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 20
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 20
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 20
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 20
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 20
 

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 20
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 20
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 20
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. 

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EERE-2008-BT-STD-0012 COMMENT 20
•	 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 20
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. 

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EERE-2008-BT-STD-0012 COMMENT 20
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 

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EERE-2008-BT-STD-0012 COMMENT 20
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 

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EERE-2008-BT-STD-0012 COMMENT 20
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 

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EERE-2008-BT-STD-0012 COMMENT 20
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 20
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 20
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 20
 

 

 

 

 

 

 

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 20
 

 

 

 

 

 

 

 

 

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 20
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 20
 

 

 

 

 

 

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 20
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 20
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 20
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 20
 

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 20
 

 

 

 

 

 

 

 

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 20
 

 

 

 

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: 

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EERE-2008-BT-STD-0012 COMMENT 20
• 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. 

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EERE-2008-BT-STD-0012 COMMENT 20
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. 

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EERE-2008-BT-STD-0012 COMMENT 20
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 

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EERE-2008-BT-STD-0012 COMMENT 20
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 

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EERE-2008-BT-STD-0012 COMMENT 20
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. 

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EERE-2008-BT-STD-0012 COMMENT 20
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. 

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EERE-2008-BT-STD-0012 COMMENT 20
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 20
 

 

 

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 20
 

 

 

 

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 20
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 20
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. 

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EERE-2008-BT-STD-0012 COMMENT 20
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 

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EERE-2008-BT-STD-0012 COMMENT 20
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 

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EERE-2008-BT-STD-0012 COMMENT 20
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 

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EERE-2008-BT-STD-0012 COMMENT 20
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) 

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EERE-2008-BT-STD-0012 COMMENT 20
 

 

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 20
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 

Defrost............................................................................................................2-4
 

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
 

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EERE-2008-BT-STD-0012 COMMENT 20
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
 

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EERE-2008-BT-STD-0012 COMMENT 20
 

 

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. 

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EERE-2008-BT-STD-0012 COMMENT 20
 

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 

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EERE-2008-BT-STD-0012 COMMENT 20
 

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. 

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EERE-2008-BT-STD-0012 COMMENT 20
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) 

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EERE-2008-BT-STD-0012 COMMENT 20
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 

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EERE-2008-BT-STD-0012 COMMENT 20
 

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. 

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EERE-2008-BT-STD-0012 COMMENT 20
 

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. 

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EERE-2008-BT-STD-0012 COMMENT 20
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 

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EERE-2008-BT-STD-0012 COMMENT 20
 

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 

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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 

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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 

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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) 

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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. 

Eq. 2.4.1 

Where: 

energy consumption associated with efficiency level A, 

baseline energy as calculated using the new test procedure, 

efficiency level, expressed as a percentage, and 

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. 

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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. 

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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. 

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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. 

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EERE-2008-BT-STD-0012 COMMENT 20
 

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). 

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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. 

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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 

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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. 

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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. 

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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 

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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. 

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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 

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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 

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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 

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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) 

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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 

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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 

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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 

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