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APPENDIX 12-A. PRELIMINARY MANUFACTURING IMPACT ANALYSIS 

QUESTIONAIRES 

TABLE OF CONTENTS 

12-A.1 RESIDENTIAL CLOTHES DRYER PRELIMINARY MANUFACTURING 

IMPACT ANALYSIS QUESTIONAIRE .....................................................................1

12-A.2 ROOM AIR CONDITIONER PRELIMINARY MANUFACTURING 

IMPACT ANALYSIS QUESTIONAIRE .....................................................................4

EERE-2007-BT-STD-0010 COMMENT 20.3
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12-A.1 RESIDENTIAL CLOTHES DRYER PRELIMINARY MANUFACTURING 

IMPACT ANALYSIS QUESTIONAIRE 

The preliminary manufacturing impact analysis questionnaire used as a guide for 

engineering discussions during manufacturer interviews is shown in this section. The following 

questions comprised the interview guide DOE used while interviewing residential clothes dryer 

manufacturers. Some of the information provided in the questionnaire has been redacted to 

protect vendor information. 

EERE-2007-BT-STD-0010 COMMENT 20.3
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PRELIMINARY MANUFACTURER IMPACT ANALYSIS TOPICS 

1 Issues 

1.1 What are the key issues for your company regarding a possible future product rulemaking? 

2 Shipment Projections 

2.1 What is your company’s approximate market share in each of the product classes? 

2.2 Would you expect your market share to change if new standards become effective that are 

5% higher than existing standards for vented dryers? 10% higher? New standards for 

condensing dryers? 

2.3 How would you expect shipments to change for the industry as a whole as a function of 

standards and why? 

2.4 Looking at price/cost effects only, how would you expect shipments to change for a 5 

percent, 10 percent, 25 percent, or 50 percent manufacturer price/cost increase? 

3 Conversion Costs 

3.1 What level of capital expenditure and product conversion costs would you anticipate to 

make at higher standard levels? Please describe what they are and provide your best 

estimate of their respective magnitudes.

3.2 How would the imposition of new energy conservation standards affect capacity utilization 

and manufacturing assets at your domestic production facilities? Would a new standard 

result in stranded capital assets? Would any facilities be closed or downsized? Added or 

upgraded? 

3.3 How might a new standard impact product innovation? 

3.4 At what efficiency levels do you expect to: 

Retire lower-efficiency platforms (and how many) 

Close current manufacturing plants rather than upgrading them to make higherefficiency dryers (moving production to new facilities, outsourcing, or ceasing 

operations altogether). 

Require the development of a “clean sheet” product platform to meet higher 

efficiency levels. 

3.5 How would manufacturer tax credits for higher efficiency products affect your decisions 

regarding research and development for highly-efficient dryers? 

3.6 Could said manufacturer tax credits influence any of the above manufacturing decisions? 

4 Product Mix and Profitability 

4.1 How would your company’s product mix and marketing strategy change with changes in 

the efficiency standard? 

EERE-2007-BT-STD-0010 COMMENT 20.3
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4.2 How would your company be impacted by a potential Energy Star program for clothes 

dryers? 

4.3 How would you expect manufacturer tax credits for highly-efficient clothes dryers to affect 

your current product mix and profitability? 

4.4 What distribution channels are used from the manufacturer to the retail outlet? What is the 

share of product going through each distribution channel? 

4.5 Generally, how would new product standards affect your customer mix, distribution 

channels, and corresponding profit margins? 

5 Market Shares and Industry Consolidation 

5.1 In the absence of new standards, do you expect any industry consolidation? 

5.2 How would new standards affect your ability to compete? 

5.3 Could new standards disproportionately advance or harm the competitive positions of 

some firms? 

5.4 Do you or any of your competitors own intellectual property that confers a significant cost 

advantage regarding achieving certain energy efficiency levels? 

5.5 Could new standards result in disproportionate economic or performance penalties for 

particular consumer/user subgroups? 

5.6 Beyond price and energy efficiency, could new standards result in products that will be 

more or less desirable to consumers due to changes in product functionality, utility, or 

other features? 

6 Cumulative Regulatory Burden 

6.1 Are there recent or impending regulations on your specific product or other products that 

impose a cumulative burden on the industry? 

6.2 If so, what is the total expected impact of those other regulations in terms of required 

capital investments, engineering hours spent addressing these issues, and/or product costs? 

6.3 Under what circumstances would you be able to coordinate any expenditures related to this 

and other regulations thereby lessening the cumulative burden? 

EERE-2007-BT-STD-0010 COMMENT 20.3
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12-A.2 ROOM AIR CONDITIONER PRELIMINARY MANUFACTURING 

IMPACT ANALYSIS QUESTIONAIRE 

 The preliminary manufacturing impact analysis questionnaire used as a guide for 

engineering discussions during manufacturer interviews is shown in this section. The following 

questions comprised the interview guide DOE used while interviewing room air conditioner 

manufacturers. Some of the information provided in the questionnaire has been redacted to 

protect vendor information. 

EERE-2007-BT-STD-0010 COMMENT 20.3
5-A-5

PRELIMINARY MANUFACTURER IMPACT ANALYSIS TOPICS 

1 Issues 

1.1 What are the key issues for your company regarding a possible future product rulemaking? 

2 Shipment Projections 

2.1 What is your company’s approximate market share in each of the product classes? 

2.2 Would you expect your market share to change once standards become effective? Does 

your outlook change with higher efficiency levels? 

2.3 How would you expect shipments to change for the industry as a whole as a function of 

standards and why? 

2.4 Looking at price/cost effects only, how would you expect shipments to change for a 5 

percent, 10 percent, 25 percent, or 50 percent manufacturer price/cost increase? 

3 Conversion Costs 

3.1 What level of capital expenditure and product conversion costs would you anticipate to 

make at higher standard levels? Please describe what they are and provide your best 

estimate of their respective magnitudes. 

3.2 How would the imposition of new energy conservation standards affect capacity utilization 

and manufacturing assets at your domestic production facilities? Would a new standard 

result in stranded capital assets? Would any facilities be closed or downsized? Added or 

upgraded? 

3.3 How might a new standard impact product innovation? 

4 Product Mix and Profitability 

4.1 How would your company’s product mix and marketing strategy change with changes in 

the efficiency standard? 

4.2 Would the current percentage of shipments at the Energy Star level be the same under a 

new standard? Would the Energy Star program be affected in any other significant ways? 

4.3 What distribution channels are used from the manufacturer to the retail outlet? What is the 

share of product going through each distribution channel? 

4.4 Generally, how would new product standards affect your customer mix, distribution 

channels, and corresponding profit margins? 

5 Market Shares and Industry Consolidation 

5.1 In the absence of new standards, do you expect any industry consolidation? 

5.2 How would new standards affect your ability to compete? 

5.3 Could new standards disproportionately advance or harm the competitive positions of 

some firms? 

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5.4 Are there concerns over intellectual property? 

5.5 Could new standards result in disproportionate economic or performance penalties for 

particular consumer/user subgroups? 

5.6 Beyond price and energy efficiency, could new standards result in products that will be 

more or less desirable to consumers due to changes in product functionality, utility, or 

other features? 

6 Cumulative Regulatory Burden 

6.1 Are there recent or impending regulations on your specific product or other products that 

impose a cumulative burden on the industry? 

6.2 If so, what is the total expected impact of those other regulations in terms of required 

capital investments, engineering hours spent addressing these issues, and/or product costs? 

EERE-2007-BT-STD-0010 COMMENT 20.3