Energy Conservation Program for Consumer Products: Energy Conservation Standards for Three Cleaning Products
Federal RegisterNov 14, 1994
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DEPARTMENT OF ENERGY
Office of Energy Efficiency and Renewable Energy
10 CFR Part 430
[Docket No. EE-RM-94-403]
RIN 1904-AA67
Energy Conservation Program for Consumer Products: Energy
Conservation Standards for Three Cleaning Products
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Advance notice of proposed rulemaking.
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SUMMARY: The Energy Policy and Conservation Act, as amended by the
National Energy Conservation Policy Act, the National Appliance Energy
Conservation Act, the National Appliance Energy Conservation Amendments
of 1988 and the Energy Policy Act of 1992, prescribes energy
conservation standards for certain major household appliances and
requires the Department of Energy (Department) to administer an energy
conservation program for these products. Among other things, the Energy
Policy and Conservation Act, as amended, requires the Department to
consider amending the energy conservation standards for dishwashers,
clothes washers and clothes dryers.
The purpose of this Advance Notice of Proposed Rulemaking is to:
Present for comment the product classes that the Department is planning
to analyze; present a detailed discussion of the analytical methodology
and analytical models that the Department expects to use in performing
analyses in connection with the proposed rule; and facilitate the
gathering of information and comments prior to publishing a subsequent
notice of proposed rulemaking.
DATES: Written comments must be received by January 30, 1995.
ADDRESSES: Written comments are to be submitted to: U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, ``Energy
Efficiency Standards for Consumer Products,'' (Docket No. EE-RM-94-
403), Room 5E-066, Forrestal Building, 1000 Independence Avenue, SW,
Washington, DC 20585, (202) 586-7140.
Copies of the public comments received may be read at the
Department's Freedom of Information Reading Room, U.S. Department of
Energy, Forrestal Building, Room 1E-190, 1000 Independence Avenue, SW,
Washington, DC 20585, (202) 586-6020 between the hours of 9:00 a.m. and
4:00 p.m., Monday through Friday, except Federal holidays.
For more information concerning public participation in this
rulemaking proceeding, see section IV, ``Public Comment Procedures,''
of this notice.
FOR FURTHER INFORMATION CONTACT:
P. Marc LaFrance, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Forrestal Building, Mail Station EE-
431, 1000 Independence Avenue, SW., Washington, DC 20585, (202) 586-
7140
Eugene Margolis, Esq., U.S. Department of Energy, Office of General
Counsel, Forrestal Building, Mail Station GC-72, 1000 Independence
Avenue, SW., Washington, DC 20585, (202) 586-9507
SUPPLEMENTARY INFORMATION:
I. Introduction
a. Authority
b. Background
II. Methodology
III. Models, Data, and Assumptions
a. Engineering Performance Models and Costing Analysis
1. Appliance classes
2. Baseline units
3. Design options
4. Maximum technologically feasible designs
5. Performance models
6. Costing analysis
7. Price-efficiency relationships
8. Data sources
9. Outputs from the Engineering Analysis
b. Residential Energy Models
1. Lawrence Berkeley Laboratory Residential Energy Model
2. Residential End-Use Energy Planning System (REEPS 2.12)
c. Manufacturer Impact Models
1. Conceptual approach
2. Measures of impact
3. Lawrence Berkeley Laboratory Manufacturer Impact Model
4. Government Regulatory Impact Model
5. Cash-flow analysis of costs due to standards
6. Data sources
d. Utility Impact Model
e. Sensitivity Analyses
IV. Public Comment Procedures
a. Participation in Rulemaking
b. Written Comment Procedures
c. Issues for Public Comment
V. Review under Executive Order 12866
I. Introduction
a. Authority
Part B of Title III of the Energy Policy and Conservation Act,
Public Law 94-163, as amended by the National Energy Conservation
Policy Act, Public Law 95-619, the National Appliance Energy
Conservation Act, Public Law 100-12, the National Appliance Energy
Conservation Amendments of 1988, Public Law 100-357, and the Energy
Policy Act of 1992, Public Law 102-486,\1\ created the Energy
Conservation Program for various Consumer Products other than
Automobiles (Program).
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\1\Part B of Title III of the Energy Policy and Conservation
Act, as amended by the National Energy Conservation Policy Act, the
National Appliance Energy Conservation Act, the National Appliance
Energy Conservation Amendments of 1988, and the Energy Policy Act of
1992, is referred to in this Advance Notice of Proposed Rulemaking
as the ``Act.'' Part B of Title III is codified at 42 U.S.C. 6291 et
seq. Part B of Title III of the Energy Policy and Conservation Act,
as amended by the National Energy Conservation Policy Act only, is
referred to as the National Energy Conservation Policy Act.
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Three cleaning products (dishwashers, clothes washers, and clothes
dryers) are the subject of this Advance Notice of Proposed Rulemaking.
The National Appliance Energy Conservation Act of 1987 amended the Act
(section 325(g)) to impose prescriptive standards (design feature
requirements) for the three cleaning products as part of the energy
conservation program for consumer products. These design feature
requirements were effective for appliances manufactured on or after
January 1, 1988, and were as follows: dishwashers shall be equipped
with an option to dry without heat, clothes washers shall have an
unheated rinse option, and gas clothes dryers shall not be equipped
with a constant burning pilot. The Act required the Department to
conduct a rulemaking by January 1, 1990, to determine if the above
mentioned standards should be amended. The Act provided that any
amendment to the standards would apply to products manufactured three
years after the rulemaking. The final rule (56 FR 22279) was issued May
14, 1991, and is effective for products manufactured on or after May
14, 1994 (hereafter referred to as the May 1991 final rule). The Act
also requires the Department to conduct a subsequent rulemaking no
later than five years after the date of publication of the previous
final rule. This second round of rulemaking is the purpose of today's
notice.
Any new or amended standard is required to be designed so as to
achieve the maximum improvement in energy efficiency that is
technologically feasible and economically justified (section
325(l)(2)(A)).
Section 325(l)(2)(B)(i) of the Act provides that before the
Department determines whether an energy conservation standard is
economically justified, it must first solicit comments on the proposed
standard. After reviewing comments on the proposal, the Department must
then determine that the benefits of the standard exceed its burdens,
based to the greatest extent practicable, on a weighing of the
following seven factors:
(1) The economic impact of the standard on the manufacturers and on
the consumers of the products subject to such standard;
(2) The savings in operating costs throughout the estimated average
life of the covered product in the type (or class) compared to any
increase in the price, initial charges, or maintenance expenses for the
covered products that are likely to result directly from the imposition
of the standard;
(3) The total projected amount of energy savings likely to result
directly from the imposition of the standard;
(4) Any lessening of the utility or the performance of the covered
products likely to result from the imposition of the standard;
(5) The impact of any lessening of competition, as determined in
writing by the Attorney General, that is likely to result from the
imposition of the standard;
(6) The need for national energy conservation; and
(7) Other factors the Secretary considers relevant.
b. Background
The Department conducted the first rulemaking to determine if the
standards (design feature requirements) imposed by the Act should be
amended. The Department published an Advance Notice of Proposed
Rulemaking (53 FR 17712, May 18, 1988), a Notice of Proposed Rulemaking
(54 FR 32744, August 9, 1989), and the May 1991 final rule. The May
1991 final rule imposed energy conservation standards for the cleaning
products which are based on performance. The standards specify a
minimum energy factor for both classes of dishwashers (Standard and
Compact). Two of the five classes of clothes washers (Top-loading
Standard and Top-loading Compact) and four of the five classes of
clothes dryers (Electric Standard, Electric Compact (120v), Electric
Compact (240v), and Gas Standard) are subject to a minimum energy
factor while the remaining classes are subject to design feature
requirements. The May 1991 final rule energy conservation standards are
effective for products manufactured on or after May 14, 1994.
In the May 1991 final rule, the Department announced that it was
accelerating the second review of energy efficiency standards for
clothes washers because it became aware of a design option (horizontal-
axis wash tub in a top-loading washer) in use in Europe that was not
included in the proposed rule and upon which no comment was received.
The Department did not consider establishing a standard based on the
top-loading horizontal-axis design option because this information came
to the attention of the Department after the close of the comment
period on the proposed rule and thus was not subject to public debate.
The Department published an Advance Notice of Proposed Rulemaking (55
FR 39624, September 28, 1990, ``nine product rulemaking'') which
announced the acceleration of the second review of energy efficiency
standards for clothes washers. In response to that notice, a number of
energy efficiency advocates and appliance manufacturers requested that
the Department delay the second review until 1995-1996. The additional
time was requested in order to allow manufacturers time to implement
the standards imposed by the May 1991 final rule and to fully evaluate
new, more energy efficient technologies such as top-loading horizontal-
axis clothes washers. This additional time, manufacturers contended,
would enable them to provide more meaningful and relevant comments on
the next, legislatively required rulemaking. The Department considered
the request, and by letter, dated February 26, 1992, notified the
parties requesting the delay that the Department had determined that it
would conduct the rulemaking on the later schedule, as requested.
Today's Advance Notice of Proposed Rulemaking includes clothes
washers. Comments previously received for the September 28, 1990,
Advance Notice of Proposed Rulemaking relative to clothes washers will
be considered and addressed in the Department's Notice of Proposed
Rulemaking. Those who submitted previous comments have the option of
maintaining their previously submitted comments, amending previous
comments, or withdrawing their previous comments and submitting new
comments. The Department will address all applicable comments in the
Notice of Proposed Rulemaking.
Presently, the Department also is conducting a rulemaking on three
types of consumer products (central air conditioners and central air
conditioning heat pumps; furnaces; and refrigerators, refrigerator-
freezers, and freezers) which was initiated by the publication of a
Advance Notice of Proposed Rulemaking. (58 FR 47326, Sept. 8, 1993)
(hereafter referred to as the Three Product Advance Notice). The Three
Product Advance Notice has a detailed discussion on numerous cross-
cutting policy and methodological issues. These issues include discount
rates, environmental externalities, manufacturer impact analysis,
incremental analysis and information on any identifiable groups or
consumers who may be disproportionally affected by any proposed
national energy efficiency standard levels. The Department proposes to
use the same analytical methods in all efficiency standard rulemakings
and, therefore, the decisions on many of these cross-cutting issues
that emerge from other rulemaking processes, such as the Three Product
Advance Notice, are likely to be reflected in the proposed standards
that will follow this Advance Notice.
The Department is developing a general test procedure revision
which will address previously granted waivers, add future testing
criteria and provide test procedure clarity. This planned revision will
not change the energy consumption reporting of any product models and
will be promulgated prior to the effective date of any new standards
from this rulemaking.
II. Methodology
This section provides a brief description of the analyses to be
used to determine the impacts of the standards. It offers an overview
of the analytic methodology and discusses the major components of the
analyses: the Engineering Analysis, the Manufacturer Analysis, the
Consumer Analysis, and the Utility Analysis.
This section also discusses the interrelationships among the
components that ensure consistency throughout the analyses.
The next section, Models, Data and Assumptions, describes the
computer models used in the analyses. The models predict the
anticipated response of consumers, manufacturers, and utilities to
future changes in the economy, including the imposition of energy
conservation standards. Quantitative estimates of the impacts of
standards will be calculated from the outputs from the models. The
models that will be utilized in the analyses are:
Engineering Performance Models,
Consumer Impact Models,
Manufacturer Impact Models, and
Utility Impact Model.
The function, data sources, assumptions and validity of the results
for each model are discussed below.
The overall impact of appliance conservation standards on energy
use, consumers, manufacturers, and other factors will be determined by
comparing projections under the base case\2\ with the projections under
the proposed standards and, perhaps, by comparing the projections of
various proposed standards. The possible comparison of different
standard cases was one of the issues raised in the Three Product
Advance Notice. The analysis method chosen, based on the review of
public comments on this earlier notice, as well as, comments received
in response to today's notice, will be used in the development of the
proposed standards for the products addressed by this Advance Notice.
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\2\The base case assumes implementation of the conservation
standards that were set by the Department of Energy in the May 1991
final rule.
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The analysis that will be performed is made up of the following
items:
An Engineering Analysis that establishes the technical
feasibility and product attributes, including costs of design options,
to improve appliance efficiency.
A Manufacturer Analysis that provides an estimate of
manufacturers' responses to the proposed standards. Their responses are
quantified by changes in several financial performance measures, such
as pricing, output and profitability etc.
A Consumer Analysis that forecasts appliance sales,
efficiencies, energy use, consumer expenditures, and the national net
benefits and costs and a separate Life Cycle Cost Analysis to evaluate
the purchaser's savings in operating expenses relative to increases in
purchase price.
A Utility Analysis that measures the projected impacts of
the altered energy-consumption patterns on electric and gas utilities.
Each analysis area will be performed for each of the three products
under consideration. The results of the Engineering Analysis will be
reviewed by the Department to determine whether standards for each
product could yield measurable energy savings. If standards would not
yield energy savings, then the analysis will be terminated. If energy
savings are possible, then a detailed analysis is performed.
There is interaction among the Engineering, Consumer, Utility, and
Manufacturer Analyses. The Engineering Analysis examines appliance
designs and related attributes such as efficiency and costs. Based on
the relationships between the prices and efficiencies of design
options, the Consumer Analysis forecasts sales and efficiencies of new
and replacement appliances. These data are used as inputs to the
Manufacturer Analysis to determine the financial impacts on
prototypical firms within the industry. The Consumer Analysis forecasts
national aggregate energy savings and consumer expenditures associated
with the purchase and operation of the appliances. Consumer
expenditures (both purchase and operation) are employed in the Life-
Cycle Cost Analysis to determine consumer impacts. Changes in sales,
revenues, investments, and marginal costs of utilities are calculated
from the energy savings in the Utility Analysis.
Three periods of time are used in the analyses. First, the
Engineering Analysis examines the technical feasibility of improving
the efficiency of the covered products by analyzing design options
available today to improve product efficiency, whether they are
commercially available or prototypes. Second, the Manufacturer Analysis
is performed for a typical year after the standards are assumed to have
been imposed. Typically, the fifth year is selected, so all major
impacts of a standard would have occurred. Third, the Consumer Analysis
examines impacts over a time period at least as long as the average
lifetimes of the products.
III. Models, Data, and Assumptions
a. Engineering Performance Models and Costing Analysis
The Engineering Analysis addresses two statutory requirements. The
first requirement is that the Department consider only improvements in
energy efficiency that are technologically feasible. The second is that
the Department consider any lessening of utility to the consumer due to
the imposition of standards. In addition, the Engineering Analysis
provides information on efficiencies, energy consumption, manufacturing
costs, and maintenance and installation costs for use in the other
analyses.
The Engineering Analysis develops cost and efficiency data for a
set of design options within each appliance class. These data are the
output of the engineering performance models and costing analysis
discussed in subsections 5-9, below.
1. Appliance Classes
The first step in the Engineering Analysis is to segregate product
types into separate classes to which different energy conservation
standards apply. Classes are differentiated by the type of energy use
(oil, natural gas, or electricity) or capacity or performance-related
features that provide utility to the consumer and affect efficiency.
Classes are differentiated in order to ensure that consumer products
having different capacities or other performance-related features
affecting efficiency and utility remain available to consumers.
For each of the three appliances, the following are the classes
that the Department proposes to consider. The Department welcomes
comments on the proposed classes.
(i) Dishwashers
Compact Dishwasher (less than 22 inches in exterior width)
Standard Dishwasher (equal to or greater than 22 inches in exterior
width)
(ii) Clothes Washers
Compact (less than 1.6 ft\3\ capacity)
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\3\The energy factor is a measurement of energy efficiency
derived from the Department of Energy test procedure for that
product.
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Standard (1.6 ft\3\ or greater capacity)
(iii) Clothes Dryers
Electric, Standard (4.4 ft\3\ or greater capacity)
Electric, Compact, 120v (less than 4.4 ft\3\ capacity)
Electric, Compact, 240v (less than 4.4 ft\3\ capacity)
Gas, Standard (4.4 ft\3\ or greater capacity)
Gas, Compact (less than 4.4 ft\3\ capacity)
In the case of clothes washers, the Department is proposing to
eliminate certain previously defined classifications (Semi-Automatic
Top-Loading, Front-Loading and Suds Saving) because they do not offer
any added utility which is inherently less energy efficient and
therefore would require protection from the energy conservation
standards. In the May 1991 final rule, these classes were not subject
to a minimum energy conservation standard imposed because they
represented a small portion of the market, and due to a lack of
adequate information the Department did not analyze them. However, the
1988 standard requiring an unheated rinse option is still applicable to
these classes. The Department has further reviewed this topic and
believes that these products should be subject to the minimum energy
conservation standards applicable to either compact or standard clothes
washers. The Department welcomes comments on this issue.
2. Baseline Units
For the purpose of generating a cost/efficiency relationship, the
Engineering Analysis needs to define a starting point or baseline. The
assumed baseline unit is to represent a typical model within an
appliance class sold during the initial year of the analysis, e.g., a
unit that minimally exceeds the existing standard. Once identified,
each baseline unit is characterized by its efficiency-related design
options. The Engineering Analysis uses information gathered from trade
organizations, manufacturers, and consultants with expertise in
specific product types to determine the engineering characteristics of
the baseline unit. The Department requests data on specific units and
combinations of design options to be considered as a baseline unit. In
addition, the Department requests comments on any other factors to be
considered in selecting baseline units.
3. Design Options
The Engineering Analysis will identify an individual design option
or combinations of design options with a potential for improving energy
efficiency. Design options that are currently on the market, that are
being developed, or that may be on the market by the time standards are
effective will be considered. Furthermore, the Department requests
comments on whether the existing test procedures are appropriate for
measuring product energy use and efficiency and whether the test
procedure can evaluate a particular design option's contribution to the
product's energy consumption.
In addition to proposing a credit for more efficient water
extraction in the clothes washer test procedure, the Department may
consider a two tier energy conservation standard for clothes washers.
One standard would be the same as the existing performance standard for
clothes washers and the second standard would require a minimum water
extraction. The Department believes that mechanical water extraction is
much more cost effective than thermal extraction. If the Department
were to propose this two tier standard, then the analysis for the
clothes dryer standard would consider the impact of drier clothes
entering the clothes dryer. The Department welcomes comments on this
issue.
The Department requests comments on both the design options listed
below and the applicability of the extant or proposed test procedure.
The following is a list of design options that will be examined:
(i) Dishwashers
Energy Savings Options for Water Reduction:
(A) Improved food filter
(B) Improved spray arm geometry
(C) Improved fill control
(D) Modified sump geometry with & without dual pumps
(E) Microprocessor controls and fuzzy logic (algorithm logic based on
sensor input)
Other Energy Saving Options:
(F) Reduced inlet water temperature
(G) Improved motor efficiency
(H) Increased insulation
(I) Flow-thru heating
(J) Ultrasonic washing
(ii) Clothes Washers
(A) Improved fill control
(B) Configuration/tolerance of inner and outer tubs to reduce water use
(C) Reduce thermal mass
(D) Added Insulation
(E) Increase motor efficiency
(F) Thermostatically controlled mixing valves
(G) Electrolytic dissociation of water
(H) Ultrasonic washing
(I) Higher spin speed
(J) Horizontal axis design
(K) Bubble action
(L) Microprocessor controls and fuzzy logic (algorithm logic based on
sensor input)
(M) Ozonated laundering
(N) Suds saving
(O) Direct drive motor
(iii) Clothes Dryers
(A) Automatic termination
(B) Increased insulation
(C) Recycle exhaust heat
(D) Inlet air preheat
(E) Inlet air preheat, condensing mode
(F) Modified operating conditions
(G) Heat pump
(H) Microwave
(I) Reverse tumble feature
(J) Improved rib design to reduce drying time
4. Maximum Technologically Feasible Designs
The Act requires that, in considering any new or amended standards,
the Department must consider those that ``shall be designed to achieve
the maximum improvement in energy efficiency that the Secretary
determines is technologically feasible and economically justified''
(section 325(l)(2)(A)). As a first step, the maximum technologically
feasible level will be identified. The maximum technologically feasible
level is one that can be carried out by the addition of energy
efficient design improvements to the baseline units without affecting
the product's utility. The Department believes that the design options
comprising the maximum technologically feasible level must have been
physically demonstrated in at least a prototype form to be considered
technologically feasible.
5. Performance Models
In the Engineering Analysis, the Department's estimate of the
efficiency of various design options and combination of design options
will be based on either calculation (e.g., computer simulation models)
or experimental data based on the Department's test procedures. The
Department requests test data on the efficiency of the various design
options and information on possible simulation models for use in this
rulemaking.
6. Costing Analysis
Manufacturer cost data for baseline units and incremental costs for
design improvements are requested. The cost data requested include, for
each design option, incremental cost data disaggregated into labor,
purchased parts, materials, shipping/packaging, and tooling. Also
requested are any additional consumer installation or maintenance costs
resulting from the design improvements.
7. Price-Efficiency Relationships
The results of the Engineering Analysis are summarized in the cost-
efficiency relationships that show the efficiency, unit energy
consumption, and manufacturer cost of each design option and
combination of design options for each appliance class. Manufacturer
and dealer markups obtained from the Manufacturer Impact Analysis are
applied to the manufacturing costs to determine the purchase price of
the appliance. The price-efficiency relationships are a fundamental
input to the Consumer Analysis.
8. Data Sources
Shipments data, costs of purchased materials and parts, and
engineering and labor cost data will be based on available information,
including information received in comments on this Advance Notice of
Proposed Rulemaking and collected from industry sources.
9. Outputs From the Engineering Analysis
For each combination of design options considered, the models and
data provide:
Energy efficiency (expressed as the Department's energy
factor),\3\
Annual energy consumption per unit (based on the
Department's test procedures),
Increased material, purchased parts, labor, and investment
costs for medium\4\ and large manufacturers by product class,
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\4\As was the case with previous analyses, small manufacturers
will not be analyzed separately. No general manufacturing approach
could be identified for these firms because of the wide variability
in their approach to manufacturing. Therefore, small manufacturers'
costs have been assumed to equal those of medium manufacturers. The
Department encourages small manufacturers to submit data.
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The relationship between cost and efficiency level by
product class, and
Other information on product characteristics, such as
lifetimes, maintenance costs and installation costs.
b. Residential Energy Models
The Department has used the Lawrence Berkeley Laboratory
Residential Energy Model (LBL-REM) in the analysis and reanalysis for
numerous Department rulemakings. The Department has considered
replacing the LBL-REM with the Electric Power Research Institute's
REEPS model and is presently analyzing it for the Three Product Advance
Notice rulemaking. The Department expects to use the analytical method
chosen for that rulemaking in the analysis for this rulemaking. The
Department welcomes comments on this approach. Below is a description
of both models.
1. Lawrence Berkeley Laboratory Residential Energy Model
The LBL-REM forecasts the appliance purchase choices that
households make as well as their subsequent appliance usage behavior
and energy consumption. The model uses engineering estimates of the
characteristics of particular designs of appliances and calculates the
national impacts of a technology-specific policy on the populations of
appliances used in the households. Alternative designs are
characterized by price and efficiency. The output from the LBL-REM
provides estimates of national energy savings and consumer economic
impacts (including equipment and operating expenses).
Engineering, economic, and demographic data are used in the LBL-
REM. The engineering data for appliances include the price-efficiency
relationships described above. Additional data include information
regarding alternative building shell construction measures and costs,
unit energy consumption and efficiency of existing appliances, age
distribution of existing appliance stock, and retirement functions.
Economic data include projected energy prices\5\ and household income,
models of energy investment, appliance purchase and usage behavior,
including fuel and technology choice for each end use. Demographic data
include number of households by type, projected housing starts and
demolitions, and initial appliance holdings.
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\5\ The projections of energy prices will be taken from the most
recent Annual Energy Outlook, a publication of the Department's
Energy Information Administration.
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Structure of the model. The LBL-REM segments annual energy
consumption into house types, end uses, and fuel types. The house types
are single-family, multifamily, and mobile homes. Calculations are
performed separately for existing and new housing construction each
year over the period 1980-2030. The end uses are space heating
(including room and central), air conditioning (room, central
conventional, and central heat pump), water heating, refrigeration,
cooking, clothes drying, lighting, clothes washing, dishwashing, pool
heating, televisions and miscellaneous. Up to four fuels are
considered, as appropriate to each end use: electricity, natural gas,
heating oil, and liquid petroleum gas. The model exists in two
versions: national (one region) and regional (10 Federal regions).
Since usage of cleaning products is not likely to differ by geographic
location, the national version will be utilized in this analysis.
The model projects five types of activities: technology/fuel
choice; building shell thermal integrity choice; appliance efficiency
choice; usage behavior; and turnover of buildings and appliances.
Housing stock submodel. This submodel generates data about housing
stock projections for the LBL-REM. The number of occupied households,
by type, is taken from the 1990 Census of Population and Housing. An
exogenous projection for housing starts is obtained, and estimates of
projected demolition rates by house type are calculated, assuming an
exponential function. The housing submodel determines the projected
housing stock each year, 1981-2030, by subtracting demolitions from
existing stock, then adding starts. The annual demolition rates by
house type will be calculated for single-family, multifamily, and
mobile homes, respectively.
Efficiency choice algorithm. Historical efficiency data are
available primarily from trade associations for selected years for each
class of appliance through at least 1992. The Federal energy
conservation standards for new units of these appliances are expected
to be met by the effective date of the standard. After that date,
future efficiency improvements are assumed to be a function of designs
available (according to the engineering analysis) and of relevant
energy prices. The forecasting algorithm is designed to allow annual
average efficiency or shipment-weighted efficiency factors to increase
if either more efficient designs become available at lower prices or
energy prices increase. Conversely, if energy prices decrease, the
shipment-weighted efficiency factors may decline, but would have a
lower bound at the existing standard level, i.e., the 1991 standard
prescribed by the Department, effective 1994, for dishwashers, clothes
washers and clothes dryers.
Thermal integrity. The LBL-REM addresses thermal integrity as an
input into the model for conducting analysis on appliances which affect
a dwelling's cooling or heating load. The Department believes that
thermal integrity will not be a factor in the analysis for the three
cleaning products. The Department welcomes comments on this assumption.
Modeling efficiency standards. The LBL-REM projects the average
efficiency of new products; for example, clothes dryers purchased each
year in the absence of additional Federal regulations. A distribution
of efficiencies is constructed around the average based on efficiency
distributions observed in the marketplace. This information includes
information from industry sources and published data from the industry
trade associations. A new Federal standard level eliminates part of the
distribution; therefore, a new distribution is constructed. The new
shipment-weighted average efficiency then characterizes the efficiency
of new units in that year. The same process is applied to all years
after implementation of the standard. The model is then run again for
the standards case\6\with the adjusted average efficiencies to
calculate any changes in market shares or usage behavior that may occur
as a result of standards and to calculate the net energy savings.
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\6\The standards case refers to a time period when a potential
new standard has been implemented.
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Turnover of appliance stocks. The initial age distribution of
appliances in stock is based on industry data about historical annual
shipments. The fraction of each product that retires each year is based
on the number of years since purchase of the product. For each year's
purchase, the model associates an average efficiency, so that when
older appliances are retired, they are also recognized as less
efficient. All appliance replacements are included in the retirement
function, including those resulting for reasons other than product
failure. However, the analysis does not explicitly consider the effect
of increased purchase price on the turnover rate. The Department
requests data and comments on how to consider this factor.
The number of potential purchasers of an appliance in new homes is
equal to the number of new homes constructed each year. The number of
potential purchasers of appliances in existing houses is equal to the
number of retiring appliances plus (if applicable) a fraction of those
households that did not previously own the product.
Calculation of market shares. Potential purchasers may purchase any
competing technology within an end use or none. For each end use, long-
term market share elasticities are estimated with respect to equipment
price, operating expense, and income, respectively. The effect of
standards is expected to be lower operating expense and increased
equipment price. The percentage changes in these quantities are used,
together with market share elasticities, to determine changes in market
share resulting from standards. The model assumes that higher equipment
prices will decrease sales volumes while lower operating expenses will
increase them. The net result (predicted market share) depends on the
standard level selected with its associated equipment prices and
operating expenses.
Usage behavior. For some products changing the operating expense
results in changes in usage behavior. These changes are modeled based
on usage elasticities in operating expense and income. For dishwashers,
clothes washers and clothes dryers we expect these elasticities to be
at or near zero; usage behavior is not influenced by the cost of
operating the appliance. On the other hand, the popularity of certain
``energy saving'' features, such as air (in lieu of heated) drying on
dishwashers suggests that some consumers alter their behavior in
response to operating costs. The Department requests comments on this
assumption.
Energy consumption calculations. The total energy consumption per
house for each end use and fuel by house type and vintage (existing or
new) is the product of the unit energy consumption (accounting for
efficiency and capacity changes) and usage factor, e.g., relative hours
of full-load use for dishwashers. The corresponding annual energy
consumption for all households is the annual consumption per household,
times the number of households of that type and vintage, times the
fraction of those households owning that appliance.
Aggregate energy consumption is obtained by summing intermediate
results. For example, national electricity consumption for residential
dishwashing in a particular year is the sum across house types and
house vintages of electricity used by compact and standard dishwashers.
National residential electricity consumption in that year is the sum of
all end uses of electricity consumption in the residential sector.
Model outputs. The principal outputs from the LBL-REM for each year
are:
Energy consumption by end use and fuel,
Total residential energy consumption by fuel,
Per-unit equipment price and operating expense by product,
Projected annual shipments of residential appliances, and
Differences in these quantities between a base and a
standards case.
These outputs are provided annually (or for selected years) and
cumulatively over a period of time, e.g., 1999-2030. Energy savings are
provided annually from implementation of standards to the end of the
period. Net present value of standards is evaluated for each regulated
product and for the end use(s) comprising the regulated and competing
products.
Energy savings are calculated as the difference in energy
consumption between the base case and standards case. Energy
consumption in both the base case and standards case includes changes
in fuel choice or changes in usage behavior. Therefore, the energy
savings capture the net energy savings due to regulation, including the
effects induced by shifts in market share or changes in usage behavior.
Net present value, on the other hand, excludes these types of
effects.\7\ Net present value is calculated from per-unit changes in
equipment and operating expenses, multiplied by standards case
shipments. If the net present value were calculated without normalizing
with regard to shipments, erroneous results would be obtained. If
standards caused decreased purchases of a product, this would appear as
an economic benefit; namely, less money spent on purchasing and using
appliances.\8\ If standards resulted in increased purchases, this would
be incorrectly counted as a cost when it reflects consumers' preference
for the post-standards product.
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\7\Present value is the discounted total value of energy
consumption during the appliances' lifetimes, plus the discounted
equipment costs for those appliances that are purchased during those
periods at alternative standards levels. The difference between a
standards case and a base case is the net present value attributable
to amended standards. A positive net present value for an appliance
at a given standard level indicates that, if that standard were
adopted, consumers of that appliance as a whole would save that much
more money in fuel costs, discounted to the present, than they would
pay in increased initial price for a more efficient appliance,
discounted to the present, compared to the base case.
\8\Without normalization, the greatest economic benefit would be
obtained by a standard level that resulted in no future purchases of
the product. Then no money would be spent on purchasing the product
or on operating expenses, and the value of the savings would equal
the amount of money that would have been spent without the standard.
This would clearly be a misrepresentation of the net present value
of standards.
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Base case usage is assumed in calculating the net present value
since any ``rebound effect''\9\ reflects the consumer's judgment that
increased usage is worth more than the direct energy savings associated
with keeping usage constant. Therefore, deduction of any foregone
energy savings resulting from a possible ``rebound effect,'' prior to
calculating the net present value, would result in an underestimate of
the true net present value associated with a given efficiency
improvement.
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\9\The ``rebound effect'' is the projected energy savings from
an efficiency improvement that does not occur. This results when
purchasers of more energy efficient appliance use them more
intensively, thereby saving less energy than the engineering
estimates would have indicated. In some instances, the rebound is
zero.
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Other Impacts. In determining economic justification, the Act
directs the Department to consider a number of different factors. Among
these factors are requirements that the Department consider the
economic impact of the standard on consumers. In this regard, the Act
establishes a rebuttable presumption that a standard is economically
justified if the additional product costs attributable to the standard
are less than three times the value of the first year energy cost
savings. Also, the Department is required to consider changes in the
life-cycle costs resulting from the standard.
Taking into consideration these various requirements, the
Department calculates:
The estimated simple payback of additional product costs
(based on estimated changes in product purchase prices) by the energy
cost savings projected to result from the proposed standard.
The estimated changes in life-cycle costs to the consumer
likely to result from the proposed standard, and
The net present value of estimated savings to the Nation
of the proposed standard.
The calculation of both consumer life-cycle costs and national net
present costs/benefits require the use of appropriate discount rates.
The discount rate used in such calculations is intended to approximate
the time-value of money of those who would bear the additional product
prices resulting from a proposed standard and who would also,
presumably, benefit from the resulting savings in energy expenses.
Consequently, the most appropriate discount rate depends on the
characteristics of the individual consumers, businesses, or other
persons affected by a proposed standard. The Department expects to use
the same discount rates for this notice as are selected as a result of
the Three Product Advance Notice. The Department welcomes comments on
this issue.
The Department recognizes that there are external societal benefits
(and possibly costs) that are generated from appliance standards. These
are principally the value of reductions in oil imports and the
reduction in projected emissions of SO2, NO2 and CO2. It
has been suggested that the appliance standards resulting from this
rulemaking will not create any SO2 or NO2 savings beyond
those that will be required by the Clean Air Act of 1990 (P.L. 101-549,
November 15, 1990). If that proves to be true, then the emissions
reductions from standards that do occur will accrue to those deriving
the reductions (which are principally electric utilities) by displacing
the measures that those firms would otherwise utilize to achieve their
required reductions of SO2 and NO2. In that case, the
SO2 and NO2 reductions from standards would represent a cost-
free way for those firms to achieve their savings, and, as such, would
have some value to those firms realizing the reductions. The actual
value that will be realized from appliance standards-induced reductions
of SO2 will be the market-determined dollar value placed on the
pollution credits that are earned. Such credits can be used by the firm
realizing the credits, ``banked'' for future use, or sold for use or
``banking'' by others.
In previous rulemakings, the Department identified benefits
resulting from national energy savings and emissions reductions, but
did not attach any monetary value to these benefits because of the
considerable uncertainty of such estimates. However, in order more
explicitly to consider such externalized benefits (or costs), the
Department will attempt in this rulemaking to establish values for
these benefits, if a sound analytical basis can be found. The
Department has recently published a Supplemental Advance Notice (59 FR
51140, October 7, 1994) to the Three Product Advance Notice; this
Supplemental Advance Notice presents considerations that would need to
be made in developing a sound analytic basis for monetizing
externalities.
The Department is concerned about the impact to any identifiable
groups or consumers who may be disproportionally affected by any
proposed national energy efficiency standard levels. The Department
requested comments on a methodology for addressing this issue in the
Three Product Advance Notice. The Department expects to follow the
policy regarding the consideration of such disproportionate impacts
that emerges from the consideration of comments on the Three Product
Advance Notice in this rulemaking. The Department welcomes comments on
this issue.
2. Electric Power Research Institutes Residential End-Use Energy
Planning System (REEPS 2.12)
REEPS has been used since the early 1980s both as a tool for
national residential policy analysis and subsequently as an analytical
tool for electric utilities to forecast long-term residential energy
demand. The current version of the model, REEPS 2.12, simulates the
energy consumption behavior of specific household segments.
REEPS 2.12 incorporates the basic features of residential end-use
forecasting into a generalized modeling framework in which the user has
considerable control over the algorithms and model structure. This
framework provides greater flexibility over more traditional models
which are ``hardwired'' for particular formulations of residential
sector energy use. This facilitates implementation of a wide range of
scenarios and policies at varying levels of disaggregation without ever
changing the computer program itself.
Space conditioning and appliance modeling. REEPS 2.12 provides a
separate modeling framework for space conditioning end-uses and another
for household appliances, like refrigerators, clothes washers, etc.
These frameworks are referred to as the HVAC module and appliance
modules. Exogenous variables include macroeconomic projections such as
income and household size and other external parameters specified by
the user. Fuel price projections are implemented as exogenous time
series for each fuel and rate class used in the model. Household data
allows the user to forecast changes to the housing stock based on
separate decay rates for each housing type and vintage block.
HVAC module/thermal shell. REEPS 2.12 has an HVAC module which
deals with space conditioning equipment and the thermal shell. The
module has various parameters such as fuel choice, system capacity,
efficiency levels, etc.. The Department believes that these issues will
not be a factor in the analysis for the three cleaning products because
these products do not impact the thermal characteristics of the
dwelling. The Department welcomes comments on this assumption.
Appliance module. The REEPS 2.12 Appliance Model provides a
generalized structure for characterizing purchases and energy
consumption of appliances. This model will be used to analyze the three
cleaning products if the Department decides to adopt REEPS. Working
within the REEPS framework, users of the model configure economic and
energy data on appliances and define functional relationships to model
changes in energy consumption in future years. Demographic segmentation
allows the user to define different segments of the appliance market
based on household characteristics such as income or household size and
differentiate purchase decisions across these segments. These other
input sets precede the specification of the appliance models themselves
because they define important elements of appliance model structure,
such as the housing types specified in the Households module. Data from
these input sets are used as drivers in forecasting the size,
characteristics, and usage of the appliance stock.
The REEPS 2.12 Appliance Model is a vintaged capital stock or stock
flow-adjustment model that maintains accounts of appliances by vintage
year. REEPS 2.12 uses a state-based approach to forecasting in which
purchase decisions are explicitly modeled at the household level. The
state-based approach differs from a saturation approach to appliance
modeling, in which the saturations or market shares are modeled and the
difference from the current ownership patterns are attributed to
appliance purchases. The ``state'' of a given appliance model in a
given year determines the energy consumption for that appliance by
tracking five key variables throughout the course of the forecast:
size, efficiency, usage, market share and the number of households.
Appliance size, efficiency and usage are defined by the user in the
units and values appropriate for a given end-use and/or appliance.
Three general modeling steps are executed for each appliance end-
use: (1) Base-year calibration, (2) decision-model calibration, and (3)
forecast execution. In the base-year calibration, the Appliance Model
is compared with the input housing stock and demographic
characteristics to check for values that are disaggregated by housing
type and demographic segment. Usage is adjusted to be consistent with
stock Unit Energy Consumption values and vintage block information on
vintage block shares, efficiencies and sizes. In the second step,
decision-model calibration, the decision models are adjusted to fit the
control values specified in the first forecast year. These control
values are referred to as ``control-year'' data, and include the
marginal appliance efficiencies and new purchase shares. Finally, in
the forecast execution step, decision models are used to predict new
appliance ownership shares and efficiency choices. The algorithmic
procedures in each of these three steps are detailed in the technical
documentation for the Appliance Model.
Policy modeling. The flexibility of REEPS 2.1 allows the user to
model a number of policies through the judicious modification of the
appropriate parameters, equations, structure, and addition of new
technologies. Government and utility policies have the potential to
restrict appliance efficiency levels, energy prices, financial criteria
for new equipment purchases, early retirement of appliances, and rates
of technical innovation. The policy choices in REEPS 2.12 include:
Energy prices, functional forms and coefficients for choice equations,
pre-failure replacement conversion decision algorithm, restrictions on
legal or market availability of specific technologies, and modification
of specific technologies, purchase prices or efficiencies.
c. Manufacturer Impact Models
1. Conceptual Approach
The manufacturer impact analysis estimates the overall impact of
new or amended standards on an industry's profitability and scale of
operation.
2. Measures of Impact
The analysis examines two types of long-run impact: profitability
and growth. Consequently, five measures of impact are reported. They
are: shipments, prices, revenues, net incomes and returns on equity.
Return on equity is the primary measure of profitability, assets and
income provide the primary measures of growth. At the request of
appliance manufacturers, a new measure, net present value of the
industry, will also be reported.
Two short-run impacts are also analyzed. First, the ability of the
industry to provide the one-time investments required to meet the new
standard is examined. Second, if standards result in decreased sales
for the particular industry being analyzed, the analysis examines the
possibility of price-cutting while the industry is adjusting to a lower
sales volume.
3. Lawrence Berkeley Laboratory Manufacturer Impact Model
In order to estimate the impacts of energy efficiency standards, a
computer spreadsheet model, the Lawrence Berkeley Laboratory
Manufacturer Impact Model (LBL-MIM), was developed.
The LBL-MIM was developed at Lawrence Berkeley Laboratory in 1988.
Since its inception, it has evolved and has been used in the analysis
and reanalysis for numerous Department rulemakings.
The LBL-MIM models the cumulative effects of standards on the
future of the industry, and by means of present value formulas presents
the effects on an annualized basis.
Ideally, a manufacturer analysis should look at the impact of a
proposed regulation on every firm that does business in the industry
under question. However, because the industries being analyzed have
many manufacturers making a particular product, a firm-by-firm analysis
is not feasible. In addition, the engineering and financial data for
most manufacturing firms are proprietary and are not routinely
available for public analysis. Because of these limitations on data and
resources, the LBL-MIM models a prototypical firm. In many cases this
firm represents a division of a larger firm. Therefore, a prototype
firm is a hypothetical firm representative of a portion of the
industry. Prototypical firms are defined by parameters that are
important for determining the impacts of standards and are consistent
with data for the portion of the industry they represent. Important
parameters used in the model include the cost structure of the firms,
profitability ratios, relative costs of complying with the new
standard, and marketing strategies.
Revenue is affected by both price and shipments. Price is
determined by computing the markup over long-run marginal costs and
then using the markup to determine an optimal price. Demand is
determined by price and operating expense elasticities, coupled with
the changes in price and operating expenses resulting from the
standards.
The LBL-MIM produces several outputs used in analyzing the impact
of standards on manufacturers. A simplified pro forma income statement
is prepared for each prototypical firm. In addition to the income
statement, five main variables--shipments, prices, revenues, net
incomes, and returns on equity--are reported. The results are presented
for the without-standards (or without amended standards) case and the
with-standards (or with amended standards) case, and the relative
differences between the two are also given.
4. Integration of the Lawrence Berkeley Laboratory Manufacturer Impact
Model and the Government Regulatory Impact Model
As part of its comments submitted to the Department for the
rulemaking on nine consumer products (comments No. 61D and 61E dated
July 1991 and September 9, 1991, respectively), the Association of Home
Appliance Manufacturers (AHAM) proposed an alternate approach to the
LBL-MIM for the analysis of manufacturer impacts. The AHAM's approach
was formalized as a computer spreadsheet by the Arthur D. Little
consulting firm. It was named the Government Regulatory Impact Model
(GRIM) and was formally proposed to DOE by representatives of the AHAM,
the Air-Conditioning and Refrigeration Institute, the Gas Appliance
Manufacturers Association, and Arthur D. Little on April 15, 1993.
The primary functional differences between GRIM and LBL-MIM are
GRIM's use of an annual cash-flow analysis for manufacturer costs and
restriction to cost predictions. DOE has analyzed the GRIM's cost
approach and found that, given identical inputs, its results were
similar enough to those of the cost section of the LBL-MIM that the
LBL-MIM outputs are not significantly affected by the use of the GRIM.
Because the cash-flow approach to manufacturer costs is simpler and
more transparent to the industry, DOE intends to analyze the GRIM cost-
analysis methodology and may integrate the model into the LBL-MIM as a
replacement for the cost analysis section of the LBL-MIM. The analysis
of the GRIM and possible adoption will be determined in the Three
Product Advance Notice rulemaking and the Department expects to use the
same methodology in this rulemaking. The Department welcomes comments
on this issue.
If the GRIM is adopted, then the capabilities of the LBL-MIM
necessary to the analysis but not found in the GRIM, such as price and
shipments forecasting, will be retained. The GRIM's measure of impact
and industry net present value would be included as part of the LBL-
MIM's primary measures of impact.
5. Cash-Flow Analysis of Costs Due to Standards
A change in standards affects the analysis in three distinct ways.
Increased levels of standards will require additional investment, will
raise production costs, and will affect revenue through higher prices
and, possibly, lower quantities sold.
The integrated model using the GRIM cost analysis uses a number of
factors--annual expected revenues; manufacturer costs such as costs of
sales, selling and general administration costs; taxes; and capital
expenditures related to depreciation, new standards, and maintenance--
to arrive at a series of annual cash flows beginning from before
implementation of standards and continuing explicitly for five years
after implementation.
The measure of industry net present values are calculated by
discounting the annual cash flows from the period before implementation
of standards to some future point in time.
The revenues are supplied by the price and shipments forecasting
algorithms from the LBL-MIM.
6. Data Sources
The models need data that characterize both a particular industry
and prototypical firms within that industry. Estimates of data are
based on information from five general sources: Lawrence Berkeley
Laboratory business consultation groups; the Engineering Analysis; the
Consumer Analysis; public financial data; and industry profiles.
d. Utility Impact Model
Electric utility impact model. The electric utility analysis serves
three purposes within the overall assessment of the impact of the
proposed standards. First, it contributes to quantifying the energy
savings by determining the reduction in fossil fuels used for
electricity generation. Second, the estimated reduction in fossil fuel
consumption is an input to the Environmental Assessment, as required by
the National Environmental Policy Act. And third, by calculating
utility avoided costs, it provides marginal electricity costs. Avoided
cost is calculated by assessing the impacts on the electric utility
industry in terms of changes in investment, revenue requirements, and
residential load factors.
The electric utility analysis adopts the standard approach that the
value of electricity savings, based on marginal costs, can be broken
down into energy savings and capacity savings. The energy component
reflects the avoided cost of fuel not burned at the powerplant by the
reduced need to generate electricity. The capacity component measures
the avoided cost of financing and building extra generating capacity.
The analysis characterizes these avoided costs per KWh of heating,
cooling, and baseload energy saved. The heating and cooling energy
includes baseload and peak energy. These values are used to calculate
societal benefits from reduced electricity consumption.
The Electric Utility Impact Model calculates avoided energy costs
based on a disaggregation of the generation fuel mix to the National
Electric Reliability Council regions and a simplified load duration
curve for each region. First, the model allocates national electricity
savings that are forecasted by the LBL-REM to National Electric
Reliability Council regions in proportion to their current consumption
of heating, cooling, and baseload energy. The regional proportions are
derived from data on regional appliance saturations, efficiencies, and
hours of use. The fraction of the electricity that would have to be
generated at the margin from oil and gas is calculated from the total
regional oil and gas fraction and the simplified load duration curve.
Projected utility natural gas and coal prices, weighted by the oil and
gas fraction and the non-oil and gas fraction, respectively, are used
to calculate utility marginal costs over the forecast period. The
marginal costs are adjusted to account for seasonal differences.
The avoided capacity cost calculation in the model is based on
conservation load factors for the energy savings attributable to the
standards as well as the capacity costs of a combustion turbine. A
conservation load factor is defined as the average hourly energy
savings of a conservation measure divided by its peak load savings. The
conservation load factors are a way of characterizing the peak demand
savings of a conservation measure. They are used to convert the
capacity value of the standards into the per-kWh values described
above. The National Electric Reliability Council forecasts of capacity
requirements for each region are used to account for regional
variations in reserve margin. If the National Electric Reliability
Council forecasts an adequate reserve margin in a region for a given
year, no value is given to the capacity savings in the region.
The inputs needed for the Utility Impact Model are conservation
load factors, state-level utility fuel prices, appliance saturations,
efficiencies, and hours of use as well as electricity generation by
fuel type and capacity need by National Electric Reliability Council
region. The outputs of the analysis are fuel savings, reduction in the
need for new generating capacity, and avoided energy and capacity costs
for heating, cooling, and baseload appliances per million Btu's of
resource energy.
Gas utility modeling. Because the natural gas supply system does
not consist of vertically integrated suppliers, the gas utility
modeling necessarily takes a different approach from the electric
utility modeling. Nonetheless, the fundamental goal, to estimate the
effect of proposed standards on utilities and their customers, is the
same. The analysis on the gas side is greatly simplified by the fact
that no energy conversion is involved, so that the amount of natural
gas saved at the burner tip is not very different from the amount that
can remain in the ground. The environmental impacts are similarly
simple, relative to electricity supply, because most of the
environmental consequences of residential natural gas use occur at the
burner tip. The focus of the gas analysis, therefore, sits squarely on
the cost impact of proposed standards.
The gas utility cost modeling is in two parts. In the first, the
effect of the standard on the general market for natural gas is
estimated. For the purposes of this analysis, the result of interest is
the city gate price of natural gas. That is, the price that local gas
distribution companies pay for the gas they later distribute to
customers. In general, the sales reductions predicted from residential
appliance efficiency standards are not expected to be great enough, or
near enough in the future to have a major impact on the North American
gas market as a whole. However, to quantify any possible effect, the
Department will use a national equilibrium gas supply and transmission
model. This model will be run under a base case that reflects current
EIA forecasts of gas supply and demand, and policy cases that reflect
Department forecasts of the effect of the proposed standard.
The second part of the analysis concerns the gas market downstream
of the city gate. The U.S. has numerous and diverse local natural gas
distribution companies, and no individual modeling of companies is
feasible. The Department will, therefore, rely on a general econometric
model of industry cost structure. Company operating costs are
represented in an historic data base covering about 50 major U.S.
distribution companies. A translog econometric cost function will be
fitted to these data and then applied as a forecasting tool. The inputs
to this model are twofold: (1) the same base case and policy case
demand forecasts, reduced to local company levels; and (2) the base and
policy case city gate price forecasts derived from the market-wide
analysis. The results of the econometric modeling will show the effects
of the proposed standard on a typical local distribution company and
its customers.
e. Sensitivity Analyses
Sensitivity studies are performed to determine how changes in
technical and operational parameters affect key engineering and
economic indicators used in evaluation of appliance standards. This
makes it possible to place limits on the overall results of the
analysis and to gain an understanding of which variables are most
important in producing these results. Sensitivity analyses are
developed in a series of distinct steps. For each component analysis in
the overall analysis, critical input parameters are identified and
reasonable ranges of variation determined. The sensitivity of the model
to changes in the value of each important parameter is then estimated
by running the model for both the base case and the standards cases.
The results of the sensitivity analyses are examined to determine the
sensitivity of the forecasts to exogenous variables and assumptions and
the sensitivity of the differences between the base and standards cases
(impacts of alternative standards).
The sensitivity analyses have been developed at the national level
and no effort has been made to link them with any specific population
groups. The standards analysis assumes that nationwide average
appliance usage rates, energy prices, and efficiency apply to all
consumers in all areas of the nation, although the Department
recognizes that there exist large variations in each of these factors.
The Department requested in the Three Product Advance Notice
information concerning the extent to which any proposed national
efficiency standard is likely to affect identifiable groups of
consumers disproportionally and how best to consider such impacts in
the selection of efficiency standard levels. The Department also
requested additional data to help it better assess the disproportionate
impacts on such groups. The Department expects to use the same approach
that emerges in the Three Product Advance Notice rulemaking in this
rulemaking. The Department welcomes comments on this issue.
IV. Public Comment Procedures
a. Participation in Rulemaking
The Department encourages the maximum level of public participation
possible in this rulemaking. Individual consumers, representatives of
consumer groups, manufacturers, associations, States or other
governmental entities, utilities, retailers, distributors,
manufacturers, and others are urged to submit written statements on the
proposal.
The Department has established a period of 75 days following
publication of this notice for persons to comment on this proposal. All
public comments received will be available for review in the
Department's Freedom of Information Reading Room.
b. Written Comment Procedures
Interested persons are invited to participate in this proceeding by
submitting written data, views, or arguments with respect to the
subjects set forth in this notice. Instructions for submitting written
comments are set forth at the beginning of this notice and below.
Comments should be labeled both on the envelope and on the
documents, ``Three Cleaning Products Rulemaking (Docket No. EE-RM-94-
403),'' and must be received by the date specified at the beginning of
this notice. Ten copies are requested to be submitted. Additionally,
the Department would appreciate an electronic copy of the comments to
the extent possible. The Department is currently using
WordPerfectTM 5.1. All comments and other relevant information
received by the date specified at the beginning of this notice will be
considered by the Department in the proposed rule.
All written comments received on the Advance Notice of Proposed
Rulemaking will be available for public inspection at the Freedom of
Information Reading Room, as provided at the beginning of this notice.
Pursuant to the provisions of 10 CFR 1004.11, any person submitting
information or data that is believed to be confidential and exempt by
law from public disclosure should submit one complete copy of the
document and ten (10) copies, if possible, from which the information
believed to be confidential has been deleted. The Department will make
its own determination with regard to the confidential status of the
information or data and treat it according to its determination.
Factors of interest to the Department, when evaluating requests to
treat information as confidential, include: (1) A description of the
item; (2) an indication as to whether and why such items of information
have been treated by the submitting party as confidential, and whether
and why such items are customarily treated as confidential, and whether
and why such items are customarily treated as confidential within the
industry; (3) whether the information is generally known or available
from other sources; (4) whether the information has previously been
available to others without obligation concerning its confidentiality;
(5) an explanation of the competitive injury to the submitting person
that would result from public disclosure; (6) an indication as to when
such information might lose its confidential character due to the
passage of time; and (7) whether disclosure of the information would be
in the public interest.
c. Issues for Public Comment
The Department is interested in receiving comments and data
concerning the accuracy and workability of this methodology. Also, the
Department welcomes discussion on improvements or alternatives to this
approach. In particular, the Department is interested in gathering data
on the following:
Descriptive and performance characteristics for baseline
models of each product class that are the subject of this rulemaking;
these baseline models should be those satisfying the appropriate
standards;
Proposed product classes for products in this rulemaking;
Costs of baseline models and incremental costs of designs
improving the energy efficiency of the products that are the subject of
this rulemaking;
Appropriateness of existing and proposed test procedures
to the proposed design options; specifically, the Department would like
comments on whether a clothes washer that consumes more energy for a
higher percentage of water extraction (thus, lower clothes dryer energy
consumption) should be given a credit and if so, how much; and
Data on lifetimes of the appliances.
The Department requested information on the issues listed below in
the Three Product Advance Notice issued in September 1993. However, the
Department encourages commenters to provide any additional information
on these issues which may not have been presented in response to the
Department's Three Product Advance Notice. These issues are as follows:
The relevance of the data inputs and outputs of the LBL-
REM and LBL-MIM models, whether these models could or should capture
the cumulative effects of Federal energy conservation standards on
multi-product appliance manufacturers and whether or not there are
acceptable alternative models that could be used, such as REEPS or
GRIM;
Analytic bases and methods of calculating the dollar value
of reduced atmospheric emissions of SO2, NO2, and CO2
from reduced energy consumption;
Data on consumer financing of appliances useful for
obtaining a weighted-average discount rate; and
Data on the possible adverse affects of standards on
identifiable groups of consumers that experience below-average utility
or usage rates.
The Department has been unable to identify the financial
characteristics of small manufacturers. For purposes of this analysis,
small manufacturers' costs are assumed to equal those of medium
manufacturers. The Department is especially interested in learning of
the existence of small manufacturers and in obtaining costing data from
such manufacturers of the products under consideration.
For the Residential Energy Model analysis, the Department requests
interested parties to provide historical data on shipments and average
efficiencies by class for the products subject to the proposed
rulemaking. Data on consumer prices and on the installation and
maintenance expenses of these appliances are also requested.
The manufacturer analysis needs financial data from the product
division level. All of these data are available at the firm level; but
since firms are typically much larger than the relevant division, the
firm data may give a misleading indication of the division's finances.
An income statement and balance sheet at the division level would
be most helpful. If this is not available, then data on the following
variables are considered most essential: Net income, revenue, selling
and general and administrative costs, engineering costs, costs of goods
sold, interest, taxes, debt-to-equity ratio, net depreciable assets,
net assets, capital investment, and long-term debt.
The Department also welcomes current data on unit sales and
revenues for the industries as a whole.
V. Review Under Executive Order 12866
Today's regulatory action has been determined to be an
``economically significant regulatory action'' under Executive Order
12866, ``Regulatory Planning and Review,'' (58 FR 51735, October 4,
1993). Accordingly, today's action was subject to review under the
Executive Order by the Office of Information and Regulatory Affairs
(OIRA).
There were no substantive changes between the draft submitted to
OIRA and today's action.
The draft of today's action and any other documents submitted to
OIRA for review have been made a part of the rulemaking record and are
available for public review in the Department's Freedom of Information
Reading Room, 1000 Independence Avenue SW. Washington, DC 20585 between
the hours of 9:00 and 4:00, Monday through Friday, telephone (202) 586-
6020.
Issued in Washington, DC, on November 2, 1994.
Christine A. Ervin,
Assistant Secretary, Energy Efficiency and Renewable Energy.
[FR Doc. 94-28044 Filed 11-10-94; 8:45 am]
BILLING CODE 6450-01-P
This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.