PRELIMINARY TECHNICAL SUPPORT 

DOCUMENT: 

ENERGY EFFICIENCY PROGRAM 

FOR CONSUMER PRODUCTS:
 

REFRIGERATORS, REFRIGERATOR-FREEZERS, AND FREEZERS 

November 2009 

U.S. Department of Energy 

Assistant Secretary 

Office of Energy Efficiency and Renewable Energy 

Building Technologies Program 

Appliances and Commercial Equipment Standards 

Washington, DC 20585 

EERE-2008-BT-STD-0012 COMMENT 22
This Document was prepared for the Department of Energy 

and by staff members of 

Navigant Consulting, Inc. 

and 

Ernest Orlando Lawrence Berkeley National Laboratory
 

EERE-2008-BT-STD-0012 COMMENT 22
EXECUTIVE SUMMARY 

TABLE OF CONTENTS 

ES.1 OVERVIEW OF PRELIMINARY ACTIVITIES......................................................ES-1
 

ES.2 OVERVIEW OF THE PRELIMINARY ANALYSES AND THE PRELIMINARY 

TECHNICAL SUPPORT DOCUMENT....................................................................ES-3
 

ES.3 KEY RESULTS OF THE ANALYSIS ......................................................................ES-4
 

ES.3.1 Market and Technology Assessment ..........................................................................ES-4
 

ES.3.2 Screening Analysis......................................................................................................ES-7
 

ES.3.3 Engineering Analysis..................................................................................................ES-7
 

ES.3.3.1 Product Classes Analyzed.......................................................................................... ES-7
 

ES.3.3.2 Manufacturing Cost Assessment................................................................................ ES-8
 

ES.3.4 Markups to Determine Product Price........................................................................ES-10
 

ES.3.5 Energy Use Characterization ....................................................................................ES-10
 

ES.3.6 Life-Cycle Cost and Payback Period Analyses ........................................................ES-13
 

ES.3.7 Shipments Analysis...................................................................................................ES-17
 

ES.3.8 National Impact Analysis..........................................................................................ES-20
 

ES.3.8.1 National Energy Savings.......................................................................................... ES-21
 

ES.3.8.2 Net Present Value .................................................................................................... ES-22
 

ES.3.9 Preliminary Manufacturer Impact Analysis..............................................................ES-23
 

ES.4 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT.....................................ES-24
 

ES.4.1 Use of the Proposed Designations for Product Classes 5A and 10A........................ES-24
 

ES.4.2 Establishment of Separate Product Classes for All-Refrigerators ............................ES-24
 

ES.4.3 Possible Combination of Product Classes 1 and 2, and Product Classes 11 and 12.ES-25
 

ES.4.4 Approach for Development of Baseline Energy Use/Adjusted Volume
 

Relationships under the Proposed Test Procedure....................................................ES-25
 

ES.4.5 Possible Modification of the Baseline Energy Use/Adjusted Volume Curve Slope ES-26
 

ES.4.6 Variation of Product Characteristics as Compared with Teardown Products...........ES-26
 

ES.4.7 Development of Energy Standards for Low-Volume Products ................................ES-26
 

ES.4.8 Field Energy Use of Standard-Size Refrigeration Products .....................................ES-26
 

ES.4.9 Field Energy Use of Compact Refrigeration Products .............................................ES-27
 

ES.4.10 Repair and Maintenance Costs..................................................................................ES-27
 

ES.4.11 Lifetime of Compact Refrigeration Products............................................................ES-27
 

ES.4.12 Base Case Efficiency Distributions ..........................................................................ES-27
 

ES.4.13 Forecasted Market Shares of Top-Mount vs. Side/Bottom-Mount RefrigeratorFreezers ....................................................................................................................ES-28
 

ES.4.14 Maturity of Vacuum Insulation Panels for High Volume Production ......................ES-28
 

ES.4.15 Clarification of the Distinction between Manual Defrost and Automatic Defrost for 

All-Refrigerators.......................................................................................................ES-28
 

ES.4.16 Analysis of Built-In Products....................................................................................ES-29
 

ES.4.17 Technical Data for Alternative Foam-Blowing Agents............................................ES-29
 

ES.4.18 Likely Scenarios for Alternative Foam-Blowing Agents .........................................ES-29
 

ES.4.19 Valuing Air-Borne Emission Reductions .................................................................ES-29
 

ES-i 

EERE-2008-BT-STD-0012 COMMENT 22
LIST OF TABLES 

Table ES.3.1 Product Classes for Refrigeration Products .......................................................ES-5
 

Table ES.3.2 Baseline-Efficiency Product Descriptions .........................................................ES-8
 

Table ES.3.3 Incremental Manufacturer Selling Price Results for Standard-Size 

Refrigerator-Freezers .........................................................................................ES-9
 

Table ES.3.4 Incremental Manufacturer Selling Price Results for Standard-Size Freezers....ES-9
 

Table ES.3.5 Incremental Manufacturer Selling Price Results for Compact Refrigerators 

and Freezers .....................................................................................................ES-10
 

Table ES.3.6 Markups for Refrigeration Products ................................................................ES-10
 

Table ES.3.7 Standard-Size Refrigerator-Freezers: Average Annual Energy Use by 

Efficiency Level...............................................................................................ES-12
 

Table ES.3.8 Standard-Size Freezers: Average Annual Energy Use by Efficiency Level....ES-12
 

Table ES.3.9 Compact Refrigerators and Freezers: Average Annual Energy Use by 

Efficiency Level...............................................................................................ES-13
 

Table ES.3.10 Product Class 3, Top-Mount Refrigerator-Freezer: LCC and PBP Results.....ES-14
 

Table ES.3.11 Product Class 5, Bottom-Mount Refrigerator-Freezer: LCC and PBP 

Results..............................................................................................................ES-15
 

Table ES.3.12 Product Class 7, Side-by-Side Refrigerator-Freezer with TTD: LCC and 

PBP Results......................................................................................................ES-15
 

Table ES.3.13 Product Class 9, Upright Freezers: LCC and PBP Results..............................ES-16
 

Table ES.3.14 Product Class 10, Chest Freezers: LCC and PBP Results ...............................ES-16
 

Table ES.3.15 Product Class 11, Compact Refrigerators: LCC and PBP Results ..................ES-17
 

Table ES.3.16 Product Class 18, Compact Freezers: LCC and PBP Results..........................ES-17
 

Table ES.3.17 Standard-Size Refrigerator-Freezers: Cumulative NES Results (quads).........ES-21
 

Table ES.3.18 Standard-Size Freezers: Cumulative NES Results (quads) .............................ES-21
 

Table ES.3.19 Compact Refrigerators and Freezers: Cumulative NES Results (quads).........ES-22
 

Table ES.3.20 Standard-Size Refrigerator-Freezers: Discounted Cumulative NPV Results..ES-22
 

Table ES.3.21 Standard-Size Freezers: Discounted Cumulative NPV Results.......................ES-23
 

Table ES.3.22 Compact Refrigerators and Freezers: Discounted Cumulative NPV Results..ES-23
 

LIST OF FIGURES 

Figure ES.1.1 Flow Diagram of Analyses for the Refrigerator, Refrigerator-Freezer, and 

Freezer Rulemaking Process..............................................................................ES-2 

Figure ES.3.1 Forecasted Shipments (Base Case) for Standard-Size Refrigerator Freezers..ES-18 

Figure ES.3.2 Forecasted Shipments (Base Case) for Standard-Size Freezers ......................ES-18 

Figure ES.3.3 Forecasted Shipments (Base Case) for Compact Refrigerators.......................ES-19 

Figure ES.3.4 Forecasted Shipments (Base Case) for Compact Freezers ..............................ES-19 

ES-ii 

EERE-2008-BT-STD-0012 COMMENT 22
EXECUTIVE SUMMARY 

ES.1 OVERVIEW OF PRELIMINARY ACTIVITIES 

Section 6295(o)(2)(A) of 42 U.S.C. requires the U.S. Department of Energy (DOE) to 

establish energy conservation standards that are technologically feasible and economically 

justified, and would achieve the maximum improvement in energy efficiency. This executive 

summary summarizes the preliminary activities that DOE conducted in consideration of 

amended energy conservation standards for refrigerators, refrigerator-freezers, and freezers. The 

executive summary describes the preliminary activities and summarizes key results from DOE’s 

preliminary analyses. Additionally, the executive summary delineates issues identified during the 

analyses about which DOE seeks comments from interested parties. These issues are highlighted 

in the public meeting presentation and are further discussed in chapter 2 of the preliminary 

technical support document (TSD). 

Figure ES.3.1 presents a summary of the analytical components of the standards-setting 

process and illustrates how key results are generated. The focal point of the figure is the center 

column, labeled “Analyses.” The columns labeled “Key Inputs” and “Key Outputs” show how 

the analyses fit into the process and how they relate to each other. Key inputs are the types of 

data and other information that the analyses require. Some key information is obtained from 

public databases. DOE collects other inputs from interested parties or persons having special 

knowledge and expertise. Key outputs are analytical results that feed directly into the standardssetting process. The issues on which DOE seeks comment from interested parties derive from the 

key results that are generated by the preliminary analyses. Arrows connecting analyses show the 

types of information that feed from one analysis to another. 

ES-1
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Utility Impact

Analysis 

Notice of Proposed Rulemaking (NOPR) 

Final Rule 

Market and Technology 

Assessment 

Screening Analysis 

Engineering Analysis 

Markups for 

Product Price 

Determination Life-Cycle Cost and 

Payback Period

Analysis 

National Impact

Analysis 

Energy Use 

Revise Pre-NOPR 

Analyses 

Life-Cycle Cost

Sub-Group Analysis 

Manufacturer Impact 

Analysis 

Shipments 

Analysis 

Employment Impact

Analysis 

Revise Analyses 

• Product Classes 

• Technology Options 

• Industry Cash Flow 

• Su b-Group Cash-Flow 

• Direct Employment Impacts 

• Compe titive Impacts 

• Cumulative Regulatory Burden 

• Cost-Efficie ncy Relat ionship 

• Life -Cycle Costs 

• Pa yback Periods 

• National Energ y Savings 

• Net Prese nt Values 

• National Employm ent Im pacts 

• Revised Resu lts 

• Market Se gmenta tion 

• Non-Regulatory Programs 

Framework Document 

• Energy Prices 

• Installation Costs 

• Maintenan ce & Repair Costs 

• Backcast an d Fo recast 

• Ma rket Saturation 

• Stakeholder Com ments 

• Demographics 

• Emission Rat es 

• National Energy Savings 

• Stakeholder Comm ents 

Environmental 

Assessment 

Regulatory Impact 

Analysis 

• Id entify Firms/Products 

• Historical Shipments 

• Manufacturer Prices 

• Average Co sts 

• M anufacturer Financial Da ta 

Design Options 

Pro duct Classes 

Retail Prices 

Design Ene rgy 

Notice of Public Meeting (NOPM) 

• Efficie ncy/Perform ance 

• Ma nufacturing C ost 

Candidate 

Standard 

Leve ls 

Technolo gy Op tions 

• Em issio n Estima tes 

• Utilit y Lo ad Fa cto rs 

• Na tion al Ene rgy Saving s 

• Non -Reg ula tory 

Alternatives 

• Desig n Optio ns 

• Ene rgy Price Fo recasts 

• Site-to-Sou rce Fa cto rs 

• Energy-Efficiency Levels 

Direct Em plo ymen t 

Impacts 

• National Energy Savings 

• National Product Costs 

• National Operating Costs 

• Utility Impacts 

• Life -Cycle Costs 

• Pa yback Periods 

• Installation 

Costs 

• Maint Costs 

• Rep air Costs 

• UEC 

• Energy 

Prices 

• Annu al En ergy Use (UEC) 

Preliminary 

Manufacturer Impact

Analysis 

• Manufa ctu rer Prices 

• Ave rage Costs 

• Conversion Capital E xpen ditures 

• Direct Emp loymen t Impacts 

• National Energ y Savings 

• Net Presen t Values 

• Trial Standa rd Le vels (TSLs) 

• Product Prototypes 

Energy-Efficie ncy 

Le vels 

• Dep artm ent of Justice Revie w 

TSLs 

Figure ES.1.1	 Flow Diagram of Analyses for the Refrigerator, RefrigeratorFreezer, and Freezer Rulemaking Process 

ES-2 

EERE-2008-BT-STD-0012 COMMENT 22
ES.2	 OVERVIEW OF THE PRELIMINARY ANALYSES AND THE 

PRELIMINARY TECHNICAL SUPPORT DOCUMENT 

For the preliminary stage, DOE publishes a notice of public meeting (NOPM) in the 

Federal Register, which announces the availability of the preliminary technical support 

document, the date and place of the public meeting, and presentation materials interested parties 

may review before the public meeting. In addition, the NOPM highlights the major analyses 

DOE developed in the preliminary stage of the rulemaking. 

The preliminary TSD describes each preliminary analysis in detail, providing detailed 

descriptions of inputs, sources, methodologies, and results. Chapter 2 of the preliminary TSD 

provides an overview of each preliminary analysis, the comments received in response to the 

analytical approaches DOE described in the framework document, and DOE’s responses to those 

comments. The following chapters of the preliminary TSD address the analyses performed for 

the preliminary stage of the rulemaking. 

A market and technology assessment (MTA) characterizes the relevant product markets 

and technology options, including prototype designs (chapter 3). 

A screening analysis reviews each technology option to determine whether it is 

technologically feasible; is practicable to manufacture, install, and service; would adversely 

affect product utility or product availability; or would have adverse impacts on health and safety 

(chapter 4). 

An engineering analysis develops cost-efficiency relationships that show a 

manufacturer’s cost of achieving increased efficiency. DOE uses manufacturer markups to 

convert manufacturer production cost (MPC) to manufacturer selling price (MSP) (chapter 5). 

A markups analysis converts the manufacturer costs derived from the engineering 

analysis to consumer equipment prices (chapter 6). 

An energy use analysis determines the annual energy use in the field of the considered 

products (chapter 7). 

Life-cycle cost (LCC) and payback period (PBP) analyses calculate, at the consumer 

level, the discounted savings in operating costs throughout the estimated average life of the 

covered products, compared to any increase in the product’s installed cost likely to result directly 

from the imposition of a given standard (chapter 8). 

A shipments analysis forecasts product shipments, which then are used to calculate the 

national impacts of standards on energy consumption, the net present value (NPV) of consumer 

costs and savings, and future manufacturer cash flows (chapter 9). 

A national impact analysis (NIA) assesses the cumulative national energy savings (NES) 

from standards and the NPV of consumer costs and savings associated with standards at different 

efficiency levels (chapter 10). 

ES-3
 

EERE-2008-BT-STD-0012 COMMENT 22
A preliminary manufacturer impact analysis (MIA) assesses the potential impacts of 

energy conservation standards on manufacturers, such as effects on expenditures for capital 

conversion, marketing costs, shipments, and research and development costs (chapter 12). 

The remaining chapters of the preliminary TSD address the analyses to be performed for 

the NOPR stage: 

•	 A life-cycle cost analysis for subgroups evaluates the effects of energy conservation 

standards on various national subgroups of the population (chapter 11). 

•	 A utility impact analysis examines impacts of energy conservation standards on the 

generation capacity of electric utilities (chapter 13). 

•	 An employment impact analysis examines the effects of energy conservation standards 

on national employment (chapter 14). 

•	 An environmental assessment examines the effects of energy conservation standards on 

various airborne emissions (chapter 15). 

•	 A regulatory impact analysis examines the national impacts of non-regulatory alternatives 

to mandatory energy conservation standards (chapter 16). 

ES.3 KEY RESULTS OF THE ANALYSIS 

The following sections describe in detail the key analyses DOE performed in support of 

the TSD. 

ES.3.1 Market and Technology Assessment 

When initiating an analysis of potential energy efficiency standards for appliance, DOE 

develops information for the products concerned on the present and past industry structure and 

market characteristics. This activity assesses industries and products both quantitatively and 

qualitatively, based on publicly available information. 

When evaluating and establishing energy conservation standards, DOE generally divides 

covered products into product classes by the type of energy used or by capacity or other 

performance-related features that affect efficiency. Different energy conservation standards may 

apply to different product classes. (42 U.S.C. 6295(q)) Table ES.3.1 describes all of the product 

classes being considered in this rulemaking. 

ES-4
 

EERE-2008-BT-STD-0012 COMMENT 22
Table ES.3.1 Product Classes for Refrigeration Products 

No. Product Class 

Classes Listed in the CFR (10 CFR 430.32(a)) 

1 Refrigerator-freezers with manual defrost 

2 Refrigerator-freezers—partial automatic defrost 

3 Refrigerator-freezers—automatic defrost with top-mounted freezer without TTD* ice service 

4 Refrigerator-freezers—automatic defrost with side-mounted freezer without TTD ice service 

5 Refrigerator-freezers—automatic defrost with bottom-mounted freezer without TTD ice service 

6 Refrigerator-freezers—automatic defrost with top-mounted freezer with TTD ice service 

7 Refrigerator-freezers—automatic defrost with side-mounted freezer with TTD ice service 

8 Upright freezers with manual defrost 

9 Upright freezers with automatic defrost 

10 Chest freezers and all other freezers except compact freezers 

11 Compact** refrigerators and refrigerator-freezers with manual defrost 

12 Compact refrigerator-freezers—partial automatic defrost 

13 Compact refrigerator-freezers—automatic defrost with top-mounted freezer and compact allrefrigerators—automatic defrost 

14 Compact refrigerator-freezers—automatic defrost with side-mounted freezer 

15 Compact refrigerator-freezers—automatic defrost with bottom-mounted freezer 

16 Compact upright freezers with manual defrost 

17 Compact upright freezers with automatic defrost 

18 Compact chest freezers 

Classes Proposed to be Established during this Rulemaking 

1A All-refrigerators—manual defrost 

3A All-refrigerators—automatic defrost 

5A Refrigerator-freezers—automatic defrost with bottom-mounted freezer with TTD ice service 

10A Chest freezers with automatic defrost 

11A Compact all-refrigerators—manual defrost 

13A Compact all-refrigerators—automatic defrost 

* TTD = through the door 

** Compact refrigerators, refrigerator-freezers, and freezers have less than 7.75 cubic feet (220 

liters) total refrigerated volume and are less than 36 inches (0.91 m) in height. 

The product classes listed in Table ES.3.1 as proposed to be established during this 

rulemaking include the following: 

•	 Product Class 5A was identified as Product Class 19 in the framework document. DOE is 

proposing to adopt the modified designation 5A to maintain consistency with Canadian 

Standards. 

ES-5
 

EERE-2008-BT-STD-0012 COMMENT 22
•	 Product Class 10A was identified as Product Class 20 in the framework document. DOE 

is proposing to adopt the modified designation 10A to maintain consistency with 

Canadian Standards. 

•	 Product Classes 1A, 3A, 11A, and 13A are proposed as a result of proposed new test 

procedures which involve modification of compartment temperatures. According to these 

test procedures the energy use of all-refrigerators decreases, while that of the other 

products of existing Products Classes 1, 3, 11, and 13 increases significantly. Establishing 

meaningful energy standard levels for the all-refrigerators requires that they be separated 

from the other products of the existing product classes. 

The CFR establishes the test procedures for refrigerators, refrigerator-freezers, and 

freezers. (10 CFR part 430, subpart B, appendices A1 and B1) DOE has initiated a separate 

rulemaking to amend these test procedures. The proposed amendments address a number of 

issues that have emerged since the last test procedure revisions, including updating the reference 

to the AHAM HRF-1 test standard, modifying the test procedures for icemakers, specifying 

procedures for test sample preparation, modifying the test procedures for convertible 

compartments and special-purpose compartments, modification of the definition for anti-sweat 

heaters to include those that prevent sweat on interior surfaces, various test procedure language 

corrections, incorporating test procedures for variable anti-sweat systems previously addressed in 

waivers, establishing new compartment temperatures and volume calculation methods, 

modification to test procedures for advanced defrost systems, and modification of the definition 

of refrigerator-freezers to exclude combination freezer-wine storage products. 

For the residential refrigeration products that are the topic of this rulemaking, DOE 

addressed as part of the market assessment (1) manufacturer market share and characteristics, (2) 

existing regulatory and non-regulatory initiatives for improving product efficiency, and (3) 

trends in product characteristics and retail markets. This information provided data and resource 

material throughout the analysis. 

DOE reviewed literature and interviewed manufacturers to develop an overall 

understanding of the residential refrigeration products industry in the United States. Industry 

publications, including trade journals, literature from manufacturers, government agencies, and 

trade organizations provided the bulk of the information, including (1) manufacturers and their 

market share; (2) shipments by product type; (3) product information; and (4) industry trends. 

Chapter 3 of the preliminary TSD describes the market analysis and resulting information. 

DOE typically uses information about existing and past technology options and prototype 

designs to determine which technologies and combinations of technologies manufacturers use to 

attain higher performance levels. In consultation with interested parties, DOE develops a list of 

technologies to be considered. The identified technologies initially include all those DOE 

believes are technologically feasible. 

DOE developed its list of technologically feasible technologies for refrigeration products 

based on a review of trade publications, technical papers, and manufacturer literature and 

through consultation with manufacturers of components and systems. Because existing products 

ES-6
 

EERE-2008-BT-STD-0012 COMMENT 22
contain many technologies for improving product efficiency, product literature and direct 

examination provided additional information. Before performing the screening analysis, DOE 

removed from the list those technologies for which the energy consumption could not be 

adequately measured using the relevant DOE test procedure. 

ES.3.2 Screening Analysis 

The screening analysis examines whether identified technologies (1) are technologically 

feasible; (2) are practicable to manufacture, install, and service; (3) have an adverse impact on 

product utility or availability; and/or (4) have adverse impacts on health and safety. As part of 

this analysis, DOE develops an initial list of options for enhancing efficiency from the 

technologies that the technology assessment identified as feasible. In consultation with interested 

parties, DOE reviews the list to assess whether the technologies: (1) are practicable to 

manufacture, install, and service; (2) would adversely affect product utility or availability; or (3) 

would have adverse impacts on health and safety. In the subsequent engineering analysis, DOE 

further examines the technology options that it did not remove from consideration in the 

screening analysis. 

ES.3.3 Engineering Analysis 

The engineering analysis (chapter 5) establishes the relationship between the cost of 

manufacturing residential refrigeration products and their efficiency. This relationship serves as 

the basis for calculating costs and benefits of modified product designs for consumers, 

manufacturers, and the Nation. Chapter 5 describes the product classes DOE analyzed, the 

representative baseline units, the efficiency levels DOE considered, the methodology DOE used 

to develop the manufacturing production cost model, and the cost-efficiency results. 

ES.3.3.1 Product Classes Analyzed 

The engineering analysis analyzed seven key product classes that cover the range of 

product classes within the residential refrigeration product category and represent approximately 

90% of the shipments of these products. Based on its analysis of three product classes of 

standard-size refrigerator-freezers, two product classes within standard-size freezers, and two 

product classes within compact refrigerators and freezers, DOE generated seven cost-efficiency 

curves. The fourteen products serving as prototypical baseline-efficiency products for the 

analysis are described in Table ES.3.2. Chapter 5 includes additional details on the representative 

product classes and the cost-efficiency curves developed as part of the engineering analysis. 

DOE also reviewed the energy efficiency equations that define existing Federal energy 

conservation standards for refrigerators, refrigerator-freezers, and freezers and the impact which 

the proposed new energy test procedure would have on these equations. The proposed test 

procedure includes compartment temperature changes and changes to the method for 

determining compartment volumes. New energy efficiency equations representing current 

baseline efficiency products tested using the proposed test procedure were developed. In 

addition, these equations were examined to determine whether the slopes of the energy/adjusted 

volume curves are appropriate for the key product classes examined for the engineering analysis. 

ES-7
 

EERE-2008-BT-STD-0012 COMMENT 22
The slopes of these curves determine whether the efficiency levels defined by the curves are 

more stringent for larger products as compared with smaller products. 

Table ES.3.2 Baseline-Efficiency Product Descriptions 

Product Class Total Volume 

(ft3) 

Annual Energy 

Use (kWh)* 

3 16 455 

21 511 

5 18.5 560 

25 593 

7 22 672 

26 729 

9 14 621 

20 758 

10 15 397 

20 484 

11 1.7 317 

4 345 

18 3.4 213 

7 279 

*Annual Energy Use based on current DOE Energy Test Procedure 

ES.3.3.2 Manufacturing Cost Assessment 

DOE estimated the manufacturing costs associated with an increase in energy efficiency 

for each of the residential refrigeration product classes analyzed. The assessment method 

involved disassembling model units, analyzing the materials and manufacturing processes, 

analyzing the design approaches manufacturers use, and developing a spreadsheet model to 

describe costs. DOE built a detailed model for assessing manufacturing cost that estimates 

manufacturer production cost. DOE also aggregated manufacturers’ costs to maintain 

confidentiality of the data. DOE obtained input from interested parties on the manufacturing cost 

model inputs. Chapter 5 of the preliminary TSD includes information on the inputs used to 

determine the manufacturing cost, including material, labor, and overhead prices. Chapter 5 also 

includes information on the various components and features incorporated into designs for 

residential refrigeration products. 

DOE’s engineering analysis produced cost-efficiency curves for the seven representative 

refrigeration product classes. The cost-efficiency curves are described by the efficiency levels 

DOE analyzed and the increase in manufacturer selling price (MSP) required to improve a 

baseline-efficiency product to each of the considered efficiency levels. Table ES.3.2 through 

Table ES.3.4 present the key results of the engineering analysis. The maximum technology levels 

determined for the product classes (average of the two products analyzed for each product class) 

ranged from 45% to 56% except for product class 11, for which the level was 75%. Incremental 

cost curves were developed for efficiency levels up to 45% for all product classes but product 

class 7, for which the 45% level was higher than the 41% maximum technology level determined 

for one of the products of this class. DOE proposed a maximum technology level of 30% in the 

ES-8
 

EERE-2008-BT-STD-0012 COMMENT 22
framework document. Stakeholders commented during the framework workshop that the 

maximum level should be increased to 35%. DOE extended this level to 45% when the analysis 

indicated that higher efficiency levels could be attained. However, although the analyses, as 

described in chapter 5 of this TSD, indicated that some product classes could attain even higher 

efficiency levels, DOE did not extend incremental cost curves further due to expectations that 

higher levels would not be cost effective. 

Table ES.3.3	 Incremental Manufacturer Selling Price Results for Standard-Size 

Refrigerator-Freezers 

Efficiency Level 

(percent less than 

baseline energy use) 

Product Class 

3: Refrigerator-freezers 

— automatic defrost 

with top-mounted 

freezer without TTD ice 

service 

5: Refrigerator-freezers 

— automatic defrost 

with bottom-mounted 

freezer without TTD ice 

service 

7: Refrigerator-freezers 

— automatic defrost 

with side-mounted 

freezer with TTD ice 

service 

10% $3.50 $1.80 $11.18 

15% $7.68 $5.79 $18.96 

20% $16.39 $13.72 $54.26 

25% $34.92 $31.38 $106 

30% $62.06 $45.06 $167 

35% $104 $110 $229 

40% $156 $183 $311 

45% $208 $251 N/A 

Table ES.3.4 Incremental Manufacturer Selling Price Results for Standard-Size 

Freezers 

Efficiency Level (percent less 

than baseline energy use) 

Product Class 

9: Upright freezers with 

automatic defrost 

10: Chest freezers and all other 

freezers except compact freezers 

10% $6.41 $2.35 

15% $11.45 $6.05 

20% $13.57 $24.08 

25% $27.51 $29.26 

30% $46.58 $34.84 

35% $76.82 $74.35 

40% $124 $77.12 

45% $197 $137 

ES-9
 

EERE-2008-BT-STD-0012 COMMENT 22
Table ES.3.5 Incremental Manufacturer Selling Price Results for Compact 

Refrigerators and Freezers 

Efficiency Level (percent less 

than baseline energy use) 

Product Class 

11: Compact refrigerators and 

refrigerator-freezers with 

manual defrost 

18: Compact chest freezers 

10% $3.36 $6.05 

15% $6.32 $9.65 

20% $8.85 $34.03 

25% $20.56 $42.62 

30% $21.63 $60.19 

35% $26.77 $63.00 

40% $39.24 $75.22 

45% $57.49 $89.70 

ES.3.4 Markups to Determine Product Price 

The markups analysis (chapter 6) develops appropriate markups in the distribution chain 

to convert the estimates of manufacturer cost derived in the engineering analysis to consumer 

prices. In developing markups, DOE determined the distribution channels for refrigeration 

products and the markup associated with each party in the distribution channel. For refrigeration 

products, DOE estimated markups taken by retailers, along with sales taxes. DOE developed 

separate markups for baseline products (baseline markups) and for the cost increase associated 

with improvements required to produce more-efficient products (incremental markups). Table 

ES.3.5 summarizes the markups developed for refrigeration products. Note that the manufacturer 

markup has already been incorporated into the incremental costs presented in the tables of 

Section ES.3.3. 

Table ES.3.6 Markups for Refrigeration Products 

Markup Baseline Incremental 

Manufacturer 1.26 

Retailer 1.45 1.15 

Sales Tax 1.069 

ES.3.5 Energy Use Characterization 

The energy use characterization provides the basis for developing the energy savings 

from higher-efficiency appliances used in the LCC and subsequent analyses. The DOE test 

procedure provides standardized results that can serve as the basis for comparing the 

performance of different appliances used under the same conditions, but actual usage in the field 

may differ from usage estimated by the test procedure. DOE conducted a review of studies that 

measured the field consumption of refrigerator-freezers to compare such measurements to the 

ES-10
 

EERE-2008-BT-STD-0012 COMMENT 22
DOE ratings, which confirmed that measurements of field energy use often vary considerably 

from the rated usage as determined by the DOE test procedure. 

To determine the field energy use by products that would meet possible energy efficiency 

standards, DOE used data from the Energy Information Administration (EIA)’s 2005 Residential 

Energy Consumption Survey (RECS). RECS is a national sample survey of housing units that 

collects statistical information on the consumption of and expenditures for energy in housing 

units along with data on energy-related characteristics of the housing units and occupants. RECS 

provides enough information to establish the type (i.e., product class) of refrigeration product 

used in each household, and also provides an estimate of the household’s energy consumption 

attributable to refrigerators or freezers. As a result, DOE was able to develop a household sample 

for the representative product classes for standard-size units. DOE did not use RECS for compact 

refrigerators and freezers because a large fraction of these products are used outside the 

residential sector. 

DOE treated the RECS reported field energy consumption, referred to as FECRECS, as the 

actual consumption of the refrigeration product(s) in that household. Energy use for a 

household’s refrigerator or freezer is known to vary depending on its operating conditions, the 

behavior of its users, and other factors. DOE characterized field energy use of each product by 

using a multiplicative ‘usage adjustment factor’ (UAF) that adjusts the energy use from its test 

energy consumption to reflect these factors. 

To develop a UAF for each RECS household, DOE utilized information that RECS 

provides on the size (i.e., volume), age and the product class of the refrigeration product. DOE 

determined for each household’s unit the corresponding maximum allowable tested energy 

consumption, referred to as TECSTD, based on the energy conservation standard that was in effect 

at the time the household purchased the refrigeration product. Using FECRECS and TECSTD, DOE 

then developed the UAF for each household to capture the combined effects of consumer 

behavior (e.g., door openings), operating conditions (e.g., room temperature and humidity), and 

product characteristics (e.g., efficiency relative to the minimum allowable). The UAF represents 

the adjustment that needs to be made to the maximum allowable tested energy use to arrive at the 

field energy consumption of the refrigeration product. For households that reported having 

ENERGY STAR refrigeration products, DOE calculated tested energy consumption based on the 

ENERGY STAR criteria in effect at the time the household purchased the refrigeration product. 

Chapter 7 provides more details on the methods, data, and assumptions used for developing 

UAFs. 

Tables ES.3.6 through ES.3.8 present the average annual energy use for the 

representative product classes at each considered energy efficiency level. The tables for 

standard-sized products show the average annual energy consumption calculated according to the 

proposed DOE test procedure and if the products were used in the appropriate RECS 2005 

household sub-samples (“field”). The table for compact appliances shows the average annual 

energy consumption according to the proposed DOE text procedure, using a distribution of 

product volumes based on the California Energy Commission’s appliance database. 

ES-11
 

EERE-2008-BT-STD-0012 COMMENT 22
Table ES.3.7 Standard-Size Refrigerator-Freezers: Average Annual Energy Use by 

Efficiency Level 

Efficiency 

Level 

(percent less 

than 

Product Class 

3: Refrigerator-freezers — 

automatic defrost with topmounted freezer without 

TTD ice service 

5: Refrigerator-freezers — 

automatic defrost with 

bottom-mounted freezer 

without TTD ice service 

7: Refrigerator-freezers — 

automatic defrost with sidemounted freezer with TTD 

ice service 

baseline 

energy use) 

Proposed Test 

(kWh) 

Field 

(kWh) 

Proposed Test 

(kWh) 

Field 

(kWh) 

Proposed Test 

(kWh) 

Field 

(kWh) 

Baseline 534 657 652 699 756 1087 

10% 481 591 587 629 680 979 

15% 454 558 554 594 643 924 

20% 428 526 522 559 605 870 

25% 401 493 489 524 567 815 

30% 374 460 456 489 529 761 

35% 347 427 424 454 491 707 

40% 321 394 391 419 454 652 

45% 294 361 359 384 - -

Table ES.3.8 Standard-Size Freezers: Average Annual Energy Use by Efficiency Level 

Efficiency Level 

(percent less than 

baseline energy 

use) 

Product Class 

9: Upright freezers with automatic 

defrost 

10: Chest freezers and all other freezers 

except compact freezers 

Proposed Test 

(kWh) 

Field 

(kWh) 

Proposed Test 

(kWh) 

Field 

(kWh) 

Baseline 717 980 428 623 

10% 646 882 385 561 

15% 610 833 364 530 

20% 574 784 342 498 

25% 538 735 321 467 

30% 502 686 300 436 

35% 466 637 278 405 

40% 430 588 257 374 

45% 394 539 235 343 

ES-12
 

EERE-2008-BT-STD-0012 COMMENT 22
Table ES.3.9 Compact Refrigerators and Freezers: Average Annual Energy Use by 

Efficiency Level 

Efficiency Level 

(percent less than 

baseline energy use) 

Product Class 

11: Compact refrigerators and 

refrigerator-freezers with manual 

defrost 

(kWh) 

18: Compact chest freezers 

(kWh) 

Baseline 325 313 

10% 292 282 

15% 276 266 

20% 260 250 

25% 244 235 

30% 227 219 

35% 211 203 

40% 195 188 

45% 179 172 

ES.3.6 Life-Cycle Cost and Payback Period Analyses 

Stipulating new energy conservation standards for products results in changes in 

consumer operating expenses—usually a decrease—and changes in consumer price—usually an 

increase. DOE analyzed the net effect of amended standards on consumers by evaluating the 

LCC using the cost-efficiency relationship derived in the engineering analysis, as well as the 

energy costs derived from the energy use characterization. Inputs to the LCC calculation 

included the installed cost to the consumer (purchase price plus installation cost), operating costs 

(energy expenses), the lifetime of the appliance, and a discount rate. Because DOE found no 

evidence that repair or maintenance costs change as the efficiency of refrigeration products 

increases, it excluded those costs from its analysis. 

Because the installed cost of a product typically increases while operating cost typically 

decreases in response to new standards, there is a time in the life of products having higher-thanbaseline efficiency when the net operating-cost benefit (in dollars) since the time of purchase is 

equal to the incremental first cost of purchasing the higher-efficiency product. The length of time 

required for products to reach this cost-equivalence point is known as the payback period (PBP). 

DOE conducted the LCC and PBP analyses using values that reflect energy consumption 

in the field. DOE identified several input values for estimating the LCC, including retail prices, 

energy prices, discount rates, and product lifetimes. DOE used EIA’s energy price data to 

determine prices for electricity in 2007 and used projections of these energy prices from EIA’s 

Annual Energy Outlook 2009 to estimate future energy prices. DOE developed discount rates 

from estimates of the finance cost for consumers that purchase refrigeration products. 

Because the basis for the lifetime estimates in the literature for refrigeration products is 

uncertain, DOE used actual data sources to estimate the distribution of refrigerator and freezer 

ES-13
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

lifetimes in the field. By combining survey results from RECS and the U.S. Census’s American 

Housing Survey with the known history of appliance shipments, DOE estimated the fraction of 

appliances of a given age still in operation. The survival function, which DOE assumed has the 

form of a cumulative Weibull distribution, provides an average and median appliance lifetime. 

To accurately estimate the share of consumers that would be affected by a standard at a 

particular efficiency level, DOE’s LCC analysis considered the projected distribution of product 

efficiencies that consumers purchase under the base case (i.e., the case without new energy 

efficiency standards). DOE refers to this distribution of product of efficiencies as a base-case 

efficiency distribution. DOE developed base-case efficiency distributions for each of the seven 

representative product classes. These distributions were developed from industry supplied data 

for the year 2007 and were comprised of product efficiencies ranging from existing baseline 

levels (i.e., meeting existing energy conservation standards) to levels meeting and exceeding 

ENERGY STAR levels. DOE then projected these distributions to the year that new standards 

are assumed to become effective (2014). To forecast the base-case efficiency distribution for 

each representative product class, DOE accounted for change in the market shares of ENERGY 

STAR appliances based on historical trends. Using the projected distribution of product 

efficiencies for each product class, DOE randomly assigned a specific product efficiency to each 

sample household. If a household was assigned a product efficiency that is greater than or equal 

to the efficiency of the standard level under consideration, the LCC calculation would show that 

this household is not impacted by that standard level. 

Table ES.3.9 through Table ES.3.15 show the results of the LCC and PBP analyses for 

the representative product classes at each considered energy efficiency level. Figures presented 

in Chapter 8 show the range of LCC savings and PBPs for all of the efficiency levels considered 

for each product class. Chapter 8 provides more details on the methods, data, and assumptions 

used for the LCC and PBP analyses. 

Table ES.3.10 Product Class 3, Top-Mount Refrigerator-Freezer: LCC and PBP Results 

Efficiency Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Level 

(percent less 

than baseline 

energy use) 

Average 

Equipment 

Cost 

Average 

Annual 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Households with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline $591 $77 $1,505 - - - - - -

10% $595 $71 $1,434 $71 0.0% 18.5% 81.5% 0.6 0.7 

15% $599 $67 $1,398 $106 0.0% 13.0% 86.9% 0.9 1.1 

20% $609 $64 $1,368 $137 0.1% 13.0% 86.8% 1.5 1.7 

25% $631 $60 $1,343 $162 2.6% 0.0% 97.4% 2.8 3.2 

30% $665 $56 $1,329 $176 7.0% 0.0% 93.0% 4.0 4.6 

35% $716 $52 $1,333 $172 16.5% 0.0% 83.5% 5.6 6.4 

40% $781 $48 $1,350 $155 28.2% 0.0% 71.8% 7.3 8.3 

45% $845 $44 $1,367 $138 36.3% 0.0% 63.7% 8.5 9.7 

ES-14
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

Table ES.3.11 Product Class 5, Bottom-Mount Refrigerator-Freezer: LCC and PBP 

Results 

Efficiency 

Level 

(percent less 

than baseline 

energy use) 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Equipment 

Cost 

Average 

Annual 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Households with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline $1,758 $70 $2,591 

10% $1,759 $69 $2,581 $11 0.0% 88.5% 11.5% 0.3 0.4 

15% $1,759 $69 $2,576 $16 0.0% 88.4% 11.6% 0.7 0.8 

20% $1,760 $68 $2,571 $20 0.0% 88.4% 11.6% 1.2 1.4 

25% $1,782 $64 $2,542 $49 14.8% 0.0% 85.2% 5.1 6.0 

30% $1,799 $60 $2,508 $83 11.2% 0.0% 88.8% 4.6 5.4 

35% $1,879 $55 $2,538 $54 44.1% 0.0% 55.9% 9.5 11.0 

40% $1,969 $51 $2,577 $14 60.5% 0.0% 39.5% 12.6 14.7 

45% $2,053 $47 $2,610 -$19 67.0% 0.0% 33.0% 14.3 16.6 

Table ES.3.12 Product Class 7, Side-by-Side Refrigerator-Freezer with TTD: LCC and 

PBP Results 

Efficiency 

Level 

(percent less 

than baseline 

energy use) 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Equipment 

Cost 

Average 

Annual 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Households with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline $1,459 $116 $2,840 

10% $1,463 $113 $2,804 $35 0.0% 74.3% 25.7% 1.1 1.3 

15% $1,469 $108 $2,759 $80 0.1% 31.6% 68.4% 1.5 1.6 

20% $1,499 $104 $2,738 $102 3.1% 31.6% 65.4% 3.8 4.2 

25% $1,563 $97 $2,724 $116 23.8% 0.0% 76.2% 6.7 7.6 

30% $1,638 $91 $2,722 $117 32.7% 0.0% 67.3% 8.1 9.0 

35% $1,714 $84 $2,721 $119 38.5% 0.0% 61.5% 8.9 9.9 

40% $1,815 $78 $2,744 $95 46.2% 0.0% 53.9% 10.1 11.2 

ES-15
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table ES.3.13 Product Class 9, Upright Freezers: LCC and PBP Results 

Efficiency 

Level 

(percent less 

than baseline 

energy use) 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Equipment 

Cost 

Average 

Annual 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Households with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline $505 $113 $2,064 

10% $511 $104 $1,942 $122 0.0% 19.4% 80.6% 0.7 0.8 

15% $517 $98 $1,870 $194 0.0% 1.6% 98.4% 0.9 1.1 

20% $520 $92 $1,793 $271 0.0% 0.5% 99.5% 0.7 0.9 

25% $537 $87 $1,731 $333 0.0% 0.4% 99.6% 1.3 1.5 

30% $561 $81 $1,675 $389 0.3% 0.2% 99.6% 1.8 2.1 

35% $598 $75 $1,633 $432 1.2% 0.0% 98.8% 2.5 3.0 

40% $656 $69 $1,611 $453 4.0% 0.0% 96.0% 3.5 4.3 

45% $745 $63 $1,621 $443 9.9% 0.0% 90.1% 5.0 6.0 

Table ES.3.14 Product Class 10, Chest Freezers: LCC and PBP Results 

Efficiency 

Level 

(percent less 

than baseline 

energy use) 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Equipment 

Cost 

Average 

Annual 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Households with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline $325 $69 $1,275 

10% $328 $63 $1,196 $79 0.0% 15.3% 84.8% 0.4 0.5 

15% $332 $60 $1,153 $122 0.0% 1.1% 98.9% 0.8 1.0 

20% $355 $56 $1,127 $148 1.2% 0.2% 98.6% 2.5 3.0 

25% $361 $53 $1,085 $190 0.7% 0.2% 99.2% 2.4 2.8 

30% $368 $49 $1,044 $231 0.4% 0.2% 99.4% 2.3 2.7 

35% $416 $46 $1,044 $231 5.3% 0.0% 94.7% 4.2 4.9 

40% $420 $42 $999 $276 3.7% 0.0% 96.3% 3.8 4.4 

45% $493 $39 $1,024 $251 13.8% 0.0% 86.2% 6.0 6.9 

ES-16
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

Table ES.3.15 Product Class 11, Compact Refrigerators: LCC and PBP Results 

Efficiency 

Level 

(percent less 

than baseline 

energy use) 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Equipment 

Cost 

Average 

Annual 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Consumers with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline $166 $33 $325 

10% $170 $30 $314 $12 4.2% 2.9% 92.8% 1.4 1.3 

15% $173 $28 $309 $16 8.1% 2.6% 89.4% 1.7 1.7 

20% $176 $26 $305 $21 9.3% 2.6% 88.1% 1.8 1.8 

25% $191 $25 $311 $14 34.1% 1.7% 64.2% 3.4 3.3 

30% $192 $23 $304 $21 26.9% 0.0% 73.2% 2.9 2.8 

35% $198 $21 $303 $23 30.5% 0.0% 69.6% 3.1 3.0 

40% $214 $20 $310 $15 44.6% 0.0% 55.4% 4.0 3.9 

45% $236 $18 $324 $1 62.2% 0.0% 37.8% 5.3 5.1 

Table ES.3.16 Product Class 18, Compact Freezers: LCC and PBP Results 

Efficiency 

Level 

(percent less 

than baseline 

energy use) 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

(years) 

Average 

Equipment 

Cost 

Average 

Annual 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

Consumers with 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline $207 $34 $399 

10% $214 $30 $388 $11 9.6% 5.0% 85.4% 2.4 2.3 

15% $218 $29 $382 $16 11.7% 0.0% 88.3% 2.5 2.5 

20% $248 $27 $403 -$4 65.8% 0.0% 34.2% 6.7 6.8 

25% $259 $25 $404 -$5 65.6% 0.0% 34.4% 6.7 6.7 

30% $281 $24 $416 -$17 76.5% 0.0% 23.5% 7.9 7.9 

35% $284 $22 $410 -$11 69.3% 0.0% 30.7% 7.1 7.1 

40% $299 $20 $415 -$16 72.0% 0.0% 28.0% 7.4 7.4 

45% $317 $19 $423 -$24 75.9% 0.0% 24.1% 7.8 7.8 

ES.3.7 Shipments Analysis 

Shipment forecasts are needed to calculate for each product being considered the national 

impacts of standards on energy use, NPV, and future manufacturer cash flows. DOE’s shipments 

models consider shipments for new homes and replacements. Rather than simply extrapolating a 

current shipments trend, the analysis uses driver input variables to forecast sales in each market 

segment. For new housing units, annual product shipments are equal to the number of new 

housing units built multiplied by the purchase rate, which is determined by the market share of 

the product under consideration. To estimate shipments due to replacements, the models use 

sales in previous years and assumptions about the product lifetime, which determine how long an 

appliance is likely to remain in use. Chapter 9 of the TSD provides additional detail on the 

shipments analysis. 

ES-17
 

EERE-2008-BT-STD-0012 COMMENT 22
1990

1995200020052010

201520202025203020352040

Figure ES.3.1 through Figure ES.3.4 illustrate the forecasted base-case shipments for all 

of the product classes included in this rulemaking. 

0.0

5.0

10.0

15.0

20.0

25.0

Millions 

PC: 5, 5A 

PC: 4, 7 

PC: 1, 1A, 3, 3A, 6 

Historical Shipments 

Modeled Shipments 

19901995200020052010201520202025203020352040

Figure ES.3.1 Forecasted Shipments (Base Case) for Standard-Size 

Refrigerator Freezers 

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

Millions 

PC: 10, 10A 

PC9 

PC8 

Historical Shipments 

Modeled Shipments 

Figure ES.3.2	 Forecasted Shipments (Base Case) for Standard-Size 

Freezers 

ES-18 

EERE-2008-BT-STD-0012 COMMENT 22
1990

1993

1996

1999

2002

20052008

2011

2014

2017

2020

2023

2026

2029

2032

2035

20382041

19901993

1996

199920022005

2008

201120142017

20202023

2026

202920322035

20382041

7.0

PC15 

0.0

1.0

2.0

3.0

4.0

5.0

6.0

Millions 

PC14 

PC: 13, 13A 

PC12 

PC: 11, 11A 

Historical Shipments 

Total Shipments 

Figure ES.3.3	 Forecasted Shipments (Base Case) for Compact 

Refrigerators 

1.2

PC18
 

PC17
 

1.0 PC16 

0.0

0.2

0.4

0.6

0.8

Millions 

Historical Shipments 

Total Shipments 

Figure ES.3.4	 Forecasted Shipments (Base Case) for Compact 

Freezers 

ES-19 

EERE-2008-BT-STD-0012 COMMENT 22
ES.3.8 National Impact Analysis 

The NIA estimates the following national impacts from possible candidate standard 

levels for residential refrigeration products: (1) national energy savings (NES); (2) monetary 

value of energy savings to consumers of the considered products due to standards; (3) increased 

total installed costs to consumers of the considered products due to standards; and (4) the net 

present value (NPV) of energy savings (difference between value of energy savings and 

increased total installed costs). DOE prepared an NES spreadsheet model to forecast energy 

savings and national consumer economic costs and savings resulting from new standards. The 

model uses typical values for inputs. 

A key component of DOE’s estimates of NES and NPV is the trend in energy efficiency 

forecasted for the base case (without new standards) and each of the standards cases (with new 

standards). To forecast the base-case efficiency distribution for each representative product class, 

DOE accounted for change in the market shares of ENERGY STAR appliances based on 

historical trends. For its determination of standards-case efficiency distributions, DOE used a 

“roll-up + ENERGY STAR” scenario to establish the distribution of efficiencies for the year that 

amended standards are assumed to become effective (i.e., 2014) and subsequent years. DOE 

assumed that product efficiencies in the base case that did not meet the standard level under 

consideration would “roll up” to meet the new standard level in 2014. It further assumed that the 

ENERGY STAR program and related efforts would continue to promote efficient appliances 

after the introduction of amended standards in 2014, and that this would lead to increased market 

shares for products with efficiency above the standard level. Chapter 10 provides additional 

details on this and other aspects of the NIA analysis. 

To estimate the national impacts of all of the product classes considered in this 

rulemaking, DOE allocated the consumer equipment costs and annual energy consumption of the 

representative product classes analyzed in detail in the engineering and LCC and PBP analyses to 

the product classes associated with each representative product class. The following list indicates 

which product classes were associated with each of the representative product classes: 

•	 Top-mount refrigerator-freezers: product classes 1, 1A, 2, 3, 3A, and 6; represented 

by product class 3. 

•	 Bottom-mount refrigerator-freezers: product classes 5 and 5A; represented by product 

class 5. 

•	 Side-by-side refrigerator-freezers: product classes 4 and 7; represented by product 

class 7. 

•	 Upright freezers: product class 9 only. 

•	 Chest freezers: product classes 8, 10, and 10A; represented by product class 10. 

•	 Compact refrigerators: product classes 11, 11A, 12, 13, 13A, 14, and 15; represented 

by product class 11. 

•	 Compact freezers: product classes 16, 17, and 18; represented by product class 18. 

ES-20
 

EERE-2008-BT-STD-0012 COMMENT 22
 

ES.3.8.1 National Energy Savings 

DOE calculated annual NES as the difference between national energy consumption in 

the base case (without new efficiency standards) and in each higher efficiency standard case. 

DOE estimated energy consumption and savings based on site energy and converted the 

electricity consumption and savings to source energy. Cumulative energy savings are the sum of 

the annual NES, which DOE determined over specified periods. 

The NES results shown in Table ES.3.16 through Table ES.3.18 are cumulative to 2044 

and are shown as primary energy savings in quads (quadrillion Btu’s). 

Table ES.3.17 Standard-Size Refrigerator-Freezers: Cumulative NES Results (quads) 

Efficiency Level 

(percent less than 

baseline energy use) 

Top-Mount 

Refrigerator-Freezer* 

Bottom-Mount 

RefrigeratorFreezer** 

Side-by-Side 

RefrigeratorFreezer*** 

10% 1.10 0.04 0.31 

15% 1.69 0.06 0.73 

20% 2.35 0.20 1.31 

25% 3.01 0.37 1.91 

30% 3.65 0.53 2.50 

35% 4.20 0.57 2.93 

40% 4.78 0.73 3.35 

45% 5.28 0.77 -

* Includes product classes 1, 1A, 2, 3A, and 6 as well as product class 3. 

** Includes product class 5A as well as product class 5. 

*** Includes product class 4 as well as product class 7. 

Table ES.3.18 Standard-Size Freezers: Cumulative NES Results (quads) 

Efficiency Level 

(percent less than baseline 

energy use) Upright Freezers* Chest Freezers** 

10% 0.34 0.23 

15% 0.55 0.37 

20% 0.75 0.50 

25% 0.96 0.63 

30% 1.15 0.76 

35% 1.34 0.87 

40% 1.51 1.00 

45% 1.63 1.07 

* Includes product class 9 only. 

** Includes product classes 8 and 10A as well as product class 10. 

ES-21 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

Table ES.3.19 Compact Refrigerators and Freezers: Cumulative NES Results (quads) 

Efficiency Level 

(percent less than baseline 

energy use) Compact Refrigerators* Compact Freezers** 

10% 0.13 0.03 

15% 0.20 0.04 

20% 0.27 0.06 

25% 0.32 0.07 

30% 0.38 0.08 

35% 0.44 0.09 

40% 0.48 0.10 

45% 0.52 0.11 

* Includes product classes 11A, 12, 13, 13A, 14, and 15 as well as product class 11 

** Includes product classes 16 and 17 as well as product class 18 

ES.3.8.2 Net Present Value 

DOE calculated net monetary savings each year as the difference between total savings in 

operating costs and increases in total equipment costs in the base case and standards cases. DOE 

calculated savings over the life of the product. DOE used discount rates of 7 percent and 3 

percent to discount future costs and savings to the present. DOE calculated NPV as the 

difference between the present value of operating cost savings and the present value of increased 

total installed costs. The NPV results for the representative product classes are shown in Table 

ES.3.19 through Table ES.3.21 as the discounted value of the net savings in dollar terms. 

Table ES.3.20	 Standard-Size Refrigerator-Freezers: Discounted Cumulative NPV 

Results 

Efficiency 

Top-Mount RefrigeratorFreezer* Bottom-Mount 

Refrigerator-Freezer** 

Side-by-Side RefrigeratorFreezer*** 

Level 

(percent less 

than baseline 

energy use) 

3% Discount 

Rate 

(billion 

2008$) 

7% Discount 

Rate 

(billion 

2008$) 

3% Discount 

Rate 

(billion 

2008$) 

7% Discount 

Rate 

(billion 

2008$) 

3% Discount 

Rate 

(billion 

2008$) 

7% Discount 

Rate 

(billion 

2008$) 

10% 13.39 5.08 0.50 0.19 3.68 1.35 

15% 20.16 7.60 0.73 0.27 8.52 3.11 

20% 26.57 9.79 2.13 0.70 11.89 3.82 

25% 31.08 11.01 1.98 0.40 14.15 3.94 

30% 33.86 11.35 1.61 0.01 15.12 3.42 

35% 34.26 10.57 1.43 -0.19 16.17 3.20 

40% 32.78 8.75 0.60 -0.91 15.73 2.22 

45% 31.53 7.18 0.40 -1.12 - -

* Includes product classes 1, 1A, 2, 3A, and 6 as well as product class 3. 

** Includes product class 5A as well as product class 5. 

*** Includes product class 4 as well as product class 7. 

ES-22 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

Table ES.3.21 Standard-Size Freezers: Discounted Cumulative NPV Results 

Efficiency Level Upright Freezers* Chest Freezers** 

(percent less than 

baseline energy use) 

3% Discount Rate 

(billion 2008$) 

7% Discount Rate 

(billion 2008$) 

3% Discount Rate 

(billion 2008$) 

7% Discount Rate 

(billion 2008$) 

10% 4.52 1.59 3.11 1.10 

15% 7.21 2.53 4.78 1.68 

20% 9.92 3.48 6.04 2.03 

25% 12.23 4.23 7.68 2.60 

30% 14.28 4.86 9.14 3.07 

35% 15.82 5.25 9.61 3.06 

40% 16.62 5.29 11.01 3.52 

45% 16.54 4.98 10.51 3.09 

* Includes product class 9 only. 

** Includes product classes 8 and 10A as well as product class 10. 

Table ES.3.22	 Compact Refrigerators and Freezers: Discounted Cumulative NPV 

Results 

Efficiency Level 

(percent less than 

baseline energy use) 

Compact Refrigerators* Compact Freezers** 

3% Discount Rate 

(billion 2008$) 

7% Discount Rate 

(billion 2008$) 

3% Discount Rate 

(billion 2008$) 

7% Discount Rate 

(billion 2008$) 

10% 1.00 0.43 0.20 0.08 

15% 1.39 0.59 0.30 0.12 

20% 1.81 0.76 0.08 0.00 

25% 1.45 0.55 0.10 0.00 

30% 1.97 0.78 0.00 -0.06 

35% 2.12 0.83 0.09 -0.02 

40% 1.72 0.59 0.06 -0.05 

45% 0.92 0.17 0.01 -0.08 

* Includes product classes 11A, 12, 13, 13A, 14, and 15 as well as product class 11. 

** Includes product classes 16 and 17 as well as product class 18. 

ES.3.9 Preliminary Manufacturer Impact Analysis 

The preliminary MIA focuses on manufacturers of residential refrigeration products. 

Potential impacts include financial effects, both quantitative and qualitative, that might result 

from new energy conservation standards and lead to changes in manufacturing practices for 

refrigerators, refrigerator-freezers, and freezers. DOE identified potential impacts through 

interviews with manufacturers and other interested parties. Chapter 12 of the preliminary TSD 

includes details on the key issues DOE identified during the preliminary MIA. 

DOE found key issues regarding the following for residential refrigeration products: 

ES-23
 

EERE-2008-BT-STD-0012 COMMENT 22
• Increased conversion costs; 

• Impact to U.S. production and jobs; 

• Cumulative regulatory burden; 

• Impact to product utility; 

• Current economic conditions; 

• Circumvention and enforcement; and 

• Technical difficulty to achieve new standards 

DOE conducted the preliminary MIA by first identifying products, methods, and 

practices used in the residential refrigeration products industry. Next, DOE determined how 

energy efficiency improvements affect cost, production, and various other manufacturing 

metrics. Finally, DOE interviewed manufacturers for feedback. DOE developed and distributed a 

questionnaire for use during the interviews. At the beginning of the interview process, DOE 

interviewed manufacturers and adjusted the analysis as appropriate, based on the feedback 

received. During the interviews, DOE also examined any additional effects on competition, 

manufacturing capacity, direct employment, and the cumulative burden of other regulations 

affecting manufacturers, as well as several issues raised by individual manufacturers. 

ES.4 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT 

DOE is interested in receiving comments on all aspects of this preliminary analysis. DOE 

especially invites comments or data to improve DOE’s analysis, including data or information 

that will respond to the following questions or concerns that were raised in response to the 

framework document and in preparation of the preliminary TSD. 

ES.4.1 Use of the Proposed Designations for Product Classes 5A and 10A 

Two possible new product classes were identified in the framework document and 

designated product class numbers 19 and 20. DOE proposes to redesignate these product classes 

as 5A and 10A to maintain harmonization with Canadian Standards, as requested in comments 

received during the framework comment period. See chapter 2, section 2.2.1.1, of the 

preliminary TSD. 

ES.4.2 Establishment of Separate Product Classes for All-Refrigerators 

The proposed new energy test procedure uses new compartment temperatures. For 

refrigerators with freezer compartments and for refrigerator-freezers, the temperature of the fresh 

food compartment during the test would be reduced from 45  ̊F to 39  ̊F under the new test 

procedure. The freezer temperature for refrigerator-freezers would be reduced from 5  ̊F to 0  ̊F. 

ES-24
 

EERE-2008-BT-STD-0012 COMMENT 22
For both of these products, measured energy use would be significantly higher, in the range from 

12 to 15%. For all-refrigerators, the compartment temperature would be increased from 38  ̊F to 

39  ̊F under the new test procedure, which would reduce measured energy use by roughly 3%. 

Product classes 1, 3, 11, and 13 include products such as refrigerators with freezer compartments 

and refrigerator-freezers, whose energy use would increase, as well as all-refrigerators, whose 

energy use would decrease. In order to maintain a meaningful and fair energy conservation 

standard for these product classes, DOE proposes that new product classes be established for the 

all-refrigerators. DOE seeks comment on this proposal. 

ES.4.3 Possible Combination of Product Classes 1 and 2, and Product Classes 11 and 12 

Shipments of refrigerators and refrigerator-freezers of product classes 1 and 2 are very 

low, significantly less than 1% of the shipments of residential refrigeration products. DOE 

believes that the shipments of refrigerator-freezers of product class 12 are also very low. The 

energy standards for product classes 1 and 2 are currently identical. While the energy standard 

for product class 12 is considerably less stringent that the standard for product class 11, there is 

no clear technical basis that DOE can currently discern for the difference. Product classes 1 and 

11 include refrigerators and refrigerator-freezers with manual defrost. Product classes 2 and 12 

include refrigerator-freezers with partial automatic defrost. Both product class groups have 

manual defrost evaporators serving the freezer compartments. However, product classes 2 and 12 

include an evaporator serving the fresh food compartment that does not require manual defrost. 

Typically this evaporator would warm sufficiently during the compressor off-cycle to melt frost. 

For this reason, there is no defrost cycle involved that would add energy use. DOE invites 

comment on whether these pairs of product classes should be combined, thus eliminating product 

classes 2 and 12. 

ES.4.4 Approach for Development of Baseline Energy Use/Adjusted Volume Relationships 

under the Proposed Test Procedure 

In a separate rulemaking, DOE expects to propose new test procedures based in part on 

the updated version of AHAM Standard HRF-1-2008. The test procedures would include 

modified compartment temperatures and a modified volume calculation method. In general, if 

test procedure revisions affect the measured efficiency of a product, the required efficiency 

levels must be adjusted based on test results with the new test procedure for products which are 

minimally compliant under the previous test procedure. (U.S.C. 6293(e)(2)) AHAM provided 

data for some key product classes showing the differences in energy test results of the two test 

procedures. DOE developed curves relating energy use and adjusted volume for minimallycompliant products based on use of the modified test procedure for all of the product classes 

relying in part on the AHAM data. DOE proposes to use these curves, discussed in Chapter 5 of 

the preliminary TSD, as the basis for the new energy conservation standards to be proposed 

initially in the NOPR phase of the rulemaking. DOE invites comment on the approach used to 

develop the curves and the resulting energy use represented by the curves. 

ES-25
 

EERE-2008-BT-STD-0012 COMMENT 22
ES.4.5 Possible Modification of the Baseline Energy Use/Adjusted Volume Curve Slope 

During manufacturer interviews conducted as part of the preliminary process, some 

manufacturers indicated that some of the energy vs. adjusted volume curves of the current energy 

conservation standards for residential refrigeration products have slopes that are not consistent 

with actual energy trends. DOE concluded during the engineering analysis that the cost and 

energy analysis conducted for two different sizes of product of each product class was not 

sufficiently precise to allow accurate predictions of size-based differences in the cost-efficiency 

trends for the products analyzed. Hence, correction of the slopes of the energy vs. adjusted 

volume curves is not possible based on the differences in incremental cost curves of the two sizes 

analyzed for each product class. DOE conducted an energy use analysis to investigate this issue 

more directly. The analysis shows that the slope of the baseline-efficiency energy use curve may 

be too low for product class 5. Similarly, the slope of the curve for product class 4 may be too 

low (While DOE did not directly analyze this product class, the trend for product class 7 would 

apply to product class 4 with an adjustment for the TTD ice feature present in product class 7 -- 

TTD ice is not present in product class 4). The DOE analysis investigating this issue is discussed 

in Chapter 5. DOE invites comment on whether an adjustment to the slopes of the baseline 

energy use relationships based on proposed test procedures is warranted for any of the product 

classes and by how much. DOE requests information supporting comments indicating the need 

for such slope changes. 

ES.4.6 Variation of Product Characteristics as Compared with Teardown Products 

DOE selected representative refrigeration products for detailed investigation. This 

investigatory work encompassed a variety of activities, including reverse engineering, physical 

teardown, manufacturing cost analysis, energy use analysis, and cost-effectiveness analyses 

regarding energy-reducing design options. DOE requested detailed design data for refrigeration 

products during the framework phase of the work, as embodied in Table A-10 of the framework 

document. Manufacturers, however, did not provide data in response to this request. Such design 

data would have allowed consideration of the variation of product designs, particularly variation 

of the costs to achieve reductions in energy use. DOE requests comment on the variation of 

refrigeration product designs and the distribution of incremental costs to achieve energy use 

reductions. 

ES.4.7 Development of Energy Standards for Low-Volume Products 

The TSD describes possible approaches to the development of energy standards for lowvolume products which were not directly analyzed during the preliminary analysis. The percent 

reduction in energy use for most of these product classes would be based on the percentage 

reduction established for similar product classes. These approaches are presented in Chapter 2, 

Section 2.15. DOE requests comments on these approaches. 

ES.4.8 Field Energy Use of Standard-Size Refrigeration Products 

Energy use of a household’s refrigerator or freezer is known to vary depending on its 

operating conditions, the behavior of its users, and other factors. DOE characterized field energy 

ES-26
 

EERE-2008-BT-STD-0012 COMMENT 22
use of a refrigeration product by using a multiplicative ‘usage adjustment factor’ (UAF) that 

adjusts the energy use from its test energy consumption to reflect these factors. The household 

sample used to calculate life-cycle costs for standard-sized products exhibits a wide range of 

UAFs for each product class, with mean values ranging from 1.08 for product class 5 to 1.48 for 

product class 10. A literature survey conducted by DOE confirms that an average UAF over the 

lifetime of a refrigeration product is likely to be greater than one. This literature spans most of 

the last two decades, but relatively few studies have been published recently. DOE invites 

comment and additional data regarding the relationship between field and test energy 

consumption for contemporary refrigeration products. 

ES.4.9 Field Energy Use of Compact Refrigeration Products 

DOE did not find any usable data on the typical field energy consumption of compact 

products. Therefore, for compact refrigerators and freezers, DOE assumed that the average field 

energy use of units of the representative sizes used in its analysis is the same as the energy use 

calculated by the DOE test procedure. DOE assumed that the variability of energy use of 

compact products in the field is solely a function of volume. To represent the distribution of 

volumes in the field, DOE used data from the 2008 California Energy Commission appliance 

model database. DOE invites comment and additional data regarding the relationship between 

field and test energy consumption for compact refrigeration products. 

ES.4.10 Repair and Maintenance Costs 

Because DOE did not find any evidence that repair and maintenance costs change as 

refrigeration product efficiency increases, it did not include these costs in its analysis. DOE 

invites comment on this approach and requests any specific information showing the extent to 

which repair and maintenance costs change as refrigeration product efficiency increases beyond 

the baseline levels used in DOE’s analysis. 

ES.4.11 Lifetime of Compact Refrigeration Products 

When DOE applied the average lifetime for a compact refrigerator given in Appliance 

magazine (10 years) to historical shipments, its model yielded a compact refrigerator stock that 

was more than double the existing stock indicated by the EIA’s RECS and Commercial Building 

Energy Consumption Survey (CBECS). DOE therefore calibrated the average lifetime to match 

the existing stock of compact refrigerators as given by the surveys. The resulting calculated 

mean lifetime is 5.62 years. DOE invites comment on its approach for estimating the lifetime for 

compact refrigerators and freezers. 

ES.4.12 Base Case Efficiency Distributions 

To accurately estimate the share of consumers that would be affected by a standard at a 

particular efficiency level, DOE’s LCC and PBP analyses considered the projected distribution 

of product efficiencies that consumers would purchase in the base case (i.e., the case without 

amended energy efficiency standards). DOE’s projection takes into account growth in market 

ES-27
 

EERE-2008-BT-STD-0012 COMMENT 22
share of ENERGY STAR refrigeration products in the coming years. DOE invites comment on 

the approach used to forecast base-case market shares of the considered efficiency levels. 

ES.4.13 Forecasted Market Shares of Top-Mount vs. Side/Bottom-Mount RefrigeratorFreezers 

DOE developed a simple model to forecast the market share of top-mount refrigeratorfreezers relative to side- and bottom-mounted products. This model was based on the historical 

consumer preferences of homeowners as a whole, as well as high-income homeowners, the 

historical market share differences between rental and owner-occupied households, and historical 

market shares of top-, side- and bottom-mount products in total shipments. The model forecasts 

that the market share of top-mount refrigerator-freezers will fall slowly, reaching 58.3% in 2015, 

56.2% in 2025, and 54.7% in 2035, with the remainder of shipments divided between side- and 

bottom-mount products in a ratio fixed by their relative sales in 2008. DOE seeks comment on its 

approach. 

ES.4.14 Maturity of Vacuum Insulation Panels for High Volume Production 

The engineering analysis indicates that dramatic reductions in energy use are possible in 

many of the product classes. The reductions depend on use of a number of design options, 

including vacuum insulation panels (VIPs). VIPs are currently used in refrigeration products, 

indicating that this technology is a viable design option. The use of VIPs adds dramatically to 

the MSP estimates, up to $300 in the preliminary analyses. The LCC analysis indicates that 

efficiency levels incorporating VIPs are economically justified. Hence, DOE anticipates that 

standard levels may be proposed at levels requiring much more widespread use of VIPs in future 

products. DOE collected information regarding the viability of VIPs during the preliminary 

analysis. However, the importance of this technology to the preliminary results indicates that a 

more careful review is warranted of its viability for high volume production. DOE invites 

comments on this issue and also requests information that would allow such an assessment to be 

conducted. 

ES.4.15 Clarification of the Distinction between Manual Defrost and Automatic Defrost 

for All-Refrigerators 

DOE is considering adding product classes 1A and 3A for all-refrigerators with manual 

and automatic defrost. It is uncertain whether there are any products of the proposed product 

class 1A, because all-refrigerators typically use off-cycle defrost, which does not require manual 

initiation. Manual defrost “is accomplished by natural or manual means with manual initiation 

and manual termination of the over-all defrost operation”. AHAM HRF-1-1979 DOE requests 

comment on the interpretation that off-cycle defrost is a form of automatic defrost for allrefrigerators. DOE also requests comment on whether there are any all-refrigerator products on 

the market that use manual defrost. 

ES-28
 

EERE-2008-BT-STD-0012 COMMENT 22
ES.4.16 Analysis of Built-In Products 

Comments made during the framework meeting and comment period and discussion of 

potential addition of product classes for built-in products is discussed in Chapter 2 of the 

preliminary TSD. DOE seeks additional technical and cost information on built-in products that 

would aid in assessment of whether the costs to achieve higher efficiency levels are significantly 

higher with these products. 

ES.4.17 Technical Data for Alternative Foam-Blowing Agents 

Stakeholders indicated during the framework meeting and comment period that DOE 

should consider the effect of potential climate change legislation on the rulemaking analyses (see 

Chapter 2 of the preliminary TSD). DOE seeks up to date technical data on the resistivity 

differences and the impact to thermal performance of alternative foam-blowing agents. 

ES.4.18 Likely Scenarios for Alternative Foam-Blowing Agents 

DOE seeks comment on the likely scenarios for manufacturers, assuming that laws such 

as the current pending legislation banning HFC’s are passed. Specifically, DOE seeks 

information regarding the timing of switching to alternative agents. 

ES.4.19 Valuing Air-Borne Emission Reductions 

DOE will conduct an environmental assessment as part of the next phase of the standards 

rulemaking; the NOPR. The primary environmental effects of energy conservation standards for 

refrigeration products are to reduce power plant emissions resulting from reduced consumption 

of electricity. DOE will assess these environmental effects by using NEMS-BT to provide key 

inputs to its analysis. The portion of the environmental assessment that will be produced by 

NEMS-BT considers carbon dioxide (CO2), sulfur dioxide (SO2), nitrogen oxides (NOX), and 

mercury (Hg). DOE also plans on monetizing the emission reductions due to standards 

consistent with methods used in recent DOE standards rulemakings pertaining to refrigerated 

beverage vending machines and commercial clothes washers. For example, in the case of CO2, 

DOE used values ranging from $5 to $55 per metric ton of CO2 to value the emission savings due 

to standards. DOE invites comments on the approaches for monetizing the emission savings due 

to energy conservation standards. 

ES-29
 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 1. INTRODUCTION 

TABLE OF CONTENTS 

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

1.2 OVERVIEW OF STANDARDS FOR RESIDENTIAL REFRIGERATORS, 

REFRIGERATOR-FREEZERS, AND FREEZERS ....................................................... 1-1 

1.3 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS...................... 1-3 

1.4 STRUCTURE OF THE DOCUMENT............................................................................ 1-6 

LIST OF TABLES 

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

1-i 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

CHAPTER 1. INTRODUCTION 

1.1 PURPOSE OF THE DOCUMENT 

This preliminary technical support document (preliminary TSD) is a stand-alone report 

that provides the technical analyses and results supporting the information presented in the 

preliminary notice of public meeting (NOPM) and executive summary for residential 

refrigerators, refrigerator-freezers, and freezers. This preliminary TSD reports on the preliminary 

activities and analyses conducted in the period preceding the notice of proposed rulemaking 

(NOPR) of this rulemaking. 

1.2	 OVERVIEW OF STANDARDS FOR RESIDENTIAL REFRIGERATORS, 

REFRIGERATOR-FREEZERS, AND FREEZERS 

The Energy Policy and Conservation Act (EPCA) of 1975, Pub. L. 94-163 (42 United 

States Code (U.S.C.) 6291–6309), established an energy conservation program for major 

household appliances. The National Energy Conservation Policy Act of 1978 (NECPA), Pub. L. 

95-619, amended EPCA to add Part Ca

 of Title III (42 U.S.C. 6311–6317), which established an 

energy conservation program for certain industrial equipment. Additional amendments to EPCA 

give DOE the authority to regulate the energy efficiency of several products, including 

residential refrigerators, refrigerator-freezers, and freezers—the products that are the focus of 

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

1987 (NAECA), Pub. L. 100-12, established energy conservation standards for refrigerators, 

refrigerator-freezers, and freezers, as well as requirements for determining whether these 

standards should be amended. (42 U.S.C. 6295(b)) 

NAECA first established performance standards for residential refrigerators, refrigeratorfreezers, and freezers, and further required that DOE conduct two cycles of rulemakings to 

determine if more stringent standards are justified.b

 (42 U.S.C. 6295(b)) On November 17, 1989, 

DOE published a final rule in the Federal Register updating the performance standards; the new 

standards became effective on January 1, 1993. 54 FR 47916. Subsequent to this final rule, DOE 

determined that new standards for some of the product classes were based on incomplete data 

and incorrect analysis. As a result, DOE published a correction that amended the new standards 

for three product classes: (1) refrigerators and refrigerator-freezers with manual defrost, (2) 

refrigerator-freezers—automatic defrost with bottom-mounted freezer but without through-thedoor (TTD) ice service, and (3) chest freezers and all other freezers. 55 FR 42845 (Oct. 24, 

1990). DOE updated the performance standards once again for refrigerators, refrigeratora Part C has been redesignated Part A-1 

b	 Definition of “refrigerators”, “refrigerator-freezers”, and “freezers” is provided in chapter 3 of the preliminary 

TSD. 

1-1 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

freezers, and freezers by publishing a final rule in the Federal Register on April 28, 1997. 62 FR 

23102. The new standards became effective on July 1, 2001. By completing a second standards 

rulemaking, DOE had fulfilled its legislative requirement to conduct two cycles of standards 

rulemakings. 

Stakeholders submitted a petition in 2004 requesting that DOE conduct another 

rulemaking to amend the standards for residential refrigerator-freezers. In April 2005, DOE 

granted the petition and conducted a limited set of analyses to assess the potential energy savings 

and economic benefit of new standards. DOE issued a report in October 2005 detailing the 

analyses.1 The analysis examined the technological and economic feasibility of new standards set 

at Energy Star levels effective in 2005 for the two most popular product classes of refrigerators: 

top-mount refrigerator-freezers without TTD features and side-mount refrigerator-freezers with 

TTD features. DOE confined its updated analysis to these two classes because they accounted for 

a majority of current product shipments. Depending on assumptions about the impact that 

standards would have on market efficiency, DOE estimated that amended standards at the 2005 

Energy Star levels would yield between 2.4 to 3.4 quads,c

 with an associated economic impact to 

the Nation ranging from a burden or cost of $1.2 billion to a benefit or savings of $3.3 billion.d 

DOE published draft data sheets containing energy-savings potentials for refrigeratorfreezers in October 2005 as part of its fiscal year 2006 schedule-setting process. These data 

sheets summarized the following in table format: (1) the potential energy savings from 

regulatory action in cumulative quads from 2010 to 2035, (2) the potential economic benefits or 

burdens, (3) the potential environmental or energy security benefits, (4) the status of required 

changes to test procedures, (5) other regulatory actions, (6) recommendations by interested 

parties, (7) evidence of market-driven or voluntary efficiency improvements, (8) regulatory 

issues, and (9) the 2005 priority. The data sheets for refrigerators and refrigerator-freezers were 

based on the October 2005 draft technical report analyzing potential new amended energy 

conservation standards for residential refrigerator-freezers described above. This report and the 

associated data sheets provided input to the setting of priorities for rulemakings activities. Other 

products were given a higher priority, and limited rulemaking work on refrigerators and freezers 

was carried out in the following years prior to the enactment of the Energy Independence and 

Security Act of 2007 (EISA). 

EISA, signed into law on December 19, 2007, requires that DOE publish a final rule no 

later than December 31, 2010, to determine whether to amend the standards in effect for 

refrigerators, refrigerator-freezers, and freezers manufactured on or after January 1, 2014. As a 

result, DOE is embarking on a standards rulemaking for these products to comply with the 

requirements of EISA. 

A quad represents a quadrillion Btu (or 1015 Btu). 

d Economic impact based on a discount rate of 7 percent real. 

1-2 

c 

EERE-2008-BT-STD-0012 COMMENT 22
1.3 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS 

Under EPCA, when DOE is studying new or amended standards, it must consider, to the 

greatest extent practicable, the following seven factors (42 U.S.C. 6295 (o)(2)(B)(i)): 

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

products; 

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

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

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

of the standard; 

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

imposition of the standard; 

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

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

6) the need for national energy conservation; and 

7) other factors the Secretary considers relevant. 

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

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

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

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

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

comment period in each stage of the rulemaking. Beginning with the Framework Document and 

during subsequent comment periods, interactions among stakeholders provide a balanced 

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

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

standard, it must first solicit comments on the proposed standard. (42 U.S.C. 6313(a)(6)(B)(i)) 

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

energy and be technologically feasible and economically justified. (42 U.S.C. 6313(a)(6)(A)) To 

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

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

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

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

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

Federal Register. The first of the rulemaking notices is a NOPM, which is designed to publicly 

1-3 

EERE-2008-BT-STD-0012 COMMENT 22
vet the models and tools used in the preliminary rulemaking and to facilitate public participation 

before the NOPR stage. The second notice is the NOPR, which presents a discussion of 

comments received in response to the NOPM and the preliminary analyses and analytical tools; 

analyses of the impacts of potential amended energy conservation standards on consumers, 

manufacturers, and the Nation; DOE’s weighting of these impacts of amended energy 

conservation standards; and the proposed energy conservation standards for each product. The 

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

the NOPR; the revised analyses; DOE’s weighting of these impacts; the amended energy 

conservation standards DOE is adopting for each product; and the effective dates of the amended 

energy conservation standards. 

In September 2008, DOE published a notice of public meeting and availability of the 

framework document. 73 FR 54089 (September 18, 2008). The framework document, 

Rulemaking Framework for Residential Refrigerators, Refrigerator-Freezers, and Freezers, 

describes the procedural and analytical approaches DOE anticipated using to evaluate the 

establishment of amended energy conservation standards for these products. This document is 

available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/refrigerator_freezer 

_framework.pdf. 

Subsequently, DOE held a public meeting on September 29, 2008, to discuss procedural 

and analytical approaches to the rulemaking. In addition, DOE used the public meeting to inform 

and facilitate involvement of interested parties in the rulemaking process. The analytical 

framework presented at the public meeting described the different analyses, such as the 

engineering analysis and the consumer economic analyses (i.e., the life-cycle cost (LCC) and 

payback period (PBB) analyses), the methods proposed for conducting them, and the 

relationships among the various analyses. 

1-4 

EERE-2008-BT-STD-0012 COMMENT 22
Table 1.3.1 Analyses Under the Process Rule 

Preliminary Analyses NOPR Final Rule 

Market and technology assessment Revised ANOPR analyses Revised analyses 

Screening analysis Life-cycle cost sub-group 

analysis 

Engineering analysis Manufacturer impact analysis 

Energy and water use determination Utility impact analysis 

Markups for equipment price 

determination 

Environmental assessment 

Life-cycle cost and payback period 

analysis 

Employment impact analysis 

Shipments analysis Regulatory impact analysis 

National impact analysis 

Preliminary manufacturer impact analysis 

During the September 2008 public meeting, interested parties commented about 

numerous issues relating to each one of the analyses listed in Table 1.3.1. Comments from 

interested parties submitted during the framework document comment period elaborated on the 

issues raised during the public meeting. DOE attempted to address these issues during its 

preliminary analyses and summarized the comments and DOE’s responses in chapter 2 of the 

preliminary TSD. 

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

interviews with manufacturers of the residential refrigerators, refrigerator-freezers, and freezers 

considered in this rulemaking as part of the engineering analysis. DOE selected companies that 

represented production of all types of products, ranging from small to large manufacturers, and 

included the Association of Home Appliance Manufacturers (AHAM) member companies. DOE 

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

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

impact analysis; (3) provide an opportunity, early in the rulemaking process, to express 

manufacturers’ concerns to DOE; and (4) foster cooperation between manufacturers and DOE. 

DOE incorporated the information gathered during the engineering interviews with 

manufacturers into its engineering analysis (Chapter 5) and the preliminary manufacturer impact 

analysis (Chapter 12). Following the publication of the preliminary analyses and the NOPM 

public meeting, DOE intends to hold additional meetings with manufacturers as part of the 

consultative process for the manufacturer impact analysis conducted during the NOPR phase of 

the rulemaking. 

DOE developed spreadsheets for the engineering, LCC, PBP, and national impact 

analyses for each product. For each product, DOE developed an LCC spreadsheet that calculates 

1-5 

EERE-2008-BT-STD-0012 COMMENT 22
the LCC and PBP at various energy efficiency levels. DOE also developed a national impact 

analysis spreadsheet that calculates the national energy savings (NES) and national net present 

values (NPVs) at various energy efficiency levels. This spreadsheet includes a model that 

forecasts the impacts of amended energy conservation standards at various levels on product 

shipments. All of these spreadsheets are available on the DOE website for refrigerators and 

freezers 

(http://www1.eere.energy.gov/buildings/appliance_standards/residential/refrigerators_freezers.ht 

ml). 

1.4 STRUCTURE OF THE DOCUMENT 

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

consists of fourteen chapters, an environmental assessment, a regulatory impact analysis, and 

appendices. 

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

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

document. 

Chapter 2 Analytical Framework: describes the rulemaking process. 

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

considered products and the technologies available for increasing 

equipment efficiency. 

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

efficiency of the considered products, and determines which technology 

options are viable for consideration in the engineering analysis. 

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

relationship between increased manufacturer price and increased 

efficiency. 

Chapter 6 Markups for Equipment Price Determination: discusses the methods 

used for establishing markups for converting manufacturer prices to 

customer equipment prices. 

Chapter 7 Energy Use Determination: discusses the process used for generating 

energy-use estimates for the considered products as a function of 

standard levels. 

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

standards on individual customers and users of the equipment and 

1-6 

EERE-2008-BT-STD-0012 COMMENT 22
compares the LCC and PBP of equipment with and without higher 

efficiency standards. 

Chapter 9 Shipments Analysis: discusses the methods used for forecasting 

shipments with and without higher efficiency standards, including how 

equipment purchase decisions are economically influenced and how 

DOE models this relationship with econometric equations. 

Chapter 10 National Impact Analysis: discusses the methods used for forecasting 

national energy consumption and national economic impacts based on 

estimates of future equipment efficiency, new construction and building 

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

efficiency standards. 

Chapter 11 Life-Cycle Cost Subgroup Analysis: discusses the effects of standards 

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

equipment with and without higher efficiency standards for these 

consumers. 

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

finances and profitability of equipment manufacturers. 

Chapter 13 Utility Impact Analysis: discusses the effects of standards on electric 

and gas utilities. 

Chapter 14 Employment Impact Analysis: discusses the effects of standards on 

national employment. 

Environmental Assessment for Residential Refrigerators, Refrigerator-Freezers, and 

Freezers: discusses the effects of standards on three pollutants—sulfur 

dioxide (SO2), nitrogen oxides (NOx), and mercury—as well as carbon 

emissions. 

Regulatory Impact Analysis for Residential Refrigerators, Refrigerator-Freezers, and 

Freezers: discusses the impact of non-regulatory alternatives to 

efficiency standards. 

Appendix 5-A Engineering Data 

Appendix 5-B ERA Model Development and WinERA User Manual 

Appendix 7-A Literature Survey of Energy Consumption by Residential RefrigeratorFreezers 

1-7 

EERE-2008-BT-STD-0012 COMMENT 22
Appendix 7-B Data for Estimating Distribution of Refrigerator and Freezer Size in the 

RECS Sample 

Appendix 8-A User Instructions for LCC and PBP Spreadsheets 

Appendix 8-B Uncertainty and Variability 

Appendix 8-C Consumer Retail Prices for Baseline Residential Refrigerator-Freezers 

and Freezers 

Appendix 8-D Household Discount Rate Distributions 

Appendix 9-A Relative Price Elasticity of Demand for Appliances 

Appendix 10-A User Instructions for Shipments and NIA Spreadsheets 

Appendix 10-B National Equipment and Operating Costs 

Appendix 12-A MIA (Preliminary MIA Questionaire) 

1-8 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

1 

REFERENCES 

U.S. Department of Energy. Technical Report: Analysis of Amended Energy Conservation 

Standards for Residential Refrigerator-Freezers. October 2005. 

<http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/refrigerator_report_1.pdf > 

1-9 

EERE-2008-BT-STD-0012 COMMENT 22
2-i

CHAPTER 2. ANALYTICAL FRAMEWORK, COMMENTS FROM 

INTERESTED PARTIES, AND DOE RESPONSES 

TABLE OF CONTENTS 

2.1 INTRODUCTION ........................................................................................................... 2-1

2.2 MARKET AND TECHNOLOGY ASSESSMENT ........................................................ 2-2

2.2.1 Definitions............................................................................................................ 2-3

2.2.1.1 Automatic Defrost Refrigerator-Freezers with Bottom-Mounted 

Freezer and with TTD Ice Service and Chest Freezers with Automatic 

Defrost2-4

2.2.1.2 Refrigeration Products with Convertible Compartments............................... 2-4

2.2.2 Product Classes and Scope of Coverage.............................................................. 2-5

2.2.2.1 Built-In Refrigeration Products...................................................................... 2-5

2.2.2.2 Wine Storage Products................................................................................... 2-8

2.2.3 Technology Assessment....................................................................................... 2-8

2.3 SCREENING ANALYSIS .............................................................................................. 2-9

2.3.1 Screening Methodology....................................................................................... 2-9

2.3.2 Alternative Foam-Blowing Agents.................................................................... 2-10

2.3.3 Alternative Refrigerants..................................................................................... 2-11

2.4 ENGINEERING ANALYSIS........................................................................................ 2-11

2.4.1 Efficiency Levels ............................................................................................... 2-12

2.4.2 Compartment Temperatures............................................................................... 2-14

2.4.3 Product Classes .................................................................................................. 2-14

2.4.4 Manufacturing Cost Analysis ............................................................................ 2-15

2.5 MARKUPS TO DETERMINE PRODUCT PRICE...................................................... 2-15

2.6 ENERGY USE CHARACTERIZATION ..................................................................... 2-16

2.7 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES .................................. 2-17

2.7.1 Retail Prices ....................................................................................................... 2-18

2.7.2 Energy Prices ..................................................................................................... 2-19

2.7.3 Maintenance and Repair Costs........................................................................... 2-19

2.7.4 Product Lifetime ................................................................................................ 2-20

2.7.5 Product Energy Efficiency Distribution in the Base Case................................. 2-20

2.8 NATIONAL IMPACT ANALYSIS.............................................................................. 2-21

2.8.1 Shipments Analysis............................................................................................ 2-21

2.8.2 Efficiency Scenarios and Trends ....................................................................... 2-21

2.8.3 National Energy Savings Analysis..................................................................... 2-22

2.8.4 Net Present Value Analysis ............................................................................... 2-22

2.9 LIFE-CYCLE COST SUBGROUP ANALYSIS .......................................................... 2-24

2.10 PRELIMINARY MANUFACTURER IMPACT ANALYSIS ..................................... 2-24

2.10.1 Industry Cash-Flow Analysis............................................................................. 2-26

2.10.2 Manufacturer Subgroup Analysis ...................................................................... 2-26

2.10.3 Competitive Impacts Assessment ...................................................................... 2-27

2.10.4 Cumulative Regulatory Burden ......................................................................... 2-27

2.10.5 Preliminary Results for the Manufacturer Impact Analysis .............................. 2-28

EERE-2008-BT-STD-0012 COMMENT 22
2-ii

2.11 UTILITY IMPACT ANALYSIS................................................................................... 2-28

2.12 ENVIRONMENTAL IMPACT ANALYSIS................................................................ 2-29

2.13 EMPLOYMENT IMPACT ANALYSIS....................................................................... 2-31

2.14 REGULATORY IMPACT ANALYSIS........................................................................ 2-31

2.15 DEVELOPMENT OF STANDARDS FOR LOW-VOLUME PRODUCT 

CLASSES ...................................................................................................................... 2-32

LIST OF TABLES 

Table 2.2.1 Typical Cost Differential for Built-in Product ENERGY STAR Compliance 

as Compared with a Conventional Product.......................................................... 2-7

Table 2.15.1 Extrapolation of Standards for Standard-Size Refrigerators and RefrigeratorFreezers.............................................................................................................. 2-33

Table 2.15.2 Extrapolation of Standards for Standard-Size Freezers........................................ 2-34

Table 2.15.3 Extrapolation of Standards for Compact Refrigerators, RefrigeratorFreezers, and Freezers........................................................................................ 2-35

LIST OF FIGURES 

Figure 2.15.1 Current Product Class 3 Products Listed in the ENERGY STAR Database....... 2-34

EERE-2008-BT-STD-0012 COMMENT 22
2-1

CHAPTER 2. ANALYTICAL FRAMEWORK, COMMENTS FROM 

INTERESTED PARTIES, AND DOE RESPONSES 

2.1 INTRODUCTION 

 Section 6295(o)(2)(A) of 42 United States Code (U.S.C.) requires the U.S. Department of 

Energy (DOE) to set forth energy conservation standards that are technologically feasible and 

economically justified, and would achieve the maximum improvement in energy efficiency. This 

chapter provides a description of the general analytical framework that DOE uses in developing 

such standards. The analytical framework is a description of the methodology, the analytical 

tools, and relationships among the various analyses that are part of this rulemaking. For example, 

the methodology that addresses the statutory requirement for economic justification includes 

analyses of life-cycle cost (LCC), economic impact on manufacturers and users, national 

benefits, impacts, if any, on utility companies, and impacts, if any, from lessening competition 

among manufacturers. 

 

 The analyses performed as part of the preliminary analysis stage and reported in this 

preliminary technical support document (preliminary TSD) are listed below. 

 A market and technology assessment to characterize the relevant product markets and 

existing technology options, including prototype designs. 

 A screening analysis to review each technology option and determine if it: is 

technologically feasible; is practical to manufacture, install, and service; would adversely 

affect product utility or product availability; or would have adverse impacts on health and 

safety. 

 An engineering analysis to develop cost-efficiency relationships that show the 

manufacturer’s cost of achieving increased efficiency. DOE determines the increased cost 

to the consumer through an analysis of engineering markups, which convert manufacturer 

production cost (MPC) to manufacturer selling price (MSP). 

 An energy use analysis to determine the annual energy use of the considered products. 

 LCC and payback period (PBP) analyses to calculate, at the consumer level, the 

discounted savings in operating costs (less maintenance and repair costs) throughout the 

estimated average life of the covered products, compared to any increase in the installed 

cost for the products likely to result directly from imposition of the standard. 

 A shipments analysis to forecast product shipments, which then are used to calculate the 

national impacts of standards on energy, net present value (NPV), and future 

manufacturer cash flows. 

 A national impact analysis (NIA) to assess the aggregate impacts at the national level of 

the NPV of total consumer LCC and national energy savings (NES). 

 A preliminary manufacturer impact analysis to assess the potential impacts of energy 

conservation standards on manufacturers, such as impacts on capital conversion 

expenditures, marketing costs, shipments, and research and development costs. 

 

EERE-2008-BT-STD-0012 COMMENT 22
2-2

 The analyses DOE will perform in the subsequent Notice of Proposed Rulemaking 

(NOPR) stage include those listed below. In addition, DOE will revise the analyses it performed 

during the preliminary analysis stage based on comments and new information received. 

 An LCC subgroup analysis to evaluate variations in customer characteristics that might 

cause a standard to affect particular consumer sub-populations, such as low-income 

households, differently than the overall population. 

 A manufacturer impact analysis to estimate the financial impact of standards on 

manufacturers and to calculate impacts on competition, employment, and manufacturing 

capacity. 

 A utility impact analysis to estimate the effects of proposed standards on electric, gas, or 

oil utilities. 

 An employment impact analysis to assess the aggregate impacts on national employment. 

 An environmental impact analysis to provide estimates of the effects of amended energy 

conservation standards on emissions of carbon (CO2), sulfur dioxide (SO2), nitrogen 

oxides (NOx), and mercury. 

 A regulatory impact analysis to present major alternatives to proposed amended energy 

conservation standards that could achieve substantially the same regulatory goal at a 

lower cost. 

 

 DOE developed this analytical framework and documented its findings in the 

Rulemaking Framework Document for Refrigerators, Refrigerator-Freezers, and Freezers 

(September 18, 2008). DOE presented the analytical approach to interested parties during a 

public meeting held on September 29, 2008. The framework document is available at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/refrigerators_freezers.ht

ml. 

 In response to the publication of the framework document and the framework public 

meeting, DOE received numerous comments from interested parties regarding DOE’s analytical 

approach. This chapter (chapter 2) of the preliminary TSD summarizes the key comments DOE 

received from interested parties and describes DOE’s responses to those comments. In addition, 

in subsequent sections of this chapter, DOE has summarized any significant changes in analytical 

approach made since publishing the framework document that DOE used in its preliminary 

analyses. Lastly, in the executive summary of the preliminary TSD, DOE identified a number of 

issues for which DOE seeks public comment. DOE has explained each of those issues in the 

relevant analysis sections below. 

2.2 MARKET AND TECHNOLOGY ASSESSMENT 

 When DOE begins an energy conservation standards rulemaking, it develops information 

that provides an overall picture of the market for the products considered, including the nature of 

the products, the industry structure, and market characteristics for the products. This activity 

consists of both quantitative and qualitative efforts based primarily on publicly available 

EERE-2008-BT-STD-0012 COMMENT 22
2-3

information. The subjects addressed in the market assessment included manufacturers, trade 

associations, and the quantities and types of products sold and offered for sale. DOE examined 

manufacturers of residential refrigeration products, which included both large and small and 

foreign and domestic manufacturers. DOE also examined data supplied by the key trade 

association for this product category, the Association of Home Appliance Manufacturers 

(AHAM). DOE also reviewed shipment data collected by AHAM and Appliance Magazine. 

Finally, DOE also reviewed other energy efficiency programs from utilities, individual states, 

and other organizations. Chapter 3 of the preliminary TSD provides additional details on the 

market and technology assessment. 

 DOE reviewed relevant literature and interviewed manufacturers to develop an overall 

picture of the residential refrigeration products industry in the United States. Industry 

publications and trade journals, government agencies, and trade organizations provided the bulk 

of the information, including: (1) manufacturers and their market shares; (2) shipments by 

product type (i.e., refrigerator, freezer, etc.); (3) product information; and (4) industry trends. 

 

 Subsequent sections of this chapter of the preliminary TSD describe the comments DOE 

received in response to its review of the market for the framework document. The analysis 

developed as part of the market and technology assessment is described in chapter 3 of the 

preliminary TSD. 

2.2.1 Definitions 

In the framework document, DOE delineated 20 different product classes for residential 

refrigeration products. Of these, 18 product classes based on the following characteristics are 

already contained in the CFR: type of unit (refrigerator, refrigerator-freezer, or freezer), 

geometric configuration for refrigerator-freezers (freezer mounting on top, side, or bottom), size 

of the cabinet (standard or compact), type of defrost system (manual, partial, or automatic), and 

presence or absence of through-the-door (TTD) ice service. DOE proposed two additional 

product classes (designated 19 and 20 in the framework document) beyond those presented in the 

CFR: automatic defrost refrigerator-freezers with bottom-mounted freezer and TTD ice service 

and chest freezers with automatic defrost. 

DOE received comments on the product definitions presented in the framework 

document. In response, DOE reviewed the definitions for refrigerators, refrigerator-freezers, and 

freezers to determine scope of coverage as it pertains to the new product classes designated 19 

and 20 in the framework document, and examined the DOE refrigerator test procedure to 

determine product classification for products with convertible compartments. Discussion of these 

issues is presented below. 

EERE-2008-BT-STD-0012 COMMENT 22
2-4

2.2.1.1 Automatic Defrost Refrigerator-Freezers with Bottom-Mounted Freezer 

and with TTD Ice Service and Chest Freezers with Automatic Defrost 

DOE received several comments regarding the classification of automatic defrost 

refrigerator-freezers with bottom-mounted freezer and TTD ice service. AHAM stated that DOE 

should re-label its proposed product class 19 as product class 5A so as to be consistent with 

Canadian product class definitions. (AHAM, No. 11 at p. 3) Natural Resources Canada (NRCan) 

agreed with that view and added that DOE should classify its proposed product class 20 as 

product class 10A. (NRCan, No. 16 at pp. 2-3) 

DOE believes that harmonization with international standards is important to reduce the 

costs of compliance and should be done whenever possible. DOE concurs with AHAM and 

NRCan and has re-designated product classes 19 and 20 as product classes 5A and 10A, 

respectively, to maintain consistency with Canadian standards. 

2.2.1.2 Refrigeration Products with Convertible Compartments 

Interested parties submitted a number of comments about convertible compartments to 

DOE. The American Council for an Energy-Efficient Economy (ACEEE), the Appliance 

Standards Awareness Project (ASAP), the Consumer Federation of America (CFA), the National 

Consumer Law Center (NCLC), the Natural Resources Defense Council (NRDC), the Northeast 

Energy Efficiency Partnerships (NEEP), the Northwest Power and Conservation Council 

(NPCC), Pacific Gas and Electric (PG&E), and Southern California Edison (SCE) submitted a 

joint comment to DOE, hereafter referred to as the “Joint Comment,” stating that: (1) the test 

procedure should be updated to reflect product configurations that are currently on the market; 

(2) convertible bottom-drawer refrigerator-freezers should be rated with the convertible drawer 

operating as a freezer, which is not the way some of these products have been rated for 

ENERGY STAR; and (3) the convertible bottom-drawer refrigerator-freezer should be rated as 

bottom-mount refrigerator-freezer (product class 5A). (Joint Comment, No. 10 at pp. 2,3) 

Whirlpool Corporation (Whirlpool) agreed that convertible bottom-drawer products 

should be considered to be “classification 19”, adding that units with convertible compartments 

must be tested in their highest-energy state. (Whirlpool, Public Meeting Transcript, No. 7 at p. 

62-63, No. 17 at p. 4) However, both Whirlpool and General Electric (GE) clarified that testing 

of a convertible compartment as a freezer may define the product as something other than a 

bottom-mount refrigerator-freezer with TTD ice, and that the product should be rated the way it 

is tested. (Whirlpool, Public Meeting Transcript, No. 7 at p. 63-64; GE, Public Meeting 

Transcript, No. 7 at p. 63-64) AHAM made a similar statement, adding that a convertible 

automatic defrost bottom-mount refrigerator-freezer equipped with no ice or water dispenser 

should be classified under product class 5 and that it should be tested with the convertible 

compartment operating as a freezer compartment in one test and as a fresh food compartment in 

a second test to determine which configuration has the highest energy use. (AHAM, No. 11 at p. 

4) 

EERE-2008-BT-STD-0012 COMMENT 22
2-5

Several of the comments noted that the requirement to test a convertible compartment in 

its highest-energy state comes from AHAM Standard HRF-1, the 1979 edition of which is 

referenced by the current DOE energy test procedure for refrigerators and refrigerator-freezers. 

DOE has learned that the convertible bottom-drawer product that prompted the question 

posed in the framework document is no longer on the market, but that a different product with 

convertible compartments was introduced by another manufacturer. This second product is rated 

in the ENERGY STAR database with one of the convertible compartments operating as a freezer 

compartment, and one operating as a fresh food compartment. DOE does not intend at this time 

to establish a new product class based on such a configuration. DOE agrees with stakeholder 

comments regarding the requirement that a convertible-compartment product be rated with the 

compartment in its highest energy-use position under the current DOE energy test procedures. In 

the NOPR addressing possible amendments to the test procedure, DOE considers whether the 

test procedure should be modified to improve clarity regarding this test requirement. 

DOE further notes that issues associated with multiple compartments and/or separate 

temperature control of drawers or otherwise isolated spaces within compartments will present a 

challenge to the energy test procedure that will require consideration as such features are more 

frequently added to products. For example, the test procedure does not indicate clearly how to 

adjust temperature setpoints and how to average compartment temperatures for a refrigeratorfreezer that has multiple fresh food compartments, multiple freezer compartments, or large 

internal sub-compartments that have separate temperature control. DOE notes that working 

Group 12 of Technical Committee 59 of the International Electrotechnical Commission (IEC) is 

developing IEC 62552, an international test procedure for refrigerators, refrigerator-freezers, and 

freezers. The issue of establishing test procedures to accurately address such product features has 

been discussed as part of the IEC test procedure development. DOE anticipates that future DOE 

energy test revisions will consider approaches adopted by the IEC test procedure to address these 

issues. 

2.2.2 Product Classes and Scope of Coverage 

 When evaluating and establishing energy conservation standards, DOE generally divides 

covered products into product classes by the type of energy used, capacity, or performancerelated features that affect efficiency. Different energy conservation standards may apply to 

different product classes. (42 U.S.C. 6295(q)) 

 DOE received several comments from interested parties regarding the product classes and 

their organization. Specifically, DOE received comments regarding whether to include built-in 

refrigeration products and wine storage products as additional product classes. 

2.2.2.1 Built-In Refrigeration Products 

 DOE received several comments on the inclusion of built-in refrigeration products as a 

separate product class. Sub Zero-Wolf, Inc. (Sub-Zero) requested that DOE establish separate 

product classes for built-in refrigeration products because they provide distinct utility and have 

EERE-2008-BT-STD-0012 COMMENT 22
2-6

limited potential for energy improvement compared to conventional freestanding units. Sub-Zero 

cited the distinction made for compact products in the previous refrigerator energy conservation 

standard rulemaking as an example of establishment of separate product classes for products for 

which options for efficiency improvements are limited. Sub-Zero also noted that built-in 

products are a niche market with low production volumes, comprising perhaps 1.5% of all 

residential refrigeration product shipments. (Sub-Zero, Public Meeting Transcript, No. 7 at pp. 

61-62 and No. 9 at pp. 1-3) The Edison Electric Institute (EEI) agreed, suggesting that DOE 

include built-in products as a separate product class. (EEI, No. 13 at p. 3) The Joint Comment 

disagreed, stating that DOE should not include built-in refrigeration products as a separate 

product class because built-ins provide the same service and amenity to consumers as standalone 

units, and they believe that manufacturers will find ways to make built-ins that meet performance 

standards similar to standalone units. The Joint Comment also notes that built-in units can 

already exceed ENERGY STAR and the Consortium for Energy Efficiency (CEE) Tier 1 and 

Tier 2 efficiency levels. (Joint Comment, No. 10 at p. 3), 

Sub-Zero further detailed the request for built-in product classes in a written comment. 

(Sub-Zero, No. 9 at p. 1-3) This comment suggests the following possible built-in product 

classes. 

 Built-in auto defrost top mount refrigerator-freezer w/o TTD ice and auto defrost allrefrigerators 

 Built-in auto defrost top mount refrigerator-freezer w/TTD ice 

 Built-in auto defrost bottom mount refrigerator-freezer w/o TTD ice 

 Built-in auto defrost bottom mount refrigerator-freezer w/TTD ice 

 Built-in auto defrost side-by-side refrigerator-freezer w/o TTD ice 

 Built-in auto defrost side-by-side refrigerator-freezer w/TTD ice 

 Built-in auto defrost upright freezer 

 Built-in compact refrigerators, refrigerator-freezers, and freezers 

 

Sub-Zero also pointed out in the written comment a number of design differences 

between built-in products and conventional products that make achieving higher efficiency levels 

more difficult for built-in products. (Sub-Zero, No. 9 at p. 2) These include the following. 

 More doors and drawers than conventional units, which leads to greater gasket length and 

door frame/gasket thermal load. 

 Limited access to condenser airflow since the products must be designed to be constrained by 

installation between cabinets. 

 More firm constraints on increases in exterior dimensions to allow increase in insulation 

thickness. 

 Use of glass doors. 

 Design for multiple compartments of different temperatures. 

 More complex hinge systems, which impact the ability to insulate the cabinet in the hinge 

region. 

EERE-2008-BT-STD-0012 COMMENT 22
2-7

DOE notes that establishment of separate product classes must be based on consumption 

of a different kind of energy, or a different capacity or other performance-related feature that 

other products within a product group do not share. The Secretary must consider such factors as 

the utility to the consumer of such a feature and other factors as the Secretary deems appropriate, 

and any rule prescribing a higher or lower level of energy use or efficiency shall include an 

explanation of the basis on which such higher or lower level was established. (42 U.S.C. 

6295(q)) 

Based on information received in discussions with manufacturers during the preliminary 

phase of the rulemaking, DOE is aware that achieving ENERGY STAR qualification for built-in 

products typically requires the use of more high-efficiency components. A conventional 

refrigerator-freezer, for example, typically requires use of a brushless DC condenser fan motor 

and a high-efficiency single-speed compressor to meet ENERGY STAR, whereas a built-in 

refrigerator-freezer generally requires use of brushless DC fan motors for both the condenser and 

evaporator, and a variable speed compressor. The cost of achieving ENERGY STAR based on 

these technical differences is estimated to be $43, as summarized in Table 2.2.1 below.a

 DOE 

understands that the differential for achieving ENERGY STAR could be more or less, depending 

on the design details of the built-in product. 

Table 2.2.1 Typical Cost Differential for Built-in Product ENERGY STAR Compliance as 

Compared with a Conventional Product 

Conventional Refrigerator-Freezer Built-In Refrigerator-Freezer 

Design Change Cost Impact Design Change Cost Impact 

Increase Compressor 

EER from 5.5 to 6.25 

$10.50 Replace Compressor 

with Variable-Speed 

Compressor 

$50

Add Brushless DC 

Condenser Fan Motor 

$3.75 Add Brushless DC 

Condenser and 

Evaporator Fan Motors 

$3.75 (condenser)

$3.50 (evaporator)

TOTAL $14.25 $57.25

Difference $43

Built-in products can be built into the kitchen cabinetry in a way that is not possible for 

conventional products. Some of the design details associated with this unique utility can impact 

energy use. These products do not consume a different type of energy from conventional 

products. While a difference in the ability to achieve higher efficiency levels is noted, DOE does 

not have sufficient information to conclude that built-in products cannot meet efficiency levels 

that might be considered for future standards. DOE acknowledges that the cost of achieving 

higher efficiency levels is greater for built-in products. DOE has not sufficiently completed an 

assessment of the cost differences associated with built-ins (as compared to conventional 

products of the high-volume product classes) and for this reason has not made a determination at 

 

a

 Cost assumptions for design changes are described in greater detail in Chapter 5 Engineering 

Analysis of the TSD. 

EERE-2008-BT-STD-0012 COMMENT 22
2-8

this preliminary stage regarding establishment of separate product classes for these products. 

DOE will work to complete this assessment as the rulemaking process progresses. 

2.2.2.2 Wine Storage Products 

 DOE received a number of comments on the subject of adding of wine storage products 

as a new product class covered under this rulemaking. Nearly all of these comments were in 

support of establishing a new product class for wine coolers. AHAM, ASAP, and PG&E all 

stated at the framework public meeting that DOE should include a separate product class for 

wine storage products. (AHAM, Public Meeting Transcript, No. 7 at pp. 58-59; ASAP, Public 

Meeting Transcript, No. 7 at p. 46-47; PG&E, Public Meeting Transcript, No. 7 at pp. 43-44) 

Specifically, these comments suggested that DOE create two separate product classes for wine 

storage products: those with manual defrost, and those with automatic defrost. EEI, Natural 

Resources Canada (NRCan), Whirlpool, Sub-Zero, and the Joint Comment expressed support for 

this position in their written comments as well. (EEI, No.13 at pp. 2-3; NRCan, No. 16 at pp. 2-

3; Whirlpool, No. 17 at pp. 4-5; Sub-Zero, No. 9 at p. 3; Joint Comment, No. 10 at p. 3) 

PG&E, however, modified its position in its written comment, stating that DOE should not 

establish new product classes for wine storage products at this time. The comment points out that 

the State of California already regulates these products, and that a Federal standard would 

supersede any State regulations. The comment further suggests that consideration is being given 

to strengthening the California energy standards for wine storage products and to expand the 

scope of product coverage, and that DOE introduction of a wine storage product class would 

limit California’s ability to take advantage of these energy savings opportunities. (PG&E, No. 14 

at pp. 1-2) 

DOE notes that the definitions of refrigerators and refrigerator-freezers in the Energy Policy and 

Conservation Act (EPCA) do not include specification of temperature levels. DOE defined 

refrigerators as “designed for storage of food at temperatures above 32°F and below 39°F” in 

order to assure that refrigerator temperature levels are suitable for storage of food. (66 FR 57845, 

November 19, 2001) Wine coolers, which control for higher temperature levels, are therefore 

excluded from the product category of refrigerators. Because wine coolers are not defined either 

in the statute or regulations as part of this product category, or as a separate and independent 

product category, they are not covered products. Hence, DOE is not considering wine coolers as 

part of this rulemaking. 

2.2.3 Technology Assessment 

 As part of the market and technology assessment, DOE developed a list of technologies 

to consider for improving product efficiency. Initially, these technologies encompass all those 

that DOE believes are technologically feasible. DOE then removed those technology options 

whose energy consumption could not be adequately measured by the existing DOE test 

procedure. Finally, DOE also removed technologies that do not change or affect the energy 

efficiency metrics of these products before moving on to the screening analysis. Chapter 3 of the 

preliminary TSD includes the detailed list of all technology options identified for each type of 

EERE-2008-BT-STD-0012 COMMENT 22
2-9

refrigerator, refrigerator-freezer, and freezer. Comments on the selection of technologies 

identified in the framework document are discussed in section 2.3. 

2.3 SCREENING ANALYSIS 

 After DOE identified the technologies in the technology assessment that could potentially 

improve the energy efficiency of residential refrigeration products, DOE conducted the screening 

analysis. The purpose of the screening analysis is to evaluate the technologies to determine 

which options to consider further and which options to screen out. DOE consults with industry, 

technical experts, and other interested parties in developing a list of technologies for 

consideration. DOE then applied the screening criteria to determine which technologies are 

unsuitable for further consideration in this preliminary rulemaking. Chapter 4 of the preliminary 

TSD, the screening analysis, contains details on the criteria that DOE used. 

 Using the screening analysis DOE, in consultation with interested parties, examined 

whether various technologies described in chapter 3 of the TSD: (1) are technologically feasible; 

(2) are practicable to manufacture, install, and service; (3) have an adverse impact on product 

utility or availability; and (4) have adverse impacts on health and safety. In the engineering 

analysis, DOE further considered the efficiency-enhancement options (i.e., technologies) that it 

did not screen out in the screening analysis. 

2.3.1 Screening Methodology 

 DOE received several comments regarding its methodology for screening technologies. 

The Joint Comment stated that DOE has been too quick to screen out technologies in previous 

rulemakings, that “manufacturers are much better at finding the lowest cost path to compliance 

than the Department”, and that DOE should review results of previous rulemakings to validate 

whether the methodology has been successful. (Joint Comment, No. 10 at p. 4) The comment did 

not indicate what would constitute success of the methodology, nor did it specifically address the 

criteria used to evaluate the technologies. Whirlpool commented that the screening analysis 

should also examine whether various technologies are proprietary. If they are, they should be 

excluded as technology options from the engineering analysis. (Whirlpool, No. 17 at p.5) On the 

other hand, AHAM stated in both the framework public meeting and in written comments that it 

believes the screening criteria are appropriate. (AHAM, No. 11 at p.5 and Public Meeting 

Transcript, No. 7 at p. 76) 

 DOE concurs with AHAM that the screening criteria are appropriate. The criteria are 

explicitly delineated in 10 CFR 430 subpart C appendix A section 4.(a)(4). DOE does not believe 

that a formal review of previous rulemakings to evaluate whether its screening methodology is 

“successful” is necessary. The time delay between the preliminary phase of the rulemaking and 

the effective date of the new standards is sufficiently long that some technologies appropriately 

screened out initially may be viable when the standards become effective. DOE is cognizant of 

the process used and the results achieved in previous rulemakings and has evaluated the 

EERE-2008-BT-STD-0012 COMMENT 22
2-10

technologies in this rulemaking by rigorously applying the criteria in section 2.3 based on 

currently available information. Also, DOE acknowledges the need to exclude proprietary 

technologies from the engineering analysis and has done so where appropriate in this 

rulemaking. 

2.3.2 Alternative Foam-Blowing Agents 

 AHAM and Whirlpool both recommended that DOE add alternative foam-blowing agents 

to the list of technologies under consideration for the screening analysis. (AHAM, No. 11 at p.5; 

Whirlpool, No. 17 at p. 5) DOE understands the intent of the comment to be that DOE should 

consider the impact of potential climate change legislation or direct EPA action limiting the use 

of greenhouse gases (GHGs) such as HFC-245fa. During investigation of technologies, DOE was 

not able to identify refrigerant blowing agent technology options that (1) have not been phased 

out in the past due to ozone depletion issues, and (2) provide better thermal performance than 

HFC-245fa, which is used extensively in the industry. Manufacturers confirmed during 

preliminary discussions that there are no available blowing agent options with better thermal 

performance. 

Manufacturers indicated during interviews that they have concerns about alternative 

foam-blowing agents which might have to be adopted as a result of potential climate change 

legislation regulating emissions of GHGs. HFC-245fa has a global warming potential (GWP) 

referenced to that of carbon dioxide (CO2) of about 1,000, but its conductivity is lower than all 

commonly known allowable alternative chemicals that are not GHGs. Hence, switching to a 

different foam-blowing agent will increase energy use of refrigeration products. Manufacturers 

expect that new legislation limiting the use of HFC blowing agents and refrigerants will be 

passed before the amended conservation standards for refrigerators goes into effect in 2014. For 

this reason, manufacturers have requested that DOE consider alternative foam-blowing agents in 

the analysis. 

 DOE points out that, because there are no alternative blowing agents that will 

improve efficiency, it is not appropriate to include this option in the list of technologies. An 

enforced transition to blowing agents with reduced global warming potential but higher thermal 

conductivity has the potential to make achieving high efficiency levels more difficult and more 

costly However, DOE cannot consider legislation that has not yet been enacted or rules that have 

not yet been established in determining its proposed standard levels before such legislation 

becomes law or before such rules have been established, regardless of the likelihood of these 

occurrences. Nevertheless, DOE acknowledges that climate change legislation could be enacted 

before the refrigeration products final rule is published. DOE also recognizes the additional 

challenge posed to the refrigeration products industry by potential limitations on HFC usage. For 

these reasons, the Department will consider conducting additional analyses addressing possible 

transition to alternative foam-blowing agents, to allow adjustment of the analysis results in a 

timely fashion in the case that such climate change legislation is enacted during the rulemaking 

process. Such analysis would consider the likely effect of increased energy consumption 

resulting from thermal conductivity increase of likely alternatives. This issue is discussed further 

EERE-2008-BT-STD-0012 COMMENT 22
2-11

in sections 2.10 and 2.10.4 of this chapter, as well as in the manufacturing impact analysis in 

chapter 12. 

2.3.3 Alternative Refrigerants 

A number of stakeholders commented about the inclusion of alternative refrigerants as a 

technology option in the screening process. Both AHAM and Whirlpool stated that DOE should 

exclude hydrocarbon refrigerants because they are regulated by safety organizations such as 

Underwriters Laboratories (UL) that restrict the usage of these substances to quantities under 50 

grams due to flammability. (AHAM, Public Meeting Transcript, No. 7 at p. 117; Whirlpool, 

Public Meeting Transcript, No. 7 at p. 72-73) Alternatively, GE stated that there are processes in 

place at the Environmental Protection Agency (EPA) to approve of hydrocarbon substances as 

safe for use as alternative refrigerants. (GE, Public Meeting Transcript, No. 7 at p. 73) 

The dominant refrigerant currently used in the U.S. is HFC-134a. A possible replacement 

refrigerant is R-600a, isobutane. R-600a is used extensively throughout the world in residential 

refrigerators and has a better thermodynamic efficiency than HFC-134a. However, R-600a is a 

hydrocarbon and is flammable. 

DOE excluded consideration of R-600a in the engineering analysis because concerns 

regarding its acceptance by UL and under the EPA's Significant New Alternatives Policy 

(SNAP) program have not been resolved. Current safety regulations limit the use of hydrocarbon 

refrigerants to quantities that are insufficient for most residential refrigeration applications. 

Underwriters Laboratories (UL) has established that no more than 50 g of isobutane can escape 

an appliance before requiring stringent safety testing, which essentially caps the allowable limit 

of R-600a at 50 g. This quantity is not enough for the typical residential refrigerator. Further, 

while thermodynamic efficiency of R-600a may be better than that of HFC-134a, it is not clear 

that the efficiency level of the alternative refrigerant is higher in practice. 

2.4 ENGINEERING ANALYSIS 

 The engineering analysis (chapter 5) establishes the relationship between the 

manufacturing production cost and the efficiency for each residential heating product. This 

relationship serves as the basis for cost/benefit calculations in terms of individual consumers, 

manufacturers, and the Nation. Chapter 5 discusses product classes DOE analyzed, the 

representative baseline units, the incremental efficiency levels, the methodology DOE used to 

develop the manufacturing production costs, the cost-efficiency curves, and the impact of 

efficiency improvements on the considered products. 

 In the engineering analysis, DOE evaluates a range of product efficiency levels and their 

associated manufacturing costs. The purpose of the analysis is to estimate the incremental 

manufacturer selling prices (MSPs) for a product that would result from increasing efficiency 

levels above the level of the baseline model in each product class. The engineering analysis 

EERE-2008-BT-STD-0012 COMMENT 22
2-12

considers technologies not eliminated in the screening analysis. The LCC analysis uses the costefficiency relationships developed in the engineering analysis. 

 DOE typically structures its engineering analysis around one of three methodologies: (1) 

the design-option approach, which calculates the incremental costs of adding specific design 

options to a baseline model; (2) the efficiency-level approach, which calculates the relative costs 

of achieving increases in energy efficiency levels without regard to the particular design options 

used to achieve such increases; and/or (3) the reverse-engineering or cost-assessment approach, 

which involves a “bottom-up” manufacturing cost assessment based on a detailed bill of 

materials derived from tear-downs of the product being analyzed. 

 For the preliminary analysis, DOE used a modified approach combining the designoption approach and the efficiency-level approach. DOE conducted energy modeling and 

manufacturing cost modeling to determine the cost impact of groups of design options which 

combined can achieve defined efficiency levels. Reverse engineering of existing products was 

used to provide calibration of the manufacturing cost models. DOE selected several baseline and 

high-efficiency products on which to conduct teardowns, which also provided an initial 

indication of cost-efficiency relationships for certain product classes. This step involved 

physically disassembling commercially available products, consulting with outside experts, 

reviewing publicly available cost and performance information, and modeling equipment cost. 

Product data and energy testing were used to calibrate the energy models. Data requested from 

the industry was used to compare with data from the DOE analyses. The efficiency levels that 

DOE considered in the engineering analysis are attainable using technologies currently available 

on the market and incorporating these technologies into residential refrigeration products. 

Chapter 5 of the preliminary TSD describes the methodology that DOE used to perform the 

engineering analysis and derive the cost-efficiency relationship. 

 In response to the approach outlined in the framework document, DOE received 

comments regarding the following issues: (1) efficiency levels; (2) compartment temperatures; 

(3) product classes; and (4) manufacturing cost analysis. Discussion of these issues is set forth 

below. 

2.4.1 Efficiency Levels 

 ACEEE and PG&E both stated that DOE should extend the cost-efficiency curves to 35 

percent lower energy than the federal standard. ACEEE mentioned that there are currently 

products on the market that exceed 30 percent below federal standards and that tax credits could 

increase the product volumes at these efficiency levels. (ACEEE, Public Meeting Transcript, No. 

7 at p. 105; PG&E, Public Meeting Transcript, No. 7 at p. 106) In response, Whirlpool stated that 

a 35 percent efficiency improvement is unrealistic and would be limited because of high costs. 

(Whirlpool, No. 17 at p. 8) Additionally, Whirlpool and AHAM both recommended that DOE 

conduct analysis for an efficiency level between baseline and 15 percent because 15 percent 

represents a very significant change in efficiency and because the change in the test procedure 

(lower compartment temperatures for refrigerator-freezers) may make achieving the 15% level 

even more difficult for some products. (Whirlpool, No. 17 at p. 8; AHAM, No. 11 at p. 7) 

EERE-2008-BT-STD-0012 COMMENT 22
2-13

The development of cost-efficiency curves to higher efficiency levels does not dictate the 

level at which new standards will be set and provides fuller insight regarding the cost levels 

required to achieve higher efficiencies. This is important, in particular, to provide an 

understanding of the cost impact of a potential new ENERGY STAR level associated with each 

new baseline efficiency level. Therefore, DOE has extended the analysis up to efficiency levels 

of 35 percent or more, as appropriate. In response to the comments of AHAM and Whirlpool, 

DOE has also included a 10 percent efficiency level in the analysis. 

DOE also received comments from AHAM and Whirlpool regarding the definition of 

efficiency levels under the new test procedure.b Specifically, AHAM and Whirlpool stated, 

“These percentages should not be applied directly to baseline values obtained using the new test 

procedure. These percentages, when applied to baselines using the current test procedure are 

realistic.” (Whirlpool, No. 17 at p. 7; AHAM, No. 11 at p. 7) DOE interprets these statements to 

mean that energy use for a percentage efficiency level would be defined to be equal to the newtest baseline energy use minus the percentage efficiency level multiplied by the current-test 

baseline energy use. This definition is illustrated below in Eq. 2.4.1. 

  EnergyNew Level  NTPBaseline   CTPA Baseline Eq. 2.4.1 

Where: 

New Energy Level = energy consumption associated with efficiency level A, 

NTPBaseline = baseline energy as calculated using the new test procedure, 

A = efficiency level, expressed as a percentage, and 

CTPBaseline = baseline energy as calculated using the current test procedure. 

For example, if the current baseline for a product is 500 kWh, and the new-test baseline 

energy use is 600 kWh, the 20 percent efficiency level would be 500 kWh, which is actually a 

16.7 percent reduction from 600 kWh. 

 DOE believes that this method is not appropriate as a definition for efficiency levels 

under the new test procedure because: (1) it is confusing given that the energy use reduction 

would generally be less than the percent efficiency level; and (2) it is expected that a product at a 

given percentage efficiency level using the current test would exhibit the same percentage 

efficiency level using the new test. Expressed in another way, an ENERGY STAR product 

should have similar sensitivity to the test procedure change as would a baseline energy product. 

DOE did not adopt the definitions suggested by AHAM and Whirlpool for these reasons. 

 

b

 As described in Section 3 Market and Technology Assessment, DOE is proposing adopting provisions of the 

updated AHAM Standard HRF-1-2008 test procedure, which specifies new compartment temperatures that will 

increase energy test energy consumption for many product classes. 

EERE-2008-BT-STD-0012 COMMENT 22
2-14

2.4.2 Compartment Temperatures 

AHAM, GE, Sub-Zero, and Whirlpool all submitted comments stating that DOE should 

use the temperatures and volumes from the new test procedure when performing its engineering 

analysis. (AHAM, Public Meeting Transcript, No. 7 at p. 86 and No. 11 at p. 6; GE, Public 

Meeting Transcript, No. 7 at p. 87; Sub-Zero, No. 9 at p. 4; and Whirlpool, No. 17 at p. 7) 

DOE agreed with the manufacturers’ suggestion and conducted its engineering analysis 

using the new temperatures and volumes. 

2.4.3 Product Classes 

DOE received a number of comments regarding product classes and the representative 

units that were selected for its teardown analysis. AHAM commented on DOE selection of an 18 

ft3 product class 5 product, indicating that 17 ft3 or 19 ft3 sizes would be more appropriate, based 

on shipment data showing limited shipment of 18 ft3

 products. AHAM also stated that the units 

selected for product classes 3, 7, 9, 10, 11, and 18 were representative of the typical volume for 

each class (AHAM, Public Meeting Transcript, No. & at p. 98-99, No. 11 at p. 5) Whirlpool 

commented that the volumes of the proposed teardown units for the product classes in which it 

participates (3, 4, 5, and 7) are representative of the industry-wide offerings. (Whirlpool, No. 17 

at p. 6) 

DOE points out that the total volume of the product class 5 listed as 18 ft3 actually has a 

rated volume of 18.5 ft3, which should have been rounded up to 19 ft3. Also, DOE believes that 

products of this size would exhibit energy-use characteristics that are sufficiently similar to those 

of slightly larger or smaller sized units within the same product class. Hence, DOE continued its 

analysis of the 18.5 ft3 product. 

DOE received additional comments from AHAM and Whirlpool suggesting that the 

representative units for product class 5 should be French door bottom-mount models because 

they have higher heat-leakage than traditional bottom-mount units. (AHAM, Public Meeting 

Transcript, No. 7 at p. 67 and No. 11 at p. 4; Whirlpool, No. 17 at p. 5) On the other hand, the 

Joint Comment suggested that DOE should not analyze product class 5 based solely on French 

Door models, stating that product types should not be chosen as the baseline simply because of 

higher inherent heat loss because this would lead to standards biased against efficiency and the 

grandfathering in of inefficient designs. (Joint Comment, No. 10 at p. 3) 

DOE requested information during manufacturer interviews regarding the prevalence of 

French Door products within product class 5. The information received suggests that more than 

half of product class 5 shipments are products with French Doors. Hence, DOE considers this 

design feature more representative of the product class than single-door designs, and DOE has 

carried out the analysis based on designs having French Doors. 

Additionally, W.C. Wood Corporation, Ltd. (WC Wood) commented on DOE’s selection 

only of WC Wood products to represent ENERGY STAR products for product classes 9 and 10. 

EERE-2008-BT-STD-0012 COMMENT 22
2-15

WC Wood suggested that DOE also examine products from another manufacturer. (WC Wood, 

No. 8 at p. 1) WC Wood states that doing so would provide DOE with a broader selection from 

which to understand the current level of freezer manufacturing technology. 

DOE acknowledges that analysis of product classes 9 and 10 could be limited if 

ENERGY STAR products from just one manufacturer were examined, so it procured and 

conducted reverse engineering analysis on similar-sized units made by another key manufacturer 

of these products. 

2.4.4 Manufacturing Cost Analysis 

DOE received several comments regarding the manufacturing cost analysis. The Joint 

Comment, NRDC, and PG&E all stated that DOE should review the accuracy of its costmodeling methods from previous rulemakings, in order to identify and address inaccurate cost 

assumptions so that such inaccuracies are not incorporated in the refrigerator cost models for this 

rulemaking. (Joint Comment, No. 10 at p. 4; NRDC, Public Meeting Transcript, No. 7 at pp. 93-

94; PG&E, Public Meeting Transcript, No. 7 at p. 94) Specifically, the Joint Comment states that 

DOE should account for the increased production levels and reduction of the learning curve 

associated with producing higher efficiency units. 

Thorough review of the accuracy of cost modeling of past rulemakings is beyond the 

scope of this rulemaking. DOE recognizes the need for accuracy in determination of the cost of 

achieving higher efficiency levels. To that end, DOE refrains from making or using cost 

projections that cannot be verified based on current information, as well as from making 

estimates that cannot be substantiated. DOE recognizes that this leads inevitably to cost estimates 

that may be high after a standard takes effect. However, the Energy Independence and Security 

Act of 2007 (EISA) modified EPCA to require that not later than 6 years after the issuance of 

any final rule establishing or amending a standard, DOE shall publish either a determination that 

standards for the product do not need to be amended or a notice of proposed rulemaking 

including new proposed standards. (42 U.S.C. 6295, section 325 (m)) Hence, if the costeffectiveness of higher efficiency standards improves significantly, the energy conservation 

standards can be adjusted in a subsequent rulemaking. 

2.5 MARKUPS TO DETERMINE PRODUCT PRICE 

 DOE used markups to convert the manufacturer selling prices estimated in the 

engineering analysis to customer prices, which then were used in the life-cycle cost (LCC) and 

payback period (PBP) and manufacturer impact analyses. DOE calculates markups for baseline 

products (baseline markups) and for more efficient products (incremental markups). The 

incremental markup relates the change in the manufacturer sales price of higher-efficiency 

models (the incremental cost increase) to the change in the retailer or distributor sales price. 

EERE-2008-BT-STD-0012 COMMENT 22
2-16

 To develop markups, DOE identifies how the products are distributed from the 

manufacturer to the customer. After establishing appropriate distribution channels, DOE relied 

on economic data from the U.S. Census Bureau and other sources to define how prices are 

marked up as the products pass from the manufacturer to the customer. See Chapter 6 for details 

on the development of markups. 

2.6 ENERGY USE CHARACTERIZATION 

 The energy use characterization, which assesses the energy savings potential from higher 

efficiency levels, provides the basis for the energy savings values used in the LCC and 

subsequent analyses. Studies show that measurements of field energy use often vary 

considerably from the rated usage as determined by the DOE test procedure. To determine the 

field energy use by products that would meet possible energy efficiency standards, DOE used 

data from the Energy Information Administration (EIA)’s 2005 Residential Energy Consumption 

Survey (RECS).1,c RECS is a national sample survey of housing units that collects statistical 

information on the consumption of and expenditures for energy in housing units along with data 

on energy-related characteristics of the housing units and occupants. DOE used RECS to 

estimate the field energy usage of standard-sized refrigerator-freezers and freezers on a 

representative sample of housing units using these products. But DOE did not use RECS for 

compact refrigerators and freezers because a large fraction of these products are used outside the 

residential sector. 

AHAM and Whirlpool expressed opposition to using RECS data for the energy use 

characterization. (AHAM, No. 11 at p. 8; Whirlpool, No. 17 at p. 9) They stated that the RECS 

data were collected in 2005 and may not be representative of the quickly changing refrigeration 

market. DOE uses the RECS to characterize energy use of refrigeration products because this 

survey is the only source that provides a nationally-representative household sample that 

includes estimates of energy use by refrigeration products. RECS also provides enough 

information to establish the type (i.e., product class) of refrigeration product used in each 

household. Changes in the refrigeration market are not an important factor because DOE’s 

approach provides a basis for estimating what the energy consumption would be if a household 

purchased a new and different product from the one they owned in 2005. As noted previously, 

DOE did not use RECS for compact refrigerators and freezers because a large fraction of these 

products are used outside the residential sector. 

EEI stated that units in unconditioned areas are more likely to have low energy usage 

during the winter season and higher energy usage during the summer season. (EEI, No. 13 at p. 

4) Although RECS does not report the precise location of the refrigerator, it does identify 

whether a household has a second refrigerator. For those households with two refrigerators, DOE 

estimated that the second unit is located in either the garage or the basement. DOE accounted for 

 

c

 This is the most recent RECS. 

EERE-2008-BT-STD-0012 COMMENT 22
2-17

the operating conditions of units located in such unconditioned areas in its calculation of the 

energy use of second refrigerators. 

EEI stated that DOE should be careful when estimating the energy usage of compact 

equipment, especially since these units are more likely to be shut off most of the time (used only 

on social occasions) or used on a seasonal basis (e.g., college dormitories) compared to full-size 

units. (EEI, No. 13 at p. 4) Because DOE was not able to find suitable data on the field use of 

compact refrigerators and freezers, it used the DOE test procedure to calculate the annual energy 

use of products of different volume, and estimated the distribution of volumes in the field using 

model data from the California Energy Commission appliance database.2

 

In calculating energy consumption of refrigeration products, DOE considered whether it 

would be appropriate to include a rebound effect (also called a take-back effect), which refers to 

the increased energy consumption resulting from actions that increase energy efficiency and 

reduce consumer costs. The rebound effect assumes that consumers give up some of the potential 

energy savings to receive more service. AHAM stated that the rebound effect does not impact the 

refrigeration market because most consumers have fixed kitchen space for a refrigeration unit, so 

purchasing a larger unit is not possible, and refrigerator size is a function of life stage, rather than 

operating cost. (AHAM, No. 11 at p. 8) Whirlpool and EEI agreed with AHAM’s perspective. 

(Whirlpool, No. 17 at p. 9; EEI, No. 13 at p. 4) DOE agrees that there is no evidence of a direct 

rebound effect for refrigeration products and it does not plan to include a rebound effect in its 

analysis. 

Chapter 7 of the preliminary TSD provides more detail about DOE’s approach for 

characterizing energy use of refrigeration products. 

2.7 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES 

 New energy conservation standards affect products’ operating expenses—usually 

decreasing them—and consumer prices for the products—usually increasing them. DOE 

analyzed the net effect of amended standards on consumers by evaluating the net LCC. To 

evaluate the net LCC, DOE used the cost-efficiency relationship derived in the engineering 

analysis, along with the energy costs derived from the energy use characterization. Inputs to the 

LCC calculation include the installed cost of a product to the consumer (consumer purchase price 

plus installation cost), operating expenses (energy expenses and maintenance costs), the lifetime 

of the unit, and a discount rate. 

 Because the installed cost of a product typically increases while operating cost typically 

decreases in response to new standards, there is a time in the life of products having higher-thanbaseline efficiency when the net operating-cost benefit (in dollars) since the time of purchase is 

equal to the incremental first cost of purchasing the higher-efficiency product. The length of time 

required for products to reach this cost-equivalence point is known as the payback period (PBP). 

EERE-2008-BT-STD-0012 COMMENT 22
2-18

Recognizing that several inputs to the determination of consumer LCC and PBP are 

either variable or uncertain, DOE conducted the LCC and PBP analysis by modeling both the 

uncertainty and variability in the inputs using Monte Carlo simulation and probability 

distributions. DOE developed LCC and PBP spreadsheet models incorporating both Monte Carlo 

simulation and probability distributions by using Microsoft Excel spreadsheets combined with 

Crystal Ball (a commercially available add-in program). 

 As described above in section 2.6, DOE developed samples of individual households that 

use standard-size refrigeration products. By developing household samples, DOE was able to 

perform the LCC and PBP calculations for each household to account for the variability in 

energy consumption and electricity price associated with each household. As noted above, DOE 

did not develop a household sample for compact refrigerators and freezers since a large number 

of such products are used in lodging, dormitories and other commercial establishments. DOE 

identified several other input values for estimating the LCC, including: retail prices; discount 

rates; and product lifetimes. DOE characterized these values with probability distributions. 

 

 DOE developed discount rates separately for residential consumers and commercial 

consumers. Because some compact refrigerators and freezers are used in commercial 

applications, DOE developed commercial discount rates and for those commercial consumers 

that purchase compact refrigerators and freezers. DOE developed discount rates from estimates 

of the interest rate, or finance cost, applied to purchases of residential and commercial products. 

Following accepted principles of financial theory, the finance cost of raising funds to purchase 

such products can be interpreted as: (1) the financial cost of any debt incurred to purchase 

products, principally interest charges on debt; or (2) the opportunity cost of any equity used to 

purchase products, principally interest earnings on household equity. 

2.7.1 Retail Prices 

As described in section 2.5, DOE used markups to convert the manufacturer selling 

prices estimated in the engineering analysis to customer retail prices for the LCC and PBP 

analysis. The Joint Comment stated that analysis of past refrigerator standards has demonstrated 

that DOE has overestimated the increase in prices resulting from energy efficiency standards, 

and that DOE should revise its methodology or develop a correction factor for this rulemaking. 

(Joint Comment, No. 10 at p. 5) DOE recognizes that every change in minimum energy 

conservation standards is an opportunity for manufacturers to make investments beyond what 

would be required to meet the new standards in order to minimize the costs or to respond to other 

factors. DOE’s manufacturing cost estimates, MIA interviews, and the GRIM analysis (which is 

conducted for DOE’s NOPR) seek to gauge the most likely industry response to proposed energy 

conservation standards. DOE’s analysis of responses must be based on currently available 

technology that will be non-proprietary when a rulemaking becomes effective, and thus cannot 

speculate on future product and market innovation. 

EERE-2008-BT-STD-0012 COMMENT 22
2-19

2.7.2 Energy Prices 

DOE used EIA’s energy price data to determine residential and commercial prices of 

electricity in 2007 in 13 geographic areas. DOE used projections of those energy prices from 

EIA’s Annual Energy Outlook 2009 (AEO 2009) to estimate future energy prices.3 The Joint 

Comment recommended that DOE conduct a sensitivity analysis using a basket of other forecasts 

besides the AEO, as the AEO has estimated lower electricity prices than most other forecasts. 

(Joint Comment, No. 10 at p. 6) DOE conducts sensitivity analysis using alternative AEO 

forecasts in addition to the AEO reference forecast. These alternative forecasts reflect different 

assumptions with respect to economic growth and other factors. In general, the range of AEO 

forecasts brackets long-run energy price forecasts made by other organizations. 

 The Joint Comment stated that DOE should consider consumers’ actual benefit of saving 

electricity at the margin rather than use the annual average cost of electricity. They noted that 

due to block rate structures used in some states, the last kWh of variable charges may be 

significantly higher than the annual average residential rate per kWh. (Joint Comment, No. 10 at 

p. 6 ) DOE did not use marginal energy prices in the current analysis because for a base load 

appliance such as residential refrigeration there is little difference between marginal and average 

prices. While it is true that many utilities use ascending block rate tariffs, the effect this has on 

the difference between marginal and average prices is offset by two other features of rate 

structures: first, residential consumers tend to pay relatively high fixed charges, which raises the 

average price relative to the marginal energy price; second, seasonal rates are also very common, 

with summer rates typically higher, and winter rates lower, than the average (this may be 

reversed in winter-peaking regions). As refrigerator energy use is not seasonal, over the year the 

rate differences average out. These arguments help explain why there is not a large difference 

between marginal and average prices. However, DOE bases its decision for which price to use on 

a review of the available data. In particular, analysis of the Edison Electric Institute Typical Bills 

and Average Rates Reports for summer and winter 2008 confirms that, averaged over the year 

and over a wide customer base as is appropriate for refrigerators; marginal and average rates are 

approximately equal.4,5

2.7.3 Maintenance and Repair Costs 

 DOE considered expected changes to maintenance, repair, and installation costs for the 

products covered in this rulemaking. Typically, small incremental changes in product efficiency 

produce no, or only minor, changes in repair and maintenance costs over baseline efficiency 

products. Products having efficiencies that are significantly greater than baseline efficiencies can 

incur increased repair and maintenance costs since they are more likely to incorporate 

technologies that are new to the industry. 

 Whirlpool stated that maintenance, repair and installation (MRI) costs are, in part, a 

function of the complexity of the technology employed in the product and the experience level of 

the technicians repairing the product. Thus, if efficiency is improved through greater leverage of 

known technology, the assumption of little change in MRI costs is correct. However, if exotic 

new technologies are required to meet new efficiency levels, MRI costs could easily be double 

EERE-2008-BT-STD-0012 COMMENT 22
2-20

current levels. (Whirlpool, No. 17 at p. 10) DOE did not find data indicating increases in MRI 

costs associated with the efficiency levels considered in its analysis. 

2.7.4 Product Lifetime 

In DOE’s October 2005 draft technical report analyzing potential new amended energy 

conservation standards for residential refrigerator-freezers,6 an average product lifetime of 19 

years was estimated based on information in DOE’s 1995 TSD.7 Whirlpool commented that the 

September 2007 issue of Appliance magazine shows an average life for refrigerators of 14 years, 

a low of 10 years and a high of 18 years, and that this is consistent with Whirlpool's experience. 

(Whirlpool, No. 17 at p. 10) The Joint Comment stated that 19 years is an accurate representation 

of the actual use of residential refrigerators; that many users continue to utilize their old 

refrigerators even after purchasing a new unit, while still others purchase used refrigerators to 

save up front costs; and that these factors work to increase the real product life such that DOE’s 

assumption is reasonable. (Joint Comment, No. 10 at p. 6) 

DOE found that the basis for the lifetime estimates in the literature for refrigerators and 

freezers is uncertain. Therefore, for standard-sized refrigerator-freezers and freezers, DOE 

conducted an analysis of actual lifetime in the field using a combination of shipments data and 

responses in RECS on the age of the refrigeration products in the homes. As described in 

Chapter 8, this analysis yielded an estimate of mean age for standard-sized refrigerator-freezers 

of approximately 17 years and for standard-sized freezers of approximately 22 years. It also 

yielded a survival function that DOE incorporated as a probability distribution in its LCC 

analysis. For compact refrigerators and freezers, DOE based the product lifetime on a 

combination of historical shipments, historical saturations in the housing stock, and historical 

saturations in the commercial building stock. As described in Chapter 8, this analysis yielded an 

estimate of mean age for compact refrigerators of 5 years and compact freezers of 7 years. 

2.7.5 Product Energy Efficiency Distribution in the Base Case 

To accurately estimate the share of consumers that would be affected by a standard at a 

particular efficiency level, DOE’s LCC and PBP analysis considered the projected distribution of 

product efficiencies that consumers purchase under the base case (i.e., the case without new 

energy efficiency standards). DOE relied on data submitted by AHAM to estimate the base case 

efficiency distributions for each of the product classes that were analyzed in the LCC and PBP 

analysis. With respect to the distribution of future product energy efficiency in the absence of 

new standards, Whirlpool and EEI stated that the ENERGY STAR and the Consortium for 

Energy Efficiency (CEE) programs are well known and widely utilized by retailers, utilities and 

some state governments as voluntary market transformation programs, and that DOE should 

consider the future impacts of these programs in its base case projection. (Whirlpool, No. 17 at p. 

11; EEI, No. 13 at p. 4) DOE agrees that the above programs are likely to affect the market and it 

projected an increase in the market share of ENERGY STAR appliances in the coming years for 

its base case forecast. Chapter 8 of the preliminary TSD provides more detail about DOE’s 

approach for base case efficiency distributions. 

EERE-2008-BT-STD-0012 COMMENT 22
2-21

2.8 NATIONAL IMPACT ANALYSIS 

 The national impact analysis assesses the net present value (NPV) of total consumer lifecycle cost (LCC) and net energy savings (NES) to the Nation. DOE determined both the NPV 

and NES for the performance levels considered for the product classes analyzed. To make the 

analysis more accessible and transparent to all interested parties, DOE prepared a Microsoft 

Excel spreadsheet model to forecast NES and the national consumer economic costs and savings 

resulting from new standards. The spreadsheet model uses as inputs typical values (as opposed to 

probability distributions). To assess the effect of input uncertainty on NES and NPV results, 

DOE may conduct sensitivity analyses by running scenarios on specific input variables. 

2.8.1 Shipments Analysis 

 Forecasts of product shipments are needed to calculate the national impacts of standards 

on energy use, NPV, and future manufacturer cash flows. DOE developed shipment forecasts 

based on an analysis of key market drivers for each considered product. In DOE’s shipments 

model, shipments of products are driven by new construction as well as stock replacements. 

The shipments models take an accounting approach, tracking market shares of each 

product class and the vintage of units in the existing stock. Stock accounting uses product 

shipments as inputs to estimate the age distribution of in-service product stocks for all years. The 

age distribution of in-service product stocks is a key input to calculations of both the NES and 

NPV, because operating costs for any year depend on the age distribution of the stock. 

 Chapter 9 of the preliminary TSD provides additional details on the shipments analysis. 

Framework phase comments regarding the shipments analysis were limited to agreement 

by AHAM and manufacturers to support the data collection effort (e.g. AHAM, No. 11 at p. 9), 

and statements highlighting the success of voluntary programs such as ENERGY STAR and 

CEE (e.g. Whirlpool, No. 17 at p.11). 

2.8.2 Efficiency Scenarios and Trends 

 Several of the inputs for determining NES and NPV depend on the product efficiency. 

DOE developed efficiency trends for the base case and standards cases. These trends specify the 

average annual historical and forecasted shipments-weighted product efficiencies. 

 In the framework document, DOE proposed to use a roll-up efficiency scenario in 

developing its forecasts of efficiency trends after standards take effect. Under a roll-up scenario, 

all products that perform at levels below a prospective standard are moved, or rolled-up, to the 

minimum performance level allowed under the standard. The distribution of products that meet 

the higher efficiency standard levels is unaffected. 

The Joint Comment stated that historical data are likely to demonstrate that the roll-up 

scenario bears no resemblance to the historical record and should be dropped from the analysis. 

EERE-2008-BT-STD-0012 COMMENT 22
2-22

It added that markets may respond with a very temporary situation where nearly all products just 

meet a new standards, but that it does not take long for a new distribution of efficiency 

performance above a new standard to emerge. The Joint Comment stated that over the analysis 

timeframe, a “shift” scenario is the dominant effect, and DOE should model a shift scenario that 

accounts for some time lag for the full shift effect to occur. (Joint Comment, No. 10 at p. 7) DOE 

agrees that the historical record suggests that the likely market response to new standards is that 

baseline models will roll-up to the standard efficiency level but some fraction of shipments will 

be above the minimum. In developing the energy efficiencies forecasted over time for each of the 

standards cases, DOE used a “roll-up + ENERGY STAR” scenario to establish the distribution 

of efficiencies for the year that revised standards are assumed to become effective (i.e., 2014) 

and subsequent years. In this scenario, product efficiencies in the base case that did not meet the 

standard level under consideration would roll-up to meet the new standard level in 2014. DOE 

assumed that new criteria would be established for ENERGY STAR refrigeration products, and 

that such products would gradually gain a larger market share. The details of the approach are 

described in Chapter 10. 

2.8.3 National Energy Savings Analysis 

 The inputs for determining the national energy savings (NES) for each product analyzed 

are: (1) annual energy consumption per unit; (2) shipments; (3) product stock; (4) national 

energy consumption; and (5) site-to-source conversion factors. DOE calculated the national 

energy consumption by multiplying the number of units, or stock, of each product (by vintage, or 

age) by the unit energy consumption (also by vintage). DOE calculated annual NES based on the 

difference in national energy consumption for the base case (without new efficiency standards) 

and for each higher efficiency standard. DOE estimated energy consumption and savings based 

on site energy, and converted the electricity consumption and savings to source energy. 

Cumulative energy savings are the sum of the NES for each year. 

 The stock of a product is dependent on annual shipments and the lifetime of the product. 

DOE projected shipments under the base efficiency case and higher efficiency cases. 

2.8.4 Net Present Value Analysis 

 The inputs for determining net present value (NPV) are: (1) total annual installed cost; (2) 

total annual savings in operating costs; (3) a discount factor; (4) present value of costs; and (5) 

present value of savings. DOE calculated net savings each year as the difference between the 

base case and each standards case in total savings in operating costs and total increases in 

installed costs. DOE calculated savings over the life of each product, accounting for differences 

in yearly energy rates. DOE calculated NPV as the difference between the present value of 

operating cost savings and the present value of total installed costs. DOE used a discount factor 

based on real discount rates of 3% and 7% to discount future costs and savings to present values. 

The Joint Comment urged DOE to give primary weight to calculations based on the lower 

discount rate. The comment asserted that societal discount rates are the subject of extensive 

academic research, the weight of academic opinion is that the appropriate societal discount rate 

EERE-2008-BT-STD-0012 COMMENT 22
2-23

is 3% or less, and NRDC and others have presented evidence to support the adoption of a 

societal discount rate in the range of 2 to 3% real. (Joint Comment, No. 10 at p. 7) 

DOE notes that OMB Circular A-4 references an earlier Circular A-94, which states that 

a real discount rate of 7 percent should be used as a base case for regulatory analysis. The 7-

percent rate is an estimate of the average before-tax rate of return to private capital in the U.S. 

economy. It approximates the opportunity cost of capital and, according to Circular A-94, is the 

appropriate discount rate whenever the main effect of a regulation is to displace or alter the use 

of capital in the private sector. OMB revised Circular A-94 in 1992 after extensive internal 

review and public comment. OMB found that the average rate of return to capital remains near 

the 7-percent rate estimated in 1992. Circular A-4 also states that when regulation primarily and 

directly affects private consumption, a lower discount rate is appropriate. “The alternative most 

often used is sometimes called the social rate of time preference...the rate at which ‘society’ 

discounts future consumption flows to their present value.”8

 It suggests that the real rate of return 

on long-term government debt may provide a fair approximation of the social rate of time 

preference, and states that over the last 30 years, this rate has averaged around 3 percent in real 

terms on a pre-tax basis. It concludes that “for regulatory analysis, [agencies] should provide 

estimates of net benefits using both 3 percent and 7 percent.”9

 Consistent with OMB guidance 

DOE did not give primary weight to results derived using a 3-percent discount rate. 

 DOE calculated increases in total installed costs as the difference in total installed cost 

between the base case and standards case (i.e., once the standards take effect). Because the more 

efficient products bought in the standards case usually cost more than products bought in the 

base case, cost increases appear as negative values in the NPV. 

 DOE expressed savings in operating costs as decreases associated with the lower energy 

consumption of products bought in the standards case compared to the base efficiency case. 

Total savings in operating costs are the product of savings per unit and the number of units of 

each vintage that survive in a given year. 

 The national impacts analysis examines the potential economic impacts of alternative 

standard levels on consumers who purchase the products that meet each standard level. The Joint 

Comment stated that the electricity price mitigation effects of new standards on refrigeration 

products should be documented and the value of reduced electricity bills to all consumers 

quantified as a benefit. (Joint Comment, No. 10 at p. 6) DOE investigated the possibility of 

estimating the impact of specific standard levels on electricity prices in its rulemaking for 

general service fluorescent lamps and incadescent reflector lamps.10 Whereas natural gas markets 

exhibit a fairly simple chain of agents from producers to consumers, the power industry is a 

complex mix of fuel suppliers, producers and distributors. While the distribution of electricity is 

regulated everywhere, its institutional structure varies, and upstream components are more 

complicated, with generation being priced using different methods across the country. For these 

and other reasons, accurate modeling of the response of electricity prices to a decrease in 

residential-sector demand due to standards is problematic. Thus, DOE does not plan to estimate 

the value of potentially reduced electricity costs for all consumers associated with revised 

standards. 

EERE-2008-BT-STD-0012 COMMENT 22
2-24

 Chapter 10 of the preliminary TSD provides additional details regarding the national 

impacts analysis. 

2.9 LIFE-CYCLE COST SUBGROUP ANALYSIS 

 The LCC subgroup analysis evaluates economic impacts on selected groups of consumers 

who might be adversely affected by a change in the national energy conservation standards for 

the considered products. DOE evaluates impacts on particular subgroups of consumers primarily 

by analyzing the LCC impacts and PBP for those particular consumers. 

 AHAM stated that DOE should consider low-income households as a consumer 

subgroup, since refrigerators are not optional for consumers, and thus the impact of price 

increase on low-income and fixed-income consumers may be more pronounced than for products 

that are more discretionary. (AHAM, No. 11 at p. 9) DOE intends to evaluate impacts of 

standards on low-income and fixed-income (i.e., senior) consumers. 

 DOE will use the LCC spreadsheet model to evaluate impacts on consumer subgroups. 

DOE can analyze the LCC for any subgroup by applying the LCC spreadsheet model to only that 

subgroup. DOE is particularly sensitive to increases in the consumer price of the considered 

products, and seeks to avoid a negative economic impact on any identified consumer subgroup. 

 The Joint Comment stated that if the Department insists on analyzing sub-groups in the 

LCC analysis, it should not only quantify the effects on those that are more negatively affected, 

but also consider those sub-groups that are more positively affected, such as those that rent 

housing and have no choice in refrigerator efficiency, yet are forced to pay the energy bills. 

(Joint Comment, No. 10 at p. 7) It is unclear whether renters would be positively affected by 

revised standards, as the extent to which property owners (the purchasers of refrigerators in most 

cases) would pass on the higher cost of more-efficient products to tenants in the rent is uncertain. 

Therefore, DOE does not plan to analyze renters as a sub-group. 

2.10 PRELIMINARY MANUFACTURER IMPACT ANALYSIS 

 DOE performed a preliminary manufacturer impact analysis (MIA) to start to estimate 

the financial impact of higher energy conservation standards on manufacturers of residential 

refrigeration products, and calculate the impact of such standards on employment and 

manufacturing capacity. The MIA has both quantitative and qualitative aspects. The quantitative 

part of the MIA relies on the government regulatory impact model (GRIM), an industry-cashflow model customized for this industry. The GRIM inputs are information regarding the 

industry cost structure, shipments, and revenues. This includes information from many of the 

analyses described above, such as manufacturing costs and prices from the engineering analysis 

and shipments forecasts. The key GRIM output is the industry net present value (NPV). Different 

EERE-2008-BT-STD-0012 COMMENT 22
2-25

sets of assumptions (scenarios) will produce different results. The qualitative part of the MIA 

addresses factors such as equipment characteristics, characteristics of particular firms, and 

market and equipment trends, and includes assessment of the impacts of standards on subgroups 

of manufacturers. The complete preliminary MIA is described in chapter 12 of the preliminary 

TSD. 

 DOE will conduct the MIA in this rulemaking in three phases, and will further tailor the 

analytical framework for the MIA based on comments from interested parties. In Phase I, DOE 

creates an industry profile to characterize the industry and identify important issues that require 

consideration. In Phase II, DOE prepares an industry cash-flow model and an interview 

questionnaire to guide subsequent discussions. In Phase III, DOE interviews manufacturers, and 

assesses the impacts of standards both quantitatively and qualitatively. DOE assesses industry 

and subgroup cash flow and NPV using the GRIM. DOE then assesses impacts on competition, 

manufacturing capacity, employment, and regulatory burden based on manufacturer interview 

feedback and discussions. 

 Until recently, DOE reported MIA results in its standards rulemakings only during the 

NOPR phase of the rulemaking. However, DOE is now evaluating and reporting preliminary 

MIA information in this preliminary analysis. DOE gathered this information during the 

preliminary manufacturer interviews conducted for the engineering analysis. 

 In response to the process outlined in the framework document for conducting the MIA, 

DOE received comments on the cumulative regulatory burden faced by the industry as a whole 

and by small, niche manufacturers in particular. Specifically, manufacturers and trade 

associations expressed concern over potential climate change legislation that would regulate or 

eliminate the use of HFCs, the regulation of refrigerants through the Environmental Protection 

Agency (EPA), and the regulation of potential alternative refrigerants through safety standards 

from organizations such as UL. 

 AHAM, GE, and Whirlpool all stated that DOE should consider the effects of potential 

climate change legislation within its analyses. All three organizations also believe that 

regulations restricting use of refrigerants and foam-blowing agents could be enacted by EPA in 

the absence of climate change legislation. This could present a major problem to manufacturers 

because the use of the most likely alternative refrigerant, R-600a, is currently restricted, due to 

safety concerns, by UL. (AHAM, No. 11 at p. 9, Public Meeting Transcript, No. 7 at pp. 116-117 

and at pp. 182-183; GE, No. 15 at pp. 1-2; and Whirlpool, No. 17 at pp. 11-12) 

DOE agrees that potential climate change legislation and potential regulations and 

restrictions by EPA would present significant challenges to refrigeration products manufacturers. 

If these kinds of regulations were passed before the final rule for refrigeration products, DOE 

would consider them in its analysis of cumulative regulatory burden during this rulemaking. 

However, DOE cannot, either when determining new energy conservation standards or when 

considering the cumulative regulatory impact of such standards, factor unenacted legislation or 

rules that have not yet been finalized into its analysis. DOE recognizes the substantial impact that 

climate change and other regulations would pose for the refrigeration products industry. DOE 

EERE-2008-BT-STD-0012 COMMENT 22
2-26

will consider conducting analyses addressing the impacts of the use of alternative refrigerants 

and foam-blowing agents possibly required by such legislation or regulations, in order to be 

prepared to adjust analysis results appropriately should such climate change legislation be 

enacted or rules be finalized during the rulemaking process. This issue is discussed also in 

section 2.3.2 and in chapter 12. 

As part of the preliminary MIA, DOE asked manufacturers about the potential impacts of 

amended energy conservation standards on their business, employment levels, market share, and 

competitive positions within the marketplace. Manufacturers stated that conversion costs are a 

concern and they anticipate that significant product modifications resulting in the need for new 

production facilities will drive production outside of the U.S. and substantially lower domestic 

employment levels. Additionally, manufacturers expressed some concern about competitive 

position and potential industry consolidation as a result of amended energy conservation 

standards. As part of the NOPR phase of the rulemaking, DOE will further analyze these 

concerns and seek further comments from manufacturers about conversion costs and 

profitability. DOE will then estimate both the qualitative and quantitative impacts on the 

refrigeration products industry. 

 The following is an overview of the information DOE will collect and the analysis that 

will be conducted during the MIA. For more detail, see chapter 12 of the preliminary TSD. 

2.10.1 Industry Cash-Flow Analysis 

 The industry cash-flow analysis relies primarily on the GRIM. DOE uses the GRIM to 

analyze the financial impacts of more stringent energy conservation standards on the industry 

that produces the products covered by the standard. The GRIM analysis uses many factors to 

determine annual cash flows from a new standard: annual expected revenues; manufacturer 

costs, including cost of goods sold, depreciation, research and development, selling, general, and 

administrative expenses; taxes; and conversion capital expenditures. DOE compares the results 

against base-case projections that involve no new standards. The financial impact of new 

standards is then the difference between the two sets of discounted annual cash flows. Other 

performance metrics, such as return on invested capital, are also available from the GRIM. For 

more information on the industry cash-flow analysis, refer to chapter 12 of the preliminary TSD. 

2.10.2 Manufacturer Subgroup Analysis 

 Industry cost estimates are not adequate to assess differential impacts among subgroups 

of manufacturers. For example, small and niche manufacturers, or manufacturers whose cost 

structure differs significantly from the industry average, could experience a more negative 

impact from the imposition of standards. Ideally, DOE would consider the impact on every firm 

individually; however, since this usually is not possible, DOE typically uses the results of the 

industry characterization to group manufacturers exhibiting similar characteristics. 

 DOE outlined the process it uses to establish manufacturer subgroups in the framework 

document and sought comment from interested parties on any potential subgroups within the 

EERE-2008-BT-STD-0012 COMMENT 22
2-27

refrigeration products industries. AHAM and Whirlpool both commented that small, niche 

manufacturers should be considered because they have less access to the resources needed to 

develop, implement, and market newer technologies, such as alternative refrigerants. (AHAM, 

No. 11 at p. 9; Whirlpool, No. 17 at p. 11) 

 Currently, DOE is characterizing the impacts on residential refrigeration products on the 

residential refrigeration industry. DOE did not identify any manufacturer subgroups within the 

industry other than small manufacturers. DOE will consider the possibility of small businesses 

being affected by the promulgation of amended energy conservation standards for residential 

refrigeration products. DOE identified a handful of small businesses within the industry in 

chapter 3 of the preliminary TSD. During the manufacturer interview process conducted as part 

of the NOPR, DOE will discuss the potential subgroups and subgroup members it has identified 

for the analysis. DOE will encourage the manufacturers to recommend subgroups or 

characteristics that are appropriate for the subgroup analysis. For more detail on the 

manufacturer subgroup analysis, see chapter 12 of the preliminary TSD. 

2.10.3 Competitive Impacts Assessment 

 DOE must also consider whether a new standard is likely to reduce industry competition, 

and the Attorney General must determine the impacts, if any, of any reduced competition. DOE 

will make a determined effort to gather and report firm-specific financial information and 

impacts. The competitive impacts assessment will focus on assessing the impacts on smaller 

manufacturers. DOE will base this assessment on manufacturing cost data and information 

collected from interviews with manufacturers. The manufacturer interviews will focus on 

gathering information to help assess asymmetrical cost increases to some manufacturers, 

increased proportion of fixed costs potentially increasing business risks, and potential barriers to 

market entry (e.g., proprietary technologies). The NOPR will be submitted to the Attorney 

General for a review of the impacts of standards on competition. The Attorney General’s 

comments on the proposed rule will be considered in preparing the final rule. 

2.10.4 Cumulative Regulatory Burden 

 DOE recognizes and seeks to mitigate the overlapping effects on manufacturers of new or 

revised DOE standards and other regulatory actions affecting the same equipment. DOE will 

analyze and consider the impact on manufacturers of multiple, product-specific regulatory 

actions. Based on its own research and discussions with manufacturers, DOE identified several 

regulations relevant to residential refrigeration products, including potential climate change and 

greenhouse gas legislation. 

 DOE outlined the cumulative regulatory burden process in the framework document and 

sought comment from interested parties on any additional regulations facing the residential 

refrigeration products industry. In response to the cumulative regulatory burden discussion in the 

framework document, AHAM, Whirlpool, and GE all commented that DOE should consider the 

effect of potential climate change regulation. (AHAM, Public Meeting Transcript, No. 7 at pp. 

116-117 and pp. 182-183, No. 11 at p. 9; Whirlpool, No. 17 at pp. 11-12; GE, No. 15 at pp. 1-2) 

EERE-2008-BT-STD-0012 COMMENT 22
2-28

As stated in section 2.3.2, DOE cannot consider in its cumulative regulatory burden 

analysis any legislation that has not yet been enacted or any new rules that have not been 

finalized. However, DOE recognizes the impact that such legislation or rules could have to 

DOE’s rulemaking schedule and the challenge it presents to manufacturers. For these reasons, 

DOE will consider conducting additional analyses, addressing use of alternative foam-blowing 

agents, to allow adjustment of the analysis results in the case that such climate change legislation 

is enacted during the rulemaking process. 

DOE identified several other regulations relevant to refrigeration products manufacturers 

during interviews conducted as part of the manufacturing impact analysis. These issues included 

regulations from the Consumer Products Safety Commission (CPSC), new DOE test procedures 

for residential refrigeration products, amended energy conservation standards for other products 

manufactured by refrigeration products manufacturers, state energy conservation standards, and 

international energy conservation standards. All of these regulations and the potential climate 

change legislation are described further in Chapter 12. 

2.10.5 Preliminary Results for the Manufacturer Impact Analysis 

 As part of the preliminary MIA, DOE discussed potential impacts of amended energy 

conservation standards with manufacturers of residential refrigeration products. These 

discussions took place during the interviews DOE conducted for the engineering analysis. The 

interviews provided valuable information that DOE will use to evaluate the impacts of amended 

energy conservation standards on manufacturers’ cash flows, manufacturing capacities, and 

employment levels in subsequent phases of the MIA. DOE discusses its findings from the 

preliminary MIA interviews in the executive summary and in chapter 12 of the preliminary TSD. 

2.11 UTILITY IMPACT ANALYSIS 

 The utility impact analysis includes an analysis of the effect of new energy conservation 

standards on the electric and the gas utility industries. For this analysis, DOE adapted NEMS, 

which is a large multi-sectoral, partial-equilibrium model of the U.S. energy sector that the EIA 

has developed throughout the past decade, primarily for preparing EIA’s AEO. In previous 

rulemakings, a variant of NEMS (currently termed NEMS-BT, BT referring to DOE’s Building 

Technologies Program), was developed to better address the specific impacts of an energy 

conservation standard. 

 NEMS, which is available in the public domain, produces a widely recognized baseline 

energy forecast for the United States through the year 2030. The typical NEMS outputs include 

forecasts of electricity sales, prices, and electric generating capacity. DOE conducts the utility 

impact analysis as a scenario that departs from the latest AEO reference case. In other words, the 

EERE-2008-BT-STD-0012 COMMENT 22
2-29

energy savings impacts from amended energy conservation standards are modeled using NEMSBT to generate forecasts that deviate from the AEO reference case. 

2.12 ENVIRONMENTAL IMPACT ANALYSIS 

 The intent of the environmental assessment is to fulfill requirements to properly quantify 

and consider the environmental effects of all new Federal rules. The primary environmental 

effects of energy conservation standards for heating products would be reduced power plant 

emissions resulting from reduced consumption of electricity. DOE will assess these 

environmental effects by using NEMS-BT to provide key inputs to its analysis. The portion of 

the environmental assessment that will be produced by NEMS-BT considers carbon dioxide 

(CO2), sulfur dioxide (SO2), nitrogen oxides (NOX), and mercury (Hg). 

 DOE has preliminarily determined that SO2 emissions from affected Electric Generating 

Units (EGUs) are subject to nationwide and regional emissions cap and trading programs that 

create uncertainty about standard’s impact on SO2 emissions. Title IV of the Clean Air Act sets 

an annual emissions cap on SO2 for all affected EGUs. SO2 emissions from 28 eastern States 

and the District of Columbia (D.C.) are also limited under the Clean Air Interstate Rule (CAIR, 

published in the Federal Register on May 12, 2005. 70 FR 25162 (May 12, 2005), which creates 

an allowance-based trading program that will gradually replace the Title IV program in those 

States and D.C.. (The recent legal history surrounding CAIR is discussed below.) The attainment 

of the emissions caps is flexible among EGUs and is enforced through the use of emissions 

allowances and tradable permits. The standard could lead EGUs to trade allowances and 

increase SO2 emissions that offset some or all SO2 emissions reductions attributable to the 

standard. DOE is not certain that there will be reduced overall SO2 emissions from the 

standards. The NEMS-BT modeling system that DOE plans to use to forecast emissions 

reductions currently indicates that no physical reductions in power sector emissions would occur 

for SO2,. However, remaining uncertainty prevents DOE from estimating SO2 reductions from 

the standards at this time. 

 Even though DOE is not certain that there will be reduced overall emissions from the 

standard, there may be an economic benefit from reduced demand for SO2 emission allowances. 

Electricity savings decrease the generation of SO2 emissions from power production, which can 

lessen the need to purchase SO2 emissions allowance credits, and thereby decrease the costs of 

complying with regulatory caps on emissions. 

 With regard to NOX emissions, the U.S. Environmental Protection Agency (EPA) issued 

the Clean Air Interstate Rule (CAIR) on March 10, 2005. 70 FR 25162 (May 12, 2005). On July 

11, 2008, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) issued its 

decision in North Carolina v. Environmental Protection Agency, in which the court vacated the 

CAIR and remanded to EPA to promulgate a rule consistent with the court’s opinion. 531 F.3d 

896 (D.C. Cir. 2008). If left in place, the CAIR would have permanently capped emissions of 

NOX in 28 eastern States and the District of Columbia. However, upon consideration of petitions 

for review, the D.C. Circuit decided on December 23, 2008 to allow CAIR to remain in effect 

EERE-2008-BT-STD-0012 COMMENT 22
2-30

until it is replaced by a rule consistent with the court's earlier opinion. North Carolina v. 

EnvironmentalProtection Agency, 550 F.3d 1176 (D.C. Cir. 2008). Therefore, DOE’s 

Environmental Analysis is based on CAIR, pending revision by EPA. See 

www.epa.gov/cleanairinterstaterule. 

 Similarly, for Hg emissions, the EPA issued the Clean Air Mercury Rule (CAMR). 70 FR 

28606 (May 18, 2005). CAMR would have permanently capped emissions of mercury for new 

and existing coal-fired power plants in all States by 2010. However, on February 8, 2008, the 

D.C. Circuit issued its decision in New Jersey v. Environmental Protection Agency, in which the 

D.C. Circuit, among other actions, vacated the CAMR. 517 F.3d 574 (D.C. Cir. 2008). EPA has 

decided to develop emissions standards for power plants under the Clean Air Act (Section 112), 

consistent with the D.C. Circuit’s opinion on the Clean Air Mercury Rule (CAMR). See 

http://www.epa.gov/air/mercuryrule/pdfs/certpetition_withdrawal.pdf. Pending EPA's 

forthcoming revisions to the rule, DOE is excluding the CAMR from its Environmental 

Analysis. 

 Both with and without emissions caps, decreased power production at emitting power 

plants can have environmental-related economic benefits. When NOX and Hg emissions are 

subject to emissions caps, electricity demand reductions may result in incremental changes in the 

prices of emissions allowances in cap-and-trade emissions markets rather than physical 

emissions reductions. When there are physical emissions reductions, economic benefits can 

accrue from the decreased environmental damage from lower emissions. Therefore, both with 

and without emissions caps, standards can produce an environmental-related economic benefit in 

the form of lower prices for emissions allowance credits or a monetary value of the economic 

benefits of lower emissions. Therefore in addition to potential physical emissions reductions, 

DOE will examine the potential monetary value of NOX and Hg benefits that may arise from a 

standard. DOE has used updated estimate(s) of the value of avoided NOX and Hg emissions in 

recent DOE efficiency standards rulemakings. These estimates are summarized in the 

environmental assessment in the preliminary TSD. 

 The results for the environmental assessment are similar to NEMS results as published in 

the AEO. These results include power sector emissions for SO2, NOX, Hg, and CO2 in five-year 

forecasted increments. The outcome of the analysis for each analyzed standard level will be 

reported as a deviation from the AEO 2009 reference (base) case. 

 EEI stated that DOE should account for the rise in renewable portfolio standards and the 

possibility of an upcoming CO2 cap and trade program, which would reduce the amount of CO2

produced per kWh generated. (EEI, No. 13 at p. 5) As stated above, DOE utilizes the most recent 

forecasts from EIA’s NEMS to estimate the future mix of power generation sources. EIA 

accounts for policies that have been enacted at the time of its analysis, including renewable 

portfolio standards and regional cap and trade programs, and DOE believes that this approach 

provides the most reliable basis for estimating future power sector emissions. 

 NRDC stated that since climate change legislation is extremely likely to be enacted by 

2014, which would place limits on CO2 levels, the analyses should monetize the value of avoided 

EERE-2008-BT-STD-0012 COMMENT 22
2-31

CO2. (NRDC, No. 7 at p. 118) The Joint Comment agreed, stating that the analyses cannot be 

considered accurate descriptions of economic justification for standard setting until a realistic 

value for avoided CO2 emissions is included. It suggested that DOE utilize carbon values from 

EIA’s analysis of climate legislation proposed in Congress. (Joint Comment, No. 10 at p. 8) 

Whirlpool argued against using values for avoided CO2 in DOE’s analysis, stating that projected 

market values are too uncertain. (Whirlpool, No. 17 at p. 13) DOE has used updated estimate(s) 

of the value of avoided CO2 emissions in recent efficiency standards rulemakings. These 

estimates are summarized in the environmental assessment in the preliminary TSD. 

 

 EEI stated that the environmental assessment should consider emissions created during 

equipment production and delivery, taking account of emissions where the appliances are 

produced. (EEI, No. 13 at p. 5) EPCA directs DOE to consider the projected amount of energy 

savings likely to result directly from imposition of the standard. (42 U.S.C. 6295(o)(2)(B)(i)) As 

emissions created during appliance production and delivery are not considered a direct impact of 

standards, DOE does not plan to include such emissions in its analysis. 

 For more detail on the environmental assessment, refer to the environmental assessment 

report in the preliminary TSD. 

2.13 EMPLOYMENT IMPACT ANALYSIS 

 The imposition of standards can affect employment both directly and indirectly. Direct 

employment impacts are changes, produced by new standards, in the number of employees at 

plants that produce the covered products and at the affiliated distribution and service companies. 

DOE evaluated direct employment impacts in the manufacturer impact analysis. Indirect 

employment impacts that occur because of the imposition of standards may result from 

consumers shifting expenditures between goods (the substitution effect) and from changes in 

income and overall expenditure levels (the income effect). DOE will utilize Pacific Northwest 

National Laboratory’s impact of sector energy technologies (ImSET) model to investigate the 

combined direct and indirect employment impacts. The ImSET model, which was developed for 

DOE’s Office of Planning, Budget, and Analysis, estimates the employment and income effects 

energy-saving technologies produced in buildings, industry, and transportation. In comparison 

with simple economic multiplier approaches, ImSET allows for more complete and automated 

analysis of the economic impacts of energy conservation investments. 

2.14 REGULATORY IMPACT ANALYSIS 

 In the NOPR stage, DOE will prepare a regulatory impact analysis (RIA) pursuant to 

Executive Order 12866, Regulatory Planning and Review, 58 FR 51735, October 4, 1993, which 

is subject to review under the Executive Order by the Office of Information and Regulatory 

Affairs at the Office of Management and Budget. The RIA addresses the potential for nonregulatory approaches to supplant or augment energy conservation standards in order to improve 

EERE-2008-BT-STD-0012 COMMENT 22
2-32

the energy efficiency or reduce the energy consumption of the products covered under this 

rulemaking. 

 DOE recognizes that voluntary or other non-regulatory efforts by manufacturers, utilities, 

and other interested parties can substantially affect energy efficiency or reduce energy 

consumption. DOE will base its assessment on the actual impacts of any such initiatives to date, 

but also will consider information presented by interested parties regarding the impacts existing 

initiatives might have in the future. 

2.15 DEVELOPMENT OF STANDARDS FOR LOW-VOLUME PRODUCT 

CLASSES 

DOE conducted rigorous analysis of seven key product classes which represent over 90 

percent of refrigeration product shipments. This section addresses the treatment of low-volume 

product classes. As presented in Table 2.15.1 through Table 2.15.3 below, DOE proposes to 

develop energy conservation standards for these product classes by extrapolating from the results 

for the seven key product classes. In this specific case of product class 3A, Figure 2.15.1 

illustrates that all-refrigerators with automatic defrost of this proposed product class appear to 

currently have a less stringent standard than refrigerator-freezers with top-mounted freezers—

both of these product types currently are part of product class 3. The plot shows that ENERGY 

STAR models categorized under product class 3 have a distinctly higher energy use than 

ENERGY STAR models that fall under the proposed product class 3A. 

EERE-2008-BT-STD-0012 COMMENT 22
2-33

Table 2.15.1 Extrapolation of Standards for Standard-Size Refrigerators and RefrigeratorFreezers 

Product 

Class 

Proposed Approach to 

Development of Energy 

Conservation Standards 

Notes and Comments 

1 Reduction of standard if needed 

so that product class 1 energy 

use is no higher than energy use 

of product class 3. Otherwise 

no change. 

The product class 1 energy standard is currently roughly 

11% lower than the standard for product class 3. 

AHAM data show that product classes 1 and 2 accounted 

for 0.1% of shipments of refrigerators, refrigeratorfreezers, and freezers in 2007. 

1A Establish the standard with the 

same percentage adjustment as 

for product class 1. 

As discussed in section 5.7.4 of the Engineering Analysis 

(chapter 5), the baseline-efficiency energy use under the 

proposed test procedure for product class 1A is less than 

the energy use for product class 1. The future energy 

standard for product class 1A would likewise be less. 

2 Combine this product class 

with product class 1. 

The energy standards for product classes 1 and 2 are 

currently identical, and shipments of these products are 

very low. 

3A Establish the standard with the 

same percentage adjustment as 

for product class 3. 

The baseline-efficiency energy use under the proposed test 

procedure for product class 3A is less than the energy use 

for product class 3. The future energy standard for product 

class 3A would likewise be less. The current product class 

3 standard is less stringent for all-refrigerators than for 

top-mount refrigerator-freezers, as indicated by the 

availability only of all-refrigerators of this product class 

with efficiency level higher than 20% in the ENERGY 

STAR database (see Figure 2.15.1). Hence, allrefrigerators are expected to achieve the same reduction in 

energy use with no reduction in cost-effectiveness. 

4 Establish the standard with the 

same percentage adjustment as 

for product class 7, with some 

consideration of adjustment of 

the slope of the energy/adjusted 

volume relationship. 

See section 5.4.2.3 of the Engineering Analysis (chapter 5) 

for a discussion of the investigation of the energy/adjusted 

volume slope. 

5A Establish the standard with the 

same percentage adjustment as 

for product class 5. 

6 Establish the standard with the 

same percentage adjustment as 

for product class 3. 

EERE-2008-BT-STD-0012 COMMENT 22
2-34

Figure 2.15.1 Current Product Class 3 Products Listed in the ENERGY STAR Database 

Table 2.15.2 Extrapolation of Standards for Standard-Size Freezers 

Product 

Class 

Proposed Approach to Development of 

Energy Conservation Standards 

Notes and Comments 

8 Establish the standard with the same 

percentage adjustment as for product class 

10. 

Although product class 8 freezers are upright 

freezers, they have manual defrost, making 

them more similar to product class 10 

(primarily chest freezers with manual 

defrost) than product class 9 (upright freezers 

with automatic defrost). The current energy 

standard for product class 8 is also is much 

closer to that of product class 10 than 

product class 9. 

10A Establish the standard equal to the standard 

for product class 10 plus the automatic 

defrost differential of the energy standards 

for the two types of upright freezers (product 

class 9 and product class 8). 

This is the approach used in the exception 

granted to Electrolux when the company 

initially introduced an automatic defrost 

chest freezer.d

 

d Decision and Order, Electrolux Home Products, Inc., Office of Hearings and Appeals, September 13, 2004, (Last 

accessed July 23, 2009.), www.oha.doe.gov/cases/ee/tee0012.pdf 

EERE-2008-BT-STD-0012 COMMENT 22
2-35

Table 2.15.3 Extrapolation of Standards for Compact Refrigerators, Refrigerator-Freezers, 

and Freezers 

Product 

Class 

Proposed Approach to 

Development of Energy 

Conservation Standards 

Notes and Comments 

11A Establish the standard with the 

same percentage adjustment as for 

product class 11. 

The baseline-efficiency energy use under the proposed 

test procedure for product class 11A is less than the 

energy use for product class 11. The future energy 

standard for product class 11A would likewise be less. 

12 Combine this product class with 

product class 11. 

Product class 12 currently has a different energy 

standard than product class 11 (it is 20 to 25% higher, 

depending on volume), while for standard-size 

products, the manual defrost and partial automatic 

defrost products have the same energy standard 

(product classes 1 and 2). The only product class 12 

products DOE is aware of have energy use about 30% 

below the standard (i.e. Microfridge MFR-3, Absocold 

ARD298C), suggesting that the product classes could 

be combined. 

13 Establish the standard with the 

same percentage adjustment as for 

product class 18. 

Large energy use reductions are not likely costeffective for these products because they have low 

production volume, hence the incremental cost 

relationship of compact freezers is more likely 

representative than that of product class 11. 

13A Establish the standard with the 

same percentage adjustment as for 

product class 13. 

Many existing product class 13 products are allrefrigerators with automatic defrost. The Energy Star 

database has no product class 13 products which are 

top-mount rather than all-refrigerator. As with product 

class 3 and 3A, it is expected that achieving efficiency 

improvement for product class 13A will be no less 

cost-effective than for product class 13. 

14 

15 

Establish the standard with the 

same percentage adjustment as for 

product class 13. 

These product classes combined account for only 0.1% 

of shipments of refrigeration products according to 

AHAM data. 

16 

17 

Establish the standard with the 

same percentage adjustment as for 

product class 18. 

EERE-2008-BT-STD-0012 COMMENT 22
2-36

REFERENCES 

 

1

 U.S. Department of Energy-Energy Information Administration, Residential Energy 

Consumption Survey, 2001 Public Use Microdata Files, 2005. Washington, DC. 

<http://www.eia.doe.gov/emeu/recs/recspubuse05/pubuse05.html> 

2

 California Energy Commission, California Energy Commission Appliances Database, 

Appliances Database – Refrigeration. Sacramento, CA. 

<http://www.energy.ca.gov/appliances/database/excel_based_files/Refrigeration/> 

(Last Accessed March 2009) 

3

 U.S. Department of Energy-Energy Information Administration, An Updated Annual Energy 

Outlook 2009 Reference Case Reflecting Provisions of the American Recovery and 

Reinvestment Act and Recent Changes in the Economic Outlook, April 2009. Washington, 

DC. Report #: SR-OIAF/2009-03. 

 <http://www.eia.doe.gov/oiaf/servicerpt/stimulus/index.html?featureclicked=1&> 

4

 Edison Electric Institute, Typical Bills and Average Rates Report – Summer 2008, 2008. For 

purchase at: 

http://www2.eei.org/products_and_services/descriptions_and_access/typ_bills_report.htm. 

5

 Edison Electric Institute, Typical Bills and Average Rates Report – Winter 2008, 2008. For 

purchase at: 

http://www2.eei.org/products_and_services/descriptions_and_access/typ_bill_winter_5.htm. 

6

 U.S. Department of Energy, Technical Report: Analysis of Amended Energy Conservation 

Standards for Residential Refrigerator-Freezers, October 2005. Washington, DC. 

<http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/refrigerator_report_1.pdf> 

7

 U.S. Department of Energy, Technical Support Document: Energy Efficiency Standards for 

Consumer Products: Refrigerators, Refrigerator-Freezers, & Freezers, July 1995. 

Washington, DC. Report No. DOE/EE-0064. 

8

 Office of Management and Budget, OMB Circular A-4, “Regulatory Analysis,” Sept. 17, 

2003. Washington, DC. p. 33. <www.whitehouse.gov/omb/circulars/index.html> 

9

 Office of Management and Budget, OMB Circular A-4, “Regulatory Analysis,” Sept. 17, 

2003. Washington, DC. p. 34. <www.whitehouse.gov/omb/circulars/index.html> 

10 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Energy 

Conservation Program: Energy Conservation Standards for General Service Fluorescent 

Lamps and Incandescent Reflector Lamps; Proposed Rule. Federal Register, 2009. 74(69): 

pp. 16920-16968. 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 3: MARKET AND TECHNOLOGY ASSESSMENT 

TABLE OF CONTENTS 

3.1 INTRODUCTION ........................................................................................................... 3-1 

3.1.1 Product Definitions .......................................................................................................... 3-1 

3.1.1.1 Refrigerators, Refrigerator-Freezers, and Freezers........................................ 3-1 

3.1.1.2 Wine Coolers .................................................................................................3-2 

3.2 MARKET ASSESSMENT .............................................................................................. 3-2 

3.2.1 Product Classes ................................................................................................................ 3-2 

3.2.1.1 Product Classes Listed in the CFR................................................................. 3-2 

3.2.1.2 Product Classes Modifications....................................................................... 3-2 

3.2.1.3 Bottom-Drawer Refrigerator-Freezers........................................................... 3-4 

3.2.2 Product Test Procedures .................................................................................................. 3-4 

3.2.2.1 New Defrost Systems..................................................................................... 3-5 

3.2.2.2 Control of Anti-Sweat Heaters....................................................................... 3-5 

3.2.2.3 Testing of Combination Wine Storage--Freezer Products............................. 3-5 

3.2.2.4 Repeatability Issues for Testing Compact Refrigerators ............................... 3-6 

3.2.2.5 Circumvention................................................................................................ 3-6 

3.2.2.6 Bottom-Drawer Refrigerator-Freezer Models ...............................................3-7 

3.2.2.7 Harmonizing with International Test Procedures .......................................... 3-7 

3.2.2.8 Standby and Off Modes ................................................................................. 3-7 

3.2.3 Manufacturer Information................................................................................................ 3-9 

3.2.3.1 Refrigerator, Refrigerator-Freezer, and Freezer Manufacturers .................... 3-9 

3.2.3.2 Refrigerator, Refrigerator-Freezer, and Freezer Manufacturer Market 

Shares .......................................................................................................... 3-12 

3.2.3.3 Mergers and Acquisitions ............................................................................ 3-14 

3.2.3.4 Distribution Channels .................................................................................. 3-15 

3.2.3.5 Manufacturer Trade Groups......................................................................... 3-15 

3.2.3.6 Compressor Manufacturers and Market Shares...........................................3-16 

3.2.4 Regulatory Programs ..................................................................................................... 3-16 

3.2.4.1 Federal Energy Conservation Standards...................................................... 3-16 

3.2.4.2 State Energy Conservation Standards.......................................................... 3-19 

3.2.4.3 Canadian Energy Conservation Standards...................................................3-19 

3.2.4.4 Mexican Energy Conservation Standards.................................................... 3-20 

3.2.4.5 Efficiency Standards Outside North America.............................................. 3-20 

3.2.5 Voluntary and other Federal and State Programs .......................................................... 3-21 

3.2.5.1 ENERGY STAR .......................................................................................... 3-21 

3.2.5.2 Federal Energy Management Program ........................................................ 3-23 

3.2.5.3 Consortium for Energy Efficiency............................................................... 3-24 

3.2.5.4 ENERGY STAR, FEMP, CEE Summary.................................................... 3-25 

3.2.5.5 Manufacturer Tax Credits for Energy-Efficient Appliances ....................... 3-25 

3.2.5.6 Rebates for Highly Energy-Efficient Products............................................ 3-26 

3.2.5.7 State Tax Incentives for Highly Energy-Efficient Products........................ 3-26 

3.2.6 Historical Shipments and Efficiencies........................................................................... 3-26 

3-i 

EERE-2008-BT-STD-0012 COMMENT 22
3.2.6.1 Historical Shipments.................................................................................... 3-26 

3.2.6.2 Historical Efficiencies.................................................................................. 3-29 

3.2.6.3 Imports and Exports..................................................................................... 3-31 

3.2.7 Saturation in U.S. Homes .............................................................................................. 3-31 

3.2.8 Product Retail Prices...................................................................................................... 3-35 

3.2.8.1 Historical Retail Prices ................................................................................ 3-35 

3.2.8.2 Refrigerator-Freezer 2004 Retail Prices ...................................................... 3-35 

3.2.8.3 2007 Manufacturer-Suggested Retail Prices................................................ 3-37 

3.2.8.4 Refrigerator-Freezer and Freezer 2008 Retail Prices...................................3-42 

3.3 TECHNOLOGY ASSESSMENT.................................................................................. 3-43 

3.3.1 Product Operation and Components .............................................................................. 3-43 

3.3.1.1 Product Operation ........................................................................................ 3-43 

3.3.1.2 Primary Components ................................................................................... 3-44 

3.3.2 Technology Options....................................................................................................... 3-48 

3.3.2.1 Insulation...................................................................................................... 3-49 

3.3.2.2 Gasket and Door Design .............................................................................. 3-53 

3.3.2.3 Anti-Sweat Heater........................................................................................ 3-55 

3.3.2.4 Compressor .................................................................................................. 3-56 

3.3.2.5 Evaporator.................................................................................................... 3-60 

3.3.2.6 Condenser ....................................................................................................3-61 

3.3.2.7 Fan and Fan Motor....................................................................................... 3-63 

3.3.2.8 Expansion Valve .......................................................................................... 3-63 

3.3.2.9 Cycling Losses.............................................................................................3-64 

3.3.2.10 Defrost System............................................................................................. 3-64 

3.3.2.11 Control System............................................................................................. 3-65 

3.3.2.12 Other Technologies...................................................................................... 3-66 

3.3.2.13 Alternative Refrigeration Cycles ................................................................. 3-67 

3.3.2.14 Alternative Refrigeration Systems............................................................... 3-70 

3.3.3 Energy Efficiency .......................................................................................................... 3-70 

LIST OF TABLES 

Table 3.2.1 Product Classes for Refrigerators, Refrigerator-Freezers, and Freezers................. 3-4 

Table 3.2.2 Refrigerator, Refrigerator-Freezer, and Freezer Manufacturers........................... 3-10 

Table 3.2.3 Standard-Size Refrigerator-Freezer Manufacturer Market Shares ....................... 3-12 

Table 3.2.4 Compact Refrigerator Manufacturer Market Shares............................................. 3-13 

Table 3.2.5 Built-In Undercounter Refrigerator Manufacturer Market Shares ....................... 3-13 

Table 3.2.6 Chest/Upright Freezer Manufacturer Market Shares............................................ 3-14 

Table 3.2.7 Major Appliance Sales by Channel....................................................................... 3-15 

Table 3.2.8 Compressor Manufacturers and World and U.S. Market Shares.......................... 3-16 

Table 3.2.9 Federal Energy Efficiency Standards for Refrigerators, RefrigeratorFreezers, and Freezers........................................................................................... 3-18 

Table 3.2.10 California Standards for Wine Chillers ................................................................ 3-19 

Table 3.2.11 California Standards for Freezers with Volume Greater than 30 cubic feet......... 3-19 

3-ii 

EERE-2008-BT-STD-0012 COMMENT 22
Table 3.2.12 Canadian Energy Standards for Added Refrigerator and Freezer Product 

Classes................................................................................................................... 3-20 

Table 3.2.13 Canadian Standards for Wine Chillers.................................................................. 3-20 

Table 3.2.14 History of ENERGY STAR Energy Use Criteria for Residential 

Refrigerators and Freezers .................................................................................... 3-22 

Table 3.2.15 Efficiency of Standard Refrigerators and Refrigerator-Freezers on the 

Market Relative to Current Federal Standard ....................................................... 3-23 

Table 3.2.16 Performance Requirement for Federal Purchases of Refrigerators and 

Freezers................................................................................................................. 3-24 

Table 3.2.17 CEE Tier Levels Refrigerators and Refrigerator-Freezers ................................... 3-25 

Table 3.2.19 Manufacturer Tax Credits for Energy-Efficient Appliances in EESA 2008 ........ 3-26 

Table 3.2.20 Rebates Offered for Highly Energy-Efficient Refrigerators in 2006 ................... 3-26 

Table 3.2.21 Market Shares of Standard Refrigerator-Freezer Product Classes ....................... 3-29 

Table 3.2.22 Sales of ENERGY STAR Labeled Refrigerator-Freezers.................................... 3-30 

Table 3.2.23 Standard Refrigerator Saturation in U.S. Homes in 1987–2005 Period ............... 3-32 

Table 3.2.24 Compact Refrigerator Saturation in U.S. Homes in 1987–2005 Period............... 3-33 

Table 3.2.25 Freezer Saturation in U.S. Homes in 1987-2005 Period....................................... 3-34 

Table 3.2.26 Refrigerator and Freezer Saturation in New U.S. Homes..................................... 3-35 

Table 3.2.27 Refrigerator-Freezer and Freezer Average Retail Prices...................................... 3-35 

Table 3.2.28 Baseline Unit Retail Prices from 2005 DOE Report (2004$)............................... 3-36 

Table 3.2.30 Regression Analysis of the Incremental Price of ENERGY STAR and other 

Attributes based on 2007 Manufacturer-Suggested Retail Prices (2007$)........... 3-42 

Table 3.2.31 Residential Refrigeration Products: Average Baseline Retail Price..................... 3-43 

Table 3.3.1 Technology Options for Refrigerators, Refrigerator-Freezers, and Freezers ....... 3-49 

Table 3.3.2 Thermal Conductivity of Freshly-Sliced Foam Specimens at 75 oF (23.9 oC) ..... 3-50 

Table 3.3.3 Comparison of Various VIP Core Materials......................................................... 3-51 

Table 3.3.4 Center-of-Panel Thermal Conductivity of VIPs ................................................... 3-52 

Table 3.3.5 Comparison of Various Gas-Filled Panel Core Materials .................................... 3-53 

Table 3.3.6 Overall Cabinet Loads .......................................................................................... 3-54 

Table 3.3.7 Compressor Rating Conditions............................................................................. 3-57 

Table 3.3.8 Estimated 1998 Maximum Compressor Efficiencies ........................................... 3-58 

Table 3.3.9 Efficiencies of Some of Embraco’s Variable-Speed Compressor Models ........... 3-59 

Table 3.3.10 Efficiencies of LG’s Current Linear Compressor Models.................................... 3-60 

LIST OF FIGURES 

Figure 3.2.1 Annual Shipments of Refrigerators and Refrigerator-Freezers ......................... 3-27 

Figure 3.2.2 Annual Shipments of Freezers........................................................................... 3-28 

Figure 3.2.3 Average Annual Electricity Use of New Refrigerator-Freezers and 

Freezers.............................................................................................................. 3-30 

Figure 3.2.4 2007 Manufacturer-Suggested Retail Price Distribution of Side-Mount 

Refrigerator-Freezers with and without ENERGY STAR (2007$)................... 3-38 

Figure 3.2.5 2007 Manufacturer-Suggested Retail Price Distribution of Top-Mount 

Refrigerator-Freezers with and without ENERGY STAR (2007$)................... 3-39 

3-iii 

EERE-2008-BT-STD-0012 COMMENT 22
Figure 3.2.7 2007 Manufacturer-Suggested Retail Price Distribution of Upright 

Freezers with and without ENERGY STAR (2007$)........................................ 3-40 

Figure 3.2.8 2007 Manufacturer-Suggested Retail Price Distribution of Chest Freezers 

with and without ENERGY STAR (2007$) ...................................................... 3-40 

Figure 3.3.1 Refrigeration Circuit .......................................................................................... 3-44 

Figure 3.3.2 Top-Mount Refrigerator-Freezer Components.................................................. 3-45 

Figure 3.3.3 Annual Energy Consumption for Refrigerators and Refrigerator-Freezers 

with Manual Defrost (Product Class #1) ........................................................... 3-72 

Figure 3.3.4 Annual Energy Consumption for Refrigerator-Freezers with Partial 

Automatic Defrost (Product Class #2)............................................................... 3-72 

Figure 3.3.5 Annual Energy Consumption for Top-Mount Refrigerator-Freezers with 

Automatic Defrost without TTD Ice Service and All-Refrigerators with 

Automatic Defrost (Product Class #3)............................................................... 3-73 

Figure 3.3.6 Annual Energy Consumption for Side-Mount Refrigerator-Freezers with 

Automatic Defrost without TTD Ice Service (Product Class #4)...................... 3-73 

Figure 3.3.7 Annual Energy Consumption for Bottom-Mount Refrigerator-Freezers 

with Automatic Defrost without TTD Ice Service (Product Class #5).............. 3-74 

Figure 3.3.8 Annual Energy Consumption for Bottom-Mount Refrigerator-Freezers 

with Automatic Defrost with TTD Ice Service (Product Class 5A) .................. 3-74 

Figure 3.3.9 Annual Energy Consumption for Top-Mount Refrigerator-Freezers with 

Automatic Defrost with TTD Ice Service (Product Class #6) ........................... 3-75 

Figure 3.3.10 Annual Energy Consumption for Side-Mount Refrigerator-Freezers with 

Automatic Defrost with Through-the-Door Ice Service (Product Class #7) ..... 3-75 

Figure 3.3.11 Annual Energy Consumption for Upright Freezers with Manual Defrost 

(Product Class #8).............................................................................................. 3-76 

Figure 3.3.12 Annual Energy Consumption for Upright Freezers with Automatic Defrost 

(Product Class #9).............................................................................................. 3-76 

Figure 3.3.13 Annual Energy Consumption for Chest Freezers and all other Freezers 

except Compact Freezers (Product Class #10) .................................................. 3-77 

Figure 3.3.14 Annual Energy Consumption for Chest Freezers with Automatic Defrost 

(Product Class #10A)......................................................................................... 3-77 

Figure 3.3.15 Annual Energy Consumption for Compact Refrigerators and RefrigeratorFreezers with Manual Defrost (Product Class #11)........................................... 3-78 

Figure 3.3.16 Annual Energy Consumption for Compact Refrigerator-Freezers with 

Partial Automatic Defrost (Product Class #12) ................................................. 3-78 

Figure 3.3.17 Annual Energy Consumption for Compact Top-Mount RefrigeratorFreezers with Automatic Defrost and All-Refrigerators with Automatic 

Defrost (Product Class #13)............................................................................... 3-79 

Figure 3.3.18 Annual Energy Consumption for Compact Side-Mount RefrigeratorFreezers with Automatic Defrost (Product Class #14) ...................................... 3-79 

Figure 3.3.19 Annual Energy Consumption for Compact Bottom-Mount RefrigeratorFreezers with Automatic Defrost (Product Class #15) ...................................... 3-80 

Figure 3.3.20 Annual Energy Consumption for Compact Upright Freezers with Manual 

Defrost (Product Class #16)............................................................................... 3-80 

3-iv 

EERE-2008-BT-STD-0012 COMMENT 22
Figure 3.3.21 Annual Energy Consumption for Compact Upright Freezers with 

Automatic Defrost (Product Class #17)............................................................. 3-81 

Figure 3.3.22 Annual Energy Consumption for Compact Chest Freezers (Product Class 

#18) .................................................................................................................... 3-81 

3-v 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 3.MARKET AND TECHNOLOGY ASSESSMENT 

3.1 INTRODUCTION 

This report provides a profile of the residential refrigerator and freezer product industries 

in the United States. The U.S. Department of Energy (DOE) developed the preliminary market 

and technology assessment presented in this chapter primarily from publicly available 

information. This assessment identifies the major manufacturers and their product characteristics, 

which form the basis for the engineering and the life-cycle cost (LCC) analyses. Present and past 

industry structure and industry financial information help DOE in the process of conducting the 

manufacturer impact analysis. 

3.1.1 Product Definitions 

3.1.1.1 Refrigerators, Refrigerator-Freezers, and Freezers 

The Code of Federal Regulations (CFR) establishes the product definitions for 

refrigerators, refrigerator-freezers, and freezers as follows:1 

•	 The term Refrigerator means an electric refrigerator and the term Refrigerator-freezer 

means an electric refrigerator-freezer. 

•	 Electric refrigerator means a cabinet designed for the refrigerated storage of food at 

temperatures above 32 degrees Fahrenheit (°F) and below 39 °F, configured for general 

refrigerated food storage, and having a source of refrigeration requiring single phase, 

alternating current electric energy input only. An electric refrigerator may include a 

compartment for freezing and storage of food at temperatures below 32 °F, but does not 

provide a separate low temperature compartment designed for the freezing and storage of 

food at temperatures below 8 °F. 

•	 Electric refrigerator-freezer means a cabinet which consists of two or more 

compartments with at least one of the compartments designed for the refrigerated storage 

of food at temperatures above 32 °F. and with at least one of the compartments designed 

for the freezing and storage of food at temperatures below 8 °F. which may be adjusted 

by the user to a temperature of 0 °F. or below. The source of refrigeration requires single 

phase, alternating current electric energy input only. 

•	 Compact refrigerator, refrigerator-freezer, and freezer means any refrigerator, 

refrigerator-freezer or freezer with total volume less than 7.75 ft3

 (220 L) and 36 inches 

(0.91 meters) or less in height. 

•	 Freezer means a cabinet designed as a unit for the freezing and storage of food at 

temperatures of 0 °F or below, and having a source of refrigeration requiring single 

phase, alternating current electric energy input only. 

3-1 

EERE-2008-BT-STD-0012 COMMENT 22
3.1.1.2 Wine Coolers 

DOE amended the definition of “electric refrigerator”, effective December 19, 2001, to 

include a maximum temperature of the fresh food storage compartment, and to exclude certain 

appliances whose physical configuration makes them unsuitable for general storage of perishable 

foods.2

 Because wines coolers maintain storage temperature above 39 oF, they are exempted 

from existing refrigerator product classifications and are not required to meet minimum 

efficiency standards. 

3.2 MARKET ASSESSMENT 

3.2.1 Product Classes 

3.2.1.1 Product Classes Listed in the CFR 

The CFR establishes the product classes for refrigerators, refrigerator-freezers, and 

freezers.3

 As per the CFR, there are 18 product classes. The product classes are based on the 

following characteristics: type of unit (refrigerator, refrigerator-freezer, or freezer), size of the 

cabinet (standard or compact), type of defrost system (manual, partial, or automatic), presence or 

absence of through-the-door (TTD) ice service, and placement of the fresh food and freezer 

compartments for refrigerator-freezers. 

DOE established separate product classes for compact products (<220 L or <7.75 ft3) 

because fewer opportunities are available for reducing energy consumption in these products. 

Space is limited in compact units, so increasing the wall thickness is undesirable. Limited highefficiency compressor options are available in the capacity ranges appropriate for compact 

refrigerators. These units typically use natural convection evaporators and condensers and, 

therefore, cannot employ better fan motors as an energy-saving option. 

3.2.1.2 Product Classes Modifications 

Table 3.2.1 below shows six proposed new product classes. Two of these new product 

classes, currently called product class 5A, automatic defrost refrigerator-freezers with bottommounted freezer with TTD ice service, and product class 10A, chest freezers with automatic 

defrost, were identified in the framework document as product classes 19 and 20. DOE proposes 

to establish these two new product classes pursuant to its decision order to grant exemptions to 

standards for these specific product categories. DOE will adopt the product class designations for 

these products which have been adopted by Canada in order to maintain international 

consistency. The additional new product classes are all-refrigerator products which are proposed 

to be separated from their current product classes which currently include refrigerators with 

freezer compartments, refrigerator-freezers, and/or all-refrigerators. The proposed test procedure 

changes described in section 3.2.2.7 will result in significantly higher energy use for refrigerators 

with freezer compartments and refrigerator-freezers and somewhat less energy use for all3-2 

EERE-2008-BT-STD-0012 COMMENT 22
refrigerators. Hence, maintaining meaningful but fair energy standards requires the separation of 

all-refrigerators from the other product types. 

DOE’s Office of Hearings and Appeals granted four exceptions for refrigerator-freezer 

products with bottom-mounted freezer and TTD ice service, to Maytag Corporation (Maytag), 

LG Electronics, Inc. (LG), Samsung Electronics, and Electrolux Home Products. DOE granted 

Maytag its exception on August 11, 2005 (case number TEE-0022), LG’s exception on 

November 9, 2005 (case number TEE-0025), Samsung’s exception on July 26, 2007 (case 

number TEE-0047) and Electrolux’s exception on December, 2008 (case number TEE-0056). 

Before these rulings, there was no appropriately-defined category for this type of product, since 

the minimum standard for product class 5 (refrigerator-freezers with automatic defrost with 

bottom-mounted freezer without TTD ice service) was established to cover only products 

without TTD ice-service at the time of its development. The actual energy consumption of this 

new product (i.e., with TTD ice-service) is higher than that of product class 5 due to the added 

heat loss through the door to the fresh-food space, the reduced temperatures of the space reserved 

in the fresh food compartment for ice storage, which is maintained at lower temperatures than the 

rest of the fresh food compartment, and the energy consumed by the fan used to cool the space 

used for ice production and storage. 

DOE’s Office of Hearings and Appeals granted an exception to Electrolux Home 

Products (Electrolux) for a specific brand of chest freezer with automatic defrost (case number 

TEE-0012). The Association of Home Appliance Manufacturers (AHAM) filed a letter 

supporting this exemption and recommended that DOE use the direct final rule process to 

establish a new class of chest freezers that would correspond to the minimum efficiency standard 

for automatic defrost chest freezers. The minimum standard for product class 10 (chest freezers 

and all other freezers) was established to cover products without automatic defrost at the time of 

its development. The actual energy consumption of the new product (i.e., with automatic defrost) 

is higher than that of product class 10 due to the added energy consumption associated with the 

automatic defrost system. 

DOE is considering combining product classes 1 and 2 and also combining product 

classes 11 and 12. The shipment levels for product classes 1 and 2 are low and the energy 

conservation standards for these products are currently identical. The shipments for product class 

12 are also very low. Although the standard for product classes 12 is currently at a higher energy 

level than for product class 12, there is no obvious technical basis for this distinction. The key 

difference between these classes is that product class 12 includes only refrigerator-freezers with 

partial automatic defrost. These systems have a manual defrost evaporator for the freezer 

compartment (as do refrigerator-freezers of product class 11), and they also include a second 

evaporator in the fresh food compartment which undergoes off-cycle defrost, a process which 

involves no addition of energy to achieve defrost. 

3-3 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 3.2.1 Product Classes for Refrigerators, Refrigerator-Freezers, and Freezers 

No. Product Class 

Classes listed in the CFR 

1 Refrigerators and refrigerator-freezers with manual defrost 

2 Refrigerator-freezers—partial automatic defrost 

3 Refrigerator-freezers—automatic defrost with top-mounted freezer without through-thedoor ice service 

4 Refrigerator-freezers—automatic defrost with side-mounted freezer without through-thedoor ice service 

5 Refrigerator-freezers—automatic defrost with bottom-mounted freezer without through-thedoor ice service 

6 Refrigerator-freezers—automatic defrost with top-mounted freezer with through-the-door 

ice service 

7 Refrigerator-freezers—automatic defrost with side-mounted freezer with through-the-door 

ice service 

8 Upright freezers with manual defrost 

9 Upright freezers with automatic defrost 

10 Chest freezers and all other freezers except compact freezers 

11 Compact refrigerators and refrigerator-freezers with manual defrost 

12 Compact refrigerator-freezers—partial automatic defrost 

13 Compact refrigerator-freezers—automatic defrost with top-mounted freezer 

14 Compact refrigerator-freezers—automatic defrost with side-mounted freezer 

15 Compact refrigerator-freezers—automatic defrost with bottom-mounted freezer 

16 Compact upright freezers with manual defrost 

17 Compact upright freezers with automatic defrost 

18 Compact chest freezers 

Product Classes Proposed to be Established During this Rulemaking 

1A All-refrigerators—manual defrost 

3A All-refrigerators—automatic defrost 

5A Refrigerator-freezers—automatic defrost with bottom-mounted freezer with TTD ice 

service 

10A Chest freezers with automatic defrost 

11A Compact all-refrigerators—manual defrost 

13A Compact all-refrigerators—automatic defrost 

3.2.1.3 Bottom-Drawer Refrigerator-Freezers 

Another product type that was recently on the market is a convertible bottom-drawer 

refrigerator-freezer where the bottom drawer can be used as either a freezer or a fresh food 

section.4 This Haier product became active on the ENERGY STAR database in 2007 but is no 

longer for sale. It was classified as a side-mount refrigerator-freezer with TTD features (product 

class 7) by the ENERGY STAR program (discussed in section 3.7.1).5 

3.2.2 Product Test Procedures 

The CFR establishes the test procedures for refrigerators, refrigerator-freezers, and 

3-4 

EERE-2008-BT-STD-0012 COMMENT 22
freezers. (10 CFR Part 430, Subpart B, Appendices A1 and B1) DOE recently addressed issues 

pertaining to defrost systems, wine cooling refrigeration products, anti-sweat heaters, chest 

freezers with automatic defrost, and refrigerator-freezers with bottom-mounted freezers 

incorporating through-the-door (TTD) features. Additional issues relevant to the test procedures 

include test result repeatability, references to an older version of the ANSI-AHAM HRF-1 test 

standard, circumvention, convertible bottom-drawer refrigerator-freezers and other 

configurations with more than two compartments, standby and off mode energy use, and 

international test procedure harmonization. The ongoing rulemaking to modify the test procedure 

addresses many of these issues. 

3.2.2.1 New Defrost Systems 

DOE published a direct final rule on March 7, 2003 which amended the test procedure for 

refrigerators and refrigerator-freezers to modify the test period for “long-time” and adaptive 

automatic defrost refrigerator-freezers. 68 FR 10957. This revision became effective in May 

2003. The energy test for such refrigerators consists of two or three parts; the third part applies 

only to adaptive defrost refrigerators and is optional. The first part measures energy use not 

including defrost events, and the second measures the energy contribution associated with 

defrost. The measurement for this second part of the test originally was specified to start as the 

refrigerator-freezer initiates defrost during a compressor on cycle. The new test procedure allows 

for a delay between compressor shutdown and defrost initiation, allowing the evaporator to warm 

up somewhat before initiation of defrost, thus saving a portion of the defrost energy 

consumption. 

3.2.2.2 Control of Anti-Sweat Heaters 

DOE granted a test procedure waiver to General Electric Company (GE) for anti-sweat 

heaters with automatic controls. GE developed a new product line of refrigerator-freezers that 

have sensors to detect ambient temperature and humidity, allowing the control system to adjust 

the wattage of anti-sweat heaters to provide only enough heat to evaporate excess moisture. DOE 

awarded this waiver on February 27, 2008.6

 The waiver provides a method for determining the 

energy use of an adaptive anti-sweat heater. A similar waiver was granted to Whirlpool 

Corporation on May 5, 2009.7

 The ongoing test procedure rulemaking proposes a variable antisweat heater test procedure to address the GE waiver and the Whirlpool petition for waiver. 

3.2.2.3 Testing of Combination Wine Storage--Freezer Products 

As discussed in Section 3.1.1.2, DOE has modified the definition of refrigerators to 

exclude wine storage products. However, DOE has not modified the definition of refrigeratorfreezers in a similar fashion to exclude products which combine a freezer compartment with a 

wine storage compartment. DOE granted a waiver to Liebherr Hausgeräte from the existing DOE 

test procedure for residential electric refrigerators and refrigerator-freezers, for Liebherr’s 

combination wine storage-freezer line of appliances. According to the current definitions, these 

products are refrigerator-freezers. In granting the waiver, DOE requires that Liebherr test or rate 

its combination wine storage-freezer products using a modified procedure proposed by Liebherr 

3-5 

EERE-2008-BT-STD-0012 COMMENT 22
in which the wine storage compartment temperature standardized temperature is 55 °F, and the 

freezer compartment standardized temperature is 5 °F. The wine storage compartment of units 

tested by this method must not be convertible to any other type of compartment, and must 

account for 50 percent or more of the total volume.8 DOE expects to propose revision of the 

definition of refrigerator-freezer to exclude these products in the ongoing refrigeration product 

test procedure rulemaking. The establishment of Wine Storage product categories and classes 

thereof is discussed in Chapter 2. 

3.2.2.4 Repeatability Issues for Testing Compact Refrigerators 

Because of inconsistencies in test results for compact refrigerators, the National Institute 

of Standards and Technology (NIST) investigated repeatability issues and published a report 

entitled “Repeatability of Energy Consumption Test Results for Compact Refrigerators.”9

 In 

addition, NIST participated in a task force formed by AHAM to revise their AHAM HRF-1, 

Energy, Performance and Capacity of Household Refrigerators, Refrigerator-Freezers and 

Freezers test procedure, which is referenced by the DOE test procedure. The latest version of 

AHAM’s test procedure is now AHAM HRF-1-2008.10 The existing DOE test procedure still 

references an older version of the AHAM test procedure, AHAM HRF-1-1979. DOE plans to 

amend the test procedure to reference the most recent version of AHAM HRF-1. 

Recent versions of AHAM HRF-1 clarified that the distance between the rear wall of the 

test sample and the test room wall or simulated wall should be at the minimum distance 

recommended by the manufacturer’s installation instructions. This is one of the issues mentioned 

in the NIST report. In contrast, the 1979 version of HRF-1 specified that this distance be “in 

accordance with the manufacturer’s instructions.” The AHAM HRF-1-2008 addresses, among 

other issues, simplification of determining cabinet compartment internal volume, another of the 

issues discussed in the NIST report. 

3.2.2.5 Circumvention 

Another issue that has been addressed by recent versions of AHAM HRF-1 is the use of 

controls or features in products that have the effect of circumventing or frustrating the objective 

of the test procedure. Some refrigerator-freezer models, for example, deactivate certain energyusing components during testing, resulting in a rated performance that is significantly different 

than actual field performance. EPCA requires that test procedures must be “reasonably designed 

to produce test results which measure energy efficiency, energy use, water use . . ., or estimated 

annual operating cost of a covered product during a representative average use cycle or period of 

use, as determined by the Secretary . . . .” 42 U.S.C. 6293(b)(3). This statutory requirement may 

be undermined if products are purposefully designed to use controls or features that produce test 

results that are so unrepresentative of a product’s actual energy or water consumption as to 

provide materially inaccurate comparative data. AHAM incorporated provisions that address 

circumvention in its 2007 and 2008 test procedure revisions. The ongoing DOE test procedure 

rulemaking proposes updating DOE’s test procedures for refrigerators, refrigerator-freezers, and 

freezers to reference the latest version of AHAM HRF-1 in order to include by reference 

language which will more strongly bans circumvention and to provide clarification regarding test 

3-6 

EERE-2008-BT-STD-0012 COMMENT 22
 

sample set-up to help prevent inconsistencies in test results. DOE notes that in its updated 

ENERGY STAR requirements for refrigerator-freezers in 2008, the ENERGY STAR program 

has included a provision to prohibit models from meeting the ENERGY STAR criteria through 

this type of circumvention scheme.11 

3.2.2.6 Bottom-Drawer Refrigerator-Freezer Models 

As discussed above in section 3.3, convertible bottom-drawer refrigerator-freezer models, 

where the bottom drawer can be used as either a freezer or a fresh food section, have been 

produced, although it is unclear whether any such products are currently on the market. It 

appears that the bottom drawer of these product types were tested as a fresh food compartment 

rather than a freezer. This is inconsistent with the provisions of AHAM HRF-1-1979 as well as 

AHAM HRF-1-2008, which require control of compartments that are convertible between 

freezer and fresh food temperature to be tested in the highest energy use position. The ongoing 

DOE test procedure rulemaking addresses this issue and solicits feedback regarding whether this 

requirement needs to be reinforced in the DOE test procedure. 

3.2.2.7 Harmonizing with International Test Procedures 

Working Group 12 of Technical Committee 59 of the International Electrotechnical 

Commission (IEC) is developing IEC 62552, an international test procedure for refrigerators, 

refrigerator-freezers, and freezers. One of the goals of this effort is to maximize harmonization 

among energy test procedures for countries representing key markets for these products. As a 

result, AHAM has incorporated compartment temperature changes into AHAM HRF-1-2008 

which are consistent with the IEC standard. These changes include (1) standard test temperatures 

of 0 °F rather than 5 °F for the freezer compartment of a refrigerator-freezer and 39 °F rather 

than 45 °F for the fresh food compartment, (2) standard test temperature of 39 °F rather than 38 

°F for an all-refrigerator, and (3) standard test temperature of 39 °F rather than 45 °F for the 

fresh food compartment of a refrigerator having a freezer compartment. DOE is also revising the 

DOE energy test procedure to adopt the modified temperatures. The change in temperatures will 

clearly result in higher test energy use for refrigerator-freezers and refrigerators with freezer 

compartments and lower test energy use for all-refrigerators, thus necessitating adjustments to 

kilowatt-hour (kWh)-per-year values for all efficiency levels for these products. As mentioned in 

section 3.2.1.2, DOE proposes to separate all-refrigerators from product classes which currently 

combine all-refrigerators with other product types. It is argued that the new temperatures are 

more consistent with actual temperatures used by consumers use12,13 and that energy use 

measured using the new temperatures will also be more representative of actual field energy use. 

Chapter 5 describes DOE determination of new energy vs. adjusted volume curves for baselineefficiency products based on the new test procedure. 

3.2.2.8 Standby and Off Modes 

EISA requires DOE to include consideration of standby mode and off mode energy consumption 

in future amendments to both its test procedures and energy conservation standards. Specifically, 

3-7 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

section 310 of EISA amends section 325 of EPCA (42 U.S.C. 6295) by adding the following 

definitions and other requirements pertaining to standby and off mode energy use: 

(gg) STANDBY MODE ENERGY USE. 

(1) DEFINITIONS.— 

(A) IN GENERAL.—Unless the Secretary determines otherwise pursuant to 

subparagraph (B), in this subsection: 

(i) ACTIVE MODE.—The term "active mode" means the condition in 

which an energy-using product:— 

(I) is connected to a main power source; 

(II) has been activated; and 

(III) provides 1 or more main functions. 

(ii) OFF MODE.—The term "off mode" means the condition in which an 

energy-using product:— 

(I) is connected to a main power source; and 

(II) is not providing any standby or active mode function. 

(iii) STANDBY MODE.—The term "standby mode" means the 

condition in which an energy-using product:— 

(I) is connected to a main power source; and 

(II) offers 1 or more of the following user-oriented or protective 

functions: 

(aa) To facilitate the activation or deactivation of other 

functions (including active mode) by remote switch 

(including remote control), internal sensor, or timer. 

(bb) Continuous functions, including information or 

status displays (including clocks) or sensor-based 

functions. 

(B) AMENDED DEFINITIONS.—The Secretary may, by rule, amend the 

definitions under subparagraph (A), taking into consideration the most current 

versions of Standards 62301 and 62087 of the International Electrotechnical 

Commission (IEC). 

(2) TEST PROCEDURES.— 

(A) IN GENERAL.—Test procedures for all covered products shall be amended 

pursuant to section 323 to include standby mode and off mode energy 

consumption, taking into consideration the most current versions of Standards 

62301 and 62087 of the International Electrotechnical Commission, with such 

energy consumption integrated into the overall energy efficiency, energy 

consumption, or other energy descriptor for each covered product, unless the 

Secretary determines that:— 

(i) the current test procedures for a covered product already fully account 

for and incorporate the standby mode and off mode energy consumption 

of the covered product,; or 

(ii) such an integrated test procedure is technically infeasible for a 

particular covered product, in which case the Secretary shall prescribe a 

separate standby mode and off mode energy use test procedure for the 

covered product, if technically feasible. 

* * * * * 

(3) INCORPORATION INTO STANDARD.— 

3-8 

EERE-2008-BT-STD-0012 COMMENT 22
(A) IN GENERAL.—Subject to subparagraph (B), based on the test procedures 

required under paragraph (2), any final rule establishing or revising a standard for 

a covered product, adopted after July 1, 2010, shall incorporate standby mode 

and off mode energy use into a single amended or new standard, pursuant to 

subsection (o), if feasible. 

(B) SEPARATE STANDARDS.—If not feasible, the Secretary shall prescribe 

within the final rule a separate standard for standby mode and off mode energy 

consumption, if justified under subsection (o). 

For refrigerators, refrigerator-freezers, and freezers, the current test procedure captures standby 

and off mode energy use. All energy input for the test duration, including during times of 

compressor off cycle is measured, for a test time period which is at least 3 hours long. Hence, 

under provision (gg)(2)(A)(i), establishing standby and off modes and test procedures to 

incorporate them into the overall energy use is not required. Complications potentially arise for 

refrigerator features not mentioned by the test procedure that might involve some standby energy 

use during normal consumer use, but that might be disconnected or otherwise turned off during 

energy testing (e.g., a computer integrated with the refrigerator). 

3.2.3 Manufacturer Information 

This section provides information on domestic manufacturers of residential refrigerators, 

refrigerator-freezers, and freezers, including their brand names and products sold in the United 

States (section 3.2.3.1), estimated market shares (section 3.2.3.2), industry mergers and 

acquisitions (section 3.2.3.3), and product distribution channels (section 3.2.3.4). The section 

also discusses manufacturer trade groups (section 3.2.3.5) and manufacturers of compressors 

(section 3.2.3.6), as this is one of the most important components of residential refrigeration 

products. 

3.2.3.1 Refrigerator, Refrigerator-Freezer, and Freezer Manufacturers 

Table 3.2.2 lists refrigerator, refrigerator-freezer, and freezer manufacturers selling 

products in the United States. The second column indicates whether the manufacturer is a 

member of AHAM, and the third column indicates whether the manufacturer produces products 

that are ENERGY STAR compliant. Manufacturers that are a member of AHAM are listed first 

in the table and generally have the largest U.S. market shares. There are also several smaller 

manufacturers supplying products to the U.S. Those smaller manufacturers that produce 

ENERGY STAR-compliant products are listed directly after AHAM member manufacturers. 

Table 3.2.2 also indicates the types of products that each manufacturer produces. Product 

types include: standard-size refrigerator-freezers, freezers, compact units, built-in units, custom 

units, undercounter units, luxury units, and other types. Other types include: units with more than 

three doors, units for ‘compact kitchens’ other than compact refrigerators, refrigerated drawers, 

and commercial-size units. 

3-9 

EERE-2008-BT-STD-0012 COMMENT 22
Table 3.2.2 Refrigerator, Refrigerator-Freezer, and Freezer Manufacturers 

Manufacturer Name 

AHAM 

Member 

E* 

Products 

Std RefrigFreezer Freezer Com­ pact Built-In Custom Door/Inter. Under Counter 

Aga Foodservice Group* Y - - - - - - - 

 Marvel Industries - - Y Y - Y - Y 

Northland Corp. - - - Y - - Y - 

Bosch Home Appliances Corp. Y Y Y Y - - Y - 

Electrolux Home Products** Y Y - - - Y Y Y 

Frigidaire - Y Y Y - - - - 

Fisher & Paykel Appliances Inc. Y - Y - - - - - 

GE Appliances*** Y Y Y Y Y - - - 

Hotpoint - Y Y Y Y - - - 

 Monogram - Y Y Y - Y - - 

Haier Group Y Y Y - Y - - - 

LG Electronics Y Y Y - - - - - 

Liebherr Y Y Y - - Y - - 

Miele Appliances Inc Y Y Y Y - Y - - 

Samsung Electronics America Y Y Y - - - - - 

Sanyo North America Corp. Y Y Y Y Y - - Y Sub-Zero Freezer Company Y Y - Y - Y Y Y 

Viking Range Corporation Y Y - Y - Y Y - 

W. C. Wood Co. † Y Y Y Y Y - - - 

Vencold - - - Y - - - - 

Whirlpool†† Y Y Y - - - - - 

Amana Appliances - Y Y Y - - - - 

 Maytag - Y Y Y - - - - 

Estate Appliances - - Y - - - - - 

 Magic Chef & Ewave - - Y Y Y - - - 

Gladiator Garage Works - Y Y - - - - - 

Ikea - Y Y - - - - - 

Inglis Home Appliances - Y Y - - - - - 

 Jenn-Air - Y Y - - Y Y - 

Kitchen Aid - Y Y - - Y - Y 

 Roper Appliances - - Y - - - - - 

Absocold Corporation - Y Y - Y - - Y 

Avanti Products ††† - Y Y Y Y - - Y 

Crosley Corporation - Y Y Y - - - - 

Daewoo Electronics Co. - Y - - Y - - - 

Danby Products Inc. - Y Y Y Y Y - - 

Diversified Refrigeration Inc. - Y - - - - - - 

3-10 

EERE-2008-BT-STD-0012 COMMENT 22
Manufacturer Name 

AHAM 

Member 

E* 

Products 

Std RefrigFreezer Freezer Com­ pact Built-In Custom Door/Inter. Under Counter 

Equator Appliances - Y Y Y Y - - - 

Galaxy Mfg. Company of C.N.Y. - Y NA NA NA NA NA NA 

Gorenje USA, Inc. - Y NA NA NA NA NA NA 

Jetson TV & Appliance Centers - Y Y Y Y Y - Y 

MicroFridge - Y - - Y - - - 

Organizacion Mabe # - Y Y - Y - - - 

 Camco Inc. - Y Y Y Y - - - 

 Moffat - Y Y - - - - - 

Petters Consumer Brands LLC - Y NA NA NA NA NA NA 

Summit Appliances - Y Y Y Y - - Y 

Sun Frost - Y - - - - - - 

U-Line Corporation - Y - Y Y - - Y 

Ultra 8 International LLC - Y - - - - - - 

ACME Kitchenettes Corp. - - - - Y - - - 

Atlas Eléctrica## - - NA NA NA NA NA NA 

Bauer Appliances - - Y Y - - - - 

Broich Enterprises ††† - Y Y Y - - - - 

Distinctive Appliances ††† - Y - - - Y Y - 

Euroquip S.A.de C.V. - - - - - - - - Jade - - Y - - - - - Indesit Company### - - Y - - - - Y 

Scottsman - - Y - - - - - 

Sunbeam^ - - Y - Y - - - 

Thermador - Y Y Y - - Y - 

WiniaMando Inc. - - - - - - - - 

Kenmore^^ - Y Y Y Y - - - 

Mastercool^^ - - NA NA NA NA NA NA 

United Refrigeration Inc. ^^^ - - - Y - - - Y 

* Owns Marvel Industries and Northland Corp. ** Includes Frigidaire and White Westinghouse brands. *** Includes Hotpoint and Monogram brands. †	 Includes Vencold brand. †† Includes the following brands: Amana Appliances, Maytag, Estate Appliances, Magic Chef & Ewave, 

Gladiator Garage Works, Ikea, Inglis Home Appliances, Jenn-Air, Kitchen Aid, Roper Appliances. 

# 48 percent owned by GE. Includes Moffat brand. Owns Camco Inc. ## 20 percent owned by Electrolux. 

### Includes Aritson brand. ^ An affiliate of Petters Group Worldwide, LLC. 

^^ Brand names that are produced by more than o

^^^ Could be a distributor or brand name under ano

oo SS=Stainless Steel; BI=Built-In; CDD=Custom

SI=Size; CB=Convertible; PI=Price 

′′	 Units included: units with more than three door

refrigerated drawers; commercial-size units 

3-11 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

3.2.3.2	 Refrigerator, Refrigerator-Freezer, and Freezer Manufacturer Market 

Shares 

Appliance magazine provides market share data for the most significant manufacturers 

(i.e., manufacturers with the greatest sales) for the following four product types: (1) standard-size 

refrigerators and refrigerator-freezers, (2) compact refrigerators, (3) built-in/undercounter 

refrigerators, and (4) freezers.14 Table 3.2.3 through Table 3.2.6 show how market shares have 

changed over at least a ten-year period. Market shares among the largest manufacturers of 

standard-size refrigerator-freezers have remained relatively stable. Whirlpool Corporation 

(Whirlpool)’s 2006 acquisition of Maytag Corporation (Maytag) (discussed below) now gives 

Whirlpool the largest U.S. market share. Also, Haier America Trading, LLC (Haier), a relatively 

recent entrant to the market, captured three percent of the market in 2006. 

Table 3.2.3 Standard-Size Refrigerator-Freezer Manufacturer Market Shares 

Company 

Market Share 

2007 2006 2005 2004 2002 2000 1995 

GE 29% 29% 29% 29% 36% 34% 35% 

Electrolux 25% 25% 25% 25% 26% 21% 17% 

Whirlpool 25% 25% 25% 25% 23% 24% 27%

 Maytag 10% 10% 11% 11% 13% 14% 10%

 Goodman/Raytheon

 (Amana) 

NA 0% 0% 0% 0% 5% 10% 

Haier 4% 3% 2% 2% 2% 0% 0% 

W.C. Wood 1% 1% 1% 0% 0% 0% 0% 

Other 6% 7% 7% 8% 0% 2% 1% 

Source: Appliance magazine 

The market for compact refrigerators has seen a dramatic shift since 1993 (Table 3.2.4). 

SANYO North America Corporation (Sanyo) had the largest market share by far in 1993, but 

now accounts for only seven percent of the market. Haier now has the largest compact 

refrigerator market share, followed by the joint venture between GE and Mexican appliance 

company Grupo P.I. Mabe S.A. (Mabe). 

3-12 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

Table 3.2.4 Compact Refrigerator Manufacturer Market Shares 

Company 

Market Share 

2007 2006 2005 2004 2002 1997 1993 

Haier 22% 21% 20.1% 20% NA 15% 0% 

GE/Mabe 16% 16% 16.7% 17% NA 18% 17% 

Sanyo 7% 7% 7.3% 8% NA 58% 61% 

U-Line 5% 5% 4.8% 0% NA 0% 0% 

Danby 3% 3% 2.9% 3% NA 0% 0% 

Avanti 1% 2% 2.5% 0% NA 0% 0% 

Whirlpool/Consul 1% 2% 1.9% 0% NA 2% 2% 

Marvel 2% 2% 1.6% 0% NA 0% 0% 

Wanbao NA 0% 0% 0% NA 5% 12% 

Others 43% 42% 42.2% 52% NA 2% 8% 

Source: Appliance magazine 

The reported market for built-in undercounter units has remained relatively stable over 

the past ten years (Table 3.2.5). The data show that U-Line Corporation (U-Line) has the greatest 

market share. Note that this market share distribution does not include full-size built-in products. 

Table 3.2.5 Built-In Undercounter Refrigerator Manufacturer Market Shares 

Company 

Market Share 

2007 2006 2005 2004 2002 2000 1995* 

U-Line 69% 70% 69% 67% 65% 75% 58% 

Marvel 21% 21% 21% 22% 25% 14% 27% 

Sub-Zero 6% 6% 6% 7% 6% 10% 12% 

Others 4% 3% 4% 4% 4% 1% 3% 

Source: Appliance magazine; * 1995 data includes compact refrigerators. 

Market share data for full-size built-in refrigerators and refrigerator-freezers is not 

publicly available. Key manufacturers in this product category include Sub-Zero, General 

Electric’s Monagram line, Whirlpool’s Kitchenaid line, Viking, and Northland. Manufacturers 

providing imported products for this market include Liebherr, Bosch, and Miele. AHAM has 

recently begun collecting shipment data on built-in products. The percentage of overall 

shipments represented by built-in products has fluctuated between 2005 and 2007 between 1.6% 

and 2.2%. This includes both full-size and compact (undercounter) built-in products. This data 

was provided by AHAM as part of the pre-NOPR phase of this rulemaking. 

For chest and upright freezers, Electrolux has retained the largest market share for ten 

years (Table 3.2.6). Haier, which was not in the market in 1995, now captures 13 percent of the 

market. 

3-13 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 3.2.6 Chest/Upright Freezer Manufacturer Market Shares 

Company 

Market Share 

2007 2006 2005 2004 2002 2000 1995 

Electrolux 

(Frigidaire) 

66% 66% 67% 68% 68% 69% 67% 

W.C. Wood 20% 21% 21% 22% 21% 27% 30% 

Haier 13% 12% 11% 9% 9% 3% 0% 

Sanyo 1% 1% 1% 1% 2% 1% 1% 

Whirlpool NA 0% 0% 0% 0% 0% 1% 

Others NA 0% 0% 0% 0% 0% 1% 

Source: Appliance magazine 

3.2.3.3 Mergers and Acquisitions 

The appliance manufacturing industry has had a continuous history of consolidation. 

Maytag acquired Jenn-Air Corporation (Jenn-Air) in 1982, Magic Chef, Inc. (Magic Chef) in 

1986, and Amana Appliances (Amana) in 2001. Whirlpool acquired the KitchenAid division of 

Hobart Corporation (KitchenAid) in 1986. White Consolidated Industries (WCI) acquired 

Frigidaire in 1979, and AB Electrolux acquired WCI (including Frigidaire) in 1986. 

Mergers and acquisitions have two purposes. First, they produce large corporations with 

the financial resources and stability to be successful in a competitive market. Second, mergers 

and acquisitions mean manufacturers can have a complete line of home appliances. This product 

diversification allows firms to offer a complete set of appliances to consumers, an important 

feature in the builder market. There is also increasing worldwide competition in the major 

appliance market, so mergers and acquisitions are likely to continue. 

On August 22, 2005, Whirlpool and Maytag announced plans to merge in a deal worth 

$2.7 billion.15 Maytag shareholders approved the merger on December 22, 2005. The U.S. 

Department of Justice (DOJ) Antitrust Division initiated an investigation into the effects of the 

merger, including potential lessening of competition or the creation of a monopoly. Opponents of 

the merger asserted that the combined companies would control as much as 70 percent of the 

residential laundry market and as much as 50 percent of the residential dishwasher market.16 

Whirlpool claimed that its large potential residential laundry market share was skewed because 

the company produces washing machines for Sears, which sells them under its Kenmore inhouse brand. Whirlpool further stated that it must periodically bid with other manufacturers to 

keep the Kenmore contract and that Sears controls the pricing of the Kenmore units.17 

In early January 2006, U.S. Senator Tom Harkin and U.S. Representative Leonard 

Boswell called on the DOJ to block the merger, claiming it would give Whirlpool an unfair 

advantage in the home appliance industry. On March 29, 2006, DOJ closed its investigation and 

approved the merger. DOJ stated that “the proposed transaction is not likely to reduce 

competition substantially. The combination of strong rival suppliers with the ability to expand 

sales significantly and large cost savings and other efficiencies that Whirlpool appears likely to 

achieve indicates that this transaction is not likely to harm consumer welfare.”18 

3-14 

EERE-2008-BT-STD-0012 COMMENT 22
 

The DOJ Antitrust Division focused its investigation on residential laundry, although it 

considered impacts across all products offered by the two companies. DOJ determined that the 

merger would not give Whirlpool market power in the sale of its products and that any attempt to 

raise prices would likely be unsuccessful. To support this claim, DOJ provided reasons 

including: (1) other U.S. brands, including Kenmore, GE, and Frigidaire, are well established; 

(2) foreign manufacturers, including LG and Samsung, are gaining market share; (3) existing 

U.S. manufacturers are below production capacity; (4) the large home appliance retailers have 

alternatives available to resist price increase attempts; and (5) Whirlpool and Maytag 

substantiated large cost savings and other efficiencies to benefit consumers.18 

Whirlpool and Maytag completed the merger on March 31, 2006. 

3.2.3.4 Distribution Channels 

Most residential refrigerators and freezers move directly from manufacturers to retail 

outlets. Table 3.2.7 identifies the types of retail stores through which major appliances, including 

refrigerators and freezers, are sold based on data from AHAM 2005 Fact Book.

19 

Table 3.2.7 Major Appliance Sales by Channel 

Type of Store Percentage of Appliance Purchases 

Department Store (such as Sears or Kohls) 34.7% 

Appliance Store or Consumer Electronics Store 30.9% 

Home Improvement Store (such as Lowe’s or Home Depot) 23.8% 

Discount Store (such as Wal-Mart or K-Mart) 2.0% 

Membership Warehouse Club/Store (such as Sam’s or Costco) 1.8% 

Another type of store 6.8% 

Source: AHAM Fact Book 

A certain share of shipments is purchased through channels other than retail outlets, e.g., 

by multi-family home builders for installation in new homes. The Consortium for Energy 

Efficiency (CEE) estimates that 20 to 30 percent of home appliance sales are commercial sales, 

i.e., sales to single/multi-family builders, contractors, government, public housing, and multifamily property managers.20 Because single-family builders typically do not include refrigeratorfreezers as part of a home sale, the 20 to 30 percent estimate by CEE is probably too high for the 

refrigerator market. 

3.2.3.5 Manufacturer Trade Groups 

AHAM is the primary manufacturer trade group representing most manufactures of 

refrigerators, refrigerator-freezers, and freezers. AHAM provides services to its members 

including government relations; certification programs for room air conditioners, dehumidifiers, 

and room air cleaners; an active communications program; and technical services and research. 

In addition, AHAM conducts other market and consumer research studies and publishes a 

biennial Major Appliance Fact Book. AHAM also develops and maintains technical test 

procedures for various appliances to provide uniform, repeatable procedures for measuring 

specific product characteristics and performance features. 

3-15 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

3.2.3.6 Compressor Manufacturers and Market Shares 

Because the compressor is a key energy-using component of refrigerators, it is important 

to determine which compressor manufacturers are supplying the U.S. refrigerator market. 

According to three sources, Embraco is the compressor manufacturer with the largest global 

market share, although several other manufacturers have significant global market share as 

well.21, 22 For the U.S. refrigerator market, based on data from Embraco, it has by far the largest 

market share.23 Besides Embraco, there are five other major compressor manufacturers supplying 

the world refrigerator and freezer market: Appliances Components Companies (ACC), 

Tecumseh Compressor Company (Tecumseh), Danfoss Compressors GmbH, Matsushita Electric 

Industrial Co., Ltd. (Matsushita), and LG Electronics, Inc. (LG). Table 3.2.8 lists the compressor 

manufacturers and their estimated global and U.S. market shares. 

Table 3.2.8 Compressor Manufacturers and World and U.S. Market Shares 

Manufacturer 

World Market Share U.S. Market Share 

2005* Year not specified** 2006*** 2001† 

Embraco 19.5% ~23% 25% 56% 

ACC 15.0% ~20% NA NA 

Tecumseh 13.5% ~8% NA NA 

Matsushita 12.9% ~9% 18% NA 

LG 10.8% ~8% NA NA 

Danfoss 8.9% ~9% 15% <1% 

Others 19.4% ~23% NA NA 

Sources: *Universidade Federal de Santa Catarina, 2006; **Institute for Materials Science, Welding and 

Forming; ***Unable to cite source; †

Embraco, 2001. 

3.2.4	 Regulatory Programs 

The following section details current regulatory programs mandating energy conservation 

standards for refrigerator/freezers. It covers U.S. Federal energy conservation standards, State 

standards, standards in Canada and Mexico (which may impact the companies servicing the 

North American market), and international standards. 

3.2.4.1 Federal Energy Conservation Standards 

The National Appliance Energy Conservation Act of 1987 (NAECA) (42 U.S.C. 6291– 

6309) established efficiency standards for refrigerators and refrigerator-freezers with a total 

refrigerated volume of less than 1104 L (39 ft3

) and for freezers with a total refrigerated volume 

of less than 850 L (30 ft3

). Compact refrigerators and freezers represent separate product classes 

and have a volume less than 220 L (7.75 ft3) and a height of 0.91 meters (36 inches) or less. The 

minimum efficiency levels depend on product class and adjusted volume. The adjusted volume is 

equal to the fresh food internal volume plus an adjustment factor which depends on the product 

type times the freezer internal volume. The adjustment factor is 1.63 for refrigerator-freezers, 

1.44 for refrigerators with freezer compartments, 1.00 for all-refrigerators (which may have a 

freezer compartment with less than 0.5 ft3 volume), and 1.73 for freezers. Maximum annual 

energy use is expressed as kilowatt-hours (kWh) per year (yr) 

3-16 

EERE-2008-BT-STD-0012 COMMENT 22
NAECA initially established energy conservation standards for refrigerator-freezers that 

became effective in 1990. DOE amended NAECA with new standards that went into effect in 

1993, followed by the current amended standards that became effective in July 2001. 

Refrigerator-freezers manufactured to meet the 2001 standard typically consume about 30 

percent less energy than required under the 1993 efficiency regulations. The 1993 and 2001 

standards are summarized in Table 3.2.9 below. 

As discussed in section 3.2.1, there are two additional product classes that DOE proposes 

to establish due to exemptions it granted in recent years for products not adhering to existing 

product class definitions: (1) automatic defrost refrigerator-freezers with bottom-mounted freezer 

and TTD ice service, and (2) automatic defrost chest freezers. These proposed product classes 

are listed as 5A and 10A in Table 3.2.9. 

3-17 

EERE-2008-BT-STD-0012 COMMENT 22
Table 3.2.9 Federal Energy Efficiency Standards for Refrigerators, Refrigerator-Freezers, 

and Freezers 

Product Class 

Energy Standard Equations for 

Maximum Energy Use (kWh/yr) 

Effective 

January 1, 1993 

Effective 

July 1, 2001 

1. Refrigerators and refrigerator-freezers with manual defrost. 13.5AV+299 

0.48av+299 

8.82AV+248.4 

0.31av+248.4 

2. Refrigerator-freezer—partial automatic defrost. 10.4AV+398 

0.37av+398 

8.82AV+248.4 

0.31av+248.4 

3. Refrigerator-freezer—automatic defrost with top-mounted 

freezer without through-the-door ice service and allrefrigerator—automatic defrost. 

16.0AV+355 

0.57av+355 

9.80AV+276.0 

0.35av+276.0 

4. Refrigerator-freezers—automatic defrost with side-mounted 

freezer without through-the-door ice service. 

11.8AV+501 

0.42av+501 

4.91AV+507.5 

0.17av+507.5 

5. Refrigerator-freezers—automatic defrost with bottom-mounted 

freezer without through-the-door ice service. 

16.5AV+367 

0.58av+367 

4.60AV+459.0 

0.16av+459.0 

6. Refrigerator-freezers—automatic defrost with top-mounted 

freezer with through-the-door ice service. 

17.6AV+391 

0.62av+391 

10.20AV+356.0 

0.36av+356.0 

7. Refrigerator-freezers—automatic defrost with side-mounted 

freezer with through-the-door ice service. 

16.3AV+527 

0.58av+527 

10.10AV+406.0 

0.36av+406.0 

8. Upright freezers with manual defrost. 10.3AV+264 

0.36av+264 

7.55AV+258.3 

0.27av+258.3 

9. Upright freezers with automatic defrost. 14.9AV+391 

0.53av+391 

12.43AV+326.1 

0.44av+326.1 

10. Chest freezers and all other freezers except compact freezers. 11.0AV+160 

0.39av+160 

9.88AV+143.7 

0.35av+143.7 

11. Compact refrigerators and refrigerator-freezers with manual 

defrost. 

13.5AV+299* 

0.48av+299* 

10.70AV+299.0 

0.38av+299.0 

12. Compact refrigerator-freezer—partial automatic defrost. 10.4AV+398* 

0.37av+398* 

7.00AV+398.0 

0.25av+398.0 

13. Compact refrigerator-freezers—automatic defrost with topmounted freezer and compact all-refrigerator—automatic defrost. 16.0AV+355* 

0.57av+355* 

12.70AV+355.0 

0.45av+355.0 

14. Compact refrigerator-freezers—automatic defrost with sidemounted freezer. 11.8AV+501* 

0.42**+501* 

7.60AV+501.0 

0.27av+501.0 

15. Compact refrigerator-freezers—automatic defrost with bottommounted freezer. 16.5AV+367* 

0.58av+367* 

13.10AV+367.0 

0.46av+367.0 

16. Compact upright freezers with manual defrost. 10.3AV+264* 

0.36av+264* 

9.78AV+250.8 

0.35av+250.8 

17. Compact upright freezers with automatic defrost. 14.9AV+391* 

0.53av+391* 

11.40AV+391.0 

0.40av+391.0 

18. Compact chest freezers. 11.0AV+160* 

0.39av+160* 

10.45AV+152.0 

0.37av+152.0 

5A. Refrigerator-freezer—automatic defrost with bottom-mounted 

freezer with through-the-door ice service. NA 5.0AV+539.0 

0.18av+539.0 

10A. Chest freezers with automatic defrost. NA 14.76AV+211.5 

0.52av+211.5 

AV:	 Adjusted Volume in ft3; av: Adjusted Volume in L 

* Applicable standards for compact refrigerator products manufactured before July 1, 2001. Compact refrigerator 

products are not separate product categories under the standards effective January 1, 1993. 

3-18 

EERE-2008-BT-STD-0012 COMMENT 22
The Energy Independence and Security Act of 2007 (EISA) (P.L. 110-140), requires that 

DOE publish a final rule no later than December 31, 2010 to determine whether to amend the 

standards in effect for refrigerators, refrigerator-freezers, and freezers manufactured on or after 

January 1, 2014. 

3.2.4.2 State Energy Conservation Standards 

As part of its Title 20 Appliance Efficiency Regulations, the California Energy 

Commission (CEC) has established standards for consumer refrigeration products that are not 

covered by Federal standards. CEC set standards for wine chillers (Table 3.2.10) and freezers 

that have a total refrigerated volume greater than 850 L (30 ft3) (Table 3.2.11).24 The standards 

for freezers with volume greater than 30 ft3 are numerically identical to the federal standards for 

smaller freezers—the California standards simply extend the federal standards beyond the 

federal size limitation. 

Table 3.2.10 California Standards for Wine Chillers 

Appliance Maximum Annual Energy Consumption 

(kWh) 

Wine chillers with manual defrost 13.7V + 267 

Wine chillers with automatic defrost 17.4V + 344 

V = volume in ft3

. 

Table 3.2.11 California Standards for Freezers with Volume Greater than 30 cubic feet 

Appliance 

Upright Freezers with manual defrost 

Maximum Annual Energy Consumption 

(kWh) 

7.55AV + 258.3 

Upright Freezers with automatic defrost 12.43AV + 326.1 

Chest Freezers 9.88AV + 143.7 

AV = adjusted total volume, expressed in ft3, which is 1.73 times freezer volume (in ft3). 

3.2.4.3 Canadian Energy Conservation Standards 

Refrigerators and freezers are regulated products in Canada under the Canadian Energy 

Efficiency Regulations. The regulations reference Canadian Standards Association (CSA) 

CAN/CSA-C300-00, Energy Performance and Capacity of Household Refrigerators, 

Refrigerator-Freezers, and Freezers, for the testing procedure and for maximum annual energy 

consumption (MAEC) limits for residential refrigerators, refrigerator-freezers, and freezers. The 

product classes and MAEC limits in the Canadian regulations are the same as in the U.S. Federal 

standards. 

In November 2006, Canada added two new product types to its Regulations (Amendment 

9) to harmonize with recent U.S. rulings with respect to these products.25 These product types are 

refrigerator-freezers with automatic defrost and with a bottom-mounted freezer with TTD ice 

service and chest freezers with automatic defrost system. The maximum energy use regulations, 

3-19 

EERE-2008-BT-STD-0012 COMMENT 22
 

listed in Table 3.2.12 below, are identical to the energy standards that DOE’s Office of Hearings 

and Appeals assigned to these classes. 

Table 3.2.12 Canadian Energy Standards for Added Refrigerator and Freezer Product 

Classes 

Appliance Maximum Annual Energy Consumption 

(kWh) 

Product Class 5A: refrigerator-freezers with 

automatic defrost and with bottom-mounted 

freezers with TTD ice service 

0.18av+539 

Product Class 10A: chest freezers with 

automatic defrost system 

0.52av + 211.5 

av = adjusted volume in liters 

Natural Resources Canada (NRCan)’s Office of Energy Efficiency (OEE) amended 

Canada's Energy Efficiency Regulations to add energy performance standards for residential 

wine chillers (or wine coolers).26 The proposed standard includes a test procedure and minimum 

energy performance standard levels for wine chillers harmonized with those in effect in 

California. Table 3.2.13 below shows the maximum annual energy consumption limits (in kWh) 

for residential wine chillers. 

Table 3.2.13 Canadian Standards for Wine Chillers 

Appliance Maximum Annual Energy Consumption 

(kWh) 

Wine chillers with manual defrost 0.48av + 267 

Wine chillers with automatic defrost 0.61av + 344 

av = adjusted volume in L. 

3.2.4.4 Mexican Energy Conservation Standards 

The Mexican Official Standard establishes the maximum energy consumption limits for 

household refrigerators and freezers using hermetic motor-driven compressors, specifies the test 

methods for determining such energy consumption and the total refrigerated volume, and 

provides energy consumption label requirements. This standard applies to household 

refrigerators up to 1,104 cubic decimeters (39 ft3) and household freezers of up to 850 cubic 

decimeters (30 ft3

) using hermetic motor-driven compressors.27 The new standard levels (NOM015-ENER-2002) became effective in May 2003. 

3.2.4.5 Efficiency Standards Outside North America 

According to the Collaborative Labeling and Appliance Standards Program (CLASP) 

database, all 15 original European Union (EU) member countries, plus 16 other countries outside 

North America, have mandatory energy efficiency standards for refrigerator-freezers.28 The 

countries other than the original EU member countries are: Algeria, Australia, Bahrain, Chile, 

China, Chinese Taipei, Costa Rica, Hungary, Indonesia, Iran, Israel, New Zealand, Philippines, 

Republic of Korea, Thailand, and Viet Nam. 

3-20 

EERE-2008-BT-STD-0012 COMMENT 22
 

In 2005, the European Parliament adopted a Commission proposal for a directive on 

establishing a framework for setting eco-design requirements (such as energy efficiency 

requirements) for all energy-using products in the residential, tertiary (services), and industrial 

sectors.29 EU-wide rules for eco-design are intended to ensure that disparities among national 

regulations do not become obstacles to intra-EU trade. The directive does not directly introduce 

binding requirements for specific products, but does define conditions and criteria for setting 

requirements regarding environmentally relevant product characteristics (such as energy 

consumption), and allows these requirements to be improved quickly and efficiently. The 

directive will be followed by implementing measures that will establish the eco-design 

requirements. 

It is difficult to compare the standards in other countries with those in the U.S. due to 

differences in test procedures. The development of an international test procedure under the 

auspices of the International Electrotechnical Commission has international test procedure 

harmonization as a key objective. Establishment of Standard IEC 62552, which is currently 

under development, should make it easier in future to compare international refrigeration product 

energy standard levels. 

3.2.5 Voluntary and other Federal and State Programs 

In addition to mandatory standards, there are voluntary programs—e.g., the Federal 

Energy Management Program (FEMP) and CEE—as well as other Federal and State policies that 

affect the efficiency of new refrigerators and freezers. 

3.2.5.1 ENERGY STAR 

Historical ENERGY STAR Requirements 

 ENERGY STAR is a voluntary program administered by the U.S. government to 

promote energy efficient consumer products. Table 3.2.14 below shows the history of ENERGY 

STAR energy use criteria for each of the three covered product categories. 

3-21 

EERE-2008-BT-STD-0012 COMMENT 22
Table 3.2.14 History of ENERGY STAR Energy Use Criteria for Residential Refrigerators 

and Freezers 

1997 2001 2003 2004 2008 

Initial Revision #1 Addition of Revision #2 Revision #3 

Criteria Freezers 

and 

Compacts 

Standard-size 

Refrigerators & 

RefrigeratorFreezers 

20% below 

1993 Federal 

Standard 

10% below 

2001 Federal 

Standard 

10% below 

2001 Federal 

Standard 

15% below 

2001 Federal 

Standard 

20% below 

2001 Federal 

Standard 

Standard-size 10% below 10% below 10% below 

Freezers -------- -------- 2001 Federal 2001 Federal 2001 Federal 

Standard Standard Standard 

Compact 20% below 20% below 20% below 

Refrigerators & -------- -------- 2001 Federal 2001 Federal 2001 Federal 

Freezers Standard Standard Standard 

As of 2006, the market share of ENERGY STAR-compliant full-size refrigerators and 

refrigerator-freezers was just under 30%.30 Within this category, approximately 20 percent of 

top- and bottom-mount and 50 percent of side-mount refrigerator-freezer units sold in the U.S. 

were ENERGY STAR compliant. Some States (i.e., Massachusetts, Michigan) have waived state 

sales tax for purchase of appliances that meet ENERGY STAR levels. 

New ENERGY STAR requirements effective in 2008 

The current ENERGY STAR criteria, drafted with input from stakeholders and two 

rounds of public comments, went into effect on April 28, 2008. To support the change, 

ENERGY STAR released a market analysis30 and a final report on proposed program 

requirements.31 Table 3.2.15 shows the number of models that met the current Federal standard 

for refrigerators and available models with efficiencies 15 percent, 20 percent, and 25 percent 

higher than the Federal standard, as of April 2007 (prior to the 2008 revision). ENERGY STAR 

program staff deemed the number of models offered to consumers at the higher efficiencies to be 

sufficient to warrant changing the labeling criteria. 

3-22
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 3.2.15 Efficiency of Standard Refrigerators and Refrigerator-Freezers on the Market 

Relative to Current Federal Standard 

Efficiency Level Number of Available Models 

(prior to 2008 criteria revision) 

Percent of Available Models 

(prior to 2008 criteria revision) 

Current Federal Standard 

(effective July 2001) 2,524 100% 

2004 ENERGY STAR Criteria 

(15% better than Federal 

Standard) 

1,441 57% 

2008 ENERGY STAR Criteria 

(20% better than Federal 

Standard) 

121 4.8% 

25% better than Federal Standard 14 0.6% 

Source: ENERGY STAR, April 27, 200730 

3.2.5.2 Federal Energy Management Program 

 DOE’s FEMPa

 works to reduce the cost and environmental impact of the Federal 

government by advancing energy efficiency and water conservation, promoting the use of 

distributed and renewable energy, and improving utility management decisions at Federal sites. 

FEMP helps Federal buyers identify and purchase energy-efficient equipment, including 

residential refrigerators and freezers. 

Federal agencies are required by the Energy Policy Act of 2005 (EPACT 2005, P.L. 109­

58) and Federal Acquisition Regulations (FAR) Subpart 23.2 to specify and buy ENERGY 

STAR-qualified products or, in categories with no ENERGY STAR label, FEMP-designated 

products which are among the highest 25 percent of equivalent products for energy efficiency. 

Table 3.2.16 below shows refrigerator and freezer performance requirements for Federal 

purchases. 

a

 For more information, please visit www.eere.energy.gov/femp. 

3-23 

EERE-2008-BT-STD-0012 COMMENT 22
Table 3.2.16 Performance Requirement for Federal Purchases of Refrigerators and 

Freezers 

Product Class 

Total Volume* 

(ft3

) 

Product Class 

Number(s)*** Annual Energy Use** 

Single–Door Manual Defrost <2.4 11 255 kWh/year or less 

Single–Door Manual Defrost 2.5 to 4.4 11 275 kWh/year or less 

Single–Door Manual Defrost 4.5 to 6.4 11 295 kWh/year or less 

Single–Door Manual Defrost >6.5 1 or 11 315 kWh/year or less 

Single–Door Automatic Defrost <2.4 13 305 kWh/year or less 

Single–Door Automatic Defrost 2.5 to 4.4 13 325 kWh/year or less 

Single–Door Automatic Defrost 4.5 to 6.4 13 345 kWh/year or less 

Single–Door Automatic Defrost >6.5 3 or 13 365 kWh/year or less 

Bottom–Mount Freezer <18.4 5, 5A, or 15 475 kWh/year or less 

Bottom–Mount Freezer 18.5 to 20.4 5 or 5A 485 kWh/year or less 

Bottom–Mount Freezer >20.4 5 or 5A 495 kWh/year or less 

Top–Mount Freezer <10.4 3, 6, or 13 340 kWh/year or less 

Top–Mount Freezer 10.5 to 12.4 3 or 6 360 kWh/year or less 

Top–Mount Freezer 12.5 to 14.4 3 or 6 380 kWh/year or less 

Top–Mount Freezer 14.5 to 16.4 3 or 6 400 kWh/year or less 

Top–Mount Freezer 16.5 to 18.4 3 or 6 420 kWh/year or less 

Top–Mount Freezer 18.5 to 20.4 3 or 6 440 kWh/year or less 

Top–Mount Freezer 20.5 to 22.4 3 or 6 460 kWh/year or less 

Top–Mount Freezer 22.5 to 24.4 3 or 6 480 kWh/year or less 

Top–Mount Freezer >24.5 3 or 6 500 kWh/year or less 

Side-mount Freezer <20.4 4, 7, or 14 560 kWh/year or less 

Side-mount Freezer 20.5 to 22.4 4 or 7 580 kWh/year or less 

Side-mount Freezer 22.5 to 24.4 4 or 7 600 kWh/year or less 

Side-mount Freezer >25.5 4 or 7 620 kWh/year or less 

* Total volume is the sum of the refrigerator and freezer volumes.
 

** Annual Energy Use is based on DOE test procedure (10 CFR 430, Sub-Part B, Appendix E). 

*** Possible Product Class numbers based on Product Class Descriptions 

3.2.5.3 Consortium for Energy Efficiency 

The Consortium for Energy Efficiency (CEE) is a nonprofit corporation that promotes the 

manufacture and purchase of energy-efficient products and services. CEE promotes energyefficient refrigerators that use significantly less electricity than the Federal standard. These 

energy-efficient refrigerators represent the upper end of the ENERGY STAR efficiency levels. 

Effective January 1, 2007, CEE identifies three tiers for “super-efficient” refrigerators and 

refrigerator-freezers. Table 3.2.17 below provides the specifications for the CEE. 

3-24 

EERE-2008-BT-STD-0012 COMMENT 22
Table 3.2.17 CEE Tier Levels Refrigerators and Refrigerator-Freezers 

Efficiency level Percent Energy Use below Federal Standard 

Standard Refrigerators Compact Refrigerators 

CEE Tier 1 (Current 

ENERGY STAR) 20 20 

CEE Tier 2 25 25 

CEE Tier 3 30 30 

3.2.5.4 ENERGY STAR, FEMP, CEE Summary 

Table 3.2.18 below presents maximum unit energy consumption (UEC) values for the 

current Federal standard and the ENERGY STAR and CEE voluntary standards for (1) a topmount refrigerator-freezer with automatic defrost with no TTD ice features and 21.4 ft3

 adjusted 

volume, and (2) a side-mount refrigerator freezer with TTD features and 26.2 ft3 adjusted 

volume. 

Table 3.2.18 Annual Energy Consumption for Refrigerator-Freezers with Different 

Specifications 

Efficiency Level Top Mount* Side-Mount** 

2001 Federal Standard 486 671 

Former ENERGY STAR (15% below standard) 413 570 

CEE Tier 1, current ENERGY STAR (20% below standard) 389 537 

CEE Tier 2 (25% below standard) 364 503 

CEE Tier 3 (30% below standard) 340 469 

* Auto defrost, no TTD features, 18.2 ft3 total volume, and 21.4 ft3 adjusted volume. 

** Auto defrost, TTD features, 21.7 ft3 total volume, and 26.2 ft3

 adjusted volume. 

Source: DOE FY-2005 Priority Setting TSD; based on ENERGY STAR (2004),32 FEMP (2005)33 CEE (2004)34
 

3.2.5.5 Manufacturer Tax Credits for Energy-Efficient Appliances 

EPACT 2005 provided tax credits to manufacturers for the production of energy-efficient 

residential refrigerators. These credits were intended to help manufacturers meet the costs of 

producing appliances that exceed the Federal standards. The credit program was modified by the 

Emergency Economic Stabilization Act of 2008 (EESA 2008) and extended through 2010.35 The 

credit for residential refrigerators is a per-product credit (see Table 3.2.19). 

3-25
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 3.2.19 Manufacturer Tax Credits for Energy-Efficient Appliances in EESA 2008 

Savings relative to 2001 Federal 

Standard Applicable Credit Amount Applicable Years 

20% to 22.9% $50 2008 

23% to 24.9% $75 2008, 2009 

25% to 29.9% $100 

30% or more $200 2008, 2009, 2010 

Notes: ‘Refrigerators’ refers to residential automatic defrost refrigerator-freezers with an internal volume of at 

least 16.5 ft3

. 

3.2.5.6 Rebates for Highly Energy-Efficient Products 

Electric utilities and other organizations promote the purchase of highly energy-efficient 

refrigerators through consumer rebates. Typically, these programs offer rebates for products 

meeting existing ENERGY STAR efficiency levels. Table 3.2.20 below lists some rebates that 

were offered in 2006. Some utilities also offer incentives to retire old and inefficient appliances. 

Many utilities also offer rebates and disposal services for recycling old units in order to 

encourage consumers to purchase new, more efficient units and to ensure the safe disposal of 

hazardous waste. 

Table 3.2.20 Rebates Offered for Highly Energy-Efficient Refrigerators in 2006 

Utility/Organization* Rebate Level 

Efficiency Vermont $25 ( ENERGY STAR), $40 (CEE Tier 2 & 3) 

Los Angeles Dept. of Water and Power $65 

PacifiCorp $20 

Sacramento Municipal Utility District $50 

San Diego Gas and Electric $50 

Southern California Edison Unspecified (while supplies last) 

* The table includes those programs listed as providing rebates for ENERGY STAR refrigerators in the 

publication “Residential Appliance Programs National Summary,” by CEE, September 2006. Additional programs 

may exist. 

3.2.5.7 State Tax Incentives for Highly Energy-Efficient Products 

According to the State Energy Efficiency Index compiled by the Alliance to Save Energy, 

Oregon is the only State that offers tax credits for premium-efficiency refrigerators.36 The tax 

credit is based on the amount of energy saved above models that meet the Federal standard. 

3.2.6 Historical Shipments and Efficiencies 

3.2.6.1 Historical Shipments 

Two public sources of information provide historical shipments data on residential 

refrigerators, refrigerator-freezers, and freezers: Appliance magazine37 and the AHAM Fact 

Book.

19 Appliance magazine breaks down refrigerator and refrigerator-freezer shipments into 

3-26 

EERE-2008-BT-STD-0012 COMMENT 22
three groups: (1) standard-size units, (2) built-in units, and (3) compact units. Both sources break 

down freezer shipments into chest and upright units. Unfortunately, neither source provides any 

further level of disaggregation. As discussed below, standard-size shipments can be broken down 

into two broad groups: (1) top- and bottom-mount refrigerators and refrigerator-freezers, and (2) 

side-mount units. 

Figure 3.2.1 shows historical shipments of refrigerators and refrigerator-freezers. Figure 

3.2.2 shows historical shipments of freezers. In the past decade, annual shipments of standard 

refrigerator-freezers have grown from 8 million to 11 million, although shipments have dropped 

off significantly in 2007 and 2008 in response to poor economic conditions. Annual shipments of 

compact refrigerators grew from one million to roughly 3 million, but shipments dropped starting 

in 2006. Note that the data for refrigerators include products used in non-residential settings 

(e.g., hotels and offices), but the size of this market segment is unknown. 

Shipments of chest and upright freezers have grown less rapidly than those of standard 

refrigerator-freezers. These shipments rose from 1.5 million in 1997 to 2.5 million in 2002, but 

shipments dropped starting in 2005 and are now at 2 million annually. Shipments of compact 

freezers are roughly 0.5 million. 

0 

2 

4 

6 

8 

10 

12 

Annual Shipments (millions) 

Standard-Size 

Compact 

1990199119921993199419951996199719981999200020012002200320042005200620072008 

Year 

Figure 3.2.1 Annual Shipments of Refrigerators and Refrigerator-Freezers 

3-27 

EERE-2008-BT-STD-0012 COMMENT 22
0.0 

0.5 

1.0 

1.5 

2.0 

2.5 

3.0 

Annual Shipments (millions) 

Standard-Size 

Compact 

1990199119921993199419951996199719981999200020012002200320042005200620072008 

Year 

Figure 3.2.2 Annual Shipments of Freezers 

For DOE’s 2005 technical analysis of amended energy conservation standards for 

residential refrigerator-freezers, AHAM provided historical shipments data for the time period 

1998–2004, broken down into three broad groups: (1) top- and bottom-mount refrigeratorfreezers, (2) side-mount units, and (3) single-door units.38 Table 3.2.21 below shows market 

share data for only two of the above three groups—top- or bottom-mount refrigerator-freezers 

and side-mount refrigerator-freezers. According to DOE’s 2005 technical analysis, these two 

product groupings account for over 99 percent of standard-size refrigerator-freezer shipments. 

Data provided by AHAM as part of the pre-NOPR phase shows that in recent years single-door 

units accounted for 0.2% or less of shipments of standard-size refrigerators and refrigeratorfreezers. This data also shows a strong shift towards bottom-mount refrigerator-freezers in the 

last few years, coinciding with reduction in market share of both side-mount and top-mount 

refrigerator-freezers. 

3-28 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 3.2.21 Market Shares of Standard Refrigerator-Freezer Product Classes 

Year 

Top- Mount 

Refrigerator- Freezer 

(percent) 

Bottom- Mount 

Refrigerator- Freezer 

(percent) 

Side-Mount RefrigeratorFreezer 

(percent) 

1998 69.3 29.9 

1999 68.8 30.8 

2000 68.3 31.3 

2001 67.5 32.1 

2002 66.6 32.8 

2003 63.7 34.5 

2004 63.4 35.1 

2005 62.5 2.0 35.2 

2006 54.5 10.6 34.6 

2007 53.9 13.6 32.4 

Source: AHAM 

Based on data from The NPD Group for 2004,39 DOE estimated that (1) top-mount 

refrigerator-freezers without TTD ice service in the size category range of 14 to 21 ft3 b comprise 

81 percent of total top- and bottom-mount refrigerators, and (2) side-mount refrigerator-freezers 

with TTD ice service in the size category range of 21 to 30 ft3 comprise 98 percent of total sidemount refrigerator-freezer shipments. 

3.2.6.2 Historical Efficiencies 

The average efficiency of new refrigerators and freezers has increased greatly since the 

1980s. Figure 3.2.3 below (which shows annual electricity consumption) indicates the changes in 

efficiency resulting from the Federal standards that took effect in 1990, 1993, and 2001. Note 

that the average efficiency trends shown in the chart reflect changes in product size and features 

as well as changes in the efficiency within specific types of products. In particular, the growing 

market share of side-mount refrigerator-freezers placed upward pressure on the average annual 

electricity use of new refrigerator-freezers. 

b

 Size category is based on ft3 of total refrigerated volume (fresh food volume plus freezer volume). 

3-29 

EERE-2008-BT-STD-0012 COMMENT 22
0 

200 

400 

600 

800 

1000 

1200 

1400 

1600 

1800 

Annual Energy Use (kWh/year) 

Standard-Sized Refrigerator-Freezer 

Freezer 

1990 

Standards 

announced 

1993 

Standards 

2001 

Standards 

1970 1975 1980 1985 1990 1995 2000 2005 2010 

Year 

Figure 3.2.3 Average Annual Electricity Use of New Refrigerator-Freezers and Freezers 

Source: AHAM 

 ENERGY STAR sales data are an indicator of the demand for very energy-efficient 

products. The market share of ENERGY STAR labeled refrigerator-freezers grew from 17 

percent in 2001 to 33 percent in 2004 (Table 3.2.22) and held steady in the low 30 percent range 

in the following two years.40 

Table 3.2.22 Sales of ENERGY STAR Labeled Refrigerator-Freezers 

Year Energy Star Criteria Percent of Total 

1998 20% below 1993 Standard 19% 

1999 24% 

2000 27% 

2001 10% below 2001 Standard 17% 

2002 20% 

2003 26% 

2004 15% below 2001 Standard 33% 

2005 33% 

2006 31% 

Source: ENERGY STAR 

3-30 

EERE-2008-BT-STD-0012 COMMENT 22
3.2.6.3 Imports and Exports 

The share of domestic shipments of refrigerators and freezers accounted for by imports 

grew significantly in the 1994-2004 period. Refrigerator imports totaled nearly six million units 

in 2004. Over one-third of the imports came from Mexico. Freezer imports totaled around one 

million units in 2004.19 

Annual refrigerator exports—mostly to Canada—were in the 1.0 to 1.1 million units 

range in the 1994-2004 period, while annual freezer exports ranged between 200,000 and 

250,000 units. 19 

3.2.7 Saturation in U.S. Homes 

Saturation refers to the percentage of homes with a given product. DOE used four 

primary sources of information on the saturation and ownership of refrigerators, refrigeratorfreezers, and freezers in U.S. homes: (1) a 2001 report prepared for AHAM by NFO Research, 

Inc.,41 (2) Appliance magazine, (3) the Energy Information Administration (EIA)’s Residential 

Energy Consumption Survey (RECS),42,43,44 and (4) a 2005 AHAM report entitled Major 

Appliance Saturation & Marketing Factors Study.45 Only RECS provides market saturations for 

recently-built housing; this information is useful for forecasting future shipments to new 

housing. 

The saturation of standard refrigerators has been close to 100 percent for two decades 

(Table 3.2.23). The RECS data show that the share of households with two or more refrigerators 

grew from 13 percent in 1993 to 15 percent in 2001 and to 19 percent in 2005 (the current 

percentage with two or more is likely even higher). 

3-31
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

Table 3.2.23 Standard Refrigerator Saturation in U.S. Homes in 1987–2005 Period 

Year 

Refrigerators, Standard 

Appliance 

Magazine NFO 2001 

RECS 

All 1 unit 2 or more 

1987 99.9% 

1988 

1989 

1990 96.7% 

1991 

1992 99.0% 

1993 99.3% 98.6% 85.8% 12.8% 

1994 99.5% 

1995 99.7% 

1996 99.8% 93.9% 

1997 99.8% 98.9% 85.8% 13.2% 

1998 99.8% 

1999 99.8% 

2000 99.9% 

2001 99.0% 93.1% 99.3% 82.9% 14.6% 

2002 99.0% 

2003 99.0% 

2004 99.0% 

2005 99.0% 99.9% 77.7% 19.2% 

The data on saturation of compact refrigerators vary greatly (Table 3.2.24). The estimates 

for 2005 vary from a low of 3.7 percent (RECS) to a high of 17.0 percent (Appliance magazine). 

Comparatively, NFO’s estimate for 2001 is 5.6 percent. 

3-32
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

Table 3.2.24 Compact Refrigerator Saturation in U.S. Homes in 1987–2005 Period 

Year 

Refrigerators, Compact 

Appliance 

Magazine NFO 2001 

RECS 

All 1 unit 2 or more 

1987 

1988 

1989 

1990 7.4% 

1991 

1992 7.4% 

1993 8.7% 3.2% 3.2% 0.0% 

1994 9.2% 

1995 9.7% 

1996 11.2% 5.8% 

1997 12.1% 2.8% 2.8% 0.1% 

1998 12.6% 

1999 14.5% 

2000 16.0% 

2001 16.5% 5.6% 3.1% 3.0% 0.1% 

2002 16.5% 

2003 16.5% 

2004 17.0% 

2005 17.0% 3.7% 3.1% 0.6% 

The data on freezer saturation are also somewhat varied (Table 3.2.25). Appliance 

magazine reports that freezer saturation has risen from 40 percent in 1993 to 45 percent in 2005, 

but the NFO study reports that the 2001 level (41 percent) was lower than in 1990 (45 percent). 

RECS shows a much lower freezer saturation in 2001 (32 percent) than the other sources, and 

also shows a declining trend. 

3-33
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

Table 3.2.25 Freezer Saturation in U.S. Homes in 1987-2005 Period 

Year 

Freezers 

Appliance 

Magazine NFO 2001 

RECS 

All 1 unit 2 or more 

1987 40.7% 

1988 

1989 

1990 45.4% 

1991 

1992 38.2% 

1993 40.0% 34.5% 30.5% 4.0% 

1994 40.0% 

1995 41.2% 

1996 42.5% 42.4% 

1997 42.4% 33.2% 30.2% 2.9% 

1998 42.8% 

1999 42.9% 

2000 44.0% 

2001 47.0% 41.0% 32.0% 28.8% 3.2% 

2002 47.5% 

2003 47.5% 

2004 47.0% 

2005 45.0% 31.6% 29.0% 2.6% 

As shown in Table 3.2.26, RECS data indicate that in new housing (1) the saturation of 

freezers is lower, and (2) the share of households with two or more refrigerators is higher in 

recently-built homes than in the total population of homes. For freezers, this result is in 

accordance with the declining saturation of freezers in the total population seen in Table 3.2.25. 

3-34
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

Table 3.2.26 Refrigerator and Freezer Saturation in New U.S. Homes 

Year 

Standard Refrigerators Freezers 

New Homes* New Homes* 

All 1 unit 2 or more All 1 unit 2 or more 

1993 99.7% 90.4% 9.2% 30.3% 27.8% 2.5% 

1994 

1995 

1996 

1997 99.6% 85.8% 13.8% 35.9% 33.1% 2.6% 

1998 

1999 

2000 

2001 100% 82.5% 15.6% 28.4% 26.3% 2.1% 

2002 

2003 

2004 

2005 100% 75.0% 26.1% 27.2% 23.9% 3.3% 

Source: RECS surveys; * “New homes” refers to homes built in the 1988-1993 period for the 1993 RECS, the 

1992-1997 period for the 1997 RECS, and the 1996-2001 period for the 2001 RECS, and the 2001-2005 period for 

the 2005 RECS. 

3.2.8 Product Retail Prices 

3.2.8.1 Historical Retail Prices 

AHAM has reported average consumer retail prices for refrigerator-freezers and freezers 

in past Fact Books. Table 3.2.27 lists the prices for eight years spanning 1980–2002. The real 

price of refrigerator-freezers and freezers (expressed in 2008 $) declined during the 1980s and 

1990s. However, in 2002, the prices of both types of products increased relative to the year 1998. 

Table 3.2.27 Refrigerator-Freezer and Freezer Average Retail Prices 

Product Price 

Year 

1980 1985 1986 1991 1993 1994 1998 2002 

RefrigeratorFreezers 

nominal $ $598 $702 $684 $732 $692 $713 $657 $788 

2008 $ $1,563 $1,405 $1,344 $1,157 $1,031 $1,036 $868 $943 

Freezers nominal $ $426 $479 $449 $434 $334 $344 $315 $405 

2008 $ $1,113 $958 $882 $686 $498 $500 $416 $485 

Source: AHAM Fact Books. 

3.2.8.2 Refrigerator-Freezer 2004 Retail Prices 

DOE’s most recent technical analysis of amended energy conservation standards for 

residential refrigerator-freezers published in October 2005 provided the retail price of the two 

largest product classes of refrigerator-freezers: top-mount refrigerator-freezers without TTD 

features and side-mount refrigerator-freezers with TTD features.38 The analysis also established 

the retail price of products meeting existing ENERGY STAR levels. 

3-35 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Baseline Retail Prices 

DOE determined the retail price of baseline-efficiency top-mount refrigerator-freezers 

without TTD features and side-mount refrigerator-freezers with TTD features from data 

purchased from NPD Group. The NPD Group dataset included information about the average 

price of more than 2000 refrigerator models sold in 2004 in the United States.c Table 3.2.28 

below summarizes the retail price data for three capacity sizes for each of the product types. The 

retail prices correspond to baseline-efficiency products, i.e., products that just meet the existing 

energy conservation standards. 

Table 3.2.28 Baseline Unit Retail Prices from 2005 DOE Report (2004$) 

Product Type 14-17 ft3 18-20 ft3 21-22 ft3 

Top-Mount without TTD $329 $386 $457 

 21-23 ft3

 24-26 ft3 27-30 ft3 

Side-Mount with TTD $702 $789 $926 

Source: The NPD Group/NPD Houseworld – POS. 

Price of ENERGY STAR 

DOE’s October 2005 report also provided incremental retail price estimates of ENERGY 

STAR products relative to baseline products. At the time, ENERGY STAR levels specified 15 

percent lower energy consumption than the federal energy standard level. DOE used two 

approaches to estimate the retail prices: (1) the application of manufacturer and retailer markups 

to manufacturer costs, and (2) a retail price analysis of ENERGY STAR compliant products 

based on data from the NPD Group. Table 3.2.29 below summarizes the retail price increments 

associated with meeting ENERGY STAR relative to baseline models of several different 

capacity sizes. Note that the two approaches yield roughly the same average retail price 

increment of meeting ENERGY STAR with the exception of the 27–30 ft3

 side-mount 

refrigerator. 

Table 3.2.29 Average Retail Price Increment of ENERGY STAR from 2005 DOE Report 

(2004$) 

Product Type Approach 14-17 ft3 18-20 ft3 21-22 ft3 

Top-Mount without 

TTD 

Markups $38 $35 $42 

Retail Prices $28 $49 $63 

Product Type Approach 21-23 ft3

 24-26 ft3 27-30 ft3 

Side-Mount with TTD Markups $54 $35 $183 

Retail Prices $47 $66 $88 

Source: DOE, 2005. 

c

 The data also included information about the refrigerator brand, manufacturer, attributes (e.g., total refrigerated 

volume, number and type of shelves), and sales, and whether each model has an Energy Star rating. The data cost 

$25,000 to purchase. 

3-36 

EERE-2008-BT-STD-0012 COMMENT 22
 

3.2.8.3 2007 Manufacturer-Suggested Retail Prices 

DOE collected retail price data for several refrigerator-freezer and freezer models from 

five manufacturers’ Internet web sites: General Electric, Whirlpool, Frigidaire, Maytag, and LG 

Electronics. The price data reflect manufacturer-suggested retail prices and, therefore, may not 

reflect actual sales prices. Even so, DOE conducted a statistical analysis of the data to determine 

the effect of certain attributes, including the impact of meeting existing ENERGY STAR levels. 

DOE collected data on 1,268 refrigerator-freezer and freezer models. The collected data 

set included information about the retail price and model number of refrigerator-freezers and 

freezers sold in 2007 in the U.S., coupled with information about the brand, attributes (i.e., color, 

stainless steel, built-in, French doors), and whether the product met existing ENERGY STAR 

levels. DOE sorted the data into the following product types: (1) side-mount refrigerator-freezers 

consisting of 523 models, (2) top-mount refrigerator-freezers consisting of 340 models, (3) 

bottom-mount refrigerator-freezers consisting of 281 models, (4) chest freezers consisting of 46 

models, and (5) upright freezers consisting of 54 models. 

Figure 3.2.4 through Figure 3.2.8 present price distributions for each product type, 

showing variation in price of products which do not meet ENERGY STAR criteria as well as 

variation in price for products with comply with ENERGY STAR. The price distributions of 

side-mount and top-mount refrigerator-freezers in Figure 3.2.4 and Figure 3.2.5 indicate that 

ENERGY STAR generally increases the price and that there is a wider price variation for 

ENERGY STAR products. Also, both refrigerator-freezer types exhibit skewed price 

distributions, i.e., more models are low-priced with relatively few high-priced models (as an 

example, fewer than 10 models were priced above $1,300 for top-mounts). The price 

distributions for bottom-mount refrigerator-freezers, Figure 3.2.6 below, show that French-door 

configurations are more of a factor in contributing to high price than ENERGY STAR efficiency 

levels. Most bottom-mount models already meet ENERGY STAR, and those models configured 

with French doors are distinctly more expensive. The price distributions for upright freezers 

show that ENERGY STAR models are generally more expensive (Figure 3.2.7). For chest 

freezers, there are several models with and without ENERGY STAR that are priced similarly, 

but there are no low-priced models that qualify for ENERGY STAR (Figure 3.2.8). 

3-37 

EERE-2008-BT-STD-0012 COMMENT 22
1000 2000 3000 4000 5000 6000 7000

90 

80 

70 

60 

50 

40 

30 

20 

10 

0 

Retail Price per Unit ($) 

# of Models 

0 

1 

Estar 

Distribution of Side-Mount Refrigerator Models 

EStar 0 refers to Non-Energy Star models 1 refers to Energy Star models. 

Figure 3.2.4 2007 Manufacturer-Suggested Retail Price Distribution of Side-Mount 

Refrigerator-Freezers with and without ENERGY STAR (2007$) 

3-38
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

400 600 800 1000 1200 1400 1600 1800 

60 

50 

40 

30 

20 

10 

0 

Retail Price per Unit ($) 

# of Models 

0 

1 

EStar 

Distribution of Top-Mount Refrigerator Models 

EStar 0 refers to Non-Energy Star models and 1 refers to Energy Star models. 

Figure 3.2.5 2007 Manufacturer-Suggested Retail Price Distribution of Top-Mount 

Refrigerator-Freezers with and without ENERGY STAR (2007$) 

800 1200 1600 2000 2400 2800 

20 

15 

10 

5 

0 

Retail Price per Unit ($) 

# of Models 

0 0 

0 1 

1 0 

1 1 

Star 

Energy 

Doors 

French 

Distribution of Bottom-Mount Refrigerator Models 

0 refers to a feature being absent and 1 refers to a feature being present. 

Figure 3.2.6 2007 Manufacturer-Suggested Retail Price Distribution of BottomMount Refrigerator-Freezers with and without ENERGY STAR (2007$) 

3-39 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

300 600 900 1200 1500 

16 

14 

12 

10 

8 

6 

4 

2 

0 

Retail Price per Unit ($) 

# of Models 

0 

1 

Star 

Energy 

Distribution of Upright Freezer Models 

0 refers to Non-Energy Star models and 1 refers to Energy Star models. 

Figure 3.2.7 2007 Manufacturer-Suggested Retail Price Distribution of Upright 

Freezers with and without ENERGY STAR (2007$) 

200 300 400 500 600 700 800

9 

8 

7 

6 

5 

4 

3 

2 

1 

0 

Retail Price per Unit ($) 

# of Models 

0 

1 

Star 

Energy 

Distribution of Chest Freezer Models 

0 refers to Non-Energy Star models and 1 refers to Energy Star models. 

Figure 3.2.8 2007 Manufacturer-Suggested Retail Price Distribution of Chest 

Freezers with and without ENERGY STAR (2007$) 

DOE also performed regression analysis on each of the five product types to estimate the 

incremental price of the different attributes. For the regression analysis, DOE confined the 

3-40 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

sample to models with prices within two standard deviations of the mean value. DOE did this to 

remove outliers from the sample. Removing the outliers lowered the sample size to 92 to 95 

percent of the original size, depending on the product type. Specifically, the side-mount 

refrigerator-freezer sample was reduced from 523 to 502, the top-mount refrigerator-freezer 

sample was reduced from 340 to 321, the bottom-mount refrigerator-freezer sample was reduced 

from 281 to 272, the upright freezer sample was reduced from 54 to 53, and the chest freezer 

sample was reduced from 46 to 43. DOE performed the regression analysis with two types of 

regression equations that it formulated to determine the price increment due to each attribute: (1) 

a ‘basic’ equation where price is a function of only ENERGY STAR qualifying levels (the focus 

variable); and (2) a ‘complete variable’ equation where price is a function of ENERGY STAR 

(the focus variable), product attributes (stainless steel, built-in, French doors), and the brand. 

Table 3.2.30 presents the summary results of the regression analysis. The first column in 

the table indicates the product type and the second column presents the ‘constant’ price (i.e., the 

price without any of the attributes under consideration, also referred to as a baseline model) for 

each product type. The ‘coefficients’ represent the price adder for a product with a specific 

attribute (i.e., ENERGY STAR, French doors for bottom-mount products, stainless steel cabinet, 

and brand). If the value is positive, than the ‘coefficient’ for the attribute is added to the 

‘constant’ price. If the value is negative, than the ‘coefficient’ for the attribute is subtracted from 

the ‘constant’ price. For example, for side-mount refrigerator-freezers, the ‘coefficient’ for 

ENERGY STAR is $208. Therefore, the added retail price of an ENERGY STAR side-mount 

refrigerator-freezer is $208, raising the baseline price from $1128 to $1336. Also presented in 

Table 3.2.30 are the adjusted R-squared value and the number in the sample. In a multiple linear 

regression model, adjusted R square measures the proportion of the variation in the dependent 

variable (retail price) accounted for by the explanatory variables.d 

DOE found that the incremental price effect of meeting ENERGY STAR levels is 

significant at a 95 percent confidence level for all product types with the exception of bottommount refrigerator-freezers. In the case of side-mount refrigerator-freezers, qualifying for 

ENERGY STAR adds $208 to the price of the baseline model, while for top-mount refrigeratorfreezers it adds $63. These price increments are significantly higher than those from DOE’s 

October 2005 technical report (see Table 3.2.29 above). Because the analysis conducted for the 

2005 technical report was more rigorous (for example, DOE conducted the 2005 retail price 

analysis using sales-weighted point-of-sale data), the price increments for meeting ENERGY 

STAR based on the 2007 manufacturer suggested retail price data are likely not as accurate a 

price indication of meeting ENERGY STAR. Rather, the analysis based on the 2007 prices 

simply confirms that ENERGY STAR products are more expensive than baseline products. In 

the case of upright and chest freezers, the analysis shows that the price increase associated with 

meeting ENERGY STAR is $107 and $121, respectively. 

For bottom-mount refrigerator-freezers, meeting ENERGY STAR levels is not a 

significant factor at a 95 percent confidence level. The French door attribute is significant and 

d

 Unlike R squared, adjusted R squared allows for the degrees of freedom associated with the sums of the squares in 

its calculation. Therefore, even though the residual sum of squares decreases or remains the same as new 

explanatory variables are added, the residual variance does not. For this reason, adjusted R square is generally 

considered to be a more accurate goodness-of-fit measure than R square. 

3-41 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

adds over $330 to the price of a baseline unit. This is consistent with the price distributions of 

bottom-mount models presented in Figure 3.2.6 above. 

The analysis suggests that stainless steel plays a significant role in the price of sidemount, top-mount, and bottom-mount refrigerator-freezers and upright freezers. The ‘coefficient’ 

of brand suggests an effect similar to stainless steel. Brand is significant for the three 

refrigerator-freezer product types but is not significant in the case of freezers. 

Table 3.2.30 Regression Analysis of the Incremental Price of ENERGY STAR and other 

Attributes based on 2007 Manufacturer-Suggested Retail Prices (2007$) 

Product 

Type 

Constant 

(Baseline) 

Coefficients (Price Adder) 

Adj 

R2 

Number 

in 

Sample 

Energy 

Star 

French 

Door 

Stainless 

Brand 

Frigidaire GE Whirlpool Maytag LG 

Mount 

Side­ $1128 $208 NA $156 -245 $375 -$231 -$252 $431 0.65 502 

TopMount 

BottomMount 

$660

$1285

 $63 

 -$31* 

NA 

$332 

$97 

$143 

-$54 

NA 

$80 

$283 

$28 

-$83 

$49 

$70 

NA 

-$212 

0.40 

0.58 

321 

272 

Upright 

Freezer $495 $107 NA $215 $56* $40* -$41* -$40* NA 0.35 53 

Chest 

Freezer $352 $121 NA NA $116* $116* -$100* -$99* NA 0.17 43 

* Although numerical values are provided, the regression analysis indicated that these attributes were not significant 

factors in determining the incremental product price at a 95 percent confidence interval. 

3.2.8.4 Refrigerator-Freezer and Freezer 2008 Retail Prices 

To determine retail prices for the year 2008, DOE drew upon proprietary retail price data 

collected by The NPD Group.46 These data reflect prices and sales at many retail outlets in the 

United States, representing more than 50 percent of retail sales nationwide. The data include 

model number, refrigerated volume, configuration of doors and ice-making, and whether the unit 

is an ENERGY STAR product. Based on these data DOE developed a sales-weighted price 

distribution for non-ENERGY STAR appliances for seven of the 20 product classes.e Additional 

details about this price data are provided in Chapter 8 of this TSD. The average baseline retail 

prices before sales tax for each of the seven product classes are shown in Table 3.2.31. With the 

exception of product class 3 (top-mount refrigerator-freezers), the retail prices in Table 3.2.31 

are relatively close to the manufacturer-suggested retail prices in Table 3.2.30. 

e

 DOE assumed that prices for non-ENERGY STAR models are a reasonable approximation of prices for the 

baseline models. 

3-42 

EERE-2008-BT-STD-0012 COMMENT 22
Table 3.2.31 Residential Refrigeration Products: Average Baseline Retail Price 

Product Class Baseline Retail Price 

2008$ 

Product class 3: Top-mount refrigerator-freezer 1,005 

Product class 5: Bottom-mount refrigerator-freezer 1,313 

Product class 7: Side-by-side refrigerator-freezer with TTD* 1,333 

Product class 9: Upright freezer 469 

Product class 10: Chest freezer 483 

Product class 11: Compact refrigerator 151 

Product class 18: Compact freezer 193 

* Through-the-door ice service. 

3.3 TECHNOLOGY ASSESSMENT 

This section provides a technology assessment for refrigerators, refrigerator-freezers, and 

freezers. Contained in this technology assessment are details about product operations and 

components (section 3.3.1), an examination of possible technological improvements for each 

product (section 3.3.2), and a characterization of the product efficiency levels currently 

commercially available (section 3.3.3). 

3.3.1 Product Operation and Components 

This section provides a brief description of the components and operation of refrigerators, 

refrigerator-freezers, and freezers. These descriptions provide a basis for understanding the 

technologies used to improve product efficiency. 

3.3.1.1 Product Operation 

Refrigerators, refrigerator-freezers, and freezers are household appliances designed for 

the refrigerated storage of food products. Definitions for these product types and their operating 

temperature ranges are discussed in section 3.2.1. 

Figure 3.3.1 shows a schematic representation of a typical refrigeration circuit used in 

residential refrigeration products. As described by the American Society of Heating, 

Refrigerating and Air-Conditioning Engineers (ASHRAE) Refrigeration Handbook,

47 the 

refrigeration process consists of the following steps: 

1.	 Electrical energy is supplied to a motor that drives a compressor, which draws cold, lowpressure refrigerant vapor for the evaporator and compresses it. 

2.	 The resulting high-pressure, high-temperature discharge gas then passes through the 

condenser, where it is cooled to saturation condition, condensed to a liquid, and possibly 

subcooled while heat is rejected to the ambient air. 

3.	 Liquid refrigerant passes through a metering (pressure-reducing) capillary tube to the 

evaporator, which is at low pressure. 

3-43 

EERE-2008-BT-STD-0012 COMMENT 22
4. The low-pressure, low-temperature liquid in the evaporator absorbs heat from its 

surroundings, evaporating to a gas, which is again withdrawn by the compressor. 

Figure 3.3.1 Refrigeration Circuit 

In Figure 3.3.1 above, the metering or flow control device pictured is a non-adiabatic 

capillary tube. In this configuration, the capillary tube is soldered to the suction line to evaporate 

the residual liquid in the suction line and warm the vapor. This suction line heat exchanger (or 

the non-adiabatic capillary) increases the refrigeration capacity of the system by the amount of 

heat being transferred from the capillary to the suction side. Non-adiabatic capillary tubes are the 

most common type of metering device in refrigerator-freezers. The other type of metering 

device, an adiabatic capillary tube, is used in some refrigeration products. In this configuration, 

the capillary tube does not exchange heat with the suction line and the refrigerant expands from 

the high pressure to the low pressure adiabatically. 

3.3.1.2 Primary Components 

The illustration in Figure 3.3.2 (from RemodelGuide.com48) shows the components and 

layout of a typical top-mount refrigerator-freezer. The components and layout are similar in sidemount and bottom-mount refrigerator-freezers. Freezers also have a similar layout and 

components, but are slightly less complicated due to the fact that they have no fresh food 

compartment. The text that follows describes the following operations or components: automatic 

defrost, cooling, temperature control, lighting, ice maker, ice and water dispenser, and door seals 

and hinges. 

3-44 

EERE-2008-BT-STD-0012 COMMENT 22
 Source: RemodelGuide.com 

Figure 3.3.2 Top-Mount Refrigerator-Freezer Components 

Automatic defrost 

Almost all standard-size refrigerator-freezers are self-defrosting. Manual defrost is still 

used in chest freezers, some upright freezers, and in compact refrigerators and freezers. Selfdefrosting refrigerator-freezers and freezers automatically melt frost that accumulates in the 

freezer compartment. The typical automatic defrost system has three functional components: a 

defrost timer, a defrost heater, and a defrost thermostat. 

•	 Defrost timer: The timer is a clock that is energized with the compressor. The timer 

initiates defrost after a set interval of compressor operation, typically twelve hours. 

•	 Defrost heater: The defrost heater is an electric resistance heating element. It is located 

just beneath or on the side of the evaporator coil, which is concealed behind a panel in the 

freezer compartment. The heater melts any ice or frost that builds up. A heater is 

typically also energized in the drip pan to prevent freeze of melted condensate and 

clogging of the drip pan drain. 

3-45 

EERE-2008-BT-STD-0012 COMMENT 22
•	 As the frost and ice melt, the resulting water drips into a drip pan. The pan is connected 

to a tube that drains the water into a shallow pan at the bottom of the refrigerator-freezer 

or freezer. The water is then evaporated by air which is drawn by a fan through the 

condenser and over the compressor shell. In some products which do not use forced 

convection condensers, particularly freezers, a special pan is mounted on top of the 

compressor shell and the water is evaporated using heat from the compressor. 

•	 Defrost thermostat: The process ends when the defrost thermostat mounted on the 

evaporator tubing senses that a sufficiently high temperature has been attained. 

Cooling 

All residential refrigerators, refrigerator-freezers, and freezers work by removing heat 

from the air in the cabinet. They all have the key components shown in Figure 3.3.1: a 

compressor, a condenser, a metering or flow control device (usually a capillary tube), and an 

evaporator. 

•	 Compressor: The compressor compresses refrigerant, providing the energy input 

necessary to drive the cycle. In most residential refrigeration products, the compressor is 

located at the bottom rear of the unit. In built-in refrigerator-freezers the compressor is 

often located on top of the refrigerator behind a grill or grate. The compressor runs 

whenever the refrigerator thermostat calls for cooling. 

•	 Condenser: The condenser is a heat exchanger located on the outside of the unit. The 

three most prevalent condenser configurations are as follows: 

–	 Forced-convention condensers use fans to move air through them to provide cooling. 

These condensers are usually located under the unit near the compressor. They can be 

fabricated of steel tubes with steel wire fins or copper tubes with aluminum fins. 

–	 Natural convection “static” condensers which don’t use fans are mounted to the back 

of the unit. They generally have steel tubes and steel wire fins. 

–	 Hot wall condensers are integrated into the outer shell of the unit. A serpentine of 

tubing is attached to the inside of the shell and provided with good thermal contact to 

the shell. This is the common configuration in freezers and it is common in compact 

refrigerators. 

•	 Metering or Flow Control Device (Capillary Tube): The metering device in most 

household refrigerator-freezers is a capillary tube. As discussed above in section 3.3.1.1, 

there are two common types of capillary tubes—adiabatic and non-adiabatic, although 

non-adiabatic are the most common. The capillary tube controls the pressure and flow of 

the refrigerant as it enters the evaporator. 

•	 Evaporator: The evaporator is a heat exchanger located inside the unit. Similar to the 

condenser, there are three main configurations for evaporators: 

–	 Forced convection evaporators use fans to move air through them to provide cooling. 

They are constructed of aluminum tubes and aluminum fins or copper tubes and 

aluminum fins. They are generally located on the rear wall of the freezer 

3-46 

EERE-2008-BT-STD-0012 COMMENT 22
compartment behind a panel. They can also be located in the mullion separating the 

freezer and fresh food compartments, as shown in Figure 3.3.2. The evaporator fan 

circulates air through the evaporator and into both the freezer and fresh food 

compartments. Because the evaporator absorbs heat, it is very cold, thereby causing 

any water vapor in the air to freeze on it as frost. Most refrigerator-freezers using this 

type of evaporator employ automatic defrost. 

–	 Roll bond evaporators fabricated from layers of aluminum sheet primarily use natural 

convection cooling. The refrigerant passages are formed into the evaporator walls. 

They are used in single-door refrigerators and are configured either as a flat plate at 

the rear of the cabinet or a rectangular box. In the latter configuration, the interior of 

the box is the freezer compartment. While these evaporators generally use natural 

convection and do not use an evaporator fan, some products with rear-mounted flat 

roll bond evaporators use fans for performance enhancement. Manual defrosting is 

required to defrost these evaporators. 

–	 Cold wall evaporators are integrated within the walls of the freezer. This 

configuration is used in nearly all chest freezers and in many upright freezers. The 

evaporator consists of tube serpentines attached to the insulation side of the cabinet 

interior liner. These evaporators use natural convection heat transfer. 

Temperature control 

All refrigerators, refrigerator-freezers, and freezers have a thermostat or electronic 

temperature control to maintain the proper temperature. Thermostats are mechanical devices 

which interrupt the electricity connection to the compressor when the temperature is sufficiently 

low. Electronic control systems generally use thermistors as temperature sensors, using relays 

mounted on the circuit boards to activate the compressor and other components such as the 

evaporator and condenser fans. 

Lighting 

Refrigerators, refrigerator-freezers, and freezers with internal lighting normally have only 

one functional lighting component—the switch—which is usually a white push-button mounted 

to be depressed by operation of the door. Closing the door turns off the light. Refrigerators 

generally use standard appliance incandescent light bulbs. 

Ice maker 

Many standard-size refrigerator-freezers come equipped with an ice maker, and nearly all 

are convertible to installation of an ice maker. The ice maker is a located within the freezer 

compartment. Ice maker systems have two basic functional components: the icemaker itself, and 

the water fill valve. The most common ice makers operate as follows: 

•	 The ice maker sends a signal to the water fill valve (normally located on the outside back 

of the refrigerator, near the bottom) to open and let water into the ice maker tray (or 

mold). Water fill control is usually by timed opening of the valve (usually 7-10 seconds). 

3-47 

EERE-2008-BT-STD-0012 COMMENT 22
•	 When the ice has frozen and reached a sufficiently low temperature (10 to 15 °F), sensed 

with a thermostat located in thermal connection with the ice tray, the ice maker begins to 

harvest (eject) the cubes. 

•	 To harvest the cubes, the ice maker first turns on a small heater beneath the tray. The 

heater warms the tray, to help release the ice cubes. Then a sweep fork rotates and pushes 

the cubes up and out of the tray. 

•	 While the ice maker is dumping the cubes into a the ice storage bin, a metal wire similar 

to a coat hanger swings up to let the cubes drop below it. When the cubes have dropped, 

the wire rotates back down. If the holding bin is full of ice, the wire rotate far enough, 

which stops further production of ice. If the sensing wire can rotate down fully, the ice 

maker refills with water and repeats the process. 

Ice and water dispenser 

 Many standard-size refrigerator-freezers have a through-the-door (TTD) ice and/or water 

dispenser. There are several different systems for delivering ice and water through the 

refrigerator door. What follows is an explanation of the common attributes of all of the systems. 

•	 Ice dispenser: For a refrigerator-freezer to provide ice through the door, the ice maker 

first dumps the ice it produces into a large bin, as discussed above. To request ice at the 

door, the user presses a lever that activates a switch. The switch turns on a motor that 

rotates an auger which pushes ice out of the bin, through a chute to the user. Some 

dispensers also have blades which chop the ice to allow delivery of crushed ice. 

•	 Water dispenser: The water dispenser is activated much like the ice dispenser. To request 

water at the door, the user presses a lever on the front of the refrigerator that activates a 

switch. The switch turns on an electric water valve at the back of the refrigerator-freezer. 

Water flows through the valve into a tube, then flows into a reservoir located in the fresh 

food compartment in which the water is chilled. As new water enters the reservoir, the 

water that is displaced flows through a separate tube through the dispenser. 

Door Seals 

All refrigerator, refrigerator-freezer, and freezer doors have a seal—a vinyl gasket 

attached to the door(s). The seal prevents infiltration of warm ambient air into the cabinet. The 

seal is lined with a magnet which helps to hold the door closed and create a tight seal. The 

magnetic portion of the gasket is aligned to face the steel extension of the cabinet’s external shell 

which wraps partially around the front face of the cabinet. Some gasket systems use opposing 

magnets on the cabinet side to improve door sealing force. 

3.3.2 Technology Options 

Table 3.3.1 lists the technology options for improving the efficiency of residential 

refrigeration products. The technology options are categorized by their associated component or 

system. Each technology option category and the options available for improving the component 

or system category are discussed below. 

3-48 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

Table 3.3.1 Technology Options for Refrigerators, Refrigerator-Freezers, and Freezers 

Insulation Expansion Valve 

Improved resistivity of insulation Improved expansion valves 

Increased insulation thickness Cycling Losses 

Vacuum-insulated panels Fluid control or solenoid valve 

 Gas-filled panels Defrost System 

Gasket and Door Design Reduced energy for automatic defrost 

Improved gaskets Adaptive defrost 

 Double door gaskets 

Improved door face frame Condenser hot gas 

Reduced heat load for TTD feature Control System 

Anti-Sweat Heater Temperature control 

Condenser hot gas Air-distribution control 

Electric heater sizing Other Technologies 

Electric heater controls Alternative refrigerants 

Compressor Component location 

Improved compressor efficiency

 Variable-speed compressors Alternative Refrigeration Cycles 

Linear compressors Lorenz-Meutzner cycle 

Evaporator Dual-loop system 

Increased surface area Two-stage system 

Improved heat exchange Control valve system 

Condenser Ejector refrigerator 

Increased surface area Tandem system 

Improved heat exchange Alternative Refrigeration Systems 

Force convection condenser Stirling cycle 

Fans and Fan Motor Thermoelectric 

Evaporator fan and fan motor improvements Thermoacoustic 

Condenser fan and fan motor improvements 

3.3.2.1 Insulation 

The primary thermal load on a refrigerator or freezer is the heat transfer through the walls 

and doors into the cabinet. In one study of an 18.6 ft3 top-mount refrigerator-freezer, the wall and 

door heat loads were estimated to account for almost 60 percent of the total thermal load.49 

Nearly all residential refrigeration products use polyurethane (PU) foam insulation for 

both the cabinets and the doors. Through the 1980s, CFC-11, a chlorofluorocarbon (CFC), was 

used as a blowing agent in almost all PU foam insulation. However, under the Montreal Protocol, 

all CFCs were banned from use by the mid 1990s due to their high ozone depletion potential 

(ODP). In the 1990s, most manufacturers adopted use of HCFC-141b, a 

hydrochlorofluorocarbon (HCFC), which has significantly less ODP. However, because HCFC141b has non-zero ODP, it was banned from production in the U.S. after January 1, 2003. In 

response to the phase-out of HCFC-141b, AHAM’s Appliance Research Consortium (ARC) 

investigated several alternatives, including two hydrofluorocarbons (HFCs), HFC-134a and 

HFC-245fa, and cyclopentane, a hydrocarbon (HC). HFCs and HCs both have zero ODP. HCs 

have a much lower global warming potential (GWP) than HFCs, but they are flammable. ARC, 

DOE, and EPA sponsored research at Oak Ridge National Laboratory (ORNL) to determine the 

3-49 

EERE-2008-BT-STD-0012 COMMENT 22
 

thermal conductivities of the three alternatives and of HCFC-141b. Based on thermal 

conductivity, ORNL identified HFC-245fa as the most attractive substance because it had the 

lowest energy penalty relative to HCFC-141b (see Table 3.3.2).50 In addition, accelerated 

lifetime performance tests conducted by ORNL indicated that the thermal conductivity of HFC245fa foam insulation increases by a smaller percentage than either HFC-134a or cyclopentane 

foams. Finally, despite the fact that HCs are used in Europe, flammability and volatile organic 

compound concerns led ARC to determine that HFCs were a more suitable replacement blowing 

agent.51 As a result, many manufacturers are currently using HFC-245fa blowing agent for PU 

foam insulation. However, refrigerators and freezers sold in the U.S. also are using HFC-134a, 

cyclopentane, and HCFC-141b blowing agent. The HCFC blowing agent is still allowed for 

refrigerators imported into the U.S. 

Table 3.3.2 Thermal Conductivity of Freshly-Sliced Foam Specimens at 75 oF (23.9 oC) 

Blowing Agent 

Slice Thickness 

0.4 inch (1.0 cm) 1.5 in (3.8 cm) 

Btu-in/hr-ft2-oF mW/m-K Btu-in/hr-ft2

-oF mW/m-K 

HCFC-141b 0.132 19.0 0.128 18.4 

HFC-245fa 0.138 19.9 0.132 19.0 

Cyclopentane 0.150 21.6 0.145 20.9 

HFC-134a 0.160 23.1 0.155 22.3 

Source: ORNL, 2003.50 

Improved Resistivity of Insulation 

Past research has investigated improving the resistivity of PU foam insulation through the 

use of additives in the foam. 

Research conducted in 1996 demonstrated that adding carbon black provides a means of 

improving the thermal insulation properties of PU foam. The research showed that PU foam 

systems using carbon black in conjunction with either HCFC-141b or cyclopentane was able to 

lower k-factors by six to nine percent in panels and in cabinets.52 

Increased Insulation Thickness 

Based on DOE’s 1995 technical support document (TSD) for refrigerators, refrigeratorfreezers, and freezers, the insulation thickness range for refrigerator-freezers in the mid-1990s 

was 1.5 to 2.75 inches (3.81 to 7.0 cm) in the doors and 1.5 to 3 inches (3.81 to 7.62 cm) in the 

cabinet walls. Walls of freezers and freezer compartments tended to be near the higher end while 

walls of refrigerators and fresh food compartments were nearer the lower end.53 

Also based on the DOE 1995 TSD, adding 0.5 to 1 inch (1.27 to 2.54 cm) more insulation 

increases the overall efficiency of the product. Energy reductions associated with these wall 

thickness increases range from a few percent to over 10 percent. Therefore, DOE considered the 

addition of more insulation as a technology option to improve efficiency. Although the 

technology to implement this change is readily available, manufacturers indicated during the 

rulemaking leading to the April 27, 1997 final rule establishing the current minimum efficiency 

levels that adding insulation would not be the first technology option they would choose to 

improve efficiency. Significant investments would be required in foaming systems, tooling, and 

3-50 

EERE-2008-BT-STD-0012 COMMENT 22
 

molding to accommodate thicker insulation. Increased packaging and shipping costs must also be 

considered. Greater insulation thickness results in either decreased interior volumes, increased 

exterior dimensions, or some combination of both. Since kitchen dimensions and designed 

spaces for refrigerator-freezers are limited, there are restrictions on increasing the exterior size of 

the product. Reducing interior volume is considered undesirable because it impacts consumer 

utility. 

Vacuum-Insulated Panels 

Vacuum-insulated panel (VIPs) technology is based on the reduction in conductivity 

which occurs in a low vacuum, the same concept which is used to reduce heat leakage in thermos 

bottles. VIPs used in refrigeration products consist of a sealed package with a fill material which 

provides support to prevent the panel from collapsing and interferes with molecular mean free 

path as the intermolecular spacing increases at lower vacuum levels. VIPs can be foamed in 

place between the cabinet liner and wrapper to decrease the heat leakage and energy required to 

maintain the cabinet at low temperature. Different configurations are commercially available 

through advances in manufacturing technologies. As a result, VIPs are available in a variety of 

geometries (e.g., flat, curved, cylindrical) with added features (e.g., holes, cut-outs).54 Typical 

VIPs generally consist of a core material and an airtight envelope. Some VIPs also include 

absorber to absorb gas which leaks through the envelope. 

Several core materials have been used in the manufacture of VIPs including polystyrene, 

open-cell PU, silica powder, and glass fiber. Research sponsored by the European Commission 

has evaluated these core materials based on their cost and characteristics, including density and 

manufacturing time. Table 3.3.3 below summarizes the VIP characteristics manufactured with 

the above core materials.55 Each of the core materials has associated advantages and 

disadvantages that dictate their acceptability for an appliance application. 

Table 3.3.3 Comparison of Various VIP Core Materials 

Property Polystyrene Open-cell PU Silica Powder Glass Fiber 

Thermal Conductivity 

at 10 Pascals (Pa) abs. 

(0.1 millibar (mbar)) 

(mW/m-K) 4.8 – 5.8 9.7 5.8 2.4 

(Btu-in/hr-ft2

-oF) 0.033 – 0.040 0.067 0.040 0.017 

Manufacturing Time Fast Medium Medium Long 

Density (kilogram(kg)/cubic meter (m3

)) 80 – 144 64 192 128 

Drying Need No Yes Yes No 

Thermal Stability Low Medium Good Very Good 

Recyclability Yes Difficult Yes NA 

Cost Low Medium High Very High 

Source: European Commission, 2000.55 

ORNL also has evaluated the performance of three types of VIPs: a silica powder filler 

encapsulated in a polymer barrier film; a fibrous glass insulation filler encapsulated in a stainless 

steel barrier; and an undisclosed insulation filler encapsulated in a stainless steel barrier.56 Table 

3.3.4 summarizes the center-of-panel thermal conductivities of the panels. For the silica powder 

and glass fiber filled VIPs, the thermal conductivities in Table 3.3.4 are comparable to those in 

Table 3.3.3. 

3-51 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 3.3.4 Center-of-Panel Thermal Conductivity of VIPs 

Property Silica Powder Glass Fiber Unknown 

Thermal Conductivity* (mW/m-K) 5.2 – 5.4 2.0 – 2.6 2.7 – 3.1 

(Btu-in/hr-ft2

-oF) 0.034 – 0.038 0.014 – 0.018 0.019 – 0.022 

* For each filler, the reported thermal conductivities are a range of values from nine separate VIPs. 

Source: Vineyard et al, 1998.56 

ORNL also determined the thermal performance of the VIPs it studied as part of a 

composite panel. The composite panel consisted of a one-inch VIP surrounded by PU foam 

insulation to form a two-inch-thick panel. The PU foam insulation was blown with a variety of 

bowing agents, but, due to the age of the study (from the mid-1990s), ORNL considered neither 

HFC- nor HC-based blowing agents. For the three VIPs presented in Table 3.3.4, silica power, 

glass fiber, and unknown, the average composite panel thermal resistances were 21.5, 20.7, and 

20.9 hr-ft2-oF/Btu, respectively.56 The lower thermal conductivities reported in Table 3.3.4 for 

the glass fiber and unknown filled VIPs relative to the silica powder VIP were offset by the heat 

conduction through their stainless steel encapsulation material. 

Of significant concern for VIPs is their long-term thermal conductivity integrity. VIP 

thermal conductivity increases dramatically as the pressure within the VIP exceeds 100 Pa abs. 

(1 mbar). The pressure increase in the VIP over time is related to several factors, including: 

residual gases in the VIP after vacuum, degassing from the VIP core material, and gas diffusion 

through the envelope pores. Improved envelopes and absorbers have been developed to prevent 

pressure increases from occurring in VIPs. For example, for the three composite VIPs that it 

analyzed, ORNL measured only a five-percent reduction in overall thermal resistance over a 

three-year period. ORNL demonstrated that this reduction in thermal resistance was less than the 

corresponding reduction for a panel without any VIPs, i.e., panels consisting only of PU foam 

insulation.56 

Recent announcements regarding VIPs include the following. Matsushita’s VIP 

technology (trade name of “U-Vacua”) was awarded the Minister of Economy, Trade and 

Industry Prize at the 17th Energy Conservation Awards sponsored by the Energy Conservation 

Center of Japan in January, 2007.57 Matsushita claims that its VIP technology has achieved the 

world’s highest level of insulation efficiency with a thermal conductivity of 1.2 mW/m-K (0.008 

Btu-in/hr-ft2-oF) at 24 oC (75.2 oF).58 Electrolux announced in 2003 the use of VIP technology in 

a freezer that they claimed reduced energy use by 35 percent relative to PU foam insulation.59 

Va-Q-tek has recently introduced its va-Q-plus VIP technology.60 

Gas-Filled Panels 

Gas-filled panels (GFPs) use thin polymer films and low-conductivity gas to create a 

device with excellent thermal insulation properties. GFPs are essentially hermetic plastic bags 

that can take on a variety of shapes and sizes. Inside the outer barrier is a cellular structure called 

a baffle which is filled with the low-conductivity gas. 

Research conducted at LBNL in the mid-1990s has demonstrated the effectiveness of 

GFPs based on the use of different gases, including xenon and krypton. Table 3.3.5 below 

summarizes the thermal performance characteristics of different GFPs, based on their center-of3-52 

EERE-2008-BT-STD-0012 COMMENT 22
panel and whole-panel performance.61 LBNL has also conducted research to demonstrate that 

GFPs, when used in refrigerator-freezers, can reduce energy consumption by approximately 

eight percent relative to PU foam insulation.62 

Table 3.3.5 Comparison of Various Gas-Filled Panel Core Materials 

Gas Fill 

Center of Panel 

Performance Whole Panel Performance 

Thermal Conductivity Panel Thickness Mean Temp. Thermal Conductivity 

mW/m-K Btu-in/hr-ft2

-oF mm inches oC oF mW/m-K Btu-in/hr-ft2-oF 

Xenon 7.4 0.051 24.1 0.95 6.8 44.2 7.4 0.051 

Krypton 11.6 0.080 25.2 0.99 11.9 53.4 10.77 0.074 

49.8 1.96 12.3 54.1 1.17 0.008 

Argon 19.9 0.138 NA NA NA NA NA NA 

Air 28.1 0.195 NA NA NA NA NA NA 

Source: LBNL61 

In addition, ORNL determined the thermal conductivity of an insulation panel containing 

radiation baffles within a polymer barrier film and filled with krypton gas at atmospheric 

pressure. The range of thermal conductivities of nine of these GFPs ranged from 0.088 to 0.092 

Btu-in/hr-ft2-oF (12.6 to 13.2 mW/m-K). ORNL also analyzed the GFPs as part of a composite 

assembly consisting of a one-inch panel surrounded by PU foam insulation to form a two-inchthick panel. The average composite panel thermal resistance was determined to be 18.2 hr-ft2

­

oF/Btu. Finally, ORNL measured only a five-percent reduction in overall thermal resistance over 

a three-year period, which was less than the reduction observed in a panel consisting only of PU 

foam insulation.56 

Although research has demonstrated that GFPs have better thermal performance than PU 

foam insulation, no known refrigeration products are using the technology. A significant problem 

in using GFPs is their lack of structural integrity in the resulting product. 

3.3.2.2 Gasket and Door Design 

A significant portion of the heat gain to refrigerators and freezers occurs around the edges 

of the doors and through the gaskets on the door edges. An analysis of thermal loads on an 18.6 

ft3 top-mount refrigerator-freezer revealed that over 28 percent of the total heat load into the 

cabinet came from ‘edge’ loads, i.e., loads due to heat transfer into the food compartments via 

paths around the perimeter of the cabinet aperture.49 Table 3.3.6 summarizes the various ‘edge’ 

loads as well as the heat loads through the walls and doors and other sources. If the ‘edge’ effect 

losses can be reduced, the efficiency of the refrigerator can be increased. This section only 

addresses the ‘edge’ effect loads from the wall and door flanges and the door gasket. Heat loads 

from the anti-sweat heaters are discussed in the following section (section 3.11.2.3). 

3-53 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

Table 3.3.6 Overall Cabinet Loads 

Component Percent of Total 

‘Edge’ Effect Loads 28.5% 

Heat gain due to conduction along the wall steel flange 5.3% 

Heat input due to conduction along the door steel flange 7.1% 

Heat conduction directly through the door gasket or seal 2.7% 

Heat input due to conduction in the mullion region 1.7% 

Heat input due to mullion region anti-sweat heater 7.7% 

Heat input due to cabinet anti-sweat condenser tube 4.0% 

Wall and Door Loads 59.1% 

Miscellaneous Loads (heat inputs due to evap fan, defrost heaters, and compressor) 12.4% 

Source: Boughton et al, 1996.49 

Improved Gaskets 

Design of door gaskets is a balance between improving the thermal-efficiency 

performance of the gasket and ensuring that the door is not difficult to open. If the gasket magnet 

force is too strong, it becomes difficult to open the door. Based on a European Commission 

study, door handles have been designed specifically to facilitate door openings by providing 

leverage and relieving the pressure differential which can build up by freeing a small section of 

the gasket before the door is opened.55 Although materials and designs for improving the air 

tightness of door gaskets exist, apparently no general criteria have been established to enable 

different designs to be classified. 

An EPA report from 1992 describes theoretical modeling and experimental research on 

gasket heat loads and concludes that replacing about half of either the metal door flange or 

cabinet flange with plastic can reduce the heat flow through the gasket region by 25 percent.63 

However, this study did not address the impacts on the convection on the cabinet side of the 

gasket associated with different geometries of the “throat” region between the door dikes and the 

cabinet wedge or with different evaporator air flow rates. Based on DOE’s 1995 TSD, 

improvements in gasket design can reduce refrigerator-freezer annual energy consumption by 

one to three percent.53 Due to the age of both the EPA and DOE research, it is uncertain how 

much further gaskets can be improved. 

Double Door Gaskets 

A double door gasket is an additional inner door seal gasket that is added to the gasket 

design. This further reduces heat leakage and infiltration into the refrigerator and freezer. 

Based on information drawn from DOE’s 1995 TSD, manufacturers did not introduce 

double door gaskets in the mid-1990s because of performance problems and cost. Ice can form 

between the gaskets, greatly reducing their effectiveness. In addition, the gaskets are visually 

unattractive and they increase the difficulty of meeting safety regulations for minimum dooropening force. 

3-54
 

EERE-2008-BT-STD-0012 COMMENT 22
Improved Door Face Frame 

As discussed above, cabinet heat loads stem not only from conduction though the 

refrigerator walls but also from conduction along the external metal casing. The metal shell 

provides the structural integrity; however, its presence means that heat loads are transferred 

along the metal shell into the cabinet. This heat transfer into the cabinet is also referred to as the 

‘edge effect.’ 

Using a plastic cover on the internal flange can reduce the ‘edge effect’ heat losses by 

approximately 50 percent.49 It is expected that the use of low-conductivity plastics to reduce 

conduction losses in this area are already being employed in most current U.S. refrigeratorfreezer designs. 

Reduced Heat Load for TTD Feature 

Through-the-door features that provide ice and/or water service displace insulation in the 

door. These features can make it difficult to apply foam in the doors. This technology option, 

which is applicable only to those product classes that include TTD ice service, utilizes improved 

design methods to reduce the heat load of TTD features. 

Based on the DOE 1995 TSD, door-design improvements that reduce the heat load from 

TTD features can reduce refrigerator-freezer annual energy consumption from two to four 

percent.53 The TSD provided little explanation of the details of these design changes, citing only 

“foam insulation” and “improved design methods”. 

3.3.2.3 Anti-Sweat Heater 

Anti-sweat heaters are commonly used in standard-size refrigerator-freezers. In general, 

compact refrigerators, compact refrigerator-freezers, and compact freezers do not use anti-sweat 

heat. These heaters apply heat to external surfaces near door gaskets, including the mullion 

region between the freezer and fresh food compartments and along the perimeter of the cabinet. 

If electric resistance heaters are used for this purpose, the heaters contribute to energy 

consumption both with their wattage input and with the heat load they generate that enters the 

cabinet. Most modern refrigerator-freezers use refrigerant tubes inserted in the cabinets in close 

proximity to the regions requiring heat. Both hot discharge gas from the compressor and warm 

liquid leaving the condenser are used to provide this heat, although a majority of products use 

warm liquid. As reported above in section 3.11.2.2, the heat loads from both electric and 

refrigerant type anti-sweat heaters can be significant. For the example illustrated in Table 3.3.6, 

the contribution of the mullion anti-sweat heater represents 7.7 percent of the total cabinet heat 

load. However, the load associated with the anti-sweat heater of modern designs may be lower 

due to evolution of design practices to reduce such loads. 

Hot Gas or Warm Liquid 

The direct electricity consumption of the anti-sweat heaters can be eliminated by using a 

hot gas or warm liquid refrigerant loop to warm external surfaces to eliminate moisture buildup. 

This approach is used extensively in residential refrigerator-freezers to reduce energy use—the 

technology is already part of all or nearly all standard-size refrigerator-freezers. 

3-55 

EERE-2008-BT-STD-0012 COMMENT 22
 

Electric Heater Sizing 

For those products using electric resistance anti-sweat heaters, unnecessarily highwattage heaters may be used. Therefore, energy use can be decreased by reducing the heater 

wattage. For those products that still use electric resistance anti-sweat heaters, DOE is unaware 

to what extent the wattage of the heater is excessive. 

Electric Heater Controls including Variable Antisweat 

For those products using electric resistance anti-sweat heaters, control schemes can be 

used to limit the amount of energy used. One option, which is included on some current 

refrigerator-freezer models, is to use an on-off switch that allows the user to turn off the heater if 

“sweating” is not an issue. The DOE Energy test procedure calls for testing with the switch in the 

on position in order to measure annual energy use.64 However, DOE understands that most 

manufacturers measure annual energy use as an average of a test with the heater on and a test 

with the heater off. 

Another option is to control the anti-sweat heater based on temperature and humidity 

conditions. As discussed in section 3.2.2.2, DOE is considering incorporating into the test 

procedure for refrigerators and refrigerator-freezers an adaptation of a test procedure for which a 

waiver was granted to GE. The waiver provides a method for calculating the annual energy use 

contribution of electric anti-sweat heaters which are controlled to operate only as much as 

needed to avoid moisture accumulation, based on the input of ambient temperature and/or 

humidity sensors.6 

3.3.2.4 Compressor 

The compressor is the primary energy-consuming component in a refrigerator, 

refrigerator-freezer, or freezer. Therefore, technologies that can advance compressor efficiency 

have a significant effect on overall product efficiency. 

Residential refrigeration products use positive-displacement compressors in which the 

entire motor-compressor is hermetically sealed in the welded steel shell. Two types of 

compressors have been used in residential refrigeration products over the years—reciprocating 

and rotary. However, predominantly reciprocating compressors are now used in U.S. products. 

Almost all compressors are directly driven by two-pole squirrel-cage induction motors 

running at approximately 3,000 rpm on 60 Hz power. Three types of induction motors have been 

used in refrigerator compressors: resistance start/induction run (RSIR), capacitor start/induction 

run (CSIR), and resistance start/capacitor run (RSCR). Of the three motor types, the RSIR motor 

is the least efficient. As a result of the U.S. energy efficiency standards that took effect in 1993 

and 2001, the vast majority of compressor motors now use the RSCR type. 

Refrigerator compressor capacities range from as low as 125 Btu/hr (for compact 

refrigerators) to as high as 2,000 Btu/hr, although maximum capacities are more typically 950 

Btu/hr for U.S. residential refrigerator-freezers. Two organizations have established conditions 

for rating the performance of refrigerator compressors: ASHRAE and Comité Européen des 

3-56 

EERE-2008-BT-STD-0012 COMMENT 22
 

Constructeurs de Matériel Frigorifique (CECOMAF).f Table 3.3.7 below shows the rating 

conditions of these two organizations. The rating conditions are almost identical, except for the 

liquid temperature—this is the temperature leaving the condenser or any subcooling loop such as 

an anti-sweat heating loop. Because the CECOMAF liquid temperature is higher, compressor 

capacities and efficiencies under ASHRAE rating conditions are approximately 30 percent 

higher than for CECOMAF conditions. The actual operating conditions for compressors in 

residential refrigeration products under DOE energy test conditions can be significantly different 

than these rating conditions. Most notably, the condensing temperatures are generally 

significantly lower than 130  ̊F. 

Table 3.3.7 Compressor Rating Conditions 

Rating Condition ASHRAE CECOMAF 

Evaporator -10 oF (-23.3 oC) -10 oF (-23.3 oC) 

Condenser 130 oF (54.4 oC) 131 oF (55 oC) 

Ambient 90 oF (32.2oC) 89.6 oF (32 oC) 

Suction Gas 90 oF (32.2oC) 89.6 oF (32 oC) 

Liquid 90 oF (32.2 oC) 131 oF (55 oC) 

Compressor efficiency is also a function of refrigeration capacity. Based on data from 

DOE’s 1995 TSD, maximum expected compressor efficiencies for the year 1998 demonstrated 

that efficiency drops off with decreasing cooling capacity.53 The expected maximum compressor 

efficiencies for the year 1998 as reported in the 1995 TSD are shown below in Table 3.3.8 

below. A year 2000 European Commission study to support energy standards of domestic 

refrigeration appliances also noted the drop in efficiency as capacity drops.55 The reduced 

efficiency for lower-capacity compressors has been attributed to optimization of performance for 

higher-capacity compressors65 and to the higher importance of mechanical losses and losses 

associated with re-expansion of gases left in the clearance volume as the swept volume of the 

reciprocating piston decreases. 

f

 CECOMAF is a European appliance manufacturer trade association formed in 1958. It merged with EUROVENT 

in 1996 to become EUROVENT/CECOMAF. This organization is now called EUROVENT. 

3-57 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 3.3.8 Estimated 1998 Maximum Compressor Efficiencies 

Product Class Served 

Capacity Range* Maximum Efficiency by 1998* 

W Btu/hr 

Coefficient of 

Performance 

(COP) 

Energy 

Efficiency 

Ratio (EER), 

Btu/hr-W 

The Five Standard RefrigeratorFreezers 220 to 278 750 to 950 1.64 5.60 

176 to 205 600 to 700 1.60 5.45 

Auto Defrost Upright Freezers 250 to 278 850 to 950 1.64 5.60 

Manual Defrost Upright Freezers 161 to 176 550 to 600 1.51 5.15 

Manual Defrost Chest Freezers 147 to 161 500 to 550 1.45 4.95 

Compacts 

117 400 1.38 4.70 

103 350 1.26 4.30 

59 200 1.04 3.55 

41 140 0.76 2.6 

Source: DOE, 1995 TSD. 

* Performance based on ASHRAE rating conditions. Performance based on the use of refrigerant R-134a. 

More recent compressor performance data was collected as part of the engineering 

analysis, and the results of this investigation is presented in Chapter 5. The highest efficiency 

single-speed compressors available for standard-size refrigerator-freezers have EER near 6.25 

Btu/hr-W. 

Improved Compressor Efficiency 

Conversion to high-efficiency compressors is fairly straightforward for manufacturers to 

implement as long as the appropriate compressors are available. As indicated above, maximum 

efficiencies for compressors that are utilized in the most common types of U.S. refrigeratorfreezers range to near 6.25 Btu/hr-W. 

Variable-Speed Compressors 

Variable-speed compressors allow efficiency improvement as compared to single-speed 

compressors since they can provide a better match of thermal loads during the vast majority of 

hours when the loads are low. Most of the time, the compressor would operate at low speed with 

a high percentage of on-time. This would lower energy consumption by reducing off-cycle losses 

and by allowing the heat exchangers to operate with lower mass flow, thus boosting their 

effectiveness. However, careful consideration must be given to how variable speed compressors 

are implemented, because increased fan run times could negate compressor energy savings. 

Electronics are used by variable-speed compressors to vary the speed. They use either inverterdriven induction motors or permanent magnet motors. Most U.S. residential refrigeration 

products do not currently use variable-speed compressors, but the use of these compressors is 

becoming more common. 

Various past studies have illustrated a range of energy savings achievable through use of 

variable speed compressors. Arthur D. Little reported savings of approximately 25 percent 

compared to single-speed motor systems in 1999.66 Research conducted by Tecumseh Products 

Company demonstrated that energy savings of 15 percent as well as reduction of sound and 

3-58 

EERE-2008-BT-STD-0012 COMMENT 22
vibration levels.67 Simulation analyses conducted at the University of Illinois demonstrated that 

steady-energy savings ranging from four to 14 percent could be realized through the use of a 

two-speed compressor in concert with multiple-speed evaporator and condenser fans. The 

research also demonstrated that an additional 0.5 to four percent in energy consumption could be 

saved through the reduction of cycling frequency, i.e. the number of starts.68 

Embraco has developed its third generation variable-speed compressor that utilizes a 

permanent magnet motor controlled by a programmable electronic unit.69 Table 3.3.9 presents 

the rated performance of some of Embraco’s variable-speed compressors. The rated efficiencies 

of these variable-speed compressors are not necessarily higher than the best efficiencies of 

single-speed compressors--evaluation of the benefits of variable-speed compressors requires 

consideration of the system performance rather than just rated performance. 

Table 3.3.9 Efficiencies of Some of Embraco’s Variable-Speed Compressor Models 

Model 

Capacity Range* Efficiency* 

W Btu/hr COP EER 

VEGY6H (1600-4500 

revolutions per minute (rpm)) 98 – 281 676 – 959 Up to 1.78 Up to 6.07 

VEGY7H (1600-4500 rpm) 111 – 314 379 – 1071 Up to 1.81 Up to 6.18 

VEGY8C (1600-4000 rpm) 132 – 319 450 – 1088 Up to 1.79 Up to 6.11 

Source: Embraco, 2006. 

* Performance based on ASHRAE rating conditions. Models utilize refrigerant R-134a. 

Linear Compressors 

Linear compressors employ a different design than either reciprocating or rotary 

compressors and are reportedly more efficient than either. These compressors use a linear rather 

than rotary motor, thus eliminating the crankshaft and linkage which converts the rotary motion 

to the linear motion of the piston of a reciprocating compressor. Elimination of the mechanical 

linkage reduces friction and side-forces. The linear motor requires power electronics and a 

controller to assure proper piston throw. Most linear compressor designs use a free piston 

arrangement and can be controlled for a range of capacities through adjustment of piston 

displacement. Early work on the concept suggested that the compressors can operate without 

requiring oil, which could provide additional energy benefit by improving heat transfer in the 

evaporator. Refrigerator noise levels can also be reduced by utilizing linear compressors in the 

same way that this can be done with variable-speed compressors, by operating most of the time 

at low capacity.70 

An early version of the linear compressor design was developed by Sunpower for 

integration into refrigerators for the European market using isobutene (R-600a) as a refrigerant.71 

LG has developed a linear compressor for household refrigerators which does require use of oil. 

LG claims that its line of linear compressors is up to 20 percent more efficient than reciprocating 

designs.72 Table 3.3.10 presents the rated efficiencies of LG’s linear compressors.73 LG reports 

the efficiency of its linear compressors only at “LG Reference Conditions,” which are 

significantly different than the ASHRAE rating conditions. Under ASHRAE conditions, 

compressors are rated with evaporating and condensing temperatures of -10oF (-23.3oC) and 

130oF (54.4oC), respectively, while the “LG Reference Conditions” are based on evaporating and 

3-59 

EERE-2008-BT-STD-0012 COMMENT 22
condensing temperatures of -14.8oF (-26oC) and 100.4oF (38oC), respectively. It is not clear what 

the liquid and suction vapor temperatures for the LG conditions are—these temperatures also 

impact capacity and power input. At the same evaporating and condensing temperatures and with 

liquid and suction vapor conditions consistent with the ASHRAE test conditions, a high 

efficiency rotating-shaft reciprocating compressor such as the Embraco EGX70HLC would have 

an operating EER of about 6.9 Btu/hr-W. Hence, the LG linear compressor may be about 9% 

more efficient than the best current-technology rotating-shaft reciprocating compressors. 

Table 3.3.10 Efficiencies of LG’s Current Linear Compressor Models 

Model 

Capacity Range* Efficiency* 

W Btu/hr COP EER 

DLF81LACT 310 1058 2.14 7.3 

FA81LACT 293 1000 2.20 7.5 

FA72LACT 276 941 2.20 7.5 

FA63LACT 241 823 2.20 7.5 

FA54LACT 207 706 2.20 7.5 

Source: LG, 2007. 

* Performance based on ‘LG Reference’ rating conditions. Models utilize refrigerant R-134a. 

In the trade press, LG has expressed willingness to license the linear compressor 

technology to competitors.74 However, because the LG design is proprietary, the widespread use 

of linear compressors is uncertain. 

3.3.2.5 Evaporator 

The evaporator is a key component of the refrigeration system. As discussed earlier in 

section 3.11.2, there are three basic evaporator designs depending on the refrigeration product: 

standard-size refrigerator-freezers and upright freezers with automatic defrost typically use a 

forced-convection finned-tube design; compact refrigerators and refrigerator-freezers and smallsize standard refrigerator-freezers generally use a roll-bond design; and chest freezers and 

upright freezers with manual defrost typically use a coil design that is integrated within the walls 

of the unit. Some manual defrost freezers also use evaporators which are integrated with the wire 

shelving. In the case of the finned-tube designs used in standard-size refrigerator-freezers, 

design, modeling, and experimental studies have been conducted to evaluate their heat transfer 

performance.75, 76 Evaporator performance can be enhanced by increasing the heat exchanger 

surface area or improving the heat exchange performance. 

Increased Surface Area 

Increasing the heat exchanger surface area can be achieved by increasing the face area of 

the evaporator or adding more tube rows. These measures are limited by the geometry of the 

refrigeration product. There is a tradeoff between increasing the volume occupied by the heat 

exchanger and reducing the interior volume of the refrigerator. 

In its 1995 TSD, DOE considered increasing the evaporator surface area for most of the 

product classes analyzed; this resulted in an estimated one to two percent reduction in annual 

energy consumption.53 In the 1995 TSD, DOE based cost and efficiency improvements for this 

3-60 

EERE-2008-BT-STD-0012 COMMENT 22
technology on estimates by manufacturers. No details were provided on how exactly the 

evaporator surface area was increased. Therefore, it is uncertain to what extent design efforts to 

increase the evaporator surface area have been employed in current U.S. refrigerator-freezer 

designs. 

Improved Heat Exchange 

Improving heat exchanger performance can be achieved through the use of enhanced fins 

and/or tubes. These types of fin and tube enhancements are common in air-conditioning 

applications where slit and louvered designs are used to enhance the fin surface and different 

types of internally-grooved surfaces are used to enhance the tubing. In its 1995 TSD, DOE 

considered enhancing the evaporator’s heat exchange performance for many of the product 

classes analyzed; this resulted in an estimated one to two percent reduction in annual energy 

consumption.53 In the 1995 TSD, DOE based cost and efficiency improvements for this 

technology on estimates by manufacturers. No details were provided on how exactly the 

evaporator heat exchange performance was enhanced. Therefore, it is uncertain to what extent 

design efforts to enhance the evaporator heat exchange performance have been employed in 

current U.S. refrigerator, refrigerator-freezer, and freezer designs. 

Heat exchanger technologies that could potentially improve evaporator performance are 

microchannel heat exchangers, electrohydrodynamic enhancement, and the adoption of phasechange materials. In the case of microchannel heat exchangers, past research has demonstrated 

that the use of such heat exchangers in domestic refrigerators can provide system efficiencies 

comparable to current technologies while reducing refrigerant charge.77 Electrohydrodynamic 

enhancement employs high-voltage fields to improve the heat exchange performance. However, 

safety issues involved in using such high voltages in domestic appliances have not yet been 

resolved. In addition, no prototypes are available to test and evaluate this technology for 

domestic refrigerators and freezers. Finally, with regard to phase-change materials, Thomson (a 

French manufacturer) has integrated into its heat exchangers a phase-change material that 

enables higher average evaporation temperatures than conventional designs, thereby yielding 

energy savings.55 It is unclear for any of these technologies whether they will ever achieve 

widespread use in refrigerator-freezers. 

Research has also been conducted on the use of a ground-source heat exchanger as a 

means of rejecting heat from the cabinet and improving the efficiency of a refrigerator-freezer. 

Although the use of such a design reduced energy consumption considerably, it is likely not 

practical for most domestic refrigeration products.78 

3.3.2.6 Condenser 

The condenser, like the evaporator, is a key component of the refrigeration system and is 

located on the outside of the unit. As discussed in section 11.1.2, there are three basic condenser 

designs depending on the refrigeration product: Standard-size refrigerator-freezers typically use a 

forced-convection finned-tube design; compact refrigerators and refrigerator-freezers generally 

use a wire-and-tube “static” design which uses natural convection cooling; and freezers typically 

use a hot wall condenser that is integrated within the shell of the unit. In the case of the static 

condensers used in compact units, modeling studies have been conducted to evaluate their heat 

3-61 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

transfer performance.79 Modeling studies have also been performed on hot-wall condensers.80, 81 

Condenser performance can be enhanced by increasing the heat exchanger surface area or 

improving the heat exchange performance. 

Increased Surface Area 

Increasing the heat exchanger surface area can be achieved by increasing the face area of 

the condenser or adding more tube rows. These measures can be limited by the geometry of the 

refrigeration product. There may be a tradeoff between increasing the volume occupied be by the 

heat exchanger and reducing the interior volume of the refrigerator. 

In its 1995 TSD, DOE considered increasing the condenser surface area for many of the 

product classes analyzed; this resulted in an estimated one to two percent reduction in annual 

energy consumption.53 In the 1995 TSD, DOE based cost and efficiency improvements for this 

technology on estimates by manufacturers. No details were provided on how exactly the 

condenser surface area was increased. Therefore, it is uncertain to what extent design efforts to 

increase the condenser surface area have been employed in current U.S. refrigerator-freezer 

designs. 

Improved Heat Exchange 

Improving heat exchanger performance can be achieved through the use of enhanced fins 

and/or tubes. These types of fin and tube enhancements are common in air-conditioning 

applications where slit and louvered designs are used to enhance the fin surface and different 

types of internally grooved surfaces are used to enhance the tubing. In its 1995 TSD, DOE 

considered enhancing the condenser’s heat exchange performance for some freezer and compact 

unit product classes; this resulted in approximately a two percent estimated reduction in annual 

energy consumption.53 In the 1995 TSD, DOE based cost and efficiency improvements for this 

technology on estimates by manufacturers. No details were provided on how exactly the 

condenser heat exchange performance was enhanced. Therefore, it is uncertain to what extent 

design efforts to enhance the condenser heat exchange performance have been employed in 

current U.S. refrigerator, refrigerator-freezer, and freezer designs. 

As with evaporators, other heat exchanger technologies could be employed to improve 

condenser performance. Microchannel heat exchangers, electrohydrodynamic enhancement, and 

the adoption of phase-change materials are all applicable to condensers, although phase-change 

materials have only been used in evaporators. It is unclear for any of these technologies whether 

they will ever achieve widespread use in refrigerator-freezers. 

The same research that investigated the use of ground-source heat exchangers as means 

of rejecting heat for the cabinet also examined its application for rejecting heat from the 

condenser. The technology was demonstrated to be effective at reducing the energy use of a 

refrigerator-freezer, but is likely not practical for most domestic refrigeration products.55 

Forced-Convection Condenser 

Most standard-size refrigerator-freezers use forced-convection condensers. In contrast, most 

standard-size freezers use hot wall condensers. The forced convection configuration can provide 

3-62 

EERE-2008-BT-STD-0012 COMMENT 22
higher heat transfer effectiveness. However, space for housing a forced convection condenser 

and its associated fan is not always available. The consideration of conversion to forcedconvection condensers will depend on whether a particular product class is designed in a way 

that allows housing of the condenser and fan in a suitable location. 

3.3.2.7 Fan and Fan Motor 

Fans are used to increase evaporator and condenser heat transfer. Because most 

refrigerator-freezers use forced-convection condensers which rely on fans for air movement, fan 

and fan-motor technology options for the condenser are applicable. However, many manualdefrost refrigerators and freezers—specifically chest freezers and small, under-counter-type 

refrigerators—use static condensers and/or natural convection evaporators and, as a result, do not 

use fans and fan motors. 

For those refrigeration products that do utilize fans, refrigerator manufacturers purchase 

fans and fan motors from outside vendors. Therefore, conversion to more-efficient fan motors 

can be accomplished relatively easily when more-efficient fans and fan motors are available. 

Fan and Fan Motor Improvements 

Evaporator can condenser fans are typically of axial design. Evaporator fan blades are 

typically either 100mm or 110mm in diameter. Because the evaporator fan and fan motor are 

located within the refrigerated cabinet and the electric energy input adds to the refrigeration load, 

more-efficient evaporator fan or evaporator fan motor designs contribute to efficiency 

improvements in two ways: (1) reducing the power consumption of the fan motor and (2) 

reducing the power consumption of the compressor due to decreased heat losses into the cabinet 

from the fan motor. 

One source of inefficiency for axial fans lies in their tendency to throw air outward. The 

Pax GroupTM has developed a fan (PAX fan) that employs streamlined blades with patented 

geometrical shapes which reportedly provide better airflow direction and improved efficiency. 

Tests performed with the PAX fan have demonstrated a reduction in fan-motor power of 23 

percent and an overall reduction in refrigerator energy consumption of 3.9 percent relative to a 

refrigerator with a typical axial fan blade design.82 However, because the PAX fan is proprietary, 

the widespread use of the design is highly uncertain. 

Before the 1993 U.S. energy efficiency standards took effect, most evaporator and 

condenser fan motors were shaded pole induction designs, with efficiencies between 10 and 15 

percent and power input of about 15 Watts (W). Higher-efficiency motor designs include 

permanent split capacitor motors (PSC) induction motors with 20 to 30 percent efficiency, and 

brushless DC motors, with near 65 percent efficiency. 

3.3.2.8 Expansion Valve 

The metering device in most household refrigerator-freezers is a capillary tube. As 

discussed above in section 11.1.1, there are two common types of capillary tubes—adiabatic and 

non-adiabatic. In the non-adiabatic configuration, the capillary tube is soldered to the suction line 

3-63 

EERE-2008-BT-STD-0012 COMMENT 22
to evaporate the residual liquid in the suction line and to warm the vapor to near-ambient 

temperature. The suction line heat exchanger (or the non-adiabatic capillary) improves efficiency 

because it increases the refrigeration capacity of the system by the amount of heat being 

transferred from the capillary to the suction side. Non-adiabatic capillary tubes are the most 

common type of metering device in refrigerator-freezers. The other type of metering device, an 

adiabatic capillary tube, is used in some refrigeration products. In this configuration, the 

capillary tube does not exchange heat with the suction line and the refrigerant expands from the 

high pressure to the low pressure adiabatically. Research has been conducted to develop models 

to study the performance of both types of capillary tubes.83, 84 

Improved Expansion Valve 

Automatic, adjustable thermostatic or electronic expansion valves may provide improved 

performance. The technology for this design option is available; however, a modification in 

system design is required. DOE has not be able to identify any data demonstrating that improved 

expansion valves will save energy in domestic refrigerators. 

3.3.2.9 Cycling Losses 

Off-cycle refrigerant migration reduces a refrigeration product’s efficiency by 

transferring heat from outside the cabinet into the evaporator. Changes in refrigerator design that 

reduce this aspect of cycling losses can increase the unit’s efficiency. 

Fluid Control or Solenoid Valve 

A fluid control or solenoid valve installed after the condenser to effectively isolate the 

evaporator from the condenser during the off-cycle can be used to prevent any refrigerant 

migration. Research has demonstrated that solenoid valves can yield substantial energy 

savings.85 However, there are drawbacks to using solenoid valves. First, refrigeration migration 

allows the system pressure to equalize, reducing the required starting torque of the compressor 

motor. A solenoid valve would increase the required starting torque of the compressor motor. 

Second, adding such a valve could negatively affect system reliability. 

3.3.2.10 Defrost System 

Section 3.11.1.2 provides a description of typical automatic defrost systems for 

refrigerator-freezers. Most units use electric heaters to defrost the ice buildup on the evaporator 

located in the freezer section of a refrigerator-freezer. Energy use associated with defrost 

includes the energy input for the heater and also the refrigeration system energy used to remove 

the defrost heat from the cabinet. 

Reduced Energy for Automatic Defrost 

In some cases, the defrost heat supplied is more than required. Thus, energy savings can 

be achieved by reducing the defrost heat by either using a smaller heater, reducing the heater ontime, reducing the frequency of defrost, or a combination of these. 

In its 1995 TSD, DOE found that most manufacturers had already significantly reduced 

the electric heat for auto defrost in order to comply with the energy efficiency standards that 

3-64 

EERE-2008-BT-STD-0012 COMMENT 22
became effective in 1993.53 There may be limited additional energy savings possible through 

optimization of automatic defrost. 

Adaptive Defrost 

To reduce the energy used for defrost, adaptive defrost can be used. An adaptive defrost 

system can control both the defrost time and the amount of defrost heat. Adaptive defrost 

systems make use of controls to adjust the time between defrost cycles to the appropriate amount 

for the door opening frequency, ambient conditions, and other consumer usage patterns which 

affect the introduction of moisture into the cabinet. In a typical automatic defrost system, a 

mechanical timer initiates defrost after a specified time period, usually 10 to 12 hours of 

compressor on-time. By allowing adjustment of the time between defrosts, energy use can be 

reduced. The DOE energy test procedure includes modified test procedures for evaluating the 

energy use of products with adaptive defrost. In its 1995 TSD, DOE estimated that energy 

consumption can be reduced by three to four percent with adaptive defrost.53 It is unclear what 

percentage of the refrigerator market currently uses adaptive defrost. 

Condenser Hot Gas 

Another method of reducing the energy required for defrost is to eliminate the need for 

electric heaters by substituting condenser hot gas in their place. In a condenser hot gas defrost 

system, the compressor continues to run and a valve opens allowing hot compressed refrigerant 

to flow to the evaporator. Many frost-free refrigerator-freezers in the 1960s and 1970s used such 

a defrost system. 

3.3.2.11 Control System 

The control systems discussed here pertain to those controlling the temperature and airdistribution within the refrigeration product. 

Temperature Control 

Conventional thermostats are thermomechanical devices that are not very accurate. The 

inaccuracy of these devices may produce large temperature fluctuations within the cabinet and, 

in turn, thermodynamic inefficiencies. Electronic thermostats are available that can provide more 

precise and repeatable temperature control than conventional thermostats. This can result in 

improved efficiency. Electronic thermostat systems can also account for more parameters than 

just the cabinet temperature, such as the room temperature, to better regulate product operation 

and reduce compressor run times. 

Air-Distribution Control 

 For refrigerator-freezers, better air distribution between the freezer and fresh food 

compartments can improve temperature control and reduce energy consumption. Improving the 

distribution of cold air within the refrigerator-freezer allows the temperature difference between 

the air and foodstuffs to be minimized, enabling the evaporation temperature to be raised and, 

thereby, reducing energy consumption. It is uncertain to what degree the air distribution control 

in current refrigerator-freezer models can be improved. However, the fact that several patents 

3-65 

EERE-2008-BT-STD-0012 COMMENT 22
 

have been issued in the U.S. since 1995 regarding air distribution implies that improvements in 

air distribution control are possible.55 

3.3.2.12 Other Technologies 

Alternative refrigerants and changing the location of refrigeration components can also 

improve the efficiency of refrigeration products. These two technology options are discussed 

below. 

Alternative Refrigerants 

Through the 1980s, CFC-12, a chlorofluorocarbon, was used as the refrigerant in almost 

all refrigerators, refrigerator-freezers, and freezers. However, under the Montreal Protocol, all 

CFCs were banned from use by the mid-1990s due to their high ozone depletion potential (ODP). 

In the early 1990s, many alternative refrigerants were evaluated as a replacement for CFC-12. Of 

the alternatives considered, the industry settled on HFC-134a as the replacement for CFC-12. 

Although initial research demonstrated that HFC-134a as a drop-in replacement yielded 

efficiencies which were four to 10 percent less than CFC-12, further work showed that with the 

appropriate superheat and subcooling taken into consideration, HFC-134a could yield essentially 

equivalent system efficiencies as CFC-12.86 

Because HFC-134a exhibits some global warming potential (GWP), research continued 

to find an alternative refrigerant with less or no GWP. For example, R-152a has a lower GWP 

than HFC-134a but, primarily due to flammability concerns and the potential liability issues it 

posed to refrigerator manufacturers, it was dismissed as a potential alternative. 

Naturally occurring substances such as carbon dioxide, ammonia, and hydrocarbons are 

all considered to be environmentally safe refrigerants with very low GWP. Hydrocarbons in 

particular are attractive due to their similar thermodynamic properties to CFC-12. Much research 

has been conducted showing the efficiency benefits of hydrocarbons. For example, the 

performance of propane/isobutane and propane/butane mixtures in domestic refrigerators has 

been shown to be equal to or better than products using CFC-12.87, 88 Hydrocarbon flammability 

has been pointed out as a significant drawback and has prevented their adoption in U.S. products. 

In contrast, European refrigerator manufacturers started manufacturing products with isobutane 

in the 1990s. However, recently the General Electric Company announced the intention to 

introduce this refrigerant in the U.S.89 

Component Location 

In its 1995 TSD, DOE saw energy savings potential in more optimal placement of certain 

components. For example, if the compressor and condenser are located on the top of the 

refrigerator-freezer, DOE determined that they can operate more efficiently because heat is more 

readily convected away from the system and, in addition, the condenser fan can be eliminated. 

As described previously, traditionally, the compressor and condenser are located at the bottom 

rather than the top of the refrigerator-freezer so the user can have easy access to the food 

compartments, to key center of gravity low, and to provide air flow and a heat source near the 

tray which collects defrost water to assure quick re-evaporation of water. Locating the condenser 

and compressor at the top of the unit would require modification of traditional practice and 

3-66 

EERE-2008-BT-STD-0012 COMMENT 22
 

consumer preference. It would also require product redesign, which could potentially increase 

manufacturing costs. 

Another option is to locate the evaporator fan motor outside the cabinet to reduce internal loads 

from the heat loss of the motor. However, it is difficult to prevent air leakage where the motor 

shaft penetrates the cabinet wall. The 1995 TSD concluded that the lack of experimental data 

prevented the evaluation of component relocation.53 

3.3.2.13 Alternative Refrigeration Cycles 

Alternative refrigeration cycles may have the potential to improve system efficiency. 

Several alternative refrigeration cycles for refrigerator-freezers are described below. Dual-loop 

refrigerator-freezers using two independent refrigeration cycles (one for the fresh food 

compartment and the other for the freezer compartment) are available on the market. Also, dualevaporator units likely utilizing a control valve system are also being marketed. The other 

alternatives listed below have been demonstrated in prototypes to reduce energy consumption but 

it is uncertain as to whether they can be mass produced as a practical alternative to today’s 

current conventional refrigeration systems. 

Lorenz-Meutzner Cycle 

In a conventional refrigerator-freezer, the temperature of the freezer and fresh food 

compartments are around 5oF (-15oC) and 38oF (3.3oC), respectively. This suggests that the fresh 

food compartment with a smaller temperature lift (i.e., the temperature difference between the 

evaporator and condenser) can operate with a higher efficiency than that of the freezer. By using 

zeotropicg

 refrigerant mixtures, the Lorenz-Meutzner cycle exploits the inherent thermodynamic 

advantages of the temperature glide exhibited during evaporation or condensation of the 

refrigerant mixture. By choosing a refrigerant mixture with very wide temperature glide, the 

refrigerant mixture can pass sequentially through the freezer and fresh food compartment 

evaporators, providing refrigeration at the two evaporating temperature levels using a single 

compressor. As compared to a conventional refrigerator-freezer, the hardware differences 

include a high-temperature evaporator for the fresh food compartment and a low-temperature 

heat exchanger between the fresh food and freezer evaporators. Lorenz and Meutzner in their 

research determined that their cycle using an R-22/R-11 refrigerant mixture (50 percent of each) 

achieved up to 20 percent energy savings compared to a conventional refrigerator-freezer using 

R-12 only.90 

Subsequent research validated Lorenz and Meutzner’s findings and demonstrated the 

viability of the cycle based on the use of different zeotropic refrigerant mixtures, including 

mixtures composed of hydrocarbons. For example, as compared to a conventional refrigeratorfreezer, experimentation on an 18 ft3 top-mount refrigerator-freezer demonstrated that a modified 

g

 A zeotropic mixture consists of two or more refrigerant components. Zeotropic mixtures have what is referred to as 

a temperature glide when they boil and condense: at a fixed pressure, the temperature is higher for higher quality 

(i.e. vapor fraction). Unlike zeotropes, azeotropic mixtures consist of two or more refrigerant components that 

behave like a single refrigerant, exhibiting no temperature glide. 

3-67 

EERE-2008-BT-STD-0012 COMMENT 22
 

Lorenz-Meutzner cycle yielded 16.6 percent, 14.6 percent, and 16.7 percent energy savings with 

binary mixtures of R-22/R-123, propane/n-pentane, and propane/n-butane, respectively.91 

Because the industry settled on the use of HFC-134a to replace CFC-12, interest in the 

Lorenz-Meutzner cycle as an alternative to conventional refrigeration cycles declined. 

Dual-Loop System 

One of the best methods to reduce the thermodynamic irreversibilities resulting from the 

operation with a single evaporator in a refrigerator-freezer is to employ two separate 

refrigeration cycles. This system, referred to as a dual-loop system, has two completely separate 

refrigeration cycles which provide cooling for the freezer and fresh food compartments 

independently. In practice, the theoretical benefits of such a cycle are not achieved due to the use 

of two compressors that are smaller and less efficient than the original single compressor. Also, 

dual-loop systems are physically larger and would either increase the product’s external 

dimensions or decrease the usable refrigerator volume. 

Research has demonstrated that the energy savings due to a dual-loop system are a 

function of the cabinet load ratio (defined as the ratio of the fresh food to the freezer cabinet 

loads) and the ratio of the freezer and refrigerator cycle efficiencies. Depending on these two 

parameters, a dual-loop system using HFC-134a can reduce energy consumption by up to 30 

percent compared to a conventional refrigerator-freezer.92 

There are numerous products currently on the market that incorporate dual-compressor 

systems, including Bosch’s Integra line of bottom-mount refrigerator-freezers,93 Sun Frost’s 

RF19 model,94 Northland’s 48-inch side-mount refrigerator-freezer,95 Sub-Zero’s built-in line of 

refrigerator-freezers,96 Liebherr refrigerators,97 etc. 

Two-Stage System 

The two-stage system employs one condenser, two evaporators, two compressors, and at 

least one suction-line heat exchanger. The increased efficiency of this system over a 

conventional system is obtained due to a smaller work requirement that results from the lowpressure ratio for each of the two compressors.98 The two-stage system offers the advantage of 

having one fewer component (a condenser) than the dual-loop system, but has many of the same 

disadvantages (e.g., either increased external dimensions or decreased internal volume). 

Control Valve System 

The control valve system has two evaporators, one for the fresh food compartment and 

one for the freezer compartment, but only one compressor and one condenser. Two different 

length capillary tubes and a control valve are installed between the fresh food and freezer 

evaporator inlets and the condenser outlet. The valve directs the flow of the refrigerant through 

one of the evaporators at a time. That is, only one of the two compartments is cooled at any 

given time. With this configuration, the fresh food compartment is cooled at a higher evaporator 

temperature than the freezer compartment. Experimental research conducted on this system 

configuration indicated that the energy efficiency can be improved by 8.5 percent over that of a 

conventional refrigerator-freezer.99 

3-68 

EERE-2008-BT-STD-0012 COMMENT 22
GE offers a refrigerator-freezer system called the ClimateKeeper2TM system that uses two 

evaporators.100 Also, KitchenAid and Jenn-Air both offer under-counter compact refrigeratorfreezers that use dual evaporators.101 102 The system details of none of these products is clearly 

described in the product literature. 

Ejector Refrigerator 

One of the intrinsic losses in a conventional refrigeration cycle is the throttling of the 

refrigerant in the capillary tube. Throttling is an isenthalpic process in which work that could be 

extracted in the expansion process is not captured. In the ejector refrigerator, some of this work 

can be captured and used to raise the pressure of refrigerant entering the compressor above that 

of the evaporator. Simulation research has been conducted on an ejector refrigerator that consists 

of one compressor, one condenser, two capillary tubes, two evaporators (one for the fresh food 

compartment and the other for the freezer compartment), and an ejector. In this refrigerator, 

saturated liquid refrigerant exits the condenser and expands in the capillary tube to the fresh food 

evaporator. In the fresh-food compartment, the refrigerant is partially evaporated. At the outlet of 

the evaporator, the liquid refrigerant is separated from the vapor in a separator. The vapor flows 

to the ejector, where it is accelerated to high velocity. The liquid expands in a second capillary 

tube to the freezer evaporator, where it evaporates entirely. The vapor leaving the freezer 

evaporator is entrained in the high-velocity flow of the vapor which left the fresh food 

evaporator. The mixed flow is decelerated to increase its pressure. The mixed flow higher 

pressure flow passes to the compressor suction port to be compressed. This particular ejector 

refrigerator was shown to have an efficiency which is 12.4 percent higher than a conventional 

refrigerator-freezer.103 

Tandem System 

Like the control valve system and the ejector refrigerator, the tandem system uses two 

evaporators (one for the fresh food compartment and another for the freezer compartment), one 

condenser, and one compressor. Refrigerant flows in series first through the fresh food 

evaporator, then the freezer evaporator, and it passes a second time through the fresh food 

evaporator. The warm liquid refrigerant leaves the condenser and flows to fresh food evaporator 

without a first expansion. In the fresh food evaporator the refrigerant liquid undergoes heat 

exchange with the evaporating refrigerant which has passed through the freezer evaporator. The 

temperature of the liquid is reduced by this heat exchange. The liquid then passes through the 

capillary tube where its pressure is reduced. The two-phase refrigerant then passes through the 

freezer evaporator and absorbs heat from the freezer compartment. This vaporization process 

only occurs when the freezer evaporator fan is turned on by the freezer thermostat. The 

refrigerant then passes back through the fresh food evaporator. Here, if the refrigerant has not 

already been vaporized (i.e., the freezer compartment does not require cooling), it vaporizes as a 

result of absorbing heat from the fresh food compartment and the warm liquid. The superheated 

refrigerant then flows to the compressor suction port. At the beginning of the compressor run, the 

fresh-food compartment fan is turned on first. Thus, the fresh food compartment is cooled before 

the system reaches steady state. As a result, the system uses the pull-down period of each cycle, 

which is generally not suitable for cooling the freezer, to cool the fresh food compartment. This 

particular tandem system was shown to reduce energy use by 18 percent compared to a 

conventional refrigerator-freezer.104 

3-69 

EERE-2008-BT-STD-0012 COMMENT 22
3.3.2.14 Alternative Refrigeration Systems 

Alternative refrigeration systems do not use vapor compression to provide refrigeration. 

Three alternative refrigeration systems are discussed below: the Stirling cycle, thermoelectric 

cooling, and thermoacoustic cooling. Although research and development has been conducted on 

each of these systems, and thermoelectric compact refrigerators and wine coolers are currently 

being marketed, none are a viable alternative for standard-size refrigerators, refrigerator-freezers, 

and freezers. 

Stirling Cycle 

A Stirling-cycle machine is a device that operates on a closed regenerative 

thermodynamic cycle, with cyclic compression and expansion of the working fluid at different 

temperature levels, and where the flow is controlled by volume changes, so that there is a net 

conversion of heat to work or vice versa. ‘Regenerative’ refers to the use of an internal heat 

exchanger, the regenerator, which is an essential part of the Stirling cycle. A Stirling 

refrigeration cycle compresses and expands an inert gas in a single cylinder. Heat is rejected at 

one end of the cylinder and absorbed at the opposite end. In the absence of all thermodynamic 

losses, the efficiency could be higher than for vapor compression systems, but there are various 

technical difficulties that have so far limited the use of Stirling-cycle cooling to small prototype 

domestic refrigerators. There is no circulating refrigerant fluid and the hot and cold heat areas are 

relatively small, which creates heat exchange challenges for any but the lowest-capacity systems. 

Thermoelectric 

Thermoelectric cooling occurs when a current is passed across the junction of two 

dissimilar metals. One side of the device becomes hot and the other cold. Materials 

(semiconductors) have relatively recently been developed that have allowed for the use of this 

type of cooling in some applications. Thermoelectric cooling devices have no moving parts, do 

not age, and have extremely long lifetimes. There are several compact refrigerators and wine 

coolers using thermoelectric cooling that are being marketed, including several models offered 

by Avanti Products.105 However, they have very low efficiency and are not yet suitable for 

standard-size domestic refrigerator-freezers. 

Thermoacoustic 

Acoustic cooling uses a sound generator inside a closed tube to vibrate a gas and cause 

alternate compression and expansion and therefore heating and cooling. The efficiency of 

prototypes have not been as high as vapor compression systems and the devices have been 

physically large for the amount of cooling produced. 

3.3.3 Energy Efficiency 

DOE gathered data on the energy efficiency of residential refrigerators, refrigeratorfreezers, and freezers currently available in the marketplace. DOE created a database of the 

current models by surveying manufacturers’ websites. The data provide an overview of the 

energy efficiency of each product class covered by this rulemaking. 

3-70 

EERE-2008-BT-STD-0012 COMMENT 22
For the models in the DOE database, Figure 3.3.3 through Figure 3.3.22 present by 

product class the relationship between rated annual energy use and adjusted volume. In each 

figure, lines representing the maximum allowable energy consumption (i.e., the current 

minimum efficiency standard) and the current ENERGY STAR level (that took effect in April 

2008 for standard-size refrigerators and refrigerator-freezers), are provided. This allows for a 

quick visual inspection of the number of models that met the ENERGY STAR level. 

The data representing all-refrigerators are highlighted in the figures for product classes 1, 

3, 11, and 13. For product classes 1 and 11, the products which are not all-refrigerators could be 

either basic refrigerators or manual defrost refrigerator-freezers. For product classes 3 and 13, 

the products which are not all-refrigerators are refrigerator-freezers. The percentage of allrefrigerators is high for product class 11 and very high for product class 13. 

The DOE survey found no current models in product class 6, top-mount refrigeratorfreezers with through the door ice and with automatic defrost. DOE still provides a figure for this 

class (Figure 3.3.9) to show the maximum allowable energy consumption for this product class. 

Many of the other product classes also have few products. 

3-71 

EERE-2008-BT-STD-0012 COMMENT 22
0 

100 

200 

300 

400 

500 

600 

700 

800 

0 5 10 15 20 25 30 35 40 

Annual Energy Consumption (kWh/yr) 

Federal Minimum Standard 

Energy Star 

Other Refrigerators 

All-Refrigerators 

Adjusted Volume (ft3) 

Figure 3.3.3 Annual Energy Consumption for Refrigerators and Refrigerator-Freezers 

with Manual Defrost (Product Class #1) 

800
 

700
 

Annual Energy Consumption (kWh/yr) 600
 

500
 

400
 

300
 

200
 

100
 

0
 

Federal Minimum Standard 

Energy Star 

0 5 10 15 20 25 30 35
 

Adjusted Volume (ft3) 

Figure 3.3.4 Annual Energy Consumption for Refrigerator-Freezers with Partial 

Automatic Defrost (Product Class #2) 

3-72
 

40 

EERE-2008-BT-STD-0012 COMMENT 22
Annual Energy Consumption (kWh/yr) 

800 

700 

600 

500 

400 

300 

0 

100 

200 

0 5 10 15 20 25 

Adjusted Volume (ft3) 

30 35 40 

Federal Minimum Standard 

Energy Star 

Refrigerator-Freezers 

All-Refrigerators 

Figure 3.3.5 Annual Energy Consumption for Top-Mount Refrigerator-Freezers with 

Automatic Defrost without TTD Ice Service and All-Refrigerators with Automatic Defrost 

(Product Class #3) 

800 

700 

Annual EnergyConsumption (kWh/yr) 

600 

500 

400 

300 

200 

0 

100 

0 5 10 15 20 25 

Adjusted Volume (ft3) 

30 35 

Federal Minimum Standard 

Energy Star 

40 

Figure 3.3.6 Annual Energy Consumption for Side-Mount Refrigerator-Freezers with 

Automatic Defrost without TTD Ice Service (Product Class #4) 

3-73 

EERE-2008-BT-STD-0012 COMMENT 22
0 

100 

200 

300 

400 

500 

600 

700 

800 

Annual Energy Consumption (kWh/yr) 

Federal Minimum Standard 

Energy Star 

0 5 10 15 20 25 30 35 40
 

Adjusted Volume (ft3) 

Figure 3.3.7 Annual Energy Consumption for Bottom-Mount Refrigerator-Freezers with 

Automatic Defrost without TTD Ice Service (Product Class #5) 

800
 

700
 

Annual Energy Consumption (kWh/yr) 600
 

500
 

400
 

300
 

200
 

100
 

0
 

Federal Minimum Standard 

Energy Star 

0 5 10 15 20 25 30 35
 40
 

Adjusted Volume (ft3) 

Figure 3.3.8 Annual Energy Consumption for Bottom-Mount Refrigerator-Freezers with 

Automatic Defrost with TTD Ice Service (Product Class 5A) 

3-74 

EERE-2008-BT-STD-0012 COMMENT 22
           

   

0 

100 

200 

300 

400 

500 

600 

700 

800 

Annual Energy Consumption (kWh/yr) 

Federal Minimum Standard 

Energy Star 

No current products within this class

could be found.

0 5 10 15 20 25 30 35 

Adjusted Volume (ft3) 

Figure 3.3.9 Annual Energy Consumption for Top-Mount Refrigerator-Freezers with 

Automatic Defrost with TTD Ice Service (Product Class #6) 

800 

700 

Annual Energy Consumption (kWh/yr) 600 

500 

400 

300 

200 

100 

0 

Federal Minimum Standard 

Energy Star 

0 5 10 15 20 25 30 35 

Adjusted Volume ft3) 

Figure 3.3.10 Annual Energy Consumption for Side-Mount Refrigerator-Freezers with 

Automatic Defrost with Through-the-Door Ice Service (Product Class #7) 

3-75 

40 

40 

EERE-2008-BT-STD-0012 COMMENT 22
0 

100 

200 

300 

400 

500 

600 

700 

800 

900 

0 5 10 15 20 25 30 35 40 45 

Annual Energy Consumption (kWh/yr) 

Federal Minimum Standard 

Energy Star 

Adjusted Volume (ft3) 

Figure 3.3.11 Annual Energy Consumption for Upright Freezers with Manual Defrost 

(Product Class #8) 

900
 

800
 

Annual Energy Consumption (kWh/yr) 

700 

600 

500 

400 

300 

200 

100 

0 

Federal Minimum Standard 

Energy Star 

0 5 10 15 20 25 30 35 40 45 

Adjusted Volume (ft3) 

Figure 3.3.12 Annual Energy Consumption for Upright Freezers with Automatic Defrost 

(Product Class #9) 

3-76 

EERE-2008-BT-STD-0012 COMMENT 22
0 

100 

200 

300 

400 

500 

600 

700 

800 

900 

Annual Energy Consumption (kWh/yr) 

Federal Minimum Standard 

Energy Star 

0 5 10 15 20 25 30 35 40 45 

Adjusted Volume (ft3) 

Figure 3.3.13 Annual Energy Consumption for Chest Freezers and all other Freezers 

except Compact Freezers (Product Class #10) 

900 

800 

Annual Energy Consumption (kWh/yr) 700 

600 

500 

400 

300 

200 

100 

0 

Federal Minimum Standard 

Energy Star 

0 5 10 15 20 25 30 35 40 45 

Adjusted Volume (ft3) 

Figure 3.3.14 Annual Energy Consumption for Chest Freezers with Automatic Defrost 

(Product Class #10A) 

3-77 

EERE-2008-BT-STD-0012 COMMENT 22
0 

100 

200 

300 

400 

500 

600 

Annual Energy Consumption (kWh/yr) 

Federal Minimum Standard 

Energy Star 

All-Refrigerators 

Other Refrigerators 

0 2 4 6 8 10 12 14 

Adjusted Volume (ft3) 

Figure 3.3.15 Annual Energy Consumption for Compact Refrigerators and RefrigeratorFreezers with Manual Defrost (Product Class #11) 

600 

Annual Energy Consumption (kWh/yr) 500 

400 

300 

200 

100 

0 

Federal Minimum Standard 

Energy Star 

0 2 4 6 8 10 12 14 

Adjusted Volume (ft3) 

Figure 3.3.16 Annual Energy Consumption for Compact Refrigerator-Freezers with 

Partial Automatic Defrost (Product Class #12) 

3-78 

EERE-2008-BT-STD-0012 COMMENT 22
0 

100 

200 

300 

400 

500 

600 

Annual Energy Consumption (kWh/yr) 

Federal Minimum Standard 

Energy Star 

All-Refrigerators 

Refrigerator-Freezers 

0 2 4 6 8 10 12 14 

Adjusted Volume (ft3) 

Figure 3.3.17 Annual Energy Consumption for Compact Top-Mount Refrigerator-Freezers 

with Automatic Defrost and All-Refrigerators with Automatic Defrost (Product Class #13) 

0 

100 

200 

300 

400 

500 

600 

Annual Energy Consumption (kWh/yr) 

Federal Minimum Standard 

Energy Star 

0 2 4 6 8 10 12 14 

Adjusted Volume (ft3) 

Figure 3.3.18 Annual Energy Consumption for Compact Side-Mount Refrigerator-Freezers 

with Automatic Defrost (Product Class #14) 

3-79 

EERE-2008-BT-STD-0012 COMMENT 22
0 

100 

200 

300 

400 

500 

600 

Annual Energy Consumption (kWh/yr) 

Federal Minimum Standard 

Energy Star 

0 2 4 6 8 10 12 14 

Adjusted Volume (ft3) 

Figure 3.3.19 Annual Energy Consumption for Compact Bottom-Mount RefrigeratorFreezers with Automatic Defrost (Product Class #15) 

600 

500 

Annual Energy Consumption (kWh/yr) 400 

300 

200 

100 

0 

Federal Minimum Standard 

Energy Star 

0 2 4 6 8 10 12 14 

Adjusted Volume (ft3) 

Figure 3.3.20 Annual Energy Consumption for Compact Upright Freezers with Manual 

Defrost (Product Class #16) 

3-80 

EERE-2008-BT-STD-0012 COMMENT 22
0 

100 

200 

300 

400 

500 

600 

Annual Energy Consumption (kWh/yr) 

Federal Minimum Standard 

Energy Star 

0 2 4 6 8 10 12 14 

Adjusted Volume (ft3) 

Figure 3.3.21 Annual Energy Consumption for Compact Upright Freezers with Automatic 

Defrost (Product Class #17) 

600 

500 

Annual Energy Consumption (kWh/yr) 400 

300 

200 

100 

0 

Federal Minimum Standard 

Energy Star 

0 2 4 6 8 10 12 14 

Adjusted Volume (ft3) 

Figure 3.3.22 Annual Energy Consumption for Compact Chest Freezers (Product Class 

#18) 

3-81 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

 

 

REFERENCES 

1	 Title 10—Energy, Chapter II—Department of Energy, Part 430—Energy Conservation 

Program for Consumer Products, Subpart A—General Provisions, Section 430.2— 

Definitions. 

2	 Energy Conservation Program for Consumer Products: Amendment to the Definition of 

“Electric Refrigerator,” Final Rule, November 19, 2001. 66 FR 57845. 

3	 Title 10—Energy, Chapter II—Department of Energy, Part 430—Energy Conservation 

Program for Consumer Products, Subpart A—General Provisions, Section 430.32—Energy 

and Water Conservation Standards and Effective Dates. 

4	 Haier America Trading, LLC. Convertible Bottom Drawer Refrigerator, Model 

PRCS25EDAS. <http://www.haieramerica.com/en/product/PRCS25EDAS> (Accessed 

September 26, 2007.) 

5	 Energy Star. Find Energy Star Qualified Refrigerator & Freezers. 

<http://www.energystar.gov/index.cfm?fuseaction=refrig.search_refrigerators> (Accessed 

September 26, 2007.) 

6	 Energy Conservation Program for Consumer Products: Decision and Order Granting a 

Waiver to the General Electric Company From the Department of Energy Residential 

Refrigerator and Refrigerator-Freezer Test Procedure, Notice of decision and order, 

February 27, 2008. 73 FR 10425. 

7	 Energy Conservation Program for Consumer Products: Decision and Order Granting a 

Waiver to Whirlpool Corporation From the Department of Energy Residential Refrigerator 

and Refrigerator-Freezer Test Procedure, May 5, 2009. 74 FR 20695. 

8	 Energy Conservation Program for Consumer Products: Decision and Order Granting a 

Waiver to Liebherr Hausgeräte From the Department of Energy Electric Refrigerator and 

Electric Refrigerator-Freezer Test Procedures, Notice of decision and order, April, 24, 2007. 

72 FR 20333. 

9	 Yashar, D.A. Repeatability of Energy Consumption Test Results for Compact Refrigerators, 

September 2000. U.S. Department of Commerce, National Institute of Standards and 

Technology, Gaithersburg, MD. NISTIR 6560. 

<http://www.fire.nist.gov/bfrlpubs/build00/PDF/b00055.pdf> 

10	 Association of Home Appliance Manufacturers. Energy, Performance and Capacity of 

Household Refrigerators, Refrigerator-Freezers and Freezers, ANSI/AHAM HRF-1-2008. 

Washington, DC. 

11	 U.S. Environmental Protection Agency. Energy Star Program Requirements for Residential 

Refrigerators and/or Freezers, August 3, 2007. Washington, DC. 

<http://www.energystar.gov/ia/partners/product_specs/program_reqs/refrig_prog_req.pdf > 

3-82
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

 

 

12	 Kosa et al., Consumer Home Refrigeration Practices: Findings from a Consumer Survey, 

presented at the American Dietetic Association Food and Nutrition Conference and Expo, 

Honolulu, Hawaii, September 16–19, 2006. 

13	 Godwin et al., “A Comprehensive Evaluation of Temperatures within Home Refrigerators,” 

Food Protection Trends (March 2007). 

14	 “The Share-of-Market Picture,” Appliance Magazine, September 1993–2006. Vols. 51–63, 

No. 9. 

15	 Maytag. “Whirlpool Corporation and Maytag Corporation Sign Definitive Merger 

Agreement,” Maytag Press Release, August 22, 2005. 

16	 Hussmann, P. “Justice to Extend Maytag-Whirlpool Merger Review,” Newton Daily News 

Online, February 14, 2006. 

17	 Ryberg, W. “Harkin, Boswell want Maytag sale blocked,” Des Moines Register, January 13, 

2006. 

18	 U.S. Department of Justice. Department of Justice Antitrust Division Statement on the 

Closing of its Investigation of Whirlpool’s Acquisition of Maytag, March 29, 2006. 

19	 Association of Home Appliance Manufacturers. Fact Book 2005—A Statistical Overview of 

the Home Appliance Industry, 2005. Washington, DC. <www.aham.org> 

20	 Consortium for Energy Efficiency. National Residential Home Appliance Market 

Transformation Strategic Plan, December 2000. Prepared by Consortium for Energy 

Efficiency Appliance Committee, Washington, DC. Appendix B. 

<http://www.cee1.org/resid/seha/seha_str_plan.pdf> 

21	 Universidade Federal de Santa Catarina, O Processo de Terceirizacao e de Qualificacao de 

Fornecedoresnorberto, Fernando Kuchenbecker, Florianópolis, Julio de 2006. 

<http://teses.eps.ufsc.br/defesa/pdf/9002.pdf> (Accessed September 26, 2007.) 

22	 Institute for Materials Science, Welding and Forming, A Small Review of Research Activities, 

Graz, Austria. 

<http://iws.tugraz.at/IWS_tree/Veranstalt/Tagungen/Download/Wtagung/IWS.pdf> 

(Accessed September 26, 2007.) 

23	 Embraco. Embraco’s path in China. Brazil. 

<http://www.bndes-exim.com/conhecimento/seminario/ElsonTeixeira%20.pdf> (Accessed 

September 26, 2007.) 

24	 California Energy Commission. Appliance Efficiency Regulations, December 2006. 

Sacramento, CA. CEC-400-2006-002-REV2. 

<http://www.energy.ca.gov/2006publications/CEC-400-2006-002/CEC-400-2006-002­

REV2.PDF> 

3-83 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

25	 Canada Gazette, Part II, Statutory Instruments 2006, November 15, 2006. Vol. 120, No. 23, 

pp. 1618 to 1875. Ottawa, Canada. <http://canadagazette.gc.ca/partII/2006/20061115/pdf/g2­

14023.pdf> 

26	 Natural Resources Canada. Canada’s Energy Efficiency Regulations, Residential Wine 

Chillers (or Wine Coolers), Final Bulletin, December 2008. Ottawa, Canada. 

<http://oee.nrcan.gc.ca/regulations/bulletin/wine-chillers-dec08.cfm?attr=4> 

27	 NOM-015-ENER-2002: Energy Efficiency of Household Refrigerators and Freezers. Limits, 

Test Methods and Labeling. Mexico Official Standard. 

<http://www.clasponline.org/productsummary.php?country=Mexico&product=Refrigerator> 

28	 Collaborative Labeling and Appliance Standards Program. S&L Worldwide Summary, 

Minimum Energy Performance Standard - Mandatory for Refrigerator-freezers Worldwide. 

<http://www.clasponline.org/productsumworldwide.php?product=Refrigerator-freezers> 

(Accessed September 26, 2007.) 

29	 European Commission. Energy. Energy Efficiency, Domestic refrigerators and freezers. 

<http://ec.europa.eu/energy/demand/legislation/eco_design_en.htm> (Accessed September 

26, 2007.) 

30	 U.S. Department of Energy. Market Analysis of Potential Changes to the ENERGY STAR 

Criteria for Refrigerators, April 27, 2007. Washington, DC. 

<http://www.energystar.gov/ia/partners/prod_development/revisions/downloads/refrig/RFCri 

teriaAnalysis_2007.pdf> 

31	 U.S. Department of Energy. Final ENERGY STAR Program Requirements and Criteria for 

Residential Refrigerators and Freezers, August 3, 2007. Washington, DC. 

<http://www.energystar.gov/ia/partners/prod_development/revisions/downloads/refrig/REF_ 

ProgramRequirements_2008.pdf > 

32	 U.S. Department of Energy and U.S. Environmental Protection Agency. ENERGY STAR, 

Refrigerators & Freezers Key Product Criteria. Washington, DC. 

<http://www.energystar.gov/index.cfm?c=refrig.pr_crit_refrigerators> (Accessed September 

26, 2007.) 

33	 Federal Energy Management Program. FEMP Designated Product: Residential 

Refrigerators. Washington, DC. 

<http://www1.eere.energy.gov/femp/procurement/eep_refrigerator.html#anchorlist> 

(Accessed September 26, 2007.) 

34	 Consortium for Energy Efficiency. CEE Super-Efficient Home Appliances Initiative, HighEfficiency Specifications for Refrigerators, Effective January 1, 2007. Boston, MA. 

<http://www.cee1.org/resid/seha/refrig/refrig-spec.pdf> (Accessed September 26, 2007.) 

3-84
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

 

35	 Emergency Economic Stabilization Act of 2008. <http://frwebgate.access.gpo.gov/cgibin/getdoc.cgi?dbname=110_cong_public_laws&docid=f:publ343.110.pdf> 

36	 Oregon Department of Energy – Conservation Division. Residential Energy Tax Credits. 

Salem, OR. <http://egov.oregon.gov/ENERGY/CONS/RES/tax/appliances.shtml> (Accessed 

September 26, 2007.) 

37	 “Statistical Review,” Appliance Magazine, April issues, 1990–1999, Vols. 50–59, No. 4 and 

May issues, 2000–2006, Vols. 60–66, No. 5. 

38	 U.S. Department of Energy-Building Technologies Program. Technical Report: Analysis of 

Amended Energy Conservation Standards for Residential Refrigerator-Freezers, August 

2005. Washington, DC. 

<http://www.eere.energy.gov/buildings/appliance_standards/pdfs/refrigerator_report_1.pdf> 

39	 The NPD Group, Inc., The NPD Group/NPD Houseworld – POS, Refrigerators, January – 

December 2004, 2005. Port Washington, NY. 

40	 Energy Star. Resources for Appliance Manufacturers and Retailers, Appliance Sales Data 

1998–2006. <http://www.energystar.gov/index.cfm?c=manuf_res.pt_appliances> (Accessed 

September 26, 2007.) 

41	 NFO World Group. Final Report: Home Appliance Saturation and Length of First 

Ownership Study, May 2001. Prepared for Association of Home Appliance Manufacturers by 

NFO World Group, Boston, MA. 

42	 U.S. Department of Energy-Energy Information Administration. Residential Energy 

Consumption Survey, 1993 Public Use Data Files, 1993. Washington, DC. 

<http://www.eia.doe.gov/emeu/recs/93publicuse.html> 

43	 U.S. Department of Energy-Energy Information Administration. Residential Energy 

Consumption Survey, 1997 Public Use Data Files, 1997. Washington, DC. 

<http://www.eia.doe.gov/emeu/recs/public.html> 

44	 U.S. Department of Energy-Energy Information Administration. Residential Energy 

Consumption Survey, 2001 Public Use Data Files, 2001. Washington, DC. 

<http://www.eia.doe.gov/emeu/recs/recs2001/publicuse2001.html> 

45	 Association of Home Appliance Manufacturers. 2005 Major Appliance Saturation & 

Marketing Factors Study, 2005. Washington, DC. 

<http://www.aham.org/ht/d/Store/name/INDRES> 

46	 The NPD Group, Inc., The NPD Group/NPD Houseworld – POS, Refrigerators, January – 

December 2007, 2007. Port Washington, NY. 

3-85
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

 

 

47	 American Society of Heating, Refrigeration and Air-Conditioning Engineers, Inc. 2006 

ASHRAE Handbook, Refrigeration. Atlanta, GA. Chapter 48, Household Refrigerators and 

Freezers. 

48	 RemodelGuide.com. HomeTips, LLC, Glendale, CA. 

<http://www.remodelguide.com/improve/appliances/refrigerators/refrigerators_works.html> 

49	 Boughton, B.E., Clausing, A.M., and Newell, T.A. “An Investigation of Household 

Refrigerator Cabinet Thermal Loads,” HVAC&R Research, 1996, Vol. 2, No. 2. April. 

50	 Wilkes, K.E., Yarbrough, D.W., Nelson, G.E., and Booth, R. Aging of Polyurethane Foam 

Insulation in Simulated Refrigerator Panels – Four-Year Results with Third-Generation 

Blowing Agents, April, 2003. Oak Ridge National Laboratory, Oak Ridge, TN. 

<http://www.ornl.gov/~webworks/cppr/y2001/pres/116700.pdf> 

51	 Wehtje, Larry. “Transition of Blowing Agents Used in Refrigerator-Freezer Foam 

Insulation,” Appliance Magazine, February 2003. 

<http://www.appliancemagazine.com/latin/editorial.php?article=45&zone=32&first=1> 

52	 Pisipati, J.S. and Godbey, J.A. “Performance of Carbon Black-Containing Polyurethane 

Foam in Domestic Refrigerators,” Journal of Cellular Plastics, 1996. Vol. 32, No. 2, 108­

138. <http://cel.sagepub.com/cgi/content/abstract/32/2/108> 

53	 U.S. Department of Energy-Office of Codes and Standards. Technical Support Document: 

Energy Efficiency Standards for Consumer Products: Refrigerators, Refrigerator-Freezers, 

and Freezers, July 1995. Washington, DC. DOE/EE-0064. 

54	 Manini, P., Rizzi, E., Pastore, G., Gregorio, P. “Advances in VIP Design for Super Insulation 

of Domestic Appliances,” Appliance Magazine, June 2003. Presented at the 54th 

International Appliance Technical Conference, March 10-12, 2003, West Lafayette, IN. 

<http://www.appliancemagazine.com/latin/editorial.php?article=45&zone=32&first=1> 

55	 European Commission. Cold II, The revision of energy labeling and minimum energy 

efficiency standards for domestic refrigeration appliances, Final Report, December 2000. 

Prepared by ADEME, France and PW Consulting, United Kingdom. 

<http://www.ceecap.org/img_assets/File/Cold%20II.pdf> 

56	 Vineyard, E.A., Stovall, T.K., Wilkes, K.E., and Childs, K.W. “Superinsulation in 

Refrigerators and Freezers,” ASHRAE Transactions, 1998, Vol. 104, Pt.2. 

57	 Japan for Sustainability. “Matsushita’s Vacuum Insulation Wins 2006 Energy Conservation 

Award,” Information Center, July 15, 2007. <http://www.japanfs.org/db/1773-e> 

58	 Matsushita Electric Industrial Co., Ltd.. U-Vacua Technical Information, 2007. 

<http://panasonic.co.jp/appliance/environment/eco_h1804.html> (Accessed September 26, 

2007.) 

3-86
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

59	 “Electrolux's New Vacuum Insulated Freezer Technology,” Appliance Magazine, August 

2003. <http://www.appliancemagazine.com/new_products.php?article=4971&zone=204&first=1> 

60	 Va-Q-plus Product Data Sheet. <http://www.va-q-tec.com/produkte/en/pplus/prod/va-qplus_pdb_en.pdf> 

61	 Lawrence Berkeley National Laboratory. Gas-Filled Panels – How effectively do GFPs 

insulate? Berkeley, CA. <http://gfp.lbl.gov/performance/default.htm> (Accessed September 

26, 2007.) 

62	 Griffith, B.T., Arasteh, D., and Turler, D. “Energy Efficiency Improvements for 

Refrigerator/Freezers Using Prototype Doors Containing Gas-Filled Panel Insulating 

Systems,” Proceedings of the 46th International Appliance Technical Conference, May 

1995. Lawrence Berkeley National Laboratory, Berkeley, CA. <http://gfp.lbl.gov/papers/lbl36658.pdf> 

63	 U.S. Environmental Protection Agency. Finite Element Analysis of Heat Transfer Through 

the Gasket Region of Refrigerators/Freezers, October, 1992. Washington, DC. EPA/430/R92/009. 

64	 Title 10—Energy, Chapter II—Department of Energy, Part 430—Energy Conservation 

Program for Consumer Products, Subpart B—Test Procedures. 

65	 U.S. Environmental Protection Agency. State of the art survey of hermetic compressor 

technology applicable to domestic refrigerator/freezers, 1993. EPA-430-R-93-010. 

66	 U.S. Department of Energy, Opportunities for Energy Savings in the Residential and 

Commercial Sectors with High-Efficiency Electric Motors, Final Report, December 1, 1999. 

Prepared by Arthur D. Little, Inc., Washington, DC. No. DE-AC01-90CE23821. 

67	 DuMoulin, T.R. and Colling, D.A. “Higher Efficiencies by Means of Variable-Speed 

Technology in a Domestic Refrigeration Application,” ASHRAE Transactions, 1998, Vol. 

104, Pt. 2. 

68	 Woodall, R.J. and Bullard, C.W. “Simulating Effects of Mutispeed Compressors on 

Refrigerator/Freezer Performance,” ASHRAE Transactions, 1997, Vol. 103, Pt. 2. 

69	 Embraco. Embraco VCC® 3rd Generation, The Intelligent Compressor, Version 00, 

September 2006. <http://www.embraco.com.br/portugue/produtos/03010.pdf> (Accessed 

September 26, 2007.) 

70	 James, Stephen J. "Developments in domestic refrigeration and consumer attitudes," Food 

Refrigeration and Process Engineering Research Centre (FRPERC), 2003. University of 

Bristol, UK. Bulletin of the IIR - No 2003-5. <http://www.iifiir.org/en/doc/1051.pdf> 

3-87
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

 

 

71	 Unger, R. “Development and Testing of a Linear Compressor Sized for the European 

Market,” Proceedings of the International Appliance Technology Conference, May, 1999. 

Sunpower, Inc., Athens, OH. 

<http://www.sunpower.com/lib/sitefiles/pdf/publications/Doc0074.pdf> 

72	 LG Electronics. "Green Technology Linear DIOS," 2004. 

<www.aceee.org_conf_mt04_wbprsnt_Lee-R3.pdf> (Accessed July 25, 2007.) 

73	 LG Electronics. LG Linear Compressor Models. 

<http://www.lge.com/products/component/ref/models.jsp> (Accessed July 25, 2007.) 

74	 American Council for an Energy-Efficient Economy. "One kWh/day Refrigerator," Emerging 

Technologies & Practices, 2004. Washington, DC. 

75	 Bansal, P.K., Wich, T., Browne, M.W., and Chen, J. “Design and Modeling of New EggCrate-Type Forced Flow Evaporators in Domestic Refrigerators,” ASHRAE Transactions, 

2001, Vol. 107, Pt. 2. 

76	 Bansal, P.K. and van Neuren, O.S. “An Experimental Study on New Egg-Crate Type 

Evaporators in Domestic Refrigerators,” ASHRAE Transactions, 1998, Vol. 104, Pt. 2. 

77	 Goslovich, K.S. and Bullard, C.W. “Potential for Using Enhanced Aluminum Extrusions for 

Refrigerator Heat Exchangers,” ASHRAE Transactions, 1997, Vol. 103, Pt. 1. 

78	 Vineyard, E.A., Horvay, J.B., and Schulak, E.R. “Experimental and Analytical Evaluation of 

a Ground-Coupled Refrigerator-Freezer,” ASHRAE Transactions, 1998, Vol. 104, Pt. 2. 

79	 Bansal, P.K. and Chin, T.C. “Modeling and optimisation of wire-and-tube condenser,” 

International Journal of Refrigeration, 2003, 26 (2003), 601-613. 

80	 Bansal, P.K. and Chin, T.C. “Design and modeling of hot-wall condensers in domestic 

refrigerators,” Applied Thermal Engineering, 2002, 22 (2002), 1601-1617. 

81	 Rebora, A. and Tagliafico, L.A. “Thermal performance analysis for hot-wall condenser and 

evaporator configurations in refrigeration appliances,” International Journal of 

Refrigeration, 1997, Vol. 21, No. 6, 490-502. 

82	 Belko, John. Novel Fan Design Offers Energy Savings to Refrigeration Market, 2007. A.O. 

Smith Electrical Products Company. 

<http://www.aosmithmotors.com/pdf/documents/pax%20fan%20evap%20%20technical%20paper%2 

0_j%20belko_-2007.pdf> (Accessed September 26, 2007.) 

83	 Bansal, P.K. and Rupasinghe, A.S. “An Homogenous Model for Adiabatic Capillary Tubes,” 

Applied Thermal Engineering, 1998, Vol. 18, Nos. 3-4, 207-219. 

3-88
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

84	 Bansal, P.K. and Rupasinghe, A.S. “An empirical model for sizing capillary tubes,” 

International Journal of Refrigeration, 1996, Vol. 19, No. 8, 497-505. 

85	 Coulter, W.H. and Bullard, C.W. “ An Experimental Analysis of Cycling Losses in Domestic 

Refrigerator-Freezers,” ASHRAE Transactions, 1997. Vol. 103, Pt. 1. 

86	 Behrens, N., Dekleva, T.W., Hartley, J.G., Murphy, F.T., and Powell, R.L. “The R-134a 

energy efficiency problem, fact or fiction,” USNC/IIR-Purdue Refrigeration Conference, 

1990, pp. 365-372. 

87	 Jung, D., Kim, C-B., Song, K., and Park, B. “Testing of propane/isobutane mixture in 

domestic refrigerators,” International Journal of Refrigeration, 2000, 23 (2000) 517-527. 

88	 Alsaad, M.A. and Hammad, M.A. “The application of propane/butane mixture for domestic 

refrigerators,” Applied Thermal Engineering, 1998, 18 (1998) 911-918. 

89	 Gatta, A., “GE Opening a Door to a Future of Cleaner Home Refrigeration”, GE Press 

Release, October 28, 2008, 

http://www.genewscenter.com/Content/Detail.asp?ReleaseID=4303&NewsAreaID=2&Menu 

SearchCategoryID= 

90	 Lorenz, A. and Meutzner, K. “On application of non-azeotropic two component refrigerants 

in domestic refrigerator and home freezers,” Proceedings of the XIV International Congress 

of Refrigeration, 1975. Moscow. 

91	 Liu, Z., Haider, I., and Radermacher, R. “Simulation and Test Results of Hydrocarbon 

Mixtures in a Modified-Lorenz-Meutzner Cycle Domestic Refrigerator,” HVAC&R 

Research, Vol. 1, No. 2, April, 1995. 

92	 Gan, A.I., Klein, S.A, and Reindl, D.T. “Analysis of Refrigerator/Freezer Appliances Having 

Dual Refrigeration Cycles,” ASHRAE Transactions, 2000, Vol. 106, Pt. 2. 

93	 Bosch. Refrigeration, Integra Bottom-Freezers. <http://www.boschappliances.com/kitchenappliances-refrigerator-freezer_refrigerators_integra_integra-bottom-freezers.html> 

(Accessed September 26, 2007.) 

94	 Sun Frost. The Sun Frost RF19. <http://www.sunfrost.com/refrigerator_models.html> 

(Accessed September 26, 2007.) 

95	 Northland Corporation. Side-by-Side Refrigerator/Freezer Models, 48” 2 Door Side-by-Side 

with Stainless Steel Interior/Exterior with Full Length Glass Door. 

<http://www.northlandnka.com/refrigeration/side-by-side/side-by-side-48SS-SGX.asp> 

(Accessed September 26, 2007.) 

3-89
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

96	 Sub-Zero Freezer Company, Inc. Design Guide, Built-In, Integrated, Wine Storage, 

Undercounter. <http://www.subzero.com/resources/products/downloads/szdesignguide.pdf> 

(Accessed September 26, 2007.) 

97	 Liebherr Dual Refrigeration System, http://www.liebherrappliances.com/quick_links/features/dual_refrigeration.html 

98	 Radermacher, R. and Kim, K. “Domestic Refrigerators: recent developments,” International 

Journal of Refrigeration, 1996, Vol. 19, No. 1, pp. 61-69. 

99	 Lavanis, M., Haider, I., and Radermacher, R. “Experimental Investigation of an Alternating 

Evaporator Duty Refrigerator/Freezer,” ASHRAE Transactions, 1998, Vol. 104, Pt. 2. 

100 General Electric Company. GE Consumer & Industrial, Press Room, Refrigerators, GE 

Profile Refrigerators with ClimateKeeper2TM Technology Offer Fresh Solutions in a Variety 

of Sizes. 

<http://www.geconsumerproducts.com/pressroom/press_releases/appliances/refrigerators/CK2_NAH 

B05.htm> (Accessed September 26, 2007.) 

101 AJ Madison Inc. KitchenAid 27” Double Drawer Refrigerator with 5.3 cu.ft. Capacity, Dual 

Evaporator, Independent Temperatures & Extend Fresh Pantry. 

<http://www.ajmadison.com/cgi-bin/ajmadison/KDDA27TR.html> (Accessed September 26, 

2007.) 

102 US-Appliance. Jenn-Air 27” Built In Under Counter Drawer Refrigerator Stainless Steel. 

<http://www.us-appliance.com/jud278dbes.html> (Accessed September 26, 2007.) 

103 Tomasek, M-L. and Radamacher, R. “Analysis of a Domestic Refrigerator Cycle with an 

Ejector,” ASHRAE Transactions, 1995, Vol. 101, Pt. 1. 

104 Kim, K., Kopko, B. and Radamacher, R. “Application of Tandem System to High-Efficiency 

Refrigerator/Freezer,” ASHRAE Transactions, 1995, Vol. 101, Pt. 2. 

105 Avanti Products. <http://www.avantiproducts.com/> (Accessed September 26, 2007.) 

3-90
 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 4: SCREENING ANALYSIS 

TABLE OF CONTENTS 

4.1 INTRODUCTION ...............................................................................................................4-1 

4.2 SCREENED-OUT TECHNOLGIES............................................................................... 4-2 

4.2.1 Improved Resistivity of Insulation....................................................................... 4-2 

4.2.2 Gas-Filled Panels ................................................................................................. 4-2 

4.2.3 Improved Gaskets, Double Gaskets, Improved Door Face Frame ...................... 4-3 

4.2.4 Reduced Heat Load for TTD Feature .................................................................. 4-3 

4.2.5 Warm Liquid or Hot Gas Refrigerant Anti-Sweat Heating ................................. 4-4 

4.2.6 Electric Anti-Sweat Heater Sizing.......................................................................4-4 

4.2.7 Linear Compressors ............................................................................................. 4-4 

4.2.8 Improved Evaporator Heat Exchange.................................................................. 4-5 

4.2.9 Improved Condenser Heat Exchange................................................................... 4-5 

4.2.10 Fan Blade Improvements ..................................................................................... 4-6 

4.2.11 Improved Expansion Valve.................................................................................. 4-6 

4.2.12 Off-Cycle Valve................................................................................................... 4-7 

4.2.13 Reduced Energy for Automatic Defrost .............................................................. 4-7 

4.2.14 Condenser Hot Gas Defrost ................................................................................. 4-7 

4.2.15 Electronic Temperature Control .......................................................................... 4-8 

4.2.16 Air-Distribution Control ...................................................................................... 4-8 

4.2.17 Alternative Refrigerants....................................................................................... 4-8 

4.2.18 Component Location............................................................................................ 4-9 

4.2.19 Lorenz-Meutzner Cycle ....................................................................................... 4-9 

4.2.20 Dual-Loop System ............................................................................................... 4-9 

4.2.21 Two-Stage System ............................................................................................. 4-10 

4.2.22 Control Valve System and Tandem System ...................................................... 4-10 

4.2.23 Ejector Refrigerator ........................................................................................... 4-10 

4.2.24 Stirling Cycle ..................................................................................................... 4-10 

4.2.25 Thermoelectric ................................................................................................... 4-11 

4.2.26 Thermoacoustic.................................................................................................. 4-11 

4.3 REMAINING TECHNOLOGIES ................................................................................. 4-12 

LIST OF TABLES 

Table 4.2.1 LG Linear Compressor Performance Data ............................................................... 4-4 

LIST OF FIGURES 

Figure 4.2.1 Comparison of Stirling and Vapor Compression Technologies............................ 4-11 

4-i 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 4. SCREENING ANALYSIS 

4.1 INTRODUCTION 

This chapter details the screening analysis that the U.S. Department of Energy (DOE) 

conducted in support of the ongoing energy conservation standards rulemakings for refrigerators, 

refrigerator-freezers, and freezers. 

In chapter 3, the market and technology assessment (MTA), DOE presented an initial list 

of technologies that can improve the energy efficiency of residential refrigeration products. The 

purpose of the screening analysis is to evaluate the technologies that improve equipment 

efficiency to determine which technologies to consider further and which to screen out. DOE 

consulted with a range of parties, including industry, technical experts, and others to develop a 

list of technologies for consideration. DOE evaluated the technologies pursuant to the criteria set 

out in the Energy Policy and Conservation Act (EPCA), as amended. (42 U.S.C. 6311-6317) 

Section 325(o) EPCA establishes criteria for prescribing new or amended standards 

designed to achieve the maximum improvement in energy efficiency. Further, EPCA directs the 

Secretary of Energy to determine whether a standard is technologically feasible and 

economically justified. (42 U.S.C. 6295(o)(2)(A), as directed by 42 U.S.C. 6316(a)(1)-(3)). 

EPCA also establishes guidelines for determining whether a standard is economically justified. 

(42 U.S.C. 6295(o)(2)(B)) Appendix A to subpart C of Title 10, Code of Federal Regulations, 

Part 430 (10 CFR Part 430), “Procedures, Interpretations and Policies for Consideration of New 

or Revised Energy Conservation Standards for Consumer Products” (the Process Rule), sets forth 

procedures to guide DOE in its consideration and promulgation of new or revised equipment 

energy conservation standards. These procedures elaborate on the statutory criteria provided in 

42 U.S.C. 6295(o) and, in part, eliminate problematic technologies early in the process of 

prescribing or amending an energy efficiency standard. In particular sections 4(b)(4) and 5(b) of 

the Process Rule guide DOE in determining whether to eliminate from consideration any 

technology that presents unacceptable problems with respect to the following criteria: 

Technological feasibility. Technologies incorporated in commercial equipment or in 

working prototypes will be considered technologically feasible. 

Practicability to manufacture, install, and service. If mass production of a technology 

in commercial equipment and reliable installation and servicing of the technology could be 

achieved on the scale necessary to serve the relevant market at the time of the effective date of 

the standard, then that technology will be considered practicable to manufacture, install, and 

service. 

Impacts on equipment utility or equipment availability. If a technology is determined 

to have significant adverse impact on the utility of the equipment to significant subgroups of 

customers, or result in the unavailability of any covered equipment type with performance 

characteristics (including reliability), features, sizes, capacities, and volumes that are 

substantially the same as equipment generally available in the United States at the time, it will 

not be considered further. 

4-1 

EERE-2008-BT-STD-0012 COMMENT 22
Adverse impacts on health or safety. If it is determined that a technology will have 

significant adverse impacts on health or safety, it will not be considered further. 

In sum, if DOE determines that a technology, or a combination of technologies, has 

unacceptable impacts on the policies stated in section 5(b) of the Process Rule, it will be 

eliminated from consideration. If a particular technology fails to meet one or more of the four 

criteria, it will be screened out. Section 4.2 documents the reasons for eliminating any 

technology. 

4.2 SCREENED-OUT TECHNOLGIES 

This section describes the technologies that DOE eliminated for failure to meet one of the 

following four factors: (1) technological feasibility; (2) practicability to manufacture, install, and 

service; (3) impacts on equipment utility or equipment availability; and (4) adverse impacts on 

health or safety. 

4.2.1 Improved Resistivity of Insulation 

Past research has demonstrated that the resistivity of polyurethane (PU) foam insulation 

can be improved through the use of additives that reduce the thermal conductivity of the foam. 

Research conducted in 1996 demonstrated that adding carbon black provides a means of 

improving the thermal insulation properties of PU foam using both HCFC-141b or cyclopentane 

blowing agents.1

 However, DOE is not aware that this process has been adopted by any supplier 

of PU foam insulation or any refrigerator manufacturer. Manufacturers have reported that it 

darkens the interior of a refrigerator lined with white plastic, and it stains anything it contacts. 

Discussion with PU foam insulation vendors indicates that there is work ongoing which 

may lead to improvement in insulation performance but that any such technology would not 

likely be ready for introduction to the market by 2014. Discussion with manufacturers has 

confirmed that there are no available options for improvement in PU foam insulation 

performance (other than reverting to use of banned blowing agents). Due to the lack of available 

information and predictions that there is no significant benefit to be expected from PU foam 

improvements, DOE has eliminated this option from consideration in the engineering analysis. 

4.2.2 Gas-Filled Panels 

Investigation of the status of gas-filled panels suggests that there has been some 

evaluation of this technology by manufacturers of residential refrigeration equipment, but that no 

manufacturers are using it in their products. The costs are reported to be as high as for vacuum 

insulation panels (VIPs), with less reduction in thermal load. DOE has not been able to identify a 

credible supplier that would provide gas filled panel products to the refrigeration industry. DOE 

has eliminated this technology from further consideration. 

4-2 

EERE-2008-BT-STD-0012 COMMENT 22
4.2.3 Improved Gaskets, Double Gaskets, Improved Door Face Frame 

Past investigation on reduction of heat load in the gasket and door face frame area has 

focused on (1) limiting the conduction of heat through metal casing material passing underneath 

the gasket magnet on the cabinet side or in the region of the gasket clip on the door side into the 

cabinet interior, (2) using a gasket which provides additional cover of frame surfaces towards the 

interior of the magnet to prevent cold air from reaching the high-conductivity metal casing near 

the gasket magnet, and (3) providing a long thin “throat” area between the gasket and the interior 

to limit convection heat transfer. Most current designs are effective in addressing these issues. 

Limited information is publicly available which would allow quantification of additional 

improvement potential for the door frame/gasket area of refrigerators. Some manufacturers use 

extra-strong gasket magnets to limit infiltration and thermal loss, but it is unclear whether 

significant thermal improvement is possible with such systems. Manufacturers indicated during 

pre-NOPR discussions that properly designed and installed gasket systems provide a tight seal 

and that there isn’t any further reduction in air leakage that could be achieved with 

improvements in the gasket system such as increasing the magnetic force. In addition, consumer 

safety laws preclude use of excessive door sealing force. 

Based on information drawn from DOE’s 1995 TSD, double door gaskets were not 

adopted by many manufacturers in the mid-1990s because of performance problems and cost. Ice 

has a tendency to form between the gaskets, greatly reducing their effectiveness. In addition, the 

gaskets tend to be visually unattractive and they make it more difficult to meet the consumer 

safety regulations for minimum door-opening force. 

It is expected that incremental improvement may be possible for some products, however, 

the lack of good quantified information on general improvement potential in this area makes this 

technology option unsuitable for consideration as a design option. 

4.2.4 Reduced Heat Load for TTD Feature 

During Pre-NOPR analysis discussions, manufacturers indicated that there is little or no 

reduction in load which can be achieved through redesign of TTD features. DOE inspected the 

TTD system of a side-by-side refrigerator and concluded that the load impact of this feature is 

modest. The door insulation thickness is maintained behind the recess except within an inch or 

two of the chute opening, and low-conductivity plastic is used on all surfaces. The chute door 

closes reliably. A calculation of the thermal load suggests that it is on the order of 3W (10 

Btu/hr). The reverse engineering of this feature shows that a 2W electric anti-sweat heater is used 

to prevent condensation of the exterior surfaces nearest the ice chute opening. Manufacturers 

indicated that these load levels are typical for TTD features. Even if the chute door was insulated 

with 1⁄2-inch of insulation (which would likely interfere with chute door operation), the load 

impact would be minimal, due to the very low surface area of this door. Based on the very low 

potential for improvement, DOE has eliminated reduced heat load TTD features as an option for 

further analysis. 

4-3 

EERE-2008-BT-STD-0012 COMMENT 22
4.2.5 Warm Liquid or Hot Gas Refrigerant Anti-Sweat Heating 

Although some refrigerators do still use electric anti-sweat heating, the typical anti-sweat 

heater for baseline units, according to the reverse engineering work and discussion with 

manufacturers, is warm liquid refrigerant. A possible exception is French door refrigerators. In 

these products, providing heat to the gasket surfaces which seal between the French doors (or to 

the flip-mullion used in some designs for sealing in this region) is not possible using warm 

refrigerant liquid or hot gas. French door refrigerators may use electric anti-sweat heaters in this 

region, but for these products conversion to refrigerant line anti-sweat is impractical. Due to the 

current use of refrigerant-line anti-sweat in situations where it can be used, DOE has eliminated 

this option from further consideration. 

4.2.6 Electric Anti-Sweat Heater Sizing 

Because the baseline products considered in the engineering analysis predominantly use 

warm liquid anti-sweat, the consideration of adjustment of the sizing of electric anti-sweat 

heaters is not relevant. 

4.2.7 Linear Compressors 

While promising potential has been reported for linear compressors, there is very little 

information available for commercialized linear compressors that allows confident prediction of 

performance and cost impacts of this technology. Information for some LG linear compressors 

has been reported at “LG Reference Conditions,” which are significantly different than the 

standard ASHRAE rating conditions. Under ASHRAE conditions, compressors are rated at -10 

oF (-23.3 oC) evaporating temperature and 130 oF (54.4 oC) condensing temperature. The “LG 

Reference Conditions” are based on -14.8 oF (-26 oC) evaporating and 100.4 oF (38 oC) 

condensing temperatures. It is not clear what the liquid and suction vapor temperatures for the 

LG conditions are—these temperatures also impact capacity and power input. The performance 

of some of LG’s linear compressors at the LG conditions is presented in Table 4.2.1 below. At 

the same evaporating and condensing temperatures and with liquid and suction vapor conditions 

consistent with the ASHRAE test conditions, a high efficiency rotating-shaft reciprocating 

compressor such as the Embraco EGX70HLC would have an operating EER of about 6.9 Btu/hrW. Hence, the LG linear compressor may be about 9% more efficient than the best currenttechnology rotating-shaft reciprocating compressors. 

Table 4.2.1 LG Linear Compressor Performance Data 

Model 

Capacity Range* Efficiency* 

W Btu/hr COP EER 

DLF81LACT 310 1058 2.14 7.3 

FA81LACT 293 1000 2.20 7.5 

FA72LACT 276 941 2.20 7.5 

FA63LACT 241 823 2.20 7.5 

FA54LACT 207 706 2.20 7.5 

Source: LG, 2007. 

* Performance based on ‘LG Reference’ rating conditions. Models utilize refrigerant R134a. 

4-4 

EERE-2008-BT-STD-0012 COMMENT 22
In the trade press, LG has expressed willingness to license the linear compressor 

technology to competitors.2

 However, because the LG design is proprietary, the widespread use 

of linear compressors is highly uncertain. Use of linear compressors in LG refrigerators is less 

explicit in LG product data than it was a few years ago, so it is unclear how many products are 

actually using these compressors. Other compressor manufacturers who have indicated that they 

have investigated linear technology have stated that linear compressor technology does not 

provide a clear path to improved efficiency, and some have indicated that they are no longer 

actively pursuing this technology. Hence, availability of linear compressor technology as an 

option for improved efficiency is uncertain. Further, DOE was not able to obtain cost estimates 

for linear compressors. For these reasons, DOE has eliminated linear compressors from further 

consideration in the analyses. 

4.2.8 Improved Evaporator Heat Exchange 

Improving heat exchanger performance can be achieved through the use of enhanced fins 

and/or tubes. These types of fin and tube enhancements are common in air-conditioning 

applications where slit and louvered designs are used to enhance the fin surface and different 

types of internally-grooved surfaces are used to enhance the tubing. Application of similar 

enhancements in refrigerator evaporators is complicated by frost accumulation on the 

evaporators. Effectiveness of the fine slit and louver features for refrigerator evaporators is 

dubious because they would be blocked quickly with frost. In order to avoid the energy use 

associated with frequent defrost, fin spacing in refrigerator evaporators is comparatively sparse. 

This allows the evaporator to work effectively without blocking airflow with a considerable 

accumulation of frost. During defrost, the typical flat fin design of these evaporators assures that 

the frost slides rapidly off the fins and doesn’t get stuck on fin enhancement features. During 

discussions with manufacturers, little indication was provided that efficiency could significantly 

be enhanced through the use of fin or tube enhancements. DOE has eliminated this option from 

consideration in subsequent analysis. 

4.2.9 Improved Condenser Heat Exchange 

Use of heat exchanger enhancements for the condenser are complicated by the need for 

adequate performance when the heat exchanger has not been cleaned. Most refrigerator 

condensers (other than hot wall condensers integrated into the outer shells of the products) are 

made of steel tubes and steel wire fins. These condensers have a very open construction which 

allows dust to flow through easily and which reduces blockage of air flow if dust does collect on 

the condenser surfaces. Flat fin condensers used in refrigerators are known to require more 

careful attention to cleaning. Use of high fin densities is more accepted in air-conditioning 

applications because periodic maintenance is expected and because size would get enormous if 

aggressive fin spacing wasn’t employed, whereas cleaning of refrigerator condensers occurs 

infrequently or never, and the loads are small enough so that maximizing use of space is not 

critical. DOE has eliminated this option from consideration in subsequent analysis. 

4-5 

EERE-2008-BT-STD-0012 COMMENT 22
4.2.10 Fan Blade Improvements 

Refrigerator fan blades use an axial design. They are typically injection molded plastic 

with a three-dimensional shape for improved performance as compared with older stamped sheet 

metal designs. One source of inefficiency for axial fans lies in their tendency to throw air 

outward, necessitating a shroud to collect and redirect airflow along the axis as intended. The 

Pax GroupTM has developed a fan (PAX fan) that employs streamlined blades with patented 

geometrical shapes derived from a naturalistic design approach, providing better airflow 

direction and improved efficiency. Tests performed when replacing existing motor combinations 

with A.O.Smith motors and PAX fan blades show power input reductions in the range of roughly 

10% to 35%.3 It is impossible to tell how much of this benefit is associated with the fan blade 

and how much with the motor. Also, because the PAX fan is proprietary, the widespread use of 

the design is highly uncertain. There is in general little data available to quantify the energy 

benefit possible with improvement in fan blade design in today’s refrigeration products. Fan 

performance is highly dependent on details of integration with the system: orifice geometry, 

tolerance of blade/orifice gap, match of system flow impedence to fan performance, etc. Hence, 

making credible estimates of energy savings potential through fan blade replacement requires 

testing fan blade swaps in baseline products. The cost of fabrication of improved fan blade 

geometries should be low, so most of the cost increase associated with this technology option 

would be associated with paying for the blade development and/or licensing fees. It is very 

difficult to predict what these costs would be unless specific vendors of high efficiency fan 

blades can be identified who provide complete information. During discussions with 

manufacturers, no information was provided which would allow credible calculation of savings 

and costs associated with improved fan blades. Hence, DOE has eliminated this option from 

further consideration. 

4.2.11 Improved Expansion Valve 

Residential refrigeration products exclusively use capillary tubes for refrigerant flow 

metering. These tubes are inexpensive and they lend themselves easily to low-cost fabrication of 

suction line heat exchangers by brazing the capillary to the suction line. Automatic, adjustable 

thermostatic or electronic expansion valves are available, but they generally are oversized for 

residential refrigeration. Furthermore, it is unclear whether there is any potential for energy 

savings using alternative expansion devices. The DOE Energy test is conducted with a single set 

of standardized temperatures for the ambient air (90 °F) and for the compartments. A capillary 

tube can be designed to provide optimized performance for this set of temperatures. Systems are 

generally designed to operate with evaporator exit conditions having little or no superheat during 

energy testing, thus maximizing use of the evaporator. In the lower ambient temperature typical 

in homes, the pressure available to move refrigerant through the capillary tube is lower, thus 

possibly leading to increased superheat and less than optimum performance. An automatic valve 

could provide optimum performance for a wider range of operating conditions, but such 

improvement is not reflected in current energy testing. DOE has eliminated this option from 

further consideration. 

4-6 

EERE-2008-BT-STD-0012 COMMENT 22
4.2.12 Off-Cycle Valve 

Off-cycle refrigerant migration reduces a refrigeration product’s efficiency by allowing 

warm and/or vapor-phase refrigerant to pass into the cabinet. A fluid control or solenoid valve 

installed after the condenser to effectively isolate the evaporator from the condenser during the 

off-cycle can be used to prevent refrigerant migration. Research has demonstrated that solenoid 

valves can yield substantial energy savings.4 Such a solenoid valve represents a possible 

reliability issue, although many wine storage products use similar solenoid valves to allow 

control of multiple compartments with a single compressor. Also, operation with an off-cycle 

valve requires that the compressor motor can start up against a substantial pressure difference. 

The starting windings of compressors that can do this reliably over the life of a refrigerator draw 

more power and hence reduce the compressor’s steady-state efficiency. The different efficiency 

levels of commercial refrigeration compressors designed for instant restart versus restart after 

pressure equalization have EER ratings which differ by 10% or more. Such a difference would 

be expected for residential compressors operating with an off cycle valve, and this difference 

would more than neutralize any benefit accrued from using the off-cycle valve. Hence, DOE has 

eliminated this option from further consideration. 

4.2.13 Reduced Energy for Automatic Defrost 

In some cases, the defrost heat supplied is more than required. Thus, energy savings can 

be achieved by reducing the defrost heat by either using smaller heaters, reducing the heater ontime, reducing the frequency of defrost, or a combination of these. In its 1995 TSD, DOE found 

that most manufacturers had already significantly reduced the electric heat for auto defrost in 

order to comply with the energy efficiency standards that became effective in 1993.5

 The percent 

of energy represented by defrost for the refrigerator-freezers tested as part of this rulemaking 

ranged from 4% to 5% for products without adaptive defrost and from 1% to 5% for products 

with adaptive defrost. It is unlikely that significant energy savings are achievable by further 

reducing the energy for automatic defrost without compromising defrost performance, except 

through use of adaptive defrost. 

4.2.14 Condenser Hot Gas Defrost 

Another method of reducing the energy required for defrost is to eliminate the need for 

electric heaters by substituting condenser hot gas in their place. In a condenser hot gas defrost 

system, the compressor continues to run and a valve opens allowing hot compressed refrigerant 

to flow to the evaporator. Many frost-free refrigerator-freezers in the 1960s and 1970s used a 

condenser hot gas defrost system. In its 1995 TSD, DOE was not able to identify data that 

demonstrated that the condenser hot gas method was more cost-effective than adaptive defrost. 

Therefore, DOE dropped the condenser gas defrost as a technology option in favor of adaptive 

defrost. 6 Hot gas defrost would potentially save energy because a large portion of the heat for 

defrost could be provided by heat generated by the compressor motor during the on-cycle rather 

than from new electricity use. The compressor is at an elevated temperature with respect to 

ambient during the on-cycle and is certainly much warmer than freezing temperature. The heat 

would be transported to the evaporator with circulating refrigerant during the defrost cycle. 

However, in spite of this potential reduction in use of electricity to provide defrost heat, the 

4-7 

EERE-2008-BT-STD-0012 COMMENT 22
energy savings potential is not well documented. Also, there are concerns regarding reliability of 

the required valve. 

4.2.15 Electronic Temperature Control 

DOE has not identified any relevant information showing the energy benefit of electronic 

temperature control. Potential benefits of electronic control when operating with single-speed 

compressors are fine-tuning of the run times and fine-tuning of the cut-in and cut-out 

temperatures. While there may be potential for incremental improvement associated with such 

fine-tuning, the lack of data supporting claims for energy savings make it difficult to properly 

analyze this option. 

4.2.16 Air-Distribution Control 

Air temperature distribution in refrigeration products with fan-forced evaporator air flow 

is generally good, in contrast with some products with cold wall or roll bond evaporators. Hence, 

it is not clear that improvements in air distribution will provide significant reduction in energy 

use. Redirection of air flows in a cabinet could potentially provide a false indication of efficient 

operation, for instance if the coldest air from the evaporator discharge is directed at the locations 

used for the energy test thermocouples. It is conceivable that valid reduction in energy use could 

occur if the air flow distribution keeps cold air away from the walls of the cabinet. However, 

there is insufficient information regarding the designs of air flow distribution systems to quantify 

potential energy savings. 

4.2.17 Alternative Refrigerants 

R-600a (isobutane) is the most logical alternative to the HFC-134a refrigerant used 

exclusively in U.S. residential refrigeration products. Isobutane is a hydrocarbon refrigerant 

which has been used for many years in refrigeration products in Europe and other foreign 

countries. The theoretical efficiency of isobutane is higher than that of HFC-134a, however, the 

U.S. refrigeration industry has not adopted hydrocarbon refrigerants (likewise for the U.S. air 

conditioning industry) due to concerns regarding flammability. Recent shifts in this viewpoint 

are the result of pressures regarding the direct global warming impact of the refrigerant rather 

than the energy use impacts. Comments from manufacturers regarding the potential for 

efficiency improvement using isobutane are mixed. In any case, it is not expected that U.S. 

manufacturers will switch to isobutane to reduce energy use and that there will be limited 

conversion unless legislation is enacted which mandates phaseouts for global warming 

substances such as HFC refrigerants. In the case of such legislation, the potential improvement in 

energy use associated with isobutane will be balanced by a potential increase in energy use 

associated with reduced resistivity of PU foam insulation made with cyclopentane blowing 

agent, the most likely replacement for currently-used HFC blowing agents. DOE will consider 

the impacts of switch to hydrocarbon refrigerants and blowing agents if such legislation is 

enacted, but DOE will not consider use of isobutane as a design option to improve efficiency in 

the absence of such legislation. 

4-8 

EERE-2008-BT-STD-0012 COMMENT 22
 

4.2.18 Component Location 

Locating the compressor at the top of the refrigerator was noted as a potential technology 

option. However, this change would increase structural requirement for the refrigerator cabinet, 

increase risk of product tip-over, and provide much less practical use of space from the consumer 

perspective. It also makes design for re-evaporation of defrost water more challenging. It is 

unlikely that the savings would justify all of these drawbacks. 

Another option is to locate the evaporator fan motor outside the cabinet to reduce internal 

loads from the heat loss of the motor. Evaporator fan motor input wattages are now in the range 

3W to 7W, with fan blade efficiency in the range 20% to 30% and motor efficiency in the range 

20% to 50%. Hence, load reduction, associated with moving the motor loss outside the cabinet, 

is only in the range 1W to 5W for the typically less than 50% of the time that the evaporator fan 

is in operation. The loss associated with the added infiltration and conduction is likely to be 

comparable to this level. Additional issues with this approach include reliability, reduced design 

flexibility, and the fact that reduction of motor losses (by using more efficient fan motors) may 

be a more effective approach to reducing the impact of the fan motor power input. 

No options for relocation of components have been identified which merit further 

consideration in the engineering analysis. 

4.2.19 Lorenz-Meutzner Cycle 

Research on Lorenz-Meutzner cycles reported in the literature involve binary mixtures 

HCFC-22/CFC-11, HCFC-22/HCFC-123, propane/n-pentane, and propane/n-butane. These 

systems achieved efficiency levels from 15 to 20 percent better than the baseline systems with 

which they were compared.7,8 Because the industry settled on the use of HFC-134a to replace 

CFC-12, interest in the Lorenz-Meutzner cycle as an alternative to conventional refrigeration 

cycles declined. All of the refrigerant combinations discussed above have specific problems, the 

first two with phaseout of constituent refrigerants CFC-11 and HCFC-22, and the last two with 

flammability of the hydrocarbon blends involved. While it is possible that HFC mixtures could 

be developed to create a viable Lorenz-Meutzner cycle refrigerator, DOE is not aware that such a 

prototype has been built and tested successfully. Hence, DOE has not considered this technology 

in the engineering analysis. 

4.2.20 Dual-Loop System 

Dual-loop systems have difficulty achieving their theoretical improvement potential due 

to the significantly reduced efficiency for smaller-capacity compressors. If the two compressors 

of a dual-loop system serving a refrigerator-freezer were sized appropriately for their respective 

loads, the freezer compressor capacity would nominally be roughly half that of a single-system 

compressor. A fresh food compressor typically operates at a capacity significantly higher than its 

nominal capacity because of the higher evaporating temperature when cooling just the fresh food 

compartment. Hence, the nominal capacity of a fresh food compartment compressor serving a 

dual-loop system is generally 30 to 40 percent that of the single-system compressor. Even with 

the efficiency improvement associated with higher evaporating temperature operation of the 

fresh food compartment compressor, this compressor still would not operate at an efficiency 

4-9 

EERE-2008-BT-STD-0012 COMMENT 22
level better than that of the single-system compressor for freezer conditions. Hence, with the 

efficiency characteristics of available compressors, it is not clear that the dual-loop architecture 

will provide any energy savings. Hence, DOE has not considered this technology in the 

engineering analysis. 

4.2.21 Two-Stage System 

In practice, a two-stage system would suffer the same disadvantages associated with a 

dual-loop system. Furthermore, it is not clear that a suitable compressor is available for the lower 

stage of such a system. DOE is not aware of any prototypes of such a system using compressors 

which their manufacturers would warrantee for such a product. Hence, DOE has not considered 

this technology in the engineering analysis. 

4.2.22 Control Valve System and Tandem System 

There are many patents covering dual-evaporator refrigerator designs. It is not clear how 

many of these were developed to improve system efficiency, since one of the benefits of using 

dual evaporators is avoiding excessively low humidity levels in the fresh food compartment. 

While there is research involving laboratory testing which shows that these technology options 

can save energy, DOE is not aware of any commercialized refrigerators using either of these 

approaches. In discussions with manufacturers none identified these options as being interesting 

approaches for energy use reduction. Further, due to the extensive patent literature discussing 

dual-evaporator systems, it is likely that products requiring dual evaporator designs would be 

restricted to the patentholders. Hence, DOE has not considered this technology in the 

engineering analysis. 

4.2.23 Ejector Refrigerator 

Energy savings have been reported for use of an ejector system in laboratory testing. In 

discussions with manufacturers there was limited familiarity with this concept and no 

acknowledgement that it has been proven through prototype testing and/or that it is an interesting 

concept for improving efficiency. Hence, DOE has not considered this technology in the 

engineering analysis. 

4.2.24 Stirling Cycle 

In principle, the efficiency of Stirling cycles could be higher than for vapor 

compression systems, but there are various technical difficulties that have so far limited the use 

of Stirling-cycle cooling to small prototype domestic refrigerators. There is no circulating 

refrigerant fluid and the hot and cold end areas are very small, which creates heat exchange 

difficulties. Heat pipes may be required to transfer heat to and from the system. A comparison of 

the performance of Stirling cycle with vapor compression compressors is shown in Figure 4.2.1 

below. The Stirling cycle data was obtained from the Global Cooling website9

 and from data 

presented at the Purdue Refrigeration Conference in 2002.10 The figure shows that Stirling 

technology is not currently ready to improve upon the efficiency of conventional technology. 

Hence, DOE has not considered this technology in the engineering analysis. 

4-10
 

EERE-2008-BT-STD-0012 COMMENT 22
0 

2 

4 

6 

8 

10 

12 

EER (Btu/hr-W) 

Conventional: Danfoss TTE4.6FK, Nominal 4.62 EER 

Conventional: Tecumseh TPG1370YXA, Nominal 5.82 EER 

Stirling: Purdue 2002 Paper 

Stirling: Global Cooling M100 

40 60 80 100 120 140 160 

Temperature Lift (F) 

Figure 4.2.1 Comparison of Stirling and Vapor Compression Technologies 

4.2.25 Thermoelectric 

 Thermoelectric cooling technologies currently do not achieve efficiency levels which 

make them attractive as a design option for improving residential refrigeration energy efficiency. 

As an example, DOE tested a thermoelectric refrigerator as part of the reverse engineering effort 

of this rulemaking. This refrigerator was a Haier model HRT02WNC, a 1.7 cuft all-refrigerator. 

In an 80 °F ambient with the system operating at full power, this unit was able to cool the 

interior to 47 °F while drawing 50W total. The fans serving the inside and outside heat sinks of 

the thermoelectric unit are rated at a voltage of 12 Volts and currents of 0.13 Amps and 0.16 

Amps respectively, and a control board power input of 1W is assumed. The thermal load for the 

cabinet was estimated as 12 W. Hence the thermoelectric module EER was 0.9 at a temperature 

lift of at most 33 °F, an order of magnitude less than is achieved by conventional technology. 

Hence, DOE has not considered this technology in the engineering analysis. 

4.2.26 Thermoacoustic 

While research suggests that thermoacoustic cooling systems could achieve respectable 

efficiencies, the technology has not reached a level of maturity sufficient for serious 

consideration as the basis for efficiency improvement in residential refrigeration products. 

Hence, DOE has not considered this technology in the engineering analysis. 

4-11
 

EERE-2008-BT-STD-0012 COMMENT 22
4.3 REMAINING TECHNOLOGIES 

After eliminating those technologies that have no effect or do not increase EER and 

screening out those technologies that that do not meet the requirements of sections 4(a)(4) and 

5(b) of the Process Rule, DOE is considering the technologies in the following list. 

• Increased Insulation Thickness 

• Vacuum Insulation Panels (VIPs) 

• Variable Anti-sweat Heating 

• Improved Compressor Efficiency 

• Variable Speed Compressors 

• Increased heat exchanger area (extension of surface area or addition of coil rows). 

• Use of forced convection condenser (for upright freezers) 

• Improved efficiency fan motors (brushless DC) 

• Adaptive Defrost 

4-12
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

REFERENCES 

1	 Pisipati, J.S. and Godbey, J.A. “Performance of Carbon Black-Containing Polyurethane 

Foam in Domestic Refrigerators,” Journal of Cellular Plastics, 1996. Vol. 32, No. 2, 108­

138. <http://cel.sagepub.com/cgi/content/abstract/32/2/108> 

2	 American Council for an Energy-Efficient Economy. "One kWh/day Refrigerator," Emerging 

Technologies & Practices, 2004. Washington, DC. 

3	 Belko, John. Novel Fan Design Offers Energy Savings to Refrigeration Market, 2007. A.O. 

Smith Electrical Products Company. 

<http://www.aosmithmotors.com/pdf/documents/pax%20fan%20evap%20%20technical%20 

paper%20_j%20belko_-2007.pdf> (Accessed September 26, 2007.) 

4	 Coulter, W.H. and Bullard, C.W. “ An Experimental Analysis of Cycling Losses in Domestic 

Refrigerator-Freezers,” ASHRAE Transactions, 1997. Vol. 103, Pt. 1. 

5	 U.S. Department of Energy-Office of Codes and Standards. Technical Support Document: 

Energy Efficiency Standards for Consumer Products: Refrigerators, Refrigerator-Freezers, 

and Freezers, July 1995. Washington, DC. DOE/EE-0064. p. 3-8. 

6	 U.S. Department of Energy-Office of Codes and Standards. Technical Support Document: 

Energy Efficiency Standards for Consumer Products: Refrigerators, Refrigerator-Freezers, 

and Freezers, July 1995. Washington, DC. DOE/EE-0064. p. 3-8. 

7	 Lorenz, A. and Meutzner, K. “On application of non-azeotropic two component refrigerants 

in domestic refrigerator and home freezers,” Proceedings of the XIV International Congress 

of Refrigeration, 1975. Moscow. 

8	 Liu, Z., Haider, I., and Radermacher, R. “Simulation and Test Results of Hydrocarbon 

Mixtures in a Modified-Lorenz-Meutzner Cycle Domestic Refrigerator,” HVAC&R 

Research, Vol. 1, No. 2, April,, 1995. 

9	 http://www.globalcooling.nl/technologyoverview.html#perform 

10	 Janssen, M. and P.Beks, “Measurement and Application of Performance Characteristics of a 

Free Piston Stirling Cooler”, presented at the Ninth International Refrigeration and Air 

Conditioning Conference at Purdue, 2002. 

4-13
 

EERE-2008-BT-STD-0012 COMMENT 22
5-i 

CHAPTER 5: ENGINEERING ANALYSIS 

TABLE OF CONTENTS 

5.1 INTRODUCTION ........................................................................................................... 5-1

5.2 PRODUCT CLASSES ANALYZED.............................................................................. 5-1

5.3 METHODOLOGY OVERVIEW .................................................................................... 5-2

5.4 EFFICIENCY LEVELS................................................................................................... 5-3

5.4.1 Baseline Units based on the Current Test Procedure........................................... 5-3

5.4.2 Baseline Efficiency Definitions Based on the Expected Test Procedure ............ 5-6

5.4.2.1 Data Illustrating the Impact of Test Procedure Changes ......................... 5-7

5.4.2.2 Establishment of Baseline Energy—Adjusted Volume Relationships 

Based on the New Test Procedure .....................................................................5-11

5.4.2.3 Investigation of the Slope of the Energy Use Curve..............................5-14

5.4.3 Incremental Efficiency Levels ........................................................................... 5-15

5.4.4 Maximum Technology Level............................................................................. 5-16

5.5 DATA COLLECTION .................................................................................................. 5-18

5.5.1 Manufacturer-Submitted Shipment and Cost Data from AHAM...................... 5-18

5.5.2 Component Vendor Data ................................................................................... 5-19

5.5.3 Reverse Engineering ..........................................................................................5-20

5.5.3.1 Selection of Products for Reverse Engineering ..................................... 5-20

5.5.3.2 Collection of Energy Modeling Data..................................................... 5-22

5.5.4 Manufacturer Interviews.................................................................................... 5-23

5.5.5 Energy testing .................................................................................................... 5-23

5.6 MANUFACTURING COST MODELING................................................................... 5-24

5.6.1 Generation of Bills of Materials ........................................................................5-24

5.6.2 Cost Structure of the Spreadsheet Models.........................................................5-25

5.6.3 Cost Model and Definitions...............................................................................5-25

5.6.3.1 Cost Definitions ..................................................................................... 5-26

5.6.4 Cost Model Assumptions Overview .................................................................. 5-26

5.6.4.1 Fabrication Estimates............................................................................. 5-27

5.6.4.2 Production Volumes Assumptions......................................................... 5-28

5.6.4.3 Factory Parameters Assumptions........................................................... 5-28

5.6.4.4 Material Cost Assumptions.................................................................... 5-28

5.6.5 Manufacturing Production Cost......................................................................... 5-30

5.6.6 Incremental Cost Estimates................................................................................ 5-31

5.6.6.1 Overhead and Depreciation Costs.......................................................... 5-31

5.6.6.2 Depreciation Costs for Insulation Thickness Increases .........................5-32

5.6.6.3 G&A and Profit...................................................................................... 5-33

5.7 ENERGY MODELING................................................................................................. 5-34

5.7.1 Energy Model development............................................................................... 5-34

5.7.2 Supplemental Spreadsheet Models .................................................................... 5-35

5.7.3 Development and Calibration of ERA Current Energy Test Models ................5-36

5.7.4 Adjustments to Energy Models to Represent Baseline Products Tested Under the 

Proposed Test Procedure................................................................................................ 5-40

EERE-2008-BT-STD-0012 COMMENT 22
5-ii 

5.8 DESIGN OPTIONS....................................................................................................... 5-42

5.8.1 Increased Insulation Thickness..........................................................................5-43

5.8.2 Vacuum-Insulated Panels................................................................................... 5-44

5.8.3 Improved Compressor Efficiency...................................................................... 5-45

5.8.4 Variable-Speed Compressor .............................................................................. 5-48

5.8.5 Increased Evaporator Surface Area ................................................................... 5-50

5.8.6 Increased Condenser Surface Area .................................................................... 5-50

5.8.7 Brushless DC Fan Motors.................................................................................. 5-50

5.8.8 Adaptive Defrost................................................................................................ 5-51

5.8.9 Variable Anti-Sweat Heater Control..................................................................5-52

5.8.10 Forced Convection Condenser...........................................................................5-53

5.9 ENGINEERING ANALYSIS RESULTS ..................................................................... 5-53

5.9.1 DOE Cost-Efficiency Curves.............................................................................5-53

5.9.2 AHAM Incremental Cost Data .......................................................................... 5-57

5.9.2.1 Product Class 3 ......................................................................................5-59

5.9.2.2 Product Class 5 ......................................................................................5-62

5.9.2.3 Product Class 7 ......................................................................................5-64

5.9.2.4 Product Class 9 ......................................................................................5-66

5.9.2.5 Product Class 11 ....................................................................................5-68

LIST OF TABLES 

Table 5.2.1 Product Classes Analyzed in Engineering Analysis.................................................5-2

Table 5.4.1 Refrigerator, Refrigerator-Freezer, and Freezer Energy Conservation Standards and 

Proposed Baseline Model Efficiencies ........................................................................................ 5-5

Table 5.4.2 Expected Cabinet Temperature Changes for the DOE Test Procedure ....................5-6

Table 5.4.3 Volume Adjustment Factors ..................................................................................... 5-6

Table 5.4.4 Compartment Volume Calculation Changes ............................................................5-7

Table 5.4.5 Compartment Temperature and Adjusted Volume Change Data provided by 

AHAM—Current Test .................................................................................................................5-8

Table 5.4.6 Compartment Temperature and Adjusted Volume Change Data provided by AHAM-

-Proposed Test .............................................................................................................................5-9

Table 5.4.7 Compartment Temperature and Adjusted Volume Change Data provided by 

AHAM—Impact ........................................................................................................................5-10

Table 5.4.8 Energy Use Impact of Compartment Temperature Changes: Data Developed by DOE

....................................................................................................................................................5-11

Table 5.4.9 Approach for Establishing Baseline Energy--Adjusted Volume Relationships ..... 5-12

Table 5.4.10 New Baseline Energy Consumption based on Proposed Test Procedure.............5-14

Table 5.4.11 DOE Assessment of the Slope of the Energy Use Curve ..................................... 5-15

Table 5.4.12 Incremental Efficiency Levels (% Energy Use Less than Baseline) .................... 5-16

Table 5.4.13 Maximum Available Levels (%Energy Use Less than Baseline)........................ 5-16

Table 5.4.14 Maximum Technology Levels.............................................................................. 5-18

Table 5.5.1 Component Vendors Contacted by DOE during Engineering Analysis.................5-20

Table 5.5.2 Selected Units for Reverse-Engineering and Energy Testing ................................5-21

Table 5.5.3 Additional Thermocouple Locations for Energy Test ............................................ 5-24

EERE-2008-BT-STD-0012 COMMENT 22
5-iii 

Table 5.6.1 Cost Model In-House Manufacturing Operation Assumptions .............................. 5-27

Table 5.6.2 Refrigerator & Freezer Factory Parameter Assumptions ....................................... 5-28

Table 5.6.3 Five-Year Metal Prices (2003-2008) ...................................................................... 5-29

Table 5.6.4 Most Prevalent Resin Prices as of December 2007 ................................................ 5-30

Table 5.6.5 Overhead and Depreciation Cost Ratios................................................................. 5-32

Table 5.6.6 Greenfield Depreciation Costs per Product ............................................................5-33

Table 5.8.1 Design Options by Product Class ...........................................................................5-43

Table 5.8.2 Teardown Product Fan Power Input ....................................................................... 5-51

Table 5.9.1 DOE Incremental Costs .......................................................................................... 5-54

Table 5.9.2 AHAM Incremental Cost Data for Product Class 3 ...............................................5-59

Table 5.9.3 AHAM Incremental Cost Data for Product Class 5 ...............................................5-62

Table 5.9.4 AHAM Incremental Cost Data for Product Class 7 ...............................................5-64

Table 5.9.5 AHAM Incremental Cost Data for Product Class 9 ...............................................5-66

Table 5.9.6 AHAM Incremental Cost Data for Product Class 11 .............................................5-68

LIST OF FIGURES 

Figure 5.3.1 Flow Diagram of Engineering Analysis Methodology ...........................................5-3

Figure 5.4.1 Maximum Efficiency Levels Available by Product Class ....................................5-17

Figure 5.6.1 Full Production Costs ............................................................................................5-30

Figure 5.7.1 ERA Analysis for Refrigerator-Freezers Compared with EnergyGuide Labels and 

Energy Test Measurements........................................................................................................ 5-38

Figure 5.7.2 ERA Analysis for Freezers Compared with EnergyGuide Labels and Energy Test 

Measurements ............................................................................................................................5-39

Figure 5.7.3 ERA Analysis for Compact Refrigerators and Freezers Compared with 

EnergyGuide Labels and Energy Test Measurements............................................................... 5-39

Figure 5.8.1 Compressor Efficiency Data..................................................................................5-46

Figure 5.8.2 Incremental Cost for Single-Speed Compressors for Standard-Size Products...... 5-47

Figure 5.8.3 Efficiency Curve for Low Capacity Compressors................................................. 5-48

Figure 5.9.1 Incremental Manufacturer Selling Price for Standard-Size Refrigerator-Freezers5-55

Figure 5.9.2 Incremental Manufacturer Selling Price for Standard-Size Freezers....................5-56

Figure 5.9.3 Incremental Manufacturer Selling Price for Compact Refrigerators and Freezers5-57

Figure 5.9.4 Incremental Cost Curves for Product Class 3........................................................5-60

Figure 5.9.5 Incremental Cost Curves for Product Class 5........................................................5-63

Figure 5.9.6 Incremental Cost Curves for Product Class 7........................................................5-65

Figure 5.9.7 Incremental Cost Curves for Product Class 9........................................................5-67

Figure 5.9.8 Incremental Cost Curves for Product Class 11......................................................5-69

Figure 5.9.9 Product Class 11 Refrigerators listed in the ENERGY STAR Database .............. 5-69

EERE-2008-BT-STD-0012 COMMENT 22
5-1 

CHAPTER 5. ENGINEERING ANALYSIS 

5.1 INTRODUCTION 

The engineering analysis establishes the relationship between manufacturer 

production cost and energy consumption for the refrigerators, refrigerator-freezers, and 

freezers covered in this rulemaking. The “cost-efficiency” relationship serves as the basis 

for cost-benefit calculations in terms of individual customers, manufacturers, and the 

Nation, from which the most economically-justified, technically feasible standard level is 

ultimately determined. 

The inputs into the engineering analysis include baseline characteristics for each 

product class addressed in the market and technology assessment (chapter 3), the design 

options from the screening analysis (chapter 4), as well as cost and energy use data 

collected from manufacturers, component vendors, reverse-engineering, and energy 

testing. The output of the engineering analysis is the cost-efficiency relationship for each 

product class independent of cabinet volume, which will be used in the life-cycle and 

payback period analyses (chapter 8). 

This chapter covers the product classes DOE analyzed, and the methodology used 

by DOE to develop manufacturing costs, energy consumption, and extend the analysis to 

low-volume product classes, as well as the results of these analyses. 

5.2 PRODUCT CLASSES ANALYZED 

In the engineering analysis for the preliminary notice of proposed rulemaking 

(Pre-NOPR), DOE analyzed the seven product classes listed in Table 5.2.1. DOE 

considers these classes to be representative of products currently shipped by the 

residential refrigerator, freezer, and refrigerator-freezer industry based on total shipments. 

These product classes represent close to 90% of the shipments of refrigerators, 

refrigerator-freezers, and freezers. DOE did not directly analyze all covered product 

classes in order to carry out the analysis as efficiently as possible. DOE proposes 

extrapolation of energy standards to the remaining product classes as described in section 

2.15 of chapter 2. 

EERE-2008-BT-STD-0012 COMMENT 22
5-2 

Table 5.2.1 Product Classes Analyzed in Engineering Analysis 

Product 

Class Equipment Description 

3 Refrigerator-freezers—automatic defrost with top-mounted freezer without 

TTD ice service 

5 Refrigerator-freezers—automatic defrost with bottom-mounted freezer without 

TTD ice service 

7 Refrigerator-freezers—automatic defrost with side-mounted freezer with TTD 

ice service 

9 Upright freezers with automatic defrost 

10 Chest freezers and all other freezers except compact freezers 

11 Compact refrigerators and refrigerator-freezers with manual defrost 

18 Compact chest freezers 

5.3 METHODOLOGY OVERVIEW 

This section describes the analytical methodology DOE used in the engineering 

analysis. In this rulemaking, DOE has adopted a combined efficiency level, design option 

approach to developing cost-efficiency curves. DOE established efficiency levels defined 

on percent energy use lower than that of baseline efficiency products in order to allow 

comparison of information developed from different sources. However, DOE’s analysis 

is based on the efficiency improvements associated with groups of design options. 

Figure 5.3.1 presents the steps in the analysis and illustrates how they contribute 

to developing the cost-efficiency curves. The process begins with data collection and 

ends with the incremental cost curve results. 

As input to the analysis, DOE requested incremental cost-efficiency data from the 

industry. The Association of Home Appliance Manufacturers (AHAM) provided 

aggregated incremental cost data for a number of the product classes under analysis. This 

information was supplemented by analytically-derived cost-efficiency curves for the 

seven product classes listed in Table 5.2.1. 

To develop the analytically-derived cost-efficiency curves, DOE collected 

information from various sources on the manufacturing cost and energy use reduction 

characteristics of each of the design options. DOE reviewed product literature, conducted 

reverse-engineering of current products, and interviewed component vendors of 

compressors, fan motors, insulation, and heat exchangers. DOE also conducted 

interviews with manufacturers, using an engineering questionnaire which is reproduced 

in appendix 5-A. 

EERE-2008-BT-STD-0012 COMMENT 22
5-3 

Figure 5.3.1 Flow Diagram of Engineering Analysis Methodology 

 Cost information from the vendor interviews and engineering questionnaires 

provided input to the manufacturing cost model. Incremental costs associated with 

specific design options were calculated using the cost model. Energy use reduction was 

modeled with a modified version of the established EPA Refrigerator Analysis (ERA) 

program which was used in the previous refrigerator rulemaking. The reverse 

engineering, vendor interviews, and manufacturer interviews provided input for the 

energy analysis. The incremental cost estimates and the energy modeling results together 

constitute the energy efficiency curves presented in this chapter. 

5.4 EFFICIENCY LEVELS 

5.4.1 Baseline Units based on the Current Test Procedure 

DOE selected baseline units as reference points for all of the product classes, 

against which DOE determined changes resulting from use of energy saving design 

options. The baseline unit in each product class represents the basic characteristics of 

equipment in that class. A baseline unit is a unit that just meets current required energy 

conservation standards and provides basic consumer utility. 

As discussed in chapter 3, DOE has initiated a rulemaking to revise the energy 

test procedure for refrigerators, refrigerator-freezers, and freezers. Some of the 

anticipated changes to the test procedure such as changes in compartment temperatures 

will result in changes in the measured energy consumption. The test procedure change 

will also affect the measured size of the refrigerators, expressed as adjusted volume. 

EERE-2008-BT-STD-0012 COMMENT 22
5-4 

Since the maximum energy use for residential refrigeration products is expressed as a 

function of adjusted volume, the change in adjusted volume also affects the definition of 

baseline products. This section discusses definitions of baseline units for the engineering 

analysis based on the current test procedure, while the next section discusses modified 

definitions for baseline refrigeration products based on the expected revised test 

procedure. 

For this rulemaking, DOE established baseline efficiency levels as the current 

federal energy conservation standards, expressed as maximum annual energy 

consumption as a function of the product’s adjusted volume, as shown in Table 5.4.1. 

These definitions are based on testing according to the current energy test procedure. 

EERE-2008-BT-STD-0012 COMMENT 22
5-5 

Table 5.4.1 Refrigerator, Refrigerator-Freezer, and Freezer Energy Conservation 

Standards and Proposed Baseline Model Efficiencies 

Product Class Equations for Maximum 

Energy Use (kWh/yr) 

1. Refrigerators and refrigerator-freezers with manual defrost. 8.82AV + 248.4 

0.31av + 248.4 

2. Refrigerator-freezer—partial automatic defrost. 8.82AV + 248.4 

0.31av + 248.4 

3. Refrigerator-freezer—automatic defrost with top-mounted freezer without 

TTD ice service and all-refrigerator—automatic defrost. 

9.80AV + 276.0 

0.35av + 276.0 

4. Refrigerator-freezers—automatic defrost with side-mounted freezer without 

TTD ice service. 

4.91AV + 507.5 

0.17av + 507.5 

5. Refrigerator-freezers—automatic defrost with bottom-mounted freezer 

without TTD ice service. 

4.60AV + 459.0 

0.16av + 459.0 

6. Refrigerator-freezers—automatic defrost with top-mounted freezer with 

TTD ice service. 

10.20AV + 356.0 

0.36av + 356.0 

7. Refrigerator-freezers—automatic defrost with side-mounted freezer with 

TTD ice service. 

10.10AV + 406.0 

0.36av + 406.0 

8. Upright freezers with manual defrost. 7.55AV + 258.3 

0.27av + 258.3 

9. Upright freezers with automatic defrost. 12.43AV + 326.1 

0.44av + 326.1 

10. Chest freezers and all other freezers except compact freezers. 9.88AV + 143.7 

0.35av + 143.7 

11.Compact refrigerators and refrigerator-freezers with manual defrost. 10.70AV + 299.0 

0.38av + 299.0 

12. Compact refrigerator-freezer—partial automatic defrost. 7.00AV + 398.0 

0.25av + 398.0 

13. Compact refrigerator-freezers—automatic defrost with top-mounted 

freezer and compact all-refrigerator—automatic defrost. 

12.70AV + 355.0 

0.45av + 355.0 

14. Compact refrigerator-freezers—automatic defrost with side-mounted 

freezer. 

7.60AV + 501.0 

0.27av + 501.0 

15. Compact refrigerator-freezers—automatic defrost with bottom-mounted 

freezer. 

13.10AV + 367.0 

0.46av + 367.0 

16. Compact upright freezers with manual defrost. 9.78AV + 250.8 

0.35av + 250.8 

17. Compact upright freezers with automatic defrost. 11.40AV + 391.0 

0.40av + 391.0 

18. Compact chest freezers. 10.45AV + 152.0 

0.37av + 152.0 

5A. Refrigerator-freezer—automatic defrost with bottom-mounted freezer with 

TTD ice service. 

5.0AV + 539.0 

0.18av + 539.0 

10A. Chest freezers with automatic defrost. 14.76AV + 211.5 

0.52av + 211.5 

AV= adjusted volume in cubic feet; av = adjusted volume in liters; 

Refrigerator-Freezers: AV = fresh food internal volume + 1.63 * freezer internal volume 

Freezers: AV = 1.73 * freezer internal volume 

Refrigerators (single-door): AV = fresh food internal volume + 1.44 * freezer internal volume 

All-Refrigerators: AV = internal volume 

EERE-2008-BT-STD-0012 COMMENT 22
5-6 

5.4.2 Baseline Efficiency Definitions Based on the Expected Test Procedure 

As discussed in chapter 3, DOE expects to propose revisions in the energy test 

procedure to harmonize with expected test temperatures under consideration for IEC test 

procedure 62552 and to simplify calculation of refrigerated volumes. The expected test 

temperature changes are summarized in Table 5.4.2 below. 

Table 5.4.2 Expected Cabinet Temperature Changes for the DOE Test Procedure 

Fresh Food Compartment 

Temperature °F 

Freezer Compartment 

Equipment Type Temperature °F 

Current Expected Current Expected

Refrigerator-Freezer 45 39 5 0 

All-Refrigerator 38 39 Not Applicable 

Refrigerator w/ Freezer 

Compartment 45 39 15 15 (No Change) 

Freezer Not Applicable 0 0 (No 

Change) 

The temperature changes also impact the volume adjustment factor used to 

determine the adjusted volume. This factor is multiplied by the freezer compartment 

volume in the adjusted volume calculation. Current and expected volume adjustment 

factors are summarized in Table 5.4.3 below. 

Table 5.4.3 Volume Adjustment Factors 

Product Current Test Procedure Expected Test Procedure 

Revisions 

Refrigerator-Freezer 1.63 1.76 

Basic Refrigerator* 1.44 1.47 

Freezer 1.73 1.76 

All-Refrigerator** 1.00 1.00 

*A basic refrigerator is a single-door refrigerator with a freezer compartment with 

volume greater than 0.5 ft3

. 

**An all-refrigerator can have a freezer compartment with volume less than 0.5 ft3. 

The key changes in the volume measurement calculation between the current test 

procedure and the expected revised test procedure are summarized in Table 5.4.4 below. 

Adjusted volume will be impacted both by the change in the volume adjustment factor 

and the change in the volume measurement. 

EERE-2008-BT-STD-0012 COMMENT 22
5-7 

Table 5.4.4 Compartment Volume Calculation Changes 

Item AHAM HRF-1-1979 AHAM HRF-1-2008 

Expected 

Effect on 

Volume 

Automatic Ice Maker 

Storage Bin Included (4.2.1.1a) 

Would be included 

under “removable 

containers” but 

dispenser MAY NOT 

be included 

None* 

Ice Makers Included (4.2.1.1a) No Mention None* 

Water Coolers Included (4.2.1.1a) No Mention None* 

Door Shelf Fronts and 

Bottoms Included (4.2.1.1b) 

Shelves molded into 

the inner door panel 

NOT included (4.2.2) 

Decrease 

Volume between the 

Deductible Door Dikes 

and Cabinet Breaker 

Strips or Adjacent 

Liner Wall 

Not Included 

(4.2.1.2d) 

No mention of 

exclusion, so probably 

included. 

Increase 

Shelf Hangers & Shelf 

and Pan Rails 

Not included for 

fixed projections if 

collective volume is 

>0.05 ft3 (4.2.1.2e) 

Could be interpreted as 

part of shelving and 

would thus be 

included. 

Increase 

*Although AHAM HRF-1-2008 either doesn’t mention this item or is not fully 

clear regarding its treatment for the volume calculation, it is expected that manufacturers 

would use the AHAM HRF-1-1979 approach. 

5.4.2.1 Data Illustrating the Impact of Test Procedure Changes 

The different compartment temperatures of the expected revised energy test procedure 

will change test energy use for refrigerators and refrigerator-freezers. In addition, both 

the impact of the modified temperatures on the adjusted volume and the modified volume 

calculation method will change adjusted volumes. For these reasons, it is necessary to 

establish modified relationships between energy use and adjusted volume to define 

baseline products. AHAM provided data for a number of the product classes, presented in 

Table 5.4.5 through Table 5.4.7 below (this is referred to as the AHAM TP Change data). 

The AHAM TP Change data for product classes 11 and 13 both show energy use 

reductions, indicating that the products represented by these data are primarily allrefrigerators. AHAM was not able to separately provide data for the all-refrigerators of 

these product classes, because insufficient data was provided by manufacturers for 

aggregation. 

EERE-2008-BT-STD-0012 COMMENT 22
5-8 

Additional data sources which provide indication of the impacts of the test 

temperature changes for standard-size refrigerator-freezers include (1) energy test 

measurements for the refrigerator-freezers tested as part of this rulemaking, and (2) 

calculation of the energy impacts using ERA, the energy modeling tool used for this 

rulemaking. The energy use impacts indicated by these sources are shown in Table 5.4.8. 

DOE conducted these energy tests and calculations for three products of each of the 

seven analyzed product classes (see Section 5.5.3.1 for discussion on selection of 

products for reverse engineering and energy testing). 

Table 5.4.5 Compartment Temperature and Adjusted Volume Change Data 

provided by AHAM—Current Test 

Product 

Class 

Fresh Food 

Volume 

Freezer 

Volume 

Adjusted 

Volume 

Energy 

Use 

12.82 5.02 20.92 420 

3 (R-F) 3.54 1.82 6.53 55 

Average 

Standard Deviation 

Number of Samples 19 19 19 19 

19.26 19.26 374 

3A (AR) 3.4 3.4 54 

Average 

Standard Deviation 

Number of Samples 11 11 11 

14.21 5.15 22.62 493 

5 1.85 1.02 3 55 

Average 

Standard Deviation 

Number of Samples 18 18 18 18 

15.77 9.32 30.95 617 

7 1.61 0.87 2.53 68 

Average 

Standard Deviation 

Number of Samples 24 24 24 24 

 16.85 29.14 603 

9 4.88 8.45 136 

Average 

Standard Deviation 

Number of Samples 18 18 18 

4.38 4.65 334 

11 1.38 1.38 44 

Average 

Standard Deviation 

Number of Samples 13 13 13 

4.75 4.77 296 

13 1.18 1.15 77 

Average 

Standard Deviation 

Number of Samples 12 12 12 

Note: R-F refers to refrigerator-freezers; AR refers to all-refrigerators. 

EERE-2008-BT-STD-0012 COMMENT 22
5-9 

Table 5.4.6 Compartment Temperature and Adjusted Volume Change Data 

provided by AHAM--Proposed Test 

Product 

Class 

Fresh Food 

Volume 

Freezer 

Volume 

Adjusted 

Volume 

Energy 

Use 

12.79 4.96 21.44 472 

3 (R-F) 3.51 1.78 6.59 53 

Average 

Standard Deviation 

Number of Samples 19 19 19 18 

19.51 19.51 364 

3A (AR) 3.51 3.51 53 

Average 

Standard Deviation 

Number of Samples 11 11 11 

14.42 5.25 23.12 582 

5 1.88 1 3.01 68 

Average 

Standard Deviation 

Number of Samples 18 18 18 18 

15.95 9.01 31.45 702 

7 1.79 0.75 2.49 82 

Average 

Standard Deviation 

Number of Samples 24 24 24 24 

 16.84 29.47 603 

9 5.04 8.73 136 

Average 

Standard Deviation 

Number of Samples 18 18 18 

4.34 4.61 324 

11 1.36 1.36 48 

Average 

Standard Deviation 

Number of Samples 13 13 13 

4.8 4.83 285 

13 1.23 1.2 73 

Average 

Standard Deviation 

Number of Samples 12 12 12 

Note: R-F refers to refrigerator-freezers; AR refers to all-refrigerators. 

EERE-2008-BT-STD-0012 COMMENT 22
5-10 

Table 5.4.7 Compartment Temperature and Adjusted Volume Change Data 

provided by AHAM—Impact 

Product 

Class 

Fresh Food 

Volume 

Freezer 

Volume 

Adjusted 

Volume 

Energy 

Use 

-0.1% -1.1% 2.8% 12.4% 

3 (R-F) 0.6% 0.9% 2.3% 6.9% 

Average 

Standard Deviation 

Number of Samples 19 19 19 18 

1.2% 1.2% -2.6% 

3A (AR) 1.0% 1.0% 1.1% 

Average 

Standard Deviation 

Number of Samples 11 11 11 

1.5% 2.2% 2.2% 18.2% 

5 1.2% 2.2% 1.2% 3.7% 

Average 

Standard Deviation 

Number of Samples 18 18 18 18 

1.0% -3.1% 1.6% 14.0% 

7 2.0% 4.6% 2.0% 6.7% 

Average 

Standard Deviation 

Number of Samples 24 24 24 24 

 -0.4% 0.9% 0.0% 

9 2.5% 2.2% 0.0% 

Average 

Standard Deviation 

Number of Samples 18 18 18 

-0.7% -0.6% -3.1% 

11 1.9% 1.6% 1.4% 

Average 

Standard Deviation 

Number of Samples 13 13 13 

0.9% 1.0% -3.6% 

13 1.6% 1.4% 0.8% 

Average 

Standard Deviation 

Number of Samples 12 12 12 

Note: R-F refers to refrigerator-freezers; AR refers to all-refrigerators. 

EERE-2008-BT-STD-0012 COMMENT 22
5-11 

Table 5.4.8 Energy Use Impact of Compartment Temperature Changes: Data 

Developed by DOE 

Product 

Class 

Product Description Impact based on 

energy 

measurements 

Impact based on 

ERA modeling 

16 ft3 Top-Mount R-F 19.1% 14.2% 

21 ft3 Top-Mount R-F 27.7% 16.0% 

3 

21 ft3

 E* Top-Mount R-F 26.6% 14.1% 

18.5 ft3 E* Bottom-Mount R-F 12.5% 22.1% 

25 ft3 E* Bottom-Mount R-F 1 27.6% 13.8% 

5 

25 ft3

 E* Bottom-Mount R-F 2 17.3% 14.4% 

4 22 ft3 Side-Mount R-F† 17.7% 12.5% 

26 ft3 7 Side-Mount R-F 24.5% 12.4% 

26 ft3 E* Side-Mount R-F 25.0% 12.2% 

1.7 ft3 11 Compact Refrigerator -4.5% -2.4% 

4.0 ft3 Compact Refrigerator Not Tested 13.4% 

†This product was thought to be product class 7 when purchased. 

The AHAM TP Change data shows reasonable agreement with the DOE modeled 

energy use impacts. However, the DOE energy measurements indicate a higher 

sensitivity to the temperature change of the new test procedure. The AHAM data shows 

that there can be significant variation in the sensitivity of different refrigerator-freezer 

products to the test temperature changes, particularly for product classes 3 and 7. The two 

compact refrigerators of Table 5.4.8 exhibit different responses to the compartment 

temperature change because the 1.7 ft3

 refrigerator has a freezer compartment smaller 

than 0.5 ft3

 and is tested as an all-refrigerator, while the 4.0 ft3 refrigerator has a freezer 

compartment just larger than 0.5 ft3, requiring that it be tested as a basic refrigerator. 

5.4.2.2 Establishment of Baseline Energy—Adjusted Volume Relationships 

Based on the New Test Procedure 

The available data to inform the establishment of baseline energy versus adjusted 

volume relationships based on the expected revised test procedure is discussed in Section 

 5.4.2.1. While this data does not address every product class, DOE proposes to use it as 

the basis for establishing the baseline relationships. The approach DOE used to develop 

these relationships for all the product classes is summarized in Table 5.4.9 below. Note 

that product classes 1, 3, 11, and 13 are split because, while the all-refrigerators have 

reduced energy use with the new test procedure, the products which include freezers have 

significantly higher energy use. This applies to product class 11, since many of these 

units have freezer compartments smaller than 0.5 ft3

, which allows them to be classified 

and tested as all-refrigerators rather than basic refrigerators. The test procedure impact of 

this classification is that the refrigerator compartment temperature will be raised for allrefrigerators, while it will be reduced for basic refrigerators under the proposed test 

procedure. 

EERE-2008-BT-STD-0012 COMMENT 22
5-12 

Table 5.4.9 Approach for Establishing Baseline Energy--Adjusted Volume 

Relationships 

Product Class Approach 

1 Use modeling with ERA for temperature, assume negligible 

adjusted volume impact based on AHAM data for PC11. 

1A 

(All-Refrigerators) 

Use AHAM TP Change aggregated data of product class 3 allrefrigerators. 

2 Trend consistent with PC1. 

3 (RefrigeratorFreezers) Use AHAM TP Change aggregated data. 

3A 

(All-Refrigerators) 

Use AHAM TP Change aggregated data. 

4 Use AHAM TP Change aggregated data of product class 7. 

5 Use AHAM TP Change aggregated data. 

5A Use AHAM TP Change aggregated data of product class 5. 

6 Use AHAM TP Change aggregated data of product class 3 

refrigerator-freezers. 

7 Use AHAM TP Change aggregated data. 

8 (volume only) Assume negligible volume impact due to simplicity of manual 

defrost freezer interior. 

9 (volume only) Use AHAM TP Change aggregated data. 

10 (volume only) Assume negligible impact due to simplicity of manual defrost 

freezer interior. 

10A (volume only) Use AHAM TP Change aggregated data for PC9. 

11 Use modeling with ERA for temperature, assume negligible 

adjusted volume impact based on AHAM data.* 

11A 

(All-Refrigerators) 

Use modeling with ERA for temperature, assume negligible 

adjusted volume impact based on AHAM data.* 

12 Trend consistent with PC11. 

13 (RefrigeratorFreezers) Use AHAM TP Change aggregated data of product class 3 

refrigerator-freezers.* 

13A 

(All-Refrigerators) 

Use AHAM TP Change aggregated data of product class 3 allrefrigerators.* 

14 Use AHAM TP Change aggregated data of product class 7. 

15 Use AHAM TP Change aggregated data of product class 5. 

16 (volume only) Assume negligible volume impact due to simplicity of manual 

defrost freezer interior. 

17 (volume only) Use AHAM TP Change aggregated data for PC9. 

18 (volume only) Assume negligible volume impact due to simplicity of manual 

defrost freezer interior. 

*The AHAM energy use increase data cannot be used for this product class, 

because it is not known how many of these products are all-refrigerators. 

EERE-2008-BT-STD-0012 COMMENT 22
5-13 

Note: For product classes 8, 10, 16, and 18, while the volume impact is assumed 

to be negligible, the adjusted volume increases according to the increase in the volume 

adjustment factor. 

The methodology for determining new baseline energy—adjusted volume curves 

given the data indicating the impacts on the energy use and adjusted volume for a given 

product class is as follows. The proposed energy use and the current energy use for a 

product are represented as being proportional using an Energy Standard Adjustment 

Factor (ESAF). 

BECNEWTP ESAF  BECCURTP Equation 5.4.1

Where: 

BECNEWTP = Baseline energy consumption using the new test procedure; 

BECCURTP = Baseline energy consumption using the current test procedure. 

The ESAF is considered to be a function only of product class. Dependence on 

adjusted volume or efficiency level cannot be determined based on the available data. 

Similarly, the adjusted volume for a product under the proposed test procedure is 

related to the adjusted volume under the current test procedure using a Volume 

Calculation Adjustment Factor (VCAF). 

AVNEWTP  AVVCAF CURTP Equation 5.4.2 

Where: 

AVNEWTP = Adjusted Volume using the new test procedure; 

AVCURTP = Adjusted Volume using the current test procedure. 

The VCAF, like the ESAF, is considered to be a function only of product class. 

Baseline energy use for the current test procedure is expressed as follows, where the 

constants A and B are a function of product class. 

BECCURTP CURTP  BAVA Equation 5.4.3 

Combining Equations 5.4.1 through 5.4.3 gives the following relationship for the 

baseline energy consumption based on the new test procedure. 

AVA   BESAF

VCAF

ESAF B

VCAF

AV BEC AESAF NEWTP

NEWTP

NEWTP  

 



  



 





 

Hence, the baseline energy consumption for the product class for the new test 

procedure can be represented as a straight-line relationship based on new constants ANEW

and BNEW, where the new constants are related to the current constants as follows. 

BA BESAF

VCAF

ESAF ANEW   NEW  

 



  ;

EERE-2008-BT-STD-0012 COMMENT 22
5-14 

The baseline energy use based on the expected revised test procedure is presented 

in Table 5.4.10 below for each of the product classes. 

Table 5.4.10 New Baseline Energy Consumption based on Proposed Test Procedure 

Product 

Class 

ESAF VCAF Current Baseline 

Energy Use 

(kWh/year) 

Expected Test Procedure 

Baseline Energy Use 

(kWh/year) 

1 1.132 1 8.82 AV + 248.4 9.98 AV + 281.2 

1A 0.974 1.012 8.82 AV + 248.4 8.49 AV + 241.9 

2 1.132 1 8.82 AV + 248.4 9.98 AV + 281.2 

3 1.124 1.028 9.8 AV + 276 10.72 AV + 310.2 

3A 0.974 1.012 9.8 AV + 276 9.43 AV + 268.8 

4 1.14 1.016 4.91 AV + 507.5 5.51 AV + 578.6 

5 1.182 1.022 4.6 AV + 459 5.32 AV + 542.5 

5A 1.182 1.022 5 AV + 539 5.78 AV + 637.1 

6 1.124 1.028 10.2 AV + 356 11.15 AV + 400.1 

7 1.14 1.016 10.1 AV + 406 11.33 AV + 462.8 

8 1 1.017 7.55 AV + 258.3 7.42 AV + 258.3 

9 1 1.009 12.43 AV + 326.1 12.32 AV + 326.1 

10 1 1.017 9.88 AV + 143.7 9.71 AV + 143.7 

10A 1 1.009 14.76 AV + 211.5 14.63 AV + 211.5 

11 1.125 1 10.7 AV + 299 12.04 AV + 336.4 

11A 0.977 1 10.7 AV + 299 10.45 AV + 292.1 

12 1.125 1 7 AV + 398 7.88 AV + 447.8 

13 1.124 1.028 12.7 AV + 355 13.89 AV + 399.0 

13A 0.974 1.012 12.7 AV + 355 12.22 AV + 345.8 

14 1.14 1.016 7.6 AV + 501 8.53 AV + 571.1 

15 1.182 1.022 13.1 AV + 367 15.15 AV + 433.8 

16 1 1.017 9.78 AV + 250.8 9.61 AV + 250.8 

17 1 1.009 11.4 AV + 391 11.3 AV + 391 

18 1 1.017 10.45 AV + 152 10.27 AV + 152 

Note: In the “Current Baseline” equations, AV is calculated using the current volume calculation method 

and adjustment factor, while in the “Proposed” equations, AV is calculated using the proposed volume 

calculation method and adjustment factor (see Table 5.4.3) 

 

5.4.2.3 Investigation of the Slope of the Energy Use Curve 

DOE carried out analysis to confirm whether the slopes of the baseline energy 

use—adjusted volume curves for the product classes analyzed in depth as part of the 

engineering analysis are representative of the energy use of typical products. DOE 

conducted these analyses based on the expected revised test procedure. The analysis 

started with an energy model of a minimally-compliant product and examined the trend 

in calculated energy use as the product size changes with constant insulation thickness. 

For the analysis of compact refrigerators, DOE considered the change in efficiency of 

typically available compressors sized appropriately for the product. For standard-size 

EERE-2008-BT-STD-0012 COMMENT 22
5-15 

products the DOE used a constant compressor efficiency in the analysis, based on 

observation that compressor efficiency does not vary significantly in the capacity range 

suitable for most standard-size products (this is discussed in greater detail in section 

 5.8.3). The energy—adjusted volume slopes calculated in this analysis are presented in 

Table 5.4.11 below. The table also shows the slopes of the proposed baseline energy 

use—adjusted volume relationships of Table 5.4.10 above. The comparison provides an 

indication of whether adjustment might be required to the proposed baseline energy use 

relationships, which are based on the current energy conservation standards and the 

expected impacts of the expected revised test procedure. The comparison shows that 

consideration may need to be given to whether the slope for the baseline energy use 

relationships should be adjusted for product classes 5, 11, 11A, and 18. By extension, 

similar consideration should be given to the slopes for product classes 4 and 5A, which 

were not directly examined, but the trends for which should be predicted by the analyses 

for product classes 7 and 5, respectively. The question of whether adjustments should be 

made to the baseline energy use relationships of Table 5.4.10 is a topic on which DOE 

requests comment from stakeholders. 

Table 5.4.11 DOE Assessment of the Slope of the Energy Use Curve 

Product Class 

Calculated 

Energy Curve Slope from 

ERA Models* 

Slope from Proposed 

Baseline Energy Use 

Equation (Table 5.4.10) 

3 13.3 10.7 

5 12.3 5.3 

7 11.9 11.3 

9 9.4 12.3 

10 7.7 9.7 

11 16.4 12.0 

11A 20 to 35** 10.5 

18 4.5 10.3 

* Analysis was conducted for both the small and large units analyzed for product classes 3, 5, 7, 

9, 10, 18. Values shown are averages of slopes for the two ERA models. 

** The energy use—adjusted volume relationship is nonlinear, with higher slope at lower 

volumes. The slopes indicated are applicable for a range of adjusted volumes from 1.7 to 3.6 ft3

.

5.4.3 Incremental Efficiency Levels 

DOE established a series of incremental efficiency levels, for which it has 

developed incremental cost data and quantified the cost-efficiency relationship for each 

of the seven analyzed product classes. The incremental efficiency levels are shown in 

Table 5.4.12 below. Maximum available efficiency levels for the analyzed product 

classes, which are based on a survey of product databases and manufacturer websites, are 

tabulated in Table 5.4.13 below. Maximum technology levels, which are based on DOE 

energy modeling using all applicable design options, are discussed in Section 5.4.4. 

EERE-2008-BT-STD-0012 COMMENT 22
5-16 

Table 5.4.12 Incremental Efficiency Levels (% Energy Use Less than Baseline) 

Level 

Standard-Size 

Refrigerator-Freezers 

(PC 3, 5, 7) 

Standard-Size 

Freezers 

(PC 9, 10) 

Compact Refrigerators 

and Freezers 

(PC 11, 18) 

1 10% 10% (Current 

ENERGY STAR) 10% 

2 15% (Former 

ENERGY STAR) 15% 15% 

3 20% (Current 

ENERGY STAR *) 20% 20% (Current ENERGY STAR *) 

4 25% (CEE Tier 2) 25% 25% (CEE Tier 2) 

5 30% (CEE Tier 3) 30% 30% (CEE Tier 3) 

6 35% 35% 35% 

7 40% 40% 40% 

8 45%** 45% 45% 

*Current ENERGY STAR is equivalent to CEE Tier 1 for standard-size refrigerators and refrigeratorfreezers and for all compact products. 

**The 45% efficiency level was not analyzed for product class 7 because it is beyond maximum 

technology according to DOE analysis. 

Table 5.4.13 Maximum Available Levels (%Energy Use Less than Baseline) 

Maximum Available Level** 

PC 

% Volume (ft3) Brand & Model # 

3 22% 18 Frigidaire FRT18HS7J 

5 26% 19 Sub-Zero BI30US8 

7 30% 26 Whirlpool GS5VHA 

9 43% 8 Gaggenau RF411700 

10 16% 9 W.C.Wood C09 

11 26% 6 MicroFridge 5.6MFR 

18 21% 5 Haier ESCM050 

** Source: ENERGY STAR Database (4/7/2009), CEE Database (3/16/2009), CEC Database (4/1/2009), 

Manufacturer websites 

5.4.4 Maximum Technology Level 

DOE defines a maximum technology level to represent the theoretical maximum 

possible efficiency if all available design options are incorporated. The maximum 

technology level is not to be confused with the maximum available level, which is the 

highest efficiency unit currently available on the market. In many cases the maximum 

technology level is not commercially available because it is not yet economically 

feasible. Figure 5.4.1 below shows the maximum available efficiency levels, based on the 

ENERGY STAR database of 4/9/09, with adjustments including deleting products which 

are no longer for sale based on the CEC database and manufacturers’ and retailers’ 

EERE-2008-BT-STD-0012 COMMENT 22
5-17 

websites. For this chart, the all-refrigerator products of product classes 1, 3, 11, and 13 

were not included—some of these have higher efficiency levels than those shown in the 

chart. The maximum available efficiency product varies significantly among the product 

classes, from 1% for product class 13 to 51% for product class 2. 

As mentioned, the maximum technology level may not represent available 

products because they may not be economically feasible. DOE determined maximum 

technology levels using energy modeling. The energy models for the maximum 

technology levels were based on use of all design options applicable for the specific 

product classes. While these product configurations have not likely been tested as 

prototypes, all of the individual design options have been incorporated in available 

products. The maximum technology efficiency levels for the analyzed product classes are 

presented in Table 5.4.14 below. These efficiency levels are significantly higher than the 

maximum available products. The costs of the maximum technology efficiency level 

designs are also quite high, being based on extensive use of high-cost design options such 

as vacuum insulating panels as well as all applicable lower-cost design options. Table 

5.4.14 indicates which design options were used for each of the product classes. 

Figure 5.4.1 Maximum Efficiency Levels Available by Product Class 

EERE-2008-BT-STD-0012 COMMENT 22
5-18 

Table 5.4.14 Maximum Technology Levels 

Design Options Used 

Product Class % Lower Energy 

Brushless DC Evaporator Fan Brushless DC Con

denser Fan 

Forced Convection Condenser Larger Evaporator Larger Condenser Thicker Insulation VIPs Variable Speed CompressorAdaptive Defrost Variable AntiSweat 

3 56%       

5 53%        

7 45%       

9 55%        

10 51%      

11 75%      

18 52%    

Note: Levels indicated are the average determined for the two products of each product 

class analyzed in detail. 

5.5 DATA COLLECTION 

DOE collected data from a number of sources to support the engineering analysis. 

The key sources include the following. 

 AHAM 

 Component Vendors 

 Reverse-Engineering of Products 

 Manufacturer Interviews 

 Energy Tests 

The data collection process is described in greater detail in the following sections. 

5.5.1 Manufacturer-Submitted Shipment and Cost Data from AHAM 

DOE included draft data requests sheets to support the engineering and other 

DOE analyses in the framework document as Tables A1 through A10 of that document. 

Some of these tables were revised based on comments received during the framework 

comment period. For example, incremental cost data was provided for up to 35% 

efficiency level, and included a 10% efficiency level, which replaced the 15% efficiency 

level of the draft tables. Other requests DOE made to AHAM in addition to the requests 

made in the framework document include the following. 

EERE-2008-BT-STD-0012 COMMENT 22
5-19 

 Historical shipment data for Wine Coolers, broken out by key types: manual 

defrost/auto defrost. 

 Historical shipment data for Built-in Refrigerators, disaggregated by product class. 

 Recent shipment data for products incorporating a wine cooler compartment with 

either (1) a fresh food compartment, (2) a freezer compartment, or (3) both a fresh 

food and a freezer compartment. 

 Recent shipment data for French Door refrigerators broken out between products with 

and without TTD ice service. 

 Recent shipment data for convertible-bottom-drawer refrigerators (products with 

three doors configured as a side-by-side arrangement on top with a single drawer 

below, and for which the upper compartments are freezer and fresh food 

compartments and the drawer is convertible). 

 Percent of refrigerator-freezers shipped with ice makers for applicable product classes 

(3, 4, 5, 13, 14, 15), historical data if possible. 

 Total shipments of ice makers (any breakdown by (a) installed at factory, (b) installed 

by dealer, (c) installed by homeowner?), historical data if possible. 

 For as many refrigerator, refrigerator-freezer, and freezer models as practical, data on 

the impact of the proposed changes in compartment temperature and volume 

calculation method: 

o Compartment Volumes: volumes calculated according to the current 

procedure and according to the new procedure, with indication of product 

class. 

o Energy use (for refrigerators and refrigerator-freezers only): Annual energy 

use measurements for units tested for both temperatures (i.e. not Energy Label 

data—this should be energy test values calculated based on test data for the 

old temperatures and the new temperatures for sequential tests of the same 

unit. This will typically require three tests to make sure that both sets of 

temperatures are bracketed. 

o It is anticipated that data for product classes 3 and 13 would be separated 

according to whether the product is a refrigerator-freezer or all-refrigerator. 

AHAM supported the rulemaking by supplying much of this data. AHAM 

supplied DOE with aggregated shipment-weighted average data for many of the 

submittals in order to avoid divulging data submitted by individual manufacturers. The 

AHAM incremental cost data included incremental material, labor, and overhead costs as 

well as conversion capital expenditures and one-time product conversion expenses for 

each efficiency level. These data are presented in Section 5.9.2, where they can more 

readily be compared with the results of DOE analysis. Data associated with other AHAM 

submittals are presented in the relevant chapters and sections most directly related to the 

data in question. 

5.5.2 Component Vendor Data 

DOE directly contacted major suppliers of key refrigerator and freezer 

components to obtain performance and cost data to support its design option analysis. 

The data received from vendors was compared with information received from 

EERE-2008-BT-STD-0012 COMMENT 22
5-20 

manufacturers during the manufacturer interviews in order to develop input values for 

performance and cost parameters for the energy modeling and manufacturing cost 

modeling. This vendor solicitation effort consisted of phone interviews, email 

correspondence, and in-person interviews. Table 5.5.1 lists the vendors contacted. 

DOE also obtained from the compressor vendors or their websites complete 

performance data for compressors used in many of the energy analyses, including 

analyses for baseline and improved-efficiency configurations. 

Table 5.5.1 Component Vendors Contacted by DOE during Engineering Analysis 

Component Type Vendors 

Compressors Embraco 

Tecumseh 

Matsushita 

Danfoss 

LG 

Huayi 

ACC (ZEL) 

Jiangsu Baixue Electric Appliances Co.,Ltd

Fan Motors Matsushita 

VIPs va-Q-tec 

Matsushita 

Foam Insulation BASF 

Foam Supplies 

Heat Exchangers Brazeway 

5.5.3 Reverse Engineering 

DOE purchased a number of representative refrigerators and freezers as part of 

the engineering analysis in order to examine design and fabrication details. This reverseengineering included detailed measurement of dimensions, system and component-level 

power measurements, measurement of air flows for products with forced convection heat 

exchangers, and physical teardowns. The results of the reverse engineering process were 

used as input to the manufacturing cost modeling and the energy use modeling. This 

section describes the selection of products for reverse-engineering as well as some of the 

measurements made to support subsequent modeling. Section 5.6 provides a more 

thorough description of the physical teardown process used to support manufacturing cost 

modeling. 

5.5.3.1 Selection of Products for Reverse Engineering 

DOE performed reverse engineering on units rated at baseline and improved (i.e., 

ENERGY STAR) energy consumption levels for the seven analyzed product classes. 

DOE chose at least one representative small-size and one large-size unit to cover the 

range of volumes within each product class. In order to best examine the design choices 

associated with efficiency improvements, DOE selected baseline efficiency/ENERGY 

EERE-2008-BT-STD-0012 COMMENT 22
5-21 

STAR product pairs if possible, for which the two products were identical other than the 

differences necessary for the ENERGY STAR-rated product to achieve higher efficiency. 

Such product pairs included the 21 ft3

 Top-Mount refrigerator-freezers, the 26 ft3 SideMount refrigerator-freezers, the 20 ft3 upright freezers, and the 4 ft3 compact refrigerators. 

Table 5.5.2 lists descriptions of the selected units and indicates whether energy testing 

was performed (see Section 5.5.5 for more on energy testing). 

Table 5.5.2 Selected Units for Reverse-Engineering and Energy Testing 

PC Product Description 

Energy % 

Less than 

Baseline 

Energy 

Test 

Physical 

Teardown 

Energy Use 

Model 

16 ft3 Top-Mount R-F 0%   

21 ft3 3 Top-Mount R-F 0%   

21 ft3

 E* Top-Mount R-F 20%   

4 22 ft3 Side-Mount R-F† 0%   

18.5 ft3 E* Bottom-Mount R-F 15%*   

25 ft3 5 E* Bottom-Mount R-F 1 20%  

25 ft3 E* Bottom-Mount R-F 2 20%  

25 ft3 French Door E* BottomMount R-F 20% 

5A 26 ft3

 French Door E* BottomMount R-F 20% 

26 ft3 Side-Mount R-F 0%   

7 26 ft3

 E* Side-Mount R-F 20%   

14 ft3 Upright Freezer 0%  

20 ft3 Upright Freezer 2%   

20 ft3 E* Upright Freezer 1 12%   9 

20 ft3 E* Upright Freezer 2 10% 

15 ft3 Chest Freezer 1%   

15 ft3 10 E* Chest Freezer 11%  

20 ft3

 Chest Freezer 0%  

1.7 ft3 Compact Refrigerator 7%   

4 ft3 11 Compact Refrigerator 2%  

4 ft3 E* Compact Refrigerator 22%  

3.4 ft3 Compact Chest Freezer 0%  

7 ft3 18 Compact Chest Freezer 1 1%  

7 ft3

 Compact Chest Freezer 2 1%  

*Exact efficiency level is not known because product literature did not include indication 

of separate compartment volumes. 

†This product was thought to be product class 7 when purchased. 

EERE-2008-BT-STD-0012 COMMENT 22
5-22 

5.5.3.2 Collection of Energy Modeling Data 

DOE examined each unit prior to teardown to record details to be used as input 

for the energy modeling. The key measurements are described in this section. 

The rated refrigerated volumes for each product’s compartments and its rated 

energy use were based on product literature or the ENERGY GUIDE. In the case of the 

3.4 ft3

 chest freezer, the product literature did not provide an indication of energy use, 

and the product did not arrive with an ENERGY GUIDE. For this product, DOE assumed 

that energy use was exactly equal to maximum allowable energy use for the product 

class. 

Power input for the product was measured for a period of 24 or more hours. This 

measurement was not intended to be an energy test, but provided useful information 

regarding the product controls, including off-cycle wattage, defrost heater on-time, and 

defrost interval (or indication of variable defrost). The power measurements for the 

products were made in the reverse engineering test laboratory, whose ambient 

temperature may have covered a broad range from 65  ̊F to 85  ̊F during the time that 

these measurements were carried out. Also, careful attention was not paid to the 

temperature setpoints for this measurement—the setpoints generally were left in the asshipped positions. 

Component-level power measurements were carried out for fans, defrost heaters, 

and manual defrost controls for the products which had these components. Power was 

also measured for some products’ anti-sweat heaters. 

Air flow measurements were made for all forced-convection heat exchangers. 

These measurements were made with a hot wire anemometer. The location of these 

measurements varied depending on the heat exchanger type and configuration. The 

determination of air flows based on these measurements is not very reliable, so this 

measurement was used as an indication of air flow trends more than exact indication of 

air flow for the various products. 

Details of the cabinet size and insulation thickness were based on direct physical 

measurements. Most of these measurements were made prior to the teardown, but 

measurements of some parameters, such as outer shell thickness, inner liner thickness, 

and insulation thickness, were made during the teardown process. Use of insulation other 

than polyurethane foam was noted as part of the teardown process. Frame area details 

including gasket details were observed, and recorded with pictures as part of the 

teardown process. 

Heat exchanger details were recorded, including type, configuration, numbers of 

tubes and fins, dimensions, etc. For cold wall and hot wall heat exchangers this data was 

recorded during the product teardown process. The details of anti-sweat heaters were also 

determined during the teardown process, including the layout for refrigerant anti-sweat 

loops. The details of suction line heat exchangers were similarly determined during 

teardown. 

EERE-2008-BT-STD-0012 COMMENT 22
5-23 

Component manufacturer and model data were recorded for key components such 

as compressors, fans, and controls. 

The energy modeling data for the teardown products are presented in detail in 

appendix 5-A. 

5.5.4 Manufacturer Interviews 

DOE’s contractor discussed engineering issues with manufacturers during the preNOPR interviews. The engineering questions were consolidated into an engineering 

questionnaire, which guided the interview process for all of these discussions. The 

engineering questionnaire is shown in appendix 5-A. Key technical topics addressed 

during these discussions include the following: 

 Typical characteristics of components and typical design details (i.e. such as 

insulation thicknesses) used for key product classes. 

 Typical design differences between baseline and ENERGY STAR products. 

 Differences in design pathways and incremental costs across different product classes 

 Viability of technology options, and their typical costs. 

All of these interviews were conducted under non-disclosure agreements with the 

manufacturers. Hence, none of the individual responses can be reported. However, values 

for many of the parameters and costs used in the engineering analysis were based on 

aggregated input from these discussions. 

5.5.5 Energy testing 

DOE conducted energy testing to verify energy use of many of the products 

obtained for reverse engineering, to provide refrigeration system data to support energy 

use modeling, and to evaluate the difference in energy use between current energy test 

compartment temperatures and the new temperatures associated with the expected revised 

test procedure. 

Twelve of the 24 units were tested, as indicated in Table 5.5.2, including all of the 

refrigerator-freezer models and one each of the upright freezers, chest freezers, and 

compact refrigerators. No compact chest freezers were tested. 

Energy testing was carried out by an independent test lab according to the DOE 

Energy Test Procedure as described in 10 CFR Part 430 Subpart B, Appendix A1 or B1, 

with reference to AHAM Standard HRF-1-1979 as applicable. In addition to the standard 

energy test results, DOE requested specific temperature measurements to be taken in 

various locations during the test to better understand the refrigeration system operating 

characteristics. Specifically, low-mass thermocouples were mounted in good thermal 

contact with the surface of refrigerant tubing, insulated externally from local ambient air. 

Table 5.5.3 lists the additional measurements. 

EERE-2008-BT-STD-0012 COMMENT 22
5-24 

Table 5.5.3 Additional Thermocouple Locations for Energy Test 

Thermocouple Location RefrigeratorFreezers 

Upright 

Freezer 

Chest 

Freezer 

Compact 

Refrigerator 

Discharge 4” from shell    

Condenser Inlet  

Condenser Mid 

Condenser Outlet    

Evaporator Inlet   

Evaporator Outlet    

Suction 4” from shell    

Condenser Air Inlet  

Pan Heater In  

Pan Heater Out  

Hot Wall Condenser 

Surface 

  

Compressor 

Compartment Air 

  

Cold Wall Evaporator 

Surface  

Two units of the 1.7 ft3 compact refrigerator were tested because the first of these 

was not able to hold proper internal temperatures. 

5.6 MANUFACTURING COST MODELING 

5.6.1 Generation of Bills of Materials 

The end result of each teardown is a structured bill of materials (BOM). DOE 

developed structured BOMs for each of the physical teardowns. Structured BOMs 

describe each product part and its relationship to the other parts in the estimated order in 

which manufacturers assembled them. The BOMs describe each fabrication and assembly 

operation in detail, including the type of equipment needed (e.g., presses, drills), the 

process cycle times, and the labor associated with each manufacturing step. The result is 

a thorough and explicit model of the production process, which includes space, conveyor, 

and equipment requirements by planned production level. 

The BOMs incorporate all materials, components, and fasteners classified as 

either raw materials or purchased parts and assemblies. The classifications into raw 

materials or purchased parts were based on DOE’s previous industry experience, recent 

information in trade publications, and discussions with high- and low-volume original 

equipment manufacturers (OEMs). DOE also visited manufacturing plants to reinforce its 

understanding of the industry’s current manufacturing practices for each of the three 

product categories. 

EERE-2008-BT-STD-0012 COMMENT 22
5-25 

For purchased parts, the purchase price is estimated based on volume-variable 

price quotations and detailed discussions with manufacturers and component suppliers. 

For fabricated parts, the prices of “raw” materials (e.g., tube, sheet metal) are estimated 

on the basis of 5-year averages (see Section 5.6.4.4). The cost of transforming the 

intermediate materials into finished parts is estimated based on current industry pricing. 

DOE shared major estimates with manufacturers during the engineering manufacturer 

interviews to gain feedback on the analysis, its methodology, and preliminary results. 

5.6.2 Cost Structure of the Spreadsheet Models 

The manufacturing cost assessment methodology used is a detailed, componentfocused technique for calculating the manufacturing cost of a product (direct materials, 

direct labor, and the overhead costs associated with production). The first step in the 

manufacturing cost assessment was the creation of a complete and structured BOM from 

the disassembly of the units selected for teardown. The units were dismantled, and each 

part was characterized according to weight, manufacturing processes used, dimensions, 

material, and quantity. The BOM incorporates all materials, components, and fasters with 

estimates of raw material costs and purchased part costs. Assumptions on the sourcing of 

parts and in-house fabrication were based on industry experience, information in trade 

publications, and discussions with manufacturers. Interview and plant visits were 

conducted with manufacturers to add industry experience on the methodology and 

pricing. 

The last step was to convert this information into dollar values. To perform this 

task, DOE collected information on labor rates, tooling costs, raw material prices, and 

other factors. DOE assumed values for these parameters using internal expertise and 

confidential information available to DOE contractors. Although most of the assumptions 

are manufacturer specific and cannot be revealed, Section 5.6.4.3 provides a discussion of 

the values used for each assumption. 

In summary, DOE assigned costs of labor, materials, and overhead to each part 

whether purchased or produced in-house. DOE then aggregated single-part costs into 

major assemblies (e.g., door assembly, heat exchanger assembly, shelving, packaging, 

controls, bottom components assembly, wiring harnesses, inner/outer wrapper assembly, 

etc.) and summarized these costs in a worksheet. During engineering interviews with 

manufacturers, DOE showed key estimates from the cost model and asked for feedback. 

DOE considered any information manufacturers gave that was relevant to the cost model 

and incorporated it into the analysis, if appropriate. 

5.6.3 Cost Model and Definitions 

Once DOE disassembled selected units, gathered information from manufacturer 

catalogs on additional products, and identified technologies, DOE created an appropriate 

manufacturing cost model that could translate physical information into manufacturer 

production costs (MPCs). The cost model is based on production activities and divides 

factory costs into the following categories: 

EERE-2008-BT-STD-0012 COMMENT 22
5-26 

 Materials: Purchased parts (i.e. compressor, fan motors, control boards, door handles, 

shelf frames, etc.), raw materials (i.e., cold rolled steel, copper tube, etc.), and indirect 

materials that are used for processing and fabrication. 

 Labor: Fabrication, assembly, indirect, and supervisor labor. Fabrication and 

assembly labor cost are burdened with benefits and supervisory costs. 

 Overhead: Equipment, tooling, and building depreciation, as well as utilities, 

equipment and tooling maintenance, insurance, and property taxes. 

5.6.3.1 Cost Definitions 

Because there are many different accounting systems and methods to monitor 

costs, DOE defined the above terms as follows: 

 Direct material: Purchased parts (out-sourced) plus manufactured parts (made inhouse from raw materials). 

 Indirect material: Material used during manufacturing (e.g., welding rods, adhesives). 

 Fabrication labor: Labor associated with in-house piece manufacturing. 

 Assembly labor: Labor associated with final assembly. 

 Indirect labor: Labor costs that scaled with fabrication and assembly labor. This 

included the cost of technicians, manufacturing engineering support, stocking, etc. 

that were assigned on a span basis. 

 Equipment and plant depreciation: Money allocated to pay for initial equipment 

installation and replacement as the production equipment wears out. 

 Tooling depreciation: Cost for initial tooling (including nonrecurring engineering and 

debugging of the tools) and tooling replacement as it wears out. 

 Building depreciation: Money allocated to pay for the building space and the 

conveyors that feed and/or make up the assembly line. 

 Utilities: Electricity, gas, telephones, etc. 

 Maintenance: Annual money spent on maintaining tooling and equipment. 

 Insurance: Appropriated as a function of unit cost. 

 Property Tax: Appropriated as a function as unit cost. 

5.6.4 Cost Model Assumptions Overview 

As discussed in the previous section, assumptions about manufacturer practices 

and cost structure played an important role in estimating the final product cost. Some 

assumptions were different for specific manufacturers, depending on their market 

position, manufacturing practices, and size. 

In converting physical information about the product into cost information, DOE 

reconstructed manufacturing processes for each component using internal expertise and 

knowledge of the methods used by the industry. DOE used assumptions regarding the 

manufacturing process parameters (e.g., equipment use, labor rates, tooling depreciation, 

and cost of purchased raw materials) to determine the value of each component. DOE 

then summed the values of the components into assembly costs and, finally, the total 

product cost. The product cost included the material, labor, and overhead costs associated 

EERE-2008-BT-STD-0012 COMMENT 22
5-27 

with the manufacturing facility. The material costs included both direct and indirect 

materials. The labor costs included fabrication, assembly, indirect, direct, and supervisor 

labor rates, including the associated overhead. 

The labor costs included assembly, fabrication, supervisor, and indirect labor. 

Overhead costs included equipment depreciation, tooling depreciation, building 

depreciation, utilities, equipment, tooling maintenance, insurance, property, and taxes. 

DOE used the information gathered from manufacturer interviews to make 

updates to the cost model. These changes involved updating component and material 

pricing. 

The next sections discuss specific assumptions about outsourcing, factory 

parameters, production volumes, and material prices. When the assumptions are 

manufacturer-specific, they are presented as industry averages to prevent disclosure of 

confidential information. 

5.6.4.1 Fabrication Estimates 

DOE characterized parts based on whether manufacturers purchased them from 

outside suppliers or fabricated them in-house. For purchased parts, DOE estimated the 

purchase price. For fabricated parts, DOE estimated the price of raw materials (e.g., tube, 

sheet metal) and the cost of transforming them into finished parts. Whenever possible, 

DOE obtained price quotes directly from the manufacturers’ suppliers. 

DOE based the manufacturing operations assumptions on internal expertise, 

interviews with manufacturers, and manufacturing facilities site visits. The major 

manufacturer processes identified and developed for the spreadsheet model are listed in 

Table 5.6.1. Fabrication process cycle times were estimated and entered into the BOM. 

Table 5.6.1 Cost Model In-House Manufacturing Operation Assumptions 

Fabrication Finishing Assembly/Joining Quality Control 

Fixturing 

Stamping/Pressing 

Turret Punch 

Tube Forming 

Brake Forming 

Cutting & Shearing 

Insulating & 

 Insulation Injection 

Tube/Wire Bending 

Brazing 

Vacuum Forming 

Blow Molding 

Washing 

Painting 

Powder Coating 

De-burring 

Polishing 

Refrigerant Charging 

Adhesive Bonding 

Spot Welding 

Seam Welding 

Packaging 

Inspecting & Testing 

EERE-2008-BT-STD-0012 COMMENT 22
5-28 

5.6.4.2 Production Volumes Assumptions 

A manufacturer’s production volumes vary depending on several factors, 

including market share, the type of product produced (i.e., standard- size refrigeratorfreezer, compact refrigerator-freezer, etc.), and if the manufacturer produces other similar 

products. DOE based production volume assumptions for these residential refrigeration 

products on shipment data, industry knowledge, and engineering manufacturer 

interviews. The manufacturing plant annual production capacities used for the analyses 

differ by product class as follows. 

 Product Classes 3 and 6: 1.5 million 

 Product Classes 5 and 5A: 0.5 million 

 Product Classes 4 and 7: 1 million 

 Product Class 9: 150,000 

 Product Class 10: 100,000 

 Product Class 11: 0.5 million 

 Product Class 18: 100,000 

5.6.4.3 Factory Parameters Assumptions 

DOE used information gathered from publicly available literature, manufacturer 

interviews, and analysis of common industry practices to formulate factory parameters 

for each type of manufacturer. DOE first made assumptions about a set of preliminary 

factory parameters before the manufacturer interviews. DOE then revised the 

assumptions using comments and information gathered during the interviews. Table 5.6.2 

lists DOE’s assumptions for refrigerator manufacturers. 

Table 5.6.2 Refrigerator & Freezer Factory Parameter Assumptions 

Parameter Assumption 

Plant Capacity (units/yr) see section 5.6.4.2 

Actual Annual Production Volume (units/yr) 5/6 of plant capacity 

Fabrication Labor Wages ($/hr) 16.00 

Fringe Benefits Ratio 50% 

5.6.4.4 Material Cost Assumptions 

DOE determined the cost of raw materials using publicly available information 

such as the American Metals Marketa

, interviews with manufacturers, and direct 

discussions with material suppliers. Common metals used in the fabrication of residential 

refrigerator products include plain cold rolled steel (CRS), copper tubing, and aluminum. 

There have been large fluctuations in metal prices over the last few years. To account for 

these fluctuations, DOE used a 5-year average of metal prices from the Bureau of Labor 

 

a

 American Metals Market. Last accessed November 2008. <http://www.amm.com>. 

EERE-2008-BT-STD-0012 COMMENT 22
5-29 

Statistics Producer Price Indices (PPIs) spanning 2003 to 2008 with an adjustment to 

2008$.b

 DOE used the PPIs for copper rolling, drawing, and extruding and steel mill 

products, and made the adjustments to 2008$ using the gross domestic product implicit 

price deflator.c

 Table 5.6.3 shows the 5-year average metal prices DOE used for the 

analysis. 

Table 5.6.3 Five-Year Metal Prices (2003-2008) 

Metals Cost ($/lb) ($2008) 

Plain Cold Rolled Steel (CRS) $0.36 

Painted CRS $0.57 

Galvanized CRS $0.48 

Aluminized CRS $0.54 

Textured CRS $0.61 

CRS Tube $0.74 

Stainless Steel $2.06 

Fin Aluminum $1.64 

Plain Copper $2.13 

Copper Tube – Plain $2.76 

Brass $1.45 

Galvanized Wire $0.60 

Standard Aluminum $1.26 

Copper Tube – Rifled $2.96 

Aluminum Tube $1.89 

Hot Rolled Steel $0.37 

Hot Rolled Steel Pipe $0.47 

Between 2003 and 2006, the price of steel rose over 60 percent and the price of 

copper rose over 140 percent. DOE used a 5-year average in material prices from 2003 to 

2008 to normalize these drastic increases to better represent long-term material price 

averages. 

For resins used in the fabrication of these refrigeration products, DOE used 

current resin prices gathered from industry research, publications such as Plastics News,d

and interviews with manufacturers. Resin prices are determined by quantity and supplier 

(i.e., contract specific) and therefore have no true fixed market price. For this analysis, 

DOE used market resin prices current as of November 2008. The prices of resins have 

been constantly increasing and closely follow petroleum prices. Table 5.6.4 shows the 

current resin prices used in the analysis. 

 

b

 U.S. Department of Labor, Bureau of Labor Statistics, Producer Price Indices. Last accessed November 

2008. <http://www.bls.gov/ppi>. 

c

 U.S. Department of Commerce, Bureau Economic Analysis, Gross Domestic Product Implicit Price 

Deflator. Last accessed November 2008. <https://bea.gov/bea/dn/nipaweb/TableView.asp#Mid>. d

 Plastic News, Resin Pricing. Last accessed March 21, 2008. 

<http://www.plasticsnews.com/subscriber/headlines.phtml>. 

EERE-2008-BT-STD-0012 COMMENT 22
5-30 

Table 5.6.4 Most Prevalent Resin Prices as of December 2007 

Resins Cost ($/lb) ($2008) 

Polystyrene (PS) $0.66 

Polypropylene (PP) $0.67 

Low Density Polyethylene $0.73 

Polyurethane Foam (non-HCFC blowing agent) $1.29 

PVC (Hard) $0.47 

5.6.5 Manufacturing Production Cost 

Once the cost estimate for each teardown unit was finalized, a detailed summary 

was prepared for relevant components, subassemblies, and processes. The BOM thus 

details all aspects of product costs. DOE totaled the cost of materials, labor, and direct 

overhead used to manufacture a product in order to calculate the manufacturing 

production cost.e

 Figure 5.6.1 shows the general breakdown of costs associated with 

manufacturing a product. 

Manufacturer

Selling Price

Full Cost of

Product

Manufacturer

Production Cost

Direct

Labor

Direct

Material Overhead

Indirect Labor

Indirect Material

Maintenance

Depreciation

Taxes

Insurance related

to assets

Non‐Production

Cost

Selling

Market

Research

Advertising

POS Promotion

Salesperson

Comp & Travel

Logistics

(Warehousing,

Delivery, Record‐

Keeping, Order

Processing)

General &

Admin.

Costs of

Service &

Staff Units

General

Corporate

Costs

(Comp, etc)

R & D

Costs associated

with finding new

and improved

products or

processes

Code

Compliance

Modernization

Interest

Cost of

borrowing

funds

Profit

Figure 5.6.1 Full Production Costs 

 

e

 When viewed from the companywide perspective, the sum of all material, labor, and overhead costs 

equals the company’s sales cost, also referred to as the cost of goods sold (COGS). 

EERE-2008-BT-STD-0012 COMMENT 22
5-31 

The full cost of product is broken down into two main costs, the full production 

cost or MPC, and the non-production cost. The non-production cost is equal to the 

manufacturer markup minus profits. 

Technologies used in the units subject to teardown are noted in the summary sheet 

of each cost model and are cost-estimated individually. Thus, various implementations of 

technologies can be accommodated, ranging from assemblies that are entirely purchased 

to units that are entirely from raw materials. Hybrid assemblies, consisting of purchased 

parts and parts made on site are thus also accommodated. 

5.6.6 Incremental Cost Estimates 

Incremental costs were determined for design options applied to the baselineefficiency refrigerator models. The approach for estimating the incremental costs varied 

depending on the design option. Details in this calculation which are specific to 

individual design options are discussed in Section 5.8, which discusses design options. 

Aspects of the incremental cost calculation which were generally applied to multiple 

design options are discussed in this section. 

Many of the design options involve replacement of a current component with a 

higher-efficiency component. For these design options, the increased price paid by the 

OEM for the new component represents the manufacturing cost increase—other elements 

of product cost such as overhead and capital expenditures would be insignificantly 

affected by these design changes. The appropriate price increases are discussed in Section 

 5.8 by design option. 

For some design changes, calculating the cost impact of the design change 

required direct use of the manufacturing cost model to determine changes to a number of 

parts. The baseline manufacturing cost was subtracted from the manufacturing cost of the 

modified design to determine the incremental cost of the design option. This approach 

was used in particular for insulation thickness increases and heat exchanger size increases 

for cold wall and hot wall heat exchangers. 

5.6.6.1 Overhead and Depreciation Costs 

Some design options involve costs in addition to the price increase associated 

with a new component. For such options, there may be overhead and capital expenses 

which must be added to the direct costs associated with the design option. Estimates of 

typical additional costs associated with overhead and depreciation for manufacture of 

refrigeration products were made for the reverse-engineering models, using estimates of 

these costs provided by the manufacturing cost model. These calculations were carried 

out based on proposed typical production plant capacities, with actual production 

volumes estimated to be 5/6 of plant capacities. The annual plant capacities for the 

product classes used in these calculations are as indicated in section 5.6.4.2. 

The additional costs are presented as percentage of direct material and labor costs 

in Table 5.6.5 below. The averages for the listed product class categories were used to 

EERE-2008-BT-STD-0012 COMMENT 22
5-32 

increase direct material and labor costs for some design options for which this adjustment 

was necessary. 

Table 5.6.5 Overhead and Depreciation Cost Ratios 

Product Class 

Group 

Product 

Class 

Product Percent 

Cost 

Ratio 

Average Percent 

Cost Ratio for 

Product Class 

Group 

16 ft3 Top-Mount R-F 31.2% 

21 ft3 3 Top-Mount R-F 23.2% 

21 ft3 E* Top-Mount R-F 23.2% 

4 22 ft3 Side-Mount R-F† 22.0% 

19 ft3 E* Bottom-Mount R-F 23.5% 

25 ft3 5 E* Bottom-Mount R-F 1 20.9% 

25 ft3

 E* Bottom-Mount R-F 2 23.3% 

26 ft3 Side-Mount R-F 20.7% 

StandardSize 

RefrigeratorFreezers 

7 26 ft3

 E* Side-Mount R-F 22.5% 

23.4% 

14 ft3 Upright Freezer 28.6% 

20 ft3 9 Upright Freezer 26.2% 

20 ft3

 E* Upright Freezer 1 25.0% 

15 ft3 Chest Freezer 35.5% 

15 ft3 E* Chest Freezer 33.2% 

StandardSize Freezers 

10 

20 ft3

 Chest Freezer 22.5% 

28.5% 

1.7 ft3 Compact Refrigerator 40.2% 

4 ft3 11 Compact Refrigerator 35.6% 

4 ft3 E* Compact Refrigerator 36.5% 

3.4 ft3 Compact Chest Freezer 42.3% 

7 ft3 Compact Chest Freezer 1 36.6% 

Compact 

Refrigerators, 

RefrigeratorFreezers, and 

Freezers 18 

7 ft3 Compact Chest Freezer 2 44.2% 

39.2% 

The manufacturing cost model estimates are consistent with overall industry 

trends. Census data shows that the average value of this cost adder for NAICS code 

335222 (Household Refrigerator and Home Freezer Manufacturing) is 27.7%. 

5.6.6.2 Depreciation Costs for Insulation Thickness Increases 

DOE considered that increases in cabinet wall and door thicknesses would require 

redesign of the entire refrigerator or freezer platform and lead to building of a new 

production plant. This conservative approach to the analysis was based on input from 

manufacturers. For such design changes, the difference in greenfield costsf

 of two designs 

would not capture the depreciation costs which would be incurred by the manufacturer 

and which would add to the product cost after such a platform conversion. DOE 

conservatively used the greenfield depreciation costs per product determined by the 

 

f

 Greenfield costs are defined as the costs associated with building a new manufacturing facility, to be 

distinguished from the costs required to upgrade or modify a facility. 

EERE-2008-BT-STD-0012 COMMENT 22
5-33 

manufacturing cost model as an additional cost for wall thickness increases. The 

calculation of manufacturing costs for all of the teardown products based on typical plant 

capacities described above was used as the basis for the determination of greenfield 

depreciation costs per product. The results of the calculations are summarized in Table 

 5.6.6 below. Average depreciation costs were applied in the engineering analyses for 

product class groups with similar levels of depreciation costs, as indicated in the table. 

Table 5.6.6 Greenfield Depreciation Costs per Product 

Product 

Class Group 

Product 

Class 

Product Depreciation 

Cost 

Average 

Depreciation 

Cost for 

Product Class 

Group 

16 ft3 Top-Mount R-F $29.60 

21 ft3 3 Top-Mount R-F $23.55 

21 ft3

 E* Top-Mount R-F $23.97 

4 22 ft3 Side-Mount R-F† $28.95 

19 ft3 E* Bottom-Mount R-F $27.49 

25 ft3 5 E* Bottom-Mount R-F 1 $27.95 

25 ft3 E* Bottom-Mount R-F 2 $39.57 

26 ft3 Side-Mount R-F $26.74 

StandardSize 

RefrigeratorFreezers 

7 26 ft3

 E* Side-Mount R-F $28.14 

$27.05 

14 ft3 Upright Freezer $19.08 

20 ft3 9 Upright Freezer $18.21 

20 ft3 E* Upright Freezer 1 $18.41 

15 ft3 Chest Freezer $18.54 

15 ft3 10 E* Chest Freezer $19.59 

20 ft3 Chest Freezer $17.31 

3.4 ft3 Compact Chest Freezer $21.00 

7 ft3 Compact Chest Freezer 1 $16.91 

Freezers 

18 

7 ft3

 Compact Chest Freezer 2 $15.32 

$18.26 

1.7 ft3 Compact Refrigerator $8.35 

4 ft3 Compact Refrigerator $9.29 

Compact 

Refrigerators 11 

4 ft3

 E* Compact Refrigerator $9.29 

$8.98 

5.6.6.3 G&A and Profit 

DOE estimated the further addition to the manufacturer selling price associated 

with G&A and profit for the appliance industry as 26% of manufacturer production cost. 

This adder was applied to all of the MPC estimates in order to determine manufacturer 

selling price (MSP) numbers. This markup is described in more detail in chapter 6. 

EERE-2008-BT-STD-0012 COMMENT 22
5-34 

5.7 ENERGY MODELING 

DOE carried out detailed energy modeling of representative baseline and 

ENERGY STAR refrigeration products as one indication of the incremental costs 

required to achieve higher efficiency levels. The products selected for reverse 

engineering provided the basis for the energy modeling. Energy model input was 

determined for these products from the data collected during the reverse engineering 

work, described in Section 5.5.3. Additional data used both as input and for calibration of 

individual product energy models was provided by energy testing as described in Section 

 5.5.5. Energy modeling was also conducted for modified designs using groups of design 

options to improve efficiency to determine the expected energy savings associated with 

the design options. Using the energy modeling results and manufacturing cost modeling 

results for these designs allowed DOE to develop incremental cost estimates for multiple 

efficiency levels based on each of the baseline products analyzed. 

DOE carried out energy modeling during this rulemaking using an improved 

version of the EPA Refrigerator Analysis (ERA) program, earlier versions of which have 

been used in previous refrigerator rulemakings. Section 5.7.1 describes the ERA model 

development briefly. A more detailed description of the program and its recent 

development is presented in appendix 5-B. 

5.7.1 Energy Model development 

ERA is a steady-state energy model that calculates heat leakage into a cabinet and 

determines the energy needed by the refrigeration system to maintain the interior 

temperatures as specified by the user. Total energy used includes the energy from the 

compressor, fan motors, defrost heater, electronic control, and anti-sweat heaters, if 

applicable. See appendix 5-B for a detailed explanation of the ERA model. 

The DOS version of ERA was developed initially under EPA-sponsorship during the late 

1980s. This was undertaken by the EPA as part of its involvement in the establishment of 

energy standards for refrigerators, refrigerator-freezers, and freezers under the National 

Appliance Energy Conservation Act of 1987 (NAECA). A developmental version of the 

program was used by the DOE as a partial basis for the energy standard established in 

1989 (effective in 1993). The work also involved extensive testing of the model against 

manufacturer-supplied refrigeration appliance design and test data. Based on these 

comparisons and manufacturer review comments through its industry organization 

(AHAM), development of the model continued until its release in 1997.1

 

ERA combined an analysis of the refrigeration load requirements of the cabinet with a 

simulation of the capacity and efficiency of the refrigeration cycle. The cabinet loads 

module was a modest enhancement of a program developed for the DOE during the late 

1970s,2 including the consideration of door-opening effects on the load and an ability to 

deal with complex insulation systems. The cycle module was a derivative of the NIST 

CYCLE 7 program,3

 which used the CSD equation of state to represent the 

thermodynamic properties of pure and mixed refrigerants,4

 adapting routines for 

EERE-2008-BT-STD-0012 COMMENT 22
5-35 

calculating refrigerant properties from REFPROP3.5

 The program, and its User’s Manual, 

were first released to the public in 1993, and for a few years were downloadable from the 

EPA website.6 Subsequent to the 1993 final rule, DOE published updated standards for 

refrigerators, refrigerator-freezers and freezers in 1997, becoming effective in 2001. 

Analysis carried out in support of the 1997 final rule involved use of the final released 

EPA version of ERA.1

 

The DOS version of ERA was subsequently modified as described in appendix 5-B, but 

these revisions were not made available to the public. During the course of this 

rulemaking, further development of the model was carried out in order to allow use of the 

model for calculation of energy use of modern residential refrigeration products and to 

allow a modern version of the program to be made available to stakeholders to validate 

DOE analysis. Key modifications made include the following. 

 Enhancement of the user-interface to a Windows environment 

 Employment of the most current refrigerant property routines 

 Incorporation of a broad range of evaporator and condenser algorithms that 

correspond to the technologies now found in modern refrigerators 

 Improved compressor modeling, with built-in procedures for validating supplied 

compressor maps 

 Improvements where desirable in the cabinet loads analysis and cycle performance 

algorithms. 

 Preparation of internal documentation of the program through extensive contextsensitive Help files. 

Many of the energy model calculations described in this chapter were made using a DOS 

version of the ERA program prior to the completion of the Windows version. 

The development history and capabilities of the program are described in more detail in 

appendix 5-B. 

5.7.2 Supplemental Spreadsheet Models 

Spreadsheet analysis tools were developed and used as part of some of the energy 

model development and calculations in order to (1) calculate airside heat transfer 

performance of spine fin evaporators, (2) determine appropriate composite insulated wall 

thermal resistivity when calculating cabinet thermal performance using vacuum panel 

insulation, and (3) adjusting ERA energy model output results for some product 

configurations for which ERA did not allow input of separate thermal resistivity for 

separate walls. 

Spine fin evaporator airside heat transfer performance was calculated using a 

spreadsheet. Equations for the model were based on the work of Holtzapple and 

Carranza.7,8 The ERA heat exchanger models (the ERAEVAP program) provided heat 

transfer coefficients for refrigerant-side heat transfer in the two-phase and superheated 

regimes. Using these values, the spreadsheet model provided the overall heat transfer 

EERE-2008-BT-STD-0012 COMMENT 22
5-36 

coefficients for the two regimes of the evaporator and the effective heat transfer area, 

which were the inputs for DOS version of ERA. 

When modeling use of vacuum insulation panels (VIPs), the cabinet walls or door 

have two regions of differing thermal resistivity. Average values of resistitivity were 

calculated and entered into ERA to model these composite insulation systems. 

The ERA model structure did not allow separate specification of insulated wall resistivity 

for the compressor compartment—the program uses the bottom surface resistivity for this 

region of the cabinet. In some cases, separate spreadsheet calculations were conducted to 

adjust energy model results to account for the different resistivity that may be used in this 

region. For this calculation, used when application of VIP to the bottom surface was 

considered, the compressor compartment thermal load was increased proportional to the 

ratio in resistivities of the modeled surface and the composite surface including VIP. The 

compressor energy use was then increased in proportion to the reduction in overall 

thermal load. 

5.7.3 Development and Calibration of ERA Current Energy Test Models 

ERA modeling during the engineering analysis involved the following three 

phases. 

 Modeling of existing products based on the current energy test procedure. 

 Adjustment of models to represent baseline products tested under the expected 

revised test procedure. 

 Iterative modeling with multiple series of adjustments to calculate the energy savings 

which can be achieved with different combinations of design options. 

This section focuses on the first phase of the ERA modeling work, namely 

establishing models for the teardown products based on the current energy test procedure. 

These models were later adjusted to represent baseline energy use under the new test 

procedures, and these models were used subsequently to calculate energy savings 

potential. The baseline analysis results were compared with available data to assure that 

the models provide accurate representation of product energy use. This section discusses 

the creation and calibration of the ERA energy models, the metrics which were 

compared, and the adjustments which were made in some cases in order to improve 

calibration. 

Input data for energy modeling was collected during the reverse engineering 

phase of the project. Collection of this data is discussed in Section 5.5.3.2 above. For 

products which DOE arranged to have energy tested, additional information was 

available for certain model parameters, such as defrost heater on times, compressor run 

time between defrosts, evaporator exit superheat, etc. Performance data was obtained 

from compressor vendors for the compressors used in the teardown products, as well as 

for compressors which could be considered as alternative options to reduce energy use. 

EERE-2008-BT-STD-0012 COMMENT 22
5-37 

Initial energy models were created, and the models were subsequently adjusted to 

provide a best match with available data for product performance. Key sources of 

information used for calibration of the energy models were the product EnergyGuide 

labels and data from energy tests carried out for a number of the reverse engineering units 

(Section 5.5.5). Energy test parameters besides energy use which were examined include 

compressor running power input, duty cycle, evaporating temperature, and condensing 

temperature. Since not all ERA input parameters can be determined definitively based on 

available information, some of the inputs were adjusted within reasonable ranges in order 

to provide good matches between model results and other performance indicators. It is 

recognized that energy levels reported in the EnergyGuide can be conservative to provide 

margin for variation in the production process. Hence, it is expected that ERA results 

would more likely be lower than the EnergyGuide value than higher. 

In some cases the directly modeled energy use was significantly lower than actual 

product energy use, In some of these cases in which the system operating parameters 

could be well calibrated based on test data, DOE attributed the high actual duty cycle and 

energy use to high actual cabinet thermal load. A number of factors could possibly 

explain such results, including greater impact than expected of thermal short circuits 

associated with wiring harnesses and other design details, excess gasket region load, and 

consistently lower insulation thermal performance than expected. A consistently 

underperforming compressor model could also explain such a discrepancy, but DOE 

concluded that this explanation is less likely than factors which would increase cabinet 

thermal load. Hence, for these cases, additional cabinet load was added to result in an 

energy use and compressor duty cycle which provided reasonable agreement with the 

available data. The side-mount refrigerator-freezers (product classes 4 and 7) were 

adjusted using this approach. 

In some cases, DOE concluded that ERA was not modeling particular heat 

exchangers properly. Adjustments were made in which the calculated effective surface 

area of the heat exchanger was adjusted upwards or downwards to represent heat transfer 

performance different than modeled. These adjustments were made to achieve more 

reasonable match of evaporating or condensing temperatures. Similar adjustments were 

made in some cases to evaporator pressure drop to adjust for an apparent discrepancy 

between measured evaporator surface temperature and compressor power input. 

The ERA analysis results after adjustments of the model input for the seven key product 

classes analyzed are compared with the EnergyGuide data and Energy test results in 

Figure 5.7.1 for refrigerator-freezers, in Figure 5.7.2 for standard-size freezers, and in 

Figure 5.7.3 for compact refrigerators and freezers. Energy testing was performed on a 

limited group of freezers and compact products: one upright freezer, one chest freezer, 

and one compact refrigerator. For these figures, the energy use of the freezers has been 

adjusted consistent with the energy test by applying the 0.85 correction factor for upright 

freezers and the 0.7 correction factor for chest freezers. 

The energy models are within a few percent of the EnergyGuide labeled energy use with 

one key exception, the 1.7 ft3 compact refrigerator. For this unit, the roughly 15% 

EERE-2008-BT-STD-0012 COMMENT 22
5-38 

discrepancy with the EnergyGuide energy use was not reconciled. Because the measured 

energy use also differed significantly from the rated energy use for this product, DOE 

could not draw firm conclusions regarding system operation in order to assist in the 

calibration effort. DOE expects that both the cabinet and system for this product are 

operating less efficiently than modeled. 

0.0

0.5

1.0

1.5

2.0

2.5

16 ft3 Top Mount21 ft3 Top Mount

21 ft3 E* Top Mount

18.5 ft3 E* Bottom 

Mount

25 ft3 E* Bottom 

Mount 1

25 ft3 E* Bottom 

Mount 2

22 ft3 Side Mount26 ft3 Side Mount

26 ft3 E* SideMount

Daily Energy Use (kWh/day)

ERA 

Energy Guide 

Energy Test

 Figure 5.7.1 ERA Analysis for Refrigerator-Freezers Compared with EnergyGuide 

Labels and Energy Test Measurements 

EERE-2008-BT-STD-0012 COMMENT 22
5-39 

0.0

0.5

1.0

1.5

2.0

2.5

14 ft3 Upright Freezer20 ft3 Upright Freezer

20 ft3 E* Upright 

Freezer

15 ft3 Chest Freezer

15 ft3 E* Chest 

Freezer

20 ft3 Chest Freezer

Daily Energy Use (kWh/day)

ERA 

Energy Guide 

Energy Test

Figure 5.7.2 ERA Analysis for Freezers Compared with EnergyGuide Labels and 

Energy Test Measurements 

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.7 ft3 Compact 

Refrigerator

4 ft3 Compact 

Refrigerator

4 ft3 E* Compact 

Refrigerator

3.4 ft3 Compact Chest 

Freezer

7 ft3 Compact Chest 

Freezer 1

7 ft3 Compact Chest 

Freezer 2

Daily Energy Use (kWh/day)

ERA 

Energy Guide 

Energy Test

Figure 5.7.3 ERA Analysis for Compact Refrigerators and Freezers Compared with 

EnergyGuide Labels and Energy Test Measurements 

EERE-2008-BT-STD-0012 COMMENT 22
5-40 

5.7.4 Adjustments to Energy Models to Represent Baseline Products Tested Under 

the Proposed Test Procedure 

This section discusses adjustment of the calibrated baseline ERA models to 

address two issues: (1) modification of some of the modeled product designs so they 

represent baseline-efficiency products of the desired product classes, and (2) adjustment 

for the proposed test procedure changes. 

Modifications were made to some of the modeled product designs so that they 

represent baseline products of the product classes of interest with appropriate typical 

characteristics. The changes made are discussed in the following paragraphs. 

Some of the teardown products purchased were not available as baselineefficiency products, i.e. products with energy use that is minimally compliant with the 

current energy standards. This was true primarily for product class 5, refrigerator-freezers 

with automatic defrost and bottom-mounted freezers without TTD ice service. As 

indicated above in Table 5.5.2, one of these products had energy use roughly 15% below 

the maximum allowable energy use (the former ENERGY STAR level), and the others 

had energy use at 20% below (the current ENERGY STAR level). In order to allow the 

engineering analysis to examine the cost associated with the efficiency improvement 

from the 0% to the 15% and 20% efficiency levels, a baseline model was created for a 

product which would be minimally compliant with the standards. This was done by 

carrying out the engineering analysis in reverse, removing the less cost-effective design 

options first, in order to achieve calculated energy levels consistent with the baseline 

energy standard. 

For product class 5, baseline models were established to represent products with 

French Doors. Comments made at the framework meeting and submitted to DOE as part 

of the framework comment period addressed this issue, as discussed in chapter 2. Most of 

the teardown products were purchased prior to the framework meeting, so DOE was not 

able to consider this issue when selecting these products. The two French Door products 

(see Table 5.5.2) were purchased later, to allow investigation of the different design 

details for these products. However, these French Door products are not product class 5, 

since they have TTD ice service. During the manufacturer interviews, DOE learned that 

more than half the sales of product class 5 currently have French Doors. As a result, DOE 

has used a French Door design as the basis for the engineering analysis for this product 

class. Because neither the products initially purchased for teardown nor the French Door 

products purchased later strictly fit the intended baseline design configuration, 

adjustments were made to establish product class 5 French Door designs for the 

engineering analysis. This was done for the 25 ft3 product by developing and adjusting an 

energy model for one of the 25 ft3 product class 5A reverse engineering units and for the 

18.5 ft3 product by adding French Door design features to the initial baseline model for 

the 18.5 ft3 product class 5 reverse engineering unit. Development of the product class 5 

French Door models involved the following considerations and steps. 

EERE-2008-BT-STD-0012 COMMENT 22
5-41 

French door refrigerator-freezers generally require electric anti-sweat heaters to 

prevent condensation of moisture on the gaskets and/or flip-mullions which seal between 

the French doors, since refrigerant-line anti-sweat heating is not possible in this region. 

The electric anti-sweat heater power input for the models was set at 6 W total, in spite of 

information that these heaters can have higher wattage input. The maximum timeaveraged heat input for a warm refrigerant liquid anti-sweat heater is typically somewhat 

lower per length,g suggesting that a wattage level of 6 W should be sufficient. DOE did 

not have adequate information regarding the thermal characteristics of the French Door 

gasket in order to allow a more refined estimate. DOE developed the baseline product 

design parameters assuming that the energy use is the average of tests with the anti-sweat 

heater on during one test and off during another.h

Gasket load for the fresh food compartment was increased to account for the 

additional gasket region length. This was added to the single-door 18.5 ft3 product class 5 

model, but was already part of the baseline for the fresh food compartment doors of the 

25 ft3 product class 5A model. The freezer compartment of the 25 ft3

 product class 5A 

teardown model had two drawers. Hence, the energy model representing this product as 

received incorporated an increase in the freezer compartment gasket load to account for 

the additional gasket length. When establishing the baseline ERA model for subsequent 

design option analysis, the added gasket load representing the two drawers was removed 

from the model. DOE took this step in order to establish a baseline model representing a 

single freezer drawer. 

The loads associated with the TTD ice system of the 25 ft3 product class 5A 

baseline were eliminated to create the 25 ft3 product class 5 with French Doors model. 

This includes the loads of the ice chute penetration, as well as the loads associated with 

the duct which conveys cold freezer air to the ice maker compartment. Additional loads 

and energy use associated with heaters in the region of this duct never entered into the 

model, because DOE understands that the teardown product was tested in a fashion which 

prevented activation of these heaters. 

Different compressor efficiency levels were selected and/or different fan motor 

types were selected in order to achieve modeled energy use consistent with the energy 

conservation standard. 

DOE obtained the product class 4 teardown unit (refrigerator-freezer with 

automatic defrost and side-mounted freezer without TTD ice service) with the 

understanding that it had TTD ice service. To address this discrepancy in the energy 

 

g

 For example, if the liquid flow of an 800 Btu/h nominal capacity compressor is cooled from a condenser 

exit temperature of 110  ̊F down to an ambient temperature of 90  ̊F, the delivered heat load during 

compressor operation is 70 Btu/h. Assuming roughly 50% duty cycle and 13 ft of freezer perimeter (the 

typical location for warm liquid anti-sweat), the heat per linear foot is 10.8 Btu/h-ft, equivalent to 3.2 W/ft. 

h

 As discussed in Chapter 3, the DOE energy test procedure calls for calculation of refrigerator energy use 

based on a test with anti-sweat heater switch in the on position. However, DOE understands that many if 

not all manufacturers calculate energy use as the average of tests with the switch in the on position and the 

off position. DOE expects to propose changing the test procedure to allow averaging of the two tests in the 

ongoing test procedure rulemaking. 

EERE-2008-BT-STD-0012 COMMENT 22
5-42 

modeling work, the initial baseline model for the product was modified to represent 

product class 7 (refrigerator-freezer with automatic defrost and side-mounted freezer with

TTD ice service). This was done by adding load and additional electric anti-sweat heat 

appropriate for the TTD feature. 

The engineering analysis has been carried out based on the expected revised 

energy test procedure, which includes modified cabinet temperatures as discussed in 

Section 5.4.2. After calibration of the ERA models with EnergyGuide and energy test 

data according to the current energy test procedure, and after the adjustment to the 

models to better represent the products under investigation as described above, the ERA 

models were adjusted to represent operation under the new energy test procedure. This 

adjustment did not apply to the freezers, since there are no proposed changes to the 

freezer compartment temperatures. The calculated impact of the compartment 

temperature changes on the energy use is discussed in Section 5.4.2.1 and is shown in 

Table 5.4.8 of that section. This calculated impact of the temperature changes is fairly 

consistent with the results provided by AHAM, although it is less than the impact 

measured during DOE testing of the teardown products. 

5.8 DESIGN OPTIONS 

After conducting the screening analysis described in chapter 4, DOE considered 

the remaining technologies in the design option analysis. Table 5.8.1 lists the design 

options considered for each product classes. Some design options are only applicable to 

certain types of equipment. Following the table is a description of how each of the design 

options was applied during the engineering analysis. See chapter 3 for background 

descriptions of the technologies. 

EERE-2008-BT-STD-0012 COMMENT 22
5-43 

Table 5.8.1 Design Options by Product Class 

Design Option PC3 PC5 PC7 PC9 PC10 PC11 PC18 

Increased Insulation 

Thickness  

1 in 



1 in 



3/4 in 

 

3/4 in 

Vacuum-Insulated 

Panels 

      

Improved Compressor 

Efficiency 

      

Variable-Speed 

Compressor 

      

Increased Evaporator 

Surface Area 

     

Increased Condenser 

Surface Area 

    

Forced Convection 

Condenser  

Brushless DC 

Evaporator Fan 

    

Brushless DC 

Condenser Fan 

    

Adaptive Defrost     

Variable Anti-Sweat 

Heater Control 

 

5.8.1 Increased Insulation Thickness 

Manufacturers stated during discussions that the potential for insulation thickness 

increases is very limited for many product classes. Greater insulation thickness would 

result in either decreased interior volumes, increased exterior dimensions, or some 

combination of both. They cited the high percentage of the market associated with 

replacements and the fixed sizes available for replacement refrigerators in consumers’ 

kitchens. The 1995 TSD supporting the 1997 refrigerator energy conservation standard 

final rule provided information regarding the reduction in served market associated with 

exterior size increases.9

 Reduction in internal volume is undesirable because this is a key 

selling feature. As a result, DOE did not consider insulation thickness increase in the 

analysis for standard-size refrigerator-freezers. 

There is some more flexibility in the potential to increase insulation thickness for 

freezers, since freezers are less likely to be placed in fixed-dimension spaces in kitchens. 

DOE did consider insulation thickness increase of up to 1 inch for standard-size freezers. 

EERE-2008-BT-STD-0012 COMMENT 22
5-44 

Compact refrigerators often have limitations on potential for size increase. 

However, many compact refrigerator products currently have insulation thickness no 

more than an inch. The potential energy benefit of insulation thickness increases for these 

products is significant. Hence, DOE considered increases of up to 3/4 inch for these 

products. DOE considered increase up to 3⁄4 inch also for compact freezers. 

While a manufacturer’s approach to implementing insulation thickness increase 

would likely involve a combination of reduced internal volume and increased external 

dimensions, DOE used just external dimension increase. This was done to assure that the 

product size (represented by adjusted volume) and the associated baseline energy use for 

the product did not change as the design options were applied. 

Costs associated with insulation thickness increases were calculated using the 

manufacturing cost model. As discussed in Section 5.6.6, DOE applied a conservative 

treatment of depreciation costs in which additional cost equal to the greenfield 

depreciation cost per product was added in order to reflect the likely build of a new 

production facility. DOE assumed that the depreciation cost would be incurred for any 

increase in insulation thickness. However, DOE allowed for increases in the door 

thickness without applying depreciation costs associated with the cabinet, and vice versa. 

Initial manufacturing cost model calculations provided the total cost impact of 

increasing all of the insulation in the product by a single amount. In order to allocate the 

cost increase to the cabinet and the door, DOE assumed that the cost of increasing the 

insulation thickness of the door was 5% of the total. This allocation was applied to both 

direct costs and depreciation costs. 

5.8.2 Vacuum-Insulated Panels 

Vacuum-insulated panels (VIPs) increase efficiency by significantly increasing 

the thermal resistivity of the cabinet walls, and therefore decreasing heat penetration into 

the cabinet. DOE considered the addition of 1⁄2-inch thick VIPs to the walls and doors of 

the cabinet for all product classes, and the remainder of the insulation thickness was filled 

with PU foam. Data for VIP thermal characteristics and costs were provided by va-Q-tec, 

a VIP manufacturer. The cost information was confirmed through discussions with 

manufacturers. In these discussions, manufacturers pointed out that edge effects can 

result in actual performance significantly less than predicted. However, DOE considers 

that thermal performance estimates based on the va-Q-tec technology are more accurate 

than for other VIP options because this technology has a more modest mid-panel thermal 

resistance and a significantly thinner metallic layer than other options. The mid-panel 

conductivity of this VIP technology is 3.5 mW/m-C (0.024 Btu-in/sqft-hr- ̊F).10 In 

contrast, the conductivity of PU foam is in the range 0.13 to 0.14 Btu-in/sqft-hr- ̊F. 

As discussed in Section 5.7.2, thermal performance of composite walls including 

VIPs was done using composite wall average thermal resistivities. The composite wall 

resistivity Rw was calculated as follows. 

EERE-2008-BT-STD-0012 COMMENT 22
5-45 

 

  VIP PU

VIPVIP PUPU

w tt

tRtR R



 

Where RVIP and RPU are the thermal resistivities of the VIP and the PU foam, and 

tVIP and tPU are the thicknesses of the VIP and PU foam layers. The thermal resistivities 

for the materials are the inverses of the conductivities. 

DOE analysis of cabinet load reduction achievable through the use of VIPs using 

this analysis approach is consistent with analysis carried out by va-Q-tec and also 

consistent with prototype testing using VIP technology. The reduction in cabinet load 

possible using VIPs for a refrigerator-freezer with typical wall thickness is roughly 30%, 

which is consistent with results reported by Electrolux for use of vacuum insulation in 

freezers.11

The following cost information, which va-Q-tec provided and/or which DOE 

developed based on subsequent discussions, formed the basis of the applied costs for 

VIPs. 

 Average panel cost $3.08/ft2

 at 1.2 cm thickness. 

 Fill cost as a percent of panel cost 60%. 

 Added glue cost for adhering the panel to cabinet surfaces 5% of panel cost. 

 Cost savings associated with displaced PU foam 2.5% of panel cost. 

In order to allow calculation of costs for other VIP thicknesses, the fill cost is 

considered proportional to the thickness, while the remaining cost per square foot is 

constant. In addition, direct labor cost associated with application of the panel to cabinet 

and door surfaces was calculated based on the $24/hr wage rate (including fringe 

benefits) discussed in section 5.6, and time for application of 10 minutes for a 

compartment and 1 minute for a door. The direct material and labor costs associated with 

use of the VIP must be adjusted to account for capital expenses and overhead associated 

with incorporation of VIPs into the production process. Because the material cost of VIPs 

is currently high in relation to the costs of other materials used in the manufacture of 

refrigerators and freezers, the cost adders for overhead and depreciation discussed in 

Section 5.6.6.1 and shown in Table 5.6.5 were divided by two in order to provide more 

reasonable representation of these costs for this technology. Hence, DOE used the 

following percent additions: 11.7% for standard-size refrigerator-freezers, 14.2% for 

standard-size freezers, and 19.6% for compact refrigerators. 

5.8.3 Improved Compressor Efficiency 

DOE considered the substitution of higher efficiency compressors for all product 

classes. This design option was often applied in two stages if there was a large gap 

between the baseline energy efficiency ratio (EER) and the maximum available EER for 

a given compressor capacity. DOE acquired compressor performance data from 

compressor vendors for use in the energy analysis, including capacity and power input for 

the applicable range of combinations of suction and discharge pressure conditions. As an 

EERE-2008-BT-STD-0012 COMMENT 22
5-46 

example of the potential for improvement, standard-size baseline refrigerator-freezers 

typically use compressors with a rated EER of 5.0 to 5.5 Btu/h-W. DOE considered 

improved EERs of 5.75 through 6.25 Btu/h-W. 

Currently the highest EER compressor commercially available is rated near 6.25 

Btu/h-W for standard- size refrigerator-freezers. The range of available compressor 

efficiencies is illustrated in Figure 5.8.1 below. The peak available efficiency level does 

not vary significantly for the range of capacities typical for standard-size refrigeratorfreezers (600 to 800 Btu/h). However, efficiency level drops off considerably for smaller 

capacity compressors that are generally used in compact refrigerators and freezers. 

0

1

2

3

4

5

6

7

0 200 400 600 800 1000

EER (Btu/h‐W)

Capacity (Btu/h)

Single Speed

Variable Speed at Lowest Speed

Variable Speed at 3000 rpm

Figure 5.8.1 Compressor Efficiency Data 

Estimates for increased cost of higher-efficiency compressors used for standardsize refrigerator-freezers and standard-size freezers were received from compressor 

vendors. These estimates were also discussed with manufacturers. Based on this 

information, DOE developed a curve for the cost premium associated with higher 

efficiency compressors. This curve is shown in Figure 5.8.2 below. 

EERE-2008-BT-STD-0012 COMMENT 22
5-47 

Figure 5.8.2 Incremental Cost for Single-Speed Compressors for Standard-Size 

Products 

When considering compressor efficiency improvement for standard-size products, 

DOE used the performance data of specific higher-efficiency compressors in the energy 

analysis. The alternative compressors were selected to have nearly the same capacity as 

the baseline compressors, in order to assure nearly identical performance except for 

compressor power input. 

In the analysis of compressor efficiency improvements for compact products, an 

approach was required which addressed the reduction of compressor efficiency as the 

capacity is reduced. A curve roughly representing the maximum available EER for 

smaller compressors was developed. This curve is compared in Figure 5.8.3 below with 

the data for commercially available compressors. 

EERE-2008-BT-STD-0012 COMMENT 22
5-48 

0

1

2

3

4

5

6

0 100 200 300 400 500 600

EER (Btu/h‐W)

Capacity (Btu/h)

CompressorData

Maximum EER Curve

Figure 5.8.3 Efficiency Curve for Low Capacity Compressors 

To model energy use of higher efficiency low-capacity compressors, DOE 

reduced the power input data for the baseline compressor by a selected factor so that the 

rated EER matches the maximum EER of the above curve. The baseline compressors of 

the products analyzed had EERs typically 0.5 to 1 Btu/h-W lower than the maximum 

curve shown in the figure above. 

DOE received vendor cost estimates for efficiency improvements for lowcapacity compressors. DOE also received information on the typical cost increase during 

discussions with manufacturers of products which use these compressors. A 

representative cost estimate of $10 per 1.0 Btu/h-W efficiency improvement was used in 

the analysis. 

5.8.4 Variable-Speed Compressor 

Variable speed compressors (VSC) operate at multiple speeds to allow variation 

of compressor capacity. They also generally use permanent magnet motors, which can be 

more efficient than induction motors for the power level required for residential 

refrigerator compressors. They improve efficiency by (1) use of the higher-efficiency 

motor technology, (2) increasing the operating effectiveness of heat exchangers because 

there is lower mass flow being cooled or warmed by a fixed-size heat exchanger, and (3) 

reducing cycling losses by reducing the number of cycles. VSC technology has been 

EERE-2008-BT-STD-0012 COMMENT 22
5-49 

available for many years and a number of refrigerator-freezer products currently use the 

technology. Currently nearly all of these products use Embraco VSCs. DOE obtained 

compressor performance data for the range of sizes of Embraco VSCs. This information 

was used in the energy analysis. DOE selected VSC capacities to nearly match those of 

the replaced single speed compressors at 3000 rpm. The lowest available speed for the 

Embraco VSCs is 1,600 rpm. The compressor typically cycles at the low speed to 

maintain internal setpoints for energy test conditions. DOE primarily used the 

performance data for 1,600 rpm in the energy analyses. The performance of VSC 

compressors at the lowest speed and at 3,000 rpm is shown in Figure 5.8.1 above. 

In order to maximize the energy benefit of VSCs, a design typically needs to 

address the impact that longer run time at lower capacity has on fan energy use. The 

increase in fan energy use can negate much of the reduction in compressor energy use. As 

a result, it is typically necessary to use brushless DC fan motors. In addition, the speed of 

brushless DC fan motors can be varied, depending on the design configuration. DOE is 

not aware of brushless DC fan motors designed for 120 VAC power input which allow 

adjustment of fan speed, although such a design should be viable. Most designs 

incorporating fan speed control use DC-input power for the fans and require a control 

system which can provide the DC power and vary it to adjust fan speed. Not all of DOE’s 

analysis involved optimization of fan speed and power with the variable speed 

compressor system. Some of the analyses involved selection of 50% fan speed, and some 

of the anlyses involved selection of speed to achieve roughly 50% power input. The cube 

law for fan power was used to calculate power input, except that at the 1/8 power level 

associated with the 50% fan speed, this power level was doubled. 

Cost estimates for the switch to variable speed compressors were provided by 

Embraco, and cost estimates were also obtained during discussions with manufacturers. 

An average of cost estimates provided by the manufacturers weighted by manufacturer 

market share is very near $50, not including additional changes which might be required 

to implement a variable speed system. DOE used a $50 cost increase in the analyses. 

Additional costs associated with conversion of a refrigeration system to variable speed 

operation are associated with a switch to brushless DC fan motors and the use of a control 

system sophisticated enough to provide adequate or optimized control. The Embraco 

VSC design includes a control system which can be used with a conventional mechanical 

thermostat. This system has been implemented in a commercially available freezer.12 The 

Embraco control adjusts speed based on the response of the mechanical thermostat. DOE 

considers that this approach is suitable for products with manual defrost. For products 

with automatic defrost and especially adaptive defrost, it is not reasonable to expect that 

that the Embraco system alone would be suitable. DOE included in cost estimates an 

additional $25 for addition of an electronic control system for products with automatic 

defrost. For product classes for which a significant portion of current models already 

have electronic control (product classes 5 and 7), analysis was conducted for an 

electronic control unit and a mechanical control unit. The average results for these 

product classes were weighted averages based on the distribution of electronic control for 

the product class. The current electronic percentages were selected based on input from 

manufacturers as 50% for side-mounts and 75% for bottom-mounts. The additional cost 

EERE-2008-BT-STD-0012 COMMENT 22
5-50 

associated with conversion to brushless DC fan motors did not generally apply: because 

brushless DC fan motors are more cost effective than a full conversion to variable speed, 

the cost of the motors would have already been applied at a lower efficiency levelwhen a 

change to variable speed is considered. 

5.8.5 Increased Evaporator Surface Area 

The evaporator is necessary for transferring heat from the cabinet to the 

refrigerant. Larger surface area allows the heat transfer to occur more efficiently. DOE 

considered an increase in evaporator surface area for all products analyzed. In some cases 

the size increase was limited by available space. This was true especially for the chest 

freezers and compact refrigerators. DOE considered size increases of up to 20%, except 

for one of the upright freezer models, for which DOE considered an increase of up to 

50%. The size increases were implemented in the energy analysis through increase of the 

effective heat exchanger surface areas and refrigerant pressure drops entered into the 

ERA model. The pressure drop increases as well as the surface area because the 

refrigerant tube length would be increased to maintain fin efficiency. 

Treatment of the cost of the evaporator size increase depended on the evaporator 

type. For forced convention and roll bond evaporators, the baseline costs of the 

evaporators were adjusted upwards by the size increase factor. For cold wall evaporators, 

the cost increase was directly calculated in the manufacturing cost model by increase of 

the tube lengths and materials associated with providing good tube/liner thermal contact. 

5.8.6 Increased Condenser Surface Area 

The condenser transfers heat from the refrigerant to the ambient air. Larger 

surface area allows the heat transfer to occur more efficiently. DOE considered an 

increase in condenser surface area for all products analyzed. In some cases the size 

increase was limited by available space. This was true especially for hot wall or static 

condensers. DOE considered size increases of up to 20%. The size increases were 

implemented in the energy analysis through increase of the effective heat exchanger 

surface areas and refrigerant pressure drops entered into the ERA model. The pressure 

drop increases as well as the surface area because the refrigerant tube length would be 

increased to maintain fin efficiency. 

Treatment of the cost of the condenser size increase depended on the condenser 

type. For forced convention and static condensers, the baseline costs of the condensers 

were adjusted upwards by the size increase factor. For hot wall condensers, the cost 

increase was directly calculated in the manufacturing cost model by increase of the tube 

lengths and materials associated with providing good tube/shell thermal contact. 

5.8.7 Brushless DC Fan Motors 

Brushless DC fan motors are more efficient than the shaded pole motors which 

are often used in baseline model refrigerators. 

EERE-2008-BT-STD-0012 COMMENT 22
5-51 

In the TSD supporting the 1997 refrigerator energy conservation standard final 

rule, shaded pole fan motor power input ranging from 8 to 12 W was assumed to be 

reduced to 4.5 W when switching to brushless DC motors.9

 This is a reduction in power 

ranging from 44 to 57%. The cost increase of that analysis associated with the switch was 

$6.50 for an evaporator fan and $4.50 for a condenser fan. 

The fan power input measured for the teardown products are summarized in Table 

 5.8.2 below. For the baseline/ENERGY STAR product pairs, power input is provided for 

both sets of each applicable fan. The fan motor power reduction associated with the 

switch to brushless DC motors based on this data is in the range 60% to 65%. 

Table 5.8.2 Teardown Product Fan Power Input 

Product Evaporator Fans Condenser Fans 

Shaded Pole Brushless 

DC 

Shaded Pole Brushless 

DC 

21 ft3 Top-Mount** 5.7, 6.1 NA 9.4 3.3 

26 ft3 Side-Mount** 5.6, 5.8 NA 8.5 3.4 

25 ft3 Bottom Mount 1 6.5 NA NA 3.7 

18.5 ft3 Bottom Mount 6.2 NA NA 3.8 

25 ft3 Bottom Mount 2 NA 3.25* NA 2.2* 

22 ft3 Side-Mount NA 3.25* 9.1 NA 

20 ft3 Upright Freezer** 11.5 4.5 NA NA 

14 ft3 Upright Freezer 7.4 NA NA NA 

*DC-input fan. The listed wattage is nominal. 

**Data provided for a baseline/ENERGY STAR product pair. 

DOE also obtained information on typical fan motor power reduction associated 

with a switch to brushless DC motors during discussions with manufacturers. The 

responses indicated that the reductions would be more modest than suggested by the 1995 

TSD values or the measurements of teardown products. DOE selected a compromise 

power reduction of 50% when the possible reduction was not already clearly illustrated 

by the measurements of the baseline/ENERGY STAR teardown product pairs under 

analysis. 

Incremental cost estimates for the switch to brushless DC motor were obtained 

through discussion with Matsushita, a key vendor supplying these motors, and through 

discussions with manufacturers. DOE used incremental cost estimates of $3.75 for 

condenser fans and $3.50 for evaporator fans. 

5.8.8 Adaptive Defrost 

An adaptive defrost system adjusts the time interval between defrosts based on 

some indication of the need for defrost. A common indicator is the length of time 

required to complete the previous defrost. Other indicators could include the number of 

door openings or a measurement of ambient humidity. DOE considered this design option 

for product classes which have automatic defrost (product classes 3, 5, 7, and 9). The 

EERE-2008-BT-STD-0012 COMMENT 22
5-52 

ERA model allows input of compressor run time between defrost. To model this option, 

DOE increased the compressor run time between defrosts to 38 hours, as compared to the 

typical range for baseline products of 10-15 hours. The 38 hours is the default time 

interval allowed by the test procedure if the mean time between defrost test is not carried 

out, assuming default values of the minimum and maximum compressor run intervals of 

12 and 84 hours. 

Based on discussions with manufacturers, DOE used an incremental cost of $8 in 

the energy analysis for adaptive defrost. This cost assumes use of a standalone adaptive 

defrost controller, which could be used if the refrigerator does not already have electronic 

control. Refrigerators which have electronic control can implement adaptive defrost with 

programming changes which incur no per-unit cost. For some products for which a 

significant portion of current shipments already have electronic control, the incremental 

cost for adaptive defrost was multiplied by the fraction of products of the product class 

which do not already have electronic control, as was done for the electronic control cost 

addition for variable speed compressors. 

In cases where both adaptive defrost and variable speed compressor design 

options were analyzed, the cost of the adaptive defrost was eliminated, because the 

introduction of electronic controls would make use of a standalone adaptive defrost 

controller unnecessary. 

5.8.9 Variable Anti-Sweat Heater Control 

Variable anti-sweat heater control adjusts the time-average wattage of an electric 

anti-sweat heater based on ambient temperature and humidity conditions so that all 

surfaces are just above the ambient dew point. DOE considered this option for bottommount French-door refrigerator-freezers (PC 5). These products must use electric antisweat heaters in the region of the seal between the two fresh food doors to control 

condensation, because warm liquid anti-sweat heating cannot be applied in this region. 

Most modern refrigeration products use warm liquid anti-sweat heating, thus making 

electric anti-sweat heaters unnecessary, except in such locations. To model the energy use 

reduction associated with this design option, DOE established a curve representing the 

heater power input as a function of ambient humidity. DOE then calculated annual 

average electric anti-sweat heater wattage based on the frequency distribution of 

humidity levels established in the GE waiver describing a test procedure for this control 

scheme.13 The selected DOE curve is based on power levels of 0W at 65% RH and 9W at 

100% RH. The maximum power was increased as compared with the 6W used for the 

anti-sweat heater for the baseline product analysis (see the discussion in Section 5.7.4), 

because the variable anti-sweat heater control minimizes the energy use impact of the 

higher wattage. 

Implementation of variable anti-sweat heater control requires use of a humidity 

sensor and an electronic controller which can adjust the time-average heater wattage 

appropriately. For products which already have electronic control, DOE used the cost just 

of a humidity sensor. DOE used a cost of $9.48 for a Honeywell humidity sensor based 

EERE-2008-BT-STD-0012 COMMENT 22
5-53 

on high-quantity pricing.14 No product currently exists which provides standalone 

variable anti-sweat heater control. However, DOE considers the $8 example of the 

standalone adaptive defrost controller to be representative of the incremental cost of such 

a product. 

5.8.10 Forced Convection Condenser 

A forced convection condenser can be more efficient than a hot wall condenser, 

because it enables more effective heat transfer from the refrigerant to the ambient air. 

DOE considered this option for upright freezers only (product class 9). This conversion 

involves the addition of a typical wire-tube condenser, a fan assembly, wiring to power 

the fan, and a warm liquid anti-sweat heating loop, and the elimination of hot wall tubing 

on the insulation side of the outer shell. In the case of the upright freezer products 

examined for the reverse engineering work, there was ample space underneath the cabinet 

for the condenser and fan assembly. In addition, these products incorporated hot gas 

condensate pan heaters. These heaters could be eliminated in a forced-convection 

arrangement, because the condenser heat and air flow of the forced convection 

arrangement would be sufficient to evaporate the condensate, as is generally done for 

refrigerator-freezers. DOE used a net incremental cost of $3 for this conversion—most of 

the cost of the added components would be saved through elimination of the hot wall 

condenser. DOE analyzed this design option both with shaded pole and brushless DC 

condenser fans. The option provided an energy benefit in combined design option 

analysis only when using the brushless DC fan motor. 

5.9 ENGINEERING ANALYSIS RESULTS 

This section shows the incremental cost curves developed by DOE and provides 

comparison to the data provided by AHAM. 

5.9.1 DOE Cost-Efficiency Curves 

DOE generated cost-efficiency curves for two product volumes in each of the 

seven analyzed product classes based on combinations of individual design options. The 

curves were normalized by converting to costs at specific efficiency levels (every 5% 

energy use reduction from 10% to 45%) for simplified downstream analysis. 

Conversion of cost curves to the specified efficiency levels was complicated by 

the characteristics of the design options required to provide further efficiency 

improvement. Some design options can be partially applied, while others cannot. For 

instance, for the 21 ft3 top-mount refrigerator, the second step in the design option path 

raises the efficiency level from 9.9% to 16.8% by increasing the compressor EER from 

5.54 to 6.08 Btu/h-W. The cost for compressor efficiency improvement, illustrated in 

Figure 5.8.2, varies as the efficiency varies. Because intermediate efficiency level 

compressors are generally available, the cost to achieve a fraction of the increase to 

16.8% would be a fraction of the cost to achieve the full step to 16.8%. Hence, DOE 

calculated the cost of raising efficiency to the 10% and 15% levels by calculating the 

EERE-2008-BT-STD-0012 COMMENT 22
5-54 

lower cost of partial improvement in compressor EER. In some cases, such as 

implementation of a variable speed compressor, the design option cannot be partially 

implemented. For these cases, the entire cost of the design option was applied at the 

intermediate efficiency level, even though the design might overshoot the efficiency 

level. This causes some of the incremental cost curves to have slopes which don’t 

increase monotonically. 

The DOE incremental MSP costs are presented in Table 5.9.1 below. While DOE 

analyzed two sizes of each product, it is not clear that differences in the curves can 

rightly be attributed to the size differences. Other factors likely have greater influence, 

for instance for product class 3 the 16 ft3

 product had noticeably thinner insulation than 

the 21 ft3

 product. DOE considers the averages of the MSPs to be representative for each 

product class. The separate analysis of the slopes of the energy use vs. adjusted volume 

curves discussed in section 5.4.2.3 addresses the issue of adjustments to more accurately 

reflect the impact that product size has on energy use. 

Table 5.9.1 DOE Incremental Costs 

Product Efficiency Level 

Class 

Size* 

(ft3) 10% 15% 20% 25% 30% 35% 40% 45% 

16 $6.52 $11.21 $21 $49 $94 $127 $168 $208 

3 21 $0.47 $4.16 $11 $20 $31 $81 $145 $208 

Avg $3.50 $7.68 $16 $35 $62 $104 $156 $208 

18.5 $7.21 $16.34 $26 $36 $58 $119 $177 $243 

5 25 $0.00 $2.27 $9.49 $30 $41 $107 $185 $254 

Avg $1.80 $5.79 $14 $31 $45 $110 $183 $251 

22 $9.92 $23.45 $76 $139 $203 $264 $359 N/A 

7 26 $12.44 $14.46 $32 $73 $131 $194 $262 $345 

Avg $11.18 $18.96 $54 $106 $167 $229 $311 N/A 

14 $6.38 $6.38 $11 $34 $62 $90 $175 $259 

9 20 $6.43 $16.51 $17 $21 $31 $64 $73 $135 

Avg $6.41 $11.45 $14 $28 $47 $77 $124 $197 

15 $0.00 $2.93 $8.90 $14 $18 $45 $51 $106 

10 20 $4.70 $9.16 $39 $45 $52 $104 $104 $168 

Avg $2.35 $6.05 $24 $29 $35 $74 $77 $137 

1.7 $2.44 $4.70 $7.10 $19 $20 $29 $45 $61 

11 4 $4.28 $7.94 $10.61 $22 $23 $24 $33 $53 

Avg $3.36 $6.32 $8.85 $21 $22 $27 $39 $57 

3.4 $5.42 $8.38 $32.54 $46 $63 $63 $63 $87 

18 7 $6.68 $10.93 $35.52 $39 $57 $63 $87 $92 

Avg $6.05 $9.65 $34.03 $43 $60 $63 $75 $90 

*These are total product volumes based on the current test procedure, not adjusted 

volumes. 

DOE did not attempt to provide distributions of costs at each efficiency level. 

While the MSP curves for the two different sizes for each product class provides some 

EERE-2008-BT-STD-0012 COMMENT 22
5-55 

indication of the variation of the costs, the full range is very likely much greater. There is 

insufficient information currently available for DOE to confidently calculate cost 

distributions at each efficiency level. The average curves for incremental manufacturer 

selling price are plotted in Figure 5.9.1 through Figure 5.9.3 below. 

$‐

$50

$100

$150

$200

$250

$300

$350

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

IncrementalManufacturer Selling Price

Efficiency Level

Product Class 3

Product Class 5

Product Class 7

Figure 5.9.1 Incremental Manufacturer Selling Price for Standard-Size 

Refrigerator-Freezers 

EERE-2008-BT-STD-0012 COMMENT 22
5-56 

$‐

$50

$100

$150

$200

$250

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

IncrementalManufacturer Selling Price

Efficiency Level

Product Class 9

Product Class 10

Figure 5.9.2 Incremental Manufacturer Selling Price for Standard-Size Freezers 

EERE-2008-BT-STD-0012 COMMENT 22
5-57 

$‐

$10

$20

$30

$40

$50

$60

$70

$80

$90

$100

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

IncrementalManufacturer Selling Price

Efficiency Level

Product Class 11

Product Class 18

Figure 5.9.3 Incremental Manufacturer Selling Price for Compact Refrigerators 

and Freezers 

5.9.2 AHAM Incremental Cost Data 

This section presents the aggregated incremental cost data provided by AHAM 

and discusses differences between this data and the incremental cost information 

developed by DOE. 

The data request sheets initially provided for the AHAM incremental cost data 

collection effort are in the framework document as Tables A-7A through A-7F of that 

document. The data collection effort was later modified to include a 35% efficiency level 

and to reduce the 15% efficiency level to 10% in order to provide an intermediate first 

level. Data was submitted to AHAM by manufacturers and this data was aggregated in 

preparation for submission to DOE, so that no reported data would represent responses 

from fewer than three manufacturers. 

Sufficient data was collected to allow reporting of incremental costs for product 

classes 3, 5, 7, 9, and 11, although for product classes 5 and 11 the reporting was for only 

one of the product sizes. 

After receipt of the data, DOE posed follow-up questions, some through AHAM 

and some directly with individual manufacturers, to improve understanding of the results. 

DOE requested that AHAM provide indication of what percent of shipments within each 

EERE-2008-BT-STD-0012 COMMENT 22
5-58 

product class was represented by reported information, so that the results for capital 

investments and one-time expenditures could more accurately be allocated to individual 

products. DOE also requested clarification regarding whether the capital investments and 

one-time expenditures reported for the two sizes of a product class would be added to 

provide total costs for the product class, or whether any portion of the cost would 

overlap. AHAM requested clarification on this question from members, and the response 

was that there is very little overlap in reporting of these costs. 

The following sections present the AHAM data and comparisons with DOE 

results by product class. 

EERE-2008-BT-STD-0012 COMMENT 22
5-59 

5.9.2.1 Product Class 3 

Incremental cost data for product class 3 refrigerator-freezers provided by AHAM 

are summarized in Table 5.9.2 below. 

Table 5.9.2 AHAM Incremental Cost Data for Product Class 3 

Efficiency Level 10% 20% 25% 30% 35% 

Product Class 3—15 ft3

Material $13.02 $20.32 $90.79 $148.13 $160.19 

Labor $0 $0 $4.23 $8.72 $9.13 

Incremental 

Cost 

Average 

(99%)* 

Overhead $0 $0 $0 $0.04 $0.07 

Building CAPX 

(99%--4)* 

$0 $0 $3.5 $4.0 $4.5 

Tooling/Equipment 

CAPX (99%--4)* 

$0 $15.0 $25.2 $120.4 $125.5 

R&D (57%--3)* $0 $0 $4.5 $4.5 $17.5 

Total Industry 

Marketing (57%--3)* $0 $0 $2.5 $2.5 $2.5 

Building CAPX $0 $0 $0.14 $0.14 $0.14 

Tooling/Equipment 

CAPX 

$0 $4.58 $6.75 $40.66 $40.69 

R&D $0 $0 $0.75 $0.75 $4.72 

CCE & OTPCE ($million) ShipmentWeighted Average 

Marketing $0 $0 $0.68 $0.68 $0.68 

Product Class 3—21 ft3

Material $8.98 $22.09 $92.55 $150.79 $173.83 

Labor $0 $0 $4.22 $8.99 $8.99 

Average 

(99%)* 

Overhead $0 $0 $0 $0.04 $0.04 

Material $0 $8.27 $34.61 $43.60 $68.30 

Labor $0 $0 $0 $0.54 $0.54 

Minimum 

(57%)* 

Overhead $0 $0 $0 $0.04 $0.04 

Material $0.81 $10.18 $36.23 $46.93 Blank 

Labor $0 $0 $0 $0.55 $0.56 

Incremental 

Cost 

Maximum 

(57%)* 

Overhead $0 $0 $0 $0.04 $0.04 

Building CAPX 

(99%--4)* 

$0 $0 $3.0 $3.0 $3.0 

Tooling/Equipment 

CAPX (99%--4)* 

$0 $3.0 $65.5 $125.5 $130.5 

R&D (57%--3)* $0.5 $0.5 $2.5 $2.5 $12.5 

Total Industry 

Marketing (57%--3)* $2.5 $2.5 $2.5 $2.5 $2.5 

Building CAPX $0 $0 $0.01 $0.01 $0.01 

Tooling/Equipment 

CAPX 

$0 $0.92 $19.05 $42.27 $42.27 

R&D $0.14 $0.14 $0.14 $0.14 $3.19 

CCE & OTPCE ($million) ShipmentWeighted Average 

Marketing $0.68 $0.68 $0.68 $0.68 $0.68 

CCE&OTPCE: Conversion Capital Expenditures and One-Time Product Conversion Expenses. Material, 

Labor, and Overhead are per unit. Blank entries indicate that there were insufficient responses for AHAM 

to provide data. 

*Percent of Product Class 3 shipments represented by these data and number of manufacturers represented 

(for capital and one-time expenditures). 

EERE-2008-BT-STD-0012 COMMENT 22
5-60 

The AHAM average incremental cost data for product class 3 refrigerator-freezers 

are compared with the DOE costs in Figure 5.9.4 below. The DOE costs in these curves 

have the manufacturer markup taken out so that they can be compared on a consistent 

basis. The AHAM curves include material, labor, overhead, and depreciation and onetime expenses. 

$-

$50 

$100 

$150 

$200 

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

Incremental Cost

Efficiency Level (%)

AHAM 21cuft AVG

AHAM 15 cuft AVG

AHAM 21 cuft MIN/MAX

DOE 21 cuft

DOE 16 cuft

DOE AVG

Figure 5.9.4 Incremental Cost Curves for Product Class 3 

Per-product incremental cost associated with capital expenditures and one-time 

expenses have been calculated as follows based on the AHAM data for these cost 

categories. Total reported industry expenditures for each of the four categories (building, 

equipment, R&D, marketing) are divided by the percent of shipments represented by the 

data as reported by AHAM to determine the total industry value of each of these 

expenditures. These values are then added to obtain the total one-time expenditures for 

the product class for each of the two product class sizes for which data was provided. The 

one-time expenditures for the small and large size products are added to obtain total 

product class one-time expenditures. For product classes for which data were reported for 

only one of the sizes (product classes 5 and 11), the total for the size is doubled to 

represent the total one-time expenditures for the entire product class. Allocation of the 

one-time expenditures is based on the projected shipments for the product class for the 

first 10 years of the life of the new standard as determined for the NIA. The expenditures 

are divided by the total of these shipments to determine the impact of one-time 

expenditures per unit. This value is then added to the incremental costs for the product 

represented by materials, labor, and overhead. 

EERE-2008-BT-STD-0012 COMMENT 22
5-61 

The data provided for the 21 ft3

 product class 3 refrigerator-freezers includes 

results for the average, the maximum, and the minimum cost data provided by 

manufacturers responding to the query for incremental cost data. Different numbers of 

responses were obtained for the average than for the minimum and maximum, as 

indicated in Table 5.9.2. The results for minimum and maximum, provided by 

manufacturers representing 57% of shipments for product class 3, are nearly equal. This 

suggests that the average cost data provided by these same manufacturers is nearly equal 

to these minimum and maximum values. The cost curve for these manufacturers, shown 

in Figure 5.9.4 with adjustments for capital and one-time expenditures, agrees very well 

with DOE results. The average cost data provided by the manufacturer(s) representing the 

remaining 42% of the product class shipments must have been quite high. 

In spite of the apparently good agreement between the DOE results and the 

AHAM data for the manufacturers who reported minimum and maximum incremental 

costs, there still remains a key discrepancy. DOE discussed the data submittals with some 

manufacturers after AHAM’s aggregation of the data, and the manufacturers reported that 

insulation thickness increases were considered as part of the design options associated 

with the data. Since DOE’s results did not consider insulation thickness increases, it 

would be expected that the DOE results would indicate higher costs. 

EERE-2008-BT-STD-0012 COMMENT 22
5-62 

5.9.2.2 Product Class 5 

Incremental cost data for product class 5 refrigerator-freezers provided by AHAM 

are summarized in Table 5.9.2 below. 

Table 5.9.3 AHAM Incremental Cost Data for Product Class 5 

Efficiency Level 10% 20% 25% 30% 35% 

Product Class 5—19 ft3

Material $2.23 $6.54 $48.82 $56.67 $86.17 

Labor $0.20 $0.25 $0.36 $0.71 $1.00 

Average 

(86%)* 

Overhead $0.33 $0.46 $0.49 $0.65 $0.85 

Material $1.86 $9.67 $51.24 $56.09 $85.59 

Labor $0.13 $0.20 $0.21 $0.26 $0.55 

Minimum 

(82%)* 

Overhead $0.41 $0.62 $0.65 $0.82 $1.01 

Material $1.86 $9.67 $51.24 $56.09 $85.59 

Labor $0.13 $0.20 $0.21 $0.26 $0.55 

Incremental Cost 

Maximum 

(82%)* 

Overhead $0.41 $0.62 $0.65 $0.82 $1.01 

Building CAPX 

(86%--4)* 

$0.1 $0.2 $0.5 $0.8 $1.0 

Tooling/Equipment 

CAPX (86%--4)* 

$0.3 $0.8 $31.0 $31.3 $36.5 

R&D (86%--4)* $0.9 $1.7 $3.2 $4.0 $12.3 

Total Industry 

Marketing (86%--4)* $0.2 $2.7 $2.8 $2.8 $2.8 

Building CAPX $0 $0 $0 $0.01 $0.01 

Tooling/Equipment 

CAPX 

$0 $0.01 $7.74 $7.75 $8.00 

R&D $0.01 $0.52 $0.54 $0.56 $2.52 

CCE & OTPCE ($million) ShipmentWeighted Average 

Marketing $0 $1.71 $1.71 $1.71 $1.71 

CCE&OTPCE: Conversion Capital Expenditures and One-Time Product Conversion Expenses. Material, 

Labor, and Overhead are per unit. Blank entries indicate that there were insufficient responses for AHAM 

to provide data. 

*Percent of Product Class 5 shipments represented by these data and number of manufacturers represented 

(for capital and one-time expenditures). 

The AHAM incremental cost data for product class 5 is compared with the 

calculations carried out by DOE in Figure 5.9.5 below. The DOE costs in these curves 

have the manufacturer markup taken out so that they can be compared on a consistent 

basis. The AHAM curves include material, labor, overhead, and depreciation and onetime expenses. The AHAM and DOE data are in good agreement, except at the 25% and 

30% efficiency levels. However, as with product class 3, the agreement may not be 

entirely consistent because the DOE results did not consider insulation thickness 

increases. 

EERE-2008-BT-STD-0012 COMMENT 22
5-63 

$-

$50 

$100 

$150 

$200 

$250 

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

Incremental Cost

Efficiency Level (%)

AHAM 19 cuft AVG

DOE 18.5 cuft

DOE 25 cuft

DOE AVG

Figure 5.9.5 Incremental Cost Curves for Product Class 5 

EERE-2008-BT-STD-0012 COMMENT 22
5-64 

5.9.2.3 Product Class 7 

Incremental cost data for product class 7 refrigerator-freezers provided by AHAM is 

summarized in Table 5.9.4 below. 

Table 5.9.4 AHAM Incremental Cost Data for Product Class 7 

Efficiency Level 10% 20% 25% 30% 35% 

Product Class 7—22 ft3

Material $7.83 $52.26 $70.33 $84.58 $109.23 

Labor $0 $1.78 $3.56 $3.68 $3.80 

Incremental Cost Average 

(97%)* 

Overhead $0 $0 $0 $0.01 $0.03 

Building CAPX Blank Blank Blank Blank Blank 

Tooling/Equipment CAPX 

(97%--3)* 

$6.0 $6.0 $91.0 $91.0 $91.0 

R&D Blank Blank Blank Blank Blank 

Total Industry 

Marketing Blank Blank Blank Blank Blank 

Building CAPX Blank Blank Blank Blank Blank 

Tooling/Equipment CAPX $1.32 $1.32 $17.48 $17.48 $17.48 

R&D Blank Blank Blank Blank Blank 

CCE & OTPCE ($million) ShipmentWeighted Average 

Marketing Blank Blank Blank Blank Blank 

Product Class 7—25 ft3

Material $4.48 $11.60 $50.47 $50.62 $53.08 

Labor $0.03 $0.06 $1.89 $3.61 $3.65 

Average 

(97%)* 

Overhead $0.07 $0.11 $0.12 $0.15 $0.21 

Material $0.25 $1.81 $10.01 $3.55 $5.03 

Labor $0.02 $0.02 $0.02 $0.04 $0.05 

Minimum 

(80%)* 

Overhead $0.05 $0.07 $0.07 $0.11 $0.15 

Material $4.39 $37.43 $65.02 $13.94 $15.19 

Labor $0.03 $0.04 $0.14 $0.06 $0.07 

Incremental Cost 

Maximum 

(80%)* 

Overhead $0.09 $0.14 $0.15 $0.18 $0.22 

Building CAPX 

(80%--4)* 

$0.1 $0.2 $0.6 $21.0 $21.3 

Tooling/Equipment CAPX 

(97%--5)* 

$24.3 $25.2 $129.5 $242.4 $250.3 

R&D (80%--4)* $1.9 $2.0 $4.5 $8.0 $9.4 

Total Industry 

Marketing (80%--4)* $2.7 $2.7 $2.8 $2.8 $2.8 

Building CAPX $0 $0 $0.09 $12.12 $12.16 

Tooling/Equipment CAPX $5.25 $5.25 $26.70 $66.41 $66.41 

R&D $0.45 $0.45 $0.46 $1.51 $1.51 

CCE & OTPCE ($million) ShipmentWeighted Average 

Marketing $1.50 $1.50 $1.50 $1.50 $1.50 

CCE&OTPCE: Conversion Capital Expenditures and One-Time Product Conversion Expenses. Material, 

Labor, and Overhead are per unit. Blank entries indicate that there were insufficient responses for AHAM 

to provide data. 

*Percent of the Product Class 7 shipments represented by these data and number of manufacturers 

represented (for capital and one-time expenditures). 

The AHAM incremental cost data for product class 7 are compared with the 

calculations carried out by DOE in Figure 5.9.6.The DOE costs in these curves have the 

EERE-2008-BT-STD-0012 COMMENT 22
5-65 

manufacturer markup taken out so that they can be compared on a consistent basis. The 

AHAM curves include material, labor, overhead, and depreciation and one-time 

expenses. 

For the 22 ft3 product 7 size, capital and one-time expenditure data was provided 

only for tooling/equipment costs. To assure that building, R&D, and marketing costs 

have been considered, the R&D and marketing costs for this product size have been set 

equal to the equivalent costs for the 26 ft3 product size. The building capital cost has been 

assumed to be proportional to tooling/equipment capital cost for product class 7. For 

product class 7, the DOE cost estimates are higher than the AHAM data at higher 

efficiency levels. However, the leveling off of the AHAM 25 ft3 curve is expected to be 

an anomaly of the reporting and aggregation process—this feature of the curve is not 

expected to be representative of the actual cost trend for this product. 

$-

$50 

$100 

$150 

$200 

$250 

$300 

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

Incremental Cost

Efficiency Level (%)

AHAM 25 cuft AVG

AHAM 22 cuft AVG

DOE 26 cuft

DOE 22 cuft

DOE AVG

Figure 5.9.6 Incremental Cost Curves for Product Class 7 

EERE-2008-BT-STD-0012 COMMENT 22
5-66 

5.9.2.4 Product Class 9 

Incremental cost data for product class 9 refrigerator-freezers provided by AHAM 

is summarized in Table 5.9.5 below. 

Table 5.9.5 AHAM Incremental Cost Data for Product Class 9 

Efficiency Level 10% 20% 25% 30% 35% 

Product Class 9—14 ft3

Material $10.86 $33.20 $21.92 $30.94 $40.86 

Labor $1.03 $3.79 $2.27 $3.07 $4.26 

Incremental Cost Average 

(21%)* 

Overhead $0.48 $1.28 $1.36 $1.45 $2.16 

Building CAPX 

(21%--3)* 

$0.1 $0.1 $3.2 $3.3 $3.5 

Tooling/Equipment 

CAPX (21%--3)* 

$0.2 $0.5 $5.6 $10.6 $15.9 

R&D (21%--3)* $0.3 $0.4 $2.8 $3.1 $3.2 

Total Industry 

Marketing (21%--3)* $0.2 $0.2 $0.3 $0.3 $0.3 

Building CAPX $0 $0 $1.17 $1.17 $1.17 

Tooling/Equipment 

CAPX 

$0 $0 $1.95 $3.90 $5.88 

R&D $0 $0 $0.78 $0.79 $0.79 

CCE & OTPCE ($million) ShipmentWeighted Average 

Marketing $0 $0 $0 $0 $0 

Product Class 9—20 ft3

Material $9.72 $32.90 $21.45 $31.55 $40.60 

Labor $0.78 $3.55 $2.40 $3.20 $4.21 

Incremental Cost Average 

(21%)* 

Overhead $0 $0.80 $1.50 $1.58 $1.98 

Building CAPX 

(21%--3)* 

$0 $0.2 $3.2 $3.4 $4.2 

Tooling/Equipment 

CAPX (21%--3)* 

$0 $0.5 $8.2 $15.7 $23.4 

R&D (21%--3)* $0 $0.3 $3.3 $3.7 $3.9 

Total Industry 

Marketing (21%--3)* $0 $0.2 $0.3 $0.3 $0.3 

Building CAPX $0 $0 $1.17 $1.17 $1.18 

Tooling/Equipment 

CAPX 

$0 $0 $2.96 $5.84 $8.76 

R&D $0 $0 $1.17 $1.17 $1.17 

CCE & OTPCE ($million) ShipmentWeighted Average 

Marketing $0 $0 $0 $0 $0 

CCE&OTPCE: Conversion Capital Expenditures and One-Time Product Conversion Expenses. Material, 

Labor, and Overhead are per unit. Blank entries indicate that there were insufficient responses for AHAM 

to provide data. 

*Percent of the Product Class 9 shipments represented by these data and number of manufacturers 

represented (for capital and one-time expenditures). 

The AHAM incremental cost data for product class 9 are compared with the 

calculations carried out by DOE in Figure 5.9.7 below. The DOE costs in these curves 

have the manufacturer markup taken out so that they can be compared on a consistent 

basis. The AHAM curves include material, labor, overhead, and depreciation and oneEERE-2008-BT-STD-0012 COMMENT 22
5-67 

time expenses. The DOE costs are lower than the AHAM data, especially at the 20% 

efficiency level, however the discrepancy diminishes at higher efficiency levels. 

$-

$25 

$50 

$75 

$100 

$125 

$150 

$175 

$200 

$225 

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

Incremental Cost

Efficiency Level (%)

AHAM 14cuft AVG

AHAM 20 cuft AVG

DOE 14 cuft

DOE 20 cuft

DOE AVG

Figure 5.9.7 Incremental Cost Curves for Product Class 9 

EERE-2008-BT-STD-0012 COMMENT 22
5-68 

5.9.2.5 Product Class 11 

Incremental cost data for product class 11 (compact refrigerators and refrigeratorfreezers with manual defrost) provided by AHAM is summarized in Table 1 below. 

Table 5.9.6 AHAM Incremental Cost Data for Product Class 11 

Efficiency Level 10% 20% 25% 30% 35% 

Product Class 11—5.5 ft3

Material $16.53 $71.17 $120.81 $130.12 $135.40 

Labor $0 $3.78 $7.55 $7.55 $7.55 

Incremental 

Cost 

Average 

(54%)* 

Overhea

d 

$0 $0 $0 $0 $0 

Building CAPX Blank Blank Blank Blank Blank 

Tooling/Equipment 

CAPX (54%--3)* 

$0 $1.1 $1.1 $5.3 $5.5 

R&D Blank Blank Blank Blank Blank 

Total Industry 

Marketing Blank Blank Blank Blank Blank 

Building CAPX Blank Blank Blank Blank Blank 

Tooling/Equipment 

CAPX 

$0 $0.41 $0.44 $2.04 $2.20 

R&D Blank Blank Blank Blank Blank 

CCE & OTPCE ($million) ShipmentWeighted Average 

Marketing Blank Blank Blank Blank Blank 

CCE&OTPCE: Conversion Capital Expenditures and One-Time Product Conversion Expenses. Material, 

Labor, and Overhead are per unit. Blank entries indicate that there were insufficient responses for AHAM 

to provide data. 

*Percent of the Product Class 11 shipments represented by these data and number of manufacturers 

represented (for capital and one-time expenditures). 

The AHAM incremental cost data for product class 11 are compared with the 

calculations carried out by DOE in Figure 5.9.8 below. The DOE costs in these curves 

have the manufacturer markup taken out so that they can be compared on a consistent 

basis. The AHAM curves include material, labor, overhead, and depreciation and onetime expenses. The discrepancy between the curves is very large. The high AHAM 

estimate for the 20% efficiency level is puzzling, because this is the ENERGY STAR 

level. DOE considers it unlikely that ENERGY STAR products of this product class 

could have $75 higher production cost than baseline efficiency products. Such products 

listed in the ENERGY STAR database are shown in Figure 5.9.9 below. The differences 

between the baseline and ENERGY STAR 4 ft3 refrigerators of the reverse engineering 

work include a larger evaporator, a different compressor, and slightly thicker walls, 

differences that would incur an order of magnitude less than $75 in additional production 

cost. The design option analysis uses a slightly different combination to achieve the 20% 

efficiency level: thicker wall, higher compressor efficiency, and a larger condenser. 

EERE-2008-BT-STD-0012 COMMENT 22
5-69 

$-

$20 

$40 

$60 

$80 

$100 

$120 

$140 

$160 

$180 

$200 

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

Incremental Cost

Efficiency Level (%)

AHAM 5.5 cuft AVG

DOE 1.7 cuft

DOE 4 cuft

DOE AVG

Figure 5.9.8 Incremental Cost Curves for Product Class 11 

0

50

100

150

200

250

300

350

400

234567

Adjusted Volume (cuft)

Energy Use (kWh/year)

Samsung

Haier, Mircofridge

GE Haier

Samsung, Haier

Microfridge

DOE Standard

Samsung

Microfridge

Samsung

Figure 5.9.9 Product Class 11 Refrigerators listed in the ENERGY STAR Database 

EERE-2008-BT-STD-0012 COMMENT 22
5-70 

REFERENCES 

 

1

 “ERA 1.2E, EPA Refrigerator Analysis Program, User’s Manual, Report to the 

Environmental Protection Agency Atmospheric Pollution Prevention Division,” Arthur 

D. Little, Inc., February 1997 

2

 "Engineering Computer Models for Refrigerators, Freezers, Furnaces, Water Heaters, 

Room and Central Air Conditioners," Report to U.S. DOE, by Arthur D. Little, Inc., 

November 1982. 

3

 McLinden, M., "Theoretical Vapor Compression Cycle, CYCLE7," unpublished. 

4

 Morrison, G., and McLinden, M., "Application of a Hard Sphere Equation of State to 

Refrigerants and Refrigerant Mixtures," National Bureau of Standards Technical Note 

1218, 1986. 

5

 "NIST Standard Reference Database 23: NIST Thermodynamic Properties of 

Refrigerants and Refrigerant Mixtures Database, Version 3.0," NIST, December 1991. 

6

 EPA Refrigerator Analysis (ERA) Program: User’s Manual, Version 1.0. United States 

Environmental Protection Agency. EPA-430-R-93-007. June 1993. with Version 1.2 

Update, November 1994. 

7

 M. T. Holtzapple and R. G. Carranza, “Heat Transfer and Pressure Drop of Spined Pipe 

in Cross-Flow – Part I: Pressure Drop Studies”, ASHRAE Transactions, 1990. 

8

 Holtzapple, M.T., A.L.Allen, and K.Lin, “Heat Transfer and Pressure Drop of Spined 

Pipe in Cross-Flow – Part II: Heat Transfer Studies, AHSRAE Transactions, 1990. 

9

 U.S. Department of Energy-Office of Codes and Standards. Technical Support 

Document: Energy Efficiency Standards for Consumer Products: Refrigerators, 

Refrigerator-Freezers, and Freezers, July 1995. Washington, DC. DOE/EE-0064. 

10 Va-q-plus data sheet, http://www.va-q-tec.com/produkte/en/pplus/prod/va-qplus_pdb_en.pdf 

EERE-2008-BT-STD-0012 COMMENT 22
5-71 

 

11 “Electrolux's New Vacuum Insulated Freezer Technology,” Appliance Magazine, 

August 2003. 

<http://www.appliancemagazine.com/new_products.php?article=4971&zone=204&first=1>

12 Personal communication with Embraco, March 2009. 

13 Energy Conservation Program for Consumer Products: Decision and Order Granting a 

Waiver to the General Electric Company From the Department of Energy Residential 

Refrigerator and Refrigerator-Freezer Test Procedure, Notice of decision and order, 

February 27, 2008. 73 FR 10425. 

14 http://search.digikey.com/scripts/DkSearch/dksus.dll?Detail&name=480-3168-2-ND 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 5-A. ENGINEERING DATA 
 

TABLE OF CONTENTS 

5-A.1 INTRODUCTION .................................................................................................5-A-1 

5-A.2 ERA INPUTS.........................................................................................................5-A-1 

5-A.3 INCREMENTAL COST DETAIL ......................................................................5-A-29 

5-A.4 ENGINEERING QUESTIONNAIRE .................................................................5-A-44 

LIST OF TABLES 

Table 5-A.2.1: ERA Inputs for Top-Mount Refrigerator-Freezers (Product Class 3) .........5-A-2 

Table 5-A.2.2: ERA Inputs for Bottom-Mount Refrigerator-Freezers (Product Class 5)....5-A-6 

Table 5-A.2.3: ERA Inputs for Bottom-Mount Refrigerator-Freezers w/TTD Ice 

(Product Class 5A).....................................................................................5-A-10 

Table 5-A.2.4: ERA Inputs for Side-Mount Refrigerator-Freezers (Product Classes 4 

and 7) .........................................................................................................5-A-14 

Table 5-A.2.5: ERA Inputs for Upright Freezers with Automatic Defrost (Product 

Class 9).......................................................................................................5-A-18 

Table 5-A.2.6: ERA Inputs for Chest Freezers with Manual Defrost (Product Class 10) .5-A-21 

Table 5-A.2.7: ERA Inputs for Compact Refrigerators (Product Class 11).......................5-A-23 

Table 5-A.2.8: ERA Inputs for Compact Chest Freezers (Product Class 18)....................5-A-26 

Table 5-A.3.1: Incremental Cost Detail for 16 ft3

 Top-Mount Refrigerator-Freezer 

(Product Class 3)........................................................................................5-A-30 

Table 5-A.3.2: Incremental Cost Detail for 21 ft3 Top-Mount Refrigerator-Freezer 

(Product Class 3)........................................................................................5-A-31 

Table 5-A.3.3: Incremental Cost Detail for 18.5 ft3 Bottom-Mount RefrigeratorFreezer (Product Class 5)...........................................................................5-A-32 

Table 5-A.3.4: Incremental Cost Detail for 25 ft3

 Bottom-Mount Refrigerator-Freezer 

(Product Class 5)........................................................................................5-A-33 

Table 5-A.3.5: Incremental Cost Detail for 22 ft3

 Side-Mount Refrigerator-Freezer with 

TTD Ice (Product Class 7) .........................................................................5-A-34 

Table 5-A.3.6: Incremental Cost Detail for 26 ft3

 Side-Mount Refrigerator-Freezer with 

TTD Ice (Product Class 7) .........................................................................5-A-35 

Table 5-A.3.7: Incremental Cost Detail for 14 ft3

 Upright Freezer with Auto Defrost 

(Product Class 9)........................................................................................5-A-36 

Table 5-A.3.8: Incremental Cost Detail for 20 ft3

 Upright Freezer with Auto Defrost 

(Product Class 9)........................................................................................5-A-37 

Table 5-A.3.9: Incremental Cost Detail for 15 ft3 Chest Freezer (Product Class 10)........5-A-38 

Table 5-A.3.10: Incremental Cost Detail for 20 ft3

 Chest Freezer (Product Class 10)........5-A-39 

Table 5-A.3.11: Incremental Cost Detail for 1.7 ft3 Compact Refrigerator (Product Class 

11) ..............................................................................................................5-A-40 

5-A-i 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.12: Incremental Cost Detail for 4.0 ft3

 Compact Refrigerator (Product Class 

11) ..............................................................................................................5-A-41 

Table 5-A.3.13: Incremental Cost Detail for 3.4 ft3

 Compact Chest Freezer (Product 

Class 18).....................................................................................................5-A-42 

Table 5-A.3.14: Incremental Cost Detail for 7.0 ft3 Compact Chest Freezer (Product 

Class 18).....................................................................................................5-A-43 

5-A-ii 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 5-A. ENGINEERING DATA 

5-A.1 INTRODUCTION 

The Energy-efficient Refrigerator Analysis Program (ERA) was used to calculate energy 

use for baseline and energy-saving configurations for the various product classes of refrigeration 

products. Inputs to this program were generated from reverse-engineering teardowns of select 

refrigerator and refrigerator-freezer models currently available. The values for the input variables 

are shown in tabular format in section 5-A.2. The input is provided to the extent possible in the 

format required for the Windows version of ERA. Because analysis was carried out with the 

DOE version of ERA for most of the products, in some cases the input format may not translate 

directly, and the output values may not match exactly. 

The incremental cost curves describing costs to attain each analyzed efficiency level are 

based on the energy use output from the ERA program. Development of costs for these curves is 

described in chapter 5. The tables in section 5-A.3 show these incremental cost curves in tabular 

format, with identification of the design options required to reach each efficiency level shown. 

As part of the engineering analysis, DOE solicited input from manufacturers on a range 

of technical topics affecting energy use in refrigeration products. The questionnaire used to 

facilitate these interviews is shown in section 5-A.4. 

5-A.2 ERA INPUTS 

The ERA inputs for each of the units selected for reverse-engineering analysis are shown 

below. Some general notes regarding the data include the following: 

1.	 Compressor compartment insulation thickness is specified directly in Windows ERA, 

while DOS ERA used bottom wall thickness. 

2.	 The ERA input for door openings is not provided, since DOE conducted analysis 

based on closed doors. 

3.	 Windows ERA includes separate input for the air in the compressor compartment. 

DOS ERA used the air temperature underneath the cabinet for this region. 

4.	 DOE conducted all analyses using single evaporator system configuration with HFC134a refrigerant. 

5.	 The tube and fin heat exchanger configuration implies forced convection air flow. 

6.	 See the Windows ERA program for definitions of air flow directions for forced 

convection wire fin condensers. 

5-A-1
 

EERE-2008-BT-STD-0012 COMMENT 22
 

7.	 Some products analyzed had spine fin evaporators, which are not supported by ERA. 

Input for a separate spine fin analysis spreadsheet calculation is provided in the tables 

below for these products. 

8.	 Windows ERA does not allow superheat or subcooling input of 0  ̊C, although DOS 

ERA does. Suggested input is 0.5  ̊C in cases where input of 0  ̊C is indicated. 

Table 5-A.2.1: ERA Inputs for Top-Mount Refrigerator-Freezers (Product Class 3) 

Top-Mount Refrigerator-Freezers 16 ft3 Baseline 21 ft3 Baseline 21 ft3 E* 

General Data 

Fresh Food Volume (ft3) 11.6 15.3 15.3 

Freezer Volume (ft3

) 4.1 5.3 5.3 

Total Volume (ft3) 15.7 20.6 20.6 

Adjusted Volume (ft3

) 18.3 23.9 23.9 

Rated Energy Use (kWh/yr) 455 509 408 

Calculated Max. Energy Use (kWh/yr) 455 511 511 

Rated Energy Use Below Maximum (%) 0.0 0.3 20.1 

Cabinet Dimensions 

Cabinet Height (cm) 146.7 165.6 165.6 

Cabinet Width (cm) 70.8 75.3 75.3 

Depth, from Door Flange (cm) 62.6 74.3 74.3 

Depth, from Door Outer Surface (cm) 71.1 80.7 80.7 

Liner Properties 

Outer Liner Thickness (mm) 0.4 0.4 0.4 

Outer Liner Conductivity (W/m-C) 44.7 44.7 44.7 

Inner Liner Thickness (mm) 1.0 1.5 2.0 

Liner Conductivity (W/m-C) 0.16 0.16 0.16 

Compressor Compartment Dimensions 

Top Depth (cm) 12.7 12.4 12.4 

Bottom Depth (cm) 21.6 25.8 25.8 

Height (cm) 26.0 16.0 16.0 

Wall (vertical) (cm) 4.3 5.1 5.1 

Wall (horizontal) (cm) 4.3 5.1 5.1 

Freezer Section 

 Insulation Thickness 

 Top Wall (cm) 5.3 7.1 7.1

 Side Wall (cm) 5.5 7.5 7.5

 Back Wall (cm) 7.0 7.9 7.9

 Door (cm) 6.2 7.2 7.2

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.50 0.50 0.50

 Wedge/Flange Dimensions 

 Freezer Wedge Depth (cm) 7.6 7.0 7.0 

5-A-2
 

EERE-2008-BT-STD-0012 COMMENT 22
Top-Mount Refrigerator-Freezers 16 ft3

 Baseline 21 ft3 Baseline 21 ft3 E* 

 Freezer Flange Width (cm) 3.8 3.8 3.8

 Heat Paths 

 Freezer Gasket Heat Leak (W/m-100C) 9.0 9.0 9.0

 Fzr Cabinet Penetration Heat Leak (W) 1.5 0.0 0.0 

Fresh Food Section 

 Insulation Thickness 

 Side Wall (cm) 3.8 4.8 4.8

 Back Wall (cm) 5.0 4.9 4.9

 Bottom Wall (cm) 4.3 5.1 5.1

 Door (cm) 4.1 4.7 4.7

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.50 0.50 0.50

 Wedge/Flange Dimensions 

 Fresh Food Wedge Depth (cm) 0.1 7.6 7.6

 Fresh Food Flange Width (cm) 3.8 3.8 3.8

 Heat Paths 

 FF Gasket Heat Leak (W/m-100C) 9.0 9.0 9.0

 FF Cabinet Penetration Heat Leak (W) 1.5 0.0 0.0 

Mullion 

 Distance to Top (cm) 44.5 50.8 50.8

 Thickness w/Liners (cm) 5.7 7.1 7.1

 Resistivity w/Liners (m2-C/W-cm) 0.5 0.5 0.5 

Air and Cabinet Temperatures 

 Room Air (°C) 32.2 32.2 32.2

 Freezer Section (°C) -15 -15 -15

 Fresh Food Section (°C) 7.2 7.2 7.2

 Air Under Cabinet (°C) 35.0 35.0 35.0

 Compressor Compartment ( ̊C) 35.0 35.0 35.0

 Air Entering Condenser (°C) 32.2 33.0 33.0 

Defrost and Controls Energy 

Defrost Type (Automatic, Manual) Automatic Automatic Automatic

 Timer Interval (Hr) 14.0 10.5 10.5

 Heater On-Time (Min) 8.0 4.8 4.8

 Defrost Power (W) 390 413 413 

Other Cycle-Dependent Loads 

 Freezer Section (W) 0 0 0

 Fresh Food Section (W) 0.3 0.3 0.3

 Outside Cabinet (W) 0 0 0 

Constant Electrical Loads 

 Freezer Section (W) 0 0 0

 Fresh Food Section (W) 0 0 0

 Outside Cabinet (W) 0 0 0 

Liquid Refrigerant Line Anti-Sweat 

5-A-3
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Top-Mount Refrigerator-Freezers 16 ft3 Baseline 21 ft3 Baseline 21 ft3 E* 

Freezer Door Flange 

 Cycle Average Energy (W) 4 3.8 3.8

 Fraction Heat Leak (0-1) 0.5 0.3 0.3 

Fresh Food Door Flange 

 Cycle Average Energy (W) 0 0 0

 Fraction Heat Leak (0-1) 0 0 0 

Mullion 

 Cycle Average Energy (W) 1.5 1.3 1.3

 Heat Leak to Freezer (0-1) 0.25 0.25 0.25

 Heat Leak to Fresh Food (0-1) 0.25 0.25 0.25 

Evaporator Design 

Exit Superheat 2 2 0

 Fin Type (flat, wavy, herringbone) Spine Flat Flat

 Fan Motor Type AC-Input 

BLDC Shaded Pole Shaded Pole

 Fan Power (W) 3.5 6.1 5.7

 Air Flow Rate (Liter/s) 16.6 21.3 21.3 

Tube Characteristics 

 Width of Tube Row 52.1 45.7 45.7

 Tube OD (mm) 9.4 7.9 7.9

 Tube Wall Thickness (mm) 0.76 0.6 0.6

 # of Tubes Deep 7 4 4

 Tube Pitch (cm) 2.5 3.8 3.8

 # of Tubes Normal to Airflow 2 6 6

 Normal Tube Pitch (cm) 2.5 1.9 1.9 

Fin Characteristics 

 Fin Thickness (mm) 0.25 0.13 0.13

 Fin Pitch (mm) 9.5 6.3 6.3

 Fin Conductivity (W/m-K) 190 190 190

 Fraction Finned (0-1) 0.93 0.89 0.89 

Spine Fin Input Data 

 Spine Height (mm) 10.5 NA NA

 Spine Width (mm) 0.79 NA NA 

Condenser Design a a 

Exit Subcooling (°C) 2 0 0

 Configuration (Static, Hot-wall, Tube 

& Fin, Microchannel) Tube & Fin Tube & Fin Tube & Fin

 Air-side Configuration (wire, plain, 

smooth wavy, herringbone, slit, louver) Wire Wire Wire 

a

 Surface areas calculated by the condenser routine were increased by a factor of 2.56 for the 21 ft3 top-mount 

refrigerators to calibrate with test data for condensing temperatures. 

5-A-4 

EERE-2008-BT-STD-0012 COMMENT 22
Top-Mount Refrigerator-Freezers 16 ft3

 Baseline 21 ft3 Baseline 21 ft3 E* 

Fan Motor Type Shaded Pole Shaded Pole AC-input 

BLDC

 Fan Power (W) 11.2 9.4 3.3

 Air Flow Rate (Liter/s) 30.0 26.0 31.2 

Tube Characteristics 

Airflow Direction (W, L, H) W W W

 Tube OD (mm) 4.8 4.8 4.8

 Tube Wall Thickness (mm) 0.8 0.6 0.6

 Length of Tube in “L” Direction 59.6 20.1 20.1

 # of Tubes in H Direction 1 8 8

 Tube Pitch (cm) 2.5 2.5 2.5

 # of Tubes in W Direction 14 6 6

 Tube Pitch (cm) 2.5 2.5 2.5

 Fraction Air through Exchanger (0-1) 0.6 0.9 0.9 

Fin Characteristics 

 Wire OD (mm) 1.5 1.1 1.1

 # of Wires on 1-side per layer 95 29 29

 Wire Mounting (1-side, 2-sides) 2-sides 2-sides 2-sides

 Wire Fin Pitch (mm) 5.1 5.1 5.1

 Wire Length (cm) 34.9 14.0 14.0

 Wire Conductivity (W/m-K) 44.7 44.7 44.7 

Compressor Data 

Manufacturer Matsushita Matsushita Matsushita

 Model # DGS57C84RAU SF51C97RAU6 DHS57C85RAU 

Cycles per hour 1.0 1.0 1.0 

Interchanger 

Effectiveness (0-1) 0.9 0.95 0.95 

5-A-5
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.2.2: ERA Inputs for Bottom-Mount Refrigerator-Freezers (Product Class 5) 

Bottom-Mount Refrigerator-Freezers 18.5 ft3 25 ft3

 E*, #1 25 ft3 E*, #2 

General Data 

 Fresh Food Volume (ft3

) 13.1 17.8 17.6

 Freezer Volume (ft3

) 5.4 7.3 7.7

 Total Volume (ft3) 18.5 25.1 25.3

 Adjusted Volume (ft3) 21.9 29.6 30.2

 Rated Energy Use (kWh/yr) 476 475 478

 Calculated Max. Energy Use (kWh/yr) 560 595 598

 Rated Energy Use Below Maximum (%) 15.0 20.2 20.0 

Cabinet Dimensions 

Cabinet Height (cm) 160.7 168.3 168.0 

Cabinet Width (cm) 75.3 90.5 90.8 

Depth, from Door Flange (cm) 69.2 72.4 71.3 

Depth, from Door Outer Surface (cm) 76.8 79.4 78.3 

Liner Properties 

Outer Liner Thickness (mm) 0.5 0.6 0.5 

Outer Liner Conductivity (W/m-C) 44.7 43.3 44.7 

Inner Liner Thickness (mm) 1.3 1.9 1.4 

Liner Conductivity (W/m-C) 0.16 0.16 0.16 

Compressor Compartment Dimensions 

Top Depth (cm) 16.5 17.1 12.7 

Bottom Depth (cm) 27.0 27.3 25.4 

Height (cm) 24.5 24.1 22.9 

Wall (vertical) (cm) 7.0 6.9 6.6 

Wall (horizontal) (cm) 7.0 6.9 6.6 

Freezer Cabinet 

 Insulation Thickness 

 Side Wall (cm) 6.9 7.5 6.8

 Back Wall (cm) 7.9 6.5 7.6

 Bottom (cm) 7.0 6.9 6.6

 Door (cm) 6.3 6.0 6.9

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.50 0.50 0.53

 Wedge/Flange Dimensions 

 Freezer Wedge Depth (cm) 5.1 6.4 5.1

 Freezer Flange Width (cm) 3.8 3.8 5.4

 Heat Paths 

 Freezer Gasket Heat Leak (W/m-100C) 9.5 8.0 8.0

 Fzr Cabinet Penetration Heat Leak (W) 0 3 0 

Fresh Food Cabinet 

 Insulation Thickness 

 Top Wall (cm) 5.2 3.9 4.2

 Side Wall (cm) 4.2 5.1 3.5 

5-A-6
 

EERE-2008-BT-STD-0012 COMMENT 22
Bottom-Mount Refrigerator-Freezers 18.5 ft3 25 ft3

 E*, #1 25 ft3 E*, #2

 Back Wall (cm) 5.7 6.8 4.1

 Door (cm) 4.3 4.9 6.9

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.50 0.50 0.53

 Wedge/Flange Dimensions 

 Fresh Food Wedge Depth (cm) 10.2 11.4 0.0

 Fresh Food Flange Width (cm) 3.8 3.8 3.4

 Heat Paths 

 FF Gasket Heat Leak (W/m-100C) 9.5 8.0 8.0

 FF Cabinet Penetration Heat Leak (W) 0.0 3.0 0.0 

Mullion 

 Distance to Top (cm) 92.7 100.0 94.3

 Thickness w/Liners (cm) 5.4 5.4 7.3

 Resistivity w/Liners (m2-C/W-cm) 0.50 0.51 0.5 

Air and Cabinet Temperatures 

 Room Air (°C) 32.2 32.2 32.2

 Freezer Section (°C) -15.0 -15.0 -15.0

 Fresh Food Section (°C) 7.2 7.2 7.2

 Air Under Cabinet (°C) 36.6 35.0 35.0

 Compressor Compartment ( ̊C) 36.6 35.0 35.0

 Air Entering Condenser (°C) 32.2 33.0 34.5 

Defrost and Controls Energy 

Defrost Type (Automatic, Manual) Automatic Automatic Automatic

 Timer Interval (Hr) 7.5 38.0 38.0

 Heater On-Time (Min) 7.0 7.0 24.0

 Defrost Power (W) 375 450 440 

Other Cycle-Dependent Loads 

 Freezer Section (W) 0 0 0

 Fresh Food Section (W) 3 0 0

 Outside Cabinet (W) 0 0 0 

Constant Electrical Loads 

 Freezer Section (W) 0.7 0.0 4.2

 Fresh Food Section (W) 0.0 0.4 0.0

 Outside Cabinet (W) 0.0 0.0 1.5 

Liquid Refrigerant Line Anti-Sweat 

Freezer Door Flange 

 Cycle Average Energy (W) 1.0 3.8 3.0

 Fraction Heat Leak (0-1) 0.75 0.5 0.75 

Fresh Food Door Flange 

 Cycle Average Energy (W) 0 0 0 

Mullion 

 Cycle Average Energy (W) 2 1.3 1.0

 Heat Leak to Freezer (0-1) 0.75 0.5 0.5 

5-A-7
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Bottom-Mount Refrigerator-Freezers 18.5 ft3 25 ft3 E*, #1 25 ft3 E*, #2

 Heat Leak to Fresh Food (0-1) 0.15 0.25 0.25 

Evaporator Design 

Exit Superheat (°C) 0.8 4.0 1.0

 Fin Type (flat, wavy, herringbone) Flat Flat Spine Fin

 Fan Motor Type (Shaded Pole, AC-Input 

BLDC, DC-Input BLDC) Shaded Pole Shaded Pole DC-Input BLDC

 Fan Power (W) 6.2 6.5 3.8

 Air Flow Rate (Liter/s) 20 30 16.6 

Tube Characteristics 

 Width of Tube Row 48.9b 71.1c

 76.2

 Tube OD (mm) 7.9 7.9 9.7

 Tube Wall Thickness (mm) 0.5 0.5 1.1

 # of Tubes Deep 4.5b 4.5c 7

 Tube Pitch (cm) 3.8 3.6 2.5

 # of Tubes Normal to Airflow 4 4 2

 Normal Tube Pitch (cm) 1.9 1.9 2.5 

Fin Characteristics 

 Fin Thickness (mm) 0.13 0.13 0.25

 Fin Pitch (mm) 5.1 5.1 9.5

 Fin Conductivity (W/m-K) 190 190 190

 Fraction Finned (0-1) 0.98 0.89 1.0 

Spine Fin Input Data 

 Spine Height (mm) NA NA 10.5

 Spine Width (mm) NA NA 0.8 

Condenser Design 

Exit Subcooling (°C) 0.7 1.0 1.5

 Configuration (Static, Hot-wall, Tube & 

Fin, Microchannel) Tube & Fin Tube & Fin Tube & Fin

 Air-side Configuration (wire, plain, 

smooth wavy, herringbone, slit, louver) Wire Wire Wire

 Fan Motor Type (Shaded Pole, AC-Input 

BLDC, DC-Input BLDC) 

AC-Input 

BLDC 

AC-Input 

BLDC 

DC-Input 

BLDC

 Fan Power (W) 3.8 3.7 2.6

 Air Flow Rate (Liter/s) 30 30.8 23.7 

Tube Characteristics 

Airflow Direction (W, L, H) L L H

 Tube OD (mm) 4.8 4.8 5.0

 Tube Wall Thickness (mm) 0.5 0.6 0.64 

b

 Number of tubes in the air flow direction alternate 4 and 5, averaging 4.5. ERA analysis was conducted by 

selecting 4 rows deep and increasing the tube row width to 55.0 cm to compensate for the missing tubes. 

c

 Number of tubes in the air flow direction alternate 4 and 5, averaging 4.5. ERA analysis was conducted by 

selecting 4 rows deep and increasing the tube row width to 80.0 cm to compensate for the missing tubes. 

5-A-8 

EERE-2008-BT-STD-0012 COMMENT 22
Bottom-Mount Refrigerator-Freezers 18.5 ft3 25 ft3

 E*, #1 25 ft3 E*, #2

 Length of Tube in “L” Direction (cm) 34.9 34.9 52.4

 # of Tubes in H Direction 2 2 3

 Tube Pitch (cm) 2.2 3.8 0.8

 # of Tubes in W Direction 26 30 10

 Tube Pitch (cm) 2.2 2.2 2.5

 Fraction Air through Exchanger (0-1) 0.8 1.0 1 

Fin Characteristics 

 Wire OD (mm) 1.3 1.3 1.4

 # of Wires on 1-side 55 51 206

 Wire Mounting (1-side, 2-sides) 2-sides 2-sides 2-sides

 Wire Fin Pitch (mm) 4.8 4.8 2.5

 Wire Length (cm) 57.1 66.7 23.5

 Wire Conductivity (W/m-K) 44.7 44.7 44.7 

Compressor Data 

Manufacturer Embraco Tecumseh Embraco

 Model EMX70HSC TPG1370YXA VEGY 8H

 Cycles per hour 1.0 1.5 0.45 

Interchanger 

Effectiveness (0-1) NA 0.95 0.98

 Compressor Shell Inlet Temperature (°C) 33.3 Unspecified Unspecified 

5-A-9
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 5-A.2.3: ERA Inputs for Bottom-Mount Refrigerator-Freezers w/TTD Ice (Product 

Class 5A) 

Bottom-Mount Refrigerator-Freezers w/TTD Ice 

General Data 

25 ft3 

 Fresh Food Volume (ft3) 17.6

 Freezer Volume (ft3) 7.1

 Total Volume (ft3) 24.7

 Adjusted Volume (ft3

) 29.2

 Rated Energy Use (kWh/yr) 547

 Calculated Max. Energy Use (kWh/yr) 685

 % Rated Energy Use Below Maximum (%) 20.0 

Cabinet Dimensions 

Cabinet Height (cm) 171.1 

Cabinet Width (cm) 91.4 

Depth, from Door Flange (cm) 68.6 

Depth, from Door Outer Surface (cm) 76.2 

Liner Properties 

Outer Liner Thickness (mm) 0.5 

Outer Liner Conductivity (W/m-C) 44.7 

Inner Liner Thickness (mm) 1.4 

Liner Conductivity (W/m-C) 0.16 

Compressor Compartment Dimensions 

Top Depth (cm) 13.5 

Bottom Depth (cm) 26.7 

Height (cm) 24.5 

Wall (vertical) (cm) 6.8 

Wall (horizontal) (cm) 6.8 

Freezer Cabinet 

 Insulation Thickness 

 Side Wall (cm) 6.8

 Back Wall (cm) 7.9

 Bottom (cm) 6.8

 Door (cm) 7.1

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.48d

 Wedge/Flange Dimensions 

 Freezer Wedge Depth (cm) 2.5

 Freezer Flange Width (cm) 4.5

 Heat Paths 

 Freezer Gasket Heat Leak (W/m-100C) 8e 

d

 Product has insulation using cyclopentane blowing agent. 

e

 The heat leak parameter entered into ERA was increased to 12.63 to account for additional gasket length, since the 

freezer compartment of this product has two drawers. 

5-A-10 

EERE-2008-BT-STD-0012 COMMENT 22
 

Bottom-Mount Refrigerator-Freezers w/TTD Ice 25 ft3

 Freezer Cabinet Penetration Heat Leak (W) 0 

Fresh Food Cabinet 

 Insulation Thickness 

 Top Wall (cm) 5.2

 Side Wall (cm) 5.1

 Back Wall (cm) 4.7

 Door (cm) 5.1

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.48

 Wedge/Flange Dimensions 

 Fresh Food Wedge Depth (cm) 11.4

 Fresh Food Flange Width (cm) 4.8

 Heat Paths 

 Fresh Food Gasket Heat Leak (W/m-100C) 8f

 Fresh Food Cabinet Penetration Heat Leak (W) 3.0 

Mullion 

 Distance to Top (cm) 102.2

 Thickness w/Liners (cm) 5.1

 Resistivity w/Liners (m2-C/W-cm) 0.47 

Air and Cabinet Temperatures 

 Room Air (°C) 32.2

 Freezer Section (°C) -15.0

 Fresh Food Section (°C) 7.2

 Air Under Cabinet (°C) 35.0

 Compressor Compartment ( ̊C) 35.0

 Air Entering Condenser (°C) 32.2 

Defrost and Controls Energy 

Defrost Type (Automatic, Manual) Automatic

 Timer Interval (Hr) 38.0

 Heater On-Time (Min) 12.7

 Defrost Power (W) 396 

Other Cycle-Dependent Loads 

 Freezer Section (W) 0

 Fresh Food Section (W) 0

 Outside Cabinet (W) 0 

Constant Electrical Loads 

 Freezer Section (W) 0

 Fresh Food Section (W) 0

 Outside Cabinet (W) 4.0 

Liquid Refrigerant Line Anti-Sweat 

f

 The heat leak parameter entered into ERA was increased to 12.3 to account for additional gasket length, since the 

fresh food compartment of this product has French doors. 

5-A-11 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Bottom-Mount Refrigerator-Freezers w/TTD Ice 25 ft3 

Freezer Door Flange 

 Cycle Average Energy (W) 3.8

 Fraction Heat Leak (0-1) 0.5 

Fresh Food Door Flange 

 Cycle Average Energy (W) 0

 Fraction Heat Leak (0-1) 0 

Mullion 

 Cycle Average Energy (W) 1.3

 Heat Leak to Freezer (0-1) .5

 Heat Leak to Fresh Food (0-1) .25 

Evaporator Design 

Exit Superheat (°C) 0.8

 Fin Type (flat, wavy, herringbone) Flat

 Fan Motor Type (Shaded Pole, AC-Input BLDC, DC-Input BLDC) DC-Input BLDC

 Fan Power (W) 1.5

 Air Flow Rate (Liter/s) 16.0 

Tube Characteristics 

 Width of Tube Row 70.5g

 Tube OD (mm) 7.9

 Tube Wall Thickness (mm) 0.7

 # of Tubes Deep 4.5g

 Tube Pitch (cm) 3.8

 # of Tubes Normal to Airflow 4

 Normal Tube Pitch (cm) 2.5 

Fin Characteristics 

 Fin Thickness (mm) 0.15

 Fin Pitch (mm) 5.1

 Fin Conductivity (W/m-K) 190

 Fraction Finned (0-1) 0.90 

Condenser Design 

Exit Subcooling (°C) 0.7

 Configuration (Static, Hot-wall, Tube & Fin, Microchannel) Tube & Fin

 Air-side Configuration (wire, plain, smooth wavy, herringbone, slit, 

louver) Wire

 Fan Motor Type (Shaded Pole, AC-Input BLDC, DC-Input BLDC) DC-Input BLDC

 Fan Power (W) 1.6

 Air Flow Rate (Liter/s) 24.0 

Tube Characteristics 

Airflow Direction (W, L, H) W

 Tube OD (mm) 5.0 

g

 Number of tubes in the air flow direction alternate 4 and 5, averaging 4.5. ERA analysis was conducted by 

selecting 4 rows deep and increasing the tube row width to 79.3 cm to compensate for the missing tubes. 

5-A-12 

EERE-2008-BT-STD-0012 COMMENT 22
0.64

15.2

12

2.2

10

2.5

0.9 

Bottom-Mount Refrigerator-Freezers w/TTD Ice 25 ft3

 Tube Wall Thickness (mm)
 

 Length of Tube in “L” Direction (cm)
 

# of Tubes in H Direction 

 Tube Pitch (cm) 

 # of Tubes in W Direction 

 Tube Pitch (cm) 

Fraction Air through Exchanger (0-1) 

Fin Characteristics 

 Wire OD (mm) 

 # of Wires on 1-side 

 Wire Mounting (1-side, 2-sides) 

 Wire Fin Pitch (mm)
 

 Wire Length (cm)
 

 Wire Conductivity (W/m-K) 

Compressor Data 

Manufacturer 

Model # 

Cycles per Hour 

Interchanger 

Effectiveness (0-1) 

1.4

22

2-sides

6.4

18.0

44.7
 

Embraco

EGX90HLC

1.0
 

5-A-13
 

0.95 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.2.4: ERA Inputs for Side-Mount Refrigerator-Freezers (Product Classes 4 and 

7) 

Side-Mount Refrigerator-Freezers PC7 26 ft3 PC7 26 ft3

 E* PC4 22 ft3 

General Data 

 Fresh Food Volume (ft3) 16.5 16.5 14.8

 Freezer Volume (ft3

) 9.5 9.5 7.0

 Total Volume (ft3) 26.0 26.0 

 Adjusted Volume (ft3) 32.0 32.0 26.3

 Rated Energy Use (ft3

) 728 582 635

 Calculated Max. Energy Use (kWh/yr) 729 729 637

 % Rated Energy Use Below Maximum 

(%) 0.2 20.2 0.3 

Cabinet Dimensions 

Cabinet Height (cm) 165.9 165.9 162.6 

Cabinet Width (cm) 90.2 90.2 85.1 

Depth, from Door Flange (cm) 72.0 72.0 69.3 

Depth, from Door Outer Surface (cm) 80.3 80.3 77.8 

Liner Properties 

Outer Shell Thickness (mm) 0.5 1 0.4 

Shell Conductivity (W/m-C) 44.7 44.7 44.7 

Inner Liner Thickness (mm) 0.5 1 0.4 

Liner Conductivity (W/m-C) 0.16 0.16 44.7 

Compressor Compartment Dimensions 

Top Depth (cm) 15.9 15.9 24.1 

Bottom Depth (cm) 27.9 27.9 30.5 

Height (cm) 23.5 23.5 25.1 

Wall (vertical) (cm) 8.3 8.3 5.8 

Wall (horizontal) (cm) 8.3 8.3 5.8 

Freezer Cabinet 

 Insulation Thickness – Freezer 

 Top Wall (cm) 7.2 7.2 6.2

 Side Wall (cm) 5.7 5.7 7.3

 Back Wall (cm) 7.8 7.8 5.7

 Bottom (cm) 8.3 8.3 5.8

 Door (cm) 6.4 6.4 5.7 

Insulation Resistivity - Freezer 

 All Walls (m2-C/W-cm) 0.50 0.50 0.5 

Wedge/Flange Dimensions 

 Freezer Wedge Depth (cm) 0.1 0.1 7.0

 Freezer Flange Width (cm) 5.7 5.7 3.8

 Heat Paths 

 Fzr Gasket Heat Leak (W/m-100C) 9.0 9.0 9.0

 Fzr Cabinet Penetration Heat Leak (W) 11.0 11.0 8.0 

Fresh Food Cabinet 

5-A-14
 

EERE-2008-BT-STD-0012 COMMENT 22
Side-Mount Refrigerator-Freezers PC7 26 ft3 PC7 26 ft3

 E* PC4 22 ft3

 Insulation Thickness – Fresh Food 

 Top Wall (cm) 4.0 4.0 4.0

 Side Wall (cm) 3.6 3.6 3.8

 Back Wall (cm) 3.6 3.6 4.8

 Bottom (cm) 6.2 6.2 4.7

 Door (cm) 6.4 6.4 5.7

 Insulation Resistivity – Fresh Food 

 All Walls (m2-C/W-cm) 0.50 0.50 0.5

 Wedge/Flange Dimensions 

 Fresh Food Wedge Depth (cm) 0.1 0.1 11.4

 Fresh Food Flange Width (cm) 3.6 3.6 3.8

 Heat Paths 

 FF Gasket Heat Leak (W/m-100C) 9.0 9.0 9.0

 FF Cabinet Penetration Heat Leak (W) 8.0 8.0 5.0

 Mullion 

 Distance to Right Side Wall (cm) 49.2 49.2 49.4

 Thickness w/Liners (cm) 3.5 3.5 3.7

 Resistivity w/Liners (m2-C/W-cm) 0.53 0.53 0.52 

Air and Cabinet Temperatures 

 Room Air (°C) 32.3 32.2 32.3

 Freezer Section (°C) -15.0 -15.0 -15.0

 Fresh Food Section (°C) 7.2 7.2 7.2

 Air Under Cabinet (°C) 35.0 35.0 35.0

 Compressor Compartment ( ̊C) 35.0 35.0 35.0

 Air Entering Condenser (°C) 33.0 33.0 33.0 

Defrost and Controls Energy 

Defrost Type (Automatic, Manual) Automatic Automatic Automatic

 Timer Interval (Hr) 10.0 10.0 38.0

 Heater On-Time (Min) 5.0 5.0 18.0

 Defrost Power (W) 500 500 535 

Other Cycle-Dependent Loads 

 Freezer Section (W) 0 0 0

 Fresh Food Section (W) 0 0 0

 Outside Cabinet (W) 0 0 0 

Constant Electrical Loads 

 Freezer Section (W) 0 0 0

 Fresh Food Section (W) 0.5 0.4 0

 Outside Cabinet (W) 0 0 1.3 

Electric Anti-Sweat Heat 

Freezer Door Flange 

 Cycle Average Energy (W) 2.1 2.1 0

 Fraction Heat Leak (0-1) 0.5 0.5 0.5 

Liquid Refrigerant Line Anti-Sweat 

5-A-15
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Side-Mount Refrigerator-Freezers PC7 26 ft3 PC7 26 ft3 E* PC4 22 ft3 

Freezer Door Flange 

 Cycle Average Energy (W) 3.0 3.0 3.8

 Fraction Heat Leak (0-1) 0.5 0.5 0.5 

Fresh Food Door Flange 

 Cycle Average Energy (W) 0 0 0

 Fraction Heat Leak (0-1) 0 0 0 

Mullion 

 Cycle Average Energy (W) 3.0 3.0 1.3

 Heat Leak to Freezer (0-1) 0.5 0.5 0.25

 Heat Leak to Fresh Food (0-1) 0.25 0.25 0.25 

Evaporator Design 

Exit Superheat (°C) 4.0 4.0 2.0

 Fin Type (flat, wavy, herringbone) Flat Flat Spine Fin

 Fan Motor Type (Shaded Pole, ACInput BLDC, DC-Input BLDC) Shaded Pole Shaded Pole DC-Input BLDC

 Fan Power (W) 5.8 5.8 3.3

 Air Flow Rate (Liter/s) 21.3 21.3 21.3 

Tube Characteristics 

 Width of Tube Row 27.9h 27.9h 24.1

 Tube OD (mm) 7.9 7.9 9.3

 Tube Wall Thickness (mm) 0.7 0.7 0.8

 # of Tubes Deep 7.5h 7.5h

 16

 Tube Pitch (cm) 3.8 3.8 2.9

 # of Tubes Normal to Airflow 8 8 2

 Normal Tube Pitch (cm) 1.3 1.3 5.1 

Fin Characteristics 

 Fin Thickness (mm) 0.2 0.2 0.25

 Fin Pitch (mm) 5.1 5.1 9.5

 Fin Conductivity (W/m-K) 190 190 190

 Fraction Finned (0-1) 0.77 0.77 1 

Spine Fin Input Data 

 Spine Height (mm) NA NA 10.5

 Spine Width (mm) NA NA 0.8 

Condenser Design i i j

 Exit Subcooling (°C) 0.0 0.0 0.0

 Configuration (Static, Hot-wall, Tube & Tube & Fin Tube & Fin Tube & Fin 

h

 Number of tubes in the air flow direction alternate 7 and 8, averaging 7.5. ERA analysis was conducted by 

selecting 8 rows deep and decreasing the tube row width to 26.2 cm to compensate for the added tubes. 

i

 Surface areas calculated by the condenser routine were increased by a factor of 2.63 for the 26 ft3 side-mount 

refrigerators to calibrate with test data for condensing temperatures. 

j

 Surface area calculated by the condenser routine was increased by a factor of 1.4 for the 22 ft3 side-mount 

refrigerator to calibrate with test data for condensing temperatures. 

5-A-16 

EERE-2008-BT-STD-0012 COMMENT 22
Side-Mount Refrigerator-Freezers PC7 26 ft3 PC7 26 ft3

 E* PC4 22 ft3 

Fin, Microchannel) 

 Air-side Configuration (wire, plain, 

smooth wavy, herringbone, slit, louver) Wire Wire Wire

 Fan Motor Type (Shaded Pole, ACInput BLDC, DC-Input BLDC) Shaded Pole AC-Input 

BLDC Shaded Pole

 Fan Power (W) 8.5 3.4 9.1

 Air Flow Rate (Liter/s) 26 26 26 

Tube Characteristics 

Airflow Direction (W, L, H) W W H

 Tube OD (mm) 4.8 4.8 4.7

 Tube Wall Thickness (mm) 0.6 0.6 0.63

 Length of Tube in “L” Direction 18.2 18.2 58.0

 # of Tubes in H Direction 9 9 2

 Tube Pitch (cm) 2.3 2.3 2.5

 # of Tubes in W Direction 10 10 10

 Tube Pitch (cm) 2.5 2.5 2.5 

Fin Characteristics 

 Wire OD (mm) 1.1 1.1 1.3

 # of Wires on 1-side 23 23 111

 Wire Mounting (1-side, 2-sides) 2-sides 2-sides 2-sides

 Wire Fin Pitch (mm) 5.6 5.6 5.2

 Wire Length (cm) 24.1 24.1 23.5

 Wire Conductivity (W/m-K) 44.7 44.7 44.7

 Fraction Air through Exchanger (0-1) 1 1 1 

Compressor Data 

Manufacturer Tecumseh Embraco Matsushita

 Model # TSA1374YAS EGX70HLC DC57C84RCU6

 Cycles per Hour 1.12 1.16 0.7 

Interchanger 

Effectiveness (0-1) 0.95 0.95 0.85 

5-A-17
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.2.5: ERA Inputs for Upright Freezers with Automatic Defrost (Product Class 9) 

Upright Freezers 14 ft3

 Baseline 20 ft3 Baseline 20 ft3 E* 

General Data 

 Freezer Volume (ft3

) 13.7 20.1 20.1

 Adjusted Volume (ft3

) 23.7 34.8 34.8

 Rated Energy Use (kWh/yr) 621 745 671

 Calculated Max. Energy Use 

(kWh/yr) 621 758 758

 % Rated Energy Use Below 

Maximum (%) 0.0 1.8 11.5 

Cabinet Dimensions 

Cabinet Height (cm) 130.2 156.2 156.2 

Cabinet Width (cm) 71.3 83.8 83.8 

Depth, from Door Flange (cm) 66.7 64.5 64.5 

Depth, from Door Outer Surface (cm) 72.4 71.1 71.1 

Liner Properties 

Outer Liner Thickness (mm) 0.4 0.9 0.9 

Outer Liner Conductivity (W/m-C) 44.7 44.7 44.7 

Inner Liner Thickness (mm) 0.4 2.2 2.2 

Liner Conductivity (W/m-C) 44.7 0.16 0.16 

Compressor Compartment 

Height (cm) 1.9 27.9 27.9 

Top Depth (cm) 17.8 5.1 5.1 

Bottom Depth (cm) 17.8 30.5 30.5 

Wall (vertical) (cm) 6.2 6.2 6.2 

Wall (horizontal) (cm) 6.2 6.2 6.2 

Insulation 

 Insulation Thickness 

 Top Wall (cm) 6.4 4.8 4.8

 Side Wall (cm) 6.4 5.7 5.7

 Back Wall (cm) 6.4 5.1 5.1

 Bottom Wall (cm) 6.2 6.2 6.2

 Door Average Thickness (cm) 3.8 7.1 7.1

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.50 0.50 0.50

 Wedge/Flange Dimensions 

 Wedge Depth (cm) 9.5 8.9 8.9

 Flange Width (cm) 5.9 4.7 4.7

 Heat Paths 

 Gasket Heat Leak (W/m-100C) 12 9 9

 Cabinet Penetration Heat Leak (W) 15 17 17 

Air and Cabinet Temperatures 

 Room Air (°C) 32.2 32.2 32.2

 Air Under Cabinet (°C) 35.0 35.5 35.5 

5-A-18
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Upright Freezers 14 ft3 Baseline 20 ft3 Baseline 20 ft3 E*

 Air Entering Condenser (°C) 32.2 32.2 32.2

 Compressor Compartment ( ̊C) 35.0 35.5 35.5

 Cabinet (°C) -17.8 -17.8 -17.8 

Defrost and Controls Energy 

Defrost Type (Automatic, Manual) Automatic Automatic Automatic

 Timer Interval (Hr) 12.0 9.0 9.0

 Heater On-Time (Min) 5.1 18.0 18.0

 Defrost Power (W) 425 370 370 

Other Cycle-Dependent Loads 

 Outside Cabinet (W) 0 0 0

 Cabinet (W) 1.6 0.3 0.3 

Constant Electrical Loads 

 Outside Cabinet (W) 0 0 0

 Cabinet (W) 0 0 0 

Refrigerant Line Anti-Sweat None None None 

Evaporator Design 

Exit Superheat 5.0 0.0 0.0

 Fin Type (flat, wavy, herringbone) Flat Flat Flat

 Fan Motor Type (Shaded Pole, ACInput BLDC, DC-Input BLDC) Shaded Pole Shaded Pole AC-Input BLDC

 Fan Power (W) 7.4 11.2 4.5

 Air Flow Rate (Liter/s) 26.0 23.7 23.7 

Tube Characteristics 

 Width of Tube Row 55.9k 50.2 50.2

 Tube OD (mm) 7.8 8.6 8.6

 Tube Wall Thickness (mm) 0.8 0.9 0.9

 # of Tubes Deep 4.5k 9 9

 Tube Pitch (cm) 3.8 3.2 3.2

 # of Tubes Normal to Airflow 4 2 2

 Normal Tube Pitch (cm) 1.3 2.5 2.5 

Fin Characteristics 

 Fin Thickness (mm) 0.18 0.24 0.24

 Fin Pitch (mm) 4.6 5.1 5.1

 Fin Conductivity (W/m-K) 190 190 190

 Fraction Finned (0-1) 0.9 0.9 0.9 

Condenser Design 

Exit Subcooling (°C) 3 1 1

 Configuration (Static, Hot-wall, 

Tube & Fin, Microchannel) Hot-wall Hot-wall Hot-wall 

Design Data 

k

 Number of tubes in the air flow direction alternate 4 and 5, averaging 4.5. ERA analysis was conducted by 

selecting 4 rows deep and increasing the tube row width to 62.9 cm to compensate for the missing tubes. 

5-A-19 

EERE-2008-BT-STD-0012 COMMENT 22
Upright Freezers 14 ft3

 Baseline 20 ft3 Baseline 20 ft3 E*

 Total Area (sides) (m2) 2.0 2.1 2.1

 Width, Side Normal to Tubes (cm) 288 333 333

 Number of Legs 26 30 30

 Length of Tubing on Wall (m) 20.3 22.0 22.0

 Tube OD (mm) 4.7 6.4 6.4

 Tube Wall Thickness (mm) 0.8 0.8 0.8

 Thickness of Liner (mm) 0.38 0.9 0.9

 Thermal Conductivity (W/m-K) 44.7 44.7 44.7

 Number of other Hot Walls (0-2) 1 1 1 

Second Hotwall (Top) 

Total Area (m2

) 0.47 0.52 0.52

 Width, Side Normal to Tubes (cm) 71 84 84

 Number of Legs 7 8 8

 Length of Tubing on Wall (m) 5.4 5.8 5.8 

Compressor Data 

Manufacturer Embraco Matsushita Matsushita

 Model # EMY60HER DG73C12RAU6 DG73C12RAU6

 Cycles per Hour 1.4 1.5 1.5 

Interchanger 

 Effectiveness (0-1) 0.7 0.98 0.98 

5-A-20
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 5-A.2.6: ERA Inputs for Chest Freezers with Manual Defrost (Product Class 10) 

Chest Freezers 15 ft3

 Baseline 15ft3 E* 20 ft3 Baseline 

General Data 

 Freezer Volume (ft3

) 14.8 14.8 19.9 

 Adjusted Volume (ft3

) 25.6 25.6 34.4 

Rated Energy Use (kWh/yr) 394 354 480

 Calculated Max. Energy Use (kWh/yr) 397 397 484

 Rated Energy Use Below Maximum (%) 0.7 10.8 0.8 

Cabinet Dimensions 

Cabinet Length (cm) 116.8 116.8 155.9 

Cabinet Width (cm) 68.6 68.6 69.9 

Depth, from Door Flange (cm) 81.1 81.1 81.6 

Depth, from Door Outer Surface (cm) 86.8 86.8 87.0 

Liner Properties 

Outer Liner Thickness (mm) 0.5 0.5 0.5 

Outer Liner Conductivity (W/m-C) 44.7 44.7 44.7 

Inner Liner Thickness (mm) 1.3 1.3 0.4 

Liner Conductivity (W/m-C) 44.7 44.7 44.7 

Compressor Compartment Dimensionsl

 Height (cm) 27.9 27.9 22.9

 Depth (cm) 9.1 9.1 22.2

 Fractional width of compartment (cm) 1 1 1

 Top Wall Insulation Thickness (cm) 6.9 6.9 7.7

 Front Wall Insulation Thickness (cm) 5.1 5.1 7.7

 Insulation Thickness 

 Side Wall (cm) 6.6 6.6 6.7

 Bottom (cm) 6.4 6.4 7.0

 Door (cm) 4.8 4.8 5.1

 Insulation Resistivity 

 All Walls (m2-C/W-cm) 0.5 0.5 0.50

 Wedge/Flange Dimensions 

 Wedge Depth (cm) 1.3 1.3 1.0

 Flange Width (cm) 4.6 4.6 5.4

 Heat Paths 

 Gasket Heat Leak (W/m-100C) 9 9 9

 Cabinet Penetration Heat Leak (W) 0.0 0.0 0.0 

Air and Cabinet Temperatures 

 Room Air (°C) 32.2 32.2 32.2

 Air Under Cabinet (°C) 38.0 38.0 36.0

 Air Entering Condenser (°C) 32.2 32.2 33.0

 Compressor Compartment (°C) 38.0 38.0 36.0 

l Windows ERA allows incorporation of the compressor compartment either into the long or the short wall. DOS 

ERA allowed incorporation only into the short wall, so the short wall option should be entered for Windows ERA. 

5-A-21 

EERE-2008-BT-STD-0012 COMMENT 22
Chest Freezers 15 ft3

 Baseline 15ft3 E* 20 ft3 Baseline 

Cabinet (°C) -17.8 -17.8 -17.8 

Defrost and Controls Energy 

Defrost Type (Automatic, Manual) Manual Manual Manual 

Other Cycle-Dependent Loads 

 Outside Cabinet (W) 0 0 0

 Inside Cabinet (W) 0 0 0 

Constant Electrical Loads 

 Outside Cabinet (W) 0.4 0.4 0.1

 Inside Cabinet (W) 0 0 0 

Refrigerant Line Anti-Sweat None None None 

Evaporator Design (Cold Wall) 

Exit Superheat 0.5 0.5 0.5

 Tube OD (mm) 6.4 6.4 7.9

 Tube Wall Thickness (mm) 0.8 0.8 0.8 

Side Walls (perimeter) 

Total Area of Side Walls (m2

) 1.57 1.57 2.73

 Number of Tube Legs 9 9 9

 Width Normal to Tubes 49.1 49.1 73

 Liner Thickness (mm) 1.3 1.3 0.4

 Liner Conductivity (W/mK) 44.7 44.7 44.7 

Bottom Surface 

 Area of Bottom Surface (m2

) 0.17 0.17 0.3

 Number of Tube Legs 3 3 2

 Width Normal to Tubes 16.4 16.4 15 

Condenser Design 

Exit Subcooling (°C) 0.5 0.5 0.5

 Configuration Hot-wall Hot-wall Hot-wall

 Total Area (m2

) 2.0 2.0 2.4

 Width of Side Normal to Tubes (cm) 53.3 53.3 53.7

 Number of Legs 6 6 7

 Length of Tubing on Wall (m) 22.3 22.3 29.5

 Tube OD (mm) 4.8 4.8 4.8

 Tube Wall Thickness (mm) 0.8 0.8 0.8

 Thickness of Liner (mm) 0.5 0.5 0.5

 Thermal Conductivity (W/m-K) 44.7 44.7 44.7

 Number of other Hot Walls (0-2) 0 0 0 

Second Hotwall None None None 

Compressor Data 

Manufacturer Matsushita Matsushita Matsushita

 Model # SF51C97RAU6 DG57C84RAU6 DGH66C94RAU

 Cycles per Hour 1.0 1.0 1.0 

Interchanger 

Effectiveness (0-1) 0.9 0.9 0.7 

5-A-22
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 5-A.2.7: ERA Inputs for Compact Refrigerators (Product Class 11) 

Compact Refrigerators 4 ft3

 Baseline 4 ft3 E* 1.7 ft3 

General Data 

 Fresh Food Volume (ft3) 3.3 3.65 1.5

 Freezer Volume (ft3

) 0.7m 0.44 0.2

 Total Volume (ft3) 4.0 4.1 1.7

 Adjusted Volume (ft3) 4.3 4.3 1.7n

 Rated Energy Use (kWh/yr) 340 270 296

 Calculated Max. Energy Use (kWh/yr) 345 345 317

 Rated Energy Use Below Maximum (%) 1.5 22 6.8 

Cabinet Dimensions 

 Cabinet Height (cm) 83.5 83.8 47.0

 Cabinet Width (cm) 47.3 49.5 44.5

 Depth, from Door Flange (cm) 40.4 45.6 40.6

 Depth, from Door Outer Surface (cm) 44.5 50.2 44.8 

Liner Properties 

 Outer Liner Thickness (mm) 0.8 0.5 0.4

 Outer Liner Conductivity (W/m-C) 44.7 44.7 44.7

 Inner Liner Thickness (mm) 1.3 1.1 1.3

 Liner Conductivity (W/m-C) 0.16 0.16 0.16 

Compressor Compartment Dimensions 

 Height (cm) 21.6 20.3 19.1

 Horizontal Wall Thickness (cm) 3.4 4.3 3.8

 Top Depth (cm) 16.2 12.7 13.0

 Vertical Wall Thickness (cm) 3.3 3.0 2.8

 Bottom Depth (cm) 16.2 12.7 13.0 

Insulation Thickness – Fresh Food 

 Top Wall (cm) 2.5 4.1 3.4

 Side Wall (cm) 2.7 4.1 3.4

 Back Wall (cm) 3.3 5.8 3.5

 Bottom (cm) 2.5 4.8 3.1

 Door (cm) 2.8 4.3 3.3 

Insulation Resistivity – Fresh Food 

 All Walls (m2-C/W-cm) 0.50 0.50 0.50 

Wedge/Flange Dimensions 

 Fresh Food Flange Width (cm) 2.3 3.3 2.5 

m The rated freezer volume is 0.7 ft3

 as indicated, but the volume based on observed freezer dimensions is 0.4 ft3 

n

 This product is classified as an all-refrigerator for testing and rating purposes, since its freezer compartment is less 

than 0.5 ft3

 in volume. It is not clear wheter the 4 ft3 E* product was also rated as an all-refrigerator based on 

available data. DOE analyzed both 4 ft3

 products as basic refrigerators and the 1.7 ft3 product as an all-refrigerator. 

5-A-23 

EERE-2008-BT-STD-0012 COMMENT 22
 

Compact Refrigerators 4 ft3 Baseline 4 ft3 E* 1.7 ft3

 Fresh Food Wedge Depth (cm) 0 0 0.6

 Heat Paths 

 Gasket Heat Leak (W/m-100C) 12.0 9.0 12.0

 Cabinet Penetration Heat Leak (W) 0 0 0 

Air and Cabinet Temperatures 

 Room Air (°C) 32.2 32.2 32.2

 Freezer Section (°C) -9.4 -9.4 -3.9

 Fresh Food Section (°C) 7.2 7.2 3.3

 Air Under Cabinet (°C) 35.0 36.6 35.0

 Compressor Compartment (°C) 35.0 36.6 35.0

 Air Entering Condenser (°C) 32.2 32.2 32.2 

Defrost and Controls Energy 

Defrost Type (Manual, Cycle) Manual Manual Manual 

Cycle-Dependent Loads 

 Inside Cabinet (W) 0 0 0

 Outside Cabinet (W) 0 0 0 

Constant Electrical Loads 

 Inside Cabinet (W) 0 0 0

 Outside Cabinet (W) 0 0 0 

Anti-Sweat Heat None None None 

Evaporator Design 

Exit Superheat (°C) 0.0 0.1 2.0

 Tube Height (mm)

 Width (mm) 

 Hydraulic Diameter (mm) 

4.4 

9.5 

6.1 

4.7 

9.5 

6.3 

4.3 

9.5 

5.9

 Refrigerant Tube Length (m) 6.7 6.1 3.1

 Number of Legs 11 10 8 

Freezer Surfaces: Present (Y/N), Spacing to 

Cabinet Wall (cm)

 Top N N N

 Left Y 1.4 Y 1.6 Y 15

 Right Y 1.4 Y 1.6 Y 1.3 

Freezer Box Dimensions 

 Width (cm) 38.7 38.4 21.0

 Height (cm) 11.4 12.7 8.9

 Depth (cm) 25.4 24.8 21.0

 Inner Door (Y or N) Y Y Y 

Condenser Design 

Exit Subcooling (°C) 1.0 1.0 0.0 

Heat Transfer Type (Static, Hot-wall, Tube 

& Fin, Microchannel) Static Static Hot-wall 

Static Condenser Details 

Fin Type Wire Wire NA 

5-A-24
 

EERE-2008-BT-STD-0012 COMMENT 22
Compact Refrigerators 4 ft3

 Baseline 4 ft3 E* 1.7 ft3

 Tube OD (mm) 4.8 4.8 NA

 Tube Wall Thickness (mm) 0.6 0.6 NA

 Number of Tube Rows 9 9 NA

 Tube Pitch (mm) 6.0 6.0 NA

 Width of Tube Row (cm) 43.2 43.2 NA

 Wire OD (mm) 1.5 1.5 NA

 Wire Length (cm) 60.3 60.3 NA

 # of Wires 98 98 NA

 Wire Conductivity (W/m-K) 44.7 44.7 NA 

Hot Wall Condenser Details 

 First Hot Wall (sides)

 Total Area of Side Panels (m2) NA NA 0.33

 Width of Side Normal to Tubes (cm) NA NA 94.0

 Number of Legs NA NA 16

 Length of Tubing on Wall (m) NA NA 6.0

 Tube OD (cm) NA NA 3.9

 Tube Wall (mm) NA NA 0.76

 Liner Thickness (mm) NA NA 0.38

 Thermal Conductivity (W/mK) NA NA 44.7

 Second Hot Wall (top) 

 Total Area (m2) NA NA 0.10

 Width Normal to Tubes (cm) NA NA 23.5

 Number of Legs NA NA 4

 Length of Tubing on Wall (m) NA NA 1.7 

Compressor Data 

Manufacturer ZEL LG Huayi 

Model # GVT44AD NSA36LACG AES25DS

 Cycles per Hour 4.0 5.0 3.0 

Interchanger 

Effectiveness (0-1) 0.8 0.98 0.7 

5-A-25
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 5-A.2.8: ERA Inputs for Compact Chest Freezers (Product Class 18) 

Compact Chest Freezers 3.4 ft3 7.0 ft3

, #1 7.0 ft3, #2 

General Data 

 Freezer Volume (ft3

) 3.4 7.0 7.0

 Adjusted Volume (ft3

) 5.9 12.1 12.1

 Rated Energy Use (kWh/yr) 213 277 276

 Calculated Max. Energy Use (kWh/yr) 213 279 279

 Rated Energy Use Below Maximum (%) 0 0.6 0.9 

Cabinet Dimensions 

 Cabinet Length (cm) 53.3 92.7 94.0

 Cabinet Width (cm) 58.4 51.8 58.4

 Depth, from Door Flange (cm) 76.2 74.6 73.3

 Depth, from Door Outer Surface (cm) 81.3 80.0 78.7 

Liner Properties 

 Outer Liner Thickness (mm) 0.5 0.6 0.9

 Outer Liner Conductivity (W/m-C) 44.7 44.7 44.7

 Inner Liner Thickness (mm) 0.4 0.4 1.0

 Liner Conductivity (W/m-C) 190 190 190 

Compressor Compartment Dimensionso

 Height (cm) 21.0 28.6 22.9

 Depth (cm) 19.7 18.1 22.9

 Fractional width of compartment (0-1) 1 1 1

 Top Wall Insulation Thickness (cm) 6.6 7.0 6.4

 Front Wall Insulation Thickness (cm) 6.4 7.0 7.3 

Insulation Thickness – Freezer 

 Side Wall (cm) 6.7 6.0 6.4

 Bottom Wall (cm) 6.3 5.1 7.3

 Door (cm) 5.8 6.4 5.5 

Insulation Resistivity – Freezer 

 All Walls (m2-C/W-cm) 0.5 0.5 0.53 

Wedge/Flange Dimensions 

 Wedge Depth (cm) 1.0 1.0 1.9

 Flange Width (cm) 3.8 4.0 4.4

 Heat Paths 

 Gasket Heat Leak (W/m-100C) 7.5 7.5 7.5

 Cabinet Penetration Heat Leak (W) 0 0 0 

Air and Cabinet Temperatures 

 Room Air (°C) 32.2 32.2 32.2

 Air Under Cabinet (°C) 35.0 35.0 35.0

 Air Entering Condenser (°C) 32.2 32.2 32.2

 Compressor Compartment (°C) 35.0 35.0 35.0 

o Windows ERA allows incorporation of the compressor compartment either into the long or the short wall. DOS 

ERA allowed incorporation only into the short wall, so the short wall option should be entered for Windows ERA. 

5-A-26 

EERE-2008-BT-STD-0012 COMMENT 22
Compact Chest Freezers 3.4 ft3 7.0 ft3

, #1 7.0 ft3, #2

 Cabinet Setpoint (°C) -17.8 -17.8 -17.8 

Defrost and Controls Energy 

Defrost Type (Manual, Auto) Manual Manual Manual 

Cycle-Dependent Loads 

 Inside Cabinet (W) 0 0 0

 Outside Cabinet (W) 0 0 0 

Constant Electrical Loads 

 Inside Cabinet (W) 0 0 0

 Outside Cabinet (W) 0.4 0.2 0.1 

Anti-Sweat Heat None None None 

Evaporator Design 

Exit Superheat (°C) 0.5 0.5 0.0

 Tube OD (mm) 8.0 7.6 6.4

 Tube Wall Thickness (mm) 0.6 0.6 0.6

 Liner Thickness (mm) 0.4 0.4 1.0

 Liner Conductivity (W/m-K) 190 190 190

 Total Area of Side Walls (m2) 1.1 1.43 1.5

 Number of Legs 10 9 12

 Width Normal to Tubes (cm) 68.3 72 64.8 

Condenser Design 

Exit Subcooling (°C) 0.5 0.5 0.0 

Heat Transfer Type (Static, Hot-wall, Tube 

& Fin, Microchannel) Static Hot-wall Hot-wall 

Static Condenser Details 

Fin Type Wire NA NA

 Tube OD (mm) 6.0 NA NA

 Tube Wall Thickness (mm) 0.64 NA NA

 Number of Tube Rows 14 NA NA

 Tube Pitch (mm) 4.6 NA NA

 Width of Tube Row (cm) 47.0 NA NA

 Wire OD (mm) 1.4 NA NA

 Wire Length (cm) 64.5 NA NA

 # of Wires 110 NA NA

 Wire Conductivity (W/m-K) 44.7 NA NA 

Hot Wall Condenser Details 

 Total Area of Side Panels (m2) NA 1.5 1.72

 Width of Side Normal to Tubes (cm) NA 53.3 241

 Number of Legs NA 7 32

 Length of Tubing on Wall (m) NA 20.2 19.6

 Tube OD (mm) NA 4.6 3.9

 Tube Wall Thickness (mm) NA 0.6 0.5

 Liner Thickness (mm) NA 0.64 0.9

 Thermal Conductivity (W/mK) NA 44.7 44.7 

5-A-27
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Compact Chest Freezers 3.4 ft3 7.0 ft3, #1 7.0 ft3, #2 

Compressor Data 

Manufacturer Jiangsu Baixuep Danfoss ZEL

 Model # QDH3511G TTE4.6GFK GVY44AD

 Cycles per Hour 2.25 1.3 2.0 

Interchanger 

Effectiveness (0-1) 0.95 0.95 0.95 

p

 Jiangsu Baixue Electric Appliances Co. Ltd. 

5-A-28 

EERE-2008-BT-STD-0012 COMMENT 22
5-A.3 INCREMENTAL COST DETAIL 

The tables in this section identify the groups of design options and their associated costs 

for all analyzed efficiency levels for the reverse-engineering units for which the full incremental 

cost analysis was conducted. 

5-A-29
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.1: Incremental Cost Detail for 16 ft3 Top-Mount Refrigerator-Freezer (Product Class 3) 

Efficiency 

Level 

Design Options Added Design Option Costs 

Material Labor Overhead Depreciation G&A, Profit Total 

10% 

Increase compressor EER from 5.55 to 5.74 $1.43 $0.00 $0.00 $0.00 $0.37 $1.80 

Brushless DC Condenser Fan Motor $3.75 $0.00 $0.00 $0.00 $0.98 $4.73 

Increase Evaporator Size by 20% $1.20 $0.00 $0.00 $0.00 $0.31 $1.51 

15% Increase Condenser Size by 20% $1.69 $0.00 $0.00 $0.00 $0.44 $2.13 

Increase compressor EER from 5.74 to 5.85 $0.83 $0.00 $0.00 $0.00 $0.21 $1.04 

20% Increase compressor EER from 5.85 to 6.26 $8.15 $0.00 $0.00 $0.00 $2.12 $10.26 

25% Adaptive Defrost $8.00 $0.00 $0.00 $0.00 $2.08 $10.08 

3.5 sqft VIP in FZR Cabinet $11.49 $1.20 $1.48 $3.68 $17.86 

30% 8.7 sqft more VIP in FZR Cabinet $28.43 $2.97 $3.67 $9.12 $44.19 

35% 6.9 sqft VIP in FF Cabinet $22.62 $1.22 $2.79 $6.92 $33.55 

40% 8.4 sqft more VIP in FF Cabinet $27.34 $1.47 $3.37 $8.37 $40.55 

45% 8.4 sqft more VIP in FF Cabinet $27.34 $1.47 $3.37 $8.37 $40.55 

5-A-30
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.2: Incremental Cost Detail for 21 ft3 Top-Mount Refrigerator-Freezer (Product Class 3) 

Efficiency 

Level 

Design Options Added Design Option Costs 

Material Labor Overhead Depreciation G&A, Profit Total 

10% Increase compressor EER from 4.92 to 5.55 $0.37 $0.00 $0.00 $0.00 $0.10 $0.47 

15% Increase compressor EER from 5.55 to 5.94 $2.93 $0.00 $0.00 $0.00 $0.76 $3.69 

Increase compressor EER from 5.94 to 6.08 $2.61 $0.00 $0.00 $0.00 $0.68 $3.29 

20% Increase Evaporator Size by 

20% $1.61 $0.00 $0.00 $0.00 $0.42 $2.03 

Increase Condenser Size by 20% $1.45 $0.00 $0.00 $0.00 $0.38 $1.83 

25% 

Brushless DC Evaporator Fan Motor $3.50 $0.00 $0.00 $0.00 $0.91 $4.41 

Brushless DC Condenser Fan Motor $3.75 $0.00 $0.00 $0.00 $0.98 $4.73 

30% Adaptive Defrost $8.00 $0.00 $0.00 $0.00 $2.08 $10.08 

35% 10.5 sqft VIP in FF Cabinet $34.22 $1.42 $4.17 $10.35 $50.16 

40% 13.4 sqft more VIP in FF Cabinet $43.68 $1.82 $5.32 $13.21 $64.03 

45% 6.8 sqft more VIP in FF Cabinet $22.26 $0.93 $2.71 $6.73 $32.63 

6.2 sqft VIP in FZR Cabinet $20.21 $1.60 $2.55 $6.33 $30.70 

5-A-31
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.3: Incremental Cost Detail for 18.5 ft3 Bottom-Mount Refrigerator-Freezer (Product Class 5) 

Efficiency 

Level 

Design Options Added Design Option Costs 

Material Labor Overhead Depreciation G&A, Profit Total 

10% 

Increase compressor EER from 5.72 to 6.06 $3.72 $0.00 $0.00 $0.00 $0.97 $4.69 

Increase Evaporator Size by 20% $2.00 $0.00 $0.00 $0.00 $0.52 $2.52 

15% 

Brushless DC Evaporator Fan Motor $3.50 $0.00 $0.00 $0.00 $0.91 $4.41 

Brushless DC Condenser Fan Motor $3.75 $0.00 $0.00 $0.00 $0.98 $4.73 

20% Adaptive Defrost $8.00 $0.00 $0.00 $0.00 $2.08 $10.08 

25% 

Increase compressor efficiency from 6.06 to 6.26 $5.40 $0.00 $0.00 $0.00 $1.40 $6.80 

Increase Condenser Size by 20% $2.00 $0.00 $0.00 $0.00 $0.52 $2.52 

30% 

Variable Anti-Sweat Heater Control $17.48 $0.00 $0.00 $0.00 $4.54 $22.02 

35% 12.6 sqft VIP in FF Cabinet $41.09 $2.12 $5.06 $12.55 $60.82 

40% 

12.1 sqft more VIP in FF Cabinet $39.59 $2.04 $4.87 $12.09 $58.60 

45% 

13.3 sqft more VIP in FZR Cabinet $43.44 $3.00 $5.43 $13.49 $65.37 

5-A-32
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.4: Incremental Cost Detail for 25 ft3 Bottom-Mount Refrigerator-Freezer (Product Class 5) 

Efficiency 

Level 

Design Options Added Design Option Costs 

Material Labor Overhead Depreciation G&A, Profit Total 

10% 

Increase compressor EER from 4.79 to 5.42 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 

15% 

Increase compressor EER from 5.42 to 5.74 $1.80 $0.00 $0.00 $0.00 $0.47 $2.27 

20% 

Increase compressor EER from 5.74 to 6.14 $5.73 $0.00 $0.00 $0.00 $1.49 $7.22 

Increase compressor EER from 6.14 to 6.26 $3.24 $0.00 $0.00 $0.00 $0.84 $4.08 

25% 

Brushless DC Evaporator Fan Motor $3.50 $0.00 $0.00 $0.00 $0.91 $4.41 

Variable Anti-Sweat Heater Control $9.48 $0.00 $0.00 $0.00 $2.46 $11.94 

Increase Condenser Size by 20% $4.90 $0.00 $0.00 $0.00 $1.27 $6.17 

30% Brushless DC Condenser Fan 

Motor $3.75 $0.00 $0.00 $0.00 $0.98 $4.73 

35% 

Increase Evaporator Size by 20% $2.60 $0.00 $0.00 $0.00 $0.68 $3.27 

13.2 sqft VIP in FF Cabinet $42.98 $1.86 $5.25 $13.02 $63.11 

40% 

16.3 sqft more VIP in FF Cabinet $53.24 $2.31 $6.50 $16.13 $78.18 

45% 14.1 sqft VIP in FZR Cabinet $46.03 $2.83 $5.72 $14.19 $68.77 

5-A-33
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.5: Incremental Cost Detail for 22 ft3 Side-Mount Refrigerator-Freezer with TTD Ice (Product 

Efficiency 

Level 

Design Options Added Design Option Costs 

Material Labor Overhead Depreciation G&A, Profit Total 

10% 

Increase compressor EER from 5.51 to 5.89 $2.85 $0.00 $0.00 $0.00 $0.74 $3.59 

Brushless DC Condenser Fan Motor $3.75 $0.00 $0.00 $0.00 $0.98 $4.73 Increase Evaporator Size by 20% $1.27 $0.00 $0.00 $0.00 $0.33 $1.60 

15% 

Increase compressor EER from 5.89 to 6.26 $7.85 $0.00 $0.00 $0.00 $2.04 $9.88 

Increase Condenser Size by 20% $2.89 $0.00 $0.00 $0.00 $0.75 $3.65 

20% 11 sqft VIP in FF Cabinet $35.92 $1.77 $4.4.1 $10.95 $53.05 

25% 13 sqft more VIP in FF Cabinet $42.58 $2.10 $5.23 $12.98 $62.89 30% 1.8 sqft more VIP in FF Cabinet $5.85 $0.29 $0.72 $1.78 $8.64 

11.3 sqft VIP in FZR Cabinet $36.90 $2.30 $4.59 $11.38 $55.17 

35% 

9.2 sqft more VIP in FZR Cabinet $30.01 $1.87 $3.73 $9.26 $44.86 

3.4 sqft VIP in FZR Door $10.97 $0.27 $1.32 $3.27 $15.82 

40% 

1.8 sqft more VIP in FZR Door $5.75 $0.14 $0.69 $1.71 $8.29 

8 sqft VIP in FF Door $26.28 $0.42 $3.12 $7.75 $37.75 

Variable Speed Compressor $39.31 $0.00 $0.00 $0.00 $10.22 $49.52 

5-A-34
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.6: Incremental Cost Detail for 26 ft3 Side-Mount Refrigerator-Freezer with TTD Ice (Product 

Efficiency 

Level 

Design Options Added Design Option Costs 

Material Labor Overhead Depreciation G&A, Profit Total 

10% 

Increase compressor EER from 5.58 to 5.93 $2.63 $0.00 $0.00 $0.00 $0.68 $3.31 

Brushless DC Evaporator Fan Motor $3.50 $0.00 $0.00 $0.00 $0.91 $4.41 Brushless DC Condenser Fan Motor $3.75 $0.00 $0.00 $0.00 $0.98 $4.73 

15% Increase compressor EER from 5.93 to 6.04 $1.61 $0.00 $0.00 $0.00 $0.42 $2.02 20% 

Increase compressor EER from 6.04 to 6.26 $5.94 $0.00 $0.00 $0.00 $1.54 $7.48 

Adaptive Defrost $8.00 $0.00 $0.00 $0.00 $2.08 $10.08 

25% 

Increase Evaporator Size by 20% $1.16 $0.00 $0.00 $0.00 $0.30 $1.46 

Increase Condenser Size by 20% $2.42 $0.00 $0.00 $0.00 $0.63 $3.05 

7.5 sqft VIP in FF Cabinet $24.47 $1.16 $3.00 $7.44 $36.08 

30% 12.2 sqft more VIP in FF Cabinet $39.86 $1.89 $4.88 $12.13 $58.76 

35% 7.2 sqft more VIP in FF Cabinet $23.44 $1.11 $2.87 $7.13 $34.56 

5.8 sqft VIP in FZR Cabinet $18.93 $1.04 $2.34 $5.80 $28.10 

40% 14.1 sqft VIP in FZR Cabinet $45.96 $2.53 $5.67 $14.08 $68.23 45% 

3.3 sqft more VIP in FZR Cabinet $10.91 $0.60 $1.35 $3.34 $16.20 

6.2 sqft VIP in FZR Door $20.14 $0.42 $2.41 $5.97 $28.93 

8.0 sqft VIP in FF Door $26.65 $0.42 $3.17 $7.86 $38.09 

5-A-35
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.7: Incremental Cost Detail for 14 ft3 Upright Freezer with Auto Defrost (Product Class 9) 

Efficiency 

Level 

Design Options Added Design Option Costs 

Material Labor Overhead Depreciation G&A, Profit Total 

10% 

Brushless DC Evaporator Fan Motor $3.50 $0.00 $0.00 $0.00 $0.91 $4.41 

Add 1" Insulation to Door $0.65 $0.00 $0.00 $0.91 $0.41 $1.97 

15% Increase Compressor EER from 5.04 to 5.43 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 20% Increase Compressor EER from 5.43 to 5.95 $3.38 $0.00 $0.00 $0.00 $0.88 $4.25 

Increase Compressor EER from 5.95 to 6.08 $2.54 $0.00 $0.00 $0.00 $0.66 $3.19 

25% 

Increase Evaporator Size by 20% $1.47 $0.00 $0.00 $0.00 $0.38 $1.85 

Convert condenser to forced convection with BLDC fan motor 

$6.75 $0.00 $0.00 $0.00 $1.76 $8.51 

Adaptive Defrost $8.00 $0.00 $0.00 $0.00 $2.08 $10.08 

30% Add 0.36" Insulation to Cabinet $4.54 $0.00 $0.00 $17.35 $5.69 $27.58 

35% 

Add another 0.64" Insulation to Cabinet $7.87 $0.00 $0.00 $0.00 $2.05 $9.91 

3.7 sqft VIP in Cabinet $12.05 $0.41 $1.77 $3.70 $17.93 

40% 17.6 sqft more VIP in Cabinet $57.37 $1.94 $8.42 $17.61 $85.35 

45% 16.4 sqft more VIP in Cabinet $53.75 $1.82 $7.89 $16.50 $79.95 0.8 sqft VIP in Door $2.70 $0.03 $0.39 $0.81 $3.94 

5-A-36
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.8: Incremental Cost Detail for 20 ft3 Upright Freezer with Auto Defrost (Product Class 9) 

Efficiency 

Level 

Design Options Added Design Option Costs 

Material Labor Overhead Depreciation G&A, Profit Total 

10% 

Brushless DC Evaporator Fan Motor $3.50 $0.00 $0.00 $0.00 $0.91 $4.41 

Add 1" Insulation to Door $0.69 $0.00 $0.00 $0.91 $0.42 $2.02 

15% Adaptive Defrost $8.00 $0.00 $0.00 $0.00 $2.08 $10.08 

20% N/A $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 25% 

Increase compressor EER from 5.73 to 6.00 $2.03 $0.00 $0.00 $0.00 $0.53 $2.55 

Increase Evaporator Size by 20% $1.34 $0.00 $0.00 $0.00 $0.35 $1.69 Increase compressor EER from 6.01 to 6.24 $6.21 $0.00 $0.00 $0.00 $1.61 $7.82 

30% 

Increase Evaporator Size by Additional 30% $2.01 $0.00 $0.00 $0.00 $0.52 $2.53 

Increase Door Insulation Thickness 1/4" $0.17 $0.00 $0.00 $0.00 $0.04 $0.22 Remove 1/4" Door Insulation -$0.17 $0.00 $0.00 $0.00 -$0.04 -$0.22 

35% 

Forced Convection Condenser with BLDC Cond Fan $6.75 $0.00 $0.00 $0.00 $1.76 $8.51 

Add 0.15" Insulation to Cabinet $1.97 $0.00 $0.00 $17.35 $5.02 $24.34 

40% Add Additional 0.55" Insulation to Cabinet $7.26 $0.00 $0.00 $0.00 $1.89 $9.15 45% 

11.7 sqft VIP in FZR Cabinet $38.31 $1.06 $5.59 $11.69 $56.65 

Add Additional 0.3" Insulation to Cabinet $3.88 $0.00 $0.00 $0.00 $1.01 $4.89 

5-A-37
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.9: Incremental Cost Detail for 15 ft3 Chest Freezer (Product Class 10) 

Efficiency 

Level 

Design Options Added Design Option Costs 

Material Labor Overhead Depreciation G&A, Profit Total 

10% Increase compressor EER from 4.92 to 5.48 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 15% Increase compressor EER from 5.48 to 5.81 $2.33 $0.00 $0.00 $0.00 $0.60 $2.93 20% 

Increase compressor EER from 5.81 to 6.08 $3.59 $0.00 $0.00 $0.00 $0.93 $4.52 

Add 0.5" Insulation to Door $0.24 $0.00 $0.91 $0.00 $0.30 $1.45 

25% 

Add another 0.5" Insulation to Door $0.23 $0.00 $0.00 $0.00 $0.06 $0.29 

Increase Condenser Size by 45% $3.48 $0.00 $0.00 $0.00 $0.90 $4.38 

30% 

Increase Evaporator Size by 30% $3.11 $0.00 $0.00 $0.00 $0.81 $3.91 

Add another 0.5" Insulation to Door $0.24 $0.00 $0.00 $0.00 $0.06 $0.30 

35% 

Remove 0.5" Insulation from Door -$0.24 $0.00 $0.00 $0.00 -$0.06 -$0.30 

Add 0.5" Insulation to Cabinet $4.54 $0.00 $0.00 $17.35 $5.69 $27.58 

40% Add another 0.5" Insulation to Cabinet $4.40 $0.00 $0.00 $0.00 $1.14 $5.54 45% Variable Speed Compressor $44.09 $0.00 $0.00 $0.00 $11.46 $55.55 

5-A-38
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.10: Incremental Cost Detail for 20 ft3 Chest Freezer (Product Class 10) 

Efficiency 

Level 

Design Options Added Design Option Costs 

Material Labor Overhead Depreciation G&A, Profit Total 

Increase Condenser Size by 29% $1.68 $0.00 $0.00 $0.00 $0.44 $2.12 

10% 

Add 1" Insulation to Door $0.62 $0.00 $0.00 $0.91 $0.40 $1.93 Increase compressor EER from 

5.71 to 5.78 $0.53 $0.00 $0.00 $0.00 $0.14 $0.66 

15% Increase compressor EER from 5.78 to 6.07 $3.54 $0.00 $0.00 $0.00 $0.92 $4.46 20% 

Increase compressor EER from 6.07 to 6.25 $4.86 $0.00 $0.00 $0.00 $1.26 $6.12 

Add 0.14 in Insulation to Cabinet $1.67 $0.00 $0.00 $17.35 $4.95 $23.97 

25% Add another 0.38 in Insulation to Cabinet $4.52 $0.00 $0.00 $0.00 $1.17 $5.69 30% Add another 0.48 in Insulation to Cabinet $5.50 $0.00 $0.00 $0.00 $1.43 $6.94 35% Variable Speed Compressor $41.08 $0.00 $0.00 $0.00 $10.68 $51.75 

40% N/A $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 45% 10.2 sqft VIP in Bottom Wall $33.46 $1.39 $4.95 $10.35 $50.14 

2.9 sqft VIP in Door $9.53 $0.10 $1.37 $2.86 $13.86 

5-A-39
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.11: Incremental Cost Detail for 1.7 ft3 Compact Refrigerator (Product Class 11) 

Efficiency 

Level 

Design Options Added Design Option Costs 

Material Labor Overhead Depreciation G&A, Profit Total 

Increase evaporator size by 20% $0.27 $0.00 $0.00 $0.00 $0.07 $0.34 

Increase condenser size by 20% $0.39 $0.00 $0.00 $0.00 $0.10 $0.49 

10% Add 0.75" Insulation to Door $0.13 $0.00 $0.00 $0.45 $0.15 $0.72 

Increase compressor EER from 3.02 to 3.09 $0.70 $0.00 $0.00 $0.00 $0.18 $0.88 

15% Increase compressor EER from 3.09 to 3.27 $1.80 $0.00 $0.00 $0.00 $0.47 $2.27 20% Increase compressor EER from 3.27 to 3.46 $1.90 $0.00 $0.00 $0.00 $0.49 $2.39 25% 

Increase compressor EER from 3.46 to 3.47 $0.10 $0.00 $0.00 $0.03 $0.13 

Add 0.23" Insulation to Cabinet $0.72 $0.00 $0.00 $8.53 $2.40 $11.65 

30% Add 0.31" Insulation to Cabinet $0.98 $0.00 $0.00 $0.00 $0.25 $1.23 

35% Add 0.21" Insulation to Cabinet $0.68 $0.00 $0.00 $0.00 $0.18 $0.85 

Add 1.6 sqft VIP in Door $5.15 $0.29 $1.07 $1.69 $8.20 

40% 

Add Another 0.7 sqft VIP in Door $2.14 $0.12 $0.44 $0.70 $3.40 

Add 2.3 sqft VIP in Cabinet $7.53 $1.02 $1.68 $2.66 $12.89 

45% Add Another 2.9 sqft VIP in Cabinet $9.38 $1.27 $2.09 $3.31 $16.06 

5-A-40
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.12: Incremental Cost Detail for 4.0 ft3 Compact Refrigerator (Product Class 11) 

Efficiency 

Level 

Design Options Added Design Option Costs 

Material Labor Overhead Depreciation G&A, Profit Total 

Add 0.75" Insulation to Door $0.15 $0.00 $0.00 $0.45 $0.16 $0.75 

10% Increase compressor EER from 

4.57 to 4.85 $2.80 $0.00 $0.00 $0.00 $0.73 $3.53 

15% Increase compressor EER from 4.85 to 5.14 $2.90 $0.00 $0.00 $0.00 $0.75 $3.65 20% 

Increase compressor EER from 5.14 to 5.33 $1.90 $0.00 $0.00 $0.00 $0.49 $2.39 

Increase Condenser Size by 8% $0.22 $0.00 $0.00 $0.00 $0.06 $0.28 

25% 

Increase Condenser Size to 20% more than initial size $0.32 $0.00 $0.00 $0.00 $0.08 $0.40 

Add 0.10" Insulation to Cabinet $0.39 $0.00 $0.00 $8.53 $2.32 $11.23 

30% Add another 0.19" Insulation to Cabinet $0.72 $0.00 $0.00 $0.00 $0.19 $0.91 35% Add another 0.26" Insulation to Cabinet $0.99 $0.00 $0.00 $0.00 $0.26 $1.24 40% 

Add another 0.20" Insulation to Cabinet $0.74 $0.00 $0.00 $0.00 $0.19 $0.93 

Add 1.4 sqft VIP in Cabinet $4.71 $0.42 $1.01 $1.60 $7.73 

45% Add Another 3.8 sqft VIP in Cabinet $12.46 $1.10 $2.66 $4.22 $20.44 

5-A-41
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.13: Incremental Cost Detail for 3.4 ft3 Compact Chest Freezer (Product Class 18) 

Efficiency 

Level 

Design Options Added Design Option Costs 

Material Labor Overhead Depreciation G&A, Profit Total 

10% Increase compressor EER from 3.74 to 4.17 $4.30 $0.00 $0.00 $0.00 $1.12 $5.42 

15% 

Increase compressor EER from 4.17 to 4.29 $1.23 $0.00 $0.00 $0.00 $0.32 $1.55 

Add 1" Insulation to Door $0.20 $0.00 $0.00 $0.91 $0.29 $1.41 

20% 

Remove 1/4" Insulation from Door -$0.05 $0.00 $0.00 $0.00 -$0.01 -$0.06 

Add 0.48" Insulation to Cabinet $1.88 $0.00 $0.00 $17.35 $5.00 $24.23 

25% 

Add another 0.27" Insulation to Cabinet $1.03 $0.00 $0.00 $0.00 $0.27 $1.30 

2.1 sqft VIP in Bottom Wall $6.85 $1.39 $1.62 $2.56 $12.42 

Add 1/4" Insulation to Door $0.05 $0.00 $0.00 $0.00 $0.01 $0.06 

30% 

Remove all design options through 25% Level -$15.50 -$1.39 -$19.88 -$9.56 -$46.33 

Variable Speed Compressor $50.00 $0.00 $0.00 $0.00 $13.00 

35% N/A $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 

40% N/A $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 

Add 0.75" Insulation to Door $0.15 $0.00 $0.00 $0.91 $0.28 $1.34 

45% Add 0.21" Insulation to 

Cabinet $0.83 $0.00 $0.00 $17.35 $4.73 $22.91 

5-A-42
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 5-A.3.14: Incremental Cost Detail for 7.0 ft3 Compact Chest Freezer (Product Class 18) 

Efficiency 

Level 

Design Options Added Design Option Costs 

Material Labor Overhead Depreciation G&A, Profit Total 

10% Increase compressor EER from 4.50 to 5.03 $5.30 $0.00 $0.00 $0.00 $1.38 $6.68 15% 

Increase compressor EER from 5.03 to 5.27 $2.40 $0.00 $0.00 $0.00 $0.62 $3.02 

Add 0.15" Insulation to Door $0.06 $0.00 $0.00 $0.91 $0.25 $1.23 

20% Add 0.60" Insulation to Door $0.25 $0.00 $0.00 $0.00 $0.07 $0.32 

Add 0.24" Insulation to Cabinet $1.92 $0.00 $0.00 $17.35 $5.01 $24.28 

25% Add another 0.34" Insulation to Cabinet $2.68 $0.00 $0.00 $0.00 $0.70 $3.38 30% 

Add another 0.17" Insulation to Cabinet $1.36 $0.00 $0.00 $0.00 $0.35 $1.71 

Add 3.1 sqft VIP in Bottom Wall $10.09 $1.04 $2.18 $3.46 $16.77 

35% 

Remove all design options through 30% Level -$24.06 -$1.04 -$20.44 -$11.84 -$57.38 

Variable Speed Compressor $50.00 $0.00 $0.00 $0.00 $13.00 $63.00 

40% Add 0.26" Insulation to Cabinet $2.05 $0.00 $0.00 $17.35 $5.04 $24.43 

45% Add another 0.47" Insulation to Cabinet $3.74 $0.00 $0.00 $0.00 $0.97 $4.71 

5-A-43
 

EERE-2008-BT-STD-0012 COMMENT 22
5-A.4 ENGINEERING QUESTIONNAIRE 

The engineering questionnaire used as a guide for engineering discussions during 

manufacturer interviews is shown in this section. Some of the information provided in the 

questionnaire has been redacted to protect vendor information. 

5-A-44
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

 

 

DESIGN FOR ENERGY IMPROVEMENT INFORMATION REQUEST 

DOE would like to confirm information on the incremental costs of increasing product efficiency 

by understanding the design options involved in the efficiency improvement. 

1. Market Share of products you sell 

To help DOE discover manufacturer sub-groups and the relative importance of various product 

classes to specific manufacturers, please disaggregate your annual unit shipments for each 

product category as shown below. Please also indicate whether you purchase these products 

from other manufacturers (i.e. private label), and whether the factory that supplies the product 

is located in the USA. 

Product Class (response for PC1 through PC20 not 

including built-in products) 

% Private 

Label? 

% Made 

in USA? 

Yearly Unit 

Shipments 

1. Refrigerators and refrigerator-freezers with 

manual defrost. 

2. Refrigerator-freezer—partial automatic defrost. 

3a. Refrigerator-freezer—automatic defrost with topmounted freezer without through-the-door ice 

service 

3b. All-refrigerator—automatic defrost. 

4. Refrigerator-freezers—automatic defrost with 

side-mounted freezer without through-the-door 

ice service. 

5. Refrigerator-freezers—automatic defrost with 

bottom-mounted freezer without through-the-door 

ice service. 

6. Refrigerator-freezers—automatic defrost with 

top-mounted freezer with through-the-door ice 

service. 

7. Refrigerator-freezers—automatic defrost with 

side-mounted freezer with through-the-door ice 

service. 

8. Upright freezers with manual defrost. 

9. Upright freezers with automatic defrost. 

10. Chest freezers and all other freezers except 

compact freezers. 

11. Compact refrigerators and refrigerator-freezers 

with manual defrost. 

12. Compact refrigerator-freezer—partial automatic 

defrost. 

13a. Compact refrigerator-freezers—automatic 

defrost with top-mounted freezer compact all5-A-45
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

refrigerator—automatic defrost. 

13b. Compact all-refrigerator—automatic defrost. 

14. Compact refrigerator-freezers—automatic defrost 

with side-mounted freezer. 

15. Compact refrigerator-freezers—automatic defrost 

with bottom-mounted freezer. 

16. Compact upright freezers with manual defrost. 

17. Compact upright freezers with automatic defrost. 

18. Compact chest freezers. 

19. Refrigerator-freezer—automatic defrost with 

bottom-mounted freezer with through-the-door 

ice service. 

20. Chest freezers with automatic defrost. 

21. Wine Coolers 

22. Built-in Refrigerators, Refrigerator-Freezers, and 

Freezers 

(please provide percentage breakdown by Product 

Class for units presenting at least 5% of unit 

sales) 

a.	 What percentage of products classified as product class 4 or 7 (side-by-sides) have convertible 

bottom drawers? 

b.	 What percentage of product class 5 and what percentage of product class 19 products are 

French-door?
 

2. Product Technical Descriptions 

The following series of exhibits and questions address technical characteristics of key 

refrigerator and freezer components for both baseline and improved-efficiency products. 

Compressors 

Please comment on the typical capacities of compressors used in the indicated products. 

5-A-46
 

EERE-2008-BT-STD-0012 COMMENT 22
 

•	 Should there be differences in capacity levels for auto-defrost and manual defrost freezers? 

•	 What capacity/volume relationship is representative for standard-sized manual-defrost 

refrigerators? 

Please comment on the indicated typical EER of compressors used in standard and Energy Star 

products. 

•	 Should there be differences between compressor EER used in auto-defrost and manual defrost 

freezers? 

Typical EER trend for compressors used in compact refrigerators and freezers: 

5-A-47
 

EERE-2008-BT-STD-0012 COMMENT 22
•	 Is variation in compressor EER in compact products dependent primarily on capacity, as 

illustrated in the line in the plot below? 

•	 Note that while a range of EER is offered by compressor vendors, it is not clear that the range of 

EER’s actually being used in products is as broad--Is this driven by cost pressures for compact 

products? 

5-A-48
 

EERE-2008-BT-STD-0012 COMMENT 22
Is the Illustrated Typical Cost vs. Capacity for Baseline Product compressors accurate? 

Is the Illustrated Curve for incremental cost for higher EER compressors for standard-sized 

refrigerator-freezers accurate? 

5-A-49
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

•	 What percentage of your baseline unit shipments use variable-speed compressors, and what 

percentage of Energy Star-rated products do? 

•	 If you use variable-speed compressors in your products, do you run them at two or three 

speeds, or do you modulate the speed based on demand? 

•	 Is $30 an appropriate cost increase for a variable-speed compressor as compared to a baseline 

efficiency single-speed compressor purchased from the vendor for standard-sized 

refrigerator-freezers? What other costs need to be considered? 

Evaporator Heat Exchanger Characteristics 

In the following table, please comment on the typical key details of evaporator heat exchangers. 

Product Type Type Core 

Volume 

(cuft) 

Tube 

Outer Dia 

(inch) 

Tube 

Length 

(ft) 

Fin Surface 

or cold 

plate 

surface 

(sqft) 

Standard-Sized 

RefrigeratorFreezers 

Forced 

Convection 

0.21 0.33 

(0.008 wall) 

37 18 

Standard-Sized 

Upright Freezers 

Forced 

Convection 

0.18 0.33 

(0.008 wall) 

32 18 

Product Type Type Tube 

Outer Dia 

(inch) 

Specific 

Tube 

Length 

(inch per 

Btu/hr 

compressor 

capacity) 

Fin Surface 

(sqin per 

Btu/hr 

compressor 

capacity) 

Standard-Sized 

Chest Freezers 

Cold Wall 0.3 1.7 

Compact Basic 

Refrigerators 

Roll Bond Channels 

0.18 high 

x 0.38 

wide 

0.55 0.6 

Compact Chest 

Freezers 

Cold Wall 0.3 2.0 

•	 All forced-convention evaporators use aluminum tubes? 

•	 Typical forced-convection evaporator fin style is flat aluminum with oval gaps to slide over 

tube serpentine? 

•	 Any use of internally-enhanced tubes? 

•	 Any use of enhanced fins? 

•	 What percentage of refrigerator/freezers use more than one evaporator? 

•	 What percentage of refrigerator/freezers use other than forced-convection evaporators? 

•	 Do you employ wide fin spacing and lack of fin surface enhancements for frost tolerance and 

quick melt runoff? 

5-A-50
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

•	 Is there a typical evaporator air flow rate vs. compressor capacity relationship? If so, can you 

detail it? 

•	 Are you aware of any further significant system improvements that may be possible through 

evaporator heat exchanger changes? (for example, via eggcrate evaporators, spine-fin?) 

•	 If you use spine-fin heat exchangers, is their performance for volume/fan power better than 

for flat-fin heat exchangers? Or was your decision driven by cost? What about frost 

tolerance and internal enhancements? 

Condenser Heat Exchanger Characteristics 

In the following table, please comment on the typical key details of evaporator heat exchangers. 

Product Type Type Tube 

Outer 

Dia 

(inch) 

Tube 

Length 

(ft) 

Wire Fin 

Diameter 

(inch) 

Wire Fin 

Total Length 

(ft) 

Standard-Sized 

RefrigeratorFreezers 

Forced 

Convection 

Steel Tube 

Wire Fin 

0.19 

(0.025 

wall) 

50 0.05 300 

Product Type Type Tube 

Outer 

Dia 

(inch) 

Tube 

Wall 

(inch) 

Specific 

Tube Length 

(inch per 

Btu/hr 

compressor 

capacity) 

Specific Wire 

Fin Length 

(foot per 

Btu/hr 

compressor 

capacity) 

Standard-Sized 

Upright Freezers 

Hot Wall 0.19 0.03 1.0 N/A 

Standard-Sized 

Chest Freezers 

Hot Wall 0.19 0.03 1.3 N/A 

Compact Basic 

Refrigerators 

Static or 

Hot Wall 

0.19 0.025 Hot Wall 1.5 

Static 0.4 

0.4 

Compact Chest 

Freezers 

Hot Wall 

or Static 

0.19 0.025 Hot Wall 1.7 

Static 0.9 

0.7 

•	 Any use of internally-enhanced tubes? 

•	 Most external condenser heat exchangers designs appear to be based on steel wire fins. What 

are the key drivers leading to this design choice? 

o	 Is in-field dust-covered performance a consideration? 

o	 Are enhanced-surface designs too expensive? 

o	 Or perhaps not worthwhile because there is enough space for lower-cost wire fin 

design? 

o	 Performance degradation when dirty? 

o	 Or can’t do better than wire fin for a given volume and the typically low fan power? 

•	 Is there a relationship between typical condenser air flow rate vs. the compressor capacity? If 

so, can you detail it? 

5-A-51
 

EERE-2008-BT-STD-0012 COMMENT 22
•	 During teardowns we noted that some manufacturers use “rolled up” heat exchangers vs. the 

typical flat external condenser heat exchangers. What are the benefits and drawbacks of such 

heat exchangers? 

Evaporator and Condenser Fans 

• Are the indicated characteristics for fan motors typical for refrigerator-freezers? 

•	 Is there any room for further, significant energy efficiency improvement via fan blade/air 

flow path design improvements (i.e. PAX fan)? 

•	 Do you consider PSC fan motors a viable intermediary step between SP and BLDC fan 

motors? 

•	 Do any of your fans run at multiple speeds, for example to match the output of a variablespeed compressor? 

•	 What are the benefits or drawbacks associated with using BLDC motors that are based on 

DC-power input vs. AC-power input? What is the cost difference between such motors? 

Cabinet Insulation Characteristics (as applicable) 

In the following table, please comment on the typical average insulation thicknesses. 

Product Type Insulation Thickess (inches) 

Standard-Sized Refrigerator-Freezers with 

Automatic Defrost—Fresh Food 

Compartment 

1.9 

Standard-Sized Refrigerator-Freezers with 

Automatic Defrost—Freezer Compartment 

2.7 

Standard-Sized Upright Freezers 2.3 

Standard-Sized Chest Freezers 2.5 

Compact Basic Refrigerators 1.2 

Compact Chest Freezers 2.5 

What typical insulation thickness would be used for the following product types? 

•	 Standard-sized refrigerator with manual or partial automatic defrost? 

•	 Compact refrigerator-freezers? 

5-A-52 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

•	 Standard-sized all-refrigerators? 

•	 Compact all-refrigerators? 

•	 Differences in typical average insulation thicknesses for built-in products? 

•	 Is the state-of-the-art current insulation system based on HFC-245fa blowing agent with 

cabinet preheating and high pressure injection? Is the conductivity typically achieved for this 

system 0.13 Btu-in/hr-ft2

-oF at room temperature? Do you use any other insulation systems? 

•	 Is there any significant further cabinet load reduction possible through lower conductivity 

foam? 

•	 Have you considered switching to low Global-Warming-Potential (GWP) blowing agents? If 

so, what are the drivers for these changes? What are the conductivity, cost impacts? 

•	 Are you using any vacuum-insulated panels (VIPs) in any products? 

•	 If you have or were considering the adoption of VIPs can you detail how you would 

incorporate them into your products, what the capital costs, and what the marginal product 

costs of such a step would be? 

•	 Have you considered gas-filled panels? If so, what drove you to adopt, or not to adopt them? 

Door Frame: 

•	 What are the key aspects of good state-of-the-art door frame/gasket area design? To what 

extent does a typical product adhere to this? What is the range of load impact of poor door 

frame region designs (i.e. in Btu/hr-ft)? 

•	 Is there any value to using double-gaskets? 

•	 Some refrigerators have extra-strong magnets requiring special handle designs to assist with 

door-opening. How much load reduction is possible with such an approach? 

Through-the-Door Dispensers: 

•	 Today’s TTD systems don’t appear to represent thermal loads as high as suggested by the 

energy allowance associated with this feature, based for example on max energy difference 

between product classes 7 and 4. Is there more to the energy impact than the thermal load 

difference? How much anti-sweat heating wattage is typically used around your TTDs? 

Anti-sweat Heaters: 

•	 Most anti-sweat heaters appear to use hot liquid. Is this correct? Is there any continued use 

of hot gas anti-sweat systems? 

•	 Is there data available indicating average duty cycle of such heaters for typical in-home 

installation? Does this depend on use of anti-sweat heater for freezer door frame, mullion 

door frame, ducts, etc.? 

•	 For example, do your products use resistance heaters within the fresh food return air duct to 

prevent frost accumulation? If so, is it always on or controlled based on humidity? 

Defrost: 

•	 What are your thoughts about benefits and drawbacks of precool prior to the defrost cycle? 

5-A-53
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

•	 The DOE energy test energy impact of defrost is small, particularly with variable defrost. Is 

this a good reflection of in-field defrost impacts? 

•	 Are dedicated controllers available to allow variable defrost to be used in products which 

otherwise use non-electronic controls? 

Expansion Devices: 

•	 Is there any performance improvement potential with expansion devices other than capillary 

tube? What about for variable-speed compressor systems? 

•	 Do you use any expansion device besides capillary tubes? 

Energy Efficiency Conversion Costs 

•	 What design changes are typically associated with converting baseline products mentioned 

above in Question 1 to Energy Star? 

•	 What are the marginal costs of the individual design options selected? 

•	 When considering energy efficiency improvements to achieve or exceed Energy Star, do 

different product classes take different pathways or are pathways similar? 

•	 Are the cost increments higher for some classes than others for a given performance 

improvement over baseline? (think 10%, 15%, 20%, 25%, 30%, 35%, 35+ improvement over 

today’s baseline) 

Thoughts/feedback on alternative refrigeration cycles/implementations: 

•	 Dual-evaporator systems attempting to cool fresh food compartment at higher evaporator 

temperatures. 

•	 Ejector system. 

•	 Stirling. 

•	 Thermoacoustic. 

•	 Thermoelectric. 

5-A-54
 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 5-B. ERA MODEL DEVELOPMENT AND WINERA USERS 

MANUAL 

TABLE OF CONTENTS 

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

5-B.2 HISTORY OF ERA MODEL................................................................................ 5-B-1 

5-B.2.1 DOE Refrigeration Appliance Efficiency Standards ............................................. 5-B-1 

5-B.2.2 Thailand Refrigeration Appliance Efficiency Standards ....................................... 5-B-2 

5-B.2.3 ERA Training Workshop in China ........................................................................ 5-B-2 

5-B.3 CHARACTERISTICS OF THE DOS VERSION OF ERA.................................. 5-B-3 

5-B.3.1 Modifications to ERA Since its Public Release..................................................... 5-B-3 

5-B.4 OBJECTIVES OF THE CURRENT PROJECT.................................................... 5-B-5 

5-B.4.1 Evaporator Analysis Program – ERAEVAP.......................................................... 5-B-6 

5-B.4.2 Condenser Analysis Program – ERACOND ......................................................... 5-B-9 

5-B.4.3 Windows Version of ERA ................................................................................... 5-B-12 

5-B-i 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 5-B. ERA MODEL DEVELOPMENT AND WINERA USERS MANUAL 

5-B.1 INTRODUCTION 

The Energy-efficient Refrigerator Analysis Program (ERA), formerly called the EPA 

Refrigerator Analysis Program, serves as an important tool in the engineering analysis, described 

in Chapter 5 of the TSD. This appendix provides background description of the evolution of the 

program since its creation in the late 1980s, provides details regarding changes made to the 

program as part of this rulemaking, and provides program operation guidance for the user. ERA 

has undergone extensive analytical upgrades and has also been converted to a Window-based 

program. The program has its own internal help utility to provide additional assistance to the user 

beyond the information provided in this appendix. 

5-B.2 HISTORY OF ERA MODEL 

ERA has seen several major improvements since its creation. This section describes the 

characteristics of the initial version of ERA and the subsequent modifications to the model prior 

to the current DOE rulemaking, including involvement in the Thailand refrigeration appliance 

efficiency standards analysis and in refrigerator energy use analysis training workshops in China 

in the 1990s. 

5-B.2.1 DOE Refrigeration Appliance Efficiency Standards 

Preparation of the current DOS version of ERA (EPA Refrigerator Analysis Program) 

was initiated under EPA-sponsorship during the late 1980s. This was undertaken by the EPA as 

part its involvement in the establishment of energy standards for refrigerators, refrigeratorfreezers, and freezers under the National Appliance Energy Conservation Act of 1987 (NAECA). 

A developmental version of the program was used by the DOE (Lawrence Berkeley Laboratory) 

as a partial basis for the energy standard established in 1989 (effective in 1993). The LBL work 

also involved an extensive testing of the model against manufacturer-supplied refrigeration 

appliance design and test data. Based on these comparisons and manufacturer review comments 

through its industry organization (AHAM), development of the model continued until its release 

in 1997 [1]. 

ERA combined an analysis of the refrigeration load requirements of the cabinet with a 

simulation of the capacity and efficiency of the refrigeration cycle. The cabinet loads module 

was a modest enhancement of a program developed for the DOE during the late 1970s [2], 

including the consideration of door-opening effects on the load and an ability to deal with 

complex insulation systems. The cycle module was a derivative of the NIST CYCLE 7 program 

[3] which used the CSD equation of state to represent the thermodynamic properties of pure and 

mixed refrigerants [4], adapting routines for calculating refrigerant properties from REFPROP3 

[5]. Using this new program, EPA carried out an extensive investigation of the potential for 

energy efficiency improvements [6]. 

5-B-1
 

EERE-2008-BT-STD-0012 COMMENT 22
 

The program, and its User’s Manual, were first released to the public in 1993, and for a few 

years were downloadable from the EPA website [7]. 

Subsequent to the 1993 final rule, DOE published updated standards for refrigerators, 

refrigerator-freezers and freezers in 1997, becoming effective in 2001. This involved use of the 

final released EPA version of ERA [1]. 

5-B.2.2 Thailand Refrigeration Appliance Efficiency Standards 

Under three separate contracts from the Thai National Energy Policy Office, a modified 

version of the program was used by the program authora

 to establish minimum efficiency 

performance standards (MEPS) for residential refrigerators and refrigerator-freezers used in 

Thailand [8, 9, 10]. The first study established goals for two categories of appliances: a one-door 

manual defrost refrigerator, and a two-door automatic-defrost refrigerator-freezer. Three levels 

of MEPS were proposed, a “long-term goal” (assumed to be achievable within 10 years, and 

tier1 and tier 2 standards which allowed 30% and 15% energy use over the long-term goal. 

As in the earlier DOE work, the local manufacturing industry was involved in the review 

and assessment of the proposed standard. 

In response to highly negative comments on the achievability of any of the proposed 

efficiency levels, a second contract was awarded to prepare and test refrigerators that would meet 

or exceed the long-term energy target. Working with Sano Electric Company of Thailand, four 

prototype units were designed and tested: 31-liter and 41.5-liter one-door refrigerators, and 78.5-

liter and 126.5-liter two-door refrigerator-freezers. Using available technology, the achieved 

energy reductions were over 20% for the one-door units, and over 34% for the two-door units, 

meeting the long-term target levels. Within several years, the proposed standards became law. 

5-B.2.3 ERA Training Workshop in China 

In response to a request from China’s State Bureau of Technical Supervision (SBTS), 

LBNL hosted a training seminar on the use of ERA for three research engineers. The results of 

this training provided an increased understanding of approaches to achieve improved standards, 

leading to a more substantial series of cost-effective cooperative efforts towards creating China’s 

standards program [11]. 

As part of a subsequent large program sponsored by the UN Global Environmental Fund (GEF), 

ThermoSoft carried out a one-week training workshop in Beijing [12]. The participants included 

40 engineers from 20 manufacturers located throughout China. Although focused on the use of 

ERA as a design tool, the workshop covered the then-current component technologies available 

a

 A consultant, established under the name ThermoSoft. This work was subcontracted through ERM-Siam. 

5-B-2
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

worldwide, providing an opportunity for a lively exchange of ideas. Each of the participants 

utilized ERA to perform analyses of their proprietary appliance models. 

5-B.3 CHARACTERISTICS OF THE DOS VERSION OF ERA 

ERA was developed employing then-current computer technology of the 1980s. The 

cabinet loads module was a minor upgrade of an earlier program used for efficiency standards, 

and an existing simplified heat pump cycle model was adapted to represent the refrigerator cycle. 

Written in FORTRAN, with a very extensive set of assembly language routines to provide a 

smooth user-interface, the program was hosted in DOS. 

Because of the complexities of the program, and the limitations of DOS, it was broken 

into three modules, linked by data files and a batch file that managed the information and 

program execution flow. Both the MENU module (which provided the user-input interface) and 

the cycle execution module used nearly all of the available 600+ Kbytes of DOS accessible 

memory.b

 This memory limitation, inherent in DOS (which can address only 655,360 bytes of 

conventional memory, 10 x 216), imposed a fundamental limitation on the design of the program 

and the details that could be considered in any analysis. 

ERA was constructed to take maximum advantage of the available capabilities provided 

by DOS, leading to somewhat complicated coding and sharing of memory spaces for certain 

functions. Because of the limitations imposed by DOS, ERA was designed to fit within the 

capabilities of a specific compiler, Microsoft FORTRAN 5.0, which was discontinued in the 

early 1990s. As a result, ERA is not compliable with any other version FORTRAN compiler. 

Further, the program requires access to the specially-developed assembly language user-interface 

module. As a consequence, although the source code has been made available upon request, no 

entity other than ThermoSoft has been able to compile it. 

Because of these restrictions, the thermophysical property routines within the DOS 

version cannot be upgraded beyond Refprop 4.0, nor can additional fluids be considered.c 

Hence, no changes to the refrigerant properties capabilities of ERA have been made since the 

mid-1990s. 

5-B.3.1 Modifications to ERA Since its Public Release 

Given the DOS-imposed restrictions, options for upgrades to the model have been limited 

within this environment. However, during on the work in Thailand, several minor enhancements 

were made: 

b

 Of course, the program executable object had to load within this space, limiting the available memory space for 

data objects. 

c

 Later versions of Refprop use a different structure. 

5-B-3
 

EERE-2008-BT-STD-0012 COMMENT 22
 

•	 Calculation of the hot-wall effective heat transfer area. This involved specification of the 

tubing routing and additional details about the wall area. The outer shell, to which the 

tubing is pressed by the expanded foam, was treated as a thermal fin to estimate the 

effective heat transfer area. This capability was used during the development of the 

prototype models in Thailand while investigating the effects of improved hot wall design 

of the energy use. 

•	 Addition of a similar analysis sub-model to calculate the effective heat transfer area for a 

cold-wall evaporator. 

•	 Added multiple-speed capability to the compressor model. The efficiency-based model, 

which was valid only for R-12, was removed to provide this capability. 

•	 Improved evaporator analysis in the single-door refrigerator to more correctly incorporate 

the radiative heat transfer effects. This led to an improvement between the model 

predictions and test results for the compact-refrigerator category. 

Although no changes to the model were made in the model’s use of compressor maps, 

experience working with Thai manufacturers highlighted the importance of high-quality 

calorimeter data.d

 As a result, each of the manufacturer-supplied maps was analyzed for 

consistency by examining the corresponding volumetric and isentropic efficiencies. An ability to 

qualify a compressor map on the basis of the underlying volumetric and isentropic efficiencies is 

built into the current revision of the model (see below). 

d

 Similar experience with poorly constructed manufacturer-supplied compressor maps was encountered during the 

EPA Multiple Pathways project [6]. 

5-B-4
 

EERE-2008-BT-STD-0012 COMMENT 22
5-B.4 OBJECTIVES OF THE CURRENT PROJECT 

A thorough revision of the ERA program, now entitled the “Energy-Efficient 

Refrigerator Analysis” program, is being undertaken for the current rulemaking to meet the 

following objectives: 

•	 Enhancement of the user-interface to a Windows environment 

•	 Employment of the most current refrigerant property routines 

•	 Incorporation of a broad range of evaporator and condenser algorithms that correspond to 

the technologies now found in modern refrigerators 

•	 Improved compressor modeling, with built-in procedures for validating supplied 

compressor maps 

•	 Improvements where desirable in the cabinet loads analysis and cycle performance 

algorithms. 

•	 Preparation of internal documentation of the program through extensive context-sensitive 

Help files. 

In addition to these objectives, support has been provided in the use of the DOS-version 

of ERA for the current standards development work. To assist this effort, a small suite of standalone programs has been prepared to calculate the required input values to ERA. This suite 

consists of: 

ERAEVAP – for the calculation of the net heat transfer capabilities of a variety of 

evaporator designs; 

ERACOND – for the calculation of the net heat transfer capabilities of a variety of 

condenser designs; and 

COMPMAP – a program to validate compressor maps by the calculation and display of 

isentropic and volumetric efficiencies, and the construction of new maps based on 

methods for smoothing the efficiencies as a function of compression ratio. 

Each of these models contains algorithms that will be incorporated into the final 

Windows version of ERA, including the refrigerant algorithms. They are stand-alone programs, 

designed only for interim use. However, since they provide a technical basis for the new version 

of ERA and have been used in the ongoing engineering analyses, they are described next. 

5-B-5
 

EERE-2008-BT-STD-0012 COMMENT 22
 

5-B.4.1 Evaporator Analysis Program – ERAEVAP 

User Interface 

ERAEVAP is a data-wizard based 

Windows program that guides the user 

through several steps in the specification 

of the evaporator design parameters. 

Step1 requires selection of the heat 

exchanger type (roll-bond freezer 

compartment, tube and fin fan-forced 

evaporator, or a chest freezer cold-wall). 

Three options are represented for a tube 

and fin configuration: plain fin, smooth 

wavy fin, and herringbone fin. 

Refrigerant choices are: R134a, R152a, R290 (propane), R404A, R507A, R600a (isobutane), and 

R744 (carbon dioxide). Refrigerant properties are calculated using the NIST Refprop 8.0 

routines, supplied as a linkable dll. 

Other typical value operating parameters are user-specified: refrigerant mass-flow, refrigerant 

saturation temperature, refrigerant inlet quality, return or cabinet air temperature, and the airflow 

rate and corresponding fan efficiency (fan-forced analyses only).e 

Step 2 depends on the heat exchanger 

configuration selected above. The 

illustration shows the input dialog for a 

tube and wavy fin design. In this 

instance, the tube dimensions, vertical 

pitch (normal to the air flow) and 

horizontal pitch (along the direction of 

the air flow) are specified. 

Each data dialog contains a simple 

illustration of the component under 

consideration. 

e

 These data must be user-defined since the program is not integrated into an overall cycle analysis. 

5-B-6
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

Step 3, in this example, presents a dialog 

that requests information on the design of 

the fin. For the example of a wavy fin, 

the requested data are: fin thickness and 

pitch, fin thermal conductivity, fraction 

of the tube row that is finned, and fin 

pattern depth. 

The number of steps required to define 

the evaporator depends on the design. 

For example, roll-bond and chest freezer 

evaporators only require two steps. 

Results displayed depend on the type of 

evaporator modeled. In the case of a tube 

and fin design, the output includes the fin 

heat transfer area and effectiveness, the 

total effective heat transfer area, air-side 

pressure drop and fan energy, and the 

refrigerant-side pressure drop. In 

addition, the display lists the overall Uvalues that are to be used as input to 

ERA. These are shown specific to the 

input requirements of the DOS version of 

ERA.f 

Roll-bond Evaporator 

ERAEVAP uses the Dittus-Bolter equation [13] to determine the heat transfer coefficients for the 

air and the vapor phase of the refrigerant. A radiative component is added on the air-side. 

Liquid phase heat transfer is calculated using the Bo Pierre correlation [14]. The overall heat 

transfer rate is dominated by the air-side resistance. Heat transfer resistance across the roll-bond 

surface is assumed to be negligible. 

The pressure drop in the evaporating heat transfer regime is calculated by marching stepwise 

downstream, calculating the local pressure gradient, and summing the local pressure drops to 

determine the total pressure drop. The local pressure drop is calculated using the LockhartMartinelli correlation [15]. 

f

 As noted earlier, the stand-alone programs are intended only as an assist towards preparing input values needed by 

DOS ERA. Hence, they are considered an interim step in the development of the final Windows version of the 

updated ERA program. 

5-B-7
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Chest Freezer Cold Wall 

Both air-side and refrigerant-side heat transfer rates are determined in the same manner as with a 

roll-bond. Calculation of the refrigerant pressure drop also uses the Lockhart-Martinelli 

correlation. 

The refrigerant tubes are pressed on the inside surface of the chest freezer liner, which because 

of its small thickness acts like a thermal fin. With adjustment made for the end tubes, each 

parallel tube is represented as having a fin of width: 

Wf = Width of plate normal to the tube / (2 * number of tubes), 

The effectiveness for this equivalent fin is: 

η = (k δ / h) 0.5 tanh [Wf * ( h / k δ) 0.5] / Wf 

For typical designs the effectiveness should be close to unity. 

Tube and Fin Evaporator 

Three fin options are modeled for the tube and fin design: plain fin, wavy fin, and herringbone 

fin. Refrigerant-side heat transfer and pressure drop are calculated in the same manner as 

described above. The air-side heat transfer rate depends on the type of fin and its design. 

Equations for representing plain fin and herringbone fin designs were based on studies by Wang 

[16]. The wavy fin configuration was represented by correlations published by Mirth and 

Ramadhyani [17].g Because the correlations are quite complex, they are not reproduced here. 

However, both references are readily available. 

The modeling and calculation approaches used in ERAEVAP will be employed in the final 

Windows version of ERA where analyses of the heat transfer and pressure drop characteristics of 

the evaporator will be built into the program. ERAEVAP will not be part of the Windows ERA 

package. 

g

 Reference [16] is a summary of many studies performed and published by Wang and his colleagues for a wide 

variety of fin configurations, including louver fins, and slit-fins. It includes a summary of the work done on wavy 

fins by Mirth and Ramadhyani, but incorrectly reproduces their correlation. 

5-B-8
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

5-B.4.2 Condenser Analysis Program – ERACOND 

Condenser Design Options 

Four generic classes of condensers are 

modeled: 1) static condenser, 2) various 

tube and fin designs, 3) microchannel 

design, and 4) a hot wall condenser. For 

each of these, the user defines the 

refrigerant mass flow rate, the saturation 

temperature, and the temperature of the 

environment (room or under-cabinet). 

The air flow rate and fan efficiency are 

also specified for the fan-forced designs. 

Static Condenser 

The static condenser model uses 

correlations developed by Bansal and 

Chin [18], who relied heavily on the 

work by Tagliafico and Tamda [19]. 

Design data include tube spacing and 

length, wire diameter, conductivity, and 

length, and the number of wires on both 

sides of the tubing. Heat transfer from 

the connecting bare tube is included in 

the analysis. 

Refrigerant-side heat transfer is calculated according to the Shah correlation [20, 21]. Pressure 

drop is calculated according to the Lockhart-Martinelli correlation, assuming for the purposes of 

analysis that 15% of the tube is in the superheated vapor phase regime, 80% in two-phase 

condensation, and 5% in the subcooled regime.h 

All of the condenser models to be described use the same approach to determining refrigerantside heat transfer and pressure drop. 

Wire Fin Condensers 

h

 This assumption will be replaced by the cycle model for the condenser in the Windows version of ERA, which will 

model the entire cycle system. 

5-B-9
 

EERE-2008-BT-STD-0012 COMMENT 22
Wire fin condensers are found in many 

domestic refrigerators. ERACOND 

provides three options for air flow across 

the unit, listed in the data dialog as along 

the W-, L- or H-directions. Since the heat 

exchanger is normally located under the 

cabinet in the compressor space, not all 

of the air flow will cross the unit. Hence, 

a required input is the fraction of the total 

air flow through the condenser. 

Calculation of the air-side heat transfer rate employs the Lee, et al correlation [22], which 

accounts for the orientation of the heat exchanger relative to the air flow. 

Tube and Extended Fins 

Calculation of the fin heat transfer uses 

the Wang correlations [16] for the plain 

fin, the herringbone fin, and the slit fin 

configurations. Representation of a wavy 

fin heat transfer uses the Mirth and 

Ramadhyani correlation [17]. 

Both sets of correlations also estimate the 

air flow pressure drop thought the fins. 

Although calculated and displayed in the 

output, they do not consider other air 

flow restrictions, and therefore represent 

low values for the fan energy. 

5-B-10
 

EERE-2008-BT-STD-0012 COMMENT 22
Hotwall Condenser 

A hotwall condenser can be modeled as a 

single wall, as in a chest freezer, or by 

multiple walls, as in an upright freezer or 

refrigerator. The heat transfer 

effectiveness of each wall is determined. 

As with the evaporator cold wall, the 

major heat flow resistance is on the airside. An overall pressure drop is 

calculated for the connected tubing using 

the Lockhart-Martinelli algorithm, with 

the Shah correlation used for the 

refrigerant condensing regime. 

Microchannel and Louver Design 

A microchannel condenser is assumed to 

use a louver-type fin. The refrigerantside design determines the refrigerant 

flow rates and corresponding heat 

transfer coefficients and pressure drop. 

Design parameters for the louver 

determine the air-side heat transfer and 

air flow pressure drop. They are 

calculated using correlations developed 

by Wang [16]. 

These same correlations, adopted by ERA, are used in the current (Mark VI) on-line version of 

the Oak Ridge heat pump model [23]. 

Compressor Model – COMPMAP 

COMPMAP is an auxiliary program to the Windows version of ERA. The program graphically 

displays the isentropic and volumetric efficiencies implied by a compressor map, as a function of 

pressure ratio, providing a visual indication of whether the map is well formed. If desired, the 

map can be rebuilt based on various options for smoothing these underlying efficiencies. 

5-B-11
 

EERE-2008-BT-STD-0012 COMMENT 22
COMPMAP may also be used to scale an 

existing map to a different COP and/or 

capacity. The program can import maps 

previously used with the DOS version of 

ERA or prepare new maps for use with 

the DOS version 

COMPMAP can be used in stand-alone 

mode or can be directly called by ERA. 

This provides a built-in tool to validate 

and prepare maps for use in a simulation. 

No assumption is made about the specific dependence of isentropic or volumetric efficiency on 

pressure ratio, other than that some correlation should exit. Using the efficiency values 

calculated for the particular map, the user is offered a choice of using the map as-is, or using a 

linear or quadratic smoothing of the efficiencies against the pressure ratio. This can be done for 

individual condenser temperatures if desired, preserving much of the original map while 

removing apparent randomness of performance as a function of the evaporator temperature. 

5-B.4.3 Windows Version of ERA 

User Interface 

ERA uses a highly-graphical interface, providing multiple options for selecting from the various 

cabinet and component choices. It is designed to guide the user carefully through the data input 

and editing process to ensure data consistency. Prior to an actual simulation of the refrigeration 

appliance performance, the user is presented a summary of the selected design variables. 

5-B-12
 

EERE-2008-BT-STD-0012 COMMENT 22
Cabinet Mode 

ERA operates in one of four view modes: 

1) cabinet design mode (shown in the 

image), 2) cycle design mode, 3) 

simulation mode, and 4) reports mode. 

Each is characterized by its own sidebar, 

containing hotspots for selecting 

component or report options. The color 

of the sidebar provides an additional 

visual clue to highlight the particular 

mode that is current. 

To define a new analysis, the user may either begin with a default set of design parameters and 

proceed through the editing process, or may read in an existing data file to be used as-is or 

edited. 

Each analysis must begin with a selection of the basic cabinet design parameters: cabinet 

category (shown on the desktop) and the overall dimensions of the unit. Once these basic choices 

have been made, the remaining categories of cabinet design data may be specified in any order. 

Data wizards, similar to those illustrated above for the stand-alone programs, guide the user at 

each stage. 

As each category of data is processed, a check mark is drawn on the sidebar to indicate the 

completeness of the editing progress. 

In some instances, special-function dialogs may be 

summoned to assist in the preparation of an input value. 

For example, the image to the right shows a dialog used to 

calculate the effective resistivity of a cabinet wall that 

contains a vacuum panel or some equivalent high thermal 

resistance element. 

5-B-13
 

EERE-2008-BT-STD-0012 COMMENT 22
Cycle Mode 

Once the basic cabinet type has been 

selected, the user may specify the cycle 

parameters. This would begin with a 

selection of the basic cycle type (single 

evaporator, dual loop, dual evaporator, or 

Lorenz cycle). Once this choice has been 

made, a simple schematic of the chosen 

cycle category is displayed on the 

desktop. The user may then continue to 

define the cycle parameters by clicking 

on the desktop to select the component of 

interest, or may use the sidebar or the 

the drop-down menu to select the next component to be defined. 

The displayed desktop image and its associated hotspots depend on the specific cycle category 

selected. 

Simulation Mode 

Prior to simulation of the cabinet loads 

and cycle behavior, the user is presented 

with a summary of the defined input. A 

data item can be selected for further 

editing by double-clicking on the 

summary line displaying the item in the 

data review dialog. 

Once the data has been reviewed and 

accepted, the user selects the Continue 

button to start the simulation. 

5-B-14
 

EERE-2008-BT-STD-0012 COMMENT 22
Reports Mode 

At the completion of the simulation (which 

is instantaneous for the cabinet loads), the 

program automatically switches to reports 

mode and displays the results on the 

desktop. The example here shows the 

calculated cabinet loads. Results for the 

cycle analysis, overall performance 

parameters, or a more detailed summary, 

can be selected using the side-bar or the 

drop-down menu for reports. 

Cabinet Loads 

As of this preliminary documentation, only the cabinet loads have been modeled. 

Each of the cabinet walls has at least one beveled edge where it joins another wall. Hence, some 

adjustment needs to be made for the difference between the inside and outside surfaces of the 

wall – that is, the conduction is not strictly one-dimensional. Detailed finite difference 

calculations carried out for a flat wall with adiabatic beveled edges (where the walls connect) 

show that a very good approximation can be obtained by representing the beveled wall as an 

equivalent wall of one dimensional heat transfer, where the equivalent wall area is: 

Areaequiv = 0.25 Areaoutside + 0.75 Areainside 

This is nearly identical to the method adopted in the DOS version of ERA, which also made 

adjustments for corner effects where three walls join. Hence, the previous methodology was 

retained, with minor corrections made as needed. 

The loads analysis does not yet consider cycle-dependent interactions such as hot- or cold-walls, 

fan energies, defrost, or other cycle-dependent heat terms. These will be incorporated during the 

cycle portion of the simulation. 

Refrigerant Properties 

The fluid choices for the refrigeration cycle are: R134a, R152a, R290, R404A, R507A, or 

R600a. Thermodynamic properties are based on Refprop 8.0 [24]. To speed the computations, 

an approach to using the Helmholtz equation of state outlined by one of the authors of Refprop 

[25] has been adopted as the primary simulation option for ERA. This reference contains 

required property data for R-404A and R-507A. Data for the other refrigerants represented by 

ERA have been obtained from the Refprop fluid database. 

5-B-15
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

A secondary option to use the full set of the more comprehensive, but considerably slower,i 

Refprop routines will be offered for those instances when the user might wish to confirm the 

simulated performance. 

Because Refprop does not supply a complete set of thermophysical properties for all of the 

refrigerants over the full set of temperatures and pressures, correlations for the thermal 

conductivity and viscosity were developed from refrigerant manufacturer literature. In general, 

uncertainties in these properties are less important than uncertainties in the thermodynamic 

properties since the net heat transfer resistance is normally dominated by the air-side. 

Cycle Analysis 

The cycle model, currently under development, will adopt the general approach employed in the 

DOS version of ERA. An iterative solution procedure will be required to simultaneously satisfy 

the heat transfer and mass flow equations throughout the loop. Where the cycle components 

affect the cabinet loads, adjustments to the loads will be calculated. 

Several major differences will appear between the Windows and DOS versions of ERA: 

•	 Only a map-based compressor model will be used. This decision is based on experience 

gained using ERA with actual equipment, where compressor information for the actual 

unit was needed to accurately reflect the energy consumption. The accompanying 

compressor module, COMPMAP, can be employed to create or modify map data. 

•	 The heat exchanger performance routines will be integrated into the overall cycle 

simulation. Hence, the effects of parameters such as refrigerant mass flow, and entering 

temperature and pressure on the heat exchanger performance will be automatically taken 

into account at each stage of the simulation. 

•	 An improved iteration approach will be used to ensure rapid and proper convergence. 

The solution method used in the ORNL Mark series heat pump looks promising [26]. 

Tools 

The new version of ERA provides several tools to assist in preparing the program inputs and in 

interpreting the results: 

Compressor Map program. COMPMAP may be run directly from ERA by selecting this option 

from the Tools menu. It provides a means of viewing and/or adjusting a map that is to be used in 

i

 Both Lemmon [25] and ThermoSoft experience obtained with a heat pump model confirm that the Helmholtz 

method can result in computation time reductions of a factor of 30 to 40 over the full set of Refprop routines. 

5-B-16
 

EERE-2008-BT-STD-0012 COMMENT 22
the cycle simulation. When selected, ERA is minimized until the compressor map program is 

dismissed, 

Refrigerant Properties. A calculation of the refrigerant properties for the selected refrigerant 

can be made given certain specified state points. The calculations are carried out using the 

Helmholtz method. 

Unit Conversion. This tool can be used to convert to different units values of length, flow rate, 

temperature, thermal conductivity, volume, energy, or power. 

5-B-17
 

EERE-2008-BT-STD-0012 COMMENT 22
REFERENCES 

1.	 “ERA 1.2E, EPA Refrigerator Analysis Program, User’s Manual, Report to the 

Environmental Protection Agency Atmospheric Pollution Prevention Division,” Arthur D. 

Little, Inc., February 1997 

2.	 "Engineering Computer Models for Refrigerators, Freezers, Furnaces, Water Heaters, Room 

and Central Air Conditioners," Report to U.S. DOE, by Arthur D. Little, Inc., November 

1982. 

3.	 McLinden, M., "Theoretical Vapor Compression Cycle, CYCLE7," unpublished. 

4.	 Morrison, G., and McLinden, M., "Application of a Hard Sphere Equation of State to 

Refrigerants and Refrigerant Mixtures," National Bureau of Standards Technical Note 1218, 

1986. 

5.	 "NIST Standard Reference Database 23: NIST Thermodynamic Properties of Refrigerants 

and Refrigerant Mixtures Database, Version 3.0," NIST, December 1991. 

6.	 “Multiple Pathways to Super Efficient Refrigerators," U.S. EPA, Global Change Division, 

Office of Atmospheric Programs, 1993. 

7.	 EPA Refrigerator Analysis (ERA) Program: User’s Manual, Version 1.0. United States 

Environmental Protection Agency. EPA-430-R-93-007. June 1993. with Version 1.2 Update, 

November 1994. 

8.	 Energy Efficiency Standards Regime Study: Refrigerator Manufacturer Workshop, ERMSiam Co Ltd, May 1999. 

9.	 Energy Efficient Refrigerator Prototype Development, ERM-Siam Co. Ltd, September 2001. 

10. Draft Standard: Household Refrigerators, ThermoSoft, June 2002. 

11. State Bur. Tech. Superv. China. 1999. Maximum Allowable Values of Energy Consumption 

and Evaluating Values of Energy Consumption for Household Refrigerators, GB12021.2-

1999. Beijing: China Stand. Publ. House 

12. “ERA Training Workshop Module, The Use of Computer Modeling and Design Tools for 

Energy-Efficient Refrigerators,” ThermoSoft, September 2000. 

13. Dittus, F. W., and Boelter, L. M. K., "Heat Transfer in Automobile Radiators of the Tubular 

type", Publications in Engineering, University of California, Berkeley, 2, pp. 443-461, 1930. 

5-B-18
 

EERE-2008-BT-STD-0012 COMMENT 22
14. Pierre, Bo, Kytlteknisk Tidskript, 3, May 1957, p. 129. 

15. Lockhart, R. W., and Martinelli, R. C., "Proposed Correlation of Data for Isothermal TwoPhase, Two-Component Flow in Pipes," Chemical Engineering Progress, 45, 1, pp. 39-48. 

16. Wang,, Chi-Chuan, “Recent Progress on the Air-side Performance of Fin-and-Tube Heat 

Exchangers,” International Journal of Heat Exchangers 1524-5608 (Vol 1 (2000), pp. 49-76. 

17. Mirth, D.R. and Ramadhyani, S., “Correlations for Predicting the Air-Side Nusselt Numbers 

and Friction Factors in Chilled-Water Cooling Coils,” Experimental Heat Transfer, 7:143-

162, 1994. 

18. Bansal, P.K. and Chin, T.C., “Modeling and Optimization of Wire-and-Tube Condenser,” 

International Journal of Refrigeration 26 (2003) 601-613. 

19. Tagliafico, L. and Tanda, G., “Radiation and Natural Convection Heat Transfer from Wireand-Tube Heat Exchangers in Refrigeration Appliances,” International Journal of 

Refrigeration, 20 (1997) 461-469. 

20. Vera-Garcia, F., et al., “Assessment of Condensation Heat Transfer Correlations in the 

Modeling of Fin and Tube Heat Exchangers,” International Journal of Refrigeration 30 

(2007) 1018-1028. 

21. Shah, M.M., “A General Correlation for Heat Transfer During Film Condensation in Pipes,” 

International Journal of Heat and Mass Transfer 22 (1979) 547-556. 

22. Lee, Tae-Hee, et al, “Determination of Airside Heat Transfer Coefficient on Wire-on-Tube 

Type Heat Exchanger,” International Journal of Heat and Mass Transfer 44 (2001) 1767-

1776. 

23. http://www.ornl.gov/~wlj/hpdm/Mark_VI_Notes.html 

24. Lemmon, E.W., Huber, M.L. and McLinden, M.O., “Reference Fluid Thermodynamic and 

Transport Properties,” NIST Standard Reference Database 23, Version 8.0. 

25. Lemmon, E.W., “Pseudo-Pure Fluid Equations of State for the Refrigerant Blends R-410A, 

R-404A, R-507A, and R-407C,” International Journal of Thermophysics, Vol 24, No 4, July 

2003, pp. 991-1006. 

26. Rice, C.K., “The ORNL Modulating Heat Pump Design Tool – Mark IV User’s Guide,” Oak 

Ridge National Laboratory Report ORNL/CON-343, September 2001. 

5-B-19
 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 6. MARKUPS FOR EQUIPMENT PRICE DETERMINATION 

TABLE OF CONTENTS 

6.1 INTRODUCTION ........................................................................................................... 6-1 

6.1.1 Distribution Channels ...................................................................................................... 6-1 

6.2 MARKUP CALCULATION PROCEDURE .................................................................. 6-1 

6.2.1 Approach for Manufacturer Markups .............................................................................. 6-2 

6.2.2 Approach for Retailer Markups ....................................................................................... 6-2 

6.3 MANUFACTURER MARKUPS .................................................................................... 6-4 

6.4 RETAILER MARKUP .................................................................................................... 6-5 

6.5 SALES TAXES ............................................................................................................... 6-6 

6.6 SUMMARY OF MARKUPS .......................................................................................... 6-7 

LIST OF TABLES 

Table 6.3.1 Major Appliance Manufacturer Gross Margins and Markups............................. 6-5 

Table 6.4.1 Data Used to Calculate Retailer Markups for Residential Refrigeration 

Products................................................................................................................ 6-5 

Table 6.5.1 Average Sales Tax Rates by Census Division and Large State........................... 6-6 

Table 6.5.2 Average Sales Tax Rates by Product................................................................... 6-7 

Table 6.6.1 Summary of Markups .......................................................................................... 6-7 

6-i 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 6. MARKUPS FOR EQUIPMENT PRICE DETERMINATION 

6.1 INTRODUCTION 

To carry out its analyses, DOE needed to determine the cost to the consumer of baseline 

products and the cost of more-efficient units. As discussed in chapter 8, DOE developed retail 

prices for baseline products using proprietary retail price data collected by The NPD Group. For 

products with higher-than-baseline efficiency, DOE estimated the consumer prices by applying 

appropriate markups to the manufacturer incremental equipment costs estimated in the 

engineering analysis. 

6.1.1 Distribution Channels 

The appropriate markups for determining consumer equipment prices depend on the type 

of distribution channels through which products move from manufacturers to purchasers. At 

each point in the distribution channel, companies mark up the price of the equipment to cover 

their business costs and profit margin. 

Data from the Association of Home Appliance Manufacturers (AHAM)1 indicate that an 

overwhelming majority of residential appliances are sold through retail outlets. Because DOE is 

not aware of any other distribution channel that plays a significant role for residential 

refrigeration products, DOE assumed that all of the residential products are purchased by 

consumers from retail outlets. DOE did not include a separate distribution channel for 

refrigeration products included as part of a new home, as it did not have information on the 

extent to which these products are “pre-installed” by builders in new homes. 

6.2 MARKUP CALCULATION PROCEDURE 

As just discussed, at each point in the distribution channel, companies mark up the price 

of the equipment to cover their business costs and profit margin. In financial statements, gross 

margin is the difference between the company revenue and the company cost of sales or cost of 

goods sold (CGS). Inputs for calculating the gross margin are all corporate costs—including 

overhead costs (sales, general, and administration); research and development (R&D) and 

interest expenses; depreciation, and taxes—and profits. In order for sales of a product to 

contribute positively to company cash flow, the product’s markup must be greater than the 

corporate gross margin. Individual products may command a lower or higher markup, 

depending on their perceived added value and the competition they face from similar products in 

the market. 

In developing markups for manufacturers and retailers, DOE obtained data about the 

revenue, CGS, and expenses of firms that produce and sell the products of interest. For retailers, 

DOE’s approach categorizes the expenses into two categories: labor-scaling costs (LSC), which 

6-1 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

are fixed labor and occupancy expenses that increase in proportion to the amount of labor 

required to produce or sell the product, and non-labor-scaling costs (NLSC), which are variable 

operating costs that do not scale with labor and vary in proportion to CGS. 

6.2.1 Approach for Manufacturer Markups 

DOE uses manufacturer markups to transform a manufacturer’s equipment costs into a 

manufacturer sales price. Using the CGS and gross margin, DOE calculated the manufacturer 

markup (MUMFG) with the following equation: 

CGS MFG + GMMFG MU MFG = 

CGS MFG

where: 

MUMFG = Manufacturer markup, 

CGSMFG = Manufacturer’s cost of goods sold or Manufacturer Production Cost 

(MPC), and 

GMMFG = Manufacturer’s gross margin. 

 The manufacturer’s CGS (or MPC) plus its GM equals the manufacturer selling price 

(MSP). 

6.2.2 Approach for Retailer Markups 

DOE based the retailer markups for residential refrigeration products on financial data 

from the U.S. Census Business Expenditure Survey. DOE organized the financial data into 

balance sheets that break down cost components incurred by firms that sell the products.a The 

key assumptions that DOE used to estimate the retailer markups using these financial data were: 

1.	 The balance sheets faithfully represent the various average costs incurred by firms selling 

home appliances. 

2.	 These costs can be divided into two categories: 

a.	 Costs that vary in proportion to the manufacturer sales price (variable costs); and 

b.	 Costs that do not vary with the manufacturer sales price (fixed costs). 

3.	 Retailer sales prices vary in proportion to retailer costs that are included in the balance 

sheets. 

In support of the first assumption, the balance sheets itemize firm costs into a number of 

expense categories, including CGS, operating labor and occupancy costs, and other operating 

a

 The retailers to whom these financial data refer handle multiple commodity lines. 

6-2 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

costs and profit. Although retailers tend to handle multiple commodity lines, the data provide 

the most accurate available indication of home appliance expenses. 

Information obtained from the trade literature pertaining to the heating, ventilation, and 

air-conditioning (HVAC) contracting industry tends to support the second assumption. This 

information indicates that retailer markups should vary according to the quantity of labor and 

materials used to sell or distribute the equipment, with markups on labor tending to be much 

larger than markups on materials.2 This information also describes markups as varying much 

more in relation to sales volume than in relation to other factors, including appliance efficiency. 

This last finding strongly suggests that labor inputs vary more with sales volume than with 

appliance cost or efficiency. In the discussion that follows in section 6.3, DOE assumes a 

division of costs between those that do not scale with the manufacturer sales price (fixed costs— 

labor and occupancy expenses referred to above as LSC), and those that do (variable costs— 

operating expenses and profit referred to above as NLSC). This division of costs led to the 

estimate of retailer markups described below in section 6.3. 

In support of the third assumption, the retailer industries are relatively competitive, and 

consumer demand for residential home appliances is relatively inelastic, i.e. the demand is not 

expected to decrease significantly with a relatively small increase in price. The large number of 

household appliance stores listed by the U.S. Census Bureau in its Statistics of U.S. Businesses 

indicates the competitive nature of the market.3 For example, there are more than 10,000 

household appliance store establishments and over 5000 merchant wholesaler establishments of 

service equipment in the U.S.b According to standard economic theory, competitive firms facing 

inelastic demand either set prices in line with costs or quickly go out of business.4 

Using the above assumptions, DOE developed baseline and incremental markups to 

transform the manufacturer sales price into a consumer equipment price. DOE used the baseline 

markups, which cover all of a retailer’s costs (i.e., both LSC and NLSC), to determine the sales 

price of baseline models. The baseline markup relates the manufacturer sales price to the retailer 

sales price. DOE considers baseline models to be equipment sold under existing market 

conditions (i.e., without new energy efficiency standards). DOE calculated the baseline markup 

(MUBASE) for retailers using the following equation: 

CGS RTL / DIST + GMRTL / DIST CGSRTL / DIST + ( LSCRTL / DIST + NLSCRTL / DIST ) MU = = BASE CGSRTL / DIST CGSRTL / DIST

where: 

MUBASE = Baseline retailer markup, 

CGSRTL/DIST = Retailer’s cost of goods sold, 

GMRTL/DIST = Retailer’s gross margin, 

b

 DOE determined the number of establishments for household appliance stores based on the following North 

American Industry Classification System (NAICS) code and description: 443111, Household Appliance Stores. 

6-3 

EERE-2008-BT-STD-0012 COMMENT 22
LSCRTL/DIST = Retailer’s labor-scaling costs, and 

NLSCRTL/DIST = Retailer’s non-labor-scaling costs. 

Incremental markups cover only those costs that scale with a change in the 

manufacturer’s sales price (i.e., NLSC). Incremental markups are coefficients that relate the 

change in the manufacturer sales price of higher-efficiency models to the change in the retailer 

sales price. DOE considers higher-efficiency models to be equipment sold under market 

conditions with new efficiency standards. It calculated the incremental markup (MUINCR) for 

retailers using the following equation: 

CGSRTL / DIST + NLSCRTL / DIST MUINCR = 

CGSRTL / DIST

where: 

MUINCR = Incremental retailer markup, 

CGSRTL/DIST = Retailer’s cost of goods sold, and 

NLSCRTL/DIST = Retailer’s non-labor-scaling costs. 

6.3 MANUFACTURER MARKUPS 

DOE developed an average manufacturer markup by examining the annual Securities and 

Exchange Commission (SEC) 10-K reports filed by four publicly-traded manufacturers primarily 

engaged in appliance manufacturing and whose combined product range includes residential 

refrigeration products.5 The four manufacturers represent a nearly 50 percent market share for 

major appliances. Because these companies are typically diversified, producing a range of 

different appliances, an industry average markup was assumed by DOE to be representative for 

the manufacture of refrigeration products. DOE evaluated markups for the years 2002─2005. 

Table 6.3.1 lists the average corporate gross margin during the years 2002─2005, and 

corresponding markups, for each of the four manufacturers. The average markup value based on 

these four companies is 1.26, which is the value that DOE used. 

6-4 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 6.3.1 Major Appliance Manufacturer Gross Margins and Markups 

Mfr A Mfr B Mfr C Mfr D 

Average Net Revenues (Million) $372 $280 $4770 $12,682 

Corporate Gross Margin 15% 28% 16% 22% 

Markup 1.18 1.39 1.19 1.28 

Source: SEC 10-K reports (2002-2005) 

6.4 RETAILER MARKUP 

DOE used financial data from the U.S. Census Business Expenditure Survey (BES), in 

the “Household Appliance Stores” category, to calculate markups used by retailers that apply to 

residential refrigeration products.c 6 Table 6.4.1 shows the BES data that DOE used and the 

estimated retail markups. 

Table 6.4.1	 Data Used to Calculate Retailer Markups for Residential Refrigeration 

Products 

Item Million Dollars 

Sales (revenue) 10343 

Cost of Goods Sold (CGS) 7151 

Gross Margin (GM) 3193 

Labor-Scaling Costs (LSC)

 Payroll 1366 

 Fringe Benefits 208 

Contract Labor 69 

 Taxes and License Fees 53 

 Lease and Rental Payments 238 

 Telephone and Communications 58 

Utilities 70 

Repair and Maintenance 36 

 LCS Subtotal: 2098 

Non-Labor-Scaling Costs (NLSC)

 Depreciation and Amortization 94 

Office Supplies 37 

 Packaging and Other Materials 0 

Advertising Services 274 

c

 DOE used the 1997 BES because the 2002 BES did not contain sufficient data for the calculation of gross margin 

or cost of goods sold. 

6-5 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 Legal Services 8 

Accounting, Auditing, and Bookkeeping 19 

 Computer Related Services 10 

 Other Operating Expenses 389 

 Net Profit Before Taxes 263 

 NLCS Subtotal: 1094 

Baseline Markup (MUBASE) = (CGS+GM)/CGS 1.45 

Incremental Markup (MUINCR) = (CGS+NLSC)/CGS 1.15 

6.5 SALES TAXES 

The sales tax represents state and local sales taxes that are applied to the consumer 

equipment price of the equipment. The sales tax is a multiplicative factor that increases the 

consumer equipment price. 

DOE derived state and local taxes from data provided by the Sales Tax Clearinghouse.7 

DOE derived population-weighted average tax values for each Census division and large state, as 

shown in Table 6.5.1 below. 

Table 6.5.1 Average Sales Tax Rates by Census Division and Large State 

Census Division/State Tax Rate 

New England 4.96% 

Mid Atlantic 6.54% 

East North Central 6.93% 

West North Central 6.77% 

South Atlantic 6.17% 

East South Central 7.90% 

West South Central 8.37% 

Mountain 6.50% 

Pacific 5.20% 

New York State 8.25% 

California 9.00% 

Texas 8.05% 

Florida 6.70% 

DOE then derived U.S. average tax values for each product (as shown in Table 6.5.2 

below) based on the product’s saturation within each Census division and large state. It 

determined the saturations from the DOE Energy Information Administration (EIA)’s 2005 

Residential Energy Consumption Survey.8 

6-6 

EERE-2008-BT-STD-0012 COMMENT 22
Table 6.5.2 Average Sales Tax Rates by Product 

Product Tax Rate 

Refrigerators (Standard-size and compact) 7.08% 

Freezers (Standard-size and compact) 6.94% 

6.6 SUMMARY OF MARKUPS 

Table 6.6.1 summarizes the markups at each stage in the distribution channel and the 

average sales tax. 

Table 6.6.1 Summary of Markups 

Markup Baseline Incremental 

Manufacturer 1.26 

Retailer 1.45 1.15 

Sales Tax 1.069 

6-7 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

REFERENCES 

1	 Association of Home Appliance Manufacturers. AHAM 2003 Fact Book, 2003. Washington, 

DC. p. 25. 

2	 Skaer, M. What should you charge? Try these Tested Formulas. The Air Conditioning, 

Heating, and Refrigeration News, 2001. 

<http://www.achrnews.com/CDA/ArticleInformation/features/BNP_Features_Item/0,1338,23113,00.html> 

3	 U.S. Census Bureau. Statistics of U.S. Businesses, 2004. Washington, DC. 

<http://www.census.gov/csd/susb/susb04.htm> 

4	 Pindyck, R.S. and D.L. Rubinfeld, Microeconomics, 5th ed., 2000. New Jersey: Prentice Hall. 

5	 Security Exchange Commission, SEC 10-K Reports, Various dates, 2002-2005, Security 

Exchange Commission. <http://www.sec.gov/> 

6	 U.S. Census Bureau. 1997 Economic Census, Business Expenses Survey, Retail Trade, 

Household Appliance Stores, 1997. Washington, DC. 

<http://www.census.gov/csd/bes/bes97.htm> 

7	 Sales Tax Clearinghouse, Inc. State sales tax rates along with combined average city and 

county rates. <http://thestc.com/STrates.stm> 

8	 U.S. Department of Energy-Energy Information Administration. Residential Energy 

Consumption Survey, 2005Public Use Data Files.. Washington, DC. 

<http://www.eia.doe.gov/emeu/recs/recspubuse05/pubuse05.html> 

6-8 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 7. ENERGY USE DETERMINATION 

TABLE OF CONTENTS 

7.1 HOUSEHOLD SAMPLES FOR REFRIGERATION PRODUCTS............................... 7-4 

7.2 APPROACH FOR STANDARD-SIZE PRODUCTS..................................................... 7-6 

7.3 USAGE ADJUSTMENT FACTORS FOR STANDARD-SIZE PRODUCTS............... 7-9 

7.3.1 Field Energy Consumption for One or More Refrigerators .................................. 7-9 

7.3.2 Tested Energy Consumption ............................................................................... 7-11 

7.3.2.1 Size ....................................................................................................... 7-11 

7.3.2.2 Assigning Vintage and ENERGY STAR Status .................................. 7-12 

7.3.3 Energy Use of Second Refrigerators ................................................................... 7-18 

7.3.4 Estimated Number of ENERGY STAR Refrigerators ........................................ 7-19 

7.3.5 Validating Field Energy Consumption................................................................ 7-20 

7.3.6 Maximum Usage Adjustment Factor .................................................................. 7-20 

7.3.7 Minimum Usage Adjustment Factor ................................................................... 7-27 

7.3.8 Results by Product Class ..................................................................................... 7-30 

7.3.9 Distributions: Comparison with Other Studies ................................................... 7-36 

7.4 ENERGY USE OF COMPACT REFRIGERATION PRODUCTS.............................. 7-38 

7.5 ANNUAL ENERGY CONSUMPTION BY EFFICIENCY LEVEL ........................... 7-38 

LIST OF TABLES 

Table 7.1.1 Refrigeration Products in Households by Product Class ..................................... 7-5 

Table 7.3.1 Size Bins for Refrigerators and Freezers ........................................................... 7-12 

Table 7.3.2 Parameters for Calculating Adjusted Volume from Total Volume of 

Refrigerator-Freezers ......................................................................................... 7-12 

Table 7.3.3 Energy Conservation Standards for Refrigeration Products.............................. 7-13 

Table 7.3.4 ENERGY STAR Criteria for Refrigeration Products........................................ 7-13 

Table 7.3.5 Vintage Bins for Refrigeration Products............................................................ 7-14 

Table 7.3.6 Refrigerator Survival Probabilities Associated with Age Bins.......................... 7-18 

Table 7.3.7 Market Share of ENERGY STAR Products ...................................................... 7-20 

Table 7.3.8 Power Consumption for Ice Maker Components............................................... 7-21 

Table 7.3.9 Theoretical Maximum Energy Consumption for Baseline Product Class 3 

Refrigerator-Freezers ......................................................................................... 7-23 

Table 7.3.10 Theoretical Maximum Energy Consumption for Baseline Product Class 5 

Refrigerator-Freezers ......................................................................................... 7-23 

Table 7.3.11 Theoretical Maximum Energy Consumption for Baseline Product Class 7 

Refrigerator-Freezers ......................................................................................... 7-24 

Table 7.3.12 Theoretical Maximum Energy Consumption for Baseline Product Class 9 

Freezers.............................................................................................................. 7-24 

7-1
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 7.3.13 Theoretical Maximum Energy Consumption for Baseline Product Class 10 

Freezers.............................................................................................................. 7-25 

Table 7.3.14 Regression Parameters by Product Class for Maximum Usage Adjustment 

Factor ................................................................................................................. 7-27 

Table 7.3.15 Temperature Settings for Refrigerators Under Test and Ideal Conditions ........ 7-27 

Table 7.3.16 Temperature Settings for Freezers Under Test and Ideal Conditions................ 7-28 

Table 7.3.17 Model Errors by Product Class and Vintage...................................................... 7-28 

Table 7.3.18 Regression Results Based on Unit Vintage ....................................................... 7-30 

Table 7.3.19 Usage Adjustment Factors Before and After Excluding Minimums and 

Maximums ......................................................................................................... 7-36 

Table 7.4.1 Parameters for Calculating Adjusted Volume from Total Volume for 

Compact Refrigerators....................................................................................... 7-38 

Table 7.5.1 Product Class 3, Top-Mount Refrigerator-Freezers Without Through-theDoor Ice Service: Average Annual Energy Use by Efficiency Level ............... 7-39 

Table 7.5.2 Product Class 5, Bottom-Mount Refrigerator-Freezers Without Throughthe-Door Ice Service: Average Annual Energy Use by Efficiency Level ......... 7-40 

Table 7.5.3 Product Class 7, Side-by-side Refrigerator-Freezers with Through-theDoor Ice Service: Average Annual Energy Use by Efficiency Level ............... 7-40 

Table 7.5.4 Product Class 9, Upright Freezers: Average Annual Energy Use by 

Efficiency Level................................................................................................. 7-41 

Table 7.5.5 Product Class 10, Chest Freezers: Average Annual Energy Use by 

Efficiency Level................................................................................................. 7-41 

Table 7.5.6 Compact Refrigerators and Freezers: Average Annual Energy Use by 

Efficiency Level................................................................................................. 7-42 

LIST OF FIGURES 

Figure 7.3.1 Average Unit Energy Consumption, 1961 to 1990 Shipments.......................... 7-14 

Figure 7.3.2 Weighted Households by Refrigerator Vintage................................................. 7-15 

Figure 7.3.3 Survival Probability of Refrigerators by Age .................................................... 7-16 

Figure 7.3.4 Survival Probability of Freezers by Age............................................................ 7-17 

Figure 7.3.5 Maximum Usage Adjustment Factor by Product Age in 2005.......................... 7-26 

Figure 7.3.6 Minimum Plausible Usage Adjustment Factor as a Function of Product 

Age in 2005........................................................................................................ 7-29 

Figure 7.3.7 Initial UAF Distribution for Standard-Size Top-Mount RefrigeratorFreezers (Product Class 3) ................................................................................. 7-31 

Figure 7.3.8 Final UAF Distribution for Standard-Size Top-Mount RefrigeratorFreezers (Product Class 3) ................................................................................. 7-31 

Figure 7.3.9 Initial UAF Distribution for Standard-Size Bottom-Mount RefrigeratorFreezers (Product Class 5) ................................................................................. 7-32 

Figure 7.3.10 Final UAF Distribution for Standard-Size Bottom-Mount RefrigeratorFreezers (Product Class 5) ................................................................................. 7-32 

7-2
 

EERE-2008-BT-STD-0012 COMMENT 22
Figure 7.3.11 Initial UAF Distribution for Standard-Size Side-by-side RefrigeratorFreezers (Product Class 7) ................................................................................. 7-33 

Figure 7.3.12 Final UAF Distribution for Standard-Size Side-by-side RefrigeratorFreezers (Product Class 7) ................................................................................. 7-33 

Figure 7.3.13 Initial UAF Distribution for Standard-Size Upright Freezers (Product 

Class 9)............................................................................................................... 7-34 

Figure 7.3.14 Final UAF Distribution for Standard-Size Upright Freezers (Product Class 

9) ........................................................................................................................ 7-34 

Figure 7.3.15 Initial UAF Distribution for Standard-Size Chest Freezers (Product Class 

10) ...................................................................................................................... 7-35 

Figure 7.3.16 Final UAF Distribution for Standard-Size Chest Freezers (Product Class 

10) ...................................................................................................................... 7-35 

7-3
 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 7. ENERGY USE DETERMINATION 

To perform the life-cycle cost (LCC) and payback period (PBP) calculations described in 

chapter 8, the U.S. Department (DOE) needed to determine the savings in operating cost that 

consumers would derive from more efficient products. DOE uses data on annual energy 

consumption, along with energy prices, to develop the most significant component of consumer 

operating cost. (Maintenance and repair costs are the other components.) This chapter describes 

how DOE determined the annual energy consumption of refrigeration products. 

The engineering analysis described in chapter 5 reports energy use derived from the DOE 

test procedure. This test produces standardized results that can be used o compare the 

performance of different brands of the same product class operating under similar conditions. 

Actual energy usage in the field, however, often differs from that estimated by the test procedure. 

Researchers have conducted studies that measure the field consumption of refrigerator-freezers, 

comparing such measurements to the DOE test results. DOE’s review of several such studies is 

described in appendix 7-A and summarized in section 7.3.9. The review confirmed that energy 

use measured in the field often differs considerably from the usage measured by the DOE test 

procedure. 

To determine the field energy use by products that would meet potential new energy 

efficiency standards, DOE used data from the Energy Information Administration’s 2005 

Residential Energy Consumption Survey (RECS).1

 RECS queries a national sample of 

households to collect statistical information on household consumption of and expenditures for 

energy, along with data on energy-related characteristics of the housing units and households. 

RECS provides enough information to establish the type of refrigeration product (the product 

class) used in each household, and provides an estimate of the household energy consumption 

attributable to refrigerators or freezers. As a result, DOE was able to develop a unique household 

sample for most of the representative product classes for standard-size units. 

DOE did not use RECS to evaluate energy consumption by compact refrigerators and 

freezers, because many of those products are used outside the residential sector, such as in 

college dormitories, hotels and motels, and offices. 

7.1 HOUSEHOLD SAMPLES FOR REFRIGERATION PRODUCTS 

DOE developed household samples for refrigeration products from the 2005 RECS. The 

survey, which sampled 4,382 housing units, was constructed to represent the household 

population throughout the United States. 

RECS results reveal whether a household uses a standard-size refrigerator or freezer. For 

households that have a standard-size refrigerator, RECS specifies whether the freezer is top- or 

bottom-mounted or is side-mounted. Thus units in the sample that have top-mounted freezers 

7-4
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

cannot be distinguished from those having bottom-mounted freezers (product classes 3 and 5). 

For a household’s primary (or “first”) refrigerator, RECS specifies whether there is through-thedoor ice service. For households that have standard-size freezers, RECS specifies whether the 

unit is upright or a chest-type. With the above data, DOE was able to assign each household 

record to one of the five product classes considered for potential new efficiency standards (Table 

7.1.1). 

Table 7.1.1 Refrigeration Products in Households by Product Class 

Product Class Number of 

Household 

Records* 

Percent of Total 

Household 

Records* 

Relative Standard 

Error Due to 

Sampling* 

3. Refrigerator-freezer: 

automatic defrost with topmounted freezer and no TTD† 

ice service 2,303 52.6% 2.1% 5. Refrigerator-freezer: 

automatic defrost with 

bottom-mounted freezer and 

no TTD ice service 

7. Refrigerator-freezer: 

automatic defrost with sidemounted freezer and TTD ice 

service 

1,026 23.4% 3.1% 

9. Upright freezer with 

automatic defrost 248 5.7% 6.4% 

10. Chest freezer and all other 

freezers except compact 

models 

369 8.4% 5.2% 

* From the Energy Information Administration’s 2005 Residential Energy Consumption Survey (RECS). 

† Through-the-door. 

The relative standard errors associated with the subsamples that contain specific product 

classes are not considered so large as to affect the validity of the derived results presented in this 

chapter. Specifically, the relative standard error of a sample of size N, expressed as a percentage, 

is 100 divided by the square root of (N-1). For the full 2005 RECS sample, the associated 

relative standard error due to sampling is 1.5 percent. For the subsamples containing product 

classes 9 and 10, the associated relative standard errors are 6.4 percent and 5.2 percent, 

respectively. Although the standard error for the smallest subsample is more than four times the 

error for the entire 2005 RECS, it still is less than 10 percent, a relative standard error considered 

small enough to yield meaningful results. Therefore, DOE believes the results generated from the 

household samples for refrigeration products are representative of U.S. households using those 

appliances. 

7-5
 

EERE-2008-BT-STD-0012 COMMENT 22
 

7.2 APPROACH FOR STANDARD-SIZE PRODUCTS 

The Residential Energy Consumption Survey (RECS) reports the annual field energy 

consumption of each household’s refrigeration product(s), a quantity referred to as FECRECS. 

DOE treated the reported energy consumption as the actual consumption of the refrigeration 

product(s) in each household. Because the energy consumed by a household’s refrigerator or 

freezer varies depending on operating conditions, user behavior, and other factors, DOE applied 

a multiplicative usage adjustment factor (UAF) to the labeled energy use of each product to 

reflect those factors. 

To develop a UAF for each RECS household, DOE utilized information that RECS 

provides on the interior volume and age of each refrigeration product. Using this information and 

the unit’s product class, DOE determined for each household unit the maximum allowable tested 

energy consumption, referred to as TECSTD, as stipulated by the energy conservation standard in 

effect at the time the household purchased the product. Because TECSTD differentiates among 

current levels of energy efficiency, it guards against overestimating the energy savings to be 

derived from potential new standards. Using FECRECS and TECSTD, DOE developed the UAF for 

each household to capture the combined effects of consumer behavior (e.g., door openings); 

operating conditions (e.g., room temperature and humidity); and product characteristics (e.g., 

efficiency relative to the maximum allowable). The UAF adjusts the maximum allowable energy 

use when the unit was tested to arrive at the field energy consumption of the refrigeration 

product. UAF is represented by the following expression. 

FECRECS UAF = TECSTD 

Eq. 7.1 

Where: 

UAF = usage adjustment factor; 

FECRECS = refrigeration product’s field energy consumption as reported for the RECS 

household; and 

TECSTD = maximum allowable tested energy consumption based on the standard in effect at 

the time the household purchased the refrigeration product; for products purchased 

before 1990 (when the first national standard came into effect), DOE used the 

shipments-weighted average energy consumption for that vintage to scale the 

standard. 

DOE was better able to estimate the efficiency of ENERGY STAR products and thus 

develop a UAF that more accurately represents only behavior and operating conditions. DOE 

used an income-based statistical model, described in section 7.3.4, to identify households likely 

to own an ENERGY STAR appliance. In those cases, UAF was defined as follows. 

7-6
 

EERE-2008-BT-STD-0012 COMMENT 22
 

FECRECS UAF = TECES 

Eq. 7.2 

Where: 

UAF = usage adjustment factor, 

FECRECS = refrigeration product’s field energy consumption as reported for the RECS 

household, and 

TECES = tested energy consumption based on the ENERGY STAR criteria in effect at the 

time the household purchased the refrigeration product. 

DOE conducted its analysis with an awareness of proposed revisions to the DOE test 

procedure for refrigerator-freezers, which will stipulate lower temperatures for the fresh food 

compartment and the freezer than those the currently prescribed. DOE has not identified how the 

tested energy consumption under the new procedure will compare to that determined under the 

current procedure. DOE expects this adjustment to take the form of a multiplicative factor 

termed the “efficiency standard adjustment factor,” or ESAF. The ESAF is expected to be 

multiplicative, because the energy use for a refrigeration unit is close to proportional to the 

difference between its interior and exterior temperatures. For the current preliminary analysis, 

DOE assumed that this factor is constant for each product class, and does not vary with product 

efficiency or adjusted volume. See chapter 5 for a complete discussion of the derivation of these 

values. DOE determined the preliminary value of the ESAF for refrigerator-freezers to be: 

• 1.124 for product class 3, 

• 1.18 for product class 5, 

• 1.14 for product class 7, 

• 1.00 for product class 9, and 

• 1.00 for product class 10. 

If the ESAF is multiplicative, it does not affect DOE’s estimate of appliance energy 

consumption by consumers, FEC The mathematical demonstration of this equivalence is shown 

below, after several additional terms are defined. Fundamentally, the value of the ESAF does not 

affect estimates of field energy use, because changes in the test procedure do not affect consumer 

behavior or operation of an appliance within a household. Field energy consumption of future 

appliances built to meet a national standard, however, may be affected by the test procedure used 

to define the standard. For this reason, DOE assumed that the effects of consumer behavior and 

operating conditions, characterized by the UAF, are separate from the effects of the test 

procedure, characterized by the ESAF. DOE therefore separated the UAF values calculated from 

the RECS household sample from the ESAF, which does not vary across the household sample. 

If appropriate, DOE will incorporate a more complete and accurate model for the ESAF 

based on ongoing analysis and additional information collected from interested parties. 

Therefore, although a constant, multiplicative ESAF does not affect estimated annual energy use, 

7-7
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

DOE has chosen to show where the factor would enter into its calculations. To that end, DOE 

defined a new term, TECSTD-REV-TP , which is determined with the following expression. 

TEC STD−REV −TP	 = ESAF ×TEC	 STD−EXIST −TP Eq. 7.3

Where: 

TECSTD-REV-TP = maximum allowable tested energy consumption based on the standard in 

effect at the time the household purchased the refrigeration product, revised to 

reflect proposed lower temperatures for the fresh food and freezer 

compartments; 

ESAF = efficiency standard adjustment factor; and 

TECSTD-EXIST-TP = maximum allowable tested energy consumption based on the standard in 

effect at the time the household purchased the refrigeration product, reflecting 

current DOE test procedure conditions. 

 Substituting TECSTD-REV-TP for TECSTD in Eq. 7.1 produces the following expression for 

UAF. 

FECRECS UAF = ESAF ×TECSTD−EXIST −TP	 Eq. 7.4 

After the UAFs were determined for each household within a given sample, DOE 

adjusted the tested energy consumption for a new refrigeration product (TECNEW) (such as those 

analyzed in the engineering analysis) into a field-adjusted annual energy consumption, referred 

to as FECNEW, using the following expression. 

FEC = TEC ×UAF	 Eq. 7.5 NEW NEW 

Where: 

FECNEW = field-adjusted annual energy consumption of new refrigeration product, and 

TECNEW = tested energy consumption of new refrigeration product. 

DOE assumed that the UAF a given household would be the same for products that meet 

some future energy efficiency standard as it is for their current appliance. In conducting the lifecycle cost analysis (chapter 8), DOE substituted the refrigeration product recorded in RECS with 

a new product of identical product class and size that the household is assumed to purchase in the 

year when the new standard goes into effect. 

If the ESAF is a multiplicative factor, as DOE assumed for this analysis, and the energy 

use required by the new standard is reduced from the current standard by a factor R (e.g., a 10­

7-8
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

percent efficiency improvement would mean R = 0.1), then for an appliance that meets the new 

standard, tested under the new test procedure, the field energy consumption is 

FEC FEC = TEC ×UAF = TEC × RECS 

NEW −STD NEW −STD NEW −STD ESAF ×TECSTD−EXIST −TP 

TECNEW −STD 

TECSTD−EXIST −TP = FECRECS ×

ESAF 

Eq. 7.6

(1− R)× ESAF ×TECSTD−EXIST −TP 

TECSTD−EXIST −TP = FECRECS ×

ESAF 

= (1− R)× FECRECS 

A multiplicative ESAF therefore is not needed to calculate energy savings related to a 

higher efficiency standard, which can be calculated using only FECRECS and R. 

7.3 USAGE ADJUSTMENT FACTORS FOR STANDARD-SIZE PRODUCTS 

This section describes how DOE developed usage adjustment factors (UAFs) from the 

data provided for each household in RECS. It also describes how DOE developed minimum and 

maximum UAFs based on the highest and lowest plausible energy consumption of refrigeration 

products in the field. DOE’s methods of acconting for second refrigerators and ENERGY STAR 

products are also described. 

7.3.1 Field Energy Consumption for One or More Refrigerators 

RECS reports the annual energy consumption of each household’s refrigerator(s) or 

freezer in terms of thousands of British thermal units (BTUs) per year, which DOE converted to 

kilowatt-hours (kWh) per year. The reported end-use quantities were not based on data obtained 

by placing meters on individual appliances; rather, a regression technique was used to estimate 

how much of the total annual electricity consumption for each household can be attributed to 

each end-use category.a

 The regression equations also were used to infer energy consumption 

when the billing data were missing or inadequate. The refrigerator component for electricity 

consisted of all electricity used to operate refrigerators. The electricity used to operate freezers 

was assigned to a separate component under the category of “general appliance.” 

a

 The desire to use a large number of independent variables without using a large number of interaction terms and 

the desire to adapt the regression procedures to account for heteroscedastic error terms led to the use of a nonlinear 

regression technique. For more information, see: http://www.eia.doe.gov/pub/consumption/residential/append_c.pdf 

7-9
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

When a house has two or more refrigerators in RECSb

, the energy consumption of all the 

refrigerators is included in the term for “electric refrigerator use.” DOE’s analysis required 

separate consideration of each individual refrigerator in a household. 

Total refrigerator field energy consumption (FEC) for households having two 

refrigerators can be expressed as: 

FEC = (UAF1 ×TECSTD1) + ( Mon ×UAF2 ×TECSTD2 ) Eq. 7.7 12 

Where: 

UAF = usage adjustment factor, 

TEC = test energy consumption, and 

Mon = number of months per year the second refrigerator is on.c
 

The subscript numerals 1 and 2 refer to the first and second refrigerator, respectively. 

TECSTD refers to the maximum annual energy consumption allowed by the efficiency 

standards in effect when the product was manufactured. This value depends on the age and 

adjusted volume of the refrigerator. DOE assigned values for the age and adjusted volume of the 

second refrigerator the same way as for the first refrigerator. After these were assigned, the 

TECstd for the second refrigerator was calculated. 

The location of the second refrigerator, often in either a garage or basement, affects its 

UAF. DOE assumed that for most households, the second refrigerator is in the garage. In those 

cases the UAF of the second refrigerator is the same as that of the first. If the second refrigerator 

operates for 12 months of the year, and the house is in the northern part of the country, however, 

the unit was assumed to be in a basement. (North is defined as Census Districts 1, 2, 3, and 4 

plus New York, as well as other areas experiencing at least 5,000 heating degree-days. Because 

the operating environment of a basement on average is colder than that of the first refrigerator, 

DOE estimated the UAF of the second refrigerator to be 70 percent of the UAF of the first. This 

estimate was based on results of a simulation performed under basement conditions versus 

Results from the DOE test procedure. Although DOE did not use RECS to develop a household 

sample for compact refrigerators, DOE included in its analysis of standard-sized products those 

households having a second refrigerator that was a compact. The compact was assigned a 

volume based on the volume distribution in the California Energy Commission appliance 

database,2

 and assigned a UAF as if it were standard-sized. 

b Of the households in RECS 2005, 19.6 percent reported having two refrigerators; 1.2 percent reported having 

three. DOE considered only those households having one or two refrigerators. 

c

 RECS reports months of operation for a second refrigerator. 

7-10
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

The UAF for each refrigerator can be calculated based on the above assumptions. For 

most households, the UAF for both first and second refrigerators is calculated as: 

FEC UAF = Eq. 7.8 ⎛ Mon ⎞ ⎜TECSTD + ( 12 

×TECSTD2 )⎟ 1 ⎝ ⎠

For households in which the second refrigerator is assumed to be in the basement, the 

UAF for the first refrigerator is calculated as: 

FEC UAF1 = Eq. 7.9 ⎛ Mon ⎞ ⎜TECSTD + (0.70× ×TECSTD2 )⎟ 1 ⎝ 12 ⎠

and the UAF for the second refrigerator is calculated as: 

UAF = 0.70 ×UAF Eq. 7.10 2 1 

7.3.2 Tested Energy Consumption 

For each refrigeration unit in a RECS home, the maximum allowable tested energy 

consumption based on the standard in effect at the time the refrigeration product was 

manufactured (TECSTD) depends on the unit’s product class, size, and age (vintage). If the 

household was assigned a refrigerator having an ENERGY STAR designation (using the model 

derived in section 7.3.4), DOE calculated the maximum allowed tested energy consumption for 

an ENERGY STAR unit of the appropriate vintage rather than the maximum allowed by the 

concurrent standard. 

Each unit’s product class was identified as described in section 7.1. The size and vintage 

were determined as described below. 

7.3.2.1 Size 

The possible answers to the RECS question regarding the size of the first refrigerator or 

freezer are shown in Table 7.3.1. The distribution of actual sizes is not uniform within the RECS 

size bins. To estimate the actual size of each unit, DOE estimated the distribution of sizes within 

each bin. To approximate that distribution, DOE used data on refrigerator models from the 2009 

California Energy Commission (CEC) appliance model database.2 The figures in appendix 7-B 

show the number of models by size within each RECS size bin for each considered product 

classes. The size assigned to a sample refrigerator within a RECS size bin was assigned 

randomly using probabilities derived from the CEC data. 

7-11
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 7.3.1 Size Bins for Refrigerators and Freezers 

Bin* Size of First Refrigerator 

cu ft† 

1 Very small (10 or fewer) 

2 Small (11 to 14) 

3 Medium (15 to 18) 

4 Large (19 to 22) 

5 Very large (more than 22) 

* Bins defined in Residential Energy Consumption Survey, 2005.

† Cubic feet. 

The maximum allowed energy consumption depends on the year the product was 

produced, its product class, and adjusted volume. For a refrigerator-freezer, the adjusted volume 

is equal to the internal volume of the fresh food compartment plus 1.63 times the internal volume 

of the freezer compartment.3

 Using the CEC database,2 DOE used the following linear regression 

to calculate the adjusted volume (Voladj) from the total volume (Voltot): 

Voladj =Voltot × Slope + Intercept Eq. 7.11 

DOE performed this calculation for each product class, deriving the parameters shown in 

 Table 7.3.2. 

Table 7.3.2 Parameters for Calculating Adjusted Volume from Total Volume of 

Refrigerator-Freezers 

Product Class Slope Intercept R2 † Count 

3. Refrigerator-freezers: automatic defrost 

with top-mounted freezer and no TTD* ice 

service 

1.2205 -1.1049 0.9691 1,803 

5. Refrigerator-freezers: automatic defrost 

with bottom-mounted freezer and no TTD 

ice service 

1.1851 0.0159 0.9929 778 

7. Refrigerator-freezers: automatic defrost 

with side-mounted freezer and TTD ice 

service 

1.3170 -1.9992 0.9906 1,866 

*Through-the-door. 

† R2

 is the coefficient of determination, a measure of how well the model fits the data. 

7.3.2.2 Assigning Vintage and ENERGY STAR Status 

The vintage of a refrigerator reflects the minimum efficiency standards that were in effect 

at the time it was purchased. Table 7.3.3 lists the relevant energy efficiency standards and the 

7-12
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

dates each became effective. The formula that expresses the standard is for maximum allowable 

kWh per year as a linear function of adjusted volume (AV).4, 5 

Table 7.3.3 Energy Conservation Standards for Refrigeration Products 

Product Class 1990 Jan. 1, 1993 July 1, 2001 

3. Top-mount refrigerator-freezers 

without TTD* ice service 23.5AV+471 16.0AV + 355 9.80AV+276.0 

5. Bottom-mount refrigerator-freezers 

without TTD ice service 27.7AV+488 16.5AV + 367 4.60AV+459.0 

7. Side-by-side refrigerator-freezers 

with TTD ice service 30.9AV+547 16.3AV + 527 10.10AV+406.0 

9. Upright freezers with automatic 

defrost 16.0AV+623 14.9AV + 391 12.43AV+326.1 

10. Chest freezers 14.8AV+233 11.0AV + 160 9.88AV+143.7 

*Through-the-door. 

The vintage also reveals which ENERGY STAR criteria were in effect. The effective 

dates of successive ENERGY STAR specifications are shown in Table 7.3.4.6 7 

Table 7.3.4 ENERGY STAR Criteria for Refrigeration Products 

ENERGY STAR Criterion Effective Date 

Refrigerators* 

 15% less energy than NAECA†

 2001 maximum allowed January 1, 2004 

 10% less energy than NAECA 2001 maximum allowed January 1, 2001 

 20% less energy than NAECA 1993 maximum allowed June 1996 

Freezers 

 10% less energy than NAECA 2001 maximum January 1, 2003 

* The criteria that became effective in 2008 (20% less energy than NAECA 2001 maximum) do not apply to 

units described in RECS 2005. 

† National Appliance Energy Conservation Act 

RECS assigns the age of a refrigeration product to one of the five bins listed in Table 

7.3.5. 

7-13
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

Table 7.3.5 Vintage Bins for Refrigeration Products 

Bin* Age of Unit 

years 

1 Less than 2 

2 2 to 4 

3 5 to 9 

4 10 to 19 

5 20 or more 

* Bins defined in Residential Energy Consumption Survey, 2005. 

The dates refrigerator standards took effect do not correspond exactly to the age bins in 

RECS. When the age bin of a refrigerator is insufficient to determine which standard applied, 

DOE chose a year from within the bin to assign as the vintage of that refrigerator. After the year 

was chosen using the survival curve developed for appliance lifetime, the standard appropriate to 

that vintage was applied. 

For refrigeration products shipped before 1990, DOE derived an efficiency index based 

on trends in the average unit energy consumption (UEC) for historical shipments of refrigerators 

and freezers. Figure 7.3.1shows the trends in UEC from 1960 to 1990. 

0 

200 

400 

600 

800 

1000 

1200 

1400 

1600 

1800 

2000 

1960 1965 1970 1975 1980 1985 1990 

UEC 

Refrigerators 

Freezers 

Source: AHAM Factbooks 

Figure 7.3.1 Average Unit Energy Consumption, 1961 to 1990 Shipments 

7-14
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

There are likely to be fewer of the oldest refrigerators within any vintage bin, both 

because older refrigerators tend be replaced and because fewer refrigerators were produced in 

earlier years. This trend is revealed in Figure 7.3.2, which shows the weighted number of 

households by vintage from the 2005 RECS. For this figure, the refrigerators in each bin were 

assigned equally to each year. A better approach would be to assign more refrigerators to the 

more recent years within each bin by calculating the survival probability [that is, the probability 

of a refrigerator surviving (remaining in use)] for a number of years. The survival probability is 

calculated using the number of refrigerators of each vintage bin reported by RECS as a fraction 

of the number of refrigerators shipped in that range of years. The survival probability accounts 

for the increases in shipments over time, as well as the refrigerators that retire from use. The 

survival probability function used to assign vintages is the same as the lifetime function derived 

for use in the life-cycle cost analysis. The derivation of all parameter values is described in 

chapter 8. 

0 

2 

4 

6 

8 

10 

12 

14 

20052003200119991997199519931991198919871985198319811979197719751973197119691967 

Year 

Households (weighted, in millions) 

Figure 7.3.2 Weighted Households by Refrigerator Vintage 

The survival probability was calculated as: 

⎛ ⎞β ⎜ x−θ ⎟ −⎜ ⎟ ⎜ α ⎟

P = e ⎝ ⎠ for x > θ

P = 1 for x ≤ θ Eq. 7.12 

Where: 

x = number of years (appliance age), 

7-15
 

EERE-2008-BT-STD-0012 COMMENT 22
α = 13.91, Weibull scale parameter, 

β = 1.68, Weibull shape parameter, and 

θ = 5, Weibull delay parameter. 

Figure 7.3.3 shows the survival probability curve for standard-sized refrigerators. 

16.18 

17.43 

0.0 

0.2 

0.4 

0.6 

0.8 

1.0 

1.2 

Fraction surviving 

Survival function 

Median lifetime 

Mean lifetime 

0 5 10 15 20 25 30 35 40 45 50 

Age (years) 

Figure 7.3.3 Survival Probability of Refrigerators by Age 

The same fitting technique was used for freezers. The scale, shape, and delay parameters 

for freezers are: 

α = 19.49, Weibull scale parameter, 

β = 2.40, Weibull shape parameter, and 

θ = 5, Weibull delay parameter. 

The survival curve for freezers ( Figure 7.3.4) does not fall off as quickly as does the one 

for refrigerators ( Figure 7.3.3), indicating a longer mean product lifetime. 

7-16
 

EERE-2008-BT-STD-0012 COMMENT 22
21.73 

22.28 

0.0 

0.2 

0.4 

0.6 

0.8 

1.0 

1.2 

Fraction surviving 

Survival function 

Median lifetime 

Mean lifetime 

0 5 10 15 20 25 30 35 40 45 50 

Age (years) 

Figure 7.3.4 Survival Probability of Freezers by Age 

A multistep process was followed to assign an age to a given refrigeration product in a 

REC household. First, the product’s age range (based on RECS bin) was compared with the 

Weibull delay parameter. For both refrigerators and freezers, the delay was fixed at 5 years, 

which falls between two RECS age bins. If the age bin contained appliances younger than the 

delay (in years), then an age within the bin was assigned randomly to the product, with no age 

preferred. If the bin contained appliances older (in years) than the delay, a survival value was 

selected randomly from within the range given for the relevant bin. For this purpose, each bin 

was assumed to extend to the beginning of the next bin. Table 7.3.6 shows the survival values 

assigned to household refrigerators by age bin. 

7-17
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

Table 7.3.6 Refrigerator Survival Probabilities Associated with Age Bins 

Age Bin Age years Survival Value 

Start Less than Start End 

1 0 2 NA NA 

2 2 5 NA NA 

3 5 10 1.000 0.8196 

4 10 20 0.8196 0.3051 

5 20 100 0.3051 0.0000 

The age of the unit was calculated from the assigned survival value using the inverse 

survival probability function: 

⎛ 1 ⎞ ⎜ ⎟

⎛ ⎛ 1 ⎞⎞⎜

⎜

⎜

β ⎟

⎟

⎟

Age = α × ⎝ ⎠ ⎜

⎜ln⎜ ⎟⎟

⎟ +θ Eq. 7.13 ⎝ ⎝ SP ⎠⎠

Where: 

SP = randomly selected survival value, 

α = Weibull scale parameter, 

β = Weibull shape parameter, and 

θ = Weibull delay parameter. 

After an age was assigned to the refrigerator or freezer, it was clear what efficiency 

standards and (if applicable) ENERGY STAR specifications were in effect when it was sold. 

7.3.3 Energy Use of Second Refrigerators 

When a household purchases a new refrigerator, some first units become second units. 

See chapter 8 for a discussion of how DOE modeled the conversion of refrigerators from first to 

second units. A second refrigerator, generally located in a basement or garage, enters a new 

operating environment and may be used less than year-round. For those units that become a 

second refrigerator, therefore, the annual energy consumption changes, presumably remaining at 

the new level for the rest of its lifetime. 

Field energy consumption for the first (FEC1) and second (FEC2) phases of a 

refrigerator’s lifetime can be expressed as: 

FEC1 = (UAF1 ×TECstd) Eq. 7.14 

Mon FEC2 = ( ×UAF ×TECstd) Eq. 7.15 12 2 

7-18
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Where: 

UAF1 = usage adjustment factor for first phase of the unit’s lifetime, 

UAF2 = usage adjustment factor for second phase,d 

TEC = test energy consumption, and 

Mon = number of months per year refrigerator is on. 

7.3.4 Estimated Number of ENERGY STAR Refrigerators 

As stated earlier, DOE used Eq. 7.2 to derive the UAF for RECS households likely to 

own an ENERGY STAR appliance. Although RECS 2005 provides information on ownership of 

ENERGY STAR refrigerators purchased between 2001 and 2005, the data seem to greatly 

overestimate the stock of ENERGY STAR refrigerators compared to data regarding shipments 

made during those years. DOE therefore developed a method that predicts ENERGY STAR 

ownership in the RECS sample based on annual average market shares of ENERGY STAR 

refrigerators and on household income. 

DOE based its approach on a study from Natural Resources Canada8

 that reported 

ENERGY STAR buyers based on three income categories. DOE assumed that the relative 

behavior of each income category is the same in the United States as for Canadian consumers. 

After matching the three income categories to RECS income bins, DOE assigned a probability of 

owning an ENERGY STAR unit to each household record as a function of its income. This 

probability was then scaled to reflect income levels in the RECS sample and national ENERGY 

STAR sales. The following equation was used. 

Estaryear = scaleyear × (Flow × P _ Estarlow + Fmid × P _ Estarmid + Fhigh × P _ Estarhigh) Eq. 7.16 

Where: 

Estaryear = percent of annual national refrigerator sales that were ENERGY STAR 

qualified; 

Flow|mid|high = percent of weighted number of RECS 2005 households in low, medium, 

and high income bins; 

P_Estar low|mid|high = probability of households in an income bin buying an ENERGY STAR 

appliance; and 

scaleyear = scaling factor to obtain the appropriate percent of ENERGY STAR 

refrigerators for each vintage. 

Table 7.3.7 shows the market shares of ENERGY STAR refrigerators (Estaryear), which 

were obtained from the ENERGY STAR program.9

 The market shares of ENERGY STAR 

freezers are estimates. 

d

 This UAF accounts for the changed operating environment during the second phase. 

7-19
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 7.3.7 Market Share of ENERGY STAR Products 

Year 1997 1998 1999 2000 2001 2002 2003 2004 2005 

Refrigerators 25.3% 19.0% 25.0% 27.0% 17.3% 20.1% 25.7% 33.2% 32.9% 

Freezers - - - - - - 10% 10% 10% 

The scaling factor for each year was calculated as: 

Estaryear scaleyear = Eq. 7.17 (Flow×P_ Estarlow+Fmid×P_ Estarmid+Fhigh×P_Estarhigh) 

A household in the low-income bin that purchased a refrigerator in a given year was a 

assigned a probability Scaleyear times P_Estar low for having an ENERGY STAR refrigerator. A 

similar approach was taken for households in the mid- and-high income bins. 

7.3.5 Validating Field Energy Consumption 

The values for refrigerator energy consumption reported in RECS 2005 ranged from 6 

kWh to more than 10,000 kWh for households having one refrigerator. DOE developed an 

approach that utilized the UAFs calculated for each household to confirm whether the reported 

values for refrigerators (and freezers) were reasonable. This approach required calculating 

maximum and minimum plausible UAFs for various refrigeration products. 

A range of possible UAFs can apply to a given refrigerator, based on the range of 

possible refrigerator sizes and ages consistent with the household’s RECS response. If the range 

of UAFs for a given household was entirely outside the boundaries of what DOE considered to 

be plausible, DOE excluded the household from the LCC analysis. Such outliers occur if the 

maximum possible UAF for a record is lower than the minimum plausible UAF or if the 

minimum UAF is higher than the maximum plausible UAF. 

If the range of UAFs for a given household intersected the range of plausible UAFs, the 

UAFs outside the boundaries were brought to the minimum or maximum plausible value. Thus, a 

household was not excluded from the sample if it had a plausible UAF. 

7.3.6 Maximum Usage Adjustment Factor 

To evaluate the maximum plausible UAF, DOE estimated the maximum plausible energy 

consumption of a refrigerator if it were running continuously. DOE’s calculation of the 

maximum electricity consumption assumes that the compressor runs constantly, comparable to 

leaving the door open 24 hours a day for 365 days a year. The evaporator and condenser fans, the 

interior lights, and the gasket heater (found only on refrigerators built before 1993) also were 

assumed to run continuously. DOE assumed that both the refrigerator and freezer compartment 

have a 20-W light bulb. The defrost cycle is often initiated based on the compressor run time. 

7-20
 

EERE-2008-BT-STD-0012 COMMENT 22
DOE assumed the defrost cycle runs for 10 minutes every 10 hours, which is the default input to 

the EPA’s refrigerator analysis (ERA) model.10 

Table 7.3.8 shows the power consumption and times DOE estimated for various 

components of each cycle for the ice maker. In real-world operation the compressor must run 

longer than indicated in Table 7.3.8 in order to extract the heat from the ice maker components, 

along with the latent heat of freezing from freezing water to make ice. To calculate the maximum 

theoretical electricity consumption, DOE assumed that the compressor already runs 

continuously, so there is no additional compressor run time. The components consume a total of 

6.3 Watt-hours per ice-making cycle.11 The value used for maximum ice-making cycles per day 

was nine.12 

Table 7.3.8 Power Consumption for Ice Maker Components 

Component Watts Length of Cycle 

Mold heater 185 2 minutes 

Solenoid valve 20 8 seconds 

Motorized ejector 3 2 minutes 

The formula for calculating the maximum plausible UAF is: 

(WComp +WFans +WLights +WGasket +WDefrost ×1.7%)×365× 24 /1000 + kWhIce MaxUAFpl = , TECSTD-EXIST-TP × ESAF 

Eq. 7.18 

Where: 

WComp = the power (in Watts) used by the compressor; 

WFans = the power (in Watts) used by the fans; 

WLights = the power (in Watts) used by the light; 

WGasket = the power (in Watts) used by the gasket heater; 

WDefrost = the power (in Watts) used by the defrost cycle, which is active 1.7 percent of 

the time 

kWhIce = the energy (in kWh) used to complete nine ice-making cycles per day 

(including mold heater, solenoid, and ejector) in one year; 

TECSTD-EXIST-TP = the test energy consumption; and 

ESAF = the efficiency standard adjustment factor. 

DOE collected the wattage for most components for the baseline models in several 

product classes from the Technical Support Documents (TSDs) developed in the analyses 

leading to the 2001 standard, the July 1995 notice of proposed rulemaking,13 and the November 

1989 final rule.14 The earlier TSDs (March 198215 and June 198016) did not report baseline 

energy use for the compressor. The documents, however, do report the amount of time the 

7-21
 

EERE-2008-BT-STD-0012 COMMENT 22
refrigerator was running during the test procedure. DOE calculated the maximum plausible 

annual energy consumption by (1) increasing the test procedure output to what it would be if the 

refrigerator were running continuously and (2) adding a continuously burning 40-W light bulb. 

The equation given above was used to calculate the maximum theoretical UEC and UAF 

for each baseline model in the TSDs. The theoretical maximum UAFs based on past TSDs for all 

of the analyzed product classes are shown in Tables 7.3.9 through 7.3.13. 

7-22
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 7.3.9 Theoretical Maximum Energy Consumption for Baseline Product Class 3 Refrigerator-Freeze

Baseline 

(TSD) Compressor 

W 

Evaporator 

Fan 

W 

Condenser 

Fan 

W 

Lights 

W 

Gasket Heater 

W 

Defrost 

W 

Defrost % 

Time On 

% 

Ice 

Making 

kWh 

Test 

Procedure 

kWh 

Ti

o

2001 124 4.5 4.5 40 0 450 1.7% 20.6 544 

Jul-95 145 9.1 12 40 0 450 1.7% 20.6 788 

Nov-89 186 10 13.5 40 19 450 1.7% 20.6 1,073 

Mar-82 - - - 40 - - - - 1,518 65

Jun-80 - - - 40 - - - - 1,805 53

* Unit Energy Consumption. † Usage adjustment factor. 

Table 7.3.10 Theoretical Maximum Energy Consumption for Baseline Product Class 5 Refrigerator-Freez

Baseline 

(TSD) Compressor 

W 

Evaporator 

Fan 

W 

Condenser 

Fan 

W 

Lights 

W 

Gasket 

Heater 

W 

Defrost 

W 

Defrost % 

Time On 

% 

Ice 

Making 

kWh 

Test 

Procedure 

kWh 

Tim

o

% 

2001 133 4.5 4.5 40 0 450 1.7% 20.6 573 

Jul-95 143 10.5 10.0 40 0 450 1.7% 20.6 845 - 

Nov-89 187 10.0 13.5 40 12 450 1.7% 20.6 1,324 - 

Mar-82 - - - 40 - - - - 2,209 63

* Unit Energy Consumption. † Usage adjustment factor 

7-23
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 7.3.11 Theoretical Maximum Energy Consumption for Baseline Product Class 7 Refrigerator-Freez

Baseline 

(TSD) 

Compressor 

W 

Evaporator 

Fan 

W 

Condenser 

Fan 

W 

Lights 

W 

Gasket 

Heater 

W 

Defrost 

W 

Defrost % 

Time On 

% 

Ice 

Making 

kWh 

Test 

Procedure 

kWh 

Tim

on 

% 

2001 141 8.0 4.5 40 0.0 450 1.7% 20.6 764 

Jul-95 150 8.0 11.6 40 0.0 450 1.7% 20.6 912 

Nov-89 186 10 14 40 - 0 1.7% 20.6 1,756 

Mar-82 - - - 40 - - - - 2,517 52

Jun-80 - - - 40 - - - - 2,422 53

Note: The Max UAF derived from the 1989 TSD does not agree with the rest of the sample, making the R2 drop from 0.99 to 0.41; 

thus it has been excluded from the regression. * Unit Energy Consumption. † Usage adjustment factor 

Table 7.3.12 Theoretical Maximum Energy Consumption for Baseline Product Class 9 Freezers 

Baseline 

(TSD) Compressor 

W 

Evaporator 

Fan 

W 

Condenser 

Fan 

W 

Lights 

W 

Gasket 

Heater 

W 

Defrost 

W 

Defrost % 

Time On 

% 

Test 

Procedure 

kWh 

Time 

on 

% 

Max 

UEC* 

kWh 

2001 119 4.5 0.0 20 0 450 1.7% 663 - 1,260 

Jul-95 126 9.0 0.0 20 0 450 1.7% 759 - 1,357 

Nov-89 169 10.0 0.0 20 9 450 1.7% 1,088 - 1,822 

Mar-82 - - - 20 - - - 1,303 81% 1,784 

Jun-80 - - - 20 - - - 1,332 87% 2,194 

* Unit Energy Consumption. † Usage adjustment factor 

7-24
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 7.3.13 Theoretical Maximum Energy Consumption for Baseline Product Class 10 Freezers 

Baseline 

(TSD) Compressor 

W 

Evaporator 

Fan 

W 

Condenser 

Fan 

W 

Lights 

W 

Gasket 

Heater 

W 

Defrost 

W 

Defrost % 

Time On 

% 

Test 

Procedure 

kWh 

Time 

on 

% 

Max 

UEC 

kWh 

2001 85 0 0 20 0 0 0.0% 394 - 916 

Jul-95 101 0 0 20 0 0 0.0% 472 - 1,059 

Nov-89 187 0 0 20 0 0 0.0% 557 - 1,813 

Mar-82 - - - 20 - - - 1,215 80% 1,695 

Jun-80 - - - 20 - - - 1150 69% 1842 

Note: The Baseline model from the 1989 TSD was excluded because its compressor power was 100 W higher than to be expected if it fthe trend in W/cu ft between 1995 and 2001. 

7-25
 

EERE-2008-BT-STD-0012 COMMENT 22
0

0.5

1

1.5

2

2.5

3

3.5

0 5 10 15 20 25

M

a

x

U

A

F

Age

PC3

PC5

PC7

PC9

PC10

The maximum annual energy consumption allowed by a given standard scales linearly 

with volume. DOE assumed that in the extreme case used to determine the maximum plausible 

energy consumption, annual energy consumption also scales linearly with volume. Therefore, the 

maximum theoretically possible UAF is constant for each production year and product class, 

regardless of volume. 

Older refrigerators generally had low maximum plausible UAFs. As the minimum 

efficiency allowed by standards increased, compartments became better insulated and the 

refrigeration cycle more efficient. The compressor therefore uses less energy to maintain 

conditions inside the cabinet and so runs for less time. Ordinary test procedure operation thus 

represents a smaller and smaller fraction of the extreme, all-out energy consumption used in the 

calculations described in this section. Thus, the test procedure energy use (TEC) for older 

refrigerators is closer to their maximum theoretically possible field energy consumption than it is 

for newer refrigerators. 

The maximum theoretically possible UAF (MaxUAF) scales linearly with age, as shown 

in Figure 7.3.5. 

Figure 7.3.5 Maximum Usage Adjustment Factor by Product Age in 2005 

7-26
 

EERE-2008-BT-STD-0012 COMMENT 22
DOE performed a linear regression to fit MaxUAF by vintage, thus providing a value of 

MaxUAF for a unit of any age. Table 7.3.14 shows the intercept and slope of the regression line 

for MaxUAF for each product class. The quality of the linear fit from the regression for each 

product class is shown by the R2

 value. 

Table 7.3.14	 Regression Parameters by Product Class for Maximum Usage Adjustment 

Factor 

Product 

Class Description Slope Intercept R2 

3 Top-mount refrigerator-freezer -0.0554 3.0796 0.9033 

5 Bottom-mount refrigerator-freezer -0.0733 3.0835 0.9298 

7 Side-by-side refrigerator-freezer with 

TTD ice service -0.0307 2.4140 0.9033 

9 Upright freezer -0.0187 1.9671 0.6832 

10 Chest freezer -0.0434 2.5638 0.9034 

DOE compared the MaxUAF value to the smallest possible UAF for the refrigerator for 

each RECS record to determine whether the household’s refrigerator energy use was plausible 

and the RECS record should be retained in the analysis. 

7.3.7 Minimum Usage Adjustment Factor 

To estimate the least plausible UAF, DOE used EPA’s refrigerator analysis (ERA) 

model.10 DOE used the default models in ERA for product classes 3 and 10. Values for the other 

product classes were derived from the default models for those product classes. DOE assumed 

that product classes 3 and 5 have identical minimum UAFs. 

For each year a TSD was published, DOE modified the ERA input file to better match the 

characteristics of the baseline model described in the TSD. Then the ERA model was run under 

test procedure conditions and under very favorable conditions (such as in an air-conditioned 

kitchen or a basement). The temperature settings for the compartments were assumed to be the 

maximum allowed by the ERA model. DOE also assumed that any gasket heater was turned off. 

Tables 7.3.15 and 7.3.16 show the temperature settings used to model both these “ideal” 

conditions and test conditions. 

Table 7.3.15 Temperature Settings for Refrigerators Under Test and Ideal Conditions 

Ambient 

Temp. 

Air Entering 

Condenser 

Air Under 

Cabinet 

Fresh Food 

Compartment 

Freezer 

Compartment 

Test 

Conditions 

32.2 °C 

(90.0 °F) 

37.8 °C 

(100.0 °F) 

35 °C 

(95.0 °F) 

7.22 °C 

(45.0 °F) 

-15 °C 

(5.0 °F) 

Ideal 

Conditions 

17 °C 

(62.6 °F) 

19 °C 

(66.2 °F) 

19 °C 

(66.2 °F) 

10 °C 

(50.0 °F) 

-2 °C 

(28.4 °F) 

7-27
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

Table 7.3.16 Temperature Settings for Freezers Under Test and Ideal Conditions 

Ambient 

Temp. 

Air Entering 

Condenser 

Air Under 

Cabinet 

Freezer 

Compartment 

Test 

Conditions 32.2 °C (90.0 °F) 37.8 °C (100.0 °F) 35 °C (95.0 °F) -17.8 °C (0.0 °F) 

Ideal 

Conditions 12 °C (53.6 °F) 14 °C (57.2 °F) 14 °C (57.2 °F) -9.99 °C (14.0 °F) 

In order to validate the model, DOE compared the ERA simulation model under test 

procedure conditions to the results of the test procedure reported in each TSD. In addition to the 

temperatures listed in Tables 7.3.15 and 7.3.16, the other control settings during the test were: 

• Defrost controls were not operative during the test procedure. 

• Anti-sweat heater switch was set to the position that consumes the maximum energy. 

The 1995 TSD also mentions a correction factor to adjust the ERA model results based 

on the tested consumption. Correction factors for DOE’s modeling for this analysis, as well as 

the values cited in the 1995 TSD, are listed in Table 7.3.17. If the error percentage is greater than 

0, it means that the ERA model overestimated the energy use in the test procedure, and the value 

of CAL in Eq. 7.19 is greater than 1. 

Table 7.3.17 Model Errors by Product Class and Vintage 

Product Class DOE % Error Estimate from 1995 

1989 1995 2001 TSD %

Top-Mount 5.93 4.14 22.29 5.93 

Side-by-Side 12.15 5.16 8.54 12.15 

Upright Freezer 19.67 15.54 17.74 19.67 

Chest Freezer 0.64 12.11 11.84 0.64 

The simulation models produced the same range of error as those specified in the 1995 

TSD. When calculating the minimum UAF, this calibration factor cancels out, as shown in the 

following equation, because the ERA model also over-estimates the energy use in the ideal 

conditions by the same factor. DOE defined the minimum plausible UAF as: 

FEC Ideal RECS FECERA CAL MinUAF = = Eq. 7.19 TEC × ESAF TEC × ESAF ERA RECS 

CAL 

Where: 

FECIdeal_ERA = minimum field energy consumption modeled in ERA under ideal conditions, 

TECERA = test energy consumption modeled in ERA under existing test procedure 

conditions, 

FECRECS = field energy consumption of the RECS record, 

7-28
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

TECRECS = test consumption calculated based on the volume and age designated for the 

UAF calculation, 

CAL = calibration factor defined by the ratio between the results from the ERA model 

and the test procedure, 

ESAF = efficiency standard adjustment factor. 

Figure 7.3.6 shows the results of calculating the minimum plausible UAF as a function of 

vintage. 

0.00 

0.05 

0.10 

0.15 

0.20 

0.25 

0.30 

0.35 

0.40 

0 5 10 15 20 

M 

i

n 

U

A

F 

Age 

Top Mount 

Side by Side 

Chest Freezer 

Upright Freezer 

Figure 7.3.6 Minimum Plausible Usage Adjustment Factor as a Function of 

Product Age in 2005
 

DOE performed a linear regression for each product class in order to model the relation 

between the minimum UAF and the vintage of a unit. The following table shows the resulting 

parameters. 

7-29
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 7.3.18 Regression Results Based on Unit Vintage 

Product Class Slope Intercept R2 

Top-Mount -0.0048 0.2496 0.909 

Side-by-Side -0.0033 0.2356 0.8022 

Upright Freezer -0.0025 0.3000 0.8107 

Chest Freezer -0.0055 0.3325 0.6448 

DOE assumed that minimum UAFs are constant across volumes, that bottom-mount and 

top-mount products have the same minimum UAF, and that through-the-door ice service does 

not affect the minimum UAF. 

7.3.8 Results by Product Class 

Figures 7.3.7 through 7.3.16 show the distribution of UAFs for the RECS households in 

the subsample that represents each standard-sized product class. Each figure shows the 

distribution of UAFs before and after the truncation produced by applying the minimum and 

maximum UAFs. The distribution used for LCC analysis is the distribution after removing 

households having implausible UAFs. 

7-30
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Frequency Chart 

.000 

.006 

.013 

.019 

.025 

0 

62.5 

125 

187.5 

250 

0. 117 0. 754 1. 391 2. 027 2. 664 

10,000 Trials 9, 800 Displ ayed 

Forecast : UAF (1) 

Figure 7.3.7 Initial UAF Distribution for Standard-Size Top-Mount 

Refrigerator-Freezers (Product Class 3) 

Frequency Chart 

.000 

.007 

.013 

.020 

.027 

0 

66.5 

133 

199.5 

266 

0. 181 0. 804 1. 427 2. 050 2. 673 

10,000 Trials 9, 858 Displ ayed 

Forecast : UAF (1) 

Figure 7.3.8 Final UAF Distribution for Standard-Size Top-Mount 

Refrigerator-Freezers (Product Class 3) 

7-31
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Frequency Chart 

.000 

.007 

.014 

.020 

.027 

0 

68.25 

136.5 

204.7 

273 

0. 153 0. 708 1. 263 1. 818 2. 373 

10,000 Trials 9, 853 Displ ayed 

Forecast : UAF (1) 

Figure 7.3.9 Initial UAF Distribution for Standard-Size Bottom-Mount 

Refrigerator-Freezers (Product Class 5) 

Frequency Chart 

.000 

.006 

.013 

.019 

.025 

0 

63 

126 

189 

252 

0. 137 0. 698 1. 258 1. 818 2. 379 

10,000 Trials 9, 899 Displ ayed 

Forecast : UAF (1) 

Figure 7.3.10 Final UAF Distribution for Standard-Size Bottom-Mount 

Refrigerator-Freezers (Product Class 5) 

7-32
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Frequency Chart 

.000 

.006 

.012 

.019 

.025 

0 

62 

124 

186 

248 

0. 199 0. 833 1. 467 2. 100 2. 734 

10,000 Trials 9, 889 Displ ayed 

Forecast : UAF (1) 

Figure 7.3.11 Initial UAF Distribution for Standard-Size Side-by-side 

Refrigerator-Freezers (Product Class 7) 

Frequency Chart 

.000 

.005 

.011 

.016 

.021 

0 

53 

106 

159 

212 

0. 233 0. 778 1. 323 1. 869 2. 414 

10,000 Trials 9, 997 Displ ayed 

Forecast : UAF (1) 

Figure 7.3.12 Final UAF Distribution for Standard-Size Side-by-side 

Refrigerator-Freezers (Product Class 7) 

7-33
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Frequency Chart 

.000 

.006 

.012 

.018 

.024 

0 

60.5 

121 

181.5 

242 

0. 372 1. 234 2. 096 2. 958 3. 820 

10,000 Trials 9, 825 Displ ayed 

Forecast : UAF (1) 

Figure 7.3.13 Initial UAF Distribution for Standard-Size Upright Freezers 

(Product Class 9) 

Frequency Chart 

.000 

.010 

.020 

.030 

.040 

0 

99.25 

198.5 

297.7 

397 

0. 331 0. 736 1. 140 1. 544 1. 948 

10,000 Trials 9, 919 Displ ayed 

Forecast : UAF (1) 

Figure 7.3.14 Final UAF Distribution for Standard-Size Upright Freezers 

(Product Class 9) 

7-34
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Frequency Chart 

.000 

.006 

.012 

.018 

.024 

0 

59.25 

118.5 

177.7 

237 

10,000 Trials 9, 885 Displ ayed 

Forecast : UAF (1) 

0.103 1.416 2.729 4.042 5.356 

Figure 7.3.15 Initial UAF Distribution for Standard-Size Chest Freezers 

(Product Class 10) 

Frequency Chart 

.000 

.008 

.017 

.025 

.034 

0 

84 

168 

252 

336 

0. 343 0. 898 1. 453 2. 008 2. 564 

10,000 Trials 10,000 Di spl ayed 

Forecast : UAF (1) 

Figure 7.3.16 Final UAF Distribution for Standard-Size Chest Freezers 

(Product Class 10) 

The maximum plausible UAF limits the freezer sample more than the refrigerator-freezer 

sample. The maximum is more restrictive for freezers because their compressors are assumed to 

run more than 80 percent of the time in normal operation, as opposed to 52 percent to 65 percent 

of the time for refrigerators. As a result, increasing appliance energy use to its theoretical 

maximum, to reflect a compressor that runs 100 percent of the time, has a smaller effect for 

freezers. RECS also has a simpler model for estimating household energy use for freezers than it 

does for refrigerator-freezers, which may contribute to the wide range of energy consumption 

assigned to freezers across the household sample. The minimum and maximum UAF thresholds 

enabled DOE to remove from the sample households having unrealistic freezer energy 

consumption. 

7-35 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 7.3.19 summarizes the characteristics of the UAFs before and after the final sample 

was selected. 

Table 7.3.19 Usage Adjustment Factors Before and After Excluding Minimums and 

Maximums 

Product Class 

Complete RECS Sample 

After Selecting Sample Based On 

Min and Max Plausible UAF 

Mean 

UAF 

Min 

UAF 

Max 

UAF 

Sample 

Size 

Mean 

UAF 

Min 

UAF 

Max 

UAF 

Sample 

Size 

Top-mount 

refrigerator-freezer 1.254 0.115 4.203 2,303 1.227 0.134 3.08 2,231 

Bottom-mount 

refrigerator- freezer 1.079 0.097 3.155 2,303 1.077 0.134 2.888 2,242 

Side-by-side 

refrigerator-freezer 1.46 0.17 4.219 1,026 1.437 0.201 2.414 871 

Upright freezer 1.7988 0.324 5.367 248 1.37 0.316 1.967 170 

Chest freezer 2.248 0.103 7.795 369 1.479 0.343 2.564 243 

7.3.9 Distributions: Comparison with Other Studies 

The variation in UAFs within the national RECS sample has several causes, including 

indoor temperature, appliance age, and varying usage patterns. Meier et al.17 and Miller and 

Pratt18 indicate that refrigerator energy use varies significantly in response to ambient 

temperature, which implies that climate contributes to variation in household energy use. In 

addition, refrigerators generally use more energy as they age, 19 and the RECS sample includes 

appliances having a wide range of ages. Household choices regarding the frequency of door 

opening and how often and how much warm food is loaded into the unit, along with the ambient 

temperature in the kitchen, likely add to variability. In addition, the DOE test procedure does not 

measure energy consumed by ice making, so it is not reflected in the labeled energy 

consumption. The presence or absence of an automatic ice maker, as well as variation in the 

amount of ice made, also contribute to the variation in UAF within and between product classes. 

In addition to their significant width, the UAF distributions shown in Figures 7.3.7 

through 7.3.16 do not have a mean value of 1, indicating that the average energy use for a 

refrigerator drawn from the American residential stock differs from the labeled energy use of that 

same refrigerator when it was new. This result is consistent with reports in the literature. A full 

literature survey, available in appendix 7-A, is summarized here. Refrigerator energy use may be 

characterized by three measures: 

(A) the label on the product when new, derived from the DOE test procedure; 

7-36 

EERE-2008-BT-STD-0012 COMMENT 22
(B) the results of the DOE test procedure on a particular appliance after it has been used 

in the field; and 

(C) the in situ (ideally directly measured) energy consumption in a user’s home. 

The UAF for a given refrigerator is the ratio of (C) to (A). Studies described in the 

literature examined two classes of refrigerators: new or likely new (installed in new homes), for 

which the usual comparison is (C) to (A); and recycled/disposed refrigerators, for which all 

possible pairs of measures have been compared. 

Studies of new (or likely new) refrigerators in consumers’ homes reveal a wide variation 

in energy use among consumers. The mean energy consumption cited in those studies lies within 

40 percent of the appliance label.20 The literature indicates that refrigerators in cooler climates 

tend to use less energy than their labeled energy consumption,19 whereas those in warmer 

locations tend to use more energy than labeled. This difference contributes to the width of the 

national UAF distributions. 

Studies of non-new refrigerators generally examine refrigerators collected as part of early 

replacement programs operated by electric utilities. Such studies are used to measure the effect 

of the utility program and to obtain credit for the energy reductions resulting from replacing old 

appliances. The non-new refrigerators described in the literature, which must be in use by their 

owners, commonly are relatively old. Measurements, both in situ and from the DOE test 

procedure, show these refrigerators use significantly more energy than the labeled consumption. 

KEMA21 used the DOE procedure to test 136 such refrigerators. This comparison of (B) to (A) 

isolates the effect of age from those of user behavior or environment. KEMA found that the 

median increase in energy consumption relative to labeled use was 46 percent, and that roughly 

15 percent of the sample used more than twice the labeled energy. Only 7 percent of the sample 

used less than labeled. When Peterson et al.22 combined the data from several studies (of a total 

of 193 recycled refrigerators), they found that the average increase in energy consumption, as 

measured by the DOE test procedure, was 50 percent, with 25 percent of refrigerators using more 

than 1.7 times their labeled energy. Miller and Pratt18 performed a regression analysis on in-use 

refrigerators in New York public housing [a (C) to (A) comparison], deducing an average 1.4­

percent increase in energy use per year. These studies indicate that the UAF distribution for old 

refrigerators is expected to be wide and to have a mean significantly higher than 1. 

Several aspects of in-use refrigerator operation are not reflected in the DOE test 

procedure and therefore affect the UAF. In particular, the DOE test does not measure the energy 

used by ice makers. Estimates of the effect of this omission range from 5 percent to 26 percent,11 

with a rough estimate of 10 percent being common and consistent with published direct 

measurements. Through-the-door (TTD) ice making may consume more energy than non-TTD 

ice making. DOE therefore expects the UAF distribution from product classes that include TTD 

ice makers to have a somewhat higher mean than classes that do not. The size of the difference 

depends on the fraction of non-TTD refrigerators that use ice makers, and the possible difference 

in ice-making behavior among users of various product classes. Meier and Martinez11 also report 

that ice-making energy may increase over time, compounding the increased energy use with age. 

7-37
 

EERE-2008-BT-STD-0012 COMMENT 22
A national sample of refrigerators, such as RECS, covers refrigerators in various climate 

zones and of various ages. As such, DOE expects those two factors (as well as behavioral 

differences among users) to produce significant scatter in the UAF. If new refrigerators use 

energy at close to their labeled rate as determined by the DOE test, and refrigerators at retirement 

use significantly more energy when tested using the same procedure, the national mean UAF is 

expected to be greater than 1. DOE could not conclude from the literature that a particular value 

or distribution should be assigned to the UAF, Therefore, DOE cannot justify further adjusting 

the UAF distribution derived from RECS. 

7.4 ENERGY USE OF COMPACT REFRIGERATION PRODUCTS 

As mentioned in the introduction to this chapter, compact refrigerators and freezers are 

used in homes, college dormitories, hotels and motels, and some commercial buildings. DOE 

found no data on the typical field energy consumption of compact refrigeration products. It 

therefore assumed that the average field energy use of compact refrigerators and freezers of a 

given size is the same as the maximum energy use allowed by the DOE standard, as measured in 

the DOE test procedure. In effect, DOE assumed that variation in field energy use of compact 

products is a function solely of volume. To represent the distribution of volumes in the field, 

DOE used data from the 2008 CEC appliance model database.2 Figures in appendix 7-B show 

the distribution of appliance sizes represented within the database. 

DOE used the CEC database to develop a linear equation relating listed total volume to 

adjusted volume for product class 11. The parameters of the equation are listed in Table 7.4.1. 

For compact freezers, the adjusted volume is equal to 1.73 times the volume.3

 DOE then used the 

relation between adjusted volume and energy use described by the DOE test procedure to relate 

the distribution of volumes in the CEC database to a distribution of energy use values. 

Table 7.4.1 Parameters for Calculating Adjusted Volume from Total Volume for Compact 

Refrigerators 

Product Category Slope Intercept R2 Count 

Compact Refrigerators 1.0458 -0.0905 0.9822 187 

7.5 ANNUAL ENERGY CONSUMPTION BY EFFICIENCY LEVEL 

This section reports the annual field energy consumption calculated for refrigeration 

products that meet new efficiency standards if they were used in RECS 2005 homes. As 

described in section 7.2, DOE calculated field-adjusted annual energy consumption for each 

home’s refrigeration product by multiplying the tested energy consumption of a new 

refrigeration product, measured using the existing test procedures, by the efficiency standard 

adjustment factor (ESAF), which is a constant for each product class, and by the UAF for that 

household. 

7-38
 

EERE-2008-BT-STD-0012 COMMENT 22
As discussed in chapter 5, DOE analyzed specific efficiency levels for the considered 

product classes. Tables 7.5.1 through 7.5.6 show the considered efficiency levels and 

corresponding annual energy consumption for each product class. The tables for standard-sized 

products show the average annual energy consumption according to the proposed DOE test 

procedure (“proposed test”) and in the average energy use based on the corresponding RECS 

2005 household subsamples (“field”). The tables for compact appliances (product classes 11 and 

18) show the average annual energy consumption according to the proposed DOE test procedure, 

using a distribution of product volumes based on the CEC appliance database. 

Table 7.5.1 Product Class 3, Top-Mount Refrigerator-Freezers Without Through-theDoor Ice Service: Average Annual Energy Use by Efficiency Level 

Efficiency Level 

(percent less than baseline 

energy use) 

Proposed Test Field 

kWh/year kWh/year 

Baseline 534 657 

1 (10%) 481 591 

2 (15%) 454 558 

3 (20%) 428 526 

4 (25%) 401 493 

5 (30%) 374 460 

6 (35%) 347 427 

7 (40%) 321 394 

8 (45%) 294 361 

7-39
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 7.5.2 Product Class 5, Bottom-Mount Refrigerator-Freezers Without Through-theDoor Ice Service: Average Annual Energy Use by Efficiency Level 

Efficiency Level 

(percent less than baseline 

energy use) 

Proposed Test Field 

kWh/year kWh/year 

Baseline 652 699 

1 (10%) 587 629 

2 (15%) 554 594 

3 (20%) 522 559 

4 (25%) 489 524 

5 (30%) 456 489 

6 (35%) 424 454 

7 (40%) 391 419 

8 (45%) 359 384 

Table 7.5.3 Product Class 7, Side-by-side Refrigerator-Freezers with Through-the-Door 

Ice Service: Average Annual Energy Use by Efficiency Level 

Efficiency Level 

(percent less than baseline 

energy use) 

Proposed Test Field 

kWh/year kWh/year 

Baseline 756 1087 

1 (10%) 680 979 

2 (15%) 643 924 

3 (20%) 605 870 

4 (25%) 567 815 

5 (30%) 529 761 

6 (35%) 491 707 

7 (40%) 454 652 

7-40
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 7.5.4 Product Class 9, Upright Freezers: Average Annual Energy Use by Efficiency 

Level 

Efficiency Level 

(percent less than baseline 

energy use) 

Proposed Test Field 

kWh/year kWh/year 

Baseline 717 980 

1 (10%) 646 882 

2 (15%) 610 833 

3 (20%) 574 784 

4 (25%) 538 735 

5 (30%) 502 686 

6 (35%) 466 637 

7 (40%) 430 588 

8 (45%) 394 539 

Table 7.5.5 Product Class 10, Chest Freezers: Average Annual Energy Use by Efficiency 

Level 

Efficiency Level 

(percent less than baseline 

energy use) 

Proposed Test Field 

kWh/year kWh/year 

Baseline 428 623 

1 (10%) 385 561 

2 (15%) 364 530 

3 (20%) 342 498 

4 (25%) 321 467 

5 (30%) 300 436 

6 (35%) 278 405 

7 (40%) 257 374 

8 (45%) 235 343 

7-41
 

EERE-2008-BT-STD-0012 COMMENT 22
Table 7.5.6 Compact Refrigerators and Freezers: Average Annual Energy Use by 

Efficiency Level 

Efficiency Level 

(percent less than 

baseline energy use) 

Product Class 

11: Compact refrigerators and 

refrigerator-freezers with manual defrost 

(kWh) 

18: Compact chest freezers 

(kWh) 

Baseline 325 313 

10% 292 282 

15% 276 266 

20% 260 250 

25% 244 235 

30% 227 219 

35% 211 203 

40% 195 188 

45% 179 172 

7-42
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

REFERENCES 

1	 U.S. Department of Energy–Energy Information Administration. Residential Energy 

Consumption Survey, 2005 Public Use Data Files. 2009. U.S. Department of Energy: 

Washington, D.C. <www.eia.doe.gov/emeu/recs/recspubuse05/pubuse05.html> 

2	 California Energy Commission. Appliances Database—Refrigeration. 

<www.energy.ca.gov/appliances/database/excel_based_files/Refrigeration/> (Last accessed April 25, 

2009.) 

3	 Title 10—Energy, Chapter II—Department of Energy, Part 430—Energy Conservation 

Program for Consumer Products, Subpart B—Test Procedures, Appendix A1 and B1. 

4	 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Energy 

Conservation Program for Consumer Products: Proposed Rulemaking Regarding Energy 

Conservation Standards for Refrigerators, Refrigerator-Freezers, and Freezers. Federal 

Register. July 20, 1995. 60 FR 37388. 

5	 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Energy 

Conservation Program for Consumer Products: Energy Conservation Standards for 

Refrigerators, Refrigerator-Freezers, and Freezers; Final Rule. Finding of No Significant 

Impact; Notice. Federal Register. April 28, 1997. 62 FR 23102. 

<www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/refrig_final.pdf> 

6	 U.S. Environmental Protection Agency and U.S. Department of Energy. Revision of the 

ENERGY STAR Criteria for Residential Refrigerators and Freezers. (Last accessed April 25, 

2009.) <www.energystar.gov/index.cfm?c=revisions.res_refrig_spec> 

7	 U.S. Environmental Protection Agency. Maintaining the Value of ENERGY STAR: 2006 

Report. [U.S. EPA: Washington, D.C.] 

8	 Ipsos-Reid Corporation. Tracking Study: Awareness of ENERGY STAR/EnerGuide Symbols 

Final Report. Natural Resources Canada. September 2006 

9	 Karney, R. ENERGY STAR Criteria for Refrigerators: Overview of ENERGY STAR Criteria 

Setting Process and History of Refrigerator Criteria. June 4, 2007. (Last accessed April 15, 

2009.) 

<www.energystar.gov/ia/partners/prod_development/revisions/downloads/refrig/Karney_Ref 

rigeratorCriteriaRevision_6.4.07.pdf> 

10	 Merriam R., Verone A., Feng H. EPA Refrigerator Analysis (ERA) Program: User's Manual 

Version 1.0, Cambridge, MA: Arthur D. Little Inc. March 1993. 

7-43 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

11	 Meier, A. and M. Martinez. Energy Use of Icemaking in Domestic Refrigerators. ASHRAE 

Transactions: Symposia. 1996. AT-96-19-2. 

12	 Parker, D. and T. Stedman. Measured Electricity Savings of Refrigerator Replacement: Case 

Study and Analysis. ACEEE 1992 Summer Study on Energy Efficiency in Buildings, 

Proceedings—Commercial Performance: Analysis and Measurement Panel 3. 1992. 

American Council for an Energy-Efficient Economy. 

13	 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Energy 

Conservation Program for Consumer Products: Technical Support Document: Energy 

Efficiency Standards for Consumer Products: Refrigerators, Refrigerator-Freezers, and 

Freezers. July 1995. Washington, D.C. 

14	 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Energy 

Conservation Program for Consumer Products: Technical Support Document: Energy 

Efficiency Standards for Consumer Products: Refrigerators and Furnaces. November 1989. 

Washington, D.C. 

15	 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Consumer 

Products Efficiency Standards: Engineering Analysis Document. March 1982. Washington, 

D.C. DOE/CE-0030. 

16	 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Consumer 

Products Efficiency Standards: Engineering Analysis. June 1980. Washington, D.C. 

DOE/CE-0166. 

17	 Meier. A., A. Megowan, B. Litt, and B. Pon. The New York State Residential Refrigerator 

Electrical Energy Monitoring Project: Final Report. 1993. Lawrence Berkeley National 

Laboratory: Berkeley, CA. Report No. LBL-33708. 

18	 Miller, J.D. and R.G. Pratt. Estimates of Refrigerator Loads in Public Housing Based on 

Metered Consumption Data. 1998. Pacific Northwest National Laboratory. Report No. 

PNNL-11991. 

19	 Meier, A.. and R. Jansky. Field Performance of Residential Refrigerators: A Comparison 

with the Laboratory Test. 1991. Lawrence Berkeley Laboratory: Berkeley, CA. Report No. 

LBL-31795. 

20	 Meier, A. “Refrigerator Energy Use in the Laboratory and in the Field.” Energy and 

Buildings. 1995. 22: pp. 233–243. 

21	 KEMA. 2004. 2003 EM&V RARP Study:Degradation and Market Potential Analysis. 

Prepared for Southern California Edison, Rosemead, CA. Prepared by KEMA Inc., Madison, 

7-44 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

WI. December 23, 2004. CALMAC STUDY ID SCE0205 ma:project:scee0015 rarp 03 

evaluation:report:title. 

22	 Peterson, J., D. Dohrmann, T. Alereza, S. Samiullah, S. Westberg, and J.H. Redd. Gross 

Savings Estimation for Appliance Recycling Programs: the Lab Versus in situ Measurement 

Imbroglio and Related Issues. Proceedings of the 2007 International Energy Performance 

Evaluation Conference (IEPEC). 2007. Chicago, IL. August. Report 653. 17 pp. 

7-45 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 7-A. LITERATURE SURVEY OF ENERYG CONSUMPTION BY 

RESIDENTIAL REFRIGERATOR-FREEZERS 

TABLE OF CONTENTS 

7-A.1 INTRODUCTION .................................................................................................7-A-1 

7-A.2 TEST PROCEDURE AND FIELD STUDIES......................................................7-A-2 

7A.2.1 DOE Test Procedure ..............................................................................................7-A-2 

7A.2.2 Field Studies...........................................................................................................7-A-3 

7A.2.2.1 KEMA-Xenergy Findings....................................................................7-A-3 

7-A.3 LITERATURE ANALYSIS ..................................................................................7-A-5 

7-A.4 SUMMARY...........................................................................................................7-A-6 

7-A.5 BIBLIOGRAPHY..................................................................................................7-A-6 

LIST OF TABLES 

Table 7-A.2.1 Refrigerator Energy Consumption Data by Year.......................................7-A-3 

Table 7-A.2.2 Literature summary....................................................................................7-A-4 

7A-i 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 7-A. LITERATURE SURVEY OF ENERGY CONSUMPTION BY 

RESIDENTIAL REFRIGERATOR-FREEZERS 

7-A.1 INTRODUCTION 

Efficient refrigerator-freezers reduce peak energy consumption as well as total household 

energy use. As a result, electric utilities regard replacement programs for these appliances as an 

attractive and effective way to reduce residential energy consumption. To estimate the amount of 

electricity savings attributable to an energy-efficient refrigerator-freezer program, utilities must 

evaluate the difference between the pre- and post-program energy consumption of the appliance 

stock. The challenge to accurately estimate the electricity savings of a refrigerator-freezer 

replacement program lies in estimating the real-life consumption of the original and replacement 

units. 

Estimation of appliance energy consumption may be undertaken in three ways, all of 

which are represented in the literature: 

A) The labeled energy consumption on a new appliance, based on the U.S. Department 

of Energy (DOE) test procedure undertaken on a sample of several identical 

appliances, and reported by the appliance manufacturer 

B) The DOE test procedure applied to a particular appliance (often not a new appliance), 

and 

C) Measurement for some period of time in situ in a household. 

Most studies compare two of these measurements in order to evaluate energy use. For example, 

a study might compare the results of the DOE test procedure on an old refrigerator with the 

labeled energy consumption when new to isolate the effect of appliance age, while eliminating 

possible effects due to user behavior. This appendix refers to such a study as comparing (B) to 

(A). 

Researchers have conducted studies that measure the field consumption of refrigeratorfreezers to compare in situ measurements to the DOE test results, represented either by the 

labeled results ((C) to (A)), or through direct testing under DOE conditions ((C) to (B)). When 

such field studies are evaluated, the lack of consistency among study conditions (such as 

geographic location, housing type, and the number and type of units), limited time of direct 

measurements, and the degradation of efficiency throughout the lifetime of a refrigerator-freezer 

contribute to the challenge of estimating potential energy consumption savings from new units. 

This appendix summarizes available literature regarding the comparison of different 

measurement methods for refrigerator-freezers in order to evaluate reasonable possible values for 

the ‘usage adjustment factor’ (UAF), which is an estimate of the ratio of (C) to (A). There are 

very few published measurements of freezers or compact appliances, so DOE addresses only 

refrigerator-freezers in this summary. Section 2 summarizes the DOE test procedure and lists and 

characterizes the field studies which DOE used in its analyses. Section 3 discusses these studies 

and their implications for the UAF parameter used in Chapter 6, particularly regarding variation 

with season and climate, and efficiency degradation with unit age. 

7-A-1 

EERE-2008-BT-STD-0012 COMMENT 22
7-A.2 TEST PROCEDURE AND FIELD STUDIES 

This section describes the DOE test procedure, then lists field studies of energy 

consumption by refrigerator-freezers and distills their results. 

7A.2.1 DOE Test Procedure 

“The DOE test is a compromise between realism and minimizing the costs of performing 

a reliable, repeatable laboratory test” (Meier, 1993). The DOE procedure for evaluating the 

annual energy consumption of refrigerator-freezers comprises the following features (10 CFR, 

Chapter II, Part 430, Appendix A1). 

•	 The standard test temperature for the fresh food compartment is 45°F. 

•	 The standard test temperature for the freezer compartment is 5°F. 

•	 The test is performed in a chamber that is maintained at an ambient temperature of 90°F. 

•	 The temperatures of the freezer and fresh food compartments are measured using three 

independent thermocouples, one for each compartment. Five thermocouples are used 

when the refrigerator height is over 40”. 

•	 The appliance’s energy consumption is calculated by interpolating test results that 

bracket the standard freezer temperature (5°F). Interpolation is done around the 5°F 

temperature (freezer compartment) and the 45°F temperature (fresh food compartment). 

•	 Ambient relative humidity is not specified. 

•	 Doors are not opened during the test. 

•	 The fresh food and freezer compartments are empty. 

•	 Ice making capability, if present, is not powered on or evaluated by the test. 

The DOE test procedure is currently undergoing a rulemaking process which may change 

some of the above details. In particular, changes have been proposed to the test temperatures for 

the refrigerator and freezer compartments. 

The DOE test procedure does not measure the effects of door opening, cooling warm 

food, or ice making. However, this test procedure provides standardized results that can serve as 

the basis for comparing the performance of appliances. Although the DOE test does not precisely 

mirror any single unit’s performance in situ, it serves as a foundation to which field 

measurements may be compared to develop estimates that account for a range of real-life 

circumstances (KEMA, 2004). 

A summary of new refrigerator-freezer unit energy consumption values provided by 

manufacturers by year shows the annual variation of shipment-weighted refrigerator energy 

consumption from 1960s to the year 2006 (Table 2.1). These data are based on “nameplate” 

values. For the model years before the DOE energy standards (1989 and earlier), the test 

conditions are unknown in which energy consumption quantities were measured, although it is 

likely that manufacturers used the American Home Appliance Manufacturers (AHAM) test 

procedure or the test procedure prescribed by California state energy conservation standards. 

7-A-2 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 7-A.2.1 Refrigerator Energy Consumption Data by Year 

Model Year 

Shipment Weighted Average 

Use (kWh/yr) Model Year 

Shipment Weighted Average 

Use (kWh/yr) 

2006 564 1990 988 

2005 550 1989 1006 

2004 559 1988 1049 

2003 589 1987 1052 

2002 576 1986 1165 

2001 611 1985 1147 

2000 779 1984 1139 

1999 762 1983 1160 

1998 738 1982 1191 

1997 728 1981 1190 

1996 708 1980 1278 

1995 693 1975 – 1979 1530† 

1994 693 1970 – 1974 1730† 

1993 699 1965 – 1969 1540† 

1992 877 1961 – 1964 1150† 

1991 918 

Source: AHAM Fact Books 

†: Approximate 

7A.2.2 Field Studies 

 In situ conditions account for several important factors including: ambient air 

temperature; the number and duration of door openings; the temperature of food loaded into the 

unit; the placement of the unit in relation to walls, ovens, and stoves; the temperature setting in 

the field; and the ice maker setting in the field. 

Since the early 1980s, utilities and government agencies have collected data on fieldmeasured refrigerator-freezer energy consumption in order to evaluate the effects of refrigerator 

“early replacement” programs. The collected data varies tremendously by sample size, the type 

of refrigerator-freezer studied, the length of time each appliance was monitored, and their 

operating conditions. The studies summarized in Table 2.2 describe the performance of 

refrigerator-freezers as measured in various ways. 

7A.2.2.1 KEMA-Xenergy Findings 

The private consulting firm KEMA-Xenergy in 2002 reviewed numerous reports of in 

situ performance studies for Southern California Edison. Several reports were summarized by 

KEMA-Xenergy but are not available to be reviewed by DOE. These reports are indicated by a 

“#” in Table 2.2. 

7-A-3 

EERE-2008-BT-STD-0012 COMMENT 22
Table 7-A.2.2 Literature summary 

Authors(s) Year Ratio Averagea Ratio Range 

Comparison Type Location Refrigerator Type 

Arthur D. Little, Inc. # 1982 >1.2 C to A Florida unknown 

Topping & Vineyard 1982 0.85 to 1.5b C to A Norfolk, VA New 

Meier & Jansky 1993 0.85 is “typical” 0.56 to 1.17 C to A Cold climates (many in Pacific Northwest) Relatively new Meier et al. 1993 B to A: 0.99, C to A: 0.87 B to A: 0.89 to 1.10 B and C to A Rochester, NY New, “energy efficient”, frost-free 

Bos # 1993 “considerably” > 1 B to A Sacramento, CA At replacement 

Quantum Consulting 1994 

0.87 for “highefficiency”, 1 for 

“super-efficiency” 

95% between 

roughly 0.7 

and 1.25 

C to A Southern CA (SCE) 1-3 years old 

Proctor Engineering (Dutt et al.) 1994 Between 0.86 and 0.9c C to A Northern CA (PG&E) New, “energy efficient” 

Goett # 1995 approx. 1 Unknown CA (PG&E and SCE) New 

Barakat & Chamberlin 

# 1996 “significantly more” than 1 B to A Unknown At replacement 

Miller & Pratt 1998 1.1 0.72 to 1.2e C to A New York City (multi­ family public housing) Some new, some older 

Kinney & Belshe 2001 0.96 (new); 1.3 (mixture) C to A New York City (multi­ family public housing) 220 old, 56 new 

ICF Consulting 2003 approx. 0.5 C to statistical model of C CA (Bay Area) At replacement 

Mowris # 2003 1.06 wide variation C to A Northern CA (6 cities) At replacement 

KEMA 2004 1.46 (median) 0.85 to > 3 B to A California At replacement 

Peterson et al. 2007 median 1.4, mean 1.5 B to A California At replacement 

ADM, Athens, et al. 2008 

0.81 to 0.88, 

depending on weather 

model 

C to B California At replacement 

a A value greater than 1 for this ratio for a C to A comparison implies that energy use in the field (C) was greater than the labeled energ# KEMA-Xenergy (2004) is DOE’s only reference for the results of this study. b Seasonal variation for a single model c Ratio of average C to average A over sample d Adjusted for typical meteorological year (TMY) at location e Variation in the mean of various types of refrigerators in various use environments 

7-A-4 

EERE-2008-BT-STD-0012 COMMENT 22
7-A.3 LITERATURE ANALYSIS 

DOE’s interest in surveying the refrigerator-freezer energy use literature is to evaluate the 

range of possible appropriate values for the ‘usage adjustment factor’, or UAF. The UAF is a 

“(C) to (A)”-type measurement, relating energy use in situ to the DOE test result for a new 

appliance. 

Studies of new appliances include Meier & Jansky (1993), Meier et al. (1993), Dutt et al. 

(1994), Quantum (1994), Goett (1995), Miller & Pratt (1998), and Kinney & Belshe (2001). The 

average (or typical) values of the ratio of (C) to (A) for these studies range from 0.85 to 1.1, and 

there is significant variation, with ratios ranging from 0.56 to 1.25. The majority of these studies 

are not adjusted for ambient temperature variations or climate (although several use year-long 

samples to eliminate seasonal effects). The only of these studies which is adjusted (Dutt et al.) is 

normalized to the climate of the particular location of the measurements, rather than to a national 

average climate model. Taken collectively, these studies do not allow DOE to draw conclusions 

regarding possible national variation in new-refrigerator energy use, particularly due to 

variations in climate. They do indicate that the labeled energy consumption of a new appliance is 

likely to be accurate in situ to within 40%, as suggested by Meier (1995). 

Studies of refrigerators at the time of replacement by utility programs show higher energy 

use relative to the labeled energy consumption than do new refrigerators. For older refrigerators, 

studies predominantly take two forms: (B) to (A) or (C) to (A). (B) to (A) studies isolate the 

effects of age from any other effects (such as behavior or ambient temperature in situ), while (C) 

to (A) studies give a direct indication of the ‘UAF’ of old appliances. These studies are not 

necessarily representative of all older refrigerators, because they study only those units and 

households participating in utility refrigerator recycling programs. 

 Test-procedure-only comparison studies include Bos (1993), Barakat & Chamberlin 

(1996), KEMA (2004) and Peterson et al. (2007). All four of these studies show significant 

energy use increase in the DOE test procedure; KEMA and Peterson both indicate an energy use 

increase of close to 50%, with wide variation. Only 7% of the refrigerators measured by KEMA 

used less than their labeled consumption. 25% of the refrigerators measured by Peterson et al. 

used more than 70% more that their labeled consumption. 

Miller & Pratt (1998), Kinney & Belshe (2001), and Mowris (2003) undertook direct 

evaluation of the ratio of in situ to labeled consumption for older refrigerators. The average ratio 

in all three studies was measured to be larger than one, although smaller than the test-procedurebased comparisons. Mowris indicated wide variation in energy use relative to the label, and 

Miller & Pratt’s sub-categories show a range of energy consumptions from 28% below the label 

to 20% above. 

Only one study reviewed by DOE compared in situ energy use to the DOE test on the 

same appliance (ADM, Athens, et al., 2008), a (C) to (B) comparison. Depending on the weather 

7-A-5
 

EERE-2008-BT-STD-0012 COMMENT 22
model used to adjust the in situ measurements, they found that on average the DOE test 

procedure overestimated the in situ use by 13 to 23%. This study does not include an indication 

of how the DOE test consumption compared with the labeled consumption. 

Testing has confirmed that age, in combination with other refrigerator characteristics, 

accounts for the degradation of refrigerator energy efficiency (KEMA, 2004; Peterson, 2007). 

Therefore, energy efficiency degradation is a factor in calculating the savings between new and 

replacement units. Energy use increases when barriers to cabinet air and heat leakage degrade. 

For example, door seals no longer close tightly, damaged walls allow air flow, and wet or 

degraded insulation no longer performs its function. 

Two studies (KEMA, 2004 and Miller & Pratt, 1998) used regression analysis to measure 

the average effect of annual degradation on appliance energy use. KEMA determined an energy 

use growth rate of roughly 40 kWh/year, depending on model characteristics. Miller & Pratt’s 

regression model predicts a 1.37% increase in energy use each year. Smit (2006) reports that 

Athens (1998) calculated a degradation rate of 0.6% per year. 

7-A.4 SUMMARY 

This appendix summarizes current literature pertaining to the difference between DOEtest based measurements (when new or at retirement) and field-based measurements of 

refrigerator-freezer energy consumption. In situ energy use was found to be close to labeled 

consumption for new refrigerators, but higher than labeled at the time of replacement. This 

appendix has examined the mean values and variability from the literature; the variability across 

a national sample is likely much greater than the range addressed here. 

Degradation of the refrigerator unit contributes to the discrepancy between the DOE test 

and field measured energy consumption data. However, the precise rate of efficiency decrease 

(and particularly its variability) cannot be determined from the literature. 

7-A.5 BIBLIOGRAPHY 

ADM Associates, Inc. 2004. Southern California Edison 1994 Residential Appliance Efficiency 

Incentive Program Ninth Year Retention Study. CEC Study ID #546A. Prepared for 

Southern California Edison Company. July 2004. 

ADM Associates, Inc.; et al. 2008. Evaluation Study of the 2004-05 Statewide Residential 

Appliance Recycling Program; 2004-2005 Programs #1114, #1157, #1232 and #1348 

Final Report and Appendices. Prepared by ADM Associates, Inc.; Athens Research; 

Hiner & Partners; and Innovologie LLC. Prepared for Southern California Edison. April, 

2008. 

7-A-6
 

EERE-2008-BT-STD-0012 COMMENT 22
Athens Research, 1998. Refrigerator/Freezer UEC Estimation, 1996 ARCA/SCE Turn-In 

Program. In Support of Xenergy Inc’s Evaluation of the 1996 Appliance Recycling 

Program. 

Dohrmann, Donald R. et al. Net Savings Estimation in Appliance Recycling Programs: A Review 

and Empirical Analysis with Recent California Data ADM Associates, Inc., Athens 

Research, Innovologie LLC for Southern California Edison. 

Dutt, Guatam, et al., 1994. “Large Scale Residential Refrigerator Field Metering”, in 1994 

ACEEE Summer Study in Energy Efficiency in Buildings, pp. 2.77. 

ICF Consulting, 2003. Evaluation of the Energy and Environmental Effects of the California 

Appliance Early Retirement and Recycling Program: Final Report. Prepared for: 

California Public Utilities Commission and Appliance Recycling Centers of America. 

May 12, 2003. 

KEMA. 2004. 2003 EM&V RARP Study:Degradation and Market Potential Analysis. Prepared 

for Southern California Edison, Rosemead, CA. Prepared by KEMA Inc., Madison, WI. 

December 23, 2004. CALMAC STUDY ID SCE0205 ma:project:scee0015 rarp 03 

evaluation:report:title. 

KEMA, 2004. Final Report: Measurement and Evaluation Study of the 2002 Statewide 

Residential Appliance Recycling Program. February, 2004. Prepared for: Southern 

California Edison. February 13, 2004. 

Kinney, Larry and Rana Belshe. 2001. Refrigerator Replacement in the Weatherization 

Program: Putting a Chill on Energy Waste: A special report for the Weatherization 

Assistance Program. E Source. September, 2001. 

Market Transformation Programme. 2007. BNC11: Domestic Refrigerator Test Standard Vs 

Real-Use Energy Consumption. April 30, 2007. 

http://www.mtprog.com/SelectProductStrategy.aspx?intSelection=1&intSector=1 

Meier, Alan, 1995. “Refrigerator energy use in the laboratory and in the field,” Energy and 

Buildings, 22, pp. 233-243. 

Meier, A.. and R. Jansky. Field Performance of Residential Refrigerators: A Comparison with 

the Laboratory Test. 1991. Lawrence Berkeley Laboratory: Berkeley, CA. Report No. 

LBL-31795. 

Meier, A. and M. Martinez. Energy Use of Icemaking in Domestic Refrigerators. ASHRAE 

Transactions: Symposia. 1996. AT-96-19-2. 

7-A-7
 

EERE-2008-BT-STD-0012 COMMENT 22
Meier. A., A. Megowan, B. Litt, and B. Pon. The New York State Residential Refrigerator 

Electrical Energy Monitoring Project: Final Report. 1993. Lawrence Berkeley National 

Laboratory: Berkeley, CA. Report No. LBL-33708. 

Miller, J.D. and R.G. Pratt. Estimates of Refrigerator Loads in Public Housing Based on Metered 

Consumption Data. 1998. Pacific Northwest National Laboratory. Report No. PNNL11991. 

Peterson, J., D. Dohrmann, T. Alereza, S. Samiullah, S. Westberg, and J.H. Redd. Gross Savings 

Estimation for Appliance Recycling Programs: the Lab Versus in situ Measurement 

Imbroglio and Related Issues. Proceedings of the 2007 International Energy Performance 

Evaluation Conference (IEPEC). 2007. Chicago, IL. August. Report 653. 17 pp. 

Quantum Consulting. 1994. 1991 Refrigerator Rebate Program Metering Study for Southern 

California Edison, Final Report. P646.070. 

Smit, Kevin L. 2006. 2005 Refrigerator/Freezer Recycling Program Evaluation. Snohomish 

County Public Utility District No. 1. March. 

Topping, Richard F. and Edward A. Vineyard. 1982. Field Test of a High-Efficiency, AutomaticDefrost Refrigerator Freezer. Prepared by AD Little and ORNL for the ASHRAE SemiAnnual Meeting, Toronto Canada. June 27-July 1, 1982. 

7-A-8
 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 7-B. DATA FOR ESTIMATING DISTRIBUTION OF 

REFRIGERATOR AND FREEZER SIZE IN THE RECS SAMPLE 

TABLE OF CONTENTS 

7-B.1 INTRODUCTION ................................................................................................. 7-B-1 

7-B.2 RESULTS .............................................................................................................. 7-B-1 

LIST OF FIGURE 

Figure 7-B.2.1 Models of Top Mount Freezer without through-the-door ice (Product 

Class 3)....................................................................................................... 7-B-2 

Figure 7-B.2.2 Models of Bottom Mount Freezer without through-the-door ice 

(Product Class 5)........................................................................................ 7-B-3 

Figure 7-B.2.3 Models of Side Mount Freezer with through-the-door ice (Product 

Class 7)....................................................................................................... 7-B-4 

Figure 7-B.2.4 Models of Upright Freezer with automatic defrost (Product Class 9)....... 7-B-5 

Figure 7-B.2.5 Models of Chest Freezers (Product Class 10)............................................ 7-B-6 

Figure 7-B.2.6 Models of Compact Refrigerator and Refrigerator-Freezer with manual 

defrost (Product Class 11).......................................................................... 7-B-7 

Figure 7-B.2.7 Models of Compact Chest Freezer (Product Class 18).............................. 7-B-8 

7B-i 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 7-B. DATA FOR ESTIMATING DISTRIBUTION OF REFRIGERATOR 

AND FREEZER SIZE IN THE RECS SAMPLE 

7-B.1 INTRODUCTION 

DOE used the California Energy Commission (CEC) appliance database1 to determine 

the distribution of refrigerator and freezer volumes in the market. The Energy Information 

Administration’s (EIA) Residential Energy Consumption Surveys (RECS)2

 provides the volumes 

of household refrigerators only within bins (ranges). In order to estimate the labeled energy 

consumption of a household’s standard-sized appliance, DOE selected a volume from within the 

appropriate RECS bin. DOE then selected a more precise volume randomly from the distribution 

of volumes within the RECS bin, basing the probability of selecting each volume on the number 

of models in the CEC database having that volume. The figures in this appendix show the 

volume distributions by number of models in the CEC database (narrower, solid bars in figures) 

and the distributions of refrigerator volumes reported by RECS respondents (wider, empty bars 

in figures). For each standard-sized refrigeration product DOE first identified the appropriate 

RECS bin and product class, then chose a more precise volume from the relevant part of the CEC 

distribution. 

For compact products (product classes 11 and 18), for which DOE did not use a 

household sample, DOE used the distribution of volumes from the CEC database to characterize 

the distribution of volumes sold in the market and determine the distribution of energy use. 

7-B.2 RESULTS 

Figures 7-B.2.1 through 7-B.2.7 depict the volume distributions on the number of models 

in the CEC database and the distribution of refrigerator and freezer volumes reported in RECS. 

7-B-1
 

EERE-2008-BT-STD-0012 COMMENT 22
Frequency 

700 

600
 

500
 

400
 

300
 

200
 

100
 

0 

CEC directory 

RECS bins 

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 
 

Total Volume (cu ft ) 

Figure 7-B.2.1 Models of Top Mount Freezer without through-thedoor ice (Product Class 3) 

7-B-2
 

EERE-2008-BT-STD-0012 COMMENT 22
Frequency 

160
 

140
 

120
 

100
 

80
 

60
 

40
 

20
 

0
 

CEC directory 

RECS bins 

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
 

Total Volume (cu ft ) 

Figure 7-B.2.2 Models of Bottom Mount Freezer without throughthe-door ice (Product Class 5) 

7-B-3
 

EERE-2008-BT-STD-0012 COMMENT 22
0 

100 

200 

300 

400 

500 

600 

700 

800 

900 

Frequency 

CEC directory 

RECS bins 

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 

Total Volume (cu ft ) 

Figure 7-B.2.3	 Models of Side Mount Freezer with through-thedoor ice (Product Class 7) 

7-B-4
 

EERE-2008-BT-STD-0012 COMMENT 22
Frequency 

50
 

45
 

40
 

35
 

30
 

25
 

20
 

15
 

10
 

5
 

0
 

CEC directory 

RECS bins 

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
 

Total Volume (cu ft ) 

Figure 7-B.2.4 Models of Upright Freezer with automatic defrost 

(Product Class 9) 

7-B-5
 

EERE-2008-BT-STD-0012 COMMENT 22
Frequency 

70 

60
 

50
 

40
 

30
 

20
 

10
 

0 

CEC directory 

RECS bins 

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
 

Total Volume (cu ft ) 

Figure 7-B.2.5 Models of Chest Freezers (Product Class 10) 

7-B-6
 

EERE-2008-BT-STD-0012 COMMENT 22
Frequency 

70 

60
 

50
 

40
 

30
 

20
 

10
 

0 

CEC directory 

1 2 3 4 5 6 7 8 9 10 
 

Total Volume (cu ft ) 

Figure 7-B.2.6 Models of Compact Refrigerator and RefrigeratorFreezer with manual defrost (Product Class 11) 

7-B-7
 

EERE-2008-BT-STD-0012 COMMENT 22
Frequency 

30 

25
 

20
 

15
 

10
 

5
 

0 

CEC directory 

1 2 3 4 5 6 7 8 9 10 
 

Total Volume (cu ft ) 

Figure 7-B.2.7 Models of Compact Chest Freezer (Product Class 

18) 

7-B-8
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

REFERENCES 

1	 California Energy Commission. Appliances Database—Refrigeration. 

<www.energy.ca.gov/appliances/database/excel_based_files/Refrigeration/> (Last accessed April 25, 

2009.) 

2	 U.S. Department of Energy–Energy Information Administration. Residential Energy 

Consumption Survey, 2005 Public Use Data Files. 2009. U.S. Department of Energy: 

Washington, D.C. <www.eia.doe.gov/emeu/recs/recspubuse05/pubuse05.html> 

7-B-9
 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS 

TABLE OF CONTENTS 

8.1 INTRODUCTION ........................................................................................................... 8-1 

8.1.1 Approach.......................................................................................................................... 8-1 

8.1.2 Summary of Inputs........................................................................................................... 8-2 

8.2 INPUTS TO LIFE-CYCLE COST ANALYSIS ............................................................. 8-7 

8.2.1 Inputs to Product Cost...................................................................................................... 8-8 

8.2.1.1 Baseline Retail Prices .................................................................................... 8-8 

8.2.1.2 Increases in Manufacturer Selling Price ........................................................ 8-9 

8.2.1.3 Markup and Sales Tax ................................................................................. 8-11 

8.2.1.4 Installation Cost ........................................................................................... 8-11 

8.2.1.5 Consumer Product Cost ............................................................................... 8-11 

8.2.2 Inputs to Operating Cost ................................................................................................ 8-13 

8.2.2.1 Annual Energy Consumption....................................................................... 8-14 

8.2.2.2 Energy Prices ............................................................................................... 8-15 

8.2.2.3 Energy Price Trends.....................................................................................8-16 

8.2.2.4 Repair and Maintenance Costs..................................................................... 8-17 

8.2.3 Product Lifetimes........................................................................................................... 8-17 

8.2.3.1 Estimated Survival Function........................................................................ 8-18 

8.2.3.2 Conversion of First to Second Refrigerators ............................................... 8-23 

8.2.3.3 Standard-Size Freezers................................................................................. 8-25 

8.2.3.4 Compact Refrigeration Products.................................................................. 8-27 

8.2.4 Discount Rates ............................................................................................................... 8-28 

8.2.4.1 Discount Rates for Residential Consumers.................................................. 8-28 

8.2.4.2 Assignment of Discount Rates to Sample Households................................ 8-31 

8.2.4.3 Discount Rates for Commercial Purchasers ................................................ 8-31 

8.2.5 Effective Date of Standard............................................................................................. 8-34 

8.2.6 Base-Case Energy Efficiencies...................................................................................... 8-35 

8.3 INPUTS TO PAYBACK PERIOD ANALYSIS........................................................... 8-37 

8.4 RESULTS OF ANALYSES .......................................................................................... 8-38 

8.4.1 Standard-Size Refrigerator-Freezers.............................................................................. 8-39 

8.4.1.1 Summary of Results..................................................................................... 8-39 

8.4.1.2 Distributions of Impacts............................................................................... 8-40 

8.4.2 Standard-Size Freezers................................................................................................... 8-45 

8.4.2.1 Summary of Results..................................................................................... 8-45 

8.4.2.2 Distributions of Impacts............................................................................... 8-46 

8.4.3 Compact Refrigeration Products.................................................................................... 8-50 

8.4.3.1 Summary of Results..................................................................................... 8-51 

8.4.3.2 Distributions of Impacts............................................................................... 8-52 

8.5 REBUTTABLE PAYBACK PERIOD.......................................................................... 8-56 

8.5.1 Metric............................................................................................................................. 8-56 

8.5.2 Inputs to Rebuttable Payback Period Analysis .............................................................. 8-56 

8-i 

EERE-2008-BT-STD-0012 COMMENT 22
8.5.3 Results of Analysis ........................................................................................................ 8-56 

LIST OF TABLES 

Table 8.1.1 Standard-Size Refrigerator-Freezers: Summary of Inputs to Calculations.......... 8-5 

Table 8.1.2 Standard-Size Freezers: Summary of Inputs to Calculations .............................. 8-6 

Table 8.1.3 Compact Refrigeration Products: Summary of Inputs to Calculations................ 8-7 

Table 8.2.1 Residential Refrigeration Products: Average Baseline Retail Price.................... 8-9 

Table 8.2.2 Standard-Size Refrigerator-Freezers: Increases in Manufacturer Selling 

Prices.................................................................................................................. 8-10 

Table 8.2.3 Standard-Size Freezers: Increases in Manufacturer Selling Prices.................... 8-10 

Table 8.2.4 Compact Refrigeration Products: Increases in Manufacturer Selling Prices..... 8-11 

Table 8.2.5 Standard-Size Refrigerator-Freezers: Average Consumer Cost ........................ 8-12 

Table 8.2.6 Standard-Size Freezers: Average Consumer Cost ............................................. 8-12 

Table 8.2.7 Compact Refrigeration Products: Average Consumer Cost .............................. 8-13 

Table 8.2.8 Standard-Size Refrigerator-Freezers: Average Annual Energy Use by 

Efficiency Level................................................................................................. 8-14 

Table 8.2.9 Standard-Size Freezers: Average Annual Energy Use by Efficiency Level...... 8-15 

Table 8.2.10 Compact Refrigeration Products: Average Annual Energy Use by 

Efficiency Level................................................................................................. 8-15 

Table 8.2.11 Average Electricity Prices in 2007 .................................................................... 8-16 

Table 8.2.12 Standard-Size Refrigerator-Freezers: Comparison of Survey and 

Shipments Data with Modeled Stock................................................................. 8-21 

Table 8.2.13 Standard-Size Freezers: Comparison of Survey and Shipments Stock to 

Modeled Stock ................................................................................................... 8-26 

Table 8.2.14 Types of Household Debt and Equity by Percentage Shares............................. 8-29 

Table 8.2.15 Average Nominal Interest Rates for Household Debt ....................................... 8-29 

Table 8.2.16 Average Real Effective Interest Rates for Household Debt .............................. 8-30 

Table 8.2.17 Average Nominal and Real Interest Rates for Household Equity ..................... 8-30 

Table 8.2.18 Average Interest on Household Debt and Equity .............................................. 8-31 

Table 8.2.19 Data for Calculating Weighted-Average Cost of Capital for Commercial 

Sectors................................................................................................................ 8-33 

Table 8.2.20 Weighted-Average Cost of Capital for Commercial Sectors............................. 8-34 

Table 8.2.21 Discount Rates for Commercial Sectors............................................................ 8-34 

Table 8.2.22 Standard-Size Refrigerator-Freezers: Base-Case Efficiency Distributions ....... 8-36 

Table 8.2.23 Standard-Size Freezers: Base-Case Efficiency Distributions............................ 8-36 

Table 8.2.24 Compact Refrigeration Products: Base-Case Efficiency Distributions ............. 8-37 

Table 8.4.1 Product Class 3, Top-Mount Refrigerator-Freezers: Analytical Results........... 8-39 

Table 8.4.2 Product Class 5, Bottom-Mount Refrigerator-Freezers: Analytical Results ..... 8-40 

Table 8.4.3 Product Class 7, Side-by-Side Refrigerator-Freezers with Through-theDoor Ice Service: Analytical Results................................................................. 8-40 

Table 8.4.4 Product Class 9, Upright Freezers: Analytical Results...................................... 8-46 

Table 8.4.5 Product Class 10, Chest Freezer: Analytical Results......................................... 8-46 

Table 8.4.6 Product Class 11, Compact Refrigerators: Analytical Results .......................... 8-51 

8-ii 

EERE-2008-BT-STD-0012 COMMENT 22
Table 8.4.7 Product Class 18, Compact Freezers: Analytical Results.................................. 8-51 

Table 8.5.1 Standard-Size Refrigerator-Freezers: Rebuttable Payback Periods................... 8-57 

Table 8.5.2 Standard-Size Freezers: Rebuttable Payback Periods........................................ 8-57 

Table 8.5.3 Compact Refrigerators and Freezers: Rebuttable Payback Periods................... 8-58 

LIST OF FIGURES 

Figure 8.1.1 Flow Diagram of Inputs for Life-Cycle Cost and Payback Period Analyses ...... 8-4 

Figure 8.2.1 Residential and Commercial Electricity Price Trends (2007 = 1) ..................... 8-17 

Figure 8.2.2 Comparison of Modeled Refrigerator Age Distribution with Data from
 

Residential Energy Consumption Surveys......................................................... 8-22 

Figure 8.2.3 Survival Function for Standard-Size Refrigerator-Freezers .............................. 8-22 

Figure 8.2.4 Function for Conversion of First to Second Refrigerator-Freezers ................... 8-25 

Figure 8.2.5 Survival Function for Standard-Size Freezers ................................................... 8-27 

Figure 8.4.1 Product Class 3, Top-Mount Refrigerator-Freezers: Distribution of LifeCycle Cost Impacts for Efficiency Level 5........................................................ 8-41 

Figure 8.4.2 Product Class 3, Top-Mount Refrigerator-Freezers: Distribution of 

Payback Periods for Efficiency Level 5............................................................. 8-41 

Figure 8.4.3 Product Class 3, Top-Mount Refrigerator-Freezers: Range of Life-Cycle 

Cost Savings by Efficiency Level...................................................................... 8-42 

Figure 8.4.4 Product Class 5, Bottom-Mount Refrigerator-Freezers: Range of LifeCycle Cost Savings by Efficiency Level ........................................................... 8-43 

Figure 8.4.5 Product Class 7, Side-by-Side Refrigerator-Freezers: Range of Life-Cycle 

Cost Savings by Efficiency Level...................................................................... 8-43 

Figure 8.4.6 Product Class 3, Top-Mount Refrigerator-Freezers: Range of Payback 

Periods by Efficiency Level............................................................................... 8-44 

Figure 8.4.7 Product Class 5, Bottom-Mount Refrigerator-Freezers: Range of Payback 

Periods by Efficiency Level............................................................................... 8-44 

Figure 8.4.8 Product Class 7, Side-by-Side Refrigerator-Freezers: Range of Payback 

Periods by Efficiency Level............................................................................... 8-45 

Figure 8.4.9 Product Class 9, Upright Freezers: Distribution of Life-Cycle Cost 

Impacts for Efficiency Level 5 .......................................................................... 8-47 

Figure 8.4.10 Product Class 9, Upright Freezers: Distribution of Payback Periods for 

Efficiency Level 5.............................................................................................. 8-47 

Figure 8.4.11 Product Class 9, Upright Freezers: Range of Life-Cycle Cost Savings by 

Efficiency Level................................................................................................. 8-48 

Figure 8.4.12 Product Class 10, Chest Freezers: Range of Life-Cycle Cost Savings by 

Efficiency Level................................................................................................. 8-49 

Figure 8.4.13 Product Class 9, Upright Freezers: Range of Payback Periods by 

Efficiency Level................................................................................................. 8-50 

Figure 8.4.14 Product Class 10, Chest Freezers: Range of Payback Periods by Efficiency 

Level .................................................................................................................. 8-50 

Figure 8.4.15 Product Class 11, Compact Refrigerators: Distribution of Life-Cycle Cost 

Impacts for Efficiency Level 5 .......................................................................... 8-52 

8-iii 

EERE-2008-BT-STD-0012 COMMENT 22
Figure 8.4.16 Product Class 11, Compact Refrigerators: Distribution of Payback Period 

for Efficiency Level 5 ........................................................................................ 8-53 

Figure 8.4.17 Product Class 11, Compact Refrigerators: Range of Life-Cycle Cost 

Savings by Efficiency Level .............................................................................. 8-54 

Figure 8.4.18 Product Class 18, Compact Freezers: Range of Life-Cycle Cost Savings 

by Efficiency Level............................................................................................ 8-54 

Figure 8.4.19 Product Class 11, Compact Refrigerators: Range of Payback Periods by 

Efficiency Level................................................................................................. 8-55 

Figure 8.4.20 Product Class 18, Compact Freezers: Range of Payback Periods by 

Efficiency Level................................................................................................. 8-55 

8-iv 

EERE-2008-BT-STD-0012 COMMENT 22
 

CHAPTER 8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS 

8.1 INTRODUCTION 

This chapter describes the Department of Energy (DOE)’s method and metrics for 

analyzing the economic impacts on individual consumers of potential energy efficiency 

standards for refrigeration products. The effects of standards on individual consumers include a 

change (usually a decrease) in operating cost and a change (usually an increase) in product cost. 

DOE analyzed the economic impacts related to potential new energy efficiency standards for 

standard-size refrigerator-freezers (top-mount, bottom-mount, and side-by-side); standard-size 

freezers (upright and chest); and compact refrigeration products (refrigerators and freezers), a 

total of 7 product classes. DOE examined the life-cycle cost, payback period, and rebuttable 

payback period of all potential efficiency standards on all product classes. The terms used in this 

analysis are defined below. 

•	 Life-cycle cost (LCC) is the total cost consumers incur during the life of an appliance, 

including purchase and operating costs (including energy expenditures). DOE 

discounts future operating costs to the time of purchase, and sums them over the 

lifetime of a product. 

•	 Payback period (PBP) measures the amount of time it takes consumers to recover the 

assumed higher purchase cost of more energy efficient products through lower 

operating costs. 

•	 Rebuttable payback period, a special case of the payback period, is based on 

laboratory conditions (specifically, those that reflect the DOE test procedure) for 

energy use. Its other inputs (including electricity prices) reflect representative realworld operating conditions. 

Inputs to the LCC and the PBP are discussed in sections 8.2 and 8.3, respectively, of this 

chapter. Results of the LCC and PBP analyses are presented in section 8.4. The rebuttable PBP is 

discussed in section 8.5. Key variables and calculations are presented for each of the three 

metrics listed above. DOE performed the calculations discussed here using a series of Microsoft 

Excel spreadsheets that are accessible on the Internet 

(www.eere.energy.gov/buildings/appliance_standards/). Details regarding and instructions for 

using the spreadsheets are discussed in appendix 8-A. 

8.1.1 Approach 

Recognizing that several inputs to the analysis of consumer LCC and PBP are either 

variable or uncertain, DOE used Monte Carlo simulation and probability distributions to model 

both the uncertainty and variability of inputs. Appendix 8-B provides a detailed explanation of 

Monte Carlo simulation and the use of probability distributions. DOE developed LCC and PBP 

spreadsheet models that incorporate both Monte Carlo simulation and probability distributions 

8-1 

EERE-2008-BT-STD-0012 COMMENT 22
 

by using Microsoft Excel® spreadsheets combined with Crystal Ball®, a commercially available 

add-in program. 

In addition to using probability distributions to characterize several of the inputs to the 

calculation, DOE developed samples of individual households that use standard-size 

refrigeration products. DOE performed the LCC and PBP calculations for each household in the 

sample to account for the variability in energy consumption and/or energy price associated with a 

range of households. 

As described in chapter 7, DOE used the DOE Energy Information Administration 

(EIA)’s 2005 Residential Energy Consumption Survey (RECS) to develop household samples 

for standard-size refrigeration products.1

 EIA constructed the 2005 RECS to represent the range 

of households throughout the United States. 

DOE used the 2005 RECS to establish the variability in the annual energy use of 

refrigeration products and in energy prices. DOE was able to assign a unique annual energy use 

and/or energy price to each household in the sample. Because of the large sample of households 

considered in the LCC and PBP analyses, annual energy use and/or energy prices vary greatly. 

Thus, although the annual energy use and/or energy prices are known for any particular 

household, their variability across all households contributes to the range of LCCs and PBPs 

calculated for any particular possible standard. 

DOE did not develop a household sample for compact refrigeration products, because 

many such products are used in lodging, dormitories, and other commercial establishments. DOE 

estimated the fractions of shipments of compact refrigeration products used in the residential and 

commercial sectors, then used appropriate inputs for those fractions. 

DOE displays LCC and PBP results as distributions of impacts compared to baseline 

conditions. Results, presented in section 8.4, were derived from 10,000 samples for each Monte 

Carlo simulation run. To illustrate the implications of the analysis, DOE generated a frequency 

chart that depicts the variation in LCC and PBP for each standard level considered for 

refrigeration products. 

8.1.2 Summary of Inputs 

The LCC represents the total consumer cost during the life of a product, including 

purchase and operating costs (including energy expenditures). DOE discounts future operating 

cost to the time of purchase, then sums them over the lifetime of each product. The PBP is the 

change in purchase cost due to an increased efficiency standard divided by the change in annual 

operating cost that results from the standard. The PBP represents the number of years it will take 

the customer to recover the increased purchase cost through decreased operating cost. 

DOE uses two types of inputs to the calculation of LCC and PBP: (1) inputs for 

establishing the purchase cost, otherwise known as the consumer product cost, and (2) inputs for 

determining the operating cost. 

8-2 

EERE-2008-BT-STD-0012 COMMENT 22
The following are the primary inputs for establishing the consumer product cost. 

•	 Baseline selling price: The price at which a manufacturer sells a product identified as 

a baseline-efficient model. 

•	 Increases in manufacturer selling price (MSP): The change in manufacturer selling 

price associated with producing a product that meets a particular efficiency level. 

•	 Markups and sales tax: The costs associated with converting increases in the MSP 

into consumer product cost. 

The following are the primary inputs for calculating the operating cost. 

•	 Product energy consumption: The site energy use associated with operating a given 

product. 

•	 Product efficiency: The energy consumption associated with a product that has an 

efficiency greater than that of the baseline product. 

•	 Energy prices: The prices consumers paid for energy (electricity) in a recent year. 

•	 Energy price trends. Energy prices forecasted into the future. DOE based these trends 

on the EIA’s Annual Energy Outlook (AEO) 2009.2 

•	 Repair and maintenance costs: Repair costs are associated with repairing or replacing 

components that fail. Maintenance costs are associated with maintaining the operation 

of a product. 

•	 Lifetime: The age at which a product is retired from service. 

•	 Discount rate: The rate at which DOE discounted future expenditures to establish 

their present value. 

Figure 8.1.1 graphically depicts the relationships among the inputs for installed cost and 

operating cost used to calculate the LCC and PBP. The yellow boxes in Figure 8.1.1 indicate 

inputs; the green boxes indicate intermediate outputs; and the blue boxes indicate the final 

outputs of LCC and PBP. 

8-3 

EERE-2008-BT-STD-0012 COMMENT 22
Baseline 

Manufacturer 

Selling Price 

Std-Level 

Manufacturer 

Selling Price 

Retailer 

Markup 

Sales Tax 

Installation 

Cost 

Total Installed 

Cost

 Energy 

Consumption 

Equipment 

Price 

Lifetime 

Operating 

Cost 

Annual Energy 

Cost 

Product 

Lifetime 

Repair and 

Maintenance 

Cost 

Discount Rate 

Energy Price 

Trends 

Annual 

Operating 

Cost 

Payback 

Period 

Life-Cycle 

Cost 

Energy Prices 

Figure 8.1.1	 Flow Diagram of Inputs for Life-Cycle Cost and Payback Period 

Analyses 

Tables 8.1.1 through 8.1.3 summarize the input values that DOE used to calculate the 

LCC and PBP for refrigeration products. The inputs for calculating total installed and operating 

costs included the product lifetime, discount rate, and energy price trends. DOE used single-point 

values to characterize all inputs to total cost, but used probability distributions to capture the 

uncertainty and/or variability of several inputs to operating cost. For those inputs characterized 

using probability distributions, the values in the following tables are average or typical values. 

8-4 

EERE-2008-BT-STD-0012 COMMENT 22
Table 8.1.1 Standard-Size Refrigerator-Freezers: Summary of Inputs to Calculations 

Input Product Class Average or Typical Value Characterization 

Baseline retail 

price 

Top-mount refrigeratorfreezer 

Bottom-mount 

refrigerator-freezer 

Side-by-side refrigeratorfreezer with TTD* 

550 2008$ 

1,615 2008$ 

1,332 2008$ 

Custom distribution 

Custom distribution 

Custom distribution 

Increase in 

manufacturer 

selling price† 

All Varies by efficiency level Single-point value 

Retailer 

markup All Baseline = 1.45 Incremental = 1.15 Single-point value 

Sales tax All 7.1% Single-point value 

Annual energy 

use 

Top-mount refrigeratorfreezer 

Bottom-mount 

refrigerator-freezer 

Side-by-side refrigeratorfreezer with TTD 

Baseline use = 657 kWh‡ 

Baseline use = 699 kWh 

Baseline use = 1,087 kWh 

Varies depending on usage 

Varies depending on usage 

Varies depending on usage 

Energy prices All 11.4 cents per kWh Varies depending on region 

Energy price 

trend All AEO 2009 reference case2 

Two additional scenarios: 

AEO high and low 

growth** 

Lifetime All 16.2 years (median) Weibull distribution 

Discount rate All 4.8% Custom distribution 

* Through-the-door ice service. 

† Includes manufacturer markup. 

‡ Kilowatt hours 

** See section 8.2.2.3. 

8-5 

EERE-2008-BT-STD-0012 COMMENT 22
Table 8.1.2 Standard-Size Freezers: Summary of Inputs to Calculations 

Input Product Class Average or Typical Value Characterization 

Baseline retail price Upright 

Chest 

469 2008$ 

304 2008$ 

Custom distribution 

Custom distribution 

Increase in manufacturer 

selling price* All Varies by efficiency level Single-point value 

Retailer markup All Baseline = 1.45 

Incremental = 1.15 Single-point value 

Sales tax All 6.59% Single-point value 

Annual energy use Upright 

Chest 

Baseline use = 980 kWh† 

Baseline use = 623 kWh 

Varies depending on usage 

Varies depending on usage 

Energy prices All 11.4 cents per kWh Varies depending on region 

Energy price trend All AEO 2009 reference case2 Two additional scenarios: 

AEO high and low growth§ 

Lifetime All 21.7 years (median) Weibull distribution 

Discount rate All 4.8% Custom distribution 

* Includes manufacturer markup. 

† Kilowatt hours. 

§ See section 8.2.2.3. 

8-6 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 8.1.3 Compact Refrigeration Products: Summary of Inputs to Calculations 

Input Product Class Average or Typical Value Characterization 

Baseline retail price Refrigerator 

Freezer 

153 2008$ 

193 2008$ 

Custom distribution 

Custom distribution 

Increase in manufacturer 

selling price* 

All Varies by efficiency level Single-point value 

Retailer markup All Baseline = 1.45 

Incremental = 1.15 Single-point value 

Sales tax All 6.9% Single-point value 

Annual energy use Refrigerator 

Freezer 

Baseline use = 325 kWh† 

Baseline use = 313 kWh 

Varies depending on usage 

Varies depending on usage 

Energy prices All 10.8 cents per kWh Varies depending on region 

Energy price trend All AEO 2009 reference case2 Two additional scenarios: 

AEO high- and low-growth§ 

Lifetime 

Refrigerator 5.6 years (mean) Weibull distribution 

Freezer 7.5 years (mean) Weibull distribution 

Energy prices All 4.8% (residential users) 

6.2% (commercial users) Custom distribution 

* Includes manufacturer markup 

† Killowatt hours. 

§

 See section 8.2.2.3. 

8.2 INPUTS TO LIFE-CYCLE COST ANALYSIS 

Life-cycle cost (LCC) is the total consumer cost during the life of an appliance, including 

purchase and operating costs (including energy costs). DOE discounted future operating costs to 

the time of purchase, then summed them over the lifetime of the product. DOE used the 

following equation to define LCC. 

LCC = PC +∑

N OCt 

t (1+ r)

Where: 

t =1 

LCC = life-cycle cost in dollars; 

PC = consumer product cost in dollars; 

∑ = sum over the lifetime, from year 1 to year N; 

N = lifetime of appliance in years; 

OC = operating cost in dollars; 

8-7 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

r = discount rate; and 

t = year for which operating cost is being determined. 

DOE expresses dollar values in 2008$ because it gathered most of its data for the LCC and PBP 

analysis in 2008. 

8.2.1 Inputs to Product Cost 

DOE calculated the cost consumers pay for baseline products based on the following 

equation. 

PC = (RSP )×(TAX ) BASE BASE 

Where: 

PCBASE = consumer cost for baseline product, 

RSPBASE = retail selling price for baseline product, and 

TAX= sales tax. 

DOE calculated the consumer cost for products having higher efficiency levels based on the 

following equation. 

PCSTD = PCBASE + (ΔMSPSTD × MU ×TAX ) RETINCR 

Where: 

PCSTD = consumer product cost for higher-efficiency products, 

PCBASE = consumer cost for baseline product
 

ΔMSPSTD = change in MSP for more efficient model, 

MURET_INCR = incremental retailer markup, 

TAX= sales tax. 

8.2.1.1 Baseline Retail Prices 

DOE’s engineering analysis (see chapter 5) did not attempt to estimate the manufacturing 

sales price (MSP) for baseline models. Instead, it developed incremental increases in MSP 

associated with increases in efficiency level. This approach required DOE to estimate retail 

prices for the baseline model in each product class. 

DOE drew upon proprietary retail price data collected by The NPD Group.3

 These data 

reflect prices and sales at many retail outlets in the United States, representing more than 50 

percent of retail sales nationwide. The data include model number, refrigerated volume, 

configuration of doors and ice-making, and whether the unit is an ENERGY STAR product. 

Based on these data DOE developed a sales-weighted price distribution for non-ENERGY STAR 

8-8 

EERE-2008-BT-STD-0012 COMMENT 22
 

appliances in each product class.a For the LCC and PBP analyses of standard-sized products, 

DOE assigned a baseline price from that distribution to each household sampled from the EIA’s 

2005 Residential Energy Consumption Survey (RECS).1

 For compact product classes, DOE 

assigned a baseline price from the distribution to each sampled product. Appendix 8-C presents 

the distribution histograms DOE developed for each product class. The average baseline retail 

prices before sales tax for each refrigeration product class are shown in Table 8.2.1. 

Table 8.2.1 Residential Refrigeration Products: Average Baseline Retail Price 

Product Class Baseline Retail Price 

2008$ 

Product class 3: Top-mount refrigerator-freezer 550 

Product class 5: Bottom-mount refrigerator-freezer 1,615 

Product class 7: Side-by-side refrigerator-freezer with TTD* 1,332 

Product class 9: Upright freezer 469 

Product class 10: Chest freezer 304 

Product class 11: Compact refrigerator 153 

Product class 18: Compact freezer 193 

* Through-the-door ice service. 

8.2.1.2 Increases in Manufacturer Selling Price 

DOE used a combination of cost data submitted by the Association of Home Appliance 

Manufacturers (AHAM)4 and a reverse engineering analysis to estimate increases to 

manufacturing cost associated with increases in efficiency levels for refrigeration products. Refer 

to Chapter 5, Engineering Analysis, for details. Adding the manufacturer markup described in 

chapter 6 yielded the MSP increases for each considered efficiency level and product class 

shown in Tables 8.2.2 through 8.2.4. 

a

 DOE assumed that prices for non-ENERGY STAR models are a reasonable approximation of prices for the 

baseline models. 

8-9 

EERE-2008-BT-STD-0012 COMMENT 22
Table 8.2.2 Standard-Size Refrigerator-Freezers: Increases in Manufacturer Selling Prices 

Efficiency Level 

% less than 

baseline energy use 

Increase in MSP 2008$ 

Product Class 3: 

Top-Mount 

Refrigerator-Freezer 

Product Class 5: 

Bottom-Mount 

Refrigerator-Freezer 

Product Class 7: 

Side-by-Side 

Refrigerator-Freezer 

with TTD Ice Service 

10 3.50 1.80 11.18 

15 7.68 5.79 18.96 

20 16.39 13.72 54.26 

25 34.92 31.38 106.00 

30 62.06 45.06 167.29 

35 103.91 110.05 228.96 

40 156.20 183.33 310.77 

45 208.14 251.25 

* Through-the-door. 

Table 8.2.3 Standard-Size Freezers: Increases in Manufacturer Selling Prices 

Efficiency Level Increase in MSP 2008$ 

% less than baseline energy 

use 

Product Class 9: 

Upright Freezer 

Product Class 10: 

Chest Freezer 

10 6.41 2.35 

15 11.45 6.05 

20 13.57 24.08 

25 27.51 29.26 

30 46.58 34.84 

35 76.82 74.35 

40 124.06 77.12 

45 196.78 136.90 

8-10 

EERE-2008-BT-STD-0012 COMMENT 22
Table 8.2.4 Compact Refrigeration Products: Increases in Manufacturer Selling Prices 

Efficiency Level 

% less than baseline 

energy use 

Increase in MSP 2008$ 

Product Class 11: 

Compact Refrigerator or 

Refrigerator-Freezer 

Product Class 18: 

Compact Chest Freezer 

10 3.36 6.05 

15 6.32 9.65 

20 8.85 34.03 

25 20.56 42.62 

30 21.63 60.19 

35 26.77 63.00 

40 39.24 75.22 

45 57.49 89.70 

8.2.1.3 Markup and Sales Tax 

To derive the incremental increase in consumer product cost for each efficiency level, 

DOE applied an incremental retail markup and sales tax to the MSP increases shown above. 

Refer to Chapter 6, Markups for Equipment Price Determination, for details. DOE also applied 

sales tax to the baseline retail prices. 

8.2.1.4 Installation Cost 

Because the cost to install refrigeration products does not change as efficiency increases, 

DOE did not incorporate installation costs in its analysis. 

8.2.1.5 Consumer Product Cost 

Tables 8.2.5 through 8.2.7 present the shipment-weighted consumer product cost at each 

considered efficiency standard level for the refrigeration product classes under consideration for 

new standards. These costs reflect the market efficiency distributions discussed in section 8.2.6. 

8-11 

EERE-2008-BT-STD-0012 COMMENT 22
Table 8.2.5 Standard-Size Refrigerator-Freezers: Average Consumer Cost 

Efficiency Level 

% less than baseline 

energy use 

Product Class 3: 

Top-Mount 

2008$ 

Product Class 5: 

Bottom-Mount 

2008$ 

Product Class 7: 

Side-by-Side 

2008$ 

Baseline 591 1,758 1,459 

10 595 1,759 1,463 

15 599 1,759 1,469 

20 609 1,760 1,499 

25 631 1,782 1,563 

30 665 1,799 1,638 

35 716 1,879 1,714 

40 781 1,969 1,815 

45 845 2,053 

Table 8.2.6 Standard-Size Freezers: Average Consumer Cost 

Efficiency Level 

% less than baseline energy use 

Product Class 9: 

Upright 

2008$ 

Product Class 10: 

Chest 

2008$ 

Baseline 505 325 

10 511 328 

15 517 332 

20 520 355 

25 537 361 

30 561 368 

35 598 416 

40 656 420 

45 745 493 

8-12 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 8.2.7 Compact Refrigeration Products: Average Consumer Cost 

Efficiency Level 

% less than baseline energy use 

Product Class 11: 

Compact Refrigerator 

2008$ 

Product Class 18: 

Compact Freezer 

2008$ 

Baseline 166 207 

10 170 214 

15 173 218 

20 176 248 

25 191 259 

30 192 281 

35 198 284 

40 214 299 

45 236 317 

8.2.2 Inputs to Operating Cost 

DOE defines operating cost (OC) by the following equation. 

OC = EC + RC + MC
 

Where: 

EC = energy cost associated with operating the product, 

RC = repair cost associated with component failure, and 

MC = cost for maintaining appliance operation. 

DOE used the following equation to calculate the annual operating cost for baseline 

products. 

OC BASE = ( AEC BASE × PRICE ENERGY BASE BASE ) + RC + MC

Where: 

OCBASE = operating cost for baseline product, 

AECBASE = annual energy consumption for baseline product, 

PRICEENERGY = energy price, 

RCBASE = repair costs associated with component failure for baseline product, and 

MCBASE = maintenance costs for baseline product. 

DOE used the following equation to calculate the annual operating cost for higher 

efficiency products. 

8-13 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

OC STD = (AEC STD × PRICE ENERGY STD STD ) + RC + MC

Where: 

OCSTD = operating cost of higher efficiency product, 

AECSTD = annual energy consumption of higher efficiency product, 

PRICEENERGY = energy price in each year, 

RCSTD = repair costs associated with component failure for higher efficiency product, 

and 

MCSTD = maintenance costs for higher efficiency product. 

8.2.2.1 Annual Energy Consumption 

As described in Chapter 7, Energy Use Determination, DOE developed samples of 

individual households that use each of the standard-sized refrigeration products considered 

herein. By developing the samples, DOE was able to calculate the LCC and PBP for each 

household to account for the variability in both energy use and energy price associated with that 

household. 

Tables 8.2.8 through 8.2.10 are derived from the analysis described in chapter 7. The 

values shown for annual energy consumption are averages in the field. For compact products, 

DOE did not use the RECS sample, and the energy consumption is as measured using the DOE 

test procedure. DOE captured the variability in energy consumption by using a range of values in 

its LCC and PBP analyses. 

Table 8.2.8 Standard-Size Refrigerator-Freezers: Average Annual Energy Use by 

Efficiency Level 

Product Class 3: 

Top-Mount RefrigeratorFreezer 

Product Class 5: 

Bottom-Mount RefrigeratorFreezer 

Product Class 7: 

Side-by-Side RefrigeratorFreezer with TTD† 

Efficiency Level 

% less than baseline 

energy use 

Energy 

Use 

kWh* 

Efficiency Level 

% less than baseline 

energy use 

Energy 

Use 

kWh 

Efficiency Level 

% less than baseline 

energy use 

Energy 

Use 

kWh 

Baseline 657 Baseline 699 Baseline 1,087 

10 591 10 629 10 979 

15 558 15 594 15 924 

20 526 20 559 20 870 

25 493 25 524 25 815 

30 460 30 489 30 761 

35 427 35 454 35 707 

40 394 40 419 40 652 

45 361 45 384 - -

* Kilowatt hours. 

†

Through-the-door ice service. 

8-14 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 8.2.9 Standard-Size Freezers: Average Annual Energy Use by Efficiency Level 

Product Class 9: 

Upright Freezer 

Product Class 10: 

Chest Freezer 

Efficiency Level 

% less than baseline 

energy use 

Energy Use 

kWh* 

Efficiency Level 

% less than baseline 

energy use 

Energy Use 

kWh 

Baseline 980 Baseline 623 

10 882 10 561 

15 833 15 530 

20 784 20 498 

25 735 25 467 

30 686 30 436 

35 637 35 405 

40 588 40 374 

45 539 45 343 

* Kilowatt hours. 

Table 8.2.10 Compact Refrigeration Products: Average Annual Energy Use by Efficiency 

Level 

Product Class 11: 

Compact Refrigerator 

Product Class 18: 

Compact Freezer 

Efficiency Level 

% less than baseline 

energy use 

Energy Use 

kWh* 

Efficiency Level 

% less than baseline 

energy use 

Energy Use 

kWh 

Baseline 325 Baseline 313 

10 292 10 282 

15 276 15 266 

20 260 20 250 

25 244 25 235 

30 227 30 219 

35 211 35 203 

40 195 40 188 

45 179 45 172 

* Kilowatt hours. 

8.2.2.2 Energy Prices 

Using data from EIA Form 8615

, DOE derived average energy prices for 13 geographic 

areas in the United States: the nine U.S. Census divisions, plus four large states (New York, 

Florida, Texas, and California) considered individually. For Census divisions containing one of 

those large states, DOE left out data for the large state when calculating average regional values. 

8-15 

EERE-2008-BT-STD-0012 COMMENT 22
For example, the Pacific region average excludes California, and the West South Central region 

excludes Texas. Using the modified regional data, DOE assigned an appropriate energy price to 

each household in the sample. 

DOE used data from EIA to estimate electricity prices for residential consumers in each 

of the 13 geographic areas These data, which are published annually, include annual electricity 

sales in kilowatt hours (kWh), revenues from electricity sales, and number of consumers by 

sector for every utility that serves final consumers. The calculation of an area-average residential 

or commercial electricity price proceeds in two steps. 

1.	 For each utility, an average sector (residential or commercial) price is estimated by 

dividing sector revenues by sector sales. 

2.	 An average regional price is calculated, whereby each utility having customers in a 

region is weighted by the number of residential consumers served in that region. 

The calculation used the most recent EIA data available at the time the analysis was conducted. 

Table 8.2.11 shows the average residential and commercial electricity price in 2007 for each 

Census division and large state. 

Table 8.2.11 Average Electricity Prices in 2007 

Geographic Area 

Average Residential Price 

2008$/kWh 

Average Commercial Price 

2008$/kWh 

New England 0.162 0.153 

Middle Atlantic 0.127 0.111 

East North Central 0.102 0.091 

West North Central 0.088 0.075 

South Atlantic 0.099 0.085 

East South Central 0.087 0.086 

West South Central 0.093 0.085 

Mountain 0.097 0.084 

Pacific 0.099 0.094 

New York State 0.178 0.169 

California 0.150 0.136 

Texas 0.128 0.119 

Florida 0.117 0.102 

Source: U.S. Department of Energy–Energy Information Administration EIA Form 861. 

8.2.2.3 Energy Price Trends 

To estimate energy prices in future years, DOE multiplied the average prices listed in 

Table 8.2.11 by the forecast of annual average price changes in the EIA’s AEO 2009.2

 To 

estimate the trend after 2030, DOE followed guidelines that the EIA had provided to the Federal 

8-16 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Energy Management Program, which called for using the average rate of change for electricity 

during 2020–2030. 

The Department calculated LCC and PBP for each class of refrigeration products using 

three separate projections from AEO 2009: reference, low, and high economic growth. 

Alternative assumptions regarding the future growth in energy markets reflects the uncertainty 

regarding economic conditions during the forecast period. Figure 8.2.1 shows the projected 

trends in residential and commercial electricity prices based on the AEO 2009 reference case. 

For the LCC results presented in this chapter, DOE used only the energy price forecasts from the 

AEO reference case. 

Electricity Price Trends 

1.2 

1.1 

1.0 

0.9 

0.8 

AEO 2009 Reference Res Elec 

AEO 2009 Reference Com Elec 

2000 2005 2010 2015 2020 2025 2030 

Source: Energy Information Administration, Annual Energy Outlook. 2009. 

Figure 8.2.1	 Residential and Commercial Electricity Price 

Trends (2007 = 1) 

8.2.2.4 Repair and Maintenance Costs 

Because DOE found no evidence that repair or maintenance costs change as the 

efficiency of refrigeration products increases, it excluded those costs from its analysis. 

8.2.3 Product Lifetimes 

8-17 

EERE-2008-BT-STD-0012 COMMENT 22
 

8.2.3.1 Estimated Survival Function 

The Energy Information Agency (EIA)’s Residential Energy Consumption Survey 

(RECS)1

 of occupied primary housing units records the presence of various appliances in each 

household, and places the age of each appliance into bins comprising several years. Data from 

the U.S. Census’s American Housing Survey (AHS),6

 which surveys all housing including vacant 

and second homes, enabled DOE to adjust the RECS data to reflect some appliance use outside 

of primary residences. By combining the results of both surveys with the known history of 

appliance shipments (collected from Appliance magazine or directly from manufacturer trade 

associations), DOE estimated the percentage of appliances of a given age still in operation. This 

survival function, which DOE assumed has the form of a cumulative Weibull distribution, 

provides an average and a median appliance lifetime. 

 The Weibull distribution is a probability distribution commonly used to measure failure 

rates.b

 Its form is similar to an exponential distribution, which models a fixed failure rate, except 

that a Weibull distribution allows for a failure rate that changes over time in a particular fashion. 

The cumulative Weibull distribution takes the form: 

⎛ x−θ ⎞

β

−⎜ ⎟ P(x) = e ⎝ α ⎠ for x > θ and 

P(x) = 1 for x ≤ θ

Where: 

P(x) = probability that the appliance is still in use at age x; 

x = appliance age; 

α = scale parameter, which would be the decay length in an exponential distribution; 

β = shape parameter, which determines the way in which the failure rate changes through 

time; and 

θ = delay parameter, which allows for a delay before any failures occur. 

When β = 1, the failure rate is constant over time, giving the distribution the form of a 

cumulative exponential distribution. In the case of appliances, β commonly is greater than 1, 

reflecting an increasing failure rate as appliances age. 

The RECS survey is DOE’s primary resource for appliance ages. For several appliances, 

including refrigerators and freezers, the survey asks respondents to identify the appliance’s age 

as: 

• less than 2 years old, 

• 2 to 4 years old, 

• 5 to 9 years old, 

b

 For reference on the Weibull distribution, see sections 1.3.6.6.8 and 8.4.1.3 of the NIST/SEMATECH e-Handbook 

of Statistical Methods, <www.itl.nist.gov/div898/handbook/>. 

8-18 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

• 10 to19 years old, or 

• more than 20 years old. 

The RECS survey has been conducted every three or four years for the past several 

decades. For this analysis, DOE used the surveys conducted in 1990, 1993, 1997, 2001, and 

2005. DOE used the AHS count of housing units that contain refrigerators to scale the RECS 

data to better match the total installed stock. The U.S. Census AHS does not include data on 

freezers. DOE used the RECS micro-data to exclude from this analysis refrigerators that are both 

“half-height” and less than 10 cubic feet in capacity, because such refrigerators are not standardsized. To determine overall refrigerator lifetime, DOE included all appropriately sized 

refrigerators, whether the household’s first (primary) or second refrigerator. Households that did 

not know the age of their appliance were allocated among the remaining age bins according to 

the distribution of respondents who did report the appliance age. 

Refrigerator ownership exhibits complex consumer behavior, which is not adequately 

reflected in AHS. In particular, AHS records only whether a housing unit contains a refrigerator, 

not the number of refrigerators. In addition, AHS may record a unit as containing a refrigerator 

when it contains a compact, rather than standard-size, appliance. Therefore, DOE used AHS only 

to scale the number of first refrigerators recorded by RECS. The baseline number of refrigerators 

reported in each RECS age bin is the sum of the AHS-scaled first refrigerators and the un-scaled, 

standard-size second refrigerators. 

DOE adjusted the RECS survey data to account for the fact that the RECS survey begins 

its reference year with July, whereas shipments data are provided for each calendar year. DOE 

adjusted the data by using the survival function to model the additional retirement and 

replacement of appliances that takes place in the latter half of a survey year (after a given 

respondent is surveyed). 

DOE used the RECS data on appliance ages, combined with the history of appliance 

shipments, to develop survival functions for refrigeration products. For example, DOE summed 

the total shipments from 5 to 9 years before each RECS survey, then compared this number with 

the number of units still in use at the time of the survey to approximate the percentage of 

surviving appliances within that age bin. By combining the age bins from the five RECS surveys 

with shipments data, DOE had enough data to use a least-squares method to build a fit to a 

Weibull distribution and find the parameters (α, β, θ) that best approximate the number of 

surviving units. Because the first two (youngest) RECS bins tend to have a large scatter relative 

to the shipments in those years, DOE combined the RECS and shipments data in the first two 

bins. Refrigerators and freezers generally do not fail during their first four years, so combining 

bins did not lower appreciably the accuracy of the distribution. DOE weighted each bin’s 

contribution to the sum of squares by the inverse of the variance in RECS survey results, which 

controls for the changes in sample size between bins and through time.c

 RECS has a complex 

c

 See sections 4.1.4.3, 4.4.3.2, and 4.4.5.2 of NIST/SEMATECH e-Handbook of Statistical Methods, 

<www.itl.nist.gov/div898/handbook/>. 

8-19 

EERE-2008-BT-STD-0012 COMMENT 22
error model. DOE used only the error due to finite sample size to determine the variance for 

weighting the age bins. The equation for the sum of squares that DOE minimized is: 

(RECSi − Survi )

2 

∑ σ2 , i i,RECS 

Where: 

i = the identifier for a bin from a single RECS; 

RECSi = the number of appliances reported by RECS in bin I; 

Survi = the number of surviving appliances in bin i predicted by the Weibull distribution 

applied to the number of appliances shipped (a function of α, β, and θ); and 

σi,RECS = the standard error (square root of the variance) of the RECS data point for bin i. 

Table 8.2.13 shows the RECS data for refrigerators, the associated total shipments, and 

the best-fit Weibull calculation of stock by age bin. Figure 8.2.2 plots the data from the third and 

fourth columns of Table 8.2.12 against each other to show the quality of the fit. DOE allowed the 

delay parameter, θ, to vary only between 1 and 5 years, which corresponds to common warranty 

periods (see discussion below). For refrigerators and freezers, the best fit within this range is 5 

years. 

The Weibull distribution, shown in Figure 8.2.3, is characterized by the parameters α = 

13.91, β = 1.68, and θ = 5.0. This distribution has a mean refrigerator lifetime of 17.43 years and 

a median lifetime of 16.18 years. 

8-20 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

Table 8.2.12 Standard-Size Refrigerator-Freezers: Comparison of Survey and Shipments 

Data with Modeled Stock 

RECS 2005 

All Refrigerators Second Refrigerators 

Modeled Modeled 

Age Bin years Shipments RECS Stock Stock RECS Stock Stock 

0 to 4 51,119,128 56,880,896 51,119,128 5,311,005 3,041,016 

5 to 9 42,988,500 40,150,841 41,031,292 4,983,112 3,524,129 

10 to 19 68,088,000 36,771,769 40,997,548 8,672,157 6,942,353 

20 or more 165,800,000 10,337,608 12,039,872 4,139,841 4,628,220 

RECS 2001 

All Refrigerators Second Refrigerators 

Modeled Modeled 

Age Bin years Shipments RECS Stock Stock RECS Stock Stock 

0 to 4 44,319,100 46,312,479 44,319,100 2,460,510 2,637,703 

5 to 9 36,982,000 39,491,335 35,298,172 3,868,224 3,031,985 

10 to 19 60,556,000 35,970,898 36,813,807 6,572,685 6,198,453 

20 or more 144,325,000 11,301,203 11,920,574 3,955,496 4,580,842 

RECS 1997 

All Refrigerators Second Refrigerators 

Modeled Modeled 

Age Bin years Shipments RECS Stock Stock RECS Stock Stock 

0 to 4 38,185,000 44,356,564 38,185,000 2,047,982 2,274,485 

5 to 9 32,698,000 36,760,359 31,123,487 2,782,204 2,695,071 

10 to 19 56,244,000 31,056,224 33,972,064 5,078,190 5,724,270 

20 or more 122,660,000 10,989,427 11,832,244 3,879,197 4,475,841 

RECS 1993 

All Refrigerators Second Refrigerators 

Modeled Modeled 

Age Bin years Shipments RECS Stock Stock RECS Stock Stock 

0 to 4 33,088,000 37,322,759 33,088,000 1,605,544 1,972,965 

5 to 9 31,584,000 35,001,768 30,138,108 2,289,052 2,591,010 

10 to 19 52,400,000 32,735,032 30,891,143 4,695,960 5,348,774 

20 or more 101,577,000 13,119,858 11,723,329 5,708,862 4,296,210 

RECS 1990 

All Refrigerators Second Refrigerators 

Modeled Modeled 

Age Bin years Shipments RECS Stock Stock RECS Stock Stock 

0 to 4 32,670,000 38,098,670 32,670,000 1,784,095 1,950,717 

5 to 9 26,419,000 30,724,176 25,249,353 2,227,766 2,158,527 

10 to 19 56,584,000 34,088,557 33,242,186 5,316,297 5,767,417 

20 or more 82,797,000 12,571,836 10,159,632 4,869,236 3,737,018 

Source: U.S. Department of Energy–Energy Information Agency. Residential Energy Consumption Survey. 1990, 

1993, 1997, 2001, and 2005. 

8-21 

EERE-2008-BT-STD-0012 COMMENT 22
Calculated number of refrigerators by bin 40000000 

30000000 

20000000 

10000000 

0 

bins 

ideal 

0 10000000 20000000 30000000 40000000 

RECS reported number of refrigerators by bin 

Figure 8.2.2 Comparison of Modeled Refrigerator Age Distribution with Data 

from Residential Energy Consumption Surveys 

1.2 

1.0 

Fraction surviving 

0.8 

0.6 

0.4 

0.2 

0.0 

16.18 

17.43 

Survival function 

Median lifetime 

Mean lifetime 

0 5 10 15 20 25 30 35 40 45 

Age (years) 

Figure 8.2.3 Survival Function for Standard-Size Refrigerator-Freezers 

8-22 

50 

EERE-2008-BT-STD-0012 COMMENT 22
The method DOE used to calculate product lifetimes incorporates several assumptions: 

•	 Appliance lifetime can be modeled by a survival function. In particular, a Weibull 

distribution is an appropriate survival function. 

•	 The appliance survival function does not change through time. 

•	 The survival function is independent of other household factors (such as household 

size or geographic region) as well as product class (within standard-size refrigerators 

or freezers). 

•	 RECS respondents neither systematically overestimated nor underestimated the 

current age of their appliance. 

•	 The historical shipment data are accurate. 

•	 The shipped appliances are installed exclusively (or almost exclusively) in residences. 

•	 The Weibull delay parameter, θ, is limited to between 1 and 5 years. 

Three of these assumptions reflect analytical choices made by DOE. The first is the 

assumption that a Weibull distribution is the appropriate distribution to use for rates of appliance 

retirement. This distribution is the standard one used in lifetime analyses, but it is not guaranteed 

to reflect actual real-world experience. The second assumption is that consumer behavior and 

mechanical appliance lifetime have not changed over time. This assumption required DOE to 

treat equally all data from the several RECS surveys. Using only recent surveys (which may 

better reflect recent consumer behavior and appliance lifetime) would provide only a few data 

points for attempting least-squares fits, producing large statistical uncertainty. 

The third assumption concerns the Weibull delay parameter. DOE limited the delay 

parameter to between 1 and 5 years to reflect the range of common appliance warranties. A delay 

of less than 1 year would imply that some appliances fail or are replaced within their first year of 

use. A delay of more than 5 years would imply that no appliances are replaced for some time 

after the end of the longest standard warranty. Fits using θ > 5 also commonly show nonsensical 

behavior, with sharp changes in consumer behavior or appliance survival immediately following 

the delay period. 

8.2.3.2 Conversion of First to Second Refrigerators 

When a household purchases a new refrigerator, sometimes it uses its original unit as a 

secondary appliance in the basement or garage. DOE modeled the process by which first 

refrigerators are converted to second refrigerators as a Weibull process having a cumulative 

distribution of the form: 

⎛ ⎜

⎛ x−θ ⎞

β

− ⎞ ⎟ P(x) = δ + (1−δ )×⎜1− e ⎝ α ⎠ ⎟ for x > θ and ⎜ ⎟ ⎝ ⎠

P(x) = δ for x ≤ θ

8-23 

EERE-2008-BT-STD-0012 COMMENT 22
Where: 

P(x) = probability that the appliance has been converted at age x; 

x = appliance age; 

α = the scale parameter, which would be the decay length in an exponential distribution; 

β = the shape parameter, which determines the way in which the conversion rate changes 

through time; 

δ = the percentage of shipments that are used immediately as second refrigerators; and 

θ = the delay parameter, which allows for a delay before any conversions occur. 

Rather than comparing second refrigerators to shipments, DOE compared them with the 

existing total installed base of refrigerators of a certain age, as measured by RECS. As with 

calculating appliance lifetime, the RECS data were adjusted with AHS data. In essence, DOE 

constructed a Weibull distribution to model a conversion function rather than a survival function. 

In addition, the model allows for the direct purchase of a new second refrigerator. A refrigerator 

bought to be a second refrigerator is modeled as being converted from first to second 

immediately at purchase; the offset parameter δ represents those units. Refrigerators commonly 

are bought to be second units, as indicated by the relatively large number of young second 

refrigerators reported by in RECS surveys. 

DOE fit the conversion function using results from the 1990, 1993, 1997, 2001, and 2005 

RECS. The RECS micro-data again enabled removing refrigerators that are not standard size, 

which has a significant effect given that many compact refrigerators are used as second units. In 

Table 8.2.12 the fifth column shows the RECS-derived stock of second refrigerators by age bin, 

and the sixth column shows the best fit from a Weibull distribution. Figure 8.2.4 shows the 

Weibull distribution. The best-fit Weibull parameters for the conversion function are α = 38.12, β

= 2.03, and θ = 0.0, with an offset of 5.6 percent (meaning that 5.6 percent of shipments are sold 

as new second refrigerators). Roughly 1.5 percent of surviving refrigerators are converted from 

first to second refrigerator status each year, and roughly 20 percent of surviving refrigerators are 

converted to second refrigerators before they reach 15 years of age. 

8-24 

EERE-2008-BT-STD-0012 COMMENT 22
0.0 

0.2 

0.4 

0.6 

0.8 

1.0 

Fraction converted to 2nd refrigerator

Conversion function 

0 10 20 30 40 50 

Age (years) 

Figure 8.2.4 Function for Conversion of First to Second Refrigerator-Freezers 

8.2.3.3 Standard-Size Freezers 

DOE assumed relatively simple consumer behavior related to freezers. DOE did not 

model the conversion from first to second freezer for households having more than one freezer, 

but simply used all freezer data from RECS. Standard-sized freezers were assumed to have a 

capacity greater than 10 cubic feet. As with refrigerators, RECS bins were adjusted for units 

replaced in the second half of a year to synchronize the RECS and shipments data. RECS did not 

collect freezer lifetime data in 1990, so DOE used results from only the 1993, 1997, 2001, and 

2005 surveys. The U.S. Census AHS survey does not report data on freezers, so the RECS bins 

were not scaled by the AHS total as for refrigerators. Before 2005, RECS reported the age 

distribution only for a household’s first freezer, so DOE assumed that second and third freezers 

have the same age distribution as first freezers. 

The best-fit Weibull parameters for freezer lifetime are α = 19.49, β = 2.40, and θ = 5.0. 

The resulting calculated mean freezer lifetime is 22.28 years; the median is 21.73 years. Table 

8.2.13 lists the (adjusted) number of freezers reported in each RECS age bin, along with the 

modeled stock based on the best-fit Weibull survival function and the manufacturer-provided 

shipments history. Figure 8.2.5 shows the survival function used for standard-size freezers in the 

LCC and national impact analyses. 

8-25 

EERE-2008-BT-STD-0012 COMMENT 22
Table 8.2.13 Standard-Size Freezers: Comparison of Survey and Shipments Stock to 

Modeled Stock 

RECS 2005 

Age Bin years Shipments RECS Stock Modeled Stock 

0–4 12,003,000 9,378,328 12,003,000 

5–9 8,617,000 8,118,709 8,557,502 

10–19 13,571,000 9,886,011 11,269,325 

20 or more 47,672,000 7,607,227 6,973,305 

RECS 2001 

Age Bin years Shipments RECS Stock Modeled Stock 

0–4 9,284,000 8,462,128 9,284,000 

5–9 7,615,000 6,939,187 7,557,289 

10–19 12,648,000 12,144,649 10,366,534 

20 or more 42,528,000 7,494,606 7,817,703 

RECS 1997 

Age Bin years Shipments RECS Stock Modeled Stock 

0–4 7,580,000 7,192,449 7,580,000 

5–9 6,578,000 7,527,447 6,529,381 

10–19 13,920,000 12,591,552 11,241,688 

20 or more 36,203,000 6,561,157 8,045,004 

RECS 1993 

Age Bin years Shipments RECS Stock Modeled Stock 

0–4 6,700,000 6,018,630 6,700,000 

5–9 6,250,000 6,924,204 6,202,243 

10–19 17,801,000 13,279,168 14,110,780 

20 or more 27,388,000 8,277,900 6,374,921 

8-26 

EERE-2008-BT-STD-0012 COMMENT 22
21.73 

22.28 

0.0 

0.2 

0.4 

0.6 

0.8 

1.0 

1.2 

Fraction surviving 

Survival function 

Median lifetime 

Mean lifetime 

0 5 10 15 20 25 30 35 40 45 50 

Age (years) 

Figure 8.2.5 Survival Function for Standard-Size Freezers 

8.2.3.4 Compact Refrigeration Products 

As mentioned previously, compact refrigeration products are used in the residential and 

commercial sectors. RECS micro-data identify households that have refrigerators that are “halfheight” and less than 10 cubic feet in capacity. DOE considered those households as potentially 

using compact refrigerators. EIA’s Commercial Building Energy Consumption Survey (CBECS) 

survey of 20037

 notes the presence of a residential-style refrigerator in an establishment. 

However, CBECS provides no further detail regarding the size of the refrigerator. Thus, RECS 

and CBECS data together do not provide enough detail on compact refrigerators to develop a 

survival function similar to the ones developed for standard-sized refrigerator-freezers and 

freezers. 

DOE assumed that a Weibull distribution remains the appropriate functional form to 

represent retirement rates of compact refrigeration products. DOE initially used the average 

value of lifetime and historical shipments data from Appliance magazine to estimate Weibull 

parameters for compact refrigerators. When DOE applied the average lifetime of 10 years, given 

in Appliance magazine, to historical shipments, the model yielded a stock of compact 

refrigerators that was more than double the stock indicated by RECS and CBECS. DOE 

8-27 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

therefore calibrated the average lifetime to match the stock of compact refrigerators as reported 

by the surveys. 

The estimated Weibull parameters for compact refrigerator lifetime are α = 5.75 and β = 

1.75. The resulting calculated mean lifetime is 5.62 years. For determining the lifetime of 

compact freezers, DOE used a scaling factor proportional to the ratio of the lifetimes of standardsized refrigerators and standard-sized freezers. The calculated mean lifetime of a compact freezer 

is 7.46 years. 

8.2.4 Discount Rates 

The discount rate is the rate at which DOE discounts future expenditures to establish their 

present value. DOE derived discount rates for the LCC and PBP analyses from estimates of the 

cost to finance the purchase of the considered products. Following financial theory, the financal 

cost of raising funds to purchase appliances can be interpreted as: (1) the financial cost of any 

debt incurred to purchase a product, or (2) the opportunity cost of any equity used to purchase a 

product. In addition to estimating discount rates for appliances bought directly by consumers, 

DOE also estimated discount rates for purchasers of compact refrigerators and freezers in the 

commercial sector. 

8.2.4.1 Discount Rates for Residential Consumers 

Households use various methods to finance the purchase of major appliances. In 

principle, one could estimate the interest rates on the actual financing vehicles used to purchase 

appliances. The frequency with which each financing vehicle is used to purchase an appliance is 

unknown, however. 

DOE’s approach involved identifying all possible debt or asset classes that might be used 

to purchase the considered appliances, including household assets that might be affected 

indirectly.d

 DOE excluded debt from primary mortgages and the equity of assets considered 

non-liquid (such as retirement accounts), because those are unlikely to be used to purchase 

appliances. DOE estimated the average percentage shares of the various types of debt and equity 

in the average U.S. household using data from the Federal Reserve Board’s Survey of Consumer 

Finances (SCF) for 1989, 1992, 1995, 1998, 2001, 2004, and 2007.8

 Table 8.2.15 shows the 

average percentages of each considered type of debt or equity. DOE derived the mean 

percentages of each source of financing throughout the 7 years surveyed. 

d An indirect effect would arise if a household sold assets in order to pay off a loan or credit card debt that might 

have been used to finance the appliance purchase. 

8-28 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

Table 8.2.14 Types of Household Debt and Equity by Percentage Shares 

Type of Debt or Equity 1989 % 1992 % 1995 % 1998 % 2001 % 2004 % 2007 % Mean % 

Home equity loan 4.3 4.5 2.7 2.8 2.8 4.4 4.6 3.7 

Credit card 1.6 2.1 2.6 2.2 1.7 2.0 2.4 2.1 

Other installment loan 2.8 1.7 1.4 1.7 1.1 1.3 1.1 1.6 

Other residential loan 4.4 6.9 5.2 4.3 3.1 5.8 7.1 5.3 

Other line of credit 1.1 0.6 0.4 0.2 0.3 0.5 0.3 0.5 

Checking account 5.8 4.7 4.9 3.9 3.6 4.2 3.4 4.4 

Savings or money market 

account 19.2 18.8 14.0 12.8 14.2 15.1 13.0 15.3 

Certificate of deposit 14.5 11.7 9.4 7.0 5.4 5.9 6.5 8.6 

Savings bond 2.2 1.7 2.2 1.1 1.2 0.9 0.7 1.4 

Bonds 13.8 12.3 10.5 7.0 7.9 8.4 6.7 9.5 

Stocks 22.4 24.0 25.9 36.9 37.5 28.0 28.6 29.0 

Mutual funds 8.0 11.1 20.9 20.1 21.3 23.4 25.5 18.6 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Sources: Federal Reserve Board. Survey of Consumer Finances (SCF) for 1989, 1992, 1995, 1998, 2001, 2004, and 

2007. 

DOE estimated interest or return rates associated with each type of equity and debt. The 

source for interest rates for loans, credit cards, and lines of credit was the Federal Reserve 

Board’s SCF for 1989, 1992, 1995, 1998, 2001, 2004, and 2007. Table 8.2.16 shows the average 

nominal rates in each year and the inflation factors used to calculate real rates. DOE calculated 

effective interest rates for home equity loans in a similar manner as for mortgage rates, because 

interest on both such loans is tax deductible. Table 8.2.17 shows the average effective real rates 

in each year and the mean rate across years. Because the interest rates for each type of household 

debt reflect economic conditions throughout numerous years, they are expected to be 

representative of rates that may be in effect in 2014. 

Table 8.2.15 Average Nominal Interest Rates for Household Debt 

Type of Debt 1989 % 1992 % 1995 % 1998 % 2001 % 2004 % 2007 % Mean % 

Home equity loan 11.5 9.6 9.6 9.8 8.7 5.7 6.3 7.9 

Credit card* - - 14.2 14.5 14.2 11.7 7.9 9.0 

Other installment loan 9.0 7.8 9.3 7.8 8.7 7.4 12.6 13.4 

Other residential loan 8.8 7.6 7.7 7.7 7.5 6.0 10.4 8.6 

Other line of credit 14.8 12.7 12.4 11.9 14.7 8.8 6.3 7.4 

Inflation rate 4.82 3.01 2.83 1.56 2.85 2.66 2.85 

Sources: Federal Reserve Board. Survey of Consumer Finances (SCF) for 1989, 1992, 1995, 1998, 2001, 2004, and 

2007. 

* No data on interest rates available for credit cards in 1989 or 1992. 

8-29 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

Table 8.2.16 Average Real Effective Interest Rates for Household Debt 

Type of Debt 1989 % 1992 % 1995 % 1998 % 2001 % 2004 % 2007 % Mean % 

Home equity loan 3.8 4.3 4.4 5.8 3.8 1.9 2.1 3.0 

Credit card* - - 11.0 12.7 11.1 9.1 3.3 3.9 

Other installment loan 4.9 5.8 7.0 6.6 6.1 5.4 9.7 10.7 

Other residential loan 4.0 4.7 4.8 6.0 4.6 3.3 5.8 6.0 

Other line of credit 9.6 9.4 9.3 10.2 7.3 6.0 3.4 4.4 

Sources: Federal Reserve Board. Survey of Consumer Finances (SCF) for 1989, 1992, 1995, 1998, 2001, 

2004, and 2007. 

* No data on interest rates available for credit cards in 1989 or 1992. 

No similar rate data are available from the SCF for classes of assets, so the Department 

derived that information from national historical data. The interest rates associated with 

certificates of deposit,9

 savings bonds,10 and bonds (AAA corporate bonds)11 were collected from 

Federal Reserve Board time-series data for 1977–2008. DOE assumed rates on checking 

accounts to be zero. Rates on savings and money market accounts came from Cost of Savings 

Index data covering 1984–2008. 12 The rates for stocks are the annual returns on the Standard and 

Poor’s 500 for 1977–2008. 13 Rates for mutual funds are a weighted average of the stock rates 

(two-thirds weight) and the bond rates (one-third weight) in each year for 1977–2008. DOE 

adjusted the nominal rates to real rates using the annual inflation rate for each year. Average 

nominal and real interest rates for the classes of household assets are listed in Table 8.2.18. 

Because the interest and return rates for each type of asset reflect economic conditions 

throughout numerous years, they are expected to be representative of rates that may be in effect 

in 2014. 

Table 8.2.17 Average Nominal and Real Interest Rates for Household Equity 

Type of Equity Average Nominal Rate % Average Real Rate % 

Checking account - 0.0 

Savings and money market accounts 5.4 2.2 

Certificate of deposit 6.6 2.3 

Savings bond 7.7 3.3 

Bonds 8.5 4.1 

Stocks 11.6 7.1 

Mutual funds 10.3 5.8 

Table 8.2.19 summarizes the mean real effective rates of each type of equity or debt. 

DOE determined the average percentage of each type of debt and asset using SCF data for 1989, 

1992, 1995, 1998, 2001, 2004, and 2007. Each year of SCF data provides the percents of debts 

and assets for U.S. households. DOE averaged those percentages for the 7 years of survey data to 

arrive at the percentages shown in Table 8.2.19. The average rate across all types of household 

debt and equity, weighted by the percentages of each type, is 4.8 percent. 

8-30 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

Table 8.2.18 Average Interest on Household Debt and Equity 

Type of Debt or Equity 

Average % of Household 

Debt plus Equity* 

Mean Effective Real Rate 

%** 

Home equity loan 3.7 3.9 

Credit card 2.1 10.7 

Other installment loan 1.6 6.0 

Other residential loan 5.3 4.4 

Other line of credit 0.5 8.8 

Checking account 4.4 0.0 

Savings and money market account 15.3 2.2 

Certificate of deposit 8.6 2.3 

Savings bond 1.4 3.3 

Bonds 9.5 4.1 

Stocks 29.0 7.1 

Mutual funds 18.6 5.8 

Total/weighted-average discount rate 100.0 4.8 

* Not including primary mortgage or retirement accounts.
 

** Adjusted for inflation and, for home equity loans, tax deduction of interest.
 

8.2.4.2 Assignment of Discount Rates to Sample Households 

To account for variations among households, DOE assigned each sampled RECS 

household a rate from a distribution of rates for each type of debt and equity. DOE developed a 

probability distribution of interest rates based on SCF data. Appendix 8-C presents the 

probability distribution of interest rates that DOE used in the LCC and PBP analyses. 

8.2.4.3 Discount Rates for Commercial Purchasers 

DOE derived the discount rate for commercial owners of compact refrigeration products 

from the cost of capital of publicly traded firms in the sectors that purchase those products. The 

firms typically finance equipment purchases through debt and/or equity capital. DOE estimated 

the cost of the firms’ capital as the weighted average of the cost of equity financing and the cost 

of debt financing for each year between 2001 and 2008. 

The costs of debt and equity financing usually are publicly available for firms in the 

lodging and other commercial sectorse

 that may purchase compact refrigeration products. 

DOE estimated the cost of equity using the capital asset pricing model (CAPM).14 The 

CAPM assumes that the cost of equity (ke) for a given company is proportional to the systematic 

risk faced by that company, whereby high risk is associated with a high cost of equity and low 

e

 The “other commercial” sector includes financial institutions and all services other than lodging (SIC 6-8). 

8-31 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

risk is associated with a low cost of equity. The systematic risk facing a firm is determined by 

several variables: the risk coefficient of the firm (β), the expected return on risk-free assets (Rf), 

and the equity risk premium (ERP). The risk coefficient of a firm describes the risk associated 

with that firm represented by standard deviations in the firm’s stock price. The expected return 

on risk-free assets is defined by the yield on long-term government bonds. The ERP represents 

the difference between the expected stock market return and the risk-free rate. To estimate the 

expected return on risk-free assets and the equity risk premium, DOE used stock and bond data 

from Damodaran Online, a widely used source of information about debt and equity financing 

for most types of firms. 15,16 The Damodaran Online data were adjusted for annual inflation 

using deflator data for the gross domestic product from the Bureau of Economic Analysis’ 

National Income and Product Accounts Tables.

17 

The cost of equity financing is estimated using the following equation: 

ke = Rf + (β× ERP) 

Where: 

ke = cost of equity, 

Rf = inflation-adjusted expected return on risk-free assets,f
 

β = risk coefficient of the firm, and 

ERP = equity risk premium.
 

The cost of debt financing (kd) is the interest rate paid on money a company borrows. The 

cost of debt is estimated by adding a risk adjustment factor (Ra) to the risk-free rate. This risk 

adjustment factor depends on the variability of stock returns represented by standard deviations 

in the firm’s stock price. Thus for firm i, the cost of debt financing is: 

k di f ai = R + R

Where: 

kd = cost of debt financing for firm i, 

Rf = expected return on risk-free assets, and 

Rai = risk adjustment factor to risk-free rate for firm i. 

DOE estimates the weighted-average cost of capital using the following equation. 

WACC = k e e d d × w + k × w

Where: 

WACC = weighted average cost of capital, 

f

 Ibbotson Associates argues that the arithmetic mean equates the expected future value with the present value and 

should be used in calculating the risk-free rate and equity risk premium when using CAPM to estimate discount 

rates (Stocks, Bonds, Bills, and Inflation 2009 Yearbook, Ibbotson Associates, p. 60). 

8-32 

EERE-2008-BT-STD-0012 COMMENT 22
 

we = proportion of equity financing, and 

wd = proportion of debt financing. 

The values of the parameters used in the calculations are shown in Table 8.2.20. 

Table 8.2.19 Data for Calculating Weighted-Average Cost of Capital for Commercial 

Sectors 

Sector Year β Rf 

% 

ERP 

% 

Ra 

% 

we 

% 

wd 

% 

2001 1.18 3.25 5.17 1.50 88 12 

2002 1.27 3.55 3.66 1.50 89 11 

2003 1.71 3.40 4.70 1.25 93 7 

Lodging 2004 0.98 3.43 4.34 1.00 89 11 

2005 1.45 3.36 4.08 1.25 93 7 

2006 1.24 3.36 4.13 1.25 93 7 

2007 1.25 3.54 4.33 1.00 96 4 

2008 1.23 4.10 2.33 2.00 86 14 

2001 0.87 3.25 5.17 3.50 77 23 

2002 0.92 3.55 3.66 3.50 77 23 

2003 0.87 3.40 4.70 1.50 81 19 

Other 

Commercial 

2004 0.90 3.43 4.34 1.25 84 16 

2005 0.88 3.36 4.08 1.50 82 18 

2006 0.91 3.36 4.13 2.00 84 16 

2007 0.87 3.54 4.33 1.25 79 21 

2008 0.93 4.10 2.33 3.00 68 32 

Note: Parameters are defined on the preceding two pages. 

Using the procedure described above and the data in Table 8.2.20, DOE developed the 

real weighted-average cost of capital for the two commercial sectors that purchase compact 

refrigeration products. Those costs are listed in Table 8.2.21. 

8-33 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 8.2.20 Weighted-Average Cost of Capital for Commercial Sectors 

Year Lodging % Other Commercial % 

2001 5.69 6.75 

2002 5.11 6.21 

2003 5.49 6.64 

2004 5.82 6.62 

2005 5.95 6.24 

2006 6.04 6.46 

2007 6.42 6.40 

2008 5.74 5.60 

Sector average 5.78 6.37 

In calculating the discount rate for companies that typically purchase compact 

refrigeration products, DOE generated a distribution of discount rates within each sector. The 

standard deviation of the distribution for each sector is provided in Table 8.2.22. Weighting each 

sector’s discount rate by its share of compact refrigerator purchases,g

 DOE estimated that the 

average discount rate for companies that purchase compact refrigeration products is 6.20 percent. 

Table 8.2.21 Discount Rates for Commercial Sectors 

Sector 

Discount Rate 

Average % % of Purchases Max. % Min. % Standard Deviation % 

Lodging 5.78 11.98 2.35 1.26 29 

Other commercial 6.37 15.65 2.48 1.72 71 

Weighted average 6.20 - - - 100 

To account for variations in discount rates within each sector, DOE applied a normal 

probability distribution to the average values and standard deviations in Table 8.2.22. DOE 

truncated the normal distribution using the maximum and minimum values presented in Table 

8.2.22. 

8.2.5 Effective Date of Standard 

The effective date of a potential new standard is the future date when it would become 

operative. Based on DOE’s implementation report for energy conservation standards activities 

submitted pursuant to section 141 of the Energy Policy Act of 2005, a final rule pertaining to the 

appliances being considered for this rulemaking is scheduled for December 2010.18 The effective 

date of any new energy efficiency standards for the products is 3 years after the final rule is 

g

 The approach for estimating the share of total purchases by each of the two commercial sectors is described in 

chapter 9. 

8-34 

EERE-2008-BT-STD-0012 COMMENT 22
 

published, or January 2014. The Department calculated the life-cycle cost (LCC) for all 

consumers as if each would purchase a new appliance in the year the standard is to take effect. 

8.2.6 Base-Case Energy Efficiencies 

To estimate the percentage of consumers who would be affected by a standard at any of 

the potential efficiency levels, in its LCC analysis DOE considered the projected distribution of 

efficiencies for products that consumers purchase under the base case (the case without new 

energy efficiency standards). DOE refers to this distribution of product energy efficiencies as the 

base-case efficiency distribution. Using the projected distribution of efficiencies for each product 

class, DOE randomly assigned a product efficiency to each sample household. If a household 

was assigned a product efficiency that was greater than or equal to the efficiency of the standard 

level under consideration, the LCC calculation would show that this household would not be 

affected by that standard level. 

DOE began with the energy efficiency distribution (market shares) for refrigeration 

products in 2007 based on data provided by AHAM19. In 2007, efficiency level 2 for 

refrigerator-freezers corresponded to the efficiency required for ENERGY STAR certification. In 

2008, the criteria changed so that efficiency level 3 corresponded to the efficiency required for 

ENERGY STAR certification. If the market shares of refrigeration products by efficiency were 

the same in 2008 as in 2007, the ENERGY STAR market share would be 0 percent for topmount refrigerators, 18 percent for bottom-mount refrigerators, and 2 percent for side-by-side 

refrigerators. 

Efforts to promote ENERGY STAR products through various means, including consumer 

rebates, are expected to increase their market shares by 2014. Although it is difficult to predict 

appliance sales in 2014, it is reasonable to assume that the increase in market shares of ENERGY 

STAR products will follow the same pattern as they did between 2001 (the year in which the 

current DOE standards took effect and caused a shift in ENERGY STAR requirements) and 

2007. The projected market shares of efficiency levels are shown in Table 8.2.23. As shown, the 

assumed market share of ENERGY STAR models in 2014 (under current requirements) is equal 

to the market share of ENERGY STAR models in 2007 (under the old requirements). For 

example, because 32 percent of side-by-side refrigerator-freezers qualified for ENERGY STAR 

(efficiency level 2 and higher) under the pre-2008 requirements, DOE assumed that 32 percent 

would meet ENERGY STAR requirements (efficiency level 3) in 2014. DOE also assumed that 

the market shares of lower-efficiency models (i.e., baseline and 10 percent below baseline) 

would stay the same between 2007 and 2014. 

8-35 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 8.2.22 Standard-Size Refrigerator-Freezers: Base-Case Efficiency Distributions 

Efficiency Level 

(% less than baseline 

energy use) 

Product Class 3: 

Top-Mount 

Refrigerator-Freezer 

Product Class 5: 

Bottom-Mount 

Refrigerator-Freezer 

Product Class 7: 

Side-by-Side 

Refrigerator-Freezer with 

TTD* 

Market Share 

% 

Market Share 

% 

Market Share 

% 

2007 2014 2007 2014 2007 2014 

Baseline 81 81 12 12 25 25 

1 (10) 6 6 0 0 43 43 

2 (15) 13 0 70 0 30 0 

3 (20)†

 0 13 18 88 2 32 

4 (25) 0 0 0 0 0 0 

5 (30) 0 0 0 0 0 0 

* Through-the-door ice service. 

†

 Meets 2008 ENERGY STAR criteria. 

ENERGY STAR requirements for standard-size freezers and compact products have not 

changed since 2001. Those ENERGY STAR requirements correspond to efficiency level 1 for 

standard-size freezers and level 3 for compact products. DOE assumed that the market shares of 

those ENERGY STAR products would remain the same between 2007 and 2014 (Tables 8.2.24 

and 8.2.25). 

Table 8.2.23 Standard-Size Freezers: Base-Case Efficiency Distributions 

Efficiency Level 

(% less than baseline energy 

Product Class 9: 

Upright Freezer 

Product Class 10: 

Chest Freezer 

Market Share 

% 

Market Share 

% 

use) 2007 2014 2007 2014 

Baseline 82 82 85 85 

1 (10)* 17 17 14 14 

2 (15) 1 1 1 1 

3 (20) 0 0 0 0 

4 (25) 0 0 2 2 

5 (30) 0 0 0 0 

* Meets 2008 ENERGY STAR criteria. 

8-36 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 8.2.24 Compact Refrigeration Products: Base-Case Efficiency Distributions 

Efficiency Level 

(% less than baseline energy 

use) 

Product Class 11: 

Compact Refrigerator 

Product Class 18: 

Compact Freezer 

Market Share 

% 

Market Share 

% 

2007 2014 2007 2014 

Baseline 97 97 95 95 

1 (10) 0 0 5 5 

2 (15) 0 0 0 0 

3 (20)* 1 1 0 0 

4 (25) 2 2 0 0 

5 (30) 0 0 0 0 

* Meets 2008 ENERGY STAR criteria. 

8.3 INPUTS TO PAYBACK PERIOD ANALYSIS 

The payback period (PBP) refers to the time it takes a consumer to recover, through 

lower operating costs, the assumed higher purchase cost of more energy efficient products. 

Numerically, the PBP is the ratio of the increase in purchase cost (from a less to a more efficient 

design) to the decrease in annual operating cost. This type of calculation is known as a simple 

payback period, because it does not account for changes in operating cost over time or the time 

value of money. That is, the calculation is performed at an effective discount rate of 0 percent. 

The equation for determining PBP is: 

ΔIC

PBP = ΔOC 

Where: 

ΔIC = the difference in total installed cost between the more efficient design based on the new 

standard level and the baseline design, and 

ΔOC = the difference in annual operating cost between the two units. 

Payback periods are expressed in years. Payback periods greater than the life of a product 

mean that the increased total installed cost is not recovered through reduced operating cost. 

The data inputs to calculating PBP are the total installed cost to the consumer for each 

product at each efficiency level and the annual (first-year) operating cost for each efficiency 

level. The inputs to calculating total installed cost are the product and installation costs. The 

inputs to calculating operating cost are the annual energy, repair, and maintenance costs. The 

PBP uses the same inputs as the LCC analysis described in section 8.2, except that no energy 

8-37 

EERE-2008-BT-STD-0012 COMMENT 22
price trends, product lifetimes, or discount rates are required. Because the PBP is a simple 

payback, the only energy price required is for the year in which a new standard takes effect—in 

this case, the price projected for 2014. 

8.4 RESULTS OF ANALYSES 

This section presents the results of the life-cycle cost (LCC) and payback period (PBP) 

analyses for the considered efficiency levels for refrigeration products. As discussed in section 

8.1.1, DOE’s approach to the LCC analysis involved developing a sample of consumers who use 

each product. DOE also used probability distributions to characterize the uncertainty in many of 

the analytical inputs. DOE used a Monte Carlo simulation technique to perform the LCC 

calculations on data pertaining to the consumers in each sample. For each set of sample 

consumers who use the appliance in each product class, DOE calculated the average LCC, the 

LCC savings, and the median and average PBP for each standard level. 

DOE calculated LCC savings and PBPs relative to the base-case product that it assigned 

to the sampled consumers. As discussed in section 8.2.6, DOE assigned some consumers a basecase product that is more efficient than the baseline product. For that reason, average LCC 

impacts are not equal to the difference between the LCC of a specific possible standard level and 

the LCC of the baseline product. 

In the following subsections, DOE presents figures showing the distribution of LCCs in 

the base case for each product class. Also presented are figures showing the distribution of LCC 

impacts and the distribution of PBPs for specific possible standard levels. The figures represent 

frequency charts that include probabilities of occurrence for the distributions of LCC impacts 

and PBPs. DOE generated the figures for the distributions from a Monte Carlo simulation that 

utilized 10,000 samples. 

LCC and PBP calculations were performed 10,000 times on the sample of consumers 

developed for each product. Each calculation was performed on a single consumer who was 

selected from the sample. The selection was based on weight, that is on how representative a 

particular consumer was of other consumers in the national distribution. Each LCC and PBP 

calculation also sampled from the probability distributions that DOE developed to characterize 

many of the inputs to the analysis. 

Based on the Monte Carlo simulations that DOE performed, for each efficiency level, 

DOE calculated the percentage of consumers who would experience a net LCC benefit, a net 

LCC cost, or no impact. DOE considered a consumer to receive no impact at a given efficiency 

level if the base-case product DOE assigned to that consumer had the same or higher efficiency 

than that of the new standard being evaluated. Note that the average LCC savings at each 

efficiency level are relative to the base-case efficiency distribution, not the baseline efficiency 

level. 

8-38 

EERE-2008-BT-STD-0012 COMMENT 22
 

8.4.1 Standard-Size Refrigerator-Freezers 

The following subsections summarize results of LCC and PBP analyses for standard-size 

refrigerator-freezers and present figures showing the distribution of LCCs in the base case for 

each product class. Also presented are figures showing the distribution of LCC impacts and the 

distribution of PBPs for specific efficiency levels. 

8.4.1.1 Summary of Results 

Tables 8.4.1 through 8.4.3 show the LCC and PBP results for each refrigerator-freezer 

product class considered for new standards. DOE determined the median and average values for 

PBPs at each efficiency level by excluding those households that would not be affected by the 

standard. 

Table 8.4.1 Product Class 3, Top-Mount Refrigerator-Freezers: Analytical Results 

Efficiency 

Level 

(% less than 

Life-Cycle Cost 2008$ Life-Cycle Cost Savings 

Payback Period 

(years) 

Average 

Average 

Annual Average 

% of Households that 

Experience 

Median Average 

baseline 

energy use) 

Product 

Cost 

Operating 

Cost 

Average 

LCC 

Savings 

2008$ 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 591 77 1,505 

1 (10) 595 71 1,434 71 0.0 18.5 81.5 0.6 0.7 

2 (15) 599 67 1,398 106 0.0 13.0 86.9 0.9 1.1 

3 (20) 609 64 1,368 137 0.1 13.0 86.8 1.5 1.7 

4 (25) 631 60 1,343 162 2.6 0.0 97.4 2.8 3.2 

5 (30) 665 56 1,329 176 7.0 0.0 93.0 4.0 4.6 

6 (35) 716 52 1,333 172 16.5 0.0 83.5 5.6 6.4 

7 (40) 781 48 1,350 155 28.2 0.0 71.8 7.3 8.3 

8 (45) 845 44 1,367 138 36.3 0.0 63.7 8.5 9.7 

8-39 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 8.4.2 Product Class 5, Bottom-Mount Refrigerator-Freezers: Analytical 

Results 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost 2008$ Life-Cycle Cost Savings 

Payback Period 

years 

Average 

Product 

Cost 

Average 

Annual 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

2008$ 

% of Households that 

Experience 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 1,758 70 2,591 

1 (10) 1,759 69 2,581 11 0.0 88.5 11.5 0.3 0.4 

2 (15) 1,759 69 2,576 16 0.0 88.4 11.6 0.7 0.8 

3 (20) 1,760 68 2,571 20 0.0 88.4 11.6 1.2 1.4 

4 (25) 1,782 64 2,542 49 14.8 0.0 85.2 5.1 6.0 

5 (30) 1,799 60 2,508 83 11.2 0.0 88.8 4.6 5.4 

6 (35) 1,879 55 2,538 54 44.1 0.0 55.9 9.5 11.0 

7 (40) 1,969 51 2,577 14 60.5 0.0 39.5 12.6 14.7 

8 (45) 2,053 47 2,610 -19 67.0 0.0 33.0 14.3 16.6 

Table 8.4.3 Product Class 7, Side-by-Side Refrigerator-Freezers with Through-theDoor Ice Service: Analytical Results 

Efficiency 

Level 

(% less than 

Life-Cycle Cost 2008$ Life-Cycle Cost Savings 

Payback Period 

years 

Average 

Average 

Annual Average 

% of Households that 

Experience 

Median Average 

baseline 

energy use) 

Product 

Cost 

Operating 

Cost 

Average 

LCC 

Savings 

2008$ 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 1,459 116 2,840 

1 (10) 1,463 113 2,804 35 0.0 74.3 25.7 1.1 1.3 

2 (15) 1,469 108 2,759 80 0.1 31.6 68.4 1.5 1.6 

3 (20) 1,499 104 2,738 102 3.1 31.6 65.4 3.8 4.2 

4 (25) 1,563 97 2,724 116 23.8 0.0 76.2 6.7 7.6 

5 (30) 1,638 91 2,722 117 32.7 0.0 67.3 8.1 9.0 

6 (35) 1,714 84 2,721 119 38.5 0.0 61.5 8.9 9.9 

7 (40) 1,815 78 2,744 95 46.2 0.0 53.9 10.1 11.2 

8.4.1.2 Distributions of Impacts 

Figure 8.4.1 presents a frequency chart that shows the distribution of LCC impacts for the 

case of efficiency level 5 for top-mount refrigerator-freezers. The note, “Certainty is 93.01% 

from $0 to +Infinity,” means that 93.01 percent of households owning top-mount refrigeratorfreezers either will not be affected or will have LCC savings under the standard compared to the 

base case. DOE could generate a similar frequency chart for every efficiency level. 

8-40 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Frequency Chart 

Certainty is 93.01% from $0 to +Infinity 

.000 

.005 

.011 

.016 

.021 

0 

53.5 

107 

160.5 

214 

($76) $109 $294 $479 $663 

10,000 Trials 9,715 Displayed 

Forecast: LCCSav_Level5 

Figure 8.4.1 Product Class 3, Top-Mount Refrigerator-Freezers: Distribution of 

Life-Cycle Cost Impacts for Efficiency Level 5 

Figure 8.4.2 is an example of a frequency chart showing the distribution of payback 

periods for efficiency level 5 for top-mount refrigerator-freezers. DOE could generate a similar 

frequency chart for every efficiency level. 

Frequency Chart 

.000 

.007 

.013 

.020 

.027 

0 

66.5 

133 

199.5 

266 

-1.00 2.46 5.93 9.39 12.86 

10,000 Trials 9,812 Displayed 

Forecast: PP_Level5 

Figure 8.4.2 Product Class 3, Top-Mount Refrigerator-Freezers: Distribution of 

Payback Periods for Efficiency Level 5 

8-41 

EERE-2008-BT-STD-0012 COMMENT 22
Figures 8.4.3 through 8.4.5 show the range of LCC savings for all the efficiency levels 

considered for each refrigerator-freezer product class. For each efficiency level, the top and 

bottom of the box in the figure indicate the 75th and 25th percentiles, respectively. The bar at the 

middle of the box indicates the median: 50 percent of households have LCC savings that exceed 

this value. The horizontal lines above and below each box indicate the 95th and 5th percentiles, 

respectively. The small box indicates the average LCC savings for each efficiency level. 

-200 

-100 

0 

100 

200 

300 

400 

500 

600 

700 

800 

1 2 3 4 5 6 7 8 

Efficiency Level 

Life-cycle Cost Savings($) 

Mean Median 

Figure 8.4.3 Product Class 3, Top-Mount Refrigerator-Freezers: Range of Life-Cycle 

Cost Savings by Efficiency Level 

8-42 

EERE-2008-BT-STD-0012 COMMENT 22
-300 

-200 

-100 

0 

100 

200 

300 

400 

500 

1 2 3 4 5 6 7 8 

Efficiency Level 

Life-cycle Cost Savings($) 

Mean Median 

Figure 8.4.4 Product Class 5, Bottom-Mount Refrigerator-Freezers: Range of LifeCycle Cost Savings by Efficiency Level Life-cycle Cost Savings($) 

800
 

700
 

600
 

500
 

400
 

300
 

200
 

100
 

0
 

-100
 

Mean
 Median -200 

-300 

1 2 3 4 5 6 7 

Efficiency Level 

Figure 8.4.5 Product Class 7, Side-by-Side Refrigerator-Freezers: Range of Life-Cycle 

Cost Savings by Efficiency Level 

Figures 8.4.6 through 8.4.8 show the range of PBPs for all efficiency levels considered 

for each analyzed refrigerator-freezer product class. For each efficiency level, the top and bottom 

of the box in the figure indicate the 75th and 25th percentiles, respectively. The bar at the middle 

8-43 

EERE-2008-BT-STD-0012 COMMENT 22
of the box indicates the median: 50 percent of the households have a PBP above this value. The 

horizontal lines above and below each box indicate the 95th and 5th percentiles, respectively. The 

small box indicates the average PBP for each efficiency level. 

0 

2 

4 

6 

8 

10 

12 

14 

16 

18 

20 

1 2 3 4 5 6 7 8 

Efficiency Level 

Payback Period(yr) 

Mean Median 

Figure 8.4.6 Product Class 3, Top-Mount Refrigerator-Freezers: Range of Payback 

Periods by Efficiency Level 

0 

5 

10 

15 

20 

25 

30 

35 

1 2 3 4 5 6 7 8 

Efficiency Level 

Payback Period(yr) 

Mean Median 

Figure 8.4.7 Product Class 5, Bottom-Mount Refrigerator-Freezers: Range of Payback 

Periods by Efficiency Level 

8-44 

EERE-2008-BT-STD-0012 COMMENT 22
 

0 

5 

10 

15 

20 

25 

1 2 3 4 5 6 7 

Efficiency Level 

Payback Period(yr) 

Mean Median 

Figure 8.4.8 Product Class 7, Side-by-Side Refrigerator-Freezers: Range of Payback 

Periods by Efficiency Level 

8.4.2 Standard-Size Freezers 

The following subsections summarize results of LCC and PBP analyses for standard-size 

freezers and present figures showing the distribution of LCCs in the base case for both product 

classes. Also presented are figures showing the distribution of LCC impacts and the distribution 

of PBPs for specific efficiency levels. 

8.4.2.1 Summary of Results 

Tables 8.4.4 and 8.4.5 show the LCC and PBP results for each freezer product class 

considered for new standards. DOE determined the median and average values for PBPs at each 

efficiency level by excluding those households not affected by a standard. 

8-45 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 8.4.4 Product Class 9, Upright Freezers: Analytical Results 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost 2008$ Life-Cycle Cost Savings 

Payback Period 

years 

Average 

Equipment 

Cost 

Average 

Annual 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

2008$ 

% of Households that 

Experience 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 505 113 2,064 

1 (10) 511 104 1,942 122 0.0 19.4 80.6 0.7 0.8 

2 (15) 517 98 1,870 194 0.0 1.6 98.4 0.9 1.1 

3 (20) 520 92 1,793 271 0.0 0.5 99.5 0.7 0.9 

4 (25) 537 87 1,731 333 0.0 0.4 99.6 1.3 1.5 

5 (30) 561 81 1,675 389 0.3 0.2 99.6 1.8 2.1 

6 (35) 598 75 1,633 432 1.2 0.0 98.8 2.5 3.0 

7 (40) 656 69 1,611 453 4.0 0.0 96.0 3.5 4.3 

8 (45) 745 63 1,621 443 9.9 0.0 90.1 5.0 6.0 

Table 8.4.5 Product Class 10, Chest Freezer: Analytical Results 

Efficiency 

Level 

(% less than 

Life-Cycle Cost 2008$ Life-Cycle Cost Savings 

Payback Period 

years 

Average 

Average 

Annual Average 

% of Households that 

Experience 

Median Average 

baseline 

energy use) 

Equipment 

Cost 

Operating 

Cost 

Average 

LCC 

Savings 

2008$ 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 325 69 1,275 

1 (10) 328 63 1,196 79 0.0 15.3 84.8 0.4 0.5 

2 (15) 332 60 1,153 122 0.0 1.1 98.9 0.8 1.0 

3 (20) 355 56 1,127 148 1.2 0.2 98.6 2.5 3.0 

4 (25) 361 53 1,085 190 0.7 0.2 99.2 2.4 2.8 

5 (30) 368 49 1,044 231 0.4 0.2 99.4 2.3 2.7 

6 (35) 416 46 1,044 231 5.3 0.0 94.7 4.2 4.9 

7 (40) 420 42 999 276 3.7 0.0 96.3 3.8 4.4 

8 (45) 493 39 1,024 251 13.8 0.0 86.2 6.0 6.9 

8.4.2.2 Distributions of Impacts 

Figure 8.4.9 presents a frequency chart showing the distribution of LCCs for the case of 

standard level 5 for upright freezers. The note, “Certainty is 99.67 % from $0 to +Infinity,” 

means that 99.67 percent of households owning upright freezers either will not be affected or 

will have LCC savings under the standard level compared to the base case. DOE could generate 

a similar frequency chart for every efficiency level. 

8-46 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Frequency Chart 

Certainty is 99.67% from $0 to +Infinity 

.000 

.004 

.009 

.013 

.017 

0 

43.25 

86.5 

129.7 

173 

($28) $261 $550 $840 $1,129 

10,000 Trials 9,739 Displayed 

Forecast: LCCSav_Level5 

Figure 8.4.9 Product Class 9, Upright Freezers: Distribution of Life-Cycle Cost 

Impacts for Efficiency Level 5 

Figure 8.4.10 presents a frequency chart showing the distribution of payback periods for 

standard level 5 for upright freezers. DOE could generate a similar frequency chart for every 

efficiency level within each product class. 

Frequency Chart 

.000 

.012 

.024 

.036 

.048 

0 

118.7 

237.5 

356.2 

475 

-1.09 0.73 2.54 4.36 6.18 

10,000 Trials 9,699 Displayed 

Forecast: PP_Level5 

Figure 8.4.10 Product Class 9, Upright Freezers: Distribution of Payback 

Periods for Efficiency Level 5 

8-47
 

EERE-2008-BT-STD-0012 COMMENT 22
Figures 8.4.11 and 8.4.12 show the range of LCC savings for the efficiency levels 

considered for each freezer product class. For each standard level, the top and bottom of the box 

indicate the 75th and 25th percentiles, respectively. The bar at the middle of the box indicates the 

median: 50 percent of the households have LCC savings that exceed this value. The horizontal 

lines above and below the box indicate the 95th and 5th percentiles, respectively. The small box 

shows the average LCC savings for each efficiency level. 

-200 

0 

200 

400 

600 

800 

1000 

1200 

1400 

1 2 3 4 5 6 7 8 

Efficiency Level 

Life-cycle Cost Savings($) 

Mean Median 

Figure 8.4.11 Product Class 9, Upright Freezers: Range of Life-Cycle Cost Savings by 

Efficiency Level 

8-48
 

EERE-2008-BT-STD-0012 COMMENT 22
-100 

0 

100 

200 

300 

400 

500 

600 

700 

800 

900 

1 2 3 4 5 6 7 8 

Efficiency Level 

Life-cycle Cost Savings($) 

Mean Median 

Figure 8.4.12 Product Class 10, Chest Freezers: Range of Life-Cycle Cost Savings by 

Efficiency Level 

Figures 8.4.13 and 8.4.14 show the range of PBPs for the efficiency levels considered for 

each freezer product class. For each standard level, the top and bottom of the box indicate the 

75th and 25th percentiles, respectively. The bar at the middle of the box indicates the median: 50 

percent of the households have PBPs that exceed this value. The horizontal lines above and 

below the box indicate the 95th and 5th percentiles, respectively. The small box shows the 

average PBP for each efficiency level. 

8-49 

EERE-2008-BT-STD-0012 COMMENT 22
0 

2 

4 

6 

8 

10 

12 

14 

1 2 3 4 5 6 7 8 

Efficiency Level 

Payback Period(yr) 

Mean Median 

Figure 8.4.13 Product Class 9, Upright Freezers: Range of Payback Periods by 

Efficiency Level 

0 

2 

4 

6 

8 

10 

12 

14 

16 

1 2 3 4 5 6 7 8 

Efficiency Level 

Payback Period(yr) 

Mean Median 

Figure 8.4.14 Product Class 10, Chest Freezers: Range of Payback Periods by 

Efficiency Level 

8.4.3 Compact Refrigeration Products 

The following subsections summarize results of LCC and PBP analyses for compact 

refrigeration products and present figures showing the distribution of LCCs in the base case for 

8-50 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

both product classes. Also presented are figures showing the distribution of LCC impacts and the 

distribution of PBPs for specific efficiency levels. 

8.4.3.1 Summary of Results 

Tables 8.4.6 and 8.4.7 show the results of LCC and PBP analyses for compact 

refrigerators and freezers. DOE determined the median and average values of PBPs by excluding 

those households not affected by a standard at each efficiency level. 

Table 8.4.6 Product Class 11, Compact Refrigerators: Analytical Results 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Life-Cycle Cost $2008 Life-Cycle Cost Savings 

Payback Period 

years 

Average 

Product 

Cost 

Average 

Annual 

Operating 

Cost 

Average 

LCC 

Average 

Savings 

$2008 

% of Consumers who 

Experience 

Median Average 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 166 33 325 

1 (10) 170 30 314 12 4.2 2.9 92.8 1.4 1.3 

2 (15) 173 28 309 16 8.1 2.6 89.4 1.7 1.7 

3 (20) 176 26 305 21 9.3 2.6 88.1 1.8 1.8 

4 (25) 191 25 311 14 34.1 1.7 64.2 3.4 3.3 

5 (30) 192 23 304 21 26.9 0.0 73.2 2.9 2.8 

6 (35) 198 21 303 23 30.5 0.0 69.6 3.1 3.0 

7 (40) 214 20 310 15 44.6 0.0 55.4 4.0 3.9 

8 (45) 236 18 324 1 62.2 0.0 37.8 5.3 5.1 

Table 8.4.7 Product Class 18, Compact Freezers: Analytical Results 

Efficiency 

Level 

(% less than 

Life-Cycle Cost $2008 Life-Cycle Cost Savings 

Payback Period 

years 

Average 

Average 

Annual Average 

% of Consumers who 

Experience 

Median Average 

baseline 

energy use) 

Product 

Cost 

Operating 

Cost 

Average 

LCC 

Savings 

$2008 

Net 

Cost 

No 

Impact 

Net 

Benefit 

Baseline 207 34 399 

1 (10) 214 30 388 11 9.6 5.0 85.4 2.4 2.3 

2 (15) 218 29 382 16 11.7 0.0 88.3 2.5 2.5 

3 (20) 248 27 403 -4 65.8 0.0 34.2 6.7 6.8 

4 (25) 259 25 404 -5 65.6 0.0 34.4 6.7 6.7 

5 (30) 281 24 416 -17 76.5 0.0 23.5 7.9 7.9 

6 (35) 284 22 410 -11 69.3 0.0 30.7 7.1 7.1 

7 (40) 299 20 415 -16 72.0 0.0 28.0 7.4 7.4 

8 (45) 317 19 423 -24 75.9 0.0 24.1 7.8 7.8 

8-51 

EERE-2008-BT-STD-0012 COMMENT 22
 

8.4.3.2 Distributions of Impacts 

Figure 8.4.15 presents a frequency chart showing the distribution of LCCs for the case of 

efficiency level 5 for compact refrigerators. The note, “Certainty is 71.04% from $0 to 

+Infinity,” means that 71.04 percent of households owning compact refrigerators either will not 

be affected or will have LCC savings under the standard level compared to the base case. DOE 

could generate a similar frequency chart for every efficiency level. 

Frequency Chart 

Certainty is 71.04% from $0 to +Infinity 

.000 

.006 

.011 

.017 

.022 

0 

56 

112 

168 

224 

($22) $15 $53 $91 $129 

10,000 Trials 9,759 Displayed 

Forecast: LCCSav5 

Figure 8.4.15 Product Class 11, Compact Refrigerators: Distribution of Life-Cycle Cost 

Impacts for Efficiency Level 5 

Figure 8.4.16 presents a frequency chart showing the distribution of payback periods for 

efficiency level 5 for compact refrigerators. DOE could generate a similar frequency chart for 

every efficiency level within each product class. 

8-52 

EERE-2008-BT-STD-0012 COMMENT 22
Frequency Chart 

.000 

.010 

.020 

.030 

.040 

0 

99.5 

199 

298.5 

398 

1.05 2.06 3.07 4.08 5.09 

10,000 Trials 9,812 Displayed 

Forecast: PPLev5 

Figure 8.4.16 Product Class 11, Compact Refrigerators: Distribution of 

Payback Period for Efficiency Level 5 

Figures 8.4.17 and 8.4.18 show the range of LCC savings for the standard levels 

considered for compact refrigerators and freezers. For each standard level, the top and bottom of 

the box indicate the 75th and 25th percentiles, respectively. The bar at the middle of the box 

indicates the median: 50 percent of the households have LCC savings that exceed this value. The 

horizontal lines above and below the box indicate the 95th and 5th percentiles, respectively. The 

small box shows the average LCC savings for each efficiency level. Figures 8.4.19 and 8.4.20 

show the range of PBPs for each efficiency level considered. 

8-53 

EERE-2008-BT-STD-0012 COMMENT 22
-60 

-40 

-20 

0 

20 

40 

60 

80 

100 

120 

1 2 3 4 5 6 7 8 

Efficiency Level 

Life-cycle Cost Savings($) 

Mean Median 

Figure 8.4.17 Product Class 11, Compact Refrigerators: Range of Life-Cycle Cost 

Savings by Efficiency Level 

Life-cycle Cost Savings($) 

80
 

60
 

40
 

20
 

0
 

-20
 

-40
 

-60
 

-80
 Mean Median 

-100 

1 2 3 4 5 6 7 8 

Efficiency Level 

Figure 8.4.18 Product Class 18, Compact Freezers: Range of Life-Cycle Cost Savings 

by Efficiency Level 

Figures 8.4.19 and 8.4.20 show the range of PBPs for the standard levels considered for 

compact refrigerators and freezers. For each standard level, the top and bottom of the box 

indicate the 75th and 25th percentiles, respectively. The bar at the middle of the box indicates the 

median: 50 percent of the households have PBPs that exceed this value. The horizontal lines 

8-54 

EERE-2008-BT-STD-0012 COMMENT 22
above and below the box indicate the 95th and 5th percentiles, respectively. The small box shows 

the average PBP for each efficiency level. 

0 

1 

2 

3 

4 

5 

6 

7 

8 

1 2 3 4 5 6 7 8 

Efficiency Level 

Payback Period(yr) 

Mean Median 

Figure 8.4.19 Product Class 11, Compact Refrigerators: Range of Payback Periods by 

Efficiency Level 

0 

2 

4 

6 

8 

10 

12 

1 2 3 4 5 6 7 8 

Efficiency Level 

Payback Period(yr) 

Mean Median 

Figure 8.4.20 Product Class 18, Compact Freezers: Range of Payback Periods by 

Efficiency Level 

8-55 

EERE-2008-BT-STD-0012 COMMENT 22
 

8.5 REBUTTABLE PAYBACK PERIOD 

DOE presents rebuttable PBPs to provide information for considering the legally 

established rebuttable presumption that an energy efficiency standard is economically justified if 

the additional product costs attributed to the standard are less than three times the value of the 

first-year savings in energy costs. (42 U.S.C. §6295 (o)(2)(B)(iii)) 

8.5.1 Metric 

The basic equation for rebuttable PBP is the same as that shown in section 8.3, Inputs to 

Analysis of Payback Period. Unlike the analyses described in sections 8.2 and 8.3, however, the 

rebuttable PBP is not based on the use of household samples and probability distributions. 

Rather, it is based on discrete, single-point values. For example, although DOE uses a probability 

distribution of regional energy prices in the analysis of payback period, it uses only the national 

average energy price from the probability distribution to determine the rebuttable PBP. 

Other than the use of single-point values, the most notable difference between the 

distribution PBP and the rebuttable PBP is the latter’s reliance on the DOE test procedure to 

determine a product’s annual energy consumption. 

8.5.2 Inputs to Rebuttable Payback Period Analysis 

The following were the key inputs that DOE used in determining rebuttable PBP. 

•	 Incremental manufacturing costs, markup, baseline retail price, sales tax, and 

installation costs were all based on single-point values derived from, or used as inputs 

to, the distributional LCC and PBP analysis. 

•	 Annual energy consumption was based on results of the proposed DOE test procedure 

for a product with the average adjusted volume from the LCC and PBP analysis. 

•	 Energy prices were based on average values for the year that new standards are 

assumed to take effect (2014). 

An average discount rate or lifetime is not required in calculating the rebuttable PBP. 

8.5.3 Results of Analysis 

DOE calculated rebuttable PBPs for each standard level relative to the purchase and 

operating costs of an average baseline product. 

Table 8.5.1 presents the rebuttable PBPs for each standard-size refrigerator product class 

that DOE analyzed for the LCC and PBP analysis. 

8-56 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 8.5.1 Standard-Size Refrigerator-Freezers: Rebuttable Payback Periods 

Product Class 3: 

Top-Mount RefrigeratorFreezer 

Product Class 5: 

Bottom-Mount RefrigeratorFreezer 

Product Class 7: 

Side-by-Side Refrigerator-Freezer 

with TTD* 

Efficiency Level 

(% less than baseline 

energy use) 

PBP 

years 

Efficiency Level 

(% less than baseline 

energy use) 

PBP 

years 

Efficiency Level 

(% less than baseline 

energy use) 

PBP 

years 

Baseline - Baseline - Baseline -

1 (10) 0.7 1 (10) 0.3 1 (10) 1.4 

2 (15) 1.0 2 (15) 0.6 2 (15) 1.6 

3 (20) 1.6 3 (20) 1.0 3 (20) 3.4 

4 (25) 2.6 4 (25) 1.8 4 (25) 5.4 

5 (30) 3.9 5 (30) 2.2 5 (30) 7.1 

6 (35) 5.6 6 (35) 4.6 6 (35) 8.3 

7 (40) 7.4 7 (40) 6.6 7 (40) 9.9 

8 (45) 8.7 8 (45) 8.1 - -

*Through-the-door ice service. 

Table 8.5.2 presents the rebuttable PBPs for each standard-size freezer product class that 

DOE analyzed for the LCC and PBP analysis. 

Table 8.5.2 Standard-Size Freezers: Rebuttable Payback Periods 

Product Class 9: 

Upright Freezer 

Product Class 10: 

Chest Freezer 

Efficiency Level 

(% less than baseline energy use) 

PBP 

years 

Efficiency Level 

(% less than baseline energy use) 

PBP 

years 

Baseline - Baseline -

1 (10) 1.0 1 (10) 0.6 

2 (15) 1.2 2 (15) 1.0 

3 (20) 1.1 3 (20) 3.0 

4 (25) 1.8 4 (25) 3.0 

5 (30) 2.5 5 (30) 2.9 

6 (35) 3.5 6 (35) 5.4 

7 (40) 5.0 7 (40) 4.9 

8 (45) 7.0 8 (45) 7.7 

Table 8.5.3 presents the rebuttable PBPs for each compact refrigeration product class that 

DOE analyzed for the LCC and PBP analysis. 

8-57 

EERE-2008-BT-STD-0012 COMMENT 22
Table 8.5.3 Compact Refrigerators and Freezers: Rebuttable Payback Periods 

Product Class 11: 

Compact Refrigerator 

Product Class 18: 

Compact Freezer 

Efficiency Level 

(% less than baseline energy use) 

PBP 

years 

Efficiency Level 

(% less than baseline energy use) 

PBP 

years 

Baseline - Baseline -

1 (10) 1.3 1 (10) 2.1 

2 (15) 1.7 2 (15) 2.3 

3 (20) 1.8 3 (20) 6.0 

4 (25) 3.3 4 (25) 6.0 

5 (30) 2.9 5 (30) 7.0 

6 (35) 3.0 6 (35) 6.3 

7 (40) 3.9 7 (40) 6.6 

8 (45) 5.1 8 (45) 7.0 

8-58 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

REFERENCES 

1	 U.S. Department of Energy–Energy Information Administration. Residential Energy 

Consumption Survey, 2005 Public Use Data Files. 2009. U.S. Department of Energy: 

Washington, D.C. <www.eia.doe.gov/emeu/recs/recspubuse05/pubuse05.html> 

2	 U.S. Department of Energy-Energy Information Administration. An Updated Annual Energy 

Outlook 2009 Reference Case Reflecting Provisions of the American Recovery and 

Reinvestment Act and Recent Changes in the Economic Outlook, April, 2009. Washington, 

DC. SR/OIAF/2009-03. 

<http://www.eia.doe.gov/oiaf/servicerpt/stimulus/pdf/sroiaf(2009)03.pdf> 

3	 The NPD Group, Inc., The NPD Group/NPD Houseworld – POS, Refrigerators, January – 

December 2007, 2007. Port Washington, NY. 

4	 Association of Home Appliance Manufacturers. Aggregated Refrigerator‐Freezer 

Incremental Cost Data for DOE Refrigerator‐Freezer Energy Efficiency Standards 

Rulemaking, March 2, 2009. Memo to Detlef Westphalen, Navigant Consulting, Inc. 

5	 U.S. Department of Energy–Energy Information Administration. Form EIA-861. 

Washington, D.C. <www.eia.doe.gov/cneaf/electricity/page/eia861.html> 

6	 U.S. Census Bureau, Housing and Household Economic Statistics Division. American 

Housing Survey. Washington, DC. 

<http://www.census.gov/hhes/www/housing/ahs/ahs.html> 

7	 U.S. Department of Energy–Energy Information Administration. Commercial Building 

Energy Consumption Survey, 2003 Public Use Data Files. 2008. U.S. Department of Energy: 

Washington, D.C. 

<http://www.eia.doe.gov/emeu/cbecs/cbecs2003/public_use_2003/cbecs_pudata2003.ht

ml> 

8	 The Federal Reserve Board. Survey of Consumer Finances. 1989, 1992, 1995, 1998, 2001, 

and 2004. <www.federalreserve.gov/pubs/oss/oss2/scfindex.html> 

9	 The Federal Reserve Board. Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: CDs (secondary market), Maturity: 6-month, Frequency: 

Annual, Description: Average rate on 6-month negotiable certificates of deposit (secondary 

market), quoted on an investment basis. 2009. Washington, D.C. 

<www.federalreserve.gov/releases/H15/data.htm> 

10	 The Federal Reserve Board. Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: State and local bonds, Maturity: 20-year, Frequency: Monthly, 

8-59 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

Description: Bond buyer go 20-bond municipal bond index. 2009. Washington, D.C. 

<www.federalreserve.gov/releases/H15/data.htm> 

11	 The Federal Reserve Board. Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: Corporate bonds/Moody’s Seasoned AAA, Frequency: Annual, 

Description: Moody’s yield on seasoned corporate bonds—all industries, AAA. 2009. 

Washington, D.C. <www.federalreserve.gov/releases/H15/data.htm> 

12	 Mortgage-X, Mortgage Information Service. Cost of Savings Index (COSI), Index History. 

2009. <http://mortgage-x.com/general/indexes/default.asp> (Last accessed, February 25, 

2009.) 

13	 Damodaran Online. The Data Page: Historical Returns on Stocks, Bonds, and Bills—United 

States. 2009. <http://pages.stern.nyu.edu/~adamodar/> 

14	 Ibbotsons Associates. SBBI Valuation Edition 2009 Yearbook. 2009. Chicago, IL. pp. 45–48. 

15	 Damodaran Online. The Data Page: Cost of Capital by Industry Sector. 2001–2008. 

<http://pages.stern.nyu.edu/~adamodar/> 

16	 Damodaran Online. The Data Page: Historical Returns on Stocks, Bonds and Bills—United 

States. <http://pages.stern.nyu.edu/~adamodar/> 

17	 Bureau of Economic Analysis–National Income and Product Accounts Tables. Table 1.1.9. 

Implicit Price Deflators for Gross Domestic Product. 

<www.bea.gov/national/nipaweb/SelectTable.asp?Selected=N> 

18	 U.S. Department of Energy. Implementation Report: Energy Conservation Standards 

Activities. Submitted Pursuant to Section 141 of the Energy Policy Act of 2005. August 2006. 

Washington, D.C. 

<www.eere.energy.gov/buildings/appliance_standards/pdfs/implementation_report_0806.pdf 

> 

19	 Association of Home Appliance Manufacturers. Aggregated Refrigerator‐Freezer 

Shipments and Efficiency Data for DOE Refrigerator‐Freezer Energy Efficiency Standards 

Rulemaking, January 16, 2009. Memo to Detlef Westphalen, Navigant Consulting, Inc. 

8-60 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 8-A. USER INSTRUCTIONS FOR LCC AND PBP SPREADSHEETS 

TABLE OF CONTENTS 

8-A.1 INTRODUCTION .................................................................................................8-A-1 

8-A.1.1 Standard Size Refrigerator-Freezers and Freezers.................................................8-A-1 

8-A.1.2 Compact Refrigerators and Compact Freezers ......................................................8-A-2 

8-A.2 BASIC INSTRUCTIONS......................................................................................8-A-3 

8A-i 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

APPENDIX 8-A. USER INSTRUCTIONS FOR LCC AND PBP SPREADSHEETS 

8-A.1 INTRODUCTION 

It is possible to examine and reproduce the detailed results of the life-cycle cost (LCC) 

and payback period (PBP) analyses using Microsoft Excel spreadsheets available on the U.S. 

Department of Energy’s website at: http://www.eere.energy.gov/buildings/appliance_standards/. 

To fully execute the spreadsheets requires both Microsoft Excel and Crystal Ball software. Both 

applications are commercially available. Crystal Ball is available at: 

http://www.decisioneering.com. 

The seven spreadsheets posted on the DOE website represent the latest versions and have 

been tested with Microsoft Excel 2003. 

8-A.1.1 Standard Size Refrigerator-Freezers and Freezers 

The Standard Size Refrigerator-Freezers and Freezers LCC and PBP spreadsheets or 

workbooks consist of the following worksheets: 

LCC Summary Contains the input selections and a summary table of energy use, 

operating costs, LCC, and Payback. This worksheet also works as 

an interface between user inputs and the rest of the worksheets — 

do not modify this sheet. 

RECS Households For each RECS household being sampled, contains the equipment 

usage data, along with product characteristics (i.e., size, volume, 

product age) and household characteristics (e.g., Census division, 

income). 

RECS UAF Contains the unit adjustment factor calculation which converts 

tested energy consumption into field energy consumption 

Base Case Eff Dist Contains market efficiency distribution in the year the standard 

takes effect 

Equipment Price Contains manufacturer price data for the considered design 

options. Also includes the manufacturer and retail mark-ups, sales 

tax. 

Energy Use Contains unit energy use data (tested and field) 

Energy Price Contains regional electricity prices for the reference year. 

8-A-1
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

Energy Price Trend Contains the electricity price trends for the reference, high, and 

low economic growth scenarios based on AEO 2009. 

Discount Rate Contains data from which an average discount rate and a 

distribution of discount rates are determined. 

Lifetime Contains the survival function and average lifetime in years. 

Standards Contains past and existing standards by product class along with 

historical trends of energy consumption prior to first standards. 

AV Equations Contains average relation between volume and adjusted volume by 

product class. 

ESAF Contains efficiency standard adjustment factor. 

UAF Range Contains parameters allowing for the sample selection, and 

minimum and maximum UAF assignments. 

EStarModel Contains Energy Star model assigning energy star to households 

based on income. 

8-A.1.2 Compact Refrigerators and Compact Freezers 

The Compact Refrigerators and Compact Freezers LCC and PBP spreadsheet or 

workbook consists of the following worksheets: 

LCC Summary	 Contains the input selections and a summary table of energy use, 

operating costs, LCC, and Payback. This worksheet also works as 

an interface between user inputs and the rest of the worksheets — 

do not modify this sheet. 

Base Case Eff Dist	 Contains market efficiency distribution in the year the standard 

takes effect. 

Division	 Contains number of customers for residential and commercial 

sector by region. 

Equipment Price	 Contains manufacturer price data for the considered design 

options. Also includes the manufacturer and retail mark-ups, sales 

tax. 

Energy Use	 Contains unit energy use data (tested and field) 

Energy Price	 Contains regional electricity prices for the reference year. 

8-A-2
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Energy Price Trend	 Contains the electricity price trends for the reference, high, and 

low economic growth scenarios based on AEO 2009. 

Discount Rate Contains data from which an average discount rate and a 

distribution of discount rates are determined. 

Lifetime	 Contains the survival function and average lifetime in years. 

AV Equations	 Contains average relation between volume and adjusted volume by 

product class. 

8-A.2 BASIC INSTRUCTIONS 

Basic instructions for operating the LCC spreadsheets are as follows: 

1.	 Once you have downloaded the LCC file from the Web, open the file using Excel. At the 

bottom, click on the tab for sheet ‘LCC Summary’. 

2.	 Use Excel’s “View/Zoom” commands at the top menu bar to change the size of the 

display to make it fit your monitor. 

3.	 The user interacts with the spreadsheet by clicking choices or entering data using the 

graphical interface that comes with the spreadsheet. Select choices from the various 

inputs listed under "User Options" heading. 

4.	 Under the "User Options" heading, select choices from the selection buttons and boxes 

for the following: (1) type of calculation (Sample or Crystal Ball®), (2) energy price 

Trend, (3) start year, and (4) efficiency market share scenario. By overwriting the code in 

the LCC summary sheet, a new discount rate or lifetime can be entered if a value other 

than the default value is wanted . The Department does not recommend saving the 

spreadsheet after the code is changed. 

5.	 To change inputs listed under "User Input", select the input you wish to change by either 

clicking on the appropriate button or selecting the appropriate input from the input box. 

6.	 This spreadsheet gives the user two types of calculation methods: 

a.	 If the "Sample Calc" is selected, then all calculations are performed for single input 

values, usually an average. The new results are shown on the same sheet as soon as 

the new values are entered. 

b.	 Alternately, if the "CB Calculation" is selected, the spreadsheet generates results that 

are distributions. Some of the inputs are also distributions. The results from the LCC 

distribution are shown as single values and refer only to the results from the last 

8-A-3 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Monte Carlo sample and are therefore not meaningful. To run the distribution version 

of the spreadsheet, the Microsoft Excel® add-in software called Crystal Ball® must 

be enabled. 

To produce sensitivity results using Crystal Ball, simply select Run from the Run menu 

(on the menu bar). To make basic changes in the run sequence, including altering the number of 

trials, select Run Preferences from the Run menu. After each simulation run, the user needs to 

select Reset (also from the Run menu) before Run can be selected again. Once Crystal Ball has 

completed its run sequence it will produce a series of distributions. Using the menu bars on the 

distribution results, it is possible to obtain further statistical information. The time taken to 

complete a run sequence can be reduced by minimizing the Crystal Ball window in Microsoft 

Excel. A step-by-step summary of the procedure for running a distribution analysis is outlined 

below: 

1.	 Find the Crystal Ball toolbar (at top of screen) 

2.	 Click on Run from the menu bar 

3.	 Select Run Preferences and choose from the following choices: 

a.	 Monte Carloa 

b.	 Latin Hypercube (recommended) 

c.	 Initial seed choices and whether you want it to be constant between runs 

d.	 Select number of Monte Carlo Trials (DOE suggests 10,000). 

4. To run the simulation, follow the following sequence (on the Crystal Ball toolbar) 

Run 

Reset 

Run 

5.	 Now wait until the program informs you that the simulation is completed. 

The following instructions are provided to view the output generated by Crystal Ball. 

1.	 After the simulation has finished, to see the distribution charts generated, click on the 

Windows tab bar that is labeled Crystal Ball. 

2.	 The life-cycle cost savings and payback periods are defined as Forecast cells. The 

frequency charts display the results of the simulations, or trials, performed by Crystal 

Ball. Click on any chart to bring it into view. The charts show the low and high endpoints 

of the forecasts. The View selection on the Crystal Ball toolbar can be used to specify 

whether you want cumulative or frequency plots shown. 

a

 Because of the nature of the program, there is some variation in results due to random sampling when Monte Carlo 

or Latin Hypercube sampling is used. 

8-A-4
 

EERE-2008-BT-STD-0012 COMMENT 22
3.	 To calculate the probability that a particular value of LCC savings will occur, either type 

0 in the box by the left arrow, or move the arrow key with the cursor to 0 on the scale. 

The value in the Certainty box shows the likelihood that the LCC savings will occur. To 

calculate the certainty of payback period being below a certain number of years, choose 

that value as the high endpoint. 

4.	 To generate a printout report, select Create Report from the Run menu. The toolbar 

choice of Forecast Windows allows you to select the charts and statistics in which you 

are interested. For further information on Crystal Ball outputs, please refer to 

Understanding the Forecast Chart in the Crystal Ball manual. 

8-A-5
 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 8-B. UNCERTAINTY AND VARIABILITY 

TABLE OF CONTENTS 

8-B.1 INTRODUCTION ................................................................................................. 8-B-1 

8-B.2 UNCERTAINTY ................................................................................................... 8-B-1 

8-B.3 VARIABILITY...................................................................................................... 8-B-1 

8-B.4 APPROACHES TO UNCERTAINTY AND VARIABILITY ............................. 8-B-2 

8-B.5 PROBABILITY ANALYSIS AND THE USE OF CRYSTAL BALL................. 8-B-2 

LIST OF FIGURES 

Figure 8-B.5.1 Normal Probability Distribution ................................................................ 8-B-3 

Figure 8-B.5.2 Triangular Probability Distribution............................................................ 8-B-3 

Figure 8-B.5.3 Uniform Probability Distribution............................................................... 8-B-3 

8B-i 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 8-B. UNCERTAINTY AND VARIABILITY 

8-B.1 INTRODUCTION 

Analysis of an energy-efficiency standard involves calculations of impacts, for example, 

the impact of a standard on consumer life-cycle cost (LCC). In order to perform the calculation, 

the analyst must first: 1) specify the equation or model that will be used; 2) define the quantities 

in the equation; and 3) provide numerical values for each quantity. In the simplest case, the 

equation is unambiguous (contains all relevant quantities and no others), each quantity has a 

single numerical value, and the calculation results in a single value. However, unambiguity and 

precision are rarely the case. In almost all cases, the model and/or the numerical values for each 

quantity in the model are not completely known (i.e., there is uncertainty) or the model and/or 

the numerical values for each quantity in the model depend upon other conditions (i.e., there is 

variability). 

Thorough analysis involves accounting for uncertainty and variability. While the 

simplest analysis involves a single numerical value for each quantity in a calculation, arguments 

can arise about what the appropriate value is for each quantity. Explicit analysis of uncertainty 

and variability is intended to provide more complete information to the decision-making process. 

8-B.2 UNCERTAINTY 

When making observations of past events or speculating about the future, imperfect 

knowledge is the rule rather than the exception. For example, the energy actually consumed by a 

particular appliance type (such as the average U.S. commercial air conditioner or heat pump) is 

not directly recorded, but rather estimated based upon available information. Even direct 

laboratory measurements have some margin of error. When estimating numerical values 

expected for quantities at some future date, the exact outcome is rarely known in advance. 

8-B.3 VARIABILITY 

Variability means that different applications or situations produce different numerical 

values when calculating a quantity. Specifying an exact value for a quantity may be difficult 

because the value depends on something else. For example, the number of hours an air 

conditioner is operated by a household depends upon the specific circumstances and behaviors of 

the occupants (e.g., number of persons, personal habits about how comfortable the person wants 

to be, etc.). Variability makes specifying an appropriate population value more difficult in as 

much as any one value may not be representative of the entire population. Surveys can be 

helpful here, and analysis of surveys can relate the variable of interest (e.g., hours of use) to 

other variables that are better known or easier to forecast (e.g., persons per household). 

8-B-1
 

EERE-2008-BT-STD-0012 COMMENT 22
8-B.4 APPROACHES TO UNCERTAINTY AND VARIABILITY 

This section describes two approaches to uncertainty and variability: 

• scenario analysis, and 

• probability analysis. 

Scenario analysis uses a single numerical value for each quantity in a calculation, then 

changes one (or more) of the numerical values and repeats the calculation. A number of 

calculations are done, which provide some indication of the extent to which the result depends 

upon the assumptions. For example, the life-cycle cost of an appliance could be calculated for 

energy rates of 2, 8, and 14¢ per kWh. 

The advantages of scenario analysis are that each calculation is simple; a range of 

estimates is used; and crossover points can be identified. (An example of a crossover point is the 

energy rate above which the life-cycle cost is reduced, holding all other inputs constant. That is, 

the crossover point is the energy rate at which the consumer achieves savings in operating 

expense that more than compensate for the increased purchase expense.) The disadvantage of 

scenario analysis is that there is no information about the likelihood of each scenario. 

 Probability analysis considers the probabilities within a range of values. For quantities 

with variability (e.g., electricity rates in different households), surveys can be used to generate a 

frequency distribution of numerical values (e.g., the number of households with electricity rates 

at particular levels) to estimate the probability of each value. For quantities with uncertainty, 

statistical or subjective measures can be used to provide probabilities (e.g., manufacturing cost to 

improve energy efficiency to some level may be estimated to be $10 ± $3). 

The major disadvantage of the probability approach is that it requires more information, 

namely information about the shapes and magnitudes of the variability and uncertainty of each 

quantity. The advantage of the probability approach is that it provides greater information about 

the outcome of the calculations, that is, it provides the probability that the outcome will be in a 

particular range. 

Scenario and probability analysis provide some indication of the robustness of the policy 

given the uncertainties and variability. A policy is robust when the impacts are acceptable over a 

wide range of possible conditions. 

8-B.5 PROBABILITY ANALYSIS AND THE USE OF CRYSTAL BALL 

To quantify the uncertainty and variability that exist in inputs to the engineering, LCC, 

and payback period (PBP) analyses, the Department used Microsoft Excel spreadsheets 

combined with Crystal Ball, a commercially available add-in, to conduct probability analyses. 

The probability analyses used Monte Carlo simulation and probability distributions. 

8-B-2
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Simulation refers to any analytical method meant to imitate a real-life system, especially 

when other analyses are too mathematically complex or too difficult to reproduce. Without the 

aid of simulation, a spreadsheet model will only reveal a single outcome, generally the most 

likely or average scenario. Spreadsheet risk analysis uses both a spreadsheet model and 

simulation to automatically analyze the effect of varying inputs on outputs of the modeled 

system. One type of spreadsheet simulation is Monte Carlo simulation, which randomly 

generates values for uncertain variables again and again to simulate a model. Monte Carlo 

simulation was named for Monte Carlo, Monaco, where the primary attractions are casinos 

containing games of chance. Games of chance such as roulette wheels, dice, and slot machines, 

exhibit random behavior. The random behavior in games of chance is similar to how Monte 

Carlo simulation selects variable values at random to simulate a model. When you roll a die, you 

know that either a 1, 2, 3, 4, 5, or 6 will come up, but you do not know which for any particular 

roll. It's the same with the variables that have a known range of values but an uncertain value for 

any particular time or event (e.g., equipment lifetime, discount rate, and installation cost). 

For each uncertain variable (one that has a range of possible values), possible values are 

defined with a probability distribution. The type of distribution selected is based on the 

conditions surrounding that variable. Probability distribution types include: 

NORMAL TRIANGULAR UNIFORM 

Figure 8-B.5.1 Normal Probability Figure 8-B.5.2 Triangular Figure 8-B.5.3 Uniform Probability 

Distribution Probability Distribution 

Distribution 

During a simulation, multiple scenarios of a model are calculated by repeatedly sampling 

values from the probability distributions for the uncertain variables and using those values for the 

cell. Crystal Ball simulations can consist of as many trials (or scenarios) as desired—hundreds or 

even thousands. During a single trial, Crystal Ball randomly selects a value from the defined 

possibilities (the range and shape of the probability distribution) for each uncertain variable and 

then recalculates the spreadsheet. 

For each uncertain variable (one that has a range of possible values), possible values are 

defined with a probability distribution. The type of distribution selected is based on the 

conditions surrounding that variable. Probability distribution types include: 

8-B-3
 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 8-C. CONSUMER RETAIL PRICE DISTRIBUTIONS FOR 

BASELINE REFRIGERATOR-FREEZERS AND FREEZERS 

TABLE OF CONTENTS 

8-C.1 INTRODUCTION ................................................................................................. 8-C-1 

8-C.2 DISTRIBUTION HISTOGRAMS......................................................................... 8-C-2 

LIST OF FIGURES 

Figure 8-C.2.1 Baseline Retail Price Distribution for Product Class 3 (Standard-sized 

Top-mount Refrigerator-Freezers without Through-the-door Service)..... 8-C-2 

Figure 8-C.2.2 Baseline Retail Price Distribution for Product Class 5 (Standard-sized 

Bottom-mount Refrigerator-Freezers without Through-the-door 

Service) ...................................................................................................... 8-C-3 

Figure 8-C.2.3 Baseline Retail Price Distribution for Product Class 7 (Standard-sized 

Side-mount Refrigerator-Freezers with Through-the-door Service) ......... 8-C-4 

Figure 8-C.2.4 Baseline Retail Price Distribution for Product Class 9 (Standard-sized 

Upright Freezers) ....................................................................................... 8-C-5 

Figure 8-C.2.5 Baseline Retail Price Distribution for Product Class 10 (Standard-sized 

Chest Freezers)........................................................................................... 8-C-6 

Figure 8-C.2.6 Baseline Retail Price Distribution for Product Class 11 (Compact 

Refrigerators) ............................................................................................. 8-C-7 

Figure 8-C.2.7 Baseline Retail Price Distribution for Product Class 18 (Compact 

Freezers)..................................................................................................... 8-C-8 

8C-i 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 8-C. CONSUMER RETAIL PRICE DISTRIBUTIONS FOR BASELINE 

REFRIGERATOR-FREEZERS AND FREEZERS 

8-C.1 INTRODUCTION 

DOE’s engineering analysis did not attempt to estimate the manufacturing cost for 

baseline models. Instead, it developed incremental increases in manufacturer selling price 

associated with increases in efficiency levels. This approach required DOE to estimate retail 

prices for the baseline model in each product class. 

DOE drew upon proprietary retail price data collected by The NPD Group.1

 These data 

reflect retail prices and sales at a large number of retail outlets in the United States (including 

over 50 percent of retail sales), and include information regarding model number, refrigerated 

volume, configuration of doors and ice-making, and whether the unit is an ENERGY STAR 

product. The data include enough information to assign each model to the correct product class. 

DOE developed a sales-weighted price distribution for non-ENERGY STAR appliances in each 

product class from this data. DOE grouped models by selling price in bins of varying width 

(generally $25 for compact products and $50 to $100 for standard-sized products) in order to 

balance the accuracy and usability of the distributions. These distributions are shown in the 

following section. 

DOE assumed that prices for non-ENERGY STAR models are a reasonable 

approximation of prices for the baseline models. These models may be “baseline” in efficiency, 

but span a wide range of other features and materials, and therefore have a broad distribution of 

prices. DOE chose not to develop volume-dependent baseline retail prices because the data did 

not show a strong relationship between volume and retail price. The price distributions within 

most volume ranges and product classes are almost as broad as the volume-independent 

distributions DOE chose to use, and regression analysis indicated very weak dependence of 

average price on volume. 

8-C-1
 

EERE-2008-BT-STD-0012 COMMENT 22
8-C.2 DISTRIBUTION HISTOGRAMS 

40%

0%

5%

10%

15%

20%

25%

30%

35%

Percent of Sales 

$150$350$550$750$950

$1,150$1,350$1,550$1,750$1,950$2,150$2,350$2,550$2,750$2,950$4,500

Selling Price 

Figure 8-C.2.1	 Baseline Retail Price Distribution for Product Class 

3 (Standard-sized Top-mount Refrigerator-Freezers 

without Through-the-door Service) 

8-C-2
 

EERE-2008-BT-STD-0012 COMMENT 22
Percent of Sales 

18%

16%

14%

12%

10%

8%

6%

4%

2%

0%

$150$350$550$750$950

$1,150$1,350$1,550$1,750$1,950$2,150$2,350$2,550$2,750$2,950$3,150$3,350$3,550$3,750$3,950$4,150$4,350$4,550$4,750$4,950$5,300$5,700

Selling Price 

Figure 8-C.2.2	 Baseline Retail Price Distribution for Product Class 

5 (Standard-sized Bottom-mount RefrigeratorFreezers without Through-the-door Service) 

8-C-3
 

EERE-2008-BT-STD-0012 COMMENT 22
Percent of Sales 

16%

14%

12%

10%

8%

6%

4%

2%

0%

$150$350$550$750$950

$1,150$1,350$1,550$1,750$1,950$2,150$2,350$2,550$2,750$2,950$3,150$3,350$3,550$3,750$3,950$4,150$4,350$4,550$4,750$4,950

Selling Price 

Figure 8-C.2.3	 Baseline Retail Price Distribution for Product Class 

7 (Standard-sized Side-mount Refrigerator-Freezers 

with Through-the-door Service) 

8-C-4
 

EERE-2008-BT-STD-0012 COMMENT 22
Percent of Sales 

25%

20%

15%

10%

5%

0%

$75

$175$275$375$475$575$675$775$875$975

$1,075$1,175$1,275$1,375$1,475$1,650$1,850$2,050$2,250$2,450$2,650$2,850$3,250$4,250$5,250$6,250

Selling Price 

Figure 8-C.2.4	 Baseline Retail Price Distribution for Product Class 

9 (Standard-sized Upright Freezers) 

8-C-5
 

EERE-2008-BT-STD-0012 COMMENT 22
Percent of Sales 

35%

30%

25%

20%

15%

10%

5%

0%

$75

$125$175$225$275$325$375$425$475$525$575$625$675$725$775$825$875$925$975

$1,050$1,150$1,250$1,350$1,450$1,550$1,650$1,750$1,850$1,950$2,250$2,750$3,500$4,500$5,500

Selling Price 

Figure 8-C.2.5	 Baseline Retail Price Distribution for Product Class 

10 (Standard-sized Chest Freezers) 

8-C-6
 

EERE-2008-BT-STD-0012 COMMENT 22
Percent of Sales 

20%

18%

16%

14%

12%

10%

8%

6%

4%

2%

0%

$25$50$75

$100$125$150$175$200$225$250$275$300$325$350$375$400$425$450$475$500$525$550$575$600$625

Selling Price 

Figure 8-C.2.6	 Baseline Retail Price Distribution for Product Class 

11 (Compact Refrigerators) 

8-C-7
 

EERE-2008-BT-STD-0012 COMMENT 22
Percent of Sales 

70%

60%

50%

40%

30%

20%

10%

0%

$25$50$75

$100$125$150$175$200$225$250$275$300$325$350$375$400$425$450$475$500$750

$1,500$2,500$3,500

Selling Price 

Figure 8-C.2.7	 Baseline Retail Price Distribution for Product Class 

18 (Compact Freezers) 

8-C-8
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

1 

REFERENCES 

The NPD Group, Inc., The NPD Group/NPD Houseworld – POS, Refrigerators, Freezers 

January – December 2007, 2008. Port Washington, NY. 

8-C-9
 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 8-D. HOUSEHOLD DISCOUNT RATE DISTRIBUTIONS 

TABLE OF CONTENTS 

8-D.1 INTRODUCTION .................................................................................................8-D-1 

8-D.2 DISTRIBUTION OF MORTGAGE INTEREST RATES ....................................8-D-1 

8-D.3 DISTRIBUTION OF RATES FOR TYPES OF DEBT AND EQUITY USED 

TO FINANCE REPLACEMENT FURNACES....................................................8-D-2 

8-D.4 DISTRIBUTION OF RATES FOR TYPES OF EQUITY USED TO 

FINANCE REPLACEMENT FURNACES ..........................................................8-D-5 

LIST OF FIGURES 

Figure 8-D.2.1 Distribution of New Home Mortgage Interest Rates .................................8-D-1 

Figure 8-D.3.1 Distribution of Home Equity Loan Interest Rates .....................................8-D-2 

Figure 8-D.3.2 Distribution of Credit Card Interest Rates .................................................8-D-3 

Figure 8-D.3.3 Distribution of Installment Loan Interest Rates.........................................8-D-3 

Figure 8-D.3.4 Distribution of Other Residence Loan Interest Rates ................................8-D-4 

Figure 8-D.3.5 Distribution of Other Lines of Credit Loan Interest Rates ........................8-D-4 

Figure 8-D.4.1 Distribution of Annual Rate of Return on CD’s ........................................8-D-5 

Figure 8-D.4.2 Distribution of Annual Rate of Return on Savings Bonds.........................8-D-6 

Figure 8-D.4.3 Distribution of Annual Rate of Return on Corporate AAA Bonds............8-D-6 

Figure 8-D.4.4 Distribution of Annual Rate of Savings Accounts.....................................8-D-7 

Figure 8-D.4.5 Distribution of Annual Rate of Return on S&P 500..................................8-D-7 

Figure 8-D.4.6 Distribution of Annual Rate of Return on Mutual Funds ..........................8-D-8 

8-D-i 

EERE-2008-BT-STD-0012 COMMENT 22
 

APPENDIX 8-D. HOUSEHOLD DISCOUNT RATE DISTRIBUTIONS 

8-D.1 INTRODUCTION 

DOE derived discount rates for the LCC analysis using data on interest or return rates for 

various types of debt and equity. To account for variation among households in rates for each of 

the types, DOE sampled a rate for each household from a distribution of rates for each debt and 

equity type. This appendix describes the distributions used. 

8-D.2 DISTRIBUTION OF MORTGAGE INTEREST RATES 

Figure 8-D.2.1 shows the distribution of real interest rates for new home mortgages. 

The data source DOE used for mortgage interest rates is the Federal Reserve Board’s Survey of 

Consumer Finances (SCF) in 1989, 1992, 1995, 1998, 2001, 2004 and 2007.1

 Using the 

appropriate SCF data for each year, DOE adjusted the nominal mortgage interest rate for each 

relevant household in the SCF for mortgage tax deduction and inflation. In cases where the 

effective interest rate is equal to or below the inflation rate (resulting in a negative real interest 

rate), DOE set the real effective interest rate to zero. 

0%

5%

10%

15%

20%

25%

30%

35%

0.5%

1.6%

2.5%3.5%

4.4%

5.4%

6.4%7.4%

8.5%

9.5%

10.5%

11.6%

12.4%13.5%

14.4%

16.7%22.9%

Real Interest Rate 

Probability 

Figure 8-D.2.1 Distribution of New Home Mortgage Interest Rates 

8-D-1
 

EERE-2008-BT-STD-0012 COMMENT 22
 

8-D.3	 DISTRIBUTION OF RATES FOR TYPES OF DEBT AND EQUITY USED 

TO FINANCE REPLACEMENT FURNACES 

Figure 8-D.3.1 through Figure 8-D.3.5 show the distribution of real interest rates for 

different types of debt used to finance replacement furnaces. The data source for the interest rates 

for home equity loans, credit cards, installment loans, other residence loans, and other lines of 

credit is the Federal Reserve Board’s SCF in 1989, 1992, 1995, 1998, 2001, 2004, and 2007.1 

DOE adjusted the nominal rates to real rates using the annual inflation rate in each year. For 

home equity loans, DOE calculated effective interest rates in a similar manner as for mortgage 

rates, since interest on such loans is tax deductible. 

0%

5%

10%

15%

20%

25%

30%

35%

0.4%

1.5%

2.6%

3.5%

4.5%

5.4%

6.4%

7.5%

8.5%

9.5%

10.6%

11.8%

12.7%

13.7%

14.7%

16.7%

17.5%

42.5%

Real Interest Rate 

Probability 

Figure 8-D.3.1 Distribution of Home Equity Loan Interest Rates 

8-D-2
 

EERE-2008-BT-STD-0012 COMMENT 22
0%

2%

4%

6%

8%

10%

12%

0.0%

1.4%2.5%

3.5%4.5%5.6%

6.7%7.5%

8.7%9.6%

10.6%

11.5%

12.6%

13.6%

14.7%

15.6%16.4%

17.6%18.5%

19.4%

20.5%

21.4%

22.5%

23.6%

24.6%

25.5%

26.3%

27.3%

Real Interest Rate 

Probability 

Figure 8-D.3.2 Distribution of Credit Card Interest Rates 

0%

5%

10%

15%

20%

25%

30%

35%

0.0%

2.4%

4.5%

6.7%8.6%

10.6%

12.5%

14.7%

16.5%

18.5%

20.5%

22.3%

24.6%

26.6%28.5%

34.1%

43.6%

47.2%

Real Interest Rate 

Probability 

Figure 8-D.3.3 Distribution of Installment Loan Interest Rates 

8-D-3
 

EERE-2008-BT-STD-0012 COMMENT 22
0%

5%

10%

15%

20%

0.2%

1.5%

2.5%3.5%

4.5%5.5%

6.5%

7.5%

8.6%

9.4%

10.6%

11.6%

12.6%14.7%15.7%

16.6%17.9%

Real Interest Rate 

Probability 

Figure 8-D.3.4 Distribution of Other Residence Loan Interest Rates 

0%

2%

4%

6%

8%

10%

12%

14%

16%

0.1%

1.4%

2.5%

3.5%

4.5%

5.5%

6.7%

7.6%

8.7%

9.5%

10.5%

11.6%

12.5%

13.5%

14.7%

15.6%

16.5%

17.3%

18.5%

19.1%

20.2%

21.5%

22.1%

23.5%

Real Interest Rate 

Probability 

Figure 8-D.3.5	 Distribution of Other Lines of Credit Loan Interest 

Rates 

8-D-4 

EERE-2008-BT-STD-0012 COMMENT 22
 

8-D.4	 DISTRIBUTION OF RATES FOR TYPES OF EQUITY USED TO 

FINANCE REPLACEMENT FURNACES 

Figure 8-D.4.1 through Figure 8-D.4.6 show the distribution of real interest rates for 

different types of equity used to finance replacement furnaces. Data for equity classes are not 

available from the Federal Reserve Board’s SCF, so the Department derived data for these 

classes from national-level historical data. The interest rates associated with certificates of 

deposit (CDs),2

 savings bonds,3 and bonds (AAA corporate bonds)4 are from Federal Reserve 

Board time-series data covering 1977–2007. DOE assumed rates on checking accounts to be 

zero. Rates on savings and money market accounts are from Cost of Savings Index data covering 

1984–2007.5

 The rates for stocks are the annual returns on the Standard and Poor’s (S&P) 500 in 

the 1977–2007 period.6

 The mutual fund rates are a weighted average of the stock rates (twothirds weight) and the bond rates (one-third weight) in each year of the 1977–2007 period. DOE 

adjusted the nominal rates to real rates using the annual inflation rate in each year. 

-2%

0%

2%

4%

6%

8%

1977

1979

1981

1983

1985

1987

1989

1991

1993

1995

1997

1999

2001

2003

2005

2007

Year 

Annual Rate of Return 

Figure 8-D.4.1 Distribution of Annual Rate of Return on CD’s 

8-D-5
 

EERE-2008-BT-STD-0012 COMMENT 22
-2%

0%

2%

4%

6%

8%

1977

1979

1981

1983

1985

1987

1989

1991

1993

1995

1997

1999

2001

2003

2005

2007

Year 

Annual Rate of Return 

Figure 8-D.4.2 Distribution of Annual Rate of Return on Savings 

Bonds 

-2%

0%

2%

4%

6%

8%

1977

1979

1981

1983

1985

1987

1989

1991

1993

1995

1997

1999

2001

2003

2005

2007

Year 

Annual Rate of Return 

Figure 8-D.4.3	 Distribution of Annual Rate of Return on Corporate 

AAA Bonds 

8-D-6 

EERE-2008-BT-STD-0012 COMMENT 22
-2%

0%

2%

4%

6%

8%

1984198519861987198819891990199119921993199419951996199719981999200020012002200320042005200620072008

Year 

Annual Rate of Return 

Figure 8-D.4.4 Distribution of Annual Rate of Savings Accounts 

-30%

-20%

-10%

0%

10%

20%

30%

40%

1977

1979

1981

1983

1985

1987

1989

1991

1993

1995

1997

1999

2001

2003

2005

2007

Year 

Annual Rate of Return 

Figure 8-D.4.5 Distribution of Annual Rate of Return on S&P 500 

8-D-7
 

EERE-2008-BT-STD-0012 COMMENT 22
-15%

-10%

-5%

0%

5%

10%

15%

20%

25%

1977

1979

1981

1983

1985

1987

1989

1991

1993

1995

1997

1999

2001

2003

2005

2007

Year 

Annual Rate of Return 

Figure 8-D.4.6 Distribution of Annual Rate of Return on Mutual 

Funds 

8-D-8
 

EERE-2008-BT-STD-0012 COMMENT 22
REFERENCES 

1. The Federal Reserve Board, Survey of Consumer Finances 1989, 1992, 1995, 1998, 2001, 

2004, 2007. <http://www.federalreserve.gov/pubs/oss/oss2/scfindex.html> 

2. The Federal Reserve Board, Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: CDs (secondary market), Maturity: 6-month, Frequency: 

Annual, Description: Average rate on 6-month negotiable certificates of deposit 

(secondary market), quoted on an investment basis, 2008. 

<http://www.federalreserve.gov/releases/H15/data.htm> 

3. The Federal Reserve Board, Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: State and local bonds, Maturity: 20-year, Frequency: 

Monthly, Description: Bond buyer go 20-bond municipal bond index, 2008. 

<http://www.federalreserve.gov/releases/H15/data.htm> 

4. The Federal Reserve Board, Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: Corporate bonds/Moody's Seasoned AAA, Frequency: 

Annual, Description: Moody's yield on seasoned corporate bonds - all industries, AAA, 

2008. <http://www.federalreserve.gov/releases/H15/data.htm> 

5. Wachovia, Cost of Savings Index (COSI) Index History, 2008. (Last accessed March 10, 

2008.) <http://mortgage-x.com/general/indexes/default.asp> 

6. Damodaran Online, Damodaran Online:The Data Page (Historical Returns on Stocks, 

Bonds, and Bills - United States), 2008. Stern School of Business, New York University. 

(Last accessed March 10, 2008.) <http://pages.stern.nyu.edu/~adamodar/> 

8-D-9
 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 9. SHIPMENTS ANALYSIS 

TABLE OF CONTENTS 

9.1 INTRODUCTION ........................................................................................................... 9-1 

9.2 SHIPMENTS MODEL METHODOLOGY.................................................................... 9-1 

9.3 DATA INPUTS AND MODEL CALIBRATION .......................................................... 9-3 

9.3.1 Standard-size Refrigerator-Freezers ................................................................................ 9-4 

9.3.1.1 Historical Shipments...................................................................................... 9-4 

9.3.1.2 Markets and Model Calibration ..................................................................... 9-5 

9.3.1.3 Disaggregation into Separate Refrigerator-Freezer Product Classes............. 9-9 

9.3.1.4 Base Case Shipments ................................................................................... 9-14 

9.3.2 Standard-size Freezers ................................................................................................... 9-15 

9.3.2.1 Historical Shipments.................................................................................... 9-15 

9.3.2.2 Markets and Model Calibration ................................................................... 9-16 

9.3.2.3 Disaggregation into Separate Freezer Product Classes................................9-18 

9.3.2.4 Base Case Shipments ................................................................................... 9-19 

9.3.3 Compact Refrigerators and Refrigerator-Freezers......................................................... 9-21 

9.3.3.1 Historical Shipments.................................................................................... 9-21 

9.3.3.2 Markets and Model Calibration ................................................................... 9-21 

9.3.3.3 Disaggregation into Separate Compact Refrigerator Product Classes......... 9-24 

9.3.3.4 Base Case Shipments ................................................................................... 9-24 

9.3.4 Compact Freezers........................................................................................................... 9-26 

9.3.4.1 Historical Shipments.................................................................................... 9-26 

9.3.4.2 Markets and Model Calibration ................................................................... 9-26 

9.3.4.3 Disaggregation into Separate Compact Freezer Product Classes ................ 9-28 

9.3.4.4 Base Case Shipments ................................................................................... 9-28 

9.4 PURCHASE PRICE, OPERATING COST, AND HOUSEHOLD INCOME 

IMPACTS ...................................................................................................................... 9-29 

9.5 AFFECTED STOCK ..................................................................................................... 9-31 

9.6 RESULTS ...................................................................................................................... 9-32 

LIST OF TABLES 

Table 9.3.1 Standard-size Refrigerator-Freezers: Historical Shipments................................. 9-5 

Table 9.3.2 Historical and Forecasted Housing Starts (millions) ........................................... 9-8 

Table 9.3.3 Market Shares of Side-by-Side Refrigerator-Freezers....................................... 9-10 

Table 9.3.4 Modeled Homeowner Side-by-Side Market Share............................................ 9-11 

Table 9.3.5 Product Class Market Shares of Standard-size Refrigerator-Freezers............... 9-13 

Table 9.3.6 Standard-size Freezers: Historical Shipments ................................................... 9-16 

Table 9.3.7 Saturation of Freezers in New Housing............................................................. 9-17 

Table 9.3.8 Product Class Market Share of Standard-size Freezers ..................................... 9-19 

9-i 

EERE-2008-BT-STD-0012 COMMENT 22
Table 9.3.9 Compact Refrigerators: Historical Shipments ................................................... 9-21 

Table 9.3.10 Product Class Market Shares of Compact Refrigerators ................................... 9-24 

Table 9.3.11 Compact Freezers: Historical Shipments........................................................... 9-26 

Table 9.3.12 Product Class Market Shares of Compact Freezers........................................... 9-28 

Table 9.4.1 Change in Relative Price Elasticity following a Purchase Price Change .......... 9-31 

LIST OF FIGURES 

Figure 9.3.1 Standard-size Refrigerator-Freezers: Survival and Retirement Functions .......... 9-7 

Figure 9.3.2 Projected Market Share of Side- And Bottom-Freezer Product Classes ........... 9-12 

Figure 9.3.3 Standard-Size Refrigerator-Freezers: Historical and Base Case Shipments 

Forecast by Market Segment ............................................................................. 9-14 

Figure 9.3.4 Standard-size Refrigerator-Freezers: Base Case Shipments Forecast by 

Product Class Group .......................................................................................... 9-15 

Figure 9.3.5 Standard-size Freezers: Survival and Retirement Functions ............................. 9-18 

Figure 9.3.6 Standard-size Freezers: Historical and Base Case Shipments Forecast by
 

Market Segment................................................................................................. 9-20 

Figure 9.3.7 Standard-size Freezers: Base Case Shipments Forecast by Product Class........ 9-20 

Figure 9.3.8 Forecast of Saturation of Compact Refrigerators in New Construction 

Market Segments ............................................................................................... 9-23 

Figure 9.3.9 Compact Refrigerators: Survival and Retirement Functions............................. 9-24 

Figure 9.3.10 Compact Refrigerators: Base Case Shipments Forecast by Market 

Segment.............................................................................................................. 9-25 

Figure 9.3.11 Compact Refrigerators: Base Case Shipments Forecast by Product Class........ 9-25 

Figure 9.3.12 Compact Freezers: Survival and Retirement Functions..................................... 9-27 

Figure 9.3.13 Compact Freezers: Historical and Base Case Shipments Forecast by 

Market Segment................................................................................................. 9-28 

Figure 9.3.14 Compact Freezers: Base Case Shipments Forecast Disaggregated by 

Product Class ..................................................................................................... 9-29 

Figure 9.6.1 Standard-Size Refrigerator-Freezers: Base Case and Standards Case 

Shipments Forecasts........................................................................................... 9-33 

Figure 9.6.2 Standard-size Freezers: Base Case and Standards Case Shipments 

Forecasts ............................................................................................................ 9-34 

Figure 9.6.3 Compact Refrigerators: Base Case and Standards Case Shipments 

Forecasts ............................................................................................................ 9-35 

Figure 9.6.4 Compact Freezers: Base Case and Standards Case Shipments Forecasts.......... 9-36 

9-ii 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 9. SHIPMENTS ANALYSIS 

9.1 INTRODUCTION 

Estimates of future product shipments are a necessary input to calculations of the national 

energy savings (NES) and net present value (NPV), as well as to the manufacturer impact 

analysis (MIA). This chapter describes the data and methods the U.S. Department of Energy 

(DOE) used to forecast annual product shipments and presents results for each of the 

refrigeration product classes being considered in this analysis. 

DOE defined four refrigeration product types, and developed models to estimate 

shipments for each type. The four types are: (1) standard-size refrigerator-freezers, (2) standardsize freezers, (3) compact refrigerators, and (4) compact freezers. DOE calibrated each model 

against historical shipments. To estimate the effects of potential standard levels on shipments of 

each product class, each model was structured to account for the combined effects on consumer 

purchase decisions of changes in product cost, annual operating cost, and household income. 

Each model considers specific market segments to estimate shipments of individual 

product classes within each segment. The analytical results from these segments then are 

aggregated to estimate total shipments for each product class and type. For the product types 

included in this analysis, DOE considered three market segments: (1) new construction or new 

owners; (2) replacements for failed products; and (3) for standard-size refrigerators, the purchase 

of an additional refrigerator. 

The shipments models were developed as Microsoft Excel spreadsheets that are 

accessible on the Internet (www.eere.energy.gov/buildings/appliance_standards/). Appendix 10­

A discusses how to access and utilize the shipments model spreadsheets, which are integrated 

into spreadsheets for the National Impact Analysis. The rest of this chapter explains the 

shipments models in more detail. Section 9.2 presents methodology behind the models; section 

9.3 describes the data inputs and calibration of each model; section 9.4 discusses impacts on 

shipments from changes in product cost, operating cost, and household income; section 9.5 

discusses the affected stock; and section 9.6 presents the shipments forecast for different energy 

conservation standard-level scenarios. 

9.2 SHIPMENTS MODEL METHODOLOGY 

DOE developed a model of the national stock of in-service appliances for estimating 

annual shipments for each of the four product types considered for this standards rulemaking. 

The model considers market segments as distinct inputs to the shipments forecast. As represented 

by the following equation, the two primary market segments for standard-size products are new 

installations and replacements. 

9-1 

EERE-2008-BT-STD-0012 COMMENT 22
_ _ 

Ship ( j ) = Rpl ( j ) + NI ( j ) p p p 

Where: 

Shipp(j) = total shipments of product p in year j, 

Rplp(j) = units of product p retired and replaced in year j, and 

NIp(j) = number of new installations of product p in year j. 

DOE’s shipments models take an accounting approach, tracking market shares of each 

product class, the vintage of units in the existing stock, and expected construction trends. Rather 

than simply extrapolating a current shipments trend, the analysis of the base case for each type 

(i.e., the case without new standards) uses input variables as drivers, including construction 

forecasts and product lifetime distributions, to forecast sales in each market segment. As a result, 

DOE’s shipments models assume that new construction drives shipments. 

To estimate shipments of replacement units, the models utilize shipments data from 

previous years and assumptions about the lifetime of each product. Estimated shipments of 

replacement units in a given year are equal to the total stock of the appliance minus those units 

shipped in previous years that remain in the stock. DOE determined the useful service life of 

each product class to estimate how many years it is likely to remain in stock. The following 

equation shows how DOE estimated shipments of replacement units. 

_ ageMax j 1 

Rpl p ( j ) = Stock p ( j 1) ∑ ∑Ship j × probRtr ( age ) 

age=0 j= N 

Where: 

Stockp (j-1) = total stock of appliances in year j-1, 

probRtr (age) = probability that an appliance of a particular age will be retired, and 

N = year in which the model begins its stock accounting (start year is specific to each 

product type, and is based on available historical shipments data). 

Stock accounting provides an estimate of the age distribution of product stocks for all 

years, using product shipments, a retirement function, and initial product stock as inputs. The age 

distribution of product stocks is a key input to both the NES and NPV calculations because the 

operating costs for any year depend on the age distribution of the stock. Operating cost is 

dependent on the product age distribution under a standards case scenario that produces 

increasing efficiency over time, where older, less efficient units may have higher operating costs, 

while younger, more-efficient units will have lower operating costs. 

DOE calculated total stock of each product by integrating historical shipments data 

beginning with a specific year. The start year depended on the historical data available for the 

product. As units are added to the stock, some of the older ones retire and exit the stock. To 

9-2 

EERE-2008-BT-STD-0012 COMMENT 22
estimate future shipments, DOE developed a series of equations that define the dynamics and 

accounting of stocks. For new units, the equation is: 

_ Stock( j,age = 1) = Ship( j 1) 

Where: 

Stock(j, age) = number of units of a particular age, 

j = year for which the stock is being estimated, and 

Ship (j) = number of units purchased in year j. 

The above equation states that the number of one-year-old units is simply equal to the number of 

new units purchased the previous year. Slightly more complicated equations, such as the 

following equation, describe how the model accounts for the existing stock of units. 

Stock( j +1,age +1) = Stock( j,age )×[1 _ prob Rtr ( age )] 

In this equation, as the year is incremented from j to j+1, the age is also incremented from age to 

age+1. Over time, a fraction of the stock is removed; that fraction is determined by a retirement 

probability function, probRtr(age), which is described in section 9.3. Because the products 

considered in this rulemaking are common appliances that have been used by U.S. consumers for 

a long time, replacements typically constitute the majority of shipments. 

9.3 DATA INPUTS AND MODEL CALIBRATION 

For standard-size products designed for residential application, DOE used two inputs to 

estimate shipments driven by new construction: new housing forecasts and saturation of the 

product in new housing. New housing includes newly constructed single- and multi-family units, 

termed “new housing completions,” and mobile home placements. For new housing completions 

and mobile home placements, DOE used recorded data through 2007, and adopted the 

projections from the DOE Energy Information Administration (EIA)’s Annual Energy Outlook 

2009 (AEO2009) for the period 2008–2030.1

 To determine new construction shipments for 

standard-size products, DOE used forecasts of market saturations combined with forecasts of 

housing starts. For compact products, which are used in both residential and commercial 

applications, DOE used market saturations in combination with forecasts of housing starts and 

new commercial construction. 

DOE estimated replacements using product retirement functions that it developed based 

on product lifetimes. The retirement functions for all product types are described in detail in 

chapter 8. The retirement functions use the following equation to determine the probability of 

retirement at a certain age for the considered products: 

9-3 

EERE-2008-BT-STD-0012 COMMENT 22
_ _ 

_ ageMax j 1 

Rpl p ( j ) = Stock p ( j 1) ∑ ∑Ship j × probRtr ( age ) 

age=0 j= N 

Where: 

Stockp (j-1) = total stock of appliances in year j-1, 

Shipj = shipments in year j, 

probRtr (age) = probability that an appliance of a particular age will be retired, and 

N = year in which the model begins its stock accounting (start year is specific to each 

product type, and is based on available historical shipments data). 

DOE used historical shipments data to calibrate its shipments models. For standard-size 

refrigerator-freezers and standard-size freezers, modeled new construction shipments and 

replacements were insufficient to account for all product shipments. DOE therefore developed 

two additional market segments to calibrate its model: “additional refrigerator purchase” for 

refrigerators and “existing homes without the appliance” for freezers. The “additional 

refrigerator purchase” segment represents those purchases that are meant to be used as a new 

primary refrigerator while the former primary refrigerator is converted to a second refrigerator, 

as well as a small number of direct purchases of second refrigerators. Chapter 8 describes in 

detail how DOE estimated the probability that a primary refrigerator will be converted to a 

second refrigerator. 

The following sections explain in detail each of the data inputs for each product type. 

9.3.1 Standard-size Refrigerator-Freezers 

DOE considered seven product classes of standard-size refrigerator-freezers for this 

rulemaking. DOE’s shipments model for these product classes used the aggregate shipments, that 

is, the shipments for all seven product classes, as the basis for its forecasts. DOE did not develop 

a separate shipments model for each refrigerator-freezer product class. Instead, DOE 

disaggregated total shipments into product classes using various data and assumptions. 

9.3.1.1 Historical Shipments 

DOE used historical shipments data (i.e., domestic shipments and imports) to populate 

and calibrate its shipments model for standard-size refrigerator-freezers. It used the following 

sources to establish historical shipments: Appliance magazine’s Statistical Review,2,3,4 AHAM 

Factbooks,5,6 and an AHAM data submittal related to this rulemaking.7

 Table 9.3.1 summarizes 

the historical shipments data. DOE developed a total stock estimate by integrating historical 

shipments. Over time, some of the units are retired and removed from the stock, triggering the 

purchase of a new unit. Because of the relationship between retirements and total stock, there is a 

strong correlation between past and future shipments, independent of conservation standards. 

9-4 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 9.3.1 Standard-size Refrigerator-Freezers: Historical Shipments 

Year 

Shipments 

millions Year 

Shipments 

millions 

1951 4.075 1980 5.124 

1952 3.570 1981 4.944 

1953 3.650 1982 4.364 

1954 3.600 1983 5.340 

1955 4.200 1984 5.882 

1956 3.700 1985 6.002 

1957 3.350 1986 6.410 

1958 3.117 1987 6.748 

1959 3.785 1988 6.733 

1960 3.475 1989 6.453 

1961 3.480 1990 6.456 

1962 3.775 1991 6.411 

1963 4.125 1992 6.721 

1964 4.545 1993 7.047 

1965 4.931 1994 7.589 

1966 4.974 1995 7.650 

1967 4.713 1996 7.975 

1968 5.150 1997 7.924 

1969 5.296 1998 8.774 

1970 5.286 1999 9.099 

1971 5.691 2000 9.217 

1972 6.315 2001 9.305 

1973 6.774 2002 9.744 

1974 5.982 2003 10.021 

1975 4.577 2004 10.913 

1976 4.817 2005 11.134 

1977 5.707 2006 11.078 

1978 5.890 2007 10.402 

1979 5.707 2008 9.314 

Sources: 2005–2007: AHAM Data Submittal, 2009; 1995–2004: AHAM Fact Book 2005; 1992–1994: AHAM 

Factbook 2003; 1951–1992: Appliance Magazine, “Statistical Review,” various issues. 

9.3.1.2 Markets and Model Calibration 

The market for standard-size refrigerator-freezers is primarily comprised of units for new 

construction, replacement units for products that have been retired, and purchases driven by the 

9-5 

EERE-2008-BT-STD-0012 COMMENT 22
conversion of an existing unit from first to second refrigerator. Total shipments are represented 

by the following equation: 

ShipSRRF ( j) = RplSRRF ( j) + NH SRRF ( j) + ConvSRRF ( j) 

Where: 

ShipSRRF (j) = total shipments of standard-size refrigerator-freezers in year j, 

RplSRRF (j) = replacement shipments in year j, 

NH SRRF(j) = shipments to new households in year j, and 

ConvSRRF (j)= shipments due to additional refrigerator purchase (conversion of first to second 

refrigerator) in year j. 

The following sections discuss these three markets in further detail. 

 New Construction. To estimate shipments driven by new residential construction, DOE 

multiplied the housing starts forecast for each year by the estimated saturation of standard-size 

refrigerator-freezers in new housing. DOE based saturation for a given year on the calculated 

saturation in the previous year. DOE froze the saturation at the level corresponding to year 2008 

(1.3 per new home), the last year for which shipments data are available. The following equation 

describes the method used for calculating saturation for new construction: 

Sat NC ( j −1) = Stock( j) / HStock( j) 

Sat NC ( j) = Sat NC (2008)∀j > 2008

Where: 

SatNC(j) = market saturation of standard-size refrigerator-freezers in the new housing market 

segment in year j, 

Stock(j) = total stock of standard-size refrigerator-freezers in year j, 

HStock(j) = total number of housing units in year j, and 

SatNC(2008) = market saturation of standard-size refrigerator-freezers in the new housing market 

segment in 2008. 

Table 9.3.2 presents historical and forecasted new housing starts based on EIA’s 

AEO2009 for the period 1990–2030. AEO2009 provides three sets of housing starts forecasts, 

based on economic growth scenarios: a Reference case, a High Economic Growth case, and a 

Low Economic Growth case. DOE used the Reference Case that incorporates the effects from 

the American Recovery and Reinvestment Act.1 DOE used the high and low growth scenarios 

from the March 2009 release of the AEO2009.

8

 DOE used the forecasts from the Reference case 

to estimate its shipments to new housing, which is comprised of single- and multi-family units 

(new housing completions) and mobile home placements. For 2031−2043, DOE froze 

completions at the 2030 level for all three economic scenarios. 

9-6 

EERE-2008-BT-STD-0012 COMMENT 22
% Retiring 

 Replacements. DOE determined refrigerator-freezer shipments to the replacement market 

using an accounting method that tracks the total stock of units by vintage. DOE estimated a stock 

by vintage by integrating historical shipments. Over time, some units are retired and removed 

from the stock, thereby triggering the shipment of replacement units. A certain percentage 

(depending on the age) of units will fail each year and need to be replaced. To determine when a 

unit fails, DOE used a survival function based on a product lifetime distribution with an average 

value of 17.1 years. Chapter 8 provides a more thorough discussion of product lifetimes. Figure 

9.3.1 shows the survival and retirement functions that DOE used to estimate replacement 

shipments for all product classes of standard-size refrigerator-freezers. 

100% % Surviving 

90% 

80% 

70% 

60% 

50% 

40% 

30% 

20% 

10% 

0% 

0 5 10 15 20 25 30 35 40 45 50 

Age 

Figure 9.3.1 Standard-size Refrigerator-Freezers: Survival and 

Retirement Functions 

9-7 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 9.3.2 Historical and Forecasted Housing Starts (millions) 

Year 

Reference 

Case 

High 

Growth 

Low 

Growth Year 

Reference 

Case 

High 

Growth 

Low 

Growth 

1990 1.38 1.38 1.38 2017 1.99 2.40 1.60 

1991 1.18 1.18 1.18 2018 2.00 2.42 1.59 

1992 1.41 1.41 1.41 2019 2.01 2.34 1.53 

1993 1.54 1.54 1.54 2020 1.99 2.16 1.39 

1994 1.76 1.76 1.76 2021 1.93 2.11 1.33 

1995 1.69 1.69 1.69 2022 1.89 2.10 1.30 

1996 1.82 1.82 1.82 2023 1.87 2.11 1.27 

1997 1.49 1.49 1.49 2024 1.87 2.15 1.26 

1998 1.54 1.54 1.54 2025 1.89 2.21 1.27 

1999 1.64 1.64 1.64 2026 1.88 2.27 1.25 

2000 1.70 1.70 1.70 2027 1.84 2.28 1.22 

2001 1.72 1.72 1.72 2028 1.79 2.26 1.19 

2002 1.75 1.75 1.75 2029 1.76 2.27 1.17 

2003 1.79 1.79 1.79 2030 1.77 2.30 1.18 

2004 1.80 1.80 1.80 2031 1.77 2.30 1.18 

2005 2.22 2.22 2.22 2032 1.77 2.30 1.18 

2006 1.92 1.92 1.92 2033 1.77 2.30 1.18 

2007 1.75 1.75 1.75 2034 1.77 2.30 1.18 

2008 1.48 1.61 1.28 2035 1.77 2.30 1.18 

2009 1.30 1.70 1.28 2036 1.77 2.30 1.18 

2010 1.08 1.38 1.02 2037 1.77 2.30 1.18 

2011 1.51 1.82 1.31 2038 1.77 2.30 1.18 

2012 1.73 2.06 1.47 2039 1.77 2.30 1.18 

2013 1.86 2.23 1.56 2040 1.77 2.30 1.18 

2014 1.89 2.30 1.59 2041 1.77 2.30 1.18 

2015 1.93 2.39 1.59 2042 1.77 2.30 1.18 

2016 1.98 2.42 1.60 2043 1.77 2.30 1.18 

Source: EIA, AEO2009. 

Shipments Due to Additional Refrigerator Purchase. To calibrate estimated shipments 

with historical data, DOE introduced into the model a market segment corresponding to 

purchases of additional standard-size refrigerator-freezers that are not intended as replacements. 

Because such purchases involve converting a first unit to a second refrigerator, DOE estimated 

shipments to this market segment by applying the probability of conversion (developed in 

chapter 8) to the stock of surviving refrigerators. To determine when a household converts a first 

refrigerator to a second one, DOE used a conversion function based on the total installed stock of 

refrigerators of a certain age. Chapter 8 provides a detailed discussion of the conversion function. 

The following equation shows how DOE calculated shipments to this market segment. 

9-8 

EERE-2008-BT-STD-0012 COMMENT 22
 

_ ageMax j 1 

SNewSRRF ( j) = Cj × ∑∑Stock(age) j × probconv (age) 

age=0 j=N 

Where: 

SNewSRRF (j )= shipments due to additional refrigerator purchase (conversion of first to second 

refrigerator) in year j, 

Cj = a calibration factor, equal to the ratio of new shipments in year j to the installed 

stock in that year, and 

Probconv(age) = probability that the refrigerator has been converted at a given age 

9.3.1.3 Disaggregation into Separate Refrigerator-Freezer Product Classes 

DOE examined the historical trends in the market shares of various refrigerator-freezer 

configurations to disaggregate the total shipments of refrigerator-freezers into shipments to each 

of the three considered refrigerator-freezer product categories (top-mount, bottom-mount and 

side-by-side configurations). The market share of side-by-side refrigerator-freezers models has 

grown significantly during the past two decades. Bottom-freezer models historically have had a 

small market share, but that share has grown in recent years. To forecast the market share for 

these three configurations throughout the 30-year analysis period (beginning in 2014), DOE built 

a simple model of aggregate consumer behavior, fit its model to the historical growth in side-byside market share, and then used its model to estimate future market shares for all three 

configurations. 

DOE assumed that bottom-freezer models were an insignificant portion of the market 

prior to 2005, and that consumer behavior related to these classes in the future would mirror 

behavior regarding side-by-side models. Therefore, DOE forecast the combined market share for 

side-by-side and bottom-freezer products. DOE assumed that the ratio between the market share 

of bottom-mount and the market share of side-mount products would remain fixed at its 2008 

value. 

DOE based its model on the market share of each product category as reported by 

households in the Energy Information Administration’s Residential Energy Consumption 

Survey9

 (RECS) and as reported by the Association of Home Appliance Manufacturers 

(AHAM).7

 RECS reports whether a household owns a side-by-side refrigerator, but does not 

distinguish between top- and bottom-mount units. For the purpose of this model, DOE assumed 

that all recently-purchased top-or-bottom-mount refrigerators reported in the RECS surveys 

conducted in 1990, 1993, 1997, 2001, and 2005 are top-mount units. 

DOE used RECS data first to estimate the maximum (“limiting”) market share that sideby-side and bottom-mount product classes would attain in the future. RECS reports the income 

of each household in its sample. DOE assumed that households that have annual incomes greater 

than $100,000 and that own their own homes are able to select the appliance that best meets their 

needs and preferences. The market share of side-by-side units in these households is significantly 

9-9 

EERE-2008-BT-STD-0012 COMMENT 22
higher than the current overall market share of side-by-side products. DOE determined market 

shares for recent purchases from RECS by considering only households which reported 

purchasing their appliance within two years prior to the survey. The market share of side-by-side 

refrigerator purchases in the selected household group from each RECS survey is shown in Table 

9.3.3. Over time, DOE assumed that all homeowners will be free to choose the product of their 

choice, as DOE assumed high-income homeowners can today. As a result, DOE assumed that 

market share of side-by-side units among all homeowners will increase until it equals the mean 

market share among high-income home-owning households, 66.4 percent. 

Table 9.3.3 Market Shares of Side-by-Side Refrigerator-Freezers 

RECS Survey Year 

Market Share of Side-by-Side Units for HighIncome Homeowners % 

1990 57.7 

1993 71.7 

1997 73.4 

2001 61.6 

2005 67.5 

Mean 66.4 

Source: EIA, Residential Energy Consumption Survey, for the years listed. 

DOE used RECS to determine what percent of side-by-side units is sold to home-owners 

in order to convert a limiting market share among home-owning households into a market share 

for all shipments. This pecentage was roughly constant in the five most recent RECS surveys, 

and DOE assumed that it would remain equal to their mean, 90.9 percent, throughout the forecast 

period. DOE also assumed that the percent of American households that own their home would 

return to its historical level of roughly 65 percent by 2025. (American home ownership was 

between 63 percent and 66 percent from 1962 to 1997, peaked at 69 percent in 2004, and fell to 

67.8 percent in 2008.) 

DOE combined the three factors (the observed preference of high-income consumers, 

percent of side-by-side refrigerator-freezers purchased by homeowners, and homeownership) to 

predict the limiting market share for the side- and bottom-freezer product classes. This limit is 

MS HO−LIM LIM × HO MS SF −LIM = = 47.45%

SFHO 

Where: 

MSSF-LIM = limiting market share for side-by-side and bottom-mount product classes, 

MSHO-LIM = limiting market share for side-by-side and bottom- mount product classes among 

homeowners (66.4 percent), 

HOLIM = DOE’s assumed value for the eventual percentage of households that will own 

their own home (65 percent), and 

9-10 

EERE-2008-BT-STD-0012 COMMENT 22
SFHO = the percentage of side-by-side and bottom-mount products sold to homeowners 

(90.9 percent). 

DOE modeled the approach to this limiting value as an exponential curve, and fit the 

model parameters to data from RECS and AHAM in order to determine the rate at which the 

market will approach the limit. RECS micro-data enabled DOE to determine the approximate 

market share of side-by-side products among all homeowners in the years preceding each RECS 

survey (1989, 1992, 1996, 2000, and 2004). DOE also calculated the market share among 

homeowners from the AHAM data by multiplying by 90.9 percent (SFHO) and dividing by the 

homeownership (HO) for each year. The resulting estimates for market shares of side-by-side 

products among homeowners are shown in Table 9.3.4. 

Table 9.3.4 Modeled Homeowner Side-by-Side Market Share 

Survey Year 

Homeowner Side-freezer 

Market Share 

AHAM 1998 41.0% 

1999 41.9% 

2000 42.2% 

2001 43.0% 

2002 43.9% 

2003 45.9% 

2004 46.2% 

2005 49.1% 

2006 59.8% 

2007 61.4% 

RECS 1989 32.5% 

1992 31.9% 

1996 41.1% 

2000 48.9% 

2004 53.0% 

DOE fit an exponential curve to the data in Table 9.3.4, approaching the limiting value 

MSSF-LIM: 

α (β − year ) MS = MS − , HO− year HO−LIM e 

Where: 

MSHO-year = market share of side-by-side and bottom-mount refrigerator-freezers among all 

homeowners in a given year, 

α, β = fit parameters, and 

MSHO-LIM = limiting market share for side- and bottom-freezer product classes among 

homeowners (66.4 percent). 

9-11 

EERE-2008-BT-STD-0012 COMMENT 22
 

The best fit parameters are: α = 0.05555 and β = 1971.62. 

The R-squared value for the fit is 0.924, indicating that the model is a relatively good fit. 

DOE multiplied the best-fit estimate of MSHO-year by homeownership in each year, then divided 

by SFHO to account for side- and bottom-mount refrigerators sold to non-homeowners. The 

results are estimated market shares of side-by-side or bottom-mount products throughout the 

analysis period. This estimate, along with the markets shares derived from the RECS and AHAM 

data, is shown in Figure 9.3.2. 

20.00% 

25.00% 

30.00% 

35.00% 

40.00% 

45.00% 

50.00% 

Side- and Bottom-freezer Market Share

Forecast market share 

AHAM Shipments Share 

RECS Side-freezer 

Limiting fraction 

1985 1995 2005 2015 2025 2035 2045 

Year 

Figure 9.3.2 Projected Market Share of Side- And Bottom-Freezer 

Product Classes 

DOE disaggregated the side and bottom-mount freezer classes into their respective 

product classes based on the AHAM data submittal for the years 2005-2008. For future years, 

DOE maintained the market shares of the product classes within each considered category of 

side-by-side and bottom-mount, and top-mount refrigerator-freezer as they existed in 2008. 

Table 9.3.5 presents the resulting market share forecast DOE used to disaggregate total modeled 

shipments. 

9-12 

EERE-2008-BT-STD-0012 COMMENT 22
Table 9.3.5 Product Class Market Shares of Standard-size Refrigerator-Freezers 

Year PC1 PC2 PC3 PC4 PC5 PC6 PC7 PC5A 

2005 0.2% 0.1% 62.4% 1.0% 1.6% 0.1% 34.1% 0.4% 

2006 0.2% 0.1% 54.4% 1.0% 8.4% 0.1% 33.6% 2.2% 

2007 0.1% 0.0% 53.8% 0.8% 10.7% 0.1% 31.6% 2.9% 

2008 0.1% 0.0% 55.8% 0.8% 10.3% 0.1% 30.2% 2.7% 

2009 0.1% 0.0% 57.7% 0.7% 9.8% 0.1% 28.8% 2.6% 

2010 0.1% 0.0% 59.6% 0.7% 9.4% 0.1% 27.6% 2.5% 

2011 0.1% 0.0% 59.3% 0.7% 9.5% 0.1% 27.8% 2.5% 

2012 0.1% 0.0% 59.0% 0.7% 9.5% 0.1% 28.0% 2.5% 

2013 0.1% 0.0% 58.7% 0.7% 9.6% 0.1% 28.2% 2.6% 

2014 0.1% 0.0% 58.4% 0.7% 9.7% 0.1% 28.4% 2.6% 

2015 0.1% 0.0% 58.1% 0.7% 9.7% 0.1% 28.6% 2.6% 

2016 0.1% 0.0% 57.8% 0.7% 9.8% 0.1% 28.8% 2.6% 

2017 0.1% 0.0% 57.6% 0.7% 9.9% 0.1% 28.9% 2.6% 

2018 0.1% 0.0% 57.3% 0.8% 9.9% 0.1% 29.1% 2.6% 

2019 0.1% 0.0% 57.1% 0.8% 10.0% 0.1% 29.3% 2.7% 

2020 0.1% 0.0% 56.8% 0.8% 10.0% 0.1% 29.5% 2.7% 

2021 0.1% 0.0% 56.7% 0.8% 10.1% 0.1% 29.6% 2.7% 

2022 0.1% 0.0% 56.5% 0.8% 10.1% 0.1% 29.7% 2.7% 

2023 0.1% 0.0% 56.3% 0.8% 10.2% 0.1% 29.8% 2.7% 

2024 0.1% 0.0% 56.1% 0.8% 10.2% 0.1% 29.9% 2.7% 

2025 0.1% 0.0% 56.0% 0.8% 10.2% 0.1% 30.0% 2.7% 

2026 0.1% 0.0% 55.8% 0.8% 10.3% 0.1% 30.2% 2.7% 

2027 0.1% 0.0% 55.6% 0.8% 10.3% 0.1% 30.3% 2.7% 

2028 0.1% 0.0% 55.4% 0.8% 10.4% 0.1% 30.4% 2.8% 

2029 0.1% 0.0% 55.3% 0.8% 10.4% 0.1% 30.5% 2.8% 

2030 0.1% 0.0% 55.1% 0.8% 10.4% 0.1% 30.7% 2.8% 

2031 0.1% 0.0% 55.0% 0.8% 10.5% 0.1% 30.7% 2.8% 

2032 0.1% 0.0% 54.8% 0.8% 10.5% 0.1% 30.8% 2.8% 

2033 0.1% 0.0% 54.7% 0.8% 10.5% 0.1% 30.9% 2.8% 

2034 0.1% 0.0% 54.5% 0.8% 10.6% 0.1% 31.0% 2.8% 

2035 0.1% 0.0% 54.4% 0.8% 10.6% 0.1% 31.1% 2.8% 

2036 0.1% 0.0% 54.3% 0.8% 10.6% 0.1% 31.2% 2.8% 

2037 0.1% 0.0% 54.2% 0.8% 10.6% 0.1% 31.3% 2.8% 

2038 0.1% 0.0% 54.1% 0.8% 10.7% 0.1% 31.3% 2.8% 

2039 0.1% 0.0% 54.0% 0.8% 10.7% 0.1% 31.4% 2.8% 

2040 0.1% 0.0% 53.9% 0.8% 10.7% 0.1% 31.5% 2.8% 

2041 0.1% 0.0% 53.8% 0.8% 10.7% 0.1% 31.6% 2.9% 

2042 0.1% 0.0% 53.5% 0.8% 10.8% 0.1% 31.7% 2.9% 

2043 0.1% 0.0% 53.4% 0.8% 10.8% 0.1% 31.8% 2.9% 

9-13 

EERE-2008-BT-STD-0012 COMMENT 22
 

9.3.1.4 Base Case Shipments 

Figure 9.3.3 shows the forecasted shipments in the base case (without new energy 

conservation standards) and the historical shipments DOE used to calibrate the forecast. The 

figure also presents shipments due to retirements, shipments to new housing, and shipments due 

to conversion from first to second unit. Figure 9.3.4 presents forecasted refrigerator-freezer 

shipments disaggregated by product category. 

25.0
 

Conversion
 

New construction
 

0.0

5.0

10.0

15.0

20.0

Millions 

Replacements

Modeled Shipments

Historical Shipments

19901995200020052010201520202025203020352040

Figure 9.3.3 Standard-Size Refrigerator-Freezers: Historical and Base 

Case Shipments Forecast by Market Segment 

9-14 

EERE-2008-BT-STD-0012 COMMENT 22
 

25.0

PC: 5, 5A 

0.0

5.0

10.0

15.0

20.0

Millions 

PC: 4, 7 

PC: 1, 1A, 3, 3A, 6 

Historical Shipments 

Total Shipments 

19901995200020052010201520202025203020352040

Figure 9.3.4 Standard-size Refrigerator-Freezers: Base Case Shipments 

Forecast by Product Class Group 

9.3.2 Standard-size Freezers 

DOE considered four product classes of standard-size freezers in its analysis. DOE’s 

shipments model for these classes uses the aggregate shipments for all four product classes as the 

basis for its forecasts. In other words, DOE did not develop a separate shipments model for each 

freezer product class. Instead, DOE used various data and assumptions to disaggregate total 

shipments into product classes. 

9.3.2.1 Historical Shipments 

DOE used data on historical shipments (i.e., domestic shipments and imports) from 

Appliance magazine’s Statistical Review,10 AHAM Factbook,5 and an AHAM data submittal7 to 

populate and calibrate its shipments model. DOE built up a total stock of freezers by integrating 

historical shipments. Over time, some of the units are retired and removed from the stock, 

triggering the shipment of new units to replace them. Because of the relationship between 

retirements and total stock, there is a strong correlation between past and future shipments, 

independent of conservation standards. Table 9.3.6 summarizes the historical shipments data for 

standard-size freezers. 

9-15 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 9.3.6 Standard-size Freezers: Historical Shipments 

Year Shipments 

millions Year Shipments millions 

1983 1.320 1996 1.548 

1984 1.261 1997 1.490 

1985 1.222 1998 1.628 

1986 1.209 1999 1.988 

1987 1.242 2000 1.963 

1988 1.316 2001 2.215 

1989 1.172 2002 2.535 

1990 1.241 2003 2.523 

1991 1.324 2004 2.516 

1992 1.525 2005 2.214 

1993 1.438 2006 2.148 

1994 1.546 2007 1.992 

1995 1.558 

Sources: 2005–2007: AHAM Data Submittal, 2009; 1997–2004: AHAM Fact Book 2005; 1983–1996: Appliance 

Magazine, “Statistical Review,” various issues 

9.3.2.2 Markets and Model Calibration 

The shipments market for standard-size freezers is primarily comprised of units for new 

construction and replacement units for products that have been retired. DOE’s shipments model 

also assumes that some existing households that do not currently own the appliance (i.e. EHA) 

will enter the market as new owners. Total shipments are represented by the following equation: 

Ship ( j) = Rpl ( j) + NH ( j) + EHA ( j) SF SF SF SF 

Where: 

ShipSF (j) = total shipments of standard-size freezers in year j, 

RplSF (j) = replacement shipments in year j, 

NH SF(j) = shipments to new households in year j, and 

EHASF (j)= shipments to existing households without the appliance in year j. 

The following sections discuss all three of these markets in further detail. 

New Construction. To forecast the shipments of standard-size freezers for new 

construction for any given year, DOE multiplied the forecasted housing starts by the forecasted 

saturation of standard-size freezers for new housing. DOE used saturation in new housing from 

the 1993, 1997, 2001, and 2005 RECS surveys.8

 DOE determined the saturations in new homes 

by using a sample of RECS household records whose home is less than 5 years old, with freezers 

9-16 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

of age less than 5 years. DOE froze the saturation at the estimated level corresponding to year 

2007 (0.119 per new home). Table 9.3.7 presents the freezer saturation data in new housing 

units. 

Table 9.3.7 Saturation of Freezers in New Housing 

Year 

New Housing Units that Contain New Freezers 

% 

1993 7.78 

1994 

1995 

1996 

1997 11.31 

1998 

1999 

2000 

2001 11.22 

2002 

2003 

2004 

2005 11.67 

Source: Source: EIA, Residential Energy Consumption Survey, for the years listed. 

Replacements. DOE determined shipments to the replacement market using an 

accounting method that tracks the total stock of units by vintage. DOE estimated the stock of 

standard-size freezers by vintage by integrating historical shipments. Over time, some units are 

retired and removed from the stock, triggering the shipment of a replacement unit. A certain 

percentage (depending on the age) of units will fail each year and need to be replaced. To 

determine when a unit fails, DOE used a survival function based on a product lifetime 

distribution that had an average value of 22.7 years. Chapter 8 presents a more thorough 

discussion of the lifetimes of standard-size freezers. Figure 9.3.5 shows the survival and 

retirement functions that DOE used to estimate shipments of replacement freezers. 

9-17 

EERE-2008-BT-STD-0012 COMMENT 22
100%
 

90%
 

80%
 

70%
 

60%
 

50%
 

40%
 

30%
 

20%
 

10%
 

0% 

0 5 10 15 20 25 30 35 40 45 50 

% Surviving 

% Retiring 

Age 

Figure 9.3.5 Standard-size Freezers: Survival and Retirement Functions 

Model Calibration—New Owners. To calibrate estimated shipments with the historical 

data, DOE introduced a market segment that consists of households that currently do not own a 

freezer. DOE estimated shipments to this market segment as residual historical shipments after 

shipments for new housing and replacements were subtracted from total shipments. DOE then 

used a 3-year moving average to estimate the percent of households who enter the market as new 

owners for 2008-2043. The following equation illustrates the calculations. 

EHASF ( j) = (1 − StockSat j ) × HStock j × EHAfrac j 

Where: 

EHASF (j) = number of freezers shipped to existing households without the appliance in year j, 

StockSatj = stock saturation of freezers in year j, 

HStockj = housing stock in year j, and 

EHAfracj = fraction of housing units without the appliance and obtain a freezer in year j. 

9.3.2.3 Disaggregation into Separate Freezer Product Classes 

To disaggregate the total shipments of standard-size freezers into shipments to each of 

the freezer product classes, DOE used the market share information submitted by AHAM.7

 The 

data submitted by AHAM provided an aggregated market share of 50.6 percent for product 

9-18 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

classes 8 and 10. DOE then used the shipments data from the 2005 AHAM Fact Book5 and 

Appliance magazine2 to disaggregate market shares for product classes 8 and 10. The AHAM 

Fact Book indicates a 59.5 percent market share for the combination of product classes 10 and 

10A. Since the market share for 10A is near zero, DOE attributed the combined market share of 

product classes 8 and 10 from the AHAM data submittal (50.6 percent) entirely to product class 

10 in order to be as close as possible to the AHAM Fact Book data. Table 9.3.8 presents the 

market share forecast used for disaggregating modeled shipments. DOE used these estimated 

market shares throughout the forecast period. 

Table 9.3.8 Product Class Market Share of Standard-size Freezers 

Year PC8 PC9 PC10 PC10A 

2008 0.0% 49.4% 50.6% 0.0% 

9.3.2.4 Base Case Shipments 

Figure 9.3.6 shows the forecasted shipments of standard-size freezer in the base case 

(without new energy conservation standards) and the historical shipments DOE used to calibrate 

the forecast. The figure also presents forecasted shipments disaggregated into its modeled market 

segments. Figure 9.3.7 presents shipment forecasts of standard-size freezers in the base case, 

disaggregated into product class groups.a 

a

 DOE grouped product classes 10 and 10A into one group. 

9-19 

EERE-2008-BT-STD-0012 COMMENT 22
 

1990

1995

2000

2005

2010

2015

2020

2025

2030

2035

2040

19901995200020052010

201520202025203020352040

Millions 

4.5

4.0

3.5

3.0

2.5

2.0

1.5

1.0

0.5

0.0

EHA Shipments 

NC Shipments 

Retirements 

Historical Shipments 

Modeled Shipments 

Figure 9.3.6	 Standard-size Freezers: Historical and Base Case 

Shipments Forecast by Market Segment 

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

Millions 

PC: 10, 10A 

PC9 

PC8 

Historical Shipments 

Modeled Shipments 

Figure 9.3.7	 Standard-size Freezers: Base Case Shipments Forecast 

by Product Class 

9-20 

EERE-2008-BT-STD-0012 COMMENT 22
 

9.3.3 Compact Refrigerators and Refrigerator-Freezers 

DOE analyzed five product classes of compact refrigerators for this rulemaking. DOE’s 

shipments model for these products utilizes aggregate shipments for all five product classes as 

the basis for its forecasts. In other words, DOE did not develop a separate shipments model for 

each product class. Instead, DOE used various data and assumptions to disaggregate total 

shipments into product classes. 

9.3.3.1 Historical Shipments 

DOE used data on historical shipments (domestic shipments and imports) to calibrate its 

shipments model. It developed historical shipments data based on data submitted by AHAM7

 and 

various issues of Appliance magazine.2,9 DOE built up a total stock of compact refrigerators by 

integrating historical shipments. Over time, some units are retired and removed from the stock, 

triggering the shipment of new units to replace them. Because of the relationship between 

retirements and total stock, there is a strong correlation between past and future shipments. Table 

9.3.9 summarizes the historical shipments data for compact refrigerators. 

Table 9.3.9 Compact Refrigerators: Historical Shipments 

Year Shipments (millions) Year Shipments (millions) 

1983 0.568 1996 1.070 

1984 0.602 1997 1.110 

1985 0.783 1998 1.186 

1986 0.810 1999 1.498 

1987 0.830 2000 1.530 

1988 1.000 2001 1.355 

1989 0.925 2002 2.038 

1990 0.933 2003 2.844 

1991 0.925 2004 2.567 

1992 0.950 2005 2.792 

1993 1.030 2006 1.641 

1994 0.950 2007 2.194 

1995 1.032 

Sources: 2005–2007: estimates based on AHAM Data Submittal, 2009;and 1983–2004: Appliance Magazine, 

“Statistical Review,” various issues. 

9.3.3.2 Markets and Model Calibration 

The market for compact refrigerators is primarily comprised of units that replace products 

that have been retired from service, and units installed in new housing, new lodging in the 

commercial sector (such as hotel rooms and dormitories), and in other new construction in the 

9-21 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

commercial sector. Total compact refrigerator shipments are represented by the following 

equation: 

Ship ( j) = Rpl ( j) + NH ( j) + NLodg ( j) + NOthComm ( j) CRRF CRRF CRRF CRRF CRRF 

Where: 

ShipCRRF (j) = total shipments of compact refrigerators in year j, 

RplCRRF(j) = replacement shipments in year j, 

NHCRRF (j) = shipments to new households in year j, 

NLodgCRRF (j) = shipments to new lodging units in year j, and 

NOthCommCRRF (j) = shipments to other new commercial establishments in year j. 

The following sections discuss these markets. 

 New Housing. To estimate shipments to new housing in each year, DOE multiplied 

forecasted housing starts by the estimated saturation of compact refrigerators in new housing 

units. DOE forecasted market saturation for this segment using the saturation of compact 

refrigerators in newly built homes in RECS 2001 and 2005 (2.7 percent and 3.2 percent, 

respectively). For years beyond 2005, DOE maintained the growth in new housing saturation 

measured between 2001 and 2005. 

New Lodging and Other Commercial New Construction. To estimate shipments to new 

commercial establishments, DOE used forecasts of new construction in lodging and other 

commercial establishments coupled with market saturation data (in units per building). DOE 

obtained the saturation data from the American Lodging Association (ALA)11 and the EIA’s 

Commercial Building Energy Consumption Survey (CBECS).12 For lodging, DOE used 

saturations from ALA for the years 1998, 2003, and 2008. For future years, DOE maintained the 

growth in saturation rates seen between 2003 and 2008. For other commercial applications, DOE 

used saturations from CBECS for the years 1999 and 2003. DOE maintained the growth in 

saturation rates seen between 1999 and 2003 for subsequent years. 

Figure 9.3.8 presents the forecast for saturation of compact refrigerators for the three 

market segments for new construction. 

9-22 

EERE-2008-BT-STD-0012 COMMENT 22
 

120% 

100% 

80% 

60% 

40% 

20% 

0% 

Lodging 

Other Commercial 

Residential 

2003 - 72% 

2003 - 48% 

2005 - 3.2% 

199019931996199920022005200820112014201720202023202620292032203520382041

Figure 9.3.8 Forecast of Saturation of Compact Refrigerators in New 

Construction Market Segments 

 Replacements. DOE determined shipments to the replacement market using an 

accounting method that tracks the total stock of units by vintage. DOE integrated historical 

shipments to estimate each year’s stock of compact refrigerators by vintage. Over time, some of 

the units are retired and removed from the stock, triggering the shipment of a new unit. Because 

of the relationship between retirements and total stock, there is a strong correlation between past 

and future shipments, independent of conservation standards. 

A certain percentage (depending on the age) of units will fail each year and need to be 

replaced. To determine when a compact refrigerator fails, DOE used a product survival function 

based on a lifetime distribution with an average value of 5.6 years. Chapter 8 presents a more 

thorough discussion of product lifetimes for compact refrigerators. Figure 9.3.9 shows the 

survival and retirement functions that DOE used to estimate replacement shipments. 

9-23 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

100% 

0% 

10% 

20% 

30% 

40% 

50% 

60% 

70% 

80% 

90% % Surviving 

% Retiring 

0 5 10 15 20 25 30 

Age 

Figure 9.3.9 Compact Refrigerators: Survival and Retirement 

Functions 

Model Calibration. To calibrate estimated shipments with the historical data, DOE 

utilized compact refrigerator stock data for 2003. DOE obtained commercial stock data from 

CBECS 2003 and estimated the 2003 residential stock from various years of RECS. Based on 

these sources, DOE estimated that in 2003 the stock was split 30 percent, 18 percent, and 52 

percent between residential, lodging, and other commercial sectors, respectively. 

9.3.3.3 Disaggregation into Separate Compact Refrigerator Product Classes 

DOE based its product class market shares for compact refrigerators on data submitted by 

AHAM7

 and CEC data13 on available compact refrigerator models. Table 9.3.10 presents the 

market share forecast used for disaggregating total modeled shipments. DOE used these 

estimated market shares throughout the forecast period. 

Table 9.3.10 Product Class Market Shares of Compact Refrigerators 

Year PC11 PC12 PC13 PC14 PC15 

2008 84.40% 5.92% 9.03% 0.32% 0.32% 

9.3.3.4 Base Case Shipments 

Figures 9.3.10 shows the forecasted shipments of compact refrigerators in the base case 

(without new energy conservation standards) along with the historical shipments DOE used to 

9-24 

EERE-2008-BT-STD-0012 COMMENT 22
 

1990

1993

1996

1999

2002

2005

2008

2011

2014

2017

2020

2023

2026

2029

2032

2035

2038

2041 

1990

1993

1996

1999

2002

2005

2008

2011

2014

2017

2020

2023

2026

2029

2032

2035

2038

2041

calibrate the forecast. The figure also presents forecasted shipments disaggregated into modeled 

market segments. Figure 9.3.11 presents the base case shipments forecast for compact 

refrigerators disaggregated by product class. (Product classes 14 and 15 are not visible in the 

figure because they account for a very small share of shipments.) 

7.00 

New other commercial 

0.00 

1.00 

2.00 

3.00 

4.00 

5.00 

6.00 

Millions 

New Lodging 

New housing 

Replacements 

Historical Shipments 

Modeled Shipments 

Figure 9.3.10	 Compact Refrigerators: Base Case Shipments Forecast 

by Market Segment 

7.0

PC15 

0.0

1.0

2.0

3.0

4.0

5.0

6.0

Millions 

PC14 

PC: 13, 13A 

PC12 

PC: 11, 11A 

Historical Shipments 

Total Shipments 

Figure 9.3.11	 Compact Refrigerators: Base Case Shipments Forecast 

by Product Class 

9-25 

EERE-2008-BT-STD-0012 COMMENT 22
 

9.3.4 Compact Freezers 

DOE considered three product classes of compact freezers for this analysis. DOE based 

its forecast shipments compact freezers on aggregate shipments, that is, shipments for all three 

product classes. In other words, DOE did not develop a separate shipments model for each 

product class. Instead, DOE used various data and assumptions to disaggregate total estimated 

shipments into product classes. 

9.3.4.1 Historical Shipments 

DOE used data on historical shipments (domestic shipments and imports) to populate and 

calibrate its shipments model for compact freezers. It obtained historical shipments data from 

data submitted by AHAM7

 and various issues of Appliance magazine2,9 ( Table 9.3.11). DOE 

built up a total stock of compact freezers by integrating historical shipments. Over time, some 

units are retired and removed from the stock, triggering the shipment of new units to replace 

them. Because of the relationship between retirements and total stock, there is a strong 

correlation between past and future shipments. 

Table 9.3.11 Compact Freezers: Historical Shipments 

Year Shipments (millions) Year Shipments (millions) 

1983 0.237 1996 0.335 

1984 0.242 1997 0.378 

1985 0.234 1998 0.393 

1986 0.247 1999 0.434 

1987 0.255 2000 0.474 

1988 0.287 2001 0.490 

1989 0.325 2002 0.520 

1990 0.337 2003 0.512 

1991 0.333 2004 0.696 

1992 0.319 2005 0.591 

1993 0.326 2006 0.524 

1994 0.304 2007 0.500 

1995 0.324 

Sources: 2005–2007: estimates based on AHAM Data Submittal, 2009; and 1983–2004: Appliance Magazine, 

“Statistical Review,” various issues. 

9.3.4.2 Markets and Model Calibration 

The market for compact freezers is primarily comprised of replacement units for products 

that have been retired from service and units purchased by new owners (not new construction) in 

both residential and commercial sectors. Total compact freezer shipments are represented by the 

following equation: 

9-26 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Ship ( j) = Rpl ( j) + NR ( j) + NC ( j) CF CF CF CF 

Where: 

ShipCF (j) = total shipments of compact freezers in year j, 

RplCF (j) = replacement shipments in year j, 

NR CF(j) = shipments to new residential owners in year j, and
 

NCCF (j)= shipments to new commercial owners in year j. 

The following sections discuss these markets in further detail. 

 Replacements. DOE determined shipments to the replacement market using an 

accounting method that tracks the total stock of units by vintage. DOE integrated historical 

shipments to estimate each year’s stock of compact freezers by vintage. Over time, some units 

are retired and removed from the stock, triggering the shipment of a replacement unit. A certain 

percentage (depending on the age) of units will fail each year and need to be replaced. To 

determine when a compact freezer fails, DOE used a product survival function based on a 

lifetime distribution with an average value of 7.46 years. Chapter 8 provides a more thorough 

discussion of product lifetimes for compact freezers. Figure 9.3.12 shows the survival and 

retirement functions that DOE used to estimate shipments of replacement units. 

0% 

10% 

20% 

30% 

40% 

50% 

60% 

70% 

80% 

90% 

100% 

% Surviving 

% Retiring 

0 5 10 15 20 25 30 

Age 

Figure 9.3.12 Compact Freezers: Survival and Retirement Functions 

New Owner. In the absence of data on saturation of compact freezers in homes or 

commercial applications, DOE estimated historical shipments to new owners based on the 

9-27 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

1990

1993

1996

1999

2002

2005

2008

2011

2014

2017

2020

2023

2026

2029

2032

2035

2038

2041 

difference between total shipments of compact freezers and estimated replacement shipments. 

DOE forecast new owner shipments using a 3-year moving average method. DOE assumed an 

even split between residential and commercial new owners for this segment. 

9.3.4.3 Disaggregation into Separate Compact Freezer Product Classes 

DOE used California Energy Commission (CEC) data on available freezer models to 

estimate market shares of product classes 16, 17, and 18.14 Table 9.3.11 presents the market 

share forecast used in this analysis for disaggregating total modeled shipments. DOE used the 

2008 market share estimates throughout the forecast period. 

Table 9.3.12 Product Class Market Shares of Compact Freezers 

Year PC16 PC17 PC18 

2008 50.0% 30.0% 20.0% 

9.3.4.4 Base Case Shipments 

Figure 9.3.13 shows the forecasted compact freezer shipments in the base case (without 

new energy efficiency standards), along with the historical shipments DOE used to calibrate the 

forecast. The figure presents compact freezer shipments disaggregated into the modeled market 

segments. Figure 9.3.14 presents forecasted base case compact freezer shipments disaggregated 

into the product classes. 

0.0 

0.1 

0.2 

0.3 

0.4 

0.5 

0.6 

0.7 

0.8 

0.9 

Millions 

New Owner 

Replacements 

Historical Shipments 

Modeled Shipments 

Figure 9.3.13 Compact Freezers: Historical and Base Case Shipments 

Forecast by Market Segment 

9-28 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

1990

1993

1996

1999

2002

2005

2008

2011

20142017

2020

2023

2026

2029

2032

2035

2038

2041

1.2

PC18 

PC17 

1.0 PC16 

Figure 9.3.14	 Compact Freezers: Base Case Shipments Forecast 

Disaggregated by Product Class 

9.4	 PURCHASE PRICE, OPERATING COST, AND HOUSEHOLD INCOME 

IMPACTS 

DOE conducted a literature review and an analysis of appliance price and efficiency data 

to estimate the combined effects on product shipments from increases in product purchase price, 

decreases in product operating costs, and changes to household income. Appendix 9-A provides 

a detailed explanation of the methodology DOE used to quantify the impacts from these 

variables. 

In the literature, DOE found only a few studies of appliance markets that are relevant to 

this rulemaking analysis. DOE identified no studies that use time-series data of product price and 

shipments data after 1980. The information that can be summarized from the literature suggests 

that the demand for appliances is price-inelastic. Other information in the literature suggests that 

appliances are a normal good, such that rising incomes increase the demand for appliances. 

Finally, the literature suggests that consumers use relatively high implicit discount ratesb

 when 

comparing appliance prices and appliance operating costs. 

b

 A high implicit discount rate with regard to operating costs means that consumers do not put much economic value 

on the operating cost savings realized from more-efficient appliances. In other words, consumers are much more 

concerned with higher purchase prices. 

0.0

0.2

0.4

0.6

0.8

Millions 

Historical Shipments 

Total Shipments 

9-29 

EERE-2008-BT-STD-0012 COMMENT 22
DOE found insufficient data on product purchase price and operating cost to perform a 

thorough analysis of dynamic changes in the appliance market. Rather, it used purchase price and 

efficiency data specific to residential refrigerators, clothes washers, and dishwashers over the 

period 1980–2002 to evaluate broad market trends and conduct simple regression analyses. 

These data indicate that there has been a rise in appliance shipments and a decline in appliance 

purchase price and operating costs over the time period. Household income has also risen during 

this time. To simplify the analysis, DOE combined the available economic information into one 

variable, termed the relative price, and used this variable in an analysis of market trends, as well 

as to conduct a regression analysis. The relative price is defined with the following expression: 

TP PP + PVOC

RP = = 

Income Income 

Where: 

RP = relative price, 

TP = total price, 

Income = household income, 

PP = appliance purchase price, and 

PVOC = present value of operating cost. 

In this equation, DOE used an implicit discount rate of 37 percent to determine the 

present value of operating costs. 

DOE’s analysis of market trends suggests that the relative price elasticity of demand for 

the three appliances is relatively inelastic (i.e., under 1.0). DOE’s regression analysis suggests 

that the relative price elasticity of demand, averaged over the three appliances, is -0.34. For 

example, a relative price increase of 10 percent results in a 3.4 percent decrease in shipments. 

Note that, because the relative price elasticity incorporates the impacts from three effects (i.e., 

purchase price, operating cost, and household income), the impact from any single effect is 

mitigated by changes from the other two effects. The relative price elasticity of -0.34 is 

consistent with estimates in the literature. Nevertheless, DOE stresses that the measure is based 

on a small data set, using simple statistical analysis. More importantly, the measure is based on 

an assumption that economic variables, including purchase price, operating costs, and household 

income, explain most of the trend in appliances per household in the United States since 1980. 

Changes in appliance quality and consumer preferences may have occurred during this period, 

but DOE did not account for them in this analysis. Despite these uncertainties, DOE believes that 

its estimate of the relative price elasticity of demand provides a reasonable assessment of the 

impact that purchase price, operating cost, and household income have on product shipments. 

Because DOE’s forecasts of shipments and national impacts due to standards is over a 

30-year time period, it needed to consider how the relative price elasticity is affected once a new 

standard takes effect. DOE considered the relative price elasticity provided by the preceeding 

9-30 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

analysis to be a short-run value. It was unable to identify sources specific to household durable 

goods, such as appliances, to indicate how short-run and long-run price elasticities differ. 

Therefore, to estimate how the relative price elasticity changes over time, DOE relied on a study 

pertaining to automobiles.15 This study shows that the automobile price elasticity of demand 

changes in the years following a purchase price change. With increasing years after the purchase 

price change, the price elasticity becomes smaller (more inelastic) until it reaches a terminal 

value around the tenth year after the price change. Table 9.4.1 shows the relative change in the 

price elasticity of demand for automobiles over time. DOE developed a time series of relative 

price elasticities for home appliances based on the relative change in the automobile price 

elasticity of demand. For years not shown in Table 9.4.1, DOE performed a linear interpolation 

to obtain the relative price elasticity. 

Table 9.4.1 Change in Relative Price Elasticity following a Purchase Price Change 

Years Following Price Change 

1 2 3 5 10 20 

Relative Change in 

Elasticity to 1st year 

1.00 0.78 0.63 0.46 0.35 0.33 

Relative Price Elasticity -0.34 -0.26 -0.21 -0.16 -0.12 -0.11 

Based on the following equation, DOE estimated standards case shipments by 

incorporating the impact of the relative price into the base case shipments forecast. Note that in 

this equation, the relative price and the relative price elasticity are functions of the year because 

both change with time. 

_ Ship ( j ) = (Rpl ( j ) + NI ( j ) + M ( j ))× (1 e ( j )× ΔRP( j )) STD _ p BASE _ p BASE _ p BASE _ p RP 

Where: 

ShipSTD_p(j) = total shipments under the standards case of product p in year j, 

RplBASE_p(j) = units of product p under the base case retired and replaced in year j, 

NIBASE_p(j) = number of new construction installations under the base case of product p in year 

j, 

MBASE_p(j) = units installed in market M under the base case of product p in year j (M 

represents purchases for existing homes for standard-size freezers, and purchase 

of an additional refrigerator for standard-size refrigerators), 

eRP(j)= relative price elasticity in year j (equals -0.34 for year 1), and 

ΔRP(j)= change in relative price due to a standard level in year j. 

9.5 AFFECTED STOCK 

In addition to the forecast of product shipments under both the base case and the 

standards case, the affected stock is a key output of DOE’s shipments models. The affected stock 

9-31 

EERE-2008-BT-STD-0012 COMMENT 22
(stock that is affected by a standards level) consists of those in-service units that are purchased in 

or after the year the standard has taken effect, as described by the following equation: 

_ j Std _ yr 

Aff Stock ( j ) = Ship ( j ) + ∑Stock ( age ) p p p 

age=1 

Where: 

Aff Stockp(j) = affected stock of units of product p of all vintages that are in service in year j, 

Shipp(j) = shipments of product p in year j, 

Stockp(j) = stock of units of product p of all vintages that are in service in year j, 

age = age of the units (years), and 

Std_yr = effective date of the standard. 

For the NES and NPV results presented in Chapter 10, DOE assumed that new energy 

efficiency standards will become effective in the year 2014. Thus, all appliances purchased 

starting on the first day of the year 2014 are affected by the standard level. 

9.6 RESULTS 

This section presents the shipments forecasts for the various standard levels that DOE 

considered for each of the four refrigeration product types. 

Figure 9.6.1 shows the standard-size refrigerator-freezer shipment forecasts for the base 

case and for two standard levels for which an impact is evident. The differences between the 

base case and standard level shipments forecasts represent the annual shipments reductions 

attributable to the standard levels. 

9-32 

EERE-2008-BT-STD-0012 COMMENT 22
25.0 

5.0 

10.0 

15.0 

20.0 

Millions 

Base 

CSL6 

CSL8 

0.0 

1990 2000 2010 2020 2030 2040 

Figure 9.6.1 Standard-Size Refrigerator-Freezers: Base Case and Standards Case 

Shipments Forecasts 

Figure 9.6.2 shows the standard-size freezer shipment forecasts for the base case and for 

several standard levels for which an impact is evident. The differences between the base case and 

standard level shipments forecasts represent the annual shipments reductions attributable to the 

standard levels. 

9-33 

EERE-2008-BT-STD-0012 COMMENT 22
1990

1995

2000

2005

2010

2015

2020

2025

2030

2035

2040

4.5

4.0

3.5

3.0

2.5

ons 

2.0

Milli

1.5 CSL5 

1.0

CSL7 

CSL8 

0.5 Base 

0.0

Figure 9.6.2 Standard-size Freezers: Base Case and Standards Case Shipments 

Forecasts 

Figure 9.6.3 shows the compact refrigerator shipment forecasts for the base case and for 

those standard levels for which an impact is evident. The differences between the base case and 

standard level shipments forecasts represent the annual shipments reductions attributable to the 

standard levels. 

9-34 

EERE-2008-BT-STD-0012 COMMENT 22
1990

1993

1996

1999

2002

2005

2008

2011

2014

2017

2020

2023

2026

2029

2032

2035

2038

2041 

0.0 

1.0 

2.0 

3.0 

4.0 

5.0 

6.0 

7.0 

Miliions 

CSL6 

CSL7 

CSL8 

Base 

Figure 9.6.3 Compact Refrigerators: Base Case and Standards Case Shipments 

Forecasts 

Figure 9.6.4 shows the compact freezer shipment forecasts for the base case and for 

selected standard levels for which an impact is evident. The differences between the base case 

and standard level shipments forecasts represent the annual shipments reductions attributable to 

the standard levels. 

9-35 

EERE-2008-BT-STD-0012 COMMENT 22
1990 

1993 

1996 

1999 

2002 

2005 

2008 

2011 

2014 

2017 

2020 

2023 

2026 

2029 

2032 

2035 

2038 

2041 

0. 

0. 

0. 

0. 

0. 

0. 

0. 

0. 

0. 

0. 

90
 

80
 

70
 

60
 

50
 

40
 

30
 

20
 

10
 

00
 

Base 

CS L3 

CS L5 

CS L8 

Millions 

Figure 9.6.4 Compact Freezers: Base Case and Standards Case Shipments Forecasts 

9-36
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

 

 

REFERENCES 

1	 U.S. Department of Energy-Energy Information Administration. An Updated Annual Energy 

Outlook 2009 Reference Case Reflecting Provisions of the American Recovery and 

Reinvestment Act and Recent Changes in the Economic Outlook, April, 2009. Washington, 

DC. SR/OIAF/2009-03. 

<http://www.eia.doe.gov/oiaf/servicerpt/stimulus/pdf/sroiaf(2009)03.pdf> 

2	 Statistical Review. Appliance Magazine, April, 1993. 

3	 Statistical Review. Appliance Magazine, April, 1990. 

4	 Statistical Review. Appliance Magazine, April, 1982. 

5	 Association of Home Appliance Manufacturers. AHAM 2005 Fact Book, 2005. Washington, 

DC. 

6	 Association of Home Appliance Manufacturers. AHAM 2003 Fact Book, 2003. Washington, 

DC. 

7	 Association of Home Appliance Manufacturers. Aggregated Refrigerator‐Freezer 

Shipments and Efficiency Data for DOE Refrigerator‐Freezer Energy Efficiency Standards 

Rulemaking, January 16, 2009. Memo to Detlef Westphalen, Navigant Consulting, Inc. 

8	 U.S. Department of Energy–Energy Information Administration. Annual Energy Outlook 

2009 with Projections to 2030. March 2009. U.S. DOE–EIA: Washington, D.C. DOE/EIA0383(2009). <http://www.eia.doe.gov/oiaf/aeo/pdf/0383(2009).pdf> 

9	 U.S. Department of Energy–Energy Information Administration. Residential Energy 

Consumption Survey. Washington, D.C. Surveys for 1990, 1993, 1997, 2001, and 2005. 

<www.eia.doe.gov/emeu/recs/contents.html> 

10	 Statistical Review. Appliance Magazine, April, 1997. 

11	 American Hotel & Lodging Association. 2008 Lodging Survey: Lodging Services, Facilities, 

and Trends, 2008. Washington, DC. p. 52, Percentage of Hotels with Refrigerators in 

Room. 

12	 U.S. Department of Energy–Energy Information Administration. Commercial Building 

Energy Consumption Survey. Washington, D.C. Surveys for 1999 and 2003. 

<http://www.eia.doe.gov/emeu/cbecs/> 

13	 California Energy Commission. Appliances Database—Refrigeration. 

<www.energy.ca.gov/appliances/database/excel_based_files/Refrigeration/> (Last accessed 

April 25, 2009.) 

9-37 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

14	 California Energy Commission. Appliances Database—Refrigeration. 

<www.energy.ca.gov/appliances/database/excel_based_files/Refrigeration/> (Last accessed 

April 25, 2009.) 

15	 S. Hymans. Consumer Durable Spending: Explanation and Prediction, Brookings Papers on 

Economic Activity, 1971. Vol. 1971, No. 1, pp. 234-239. 

9-38 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 9-A. RELATIVE PRICE ELASTICITY OF DEMAND FOR 

APPLIANCES 

TABLE OF CONTENTS 

9-A.1 INTRODUCTION .................................................................................................9-A-1 

9-A.2 LITERATURE REVIEW ......................................................................................9-A-1 

9-A.2.1 Price .......................................................................................................................9-A-1 

9-A.2.2 Income....................................................................................................................9-A-1 

9-A.2.3 Appliance Efficiency and Discount Rates .............................................................9-A-2 

9-A.3 VARIABLES DESCRIBING THE MARKET FOR REFRIGERATORS, 

CLOTHES WASHERS, AND DISHWASHERS .................................................9-A-2 

9-A.3.4 Physical Household/Appliance Variables..............................................................9-A-3 

9-A.3.5 Economic variables................................................................................................9-A-3 

9-A.4 REGRESSION ANALYSIS OF VARIABLES AFFECTING APPLIANCE 

SHIPMENTS .........................................................................................................9-A-4 

9-A.4.1 Broad Trends..........................................................................................................9-A-5 

9-A.4.2 Model Specification...............................................................................................9-A-7
 

9-A.4.3 Model Discussion...................................................................................................9-A-8 

9-A.4.4 Analysis Results.....................................................................................................9-A-8 

9A.4.4.1 Individual Appliance Model ................................................................9-A-8 

9A.4.4.2 Combined Appliance Model................................................................9-A-9 

9-A.4.5 Additional Regression Specifications and Results ..............................................9-A-10 

9A.4.5.1 Lower Consumer Discount Rate........................................................9-A-10 

9A.4.5.2 Disaggregated Variables ....................................................................9-A-10 

9-A.5 LONG RUN IMPACTS.......................................................................................9-A-11 

9-A.6 SUMMARY.........................................................................................................9-A-12 

9-A.7 DATA USED IN THE ANALYSIS ....................................................................9-A-13 

LIST OF TABLES 

Table 9-A.2.1 Estimates of the Impact of Price, Income and Efficiency on 

Automobile and Appliance Sales...............................................................9-A-2 

Table 9-A.3.1 Physical Household/Appliance Variables..................................................9-A-3 

Table 9-A.3.2 Economic Variables...................................................................................9-A-4 

Table 9-A.4.1 Simple Estimate of Total Price Elasticity of Demand ...............................9-A-6 

Table 9-A.4.2 Tabular Estimate of Relative Price Elasticity of Appliance Demand........9-A-7 

Table 9-A.4.3 Individual Appliance Model Results .........................................................9-A-9 

Table 9-A.4.4 Combined Appliance Model Result...........................................................9-A-9 

Table 9-A.4.5 Combined and Individual Results, 20 percent discount rate....................9-A-10 

Table 9-A.4.6 Disaggregated Regression Results, 37 percent discount rate...................9-A-11 

Table 9-A.5.1 Change in Price Elasticity of Demand for Automobiles following a 

Purchase Price Change.............................................................................9-A-12 

9A-i 

EERE-2008-BT-STD-0012 COMMENT 22
Table 9-A.5.2 Change in Relative Price Elasticity for Home Appliances following a 

Purchase Price Change.............................................................................9-A-12 

LIST OF FIGURE 

Figure 9-A.3.1 Trends in Appliance Shipment, Housing Starts and Replacements...........9-A-4 

Figure 9-A.4.1 Residual Shipments and Appliance Price ..................................................9-A-6 

9A-ii 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 9-A. RELATIVE PRICE ELASTICITY OF DEMAND FOR APPLIANCES 

9-A.1 INTRODUCTION 

This appendix summarizes DOE’s study of the price elasticity of demand for home 

appliances, including refrigerators, clothes washers and dishwashers. DOE chose this particular 

set of appliances because of the availability of data to determine a price elasticity. This appendix 

begins with a review of the existing economics literature describing the impact of economic 

variables on the sale of durable goods in section 9A.2. In section 9A.3, the market for home 

appliances and changes in it over the past 20 years is described. In section 9A.4, DOE 

summarizes the results of its regression analysis and presents estimates of the price elasticity of 

demand for the three appliances. In section 9A.5, DOE presents development of an ‘effective’ 

purchase price elasticity. DOE’s interpretation of its results is presented in section 9A.6. 

Finally, section 9A.7 describes the data used in DOE’s analysis. 

9-A.2 LITERATURE REVIEW 

There are relatively few studies measuring the impact of price, income and efficiency on 

the sale of household appliances. In this section DOE provides a short review of this literature 

which suggests the likely importance of these variables. 

9-A.2.1 Price 

The goal of many of the studies covered in this review is to measure the impact of price 

on sales in a dynamic market. One study of the automobile market prior to 1970 finds the price 

elasticity of demand to decline over time. The author explains this as the result of buyers 

delaying purchases after a price increase but eventually making the purchase (Table 9A.2.1).1 A 

contrasting study of household white goods also prior to 1970, finds the elasticity of demand to 

increase over time as more price-conscious buyers enter the market.2

 A recent analysis of 

refrigerator market survey data finds that consumer purchase probability decreases with survey 

asking price.3

 Estimates of the price elasticity of demand for different brands of the same 

product tend to vary. A review of 41 studies of the impact of price on market share found the 

average price elasticity to be -1.75.4

 The average estimate of price elasticity of demand reported 

in these studies is -0.33 in the appliance market and -0.47 in the combined automobile and 

appliance markets. 

9-A.2.2 Income 

Higher income households are more likely to own household appliances.5

 The impact of 

income on appliance shipments is explored in two econometric studies of the automobile and 

appliance markets. 1,2 The average income elasticity of demand is 0.50 in the appliance study 

cited in the literature review, much larger in the automobile study (Table 9.A.2.1). 

9-A-1
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

9-A.2.3	 Appliance Efficiency and Discount Rates 

Many studies estimate the impact of appliance efficiency on consumer appliance choice. 

Typically, this impact is summarized by the implicit discount rate, i.e., the rate consumers use to 

compare future appliance operating cost savings against an appliance purchase price premium. 

One early and much cited study concludes that consumers use a 20 percent implicit discount rate 

when purchasing room air conditioners (Table 9A.2.1).6 A survey of several studies of different 

appliances suggests that the consumer implicit discount rate has a broad range and averages 

about 37 percent.7 

Table 9-A.2.1	 Estimates of the Impact of Price, Income and Efficiency on Automobile 

and Appliance Sales 

Durable Good 

Price 

Elasticity 

Income 

Elasticity 

Brand 

Price 

Elasticity 

Implicit 

Discount 

Rate Model 

Data 

Years 

Time 

Period 

Automobiles1

 -1.07 3.08 - - Linear Regression, stock 

adjustment - Short run 

Automobiles1

 -0.36 1.02 - - Linear Regression, stock 

adjustment - Long run 

Clothes Dryers2

 -0.14 0.26 - - Cobb-Douglas, diffusion 1947-1961 Mixed 

Room Air 

Conditioners2 -0.378

 0.45 - - Cobb-Douglas, diffusion 1946-1962 Mixed 

Dishwashers2

 -0.42 0.79 - - Cobb-Douglas, diffusion 1947-1968 Mixed 

Refrigerators3

 -0.37 - - 39% Logit probability, survey 

data 1997 Short run 

Various4

 - - -1.769 - Multiplicative regression - Mixed 

Room Air 

Conditioners5 - - -1.72 - Non-linear diffusion 1949-1961 Short run 

Clothes Dryers5 - - -1.32 - Non-linear diffusion 1963-1970 Short run 

Room Air 

Conditioners6 - - - 20% Qualitative choice, survey 

data - -

Household 

Appliances7 - - - 37%10 Assorted - -

Sources: 1

 S. Hymens. 1971; 2 P. Golder and G. Tellis, 1998; 3 D. Revelt and K. Train, 1997; 4

 G. Tellis, 1988; 5 D. Jain and R. Rao; 6 J. Hausman; 7 K. Train, 1985. 

Notes:	 8

 Logit probability results are not directly comparable to other elasticity estimates in this table. 9

 Average brand price elasticity across 41 studies. 

10 Averaged across several household appliance studies referenced in this work. 

9-A.3 VARIABLES DESCRIBING THE MARKET FOR REFRIGERATORS, 

CLOTHES WASHERS, AND DISHWASHERS 

In this section DOE evaluates variables that appear to account for refrigerator, clothes 

washer and dishwasher shipments, including physical household/appliance variables, and 

economic variables. 

9-A-2
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

9-A.3.4 Physical Household/Appliance Variables 

Several variables influence the sale of refrigerators, clothes washers and dishwashers. 

The most important for explaining appliance sales trends are the annual number of new 

households formed (housing starts) and the number of appliances reaching the end of their 

operating life (replacements). Housing starts influence sales because new homes are often 

provided with, or soon receive, new appliances, including dishwashers and refrigerators. 

Replacements are correlated with sales because new appliances are typically purchased when old 

ones wear out. In principle, if households maintain a fixed number of appliances, shipments 

should equal housing starts plus appliance replacements. 

9-A.3.5 Economic variables 

Appliance price, appliance operating cost and household income are important economic 

variables affecting shipments. Low prices and costs encourage household appliance purchases 

and a rise in income increases householder ability to purchase appliances. In principle, changes 

in economic variables should explain changes in the number of appliances per household. 

During the 1980–2002 study period, annual shipments grew 69 percent for clothes 

washers, 81 percent for refrigerators and 105 percent for dishwashers (Table 9A.3.1). This rising 

shipments trend is explained in part by housing starts, which increased 6 percent and by 

appliance replacements, which rose between 49 percent and 90 percent, depending on the 

appliance, over the period (Table 9A.3.1).a

 For mature markets such as these, replacements 

exceed appliance sales associated with new housing construction. 

Table 9-A.3.1 Physical Household/Appliance Variables 

 Shipments1 (millions) Housing Starts2 (millions) Replacements3 (millions) 

Appliance 1980 2002 Change 1980 2002 Change 1980 2002 Change 

Refrigerators 5.124 9.264 81% 1.723 1.822 6% 3.93 5.84 49% 

Clothes Washers 4.426 7.492 69% 1.723 1.822 6% 3.66 5.50 50% 

Dishwashers 2.738 5.605 105% 1.723 1.822 6% 1.99 3.79 90% 1

Shipments: Number of units sold. Sources: AHAM Fact Book and Appliance Magazine. 2

Housing Starts: Annual number of new homes constructed. Source: U.S. Census. 3

Replacements: Average of annual lagged shipments, with lag equal to expected appliance operating life, ± 5 years.
 

Nevertheless, it is apparent that appliance shipments increased somewhat more rapidly 

than housing starts and replacements. This is shown by comparing the beginning and end points 

of lines representing “starts plus replacements” (uppermost solid line in Figure 9A.3.1) and 

“shipments” (diamond linked line in Figure 9A.3.1). In 1980 the “shipment” line begins below 

the “starts plus replacements” line. In 2002, the “shipments” line ends above the “starts plus 

replacements” line. This more rapid increase in shipments, compared to housing starts plus 

replacements, suggests that the appliance per household ratio increased over the study period. 

a

 Appliance replacements are determined from the expected operating life of refrigerators (19 years), clothes 

washers (14 years), and dishwashers (12 years) and from past shipments. Replacements are further discussed in 

section 9A.3. 

9-A-3
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

Refrigerator Shipments 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

1980 1984 1988 1992 1996 2000 

Millions 

New Housing 

Retirements 

Shipments 

Clothes Washer Shipments 

0 

1 

2 

3 

4 

5 

6 

7 

8 

1980 1984 1988 1992 1996 2000 

Millions 

Dishwasher Shipments 

0 

1 

2 

3 

4 

5 

6 

1980 1984 1988 1992 1996 2000 

Millions 

Figure 9-A.3.1	 Trends in Appliance Shipment, Housing Starts and 

Replacements 

Economic variables, including price, cost and income, may explain this increase in 

appliances per household. Over the period, appliance prices decreased 40 percent to 50 percent, 

operating costs fell between 33 percent and 72 percent, and median household income rose 16 

percent (Table 9A.3.2). 

Table 9-A.3.2 Economic Variables 

Price1 (1999$) Operating Cost2 (1999$) Household Income3 (1999$) 

Appliance 1980 2002 Change 1980 2002 Change 1980 2002 Change 

Refrigerators 1208 726 -40% 333 94 -72% 37,447 43,381 16% 

Clothes Washers 779 392 -50% 262 175 -33% 37,447 43,381 16% 

Dishwashers 713 369 -48% 183 95 -48% 37,447 43,381 16% 1

Price: Shipment weighted retail sales price. Sources: AHAM Fact Book and Appliance Magazine. 2

Operating Cost: Annual electricity price times electricity consumption. Source: AHAM Fact Book. 3

Income: Mean Household income. Source: U.S. Census. 

9-A.4 REGRESSION ANALYSIS OF VARIABLES AFFECTING APPLIANCE 

SHIPMENTS 

Little data is available for estimating the impact of economic variables on the demand for 

appliances. Industry operating cost data is incomplete—appliance energy use data is available 

for only 12 years of the 1980-2002 study period. Industry price data is also incomplete— 

available for only 8 years of the study period for each of the appliances. 

The lack of data suggests that regression analysis can at best evaluate broad data trends, 

utilizing relatively few explanatory variables. This section begins by describing broad trends 

apparent in the economic and physical household data sets and then specifies a simple regression 

model to measure these trends, making assumptions to minimize the number of explanatory 

9-A-4
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

variables. Finally, results are presented of the regression analysis and the estimate of the price 

elasticity of demand for appliances. In this section (specifically section 9A.4.5), DOE also 

presents the results of regression analysis performed with more complex models, and used to test 

assumptions made to specify the simple model. These results support the simple model 

specification, and estimates of the price elasticity of appliance demand measured with that 

model. 

9-A.4.1 Broad Trends 

In this section DOE reviews trends in the physical household and economic data sets and 

posit a simple approach for estimating the price elasticity of appliance demand. As noted above, 

the physical household variables (starts and appliance replacements), explain most of the 

variability in appliance shipments over the period.b DOE assumes the rest of the variability in 

shipments (referred to as “residual shipments”) is explained by economic variables, and present a 

tabular method for measuring price elasticities described below. 

To illustrate this tabular approach, DOE defines two new variables—residual shipments 

and total price. Residual shipments are defined as the difference between shipments and 

physical household demand (starts plus replacements). Total price, represented by the following 

equation, is defined as appliance price plus the present value of lifetime appliance operating 

cost:c 

TP = PP + PVOC

where: 

TP = Total price, 

PP = Appliance purchase price, and 

PVOC = Present value of operating cost. 

Over the study period, residual shipments increase 30 percent for refrigerators, 19 percent for 

clothes washers, and 23 percent for dishwashers in proportion to total shipments. At the same 

time, total prices decline 47 percent, 45 percent and 48 percent for refrigerators, clothes washers, 

and dishwashers, respectively. Assuming that total price explains the entire change in per 

household appliance usage, a rough estimate is calculated of the total price elasticity of demand 

equal to -0.48 for refrigerators, -0.32 for clothes washers and -0.37 for dishwashers (Table 

9A.4.1). 

b

 A log regression of the form: Shipments = a + b • Housing Starts + c • Retirements, indicates that these two 

variables explain 89 percent of the variation in refrigerator shipments, 97 percent of the variation in clothes washer 

shipments, and 97 percent of the variation in dishwasher shipments. 

c

 Present value operating cost is calculated assuming a 19 year operating life for refrigerators, 14 year operating life 

for clothes washers, and a 12 year operating life for dishwashers. A 37 percent discount rate is used to sum annual 

operating costs into a present value operating cost. 

9-A-5
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

Table 9-A.4.1 Simple Estimate of Total Price Elasticity of Demand 

Residual Shipments (millions) Total Price (199$) 

Appliance 1980 2002 Difference Change 1980 2002 Change Elasticity

Refrigerators -0.5 1.6 2.1 30% 1541 820 -61% -0.48 

Clothes Washers -1.0 0.2 1.1 19% 1042 567 -59% -0.32 

Dishwashers -1.0 -0.01 1.0 23% 896 464 -64% -0.37 

The negative correlation between total price and residual shipments suggested by these 

negative price elasticities is illustrated in a graph of residual shipments on the y-axis and total 

price on the x-axis (Figure 9A.4.1). 

2000 

Refrigerators 

1200 

Clothes Washers 

1000 

Dishwashers 

1600 

ents 

1000 

ments 

800 

ments 

Shipm 1200 

Shipual 

800 

Shipual 

600 

800 

Residual 

Resid

600 

Resid

400 

400 400 200 

-2.0 -1.0 0.0 1.0 2.0 -1.5 -1.0 -0.5 0.0 0.5 -2.0 -1.5 -1.0 -0.5 0.0 0.5 

Total Price Total Price Total Price 

Yellow points are observed price data; red points are interpolated price data. 

Figure 9-A.4.1 Residual Shipments and Appliance Price 

Household income rose during the study period, making it easier for households to 

purchase appliances. Assuming that a rise in income has a similar impact on shipments as a 

decline in price, the impact of income is incorporated by defining a third variable, termed 

relative price, calculated as total price divided by household income and represented by the 

following equation:d 

RP = 

Income

TP

where: 

RP = Relative price, 

TP = Total price, and 

Income = Household income. 

d

 Recall that the income elasticity of demand cited in the literature review is 0.50 and the price elasticity of demand 

cited in the review averages -0.35. This suggests that combining the effects of income and price will yield an 

elasticity less negative than price elasticity alone. 

9-A-6
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

The percent decline in relative price for the three appliances divided by the percent decline in 

residual shipments suggests a rough estimate of relative price elasticity equal to -0.40 for 

refrigerators, -0.26 for clothes washers and -0.30 for dishwashers (Table 9A.4.2). 

Table 9-A.4.2 Tabular Estimate of Relative Price Elasticity of Appliance Demand 

Residual Shipments (millions) Relative Price (1999$) 

Appliance 1980 2002 Change 1980 2002 Change Elasticity

Refrigerators -0.532 1.597 30% 0.041 0.019 -74% -0.40 

Clothes Washers -0.953 0.174 19% 0.028 0.013 -72% -0.26 

Dishwashers -0.974 -0.005 23% 0.024 0.011 -76% -0.30 

9-A.4.2 Model Specification 

The limited price data suggests using a simple regression model to estimate the impact of 

economic variables on shipments, using few explanatory variables. The following equation 

chosen for this analysis includes one physical household variable (starts plus replacements) and 

one relative price variable (the sum of purchase price plus operating cost, divided by income). 

Ship = a + b× RP + c ×[Starts + Rplc] Eq. 9A.1 

where: 

Ship = Quantity of appliance sold, 

RP = Relative price, 

Starts = Number of new homes, and 

Rplc = Number of appliances at the end of their operating life. 

The natural logs are taken of all variables so that the estimated coefficients for each 

variable in the model may be interpreted as the percent change in shipments associated with the 

percent change in the variable. Thus, the coefficient b in this model is interpreted as the relative 

price elasticity of demand for the three appliances. 

The following combined regression equation is used to estimate an average price 

elasticity of demand across the three appliances, using pooled data in a single regression. A 

combined regression specification is justified, given limited data availability and similarity in 

price and shipment behavior across appliances (see Figure 9A.4.1). Thus, the model represented 

by the combined regression equation is considered the basic model in DOE’s analysis of 

appliance shipments. 

Ship = a + b× RP + c ×[Starts + Rplc]+ d × CW + e × DW Eq. 9A.2 

where: 

CW = Quantity of clothes washers sold, and 

DW = Quantify of dishwashers sold. 

9-A-7
 

EERE-2008-BT-STD-0012 COMMENT 22
 

9-A.4.3 Model Discussion 

The most important assumption used to specify this model is that changes in economic 

variables over the study period—income, price, and operating cost—are responsible for all 

observed growth in residual appliance shipments. In other words, DOE assumes other possible 

explanations, such as changing consumer preferences and increases in the quality of 

appliances—had no impact. This assumption seems unlikely but without additional data, the 

impact of this assumption on the price elasticity of demand cannot be measured. DOE effectively 

assumes that changes in consumer preferences and appliance characteristics, while affecting 

which specific models are purchased, have relatively little impact on the total number of 

appliances purchased in a year. 

Three additional assumptions used to specify this model deserve comment. The relative 

price variable is specified in the model, assuming that (1) the correct implicit discount rate is 

used to combine appliance price and operating cost and that (2) rising income has the same 

impact on shipments as falling total price. The “starts + replacements” variable is specified, 

assuming (3) that starts and replacements have similar impacts on shipments. 

To investigate the first assumption about discount rates, DOE calculated “present value 

operating cost” using a 20 percent implicit discount rate and performed a second regression 

analysis based on the models described in equations. 9A.1 and 9A.2. The results of this analysis, 

presented in section 9A.4.5, indicate that the elasticity of relative price is relatively insensitive to 

changes in the discount rate. 

To investigate the second and third assumptions, DOE specified a regression model 

separating income from total price and replacements from starts, thus adding two additional 

explanatory variables to the basic model as shown in the following equation: 

Ship = a + b×TP + c × Incone + d × Start + e × Rplc + f × CW + g × DW Eq. 9A.3 

The results of the regression analysis of this model are also presented in section 9A.4.5. 

These results suggest that the elasticity of total price (coefficient b) is relatively insensitive to 

changes in the treatment of income and “starts + replacements” in the model. 

9-A.4.4 Analysis Results 

9A.4.4.1 Individual Appliance Model 

The individual appliance regression equations are specified as followed (as shown earlier 

as Eq. 9A.1): 

Ship = a + b× RP + c ×[Starts + Rplc] 

In regression analysis of this model, the elasticity of relative price (b) is estimated to be 

9-A-8
 

EERE-2008-BT-STD-0012 COMMENT 22
-0.40 for refrigerators, -0.31 for clothes washers and -0.32 for dishwashers (Table 9A.4.3), 

averaging -0.35. These elasticities are similar to those reported in the literature survey for 

appliances (Table 9A.2.1). They are remarkably similar to the price elasticity calculated using a 

tabular approach presented above (Table 9A.4.2). 

The estimated coefficient associated with the “starts + replacements” variable is close to 

one. A coefficient equal to one for this variable would imply that shipments increase in direct 

proportion to an increase in “starts + replacements”, holding economic variables constant. The 

high R squared values (above 95) and t statistics (above 5) in the results provide a measure of 

confidence in this analysis, despite the very small data set. 

Table 9-A.4.3 Individual Appliance Model Results 

Refrigerator Clothes Washer Dishwasher 

Variable Coefficient t-stat Coefficient t-stat Coefficient t-stat 

Intercept -1.51 -7.26 -1.47 -8.23 -2.08 -16.78 

Relative Price -0.40 -6.60 -0.31 -5.69 -0.32 -7.03 

Starts + Replacements 1.05 5.90 1.08 6.41 1.35 11.46 

R2

 0.954 0.954 0.975 

Observations 23 23 23 

9A.4.4.2 Combined Appliance Model 

The combined appliance regression equation is specified as follows (as shown earlier as 

Eq. 9A.2): 

Ship = a + b× RP + c ×[Starts + Rplc]+ d × CW + e × DW

This regression analysis indicates that the model fits the existing shipments data well 

(high R squared) and that the variables included in the model are statistically significant (Table 

9A.4.4). The elasticity of relative price estimated with this model is -0.34, close to the average 

value estimated in the individual appliance models (-0.35). It is also similar to elasticity 

estimates reported in the literature survey and calculated using the tabular approach above. 

Table 9-A.4.4 Combined Appliance Model Result 

Variable Coefficient t-stat 

Intercept -1.60 -15.54 

Relative Price -0.34 -10.74 

Starts + Replacements 1.21 13.95 

CW -0.20 -9.04 

DW -0.32 -6.58 

R2

 0.983 

Observations 69 

9-A-9
 

EERE-2008-BT-STD-0012 COMMENT 22
9-A.4.5 Additional Regression Specifications and Results 

As described above in section 9A.4.3, DOE used three assumptions to specify its 

appliance models. The first is that the implicit price variable in the basic regression model is 

specified using a 37 percent implicit discount rate, to aggregate appliance price and operating 

cost. The second states that the implicit price variable is defined assuming that rising income has 

the same impact on shipments as falling total price. The third states that the “starts + 

replacements” variable is defined assuming that housing starts have a similar impact on 

shipments as appliance replacements. 

9A.4.5.1 Lower Consumer Discount Rate 

To investigate the first assumption about discount rates, DOE calculated “present value 

operating cost” using a 20 percent implicit discount rate and performed a second regression 

analysis based on the models described in equations 9A.1 and 9A.2. The estimated coefficient 

associated with the relative price variable in these regressions is almost identical to the 

coefficients estimated for same variable reported above using a 37 percent implicit discount rate. 

The elasticity of relative price calculated using a 20 percent discount rate is -0.33 in the 

combined regression and averages -0.35 for the three appliances (Table 9A.4.5). The elasticity 

of price calculated using a 37 percent discount rate is -0.34 in the combined regression and 

averages -0.35 for the three appliances. DOE concludes from this analysis that the elasticity of 

relative price is relatively insensitive to changes in the discount rate. 

Table 9-A.4.5 Combined and Individual Results, 20 percent discount rate 

Three Appliances 

Variable 

Intercept 

Total Price / Income 

Starts + Retirements 

CW 

DW 

Coefficient 

-1.53 

-0.33 

1.20 

-0.18 

-0.32 

t-Stat 

-14.61 

-10.69 

13.65 

-8.69 

-6.57 

R2 

Observations 

0.982 

69 

Variable 

Intercept 

Total Price / Income 

Starts + Retirements 

Refrigerator 

Coefficient 

-1.36 

-0.38 

1.04 

t-Stat 

-6.26 

-6.50 

5.73 

Clothes Washers 

Coefficient t-Stat 

-1.41 -7.49 

-0.32 -5.29 

1.06 5.83 

Dishwasher 

Coefficient 

-2.04 

-0.33 

1.34 

t-Stat 

-17.23 

-7.30 

11.64 

R2 

Observations 

0.953 

23 

0.950 

23 

0.977 

23 

9A.4.5.2 Disaggregated Variables 

To investigate the second and third assumptions, DOE constructed a regression model 

separating income from total price and replacements from starts, thus adding two additional 

explanatory variables to the basic model (as shown earlier as Eq. 9A.3). 

9-A-10 

EERE-2008-BT-STD-0012 COMMENT 22
Ship = a + b×TP + c × Incone + d × Start + e × Rplc + f × CW + g × DW

The estimated coefficient associated with the total price variable in these regressions is 

almost identical to the coefficients estimated for the relative price variable reported above. The 

elasticity of total price in the above equation is -0.36 in the combined appliance regression and 

averages -0.35 for the three appliances (Table 9A.4.6). The elasticity of relative price based on 

the model described in equation 9A.2 is -0.34 in the combined regression (Table 9A.4.4) and 

averages -0.35 across the individual appliances (Table 9A.4.3). DOE concludes that the price 

elasticity calculated in this analysis is relatively insensitive to the specification of household 

income and “starts + replacements” variables in the model. 

Table 9-A.4.6 Disaggregated Regression Results, 37 percent discount rate 

Three Appliances 

Variable Coefficient t-Stat 

Intercept -2.92 -1.26 

Income 0.58 2.92 

Total Price -0.36 -7.06 

Housing Starts 0.44 10.02 

Retirements 0.62 8.12 

CW -0.24 -9.25 

DW -0.46 -7.68 

R2 0.985 

Observations 69 

Refrigerator Clothes Washers Dishwasher 

Variable Coefficient t-Stat Coefficient t-Stat Coefficient t-Stat 

Intercept -6.19 -2.24 -6.64 -1.63 1.00 0.23 

Income 0.89 3.80 0.87 2.31 0.20 0.52 

Total Price -0.35 -5.48 -0.27 -2.51 -0.43 -5.18 

Housing Starts 0.41 7.38 0.25 3.29 0.62 8.24 

Retirements 0.56 6.06 0.56 2.09 0.65 5.86 

R2 0.984 0.958 0.979 

Observations 23 23 23 

9-A.5 LONG RUN IMPACTS 

As noted above in Table 9A.2.1 in section 9A.2, the literature review provides price 

elasticities over short and long time periods, also referred to as short run and long run price 

elasticities. As noted in the first two rows of Table 9A.2.1, one source (i.e., Hymans) shows that 

the price elasticity of demand is significantly different over the short run and long run for 

automobiles.1

 Because DOE’s forecasts of shipments and national impacts due to standards is 

over a 30-year time period, consideration must be given as to how the relative price elasticity is 

affected once a new standard takes effect. 

DOE considers the relative price elasticities determined above in section 9A.4 to be short 

run elastcities. DOE was unable to identify sources specific to household durable goods, such as 

appliances, to indicate how short run and long run price elasticities differ. Therefore, to estimate 

how the relative price elasticity changes over time, DOE relied on the Hymans study pertaining 

to automobiles. Based on the Hymans study, Table 9A.5.1 shows how the automobile price 

9-A-11
 

EERE-2008-BT-STD-0012 COMMENT 22
 

elasticity of demand changes in the years following a purchase price change. With increasing 

years after the price change, the price elasticity becomes more inelastic until it reaches a terminal 

value around the tenth year after the price change. 

Table 9-A.5.1 Change in Price Elasticity of Demand for Automobiles following a Purchase 

Price Change 

Years Following Price Change 

1 2 3 5 10 20 

Price Elasticity of Demand -1.20 -0.93 -0.75 -0.55 -0.42 -0.40 

Relative Change in 

Elasticity to 1st year 

1.00 0.78 0.63 0.46 0.35 0.33 

Source: Hymans, 1971. 

Based on the relative change in the automobile price elasticity of demand shown in Table 

9A.5.1, DOE developed a time series of relative price elasticities for home appliances. Table 

9A.5.2 presents the time series. 

Table 9-A.5.2 Change in Relative Price Elasticity for Home Appliances following a 

Purchase Price Change 

Years Following Price Change 

1 2 3 5 10 20 

Relative Change in 

Elasticity to 1st year 

1.00 0.78 0.63 0.46 0.35 0.33 

Relative Price Elasticity -0.34 -0.26 -0.21 -0.16 -0.12 -0.11 

9-A.6 SUMMARY 

This appendix describes the results of a literature search, tabular analysis and regression 

analysis of the impact of price and other variables on appliance shipments. In the literature, 

DOE finds only a few studies of appliance markets that are relevant to this analysis, and no 

studies using time series price and shipments data after 1980. The information that can be 

summarized from the literature, suggests that the demand for appliances is price inelastic. Other 

information in the literature suggests that appliances are a normal good, such that rising incomes 

increase the demand for appliances. Finally, the literature suggests that consumers use relatively 

high implicit discount rates, when comparing appliance prices and appliance operating costs. 

There is not enough price and operating cost data available to perform complex analysis 

of dynamic changes in the appliance market. In this analysis, DOE uses data available for 

refrigerators, clothes washers and dishwashers to evaluate broad market trends and to perform 

simple regression analysis. 

These data indicate that there has been a rise in appliance shipments and a decline in 

appliance price and operating cost over the period. Household income has also risen during this 

time. To simplify the analysis, DOE combined the available economic information into one 

9-A-12
 

EERE-2008-BT-STD-0012 COMMENT 22
variable, termed relative price, and used this variable in a tabular analysis of market trends, and a 

regression analysis. 

DOE’s tabular analysis of trends in the number of appliances per household suggests that 

the price elasticity of demand for the three appliances is inelastic. Our regression analysis of 

these same variables suggests that the relative price elasticity of demand is -0.34. The price 

elasticity is consistent with estimates in the literature. Nevertheless, DOE stresses that the 

measure is based on a small data set, using very simple statistical analysis. More important, the 

measure is based on an assumption that economic variables, including price, income and 

operating costs, explain most of the trend in appliances per household in the United States since 

1980. Changes in appliance quality and consumer preferences may have occurred during this 

period, but they are not accounted for in this analysis. 

9-A.7 DATA USED IN THE ANALYSIS 

•	 Appliance Shipments: Shipments are defined as the annual number of units shipped in 

millions. These data were collected from the Association of Home Appliance Manufacturers 

(AHAM)8

 and Appliance Magazine9 as annual values for each year, 1980–2002. AHAM 

was used for the period 1989–2002 while Appliance Magazine was used for the period 1980– 

1988. 

•	 Appliance Price: Price is defined as the shipments weighted retail sales price of the unit in 

1999 dollars. Price values for 1980, 1985, 1986, 1991, 1993, 1994, 1998, and 2002 were 

collected from AHAM Fact Books.10 Price values for other years were interpolated from 

these eight years of data. 

•	 Housing Starts: Housing starts data were collected from U.S. Census construction statistics 

(C25 reports) as annual values for each year, 1980–2002.11 

•	 Replacements: Retirement-driven replacements are estimated with the assumption that some 

fraction of sales arise from consumers replacing equipment at the end of its useful life. Since 

each appliance has a different expected lifespan (19 years for refrigerators12, 14 years for 

clothes washers13, 12 years for dishwashers14), replacements are calculated differently for 

each appliance type. Replacements are estimated as the average of shipments 14–24 years 

previous for refrigerators, 9–19 years previous for clothes washers, and 7–17 years previous 

for dishwashers. Historical shipments data were collected from AHAM and Appliance 

Magazine. 

•	 Annual Electricity Consumption: Electricity Use (UEC) is defined as the energy 

consumption of the unit in kilowatt-hours. Electricity consumption is dependent on appliance 

capacity and efficiency. These data were provided by AHAM for 1980, 1990–1997 and 

1999–2002.15 Data were interpolated in the years for which data were not available. 

9-A-13
 

EERE-2008-BT-STD-0012 COMMENT 22
• Operating Cost: Operating Cost is the present value of the electricity consumption of an 

appliance over its expected lifespan. The lifespans of refrigerators, clothes washers and 

dishwashers are assumed to be 19, 14, and 12 years respectively. Discount rates of 20 

percent6

 and 37 percent16 were used, producing similar estimates of price elasticity. A study 

by Hausman recommended a discount rate of “about 20 percent” in its introduction, and 

presented results ranging from 24.1 percent to 29 percent based on his calculations for room 

air conditioners. A study by Train suggests a range of implicit discount rates averaging 35 

percent for appliances. 

• Income: Median annual household income in 2003 dollars. This data was collected for each 

year, 1980–2002, from Table H-6 of the U.S. Census.17 

9-A-14
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

REFERENCES 

1	 S. Hymans. Consumer Durable Spending: Explanation and Prediction, Brookings Papers on 

Economic Activity, 1971. Vol. 1971, No. 1, pp. 234-239. 

2	 P. Golder and G. Tellis. Beyond Diffusion: An Affordability Model of the Growth of New 

Consumer Durables, Journal of Forecasting, 1998. 

3	 D. Revelt and K. Train. Mixed Logit with Repeated Choices: Household's Choice of 

Appliance Efficiency Level, Review of Economics and Statistics, 1997. 

4	 G. Tellis. The Price Elasticity of Selective Demand: A Meta-Analysis of Econometric 

Models of Sales, Journal of Marketing Research, 1988. 

5	 U.S. Department of Energy-Energy Information Agency. The Effect of Income on 

Appliances in U.S. Households, 2002. Washington, DC. 

<http://www.eia.doe.gov/emeu/recs/appliances/appliances.html> 

6	 J. Hausman. Individual discount rates and the purchase and utilization of energy using 

durables, The Bell Journal of Economics, 1979. 

7	 K. Train. Discount rates in consumer' energy related decisions: a review of the literature, 

Energy, 1985. 

8	 Association of Home Appliance Manufacturers. AHAM Fact Books, 2000 and 2003. 

Washington, DC. 

9	 Statistical Review. Appliance Magazine, April, 1990. 

10	 Association of Home Appliance Manufacturers. AHAM Fact Books, 1987, 1988, 1993, 1995, 

2000, and 2003. Washington, DC. 

11	 U.S. Census Bureau. Current Construction Reports, C25 – New One-Family Houses Sold. 

Washington, DC. <http://www.census.gov/prod/www/abs/c25.html> 

12	 Duemling, Reubin. Product Life of Refrigerators, 1999. University of California, Berkeley, 

Energy and Resources Group masters thesis. 

13	 U.S. Department of Energy-Office of Building Research and Standards. Final Rule Technical 

Support Document (TSD): Energy Efficiency Standards for Consumer Products: Clothes 

Washers, December, 2000. Washington, DC. Chapter 7. 

14	 U.S. Department of Energy-Office of Codes and Standards. Technical Support Document: 

Energy Conservation Standards for Consumer Products: Dishwashers, Clothes Washers, and 

Clothes Dryers, December, 1990. Washington, DC. DOE/CE-02999P. Chapter 4. 

9-A-15
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

15	 Association of Home Appliance Manufacturers. AHAM 2003 Fact Book, 2003. Washington, 

DC. 

16	 K.E. Train, and Atherton, T. Rebates, loans, and customers’ choice of appliance efficiency 

level: combining stated- and revealed-preference data, The Energy Journal, 1995. 

17	 U.S. Census Bureau. Income, Historical Income Tables – Households, Table H-6. 

Washington, DC. <http://www.census.gov/hhes/www/income/histinc/inchhtoc.html> 

9-A-16
 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 10: NATIONAL IMPACT ANALYSIS 

TABLE OF CONTENTS 

10.1 INTRODUCTION ......................................................................................................... 10-1 

10.2 FORECASTED EFFICIENCIES FOR BASE AND STANDARDS CASES .............. 10-2 

10.2.1 Method and Assumptions .............................................................................................. 10-2
 

10.2.2 Standard-Size Refrigerator-Freezers.............................................................................. 10-6 

10.2.3 Standard-Size Freezers................................................................................................. 10-10 

10.2.4 Compact Refrigerators and Freezers............................................................................ 10-11 

10.3 NATIONAL ENERGY SAVINGS ............................................................................. 10-13 

10.3.1 Definition ..................................................................................................................... 10-14 

10.3.2 Inputs............................................................................................................................ 10-15 

10.3.2.1 Shipments................................................................................................... 10-15 

10.3.2.2 Equipment Stock........................................................................................ 10-15 

10.3.2.3 Annual Energy Consumption per Unit ...................................................... 10-15 

10.3.2.4 National Annual Energy Consumption...................................................... 10-17 

10.3.2.5 Site-to-Source Conversion Factors ............................................................ 10-17 

10.4 NET PRESENT VALUE............................................................................................. 10-18 

10.4.1 Definition ..................................................................................................................... 10-18 

10.4.2 Inputs............................................................................................................................ 10-20 

10.4.2.1 Average Annual Product Cost ................................................................... 10-20 

10.4.2.2 Annual Operating Cost Savings per Unit................................................... 10-21 

10.4.2.3 Total Annual Increases in Product Cost.....................................................10-22 

10.4.2.4 Total Annual Savings in Operating Cost ................................................... 10-22 

10.4.2.5 Discount Factor.......................................................................................... 10-22 

10.4.2.6 Present Value of Costs...............................................................................10-23 

10.4.2.7 Present Value of Savings ...........................................................................10-23 

10.5 RESULTS OF NES AND NPV CALCULATIONS ................................................... 10-23 

10.5.1 Summary of Inputs....................................................................................................... 10-23 

10.5.2 Results of National Energy Savings Calculations ....................................................... 10-24 

10.5.2.1 Standard-Size Refrigerator-Freezers.......................................................... 10-24 

10.5.2.2 Standard-Size Freezers............................................................................... 10-25 

10.5.2.3 Compact Refrigerators and Freezers.......................................................... 10-26 

10.5.3 Annual Costs and Savings ........................................................................................... 10-27
 

10.5.4 Results of Net Present Value Calculations .................................................................. 10-28 

10.5.5 Summary of NIA Results............................................................................................. 10-30
 

LIST OF TABLES 

Table 10.2.1 Standard-Size Refrigerator-Freezers: Base-Case Efficiency Distributions ....... 10-4 

Table 10.2.2 Standard-Size Freezers: Base-Case Efficiency Distributions............................ 10-4 

10-i 

EERE-2008-BT-STD-0012 COMMENT 22
Table 10.2.3 Compact Refrigerators and Freezers: Base-Case Efficiency Distributions ....... 10-5 

Table 10.2.4 Top-Mount Refrigerator-Freezers: Efficiency Distributions in 2014 for 

Base and Standards Cases.................................................................................. 10-7 

Table 10.2.5 Top-Mount Refrigerator-Freezers: Efficiency Distributions in and After 

2021 for Base and Standards Cases ................................................................... 10-7 

Table 10.2.6 Bottom-Mount Refrigerator-Freezers: Efficiency Distributions in 2014 for 

Base and Standards Cases.................................................................................. 10-8 

Table 10.2.7 Bottom-Mount Refrigerator-Freezers: Efficiency Distributions in and 

After 2021 for Base and Standards Cases.......................................................... 10-8 

Table 10.2.8 Side-by-Side Refrigerator-Freezers: Efficiency Distributions in 2014 for 

Base and Standards Cases.................................................................................. 10-9 

Table 10.2.9 Side-by-Side Refrigerator-Freezers: Efficiency Distributions in and After 

2021 for Base and Standards Cases ................................................................... 10-9 

Table 10.2.10 Upright Freezers: Efficiency Distributions in 2014 for Base and Standards 

Cases ................................................................................................................ 10-10 

Table 10.2.11 Upright Freezers: Efficiency Distributions in and After 2021 for Base and 

Standards Cases ............................................................................................... 10-10 

Table 10.2.12 Chest Freezers: Efficiency Distributions in 2014 for Base and Standards 

Cases ................................................................................................................ 10-11 

Table 10.2.13 Chest Freezers: Efficiency Distributions in and After 2021 for Base and 

Standards Cases ............................................................................................... 10-11 

Table 10.2.14 Compact Refrigerators: Efficiency Distributions in 2014 for Base and 

Standards Cases ............................................................................................... 10-12 

Table 10.2.15 Compact Refrigerators: Efficiency Distributions in and After 2021 for 

Base and Standards Cases................................................................................ 10-12 

Table 10.2.16 Compact Freezers: Efficiency Distributions in 2014 for Base and 

Standards Cases ............................................................................................... 10-13 

Table 10.2.17 Compact Freezers: Efficiency Distributions in and After 2021 for Base 

and Standards Cases......................................................................................... 10-13 

Table 10.3.1 Standard-Size Refrigerator-Freezers: Shipment-Weighted Average Annual 

Energy Consumption in 2014 .......................................................................... 10-16 

Table 10.3.2 Standard-Size Freezers: Shipment-Weighted Average Annual Energy 

Consumption in 2014....................................................................................... 10-16 

Table 10.3.3 Compact Refrigerators and Freezers: Shipment-Weighted Average Annual 

Energy Consumption in 2014 .......................................................................... 10-16 

Table 10.4.1 Standard-Size Refrigerator-Freezers: Shipment-Weighted Average 

Product Cost in 2014 for Base and Standards Cases ....................................... 10-21 

Table 10.4.2 Standard-Size Freezers: Shipment-Weighted Average Product Cost in 

2014 for Base and Standards Cases ................................................................. 10-21 

Table 10.4.3 Compact Refrigerators and Freezers: Shipment-Weighted Average 

Product Cost in 2014 for Base and Standards Cases ....................................... 10-21 

Table 10.5.1 Inputs to Calculation of National Energy Savings and Net Present Value...... 10-24 

Table 10.5.2 Standard-Size Refrigerator-Freezers: Cumulative National Energy 

Savings, quads ................................................................................................. 10-25 

10-ii 

EERE-2008-BT-STD-0012 COMMENT 22
Table 10.5.3 Standard-Size Refrigerator-Freezers: Discounted Cumulative National 

Energy Savings, quads..................................................................................... 10-25 

Table 10.5.4 Standard-Size Freezers: Cumulative National Energy Savings, quads ........... 10-26 

Table 10.5.5 Standard-Size Freezers: Discounted Cumulative National Energy Savings, 

quads................................................................................................................ 10-26 

Table 10.5.6 Compact Refrigerators and Freezers: Cumulative National Energy 

Savings, quads ................................................................................................. 10-27 

Table 10.5.7 Compact Refrigerators and Freezers: Discounted Cumulative National 

Energy Savings, quads..................................................................................... 10-27 

Table 10.5.8 Standard-Size Refrigerator-Freezers: Discounted Cumulative Net Present 

Values .............................................................................................................. 10-29 

Table 10.5.9 Standard-Size Freezers: Discounted Cumulative Net Present Values............. 10-30 

Table 10.5.10 Compact Refrigerators and Freezers: Discounted Cumulative Net Present 

Values .............................................................................................................. 10-30 

Table 10.5.11 Standard-Size Refrigerator-Freezers: NES and NPV Results ......................... 10-31 

Table 10.5.12 Standard-Size Freezers: NES and NPV Results .............................................. 10-31 

Table 10.5.13 Compact Refrigerators and Freezers: NES and NPV Results ......................... 10-32 

LIST OF FIGURES 

Figure 10.2.1 Projected Shipment-Weighted Energy Use Factors as a Function of 

Standard Level for Product Class 7 ................................................................... 10-6 

Figure 10.3.1 Marginal Site-to-Source Conversion Factors for Electricity ........................... 10-18 

Figure 10.5.1 Non-Discounted Annual Increases in Installed Cost and Savings in 

Operating Cost for Product Class 3 at Standard Level 3 ................................. 10-28 

10-iii 

EERE-2008-BT-STD-0012 COMMENT 22
 

CHAPTER 10. NATIONAL IMPACT ANALYSIS 

10.1 INTRODUCTION 

This chapter describes the method the U.S. Department of Energy (DOE) used to 

estimate the national impacts of candidate standard levels for residential refrigeration products. 

DOE evaluated the following impacts: (1) national energy savings (NES) attributable to each 

possible standard, (2) monetary value of those energy savings to consumers of the considered 

products, (3) increased total installed cost of the products because of standards, and (4) net 

present value (NPV) of energy savings (the difference between the value of energy savings and 

increased total installed cost). 

DOE determined both the NES and NPV for all the efficiency levels considered for new 

standards for residential refrigeration products. DOE performed all calculations for each 

considered product using a Microsoft Excel spreadsheet model, which is accessible on the 

Internet. <www.eere.energy.gov/buildings/appliance_standards/> The spreadsheets, which 

implement the National Impact Analysis (NIA) model, combine the calculations for determining 

the NES and NPV for each considered product with input from the appropriate shipments model. 

Details and instructions for using the NIA model are provided in appendix 10-A. 

Chapter 9 provides a detailed description of the shipments models that DOE used to 

forecast future purchases of the considered products. Chapter 9 includes detailed descriptions of 

consumers’ sensitivities to total installed cost, operating cost, and income, and how DOE 

captured those sensitivities within the model. 

Throughout its analysis, DOE studied seven product classes in detail. For the National 

Impact Analysis, each of these classes represents a product category which also contains other 

product classes. DOE assigned each of the twenty product classes to one of these seven product 

categories. The following list indicates which product classes are associated with each product 

category: 

•	 Top-mount refrigerator-freezers: product classes 1, 1A, 2, 3, 3A, and 6; represented 

by product class 3. 

•	 Bottom-mount refrigerator-freezers: product classes 5 and 5A; represented by product 

class 5. 

•	 Side-by-side refrigerator-freezers: product classes 4 and 7; represented by product 

class 7. 

•	 Upright freezers: product class 9 only. 

•	 Chest freezers: product classes 8a, 10, and 10A; represented by product class 10. 

a

 Product class 8, “upright freezers with manual defrost” is analyzed as part of the “chest freezer” category because 

products in this class are much more technologically similar to chest freezers. 

10-1 

EERE-2008-BT-STD-0012 COMMENT 22
 

•	 Compact refrigerators: product classes 11, 11A, 12, 13, 13A, 14, and 15; represented 

by product class 11. 

•	 Compact freezers: product classes 16, 17, and 18; represented by product class 18. 

To estimate the national impacts of new standards for all the product classes considered 

in this rulemaking, DOE allocated the product cost and annual energy consumption of each 

representative product class to all product classes within its category. 

10.2 FORECASTED EFFICIENCIES FOR BASE AND STANDARDS CASES 

This section describes the method DOE used to forecast the energy efficiencies of 

considered products under the base case and each of the potential standards cases. It provides 

efficiency distributions for all product classes of standard-size refrigerator-freezers, standard-size 

freezers, and compact refrigerators and freezers. 

10.2.1 Method and Assumptions 

A key factor in estimating NES and NPV is the trend in energy efficiency forecasted for 

the base case (without new standards) and each of the standards cases. In calculating the NES, 

per-unit annual energy consumption is a direct function of product efficiency. For the NPV, two 

inputs, the per-unit total installed cost and the per-unit annual operating cost, depend on 

efficiency. The first input, the per-unit total installed cost, is a direct function of efficiency. The 

per-unit annual operating cost, because it is a function of the per-unit annual consumption, is 

indirectly dependent on product efficiency. 

For each product class considered for new standards, DOE determined the distribution of 

product efficiencies in the marketplace in 2007 based on data submitted by the Association of 

Home Appliance Manufacturers (AHAM).1

 Using the 2007 efficiency distribution as a starting 

point, DOE developed a base-case efficiency distribution based on certain assumptions regarding 

future trends. DOE assumed that increases in efficiency are driven largely by the ENERGY 

STAR program and the consumer incentives available for ENERGY STAR appliances. DOE 

evaluated the historical trends in energy use by refrigeration products, as reported in the AHAM 

Fact Book 20052

 (as well as data provided by AHAM for 2006 and 20071). Based on the AHAM 

information, DOE concluded that the roughly constant energy use per appliance observed 

between 2001 and 2007 reflected the growing market share for larger appliances and product 

classes that use more energy, such as side-mount refrigerator-freezers, balanced by an increasing 

market share for ENERGY STAR appliances. 

The requirements for meeting ENERGY STAR qualification were changed on April 1, 

2008, for standard-size refrigerator-freezers, but remained the same for standard-size freezers 

and compact products.3

 DOE assumed that the market for standard-size refrigerators will shift 

toward greater efficiency between 2007 and 2014 (the assumed effective date of a new standard) 

10-2 

EERE-2008-BT-STD-0012 COMMENT 22
in response to the change in ENERGY STAR requirements. In particular, DOE assumed (for all 

product classes) that the percentage of shipments that meet the new ENERGY STAR criteria will 

be the same in 2014 as it was in 2007. For standard-size freezers and all compact products, DOE 

assumed no change in the distribution of efficiencies before 2014. For standard-size refrigeratorfreezers, DOE assumed that the market share of products that qualified for the ENERGY STAR 

label in 2007 but could not meet the 2008 criteria, gradually will shift to meet the new criteria, 

resulting in the same market share for ENERGY STAR refrigeration products in 2014 as in 

2007. For product class 3, for example, the ENERGY STAR market share in 2007 was 13.4 

percent. The assumed market share in 2014 (under the new criteria) also is 13.4 percent (see 

Table 10.2.1). 

Base case. For the base-case scenario, DOE assumed that the ENERGY STAR 

requirements for all product classes will become more stringent in 2014 than in 2008, if there 

were no revised standards. This assumption reflects the view that, in the absence of DOE 

standards, the ENERGY STAR program (and or other federal or State programs) would feel 

compelled to increase promotion of higher-efficiency refrigeration products. DOE assumed that 

energy use by ENERGY STAR products would be required to be 25 percent, rather than 20 

percent, lower than the standard for standard-size refrigerator-freezers and compact products, 

and 15 percent, rather than 10 percent lower for standard-size freezers. DOE then assumed that 

the ENERGY STAR market shares in 2021, under the new qualification criteria, would equal the 

ENERGY STAR market shares in 2007. Finally, DOE assumed that the efficiency distributions 

would be fixed from 2021 until the end of the forecast period (30 years after the assumed 

effective date of 2014). 

Table 10.2.1 shows the market shares of product efficiencies that DOE projected for 

standard-size refrigerator-freezers in 2007, 2014, and 2021. The table also lists the shipmentweighted energy use factor (SWEUF) for each product class for those years. The distributions for 

product classes of freezers and compact models are not projected to change between 2007 and 

2014, but are projected to change between 2014 and 2021 in response to assumed ENERGY 

STAR requirements (Tables 10.2.2 and 10.2.3). 

10-3 

EERE-2008-BT-STD-0012 COMMENT 22
Table 10.2.1 Standard-Size Refrigerator-Freezers: Base-Case Efficiency Distributions 

Energy 

Use 

Top-Mount RefrigeratorFreezers 

(market share in %) 

Bottom-Mount RefrigeratorFreezers 

(market share in %) 

Side-by-Side RefrigeratorFreezers 

(market share in %) 

Factor 2007 2014 2021 2007 2014 2021 2007 2014 2021 

1.0 

0.90 

0.85 

0.80* 

0.75 

0.70 

0.65 

0.60 

0.55 

80.7 

5.9 

13.2 

0.2 

0.0 

0.0 

0.0 

0.0 

0.0 

80.7 

5.9 

0.0 

13.4 

0.0 

0.0 

0.0 

0.0 

0.0 

80.7 

5.9 

0.0 

0.0 

13.4 

0.0 

0.0 

0.0 

0.0 

11.8 

0.1 

69.8 

18.3 

0.0 

0.0 

0.0 

0.0 

0.0 

11.8 

0.1 

0.0 

88.1 

0.0 

0.0 

0.0 

0.0 

0.0 

11.8 

0.1 

0.0 

0.0 

88.1 

0.0 

0.0 

0.0 

0.0 

25.0 

43.0 

30.3 

1.7 

0.0 

0.0 

0.0 

0.0 

-

25.0 

43.0 

0.0 

32.0 

0.0 

0.0 

0.0 

0.0 

-

25.0 

43.0 

0.0 

0.0 

32.0 

0.0 

0.0 

0.0 

-

SWEUF 0.974 0.967 0.961 0.859 0.824 0.780 0.908 0.893 0.877 

* Meets 2008 ENERGY STAR criteria. 

Table 10.2.2 Standard-Size Freezers: Base-Case Efficiency Distributions 

Energy Use 

Upright Freezers 

(market share in %) 

Chest Freezers 

(market share in %) 

Factor 2007 2014 2021 2007 2014 2021 

1.0 

0.90* 

0.85 

0.80 

0.75 

0.70 

0.65 

0.60 

0.55 

81.5 

17.0 

1.0 

0.1 

0.2 

0.2 

0.0 

0.0 

0.0 

81.5 

17.0 

1.0 

0.1 

0.2 

0.2 

0.0 

0.0 

0.0 

81.5 

0.0 

18.0 

0.1 

0.2 

0.2 

0.0 

0.0 

0.0 

84.7 

14.3 

0.8 

0.0 

0.0 

0.2 

0.0 

0.0 

0.0 

84.7 

14.3 

0.8 

0.0 

0.0 

0.2 

0.0 

0.0 

0.0 

84.7 

0.0 

15.1 

0.0 

0.0 

0.2 

0.0 

0.0 

0.0 

SWEUF 0.980 0.980 0.972 0.984 0.984 0.977 

* Meets 2008 ENERGY STAR criteria. 

10-4 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10.2.3 Compact Refrigerators and Freezers: Base-Case Efficiency Distributions 

Energy Use 

Compact Refrigerators 

(market share in %) 

Compact Freezers 

(market share in %) 

Factor 2007 2014 2021 2007 2014 2021 

1.0 

0.90 

0.85 

0.80* 

0.75 

0.70 

0.65 

0.60 

0.55 

97.1 

0.3 

0.0 

0.9 

1.7 

0.0 

0.0 

0.0 

0.0 

97.1 

0.3 

0.0 

0.9 

1.7 

0.0 

0.0 

0.0 

0.0 

97.1 

0.3 

0.0 

0.0 

2.6 

0.0 

0.0 

0.0 

0.0 

95.4 

4.6 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

95.4 

4.6 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

95.4 

4.6 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

SWEUF 0.994 0.994 0.993 0.995 0.995 0.995 

* Meets 2008 ENERGY STAR criteria. 

Standards cases. To determine efficiency distributions for cases in which a candidate 

standard applies, DOE used a “roll-up + market shift” scenario for 2014, the year that revised 

standards are assumed to become effective, and subsequent years. DOE assumed that product 

efficiencies in the base case that did not meet the standard under consideration would roll up to 

meet the new standard in 2014. 

DOE further assumed that revised standards would result in a market shift such that 

market shares of products with efficiency better than the standard would gradually increase. In 

keeping with the perspective of the base case scenario that energy efficiency will be a policy 

priority, DOE assumed that the ENERGY STAR program will continue to promote efficient 

appliances after revised standards are introduced in 2014. For a standard that calls for an energy 

use factor of 0.9 (a 10-percent reduction in energy use from the current standard) for standardsize refrigerator-freezers, DOE assumed that the ENERGY STAR requirement would remain 20 

percent better than the standard. For all other standard levels for standard-size refrigeratorfreezers other than the maximum-efficiency level, DOE assumed that the ENERGY STAR 

program would use a threshold of 15 percent better than the standard, because it might be 

difficult to achieve 20 percent better than the standard at the new, higher efficiency levels. For all 

standard levels other than the maximum-efficiency level, DOE assumed that the ENERGY 

STAR program would use a threshold of 10 percent better than the standard for standard-size 

freezers, and 20 percent better than the standard for compact refrigeration products. Those levels 

correspond to the current ENERGY STAR requirements (relative to the standard). 

Using the above criteria, DOE assumed that from 2014 to 2021 the market share of 

ENERGY STAR appliances for each product category would grow linearly until it reached the 

level obtained in 2007. DOE assumed that after 2021 the percentage of shipments at each 

efficiency level would remain fixed at the 2021 values. 

10-5 

EERE-2008-BT-STD-0012 COMMENT 22
 Figure 10.2.1 is a graphical representation of DOE’s approach. The figure shows a plot of 

the shipment-weighted energy use factor for product class 7 (representative of all side-by-side 

refrigerator-freezers) for the base case and each candidate standard level. Some units in each 

year exceed the standard level in all cases except candidate standard level 7, which represents the 

maximum-efficiency case. Similar figures could be created for every product class. Shipment-Weighted Energy Use Factor

1 

0.9 

Base case 

CSL 1 (0.9) 

0.8 CSL 2 (0.85) 

CSL 3 (0.8) 

CSL 4 (0.75) 0.7 

CSL 5 (0.7) 

CSL 6 (0.65) 

0.6 CSL 7 (0.6) 

0.5 

0.4 

2005 2010 2015 2020 2025 2030 2035 2040 2045 

Year 

Figure 10.2.1 Projected Shipment-Weighted Energy Use Factors as a Function 

of Standard Level for Product Class 7 

10.2.2 Standard-Size Refrigerator-Freezers 

Tables 10.2.4 through 10.2.9 show the efficiency distributions for 2014 and 2021 that 

DOE used for the considered refrigerator-freezer product classes under the base case and each 

potential standards case. Efficiency distributions for the base and standards cases transition 

linearly from 2014 to 2021, after which they remain fixed. The tables include the shipmentweighted energy use factor (SWEUF) associated with each case. 

10-6 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10.2.4 Top-Mount Refrigerator-Freezers: Efficiency Distributions in 2014 for Base 

and Standards Cases 

Efficiency 

Level 

(% less 

than 

baseline 

energy 

use) 

Energy 

Use 

Factor 

Baseline 1.0 

1 (10) 0.90 

2 (15) 0.85 

3 (20) 0.80 

4 (25) 0.75 

5 (30) 0.70 

6 (35) 0.65 

7 (40) 0.60 

8 (45) 0.55 

SWEUF 

Base 

Case 

80.7 

5.9 

0.0 

13.4 

0.0 

0.0 

0.0 

0.0 

0.0 

0.967 

1 

-

86.6 

0.0 

13.4 

0.0 

0.0 

0.0 

0.0 

0.0 

0.887 

2 

-

-

86.6 

13.4 

0.0 

0.0 

0.0 

0.0 

0.0 

0.843 

Market Share % 

Standards Case 

3 4 5 

- - -

- - -

- - -

100.0 - -

0.0 100.0 -

0.0 0.0 100.0 

0.0 0.0 0.0 

0.0 0.0 0.0 

0.0 0.0 0.0 

0.800 0.750 0.700 

6 7 8 

- - -

- - -

- - -

- - -

- - -

- - -

100.0 - -

0.0 100.0 -

0.0 0.0 100.0 

0.650 0.600 0.550 

Table 10.2.5 Top-Mount Refrigerator-Freezers: Efficiency Distributions in and After 

2021 for Base and Standards Cases 

Efficiency Market Share % 

Level Standards Case 

(% less 

than 

baseline Energy 

energy Use Base 

use) Factor Case 1 2 3 4 5 6 7 8 

Baseline 1.0 80.7 - - - - - - - -

1 (10) 0.90 5.9 86.6 - - - - - - -

2 (15) 0.85 0.0 0.0 86.6 - - - - - -

3 (20) 0.80 0.0 0.0 0.0 86.6 - - - - -

4 (25) 0.75 13.4 13.4 13.4 0.0 86.6 - - - -

5 (30) 0.70 0.0 0.0 0.0 13.4 0.0 86.6 - - -

6 (35) 0.65 0.0 0.0 0.0 0.0 13.4 0.0 86.6 - -

7 (40) 0.60 0.0 0.0 0.0 0.0 0.0 13.4 13.4 86.6 -

8 (45) 0.55 0.0 0.0 0.0 0.0 0.0 0.0 0.0 13.4 100.0 

SWEUF 0.961 0.880 0.837 0.787 0.737 0.687 0.643 0.593 0.550 

10-7 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

Table 10.2.6 Bottom-Mount Refrigerator-Freezers: Efficiency Distributions in 2014 for 

Base and Standards Cases 

Efficiency 

Level 

(% less 

than 

baseline 

energy 

use) 

Energy 

Use 

Factor 

Baseline 1.0 

1 (10) 0.90 

2 (15) 0.85 

3 (20) 0.80 

4 (25) 0.75 

5 (30) 0.70 

6 (35) 0.65 

7 (40) 0.60 

8 (45) 0.55 

SWEUF 

Base 

Case 

11.8 

0.1 

0.0 

88.1 

0.0 

0.0 

0.0 

0.0 

0.0 

0.824 

1 

-

11.9 

0.0 

88.1 

0.0 

0.0 

0.0 

0.0 

0.0 

0.812 

Market Share % 

Standards Case 

2 3 4 5 6 

- - - - -

- - - - -

11.9 - - - -

88.1 100.0 - - -

0.0 0.0 100.0 - -

0.0 0.0 0.0 100.0 -

0.0 0.0 0.0 0.0 100.0 

0.0 0.0 0.0 0.0 0.0 

0.0 0.0 0.0 0.0 0.0 

0.806 0.800 0.750 0.700 0.650 

7 

-

-

-

-

-

-

-

100.0 

0.0 

0.600 

8 

-

-

-

-

-

-

-

-

100.0 

0.550 

Table 10.2.7 Bottom-Mount Refrigerator-Freezers: Efficiency Distributions in and After 

2021 for Base and Standards Cases 

Efficiency Market Share % 

Level Standards Case 

(% less 

than 

baseline Energy 

energy Use Base 

use) Factor Case 1 2 3 4 5 6 7 8 

Baseline 1.0 11.8 - - - - - - - -

1 (10) 0.90 0.1 11.9 - - - - - - -

2 (15) 0.85 0.0 0.0 11.9 - - - - - -

3 (20) 0.80 0.0 0.0 0.0 11.9 - - - - -

4 (25) 0.75 88.1 88.1 88.1 0.0 11.9 - - - -

5 (30) 0.70 0.0 0.0 0.0 88.1 0.0 11.9 - - -

6 (35) 0.65 0.0 0.0 0.0 0.0 88.1 0.00 11.9 - -

7 (40) 0.60 0.0 0.0 0.0 0.0 0.0 88.1 88.1 11.9 -

8 (45) 0.55 0.0 0.0 0.0 0.0 0.0 0.00 0.00 88.1 100.0 

SWEUF 0.780 0.768 0.762 0.712 0.662 0.622 0.606 0.556 0.550 

10-8 

EERE-2008-BT-STD-0012 COMMENT 22
Table 10.2.8 Side-by-Side Refrigerator-Freezers: Efficiency Distributions in 2014 for Base 

and Standards Cases 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Baseline 

1 (10) 

2 (15) 

3 (20) 

4 (25) 

5 (30) 

6 (35) 

7 (40) 

Energy Use 

Factor Base Case 

1.0 25.0 

0.90 43.0 

0.85 0.0 

0.80 32.0 

0.75 0.0 

0.70 0.0 

0.65 0.0 

0.60 0.0 

SWEUF 0.893 

1 

-

68.0 

0.0 

32.0 

0.0 

0.0 

0.0 

0.0 

0.868 

Market Share % 

Standards Case 

2 3 4 5 6 7 

- - - - - -

- - - - - -

68.0 - - - - -

32.0 100.0 - - - -

0.0 0.0 100.0 - - -

0.0 0.0 0.0 100.0 - -

0.0 0.0 0.0 0.0 100.0 -

0.0 0.0 0.0 0.0 0.0 100.0 

0.834 0.800 0.750 0.700 0.650 0.600 

Table 10.2.9 Side-by-Side Refrigerator-Freezers: Efficiency Distributions in and After 

2021 for Base and Standards Cases 

Efficiency 

Level 

(% less than 

baseline 

energy use) 

Baseline 

1 (10) 

2 (15) 

3 (20) 

4 (25) 

5 (30) 

6 (35) 

7 (40) 

Energy Use 

Factor Base Case 

1.0 25.0 

0.90 43.0 

0.85 0.0 

0.80 0.0 

0.75 32.0 

0.70 0.0 

0.65 0.0 

0.60 0.0 

SWEUF 0.877 

1 

-

68.0 

0.0 

0.0 

32.0 

0.0 

0.0 

0.0 

0.852 

Market Share % 

Standards Case 

2 3 4 5 6 7 

- - - - - -

- - - - - -

68.0 - - - - -

0.0 68.0 - - - -

32.0 0.0 68.0 - - -

0.0 32.0 0.0 68.0 - -

0.0 0.0 32.0 0.0 68.0 -

0.0 0.0 0.0 32.0 32.0 100.0 

0.818 0.768 0.718 0.668 0.634 0.600 

10-9 

EERE-2008-BT-STD-0012 COMMENT 22
 

10.2.3 Standard-Size Freezers 

Tables 10.2.10 through 10.2.13 give the efficiency distributions in 2014 and 2021 that 

DOE used for the base case and each standards case for the standard-sized freezer product 

classes. The efficiency distributions for the base and all standards cases transition linearly from 

2014 to 2021, after which they remain fixed. The tables include the SWEUF associated with 

each case. 

Table 10.2.10 Upright Freezers: Efficiency Distributions in 2014 for Base and Standards 

Cases 

Efficiency Market Share % 

Level Standards Case 

(% less 

than Energy 

baseline Use Base 

energy use) Factor Case 1 2 3 4 5 6 7 8 

Baseline 1.0 81.5 - - - - - - - -

1 (10) 0.90 17.0 98.5 - - - - - - -

2 (15) 0.85 1.0 1.0 99.5 - - - - - -

3 (20) 0.80 0.1 0.1 0.1 99.6 - - - - -

4 (25) 0.75 0.2 0.2 0.2 0.2 99.8 - - - -

5 (30) 0.70 0.2 0.2 0.2 0.2 0.2 100.0 - - -

6 (35) 0.65 0.0 0.0 0.0 0.0 0.0 0.0 100.0 - -

7 (40) 0.60 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 -

8 (45) 0.55 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 

SWEUF 0.980 0.899 0.849 0.800 0.750 0.700 0.650 0.600 0.550 

Table 10.2.11 Upright Freezers: Efficiency Distributions in and After 2021 for Base and 

Standards Cases 

Efficiency Market Share % 

Level Standards Case 

(% less 

than Energy 

baseline Use Base 

energy use) Factor Case 1 2 3 4 5 6 7 8 

Baseline 1.0 81.5 - - - - - - - -

1 (10) 0.90 0.0 81.5 - - - - - - -

2 (15) 0.85 18.0 18.0 81.5 - - - - - -

3 (20) 0.80 0.1 0.1 18.1 81.5 - - - - -

4 (25) 0.75 0.2 0.2 0.2 18.3 81.5 - - - -

5 (30) 0.70 0.2 0.2 0.2 0.2 18.5 81.5 - - -

6 (35) 0.65 0.0 0.0 0.0 0.0 0.0 18.5 81.5 - -

7 (40) 0.60 0.0 0.0 0.0 0.0 0.0 0.0 18.5 81.5 -

8 (45) 0.55 0.0 0.0 0.0 0.0 0.0 0.0 0.0 18.5 100.0 

SWEUF 0.972 0.890 0.840 0.791 0.741 0.691 0.641 0.591 0.550 

10-10 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10.2.12 Chest Freezers: Efficiency Distributions in 2014 for Base and Standards 

Cases 

Efficiency 

Level 

(% less 

than 

baseline 

energy use) 

Energy 

Use 

Factor 

Base 

Case 1 

Baseline 1.0 84.7 -

1 (10) 0.90 14.3 99.0 

2 (15) 0.85 0.8 0.8 

3 (20) 0.80 0.0 0.0 

4 (25) 0.75 0.0 0.0 

5 (30) 0.70 0.2 0.2 

6 (35) 0.65 0.0 0.0 

7 (40) 0.60 0.0 0.0 

8 (45) 0.55 0.0 0.0 

SWEUF 0.984 0.900 

Market Share % 

Standards Case 

2 3 4 5 

- - - -

- - - -

99.8 - - -

0.0 99.8 - -

0.0 0.0 99.8 -

0.2 0.2 0.2 100.0 

0.0 0.0 0.0 0.0 

0.0 0.0 0.0 0.0 

0.0 0.0 0.0 0.0 

0.850 0.800 0.750 0.700 

6 7 

- -

- -

- -

- -

- -

- -

100.0 -

0.0 100.0 

0.0 0.0 

0.650 0.600 

8 

-

-

-

-

-

-

-

-

100.0 

0.550 

Table 10.2.13 Chest Freezers: Efficiency Distributions in and After 2021 for Base and 

Standards Cases 

Efficiency Market Share % 

Level 

(% less than Energy 

Standards Case 

baseline Use Base 

energy use) Factor Case 1 2 3 4 5 6 7 8 

Baseline 1.0 84.7 - - - - - - - -

1 (10) 0.90 0.0 84.7 - - - - - - -

2 (15) 0.85 15.1 15.1 84.7 - - - - - -

3 (20) 0.80 0.0 0.0 15.1 84.7 - - - - -

4 (25) 0.75 0.0 0.0 0.0 15.1 84.7 - - - -

5 (30) 0.70 0.2 0.2 0.2 0.2 15.3 84.7 - - -

6 (35) 0.65 0.0 0.0 0.0 0.0 0.0 15.3 84.7 - -

7 (40) 0.60 0.0 0.0 0.0 0.0 0.0 0.0 15.3 84.7 -

8 (45) 0.55 0.0 0.0 0.0 0.0 0.0 0.0 0.0 15.3 100.0 

SWEUF 0.977 0.892 0.842 0.792 0.742 0.692 0.642 0.592 0.550 

10.2.4 Compact Refrigerators and Freezers 

Tables 10.2.14 through 10.2.17 show the efficiency distributions in 2014 and 2021 that 

DOE used for the base case and all potential standards cases for compact refrigeration product 

classes. The efficiency distributions for the base and standards cases transition linearly from 

2014 to 2021, after which they remain fixed. The tables include the SWEUF associated with 

each case. 

10-11 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10.2.14 Compact Refrigerators: Efficiency Distributions in 2014 for Base and 

Standards Cases 

Efficiency Market Share % 

Level 

(% less than Energy 

Standards Case 

baseline Use Base 

energy use) Factor Case 1 2 3 4 5 6 7 8 

Baseline 1.0 97.1 - - - - - - - -

1 (10) 0.90 0.3 97.4 - - - - - - -

2 (15) 0.85 0.0 0.0 97.4 - - - - - -

3 (20) 0.80 0.9 0.9 0.9 98.3 - - - - -

4 (25) 0.75 1.7 1.7 1.7 1.7 100.0 - - - -

5 (30) 0.70 0.0 0.0 0.0 0.0 0.0 100.0 - - -

6 (35) 0.65 0.0 0.0 0.0 0.0 0.0 0.0 100.0 - -

7 (40) 0.60 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 -

8 (45) 0.55 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 

SWEUF 0.993 0.897 0.848 0.799 0.750 0.700 0.650 0.600 0.550 

Table 10.2.15 Compact Refrigerators: Efficiency Distributions in and After 2021 for Base 

and Standards Cases 

Efficiency Market Share % 

Level 

(% less than Energy 

Standards Case 

baseline Use Base 

energy use) Factor Case 1 2 3 4 5 6 7 8 

Baseline 1.0 97.1 - - - - - - - -

1 (10) 0.90 0.3 97.4 - - - - - - -

2 (15) 0.85 0.0 0.0 97.4 - - - - - -

3 (20) 0.80 0.0 0.0 0.0 97.4 - - - - -

4 (25) 0.75 2.6 2.6 0.0 0.0 97.4 - - - -

5 (30) 0.70 0.0 0.0 2.6 0.0 0.0 97.4 - - -

6 (35) 0.65 0.0 0.0 0.0 2.6 0.0 0.0 97.4 - -

7 (40) 0.60 0.0 0.0 0.0 0.0 2.6 2.6 0.0 97.4 -

8 (45) 0.55 0.0 0.0 0.0 0.0 0.0 0.0 2.6 2.6 100.0 

SWEUF 0.993 0.896 0.846 0.796 0.746 0.697 0.647 0.599 0.550 

10-12 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10.2.16 Compact Freezers: Efficiency Distributions in 2014 for Base and Standards 

Cases 

Efficiency Market Share % 

Level 

(%less than Energy 

Standards Case 

baseline Use Base 

energy use) Factor Case 1 2 3 4 5 6 7 8 

Baseline 1.0 95.4 - - - - - - - -

1 (10) 0.9 4.6 100.0 - - - - - - -

2 (15) 0.85 0.0 0.0 100.0 - - - - - -

3 (20) 0.80 0.0 0.0 0.0 100.0 - - - - -

4 (25) 0.75 0.0 0.0 0.0 0.0 100.0 - - - -

5 (30) 0.70 0.0 0.0 0.0 0.0 0.0 100.0 - - -

6 (35) 0.65 0.0 0.0 0.0 0.0 0.0 0.0 100.0 - -

7 (40) 0.60 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 -

8 (45) 0.55 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 

SWEUF 0.995 0.900 0.850 0.800 0.750 0.700 0.650 0.600 0.550 

Table 10.2.17 Compact Freezers: Efficiency Distributions in and After 2021 for Base and 

Standards Cases 

Efficiency Market Share % 

Level 

(% less than Energy 

Standards Case 

baseline Use Base 

energy use) Factor Case 1 2 3 4 5 6 7 8 

Baseline 1.0 95.4 - - - - - - - -

1 (10) 0.90 4.6 100.0 - - - - - - -

2 (15) 0.85 0.0 0.0 100.0 - - - - - -

3 (20) 0.80 0.0 0.0 0.0 100.0 - - - - -

4 (25) 0.75 0.0 0.0 0.0 0.0 100.0 - - - -

5 (30) 0.70 0.0 0.0 0.0 0.0 0.0 100.0 - - -

6 (35) 0.65 0.0 0.0 0.0 0.0 0.0 0.0 100.0 - -

7 (40) 0.60 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 -

8 (45) 0.55 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 100.0 

SWEUF 0.995 0.900 0.850 0.800 0.750 0.700 0.650 0.600 0.550 

10.3 NATIONAL ENERGY SAVINGS 

DOE calculated the national energy savings associated with the difference between the 

base case and the case associated with each potential standard for the refrigeration products 

10-13 

EERE-2008-BT-STD-0012 COMMENT 22
considered herein. DOE calculated cumulative energy savings throughout the forecast period, 

which extends from 2014 to 2044. 

10.3.1 Definition 

The following equation shows that DOE calculated annual national energy savings (NES) 

as the difference between two projections: a base case (without new standards) and a standards 

case. Positive values of NES represent energy savings (that is, national annual energy 

consumption (AEC) under a standard is less than in the base case). 

_ NESy = AEC AEC BASE STD 

Cumulative energy savings are the sum of annual national energy savings throughout the 

forecast period, which extends from the assumed effective date of new standards (2014) to 30 

years after that date (2044). The calculation is represented by the following equation. 

NEScum = ∑NES y 

DOE calculated the national annual energy consumption by multiplying the number or stock of 

each product class (by vintage) by its unit energy consumption (UEC; also by vintage). The 

calculation of national annual energy consumption is represented by the following equation. 

AEC y = ∑STOCKV ×UECV 

DOE defined the quantities for the above expressions as follows. 

AEC = national annual energy consumption each year in quadrillion British thermal units 

(quads), summed over vintages of the product stock, STOCKV; 

NES = annual national energy savings (quads); 

STOCKV = stock of product (millions of units) of vintage V that survive in the year for which 

DOE calculated annual energy consumption; 

UECV = annual energy consumption per product in kilowatt hours (kWh) [electricity 

consumption is converted from site energy to source energy (quads) by applying a 

time-dependent conversion factor]; 

V = year in which the product was purchased as a new unit; and 

y = year in the forecast. 

The stock of a product depends on annual shipments and the lifetime of the product. As 

described in chapter 9, DOE projected product shipments under the base case and standards 

cases. DOE projected that shipments under the standards cases would be slightly lower than 

under the base case, because of the higher purchase cost of more efficient products. In other 

words, DOE believes that the higher purchase cost would cause some consumers to forego 

purchasing new products. 

10-14 

EERE-2008-BT-STD-0012 COMMENT 22
To avoid including savings attributable to shipments displaced because of standards, 

DOE used the projected standards-case shipments and, in turn, the standards-case stock, to 

calculate the annual energy consumption for the base case. 

10.3.2 Inputs 

The inputs to the calculation of national energy savings (NES) are: 

• Shipments; 

• product stock (STOCKV); 

• annual energy consumption per unit (UEC); 

• national annual energy consumption (AEC); and 

• site-to-source conversion factor (src_conv). 

10.3.2.1 Shipments 

DOE forecasted shipments of each considered product class under the base case and all 

standards cases. Several factors affect forecasted shipments, including purchase cost, operating 

cost, and household income. As noted earlier, the increased cost of more efficient products 

causes some consumers to forego buying the products. Consequently, shipments forecasted 

under the standards cases are lower than under the base case. The method DOE used to calculate 

and generate the shipments forecasts for each considered product class is described in detail in 

Chapter 9, Shipments Analysis. 

10.3.2.2 Equipment Stock 

The equipment stock in a given year is the number of products shipped from earlier years 

that survive in that year. The NIA model tracks the number of the number of units shipped each 

year. DOE assumes that products have an increasing probability of retiring as they age. The 

probability of survival as a function of years since purchase is the survival function. Chapter 9 

provides additional details on the survival functions that DOE used for each product. 

10.3.2.3 Annual Energy Consumption per Unit 

DOE used the shipment-weighted energy use factors (SWEUFs) presented in section 10.2 

for the base case and standards cases, along with the data on annual energy consumption 

presented in chapters 7 and 8, to estimate the shipment-weighted average annual per-unit energy 

consumption under the base and standards cases. The average annual per-unit energy 

consumption projected for 2014 for each product category is shown in Tables 10.3.1 through 

10.3.3. 

10-15 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

Table 10.3.1 Standard-Size Refrigerator-Freezers: Shipment-Weighted Average Annual 

Energy Consumption in 2014 

Base 

Case 

Standards Case 

1 2 3 4 5 6 7 8 

Top-Mount 

SWEUF 

 Avg. Energy Use (kWh) 

0.967 

636 

0.887 

582 

0.843 

554 

0.800 

526 

0.750 

493 

0.700 

460 

0.650 

427 

0.600 

394 

0.550

361 

Bottom-Mount 

SWEUF 

 Avg. Energy Use (kWh) 

0.824 

575 

0.812 

567 

0.806 

563 

0.800 

559 

0.750 

524 

0.700 

489 

0.650 

454 

0.600 

419 

0.550

384 

Side-by-Side 

SWEUF 

 Avg. Energy Use (kWh) 

0.893 

971 

0.868 

944 

0.834 

907 

0.800 

870 

0.750 

815 

0.700 

761 

0.650 

707 

0.600 

652 

-

-

Table 10.3.2 Standard-Size Freezers: Shipment-Weighted Average Annual Energy 

Consumption in 2014 

Base Standards Case 

Case 1 2 3 4 5 6 7 8 

Upright 

SWEUF 0.980 0.899 0.849 0.800 0.750 0.700 0.650 0.600 0.550

 Avg. Energy Use (kWh) 960 881 832 784 735 686 637 588 539 

Chest 

SWEUF 0.984 0.899 0.850 0.800 0.750 0.700 0.650 0.600 0.550

 Avg. Energy Use (kWh) 613 560 529 498 467 436 405 374 343 

Table 10.3.3 Compact Refrigerators and Freezers: Shipment-Weighted Average Annual 

Energy Consumption in 2014 

Base Standards Case 

Case 1 2 3 4 5 6 7 8 

Refrigerator 

SWEUF 

 Avg. Energy Use (kWh) 

0.994 

323 

0.897 

291 

0.848 

275 

0.799 

260 

0.750 

244 

0.700 

227 

0.650 

211 

0.600 

195 

0.550

179 

Freezer 

SWEUF 

 Avg. Energy Use (kWh) 

0.995 

311 

0.900 

281 

0.850 

266 

0.800 

250 

0.750 

235 

0.700 

219 

0.650 

203 

0.600 

188 

0.550

172 

10-16 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

         

10.3.2.4 National Annual Energy Consumption 

The national annual energy consumption (AEC) is the product of the annual energy 

consumption per unit and the number of units of each vintage. This method of calculation 

accounts for differences in unit energy consumption from year to year. The equation for 

determining the annual energy consumption, which was presented in section 10.3.1, is repeated 

here. 

AEC = ∑STOCKV ×UECV 

In determining national annual energy consumption, DOE first calculated annual energy 

consumption at the site, then applied a conversion factor, described below, to calculate primary 

energy consumption. 

10.3.2.5 Site-to-Source Conversion Factors 

In determining national annual energy consumption, DOE initially calculated the annual 

energy consumption at the site (for electricity, the energy in kWh consumed at the household or 

establishment). It then used site energy consumption to calculate primary (source) energy 

consumption by applying a conversion factor to account for losses associated with the 

generation, transmission, and distribution of electricity. The site-to-source conversion factor is a 

multiplicative factor used to convert site energy consumption into primary or source energy 

consumption, expressed in quads (quadrillion Btus). DOE used annual site-to-source conversion 

factors based on the version of the National Energy Modeling System (NEMS)b

 that corresponds 

to EIA’s Annual Energy Outlook 2008 (AEO 2008).4

 The factors are marginal values, which 

represent the response of the system to an incremental decrease in consumption. For electricity, 

the conversion factors change over time in response to projected changes in generation sources 

(i.e., the types of power plants projected to provide electricity to the Nation). Figure 10.3.1 

shows the site-to-source conversion factors from 2005 to the end of the forecast period. DOE 

assumed that conversion factors remain at 2030 values throughout the rest of the forecast. 

b For more information on NEMS, please refer to the U.S. Department of Energy, Energy Information 

Administration documentation.  A useful summary is National Energy Modeling System: An Overview 2000,

DOE/EIA‐0581(2000), March 2000.  EIA approves use of the name NEMS to describe only an official version

of the model without any modification to code or data.  Because this analysis entails some minor code

modifications and the model is run under various policy scenarios that are variations on EIA assumptions, 

DOE refers to the model by the name NEMS‐BT (BT is DOE’s Building Technol

aegis this work has been performed).  NEMS‐BT was previously called NEMS‐BRS.

ogies Program, under whose

10-17 

EERE-2008-BT-STD-0012 COMMENT 22
0 

2000 

4000 

6000 

8000 

10000 

12000 

14000 

Marginal Site-to-Source Conversion Factor for 

Electricty (Btu/kWh) 

2000 2005 2010 2015 2020 2025 2030 2035 2040 2045 2050 

Year 

Figure 10.3.1 Marginal Site-to-Source Conversion Factors for Electricity 

10.4 NET PRESENT VALUE 

DOE calculated the net present value (NPV) of the increased product cost and reduced 

operating cost associated with the difference between the base case and each potential standards 

case for the considered refrigeration products. 

10.4.1 Definition 

The NPV is the value in the present of a time-series of costs and savings. The NPV is 

described by the equation: 

_ NPV = PVS PVC 

Where: 

PVS = present value of savings in operating cost, and 

PVC = present value of increased total product cost to consumers. 

10-18 

EERE-2008-BT-STD-0012 COMMENT 22
DOE determined the PVS and PVC according to the following expressions. 

PVS = ∑OCSy × DFy 

PVC = ∑TICy × DFy 

Where: 

OCS = total annual savings in operating cost each year summed over vintages of the product 

stock, STOCKV; 

TIC = total annual increases in product cost each year summed over years of the product 

shipments, SHIPy; 

DF = discount factor in each year; and 

y = year in the forecast. 

DOE calculated the total annual consumer savings in operating cost by multiplying the 

number or stock of a given product class (by vintage) by its per-unit operating cost savings (also 

by vintage). DOE calculated the total annual increases in consumer product cost by multiplying 

the number or shipments of the given product class (by vintage) by its per-unit increase in 

consumer product cost (also by vintage). The calculation of total annual operating cost savings 

and total annual product cost increases is represented by the following equations. 

OCS y = ∑STOCKV ×UOCSV 

TIC y =∑SHIPy ×UTICy 

Where: 

STOCKV = stock of products of vintage V that survive in the year for which DOE calculated 

annual energy consumption, 

UOCSV = annual per-unit savings in operating cost, 

V = year in which the product was purchased as a new unit, 

SHIPy = shipments of products in year y, and 

UTICy = annual per-unit increase in installed product cost in year y. 

DOE determined the total increased product cost for each year from the effective date of 

a potential standard to 2044. It determined the present value of operating cost savings for each 

year from the effective date of the standard to the year when all units purchased by 2044 have 

been retired. DOE calculated costs and savings as the difference between a standards case and a 

base case without new standards. 

10-19 

EERE-2008-BT-STD-0012 COMMENT 22
DOE developed a discount factor from the national discount rate and the number of years 

between the present (i.e., year to which the sum is being discounted) and the year in which the 

costs and savings occur. The NPV is the sum over time of the discounted net savings. 

10.4.2 Inputs 

The inputs to calculation of the net present value (NPV) are: 

• Average annual product cost; 

• average annual savings in operating cost,; 

• total annual increases in product cost; 

• total annual savings in operating cost; 

• discount factor; 

• present value of costs; and 

• present value of savings. 

The increase in total annual product cost is equal to the annual change in the average 

annual product cost (difference between base case and standards case) multiplied by the 

shipments forecasted in the standards case. As with the calculation of the NES, DOE did not 

calculate total annual product costs using base-case shipments. To avoid including savings due to 

displaced shipments (by consumers deciding not to buy higher-cost products), DOE used the 

standards-case projection of shipments and, in turn, the standards-case stock, to calculate product 

costs. 

The total annual savings in operating cost are equal to the change in annual operating cost 

(difference between base case and standards case) per unit multiplied by the shipments 

forecasted in the standards case. 

10.4.2.1 Average Annual Product Cost 

The average annual product cost is directly dependent on efficiency. DOE therefore used 

the SWEUFs presented in section 10.2 for the base case and each standards case, along with the 

product costs at various efficiency levels (presented in chapter 8), to estimate the shipmentweighted average annual product cost under the base and standards cases. Tables 10.4.1 through 

10.4.3 show the shipment-weighted average consumer product cost based on the SWEUFs that 

correspond to the base case and each standards case in 2014. 

10-20 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

Table 10.4.1 Standard-Size Refrigerator-Freezers: Shipment-Weighted Average Product 

Cost in 2014 for Base and Standards Cases 

Base 

Case 

Standards Case 

1 2 3 4 5 6 7 8 

Top-Mount 

SWEUF 0.967 0.887 0.843 0.800 0.750 0.700 0.650 0.600 0.550

 Avg. Product Cost 2008$ 1,081 1,086 1,090 1,099 1,121 1,155 1,206 1,271 1,335 

Bottom-Mount 

SWEUF 0.824 0.812 0.806 0.800 0.750 0.700 0.650 0.600 0.550

 Avg. Product Cost 2008$ 1,447 1,449 1,449 1,451 1,470 1,525 1,614 1,696 1,790 

Side-by-Side 

SWEUF 0.893 0.868 0.834 0.800 0.750 0.700 0.650 0.600 -

 Avg. Product Cost 2008$ 1,456 1,460 1,466 1,496 1,559 1,634 1,710 1,817 -

Table 10.4.2 Standard-Size Freezers: Shipment-Weighted Average Product Cost in 2014 

for Base and Standards Cases 

Base Standards Case 

Case 1 2 3 4 5 6 7 8 

Upright 

SWEUF 0.980 0.899 0.849 0.800 0.750 0.700 0.650 0.600 0.550

 Avg. Product Cost 2008$ 501 507 514 517 533 563 597 657 758 

Chest 

SWEUF 0.984 0.899 0.850 0.800 0.750 0.700 0.650 0.600 0.550

 Avg. Product Cost 2008$ 514 519 524 545 564 568 581 621 707 

Table 10.4.3 Compact Refrigerators and Freezers: Shipment-Weighted Average Product 

Cost in 2014 for Base and Standards Cases 

Base 

Case 

Standards Case 

1 2 3 4 5 6 7 8 

Refrigerator 

SWEUF 0.994 0.897 0.848 0.799 0.750 0.700 0.650 0.600 0.550

 Avg. Product Cost 2008$ 159 164 167 171 186 187 192 205 224 

Freezer 

SWEUF 0.995 0.900 0.850 0.800 0.750 0.700 0.650 0.600 0.550

 Avg. Product Cost 2008$ 207 214 219 238 258 273 300 302 311 

10.4.2.2 Annual Operating Cost Savings per Unit 

The average annual operating cost includes the costs for energy, repair, and maintenance. 

As described in chapter 8, for all the considered products DOE assumed that potential standards 

10-21 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

would produce no increase in maintenance or repair costs. For all the considered products, 

therefore, DOE determined the per-unit annual savings in operating cost based only on the 

savings in energy costs attributable to a standard. DOE determined the per-unit annual savings in 

operating cost by multiplying the per-unit annual savings in energy consumption developed for 

each product class by the appropriate energy price. As described in chapter 8, DOE forecasted 

energy prices based on EIA’s AEO 2009.5 

10.4.2.3 Total Annual Increases in Product Cost 

The total annual increase in product cost for any given standards case is the product of 

the average cost increase per unit due to the standard and the number of units of each vintage 

shipped. This method accounts for differences in product cost from year to year. The equation 

for determining the total annual increase in product cost for a given standards case, which was 

shown in section 10.4.1, is repeated here. 

TIC y =∑SHIP y×UTICy 

10.4.2.4 Total Annual Savings in Operating Cost 

The total annual savings in operating cost for any given standards case is the product of 

the annual savings in operating cost per unit attributable to the standard and the number of units 

of each vintage. This method accounts for differences in annual savings in operating cost from 

year to year. The equation for determining the total annual savings in operating cost for a given 

standards case, which was presented in section 10.4.1, is repeated here. 

OCS = ∑STOCKV ×UOCSV 

10.4.2.5 Discount Factor 

DOE multiplied monetary values in future years by a discount factor to determine the 

present value. The discount factor (DF) is described by the equation: 

1

DF = _ ( y yp ) (1+ r ) 

Where: 

r = discount rate, 

y = year in which the monetary value exists, and 

yP = year in which the present value is being determined. 

Although DOE used consumer discount rates to determine the life-cycle cost of 

refrigeration products (chapter 8), it used national discount rates to calculate national NPV. DOE 

estimated NPV using both a 3-percent and a 7-percent real discount rate, in accordance with the 

10-22 

EERE-2008-BT-STD-0012 COMMENT 22
Office of Management and Budget’s guidance to Federal agencies on the development of 

regulatory analysis, particularly section E therein: Identifying and Measuring Benefits and 

Costs.

6

 DOE defined the present year as 2009. 

10.4.2.6 Present Value of Costs 

The present value of increased product costs is the annual total cost increase in each year 

(the difference between a standards case and the base case), discounted to the present and 

summed throughout the period in which DOE is considering the installation of products (that is, 

from the effective date of standards, 2014, to 2044). DOE calculated annual increases in installed 

cost as the difference in total product cost for new appliances purchased each year, multiplied by 

the shipments in the standards case. 

10.4.2.7 Present Value of Savings 

The present value of savings in operating cost is the annual savings on operating cost (the 

difference between the base case and a standards case), discounted to the present and summed 

from the effective date to the time when the last unit installed by 2044 is retired from service. 

Savings are decreases in operating cost associated with the higher energy efficiency of products 

purchased in the standards case compared to the base case. Total annual savings in operating cost 

are the savings per unit multiplied by the number of units of each vintage that survive in a 

particular year. 

10.5 RESULTS OF NES AND NPV CALCULATIONS 

The National Impact Analysis (NIA) model produces estimates of the NES and NPV 

attributable to a given candidate standard level. The inputs to the NIA model were discussed in 

sections 10.3.2 (inputs to NES ) and 10.4.2 (inputs to NPV). DOE generated the NES and NPV 

results using a Microsoft Excel spreadsheet, which is accessible on the Internet 

<www.eere.energy.gov/buildings/appliance_standards/> Details regarding and instructions for 

using the spreadsheet are provided in appendix 10-A. 

10.5.1 Summary of Inputs 

Table 10.5.1 summarizes the inputs to the NIA model. A brief description of the data is 

provided for each input. 

10-23 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10.5.1 Inputs to Calculation of National Energy Savings and Net Present Value 

Input Description 

Shipments Annual shipments from shipments model. (See chapter 9.) 

Effective date of standard 2014. 

Base-case forecasted efficiencies See section 10.2. 

Standards-case efficiencies See section 10.2. 

Annual energy consumption per unit Annual weighted-average values are a function of SWEUF. 

(See section 10.3.2.1.) 

Total installed cost per unit Annual weighted-average values are a function of the 

efficiency distribution. (See section 10.4.2.1.) 

Energy cost per unit Annual weighted-average values are a function of annual 

energy consumption per unit and energy prices. (See chapter 8 

for energy prices.) 

Repair and maintenance costs per unit No changes in repair and maintenance cost assumed at higherthan-baseline efficiency levels. 

Forecast of energy prices Energy prices: EIA AEO20095

 forecasts (to 2030) and 

extrapolation thereafter. (See chapter 8.) 

Marginal energy site-to-source 

conversion factor 

A time-series conversion factor that includes electric 

generation, transmission, and distribution losses. Conversion, 

which changes yearly, is generated by DOE-EIA’s NEMS* 

program. 

Discount rates 3% and 7% real. 

Present year Future expenses are discounted to 2009. 

* Chapter 13, Utility Impact Analysis, provides more detail on the National Energy Modeling System (NEMS). 

10.5.2 Results of National Energy Savings Calculations 

The following sections provide results of calculating NES for the efficiency levels 

analyzed for the considered products. NES results, which are cumulative from 2014 to 2044, are 

primary energy savings. DOE based the inputs to the NIA model on weighted-average values, 

yielding results that are discrete point values, rather than a distribution of values as in the lifecycle cost and payback period analyses. The results in Tables 10.5.2 through 10.5.7 represent all 

the product classes that DOE included in each of the seven representative product categories, not 

only the primary product class that accounts for the bulk of shipments in each category. 

10.5.2.1 Standard-Size Refrigerator-Freezers 

Table 10.5.2 shows the NES results for the efficiency levels analyzed for standard-size 

refrigerator-freezers. Table 10.5.3 shows the magnitude of the NES if the savings are discounted 

at rates of 3 percent and 7 percent. 

10-24 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

Table 10.5.2 Standard-Size Refrigerator-Freezers: Cumulative National Energy Savings, 

quads 

Efficiency Level 

(% less than baseline 

energy use) 

Top-Mount 

RefrigeratorFreezer* 

Bottom-Mount 

RefrigeratorFreezer** 

Side-by-Side 

RefrigeratorFreezer*** 

1 (10) 1.10 0.04 0.31 

2 (15) 1.69 0.06 0.73 

3 (20) 2.35 0.20 1.31 

4 (25) 3.01 0.37 1.91 

5 (30) 3.65 0.53 2.50 

6 (35) 4.20 0.57 2.93 

7 (40) 4.78 0.73 3.35 

8 (45) 5.28 0.77 -

* Includes product classes 1, 1A, 2, 3A, and 6 as well as product class 3. 

** Includes product class 5A as well as product class 5. 

*** Includes product class 4 as well as product class 7. 

Table 10.5.3 Standard-Size Refrigerator-Freezers: Discounted Cumulative National 

Energy Savings, quads 

Efficiency Level 

(% less than 

baseline energy 

use) 

Top-Mount 

Refrigerator-Freezer* 

Bottom-Mount 

Refrigerator-Freezer** 

Side-by-Side 

Refrigerator-Freezer*** 

3% 

Discount 

Rate 

7% 

Discount 

Rate 

3% 

Discount 

Rate 

7% Discount 

Rate 

3% 

Discount 

Rate 

7% 

Discount 

Rate 

1 (10) 0.57 0.26 0.02 0.01 0.16 0.07 

2 (15) 0.87 0.40 0.03 0.01 0.37 0.17 

3 (20) 1.21 0.56 0.10 0.04 0.67 0.30 

4 (25) 1.55 0.72 0.18 0.08 0.98 0.44 

5 (30) 1.88 0.87 0.27 0.12 1.28 0.58 

6 (35) 2.17 1.00 0.29 0.13 1.50 0.68 

7 (40) 2.47 1.13 0.37 0.17 1.72 0.78 

8 (45) 2.72 1.25 0.40 0.18 - -

* Includes product classes 1, 1A, 2, 3A, and 6 as well as product class 3. 

** Includes product class 5A as well as product class 5. 

*** Includes product class 4 as well as product class 7. 

10.5.2.2 Standard-Size Freezers 

Table 10.5.4 shows the NES results for the efficiency levels analyzed for standard-size 

freezers. Table 10.5.5 shows the magnitude of the NES if the savings are discounted at rates of 3 

percent and 7 percent. 

10-25 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 10.5.4 Standard-Size Freezers: Cumulative National Energy Savings, quads 

Efficiency Level 

(% less than baseline energy use) Upright Freezers* Chest Freezers** 

1 (10) 0.34 0.23 

2 (15) 0.55 0.37 

3 (20) 0.75 0.50 

4 (25) 0.96 0.63 

5 (30) 1.15 0.76 

6 (35) 1.34 0.87 

7 (40) 1.51 1.00 

8 (45) 1.63 1.07 

* Includes product class 9 only. 

** Includes product classes 8 and 10A as well as product class 10. 

Table 10.5.5 Standard-Size Freezers: Discounted Cumulative National Energy Savings, 

quads 

Efficiency Level 

(% less than baseline 

energy use) 

Upright Freezers* Chest Freezers** 

3% Discount 

Rate 

7% Discount 

Rate 

3% Discount 

Rate 

7% Discount 

Rate 

1 (10) 0.17 0.08 0.12 0.05 

2 (15) 0.28 0.12 0.19 0.08 

3 (20) 0.38 0.17 0.25 0.11 

4 (25) 0.48 0.22 0.32 0.14 

5 (30) 0.58 0.26 0.38 0.17 

6 (35) 0.68 0.30 0.44 0.20 

7 (40) 0.76 0.34 0.50 0.22 

8 (45) 0.83 0.37 0.54 0.24 

* Includes product class 9 only. 

** Includes product classes 8 and 10A as well as product class 10. 

10.5.2.3 Compact Refrigerators and Freezers 

Table 10.5.6 shows the NES results for the efficiency levels analyzed for compact 

refrigerators and freezers. Table 10.5.7 shows the magnitude of the NES if the savings are 

discounted at rates of 3 percent and 7 percent. 

10-26 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 10.5.6 Compact Refrigerators and Freezers: Cumulative National Energy Savings, 

quads 

Efficiency Level 

(% less than baseline energy use) Compact Refrigerators* Compact Freezers** 

1 (10) 0.13 0.03 

2 (15) 0.20 0.04 

3 (20) 0.27 0.06 

4 (25) 0.32 0.07 

5 (30) 0.38 0.08 

6 (35) 0.44 0.09 

7 (40) 0.48 0.10 

8 (45) 0.52 0.11 

* Includes product classes 11A, 12, 13, 13A, 14, and 15 as well as product class 11 

** Includes product classes 16 and 17 as well as product class 18 

Table 10.5.7 Compact Refrigerators and Freezers: Discounted Cumulative National 

Energy Savings, quads 

Efficiency Level 

(% less than baseline 

energy use) 

Compact Refrigerators* Compact Freezers** 

3% Discount 

Rate 

7% Discount 

Rate 3% Discount Rate 7% Discount Rate 

1 (10) 0.07 0.03 0.02 0.01 

2 (15) 0.11 0.05 0.02 0.01 

3 (20) 0.14 0.07 0.03 0.02 

4 (25) 0.17 0.08 0.04 0.02 

5 (30) 0.21 0.10 0.04 0.02 

6 (35) 0.24 0.12 0.05 0.03 

7 (40) 0.26 0.13 0.06 0.03 

8 (45) 0.28 0.14 0.06 0.03 

* Includes product classes 11A, 12, 13, 13A, 14, and 15 as well as product class 11 

** Includes product classes 16 and 17 as well as product class 18 

10.5.3 Annual Costs and Savings 

Figure 10.5.1 illustrates the basic inputs to the calculation of net present value (NPV) by 

showing the non-discounted annual increases in product cost and annual savings in operating 

cost at the national level for efficiency level 3 for product class 3 (refrigerator-freezers– 

automatic defrost with top-mounted freezer and without through-the-door ice service). The figure 

also shows the net savings, which is the difference between the savings and costs for each year. 

The annual increase in product cost is the total cost for products purchased each year in the 

forecast period. The annual savings in operating cost applies to products operating in each year. 

The NPV is the difference between the cumulative annual discounted savings and cumulative 

10-27 

EERE-2008-BT-STD-0012 COMMENT 22
annual discounted costs. DOE could create figures like Figure 10.5.1 for each of the considered 

efficiency levels for each product class. 

-0.5 

0 

0.5 

1 

1.5 

2 

2.5 

2010 2015 2020 2025 2030 2035 2040 2045 2050 2055 2060 2065 2070 

Billions of 2008 Dollars 

Operating Cost Savings 

Incremental Product Cost 

Net Savings 

Year 

Figure 10.5.1	 Non-Discounted Annual Increases in Installed Cost and Savings 

in Operating Cost for Product Class 3 at Standard Level 3 

10.5.4 Results of Net Present Value Calculations 

This section provides results of calculating net present value (NPV) for the potential 

efficiency standards for the considered refrigeration product classes. Results, which are 

cumulative, are shown as the discounted value of the savings in dollar terms. Results are 

provided for each potential efficiency standard. DOE based the inputs to the NIA model on 

weighted-average values, yielding results that are discrete point values, rather than a distribution 

of values as in the life-cycle cost and payback period analysis. 

The present value of increased total installed cost is the total annual increase in installed 

cost (the difference between the standards case and base case), discounted to the present and 

summed throughout the period for which DOE evaluated the impact of standards. 

Savings are decreases in operating cost associated with the higher energy efficiency of 

products purchased in the standards case compared to the base case. Total savings in operating 

10-28 

EERE-2008-BT-STD-0012 COMMENT 22
 

cost are the savings per unit multiplied by the number of units of each vintage (i.e., year of 

manufacture) that survive in a particular year. For units purchased by 2044, the operating cost 

includes energy consumed until the last unit is retired from service. 

Tables 10.5.8 though 10.5.10 show the NPV associated with the potential standards for 

the considered refrigeration products. Detailed results showing the breakdown of the NPV into 

national installed product cost and operating cost savings are provided in appendix 10-B. As was 

the case with NES results, the results for NPV refer to all the product classes that DOE included 

in each of the seven representative product class categories, not simply to the primary product 

class that accounts for the bulk of shipments in each case. 

Table 10.5.8 Standard-Size Refrigerator-Freezers: Discounted Cumulative Net Present 

Values 

Efficiency 

Level 

(% less 

than 

baseline 

energy use) 

Top-Mount 

Refrigerator-Freezer* 

Bottom-Mount 

Refrigerator-Freezer** 

Side-by-Side 

Refrigerator-Freezer*** 

3% Discount 

Rate 

billion 2008$ 

7% Discount 

Rate 

billion 2008$ 

3% Discount 

Rate 

billion 2008$ 

7% Discount 

Rate 

billion 2008$ 

3% Discount 

Rate 

billion 2008$ 

7% Discount 

Rate 

billion 2008$ 

1 (10) 13.39 5.08 0.50 0.19 3.68 1.35 

2 (15) 20.16 7.60 0.73 0.27 8.52 3.11 

3 (20) 26.57 9.79 2.13 0.70 11.89 3.82 

4 (25) 31.08 11.01 1.98 0.40 14.15 3.94 

5 (30) 33.86 11.35 1.61 0.01 15.12 3.42 

6 (35) 34.26 10.57 1.43 -0.19 16.17 3.20 

7 (40) 32.78 8.75 0.60 -0.91 15.73 2.22 

8 (45) 31.53 7.18 0.40 -1.12 - -

* Includes product classes 1, 1A, 2, 3A, and 6 as well as product class 3. 

** Includes product class 5A as well as product class 5. 

*** Includes product class 4 as well as product class 7. 

10-29 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10.5.9 Standard-Size Freezers: Discounted Cumulative Net Present Values 

Efficiency Level 

(% less than 

baseline energy 

use) 

Upright Freezers* Chest Freezers** 

3% Discount Rate 

billion 2008$ 

7% Discount Rate 

billion 2008$ 

3% Discount Rate 

billion 2008$ 

7% Discount Rate 

billion 2008$ 

1 (10) 4.52 1.59 3.11 1.10 

2 (15) 7.21 2.53 4.78 1.68 

3 (20) 9.92 3.48 6.04 2.03 

4 (25) 12.23 4.23 7.68 2.60 

5 (30) 14.28 4.86 9.14 3.07 

6 (35) 15.82 5.25 9.61 3.06 

7 (40) 16.62 5.29 11.01 3.52 

8 (45) 16.54 4.98 10.51 3.09 

* Includes product class 9 only. 

** Includes product classes 8 and 10A as well as product class 10. 

Table 10.5.10 Compact Refrigerators and Freezers: Discounted Cumulative Net Present 

Values 

Efficiency Level 

(% less than 

baseline energy 

use) 

Compact Refrigerators* Compact Freezers** 

3% Discount Rate 

billion 2008$ 

7% Discount Rate 

billion 2008$ 

3% Discount Rate 

billion 2008$ 

7% Discount Rate 

billion 2008$ 

1 (10) 1.00 0.43 0.20 0.08 

2 (15) 1.39 0.59 0.30 0.12 

3 (20) 1.81 0.76 0.08 0.00 

4 (25) 1.45 0.55 0.10 0.00 

5 (30) 1.97 0.78 0.00 -0.06 

6 (35) 2.12 0.83 0.09 -0.02 

7 (40) 1.72 0.59 0.06 -0.05 

8 (45) 0.92 0.17 0.01 -0.08 

* Includes product classes 11A, 12, 13, 13A, 14, and 15 as well as product class 11. 

** Includes product classes 16 and 17 as well as product class 18. 

10.5.5 Summary of NIA Results 

This section provides NES (undiscounted) and NPV results together for each efficiency 

level considered for the refrigeration product classes. Tables 10.5.11 though 10.5.13 allow the 

reader to see which efficiency levels have the highest energy savings while also having a positive 

NPV. 

10-30 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 10.5.11 Standard-Size Refrigerator-Freezers: NES and NPV Results 

Efficiency 

Level 

(percent 

less than 

baseline 

energy 

use) 

Top-Mount 

Refrigerator-Freezer* 

Bottom-Mount 

Refrigerator-Freezer** 

Side-by-Side 

Refrigerator-Freezer*** 

NES 

(quads) 

NPV @ 

3% 

Discount 

Rate 

(billion 

2008$) 

NPV@ 

7% 

Discount 

Rate 

(billion 

2008$) 

NES 

(quads) 

NPV @ 

3% 

Discount 

Rate 

(billion 

2008$) 

NPV@ 

7% 

Discount 

Rate 

(billion 

2008$) 

NES 

(quads) 

NPV @ 

3% 

Discount 

Rate 

(billion 

2008$) 

NPV@ 

7% 

Discount 

Rate 

(billion 

2008$) 

1 (10%) 1.10 13.39 5.08 0.04 0.50 0.19 0.31 3.68 1.35 

2 (15%) 1.69 20.16 7.60 0.06 0.73 0.27 0.73 8.52 3.11 

3 (20%) 2.35 26.57 9.79 0.20 2.13 0.70 1.31 11.89 3.82 

4 (25%) 3.01 31.08 11.01 0.37 1.98 0.40 1.91 14.15 3.94 

5 (30%) 3.65 33.86 11.35 0.53 1.61 0.01 2.50 15.12 3.42 

6 (35%) 4.20 34.26 10.57 0.57 1.43 -0.19 2.93 16.17 3.20 

7 (40%) 4.78 32.78 8.75 0.73 0.60 -0.91 3.35 15.73 2.22 

8 (45%) 5.28 31.53 7.18 0.77 0.40 -1.12 - - -

* Includes product classes 1, 1A, 2, 3A, and 6 as well as product class 3. 

** Includes product class 5A as well as product class 5. 

*** Includes product class 4 as well as product class 7. 

Table 10.5.12 Standard-Size Freezers: NES and NPV Results 

Efficiency Level 

(percent less 

than baseline 

energy use) 

Upright Freezers* Chest Freezers** 

NES 

(quads) 

NPV @ 3% 

Discount 

Rate 

(billion 

2008$) 

NPV@ 7% 

Discount 

Rate 

(billion 

2008$) 

NES 

(quads) 

NPV @ 3% 

Discount 

Rate 

(billion 

2008$) 

NPV@ 7% 

Discount 

Rate 

(billion 

2008$) 

1 (10%) 0.34 4.52 1.59 0.23 3.11 1.10 

2 (15%) 0.55 7.21 2.53 0.37 4.78 1.68 

3 (20%) 0.75 9.92 3.48 0.50 6.04 2.03 

4 (25%) 0.96 12.23 4.23 0.63 7.68 2.60 

5 (30%) 1.15 14.28 4.86 0.76 9.14 3.07 

6 (35%) 1.34 15.82 5.25 0.87 9.61 3.06 

7 (40%) 1.51 16.62 5.29 1.00 11.01 3.52 

8 (45%) 1.63 16.54 4.98 1.07 10.51 3.09 

* Includes product class 9 only. 

** Includes product classes 8 and 10A as well as product class 10. 

10-31 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10.5.13 Compact Refrigerators and Freezers: NES and NPV Results 

Efficiency 

Level 

(percent less 

than baseline 

energy use) 

Compact Refrigerators* Compact Freezers** 

NES 

(quads) 

NPV @ 3% 

Discount Rate 

(billion 2008$) 

NPV@ 7% 

Discount Rate 

(billion 2008$) 

NES 

(quads) 

NPV @ 3% 

Discount 

Rate 

(billion 

2008$) 

NPV@ 7% 

Discount Rate 

(billion 2008$) 

1 (10%) 0.13 1.00 0.43 0.03 0.20 0.08 

2 (15%) 0.20 1.39 0.59 0.04 0.30 0.12 

3 (20%) 0.27 1.81 0.76 0.06 0.08 0.00 

4 (25%) 0.32 1.45 0.55 0.07 0.10 0.00 

5 (30%) 0.38 1.97 0.78 0.08 0.00 -0.06 

6 (35%) 0.44 2.12 0.83 0.09 0.09 -0.02 

7 (40%) 0.48 1.72 0.59 0.10 0.06 -0.05 

8 (45%) 0.52 0.92 0.17 0.11 0.01 -0.08 

* Includes product classes 11A, 12, 13, 13A, 14, and 15 as well as product class 11. 

** Includes product classes 16 and 17 as well as product class 18. 

10-32 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

REFERENCES 

1	 Association of Home Appliance Manufacturers. Aggregated Refrigerator‐Freezer 

Shipments and Efficiency Data for DOE Refrigerator‐Freezer Energy Efficiency Standards 

Rulemaking, January 16, 2009. Memo to Detlef Westphalen, Navigant Consulting, Inc. 

2	 AHAM. AHAM 2005 Fact Book. 2005. Association of Home Appliance Manufacturers: 

Washington, D.C. 

3	 U.S. Environmental Protection Agency. ENERGY STAR–Refrigerators & Freezers Key 

Product Criteria. 2009. U.S. EPA: Washington, DC. (Last Accessed April 30, 2009.) 

<www.energystar.gov/index.cfm?c=refrig.pr_crit_refrigerators> 

4	 U.S. Department of Energy–Energy Information Administration. Annual Energy Outlook 

2008 with Projections to 2030. February 2008. U.S. DOE–EIA: Washington, D.C. 

DOE/EIA-0383(2008). 

5	 U.S. Department of Energy-Energy Information Administration. An Updated Annual Energy 

Outlook 2009 Reference Case Reflecting Provisions of the American Recovery and 

Reinvestment Act and Recent Changes in the Economic Outlook, April, 2009. Washington, 

DC. SR/OIAF/2009-03. 

<http://www.eia.doe.gov/oiaf/servicerpt/stimulus/pdf/sroiaf(2009)03.pdf> 

6	 Office of Management and Budget. OMB Circular A-4, Regulatory Analysis. 2003. OMB: 

Washington, D.C. September 17, 2003. 

<www.whitehouse.gov/omb/assets/omb/circulars/a004/a-4.pdf> 

10-33 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 10-A. USER INSTRUCTIONS FOR SHIPMENTS AND NIA 

SPREADSHEETS 

TABLE OF CONTENTS 

10-A.1 INTRODUCTION ...............................................................................................10-A-1 

10-A.1.1 Standard-Size Refrigerator-Freezers....................................................................10-A-1 

10-A.1.2 Standard-Size Freezers.........................................................................................10-A-2 

10-A.1.3 Compact Refrigerators.........................................................................................10-A-3 

10-A.1.4 Compact Freezers.................................................................................................10-A-4 

10-A.2 BASIC INSTRUCTIONS....................................................................................10-A-5 

10A-i 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

APPENDIX 10-A. USER INSTRUCTIONS FOR SHIPMENTS AND NIA 

SPREADSHEETS 

10-A.1 INTRODUCTION 

The results obtained for the shipments analysis and the national impact analysis (NIA) 

can be examined and reproduced using the Microsoft Excel spreadsheet available on the U.S. 

Department of Energy Building Technologies website 

at: http://www.eere.energy.gov/buildings/appliance_standards/. 

There are a total of four NIA spreadsheets, one each for the following product types: 

standard-size refrigerator-freezers, standard-size freezers, compact refrigerators, and commercial 

compact freezers. The four spreadsheets posted on the DOE website represent the latest versions 

and have been tested with Microsoft Excel 2003. 

To execute the spreadsheet requires Microsoft Excel 2003 or a later version. The NIA 

spreadsheet performs calculations to forecast the change in national energy use and net present 

value due to an energy conservation standard. The energy use and associated costs for a given 

standard are determined first by calculating the shipments and then calculating the energy use 

and costs for all equipment shipped under that standard. The differences between the standards 

and base cases can then be compared and the overall energy savings and present values 

determined. 

10-A.1.1 Standard-Size Refrigerator-Freezers 

 The standard-size refrigerator-freezer NIA spreadsheet or workbook consists of the 

following worksheets: 

Input and Summary	 Contains user input selections under “User Inputs” and a summary 

table, Cumulative Energy Savings and NPV for the selected 

standard level efficiency distribution. The sheet contains the 

efficiency levels being considered for standard-size refrigeratorfreezers and the associated incremental prices. This sheet also 

contains base and standards case efficiency trends for standard-size 

refrigerator-freezers, and efficiency weighted average energy use 

and equipment price for the base and standards cases. 

Historical Shipment & Contains data for historical sales of standard-size refrigeratorMarket Share freezers by product class. The forecast market share between topmount and side/bottom-mount refrigerator-freezers is provided. 

Base Case	 Contains the calculations for determining the shipments, energy 

consumption, and operating costs for the base case. The sheet starts 

with the stock accounting of the equipment and uses the survival 

10-A-1
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

function to calculate the surviving stock. It then performs 

calculations of replacements, and shipments going into new 

housing. The sheet calculates replacement units, shipments going 

into new units, and early replacement shipments, and aggregates 

them into total shipments. 

Base Energy Calc Contains additional stock accounting calculations to properly 

allocate shipments, energy use, and costs to top-mount and 

side/bottom-mount refrigerator-freezers for the base case. 

Standards Case Contains stock accounting of the equipment that calculates annual 

shipments estimates, energy savings, and operating cost savings for 

the standards case. The energy and cost savings in a single year are 

the difference between the base case energy use and costs and the 

standard case energy use and costs for that year. 

Standards Energy Calc Contains additional stock accounting calculations to properly 

allocate shipments, energy use, and costs to top-mount and 

side/bottom-mount refrigerator-freezers for the standards case. 

Housing Projections Contains the projected new housing construction starts and total 

housing stock for the three economic scenarios (Reference, Low 

Growth, and High Growth). Also provides the early replacement 

rate. 

Fuel Prices Contains projected average energy prices for the three economic 

scenarios. 

Heat Rates Contains the marginal site to source conversion factors that are 

used in the source energy savings calculations, for both electricity 

and gas. 

Lifetime Contains the probability of survival of a standard-size refrigeratorfreezer at a given age and the average lifetime of a unit. 

10-A.1.2 Standard-Size Freezers 

The standard-size freezer NIA spreadsheet or workbook consists of the following 

worksheets: 

Input and Summary	 Contains user input selections under “User Inputs” and a summary 

table, Cumulative Energy Savings and NPV for the selected 

standard level efficiency distribution. The sheet contains the 

efficiency levels being considered for standard-size freezers and 

the associated incremental prices. This sheet also contains base 

10-A-2
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

and standards case efficiency trends for standard-size freezers, and 

efficiency weighted average energy use and equipment price for 

the base and standards cases. 

Historical Shipment Contains data for historical sales of standard-size freezers by 

product class. 

Base Case Contains the calculations for determining the shipments, energy 

consumption, and operating costs for the base case. The sheet starts 

with the stock accounting of the equipment and uses the survival 

function to calculate the surviving stock. It then performs 

calculations of replacements, and shipments going into new 

housing. The sheet calculates replacement units, shipments going 

into new units, and shipments going to first time owners (existing 

households that do not already own the product), and aggregates 

them into total shipments. 

Standards Case Contains stock accounting of the equipment that calculates annual 

shipments estimates, energy savings, and operating cost savings for 

the standards case. The energy and cost savings in a single year are 

the difference between the base case energy use and costs and the 

standard case energy use and costs for that year. 

Housing Projections Contains the projected new housing construction starts and total 

housing stock for the three economic scenarios (Reference, Low 

Growth, and High Growth). Also provides the early replacement 

rate. 

Fuel Prices Contains projected average energy prices for the three economic 

scenarios. 

Heat Rates Contains the marginal site to source conversion factors that are 

used in the source energy savings calculations, for both electricity 

and gas. 

Lifetime Contains the probability of survival of a standard-size refrigeratorfreezer at a given age and the average lifetime of a unit. 

10-A.1.3 Compact Refrigerators 

The compact refrigerator NIA spreadsheet or workbook consists of the following 

worksheets: 

Input and Summary	 Contains user input selections under “User Inputs” and a summary 

table, Cumulative Energy Savings and NPV for the selected 

10-A-3
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

standard level efficiency distribution. The sheet contains the 

efficiency levels being considered for compact refrigerators and 

the associated incremental prices. This sheet also contains base 

and standards case efficiency trends for compact refrigerators, and 

efficiency weighted average energy use and equipment price for 

the base and standards cases. 

Historical Shipment Contains data for historical sales of compact refrigerators by 

product class. Also provides historical saturations of compact 

refrigerators in lodging, residential, and commercial buildings. 

Base Case Contains the calculations for determining the shipments, energy 

consumption, and operating costs for the base case. The sheet starts 

with the stock accounting of the equipment and uses the survival 

function to calculate the surviving stock. It then performs 

calculations of replacements, and shipments going into new 

housing, new lodging, and new commercial buildings, and 

aggregates them into total shipments. 

Standards Case Contains stock accounting of the equipment that calculates annual 

shipments estimates, energy savings, and operating cost savings for 

the standards case. The energy and cost savings in a single year are 

the difference between the base case energy use and costs and the 

standard case energy use and costs for that year. 

Housing & Comm Flrspc 

Project 

Contains the projected new housing construction starts, total 

housing stock, projected new commercial floorspace projections, 

and total lodging and commercial floorspace stock for the three 

economic scenarios (Reference, Low Growth, and High Growth). 

Fuel Prices Contains projected average energy prices for the three economic 

scenarios. 

Heat Rates Contains the marginal site to source conversion factors that are 

used in the source energy savings calculations, for both electricity 

and gas. 

Lifetime Contains the probability of survival of a standard-size refrigeratorfreezer at a given age and the average lifetime of a unit. 

10-A.1.4 Compact Freezers 

The compact freezer NIA spreadsheet or workbook consists of the following worksheets: 

10-A-4
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

Input and Summary Contains user input selections under “User Inputs” and a summary 

table, Cumulative Energy Savings and NPV for the selected 

standard level efficiency distribution. The sheet contains the 

efficiency levels being considered for compact freezers and the 

associated incremental prices. This sheet also contains base and 

standards case efficiency trends for compact freezers, and 

efficiency weighted average energy use and equipment price for 

the base and standards cases. 

Historical Shipment Contains data for historical sales of compact freezers by product 

class. 

Base Case Contains the calculations for determining the shipments, energy 

consumption, and operating costs for the base case. The sheet starts 

with the stock accounting of the equipment and uses the survival 

function to calculate the surviving stock. It then performs 

calculations of replacements, and shipments going to first time 

owners (existing households that do not already own the product), 

and aggregates them into total shipments. 

Standards Case Contains stock accounting of the equipment that calculates annual 

shipments estimates, energy savings, and operating cost savings for 

the standards case. The energy and cost savings in a single year are 

the difference between the base case energy use and costs and the 

standard case energy use and costs for that year. 

Housing Projections Contains the projected new housing construction starts and total 

housing stock for the three economic scenarios (Reference, Low 

Growth, and High Growth). Housing data used solely to determine 

a compact freezer saturation in new housing. 

Fuel Prices Contains projected average energy prices for the three economic 

scenarios. 

Heat Rates Contains the marginal site to source conversion factors that are 

used in the source energy savings calculations, for both electricity 

and gas. 

Lifetime Contains the probability of survival of a standard-size refrigeratorfreezer at a given age and the average lifetime of a unit. 

10-A.2 BASIC INSTRUCTIONS 

Basic instructions for operating the NIA spreadsheets are as follows: 

10-A-5
 

EERE-2008-BT-STD-0012 COMMENT 22
1.	 Once the NIA spreadsheets have been downloaded from the Web, open the file using 

Excel. At the bottom, click on the tab for the worksheet ‘Input and Summary’. 

2.	 Use Excel’s View/Zoom commands at the top menu bar to change the size of the display 

to make it fit your monitor. 

3.	 The user can change the model parameters listed in the grey box labelled “User Inputs”. 

The parameters are: 

a.	 Lifetime: To change value, type in the desired value that lies within the maximum 

lifetime indicated. 

b.	 Discounting future values: To change the value used for discounting NPV and 

national energy savings, and the year in which to discount to. 

c.	 Relative Price Elasticity: To change value, use the drop-down arrow and select 

the desired impact (this parameter is not considered in the cooking products 

analysis). 

d.	 Economic Growth: To the change value, use the drop-down arrow and select the 

desired Growth level (Reference, Low, or High). 

4.	 Once the parameters have been set, there are two options; 

a.	 Click the “Select CSL’ button to choose which candidate standard level to 

analyze. The associated efficiency distributions and growth trends are fixed as 

specified in Chapter 10 of this preliminary technical support document. Once the 

CSL has been selected, click the “OK” button to make your selected CSL 

effective. (This option is not available for compact freezers.) 

b.	 Click the “Set base case/Standards Case” button and define the efficiency 

distribution of the market, and the efficiency growth rate for both the base case 

and the standards case. Once the distribution and the growth rate have been set, 

click the “update” button to make your defined distribution effective. 

5.	 The results are automatically updated and are reported in the summary table for each 

product class to the right of the “User Inputs” box. 

10-A-6
 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 10-B. NATIONAL EQ UIPMENT AND OPERATING COSTS 

TABLE OF CONTENTS 

10-B.1 INTRODUCTION ............................................................................................... 10-B-1 

10-B.2 RESULTS ............................................................................................................ 10-B-2 

10-B.2.1 Standard-Size Refrigerator-Freezers.................................................................... 10-B-2 

10-B.2.2 Standard-Size Freezers......................................................................................... 10-B-8 

10-B.2.3 Compact Refrigerators....................................................................................... 10-B-12 

10-B.2.4 Compact Freezers............................................................................................... 10-B-14
 

LIST OF TABLES 

Table 10-B.2.1 Standard-Size Refrigerator-Freezers, Top-Mount Product Classes: 

Cumulative National Equipment and Operating Costs with NPV from 

2014–2044, Seven-Percent Discount Rate (billion 2008$)...................... 10-B-3 

Table 10-B.2.2 Standard-Size Refrigerator-Freezers, Top-Mount Product Classes: 

Cumulative National Equipment and Operating Costs with NPV from 

2014–2044, Three-Percent Discount Rate (billion 2008$)...................... 10-B-4 

Table 10-B.2.3 Standard-Size Refrigerator-Freezers, Bottom-Mount Product Classes: 

Cumulative National Equipment and Operating Costs with NPV from 

2014–2044, Seven-Percent Discount Rate (billion 2008$)...................... 10-B-5 

Table 10-B.2.4 Standard-Size Refrigerator-Freezers, Bottom-Mount Product Classes: 

Cumulative National Equipment and Operating Costs with NPV from 

2014–2044, Three-Percent Discount Rate (billion 2008$)...................... 10-B-6 

Table 10-B.2.5 Standard-Size Refrigerator-Freezers, Side-Mount Product Classes: 

Cumulative National Equipment and Operating Costs with NPV from 

2014–2044, Seven-Percent Discount Rate (billion 2008$)...................... 10-B-7 

Table 10-B.2.6 Standard-Size Refrigerator-Freezers, Side-Mount Product Classes: 

Cumulative National Equipment and Operating Costs with NPV from 

2014–2044, Three-Percent Discount Rate (billion 2008$)...................... 10-B-8 

Table 10-B.2.7 Standard-Size Freezers, Upright Product Class: Cumulative National 

Equipment and Operating Costs with NPV from 2014–2044, SevenPercent Discount Rate (billion 2008$)..................................................... 10-B-9 

Table 10-B.2.8 Standard-Size Freezers, Upright Product Class: Cumulative National 

Equipment and Operating Costs with NPV from 2014–2044, ThreePercent Discount Rate (billion 2008$)................................................... 10-B-10 

Table 10-B.2.9 Standard-Size Freezers, Chest Product Classes: Cumulative National 

Equipment and Operating Costs with NPV from 2014–2044, SevenPercent Discount Rate (billion 2008$)................................................... 10-B-11 

Table 10-B.2.10 Standard-Size Freezers, Chest Product Classes: Cumulative National 

Equipment and Operating Costs with NPV from 2014–2044, ThreePercent Discount Rate (billion 2008$)................................................... 10-B-12 

10-B-i 

EERE-2008-BT-STD-0012 COMMENT 22
Table 10-B.2.11 Compact Refrigerators: Cumulative National Equipment and 

Operating Costs with NPV from 2014–2044, Seven-Percent Discount 

Rate (billion 2008$) ............................................................................... 10-B-13 

Table 10-B.2.12 Compact Refrigerators: Cumulative National Equipment and 

Operating Costs with NPV from 2014–2044, Three-Percent Discount 

Rate (billion 2008$) ............................................................................... 10-B-14 

Table 10-B.2.13 Compact Freezers: Cumulative National Equipment and Operating 

Costs with NPV from 2014–2044, Seven-Percent Discount Rate 

(billion 2008$) ....................................................................................... 10-B-15 

Table 10-B.2.14 Compact Freezers: Cumulative National Equipment and Operating 

Costs with NPV from 2014–2044, Three-Percent Discount Rate 

(billion 2008$) ....................................................................................... 10-B-16 

10-B-ii 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

APPENDIX 10-B. NATIONAL EQUIPMENT AND OPERATING COSTS 

10-B.1 INTRODUCTION 

In this appendix, the Department presents the components of the net present value (NPV), 

namely, the present value of the equipment (or total installed costs) and the present value of the 

operating costs for each of the four residential refrigerator-freezer product types. The present 

value of equipment costs is also termed the cumulative national equipment costs while the 

present value of operating costs is also termed the cumulative national operating costs. 

As presented in Chapter 10, National Impact Analysis, the NPV is described by the 

equation: 

_ NPV = PVS PVC 

where: 

PVS = Present value of operating cost savings (including energy, water, repair, and 

maintenance costs) and 

PVC = Present value of increased total installed costs (including equipment and 

installation). 

The PVS and PVC are determined according to the following expressions: 

PVS = ∑OCSy × DFy 

PVC = ∑TICy × DFy 

where: 

OCS = Total annual operating cost savings each year summed over vintages of the 

product stock, 

TIC = Total annual installed cost increases each year summed over vintages of the 

product stock, 

DF = Discount factor in each year, and 

y = Year in the forecast (i.e., 2012 to 2042). 

PVS and PVC are determined for each year from the effective date of the standard to the year 

when units purchased in 2042 retire. 

The present value of operating costs and the present value of equipment costs (or total 

installed costs) are the components comprising the PVS and PVC, respectively. The PVS is 

10-B-1
 

EERE-2008-BT-STD-0012 COMMENT 22
 

determined by taking the difference between the present value of operating costs for the base 

case and the present value of operating costs for the standards case. The PVC is determined by 

taking the difference between the present value of equipment costs for the base case and the 

present value of equipment costs for the standards case. 

10-B.2 RESULTS 

For following sections provide tables showing the present value of operating costs (also 

known as the cumulative national operating costs) and the present value of equipment costs (also 

known as the cumulative national equipment costs) each of the four appliance products. For 

each product, two sets of results are presented; one based on a seven-percent and another based 

on a three-percent discount rate. 

In the tables provided in the following sections, the national operating and equipment 

costs are presented for the base case (i.e., without standards) and each standard level analyzed. 

Differences between the base case and standards cases are also presented. The difference in the 

national equipment costs represents the PVC or present value of equipment cost increases while 

the difference in the national operating costs represents the PVS or present value of operating 

cost savings. The difference between the base case and standards case total national equipment 

and operating costs represents the NPV. 

10-B.2.1 Standard-Size Refrigerator-Freezers 

Tables 10B.2.1–10B.2.6 present the national equipment and operating costs, PVC, PVS, 

and NPV for standard-size refrigerator-freezers at real discount rates of seven- and three-percent, 

respectively. 

All base case values were determined with shipments projections established under the 

standards case. As detailed in Chapter 9, shipments projections under the standards cases were 

determined to be lower than those in the base case projection due to the higher installed cost of 

the more efficient equipment. As a result, DOE used the standards case shipments projection 

and, in turn, the standards case equipment stock, to determine the NPV to avoid the inclusion of 

savings due to displaced shipments. Thus, the base case values shown in Tables 10B.2.1–10B.2.6 

vary with the standards case. 

DOE studied seven three product classes in detail for standard-size refrigerator-freezers. 

For the National Impact Analysis, each of these classes represents a product category which also 

contains other product classes. For standard-size refrigerator-freezers, the following list indicates 

which product classes are associated with each product category: 

•	 Top-mount refrigerator-freezers: product classes 1, 1A, 2, 3, 3A, and 6; represented 

by product class 3. 

•	 Bottom-mount refrigerator-freezers: product classes 5 and 5A; represented by product 

class 5. 

10-B-2
 

EERE-2008-BT-STD-0012 COMMENT 22
 

•	 Side-by-side refrigerator-freezers: product classes 4 and 7; represented by product 

class 7. 

Table 10-B.2.1	 Standard-Size Refrigerator-Freezers, Top-Mount Product Classes: 

Cumulative National Equipment and Operating Costs with NPV from 

2014–2044, Seven-Percent Discount Rate (billion 2008$) 

Standard Level Equipment Operating Total 

Base Case 46.62 101.53 148.15 

Standard Level 1 46.89 96.18 143.07 

Difference* -0.27 5.36 5.08 

Base Case 46.56 101.46 148.03 

Standard Level 2 47.19 93.24 140.43 

Difference* -0.62 8.22 7.60 

Base Case 46.42 101.26 147.68 

Standard Level 3 48.03 89.86 137.89 

Difference* -1.61 11.40 9.79 

Base Case 46.11 100.85 146.96 

Standard Level 4 49.72 86.24 135.95 

Difference* -3.60 14.61 11.01 

Base Case 45.68 100.26 145.93 

Standard Level 5 52.06 82.53 134.59 

Difference* -6.38 17.73 11.35 

Base Case 45.10 99.49 144.59 

Standard Level 6 54.92 79.10 134.02 

Difference* -9.82 20.39 10.57 

Base Case 44.32 98.43 142.75 

Standard Level 7 58.77 75.23 134.00 

Difference* -14.45 23.20 8.75 

Base Case 43.61 97.47 141.08 

Standard Level 8 62.04 71.86 133.89 

Difference* -18.43 25.61 7.18 

* Equipment Cost Difference represents the PVC; Operating Cost Difference represents the PVC; NPV is 

represented by the bold and italicized values. 

10-B-3
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10-B.2.2 Standard-Size Refrigerator-Freezers, Top-Mount Product Classes: 

Cumulative National Equipment and Operating Costs with NPV from 

2014–2044, Three-Percent Discount Rate (billion 2008$) 

Standard Level Equipment Operating Total 

Base Case 88.80 223.02 311.83 

Standard Level 1 89.32 209.12 298.44 

Difference* -0.52 13.91 13.39 

Base Case 88.71 222.85 311.57 

Standard Level 2 89.90 201.51 291.40 

Difference* -1.18 21.35 20.16 

Base Case 88.45 222.37 310.81 

Standard Level 3 91.57 192.68 284.24 

Difference* -3.12 29.69 26.57 

Base Case 87.91 221.37 309.27 

Standard Level 4 94.86 183.33 278.19 

Difference* -6.96 38.04 31.08 

Base Case 87.14 219.95 307.08 

Standard Level 5 99.45 173.78 273.22 

Difference* -12.31 46.17 33.86 

Base Case 86.15 218.14 304.29 

Standard Level 6 104.96 165.07 270.03 

Difference* -18.80 53.06 34.26 

Base Case 84.79 215.63 300.42 

Standard Level 7 112.48 155.16 267.64 

Difference* -27.69 60.47 32.78 

Base Case 83.57 213.38 296.95 

Standard Level 8 118.84 146.58 265.42 

Difference* -35.27 66.80 31.53 

* Equipment Cost Difference represents the PVC; Operating Cost Difference represents the PVC; NPV is 

represented by the bold and italicized values. 

10-B-4
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10-B.2.3 Standard-Size Refrigerator-Freezers, Bottom-Mount Product Classes: 

Cumulative National Equipment and Operating Costs with NPV from 

2014–2044, Seven-Percent Discount Rate (billion 2008$) 

Standard Level Equipment Operating Total 

Base Case 31.06 17.30 48.36 

Standard Level 1 31.06 17.11 48.17 

Difference* 0.00 0.19 0.19 

Base Case 31.06 17.30 48.36 

Standard Level 2 31.07 17.01 48.08 

Difference* -0.02 0.29 0.27 

Base Case 31.03 17.29 48.31 

Standard Level 3 31.27 16.34 47.61 

Difference* -0.24 0.95 0.70 

Base Case 30.88 17.22 48.10 

Standard Level 4 32.22 15.48 47.70 

Difference* -1.34 1.75 0.40 

Base Case 30.72 17.16 47.88 

Standard Level 5 33.25 14.62 47.87 

Difference* -2.53 2.54 0.01 

Base Case 30.63 17.12 47.74 

Standard Level 6 33.59 14.35 47.94 

Difference* -2.97 2.77 -0.19 

Base Case 30.39 17.02 47.41 

Standard Level 7 34.84 13.48 48.32 

Difference* -4.45 3.54 -0.91 

Base Case 30.29 16.98 47.27 

Standard Level 8 35.18 13.21 48.40 

Difference* -4.89 3.77 -1.12 

* Equipment Cost Difference represents the PVC; Operating Cost Difference represents the PVC; NPV is 

represented by the bold and italicized values. 

10-B-5
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10-B.2.4 Standard-Size Refrigerator-Freezers, Bottom-Mount Product Classes: 

Cumulative National Equipment and Operating Costs with NPV from 

2014–2044, Three-Percent Discount Rate (billion 2008$) 

Standard Level Equipment Operating Total 

Base Case 60.30 40.68 100.98 

Standard Level 1 60.31 40.17 100.48 

Difference* -0.01 0.51 0.50 

Base Case 60.30 40.68 100.97 

Standard Level 2 60.33 39.92 100.24 

Difference* -0.03 0.76 0.73 

Base Case 60.24 40.64 100.88 

Standard Level 3 60.75 38.01 98.75 

Difference* -0.51 2.64 2.13 

Base Case 59.95 40.48 100.43 

Standard Level 4 62.72 35.73 98.45 

Difference* -2.77 4.75 1.98 

Base Case 59.63 40.30 99.93 

Standard Level 5 64.86 33.46 98.32 

Difference* -5.23 6.84 1.61 

Base Case 59.50 40.23 99.73 

Standard Level 6 65.41 32.89 98.30 

Difference* -5.91 7.34 1.43 

Base Case 59.08 40.00 99.08 

Standard Level 7 67.86 30.61 98.47 

Difference* -8.78 9.38 0.60 

Base Case 58.94 39.92 98.86 

Standard Level 8 68.41 30.06 98.47 

Difference* -9.47 9.86 0.40 

* Equipment Cost Difference represents the PVC; Operating Cost Difference represents the PVC; NPV is 

represented by the bold and italicized values. 

10-B-6
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10-B.2.5 Standard-Size Refrigerator-Freezers, Side-Mount Product Classes: 

Cumulative National Equipment and Operating Costs with NPV from 

2014–2044, Seven-Percent Discount Rate (billion 2008$) 

Standard Level Equipment Operating Total 

Base Case 63.01 81.15 144.17 

Standard Level 1 63.16 79.65 142.81 

Difference* -0.15 1.50 1.35 

Base Case 62.97 81.12 144.09 

Standard Level 2 63.40 77.58 140.98 

Difference* -0.43 3.53 3.11 

Base Case 62.68 80.87 143.55 

Standard Level 3 65.16 74.57 139.73 

Difference* -2.48 6.30 3.82 

Base Case 62.25 80.52 142.77 

Standard Level 4 67.53 71.30 138.83 

Difference* -5.28 9.22 3.94 

Base Case 61.72 80.08 141.81 

Standard Level 5 70.39 68.00 138.39 

Difference* -8.67 12.08 3.42 

Base Case 61.33 79.76 141.09 

Standard Level 6 72.31 65.58 137.89 

Difference* -10.98 14.18 3.20 

Base Case 60.81 79.33 140.15 

Standard Level 7 74.82 63.11 137.93 

Difference* -14.00 16.22 2.22 

* Equipment Cost Difference represents the PVC; Operating Cost Difference represents the PVC; NPV is 

represented by the bold and italicized values. 

10-B-7
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10-B.2.6 Standard-Size Refrigerator-Freezers, Side-Mount Product Classes: 

Cumulative National Equipment and Operating Costs with NPV from 

2014–2044, Three-Percent Discount Rate (billion 2008$) 

Standard Level Equipment Operating Total 

Base Case 122.36 182.70 305.06 

Standard Level 1 122.64 178.74 301.38 

Difference* -0.29 3.96 3.68 

Base Case 122.28 182.62 304.90 

Standard Level 2 123.11 173.27 296.38 

Difference* -0.83 9.35 8.52 

Base Case 121.74 182.00 303.73 

Standard Level 3 126.69 165.15 291.84 

Difference* -4.96 16.84 11.89 

Base Case 120.97 181.13 302.09 

Standard Level 4 131.39 156.55 287.94 

Difference* -10.43 24.58 14.15 

Base Case 120.02 180.06 300.09 

Standard Level 5 137.07 147.90 284.97 

Difference* -17.05 32.17 15.12 

Base Case 119.36 179.31 298.67 

Standard Level 6 140.78 141.72 282.50 

Difference* -21.42 37.59 16.17 

Base Case 118.47 178.32 296.79 

Standard Level 7 145.61 135.45 281.06 

Difference* -27.14 42.87 15.73 

* Equipment Cost Difference represents the PVC; Operating Cost Difference represents the PVC; NPV is 

represented by the bold and italicized values. 

10-B.2.2 Standard-Size Freezers 

Tables 10B.2.7–10B.2.10 present the national equipment and operating costs, PVC, PVS, 

and NPV for standard-size freezers at real discount rates of seven- and three-percent, 

respectively. 

All base case values were determined with shipments projections established under the 

standards case. As detailed in Chapter 9, shipments projections under the standards cases were 

determined to be lower than those in the base case projection due to the higher installed cost of 

the more efficient equipment. As a result, DOE used the standards case shipments projection 

and, in turn, the standards case equipment stock, to determine the NPV to avoid the inclusion of 

savings due to displaced shipments. Thus, the base case values shown in Tables 10B.2.7– 

10B.2.10 vary with the standards case. 

10-B-8
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Throughout its analysis, DOE studied two product classes in detail for standard-size 

freezers. For the National Impact Analysis, each of these classes represents a product category 

which also contains other product classes. For standard-size freezers, the following list indicates 

which product classes are associated with each product category: 

• Upright freezers: product class 9 only. 

• Chest freezers: product classes 8a, 10, and 10A; represented by product class 10. 

Table 10-B.2.7 Standard-Size Freezers, Upright Product Class: Cumulative National 

Equipment and Operating Costs with NPV from 2014–2044, Seven-Percent 

Discount Rate (billion 2008$) 

Standard Level Equipment Operating Total 

Base Case 7.01 34.32 41.33 

Standard Level 1 7.09 32.65 39.74 

Difference* -0.09 1.68 1.59 

Base Case 6.99 34.29 41.28 

Standard Level 2 7.16 31.59 38.75 

Difference* -0.17 2.70 2.53 

Base Case 6.98 34.26 41.24 

Standard Level 3 7.21 30.54 37.76 

Difference* -0.23 3.71 3.48 

Base Case 6.94 34.13 41.07 

Standard Level 4 7.42 29.43 36.84 

Difference* -0.48 4.71 4.23 

Base Case 6.88 33.96 40.84 

Standard Level 5 7.70 28.28 35.98 

Difference* -0.82 5.68 4.86 

Base Case 6.78 33.69 40.47 

Standard Level 6 8.13 27.09 35.22 

Difference* -1.34 6.60 5.25 

Base Case 6.63 33.26 39.90 

Standard Level 7 8.77 25.83 34.61 

Difference* -2.14 7.43 5.29 

Base Case 6.44 32.72 39.17 

Standard Level 8 9.49 24.70 34.19 

Difference* -3.05 8.03 4.98 

* Equipment Cost Difference represents the PVC; Operating Cost Difference represents the PVC; NPV is 

represented by the bold and italicized values. 

a

 Product class 8, “upright freezers with manual defrost” is analyzed as part of the “chest freezer” category because 

products in this class are much more technologically similar to chest freezers. 

10-B-9 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10-B.2.8 Standard-Size Freezers, Upright Product Class: Cumulative National 

Equipment and Operating Costs with NPV from 2014–2044, Three-Percent 

Discount Rate (billion 2008$) 

Standard Level Equipment Operating Total 

Base Case 13.45 78.49 91.94 

Standard Level 1 13.62 73.80 87.42 

Difference* -0.17 4.69 4.52 

Base Case 13.43 78.38 91.81 

Standard Level 2 13.74 70.86 84.60 

Difference* -0.32 7.53 7.21 

Base Case 13.41 78.30 91.71 

Standard Level 3 13.85 67.93 81.78 

Difference* -0.45 10.37 9.92 

Base Case 13.32 77.96 91.29 

Standard Level 4 14.24 64.81 79.06 

Difference* -0.92 13.15 12.23 

Base Case 13.21 77.49 90.69 

Standard Level 5 14.79 61.63 76.42 

Difference* -1.58 15.86 14.28 

Base Case 13.03 76.73 89.76 

Standard Level 6 15.63 58.31 73.93 

Difference* -2.60 18.42 15.82 

Base Case 12.75 75.56 88.30 

Standard Level 7 16.88 54.81 71.69 

Difference* -4.13 20.75 16.62 

Base Case 12.39 74.10 86.49 

Standard Level 8 18.26 51.69 69.95 

Difference* -5.86 22.41 16.54 

* Equipment Cost Difference represents the PVC; Operating Cost Difference represents the PVC; NPV is 

represented by the bold and italicized values. 

10-B-10
 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10-B.2.9 Standard-Size Freezers, Chest Product Classes: Cumulative National 

Equipment and Operating Costs with NPV from 2014–2044, Seven-Percent 

Discount Rate (billion 2008$) 

Standard Level Equipment Operating Total 

Base Case 4.65 22.50 27.15 

Standard Level 1 4.69 21.36 26.05 

Difference* -0.03 1.14 1.10 

Base Case 4.64 22.46 27.09 

Standard Level 2 4.77 20.65 25.42 

Difference* -0.13 1.80 1.68 

Base Case 4.59 22.31 26.90 

Standard Level 3 5.00 19.87 24.86 

Difference* -0.41 2.44 2.03 

Base Case 4.57 22.27 26.84 

Standard Level 4 5.07 19.17 24.24 

Difference* -0.50 3.10 2.60 

Base Case 4.54 22.19 26.74 

Standard Level 5 5.20 18.46 23.66 

Difference* -0.66 3.73 3.07 

Base Case 4.43 21.88 26.32 

Standard Level 6 5.66 17.60 23.26 

Difference* -1.23 4.29 3.06 

Base Case 4.41 21.81 26.22 

Standard Level 7 5.79 16.91 22.71 

Difference* -1.38 4.90 3.52 

Base Case 4.25 21.35 25.60 

Standard Level 8 6.41 16.10 22.51 

Difference* -2.17 5.26 3.09 

* Equipment Cost Difference represents the PVC; Operating Cost Difference represents the PVC; NPV is 

represented by the bold and italicized values. 

10-B-11
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 10-B.2.10Standard-Size Freezers, Chest Product Classes: Cumulative National 

Equipment and Operating Costs with NPV from 2014–2044, Three-Percent 

Discount Rate (billion 2008$) 

Standard Level Equipment Operating Total 

Base Case 8.93 51.47 60.40 

Standard Level 1 9.00 48.29 57.29 

Difference* -0.07 3.18 3.11 

Base Case 8.90 51.34 60.25 

Standard Level 2 9.16 46.31 55.47 

Difference* -0.25 5.03 4.78 

Base Case 8.81 50.95 59.76 

Standard Level 3 9.60 44.12 53.72 

Difference* -0.79 6.83 6.04 

Base Case 8.78 50.83 59.61 

Standard Level 4 9.74 42.19 51.92 

Difference* -0.96 8.64 7.68 

Base Case 8.73 50.61 59.34 

Standard Level 5 10.01 40.19 50.19 

Difference* -1.28 10.42 9.14 

Base Case 8.52 49.77 58.30 

Standard Level 6 10.88 37.80 48.69 

Difference* -2.36 11.97 9.61 

Base Case 8.47 49.57 58.04 

Standard Level 7 11.14 35.89 47.03 

Difference* -2.67 13.68 11.01 

Base Case 8.17 48.32 56.49 

Standard Level 8 12.34 33.64 45.98 

Difference* -4.17 14.68 10.51 

* Equipment Cost Difference represents the PVC; Operating Cost Difference represents the PVC; NPV is 

represented by the bold and italicized values. 

10-B.2.3 Compact Refrigerators 

Tables 10B.2.11 and 10B.2.12 present the national equipment and operating costs, PVC, 

PVS, and NPV for compact refrigerators at real discount rates of seven- and three-percent, 

respectively. 

All base case values were determined with shipments projections established under the 

standards case. As detailed in Chapter 9, shipments projections under the standards cases were 

determined to be lower than those in the base case projection due to the higher installed cost of 

the more efficient equipment. As a result, DOE used the standards case shipments projection 

and, in turn, the standards case equipment stock, to determine the NPV to avoid the inclusion of 

10-B-12
 

EERE-2008-BT-STD-0012 COMMENT 22
 

savings due to displaced shipments. Thus, the base case values shown in Tables 10B.2.11 and 

10B.2.12 vary with the standards case. 

Throughout its analysis, DOE studied one product class in detail for compact 

refrigerators. For the National Impact Analysis, this class represents a product category which 

also contains other product classes. For compact refrigerators, the following indicates which 

product classes are associated with the product category: 

•	 Compact refrigerators: product classes 11, 11A, 12, 13, 13A, 14, and 15; represented 

by product class 11. 

Table 10-B.2.11Compact Refrigerators: Cumulative National Equipment and Operating 

Costs with NPV from 2014–2044, Seven-Percent Discount Rate (billion 

2008$) 

Standard Level Equipment Operating Total 

Base Case 5.54 6.65 12.19 

Standard Level 1 5.68 6.09 11.76 

Difference* -0.14 0.56 0.43 

Base Case 5.50 6.60 12.10 

Standard Level 2 5.75 5.76 11.51 

Difference* -0.25 0.84 0.59 

Base Case 5.46 6.56 12.02 

Standard Level 3 5.82 5.44 11.25 

Difference* -0.36 1.12 0.76 

Base Case 5.28 6.37 11.65 

Standard Level 4 6.09 5.01 11.10 

Difference* -0.81 1.36 0.55 

Base Case 5.27 6.36 11.62 

Standard Level 5 6.11 4.73 10.85 

Difference* -0.85 1.62 0.78 

Base Case 5.19 6.27 11.46 

Standard Level 6 6.23 4.40 10.64 

Difference* -1.04 1.87 0.83 

Base Case 5.01 6.09 11.09 

Standard Level 7 6.47 4.03 10.50 

Difference* -1.47 2.06 0.59 

Base Case 4.75 5.82 10.58 

Standard Level 8 6.78 3.62 10.41 

Difference* -2.03 2.20 0.17 

* Equipment Cost Difference represents the PVC; Operating Cost Difference represents the PVC; NPV is 

represented by the bold and italicized values. 

10-B-13 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

Table 10-B.2.12Compact Refrigerators: Cumulative National Equipment and Operating 

Costs with NPV from 2014–2044, Three-Percent Discount Rate (billion 

2008$) 

Standard Level Equipment Operating Total 

Base Case 10.95 14.10 25.05 

Standard Level 1 11.22 12.83 24.06 

Difference* -0.27 1.26 1.00 

Base Case 10.86 13.98 24.84 

Standard Level 2 11.36 12.09 23.45 

Difference* -0.50 1.89 1.39 

Base Case 10.78 13.88 24.66 

Standard Level 3 11.48 11.37 22.85 

Difference* -0.71 2.52 1.81 

Base Case 10.40 13.44 23.84 

Standard Level 4 12.00 10.39 22.39 

Difference* -1.59 3.04 1.45 

Base Case 10.37 13.40 23.77 

Standard Level 5 12.04 9.76 21.80 

Difference* -1.67 3.64 1.97 

Base Case 10.20 13.20 23.40 

Standard Level 6 12.26 9.01 21.28 

Difference* -2.06 4.18 2.12 

Base Case 9.83 12.75 22.58 

Standard Level 7 12.71 8.15 20.86 

Difference* -2.88 4.60 1.72 

Base Case 9.30 12.12 21.42 

Standard Level 8 13.27 7.24 20.51 

Difference* -3.97 4.89 0.92 

* Equipment Cost Difference represents the PVC; Operating Cost Difference represents the PVC; NPV is 

represented by the bold and italicized values. 

10-B.2.4 Compact Freezers 

Tables 10B.2.13 and 10B.2.14 present the national equipment and operating costs, PVC, 

PVS, and NPV for compact freezers at real discount rates of seven- and three-percent, 

respectively. 

All base case values were determined with shipments projections established under the 

standards case. As detailed in Chapter 9, shipments projections under the standards cases were 

determined to be lower than those in the base case projection due to the higher installed cost of 

the more efficient equipment. As a result, DOE used the standards case shipments projection 

and, in turn, the standards case equipment stock, to determine the NPV to avoid the inclusion of 

10-B-14
 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

savings due to displaced shipments. Thus, the base case values shown in Tables 10B.2.13 and 

10B.2.14 vary with the standards case. 

Throughout its analysis, DOE studied one product class in detail for compact freezers. 

For the National Impact Analysis, this class represents a product category which also contains 

other product classes. For compact freezers, the following indicates which product classes are 

associated with the product category: 

• Compact freezers: product classes 16, 17, and 18; represented by product class 18. 

Table 10-B.2.13Compact Freezers: Cumulative National Equipment and Operating Costs 

with NPV from 2014–2044, Seven-Percent Discount Rate (billion 2008$) 

Standard Level Equipment Operating Total 

Base Case 1.31 1.70 3.01 

Standard Level 1 1.36 1.57 2.93 

Difference* -0.05 0.13 0.08 

Base Case 1.30 1.69 2.99 

Standard Level 2 1.37 1.49 2.87 

Difference* -0.07 0.20 0.12 

Base Case 1.24 1.63 2.87 

Standard Level 3 1.49 1.38 2.87 

Difference* -0.25 0.25 0.00 

Base Case 1.22 1.60 2.82 

Standard Level 4 1.53 1.29 2.82 

Difference* -0.31 0.31 0.00 

Base Case 1.18 1.56 2.74 

Standard Level 5 1.60 1.20 2.80 

Difference* -0.42 0.36 -0.06 

Base Case 1.17 1.55 2.72 

Standard Level 6 1.61 1.14 2.75 

Difference* -0.44 0.42 -0.02 

Base Case 1.14 1.52 2.67 

Standard Level 7 1.65 1.06 2.71 

Difference* -0.51 0.47 -0.05 

Base Case 1.11 1.49 2.60 

Standard Level 8 1.70 0.98 2.68 

Difference* -0.59 0.51 -0.08 

* Equipment Cost Difference represents the PVC; Operating Cost Difference represents the PVC; NPV is 

represented by the bold and italicized values. 

10-B-15 

EERE-2008-BT-STD-0012 COMMENT 22
 

Table 10-B.2.14Compact Freezers: Cumulative National Equipment and Operating Costs 

with NPV from 2014–2044, Three-Percent Discount Rate (billion 2008$) 

Standard Level Equipment Operating Total 

Base Case 2.48 3.46 5.94 

Standard Level 1 2.56 3.17 5.74 

Difference* -0.09 0.29 0.20 

Base Case 2.46 3.44 5.90 

Standard Level 2 2.60 3.00 5.60 

Difference* -0.14 0.43 0.30 

Base Case 2.34 3.28 5.62 

Standard Level 3 2.81 2.73 5.54 

Difference* -0.47 0.55 0.08 

Base Case 2.29 3.23 5.53 

Standard Level 4 2.87 2.55 5.42 

Difference* -0.58 0.68 0.10 

Base Case 2.21 3.13 5.34 

Standard Level 5 3.00 2.34 5.34 

Difference* -0.79 0.79 0.00 

Base Case 2.20 3.11 5.31 

Standard Level 6 3.02 2.19 5.21 

Difference* -0.82 0.92 0.09 

Base Case 2.14 3.04 5.18 

Standard Level 7 3.09 2.02 5.11 

Difference* -0.96 1.02 0.06 

Base Case 2.07 2.96 5.03 

Standard Level 8 3.18 1.85 5.02 

Difference* -1.11 1.11 0.01 

* Equipment Cost Difference represents the PVC; Operating Cost Difference represents the PVC; NPV is 

represented by the bold and italicized values. 

10-B-16
 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 11. LIFE-CYCLE COST SUBGROUP ANALYSIS
 

TABLE OF CONTENTS 

11.1 INTRODUCTION ......................................................................................................... 11-1 

11.2 PURCHASE PRICE IMPACTS.................................................................................... 11-1 

11-i 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 11. LIFE-CYCLE COST SUBGROUP ANALYSIS 

11.1 INTRODUCTION 

The life-cycle cost (LCC) subgroup analysis evaluates impacts on any identifiable groups 

or customers who may be disproportionately affected by any national energy efficiency standard 

level. The Department of Energy (DOE) will conduct this analysis as one of the analyses for the 

notice of proposed rulemaking (NOPR). DOE will accomplish this, in part, by analyzing the 

LCC and payback periods (PBPs) for those customers that fall into any identifiable groups. DOE 

plans to evaluate variations in regional energy prices and variations in energy use that might 

affect the net present value of a standard to customer subpopulations. To the extent possible, 

DOE will obtain estimates of each input parameter’s variability and will consider this variability 

in its calculation of customer impacts. DOE plans to perform sensitivity analyses to consider 

how differences in energy use will affect subgroups of customers. 

DOE will determine the impact on customer subgroups using the LCC Spreadsheet 

Model, which allows for different data inputs. The standard LCC analysis (described in Chapter 

8) focuses on the households and establishments that use refrigerators, refrigerator-freezers, and 

freezers. For standard-size refrigerator-freezers and freezers, DOE can use the LCC Spreadsheet 

Models to analyze the LCC for any subgroup by sampling only that subgroup. (Chapter 8 

explains in detail the inputs to the model used in determining LCC and PBPs.) 

In the case of households that use refrigerator-freezers and freezers, some possible 

subgroups DOE may choose to consider are: (1) low-income households, and (2) senior citizens. 

In the case of commercial establishments that use compact refrigerators and freezers, small 

businesses are a subgroup that DOE may choose to consider. If it analyzes small businesses, 

DOE will likely focus on small business subgroups such as lodging establishments. 

11.2 PURCHASE PRICE IMPACTS 

DOE will be especially sensitive to increases in the purchase price of the equipment due 

to new standards, to avoid negative impacts on identifiable population groups that may not be 

able to afford significant increases in equipment price. For such customers that are sensitive to 

price increases, increases in first costs of a product can preclude the purchase of a new model of 

that product. As a result, some customers may retain products past their useful life. These older 

products are generally less efficient to begin with, and their efficiency may deteriorate further if 

they are retained beyond their useful life. Increases in first cost also can preclude the purchase 

and use of a product altogether, resulting in a potentially large loss of utility to the customer. 

11-1 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 12. PRELIMINARY MANUFACTURER IMPACT ANLAYSIS 

TABLE OF CONTENTS 

12.1 INTRODUCTION ......................................................................................................... 12-1 

12.2 METHODOLOGY ........................................................................................................ 12-1 

12.2.1 Phase 1: Industry Profile.................................................................................... 12-2 

12.2.2 Phase 2: Industry Cash-Flow Analysis and Interview Guide ............................ 12-2 

12.2.2.1 Industry Cash-Flow Analysis............................................................ 12-2 

12.2.2.2 Interview Guide ................................................................................ 12-2 

12.2.3 Phase 3: Sub-Group Analysis ............................................................................ 12-3 

12.2.3.1 Manufacturer Interviews................................................................... 12-3 

12.2.3.2 Revised Industry Cash-Flow Analysis.............................................. 12-3 

12.2.3.3 Manufacturer Sub-Group Analysis................................................... 12-4 

12.2.3.4 Competitive Impact Assessment....................................................... 12-4 

12.2.3.5 Manufacturing Capacity Impact ....................................................... 12-4 

12.2.3.6 Employment Impact.......................................................................... 12-4 

12.2.3.7 Cumulative Regulatory Burden ........................................................ 12-5 

12.3 PRELIMINARY MANUFACTURER IMPACT ANALYSIS ..................................... 12-5 

12.3.1 General Interview Structure............................................................................... 12-5 

12.3.1.1 Key Issues ......................................................................................... 12-6 

12.3.1.2 Shipment Projections ........................................................................ 12-6 

12.3.1.3 Profitability ....................................................................................... 12-6 

12.3.1.4 Product Mix ...................................................................................... 12-6 

12.3.1.5 Conversion Costs, Manufacturing Capacity, and Employment 

Levels................................................................................................ 12-7 

12.3.1.6 Market Shares and Industry Consolidation....................................... 12-8 

12.3.1.7 Product Utility and Innovation.......................................................... 12-8 

12.3.1.8 Impact on Small Manufacturers........................................................ 12-8 

12.3.1.9 Cumulative Burden ........................................................................... 12-9 

12.3.1.10 State Energy Conservation Standards............................................... 12-9 

12.3.1.11 International Energy Conservation Standards .................................. 12-9 

12.4 RESIDENTIAL REFRIGERATION PRODUCT PRELIMINARY MIA RESULTS.. 12-9 

12.4.1 Key Issues ........................................................................................................ 12-10 

12.4.2 Profitability, Product Mix, and Shipments ...................................................... 12-12 

12.4.3 Conversion Costs, Manufacturing Capacity, and Employment Levels ........... 12-13 

12.4.3.1 Impact on U.S. Production and Jobs............................................... 12-13 

12.4.3.2 Foreign Labor.................................................................................. 12-13 

12.4.4 Industry Consolidation..................................................................................... 12-14 

12.4.5 Impact on Product Utility and Innovation ....................................................... 12-14 

12.4.6 Cumulative Burdens......................................................................................... 12-14 

12.4.6.1 Pending Regulations from the CPSC.............................................. 12-15 

12.4.6.2 Potential Climate Change and Greenhouse Gas Legislation .......... 12-15 

12.4.6.3 Standards for Other Products Made by Residential Refrigeration 

Products Manufacturers .................................................................. 12-15 

12.4.6.4 State and International Standards.................................................... 12-16 

12-i 

EERE-2008-BT-STD-0012 COMMENT 22
12.4.7 Impact on Small Manufacturers....................................................................... 12-16 

12-ii 

EERE-2008-BT-STD-0012 COMMENT 22
 

CHAPTER 12. PRELIMINARY MANUFACTURER IMPACT ANALYSIS 

12.1 INTRODUCTION 

The purpose of the manufacturer impact analysis (MIA) is to identify the likely 

impacts of amended energy conservation standards on manufacturers. The U.S. 

Department of Energy (DOE) will conduct this analysis with input from manufacturers 

and other interested parties and will apply this methodology to its evaluation of amended 

energy conservation standards for residential refrigerators, refrigerator-freezers, and 

freezers. DOE will also consider financial impacts and a wide range of quantitative and 

qualitative industry impacts that might occur following the amendment of an energy 

conservation standard. For example, a particular energy conservation standard level, if 

adopted by DOE, could require changes to residential refrigeration products 

manufacturing practices. DOE will identify and come to understand these impacts 

through interviews with manufacturers and other interested parties during the Notice of 

Proposed Rulemaking (NOPR) stage of its analysis. 

Recently, DOE announced changes to the MIA format through a report issued to 

Congress on January 31, 2006 (as required by section 141 of the Energy Policy Act of 

2005 (EPACT 2005)), entitled “Energy Conservation Standards Activities.”a

 Previously, 

DOE did not report any MIA results until the Notice of Proposed Rulemaking (NOPR) 

phase; however, under this new format, DOE has collected, evaluated, and reported 

preliminary information and data during the preliminary phase (the phase preceding the 

NOPR) of this rulemaking. Such preliminary information includes the anticipated 

conversion capital expenditures by efficiency level and the corresponding anticipated 

impacts on jobs. DOE solicited this information during the engineering analysis 

manufacturer interviews and reported the results below. 

12.2 METHODOLOGY 

DOE conducts the MIA in three phases and further tailors the analytical 

framework based on comments from interested parties. In Phase 1, DOE creates an 

industry profile to characterize the industry and conducts a preliminary MIA to identify 

important issues that require consideration. The preliminary technical support document 

(preliminary TSD) presents the results of the Phase 1 analysis. In Phase 2, DOE prepares 

an industry cash-flow model and an interview questionnaire to guide subsequent 

discussions. In Phase 3, DOE interviews manufacturers, and assesses the impacts of 

amended energy conservation standards both quantitatively and qualitatively. Using the 

government regulatory impact model (GRIM), DOE assesses industry and sub-group 

a

 This report is available on the DOE website at 

www.eere.energy.gov/buildings/appliance_standards/2006_schedule_setting.html. 

12-1
 

EERE-2008-BT-STD-0012 COMMENT 22
cash flow and NPV. Then, DOE assesses impacts on competition, manufacturing 

capacity, employment, and regulatory burden based on manufacturer interview feedback 

and discussions. The NOPR TSD presents results of the Phase 2 and 3 analyses. 

12.2.1 Phase 1: Industry Profile 

In Phase 1 of the manufacturer impact analysis, DOE collects pertinent qualitative 

and quantitative financial and market information. This includes residential refrigerator, 

refrigerator-freezer, and freezer manufacturer market share, corporate operating ratios, 

wages, employment, and production cost ratios. Sources of information may include 

reports published by industry groups, trade journals, the U.S. Census Bureau, copies of 

Securities Exchange Commission (SEC) 10-K filings, and interviews with manufacturers. 

DOE also relies on information from its market and technology assessment, engineering 

analysis, life-cycle cost analysis, markup analysis, and analysis of capital expenditure 

requirements and other data submitted by AHAM to determine the product prices to 

characterize the residential refrigeration product industry. 

12.2.2 Phase 2: Industry Cash-Flow Analysis and Interview Guide 

In Phase 2, DOE will perform a preliminary industry cash-flow analysis and 

prepare written guidelines for interviewing manufacturers. 

12.2.2.1 Industry Cash-Flow Analysis 

DOE uses the GRIM to analyze the financial impacts of amended energy 

conservation standards on the residential refrigeration products industries. Standards will 

likely require additional investment, raise production costs, and affect revenue through 

higher prices and, possibly, lower sales. The GRIM uses several factors to determine a 

series of annual cash flows for the year standards become effective and for several years 

after implementation. These factors include annual expected revenues, costs of sales, 

selling and general administration costs, taxes, and capital expenditures related to 

depreciation, new standards, and maintenance. Inputs to the GRIM include 

manufacturing costs, shipments forecasts, and price forecasts developed in other 

analyses. Another input, financial information, will be developed based on publicly 

available data and confidentially submitted manufacturer information. DOE compares the 

results of the GRIM against baseline projections where no standards are in place. The 

financial impact of amended energy conservation standards is the difference between the 

two sets of discounted annual cash flows. 

12.2.2.2 Interview Guide 

DOE will conduct interviews with manufacturers to gather information on the 

effects of standards on revenues and finances, direct employment, capital assets, and 

industry competitiveness. Before the interviews, DOE will distribute an interview guide 

that will provide a starting point to identify relevant issues and help identify the impacts 

of standards on individual manufacturers or sub-groups of manufacturers. DOE 

anticipates that the interview guide will cover current organizational characteristics, 

industry infrastructure, manufacturer cash-flow analysis, a competitive impacts 

12-2
 

EERE-2008-BT-STD-0012 COMMENT 22
assessment, an employment impacts assessment, and a manufacturing capacity impacts 

assessment. 

12.2.3 Phase 3: Sub-Group Analysis 

Phase 3 activities will take place after the publication of the NOPR documents 

and will include manufacturer interviews, revision of the industry cash-flow analysis, 

manufacturer sub-group cash-flow analysis, competitive impact assessment, 

manufacturing capacity impact, employment impact, and cumulative regulatory burden. 

12.2.3.1 Manufacturer Interviews 

The information gathered in Phase 1 and the cash-flow analysis performed in 

Phase 2 will be supplemented with information gathered during interviews with 

manufacturers during Phase 3. The interview process has a key role in the manufacturer 

impact analyses, since it provides an opportunity for interested parties to express their 

views privately on important issues, allowing confidential or sensitive information to be 

considered in the rulemaking decision. 

DOE will conduct detailed interviews with as many manufacturers as necessary to 

gain insight into the range of potential impacts of standards. During the interviews, DOE 

will solicit information on the possible impacts of standards on sales, direct employment, 

capital assets, and industry competitiveness. Both qualitative and quantitative information 

are valuable. Interviews will be scheduled well in advance in order to provide every 

opportunity for key individuals to be available for comment. Although a written response 

to the questionnaire will be acceptable, DOE prefers an interactive interview process 

because it helps clarify responses and provides the opportunity to identify additional 

issues. 

All information transmitted will be considered, as appropriate, in DOE’s decisionmaking process. Interview participants will be asked to identify all confidential 

information provided in writing or orally; no confidential information will be made 

available in the public record. Participants will also be asked to identify all information 

they wish included in the public record but do not want to have associated with their 

interview. This information will be incorporated into the public record but reported 

without attribution. 

12.2.3.2 Revised Industry Cash-Flow Analysis 

In Phase 2 of the MIA, DOE will provide manufacturers with a preliminary 

GRIM for review and evaluation. During the interviews, DOE will seek comment and 

suggestions regarding the values selected for the parameters. Upon completion of the 

interviews, DOE will revise its industry cash-flow model based on manufacturer 

feedback. 

12-3
 

EERE-2008-BT-STD-0012 COMMENT 22
12.2.3.3 Manufacturer Sub-Group Analysis 

Using average cost assumptions to develop an industry cash-flow estimate is not 

adequate for assessing differential impacts among sub-groups of manufacturers. Smaller 

manufacturers, niche players, or manufacturers exhibiting a cost structure that differs 

largely from the industry average could be more negatively affected. Ideally, DOE would 

consider the impact on every firm individually; however, it typically uses the results of 

the industry characterization to group manufacturers exhibiting similar characteristics. 

During the interview process, DOE will discuss the potential sub-groups and sub-group 

members that have been identified for the analysis. DOE will look to the manufacturers 

and other stakeholders to suggest what sub-groups or characteristics are most appropriate 

for the analysis. 

12.2.3.4 Competitive Impact Assessment 

Section 342 (6)(B)(i)(V) of the Energy Policy Act of 1992 (EPCA) directs DOE 

to consider any lessening of competition likely to result from imposition of standards. It 

further directs the U.S. Attorney General to determine the impacts, if any, of any decrease 

in competition. DOE will make a determined effort to gather and report firm-specific 

financial information and impacts. The competitive analysis will focus on assessing the 

impacts on smaller, yet significant, manufacturers. The assessment will be based on 

manufacturing cost data and information collected from interviews with manufacturers. 

The manufacturer interviews will focus on gathering information that would help in 

assessing asymmetrical cost increases to some manufacturers, the potential increase in 

business risks from an increased proportion of fixed costs, and potential barriers to 

market entry (e.g., proprietary technologies). 

12.2.3.5 Manufacturing Capacity Impact 

One of the significant outcomes of standards could be the obsolescence of 

existing manufacturing assets, including tooling and investment. The manufacturer 

interview guide will have a series of questions to help identify impacts on manufacturing 

capacity, specifically capacity utilization and plant location decisions in North America 

with and without a standard; the ability of manufacturers to upgrade or remodel existing 

facilities to accommodate the new requirements; the nature and value of stranded assets, 

if any; and estimates for any one-time restructuring and other charges, where applicable. 

12.2.3.6 Employment Impact 

The impact of amended energy conservation standards on employment is an 

important consideration in the rulemaking process. To assess how domestic employment 

patterns might be affected, the interview will explore current employment trends in the 

refrigeration products industry. The interview will also solicit manufacturer views on 

changes in employment patterns that may result from increased standard levels. The 

employment impacts section of the interview guide will focus on current employment 

levels associated with manufacturers at each of their production facilities, expected future 

12-4
 

EERE-2008-BT-STD-0012 COMMENT 22
employment levels with and without a standard, and differences in workforce skills and 

issues related to the retraining of employees. 

12.2.3.7 Cumulative Regulatory Burden 

DOE recognizes and seeks to mitigate the overlapping effects on manufacturers of 

amended energy conservation standards and other regulatory actions affecting the same 

products. DOE will analyze and consider the impact on manufacturers of multiple, 

product-specific regulatory actions. Based on its own research and discussions with 

manufacturers, DOE identified several regulations and proposed regulations relevant to 

refrigerator, refrigerator-freezer, and freezer manufacturers, including existing or new 

standards, potential limits on greenhouse gas (GHG) emissions, including 

hydrofluorocarbon (HFC) refrigerants and foam-blowing agents, standards for other 

products made by refrigerator, refrigerator-freezer, and freezer manufacturers, State 

energy conservation standards, and International energy conservation standards. DOE 

will study the potential impacts of these cumulative burdens in greater detail during the 

MIA conducted during the NOPR phase. 

12.3 PRELIMINARY MANUFACTURER IMPACT ANALYSIS 

During the preliminary rulemaking phase, DOE conducted a preliminary 

evaluation of the impact of potential amended energy conservation standards on 

manufacturer financial performance, manufacturing capacity and employment levels, and 

product utility and innovation. A primary focus was to identify the cumulative burden 

that industries face from the overlapping effect of new or recent DOE energy 

conservation standards and/or other regulatory action affecting the same products or 

industries. 

The primary sources of information for this analysis were on-site or telephone 

interviews with manufacturers of residential refrigeration products conducted during the 

fall and winter of 2008. To maintain confidentiality, DOE did not identify the individual 

manufacturers that disclosed information. The evaluation only reports aggregated 

information and does not disclose sensitive or company-specific information. 

For the preliminary MIA, DOE conducted interviews with manufacturers 

primarily to identify key issues and gain insights into the qualitative impacts of amended 

energy conservation standards. For each product, DOE used an interview guide to gather 

responses from multiple manufacturers on many issues. All of the interview guides 

covered the same general topic areas, but each interview guide was adapted to the needs 

of each product category. Appendix 12-A contains a copy of the interview guides for 

residential refrigerators, refrigerator-freezers, and freezers. 

12.3.1 General Interview Structure 

The manufacturer interviews included questions relating to the following topics. 

DOE received responses to most, if not all, of these topics from various manufacturers. 

12-5
 

EERE-2008-BT-STD-0012 COMMENT 22
12.3.1.1 Key Issues 

Perhaps the most important aspect of the preliminary MIA is the opportunity to 

identify key manufacturer issues early in the development of amended energy 

conservation standards. During the interviews, DOE engages manufacturers in a 

discussion about what they perceive to be the key issues in the rulemaking. Key issues, 

once identified, are added to the list of topics explored during the interviews. For 

example, key issues in previous rulemakings have included concerns over patent 

protections that might prevent some companies from implementing higher efficiency 

designs. 

12.3.1.2 Shipment Projections 

Shipment projections can be a significant factor in determining the impacts of 

amended energy conservation standards. The interviews provide an opportunity for 

manufacturers to share information that can help DOE quantify the magnitude of any 

changes in shipments resulting from amended energy conservation standards. DOE is 

interested in information relating to the current number of product shipments, broken 

down by product class, capacity rating, and efficiency level. DOE also seeks input on the 

forecast of future shipments absent amended energy conservation standards. 

Manufacturers are asked how they would expect shipments to change for the industry as a 

whole as a function of standard levels and why they expect these changes might occur. 

More specific questions aim to derive a price elasticity estimate for use in the national 

impact analysis (NIA) spreadsheet. 

Another aspect of the shipments discussion is to understand the impacts of a 

reduction in shipments on individual refrigeration products companies. 

12.3.1.3 Profitability 

DOE requests manufacturers’ views on what they perceive to be the possible 

impact of potential amended energy conservation standards on their future profitability. 

Amended energy conservation standards could affect financial performance in several 

different ways. Several of these impacts are captured in previous sections. For instance, 

the capital and product conversion outlays needed to upgrade or redesign products and 

product platforms before they have reached the end of their useful life can engender 

significant conversion costs that otherwise would not be expended, resulting in reduced 

cash flow and stranded investments. Higher energy efficiency standards also can result in 

higher per-unit costs that may deter some consumers from purchasing the products, or 

cause some consumers to choose less efficient products, thereby reducing shipments. 

12.3.1.4 Product Mix 

DOE is interested in understanding if amended energy conservation standards 

might change a manufacturer’s product mix and if this change affects profits. For 

example, higher energy efficiency standards might limit a manufacturer’s ability to 

differentiate products and market premium products that command higher profit margins. 

12-6
 

EERE-2008-BT-STD-0012 COMMENT 22
The interview guide also investigates how amended energy conservation 

standards might affect a manufacturer’s consumer mix and its distribution channels, and 

how in turn this might change profitability. 

12.3.1.5	 Conversion Costs, Manufacturing Capacity, and Employment 

Levels 

During the interviews, DOE asks manufacturers to quantify and explain both the 

capital and product conversion costs necessary to raise the energy efficiency of their 

product lines to the proposed standard levels. In some instances, manufacturers may be 

able to meet proposed standard levels by modifying existing products. In other cases, the 

necessary changes may entail a complete product-line redesign. In these situations, an 

increase in efficiency standards will cause manufacturers to incur one-time conversion 

capital expenditures and product-conversion expenses. Conversion capital expenditures 

are one-time investments in property, plant, and equipment. Product-conversion expenses 

include one-time investments in research, product development, testing, and marketing. 

One of the significant outcomes of amended energy conservation standards could 

be the obsolescence of existing manufacturing assets, including tooling and other capital 

investment. The interview guide includes questions to identify impacts on manufacturing 

capacity. DOE developed these questions to understand the impact of potential amended 

standards on: 

•	 North American manufacturing capacity; 

•	 capacity utilization and plant location decisions in North America both with and 

without standards; 

•	 the ability of manufacturers to upgrade or remodel existing facilities to 

accommodate a new product mix; and 

•	 the nature and value of stranded assets, if any. 

The impact of amended energy conservation standards on employment is an 

important consideration in the rulemaking process. DOE uses the interviews to explore 

current trends in production employment and solicit manufacturer views on changes in 

employment patterns resulting from amended energy conservation standards. Questions 

regarding employment impacts help to understand 

•	 current employment levels associated with manufacturing the subject products at 

each production facility; 

•	 expected future employment levels both with and without amended standards; and 

•	 differences in workforce skills and issues related to retraining employees. 

12-7
 

EERE-2008-BT-STD-0012 COMMENT 22
12.3.1.6 Market Shares and Industry Consolidation 

Amended energy conservation standards can alter the competitive dynamics of the 

marketplace. This can include prompting companies to enter the market, exit the market, 

or merge with other companies. The preliminary MIA interview questions ask 

manufacturers to share their perspectives on industry consolidation both in the absence of 

amended standards and assuming amended standards at various efficiency levels. The 

interview questions focus on gathering information that helps in assessing 

• disproportionate cost increases to some manufacturers; 

• increased proportion of fixed costs potentially increasing business risks; and 

• potential barriers to market entry (e.g., proprietary technologies). 

DOE conducts an assessment of anti-competitive effects of proposed standards in 

order to protect the interests of the consumer. During the interviews, DOE solicits 

information to understand if amended standards could result in disproportionate 

economic or performance penalties for particular consumer/user sub-groups. 

DOE also asks manufacturers if amended energy conservation standards could 

result in products that will be more or less desirable to consumers due to changes in 

product functionality, utility, or other features. 

12.3.1.7 Product Utility and Innovation 

Amended energy conservation standards can force manufacturers to compromise 

product utility to consumers by eliminating energy-consuming features. During the 

interviews, DOE requests information on the effects of proposed standards on product 

utility. 

Amended energy conservation standards may require investment in conversion 

costs, including research and development (R&D). This required spending may force a 

manufacturer to reduce funding usually allocated to product innovation. Amended energy 

conservation standards may also force manufacturers to eliminate innovative energyconsuming features from their products. During the interviews, DOE requests 

information on the effect of proposed standards on innovation. 

12.3.1.8 Impact on Small Manufacturers 

DOE will consider the possibility of small businesses being affected by the 

promulgation of amended energy conservation standards for residential refrigerators, 

refrigerator-freezers, and freezers. Should any small business manufacturers be identified, 

DOE will study the potential impacts on these small businesses in greater detail during 

the MIA. 

12-8
 

EERE-2008-BT-STD-0012 COMMENT 22
12.3.1.9 Cumulative Burden 

While any one regulation may not impose a significant burden on manufacturers, 

the combined effects of several impending regulations may have serious consequences 

for some manufacturers, groups of manufacturers, or entire industries. Assessing the 

impact of a single regulation may overlook this cumulative regulatory burden. 

Expenditures associated with meeting other regulations are an important aspect of 

DOE’s consideration of the “cumulative regulatory burden” the industry faces. The 

interviews help DOE identify the level and timing of investments manufacturers are 

expecting to incur as a result of these regulations. Manufacturers are also asked under 

what circumstances they might be able to coordinate any expenditures related to these 

regulations and efficiency standards. 

In addition to the amended energy conservation for residential refrigeration 

products, several other Federal regulations and pending regulations apply to other 

products these manufacturers make. DOE will investigate these cumulative regulatory 

burdens in greater detail during the NOPR phase of the rulemaking. 

12.3.1.10 State Energy Conservation Standards 

DOE identified and described regulatory programs at the state level in the market 

and technology assessment (chapter 3 of the preliminary TSD) for the products covered 

in this rulemaking. Multiple States have requirements for products covered under this 

rulemaking. Accommodating multiple State standards in addition to National standards 

raises costs for manufacturers. 

12.3.1.11 International Energy Conservation Standards 

DOE discussed regulatory programs from certain other countries, such as Canada 

and Mexico, in the market and technology assessment, (chapter 3 of the preliminary 

TSD). A few manufacturers sell a small portion of their total production to countries 

outside the United States. In these cases, the products must meet the standards for each 

country. Companies may design some units to meet more stringent standards than those 

imposed by the United States in order to minimize the number of product variations. 

12.4	 RESIDENTIAL REFRIGERATION PRODUCT PRELIMINARY MIA 

RESULTS 

During the preliminary MIA interview, manufacturers identified key issues 

surrounding DOE’s rulemaking for refrigeration products and provided feedback 

regarding the potential impact of amended energy conservation standards. DOE 

summarized the feedback below. 

12-9
 

EERE-2008-BT-STD-0012 COMMENT 22
12.4.1 Key Issues 

One of the main questions in each of the preliminary interview guide asks: “What 

are the key issues for your company regarding the refrigeration products energy 

conservation standard rulemaking?” This open question initiated dialogue with the 

manufacturers, enabling them to identify key points that DOE would explore and discuss 

during the interview. This section describes the key issues manufacturers felt were of the 

highest importance in relation to the residential refrigeration products energy 

conservation standards rulemaking and that would have the most significant impact on 

the industry. Manufacturers indicated that, for the most part, the risks associated with 

these issues increase with more stringent energy conservation standards. The issues are 

overall concerns that many manufacturers expressed and in some cases, are dependent 

upon the product class. 

Refrigerator, refrigerator-freezer, and freezer manufacturers cited concerns 

regarding a number of issues that are covered in greater detail elsewhere in this chapter. 

These issues were conversion costs, the impact to U.S. production and jobs, cumulative 

regulatory burden, and the impact on product utility. Detailed descriptions of these 

manufacturer concerns are provided in the appropriate sections that follow; only brief 

descriptions are provided here. 

•	 Increased Conversion Costs – A number of manufacturers indicated that 

conversion costs will be much greater if the adopted standards require significant 

changes to efficiency rather than moderate changes to efficiency. This is due to 

the need for wall thickness increases rather than just component swaps in the case 

of significantly more stringent energy standards. 

•	 Impact to U.S. Production and Jobs – Manufacturers generally agreed that 

increased standards requiring investment in new plants would most likely have 

the effect of lowering U.S. production and jobs because plants would be built 

overseas for the benefit of lower labor costs. 

•	 Cumulative Regulatory Burden – Many manufacturers indicated that refrigeration 

products face a number of pieces of new legislation that would exacerbate the 

burden created from more stringent energy standards. These include a potential 

Greenhouse Gas (GHG) bill in the U.S. and changing energy standards in Canada 

and abroad. 

•	 Impact to Product Utility – Several manufacturers expressed concern about the 

possibility of lower product utility resulting from stricter energy standards. If 

thicker walls are required to meet new standards, internal volumes would be 

reduced while still using the same amount of floor space. Other features that can 

increase energy usage, such as glass doors and multiple temperature zones in 

drawer compartments, may have to be removed if standards are significantly 

stricter. 

12-10 

EERE-2008-BT-STD-0012 COMMENT 22
The other issues of key importance to manufacturers are the current poor economic 

conditions, the circumvention of new standards and need for enforcement, and the timing 

and technical difficulty of achieving new standards. 

•	 Current Economic Conditions – A number of manufacturers indicated that the 

current status of the U.S. economy has put strains on the financial conditions of 

their companies. This strain diminishes their ability to support the investments 

required to meet new energy standards and causes a competition for capital 

between these required investments and other opportunities such as research and 

new product development. Any impact from new standards on conversion costs, 

U.S. production, and jobs would be greater because of the difficult economic 

environment. 

•	 Circumvention and Enforcement – Several manufacturers expressed concern that 

some manufacturers have not followed the intent of the current test procedure or 

have actively circumvented the test procedure via sensors that detect test 

conditions. These sensors direct a controller to disable certain energy-using 

functions during the test in order to achieve lower energy consumption for the 

Energy Guide labeling. These actions have hurt domestic manufacturers 

competitively. Other companies expressed concern that there is not enough 

enforcement of energy standards to ensure that products meet the ratings on their 

labels. Some import brands have submitted incorrect or incomplete data to DOE 

for labeling, particularly for compact product classes. Since some importers 

source from multiple manufacturers, and label submissions are associated with the 

import brand rather than the manufacturing company, it is difficult to track 

labeling issues to the original manufacturer. 

•	 Technical Difficulty to Achieve New Standards – Many manufacturers expressed 

concerns about the technical difficulty in achieving new standards that are 

significantly more stringent than current levels. They pointed out that there are 

fewer additional low-cost technology improvements available now than there 

were during past rulemakings. Specifically, compact freezers were cited as a 

product class in which it will be especially difficult to make significant 

improvements. The standards for compact freezers are already more stringent 

relative to capacity than are standards for compact refrigerators. Compact units, in 

general, pose a challenge because there are very few low-capacity compressors 

with sufficiently high efficiencies. Several manufacturers indicated that 

improvements could be made, but highlighted the importance of staying informed 

by DOE of the proposed new standard levels throughout the rulemaking process. 

They also emphasized having adequate time between the final rule and the 

effective date of the new standards to ensure adequate time is available to 

redesign products and to make the appropriate investments in manufacturing 

lines. 

12-11 

EERE-2008-BT-STD-0012 COMMENT 22
12.4.2 Profitability, Product Mix, and Shipments 

DOE asked manufacturers during the preliminary manufacturer interviews how 

amended energy conservation standards would affect their profitability, product mix, and 

overall shipments. Nearly all manufacturers stated that amended energy conservation 

standards could lower profits depending upon the efficiency level under consideration by 

DOE. In particular, manufacturers indicate that new standards requiring cost increases of 

15-20 percent or more would have significant impacts through lowered industry 

shipments and a shift in product mix. 

Manufacturers of all types of refrigeration products state that cost increases at 

these levels would drive consumers toward lower-cost products. Nearly all manufacturers 

have certain product lines that would have difficulty meeting new standards that are 

significantly stricter. They say that they would most likely drop some of these products 

because of technical difficulties in achieving new standards. 

Several manufacturers of refrigerators and refrigerator-freezers stated that they 

would shift their product mix to compete in lower cost products or would no longer be 

able to compete as heavily in ENERGY STAR products. This would lower profitability 

because lower cost and baseline products typically cannot command as much of a margin 

as do premium and Energy Star products. Contrarily, some manufacturers expect to move 

more strongly towards higher-end products because of the higher profit margins 

available. They contend that the cost-competitive nature of low-end refrigeration 

products makes it very difficult to pass on increased costs to the consumer. For this 

reason, they indicate that they would modify their product mix to be weighted more 

heavily toward higher-margin products. One manufacturer even noted that it would exit 

certain low-margin product classes completely if the investment costs required to meet 

the amended energy standards were too high. Still, other manufacturers did not expect to 

change their product mix much at all, either because their product platforms are far from 

the end of their efficiency capability or because their market strategy calls for 

maintaining a fixed portion of ENERGY STAR products. 

All manufacturers agree that amended energy standards would decrease profit 

margins for refrigeration products in general. Manufacturers stated that the extent to 

which margins diminish will depend on how much cost their competitors are able to pass 

through to the customer. Manufacturers of higher-end products have higher margins, and 

thus greater capacity to absorb cost increases, whereas entry level products have very thin 

margins and minimal capacity to absorb cost increases. Manufacturers stated that 

customers of lower-end products are very price-sensitive and the ability of a 

manufacturer to pass cost increases through without affecting demand for low-end 

products is extremely limited. In general, most manufacturers agree that significantly 

stricter amended energy standards would increase retail prices and lower demand for 

refrigeration products across the board. Specifically, many indicated that increased costs 

will price some consumers out of the market completely and bring would-be purchasers 

of higher-end units down to entry-level products, thereby reducing both overall demand 

and demand for higher-margin refrigeration products. 

12-12 

EERE-2008-BT-STD-0012 COMMENT 22
12.4.3 Conversion Costs, Manufacturing Capacity, and Employment Levels 

DOE estimated that a typical high-volume domestic refrigerator, refrigeratorfreezer, or freezer production line would have a life cycle of approximately ten years in 

the absence of amended energy conservation standards. During that period, 

manufacturers would not make major equipment changes that alter the underlying 

platforms. Thus, an amended energy conservation standard that took effect and resulted 

in a major platform redesign before the end of the platform’s life would strand a portion 

of the earlier capital investments. 

DOE asked manufacturers what level of conversion costs they anticipate if 

amended energy conservation standards were to take effect. Manufacturers said that 

conversion costs would be significant if amended standards require new product 

platforms, as opposed to component swaps only. The primary changes that would dictate 

new product platforms are significant alterations to wall thicknesses or the use of vacuum 

insulated panels (VIP). The cost of such changes varies by manufacturer, depending on 

the volume of production and whether capital, tooling, and engineering investments are 

required. Lower-volume manufacturers have indicated that conversion costs in this 

scenario could range from a few million dollars to tens of millions. Higher volume 

manufacturers have indicated potential costs in the range of hundreds of millions of 

dollars. 

Additionally, manufacturers have identified the cost of plant closings as an 

important component of conversion costs. Several manufacturers indicated that 

significant energy efficiency increases would drive them to construct new plants in 

lower-cost labor markets. Mexico, specifically, was offered as a potential location. Some 

existing U.S. plants would either be closed or downsized, reducing domestic employment 

levels and leaving some stranded assets. Contrarily, a few domestic manufacturers 

indicated that they would have few stranded assets or that they would not move 

production outside the U.S. 

12.4.3.1 Impact on U.S. Production and Jobs 

The impact of amended energy conservation standards on employment is an 

important consideration in the rulemaking process. As indicated in section 12.3.2.3 

above, significant increases to the energy efficiency standards for refrigeration products 

would cause some manufacturers to close domestic production facilities and to construct 

new plants outside of the U.S. Manufacturers with existing facilities abroad indicated that 

they may expand or modify those facilities rather than build entirely new plants. 

12.4.3.2 Foreign Labor 

Manufacturers indicated that there has been a shift in production out of the United 

States, in particular to Mexico. For compact products, the trend has been towards 

production even further from the U.S., particularly China. Manufacturers said that 

amended energy conservation standards could exacerbate these trends. Some 

manufacturers are very committed to keeping production in the U.S., but in general these 

12-13 

EERE-2008-BT-STD-0012 COMMENT 22
do not include the highest-volume manufacturers. Consideration of production outside 

the U.S. is primarily driven by concerns about profitability and the opportunity for lower 

labor costs. 

12.4.4 Industry Consolidation 

Three companies now account for the majority of U.S. sales of residential 

refrigeration products. The relative market share among these companies and between 

these companies and other manufacturers varies depending on product class. In certain 

product classes, other manufacturers dominate the market. A trend of consolidation has 

occurred within the industry in recent years. Most manufacturers anticipate further 

consolidation in the future, even in the absence of amended energy conservation 

standards. Manufacturers also indicated that new standards could impact future 

consolidation by making certain manufacturers less competitive. 

12.4.5 Impact on Product Utility and Innovation 

Amended energy conservation standards can affect purchasers of residential 

refrigeration products by increasing or decreasing the utility of such products. 

Manufacturers generally agree that stringent energy efficiency standards would decrease 

innovations and reduce product utility. They believe that product utility would be 

impacted in several ways. First, significantly stricter standards would increase the costs 

of refrigeration products across the board. Most manufacturers believe that the price 

increases would force lower income customers out of the market for refrigeration 

products altogether. Second, meeting new standards will likely require manufacturers to 

increase product wall thicknesses. Most residential kitchens have limited refrigerator 

space, so the wall thicknesses of refrigeration products would be forced to grow inward. 

This leaves less internal volume available for use by the customer. This is an issue of 

great concern for virtually all manufacturers. Finally, several manufacturers indicated that 

other product features currently available today may have to be removed in order to meet 

new standard levels and maintain acceptable product costs. Examples of these features 

include ice and water dispensers, glass doors, soda can dispensers, crisper compartments, 

antisweat features, and food preservation capabilities. 

Manufacturers also believe that product innovation would be affected by amended 

energy conservation standards. Specifically, they say that innovation will increase in the 

area of energy efficiency, but it will decrease or disappear in the development of other 

features. New efficiency standards would cause manufacturers to divert money from the 

development of new, brand-differentiating features to the development of features that 

decrease energy usage. 

12.4.6 Cumulative Burdens 

Based on its own research and discussions with manufacturers, DOE identified 

several regulations relevant to residential refrigeration products, including: 

• regulations from the Consumer Products Safety Commission (CPSC); 

12-14 

EERE-2008-BT-STD-0012 COMMENT 22
• potential climate change and greenhouse gas (GHG) regulation; 

• new DOE test procedures for residential refrigeration products; 

• standards for other products made by residential refrigeration product 

manufacturers; 

• other State energy conservation standards; and 

• international energy conservation standards. 

Complying with such regulations requires corporations to invest both human and 

capital resources. The following subsections discuss in greater detail regulations affecting 

the residential refrigeration products industry. 

12.4.6.1	 Pending Regulations from the CPSC 

Several manufacturers stated that the CPSC was considering regulations regarding 

the labeling and materials identification for residential refrigeration products. They 

indicated that the regulations would essentially duplicate existing Underwriters 

Laboratories (UL) certification requirements for safety. At the time that the manufacturer 

impact analysis interviews were conducted, the new CPSC regulations were still pending. 

The rulemaking was passed in December 2008, however, and is published in 16 CFR 

1101. 

12.4.6.2	 Potential Climate Change and Greenhouse Gas Legislation 

Many manufacturers expressed concern about potential climate change 

legislation. This is an area of great importance within the industry. Manufacturers expect 

a climate change bill that regulates the use and emissions of GHG’s to be passed by 

Congress in the near future. As a result, use of hydrofluorocarbons (HFC’s), the most 

commonly used refrigerants and foam-blowing agents, would become restricted. These 

substances would eventually be phased out, or their use capped at a restricted level. This 

presents a problem for manufacturers because the key alternative insulation foam 

blowing agent is cyclopentane. Insulation made with this blowing agent has higher 

conductivity than current state-of-the art foam insulation, and conversion to cyclopentane 

presents factory issues due to its flammability..Conversion of the currently-used 

refrigerant, HFC-134a, to the most likely alternative, R-600a or isobutane, would require 

product redesign, and causes issues associated with safety certification compliance under 

UL regulations. Proposed legislation presents uncertainty for manufacturers as to how 

hydrocarbon refrigerants and foam-blowing agents would be regulated for safety within 

the U.S. Manufacturers indicate that the costs of making changes associated with 

conversion to new refrigerants and blowing agents would be in the millions of dollars. 

12.4.6.3	 Standards for Other Products Made by Residential Refrigeration 

Products Manufacturers 

In addition to the efficiency regulations for residential refrigeration products, 

several other Federal regulations and pending regulations apply to other products 

manufactured by the companies that manufacture refrigeration products. Many of these 

companies manufacture multiple lines of residential appliances, including clothes 

12-15 

EERE-2008-BT-STD-0012 COMMENT 22
washers, clothes dryers, dishwashers, and cooking products, all of which are also subject 

to Federal efficiency regulations. Some of these products are currently undergoing 

rulemakings amending the test procedures to incorporate standby and off mode energy 

consumption as well. Additionally, manufacturers pointed out that changes are being 

made to the refrigeration products test procedures concurrent with the refrigeration 

products energy conservation standard rulemaking. 

12.4.6.4 State and International Standards 

Manufacturers stated that there are a number of state and international standards 

that they must adhere to in addition to those currently under consideration in this 

rulemaking. European standards such as the Restriction on the use of Hazardous 

Substances (RoHS), Waste Electrical and Electronic Equipment (WEEE), and the 

Registration, Evaluation, Authorization, and restriction of Chemicals (REACH) create 

additional compliance costs for manufacturers that compete in Europe. Manufacturers 

indicated that California has programs similar to these that are either already in place or 

are currently in development. Additionally, different efficiency standards in foreign 

countries add to the range of regulations that manufacturers must meet. DOE will 

investigate these cumulative regulatory burdens in greater detail during the MIA analysis. 

12.4.7 Impact on Small Manufacturers 

The Small Business Administration (SBA) defines small business manufacturing 

enterprises for North American Industry Classification System (NAICS) code 335222, 

Household Refrigerator and Home Freezer Manufacturing, as companies with 1000 or 

less employees. SBA lists small business size standards that are matched to industries as 

they are described in the NAICS. The size standard defines the maximum allowable size 

of a for-profit small business for Federal Government programs. Size standards are 

generally based on the average annual receipts or the average number of employees at a 

firm. 

The manufacturer interviews indicated that smaller refrigeration product 

manufacturers typically have smaller corporate research and development and 

engineering staff than larger manufacturers. Smaller manufacturers often produce niche 

or specialty products and focus on providing products that other larger manufacturers do 

not produce. Although small manufacturers often have a more limited product range than 

larger manufacturers, the effort to address some aspects of regulations are relatively fixed 

and do not scale directly with the number of products or product platforms produced. 

Consequently, the cumulative burden of regulations will tend to place more of a burden 

on smaller manufacturers because of their more limited resources. 

DOE will study the potential impacts to these small businesses in greater detail 

during the MIA. 

12-16 

EERE-2008-BT-STD-0012 COMMENT 22
APPENDIX 12-A. PRELIMINARY MANUFACTURER IMPACT ANALYSIS 

QUESTIONNAIRE 

TABLE OF CONTENTS 

12A.1 INTRODUCTION ...............................................................................................12-A-1
 

12A.2 QUESTIONNAIRE .............................................................................................12-A-1
 

12-A-i 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

APPENDIX 12-A. PRELIMINARY MANUFACTURER IMPACT ANALYSIS 

QUESTIONNAIRE 

12-A.1 INTRODUCTION 

DOE used the questionnaire below to interview a number of refrigerator and freezer 

manufacturers during the pre-NOPR phase of the rulemaking to analyze the impact of energy 

conservation standards on manufacturers. Individual manufacturer responses are kept 

confidential. Aggregated results are summarized in chapter 12. 

12-A.2 QUESTIONNAIRE 

1 Issues 

1.1	 What are the key issues for your company regarding a possible future product 

rulemaking? 

2 Shipment Projections 

2.1	 What is your company’s approximate market share in each of the product classes? 

2.2	 Would you expect your market share to change once standards become effective? 

Does your outlook change with higher efficiency levels? 

2.3	 How would you expect shipments to change for the industry as a whole as a function 

of standards and why? 

2.4	 Looking at price/cost effects only, how would you expect shipments to change for a 

25 percent, 50 percent, 100 percent, or 200 percent manufacturer price/cost increase? 

3 Conversion Costs 

3.1	 What level of capital expenditure and product conversion costs would you anticipate 

to make at higher standard levels? Please describe what they are and provide your 

best estimate of their respective magnitudes. 

3.2	 How would the imposition of new energy conservation standards affect capacity 

utilization and manufacturing assets at your domestic production facilities? Would a 

new standard result in stranded capital assets? Would any facilities be closed or 

downsized? Added or upgraded? 

3.3	 How might a new standard impact product innovation? 

12-A-1
 

EERE-2008-BT-STD-0012 COMMENT 22
4 Product Mix and Profitability 

4.1	 How would your company’s product mix and marketing strategy change with 

changes in the efficiency standard? 

4.2	 Would the current percentage of shipments at the Energy Star level be the same 

under a new standard? 

4.3	 What distribution channels are used from the manufacturer to the retail outlet? What 

is the share of product going through each distribution channel? 

4.4	 Generally, how would new product standards affect your customer mix, distribution 

channels, and corresponding profit margins? 

4.5	 How might a new standard affect the Energy Star program, and consequently your 

firm? 

5 Market Shares and Industry Consolidation 

5.1	 In the absence of new standards, do you expect any industry consolidation? 

5.2	 How would new standards affect your ability to compete? 

5.3	 Could new standards disproportionately advance or harm the competitive positions 

of some firms? 

5.4	 Are there concerns over intellectual property? 

5.5	 Could new standards result in disproportionate economic or performance penalties 

for particular consumer/user subgroups? 

5.6	 Beyond price and energy efficiency, could new standards result in products that will 

be more or less desirable to consumers due to changes in product functionality, 

utility, or other features? 

6 Cumulative Regulatory Burden 

6.1	 Are there recent or impending regulations on your specific product or other products 

that impose a cumulative burden on the industry? 

6.2	 If so, what is the total expected impact of those other regulations? 

12-A-2
 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 13. UTILITY IMPACT ANALYSIS 

TABLE OF CONTENTS 

13.1 INTRODUCTION ......................................................................................................... 13-1 

13.2 METHODOLOGY ........................................................................................................ 13-2 

13.3 RESULTS ...................................................................................................................... 13-3 

13-i 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

         

CHAPTER 13. UTILITY IMPACT ANALYSIS 

13.1 INTRODUCTION 

The Department of Energy (DOE) will analyze specific effects of its proposed standard 

levels on the electric utility industry as part of the notice of proposed rulemaking analyses, using 

a variant of the U.S. DOE/Energy Information Administration (EIA)’s National Energy 

Modeling System (NEMS). The NEMS is a large, multi-sectoral, partial equilibrium model of 

the U.S. energy sector. EIA uses NEMS to produce the Annual Energy Outlook (AEO).

1

 NEMS 

produces a widely recognized baseline energy forecast for the United States, and this energy 

forecast is available in the public domain. DOE will use a variant known as NEMS-BT to 

provide key inputs to the analysis.a

The utility impact analysis will consist of a comparison between model results for the 

base case and for policy cases in which proposed standards are in place. The use of NEMS-BT 

for the utility analysis offers several advantages. As the official DOE energy forecasting model, 

NEMS relies on a set of assumptions that are transparent and have received wide exposure and 

commentary. NEMS-BT allows an estimate of the interactions between the various energy 

supply and demand sectors and the economy as a whole. The utility impact analysis will report 

the changes in installed capacity and generation, by fuel type, that result for each trial standard 

level, as well as changes in electricity and natural gas sales to the residential and commercial 

sectors. 

DOE plans to conduct the utility impact analysis as a policy deviation from the 2009 

version of the AEO that reflect provisions of the American Recovery and Reinvestment Act 

(ARRA) and recent changes in the economic outlook (AEO2009),1 applying the same basic set of 

assumptions. For example, the operating characteristics (e.g., energy conversion efficiency, 

emissions rates) of future electricity generating plants are as specified in the AEO2009 reference 

case. DOE also will explore deviations from some of the reference case assumptions, to represent 

alternative futures. Two alternative scenarios use the high and low economic growth cases. 

(The reference case corresponds to medium growth.) The high economic growth case assumes 

higher projected growth rates for population, labor force, and labor productivity, resulting in 

lower predicted inflation and interest rates relative to the reference case and higher overall 

aggregate economic growth. The opposite is true for the low growth case. Because EIA does 

not plan to produce high and low economic growth cases corresponding to the AEO2009 that 

a  For more information on NEMS, please refer to the U.S. Department of Energy, Energy Information 

Administration documentation.  A useful summary is National Energy Modeling System: An Overview 2000,

DOE/EIA‐0581(2000), March 2000.  EIA approves use of the name NEMS to describe only an official version

of the model without any modification to code or data.  Because this analysis entails some minor code

modifications and the model is run under various policy scenarios that are variations on EIA assumptions, 

DOE refers to the model by the name NEMS‐BT (BT is DOE’s Building Technol

aegis this work has been performed).  NEMS‐BT was previously called NEMS‐BRS. 

ogies Program, under whose

13-1 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

includes the ARRA, DOE plans to estimate these cases based on the March 2009 release of the 

AEO2009 that excludes the ARRA.2 

13.2 METHODOLOGY 

The electric utility impact analysis will consist of NEMS-BT forecasts for generation, 

installed capacity, sales, and prices. NEMS provides reference case load shapes for several end 

uses. The model uses predicted growth in demand for each end use to build up a projection of 

the total electric system load growth for each region, which it uses in turn to predict the 

necessary additions to capacity. NEMS-BT accounts for the implementation of efficiency 

standards by decrementing the appropriate reference case load shape. DOE will determine the 

size of the decrement using data for the per-unit energy savings developed in the life-cycle cost 

and payback period analysis (Chapter 8) and the forecast of shipments developed for the national 

impact analysis (Chapter 9). 

The predicted reduction in capacity additions is sensitive to the peak load impacts of the 

standard. DOE will investigate the need to adjust the hourly load profiles that include this end 

use in NEMS-BT. 

 Since the AEO2009 version of NEMS forecasts only to the year 2030, DOE must 

extrapolate results to 2044. DOE conducts an extrapolation to 2044 to be consistent with the 

analysis period being used by DOE in the national impact analysis (NIA). It will not be feasible 

to extend the forecast period of NEMS-BT for the purposes of this analysis, nor does EIA have 

an approved method for extrapolation of many outputs beyond 2030. While it might seem 

reasonable in general to make simple linear extrapolations of results, in practice this is not 

advisable because outputs could be contradictory. For example, changes in the fuel mix implied 

by extrapolations of those outputs could be inconsistent with the extrapolation of marginal 

emissions factors. An analysis of various trends sufficiently detailed to guarantee consistency is 

beyond the scope of this work and, in any case, would involve a great deal of uncertainty. 

Therefore, for all extrapolations beyond 2030, DOE intends to use simple replications of year 

2030 results; in this way results are guaranteed to be consistent. As with the AEO reference case 

in general, the implicit assumption is that the regulatory environment does not deviate from the 

current known situation during the extrapolation period. Only changes that have been announced 

with date-certain introduction are included in NEMS-BT. 

For petroleum products, EIA uses the average growth rate for the world oil price over the 

years 2010 to 2025, in combination with the refinery and distribution markups from the year 

2025, to determine the regional price forecasts. Similarly, EIA derives natural gas prices from an 

average growth rate figure in combination with regional price margins from the year 2025. 

13-2 

EERE-2008-BT-STD-0012 COMMENT 22
13.3 RESULTS 

Results of the analysis will include changes in residential and commercial electricity 

sales, installed capacity and generation by fuel type for each trial standard level, in five-year 

increments extrapolated to the year 2044. 

13-3 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

REFERENCES 

1	 U.S. Department of Energy-Energy Information Administration. An Updated Annual Energy 

Outlook 2009 Reference Case Reflecting Provisions of the American Recovery and 

Reinvestment Act and Recent Changes in the Economic Outlook, April, 2009. Washington, 

DC. SR/OIAF/2009-03. 

<http://www.eia.doe.gov/oiaf/servicerpt/stimulus/pdf/sroiaf(2009)03.pdf> 

2	 U.S. Department of Energy-Energy Information Administration. Annual Energy Outlook with 

Projections to 2030, March, 2009. Washington, DC. DOE/EIA-0383(2009). 

<http://www.eia.doe.gov/oiaf/aeo/aeoref_tab.html> 

13-4 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 14. EMPLOYMENT IMPACT ANALYSIS 

TABLE OF CONTENTS 

14.1 INTRODUCTION ......................................................................................................... 14-1 

14.2 METHODOLOGY ........................................................................................................ 14-1 

14-i 

EERE-2008-BT-STD-0012 COMMENT 22
CHAPTER 14. EMPLOYMENT IMPACT ANALYSIS
 

14.1 INTRODUCTION 

The Department of Energy (DOE) intends the employment impact analysis to estimate 

national job creation or job elimination resulting from possible new standards, due to reallocation 

of the associated expenditures for purchasing and operating equipment. DOE will conduct this 

analysis as one of the analyses for the notice of proposed rulemaking (NOPR). DOE will 

estimate national impacts on major sectors of the U.S. economy, using publicly available data 

and incorporating different energy price scenarios that it will carry out as part of the analysis for 

the NOPR. DOE will make all methods and documentation available for review. 

The imposition of standards can impact employment both directly and indirectly. Direct 

employment impacts are changes in the number of employees at the plants that produce the 

covered equipment, along with the affiliated distribution and service companies, resulting from 

the imposition of standards. DOE will evaluate direct employment impacts in its manufacturer 

impact analysis, as described in Chapter 12. Indirect employment impacts may result from 

expenditures shifting between goods (the substitution effect) and changes in income and overall 

expenditure levels (the income effect) that occur due to the imposition of standards. 

DOE expects new equipment standards to decrease energy consumption, and therefore to 

reduce expenditures for energy. The savings in energy expenditures may be spent on new 

investment and other items. The standards may increase the purchase price of equipment, 

including the retail price plus sales tax, and increase installation costs. 

Using an input-output model of the U.S. economy, this analysis seeks to estimate the 

year-to-year effect of these expenditure impacts on net economic output and employment. 

A simple model might involve reduced expenditures for energy and reallocation of that money 

toward other sectors in the economy. DOE intends the employment impact analysis to quantify 

the indirect employment impacts of these expenditure changes. It will evaluate direct 

employment impacts in the manufacturer impact analysis step of the process. 

14.2 METHODOLOGY 

To investigate the combined direct and indirect employment impacts, DOE will use the 

Pacific Northwest National Laboratory (PNNL)’s ‘Impact of Sector Energy Technologies’ 

(ImSET) model.1

 PNNL developed ImSET, a spreadsheet model of the U.S. economy that 

focuses on 188 sectors most relevant to industrial, commercial, and residential building energy 

use, for DOE’s Office of Energy Efficiency and Renewable Energy. ImSET is a special-purpose 

version of the U.S. Benchmark National Input-Output (I-O) model, which has been designed to 

estimate the national employment and income effects of energy saving technologies that are 

deployed by DOE’s Office of Energy Efficiency and Renewable Energy. In comparison with the 

14-1 

EERE-2008-BT-STD-0012 COMMENT 22
 

previous versions of the model used in earlier rulemakings, this version allows for more 

complete and automated analysis of the essential features of energy efficiency investments in 

buildings, industry, transportation, and the electric power sectors. 

The ImSET software includes a computer-based I-O model with structural coefficients to 

characterize economic flows among the 188 sectors. ImSET’s national economic I-O structure is 

based on the 1997 Benchmark U.S. table, specially aggregated to 188 sectors.2 

DOE intends to use the ImSet model to estimate changes in employment, industry output, 

and wage income in the overall U.S. economy resulting from changes in expenditures in the 

various sectors of the economy. For example, commercial clothes washer standards may reduce 

energy expenditures and increase equipment prices in the commercial sector. These expenditure 

changes are likely to reduce commercial and energy sector employment. At the same time, these 

equipment standards may increase commercial sector investment, and increase employment in 

other sectors of the economy. DOE designed the employment impact analysis to estimate the 

year-to-year net national employment effect of these different expenditure flows. 

14-2 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

REFERENCES 

1	 Roop, J. M., M. J. Scott, and R. W. Schultz. ImSET: Impact of Sector Energy Technologies, 

2005. Pacific Northwest National Laboratory, Richland, WA. PNNL- 15273. 

2	 Lawson, Ann M., Kurt S. Bersani, Mahnaz Fahim-Nader, and Jiemin Guo. “Benchmark 

Input-Output Accounts of the U. S. Economy, 1997,” Survey of Current Business, December 

2002. pp. 19-117. 

14-3 

EERE-2008-BT-STD-0012 COMMENT 22
ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY CONSERVATION 

STANDARDS FOR RESIDENTIAL REFRIGERATAORS, REFRIGERATORFREEZERS, AND FREEZERS 

TABLE OF CONTENTS 

1.0 INTRODUCTION ........................................................................................................EA-1 

2.0 METHODOLOGY .......................................................................................................EA-2 

2.1 Air Emissions................................................................................................................EA-2 

2.2 Economic Value of Emission Reductions.....................................................................EA-5 

3.0 RESULTS ...................................................................................................................EA-15 

LIST OF TABLES 

Table EA.1 Global Social Cost of Carbon (SCC) Estimates ($/t CO2 in 2007 (2006$)), 

Based on 3% and 5% Discount Rates................................................................EA-10 

Table EA.2 Global Social Cost of Carbon Estimates ($/t CO2 in 2007 in 2006$), Using 

Newell & Pizer Adjustment for Future Discount Rate Uncertainty ..................EA-12
 

EA-i 

EERE-2008-BT-STD-0012 COMMENT 22
 

ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY CONSERVATION 

STANDARDS FOR RESIDENTIAL REFRIGERATAORS, REFRIGERATORFREEZERS, AND FREEZERS 

1.0 INTRODUCTION 

The Department of Energy (DOE) will conduct an environmental assessment as part of 

the notice of proposed rulemaking. DOE will assess the impacts of proposed energy 

conservation standards for residential refrigerators, refrigerator-freezers, and freezers on certain 

environmental indicators using a variant of the U.S. DOE/Energy Information Administration 

(EIA)’s National Energy Modeling System (NEMS).a EIA uses NEMS to produce the Annual 

Energy Outlook (AEO).1 DOE will use a variant known as NEMS-BT to provide key inputs to 

the analysis, based on the 2009 version of the AEO (AEO2009). Results of the environmental 

assessment will be similar to those provided in AEO2009. 

DOE intends the environmental assessment to provide emissions results to policymakers 

and other stakeholders, and to fulfill requirements that the environmental effects of all new 

Federal rules be properly quantified and considered. The environmental assessment considers 

three pollutants— sulfur dioxide (SO2), nitrogen oxides (NOx), and mercury (Hg)—as well as 

carbon emissions. The only form of carbon emissions tracked by NEMS-BT is carbon dioxide 

(CO2), so the carbon discussed in this report is only in the form of CO2. For each of the trial 

standard levels, DOE will calculate total emissions using NEMS-BT, using additional, external 

analysis as needed. 

Although DOE plans to consider only SO2, NOx, mercury, and CO2 in its environmental 

assessment, there are other air pollutants which are of concern. Specifically, the Clean Air Act 

requires the Environmental Protection Agency (EPA) to set National Ambient Air Quality 

Standards for the following six common air pollutants, also know as “criteria pollutants”: (1) 

ozone, (2) particulate matter (PM), (3) carbon monoxide (CO), (4) nitrogen dioxide, (5) SO2, and 

(6) lead.2 EPA recently added to this list mercury. But none of the “criteria pollutants” not 

already considered (i.e., ozone, PM, CO, and lead) are driven significantly by electric utility 

power plants. Therefore, DOE does not intend on addressing them in the environmental 

assessment. In the case of ozone and particulate matter, other pollutants are precursors to their 

formation and atmospheric conditions are the driver behind their formation. Also, SO2 and NOx 

are the primary precursors to ozone and PM, respectively, and will already be addressed by the 

environmental assessment. In the case of CO, electric utilities are not significant sources. For 

electric power plants, almost all carbon emissions come out in the form of CO2 as the 

combustion process is lean enough not to yield CO in significant amounts. Finally, with regard 

to lead, the ban on the use of leaded gasoline has resulted in a dramatic decrease in lead 

emissions since the mid 1970s. Now industrial processes (not electric utilities), particularly 

a For more information on NEMS, please refer to the U.S. Department of Energy, Energy Information 

Administration documentation. A useful summary is National Energy Modeling System: An Overview 2000, 

DOE/EIA-0581(2000), March 2000. EIA approves use of the name NEMS to describe only an official version of 

the model without any modification to code or data. Because this analysis entails some minor code modifications 

and the model is run under various policy scenarios that are variations on EIA assumptions, DOE refers to the model 

as NEMS-BT (BT is DOE’s Building Technologies Program). NEMS-BT was previously called NEMS-BRS. 

EA-1 

EERE-2008-BT-STD-0012 COMMENT 22
primary and secondary lead smelters and battery manufacturers, are responsible for most of lead 

emissions and all violations of the lead air quality standards. 

2.0 METHODOLOGY 

DOE plans to conduct the utility impact analysis as a policy deviation from the 2009 

version of the AEO that reflect provisions of the American Recovery and Reinvestment Act 

(ARRA) and recent changes in the economic outlook (AEO2009),1

 applying the same basic set of 

assumptions. For example, the emissions characteristics of an electricity generating plant will be 

exactly those used in AEO2009. The NEMS reference case and alternative growth scenarios are 

as described in the utility impact analysis (see Chapter 13 of the preliminary technical support 

document). Below are descriptions of the air emissions that DOE will analyze in the 

environmental assessment. 

2.1 Air Emissions 

Carbon Dioxide (CO2) 

Carbon dioxide (CO2) is not a regulated or criteria pollutant, but it is of interest because 

of its classification as a greenhouse gas (GHG). GHGs trap the sun’s radiation inside the Earth’s 

atmosphere and either occur naturally in the atmosphere or result from human activities. 

Naturally occurring GHGs include water vapor, CO2, methane (CH4), nitrous oxide (N2O), and 

ozone (O3). Human activities, however, add to the levels of most of these naturally occurring 

gases. For example, CO2 is emitted to the atmosphere when solid waste, fossil fuels (oil, natural 

gas, and coal), wood, and wood products are burned. During the past 20 years, about threequarters of anthropogenic (i.e., human-made) CO2 emissions resulted from burning fossil fuels. 

Concentrations of CO2 in the atmosphere are naturally regulated by numerous processes, 

collectively known as the “carbon cycle.” The movement of carbon between the atmosphere and 

the land and oceans is dominated by natural processes, such as plant photosynthesis. While these 

natural processes can absorb some of the anthropogenic CO2 emissions produced each year, 

billions of metric tons are added to the atmosphere annually. In the U. S., CO2 emissions from 

both energy generation and industrial processes account for 84.6 percent of total U.S. GHG 

emissions. 

NEMS-BT tracks carbon emissions using a detailed carbon module; this approach 

provides good results because of its broad coverage of all sectors and inclusion of interactive 

effects. Past experience with carbon results from NEMS suggests that the NEMS-generated 

emissions estimates are somewhat lower than estimates based on simple average factors. One of 

the reasons for this divergence is that NEMS tends to predict that conservation displaces 

renewable generating capacity in the later years of its forecast. On the whole, NEMS-BT 

provides carbon emissions results of reasonable accuracy, at a level consistent with other 

published Federal results. 

EA-2 

EERE-2008-BT-STD-0012 COMMENT 22
Sulfur Dioxide (SO2) 

The NEMS-BT model reports the two airborne pollutant emissions that DOE has reported 

in past analyses, SO2 and NOx. The Clean Air Act Amendments of 1990 set an SO2 emissions 

cap on all power generation.3

 The attainment of this target, however, is flexible among 

generators through the use of emissions allowances and tradable permits. The NEMS-BT model 

includes a module for SO2 allowance trading and delivers a forecast of SO2 allowance prices. 

Accurate simulation of SO2 trading tends to imply that physical emissions effects will be zero, as 

long as emissions are at the ceiling. But to the extent reduced power generation demand 

decreases the demand for and price of emissions allowance permits, there is an environmentally 

related economic benefit from the proposed energy conservation standards reducing SO2 

emissions allowance demand. Furthermore, over time, if emissions decline, there is greater 

flexibility in reducing the ceiling amount. However, since DOE does not anticipate a change in 

SO2 emissions, DOE does not plant to report SO2 emission impacts. There is an SO2 benefit 

from conservation in the form of a lower allowance price but, since the impact of any one 

standard on the allowance price is likely small and highly uncertain, DOE does not plan to 

monetize the SO2 benefit. 

Nitrogen Oxides (NOx)

 Nitrogen oxides, or NOx, are the generic term for a group of highly reactive gases, all of 

which contain nitrogen and oxygen in varying amounts. Many of the nitrogen oxides are 

colorless and odorless. However, one common pollutant, nitrogen dioxide (NO2), along with 

particles in the air can often be seen as a reddish-brown layer over many urban areas. NO2 is the 

specific form of NOx reported in this document. NOx is one of the main ingredients involved in 

the formation of ground-level ozone, which can trigger serious respiratory problems. It can 

contribute to the formation of acid rain, and can impair visibility in areas such as national parks. 

NOx also contributes to the formation of fine particles that can impair human health. 

Nitrogen oxides form when fossil fuel is burned at high temperatures, as in a combustion 

process. The primary manmade sources of NOx are motor vehicles, electric utilities, and other 

industrial, commercial, and residential sources that burn fossil fuels. NOx can also be formed 

naturally. Electric utilities account for about 22 percent of NOx emissions in the United States. 

NEMS-BT also has an algorithm for estimating NOx emissions from power generation. 

The impact of these emissions, however, will be affected by the Clean Air Interstate Rule 

(CAIR), which the U.S. Environmental Protection Agency (EPA) issued under sections 110 and 

111 of the Clean Air Act (40 CFR Parts 51, 96, and 97) on May 12, 2005.4 CAIR will 

permanently cap emissions of SO2 and NOx in eastern states of the United States. CAIR 

achieves large reductions of SO2 and/or NOx emissions across 28 eastern states and the District 

of Columbia (DC). States must achieve the required emission reductions using one of two 

compliance options: 1) meet an emission budget for each regulated state by requiring power 

plants to participate in an EPA-administered interstate cap-and-trade system that caps emissions 

in two stages, or 2) meet an individual state emissions budget through measures of the state’s 

choosing. Phase 1 caps for NOx are to be in place in 2009. Phase 1 caps for SO2 are to be in 

place in 2010. The Phase 2 caps for both pollutants are due in 2015. 

EA-3 

EERE-2008-BT-STD-0012 COMMENT 22
 

On July 11, 2008, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. 

Circuit) issued its decision in North Carolina v. Environmental Protection Agency, which 

vacated the CAIR issued by the U.S. Environmental Protection Agency on March 10, 2005.5 

But on December 23, 2008, the D.C. Circuit decided to allow CAIR to remain in effect until it is 

replaced by a rule consistent with the court’s earlier opinion. North Carolina v. Environmental 

Protection Agency, 550 F.3d 1176 (D.C. Cir. 2008) (remand of vacatur). 

The NEMS-BT version to be used by DOE to estimate NOx emission impacts includes 

the cap on NOx emissions as specified by CAIR. As with SO2 emissions, a cap on NOx 

emissions means that equipment efficiency standards may have no physical effect on these 

emissions in the 28 eastern states and DC. When NOx emissions are subject to emissions caps, 

DOE’s emissions reduction estimate corresponds to incremental changes in the prices of 

emissions allowances in cap-and-trade emissions markets rather than physical emissions 

reductions. Therefore, while the emissions cap may mean that physical emissions reductions 

will not result from standards in those states covered by CAIR, standards could produce an 

environmental-related economic benefit in the form of lower prices for emissions allowance 

credits. However, as with SO2 allowance prices, DOE does not plan to monetize this benefit 

because the impact on the NOx allowance price from any single energy conservation standard is 

likely small and highly uncertain. For those states not covered by CAIR, DOE intends to 

estimate the impact on NOx emissions using NEMS-BT. 

Mercury (Hg) 

Coal-fired power plants emit Hg found in coal during the burning process. While coalfired power plants are the largest remaining source of human-generated Hg emissions in the 

United States, they contribute very little to the global Hg pool or to contamination of U.S. 

waters. U.S. coal-fired power plants emit Hg in three different forms: oxidized Hg (likely to 

deposit within the United States); elemental Hg, which can travel thousands of miles before 

depositing to land and water; and Hg that is in particulate form. Atmospheric Hg is then 

deposited on land, lakes, rivers, and estuaries through rain, snow, and dry deposition. Once 

there, it can transform into methylmercury and accumulate in fish tissue through 

bioaccumulation. 

Americans are exposed to methylmercury primarily by eating contaminated fish. Because 

the developing fetus is the most sensitive to the toxic effects of methylmercury, women of 

childbearing age are regarded as the population of greatest concern. Children exposed to 

methylmercury before birth may be at increased risk of poor performance on neurobehavioral 

tasks, such as those measuring attention, fine motor function, language skills, visual-spatial 

abilities, and verbal memory. 

NEMS-BT has an algorithm for estimating these emissions from power generation. EPA 

issued on May 18, 2005 the final rule entitled “Standards of Performance for New and Existing 

Stationary Sources: Electric Steam Generating Units,” under sections 110 and 111 of the Clean 

Air Act (40 CFR Parts 60, 63, 72, and 75).6 This rule, also called the Clean Air Mercury Rule 

(CAMR), was closely related to the CAIR and established standards of performance for Hg 

EA-4 

EERE-2008-BT-STD-0012 COMMENT 22
 

emissions from new and existing coal-fired electric utility steam generating units. The CAMR 

regulated Hg emissions from coal-fired power plants. But on February 8, 2008, the U.S. Court 

of Appeals for the District of Columbia Circuit (D.C. Circuit) issued its decision in State of New 

Jersey, et al. v. Environmental Protection Agency,

7

 in which the Court, among other actions, 

vacated the CAMR referenced above. EPA has recently decided to develop emissions standards 

for power plants under the Clean Air Act (Section 112), consistent with the D.C. Circuit’s 

opinion on the CAMR. Accordingly, on February 6, 2009, the Department of Justice, on behalf 

of EPA, asked the Supreme Court to dismiss EPA’s request (petition for certiorari) that the Court 

review the D.C. Circuit Court’s vacatur of the Clean Air Mercury Rule (CAMR). On February 

23, 2009, the Court also denied the Utility Air Regulatory Group’s request to review the U.S. 

Circuit Court of Appeals decision. 

The NEMS-BT version to be used by DOE to estimate Hg emission impacts does not cap 

Hg emissions and will not do so until the EPA issues a rule regarding Hg that is consistent with 

the Court’s decision. 

2.2 Economic Value of Emission Reductions 

In examining the impact of potential standards, DOE plans to assess potential monetary 

benefits from reduced emissions of CO2, NOx, Hg, and SO2 associated with this rulemaking. 

Carbon Dioxide (CO2) 

DOE plans on relying on a set of values developed by an interagency process that 

conducted a thorough review of existing estimates of the social cost of carbon (SCC). The SCC 

is intended to be a monetary measure of the incremental damage resulting from greenhouse gas 

(GHG) emissions, including, but not limited to, net agricultural productivity loss, human health 

effects, property damages from sea level rise, and changes in ecosystem services. Any effort to 

quantify and to monetize the harms associated with climate change will raise serious questions of 

science, economics, and ethics. But with full regard for the limits of both quantification and 

monetization, the SCC can be used to provide estimates of the social benefits of reductions in 

GHG emissions. 

For at least three reasons, any single estimate of the SCC will be contestable. First, 

scientific and economic knowledge about the impacts of climate change continues to grow. With 

new and better information about relevant questions, including the cost, burdens, and possibility 

of adaptation, current estimates will inevitably change over time. Second, some of the likely and 

potential damages from climate change—for example, the value society places on adverse 

impacts on endangered species—are not included in all of the existing economic analyses. These 

omissions may mean that the best current estimates are too low. Third, controversial ethical 

judgments, including those involving the treatment of future generations, play a role in 

judgments about the SCC (see in particular the discussion of the discount rate, below). 

To date, regulations have used a range of values for the SCC. For example, a regulation 

proposed by the U.S. Department of Transportation (DOT) in 2008 assumed a value of $7 per 

ton CO2 (2006$) for 2011 emission reductions (with a range of $0–14 for sensitivity analysis). 

Regulation finalized by DOE used a range of $0–$20 (2007$). Both of these ranges were 

EA-5 

EERE-2008-BT-STD-0012 COMMENT 22
designed to reflect the value of damages to the United States resulting from carbon emissions, or 

the “domestic” SCC. In the final Model Year 2011 Corporate Average Fuel Economy rule, DOT 

used both a domestic SCC value of $2/t CO2 and a global SCC value of $33/t CO2 (with 

sensitivity analysis at $80/tCO2), increasing at 2.4 percent per year thereafter. 

In recent months, a variety of agencies have worked to develop an objective methodology 

for selecting a range of interim SCC estimates to use in regulatory analyses until improved SCC 

estimates are developed. The following summary reflects the initial results of these efforts and 

proposes ranges and values for interim social costs of carbon used in this rule. It should be 

emphasized that the analysis described below is preliminary. These complex issues are of course 

undergoing a process of continuing review. Relevant agencies will be evaluating and seeking 

comment on all of the scientific, economic, and ethical issues before establishing final estimates 

for use in future rulemakings. 

The interim judgments resulting from the recent interagency review process can be 

summarized as follows: (a) DOE and other Federal agencies should consider the global benefits 

associated with the reductions of CO2 emissions resulting from efficiency standards and other 

similar rulemakings, rather continuing the previous focus on domestic benefits; (b) these global 

benefits should be based on SCC estimates (in 2007$) of $55, $33, $19, $10, and $5 per ton of 

CO2 equivalent emitted (or avoided) in 2007; (c) the SCC value of emissions that occur (or are 

avoided) in future years should be escalated using an annual growth rate of 3 percent from the 

current values); and (d) domestic benefits are estimated to be approximately 6 percent of the 

global values. These interim judgments are based on the following considerations. 

1.	 Global and domestic estimates of SCC. Because of the distinctive nature of the climate 

change problem, estimates of both global and domestic SCC values should be considered, 

but the global measure should be “primary.” This approach represents a departure from 

past practices, which relied, for the most part, on measures of only domestic impacts. As 

a matter of law, both global and domestic values are permissible; the relevant statutory 

provisions are ambiguous and allow the agency to choose either measure. (It is true that 

Federal statutes are presumed not to have extraterritorial effect, in part to ensure that the 

laws of the United States respect the interests of foreign sovereigns. But use of a global 

measure for the SCC does not give extraterritorial effect to Federal law and hence does 

not intrude on such interests.) 

It is true that under OMB guidance, analysis from the domestic perspective is required, 

while analysis from the international perspective is optional. The domestic decisions of 

one nation are not typically based on a judgment about the effects of those decisions on 

other nations. But the climate change problem is highly unusual in the sense that it 

involves (a) a global public good in which (b) the emissions of one nation may inflict 

significant damages on other nations and (c) the United States is actively engaged in 

promoting an international agreement to reduce worldwide emissions. 

In these circumstances, the global measure is preferred. Use of a global measure reflects 

the reality of the problem and is expected to contribute to the continuing efforts of the 

United States to ensure that emission reductions occur in many nations. 

EA-6 

EERE-2008-BT-STD-0012 COMMENT 22
Domestic SCC values are also presented. The development of a domestic SCC is greatly 

complicated by the relatively few region- or country-specific estimates of the SCC in the 

literature. One potential estimate comes from the DICE (Dynamic Integrated Climate 

Economy, William Nordhaus) model. In an unpublished paper, Nordhaus (2007) 

produced disaggregated SCC estimates using a regional version of the DICE model. He 

reported a U.S. estimate of $1/tCO2 (2007 value, 2007$), which is roughly 11 percent of 

the global value. 

An alternative source of estimates comes from a recent EPA modeling effort using the 

FUND (Climate Framework for Uncertainty, Negotiation and Distribution, Center for 

Integrated Study of the Human Dimensions of Global Change) model. The resulting 

estimates suggest that the ratio of domestic to global benefits varies with key parameter 

assumptions. With a 3-percent discount rate, for example, the U.S. benefit is about 6 

percent of the global benefit for the “central” (mean) FUND results, while, for the 

corresponding “high” estimates associated with a higher climate sensitivity and lower 

global economic growth, the U.S. benefit is less than 4 percent of the global benefit. With 

a 2-percent discount rate, the U.S. share is about 2 to5 percent of the global estimate. 

Based on this available evidence, a domestic SCC value equal to 6 percent of the global 

damages is used in this rulemaking. This figure is in the middle of the range of available 

estimates from the literature. It is recognized that the 6 percent figure is approximate and 

highly speculative and alternative approaches will be explored before establishing final 

values for future rulemakings. 

2.	 Filtering existing analyses. There are numerous SCC estimates in the existing literature, 

and it is legitimate to make use of those estimates to produce a figure for current use. A 

reasonable starting point is provided by the meta-analysis in Richard Tol, “The Social 

Cost of Carbon: Trends, Outliers, and Catastrophes, Economics: The Open-Access, 

Open-Assessment E-Journal,” Vol. 2, 2008-25. http://www.economicsejournal.org/economics/journalarticles/2008-25 (2008). With that starting point, it is 

proposed to “filter” existing SCC estimates by using those that (1) are derived from peerreviewed studies; (2) do not weight the monetized damages to one country more than 

those in other countries; (3) use a “business as usual” climate scenario; and (4) are based 

on the most recent published version of each of the three major integrated assessment 

models (IAMs): FUND, DICE and PAGE (Policy Analysis of the Greenhouse Effect). 

Proposal (1) is based on the view that those studies that have been subject to peer review 

are more likely to be reliable than those that have not been. Proposal (2) is based on a 

principle of neutrality and simplicity; it does not treat the citizens of one nation 

differently on the basis of speculative or controversial considerations. Proposal (3) stems 

from the judgment that as a general rule, the proper way to assess a policy decision is by 

comparing the implementation of the policy against a counterfactual state where the 

policy is not implemented. A departure from this approach would be to consider a more 

dynamic setting in which other countries might implement policies to reduce GHG 

EA-7 

EERE-2008-BT-STD-0012 COMMENT 22
emissions at an unknown future date, and the United States could choose to implement 

such a policy now or in the future. 

Proposal (4) is based on three complementary judgments. First, the FUND, PAGE, and 

DICE models now stand as the most comprehensive and reliable efforts to measure the 

damages from climate change. Second, the latest versions of the three IAMs are likely to 

reflect the most recent evidence and learning, and hence they are presumed to be superior 

to those that preceded them. It is acknowledged that earlier versions may contain 

information that is missing from the latest versions. Third, any effort to choose among 

them, or to reject one in favor of the others, would be difficult to defend at this time. In 

the absence of a clear reason to choose among them, it is reasonable to base the SCC on 

all of them. 

The agency is keenly aware that the current IAMs fail to include all relevant information 

about the likely impacts from greenhouse gas emissions. For example, ecosystem 

impacts, including species loss, do not appear to be included in at least two of the models. 

Some human health impacts, including increases in food-borne illnesses and in the 

quantity and toxicity of airborne allergens, also appear to be excluded. In addition, there 

has been considerable recent discussion of the risk of catastrophe and of how best to 

account for worst-case scenarios. It is not clear whether the three IAMs take adequate 

account of these potential effects. 

3.	 Use a model-weighted average of the estimates at each discount rate. At this time, there 

appears to be no scientifically valid reason to prefer any of the three major IAMs (FUND, 

PAGE, and DICE). Consequently, the estimates are based on an equal weighting of 

estimates from each of the models. Among estimates that remain after applying the filter, 

the average of all estimates within a model is derived. The estimated SCC is then 

calculated as the average of the three model-specific averages. This approach ensures that 

the interim estimate is not biased towards specific models or more prolific authors. 

4. Apply a 3-percent annual growth rate to the chosen SCC values. SCC is assumed to 

increase over time, because future emissions are expected to produce larger incremental 

damages as physical and economic systems become more stressed as the magnitude of 

climate change increases. Indeed, an implied growth rate in the SCC is produced by most 

studies that estimate economic damages caused by increased GHG emissions in future 

years. But neither the rate itself nor the information necessary to derive its implied value 

is commonly reported. In light of the limited amount of debate thus far about the 

appropriate growth rate of the SCC, applying a rate of 3 percent per year seems 

appropriate at this stage. This value is consistent with the range recommended by IPCC 

(2007) and close to the latest published estimate (Hope, 2008). 

For climate change, one of the most complex issues involves the appropriate discount 

rate. OMB’s current guidance offers a detailed discussion of the relevant issues and calls for 

discount rates of 3 percent and 7 percent. It also permits a sensitivity analysis with low rates for 

intergenerational problems. (“If your rule will have important intergenerational benefits or costs 

you might consider a further sensitivity analysis using a lower but positive discount rate in 

EA-8 

EERE-2008-BT-STD-0012 COMMENT 22
addition to calculating net benefits using discount rates of 3 and 7 percent.”) The SCC is being 

developed within the general context of the current guidance. 

The choice of a discount rate, especially over long periods of time, raises highly 

contested and exceedingly difficult questions of science, economics, philosophy, and law. See, 

e.g., William Nordhaus, “The Challenge of Global Warming (2008); Nicholas Stern, The 

Economics of Climate Change” (2007); “Discounting and Intergenerational Equity” (Paul 

Portney and John Weyant, eds., 1999). Under imaginable assumptions, decisions based on costbenefit analysis with high discount rates might harm future generations—at least if investments 

are not made for the benefit of those generations. (See Robert Lind, “Analysis for 

Intergenerational Discounting,” id. at 173, 176–177.) At the same time, use of low discount rates 

for particular projects might itself harm future generations, by ensuring that resources are not 

used in a way that would greatly benefit them. In the context of climate change, questions of 

intergenerational equity are especially important. 

Reasonable arguments support the use of a 3-percent discount rate. First, that rate is 

among the two figures suggested by OMB guidance, and hence it fits with existing National 

policy. Second, it is standard to base the discount rate on the compensation that people receive 

for delaying consumption, and the 3-percent rate is close to the risk-free rate of return, proxied 

by the return on long term inflation-adjusted U.S. Treasury Bonds. (In the context of climate 

change, it is possible to object to this standard method for deriving the discount rate.) Although 

these rates are currently closer to 2.5 percent, the use of 3 percent provides an adjustment for the 

liquidity premium that is reflected in these bonds’ returns. 

At the same time, other arguments support use of a 5-percent discount rate. First, that rate 

can also be justified by reference to the level of compensation for delaying consumption, because 

it fits with market behavior with respect to individuals’ willingness to trade off consumption 

across periods as measured by the estimated post-tax average real returns to private investment 

(e.g., the S&P 500). In the climate setting, the 5-percent discount rate may be preferable to the 

riskless rate because it is based on risky investments and the return to projects to mitigate climate 

change is also risky. In contrast, the 3-percent riskless rate may be a more appropriate discount 

rate for projects where the return is known with a high degree of confidence (e.g., highway 

guardrails). 

Second, 5 percent, and not 3 percent, is roughly consistent with estimates implied by 

reasonable inputs to the theoretically derived Ramsey equation, which specifies the optimal time 

path for consumption. That equation specifies the optimal discount rate as the sum of two 

components. The first reflects the fact that consumption in the future is likely to be higher than 

consumption today (even accounting for climate impacts), so diminishing marginal utility 

implies that the same monetary damage will cause a smaller reduction of utility in the future. 

Standard estimates of this term from the economics literature are in the range of 3 to 5 percent. 

The second component reflects the possibility that a lower weight should be placed on utility in 

the future, to account for social impatience or extinction risk, which is specified by a pure rate of 

time preference (PRTP). A conventional estimate of the PRTP is 2 percent. (Some observers 

believe that a principle of intergenerational equity suggests that the PRTP should be close to 

zero.) It follows that discount rate of 5 percent is within the range of values which are able to be 

EA-9 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

derived from the Ramsey equation, albeit at the low end of the range of estimates usually 

associated with Ramsey discounting. 

It is recognized that the arguments above—for use of market behavior and the Ramsey 

equation—face objections in the context of climate change, and of course there are alternative 

approaches. In light of climate change, it is possible that consumption in the future will not be 

higher than consumption today, and if so, the Ramsey equation will suggest a lower figure. Some 

people have suggested that a very low discount rate, below 3 percent, is justified in light of the 

ethical considerations calling for a principle of intergenerational neutrality. See Nicholas Stern, 

“The Economics of Climate Change” (2007); for contrary views, see William Nordhaus, The A 

Question of Balance (2008); Martin Weitzman, “Review of the Stern Review on the Economics 

of Climate Change." Journal of Economic Literature, 45(3): 703–724 (2007). Additionally, some 

analyses attempt to deal with uncertainty with respect to interest rates over time; a possible 

approach enabling the consideration of such uncertainties is discussed below. Richard Newell 

and William Pizer, “Discounting the Distant Future: How Much do Uncertain Rates Increase 

Valuations?” J. Environ. Econ. Manage. 46 (2003) 52-71. 

The application of the methodology outlined above yields estimates of the SCC that are 

reported in Table EA.1. These estimates are reported separately using 3-percent and 5-percent 

discount rates. The cells are empty in rows 10 and 11 because these studies did not report 

estimates of the SCC at a 3-percent discount rate. The model-weighted means are reported in the 

final or summary row; they are $33 per t CO2 at a 3-percent discount rate and $5 per t CO2 with a 

5-percent discount rate. 

Table EA.1 Global Social Cost of Carbon (SCC) Estimates ($/t CO2 in 2007 (2006$)), 

Based on 3% and 5% Discount Rates* 

Model Study Climate Scenario 3% 5% 

1 FUND Anthoff et al. 2009 FUND default 6 -1 

2 FUND Anthoff et al. 2009 SRES A1b 1 -1 

3 FUND Anthoff et al. 2009 SRES A2 9 -1 

4 FUND Link and Tol 2004 No THC 12 3 

5 FUND Link and Tol 2004 THC continues 12 2 

6 FUND Guo et al. 2006 Constant PRTP 5 -1 

7 FUND Guo et al. 2006 Gollier discount 1 14 0 

8 FUND Guo et al. 2006 Gollier discount 2 7 -1 

FUND Mean 8.25 0 

9 PAGE Wahba & Hope 2006 A2-scen 57 7 

10 PAGE Hope 2006 7 

11 DICE Nordhaus 2008 8 

Summary Model-weighted Mean 33 5 

*The sample includes all peer reviewed, non-equity-weighted estimates included in Tol (2008), Nordhaus (2008), 

Hope (2008), and Anthoff et al. (2009), that are based on the most recent published version of FUND, PAGE, or 

DICE and use business-as-usual climate scenarios. All values are based on the best available information from the 

underlying studies about the base year and year dollars, rather than the Tol (2008) assumption that all estimates 

included in his review are 1995 values in 1995$. All values were updated to 2007 using a 3-percent annual growth 

rate in the SCC, and adjusted for inflation using GDP deflator. 

EA-10 

EERE-2008-BT-STD-0012 COMMENT 22
 

DOE has conducted analyses at $33 and $5 per ton as these represent the estimates 

associated with the 3 percent and 5 percent discount rates, respectively. The 3 percent and 5 

percent estimates have independent appeal and at this time a clear preference for one over the 

other is not warranted. Thus, DOE has also included—and centered its current attention on—the 

average of the estimates associated with these discount rates, which is $19. (Based on the $19 

global value, the domestic value would be $1.14 per ton of CO2 equivalent.) 

It is true that there is uncertainty about interest rates over long time horizons. 

Recognizing that point, Newell and Pizer have made a careful effort to adjust for that 

uncertainty. See Newell and Pizer, supra. This is a relatively recent contribution to the literature. 

There are several concerns with using this approach in this context. First, it would be a 

departure from current OMB guidance. Second, an approach that would average what emerges 

from discount rates of 3 percent and 5 percent reflects uncertainty about the discount rate, but 

based on a different model of uncertainty. The Newell-Pizer approach models discount rate 

uncertainty as something that evolves over time; in contrast, one alternative approach would 

assume that there is a single discount rate with equal probability of 3 percent and 5 percent. 

Table EA.2 reports on the application of the Newell-Pizer adjustments. The precise 

numbers depend on the assumptions about the data generating process that governs interest rates. 

Columns (1a) and (1b) assume that “random walk” model best describes the data and uses 3-

percent and 5-percent discount rates, respectively. Columns (2a) and (2b) repeat this, except that 

it assumes a “mean-reverting” process. As Newell and Pizer report, there is stronger empirical 

support for the random walk model. 

EA-11 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table EA.2 Global Social Cost of Carbon Estimates ($/t CO2 in 2007 in 2006$),* Using 

Newell & Pizer Adjustment for Future Discount Rate Uncertainty** 

Model Study Climate Scenario 

Random- walk 

model 

Mean-reverting 

model 

3% 5% 3% 5% 

(1a) (1b) (2a) (2b) 

1 FUND Anthoff et al. 2009 FUND default 10 0 7 -1 

2 FUND Anthoff et al. 2009 SRES A1b 2 0 1 -1 

3 FUND Anthoff et al. 2009 SRES A2 15 0 10 -1 

4 FUND Link and Tol 2004 No THC 20 6 13 4 

5 FUND Link and Tol 2004 THC continues 20 4 13 2 

6 FUND Guo et al. 2006 Constant PRTP 9 0 6 -1 

7 FUND Guo et al. 2006 Gollier discount 1 14 0 14 0 

8 FUND Guo et al. 2006 Gollier discount 2 7 -1 7 -1 

FUND Mean 12 1 9 0 

9 PAGE Wahba & Hope 2006 A2-scen 97 13 63 8 

10 PAGE Hope 2006 13 8 

11 DICE Nordhaus 2008 15 9 

Summary Model-weighted Mean 55 10 36 6 

*The sample includes all peer reviewed, non-equity-weighted estimates included in Tol (2008), Nordhaus (2008), 

Hope (2008), and Anthoff et al. (2009), that are based on the most recent published version of FUND, PAGE, or 

DICE and use business-as-usual climate scenarios. All values are based on the best available information from the 

underlying studies about the base year and year dollars, rather than the Tol (2008) assumption that all estimates 

included in his review are 1995 values in 1995$. All values were updated to 2007 using a 3-percent annual growth 

rate in the SCC, and adjusted for inflation using GDP deflator. 

**Assumes a starting discount rate of 3 percent. Newell and Pizer (2003) based adjustment factors are not applied to 

estimates from Guo et al. (2006) that use a different approach to account for discount rate uncertainty (rows 7-8). 

The resulting estimates of the social cost of carbon are necessarily greater. When the 

adjustments from the random walk model are applied, the estimates of the social cost of carbon 

are $10 and $55, with the 3 percent and 5 percent discount rates, respectively. The application of 

the mean-reverting adjustment yields estimates of $6 and $36. Since the random walk model has 

greater support from the data, DOE also conducted analyses with the value of the SCC set at $10 

and $55. 

In summary, DOE will consider in its decision process for the notice of proposed 

rulemaking the potential global benefits resulting from reduced CO2 emissions valued at $5, $10, 

$19, $30 and $55 per metric ton, and has also presented the domestic benefits derived using a 

value of $1.14 per metric ton. 

DOE is well aware that scientific and economic knowledge about the contribution of CO2 

and other GHG emissions to changes in the future global climate and the potential resulting 

damages to the world economy continues to evolve rapidly. Thus, any value placed in this 

rulemaking on reducing CO2 emissions is subject to likely change. 

DOE, together with other Federal agencies, is reviewing various methodologies for 

estimating the monetary value of reductions in CO2 and other GHG emissions. This review will 

consider the comments on this subject that are part of the public record for this and other 

EA-12 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

rulemakings, as well as other methodological assumptions and issues, such as whether the 

appropriate values should represent domestic U.S. benefits, as well as global benefits (and costs). 

Given the complexity of the many issues involved, this review is ongoing. 

Nitrogen Oxides (NOx) 

As discussed earlier, with respect to NOx the CAIR rule has been reinstated by the 

courts. Therefore, NOx emissions in those states covered by CAIR will be subject to a cap with 

corresponding annual allowances openly traded. DOE’s approach to NOx allowance price 

impacts are discussed below. 

For those states not covered by CAIR, DOE plans on estimating the monetized benefits 

of NOx emissions reductions in these states based on environmental damage estimates from the 

literature. Available estimates suggest a very wide range of monetary values for NOx emissions, 

ranging from $370 per ton to $3,800 per ton of NOx from stationary sources, measured in 2001$ 

or a range of $432 per ton to $4,441 per ton in 2007$.8 

Mercury (Hg) 

DOE plans on estimating the monetized benefits of Hg emissions reductions based on 

environmental damage estimates from the literature. DOE has determined that the basic science 

linking mercury emissions from power plants to impacts on humans is considered highly uncertain. 

However, DOE identified two estimates of the environmental damages of mercury based on two 

estimates of the adverse impact of childhood exposure to methyl mercury on IQ for American 

children, and subsequent loss of lifetime economic productivity resulting from these IQ losses. 

The high-end estimate is based on an estimate of the current aggregate cost of the loss of IQ in 

American children that results from exposure to mercury of U.S. power plant origin ($1.3 billion 

per year in 2000$), which translates to $32.6 million per ton emitted per year (2007$).9 The lowend estimate was $664,000 per ton emitted in 2004$ or $729,000 per ton in 2007$, which DOE 

derived from a published evaluation of mercury control using different methods and assumptions 

from the first study, but also based on the present value of the lifetime earnings of children 

exposed.10 b 

Sulfur Dioxide (SO2) and Nitrogen Oxides (NOx) Allowance Prices 

With regard to SO2 emissions, unlike the other pollutants to be considered in this 

analysis, these emissions have for some time been subject to a national cap with corresponding 

annual allowances openly traded; therefore, considerable market experience with these 

instruments has already been accumulated. It has been argued that imposition of any standard 

that lowers U.S. national electricity consumption creates beneficial downward pressure on the 

prices of these allowances, and this cost reduction benefit should be considered in any analysis of 

a proposed standard. While this assertion is fundamentally sound (i.e., reduced electricity 

demand should ceteris paribus bring about lower SO2 and NOx allowance prices) there are a 

myriad of complications impeding any meaningful quantification of any associated benefit. 

b

 The estimate was derived by back-calculating the annual benefits per ton from the net present value of benefits 

reported in the study. 

EA-13 

EERE-2008-BT-STD-0012 COMMENT 22
While complexity of analysis alone clearly cannot justify disregarding a potential consequence of 

a standard, DOE additionally believes these benefits to be both volatile and de minimis when 

compared to the direct effects of a standard as estimated in this analysis. 

Some of the problems to be confronted in an allowance price effect forecast are: 

•	 Only any net lowering of the total allowance bill to generators free of transfers is the 

potential source of a benefit. Any such compliance cost saving would need to be 

accurately estimated, and this effect is no different from the benefit derived from a cost 

reduction for other inputs, such as fuel. When the SO2 allowance market that was created 

in 1995 under the Clean Air Act Amendments began, initial allowance allocations were 

directly granted to large affected units based on their historic (1985-87) use of fuel. For 

30 years, allowances for the following year are issued every spring at a declining rate to 

these entitled parties, and thereafter can be freely used, traded, or banked. Some 

additional allowances are allocated in diverse ways (e.g. as rewards to generators 

installing control equipment). In other words, the entitled generators holding emission 

rights are losers when the value of allowances declines, while the buyers of allowances 

are gainers. Before they are used, allowances may be traded many times at prices 

reflecting the marginal not average cost of compliance. 

•	 The trading system allows for allowance banking. Consequently, any observed change in 

a forecast year could represent the manifestation of market fundamentals but could 

similarly just indicate deposit or withdrawal of allowances. In general, used allowances 

have fallen short of the cap so emissions may exceed the specified cap for future years. 

•	 Control efforts could further reduce the SO2 cap for some jurisdictions, creating 

regulatory uncertainty that perturbs the allowance market. The issuance of the proposed 

and final CAIR rules were likely contributing factors to allowance price increases leading 

to a dramatic 2005 allowance price spike. While prices had already fallen far below their 

historic highs by the time CAIR was vacated in the summer of 2008, spot allowance 

prices nonetheless made a further precipitous drop following the D.C. Circuit Court 

ruling. 

•	 Because allowances can be traded freely by generators, brokers, and investors, they can 

serve as financial instruments, and, especially since 2003, allowance prices have been 

volatile. Between 2000, when a tightened Clean Air Amendment cap came into force, 

and 2007, allowances traded between a low of about $120/short ton in 2002 and a high of 

about $1600/short ton, with the 2005 spike being particularly dramatic.11 12 Since there is 

no reason to believe that these conditions will alter over the life of a proposed standard, 

the challenge of forecasting prices is much more complex than a simple supply-demand 

balance might suggest. Also, note that any quantification of the benefit likely depends on 

the level of prices as well as their net change. To believe that a simple delta in the prices 

could be used to estimate the benefit is to believe that the same numerical reduction in 

price would result from the standard whether the prevailing trading price were $100 or 

$1000 per short ton. 

EA-14 

EERE-2008-BT-STD-0012 COMMENT 22
With regard to NOx emissions, CAIR has only recently been reinstated by the courts, 

therefore market instruments with regard to NOx are not known. But DOE is left to presume that 

the same problems that confront an SO2 allowance price effect forecast would also apply to a 

NOx allowance price effect forecast. 

As noted earlier, the forecasting tool to be used for this analysis is the AEO2009 version 

of NEMS-BT, which generates forecasts of both SO2 and NOx emissions and allowance prices. 

DOE intends to review the allowance price forecasts and the effect that refrigerator standards 

have on them. If this review suggests that the SO2 and NOx allowance price effects are both 

significant and estimable using NEMS-BT, it may be included in the environmental assessment 

for the notice of proposed rulemaking. 

3.0 RESULTS 

The results for the environmental assesssment are similar to a complete NEMS run, as 

published in the AEO2009. These include emissions for SO2, NOx, mercury, and CO2 in fiveyear forecasted increments, extrapolated to the year 2043. DOE will report the outcome of the 

analysis for each trial standard level as a deviation from the AEO2009 reference case results. 

EA-15 

EERE-2008-BT-STD-0012 COMMENT 22
 

 

 

 

 

 

 

 

 

 

 

 

 

 

REFERENCES
 

1	 U.S. Department of Energy-Energy Information Administration. An Updated Annual Energy 

Outlook 2009 Reference Case Reflecting Provisions of the American Recovery and 

Reinvestment Act and Recent Changes in the Economic Outlook, April, 2009. Washington, 

DC. SR/OIAF/2009-03. 

<http://www.eia.doe.gov/oiaf/servicerpt/stimulus/pdf/sroiaf(2009)03.pdf> 

2 U.S. Environmental Protection Agency. Six Common Air Pollutants. Washington, DC. 

<http://www.epa.gov/air/urbanair/> 

3 U.S. Environmental Protection Agency. Clean Air Act. Washington, DC. 

<http://www.epa.gov/air/caa/> 

4	 U.S. Federal Register. Rule To Reduce Interstate Transport of Fine Particulate Matter and 

Ozone (Clean Air Interstate Rule); Revisions to Acid Rain Program; Revisions to the NOX 

SIP Call, Final Rule, May 12, 2005. 70 FR 25162. 

5	 U.S. Environmental Protection Agency. Clean Air Interstate Rule. 

<http://www.epa.gov/cleanairinterstaterule/> 

6	 U.S. Federal Register. Standards of Performance for New and Existing Stationary Sources: 

Electric Utility Steam Generating Units, Final Rule, May 18, 2005. 70 FR 28606. 

7	 U.S. Environmental Protection Agency. Clean Air Mercury Rule. 

<http://www.epa.gov/oar/mercuryrule/> 

8	 Office of Management and Budget, Office of Information and Regulatory Affairs, 2006 

Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded 

Mandates on State, Local, and Tribal Entities, 2006. Washington, DC. 

<http://www.whitehouse.gov/omb/inforeg/2006_cb/2006_cb_final_report.pdf> 

9	 Trasande, L., C. Schechter, K.A. Haynes, and P.J. Landrigan, “Applying Cost Analyses to 

Drive Policy that Protects Children,” 1076 ANN. N.Y. ACAD. SCI. 911 (2006). 

10	 Ted Gayer and Robert Hahn, “Designing Environmental Policy: Lessons from the Regulation 

of Mercury Emissions,” Regulatory Analysis 05-01 (AEI-Brookings Joint Center For 

Regulatory Studies) p. 31 (2004). A version of this paper was published in the Journal of 

Regulatory Economics in 2006. 

11	 U.S. Environmental Protection Agency, Allowance Prices (1995-2004), SO2 Allowance Price 

Index. Washington, DC. <http://www.epa.gov/airmarkets/progress/alprices.html> 

12	 U.S. Environmental Protection Agency, Clean Air Markets – Data and Maps. Washington, 

DC. <http://camddataandmaps.epa.gov/gdm/> 

EA-16 

EERE-2008-BT-STD-0012 COMMENT 22
REGULATORY IMPACT ANALYSIS FOR PROPOSED ENERGY CONSERVATION 

STANDARDS FOR RESIDENTIAL REFRIGERATORS, REFRIGERATORFREEZERS, AND FREEZERS 

TABLE OF CONTENTS 

1.0 INTRODUCTION ...................................................................................................... RIA-1
 

2.0 METHODOLOGY ..................................................................................................... RIA-1 

LIST OF TABLES 

Table RA.1 Non-Regulatory Alternatives to Standards ......................................................... RA-1 

RIA-i 

EERE-2008-BT-STD-0012 COMMENT 22
REGULATORY IMPACT ANALYSIS FOR PROPOSED ENERGY CONSERVATION 

STANDARDS FOR RESIDENTIAL REFRIGERATORS, REFRIGERATORFREEZERS, AND FREEZERS 

1.0 INTRODUCTION 

Under the Process Rule (Procedures for Consideration of New or Revised Energy 

Conservation Standards for Consumer Products, 61 FR 36974 (July 15, 1996)), the Department 

of Energy (DOE) is committed to continually explore non-regulatory alternatives to standards. 

DOE will prepare a draft regulatory impact analysis pursuant to E.O. 12866, “Regulatory 

Planning and Review,” which will be subject to review under the Executive Order by the Office 

of Management and Budget’s Office of Information and Regulatory Affairs. 58 FR 51735. 

DOE has identified six major alternatives to standards as representing feasible policy options to 

achieve customer product energy efficiency. It will evaluate each alternative in terms of its 

ability to achieve significant energy savings at a reasonable cost, and will compare the 

effectiveness of each one to the effectiveness of the proposed standards rule. 

The non-regulatory means of achieving energy savings that DOE proposes to analyze are 

listed in Table RA.1. The technical support document (TSD) in support of DOE’s notice of 

proposed rulemaking will include a complete quantitative analysis of each alternative, the 

methodology for which is discussed briefly below. 

Table RA.1 Non-Regulatory Alternatives to Standards 

No new regulatory action 

Consumer tax credits 

Manufacturer tax credits 

Performance Standards 

Rebates 

Voluntary energy efficiency targets 

Early replacement 

Bulk government purchases 

2.0 METHODOLOGY 

DOE will use the National Impact Analysis (NIA) Spreadsheet Models for each of the 

four appliance products to calculate the national energy savings and the net present value (NPV) 

corresponding to each alternative to the proposed standards. The NIA Spreadsheet Models for 

residential refrigerators, refrigerator-freezers, and freezers are discussed in Chapter 10 of the 

preliminary TSD. To compare each alternative quantitatively to the proposed conservation 

standards, DOE will need to quantify the effect of each alternative on the purchase and use of 

energy efficient residential dishwashers, dehumidifiers, and cooking products, and commercial 

clothes washers. Once it has quantified each alternative, DOE will make the appropriate 

RIA-1
 

EERE-2008-BT-STD-0012 COMMENT 22
revisions to the inputs in the NIA Spreadsheet Models. Key inputs that DOE may revise in these 

models are: 

•	 Energy prices and escalation factors; 

•	 Implicit market discount rates for trading off purchase price against operating 

expense when choosing equipment efficiency; 

•	 Consumer purchase price, operating cost, and income elasticities; 

•	 Consumer price-versus-efficiency relationships; and 

•	 Equipment stock data (purchase of new equipment or turnover rates for inventories). 

The key measures of the impact of each alternative will be: 

•	 energy use (in exajoules, or 1018 joules): Cumulative energy use of the equipment 

from the effective date of the new standard to the year 2042. DOE will report 

electricity consumption as primary energy. 

•	 National energy savings: Cumulative national energy use from the base case 

projection minus the alternative policy case projection. 

•	 Net present value: The value of future operating cost savings from equipment bought 

in the period from the effective date of the new standard (2012) to the year 2042. 

DOE will calculate the NPV as the difference between the present value of equipment 

and operating expenditures (including energy) in the base case, and the present value 

of expenditures in each alternative policy case. DOE will discount future operating 

and equipment expenditures to 2009 using a seven-percent and three-percent real 

discount rate. It will calculate operating expenses (including energy costs) for the life 

of the equipment. 

RIA-2
 

EERE-2008-BT-STD-0012 COMMENT 22