Manufacturer Impact Analysis

Review Process

March 11, 1997 U.S. Department of Energy

Office of Energy Efficiency

and Renewable Energy

1000 Independence Avenue, SW

Washington, DC 20585

EE-PI-96-001 COMMENT 81

Manufacturer Impact Analysis March 11, 1997 

Review Process 

U.S. Department of Energy 

Office of Energy Efficiency 

and Renewable Energy 

1000 Independence Avenue, SW 

Washington, DC 20585 
Review Process Background

In the July 1996 Process Rule, the Department committed to a

detailed review of the manufacturer impact analyses methodologies.

The new methodology must:

V

i

e1

Provide for early stakeholder input

Utilize an annual cash flow approach to determine quantitative

impacts, including an assessment of short term cost and capital

requirements

Develop estimates of critical variables (with input from interested

parties) drawing on multiple sources, both quantitative and qualitative

Report the distribution of impacts on manufacturers .

Use-models that are easy to understand and account for uncertainty

Consider the cumulative, impacts of regulation

Consider the impacts on manufacturing capacity, plant closures and

loss of capital investment

March 11, 1997

1

EE-PI-96-001 COMMENT 81

Review Process Background 

In the July 1996 Process Rule, the Department committed to a 

detailed review of the manufacturer impact analyses methodologies. 

The new methodology must: 

(~ VJ 

r./J; , I , J 

Provide for early stakeholder input 

Utilize an annual cash flow approach to determine quantitative 

impacts, including an assessment of short term cost and capital 

requirements 

,v: Develop estimates of critical variables (with input from interested 

parties) drawing on multiple sources, both quantitative and qualitative 

'J Report the distribution of impacts on manufacturers 

,./J' , I " ._' Use,models that are easy to unders~and and account for uncertainty 

r./J Consider the cumulative,impacts of regulation 

l./J Consider the impacts on manufacturing capacity, plant closures and 

loss of capital investment 

March 11, 1997 
Review Process Strawman

DOE has developed a strawman methodology for future manufacturer

impact analyses.

The methodology adds implementation procedures to the Process

Rule

The methodology will have flexibility built-in so that it can be adapted

to specific rulemakings

The methodology will be further developed with stakeholders' input

At the conclusion of this workshop, stakeholders will be invited to

participate in a work group tasked with the future development of

models or methods

EE-PI-96-001 COMMENT 81

Review Process Strawman 

DOE has developed a strawman methodology for future manufacturer 

impact analyses. 

[./I The methodology adds implementation procedures to the Process 

Rule 

:,./1 The methodology will have flexibility built-in so that it can be adapted 

to specific rulemakings 

'./I The methodology will be further developed with stakeholders' input 

. :JJ At the conclusion of this workshop, stakeholders will be invited to 

participate in a work group tasked with the future development of 

models or methods 

March 11, 1997 

2 
Review Process Schedule

Development of analyses methodologies will continue through the

spri ng of 1997.

I l

Jan8

Adviso ry Committee

Stakeholder Interviews / Consultations

Feb 14

Strawman Completed

I

March 11,12

Workshop

March 11,12

Formation of Workgroup

Workgroup Meetings

January February I March April

March 11, 1997

EE-PI-96-001 COMMENT 81

Review Process Schedule 

Development of analyses methodologies will continue through the 

spring of 1997 . 

• Jan8 T Advisory Committee 

siak~flola~rJritE3~iews I.Cbnstiltations 

Strawman Completed 

I 

• March 11,12 T Workshop 

I I . 

• March 11,12 T Formation of Workgroup 

March 11, 1997 

3. 
Review Process

DOE is seeking suggestions to improve the proposed review process.

Define the role and membership of the working group

Identify experts to assist and/or review the analyses methodologies

Propose alternatives/modifications to the proposed process

March 11, 1997

4

EE-PI-96-001 COMMENT 81

Review Process 

DOE is seeking suggestions to improve the proposed review process. 

'./J Define the role and membership of the working group 

'./J Identify experts to assist and/or review the ana.lyses methodologies 

~./J Propose alternatives/modifications to the proposed process 

March 11, 1997 

4