve calculated back to what the 

value would be using the proposed test, or are those 

actual test values on, say, the products that you do 

teardown on? 

MR. HOPKINS: In effect, what these numbers 

are is that the second column is the third column 

divided by the average usage adjustment factor. 

MS. BRUNK: But that’s kind of obvious, isn’t 

it? Wouldn’t you be really comparing a proposed test 

like something that was done on these product classes 

that were actually evaluated either by – aren’t we 

comparing the test procedure? So, wouldn’t you be 

looking at the actual test procedure numbers which DOE 

actually already collected? 

MR. HOPKINS: These numbers take into account 

all of the variability in the sample of the volume of 

refrigerators, et cetera. 

MS. BRUNK: Right. But I guess what I’m 

struggling with here is you’re basically just – you’ve 

taken the field and you’ve divided it by the UAF. 

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Where is the comparison to what DOE did in the 

engineering analysis, which is we developed all of this 

data in terms of energy use with the new test 

procedure? I guess I’m just wondering about that 

comparison. 

MR. HOPKINS: An equivalent way of generating 

the second column, because they’re all derived as a 

piece, is for each household to take the volume of 

refrigerator with a particular product class in that 

household and to calculate what the energy use under 

the current test procedure and the current standard 

would be for that product and adjust based on the 

analysis in the engineering analysis, to carry to what 

we’re calling the proposed test here, which is, 

obviously, not actually a formally, legally proposed 

test but is the general test procedure not including 

ice–making that was analyzed in the engineering 

analysis. 

MS. BRUNK: This is Debra Brunk again. I 

think we’re not communicating on exactly what I’m 

asking here, so we’ll try to make it a little bit more 

clear in our comments. 

MR. HOPKINS: Yes, please. 

MS. BRUNK: Basically, all I’m saying is it 

would be interesting to have either another column in 

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there or something that is actually what would the 

proposed test do with this actual product. Forget what 

RECS is saying, forget anything else, but how do these 

actually compare. 

The second comment I just want to make is, 

you had mentioned earlier that RECS cannot distinguish 

between a top–mount and a bottom–mount. So, how are 

you actually getting the numbers that are up there? 

Wouldn’t that just be shown as a single class? 

MR. HOPKINS: For a given volume, the 

standards are different between a top–mount and a 

bottom–mount. Therefore, the energy use assumed for 

that product is different. That results in the 

difference between the first two lines. 

MS. BRUNK: I’m sorry. One more question. 

How does the consumer provide a volume to you? Or, I’m 

sorry, to the RECS survey. How is that volume 

determined? 

MR. HOPKINS: The respondent is asked to say 

which of a set of volume bins does their product fit 

into. I’m not sure of the exact bins, but, for 

example, it might be is this a 16– to 18–cubic foot 

product or is this an 18– to 20–cubic foot product. 

MS. BRUNK: How would they know? Is this 

making them look back at their use and care manual? 

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How would they know this? A standard consumer who 

doesn’t even know half the time what – I mean, I’ve 

heard a number of people asking questions in showrooms 

and stuff. I’m just curious. I’m just trying to get 

at, if you’re using the volume distinction to separate 

these two product classes, I’m trying to get an idea of 

how the consumer actually knows what that is, since 

we’re using that data to put these numbers together. 

MR. HOPKINS: Just to clarify, the volume 

distinction was not used to determine which product 

class a given household owns, only what energy use 

might have been expected for that product when it was 

new. 

On how the survey respondent knows, the only 

assumption we can make is that the survey respondent is 

correct. 

MS. BRUNK: Of course. I’m sorry; I keep 

asking questions as this dialogue continues. This is 

assuming that all the refrigerators are baseline 

models? If you’re doing, again, that assumption in 

terms of this is what the energy is, what if it’s an 

Energy Star product that was bought 20 years ago? 

Might that not fall into a different class? 

MR. HOPKINS: One of the questions that RECS 

asks is whether the product is an Energy Star product, 

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so the analysis can take that into account, including, 

with the age, what the Energy Star requirement was 

relative to the standard at the time the product was 

new. 

MR. BROOKMAN: Tom Eckman. Oh, pardon me. I 

dropped Chris out of the queue. Chris, you’re next. 

Sorry, Tom. 

MR. JOHNSON: Chris Johnson. One of the real 

difficulties in something like this is, and one of the 

major factors, is human behavior and family size. That 

is incorporated in socioeconomic and geographic. 

For instance, somebody with a side–by–side 

refrigerator, let’s say a family of three that lives in 

Phoenix, and you compare that with a family of eight 

with four teenagers that live in Chicago. There’s so 

much variability. Other than, similar to the census, 

knocking on somebody’s door and spending a half an hour 

watching their behavior, how could you even 

statistically infer energy use without an actual – it 

just seems like there’s so much variability that you 

could drive a truck through some of these assumptions. 

I think, actually, at some point AHAM – we 

talked about manufacturers doing this. When we asked 

our marketing people, it’s so difficult to do, even 

from your own customers, to know whether or not they 

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even know what you’re talking about, whether they’re 

correct or not correct, of how do you verify. 

The other thing I would say about this is how 

do you know this is accurate? If this is accurate now, 

how do you know this is going to be accurate in one 

year? Is there repeatability? Is there verification 

capability of this data? Those issues. It’s just a 

very difficult process to do, based on human behavior 

and family size and all that stuff. 

MR. BROOKMAN: Tom. 

MR. ECKMAN: Well, first of all, I would 

support metering. Any time you get an idea, that’d be 

a great idea. Just find some money to do that. It’d 

be wonderful. We could solve a lot of these problems. 

My question is how you distinguish between 

the top–mount and the bottom–mount if RECS doesn’t 

differentiate, if the picture is an “or.” 

MR. HOPKINS: Right. The initial household 

sample for both top–mount and bottom–mount is the same 

set of households. The household sample – 

MR. ECKMAN: Overlaps. 

MR. HOPKINS: The household sample almost 

completely overlaps. 

MR. ECKMAN: You’re assigning them 100 

percent probability that they’re one or the other, but 

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you’re just splitting the shipments; is that right? 

MR. HOPKINS: For a given analysis, say it’s 

the top–mount refrigerator analysis, DOE used a 

household sample that uses the entire universe of 

households with – 

MR. ECKMAN: Top–mount. 

MR. HOPKINS: – with top–mount refrigerators 

and, for bottom–mount, the entire sample that may have 

bottom–mount refrigerators, so as to have a sample for 

both sets. 

MR. ECKMAN: So, the distribution is the 

same. 

MR. HOPKINS: The final distributions and 

usage adjustment factors end up slightly different 

because the standards that those products would have 

had to comply with historically have been different. 

The exact number of households in the sample 

ends up somewhat different because of the cutoffs that 

remove outliers that depend on modeling of those 

products. 

MR. ECKMAN: Debra had this question of why 

you couldn’t compare the old test with the new test. 

Didn’t you use the new test to generate the UAF? 

MR. HOPKINS: Correct. 

MR. ECKMAN: So, you have the new test for 

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each of the RECS houses. 

MR. HOPKINS: Correct. Right. With the 

assumption from the engineering analysis – 

MR. ECKMAN: You could back out what the old 

test – 

MR. HOPKINS: Then divide by or multiply, 

depending on which direction you’re going – 

MR. ECKMAN: So, you could create that second 

column – 

MR. HOPKINS: You could create the – 

MR. ECKMAN: The current test. 

MR. HOPKINS: – the current test with using 

the ESAF, efficiency standards adjustment factor. The 

full table of those values is in the TSD. 

MR. BROOKMAN: Kelly. 

MS. KLINE: No, I’m sorry. I think we’re all 

kind of still having a collective problem understanding 

how you segregated the top– and bottom–mount here. 

What did you base the differentiation between – 

MR. HOPKINS: There are households – in fact, 

roughly probably 2,200 households – that were in both 

samples. 

MS. KLINE: But then I thought they were not 

able – they could just tell you they had either/or, 

right? They said they had either/or. 

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MR. HOPKINS: They said they had either a top 

freezer or a bottom freezer. 

MS. KLINE: Right. Okay. So, now – 

MR. HOPKINS: But with no way for us to 

distinguish which one they may have. 

MS. KLINE: So, help me with the next step, 

then. How did you distinguish – 

MR. HOPKINS: Any household that might have 

either a top freezer or a bottom freezer is included in 

both samples. 

MS. KLINE: Okay. 

MR. BROOKMAN: Then, how did you end up 

splitting them the way you did? 

MS. KLINE: Yeah. 

MR. HOPKINS: They’re not split so much as 

separate calculations. The first calculation is 

calculated with a sample of 2,231 households that may 

have a top–mount product. The second – 

MS. KLINE: So, you’re assuming they all had 

top–mounts or they all had bottom–mounts? 

MR. HOPKINS: One calculation is every 

household that said they had either a top– or bottom–

mount, had a top–mount, and one calculation is every 

household that said they had either a top– or bottom–

mount, had a bottom–mount. 

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MS. KLINE: Is it 100 percent divided by two, 

or is it just 100 percent in each one? 

MR. HOPKINS: It’s 100 percent in each. 

MR. BROOKMAN: Let’s let this gentleman, 

please. Say your name. 

MR. GREENBLATT: Jeffrey Greenblatt from 

LBNL. If I can just clarify. What I think these 

comments are asking, Asa, is why the sample size isn’t 

exactly the same for the two categories. 

MR. HOPKINS: The sample sizes are very 

similar but are slightly different because of the 

process of removing outliers. Engineering modeling was 

used to – if RECS reported a refrigerator that used, 

for example, 10 kilowatt–hours per year, far less than 

a product in use could possibly use, the analysis 

removed that household. Similarly, if it was reported 

as using thousands and thousands of kilowatt–hours per 

year, that data point is clearly an outlier and was 

removed. The process of removing those outliers 

results in slightly different sample sizes. 

MR. BROOKMAN: I want you to finish the 

slides in this segment, and then we can think about 

this over lunch and return to it if we need to. So, 

finish out the slides. 

MR. HOPKINS: All right. I’m going to assume 

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that it’s safe that we pass this slide for now. 

MR. BROOKMAN: We’ll see. 

MR. HOPKINS: Again, after lunch, we welcome 

any comment on – 

MR. BROOKMAN: Maybe we can have a brief 

discussion before we go to lunch off the record here. 

MR. HOPKINS: Just for compact refrigerators, 

lacking any household sample or any information on 

field energy use, DOE simply assumed field energy 

consumption was identically equal to the test energy 

consumption and developed the average value simply 

using the distribution of volumes of models sold in the 

California Energy Commission database. 

We welcome any comment on the field energy 

use of compact products. 

MR. BROOKMAN: Debra. 

MS. BRUNK: Debra Brunk with AHAM. I think 

I’ll just make the obvious comment here that we support 

the approach on compacts. We really think the same 

approach should be used for standard size products. 

Keep things consistent. 

Again, I think it’s just – this discussion 

clarifies, I think, some of the confusion around how 

the data is used and the variability of it. So, again, 

we would support this approach for all products in this 

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rulemaking. 

MR. BROOKMAN: Additional comments on these 

last two segments here? Andrew. 

MR. DELASKI: We like consistency in the 

other direction. We think that the modeling should 

show what consumers experience in the field and that 

the data for the other product classes shows that the 

test method underestimates energy use. Most likely, 

the estimation you’re using for compacts is 

underestimating energy use. I don’t have any data to 

supply to you, but we’ll certainly look into that. 

I think right now those compact numbers are 

probably overly conservative given what we know about 

all of the other product classes and that their field 

performance exceeds their test performance. 

MR. BROOKMAN: Steve. 

MR. CHURCH: Whirlpool would just like to say 

that we feel that the quality of the data that we’re 

utilizing for field data has too many holes in it. I 

would agree with Tom’s statement that if this was 

metered products, that would be one thing. That’s real 

information on real products. But the type of 

information we’ve got here is too diluted. 

MR. BROOKMAN: Thanks. Martin, please. 

MR. SEVERANCE: I was going to say, my 

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understanding from the data, it’s estimated data. It’s 

not metered or measured data from the field. That’s 

correct, right? 

MR. HOPKINS: That is correct. DOE did 

conduct a literature review of field energy use for 

products. Again, unfortunately, older metered data, 

which generally showed that the field energy use was 

not equal to the test energy use, and in some cases 

higher and in some cases lower. 

MR. BROOKMAN: Yes, Jennifer. 

MS. AMANN: Hi. Jennifer Amann, ACEEE. I 

just wanted to point out; Jeff Harris had mentioned the 

California data set, the California Residential 

Appliance Saturation Survey, which is available data. 

I believe it’s a statistically significant sample of 

California households. I believe they do metering 

associated with that. It may not be the case, but it’s 

definitely worth exploring. 

MR. BROOKMAN: Thank you. So, final comments 

before we go to lunch? 

 (No response) 

MR. BROOKMAN: I want to provide an 

opportunity to return to this if we need to. If you 

can distill your questions even further over lunch – 

you’ll have nothing else to discuss, I’m sure, at lunch 

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– we can do that. 

But let’s pause for lunch now. It’s almost 

1:00. They’re going to lock this room. Please make 

sure to wear your visitor badge while you’re in the 

building. 

(Whereupon, at 12:54 p.m., the proceedings 

were adjourned for lunch, to reconvene at 2:05 p.m., 

the same day.) 

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A F T E R N O O N S E S S I O N 

2:05 p.m. 

MR. BROOKMAN: Let’s resume. If you could 

take your seats. We’re going to move into lifecycle 

cost analysis. 

MR. ROSENQUIST: I assume you don’t have any 

other questions about energy use. 

MR. BROOKMAN: Yes. Steve. 

MR. CHURCH: I just want to make one more 

statement. Just before we went on break, I said that 

we needed metered data. Also, we need adjustments for 

energy–consuming items on products in the field that we 

don’t account for in the energy test. For instance, 

ice–making energy. If we come up with a test procedure 

for ice–making energy, and you’ve already used or, in a 

sense, captured ice–making energy with this field test 

data, we’ll get smacked for it twice. 

MR. BROOKMAN: Gotcha. I think that’s a 

point that Tom made a moment ago. I was going to ask 

Amanda. Amanda, do you know; does the California data 

that you referred to, is it metered data? 

MS. STEVENS: We think that’s metered data, 

but I can’t be 100 percent positive. 

MR. BROOKMAN: Well, maybe there’s one good 

source there. Do you know about that? 

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MR. ROSENQUIST: No. To my knowledge, I 

didn’t think it was, but I’ll double–check. 

MR. BROOKMAN: Okay. Final comments before 

we move on? 

 (No response) 

MR. BROOKMAN: Okay. We’re moving on. 

MR. ROSENQUIST: I’m here to present the 

lifecycle cost and payback period analysis. This slide 

is to reorient you in terms of the way the lifecycle 

cost and payback period analysis works into the 

preliminary analysis flow diagram. You see that the 

outputs from the markups and the energy use analysis 

feed into the lifecycle cost. The lifecycle cost 

outputs in turn feed into the national impact analysis 

as well as with the shipments analysis. 

The purpose of this analysis is pretty 

straightforward. It’s to determine the LCC savings, 

the lifecycle cost savings, and the payback periods for 

all the standard levels that are being analyzed for 

refrigerators and freezers. 

The method relies on calculating the 

lifecycle cost, which is equal to the first cost, or 

the retail price, of the equipment plus its lifetime 

operating costs. Since those operating costs are 

occurring over the life of the product, discount rates 

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are used to bring that back to a present value. Once 

that’s done, it’s of course added to the first cost to 

come up with the total lifecycle cost. 

To make the analysis as transparent as 

possible, it’s put into a Microsoft Excel spreadsheet. 

 Also, what’s added to it is a software package called 

Crystal Ball, which allows DOE to conduct the analysis 

using a Monte Carlo simulation. With that, many of the 

inputs to the analysis, they have uncertainty and 

variability, and probability distributions are used to 

characterize that. That’s what Crystal Ball allows DOE 

to do. 

Also, as Asa mentioned earlier about the 

energy use analysis, a household sample is utilized for 

the standard size refrigerator–freezers and freezer 

products. Those household samples are used as part of 

this Monte Carlo simulation. Those characterize the 

energy use of the product as well as the energy pricing 

that those households are under. 

I saw a question there. 

MR. SEVERANCE: A curious question on the 

Crystal Ball simulations. All the data that’s used in 

the simulation is normal data? 

MR. ROSENQUIST: You mean it has a normal 

probability distribution? 

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MR. SEVERANCE: Yeah. 

MR. ROSENQUIST: No, they aren’t. Most of 

them are actually custom distributions. For example, 

in the case of the discount rates, it’s actually based 

upon the share each type of discount rate has. 

MR. BROOKMAN: Thank you, Martin. 

MR. ROSENQUIST: I’m going to move on to show 

you the flow diagram for all the inputs that go into 

the calculation of the lifecycle cost and the payback 

period. 

Starting up in the upper left–hand corner, 

you have the manufacturing costs that come from the 

engineering analysis. Those are coupled with the 

manufacturer markups, the retailer markups, and the 

sales taxes to arrive at an equipment price. That, in 

turn, is coupled with an installation cost to give you 

the total installed cost of the product. 

The bottom set of inputs have to do with the 

operating costs. There, you start with the energy use, 

which Asa described earlier this morning. That’s used, 

again, to develop the energy use of the product. 

That’s coupled with energy prices to come up with the 

annual energy expense of the product. That’s coupled 

with repair costs and maintenance costs to give you 

annual operating expenses. Then, lifetime discount 

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rate and energy price trends are used to take those 

annual operating expenses and convert them into 

lifetime operating expenses. 

The lifetime operating costs are combined 

with the total installed cost to give you the lifecycle 

cost, and the change in the total installed cost 

divided by the change in the first year’s operating 

costs give you the payback period. 

Now I’m going to start marching through all 

the inputs that go into the lifecycle cost analysis, 

unless there are any questions about what I just went 

over. 

First are the total installed costs. It’s 

relatively straightforward. It’s simply the equipment 

price or the retail price plus the installation cost. 

You’ve heard before how the manufacturing costs were 

developed and how the markups were developed. Again, 

what DOE is doing here is taking the incremental change 

in manufacturing cost developed by the engineering 

analysis and multiplying them by the markups and sales 

taxes to come up with the change in equipment price to 

the consumer from the standard level. 

Installation costs represent the labor and 

materials associated with installing the equipment at 

the site. DOE did not consider any installation costs, 

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though, for this analysis. DOE also assumed that there 

was no change in those installation costs due to 

increased efficiency. 

Now, as I just said, the engineering analysis 

developed incremental manufacturing cost changes due to 

these various standard levels, so DOE had to go to a 

different source to come up with the baseline equipment 

price, the baseline retail price, of these various 

refrigerators and freezers. DOE used sales data from a 

group called the NPD Group, which collects data from 

various retailer outlets throughout the country. 

The data also defines whether that equipment 

meets Energy Star or doesn’t meet Energy Star. For the 

baseline retail price, we used only the non–Energy 

Star–compliant equipment. 

We did this for all the product classes that 

were analyzed. Those are these seven product classes 

that you saw in the engineering analysis. This figure 

shows you the distribution in retail prices for side–

by–side refrigerators, Product Class 7. You can see 

that the distribution is quite wide, but it’s mostly 

centered around the $800 range. 

This next slide shows the relationship 

between consumer retail price and efficiency and how 

they relate for a couple of the product classes that 

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were analyzed. The two classes are upright freezers 

and side–by–side refrigerators. Of course, the Y–axis 

is the retail price. The X–axis is the efficiency. 

It’s been converted into this dimensionless value which 

represents the standard level energy consumption 

divided by the baseline energy consumption. 

You can see in both cases that price–

efficiency relationship is relatively flat through 

about 0.85 or 0.8, and then it takes off quickly after 

that. Again, this is directly a function of the 

manufacturing cost estimates, and those markups are 

used to convert them into retail prices. 

Next, I’m going to go on to the electricity 

prices. DOE used data from the Energy Information 

Administration’s Form 861. It provides, for all the 

utilities serving customers in the country for both 

residential and commercial, both the sales and revenues 

by utility. DOE can then derive an average electricity 

price by utility by just taking their revenue and 

dividing it by their sales. 

This data also provides the number of 

customers served – okay. Yes. 

MR. JOHNSON: Chris Johnson. Just a question 

on the prices. I’m sorry; is this – oh, I probably 

misunderstood. Is this consumer prices or utility 

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prices? 

MR. ROSENQUIST: Yeah, this is consumer 

prices. This is what consumers pay for electricity. 

MR. JOHNSON: Does that include all of the 

various programs of peak and off–peak and all that? 

The way you just described the average price, it didn’t 

sound like it took into account some of the other – 

MR. ROSENQUIST: Right. We’re just deriving 

it from the sales and revenues from these utilities and 

using this average price throughout the analysis. We 

didn’t, for example, look at tariffs. 

MR. BROOKMAN: Debra. 

MS. BRUNK: Debra Brunk, AHAM. Just a quick 

question back on Slide 103. Can you just remind me 

what you said in terms of how the normalized efficiency 

was calculated? 

MR. ROSENQUIST: Oh, oh. You know 

refrigerators are rated with annual energy use, right? 

MS. BRUNK: Right, right. 

MR. ROSENQUIST: Each one of these efficiency 

levels, the number 0.8, for example, stands for a 20 

percent reduction in annual energy use, which is the 

annual energy use at that level divided by the baseline 

energy use. That is the energy use that’s for the 

minimally complying product. 

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MR. BROOKMAN: Jeff Harris. 

MR. HARRIS: Greg, if I recall, the tendency 

has been to assume that refrigerators are kind of a 

constant load device. I wonder if there is or could be 

any data to see whether there’s either a day–to–night, 

a diurnal difference, or a seasonal difference because 

of average temperatures in the surrounding space that 

might in fact correlate with utility rates and be worth 

considering. In other words, refrigerator use in fact 

is noticeably higher when rates are also noticeably 

higher. 

I do recall that DOE has the data on tariffs 

from the air conditioning analysis, and so that part 

may not be too hard to bring into this analysis. 

MR. ROSENQUIST: I guess the more difficult 

part would be to get that load data for refrigerators. 

As Jeff just said, for other products, 

specifically air conditioners, DOE has collected actual 

tariff data to come up with a marginal electricity 

price. Those marginal electricity prices are derived 

not only from the tariff but from the type of hourly 

load that that air conditioning has. 

That same sort of process could be used for 

refrigerators. DOE chose not to do it here based upon 

the fact that refrigerators are basically a relatively 

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constant load throughout the day. Therefore, peak 

pricing that would occur, for example, in the summer at 

a hot period during the day wouldn’t be a big 

contributor to the overall energy consumption or 

operating cost of the refrigerator. 

MR. BROOKMAN: Tom. 

MR. ECKMAN: There is load data for 

relatively old machines, but I suspect the shape hasn’t 

changed all that much. You have L-cap data on, I don’t 

know, 500 homes, probably, in the Northwest. That’s – 

information. What’s been weather–normalized and all 

kinds of other stuff. But you could see whether the 

temperature impacts the compressor operation, which it 

clearly does, and the losses. 

You could look at it to see whether it makes 

that much difference. I think it doesn’t, but you can. 

MR. BROOKMAN: Thank you. 

MR. ROSENQUIST: To continue, these average 

electricity prices were developed for 13 regions that 

DOE looked at. These 13 regions correspond to the 

level of regional disaggregation that’s in the RECS 

data and that was used to analyze the energy use of 

standard size refrigerator–freezers and freezers. 

There are both residential prices here and 

commercial prices. DOE developed commercial prices 

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because compacts are believed to be used in commercial 

applications. DOE developed commercial prices as a 

result of that. 

Generally, the prices are the lowest in the 

southern part of the United States and are basically 

the highest in the northeast and California. 

For purposes of calculating lifecycle cost, 

DOE has to project these prices out into the future. 

To do that, DOE used the Energy Price Forecast out of 

the Annual Energy Outlook. This is a publication put 

out annually by DOE. The analysis used is in the most 

recent version of the AEO, which is the one that takes 

into account the American Recovery and Reinvestment 

Act. 

DOE also incorporates into its LCC 

spreadsheets high and low growth cases, in addition to 

the reference case. The high and low growth are 

incorporated in order to be able to do sensitivities to 

see how different price trends affect electricity 

prices and operating costs. 

 Finally – 

MR. BROOKMAN: Chris, go ahead. 

MR. JOHNSON: Chris Johnson. My question 

about the Electricity Price Forecast is we’re going to 

have a smart grid at some point. Pursuant to 

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applications and smart–enabled products and appliances, 

consumers are going to have dynamic pricing in place. 

Since there’s no dynamic pricing tariffs around or it 

is way too early to tell if there’s some type of 

national dynamic pricing model that you could look at, 

how would that factor into this? 

This would be subject to change, I would 

think, when NIST, DOE, all the standards development 

bodies, and the public utilities commissions start 

looking at dynamic pricing based on real–time use and 

peak/off–peak and all that. That’s radically different 

than what’s in place now. If you use what’s in place 

now for 2030, that’s not going to be true because there 

is going to be dynamic pricing in place. 

MR. ROSENQUIST: Right. If that sort of 

situation happens in the form of legislation, for 

example, then what DOE does is it actually tries to 

incorporate that within the forecast of the Annual 

Energy Outlook. 

I guess there’s a question of whether or not 

AEO can really forecast to reflect that level of 

detail, but until that legislation is actually on the 

books, the AEO won’t try to incorporate it. 

That’s a valid point. This is a forecast, 

right? It’s trying to forecast on what is known and 

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not what may happen in the future. 

MR. BROOKMAN: Ron Lewis. 

MR. LEWIS: Just augmenting that is DOE was 

directed through legislation to revisit the rulemakings 

and update the standards on a cycle every six years and 

the test procedures every seven years. Even though 

this would be putting a standard into place with the 

analysis that’s based on the best information that we 

have available that’s factual, we can’t be projecting 

for something that doesn’t even exist yet. We will 

have opportunities between now and 2030 to absorb new 

information and accommodate that. 

MR. BROOKMAN: Thank you. 

MR. ROSENQUIST: What I was going to say is 

that DOE also forecasts the price beyond 2030. The AEO 

only forecasts it out to 2030. What DOE does is 

extrapolation based upon the trend between 2020 and 

2030 because DOE needs to do this for the purposes of 

doing calculations in the national impact analysis. 

The next topic is product lifetimes. I’m 

going to turn it over to my colleague Asa Hopkins to 

talk about that. 

MR. HOPKINS: Thanks, Greg. I’m going to 

present now a new technique which DOE has developed for 

calculating product lifetime. DOE hopes this method 

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will provide accurate lifetimes for use in this 

rulemaking and potentially in other rulemakings, should 

it be appropriate. 

One of the pieces of data that RECS collects 

from each household about their appliance is its age. 

How many years ago was the appliance purchased. DOE 

can compare the existing stock of appliances of a 

particular age with the shipments of appliances that 

occurred in the year that those products were 

manufactured. 

Rather than characterizing the lifetime 

necessarily as one number and using a single number or 

a very simple distribution for characterizing product 

lifetime, what DOE really needs in a lifecycle cost is 

a survival function that says, of the products shipped 

in a particular year, how many will still be in 

operation 10 years after, how many 15 years after, 20 

years after, et cetera, so that those can all be taken 

into account in results and impacts on the lifecycle 

cost as well as on shipments projections. 

Rather than trying to get a single number, 

DOE fit the relationship between the historical 

shipments and the stock as reported by RECS to the 

distribution called a Weibulldistribution, which is a 

standard distribution used to characterize lifetime. 

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DOE was able to combine data from the 

previous five RECS surveys, 1990, 1993, 1997, 2001, and 

2005, to have enough data of the stock in different age 

bins to make a reliable fit. 

I apologize for the confusion of the figure 

on the bottom. That’s a figure that we used in 

evaluating the analysis, but it’s somewhat confusing 

for those who are just coming to the technique. The 

red curve there is the best fit refrigerator lifetime 

curve. 

Here are the Weibull distributions that 

characterize the mean lifetime for refrigerators and 

for freezers. DOE didn’t develop independent lifetime 

distributions for – this is all just for standard size 

products where RECS accurately characterizes what’s 

available and what’s in use and in stock. Rather than 

disaggregate this further into product class in the 

manner that DOE did in the energy use, DOE assumed that 

different product classes of refrigerators and freezers 

have comparable lifetime distributions. 

MR. BROOKMAN: Tom. 

MR. ECKMAN: How did you deal with the second 

refrigerator? You just asked them what the age of 

their primary refrigerator was, and that’s the fit 

through primary? 

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MR. HOPKINS: I think all of these RECS 

surveys that we’ve used ask the age of each and every 

refrigerator that’s present in the household, including 

the second. 

MR. ECKMAN: This is representative of the 

stock, the one plus saturation of the stocks. 

MR. HOPKINS: This is representative of the 

stock as a whole. Right. There are more refrigerators 

in American households than there are households. The 

average saturation is greater than one. 

Thank you for mentioning second 

refrigerators. We’ll get there in a moment. 

Before I move on from this, are there 

questions about this method, since it’s new and may be 

somewhat unfamiliar? 

MR. SEVERANCE: Martin Severance. Do you 

know what the beta value was for your Weibull 

distribution? 

MR. HOPKINS: I don’t know the number off the 

top of my head. The numbers are in the Technical 

Support Document. It’s a Weibull distribution with a 

delay, so it’s the three–parameter Weibull 

distribution. 

DOE also characterized the behavior of 

households converting their first refrigerator to a 

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second refrigerator and buying a new first 

refrigerator. DOE needed to take this into account to 

build an accurate shipments model. 

DOE undertook a similar fitting process with 

RECS to look at the stock of refrigerators of a certain 

age and evaluate what fraction are in use as first 

refrigerators and what fraction as second refrigerators 

and, again, modeled that conversion process with a 

Weibull distribution. 

The best fit curve is shown here in red. 

There’s a small offset at zero, which is actually 

statistically present in the data, which implies that 

some number of second refrigerators are bought new to 

act as second refrigerators. They are converted to use 

as a second refrigerator immediately upon purchase. 

The fraction of surviving refrigerators that 

are second refrigerators grows over time, as expected. 

 The second refrigerator stock is, on average, older 

than the primary refrigerator stock. 

For compact products, RECS and the Commercial 

Buildings Energy Consumption Survey do not provide 

enough data on the stock of products at different ages 

to apply that same method. DOE calibrated its lifetime 

Weibull distribution to best match the total stock 

that’s represented by those two surveys. 

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DOE first examined a lifetime of 10 years, 

which is the lifetime that was estimated by Appliance 

Magazine. If you apply that lifetime to the historical 

shipments, the stock would be much, much greater than 

the stock that’s actually reported in surveys. The 

lifetime with the best fit to the existing measured 

stock from the surveys is a compact lifetime of 5.62 

years. 

For compact freezers, DOE has even less data. 

 Compact freezers are not surveyed well by either RECS 

or CBECS. Even getting a total stock is a challenge. 

What DOE did for this stage of the analysis was simply 

assume that since standard size freezers live to be 

somewhat older than standard size refrigerator–

freezers, the compact freezers likely are in use longer 

than compact refrigerators by an equivalent factor. 

Simply multiplying that 5.62 by that factor that 

standard size freezers are observed to live longer 

results in a compact freezer lifetime of 7.46 years. 

Particularly because DOE has virtually no 

data to draw upon for that compact freezer lifetime, 

we’ve highlighted this in particular as an issue for 

comment and would welcome any data or information that 

anyone might provide that would allow us to build a 

more accurate and precise lifetime estimate for compact 

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freezers. 

MR. BROOKMAN: Do we have data? Do we have 

even anecdotal information on this? 

MR. HOPKINS: Compact freezers are less than 

seven and three–quarters cubic feet in size and less 

than 36 inches tall. 

MR. BROOKMAN: So, in your written comments, 

Debra, if there’s a way to – yes. Thank you. Chris, 

we can’t hear you. 

MR. JOHNSON: Chris Johnson. Maybe coach and 

bus operators that have custom coaches, and RV 

vehicles, and all that kind of stuff. If that’s what 

you mean by compact refrigerators. 

MR. HOPKINS: We’ll get into this in a little 

bit, but compact refrigerators are used both in homes 

and commonly in places like dorm rooms or hotel rooms. 

 We have very little data about even what the usage – 

who’s even using compact freezers. It’s a small enough 

product that it’s hard to ascertain. 

MR. von WENTZEL: Constantin von Wentzel. 

One manufacturer mentioned that funeral homes do use 

them. 

MR. HOPKINS: Greg is going to continue the 

rest of the LCC. 

MR. ROSENQUIST: I’m going to continue with 

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the inputs, moving on to the discount rates. The 

discount rates are used to – what they’re used for is 

to convert those future operating costs into a present 

value. DOE bases the discount rate on the finance cost 

of purchasing the product. 

There are basically two ways that DOE 

determines the discount rate from, which is the finance 

cost of using any debt to purchase that product or the 

interest rates associated with any opportunity cost 

from equity that’s used to purchase the product. 

For residential discount rate, DOE looks at 

the different interest rates associated with these debt 

and equity vehicles. To do that, they use what’s 

called the Survey of Consumer Finances. DOE looked at 

years extending back to 1989 to come up not only with 

the interest rates associated with these debt and 

equity vehicles but also the share in terms of dollars 

of each one of those debt and equity vehicles of a 

consumer’s household. 

Mashing all that data together, you get a 

weighted average value of 4.8 percent real. What’s 

used in the analysis is an actual distribution of 

discount rates that extend from almost 0 percent all 

the way up to around 20 percent of an interest rate. 

Yes. 

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MR. HALL: Dave Hall here. I have a question 

going back briefly, just quickly. The compacts as 

spoken in the previous for freezers, is that front door 

or chest or all–inclusive? 

MR. BROOKMAN: Asa, can you address that? 

MR. HALL: It doesn’t say. 

MR. BROOKMAN: Microphone, Asa. 

MR. HOPKINS: I’ll just say that the compact 

definition isn’t based upon whether the doors open from 

the front or from the top. Or, actually, it is. 

There’s a chest freezer category. 

MR. HALL: Yes, yes. 

MR. HOPKINS: Yeah. We’re talking about all 

chest freezers – I mean all compact freezers when we’re 

talking about the compact lifetime, yes. 

MR. BROOKMAN: Thank you. 

MR. HOPKINS: Sorry about that confusion. 

MR. ROSENQUIST: Getting back to discount 

rates to talk about the commercial rates, for those 

purchases that are made from commercial customers 

specifically for compact units, DOE used a weighted 

average cost of capital routine or technique. Again, 

what this does is it looks at the equity and debt 

financing of firms that are purchasing compact units. 

The weighted average value of that calculation was 6.2 

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percent. 

Never mind the word “check” there. That was 

something for us to do to make sure that that value was 

correct. 

 (Laughter) 

MR. BROOKMAN: Did it turn out okay? 

MR. ROSENQUIST: Yeah. 

MR. BROOKMAN: It turned out okay. Good. 

Put a check next to that. Okay. 

MR. ROSENQUIST: The next input are the 

repair and maintenance costs. The repair cost is the 

cost associated with actually replacing a component 

that’s failed in the product, while the maintenance 

costs are associated with just doing that regular sort 

of maintenance that’s needed to keep the equipment 

running efficiently. 

DOE did not assume any changes in the repair 

and maintenance costs due to increased efficiency. 

That leads to this next issue for public 

comment: DOE’s assumptions regarding repair and 

maintenance costs. That is, again, DOE assumed that 

there would be no change in repair and maintenance 

costs due to the increased efficiency of the 

refrigerator or freezer. 

MR. BROOKMAN: Debra Brunk. 

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MS. BRUNK: Debra Brunk, AHAM. I just wanted 

to respond to that. We disagree with DOE’s assumption 

that higher efficiency products would have similar 

repair and maintenance costs than lower efficiency 

products. It does depend on the technical approach 

that’s used to gain the higher efficiency, but 

typically, your higher efficiency products are going to 

contain more components. They’re more sophisticated 

components. For instance, we’ve talked about higher 

EER compressors, vacuum panels, those kinds of things. 

They also tend to incorporate more 

electronics, which actually helps them to be more 

energy efficient. 

You combine those all together, and if you 

have any kind of repair or replacement costs, those 

costs certainly go up. We believe DOE does have the 

data in your analysis, similar to what you did for the 

built–in evaluation, where you have the cost of 

different components that could be used in these 

different products to evaluate what that cost 

difference would be for replacement. 

Also, there are issues in terms of repair and 

maintenance regarding the expertise of the repair folks 

that need to deal with those products. We are working 

to see if we can find some additional information on 

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that also to provide to DOE. 

MR. BROOKMAN: Thank you. Other comments on 

repair and maintenance costs? Are you separating there 

repair from maintenance, Debra? 

MS. BRUNK: Yes. 

MR. BROOKMAN: That’s what I thought. Okay. 

 Let’s proceed then. 

MR. ROSENQUIST: I’m finally getting to the 

last input that goes into the lifecycle cost and 

payback period analysis. This is the efficiency 

distributions that are used in the base case. The base 

case means the case without any new efficiency 

standards. 

What DOE tries to do here is to accurately 

characterize how consumers are purchasing products 

without standards, in recognition of the fact that 

programs like Energy Star are already out there 

promoting the use and adoption of more efficient 

products. 

DOE does this in order to accurately do its 

LCC and payback period analysis so it doesn’t overstate 

the percentage of consumers that may benefit from an 

efficiency standard. Basically, it would show a 

consumer that’s already purchasing a product at a 

particular standard level as being not impacted so it 

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doesn’t factor into the actual distribution of winners 

and losers. 

DOE developed base case efficiency 

distributions for the seven product classes that were 

analyzed in the engineering analysis there and then 

being analyzed in the lifecycle cost and payback period 

analysis. 

These are the distributions. These are the 

distributions for standard size refrigerator–freezers 

and standard size freezers. The basis of the 

distributions are data provided by AHAM for the year 

2007. Now, because the standard doesn’t become 

effective until 2014, DOE has to make some estimates or 

assumptions about how those distributions may change. 

In the case of standard size refrigerator–

freezers, DOE assumes that current market share of 

Energy Star products, or that market share in 2007, 

would be maintained in 2014 even though the Energy Star 

level in 2007 was 15 percent below the baseline 

efficiency level and has now since moved to 20 percent 

lower than the baseline efficiency level. That’s the 

estimate that DOE did for standard size refrigerator–

freezers. 

As an example, you can see that the Energy 

Star level being 20 percent lower than the baseline 

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level, the 0.8 value represents 32 percent of the 

market for side–by–sides. That was the distribution 

that was assumed in 2014. 

For standard size freezers, the Energy Star 

level has not changed since 2007. DOE assumed that 

this efficiency distribution was maintained from 2007 

out to 2014. 

MR. BROOKMAN: Andrew. 

MR. DELASKI: I want to make sure I 

understand this right. In Line 3, or Baseline Level 3, 

80 percent, the current Energy Star – Energy Star was 

15 percent better than the basic standard. Now it’s 20 

percent, correct? 

MR. ROSENQUIST: That’s correct. 

MR. DELASKI: So, the market share in 2007 – 

I’m just restating what you said to make sure I’ve got 

it right – was the numbers that we see here in that 

line: 13 percent, 88 percent, 32 percent? 

MR. ROSENQUIST: That’s correct. 

MR. DELASKI: So, the assumption is that all 

those products that were efficient – that same market 

share, then, meets that new Energy Star level in 2014. 

MR. ROSENQUIST: That’s correct. 

MR. DELASKI: That strikes me as maybe 

plausible for the top–mount, but for the bottom–mount, 

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88 percent is an awful lot. That seems to me an 

ambitious assumption. A full third is Energy Star as a 

program, of course, is targeting to influence a quarter 

of the market. That’s one of the organizing principles 

of the program. So, it strikes me that those 88 and 32 

percent numbers need some more thorough consideration. 

MR. ROSENQUIST: Would you suggest limiting, 

then, that value to 25 percent because that’s the 

target of the Energy Star program? 

MR. DELASKI: We’ll comment on that in our 

written comments. 

MR. BROOKMAN: Steve. 

MR. CHURCH: I find it odd that you would 

make the assumption that 2007 for some magical reason 

is going to be the same as 2014. There are certain 

market incentives that are in place that cause 

manufacturers to have products at certain levels. Are 

we going to make the assumption, then, that Energy 

Star, when we put the 2014 standard in place, right 

away it’s going to be at 20 percent? What market 

incentive is going to cause a manufacturer to have 

products 20 percent below the 2014 standard? 

MR. ROSENQUIST: Just to be clear, this is 

supposed to represent the case without standards. This 

is the base case. This is under the assumption that no 

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new standards would take effect. We’re trying to 

create this base case from a point of reference to 

evaluate the standard level that does take place in 

2014. 

Does that answer your question? 

MR. CHURCH: Yeah, I think so. 

MR. ROSENQUIST: Okay. I’ll move on. This 

shows the distributions for compact units. This is 

similar to standard size freezers in that the Energy 

Star level is currently 10 percent better than the 

baseline level. Again, because that level hasn’t 

changed from 2007 until now, DOE went ahead and assumed 

that this distribution that you see here would remain 

constant until 2014. 

Now let’s look at some results from one 

product class. This is side–by–sides, Product Class 7. 

 What you’re seeing here is a distribution of the range 

of LCC savings for the various efficiency levels that 

were analyzed for side–by–sides. The hash marks 

represent the 95th and 5th percentile of that 

distribution. The top and bottom edges of the box 

represent the 75th and 25th percentiles of this 

distribution. The red is the mean value, and the blue 

dash is the median value. 

As you can see, focusing on the mean values, 

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there are lifecycle cost savings for every single 

efficiency level that were analyzed for side–by–sides. 

 The lifecycle cost minimum point is either at 

Efficiency Level 5 or 6. 

Then, these are the type of results that were 

generated for the simple payback periods. Again, 

similar plot. Everything is the same in terms of 

interpreting the hash marks and the edges of the boxes. 

 This just shows that, as you increase efficiency or go 

up in efficiency level, the payback period increases, 

which you would expect because the first cost 

increases. 

Now, this gets back to our discussion from 

before lunch about the usage adjustment factor. There 

were a lot of questions about the ability of using RECS 

to establish a factor that converts test energy 

consumption into field energy consumption. 

DOE was already thinking along the same lines 

and wanted to see what the sensitivity of the lifecycle 

cost results were to having a UAF that had, on average, 

a value of one. That is, keeping the variability that 

you saw from those distributions that Asa had presented 

this morning but having the mean value exactly at 1.0. 

 Again, on average, the test consumption equals the 

field consumption. 

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DOE did this for upright freezers and for 

side–by–sides. For upright freezers, the blue dots are 

the lifecycle cost as a function of efficiency level 

with the usage adjustment factor of 1.37. Those maroon 

squares show it with a value of one, normalized UAF. 

You can see in this case that it doesn’t really have an 

effect on where the minimum lifecycle cost occurs, and 

it doesn’t have an effect on the fact that all of the 

efficiency levels provide lifecycle cost savings. 

That’s not the case with side–by–sides. In 

side–by–sides, again looking at the value with the UAF 

of 1.43, you get all the standard levels giving you 

lifecycle cost savings, and the minimum lifecycle cost 

is at a level, I believe, of 0.65, which is 35 percent 

lower than the baseline level. 

When you use that normalized UAF, what 

happens here is that the last two efficiency levels no 

longer give you LCC savings and the minimum lifecycle 

cost point moves back to 20 percent lower than the 

baseline level. In one case in one product class, 

normalizing the UAF makes no significant difference, 

but in another product class it does. 

 So, questions. 

MR. BROOKMAN: Debra first. 

MS. BRUNK: This is Debra Brunk with AHAM. 

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All I would note is I think a 5 percent change in 

energy efficiency could be considered a significant 

change for a lot of our manufacturers. 

MR. BROOKMAN: Thank you. Andrew. 

MR. DELASKI: I just want to make sure I 

understand the charts properly. What’s on the Y–axis? 

MR. ROSENQUIST: The Y–axis is lifecycle 

cost. 

MR. DELASKI: It’s LCC as calculated by the 

LCC model. 

MR. ROSENQUIST: Yes. 

MR. DELASKI: So, the squares are with a UAF 

of one and the diamonds – I’m colorblind, so I go with 

the shapes. The diamonds are the UAF as shown in the 

superscript. 

MR. ROSENQUIST: Right. That’s correct. 

MR. BROOKMAN: So, say again what this shows? 

MR. ROSENQUIST: It shows that it depends on 

the product class, right? Going to a situation where 

the assumption is that the test energy consumption 

equals the field energy consumption, it may not have 

any effect on the lifecycle cost results, as in the 

case of upright freezers, but it could have a 

relatively significant impact for a product class like 

side–by–sides. That’s what it comes down to. 

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For example, if DOE was basing their policy 

decision on the next standard level on minimum 

lifecycle cost, with a UAF for side–by–sides you’d 

choose something along the lines of 35 percent lower 

than the baseline level. Well, with a UAF of equal to 

one, you’d get something at around 20 percent lower 

than the baseline level. 

Again, I have to qualify that. That’s if DOE 

were only to base its policy decision on minimum 

lifecycle cost. 

MR. BROOKMAN: You’re just illustrating how 

that analytic would work. 

MR. ROSENQUIST: Yes. 

MR. BROOKMAN: Thank you. That’s all. 

MR. ROSENQUIST: Don’t want to get in trouble 

for saying something like that. 

MR. BROOKMAN: Thank you. Other questions or 

comments surrounding this? Why don’t you go to the 

comment box? Invites comments and recommendations from 

interested parties on any other aspects related to 

lifecycle cost analysis. Most of you are familiar with 

the Department’s approach to this. 

 (No response) 

MR. BROOKMAN: Nothing additional? Okay. 

So, we’re going to move on to national impact analysis. 

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MR. ROSENQUIST: I’ll be turning it back over 

to Asa Hopkins to talk about the national impact 

analysis. 

SHIPMENTS ANALYSIS AND NATIONAL IMPACT ANALYSIS 

ASA HOPKINS 

 (PowerPoint presentation) 

MR. HOPKINS: Just a quick reminder of where 

we are on working our way through this diagram. Greg 

has just finished with the lifecycle cost payback 

analysis, which is one of the inputs to the national 

impact analysis, the other input being a shipments 

analysis, whose purpose is to forecast refrigerator and 

freezer shipments over the course of the analysis 

period. The analysis period for all of these analyses 

is from 2014 to 2044. 

The shipments analysis also includes a 

disaggregation of shipments into product classes and an 

evaluation of how that disaggregation may change over 

time. 

National impact analysis. The primary 

outputs of that analysis are an estimate of the 

national energy savings and a national economic input 

expressed as the national net present value. In order 

to do that, the Department also needs to estimate the 

change in efficiency distributions over time. 

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This just recapitulates how the analyses flow 

into each other and highlights the primary outputs, the 

national energy savings and the national net present 

value. 

To make it clear, national energy savings is 

calculated strictly for the period from 2014 to 2044, 

whereas the national net present value is calculated 

for products shipped during that period. 

This flow diagram shows how the Department’s 

shipments model is structured. The primary drivers of 

shipments are replacements of existing appliances and 

appliances going into new construction and new homes. 

The shipments from these two drivers combined are then 

compared with the historical shipments. For each 

category of appliance, different calibration factors 

are used to adjust. 

The four categories for which shipment models 

are derived and where national impact analyses are 

conducted are standard size refrigerator–freezers, 

standard size freezers, compact refrigerators, and 

compact freezers. The shipments calibrations are 

somewhat different for each. 

For compact refrigerators, the calibration 

factor is what share of the shipments are going into 

residential applications versus going into lodging or 

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other commercial applications. 

For standard size and compact freezers, the 

calibration is essentially growth in saturation: the 

homes that have not previously owned a standalone 

freezer that are purchasing a freezer. 

For standard size refrigerators, the 

calibration variable is the conversion to a second 

refrigerator and therefore increasing saturation. 

Once these are calibrated, that gives an 

estimate of the total shipments, and then those total 

shipments are disaggregated by product class market 

share to arrive at total shipment forecast by product 

class. 

One issue of particular analytical interest 

for the Department was forecasting the market shares 

within standard size refrigerator–freezers between top–

mount products and side–by–side and bottom–mount 

products. DOE developed a model that was based upon 

the historical growing share for side–by–side and 

bottom–mount products among homeowners, taking into 

account household income. The model approaches a limit 

at the end of the analysis period of approximately 46.5 

percent share for side–by–side plus bottom–mount. 

The data on the slide shows that the data 

that the Department used in developing this model. The 

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model is not simply a fit to this data. There is more 

explanation in the TSD following through that you may 

read at your leisure, but just to see how the model 

fits with the data provided both by RECS and by market 

share data provided by AHAM. 

We are particularly interested in comment on 

these forecast market shares, and you can read the full 

comment, if you’d like. 

MR. BROOKMAN: Debra. 

MS. BRUNK: Debra Brunk with AHAM. 

Preliminary evaluation would suggest that DOE’s 

forecasted shares look realistic. However, we do 

suggest that DOE actually split out shipments of side–

by–sides and bottom–mounts because those two are 

expected to grow at different rates here in the future. 

 AHAM has recently split those out as well. 

MR. HOPKINS: What the Department did for the 

preliminary analysis was to keep the relative 

proportion of side–by–side and bottom–mount equal to 

the most recent data from AHAM and unchanging over the 

analysis period. 

MR. BROOKMAN: You can see the comment box 

there. What do you think? Other comments? 

 (No response) 

MR. HOPKINS: Shall I continue? 

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Just to recap where the input data came from 

for the shipments model, the lifetime function used to 

determine replacements was the same as the lifetime 

function we described just a little bit ago. For new 

construction, the data comes from the forecast from the 

2009 AEO, the same most recent stimulus case. The new 

housing completions saturations in housing come from 

those five RECS surveys. 

In the commercial case, the new construction 

comes from forecast of new lodging and other commercial 

completions, and the saturations come from the 

Commercial Buildings Energy Consumption Survey as well 

as a survey that the American Lodging Association 

undertook of their membership. 

Historical shipments come from AHAM, from the 

AHAM Fact Book, and from Appliance Magazine. The 

shipments by product class come from AHAM as well as 

looking at the changing distributions over time in the 

Residential Energy Consumption Survey. 

Just one example category for standard size 

refrigerator–freezers. The shipments forecast is the 

blue dots, the red area are the shipments due to 

replacements, the brown is the shipments due to new 

construction, and the yellow is the shipments due to 

houses going from one refrigerator to two 

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refrigerators. 

MR. BROOKMAN: Jeff Harris. 

MR. HARRIS: Pardon me if you’re going to get 

to this. I didn’t see it looking ahead a couple 

slides, though. Has there been any noticeable trend, 

or are you anticipating any, in the average size of 

primary refrigerators? 

MR. HOPKINS: DOE did not take into account 

any trend in size. The sizes were assumed to be drawn 

from the same size bins as from the RECS 2005 survey. 

MR. HARRIS: I believe that there is data – 

certainly, there is a lot of experiential data, I 

think, among us – that over the last 20 years we’ve had 

a noticeable upward shift. Whether that’s somehow 

topping out I don’t know, but it might be something to 

look at. 

MR. HOPKINS: One of the things that DOE took 

into account in making this particular choice was the 

space in a countertop in a kitchen that limits the 

practicable size of many refrigerators, and the growing 

fraction over time of households with second 

refrigerators perhaps speaks to that trend. 

DOE also took into account in its shipments 

analysis in the standards case the impact of purchase 

price and operating cost through a relative price 

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elasticity. The relative price is this fraction shown 

here, which is the purchase price plus the present 

value of the operating cost divided by the household 

income. 

DOE has developed a model that it has used in 

other rulemakings as well for home appliances that is 

based on historical shipments, retail price, 

efficiency, and income data that implies relative price 

elasticity of minus–0.34, which means graphically that 

a 10 percent increase in relative price would result in 

a 3.4 percent drop in shipments. 

Published data also indicates that consumers 

become less sensitive to initial price changes over 

time and that relative price elasticity drops by 65 

percent over 10 years. 

These show the impacts in those four cases on 

shipments due to the increased price at different 

efficiency levels. Not all the levels are shown 

because there would be far too many lines to discern. 

But in each case, the lowest line is the most 

expensive, most efficient product. You can see that 

there are effects and that the significance of the 

effects varies somewhat by product. 

MR. BROOKMAN: Tom Eckman. 

MR. ECKMAN: Tom Eckman. So, is this effect 

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on shipments on the total or only on replacements? 

MR. HOPKINS: This is on the total. 

MR. ECKMAN: It seems to me in new 

construction the choice is to buy a standard compliant 

unit or not. 

MR. HOPKINS: Right. Yeah. 

MR. ECKMAN: So, it seems to me you 

overestimate the effect if you apply this elasticity to 

new construction. 

MR. HOPKINS: Okay. Yeah. I did not 

personally conduct this particular analysis. That may 

be taken into account. Greg may know or – 

MR. ROSENQUIST: I’m sorry. I didn’t hear 

the question. 

MR. ECKMAN: The question is whether the 

elasticity was applied to replacement units alone or to 

new construction. 

MR. ROSENQUIST: It was applied to both. 

MR. ECKMAN: I think that’s an overestimate 

because people are going to have to have a 

refrigerator, so price isn’t a question. 

MR. DELASKI: Doug, just a follow–on question 

on that. Again, what was the source of elasticity, the 

inputs for that calculation? 

MR. HOPKINS: DOE has conducted analysis for 

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home appliances in general, an in–house analysis on 

using the inputs listed here, looking at the impacts of 

previous price changes on shipments. Historically, as 

prices have changed, what has happened to shipments. 

MR. DELASKI: Looking at home appliances, by 

home appliances do you mean white goods? 

MR. HOPKINS: Home appliances in particular. 

White goods. 

MR. ROSENQUIST: The specifics on that, they 

looked at historical price, retail price, efficiency, 

and shipments data, as well as household income, going 

back on the order of, I believe, 20 years for clothes 

washers, refrigerators, and dishwashers. 

Again, we only had eight price points even 

though it spanned 20 years. To build up the data set 

from which to regress on, the decision was made to 

include all those appliances, just not restrict it to 

refrigerators. 

MR. DELASKI: Thank you. 

MR. BROOKMAN: Questions on this before we 

move on? 

 (No response) 

MR. HOPKINS: Moving on to discuss the 

national impact analysis, I’ll just recap a lot of what 

the inputs are to this analysis, which covers most of 

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the ground we’ve covered today. 

The first input is the total customer cost, 

which is the average per–unit values as a function of 

efficiency taken from the lifecycle cost analysis; the 

repair and maintenance costs, also carried forward from 

the lifecycle cost; the average energy use, also the 

average values from the LCC. 

I’m going to come back and discuss in more 

detail in a moment the efficiency forecasts. They’re 

summarized here, but I’ll give a much more detailed 

discussion in a moment. 

The average energy prices were taken from the 

lifecycle cost analysis, which gives a weighted average 

price over the country. The forecasts come from the 

AEO. The Department develops electric site–to–source 

conversion factors that convert kilowatt–hours at the 

home to Btus of primary energy going into generation. 

It calculates marginal heat rates using the same model 

that the AEO uses. The source factor is not constant 

over time. It changes based on the AEO forecast of 

different generation sources. 

The discount rate used was both 7 and 3 

percent real, which is following guidance from the 

Office of Management and Budget. All net present 

values are discounted to a present year, the year 2009. 

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Are there any questions on any of the inputs 

before I – 

MS. STEVENS: Amanda Stevens. I had a 

question. I’ve seen for a couple of different 

rulemakings there’s been the site–to–source conversion 

factors. It drops pretty dramatically in the next 

century, like on the order of 10,000 to 6,500. I don’t 

know the units. I looked briefly at the AEO and I 

didn’t see a description. I know it’s due to the 

changes in generation and what kind of electricity, but 

I’m just wondering if you had any further comment on 

what was behind that trend or what the AEO attributes 

that. 

MR. HOPKINS: I personally do not know. 

Generally, natural gas is a bit more efficient than 

coal. Renewables have different factors, et cetera. 

MS. STEVENS: Right. It just seemed like a 

dramatic – 

MR. HOPKINS: The marginals are going to be 

different than the average. It’s complicated, and I 

didn’t conduct that, so I can’t personally say exactly 

what’s going on. 

MR. BROOKMAN: Would the AEO reflect those in 

their forecasts? 

MR. HOPKINS: Our team at DOE is the same 

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modeling software that the AEO uses, but the AEO does 

not calculate the marginals. Our program uses the same 

tool to go a little bit above and beyond where AEO does 

in order to get the appropriate value for use in our 

analysis. 

MR. BROOKMAN: Amanda, if you think that’s 

relevant, you ought to see if you can find that and 

include it in your comments because there’s a long time 

between now and 2030. 

MR. HOPKINS: I’d like to go – yeah. Sorry. 

MR. DELASKI: If I could take you back to the 

elasticity slide for a second. I’ve been able to think 

more about that. 

I think a 3.4 percent decline or a 10 percent 

decline or increase in price, as I understand that now, 

it’s based on data from washers, refrigerators, and 

dishwashers. It strikes me that it likely overstates 

the impact for refrigerators because while consumers 

have other ways to wash their clothes, like go to a 

laundromat, and other ways to wash dishes, like hand–

wash them, there’s no other way to keep your food cold 

but to put it in the fridge. So, it does strike me 

that there’s some elasticity but that by bundling in 

washers and dishwashers we’ve likely overestimated the 

price elasticity of demand for refrigerators. Thanks.

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MR. BROOKMAN: Thank you. 

MR. HOPKINS: We’ll spend a few moments here 

on the forecasted efficiency distributions. As Greg 

described in the lifecycle cost for the base case, DOE 

assumed that the Energy Star market share would remain 

constant regardless of – well, as Energy Star may 

become more strict. There was a definition of Energy 

Star in effect from 2001, when the current standard 

became active, until 2008. 

The Energy Star market share grew over that 

period. A similar seven–year period, roughly, is the 

period between 2007 or ’08 and 2014, when the new 

standard would come into effect. DOE assumed that the 

Energy Star market share would follow that level to the 

20 percent level for refrigerator–freezers in 2014. 

In the absence of new standards taking effect 

in 2014, DOE forecasted that the Energy Star program 

would likely increase the stringency of its criteria 

again in 2014 and then it would take another seven 

years for the market share again to catch that new 

level. 

That’s shown here in this table of 2007 data 

from AHAM; 2014, the forecast we saw before with LCC; 

and 2021, where that same 32 percent Energy Star market 

share moves up another 5 percent in efficiency. 

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Again, this is for the case where there are 

no new standards coming into effect in 2014. So, in 

the standards case, DOE used what we termed a roll–up 

plus market shift model. At the introduction of new 

standards in 2014, DOE forecasts that the market share 

will roll up to the standard level. That is, any 

market share that was at the standard level or below 

would, in 2014, be at that level. 

Then, DOE, I think, forecasts that the Energy 

Star program will continue to exist and continue to 

promote more efficient products. DOE forecasts then 

that the market share in some new Energy Star level 

would grow between 2014 and 2021 again to levels 

comparable to the 2007 Energy Star market share. 

This slide is slightly inaccurate in that 

rather than Energy Star level being set at 20 percent 

across the board, it did vary by product class. The 

details are in the TSD. 

Then, similar to the base case, DOE forecasts 

that the efficiency distributions in 2021 are then 

fixed throughout the rest of the analysis period. It’s 

a little bit far out forecast the behavior of the 

Energy Star program more than 12 years from now. 

Just to take you through an example for 

Product Class 7, you can see the first column is the 

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base case, which we’ve seen before, of 2014 and 2021. 

I urge you to pick a particular level, say Level 2, 

from the standards case, see that the 25 and 43 percent 

market share that’s currently in the first two levels 

rolls up to Level 2 in 2014. Then, between 2014 and 

2021, that 32 percent Energy Star market share shifts 

out a level towards our estimate of where a new Energy 

Star level would be. That same behavior occurs in each 

standards case. 

In this way we are acknowledging the 

existence of the Energy Star program but not attempting 

to claim that energy savings that results from the 

Energy Star program is somehow a result of the 

standards. 

We welcome your comment on this forecast for 

efficiency distributions. 

MR. BROOKMAN: A specific request for comment 

here, should there be any. 

MR. HOPKINS: Of course, written comment is 

also valuable. 

 (No response) 

MR. HOPKINS: Just one example of the annual 

savings and cost results for a particular product class 

in this NIA. For Product Class 3 at Efficiency Level 

3, which is 20 percent, or the current Energy Star 

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level, you could see that the incremental product cost 

is shown negative, in purple, showing incremental 

negative costs growing over time as shipments grow. 

The maroon bars show the operating cost savings, which 

starts at zero because these are shipments starting in 

2014. It grows steeply and then more gradually as the 

stock saturates with products that meet the 2014 

standard. Then, in 2044, the analysis period ends and 

the operating cost savings continue because products 

purchased near the end of the analysis period are still 

in operation. 

Here are some examples of the output of the 

national energy savings and national net present value 

for a couple of product classes. The full tables are 

in the TSD. 

You can see the national energy savings for 

top–mount standard size refrigerator–freezers grow with 

efficiency, as expected. The net present value grows 

and then falls but does not go negative as the standard 

would become more stringent. For standard size upright 

freezers, the stock is smaller so that the total 

numbers are smaller. Of course, the costs are 

different that affect the NPV. 

MR. BROOKMAN: Yes, Amanda. 

MS. STEVENS: Just a point of clarification. 

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 From the last graph, if I’m not mistaken, the energy 

and cost savings are over that entire period. They 

don’t get chopped off at 2042? 

MR. HOPKINS: The national energy savings is 

calculated only for the period from 2014 to 2044. It 

does not include energy savings from products after 

that point. However, the national net present value 

does include the operating cost savings for those 

products. 

MS. STEVENS: Okay. Thank you. 

MR. BROOKMAN: The Department invites 

additional comments. Any other comments related to 

national impact analysis? Andrew, yes. Thank you. 

MR. DELASKI: Thank you. As the Department 

goes from the 2014 case to the 2021 case and the 

numbers shift up as the Energy Star program has an 

effect in moving the market, it isn’t that suddenly 

everything goes all at once in 2021 but you have a 

progression. 

MR. HOPKINS: It’s a linear transition from 

2014 to 2021. 

MR. DELASKI: A linear transition. Okay. 

Great. Thank you very much. 

MR. HALL: David Hall. On 137, the quads for 

each of these two classes or products, one, it’s 

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referenced to current standard as baseline. 

MR. HOPKINS: It’s referenced to the base 

case that I described, which includes the impact of 

Energy Star and the impact of Energy Star taking an 

additional action in 2014, et cetera. It’s not just a 

world in which everyone only has a baseline product. 

It’s relative to a base case that reflects the 

distributions of the market. 

MR. HALL: Over time. Does this include the 

field use? 

MR. HOPKINS: Yeah. This is based on the 

annual energy use outputs from the lifecycle cost 

analysis, which use the RECS–derived energy use. 

MR. HALL: Thank you. 

MR. BROOKMAN: Okay. A lot of data. Any 

other comments on this before we move on? 

 (No response) 

MR. HOPKINS: I’m going to turn it over to 

colleagues from Navigant Consulting, who are going to 

take you through the preliminary manufacturer impact. 

PRELIMINARY MANUFACTURER IMPACT ANALYSIS 

STEVEN STODDARD 

 (PowerPoint presentation) 

MR. STODDARD: Thank you, Asa. Just to 

reiterate, my name is Steve Stoddard. I’m with 

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Navigant Consulting, and I’ve been participating in 

most of the analyses, especially the engineering 

analyses and some of the preliminary manufacturer 

interviews that have taken place already. 

Starting with this page, as you can see, it’s 

sort of a step outside of the rest of the process. 

During this preliminary analysis stage, DOE has 

conducted the manufacturing impact analysis. It’s sort 

of a condensed version of the full manufacturing impact 

analysis. 

There are essentially three different phases. 

 The first phase is really to get an industry profile 

both to characterize the industry and to identify 

important issues for consideration. DOE went about 

this by conducting on–site and telephone interviews 

with manufacturers of these products. 

The second and third phases are going to be 

pursued a bit more deeply during the NOPR stage of this 

analysis. That includes an industrial cash flow model 

and a more full, complete interview questionnaire, as 

well as the complete manufacturer interviews, in order 

to get both qualitative and quantitative impact 

assessments. 

Some of the topics that were discussed 

through these initial interviews are shown here. The 

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interviews conducted by DOE represented manufacturers 

for most of the U.S. market. Over 90 percent of the 

market was represented for standard size product 

classes by the manufacturers that were interviewed. 

These manufacturers represented over 80 percent of the 

market overall, as well. Again, here in the chevrons 

you can see the six key topics that were discussed. 

Just to cover some of the key issues that 

were identified by the manufacturers, the first one was 

increase in conversion costs. Manufacturers stated 

that conversion costs will be high if new standards 

require platform changes. These would be changes such 

as increased wall thicknesses for insulation or the use 

of vacuum insulation panels. 

The costs will vary by manufacturer, but low–

volume manufacturers probably would see increased costs 

on the order of a few million to tens of millions of 

dollars, whereas high–volume manufacturers could see 

costs increase on the order of hundreds of millions of 

dollars for these conversion costs. 

The impact that that would have on U.S. jobs 

could be significant in certain situations. 

Significant cost increases could result in the 

construction of new plants, which manufacturers stated 

would be likely to be constructed in places like 

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Mexico, where they could take advantage of lower labor 

costs. 

Two of the other key issues that were 

identified were cumulative regulatory burden and the 

impact on product utility. In regards to the 

cumulative regulatory burden, manufacturers stated they 

expect a climate change bill to be passed sometime in 

the near future. There is a variety of pending 

legislation in Congress that could likely impact 

greenhouse gases. 

Recent findings by the Environmental 

Protection Agency suggest that there could be other 

ways in which these GHGs could be regulated and may 

even be more likely to push the pending legislation 

through Congress faster and could be more broad–

reaching. 

The current proposals in Congress would 

essentially cap emissions from manufacturers and would 

then go through a sliding scale over a period of time, 

which would require the substitution of alternatives in 

place of the GHGs. For instance, HFCs used for 

refrigeration as the refrigerant and as foam–blowing 

agents would have to be switched over to alternatives. 

As identified earlier in this discussion 

today, hydrocarbons are one of the most viable 

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alternatives, but there are some issues with these, as 

we discussed earlier, both safety issues as well as 

cost. Manufacturers identified that the cost to meet 

the safety requirements within their plants would be 

fairly significant in order to make hydrocarbons 

available as refrigerants. 

Additionally, changing energy efficient 

standards in Canada and consumer safety regulations in 

Europe present additional regulatory burdens for 

manufacturers as well. 

Finally, manufacturers mentioned that there 

could be a significant impact to product utility. 

Significantly increased standards could result in, as 

mentioned, increased wall thicknesses, which would most 

likely have to reduce the available storage volume 

internally for the units. This is because, 

increasingly, refrigeration products are being boxed 

into specific dimensions and the only way to increase 

the thicknesses would be to go into the unit. This 

presents a decrease in product utility for many 

consumers. 

Manufacturers also mentioned other features 

would have to be removed or potentially, depending on 

the levels at which the standards were set, such as ice 

and water dispensers, soda can dispensers, glass doors, 

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and anti–sweat features. 

All these things that have been covered are 

just key issues that were identified. We recognize 

there are some other specific areas that were not 

covered here in the presentation, but these are 

discussed further in the TSD. 

DOE welcomes at this time any additional 

concerns that are not expressed either here or in the 

TSD that manufacturers may have. 

MR. BROOKMAN: Jeff Harris. 

MR. HARRIS: I’m happy to do some offline 

homework, but I wonder if you could comment, or some of 

the manufacturers might give us a couple of words about 

what the effect is on total consumption of differential 

temperature zones. It’s not obvious to me, the first 

order. Second, the relationship between safety 

requirements in Europe and the U.S. market. 

MR. STODDARD: My understanding, just in 

regards to the second point, is cumulative regulatory 

burden is in regards to any regulation that would be 

taking place that manufacturers would face, whether 

it’s in the U.S. or abroad. Meeting a variety of 

standards could make it more difficult to meet 

increased efficiency standards within the U.S. 

MR. BROOKMAN: Andrew. Let’s let Jennifer 

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speak first. 

MS. AMANN: The pending legislation on energy 

and climate also includes significant tax breaks for 

manufacturers to upgrade their manufacturing lines for 

higher efficiency products. I’d like to ask if that’s 

been a part of the analysis or if it will be going 

forward. 

MR. STODDARD: That’s a good point. Thank 

you. That has not been taken into account, but that is 

certainly something that could be in future. 

MR. BROOKMAN: Andrew. 

MR. DELASKI: This is more of a general 

question for the next phase of the MIA and how it’s 

conducted and what the approach is, which is that the 

last refrigerator standard was negotiated. I think it 

was a negotiated standard. In 1997 it was completed, 

and the final rule went into effect in 2001. When this 

next one goes into effect, it will have been 13 years 

between standards’ effective dates. 

I believe I read somewhere the production 

capacity that would have been put in place for that 

2001 standard will be fully amortized or at least close 

to fully amortized by the time 2014 rolls around. 

It strikes me that manufacturers are going to 

be having to replace plants and equipment to make 

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refrigerators whether there’s a new standard in 2014 or 

not. How is that sort of business cycle or plant life 

taken into account in the MIA, the fact that some of 

these lines, some of these plants, are going to have to 

be refurbished and rebuilt in this time frame anyway? 

MR. STODDARD: Constantin, would you like to 

address that? 

MR. von WENTZEL: Constantin von Wentzel 

here. I think you have to distinguish between 

investments that were made to meet the 2001 standard 

and ongoing investments required to keep a plant in 

operation. Just because a plant made an investment 13 

years ago doesn’t mean that it didn’t need to make 

investments in the meantime. 

The kinds of investments that we’re talking 

about when you start looking at changing wall 

thicknesses, for instance, really go to the heart of 

the entire manufacturing operation. You’re talking 

about very large, very specialized foam machines and a 

great deal of fixtures and other pieces of equipment 

that would have to be modified or changed out 

altogether. 

You combine that with other things like 

trying to address flammable refrigerants or foaming 

agents, and you may have to start over completely. For 

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instance, for a flammable foaming agent, you have to 

have buffered layers of security around that station to 

ensure that if there was an explosion – to prevent an 

explosion, in other words. 

You may actually be looking at redoing plants 

entirely from the ground up and just building a new 

plant next to the old plant because it’s probably not 

practicable to upgrade the old facility because of all 

the things that are around the foaming stations at the 

present time. 

MR. DELASKI: Yeah. I understand that. I 

anticipate that this standard would result in 

significant requirements on manufacturers to make new 

investments. My point is more that we have to be 

careful in doing the MIA. I urge the Department to be 

careful in disaggregating incremental impacts due to 

the standards. 

MR. von WENTZEL: That’s an excellent point. 

MR. DELASKI: Because there is a lot of 

investment that’s going to happen in the base case for 

just the reasons that investments have happened since 

2001. I know it hasn’t been a static environment since 

then. In fact, I keep a folder of manufacturer 

announcements of plants being changed and moved, which 

have happened quite a bit since 2001. So, there have 

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been changes and investments since then along the lines 

of what you describe here, generally moving plants from 

U.S. facilities to Mexico. That’s been happening. 

These investments have been happening, and 

they will continue to happen with or without standards. 

 I think part of the challenge for DOE is to 

disaggregate the base case from what would happen with 

the standards and not attribute to the standards things 

that would happen anyway. 

MR. von WENTZEL: Correct. Constantin von 

Wentzel again here. I completely agree with you, and 

it’s a very good point. If you could share that data 

with us, I think it would certainly make our questions 

to interview manufacturers a little bit more pointed. 

If you could supply that data of plant closings and 

movings and so on and so forth. 

I think it is a very, very good concern. But 

to disaggregate it I think would be very, very 

difficult because one could make the argument, and I’m 

not saying this is the case, that this manufacturer may 

make a decision to close a plant and use the standard 

as a convenient reason to do so. There’s really no way 

for us to disaggregate that. 

MR. BROOKMAN: Ron Lewis. 

MR. LEWIS: I’d be interested, Andrew. 

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You’ve got a collection now over the last few years of 

announcements of factories relocating or rebuilding or 

something; is that what I understood? 

MR. DELASKI: Sure. 

MR. LEWIS: How we connect in a 

disaggregation exercise the prior statement you made 

about it had been 13 years since the last standard if 

in all these recent investments they’ve just removed, 

retooled, got new major investments into a new factory, 

they’ve relocated, tying together those two seeming 

opposing issues, one of the total depreciation because 

of 13 years versus the recent changes. 

MR. DELASKI: I think part of it has been 

consolidation of production, particularly in the last 

couple years as sales have declined. 

MR. LEWIS: Yeah. I think there has been a 

fair number of complete relocations and moves as well. 

 Any input you’ve got in that area would be helpful 

because it seems like there are two different dynamics 

here that are counter–opposed in how we weigh those and 

give consideration to both. Any insights you have 

would be helpful. 

MR. BROOKMAN: You can see the comment box 

still up there on the screen. Any other comments 

related to preliminary manufacturer impact analysis 

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before we move on? 

 (No response) 

MR. STODDARD: This time I’ll turn it over to 

my colleague Greg Rosenquist. 

NOPR ANALYSES 

GREG ROSENQUIST AND JEFF KINGMAN 

 (PowerPoint presentation) 

MR. ROSENQUIST: We’re in the homestretch 

here. We’re going to go over briefly the analyses that 

are going to be required for the NOPR, the notice of 

proposed rulemaking. This is about what DOE is going 

to be doing in the future. It’s no longer about what 

DOE had done for the preliminary analyses. 

As you can see here, there are several steps 

to conducting all the analyses for the NOPR. The first 

is revising the preliminary analyses based upon 

stakeholder comment. Next is to conduct a lifecycle 

cost subgroup analysis, then to do the manufacturer 

impact, utility impact, employment impact, the 

environmental assessment, and the regulatory impact 

analyses. 

The next slide you’re going to see is on 

revisions to the preliminary analyses. Again, the 

revisions are conducted on the engineering and 

lifecycle cost, the national impacts analysis, and all 

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the related analyses that you’ve all heard discussed 

here, including the energy use markups, and also 

elements of the manufacturer impact. 

The basic step here is to review all the 

comments that come in, summarize them, identify all the 

issues, and then determine which ones have to be 

addressed analytically. After that determination is 

made, the necessary revisions are made to the 

engineering, lifecycle cost, payback, and national 

impacts analysis. 

The next step in the NOPR phase is to conduct 

the lifecycle cost subgroup. Its purpose is to 

determine whether or not there are any subgroups or 

subpopulations that may be disproportionately impacted 

by the standards. 

The method that’s utilized is to use the same 

tools that are being used to conduct the lifecycle cost 

and payback period analyses, with the exception that 

many of the inputs are honed down to the type of 

subgroups that DOE has determined that they want to 

analyze. 

Possible subgroups for this analysis for 

refrigerators and freezers include low–income 

households and not small businesses but senior 

citizens. 

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The output is the same as the lifecycle cost 

and payback period analysis. It’s a distribution of 

lifecycle cost savings, distribution of paybacks, and 

again, it’s for each standard level that’s being 

analyzed. From that, again, DOE can determine, in the 

particular subgroups that have been identified, whether 

those impacts are any different than the general 

population. 

This slide highlights the fact that DOE is 

especially sensitive to increases in purchase price 

that may affect particular subgroups, particularly the 

ones I just identified, seniors and low–income. DOE 

takes those price impacts that occur from a standard 

and make sure to evaluate them properly when looking at 

consumers who may not be able to afford a more 

efficient product. 

MR. BROOKMAN: Jeff Harris. 

MR. HARRIS: Greg, you might be getting to 

this, but it seems to me another subgroup worth 

considering might be the nonresidential uses. You 

mentioned subcompact fridges. There’s also some number 

– I don’t know what the actual number is. You may have 

looked at this – of standard size refrigerators in 

office kitchenettes and so forth. A fair number of 

those are around. 

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My gut feeling is that the purchase price on 

average may be lower than the customer purchase price 

because you have buying power and volume and so forth, 

especially, for example, DOD buying many fridges for 

shipping overseas and barracks and so forth. I’m not 

sure of this, but I suspect that the retail price on 

average may be higher because it’s commercial rates, 

not residential rates. So, you might find a very 

different kind of economics for that subset of 

residential products that’s not in fact in homes. 

MR. ROSENQUIST: Again, as we discussed 

earlier, DOE has addressed the use of compacts in 

commercial buildings but hasn’t done that for the 

standard size equipment. On that note, DOE is really 

looking for any data that would indicate the prevalence 

of standard size equipment in commercial applications. 

MR. HARRIS: There is, as I’ve just heard 

recently, a study of miscellaneous electric loads that 

the Buildings Office in the Commercial Unit has 

commissioned, I think at LBNL, but I’m not sure about 

that, to look at not just refrigerators but other kinds 

of loads in commercial buildings. There might be data 

within the time frame of interest. 

MR. BROOKMAN: Thank you. Ron Lewis. 

MR. LEWIS: If I understand the question that 

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Jeff posed, or the suggestion, we already have the 

shipment data that would include all those products, 

correct? The shipments that we got from the factories 

regardless of where they end up in application. We’ve 

already got some of the information. It’s just in the 

economics on this subgroup, then parsing the shipment 

data to what’s actually going into residences versus 

others. Is that, Jeff, what you were asking for? 

MR. HARRIS: Yeah. I guess what I’m 

suggesting is it might be worth looking at the 

nonresidential applications as another subgroup of 

interest because I think the economics may be different 

on both sides, both on the purchase price and on the 

energy costs, non–res versus res. 

MR. BROOKMAN: Thank you. 

MR. ROSENQUIST: Okay. I’m going to move on 

and talk about the next step. Before conducting all 

the other analyses, what DOE has to do is establish 

trial standard levels. The reason why DOE selects 

trial standard levels is to produce a set of more 

limited standard levels which can then be analyzed in 

all the downstream analyses, including the manufacturer 

impact, the employment impact, and so on. 

Each trial standard level consists of a 

candidate standard level from each product class. In 

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our case, in the case of refrigerators, freezers, and 

compacts, there are numerous product classes, and a 

trial standard level would consist of a unique standard 

level from each one of those product classes. 

The basis of the type of standard levels that 

are assigned to a trial standard level are based upon a 

set of criteria. That set of criteria could be, for 

example, the standard level with a minimum lifecycle 

cost or a standard level with a payback period of three 

years or a standard level that has a unique type of 

technology. 

Again, what DOE does in setting up these 

trial standard levels is, first, establish the criteria 

in which to draw candidate standard levels from to 

produce that trial standard level. 

In general, DOE analyzes for each product 

class around eight candidate standard levels. When it 

goes to do the manufacturer impact analysis and the 

other downstream analyses, there are a limited set of 

trial standard levels that consist, again, of the 

candidate standard levels from each one of the product 

classes. 

Does anyone have any questions about that? 

Okay. 

MR. BROOKMAN: Chris. 

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MR. JOHNSON: So, what you’ve just described 

to me, as a layman that’s not really familiar with all 

this, is that you have a set of trial standard levels 

and you try and figure out which ones are realistic and 

which ones are not; is that right? For each product 

class? Which ones are attainable and which ones are 

not attainable based on all the criteria that you have 

to meet. 

MR. ROSENQUIST: Well, yeah. Again, DOE sets 

up a criteria for establishing what the trial standard 

level is comprised of, what candidate standard levels 

from each one of the product classes a trial standard 

level is comprised of. First, it sets the criteria. 

For example, minimum lifecycle cost is one. 

That trial standard level then would consist 

of each candidate standard level from each one of the 

product classes that had the minimum lifecycle cost. 

Then there are other types of criteria. For 

example, let’s create – 

MR. JOHNSON: How are the criteria evaluated? 

 Equally? 

MR. ROSENQUIST: After the trial standard 

levels are developed, they’re then analyzed. At that 

point, DOE looks at those trial standard levels and 

then makes a decision on which one to propose. 

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MR. BROOKMAN: Ron Lewis. 

MR. LEWIS: There are seven statutory 

criteria we have to consider. It comes down to 

basically, we start at the top and we work our way down 

from the – it has to be technologically feasible and 

economically justifiable, so we’re coming down through 

those trial standard levels with that criteria also 

with the seven criteria in the statutes that we have to 

consider. We actually have a mapping of the statutory 

criteria to the actual analysis that we do to fulfill 

them. 

I think what Greg was addressing was how we 

build that portfolio and populate it with the 

individual TSLs, and then the actual decision point is 

later on, after we’ve populated it on the basis that 

he’s describing. We start at the top and work our way 

down to stop at that point where it meets the required 

criteria, which is set by Congress, not by us. 

MR. BROOKMAN: Just for your reference, on 

Page 11 in these slides those seven EPCA factors are 

listed. 

MR. JOHNSON: I guess I would argue that you 

need a test procedure to do that, but that’s another 

story. 

MR. BROOKMAN: Thank you. 

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MR. ROSENQUIST: This slide is just to 

solicit comment on this issue of selecting the 

appropriate criteria to establish trial standard 

levels. 

Does anyone have any additional comments on 

the selection criteria? 

MR. BROOKMAN: Andrew. 

MR. DELASKI: You’re looking for suggestions 

on selection – yeah. I was a little surprised to see 

that, on your prior slide, you did not have the maximum 

cost effective level. 

MR. ROSENQUIST: Oh, yeah. The max tech 

level is always – 

MR. DELASKI: Not the max tech level but the 

maximum cost effective level. 

MR. ROSENQUIST: Oh, the maximum cost 

effective – 

MR. DELASKI: That is the level that would 

generate the maximum energy savings and also be cost 

effective to the consumer, which max tech likely 

doesn’t fulfill in some instances. The law now says 

the maximum level of energy savings. That is whatever 

Ron just said. 

MR. BROOKMAN: Cost effective and 

technologically feasible. 

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MR. DELASKI: I think that you would 

certainly want to evaluate that level that met the high 

level description in 325(o). 

Then, the minimum LCC I think certainly makes 

sense. That’s one that typically is analyzed. I 

suspect that you’ll need a gap–fill between those two, 

between minimum LCC and maximum cost effective. I 

don’t know that you need to go much lower than Energy 

Star. That would be my guidance. 

MR. BROOKMAN: Kelly? 

MS. KLINE: This feeds off a comment I made 

earlier, I guess, about the difference in the most 

energy efficient level max tech. I’m assuming that’s 

based on the earlier numbers that were really based on 

kind of theoretical max tech rather than max tech that 

are actually observed in the market. I guess that 

would be my suggestion here. I don’t see anything that 

reflects the max tech as actually observed. 

MR. BROOKMAN: David. 

MR. HALL: David Hall. With the trial 

levels, is it to be conducted or carried out over those 

same seven representative classes as has been carried 

out through this? 

MR. ROSENQUIST: Again, I’m trying to make 

this distinction. There’s the candidate standard 

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levels that are considered for each product class. 

Some of those candidate standard levels, though, go 

into comprising the trial standard level. 

Let’s say, for example, that we want to use 

minimum lifecycle cost as a criteria to establish a 

trial standard level. Then, DOE would choose that 

candidate standard level from each one of the product 

classes that met that criteria. It could be Candidate 

Standard Level 3 from one product class, Candidate 

Standard Level 2 from another class, Candidate Standard 

Level 6 from another class. All those candidate 

standard levels are assembled into the trial standard 

level. 

MR. HALL: Thank you. 

MR. ROSENQUIST: Now it’s up to Jeff Kingman 

here to talk about the manufacturer impact analysis. 

MR. KINGMAN: Earlier, you heard from my 

colleague that took you through some of the preliminary 

findings that took place that we found from our 

previous interviews. I’m just going to take you 

briefly through the steps DOE takes to conduct the NOPR 

phase of the rulemaking or the manufacturer impact 

analysis during the NOPR phase. 

The main purpose of the manufacturer impact 

analysis, or MIA as we abbreviate it, is to conduct an 

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analysis to figure out the impact of the standards on 

manufacturers of the products. During this rulemaking, 

we also choose to identify some subgroups that could be 

more affected than the overall industry. 

The most important part of the manufacturer 

impact analysis is the industry net present value, or 

INPV. That’s a representation of the impacts on the 

industry caused by a standard. 

The main output is obviously, like I just 

said, the INPV. We also use the manufacturer impact 

analysis to report some of the qualitative impacts that 

could occur. 

This slide just shows that there are three 

main phases during the NOPR phase to conducting the 

MIA, and I’m going to go through those in detail now. 

The overall impression now, and you might 

have gotten already, is that the manufacturer impact 

analysis is conducted in conjunction with the other 

rulemaking or the other analyses. For instance, on 

this slide, you can see that the shipments from the 

national impact analysis feed into our cash flow model. 

 Also, the costs from the engineering are obviously an 

important part of the cash flow for the industry. 

The first phase we already briefly touched on 

this morning, or this afternoon, but we go through and 

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look at all the publicly available information. We 

look at such things like 10-Ks of companies that make 

the covered products, things like that. Some of this 

was already also reported in the market and technology 

assessment, but we also go through and look at any new 

information that has become available. 

In the second phase, we use the inputs we 

have from public information and put it into our actual 

cash flow model to get a general idea of what we think 

the impacts might be. As I said, down at the bottom 

you can see the main output from our cash flow model is 

something called industry net present value, or INPV. 

In the second phase, we also create an 

interview guide that we will use to conduct interviews 

with manufacturers. Down here are some of the topics 

that we usually include. I just also want to add that 

we also plan on updating some of these topics to 

include things that have come up during today’s meeting 

and that you’ll be submitting in your written comments, 

too. 

Importantly, we are looking to conduct these 

interviews as soon as we can. The comment period 

closes in a few weeks. Like I said, once that does 

close, we’re going to look at the information that has 

been submitted and that we’ve learned here today to put 

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together an interview guide that we are going to send 

to manufacturers. 

We do really appreciate any information you 

do share with us, and we offer up the nondisclosure 

agreements to all manufacturers that we do interview 

because we want to give you an opportunity to disclose 

information that you might not be comfortable sharing 

in public. That kind of information is really helpful 

for some of the inputs to the cash flow model. 

Finally, the final way that we finish up the 

NOPR analyses is, besides just the industry–wide 

impacts, we also go back and look at the impacts on 

some of the manufacturer subgroups that might be more 

impacted. One of the things we’re required to look at 

by law is the impact on small businesses, so that’s one 

of the things we usually do look at. After that, we 

write up all the findings that we do and do a final run 

on the cash flow model and put it together for the 

documentation for the notice. 

If anyone has any questions on what we 

typically do for that? 

 (No response) 

MR. ROSENQUIST: Let’s resume the NOPR 

analysis steps with the utility impact analysis. Its 

purpose is to determine the effect of standards on 

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electric utilities, basically their sales and the peak 

demand that they have to serve. 

The basic methodology is to take the national 

energy savings that comes from the national impact 

analysis for each standard level and then feed it into 

what’s called the National Energy Modeling System, or 

NEMS. This is the federal government’s official energy 

economic model. This is also used to product the 

Annual Energy Outlook. 

NEMS produces what’s called a reference case. 

 What DOE runs then by implementing these national 

energy savings from the various standard levels is a 

standards case. That standards case shows DOE the 

change in electricity and sales by region, how these 

standards affect the mix of generation and also the 

installed generation capacity. 

Are there any questions on that? I flew 

right through it. 

MR. BROOKMAN: Jeff. 

MR. HALL: Pardon my ignorance on this, Greg, 

but does that analysis also show the dollar capital 

cost for new construction? Does it include T&D as well 

as generation? 

MR. ROSENQUIST: No, it does not. It doesn’t 

look at the financial impacts to the utility sector. 

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It doesn’t look at how transmission distribution may be 

affected. 

MR. BROOKMAN: Tom. 

MR. ECKMAN: This is Tom Eckman. Is that a 

statutory constraint or just a scope constraint? 

MR. ROSENQUIST: It’s a NEMS constraint. 

That’s what NEMS output provides. It doesn’t actually 

show how – basically, NEMS is an equilibrium model. If 

there is demand, there will be supply. In that sense, 

then, there’s no real analysis of how transmission and 

distribution would be affected. That’s how I 

understand it. 

MR. ECKMAN: Both T&D as well as generation. 

 So, you get an output from NEMS that’s – 

MR. ROSENQUIST: On installed generation 

capacity. 

MR. ECKMAN: And how much that’s offset by 

the standard. 

MR. ROSENQUIST: The standard, right. 

MR. ECKMAN: The question that Jeff raised 

is, is that priced or you just know magnitude? 

MR. ROSENQUIST: Just magnitude. In giga 

watts, for example. 

MR. ECKMAN: It seems to me there’s a lot of 

net present value hanging on that particular analysis. 

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 We spend a lot of money on new generation. One of the 

purposes of doing these standards is not to spend a lot 

of money on new generation. If we’re not capturing 

that, we’ve missed a considerable amount of the 

benefit. Is that a scope or is that a statute 

constraint? 

MR. ROSENQUIST: I don’t really know. I’d 

have to get back to you on that. 

MR. ECKMAN: If it’s not a statute 

constraint, it certainly ought to be in the analysis. 

MR. BROOKMAN: Thanks, Tom. 

MR. ROSENQUIST: In reply to that, I would 

say that in some degree the electricity pricing should 

try to account for the – 

MR. ECKMAN: You’re only seeing the benefits 

of the participants here, not the nonparticipants. 

Part of that cost is being borne by non–refrigerator 

owners, so we’re missing a bunch of the cost. 

MR. BROOKMAN: Are you in this same spectrum? 

 I’ve got other people who want to follow on here. 

MS. STEVENS: Well, I had two points. 

MR. BROOKMAN: Hang on, then. Chris and then 

Jeff Harris. Jeff first. 

MR. JOHNSON: Oh, I’m sorry. 

MR. BROOKMAN: Jeff, go ahead. 

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MR. HARRIS: I think that NEMS can give you, 

of course, some differential in average prices based on 

growth rates. They have a high growth, low growth, and 

a base case, and a lot of other excursions. You can 

get total cost, I think, capacity cost, out of NEMS. 

You may have to do some interpolation without doing 

special runs. 

But I’m kind of on the same wavelength as 

Tom, I guess. It seems like it’s worth looking at. 

MR. BROOKMAN: Chris. 

MR. JOHNSON: Chris Johnson. My comment 

would be that, with that limitation, NEMS is going to 

have to be radically redone within five or six years 

due to smart grid and demand response. That completely 

changes the whole shape and size of electric utilities 

in consumption and peak load demand, which would also 

reflect price both for them and for consumers. 

Anything that doesn’t account for that, I 

would say, by 2014, it’s hard to really get a real 

solid number or any type of accuracy. 

MR. BROOKMAN: Thank you. Amanda. 

MS. STEVENS: I just wanted to follow up and 

just echo Tom’s point that that was a really good 

observation. 

Then, the second thing I was wondering is, I 

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know DOE usually presents energy savings in terms of 

quads over the 30 years of the analysis. I was 

wondering if it would be possible to also show that in 

terms of the annual energy savings that are accruing 

across the country. That’s usually something that’s 

not real explicit in the write–up. 

MR. ROSENQUIST: That’s correct. The last 

TSD for refrigerators showed just the cumulative 

savings. 

MS. STEVENS: Yeah. It would be great for us 

to be able to see that over time. 

MR. BROOKMAN: Is that easy to do? 

MR. ROSENQUIST: Yes. It can be generated, 

it just typically hasn’t been. 

MR. BROOKMAN: Other comments on this 

segment? 

 (No response) 

MR. ROSENQUIST: On to the next analysis 

phase, which is the employment impact analysis. Its 

purpose is to estimate the effect of standards on 

national employment. What’s used here is a spreadsheet 

model called EMSIt. You can see what the semi–acronym 

stands for. This is a model that was developed by the 

Pacific Northwest National Laboratory. 

Again, it’s meant to analyze the indirect 

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effects from changes in consumer expenditures and 

changes to revenues, for example, from utilities as a 

result of standards. It tries to propagate those 

changes throughout this energy economy to see what sort 

of effect it finally has on jobs throughout the 

country. 

We do want to make the point that the direct 

employment impact to manufacturers is analyzed in the 

manufacturer impact analysis. 

Again, the output is this change in jobs or 

national employment due to these changes in consumer 

expenditures and, for example, changes in revenues to 

utilities. 

MR. BROOKMAN: Comments on employment impact 

analysis? 

 (No response) 

MR. ROSENQUIST: Next is the environmental 

assessment. Its purpose is to determine the impact on 

power plant emissions, airborne emissions, from these 

various standards that are being analyzed. 

The same tool is used here as for the utility 

impact analysis, and that’s NEMS. Again, the same 

process is used. DOE takes the national energy savings 

corresponding to these various standard levels and puts 

them into NEMS to see how the emissions from power 

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plants are affected. 

The output from that are the emission 

reductions due to the standards on sulphur dioxide, 

nitrogen oxides, carbon dioxide, and mercury. 

The other thing that’s been done recently in 

the environmental assessment is to value these 

emissions. This is what the next issue for public 

comment is. 

Again, as I just noted, very recent 

rulemakings have put a dollar value on the emission 

reductions. Specifically for CO2, for example, a range 

of $5 to $55 per ton has been used to value these 

emissions. 

DOE is looking for any comment on the 

specific topic of monetizing these emission reductions. 

MR. BROOKMAN: Andrew. 

MR. DELASKI: I’ll just briefly comment. 

We’ll comment more in detail in the written comments. 

I think the Department has made enormous progress in 

this area in the past year. We’ll comment on the 

specifics in the written comments. 

MR. BROOKMAN: Do you wish to offer now what 

should guide their pricing? 

MR. DELASKI: No, we’ll do it in the written 

comments. 

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MR. BROOKMAN: Okay. Thank you. Additional 

comments? Yes? I see none. Okay. Oh, yes. Debra. 

MS. BRUNK: This is Debra Brunk. This is not 

specifically a comment on monetizing the value of CO2, 

but I can’t find any other place to insert this. This 

makes as much sense as any. 

Chris Johnson has alluded to this several 

times as well, but we’re looking at a reduction in CO2

emissions, reduction in energy. We’ve talked all day a 

lot about the standards and the impact those could have 

on energy use. Something that we also want to bring up 

here, and I think the time is right, is really looking 

at what DOE may be doing in terms of evaluating the 

impact that smart appliances can actually have on 

holistic energy savings. Not maybe with the site type 

energy that we’ve been talking about, which is a single 

appliance, but the number of power plants that could be 

reduced, the CO2 emissions that could be reduced 

through the implementation of this type of technology, 

which certainly has had a tremendous push from this 

administration and in which, of course, DOE is also 

involved heavily. 

We just want to put that out there. It’s 

something we’re very interested in as an industry. 

We’re spending a lot of our time and resources to put 

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forward what needs to happen for us and what we need to 

do to make sure that this works. We certainly see 

something happening by 2014. 

We would like to just put on the table, if 

there is some way that if we actually start looking at 

the impact of CO2 emissions and reductions in power 

plants and if that ends up actually being incorporated 

into the analysis, is there something also that could 

be looked at in terms of a standards credit or some 

other incentive that would help to move this along, 

again, just recognizing the tremendous impact that we 

see potentially from the addition of this technology 

into home appliances. 

MR. BROOKMAN: Thank you, Debra. Additional 

comments in this vein? Let me remind all of you that 

there is an opportunity for brief summary remarks at 

the end of the day as well. We’re almost there, also, 

by the way. 

Back to Greg. 

MR. ROSENQUIST: Finally, the last step is 

the regulatory impact analysis. Its purpose is to 

determine the national impacts from alternatives to 

mandatory efficiency standards. What DOE has typically 

looked at in the past are such things as rebate 

programs, consumer and manufacturer tax credits, 

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voluntary efficiency targets like Energy Star, 

government procurement programs, for example, that are 

administered by FEMP. 

These are all looked at as means in which to 

save energy and provide economic benefit. Again, DOE 

wants to see whether or not that provides the same 

level of benefit as mandatory standards. 

The method that’s used is to use the 

spreadsheet model that’s used in the national impact 

analysis again, modifying key inputs to determine what 

the effect of the particular non–regulatory measure is 

on things like purchase price, energy use, operating 

cost, and things along that line. 

What you get out of this analysis is the same 

thing that you get out of our national impact analysis, 

which is national energy savings and net present value 

due to these various non–regulatory measures. Again, 

those are directly compared to the mandatory efficiency 

standards to determine whether or not that vehicle is a 

better way to accomplish these national impacts of the 

mandatory standards. 

MR. BROOKMAN: Comments on this, on 

regulatory impact analysis? 

 (No response) 

MR. ROSENQUIST: I think I’m going to turn 

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this back over to Lucas to close out. 

MR. BROOKMAN: Do you want to do this at the 

very end or do you want to do this now? Okay. 

As reflected in the agenda, now is an 

opportunity for anybody to raise any additional issues 

that you may not have covered sufficiently, things that 

you think deserve or you desire to have additional 

emphasis on. Briefly, Dave. 

MR. HALL: No, mine is retro. As we were 

whipping through it – 

MR. BROOKMAN: Let’s return to it. What 

slide is it? 

MR. HALL: Page 110. Basically, I’m 

questioning, since chest freezers are included with the 

grouping of all compact freezers, from our experience, 

compact chest freezers’ design and construction is 

consistent with full size chest freezers’ design and 

construction. Their life is on that similar magnitude, 

not necessarily by this equivalency. 

MR. BROOKMAN: By this extrapolation here. 

MR. HALL: Thank you. 

MR. BROOKMAN: Yes. Okay. Thank you. I’m 

certain the Department would welcome data on that 

point. That would be helpful to them. Or even 

anecdotal information. 

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So, an opportunity now for anybody to make 

closing remarks, points of emphasis, that sort of 

thing. Debra. 

DISCUSSION OF OTHER ISSUES AND FINAL REMARKS FROM 

INTERESTED PARTIES 

REMARKS BY DEBRA BRUNK 

ASSOCIATION OF HOME APPLIANCE MANUFACTURERS 

MS. BRUNK: Debra Brunk with AHAM. I guess I 

just wanted to make a comment here around, again, this 

being a helpful stage to go through an awful lot of 

this information. I think we’ve identified some holes 

here, some issues, some potential areas we need to work 

on. 

Something, I guess, I was just wondering 

about. Again, we’re changing the procedure already a 

little bit by having this pre–NOPR. I think it’s 

certainly valuable that we provide comments and all of 

that, but again, hearing the discussion today, I’m just 

wondering if there is some advantage in the future. I 

think, ideally, this rulemaking is perfectly suited for 

it because it’s so complicated. 

But if there’s any way to have this meeting 

or another type of meeting become more of a working 

meeting where we could actually hash out some of this 

stuff as opposed to the more formal approach, where we 

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could actually, perhaps, walk away with action items 

for various parties to try to get specific information. 

I don’t know. I just wonder if it would help 

to move the process along a little bit better and make 

sure that everyone is aware of what is happening. 

MR. BROOKMAN: Okay. Thank you for that. 

Any response to that? Okay. 

MR. LEWIS: We appreciate the thought and the 

input. We’ll certainly consider it. We’re looking for 

any suggestions that would streamline and make this 

more effective as an end result. We’ll certainly be 

thinking about that and see what we can do moving 

forward. 

MR. BROOKMAN: Other comments here, or 

summary remarks? 

 (No response) 

MR. BROOKMAN: Okay. Then I’m going to turn 

it back to Lucas for a final comment or two. 

My final comment is to thank all of you. 

We’ve had a very productive day. Appreciate the spirit 

of disclosure. Wish all of you well in the holiday 

season. 

Please fill out the evaluation form. The 

Department is always looking for ways to improve these 

meetings. It’s at the back of your packet. Lucas. 

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NEXT STEPS AND CLOSING REMARKS 

LUCAS ADIN 

 (PowerPoint presentation) 

MR. ADIN: I’ll be really brief here. Just a 

couple quick administrative items. We accept written 

comments all the way up until January 15, 2010. That’s 

the deadline for that. I believe that’s at midnight on 

January 15, 2010, too, which some folks do take 

advantage of. We understand that, which is fine. 

The e–mail address and regular mail addresses 

are up there. They’re also in the Federal Register 

notice. If you need that information, it’s there. 

That’s also on the website. We look forward to seeing 

your written comments very much. 

It’s been, as Doug said, a very productive 

meeting. 

MR. BROOKMAN: We didn’t do that slide. 

MR. ADIN: Oh, I’m sorry. This was just a – 

was it this one or the one above it? 

MR. BROOKMAN: One more slide. That one. 

No, down. 

MR. ADIN: This one? 

MR. BROOKMAN: Yeah. I thought I had 

referenced that. 

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MR. ADIN: Okay. All right. I’ll be 

perfectly honest. I really hadn’t been prepared to 

speak on this particular slide, but – 

MR. BROOKMAN: Ron Lewis. 

MR. LEWIS: Should, as Debra suggested, 

people get together and work through things and come to 

us with solutions while we’re working through how we’re 

going to streamline the process, we certainly wouldn’t 

be disappointed if somebody delivered in our lap and 

said here are all the answers. 

 (Laughter) 

MR. LEWIS: We have always encouraged those 

agreements. If anybody wanted to stay around a little 

bit later this afternoon to work on that – 

 (Laughter) 

MR. LEWIS: – we highly encourage that. 

MR. BROOKMAN: It has always been the case 

that, as a result of these meetings and others, there 

has been a spirit of cooperation just permeating these 

different constituencies. Thank you for that, Ron. 

Back to you. 

MR. ADIN: Yes. Thank you, Doug, for 

bringing up that slide. Thanks, Ron, for elaborating 

on that particular point. 

I did skip this slide, too. This is just a 

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reiteration of the seven points of analysis that we 

touch on and the analyses that we do corresponding with 

those things. We talked about them in pretty 

exhaustive detail today. That brings us back to the 

end here. 

I just want to close by thanking everyone who 

came today. We really appreciate your input very much. 

 It’s an integral part of doing this analysis, and it 

really helps us quite a bit. We look forward to 

anything else that you have to say in your written 

comments. 

One thing about this I would point out. 

Those numbers, the docket number and the RIN number 

will stay the same all the way through this rulemaking, 

all the way up until the final rule, so those will 

always be the reference numbers. 

MR. LEWIS: One last thing. I don’t know if 

you’ve noticed in recent rulemakings, but we’ve put 

these electronic mailboxes there for the rulemakings 

that have really helped us to distribute the comments 

to the people that need to know them internally that 

are in the decision–making path. That is very helpful. 

 If you e–mail them to that address, that would be very 

helpful. 

MR. DELASKI: In the spirit of electronic 

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comments, I would again urge the Department to make the 

comments to the docket available to the public online. 

 Something that’s maybe been on your plate for a while 

now, but I think it would be great if that was 

something that could move forward. 

MR. BROOKMAN: Thank you, Andrew. Thank you. 

Okay. Thanks to all of you. Safe travels. 

(Whereupon, at 4:08 p.m., the meeting was 

concluded.) 

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1 REPORTER'S CERTIFICATE

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 This is to certify that the attached proceedings 

before: 

U.S. DEPARTMENT OF ENERGY 

In the Matter of: 

PUBLIC MEETING ON THE PRELIMINARY ANALYSES FOR 

RESIDENTIAL REFRIGERATORS, REFRIGERATOR–FREEZERS, AND 

FREEZERS

 Were held as herein appears and that this is the 

original transcript thereof for the file of the 

Department, Commission, Board, Administrative Law Judge 

or the Agency. 

 Further, I am neither counsel for or related to any 

party to the above proceedings. 

 

17 Wendy Greene 18 

19 

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 Official Reporter 

Dated: December 28, 2009 

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