### American Council for an Energy-EfficientEconomy Appliance StandardsAwarenessProject California Energy Commission ConsumerFederation of America

Spencer Abraham Secretary ofEnergy 

### Natural ResourcesDefense Council National ConsumerLaw Center National Grid, USA Northeast EnergyEfficiencyPartnerships NorthwestPower and Conservation Council Pacific Gas & 

### Electric Company Vermont Energy Investment Corporation

June 1,2004

U.S. Department ofEnergy 1000 Independence Avenue SW Washington, DC 20585 Dear Secretary Abraham, We are writing to formally petition DOE to conduct a rulemaking to amend existing minimum efficiency standards for residential refrigerators, refrigerator-freezers, and freezers. As you know, these products are regulated by DOE under the National Appliance Energy Conservation Act (NAECA) of 1987. Initial standards on refrigerators, which were established by Congress and signed by President Reagan, took effect in 1990. DOE subsequently strengthened these standards by 25% effective 1993 and an additional 30% effective 200l. Currently nearly 700 products are being produced and sold that exceed the 2001 standard by 15%, including halfa dozen products that exceed the 2001 standard by 30%.1 We respectfully submit that the existence ofthese products, combined with the other evidence presented in this petition, more thanjustifies the granting ofthis petition and the commencement ofanother round ofrulemaking for refrigerators to amend existing standards. We ask you to begin this rulemaking in Fiscal Year 2005. Petitioners include energy efficiency organizations, environmental organizations, consumer organizations, states and electric utilities. The undersigned organizations have a strong interest inthe establishment ofstrong, cost-effective appliance standards under NAECA, including new standards for residential refrigerators. Appliance energy efficiency standards are the single most effective tool for reducing energy usage while still providing consumers with reliable and affordable energy services. Increasing appliance efficiency levels reduces electricity waste and electricity demand and reduces air pollution and other environmental problems associated with electricity generation,

1 EPA and DOE, ENERGY STAR Qualified Refrigerators, last uploaded April 19, 2004. Available at http :// www.energysta r.govlindex.cfrn ?c=r efrig.pr refrigerators .while providing consumers with the same level ofservice from their appliances. As President Bush's National Energy Policy states, appliance standards "stimulate energy savings that benefit the consumer and reduce fossil fuel consumption, thus reducing air emissions. ,,2 Appliance energy efficiency standards also have important benefits for consumers, including low-income consumers: by reducing electricity usage, standards reduce consumer bills for those who purchase appliances and also help to reduce electricity prices overall by reducing wholesale electricity prices, particularly at times of peak demand. Appliance standards are an importanttool for relieving stress on overloaded electric grids and provide a means for electric utilities to provide least cost service to their customers. Finally, appliance standards assist in ensuring energy security by helping to reduce America's dependence on imported fossil fuels and by reducing electric grid vulnerability. Petitions for Amended Standards Under NAECA Under NAECA, DOE is mandated to conduct two reviews ofstandards on each regulated product. These two reviews have been completed for refrigerators. However, section 32S(n) ofNAECA [42 U.S.C. 

### § 629S(n)] also provides that: Petition for an Amended Standard.-(l) With respect to each covered product described in paragraphs (I) through (II), and in paragraphs (13) and (14) of section 322(a) [refrigerators are in paragraph (I)], any person may petition the Secretary to conduct a rulemaking to determine for a covered product ifthe standards contained either in the last final rule required under subsections (b) through (i) ofthis section [refrigerators are covered under subsection (b)] or in a final rule published underthis section shall be amended. (2) The Secretary shall grant a petition ifhe finds that it contains evidence which, assuming no other evidence were considered, provides an adequate basis for amending the standards under the following criteria- (A) amended standards will result in significant conservation ofenergy; (B) amended standards are technologically feasible; and (C) amended standards are cost effective as described in subsection (0)(2)(B)(i)(II). [This calls for comparing "the savings in operating costs throughout the estimated average life ofthe covered product in the type (or class) compared to any increase in the price of, or in the initial charges for, or maintenance expenses of, the covered products which are likely to result from the imposition ofthe standard"]. The grant ofa petition by the Secretary under this subsection creates no presumption with respect to the Secretary's determination ofany ofthe criteria in a rulemaking underthis section. In this petition, we will show how the three key criteria for a petition are met, and therefore that DOE has no choice but to grant the petition. Furthermore, DOE has just begun a process to set priorities for standards rulemakings in Fiscal Year 

### 2005, and

2 National Energy Policy Development Group, 2001, National Energy Policy. 

### pp. 4-5, Washington, DC: U,S. Government Printing Office.

2

### therefore the timing is justright for adding a new rulemaking into the schedule. In addition, although budgetary issues are irrelevant to the establishment ofamended standards under N

### AECA, we note that DOE should have funds for a new rulemaking as a substantial amount offunds for the standards program are not being spent in Fiscal Year 2004 and are therefore available for Fiscal Year 2005. Congress is likely to provide additional funds for the program in Fiscal Year 2005, including some funds beyond the budget request. In the following sections we discuss each ofthe three key petition criteria in relation to residential refrigerators, refrigerator-freezers, and freezers. Conservation ofEnergy On April 27, 2004, DOE issued a set ofanalyses that it is using to help set rulemaking priorities for the standards program3 

### As part ofthis analysis DOE estimated the energy savings from possible new efficiency standards including the current ENERGY STAR® specification (energy consumption at least 15% less than the current mandatory standard) and higher tiers developed by the Consortium for Energy Efficiency, a group ofutilities, states and non-profit organizations that plan and operate energy-saving programs. In this analysis, DOE found that a new standard at the ENERGY STAR level would save an average of 83 kWh per refrigerator, and that when multiplied by the more than 9 million refrigerators sold annually, would save 2.89 quads ofenergy on a cumulative basis over the 2010-2035 period. 4 

### This level ofsavings is similar to the recent fluorescent ballast final rule 5 

### As part ofthe same analysis, DOE also looked at CEE tier 3 and found that this level of performance would save an average of 166 kWh per refrigerator, resulting in cumulative savings of5.78 quads ofenergy overthe 2010-2035 period6 

### This level ofsavings is similar to DOE's recently completed clothes washer, water heater and central air conditioner rules, 7 

### and similarto the potential savings from the distribution transformer and residential furnace/boiler rulemakings now underway. 8

3 In particular, we refer to "Appendix A: FY2OO5 Technical Support Document" which can be found at http :// www .eere.energy.gov/buildingsia ppliance standardsi2005 priority setting.html

. [Relevant excerpts are included as Attachment 1]. 4 Ibid, P 7-7. j In the Final Rule setting the new ballast standard, DOE states: "The Department concludes that an electronic ballast standard saves a significant amount ofenergy. The energy savings reported in the Department's analysis for an electronic ballast standardbased on the Joint Comments ranged between 1.20 and 2.32 Quads of energy, not including the HVAC effects. The Department considers energy savings within this range to be significant." FederalRegister 65(182), Sept. 19,2000, p. 56745. 6 Appendix A, p. 7-7. See note #3. 7 In the Final Rule setting the clothes washer standard, DOE states: "Next, we considered the two step 1.0411.26 MEF efficiency level, which was proposed in the Joint Comment (Joint Comment, No. 204) [This is the standard ultimately adopted]. This trial standard level, Trial StandardLevel 3, has energy savings of5.52 quads through 2030, a significant amount." FederalRegister 66(9), Jan. 12,2001, p. 3327.

In the Final Rule setting the new water heater standard, DOE states: "Next, we considered trial standard level three [This is the standardultimately adopted]. This trial standard level saves about 4.6 quads of energy, a significant amount." FederalRegister 66(11), Jan. 17,2001, p. 4493.

3

### that we are aware ofthat ENERGY STAR level refrigerators have any maintenance costs in excess ofthose ofnon-ENERGY STAR models. Therefore, maintenance costs do not affect the result ofthis cost-effectiveness analysis. However, it is worth noting that more recent data indicates that the old DOE cost estimates overestimate costs by at least about a factor oftwo, and perhaps by a factor of nine. Specifically, a recent review by the American Council for an Energy-Efficient Economy ofthe Sears website found that ENERGY STAR refrigerators cost an average of about $36 more than otherwise comparable units that are not ENERGY STAR. 13 

### Thus, current incremental costs appear to be nearly halfofwhat DOE estimated in the 1990s. At an incremental cost of$36, an ENERGY STAR refrigerator saving 83 kWh/year will have a simple paybackto the consumer ofabout 5 years at current national average electricity prices. Ifwe revise DOE's net present value analysis to change the incremental cost to $36 but leave all other assumptions the same, thenthe net benefits of this standard increase to $3.2 billion. 14 Furthermore, current costs for ENERGY STAR are for a niche product and not for widespread production. In particular, as shown in Attachment 2, manufacturers are currently charging a large cost premium for ENERGY STAR side-by-side units since these are high-end units for which manufacturers can charge very profitable prices. Past experience shows that when new standards are set, costs are generally much less than what manufacturers and DOE estimate during the standard-setting process. For example, the U.S. Census Bureau, as part ofits annual Census ofManufacturers, collects data on the number ofrefrigerators shipped and the value ofthe shipments. Taking value of shipments and dividing by the number shipped gives average value per unit, including manufacturer costs, markups and profit. In preparation for the 2001 standard, manufacturers made a variety ofproduct changes, primarily in 2000 and 2001. Therefore, the incremental cost at the manufacturer level ofthe new standards can be estimated by comparing value per unit for 1999 (which was $424.96) and 2002 ($427.94). The difference is only $2.98 15 

### Ifwe multiply this by DOE's estimate ofthe markup factor between manufacturer costs and consumer cost (2.07),16 then the real world incremental cost is approximately $6, which is only 12% ofthe $50 average consumer incremental cost estimated by DOE in the rulemaking. 17

13 Details are provided in Attachment 2. 14 Netbenefit calculations were done with DOE's "refrig_std

_nes_20040409" spreadsheet available at http :// www.eere.energy.gov/buildings/a ppliance standards12005 priority setting.html

. Only incremental costs were changed. 15 Details offhis data analysis are provided in Attachment 3. 16 We derive this markup factor by comparing the retail price ofa top mount auto defrost refrigeratorfreezer at the selected standard level from Table 4.1 on p. 4-3 with fhe manufacturer cost ofthis same model from Table 3.5 on p. 3-2. DOE, 1995, Technical SupportDocument: Energy Efficiency Standards for ConsumerProducts: Refrigerators, Refrigerator-Freezers, andFreezers, DOEIEE-0064. Washington, DC DOE. 17 Ibid., Table 5.3.4, p. 5-12.

5

### Ifwe apply this 12% factor to DOE's 1990s estimate ofa $60 incremental cost for the current ENERGY STAR level, then we get an incremental cost ofonly $7, a simple payback ofone yea-, and the net benefits ofsuch a standard increase to $5.6 billion. 18 

### We can apply the same logic to DOE's 1990's estimate ofthe incremental cost ofa unit using 30% less energy than the current standard (e.g

., CEE tier 3). ill 

### the 1990s DOE estimated a $235 incremental cost, but if

### DOE overestimated this cost increase to the same degree it**overestim~ed** 

### the incremental cost ofa unitjust meeting the new standard, then the incremental cmf is only $28 ($235 

## * 12%), the simple payback about two years, and the net benefits ofthe standa-d $10.1 billion. 19 

### In summa-y, even with DOE's very dated and conservative assumptions, the costeff ectiveness test is met by a standard 15% belowthe present one (i.e. , the clUTent ENERGY STAR). But if

### newer daaare used, such as current incremental costs for ENERGY STAR or adjusting the ea-lier DOE estimates in light ofactual experience implementing the 2001 standard, then new refrigerator standards are even more cost-eff ective (e.g. probably more cost-effective than almost any other standard DOE has set). ill 

### short, we have pointed to more than enough evidence to provide an " adequate basis" for dete nnining that amended standards are cost effective, sufficient to require the granting ofthis petition (42 U.S.c. 

### § 6295(n)(2Xc)). Conclusion DOE's own analysis indicates that a newrefrigerator standard will save a significant amount ofenergy, is technologically feasible, and is cost-eff ective. Thus, using DOE's own analysis, the three criteriaunder NAECA for granting a petition for amended standards are met. Furthermore, more recent cost data indicate that a newrefrigerator standard could well be 

### one ofthe most successful standards, with velY large economic benefits and energy savings. Given these findings, we respectfully request that this petition be 

### granted andthat you begin anew mlemaking for refrigerators ald related products in Fiscal Year 2005. Sincerely,

Steven M. Nadel Executive Director American Council for an Energy-Efficient Economy 1001 Connecticut Ave. NW, Suite 801 Waffiington, DC 20036

18 See note #14

. 19 See note #14

.

6

### Andrew L. deLaski Executive Director Appliance Standards Awareness Project 20 Belgrade Ave., Suite 1 Boston, MA 02131

William J. Keese Chairman California Energy Commission 1516 Ninth St. Sacramento, CA 95814

Mel Hall-Crawford Energy Projects Manager Consumer Federation ofAmerica 1424 16 St., Suite 604 Washington, DC 20036

# ~ /.I.

# ~ David B. Goldstein Senior Scientist Katherine Kennedy Senior Attorney Natural Resources Defense Council 71 Stevenson St., Suite 825 San Francisco, CA 94105

7

# }.{\J~~.41-(**}N ~~/**  Charles Harak, Esg. National Consumer Law Center (On behalf ofits low·income clients) 77 Summer Street, 10th 

### floor Boston, MA 02110 617542·8010 (ph) 617542·8028 (fax) 

## charak@nclc.org

Timothy M. Stout Vice President

- Energy Efficiency National Grid, USA 55 Bearfoot Rd

. Northborough, MA 01532

Susan E. Coakley Executive Director Northeast Energy Efficiency Partnerships 5 l\1iJitia Dr. Lexington, MA 02421

Stephen L. 

### C row Executive Director Northwest Power and Conserv ation Council 851 S.W. Sixth Ave

., Suite 1100 Portland, OR 97204

Roland J. 

### Risser Director, Customer Energy Efficiency Pacific Gas and Electric Company P.O. Box 770000 San Francisco, CA 94177

8

### Beth Sachs Executive Director Vennon t Energy Investment Corporation 

### 255 S.Champlain 

## st. Burlington, VI 05401

9

### Attachment l. 

### Refrigerator Section from DOE FY200S 

### Technical Support Document (full document available at: http://www.eere .energy.gov/buildings/appliance standards/200S priority setting.html )

10A7 Refrigerators and Refrigerator-Freezers, Freezers, and Compact Refrigerators
A7.1 Background Refrigerators, refrigerator-freezers, and freezers are major household appliances designed for the refrigerated storage offood products. A refrigerator consists ofa refrigerated cabinet designed for the refrigerated storage offood at temperatures above O°C (32°F) and below 3.9°C (39°F), configured for general refrigerated food storage, and having a source ofrefrigeration requiring single phase, alternating current electric energy input only. A refrigerator may include a compartment for the storage offood at temperatures below O°C (32°F), but does not provide a separate low temperature compartment designed for freezing and storage offood at temperatures below -13.3°C (8°F). A refrigerator-freezer is a cabinet which consists ofat least one compartment designed for the refrigerated storage offood at temperatures above O°C (32°F) and at least one other compartment designed for the freezing·and storage offood at temperatures below -13.3°C (8°F). A freezer consists ofa cabinet for the storage and freezing offoods at
- 17.8°C (O°F) or below. Compact refrigerators are defmed by the DOE as having less than a 7.75 cubic foot capacity and 36 inches or less in height. In 1987, the National Appliance Energy Conservation Act (NAECA) was signed into law establishing minimum energy efficiency standards for refrigerators, refrigerator-freezers, and freezers. For twelve product classes, NAECA specified the maximum allowable energy in kilowatt-hours per year for products manufactured on or after January 1, 1990 (NAECA 1987). Subsequent to the NAECA requirements, a new set ofminimum efficiency standards became effective first in 1993 then again in 2001 (DOE 1997). The new minimum efficiency standards in 1993 eliminated 99 percent ofthe models and increased efficiency by 25 to 30 percent relative to the NAECA requirements. The minimum efficiency standards that became effective on July 1,2001 increase the efficiency ofthe most popular product class, top mount refrigerator-freezers with auto-defrost, by approximately 30 percent relative to the 1993 standards. Table A 7-1 provides background data on the installed base, annual shipments, lifetime, and national annual energy consumption for refrigerator-freezers and freezers. The background data are divided into three categories: standard size refrigerators and refrigerator-freezers, freezers, and compact refrigerators.

7-1Table A7-1: Standard Refrigerator, Freezer, and Compact Refrigerator Background Data

Refrigerator & Annual Shipments,RefrigeratorFreezers

Freezers

Compact Refrigertors quad
Installed Base, millions Annual Shipments, millions Equipment Lifetime, years quad
Installed Base, millions Annual Shipments, millions Equipment Lifetime, years quad 0.86
29 1.49 19 0.14

12 1.40 11 0.04 sed on historical shipments and uipment lifetime of 19 years

ased on installed base and stock annual energy use Based on historical shipments and equipment lifetime of 19 years (Appliance 2004) (DOE 1995) Based on installed base and stock annual energy use Based on historical shipments and equipment lifetime of 19 years (Appliance 2004) E 1995)
annual energy use Installed base, annual shipment, and AEC values are for the year 2002.

A7.2 Product Technology Description and Market Presence Technology for improving refrigerator and freezer performance include: using more efficient compressors, reducing the power consumption offans, using smart defrost technology to minimize the amount ofdefrost that is needed and adding insulation. The saturation ofrefrigerators/refrigerator-freezers was 96 percent in 2001, based on the number ofhouseholds with at least one refrigerator (AHAM 2003). The sales ofcompact refrigerators have increased appreciably in the last several years. While most seem to be sold to residential consumers, significant amounts are also prevalent in non-residential applications such as hotels, dormitories and offices. The Federal Energy Management Program (FEMP), ENERGY STAR®, and the Consortium for Energy Efficiency (CEE) specify voluntary efficiency requirements for refrigerators, refrigerator-freezers, and freezers (FEMP 2004; ENERGY STAR® 2004; CEE 2004). FEMP provides efficiency targets only for standard size refrigerator-freezers. For example, for topmount refrigerator-freezers with auto-defrost, the specified annual energy use reduction target is four percent lower than the current minimum standard. FEMP is in the process ofrevising its purchasing recommendations for refrigerators, in order to be in alignment with ENERGY STAR® specifications. The difference between FEMP and ENERGY STAR® will be that while

7-2ENERGY STAR® specifies an efficiency curve, FEMP divides recommendations into bins based on capacity and reports their recommendations in kWh/year rather than as a percentage increase in efficiency. ENERGY STAR® specifies annual energy use reduction targets of 15, 10, and 20 percent for standard size refrigerator-freezers, freezers, and compact refrigerators respectively. CEE targets only standard-size refrigerator-freezers. CEE specifies three tier levels specifying annual energy use reduction targets of20, 25, and 30 percent relative to current minimum efficiency standards. The market presence ofhigher efficiency refrigerators and freezers can be gauged somewhat by the number refrigerators meeting the ENERGY STAR® specifications and CEE tier levels. The AHAM 2003 Fact Book reports that 25 percent ofsales ofrefrigerator products over 6.5 cu. ft. in capacity meet ENERGY STAR® levels (AHAM 2003). On January 1,2004, the ENERGY STAR® criteria changed for all full size refrigerators (above 7.75 cu. ft in capacity). Fortopmount refrigerator-freezers with volumes between 16.5 to 18.4 cu. ft., 33 models currently meet the ENERGY STAR® criteria. For chest freezers, twelve models currently meet the ENERGY STAR® criteria; however, none were in the 22.5 to 24.4 cu. ft. range. For single-door refrigerators, 23 models currently meet the ENERGY STAR® criteria (ENERGY STAR® 2004). All single-door refrigerator models meeting ENERGY STAR® have volumes less than 7.75 cu.ft., qualifying them as compact refrigerators. According to information compiled by ENERGY STAR®, several refrigerator-freezer models meet the CEE tier levels. Over 50 refrigerator-freezer models lie between the first two CEE tier levels (i.e., energy use of20 to 25 percent lower than existing minimum standards), five models lie between the second and third CEE tier levels (i.e., energy use of25 to 30 percent lower than existing minimum standards), and six models have lower energy consumption than the third CEE tier level (ENERGY STAR® 2004). Tables A7-2 through A7-4 provide the UEC values corresponding to various efficiency levels of standard-size refrigerator-freezers, freezers, and compact refrigerators.

7-3Table A7-2: Standard-Size Refrigerator-Freezer Technology Levels and VEC Values

4842 (DOE 1997) 530 (FEMP2004) 469 (ENERGY STAR® 2004) CEE Tier 1 (20% decrease) 442 (CEE 2004) CEE Tier 2 (25% decrease) 414 (CEE 2004) CEE Tier 3 (30% decrease) 338 (CEE 2004)

VEC values are a shipment-weighted average ofall standard-size refrigerator-freezers. 2 Minimum standard for top- mount refrigerator-freezer with auto defrost, 21.4 cu. ft. adjusted volume. 3 FEMP is in the process ofrevising its purchasing recommendations for refrigerators, in order to be in alignment

with ENERGY STAR® specifications. The difference between FEMP and ENERGY STAR® will be that while ENERGY STAR® specifies an efficiency curve, FEMP divides recommendations into bins based on capacity and reports their recommendations in kWh/year rather than as a percentage increase in efficiency.

Table A7-3: Freezer Technology Levels and VEC Values

1 VEC values are a shipment-weighted average ofall freezers.

Table A7-4: Compact Refrigerator Technology Levels and VEC Values

R® (20% df!rrel!s I VEC values are a shipment-weighted average ofall compact refrigerators. Tables A 7-5 through A 7-7 provide retail price information corresponding to the efficiency levels specified in Tables A 7-2 through A 7-4. Retail price data for typical new standard-size refrigerator-freezers and freezers are provided by AHAM in their 2003 Fact Book (AHAM 2003). A representative retail price for a typical new compact refrigerator was obtained from a retailer website (WalMart 2004). Retail prices are generated for high efficiency levels from the percentage price increases indicated by the price versus efficiency relationships in DOE's 1995 refrigerator Technical Support Document (TSD) (DOE 1995).

7-4Table A7-5: Standard-Size Refrigerator-Freezer Retail Prices

3 (30% decrease) 1 Price vs. efficiency relationship, top-mount refrigerator-freezer with auto-defrost, Table 4.1

Table A7-6 Freezer Retail Prices

Typical New 444 $405 (AHAM2003) ENERGY STAR® (l0% 400 $415 (DOE 1995)1

Price vs. efficiency relationship, chest manual defrost freezer, Table 4.8, baseline to design option 2 efficiency range.

Table A7-7: Compact Refrigerator Retail Prices

Typical New ENERGY STAR® (20% 240

Price vs. efficiency relationship, compact manual defrost refrigerator, Table 4.9.

A7.3 Test Procedure Status
Standard-size refrigerators, refrigerator-freezers, freezers, and compact refrigerators are all covered under the same DOE test procedure. They are tested at an ambient temperature of900P while internal volume temperatures are kept within specified temperature conditions. DOE has recently taken action on a couple ofissues regarding the test procedure. Also, there have been recent actions to improve AHAM's test standard. The National Institute ofStandards and Technology (NIST) has investigated the possibility ofharmonizing the U.S. test procedure with international test standards. All ofthese recent actions are described in more detail below.

7-5Credit for a more efficient defrost system DOE issued a direct final rule, which became effective in May 2003, amending the calculation of the test time period for "long-time" automatic defrost units (DOE 2003). This change gives credit for a control capable ofdetecting frost so that the defrosting occurs other than during a compressor-on cycle, thereby saving energy by taking advantage ofthe natural warming ofthe evaporator during the compressor-offcycle. This revision has no effect on the testing of refrigerators and refrigerator-freezers that do not employ a long-time automatic defrost system. Change in electric refrigerator definition to exclude wine coolers Several manufacturers ofwine coolers requested exemptions from the refrigerator energy efficiency standards. Some wine coolers are made with glass front doors, which make them less energy efficient than standard refrigerators. As a result, the DOE amended the definition of "electric refrigerator", effective December 19,2001, to include a maximum temperature ofthe fresh food storage compartment, and to exclude certain appliances whose physical configuration makes them unsuitable for general storage ofperishable foods. The purpose ofthe revised electric refrigerator definition was to exclude wine coolers from the energy efficiency regulation (DOE 2001). This rule may also affect other compact refrigerators designed to store and cool beverages other than wine. For example, since the time ofthe test procedure revision, a new product has entered the market that is both a compact refrigerator and wine cooler whose performance cannot be rated by the existing test procedure. Repeatability issues for testing compact refrigerators Because ofinconsistencies in test results for compact refrigerators, the National Institute of Standards and Technology (NIST) investigated repeatability and reproducibility issues and published a report entitled "Repeatability ofEnergy Consumption Test Results for Compact Refrigerators". In addition, NIST participated in a task force formed by the Association of Home Appliance Manufacturers (AHAM) to revise their AHAM HRF-1 test procedure. The latest version ofAHAM's test procedure is now AHAM HRF-1, 2003. But the existing DOE test procedure still references an older version ofthe AHAM test procedure, AHAM HRF-1, 1979. DOE may need to amend the test procedure to reference the most recent version of AHAMHRF-l. Harmonizing with international standards NIST has done comparisons between ISO's international test standards and the North American test standard. The two test procedures are similar but not identical. Differences include the ambient temperature at which the refrigerators are tested and the ISO specified test load. There is some interest in harmonizing and unifying the two test procedures by manufacturers intereste( in international trade. Recently, the United States, Canada, and Mexico have harmonized their test procedures.

7-6A7.4 Energy Savings Estimates and Calculations
Table A7-8 presents the energy savings potential for the FEMP, ENERGY STAR®, and CEE efficiency levels specified in Tables A 7-2 through A 7-4. Also provided in Table A 7-8 is the economic benefit or burden to consumers for each efficiency level. Note that only the FEMP and ENERGY STAR® efficiency levels yield an economic benefit to consumers. Consumer national utility bill savings for a given year are derived by taking the national annual energy savings and multiplying it by the corresponding electricity price from the DOE-Energy Information Administration'sAnnualEnergy Outlook2004 (DOE 2004). Consumer national equipment cost increases are derived bytaking the per unit change in equipment cost and mUltiplying it by the annual shipments. Cumulative bill savings and equipment cost increases are summed over the time period 2010-2035 with the net benefit orburden being the difference between the two values. 13

Table A7-8: Refrigerator Potential Energy and Economic Impact Estimates

Standard-Size Refrigerator-Freezers Base Case NA NA FEMP 5 0.77 1.00 ENERGYSTAR® 469 2.89 0.52 CEE Tier 1 442 3.85 -1.28 414 4.82 -4.07 CEE Tier 3 386 5.78 -7.85 Freezers Base Case 444 NA NA ENERGY ST AR® 400 0.38 0.61 Compact Refrigerators Base Case 300 NA NA ENERGY STAR® 240 0.48 0.87

13 Economic calculations are performed with a spreadsheet tool which is available on the DOE Building Technologies Program, Appliances and Commercial Equipment Standards web site. <http://www.eere.energy.gov /buildings/appliance_standards/2005 _priority _setting.html>
7-7A7.S Regulatory Actions and Cumulative Burden

For full line manufacturers ofwhite goods, consideration needs to be given to what other regulatory actions are in effect for other products. Also, refrigerator manufacturers had to recently comply with U

## .s. EPA regulations on the phaseout ofHCFC-141b in 2003, the blowing agent that was used for foam insulation. Any consideration given to updated minimum efficiency requirements needs to account for the effort and cost manufacturers expended for meeting this regulation.

A7.6 Issues Impacting Potential Energy Efficiency Standards
DOE's most recent energy efficiency standards became effective on July 1,2001. This set of standards is the third set ofminimum efficiency requirements that the industry has faced since 1990. The first set ofstandards took effect in 1990 and the second set in 1993. Wine cooler and beverage centers as well as combination refrigeratoribeverage coolers, need definitions and possible test procedures and standards. Compact refrigerators are a fast growing part ofthe overall refrigerator market. Thus, due to their increased national energy consumption, potential energy savings could become greater in the future.

7-8References Appliance Magazine. 2004. "Healthy Times Ahead." January, 2004. Association ofHome Appliance Manufacturers (AHAM). 1996. Data on compact refrigerators. Chicago, IL. Association ofHome Appliance Manufacturers (AHAM). 2003. "Fact Book 2003." Chicago, IL. Consortium for Energy Efficiency (CEE). 2004. www.ceel.org ENERGY STAR®. 2004. www.energystar.gov Federal Energy Management Program (FEMP). 2004. http://www.eere.energy.gov/femp/technologies/eeproducts.cfm National Appliance Energy Conservation Act (NAECA), 1987, Pub. L. 100-12 U.S. Department ofEnergy (DOE)-Office ofCodes and Standards, 1995. "Technical Support Document: Energy Efficiency Standards for Consumer Products: Refrigerators, RefrigeratorFreezers, & Freezers ." Washington, DC. DOE/EE-0064. U.S. Department ofEnergy (DOE)-Office ofEnergy Efficiency and Renewable Energy. 1997. "Energy Conservation Program for Consumer Products: Energy Conservation Standards for Refrigerators, Refrigerator-Freezers and Freezers; Final Rule." Federal Register 62 (81): 23102- 23116. U.S. Department ofEnergy (DOE)-Office ofEnergy Efficiency and Renewable Energy. 2001. "Energy Conservation Program for Consumer Products: Amendment to the Defmition ofElectric Refrigerator; Final Rule." Federal Register 66 (223): 57845-57848. U.S. Department ofEnergy (DOE)-Office ofEnergy Efficiency and Renewable Energy. 2003, "Energy Conservation Program for Consumer Products: Test Procedure for Refrigerators and Refrigerator-Freezers; Direct Final Rule." Federal Register 68 (45): 10957-10961. U.S. Department ofEnergy (DOE), Energy Information Administration. 2004. "Annual Energy Outlook 2004 with projections to 2025." Washington, DC. DOEIEIA-0383(2004). January 2004. WaIMart.2004. Retail price for a Haier 4.2 cu.ft. compact refrigerator. March,2004. www.walmart.com

7-9Attachment 2 Incremental Cost of ENERGY STAR Refrigerators May 2004 , not ENERGY STAR ENERGY STAR Volume Brand Color Type (cu. Ft.) other features Model Price Model Price Kenmore White Top freezer 20.6 icemaker 73092 $ 650.00 74172 $ 650.00 Kenmore White Top freezer 20.6 icemaker 74162 $ 630.00 74172 $ 650.00 Kenmore White Top freezer 20.6 63092 $ 600.00 64172 $ 600.00 Kenmore White Top freezer 20.6 64152 $ 580.00 64172 $ 600.00 Kenmore White Top freezer 18.3 63892 $ 550.00 64882 $ 550.00 GE White Top freezer 17.9 GTS18KBP\/\'w $ 600.00 GTH18JBR\/\,W $ 580.00 GE White Top freezer 14.9 GTR 15BBR\/\,W $ 510.00 GTH15BBR\/\,W $ 550.00 Top freezer Average Kenmore White Side by side 21.9 54242 $ 1,000.00 55582 $ 1,120.00

Kenmore White Side by side 25.4 54542 $ 1,050.00 54582 $ 1,170.00 GE White Side by side 22 thru-door ice & water GSS22KGP\/\'w $ 1,150.00 GSH22KGPI/IIIIIJ $ 1,200.00 GE White Side by side 25 thru-door ice & water GSS25JFPVWV $ 1,050.00 GSH25VGRWVV $ 1,250.00 Frigidaire White Side by side 22.6 thru-door ice & water FRS23KF5CW $ 900.00 FRS23KF6CW $ 1,000.00 Side by side Average Amana White Bottom freezer 21.9 IARB2217CW $ 1.250.00 IABB2227DEW $ 1.250.00 I Bottom freezer Average General notes for ACEEE analysis: PriceIJ.. $20.00 $20.00 ·20 $40.00 $8.57 $120.00
$120.00 $50.00 $200.00 $100.00 $118.00

$0 %IJ.. Notes 0% 3% ES model loses the wineJbeverage rack 0% 3% 0% -3% ES model adds "NeverClean" condenser, Deluxe Quiet Design 8% ES model adds"FrostGuard"
12"k ES model has many trademarked names associated with it (e.g. "America's Quietest sound package", "Acceler-Ice ice production") 11% ES model has many trademarked names associated with it (e.g. "America's Quietest sound package", "Acceler-Ice ice production") 4% Identical features, except for ENERGY STAR 19% 11% ES model adds crisper light & water filter indicator light ES model has many trademarked names (e.g., "Temp-Assure 0% freshness control", "SofSound I Quiet package", "Fresh Nest egg storage")

As the source of pricing, we used http://.lvww.sears.com/duringthe May 20-21, 2004 period. This has the advantage of being "real world" pricing, not as inflated as MSRP. We used "Regular" prices and ignored sale prices, discounts, and coupons, mostly because the discounts were variously time dependant (so doing the research the next day WOUld, literally, have resulted in different price points.) The market shares used below are from DOE 1995 TSD p. 8-4. We use the single-family home column and exclude compact manual defrost units in calculating market shares.
Average cost of ENERGY Type STAR Weight Top freezer $8.57 73% $6.26 Side by side $118.00 25% $29.50 Bottom freezer $0 2% $0.00 $35.76 WeightedAverage

6/1/04 ENERGY STAR refrigerator costs

### Attachment 3 Household Refrigerator Shipments and Costs From Census ofManufacturers -- MA335F (Major Household Appliances) Change relative to: Previous Year Quantity Value Value/unit 1997 year 1997 12,092.4 $5,272.4 $436.01 $0.00 NA 1998 11,279.0 5,035.6 446.46 10.45 $10.45 1999 11,692.5 4,968.8 424.96 -11.05 -21.50 2000 12,354.7 5,395.8 436.74 0.73 11.78 2001 11,776.4 5,227.1 443.86 7.85 7.12 2002 12,067.9 5,164.3 427.94 -8.07 -15.93 Data are compiled by the Bureau ofthe Census and are available at: http://www.census.gov/ciriwww/335/ma335f.html

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