CHAPTER 5. ENGINEERING ANALYSIS

TABLE OF CONTENTS
5.1 INTRODUCTION

........................................................................................................... 5-1 5.2 TECHNOLOGIES UNABLE TO BE INCL UDED IN THE ANOPR ANALYSIS

....... 5-1 5.3 PRODUCT CLASSES ANALYZED

.............................................................................. 5-5 5.4 EFFICIENCY LEVELS

................................................................................................... 5-8 5.4.1 Baseline Units

........................................................................................................... ....... 5-8 5.4.2 Incremental Efficiency Levels

....................................................................................... 5-10 5.5 METHODOLOGY OVERVIEW

.................................................................................. 5-15 5.5.1 AHAM Data Request

..................................................................................................... 5-1 6 5.5.2 Manufacturer Interviews

................................................................................................ 5- 16 5.5.3 Product Teardowns

........................................................................................................ 5-17 5.5.3.1 Generation of Bill of Materials

.................................................................... 5-18 5.5.3.2 Cost Structure of the Spreadsheet Models

................................................... 5-18 5.5.4 Review of Previous Technical Support Documents

...................................................... 5-20 5.5.5 Product Testing

.......................................................................................................... .... 5-20 5.6 ANALYSIS AND RESULTS

........................................................................................ 5-20 5.6.1 Dishwashers

.............................................................................................................. ..... 5-20 5.6.1.1 AHAM Data

................................................................................................. 5-20 5.6.1.2 Product Testing

............................................................................................ 5-23 5.6.1.3 Product Teardown

........................................................................................ 5-30 5.6.1.4 Manufacturer Interviews

.............................................................................. 5-38 5.6.2 Dehumidifiers

............................................................................................................ .... 5-41 5.6.2.1 AHAM Data

................................................................................................. 5-41 5.6.2.2 Manufacturer Interviews

.............................................................................. 5-46 5.6.2.3 Product Teardowns

...................................................................................... 5-47 5.6.3 Cooking Products

......................................................................................................... .. 5-57 5.6.3.1 AHAM Data

................................................................................................. 5-57 5.6.3.2 Review of Past TSDs

................................................................................... 5-63 5.6.4 Commercial Clothes Washers

........................................................................................ 5-70 5.6.4.1 AHAM Data

................................................................................................. 5-70 5.6.4.2 Manufacturer Interviews

.............................................................................. 5-72 5.6.4.3 Review of the Most Recent TSD fo r Residential Clothes W ashers

............. 5-79

LIST OF TABLES
Table 5.4.1 EPACT 2005 Standards fo r Residential Dehum idifiers

...................................... 5-9 Table 5.4.2 1996 TSD Baseline Energy Factors for Cooking Products

................................. 5-9 Table 5.4.3 Efficiency Levels for Residential Dishwashers

................................................. 5-11 Table 5.4.4 Efficiency Levels for Residential Dehum idifiers

.............................................. 5-12

5-iTable 5.4.5 Efficiency Levels for Residential Gas Cooktops ............................................... 5-12 Table 5.4.6 Efficiency Levels for Residential Electric Cooktops......................................... 5-13 Table 5.4.7 Efficiency Levels for Residential Gas Ovens .................................................... 5-14 Table 5.4.8 Efficiency Levels for Residential Electric Ovens .............................................. 5-14 Table 5.4.9 Efficiency Levels for Residential Microwave Ovens ........................................ 5-15 Table 5.4.10 Efficiency Levels for Commercial Clothes Washers......................................... 5-15 Table 5.5.1 Engineering Analysis Methods .......................................................................... 5-16 Table 5.5.2 Major Manufacturing Processes ........................................................................ 5-19 Table 5.6.1 AHAM Dishwasher Mark et Share Data Submittal............................................ 5-21 Table 5.6.2 AHAM Dishwasher Shipments a nd Shipment-Weighted Efficiency Data Submittal

............................................................................................................ 5-21 Table 5.6.3 AHAM Dishwasher Increm ental Cost Data Submittal...................................... 5-22 Table 5.6.4 Dishwasher Te st Unit Features .......................................................................... 5-23 Table 5.6.5 Comparison of Dishwasher Incr emental Efficiency Levels and Teardown Unit EFs ............................................................................................................. 5-31 Table 5.6.6 Design Options on Dishwasher Teardown Units............................................... 5-33 Table 5.6.7 Incremental Manufacturing Costs fo r Residential Standard Dishwashers ........ 5-38 Table 5.6.8 AHAM Dehumidifier Sh ipments Data Submittal.............................................. 5-42 Table 5.6.9 AHAM Dehumidifier Shipment-Weighted Efficiency Data Submittal............. 5-42 Table 5.6.10 AHAM Dehumidifi er Market Share Data Submittal for 35.01 to 45.00 Pints/Day............................................................................................................ 5-42 Table 5.6.11 AHAM Dehumidifi er Market Share Data Submittal for 54.01 to 74.99 Pints/Day............................................................................................................ 5-43 Table 5.6.12 AHAM Dehumidifier Increm ental Cost Data Submittal for 0–35.00 Pints/Day............................................................................................................ 5-44 Table 5.6.13 AHAM Dehumidifier Increm ental Cost Data Submittal for 35.01–45.00 Pints/Day............................................................................................................ 5-44 Table 5.6.14 AHAM Dehumidifier Increm ental Cost Data Submittal for 54.01–74.99 Pints/Day............................................................................................................ 5-45 Table 5.6.15 Retained Design Opti ons for Dehumidifiers...................................................... 5-50 Table 5.6.16 Assumed Dehumidifier Product- Class-Specific Cost and Efficiency Parameters.......................................................................................................... 5-51 Table 5.6.17 Estimated Dehumidifier Cost and Efficiency Parameters for All Product Classes................................................................................................................ 5-52 Table 5.6.18 Incremental Costs to Increase Dehumidifier EF................................................ 5-57 Table 5.6.19 Microwave Oven St andby Power Comparison.................................................. 5-62 Table 5.6.20 Gas Cooktop Manufacturing Cost and Efficiency Increments .......................... 5-64 Table 5.6.21 Electric Coil Cooktop Manufacturing Cost and Efficiency Increments ............ 5-65 Table 5.6.22 Electric Smooth Cooktop Manufacturi ng Cost and Efficiency Increments....... 5-65 Table 5.6.23 Gas Standard Oven Manufacturi ng Cost and Efficiency Increments ................ 5-66 Table 5.6.24 Gas Self-Cleaning Oven Manufacturing Cost and Efficiency Increments ........ 5-67 Table 5.6.25 Electric Standard Oven Manufactur ing Cost and Efficiency Increments .......... 5-68 Table 5.6.26 Electric Self-Cleaning Oven Manufacturing Cost and Efficiency Increments.......................................................................................................... 5-68

5-iiTable 5.6.27 Slopes and Intercepts for OvenEnergy Factor versus Cavity Volume Relationship

....................................................................................................... 5-69 Table 5.6.28 Microwave Oven Manufacturing Cost and Efficiency Increm ents

................... 5-70 Table 5.6.29 AHAM Commercial Clothes Wash er Shipm ents and Shipment-Weighted MEF and WF Data Submittal

............................................................................ 5-70 Table 5.6.30 AHAM Baseline MEF Commercial Clothes W asher Average Energy and Water Use Data Submittal

................................................................................. 5-71 Table 5.6.31 AHAM Commercial Clothes Washer Increm ental Cost Data Submittal

........... 5-71 Table 5.6.32 1996 AHAM Residential Clothes Washer Cost Data Submittal

....................... 5-81 Table 5.6.33 1996 AHAM Residential Clothes Washer Energy and W ater Use Data Submittal

............................................................................................................ 5-84 Table 5.6.34 Incremental Manufacturing Cost for Comm ercial Clothes Washers

................. 5-94

LIST OF FIGURES Figure 5.5.1 Manufacturing Cost Assessment Stages

............................................................ 5-19 Figure 5.6.1 AHAM Dishwasher Co st-Efficiency Curve

...................................................... 5-22 Figure 5.6.2 Overall Dishwasher Cy cle Param eters versus EF

.............................................. 5-26 Figure 5.6.3 Dishwasher EAEU versus EF

............................................................................ 5-27 Figure 5.6.4 Dishwasher Machine Electri cal Energy Consumption Disaggregated by Com ponent

......................................................................................................... 5-28 Figure 5.6.5 Dishwasher Water Consumpti on Disaggregated by Cycle Segm ent

................. 5-29 Figure 5.6.6 Dishwasher Full Produc tion Cost Distributions

................................................ 5-31 Figure 5.6.7 Dishwasher Materi al Cost Distributions

............................................................ 5-32 Figure 5.6.8 Comparison of Dishwasher Incremen tal Costs for the Efficiency Levels in AHAM’s Submittal, 0.58 EF Baseline

.............................................................. 5-37 Figure 5.6.9 Comparison of Dishwasher Incremental Costs for EF = 0.58 to 1.11

............... 5-37 Figure 5.6.10 AHAM Dehumidifier Cost-Efficiency Curves

.................................................. 5-45 Figure 5.6.11 Efficiency Range of Dehumidifier Teardowns

.................................................. 5-48 Figure 5.6.12 Baseline Dehumidifier Ma terial Cost Distribution

............................................ 5-49 Figure 5.6.13 Baseline Dehumidifier Fu ll Production Cost Distribution

................................. 5-49 Figure 5.6.14 Comparison of Dehumidifier Increm ental Production Costs: 0-35.00 Pints/Day

............................................................................................................ 5-53 Figure 5.6.15 Comparison of Incremental Dehum idifier Production Costs: 35.01-45.00 Pints/Day

............................................................................................................ 5-54 Figure 5.6.16 Comparison of Incremental Dehum idifier Production Costs: 54.01-74.99 Pints/Day

............................................................................................................ 5-54 Figure 5.6.17 Comparison of Total Incremental De hum idifier Costs: 0- 35.00 Pints/Day

...... 5-55 Figure 5.6.18 Comparison of Total Increm ental Dehum idifier Costs: 35.01-45.00 Pints/Day

............................................................................................................ 5-55 Figure 5.6.19 Comparison of Total Increm ental Dehum idifier Costs: 54.01-74.99 Pints/Day

............................................................................................................ 5-56 Figure 5.6.20 AHAM Microwave Oven Efficiency versus Rated Output Power

.................... 5-60

5-iiiFigure 5.6.21 AHAM Microwave Oven Efficiency versus Oven Volume

.............................. 5-61 Figure 5.6.22 AHAM Microwave Oven Standby Power Consumption

................................... 5-62 Figure 5.6.23 AHAM Commercial Clothes Washer Increm ental Cost Data Submittal

........... 5-72 Figure 5.6.24 2000 Low-Volume versus Hi gh-Volum e Clothes Washer Cost Disadvantage

...................................................................................................... 5-88 Figure 5.6.25 2000 Cost Disadvantage of Producing 100,000 versus 1.5MM Clothes Washers per Year with Gr een Field Facility

...................................................... 5-89

5-ivCHAPTER 5. ENGINEERING ANALYSIS

5.1 INTRODUCTION After conducting the screening analysis, the Departm ent of Energy (DOE) performed an engineering analysis based on the remaining desi gn options. The engineering analysis consists of estimating the energy and water consumption and costs of products at various levels of increased efficiency. This section provides an ov erview of the engineerin g analysis (section 5.1), considers technologies which are unable to anal yzed for this rulemaking (section 5.2), discusses proposed product classes (section 5.35.2), establishes baseline unit specification (section 5.4.1), discusses incremental efficiency levels (s ection 5.4.2), explains th e methodology used during data gathering (5.5) and disc usses the analysis and result s (section 5.6) DOE completed a separate engineering analysis for residential dishwashers, dehumidifier s, and cooking products and commercial clothes washers. The primary inputs to the engine ering analysis are baseline infor mation from the market and technology assessment (Chapter 3 of the TS D) and technology options from the screening analysis (Chapter 4). Additional inputs include cost and energy efficiency data, which DOE received from the Association of Home App liance Manufacturers (AHAM) and qualified and supplemented through tear-down analysis and manuf acturer interviews. The primary output of the engineering analysis is a set of cost-efficiency curves. In the subsequent markups analysis (Chapter 7), DOE determined customer ( i.e. product purchaser) prices by applying distribution markups, sales tax and contractor markups. Af ter applying these markups, they serve as the input to the building energy-use a nd end-use load charac terization (Chapter 6) and the life-cycle cost (LCC) and payback period analyses (Chapter 8). DOE typically structures its engineering analysis around one of three m ethodologies. These are: (1) the design-option approach, wh ich 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 ener gy 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 “b ottom-up” manufacturing cost assessment based on a detailed bill of materials derived from tear downs of the product being analyzed. Deciding which methodology to use for the engineering analysis depends on the product, the design options under study, and any histori cal data that DOE can draw on.

5.2 TECHNOLOGIES UNABLE TO BE INCLUDED IN THE ANOPR ANALYSIS In performing the engineering analysis, DOE did not consider for analysis certain technologies that m et the screeni ng criteria but were unable to be evaluated for one or more of the following reasons: (1) data are not availa ble to evaluate consumer usage of a product incorporating the technology, and, therefore the test procedure conditions and methods may not

5-1be applicable; (2) data are not available to eval uate the energy efficiency characteristics of the technology; and (3) available da ta suggest that the efficiencybenefits of the technology are negligible. In the first two cases, DOE is unabl e to adequately assess how these technologies impact annual energy consumption For technologies that lack consumer usage details (including operating conditions, duration, and frequency), DOE believes that the ex isting test procedures m ay specify conditions and methods that are not representa tive of actual usage. DOE furthe r believes that even if data were available to amend the test procedure, su ch changes could be extensive enough to require total revision, which in turn could warrant the creation of a separate product class for that technology in the event that the test pr ocedure changes indi cated unique utility. Furthermore, certain technologies cannot be m easured according to the conditions and methods specified in the existing test procedure. In other cases, available data suggested that som e of the design options resulted in such small energy savings as to be negligible. Becau se DOE intends to focus on the technologies with measurable impact on efficiency, design options with negligible energy savings have been eliminated from further consideration. Dehumidifiers Many dehumidifiers feature a bu ilt-in rela tive humidity (RH) sensor, or hygrometer, and most (including all units upon wh ich DOE conducted reverse-engi neering) feature a built-in humidistat, a device that allows th e consumer to set the desired RH level for the room. When the humidity near the dehumidifier drops below the us er-defined or pre-set va lue, the dehumidifier automatically shuts off. This sensor-contro lled system presumably saves energy by avoiding running the dehumidifier when the RH is such that further dehumidification would be neither effective nor desirable. However, there is no industry consensus on patterns in ambient conditions and usage. If such parameters we re known to DOE, the test procedure, which currently specifies constant ambient temperatur e and humidity, would need to be revised to measure energy savings associated with th ese technologies. Therefore, the built-in hygrometer/humidistat design option was not considered for further analysis. In addition, several other de sign options were excluded fr om consideration in the ANOPR based on lack of information on repres entative consumer usage These include improved dehumidifier controls, which incorpor ate sensors and algorithms to optimize response under off-design ambient conditions, and improved flow-control devices. Defrost measures are required when air entering a dehum idifier is below 65 degrees Fahrenheit (°F), such as in a basement applicat ion. Since the test procedure conditions are above 65° F, no energy savings can be quantified for either improved defrost methods or improved demand-defrost controls. Thus, DOE dropped these design options from further analysis for the ANOPR.

5-2Some dehumidifiers with electronic controls consume standby power when the dehumidifier is not performing its intended f unction. Without industry consensus on usage patterns, however, DOE’s test procedure does not include measurement of any standby power consumption for dehumidifiers. If such para meters were known to DOE, the test procedure would need to be revised to measure energy sa vings of low-standby-loss controls. Based on the lack of information on representative cons umer usage, DOE removed the low-standby-loss control design option from further consideration for the ANOPR. To prevent air filters from clogging, some dehu midifier m anufacturers design air filters to be removable and washable. Washing the air filter prevents clogging. However, DOE assumes rating testing is performed on new machines with little to no dust buildup. In addition, the DOE test procedure specifies six hours of continuous testing without any interruptions. Thus, a filter could not be removed for cleani ng. As a result of the assumed unit cleanliness and continuous testing, DOE has no data to determine efficiencyimprovements associated with washable air filters and therefore will not analyze this design option for the ANOPR. Cooking Products Several technologies are av ailable for cooktops which allow the burners or heating elem ents to automatically adjust in response to cooking-state setpoints, such as cooking vessel temperature. These include thermostatically-controlled gas cooktop burners as well as electronic controls for electric cooktops. However, DOE is unaware of any data to quantify the energy efficiency effects of such technologies. Further, efficiency benefits of these design options are only realized under variable burner or element conditions. Because the cooktop test procedure does not account for consumer usage patterns, th e energy savings of these technologies cannot be adequately measured. Therefore, DOE will not c onsider these design options for further analysis for the ANOPR. Similarly, DOE is unaware of any data that indica tes a measurable energy efficiency impact of insulation in gas and electric coil c ooktops, so DOE will not analyze this design option in the ANOPR for these product classes. Induction cooktops require ferromagnetic cookwar e in order to transfer energy to the food contents. While the test block specified in the DOE test procedure is aluminum and thus is unable to measure the efficiency of induction co oktops, the National Bureau of Standards (NBS), now called National Institute of Standards and Technology (NIST), proposed an alternate method of measuring the energy consumption of such cooktops by simply attaching a ferromagnetic material to the bottom of the test block. Data obtained by this method suggested an efficiency improvement over baseline electric smooth cooktops. However, this test method has not been rigorously validated for incorporatio n into the DOE test procedure and therefore, due to the unresolved nature of the NIST data, DOE will eliminate induction elements for electric smooth cooktops from further consideration in the ANOPR. Some electric cooktops and microwave ovens with electronic controls consum e standby power, but the EF metrics do not incorporate such power in their calculation. Even though DOE

5-3considers the consumer usage of these products to be well-defined, the current test procedure does not measure standby power, thus DOE is unabl e to quantify the impact on energy savings of low-standby-loss electronic controls for these pr oducts and will not consid er these design options during the ANOPR analysis. The only currently available gas ovens that DOE is aware of that incorporate radiant burners do so for broiling cooking functions, whic h are a secondary cooki ng function that is not the focus of the DOE efficien cy measurement. Energy efficiency is instead measured during the primary bake function, thus the energy benefits are not captured by the test procedure under these conditions. Accordingly, DOE will eliminat e radiant burners in gas ovens from further analysis for the ANOPR.
While there are several residential steam ovens currently on the m arket, DOE believes that the existing test procedure may specify conditi ons and methods that are not representative of actual usage. DOE further believes that even if data were available to am end the test procedure, such changes could be extensive enough to requir e total revision, which in turn could warrant the creation of a separate product cl ass in the event that the test procedure changes indicated unique utility. Thus, DOE will not consider steam cooking in the ANOPR analysis. For added insulation in microwave ovens, this technology will not im prove EF, since during the short duration of the DOE test procedure as we ll as during typical usage, the microwave oven cavity walls do not heat up. Thus , the energy savings of this design option would be so small as to be not be measurable. Cooking sensors, which terminate the operation of a microwave oven based upon inferred cooking state, appear to prom ote shorter cook times and thus lowe r energy consumption. Due to the lack of consumer usage details, including opera ting conditions, duration, and frequency, DOE believes that the existing test procedure ma y specify conditions and methods that are not representative of actual usage. Thus DOE will not consider this design option for further analysis for the ANOPR. According to AHAM, dual magnetrons in microwave ovens do not improve energy efficiency due to the added losses associated with two m agnetron heaters. In addition, AHAM stated that the additional cost of dual magnetrons could not be economically justified. DOE does not have any efficiency data on dual magnetrons by which to evaluate this design option. Therefore, it will not consider dual magnetr ons for further analysis in the ANOPR. AHAM stated that virtually no residential solo-function m icrowav e oven still uses a ceramic stirrer. Almost all microwave ovens us e polypropylene or mica film stirrers, which have lower losses than ceramic sti rrers. According to AHAM, this design option has already been optimized so there is no opportuni ty for efficiency improvements. The stirrer cover, however, may be made of ceramic when there are browning elements that generate too much heat for a plastic cover. These covers absorb some mi crowave energy but are needed to prevent food splatter inside the wave guide. Eliminating th e ceramic cover would adversely affect consumer

5-4utility by requiring cleaning of the stirrer or by reduc ing the life of the stirre r. Therefore, DOE’s ANOPR analysis will not consider eliminating or improving the ceramic stirrer cover. According to AHAM, losses associated with th e wave guide are typi cally less than 0.5 percent of the overall energy consumption. DOE is not aware of any data demonstrating efficiency improvements associated with wave guide improvement, so it will not analyze this design option for the ANOPR.
Commercial Clothes Washers Although several manufacturers have made claims regarding improved wash perform ance and greater utility of improved drum designs for hor izontal-axis clothes washers, DOE is unaware of any publicly-available data to corroborate a decrease in cycle time or water consumption or an increase in MEF as a result of implementing this design option. Therefore, DOE will not analyze this design option for the ANOPR. Even though DOE considers consumer usage of CCW s to be well defined, the current tests procedures do not measure standby power . Also, DOE is unaware of any data demonstrating energy savings associated with low-standby power supplies for CCWs. Thus, in the context of the present rulemaking, DOE e liminated the low-standby-power design option from the ANOPR analysis.

5.3 PRODUCT CLASSES ANALYZED DOE separated residential dishwashers, dehum idifiers, and cooking products and commercial clothes washers into product classes. Because DOE formulated a separate energy conservation standard for each product class, the crit eria for separation into different classes are: (1) type of energy used (natural gas or electricity), and (2) capacity or other performance-related features such as those that prov ide utility to the consum er, or others deemed appropriate by the Secretary that would justify the establishment of a separate energy conservation standard. (42 U.S.C. 6295 (q) and 6316(a))
For dishw ashers , the size of the unit significantly im pacts the energy consumed. In other words, standard-sized dishwashers with relative ly greater water consump tion have significantly greater energy use than compact units. Because standard dishwashers offer enhanced consumer utility over compact units ( i.e. , the ability to wash more dish es), DOE analyzed the following product classes, based on the size of the dish washer (as specified in American National Standards Institute (ANSI)/AHAM Standard DW-1-2005, Dishwashers ):

 Com pact, capacity less than 8 place se ttings plus 6 serving pieces; and

 Standard, capacity equal to or greater than8 place settings plus 6 serving pieces.

5-5For dehumidifiers , the Energy Policy Act of 2005, Public Law 109-58, (EPACT 2005) sets energy conservation standards based on the capaci ty of the unit as measured in pints of water extracted per day. (EPACT 2005, section 135(c), 42 U.S.C. 6295(cc)) DOE believes that there are unique design constraints associ ated with a unit’s capacity that warrant the creation of these separate classes. The pints of water extracte d per day are measured us ing the test procedure outlined in ANSI/AHAM Sta ndard DH-1-2003, Dehumidifiers . For standards effective October 1, 2007, EPACT 2005, in section 135(c), names 5 pr oduct classes. EPACT 2005 also prescribes a new set of amended standards for dehumidifiers in the event that DOE fails to publish a final rule requiring new standards to take effect by October 1, 201 2. In providing a new set of standards, EPACT 2005, in section 135(c), s ubdivides the 35.01-54.00 pi nts/day product class into 2 product classes: 35.01-45.00 pints/ day and 45.01-54.00 pints/day. The 2012 product classes are shown below.

 25.00 pints/day or less;

 25.01–35.00 pints/day;

 35.01–45.00 pints/day;

 45.01–54.00 pints/day;

 54.01–74.99 pints/day; and

 75.00 pints/day or more.

For cooking products , DOE analyzed product classes based on the energy source ( i.e. , gas or electric) and the cooking method ( i.e. cooktops, ovens, and microwave ovens). These distinctions yielded 5 cooking pr oduct classes: gas cooktops, el ectric cooktops, gas ovens, electric ovens, and microwave ovens. DOE’s pr oduct classes are based on the list of product classes defined by DOE in its 1996 Technica l Support Document for Residential Cooking Products (1996 TSD), which was released as part of the previous standards rulemaking. 1 Gas and electric ranges aare not listed below as product classes. Because ranges consist of both a cooktop and oven, any potential cooktop and oven standards will apply to the individual components of the range. As a result, produc t classes for ranges are not necessary.
For gas cooktops , DOE’s analyzed product class is:

 Conventional burners.
For electric cooktops , D OE’s 1996 TSD determined that the ease of cleaning smooth elements provides enhanced consumer utility over coil elements. Because smooth elements typically use more energy than coil elements , DOE analyzed the following product classes for electric cooktops:

 Low or high wattage open (coil) elements; and

 Smooth elements.

aDOE defines a “conventional range” under EPCA as “a class of kitchen ranges and ovens which is a household cooking appliance consisting of a conventional cooking top and one or more conventional ovens.” (10 CFR 430.2)

5-6For electric ovens , the 1996 TSD determined that the type of oven-cleaning system is a utility feature that affects performance. DOE found that standard ovens and ovens using a catalytic continuous-cleaning process use roughly the same amount of energy. Self-cleaning ovens use a pyrolytic process that provides enhan ced consumer utility with lower overall energy consumption as compared to either standard orcatalytically-lined ovens . Thus, DOE analyzed the following product classes for electric ovens:

 Standard oven with or w ithout a catalytic line; and

 Self-cleaning oven.
For gas ovens , DOE analyzed the following produc t classes based upon the sam e reasoning as electric ovens:

 Standard oven with or w ithout a catalytic line; and

 Self-cleaning oven.
For microw ave ovens , DOE analyzed no further class breakdown. This product class can encompass microwave ovens with and with out browning elements, but does not include microwave ovens that incorporate convection systems (combination ovens). DOE will not conduct an analysis at this time of combination microwave ovens due to the inability of the test procedure to measure the perfor mance of the convection component and thus a lack of data evaluating the energy efficiency or energy effi ciency characteristics of microwave ovens incoporating convection systems
For commercial clothes w ashers , EPCA, as amended by EP ACT 2005, applies a single standard for energy efficiency and a single standard for water efficiency to all CCWs. (EPACT 2005, section 136(e); 42 U.S.C. 6313(e)) This class encompasses both top- and front-loading units. The statutory provisions do not, however, specifically prevent DOE from creating separate product classes subject to the same standards, if such differentiation is deemed appropriate. In determining product classes, DOE recognizes there ar e five classes of residential clothes washer classes which are differentiated, inpart, by washer axis and thatthere is certain commonality between commercial and residential clothes washers. b However, despite the similarities between residential and commercial clothes washers, th e Congress enacted a singl e standard for CCWs some years after DOE established the five clas ses for residential clothes washers, which may suggest that Congress intended for DOE to retain a single class wh en updating these standards.DOE decided to keep a single product class that encompasses both top-loading and frontloading units for this analysis for several reasons. Also, DOE believes that, even though there
m ay be some performance-related features on existing CCWs that might warrant multiple CCW

b DOE understands how some stakeholders could interpret there being only one class of standard-size residential clothes washers in DOE’s regulations since the value of the en ergy efficiency standard is the same for both classes. While the standards are the same, DOE notes they are separate in DOE’s regulations found at 430.32(g). The maxtech level for the two classes are diffe rent, because of the utility features, and are, therefore, representative of separate classes.

5-7product classes (as was demonstrated in the resi dential clothes washer rulemaking), technologies may be available that enable top-loading units to attain the same efficiency level as front-loading units, thereby rendering any product class distinction meaningless. DOE was sensitive to other considerations including the likely outcome of requisite U.S. Department of Justice (DOJ) review of the potential impacts, if any, of efficiency standards on competition, given that a large percentage of the overall market for commercial washers is produced by one manufacturer that specializes in vertical-axis machines. Another consideration may be th e potential effect of multiple-class standards on the market shares of ve rtical-axis and horizontal-axis machines. For example, if separate standards further widene d the first cost differences between these two classes of washers, than the ove rall result might be a decline in the market share of the more energy efficient horizontal-axis machines, which could more than offset any energy savings achiieved in verti cal-axis machines.

5.4 EFFICIENCY LEVELS

5.4.1 Baseline Units
DOE selected baseline units as reference points for each p roduct class, against which DOE measured changes resulting from energy cons ervation standards. The baseline unit in each product class represents the basic ch aracteristics of equipm ent in that class. Typically, a baseline unit is a unit that just meets current required energy conservation standards and provides basic consumer utility. DOE used the baseline units in the engine ering analysis and th e life-cycle-cost and payback-period analysis. To determine energy savings and changes in price, DOE compared each higher-energy-efficiency or lower-energy-effi ciency design option with the baseline unit. The identification of baseline units required es tablishing the baseline efficiency level. EPACT 2005 established standards for dehum idif iers and commercial clothes washers that become effective October 1, 2007. For dishwasher s, DOE selected baseline efficiency levels based upon the current minimum standard. For cooking products, no minimum standards exist, so DOE selected baseline levels from the 1996 TSD. For commercial clothes washers, DOE used the baseline unit to evaluate new water fact or standards in addition to energy conservation standards. The minimum energy conservation standards for dishw ashers , as measured by the energy factor (EF) in cycles per kilowatt-hour (kWh), became effective on May 14, 1994. DOE developed the following standards for compact and standard capacity dishwashers (10 CFR Part 430.32(f), Subpart C):

 Com pact = 0.62 EF; and

 Standard = 0.46 EF.

5-8For dehumidifiers , each energy efficiency level is e xpressed as a minimum EF, which is a function of liters per kWh. EPACT 2005 sets the current minimum energy conservation standards for dehumidifiers based on the unit’s capacity (in pints/day). Table 5.4.1 shows the product classes established by EPACT 2005, along with the standard levels set to take effect October 1, 2007. (EPACT 2005, section 135 (c)(4); 42 U.S.C. 6295(cc); 70 FR 60407, 60414, (October 18, 2005); 10 CFR 430.32(v)) DOE will us e the October 1, 2007 levels as baseline efficiency levels.
Table 5.4.1 EPACT 20 05 Standards for Residential Dehumidifiers

Dehumidifier Capacity Standards Effective October 1, 2007 EF, liters/kWh 25.00 pints/day or less 1.00 25.01–35.00 pints/day 1.20 35.01–54.00 pints/day 1.30 54.01–74.99 pints/day 1.50 75.00 pints/day or more 2.25
For residential cooking p roducts (except for the prescriptive standard for gas products), there are no existing minimum energy conservation st andards, as previous analyses failed to determine economic justification for them. The DOE test procedure uses an EF to rate the efficiency of cooking products. The EF for th ese products is the ratio of the annual useful cooking energy output of the re sidential cooking appliance ( i.e. the energy conveyed to the item being heated) to its total annual energy cons umption. In accordance with the 1996 TSD on residential cooking products, DOE has selected the baseline EFs for the product classes DOE is using in this rulemaking listed in Table 5.4.2 Table 5.4.2 1996 TSD Baseline Energy Factors for Cooking Products

Product Class Baseline from 1996 TSD EF Gas Conventional Burner Cooktop 0.156 Electric Open (Coil) Element Cooktop 0.737 Electric Smooth Element Cooktop 0.742 Gas Standard Oven 0.030 Gas Self-Clean Oven 0.054 Electric Standard Oven 0.107 Electric Self-Clean Oven 0.096 Microwave Oven 0.557
For all commercial clothes w ashers , EPCA establishes the following energy and water conservation standards: a mini mum modified energy factor (MEF) of 1.26 cubic feet (ft 3 ) per kWh and a maximum water factor (WF) of 9.5 ga llons per cubic foot. (EPACT 2005, section 136(e); 42 U.S.C. 6313(e); see also 70 FR 60416 (Oct. 18, 2005), adding 10 CFR 431.156) In this rulemaking, DOE is using a baseline model that has those efficiencies. The MEF takes into

5-9consideration not only the energy consumption of the washer but also the amount of energy required to dry clothes based on the remaini ng moisture content of the clothes.

5.4.2 Incremental Efficiency Levels For the majority of the product classes pres ented in section 5.3, DOE analyzed several efficiency levels and ob tained incremental cost data at each of these levels. Tables 5.4.3 through Table 5.4.10 provide efficiency levels and the re ference source of each level for each of the products under consideration. DOE notes that in some cases the highest efficiency level was identified based on a review of available produc t literature for products commercially available ( i.e. , commercial clothes washers, dishwashers, and dehumidifiers ). For cooking products, the maximum levels identified Table 5.4.5 through Table 5.4.9 are based on data developed from the design option analysis in th e previous rulemaking.
For residential dishw ashers , DOE considered 7 efficiencylevels beyond the baseline efficiency levels for both standard and compact product classes, as listed in Table 5.4.3. These levels were derived from Energy Star c criteria, Consortium for Energy Efficiency (CEE) Tier 1 and 2 levels, and the current maximum technology that is commercially available. DOE also added 2 levels to fill the gap between CEE Tier 2 and the current maximum technology that is commercially available. As will be discu ssed in section 5.6.1.1, AHAM provided incremental cost data for the first 5 efficiency levels of the standard class only. For compact dishwashers, fewer than 3 manufacturers produce products within th is product class. Therefore, for disclosure purposes, AHAM did not submit data. As a result, DOE conducted an engineering analysis only on standard dishwashers DOE achieved scaling for compact dishwashers by using the ratio of current standard levels for standard size vers us compact size units, a lthough it determined the max-tech level by a review of technology in th e current Energy Star database of certified dishwashers.

c Energy Star is a voluntary labeling program, backed by the U.S. Environmental Protection Agency (EPA) and DOE, which identifies energy efficient pr oducts through a qualification program.

5-10Table 5.4.3 Efficiency Levels for Residential Dishwashers Level Efficiency Level Source Efficiency Level (EF), cycles/kWh Compact Standard baseline Current Federal Standard 0.62 0.46 1 Energy Star (prior to January 1, 2007) (scaled for com pact) 0.78 0.58 2 CEE Tier 1 (2006) (scaled for compact) 0.84 0.62 3 Energy Star (January 1, 2007) 0.88 0.65 4 CEE Tier 2 (2006) (scaled for compact) 0.92 0.68 5 Gap Fill 1.01 0.72 6 Gap Fill 1.08 0.80 7 Max Available 1.74 1.11 AHAM provided incremental cost data for 3 of the 6 dehumidif ier product classes. The other product classes were not explicitly consider ed in the engineering an alysis and DOE intends to extend the results in late r analyses to the omitted cl asses (45.01-54.00 pints/day, 75.00 and greater pints/day, and 25.00 pints/ day or less). DOE combined two product classes defined by EPACT 2005—25.00 pints/day or less and 25.01 –35.00 pints/day—to form a single product class of 0–35.00 pints/day for this analysis, due to the similar aggregation of data by AHAM in its manufacturer cost data submittal. For purpos es of conducting the NIA, DOE believes that the results from the product classes analyzed can be extended to the two statutorily-set product classes for which AHAM data (or comparable data) are unavailable. This approach is believed to be valid due to chassis and component sim ilarities among the product classes, with primary differences due to scaling. To create incremental efficiency levels for residential dehumidifiers shown in Table 5.4.4, DOE used the def ault 2012 standards, Energy St ar data, and stakehol der input. The first efficiency level above the baseline is a gap f ill between the baseline and the default efficiency level set to become effective October 1, 2012. The second efficiency level is the default efficiency level set to become effective October 1, 2012. Dehumidi fier manufacturers recommended the third and fourth levels. The fifth level is the maximum efficiency level available in the Energy Star da tabase of qualified dehumidifiers, as of April 27, 2006. Table 5.4.4 shows incremental efficiency levels fo r the product classes for which AHAM subm itted data.

5-11Table 5.4.4 Efficiency Levels for Residential Dehumidifiers Dehumidifier Capacity Efficiency Level (EF), liters/kWh baseline 1 2 3 4 5** 0–35.00 pints/day 1.20* 1.25 1.30 1.35 1.40 1.45 35.01–45.00 pints/day 1.30 1.35 1.40 1.45 1.50 1.74 54.01–74.99 pints/day 1.50 1.55 1.60 1.65 1.70 1.80 *Note: baseline efficiency level listed is the baseline level for dehumidifiers rated at 25.01-35.00 Pints/Day ** Max available Table 5.4.5 presents the efficiency levels analyzed for residential gas cooktops . The baseline and higher efficiency levels are based on the analysis performed in 1996 for the previous rulemaking. Since the 1996 TSD took a design-options approach to the analysis, each efficiency level is associated with a particular desi gn option or combination of design options. Two higher efficiency levels for gas cooktops were included in the 1996 TSD that are not considered here due to the elim ination of design options. In the current analysis, reflective surfaces are screened out due to impacts on c onsumer utility, and thermostatically-controlled burners were not analyzed for the ANOPR due to the inability of the DOE test procedure to adequately represent usage patterns and ther efore energy efficiency characteristics. The combination of design options that produces the maximum technologically feasible EF is designated as “max tech”. DOE has structured the analysis for standi ng pilot igntion system s as a design option associated with the baseline configurations because DOE has determined that cooktops incorporating such ignition systems do not pr ovide unique utility. Power outages are not frequent and long enough for residential electricit y customers to consider operation during a lack of electric power a significant utility. Between 90 and 93 percent of such customers experience no electricity outages longer than four hours per year. 2 The first standards efficiency level corresponds to the eliminati on of standing pilot lights.
Table 5.4.5 Effic iency Levels for Residential Gas Cooktops

Level Efficiency Level Source Conventional Burners Cooking Efficiency EF baseline 1996 TSD Baseline (with standing pilots) 0.399 0.156 1 1996 TSD (without standing pilots) 0.399 0.399 2 Max Tech (1996 TSD) 0.420 0.420 The 1996 TSD analyzed 2 efficiency levels for electric coil cooktops and 3 levels for electric sm ooth cooktops. Si nce the 1996 TSD took a design-opti ons approach to the analysis, each efficiency level is associated with a particular design option or combination of design options. In the current analysis, however, reflec tive surfaces are screened out as a design option for electric coil cooktops due to impacts on c onsumer utility, and induction elements are not analyzed for electric smooth cooktops because th e available efficiency data, while suggestive of energy savings, cannot be validated by the exis ting DOE test procedure. In addition, radiant elements for smooth electric cooktops, which were included in the 1996 TSD, were not

5-12considered as a design option for this rulemaki ng because manufacturer data provided to DOE for the 1996 TSD indicated that this technology do es not offer an efficiency improvement over the baseline according to the DOE test procedure. Therefore, only a single efficiency level beyond the baseline is being analyzed for both electric coil and smooth cooktops, and by default this level becomes the max tech, as shown in Table 5.4.6.
Table 5.4.6 Efficiency Levels for Resi dential Electric Cooktops

Level Efficiency Level Source Open (Coil) Elements Smooth Elements Cooking Efficiency EF Cooking Efficiency EF baseline 1996 TSD Baseline 0.737 0.737 0.742 0.742 1 1996 TSD 0.769 (Max Tech) 0.769 0.753 (Max Tech) 0.753 Efficiency levels for gas ovens, as show n in Table 5.4.7, are based on the 1996 TSD. Since the 19 96 TSD took a design-options approach to the analysis, each efficiency level is associated with a particular de sign option or combination of de sign options. The oven separator design option from the 1996 TSD was screened out in the current analys is due to consumer safety and utility issues, as we ll as a lack of practicability to design and manufacture. Lowstandby-loss electronic controls we re added as design options for both standard and self-cleaning gas ovens, but were not included as efficiency levels because DOE does not have efficiency or cost increment information on them. The baseline efficiency level for gas standard ov ens assumes that th e product is equipped with standing pilot lights, and the first standard s efficiency level corresponds to the elimination of standing pilot lights based on the same reas on as for gas cooktops. However, because the cleaning cycle of gas self-clean ovens requires electr ical energy use, EPCA in effect requires that such ovens currently be equipped with a non-standing pilot ignition system because such an ignition system is disallowed if there is an elect rical cord provided on the product. Therefore, the baseline efficiency level for ga s self-cleaning ovens assumes th ey lack a standing pilot light. Further, the first standards efficiency level is not based on elimination of a standing pilot, but rather on the addition of the forced convection design option. Electronic spark ignition lowers the standby power consumption as well as the cooking efficiency of standard gas ovens, and since th e standard gas oven EF rating includes standby power, results in an ov erall reduction in ener gy consumption. Electric spark ignition has the same functionality as ho t surface ignition sources and is therefore listed as an alternate efficiency level to the hot surface (glo-bar ) design option. DOE is seeking input on these as design options from stakeholders for the Noti ce of Proposed Rulemaking (NOPR).

5-13Table 5.4.7 Efficiency Levels for Residential Gas Ovens
Level Efficiency Level Source Standard Oven Self-Cleaning Oven Cooking Efficiency EF Cooking Efficiency EF
baseline 1996 TSD Baseline (with standing pilot light) 0.059 0.0298 0.071 0.0540
1 1996 TSD 0.058 (Glo-bar ignition) 0.0536 0.088 0.0625 2 1996 TSD 0.061 0.0566 0.088 0.0627 3 1996 TSD 0.062 0.0572 0.089 (Max Tech) 0.0632 4 1996 TSD 0.065 0.0593

- - 5 1996 TSD 0.065 0.0596

- - 6 1996 TSD/Current Analysis 0.066 (Max Tech) 0.0600

- - 1a (1) 1996 TSD (with electronic spark ignition) 0.058 0.0583

- - (1) Note: Standard levels 1 and 1a correspond to designs that are utilized for the same purpose--eliminate the need for a standing pilot--but the technologies for each design are different. Standard level 1 is a hot surface ignition device while standard level 1a is a spark ignition device Efficiency levels for electric ovens, s hown in Table 5.4.8, are primarily based on the 1996 TSD. The oven separator design option from the 1996 TSD was screened out in the current analysis due to consumer safety and utility issues, as well as a l ack of practicabil ity to design and manufacture. The bi-radiant oven was screened ou t due to a lack of tech nological feasibility and practicability to manufacture, as well as impacts on consum er utility. Low-standby-loss electronic controls were added as design options for both standa rd and self-cleaning electric ovens in this analysis, but were not included as efficiency levels because, even though the test procedure accounts for the energy consumption of electronic controls, DOE does not have incremental efficiency or cost information on them. DOE is seeki ng input on these from stakeholders for the NOPR.
Table 5.4.8 Efficiency Levels for Residential Electric Ov ens

Level Efficiency Level Source Standard Oven Self Cleaning Oven Cooking Efficiency EF Cooking Effic iency EF baseline 1996 TSD Baseline 0.122 0.1066 0.138 0.1099 1 1996 TSD/Current Analysis 0.128 0.1113 0.138 0.1102 2 1996 TSD/Current Analysis 0.134 0.1163 0.142 (max-tech) 0.1123 3 1996 TSD/Current Analysis 0.137 0.1181

- - 4 1996 TSD/Current Analysis 0.140 0.1206

- - 5 1996 TSD/Current Analysis 0.141 (max-tech) 0.1209

- - For microwave ovens, Table 5.4.9 li sts the efficiency levels th at were retained from the 1996 TSD, even though recent AHAM-supplied data s uggests slightly different baseline and maximum-available efficiencies of a representative sample of current models. For example, the

5-14minimum average efficiency among the microw ave ovens recently tested by AHAM was 54.8 percent, while the maximum average efficiency was 61.8 percent, compared to 55.7 percent and 60.2 percent, respectively, from the 1996 TSD. However, it was noted that the standard deviation in efficiency measurem ents for any given microwave oven ranged from 0.2 to 1.2 absolute percentage points. Th erefore, given this test-to-testvariation, it was determined by DOE that the efficiency levels from the 1996 TSD we re still representative of the state of current microwave oven technology to the ex tent that the DOE test proce dure can capture performance. Further discussion of the AHAM test data is provided in section 5.6.3.1.
Table 5.4.9 Efficiency Levels for Residential Microw ave Ovens

Level Efficiency Level Source Efficiency Level (EF) baseline 1996 TSD Baseline 0.557 1 1996 TSD 0.586 2 1996 TSD 0.588 3 1996 TSD 0.597 4 1996 TSD Max Tech 0.602
EPCA mandates that DOE determine both a m inimum MEF and a maximum WF. DOE analyzed 6 efficiency levels beyond the baseline for commercial clothes washers, as listed in Table 5.4.10. These levels were based on Ener gy Star, the CEE Commer cial Clothes Washer Initiative, and maximum levels that are currentlycommercially available. A gap-fill level was added based on stakeholder input. AHAM provide d incremental cost data only at 2 of these levels (1.42 MEF/9.5 WF and 2.00 MEF/5.5 WF).
Table 5.4.10 Efficiency Levels for Commercia l Clothes Washers

Level Efficiency Level Source Efficiency Level MEF, ft 3 /kWh WF, gallons/ft 3 baseline DOE Standard (effective 2007) 1.26 9.5 1 CEE Tier 1 (January 1, 2004) 1.42 9.5 2 CEE Tier 2 (January 1, 2004) 1.60 8.5 3 Energy Star (effective 2007) 1.72 8.0 4 CEE Tier 3A (January 1, 2004) 1.80 7.5 5 Gap Fill 2.00 5.5 6 Max Available 2.20 5.1

5.5 METHODOLOGY OVERVIEW DOE used data submitted by AHAM as the primary source of cost information for the engineering analysis. AHAM pr ovided DOE with aggregated incremental manufacturing cost data from it member companies. DOE conducte d an independent review of the AHAM data using several methods and data sources. To ga in a better understanding of the data submitted by member companies and to be able to relate th e costs of improving effici ency to discrete (or

5-15system) technologies, DOE conducted interviews w ith manufacturers of residential dishwashers and dehumidifiers and commercial clothes washers. For dishwashers and dehumidifiers, DOE performed detailed product teardowns on several pr oduct models spanning a range of efficiencies to generate similar cost-efficiency curves for validation of the AHAM data. For products which were the subject of a rulemaking in the recent past, DOE reviewed the previous TSDs and compared cost and performance information to the AHAM data and other published data. Finally, DOE conducted detailed energy performan ce testing of dishwashers at an independent laboratory to gain insights into energy performance and disaggregated energy use of components and subsystems. Table 5.5.1 below shows which methods DOE used for each product.
Table 5.5.1 Engineerin g Analysis Methods

Method Products Dishwashers Dehumidifiers Cooking Products Commercial Clothes Wa shers AHAM Data √ √ √ √ Review of Past TSD √ √ Product Teardown √ √ Product Testing √ Manufacturer Interv iews √ √ √

5.5.1 AHAM Data Request In support of this rulemaking effort, DOE requested incremental cost data from AHAM for each of the 4 product catego ries. The data represent the average incremental production cost to improve a baseline unit to a specified efficiency level. This methodology constitutes an efficiency-level approach to the engineeri ng analysis because DOE examined aggregated incremental increases in manufacturer selling pric e at specified levels of energy efficiency. In addition, DOE requested shipments, shipment-wei ghted average efficiency, and market share efficiency data. Tables of aggregated da ta provided to DOE by AHAM are contained in Appendix 5A.

5.5.2 Manufacturer Interviews AHAM provided to DOE shipment-weighted ma nufacturer costs. These costs included the shipm ent-weighted average cost as well as the lowest and highest single-manufacturer cost to achieve efficiency levels above the baseline level. Presenting the data in this manner enables stakeholders to appreciate the variability in baseline units, design strategies, and cost structures that exist among manufac turers. To better understand and explain the causes of these cost variances, DOE supplemented th ese cost data with inform ation obtained through follow-up manufacturer interviews. These confidential interviews provide d a deeper understanding of the

5-16various combinations of technologies used to in crease product efficienc y, and their associated manufacturing costs. Sample questions asked during the follow-up in terviews are contained in Appendix 5B. During the interviews, DOE also gathered inform ation about the capital expenditures required to increase the efficiency of the ba seline units to various efficiency levels ( i.e. , conversion capital expenditures by efficiency or energy-use level). The interviews provided information about the size and the nature of the capital investments. DOE also requested information about the depreciation method used to expense the conversion capital.

5.5.3 Product Teardowns Other than obtaining detailed manufacturing co st s directly from a ma nufacturer, the most accurate method for determining the production cost of a piece of equipmen t is to disassemble the equipment piece-by-piece and estimate the materi al and labor cost of each component using a process commonly called a physical teardown. A supplementary method, called a catalog teardown, uses published manufactur er catalogs and supplementary component data to estimate the major physical differences between a piec e of equipment that has been physically disassembled and another piece of similar equi pment. DOE only performed physical teardown analysis on dehumidifiers and dishwashers. The teardown methodology is expanded in section 5.5.3.1 and section 5.5.3.2. Selection of Units During the process of selecting units for teardown, DOE considered 3 main questions:

 What efficiency levels should be captured in the t eardown analysis?

 Are there units on the market th at capture all potential effici ency levels and design options?

 Which of the available units are most representative? In responding to the preceding questions , DOE a dopted the following criteria for selecting units for the teardown analysis:

 The selected products should span the full range of efficiency levels for each product class under consideration;

 Within each product class, if possible, the se lected products should come from the same manufacturer and be within the same product series;

 The selected products should prim arily com e from manufacturers with large market share in that product class, although the highest effici ency products were chosen irrespective of manufacturer; and

 The selected products should have non-efficiency -related features that are the same as, or similar to, features of other products in the sa me class and at the same efficiency level.

5-17Additional criteria for select ing the teardown units specific to each product category are described in sections 5.6.1.3 for dishwash ers and section 5.6.2.3 for dehumidifiers.

5.5.3.1 Generation of Bill of Materials
The end result of each teardown is a structur ed bill of materials (BOM). Structured BOMs describe each equ ipment part and its relations hip to the other parts, in the estimated order of assembly. The BOMs describe each fabrication and assembly operatio n in detail, including the type of equipment needed ( e.g. , stamping presses, injection mo lding machines, spot-welders, etc.) and the process cycle times. The resultis a thorough and explicit model of the production process. The BOMs incorporate all materials, components, and fasteners, classi fied as either raw
m aterials or purchased parts and assemblies. Th e classification into raw materials or purchased parts is based on DOE’s previous industry expe rience, recent informati on in trade publications, and discussions with high- and low-volume original equipment manufacturers (OEMs). For purchased parts, the purchase price is an estim ate based on volume-variable price quotations and detailed disc ussions with suppliers. For fabricated parts, the price of intermediate materials ( e.g. , tube, sheet metal) and the cost of transforming them into finished parts are an estimate based on current industry pricing.
The cost of raw materials was determined us ing prices for copper, steel and alum inum from the American Metals Market. 3 The prices for rifled an d unrifled copper tubing were obtained directly from a tubing manufacturer. The price of steel drasticallyincreased in 2005, and the pr ice of copper has increased stead ily since 2004. Because DOE is using a 5-y ear average in material prices from 2002-2006, these price increases are norma lized, which better represents long-term material prices.

5.5.3.2 Cost Structure of the Spreadsheet Models The manufacturing cost assessment methodology used is a detailed, com ponent-focused technique for rigorously calculati ng the manufacturing cost of a pr oduct (direct materials, direct labor and some overhead costs). Figure 5.5.1 shows the 3 major steps in generating the manufacturing cost.

5-18Figure 5.5.2 Manufacturing Cost Assessment Stages The first step in the manufacturing cost a sse ssment was the creation of a complete and structured BOM from the disassembly of the units selected for teardown. The units were dismantled, and each part was characterized according to weight, manufacturing processes used, dimensions, material, and quantity. The BOM in corporates all materials, components, and fasteners with estimates of raw material costs and purchased part costs. Assumptions on the sourcing of parts and in-house fabrication were based on industry experience, information in trade publications, and discussions with manufact urers. Interviews and plant visits were conducted with manufacturers to ensure accuracy on methodology and pricing. Following the development of a detailed BOM, the major manufacturing processes were identified and developed for the spreadsheet m odel. These processes are listed in Table 5.5.2.
Table 5.5.2 Major Man ufacturing Processes

Fabrication Finishing Assembly/Joining Quality Co ntrol Fixturing Washing Adhesive Bonding Inspecting & Testing Stamping/Pressing Powder Coating Spot Welding Brake Forming De-burring Seam Welding Cutting and Shearing Polishing Insulating Fabrication process cycle times were estimat ed and entered into the BOM. For this analysis, $24.00 per hour was used as the average fully-burdened labor rate based on typical annual wages and benefits of industry employees. In the final step of the cost assessment, assembly times and associated direct labor costs were estimated. Once the cost estimate for each teardown unit was finalized, a detailed summar y was prepared for relevant components, subassemblies and processes. The BOM thus details all aspects of unit costs. Design options used in units subject to tear down are noted in the summ ary sheet of each cost model and are cost-estimated individually. Thus, various implementations of design options can be accommodated, ranging from assemblies that ar e entirely purchased to units that are made entirely from raw materials. Hybrid assemblies, consisting of purchased parts and parts made on site are thus also accommodated.

5-195.5.4 Review of Previous Technical Support Documents DOE reviewed previous rulemaking TSDs to assess the ir applicability to the current standard setting process for cooki ng products and commercial clothe s washers. These previous rulemaking technical support doc uments served as a source for design options, baseline efficiency levels, and energy consumption analysis, in addition to other sources. DOE utilized the 1996 cooking products TSD as a source for baseli ne unit efficiency as well as design options and incremental cost and efficiency data. This approach for cooking products was endorsed by stakeholders. DOE also reviewed the 2000 reside ntial clothes washer TSD since residential and commercial clothes washers share the same de sign options, are frequently built on the same chassis, and are therefore subjec t to similar economic impacts.

5.5.5 Product Testing DOE conducted product testing on reside ntial dishwashers to develop a better understanding of the potential efficiency impr ovements of design options and to develop disaggregated efficiency data.

5.6 ANALYSIS AND RESULTS

5.6.1 Dishwashers The dishwasher engineering analysis was pe rformed by considering cost and efficiency inform ation from multiple sources. AHAM provided incremental manufacturing costs for all but the highest efficiency levels of interest to DOE. DOE supplemented these data points by conducting its own engineering anal ysis, comprised of performance testing at an independent laboratory and manufacturing costestimates from detailed teardowns of currently-available dishwashers. Manufacturer interviews were al so conducted to obtain greater insight into the design strategies to improve effici ency and the associated costs.

5.6.1.1 AHAM Data AHAM provided to DOE shipment data from its member companies for dishwashers. Table 5.6.1 shows m arket share by energy factor for residential dishwasher shipments from 2002 to 2005.

5-20Table 5.6.1 AHAM Dishwasher Market Share Data Submittal EF Range, cycles/kWh Year 2002 2003 2004 2005 0.46-0.49 (Baseline = 0.46) 40% 22% 9% 3% 0.50-0.53 9% 5% 2% 2% 0.54-0.57 0% 0% 0% 2% 0.58-0.59 (2006 Energy Star = 0.58) 15% 19% 18% 43% 0.60-0.61 13% 16% 28% 17% 0.62-0.63 4% 23% 31% 22% 0.64-0.65 (2007 Energy Star = 0.65) 9% 6% 9% 8% 0.66-0.67 5% 5% 1% 0% 0.68 and above 5% 5% 2% 3% TOTAL: 100% 100% 100% 100% On a shipment-weighted basis, the average effi ciency of a dishwasher sold in the U.S. has been increasing since 1995, according to the AHAM-subm itted data shown in Table 5.6.2.
Table 5.6.2 AHAM Dishw asher Shipments and Shi pment-Weighted Efficiency Data Submittal
Year Shipments, Domestic + Imports (# of Units) Shipment-Weighted Average Efficiency

(EF, cycles/kWh ) 1995 4,253,745 0.485 1996 4,316,828 0.476 1997 4,655,200 0.495 1998 5,073,023 0.508 1999 5,424,973 0.504 2000 5,833,686 0.503 2001 5,752,217 0.533 2002 5,906,348 0.553 2003 6,467,303 0.581 2004 6,867,551 0.598 2005 7,280,046 0.599 AHAM also provided DOE with incremental ma nufacturing cost data from its m ember companies up to an EF of 0.72. These data in clude minimum, maximum and average shipmentweighted total incremental costs. These incremental costs include capital costs for tooling and equipment, depreciated assuming a 5-year useful life. In addition, AHAM estimated the number of dishwashers shipped that would be impacted by standards at each level. The data submitted by AHAM represents a ggregate input from the producers of approxim ately 90 percent of the standard dishwa shers sold in the U.S. Table 5.6.3 shows the submitted data.

5-21Table 5.6.3 AHAM Dishwasher Incremental Cost Data Submittal EF Level ( cycles /kWh ) 0.58 0.62 0.65 0.68 0.72 Shipment-Weighted Increm ental Cost ($) for each EF level Min. 3.22 4.52 5.39 17.11 34.05 Avg. 4.01 7.38 14.00 30.35 71.38 Max. 4.92 8.43 14.50 37.64 91.74 Avg. One-Time Product Conversion Expenses, Million $, Total for all Manufacturers R&D 1.43 4.43 5.73 18.53 29.23 Marketing 0.99 1.99 3.29 7.49 13.99 Conversion Capital Expenditure Assum ptions, Million $, Total for all Manufacturers Building Insufficient Manufacturer Data Submitted Tooling and Equipm ent 16.85 19.95 23.25 44.85 98.45 Total Shipments, Thousands, subject to retooling, conversion, etc. as a function of minimum EF level revis ion 3,452 7,302 7,302 7,302 7,302Incremental Cost ($) Note: Shipment-weighted tooling equipment depreciation lifetime is 5 years Figure 5.6.1 plots the average incremental co st as a function of EF for the AHAM dishwasher data. The lowest point on the graph indicates the baseline level and therefore has a cost increment of $0. Note that the curve ‘breaks’ at an EF of 0.65. Above this EF, the cost to raise dishwasher efficiency increases dramatically.

$80
$70
$60
$50
$40
$30
$20
$10

$0 0.72, $71.38

0.46, $0.00

0.4 0.45 0.5 0.55 0.6 0.65 0.7 0.75 EF Figure 5.6.1 AHAM Dishwasher Cost-Efficiency Curve

5-225.6.1.2 Product Testing Dishwasher testing was performed on a group of dishwashers coveri ng a broad range of potential standard levels. Th e test results included submeter ed component energy consumption data which enabled DOE to measure the performance of various design options. The tests also served to quantify patterns of water and energy consumption during various stages of the cycle and identify energy efficiency and wash performa nce strategies. Six standard-size dishwashers were identified as test units whose EFs spanne d a range across two different product platforms from the minimum Energy Star level (prior to th e increase in January 2007) to the maximum EF available. The products chosen comprised multipl e units from multiple manufacturers, and were selected carefully to identify design options as sociated with each e fficiency level. Beyond measurements required to measure the performa nce according to the DOE test procedure, the testing consisted of multi-submetering to record disaggregated energy consumption with various design options. Table 5.6.4 lists features of the tested units.
Table 5.6.4 Dishw asher Test Unit Features

Feature Dishwasher Test Unit Designation #1 #2 #3 #4 #5 #6 Rated EF (cycle/kWh) 0.58 0.64 0.68 0.78 0.93 1.11
Controls Electronic ElectroMechanical Electronic Electronic Electronic Electronic Soil Sensing No No Yes No Yes Yes Tub Material Plastic Plastic Plastic Stainless Stainless Stainless Main Pump Speeds 1 1 3 1 1, Triac control 1, Triac control Spray System 2 arms, 1 nozzle 2 arms, 1 nozzle 3 arms 2 arms 2 arms 2 main arms, 1 cutlery tray sprayer Spray Arm Diverter Yes Yes Yes No Yes Yes Valve Water Heater Type Tubular Tubular Tubular FlowThrough FlowThrough FlowThrough Temperature Sensor Fixed Fixed Thermocouple Thermocouple Thermocouple Thermocouple Venting System None None Active Door Vent None Fan-Assist Vent Fan-Assist Vent
Each dishwasher was tested at an independent lab oratoryaccording to the DOE test procedure (10 CFR 430 Subpart B, Appendix C). Th e test procedure consists of setting nominal ambient and inlet water conditions, selecting a “n ormal cycle”, and running the dishwasher with the appropriate test load. “Norma l” conditions are defined in the te st procedure as the cycle type recommended by the manufacturer for completely washing a full load of normally-soiled dishes

5-23including the power-dry feature. DOE determined that none of the dishwashers tested had a truncated normal cycle, defined as a normal cycle that is interrupted to eliminate the power-dry feature after the te rmination of the last rinse operation. For dishwashers that are not equipped with a soil sensor, the test load consists of 8 clean place settings plus 6 serving pieces, and the unit is run for a single cycle. For soil-sensing dishwashers, the unit is tested at sensor heavy response, sensor medium response, and sensor light response, as defined by the following test loads:

 Sensor Heavy Response – the dishwasher is lo aded with8 place settings plus 6 serving pieces. Four of the 8 place settings ar e soiled according to ANSI/AHAM DW-1-2005.

 Sensor Medium Response – the dishwasher is loaded with 8 place settings plus 6 serving pieces. Two of the 8 place settings are soiled according to ANSI/AHAM DW-1-2005.

 Sensor Ligh t Response – the dishwasher is loaded with 8 place settings plus 6 serving pieces. One of the place settings is soiled with half of the soil load specified for a single place setting according to ANSI/AHAM DW-1-2005. During each test cycle, machine electrical en erg y consumption and water consumption is measured. In addition, for each dishwasher, standby power is measured. In order to calculate EF and annual energy consumption according to the DOE test procedure, the following calculations for machines without truncated no rmal cycles are performed. For non-soil-sensing machines, the machine el ectrical energy consum ption M is simply the measured kWh consumed per cycle. For soil-sensing dishwashers, the machine electrical energy consumption is a weighted average defined as: M = (M hr x F hr ) + (M mr x F mr ) + (M lr x F lr ) where,
M hr = the machine electrical energy consumption for the sensor heavy response test in kWh M mr = the machine electrical energy consumption fo r the sensor medium response test in kWh M lr = the machine electrical energy consumption for the sensor light response test in kWh F hr = the weighting factor based on consumer use of heavy response = 0.05 F mr = the weighting factor based on cons umer use of medium response = 0.33 F lr = the weighting factor based on cons umer use of light response = 0.62
In addition to the machine electrical ener gy consum ption, the EF calculation includes the energy required to heat the water used in the cycl e. For purposes of calculating EF, it is assumed that the water is heated electrically. The wate r energy consumption V in gallons per cycle is based upon the water consumption measured during the normal cycle. For non-soil-sensing machines, V is the number of gallons measured during the test cycle. For soil-sensing dishwashers, the water consumption is: V = (V hr x F hr ) + (V mr x F mr ) + (V lr x F lr ) where,
V hr = the water consumption for the sensor heavy response test in gal/cycle V mr = the water consumption for the sensor medium response test in gal/cycle

5-24L V lr = the water consumption for the sensor light response test in gal/cycle
All of the units were rated for a nom inal 120 ° F inlet water temperature. Thus, for both soil-sensing and non-soil-sensing machines, th e water energy consumption W in kWh for electrically-heated water is defined as: W = V x T x K where,

T = the nominal water heater temperature rise = 70 ° F K = the specific heat of water in kWh per gallon per ° F = 0.0024 Finally, EF, expressed in cycles per kWh, is derived from machine and water energy consumption according to: E = 1/(M + W) Estimated annual energy consumption (EAEU) incorporates not only energy used during dishwashing operations, but standby power throughout the year as we ll. For all dishwashers with normal cycles, EAEU is defined as: EAEU = (M + W) x N + S where, N = the representative average dishwash er use as defined by DOE = 215 cycles/yr S = the annual standby electrical ener gy in kWh per year, defined by:
S = S m x ((H s )/1000) where,
S m = the average standby power in watts; and
H s = H – (N x L) where,
H = the total number of hour s per year = 8766 hours per year = the average duration of the normal cycle for non-soil-sensing dishwashers and the average duration of the sensor light response, sensor m edium response, and sensor heavy response for soil-sensing dishwashers Unfortunately, unit #6 developed control bo ard problem s before testing could be completed. Therefore, further performance analys is for data validation purposes was limited to rated EFs between .58 and .93 (test units #1 through #5). However, test unit #6 was still subject to teardown and costing analysis. Additional instrumentation was provided duri ng these tes ts to measure disaggregated component energy consumption in order to assess which design options could have the greatest impact on efficiency. Watt meters were att ached to the following major components which together account for virtually all of th e electrical usage of the dishwasher:

5-25 heating element;

 main pump motor;

 drain pump motor, if the dishwasher had dual pumps, and;

 vent blower, if the dishwasher was equipped with convective drying. Overall trends in key parameters of the dishwashers under D OE testing are shown in Figure 5.6.2, including average cycle times, machine electrical energy consumption, water consumption, and standby power. Machine elec trical energy and water consumption are weighted averages calculated in accordance withthe DOE test procedure. Cycle time and standby power are simple averages of the 3 tests, with standby power take n as the average power measured immediately after the conc lusion of the normal cycle.

6.0

5.0

4.0

3.0

2.0

1.0

0.0 Consumption, kWh Cycle Time, hours Machine Electrical Energy Water Consumption, gallons Standby Power, W

0.5 0.55 0.6 0.65 0.7 0.75 0.8 0.85 0.9 0.95 1 Rated EF, c ycles/kWh
Figure 5.6.2 Overall Dishwasher Cycle Parameters versus EF The data show that, with the exception of unit #2 with a rated EF of 0.64, t here are relatively consistent trends for machine electric al power consumption a nd water consumption as a function of EF. Unit #2 is somewhat anomalous but its divergent water versus energy-use strategy may be explained due to the use of a fixe d electromechanical timer program in that unit. A plausible explanation could be that the “program” embedded in to the various cam shafts of that timer might be an “older ” program. The electronic units have the benefit of easilyreconfigurable electrically-erasable program mable read-only memory devices (EEPROMs), allowing a manufacturer to reprogr am its dishwasher line at muchlower cost. Some dishwashers that DOE examined even had infrared (IR) receivers and transmitters in the user interface, potentially allowing the reprogramming of units in the field.

5-26Excluding the performance of unit #2, there is almost a linear function for water and machine electrical energy consumption versus EF . Similarly, standby power generally increases with increasing EF. This is likely due to the mo re complex displays and us er interfaces typically associated with higher-end mach ines. Cycle time shows less of a correlation, as cycle times mayEAEUkWh/yr be limited by consumer acceptance. In additi on, as platforms are pushed to higher and higher efficiencies, the thermal drying process is aide d either via active-vent systems that open the cavity to the kitchen, or even power-vent systems that actively pull cooler and drier kitchen air through the cavity, which redu ces the required final rinse water temperature On an EAEU basis, the correla tion with EF becom es much more consistent, as shown in Figure 5.6.3. The somewhat lower EAEU for the 0.64 EF machine may be explained in part by the electromechanical timer inside that dishwasher. Such timers consume no energy when they are not in use, whereas the elec tronic boards found in all other di shwashers may do so in order to keep displays, status knobs, and other aspects of the user interface lit and active.

450
400
350
300
250
200
150
100

50

0 0.4 0.5 0.6 0.7 0.8 0.9 1 Rated EF cy cle/kWh
Figure 5.6.3 Dishwasher EAEU versus EF Time-resolved data from the watt meters allowed each component’s energy consumption to be ascertained for different segm ents of the cycle as well as for the entire cycle. Figure 5.6.4 shows the component energy usage per overall cycle for each of the test units. Each value is obtained via simple averages of the data from the 3 tests for each dishwasher; no weighting based on soil load was applied for soil-sensing m achines in order to prov ide a consistent means of comparison among the test units. Machine electrical energy consumption and water consumption, however, are both reported elsewhere in this section as weighted averages in accordance with the DOE test procedure. It can be seen from Figure 5.6.4 that the heating

5-27element is by far the largest contributor to m achine electrical energy consumption, and therefore optimization of its usage and design will have a si gnificant effect on efficiency. The main pump energy consumption has a second-order impact, while the drain pump and vent blower (if any) have negligible effect on el ectrical energy consumption.

0 0.2 0.4 0.6 0.8

1 1.2kWhEnergy Consumption,

0.58 0.64 0.68 0.78 0.93 Rated EF, cyc les/kWh

l Heater Main Pump Drain Pump Vent B ower Figure 5.6.4 Dishwasher Machine Electrical Energy Consumption Disaggregated by Component Figure 5.6.5 examines water consumption, since water energy consum ption contributes to EF along with machine energy consumption. In constructing this graph, the gallons consumed during the overall cycle were broken down into se parate fill events. Since it is difficult to distinguish a pre-rinse, wash, and rinse portion of the cycle, the fill events were qualified only as a heated or unheated fill. The fills did not necess arily occur in the order that is displayed in the graph; for example, a particular cycle may consist of several unheated fills, a heated fill, another unheated fill, and a final heated fill. However, since fill strategies varied significantly from model to model, in order to compare water us age across all models th is simplified graphing approach was taken.

5-286

5Water Consumption,gallons/cycle

4

3

2

1

0 0.58 0.64 0.68 0.78 0.93 Rated EF, cycle/kWh

Thi First Unheated Fill Second Unheated Fill Third Unheated Fill Fourth Unheated Fill Fifth Unheated Fill First Heated Fill Second Heated Fill rd Heated Fill Fourth Heated Fill Figure 5.6.5 Dishwasher Water Consumption Disaggregated by Cycle Segment The data show that different water usage strategies allow im provement in EF. First, reducing the size of each fill cl early will reduce water consumption and thus water energy consumption, since less energy is required to heat the volume of water both in the water heater and with the booster heater in the dishwasher. Second, the total number of fills may be reduced. For instance, moving from the 0.58 to the 0.68 EF un it eliminated one heated fill. Finally, the relative proportions of heated and unheated fills may be adjusted. Creating a cycle with more unheated fills instead of heated ones means that less electrical energy will be expended to heat the water. However, this also means that in or der to maintain wash performance, the dishwasher will have a greater reliance on mech anical action to loosen soil and require better filtration in order to prevent re-deposition of food particles wh ile contending with the reduced cleaning effect from thermal or chemical energy, via the detergent. Once again, there is an incongruity between uni t #2 and the units at adjacent efficiency levels. This machine trades off higher-than- expected water consumption with lower-thanexpected heater electrical energy input to achieve its EF. To achieve this with 4 heated fills of approximately 1 gallon each requires a reduced water temperature for at least some of the fills. When average tub temperatures are measured for each heated cycle segment, the temperature for unit #2 ranged from 4 ° F to 22 ° F lower than those for comparable cycle segments in the other units. As discussed previously, this performance trade-off may be due entirely to the controller in the unit, since the other physical differences between the (electrom echanical) 0.64 EF unit and the (electronic) 0.58 EF unit are minimal.

5-29To summarize key findings from the testing of a small number of dishwashers, DOE observed that:

 Electrical energy consumption wa s inversely correlated with water consumption, so that the higher-EF d ishwashers used less water.

 The higher-EF m achines tended to have highe r standby power consumption, but on an EAEU basis there was still a consistent do wnward trend as a function of EF

 The higher-EF m achines did not necessarily have longer cycle times and they usually supplemented resistance heat withactive-vent systems or even fan-assisted drying systems. Compared to the power draw of the resistance element, the power re quired to activate a wax motor for vent opening and perhaps a small fan motor is minimal.

 The vast m ajority of electrical energy consumption during the cycle was attributable to the heating element. Energy consumption of the main pump was secondary, and energy consumption from the drain pump and venting mechanism were negligible. Therefore, design strategies that improve he ater efficiency or reduce the quantity of water to be heated have a high impact on EF. Heater configuratio ns are discussed further in the market and technology assessment (Chapter 3 of the TSD).

 The higher -EF machines tended to have more fills per cycle, but less water consumption per fill, so that the total water consumption was lower. Design features to reduce the water required per fill are discussed in the market and technology assessment (Chapter 3 of the TSD).

 The higher -EF machines with more fills tended to have fewer and/or shorter heated ones. They relied more on pre-soaking the dishware , utilizing mechanical energy for a greater percentage of soil removal. Fewer and shor ter heated cycle segments again reduce the overall energy consumption.

5.6.1.3 Product Teardown
Costs DOE tore down the previously-tested dishwash ers to identify design options that can be used to raise EF and their associated costs. DOE also tore down an additional 0.72 E F unit that shared the same platform as some of the tested units. This last dishwasher was not yet available on the market at the time of testing but was released for high-volume manufacturing 3 weeks later. The teardown units spanned the range of efficiencies given in section 5.4.2. Table 5.6.5 compares the incremental efficiency leve ls and EFs of DOE’s teardown units. DOE selected a range of dishwashers that utili zed the sam e platform in order to provide a consistent basis of comparison for design optio ns. The first 4 units (EFs of 0.58, 0.64, 0.68 and 0.72) shared one platform based on the same plastic tub and sump, while the other 3 units shared

5-30a stainless-tub platform that was almost identic al among the 3 models. DOE did not tear down a baseline (0.46 EF) unit because DOE was not awar e of a baseline unit which shared a platform with higher-efficiency machines.
Table 5.6.5 Comparison of Dishw asher Incremental Efficiency Levels and Teardown Unit EFs Incremental Efficiency Level, EF ( cyc le/kWh ) Teardown Unit EF (cycle/k Wh ) 0.58 0.58 0.62 0.64 0.65 0.68 0.68 0.72 0.72 0.78 0.80 0.93 1.11 1.11 After tearing the units down, DOE grouped prod uction costs into the categories shown in Figure 5.6.6. To protect sensit ive manufacturing information, DOE does not display absolute costs. Note that combined material costs (raw material and purchased parts) typically account for 60 percent to 70 percent of the production cost.

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

EF, Cycles/kWh Figure 5.6.6 Dishwasher Full Production Cost Distributions Maintenance Costs

Costs Building Tooling

Purchased Parts
Raw Material 0.58 0.64 0.68 0.72 0.78 0.93 1.11% of Total Production Cost Insurance Costs Property Tax Utility Costs

Indirect Process

Depreciation Depreciation Equipment Depreciation Fabrication Labor Assembly Labor

As can be observed in Figure 5.6.6, the importan ce of raw materials declines for a given platform as design options are added via purchas ed parts. As the complexity of a washer

5-31increases, the assembly costs also rise. The hi gher raw material costs fo r the 3 higher-efficiency dishwashers are largely at tributable to the stainl ess steel tub material. DOE also broke the material costs down by component subsystem, as shown in Figure 5.6.7. As expected, the cavity and door assemblie s are a m ajor cost component. However, the proliferation of design options steadily decreases the percentage cost contribution of doors and cavities as dishwasher platforms are pushed to higher and higher efficiency levels.

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0% /

i

0.58 0.64 0.68 0.72 0.78 0.93 1.11 EF Cycles/kWh% of Material Costs Final Boxing

Final Assembly

Rack Assemblies

Vent Blower Assembly

Front Door & Soap Rinse Dispenser Control System & Wir ng Harness Main Pump + Dist.

Drain Pump & Hoses

Main Cavity & Frame Figure 5.6.7 Dishwasher Material Cost Distributions Design Options For each unit subject to teardown, DOE noted al l aspects of construction as described in section 5.5.3.1, including design options and how they were implemented. DOE grouped the design options for residential di shwashers into 5 majo r categories as noted in Table 5.6.6: (1) insulation, (2) water system, (3) sp rayer design, (4) heating system, and (5) controls. In addition to the design options noted inTable 5.6.6, DOE noted platform design approaches, such as tub material and sump design, to help identify how platform changes allow manufacturers to reduce water requirements. The 2 platform families subject to teardown were repr esentative of units that span a wide range of efficiencies, but the sample size is sm all compared to the number of different washer platforms on the U.S. market today.

5-32Table 5.6.6 Design Options on Dishwasher Teardown Units Energy Factor Category Detail 0.58 0.64 0.68 0.72 0.78 0.93 1.11

Insulation by Cavity-Top and Sides Cavity-Back Yes No No No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Location Cavity-Bottom No No No No Yes Yes Yes Door No No No Yes Yes Yes Yes # of Main Pu mp Speeds 1 1 3 3 1 1, Triac 1, Triac Water Supply Tubing Loc. Exterior Exterior Exterior Exterior Interior Interior Interior Water Water Meter No No No No Yes Yes Yes System Multi-Spray / Diverter Valve Yes Yes Yes Yes No Yes Yes Float Switch Yes Yes Yes Yes No No No Sump Pressure Transducer No No No No No Yes Yes

Sprayers by Cavity Location and Type Bottom
Middle
Top Plastic 2­ Ar m Plastic 2-Arm Plastic Spray Nozzle Plastic 2­ Ar m Plastic 2­ Arm Plastic Spray Nozzle Plastic 3­ Ar m Plastic 2­ Arm Plastic 2-Arm Plastic 3-Arm Plastic 2-Arm Plastic 2-Arm Stainless 2-Arm Stainless 2-Arm
None Stainless 2-Arm Stainless 2-Arm
None Stainless 2-Arm Stainless 2-Arm Cutlery Tray Sprayer Heating Heater Type Tubular Tubular Tubular Tubular FlowThrough FlowThrough FlowThrough
Type Electronic ElectroMechanical Electronic Electronic Electronic Electronic Electronic Thermocouple No No Yes Yes Yes Yes Yes Controls Soil Sensor Hum idity Sensor No No No No Yes No Yes No No No No No Yes Yes
Vent Technology None None Active Door Vent FanAssisted Vent None FanAssisted Vent FanAssisted Vent Platform changes involve changi ng the overall sy stem architectur e, and typically result in reduced fill levels in the cavity. As s hown by Figure 5.6.4, water heating drives energy consumption. Thus, any effort to reduce wate r usage will reduce energy consumption. DOE

5-33also observed that platform design is the limiti ng factor in achieving a higher EF, meaning that a machine that uses even the most-efficient comp onents will not achieve a high EF if it has a lower-efficiency platform design. This obs ervation was confirmed during manufacturer interviews. Platform changes give a manuf acturer the opportunity to dram atically impact the wateruse requirements per fill. The smaller the sump and water distribution system volume, the less water a dishwasher needs. The higher-EF platform chosen for the testing and analysis was thus able to have more fills per cycle, yet consume less water per cycle than the less-efficient platform. However, reducing the sump volume and filter area comes with a risk of clogging via food particles and other debris. To address this risk, the highe r-EF platforms incorporate a sump pressure transducer that signals the controller whenever the fi ltration elements need to be backwashed. Whereas most dishwashers currently manufact ured in the U.S. rely on m acerators and partially bypass their filters during washing and rinsing operations, European dishwasher designs generally filter 100 percent of th e water that is about to ente r the sump pump and distribution system. By filtering the water with fine filters, European designs benefit from being able to use smaller arm nozzles and distribution pipes with out the potential for clogging them with food particles. Locating the pipes inside the wash cavity further reduces the length and hence the water volume required to fill these pipes. Electronic controllers combined with water meters allow a dishwasher to dose water very precisely, regardless of water suppl y pressure. If a dishwasher us es a sump pressure transducer to periodically back-flush clogged filters, the kno wledge of how m uch water the drain pump can move in a given amount of time also allows the c ontroller to precisely re fill the sump after each back-flush. Sensing the build-up of filter-clogging particles via the transducer also gives the controller an opportunity to vary its cleaning program according to various algorithms, which can provide similar soil-sensing functionality as a turbidity sensor. Within a platform, EF-reduction options include using multi-speed pumps that can operate at sp eeds optimized for each operating condition. Pumps may use higher pressure to help knock food particles off the dishware, for example, while reserving lower pump speeds for rinse cycles. Manufacturers also vary the number of spra yers and the num ber of arms per sprayer inside the cavity. The lower-efficiency unit with in the lower-efficiency platform had 2 sprayers, one of which was filled via a spray nozzle in the roof of the cavity. The higher-efficiency units within this platform incorporated sprayers with more arms, which were connected directly to the sump pump (as opposed to an open-air nozzle), and included an additional sprayer mounted to the roof of the cavity. However, the higher-e fficiency platform washers all had identical 2­ armed sprayers which were made of stainless steel as opposed to plastic. While the highestefficiency unit had a spray system under the roof of the cavity, its primary function was to direct spray to a cutlery rack located directly underneath it.

5-34Adding insulation or changing insulation materials in the cabinet cuts down on heat losses, thus requiring less energy consumpti on by the heater. DOE observed incremental changes in insulation location and type as a f unction of EF. Lower-efficiency units did not appear to have insulation at all. Higher-effici ency units added insulati on to the top, sides, and bottom of the cabinet and the door. Manufactur ers also used severa l different insulation materials: polypropylene blankets, open-cell polyur ethane foam, and rubberized asphalt with and without cotton or foam backing. The decision to adopt rubberized asphalt seems to be driven largely by the desire for sound-attenuation. As shown in Figure 5.6.4, water heating consumes the most energy during a wash cycle. Thus, in addition to reducing the amount of water required, ch anging heater design can reduce energy consumption. The heater design change that has the most effect on both water and machine energy consumption is switching from a tubular supplemental heater to a flow-through heater. The tubular supplemental heater design re quires a certain amount of water to be in the bottom of the tub. Flow-through designs heat the water as it flows from the sump to the sump pump and require much less water volume. Ho wever, tubular and flow-through heaters are not interchangeable technologies, so changing to a flow-through design requires a platform redesign. Drying strategy also influen ces EF. Drying can be achie ved via an exposed tubular supplem ental heating element or by heated rinse cy cles that can raise the dishware temperatures high enough to drive off moisture. The drying pr ocess may be aided by louvers in the door that are opened via wax motors. Optional fans can dr aw relatively cool, dry kitchen air into the dishwasher cavity through these openings. Some dishwasher designs feature “condensation” drying systems that use cooled cavity walls to re move latent heat inside the dishwasher cavity via condensation of the moisture. The cavity walls may be cooled via cold intake water (for washers that feature a cold-water connection, as is typical in Europe) or active-fan systems that draw relatively cooler kitchen ai r over the cavity walls. A humiditysensor can provide feedback to the controller as to when the contents of the cavity are dry. DOE also studied control components and strate gy as a m eans for increasing EF. Section 5.6.1.2 discussed various observed control strategies in the tested dishwashers, such as reducing the to tal number of cycles and adjusting the rela tive proportions of heated and unheated fills, but these strategies do not require different components and would be reflected as development expenditures, not incremental costs. However, during the teardowns DOE did observe specific control components that influence EF. Some units have soil sensors, which allow the machine to sense the wash water turbidity, infer the clean liness of the dishware, and possibly reduce the required number of cycles or ad just water levels and temperatur es accordingly. Also, all higherEF units feature thermocouples to measure te mperature for closed loop control. This thermocouple was observed to be located in eith er the door or inside the sump on the teardown units. Better water temperature control results in less energy used for water heating and more consistent wash performance.

5-35Cost-Efficiency Comparison Using the calculated production costs, DOE ge nerated a cost-efficiency curve to com pare with the data AHAM submitted. As mentioned prev iously, DOE is unaware of any baseline 0.46 EF units on the market with a similar platform as a more efficient unit. As a consequence, DOE did not tear down a 0.46 EF unit, and the baseline for DOE’s cost -efficiency curve is a 0.58 EF unit. For comparison to the AHAM data, DOE recalculated AHAM’s incremental costs based upon a baseline of 0.58 EF. The purpose of comparing DOE’s results to the AHAM-submitted data was to assess the reasonableness of AHAM’s data rather than attempt to duplicate them . DOE’s teardown sample size was very small and could not be expected to adequately capture the variability of all products in the marketplace. In addition to smal l sample size, DOE’s results were influenced by the choice of platforms. DOE’s teardown analys is and manufacturer interviews confirmed that upgrading components can only raise EF to a certainpoint for a given platform, and that overall system architecture limits EF. The platform which DOE reverse-engineered is among the most efficient available from large-volume manufacturer s (with an EF that sp ans the range of 0.58 to 0.72). Thus, it is reasonable to a ssume that starting from a lower-e fficiency platform, as did the units in AHAM’s dataset, will result in higher in cremental costs. If the reverse-engineering sample size had been larger, it is reasonable to assume that the range of incremental costs by efficiency level would have broadened. As a result, DOE feels that the AHAM submission is reasonable and reflective of the gamut of dishwash er platforms and their i nherent efficiencies on the market today. Figure 5.6.8 and Figure 5.6.9 compare AHAM’s and DOE’s cost-efficiency curves for dishwashers, norm alized for a baseline EF of 0.5 8. Figure 5.6.8 presents the curves across the range of EFs for which AHAM provided data (0.58 to 0.72 EF), while Figure 5.6.9 shows the same data across the complete range of EFs that DOE examined (0.58 to 1.11EF).

5-36$- $10 $20 $30 $40 $50 $60 $70 $80 $90[$]Incremental Production Cost

AHAM - Min AHAM - Avg AHAM - Max DOE

0.55 0.60 0. 65 0.70 0.75 EF Figure 5.6.8 Comparison of Dishwasher Incremental Costs for the Efficiency Levels in AHAM’s Submittal, 0.58 EF Baseline

$- $20 $40 $60 $80 $100 $120 $140 $160 $180 $200[$]Incremental Production Cost

AHAM - Min AHAM - Avg AHAM - Max DOE

0.55 0.65 0.75 0.85 0.95 1.05 1.15 EF Figure 5.6.9 Comparison of Dishwasher Incre mental C osts for EF = 0.58 to 1.11, 0.58 EF Baseline
Table 5.6.7 tabulates the incremental manuf acturing costs for residential standard dishwashers as a function of EF for all efficiency levels above the baseline of EF = 0.46. Since this data is not norm alized to a baseline of 0.58, the values will be higher than those presented in the previous figures by the cost increment between EF = 0.46 and 0.58 ($4.01). The cost increment at EF = 0.80 was obtained by interpolating the DOE cost curve between EF = 0.78 and 0.93. Table 5.6.7 contains the cost-efficiency datathat is used in subsequent analyses.

5-37Table 5.6.7 Incremental Manufacturing Costs for Residential Standard Dishwashers Product Class: Standard Energy Factor ( cycles/k Wh) Incremental Cost Baseline

- 0.58 $4.01 0.62 $7.38 0.65 $14.00 0.68 $30.35 0.72 $71.38 0.80 $133.29* 1.11 $184.67* * The LCC analysis utilized values for th ese levels that were normalized to a baseline EF = 0.58, so that each cost was $4.01 lower. The LCC analysis for the NOPR will correct these values.

5.6.1.4 Manufacturer Interviews
DOE conducted interviews with dishwasher m anufacturers to develop a better understanding of the technologies used to improve the energy efficiency of dishwashers. These interviews also helped DOE analyze the result s of the performance te sting and ask clarifying questions resulting from the dishwasher teardow ns. During interviews, manufacturers were asked what combinations of design options woul d be required to increase the energy efficiency of dishwashers in order to meet the efficiency levels proposed for dishwashers in section 5.4.2. The discussion helped DOE understand what pro posed design options have already been implemented and what additional design optio ns DOE should consider. Additionally, the interviews provided a better understanding of the design strategies underlying the AHAM dishwasher data submittal. The discussion below represents a consolidati on of the responses in order to avoid revealing design de tails, component costs, and othe r sensitive information for any given manufacturer. Background Information The dishwasher market is characterized by the dom inance of Energy Star-rated units. Many manufacturers offer a 90 percent or gr eater Energy Star-compliant product line. Therefore, efficient technologies dominate, and baseline dishwashers do not represent the majority of product offerings, although multip le manufacturers stressed that baseline dishwashers represent a significant po rtion of sales. In addition to the prevalence of Energy Star products, multiple dishwasher manufacturers speci alize in high-end units which have features such as stainless steel cavities and el ectronic controls as standard features.
0.46 EF Baseline Efficiency Level All manufacturers interviewed significantly exceed the baseline, m inimally-compliant energy efficiency level with most of their dishwasher models. Most baseline dishwashers use electromechanical controls instead of the electr onic controls prevalen t in higher-efficiency

5-38designs. Dishwashers lacking electronic controls cannot use soil sensors, thermocouples, water meters, pressure transducers, or other such feat ures to reduce their annua l energy use. Baselineefficiency dishwashers generally feature a plastic cavity instead of the more costly stainless steel designs found on higher-end dishwashers, althou gh this feature does not significantly impact energy (or water) performance. Manufacturers that offer low-end baseline dishwashers mentioned that within this market segment, c onsumers are more likely to accept fewer features and poorer wash performance than consum ers purchasing premium dishwashers. Baseline dishwashers are primarily associ ated with older design platform s which inherently make it difficult to improve energy (and water) efficiency beyond a certain point. These characteristics include a compactor-style drain and filter system, fewer spray arms, and a cavity and sump design that require s a relatively large quantity of water. Additionally, low-end baseline dishwashers may use multiple water changes to compensate for less-effective filtration.
0.58 EF Efficiency Level This efficiency level corresponds to the 2006 Energy Star level. Since m any retailers require Energy Star qualification for all the di shwashers they sell, manufacturers regard the Energy Star qualification level as the de-facto standard. In order to meet this proposed standard level, manufacturers reduce the fill level in the wash cavity, since hot water consumption represents a significant portion of dishwasher energy consumpti on. To reduce the fill level, multiple manufacturers reduce the volume of the dishwasher sump; reduce the internal wetted volume of the pump, hydraulic tubing, and spray arms; and design the spray-arm jets to clean more effectively with less water. The design f eatures described may be, but are not necessarily, associated with substitution technologies. The fe atures may also be integral to newer platform designs. Multiple manufacturers stated that electroni c controls are not necessary to meet the first proposed standard level. Multiple manufacturers also stated that soil sensors are not necessary to meet the first proposed standard level.
0.65 EF Efficiency Level This is the 2007 Energy Star level. Manufacturers expressed concern about their ability to m eet this standard level with their low-end product line based on older-generation design platforms. These older platforms can be altere d with some efficiency -increasing technologies, like optimized hydraulic systems, but significant ch anges to the filtration system or the sump, both integral parts of the platform, require a co stly redesign involving re search and development (R&D), tooling changes, and perhaps even a factory and equipment redesign. The costs associated with a redesign represent a step function rather than an incremental increase. To reach an EF of 0.65, manufacturers furthe r op timize the hydraulic system to reduce the water fill level required. Fo r example, one design strategy c onsists of alternately using the top and bottom spray arms, thus reducing the am ount of water in circulation and reducing the water required in each fill. Multiple manufacturers stated that while cost-sensitive consumers may accept some perform ance sacrifice to meet energy conservation standards, ma nufacturers were uncomfortable

5-39with the performance sacrifices that might be necessary to meet the 0.65 EF level without large cost increases. Drying energy, while associated with significant ener gy consumption, was not viewed as a major area of possible improvement. It was noted that while some European highefficiency dishwasher models use condensation drying, this is less effec tive in the U.S., since U.S. dishwashers are plumbed into the hot water line and therefore cannot m aintain a cold water reservoir to assist the condensi ng process. Sacrificing drying performance is not an option manufacturers are willing to contemplate even if this meant they could save energy on the heated drying portion of their wash cycle. Multiple manufacturers stated that consumers of higher- end dishwashers will not tolerate either reduced washer performance or longer wa shing cycles. Thus, reducing the overall energy consumption through longer drying cycles via activ e vents or by alternating spray patterns is limited by consumer acceptance. For higher-end dishwashers, manufacturers use multiple strategies to meet this proposed standard lev el without sacrificing performance. Several manufacturers stated that electronic controls are required to achieve this proposed standard level, since multiple energy-savings opportunities arise from c ontrol strategy changes. However, the 0.64 EF test unit that DOE tore down featured an electromechanical controller, suggesting that inherent ly-efficient platforms may be able to achieve a 0.65 EF while avoidi ng the need for an elec tronic controller. Soil sensors and/or sump pressure transducers are frequently used to control wash cycles at th is efficiency level. In order to mainta in wash performance, manufacturers use a more advanced water filtration system to reduce the numb er of water fills required per wash cycle and shrink the size of nozzles, distribution piping, sump volume, pump, and inline heater to minimize wetted volume. Filtration systems with small me sh sizes and minimized surface area carry some performance risk, however, as users can overload these systems more easily with excess soil left on dishware. Pressure transducers can help mitig ate that risk by sensing the build-up of soil and flushing the filter as needed. Multiple manufacturers stated that they cannot add electronic controls and soil sensors to low-end dishwa shers while maintaining their price point.
One manufacturer noted that as the mass of wa ter inside the dishwasher is m inimized, the amount of energy required to heatthe water inside the dishwasher above its inlet temperature is reduced. Thus, platforms that have minimized water requirements by design can heat the water to higher temperatures for the same amount of energy, improving wash performance.
Dishwashers with inline heater s heat the dishware during the final rinse cy cle to drive off moisture, while those using tubular heating elements can heat the di shware either via the rinse or by subsequent convective and radi ant drying inside the cavity. Either heat ing strategy can be aided by active-vent doors or blower s after the final rinse cycle.
1.0 EF Efficiency Level To meet this efficiency level, conserving water is essential, since hot water consum ption drives energy consumption. Multiple manufacturers stated that this standa rd level would be very difficult to meet, even with high-end dishwasher f eatures, without sacrificing wash performance.

5-40Manufacturers stated that elec tronic controls and soil sens ors would be required on all dishwashers to meet this proposed standard leve l. Some manufacturers commented that meeting this standard level would require a complex wash -cycle control decision tree, which increases the chance that the dishwasher controller will make a decision tree error, reducing dishwasher performance. Reducing water temperature would help meet this proposed standard level, but this option is only available in Europe , where dishwashers are plumbed into the cold water line. Several product utility concerns were expressed by manufacturers. Som e manufacturers stated that in order to decrease energy and wa ter consumption, cycle times would have to be increased, and that consumers have an incorr ect perception that longe r cycle times indicate greater energy consumption. One manufacturer commented that atthese high standard levels there is increased risk that some manufacturers would introdu ce a highly-efficient but poorlyperforming ‘normal’ wash cycle, since this is the cycle measured by the DOE test procedure. Consumers might then select a less-efficient wash cycle, negating some of the assumed energy savings. Since many higher-end dishwashers are potentiall y sim ple to re-program in the field, the service representatives have th e opportunity to modify a dish washer’s performance at the expense of energy consumption. For example, the dishwasher may be programmed to raise water temperatures to improve its soil-removal ch aracteristics. Such fi eld modifications would be hard to detect or prevent, and could negate much of the energy savings potential intended by the rulemaking. Intellectual Property During discussions with DOE, no dishwash er manufactures expressed significant concerns about intellectual prope rty and patent infringem ent at the first and second proposed standard levels. However, one manufacturer expressed concern that there might be some intellectual property obstacl es at the highest prop osed standard level.

5.6.2 Dehumidifiers The dehumidifier engineering analysis was pe rform ed by considering cost and efficiency information from multiple sources. AHAM provided incremental manufacturing costs for all but the highest efficiency levels for the 3 produc t classes for which data was submitted. DOE supplemented these data points by conducting its own detailed dehumidifier teardowns and estimating the manufacturing costs of observe d efficiency features. DOE also conducted interviews with dehumidifier manufacturers to obta in greater insight into design strategies and their associated costs to improve efficiency.

5.6.2.1 AHAM Data In support of the dehumidifier rulemaking, AHAM collected increm ental manufacturing cost data from its member companies and submitted them to DOE. The data submitted by AHAM represents the aggregate input from th e producers of over 95 percent of the covered

5-41dehumidifiers sold in the U.S. AHAM did notprovide any data for the product class of 75.00 pints/day or greater, due to in sufficient data to protect conf identiality. Table 5.6.8 describes overall unit shipments from 2003 to 2005 by capacityrange. Other than the product class of 25.00 pints/day or less, each dehumidifier product class experienced ship ment growth in that time period.
Table 5.6.8 AHAM Dehumidifier Shipments Data Submittal Year Shipments, Domestic + Impo rts (thousands of units) by Capacity (pints/day) ≤ 25.00 25.01-35.00 35.01-45.00 45.01-54.00 54.01-74.99 ≥ 75.00 2003 178 282 307 289 255

- 2004 169 389 395 343 376

- 2005 127 509 455 406 460

- Table 5.6.9 details the shipment-weighted av erage energy ef ficiency of dehumidifier shipments from 2003 to 2005 by capacity. All pr oduct classes other thanthat for 25.01 - 35.00 pints/day recorded EF improvements over that time period.
Table 5.6.9 AHAM Dehumidifier Shipment-Weight ed Effic iency Data Submittal Year Shipment-Weighted Average Energy Efficiency ( liter s/kWh ) by Capacity ( pints/day ) ≤ 25.00 25.01-35.00 35.01-45.00 45.01-54.00 54.01-74.99 ≥ 75.00 2003 1.25 1.26 1.35 1.48 1.56

- 2004 1.27 1.27 1.38 1.56 1.56

- 2005 1.28 1.26 1.42 1.57 1.57

- In addition to total shipment and shipme nt-weig hted average energy efficiency for dehumidifiers, AHAM also submitted 2 tables of da ta disclosing market share by efficiency level and year. Table 5.6.10 discloses market shar e from 2003 to 2005 for dehumidifiers in the 35.01- 45 pints/day product class, while Table 5.6.11 details the same type of data for the 54.01 to 74.99 pints/day product class.
Table 5.6.10 AHAM Dehumidifier Market Sha re Data Submittal for 35.01 to 45.00 Pints/Day Efficiency Bin ( liters /kWh ) Market Share by Year (percent) 2003 2004 2005 < 1.30 1.30-1.34: Baseline = 1.30 70% 54% 27% 1.35-1.39: Mid Point = 1.35 35% 1.40-1.44: E PACT 2005=1.40 4% 1.45-1.49: S uggested =1.45 26% 38% 1.50-1.59: S uggested = 1.50 8% 38% > 1.59: Max Available = 1.74 < 1.30

5-42Table 5.6.11 AHAM Dehumidifier Market Share Data Submittal for 54.01 to 74.99 Pints/Day Efficiency Bin ( liters /kWh ) Market Share by Year (percent) 2003 2004 2005 < 1.50 3% 1.50-1.54: Baseline = 1.50 9% 31% 1.55-1.59: Mid Point = 1.55 75% 1.60-1.64: E PACT 2005=1.60 76% 57% 1.65-1.69: S uggested =1.65 22% 15% 12% 1.70-1.79: S uggested = 1.70 > 1.79: Max Available = 1.80 < 1.50 3%
AHAM also submitted incremental cost data by efficiency level for 3 dehumidifier capacity ranges as can be seen in Table 5.6.12, T able 5.6.13, and Table 5.6.14. The incremental cost at each level is the cost to upgrade a baseline- efficiency unit to that efficiency level. The average incremental costs shown in these tables are shipment-weighted averages. The cost information provided by AHAM does not acc ount for the scheduled phase-out of hydrochlorofluorocarbon (HCFC) re frigerants due to the U.S. E nvironmental Protection Agency (EPA) regulations. R-22 is an HCFC refriger ant commonly used in dehumidifiers that will no longer be allowable for use in products manufactured starting in the year 2010. The first 2 product classes proposed by EPACT 2005, 25.00 pints/day or less and 25.01- 35.00 pints/day, were combined by AHAM because so m e manufacturers did not have shipments in the 25.01-35.00 pints/day category. To preven t disclosure of sens itive information, AHAM did not provide data for the EPACT 2 005 product classes 45.01–54.00 pints/day and 75.00 pints/day or greater be cause fewer than 3 manufacturers pr oduce units in these categories. Also in Table 5.6.12 through Table 5. 6.14, AHAM estim ates the number of dehumidifiers shipped, by product class, that w ould be impacted by standards at each level.

5-43Table 5.6.12 AHAM Dehumidifier Incremental Cost Data Submittal for 0–35.00 Pints/Day Product Class 0–35.00 pints/day Efficiency Level 1 2 3 4 5 Energy Factor (EF) L/kWh 1.25 1.30 1.35 1.40 1.45 Incremental Costs, $ Per Unit, Shipment-W eighted Average 3.12 4.92 10.41 18.8 25.61 Minimum 0 0 8.03 15.2 21.9 Maximum 7 10 20 29.54 34.79 One-Time Product Conversion Expenses, Million $, T otal for All Manufacturers R&D 0.05 0.15 2.25 4.75 7.15 Marketing 0.1 0.15 1.7 4.75 6 Conversion Capital Expenditure Assum ptions, Million $, Total for All Manufacturers Building 0.025 5.05 5.1 5.15 5.2 Tooling and Equipm ent 0.3 1.85 3.9 6.95 9 Total Shipments, Thousands, subject to retooling, conversion, etc. as a function of minimum EF level revis ion 525 625 745 745 745

Table 5.6.13 AHAM Dehumidifier Incremental Cost Data Submittal for 35.01–45.00 Pints/D ay Product Class 35.01–45.00 pints/day Efficiency Level 1 2 3 4 5 Energy Factor (EF) L/kWh 1.35 1.40 1.45 1.50 1.74 Incremental Costs, $ Per Unit, Shipment-W eighted Average 6.11 14.47 22.68 32.84 N/A Minimum 0 0 0 22.5 N/A Maximum 10 35.38 46.36 65.34 N/A One-Time Product Conversion Expenses, Million $, T otal for All Manufacturers R&D 1.7 3.43 3.6 4.6 N/A Marketing 0.6 2.65 2.7 3.75 N/A Conversion Capital Expenditure Assum ptions, Million $, Total for All Manufacturers Building 0.025 0.05 0.1 5.15 N/A Tooling and Equipm ent 2.45 4.5 4.55 8.65 N/A Total Shipments, Thousands, subject to retooling, conversion, etc. as a function of minimum EF level revis ion 548 548 548 648 N/A

5-44Table 5.6.14 AHAM Dehumidifier Incremental Cost Data Submittal for 54.01–74.99 Pints/Day Product Class 54.01–74.99 pints/day Efficiency Level 1 2 3 4 5 Energy Factor (EF) L/kWh 1.55 1.60 1.65 1.70 1.80 Incremental Costs, $ Per Unit, Shipment-W eighted Average Minim um Maximum 4.18 0 13 8 0 16 12.36 0 19 23.18 9 63 33.94 29 87 One-Time Product R&D 0.1 0.23 0.4 6.9 11.8 Conversion Expenses, Million $, Total for All Marketing 0.1 0.15 0.2 6.35 11 Manufacturers Conversion Capital Building 0.025 0.05 0.1 6.15 6.2 Expenditure Assumptions, Million $, T otal for All Manufacturers Tooling and Equipm ent 0.65 0.7 0.75 8.1 12 Total Shipments, Thousands, subject to retooling, conversion, etc. as a function of 450 450 450 612 612 minimum EF level revision Figure 5.6.10 plots the average incremental cost as a function of EF for the AHAM da ta. Note that the 3 curves have similar slopes.

0 5 10 15 20 25 30 35 40Incremental Cost$

1.00 1.10 1.20 1.30 1.40 1.50 1.60 1.70 1.80 1.90 EF L/kWh i 0 - 35.00 pints/day 35.01 - 45.00 p nts/day 54.01 - 74.99 pints/day Figure 5.6.10 AHAM Dehumidifier Cost-Efficiency Curves

5-455.6.2.2 Manufacturer Interviews
DOE conducted interviews with dehumidi fier manufacturers to develop a better understanding of the technologies used to im prove dehumidifier energy efficiency. During these interviews, DOE asked manufactur ers what groupings of design options would be required to increase the energy efficiency in order to meet the efficiency levels proposed in section 5.4.2 for dehumidifiers. The discussions helped DOE under stand which design options have already been implemented and which additional design optio ns DOE should consider. Additionally, the interviews provided DOE with a better understanding of the design strategies underlying the AHAM dehumidifier data submittal. The discussi on below represents a consolidation of the responses. Components That Influence Energy Efficiency Manufacturers identified the components that influence energ y efficiency, as measured by ANSI/AHAM Standard DH-1-2003, as fans and fan motors, heat exchanger coils, and compressors. Most manufacturers use either shad ed-pole or permanent split-capacitor (PSC) fan motors. Some manufacturers have considered electronically-commutated motors (ECM), which use less energy than shaded-pole or PSC fan mo tors, but have not pursued implementation of them because of cost, availability, and con cerns about service and reliability issues. Manufacturers also noted that the control syst em, either electronic or mechanical, does not influence energy efficiency under DOE test conditions. Manufacturers currently use either rotaryor reciprocating co mpressors in their dehumidifiers. The efficiency range of compre ssors available today varies by product class. Manufactures cited the energy efficiency ratio (E ER) range for smaller-capacity product classes as 8 to 9 and 8.5 to 10.5 for larger-capacity product classes. Ma nufacturers have not implemented variable-speed compressors because of the higher cost and because the static conditions of the DOE test procedure cannot capture their benefits. Other compressor technologies, such as scroll or in ertia compressors, are not availabl e in capacities appropriate for dehumidifiers. Strategies to Increase Energy Efficiency Manufacturers consider material cost, sh ipping cost, and weight as key design param eters. Most manufacturers use only 1 or 2 product platforms for all of their product offerings. Manufacturers cited 2 strategies to in crease energy efficiency: (1) heat exchanger coil improvements or (2) compressor improvements. Fan motors influence energy efficiency, but most manufacturers are already using the most efficient products available, with the exception of ECM. Coil improvements increase the amount of water collected per unit of energy consumed, but manufacturers stated that efficiency gains do not vary linearly with surface area growth. For example, an evaporator coil can only be grow n so much for a given capacity and compressor before its coil surface wi ll start to just cool the air rather than condense moisture out of it. Compressor improvements direct ly reduce energy usage.

5-46Manufacturers cited compressors as the primar y strategy to increase energy efficiency. Higher-capacity compressors usually offer higher e fficiencies than lower-capacity units. As a result, a manufacturer may adapt a high-effici ency, high-capacity compressor to work in a higher-efficiency, lower-capacity dehumidifier. However, comp ressors are usually the most expensive dehumidifier component and any incr eases in compressor price will have a large impact on overall unit cost. Some manufacturers are currentlyus ing the most efficient compressors on the market and are therefore focusing on heat exchanger coil impr ovements to increase energy efficiency. Other manufacturers may focus on coil improvements because of the high costs for compressor improvements. For these manufacturers, further increases in efficiency are only possible via increasing the coil area or complete system re designs. Complete system redesigns incur expenses for R&D, tooling expenditures, and build ing expenditures. Larger coils require more material, and manufacturers cited this as a concer n, given high material pr ices. Also, as coils grow, the chassis and compressor ca pacity must grow as well. If the unit size increases past a certain point, fewer units can fit in a shipping co ntainer, which results inhigher per-unit shipping costs. Also, as the chassis grows, weight in creases, requiring more substantial packaging. Comparing costs required to in crease efficiency a cross produ ct classes, the higher the capacity, the higher the incremental costs due to the costs associated with the larger coil and compressor.

5.6.2.3 Product Teardowns DOE tore down dehumidifiers to identify design o ptions, and their associated costs, that can be used to raise EF. The dehumidifier teardown analysis performed for this engineering analysis included 14 teardown units in 4 product classes. DOE selected products such that within a product class, the models selected have the same capacity but different efficiencies. Figure 5.6.11 illustrates that the selected product s cover the range of efficiency levels as provided by AHAM. Figure 5.6.11 also shows the efficiency range of products currently offered. Note that in the 35.01-45.00 pints/day product class, th e range of product offerings extends beyond the range of the AHAM data, an d DOE tore down a product near the high end of the commercially-available range. DOE does not e xplicitly identify the cap acities of the units it tore down, because doing so could expose sensiti ve information about individual manufacturers’ products. AHAM did not provide data in the 45.01-54.00 pints/day product class to avoid disclosure of sensitive information, because fewer than 3 manufacturers produce units in these categories. Therefore, cost efficiency curv es were only generated for the following product classes: 0 to 35.00 pints/day, 35.01 to 45.00 pints/day, and 54.01 to 74.99 pints/day. However, DOE conducted teardowns in the 45.01-54.00 pi nts/day product class for completeness.

5-47

### 2.2

2

1.8

1.6

1.4

1.2

1EF, L/kWh 

### Teardown Point Range o f products Efficiency Range of AHAM data available

35.00 pints/da y 35.01-45.00 45.01-54.00 54.01-74.99 or less pints/day pints/day pints/day
Figure 5.6.11 Efficiency Range of Dehumidifier Teardowns After the dehumidifier teardowns, DOE grouped costs into the categor ies shown below. Figure 5.6.12 shows the breakdown of m aterial costs for a typical baseline dehumidifier, as generated from DOE’s BOM. Note that the re frigeration system, heat exchangers, and fan components (components that largely determine en ergy consumption) make up 61 percent of the material costs. Figure 5.6.13 shows the various costs comprising a typical baseline dehumidifier’s full production cost. Depending on the manufacturer and the scale they are operating at, the depreciation costs may vary from those shown in Figure 5.6.13, which assumes a “green field” site.

5-48Water Bucket Final

2%
Chassis

17% 1%

Controls

8% 3%

7% Condenser 9% Boxing Assembly

16%

Fan Motor and Blade Wiring Harnesses

Evaporator Refrigeration Circuit

37%

Figure 5.6.12 Baseline Dehumidifier Material Cost Distribution

Space Tooling Depreciation Indirect

4% 2%

Depreciation Cost 1% Cost 5% 3%

Raw

Purchased Parts Assembly Labor Cost Fabrication Labor Cost Equipment Depreciation Cost 0.1% Process Costs

Material

Costs 32%

Material Costs 53%

Figure 5.6.13 Baseline Dehumidifier Full Production Cost Distribution

5-49Cost-Efficiency Curves To generate cost-efficiency curves, DOE fo cused on design options that influence EF. After the screening analysis, DOE retain ed the design options listed in Table 5.6.15.
Table 5.6.15 Retained Design Opt ions for Dehumidifiers 1. Improved fan and fan-motor efficiency 2. Improved compressor efficiency 3. Improved evaporator performance 4. Improved condenser performance Manufacturer interviews confirmed the validity of these design options, which can be classified into 2 categories: fan and fan-motor improvements and refrigeration component improvements. For fan and fan-motor improvements, the units DOE tore down contained only shaded pole and PSC m otors. Manufacturer interviews c onfirmed that only these types of motors are currently incorporated in dehumidifiers. Some manufacturers have inve stigated upgrading to ECM designs, but have not performed these upgrades due to concerns over cost, availability, and reliability. For the refrigeration components, manufacturers cited 2 strategies to increase EF. The first approach is to use a higher-efficiency com p ressor. As the compressor efficiency increases, as measured by the compressor’s EER, the EF increases because less energy is required to remove water from the ambient air. Various type s of losses can be reduced in order to increase compressor efficiency. For example, higher-effici ency motors reduce motor losses and resulting heat gain to the refrigerant. Improved compresso r bearings can reduce mechanical losses, thus increasing mechanical efficienc y. Reducing gas leakage from hi gh-pressure to low-pressure regions through improved sealing techniques or tighter tolerances improves volumetric efficiency. Improved designs can also reduce pre ssure-drop losses in the compressor, as well as losses due to re-expansion of refr igerant or over- or under-compression. Available compressor efficiencies vary based upon com pressor capacity range and technology. DOE’s product teardowns found differ ent compressor technologies in different product classes. For the 0-35.00 pints/day product class, hermetic reciprocating compressors using R-134a refrigerant were prevalent. Un its in the 35.01-45.00 pints/day product class used hermetic reciprocating or rotary compressors with R-22. Finally, the teardown units in the 54.01-74.99 pints/day product class all used rotary compressors with R-22. To assess the impact of compressor EER on system EF, DOE assumed that the correlation between dehumidifier EF and compre ssor EER is approximately one-to-one. Given the lack of commercially-available software p ackages to simulate dehumidifiers, DOE verified this assumption by examining the DOE engin eering analysis for residential room airconditioners. 4 The design of residential room air-conditione rs is similar to that of dehumidifiers, but with a larger capacity. For the residential room air-conditioner engineering analysis, DOE

5-50used the Oak Ridge National Laboratory (ORNL) Heat Pump Design Model to assess the impact of compressor efficiency increases. Using this model, DOE verified thatthe correlation between compressor EER and dehumidifier EF is ind eed approximately one-to-one, meaning a one percent increase in compressor effi ciency roughly translates to a one percent increase in system efficiency. To estimate the cost of compressor effici ency increases, DOE assum ed a one-to-two relationship, meaning that a 1 percent increase in compressor efficiency requires a 2 percent increase in cost. Manufacturer interviews and discussions with compressor manufacturers verified this assumption. Tabl e 5.6.16 shows DOE’s estimates for baseline compressor cost and efficiency. Table 5.6.17 lists ot her key estimates for the compressor portion of the engineering analysis. DOE determined, based on produc t teardowns, that manufacturers must use a reciprocating compressor to re ach an EF of 1.5 in the 35.01- 45.00 pints/day product class.
Table 5.6.16 Assumed Dehumidifier Product-Class- Specific Cost and Efficiency Paramete rs

Product Class Compressor Technology Refrigerant Baseline Compresso r Cost, $ Baseline Compresso r Capacity, Btu d /h Baseline Compresso r EER, Btu/Wh HeatExchanger Baseline Cost, $ 0–35.00 pints/day Hermetic Reciprocating R-134a $40 2800 7.60 $10 35.01– 45.00 pints/day Rotary & Reciprocating R-22 $25 Rotary, $45 Recip. 4500 8.60 $12
54.01– 74.99 Rotary R-22 $30 6500 8.80 $15 pints/day

d Btu = British thermal units

5-51Table 5.6.17 Estimated Dehumidifier Cost and Efficiency Parameters for All Product Classes Assumption Value Source % Increase in compressor cost required to increase EE R by 1% 2% Interviews with dehumidifier and
com pressor manufacturers % Increase in heat exch anger cost required to increase EF by 1% 1.71% Product teardowns % Increase in compressor EER required to increase EF by 1% 1.05% Analysis based on room airconditioner engineering analysis. % Increase in chassis and boxing cost per % increase in h eat exchanger cost 1% DOE estimate
Average chassis and boxing cost $21.00 Teardown analysis, manufacturer inte rviews % of selling price fo r overseas shipping 5% DOE estimate, verified by
m anufacturer interviews % of selling price for ground transportation 5% DOE estimate, verified by
m anufacturer interviews Manufacturers cited increasing heat exchanger area as a secondary option to raise EF via refrigeration com ponents. In the units DOE to re down, DOE noted variou s options to increase heat exchanger surface area, including adding extr a rows, increasing fin pitch, and increasing the overall heat exchanger face area. DOE developed general correlations for estim atin g cost impacts of heat exchanger improvements, fully recognizing that the relationship betweenheat exchanger design and dehumidifier performance is not linear. From product teardowns, DOE estimated that a 1 percent increase in EF will incr ease heat exchanger costs by 1.7 percent, due to the higher materials costs required to achieve a larger su rface area. From the pr oduct teardown analysis, DOE estimated typical baseline heat exchanger costs for each product class, as shown in Table 5.6.16. Manufacturers noted that an increase inheat exchanger coil surface requires a corresponding increase in compressor capacity. DOE assumed a 1 per cent increase in heat exchanger size requires a corre sponding 1 percent increase incompressor capacity, where the baseline compressor capacities, also shown in Table 5.6.16, were developed from product teardowns. As heat exchanger surface area grows, the chassis and packaging m ust grow as well. DOE estimates that a 1 percent increase in heat ex changer cost results in a 1 percent increase in chassis and packaging costs, because the heat exchanger size is increased. From product teardowns, DOE calculated an average baseline chassis and boxing cost of $21.00 for all product classes. DOE assumed a constant chassis and packaging cost across all product classes based upon manufacturers’ comments that many manufacturers use the sa me platform for all product classes.

5-52According to manufacturers, a key dehumidif ier design parameter is shipping cost. Dehumidifiers are sized to maxi mize the number of units that ca n fit in a standard shipping container. A possible consequen ce of increasing heat exchanger si ze – and subsequently chassis and package size – is a decrease in the number of units per container and therefore an increase in shipping costs per unit. Base d upon manufacturer interviews and DOE’s experience, shipping costs and freight costs are estimated as 5 percen t of the selling price. This percentage has traditionally been estimated as 3 percent to 4 perc ent, but recent increases in fuel costs have increased transportation costs. To account for domestic versus overseas manufacturing, DOE used market data to develop location-weighted shipping costs. DOE thenscaled shipping costs based upon incremental increases in selling price. For non-manufacturing costs ( i.e., building, tooling/equipmen t, R&D, and marketing), DOE used the costs submitted by AHAM with a 10-year depreciation period for building costs and a 3-year depreciation period for the other costs. Figure 5.6.14 through Figure 5.6.19 compare DOE’s cost estimates to the AHAM-submitted data. These figures demonstrate reasonable agreement between the DOE and AHAM cost-efficiency curves in all product classes.Incremental Production Costs, $ 16
14
12
10

8
6
4
2
0 1.2 1.25 1.3 1.35 1.4 1.45 1.5 EF, L/kWh

g e DOE AHAM Avera AHAM Mi AHAM M
Figure 5.6.14 Comparison of Dehumidifier Incremental Production Costs: 0-35.00 Pints/Day

5-530 5 10 15 20 25 30 35Incremental Production Costs, $

1.3 1.35 1.4 1.45 1.5 1.55 1.6 1.65 1.7 EF, L/kWh DOE AHAM Average
Figure 5.6.15 Comparison of Incremental Dehumidifier Production Costs: 35.01-45.00 Pints/Day

0 2 4 6 8 10 12 14 16 18Incremental Production Costs, $

1.5 1.55 1.6 1.65 1.7 1.75 1.8 1.85 EF, L/kWh DOE AHAM Average
Figure 5.6.16 Comparison of Incremental Dehumidifier Production Costs: 54.01-74.99 Pints/Day

5-540 5 10 15 20 25 30 35 40Incremental Production Costs, $

1.2 1.25 1.3 1.35 1.4 1.45 1.5 EF, L/kWh
DOE AHAM Average AHAM Min AHAM Max

Figure 5.6.17 Comparison of Total Incremental Dehumidifier Costs: 0-35.00 Pints/Day

0 10 20 30 40 50 60 70Incremental Production Costs, $

1.3 1.35 1.4 1.45 1.5 1.55 1.6 1.65 1.7 EF, L/kWh DOE AHAM Average AHAM Min AHAM Max
Figure 5.6.18 Comparison of Total Incremental Dehumidifier Costs: 35.01-45.00 Pints/Day

5-550 10 20 30 40 50 60 70 80 90 100Incremental Production Costs, $

1.5 1.55 1.6 1.65 1.7 1.75 1.8 1.85 EF, L/kWh
DOE g e AHAM Avera AHAM - Min AHAM - Max
Figure 5.6.19 Comparison of Total Incremental Dehumidifier Costs: 54.01-74.99 Pints/Day
Table 5.6.18 tabulates DOE’s incrementa l production cost against the AHAM data subm ittal. The AHAM data is shown disaggreg ated into shipment-w eighted incremental production costs as well as non-ma nufacturing cost components. This comparison validates the AHAM average total incremental manufacturing co sts, which are used to define the costefficiency relationship for the LCC analysis . In the single instance where AHAM did not provide data (EF = 1.74 for the 35.01 to 45.01 pints/ day product class), th e total incremental manufacturing cost is extrapolated from a linear f it of the AHAM data at lower efficiency levels.

5-56Table 5.6.18 Incremental Costs to Increase Dehumidifier EF

Product Class, pints/day EF, L/kWh DOE Incrementa l Production Cost, $ per unit AHAM Incrementa lShipmentWeighted Production Cost, $ per unit Incremental Depreciated Cost, $ per unit Incremental R&D and Marketing Costs, $ per unit Total Incrementa l Manufacturing Cost, $ per unit 1.25 2.56 2.83 0.20 0.10 3.12 1.3 5.35 2.97 1.79 0.16 4.92 0-35.00 1.35 8.12 6.21 2.43 1.77 10.41 1.4 11.04 10.75 3.80 4.25 18.80 1.45 14.00 15.00 4.72 5.88 25.61 1.35 2.61 3.22 1.49 1.40 6.11
35.01- 45.00 1.4 5.28 8.03 2.75 3.70 14.47 1.45 7.75 16.06 2.79 3.83 22.68 1.5 22.41 23.30 5.24 4.30 32.84 1.74 N/A N/A N/A N/A 74.72* 1.55 2.37 3.54 0.49 0.15 4.18
54.01- 74.99 1.6 4.77 7.19 0.53 0.28 8.00 1.65 7.32 11.34 0.58 0.44 12.36 1.7 10.23 10.55 5.42 7.22 23.18 1.8 15.40 13.97 7.55 12.42 33.94

* Extrapolated from the A HAM cost-e fficiency curve.

5.6.3 Cooking Products

5.6.3.1 AHAM Data Conventional Cooking Products
In concurrence with various stakeho lders, DOE determined that the efficiency characteristics of gas and electric cooktops and ovens from the 1996 TSD were still valid. Therefore, the efficiency data provided in th e 1996 TSD were presumed to still be valid. Furthermore, DOE believes that the cost of the design options investigated in the 1996 TSD are also valid once adjusted to reflect changes in th e producer price index (PPI). The data from the 1996 TSD are detailed in section 5.6.3.2.
Microwave Ovens
In contrast to conventional cooking products, m icrowave ovens were presumed to have incorporated improved technology since 1996. Th erefore, AHAM provided data on microwave oven efficiency and microwave standby power fo r a sample of microwave ovens currently

5-57available in the U.S. market. 5 Microwave oven efficiency was tested according to DOE’s test procedure, which utilizes International Electrotechnica l Commission (IEC) 705-1988 and Amendment 2-1993, Methods for measuring the pe rformance of microwave ovens for household and similar purposes . Standby power was tested in accordance with IEC 62301-2005, Household electrical appliances – Measurem ent of standby power

. The microwave oven test procedure speci fied in IEC 705-1998 and Am endment 2-1993 calls for heating a glass contai ner containing one liter of wate r at full power until the water temperature is raised by a specified amount. The starting temperature of the water T 1 in degrees Celsius ( ° C) is given as:
T 1 = T 0 – (10 ± 1 ° C) where,

T 0 = the ambient temperature, specified as 20 ± 2 ° C The water is heated by the operation of the microwave oven until the final water temperature T 2 in ° C is:
T 2 = T 0 ± 1 ° C The microwave power output P in watts (W) is then calculated from: P = (4.187 m w (T 2 – T 1 ) + 0.88 m c (T 2 – T 0 ))/t where,

m m w = the mass of the water in grams (g)

c = the mass of the container in g t = the heating time in seconds (s) The time to heat the water load, power input P IN in W, and the total energy consumption E M in watt-hours (Wh) of the microwave oven during the test period are also recorded. This test is repeated 3 times, unless the power output valu e resulting from the second test is within 1.5 percent of the value obtained from the first test. The 2 or 3 values of P are averaged for further calculations. Cooking efficiency Eff MO is then obtained using:
Eff MO = P/P IN For the remainder of the calculations, the te st procedure specified in 10 CFR 430 Subpart B Appendix I is utilized. Note th at in the following calculations, all temperatures are expressed

5-58in degrees Fahrenheit. The mi crowave oven test energy output E T in Wh (kilo-joules (kJ)) e is calculated as:
E T = C P M W (T 2 – T 1 ) + C C M C (T 2 – T 0 ))/K e where,
M W = the measured mass of the test water load in pounds (lb), (g) M C = the measured mass of the test container before filling with test water load in lb (g) T 1 = the initial test water load temperature in ° F ( ° C) T 2 = the final test water load temperature in ° F ( ° C) T 0 = the measured ambient room temperature in ° F ( ° C) C C = 0.210 Btu/lb- ° F (0.88 kJ/kilogram (kg)- ° C), specific heat of the test container C P = 1.0 Btu/lb- ° F (4.187 kJ/kg- ° C), specific heat of water K e = 3,412 Btu/kWh (3,600 kJ/kWh), conversion factor of kWh to Btu. The 2 or 3 values for test energy output are averaged and the m icrowave oven annual energy consumption E MO is calculated in kWh per year from:
E MO = (E M x O M )/E T where,

E M = the test energy consumption in Wh (kJ) O M = 79.8 kWh (287,280 kJ) per year, the microw ave oven annual useful cooking-energy output Finally, the microwave oven energy factor R MO (equivalent to EF) is calculated from:
RMO = O M /E MO EF is the metric for microwave ovens on which the DOE efficiency standard is based, while AHAM provided test data in terms of cooking efficiency in their data submittal for this rulemaking. From the above equations, it can be observed that there ar e several contributing factors that can lead to significant test-to-test variations in measured EF and efficiency. First, the tolerances on the temperature specifications are s ubstantial relative to the absolute values. The range of allowable temperatures for ambient, starting, and final temperatures can lead to acceptable test load temperature rises ranging from 4 to 16 ° C. Since the heating time is on the order of only a few tens of seconds, power a nd energy output calculations are difficult to measure consistently test-to-test. In addition, the efficiency calc ulation assumes that input power is constant for the duration of the test, which may not be the case. These factors make the existing test procedure diffi cult to conduct with accuracyand repeatability.

e Note that in order to correctly utilize the equation as specified in the test procedure to produce either watt-hours for standard units or kJ for metric units, additional factors must be applied. For standard units, E T must be multiplied by 1000. For metric units, E T must be divided by 3600.

5-59In the recent testing for this analysis, although AHAM only tested 21 units from 9 manufacturers, the units were se lected to represent a broad spectrum of models available in the marketplace with varying cap acities and features. Figure 5.6.20 through Figure 5.6.22 display the AHAM microwave oven efficiency and standby power data.

50% 55% 60% 65%Efficiency

600 700 800 900 1000 1100 1200 1300 1400 Rated Output Power (W) Figure 5.6.20 AHAM Microwave Oven Efficiency versus Rated Output Power 6 Figure 5.6.20 illustrates a small variation in e fficiency across all rated output powers, approximately ±3.5 absolute percentage points from the average efficiency. There is a lack of a correlation between microwave oven rated output power and microwave oven efficiency. Figure 5.6.21 illustrates the relationship between micr o wave oven efficiency and microwave oven volume. Similarly, there is no correlation be tween microwave oven efficiency and volume. Figure 5.6.20 and Figure 5.6.21 confirm DOE’s approach of creating a single product class for microwave ovens irrespective of rated output power or cavity volum e, and demonstrate that there is no basis to specify an efficiency standard th at is a function of eith er rated output power or cavity volume.

5-6050% 55% 60% 65%Efficiency

0.0 0.5 1.0 1.5 2.0 2.5 Microwave Oven Volume (ft^3) Figure 5.6.21 AHAM Microwave Oven Efficiency versus Oven Volume 7 Microwave oven standby power consumption is a function primarily of the digital clock display, with more complex graphical displays drawing more power. According to AHAM, the 3 major types of displays used in microwave ovens are light emitting diodes (LEDs), vacuum fluorescent display (VFD), and liquid crystal display (LCD). Typically, LCD without backlighting uses the least amount of energy while VFD uses the most. Energy consumed by LCD would depend on whether back-lighting is present or not, and if presen t, the number of LEDs used for back-lighting. For LEDs, the number of segments, color and operating temperature has an impact on energy consumption. The size of th e display (number of digits and icons) also affects the energy consumed by the display. For VFD, the size of the display is a major factor in energy consumption. 8 Standby power consumption may al so be affected by the electronic controls required for features such as cooking sensors. Figure 5.6.22 displays AHAM-measured mi crowave oven standby-power-consum ption data as a function of rated outputpower. Unlike efficiency, these data show a wide range of standby power usage, but there is no correlation between standby power consumption and output power. Standby power consumption ranged from 1.5 to 5.8 W, with 9 of the 21 microwave ovens meeting the FEMP recommendation of 2.0 W or less. The average standby power measured was 2.9 W. AHAM did not provide any information with which DOE could correlate standby power with other features such as cooking sensors.

5-617.0

6.0Standby Power Consumption (W)

5.0

4.0

3.0

2.0

1.0

0.0 600 700 800 900 1000 1100 1200 1300 1400 Rated Output Power (W) Figure 5.6.22 AHAM Microwave Oven Standby Power Consumption 9Table 5.6.19 compares the AHAM-measured microwave oven standby-powerconsumption data with data fromother studies that have examin ed standby power in the U.S. and Canada. It can be seen thataverage standby power has remain ed relatively constant since 1997 even though minimum and maximum leve ls have varied by a greater amount.
Table 5.6.19 Microw ave Oven Standby Power Comparison

Source Microwave Oven Standby Power Consumption Min, W Average, W Max, W Std Dev, W # Samples AHAM 2006 10 1.5 2.9 5.8 0.8 21 CBEEDAC 2006 11 0.4 1.9 3.3 0.8 19 CREEDAC 2001 (New Stock) 12 0.8 3.8 12.6

- 4 CREEDAC 2001 (Existing Stock) 13 0.0 2.1 7.3

- 64 LBNL 1999 14 0.0 2.9 6.0

- 42 Florida Solar Energy Center 1998 15

- 3.0

- - 25 LBNL 1997 16

- 3.1

- - - Although the DOE test procedure does not m easure standby power, it is recognized that annual energy consum ption can be significantly affected by standby pow er in real-world usage. For example, a 1-watt increase in standby power corresponds to an increase of 8.76 kWh in annual energy consumption. The microwave oven test procedure assumes an annual useful cooking energy output (O M ) of 79.8 kWh. For a baseline microwave oven that operates at 55.7

5-62percent efficiency (E T /E M ), annual energy consumption (E MO ) not including standby power would be:
E MO = O M /(E T /E M ) = 143.3 kWh Therefore each watt of standby power included in the annual energy consumption metric would increase it by 6 percent for a baseline m icrowave oven. Since the highest measured standby power was 5.8 W, the increment of 3.8 W over the FEMP recommended level of 2.0 W would represent a 23 percent increase in annua l energy consumption for a baseline microwave oven. Since the annual energy consumption of a mo re efficient unit will be lower, the standby power will have an even greater relative contribution for high-efficiency microwave ovens.

5.6.3.2 Review of Past TSDs After consulting with AHAM and various stak eholders, DOE determ ined that the design options for cooking products other than microwav es have not changed significantly since the 1996 TSD analysis. Therefore, DOE decided to update the 1996 TSD analysis using the PPI to scale incremental manufacturing cost data for ga s and electric cooktops, and gas and electric standard and self-cleaning ovens. For gas cooktops and ovens, the PPI for gas household cooking equipment was utilized. Similarly, th e PPI for electric household cooking equipment was used for electric cooktops and ovens. Wher e additional design options have been identified that weren’t in the 1996 TSD, DOE is soliciting inputs from stakehol ders to determine efficiency and incremental cost information. This cost-effici ency data will be included in the TSD for the NOPR. Comparison of current microwave oven effici ency data with analogous data from the 1996 TSD showed that the range of efficiency le vels analyzed in the 1996 TSD are still valid, although AHAM indicated in comments provided along with its data submittal for this rulemaking that certain design options used to achieve those levels have already been optimized. 17 But as noted in section 5.4.2, the range of efficiency levels from the 1996 TSD is still representative of the perf ormance of current microwave ove n models. Therefore, for the purposes of this analysis, the same efficiency le vels are used. As with the conventional cooking products, the incremental manufacturing cost data from the 1996 TSD was scaled by the PPI forelectric household cooking equipment, which includes microwave ovens, to obtain the costefficiency relationship. DOE is seeking further information from stakeholders regarding specific design options and cost increments to include in the TSD for the NOPR. Cooktop Test Procedure DOE’s cooktop test procedure is based on meas uring the am ount of energy required to raise an aluminum block test load from room te mperature to a specified temperature above room temperature at full input heating rate, then operating the burner or element a fixed time longer at a reduced input heating rate. The size of the test block depends on the burner or element size, and the test is repeated for each burner or element. Annual energy consumption is calculated from the average cooking efficiency of the burners or elem ents. Cooktops are rated using EF, which is the

5-63ratio of the annual useful cooking-energy output of the cooktop to its total annual energy consumption. The annual energy consumption include s the energy input during the time the load is being heated, plus the en ergy consumed by any standing pilot during standby hours for a gas cooktop. Therefore, design options that raise the cooking efficien cy of a gas or electric cooktop and/or reduce the energy consumption of a pilo t on a gas cooktop can decrease the total annual energy consumption and therefore improve EF. Gas Cooktops Table 5.6.20 describes the design options and design option combinati ons that result in increased E F of gas cooktops. The design options and efficiency levels analyzed are those presented in the 1996 engineering analysis, withseveral design options (reflective surfaces and thermostatically-controlled burne rs) eliminated in this analys is as described in section 5.4.2.
Table 5.6.20 Gas Cookto p Manufacturing Cost and Efficiency Increments
Level Efficiency Level Description Cooking Efficiency EF Delta Manufacturer Cost from Baseline, 2006 dollars Baseline Baseline 39.9% 0.156

- 1 Baseline + Electronic Ignition 39.9% 0.399 $12.06 2 1 + Sealed Burners 41.8% 0.420 $32.06 Notes: Baseline: Cooktop cooking efficiency = 39.9%, four conventional 9,000 Btu/hr burners, two 117 Btu/hr standing pilot lights (1) Electronic Ignition: Standing pilot lights eliminated, cooking efficiency increase = 0.0% (2) Sealed Burners: Cooking efficiencyi ncrease = 4.8% (relative percent ) Electric Coil Cooktops Table 5.6.21 describes the design option that results in incr eased cooking efficiency of electric open (coil) cooktops. The design optio n and efficiency levels analyzed are those presented in the 1996 engineering analysis, wi th one design option (r eflective surfaces) eliminated in this analysis as described in section 5.4.2.

5-64Table 5.6.21 Electric Coil Cooktop Manufacturing Cost and Efficiency Increments
Level Efficiency Level Description Cooking Efficiency EF Delta Manufacturer Cost from Baseline, 2006 dollars Baseline Baseline 73.7% 0.737

- 1 Baseline + Improved Contact Conductance 76.9% 0.769 $2.28
Notes: Baseline: Cooktop cooking efficiency = 73.7%, two 6-inch 1,250 W and two 8-inch 2,100 W elements (1) Improved Contact Conductance: Cooking e fficiency increase = 4.3% (relative percent) Electric Smooth Cooktops Table 5.6.22 describes the design options that result in increased cooking efficiency of electric sm ooth cooktops. The design options an d efficiency levels anal yzed are those presented in the 1996 engineering analysis, wi th one design option (induction element) eliminated in this analysis as described in section 5.4.2. Another design option (radiant element) discussed in the 1996 engineering analysis was notincluded in this analysis because it exhibited a lower efficiency than the baseline cooktop.
Table 5.6.22 Electric Smooth Cooktop Manufacturing Cos t and Efficiency Increments
Level Efficiency Level Description Cooking Efficiency EF Delta Manufacturer Cost from Baseline, 2006 dollars Baseline Baseline 74.2% 0.742

- 1 Baseline + Halogen Lamp Elem ent 75.3% 0.753 $89.09
Notes: Baseline: Cooktop cooking efficiency = 74.2%, two 6-inch 1,500 W and two 8-inch 2,000 W solid disk elements (1) Halogen Element: Cooking efficiency increase = 1.5% (relative percent), two small 1,200 W and two large 1, 800 W circular lamps Conventional Oven Test Procedure DOE’s oven test procedure is based on meas uring the am ount of energy required to raise an aluminum block test load from room temp erature to a specified temperature above room temperature. Ovens are rated using EF, which is the ratio of the annual useful cooking-energy output of the oven (energy conveyed to the item being heated) to its total annual energy consumption. The annual energy consumption incl udes the energy input during the time the load is being heated plus the energy consumed by ot her features such as a clock, standing pilot, electronic ignition system, and/or self-cleaning cycles. Theref ore, design options that raise the cooking efficiency of the oven and/or reduce the energy consumption of features not related to heating food can decrease the total annual energy consumpti on and therefore improve EF.

5-65Gas Ovens Table 5.6.23 describes the design options and design option combinati ons that result in increased E F of gas standard ovens. The design op tions and efficiency levels analyzed are those presented in the 1996 engineering analysis, with one design option (o ven separator) eliminated in this analysis as described in section 5.4.2. Fo r the NOPR, DOE intends to analyze additional design options which would re sult in a lowering of the en ergy consumption of non-cooking features ( e.g. standby power).
Table 5.6.23 Gas Standard Oven Manufacturin g Cost and Efficiency Increments
Level Efficiency Level Description Cooking Efficiency EF Delta Manufacturer Cost from Baseline, 2006 dollars Baseline Baseline 5.9% 0.0298

- 1 Baseline + Electric Glo-bar Ignition 5.8% 0.0536 $12.06 2 1 + Improved Insulation 6.1% 0.0566 $15.64 3 2 + Improved Door Seals 6.2% 0.0572 $16.72 4 3 + Forced Convection 6.5% 0.0593 $38.86 5 4 + Reduced Vent Rate 6.5% 0.0596 $40.48 6 5+ Reduced Conduction Losses 6.6% 0.0600 $44.11 1a Baseline + Electronic Spark Ignition 5.8% 0.0583 $15.00
Notes: Baseline: Cooking efficiency = 5.92%, 2” of 1.09 lb/cubic foot insulation, standing pilot light ignition = 175 Btu/hr (1) Baseline + Electric Glo-Bar Ignition: Cooking efficiency decrease = 0.152 (absolute percentage points), added el ectricity consumption = 176 Wh (2) 1 + Improved Insulation: Cooking effici ency inc rease = 4.9% (relative percent) (3) 2 + Improved Door Seals: Cooking effici ency inc rease = 1.0% (relative percent) (4) 3 + Forced Convection: Cooking e fficie ncy increase = 4.8% (relative pe rcent), added electricity consumption = 15 watt-hours (5) 4 + Reduced Vent Rate: Cooking effici e ncy increase = 0.5% (relative percent) (6) 5 + Reduced Conduction Losses: Cooking efficiency increase = 0.05 (absolute percentage points) (1 a) Baseline + Electronic Spark Ignition: Cooking efficiency decrease = 0.09 (absolute percentage points), added electricity consumption = 0.0 Wh. Standard levels 1 and 1a correspond to designs that are utilized for the same purpose--eliminate the need for a standing pilot--but the technolo gies for each design are different. Standard level 1 is a hot surfa ce ig nition device while standard level 1a is a spark ignition device Table 5.6.24 describes the design options and design option combinati ons that result in increased EF of gas self-clean ovens. The desi gn options and efficiency levels analyzed are those presented in the 1996 engineering anal ysis, with one design option (oven separator) eliminated in this analysis as described in section 5.4.2. For the NOPR, DOE intends to analyze additional design options which would result ina lowering of the energy consumption of noncooking features ( e.g. standby power).

5-66Table 5.6.24 Gas Self-Cleaning Oven Manufacturing Cost and Efficiency Increments
Level Efficiency Level Description Cooking Efficiency EF Delta Manufacturer Cost from Baseline, 2006 dollars Baseline Baseline 7.1% 0.0540

- 1 Baseline + Forced Convection 8.8% 0.0625 $11.01 2 1 + Reduced Conduction Losses 8.8% 0.0627 $15.38 3 2 + Improved Door Seals 8.9% 0.0632 $16.60 Notes: Baseline: Cooking efficiency = 7.13%, clock power = 3.6 W, 2” of 1.90lb/cubic foot insulation, electronic ignition = 176 Wh, self-cleaning energy consumption = 43,158 Btu (1) Baseline + Forced Convection: C ooking efficiency increase = 23% (rel ative percent), added electricity consumption (during cooking and cleaning cycles) = 15 Wh (2) 1 + Reduced Conduction Losses: Cooking efficiency increase = 0.05 (absolute percentage points) (3) 2 + Improved Door Seals: Cooking effici ency inc rease = 1.0% (relative percent) Electric Ovens Table 5.6.25 describes the design options and design option combinati ons that result in increased E F of electric standard ovens. The de sign options and efficiency levels analyzed are those presented in the 1996 engi neering analysis, with several design options (bi-radiant oven and oven separator) eliminated in this analysis as described in section 5.4.2. For the NOPR, DOE intends to analyze additional design options which would result in a lowering of the energy consumption of non-cooking features ( e.g. standby power).

5-67Table 5.6.25 Electric Standard Oven Manufacturing Cost and Efficiency Increments
Level Efficiency Level Description Cooking Efficiency EF Delta Manufacturer Cost from Baseline, 2006 dollars Baseline Baseline 12.2% 0.1066

- 1 Baseline + Reduced Vent Rate 12.8% 0.1113 $1.63 2 1 + Improved Insulation 13.4% 0.1163 $4.84 3 2 + Improved Door Seals 13.7% 0.1181 $8.53 4 3 + Forced Convection 14.0% 0.1206 $48.14 5 4 + Reduced Conduction Losses 14.1% 0.1209 $51.69 Notes: Baseline: Cooking efficiency = 12.15%, clock power = 3.9 W, 2” of 1.09 lb/cubic foot insulation (1) Baseline + Reduced Vent Rate: Cooking efficiency increase = 0.62% (absolute percentage points) (2) 1 + Improved Insulation: Cooking efficiency increase = 0.52% (relative percent) (3) 2 + Improved Door Seals: Cooking efficiency increase = 0.24 (absolute percentage points) (4) 3 + Forced Convection: Cooking e fficie ncy increase = 0.33 (absolute pe rcentage points), added electricity consumption = 15 Wh (5) 4 + Reduced Conduction Losses: Cooking efficiency increase = 0.05 (absolute percentage points) Table 5.6.26 describes the design options and design option combinati ons that result in increased EF of electric self-cleaning ovens. Th e design options and efficiency levels analyzed are those presented in the 1996 e ngineering analysis, with severa l design options (bi-radiant oven and oven separator) eliminated in this analysis as described in section 5.4.2. For the NOPR, DOE intends to analyze additional design options which would result in a lowering of the energy consumption of non-cooking features ( e.g. standby power).
Table 5.6.26 Electric Self-Cleaning Oven Manufacturi ng C ost and Efficiency Increments
Level Efficiency Level Description Cooking Efficiency EF Delta Manufacturer Cost from Baseline, 2006 dollars Baseline Baseline 13.8% 0.1099

- 1 Baseline + Reduced Conduction Losses 13.8% 0.1102 $4.37 2 1 + Forced Convection 14.2% 0.1123 $43.98 Notes: Baseline: Cooking efficiency = 13.79%, clock power = 3.8 W, 2” of 1.09 lb/cubic foot insulation, self-cleaning energy consumption = 5,286 Wh (1) Baseline + Reduced Conduction Losses: Cooking effici ency inc rease = 0.05 (absolute percentage points) (2) 1 + Forced Convection: Cooking e fficie ncy increase = 0.33 (absolute pe rcentage points), added electricity consumption = 15 Wh

5-68Conventional Oven Energy Use versus Volume The oven cost-efficiency relati onships detailed above are pr edicated upon baseline ovens with a cavity volum e of 3.9 cubic feet. It is well documented, however, that efficiency scales with oven cavity volume. This variation betw een efficiency, and thus energy factor, and oven volume results from the fact that larger ovens have higher thermal masses and larger vent rates than smaller ovens. Since the test procedure for establishing EF is a transient test with a fixed test load, the increased energy c onsumption due to the increased mass of larger units yields a lower EF. The 1980 DOE engineering an alysis for residential appliances 18 established a relationship between oven volume and EF from data compiled by the National Bureau of Standards (which was renamed to National Institu te of Standards and Technology). Using these data, linear equations were deri ved for both electric and gas ovens. No distinction was found to exist between standard and self-cleaning ovens for ei ther gas or electric ovens. Intercepts for a particular baseline model or oven design were ch osen so that the equations pass through the desired EF corresponding to a pa rticular volume. Values from the 1996 TSD for the slopes and intercepts for gas and electric ovens are li sted in Table 5.6.27. The 1996 TSD did not analyze data at every efficiency level, and higher e fficiency levels are not included in Table 5.6.27 because certain design options have been elimin ated in the current analysis. DOE believes the slopes and intercepts of these equations from the 1996 TSD to still be valid.
Table 5.6.27 Slopes and Intercepts for Oven Energy Factor versus Cavity Volume Relationship Energy Efficiency Electric Gas Slope = -0.0157 Slope = -0.0073 Level Standard Self-Clean Standard Self-Clean Baseline

- 0.1632 0.0865 0.0865 1 0.1752

- 0.0895

- 2 0.1802

- - - 3 0.1822

- 0.0935

- Note: EF = (Slope x Volume) + Intercept where Volume is expressed in cubic feet.
Microwave Ovens Table 5.6.28 describes the design options and design option combinati ons that result in increased E F of microwave ovens. The design opti ons and efficiency levels analyzed are those presented in the 1996 engineering analysis, with incremental manu facturing costs scaled by the PPI for electric household cooking equipment. For the NOPR, DOE seeks input from stakeholders on the approach of analyzing a dditional design options which would result in a lowering of the energy consump tion of non-cooking features ( e.g. standby power), even though the test procedure currently does not account for such usage in EF. It should be noted that DOE is considering the a ddition of standby power measurement to the test procedure.

5-69Table 5.6.28 Microwave Oven Manufacturing Co st and Efficiency Increments
Level Efficiency Level Description Cooking Efficiency EF Delta Manufacturer Cost from Baseline, 2006 dollars Baseline Baseline 55.7% 0.557

- 1 Baseline + More Efficient Power Supply 58.6% 0.586 $8.68 2 1 + More Efficient Fan 58.8% 0.588 $17.95 3 2 + More Efficient Magnetron 59.7% 0.597 $32.53 4 3 + Reflective Surfaces 60.2% 0.602 $51.11 Notes: Baseline: Cooking efficiency = 55.7% (1) Efficient Power Source: Cooking efficiencyi ncrease = 2.9 (absolute percentage points) (2) Efficient Fan: Cooking efficiency increase = 0.23 (absolute percentage points) (3) Efficient Magnetron: Cooking efficiency i ncrease = 0.90 (absolute percentage points ) (4) Reflective Surface: Cooki ng e fficiency increase = 0.50 (absolute percentage points)

5.6.4 Commercial Clothes Washers

5.6.4.1 AHAM Data In support of DOE in the commercial clothes washer rulemaking, AHAM collected increm ental manufacturing cost data from its member compan ies in October of 2006. Table 5.6.29 compiles unit shipment and energy-efficiency data for commercial clothes washers from 2002 to 2005.
Table 5.6.29 AHAM Co mmercial Clothes Washer Shipments and Shipment-Weighted MEF and WF Data Submittal Year Total Shipments MEF ( ft

3 /kWh) WF (Gallons / ft 3 ) 2002 175,187 1.30 11.77 2003 190,720 1.33 11.42 2004 178,382 1.33 11.33 2005 177,394 1.41 10.91 Table 5.6.30 reproduces AHAM's 2006 data subm ittal for the averag e water and power consumption agitator vertical-axi s commercial clothes washers that meet the baseline 1.26 MEF energy efficiency level. Since January 2007, how ever, clothes washers manufactured at this baseline 1.26 MEF must meet a lower WF (9.5) than the one listed in the AHAM data submittal.

5-70Table 5.6.30 AHAM Baseline MEF Commercial Clothes Washer Average Energy and Water Use Data Submittal Attributes of Average 1.26 ME F Washer Power Consumption per Wash Cycle (kWh )

MEF ( ft

3 /kWh) WF (Gallons

/ ft 3 ) Washer Capacity (ft 3 ) Water Use (Gallons/Cy cle) Standby Pow er Consumption (W) Hot Water Machine Po wer Dryer Po wer
1.26 11.1 3.1 34.3 * 0.87 0.18 1.38 DOE requested incremental cost data for effici ency levels discussed in sections 5.4.1 and 5.4.2. Additional data submitted by AHAM, shown in Table 5.6.31, repr esents aggregated input from the producers of commercial clothes washer s sold in the U.S. The shipment-weighted incremental cost at each level is the cost to upgrade the baseline efficiency machine (1.26 MEF/9.5 WF) to that efficiency le vel. Many efficiency levels contain no cost data since AHAM requires a minimum of 3 data points per efficiency level before submitting shipment-weighted results.
Table 5.6.31 AHAM Commercial C lothes Washer Incremental Cost Data Submittal Efficiency Level 1 2 3 4 5 6 Exploratory MEF Levels – Comm ercial Clothes Washers 1.42 1.6 1.72 1.8 2 2.2 Exploratory WF Levels – Comm ercial Clothes Washers 9.5 8.5 8.0 7.5 5.5 5.1 Incremental Costs ($ Per Unit) – Shipm ent-Weighted $ 74.73 * * * $ 316.35 * * Insufficient data reported Table 5.6.31 displays the AHAM commercial clothes washer cost submittal. For 2 proposed efficiency levels, the MEF, WF, and in cremental manufacturing cost are noted. There were insufficient data at other e fficiency levels to report costs. Figure 5.6.23 plots the efficiency levels for which AHAM submitted incr emental manufacturing cost data, i.e. the baseline efficiency level, efficiency level 1, and efficiency level 5.

5-71350

300Incremental Mfg. Cost ($/unit) 250

200

150

100

50

0 liBase ne EL: 9.5WF EL 1: 9.5WF EL 5: 5.5WF

1.2 1.4 1.6 1.8 2 2.2 MEF EL = Efficiency Level
Figure 5.6.23 AHAM Commercial Clothes Washer Incremental Cost Data Submittal

Manufacturers stated that the baseline e fficiency level (1.26 MEF/9.5 WF) and the efficiency level 1 (1.42 MEF/9.5W F) are attainable with agitator ve rtical-axis clothes washers. Manufacturers also stated that efficiency level 5 (2.00 MEF/5.5 WF) would require the use of horizontal-axis clothes washers. Therefore, the data in Tabl e 5.6.31 is subject to a platform change from agitator vertical-axi s to horizontal-axis clothes wash ers between efficiency level 1 and efficiency level 5. Give n the persistent manufacturing cost difference between these platforms, an incremental cost “curve” with mo re intermediate data points would thus likely exhibit a steep step change wherever that platform change occurs.

5.6.4.2 Manufacturer Interviews
DOE conducted interviews withm anufacturers of commercial clothes washers to develop a better understanding of the technologies used to improve the energy and water efficiency of these products. During the interviews, manuf acturers were asked what design options or combination of design options would be required to increase the energy and water efficiency. The discussion helped DOE understand what de sign options manufacturers have already implemented and what additional design optio ns DOE should consider. Additionally, the interviews provided a better understanding of the design strategies underlying the AHAM commercial clothes washer data submittal. The discussion below represents a consolidation of the manufacturers’ responses.

5-72Background Information DOE learned that manufacturers may produce 3 di stinct residential or commercial clothes washer platform s, each with inherent cost and efficiency attributes:

 agitator vertical-axis clothes washers;

 non-agitator vertical-axi s clothes washers; and

 horizontal-axis clothes washers. Agitator vertical-axis clothes washers immerse clothes in a v ertically -oriented tub filled with a detergent and water solution. During the wa sh portion of the cycle, the agitator moves the suspended clothing through the solution. Agitator vertical-axis clothes washers fully immerse clothing during the rinse portion of the cycle as well. Since such designs immerse the clothing completely, their water consumption is inhere ntly the highest among th e 3 types of washer platforms. Additionally, since ho t water heating represents the majority of the total energy used during the cycle, the total energy consumption of th is washer type per cycle is usually also the highest among the 3 clothe s washer platforms.
Some residential vertical-axis clothes washer mo dels com bine the low cost of the vertical-axis platform with energy- and water-saving design op tions such as automatic fill control or spray rinse. However, the vertical-axis models with automatic fill control currently on the U.S. market utilize proprietary technology and are residential clothes washer s. The spray-rinse option has seen limited implementation in the commercia l clothes washer market due to perceived performance concerns and hence consumer resistance. Non-agitator vertical-axis clothes washers repl a ce the agitator with an impeller, nutating plate, or other alternative manipulator. Non-agit ator vertical-axis clothe s washers do not need to suspend clothing completely in water to ensure ad equate cleaning. This allows these washers to reduce tub fill levels, increasing water efficiency, and when hot water is used, energy efficiency. The design changes and additiona l components necessary to manufacture non-agitator verticalaxis clothes washers raise their price well above that for traditi onal agitator vertical-axis clothes washers. Non-agitator vertical -axis clothes washers have yet to be released as commercial models, and manufacturers expre ssed reservations about the viab ility of doing so due to the heavy-duty demands of commercial laundry appl ications. Two non-agitator vertical-axis residential clothes washers were introduced in the past at significant capital development expense by manufacturers, but were subsequently discontinue d by those manufacturers.
Horizontal-axis clothes washer s use a horizontally-rotating w ashtub with no agitator. As the tub rotates, the clothing is repeatedly lif ted and dropped into a sm all pool of water and detergent solution at the bottom of the wash tub. Clothing is then rinsedin a similar manner. Since horizontal-axis washers do not need to su spend clothes in water to properly wash them, this technology platform can offer the highest wate r efficiencies on the market. When hot water wash cycles are used, the smaller amount of hot water required gives horizontal-axis clothes washers better energy efficiency than agitator vert ical-axis clothes washers. However, a typical

5-73horizontal-axis washer platform is significantly more expensive to manufacture than an agitator vertical-axis model. Design Options Manufacturers can use a variety of appro aches to improve the energy and water efficiency of commercial clothes washers. Impr ovements to energy and water efficiency are not necessarily correlated, since some technologies may improve only energy efficiency or water efficiency, but not both. These technologies can be applied to different washer platforms with varying impact on MEF and WF. Wh en manufacturers reach the effi ciency limits of a particular platform, they must switch to an inherently more efficient platform to increase efficiency further. During the interviews, DOE requested input fr om m anufacturers regard ing the particular design options or strategies theyare using to achieve improved energy and water efficiency. The following general approaches were discussed:

• Reduced wash temperatures – manufacturer s red uce water temperatures during the hot portions of the wash cycle. This increases th e energy efficiency of the clothes washer since hot water consumption represents the majority of overall energy consumption. Reduced wash temperatures can be used on all washer platforms. Multiple manufacturers stated that reducing wash temperature negatively impacts wash performance.

• Reduced fill levels – manufact urers can reduce the volume of water used in some washer designs for a given load size. This reduction increases the water efficiency of the washer and, when hot water is used, the energy effici ency of the washer. Multiple manufacturers stated that any further reduction in wate r fill level negatively impacts wash cleaning performance in agitator ve rtical-axis clothes washers f

.
• Additional temperature settings – by adding additional cooler wash temperature settings,
m anufacturers take advantage of the averagi ng function in the DOE clothes washer test procedure to achieve calculated energy consumption reductions. These design changes will only result in real-wor ld energy savings if consumers choose the lower wash temperature cycles. Additional temperature settings can be implemented on all washer platforms.

• Additional load-size settings – by incorporating additional us er-s electable, lower washer load-size, and hence fill-level , settings, manufacturers use th e averaging function in the DOE clothes washer test procedure to achieve calculated water co nsumption reduction and, when hot water is used, energy consumption reduction. These design changes will only result in real-world water and energy savings if cons umers choose lower fill-level settings while operating the clothes washer.

• Electronic controls – manufacturer s stated that electron ic contro ls would let them add more water temperatures, water fill levels, and othe r wash options to further utilize averaging

f In vertical-axis agitator models, the clothes must “turn-over” in the tub by being pulled down into the tub by the oscillating agitator and then pushed back up along the oute r wall of the tub. Turn-over is responsible for evenlydistributed cleaning of the garments. Reduced fill level in the tub reduces turn-over in agitator vertical-axis clothes washers, and subsequently reduces cleaning performance.

5-74functions in the DOE test procedure , although this additional functionality comes at a significant cost premium over standard mechanical timers . Electronic controls can also be programmed to reset between user s, preventing settings from “carrying over.” Electronic controls can be implemented on all washer platforms.

• Water-temperature feedback – manufacturers can use tem perature sensors and electronic controllers to increase energy efficiency by controlling water temperatures precisely. Currently, many washers use “open-loop” c ontrols with no temperature feedback. Manufacturers add a safety margin in the form of extra hot water for warm-water fill cycles to ensure that minimum temperatures are met. Washers with open-l oop controls operating under favorable conditions can thus create hotter wash water than desired or necessary when the temperature of the hot water supply is adequate or high. By adding a temperature sensor to provide water-temperature feedback, clothes washers with adaptive controllers can use less hot water in order to just reach the correct wa sh temperature, saving energy. As MEFs are pushed to higher levels, manufacturers may need to use more feedback as safety margins are decreased or eliminated. Water-temperature f eedback can be used on all washer platforms equipped with electronic controls.

• Spray rinsing – replacing immersion rinsing wi th a spray rinse reduces water consumption, along with energy consumption when hot rinse cycles are used. Spray rinsing has been previously used on all washer platform s but is currently not implemented by any manufacturer in commercial clothes washers due to performance concerns and the heavyduty demands of commercial laundry applications. A major route operator, WEB Service Company Inc. (WEB) of Redondo Beach, CA, testified during a California Energy Commission (CEC) hearing in 2001 that, in the late 1990s, it deployed a spray-rinse design option on a vertical-axis commercial clothes washer, but was forced to recall all of the washers 19 . At the same hearing, Whirlpool Corporation (Whirlpool) stated that it manufactured the spray rinse commercial clothes washers referred to by WEB a nd that “the spray rinse itself, was inadequate for the commercial application to get these clothes fully clean, get sand out of them and get the suds out of them.” 20

• Partial-drain rinsing – which partially drains the wash tub prio r to th e rinse cycle and then reuses some of the wash water for the rinse cycle. This reduces water consumption and, when hot water is used for the rinse cycle, en ergy consumption. Partial-drain rinsing can be used on all washer platforms. While this design option is currently offered in a vertical-axis commercial clothes washer from a major commercial clothes washer manufacturer, it is not universally accepted by all equipment owners and users due to the user and owner perception of inadequate rinsing.

• Higher spin-cycle speeds – washers with highe r spin-cyc le speeds can extract more water from clothing using mechanical energy, reducin g the remaining moisture content (RMC). The DOE test procedure for co mmercial clothes washers cred its a decrease in RMC as an increase in MEF. Higher spin-cycle speeds can be used on all washer platforms, but the mechanical suspension components of the clothe s washer may need to be modified by the manufacturer at significant e xpense to accept the increased cyc lical fatigue stress induced by the higher load forces. Additionally, one manuf acturer expressed concern that the structure in which the washer is installed may need to be upgraded as well.

5-75DOE requested that manufacturers comment on which platforms and design options they would use to produce washers cap able of meeting the MEF and WF requirements of several standard levels:
1.26 MEF/9.5 WF Baseline Efficiency Level
Baseline commercial clothes washers must m eet existing washer energy and water conservation standards. All manufacturers were able to meet this standard level by modifying their agitator vertical-axis clothes washer platforms. Modifications to meet MEF requirements included reducing water temperatures during wash and rinse cycles or incorporating additional user-selectable cooler wash temperature settings to the clothes washer’s control panel. In order to meet this WF requirement, m anufacturers reduced water usage during the rinse cycle by redesigning their wash baskets, implementing lower rinse-water fill levels, or using partial-drain rinse technology. The incremen tal cost of allowing multiple fill levels is relatively minor, since additional pressure sw itches (beyond the one already found in each washer) are inexpensive to implement. Base d on these statements, DOE estimates that the incremental cost of upgrading ag itator vertical-axis clothes washers to meet the 1.26 MEF/9.5 WF was less than 10 percent of the baseline wa sher cost. A physical teardown of units compliant with current standards and older 11.0 WF units would give DOE further insight into the details of the conversion costs. Currently, most consumers in commercial laundry settings receive no m onetary benefit from selecting colder wash cycles or lower wate r levels. Only newer, electronic control systems using card readers can offer this functionality, and then only if the route operator enables it. Thus, manufacturers are not sure if consumers using commercial clothes washers will select lower wash temperatures or lower water settings , since most consumers pay the same amount of money per load and are unlikely to select wash op tions that they believe could result in decreased washer performance. Additionally, commercial clothes washers are frequently overloaded or loaded with heavily-soiled clothing, which implies that consumers are even less likely to select reduced wash temperatures and fill levels.
1.42 MEF/9.5 WF Efficiency Level
DOE learned that this standard level re presented an increm ental improvement for manufacturers. Since this standard level only requires an incr ease in MEF, with no increase in WF over the baseline, manufacturers stated that they were familiar with the design changes necessary to produce washers at this standard level. It is believ ed that this level could be met with additional modifications to agitator vertical-axis clothes washer designs, even with the continued use of electrom echanical controls. All manufacturers planned on using further redu ctions in water tem perature to meet the MEF requirements of this standa rd level. This may include incorporating additional userselectable wash temperature settings. However, manufacturers cautioned that further reductions

5-76in wash water temperatures would lead to decr eases in wash performance. The magnitude of these concerns varied by manufacturer. Manufacturers did express some additional con cerns about the steps necessary to m eet this standard level. One concer n is that electromechanical contro ls do not reset between washes. While this may not represent a problem for a resi dential clothes washer with a single user, usercontrollable settings could “carry over” between users of commercial clothes washers, causing confusion and decreased wash performance. On e manufacturer also expressed concern that water temperature reductions necessary to meet this standard level would encourage biofilm growth inside the washer.
1.60 MEF/8.5 WF Efficiency Level
DOE learned that this standard level woul d likely represent a significant change in commercial clothes washer design. Since this standard level incorporates an increase in both MEF and WF, not all m anufacturers are familiar with the design change s necessary to produce washers that meet this standard level, and how these design changes will affect washer performance and reliability. DOE also learned that the washing practices of commercial clothes washer users render
som e energy and water efficiency-enhancing desi gn options impractical. Customers frequently overload washers at laundromats and multifamily hous ing laundry facilities in order to minimize their washing costs. These customers are more concerned with lowering their overall washing cost than with cleaning performance. Wa sher overloading significantly decreases the performance of efficiency-enhancing design options like spray rinsing and partial-drain rinsing. Additionally, some customers go to laundromats to avoid washing heavily-soiled loads in their own residential clothes washers. These customers would be significantly affected by design options that cause performance decreases. Cu stomers have already complained that spray rinsing cannot adequately remove sand from heavily-soiled clothing loads, for example. As wash water temperatures drop to m eet the 1.60 MEF requirem ents, manufacturers have the option of lengthening the wash cycle to improve wash performance. However, any increase in cycle length is not in the economic in terest of route operators , as longer cycle lengths can result in fewer washer cycles per day from a given clothes washer. Manufacturers could also offer user-selectable water fill levels at this effici ency level in order to take advantage of the WF credit that such a switch entails. Accord ing to manufacturers, th e savings from giving commercial clothes washer end-users such a choice would be illusory since users have no economic incentive to lower the wa ter level, since they typicallypay the same amount per wash, regardless of fill level. Some manufacturers have made agitator vertical -axis clothes washers with spray rinse for the commercial market in the past. However, as discussed above, ma nufacturers have noted consumer resistance to commercial clothes washers with a spray rinse, as such systems may not result in adequate rinse performance, particularly for heavily soiled items.

5-77Multiple commercial clothes washer manufacturers stated that this efficiency level was beyond the realistic reach of agitator vertical-axis clothes washers for use in the commercial laundry market. According to th ese manufacturers, such wash er platforms would not yield adequate wash and rinse performance in commercial settings. As a result, most manufacturers of comm ercial clothes washers stated that this efficiency level could only be met with non-ag itator vertical-axis washers or horizontal-axis washers. Such a platform transition would let manufacturers re duce washer fill levels, since neither of these platforms require clothing to be completely immersed and suspended in water. Electronic controls would let manufacturers improve washer performance, as well as add additional water fill options, water temperature options, and wa sh cycle options. Based upon the DOE test procedure, additional lower water fill-level options increase WF, and additional lower water temperature options increase MEF. Manufacturers also stated that highe r spin-cycle speeds could increase MEF by reducing the RMC. This standard level thus presents problems for the laundrom ats and route operators who own and operate commercial clothes washers. Existing inventories of replacement parts for vertical-axis washers would start becoming obsolet e as manufacturers transition to incompatible platforms, potentially representing significant stranded capital. Furthermore, replacement parts for high-efficiency washers can be more expensiv e than replacement part s for agitator verticalaxis clothes washers. For example, replacing a failed control circuit board costs significantly more than replacing a failed electromechanical controller. One manufacturer noted that multiple non-agitator vertical-axis clothes washer platforms have been w ithdrawn from the residential market. Since none of the remaining non-agitator vertical-axis residential clothes washer manufacturers expressed an interest in converting these washer platforms for use in the commercial laun dry business, the most likely result of a 1.60 MEF/8.5 WF efficiency level is a complete tran sition to horizontal-axis clothes washers.
1.72 MEF/8.0 WF Efficiency Level
All manufacturers stated that this effici ency level was beyond th e reach of agitator vertical-axis clothes washers ina commercial laundry se tting. Thus, a switch would be required to either non -agitator vertical-axi s or to horizontal-axis washer plat forms with the same issues as noted for the 1.60 MEF/8.5 WF efficiency level. Since none of the manu facturers expects to manufacture non-agitator vertical -axis clothes washers for the co mmercial laundry market, the most likely outcome would be the adoption of horizontal- axis clothes washers.
1.80 MEF/7.5 WF Efficiency Level According to manufacturers, neith er vertical-axis clothes wash er platform can reach this efficiency level in a comm ercial laundry se tting and provide satisfa ctory wash and rinse performance. Thus, this efficiency level is a de -facto horizontal-axis stan dard. According to all manufacturers, the cost of manufacturing a 1.80 MEF/7.5 WF horizontal-axis commercial clothes washer is the same as manufacturi ng a 2.00 MEF/5.5 WF model. Thus, they saw no reason to consider this efficiency level.

5-782.00 MEF/5.5 WF Efficiency Level
All manufacturers of commercial clothes wa shers currently m anu facture a horizontalaxis, commercial clothes washer in this MEF/WF range. As a result, AHAM was able to submit a shipment-weighted incremental cost for this efficiency level, for which all manufacturers assumed the use of a horizontal-a xis clothes washer platform.
2.20 MEF/5.1 WF Efficiency Level
Manufacturers stated that this standard leve l would requir e additional modifications to their horizontal-axis commercial clothes washer platforms. All manufac turers would need to replace any electronic motor-drive n transmissions with electroni cally-controlled direct-drive motors. Further reductions in water temperatures and water fill levels would also be necessary. As part of interviews with DOE, manufacturers estimated that the incremental manufacturing cost increase to meet this standard level would range from $316 to $450 per clothes washer.

5.6.4.3 Review of the Most Recent TSD for Residential Clothes Washers In 2001, DOE concluded a rulemaking for residentia l clothes washers. The intent of this section is to review som e of the conclusi ons drawn in the 2000 TSD which supported that rulemaking, to update the data presented in it, and to assess in which ways the residential clothes washer TSD can be used in the context of th is commercial clothes washer rulemaking. In particular, this review will focus on the manufact uring costs published in the 2000 TSD. First, the 1996 AHAM residential clothes washer cost data submittal provided for the 2000 TSD will be examined, followed by the 2000 reverse-engin eering analysis and an update on the lowvolume manufacturer case. 1996 AHAM Cost and Energy Use Data Submittal Review In 1996, manufacturers submitted manufacturing cost and energy use estimates by efficiency level for residential clothes washer s to AHAM. T his data was then aggregated by market share and efficiency level to prevent th e disclosure of confiden tial information, and the results were used in the analysis reported in the 2000 TSD. Wh ile this process yielded viable results in the residential clothes washer rulemaking, the results are not directly applicable to the current commercial clothes washer rulemaki ng due to differences in the following key parameters: (1) intended use and cycle life, (2) production scale, (3) technical advancements, (4) market share, (5) platform mixing, and (6) incomp atibility of the MEF and WF pairings in the data submittal. Intended Use and Cycle Life
Clothes washer manufacturers have traditiona lly designed their comm ercial units to share many parts with their residential platforms. Shared components typically c onsist of parts that do not affect unit life, such as cabinet stampings, th at may or may not be selectively upgraded. For example, entry-level residential clothes washer cabinets typically featur e a powder-coated plastic

5-79finish whereas commercial models may feature a more durable enameled finish. Purchased components such as motors, timers, and switches ma y also be customized to reflect the different and more rigorous usage patterns expected in commercial applications. For example, one manufacturer stated that thei r commercial clothes washers ar e expected to last 12,000 wash cycles whereas residential models are exp ected to last 6,000 or fewer wash cycles.
Production Scale In 1996, a twenty-fold scale difference exis ted between residential and commercial clothes washer m arket unit shipments. Since th en, residential clothes washer shipments have grown while commercial clothes washer sales have stagnated or declined. As a result, the current scale difference is more than forty-fold. The scale difference helps explain why commercial clothes washers have traditionally been a product extension of existing residential cl othes washer platform s fo r most manufacturers. By sharing many components with residential models, research and development, tooling and equipment, and other costs can be spread ove r the largest number of clothes washers. Consequently, any additional investment require d for commercial clothes washers alone is depreciated over a much sm aller production volume. As efficiency standards are ra ised, m anufacturers may be required to make investments in the form of capital expenditures, research and development, and implementation to meet such standards. Investments such as new tooling a nd research, in particular, are “step” functions, requiring a minimum investment regardless of production volume. A standard that affects commercial clothes washers first may thus requir e a substantial investment that can only be depreciated over a much sma ller production volume. As a result of the much lower production volum es, the per-unit conversion costs to accommodate higher efficiencies ar e greater per efficiency incr ement for commercial clothes washers than they are for residential models. Therefore, Table 4.2 published in the 2000 TSD (duplicated below as Table 5.6.32) is not valid for commercial cl othes washers because the fixedcosts are assumed to be depreciated over a much larger product volume and because the highervolume production processes manufacturers envisione d minimize variable costincreases. Most manufacturers of residential cl othes washers in 1996 had pro duction levels in excess of 300,000 units per year, with the leading manufacturer producing about 3.5 million vertical-axis washers per year. In contrast, the 2 leading commercial cl othes washer manufacturers in 2007 have commercial clothes washer production le vels of about 100,000 units per year. Currently, as in 1996, there is a low-volume m anufacturer that operates in both the residential and commercial clothes washer markets. While its volumes in the residential market are very small on a percentage basis, this manufacturer is very prominent in the commercial clothes washer market. Unlike its diversified competitors, this company exclusively manufactures laundry equipment. A review of the Securities and Exchan ge Commission (SEC) 10-K documents revealed that, as of 2005, this co mpany derived 22 percent of its total revenue from the sale of front- and top-loading clothes wa shers and 87 percent of that income was from

5-80the commercial market. As a result, this co mpany will be affected disproportionately by the commercial clothes washer rulemaking compared to its competitors, for whom commercial clothes washers represent about 2 percent of total clothes washer sales.
Table 5.6.32 1996 AHAM Residential Clothes Washer Cost Data Submittal

Product Characteristics Incremental Variable Costs Total Incre- No. ( $ per Unit ) Fixed mental of Costs ($ per Mfg. Cost ResponPercent MEF WF Ma- Labor Over- Total Improve- terials head unit ) ($ per dents ment unit ) Baseline 0.817 13.779 5 0.860 13.732 $0.01 $0.01 $0.00 $0.02 $0.07 $0.09 5 10 0.908 13.710 $0.25 $0.04 $0.01 $0.30 $0.61 $0.91 5 15 0.961 13.670 $3.18 $0.10 $0.04 $3.32 $1.01 $4.33 5 20 1.021 13.342 $10.71 -$0.02 $1.80 $8.89 $6.21 $15.10 5 25 1.089 9.220 $36.14 $8.61 $0.09 $44.84 $19.29 $64.13 5 30 * 35 1.257 7.601 $86.73 $10.94 $7.78 $105.45 $22.72 $128.17 5 40 1.362 7.610 $87.15 $10.94 $7.78 $105.87 $22.72 $128.59 5 45 1.485 8.570 $125.58 $15.52 $14.51 $155.61 $24.67 $180.28 4 50 1.634 8.570 $132.40 $15.68 $14.51 $162.59 $24.67 $187.26 4 * No data were submitted at this efficiency level Technical Advancements While the general function of clothes wash ers has not changed si nce the 2000 TSD, m any different technologies have been implemented. As with dishwashers, de humidifiers, and other residential appliances, clothes wa shers are built on platforms whose baseline performance can be improved with design options. Some platforms ar e inherently more energy and water efficient than others, allowing a manufactur er to use fewer design options to reach a particular efficiency level, but there are efficiency limits inherent to every platform regardle ss of how many design options are employed. These limits affect the MEF as well as the WF. Clothes washers currently often use electroni c co ntrollers instead of electromechanical controllers, which were more pr evalent at the time of the 2000 TSD. Electronic controllers usually carry a cost premium over electromechan ical timers, driving up manufacturing cost. However, such controllers are appealing to cust omers and are required for some design options. Besides enabling certain design options, electron ic controllers allow owners to more easily monitor washer utilization, functiona l status, and other parameters. There are potential reliability benefits as well. For example, one reason that variable-water-height sele ctors are atypical in commercial vertical-axis clothes washers is that ow ners prefer not to give users the ability to select water levels. If they di d, users could attempt to wash a fu ll load on a “low water” setting, potentially damaging the washer and/or the clothe s being washed. Electronic controllers may be able to detect such overload conditions and stop the wash cycle before the clothes washer is

5-81harmed. Alternatively, controller s can be programmed to “reset” to default settings after each wash cycle. This forces the end-user selectthe appropriate cycle fo r each use, potentially reducing the incidence of accidental overloads. Some manufacturers have also phased out mech anical tran smission a nd clutch systems, replacing them with variable-sp eed electronic drive systems. Benefits include a reduction in mechanical complexity, increased cabinet sp ace to accommodate potential expansion of the basket/tub, and greater wash program flexibility. The substitution of electronics for mechanical systems can increase overall unit co st, particularly if fixed in-house assets that had been used to manufacture mechanical transmission and clutch systems become stranded assets. Many design options available in residential clothes washer have ye t to find application in comm ercial clothes washers. The reliabi lity and longevity requirements of commercial clothes washers combined with the production scal e issues are such thatmanufacturers avoid adding design options unless necessary. As the part count increases, so does the probability that the clothes washer will break down, and purchased parts sourced just for commercial clothes washers are likely to carry a cost premium. Thus, DOE expects manufacturers will continue to introduce new features first inthe residential markets befo re transitioning them to the commercial field. Since the 2000 residential clothes washer TSD was written, there have been numerous technolog ical advances incorpor ated into clothes washers, and the manufacturing costs submitted to AHAM were based on residential clothes wash er models which are no longer in production. Thus, even if DOE could ascertain the manufact uring cost differential between commercial and residential clothes washers in 1996, that differential would no longer be valid for current models. Most importantly, manufacturers have been able to improve the MEF and WF of agitator clothes washers at a m uch lower cost than they projected in 1996. Inst ead of using horizontalaxis or non-agitator vertical-a xis clothes washers as projected to meet a 1.26 MEF, current baseline 1.26 MEF commercial cl othes washers consist of agitato r models with reduced water consumption, lower wash temperatures, and impr oved control systems. Thus, manufacturers were able to reach the current efficiency require ments at much lower cost than projected in 1996. One manufacturer noted that the costs of improved control systems are substantially higher than those of the electromechanical c ontrols they replaced and that the wash performance and hence end-user utility of vertical-a xis clothes washers are affect ed by lower WF and higher MEF requirements.
Market Share The market shares that AHAM used to aggr egate m anufacturer-submitted data were valid for the residential clothes washer market in 1996. However, since then th ere has been significant consolidation by domestic producers, and multiple foreign brands have started selling their clothes washers in the U.S. More importantly, th e market shares of producers in the residential clothes washer market are not equivalent to the market sh ares of manufacturers in the commercial clothes washer industry.

5-82Four to 5 residential clothes washer manu facturers submitted manufacturing cost data estimates for each efficiency level for the 1996 AHAM data request. However, there are currently essentially only 3 U.S. commercial clothes washer manufacturers: Alliance Laundry Systems LLC (Alliance), General Electric GE Cons umer & Industrial (GE), and Whirlpool (via its acquisition of Maytag Corporation (Maytag)). The low number of manufacturers limits current AHAM data submittals to DOE since AHAM requires a minimum of 3 data points per efficiency level before it publishes any results. Since AHAM adjusts incremental manufacturing cost data submittals by efficiency level
on a m arket-share basis, the manufacturing costs submitted by the largest manufacturers have the greatest weight. As noted above, the distri butions of market share by manufacturer for commercial and residential clothe s washers are quite different. Since DOE does not have access to the disaggregated data, ther e is no opportunity to compensate for market share differences between markets, even if the costs of manufact uring residential and comm ercial clothes washers were the same. Platform Mixing Attempting to update the 1996 AHAM data subm ittal is hin dered by its aggregation of vertical- and horizontal-axis clothes washers. Based on th e AHAM-supplied energy and water use data, reproduced in Table 5.6.33, DOE assumes th at the cost and energy use tables contained only agitator vertical-axis data for efficiencyimprovement levels of up to, and including, 20 percent. This assumption is driven by the cons istent water usage up to that point and the low incremental costs to reach that efficiency level. Similarly, DOE assumes that the 2 highest efficiency levels, 45 and 50 percent improvement , exclusively incorporated horizontal-axis clothes washers. The 25 to 40 percent improveme nt categories appear to have aggregated highefficiency vertical- as well as horizontal-axis clothes washers.

5-83Table 5.6.33 1996 AHAM Residential Clothes Washer Energy and Water Use Data Submittal Product Characteristics Energy Use Water Use ( kWh/cycle ) Percent Improve

-ment MEF Total Energy w/Dryer

( kWh /cycle ) Clothes Containe

r (

ft

3 ) Hot Water Machin e Energy Dryer Energy ( gal / cycle ) ( gal / ft

3 )

Baseline 0.817 3.227 2.847 1.587 0.209 1.430 39.181 13.779 5 0.860 3.165 2.817 1.543 0.209 1.413 38.613 13.732 10 0.908 3.017 2.822 1.408 0.209 1.400 38.613 13.710 15 0.961 2.833 2.832 1.216 0.209 1.407 38.621 13.670 20 1.021 2.739 2.893 1.113 0.218 1.408 38.446 13.342 25 1.089 2.292 2.866 0.715 0.304 1.273 26.600 9.220 30 * 35 1.257 1.866 2.749 0.462 0.133 1.270 21.030 7.601 40 1.362 1.859 2.749 0.462 0.133 1.263 21.030 7.610 45 1.485 1.651 2.736 0.429 0.114 1.107 23.405 8.570 50 1.634 1.574 2.736 0.413 0.114 1.047 23.405 8.570 * No data were submitted at this efficiency l evel. Since DOE does not have access to the disaggregated data and the clothes washer platforms that underlie the AHAM data submittals , there is no method by which DOE can assess how relevant the data submittal is to the curr ent rulemaking. It is not clear to DOE which models were submitted at each efficiency level, whether these models use the same platforms as current commercial clothes washers, nor what e fficiency improvements manufacturers have been able to achieve with these models since 1996. Incompatibility of the MEF and WF Pairings Table 5.6.33 shows the lowest shipment-weigh ted W F at 1.26 MEF. No vertical-axis clothes washers could reach 1.634 MEF in 1996, sugge sting that the clothes washers at the 2 highest efficiency levels cons isted of horizontal-axis clothe s washers whereas baseline units consisted of agitator vertical-axi s clothes washers. The WF is lowest at 1.26 MEF, indicating that the shipment-weighted WF for that efficien cy level included clothes washers that had a lower WF than residential horizontal-axis clothes washers did at that time. DOE is aware of an agitator vertical-axis commercial clothes washer platform from a major manufacturer that had achieved a 7.3 WF via spray rins e. However, this unit was withdrawn from the market a number of years ag o due to end-user complaints regarding rinse performance. The CEC database of current co mmercial clothes washer s lists no vertical-axis clothes washers with a similar wate r factor. The closest model is an agitator vertical-axis washer platform with an 8.8 WF. The single vertical-axis clothes washer platform currently listed in the

5-84CEC residential clothes washer database that meets the 7.6 WF does not exist in a commercial version and consists of a non-agitator design. Thus, the results at 1.26 MEF in Table 5.6.33 suggest multiple platforms, likely consisting of agitator vertical-axis w ith spray ri nse, non-agitator vertical -axis, and horizontalaxis residential clothes washers. Neither spray-rinse agitator nor non- agitator clothes washers are currently in pr oduction for commercial purposes. The incompatibility be tween the WF of machine properties submitted to AHAM for the 1996 data submittal and machines currently on the market is yet another indication of how the projections of manufacturers diverged from the agitator vertical-axis clothes washers th ey developed to meet the 1.26 MEF/9.5 WF requirements.
Conclusion There are sufficient changes in market condi tions due to intended use and cycle life, production scale, technical advancements, and m arket share to precl ude the use of the 1996 AHAM data submittal as a basis for the current commercial clothes washer analysis. Furthermore, the 1996 AHAM data submittal cannot be factored into the analysis due to platform mixing and the resulting inability to disaggregat e the data into vertical- and horizontal-axis machines. 2000 TSD Reverse-Engineering Review Further manufacturing cost data by effi ciency level was developed for the 2000 residen tial clothes washer rulemaking by DOE. Since DOE has access to this data, DOE has decided to review and publish data that remain s relevant to the curr ent commercial clothes washer rulemaking.
Reviewed Models
For the 2000 residential clothes washer TS D, DOE reverse-engin eered 8 residential clothes washers in 1999 from manu facturers with substantial mark et shares. DOE subsequently developed cost models to estimate the manuf acturing costs of these washers at varying production levels. The market share covered by the residential cl o thes washer platforms reverse-engineered in 1999 was about 80 percent. Three of the wash ers shared a chassis with commercial clothes washers in 1999. DOE could make estimates rega rding the costs to update these platforms for commercial use, but the market sh are covered by these platforms is currently less than 20 percent of the commercial market, limiting the usefulness of the results. All 3 of the major manufacturers currentl y serving the commercial clothes washer industry have introduced new m odels or significantly revise d existing models since the 2000 residential clothes washer TSD. Some manufacturers have upda ted the drive systems and other major system components to differentiate their products or improve energy efficiency. As a

5-85result, there have been significant changes in th e baseline cost of clothes washers that the 2000 TSD could not have analyzed, even if it had revi ewed commercial clothes washer models.
Market Share and Scale The U.S. commercial clothes washer market is very small compared to the residential clothes washer m arket. Whereas shipments of re sidential clothes washers have been increasing, with more than 9.2 million units in 2005, commerc ial clothes washer sales have stagnated or declined to about 200,000 units per year. The resi dential clothes washer market is dominated by the merged Whirlpool-Maytag entity, which has an approximate combined market share of 70 percent. The residential clothes washer sales of this entity exceed 6.5 million units per year, more than thirty times the entire commercial clothes washer market. This scale difference is important in this anal ys is because agitator vertical-axis residential and commercial clothes washers typically shar e many parts to minimize tooling and equipment investments. Thus, a manufacturer that bene fits from high manufacturing volumes on the residential side has a much larger potential base of units over which to depreciate investments. Commercial assembly lines can be repurposed towards residentia l clothes washer production if the commercial vertical-axis washer platform is no longer cost effective to produce. While the largest competitor in the U.S. cl othes washer m anufacturing business may not realize much cost benefit due to manufacturi ng scale in moving to 6.5 million units per year versus the 1.5 million units per year modele d during the 2001 residential clothes washer rulemaking, there are other advantages to scale. For example, research and development and other overhead functions can be leaner as a percen tage of sales revenue, yet still have far more available resources than comparable departments at lower-volume competitors. High-volume competitors have a long history of improving the performance of agitator vertical-axis clothes washers via add-on design options such as sp ray rinse, nutating plates, and other m eans. For a lower-volume manufacturer, it is inherently more difficult to assemble and defend an intellectual-property portfolio. Sim ilarly, a low-volume manufacturer may have to wait for innovations to trickle down from comm on suppliers since high- volume manufacturers typically get first (and sometimes ex clusive) access to new technologies. Manufacturers whose production comprises a hi gh percentage of comm ercial clothes washers are thus impacted disproportionatelyby any regulatory burden regarding commercial clothes washers. One low-volume U.S. clothe s washer manufacturer was contractually barred from manufacturing residentia l clothes washers from 1999 until 2004. While its subsequent SEC 10-K reports show significant growth in the resi dential market segment, commercial sales are still substantially higher. As a result, this low-volume manufactu rer is not only c oncentrated in the commercial clothes washer market, but its l ack of diversification makes it particularly sensitive to any impacts on its commerc ial clothes washer business as well. The Low-Volume Manufacturer Case

5-86The Low-Volume Manufacturer (LVM) has b een successfully competing with much larger competitors in the commercial laundry ma rket for several years. Based on the LVM's public SEC 10-K filings, DOE has estimated that the LVM derives about a third of its total revenues from the sales of clothes washers and dryers, which are usually bundled. Clothes washer sales by themselves account for more than 20 percent of to tal revenue. Laundry equipment for institutional use largely makes up the balance. Fo r a detailed breakdown of LVM revenues by product line and market segment, see Appendix 5C of the TSD, which details DOE's methodology and results for the LVM analysis. As of 2005, agitator ve rtical-axis clothes washers sold by the LVM into the commercial market segment represented about 70 percent of unit shipments and about 60 percent of total commercial clothes washer revenues. Thus, any legislation that eliminates the use of such clothes washers from the commercial market w ould affect the LVM disp roportionably due to the relative importance of the business and its effecton manufacturing scale. Such a transition also poses a business risk since a platform change will reduce the value of accumulated spare-parts inventories, technician training, etc. to route operators. Thus , any switching cost to other brands could be substantially reduced.
The LVM released a horizontal-axis clothe s washer for sale in 1999 and does not presently manufacture any non-agitat or vertical-axis clothes washer s. As of 2005, its sales of horizon tal-axis clothes washers represent ap proximately 20 percent of total washer unit shipments and approximately 35 percent of tota l washer revenues. Given the scale of the manufacturer at the time, the design was likely optimized for very low production volume. Should the entire commercial clothes washer industry be forced to migrate to horizontal-axis clothes washers, the LVM would thus have to ma ke substantial investments to make its design more cost competitive. While the LVM is already at work to reduce horizontal-axis unit costs, a market transition to horizontal-a xis washers accelerated by federal standards would most likely result in the LVM moving its horiz ontal-axis manufacturing offshore. However, unlike its larger rivals, the LVM doe s not benefit f rom very large scale in its residential operations to help amortize the investments in research, development, plant expenditures, and implementation expenses. The size of the commercial clothes washer market by itself is simply too small to justify large lu mp-sum investments. The agitator vertical-axis units that the LVM manufactures have benefited from years of investments and refinements, whereas the horizontal-axis model received its first update in 2003. Besides benefiting from ongoing development and investm ents, agitator vertical-axis clothes washers at the LVM also benefit from well-depreciated equipment and tooling and a long-term knowledge base. In the past, the LV M had residential sales well in excess of its commercial clothes washer sales before a non- compete contract cut off the LVM from the residential market from 1999 until 2004. Thus, wh ile the LVM has gained the experience of producing hundreds of thousands of vertical-axis clothes washers pe r year, it has yet to gain the same experience with its horizontal-axis clothes washer line.

5-87The loss of the commercial market for agitator vertical-axis clothes washers is likely to make residential models of those clothes washer s too expensive to manufacture due to the much smaller scale. Whether the LVM could remain in the horizontal-axis clothes washer business despite the loss of the agitator vertical-axis clothe s washer business is also uncertain. To date, the LVM has been able to grow its business desp ite adverse market conditions and much larger competitors. Implications of Scale for the Low-Volume Manufacturer As discussed previously, mostof the clothes washers under review in the 2001 residential clothes washer rulem aking did not share a chassis with a commercial model. Thus, the results of the engineering analysis in the 2000 TSD do notapply to present day commercial clothes washers except for a very narrow set of observations.
A universal factor in manufact uring is scale, which descri bes how m any units over which a fixed investment can be amortized. As part of the 2000 reverse-engi neering analysis for residential clothes washers, DOE tried to understand the implications of low-volume manufacturing. Figure 5.6.24, origin ally published as Figure 5.10 in the 2000 residential clothes washer TSD, averages the cost differences am ong multiple baseline vertical-axis residential clothes washers at production levels of 1.5 m illion and 0.3 million units per year. It also averages horizontal-axis results for the residential horizontal-axis clothes washers that DOE reverse-engineered.

Figure 5.6.24 2000 Low-Volume versus High-Volume Clothes Washer Cost Disadvantage

5-88While the units under review in the 2000 re sidential clothes washer TSD are not applicable to the current commercial clothes wash er analysis, the impact of manufacturing scaleUSD is still relevant to the commercial clothes washer market . As manufacturing volumes shrink, labor costs rise due to growing inefficiencies within the fabri cation and assembly lines. The effect of manufacturing scale on depreciation is even more pronounced, as there are minimum tooling and equipment investments required to start operations, re gardless of what the actual manufacturing volume turns out to be. Carefu l design will minimize the amount of additional tooling required to brin g a new product to market. Results from the 2000 TSD analysis for the effects of manufacturing scale are presented as follows, recognizing that sim ilar results will likely apply to commercial clothes washers. Figure 5.6.25 examines the case of very low-production volumes (100,000 units per year) versus producing at high volumes (1,500,000 units per y ear). Driven mainly by increases in depreciation costs, the verylow-volume manufacturing cost increment over high-volume manufacturing increases to about $80 for both vert ical- and horizontal-axis clothes washers.

$90.00
$80.00
$70.00
$60.00
$50.00
$40.00
$30.00
$20.00
$10.00

$0.00 V- Axis H-Axis Other

i Depreciation Labor Mater als

Figure 5.6.25 2000 Cost Disadvantage of Producing 100,000 versus 1.5MM Clothes Washers per Year with Green Field Facility

The agitator vertical-axis clothes washer m arket is largely commoditized, resulting in fierce price competition. A $156 price differenc e for the end user ($80 manufacturing cost multiplied by a 1.93 total markup (see Chapter 7 of th is TSD)) is not likely to be sustainable.

5-89However, the LVM is aided in this product segm ent by the extant tooling and equipment, years of research and development, etc. which represent a sunk cost. In contrast, the horizontal-axis clothes washer m anufacturing line would have to increase its output by multiples to meet the unit demand th at the vertical-axis line currently sustains. Since the 2 platforms do not share many components, the vertical-axis line w ould be likely to be written off, while substantial investments w ould be required to e xpand the output of the horizontal-axis line. Such investments may not be justified by the potentia l market for them, and the larger rivals have a great a dvantage in terms of leveraging their residential clothes washer shipments to minimize depreciation on a per-unit basis. Thus, while the LVM may be able to comp ete with its b igger rivals on the agitator vertical-axis platform due to depreciated plant and equipment, prior high-volume experience, and a long learning curve, it would be competing at a great disadvantage with its larger rivals should horizontal-axis commercial clot hes washers become the only platform that can meet future energy efficiency standards. Manufacturers operating at verylow volum es are likely to face margin pressure for both vertical- and horizontal-axis clothes washer s. To counter pressure from high-volume manufacturers, low-volume producers have to co mpete on the basis of service, reliability, bundling, and product differentiation. Its long legacy in the agitato r vertical-axis market also aids the LVM in competing successfully with larger rivals.
Conclusion In conclusion, the LVM faces larger rivals in all of the clothes washer markets it competes in, yet the LVM has been able to growits revenue despite bein g heavily concentrated in the stagnant commercial clothes washer market . As a result, the elimination of the agitator vertical-axis clothes washer platform from the commercial clothes washer market would impact this manufacturer disproportionate ly and could therefore repres ent a material risk to the company. Other Observations Regarding the 2 000 Residential Clothes Washer TSD Historic Background When DOE began the 2001 residential clothe s w asher rulemaking, the U.S. residential clothes washer market consisted almost exclusivel y of vertical-axis platforms. Table 3.9 in the 2000 TSD noted that vertical-axis clothes washer s comprised a 99.9 percent market share as of 1995. Available horizontal-axis clothes washers were limited to imported goods and 2 domestic platforms. While the majority of overall clothes washer shipments in the U.S. still consist of vertical-axis clothes washers, th e shipment levels and market share of horizontal-axis clothes washers have grown significantly. Unlike in 1995, all remaining U.S. manufact urers now sell horizontal-axis clothes washers that are either produced in th eir own fact ories or outsourced. The majority of residential

5-90horizontal-axis clothes washers sold in the U.S. today are manufactured abroad. While a greater proportion of commercial clothes washers are made domesti cally, significant market scale differences remain. Thus, as markets for verti cal-axis clothes washers decline, domestic clothes washer production will likely decline also. In the 1996 AHAM data submittal, the maximum potential improvement was capped at an MEF of 1.634, whereas horizon tal-axis clothe s washers from multiple vendors currently reach MEFs in excess of 2.00. Manufacturers have also increased the basket cap acity of vertical- and horizontal-axis clothes washers, reaching up to 4 cubic feet in some residential models. The WFs are also significantly lower on several current horizontal-axis clothes washers found in either residential or commercial clothes washer markets than they were for models in the 2000 TSD.
As a result of the residential clothes wash er rulem aking, the standards for residential clothes washers were increased in 2 steps, reaching an MEF of 1.26 as of January 1, 2007. When the standard was signed into law, no horizonta l-axis clothes washer MEFs were below 1.26. Thus, only vertical-axis clothes washers were affected by the rulemaking. In the interim, manufacturers worked to find the most cost-effec tive way to modify their vertical-axis platforms to meet the current minimum MEF. At the time of the 2000 TSD, a correlation was noted and assum ed between MEF and WF (see Table 5.6.33). However, no WF was imposed in the final rulemaking. As a result, manufacturers could largely focu s on reducing the energy content of the wash and rinse water rather than having to jointly focus on the MEF an d the WF. None of th e agitator vertical-axis clothes washers that currently meet the 1.26 MEF minimum efficiency standard also reach the WF predicted for that efficiency level by the 2000 TSD. Typically, such current vertical-axis clothes washers use 2 more gallons of water per cubic foot of capacity than the WF associated with the 1.26 MEF standa rd in the 2000 TSD. Impact of Product Test Procedures Based on language in EPACT 2005, DOE is requi red to rate commercial clothes washers with the same test procedure established for re sidential clothes washers. (E PACT 2005, section 136(f)) DOE adopted test procedures for commerc ial clothes washers in a final rule published on October 18, 2005. (70 FR 60407, 60416) The te sting procedure for residential clothes washers is published in Appendix J1 to 10 CFR Part 430, Subpart B. When calculating MEF, the DOE test procedur e factors in end -user-selectable variables including the wash and rinse water temperatures, and fill level. Thus, adaptive water levels (either user-set or automatic) and temperature choices are accounted for in the calculation. Some design options, such as reducing th e amount of rinse water, have an efficiency benefit regardless of the user-set program. Thes e and other design options have allowed the 3 highest-volume commercial clothes washer manufacturers to reac h the 1.26 MEF standard le vel at relatively low cost by making evolutionary changes to their vertical-axis platforms.

5-91For example, the calculated MEF is a func tion of the cycle water temperatures. By requiring a cold rinse and offering more warm or cold wash programs while reducing the number of hot wash cycle options, the MEF of a washer can be raised without affecting the WF. The incremental cost of offering more wash temperat ures or lowering the temperatures overall is relatively minor. Similarly, the added cost and complexity of offering a water level selector switch is relatively minor but it allows manufacturers to take advantage of the credits that the DOE test procedure gives to washer s that have this design option.
At the time of the AHAM data submittal for th e 2000 TSD, clothes washer manufacturers had little experience with the upda ted clothes washer test proce dure, which was not published in the Federal Register until August 27, 2000. The onl y vertical-axis clothes washers on the market at the time that could reach an MEF of 1.26 were proprietary in design. Furthermore, the clothes washer manufacturing cost estimates for the 1.26 MEF levels were an amalgam of the high-cost proprietary vertical-axis design and several horizontal-axis washers. In conclusion, the cost of upgrading verti cal-axis washers to reach an MEF of 1.26 was lower than m anufacturers estimated accordi ng to the AHAM-supplied data. No expensive design options had to be employed to push the ve rtical-axis platform to that MEF level. Therefore, DOE believes that the current manufactur ing cost of an agitator vertical-axis clothes washer which meets the 1.26 MEF/9.5 WF efficiency level is within 10 per cent of the cost of a baseline washer in Table 5.6.33 once thes e costs are adjusted for inflation. Persistence of Baseline Vertical-Axis versu s Horizontal-Axis Clothes Washer Cost Differential Since the publication of the 2000 TSD, the clothes washer market has been transformed by the entrance of m ore foreign competitors, significant market consolidation, and the appearance of residential clothe s washers that have higher load capacities than the basketcapacity limits defined by EPACT 2005. For example, horizontal-axis residential clothes washers from BSH Home Applian ces Corporation (Bosch-Siemens), GE, LG Electronics, Inc. (LG), and Whirlpool have a stat ed basket capacity in excess of the 3.5 cubic foot capacity product class definition limit set by EPACT 2005 for residential clothes washers. Despite the entrance of multiple horizontal-a x is clothes washers into the commercial and residential markets, a significant retail price diffe rence between agitator vertical- and horizontalaxis clothes washer platforms persists. This suggests that manufacturer s have yet to overcome the inherently higher costs associated with manufacturing horizontal -axis clothes washer platforms. These cost differences are due in part to the suspensions, seals, drive systems, and stain less-steel wash baskets that horizontal-a xis clothes washers employ and which can be simpler, unnecessary, and/or less expensive in baseline vertical-axis models. The higher strength, stiffness, and vibrati on-resistance requirements for hori zontal-axis clothes washers add further cost and complexity. Electronic drive systems are found in all horizontal-axis clothes

5-92washers, whereas simpler and less expensive i nduction motors are typi cally found on baseline vertical-axis clothes washers. High-volume manufacturers of ve rtical-ax is clothes washers al so benefit from a plant and equipment stock that have been largely depreci ated, yet remain functional. The growth in horizontal-axis clothes washer sales continues to demand factory expansion and the resultant investments. As noted above, the reverse-engineering anal ysis of the 2000 residential clothes washer TSD is largely not a valid basis upon which to compare costs in the commercial m arket. However, it is interesting to note how manufacturers were able to meet the current 1.26 MEF residential clothes washer standard with little to no additional manufacturi ng cost. Thus, the cost of a baseline vertical-axis washer has not change d much in the interim, other than to reflect changes in raw materials costs. Horizontal-axis clothes washer costs are similarly affected, so that the manufacturing cost differential between the 2 residential clothes washer platforms has remained largely the same. The retail pricing survey for this current TSD underscores this persiste nt differential, as noted in Figure 3.11.1 in Chapter 3 of this TSD. This figure dem onstrates that the average retail price difference between commercial top-loading, vertical-axis and front -loading, horizontal-axis washers varies between $531 for washers with coin boxes and $625 for washers without coin boxes. As noted in Table 8.2.42 in Chapter 8 of th is TSD, the total mar kup from manufacturer to end user is 1.93 for commercial clothes washer s. Therefore there is a manufacturing cost difference of $275 to $327 between vertical-axis a nd horizontal-axis commer cial clothes washer platforms. This difference is about $100 higher than th e average difference cal culated in the 2000 residential clothes washer TSD between baselin e vertical-axis and 2 horizontal-axis clothes washers that were subjected to revers e-engineering an alysis. However, the residential designs were produced at much a higher manufacturing s cale, suggesting higher co st optimization, better purchasing power, and lower raw material costs. Higher- volume manufacturing allows a manufacturer to consider more platform and design options th at could not be economically justified at a very low manufacturing scale. Thus, the $316 cost difference in the AHAM -submitted data for vertical-axis and horizon tal-axis commercial clothes washers is pl ausible. A cost difference higher than that found in the residential market is reasonable si nce commercial clothes washers are designed to be more rugged, are required to be more reliable, and are produced at a much lower scale. As a consequence, manufacturers cannot readily cost-optimize horizontal -axis designs to the extent that they have been able to refi ne their extant verti cal-axis units. In addition, even an optimized horizontal-axis commercial clothes washer will remain inherently more expensive to produce than a high-volume residential model built on the same platform due to the volume over which customized items like controllers have to be depreciated.

5-93In determining incremental costs at intermediate efficiency levels other than those at which AHAM supplied data, DOE notes that, like dishwashers, CCWs are platform-driven products where platforms achieve an inherent e fficiency based on design that can be further enhanced via design options. However, the cost of the CCW is the same to the manufacturer, whether it is programmed to operate at the inherent efficiency level, or below. Thus, DOE expects that the incrementa l costs between 1.60 MEF/8.5 WF and 2.2 MEF/5.1 WF would be constant at the same value as those provided by AHAM for the level 2.0 MEF/5.5 WF. Table 5.6.34 shows the preliminary commercial clothes washer cost-efficiency results.
Table 5.6.34 Incrementa l Manufacturing Cost for Commercial Clothes Washers Efficiency Levels (MEF/WF) Incremental Cost Baseline

- 1.42/9.5 $74.73 1.60/8.5 $316.35 1.72/8.0 $316.35 1.80/7.5 $316.35 2.00/5.5 $316.35 2.20/5.1 $316.35

5-94REFERENCES

1 U.S. Department of Energy (DOE). 1996. T echnical Support Docum ent for Residential Cooking Products. Washington, DC.
< http://www.eere.energy.gov/buildings/appliance_s tandard s/residential/cooking_products_0998_r.html >

2 A. P. Sanghvi, Cost-Benefit Analysis of Power System Reliability: Determination of Interruption Costs. Prepared by RCG/Hagle r Bailly, Inc., Arlington, VA for Electric Power Research Institute, Palo Alto, CA, EL- 6791. Vol. 2, p. 3-3 and Vol. 3, p. 3-3. < http://www.epri.com >

3 American Metals Market, http://www.amm.com/.

4 U.S. Department of Energy (DOE). 1997. Technical Support Docum ent: Energy Conservation Standards for Consumer Products: Room Air Conditioners . Washington, DC, DOE/EE-O148, Septem ber 1997.

5 Association of Home Appliance Manuf acturers (AHAM). 2006. AHAM Test Data on Microwave Ovens . October 23, 2006. Docket N o. EE-2006-STD-0127, Comm ent Number 17.

6 Ibid

.
7 Ibid

.
8 Ibid.

9 Ibid

.
10 Ibid

.
11 Fish, N. et al . 2006. Standby Power Energy Use of Common Household Appliances

. Canadian Building Energy End-Use Data and Analysis Centre, CBEEDAC 2006-RP-04- DRAFT, July 2006.

12 Aulenback, A. et al . 2001. Stand-By Power Requirements for Household Appliances. Canadian Residential Energy End-Use Data and Analysis Cent re, CREEDAC-2001-05-04, May 2001.

13 Ibid

.
14 Lawrence Berkeley National Laborator y (LBNL). 1999. Standby Power Summary Table. Available online at http://standby.lbl.gov/Data/SummaryTable.html.

5-9515 Floyd, D. and Webber, C. 1998. “Leaking Elec tricity: Individual Field Measurement of Consumer Electronics”, Proceedings of Amer ican Council for an Energy-Efficient Economy , Florida Solar Energy Center, August 1998.

16 Meier, A. and Huber, W. 1997. Results from the Investigations on Leak ing Electricity in the USA . Lawrence Berkeley National La boratory, Berkeley, C A, LBNL-40909, 1997.

17 AHAM. 2006. Op. cit

.
18 U.S. Department of Energy (DOE). 1980. Engineering Analysis . Washington, DC, DOE/CS-1066, June 1980.

19 Bloomfield Jr., W.E., President of WEB Service Company Inc., 2001. Testimony at the California Energy Commission (CEC) public hearing regarding the matter of AB970 California Appliance Effici ency Regulations, CEC 4-24- 2001 Hearing Record, April 24, 2001, p. 138.

20 Thompson, M., Whirlpool Corporation, 2001. Testimony at the CEC public hearing regarding the matter of AB970 California Appliance Efficien cy Regulations, CEC 4-24-2001 Hearing Record, April 24, 2001, p. 157.

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