Energy Conservation Standards for

Residential Dishwashers, Dehumidifiers, and Cooking 

and Commercial Clothes Washers 

Commercial Clothes Washer Supplemental N

Proposed Rulemaking (SNOPR) 

Public Meeting 

Building Technologies Program

Office of Energy Efficiency and Renewable Energy

U.S. Department of Energy

November 16, 2009

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/clothe

EERE-2006-STD-0127 COMMENT 67.3
 Purposes

• To invite comment on the proposed energy conservation standard level TSL 3 f

clothes washers (CCWs);

• To present methodologies and characterize results for this rulemaking analyses

updates to the analyses presented in the Supplemental Notice of Proposed Ru(SNOPR);

• To discuss specific issues related to each analysis;• To seek input from interested parties on methodologies, assumptions, data sou

from the analyses; and

• To describe the next steps.

 Comments from Participants

• Participants are invited to provide summary comments or statements;• Participants are invited to raise additional issues for discussion today; and• SNOPR comment period closes December 9, 2009.

Purpose of the Public Meeting and 

Comments From Participants

EERE-2006-STD-0127 COMMENT 67.3
Statutory Authority – the Energy Policy and 

Conservation Act (EPCA) as amended

 The Energy Independence and Security Act of 2007 (EISA) am

EPCA (42 U.S.C. 6295(g)(10),(cc)) to prescribe standards for dand dehumidifiers, so DOE is not proposing standards for the

products.

 DOE published a Final Rule addressing energy conservation 

for residential electric and gas kitchen ranges and ovens and ovens on April 8, 2009. 74 FR 16040.

 The proposed notice addresses in part the requirements of se

136(e) of the Energy Policy Act of 2005 (EPACT 2005), which aEPCA (42 U.S.C. 6313 (e)) to require DOE to publish a Final Ruaddressing standards for CCWs by January 1, 2010.

EERE-2006-STD-0127 COMMENT 67.3
DOE Actions on Commercial Clothes Washe

 Test Procedures

• Final Rule for CCWs, which adopted the EPACT 2005 amendments to EPC

CCWs be rated according to the residential clothes washer test procedure, 

October 18, 2005. 70 FR 60407, 60416.

 Energy Conservation Standards

• Notice of availability of the Framework Document published March 27, 2006• Advance Notice of Public Rulemaking (ANOPR) published November 15, 20

64432.

• Technical Support Document (TSD) posted on DOE website.• Notice of Public Rulemaking (NOPR) published October 17, 2008. 73 FR 62

2008 NOPR)

• SNOPR published in the Federal Register November 9, 2009. 74 FR 57738

– Issued by DOE on October 30, 2009.– Available to stakeholders for review approximately two weeks prior to the public m

• Final Rule scheduled for January 2010.

EERE-2006-STD-0127 COMMENT 67.3
Background and Purpose

• The October 2008 NOPR proposed amended energy conservation stand

products and equipment, including commercial clothes washers.

• That rulemaking published a final rule in March 2009, well ahead of the 

deadline of January 1, 2010. 

• CCWs were not among the products covered in the final rule because c

the accuracy of the stated max-tech efficiency level for top-loading CCW

o Three sample max-tech top-loading units being tested, none of wh

the efficiency levels stated by the manufacturer; and

o DOE fulfilling its obligation to develop an SNOPR based on the ne

since the NOPR had proposed a TSL for top-loading CCWs at the 

• This SNOPR presents the revised analysis and proposes new standard 

comment.

EERE-2006-STD-0127 COMMENT 67.3
EPCA directs DOE to consider seven factors when 

energy conservation standards

Factor Analysis

1. Economic impact on consumers 

and manufacturers

Life-cycle cost analysisManufacturer impact analysis

2. Lifetime operating cost savings Life-cycle cost analysis3. Total projected energy savings National impact analysis 4. Impact on utility or performance Screening analysis

Engineering analysis

5. Impact of any lessening of 

competition

Manufacturer impact analysis

6. Need for national energy 

conservation

National impact analysis

7. Other factors the Secretary 

considers relevant

Environmental assessmentUtility impact analysisEmployment impact analysis

EERE-2006-STD-0127 COMMENT 67.3
Selection of Proposed Standards

 DOE considered five trial standard levels (TSLs), beginning with t

efficient level (TSL 5) and worked down to a level where the benefpotential standards outweighed the burdens.

• DOE tentatively concludes that at TSL 5 and TSL 4, the benefits of energy s

economic benefits, and emissions reductions would be outweighed by the pdisincentivizing consumers to purchase high-efficiency front-loading CCWs 

capital conversion costs that could result in a substantial reduction in manuf

• DOE tentatively concludes that TSL 3 saves a significant amount of energy 

technologically feasible and economically justified.

• At TSL 3, DOE tentatively concludes that the potential adverse impacts to o

Manufacturer (LVM), and therefore the potential adverse impacts on CCW m

competition, would be minimized. DOE has also taken into consideration the Justice’s review of the standards proposed in the October 2008 NOPR. (Coimpacts are discussed in more detail in the Manufacturer Impact Analysis sepresentation).

Propo

EERE-2006-STD-0127 COMMENT 67.3
Propo

Proposed Amended Energy Conservation Standar

Commercial Clothes Washers (TSL 3)

Product Class Proposed Energy Conservation Sta

Top-Loading 1.60 Modified Energy Factor/8.5 WatFront-Loading 2.00 Modified Energy Factor/5.5 Wat

DOE invites comments on these newly proposed energy conservation standards. (This is identified as Issue #7 of Issues on Which DOE Seeks Comment.)

EERE-2006-STD-0127 COMMENT 67.3
 Opening Remarks

• At this time, DOE welcomes opening remarks from interested part

SNOPR for commercial clothes washers.

Opening Remarks and Comments from Interes

Parties on the Proposed Energy Conservation Sta

Opening Remarks 

EERE-2006-STD-0127 COMMENT 67.3
Summary of Issues on Which DOE Seeks Comment - SNOP

Issues for Publ

1. Whether the method of “loading” clothes washers, or any other characteristic c

associated with traditional “top-loading” or “front-loading” clothes washers, are 

the meaning of 42 U.S.C. 6295(o)(4) in EPCA and whether the availability of s

would likely be affected by eliminating the separate classes for these equipmepreviously established by DOE.*

2. The revised efficiency levels, including the revised max-tech level for top-loadi

3. Technological feasibility of the proposed max-tech CCW, including washing an

performance measures for CCWs and population data for water heating CCW

4. The determination of short- and long-run price elasticities of demand and cros

elasticities for top-loading vs. front-loading CCWs and used vs. front-loading C

5. The determination of manufacturer impacts, including the effects of manufactu

and competitive concerns.

6. The determination of environmental impacts.

7. The newly proposed energy conservation standards.

* Typically, vertical-axis clothes washers are accessed from the top (“top-loaders”), axis clothes washers are accessed from the front (“front-loaders”). 

EERE-2006-STD-0127 COMMENT 67.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

The SNOPR analyses consist of revisions to the NOPR analyses.

EERE-2006-STD-0127 COMMENT 67.3
 Purpose

• To characterize manufacturer cost-efficiency relationships for higher efficien• To evaluate design options that improve efficiency relative to the baseline u• Sensitivity analysis to look at current material prices.

 Product classes analyzed

• Two CCW equipment classes were analyzed.

 Efficiency-level approach

• For the NOPR, industry supplied cost-efficiency data for two efficiency level

baseline.

• DOE analytically supplemented and validated this data to extend the cost-e

over all efficiency levels for both equipment classes.

• For the SNOPR, DOE revised the top-loader max-tech efficiency level and u

analysis to $2008.

Engin

Engineering Analysis

EERE-2006-STD-0127 COMMENT 67.3
Equipment Classes: Background

 When evaluating and establishing energy conservation standards, D

covered products or equipment into classes by (42 U.S.C. 6295(q); 63

• Type of energy used;• Capacity;• Other performance-related features that affect consumer utility and efficiency.

 For the ANOPR, CCWs were analyzed as a single equipment class ba

EPACT 2005.

• EPACT 2005 only mentions one equipment class, though DOE has the authority 

as it sees fit.

 For the NOPR, the equipment classes were split into top-loading and 

due to several factors:

• Comments from some interested parties regarding consumer utility (In particula

consumer utility per EPCA).

• Precedents set by multiple residential clothes washer rulemakings.• The California Energy Commission (CEC) Petition for Waiver denial.

Engin

EERE-2006-STD-0127 COMMENT 67.3
CEC Petition

 On September 13, 2005, the CEC submitted a petition to DOE for exe

federal preemption of California’s water conservation standards for rclothes washers.

• There are currently no Federal standards in effect for residential clothes washer 

2007 added a 9.5 WF standard that will become effective January 1, 2011.

• The California Code of Regulations would have an 8.5 WF standard effective Ja

a 6.0 WF standard effective January 1, 2010.

• The standards for front- loaders are the same as those for top-loaders in both Fe

California regulations.

 On December 28, 2006, DOE denied the CEC petition for three separa

independent reasons.

1. DOE did not have the statutory authority to issue a final rule that would become 

January 1, 2007 – a three year minimum is required.

2. DOE determined that CEC did not establish unusual and compelling water intere

required by EPCA for DOE to grant a waiver.

3. The standards would likely result in the unavailability of top-loaders in Cal

would violate EPCA.

 The 9th Circuit Court of Appeals recently reversed DOE’s denial and r

petition for further proceedings. Because this opinion was filed Octo

it occurred too late to be considered in the SNOPR analyses.

Engin

EERE-2006-STD-0127 COMMENT 67.3
Equipment Classes Proposed in the SNOPR

 For the SNOPR, DOE tentatively concluded that top-loading, vertical

provide unique utility and maintained that the axis of access is a fea

to EPCA.

 DOE retained the two equipment classes from the NOPR:

• Top-loading• Front-loading

 DOE is willing to reconsider its previous conclusions as part of this 

• If a single equipment class were to be established, DOE would give c

weight to the potential adverse effects of a single standard on compeCCW market.

• DOE does not intend to set a standard that would produce significant 

impacts on competition.

Engin

EERE-2006-STD-0127 COMMENT 67.3
Equipment Classes (Issue #1)

Engin

DOE invites comments on whether the method of “loading” clwashers, or any other characteristic commonly associated wittraditional “top-loading” or “front-loading” clothes washers [spresence or absence of agitators, ability to interrupt cycles, anothers] are “features” within the meaning of 42 U.S.C. 6295(o)(and whether the availability of such feature(s) would likely be eliminating the separate classes for these equipment types prestablished by DOE.DOE also seeks comments as to whether, as a consequence oand technology developments, it should maintain the same eqclasses for commercial clothes washers as it does for residenwashers.

EERE-2006-STD-0127 COMMENT 67.3
Efficiency Levels: Max-Tech Top-Loading

 The max-tech efficiency level defined for the NOPR for top-loading 

• Was based upon the unit with the maximum available Modified Energy Facto

CEC equipment database.

• DOE proposed setting the standard at the max-tech top-load efficiency level 

 At the NOPR meeting, Alliance Laundry Systems stated that it had 

and tested a max-tech top-loader which did not achieve rated perfothat there were numerous inconsistencies in the efficiency labelin

 DOE subsequently tested a sample of three identical max-tech uni

independent laboratory

• Actual performance (1.63 MEF/8.4 WF vs. 1.76 MEF/8.3 WF) did not match 

performance.

• Even at this lower level, the unit identified as the max-tech top-loading CCW 

NOPR continues to be the max-tech unit for the SNOPR.

 For the SNOPR, DOE has revised the max-tech efficiency level for 

CCWs.

• The revised level represents what DOE believes the max-tech CCW can act

given the tolerances and repeatability of the test procedure. 

• This new max-tech efficiency level is the same as the next lower efficiency le

NOPR.

Engin

EERE-2006-STD-0127 COMMENT 67.3
Revised Efficiency Levels (Issue #2)

Engin

DOE invites comments on the revised efficiency levels, inclrevised max-tech level for top-loading CCWs.

Efficiency Level

MEF/WF

Top-Loading Front-Load

Baseline 1.26/9.5 1.72/8.0

1 1.42/9.5 1.80/7.5

2 1.60/8.5 (max-tech) 2.00/5.5

3 -- 2.2

0

/5.1

4 -- 2.3

5

/4.4

EERE-2006-STD-0127 COMMENT 67.3
Technological Feasibility (Issue #3)

Engin

DOE invites comments on the technological feasibility of the pmax-tech CCW, including washing and rinsing performance mCCWs and population data for water heating CCWs.

 The max-tech top-loader CCW has the following features:

• Currently marketed only to on-premise laundry facilities• Based on a standard vertical-axis residential platform with an agita• Four manually-set water levels (most CCWs have three or less)• Five wash programs (most CCWs have three)• Low wash water temperatures (~71°F “Warm”, 108°F “Hot”)• Spray rinse• No observed proprietary technologies

 Market acceptance, which depends on wash performance, is unkn

 Suitability for non-institutional use is also unknown. DOE also received comments that front-loading CCWs with electri

used in some parts of the northern United States, would not meet proposed front-loading standards.

EERE-2006-STD-0127 COMMENT 67.3
Request for Additional Comments

DOE invites comments on any other issues pertaining to the Analysis.

Engin

EERE-2006-STD-0127 COMMENT 67.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

EERE-2006-STD-0127 COMMENT 67.3
 Energy Use Characterization

• To develop energy and water consumption savings estimates for 

equipment efficiency levels. 

 Markups for Equipment Price Determination

• To characterize the channels for how equipment is distributed fro

manufacturer to the customer.

• To determine prices paid by customers based on manufacturer se

for baseline and higher efficiency equipment.

 Life-Cycle Cost and Payback Period Analyses

• To develop the customer life-cycle cost savings and payback peri

efficiency equipment.

Purpose

EERE-2006-STD-0127 COMMENT 67.3
Approach

 Based on per-cycle energy and water use multiplied by th

per year.

 Number of cycles per day based on various studies.

• Multi-Family: Average = 3.4; Range = 1 to 10.9.• Laundromats: Average = 6; Range = 3 to 8.

Energy Use C

EERE-2006-STD-0127 COMMENT 67.3
Distribution Channels, Inputs and Results 

Markups to Determine E

 According to data from the Consortium for Energy Efficiency

overwhelming majority of equipment is sold through distribuoperators.

• Laundromats generally purchase equipment through distributors.• Multi-family housing and large institutions generally lease equipment 

operators

 Based markup calculations only on the distribution channel 

distributors.

• Assumed resulting equipment prices would be representative of price

consumers acquiring equipment from route operators.

 Overall baseline markup = 1.93; overall incremental markup = 

Manufacturer

Distributor Laundromat

Route Operator Multi-Family Housing

EERE-2006-STD-0127 COMMENT 67.3
 LCC equals consumer price plus the sum of operating costs d

to a particular base year.

 Economic evaluation from the customer perspective. Analysis implemented in an Excel® spreadsheet combined wit

Ball®.

 Analysis models the uncertainty and variability of inputs usin

Carlo simulation and probability distributions.

 Results are expressed as LCC savings (baseline minus stand Simple payback period (in years) is also calculated and repor

analysis.

Life-Cycle Cost and Payback P

Approach

Combine Changes 

in Costs 

Installed Cost

(Customer Price + Installation Cost)

Operating Expenses

Convert 

to Present 

Value

EERE-2006-STD-0127 COMMENT 67.3
Life-Cycle Cost and Payback P

 Electricity Prices

• Based on the Energy Information Administration (EIA) Form 861 D• Developed for 13 Regions: 9 Census Divisions and 4 Large State

 Natural Gas Prices

• Based on data from EIA’s Natural Gas Monthly.• Developed for 13 Regions: 9 Census Divisions and 4 Large State

 Water and Wastewater Prices

• Based on data from Raftelis Consultants and American Water Wo

Association (AWWA).

• Developed for 4 Census Regions due to data limitations.

 Energy Price Forecasts

• Based on 2009 Annual Energy Outlook.

 Water and Wastewater Price Forecasts

• Projections from 1970-2008 based on CPI national water price ind

average).

• Price projections to 2043 based on average growth rate from 197

Energy and Water Prices

EERE-2006-STD-0127 COMMENT 67.3
Installation, Repair and Maintenance Cost

Discount Rates and Equipment Lifetime

Life-Cycle Cost and Payback P

 Installation Cost

• Base cost = $190 based on RS Means

 Repair and Maintenance Cost

• Annualized cost a function of 1⁄2 consumer equipment price divided by 

lifetime.

 Discount Rates

• Based on the finance cost of raising funds to purchase appliances.

– Financial cost of any debt incurred to purchase equipment.– Opportunity cost of any equity used to purchase equipment.

• Calculated from the weighted-average cost of capital to the firm (WAC

equity and debt financing.

• Weighted-average real value = 5.7%.

 Equipment Lifetime

• Based on various sources including Appliance magazine and past DOE 

– Minimum = 7 (Multi-Family), 5 (Laundromat)– Average = 11.3 (Multi-Family), 7.1 (Laundromat)– Maximum = 15.5 (Multi-Family), 9.3 (Laundromat)

• All equipment lifetimes characterized with Weibull distribution.

EERE-2006-STD-0127 COMMENT 67.3
Equipment Assignment in the Base Case

Top-Loading Front-Loading

Level MEF WF Market Share* Level MEF WF Mar

Baseline 1.26 9.50 64.8% Baseline 1.72 8.00 

1 1.42 9.50 33.8% 1 1.80 7.50 2 1.60 8.50 1.4% 2 2.00 5.50 

3 2.20 5.10 4 2.35 4.40 

* Based on distribution of models reported in CEC database.

Life-Cycle Cost and Payback 

 Avoids overstating the benefits from increasing equipment efficiency 

the percentage of consumers already purchasing efficient equipment

EERE-2006-STD-0127 COMMENT 67.3
Life-Cycle Cost 

Average LCC Savings vs. Installed Cost

Multi-Family Application

($25)

$0

$25$50$75

$100$125$150$175$200$225

$700 $800 $900 $1,000 $1,100 $1,200 $1,300 $1,400 $1

Installed Cost

Average LCC Savings

Baseline

Level 1

Level 2

Level 3

Level 4

Baseline

Level 1

Level 2

Top-Loading Front-Loading

EERE-2006-STD-0127 COMMENT 67.3
Request for Additional Comments

Publ

DOE invites comments on any other issues pertaining to the Use, Markups, and Life-Cycle Cost and Payback Period Analy

EERE-2006-STD-0127 COMMENT 67.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

EERE-2006-STD-0127 COMMENT 67.3
Purpose

 Shipments Analysis

• To estimate commercial clothes washer shipments over time.

 National Impact Analysis

• To estimate the National Energy Savings (NES) from commercial 

washer energy conservation standards at different efficiency level

• To estimate the national economic impact on the nation (or the Ne

Value (NPV)) from commercial clothes washer energy conservatiostandards at different efficiency levels.

Ship

EERE-2006-STD-0127 COMMENT 67.3
Approach

Ship

 Estimate base-case shipments forecasts (2013–2043)

• Develop a shipments model that accounts for shipments to:

– New construction: New housing construction forecasts multiplied by historical rat

ownership.

– Replacements: Equipment retirement functions (equipment lifetimes) applied to e

• Historical shipments used to calibrate shipments model.

– Non-replacements (retired units not replaced).

 Estimate standards-case shipments forecasts (2013–2043)

• Developed with same data as used to estimate base-case forecasts.• Accounts for purchase price and operating cost changes due to standards by de

price elasticity of demand.

– Elasticity developed from historical price, efficiency, and shipments data for resid

– Purchase price effects dominate.

• Cross price elasticity describing the interactions between top-loading and front-lo

purchases due to price increases not considered.

• Shipments forecasted to drop due to standards but consumers are forecasted to 

initial changes in purchase price based on consumer automobile purchase decis

– Consumers forgoing the purchase of new washers assumed to purchase used m– Cross price elasticity describing the interaction of used and new purchases not c

EERE-2006-STD-0127 COMMENT 67.3
Standards-Case Shipments Impacts (Issue #

Ship

DOE invites comments on the following aspects of its method to estimate s

impacts due to standards:

(1) Because purchase price and efficiency data for residential appliances w

develop the short-run price elasticity of demand, DOE seeks comment oapplicable the price elasticity is to the commercial clothes washing mar

(2) Because estimates of the long-run price elasticity of demand were deriv

consumer automobile purchase decisions, DOE seeks comment on whe

inferred that the initial CCW price elasticity of demand would become mover time. 

(3) Because a cross price elasticity of demand between top-loading and fro

CCWs could not be developed due to the lack of specific data, DOE seeand data on the price interactions between the two types of CCWs, espethose circumstances where the purchase price increase for one CCW eclass is more significant than for the other. 

(4) Because DOE is concerned over its assumption that consumers forgoin

loader CCW purchase due to a price increase caused by standards wouacquire used top-loading washers, DOE seeks comments and input on 

interactions between the used CCW market and the new front-loading C

EERE-2006-STD-0127 COMMENT 67.3
Results

Shipments A

Top-Loading Washers Front-Loading Wa

 Example Standard Level = 1.60 MEF, 8.5 WF  Example Standard Level = 

0.000.020.040.060.080.100.120.140.160.180.20

1985 1995 2005 2015 2025 2035

Year

Shipments (million)

Base CaseStandards Case

0.000.010.020.030.040.050.060.070.080.09

1985 1995 2005 2015 

Year

Shipments (million)

EERE-2006-STD-0127 COMMENT 67.3
 National energy savings calculated from 2013-2043.

 National NPV calculated for equipment shipments entering the building stock fro

 Base case incorporates the penetration of higher efficiency equipment.

 Standards “roll up” inefficient equipment but do not affect efficient equipment.

Approach

National 

 Once a standard is in place, old equipment goes out of the inventory according t

efficiency mix. New equipment is sold to replace equipment according to the ne

 Use national average equipment prices, annual energy use, energy prices, annua

maintenance expenditures from LCC analysis. Streams of energy use and total cover analysis time periods and costs discounted to the present.

Front-Loading Washers

CSL TSL

Efficiencies

Market Shares

Base Case

Trial Standard Level

MEF WF 1234

Baseline- 1.72 83.5%- - - 

1 1 1.8 7.5 0.0% 3.5%- - 

2 2, 3 2 5.5 73.7% 73.7% 77.2% 77.2% 3 4 2.2 5.1 22.8% 22.8% 22.8% 22.8% 104 5 2.35 4.4 0.0% 0.0% 0.0% 0.0% 0.0

SWEF (MEF)* 2.04 2.04 2.05 2.05 2

SWEF (WF) 5.5 5.48 5.41 5.41 5

* Shipment-weighted efficiency (SWEF) , expressed in terms of MEF

EERE-2006-STD-0127 COMMENT 67.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

EERE-2006-STD-0127 COMMENT 67.3
 Purpose

• To develop a list of standard levels from which impacts are weighed and a pro

level is selected.

– Each trial standard level consists of a set of potential minimum efficiency 

all equipment classes, and may vary between equipment classes; and

– SNOPR analyses assess impacts for trial standard levels (not equipmen

 Method 

• Trial standard levels are assembled from the equipment classes identified in t

– Each trial standard level consists of the standard levels from each equip

meets a certain set of criteria.

 TSL 1: First standard level from each equipment class representin

design change.

 TSL 2: Standard levels for each equipment class that still represen

share of the market.

 TSL 3: Standard levels that minimize the equipment price differenc

two equipment classes.

 TSL 4: Increments standard level for front-loaders; Standard level 

unchanged from TSL 3 (already at max-tech level).

 TSL 5: Max-tech level from each equipment class.

Trial S

Selection of Trial Standard Levels

EERE-2006-STD-0127 COMMENT 67.3
Trial S

Trial Standard Levels for the SNOPR

Commercial Clothes Washers

Trial Standard Levels

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Top-LoadingMEF 1.42 1.42 1.60 1.60 1.60

WF 9.5 9.5 8.5 8.5 8.5Front-LoadingMEF 1.80 2.00 2.00 2.20 2.35WF 7.5 5.5 5.5 5.1 4.4

 TSLs 1 through 5 provide a positive NPV ranging from $0.01 

billion to $0.51 billion at 7-percent discount rate.

EERE-2006-STD-0127 COMMENT 67.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

EERE-2006-STD-0127 COMMENT 67.3
Consumer Subgroup Analysis

Consumer Su

 Purpose

• To evaluate the economic impacts of standards on consumer subgroups who 

disproportionately impacted compared with the general user population.

 Method

• DOE identified small businesses and consumers without municipal water and 

be disproportionately affected, and examined the impact of proposed standard

• DOE used the LCC spreadsheet model to determine the impact on these sub

 Output

• LCC savings and simple payback period (in years) for the identified customer • Determined that the subgroups were not disproportionately impacted by the s

EERE-2006-STD-0127 COMMENT 67.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

EERE-2006-STD-0127 COMMENT 67.3
Manufacturer Impact Analysis

Manufacturer I

 Purpose

• To assess the impacts of standards on commercial clothes washer manufact• To identify and estimate impacts on manufacturer subgroups that may be mo

impacted than the industry as a whole;

• One “Low-Volume Manufacturer” (LVM) is focused on the commercial la

business and has much lower revenues than its larger competitors in thclothes washer market.

• To examine the impact of cumulative regulatory burdens on the industry.

 Method 

• Analyze industry cash flow and net present value through use of the Governm

Regulatory Impact Model (GRIM); and

• Interview manufacturers to refine inputs to the GRIM, develop subgroup anal

address qualitative issues.

• For the SNOPR, the GRIM was updated for a 2009 base year, with the result

$2008.

• The SNOPR MIA also considered the impacts of manufacturer tax credits.

EERE-2006-STD-0127 COMMENT 67.3
Manufacturer Impact Analysis Process

Manufacturer I

 The MIA consists of three phases:

Industry profile

Develop straw-man GRIM*

Develop interview guide

Interviews

& 

industrywide / 

subgroup

analyses

Assess direct employment, competition, cumulative burden

Phase 2

* Government Regulatory Impact Model (GRIM)

Phase 1 Phase 3

EERE-2006-STD-0127 COMMENT 67.3
Updated INPV Results by TSL

 Change in INPV analyzed for two scenarios:

• Preservation of Gross Margin Percentage Markup with Base-Case • Preservation of Gross Margin Percentage Markup with Price Elast

Shipments

Manufacturer 

Trial Standard Levels

Base Case TSL 1 TSL 2 TSL 3 TSL 4 

Preservation of Gross Margin Percentage Markup with Base-Case ShipmentsINPV (2008$ million) 62 65 63 57 54 

Change in INPV (2008$ million

—

4 1 (5) (8) 

Change in INPV (%)

—

5.97% 2.24% -7.81% -12.73% 

Preservation of Gross Margin Percentage Markup with Price Elasticity of Demand ShipmeINPV (2008$ million) 62 64 62 55 51 

Change in INPV (2008$ million

— 2.8 0.5 (7.0) (10.2) 

Change in INPV (%) — 4.50% 0.76% -11.39% -16.57% 

EERE-2006-STD-0127 COMMENT 67.3
Manufacturer Production Tax Credits

 The Energy Improvement and Extension Act (EIEA 2008) provides 

manufacturers of qualifying equipment.

• Manufacturers qualify for a $150 credit for each CCW that has a m

and maximum 8.0 WF.

• Manufacturers qualify for a $250 credit for each CCW that has a m

and maximum 4.5 WF. 

• Qualifying washers must be produced in the United States. • Manufacturers also must increase production of qualifying washers 

credit. The EIEA tax credits are only earned on qualifying washers average number of qualifying washers produced by the manufactuprevious two years. 

Manufacturer 

EERE-2006-STD-0127 COMMENT 67.3
Manufacturer Production Tax Credits - Contin

 In its analysis, DOE found that the EIEA 2008 tax credits do not gre

the negative industry impacts.

• The LVM is the only manufacturer that produces qualifying CCWs. • Most of the potential benefit from the EIEA 2008 tax credits occur o

analysis period.

• Manufacturers are eligible for these tax credits in 2008, 2009, • The base year in the MIA is 2009. 

• The LVM did qualify for a substantial benefit in 2008 ($2.4 million). 

then it has not increased the production of qualifying washers to coa large production tax credit from the program. 

• DOE estimated that the LVM will collect a total of $385,000 in 

credits in 2009 and 2010. 

• Thus, the total income from producer tax credits for the LVM 

about $2.8 million.

Manufacturer 

EERE-2006-STD-0127 COMMENT 67.3
Manufacturer 

Department of Justice Review

 The DOJ review of the TSL proposed in the NOPR (1.76 MEF/8.3 WF) 

“... it appears that meeting the proposed standards may require s

investment in the development of new technology that some suloading CCWs may not find it economical to make. CCWs are uin multi-housing laundries, with top loading machines accounti

approximately 80 percent of machines in these locations. The r

percent are front loading machines, which are more energy efficsignificantly more expensive than top loading models. There amanufacturers of top loading CCWs selling in the United Statesthat there is a real risk that one or more of these manufacturers the proposed standard. In such a case, CCW purchasers would competitive alternatives for top loading machines, potentially repurchasers facing higher prices from the remaining top loading or manufacturers.... To maintain competition, the Department of Energy should ckeeping the existing standard in place for top loading CCWs.”

EERE-2006-STD-0127 COMMENT 67.3
Manufacturer Impacts (Issue #5)

Manufacturer 

DOE invites comments on the determination of manufacturer iincluding the effects of manufacturer tax credits and competitconcerns.

EERE-2006-STD-0127 COMMENT 67.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

EERE-2006-STD-0127 COMMENT 67.3
 Purpose

• To investigate the effects on utilities from reduced energy sales and peak load 

potential standards.

 Method 

• Use National Energy Savings Results; and• Use the EIA’s National Energy Modeling System (NEMS-BT) tailored for DOE’

Technologies Program.

 Output

• Change in electricity and gas sales and price by region;• Change in the mix of electricity generation; and• Change in installed capacity and generation.

– TSLs 1 through 5 resulted in very small installed generation capacity redu

from 5 to 12 MW.

Utility Im

Utility Impact Analysis

EERE-2006-STD-0127 COMMENT 67.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

EERE-2006-STD-0127 COMMENT 67.3
 Purpose

• To report net jobs created or eliminated nationally as a consequence of new or 

energy conservation standards. Employment impacts include direct and indirec

 Method 

• Uses the Impact of Sector Energy Technologies (ImSET) model to assess the 

employment impacts;

• Estimate changes in employment, industry output, and wage income in the ove

States economy resulting from changes in expenditures in the various sectors economy;

• Estimate changes in costs and benefits using the NIA analysis; and• Direct employment impacts are addressed in the MIA.

 Output

• Change in employment in national economy, other than in the manufacturing s

regulated, as a consequence of the amended energy conservation standards.

• TSLs 1 through 5 result in a net increase in jobs but so small that it would be im

national labor statistics and might be offset by other, unanticipated effects on e

Employment I

Employment Impact Analysis

EERE-2006-STD-0127 COMMENT 67.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

EERE-2006-STD-0127 COMMENT 67.3
 Purpose

• To report environmental impacts as a consequence of the amended energy co

standards, including changes in power plant emissions.

 Method

• Use National Energy Savings Results; and• Use the EIA’s National Energy Modeling System (NEMS-BT) tailored for DOE’

Technologies Program.

 Output

• Calculated the reduction in power plant emissions of carbon dioxide (CO2), oxi

(NOX) and mercury (Hg), using the NEMS-BT computer model.

• Calculated the reduction in on-site emissions (CO2 and NOX) where gas applia

(i.e., gas water heating and drying for commercial clothes washers)

• Sulfur dioxide (SO2) emissions were not included due to the emissions cap set 

Air Act Amendments of 1990. Impact on SO2 emissions changes was estimate

to affect value of emissions allowances under the cap.

• Monetized value of reductions in CO2, NOX, and Hg.• Assessed impact to SO2 allowance prices.

Environment

Environmental Assessment

EERE-2006-STD-0127 COMMENT 67.3
Determination of Environmental Impacts (Issue 

Environmen

DOE seeks comment on the determination of the anticipated environmimpacts of the supplemental proposed rule, including the methods for expected CO2, NOX, and Hg emissions savings due to the proposed st

EERE-2006-STD-0127 COMMENT 67.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employment 

Impact 

Analysis

EnviroAsses

EERE-2006-STD-0127 COMMENT 67.3
 Purpose

• To investigate the national impacts due to non-regulatory alternatives comp

mandatory energy conservation standards.

• The non-regulatory alternatives that DOE analyzed include: 

– No New Regulatory Action;– Consumer Rebates;– Commercial Customer Tax Credits; – Voluntary Energy-Efficiency Targets—ENERGY STAR;– Manufacturer Tax Credits;– Early Replacement; and – Bulk Government Purchases.

 Method

• Modify NIA spreadsheet model to consider the above scenarios and assess 

adoption of equipment at the proposed standard levels.

 Output

• National Energy Savings and Net Present Value of the non-regulatory altern

Regulatory Im

Regulatory Impact Analysis

EERE-2006-STD-0127 COMMENT 67.3
Issues for Publ

Summary of Issues on Which DOE Seeks Comment - SNOP

1. Whether the method of “loading” clothes washers, or any other characteristic c

associated with traditional “top-loading” or “front-loading” clothes washers, are 

the meaning of 42 U.S.C. 6295(o)(4) in EPCA and whether the availability of s

would likely be affected by eliminating the separate classes for these equipmepreviously established by DOE.

2. The revised efficiency levels, including the revised max-tech level for top-loadi

3. Technological feasibility of the proposed max-tech CCW, including washing an

performance measures for CCWs and population data for water heating CCW

4. The determination of short- and long-run price elasticities of demand and cros

elasticities for top-loading vs. front-loading CCWs and used vs. front-loading C

5. The determination of manufacturer impacts, including the effects of manufactu

and competitive concerns.

6. The determination of environmental impacts.

7. The newly proposed energy conservation standards.

EERE-2006-STD-0127 COMMENT 67.3
Request for Additional Comments

Publ

DOE invites comments on any remaining issues pertaining to SNOPR.

EERE-2006-STD-0127 COMMENT 67.3
How to Submit Comments...

 Public Meeting – Oral comments will be captured in the transcript and 

part of the public record.

 Written comments – NOPR comment period open until December 9, 2

Reference docket #: EE–2006–STD–0127 and/or RIN #: 1904–AB49

Email: home_appliance.rulemaking@ee.doe.govMail: Ms. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program, Mailstop EE–2J1000 Independence Avenue, SW.Washington, DC 20585–0121.Telephone: (202) 586–2945.

Courier: Ms. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program950 L’Enfant Plaza, SW., 6th Floor,Washington, DC 20024.

EERE-2006-STD-0127 COMMENT 67.3
Backup Slides

EERE-2006-STD-0127 COMMENT 67.3
Summary of Results For Commercial Clothes Washers

Category TSL 1 TSL 2 TSL 3 TSL Primary Energy Saved (quads) 0.04 0.04 0.10 0.11 

7% Discount Rate 0.01 0.01 0.03 0.03 3% Discount Rate 0.02 0.02 0.06 0.06 Primary Water Saved (trillion gallons) 0.00 0.01 0.14 0.16 

7% Discount Rate 0.00 0.00 0.04 0.04 

3% Discount Rate 0.00 0.00 0.08 0.09 Generation Capacity Reduction (GW)** 0.005 0.005 0.010 0.011 NPV (2008$ billion):

7% Discount Rate 0.01 0.02 0.36 0.41 

3% Discount Rate 0.08 0.10 0.89 1.03 

Industry Impacts:

Industry NPV (2008$ million) 4 – 3 1 – 0 (5) – (7) (8) – (1

Industry NPV (% Change) 6.0 – 4.5 2.2– 0.8 (7.8) – (11.4) (12.7) – (

Cumulative Emissions Impacts†:

CO2 (Mt) 2.36 2.39 5.07 5.66 

NOx (kt) 1.43 1.45 3.04 3.39 

Hg (t) 0 – 0.01 0 – 0.01 0 – 0.03 0 – 0.0

Wastewater Discharge Impacts (trillion gallons) 0.00 0.01 0.14 0.16 

EERE-2006-STD-0127 COMMENT 67.3
Summary of Results For Commercial Clothes Washers – Contin

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL Mean LCC Savings* (2008$):

Top-Loading, Multi-Family (8.1) (8.1) 179 179 179Top-Loading, Laundromat (17.7) (17.7) 190 190 190Front-Loading, Multi-Family 4.7 19.5 19.5 91 203Front-Loading, Laundromat 5.2 22.0 22.0 93 216

Median PBP (years):

Top-Loading, Multi-Family 11.7 11.7 4.6 4.6 4.6Top-Loading, Laundromat 7.9 7.9 2.8 2.8 2.8Front-Loading, Multi-Family 0.0 0.4 0.4 3.0 2.9Front-Loading, Laundromat 0.0 0.2 0.2 1.8 1.6

LCC Results:

Top-Loading

Multi-Family

Net Cost (%) 43.3 43.3 13.8 13.8 13.8No Impact (%) 35.3 35.3 1.2 1.2 1.2Net Benefit (%) 21.5 21.5 85.0 85.0 85.0

Laundromat

Net Cost (%) 51.4 51.4 2.9 2.9 2.9No Impact (%) 35.3 35.3 1.2 1.2 1.2Net Benefit (%) 13.3 13.3 95.9 95.9 95.9

EERE-2006-STD-0127 COMMENT 67.3
Category TSL 1 TSL 2 TSL 3 TSL 4 TSL LCC Results:

Front-Loading

Multi-Family

Net Cost (%) 0.0 0.0 0.0 1.4 1.1

No Impact (%) 96.3 96.3 96.3 23.1 0.0Net Benefit (%) 3.7 3.7 3.7 75.5 98.9

Laundromat

Net Cost (%) 0.0 0.0 0.0 0.0 0.0

No Impact (%) 96.3 96.3 96.3 23.1 0.0Net Benefit (%) 3.7 3.7 3.7 76.9 100.0

* Parentheses indicate negative (-) values. For LCCs, a negative value means an increase in 

LCC by the amount indicated.** Changes in installed generation capacity by 2043 based on AEO 2009 Reference Case.

† CO2 emissions impacts include physical reductions at power plants and at buildings where 

the appliance is being used. NOx emissions impacts include physical reductions at power 

plants and at buildings where the appliance is being used.

Summary of Results For Commercial Clothes Washers – Contin

EERE-2006-STD-0127 COMMENT 67.3
Market Characteristics – Commercial Clothes Wa

Market and Technolo

 Three manufacturers account for nearly 100% of the domestic 

share for commercial clothes washers.

Source: Consortium for Energy Efficiency (CEE). Commercial, Family-Sized Washers: An Initiative Description of the Consortium 

Major Manufacturers Other Manufacturers

Alliance ElectroluxWhirlpool/Maytag* Continental GE LG

Wascomat

* In 2006, Whirlpool and Maytag merged, but have continued to maCCW product lines to date.

EERE-2006-STD-0127 COMMENT 67.3
Screening Analysis Method

Scr

 Design options screened using the following criteria:

• Technological feasibility;• Practicability to manufacture, install and service;• Adverse impacts on equipment utility or equipment availability; an• Adverse impacts on health or safety.

EERE-2006-STD-0127 COMMENT 67.3
Technologies Selected for Further Considerat

Scr

Commercial Clothes Washers1. Adaptive control systems2. Added insulation3. Advanced agitation concepts for top-loading machines4. Automatic water fill control5. Direct-drive motor6. Front-loading design with recirculation7. Improved fill control8. Improved front-loading-washer drum design9. Improved water extraction to lower remaining moisture content10. Increased motor efficiency 11. Low-standby-power electronic controls12. Spray rinse or similar water-reducing rinse technology 13. Steam washing 14. Thermostatically controlled mixing valves 15. Tighter tub tolerance

EERE-2006-STD-0127 COMMENT 67.3
Downstream Ana

• Life-Cycle Cost an

Payback Period

• National Impacts• Manufacturer Imp

Analysis

Cost – Efficiency 

Relationship

Incremental 

Manufacturing Cost

MEF

Engin

 Characterize the relationship between manufacturer cost and efficienc

Purpose of the Engineering Analysis

EERE-2006-STD-0127 COMMENT 67.3
Commercial Clothes Washers: Annual Energy and W

 Annual Energy & Water Use = Per-Cycle Use x Cycles per year Per-cycle energy use components

• Water-heating• Drying• Machine

 Drying energy use (RMC) and machine energy use are a functio

• Based on residential clothes washer data

 Number of cycles per day

• Multi-Family: Average = 3.4; Range = 1 to 10.9• Laundromats: Average = 6; Range = 3 to 8

 Annual energy and water use of baseline top-loading clothes w

MEF, 9.50 WF) 

• Multi-Family

– Energy use = 2769 kWh/year (1020 kWh WH; 1583 kWh drying; 16– Water use = 33 1000-gallons/year

• Laundromats

– Energy use = 4866 kWh/year (1793 kWh WH; 2782 kWh drying; 29– Water use = 58 1000-gallons/year

Energy Use and Water Us

EERE-2006-STD-0127 COMMENT 67.3
Baseline and Incremental Markups

Markups to Determine E

 Markups relate customer price to cost of goods sold (CGS

 Baseline markups relate price to cost prior to a change in e

• Baseline markups indicate a customer price that covers all of a reta

distributor’s expenses plus profit

• Direct labor costs (salaries, payroll, rental and occupancy) are inclu

 Incremental markups relate the incremental change in cus

to the incremental change in CGS

• Some costs remain constant with CGS increases• Incremental markups cover only expenses that vary with CGS – in 

expenses that increase due to an increase in equipment efficiency

– For example, direct labor costs (salaries, payroll, rental and occupancy) 

efficiency-induced changes in CGS

• DOE assumes other operating costs and profit will scale proportion

EERE-2006-STD-0127 COMMENT 67.3
Markups to Determine E

Resulting Markups

Markup Baseline Incr.Manufacturer 1.26Retailer - -Distributor 1.43 1.18Sales Tax 1.069Overall 1.93 1.59

EERE-2006-STD-0127 COMMENT 67.3
Life-Cycle Cost and Payback P

LCC Calculation Flowchart

Total Installed

Cost

From 

Engineering 

Analysis

(Cost is a 

Function of 

Efficiency)

From Markups 

to Determine 

Equipment 

Price

Repair Cost

Maintenance

Cost

Annual

Operating

Expense

Lifetime

Operating

Expense

From Energy Use 

and Water Use 

Characterization

(Energy & Water 

Use are a Function 

of Efficiency)

Payback

Period

Energy

(and Water)

Consumption

Manufacturer

Markup

Sales Tax

Retailer or

Distributor

Markup

Consumer

Price

Baseline

Manufacturer

Cost

Std-Level

Manufacturer

Cost

Energy

(and Water)

Prices

Annual Energy

(and Water)

Cost

Lifetime

Discount Rate

Energy

(and Water)Price Trend

Installation

Cost

EERE-2006-STD-0127 COMMENT 67.3
National Impact Analysis Process

Shipments Model

National Energy Savings

NationalEconomicImpacts

LCC Analysis Results and Other Inputs

N

Ener

(

N

Net P

(2008 

 National energy savings calculated for period from 2013-2043 (30 ye NPV calculated for period from 2013-2062

National 

EERE-2006-STD-0127 COMMENT 67.3
Shipments Model

Ship

Appliance Stock

Appliance

Lifetime

Replacement

Shipments

Combined

Shipments

New Building

Construction

New Building

Appliance

Saturation

New

Construction

Shipments

Historical

Shipments

Shipments

Difference

Total

Shipments

Units not

Replaced

Rate of NonReplacement

(Calibration Variable)

EERE-2006-STD-0127 COMMENT 67.3
Purchase Price and Operating Cost Impact

Ship

 Shipments impacts due to purchase price and operating co

are accounted for when forecasting standards case shipme

 Shipments Model used Relative Price

(RP) elasticity to estim

impacts from purchase price (PP) and the present value of ocost (PVOC) changes

 Purchase price effects dominate but mitigated by househol Based on historical shipments, retail price, efficiency, and i

for home appliances, RP elasticity = -0.34

• 10% increase in RP results in a 3.4% drop in shipments• Consumers become less sensitive to initial changes in purchase pr

– Based on economic literature, RP elasticity drops 65% in ten years

Income

PP PVOC RP

+

=

EERE-2006-STD-0127 COMMENT 67.3
Inputs

National 

 Total Installed Cost

• Average per unit values as a function of efficiency level taken from LCC analysis

 Repair and Maintenance Costs

• No increase in repair and maintenance costs with efficiency

 Annual Energy Use

• Average per unit values as a function of efficiency level taken from LCC analysis

 Base-Case and Standards-Case Forecasted Efficiencies

• Base-Case efficiencies 2005-2013: Based on base case efficiency distributions fr• Standards-Case efficiencies 2013: Based on “Roll-up” scenario• Forecasted efficiencies: Frozen at 2013 levels

 Energy and Water Prices

• Average prices taken from LCC analysis• Future energy prices adjusted according to trend forecasted by the 2009 Annual E• Future water prices forecasted on linear extrapolation of CPI national water price 

2008

 Electricity Site-to-Source Conversion Factors

• Conversion factors based on marginal heat rates from NEMS corresponding to 20

Outlook

• Factors vary annually and account for generation, distribution, and transmission lo

 Discount Rate

• 7% and 3% real from OMB’s Regulatory Analysis Guideline A-4

 Present Year

• Future expenses are discounted to the year 2009

EERE-2006-STD-0127 COMMENT 67.3