By E-Mail

Ajit Jillavenkatesa

100 Bureau Drive

Stop 1060

Gaithersburg, MD 20899-1060

SOS_RFI@nist.gov

Re: Standardization feedback for Sub-Committee on Standards; 

Docket No. 0909100442-0563-02

Dear Mr. Jillavenkatesa:

The Association of Home Appliance Manufacturers (AHAM), respectfully submits the following 

feedback on standardization for the Sub-Committee on Standards in response to the request for 

information published in 75 Fed. Reg. 76397 (Dec. 8, 2010), Docket No. 0909100442-0563-02.

AHAM represents manufacturers of major, portable and floor care home appliances, and 

suppliers to the industry. AHAM’s membership includes over 150 companies throughout the 

world. In the U.S., AHAM members employ tens of thousands of people and produce more than 

95% of the household appliances shipped for sale. The factory shipment value of these products 

is more than $30 billion annually. The home appliance industry, through its products and 

innovation, is essential to U.S. consumer lifestyle, health, safety and convenience. Through its 

technology, employees and productivity, the industry contributes significantly to U.S. jobs and 

economic security. Home appliances also are a success story in terms of energy efficiency and 

environmental protection. New appliances often represent the most effective choice a consumer 

can make to reduce home energy use and costs.

AHAM is also a standards development organization, accredited by the American National 

Standards Institute (ANSI). The Association authors numerous appliance performance testing 

standards used by manufacturers, consumer organizations and governmental bodies to rate and 

compare appliances. AHAM’s consumer safety education program has educated millions of 

consumers on ways to properly and safely use appliances such as portable heaters, clothes dryers, 

and cooking products.

The Sub-Committee on Standards sought information on a number of questions regarding the 

effectiveness of federal agencies’ participation in the development and implementation of 

standards and conformity assessment programs. The Sub-Committee stated that it plans to 

consider the feedback to develop case studies that federal agencies can consider in their future 

engagement in standards development and conformity assessment. In particular, the SubCommittee is interested in comments that relate to the smart grid.
p 2

AHAM believes that industry is often the best group to drive the standards setting process 

because it is that group that is generally most familiar with product and other requirements and 

with consumer needs and expectations. Credible standards setting processes, like those in which 

AHAM is involved, are open and transparent and require technical expertise from industry and 

concerted efforts by affected parties and other stakeholders. Accordingly, we believe that federal 

agencies should leverage existing standards, including test procedures, which are developed 

through an open and transparent process. The same is true for standards and test procedures that 

are being developed in the area of the smart grid

AHAM is interested and involved in the development of the smart grid and related policies, and 

can provide a unique perspective from our member companies who will manufacture products 

that will become a part of our nation's future smart grid. From our perspective, the objective of 

the smart grid is to facilitate the development and use of new technology and systems that will 

allow consumers to automatically control their energy use and costs.

AHAM believes that in order for the smart grid to be successful, there are three essential 

requirements for the Smart Grid's interaction with consumers:1

1. Pricing must provide incentives to manage energy use more efficiently and enable 

consumers to save money.

2. Communication standards must be open, flexible, secure, and limited in number.

3. Consumer choice and privacy must be respected—the consumer is the decision maker.

In order to address one of those three essential requirements, AHAM completed an Assessment 

of Communication Standards for Smart Appliances, The Home Appliance Industry's Technical 

Evaluation of Communication Protocols, which is the industry's technical evaluation of the 

multitude of existing communications protocols designed for the smart grid. 2

The assessment was built with a focus on consumers' needs. To represent those needs 

accurately, AHAM's approach was to use appliance consumers' requirements to drive 

identification of the best communication protocols to use for smart grid interfaces. In Six Sigma 

language, this is called the Voice of the Customer. To represent this voice, AHAM chose to use 

the Quality Function Deployment (QFD) tool.3

In addition, AHAM partnered with efficiency organizations to submit a petition to the ENERGY 

STAR program to recognize the benefits of smart appliances and to jump start the smart grid.

This petition, which is part of the agreement between appliance manufacturers and energy 

efficiency advocates, asks the ENERGY STAR program to recognize the benefits of smart 

appliances and incorporate a five percent credit to the energy performance level required to meet 

ENERGY STAR eligibility criteria for smart-grid enabled appliances as soon as possible. A 

 1 See AHAM, Smart Grid White Paper: The Home Appliance Industry’s Principles & Requirements for Achieving a 

Widely Accepted Smart Grid (Dec. 2009), available at http://www.aham.org/ht/a/GetDocumentAction/i/44191. 

2 Available at http://www.aham.org/ht/a/GetDocumentAction/i/50696. 

3 The full QFD analysis is available at http://www.aham.org/ht/a/GetDocumentAction/i/50698%20. 
p 3

copy of the petition is attached to these comments at Attachment A.

The Pacific Northwest National Laboratory (PNNL) recently completed a cost/benefit analysis 

for the Department of Energy (DOE), which was included with the petition. PNNL determined 

that the annual benefits from having smart grid capabilities in an appliance are greater than the 

costs of an equivalent five percent increase in operational machine efficiencies.

To facilitate the development of the smart grid, AHAM believes that it would be useful for 

federal agencies to help fund standards oriented research, similar to the communications study 

AHAM undertook and the analysis done by PNNL. Areas that are ripe for research related to the 

smart grid are ancillary services, dynamic rates, and interoperability. In addition, federal 

agencies could help develop smart grid technologies by sponsoring and administering pilot 

projects similar to those underway in a few municipalities, on a larger, perhaps national, scale. 

AHAM appreciates the opportunity to submit this feedback on standardization for the SubCommittee on Standards.

Respectfully Submitted,

Jennifer Cleary

Director, Regulatory Affairs
p 4

ATTACHMENT A
January 6, 2011 

The Honorable Gina McCarthy The Honorable Cathy Zoi 

Assistant Administrator Assistant Secretary 

Office of Air and Radiation     Office of Energy Efficiency and 

Environmental Protection Agency Renewable Energy

1200 Pennsylvania Avenue, NW U.S. Department of Energy 

Washington, DC 20460 1000 Independence Avenue, SW 

 Washington, DC 20585 

Dear Assistant Administrator McCarthy and Assistant Secretary Zoi: 

The Association of Home Appliance Manufacturers (AHAM) and efficiency organizations, 

which are being coordinated by the American Council for an Energy-Efficient Economy 

(ACEEE), have agreed to a number of recommendations related to new appliance efficiency 

standards and test procedures, smart appliances, and incentives to manufacture super-efficient 

appliances. As part of the agreement, the parties are jointly petitioning the ENERGY STAR 

program to provide a 5 percent credit to the energy performance level required to meet ENERGY 

STAR eligibility criteria. Please find attached a petition to the ENERGY STAR program to 

implement one of the central pillars of the Energy Efficient and Smart Appliance Agreement of 

2010. 

We look forward to working with the ENERGY STAR program to advance the 

recommendations contained in this petition. Please do not hesitate to contact either of us if you 

have any questions or need any further information. 

Sincerely, 

 

Kevin Messner Steven Nadel 

Vice President, Government Relations Executive Director 

AHAM ACEEE 
1 

Joint Petition To ENERGY STAR To Adopt Joint Stakeholder Agreement As It Relates To 

Smart Appliances 

January 6, 2011 

Association of Home Appliance Manufacturers1

American Council for an Energy-Efficient Economy 

Natural Resources Defense Council 

Alliance to Save Energy 

Alliance for Water Efficiency 

Northwest Power and Conservation Council 

Northeast Energy Efficiency Partnerships 

Consumer Federation of America 

National Consumer Law Center 

Earthjustice 

California Energy Commission 

Demand Response and Smart Grid Coalition 

I. Introduction and Overview

The Joint Petitioners are pleased to present to the U. S. Environmental Protection Agency (EPA) 

and Department of Energy (DOE) the results of successful negotiations which resulted in an 

agreement (“the Joint Proposal”) on federal minimum energy conservation standards for five 

products, and related test procedures, ENERGY STAR, and financial incentive provisions. The 

description of this package and an initial estimate of its impact can be found in Attachment 1. 

Central to this Joint Proposal is the agreement to request from ENERGY STAR a five percent 

credit to the energy performance level required to meet ENERGY STAR eligibility criteria for 

smart-grid enabled appliances. The Joint Petitioners urge EPA and DOE to adopt the Joint 

Proposal, incorporating a five percent credit to the energy performance level required to meet 

ENERGY STAR eligibility criteria for smart-grid enabled appliances as soon as possible, but not 

later than March 31, 2011. The Joint Petitioners are representative of a wide range of expert and 

relevant points of view—including manufacturers of various sizes representing over 99% of the 

market; consumer, environmental, and advocacy groups; and a major public power planning 

agency—concerning ENERGY STAR for the subject products. 

The agreement in its entirety, see Attachment 2, covers residential refrigerator/freezers, clothes 

washers, clothes dryers, room air-conditioners, and dishwashers. There are three main pillars of 

this agreement: 

1. Energy efficiency standards: the agreement recommends new federal minimum 

efficiency standards that will save significant amounts of energy. Lawrence Berkeley 

 

1

 Whirlpool, General Electric, Electrolux, LG Electronics, BSH, Alliance Laundry, Viking Range, Sub-Zero Wolf, 

Friedrich A/C, U-Line, Samsung, Sharp Electronics, Miele, Heat Controller, AGA Marvel, Brown Stove, Haier, 

Fagor America, Airwell Group, Arcelik, Fisher & Paykel, Scotsman Ice, Indesit, Kuppersbusch, Kelon, DeLonghi 
2 

National Laboratory (LBL) projects that the Joint Proposed Standards would save more 

than 9 quads of primary energy over 30 years. It would also result in nearly five trillion 

less gallons of water used over 30 years and reduce carbon emissions by approximately 

550 million metric tons. 

2. Smart appliances: the agreement hastens the production of smart appliances. As part of 

the agreement, the parties are jointly submitting this petition to the Environmental 

Protection Agency (EPA) and DOE to provide a five percent credit to the energy 

performance level required to meet ENERGY STAR eligibility criteria for products that 

meet a definition of “smart appliance.” Further recognizing the opportunity for smart 

appliances to contribute to energy efficiency and the smart grid, the parties will work 

together to develop a proposal for incentives for appliances with “smart” capabilities. It 

is expected that the incentives for smart appliances may produce additional CO2 emission 

reductions. 

3. Tax credit: the agreement includes recommendations for updates and extensions of the 

manufacturer tax credit for the production of super-efficient dishwashers, clothes 

washers, refrigerators and freezers. These incentives encourage manufacturers to 

develop, commercialize, and sell very high efficiency products, helping to transform 

markets faster than with standards alone. The lower tiers of the current federal incentives 

are phased-out under the new agreement and new, higher tiers are added. LBL has 

estimated the tax credits for appliances would save an additional 0.67 quads of primary 

energy over 30 years. 

This petition is only in regard to the ENERGY STAR program (minimum efficiency standards 

are a part of different petitions). Action on the tax credit and energy standards elements of the 

agreement will require consideration by Congress and the DOE. 

Congress authorized the ENERGY STAR program “to identify and promote energy-efficient 

products and buildings in order to reduce energy consumption, improve energy security, and 

reduce pollution through voluntary labeling of, or other forms of communication about, products 

and buildings that meet the highest energy conservation standards.” 42 U.S.C. § 6294a. The 

Joint Proposal to provide a five percent credit to the energy performance level required to meet 

ENERGY STAR eligibility criteria for products that meet an EPA-set definition of “smart 

appliance” advances those goals. The five percent credit will encourage the design and 

manufacture of these products. These products have the potential to reduce energy consumption 

and reduce cost to consumers. Accordingly, ENERGY STAR should adopt the five percent 

credit. 

II. The Joint Petitioners To and Supporters of the Agreement

The American Council for an Energy Efficient Economy (ACEEE) is a nonprofit, non-partisan, 

organization dedicated to advancing energy efficiency as a means of promoting economic 

prosperity, energy security, and environmental protection. ACEEE fulfills its mission by 

conducting in-depth technical and policy assessments; advising policymakers and program 

managers; working collaboratively with businesses, public interest groups, and other 
3 

organizations; publishing books, conference proceedings, and reports; organizing conferences 

and workshops; and educating consumers and businesses. 

The Association of Home Appliance Manufacturers (AHAM) represents manufacturers of major, 

portable and floor care home appliances, and suppliers to the industry. AHAM’s membership 

includes over 150 companies throughout the world. In the U.S., AHAM members employ tens 

of thousands of people and produce more than 95% of the household appliances shipped for sale. 

The factory shipment value of these products is more than $30 billion annually. The home 

appliance industry, through its products and innovation, is essential to U.S. consumer lifestyle, 

health, safety and convenience. Through its technology, employees and productivity, the 

industry contributes significantly to U.S. jobs and economic security. Home appliances also are 

a success story in terms of energy efficiency and environmental protection. New appliances 

often represent the most effective choice a consumer can make to reduce home energy use and 

costs. AHAM represents the manufacturers of virtually all affected clothes dryers and room air 

conditioners manufactured and/or sold in the United States. AHAM is involved in a number of 

activities related to smart appliances, including advocating for government action, to helping 

align the high level architecture and communication protocols used by smart appliances. 

The Alliance to Save Energy (ASE) is a coalition of prominent business, government, 

environmental, and consumer leaders who promote the efficient and clean use of energy 

worldwide to benefit consumers, the environment, the economy, and national security. 

Established as an NGO in 1977, to carry out its mission the Alliance undertakes research, 

educational programs, and policy advocacy; designs and implements energy-efficiency projects; 

promotes technology development and deployment; and builds public-private partnerships in the 

United States and other countries. 

The Alliance for Water Efficiency is a stakeholder-based 501(c)(3) non-profit organization 

dedicated to the efficient and sustainable use of water, with 317 member organizations from 

water utilities, government agencies, businesses, industry, plumbing, appliance and irrigation 

manufacturers, retailers, environmental and energy efficiency advocates, and other stakeholders. 

Located in Chicago, the Alliance serves as a North American advocate for water efficient 

products and programs, and provides information and assistance on water conservation efforts. 

The Appliance Standards Awareness Project (ASAP) is a coalition group dedicated to advancing 

cost-effective energy efficiency standards for appliances and equipment. ASAP works at both 

the state and federal levels and is led by a Steering Committee with representatives from 

consumer groups, utilities, state government, environmental groups, and energy-efficiency 

groups. 

The Consumer Federation of America is an association of nearly 300 nonprofit consumer groups 

that was established in 1968 to advance the consumer interest through research, advocacy, and 

education. 

The National Consumer Law Center ®, a nonprofit corporation founded in 1969, assists 

consumers, advocates, and public policy makers nationwide on consumer law issues. NCLC 

works toward the goal of consumer justice and fair treatment, particularly for those whose 
4 

poverty renders them powerless to demand accountability from the economic marketplace. 

NCLC has provided model language and testimony on numerous consumer law issues before 

federal and state policy makers. NCLC publishes an 18-volume series of treatises on consumer 

law, and a number of publications for consumers. 

The Natural Resources Defense Council (NRDC) is a national environmental advocacy 

organization with over 1.3 million members and online activists. NRDC has spent decades 

working to build and improve DOE’s federal appliance standards programs because of the 

important energy, environmental, consumer, and reliability benefits of appliance efficiency 

standards. NRDC participated in the enactment of the first federal legislation establishing 

efficiency standards, and has been active in all significant rulemakings since then. 

Northeast Energy Efficiency Partnerships (NEEP) is a non-profit organization that facilitates 

regional partnerships to advance the efficient use of energy in homes, buildings and industry in 

the Northeast U.S. NEEP works to leverage knowledge, capability, learning and funding 

through regionally coordinated policies, programs and practices. As a regional organization that 

collaborates with policy makers, energy efficient program administrators, and business, NEEP is 

a leader in the movement to build a cleaner environment and a more reliable and affordable 

energy system. 

The Northwest Power and Conservation Council is an interstate compact between the states of 

Idaho, Montana, Oregon and Washington authorized by the Northwest Power Act of 1980 

(PL96-501). The Council is charged with ensuring that the Northwest’s electric power system 

will provide adequate and reliable energy at the lowest economic and environmental cost to its 

citizens. 

The Demand Response and Smart Grid Coalition (DRSG) is the trade association for companies 

that provide products and services in the areas of demand response, smart meters and smart grid 

technologies. DRSG works to educate and provide information to policymakers, utilities, the 

media, the financial community and stakeholders on how demand response and smart grid 

technologies such as smart meters can help modernize our electricity system and provide 

customers with new information and options for managing their electricity use. 

Other supporters include the California Energy Commission and Earthjustice. 
5 

III. Rationale For The Negotiations 

The Joint Petitioners entered into discussions on smart appliances as part of the overall 

agreement negotiation for two main reasons. First, it was thought that the smart grid can provide 

important energy efficiencies and reliability improvements and that there needs to be incentives 

to manufacturers to sell smart appliances to hasten the development of an effective smart grid. 

Second, smart appliances can provide more effective and efficient use of electricity, which can 

save energy, save consumers money on their electricity bills, and increase the use of renewable 

energy. The Joint Petitioners believe that both of these goals were achieved and will be borne 

out in the implementation of this proposal. 

IV. The Negotiations Process

The parties’ discussions commenced in the spring of 2010 and an agreement was finalized on 

July 30, 2010. Discussions were held, and empirically- and technically-based proposals were 

made relying on data and analysis provided by DOE’s consultants. The Joint Petitioners’ 

proposal also is supported by the Pacific Northwest National Laboratory’s analysis on benefits of 

smart appliances, as discussed below. 

V. The Joint Stakeholder Proposal

The Joint Proposal is to provide a five percent credit to the energy performance level required to 

meet ENERGY STAR eligibility criteria for the smart-grid enabled appliances that are included 

in the Joint Proposal, which includes residential refrigerator/freezers, clothes washers, clothes 

dryers, room air-conditioners, and dishwashers. A five percent credit means that smart 

appliances would be allowed to use five percent more energy than non-smart products that earn 

the Energy Star designation.2

 The proposal will save consumers money and save energy, and 

may help increase the use of renewable energy. 

VI. Justification

A. The Problem: Electricity Use Is Increasing

EIA, in its 2010 Annual Energy Outlook, projects that electricity use will increase by more than 

30 percent by 2035. Residential electricity use will increase by 23 percent from 2010-2035, due 

to growth in population and disposable income and continued population shifts to warmer 

regions with greater cooling requirements. Peak demand increases may be even more 

pronounced. One industry forecast of peak demand, which extrapolates the North American 

Electric Reliability Corporation’s 2005 Peak Demand and Energy Projection Bandwidths, results 

in non-coincident peak demand that is 55 percent higher in 2030 than it was expected to be in 

 

2

 Please note that the joint agreement and this petition does not cover what the Energy Star specification should be 

for non-smart appliances, against which the 5% credit would be calculated.
6 

2008.3 Summer peak load was expected to increase 430 GW in 2030 from the existing 781 GW. 

This forecast DOES NOT include expected demand response programs, but does include modest 

forecasted efficiency savings. Peak demand is the most costly because 10 percent of the 

generation and 25 percent of the transmission infrastructure are needed to service only 400 hours 

per year (see figure 1). However, the 2010 Annual Energy Outlook projects that electric power 

sector generating capacity will grow by only 8 percent from 2010 to 2030. 

B. The Smart Grid Is Critical in Addressing the Increase in Electricity Use

As discussed below, the smart grid is an important part of efforts to address projected increases 

in electricity use. The Electric Power Research Institute (EPRI) estimates that the 

implementation of smart grid technologies could reduce electricity use by more than four percent 

annually by 2030.4 And the residential sector is critically important to managing the electrical 

grid into the future. The residential sector represents 37 percent of electricity use and is the 

largest consuming sector of electricity (see figure 2). 

 

3 Ingrid Rohmund and Greg Wikler (Global Energy Partners, LLC), Ahmad Faruqui (The Brattle Group), Omar 

Siddiqui (Electric Power Research Institute) and Rick Tempchin (Edison Electric Institute), “Assessment of 

Achievable Potential for Energy Efficiency and Demand Response in the U.S. (2010 – 2030),” Paper prepared for 

2008 ACEEE Summer Study on Energy Efficiency in Buildings, p. 5-264. 

4

 Press Release, U.S. Department of Energy, Secretary Chu Announces Two Million Smart Grid Meters Installed 

Nationwide (August 31, 2010), available at http://www.energy.gov/news/9433.htm. 

Figure 1
7 

Demand response, augmented by the smart grid and smart appliances, will result in some energy 

savings and reductions in costs. The North American Energy Standards Board (NAESB) has 

defined demand response as “changes in electric use by demand-side resources from their normal 

consumption patterns in response to changes in the price of electricity, or to incentives designed 

to induce lower electricity use at times of potential peak load, high cost periods, or when systems 

reliability is jeopardized.” 5 In other words, when an electric utility company or third party 

energy service provider encounters a problem, it can send a signal alerting the consumer of the 

complication so that the consumer can react by reducing load during this critical time period. 

Reduction in energy usage during critical periods is the result of a response to a request for 

lowered energy usage. Critical time reductions of energy use can be accomplished by either 

“shifting” usage to a non-critical time of the day or by “shedding” load to reduce peak power. 

According to EPRI “. . . load reductions offered by demand response and load control programs 

facilitated by a Smart Grid can yield energy savings and reductions in carbon emissions.”6 And 

Secretary Chu has recognized that “[s]mart grid technologies will give consumers choice and 

promote energy savings, increase energy efficiency, and foster the growth of renewable energy 

resources.”7

 Further evidence that reducing peak power is linked to saving energy, in the EIA’s 

Electric Power Annual 2008 (Table 9.2) utilities reported for every 1kW of peak load reduction 

there is a corresponding 139 kWh of energy saved.

Reducing peak load provides several other benefits: 

• provides relief during capacity-constrained periods 

• reduces transmission congestion 

• minimizes operation of peaking plants 

• defers the need for new generation 

 According to a report released by Vice President Biden on August 24, 2010: 

 

5

 “Measurement & Verification for Demand Response Programs,” Recommendation to NAESB Executive 

Committee (July 29, 2009). 

6

 “The Green Grid,” Electric Power Research Institute, June 2008 

7

 Press Release, U.S. Department of Energy, Secretary Chu Announces Two Million Smart Grid Meters Installed 

Nationwide (August 31, 2010), available at http://www.energy.gov/news/9433.htm. 

Figure 2
8 

Smart Grid technology, combined with supportive policy, allows for smarter use of 

energy, largely by increasing the transparency, measurement, and control of energy used 

by the players who supply, transmit, distribute, and demand it. Through automated 

sensors and controls as well as dynamic pricing, this intelligent infrastructure will make 

the electric system more reliable, empower consumers and utilities to use energy more 

wisely, help manage peak demand, enable larger scale use of renewable energy and 

electric vehicles, and reduce U.S. dependence on oil.8

The Joint Petitioners’ proposal for a five percent credit is exactly the type of supportive policy 

that will allow the smart grid to thrive and produce the above-enumerated benefits for 

consumers, utilities, and the environment. 

C. Smart Appliances Benefit Spinning Reserves

To balance supply and demand continuously despite sudden, unexpected failures of generators 

and/or transmission lines, utilities typically maintain contingency reserves to compensate for 

such failures. Contingency reserves include: 10-minute spinning reserves, 10-minute nonsynchronized reserves, and 30-minute operating reserves. The 10-minute spinning reserves are 

typically provided by generators supplying base-load power by operating the generators below 

their rated capacity, and then ramping them up when called upon to deliver spinning reserves. 

Despite their importance to power system operation, the larger the spinning reserve requirement, 

the greater the emissions. 

In recent years, there has been considerable interest towards exploiting the enormous potential of 

demand response towards providing spinning reserves.9

 This is over and beyond peak-load 

reduction as discussed above. Residential loads capable of interacting with the grid (smart 

appliances) such as refrigerator/freezers, clothes washers, clothes dryers, room air-conditioners, 

and dishwashers are particularly suited as sources of 10-minute spinning reserves because the 

operation of such loads can be interrupted for short periods (up to 10 minutes) without causing 

any diminution of the quality of service for consumers. Furthermore, end-use load can often be 

curtailed almost instantaneously as opposed to generators that must ramp up and down subject to 

operating constraints in order to avoid equipment damage. Finally, given the potentially large 

number of responsive end-use loads, their aggregate response could be extremely reliable when 

called upon to provide spinning reserves. Thus, residential loads could obviate the need for 

maintaining some fossil-fuel based generation for providing spinning reserves thereby reducing 

operating costs and also lowering emissions. 

 

8

 Executive Office of the President of the United States and Vice President of the United States, “The Recovery Act: 

Transforming The American Economy Through Innovation,” at 37 (August 2010), available at 

http://www.whitehouse.gov/sites/default/files/uploads/Recovery_Act_Innovation.pdf (emphasis added) [hereinafter 

“the Recovery Act Report”]. 

9

 Spinning Reserve From Responsive Load: http://certs.lbl.gov/pdf/spinning-reserves.pdf 
9 

Pacific Northwest National Laboratory (PNNL) has undertaken a study to evaluate the precise 

benefits of smart appliances towards providing both peak-load reduction and spinning reserves. 

An overview of this study is presented in Section E. 

D. Definition of Smart Appliances and Product-specific Guidance

Defining smart appliances is challenging because it is a definition for a product that is still in its 

infancy, and a major purpose of this petition is to provide an incentive to increase the 

deployment across the country. Hence, it is important to clearly define the properties and 

capabilities of a ‘Smart Appliance’ to differentiate it from existing home appliances and ensure 

that the definition is not so restrictive that it stifles technology innovation and competition. The 

Joint Petitioners propose the following provisional definition of smart appliances: 

Smart appliances are still in their infancy, presenting a significant definitional challenge. The 

Joint Petitioners believe it is important to clearly differentiate smart appliances from existing 

home appliances by defining smart appliance properties and capabilities. However, definitions 

must not be so restrictive as to stifle technology innovation and competition. The products must 

continue to comply with the applicable product safety standards -- the addition of smart 

technology cannot override existing safety protections and functions. Any reduction in load 

cannot adversely impact the product’s inputs, e.g., clothes, foods, dishware. 

The Joint Petitioners propose the following provisional definitions related to smart appliances. 

Any smart appliance must meet the definition of “smart appliance” and the product specific 

requirements below. 

The term “smart appliance” means a product that uses electricity for its main power 

source which has the capability to receive, interpret and act on a signal received from a 

utility, third party energy service provider or home energy management device, and 

automatically adjust its operation depending on both the signal’s contents and settings 

from the consumer. The product will be sold with this capability, which can be built-in 

or added through an external device that easily connects to the appliance. The costs of 

such devices shall be included in the product purchase price.10

 These signals must include (but are not limited to) appliance delay load, time-based 

pricing and notifications for load-shedding to meet spinning reserve requirements. Any 

appliance operation settings or modes shall be easy for an average, non-technical 

consumer to activate or implement. Additionally, a smart appliance or added device may 

or may not have the capability to provide alerts and information to consumers via either 

visual or audible means. The appliance may not be shipped with pre-set time duration 

limits that are less than those listed below, but may allow consumer-set time duration 

 

10 If additional requirements are needed to activate the product’s “smart” capabilities as purchased, then prominent 

labels and instructions must be displayed at the point of purchase and in product literature on what specifically 

consumers or utilities need to do to achieve these capabilities (e.g. “This product requires snapping in the compatible 

network module and utility installation of a smart meter or other device for use of capabilities that earned the 

ENERGY STAR label”). 
10 

limits on smart operating modes, and will also allow consumers to override any specific 

mode (e.g. override a delay to allow immediate operation, limit delays to no more than a 

certain number of hours, or maintain a set room temperature). 

The term “delay load capability” refers to the capability of an appliance to respond to a 

signal that demands a response intended to meet peak load deferral requirements, but 

which also could be used to respond to a sudden maintenance issue at another time of 

day. 

The term “spinning reserve capability” means the capability of an appliance to respond 

to a signal that demands a response intended to temporarily reduce load by a short-term, 

specified amount, usually 10 minutes. 

We further recommend product-specific definitions as provided below. Each of the following 

definitions includes a response to a “delay load signal” and a response to reduce load to provide 

spinning reserve services. A smart appliance needs to have the capability to meet both of these 

requirements, but not simultaneously. 

a) Refrigerator/Freezers: a smart refrigerator/freezer must have the following minimum 

capabilitiesi) Delay load capability - upon receipt of a signal requesting a delay of load for a time 

duration not exceeding 4 hours, the product must shift defrost cycles beyond the delay period and 

do one of the following -- 

(1) shift ice maker cycles beyond the delay period, or 

(2) reduce average wattage during the delay period by at least 9.6 watts 

relative to average load over a 24 hour period, and may shift this wattage 

beyond the delay period", and 

ii) Spinning reserve capability - upon receipt of a signal requesting the start of a reduced 

load period for a time duration not exceeding 10 minutes, the product must restrict its average 

energy consumption during this time period to a maximum of 50 percent of the average load over 

a 24 hour period (unless there is a consumer initiated function, such as door opening or ice or 

water dispensing). 

b) Clothes Washers: a clothes washer must have the following minimum capabilities - 

i) Delay load capability - upon receipt of a signal requesting a delay of load for a time 

duration not exceeding either 4 hours or such other period that the consumer may select, the 

product must automatically delay the start of the operating cycle beyond the delay period, and 

ii) Spinning reserve capability - upon receipt of a signal requesting the start of a reduced 

load period for a time duration not exceeding 10 minutes, the product must automatically reduce 

its average wattage during this time period by at least 50 percent relative to average wattage 

during this period in the operating cycle under DOE test conditions. 

c) Clothes Dryers: a clothes dryer must have the following minimum capabilities - 

i) Delay load capability - upon receipt of a signal requesting a delay of load for a time 

duration not exceeding 3 hours, the product must automatically delay the start of the operating 

cycle beyond the delay period, and 
11 

ii) Spinning reserve capability - upon receipt of a signal requesting the start of a reduced 

load period for a time duration not exceeding 10 minutes, the product must automatically reduce 

its average wattage during this period by at least 80 percent relative to average wattage during 

this period in the operating cycle under the DOE test conditions. 

d) Room Air Conditioners: a room air conditioner must have the following minimum 

capabilities - 

i) Delay load capability - upon receipt of a signal requesting a delay of load for a time 

duration not exceeding either 4 hours or such other period that the consumer may select, the 

product must automatically reduce its average wattage during this period by at least 25 percent 

relative to average wattage during this period in the operating cycle under the DOE test 

conditions, and 

ii) Spinning reserve capability - upon receipt of a signal requesting the start of a reduced 

load period for a time duration not exceeding 10 minutes, the product must automatically reduce 

its average wattage during this period by at least 80 percent relative to average wattage during 

this period in the operating cycle under during the DOE test conditions. 

e) Dishwashers: a dishwasher must have the following minimum capabilitiesi) Delay load capability - upon receipt of a signal requesting a delay of load for a time 

duration not exceeding either 4 hours or such other period that the consumer may select, the 

product must automatically delay the start of the operating cycle beyond the delay period , and 

ii) Spinning reserve capability - upon receipt of a signal requesting the start of a reduced 

load period for a time duration not exceeding 10 minutes, the product must automatically reduce 

its average wattage during this period by at least 50 percent relative to average wattage during 

this period in the operating cycle under the DOE test conditions. 

E. Benefits of Smart Appliances

PNNL has undertaken a study to evaluate the precise benefits of smart appliances 

(refrigerator/freezers, clothes washers, clothes dryers, room air-conditioners, and dishwashers) 

towards providing both peak-load reduction and spinning reserves through demand response. 

The benefits being considered are distinct from those arising due to traditional machine 

enhancements that enable operational efficiencies. The benefits include estimates of the 

production cost savings to utilities and the extent to which smart appliances can provide ancillary 

services to facilitate greater penetration of renewable generation sources (wind and solar in 

particular). 

The analytical model developed by PNNL is based on generic smart appliance demand response 

capabilities, i.e., not limited to a particular manufacturer. The methodology adopted is based on 

various underlying parameters such as expected smart appliance penetration and usage rates, 

daily usage patterns, definitions of peak and off-peak periods, and other pertinent benefitsimpacting assumptions. In establishing the monetary value of benefits, historical wholesale 

market clearing prices are drawn from various electric power markets including NYISO, CAISO, 

PJM, and ERCOT. 
12 

The model is based on ELCAP load shapes for daily usage patterns. 11 Appliance energy 

consumption is based on AHAM data and DOE standards and test procedures.12 The valuation 

of benefits is different for each appliance, but for dryers, clothes washers, and dishwashers, the 

model first estimates the total on-peak and off-peak consumptions. Then, based on these 

consumptions, and annual hourly average energy market clearing prices, the wholesale 

production cost savings derived from shifting of a given percentage of peak load to off-peak 

periods is estimated. When it comes to spinning reserves, there are 3 components. 

1. Load from dryers, clothes washers, and dishwashers that are operating during off 

peak. 

2. Appliance loads not shifted from peak hours. Recall, only a certain percentage of 

loads are shifted from peak to off-peak hours. The remaining load during peak hours 

is available for spinning reserves. 

3. Load shifted from peak to off-peak hours. This shifted load is also available for 

spinning reserves. 

The annual hourly spinning-reserve market clearing prices are invoked to value these three 

spinning reserve components. The total operational cost savings or “benefits” are those arising 

from peak load shifting and spinning reserves. 

The five percent smart appliance credit is then applied to the total annual operating cost of a 

given appliance to estimate the credit which is the “cost” applied towards making an appliance 

smart. Finally, the “benefits” to “cost” ratio is evaluated. The optimistic scenario generally assumes 

that all customers can receive grid signals and communicate these to the appliance and that all 

customers are willing to shift 100 percent of their on-peak loads. The pessimistic scenario 

generally assumes that 50 percent of customers can receive grid signals and communicate these 

to the appliance, that 70 percent of customers are willing to shift on-peak loads (90 percent in the 

case of the 10 minute shifts needed to serve spinning reserves), and that on average these 

customers will shift about 50 percent of their on-peak load out of the peak. The optimistic 

scenario assumes that shifts will move energy use out of a five-hour peak period on average, 

while the pessimistic scenario uses a four-hour average for shifts. A summary of the results are as 

follows and full report is attached: 

As can be seen from Table 1.1 and Table 1.2, in all the markets, in either optimistic or pessimistic 

assumption scenarios, the benefit-to-cost ratio for all appliances exceeds 100 percent. This is 

especially the case for the optimistic scenario, in which the benefits overwhelmingly exceed the cost 

as shown in Table 1.1. This means that the annual benefits from having smart grid capabilities in an 

appliance are greater than an equivalent five percent increase in operational machine efficiencies. 

The expectation then is that if ENERGY STAR adopts this proposal for a five percent incentive for 

smart appliances it will facilitate the growth of the smart-appliance industry. 

 

11 Pratt, R.G., et al., 1989. “Description of Electric Energy Use in Single-Family Residences in the Pacific 

Northwest," End-Use Load and Consumer Assessment Program (ELCAP),” Pacific Northwest Laboratory, 

DOE/BP-13795-21, Richland, WA, April 1989 

12 http://www1.eere.energy.gov/buildings/appliance_standards/residential_products.html 
13 

Table 1.1: Benefit-to-Cost Ratios of Smart Appliances Based on “Optimistic” Assumptions 

Table 1.2: Benefit-to-Cost Ratios of Smart Appliances Based on “Pessimistic” Assumptions 

F. Synergies of Suite of Appliances

The benefits of smart appliances are greatly enhanced by the synergies provided by having 

multiple smart appliances in the home, hence the need for an across the board five percent credit 

to equally incentivize the deployment and use of “smart” features in all the products. For 

example, a suite of appliances in the home can better “represent” a power generation facility 

because of its flexibility to address load shifting and spinning-reserve requirements. Different 

products may provide strengths in different areas. For example, a refrigerator would likely have 

a high probability that its defrost operation would be shifted to a more desirable time (at any time 

of day or night) for the grid operations when needed, whereas a dryer, with its high load during a 

relatively short span of time usually during the day, would likely have a higher probability that 

its heat elements could be turned off or reduced for short periods of time during operation to 

reduce spinning reserve requirements. Thus, the synergies of a home suite with a broad mix of 

smart appliances would likely provide a correspondingly higher benefit to the environment, the 

consumer and the grid, than the additive benefits of each smart appliance evaluated separately. 
14 

G. Demand Response vs. Energy Efficiency

Increasing energy efficiency is not the only way to drive energy savings. As discussed above, 

demand response can also yield some energy savings. For example, cycling the dryer heating 

coil off while continuing to spin clothes allows use of the residual heat in the dryer, reducing 

heater-on time when the heater coil is restarted and yielding less total cycle energy use but a 

longer cycle time. The residential consumer and smart appliances are important to the success of 

demand response. Since late 2007 and after passage of the 2007 energy law, for example, 

efficiency savings were estimated by the Electric Power Research Institute (EPRI), including 

savings from refrigerators, dryers, room air conditioners, clothes washers, and dishwashers. 

EPRI found that the savings from these appliances were a small percentage of maximum 

achievable potential in 2030 in relation to other residential, commercial, and industrial uses.13 

Efficiency advocates believe that EPRI significantly underestimated the efficiency savings 

available from appliances (e.g., EPRI generally only looked at then-current Energy Star levels 

and not beyond). Still, efficiency advocates agree that as appliance efficiency continues to 

increase, remaining opportunities for appliance efficiency savings will decline Further 

information from the EPRI study is shown in Figure 3, which depicts that the maximum 

potential for efficiency savings in home appliances (highlighted in chart) that are affected by this 

petition is quite low compared with other products. 

 

 

13 Rohmund, Ingrid ,et. al (Global Energy Partners, Brattle Group, EPRI, EEI), Assessment of Achievable Potential 

for Energy Efficiency and Demand Response in the US (2010-2030) 
15 

 

According to the EPRI assessment of achievable potential for energy efficiency and demand response 

in the U.S., demand response combined with increases in energy efficiency can offset 40 percent 

(173 GW) of the growth in summer peak demand by 2030 (see figure 4).14 

 

14 Ibid 

Figure 3 
16 

Significantly, residential customers offer as much demand response potential as small, medium, 

and large businesses combined (see figure 5). 

 According to FERC, “. . . it is the residential class that represents most [sic] untapped potential 

for demand response. . . While residential customers provide only roughly 17 percent of today’s 

demand response potential, in the AP [Achievable Participation] scenario they provide over 45 

percent of the potential impacts.”15 The FERC National Assessment of Demand Response, June 

2009, found that “pricing w/tech,” (including smart appliances) offer more than half of the 

potential for peak demand reduction (see figure 6). Furthermore, as the PNNL study indicates, 

further gains are possible through the utilization of smart appliances for providing spinning 

reserves. 

 

15 “National Assessment of Demand Response,” Federal Energy Regulatory Commission, June 2009 

Figure 5

Figure 4
17 

H. Smart Appliances Are Untapped

It is expected that an increasing number of consumers will have access to smart meters over the 

next five years. According to the Recovery Act Report: 

. . . the Recovery Act recognized the opportunity to accelerate the deployment of 

components that make up a Smart Grid to support a modern, low-carbon economy and 

create a platform for innovation for new energy management and information services in 

homes and buildings. The combination of Recovery Act funds and private investments 

promise to add 18 million new smart meters to the eight million currently in use. This 

means 26 million smart meters will be in use by 2010, on track to reach 40 million by 

2015 through public and private investment.16 

However, in order for consumers to maximize the benefits they can obtain from these smart 

meters, it is important to incentivize the use of smart appliances in the home. The Joint 

Petitioners’ proposed five percent credit will jump start this component of the smart grid, thus 

helping to achieve energy and other savings on an accelerated timeline. 

 

I. Demand Reduction Yields Further Capacity Savings

Reducing demand also yields capacity savings. Reducing demand may have a 24 percent higher 

impact at the generating facility, which equates to even more capacity savings (see figure 7). 

 

16 The Recovery Act Report, supra n.4, at 39. 

Figure 6
18 

J. Increased Use of Renewable Energy

The benefit of the smart grid goes beyond energy savings. Due to environmental concerns, there 

has been increasing interest in recent years towards incorporating large amounts of renewable 

sources of energy such as solar and wind, and diminish the reliance on fossil-fuels to create a 

more diversified energy supply portfolio. For example, DOE has initiated a collaborative effort 

to explore the possibility of wind power supplying 20 percent of US electricity needs by the year 

2030.17 One of the key challenges involved with solar and wind as sources of energy is that they 

are intermittent and cannot be relied upon with certainty. Solar energy output can drop very 

quickly with passing clouds, while wind energy output changes very frequently, almost every 

hour. As a result, in order to balance supply and demand, a key objective of power system 

operation alluded to above, it is required to maintain energy reserves based on conventional 

generation sources like natural gas. But doing so works against the very purpose of incorporating 

solar and wind energy, namely, decreasing reliance on fossil fuels. Fortunately, demand response 

through smart appliances can be invoked to curtail and/or defer demand for power during periods 

when solar and wind energy are in short supply, and to shift the demand to when there is an 

abundance, enabling greater utilization of renewable energy. 

Thus, smart appliances and smart grid can play an important role in facilitating greater utilization 

of intermittently available renewable resources such as solar and wind, from which will accrue 

reductions in CO2 emissions.18 The intermittent nature of the renewables is a critical impediment 

to greater impact. By developing a truly smart grid that can shift demand to when supply is 

available, this impediment gets reduced significantly. A dynamic response system like that 

envisioned for residential usage of smart appliances will enable renewable energy to become a 

more significant part of the total energy picture. This five percent energy credit for being smart 

grid enabled may be critical to increasing the use of renewable energy. 

 

17 http://www1.eere.energy.gov/windandhydro/wind_2030.html 

18 “The Green Grid,” Electric Power Research Institute, June 2008 

Figure 7 (Source: The Brattle Group, Power of 5%)
19 

K. Smart Appliances Will Also Help Reduce Carbon Emissions

Recently, PNNL published a study that estimates the role of smart grid towards reducing carbon 

emissions.19 In particular, the study evaluated the carbon reductions through nine smart grid 

mechanisms. PNNL found that carbon emissions can be reduced directly through smart grid 

applications, and indirectly by investing the operational savings resulting from smart grid into 

renewable sources of power generation and efficiency programs. The table below (see figure 8) 

summarizes the study’s findings including the key conclusion: smart grid may facilitate a 12 

percent direct carbon reduction, and a 6 percent indirect reduction. 

Figure 8. Nine Smart Grid based Carbon Reducing Mechanisms (Source: PNNL The Smart Grid: An 

Estimation of the Energy and CO2 Benefits)

The PNNL study does not explicitly identify the role of smart appliances in carbon reductions, 

but smart appliances could play a role in several of the carbon reducing mechanisms in the above 

table. 

L. Smart Appliances Will Help Consumers Save Money

Smart appliances will also benefit the consumer. “The development of [smart grid tools for 

consumers] will enable both utilities and consumers to use electricity more efficiently, thereby 

reducing their costs.”20 For example, dynamic pricing of electricity creates the conditions that 

encourage consumers to change their or the appliances’ behavior by using appliances when the 

 

19Smart Grid: An Estimation of the Energy and CO2 Benefits, presentation to EPA, 

http://www.epa.gov/statelocalclimate/documents/pdf/pratt_presentation_3-23-2010.pdf

20 The Recovery Act Report, supra n.4, at 40. 
rates are lower, which if properly developed, will save consumers money on their total electricity 

bill. According to FERC’s Assessment of Demand Response and Advanced Metering Report, 

there were an estimated 7.95 million installed advanced meters nationwide in 2009. These smart 

meters are already helping to reduce energy costs for families and businesses.21 As stated above, 

EPRI estimates that the implementation of smart grid technologies could reduce electricity use 

by more than four percent annually by 2030, which would mean an electric bill savings of $20.4 

billion for consumers and businesses around the country each year.

22

VII. Conclusion

The Joint Petitioners recommend that the EPA and DOE adopt the Joint Proposal, providing a 5 

percent credit to the energy performance level required to meet ENERGY STAR eligibility 

criteria for smart-grid enabled appliances contained in the Joint Proposal. We believe that the 

broad consensus in support of the proposed credit will allow ENERGY STAR and the consumers 

to benefit from smart appliances and the smart grid more quickly, avoiding lost energy savings 

and savings on electricity bills. We urge EPA and DOE to expedite the adoption of this proposal 

on as accelerated a schedule as possible, but preferably no later than March 31, 2011. 

Joint Petitioners 

 Manufacturers Advocates

Kevin Messner Steven Nadel 

Vice President, Government Relations Executive Director 

Association of Home Appliance American Council for an Energy 

Manufacturers Efficient Economy 

On Behalf of – 

                                                           

21 Press Release, U.S. Department of Energy, Secretary Chu Announces Two Million Smart Grid Meters Installed 

Nationwide (August 31, 2010), available at http://www.energy.gov/news/9433.htm. 

22 Ibid. 

20
21 

Members of Major Appliance Division: Appliance Standards Awareness Project 

Whirlpool Natural Resources Defense Council 

General Electric Alliance to Save Energy 

Electrolux Alliance for Water Efficiency 

LG Electronics Northwest Power and Conservation Council 

BSH Northeast Energy Efficiency Partnerships 

Alliance Laundry Consumer Federation of America 

Viking Range National Consumer Law Center 

Sub-Zero Wolf 

Friedrich A/C 

U-Line 

Samsung 

Sharp Electronics 

Miele 

Heat Controller 

AGA Marvel 

Brown Stove 

Haier 

Fagor America 

Airwell Group 

Arcelik 

Fisher & Paykel 

Scotsman Ice 

Indesit 

Kuppersbusch 

Kelon 

DeLonghi 
ATTACHMENT I 
Energy Efficient and Sma

Appliance Agreement of 2Appliance Agreement of 2
Association of Home Appliance Manufacturers

Supporters

Association of Home Appliance Manufacturers

American Council for an Energy-Efficient Economy

Appliance Standards Awareness Project

Natural Resources Defense Council

Earthjustice

Alliance to Save Energy

Northwest Power and Conservation Council

Northeast Energy Efficiency Partnerships Northeast Energy Efficiency Partnerships

California Energy Commission

Demand Response and Smart Grid Coalition

Consumer Federation of America 

National C C onsumer Law 

Cente

r

Alliance for Water Efficiency
Agreement Overview

SAVES ENERGY/INCREASES ENERGY INDEPENDENCE

– Improves product energy efficiency and saves more tha

of 30 (U S 100 d ) f energy over 30 years (U.S. uses ~100 qua

d

s

)

SAVES WATER

– Requires and incentivizes clothes washers and dishwa

nearly 5 trillion less gallons of water over 30 years

REDUCES GHG EMISSIONS

– 30-

y g ear savin

gs ~550 MMT CO2 

SAVES CONSUMERS MONEY

– Net savings to consumers in the billions of $

SMART GRID AND ENERGY STAR SMART GRID AND ENERGY STAR

– Jump-starts the Smart Grid by helping to deploy smart 

nationwide and enable consumers to better take advan

demand

-response and real response and real

-time pricing opportunities time pricing opportunities

– Recognizes smart appliance contributions through ENE
Agreement Overview Agreement Overview

JOBS

– Impacts 46,000 manufacturing jobs (19,000 direct; 27,

chain/support) and creates new jobs, including bringinthe US j y obs that were outsourced in earlier 

years

MANUFACTURER INCENTIVES

– Incentivizes manufacturers to increase the production 

efficient products efficient products

—over and above ENERGY STAR le

over and above ENERGY STAR le

thereby saving even more energy and water and encomore job creation

DOE EFFICIENCIES DOE EFFICIENCIES

– Frees up resources now devoted to rulemakings on th

products
New Refrigerator Standar

New Refrigerator Standar

• 20

-30% energy savings relative to c

30% energy savings relative to c

standards for major product categor

• New standards take effect Jan 1 20

New standards take effect Jan. 

1, 20

• DOE to develop new test procedure 

measure ice-mak bD er energy use 

by 

D

31, 2012. This is used for standard 

eff ti 2016 ffective ~2016.
Refrigerator/Freezer Energ

S i bC av ngs 

by 

Category

% Savings % Savings Classes30% Auto defrost freezers25% Top-mount and side-by-side R/

Manual defrost freezers Manual defrost freezers

20% Bottom-mount R/F10-25% Various smaller categories

Standards are 5% lower for buStandards are 5% lower for bu

units
New Clothes Washer Stand

New Clothes Washer Stand

• Initial standards effective Jan. 1, 201

Initial standards effective Jan. 1, 201

• Different standards for top-loaders a

front

-loaders

– Top-loader standards have two phases

• Front

-loaders: 43% energy savings a

loaders: 43% energy savings a

52% water savings relative to currenstandard

• Top-loaders: 26% energy savings an

16% water savin

g ( ), 

s 

(2015), 37% ene

savings and 37% water savings (201
Clothes Washer Standard

(MEF/WF)

Category Current 2015 201

Standard

2015

Standard

201

Stan

Top-load, 1.72/8.0 2.0/

std size 1.26/9.5

/8 0 0/

Front-load, 2.2/4.5Std sizeTop

-load, 0.65/18.4 1.26/14.0 1.81

Compact

0.65/18.4 1.26/14.0 1.81

Front

-load, N/A 1 72/8 0

Compact

N/A

1.72/8.0
Clothes Dryer Standard

Clothes Dryer Standard

• 5% energy savings using current tes

5% energy savings using current tes

procedure.

• In addition test procedure modified 

In addition, test procedure modified 

address effectiveness of auto termin

This provides significant This provides significant additional e

additional e

savings from reduced over-drying.

• St d d t k ff t J 1 2015 Stan

dar

d

t

a

kes effec

t

Jan. 

1, 2015
Room Air Conditioner Stand

(Eff i J 1 2014) (Effective 

June 

1, 2014)
Dishwasher Standards Dishwasher Standards

• Improve efficiency of standard and Improve efficiency of standard and

compact dishwashers.

– Standard units to 307 kWh/yr 5 0 gal/c

Standard units to 307 kWh/yr, 

5.0 gal/c

– Compact units to 222 kWh/yr, 3.5 gal/c

• S th J l 2011 ENERGY ST

Same as the 

J

uly 2011 ENERGY ST

specification

• Reduces energy use 14% and wate

23%

• Takes effect Jan. 1, 2013
Smart Appliances Smart Appliances

• Parties will jointly petition EPA to pro

Parties will jointly petition EPA to pro

5% credit on energy use for productmeet an EP

A-set definition of “smart 

appliance”.

– Will include ability to push some energ

to off-peak periods when receive a sign

the utility.

• Parties will also work together to dev

Parties will also work together to dev

proposal for tax or other incentives f

appliances with appliances with

“smart

” capabilities capabilities.
Proposed Tax Incentives

(extension of current incentives that ex

12/31/10)
Energy and Water Savings from Stan

Energy and Water Savings from Stan
ATTACHMENT 2 
Product Class Slope Intercept

Standard size

Automatic Defrost Refrigerator-Freezers

3 Top Freezer w/o TTD ice 25% 7.35 207.0

6 Top Freezer w/ TTD ice 25% 7.65 267.0

4 Side Freezer w/o TTD ice 25% 3.68 380.6

7 Side Freezer w/ TTD ice 25% 7.58 304.5

5 Bottom Freezer w/o TTD ice 20% 3.68 367.2

5a/19 Bottom Freezer w/ TTD ice 20% 4.00 431.2

Manual & Partial Automatic Refrigerator-Freezers

1 Manual Defrost 20% 7.06 198.7

2 Partial Automatic 20% 7.06 198.7

All Refrigerators

1a Manual Defrost 20% 7.06 198.7

3a Automatic Defrost 25% 7.35 207.0

All Freezers

8 Upright with manual defrost 25% 5.66 193.7

9 Upright with automatic defrost 30% 8.70 228.3

10 Chest with manual defrost 25% 7.41 107.8

10a/20 Chest with automatic defrost 30% 10.33 148.1

Compact Size

Automatic Defrost Refrigerator-Freezers

13/15 Top Freezer and Bottom Freezer 15% 10.80 301.8

14 Side Freezer 20% 6.08 400.8

Manual & Partial Automatic Refrigerator-Freezers

11 Manual Defrost 25% 8.03 224.3

12 Partial Automatic 25% 5.25 298.5

All Refrigerators

11a Manual defrost 25% 8.03 224.3

13a Automatic defrost 25% 9.53 266.3

All Freezers

16 Upright with manual defrost 10% 8.80 225.7

17 Upright with automatic defrost 10% 10.26 351.9

18 Chest 10% 9.41 136.8

Built-ins

Automatic Defrost Refrigerator-Freezers

3B Top Freezer w/o TTD ice 20% 7.84 220.8

4B Side Freezer w/o TTD ice 20% 3.93 406.0

7B Side Freezer w/ TTD ice 20% 8.08 324.8

5B Bottom Freezer w/o TTD ice 15% 3.91 390.2

5aB Bottom Freezer w// TTD ice 15% 4.25 458.2

All Refrigerators

3aB Automatic Defrost 20% 7.84 220.8

All Freezers

9B Upright with automatic defrost 25% 9.32 244.6

Revised Standard 

Equation

January 1, 2014

Change in 

Standard

Energy Efficient and Smart Appliance Agreement of 2010

Refrigerator/Freezer

Product Description
Change in 

Standard

New Standard 

(MEF/WF)

Change in 

Standard

New Standard 

(MEF/WF)

Top-Loading, Compact (less than 1.6 

cubic feet capacity) 48%/24% 1.26/14.0 64%/37% 1.81/11.6

Top-Loading, Standard 26%/16% 1.72/8.0 37%/37% 2.0/6.0

Front-Loading, Standard 43%/52% 2.2/4.5 N/A N/A

Front-Loading, Compact (less than 1.6 

cubic feet capacity) new 1.72/8.0 N/A N/A

New Standard Jan. 1, 2015 New Standard Jan. 1, 2018

Energy Efficient and Smart Appliance Agreement of 2010

Clothes Washers

Product Description
Change in 

Standard

New 

Standard 

(EF)

Vented Electric Standard 5% 3.17

Vented Electric Compact 120V 5% 3.29

Vented Electric Compact 240V 5% 3.05

Vented Gas 5% 2.81

Vent-less Electric Compact 240V new 2.37

Vent-less Electric Combination Washer/Dryer new 1.95

January 1, 2015

Energy Efficient and Smart Appliance Agreement of 2010

Dryers

Product Description
Change in 

Standard

New Standard 

(EER)

Without Reverse Cycle w/Louvers

<6,000 15% 11.2

6,000 to 7,999 15% 11.2

8,000-13,999 12% 11.0

14,000 to 19,999 11% 10.8

20,000-27,999 11% 9.4

≥28,000 6% 9.0

Without Reverse Cycle w/o Louvers

< 6,000 13% 10.2

6,000 to 7,999 13% 10.2

8,000-10,999 14% 9.7

11,000-13,999 13% 9.6

14,000-19,999 11% 9.4

≥20,000 11% 9.4

With Reverse Cycle 

< 20,000 w/Louvers 10% 9.9

≥ 20,000 w/Louvers 11% 9.4

< 14,000 w/o Louvers 11% 9.4

≥ 14,000 w/o Louvers 10% 8.8

Casement

Casement Only 10% 9.6

Casement-Slider 11% 10.5

June 1, 2014

Energy Efficient and Smart Appliance Agreement of 2010

Room Air Conditioners

Product Description
Change in 

Standard New Standard

Standard (≥ 8 place settings plus 6 serving 

pieces) 14% & 23% 307 kWh/year &5.0 gallons/cycle 

Compact (< 8 place settings plus 6 serving 

pieces) 15% & 24% 222 kWh/year &3.5 gallons/cycle

January 1, 2013

Product Description

Energy Efficient and Smart Appliance Agreement of 2010

Dishwashers
Agreement on Minimum Federal Efficiency Standards,

Smart Appliances, Federal Incentives and

Related Matters for Specified Appliances

July 30, 2010

 THIS AGREEMENT memorializes the commitments made by the undersigned 

representatives of the organizations (the “Joint Stakeholders”) regarding joint 

recommendations for new energy and water conservation standards, test procedures, tax 

incentives and Energy Star criteria for specified major home appliances. The Joint 

Stakeholders will jointly submit to the United States Congress and the Administration 

(including, but not limited to the Department of Energy (DOE) and the Environmental 

Protection Agency (EPA)) this Agreement and the specific recommendations herein in 

such form as will facilitate their adoption. The Joint Stakeholders agree to pursue a 

multi-pronged approach designed to achieve Congressional and regulatory 

implementation of all the elements contained in the agreement. Any changes to this 

agreement must be mutually agreed to by the joint Stakeholders. 

1. The Joint Stakeholders will jointly submit to Congress and, in good faith, proactively 

seek enactment of the energy and water conservation standards contained in 

Attachment I. The Joint Stakeholders will submit to Congress recommended 

amendments to the Energy Policy and Conservation Act enacting these standards 

(Attachment II). These amendments include revised standards for 

refrigerator/freezers, clothes washers, clothes dryers, room air conditioners and 

dishwashers. 

2. Not later than August 1, 2010, the Joint Stakeholders shall submit this agreement to 

DOE. The Joint Stakeholders shall jointly propose that DOE issue final rules 

adopting each of the energy conservation standards contained in Attachment I and the 

amendments presented to Congress and will proactively advocate for DOE adoption 

of these standards. The Joint Stakeholders agree that the recommended standards 

address all of the statutory criteria that the Department is required to take into account 

in promulgating new energy and water conservation standards for the affected 

products with respect to the specified efficiency criteria. 

3. For refrigerators/freezers, clothes washers, room air conditioners and clothes dryers, 

the Joint Stakeholders shall submit comments to each product’s DOE docket 

supporting the recommendations. For refrigerator/freezers, such comment shall be 

filed not later than August 10, 2010; for clothes dryers and room air conditioners, not 

later than September 10, 2010 and for clothes washers not later than October 31, 

2010. In the case of dishwashers (for which no rulemaking is currently underway) 

not later than September 15, 2010, the Joint Stakeholders shall petition DOE to 

initiate a rulemaking and to publish a final rule by September 2011. 

4. The Joint Stakeholders have made no agreement concerning the appropriate levels for 

standby or off mode energy consumption and agree that stakeholders will comment to 
DOE as they view appropriate during DOE’s rulemaking process for each of the 

affected products, as applicable. 

5. The Joint Stakeholders agree that pending amendments to test procedures for the 

affected products should be completed by DOE, subject to input from all stakeholders 

and agree to recommend that DOE translate the standards contained in this agreement 

to equivalent levels specified under revised test procedures. 

6. The Joint Stakeholders agree to jointly petition DOE to initiate a rulemaking by 

January 1, 2012 to be completed by December 31, 2012 to revise the test procedure 

for refrigerators/freezers to incorporate measured ice maker energy use. The Joint 

Stakeholders will make good faith efforts to work collaboratively through AHAM’s 

HRF-1 task force to arrive at a joint test procedure recommendation. AHAM will 

invite the non-manufacturer signers to this agreement to designate a participant for 

the task force only for the development of this initial test procedure for 

refrigerators/freezers to incorporate measured ice maker energy use. As part of the 

petition to be filed, the Joint Stakeholders further agree to petition DOE for 

rulemaking to incorporate measured ice maker energy use into an amended 

refrigerator standard to be completed within six months of a revised test procedure 

incorporating measured ice maker energy use based on the procedure recommended 

by AHAM’s HRF-1 task force and to recommend that this amended standard take 

effect three years after a final rule is published. This commitment to petition for 

rulemaking and standards revisions applies whether a specific consensus test 

procedure is developed by AHAM’s HRF-1 task force or not. 

7. The Joint Stakeholders agree to submit the letters and attachments recommending 

certain modifications to the test procedures for refrigerator/freezers, clothes washers 

and clothes dryers contained in Attachment III, IV and V not later than August 1, 

2010. The Joint Stakeholders agree that each party may advocate for any other 

modifications to the test procedures, provided such modification is not in direct 

contradiction to the attached recommendations. 

8. The Joint Stakeholders will jointly submit to Congress recommendations for 

extending the existing federal manufacturer tax credits for specified appliances as 

described in Attachment VI. 

9. The Joint Stakeholders will in good faith jointly develop and proactively support the 

adoption of federal tax credits or other incentives for widespread deployment and 

effective integration of smart-grid enabled versions of appliances subject to this 

agreement across the United States. 

10. The Joint Stakeholders will jointly petition EPA and DOE no later than September 

30, 2010 to provide a 5% credit to the energy performance level required to meet 

ENERGY STAR eligibility criteria for smart-grid enabled appliances that are subject 

to this agreement. 

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11. Any filings, proposals or responses to DOE notices shall be consistent with this 

Agreement and the parties shall file rulemaking petitions, file comments or take other 

actions with respect to DOE or other regulatory agencies consistent with this 

Agreement. 

12. The Joint Stakeholders agree to cooperate with each other in the preparation of press 

releases and public statements in support of this Agreement. 

13. The Joint Stakeholders agree to support and cooperate with each other to obtain 

passage of the legislation described in the Agreement, including advocacy in 

Congress and to the Administration. The Joint Stakeholders agree to develop and 

jointly recommend legislative history concerning the recommended amendments. 

14. The Joint Stakeholders agree to consult with and obtain consent from all parties 

before supporting, advocating or agreeing to changes in the legislation. Such consent 

will not unreasonably be withheld. 

15. The Joint Stakeholders agree not to attempt to overturn or revise, or to file or support 

any legal or legislative challenge to, the recommendations once adopted, whether by 

Act of Congress or by rule. The Stakeholders agree to support DOE in a manner as 

each one deems to be reasonable and appropriate in defending any legal, legislative, 

or administrative challenge to a final rule that adopts the proposed standards. This 

provision will still apply if DOE, on its own volition, adopts a rule that includes 

minor deviations from Attachment I. The Joint Stakeholders agree to consult with 

respect to their responses to any deviation from the recommendations and to make 

good faith efforts to respond jointly. 

16. The Joint Stakeholders agree to implement the commitments made in this Agreement 

individually or in groups. Each Joint Stakeholder will respond in good faith to 

reasonable requests by other Joint Stakeholders for joint implementation of any of 

these commitments. 

17. Any additional mutually agreed to changes to this agreement will be provided to 

Congress and the Administration as necessitated. 

18. Nothing in this Agreement is intended to inhibit in any way efforts by individual 

stakeholders to research, develop, or market products to standards that differ from 

those contemplated by this Agreement, provided such products are in compliance 

with applicable laws and regulations. 

19. Nothing in this Agreement is intended to direct any technical or product design 

approach to achieving efficiency standards and the parties shall not take any act to 

establish any such common approach. 

20. This Agreement is hereby agreed to, in counterparts, by the undersigned Joint 

Stakeholders. This Agreement binds the undersigned Joint Stakeholders, their 

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employees, their agents, and any successors and will take effect when all signatures 

are affixed. This agreement applies until December 31, 2012, except clause 15 which 

applies until December 31, 2013. 

Joint Stakeholders

 Manufacturers Advocates

Joseph McGuire Steven Nadel 

President Executive Director 

Association of Home Appliance American Council for an Energy 

Manufacturers Efficient Economy 

On Behalf of – 

Members of Major Appliance Division: Appliance Standards Awareness Project 

Whirlpool Natural Resources Defense Council 

General Electric Alliance to Save Energy 

Electrolux Alliance for Water Efficiency 

LG Electronics Northwest Power and Conservation Council 

BSH Northeast Energy Efficiency Partnerships 

Alliance Laundry Consumer Federation of America 

Viking Range National Consumer Law Center 

Sub-Zero Wolf 

Friedrich A/C 

U-Line 

Samsung 

Sharp Electronics 

Miele 

Heat Controller 

AGA Marvel 

Brown Stove 

Haier 

Fagor America 

Airwell Group 

Arcelik 

Fisher & Paykel 

Scotsman Ice 

Indesit 

Kuppersbusch 

Kelon 

DeLonghi 

Attachments 

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(I) Recommended energy and water conservation standards 

(II) Recommended legislative amendments 

(III) Recommendations concerning refrigerator test procedures 

(IV) Recommendations concerning clothes washer test procedures 

(V) Recommendations concerning clothes dryer test procedures 

(VI) Recommended legislative amendment for tax incentives 

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