1 | Building Technologies Program eere.energy.gov

The Parker Ranch installation in Hawaii

BUILDING TECHNOLOGIES PROGRAM

Energy Conservation Program for Appliance 

Standards:

 

SNOPR Public Meeting for Microwave Ovens

March 14, 2012

Wes Anderson

Department of Energy

Energy Efficiency & Renewable Energy
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Introduction

Purpose of the Public Meeting

 To present revised methodologies based on stakeholder feedback, 

and characterize results for analyses

 To discuss specific issues related to each analysis

 To seek input from attendees on methodologies, assumptions and 

data sources

 To describe remaining steps before issuance of Final Rule
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Introduction

DOE welcomes comments, data, and information concerning its 

analysis on microwave ovens. Throughout this presentation, issues 

that correspond to issues raised in DOE’s published material from this 

analysis are raised for discussion in boxes like this one. Nonetheless, 

comments are welcome on any part of DOE’s analysis.

Issues for Comment
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Introduction

NOPR

SNOPR

(Standby

Power)

 Framework Document made available by DOE on March 15, 2006. (71 FR 15059)

 ANOPR issued by DOE on November 15, 2007 (72 FR 64432) (ANOPR Public 

Meeting on December 13, 2007)

 NOPR issued by DOE on October 17, 2008 (73 FR 62034) (NOPR Public Meeting 

on November 13, 2008). Comments from stakeholders led DOE to continue 

rulemaking for microwave oven standby power.

 Final Rule issued by DOE on April 8, 2009 addressing cooking efficiency 

standards. (74 FR 16040) DOE determined that new cooking efficiency 

standards for microwave ovens were not justified.

Steps in the Microwave Oven Energy Conservation Standards 

Rulemaking

Final

 Rule (Cooking

Efficiency)

ANOPR Framework

Document

Final

 Rule (Standby

Power)
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Introduction

Purpose of the SNOPR

 The October 2008 NOPR analyzed microwave standby power as a measure of 

energy consumption separate from cooking efficiency, and proposed new 

prescriptive standards for standby power.

 DOE received comments that it should consider an updated version of the 

international standby power standard (International Electrotechnical 

Commission (IEC) 62301), which was expected shortly.

 Therefore, the rulemaking for microwave oven standby power was continued 

rather than included in the April 2009 Final Rule to allow DOE to consider IEC 

62301 Second Edition

• EPCA’s statutory requirement to consider the “most current version”

• International harmonization

 The SNOPR analysis also addresses comments on other topics received on the 

NOPR.

 This SNOPR presents the revised analysis and proposes new standard levels 

for comment.
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Introduction

 SNOPR for microwave oven standby power issued by DOE on January 31, 2012 

(SNOPR Public Meeting today, March 14, 2012)

 Comments on SNOPR from interested parties

• Transcript records oral comments from today’s public meeting

• Written comments (comment period closes April 16, 2012)

 DOE reviews and considers all comments submitted on a timely basis.

 Final Rule Publication

• In accordance with EPCA, as amended by EISA 2007.

SNOPR Schedule
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Introduction

Test Procedure

 DOE published an interim final rule for the microwave oven test 

procedure on March 9, 2011, to incorporate measures of standby 

mode and off mode energy use.

 The test procedure amendments are based on IEC 62301 First Edition, 

which was the most current at the time that the interim final rule was 

finalized.

• IEC Standard 62301 Second Edition published on January 27, 2011.

 DOE received comments on the interim final rule supporting the 

incorporation by reference of the second edition.

 DOE published an SNOPR on November 23, 2011, to propose 

amendments based on IEC 62301 Second Edition and to address 

covered products.

• DOE is currently considering comments received.
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Proposed Amended Energy Conservation Standards for Microwave 

Oven Standby Power (TSL 3)

Proposed Standards

 The compliance date of these standards would be three years from 

the publication of the final rule.

DOE invites comments on these newly proposed energy 

conservation standards.

Product Class

Proposed Energy 

Conservation Standards

Microwave-Only Ovens and Countertop 

Combination Microwave Ovens

Maximum Standby Power = 1.0 

watt

Built-In and Over-the-Range Combination 

Microwave Ovens

Maximum Standby Power = 2.2 

watts
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Opening Remarks and Comments from Interested

Parties on the Proposed Energy Conservation Standards 

At this time, DOE welcomes opening remarks from interested 

parties on the SNOPR for microwave oven standby power.
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The SNOPR analyses consist of revisions to the NOPR analyses.

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups to 

Determine

Product

Price

Life-Cycle

Cost and

Payback 

Period Analyses

Market & 

Technology 

Assessment

Proposed 

Standard 

Levels

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

NOPR

Analysis

Trial 

Standard 

Levels

Regulatory

Impact 

Analysis

SNOPR Analyses Flow Diagram
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Market Assessment

SNOPR Updates: Product Classes

 DOE divides covered products into classes by: 

• the type of energy used,

• capacity, or 

• other performance-related features that affect consumer utility and efficiency.

 DOE defines a microwave oven as follows:

“A class of kitchen ranges/ovens which is a household cooking appliance consisting 

of a compartment designed to cook or heat food by means of microwave energy.”

 In the 2008 NOPR, DOE proposed a single product class 

encompassing microwave ovens with and without browning (thermal) 

elements, 

• Did not include microwave ovens incorporating convection systems 

(“combination microwave ovens”).

 In response to comments, DOE reassessed the covered products.

• Determined that combination microwave ovens would also be considered 

covered products under the regulatory definition because they are capable of 

cooking or heating food by means of microwave energy.
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Market Assessment

Product Classes

 DOE investigated whether there are any performance related features 

that would justify separate energy conservation standards based on:

• Microwave-only vs. Combination

• Configuration:

Countertop Built-In Over-the-Range
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Market Assessment

Product Classes: Microwave-Only Over-the-Range vs. 

Countertop

 DOE conducted a survey of over-the-range microwave-only units 

available on the U.S. market.

• Display technologies used are similar to those used in countertop microwaveonly units (i.e., LED displays, LCDs, and VFDs).

• In-store standby mode testing on a limited sample of over-the-range microwaveonly units showed similar standby power consumption as countertop microwaveonly units.

 DOE tentatively concludes that over-the-range microwave-only units 

would not warrant a separate product class from microwave-only 

countertop units.

• May have additional components that are energized during active mode 

operation.

• However, DOE’s testing showed that the presence of such features did not 

increase the standby power consumption.
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Market Assessment

Product Classes: Countertop Combination vs. 

Microwave-Only

 DOE also conducted standby power testing on a sample of 13 

representative combination microwave ovens. 

 Countertop Combination Microwave Ovens:

• Use similar display technologies as countertop microwave-only units. 

• Standby power consumption ranging from 1.2 W to 4.7 W, similar to the 

standby power consumption for countertop microwave-only units.

 DOE tentatively concludes that countertop combination microwave 

ovens would not warrant a product class separate from microwaveonly ovens.
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Market Assessment

Product Classes: Built-In and Over-the-Range 

Combination 

 DOE testing showed standby power consumption for these products 

ranged from 4.1 W to 8.8 W, higher than the standby power 

consumption for other microwave oven product types.

 DOE’s reverse-engineering analysis suggests that additional features 

for these products are required to handle the thermal loads 

associated with their installation and to provide consumer utility.

 Require a significant number of additional relays on the control board 

and thus require a larger power supply for the control of such relays.
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Market Assessment

Product Classes

 DOE believes that a separate product class should be established for 

built-in and over-the-range combination microwave ovens.

Product Class

1. Microwave-Only Ovens and Countertop Combination Microwave Ovens

2. Built-in and Over-the-Range Combination Microwave Ovens

Issue 7: DOE requests information on any utility or performance 

impacts to built-ins at the standard level proposed by DOE.
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Technology Assessment

SNOPR Updates: Operating Modes

 The DOE test procedure, as amended in the interim final rule, 

provides definitions for standby mode and off mode in microwave 

ovens :

• “Standby mode means any mode in which a ... microwave oven is 

connected to a mains power source and offers one or more of the 

following user-oriented or protective functions which may persist for an 

indefinite time:

– To facilitate the activation of other modes (including activation or 

deactivation of active mode) by remote switch (including remote control), 

internal sensor, or timer;

– Continuous functions, including information or status displays (including 

clocks) or sensor-based functions. A timer is a continuous clock function 

(which may or may not be associated with a display) that allows for 

regularly scheduled tasks and that operates on a continuous basis.”

• “Off mode means a mode in which a ... microwave oven is connected 

to a mains power source and is not providing any active mode or 

standby mode function and where the mode may persist for an 

indefinite time. An indicator that only shows the user that the product is 

in the off position is included within the classification of an off mode.”
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Technology Assessment

Operating Modes

 In the NOPR, DOE noted that it observed no microwave ovens in its 

test sample that were capable of operation in off mode, and further 

that its research suggested that no microwave ovens available in the 

United States are capable of off mode operation.

 DOE received no comments or data indicating that microwave ovens 

with an off mode are currently available or expected to become 

available on the U.S. market.

 DOE investigated the potential for microwave ovens with an on/off 

switch to operate in off mode.

• Such units would be capable of off mode.

• Zero energy would be consumed in off mode.

 DOE did not propose in the SNOPR standards for off mode because 

there would be no benefit associate with such a standard.

Issue 1: DOE requests input and data regarding off mode power for 

microwave ovens.
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19

Technology Assessment

SNOPR Updates: Technology Options

 In the NOPR, DOE identified features which affect standby power:

• Cooking sensors;

• Display technologies; and

• Control strategies and associated control boards, including a function to 

turn off power to components during standby mode.

 Additional testing showed that standby power characteristics for 

countertop combination microwave ovens and over-the-range 

microwave-only units are similar to that of countertop microwave-only 

units.

 Tests on over-the-range combination microwave ovens showed that 

standby power for these products also depend largely on the features 

listed above.
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Technology Assessment

Technology Options: Cooking Sensors

 DOE noted in the NOPR that zero-standby power piezoelectric steam 

sensors were available in microwave ovens in the U.S. market, and 

that other sensors (infrared, weight, relative humidity sensors) had 

either been applied in microwave ovens sold elsewhere or had been 

identified as feasible for these applications.

 Commenters raised concerns about:

• Availability, reliability, and accuracy;

• Intellectual property issues.

 DOE conducted additional research, and notes:

• Alternate sensor technologies have been available on the market 

internationally for years.

• It is not aware of data showing that these sensors would have reliability 

and accuracy significantly different than the absolute humidity sensors 

commonly employed in U.S. microwave ovens.

• It is not aware of any intellectual or patent infringement issues for any 

of the above-listed sensors.
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Technology Assessment

Technology Options: Display Technologies

 DOE identified three display technologies for microwave ovens:

• Light-emitting diode (LED) displays

• Liquid crystal displays (LCDs) with and without backlighting

• Vacuum fluorescent displays (VFDs)

 Commenters submitted information on the utility of display technologies:

• Reliability in higher-heat installations, such as over-the-range;

• Viewing angle and visibility;

• Availability of sizes and colors demanded by consumers of higher-end products and 

which allow manufacturers to provide a consistent appearance among products in a 

suite.

 Additional DOE research indicates:

• Each display technology is currently incorporated in multiple over-the-range models.

• Temperature ratings for the three types of displays are comparable.

• Each display technology offers acceptable brightness, viewing angle, and ability to 

display complex characters in both countertop and over-the-range microwave ovens.

• No microwave oven display had intermittent backlighting or other features that lessen 

utility.

 DOE continues to believe that all display technologies can be integrated in 

countertop and over-the-range microwave ovens with no loss of utility.
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Issue 2: DOE requests input and data on the utility provided by specific 

features that contribute to microwave oven standby power. In 

particular, DOE seeks information on the utility of display 

technologies, as well as on cooking sensors that do not 

require standby power.

Issue for Public Comment
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Technology Assessment

Technology Options: Power Supply and Control Boards

 DOE determined for the NOPR that switching power supplies could 

improve standby power by increasing power supply and control board 

efficiency.

• Up to 75-percent conversion efficiency with 0.2 W or less standby power.

• DOE believed such power supplies were unproven in long-term microwave oven 

applications.

 Additional DOE research indicates:

• Switching power supplies are found in many consumer products and appliances, 

suggesting adequate reliability and durability.

• No data suggests that reliability is significantly worse than conventional linear 

power supplies over the lifetime of a microwave oven.

• While switching power supplies in other consumer applications may achieve 92-

percent efficiency, DOE is unaware of any switching power supplies suitable for 

application in microwave ovens that exceed 75-percent efficiency.

 DOE observed switching power supplies in certain combination 

microwave ovens in its recent test sample.
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Technology Assessment

Technology Options: Automatic Power-Down

 Automatic power-down allows manufacturers to make design tradeoffs 

between incorporating standby power-consuming features (such as 

displays or cooking sensors) and including a function to cut power to 

those components during standby mode.

 Commenters requested DOE consider a user-activated control to turn 

off the display.

• With the display switched off, the microwave oven would be in off mode 

unless other features associated with standby mode remain energized.

• DOE is not aware of any products incorporating such a user-activated 

control.

• DOE also does not have information on how often consumers might 

make use of this feature.

• Although DOE is unable to consider user-activated controls for turning 

off the display as a design feature, manufacturers are not precluded by 

the proposed standards from incorporating it in their products.
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Issue 3: DOE requests input and data on control strategies available to 

enable manufacturers to make design tradeoffs between 

incorporating standby-power-consuming features such as 

displays or cooking sensors and including a function to turn 

power off to these components during standby mode. DOE 

also seeks comment on the viability and cost of microwave 

oven control board circuitry that could accommodate 

transistors to switch off cooking sensors and displays.

Issue 4: Whether switching or similar modern power supplies can 

operate successfully inside a microwave oven and the 

associated efficiency impacts on standby power.

Issues for Public Comment
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Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups to 

Determine

Product

Price

Life-Cycle

Cost and

Payback 

Period Analyses

Market & 

Technology 

Assessment

Proposed 

Standard 

Levels

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

NOPR

Analysis

Trial 

Standard 

Levels

Regulatory

Impact 

Analysis

SNOPR Analyses Flow Diagram
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Engineering Analysis

Standby Power Levels – Product Class 1

 For the NOPR, DOE established the following standby power levels 

for analysis: 

 DOE believes that the TSLs and associated analyses are still valid for 

product class 1.

Standby Power

Level (TSL) Source

Standby 

Power (W)

Baseline Baseline 4.0

1 FEMP Procurement Efficiency Recommendation 2.0

2 Gap Fill 1.5

3 IEA 1-Watt Program 1.0

4 Max Tech 0.02
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Engineering Analysis

Standby Power Levels – Product Class 2

 For the SNOPR, DOE reverse-engineered a representative sample of 

built-in and over-the-range combination microwave ovens.

• Analyzed the various components that contribute to the standby power 

consumption. 

• Measured standby power consumption of individual components.

Standby Power

Level (TSL) Description

Standby 

Power (W)

Baseline Baseline 4.5

1 Zero-standby cooking sensor 3.7

2 Switch mode power supply 2.7

3

Solid state relays and optimized switch mode 

power supply 2.2

4 Max Tech – automatic power down 0.04
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Engineering Analysis

Incremental Manufacturing Costs – Product Class 1

 DOE believes the standby power levels and corresponding 

incremental manufacturing costs presented in the NOPR remain 

fundamentally valid for product class 1.

 Scaled incremental costs to 2010$ using the Producer Price Index.

Standby 

Power Level Standby Power (W) Incremental Cost (2010$)

Baseline 4.0 N/A

1 2.0 $0.27

2 1.5 $0.60

3 1.0 $1.31

4 0.02 $4.58
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Engineering Analysis

Incremental Manufacturing Costs – Product Class 2

 To evaluate the built-in and over-the-range combination microwave 

oven product class, DOE conducted analyses on a test sample of 13 

combination microwave ovens.

• Product teardowns

• Control board cost analyses

 DOE estimated the cost associated with each standby power level by 

using quotes from various component suppliers to determine the cost 

of the components used in each design option.

Standby 

Power Level Standby Power (W) Incremental Cost (2010$)

Baseline 4.5 N/A

1 3.7 $0.00

2 2.7 $2.29

3 2.2 $9.44

4 0.04 $5.18
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Issue 5: DOE requests input and data on the estimated incremental 

manufacturing costs, as well as the assumed approaches to 

achieve TSL 3 for microwave oven standby mode and off 

mode. DOE also seeks comment on whether any intellectual 

property or patent infringement issues are associated with the 

design options considered in the analyses.

Issue for Public Comment
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Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups to 

Determine

Product

Price

Life-Cycle

Cost and

Payback 

Period Analyses

Market & 

Technology 

Assessment

Proposed 

Standard 

Levels

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

NOPR

Analysis

Trial 

Standard 

Levels

Regulatory

Impact 

Analysis

SNOPR Analyses Flow Diagram
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Life-Cycle Cost and Payback Period 

Analysis

LCC and PBP Analysis Inputs Update

Inputs October 2008 NOPR Changes for the SNOPR

Affecting Installed Costs

Product Cost Derived by multiplying manufacturer cost by manufacturer, distributor 

markups and sales tax.

Used experience curve fits to forecast a price 

scaling index to forecast product prices.

Affecting Operating Costs

Annual Energy Use Annual energy use determined from the annual usage (average daily 

use cycles).

No change

Energy Prices Electricity: Updated using EIA’s 2006 Form 861 data.

Variability: Regional energy prices determined for 13 regions.

Electricity: Updated using EIA’s 2009 Form 

861 data.

Variability: No change.

Energy Price 

Trends

Energy: Forecasts updated with EIA’s Annual Energy Outlook 2008 

(AEO 2008).

Reference Case, High Growth, and Low 

Growth forecasts updated with EIA’s AEO 

2010 May Release.

Repair and 

Maintenance Costs

Assumed no repair or maintenance costs. No change

Affecting Present Value of Annual Operating Cost Savings

Product Lifetime Developed a Weibull probability distribution based on an average 

lifetime of 9 years.

No change

Discount Rates Average value: 4.8%. Variability: Characterized using Weibull

probability distributions.

No change

Affecting Installed and Operating Costs

Effective Date of 

New Standard

2012 2014
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Base and Standards Case Efficiency Distributions

Life-Cycle Cost and Payback Period 

Analysis

 LCC and PBP analysis typically analyzes standard levels relative 

to a baseline efficiency level

 Not all consumers purchase products at baseline levels

• Must account for consumers purchasing more efficient products to 

accurately estimate consumer economic impacts

 Base-Case efficiency distributions define the percentage of products 

being purchased at various efficiency levels

• Consumers already purchasing products at efficiencies greater than or 

equal to a prospective standard level are not impacted by the standard

 Base-Case Efficiency Distributions

• Determined from tests conducted on 52 units by DOE and AHAM.

 Standards-Case Efficiency Distributions

• Applied a “roll-up” approach to estimate the distribution for each standards 

case.
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Life-Cycle Cost and Payback Period 

Analysis

Base and Standards Case Efficiency Distributions

 DOE maintained the shipments-weighted standby power and annual 

energy use shown in the following tables throughout the forecast 

period, 2014–2043. 

Microwave and Countertop Combination Ovens: Standby Energy Consumption Distributions in 

2014 for Base and Standards Cases

Stand-by 

Power (W)

Annual Energy Use 

(kWh/yr)

Market Share (%)

Base 

Case

Standby Power Level

1 2 3 4

4.00 34.8 46%

2.00 17.4 35% 81%

1.50 13.0 19% 19% 100%

1.00 8.69 0% 0% 0% 100%

0.02 0.17 0% 0% 0% 0% 100%

Shipments Weighted Standby Power 2.83 1.90 1.50 1.00 0.02

Shipments Weighted Annual Energy Use 24.6 16.5 13.0 8.7 0.17
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Life-Cycle Cost and Payback Period 

Analysis

Base and Standards Case Efficiency Distributions

 DOE maintained the shipments-weighted standby power and annual 

energy use shown in the following tables throughout the forecast 

period, 2014–2043. 

Over the Range Combination Ovens: Standby Energy Consumption Distributions in 2014 for 

Base and Standards Cases

Stand-by 

Power (W)

Annual Energy Use 

(kWh/yr)

Market Share (%)

Base Case

Standby Power Level

1 2 3 4

4.50 39.1 100%

3.70 32.1 0% 100%

2.70 23.5 0% 0% 100%

2.20 19.1 0% 0% 0% 100%

0.04 0.35 0% 0% 0% 0% 100%

Shipments Weighted Standby Power 4.50 3.70 2.70 2.20 0.04

Shipments Weighted Annual Energy Use 39.1 32.1 23.5 19.1 0.35
37 | Building Technologies Program eere.energy.gov

Issue 6: DOE requests input and data on the estimated market share of 

microwave ovens at the standby power consumption 

stipulated by the proposed standards (1.0 W for countertop; 

2.2 W for combination)

Issue for Public Comment
38 | Building Technologies Program eere.energy.gov

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups to 

Determine

Product

Price

Life-Cycle

Cost and

Payback 

Period Analyses

Market & 

Technology 

Assessment

Proposed 

Standard 

Levels

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

NOPR

Analysis

Trial 

Standard 

Levels

Regulatory

Impact 

Analysis

SNOPR Analyses Flow Diagram
39 | Building Technologies Program eere.energy.gov

Shipments Analysis

Inputs 2008 NOPR Description Changes for the SNOPR 

Number of 

Product Classes

One product class. Market share data 

provided by AHAM.

Two product classes: (1) all microwave ovenonly and countertop microwave ovencombination; (2) over-the-range microwave 

oven-combination. Market share data 

provided by AHAM; 99% product class #1 and 

1% product class #2. Product class market 

shares held constant over forecast period.

New 

Construction 

Shipments

Housing forecasts updated with EIA 

AEO 2009 April release forecasts for 

the Reference case, High growth case, 

and Low growth case. 

No change in approach. Housing forecasts 

updated with EIA AEO 2010 forecasts for the 

Reference case, High growth case, and Low 

growth case. 

Replacements Determined by tracking total product 

stock by vintage and establishing the 

failure of the stock using retirement 

functions from the LCC and PBP 

analysis. Retirement functions revised 

to be based on Weibull lifetime 

distributions.

No change. 

 Shipments Analysis Inputs 1 through 3
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Shipments Analysis

Inputs 2008 NOPR Description Changes for the 

SNOPR 

Historical Shipments Data sources include AHAM data submittal and 

Appliance magazine.

No change.

Purchase Price, 

Operating Cost, and 

Household Income 

Impacts due to 

Efficiency Standards

Developed “relative price” elasticity, which accounts 

for the purchase price and the present value of 

operating cost savings divided by household 

income. Used purchase price and efficiency data 

specific to residential refrigerators, clothes 

washers, and dishwashers between 1980 and 2002 

to determine a “relative price” elasticity of demand 

of -0.34. 

No change.

Fuel Switching Not considered. No change.

 Shipments Analysis Inputs 4 through 6
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Inputs 2008 NOPR Description Changes for the SNOPR 

Base-Case 

Forecasted 

Efficiencies

Shipment-weighted efficiency (SWEF) 

determined in 2005. SWEF held constant 

over forecast period. 

No change. 

Standards-Case 

Forecasted 

Efficiencies

Analyzed as one product class. Roll-up 

scenario used for determining SWEF in 

the year that standards become effective 

for each standards case. SWEF held 

constant over forecast period. 

Analyzed as two product classes. 

Roll-up scenario used for determining 

SWEF in the year that standards 

become effective for each standards 

case. SWEF held constant over 

forecast period.

Annual Energy 

Consumption per 

Unit

Annual weighted-average values as a 

function of SWEF. 

No change.

Total Installed Cost 

per Unit

Annual weighted-average values as a 

function of SWEF. 

Incorporated learning rate to forecast 

product prices.

Energy Cost per Unit Annual weighted-average values as a 

function of the annual energy 

consumption per unit and energy prices. 

No change.

Impact Analyses

 NIA inputs 1 through 5; NIA generates necessary outputs for utility, 

environmental, employment, and regulatory impact analyses
42 | Building Technologies Program eere.energy.gov

Inputs 2008 NOPR Description Changes for the SNOPR 

Repair Cost and 

Maintenance Cost 

per Unit

Assumed no increase in repair and 

maintenance costs as a function of 

standby power.

No change.

Escalation of Energy 

Prices

AEO 2008 forecasts (to 2030); 

extrapolated to 2042.

Updated to AEO 2010 May release 

forecasts (to 2035); extrapolated to 

2043.

Energy Site-toSource ConversionConversion varies yearly and is generated 

by DOE/EIA’s NEMS program (a timeseries conversion factor; includes electric 

generation, transmission, and distribution 

losses).

No change.

Discount Rate 3 and 7 percent real. No change.

Present Year Future expenses discounted to 2007. Future expenses discounted to 2011.

Impact Analyses

 NIA inputs 6 through 10; NIA generates necessary outputs for utility, 

environmental, employment, and regulatory impact analyses
43 | Building Technologies Program eere.energy.gov

Trial Standard Levels

Trial Standard 

Level

Standby Power (W)

Product Class 1: MicrowaveOnly and Countertop 

Combination

Product Class 2: Built-In and 

Over-the-Range Combination

1 2.00 3.70

2 1.50 2.70

3 1.00 2.20

4 0.02 0.04

 The TSLs analyzed are equivalent to the standby power levels
44 | Building Technologies Program eere.energy.gov

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups to 

Determine

Product

Price

Life-Cycle

Cost and

Payback 

Period Analyses

Market & 

Technology 

Assessment

Proposed 

Standard 

Levels

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

NOPR

Analysis

Trial 

Standard 

Levels

Regulatory

Impact 

Analysis

SNOPR Analyses Flow Diagram
45 | Building Technologies Program eere.energy.gov

Manufacturer Impact Analysis

SNOPR Updates

 DOE updated the MIA results based on several changes to other 

analyses that impact the MIA:

• Engineering Analysis - Updated manufacturing production costs 

(MPCs) for Product Class 1, new MPCs for Product Class 2, and all 

costs converted to 2010$. 

• NIA - Updated total shipments and efficiency distributions, used a new 

analysis period (2014-2043) and base year (2011), and incorporated 

price trends into the analysis;

 DOE also updated the conversion costs

• To segment total product and capital conversion costs between Product 

Class 1 and Product Class 2, DOE used the same split between these 

two product classes as used in the NIA

• DOE used the same per-platform costs at each standby power level for 

both product classes, but converted these product and capital 

conversion costs to 2010$ using the PPI.
46 | Building Technologies Program eere.energy.gov

Manufacturer Impact Analysis

Summary of Results at the Proposed Standards Level

 At TSL 3, the impacts on INPV range from approximately -$52.9 million 

to -$73.6 million (a change in INPV of -4.7 percent to -6.5 percent).

• Base case industry value is estimated to be $1.1 billion in $2010. 

• The required conversion costs are estimated to be $94.7 million at TSL 

3. As an indication of the magnitude of these conversion costs, industry 

cash flow decreases by approximately 29.9 percent, to $59.0 million, 

compared to the base-case value of $84.2 in the year before the 

compliance date of the standard. 

• The incremental MPCs at TSL 3 are estimated to be $1.31 for Product 

Class 1 and $9.44 for Product Class 2. The range of the impacts on 

INPV and cash flow at TSL 3 varies depending on the ability of 

manufacturers to pass on these increases in MPCs to their customers. 

 The vast majority of microwave ovens are imported and the 

employment impacts in the GRIM are small.
47 | Building Technologies Program eere.energy.gov

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups to 

Determine

Product

Price

Life-Cycle

Cost and

Payback 

Period Analyses

Market & 

Technology 

Assessment

Proposed 

Standard 

Levels

Employment 

Impact 

Analysis

Utility & 

Environmental Impact 

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Revise

NOPR

Analysis

Trial 

Standard 

Levels

Regulatory

Impact 

Analysis

SNOPR Analyses Flow Diagram
48 | Building Technologies Program eere.energy.gov

Proposed Standards

 DOE considered four TSLs for standby power, beginning with 

the most efficient level (TSL 4) and worked down to a level 

where the benefits of potential standards outweighed the 

burdens.

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

savings, economic gain, and emissions reductions would be 

outweighed by the potential economic burden on consumers from loss 

of product utility and the large capital conversion costs that would result 

in a reduction in INPV for manufacturers.

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

energy and is technologically feasible and economically justified.

Selection of Proposed Standard
49 | Building Technologies Program eere.energy.gov

Proposed Standards

Microwave-Only 

and Countertop 

Combination 

Ovens

Built-In and Overthe-Range 

Combination 

Ovens

Proposed standard level 3 3

National Energy Savings (quads) 0.41 0.01

Net Present Value 

(2010$ billion)

3% discount rate 3.58 0.02

7% discount rate 1.81 0.01

Industry Net 

Present Value

2010$ million 1031.6 to 1050.6 22.3 to 23.9

% change (6.5) to (4.8) (7.1) to (0.3)
50 | Building Technologies Program eere.energy.gov

Closing

How to Submit Comments...

 Public Meeting – oral comments will be captured in the transcript and become 

part of the public record.

 Written comments – Reference docket #: EERE-2011-BT-STD-0048 and/or 

RIN #: 1904-AC07

Email: MWO-2011-BT-STD-0048@ee.doe.gov 

Mail: Mrs. Brenda Edwards

 U.S. Department of Energy

 Building Technologies Program

 1000 Independence Avenue, SW, Mailstop EE-2J

 Washington, DC 20585-0121

Courier: Mrs. Brenda Edwards

 U.S. Department of Energy

 Building Technologies Program

 950 L'Enfant Plaza, 6th Floor

 Washington, DC 20024

 Telephone: (202) 586-2945
51 | Building Technologies Program eere.energy.gov

APPENDIX
52 | Building Technologies Program eere.energy.gov

Introduction

Statutory Authority – the Energy Policy and 

Conservation Act (EPCA) as Amended

 EPCA (42 U.S.C. 6291 et seq.) set forth criteria and procedures for DOE’s 

adoption and amendment of energy conservation standards and test procedures 

for covered products.

 Energy Independence and Security Act of 2007 (EISA 2007) Amendments to EPCA

• Any final rule establishing or revising a standard for a covered product, adopted 

after July 1, 2010, shall incorporate standby and off mode energy use into a single 

standard if feasible. If not feasible, DOE shall prescribe a separate standard for 

standby and off mode energy use, if justified.

 New microwave oven standby power standards are being considered as part of a 

rulemaking that also initially covered residential dishwashers, dehumidifiers, and 

conventional cooking products and commercial clothes washers.

• Amended dishwasher and dehumidifier standards were established by EISA 2007.

• Standards for conventional cooking products and microwave ovens as to cooking 

efficiency were addressed in a final rule in April 2009.

• Amended commercial clothes washer standards were adopted by final rule in 

January 2010.
53 | Building Technologies Program eere.energy.gov

The Energy Policy and Conservation Act (EPCA) directs DOE to 

consider seven factors when setting energy conservation standards

Factor Analysis

1. Economic impact on consumers and 

manufacturers

Life-cycle cost analysis

Manufacturer impacts analysis

2. Lifetime operating cost savings Life-cycle cost analysis

3. Total projected energy savings National impact analysis

4. Impact on utility or performance Screening analysis

Engineering analysis

5. Impact of any lessening of competition Manufacturer impacts analysis

6. Need for national energy conservation National impact analysis

7. Other factors the Secretary considers 

relevant

Environmental assessment

Utility impact analysis

Employment impact analysis

Introduction
54 | Building Technologies Program eere.energy.gov

Introduction

Test Procedure Background

 DOE’s test procedure for microwave ovens appears at appendix I to 

part 430 subpart B of Title 10 of the Code of Federal Regulations.

 DOE repealed the regulatory provisions establishing the cooking 

efficiency test procedure for microwave ovens under EPCA in a final 

rule published on July 22, 2010.

• DOE determined that the microwave oven test procedure provisions to 

measure cooking efficiency do not produce accurate and repeatable 

test results.

• Was unaware of any test procedures that have been developed that 

address the concerns with the DOE microwave oven cooking efficiency 

test procedure.

 EISA 2007 Amendments to EPCA direct DOE to incorporate a measure 

of standby and off mode energy consumption into its microwave oven 

test procedure by March 31, 2011.
55 | Building Technologies Program eere.energy.gov

Engineering Analysis

Efficiency Metric

 DOE eliminated the active mode cooking efficiency test procedure 

provisions in a July 2010 Test Procedure Final Rule.

• Existing provisions did not produce accurate and repeatable results.

• Absence of active mode provisions result in a de facto separate energy 

use descriptor for microwave oven standby mode and off mode energy 

use.

 Proposed standards are based on a maximum average standby 

power, in Watts (W).
56 | Building Technologies Program eere.energy.gov

Engineering Analysis

Incremental Manufacturing Costs

 From product testing and reverse engineering, DOE observed 

correlations between:

• Specific components and technologies, or combinations thereof, and

• Measured standby power

 DOE obtained preliminary incremental manufacturing costs 

associated with standby power levels by considering combinations of 

those components as well as other technology options identified to 

reduce standby power.

 DOE presented manufacturing cost estimates based on quotes 

obtained from:

• suppliers, 

• interviews with manufacturers and subject matter experts, 

• research and literature review, and 

• numerical modeling.
57 | Building Technologies Program eere.energy.gov

Baseline and Incremental Markups

■ Markups relate customer price to cost of goods sold (CGS)

■ Baseline markups relate price to cost prior to a change in efficiency

• Baseline markups indicate a customer price that covers all of a retailer’s 

expenses plus profit.

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

■ Incremental markups relate the incremental change in customer 

price to the incremental change in CGS beyond baseline

• Some distribution costs remain constant with CGS increases.

• Incremental markups cover only expenses that vary with CGS – in this case, 

expenses that increase due to an increase in equipment efficiency.

• For example, direct labor costs (salaries, payroll, rental and occupancy) do not vary 

with efficiency-induced changes in CGS.

• DOE assumes other operating costs and profit will scale proportionally with 

CGS.

Markups to Determine Equipment 

Price
58 | Building Technologies Program eere.energy.gov

Estimates of Retail Market Competition

■ DOE assumed that competition in the retail market, combined with 

inelastic demand, will put downward pressure on retail margins, 

supporting the incremental markup approach.

■ To confirm that retail markets are competitive, DOE used a commonlyused index of market concentration, the Four Firm Concentration Ratio 

(FFCR).*

■ An FFCR < 40% indicates a relatively unconcentrated market, while an 

FFCR > 70% indicates a concentrated market (oligopoly).

■ FFCRs were evaluated for major appliance sales in three retail channels: 

Electronics and Appliance Stores, Building and Material and Supplies 

Dealers, and General Merchandise Stores. In each case, the resulting 

FFCR was well below the 40% threshold.

* The Department of Justice uses a more complete index, the Herfindahl-Hirschman Index (HHI), but DOE lacked 

the information necessary for calculating an HHI.

Markups to Determine Equipment 

Price
59 | Building Technologies Program eere.energy.gov 

Life-Cycle Cost and Payback Period 

Analysis 

LCC and PBP Analysis Inputs 

Baseline

Manufacturer Cost

Std-Level

Manufacturer Cost

Sales Tax Installation Cost Total Installed Cost

Energy Prices

 Energy Use

Equipment Price

Lifetime

Operating

Expense Annual Energy Expense Lifetime Repair Cost Discount Rate Maintenance Cost Energy Price Trends

Annual

Operating

Expense

Payback

Period Life-Cycle Cost

Manufacturer Markup

From Engineering

Analysis

(Price is a

function of

Efficiency)

From Markups for

Equipment Price Determination

From Energy Use

Determination (Use is a

function of

Efficiency)

Consumer

Retail Price

Markup

-

r- .. - - .. 

- , r 

... 

• 

, ~ 

--{ • 

.. .. .. 

r- -

r--
60 | Building Technologies Program eere.energy.gov

■ Background

• DOE must publish an initial regulatory flexibility analysis if it cannot certify 

that the rule will not have a significant economic impact on a substantial 

number of small entities.

■ Findings

• DOE identified no small business manufacturer of microwave ovens for 

which there would be a significant economic impact

Regulatory Flexibility Act
61 | Building Technologies Program eere.energy.gov

Summary of Results

TSL 1 TSL 2 TSL 3 TSL 4

(Max 

Tech)

National Energy Savings (quads) 0.21 0.30 0.41 0.63

NPV of Consumer Benefits (2010$ billion)

7% discount rate 1.02 1.42 1.82 2.25

3% discount rate 1.98 2.78 3.59 4.60

Maximum Industry NPV Change (2010$ billion) (27.1) to

(29.3)

(45.2) to 

(52.4)

(52.9) to 

(73.6)

(90.4) to 

(165.7)

Maximum Industry NPV Change (%) (2.4) to 

(2.6)

(4.0) to 

(4.6)

(4.7) to 

(6.5)

(8.0) to 

(14.7)

Mean LCC Savings (2010$)

Microwave-Only Ovens and Countertop Combination Microwave Ovens 7 10 13 12

Built-In and Over-the-Range Combination

Microwave Ovens

6 11 4 27

Present Value of CO2 Emissions Savings (2010$ billion) 70 to 

1,066

101 to 

1,539

139. to 

2,118

213 to 

3,259

Proposed 

Level