[Federal Register Volume 81, Number 171 (Friday, September 2, 2016)]
[Proposed Rules]
[Pages 60784-60876]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-20721]
[[Page 60783]]
Vol. 81
Friday,
No. 171
September 2, 2016
Part II
Department of Energy
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10 CFR Parts 429 and 430
Energy Conservation Program: Energy Conservation Standards for
Residential Conventional Cooking Products; Proposed Rule
Federal Register / Vol. 81 , No. 171 / Friday, September 2, 2016 /
Proposed Rules
[[Page 60784]]
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DEPARTMENT OF ENERGY
10 CFR Parts 429 and 430
[Docket Number EERE-2014-BT-STD-0005]
RIN 1904-AD15
Energy Conservation Program: Energy Conservation Standards for
Residential Conventional Cooking Products
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Supplemental notice of proposed rulemaking (SNOPR).
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SUMMARY: The Energy Policy and Conservation Act of 1975 (EPCA), as
amended, prescribes energy conservation standards for various consumer
products and certain commercial and industrial equipment, including
residential conventional cooking products. EPCA also requires the U.S.
Department of Energy (DOE) to determine whether more-stringent, amended
standards would be technologically feasible and economically justified,
and would save a significant amount of energy. In this SNOPR, DOE
proposes new and amended energy conservation standards for residential
conventional cooking products, specifically conventional cooking tops
and conventional ovens.
DATES: Comments: DOE will accept comments, data, and information
regarding this supplemental notice of proposed rulemaking (SNOPR) no
later than October 3, 2016. See section VII, ``Public Participation''
for details.
Comments regarding the likely competitive impact of the proposed
standard should be sent to the Department of Justice contact listed in
the ADDRESSES section before October 3, 2016.
ADDRESSES:
Instructions: Any comments submitted must identify the SNOPR for
Energy Conservation Standards for residential conventional cooking
products, and provide docket number EERE-2014-BT-STD-0005 and/or
regulatory information number (RIN) number 1904-AD15. Comments may be
submitted using any of the following methods:
1. Federal eRulemaking Portal: www.regulations.gov. Follow the
instructions for submitting comments.
2. Email: [email protected].
Include the docket number and/or RIN in the subject line of the
message.
3. Mail: Mr. John Cymbalsky, U.S. Department of Energy, Building
Technologies Program, Mailstop EE-5B, 1000 Independence Avenue SW.,
Washington, DC 20585-0121. If possible, please submit all items on a
CD. It is not necessary to include printed copies.
4. Hand Delivery/Courier: Mr. John Cymbalsky, U.S. Department of
Energy, Building Technologies Program, 950 L'Enfant Plaza SW., Room
6094, Washington, DC 20024. Telephone: (202) 586-6636. If possible,
please submit all items on a CD, in which case it is not necessary to
include printed copies.
No telefacsimilies (faxes) will be accepted. For detailed
instructions on submitting comments and additional information on the
rulemaking process, see section VII of this document (``Public
Participation'').
Written comments regarding the burden-hour estimates or other
aspects of the collection-of-information requirements contained in this
proposed rule may be submitted to Office of Energy Efficiency and
Renewable Energy through the methods listed above and by email to
[email protected].
EPCA requires the Attorney General to provide DOE a written
determination of whether the proposed standard is likely to lessen
competition. The U.S. Department of Justice Antitrust Division invites
input from market participants and other interested persons with views
on the likely competitive impact of the proposed standard. Interested
persons may contact the Division at [email protected] before
October 3, 2016. Please indicate in the ``Subject'' line of your email
the title and Docket Number of this SNOPR.
Docket: The docket, which includes Federal Register notices, public
meeting attendee lists and transcripts, comments, and other supporting
documents/materials, is available for review at www.regulations.gov.
All documents in the docket are listed in the www.regulations.gov
index. However, some documents listed in the index may not be publicly
available, such as those containing information that is exempt from
public disclosure.
A link to the docket Web page can be found at: http://www.regulations.gov/#!docketDetail;D=EERE-2014-BT-STD-0005. This Web
page will contain a link to the docket for this document on the
www.regulations.gov site. The regulations.gov Web page will contain
simple instructions on how to access all documents, including public
comments, in the docket. See section VII, ``Public Participation,'' for
further information on how to submit comments through
www.regulations.gov.
FOR FURTHER INFORMATION CONTACT:
Mr. John Cymbalsky, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Program, EE-2J,
1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone:
(202) 287-1692. Email: [email protected].
Ms. Celia Sher, U.S. Department of Energy, Office of the General
Counsel, GC-33, 1000 Independence Avenue SW., Washington, DC 20585-
0121. Telephone: (202) 287-6122. Email: [email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Synopsis of the Proposed Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits and Costs
D. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for Residential Conventional
Cooking Products
III. General Discussion
A. Scope of Coverage
B. Prescriptive Standard for Conventional Ovens
C. Test Procedure
D. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
E. Energy Savings
1. Determination of Savings
2. Significance of Savings
F. Economic Justification
1. Specific Criteria
2. Rebuttable Presumption
G. Changes to 10 CFR 429.23 Addressing the Certification,
Compliance and Enforcement Criteria for Conventional Cooking
Products
H. Other Issues
IV. Methodology and Discussion of Comments
A. Market and Technology Assessment
1. General
2. Product Classes
3. Technology Options
B. Screening Analysis
1. Screened-Out Technologies
2. Remaining Technologies
C. Engineering Analysis
1. Methodology
2. Product Testing and Reverse Engineering
3. Efficiency Levels
4. Incremental Manufacturing Production Cost Estimates
5. Consumer Utility
D. Markups Analysis
E. Energy Use Analysis
F. Life-Cycle Cost and Payback Period Analysis
1. Product Costs
2. Installation Costs
3. Unit Energy Consumption
[[Page 60785]]
4. Energy Prices
5. Repair and Maintenance Costs
6. Product Lifetime
7. Discount Rates
8. Compliance Date
9. No-New-Standards Case Efficiency Distribution
10. Inputs to Payback Period Analysis
11. Rebuttable-Presumption Payback Period
G. Shipments Analysis
H. National Impact Analysis
1. Efficiency Trends
2. National Energy Savings
3. Net Present Value of Customer Benefit
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
2. GRIM Analysis and Key Inputs
3. Discussion of Comments
4. Manufacturer Interviews
K. Emissions Analysis
L. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
2. Social Cost of Other Air Pollutants
M. Utility Impact Analysis
N. Employment Impact Analysis
V. Analytical Results
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
2. Economic Impacts on Manufacturers
3. National Impact Analysis
4. Impact on Utility or Performance of Products
5. Impact of Any Lessening of Competition
6. Need of the Nation To Conserve Energy
7. Other Factors
8. Summary of National Economic Impacts
C. Conclusion
1. Benefits and Burdens of TSLs Considered for Conventional
Cooking Products
2. Summary of Annualized Benefits and Costs of the Proposed
Standards
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Description and Estimated Number of Small Entities Regulated
2. Description and Estimate of Compliance Requirements
3. Duplication, Overlap, and Conflict With Other Rules and
Regulations
4. Significant Alternatives to the Rule
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality Bulletin for Peer Review
VII. Public Participation
A. Submission of Comments
B. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Synopsis of the Proposed Rule
Title III, Part B \1\ of the Energy Policy and Conservation Act of
1975 (EPCA or the Act), Public Law 94-163 (42 U.S.C. 6291-6309, as
codified), established the Energy Conservation Program for Consumer
Products Other Than Automobiles.\2\ These products include residential
conventional cooking products, and specifically conventional cooking
tops \3\ and conventional ovens,\4\ the subject of this document.
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\1\ For editorial reasons, upon codification in the U.S. Code,
Part B was redesignated Part A.
\2\ All references to EPCA in this document refer to the statute
as amended through the Energy Efficiency Improvement Act of 2015,
Public Law 114-11 (Apr. 30, 2015).
\3\ Conventional cooking top means a class of kitchen ranges and
ovens which is a household cooking appliance consisting of a
horizontal surface containing one or more surface units which
include either a gas flame or electric resistance heating. (10 CFR
430.2) This includes any conventional cooking top component of a
combined cooking product.
\4\ Conventional oven means a class of kitchen ranges and ovens
which is a household cooking appliance consisting of one or more
compartments intended for the cooking or heating of food by means of
either a gas flame or electric resistance heating. It does not
include portable or countertop ovens which use electric resistance
heating for the cooking or heating of food and are designed for an
electrical supply of approximately 120 volts. (10 CFR 430.2) This
includes any conventional oven(s) component of a combined cooking
product.
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Pursuant to EPCA, any new or amended energy conservation standard
must be designed to achieve the maximum improvement in energy
efficiency that is technologically feasible and economically justified.
(42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or amended standard must
result in a significant conservation of energy. (42 U.S.C.
6295(o)(3)(B)) EPCA also provides that not later than 6 years after
issuance of any final rule establishing or amending a standard, DOE
must publish either a notice of determination that standards for the
product do not need to be amended, or a notice of proposed rulemaking
including new proposed energy conservation standards. (42 U.S.C.
6295(m)(1))
In accordance with these and other statutory provisions discussed
in this document, DOE proposes new and amended energy conservation
standards for residential conventional cooking products. Per its
authority in 42 U.S.C. 6295(h)(2), DOE proposes to remove the existing
prescriptive standard for gas cooking tops prohibiting a constant
burning pilot light. Instead, for conventional cooking tops, DOE
proposes performance standards only, shown in Table I.1, which are the
maximum allowable integrated annual energy consumption (IAEC). The IAEC
includes active mode, standby mode, and off mode energy use. These
proposed standards for conventional cooking tops, if adopted, would
apply to all product classes listed in Table I.1 and manufactured in,
or imported into, the United States starting on the date 3 years after
the publication of any final rule for this rulemaking. The proposed
standards correspond to trial standard level (TSL) 2, which is
described in section V.A. DOE notes that constant burning pilot lights,
which are currently prohibited under the existing prescriptive standard
for gas cooking tops (10 CFR 430.32(j)), consume approximately 2,000
kilo British thermal units (kBtu) per year. While DOE's proposal would
remove this prescriptive requirement from its regulations, DOE notes
that, based on its review of the existing prescriptive standard
prohibiting constant burning pilots for gas cooking tops and the
proposed efficiency levels presented in section IV.C.3.b, the proposed
performance standards of 924.4 kBtu per year for gas cooking tops would
not be achievable by products if they were to incorporate a constant
burning pilot.
Table I.1--Proposed Energy Conservation Performance Standards for Conventional Cooking Tops
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Product class Maximum integrated annual energy consumption (IAEC)
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Electric Open (Coil) Element Cooking Tops.................. 113.2 kWh/yr.
Electric Smooth Element Cooking Tops....................... 121.2 kWh/yr.
Gas Cooking Tops........................................... 924.4 kBtu/yr.
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[[Page 60786]]
For conventional ovens, the proposed standard is a prescriptive
design requirement for the control system of the oven. Conventional
electric ovens shall not be equipped with a control system that uses a
linear power supply. Conventional gas ovens shall be equipped with a
control system that uses an intermittent/interrupted ignition or
intermittent pilot ignition and does not use a linear power supply (See
Table I.2). These proposed standards for conventional ovens, if
adopted, would apply to all conventional ovens manufactured in, or
imported into, the United States starting on the date 3 years after the
publication of any final rule for this rulemaking. DOE considered a
combination of factors in developing its proposal to prescribe a
control system design requirement for conventional ovens, rather than
proposing to regulate IAEC with a performance standard. The rationale
for this tentative decision is further explained in sections IV.C.5 and
V.B.8 of this SNOPR. DOE also notes that the current prescriptive
standards for conventional gas ovens prohibiting constant burning pilot
lights would continue to be applicable. (10 CFR 430.32(j)). Table I.2
provides a summary of the proposed standards for conventional ovens.
Table I.2--Proposed Prescriptive Energy Conservation Standards for
Conventional Ovens
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Current SNOPR
Oven product class Current standard proposed standards
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Electric Standard, None................ Shall not be
Freestanding. equipped with a
Electric Standard, Built-In/ control system that
Slide-In. uses linear power
supply.*
Electric Self-Clean,
Freestanding.
Electric Self-Clean, Built-
In/Slide-In.
Gas Standard, Freestanding.. No constant burning The control system
Gas Standard, Built-In/Slide- pilot light. for gas ovens
In. shall:
Gas Self-Clean, Freestanding (1) Not be equipped
Gas Self-Clean, Built-In/ with a constant
Slide-In. burning pilot
light;
(2) Be equipped with
an intermittent/
interrupted
ignition or
intermittent pilot
ignition; and
(3) Not be equipped
with a linear power
supply.
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* A linear power supply produces unregulated as well as regulated power.
The unregulated portion of a linear power supply typically consists of
a transformer that steps alternating current (AC) line voltage down, a
voltage rectifier circuit for AC to direct current (DC) conversion,
and a capacitor to produce unregulated, direct current output. Linear
power supplies are described in section IV.A.3 of this SNOPR.
A. Benefits and Costs to Consumers
Table I.3 presents DOE's evaluation of the economic impacts of the
proposed standards on consumers of residential conventional cooking
products, as measured by the average life-cycle cost (LCC) savings and
the simple payback period (PBP).\5\ The average LCC savings are
positive for all product classes, and the PBP is less than the average
lifetime of the equipment, which is estimated to be 16 years for
electric cooking tops and 13 years for gas cooking products (see
section IV.F.6 for additional detail).
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\5\ The average LCC savings are measured relative to the no-new-
standards-case efficiency distribution, which depicts the market in
the compliance year (see section IV.F.9 of this notice) and is the
savings achieved over the average lifetime of the product. The
simple PBP, which is designed to compare specific efficiency levels,
is measured relative to the baseline model.
Table I.3--Impacts of Proposed Energy Conservation Standards (TSL2) on Consumers of Residential Conventional
Cooking Products
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Average LCC Average
Product class savings Simple payback lifetime
(2015$) period (years) (years)
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Electric Open (Coil) Element Cooking Tops....................... 3 0.5 16
Electric Smooth Element Cooking Tops............................ 24 1.0 16
Gas Cooking Tops................................................ 1 9.1 13
Electric Standard Oven, Free-standing........................... 6 0.9 16
Electric Standard Oven, Built-in/Slide-in....................... 6 0.9 16
Electric Self-Clean Oven, Free-Standing......................... 7 0.9 16
Electric Self-Clean Oven, Built-in/Slide-in..................... 7 0.9 16
Gas Standard Oven, Free-Standing................................ 44 1.1 13
Gas Standard Oven, Built-in/Slide-in............................ 44 1.1 13
Gas Self-Clean Oven, Free-Standing.............................. 48 1.1 13
Gas Self-Clean Oven, Built-In/Slide-in.......................... 48 1.1 13
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DOE's analysis of the impacts of the proposed standards on
consumers is described in section IV.F of this SNOPR.
B. Impact on Manufacturers
The industry net present value (INPV) is the sum of the discounted
cash flows to the industry from the reference year through the end of
the analysis period (2016 to 2048). Using a real discount rate of 9.1
percent, DOE estimates that the INPV for manufacturers of residential
conventional cooking products is $1,238.1 million in 2015$. Under the
proposed standards, DOE expects that manufacturers may lose up to 7.2
percent of their INPV, which is approximately $89.6 million in 2015$.
Additionally, based on DOE's interviews with the manufacturers of
residential conventional cooking
[[Page 60787]]
products, DOE does not expect any plant closings or significant loss of
employment.
Table I.4 and Table I.5 show the financial impacts (represented by
changes in INPV) of new and amended energy conservation standards on
residential conventional cooking product manufacturers as well as the
conversion costs that DOE estimates manufacturers would incur under the
preservation of gross margin and preservation of operating profit
markup scenarios (described in section IV.J.2). As noted above, the
proposed standards correspond to TSL 2.
Table I.4--Manufacturer Impact Analysis for Residential Conventional Cooking Products--Preservation of Gross Margin Markup Scenario
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Trial standard level
Units No-new- ---------------------------------------------------------------
standards case 1 2 3 4
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INPV...................................... (2015$ millions)............ 1,238.1 1,200.1 1,156.7 868.0 511.1
Change in INPV............................ (2015$ millions)............ .............. (38.0) (81.4) (370.1) (727.1)
(%)......................... .............. (3.1) (6.6) (29.9) (58.7)
Product Conversion Costs.................. (2015$ millions)............ .............. 19.9 71.3 261.8 525.4
Capital Conversion Costs.................. (2015$ millions)............ .............. 29.9 47.9 248.2 580.2
Total Conversion Costs.................... (2015$ millions)............ .............. 49.8 119.2 510.0 1,105.7
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* Numbers in parentheses indicate negative numbers.
Table I.5--Manufacturer Impact Analysis for Residential Conventional Cooking Products--Preservation of Operating Profit Markup Scenario
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Trial standard level
Units No-new- ---------------------------------------------------------------
standards case 1 2 3 4
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INPV...................................... (2015$ millions)............ 1,238.1 1,198.3 1,148.5 844.7 314.6
Change in INPV............................ (2015$ millions)............ .............. (39.8) (89.6) (393.5) (923.6)
(%)......................... (3.2) (7.2) (31.8) (74.6)
Product Conversion Costs.................. (2015$ millions)............ .............. 19.9 71.3 261.8 525.4
Capital Conversion Costs.................. (2015$ millions)............ .............. 29.9 47.9 248.2 580.2
Total Conversion Costs.................... (2015$ millions)............ .............. 49.8 119.2 510.0 1,105.7
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DOE's analysis of the impacts of the proposed standards on
manufacturers is described in section IV.J of this SNOPR.
C. National Benefits and Costs \6\
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\6\ All monetary values in this document are expressed in 2015
dollars, and where appropriate, are discounted to 2016 unless
explicitly stated otherwise. Energy savings in this section refer to
the full-fuel-cycle savings (see section IV.H of this SNOPR for
discussion).
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DOE's analyses indicate that the proposed standards would save a
significant amount of energy. The lifetime energy savings from
residential conventional cooking products purchased in the 30-year
period that begins in the assumed year of compliance with the proposed
standards (2019-2048), relative to the no-new-standards case without
the proposed standards, amount to 0.76 quadrillion British thermal
units (quads).\7\ This represents a savings of 5.9 percent relative to
the energy use of these products in the no-new-standards case.
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\7\ A quad is equal to 10\15\ British thermal units (Btu). The
quantity refers to full-fuel-cycle (FFC) energy savings. FFC energy
savings includes the energy consumed in extracting, processing, and
transporting primary fuels (i.e., coal, natural gas, petroleum
fuels), and thus presents a more complete picture of the impacts of
energy efficiency standards. For more information on the FFC metric,
see section IV.H.2 of this SNOPR.
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The cumulative net present value (NPV) of total consumer costs and
savings of the proposed standards for residential conventional cooking
products ranges from $2.72 billion (at a 7-percent discount rate) to
$6.24 billion (at a 3-percent discount rate). This NPV expresses the
estimated present value of future operating-cost savings minus the
estimated increased product costs for products purchased in 2019-2048.
In addition, the proposed standards are projected to yield
significant environmental benefits. The energy savings described above
are estimated to result in cumulative emission reductions of 45.3
million metric tons (Mt) \8\ of carbon dioxide (CO2), 6,369
thousand tons of methane, 23.6 thousand tons of sulfur dioxide
(SO2), 88.0 thousand tons of nitrogen oxides
(NOX), 0.50 thousand tons of nitrous oxide (N2O),
and 0.09 tons of mercury (Hg).\9\ The cumulative reduction in
CO2 emissions through 2030 amounts to 9.057 Mt, which is
equivalent to the emissions resulting from the annual electricity use
of 0.826 million homes.
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\8\ A metric ton is equivalent to 1.1 short tons. Results for
emissions other than CO2 are presented in short tons.
\9\ DOE calculated emissions reductions relative to the no-new-
standards case, which reflects key assumptions in the Annual Energy
Outlook 2015 (AEO 2015) Reference case. AEO 2015 generally
represents current legislation and environmental regulations for
which implementing regulations were available as of October 31,
2014.
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The value of the CO2 reductions is calculated using a
range of values per metric ton of CO2 (otherwise known as
the ``Social Cost of Carbon'', or SCC) developed by a Federal
interagency working group.\10\ The derivation of the SCC values is
discussed in section IV.L of this SNOPR. Using discount rates
appropriate for each set of SCC values (see Table I.7), DOE estimates
the present monetary value of the CO2 emissions reduction
(not including CO2 equivalent emissions of other gases with
global warming potential) is between $0.3 billion and $4.5 billion,
with a value of $1.5 billion using the central SCC case represented by
$40.6/t in 2015. DOE also estimates the present monetary value of the
NOX emissions reduction to be $0.08 billion at a 7-percent
discount rate and $0.19 billion
[[Page 60788]]
at 3-percent discount rate.\11\ DOE is investigating appropriate
valuation of the reduction in methane and other emissions, and did not
include any values in this rulemaking.
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\10\ Technical Update of the Social Cost of Carbon for
Regulatory Impact Analysis Under Executive Order 12866, Interagency
Working Group on Social Cost of Carbon, United States Government
(May 2013; revised July 2015) (Available at: https://www.whitehouse.gov/sites/default/files/omb/inforeg/scc-tsd-final-july-2015.pdf).
\11\ DOE estimated the monetized value of NOX
emissions reductions associated with electricity savings using
benefit per ton estimates from the Regulatory Impact Analysis for
the Clean Power Plan Final Rule, published in August 2015 by EPA's
Office of Air Quality Planning and Standards. (Available at: http://www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis.) See section IV.L.2 of this SNOPR for further
discussion. The U.S. Supreme Court has stayed the rule implementing
the Clean Power Plan until the current litigation against it
concludes. Chamber of Commerce, et al. v. EPA, et al., Order in
Pending Case, 577 U.S._(2016). However, the benefit-per-ton
estimates established in the Regulatory Impact Analysis for the
Clean Power Plan are based on scientific studies that remain valid
irrespective of the legal status of the Clean Power Plan. DOE is
primarily using a national benefit-per-ton estimate for
NOX emitted from the Electricity Generating Unit sector
based on an estimate of premature mortality derived from the ACS
study (Krewski et al., 2009). If the benefit-per-ton estimates were
based on the Six Cities study (Lepuele et al., 2011), the values
would be nearly two-and-a-half times larger.
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Table I.6 summarizes the national economic costs and benefits
expected to result from the proposed standards for residential
conventional cooking products.
Table I.6--Summary of National Economic Benefits and Costs of Proposed
Energy Conservation Standards (TSL2) for Residential Conventional
Cooking Products *
------------------------------------------------------------------------
Present value
Category (billion 2015$) Discount rate (%)
------------------------------------------------------------------------
Benefits
------------------------------------------------------------------------
Consumer Operating Cost 3.2 7
Savings.................... 7.0 3
CO2 Reduction Monetized 0.3 5
Value ($12.4/t case) **....
CO2 Reduction Monetized 1.5 3
Value ($40.6/t case) **....
CO2 Reduction Monetized 2.4 2.5
Value ($63.2/t case) **....
CO2 Reduction Monetized 4.5 3
Value ($118/t case) **.....
NOX Reduction Monetized 0.08 0.19
Value [dagger]............. 7 3
Total Benefits 4.8 7
[dagger][dagger]........... 8.7 3
------------------------------------------------------------------------
Costs
------------------------------------------------------------------------
Consumer Incremental 0.5 7
Installed Costs............ 0.8 3
------------------------------------------------------------------------
Total Net Benefits
------------------------------------------------------------------------
Including CO2 and NOX 4.3 7
Reduction Monetized Value 7.9 3
[dagger][dagger]...........
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* This table presents the costs and benefits associated with residential
conventional cooking products shipped in 2019-2048. These results
include impacts to consumers which accrue after 2048 from the products
purchased in 2019-2048. The results account for the incremental
variable and fixed costs incurred by manufacturers due to any final
standard, some of which may be incurred in preparation for the rule.
** The CO2 values represent global monetized values of the SCC, in
2015$, in 2015 under several scenarios of the updated SCC values. The
first three cases use the averages of SCC distributions calculated
using 5%, 3%, and 2.5% discount rates, respectively. The fourth case
represents the 95th percentile of the SCC distribution calculated
using a 3% discount rate. The SCC time series incorporate an
escalation factor.
[dagger] DOE estimated the monetized value of NOX emissions reductions
associated with electricity savings using benefit per ton estimates
from the Regulatory Impact Analysis for the Clean Power Plan Final
Rule, published in August 2015 by EPA's Office of Air Quality Planning
and Standards. (Available at:http://www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis.) See supra note 11
and accompanying text.
[dagger][dagger] Total Benefits for both the 3% and 7% cases are derived
using the series corresponding to average SCC with 3-percent discount
rate ($40.6/t case).
The benefits and costs of the proposed standards, for products sold
in 2019-2048, can also be expressed in terms of annualized values. The
annualized monetary values are the sum of: (1) The national economic
value of the benefits in reduced consumer operating costs, minus (2)
the increase in product purchase prices and installation costs, plus
(3) the value of the benefits of CO2 and NOX
emission reductions, all annualized.\12\
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\12\ To convert the time-series of costs and benefits into
annualized values, DOE calculated a present value in 2015, the year
used for discounting the NPV of total consumer costs and savings.
For the benefits, DOE calculated a present value associated with
each year's shipments in the year in which the shipments occur
(e.g., 2020 or 2030), and then discounted the present value from
each year to 2015. The calculation uses discount rates of 3 and 7
percent for all costs and benefits except for the value of
CO2 reductions, for which DOE used case-specific discount
rates, as shown in Table I.7. Using the present value, DOE then
calculated the fixed annual payment over a 30-year period, starting
in the compliance year, that yields the same present value.
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Although the values of operating cost savings and CO2
emission reductions are both important, two issues are relevant. First,
the national operating savings are domestic U.S. consumer monetary
savings that occur as a result of market transactions, whereas the
value of CO2 reductions is based on a global value. Second,
the assessments of operating cost savings and CO2 savings
are performed with different methods that use different time frames for
analysis. The national operating cost savings is measured for the
lifetime of residential conventional cooking products shipped in 2019-
2048. Because CO2 emissions have a very long residence time
in the atmosphere,\13\ the SCC values in future years reflect future
climate-related impacts resulting from the emission of CO2
that continue well beyond 2100.
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\13\ The atmospheric lifetime of CO2 is estimated of
the order of 30-95 years. Jacobson, MZ (2005). ``Correction to
``Control of fossil-fuel particulate black carbon and organic
matter, possibly the most effective method of slowing global
warming.'' '' J. Geophys. Res. 110. pp. D14105.
---------------------------------------------------------------------------
Estimates of annualized benefits and costs of the proposed
standards are
[[Page 60789]]
shown in Table I.7. The results under the primary estimate are as
follows.
Using a 7-percent discount rate for benefits and costs other than
CO2 reductions (for which DOE used a 3-percent discount rate
along with the average SCC series corresponding to a value of $40.6/ton
in 2015 (2015$)), the estimated cost of the proposed standards for
cooking products is $42.6 million per year in increased equipment
costs, while the benefits are $293 million per year in reduced
equipment operating costs, $80.8 million in CO2 reductions,
and $7.4 million in reduced NOX emissions. In this case, the
net benefit amounts to $339 million per year.
Using a 3-percent discount rate for all benefits and costs and the
average SCC series corresponding to a value of $40.6/ton in 2015
(2015$), the estimated cost of the proposed standards for cooking
products is $42.3 million per year in increased equipment costs, while
the benefits are $380 million per year in reduced operating costs,
$80.8 million in CO2 reductions, and $10.1 million in
reduced NOX emissions. In this case, the net benefit amounts
to $429 million per year.
Table I.7--Annualized Benefits and Costs of Proposed Amended Standards (TSL 2) for Conventional Cooking Products Sold in 2019-2048
--------------------------------------------------------------------------------------------------------------------------------------------------------
Million 2015$/year
-----------------------------------------------------------------------------------
Discount rate Low net benefits estimate High net benefits estimate
Primary estimate * * *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings... 7%.............................. 293....................... 262....................... 332.
3%.............................. 380....................... 336....................... 439.
CO2 Reduction Value ($12.4/t case) 5%.............................. 23.8...................... 21.7...................... 26.5.
**.
CO2 Reduction Value ($40.6/t case) 3%.............................. 80.8...................... 73.6...................... 90.5.
**.
CO2 Reduction Value ($63.2/t case) 2.5%............................ 118.6..................... 107.9..................... 132.8.
**.
CO2 Reduction Value ($118/t case) 3%.............................. 246.3..................... 224.1..................... 275.6.
**.
NOX Reduction Value [dagger]...... 7%.............................. 7.4....................... 6.8....................... 18.2.
3%.............................. 10.1...................... 9.2....................... 25.6.
---------------------------------------------------------------------------------------------------------------------
Total Benefits 7% plus CO2 range............... 325 to 547................ 290 to 493................ 377 to 626.
[dagger][dagger].
7%.............................. 382....................... 342....................... 441.
3% plus CO2 range............... 414 to 637................ 367 to 569................ 491 to 740.
3%.............................. 471....................... 418....................... 555.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Costs
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Incremental Installed 7%.............................. 42.6...................... 41.6...................... 45.3.
Product Costs. 3%.............................. 42.3...................... 41.3...................... 45.2.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Net Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total [dagger][dagger]........ 7% plus CO2 range............... 282 to 504................ 249 to 451................ 332 to 581.
7%.............................. 339....................... 301....................... 396.
3% plus CO2 range............... 372 to 594................ 325 to 528................ 446 to 695.
3%.............................. 429....................... 377....................... 510.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with cooking products shipped in 2019-2048. Note that the benefits and costs may not
exactly sum to the net benefits due to rounding. These results include benefits to consumers which accrue after 2048 from the products purchased in
2019-2048. The results account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of which may be
incurred in preparation for the rule. The Primary, Low Benefits, and High Benefits Estimates utilize projections of energy prices from the AEO 2015
Reference case, Low Economic Growth case, and High Economic Growth case, respectively. In addition, incremental product costs reflect a medium decline
rate in the Primary Estimate, a low decline rate in the Low Benefits Estimate, and a high decline rate in the High Benefits Estimate. The methods used
to derive projected price trends are explained in section IV.F.1 of this SNOPR.
** The CO2 values represent global monetized values of the SCC, in 2015$, in 2015 under several scenarios of the updated SCC values. The first three
cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case represents the 95th
percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series incorporate an escalation factor.
[dagger] DOE estimated the monetized value of NOX emissions reductions associated with electricity savings using benefit per ton estimates from the
Regulatory Impact Analysis for the Clean Power Plan Final Rule, published in August 2015 by EPA's Office of Air Quality Planning and Standards.
(Available at: http://www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis.) See section IV.L.2 of this SNOPR for further
discussion. For DOE's Primary Estimate and Low Net Benefits Estimate, the agency used a national benefit-per-ton estimate for NOX emitted from the
Electric Generating Unit sector based on an estimate of premature mortality derived from the ACS study (Krewski et al., 2009). For DOE's High Net
Benefits Estimate, the benefit-per-ton estimates were based on the Six Cities study (Lepuele et al., 2011), which are nearly two-and-a-half times
larger than those from the ACS study.
[dagger][dagger] Total Benefits for both the 3% and 7% cases are derived using the series corresponding to the average SCC with a 3-percent discount
rate ($40.6/t case). In the rows labeled ``7% plus CO2 range'' and ``3% plus CO2 range,'' the operating cost and NOX benefits are calculated using the
labeled discount rate, and those values are added to the full range of CO2 values.
DOE's analysis of the national impacts of the proposed standards is
described in sections IV.H, IV.K and IV.L of this SNOPR.
D. Conclusion
DOE has tentatively concluded that the proposed standards represent
the maximum improvement in energy efficiency that is technologically
feasible and economically justified, and would result in the
significant conservation of energy. DOE further notes that products
achieving these standard levels are already commercially available for
at least some,
[[Page 60790]]
if not most, product classes covered by this proposal. Based on the
analyses described above, DOE has tentatively concluded that the
benefits of the proposed standards to the Nation (energy savings,
positive NPV of consumer benefits, consumer LCC savings, and emission
reductions) would outweigh the burdens (loss of INPV for manufacturers
and LCC increases for some consumers).
DOE also considered more-stringent energy efficiency levels as
TSLs, and is considering them in this rulemaking. However, DOE has
tentatively concluded that the potential burdens of the more-stringent
energy efficiency levels would outweigh the projected benefits. Based
on consideration of the public comments DOE receives in response to
this SNOPR and related information collected and analyzed during the
course of this rulemaking effort, DOE may adopt energy efficiency
levels presented in this SNOPR that are either higher or lower than the
proposed standards, or some combination of level(s) that incorporate
the proposed standards in part.
II. Introduction
The following section briefly discusses the statutory authority
underlying this proposal, as well as some of the relevant historical
background related to the establishment of standards for residential
conventional cooking products.
A. Authority
Title III, Part B of the Energy Policy and Conservation Act of 1975
(EPCA or the Act), Public Law 94-163 (codified as 42 U.S.C. 6291-6309)
established the Energy Conservation Program for Consumer Products Other
Than Automobiles, a program covering most major household appliances
(collectively referred to as ``covered products''), which includes
residential cooking products,\14\ and specifically residential
conventional cooking tops and conventional ovens that are the subject
of this rulemaking. (42 U.S.C. 6292(a)(10)) EPCA prescribed energy
conservation standards for these products (42 U.S.C. 6295(h)(1)), and
directs DOE to conduct rulemakings to determine whether to amend these
standards. (42 U.S.C. 6295(h)(2)) Under 42 U.S.C. 6295(m), the agency
must periodically review its already established energy conservation
standards for a covered product. Under this requirement, the next
review that DOE would need to conduct must occur no later than 6 years
from the issuance of a final rule establishing or amending a standard
for a covered product.
---------------------------------------------------------------------------
\14\ DOE's regulations define kitchen ranges and ovens, or
``cooking products'', as consumer products that are used as the
major household cooking appliances. They are designed to cook or
heat different types of food by one or more of the following sources
of heat: Gas, electricity, or microwave energy. Each product may
consist of a horizontal cooking top containing one or more surface
units and/or one or more heating compartments. Based on this
definition, in this SNOPR, DOE interprets kitchen ranges and ovens
to refer more generally to all types of cooking products including,
for example, microwave ovens.
---------------------------------------------------------------------------
Pursuant to EPCA, DOE's energy conservation program for covered
products consists essentially of four parts: (1) Testing; (2) labeling;
(3) the establishment of Federal energy conservation standards; and (4)
certification and enforcement procedures. The Federal Trade Commission
(FTC) is primarily responsible for labeling, and DOE implements the
remainder of the program. Subject to certain criteria and conditions,
DOE is required to develop test procedures to measure the energy
efficiency, energy use, or estimated annual operating cost of each
covered product. (42 U.S.C. 6293) Manufacturers of covered products
must use the prescribed DOE test procedure as the basis for certifying
to DOE that their products comply with the applicable energy
conservation standards adopted under EPCA and when making
representations to the public regarding the energy use or efficiency of
those products. (42 U.S.C. 6293(c) and 6295(s)) Similarly, DOE must use
these test procedures to determine whether the products comply with
standards adopted pursuant to EPCA. Id. The DOE test procedures for
residential conventional cooking products, including conventional
cooking tops and ovens, currently appear at title 10 of the Code of
Federal Regulations (CFR) part 430, subpart B, appendix I (Appendix I).
DOE must follow specific statutory criteria for prescribing new or
amended standards for covered products. As indicated above, any new or
amended standard for a covered product must be designed to achieve the
maximum improvement in energy efficiency that is technologically
feasible and economically justified. (42 U.S.C. 6295(o)(2)(A))
Furthermore, DOE may not adopt any standard that would not result in
the significant conservation of energy. (42 U.S.C. 6295(o)(3))
Moreover, DOE may not prescribe a standard: (1) For certain products,
including residential conventional cooking products, if no test
procedure has been established for the product, or (2) if DOE
determines by rule that the standard is not technologically feasible or
economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) In deciding
whether a standard is economically justified, DOE must determine
whether the benefits of the standard exceed its burdens. (42 U.S.C.
6295(o)(2)(B)(i)) DOE must make this determination after receiving
comments on the proposed standard, and by considering, to the greatest
extent practicable, the following seven statutory factors:
1. The economic impact of the standard on manufacturers and
consumers of the products subject to the standard;
2. The savings in operating costs throughout the estimated average
life of the covered products 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 from the imposition of the
standard;
3. The total projected amount of energy, or as applicable, water,
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 and water conservation; and
7. Other factors the Secretary of Energy (Secretary) considers
relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
EPCA, as codified, also contains what is known as an ``anti-
backsliding'' provision, which prevents the Secretary from prescribing
any amended standard that either increases the maximum allowable energy
use or decreases the minimum required energy efficiency of a covered
product. (42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe
an amended or new standard if interested persons have established by a
preponderance of the evidence that the standard is likely to result in
the unavailability in the United States of any covered product type (or
class) of performance characteristics (including reliability),
features, sizes, capacities, and volumes that are substantially the
same as those generally available in the United States. (42 U.S.C.
6295(o)(4))
Further, EPCA, as codified, establishes a rebuttable presumption
that a standard is economically justified if the Secretary finds that
the additional cost to the consumer of purchasing a product complying
with an energy conservation standard level will be less than three
times the value of the energy
[[Page 60791]]
savings during the first year that the consumer will receive as a
result of the standard, as calculated under the applicable test
procedure. (42 U.S.C. 6295(o)(2)(B)(iii))
Additionally, EPCA specifies requirements when promulgating a
standard for a type or class of covered product that has two or more
subcategories. DOE must specify a different standard level than that
which applies generally to such type or class of products for any group
of covered products that have the same function or intended use if DOE
determines that products within such group (A) consume a different kind
of energy from that consumed by other covered products within such type
(or class); or (B) have a capacity or other performance-related feature
which other products within such type (or class) do not have and such
feature justifies a higher or lower standard. (42 U.S.C. 6295(q)(1)) In
determining whether a performance-related feature justifies a different
standard for a group of products, DOE must consider such factors as the
utility to the consumer of the feature and other factors DOE deems
appropriate. Id. Any rule prescribing such a standard must include an
explanation of the basis on which such higher or lower level was
established. (42 U.S.C. 6295(q)(2))
Federal energy conservation requirements generally supersede State
laws or regulations concerning energy conservation testing, labeling,
and standards. (42 U.S.C. 6297(a)-(c)) DOE may, however, grant waivers
of Federal preemption for particular State laws or regulations, in
accordance with the procedures and other provisions set forth under 42
U.S.C. 6297(d)).
Finally, pursuant to the amendments contained in the Energy
Independence and Security Act of 2007 (EISA 2007), Public Law 110-140,
any final rule for new or amended energy conservation standards
promulgated after July 1, 2010, is required to address standby mode and
off mode energy use. (42 U.S.C. 6295(gg)(3)) Specifically, when DOE
adopts a standard for a covered product after that date, it must, if
justified by the criteria for adoption of standards under EPCA (42
U.S.C. 6295(o)), incorporate standby mode and off mode energy use into
the standard, or, if that is not feasible, adopt a separate standard
for such energy use for that product. (42 U.S.C. 6295(gg)(3)(A)-(B))
DOE's current test procedures for residential conventional cooking tops
address standby mode and off mode energy use. In this rulemaking, DOE
intends to incorporate such energy use into any new or amended energy
conservation standards it adopts in the final rule. As discussed in
section III.C, DOE is proposing to repeal the test procedures for
conventional ovens. As a result, a performance standard that addresses
standby mode and off mode energy use is not feasible for conventional
ovens. However, as discussed in section III.B, DOE is proposing in this
SNOPR to adopt prescriptive design requirements for the control system
of conventional ovens that would address standby mode and off mode
energy use.
B. Background
1. Current Standards
In a final rule published on April 8, 2009 (April 2009 Final Rule),
DOE prescribed the current energy conservation standards for
residential cooking products to prohibit constant burning pilots for
all gas cooking products (i.e., gas cooking products both with or
without an electrical supply cord) manufactured on or after April 9,
2012. 74 FR 16040, 16041-16044. DOE's regulations, codified at 10 CFR
430.2, define conventional cooking tops and conventional ovens as
classes of cooking products. As noted in the April 2009 Final Rule, DOE
considered standards for conventional cooking tops and conventional
ovens separately, and noted that any cooking top or oven standard would
apply to the individual components of a conventional range. 74 FR
16040, 16053.
2. History of Standards Rulemaking for Residential Conventional Cooking
Products
The National Appliance Energy Conservation Act of 1987 (NAECA),
Public Law 100-12, amended EPCA to establish prescriptive standards for
gas cooking products, requiring gas ranges and ovens with an electrical
supply cord that are manufactured on or after January 1, 1990, not to
be equipped with a constant burning pilot light. NAECA also directed
DOE to conduct two cycles of rulemakings to determine if more stringent
or additional standards were justified for kitchen ranges and ovens.
(42 U.S.C. 6295 (h)(1)-(2))
DOE undertook the first cycle of these rulemakings and published a
final rule on September 8, 1998, which found that no standards were
justified for conventional electric cooking products at that time. In
addition, partially due to the difficulty of conclusively demonstrating
that elimination of standing pilots for conventional gas cooking
products without an electrical supply cord was economically justified,
DOE did not include amended standards for conventional gas cooking
products in the final rule. 63 FR 48038. For the second cycle of
rulemakings, DOE published the April 2009 Final Rule amending the
energy conservation standards for conventional cooking products to
prohibit constant burning pilots for all gas cooking products (i.e.,
gas cooking products both with or without an electrical supply cord)
manufactured on or after April 9, 2012. DOE decided to not adopt energy
conservation standards pertaining to the cooking efficiency of
conventional electric cooking products because it determined that such
standards would not be technologically feasible and economically
justified at that time. 74 FR 16040, 16041-16044.\15\
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\15\ As part of the April 2009 Final Rule, DOE decided not to
adopt energy conservation standards pertaining to the cooking
efficiency of microwave ovens. DOE also published a final rule on
June 17, 2013 adopting energy conservation standards for microwave
oven standby mode and off mode. 78 FR 36316. DOE is not considering
energy conservation standards for microwave ovens as part of this
rulemaking.
---------------------------------------------------------------------------
EPCA also requires that, not later than 6 years after the issuance
of a final rule establishing or amending a standard, DOE publish a
notice of proposed rulemaking (NOPR) proposing new standards or a
notice of determination that the existing standards do not need to be
amended. (42 U.S.C. 6295(m)(1)) Based on this provision, DOE was
required to publish by March 31, 2015, either a NOPR proposing new
standards for conventional electric cooking products and/or amended
standards for conventional gas cooking products \16\ or a notice of
determination that the existing standards do not need to be amended.
Consequently, DOE initiated a rulemaking to determine whether to adopt
new or amended standards for conventional cooking products.
---------------------------------------------------------------------------
\16\ As discussed in section III.A of this SNOPR, DOE is also
tentatively planning to consider new energy conservation standards
for commercial-style gas cooking products with higher burner input
rates, for which DOE did not previously consider energy conservation
standards.
---------------------------------------------------------------------------
On February 12, 2014, DOE published a request for information (RFI)
notice (the February 2014 RFI) to initiate the mandatory review process
imposed by EPCA. As part of the RFI, DOE sought input from the public
to assist with its determination on whether new or amended standards
pertaining to conventional cooking products are warranted. 79 FR 8337.
In making this determination, DOE must evaluate whether new or amended
standards would (1) yield a significant savings in energy use and (2)
be both technologically feasible and economically justified. (42 U.S.C.
6295(o)(3)(B))
[[Page 60792]]
On June 10, 2015, DOE published a NOPR (the June 2015 NOPR)
proposing new and amended energy conservation standards for residential
conventional ovens. 80 FR 33030. The June 2015 NOPR also announced that
a public meeting would be held on July 14, 2015 at DOE headquarters in
Washington, DC. At this meeting, DOE presented the methodologies and
results of the analyses set forth in the NOPR, and interested parties
that participated in the public meeting discussed a variety of topics.
DOE received a number of comments from interested parties in response
to the June 2015 NOPR. DOE considered these comments, as well as
comments from the public meeting, in preparing this SNOPR. The
commenters are summarized in Table II.1. Relevant comments, and DOE's
responses, are provided in the appropriate sections of this SNOPR.
Table II.1--Interested Parties Providing Comments on the June 2015 NOPR
for Conventional Ovens
------------------------------------------------------------------------
Name Acronyms Commenter type *
------------------------------------------------------------------------
Air-conditioning, Heating, & AHRI.............. TA
Refrigeration Institute.
Appliance Standards Awareness Joint Efficiency EA
Project (ASAP), Alliance to Advocates.
Save Energy (ASE), American
Council for an Energy-
Efficient Economy (ACEEE),
Consumer Federation of America
(CFA), Consumers Union (CU),
National Consumer Law Center
(NCLC), Natural Resources
Defense Council (NRDC), and
Northwest Energy Efficiency
Alliance (NEEA).
Arizona Senator................ .................. CM
Arizona Congressional .................. CM
Delegation.
Arizona Congress Member........ .................. CM
Association of Home Appliance AHAM.............. TA
Manufacturers.
BSH Home Appliances............ BSH............... M
California Congress Member..... .................. CM
Cato Institute Center for the Cato.............. RO
Study of Science.
Edison Electric Institute...... EEI............... UA
Electrolux North America....... Electrolux........ M
Environmental Defense Fund, EDF, IPI, NRDC, EA
Institute for Policy Integrity UCS.
at New York University School
of Law, Natural Resources
Defense Council, and Union of
Concerned Scientists.
GE Appliances.................. GE................ M
Haier America.................. Haier............. M
Miele, Inc..................... Miele............. M
National Propane Gas NPGA.............. TA
Association.
Pacific Gas and Electric....... PG&E.............. U
Sub-Zero Group, Inc............ Sub-Zero.......... M
Tennessee Congress Member...... .................. TM
U.S. Chamber of Commerce, The Associations.. TA
American Chemistry Council,
American Coke and Coal
Chemicals Institute, American
Forest & Paper Association,
American Fuel & Petrochemical
Manufacturers, American
Petroleum Institute, Brick
Industry Association, Council
of Industrial Boiler Owners,
National Association of Home
Builders, National Association
of Manufacturers, National
Mining Association, National
Oilseed Processors
Association, Portland Cement
Association.
Whirlpool Corporation.......... Whirlpool......... M
Wisconsin Senators............. .................. CM
------------------------------------------------------------------------
* CM: Congress Member; EA: Efficiency Advocate; GA: Government Agency;
IR: Industry Representative; M: Manufacturer; RO: Research
Organization; TA: Trade Association; U: Utility.
As part of the June 2015 NOPR, DOE also noted that it was deferring
its decision regarding whether to adopt amended energy conservation
standards for conventional cooking tops, pending further study. 80 FR
33030, 33038-33040. In both the test procedure NOPR published on
January 30, 2013 (78 FR 6232, the January 2013 TP NOPR) and the test
procedure SNOPR published on December 3, 2014 (79 FR 71894, the
December 2014 TP SNOPR), DOE proposed amendments to the cooking
products test procedure in Appendix I that would allow for the testing
of active mode energy consumption of induction cooking tops. After
reviewing public comments on the December 2014 TP SNOPR, conducting
further discussions with manufacturers, and performing additional
analyses, DOE decided that further study was required before an updated
cooking top test procedure could be established that produces test
results which measure energy use during a representative average use
cycle for all types of cooking tops, is repeatable and reproducible,
and is not unduly burdensome to conduct. 80 FR 37954 (July 2, 2015).
As discussed in section III.C, on August 22, 2016, DOE published in
the Federal Register a SNOPR proposing amendments to the test
procedures for conventional cooking tops and ovens that include, among
other things, test methods for induction cooking tops and gas cooking
tops with high burner input rates. 81 FR 57374. DOE is publishing this
document to propose new and amended energy conservation standards for
conventional cooking tops based on the proposed amendments to the test
procedure. As discussed in section III.C, DOE also proposed to repeal
the test procedure for conventional ovens in the August 2016 TP SNOPR.
As a result, DOE has also revised its proposal from the June 2015 NOPR
for conventional ovens from a performance-based standard to a
prescriptive standard.
III. General Discussion
A. Scope of Coverage
As discussed in section II.A of this SNOPR, 42 U.S.C. 6292(a)(10)
of EPCA covers kitchen ranges and ovens, or ``cooking products.'' DOE's
regulations define ``cooking products'' as consumer products that are
used as the major household cooking appliances. They are designed to
cook or heat different types of food by one or more of the following
[[Page 60793]]
sources of heat: Gas, electricity, or microwave energy. Each product
may consist of a horizontal cooking top containing one or more surface
units \17\ and/or one or more heating compartments. (10 CFR 430.2) In
this SNOPR, DOE is considering energy conservation standards for
certain residential conventional cooking products, namely, conventional
cooking tops and conventional ovens.
---------------------------------------------------------------------------
\17\ The term surface unit refers to burners for gas cooking
tops, electric resistance heating elements for electric cooking
tops, and inductive heating elements for induction cooking tops.
---------------------------------------------------------------------------
DOE proposed in the August 2016 TP SNOPR to define a combined
cooking product as a household cooking appliance that combines a
conventional cooking top and/or conventional oven with other appliance
functionality, which may or may not include another cooking product. 81
FR 57374, 57378. In this rulemaking, DOE is not considering combined
cooking products as a distinct product category and is not basing its
product classes on that category. Instead, DOE is considering energy
conservation standards for conventional cooking tops and conventional
ovens separately. Because combined cooking products consist, in part,
of a cooking top and/or oven, any potential cooking top or oven
standards would apply to the individual components of the combined
cooking product.
As part of the 2009 standards rulemaking for conventional cooking
products, DOE did not consider energy conservation standards for
residential conventional gas cooking products with higher burner input
rates, including products marketed as ``commercial-style'' or
``professional-style,'' due to a lack of available data for determining
efficiency characteristics of those products. DOE considered such
products to be gas cooking tops with burner input rates greater than
14,000 British thermal units (Btu)/hour (h) and gas ovens with burner
input rates greater than 22,500 Btu/h. 74 FR 16040, 16054 (Apr. 8,
2009); 72 FR 64432, 64444-64445 (Nov. 15, 2007). DOE also stated that
the DOE cooking products test procedures at that time may not
adequately measure performance of gas cooking tops and ovens with
higher burner input rates. 72 FR 64432, 64444-64445 (Nov. 15, 2007).
As part of the February 2014 RFI, DOE stated that it tentatively
planned to consider energy conservation standards for all residential
conventional cooking products, including commercial-style gas cooking
products with higher burner input rates. In addition, DOE stated that
it may consider developing test procedures for these products and
determine whether separate product classes are warranted. 79 FR 8337,
8340 (Feb. 12, 2014).
As discussed in section III.C of this SNOPR, DOE is proposing to
amend the conventional cooking top test procedure in Appendix I to, in
part, measure the energy use of commercial-style gas cooking tops with
high burner input rates. See 81 FR 57374, 57385-57386. As discussed in
section III.B of this SNOPR, DOE proposed to repeal the conventional
oven test procedure in the August 2016 TP SNOPR. Due to the
uncertainties in analyzing a performance-based standard using oven
testing provisions that DOE is proposing to remove from the test
procedure, DOE is proposing to adopt prescriptive design requirements
for the control system of conventional ovens, including commercial-
style ovens with higher burner input rates.
DOE notes that the current definitions for ``conventional cooking
top'' and ``conventional oven'' in 10 CFR 430.2 already cover
commercial-style gas cooking products with higher burner input rates,
as these products are household cooking appliances with surface units
or compartments intended for the cooking or heating of food by means of
a gas flame. As a result, DOE is proposing energy conservation
standards for all residential conventional cooking tops and
conventional ovens, including commercial-style products with higher
burner input rates. As discussed in section IV.A.2 of this SNOPR, DOE
is not proposing to establish a separate product class for gas cooking
tops and ovens with higher burner input rates that are marketed as
``commercial-style'' and, as a result, DOE is not proposing separate
definitions for these products.
In response to the June 2015 NOPR, AHAM and GE commented that DOE
should revise the definition of conventional ovens to make it clear
that the definition encompasses the primary cooking product in a home
and does not include ancillary cooking products that do not fit
conventional cooking product use patterns (i.e., intermittent use
products). Specifically, AHAM and GE stated that the definition should
specify that conventional ovens include a thermostat setting that can
be set to control the internal temperature of the oven to 325 degrees
Fahrenheit ([deg]F) higher than room ambient air temperature. (AHAM,
No. 29 at p. 7; \18\ GE, No. 32 at p. 2)
---------------------------------------------------------------------------
\18\ A notation in the form ``AHAM, No. 29 at p. 7'' identifies
a written comment (1) made by AHAM; (2) recorded in document number
29 that is filed in the docket of this energy conservation standards
rulemaking (Docket No. EERE-2014-BT- STD-0005) and maintained in the
Resource Room of the Building Technologies Program; and (3) which
appears on page 7 of document number 29.
---------------------------------------------------------------------------
DOE notes that the change to the conventional oven definition
proposed by AHAM and GE could result unintentionally in certain
products not being covered. DOE currently defines ``conventional
ovens'' in 10 CFR 430.2 as cooking products that are used as the major
household cooking appliance and consist of one or more compartments
intended for the cooking or heating of food by means of either a gas
flame or electric resistance heating. DOE notes that the means of
heating and description of the product are clearly specified in the
current definition. DOE's definition relates to the functionality of
the product, not its intended use, so a conventional oven would be
considered a covered product whether it serves a primary or ancillary
application. DOE is not proposing to define conventional ovens based on
their intended use and a product that meets the existing definition
would be considered a covered product. If a manufacturer is unable to
test a product in accordance with the provisions in the test procedure
(e.g., setting the oven thermostat), a manufacturer may apply for a
waiver from the test procedure, in accordance with 10 CFR 430.27, if it
is able to provide an explanation for why its product design is unique
and would require different considerations for the test conditions. DOE
welcomes comments on whether there are products that would meet the
definition of a conventional oven, but that could not be tested
according to the DOE test procedure.
B. Prescriptive Standard for Conventional Ovens
This SNOPR proposes to adopt a prescriptive design requirement for
the control system of conventional ovens. DOE considered a combination
of factors in developing its proposal to prescribe a control design
requirement for conventional ovens, rather than proposing to regulate
IAEC with a performance standard. The rationale for this tentative
decision is explained below.
DOE's analysis determined that the baseline efficiency level for
conventional ovens corresponds to a linear power supply control design.
For conventional gas ovens, DOE's analysis showed that the baseline
control design also uses an ``intermittent ignition'' system with a
glo-bar (also referred to as a hot surface) igniter. As discussed in
section V.A of this SNOPR, the design
[[Page 60794]]
options analyzed to achieve the proposed standard level for
conventional ovens involved changing from a control design that uses a
linear power supply to one that incorporates a switch-mode power supply
(SMPS). In addition, for gas ovens, the proposed standard level
corresponds to switching from an intermittent glo-bar ignition system
to an ``intermittent/interrupted ignition'' or ``intermittent pilot
ignition'' (e.g., electronic spark ignition). Descriptions of these
design options are discussed further in section IV.A.3.b of this SNOPR.
DOE notes that the currently applicable prescriptive standards for gas
ovens prohibit constant burning pilot lights, which are a type of
continuous ignition system that would be precluded by the proposed
standards.
DOE conducted the analysis for conventional ovens for this SNOPR
based on the test procedure adopted in the July 2, 2015 final rule (80
FR 37954, hereinafter referred to as the July 2015 TP Final Rule),
which was the current test procedure at the time the standards analysis
was conducted. After reviewing public comments and considering
additional feedback and test data from manufacturers, DOE concluded
that commercial-style ovens have inherently lower efficiencies than for
residential-style ovens with comparable cavity sizes when measured
using the previous version of the test procedure adopted in the July
2015 TP Final Rule, due to the greater thermal mass of the cavity and
racks in commercial-style ovens. Due to uncertainty regarding such
efficiency measurement, DOE is proposing to repeal the conventional
oven test procedure, as described in the August 2016 TP SNOPR, and
determined that further investigation would be required to develop test
methods that appropriately account for the effects of certain
commercial-style oven design features (e.g., heavier-gauge cavity
construction, high input rate burners, extension racks, etc.). 81 FR
57374, 57378-57379. The uncertainties in analyzing a performance-based
standard using oven testing provisions that DOE proposed to remove from
the test procedure in the August 2016 TP SNOPR have led DOE to propose
prescriptive design requirements for the control system of conventional
ovens.
As discussed in section II.B.1 of this SNOPR, manufacturers are not
currently required to conduct testing to certify compliance with
standards because DOE has promulgated only prescriptive standards for
gas cooking products. The prescriptive-based standard for conventional
ovens proposed in this SNOPR would continue to minimize burden on
manufacturers because it would not require manufacturers to test, rate,
and label conventional ovens.
For the reasons cited above, DOE is proposing a prescriptive
requirement for conventional ovens that would require conventional
electric ovens to not be equipped with a control system that uses a
linear power supply. The proposed standards would also require that
conventional gas ovens be equipped with a control system that uses
intermittent/interrupted ignition or intermittent pilot ignition and
does not use a linear power supply.
C. Test Procedure
EPCA sets forth generally applicable criteria and procedures for
DOE's adoption and amendment of test procedures. (42 U.S.C. 6293)
Manufacturers of covered products must use these test procedures to
certify to DOE that their product complies with energy conservation
standards and to quantify the efficiency of their product. DOE's test
procedures for conventional cooking tops, conventional ovens, and
microwave ovens are codified at appendix I to subpart B of Title 10 of
the CFR part 430.
DOE established the test procedures in a final rule published in
the Federal Register on May 10, 1978. 43 FR 20108, 20120-20128. DOE
revised its test procedures for cooking products to more accurately
measure their efficiency and energy use, and published the revisions as
a final rule in 1997. 62 FR 51976 (Oct. 3, 1997). These test procedure
amendments included: (1) A reduction in the annual useful cooking
energy; (2) a reduction in the number of self-clean oven cycles per
year; and (3) incorporation of portions of International
Electrotechnical Commission (IEC) Standard 705-1988, ``Methods for
measuring the performance of microwave ovens for household and similar
purposes,'' and Amendment 2-1993 for the testing of microwave ovens.
Id. The test procedures for conventional cooking products establish
provisions for determining estimated annual operating cost, cooking
efficiency (defined as the ratio of cooking energy output to cooking
energy input), and energy factor (defined as the ratio of annual useful
cooking energy output to total annual energy input). 10 CFR 430.23(i);
Appendix I. These provisions for conventional cooking products are not
currently used for compliance with any energy conservation standards
because the present standards are design requirements; in addition,
there is no EnergyGuide \19\ labeling program for cooking products.
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\19\ For more information on the EnergyGuide labeling program,
see: www.access.gpo.gov/nara/cfr/waisidx_00/16cfr305_00.html.
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DOE subsequently conducted a rulemaking to address standby and off
mode energy consumption, as well as certain active mode (i.e., fan-only
mode) testing provisions, for residential conventional cooking
products. DOE published a final rule on October 31, 2012 (77 FR 65942,
the October 2012 TP Final Rule), adopting standby and off mode
provisions that satisfy the EPCA requirement that DOE include measures
of standby mode and off mode power in its test procedures for
residential products, if technically feasible. (42 U.S.C.
6295(gg)(2)(A))
On January 30, 2013, DOE published a NOPR (78 FR 6232, the January
2013 TP NOPR) proposing amendments to Appendix I that would allow for
testing the active mode energy consumption of induction cooking
products; i.e., conventional cooking tops equipped with induction
heating technology for one or more surface units on the cooking top.
DOE proposed to incorporate induction cooking tops by amending the
definition of ``conventional cooking top'' to include induction heating
technology. Furthermore, DOE proposed to require for all cooking tops
the use of test equipment compatible with induction technology.
Specifically, DOE proposed to replace the solid aluminum test blocks
currently specified in the test procedure for cooking tops with hybrid
test blocks comprising two separate pieces: An aluminum body and a
stainless steel base. 78 FR 6232, 6234 (Jan. 30, 2013).
In response to the February 2014 RFI, AHAM commented that DOE
should rely on the finalized version of the test procedure (i.e., the
October 2012 TP Final Rule) and not a proposed test procedure when
evaluating energy conservation standards, particularly given the
significant comments opposing the proposed test procedure (as discussed
in AHAM's comments on the January 2013 TP NOPR). Accordingly, AHAM
stated that DOE should finalize amendments to the test procedure before
conducting any analysis for the standards rulemaking, or else proceed
without addressing induction cooking products in this round of
standards rulemaking. (AHAM, No. 9 at pp. 3-4, 6, 7)
AHAM and Whirlpool commented that a test procedure should be
developed to address commercial-style cooking products if DOE plans to
[[Page 60795]]
evaluate them in a standards analysis. (AHAM, No. 9 at p. 2; Whirlpool,
No. 13 at p. 1) AHAM also commented that DOE should either proceed
without addressing commercial-style products as it did for the April
2009 Final Rule or delay the rulemaking analysis until there is a
finalized test procedure that can measure commercial-style products.
(AHAM, No. 9 at p. 4, 6, 7) AHAM added that it could not provide data
regarding the differences between residential-style and commercial-
style gas cooking products without a test procedure to measure higher
input rate burners. (AHAM, No. 9 at p. 7) The California IOUs supported
amending the test procedure to measure the energy use of residential
commercial-style gas cooking products with higher burner input rates.
(California IOUs, No. 11 at p. 2)
On December 3, 2014, DOE published an SNOPR (the December 2014 TP
SNOPR), in which DOE modified its proposal from the January 2013 TP
NOPR to specify different test equipment that would allow for measuring
the energy efficiency of induction cooking tops, and would include an
additional test block size for electric surface units with large
diameters (both induction and electric resistance). 79 FR 71894. In
addition, DOE proposed methods to test non-circular electric surface
units, electric surface units with flexible concentric cooking zones,
and full-surface induction cooking tops. Id. In the December 2014 TP
SNOPR, DOE also proposed amendments to add a larger test block size to
test gas cooking top burners with higher input rates. Id.
In the December 2014 TP SNOPR, DOE also proposed methods for
measuring conventional oven volume, clarification that the existing
oven test block must be used to test all ovens regardless of input
rate, and a method to measure the energy consumption and efficiency of
conventional ovens equipped with an oven separator. 79 FR 71894 (Dec.
3, 2014). DOE published the July 2015 TP Final Rule adopting the test
procedure amendments discussed above for conventional ovens only. 80 FR
37954.
AHAM and Electrolux commented that DOE did not provide sufficient
time after finalizing the test procedure for conventional ovens for
stakeholders to evaluate the proposed conventional oven standards. AHAM
and Electrolux stated that manufacturers do not regularly conduct
energy tests because there is no current standard for conventional
ovens. As a result, they stated that more time was needed for
manufacturers to fully understand the impact of the final test
procedure and evaluate the proposed standards for conventional ovens.
(AHAM, No. 29 at pp. 4-5; Electrolux, No. 27 at pp. 2-3)
AHRI commented that DOE states in its regulations that it will
finalize amended test procedures before introducing applicable amended
standards.\20\ AHRI noted that for conventional ovens, DOE published a
final rule to amend the test procedure more than 3 weeks after the
publication of the June 2015 NOPR which introduced amended standards
and thus did not comply with the codified procedures noted above. AHRI
believes that the comment period did not provide manufacturers with
sufficient time to fully evaluate the proposed standards with the
amended test procedure. (AHRI, No. 34 at p. 2)
---------------------------------------------------------------------------
\20\ AHRI made this comment in reference to 10 CFR part 430,
subpart C, appendix A(7)(c).
---------------------------------------------------------------------------
Sub-Zero expressed concern that limitations in the test procedures
and available data might unfairly impact commercial-style products in a
rulemaking establishing energy conservation standards. (Sub-Zero, No.
25 at p. 2)
AHAM submitted an additional comment after the end of the June 2015
NOPR comment period to discuss additional industry product testing. As
part of this comment, AHAM reiterated its concern that manufacturers
were unable to adequately analyze DOE's proposed rule during the
comment period because DOE did not provide sufficient time after
finalizing the conventional oven test procedure for stakeholders to
evaluate the proposed standards. (AHAM, No. 38 at p. 2)
DOE has considered these comments as part of this rulemaking and
notes that this SNOPR provides additional opportunity for interested
parties to provide comment based on the proposed cooking product test
procedure discussed below. With respect to the process of establishing
test procedures and standards for a given product, DOE notes that,
while not legally obligated to do so, it generally follows the approach
laid out in guidance found in 10 CFR part 430, subpart C, Appendix A
(Procedures, Interpretations and Policies for Consideration of New or
Revised Energy Conservation Standards for Consumer Products). That
guidance provides, among other things, that, when necessary, DOE will
issue final, modified test procedures for a given product prior to
publication of the NOPR proposing energy conservation standards for
that product. While DOE strives to follow the procedural steps outlined
in its guidance, there may be circumstances in which it may be
necessary or appropriate to deviate from it. In such instances, the
guidance indicates that DOE will provide notice and an explanation for
the deviation. Accordingly, DOE is providing notice that it continues
to develop the final test procedure for conventional cooking products.
As discussed below, DOE has carefully considered the significant
comments regarding the test procedures for both induction cooking tops
and commercial-style cooking products, which led to DOE publishing an
additional SNOPR on August 22, 2016. DOE believes proposed amendments
in the August 2016 TP SNOPR address the significant concerns regarding
the conventional cooking products test procedure and will issue the
final test procedure before the standards final rule. Furthermore, as
discussed in section IV.C.5 of this SNOPR, DOE is proposing to adopt a
prescriptive design requirement for conventional ovens. Because this
proposed standard is a design requirement and not a performance
standard (i.e., minimum efficiency or maximum energy consumption),
manufacturers would not be required to test using the DOE test
procedure for conventional ovens to certify products to the proposed
standards in this SNOPR.
As discussed in the June 2015 NOPR for conventional ovens, DOE
received a significant number of comments regarding the proposed hybrid
test block test method for cooking tops in response to the December
2014 TP SNOPR and in separate interviews conducted with conventional
cooking product manufacturers in February and March of 2015. AHAM and
manufacturers commented that the hybrid test block method, as proposed,
presented many issues with the construction and configuration of the
test block which had not yet been addressed, and which left the
repeatability and reproducibility of the test procedure in question. 80
FR 33030, 33039-33040 (June 10, 2015). A number of manufacturers that
produce and sell products in Europe supported the use of a water-
heating test method and harmonization with International
Electrotechnical Commission (IEC) Standard 60350-2 Edition 2,
``Household electric appliances--Part 2: Hobs--Method for measuring
performance'' (IEC Standard 60350-2) for measuring the energy
consumption of electric cooking tops. These manufacturers noted the
test methods in IEC Standard 60350-2 are compatible with all electric
cooking top types, specify additional cookware diameters
[[Page 60796]]
to account for the variety of surface unit sizes on the market, and use
test loads that represent real-world cooking top loads. Efficiency
advocates also recommended that DOE require water-heating test methods
to produce a measure of cooking efficiency for conventional cooking
tops that is more representative of actual cooking performance than the
hybrid test block method. 80 FR 33030, 33039-33040 (June 10, 2015).
For these reasons, DOE decided to defer its decision regarding
adoption of energy conservation standards for conventional cooking tops
until a representative, repeatable and reproducible test method for
cooking tops was finalized. 80 FR 33030, 33040 (June 10, 2015).
AHAM, GE, and Electrolux commented in response to the June 2015
NOPR supporting DOE's decision to not propose standards for cooking
tops because there was not yet a representative, repeatable,
reproducible test procedure for this product category. (AHAM, No. 29 at
p. 2; GE, No. 32 at p. 1; Electrolux, No. 27 at p. 2) AHAM stated that
in addition to the time required to identify an appropriate test method
for cooking tops, manufacturers will need time to obtain test
equipment, verify that the test method is repeatable and reproducible,
test their full product lines, and provide data to DOE to form the
basis for any energy conservation standards. Therefore, AHAM believed
that consideration of energy conservation standards for cooking tops
would only be possible and appropriate in the next standards rulemaking
cycle for conventional cooking products. (AHAM, No. 29 at p. 3)
AHAM, GE and Electrolux commented that 42 U.S.C. 6295(m)(4)(B),
which specifies that a manufacturer shall not be required to apply new
standards to a product with respect to which other new standards have
been required during the prior 6-year period, prohibits DOE from
proceeding with cooking tops on a different schedule than conventional
ovens if DOE decides to proceed with standards for conventional ovens.
(AHAM, No. 29 at pp. 2,3; GE, No. 32 at p. 2; Electrolux, No. 27 at p.
2) GE added that, regardless of when standards for cooking tops are
proposed or finalized, the compliance date must not be until at least 6
years after the compliance date for the proposed standards for
conventional ovens. (GE, No. 32 at p. 2)
Whirlpool commented that, although the FTC has not ruled on whether
EnergyGuide labels will be justified for conventional ranges, Natural
Resources Canada requires a comprehensive label that declares the
energy consumption of the combined product. Whirlpool stated that DOE
should consider this possibility when evaluating whether to align the
compliance dates for conventional cooking tops and ovens. (Whirlpool,
No. 33 at p. 4)
EEI commented that if DOE adopts new standards for both
conventional cooking tops and ovens, the compliance dates for both
products should be as close as possible to be market neutral. (EEI,
Public Meeting Transcript, No. 35 at p. 18) \21\
---------------------------------------------------------------------------
\21\ A notation in the form ``EEI, Public Meeting Transcript,
No. 35 at p. 18'' identifies an oral comment that DOE received
during the July 14, 2015, residential conventional oven energy
conservation standards NOPR public meeting. Oral comments were
recorded in the public meeting transcript and are available in the
residential conventional cooking products energy conservation
standards rulemaking docket (Docket No. EERE-2014-BT-STD-0005). This
particular notation refers to a comment: (1) Made by Edison Electric
Institute during the public meeting; (2) recorded in document number
35, which is the public meeting transcript that is filed in the
docket of this energy conservation standards rulemaking; and (3)
which appears on page 18 of document number 35.
---------------------------------------------------------------------------
DOE published an additional test procedure SNOPR on August 22, 2016
(81 FR 57374) that proposes to amend the test procedures for
conventional cooking tops. Given the feedback from interested parties
discussed above and based on the additional testing and analysis
conducted for the test procedure rulemaking, in the August 2016 TP
SNOPR, DOE withdrew its proposal for testing conventional cooking tops
with a hybrid test block. Instead, DOE is proposing to amend its test
procedure to incorporate by reference the relevant sections of European
Standard EN 60350-2:2013 ``Household electric cooking appliances Part
2: Hobs--Methods for measuring performance'' 22 23 (EN
60350-2:2013), which provide a water-heating test method to measure the
energy consumption of electric cooking tops. The test method specifies
the quantity of water to be heated in a standardized test vessel whose
size is selected based on the diameter of the surface unit under test.
The test vessels specified in EN 60350-2:2013 are compatible with all
cooking top technologies and surface unit diameters available on the
U.S. market. 81 FR 57374, 57381-57384.
---------------------------------------------------------------------------
\22\ Hob is the British English term for cooking top.
\23\ On April 25, 2014, IEC made available the draft version of
IEC Standard 60350-2 Edition 2.0 Committee Draft (IEC 60350-2 CD).
DOE notes that the draft amendment to IEC 60350-2 on which testing
for the January 2013 NOPR was based includes the same basic test
method as the 2014 IEC 60350-2 CD. DOE also notes that the European
standard EN 60350-2:2013 is based on the draft amendment to IEC
60350-2. DOE believes that the IEC procedure, once finalized, will
retain the same basic test method as currently contained in EN
60350-2:2013.
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DOE is also proposing to extend the test methods provided in EN
60530-2:2013 to gas cooking tops by correlating the burner input rate
and test vessel diameters specified in EN 30-2-1:1998 ``Domestic
cooking appliances burning gas--Part 2-1: Rational use of energy--
General'' (EN 30-2-1) to the test vessel diameters and water loads
already included in EN 60350-2:2013. The range of gas burner input
rates covered by EN 30-2-1 includes surface units with burners
exceeding 14,000 Btu/h, and thus EN 30-2-1 provides a method to test
gas surface units with high input rate burners, which previously had
not been addressed in the DOE test procedure or energy conservation
standards. 81 FR 57374, 57385-57386.
In the August 2016 TP SNOPR, DOE proposed to amend the conventional
cooking top test procedure to specify that the test energy consumptions
measured for each surface unit be averaged together and then normalized
to a representative load size to determine the total per-cycle energy
consumption of the cooking top. The annual active mode energy
consumption of the cooking top would be calculated by multiplying the
total per-cycle energy consumption of the cooking top by the ``adjusted
cooking frequency.'' 81 FR 57374, 57387-57388. As discussed in the
August 2016 TP SNOPR, DOE determined the adjusted cooking frequency by
comparing the energy use determined based on cooking frequency data
from 2009 DOE Energy Information Administration (EIA) Residential
Energy Consumption Survey (RECS 2009) \24\ and the water heating test
method, to recent field use data for cooking products.25 26
Based on this review, DOE determined that the estimated annual active
mode cooking top energy consumption using the cooking frequency based
on RECS 2009 data and the water heating test method did not adequately
represent consumer use. As a result, DOE proposed in the August 2016 TP
SNOPR
[[Page 60797]]
to normalize the cooking frequency to account for differences between
the duration of a cooking event represented in the RECS data and the
water heating test method. DOE also proposed to calculate the
integrated annual energy consumption for the cooking top as the sum of
the annual active mode energy consumption and the combined low-power
mode energy consumption. Id.
---------------------------------------------------------------------------
\24\ U.S. Department of Energy: Energy Information
Administration, Residential Energy Consumption Survey: 2009 RECS
Survey Data (2013) (Available at: http://www.eia.gov/consumption/residential/data/2009/).
\25\ California Energy Commission. 2009 California Residential
Appliance Saturation Study, October 2010. Prepared for the
California Energy Commission by KEMA, Inc. Contract No. 200-2010-
004. <http://www.energy.ca.gov/2010publications/CEC-200-2010-004/CEC-200-2010-004-V2.PDF>.
\26\ FSEC 2010. Updated Miscellaneous Electricity Loads and
Appliance Energy Usage Profiles for Use in Home Energy Ratings, the
Building America Benchmark and Related Calculations. Published as
FSEC-CR-1837-10, Florida Solar Energy Center, Cocoa, FL.
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Because DOE has proposed test procedures for conventional cooking
tops that produce representative, repeatable, reproducible test
results, DOE is now combining the rulemaking to consider energy
conservation standards for conventional cooking tops and ovens and is
correspondingly aligning the compliance dates for both product
categories. For this SNOPR, DOE evaluated its proposed energy
conservation standards for conventional cooking tops based on the
proposed cooking top test procedure discussed above.
As discussed in section III.B, DOE is proposing to repeal the
conventional oven test procedure as discussed in the August 2016 TP
SNOPR and is proposing to adopt prescriptive design requirements for
the control system of conventional ovens. As a result, manufacturers
would not need to test, rate, and label conventional ovens to
demonstrate compliance with the proposed prescriptive design
requirements.
Whirlpool and EEI support the use of an IAEC metric that includes
cooking energy, standby energy, and self-clean energy because it allows
manufacturers flexibility in incorporating cost-effective design
options that improve energy efficiency. Whirlpool also believes it
would allow manufacturers to consider tradeoffs between consumer
utility and energy efficiency improvements. (Whirlpool, No. 33 at p. 5;
EEI, No. 30 at p. 3) EEI added that an integrated metric would
facilitate the development of ``smart'' ovens that are more interactive
with energy supply grids to allow consumers to determine the most
energy-efficient and cost-effective times to operate them. EEI stated
that a smart oven may need to communicate with an energy grid on a
continuous basis, but the communication function may require a very
small increase in the energy used in the standby mode or off mode.
According to EEI, a separate standard for standby mode or off mode
could result in appliances that are not able to have the ``smart''
functionality. (EEI, No. 30 at p. 3)
In this SNOPR, DOE performed its analysis for both ovens and
cooking tops using the IAEC metric to account for both active mode and
standby mode design options. As described in section V.C.1 of this
SNOPR, DOE is proposing a prescriptive standard for conventional ovens
and a performance standard using the IAEC metric for conventional
cooking tops. For conventional ovens, DOE tentatively determined that a
prescriptive requirement would be a more effective means of achieving
energy savings for all oven product types (i.e., residential-style and
commercial-style ovens) due to uncertainties in the methods used to
measure conventional oven IAEC that DOE is proposing to remove from the
test procedure in the August 2016 TP SNOPR. DOE also notes that the
proposed prescriptive standards for conventional ovens would not
preclude the introduction of connected products because the
prescriptive design requirements for the control systems does not
directly affect the design of the connected feature. Moreover, because
DOE is not proposing a separate standby mode and off mode performance
standard for conventional cooking tops, connected cooking tops would
not be precluded.
In response to the June 2015 NOPR, Whirlpool also questioned the
energy use metric for conventional ranges in light of the potentially
separate standards schedule for conventional cooking tops and
conventional ovens. Whirlpool stated that an integrated metric would
allow manufacturers to pursue the most technically-feasible and/or
economically-justifiable design options to meet the relevant standard
while still achieving the same national energy conservation had they
been separate. (Whirlpool, No. 33 at p. 3) Whirlpool noted that since
standby power is included in the oven and cooking top test procedures,
and that standby power for conventional ranges cannot be separated into
oven and cooking top portions of standby energy, it is unclear how
manufacturers would test and certify the oven and cooking top portions
of conventional ranges separately. (Whirlpool, No. 33 at p. 3)
As discussed above, DOE is now proposing standards for both
conventional cooking tops and ovens with the same compliance date. As
noted in section III.A of this SNOPR, any potential cooking top or oven
standard would apply to the individual components of the combined
cooking product. As a result, DOE does not foresee any issues with
compliance for combined cooking products, such as conventional ranges,
that include both a conventional cooking top and conventional oven. The
test procedure amendments proposed in the August 2016 TP SNOPR include
provisions for measuring the standby power of combined cooking products
and calculating the IAEC for the conventional cooking top component of
combined cooking products. In addition, as discussed above, because DOE
is proposing prescriptive standards for conventional ovens,
manufacturers would not be required to conduct testing according to
Appendix I to demonstrate compliance with standards.
D. Technological Feasibility
1. General
In each energy conservation standards rulemaking, DOE conducts a
screening analysis based on information gathered on all current
technology options and prototype designs that could improve the
efficiency of the products or equipment that are the subject of the
rulemaking. As the first step in such an analysis, DOE develops a list
of technology options for consideration in consultation with
manufacturers, design engineers, and other interested parties. DOE then
determines which of those means for improving efficiency are
technologically feasible. DOE considers technologies incorporated in
commercially available products or in working prototypes to be
technologically feasible. 10 CFR part 430, subpart C, appendix A,
section 4(a)(4)(i).
After DOE has determined that particular technology options are
technologically feasible, it further evaluates each technology option
in light of the following additional screening criteria: (1)
Practicability to manufacture, install, and service; (2) adverse
impacts on product utility or availability; and (3) adverse impacts on
health or safety. 10 CFR part 430, subpart C, appendix A, section
4(a)(4)(ii)-(iv). Section IV.B of this SNOPR discusses the results of
the screening analysis for residential conventional cooking products,
particularly the designs DOE considered, those it screened out, and
those that are the basis for the TSLs in this rulemaking. For further
details on the screening analysis for this rulemaking, see chapter 4 of
the SNOPR Technical Support Document (TSD).
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt an amended standard for a type or class
of covered product, it must determine the maximum improvement in energy
efficiency or maximum reduction in energy use that is technologically
feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the
[[Page 60798]]
engineering analysis, DOE determined the maximum technologically
feasible (``max-tech'') improvements in energy efficiency for
residential conventional cooking tops, using the design parameters for
the most efficient products available on the market or in working
prototypes, and information from the previous rulemaking. The max-tech
levels that DOE determined for this rulemaking are described in section
IV.C.3 of this proposed rule and in chapter 5 of the SNOPR TSD.
E. Energy Savings
1. Determination of Savings
For each TSL, DOE projected energy savings from the products that
are the subject of this rulemaking purchased in the 30-year period that
begins in the year of compliance with new and amended standards (2019
to 2048).\27\ The savings are measured over the entire lifetime of
products purchased in the 30-year analysis period. DOE quantified the
energy savings attributable to each TSL as the difference in energy
consumption between each standards case and the no-new-standards case.
The no-new-standards case represents a projection of energy consumption
in the absence of new and amended efficiency standards, and it
considers market forces and policies that affect demand for more
efficient products.
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\27\ Each TSL is comprised of specific efficiency levels for
each product class. The TSLs considered for this SNOPR are described
in section V.A of this SNOPR. DOE conducted a sensitivity analysis
that considers impacts for products shipped in a 9-year period.
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DOE uses its national impact analysis (NIA) spreadsheet models to
estimate national energy savings (NES) from potential new and amended
standards. The NIA spreadsheet model (described in section IV.H of this
SNOPR) calculates energy savings in terms of site energy, which is the
energy directly consumed by products at the locations where they are
used. Based on the site energy, DOE calculates NES in terms of primary
energy savings at the site or at power plants, and also in terms of
full-fuel-cycle (FFC) energy savings. The FFC metric includes the
energy consumed in extracting, processing, and transporting primary
fuels (i.e., coal, natural gas, petroleum fuels), and thus presents a
more complete picture of the impacts of energy conservation
standards.\28\ DOE's approach is based on the calculation of an FFC
multiplier for each of the energy types used by covered products or
equipment. For more information on FFC energy savings, see section
IV.H.2 of this SNOPR. For natural gas, the primary energy savings are
considered to be equal to the site energy savings.
---------------------------------------------------------------------------
\28\ The FFC metric is discussed in DOE's statement of policy
and notice of policy amendment. 76 FR 51282 (Aug. 18, 2011), as
amended at 77 FR 49701 (Aug. 17, 2012).
---------------------------------------------------------------------------
2. Significance of Savings
To adopt any new or amended standards for a covered product, DOE
must determine that such action would result in ``significant'' energy
savings. (42 U.S.C. 6295(o)(3)(B)) Although the term ``significant'' is
not defined in the Act, the U.S. Court of Appeals for the District of
Columbia Circuit, in Natural Resources Defense Council v. Herrington,
768 F.2d 1355, 1373 (D.C. Cir. 1985), opined that Congress intended
``significant'' energy savings in the context of EPCA to be savings
that were not ``genuinely trivial.'' The energy savings for the
proposed standards (presented in section IV.H.2 of this SNOPR) are
nontrivial, and, therefore, DOE considers them ``significant'' within
the meaning of section 325 of EPCA.
F. Economic Justification
1. Specific Criteria
As noted above, EPCA provides seven factors to be evaluated in
determining whether a potential energy conservation standard is
economically justified. (42 U.S.C. 6295(o)(2)(B)(i)) The following
sections discuss how DOE has addressed each of those seven factors in
this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a potential amended standard on
manufacturers, DOE conducts a manufacturer impact analysis (MIA), as
discussed in section IV.J of this SNOPR. DOE first uses an annual cash-
flow approach to determine the quantitative impacts. This step includes
both a short-term assessment--based on the cost and capital
requirements during the period between when a regulation is issued and
when entities must comply with the regulation--and a long-term
assessment over a 30-year period. The industry-wide impacts analyzed
include (1) INPV, which values the industry on the basis of expected
future cash flows; (2) cash flows by year; (3) changes in revenue and
income; and (4) other measures of impact, as appropriate. Second, DOE
analyzes and reports the impacts on different types of manufacturers,
including impacts on small manufacturers. Third, DOE considers the
impact of standards on domestic manufacturer employment and
manufacturing capacity, as well as the potential for standards to
result in plant closures and loss of capital investment. Finally, DOE
takes into account cumulative impacts of various DOE regulations and
other regulatory requirements on manufacturers. For individual
consumers, measures of economic impact include the changes in LCC and
PBP associated with new or amended standards. These measures are
discussed further in the following section. For consumers in the
aggregate, DOE also calculates the national net present value of the
economic impacts applicable to a particular rulemaking. DOE also
evaluates the LCC impacts of potential standards on identifiable
subgroups of consumers that may be affected disproportionately by a
national standard.
b. Savings in Operating Costs Compared to Increase in Price (LCC and
PBP)
EPCA requires DOE to consider 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 of, or in the
initial charges for, or maintenance expenses of, the covered product
that are likely to result from a standard. (42 U.S.C.
6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC and PBP
analysis.
The LCC is the sum of the purchase price of a product (including
its installation) and the operating expense (including energy,
maintenance, and repair expenditures) discounted over the lifetime of
the product. The LCC analysis requires a variety of inputs, such as
product prices, product energy consumption, energy prices, maintenance
and repair costs, product lifetime, and consumer discount rates
appropriate for consumers. To account for uncertainty and variability
in specific inputs, such as product lifetime and discount rate, DOE
uses a distribution of values, with probabilities attached to each
value.
The PBP is the estimated amount of time (in years) it takes
consumers to recover the increased purchase cost (including
installation) of a more-efficient product through lower operating
costs. DOE calculates the PBP by dividing the change in purchase cost
due to a more-stringent standard by the change in annual operating cost
for the year that standards are assumed to take effect.
For its LCC and PBP analysis, DOE assumes that consumers will
purchase the covered products in the first year of compliance with
amended standards. The LCC savings for the considered efficiency levels
are calculated relative
[[Page 60799]]
to the case that reflects projected market trends in the absence of
amended standards. DOE's LCC and PBP analysis is discussed in further
detail in section IV.F of this SNOPR.
c. Energy Savings
Although significant conservation of energy is a separate statutory
requirement for adopting an energy conservation standard, EPCA requires
DOE, in determining the economic justification of a standard, to
consider the total projected energy savings that are expected to result
directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As
discussed in section III.E of this SNOPR, DOE uses the NIA spreadsheet
models to project national energy savings.
d. Lessening of Utility or Performance of Products
In establishing product classes and in evaluating design options
and the impact of potential standard levels, DOE evaluates potential
standards that would not lessen the utility or performance of the
considered products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) Based on data
available to DOE, the standards proposed in this SNOPR would not reduce
the utility or performance of the products under consideration in this
rulemaking.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of
competition, as determined in writing by the Attorney General, that is
likely to result from a proposed standard. (42 U.S.C.
6295(o)(2)(B)(i)(V)) It also directs the Attorney General to determine
the impact, if any, of any lessening of competition likely to result
from a proposed standard and to transmit such determination to the
Secretary within 60 days of the publication of a proposed rule,
together with an analysis of the nature and extent of the impact. (42
U.S.C. 6295(o)(2)(B)(ii)) DOE will transmit a copy of this proposed
rule to the Attorney General with a request that the Department of
Justice (DOJ) provide its determination on this issue. DOE will publish
and respond to the Attorney General's determination in the final rule.
DOE invites comment from the public regarding the competitive impacts
that are likely to result from this proposed rule. In addition,
stakeholders may also provide comments separately to DOJ regarding
these potential impacts. See ADDRESSES section for information to send
comments to DOJ.
f. Need for National Energy Conservation
DOE also considers the need for national energy conservation in
determining whether a new or amended standard is economically
justified. (42 U.S.C. 6295(o)(2)(B)(i)(VI)) The energy savings from new
or amended standards are likely to provide improvements to the security
and reliability of the nation's energy system. Reductions in the demand
for electricity also may result in reduced costs for maintaining the
reliability of the nation's electricity system. DOE conducts a utility
impact analysis to estimate how standards may affect the nation's
needed power generation capacity, as discussed in section IV.M of this
SNOPR.
The proposed standards also are likely to result in environmental
benefits in the form of reduced emissions of air pollutants and
greenhouse gases (GHGs) associated with energy production and use. DOE
conducts an emissions analysis to estimate how standards may affect
these emissions, as discussed in section IV.K of this SNOPR; the
emissions impacts are reported in section V.B of this SNOPR. DOE also
estimates the economic value of emissions reductions resulting from the
considered TSLs, as discussed in section IV.L of this proposed rule.
g. Other Factors
EPCA allows the Secretary of Energy, in determining whether a
standard is economically justified, to consider any other factors that
the Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII))
To the extent interested parties submit any relevant information
regarding economic justification that does not fit into the other
categories described above, DOE could consider such information under
``other factors.''
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a
rebuttable presumption that an energy conservation standard is
economically justified if the additional cost to the consumer of a
product that meets the standard is less than three times the value of
the first year's energy savings resulting from the standard, as
calculated under the applicable DOE test procedure. DOE's LCC and PBP
analyses generate values used to calculate the effects that proposed
energy conservation standards would have on the payback period for
consumers. These analyses include, but are not limited to, the 3-year
payback period contemplated under the rebuttable-presumption test. In
addition, DOE routinely conducts an economic analysis that considers
the full range of impacts to consumers, manufacturers, the Nation, and
the environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The
results of this analysis serve as the basis for DOE's evaluation of the
economic justification for a potential standard level (thereby
supporting or rebutting the results of any preliminary determination of
economic justification). The rebuttable presumption payback calculation
is discussed in section IV.F.10 of this proposed rule.
G. Changes to 10 CFR 429.23 Addressing the Certification, Compliance
and Enforcement Criteria for Conventional Cooking Products
In this SNOPR, DOE is proposing to update the certification
requirements for cooking products in 10 CFR 429.23 to include the
annual energy use and integrated annual energy use metrics for
conventional gas and electric cooking tops in the sampling plan
requirements. Additionally, DOE is proposing to update the reporting
requirements for conventional ovens to reflect the proposed
prescriptive design requirements. DOE notes that the certification and
reporting requirements for conventional cooking tops and conventional
ovens also apply to the conventional cooking top component and
conventional oven component of combined cooking products.
H. Other Issues
AHAM submitted a late comment discussing additional industry
product testing, and provided a recommendation regarding the proposed
standard levels selected for electric self-clean ovens. In this
comment, AHAM stated that DOE did not analyze a sufficient sample size
of electric standard ovens and, as a result, the efficiency levels for
electric standard ovens presented in the June 2015 NOPR are
significantly stricter than for electric self-clean ovens. (AHAM, No.
39 at pp. 2-4) AHAM claimed that the standard levels proposed in the
June 2015 NOPR could result in manufacturers adding a self-clean cycle
to electric standard ovens instead of improving the oven's efficiency
to meet the proposed standard for electric standard ovens, thus
eliminating or reducing the availability of electric standard ovens
from the market. AHAM further stated that electric standard ovens are
the lowest-priced conventional ovens in the retail market, so
eliminating them would provide a hardship for low-
[[Page 60800]]
income and other consumers who rely on low purchase prices. (AHAM, No.
39 at pp. 4-5)
AHAM recommended standards for electric standard ovens that are
based on subtracting the average self-clean energy consumption from the
corresponding standard for electric self-clean ovens. AHAM believes
this approach would mitigate the uncertainties of the analysis, avoid
discriminating against consumers of electric standard ovens, and have a
negligible effect on the total energy savings compared to the standard
levels proposed in the June 2015 NOPR. (AHAM, No. 39 at pp. 7-8)
For the reasons discussed in section III.B of this SNOPR, DOE is
proposing a prescriptive design requirement for the control system for
conventional ovens in this SNOPR. This prescriptive standard would
require the same design changes for both standard and self-clean ovens.
As a result, DOE expects that the standards proposed in this SNOPR
would not impose stricter requirements on electric standard ovens than
on electric self-clean ovens, and would not eliminate or reduce the
availability of electric standard ovens.
IV. Methodology and Discussion of Comments
DOE used several analytical tools to estimate the impact of the
proposed standards. The first tool is a spreadsheet that calculates the
LCC and PBP of potential energy conservation standards. The national
impacts analysis uses a spreadsheet set that provides shipments
forecasts and calculates national energy savings and net present value
resulting from potential energy conservation standards. DOE uses the
third spreadsheet tool, the Government Regulatory Impact Model (GRIM),
to assess manufacturer impacts of potential standards. These three
spreadsheet tools are available at the Web site for this rulemaking:
http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=85. Additionally, DOE used output from the EIA's
AEO 2015, a widely known energy forecast for the United States, for the
emissions and utility impact analyses.
A. Market and Technology Assessment
1. General
For the market and technology assessment, DOE develops information
that provides an overall picture of the market for the products
concerned, including the purpose of the products, the industry
structure, and market characteristics. This activity includes both
quantitative and qualitative assessments, based primarily on publicly
available information. Chapter 3 of the SNOPR TSD contains additional
discussion of the market and technology assessment.
2. Product Classes
When evaluating and establishing energy conservation standards, DOE
divides covered products into product classes by the type of energy
used or by capacity or other performance-related features that
justifies a different standard. In making a determination whether a
performance-related feature justifies a different standard, DOE must
consider such factors as the utility to the consumer of the feature and
other factors DOE determines are appropriate. (42 U.S.C. 6295(q))
a. Conventional Cooking Tops
During the previous energy conservation standards rulemaking for
cooking products, DOE evaluated product classes for conventional
cooking tops based on energy source (i.e., gas or electric). These
distinctions initially yielded two conventional cooking product
classes: (1) Gas cooking tops; and (2) electric cooking tops. For
electric cooking tops, DOE determined that the ease of cleaning smooth
elements provides enhanced consumer utility over coil elements. Because
smooth elements typically use more energy than coil elements, DOE
defined two separate product classes for electric cooking tops. DOE
defined the following product classes in the TSD for the April 2009
Final Rule (2009 TSD) \29\ for conventional cooking tops:
---------------------------------------------------------------------------
\29\ The technical support document from the previous
residential cooking products standards rulemaking is available at:
http://www.regulations.gov/#!documentDetail;D=EERE-2006-STD-0127-
0097.
---------------------------------------------------------------------------
Electric cooking tops--low or high wattage open (coil)
elements;
Electric cooking tops--smooth elements; and
Gas cooking tops--conventional burners.
Induction Heating
As part of the February 2014 RFI, DOE stated that it tentatively
planned to maintain the product classes for conventional cooking tops
from the previous standards rulemaking, as presented above. DOE also
stated that it planned to consider induction heating as a technology
option for electric smooth cooking tops rather than as a separate
product class. DOE noted that induction heating provides the same basic
function of cooking or heating food as heating by gas flame or electric
resistance, and that the installation options available to consumers
are also the same for both cooking products with induction and electric
resistance heating. DOE stated that it might consider whether separate
product classes are warranted for commercial-style gas cooking products
with higher burner input rates. 79 FR 8337, 8341-8342 (Feb. 12, 2014).
In response to the February 2014 RFI, Laclede Gas Company (Laclede)
claimed that the two product classes for electric cooking tops are
based solely on aesthetics, which is not a sufficient reason for
establishing separate product classes. (Laclede, No. 8 at p. 5) As
noted above, DOE determined that the ease of cleaning smooth elements
provides enhanced consumer utility over coil elements. Because smooth
elements typically use more energy than coil elements, DOE defined two
separate product classes for electric cooking tops. DOE maintains this
determination that electric smooth cooking tops provide enhanced
utility while using more energy than coil elements, and as a result,
proposes to consider separate product classes for this SNOPR.
Natural Resources Defense Council (NRDC) agreed with DOE that
induction heating should not be considered a separate product class,
and further recommended classifying all electric cooking tops in a
single product class. NRDC commented that DOE determined in the
previous standards rulemaking that smooth element cooking tops
warranted a separate product class because they consume more energy
than open coil element cooking tops and provide the consumer utility of
ease of cleaning. NRDC stated, however, that electric cooking tops
using induction technology are now available that provide both high
energy efficiency and ease of cleaning. NRDC believes that open coil
elements do not provide any additional benefit to consumers and
therefore may not necessitate a separate product class. (NRDC, No. 12
at p. 2) DOE recognizes that smooth cooking tops with induction
technology can achieve higher energy efficiency than electric coil
cooking tops while providing ease of cleaning, as suggested by NRDC.
However, DOE notes that the electric resistance heating technology more
commonly found in smooth element cooking tops are typically less
efficient than coil elements. As a result, DOE is not proposing to
establish a single product class for all electric cooking tops.
In response to the February 2014 RFI, AHAM and Whirlpool commented
that induction cooking tops should be considered a separate product
class and
[[Page 60801]]
not a technology option for electric smooth cooking tops, due to the
following claimed performance and consumer utility differences:
Induction cooking tops are easier to clean than smooth
cooking tops with electric resistance heating because there is less
likelihood of baked-on foods, which are difficult to clean. With
induction cooking tops, the pot alone is heated through electromagnetic
energy, while the spilled food on the cooking top receives only a small
amount of conduction heating from the pot;
Induction cooking tops heat faster than smooth cooking
tops with electric resistance heating. AHAM and Whirlpool stated that
there is a precedent to establishing separate product classes based on
cycle time. According to these commenters, in the clothes washer
rulemaking, DOE separated front-loading and top-loading clothes washers
because the cycle times varied, significantly impacting consumer
utility and product performance;
Standby energy use will typically be higher for induction
cooking tops than for smooth cooking tops because there are more
advanced electronics, especially for full surface induction cooking
tops that sense a pot when it is placed anywhere on the unit's surface.
To maintain that consumer utility, induction cooking tops need a higher
standby energy for the sensors to detect the placement of a pot;
Magnetic cookware is needed for induction cooking tops,
but not for smooth cooking tops with electric resistance heating. This
may affect cooking performance and energy use by the end user, as
certain non-magnetic cookware, such as aluminum, does not retain heat
well; and
Induction is an entirely different method of heating food
(electromagnetic energy) than smooth cooking tops with electric
resistance heating (radiant and conduction energy). (AHAM, No. 9 at pp.
4-5, 6, 7; Whirlpool, No. 13 at pp. 3, 4, 5)
NRDC and the California IOUs agreed with DOE that induction heating
should be considered as a technology option for electric smooth cooking
tops. (NRDC, No. 12 at p. 2; California IOUs, No. 11 at p. 2) NRDC
noted that many induction cooking top models from multiple brands and
manufacturers have entered the market, and that some manufacturers
offer induction ``hot plates,'' as well as hybrid ranges and cooking
tops that have electric and induction elements. NRDC also stated that
induction cooking tops hold a significant portion of the market in
Europe and Asia. For these reasons, NRDC urged DOE to consider
induction technology in its analysis. (NRDC, No. 12 at pp. 1-2) The
California IOUs urged DOE to review the Food Service Technology Center
reports available on induction technology for commercial cooking
products, which include measurements of energy input rate, heat-up
temperature response, and heavy-load energy efficiency under the
American Society for Testing and Materials (ASTM) Standard F1521-03.
According to the California IOUs, these reports would be helpful in
assessing the test procedures and measured energy efficiency of
induction cooking tops. (California IOUs, No. 11 at p. 2)
DOE observes that induction cooking tops provide the same basic
function of cooking or heating food as does electric resistance
heating. In addition, in considering whether there are any performance-
related features that justify a higher energy use standard to establish
a separate product class, DOE notes that the utility of speed of
cooking, ease of cleaning, and requirements for specific cookware for
induction cooking tops do not appear to be uniquely associated with
higher energy use compared to other smooth cooking tops with electric
resistance heating elements. DOE recognizes that induction cooking tops
are only compatible with ferromagnetic cooking vessels. However, DOE
does not identify any consumer utility unique to any specific type of
cookware that would warrant establishing separate product classes. As
discussed in section IV.F.2 of this SNOPR, DOE considered the cost of
replacing cookware as part of the LCC analysis. DOE also conducted
standby testing on full-surface induction cooking tops. Based on DOE's
testing, the sensors required to detect the presence of a pot placed on
the cooking surface do not remain active while the product is in
standby mode. In addition, DOE notes that the standby power required
for the tested model (0.25 watts (W)) was below the average standby
power for other cooking tops in DOE's test sample (2.25 W). For these
reasons, DOE is not considering a separate product class for induction
cooking products in this proposal. As noted in section IV.A.3 of this
SNOPR, DOE is considering induction heating as a technology option for
electric smooth cooking tops. Because residential induction cooking
tops are available on the market, DOE analyzed these products rather
than information from commercial products, as suggested by the
California IOUs, as part of the engineering analysis, including testing
and tearing down multiple sample units.
Commercial-Style Cooking Tops
With regard to commercial-style cooking products, including those
with higher burner input rates, AHAM commented in response to the
February 2014 RFI that without a definition or test procedure for
commercial-style cooking products, neither AHAM nor DOE can determine
whether these products would warrant a separate product class. AHAM
stated that DOE should first develop a test procedure for these
products to allow for analysis of them. (AHAM, No. 9 at p. 12)
Based on DOE's review of conventional gas cooking tops available on
the market, DOE determined that products marketed as commercial-style
cannot be distinguished from standard residential-style products based
on performance characteristics or consumer utility. While conventional
gas cooking tops marketed as commercial-style have more than one burner
rated above 14,000 Btu/h and cast iron grates, approximately 50 percent
of cooking top models marketed as residential-style also have one or
more burners rated above 14,000 Btu/h and cast iron grates.
DOE considered whether separate product classes for commercial-
style gas cooking tops with higher burner input rates are warranted by
comparing the test energy consumption of individual surface units in a
sample of cooking tops tested by DOE.\30\ DOE measured the test energy
consumption of gas surface units in a sample of twelve gas cooking
tops, which included six products marketed as commercial-style. The
number of surface units per cooking top ranged from four to six. Figure
IV.1 shows test energy consumption for an individual surface unit,
normalized by the mass of the test load (as specified in the proposed
cooking tops test procedure in the August 2016 TP SNOPR), versus burner
input rate for each surface unit in the test sample. Because the mass
of the test load depends on the input rate of the burner, the test
energy consumption must be normalized for comparison. The higher the
ratio of test energy consumption to
[[Page 60802]]
test load mass, the less efficient the surface unit.
---------------------------------------------------------------------------
\30\ DOE originally conducted testing on its test sample using
the withdrawn hybrid test block method proposed in the December 2014
TP SNOPR. DOE tested four of the twelve units in its test sample
using both the withdrawn hybrid test block method and the water
heating test method proposed in the August 2016 TP SNOPR. DOE then
used the relative difference in results between the two test methods
to scale the normalized test energy consumption by surface unit for
the remaining units in its test sample. Additional details of this
analysis are provided in chapter 5 of the NOPR TSD.
[GRAPHIC] [TIFF OMITTED] TP02SE16.000
As indicated in Figure IV.1, there was no statistically significant
correlation between burner input rate and the ratio of surface unit
energy consumption to test load mass for cooking tops marketed as
either residential-style or commercial-style. DOE's testing, as
presented further in section IV.C.2 of this SNOPR, showed that this
efficiency ratio for gas cooking tops is more closely related to burner
and grate design rather than input rate.
In response to the June 2015 NOPR, Sub-Zero and BSH submitted late
comments regarding commercial-style cooking tops. Sub-Zero commented
that ``high-performance cooking'' is a better descriptor of this
product segment than ``commercial-style.'' Sub-Zero stated that high-
performance cooking products can be defined as cooking products that
offer residential consumers performance similar to that found in
restaurant equipment at a safety and convenience level that is
acceptable for residential use. (Sub-Zero, No. 40 at p. 2)
Sub-Zero commented that a separate product class should be
established for high-performance gas cooking tops to recognize the
unique utility and performance attributes associated with high-
performance cooking products. Sub-Zero expressed concern that DOE may
not be adequately considering cooking performance in its analysis for
cooking tops, and that DOE may not be fully addressing any combustion
and emissions issues arising from potential design changes made to
improve the efficiency of gas cooking tops. (Sub-Zero, No. 40 at p. 2)
Sub-Zero and BSH stated that customer input drives the design and
cooking performance requirements for their gas cooking tops, and that
high-performance gas cooking tops include design features that enhance
cooking performance (rapid boiling, precision simmering, and even heat
distribution) but negatively impact efficiency. (Sub-Zero, No. 25 at
pp. 2-3; BSH, No. 41 at pp. 1-2) Sub-Zero and BSH noted that these
features include:
High input rate burners with large diameters provide
faster heat up times and allow consumers to use larger cooking vessels
while maintaining even heat distribution (Sub-Zero, No. 25 at p. 3;
BSH, No. 41 at p. 2);
High input rate burners with high levels of flame
controllability, specifically high turndown ratios, allow for simmering
of foods such as chocolates and sauces while also providing faster heat
up times (Sub-Zero, No. 25 at p. 3; BSH, No. 41 at p. 2);
Spacing between the gas flame, grate, and cooking vessel
must be greater for high input rate burners than low input rate burners
to meet performance and safety requirements, specifically even heat
distribution and reduction of carbon monoxide. Reducing the spacing
between the gas flame and the cooking vessel can increase efficiency,
but flame quenching due to flame impingement and contact with the
grate/cooking vessel can lead to increased carbon monoxide emissions
and combustion by-products (Sub-Zero, No. 25 at p. 3);
Heavy cast iron grates allow for better heat distribution
to cooking vessels while also providing the strength required to
support large loads and increased product longevity. (Sub-Zero, No. 25
at p. 4; BSH, No. 41 at p. 2) Heavier cast iron grates also retain
[[Page 60803]]
more heat once the burner is turned down during simmer or shut off.
(Sub-Zero, No. 25 at p. 2-4)
Sub-Zero and BSH commented that safety, performance, and efficiency
attributes of the cooking top must be considered systematically in
terms of product design (e.g., mass of the grates, diameter of the
burner, distance from the burner to the cooking vessel, and open area
allotted for exhaust of combustion by-products), because changes to one
attribute can significantly impact the others (Sub-Zero, No. 40 at p.
3; BSH, No. 41 at p. 2)
For these reasons, Sub-Zero requested that DOE consider the impact
that any proposed standard levels would have on small, niche-market,
high-performance cooking product manufacturers and their ability to
serve their unique set of customers. According to Sub-Zero, eliminating
the unique features of commercial-style gas cooking tops would not
allow companies such as Sub-Zero to adequately serve their customer
base. (Sub-Zero, No. 40 at p. 4)
BSH commented that although it agrees with DOE's general approach
of not analyzing cooking performance, commercial-style products must
meet greater customer demands than residential-style products. BSH also
commented that if DOE does not differentiate between commercial-style
and residential-style products, more stringent standards would apply
primarily to commercial-style products and have no effect on
residential-style products. BSH commented that this could result in the
elimination of commercial-style products from the market and limit
consumer choice. BSH commented, therefore, that DOE should consider
either a different test procedure or a separate product class for
commercial-style products. (BSH, No. 41 at p. 3)
The Wisconsin Senators expressed concern that recombining the
rulemaking to consider standards for both cooking tops and ovens would
likely impact high performance products and would require significant
design changes resulting in lessened consumer utility and product
performance. (Wisconsin Senators, No. 45 at p. 1) Arizona Congress
Member Grijalva and the Arizona Congressional Delegation similarly
noted that recombining the rulemaking will make it more difficult to
have separate product classes to account for the unique features of
high performance products. (Arizona Congress Member Grijalva, No. 43 at
p. 1; Arizona Congressional Delegation, No. 44 at pp. 1-2) The
Wisconsin Senators, Arizona Congress Member Grijalva, and the Arizona
Congressional Delegation noted that new standards could negatively
impact manufacturers like Sub-Zero and their ability to compete in the
marketplace if high performance cooking products are not distinguished
from conventional residential-style products. (Wisconsin Senators, No.
45 at p. 1; Arizona Congress Member Grijalva, No. 43 at p. 1)
DOE recognizes that the presence of certain features, such as heavy
cast iron grates and multiple high input rate burners, may help
consumers perceive a difference between commercial-style and
residential-style gas cooking top performance. However, DOE is not
aware of clearly-defined and consistent design differences and
corresponding utility provided by commercial-style gas cooking tops as
compared to residential-style gas cooking tops. Although DOE's testing,
presented in section IV.C.2, indicates there is a difference in energy
consumption between residential-style and commercial-style gas cooking
tops, this difference could not be correlated to any specific utility
provided to consumers. Moreover, DOE is not aware of an industry test
standard that evaluates cooking performance and that would quantify the
utility provided by these products. In addition, as discussed above,
DOE's testing showed that there was no statistically significant
correlation between burner input rate and the ratio of surface unit
energy consumption to test load mass for cooking tops marketed as
either residential-style or commercial-style.
For these reasons, DOE is not proposing to establish a separate
product class for gas cooking tops marketed as commercial-style or
conventional gas cooking tops with higher burner input rates. However,
as discussed in sections IV.C.3.b and V.C.1 of this SNOPR, DOE
conducted its engineering analysis consistent with products currently
available on the market and is proposing energy conservation standards
for gas cooking tops in this SNOPR that would maintain the features
available in conventional cooking tops marketed as commercial-style
(e.g., multiple high input rate burners, cast iron gates, etc.) that
may be used to differentiate these products in the marketplace. In
addition, the standards proposed in this SNOPR are based on burner and
grate system designs that are available on the market and thus would
not alter the safety of existing commercial-style gas cooking top in
terms of combustion products or emissions.
b. Conventional Ovens
During the first energy conservation standards rulemaking for
cooking products, DOE evaluated product classes for conventional ovens
based on energy source (i.e., gas or electric). These distinctions
initially yielded two conventional oven product classes: (1) Gas ovens;
and (2) electric ovens. DOE more recently determined that the type of
oven-cleaning system is a utility feature that affects performance. DOE
found that standard ovens and ovens using a catalytic continuous-
cleaning process use roughly the same amount of energy. On the other
hand, self-clean ovens use a pyrolytic process that provides enhanced
consumer utility with lower overall energy consumption as compared to
either standard or catalytically lined ovens. Therefore, DOE defined
the following product classes in the TSD for the April 2009 Final Rule
(2009 TSD) \31\ for conventional ovens:
---------------------------------------------------------------------------
\31\ The technical support document from the previous
residential cooking products standards rulemaking is available at:
http://www.regulations.gov/#!documentDetail;D=EERE-2006-STD-0127-
0097.
---------------------------------------------------------------------------
Electric ovens--standard oven with or without a catalytic
line;
Electric ovens--self-clean oven;
Gas ovens--standard oven with or without a catalytic line;
and
Gas ovens--self-clean oven.
As part of the February 2014 RFI, DOE stated that it tentatively
planned to maintain the product classes for conventional ovens from the
previous standards rulemaking, as presented above. DOE stated that it
might consider whether separate product classes are warranted for
commercial-style gas ovens with higher burner input rates. 79 FR 8337,
8341-8342 (Feb. 12, 2014).
Self-Cleaning Technology
Based on DOE's review of conventional gas ovens available on the
U.S. market, and based on manufacturer interviews and testing conducted
as part of the engineering analysis, DOE noted in the June 2015 NOPR
that the self-cleaning function of the self-clean oven may employ
methods other than a high-temperature pyrolytic cycle to perform the
cleaning action. 80 FR 33030, 33043. Specifically, DOE noted that it is
aware of a type of self-cleaning oven that uses a proprietary oven
coating and water to perform a self-clean cycle with a shorter duration
and at a significantly lower temperature setting. The self-cleaning
cycle for these ovens, unlike catalytically-lined standard ovens that
provide continuous cleaning during normal baking, still have a separate
self-
[[Page 60804]]
cleaning mode that is user-selectable and must be tested separately. In
the June 2015 NOPR, DOE clarified that a conventional self-clean
electric or gas oven is an oven that has a user-selectable mode
separate from the normal baking mode, not intended to heat or cook
food, which is dedicated to cleaning and removing cooking deposits from
the oven cavity walls. Id.
Whirlpool agreed that separate product classes are justified for
standard and self-clean ovens. (Whirlpool, No. 33 at p. 6) Whirlpool
also agreed with DOE that ovens that provide the same consumer utility
and benefits of self-clean via means other than a standard pyrolytic
process should be subject to the same standards as those that employ a
pyrolytic process because this framework promotes innovation in self-
clean performance and energy efficiency. (Whirlpool, No. 33 at p. 5) GE
commented that, while it supports the treatment of self-clean ovens as
a separate product class, including non-pyrolytic models in the
definition of self-clean would require unique provisions in the test
procedure for this technology. In particular, GE suggested that DOE
determine whether a usage factor of four times per year is appropriate
for both pyrolytic and non-pyrolytic self-clean technologies, since the
former is not as effective and requires additional cycles per year to
achieve the same performance. (GE, No. 32 at p. 3)
DOE is not aware of any differences in consumer behavior in terms
of the frequency of use of the self-clean function that would be
predicated on the type of self-cleaning technology rather than on
cleaning habits or cooking usage patterns that are not dependent on the
type of technology. Therefore, DOE is not proposing a different usage
factor for non-pyrolytic self-clean operation. However, DOE welcomes
data on the consumer usage patterns of pyrolytic versus non-pyrolytic
self-cleaning functions in conventional ovens.
Commercial-Style Ovens
With regards to gas oven burner input rates, DOE noted in the June
2015 NOPR that based on its review of the residential conventional gas
ovens available on the market, residential-style gas ovens typically
have an input rate of 16,000 to 18,000 Btu/h whereas residential gas
ovens marketed as commercial-style typically have burner input rates
ranging from 22,500 to 30,000 Btu/h.\32\ 80 FR 33030, 33043. Additional
review of both the residential-style and commercial-style gas oven
cavities indicated that there is significant overlap in oven cavity
volume between the two oven types. Standard residential-style gas oven
cavity volumes range from 2.5 to 5.6 cubic feet (ft \3\) and gas ovens
marketed as commercial-style have cavity volumes ranging from 3.0 to
6.0 ft \3\. Sixty percent of the commercial-style models surveyed had
cavity volumes between 4.0 and 5.0 ft \3\, while fifty percent of the
standard models had cavity volumes between 4.0 and 5.0 ft \3\. The
primary differentiating factor between the two oven types was burner
input rate, which is greater than 22,500 Btu/h for commercial-style gas
ovens. Id.
---------------------------------------------------------------------------
\32\ However, DOE noted that many gas ranges, while marketed as
commercial- or professional-style and having multiple surface units
with high input rates, did not have a gas oven with a burner input
rate above 22,500 Btu/h.
---------------------------------------------------------------------------
DOE conducted testing for the June 2015 NOPR using the version of
the test procedure later adopted in the July 2015 TP Final Rule to
determine whether commercial-style gas ovens with higher burner input
rates warrant establishing a separate product class.
DOE evaluated the cooking efficiency of eight conventional gas
ovens, including five ovens with burners rated at 18,000 Btu/h or less
and the remaining three with burner input rates ranging from 27,000
Btu/h to 30,000 Btu/h. 80 FR 33030, 33043. DOE's testing showed that
the measured cooking efficiencies for ovens with burner input rates
above 22,500 Btu/h were lower than for ovens with ratings below 22,500
Btu/h, even after normalizing cooking efficiency to a fixed cavity
volume. However, DOE also noted that the conventional gas ovens with
higher burner input rates in DOE's test sample were marketed as
commercial-style and had greater total thermal mass, including heavier
racks and thicker cavity walls, even after normalizing for cavity
volume. DOE's testing of a 30,000 Btu/h oven suggested that much of the
energy input to commercial-style ovens with higher burner input rates
goes to heating the added mass of the cavity, rather than the test
load, resulting in relatively lower measured efficiency when measured
according to the test procedure adopted in the July 2015 TP Final Rule.
80 FR 33030, 33043-33044. DOE also investigated the time it took each
oven in the test sample to heat the test load to a final test
temperature of 234[emsp14][deg]F above its initial temperature, as
specified in the DOE test procedure in Appendix I at the time of the
testing. DOE's testing showed that gas ovens with burner input rates
greater than 22,500 Btu/h do not heat the test load significantly
faster than the ovens with lower burner input rates, and two out of the
three units with the higher burner input rates took longer than the
average time to heat the test load. Therefore, DOE concluded in the
June 2015 NOPR that there is no unique utility associated with faster
cook times that is provided by gas ovens with burner input rates
greater than 22,500 Btu/h. 80 FR 33030, 33045.
Based on DOE's testing, reverse engineering, and additional
discussions with manufacturers, DOE posited in the June 2015 NOPR that
the major differentiation between conventional gas ovens with lower
burner input rates and those with higher input rates, including those
marketed as commercial-style, was design and construction related to
aesthetics rather than improved cooking performance. Further, DOE did
not identify any unique utility conferred by commercial-style gas
ovens. For the reasons discussed above, DOE did not propose to
establish a separate product class for commercial-style gas ovens with
higher burner input rates. 80 FR 33030, 33045.
The Joint Efficiency Advocates agreed with DOE's determination that
commercial-style gas ovens do not provide any unique utility. The Joint
Efficiency Advocates added that Consumer Reports similarly found in
their tests that ``higher Btu hasn't guaranteed faster heating.'' They
noted that Consumer Reports also found that ``pro-style ranges are big
on style, but aren't the best ranges'' and that ``even regular ranges
now have beefy knobs, rugged grates, and stainless trim for a lot less
money,'' observations which support DOE's decision not to establish a
separate product class for commercial-style gas ovens with higher
burner input rates. (Joint Efficiency Advocates, No. 31 at p. 2)
As noted for cooking tops, Sub-Zero commented that ``high
performance cooking'' is a better descriptor of this product segment
than ``commercial-style.'' Sub-Zero commented that a separate product
class should be established for high performance electric and gas ovens
to recognize the unique utility and performance attributes associated
with high performance cooking products. Sub-Zero expressed concern that
DOE did not consider cooking performance in its analysis for this
rulemaking. According to Sub-Zero, the ability of any oven to bake and
broil evenly, allow yeast products to rise consistently, and produce
consistent quality from rack to rack when several racks are being used
[[Page 60805]]
are key criteria for consumer acceptance. (Sub-Zero, No. 25 at p. 2)
Sub-Zero and BSH stated that inputs from their customers drive the
design and cooking performance requirements for their ovens. (Sub-Zero,
No. 25 at pp. 2, 3; BSH, No. 41 at pp. 1-2) Sub-Zero commented that
high performance ovens include the following design features that
enhance cooking performance (professional quality baking, broiling,
roasting, slow bake, proofing, and other functions) but negatively
impact efficiency:
Heavier gauge materials which extend product life and
enhance product quality, cooking functionality and durability;
Configurations that allow for up to six-rack baking
capability with full extension, heavy-gauge oven racks to support large
loads and provide enhanced safety and ergonomic benefit;
Full oven-height dual convection blowers to optimize
cooking air flow;
Hidden bake elements that enhance customer safety,
cleanability and heat distribution for better cooking performance;
Controls and software to maximize the long-term
reliability of oven cavity porcelain when employing a hidden bake
element; and
Cooling fans for the electronic printed circuit boards
that provide precise oven control and touch-screen user interface for
cooking modes and other features. (Sub-Zero, No. 25 at pp. 3, 5-6)
BSH also noted that commercial-style ovens include design features
identified by Sub-Zero, including: Robust, full-extension ball-bearing
oven racks to support heavy food loads; the ability to cook on three
racks simultaneously with high output heating elements for even heat
distribution; hidden bake elements. (BSH, No. 41 at p. 2) BSH also
noted the following additional design features associated with
commercial-style products:
Soft-close hinges to handle constant loading and unloading
of the oven to eliminate the noise of slamming doors;
A variety of modes and options not typically found in
residential-style products (e.g., rapid steam generator, additional
convection heating element, high power combination modes such as
convection broil and steam convection);
Powerful heating elements to maintain set temperatures
during sessions of loading and unloading food (e.g., caterers and
entertainers at large house parties); and
Very large usable baking space, e.g., two ovens in a 60-
inch range that operate independently to provide more versatility in
cooking with each cavity capable of cooking one to three racks of food.
In addition, commercial-style ovens can accommodate commercial baking
pans that are more than twice the size of standard residential baking
pans. (BSH, No. 41 at p. 2)
Sub-Zero commented that testing of their products shows that the
standard levels must be increased for ovens with enhanced high
performance and customer utility attributes. Its test data showed that
there are significant differences in efficiency levels when comparing
high performance oven designs to conventional oven designs. (Sub-Zero,
No. 25 at pp. 2-3)
For these reasons, Sub-Zero requested that DOE reconsider the
impact that the proposed standard levels will have on small, niche-
market, high-performance cooking manufacturers and their ability to
serve their unique set of customers. According to Sub-Zero, the
proposed standard levels would not allow companies such as Sub-Zero to
adequately serve their customer base. Sub-Zero added that the proposed
standards would force them and other high performance cooking product
manufacturers to compete in the conventional oven market space by
requiring them to employ lighter gauge materials, exposed heating
elements, lighter racks, simpler controls, and single versus dual
convection fan systems, which Sub-Zero claims would eliminate the
utility and performance features that market analysis shows is needed
for its company to stay viable. (Sub-Zero, No. 25 at p. 6)
An Arizona Senator, California Congress Member, and Tennessee
Congress Member separately commented that the proposed rule lacks any
sort of distinction among residential ovens based on the cooking
features they provide to the consumer, and may compromise the quality,
functionality, and features associated with high-performance ovens.
(Arizona Senator, No. 37 at p. 1; California Congress Member, No. 47 at
p. 1; Tennessee Congress Member, No. 46 at p. 1) The Arizona Senator,
the Arizona Congressional Delegation, California Congress Member, and
Tennessee Congress Member encouraged DOE to work with the affected
industry entities to reevaluate its proposal to prescribe a separate
set of standards for high-performance ovens that acknowledges the
unique characteristics of high-performance products and preserves
customer choice. (Arizona Senator, No. 37 at p. 1; Arizona
Congressional Delegation, No. 36 at p. 1; California Congress Member,
No. 47 at pp. 1-2; Tennessee Congress Member, No. 46 at p. 2) The
Arizona Congressional Delegation, California Congress Member, and
Tennessee Congress Member also commented that the proposed rule is
overly burdensome and would impose significant costs for companies in
the high-performance oven market, including Sub-Zero and BSH. (Arizona
Congressional Delegation, No. 36 at pp. 1; California Congress Member,
No. 47 at pp. 1; Tennessee Congress Member, No. 46 at p. 1) The Arizona
Congressional Delegation added that forcing a manufacturers like Sub-
Zero to abandon its distinct line of cooking products and to
manufacture mass-market products would lessen customer utility and the
performance of its ovens, and create a significant disparity in the
company's competitive landscape. (Arizona Congressional Delegation, No.
36 at p. 1)
As discussed previously for cooking tops, BSH commented that
although it agrees with DOE's general approach of not analyzing cooking
performance for ovens, commercial-style products have to fulfill higher
customer demands than residential-style products. BSH stated that if
DOE does not differentiate between commercial-style and residential-
style products, more stringent standards would apply mainly to
commercial-style products and have no effect on residential-style
products. BSH commented that this could result in the elimination of
commercial-style products from the market and limit consumer choice.
Based on this, BSH commented that DOE should either consider a
different test procedure or a separate product class for commercial-
style products. (BSH, No. 41 at p. 3)
Miele also submitted a late comment in response to the June 2015
NOPR regarding commercial-style ovens. Miele commented that DOE should
either consider establishing a separate product class and exempt
commercial-style ovens from standards or delay the rulemaking until
there is a finalized test procedure that adequately measures
commercial-style products energy use and accounts for the enhanced
cooking performance so that these products are not eliminated from the
market. Miele commented that the DOE test procedure does not adequately
reflect the energy use of commercial-style products because it does not
account for the effects of door openings and the energy required for
thermal recovery. Miele noted that the added mass of commercial-style
ovens provides the advantage of requiring less energy and time to
recover, which alters the quality of foods being cooked. (Miele, No. 42
at pp. 1-2)
To further address whether commercial-style ovens provide a
[[Page 60806]]
unique utility that would warrant establishing a separate product
class, DOE conducted additional interviews with manufacturers of
commercial-style cooking products and reviewed additional commercial-
style test data. While these data demonstrated a difference in energy
consumption between residential-style and commercial-style ovens when
measured according to the test procedure adopted in the July 2015 TP
Final Rule, this difference could not be correlated to any specific
utility provided to consumers. Moreover, DOE is not aware of an
industry test standard that evaluates cooking performance and that
would quantify the utility provided by these products. DOE also notes
that all conventional ovens, regardless of whether or not the product
is marketed as commercial-style, must meet the same safety standards
for the construction of the oven. American National Standards Institute
(ANSI) Z21.1 ``Household Cooking Gas Appliances'' (ANSI Z21.1), Section
1.21.1, requires that the oven structure, and specifically the baking
racks, have sufficient strength to sustain a load of up to 25 pounds
depending on the width of the rack. A similar standard (Underwriters
Laboratories (UL) 858 ``Household Electric Ranges'' (UL 858)) exists
for electric ovens.
Furthermore, DOE has observed many of the design features
identified by manufacturers as unique to commercial-style ovens and
that may impact the energy consumption, such as extension racks,
convection fans, cooling fans, and hidden bake elements, in
residential-style products. DOE recognizes that the presence of these
features, along with thicker oven cavity walls and higher burner input
rates, may help consumers perceive a difference between commercial-
style and residential-style ovens. However, DOE is not aware of a
clearly-defined and consistent design difference and corresponding
utility provided by commercial-style ovens as compared to residential-
style ovens.
For these reasons, DOE is not proposing to establish a separate
product class for commercial-style ovens. As discussed in sections
III.B and III.C of this SNOPR, DOE is proposing to repeal the oven test
procedure in the August 2016 TP SNOPR, noting that further
investigation would be required to develop test methods that
appropriately account for the effects of certain commercial-style oven
design features (e.g., heavier-gauge cavity construction, high input
rate burners, extension racks, etc.). However, as discussed in sections
III.B and V.C.1 of this SNOPR, the prescriptive control system design
requirements proposed in this SNOPR would apply to all conventional
oven product types and would maintain the features available in
conventional ovens marketed as commercial-style that may be used to
differentiate these products in the marketplace.
Installation Configuration
As discussed in section III.C of this SNOPR, in the October 2012 TP
Final Rule, DOE amended Appendix I to include methods for measuring
fan-only mode.\33\ Based on DOE's testing of freestanding, built-in,
and slide-in conventional gas and electric ovens, DOE observed that all
of the built-in and slide-in ovens tested consumed energy in fan-only
mode, whereas freestanding ovens did not. The energy consumption in
fan-only mode for built-in and slide-in ovens ranged from approximately
1.3 to 37.6 watt-hours (Wh) per cycle, which corresponds to 0.25 to 7.6
kWh/yr. Based on DOE's reverse engineering analyses discussed in
section IV.C of this SNOPR, DOE noted that built-in and slide-in
products incorporated an additional exhaust fan and vent assembly that
was not present in freestanding products. The additional energy
required to exhaust air from the oven cavity is necessary for slide-in
and built-in installation configurations to meet safety-related
temperature requirements because the oven is enclosed in cabinetry. For
these reasons, DOE proposed in the June 2015 NOPR to include separate
product classes for freestanding and built-in/slide-in ovens. 80 FR
33030, 33045.
---------------------------------------------------------------------------
\33\ Fan-only mode is an active mode that is not user-selectable
in which a fan circulates air internally or externally to the
cooking product for a finite period of time after the end of the
heating function.
---------------------------------------------------------------------------
AHAM, Whirlpool, and Electrolux supported DOE's proposal to
establish separate product classes for freestanding and built-in/slide-
in ovens. (AHAM, No. 29 at p. 8; Whirlpool, No. 33 at p. 6; Electrolux,
No. 27 at p. 4) In the absence of adverse comments, and for the reasons
discussed above, DOE is maintaining its proposal to establish separate
product classes for freestanding and built-in/slide-in ovens.
In summary, DOE proposes the product classes listed in Table IV.1
for this SNOPR.
Table IV.1--Proposed Product Classes for Conventional Cooking Products
----------------------------------------------------------------------------------------------------------------
Product class Product type Sub-category Installation type
----------------------------------------------------------------------------------------------------------------
1.................................... Electric cooking top... Open (coil) elements. .......................
2.................................... ....................... Smooth elements. .......................
3.................................... Gas cooking top........ Conventional burners. .......................
4.................................... Electric oven.......... Standard with or....... Freestanding.
5.................................... ....................... without a catalytic Built-in/Slide-in.
line.
6.................................... ....................... Self-clean............. Freestanding.
7.................................... ....................... ....................... Built-in/Slide-in.
8.................................... Gas oven............... Standard with or....... Freestanding.
9.................................... ....................... without a catalytic Built-in/Slide-in.
line.
10................................... ....................... Self-clean............. Freestanding.
11................................... ....................... ....................... Built-in/Slide-in.
----------------------------------------------------------------------------------------------------------------
3. Technology Options
As part of the market and technology assessment, DOE uses
information about existing and past technology options and prototype
designs to help identify technologies that manufacturers could use to
improve energy efficiency. Initially, these technologies encompass all
those that DOE believes are technologically feasible. Chapter 3 of the
NOPR TSD includes the detailed list and descriptions of all technology
options identified for this equipment.
a. Conventional Cooking Tops
In the February 2014 RFI, DOE stated that based on a preliminary
review of the cooking products market and information published in
recent trade publications, technical reports, and
[[Page 60807]]
manufacturer literature, the results of the technology screening
analysis performed during the previous standards rulemaking remain
largely relevant for this rulemaking. 79 FR 8337, 8341 (Feb. 12, 2014).
DOE stated in the February 2014 RFI that it planned to consider the
technology options presented in Table IV.2 for conventional cooking
tops. 79 FR 8337, 8342-8343.
Table IV.2--February 2014 RFI Technology Options for Conventional
Cooking Tops
------------------------------------------------------------------------
-------------------------------------------------------------------------
Open (coil) element electric cooking tops:
1. Electronic controls.
2. Improved contact conductance.
3. Insulation.
4. Reflective Surfaces.
Smooth element electric cooking tops:
5. Electronic controls.
6. Halogen elements.
7. Induction elements.
8. Low-standby-loss electronic controls.
Gas Cooking Tops:
9. Catalytic burners.
10. Insulation.
11. Radiant gas burners.
12. Reduced excess air at burner.
13. Reflective surfaces.
14. Sealed burners.
15. Thermostatically controlled burners.
------------------------------------------------------------------------
In response to the February 2014 RFI, DOE received a number of
comments regarding the technology options for conventional cooking
tops.
Whirlpool commented that there would not be efficiency gains from
insulation for electric coil and gas cooking tops. Whirlpool further
questioned where extra insulation would be placed on an electric coil
or gas cooking top and whether consumers would accept that in the
product's design. (Whirlpool, No. 13 at pp. 3, 4) Based on discussions
with multiple manufacturers, DOE agrees that it is unclear where
insulation could be placed in electric coil and gas cooking tops to
improve efficiency, nor were manufacturers able to provide data
demonstrating any measurable efficiency improvement association with
added insulation. As a result, DOE did not further analyze this
technology option for these proposed product classes.
Whirlpool commented that small energy savings are associated with
thermostatically controlled burners for gas cooking tops, and that
manufacturers would need to assess the possible quality impact from
subjecting the electronics to high temperatures. (Whirlpool, No. 13 at
p. 4) Whirlpool also commented that most electric coil element and
smooth element cooking tops on the market today have electronic
controls. (Whirlpool, No. 13 at p. 4) Based on DOE's review of products
on the market, DOE agrees that the majority of electric smooth cooking
tops on the market today have electronic controls. However, all of the
electric coil cooking tops reviewed by DOE were equipped with
electromechanical controls. Nonetheless, DOE determined that
thermostatically controlled burners and electronic controls, which
allow the burners or heating elements to automatically adjust in
response to cooking-state set points (e.g., cooking vessel
temperature), would not improve efficiency based on the current DOE
test procedure because the efficiency benefits of these design options
can only be realized under variable burner or heating element
conditions. As a result, DOE is not proposing to include these
technologies in its analyses.
AHAM and Whirlpool commented that halogen elements should not be
considered as a technology option for electric smooth cooking tops
because they may not heat enough to properly cook food. AHAM and
Whirlpool stated that they do not believe that these elements typically
are capable of achieving temperatures greater than about
350[emsp14][deg]F. (AHAM, No. 9 at p. 5; Whirlpool, No. 13 at p. 4) DOE
notes that this technology option would incorporate radiant heating
coils around the halogen element to provide supplemental heat around
the element's edge, producing a highly responsive element with an even
temperature distribution. Based on data presented in the 2009 TSD,
halogen elements may increase efficiency by approximately 1.5 percent.
As a result, DOE is retaining halogen elements as a technology option
for electric smooth cooking tops.
Whirlpool commented that there may be negligible savings from
improved contact conductance, as the coil element changes shape when
heating, making it difficult to keep the element completely flat
throughout the cooking cycle. According to Whirlpool, radiation also
acts like conduction at very short distances (i.e., the distance
between test load and surface of non-flat coil element). Additionally,
Whirlpool commented that the possible energy savings from improved
contact conductance would not be realized by consumers because many do
not have the completely flat cookware. (Whirlpool, No. 13 at pp. 4, 6)
DOE recognizes that only minimal energy savings may be possible due to
improved contact conductance. However, DOE understands that the thermal
contact resistance between two bodies results in a temperature drop and
that improving the flatness of this interface, by improving the overall
flatness of either surface, can improve the heat transfer between the
two bodies. According to the 2009 TSD, DOE determined that improved
contact conductance, by improving the flatness of the coil heating
element, could result in a relative efficiency increase of
approximately 3 percent.\34\ As a result, DOE retained the technology
option for the purposes of this SNOPR. DOE welcomes additional comment
on whether improved contact conductance should be considered as a
technology option, in particular information and data substantiating
the claims that radiation acts like conduction at very short distances
and the degree to which the heating element or cookware may deform and
impact the heat transfer between the two surfaces.
---------------------------------------------------------------------------
\34\ TSD: Energy Efficiency Program for Consumer Products and
Commercial and Industrial Equipment: Residential Dishwashers,
Dehumidifiers, and Cooking Products, and Commercial Clothes Washers.
March 2009. Washington, DC. Chapter 3, p. 3-54.
---------------------------------------------------------------------------
Whirlpool commented that small energy savings are possible with
low-standby-loss electronic controls for electric smooth cooking tops,
but they are not expected to be economically justified. (Whirlpool, No.
13 at p. 4) As part of DOE's testing and reverse engineering analyses,
DOE observed that a large percentage of cooking top models incorporate
SMPS, which result in lower standby power consumption compared to
products with conventional linear power supplies. Based on discussions
with manufacturers, DOE notes that multiple manufacturers are already
transitioning to SMPS for their full product offerings. DOE also
observed that one electric smooth cooking top in its test sample is
equipped with an automatic power-down function in addition to the SMPS
that powers down the controls to a lower-power state after a period of
user inactivity to reduce standby power. As a result, DOE maintained
low-standby-loss electronic controls as a technology option and
assessed the associated costs in the engineering analysis.
Whirlpool commented that about 99 percent of electric coil cooking
tops already have chrome drip bowls, which act as a reflective surface.
(Whirlpool, No. 13 at p. 4) Whirlpool commented that there are possible
savings associated with reflective surfaces for gas cooking tops, which
could be implemented by the use of stainless steel, but consumers would
not accept cooking products being available only in stainless steel.
(Whirlpool, No. 13 at p. 3) Based on DOE's review of products on the
market, DOE is unaware of any
[[Page 60808]]
electric coil cooking tops that do not have chrome drip bowls. As a
result, DOE believes this technology is associated with the baseline
design and did not consider reflective surfaces as a technology option
for further improving product efficiency for electric coil cooking
tops. DOE agrees with Whirlpool's assertion that there is a potential
for energy savings associated with reflective surfaces for gas cooking
tops. As a result, DOE retained this technology option for the SNOPR.
DOE considers issues related to consumer utility, such as the lack of
consumer acceptance of cooking top surfaces being available only in
stainless steel noted by Whirlpool, as part of the screening analysis.
Whirlpool commented that there could be savings from less waste
heat and increased burner efficiency from radiant gas burners, but it
would not be economically justifiable. (Whirlpool, No. 13 at p. 3) DOE
notes that the 2009 TSD indicated that prototype designs using radiant
gas burners showed improved efficiency for gas cooking tops. As a
result, DOE retained this as a technology option for further
consideration. Economic impacts are addressed in the engineering, LCC,
and PBP analyses.
DOE notes that sealed burners for conventional gas cooking tops
were considered a technology option in the 2009 TSD. However, as
discussed in section IV.C.2 of this SNOPR, DOE determined based on its
testing that neither sealed nor open burner types clearly performed
better or worse than the other. As a result, DOE is not considering
sealed burners as a technology option for conventional gas cooking tops
for this SNOPR.
DOE is proposing to consider an additional technology option for
conventional gas cooking tops based on product testing and reverse
engineering analyses conducted for this SNOPR. DOE testing, described
in in section IV.C.2 of this SNOPR and chapter 5 of the SNOPR TSD,
revealed that gas cooking top efficiency was correlated to burner
system design (e.g., grate weight, flame angle, distance from burner
ports to the cooking surface). For example, heavier grates result in
more input energy being absorbed by the grate instead of the pan.
Because design of burner system components are interdependent and must
also consider combustion efficiency to maintain approved levels of
carbon monoxide emissions, DOE included optimized gas cooking top
burner and grate designs for increasing efficiency consistent with
products available on the market.
Table IV.3 lists the proposed technology options for cooking tops
that DOE is considering for this SNOPR.
Table IV.3--Proposed Technology Options for Conventional Cooking Tops
------------------------------------------------------------------------
-------------------------------------------------------------------------
Open (coil) element electric cooking tops:
1. Improved contact conductance.
Smooth element electric cooking tops:
2. Halogen elements.
3. Induction elements.
4. Low-standby-loss electronic controls.
Gas Cooking Tops:
5. Radiant gas burners.
6. Reduced excess air at burner.
7. Reflective surfaces.
8. Optimized burner and grate design.
------------------------------------------------------------------------
b. Conventional Ovens
In the June 2015 NOPR, DOE proposed to consider the technology
options listed in Table IV.4. 80 FR 33030, 33046-33047.
Table IV.4--June 2015 NOPR Technology Options for Conventional Ovens
------------------------------------------------------------------------
-------------------------------------------------------------------------
1. Bi-radiant oven (electric only).
2. Electronic spark ignition (gas only).
3. Forced convection.
4. Halogen lamp oven (electric only).
5. Improved and added insulation (standard ovens only).
6. Improved door seals.
7. No oven-door window.
8. Oven separator (electric only).
9. Reduced conduction losses.
10. Reduced vent rate (electric standard ovens only).
11. Reflective surfaces.
12. Low-standby-loss electronic controls.
13. Optimized burner and cavity design.
------------------------------------------------------------------------
In the June 2015 NOPR, DOE stated that it was considering an
additional technology option for optimizing the burner and cavity
design for gas ovens based on product testing and reverse engineering
analyses. DOE's testing indicated that reducing the thermal mass of the
oven cavity can increase cooking efficiency. Because oven cavity and
burner design are interdependent, DOE proposed to consider optimized
burner and cavity design as a technology option for increasing
efficiency for gas ovens consistent with products available on the
market rather than the reduced thermal mass technology option
considered for the previous rulemaking. 80 FR 33030, 33047.
AHAM commented that the market already incentivizes manufacturers
to reduce the gauge of the metals they use to the extent practical, and
that products that just meet the proposed standard level are already
doing this t. AHAM stated that there is only so far a manufacturer can
reduce gauge and retain consumer utility, product functionality and
performance, and safety. (AHAM, No. 29 at p. 8) Electrolux similarly
disagreed with the DOE position that optimizing the oven cavity, by
reducing the gauge of steel (and thus thermal mass) used in
manufacturing the oven cavity, is a viable means for reducing energy
consumption. Electrolux stated that it has already reduced the thermal
mass of the oven cavity in its products and there is no more efficiency
that can be safely gained by reducing the gauge of steel any further.
(Electrolux, No. 27 at p. 4)
As part of DOE's reverse-engineering analyses, described in section
IV.C of this SNOPR and chapter 5 of the SNOPR TSD, DOE observed that
the commercial-style ovens in its test sample had wall thicknesses
approximately 1.5 times greater than those of residential-style ovens.
Additionally, DOE observed that these products had heavier rack
weights. DOE's testing showed that by optimizing the burner/cavity
design, IAEC could be reduced by approximately 22 percent, depending on
the oven cavity volume. DOE also notes that, as discussed in section
IV.A.2.b of this SNOPR, ANSI Z21.1 and UL 858 include requirements for
the oven structure and racks to be able to support loads with a certain
weight range, depending on the width of the rack. For these reasons,
DOE maintained the optimized burner/cavity design as a technology
option.
DOE's analysis revealed that conventional ovens at the baseline
efficiency level use a conventional linear power supply control design.
A linear power supply typically produces unregulated as well as
regulated power. The main characteristic of an unregulated power supply
is that its output may contain significant voltage ripple and that the
output voltage will usually vary with the current drawn. The voltages
produced by regulated power supplies are typically more stable,
exhibiting less ripple than the output from an unregulated power supply
and maintaining a relatively constant voltage within the specified
current limits of the device(s) regulating the power. The unregulated
portion of a linear power supply typically consists of a transformer
that steps alternating current (AC) line voltage down, a voltage
rectifier circuit for AC to direct current (DC) conversion, and a
capacitor to produce unregulated, direct current output. However, there
are many means of producing and implementing an
[[Page 60809]]
unregulated power supply such as transformerless capacitive and/or
resistive rectification circuits.
Within a linear power supply, the unregulated output serves as an
input into a single or multiple voltage-regulating devices. Such
regulating devices include Zener diodes, linear voltage regulators, or
similar components which produce a lower-potential, regulated power
output from a higher-potential direct current input. This approach
results in a rugged power supply which is reliable, but typically has
an efficiency of about 40 percent. As discussed in section IV.C.3.b of
this SNOPR, DOE's analysis showed that switching from a conventional
linear power supply to an SMPS reduces the standby mode energy
consumption for conventional ovens. An SMPS offer higher conversion
efficiencies of up to 75 percent in appliance applications for power
supply sizes similar to those of conventional ovens. An SMPS also
reduces the no-load standby losses.
AHRI commented that DOE's discussion of the electronic spark
ignition design option and the proposed standard levels in the June
2015 NOPR strongly suggest a practical effect of eliminating glo-bar
ignition systems. AHRI commented that the typical glo-bar ignition
systems currently used in gas ovens remain energized during the entire
time that the main burner is on. AHRI noted that this is directly
related to a key safety feature of these ignition systems--that the
electric current sufficient to open the gas valve cannot pass through
the igniter until the igniter has attained a temperature that will
ignite the gas at the burner. According to AHRI, DOE's analysis is
technically inaccurate and the major reduction in the electrical
consumption of the ignition systems is not due to replacing the glo-bar
with a spark igniter, but instead to changing the ignition system to an
``interrupted'' type of system. AHRI noted that the North American
safety standard for automatic gas ignition systems specifies that an
intermittent/interrupted ignition system is energized prior to the
admission of fuel to the main burner and is de-energized when the main
burner flame is established. AHRI stated that this is the proper
technical description of the technology option that was analyzed.
(AHRI, No. 34 at p. 1)
AHRI also commented that it understands that the proposed maximum
energy use standards for gas ovens in the June 2015 NOPR do not require
the use of an electronic spark ignition system, but that if this
understanding is not correct, then DOE would be proposing a
prescriptive design requirement within a rule that is intended to be a
performance standard. (AHRI, No. 34 at p. 2)
DOE acknowledges that by describing the gas ignition system
technology option analyzed in the June 2015 NOPR as electronic spark
ignition, DOE could potentially preclude certain ignition types from
consideration that may result in reduced energy consumption. As a
result, DOE conducted a review of ignition systems available on the
market as well as various industry definitions for automatic gas
ignition available in household gas appliances. DOE based its analysis
on existing industry terminology such as definitions available in ANSI
Z21.1 and ANSI Z21.20, ``Automatic Electrical Controls for Household
and Similar Use Part 2: Particular Requirements for Automatic Burner
Ignition Systems and Components.''
When a conventional gas oven cooking cycle is initiated, an
ignition system is energized before gas is allowed to flow to the main
burner to be lit. Ignition types observed on the market for
conventional gas ovens fall under four categories: (1) Continuous
(e.g., constant-burning or ``standing'' pilot) (2) intermittent
ignition (3) intermittent/interrupted ignition and (4) intermittent
pilot ignition. These ignition types are described in the following
paragraphs.
Continuous ignition systems are a type of ignition that, once
placed in operation, are intended to remain ignited or energized
continuously until manually interrupted. Thus, they would remain
energized throughout, and outside of, a cooking cycle. Constant burning
pilot igniters are considered continuous ignition systems. As noted in
section II.B.1 of this SNOPR, in the April 2009 Final Rule, DOE
prescribed the current energy conservation standards for conventional
cooking products to prohibit constant burning pilots for all gas
cooking products.
For intermittent ignition systems, the ignition source is ignited
or energized when the appliance controls call for heat. The ignition
source remains continuously ignited or energized during each period of
main burner operation and is extinguished or de-energized when each
main burner operating cycle is completed. DOE's analysis determined
that baseline conventional gas ovens are equipped with an intermittent
ignition system that uses a glo-bar igniter (also referred to as a hot
surface igniter). For these ignition systems, when the thermostat is
set to a specific temperature and the oven controls call for heat, line
voltage is applied to the igniter. As the glo-bar heats and increases
in temperature, the current draw decreases. A safety valve is installed
in series with the igniter such that the valve allows gas flow to the
main burner only when the current draw of the glo-bar falls below a
certain point, which corresponds to a temperature capable of igniting
the gas at the burner. Because the safety valve remains open only when
the glo-bar igniter is drawing the correct current, the igniter must
continually draw power to keep the burner ignited. Based on DOE's
testing, glo-bar ignition systems consume between 300 W and 450 W when
energized.
For intermittent/interrupted ignition systems, the ignition source
is ignited or energized each time the appliance controls call for heat.
However, the ignition source is extinguished or de-energized after the
main burner flame is ignited. DOE notes that some conventional ovens on
the market use a direct electronic spark ignition, which is a type of
intermittent/interrupted ignition system. When the direct electronic
spark igniter receives a signal from the controls (either by a rotary-
actuated control dial or from an electronic control system), the spark
electrode sparks to ignite the main burner directly. The spark igniter
is de-energized once ignition of the main burner is complete. DOE is
also aware of a ceramic glo-bar igniter designed to be used in an
intermittent/interrupted ignition system, which is energized when there
is a call for heat and de-energized once the main burner flame has been
ignited.
For intermittent pilot ignition systems, upon a call for the burner
to ignite, a spark module lights a pilot flame, which in turn ignites
the main burner. In the systems reviewed by DOE, DOE observed that when
the main burner shuts off, the pilot also shuts off. DOE welcomes
comment that would confirm the operation sequence of intermittent pilot
ignition systems used in conventional gas oven applications. DOE notes
that battery-power ignition systems would be considered an intermittent
pilot ignition system and already exist in conventional gas ovens
available on the market. DOE further notes that a similar electronic
spark ignition system that uses line power and that ignites a pilot
flame would also be considered an intermittent pilot ignition system.
As discussed in section IV.C.3.b of this SNOPR, DOE's testing
conducted for the June 2015 NOPR showed that intermittent pilot
ignition systems (i.e.. electronic spark ignition systems) reduce
energy consumption as compared to intermittent glo-bar
[[Page 60810]]
ignition systems. However, based on DOE's review of different ignition
systems, DOE has additionally determined that energy savings can be
achieved from switching from the baseline intermittent glo-bar ignition
system to either an intermittent/interrupted ignition or intermittent
pilot ignition. As a result, DOE is expanding the gas ignition system
technology option to account for both of these options.
As discussed in section I and section III.B of this SNOPR, DOE is
proposing to adopt a prescriptive standard for the control system of
conventional gas ovens to require the use an intermittent/interrupted
ignition or intermittent pilot ignition. As a result, DOE is proposing
to define intermittent/interrupted ignition and intermittent pilot
ignition in 10 CFR 430.2. DOE would define intermittent/interrupted
ignition to be an ignition source which is ignited or energized upon
initiation of each main burner operational cycle and which is
extinguished or no longer energized after the main burner is ignited.
DOE would define intermittent pilot ignition to be an ignition source
which, upon initiation of each main burner operational cycle, ignites a
pilot that remains lit continuously during the main burner operational
cycle and is extinguished when the main burner operational cycle is
completed. DOE seeks comment on the use of these terms as descriptors
for the ignition systems capable of reducing the energy consumption of
conventional gas ovens.
In the June 2015 NOPR, DOE proposed to consider reducing the vent
rate as a technology option for standard-clean electric ovens. 80 FR
33030, 33047. Electrolux stated that the technology option of providing
for a reduced vent rate is not practical and cannot be used to increase
the energy efficiency of conventional ovens because venting of the oven
cavity during the cooking operation is necessary for the optimum
cooking performance of the oven. (Electrolux, No. 27 at p. 5)
DOE recognizes that some electric standard ovens may already have a
reduced vent rate. However, this may not be the case for all electric
standard ovens on the market. For example, DOE's test sample included
standard and self-clean versions of the same basic model of electric
oven, and during the reverse engineering analysis described in section
IV.C.2 of this SNOPR, DOE observed that both units had the same design,
construction, and fan-only mode energy consumption, indicating that
their vent rate was identical. This indicates that a reduced vent rate
could be considered for the standard version of this model.
Additionally, in the previous rulemaking, manufacturers themselves
confirmed that vent rate could be reduced for electric standard ovens.
Thus, DOE continues to include this design option as part of its
analysis but requests comment on whether a reduced vent rate could be
used to increase the energy efficiency of conventional electric
standard ovens.
In the June 2015 NOPR, DOE proposed to consider improved insulation
as a technology option for standard-clean ovens. 80 FR 33030, 33047.
AHAM and Electrolux commented that DOE has not clearly defined high
density insulation. AHAM added that, as a result, they cannot comment
on the whether this technology is already in use in standard-clean
ovens. (AHAM, No. 29 at p. 8; Electrolux, No. 27 at pp. 4-5) As noted
in chapter 5 of the NOPR TSD, DOE considers the improved insulation
technology option to consist of switching from the low-density (~1.09
pounds (lb)/ft\3\) fiberglass insulation typically used in standard-
clean ovens, to a higher density (~1.90 lb/ft\3\) insulation, as
commonly incorporated in self-clean ovens to meet UL surface
temperature requirements during the high-temperature pyrolysis self-
clean cycle.
B. Screening Analysis
DOE uses the following four screening criteria to determine which
technology options are suitable for further consideration in an energy
conservation standards rulemaking:
1. Technological feasibility. Technologies that are not
incorporated in commercial products or in working prototypes will not
be considered further.
2. Practicability to manufacture, install, and service. If it is
determined that mass production and reliable installation and servicing
of a technology in commercial products could not be achieved on the
scale necessary to serve the relevant market at the time of the
compliance date of the standard, then that technology will not be
considered further.
3. Impacts on product utility or product availability. If it is
determined that a technology would have significant adverse impact on
the utility of the product to significant subgroups of consumers or
would result in the unavailability of any covered product type with
performance characteristics (including reliability), features, sizes,
capacities, and volumes that are substantially the same as products
generally available in the United States at the time, it will not be
considered further.
4. Adverse impacts on health or safety. If it is determined that a
technology would have significant adverse impacts on health or safety,
it will not be considered further.
10 CFR part 430, subpart C, appendix A, 4(a)(4) and 5(b).
In sum, if DOE determines that a technology, or a combination of
technologies, fails to meet one or more of the above four criteria, it
will be excluded from further consideration in the engineering
analysis. The reasons for eliminating any technology are discussed
below.
The subsequent sections include comments from interested parties
pertinent to the screening criteria, DOE's evaluation of each
technology option against the screening analysis criteria, and whether
DOE determined that a technology option should be excluded (``screened
out'') based on the screening criteria.
1. Screened-Out Technologies
a. Conventional Cooking Tops
For conventional cooking tops, DOE screened out radiant gas
burners, catalytic burners, reduced excess air at burner, and
reflective surfaces for the reasons that follow.
In the previous rulemaking, manufacturers concluded that infrared
jet-impingement radiant gas burners would not be able to comply with
the ANSI Standard Z21.1-2005, ``Household Cooking Gas Appliances.''
Field testing had shown that users were unable to turn down the burner
satisfactorily, which indicated a potential health and safety risk. 72
FR 64432, 64455 (Nov. 15, 2007). No more recent designs of radiant gas
burners for residential cooking tops have resolved this issue, and
therefore, due to potential impacts on consumer health and safety, DOE
screened out radiant gas burners from further analysis.
In response to the February 2014 RFI, Whirlpool commented that
catalytic burners are not applicable to today's market for gas cooking
tops. Whirlpool stated that these seem to be more applicable to
industrial furnaces than residential gas cooking top burners.
(Whirlpool, No. 13 at p. 3) In the absence of any commercialized
catalytic burners for residential gas cooking tops, DOE asserts that it
would not be practicable to manufacture, install and service this
technology on the scale necessary to serve the relevant market at the
time of the effective date of an amended standard. Also, because this
technology is in the research stage, it is
[[Page 60811]]
not possible to assess whether it will have any adverse impacts on
utility to consumers or product availability, or any adverse impacts on
consumers' health or safety. As a result, DOE screened out catalytic
burners from further analysis.
Whirlpool commented that reduced excess air at burner does not seem
to be applicable to residential gas cooking tops, as excess air is
needed for clean, safe, and complete combustion. (Whirlpool, No. 13 at
p. 3) Reduced excess air at the burner has not been definitively shown
to increase efficiency. In addition, DOE cannot assess adverse impacts
on consumers' utility, health, or safety or equipment availability for
this technology. Reducing excess air at the burner increases the
possibility of adverse conditions such as poor flame quality and
elevated carbon monoxide levels, which would suggest adverse impacts on
consumers' utility, health, and safety. For these reasons, DOE screened
out reduced excess air at the burner from further analysis.
Reflective surfaces for gas cooking tops utilize highly polished or
chromed drip pans underneath the burner. The primary mechanism for heat
transfer to the cooking vessel for gas cooking tops is convection. As a
result, the efficiency gains resulting from using reflective pans are
extremely small because gas flames and burners have minimal infrared
emissions. Based on data provided by manufacturers through AHAM, DOE
estimated in the 2009 TSD that an efficiency increase of only 0.1
percent was possible. Also, as reported in the 1996 TSD,\35\
manufacturers stated that any increase in efficiency due to a
reflective surface could easily be negated if the consumer fails to
regularly clean the surface or uses an abrasive pad to clean the
surface. As a result, DOE screened out this technology option from
further analysis.
---------------------------------------------------------------------------
\35\ Available online at http://www.regulations.gov/#!documentDetail;D=EERE-2006-STD-0070-0053.
---------------------------------------------------------------------------
b. Conventional Ovens
For conventional ovens, in the June 2015 NOPR, DOE screened out
added insulation, bi-radiant oven, halogen lamp oven, no oven door
window, and reflective surfaces. 80 FR 33030, 33047-33048.
DOE did not receive any comments opposing the technology options
screened out in the June 2015 NOPR. For the same reasons discussed in
the June 2015 NOPR, DOE is continuing to screen out added insulation,
bi-radiant oven, halogen lamp oven, no oven door window, and reflective
surfaces from further analysis.
Additionally, as discussed in section IV.A.3.b of this SNOPR, the
optimized burner and cavity design technology option would require
changes to commercial-style ovens that include reducing the thermal
mass of the oven cavity. DOE recognizes that an energy conservation
standard that requires this technology option may result in the
unavailability of a certain product type, i.e., commercial-style ovens
that include features (e.g., thicker oven cavity walls, high input rate
burners, extension racks, etc.) that are used to differentiate these
products from residential-style products. As a result, DOE has screened
out optimized burner and cavity design from further analysis.
2. Remaining Technologies
Based on the screening analysis, DOE considered the design options
listed in Table IV.5 for conventional cooking tops and Table IV.6 for
conventional ovens.
Table IV.5--Remaining Conventional Cooking Top Technology Options
------------------------------------------------------------------------
-------------------------------------------------------------------------
Open (coil) element electric cooking tops:
1. Improved contact conductance.
Smooth element electric cooking tops:
2. Halogen elements.
3. Induction elements.
4. Low-standby-loss electronic controls.
Gas Cooking Tops:
5. Optimized burner and grate design.
------------------------------------------------------------------------
Table IV.6--Remaining Conventional Oven Technology Options
------------------------------------------------------------------------
-------------------------------------------------------------------------
1. Intermittent/interrupted ignition or intermittent pilot ignition
system.
2. Forced convection.
3. Improved insulation.
4. Improved door seals (standard ovens only).
5. Oven separator (electric only).
6. Reduced conduction losses.
7. Reduced vent rate (electric standard ovens only).
8. Low-standby-loss electronic controls.
------------------------------------------------------------------------
C. Engineering Analysis
The engineering analysis estimates the cost-efficiency relationship
of products at different levels of increased energy efficiency. This
relationship serves as the basis for the cost-benefit calculations for
consumers, manufacturers, and the Nation. In determining the cost-
efficiency relationship, DOE estimates the increase in manufacturer
cost associated with increasing the efficiency of products from the
baseline up to the maximum technologically feasible (``max-tech'')
efficiency level for each product class.
1. Methodology
DOE typically structures the engineering analysis using one of
three approaches: (1) The design-option approach, which provides the
incremental costs of adding design options to a baseline model that
will improve its efficiency (i.e., lower its energy use); (2) the
efficiency-level approach, which provides the incremental costs of
moving to higher energy efficiency levels, without regard to the
particular design option(s) used to achieve such increases; and (3) the
reverse-engineering (or cost-assessment) approach, which provides
``bottom-up'' manufacturing cost assessments for achieving various
levels of increased efficiency, based on teardown analyses (or physical
teardowns) that provide detailed data on costs for parts and material,
labor, overhead, and equipment, tooling, conveyor, and space
investments for models that operate at particular efficiency levels.
To determine the cost-efficiency relationship, DOE structured its
engineering analysis for this SNOPR using a design-option approach,
supplemented by reverse engineering (physical teardowns and testing of
existing products in the market) to identify the incremental cost and
efficiency improvement associated with each design option or design
option combination. In addition, DOE considered cost-efficiency data
from the 2009 TSD. DOE also conducted interviews with manufacturers of
conventional cooking products to develop a deeper understanding of the
various combinations of design options used to increase product
efficiency, and their associated manufacturing costs.
2. Product Testing and Reverse Engineering
To develop the cost-efficiency relationships for the engineering
analysis, DOE conducted testing and reverse engineering teardowns on
products available on the market. Because there are no performance-
based energy conservation standards or energy reporting requirements
for conventional cooking products, DOE selected test units based on
performance-related features and technologies advertised in product
literature.
a. Conventional Cooking Tops
For conventional cooking tops, DOE's test sample included four gas
cooking tops, eight gas ranges, six electric cooking tops, and two
electric ranges for a total of 20 conventional cooking tops
[[Page 60812]]
covering all of the product classes considered in this SNOPR. The test
units are described in detail in chapter 5 of the SNOPR TSD.
DOE first conducted testing on each cooking top in its test sample.
DOE then conducted physical teardowns on each test unit to develop a
manufacturing cost model and to evaluate key design features. DOE
supplemented its reverse engineering analyses by conducting
manufacturer interviews to obtain feedback on efficiency levels, design
options, inputs for the manufacturing cost model, and resulting
manufacturing costs. DOE used the results from testing, reverse
engineering, and manufacturer interviews to develop the efficiency
levels and manufacturing costs discussed in section IV.C.3 and section
IV.C.4 of this SNOPR.
Table IV.7 and Table IV.8 present the testing results for the
conventional gas and electric cooking tops, respectively. Residential
conventional ranges include both a cooking top and oven but each
component is tested individually and falls into a separate product
class. Thus, DOE separated the range components for its analysis and
each of the units in the following tables represent a cooking top that
may be either a standalone unit or a component of a range.
Table IV.7--DOE Conventional Gas Cooking Top Test Results \36\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Grate weight
Cooking top product Burner input rating per burner
Test unit No. class Burner type (Btu) Grate material (pounds (lbs)) IAEC (kBtu/yr)
*
--------------------------------------------------------------------------------------------------------------------------------------------------------
1..................... Conventional Gas..... Open.................... 4 x 9,000............ Steel................... 0.5 655.2
2..................... Conventional Gas..... Open.................... 4 x 9,100............ Steel................... 1.1 760.5
3..................... Conventional Gas..... Open.................... 4 x 9,100............ Steel................... 1.1 834.3
4..................... Conventional Gas..... Sealed.................. 5,000; 9,500; 10,000; Cast Iron............... 2.2 960.4
15,000; 17,000.
5..................... Conventional Gas..... Sealed.................. 2 x 7,000; 2 x 8,000. Cast Iron............... 2.1 730.4
6..................... Conventional Gas..... Sealed.................. 4 x 18,000........... Cast Iron............... 6.1 1067.0
7..................... Conventional Gas..... Sealed.................. 5,000; 2 x 9,100; Cast Iron............... 4.2 1033.5
11,000; 20,000.
8..................... Conventional Gas..... Sealed.................. 4 x 18,000........... Cast Iron............... 4.8 928.6
9..................... Conventional Gas..... Sealed.................. 2 x 9,500; 2 x Cast Iron............... 5.4 924.4
15,000; 2 x 18,500.
10.................... Conventional Gas..... Open.................... 4 x 23,000........... Cast Iron............... 8.6 909.1
11.................... Conventional Gas..... Open.................... 12,000; 2 x 18,000; 3 Cast Iron............... 6.3 1104.8
x 25,000.
12.................... Conventional Gas..... Closed.................. 2 x 15,000; 9,500 Cast Iron............... 3.7 837.9
5,000.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* For cooking tops with continuous grates covering multiple surface unit burners, the total grate weight was divided by the number of burners.
Table IV.8--DOE Conventional Electric Cooking Top Test Results \37\
----------------------------------------------------------------------------------------------------------------
Test unit No. Cooking top product class Surface unit input rating * (W) IAEC (kWh/yr)
----------------------------------------------------------------------------------------------------------------
1........................... Smooth Element--Induction....... 1,900; 2,600; 3,200; 3,400...... 119.9
2........................... Smooth Element--Induction....... Max 3,600....................... 105.7
3........................... Smooth Element--Induction....... 1,800; 2 x 2,500; 3,700......... 121.0
4........................... Smooth Element--Electric 3 x 1,200; 2,000; 2,400; 3,000.. 139.1
Resistance.
5........................... Smooth Element--Electric 3 x 1,200; 1,500; 2,400; 2 x 125.9
Resistance. 3,000.
6........................... Open (Coil) Element............. 3 x 1,300; 1 x 2,100............ 111.4
7........................... Open (Coil) Element............. 2 x 1,300; 2 x 2,400............ 115.0
8........................... Open (Coil) Element............. 3 x 1,250; 2,100................ 124.1
----------------------------------------------------------------------------------------------------------------
* Includes wattages for surface units with multiple concentric heating elements for a single surface unit.
b. Conventional Ovens
As noted in the June 2015 NOPR, DOE's test sample for conventional
ovens included 1 gas wall oven, 7 gas ranges, 5 electric wall ovens,
and 2 electric ranges for a total of 15 conventional ovens covering all
of the considered product classes. DOE conducted testing according to
the test procedure adopted in the July 2015 TP Final Rule. 80 FR 33030,
33048-33049. As discussed in section III.B of this SNOPR, although DOE
has since proposed to repeal the conventional oven test procedure in
Appendix I, DOE based its analyses for this SNOPR on the data measured
using that test procedure. Table IV.9 and Table IV.10 present the
testing results for the conventional gas and electric ovens,
respectively. As with cooking tops, DOE used the results from testing,
reverse engineering, and manufacturer interviews to develop the
efficiency levels and manufacturing costs for conventional ovens
discussed in section IV.C.3 and section IV.C.4 of this SNOPR.
---------------------------------------------------------------------------
\36\ As discussed in section IV.A.2 of this SNOPR, DOE
originally conducted testing using the withdrawn hybrid test block
method proposed in the December 2014 TP SNOPR. DOE tested four of
the twelve units in its test sample using both the hybrid test block
method and the water heating test method proposed in the August 2016
TP SNOPR. DOE then used the relative difference in results between
the two test methods to scale the normalized total cooking top
energy consumption for the remaining units in its test sample.
\37\ DOE originally conducted testing using the withdrawn hybrid
test block method proposed in the December 2014 TP SNOPR. DOE tested
five of the eight electric units in its test sample using both the
hybrid test block method and the water heating test method proposed
in the August 2016 TP SNOPR. DOE then used the relative difference
in results between the two test methods to scale the normalized test
energy consumption by surface unit for the remaining units in its
test sample. Additional details of this analysis for electric
cooking tops are provided in chapter 5 of the SNOPR TSD.
[[Page 60813]]
Table IV.9--DOE Conventional Gas Oven Test Results
--------------------------------------------------------------------------------------------------------------------------------------------------------
Burner input Cavity volume Convection (Y/ IAEC * (kBtu/
Test unit No. Oven product class rate (Btu/h) (ft\3\) Ignition type N) yr)
--------------------------------------------------------------------------------------------------------------------------------------------------------
1........................... Gas Standard--Freestanding 18,000 4.8 Spark........................ N 1341.4
2........................... Gas Standard--Freestanding 18,000 4.8 Glo-bar...................... N 1489.1
3........................... Gas Self-Clean-- 18,000 5.0 Glo-bar...................... Y 1403.4
Freestanding.
4........................... Gas Standard--Freestanding 16,500 4.4 Glo-bar...................... N 1501.3
5........................... Gas Self-Clean--Built-in/ 13,000 2.8 Glo-bar...................... N 1159.9
Slide-in.
6........................... Gas Standard--Freestanding 28,000 5.3 Glo-bar...................... Y 2061.3
7........................... Gas Standard--Built-in/ 27,000 4.4 Glo-bar...................... Y 1922.9
Slide-in.
8........................... Gas Standard--Freestanding 30,000 5.4 Glo-bar...................... Y 2296.9
--------------------------------------------------------------------------------------------------------------------------------------------------------
* The IAEC values presented here differ slightly from those in the June 2015 NOPR due to a minor technical correction in the method used to calculate
the electrical energy contribution to IAEC for gas ovens in the test procedure adopted in the July 2015 TP Final Rule. Further information on this
correction is available in section IV.C.3.c and chapter 5 of the SNOPR TSD.
Table IV.10--DOE Conventional Electric Oven Test Results
----------------------------------------------------------------------------------------------------------------
Heating
Test unit No. Oven product class element Cavity volume Convection (Y/ IAEC (kWh/yr)
wattage (W) (ft\3\) N)
----------------------------------------------------------------------------------------------------------------
1...................... Electric Self-Clean-- 3,000 5.9\*\ Y 266.2
Freestanding.
2...................... Electric Standard-- 2,000 2.4 N 213.6
Freestanding.
3...................... Electric Self-Clean-- 3,400 2.7 N 158.7
Built-in/Slide-in.
4...................... Electric Standard-- 2,600 4.3 N 287.7
Built-in/Slide-in.
5...................... Electric Self-Clean-- 2,600 4.3 N 308.8
Built-in/Slide-in.
6...................... Electric Self-Clean-- 2,600 4.3 Y 341.8
Built-in/Slide-in.
7...................... Electric Self-Clean-- 2,800 4.3 N 370.0
Built-in/Slide-in.
----------------------------------------------------------------------------------------------------------------
* Test Unit 1 was equipped with an oven separator that allowed for splitting the single cavity into two separate
smaller cavities with volumes of 2.7 ft\3\ and 3.0 ft\3\.
3. Efficiency Levels
a. Baseline Efficiency Levels
A baseline unit is a product that just meets current Federal energy
conservation standards. DOE uses the baseline unit for comparison in
several phases of the SNOPR analyses, including the engineering
analysis, LCC analysis, PBP analysis, and NIA. To determine energy
savings that will result from an amended energy conservation standard,
DOE compares energy use at each of the higher energy efficiency levels
to the energy consumption of the baseline unit. Similarly, to determine
the changes in price to the consumer that will result from an amended
energy conservation standard, DOE compares the price of a unit at each
higher efficiency level to the price of a unit at the baseline.
Conventional Cooking Tops
As part of the February 2014 RFI, DOE initially developed baseline
efficiency levels by considering the current standards for conventional
gas cooking tops and the baseline efficiency levels for conventional
electric cooking tops from the previous standards rulemaking analysis.
DOE developed tentative baseline efficiency levels for the February
2014 RFI using the former test block-based test procedure and the
proposed test procedure amendments in the January 2013 TP NOPR that
included modifications to the test block to allow for the test of
induction cooking tops. The baseline efficiency levels proposed in the
February 2014 RFI are presented in Table IV.11. 79 FR 8337, 8343 (Feb.
12, 2014). DOE developed baseline efficiency levels for standby mode
and off mode based on test data presented in the microwave oven test
procedure SNOPR.\38\
---------------------------------------------------------------------------
\38\ In the May 2012 microwave oven test procedure SNOPR, DOE
considered test procedure amendments for measuring the standby mode
and off mode energy consumption of combined cooking products and, as
a result, presented standby power data for microwave ovens,
conventional cooking tops, and conventional ovens. 77 FR 28805,
28811 (May 16, 2012).
Table IV.11--February 2014 RFI Conventional Cooking Top Baseline Efficiency Levels
----------------------------------------------------------------------------------------------------------------
2009 standards rulemaking Proposed test
-------------------------------- procedure
Product class Cooking Energy factor cooking Proposed IAEC
efficiency (EF) efficiency
----------------------------------------------------------------------------------------------------------------
Electric Cooking Tops--Open (Coil) 0.737 0.737 0.674 256.7 kWh/yr.
Elements.
Electric Cooking Tops--Smooth 0.742 0.742 0.679 280.6 kWh/yr.
Elements.
Gas Cooking Tops................... 0.399 0.399 0.365 1445.0 kBtu/yr.
----------------------------------------------------------------------------------------------------------------
As discussed in III.C, DOE recently published the August 2016 TP
SNOPR proposing to amend the cooking tops test procedure in Appendix I
to be based on the water heating test method. DOE developed baseline
efficiency levels for this SNOPR considering both data from the
previous standards rulemaking and the energy use for the test units
based
[[Page 60814]]
on the water heating test procedure proposed in the August 2016 TP
SNOPR. DOE conducted testing for units in its test sample to measure
IAEC, which includes energy use in active mode and standby mode. DOE
also requested energy use data as part of the manufacturer interviews.
However, because manufacturers are not currently required to conduct
testing according to the DOE test procedure, very little energy use
information was available.
The baseline efficiency levels for this SNOPR differ from those
presented in the 2014 RFI for each product class. This is primarily due
to the difference between the withdrawn hybrid test block method and
the adopted water-heating test methods, and the differences in the
calculation of annual energy consumption. As outlined in section III.C
of this SNOPR, in the August 2016 TP SNOPR, DOE proposed to adjust its
calculation of annual energy consumption for cooking tops to account
for changes in consumer cooking frequency and differences between
actual field usage of the cooking top and the DOE test method. 81 FR
57374, 57387-57388. As a result, the IAEC for each cooking top included
in DOE's test sample, as calculated using the methods adopted in the
August 2016 TP SNOPR, is lower than the baseline IAEC values
established in the 2009 cooking products energy conservation standards
rulemaking as well as those presented in the 2014 RFI for each product
class. However, after scaling the baseline values from the 2014 RFI to
reflect the updated IAEC calculation method, the highest measured IAEC
in DOE's test sample for this SNOPR was higher than the baseline IAEC
observed during the 2009 rulemaking for each cooking top product class,
suggesting that the baseline energy consumption of cooking tops has
increased since 2009. Thus, to establish the new baseline IAEC for
cooking tops, DOE set the baseline IAEC equal to the maximum IAEC
measured in the test sample for each product class.
Because baseline electric coil cooking tops and gas cooking tops
have only electromechanical controls, the baseline IAEC for these
product classes is calculated based on zero standby mode and off mode
energy consumption. In contrast, baseline electric cooking tops with
smooth elements have electronic controls which consume energy in
standby and off mode. To determine the baseline IAEC for smooth element
electric cooking tops, DOE set baseline standby energy consumption
equal to that of the cooking top with the highest standby energy
consumption in its test sample to maintain the full functionality of
controls for consumer utility.
The proposed baseline efficiency levels for conventional cooking
tops for this SNOPR are presented in Table IV.12. Additional details on
the development of the proposed baseline efficiency levels for
conventional cooking tops are included in chapter 5 of the SNOPR TSD.
The baseline efficiency levels were based on testing of DOE's sample of
products, as presented in section IV.C.2. DOE recognizes that
manufacturers implement different heating element or burner designs and
welcomes additional data regarding the proposed baseline efficiency
levels.
Table IV.12--Conventional Cooking Top Baseline Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Product class Proposed IAEC
----------------------------------------------------------------------------------------------------------------
Electric Cooking Tops--Open (Coil) Elements................ 118.1 kWh/yr.
Electric Cooking Tops--Smooth Elements..................... 144.7 kWh/yr.
Gas Cooking Tops........................................... 1104.8 kBtu/yr.
----------------------------------------------------------------------------------------------------------------
Conventional Ovens
For the June 2015 NOPR, DOE developed baseline efficiency levels
for conventional ovens considering both data from the previous
standards rulemaking and the measured energy use for the test units.
DOE conducted testing for all units in its test sample to measure IAEC,
which includes energy use in active mode (including fan-only mode) and
standby mode. DOE also requested energy use data as part of the
manufacturer interviews. However, because manufacturers are not
currently required to conduct testing according to the DOE test
procedure, DOE noted that very little energy use information was
available. 80 FR 33030, 33050.
To establish the baseline efficiency levels for conventional ovens,
first DOE derived a relationship between IAEC and cavity volume as
discussed in section IV.C.3.c of this SNOPR. Using the slope from the
previous rulemaking, DOE selected new intercepts corresponding to the
ovens in its test sample with the lowest efficiency, so that no ovens
in the test sample were cut off by the baseline curve. DOE then set
baseline standby energy consumption for conventional ovens equal to
that of the oven (including the oven component of a range) with the
highest standby energy consumption in DOE's test sample to maintain the
full functionality of controls for consumer utility. While only DOE
test data was available to validate the baseline equation for gas
ovens, DOE compared the new baseline equation for electric ovens with
data available in the Natural Resources Canada (NRCan) databases, which
showed that DOE's assumptions for slopes and intercepts reasonably
represented the market. Id.
DOE developed separate baseline efficiency levels for each proposed
product class based on testing conducted for the June 2015 NOPR. The
proposed baseline efficiency levels for the NOPR are presented in Table
IV.13 and are based on an oven with a cavity volume of 4.3 ft\3\. Id.
Table IV.13--June 2015 NOPR Conventional Oven Baseline Efficiency Levels
------------------------------------------------------------------------
Product class Sub type Proposed IAEC *
------------------------------------------------------------------------
Electric Oven--Standard Oven Freestanding..... 294.5 kWh.
with or without a Catalytic Built-in/Slide-in 301.5 kWh.
Line.
Electric Oven--Self-Clean Oven Freestanding..... 355.0 kWh.
Built-in/Slide-in 361.1 kWh.
Gas Oven--Standard Oven with Freestanding..... 2118.2 kBtu.
or without a Catalytic Line. Built-in/Slide-in 2128.1 kBtu.
[[Page 60815]]
Gas Oven--Self-Clean Oven..... Freestanding..... 1883.8 kBtu.
Built-in/Slide-in 1893.7 kBtu.
------------------------------------------------------------------------
* Proposed IAEC baseline efficiency levels are normalized based on a 4.3
ft\3\ volume oven.
As noted in section III.H of this SNOPR, AHAM, Whirlpool, and
Electrolux expressed concern that DOE has based its analysis on an
insufficient sample size of models, in particular for the electric
standard oven baseline efficiency levels. (AHAM, No. 29 at p. 5; AHAM,
No. 38 at pp. 2-3; Whirlpool, No. 33 at p. 5; Electrolux, No. 27 at pp.
3-4)
To address concerns regarding the limited data used to establish
the baseline efficiency levels for the electric standard oven product
classes, DOE augmented its analysis of electric standard ovens by
considering the energy use of the electric self-clean units in its test
sample, adjusted to account for the differences between standard-clean
and self-clean ovens. For these electric self-clean ovens, DOE first
subtracted the annual self-cleaning energy consumption and adjusted the
cycles per year \39\ to recalculate IAEC. DOE also adjusted the IAEC
for each electric self-clean oven model to account for the design
differences between self-clean ovens and standard clean ovens, noting
that baseline self-clean ovens are typically designed with the improved
insulation and improved door seals design options that were not
considered to be part of the baseline efficiency level for standard
clean ovens. Additional details regarding this analysis are presented
in chapter 5 of the SNOPR TSD. The resulting expanded dataset is shown
in Figure IV.2.
---------------------------------------------------------------------------
\39\ In the current DOE test procedure for conventional ovens in
Appendix I, the cycles per year used to calculate IAEC is 219 for
electric standard ovens and 204 for electric self-clean ovens.
[GRAPHIC] [TIFF OMITTED] TP02SE16.001
Augmenting the electric standard oven dataset with self-clean
models from the DOE test sample allowed DOE to consider a wider range
of cavity volumes in its analysis. Based on this analysis, DOE adjusted
the baseline IAEC versus cavity volume relationship for electric
standard ovens so that no models in DOE's dataset, including those in
the augmented sample, were cut off by the baseline curve.
The proposed baseline efficiency levels for this SNOPR are
presented in Table IV.14 and are based on an oven with a cavity volume
of 4.3 ft\3\.
Table IV.14--Conventional Oven Baseline Efficiency Levels
------------------------------------------------------------------------
Proposed IAEC
Product class Sub type *[dagger]
------------------------------------------------------------------------
Electric Oven--Standard Oven Freestanding........ 315.2 kWh.
with or without a Catalytic Built-in/Slide-in... 322.3 kWh.
Line.
[[Page 60816]]
Electric Oven--Self-Clean Freestanding........ 354.9 kWh.
Oven. Built-in/Slide-in... 362.0 kWh.
Gas Oven--Standard Oven with Freestanding........ 2083.1 kBtu.
or without a Catalytic Line. Built-in/Slide-in... 2093.0 kBtu.
Gas Oven--Self-Clean Oven... Freestanding........ 1959.6 kBtu.
Built-in/Slide-in... 1969.6 kBtu.
------------------------------------------------------------------------
* Proposed IAEC baseline efficiency levels are normalized based on a 4.3
ft\3\ volume oven.
[dagger] The baseline IAEC values presented here differ slightly from
those in the June 2015 NOPR due to a minor technical correction in the
method used to calculate the electrical energy contribution to IAEC
for gas ovens in the test procedure adopted in the July 2015 TP Final
Rule. Further information on this correction is available in section
IV.C.3.c and chapter 5 of the SNOPR TSD.
b. Incremental Efficiency Levels
For each product class for both conventional cooking tops and
conventional ovens, DOE analyzes several efficiency levels and
determines the incremental cost at each of these levels.
Conventional Cooking Tops
For the February 2014 RFI, DOE tentatively proposed the incremental
efficiency levels for conventional cooking tops presented in Table
IV.15 through Table IV.17. DOE developed these levels based primarily
on the efficiency levels presented in the 2009 TSD, adjusted using the
former test block-based test procedure and the proposed test procedure
amendments in the January 2013 TP NOPR that included modifications to
the test block to allow for the test of induction cooking tops. DOE
also considered separate efficiency levels associated with reducing
standby mode and off mode energy use by first changing conventional
linear power supplies to SMPS and then by meeting the 1 W maximum
standby power limit set forth in the Commission of the European
Communities Regulation 1275/2008 (hereinafter ``Ecodesign
regulation''). 79 FR 8337, 8345-8346 (Feb. 12, 2014).
Table IV.15--February 2014 RFI Open (Coil) Element Electric Cooking Top
Efficiency Levels
------------------------------------------------------------------------
Proposed IAEC
Level Efficiency level source (kWh/yr)
------------------------------------------------------------------------
Baseline................. 2009 TSD (Baseline).......... 256.7
1........................ 2009 TSD (Improved Contact 246.0
Conductance).
------------------------------------------------------------------------
Table IV.16--February 2014 RFI Smooth Element Electric Cooking Top
Efficiency Levels
------------------------------------------------------------------------
Proposed IAEC
Level Efficiency level source (kWh/yr)
------------------------------------------------------------------------
Baseline................. 2009 TSD (Baseline).......... 280.6
1........................ Baseline + Switch-Mode Power 268.6
Supply (SMPS).
2........................ Baseline + 1 W Standby....... 263.5
3........................ 2009 TSD (Halogen Lamp 259.8
Element) + 1 W Standby.
4........................ Induction + SMPS............. 245.9
5........................ Induction + 1 W Standby...... 240.7
------------------------------------------------------------------------
Table IV.17--February 2014 RFI Gas Cooking Top Efficiency Levels
------------------------------------------------------------------------
Proposed IAEC
Level Efficiency level source (kBtu/yr)
------------------------------------------------------------------------
Baseline................. 2009 TSD (Electronic 1445.0
Ignition).
1........................ 2009 TSD Max-Tech (Sealed 1372.7
Burners).
------------------------------------------------------------------------
In response to the February 2014 RFI, AHAM disagreed with DOE's
consideration of the 1-W Ecodesign regulation standby power requirement
because products sold in the European Union are different from the
products sold in the United States. (AHAM, No. 9 at p. 6) As discussed
below, DOE reevaluated the efficiency levels associated with standby
power improvements based on product testing and reverse engineering. As
a result, DOE is no longer considering an efficiency level specifically
associated with the 1-W Ecodesign regulation standby power requirement.
Laclede commented that induction cooking tops save a significant
amount of energy and meet the criteria of technologically feasible and
economically justified based upon their widespread commercial
availability. Consequently, Laclede urged DOE to use electric induction
cooking top efficiencies to set the minimum efficiencies of electric
cooking tops. (Laclede, No. 8 at pp. 4, 5) DOE included an efficiency
level associated with this technology based on product testing. As
discussed in section II.A of
[[Page 60817]]
this SNOPR, DOE follows specific statutory criteria prescribed by EPCA
for determining whether proposed energy conservation standards are
technologically feasible and economically justified. (42 U.S.C.
6295(o)(2)(B)(i)(I)-(VII)) DOE considered these criteria when
evaluating each proposed efficiency level, including the level
associated with induction heating.
Whirlpool commented that sealed burners already comprise a majority
of the market (<90 percent), so this technology is not appropriate as a
max-tech level for gas cooking tops. Whirlpool commented that it is
unaware of any technologies or efficiency levels for max-tech for gas
cooking tops. (Whirlpool, No. 13 at p. 6) Based on DOE's testing of
both sealed and open burners, presented in section IV.C.2 of this
SNOPR, DOE noted that neither burner type clearly performed better or
worse than the other. As a result, DOE did not consider an efficiency
level associated with sealed burners for conventional gas cooking tops.
For this SNOPR, DOE developed incremental efficiency levels for
each cooking top product class by first considering information from
the 2009 TSD. In cases where DOE identified design options during
testing and reverse engineering teardowns, DOE updated the efficiency
levels based on the tested data. In addition to the efficiency levels
associated with design options identified in the February 2014 RFI, DOE
identified an additional efficiency level for smooth element electric
cooking tops associated with low-standby-loss controls for an automatic
power-down function that shuts off certain power-consuming components
after a specified period of user inactivity that was observed during
testing and teardowns.
DOE also considered additional efficiency levels associated with
optimized burner and grate design for conventional gas cooking tops.
DOE's testing, as presented in sections IV.A.2 and IV.C.2 of this
SNOPR, showed that energy use was correlated to burner design (e.g.,
grate weight, flame angle, distance from burner ports to the cooking
surface) and could be reduced by optimizing the design of the burner
and grate system. DOE reviewed the test data for the conventional gas
cooking tops in its test sample and identified three efficiency levels
associated with improving the burner and grate design.
Although, as discussed in section IV.A.2 of this SNOPR, DOE's
testing showed that there was no statistically significant correlation
between burner input rate and cooking energy consumption of the cooking
top, DOE notes that cooking tops that incorporate different
combinations of burners, including high input rate burners for larger
food loads, have differing capabilities to cook or heat different sized
food loads. As a result, DOE is proposing multiple efficiency levels
that take into account key burner configurations. DOE is proposing
Efficiency Level 1 based on an optimized burner and improved grate
design of the unit in the test sample with the lowest measured IAEC
among those with cast iron grates and a six surface unit configuration
with at least four out of the six surface units having burner input
rates exceeding 14,000 Btu/h. DOE selected these criteria to maintain
the full functionality of cooking tops marketed as commercial-style.
DOE notes that while there are some such products with fewer than six
surface units and fewer than four high burner input rate burners, DOE
did not observe any products marketed as residential-style with the
burner configuration DOE is associating with Efficiency Level 1.
DOE is proposing Efficiency Level 2 for conventional gas cooking
tops based on an optimized burner and further improved grate design of
the unit in the DOE test sample with the lowest measured IAEC among
those units with cast iron grates and at least one surface unit having
a burner input rate exceeding 14,000 Btu/h. None of the gas units in
the DOE test sample marketed as commercial-style were capable of
achieving this efficiency level. The cooking tops in the DOE test
sample capable of meeting this efficiency level were marketed as
residential-style and had significantly lighter cast-iron grates than
the commercial-style units.
DOE established Efficiency Level 3 (max-tech) based on the unit in
the DOE test sample with the lowest measured IAEC among those with cast
iron grates, regardless of the number of burners or burner input rate.
DOE notes that the grate weight for this unit was not lowest in the DOE
test sample, confirming that a fully optimized burner and grate design,
and not a reduction in grate weight alone, is required to improve
cooking top efficiency.
Table IV.18 through Table IV.20 show the incremental efficiency
levels for each cooking top product class, including whether the
efficiency level is from the 2009 TSD or based on testing for the
SNOPR. Details of the derivations of each efficiency level are provided
in chapter 5 of the SNOPR TSD. The efficiency levels were based, in
part, on testing of DOE's sample of products, as presented in section
IV.C.2 of this SNOPR. DOE recognizes that manufacturers implement
different heating element or burner designs and welcomes additional
test data regarding the proposed efficiency levels.
Table IV.18--Open (Coil) Element Electric Cooking Top Efficiency Levels
--------------------------------------------------------------------------------------------------------------------------------------------------------
Relative %
Level Efficiency level source Design option Proposed IAEC decrease in
(kWh/yr) IAEC
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline........... SNOPR Testing............................................................. Baseline............... 118.1 ..............
1.................. 2009 TSD.................................................................. Baseline + Improved 113.2 -4.2
Contact Conductance.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table IV.19--Smooth Element Electric Cooking Top Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Relative %
Level Efficiency level source Design option Proposed IAEC decrease in
(kWh/yr) IAEC
----------------------------------------------------------------------------------------------------------------
Baseline................. SNOPR Testing.......... Baseline.................... 144.7 ..............
1........................ SNOPR Testing.......... Baseline + SMPS............. 137.0 -5.3
2........................ SNOPR Testing.......... 1 + Automatic Power Down.... 121.2 -11.5
3........................ 2009 TSD............... 2 + Halogen Lamp Element.... 119.5 -1.4
4........................ SNOPR Testing.......... 2 + Induction Heating 102.3 -14.4
Element.
----------------------------------------------------------------------------------------------------------------
[[Page 60818]]
Table IV.20--Gas Cooking Top Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Relative %
Level Efficiency level source Design option Proposed IAEC decrease in
(kBtu/yr) IAEC
----------------------------------------------------------------------------------------------------------------
Baseline................. SNOPR Testing.......... Baseline.................... 1104.6 ..............
1........................ SNOPR Testing.......... Baseline + Optimized Burner/ 924.4 -16.3
Improved Grates (Achievable
with a 6 surface unit
configuration with 4 or
more high input rate
burners and cast iron
grates).
2........................ SNOPR Testing.......... Baseline + Optimized Burner/ 837.8 -9.4
Optimized Grates
(Achievable with at least
one high input rate burners
and cast iron grates).
3........................ SNOPR Testing.......... Baseline + Optimized Burner/ 730.2 -12.8
Optimized Grates (Highest
efficiency unit with cast
iron grates).
----------------------------------------------------------------------------------------------------------------
Conventional Ovens
For the June 2015 NOPR, DOE developed incremental efficiency levels
for each conventional oven product class by first considering
information from the 2009 TSD. In cases where DOE identified design
options during testing and reverse engineering teardowns, DOE updated
the efficiency levels based on the tested data. In addition to the
efficiency levels associated with design options identified in the 2009
TSD, DOE also included an efficiency level for electric ovens based on
a test unit equipped with an oven separator that allowed for reducing
the cavity volume that is used for cooking. For conventional gas ovens,
DOE's testing showed that energy use was correlated to oven burner and
cavity design (e.g., thermal mass of the cavity and racks) and can be
significantly reduced when optimized. DOE determined the efficiency
level associated with optimized burner and cavity design based on the
tested units normalized for cavity volume. 80 FR 33030, 33051-33052.
Table IV.21 through Table IV.24 show the incremental efficiency
levels presented in the June 2015 for each conventional oven product
class, including whether the efficiency level is from the 2009 TSD or
based on testing for the NOPR. The efficiency levels are normalized
based on an oven with a cavity volume of 4.3 ft\3\. Id.
Table IV.21--June 2015 NOPR Electric Standard Oven Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Proposed IAEC (kWh)
-------------------------------
Level Efficiency level source Design option Built-in/slide-
Freestanding in
----------------------------------------------------------------------------------------------------------------
Baseline................. NOPR Testing........... Baseline.................... 294.5 301.5
1........................ NOPR Testing........... Baseline + SMPS............. 284.6 291.4
2........................ 2009 TSD............... 1 + Reduced Vent Rate....... 271.7 278.2
3........................ 2009 TSD............... 2 + Improved Insulation..... 259.2 265.4
4........................ 2009 TSD............... 3 + Improved Door Seals..... 254.9 261.0
5........................ NOPR Testing........... 4 + Forced Convection....... 244.6 250.5
6........................ NOPR Testing........... 5 + Oven Separator.......... 207.8 212.8
7........................ 2009 TSD............... 6 + Reduced Conduction 207.3 212.2
Losses.
----------------------------------------------------------------------------------------------------------------
Table IV.22--June 2015 NOPR Electric Self-Clean Oven Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Proposed IAEC (kWh)
-------------------------------
Level Efficiency level source Design option Built-in/slide-
Freestanding in
----------------------------------------------------------------------------------------------------------------
Baseline................. NOPR Testing........... Baseline.................... 355.0 361.1
1........................ NOPR Testing........... Baseline + SMPS............. 345.1 351.0
2........................ NOPR Testing........... 1 + Forced Convection....... 327.2 332.7
3........................ NOPR Testing........... 2 + Oven Separator.......... 278.9 283.7
4........................ 2009 TSD............... 3 + Reduced Conduction 278.1 282.9
Losses.
----------------------------------------------------------------------------------------------------------------
Table IV.23--June 2015 NOPR Gas Standard Oven Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Proposed IAEC (kBtu)
-------------------------------
Level Efficiency level source Design option Built-in/slide-
Freestanding in
----------------------------------------------------------------------------------------------------------------
Baseline.................. 2009 TSD................. Baseline................. 2118.2 2128.1
1......................... NOPR Testing............. Baseline + Optimized 1649.3 1657.0
Burner/Cavity.
2......................... NOPR Testing............. 1 + SMPS................. 1614.7 1622.2
3......................... NOPR Testing............. 2 + Electronic Spark 1490.7 1497.7
Ignition.
4......................... 2009 TSD................. 3 + Improved Insulation.. 1414.8 1421.5
5......................... 2009 TSD................. 4 + Improved Door Seals.. 1400.6 1407.2
[[Page 60819]]
6......................... NOPR Testing............. 5 + Forced Convection.... 1355.6 1362.0
7......................... 2009 TSD................. 6 + Reduced Conduction 1347.0 1353.3
Losses.
----------------------------------------------------------------------------------------------------------------
Table IV.24--June 2015 NOPR Gas Self-Clean Oven Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Proposed IAEC (kBtu)
-------------------------------
Level Efficiency level source Design option Built-in/slide-
Freestanding in
----------------------------------------------------------------------------------------------------------------
Baseline................. 2009 TSD............... Baseline.................... 1883.8 1893.7
1........................ NOPR Testing........... Baseline + SMPS............. 1848.2 1858.0
2........................ NOPR Testing........... 1 + Electronic Spark 1668.7 1677.5
Ignition.
3........................ NOPR Testing........... 2 + Forced Convection....... 1596.3 1604.7
4........................ 2009 TSD............... 3 + Reduced Conduction 1591.0 1599.4
Losses.
----------------------------------------------------------------------------------------------------------------
GE commented that DOE's estimate of a 9.71 percent decrease in IAEC
when converting from glo-bar to spark ignition is overestimated. GE
stated that its data indicate that the actual improvement would be only
60 percent of DOE's estimate. (GE, No. 32 at p. 3) As discussed in
chapter 5 of the SNOPR TSD, DOE determined the relative decrease in
energy consumption due to electronic spark ignition by comparing two
gas ovens of similar design but different ignition systems. DOE notes
that this efficiency improvement is also on the same order of magnitude
considered in the 2009 rulemaking analysis. Therefore, DOE retains its
estimated decrease in IAEC for this technology option in this SNOPR.
DOE also notes that, as discussed in section IV.A.3.b of this SNOPR, it
has revised the description of this technology option to include
intermittent/interrupted ignition systems in addition to intermittent
pilot ignition systems, recognizing that other ignition systems are
available that reduce the energy of consumption of a gas oven. DOE
welcomes any additional data demonstrating the reduction in IAEC
resulting from use of intermittent/interrupted ignition or intermittent
pilot ignition systems as compared to intermittent glo-bar ignition
systems.
AHAM and Electrolux commented that, once DOE establishes an
accurate baseline for conventional ovens, as discussed in section
IV.C.3.a of this SNOPR, DOE should adjust the proposed efficiency
levels to be proportionate to the new baseline efficiency levels.
(AHAM, No. 29 at p. 7; Electrolux, No. 27 at p. 4)
As discussed in section IV.C.3.a of this SNOPR, DOE has updated its
estimates of the baseline efficiency levels for conventional ovens for
this SNOPR. DOE has accordingly updated the incremental efficiency
levels relative to the new baseline estimates for each product class.
In addition, as discussed in section IV.A.3.b and IV.B.1.b of this
SNOPR, DOE revised its description of the design options pertaining to
gas ignition systems and screened out the optimized burner and cavity
design option from the engineering analysis. Table IV.25 through Table
IV.28 present the updated efficiency levels for each product class,
normalized based on an oven with a cavity volume of 4.3 ft\3\.
Table IV.25--Electric Standard Oven Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Proposed IAEC (kWh)
-------------------------------
Level Efficiency level source Design option Built-in/slide-
Freestanding in
----------------------------------------------------------------------------------------------------------------
Baseline................. NOPR Testing........... Baseline.................... 315.2 322.3
1........................ NOPR Testing........... Baseline + SMPS............. 306.3 313.3
2........................ 2009 TSD............... 1 + Reduced Vent Rate....... 292.3 299.0
3........................ 2009 TSD............... 2 + Improved Insulation..... 278.7 285.0
4........................ 2009 TSD............... 3 + Improved Door Seals..... 274.0 280.3
5........................ NOPR Testing........... 4 + Forced Convection....... 262.8 268.8
6........................ NOPR Testing........... 5 + Oven Separator.......... 222.8 227.8
7........................ 2009 TSD............... 6 + Reduced Conduction 222.2 227.2
Losses.
----------------------------------------------------------------------------------------------------------------
Table IV.26--Electric Self-Clean Oven Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Proposed IAEC (kWh)
-------------------------------
Level Efficiency level source Design option Built-in/slide-
Freestanding in
----------------------------------------------------------------------------------------------------------------
Baseline................. NOPR Testing........... Baseline.................... 354.9 362.0
1........................ NOPR Testing........... Baseline + SMPS............. 346.0 353.0
2........................ NOPR Testing........... 1 + Forced Convection....... 327.9 334.5
3........................ NOPR Testing........... 2 + Oven Separator.......... 279.3 284.9
[[Page 60820]]
4........................ 2009 TSD............... 3 + Reduced Conduction 278.5 284.1
Losses.
----------------------------------------------------------------------------------------------------------------
Table IV.27--Gas Standard Oven Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Proposed IAEC (kBtu)
-------------------------------
Level Efficiency level source Design option Built-in/slide-
Freestanding in
----------------------------------------------------------------------------------------------------------------
Baseline................. ....................... Baseline (Intermittent Glo- 2083.1 2093.0
bar Ignition).
1........................ NOPR Testing........... Baseline + SMPS............. 2052.5 2062.4
2........................ NOPR Testing........... 1 + Intermittent/interrupted 1849.9 1858.8
Ignition or Intermittent
Pilot Ignition.
3........................ 2009 TSD............... 2 + Improved Insulation..... 1754.6 1763.1
4........................ 2009 TSD............... 3 + Improved Door Seals..... 1736.8 1745.1
5........................ NOPR Testing........... 4 + Forced Convection....... 1665.7 1673.7
6........................ 2009 TSD............... 5 + Reduced Conduction 1654.9 1662.9
Losses.
----------------------------------------------------------------------------------------------------------------
Table IV.28--Gas Self-Clean Oven Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Proposed IAEC (kBtu)
-------------------------------
Level Efficiency level source Design option Built-in/slide-
Freestanding in
----------------------------------------------------------------------------------------------------------------
Baseline................. ....................... Baseline (Intermittent Glo- 1959.6 1969.6
bar Ignition).
1........................ NOPR Testing........... Baseline + SMPS............. 1929.0 1939.0
2........................ NOPR Testing........... 1 + Intermittent/interrupted 1740.5 1749.4
Ignition or Intermittent
Pilot Ignition.
3........................ NOPR Testing........... 2 + Forced Convection....... 1664.5 1673.0
4........................ 2009 TSD............... 3 + Reduced Conduction 1658.9 1667.4
Losses.
----------------------------------------------------------------------------------------------------------------
Implicit in the design option descriptor for Efficiency Level 1 for
each conventional oven product class is that an SMPS replaces any
linear power supply in the control system. DOE notes that conventional
ovens equipped with electromechanical control systems have neither a
linear power supply nor an SMPS, but do not consume energy in standby
mode. As a result, DOE is not proposing a prescriptive design standard
to require SMPS and is instead proposing to exclude linear power
supplies for all conventional ovens.
c. Relationship Between IAEC and Oven Cavity Volume
The conventional oven efficiency levels detailed above are
predicated upon baseline ovens with a cavity volume of 4.3 ft\3\. Based
on DOE's testing of conventional gas and electric ovens and discussions
with manufacturers, IAEC scales with oven cavity volume due to larger
ovens having higher thermal masses and larger volumes of air (including
larger vent rates) than smaller ovens. Because the DOE test procedure
for measuring IAEC uses a fixed test load size, larger ovens with
higher thermal mass will have a higher measured IAEC. As a result, DOE
considered available data to characterize the relationship between IAEC
and oven cavity volume.
For the June 2015 NOPR, DOE established the slopes by first
evaluating the data from the 2009 TSD, which presented the relationship
between measured energy factor (EF) and cavity volume, then translated
from EF to IAEC considering the range of cavity volume for the majority
of products available on the market. DOE suggested in the June 2015
NOPR that these slopes continue to be relevant based on DOE's testing.
80 FR 33030, 33053 (June 10, 2015). For electric ovens, DOE considered
the data for standard and self-clean ovens available in the Natural
Resources Canada product databases.\40\ DOE noted that these data are
based on the same test procedure considered for the previous DOE
standards rulemaking, and as a result, DOE stated that the slopes based
on these larger datasets are relevant for this analysis. The intercepts
for each efficiency level were then chosen so that the equations pass
through the desired IAEC corresponding to a particular volume. The
values for the slopes and intercepts for each conventional oven product
class developed in the June 2015 NOPR are presented in Table IV.29 and
Table IV.30. 80 FR 33030, 33053.
---------------------------------------------------------------------------
\40\ Available at: http://oee.nrcan.gc.ca/pml-lmp/index.cfm?action=app.search-recherche&appliance=OVENS_E.
[[Page 60821]]
Table IV.29--June 2015 NOPR Slopes and Intercepts of Electric Oven IAEC versus Cavity Volume Relationship
----------------------------------------------------------------------------------------------------------------
Standard electric ovens Self-clean electric ovens
---------------------------------------------------------------
Slope = 31.8 Slope = 42.3
Level ---------------------------------------------------------------
Freestanding Built-in/slide- Freestanding Built-in/slide-
intercepts in intercepts intercepts in intercepts
----------------------------------------------------------------------------------------------------------------
Baseline........................................ 157.74 164.78 173.12 179.18
1............................................... 147.82 154.62 163.24 169.13
2............................................... 134.98 141.47 145.28 150.86
3............................................... 122.45 128.64 97.05 101.81
4............................................... 118.20 124.29 96.24 100.98
5............................................... 107.91 113.75 .............. ..............
6............................................... 71.10 76.07 .............. ..............
7............................................... 70.54 75.49 .............. ..............
----------------------------------------------------------------------------------------------------------------
Table IV.30--June 2015 NOPR Slopes and Intercepts of Gas Oven IAEC Versus Cavity Volume Relationship
----------------------------------------------------------------------------------------------------------------
Standard gas ovens Self-clean gas ovens
---------------------------------------------------------------
Slope = 214.4 Slope = 214.4
Level ---------------------------------------------------------------
Freestanding Built-in/slide- Freestanding Built-in/slide-
intercepts in intercepts intercepts in intercepts
----------------------------------------------------------------------------------------------------------------
Baseline........................................ 1196.3 1206.2 961.8 971.8
1............................................... 727.4 735.1 926.3 936.0
2............................................... 692.7 700.3 746.7 755.5
3............................................... 568.8 575.8 674.4 682.8
4............................................... 492.9 499.5 669.1 677.5
5............................................... 478.7 485.2 .............. ..............
6............................................... 433.7 440.1 .............. ..............
7............................................... 425.1 431.4 .............. ..............
----------------------------------------------------------------------------------------------------------------
As part of the analyses conducted for this SNOPR, DOE reviewed the
slopes for electric ovens derived for the 2009 rulemaking analysis.
Both electric standard and self-clean ovens but a different baseline y-
intercept. As noted in the SNOPR TSD, due to the conversion from EF to
IAEC, the relationship between IAEC and cavity volume developed for the
June 2015 NOPR analysis, using the 2009 slope, was not linear. Thus,
for this SNOPR, DOE performed a linear curve fit on the IAEC evaluated
at discrete cavity volumes that were considered to represent the range
of cavity volumes available on the market. This resulted in different
slopes for the electric standard and self-clean oven product classes.
After expanding the dataset used to establish baseline energy
consumption for electric standard ovens, as described in section
IV.C.3.a of this SNOPR, to include a wider range of cavity volumes, DOE
modified the slope for the electric oven product classes so that it was
representative of the augmented dataset.
Table IV.31 and Table IV.32 present the updated results. IAEC
versus cavity volume relationship for each product class. DOE also
notes that for gas ovens, the slope and y-intercepts have changed
slightly from the values presented in June 2015 NOPR. This is related
to a minor technical error in IAEC calculation specified in the test
procedure. The conventional oven test procedure adopted in the July
2015 TP Final Rule calculates the annual secondary energy consumption
for gas ovens (i.e., the electrical energy component of the total
annual energy consumption) using the annual useful cooking energy
output constant intended for electric ovens instead of the constant
specified for gas ovens. Because, this constant represents the typical
field usage of the oven, the factor used to calculate the annual
secondary energy consumption for gas ovens should correspond to the
same usage factor used to calculate the annual primary energy
consumption. Specific information on this minor technical change is
available in chapter 5 of the SNOPR TSD.
Table IV.31--Slopes and Intercepts of Electric Oven IAEC Versus Cavity Volume Relationship
----------------------------------------------------------------------------------------------------------------
Standard electric ovens Self-clean electric ovens
---------------------------------------------------------------
Slope = 46.3 Slope = 46.3
Level ---------------------------------------------------------------
Freestanding Built-in/slide- Freestanding Built-in/slide-
intercepts in intercepts intercepts in intercepts
----------------------------------------------------------------------------------------------------------------
Baseline........................................ 116.3 123.3 156.0 163.1
1............................................... 107.3 114.4 147.1 154.1
2............................................... 93.4 100.1 129.0 135.6
3............................................... 79.7 86.1 80.4 86.0
4............................................... 75.1 81.4 79.5 85.1
5............................................... 63.9 69.9 .............. ..............
[[Page 60822]]
6............................................... 23.9 28.9 .............. ..............
7............................................... 23.3 28.2 .............. ..............
----------------------------------------------------------------------------------------------------------------
Table IV.32--Slopes and Intercepts of Gas Oven IAEC Versus Cavity Volume Relationship
----------------------------------------------------------------------------------------------------------------
Standard gas ovens Self-clean gas ovens
---------------------------------------------------------------
Slope = 229.5 Slope = 229.5
Level ---------------------------------------------------------------
Freestanding Built-in/slide- Freestanding Built-in/slide-
intercepts in intercepts intercepts in intercepts
----------------------------------------------------------------------------------------------------------------
Baseline........................................ 1096.1 1106.1 972.7 982.6
1............................................... 1065.5 1075.5 942.1 952.0
2............................................... 863.0 871.9 753.6 762.5
3............................................... 767.7 776.1 677.6 686.1
4............................................... 749.8 758.2 672.0 680.5
5............................................... 678.7 686.7 .............. ..............
6............................................... 668.0 675.9 .............. ..............
----------------------------------------------------------------------------------------------------------------
4. Incremental Manufacturing Production Cost Estimates
a. Conventional Cooking Tops
Based on the analyses discussed above, DOE developed the cost-
efficiency results for each conventional cooking top product class
shown in Table IV.33. Where available, DOE developed incremental
manufacturing production costs (MPCs) based on manufacturing cost
modeling of test units in its sample featuring the proposed design
options. For design options that were not observed in DOE's sample of
test units for this SNOPR, DOE used the incremental manufacturing costs
developed as part of the 2009 TSD, then adjusted the values to reflect
changes in the Bureau of Labor Statistics' Producer Price Index (PPI)
for household cooking appliance manufacturing.\41\
---------------------------------------------------------------------------
\41\ Available at: http://www.bls.gov/ppi/.
Table IV.33--Conventional Cooking Top Incremental Manufacturing Production Cost (2014$)
----------------------------------------------------------------------------------------------------------------
Open (coil)
element Smooth element Gas cooking
Level electric electric tops
cooking tops cooking tops
----------------------------------------------------------------------------------------------------------------
Baseline........................................................ .............. .............. ..............
1............................................................... $2.71 $0.70 $11.33
2............................................................... .............. 2.42 11.33
3............................................................... .............. 108.19 11.33
4............................................................... .............. 186.08 ..............
----------------------------------------------------------------------------------------------------------------
b. Conventional Ovens
For the June 2015 NOPR, DOE developed the cost-efficiency results
for each conventional oven product class shown in Table IV.34. DOE
noted that the estimated incremental MPCs would be equivalent for the
freestanding and built-in/slide-in oven product classes. 80 FR 33030,
33053-33054.
Table IV.34--June 2015 NOPR Conventional Oven Incremental Manufacturing Production Cost (2014$)
----------------------------------------------------------------------------------------------------------------
Electric ovens Gas ovens
Level ---------------------------------------------------------------
Standard Self-clean Standard Self-clean
----------------------------------------------------------------------------------------------------------------
Baseline........................................ .............. .............. .............. ..............
1............................................... 0.82 0.82 0.00 0.82
2............................................... 2.76 25.00 0.82 7.31
3............................................... 7.89 56.74 7.31 27.96
4............................................... 10.22 61.93 12.44 33.15
5............................................... 34.40 .............. 14.77 ..............
6............................................... 66.14 .............. 35.43 ..............
7............................................... 70.36 .............. 39.74 ..............
----------------------------------------------------------------------------------------------------------------
[[Page 60823]]
AHAM disagreed with DOE's conclusion that the optimized burner/
cavity design option has a zero-cost. AHAM stated that for
manufacturers that have not reduced the gauge of the metals, this
change would require a retooling cost for reducing the gauge. (AHAM,
No. 29 at p. 8) As discussed in section IV.B.1.b of this SNOPR, DOE
screened out the optimized burner and cavity design option from the
engineering analysis. As a result, DOE removed this efficiency level
from the analysis for this SNOPR. The cost-efficiency results for each
conventional oven product class are shown in Table IV.35.
Table IV.35--Conventional Oven Incremental Manufacturing Production Cost (2014$)
----------------------------------------------------------------------------------------------------------------
Electric ovens Gas ovens
Level ---------------------------------------------------------------
Standard Self-clean Standard Self-clean
----------------------------------------------------------------------------------------------------------------
Baseline........................................ .............. .............. .............. ..............
1............................................... 0.82 0.82 0.82 0.82
2............................................... 2.76 25.00 7.31 7.31
3............................................... 7.89 56.74 12.44 27.96
4............................................... 10.22 61.93 14.77 33.15
5............................................... 34.40 .............. 35.43 ..............
6............................................... 66.14 .............. 39.74 ..............
7............................................... 70.36 .............. .............. ..............
----------------------------------------------------------------------------------------------------------------
5. Consumer Utility
In determining whether a standard is economically justified, EPCA
requires DOE to consider ``any lessening of the utility or the
performance of the covered products likely to result from the
imposition of the standard.'' (42 U.S.C. 6295(o)(2)(B)(i)(IV))
a. Conventional Cooking Tops
In response to the February 2014 RFI, AHAM and Whirlpool commented
that new energy conservation standards could likely impact the utility
of conventional cooking tops in the following ways:
A standard could lower burner input rates, which will
impact cooking times. Higher burner input rates allow for quicker
cooking time, which is an important consumer utility;
A standard could require changes to grate materials. Heavy
duty grates, such as cast iron grates, hold larger cooking vessels and
provide for better pot stability. Thus, a change to less sturdy grates
would impact consumer utility;
A standard could also result in the removal of accent
lighting and large displays which are preferred consumer features.
There is reduced consumer utility from further reducing standby power
from what products use today. According to Whirlpool, the market is
still pushing manufacturers to add more advanced electronics that use
more standby power. (AHAM, No. 9 at p. 7; Whirlpool, No. 13 at pp. 5,
8).
Accordingly, AHAM and Whirlpool opposed amendment of the existing
standards for cooking products. AHAM and Whirlpool stated that not only
would amended standards fail to be technologically feasible or
economically justified, but they would also impact the utility of
cooking products. (AHAM, No. 9 at p. 7; Whirlpool, No. 13 at p. 8)
DOE conducted the engineering analysis by considering cooking top
design options that are consistent with products currently on the
market, and as a result, DOE did not consider changes that would result
in removal of accent lighting and display features. For gas cooking
tops, DOE considered efficiency levels associated with optimizing the
burner and grates, but selected efficiency levels based on products
tested with cast iron grates to maintain ability to provide stability
for pots containing larger loads. As discussed in section V.B.8 of this
SNOPR, the energy conservation standards for gas cooking tops proposed
in this SNOPR correspond to the efficiency level that maintains
features of gas cooking tops marketed as commercial-style, namely
multiple high input rate burners (i.e., greater than 14,000 Btu/h) that
would allow for quicker cooking times. As a result, DOE does not
believe that the design options and efficiency levels associated with
the proposed standards in this SNOPR would impact the consumer utility
of conventional cooking tops, as suggested by AHAM and Whirlpool, nor
preclude the availability of cooking tops marketed as commercial-style.
b. Conventional Ovens
In the June 2015 NOPR, DOE noted that it conducted the engineering
analysis by considering design options that are consistent with
products currently on the market and that it did not believe that any
of the design options and efficiency levels considered would impact the
consumer utility of conventional ovens. 80 FR 33030, 33054.
DOE also noted that gas ovens with higher burner input rates did
not have significantly faster cooking times when tested according to
the test procedure adopted in the July 2015 TP Final Rule. This is
likely due in large part to the fact that gas ovens with higher burner
input rates marketed as commercial-style often have significantly
larger thermal masses, which absorb a significant amount of additional
heat. 80 FR 33030, 33054.
Sub-Zero commented in response to the June 2015 NOPR for
conventional ovens in which DOE did not consider a separate product
class for commercial-style products, that manufacturers of commercial-
style ovens differentiate their product offerings based on features
such as heavier gauge materials and higher input rate burners.
According to Sub-Zero, these manufacturers may be forced to exit the
market if a standard were to require that they produce gas ovens that
can no longer meet customer expectations. (Sub-Zero, No. 25 at p. 7)
As discussed in section IV.A.2.b of this SNOPR, DOE was not able to
identify a clearly-defined utility provided to consumers by commercial-
style ovens and, as a result, DOE did not establish separate product
classes for these products. However, DOE recognizes that commercial-
style ovens are a product type that typically incorporate certain
features that may be expected by purchasers of such products (e.g.,
heavier-gauge cavity construction, high input rate burners, and
extension racks). DOE also recognizes that these features result in
inherently lower efficiencies for commercial-style ovens than for
residential-style ovens with comparable cavities sizes, due to the
greater thermal mass of the cavity and racks, when measured using the
test procedure adopted in the July 2015 TP Final Rule. As discussed in
section III.B and III.C of this SNOPR, DOE is proposing to repeal
[[Page 60824]]
the oven test procedure in the August 2016 TP SNOPR due to
uncertainties in its ability to measure representative energy use of
commercial-style ovens, and thus is not proposing a performance-based
standard for conventional ovens. Instead, DOE is proposing to adopt a
prescriptive design requirement for the conventional oven control
system.
D. Markups Analysis
The markups analysis develops appropriate markups in the
distribution chain to convert the MPC estimates derived in the
engineering analysis to consumer prices. At each step in the
distribution channel, companies mark up the price of the product to
cover business costs and profit margin. For conventional cooking
products, the main parties in the distribution chain are manufacturers
and retailers.
Thus, DOE analyzed a manufacturer-to-consumer distribution channel
consisting of three parties: (1) The manufacturers of the products; (2)
the retailers purchasing the products from manufacturers and selling
them to consumers; and (3) the consumers who purchase the products.
The manufacturer markup converts MPC to manufacturer selling price
(MSP). DOE developed an average manufacturer markup by examining the
annual Securities and Exchange Commission (SEC) 10-K reports filed by
publicly traded manufacturers primarily engaged in appliance
manufacturing and whose combined product range includes conventional
cooking products.
For retailers, DOE developed separate markups for baseline products
(baseline markups) and for the incremental cost of more efficient
products (incremental markups). Incremental markups are coefficients
that relate the change in the MSP of higher-efficiency models to the
change in the retailer sales price. DOE relied on economic data from
the U.S. Census Bureau to estimate average baseline and incremental
markups.\42\
---------------------------------------------------------------------------
\42\ U.S. Census, 2007 Annual Retail Trade Survey (ARTS),
Electronics and Appliance Stores sectors.
---------------------------------------------------------------------------
AHAM criticized DOE's reliance on the concept of incremental
markups, stating that its theory has been disproved and it is in
contradiction to empirical evidence. (AHAM, No. 29 at p. 9) In an
attachment to AHAM's comment, Shorey Consulting, Inc. (Shorey
Consulting) stated that (1) DOE requires a strong form of economic
theory, since it is saying that something will happen solely because
theory says it should; and (2) an a priori resort to economic theory
without clear empirical support is highly problematic. Shorey
Consulting interviewed a sample of local/regional and national
appliance retailers and reported that, with very few exceptions, they
reacted to the DOE concept that percentage margins will be lower in a
post-standards situation with incredulity. It concluded that DOE needs
to abandon the incremental margin approach and revert to the average
margin approach that corresponds to actual industry practice. (AHAM,
No. 29 at pp. A-10-A-11)
DOE disagrees that the theory behind the concept of incremental
markups has been disproved. The concept is based on a simple notion: An
increase in profitability, which is implied by keeping a fixed markup
when the product price goes up, is not likely to be viable over time in
a business that is reasonably competitive. DOE agrees that empirical
data on markup practices would be desirable, but such information is
closely held and difficult to obtain.
Regarding the interviews with appliance retailers, it is difficult
for DOE to evaluate the characterization of the responses without
knowing what questions were posed to the retailers. DOE's analysis
necessarily considers a very simplified version of the world of
appliance retailing: Namely, a situation in which nothing changes
except for those changes in appliance offerings that occur in response
to amended standards. DOE implicitly asks: Assuming the product cost
increases while the other costs remain constant (no change in labor,
material and operating costs), are retailers still able to keep the
same markup over time as before? DOE recognizes that retailers are
likely to seek to maintain the same markup on appliances if the price
they pay goes up as a result of appliance standards, but it believes
that over time adjustment is likely to occur due to competitive
pressures. Other retailers may find that they can gain sales by
reducing the markup and maintaining the same per-unit operating profit.
The incremental markup approach reflects a similar perspective as the
``preservation of per-unit operating profit markup scenario'' used in
the MIA (see section IV.J of this document).
In summary, DOE acknowledges that its approach to estimating
retailer markup practices after amended standards take effect is an
approximation of real-world practices that are both complex and varying
with business conditions. However, DOE maintains that its assumption
that standards do not facilitate a sustainable increase in
profitability is reasonable. DOE welcomes information that could
support improvement in its methodology.
Chapter 6 of the SNOPR TSD provides details on DOE's development of
markups for conventional cooking products.
E. Energy Use Analysis
The energy use analysis provides estimates of the annual energy
consumption of cooking tops and ovens at the considered efficiency
levels. DOE uses these values in the LCC and PBP analyses and in the
NIA to establish the savings in consumer operating costs at various
product efficiency levels. DOE developed energy consumption estimates
for all product classes analyzed in the engineering analysis. DOE's
energy use analysis estimated the range of energy use of cooking
products in the field, i.e., as they are actually used by consumers.
For this SNOPR, DOE used the 2009 California Residential Appliance
Saturation Survey (RASS) \43\ and a Florida Solar Energy Center (FSEC)
study \44\ to establish representative annual energy use values for
conventional cooking tops and ovens. These studies confirmed that
annual cooking energy use has been consistently declining since the
late 1970s.
---------------------------------------------------------------------------
\43\ California Energy Commission, Residential Appliance
Saturation Survey (RASS) (2009).
\44\ Parker, D., Fairey, P., Hendron, R., ``Updated
Miscellaneous Electricity Loads and Appliance Energy Usage Profiles
for Use in Home Energy Ratings, the Building America Benchmark
Procedures and Related Calculations,'' Florida Solar Energy Center
(FSEC) (2010).
---------------------------------------------------------------------------
Energy use by residential cooking products varies greatly based on
consumer usage patterns. DOE established a range of energy use from
data in the Energy Information Administration (EIA)'s 2009 Residential
Energy Consumption Survey (RECS 2009).\45\ RECS 2009 does not provide
the annual energy consumption of cooking products, but it does provide
the frequency of cooking product use.\46\ DOE was unable to use the
frequency of use to calculate the annual energy consumption using a
bottom-up approach, as data in RECS did not include information about
the duration
[[Page 60825]]
of a cooking event to allow for an annual energy use calculation. DOE
therefore relied on California RASS and FSEC studies to establish the
average annual energy consumption of conventional cooking tops and
ovens.
---------------------------------------------------------------------------
\45\ U.S. Department of Energy: Energy Information
Administration, Residential Energy Consumption Survey: 2009 RECS
Survey Data (2013) (Available at: http://www.eia.gov/consumption/residential/data/2009/). RECS 2009 is based on a sample of 12,083
households statistically selected to represent 113.6 million housing
units in the United States. (Available at: www.eia.gov/consumption/residential/).
\46\ DOE was unable to use the frequency of use to calculate the
annual energy consumption using a bottom-up approach, as data in
RECS did not include information about the duration of a cooking
event to allow for an annual energy use calculation.
---------------------------------------------------------------------------
From RECS 2009, DOE developed household samples for each product
class. For each household using a conventional cooking product, RECS
provides data on the frequency of use and number of meals cooked in the
following bins: (1) Less than once per week, (2) once per week, (3) a
few times per week, (4) once per day, (5) two times per day, and (6)
three or more times per day. DOE utilized the frequency of use to
define the variability of the annual energy consumption. First, DOE
assumed that the weighted-average cooking frequency from RECS
represents the average energy use values based on the California RASS
and FSEC studies. DOE then varied the annual energy consumption across
the RECS households based on their reported cooking frequency relative
to the weighted-average cooking frequency.
Chapter 7 of the SNOPR TSD describes the energy use analysis in
detail.
F. Life-Cycle Cost and Payback Period Analysis
The purpose of the LCC and PBP analysis is to evaluate the economic
impacts of potential energy conservation standards for cooking products
on individual consumers. The LCC is the total consumer expense over the
life of the product, including purchase and installation expense and
operating costs (energy expenditures, repair costs, and maintenance
costs). The PBP is the number of years it would take for the consumer
to recover the increased costs of purchasing a higher efficiency
product through energy savings. To calculate LCC, DOE discounted future
operating costs to the time of purchase and summed them over the
lifetime of the product.
For any given efficiency level, DOE measures the change in LCC
relative to an estimate of the base-case product efficiency
distribution. The base-case estimate reflects the market in the absence
of new or amended energy conservation standards, including the market
for products that exceed the current energy conservation standards. In
contrast, the PBP is measured relative to the baseline product.
DOE calculated the LCC and payback periods for conventional cooking
tops and ovens for a nationally representative set of housing units
selected from RECS 2009. By using a representative sample of
households, the analysis captured the variability in energy consumption
and energy prices associated with cooking product use.
For each sample household, DOE determined the energy consumption
for the cooking product and the appropriate energy price. DOE first
calculated the LCC associated with a baseline cooking product for each
household. To calculate the LCC savings and PBP associated with
products meeting higher efficiency standards, DOE substituted the
baseline unit with more efficient designs.
As part of the LCC and PBP analyses, DOE developed data that it
used to establish product prices, installation costs, annual household
energy consumption, energy prices, maintenance and repair costs,
product lifetime, and discount rates. Inputs to the LCC and PBP
analysis are categorized as: (1) Inputs for establishing the total
installed cost and (2) inputs for calculating the operating costs. DOE
models the uncertainty and the variability in the inputs to the LCC and
PBP analysis using Monte Carlo simulations and probability
distributions.\47\
---------------------------------------------------------------------------
\47\ The Monte Carlo process statistically captures input
variability and distribution without testing all possible input
combinations. Therefore, while some atypical situations may not be
captured in the analysis, DOE believes the analysis captures an
adequate range of situations in which the conventional cooking
products operate.
Table IV.36--Summary of Inputs and Methods for the LCC and PBP Analysis
*
------------------------------------------------------------------------
Inputs Source/method
------------------------------------------------------------------------
Product Cost...................... Derived by multiplying MPCs by
manufacturer and retailer markups
and sales tax, as appropriate. Used
historical data to derive a price
scaling index to forecast product
costs.
Installation Costs................ Baseline installation cost
determined with data from RS Means.
Assumed no change with efficiency
level, except for induction heating
design option of electric smooth
cooking top.
Annual Energy Use................. The total annual energy use was
based on CA RASS and FSEC Studies.
Variability: Based on the 2009 RECS.
Energy Prices..................... Electricity: Based on EIA's Form 861
data for 2012.
Variability: Regional energy prices
determined for 27 regions.
Energy Price Trends............... Based on AEO2015 price forecasts.
Repair and Maintenance Costs...... Assumed no change with efficiency
level for all cooking tops and
electric ovens. Used industry input
to estimate change in repair and
maintenance costs to switch from
glo-bar ignition to electronic
spark ignition.
Product Lifetime.................. 16 years for electric and 13 years
for gas cooking products.
Discount Rates.................... Approach involves identifying all
possible debt or asset classes that
might be used to purchase the
considered appliances, or might be
affected indirectly. Primary data
source was the Federal Reserve
Board's Survey of Consumer
Finances.
Compliance Date................... 2019.
------------------------------------------------------------------------
* References for the data sources mentioned in this table are provided
in the sections following the table and in chapter 8 of the SNOPR TSD.
The following sections contain comments on the inputs and key
assumptions of DOE's LCC and PBP analysis and explain how DOE took
these comments into consideration. Chapter 8 of the TSD accompanying
this SNOPR contains detailed discussion of the methodology and data
utilized for the LCC and PBP analysis.
1. Product Costs
To calculate the prices faced by cooking products purchasers, DOE
multiplied the manufacturing costs developed from the engineering
analysis by the supply chain markups it developed (along with sales
taxes).
To project future product prices, DOE examined the electric and gas
cooking products PPI for the period 1982-2013. This index, adjusted for
inflation, shows a declining trend. The decline for gas cooking
products is somewhat more
[[Page 60826]]
significant than that for electric cooking products (see appendix 10-D
of the SNOPR TSD). Based on an exponential fit of the adjusted PPIs,
DOE utilized a declining price trend for both electric and gas cooking
products as the default case to project future product price.
2. Installation Costs
Installation costs include labor, overhead, and any miscellaneous
materials and parts. For this SNOPR, DOE used data from the 2013 RS
Means Mechanical Cost Data on labor requirements to estimate
installation costs for conventional cooking products.\48\
---------------------------------------------------------------------------
\48\ RS Means Company Inc., RS Means Mechanical Cost Data (2013)
(Available at http://rsmeans.reedconstructiondata.com/default.aspx).
---------------------------------------------------------------------------
In general, DOE estimated that installation costs would be the same
for different efficiency levels. In the case of electric smooth cooking
tops, the induction heating design option requires a change of utensils
to those that are ferromagnetic to operate the cooking tops. DOE
treated this as additional installation cost for this particular design
option. DOE used average number of pots and pans utilized by a
representative household to estimate this portion of the installation
cost. See chapter 8 of the SNOPR TSD for details about this component.
Given the installation costs of the induction cooktop, the market share
is expected to remain at 2.6% in the standards case. See section IV.F.9
and IV.H.1 for details on the market shares.
3. Unit Energy Consumption
Section IV.E of this SNOPR describes the derivation of annual
energy use for conventional cooking products.
DOE did not find any evidence of a rebound effect, in which
consumers use a more efficient appliance more intensively, for
conventional cooking products. Cooking practices are affected by
people's eating habits, which are unlikely to change due to higher
product efficiency. DOE requests comment on its decision to not use a
rebound effect for cooking products (see issue 11 in section VII.E of
this SNOPR).
4. Energy Prices
DOE derived marginal residential electricity and natural gas prices
for 27 geographic areas.\49\ Marginal prices are appropriate for
determining energy cost savings associated with possible changes to
efficiency standards.
---------------------------------------------------------------------------
\49\ DOE characterized the geographic distribution into 27
geographic areas to be consistent with the 27 states and group of
states reported in RECS 2009.
---------------------------------------------------------------------------
For electricity, DOE derived marginal and average prices which vary
by season, region, and baseline electricity consumption level. DOE
estimated these prices using data published with EEI, Typical Bill and
Average Rates reports for summer and winter 2014.\50\ For the
residential sector each report provides, for most of the major
investor-owned utilities (IOUs) in the country, the total bill assuming
household consumption levels of 500, 750, and 1,000 kWh for the billing
period. DOE defined the average price as the ratio of the total bill to
the total electricity consumption. DOE also used the EEI data to define
a marginal price as the ratio of the change in the bill to the change
in energy consumption.
---------------------------------------------------------------------------
\50\ Edison Electric Institute. Typical Bills and Average Rates
Report. Winter 2014 published April 2014, Summer 2014 published
October 2014. Available at: http://www.eei.org/resourcesandmedia/products/Pages/Products.aspx.
---------------------------------------------------------------------------
For the residential sector, DOE defined the average price as the
ratio of the total bill to the total electricity consumption. DOE also
used the EEI data to define a marginal price as the ratio of the change
in the bill to the change in energy consumption. DOE first calculated
weighted-average values for each geographic area for each type of
price. Each EEI utility in an area was assigned a weight based on the
number of consumers it serves. Consumer counts were taken from the most
recent EIA Form 861 data (2012).\51\
---------------------------------------------------------------------------
\51\ U. S. Department of Energy, Energy Information
Administration. Form EIA-861 Annual Electric Power Industry
Database. http://www.eia.doe.gov/cneaf/electricity/page/eia861.html.
---------------------------------------------------------------------------
DOE assigned seasonal average prices to each household in the LCC
sample based on its location and its baseline monthly electricity
consumption for an average summer or winter month. For sampled
households who were assigned a product efficiency greater than or equal
to the considered level for a standard in the no-new-standards case,
DOE assigned marginal price to each household based on its location and
the decremented electricity consumption. In the LCC sample, households
could be assigned to one of 27 geographic areas.
DOE obtained data for calculating prices of natural gas from the
EIA publication, Natural Gas Navigator.\52\ DOE used the complete
annual data for 2013 to calculate an average annual price for each
geographic area. (For use in the LCC model, prices were scaled to
2015$.) For each State, DOE calculated the annual residential price of
natural gas using a simple average of data. DOE then calculated a price
for each geographic area, weighting each State in an area by its number
of households.
---------------------------------------------------------------------------
\52\ U.S. Department of Energy--Energy Information
Administration. Natural Gas Navigator. 2013. (Last accessed April
26, 2015.) http://tonto.eia.doe.gov/dnav/ng/ng_pri_sum_dcu_nus_m.htm.
---------------------------------------------------------------------------
The method used to calculate marginal natural gas prices differs
from that used to calculate electricity prices, because EIA does not
provide consumer- or utility-level data on gas consumption and prices.
EIA provides historical monthly natural gas consumption and
expenditures by State. This data was used to determine 10-year average
marginal price factors for the geographical areas. These factors are
then used to convert average monthly energy prices into marginal
monthly energy prices. Because cooking products operate all year
around, DOE determined summer and winter marginal price factors.
To estimate future trends in electricity and natural gas prices,
DOE used price forecasts in AEO 2015. To arrive at prices in future
years, DOE multiplied the average and marginal prices described above
by the forecast of annual average changes in national-average
residential electricity and natural gas prices. Because the AEO 2015
forecasts prices only to 2040, DOE used the average rate of change
during 2025-2040 to estimate the price trends beyond 2040.
The spreadsheet tool used to conduct the LCC and PBP analysis
allows users to select the AEO 2015 high-growth case or low-growth case
price forecasts to estimate the sensitivity of the LCC and PBP to
different energy price forecasts.
See Chapter 8 of the SNOPR TSD for more information on the
derivation of energy prices.
5. Repair and Maintenance Costs
Repair costs are associated with repairing or replacing components
that have failed in the appliance. Maintenance costs are associated
with maintaining the operation of the equipment.
Typically, small incremental changes in product efficiency incur
no, or only very small, changes in repair and maintenance costs over
baseline products. For all electric cooking products, DOE did not
include any changes in repair and maintenance costs for products more
efficient than baseline products.
For gas ovens, DOE determined the repair and maintenance costs
associated with different types of ignition systems. For the July 2015
NOPR for conventional ovens, DOE estimated an average repair cost of
$170 occurring every fifth year during the product's lifetime. 80 FR
33030, 33056.
[[Page 60827]]
For electronic spark ignition systems, DOE estimated an average
repair cost of $206 occurring in the tenth year of the product's life.
DOE received comments regarding the frequency of repair for the
electric globar/hot surface ignition systems. AHAM commented that a
globar is replaced less often than three times during the lifetime of
an oven. (AHAM, No. 29 at p. 8) Electrolux noted that during their
life-cycle testing of an oven using globars, they estimated a
replacement rate of approximately 0.70 glo-bars. (Electrolux, No. 27 at
p.5) GE commented that the globar replacement occurs significantly less
frequently than the three times DOE estimated. (GE, No.32 at p.3)
Utilizing these inputs along with the earlier data from manufacturer
inputs, DOE revised the average repair cost attributable to globar and
electronic spark ignition systems and annualized it over the life of
the unit at $21.04 and $20.60 for globar and electronic spark ignition
systems, respectively. Based on input from manufacturers, DOE did not
include maintenance costs for glo-bars or electronic ignitions.
DOE seeks comments on its repair cost estimation for gas ovens, as
well as on its decision not to include changes in repair and
maintenance costs for products more efficient than baseline products
for electric cooking products (see section VII.B of this SNOPR).
See chapter 8 of the TSD accompanying this SNOPR for further
information regarding repair and maintenance costs.
6. Product Lifetime
Equipment lifetime is the age at which the equipment is retired
from service. DOE used a variety of sources to establish low, average,
and high estimates for product lifetime. In the July 2015 NOPR, DOE
utilized data from Appliance Magazine Market Insight, and established
average product lifetimes of 15 years for conventional electric cooking
products and 17 years for conventional gas cooking products.\53\ 80 FR
33030, 33056. AHAM commented that their data indicated average product
lifetimes of 16 years for conventional electric ovens and 13 years for
conventional gas ovens. (AHAM, No. 29 at p. 9) For the SNOPR, DOE
revised the average lifetime estimates to reflect the new data,
extending the revision as applicable also to electric and gas cooking
tops, thereby establishing an average product lifetimes of 16 years for
all electric cooking products and 13 years for all conventional gas
cooking products. DOE characterized the product lifetimes with Weibull
probability distributions. DOE requests comment on using the data it
received from AHAM on the average lifetime for gas and electric ovens
and extending it to cooktops (See Section VII E. Issues on Which DOE
Seeks Comment).
---------------------------------------------------------------------------
\53\ Appliance Magazine, Market Insight. The U.S. Appliance
Industry: Market Value, Life Expectancy & Replacement Picture 2012.
---------------------------------------------------------------------------
See chapter 8 of the TSD accompanying this SNOPR for further
details on the sources used to develop product lifetimes, as well as
the use of Weibull distributions.
7. Discount Rates
In the calculation of LCC, DOE applies discount rates appropriate
to households to estimate the present value of future operating costs.
DOE estimated a distribution of residential discount rates for
conventional cooking products based on consumer financing costs and
opportunity cost of funds related to appliance energy cost savings and
maintenance costs.
To establish residential discount rates for the LCC analysis, DOE's
approach involved identifying all relevant household debt or asset
classes in order to approximate a consumer's opportunity cost of funds
related to appliance energy cost savings and maintenance costs. DOE
estimated the average percentage shares of the various types of debt
and equity by household income group using data from the Federal
Reserve Board's Survey of Consumer Finances (SCF) for 1995, 1998, 2001,
2004, 2007, 2010, and 2013.\54\ Using the SCF and other sources, DOE
then developed a distribution of rates for each type of debt and asset
by income group to represent the rates that may apply in the year in
which amended standards would take effect. DOE assigned each sample
household a specific discount rate drawn from one of the distributions.
The average rate across all types of household debt and equity and
income groups, weighted by the shares of each class, is 4.4 percent.
See chapter 8 in the SNOPR TSD for further details on the development
of consumer discount rates.
---------------------------------------------------------------------------
\54\ Note that two older versions of the SCF are also available
(1989 and 1992). These surveys were not used in this analysis
because they do not provide all of the necessary types of data
(e.g., credit card interest rates). DOE determines that the 15-year
span covered by the six surveys included is sufficiently
representative of recent debt and equity shares and interest rates.
---------------------------------------------------------------------------
8. Compliance Date
The compliance date is the date when a covered product is required
to meet a new or amended standard. DOE calculated the LCC and PBP for
all customers as if each were to purchase a new product in the year
that compliance with amended standards is required. Any final rule
establishing amended standards would apply to conventional cooking
products manufactured 3 years after the date on which the final rule is
published (42 U.S.C. 6295(m)(4)(A)(i)). For purposes of its analysis,
DOE assumed that a final rule would be published in 2016, which results
in 2019 being the first year of compliance with amended standards.
9. No-New-Standards Case Efficiency Distribution
To estimate the share of consumers that would be affected by a
potential energy conservation standard at a particular efficiency
level, DOE's LCC analysis considered the projected distribution (market
shares) of product efficiencies in the no-new-standards case (i.e., the
case without amended or new energy conservation standards). This
approach reflects the fact that some consumers may purchase products
with efficiencies greater than the baseline levels.
To establish the current efficiency distribution for electric
cooking products and conventional gas ovens, DOE developed and
implemented a consumer-choice model \55\ that assumes most consumers
(i.e., home owners \56\) are sensitive to the appliance first cost, and
calculates the market share for available efficiency options based on
the initial cost of electric cooking products and gas ovens at each
efficiency level. DOE used a logit model to characterize historical
shipments as a function of purchase price. In order to develop the
logit model, DOE utilized shipments data collected by Market Research
Magazine \57\ and the PPI of household cooking appliance manufacturing
\58\ in the years 2002-2012, along with the consumer purchase price
derived from the engineering analysis, to analyze factors that
influence consumer purchasing decisions. Using this model, DOE found
that historical shipments
[[Page 60828]]
show a strong dependence on the first costs for electric cooking
products and conventional gas ovens, and developed the best-fit logit
parameters to capture this relationship. DOE then used the parameters
to derive the market share for available efficiency options for home
owners. Given that landlords generally have little incentive to install
higher-efficiency products, DOE assigned the purchases of renters in
the RECS sample to the baseline efficiency level.
---------------------------------------------------------------------------
\55\ DOE developed this consumer choice model for this
rulemaking, the details of which are outlined in Chapter 8 of the
SNOPR TSD. This consumer choice framework has been used in many
rulemakings and is also a key component in EIA's NEMS residential
model to simulate appliance purchases over a range of efficiencies.
\56\ DOE assumed that landlords would have no economic incentive
to purchase higher-efficiency products and renters would have no
decision making power to purchase or replace an electric cooking
products or gas oven.
\57\ UBM Canon, Market Research Magazine: Appliance Historical
Statistical Review, 2014.
\58\ U.S. Bureau of Labor Statistics, Producer Price Index
Industry Data: Household cooking appliance manufacturing, 2014.
---------------------------------------------------------------------------
To establish the current efficiency distribution for gas cooking
tops, DOE relied on publicly available data on gas cooking top models
in the market \59\ and their configuration with regard to grates and
burner input rates to characterize the efficiency distribution.
---------------------------------------------------------------------------
\59\ Model data collected from the Web sites of A J Madison,
Best Buy, and Lowe's.
---------------------------------------------------------------------------
Given the lack of data on historic efficiency trends, DOE assumed
that the estimated current distributions would apply in 2019.
Table IV.37, Table IV.38, and Table IV.39 present the market shares
of the efficiency levels in the no-new-standards case for conventional
cooking products.\60\ See chapter 8 of the SNOPR TSD for further
details on the development of these market shares.
---------------------------------------------------------------------------
\60\ For the conventional oven product classes, the efficiency
levels are based on an oven with a cavity volume of 4.3 ft\3\. As
discussed in section IV.C.3 of this notice, DOE developed slopes and
intercepts to characterize the relationship between IEAC and cavity
volume for each efficiency level.
[GRAPHIC] [TIFF OMITTED] TP02SE16.003
[[Page 60829]]
[GRAPHIC] [TIFF OMITTED] TP02SE16.004
DOE seeks comments on its use of consumer choice model for
establishing no-new standards efficiency distribution for some of the
product classes (see section VII.B of this SNOPR).
See chapter 8 of the TSD accompanying this SNOPR for further
information regarding no-new standards efficiency distribution.
10. Inputs to Payback Period Analysis
The PBP is the amount of time it takes the consumer to recover the
additional installed cost of more efficient equipment, compared to
baseline equipment, through energy cost savings. PBPs are expressed in
years. PBPs that exceed the life of the product mean that the increased
total installed cost is not recovered in reduced operating expenses.
The inputs to the PBP calculation are the total installed cost of
the product to the customer for each efficiency level and the annual
first year operating expenditures for each efficiency level. The PBP
calculation uses the same inputs as the LCC analysis, except that
energy price trends and discount rates are not needed.
11. Rebuttable-Presumption Payback Period
EPCA establishes a rebuttable presumption that a standard is
economically justified if the Secretary finds that the additional cost
to the consumer of purchasing a product complying with an energy
conservation standard level will be less than three times the value of
the energy savings during the first year that the consumer will receive
as a result of the standard, as calculated under the test procedure in
place for that standard. (42 U.S.C. (o)(2)(B)(iii) For each considered
efficiency level, DOE determines the value of the first year's energy
savings by calculating the quantity of those savings in accordance with
the applicable DOE test procedure, and multiplying that amount by the
average energy price forecast for the year in which compliance with the
amended standards would be required. While DOE examined the rebuttable-
presumption criterion, it considered whether the standard levels
considered for this rule are economically justified through a more
detailed analysis of the economic impacts of those levels pursuant to
42 U.S.C. 6295(o)(2)(B)(i) (See section V.B.1.c.).
G. Shipments Analysis
DOE uses projections of product shipments to calculate the national
impacts of standards on energy use, NPV, and future manufacturer cash
flows. DOE develops shipment projections based on historical data and
an analysis of key market drivers for each product. Historical
shipments data are used to build up an equipment stock and also to
calibrate the shipments model. For conventional cooking products, DOE
accounted for three market segments: (1) New construction, (2) existing
homes (i.e., replacing failed products), and (3) retired but not
replaced products.
To determine new construction shipments, DOE used a forecast of new
housing coupled with product market saturation data for new housing.
For new housing completions and mobile home placements, DOE adopted the
projections from EIA's AEO 2015 through 2040. The market saturation
data for new housing came from RECS 2009.
DOE estimated replacements using product retirement functions
developed from product lifetimes. DOE used retirement functions based
on Weibull distributions.
To reconcile the historical shipments with the model, DOE assumed
that every retired unit is not replaced. DOE attributed the reason for
this non-replacement to building demolition occurring over the period
2013-2048. The not-replaced rate is distributed across electric and gas
cooking products.
DOE allocated shipments to each product class based on the current
market share of the class. DOE developed the market shares based on
data collected from Appliance Magazine Market Research report \61\ and
U.S. Appliance Industry Statistical Review.\62\ The shares are kept
constant over time.
---------------------------------------------------------------------------
\61\ Appliance Magazine Market Research. The U.S. Appliance
Industry: Market Value, Life Expectancy & Replacement Picture 2012.
\62\ Appliance 2011. U.S. Appliance Industry Statistical Review:
2000 to YTD 2011.
---------------------------------------------------------------------------
DOE did not estimate any fuel switching for electric and gas
cooking products, as no significant switching was observed from
historical data.
[[Page 60830]]
Table IV.40 summarizes the approach and data DOE used to derive the
inputs to the shipments analysis for the SNOPR.
Table IV.40--Approach and Data Used To Derive the Inputs to the
Shipments Analysis
------------------------------------------------------------------------
Inputs Approach
------------------------------------------------------------------------
New Construction Shipments........ Determined by multiplying housing
forecasts by forecasted saturation
of cooking products for new
housing. Housing forecasts based on
AEO2015 projections. New housing
product saturations based on RECS
2009. Saturations maintained at
2009 levels.
Replacements...................... Determined by tracking total product
stock by vintage and establishing
the failure of the stock using
retirement functions from the LCC
and PBP analysis. Retirement
functions were based on Weibull
lifetime distributions.
Retired but not replaced.......... Used to calibrate shipments model to
historical shipments data to
account for a decline in the
replacement shipments.
Historical Shipments.............. Data sources include U.S.
Statistical Review of Appliance
Industry, Appliance Magazine and
Association of Home Appliance
Manufacturers.
Impacts Due to Efficiency Considered an impact on the
Standards. replacement market through possible
repair of older cooking units to
extend their lifetime, in response
to an increase in price.
------------------------------------------------------------------------
DOE considered the impact of prospective standards on product
shipments. DOE concluded that it is unlikely that the price increase
due to the proposed standards would impact the decision to install a
cooking product in the new construction market. In the replacement
market, DOE assumed that, in response to an increased product price,
some consumers will choose to repair their old cooking product and
extend its lifetime instead of replacing it immediately. DOE estimated
the magnitude of such impact through a purchase price elasticity of
demand. The estimated price elasticity of -0.367 is based on data on
cooking products as described in appendix 9A of the SNOPR TSD. This
elasticity relates the repair or replace decision to the incremental
installed cost of higher efficiency cooking products. DOE estimated
that the average extension of life of the repaired unit would be 5
years, and then that unit will be replaced with a new cooking unit.
DOE seeks comments on its approach and use of data for shipments
analysis (see section VII.B of this SNOPR).
For further details on the shipments analysis, please refer to
chapter 9 of the SNOPR TSD.
H. National Impact Analysis
The NIA assesses the national energy savings and the national NPV
of total consumer costs and savings that would be expected to result
from amended standards at specific efficiency levels.
DOE used an MS Excel spreadsheet model to calculate the national
energy savings and the consumer costs and savings from each TSL.\63\
The NIA calculations are based on the annual energy consumption and
total installed cost data from the energy use analysis and the LCC
analysis. DOE projected the lifetime energy savings, energy cost
savings, equipment costs, and NPV of customer benefits for each product
class over the lifetime of equipment sold from 2019 through 2048.
---------------------------------------------------------------------------
\63\ DOE's use of MS Excel as the basis for the spreadsheet
models provides interested parties with access to the models within
a familiar context. In addition, the TSD and other documentation
that DOE provides during the rulemaking help explain the models and
how to use them. Interested parties can review DOE's analyses by
changing various input quantities within the spreadsheet.
---------------------------------------------------------------------------
DOE evaluated the impacts of potential standards for conventional
cooking products by comparing a case without such standards with
standards-case projections. The no-new-standards case characterizes
energy use and customer costs for each product class in the absence of
proposed energy conservation standards. DOE compares the no-new-
standards case with projections characterizing the market for each
product class if DOE adopted new or amended standards at specific
energy efficiency levels (i.e., the TSLs or standards cases) for that
class.
Table IV.41 summarizes the key inputs for the NIA. The sections
following provide further details, as does chapter 10 of the SNOPR TSD.
Table IV.41--Inputs for the National Impact Analysis
------------------------------------------------------------------------
Input Description
------------------------------------------------------------------------
Shipments......................... Annual shipments from shipments
model.
Compliance date................... January 1, 2019.
No-new-standards-case efficiency.. Based on consumer choice model for
electric cooking products and gas
ovens and model web-based data for
gas cooking tops.
Standards-case efficiency......... Based on a ``roll up'' scenario to
establish a 2019 shipment weighted
efficiency.
Annual energy consumption per unit Calculated for each efficiency level
and product class based on inputs
from the energy use analysis.
Total installed cost per unit..... Calculated by efficiency level using
manufacturer selling prices and
weighted-average overall markup
values.
Energy expense per unit........... Annual energy use is multiplied by
the corresponding average
electricity and gas price.
Escalation of electricity and gas AEO 2015 forecasts (to 2040) and
prices. extrapolation beyond 2040 for
electricity and gas prices.
Electricity site-to-primary energy A time series conversion factor;
conversion. includes electric generation,
transmission, and distribution
losses.
Discount rates.................... 3% and 7%.
Present year...................... 2016.
------------------------------------------------------------------------
[[Page 60831]]
1. Efficiency Trends
A key component of DOE's estimates of national energy savings and
NPV is the energy efficiencies forecasted over time. For the no-new-
standards case, DOE utilized the consumer choice model (as described in
section IV.F.9 of this SNOPR) in combination with the equipment price
projection (as described in section IV.F.1 of this SNOPR) to determine
the efficiencies in each future year.
To estimate the impact that standards would have in the year
compliance becomes required, DOE assumed that equipment efficiencies in
the no-new-standards case that do not meet the standard level under
consideration would ``roll up'' to meet the new standard level, and
market shares at efficiencies above the standard level under
consideration will shift based on the consumer choice model. In the
case of gas cooking tops, which do not follow a consumer choice model,
the market shares at efficiencies above the standard level under
consideration would remain unchanged.
2. National Energy Savings
For each year in the forecast period, DOE calculates the national
energy savings for each standard level by multiplying the shipments of
cooking products by the per-unit annual energy savings. Cumulative
energy savings are the sum of the annual energy savings over the
lifetime of all equipment shipped during 2019-2048.
The annual energy consumption per unit depends directly on
equipment efficiency. DOE used the shipment-weighted energy
efficiencies associated with the no-new-standards case and each
standards case, in combination with the annual energy use data, to
estimate the shipment-weighted average annual per-unit energy
consumption under the no-new-standards case and standards cases. The
national energy consumption is the product of the annual energy
consumption per unit and the number of units of each vintage, which
depends on shipments. DOE calculates the total annual site energy
savings for a given standards case by subtracting total energy use in
the standards case from total energy use in the no-new-standards case.
Note that total shipments are nearly the same in the standards cases as
in the no-new-standards case.
DOE converted the site electricity consumption and savings to
primary energy (power sector energy consumption) using annual
conversion factors derived from the AEO 2015 version of the National
Energy Modeling System (NEMS).
In response to the recommendations of a committee on ``Point-of-Use
and Full-Fuel-Cycle Measurement Approaches to Energy Efficiency
Standards'' appointed by the National Academy of Science, DOE announced
its intention to also use FFC measures of energy use, GHG emissions and
other emissions in the national impact analyses and emissions analyses
included in future energy conservation standards rulemakings. 76 FR
51281 (August 18, 2011). After evaluating the approaches discussed in
the August 18, 2011 notice, DOE published a statement of amended policy
in the Federal Register in which DOE explained its determination that
NEMS is the most appropriate tool for its FFC analysis and its
intention to use NEMS for that purpose. 77 FR 49701 (August 17, 2012).
The FFC factors incorporate losses in production and delivery in the
case of natural gas (including fugitive emissions), and energy used to
produce and deliver the fuels used by power plants. The approach used
for this SNOPR, and the FFC multipliers that were applied, are
described in appendix 10A of the SNOPR TSD. Table IV.42 through Table
IV.46 present the FFC equivalent of IAEC for the considered efficiency
levels.
[GRAPHIC] [TIFF OMITTED] TP02SE16.005
Table IV.43--Conventional Electric Standard Ovens: FFC Equivalent of IAEC
----------------------------------------------------------------------------------------------------------------
IAEC--Site (kWh) IAEC--FFC (kWh)
---------------------------------------------------------------
Standard level Built-in/ Built-in/
Free-standing slide-in Free-standing slide-in
----------------------------------------------------------------------------------------------------------------
Baseline........................................ 315.2 322.3 1,039 1,062
1............................................... 306.3 313.3 1,009 1,032
2............................................... 292.3 299.0 963 985
3............................................... 278.7 285.0 918 939
[[Page 60832]]
4............................................... 274.0 280.3 903 924
5............................................... 262.8 268.8 866 886
6............................................... 222.8 227.8 734 751
7............................................... 222.2 227.2 732 749
----------------------------------------------------------------------------------------------------------------
Table IV.44--Conventional Electric Self-Clean Ovens: FFC Equivalent of IAEC
----------------------------------------------------------------------------------------------------------------
IAEC--Site (kWh) IAEC--FFC (kWh)
---------------------------------------------------------------
Standard level Built-in/ Built-in/
Free-standing slide-in Free-standing slide-in
----------------------------------------------------------------------------------------------------------------
Baseline........................................ 354.9 362.0 1,170 1,193
1............................................... 346.0 353.0 1,140 1,163
2............................................... 327.9 334.5 1,080 1,102
3............................................... 279.3 284.9 920 939
4............................................... 278.5 284.1 918 936
----------------------------------------------------------------------------------------------------------------
Table IV.45--Conventional Gas Standard Ovens: FFC Equivalent of IAEC
----------------------------------------------------------------------------------------------------------------
IAEC--Site (kBtu) IAEC--FFC (kBtu)
---------------------------------------------------------------
Standard level Built-in/ Built-in/
Free-standing slide-in Free-standing slide-in
----------------------------------------------------------------------------------------------------------------
Baseline........................................ 2,083.1 2,093.0 2,332 2,343
1............................................... 2,052.5 2,062.4 2,297 2,308
2............................................... 1,849.9 1,858.8 2,071 2,081
3............................................... 1,754.6 1,763.1 1,964 1,973
4............................................... 1,736.8 1,745.1 1,944 1,953
5............................................... 1,665.7 1,673.7 1,864 1,873
6............................................... 1,654.9 1,662.9 1,852 1,861
----------------------------------------------------------------------------------------------------------------
Table IV.46--Conventional Gas Self-Clean Ovens: FFC Equivalent of IAEC
----------------------------------------------------------------------------------------------------------------
IAEC--Site (kBtu) IAEC--FFC (kBtu)
---------------------------------------------------------------
Standard level Built-in/ Built-in/
Free-standing slide-in Free-standing slide-in
----------------------------------------------------------------------------------------------------------------
Baseline........................................ 1,959.6 1,969.6 2,193 2,204
1............................................... 1,929.0 1,939.0 2,159 2,170
2............................................... 1,740.5 1,749.4 1,948 1,958
3............................................... 1,664.5 1,673.0 1,863 1,873
4............................................... 1,658.9 1,667.4 1,857 1,866
----------------------------------------------------------------------------------------------------------------
The National Propane Gas Association (NPGA) commented that DOE uses
FFC to project the energy savings and energy consumption of ovens under
the proposed standards, but DOE also employs a separate methodology
exclusively to forecast savings for electricity, which seems to double
estimates of electricity savings. NPGA stated that DOE's primary energy
savings calculations are in addition to FFC energy savings. Therefore,
electricity receives two energy savings estimates: That of primary
energy savings calculations and FFC energy savings calculations. (NPGA,
No. 35 at p. 3)
The estimated primary energy savings from energy conservation
standards are not in addition to the FFC savings. DOE continues to
report primary energy savings because this is a metric that has been
familiar to stakeholders. However, DOE regards FFC energy savings as
providing a more complete picture of the impacts of potential
standards.
3. Net Present Value of Customer Benefit
The inputs for determining the NPV of the total costs and benefits
experienced by consumers are: (1) Total annual installed cost; (2)
total annual operating costs; and (3) a discount factor to calculate
the present value of costs and savings. DOE calculates the lifetime net
savings for equipment shipped each year as the difference between the
no-new-standards case and each standards case in total savings in
lifetime operating costs and total increases in
[[Page 60833]]
installed costs. DOE calculates lifetime operating cost savings over
the life of each considered conventional cooking products shipped
during the forecast period.
a. Total Annual Installed Cost
The total installed cost includes both the equipment price and the
installation cost. For each product class, DOE calculated equipment
prices by efficiency level using manufacturer selling prices and
weighted-average overall markup values. Because DOE calculated the
total installed cost as a function of equipment efficiency, it was able
to determine annual total installed costs based on the annual shipment-
weighted efficiency levels determined in the shipments model. DOE
accounted for the repair and maintenance costs associated with typical
repairs in cooking products.
As noted in section IV.F.1 of this SNOPR, DOE assumed a declining
trend in the conventional cooking product prices over the analysis
period. In addition, DOE conducted sensitivity analyses using
alternative price trends: one in which the rate of decline in prices is
greater than the reference trend, and one in which the rate of decline
is lower. These price trends, and the NPV results from the associated
sensitivity cases, are described in appendix 10B of the SNOPR TSD.
b. Total Annual Operating Cost Savings
The per-unit energy savings were derived as described in section
IV.H.2 of this SNOPR. To calculate future electricity and natural gas
prices, DOE applied the projected trend in national-average residential
electricity and natural gas prices from the AEO 2015 Reference case,
which extends to 2040, to the prices derived in the LCC and PBP
analysis. DOE used the trend from 2025 to 2040 to extrapolate beyond
2040.
In addition, DOE analyzed scenarios that used the energy price
projections in the AEO 2015 Low Economic Growth and High Economic
Growth cases. These cases have higher and lower energy price trends
compared to the Reference case. These price trends, and the NPV results
from the associated cases, are described in appendix 10C of the SNOPR
TSD.
In calculating the NPV, DOE multiplies the net dollar savings in
future years by a discount factor to determine their present value. DOE
estimates the NPV using both a 3-percent and a 7-percent real discount
rate in accordance with guidance provided by the OMB to Federal
agencies on the development of regulatory analysis.\64\ The discount
rates for the determination of NPV are in contrast to the discount
rates used in the LCC analysis, which are designed to reflect a
consumer's perspective. The 7-percent real value is an estimate of the
average before-tax rate of return to private capital in the U.S.
economy. The 3-percent real value represents the ``social rate of time
preference,'' which is the rate at which society discounts future
consumption flows to their present value.
---------------------------------------------------------------------------
\64\ U.S. Office of Management and Budget, ``Circular A-4:
Regulatory Analysis,'' Section E, (Sept. 17, 2003) (Available at:
http://www.whitehouse.gov/omb/circulars_a004_a-4/).
---------------------------------------------------------------------------
I. Consumer Subgroup Analysis
In analyzing the potential impact of new or amended standards on
individual consumers, DOE evaluates the impact on identifiable
subgroups of consumers that may be disproportionately affected by a
national standard level. The purpose of a subgroup analysis is to
determine the extent of any such disproportional impacts. DOE evaluates
impacts on particular subgroups of consumers by analyzing the LCC
impacts and PBP for those particular consumers from alternative
standard levels. For this SNOPR, DOE used RECS 2009 data to analyze the
potential effect of standards for residential cooking products on two
consumer subgroups: (1) Households with low income levels, and (2)
households comprised of seniors. DOE used the LCC and PBP spreadsheet
model to estimate the impacts of the considered efficiency levels on
these subgroups.
More details on the consumer subgroup analysis can be found in
chapter 11 of the SNOPR TSD accompanying this SNOPR.
J. Manufacturer Impact Analysis
1. Overview
DOE conducted an MIA for residential conventional cooking products
to estimate the financial impact of new and amended energy conservation
standards on manufacturers of these products. The MIA has both
quantitative and qualitative aspects. The quantitative part of the MIA
relies on the GRIM, an industry cash-flow model customized for
residential conventional cooking products covered in this rulemaking.
The key GRIM inputs are data on the industry cost structure,
manufacturer production costs, shipments, and assumptions about
manufacturer markups and conversion costs. The key MIA output is INPV.
DOE used the GRIM to calculate cash flows using standard accounting
principles and to compare changes in INPV between a no-new-standards
case and various TSLs in the standards cases. The difference in INPV
between the no-new-standards and standards cases represent the
financial impact of new and amended energy conservation standards on
residential conventional cooking product manufacturers. Different sets
of assumptions (scenarios) produce different INPV results. The
qualitative part of the MIA addresses factors such as manufacturing
capacity; characteristics of, and impacts on, any particular subgroup
of manufacturers; and impacts on competition.
DOE conducted the MIA for this rulemaking in three phases. In the
first phase DOE prepared an industry characterization based on the
market and technology assessment, as well as publicly available
information. In the second phase, DOE developed an interview guide
based on the industry financial parameters derived in the first phase.
In the third phase, DOE conducted interviews with a variety of
residential conventional cooking product manufacturers, all of whom
accounted for more than 85 percent of domestic residential conventional
cooking product sales covered by this rulemaking. During these
interviews, DOE discussed engineering, manufacturing, procurement, and
financial topics specific to each company and obtained each
manufacturer's view of the residential conventional cooking product
industry as a whole. The interviews provided information that DOE used
to evaluate the impacts of new and amended standards on manufacturers'
cash flows, manufacturing capacities, and direct domestic manufacturing
employment levels. Section V.B.2 of this SNOPR contains a discussion on
the estimated changes in the number of domestic employees involved in
manufacturing residential conventional cooking products covered by the
proposed standards. Section IV.J.4 of this SNOPR contains a description
of the key issues manufacturers raised during the interviews.
During the third phase, DOE also used the results of the industry
characterization analysis in the first phase and feedback from
manufacturer interviews to group together manufacturers that exhibit
similar production and cost structure characteristics. DOE identified
two manufacturer subgroups for a separate impact analysis--small
business manufacturers and commercial-style manufacturers.
[[Page 60834]]
Small business manufacturers are defined by the Small Business
Administration (SBA) for this particular industry as having less than
1,500 total employees. This threshold includes all employees in a
business' parent company and any other subsidiaries. Based on this
classification, DOE identified nine residential conventional cooking
product manufacturers that qualify as small businesses. Commercial-
style manufacturers are defined as manufacturers primarily selling
residential gas cooking products that are marketed as commercial-style.
DOE identified five commercial-style manufacturers primarily selling
commercial-style cooking products covered by this rulemaking. The
impacts on the small business manufacturer subgroup are discussed in
greater detail in section VI.B of this SNOPR and the impacts on the
commercial-style manufacturer subgroup are discussed in greater detail
in section V.B.2.d of this SNOPR.
2. GRIM Analysis and Key Inputs
DOE uses the GRIM to quantify the changes in cash flows over time
due to new and amended energy conservation standards. These changes in
cash flows result in either a higher or lower INPV for the standards
cases compared to a case where new and amended standards have not been
set (no-new-standards case). The GRIM analysis uses a standard annual
cash flow analysis that incorporates manufacturer costs, manufacturer
markups, industry shipments, and industry financial information as
inputs. It then models changes in manufacturer production costs,
manufacturer investments, and manufacturer margins that result from new
and amended standards. The GRIM uses these inputs to calculate a series
of annual cash flows beginning with the reference year of the analysis,
2016, and continuing to 2048. DOE computes INPV by summing the stream
of annual discounted cash flows during the analysis period. DOE used a
real discount rate of 9.1 percent for residential conventional cooking
product manufacturers. The discount rate estimates were derived from
industry corporate annual reports to the Securities and Exchange
Commission (SEC 10-Ks). During manufacturer interviews residential
conventional cooking product manufacturers were asked to provide
feedback on this discount rate. Most manufacturers agreed that a
discount rate of 9.1 was appropriate to use for residential
conventional cooking product manufacturers. Many inputs into the GRIM
came from the engineering analysis, the shipment analysis, manufacturer
interviews, and other research conducted during the MIA. The major GRIM
inputs are described in detail in the following sections.
a. Capital and Product Conversion Costs
DOE expects new and amended energy conservation standards for
residential conventional cooking products to cause manufacturers to
incur conversion costs to bring their production facilities and product
designs into compliance with the new and amended standards. For the
MIA, DOE classified these conversion costs into two major groups: (1)
Capital conversion costs, and (2) product conversion costs. Capital
conversion costs are investments in property, plant, and equipment
necessary to adapt or change existing production facilities such that
new product designs can be fabricated and assembled. Product conversion
costs are investments in research, development, testing, marketing,
certification, and other non-capitalized costs necessary to make
product designs comply with new and amended standards.
Using feedback from manufacturer interviews, DOE conducted a top-
down analysis to calculate the capital and product conversion costs for
residential conventional cooking product manufacturers. DOE asked
manufacturers during interviews to estimate the total capital and
product conversion costs they would need to incur to be able to produce
each residential conventional cooking product at specific efficiency
levels. DOE then summed these values provided by manufacturers to
arrive at total top-down industry conversion cost for residential
conventional cooking products.
See chapter 12 of the SNOPR TSD for a complete description of DOE's
assumptions for the capital and product conversion costs.
b. Manufacturer Production Costs
Manufacturing more efficient residential conventional cooking
products is typically more expensive than manufacturing baseline
products due to the need for more costly materials and components. The
higher MPCs for these more efficient products can affect the revenue,
gross margin, and the cash flows of residential conventional cooking
product manufacturers. DOE developed MPCs for each representative unit
at each efficiency level analyzed. DOE purchased a number of units from
each product class, then tested and tore down those units to create a
unique bill of materials for the purchased unit. Using the bill of
materials for each residential conventional cooking product, DOE was
able to create an aggregated MPC based on the material costs from the
bill of materials; the labor costs based on an average labor rate and
the labor hours necessary to manufacture the residential conventional
cooking products; and the overhead costs, including depreciation, based
on a markup applied to the material and labor costs based on the
materials used. For more information about MPCs, see section IV.C of
this SNOPR.
c. Shipment Scenarios
INPV, the key GRIM output, depends on industry revenue, which
depends on the quantity and prices of residential conventional cooking
products shipped in each year of the analysis period. Industry revenue
calculations require forecasts of: (1) The total annual shipment volume
of residential conventional cooking products; (2) the distribution of
shipments across product classes (because prices vary by product
class); and (3) the distribution of shipments across efficiency levels
(because prices vary with efficiency).
For the no-new-standards case scenario of the shipment analysis,
DOE develops shipment projections based on historical data and an
analysis of key market drivers. In the standards cases, DOE modeled a
roll-up scenario. The roll-up scenario represents the case in which all
shipments in the no-new-standards case that do not meet the new and
amended standards are redesigned to now meet the new and amended
standards levels, but do not exceed the new and amended standards
levels. Also, no shipments that meet or exceed the new and amended
standards have an increase in efficiency due to the new and amended
standards.
For a complete description of the shipments used in the no-new-
standards case and standards cases see the shipments analysis
discussion in section IV.G of this SNOPR.
d. Markup Scenarios
As discussed in the manufacturer production costs section
previously, the MPCs for each of the product classes of residential
conventional cooking products are the manufacturers' factory costs for
those units. These costs include materials, direct labor, depreciation,
and overhead, which are collectively referred to as the cost of goods
sold (COGS). The MSP is the price received by residential conventional
cooking product manufacturers from their customers, typically retail
outlets, regardless of the
[[Page 60835]]
downstream distribution channel through which the residential
conventional cooking products are ultimately sold. The MSP is not the
cost the end-user pays for residential conventional cooking products
because there are typically multiple sales along the distribution chain
and various markups applied to each sale. The MSP equals the MPC
multiplied by the manufacturer markup. The manufacturer markup covers
all the residential conventional cooking product manufacturer's non-
production costs (i.e., selling, general and administrative expenses
(SG&A), research and development (R&D), and interest, etc.) as well as
profit. Total industry revenue for residential conventional cooking
product manufacturers equals the MSPs at each efficiency level for each
product class multiplied by the number of shipments at each efficiency
level for each product class.
Modifying these manufacturer markups in the standards cases yields
a different set of impacts on residential conventional cooking product
manufacturers than in the no-new-standards case. For the MIA, DOE
modeled two standards case markup scenarios for residential
conventional cooking products to represent the uncertainty regarding
the potential impacts on prices and profitability for residential
conventional cooking product manufacturers following the implementation
of new and amended energy conservation standards. The two scenarios
are: (1) A preservation of gross margin markup scenario and (2) a
preservation of operating profit markup scenario. Each scenario leads
to different manufacturer markup values, which, when applied to the
inputted MPCs, result in varying revenue and cash flow impacts on
residential conventional cooking product manufacturers.
The preservation of gross margin markup scenario assumes that the
COGS for each residential conventional cooking product is marked up by
a flat percentage to cover SG&A expenses, R&D expenses, interest
expenses, and profit. This allows manufacturers to preserve the same
gross margin percentage in the standards cases as in the no-new-
standards case throughout the entire analysis period. This markup
scenario represents the upper bound of the residential conventional
cooking product industry profitability in the standards cases because
residential conventional cooking product manufacturers are able to
fully pass through additional costs due to standards to their
consumers.
To derive the preservation of gross margin markup percentages for
residential conventional cooking products, DOE examined the SEC 10-Ks
of all publicly traded residential conventional cooking product
manufacturers to estimate the industry average gross margin percentage.
DOE estimated that the manufacturer markup is 1.20 for all residential
conventional cooking products. Manufacturers were then asked about this
industry gross margin percentage derived from SEC 10-Ks during
interviews. Residential conventional cooking product manufacturers
agreed that the 1.20 average industry gross margin calculated from SEC
10-Ks was an appropriate estimate to use in the MIA. DOE seeks comment
on the use of 1.20 as a manufacturer markup for all residential
conventional cooking products.
DOE included an alternative markup scenario, the preservation of
operating profit markup scenario, because manufacturers stated they do
not expect to be able to markup the full cost of production in the
standards cases, given the highly competitive residential conventional
cooking product market. The preservation of operating profit markup
scenario assumes that manufacturers are able to maintain only the no-
new-standards case total operating profit in absolute dollars in the
standards cases, despite higher production costs and investment. The
no-new-standards case total operating profit is derived from marking up
the COGS by the preservation of gross margin markup previously
described. In the standards cases for the preservation of operating
profit markup scenario, DOE adjusted the residential conventional
cooking product manufacturer markups in the GRIM at each TSL to yield
approximately the same earnings before interest and taxes in the
standards cases in the year after the compliance date of the new and
amended standards as in the no-new-standards case. Under this scenario
manufacturers are not able to earn additional operating profit on
higher per unit production costs and increased capital and product
investments required to comply with new and amended energy conservation
standards. However, they are able to maintain the same operating profit
in absolute dollars in the standards cases that was earned in the no-
new-standards case.
The preservation of operating profit markup scenario represents the
lower bound of industry profitability in the standards cases. This is
because manufacturers are not able to fully pass through the additional
costs necessitated by new and amended energy conservation standards, as
they are able to do in the preservation of gross margin markup
scenario. Therefore, manufacturers earn less revenue in the
preservation of operating profit markup scenario than they do in the
preservation of gross margin markup scenario.
3. Discussion of Comments
The February 2014 RFI for residential conventional cooking products
did not focus on the MIA or specifically address any issues relating to
the MIA. Therefore, DOE did not receive any MIA-specific comments from
this February 2014 RFI. However, during the July 2015 NOPR public
meeting for residential conventional ovens, interested parties
commented on the assumptions and results of the residential
conventional ovens NOPR. These issues included, test procedure, safety
requirements, and the cumulative regulatory burden placed on
manufacturers.
a. Test Procedure
AHAM commented that DOE's recent practice of amending the test
procedure parallel to proposing amended standards increases the burden
on manufacturers of residential conventional cooking products in
responding to DOE's proposed rules. When the rulemakings are parallel
to each other, it is difficult to comment on the proposed energy
conservation standard because the test procedure is not yet finalized.
(AHAM, No. 38 at p. 10) DOE has considered these comments as part of
this rulemaking and notes that this SNOPR provides additional
opportunity for interested parties to provide comment based on the
proposed cooking product test procedure discussed in section III.C.
b. Safety Requirements
Manufacturers expressed concern that the new safety requirements,
UL 858 and Canadian Standards Association (CSA) C22.2.61 ``Household
Cooking Ranges,'' for conventional cooking products would consume a
significant amount of human and capital resources until 2018, which
would cause a strain on resources needed for the implementation of
energy conservation standards. It was suggested that the effective date
of standards be shifted to allow manufacturers first to meet safety
standards and then focus their limited resources on meeting the new and
amended energy conservation standards. (Whirlpool, No. 33 at p. 4, 5,
and 7; Electrolux, No. 27 at p. 5) DOE
[[Page 60836]]
understands manufacturers must comply with several regulations,
including UL 858 and CSA C22.2.61, and included this in analyzing
impacts of the proposed standard on manufacturers in the cumulative
regulatory burden section, section V.B.2.e of this SNOPR. DOE
understands manufacturers have limited resources, however DOE feels
that setting an effective date at the end of 2019 balances the benefits
and costs associated with this rulemaking.
c. Cumulative Regulatory Burden
Several manufacturers noted the regulatory burden that numerous
regulations will have on manufacturers. The regulatory burden of new
safety requirements, UL 858 and CSA C22.2.61; DOE energy conservation
standards on other home appliances; and the dual investments for
adopting oven and cooking top standards are a concern amongst
manufacturers. Manufacturers stated that DOE should also consider
additional products that manufacturers of residential conventional
cooking products make, which are also subject to potential DOE energy
conservation standards. This places further cumulative regulatory
burden on time and resources needed to evaluate and respond to both
test procedures and energy conservation standards. (Whirlpool, No. 33
at p. 4 and 7; Electrolux, No. 27 at p. 5; AHAM, No. 38 at p. 10) DOE
analyzed cumulative regulatory burden, V.B.2.e, and included this in
analyzing impacts of the proposed standard on manufacturers.
4. Manufacturer Interviews
DOE conducted manufacturer interviews following publication of the
February 2014 RFI in preparation for the June 2015 NOPR analysis. In
these interviews, DOE asked manufacturers to describe their major
concerns with this residential conventional cooking products
rulemaking. The following section describes the key issues identified
by residential conventional cooking product manufacturers during these
interviews. DOE conducted additional discussions with select
manufacturers to follow up on information received on the June 2015
NOPR, but those discussions focused primarily on the engineering
analysis.
a. Premium Products Tend To Be Less Efficient
Manufacturers stated that their premium products (i.e., gas cooking
tops and ovens marketed as commercial-style) are usually less efficient
than products marketed as residential-style. Commercial-style cooking
tops typically have less efficient features such as larger cast iron
grates that act as an additional thermal load. Also, this style of gas
cooking top typically has a wider gap between the burner and grate
surface, further reducing the efficiency of the cooking top.
Conversely, gas cooking tops marketed as residential-style tend to have
inner, lower grates so the cooking vessels resting on them are closer
to the heat sources. Commercial-style ovens typically have large,
heavier-gauge cavity construction and extension racks that result in
inherently lower efficiencies compared to residential-style ovens with
comparable cavities sizes, due to the greater thermal mass of the
cavity and racks, when measured according to the DOE test procedure in
effect at the time of the interviews. Manufacturers warned DOE that
focusing only on the efficiency of residential conventional cooking
products could cause some manufacturers to redesign their products in a
way that reduces consumer satisfaction as consumers tend to value
premium features, even though they may be less efficient.
b. Induction Cooking Products
Some manufacturers stated that induction cooking tops should be
considered as a separate product class apart from electric smooth
cooking tops. Manufacturers stated that while induction cooking tops
tends to be more efficient that other electric smooth cooking tops,
induction cooking tops could require consumers to replace some or all
of their cookware if they are not ferromagnetic.
c. Product Utility
Manufacturers stated that energy efficiency is not one of the most
important attributes that consumers value when purchasing residential
conventional cooking products. Manufacturers stated that there are
several other factors, such as performance and durability, which
consumers value more when purchasing residential conventional cooking
products. Forcing manufacturers to improve the efficiency of their
products could lead to some manufacturers removing premium features
that consumers desire from their products, reducing overall consumer
utility.
d. Testing and Certification Burdens
Several manufacturers expressed concern about the testing and
recertification costs associated with new and amended energy
conservation standards for residential conventional cooking products.
Because testing and certification costs are incurred on a per model
basis, if a large number of models are required to be redesigned to
meet new and amended standards, manufacturers would be forced to spend
a significant amount of money testing and certifying products that were
redesigned due to new and amended standards. Manufacturers stated that
these testing and certification costs associated with residential
conventional cooking products could significantly strain their limited
resources if these costs were all incurred in the 3-year time frame
from the publication of a final rule to the implementation of the new
and amended standards.
K. Emissions Analysis
The emissions analysis consists of two components. The first
component estimates the effect of potential energy conservation
standards on power sector and site (where applicable) combustion
emissions of CO2, NOX, SO2, and Hg.
The second component estimates the impacts of potential standards on
emissions of two additional greenhouse gases, CH4 and
N2O, as well as the reductions to emissions of all species
due to ``upstream'' activities in the fuel production chain. These
upstream activities comprise extraction, processing, and transporting
fuels to the site of combustion. The associated emissions are referred
to as upstream emissions.
The analysis of power sector emissions uses marginal emissions
factors that were derived from data in AEO 2015, as described in
section IV.M of this SNOPR. The methodology is described in chapter 13
and chapter 15 of the SNOPR TSD.
Combustion emissions of CH4 and N2O are
estimated using emissions intensity factors published by the EPA, GHG
Emissions Factors Hub.\65\ The FFC upstream emissions are estimated
based on the methodology described in chapter 15 of the SNOPR TSD. The
upstream emissions include both emissions from fuel combustion during
extraction, processing, and transportation of fuel, and ``fugitive''
emissions (direct leakage to the atmosphere) of CH4 and
CO2.
---------------------------------------------------------------------------
\65\ Available at: http://www2.epa.gov/climateleadership/center-corporate-climate-leadership-ghg-emission-factors-hub.
---------------------------------------------------------------------------
The emissions intensity factors are expressed in terms of physical
units per MWh or MMBtu of site energy savings. Total emissions
reductions are estimated using the energy savings calculated in the
national impact analysis.
[[Page 60837]]
For CH4 and N2O, DOE calculated emissions
reduction in tons and also in terms of units of carbon dioxide
equivalent (CO2eq). Gases are converted to CO2eq
by multiplying each ton of gas by the gas' global warming potential
(GWP) over a 100-year time horizon. Based on the Fifth Assessment
Report of the Intergovernmental Panel on Climate Change,\66\ DOE used
GWP values of 28 for CH4 and 265 for N2O.
---------------------------------------------------------------------------
\66\ IPCC, 2013: Climate Change 2013: The Physical Science
Basis. Contribution of Working Group I to the Fifth Assessment
Report of the Intergovernmental Panel on Climate Change [Stocker,
T.F., D. Qin, G.-K. Plattner, M. Tignor, S.K. Allen, J. Boschung, A.
Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.)]. Cambridge
University Press, Cambridge, United Kingdom and New York, NY, USA.
Chapter 8.
---------------------------------------------------------------------------
Because the on-site operation of gas cooking tops requires use of
fossil fuels and results in emissions of CO2,
NOX, and SO2 at the sites where these appliances
are used, DOE also accounted for the reduction in these site emissions
and the associated upstream emissions due to potential standards. Site
emissions were estimated using emissions intensity factors from an EPA
publication.\67\
---------------------------------------------------------------------------
\67\ U.S. Environmental Protection Agency, Compilation of Air
Pollutant Emission Factors, AP-42, Fifth Edition, Volume I:
Stationary Point and Area Sources (1998) (Available at: http://www.epa.gov/ttn/chief/ap42/index.html).
---------------------------------------------------------------------------
The AEO incorporates the projected impacts of existing air quality
regulations on emissions. AEO 2015 generally represents current
legislation and environmental regulations, including recent government
actions, for which implementing regulations were available as of
October 31, 2015. DOE's estimation of impacts accounts for the presence
of the emissions control programs discussed in the following
paragraphs.
SO2 emissions from affected electric generating units
(EGUs) are subject to nationwide and regional emissions cap-and-trade
programs. Title IV of the Clean Air Act sets an annual emissions cap on
SO2 for affected EGUs in the 48 contiguous States and the
District of Columbia (DC). (42 U.S.C. 7651 et seq.) SO2
emissions from 28 eastern States and DC were also limited under the
Clean Air Interstate Rule (CAIR). 70 FR 25162 (May 12, 2005). CAIR
created an allowance-based trading program that operates along with the
Title IV program. In 2008, CAIR was remanded to EPA by the U.S. Court
of Appeals for the District of Columbia Circuit, but it remained in
effect.\68\ In 2011, EPA issued a replacement for CAIR, the Cross-State
Air Pollution Rule (CSAPR). 76 FR 48208 (August 8, 2011). On August 21,
2012, the D.C. Circuit issued a decision to vacate CSAPR,\69\ and the
court ordered EPA to continue administering CAIR. On April 29, 2014,
the U.S. Supreme Court reversed the judgment of the D.C. Circuit and
remanded the case for further proceedings consistent with the Supreme
Court's opinion.\70\ On October 23, 2014, the D.C. Circuit lifted the
stay of CSAPR.\71\ Pursuant to this action, CSAPR went into effect (and
CAIR ceased to be in effect) as of January 1, 2015.
---------------------------------------------------------------------------
\68\ See North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008);
North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 2008).
\69\ See EME Homer City Generation, LP v. EPA, 696 F.3d 7, 38
(D.C. Cir. 2012), cert. granted, 81 U.S.L.W. 3567, 81 U.S.L.W. 3696,
81 U.S.L.W. 3702 (U.S. June 24, 2013) (No. 12-1182).
\70\ See EPA v. EME Homer City Generation, 134 S. Ct. 1584, 1610
(U.S. 2014). The Supreme Court held in part that EPA's methodology
for quantifying emissions that must be eliminated in certain States
due to their impacts in other downwind States was based on a
permissible, workable, and equitable interpretation of the Clean Air
Act provision that provides statutory authority for CSAPR.
\71\ See Georgia v. EPA, Order (D.C. Cir. filed October 23,
2014) (No. 11-1302),
---------------------------------------------------------------------------
EIA was not able to incorporate CSAPR into AEO 2015, so it assumes
implementation of CAIR. Although DOE's analysis used emissions factors
that assume that CAIR, not CSAPR, is the regulation in force, the
difference between CAIR and CSAPR is not relevant for the purpose of
DOE's analysis of emissions impacts from energy conservation standards.
The attainment of emissions caps is typically flexible among EGUs
and is enforced through the use of emissions allowances and tradable
permits. Under existing EPA regulations, any excess SO2
emissions allowances resulting from the lower electricity demand caused
by the adoption of an efficiency standard could be used to permit
offsetting increases in SO2 emissions by any regulated EGU.
In past rulemakings, DOE recognized that there was uncertainty about
the effects of efficiency standards on SO2 emissions covered
by the existing cap-and-trade system, but it concluded that negligible
reductions in power sector SO2 emissions would occur as a
result of standards.
Beginning in 2016, however, SO2 emissions will fall as a
result of the Mercury and Air Toxics Standards (MATS) for power plants.
77 FR 9304 (Feb. 16, 2012). In the MATS rule, EPA established a
standard for hydrogen chloride as a surrogate for acid gas hazardous
air pollutants (HAP), and also established a standard for
SO2 (a non-HAP acid gas) as an alternative equivalent
surrogate standard for acid gas HAP. The same controls are used to
reduce HAP and non-HAP acid gas; thus, SO2 emissions will be
reduced as a result of the control technologies installed on coal-fired
power plants to comply with the MATS requirements for acid gas. AEO
2015 assumes that, in order to continue operating, coal plants must
have either flue gas desulfurization or dry sorbent injection systems
installed by 2016. Both technologies, which are used to reduce acid gas
emissions, also reduce SO2 emissions. Under the MATS,
emissions will be far below the cap established by CAIR, so it is
unlikely that excess SO2 emissions allowances resulting from
the lower electricity demand would be needed or used to permit
offsetting increases in SO2 emissions by any regulated
EGU.\72\ Therefore, DOE believes that energy conservation standards
will generally reduce SO2 emissions in 2016 and beyond.
---------------------------------------------------------------------------
\72\ DOE notes that the Supreme Court remanded EPA's 2012 rule
regarding national emission standards for hazardous air pollutants
from certain electric utility steam generating units. See Michigan
v. EPA (Case No. 14-46, 2015). DOE has tentatively determined that
the remand of the MATS rule does not change the assumptions
regarding the impact of energy efficiency standards on
SO2 emissions. Further, while the remand of the MATS rule
may have an impact on the overall amount of mercury emitted by power
plants, it does not change the impact of the energy efficiency
standards on mercury emissions. DOE will continue to monitor
developments related to this case and respond to them as
appropriate.
---------------------------------------------------------------------------
CAIR established a cap on NOX emissions in 28 eastern
States and the District of Columbia.\73\ Energy conservation standards
are expected to have little effect on NOX emissions in those
States covered by CAIR because excess NOX emissions
allowances resulting from the lower electricity demand could be used to
permit offsetting increases in NOX emissions from other
facilities. However, standards would be expected to reduce
NOX emissions in the States not affected by the caps, so DOE
estimated NOX emissions reductions from the standards
considered in this SNOPR for these States.
---------------------------------------------------------------------------
\73\ As stated previously, the current analysis assumes that
CAIR, not CSAPR, is the regulation in force. The difference between
CAIR and CSAPR with regard to DOE's analysis of NOX
emissions is slight.
---------------------------------------------------------------------------
The MATS limit mercury emissions from power plants, but they do not
include emissions caps and, as such, DOE's energy conservation
standards would likely reduce Hg emissions. DOE estimated mercury
emissions reduction using emissions factors based on AEO 2015, which
incorporates the MATS.
EEI commented that DOE's general approach to the long-term
assessment of the impacts of energy conservation
[[Page 60838]]
standards on electricity usage and the related upstream emissions from
the power sector is flawed due to their failure to address significant
and expected changes in the power sector that will change demand for
electricity and the composition of the generating fleet through the
period that is covered by the life of a new residential cooking
product. EEI also commented that this focus on existing regulations
results in predictions about the future composition of the electric
generating fleet and the related emissions from that fleet that are
unlikely to be borne out by actual experience. (EEI, No. 30 at p. 4)
DOE believes it would be inappropriate to use projections of the
power sector that attempt to incorporate regulations that have not been
finalized. The final shape of a regulation affects its impacts on the
power sector and is not certain until the regulation has become
effective.\74\
---------------------------------------------------------------------------
\74\ In many cases, newly-issued regulations face challenge in
the courts, the outcome of which is uncertain. However, DOE believes
that it is reasonable to include the impacts of regulations that
have already been issued.
---------------------------------------------------------------------------
L. Monetizing Carbon Dioxide and Other Emissions Impacts
As part of the development of this proposed rule, DOE considered
the estimated monetary benefits from the reduced emissions of
CO2 and NOX that are expected to result from each
of the TSLs considered. In order to make this calculation similar to
the calculation of the NPV of consumer benefit, DOE considered the
reduced emissions expected to result over the lifetime of equipment
shipped in the forecast period for each TSL. This section summarizes
the basis for the monetary values used for each of these emissions and
presents the values considered in this SNOPR.
1. Social Cost of Carbon
The SCC is an estimate of the monetized damages associated with an
incremental increase in carbon emissions in a given year. It is
intended to include (but is not limited to) changes in net agricultural
productivity, human health, property damages from increased flood risk,
and the value of ecosystem services. Estimates of the SCC are provided
in dollars per metric ton of carbon dioxide. A domestic SCC value is
meant to reflect the value of damages in the United States resulting
from a unit change in carbon dioxide emissions, while a global SCC
value is meant to reflect the value of damages worldwide.
Under section 1(b)(6) of Executive Order 12866, ``Regulatory
Planning and Review,'' 58 FR 51735 (Oct. 4, 1993), agencies must, to
the extent permitted by law, assess both the costs and the benefits of
the intended regulation and, recognizing that some costs and benefits
are difficult to quantify, propose or adopt a regulation only upon a
reasoned determination that the benefits of the intended regulation
justify its costs. The purpose of the SCC estimates presented here is
to allow agencies to incorporate the monetized social benefits of
reducing CO2 emissions into cost-benefit analyses of
regulatory actions. The estimates are presented with an acknowledgement
of the many uncertainties involved and with a clear understanding that
they should be updated over time to reflect increasing knowledge of the
science and economics of climate impacts.
As part of the interagency process that developed the SCC
estimates, technical experts from numerous agencies met on a regular
basis to consider public comments, explore the technical literature in
relevant fields, and discuss key model inputs and assumptions. The main
objective of this process was to develop a range of SCC values using a
defensible set of input assumptions grounded in the existing scientific
and economic literatures. In this way, key uncertainties and model
differences transparently and consistently inform the range of SCC
estimates used in the rulemaking process.
a. Monetizing Carbon Dioxide Emissions
When attempting to assess the incremental economic impacts of
carbon dioxide emissions, the analyst faces a number of challenges. A
report from the National Research Council points out that any
assessment will suffer from uncertainty, speculation, and lack of
information about: (1) Future emissions of greenhouse gases; (2) the
effects of past and future emissions on the climate system; (3) the
impact of changes in climate on the physical and biological
environment; and (4) the translation of these environmental impacts
into economic damages.\75\ As a result, any effort to quantify and
monetize the harms associated with climate change will raise serious
questions of science, economics, and ethics and should be viewed as
provisional.
---------------------------------------------------------------------------
\75\ National Research Council. Hidden Costs of Energy: Unpriced
Consequences of Energy Production and Use. National Academies Press:
Washington, DC (2009).
---------------------------------------------------------------------------
Despite the limits of both quantification and monetization, SCC
estimates can be useful in estimating the social benefits of reducing
carbon dioxide emissions. The agency can estimate the benefits from
reduced (or costs from increased) emissions in any future year by
multiplying the change in emissions in that year by the SCC values
appropriate for that year. The NPV of the benefits can then be
calculated by multiplying each of these future benefits by an
appropriate discount factor and summing across all affected years.
It is important to emphasize that the interagency process is
committed to updating these estimates as the science and economic
understanding of climate change and its impacts on society improves
over time. In the meantime, the interagency group will continue to
explore the issues raised by this analysis and consider public comments
as part of the ongoing interagency process.
b. Development of Social Cost of Carbon Values
In 2009, an interagency process was initiated to offer a
preliminary assessment of how best to quantify the benefits from
reducing carbon dioxide emissions. To ensure consistency in how
benefits are evaluated across Federal agencies, the Administration
sought to develop a transparent and defensible method, specifically
designed for the rulemaking process, to quantify avoided climate change
damages from reduced CO2 emissions. The interagency group
did not undertake any original analysis. Instead, it combined SCC
estimates from the existing literature to use as interim values until a
more comprehensive analysis could be conducted. The outcome of the
preliminary assessment by the interagency group was a set of five
interim values: global SCC estimates for 2007 (in 2006$) of $55, $33,
$19, $10, and $5 per metric ton of CO2. These interim values
represented the first sustained interagency effort within the U.S.
government to develop an SCC for use in regulatory analysis. The
results of this preliminary effort were presented in several proposed
and final rules.
c. Current Approach and Key Assumptions
After the release of the interim values, the interagency group
reconvened on a regular basis to generate improved SCC estimates.
Specifically, the group considered public comments and further explored
the technical literature in relevant fields. The interagency group
relied on three integrated assessment models commonly used to estimate
the SCC: The FUND, DICE, and PAGE models. These models are frequently
cited in the peer-reviewed literature and were used in the last
assessment of the Intergovernmental Panel on Climate
[[Page 60839]]
Change (IPCC). Each model was given equal weight in the SCC values that
were developed.
Each model takes a slightly different approach to model how changes
in emissions result in changes in economic damages. A key objective of
the interagency process was to enable a consistent exploration of the
three models while respecting the different approaches to quantifying
damages taken by the key modelers in the field. An extensive review of
the literature was conducted to select three sets of input parameters
for these models: Climate sensitivity, socio-economic and emissions
trajectories, and discount rates. A probability distribution for
climate sensitivity was specified as an input into all three models. In
addition, the interagency group used a range of scenarios for the
socio-economic parameters and a range of values for the discount rate.
All other model features were left unchanged, relying on the model
developers' best estimates and judgments.
In 2010, the interagency group selected four sets of SCC values for
use in regulatory analyses.\76\ Three sets of values are based on the
average SCC from three integrated assessment models, at discount rates
of 2.5 percent, 3 percent, and 5 percent. The fourth set, which
represents the 95th-percentile SCC estimate across all three models at
a 3-percent discount rate, is included to represent higher-than-
expected impacts from climate change further out in the tails of the
SCC distribution. The values grow in real terms over time.
Additionally, the interagency group determined that a range of values
from 7 percent to 23 percent should be used to adjust the global SCC to
calculate domestic effects,\77\ although preference is given to
consideration of the global benefits of reducing CO2
emissions. Table IV.47 presents the values in the 2010 interagency
group report, which is reproduced in appendix 14A of the SNOPR TSD.
---------------------------------------------------------------------------
\76\ Social Cost of Carbon for Regulatory Impact Analysis Under
Executive Order 12866. Interagency Working Group on Social Cost of
Carbon, United States Government (February 2010) (Available at:
http://www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-for-RIA.pdf.).
\77\ It is recognized that this calculation for domestic values
is approximate, provisional, and highly speculative. There is no a
priori reason why domestic benefits should be a constant fraction of
net global damages over time.
Table IV.47--Annual SCC Values From 2010 Interagency Report, 2010-2050
[2007$ per metric ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount rate (%)
---------------------------------------------------------------
5 3 2.5 3
Year ---------------------------------------------------------------
95th
Average Average Average Percentile
----------------------------------------------------------------------------------------------------------------
2010............................................ 4.7 21.4 35.1 64.9
2015............................................ 5.7 23.8 38.4 72.8
2020............................................ 6.8 26.3 41.7 80.7
2025............................................ 8.2 29.6 45.9 90.4
2030............................................ 9.7 32.8 50.0 100.0
2035............................................ 11.2 36.0 54.2 109.7
2040............................................ 12.7 39.2 58.4 119.3
2045............................................ 14.2 42.1 61.7 127.8
2050............................................ 15.7 44.9 65.0 136.2
----------------------------------------------------------------------------------------------------------------
The SCC values used for this SNOPR were generated using the most
recent versions of the three integrated assessment models that have
been published in the peer-reviewed literature.\78\ Table IV.48 shows
the updated sets of SCC estimates from the 2013 interagency update in
5-year increments from 2010 to 2050. Appendix 14B of the SNOPR TSD
provides the full set of values. The central value that emerges is the
average SCC across models at 3-percent discount rate. However, for
purposes of capturing the uncertainties involved in regulatory impact
analysis, the interagency group emphasizes the importance of including
all four sets of SCC values.
---------------------------------------------------------------------------
\78\ Technical Update of the Social Cost of Carbon for
Regulatory Impact Analysis Under Executive Order 12866. Interagency
Working Group on Social Cost of Carbon, United States Government
(May 2013; revised July 2015) (Available at: http://www.whitehouse.gov/sites/default/files/omb/inforeg/scc-tsd-final-july-2015.pdf).
Table IV.48--Annual SCC Values From 2013 Interagency Update (Revised July 2015), 2010-2050
[2007$ per metric ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount rate (%)
---------------------------------------------------------------
5 3 2.5 3
Year ---------------------------------------------------------------
95th
Average Average Average Percentile
----------------------------------------------------------------------------------------------------------------
2010............................................ 10 31 50 86
2015............................................ 11 36 56 105
2020............................................ 12 42 62 123
2025............................................ 14 46 68 138
2030............................................ 16 50 73 152
2035............................................ 18 55 78 168
2040............................................ 21 60 84 183
2045............................................ 23 64 89 197
2050............................................ 26 69 95 212
----------------------------------------------------------------------------------------------------------------
[[Page 60840]]
AHAM suggested that DOE rely on the 2010 estimates for SCC until it
has resolved all comments on the derivation of the SCC estimates from
the 2013 report. DOE notes that the 2013 report provides an update of
the SCC estimates based solely on the latest peer-reviewed version of
the models, replacing model versions that were developed up to 10 years
ago in a rapidly evolving field. It does not revisit other assumptions
with regard to the discount rate, reference case socio-economic and
emission scenarios, or equilibrium climate sensitivity. Improvements in
the way damages are modeled are confined to those that have been
incorporated into the latest versions of the models by the developers
themselves in the peer-reviewed literature. Given the above, using the
2010 estimates would be inconsistent with DOE's objective of using the
best available information in its analyses.
It is important to recognize that a number of key uncertainties
remain, and that current SCC estimates should be treated as provisional
and revisable since they will evolve with improved scientific and
economic understanding. The interagency group also recognizes that the
existing models are imperfect and incomplete. The National Research
Council report mentioned above points out that there is tension between
the goal of producing quantified estimates of the economic damages from
an incremental ton of carbon and the limits of existing efforts to
model these effects. There are a number of analytical challenges that
are being addressed by the research community, including research
programs housed in many of the Federal agencies participating in the
interagency process to estimate the SCC. The interagency group intends
to periodically review and revise those estimates to reflect increasing
knowledge of the science and economics of climate impacts, as well as
improvements in modeling.
In summary, in considering the potential global benefits resulting
from reduced CO2 emissions, DOE used the values from the
2013 interagency report (revised July 2015), adjusted to 2015$ using
the implicit price deflator for gross domestic product (GDP) from the
Bureau of Economic Analysis. For each of the four sets of SCC cases
specified, the values for emissions in 2015 were $12.4, $40.6, $63.2,
and $118 per metric ton avoided (values expressed in 2015$). DOE
derived values after 2050 using the relevant growth rates for the 2040-
2050 period in the interagency update.
DOE multiplied the CO2 emissions reduction estimated for
each year by the SCC value for that year in each of the four cases. To
calculate a present value of the stream of monetary values, DOE
discounted the values in each of the four cases using the specific
discount rate that had been used to obtain the SCC values in each case.
The Cato Institute stated that the SCC is not supported by
scientific literature, not in accordance with OMB guidelines, fraught
with uncertainty, illogical and thus unsuitable and inappropriate for
Federal rulemaking. The comment emphasized that the SCC is discordant
with the best scientific literature on the equilibrium climate
sensitivity and the fertilization effect of carbon dioxide. Further,
the estimates should make a clear distinction between global and
domestic cost-benefit estimates and delineate the potential positive
impact on agriculture. The Cato Institute argued that use of the SCC in
cost/benefit analyses in this rulemaking should be suspended. (Cato
Institute, No. 24 at pp. 3, 13) NPGA also commented on the issue of a
clear distinction between global and domestic cost-benefit estimates.
(NPGA, No. 35 at p. 2)
DOE acknowledges the limitations of the SCC estimates, which are
discussed in detail in the 2010 Report. Specifically, the 2010 Report
discusses and explains the reasons for uncertainties in the assumptions
regarding climate sensitivity, as well as other model inputs such as
economic growth and emissions trajectories.\79\ The three integrated
assessment models used to estimate the SCC are frequently cited in the
peer-reviewed literature and were used in the last assessment of the
IPCC. In addition, new versions of the models that were used in 2013 to
estimate revised SCC values were published in the peer-reviewed
literature (see appendix 14B of the final rule TSD for discussion).
Although uncertainties remain, the revised estimates in the 2013 Report
are based on the best available scientific information on the impacts
of climate change. The current SCC estimates have been developed over
many years, using the best science available, and with input from the
public. In November 2013, OMB announced a new opportunity for public
comment on the interagency technical support document underlying the
revised SCC estimates. 78 FR 70586. In July 2015 OMB published a
detailed summary and formal response to the many comments that were
received.\80\ It also stated its intention to seek independent expert
advice on opportunities to improve the estimates, including many of the
approaches suggested by commenters. DOE stands ready to work with OMB
and the other members of the interagency working group on further
review and revision of the SCC estimates as appropriate.
---------------------------------------------------------------------------
\79\ Interagency Working Group on Social Cost of Carbon, Social
Cost of Carbon for Regulatory Impact Analysis Under Executive Order
12866 (2010), Available at http://www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-for-RIA.pdf.
\80\ This is available at https://www.whitehouse.gov/blog/2015/07/02/estimating-benefits-carbon-dioxide-emissions-reductions.
---------------------------------------------------------------------------
With respect to distinguishing between global and domestic benefits
from reducing CO2 emissions, DOE's analysis estimates both
global and domestic benefits of CO2 emissions reductions.
Following the recommendation of the interagency working group, DOE
places more focus on a global measure of SCC. As discussed in appendix
14A of the SNOPR TSD, the climate change problem is highly unusual in
at least two respects. First, it involves a global externality:
Emissions of most greenhouse gases contribute to damages around the
world even when they are emitted in the United States. Consequently, to
address the global nature of the problem, the SCC must incorporate the
full (global) damages caused by GHG emissions. Second, climate change
presents a problem that the United States alone cannot solve. Even if
the United States were to reduce its greenhouse gas emissions to zero,
that step would be far from enough to avoid substantial climate change.
Other countries would also need to take action to reduce emissions if
significant changes in the global climate are to be avoided.
Emphasizing the need for a global solution to a global problem, the
United States has been actively involved in seeking international
agreements to reduce emissions and in encouraging other nations,
including emerging major economies, to take significant steps to reduce
emissions. When these considerations are taken as a whole, the
interagency group concluded that a global measure of the benefits from
reducing U.S. emissions is preferable.
2. Social Cost of Other Air Pollutants
As noted previously, DOE has estimated how the considered energy
conservation standards would reduce site NOX emissions
nationwide and decrease power sector NOX emissions in those
22 States not affected by the CAIR.
DOE estimated the monetized value of NOX emissions
reductions from electricity generation using benefit per ton estimates
from the Regulatory Impact Analysis for the Clean Power
[[Page 60841]]
Plan Final Rule, published in August 2015 by EPA's Office of Air
Quality Planning and Standards.\81\ The report includes high and low
values for NOX (as PM2.5) for 2020, 2025, and
2030 discounted at 3 percent and 7 percent, which are presented in
chapter 14 of the SNOPR TSD. DOE primarily relied on the low estimates
to be conservative.\82\ DOE assigned values for 2021-2024 and 2026-2029
using, respectively, the values for 2020 and 2025. DOE assigned values
after 2030 using the value for 2030. DOE developed values specific to
the end-use category for cooking products using a method described in
appendix 14C of the NOPR TSD.
---------------------------------------------------------------------------
\81\ Available at www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis. See Tables 4A-3, 4A-4, and
4A-5 in the report. The U.S. Supreme Court has stayed the rule
implementing the Clean Power Plan until the current litigation
against it concludes. Chamber of Commerce, et al. v. EPA, et al.,
Order in Pending Case, 577 U.S. __ (2016). However, the benefit-per-
ton estimates established in the Regulatory Impact Analysis for the
Clean Power Plan are based on scientific studies that remain valid
irrespective of the legal status of the Clean Power Plan.
\82\ For the monetized NOX benefits associated with
PM2.5, the related benefits are primarily based on an
estimate of premature mortality derived from the ACS study (Krewski
et al., 2009), which is the lower of the two EPA central tendencies.
Using the lower value is more conservative when making the policy
decision concerning whether a particular standard level is
economically justified so using the higher value would also be
justified. If the benefit-per-ton estimates were based on the Six
Cities study (Lepuele et al., 2012), the values would be nearly two-
and-a-half times larger. (See chapter 14 of the SNOPR TSD for
further description of the studies mentioned above.)
---------------------------------------------------------------------------
DOE estimated the monetized value of NOX emissions
reductions from combustion in homes using benefit per ton estimates
from the EPA's Technical Support Document Estimating the Benefit per
Ton of Reducing PM2.5 Precursors from 17 Sectors.\83\ Although none of
the sectors refers specifically to residential and commercial
buildings, DOE believes that the sector called ``Area sources'' would
be a reasonable proxy for residential and commercial buildings. ``Area
sources'' represents all emission sources for which states do not have
exact (point) locations in their emissions inventories. Since exact
locations would tend to be associated with larger sources, ``area
sources'' would be fairly representative of small dispersed sources
like homes and businesses. The Technical Support Document provides high
and low estimates for 2016, 2020, 2025, and 2030 at 3-percent and 7-
percent discount rates. As with the benefit per ton estimates for
NOX emissions reductions from electricity generation, DOE
primarily relied on the low estimates to be conservative.
---------------------------------------------------------------------------
\83\ http://www.epa.gov/sites/production/files/2014-10/documents/sourceapportionmentbpttsd.pdf.
---------------------------------------------------------------------------
DOE multiplied the emissions reduction (in tons) in each year by
the associated $/ton values, and then discounted each series using
discount rates of 3 percent and 7 percent as appropriate. DOE will
continue to evaluate the monetization of avoided NOX
emissions and will make any appropriate updates of the current analysis
for the final rulemaking.
DOE is evaluating appropriate monetization of avoided
SO2 and Hg emissions in energy conservation standards
rulemakings. It has not included monetization of these emissions in the
current analysis.
M. Utility Impact Analysis
The utility impact analysis estimates several effects on the
electric power industry that would result from the adoption of new or
amended energy conservation standards. The utility impact analysis
estimates the changes in installed electrical capacity and generation
that would result for each TSL. The analysis is based on published
output from the NEMS associated with AEO 2015. NEMS produces the AEO
Reference case, as well as a number of side cases that estimate the
economy-wide impacts of changes to energy supply and demand. DOE uses
published side cases to estimate the marginal impacts of reduced energy
demand on the utility sector. These marginal factors are estimated
based on the changes to electricity sector generation, installed
capacity, fuel consumption and emissions in the AEO Reference case and
various side cases. Details of the methodology are provided in the
appendices to chapters 13 and 15 of the SNOPR TSD.
The output of this analysis is a set of time-dependent coefficients
that capture the change in electricity generation, primary fuel
consumption, installed capacity and power sector emissions due to a
unit reduction in demand for a given end use. These coefficients are
multiplied by the stream of electricity savings calculated in the NIA
to provide estimates of selected utility impacts of new or amended
energy conservation standards.
N. Employment Impact Analysis
Employment impacts from new or amended energy conservation
standards include direct and indirect impacts. Direct employment
impacts are any changes in the number of employees of manufacturers of
the equipment subject to standards; the MIA addresses those impacts.
Indirect employment impacts are changes in national employment that
occur due to the shift in expenditures and capital investment caused by
the purchase and operation of more efficient equipment. Indirect
employment impacts from standards consist of the jobs created or
eliminated in the national economy, other than in the manufacturing
sector being regulated, due to: (1) Reduced spending by end users on
energy; (2) reduced spending on new energy supply by the utility
industry; (3) increased consumer spending on the purchase of new
equipment; and (4) the effects of those three factors throughout the
economy.
One method for assessing the possible effects on the demand for
labor of such shifts in economic activity is to compare sector
employment statistics developed by the Labor Department's Bureau of
Labor Statistics (BLS). BLS regularly publishes its estimates of the
number of jobs per million dollars of economic activity in different
sectors of the economy, as well as the jobs created elsewhere in the
economy by this same economic activity. Data from BLS indicate that
expenditures in the utility sector generally create fewer jobs (both
directly and indirectly) than expenditures in other sectors of the
economy.\84\ There are many reasons for these differences, including
wage differences and the fact that the utility sector is more capital-
intensive and less labor-intensive than other sectors. Energy
conservation standards have the effect of reducing consumer utility
bills. Because reduced consumer expenditures for energy likely lead to
increased expenditures in other sectors of the economy, the general
effect of efficiency standards is to shift economic activity from a
less labor-intensive sector (i.e., the utility sector) to more labor-
intensive sectors (e.g., the retail and service sectors). Thus, the BLS
data suggest that net national employment may increase because of
shifts in economic activity resulting from amended standards.
---------------------------------------------------------------------------
\84\ See U.S. Department of Commerce--Bureau of Economic
Analysis. Regional Multipliers: A User Handbook for the Regional
Input-Output Modeling System (RIMS II). 1997. U.S. Government
Printing Office: Washington, DC. Available at http://www.bea.gov/scb/pdf/regional/perinc/meth/rims2.pdf.
---------------------------------------------------------------------------
DOE estimated indirect national employment impacts for the standard
levels considered in this SNOPR using an input/output model of the U.S.
economy called Impact of Sector Energy Technologies, Version 3.1.1
(ImSET).\85\
[[Page 60842]]
ImSET is a special-purpose version of the ``U.S. Benchmark National
Input-Output'' (I-O) model, which was designed to estimate the national
employment and income effects of energy-saving technologies. The ImSET
software includes a computer-based I-O model having structural
coefficients that characterize economic flows among the 187 sectors
most relevant to industrial, commercial, and residential building
energy use.
---------------------------------------------------------------------------
\85\ M.J. Scott, O.V. Livingston, P.J. Balducci, J.M. Roop, and
R.W. Schultz, ImSET 3.1: Impact of Sector Energy Technologies, PNNL-
18412, Pacific Northwest National Laboratory (2009) (Available at:
www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf).
---------------------------------------------------------------------------
DOE notes that ImSET is not a general equilibrium forecasting
model, and understands the uncertainties involved in projecting
employment impacts, especially changes in the later years of the
analysis. Because ImSET does not incorporate price changes, the
employment effects predicted by ImSET may over-estimate actual job
impacts over the long run. Therefore, DOE generated results for near-
term timeframes, where these uncertainties are reduced. For more
details on the employment impact analysis, see chapter 16 of the SNOPR
TSD.
V. Analytical Results
The following section addresses the results from DOE's analyses
with respect to potential energy conservation standards for
conventional cooking products. It addresses the TSLs examined by DOE
and the projected impacts of each of these levels if adopted as energy
conservation standards for conventional cooking products. Additional
details regarding DOE's analyses are contained in the SNOPR TSD
supporting this SNOPR.
A. Trial Standard Levels
DOE analyzed the benefits and burdens of four TSLs for conventional
cooking products. These TSLs were developed by combining specific
efficiency levels for each of the product classes analyzed by DOE. DOE
presents the results for the TSLs in this document, while the results
for all efficiency levels that DOE analyzed are in the SNOPR TSD.
Table V.1 through Table V.3 present the TSLs and the corresponding
efficiency levels for conventional cooking products.\86\ TSL 4
represents the maximum technologically feasible (``max-tech'')
improvements in energy efficiency for all product classes. TSL 3
comprises efficiency levels providing maximum NES with positive NPV.
TSL 2 includes the prescriptive standards for conventional ovens
control design and represents a level between TSL 1 and TSL 3 that does
not eliminate commercial-style cooking tops from the market and yields
an NPV greater than TSL 1. TSL 1 was configured with a control strategy
approach with maximum NES.
---------------------------------------------------------------------------
\86\ For the conventional oven product classes, the efficiency
levels are based on an oven with a cavity volume of 4.3 ft\3\. As
discussed in section IV.C.3 of this notice, DOE developed slopes and
intercepts to characterize the relationship between IEAC and cavity
volume for each efficiency level.
Table V.1--Trial Standard Levels for Cooking Tops
--------------------------------------------------------------------------------------------------------------------------------------------------------
Electric open (coil) element cooking Electric smooth element Gas cooking tops
tops cooking tops ----------------------------------------
TSL --------------------------------------------------------------------------
Efficiency Efficiency level IAEC (kWh/yr)
Efficiency level IAEC (kWh/yr) level IAEC (kWh/yr)
--------------------------------------------------------------------------------------------------------------------------------------------------------
1.................................... Baseline................ 118.1 2 121.2 Baseline............... 1,104.6
2.................................... 1....................... 113.2 2 121.2 1...................... 924.4
3.................................... 1....................... 113.2 2 121.2 3...................... 730.4
4.................................... 1....................... 113.2 4 102.3 3...................... 730.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.2--Trial Standard Levels for Ovens, Electric
--------------------------------------------------------------------------------------------------------------------------------------------------------
Electric standard ovens, Electric standard ovens, Electric self-cleaning Electric self-cleaning
free-standing built-in/slide-in ovens, free-standing ovens, built-in/slide-in
TSL -------------------------------------------------------------------------------------------------------
Efficiency IAEC (kWh/ Efficiency IAEC (kWh/ Efficiency IAEC (kWh/ Efficiency IAEC (kWh/
level yr) level yr) level yr) level yr)
--------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................... 1 306.3 1 313.3 1 346.0 1 353.0
2............................................... 1 306.3 1 313.3 1 346.0 1 353.0
3............................................... 4 274.0 4 280.3 1 346.0 1 353.0
4............................................... 7 222.2 7 227.2 4 278.5 4 284.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.3--Trial Standard Levels for Ovens, Gas
--------------------------------------------------------------------------------------------------------------------------------------------------------
Gas standard ovens, free- Gas standard ovens, Gas self-clean ovens, Gas self-clean ovens,
standing built-in/slide-in free-standing built-in/slide-in
TSL -------------------------------------------------------------------------------------------------------
Efficiency IAEC (kWh/ Efficiency IAEC (kWh/ Efficiency IAEC (kWh/ Efficiency IAEC (kWh/
level yr) level yr) level yr) level yr)
--------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................... 1 2,052.5 1 2,062.4 1 1,929.0 1 1,939.0
2............................................... 2 1,849.9 2 1,858.8 2 1,740.5 2 1,749.4
3............................................... 6 1,654.9 6 1,662.9 4 1,658.9 4 1,667.4
4............................................... 6 1,654.9 6 1,662.9 4 1,658.9 4 1,667.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 60843]]
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
DOE analyzed the economic impacts on conventional cooking products
consumers by looking at the effects potential amended standards would
have on the LCC and PBP. DOE also examined the impacts of potential
standards on consumer subgroups. These analyses are discussed below.
a. Life-Cycle Cost and Payback Period
In general, higher-efficiency products affect consumers in two
ways: (1) Purchase price increases, and (2) operating costs decrease.
Inputs used for calculating the LCC and PBP include total installed
costs (i.e., product price plus installation costs), and operating
costs (i.e., annual energy savings, energy prices, energy price trends,
repair costs, and maintenance costs). The LCC calculation also uses
product lifetime and a discount rate. Chapter 8 of the SNOPR TSD
provides detailed information on the LCC and PBP analyses.
Table V.4 through Table V.25 show the LCC and PBP results for all
efficiency levels considered for each conventional cooking product
class. In the first of each pair of tables, the simple payback is
measured relative to the baseline product. In the second table, the LCC
savings are measured relative to the no-new-standards case efficiency
distribution in the compliance year (see section IV.F.9 of this SNOPR).
Because some consumers purchase products with higher efficiency in the
no-new-standards case, the average savings are less than the difference
between the average LCC of the lowest-efficiency level and the average
LCC at each TSL. The savings refer only to consumers who are affected
by a standard at a given TSL. Those who already purchase a product with
efficiency at or above a given TSL are not affected. Consumers for whom
the LCC increases at a given TSL experience a net cost.
Table V.4--Average LCC and PBP Results by Efficiency Level for PC1 Electric Open (Coil) Element Cooking Tops
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs 2015$
---------------------------------------------------------------- Simple payback
TSL Efficiency level First year's Lifetime years
Installed cost operating cost operating cost LCC
--------------------------------------------------------------------------------------------------------------------------------------------------------
1......................................... Baseline.................... $253 $16 $337 $590 ..............
2,3,4..................................... 1........................... 256 15 329 585 0.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.5--Average LCC Savings Relative to the No-New-Standards Case Efficiency Distribution for PC1 Electric
Open (Coil) Element Cooking Tops
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
---------------------------------------
TSL Efficiency level % of Consumers Average savings*
that -----------------------
experience Net cost 2015$
----------------------------------------------------------------------------------------------------------- -------
1.......................................... Baseline...................... 0 $0.00
2,3,4...................................... 1............................. 19 2.87
----------------------------------------------------------------------------------------------------------------
* The calculation includes households with zero LCC savings (no impact).
Table V.6--Average LCC and PBP Results by Efficiency Level for PC2 Electric Smooth Element Cooking Tops
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs 2015$
---------------------------------------------------------------- Simple payback
TSL Efficiency level First year's Lifetime years
Installed cost operating cost operating cost LCC
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,2,3..................................... 2........................... $483 $16 $343 $825 1.0
4......................................... 4........................... 835 14 312 1,146 61.9
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.7--Average LCC Savings Relative to the No-New-Standards Case Efficiency Distribution for PC2 Electric
Smooth Element Cooking Tops
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
---------------------------------------
TSL Efficiency level % of Consumers Average savings*
that -----------------------
experience Net cost 2015$
----------------------------------------------------------------------------------------------------------- -------
1,2,3...................................... 2............................. 0 $24.37
[[Page 60844]]
4.......................................... 4............................. 98 (280.82)
----------------------------------------------------------------------------------------------------------------
* The calculation includes households with zero LCC savings (no impact).
Table V.8--Average LCC and PBP Results by Efficiency Level for PC3 Gas Cooking Tops
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs 2015$
---------------------------------------------------------------- Simple payback
TSL Efficiency level First year's Lifetime years
Installed cost operating cost operating cost LCC
--------------------------------------------------------------------------------------------------------------------------------------------------------
1......................................... Baseline.................... $345 $12 $266 $611 --
2......................................... 1........................... 361 10 246 607 9.1
3,4....................................... 3........................... 361 8 225 586 4.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.9--Average LCC Savings Relative to the No-New-Standards Case Efficiency Distribution for PC3 Gas Cooking
Tops
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
---------------------------------------
TSL Efficiency level % of Consumers Average savings*
that -----------------------
experience Net cost 2015$
----------------------------------------------------------------------------------------------------------- -------
1.......................................... Baseline...................... 0 $0.00
2.......................................... 1............................. 14 1.10
3,4........................................ 3............................. 6 15.83
----------------------------------------------------------------------------------------------------------------
*The calculation includes households with zero LCC savings (no impact).
Table V.10--Average LCC and PBP Results by Efficiency Level for PC4 Electric Standard Ovens, Free-Standing
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs 2015$
---------------------------------------------------------------- Simple payback
TSL Efficiency level First year's Lifetime years
Installed cost operating cost operating cost LCC
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,2....................................... 1........................... $557 $17 $386 $942 0.9
3......................................... 4........................... 569 16 364 934 4.7
4......................................... 7........................... 652 13 332 984 17.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.11--Average LCC Savings Relative to the No-New-Standards Case Efficiency Distribution for PC4 Electric
Standard Ovens, Free-Standing
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
---------------------------------------
TSL Efficiency level % of Consumers Average savings*
that -----------------------
experience Net cost 2015$
----------------------------------------------------------------------------------------------------------- -------
1,2........................................ 1............................. 0 $5.93
3.......................................... 4............................. 20 10.23
4.......................................... 7............................. 80 (30.82)
----------------------------------------------------------------------------------------------------------------
*The calculation includes households with zero LCC savings (no impact).
[[Page 60845]]
Table V.12--Average LCC and PBP Results by Efficiency Level for PC5 Electric Standard Ovens, Built-In/Slide-In
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs 2015$
---------------------------------------------------------------- Simple payback
TSL Efficiency level First year's Lifetime years
Installed cost operating cost operating cost LCC
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,2....................................... 1........................... $583 $17 $386 $968 0.9
3......................................... 4........................... 596 16 364 960 4.7
4......................................... 7........................... 678 13 332 1,010 17.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.13--Average LCC Savings Relative to the No-New-Standards Case Efficiency Distribution for PC5 Electric
Standard Ovens, Built-In/Slide-In
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-------------------------------
% of Consumers Average
TSL Efficiency level that savings*
experience ---------------
----------------
Net cost 2015$
----------------------------------------------------------------------------------------------------------------
1,2........................................... 1............................... 0 $5.96
3............................................. 4............................... 20 10.23
4............................................. 7............................... 80 (30.83)
----------------------------------------------------------------------------------------------------------------
* The calculation includes households with zero LCC savings (no impact).
Table V.14--Average LCC and PBP Results by Efficiency Level for PC6 Electric Self-Clean Ovens, Free-Standing
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs 2015$
---------------------------------------------------------------- Simple payback
TSL Efficiency level First year's Lifetime years
Installed cost operating cost operating cost LCC
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,2,3..................................... 1........................... $600 $25 $482 $1,083 0.9
4......................................... 4........................... 684 21 433 1,117 16.2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.15--Average LCC Savings Relative to the No-New-Standards Case Efficiency Distribution for PC6 Electric
Self-Clean Ovens, Free-Standing
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-------------------------------
% of Consumers Average
TSL Efficiency level that savings*
experience ---------------
----------------
Net cost 2015$
----------------------------------------------------------------------------------------------------------------
1,2,3......................................... 1............................... 0 $7.04
4............................................. 4............................... 72 (17.19)
----------------------------------------------------------------------------------------------------------------
* The calculation includes households with zero LCC savings (no impact).
Table V.16--Average LCC and PBP Results by Efficiency Level for PC7 Electric Self-Clean Ovens, Built-In/Slide-In
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs 2015$
---------------------------------------------------------------- Simple payback
TSL Efficiency level First year's Lifetime years
Installed cost operating cost operating cost LCC
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,2,3..................................... 1........................... $626 $25 $484 $1,110 0.9
4......................................... 4........................... 710 21 435 1,145 16.2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
[[Page 60846]]
Table V.17--Average LCC Savings Relative to the No-New-Standards Case Efficiency Distribution for PC7 Electric
Self-Clean Ovens, Built-In/Slide-In
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-------------------------------
% of Consumers Average
TSL Efficiency level that savings*
experience ---------------
----------------
Net cost 2015$
----------------------------------------------------------------------------------------------------------------
1,2,3......................................... 1............................... 0 $7.08
4............................................. 4............................... 72 $17.21)
----------------------------------------------------------------------------------------------------------------
* The calculation includes households with zero LCC savings (no impact).
Table V.18--Average LCC and PBP Results by Efficiency Level for PC8 Gas Standard Ovens, Free-Standing
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs 2015$
---------------------------------------------------------------- Simple payback
TSL Efficiency level First year's Lifetime years
Installed cost operating cost operating cost LCC
--------------------------------------------------------------------------------------------------------------------------------------------------------
1......................................... 1........................... $602 $35 $529 $1,130 0.6
2......................................... 2........................... 611 28 452 1,063 1.1
3,4....................................... 6........................... 655 28 450 1,105 6.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.19--Average LCC Savings Relative to the No-New-Standards Case Efficiency Distribution for PC8 Gas
Standard Ovens, Free-Standing
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-------------------------------
% of Consumers Average
TSL Efficiency level that savings*
experience ---------------
----------------
Net cost 2015$
----------------------------------------------------------------------------------------------------------------
1............................................. 1............................... 0 $7.60
2............................................. 2............................... 0 43.64
3,4........................................... 6............................... 61 9.77
----------------------------------------------------------------------------------------------------------------
* The calculation includes households with zero LCC savings (no impact).
Table V.20--Average LCC and PBP Results by Efficiency Level for PC9 Gas Standard Ovens, Built-In/Slide-In
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs 2015$
---------------------------------------------------------------- Simple payback
TSL Efficiency level First year's Lifetime years
Installed cost operating cost operating cost LCC
--------------------------------------------------------------------------------------------------------------------------------------------------------
1......................................... 1........................... $628 $35 $529 $1,156 0.6
2......................................... 2........................... 637 28 452 1,089 1.1
3,4....................................... 6........................... 681 28 450 1,131 6.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.21--Average LCC Savings Relative to the No-New-Standards Case Efficiency Distribution for PC9 Gas
Standard Ovens, Built-In/Slide-In
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-------------------------------
% of Consumers Average
TSL Efficiency level that savings*
experience ---------------
----------------
Net cost 2015$
----------------------------------------------------------------------------------------------------------------
1............................................. 1............................... 0 $7.60
2............................................. 2............................... 0 43.65
[[Page 60847]]
3,4........................................... 6............................... 61 9.77
----------------------------------------------------------------------------------------------------------------
* The calculation includes households with zero LCC savings (no impact).
Table V.22--Average LCC and PBP Results by Efficiency Level for PC10 Gas Self-Clean Ovens, Free-Standing
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs 2015$
Efficiency ---------------------------------------------------------------- Simple
TSL level First year's Lifetime payback years
Installed cost operating cost operating cost LCC
--------------------------------------------------------------------------------------------------------------------------------------------------------
1....................................................... 1 $716 $38 $559 $1,275 0.7
2....................................................... 2 725 31 484 1,209 1.1
3,4..................................................... 4 760 31 485 1,245 5.3
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.23--Average LCC Savings Relative to the No-New-Standards Case Efficiency Distribution for PC10 Gas Self-
Clean Ovens, Free-Standing
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-------------------------------
% of consumers Average
TSL Efficiency that savings*
level experience ---------------
----------------
Net cost 2015$
----------------------------------------------------------------------------------------------------------------
1............................................................... 1 0 $7.73
2............................................................... 2 0 48.03
3,4............................................................. 4 49 20.27
----------------------------------------------------------------------------------------------------------------
* The calculation includes households with zero LCC savings (no impact).
Table V.24--Average LCC and PBP Results by Efficiency Level for PC11 Gas Self-Clean Ovens, Built-In/Slide-In
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs 2015$
Efficiency ---------------------------------------------------------------- Simple
TSL level First year's Lifetime payback years
Installed cost operating cost operating cost LCC
--------------------------------------------------------------------------------------------------------------------------------------------------------
1....................................................... 1 $742 $38 $559 $1,301 0.7
2....................................................... 2 751 31 484 1,235 1.1
3,4..................................................... 4 786 31 485 1,271 5.3
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V.25--Average LCC Savings Relative to the No-New-Standards Case Efficiency Distribution for PC11 Gas Self-
Clean Ovens, Built-In/Slide-In
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-------------------------------
% of consumers Average
TSL Efficiency that savings*
level experience ---------------
----------------
Net cost 2015$
----------------------------------------------------------------------------------------------------------------
1............................................................... 1 0 $7.73
2............................................................... 2 0 48.05
[[Page 60848]]
3,4............................................................. 4 49 20.27
----------------------------------------------------------------------------------------------------------------
* The calculation includes households with zero LCC savings (no impact).
b. Consumer Subgroup Analysis
As described in section IV.I of this SNOPR, DOE determined the
impact of the considered TSLs on low-income households and senior-only
households. Table V.26 through Table V.36 compare the average LCC
savings and PBP at each efficiency level for the two consumer
subgroups, along with the average LCC savings for the entire sample. In
most cases, the average LCC savings and PBP for low-income households
and senior-only households at the considered efficiency levels are not
substantially different from the average for all households. Chapter 11
of the SNOPR TSD presents the complete LCC and PBP results for the
subgroups.
Table V.26--Comparison of Average LCC Savings for Consumer Subgroups and All Households for PC1 Electric Open (Coil) Element Cooking Tops
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2015$) Simple payback period (years)
-----------------------------------------------------------------------------------------------
TSL Low-income Senior-only Low-income Senior-only
households households All households households households All households
--------------------------------------------------------------------------------------------------------------------------------------------------------
1....................................................... $0.00 $0.00 $0.00 .............. .............. ..............
2,3,4................................................... 2.95 2.66 2.60 0.5 0.5 0.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.27--Comparison of Average LCC Savings for Consumer Subgroups and All Households for PC2 Electric Smooth Element Cooking Tops
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2015$) Simple payback period (years)
-----------------------------------------------------------------------------------------------
TSL Low-income Senior-only Low-income Senior-only
households households All households households households All households
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,2,3................................................... $24.36 $24.72 $24.37 1.0 1.0 1.0
4....................................................... (280.72) (282.11) (282.36) 62.0 62.8 63.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.28--Comparison of Average LCC Savings for Consumer Subgroups and All Households for PC3 Gas Cooking Tops
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2015$) Simple payback period (years)
-----------------------------------------------------------------------------------------------
TSL Low-income Senior-only Low-income Senior-only
households households All households households households All households
--------------------------------------------------------------------------------------------------------------------------------------------------------
1....................................................... $0.00 $0.00 $0.00 .............. .............. ..............
2....................................................... 1.94 0.84 0.83 7.6 9.6 9.6
3,4..................................................... 19.67 15.04 14.82 3.6 4.6 4.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.29--Comparison of Average LCC Savings for Consumer Subgroups and All Households for PC4 Electric Standard Ovens, Free-Standing
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2015$) Simple payback period (years)
-----------------------------------------------------------------------------------------------
TSL Low-income Senior-only Low-income Senior-only
households households All households households households All households
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,2..................................................... $5.94 $6.09 $5.71 0.9 0.9 0.9
3....................................................... 9.77 7.96 11.54 4.7 5.2 4.4
4....................................................... (32.05) (38.77) (24.65) 17.4 20.0 15.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 60849]]
Table V.30--Comparison of Average LCC Savings for Consumer Subgroups and All Households for PC5 Electric Standard Ovens, Built-In/Slide-In
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2015$) Simple payback period (years)
-----------------------------------------------------------------------------------------------
TSL Low-income Senior-only Low-income Senior-only
households households All households households households All households
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,2..................................................... $5.97 $6.12 $5.73 0.9 0.9 0.9
3....................................................... 9.77 7.96 11.59 4.7 5.2 4.4
4....................................................... (32.06) (38.78) (24.58) 17.4 20.0 15.3
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.31--Comparison of Average LCC Savings for Consumer Subgroups and All Households PC6 Electric Self-Cleaning Ovens, Free-Standing
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2015$) Simple payback period (years)
-----------------------------------------------------------------------------------------------
TSL Low-income Senior-only Low-income Senior-only
households households All households households households All households
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,2,3................................................... $6.68 $7.17 $6.83 0.9 0.8 0.9
4....................................................... (10.81) (23.62) (12.86) 14.1 18.8 14.9
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.32--Comparison of Average LCC Savings for Consumer Subgroups and All Households PC7 Electric Self-Cleaning Ovens, Built-In/Slide-In
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2015$) Simple payback period (years)
-----------------------------------------------------------------------------------------------
TSL Low-income Senior-only Low-income Senior-only
households households All households households households All households
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,2,3................................................... $6.73 $7.20 $6.84 0.9 0.8 0.9
4....................................................... (10.83) (23.64) (12.86) 14.1 18.8 14.9
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.33--Comparison of Average LCC Savings for Consumer Subgroups and All Households PC8 Gas Standard Ovens, Free-Standing
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2015$) Simple payback period (years)
-----------------------------------------------------------------------------------------------
TSL Low-income Senior-only Low-income Senior-only
households households All households households households All households
--------------------------------------------------------------------------------------------------------------------------------------------------------
1....................................................... $7.18 $7.41 $7.53 0.7 0.6 0.7
2....................................................... 51.40 38.30 25.11 0.9 1.2 1.8
3,4..................................................... 17.71 4.24 3.86 5.1 6.6 7.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.34--Comparison of Average LCC Savings for Consumer Subgroups and All Households for PC9 Gas Standard Oven, Built-In/Slide-In
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2015$) Simple payback period (years)
-----------------------------------------------------------------------------------------------
TSL Low-income Senior-only Low-income Senior-only
households households All households households households All households
--------------------------------------------------------------------------------------------------------------------------------------------------------
1....................................................... $7.18 $7.41 $7.53 0.7 0.6 0.7
2....................................................... 51.41 38.31 25.14 0.9 1.2 1.8
3,4..................................................... 17.70 4.23 3.87 5.1 6.6 7.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 60850]]
Table V.35--Comparison of Average LCC Savings for Consumer Subgroups and All Households for PC10 Gas Self-Cleaning Ovens, Free-Standing
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2015$) Simple payback period (years)
-----------------------------------------------------------------------------------------------
TSL Low-income Senior-only Low-income Senior-only
households households All households households households All households
--------------------------------------------------------------------------------------------------------------------------------------------------------
1....................................................... $7.50 $7.69 $7.66 0.7 0.7 0.7
2....................................................... 45.86 42.33 26.80 1.2 1.2 1.8
3,4..................................................... 18.15 14.67 1.63 5.3 5.6 8.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.36--Comparison of Average LCC Savings for Consumer Subgroups and All Households for PC11 Gas Self-Cleaning Oven, Built-In/Slide-In
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2015$) Simple payback period (years)
-----------------------------------------------------------------------------------------------
TSL Low-income Senior-only Low-income Senior-only
households households All households households households All households
--------------------------------------------------------------------------------------------------------------------------------------------------------
1....................................................... $7.50 $7.69 $7.66 0.7 0.7 0.7
2....................................................... 45.87 42.34 26.85 1.2 1.2 1.8
3,4..................................................... 18.15 14.67 1.66 5.3 5.6 8.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
c. Rebuttable Presumption Payback
As discussed above, EPCA provides a rebuttable presumption that an
energy conservation standard is economically justified if the increased
purchase cost for a product that meets the standard is less than three
times the value of the first-year energy savings resulting from the
standard. In calculating a rebuttable presumption payback period for
the considered TSLs, DOE used discrete values rather than distributions
for input values, and, as required by EPCA, based the energy use
calculation on the DOE test procedures for conventional cooking
products. In contrast, the PBPs presented in section V.B.1.a of this
SNOPR were calculated using distributions that reflect the range of
energy use in the field.
Table V.37 presents the rebuttable-presumption payback periods for
the considered TSLs. While DOE examined the rebuttable-presumption
criterion, it considered whether the standard levels considered for
this rule are economically justified through a more detailed analysis
of the economic impacts of those levels pursuant to 42 U.S.C.
6295(o)(2)(B)(i). The results of that analysis serve as the basis for
DOE to evaluate the economic justification for a potential standard
level (thereby supporting or rebutting the results of any preliminary
determination of economic justification).
Table V.37--Conventional Cooking Products: Rebuttable PBPs
(years)
----------------------------------------------------------------------------------------------------------------
Trial standard level
Product class ---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
PC1: Electric Open (Coil) Element Cooking Tops.. .............. 4.8 4.8 4.8
PC2: Electric Smooth Element Cooking Tops....... 0.9 0.9 0.9 53.3
PC3: Gas Cooking Tops........................... .............. 8.6 4.1 4.1
PC4: Electric Standard Ovens, Free-Standing..... 0.8 0.8 2.2 6.7
PC5: Electric Standard Ovens, Built-In/Slide-In. 0.8 0.8 2.2 6.6
PC6: Electric Self-Clean Ovens, Free-Standing... 0.8 0.8 0.8 7.1
PC7: Electric Self-Clean Ovens, Built-In/Slide- 0.8 0.8 0.8 7.0
In.............................................
PC8: Gas Standard Ovens, Free-Standing.......... 3.7 4.4 12.9 12.9
PC9: Gas Standard Ovens, Built-In/Slide-In...... 3.7 4.3 12.8 12.8
PC10: Gas Self-Clean Ovens, Free-Standing....... 3.6 4.5 15.0 15.0
PC11: Gas Self-Clean Ovens, Built-In/Slide-In... 3.6 4.5 14.9 14.9
----------------------------------------------------------------------------------------------------------------
2. Economic Impacts on Manufacturers
DOE performed an MIA to estimate the impact of new and amended
energy conservation standards on manufacturers of residential
conventional cooking products. The following sections describe the
expected impacts on residential conventional cooking product
manufacturers at each TSL. Chapter 12 of the SNOPR TSD explains the MIA
in further detail.
a. Industry Cash-Flow Analysis Results
Table V.38 through Table V.39 depict the financial impacts
(represented by changes in INPV) of new and amended energy conservation
standards on residential conventional cooking product manufacturers as
well as the conversion costs that DOE estimates manufacturers would
incur at each TSL. To evaluate the range of cash flow impacts on the
residential conventional cooking product industry, DOE modeled two
markup scenarios that correspond to the range of anticipated market
responses to new and amended standards. Each markup scenario results in
a unique set of cash flows and corresponding industry values at each
TSL.
[[Page 60851]]
In the following discussion, the INPV results refer to the
difference in industry value between the no-new-standards case and the
standards cases that result from the sum of discounted cash flows from
the reference year (2016) through the end of the analysis period. The
results also discuss the difference in cash flows between the no-new-
standards case and the standards cases in the year before the
compliance date for new and amended energy conservation standards. This
figure represents the size of the required conversion costs relative to
the cash flow generated by the residential conventional cooking product
industry in the absence of new and amended energy conservation
standards. In the engineering analysis, DOE enumerates common
technology options that achieve the efficiencies for each of the
product classes. For descriptions of these technology options and the
required efficiencies at each TSL, see section IV.C and section V.A,
respectively, of this SNOPR.
To assess the upper (less severe) end of the range of potential
impacts on residential conventional cooking product manufacturers, DOE
modeled a preservation of gross margin markup scenario. This scenario
assumes that in the standards cases, manufacturers would be able to
pass along all the higher production costs required for more efficient
products to their consumers. Specifically, the industry would be able
to maintain its average no-new-standards case gross margin (as a
percentage of revenue) despite the higher production costs in the
standards cases. In general, the larger the product price increases,
the less likely manufacturers are to achieve the cash flow from
operations calculated in this scenario because it is less likely that
manufacturers would be able to fully mark up these larger production
cost increases.
To assess the lower (more severe) end of the range of potential
impacts on the residential conventional cooking product manufacturers,
DOE modeled the preservation of operating profit markup scenario. This
scenario represents the lower end of the range of potential impacts on
manufacturers because no additional operating profit is earned on the
higher production costs, eroding profit margins as a percentage of
total revenue.
Table V.38 and Table V.39 present the projected results for
residential conventional cooking products under the preservation of
gross margin and preservation of operating profit markup scenarios. DOE
examined results for all product classes together since the majority of
manufacturers sell products across a variety of the analyzed product
classes.
Table V.38--Manufacturer Impact Analysis for Residential Conventional Cooking Products--Preservation of Gross Margin Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units No-new- ---------------------------------------------------------------
standards case 1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... (2015$ millions)............ 1,238.1 1,200.1 1,156.7 868.0 511.1
Change in INPV............................ (2015$ millions)............ .............. (38.0) (81.4) (370.1) (727.1)
(%)......................... .............. (3.1) (6.6) (29.9) (58.7)
Product conversion costs.................. (2015$ millions)............ .............. 19.9 71.3 261.8 525.4
Capital conversion costs.................. (2015$ millions)............ .............. 29.9 47.9 248.2 580.2
Total conversion costs................ (2015$ millions)............ .............. 49.8 119.2 510.0 1,105.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Numbers in parentheses indicate negative numbers.
Table V.39--Manufacturer Impact Analysis for Residential Conventional Cooking Products--Preservation of Operating Profit Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units No-new- ---------------------------------------------------------------
standards case 1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... (2015$ millions)............ 1,238.1 1,198.3 1,148.5 844.7 314.6
Change in INPV............................ (2015$ millions)............ .............. (39.8) (89.6) (393.5) (923.6)
(%)......................... .............. (3.2) (7.2) (31.8) (74.6)
Product conversion costs.................. (2015$ millions)............ .............. 19.9 71.3 261.8 525.4
Capital conversion costs.................. (2015$ millions)............ .............. 29.9 47.9 248.2 580.2
Total conversion costs.................... (2015$ millions)............ .............. 49.8 119.2 510.0 1,105.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
TSL 1 sets the efficiency level at baseline for two product
classes, electric open (coil) element cooking tops and gas cooking
tops; EL 1 for all electric and gas ovens; and EL 2 for one product
class, electric smooth element cooking tops. At TSL 1, DOE estimates
impacts on INPV range from -$39.8 million to -$38.0 million, or a
change in INPV of -3.2 percent to -3.1 percent. At TSL 1, industry free
cash flow (operating cash flow minus capital expenditures) is estimated
to decrease to $83.2 million, or a drop of 19.1 percent, compared to
the no-new-standards case value of $102.8 million in 2018, the year
leading up to new and amended energy conservation standards.
Percentage impacts on INPV are slightly negative at TSL 1. DOE does
not anticipate that manufacturers would lose a significant portion of
their INPV at this TSL, given the limited conversion costs and number
of residential conventional cooking products projected to comply with
the analyzed standards at this TSL. DOE projects that in the expected
year of compliance (2019), 100 percent of electric open (coil) element
cooking top and gas cooking top shipments; 28 percent of electric
smooth element cooking top shipments; 60 percent of electric standard
free standing oven and electric standard built-in oven shipments; 53
percent of electric self-clean free standing oven and electric self-
clean built-in oven shipments; 56 percent of gas standard free standing
oven and gas standard built-in oven shipments; and 52 percent of gas
self-clean free standing oven and gas self-clean built-in oven
shipments would meet or exceed the efficiency levels required at TSL 1.
[[Page 60852]]
DOE expects conversion costs to be small at TSL 1 because the
design changes prescribed at this TSL only affect standby mode power
consumption and do not apply to active mode power consumption. DOE
expects residential conventional cooking product manufacturers would
incur $19.9 million in product conversion costs for product redesigns
that include converting electric smooth cooking tops and both gas and
electric ovens to transition from using linear power supplies to SMPS
in order to reduce standby power consumption; as well as implementing
automatic power down controls for electric smooth cooking tops. DOE
expects $29.9 million in capital conversion costs for manufacturers to
upgrade production lines and retool equipment associated with achieving
this reduction in standby power.
At TSL 1, under the preservation of gross margin markup scenario,
the shipment-weighted average MPC increases very slightly by
approximately 0.2 percent relative to the no-new-standards case MPC.
This extremely slight price increase is significantly outweighed by the
$49.8 million in conversion costs estimated at TSL 1, resulting in
slightly negative INPV impacts at TSL 1 under the preservation of gross
margin markup scenario.
Under the preservation of operating profit markup scenario,
manufacturers earn the same nominal operating profit as would be earned
in the no-new-standards case, but manufacturers do not earn additional
profit from their investments. The very slight increase in the shipment
weighted-average MPC results in a slightly lower average manufacturer
markup (slightly smaller than the 1.20 manufacturer markup used in the
no-new-standards case). This slightly lower average manufacturer markup
and the $49.8 million in conversion costs, results in slightly negative
INPV impacts at TSL 1 under the preservation of operating profit.
TSL 2 sets the efficiency level at EL 1 for six product classes,
electric open (coil) element cooking tops, gas cooking tops, electric
standard free-standing ovens, electric standard built-in ovens,
electric self-clean free-standing ovens, and electric self-clean built-
in ovens; and EL 2 for five product classes, electric smooth element
cooking tops, gas standard free-standing ovens, gas standard built-in
ovens, gas self-clean free-standing ovens, and gas self-clean built-in
ovens. At TSL 2, DOE estimates impacts on INPV to range from -$89.6
million to -$81.4 million, or a change in INPV of -7.2 percent to -6.6
percent. At TSL 2, industry free cash flow is estimated to decrease to
$59.3 million, or a drop of 42.3 percent, compared to the no-new-
standards case value of $102.8 million in 2018, the year leading up to
new and amended energy conservation standards.
Percentage impacts on INPV are moderately negative at TSL 2. While
the $119.2 million in industry conversion costs represent a larger
investment for manufacturers than at TSL 1, DOE does not anticipate
that manufacturers would lose a significant portion of their INPV at
this TSL since the no-new-standards case INPV for manufacturers is more
than $1,238.1 million. DOE projects that in 2019, 33 percent of
electric open (coil) element cooking top shipments; 28 percent of
electric smooth element cooking top shipments; 74 percent of gas
cooking top shipments; 60 percent of electric standard free standing
oven and electric standards built-in oven shipments; 53 percent of
electric self-clean free standing oven and electric self-clean built-in
oven shipments; 46 percent of gas standard free standing oven and gas
standard built-in oven shipments; and 39 percent of gas self-clean free
standing oven and gas self-clean built-in oven shipments would meet or
exceed the efficiency levels required at TSL 2.
DOE expects that product conversion costs will rise from $19.9
million at TSL 1 to $71.3 million at TSL 2 for extensive product
redesigns and testing. Capital conversion costs will also increase from
$29.9 million at TSL 1 to $47.9 million at TSL 2 to upgrade production
equipment to accommodate for added or redesigned features in each
product class. The large conversion costs at TSL 2 are driven by the
need to improve contact conductance for electric open (coil) cooking
tops; transition from using linear power supplies to SMPS to reduce
standby power consumption while also implementing automatic power down
controls for electric smooth cooking tops; improve burner and grate
design for gas cooking tops; transition from using linear power
supplies to SMPS to reduce standby power consumption for electric
ovens; and transition from using linear power supplies to SMPS to
improve power consumption in gas ovens.
At TSL 2, under the preservation of gross margin markup scenario,
the shipment weighted-average MPC only slightly increases by 0.9
percent, relative to the no-new-standards case MPC. In this scenario,
INPV impacts are moderately negative because manufacturers incur larger
conversion costs, $119.2 million, and are not able to recover much of
those conversion costs through the slight increase in the shipment
weighted-average MPC at TSL 2.
Under the preservation of operating profit markup scenario, the 0.9
percent shipment weighted-average increase in MPC results in a slightly
lower average manufacturer markup (slightly smaller than the 1.20
manufacturer markup used in the no-new-standards case). This slightly
lower average manufacturer markup and the $119.2 million in conversion
costs result in moderately negative INPV impacts at TSL 2.
TSL 3 sets the efficiency level at EL 1 for three product classes,
electric open (coil) cooking tops, electric self-clean free-standing
ovens, and electric self-clean built in ovens; EL 2 for one product
class, electric smooth element cooking tops; EL 3 for one product
class, gas cooking tops; EL 4 for four product classes, electric
standard free-standing ovens, electric standard built-in ovens, gas
self-clean free-standing ovens, and gas self-clean built-in ovens; and
EL 6 for two product classes, gas standard free-standing ovens and gas
standard built-in ovens. At TSL 3, DOE estimates impacts on INPV to
range from -$393.5 million to -$370.1 million, or a change in INPV of -
31.8 percent to -29.9 percent. At this standard level, industry free
cash flow is estimated to decrease to -$89.7, or a drop of 187.2
percent, compared to the no-new-standards case value of $102.8 million
in 2018, the year leading up to new and amended energy conservation
standards.
Percentage impacts on INPV are significantly negative at TSL 3. The
$510.0 million in industry conversion costs represent a significant
investment for manufacturers, and is the primary cause of the potential
drop in INPV of up to 31.8 percent and a negative free cash flow in the
year leading up to the new and amended standards. DOE projects that in
2019, 33 percent of electric open (coil) cooking top shipments; 28
percent of electric smooth element cooking top shipments; 13 percent of
gas cooking top shipments; 31 percent of electric standard free
standing oven and electric standard built-in oven shipments; 53 percent
of electric self-clean free standing oven and electric self-clean
built-in oven shipments; 9 percent of gas standard free standing oven
and gas standard built-in oven shipments; and 13 percent of gas self-
cleaning free standing oven and gas self-cleaning built-in oven
shipments would meet or exceed the efficiency levels at TSL 3.
DOE expects that product conversion costs will significantly rise
from $71.3 million at TSL 2 to $261.8 million at
[[Page 60853]]
TSL 3 for extensive product redesigns and testing. Capital conversion
costs will also significantly increase from $47.9 million at TSL 2 to
$248.2 million at TSL 3 to upgrade production equipment to accommodate
for added or redesigned features in each product class. The large
conversion costs at TSL 3 are driven by the need to optimize burners
and grates for gas cooking tops; improve insulation and door seals for
electric standard ovens; electronic spark ignition, improve insulation,
increase the efficiency of door seals, forcing convection, and reducing
convection losses for gas standard ovens; and forcing convection and
reducing convection losses in gas self-clean ovens.
At TSL 3, under the preservation of gross margin markup scenario,
the shipment weighted-average MPC increases by 2.5 percent, relative to
the no-new-standards case MPC. In this scenario, INPV impacts are
negative because manufacturers incur sizable conversion costs ($510.0
million) and are not able to recover much of those conversion costs
through the 2.5 percent increase in the shipment weighted-average MPC
at TSL 3.
Under the preservation of operating profit markup scenario, the 2.5
percent shipment weighted-average increase in MPC results in a slightly
lower average manufacturer markup (1.199, compared to the 1.20
manufacturer markup used in the no-new-standards case). This slightly
lower average manufacturer markup and the $510.0 million in conversion
costs results in significantly negative INPV impacts at TSL 3.
Commercial-style manufacturers, manufacturers producing gas cooking
products that are primarily marketed as commercial-style, would not be
able to meet the standards required at TSL 3. As described in sections
IV.C.3.b and IV.C.5 of this SNOPR, the features inherent to such gas
cooking products would preclude this product configuration from being
able to meet the standards required at TSL 3, and would likely force
commercial-style manufacturers to exit the gas cooking product market.
TSL 4 sets the efficiency level at EL 1 for one product class,
electric open (coil) element cooking tops; EL 3 for one product class,
gas cooking tops; EL 4 for five product classes, electric smooth
element cooking tops, electric self-clean free-standing ovens, electric
self-clean built-in ovens, gas self-clean free-standing ovens, and gas
self-clean built-in ovens; EL 6 for two product classes, gas standard
free-standing ovens and gas standard built-in ovens; and EL 7 for two
product classes, electric standard free-standing ovens and electric
standard built-in ovens. This represents max-tech for all product
classes. At TSL 4, DOE estimates impacts on INPV to range from -$923.6
million to -$727.1 million, or a change in INPV of -74.6 percent to -
58.7 percent. At TSL 4, industry free cash flow is estimated to
decrease to -$340.7 million, or a drop of 431.3 percent, compared to
the no-new-standards case value of $102.8 million in 2018, the year
leading up to new and amended energy conservation standards.
At TSL 4 conversion costs significantly increase, causing free cash
flow to become significantly negative, -$340.7 million, in the year
leading up to energy conservation standards and causing manufacturers
to lose a substantial amount of INPV. Also, the percent change in INPV
at TSL 4 is significantly negative due to the extremely large
conversion costs, $1,105.7 million. Manufacturers at this TSL would
have a very difficult time in the short term to make the necessary
investments to comply with new and amended energy conservation
standards prior to when standards went into effect. Also, the long-term
profitability of residential conventional cooking product manufacturers
could be seriously jeopardized as several manufacturers would struggle
to comply with standards at this TSL, especially the commercial-style
manufacturer subgroup. These manufacturers produce gas cooking products
that are primarily marketed as commercial-style. As described in
sections IV.C.3.b and IV.C.5 of this SNOPR, the features inherent to
such gas cooking products would preclude this product configuration
from being able to meet the standards required at TSL 4, and would
likely force commercial-style manufacturers to exit the gas cooking
product market.
A high percentage of total shipments will need to be redesigned to
meet the efficiency levels prescribed at TSL 4. DOE projects that in
2019, 33 percent of electric open (coil) element cooking top shipments;
3 percent of electric smooth element cooking top shipments; 13 percent
of gas cooking top shipments; 7 percent of electric standard free
standing oven and electric standard built-in oven shipments; 12 percent
of electric self-clean free standing oven and electric self-clean
built-in oven shipments; 9 percent of gas standard free standing oven
and gas standard built-in oven shipments; and 13 percent of gas self-
clean free standing oven and gas self-clean built-in oven shipments
would meet the efficiency levels at TSL 4.
DOE expects significant conversion costs at TSL 4, which represents
max-tech. DOE expects product conversion costs to significantly
increase from $261.8 million at TSL 3 to $525.4 million at TSL 4. Large
increases in product conversion are due to the vast majority of
shipments needing extensive redesign as well as a significant increase
in testing and recertification for redesigned products. DOE estimates
that capital conversion costs will also significantly increase from
$248.2 million at TSL 3 to $580.2 million at TSL 4. Capital conversion
costs are driven by investments in production equipment to accommodate
for the addition of induction heating elements for electric smooth
cooking tops; improved contact conductance for electric open (coil)
element cooking tops; and by optimizing the burner and grate system for
residential-style gas cooking tops; reducing vent rate, improving
insulation and door seals, forcing convection, developing oven
separators, and reducing conduction loses for electric standard ovens;
forcing convection, developing oven separators, and reducing conduction
loses for electric self-clean ovens; electronic spark ignition, improve
insulation, increase the efficiency of door seals, forcing convection,
and reducing convection losses for gas standard ovens; and forcing
convection and reducing conduction losses in gas self-clean ovens. DOE
estimates that most commercial-style manufacturers would not be able to
meet the gas cooking product standards prescribed at TSL 4 and would be
forced to exit the gas cooking product market.
At TSL 4, under the preservation of gross margin markup scenario,
the shipment weighted-average MPC increases by 18.0 percent relative to
the no-new-standards case MPC. In this scenario, INPV impacts are
severely negative because the $1,105.7 million in conversion costs
outweigh the modest increase in shipment weighted-average MPC,
resulting in significantly negative INPV impacts at TSL 4.
Under the preservation of operating profit markup scenario, the
18.0 percent shipment weighted-average increase in MPC results in a
slightly lower average manufacturer markup of 1.192 (compared to 1.20
used in the no-new-standards case). This lower average manufacturer
markup and the $1,105.7 million in conversion costs, results in
significantly negative INPV impacts at TSL 4.
b. Impacts on Employment
DOE quantitatively assessed the impacts of new and amended energy
[[Page 60854]]
conservation standards on direct employment. DOE used the GRIM to
estimate the domestic labor expenditures and number of domestic
production workers in the no-new-standards case and at each TSL from
2019 to 2048. DOE used statistical data from the U.S. Census Bureau's
2014 Annual Survey of Manufactures (ASM), the results of the
engineering analysis, and interviews with manufacturers to determine
the inputs necessary to calculate industry-wide labor expenditures and
domestic employment levels. Labor expenditures involved with the
manufacturing of the products are a function of the labor intensity of
the products, the sales volume, and an assumption that wages remain
fixed in real terms over time.
In the GRIM, DOE used the labor content of the MPCs to estimate the
annual labor expenditures in the industry. DOE used census data and
interviews with manufacturers to estimate the portion of the total
labor expenditures that is attributable to domestic labor.
The production worker estimates in this section cover only workers
up to the line-supervisor level directly involved in fabricating and
assembling a product within a manufacturing facility. Workers
performing services that are closely associated with production
operations, such as material handing with a forklift, are also included
as production labor. DOE's estimates account for production workers who
manufacture only the specific products covered in this rulemaking.
The employment impacts shown in Table V.40 represent the potential
domestic production employment that could result following new and
amended energy conservation standards. The upper bound of the results
estimates the maximum change in the number of production workers that
could occur after compliance with new and amended energy conservation
standards when assuming that manufacturers continue to produce the same
scope of covered products in the same production facilities. It also
assumes that domestic production does not shift to lower labor-cost
countries. Because there is a real risk of manufacturers evaluating
sourcing decisions in response to new and amended energy conservation
standards, the lower bound of the employment results includes DOE's
estimate of the total number of U.S. production workers in the industry
who could lose their jobs if some or all existing domestic production
were moved outside of the United States. While the results present a
range of domestic employment impacts following 2019, the following
sections also include qualitative discussions of the likelihood of
negative employment impacts at the various TSLs. Finally, the direct
employment impacts shown are independent of the employment impacts from
the broader U.S. economy, documented in chapter 17 of the SNOPR TSD.
Using 2014 ASM data and interviews with manufacturers, DOE
estimates that approximately 60 percent of the residential conventional
cooking products sold in the United States are manufactured
domestically. With this assumption, DOE estimates that in the absence
of new and amended energy conservation standards, there would be
approximately 8,663 domestic production workers involved in
manufacturing residential conventional cooking products in 2019. Table
V.40 shows the range of the impacts of new and amended energy
conservation standards on U.S. production workers in the residential
conventional cooking product industry.
Table V.40--Potential Changes in the Total Number of Domestic Residential Conventional Cooking Product
Production Workers in 2019
----------------------------------------------------------------------------------------------------------------
No-New- Trial standard level
Standards ---------------------------------------------------------------
case 1 2 3 4
----------------------------------------------------------------------------------------------------------------
Total Number of Domestic 8,663 8,675 8,724 8,832 9,635
Production Workers in 2019
(without changes in production
locations).....................
Potential Changes in Domestic -- (433)-12 (866)-61 (2,166)-169 (4,332)-972
Production Workers in 2019 \*\.
----------------------------------------------------------------------------------------------------------------
* DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative numbers.
At the upper end of the range, all examined TSLs show a slight
increase in the number of domestic employment for residential
conventional cooking products. DOE believes that manufacturers would
increase production hiring due to the increase in the labor associated
with adding the required components to make residential conventional
cooking products more efficient. However, as previously stated, this
assumes that in addition to hiring more production employees, all
existing domestic production would remain in the United States and not
shift to lower labor-cost countries.
DOE expects any significant changes in domestic employment at TSL 1
to be limited because standards would only affect standby mode power
consumption at this TSL. Most manufacturers stated that this TSL would
not require significant design changes and therefore would not have a
significant impact on domestic employment decisions.
At TSL 2, TSL 3, and TSL 4, all product classes would require
higher efficiency standards and therefore most manufacturers would be
required to make modifications to their existing production lines.
However, manufacturers stated that due to the larger size of most
residential conventional cooking products, very few units are
manufactured and shipped from far distances such as Asia or Europe. The
vast majority of residential conventional cooking products are
currently made in North America. Some manufacturers stated that even
significant changes to production line would not cause them to shift
their production to lower labor-cost countries, as several
manufacturers either only produce residential conventional cooking
products domestically or have recently made significant investments to
continue to produce residential conventional cooking products
domestically. DOE estimates that, at most, 10 percent of the domestic
labor for residential conventional cooking products could move to other
countries in response to the standards proposed at TSL 2.
At TSL 3, manufacturers could alter production locations in
response to standards since all product classes would be required to
meet more stringent standards than at TSL 2. DOE estimated that at most
25 percent of the
[[Page 60855]]
domestic labor for residential conventional cooking products could move
to other countries in response to the standards prescribed at TSL 3.
At TSL 4, manufacturers could alter production locations in
response to standards since all product classes would be required to
meet max-tech. DOE estimated that at most 50 percent of the domestic
labor for residential conventional cooking products could move to other
countries in response to the standards prescribed at TSL 4.
DOE seeks comment on the potential domestic employment impacts to
residential conventional cooking product manufacturers at the proposed
efficiency levels.
c. Impacts on Manufacturer Capacity
Residential conventional cooking product manufacturers stated that
they did not anticipate any capacity constraints at the proposed
standards, TSL 2. Some manufacturers stated that any standard requiring
induction heating technology for all electric smooth element cooking
tops would present a very difficult standard to meet since only around
3 percent of the existing electric smooth element cooking tops use
induction technology. Manufacturers stated that converting 97 percent
of their electric smooth element cooking tops in the 3-year compliance
window would present a significant challenge since the production of
induction heating cooking tops differs significantly from current
cooking top production. However, DOE is not proposing to set efficiency
standards that would require manufacturers to use induction technology.
Therefore, DOE does not anticipate a manufacturer capacity constraint
at TSL 2, the proposed standard.
DOE requests comment on any potential manufacturer capacity
constraints caused by the proposed standards in this SNOPR, TSL 2.
d. Impacts on Subgroups of Manufacturers
Using average cost assumptions to develop an industry cash-flow
estimate may not be adequate for assessing differential impacts among
manufacturer subgroups. Small manufacturers, niche product
manufacturers, and manufacturers exhibiting cost structures
substantially different from the industry average could be affected
disproportionately. DOE analyzed the impacts to small businesses in
section VI.B of this SNOPR. DOE also identified the commercial-style
manufacturer subgroup as a potential manufacturer subgroup that could
be adversely impacted by this rulemaking based on the results of the
industry characterization.
The commercial-style manufacturer subgroup consists of cooking
product manufacturers that primarily sell gas cooking tops, gas ovens,
and electric self-clean ovens marketed as commercial-style, either as a
standalone product or as a component of a conventional range.
Commercial-style gas cooking tops typically have heavy cast iron grates
that act as an additional thermal load and up to six high input rate
burners that contribute to reduced cooking top efficiency. No
commercial-style manufacturers sell electric coil element cooking tops
and the subgroup would be unaffected by any standard required for this
product class. However, some, but not all, commercial-style
manufacturers produce electric smooth element cooking tops. Of those
commercial-style manufacturers that do produce electric smooth element
cooking tops, all have products that use induction technology that
would be capable of meeting max-tech for this product class.
Commercial-style electric and gas ovens typically have cavities with
thick gauge cavity walls and heavier racks that result in inherently
lower efficiencies as compared to residential-style ovens with
comparable cavities sizes, due to the greater thermal mass of the
cavity and racks, when measured by the previous DOE test procedure DOE
assumes that the commercial-style manufacturer subgroup is primarily
impacted by the proposed energy conservation standards required for the
gas cooking top, gas oven, and electric self-clean oven product classes
and are not significantly impacted by the standards proposed for the
electrical cooking top and the electric standard oven product classes.
For the gas cooking top product class, EL 1 represents DOE's
estimate of the most efficient cooking top available on the market with
cast-iron grates and six burners, at least four of which are high input
rate, which are features associated with gas cooking tops marketed as
commercial-style. Commercial-style manufacturers would not be able to
meet a gas cooking top standard set at EL 2 or EL 3 while retaining the
full functionality of a commercial-style product. Therefore, these
commercial-style manufacturers would likely be forced to exit the gas
cooking top market as a result of gas cooking top standards set at EL 2
or EL 3. TSL 3 and TSL 4 require EL 3 for the gas cooking top product
class.
For the gas oven and electric self-clean oven product classes, TSL
2 represents a prescriptive design requirement for the oven control
systems that would maintain features associated with ovens marketed as
commercial-style, such as thick gauge cavity walls and heavier
extension racks. Commercial-style manufacturers would not be able to
meet a performance-based standard for ovens set at a TSL higher than
TSL 2 while retaining the full functionality of their commercial-style
product. Therefore, these commercial-style manufacturers would be
likely forced to exit the conventional oven market as a result of
conventional oven standards set above TSL 2.
DOE requests comment on the two manufacturer subgroups that DOE
identified, the impacts of the proposed standards on those manufacturer
subgroups, and any other potential manufacturer subgroups that could be
disproportionally impacted by this rulemaking.
e. Cumulative Regulatory Burden
While any one regulation may not impose a significant burden on
manufacturers, the combined effects of recent or impending regulations
may have serious consequences for some manufacturers, groups of
manufacturers, or the entire industry. Assessing the impact of a single
regulation may overlook this cumulative regulatory burden. In addition
to energy conservation standards, other regulations can significantly
affect manufacturers' financial operations. Multiple regulations
affecting the same manufacturer can strain profits and lead companies
to abandon product lines or markets with lower expected future returns
than competing products. For these reasons, DOE conducts a cumulative
regulatory burden analysis as part of its rulemakings pertaining to
appliance efficiency.
As discussed in section II.B.2 of this SNOPR, DOE published a
separate NOPR proposing energy conservation standards for conventional
ovens. 80 FR 33030 (June 10, 2015). AHAM and Electrolux commented in
response to the June 2015 NOPR that DOE's proposal to bifurcate
standards for cooking tops and ovens means that conventional ranges, a
single product which makes up over 80 percent of conventional cooking
product shipments, could be subject to two different standards on two
different timelines. AHAM and Electrolux stated that DOE's proposal to
promulgate separate standards for cooking tops and ovens on two
separate timelines would likely result in two product redesigns and
dual investments for conventional ranges. AHAM added that this would
[[Page 60856]]
potentially mean unnecessary increased costs for both manufacturers and
consumers. AHAM and Electrolux commented that manufacturers will be
likely left with stranded investments and unnecessary additional
investments. (AHAM, No. 29 at pp. 2, 3, 10; Electrolux, No. 27 at p. 2)
Whirlpool agreed with AHAM's comments and opposed DOE's proposal to
pursue energy conservation standards for cooking tops on a different
regulatory timeline than standards for ovens. Whirlpool noted that
along with potentially imposing dual product redesigns and investments
for conventional ranges, manufacturers may also choose to redesign
these products together and launch models to the market in advance of
the lagging standard compliance date in order to meet both standards;
the net effect of this is a shortened lead-in period for the product
tied to the lagging standard. Whirlpool urged DOE to reconsider its
proposal and align regulatory timelines for ovens and cooking tops to
prevent unnecessary and substantial regulatory burden on industry.
(Whirlpool, No. 33 at pp. 3, 4, 8)
DOE recognizes that combined cooking products that include both a
conventional cooking top and oven (e.g., conventional ranges) may be
assembled on a single assembly line in manufacturing production
facilities. DOE also notes that some components and parts (e.g.,
cabinet housing, controls) may be shared between the oven and cooking
top portion of the combined cooking product. DOE recognizes that
setting standards with different compliance dates for ovens and cooking
tops could result in the need for manufacturers to redesign the oven
and cooking top portions of combined cooking products (including shared
components and assembly lines) separately on different timelines. As
discussed in section II.B.2 of this SNOPR, DOE is now combining the
rulemaking to consider energy conservation standards for conventional
cooking tops and ovens and will align the compliance dates for both
product categories.
Manufacturers also commented that conventional electric ranges are
facing an additional redesign in the same time period in order to
comply with a recent change to UL 858. That change to the voluntary
safety standard will require conventional electric ranges, a combined
cooking product covered by this rule, to monitor pan bottom temperature
and is aimed at reducing the incidences of unattended cooking fires.
Manufacturers noted that the change to UL 858 would likely occur just
before the compliance date of new and amended residential conventional
cooking product standards. Manufacturers added that changes to comply
with the requirements in UL 858 to significantly reduce surface
temperatures during a prescribed baking operation may also impact the
measured efficiency for these products. Manufacturers further explained
that the changes in UL 858 will require a major redesign for all
electric coil cooking tops by every manufacturer.
DOE acknowledges that most residential conventional cooking product
manufacturers also make appliances that are or could be subject to
future energy conservation standards implemented by DOE. DOE looks at
these regulations that could affect residential conventional cooking
product manufacturers that will take effect approximately 3 years
before or after the estimated 2019 compliance date of new and amended
energy conservation standards for residential conventional cooking
products. These energy conservation standards include those for
microwave ovens with a compliance date in 2016,\87\ commercial
refrigeration equipment with a compliance date in 2017,\88\ commercial
clothes washers with a compliance date in 2018,\89\ residential clothes
washers with a compliance date in 2018,\90\ furnace fans with a
compliance date in 2019,\91\ dehumidifiers with a compliance date in
2019,\92\ and dishwashers with a potential compliance date in 2019.\93\
---------------------------------------------------------------------------
\87\ Energy conservation standards final rule for microwave
ovens. 78 FR 36316 (June 17, 2013).
\88\ Energy conservation standards final rule for commercial
refrigeration equipment. 79 FR 17726 (March 28, 2014).
\89\ Energy conservation standards final rule for commercial
clothes washers. 79 FR 74492 (December 15, 2014).
\90\ Energy conservation standards direct final rule for
residential clothes washers. 77 FR 32308 (May 31, 2012).
\91\ Energy conservation standards final rule for furnace fans.
79 FR 38130 (July 3, 2014).
\92\ Energy conservation standards final rule for dehumidifiers.
81 FR 38338 (June 13, 2016).
\93\ Energy conservation standards NOPR for dishwashers. 79 FR
76142 (December 19, 2014).
---------------------------------------------------------------------------
The compliance years and expected industry conversion costs of
relevant new and amended energy conservation standards are indicated in
Table V.41.
Table V.41--Compliance Dates and Expected Conversion Expenses of Federal Energy Conservation Standards Affecting Conventional Cooking Product
Manufacturers
--------------------------------------------------------------------------------------------------------------------------------------------------------
Number of Industry Industry
Number of manufacturers conversion conversion
Regulation manufacturers from today's Approximate standards year costs costs/revenue
* rule ** (millions $) *** (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Microwave Ovens, 78 FR 36316 (Jun. 17, 2013) 12 7 2016...................................... 43.1(2011$) <1
Commercial Refrigeration Equipment, 79 FR 54 3 2017...................................... 184 (2012$) 2.0
17726 (Mar. 28, 2014).
Residential Clothes Washers, 77 FR 32308 16 10 2018 (Second Round)....................... 418.5 (2010$) 1.4
(May 31, 2012).
Commercial Clothes Washers, 79 FR 74492 6 4 2018...................................... 10.2 (2013$) 2.2
(Dec. 15, 2014).
Furnace Fans, 79 FR 38130 (Jul. 3, 2014).... 27 1 2019...................................... 40.6 (2012$) 1.6
Dehumidifiers, 81 FR 38338 (Jun. 13, 2016).. 25 4 2019...................................... 52.5 (2014$) 4.5
Dishwashers (NOPR) [dagger], 79 FR 76142 18 13 2019...................................... 316.9 (2013$) 5.6
(Dec. 19, 2014).
--------------------------------------------------------------------------------------------------------------------------------------------------------
* This column presents the total number of manufacturers identified in the energy conservation standard rule contributing to cumulative regulatory
burden.
** This column presents the number of manufacturers producing residential conventional cooking products that are also listed as manufacturers in the
listed energy conservation standard contributing to cumulative regulatory burden.
*** This column presents conversion costs as a percentage of cumulative revenue for the industry during the conversion period. The conversion period is
the timeframe over which manufacturers must make conversion costs investments and lasts from the announcement year of the final rule to the standards
year of the final rule. This period typically ranges from 3 to 5 years, depending on the energy conservation standard.
[[Page 60857]]
[dagger] The final rule for this energy conservation standard has not been published. The compliance date and analysis of conversion costs have not been
finalized at this time. Values in this row are estimates for the standard level proposed in the NOPR.
DOE discusses these and other requirements and includes the full
details of the cumulative regulatory burden analysis in Chapter 12 of
the SNOPR TSD. DOE will continue to evaluate its approach to assessing
cumulative regulatory burden for use in future rulemakings to ensure
that it is effectively capturing the overlapping impacts of its
regulations. In particular, DOE will assess whether looking at rules
where any portion of the compliance period potentially overlaps with
the compliance period for the subject rulemaking would yield a more
accurate reflection of cumulative regulatory burden.
DOE seeks comment on the compliance costs of any other regulations
residential conventional cooking product manufacturers must follow,
especially if compliance with those regulations is required three years
before or after the estimated compliance date of this proposed standard
(2019). Additionally, DOE welcomes comment on how it analyzes and
considers cumulative regulatory burden.
3. National Impact Analysis
a. Significance of Energy Savings
To estimate the energy savings attributable to potential standards
for conventional cooking products, DOE compared the energy consumption
of those products under the no-new-standards case to their anticipated
energy consumption under each TSL. The savings are measured over the
entire lifetime of products purchased in the 30-year period that begins
in the year of anticipated compliance with amended standards (2019-
2048). Table V.42 presents DOE's projections of the national energy
savings for each TSL considered for conventional cooking products. The
savings were calculated using the approach described in section IV.H of
this SNOPR.
Table V.42--Conventional Cooking Products: Cumulative National Energy Savings for Products Shipped in 2019-2048
[Quads]
----------------------------------------------------------------------------------------------------------------
Trial standard level
Product type Energy savings ---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
Conventional Cooking Tops..... Primary energy.. 0.22 0.31 0.48 0.70
FFC energy...... 0.23 0.33 0.52 0.75
Conventional Ovens............ Primary energy.. 0.17 0.41 0.47 1.05
FFC energy...... 0.18 0.43 0.50 1.10
---------------------------------------------------------------------------------
TOTAL (All Products)...... Primary energy.. 0.39 0.72 0.95 1.75
FFC energy...... 0.41 0.76 1.01 1.85
----------------------------------------------------------------------------------------------------------------
OMB Circular A-4 \94\ requires agencies to present analytical
results, including separate schedules of the monetized benefits and
costs that show the type and timing of benefits and costs. Circular A-4
also directs agencies to consider the variability of key elements
underlying the estimates of benefits and costs. For this rulemaking,
DOE undertook a sensitivity analysis using nine, rather than 30, years
of product shipments. The choice of a 9-year period is a proxy for the
timeline in EPCA for the review of certain energy conservation
standards and potential revision of and compliance with such revised
standards.\95\ The review timeframe established in EPCA is generally
not synchronized with the product lifetime, product manufacturing
cycles, or other factors specific to conventional cooking products.
Thus, such results are presented for informational purposes only and
are not indicative of any change in DOE's analytical methodology. The
NES sensitivity analysis results based on a 9-year analytical period
are presented in Table V.43. The impacts are counted over the lifetime
of conventional cooking products purchased in 2019-2027.
---------------------------------------------------------------------------
\94\ U.S. Office of Management and Budget, ``Circular A-4:
Regulatory Analysis'' (Sept. 17, 2003) (Available at: http://www.whitehouse.gov/omb/circulars_a004_a-4/).
\95\ Section 325(m) of EPCA requires DOE to review its standards
at least once every 6 years, and requires, for certain products, a
3-year period after any new standard is promulgated before
compliance is required, except that in no case may any new standards
be required within 6 years of the compliance date of the previous
standards. While adding a 6-year review to the 3-year compliance
period adds up to 9 years, DOE notes that it may undertake reviews
at any time within the 6 year period and that the 3-year compliance
date may yield to the 6-year backstop. A 9-year analysis period may
not be appropriate given the variability that occurs in the timing
of standards reviews and the fact that for some consumer products,
the compliance period is 5 years rather than 3 years.
Table V.43--Conventional Cooking Products: Cumulative National Energy Savings for Products Shipped in 2019-2027
[Quads]
----------------------------------------------------------------------------------------------------------------
Trial standard level
Product type Energy savings ---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
Conventional Cooking Tops..... Primary energy.. 0.06 0.08 0.13 0.20
FFC energy...... 0.06 0.09 0.14 0.21
Conventional Ovens............ Primary energy.. 0.05 0.12 0.14 0.30
FFC energy...... 0.05 0.12 0.14 0.32
---------------------------------------------------------------------------------
[[Page 60858]]
TOTAL (All Products)...... Primary energy.. 0.11 0.20 0.27 0.50
FFC energy...... 0.11 0.21 0.28 0.53
----------------------------------------------------------------------------------------------------------------
a. Net Present Value of Consumer Costs and Benefits
DOE estimated the cumulative NPV to the nation of the total costs
and savings for consumers that would result from particular standard
levels for conventional cooking products. In accordance with the OMB's
guidelines on regulatory analysis (OMB Circular A-4, section E,
September 17, 2003),\96\ DOE calculated NPV using both a 7-percent and
a 3-percent real discount rate. Table V.44 shows the consumer NPV
results for each TSL DOE considered for conventional cooking products.
The impacts are counted over the lifetime of products purchased in
2019-2048.
---------------------------------------------------------------------------
\96\ Available at: www.whitehouse.gov/omb/circulars_a004_a-4.
Table V.44--Conventional Cooking Products: Cumulative Net Present Value of Consumer Benefits for Products
Shipped in 2019-2048
----------------------------------------------------------------------------------------------------------------
Billion 2015$
---------------------------------------------------------------
Equipment type Discount rate Trial standard level
(%) ---------------------------------------------------------------
1 2 3 4 *
----------------------------------------------------------------------------------------------------------------
Conventional Cooking Tops....... 3 1.97 2.39 3.62 (13.00)
7 0.85 0.99 1.54 (8.22)
Conventional Ovens.............. 3 1.55 3.85 2.66 1.10
7 0.69 1.73 0.96 (0.72)
-------------------------------------------------------------------------------
TOTAL (All Products)........ 3 3.52 6.24 6.28 (11.91)
7 1.53 2.72 2.50 (8.94)
----------------------------------------------------------------------------------------------------------------
*Parentheses indicate negative (-) values.
The NPV results based on the aforementioned 9-year analytical
period are presented in Table V.45. The impacts are counted over the
lifetime of products purchased in 2019-2027. As mentioned previously,
such results are presented for informational purposes only and is not
indicative of any change in DOE's analytical methodology or decision
criteria.
Table V.45--Conventional Cooking Products: Cumulative Net Present Value of Consumer Benefits for Products
Shipped in 2019-2027
----------------------------------------------------------------------------------------------------------------
Billion 2015$
---------------------------------------------------------------
Equipment type Discount rate Trial standard level
---------------------------------------------------------------
1 2 3 4 *
----------------------------------------------------------------------------------------------------------------
Conventional Cooking Tops....... 3 0.66 0.78 1.17 (4.78)
7 0.40 0.45 0.69 (4.03)
Conventional Ovens.............. 3 0.54 1.35 0.87 0.12
7 0.33 0.83 0.42 (0.50)
-------------------------------------------------------------------------------
TOTAL (All Products)........ 3 1.20 2.13 2.04 (4.66)
7 0.73 1.28 1.12 (4.54)
----------------------------------------------------------------------------------------------------------------
* Parentheses indicate negative (-) values.
The above results reflect the use of a default trend to estimate
the change in price for conventional cooking products over the analysis
period (see section IV.F.1 of this SNOPR). DOE also conducted a
sensitivity analysis that considered one scenario with a lower rate of
price decline than the reference case and one scenario with a higher
rate of price decline than the reference case. The results of these
alternative cases are presented in appendix 10C of the SNOPR TSD. In
the high price decline case, the NPV is higher than in the default
case. In the low price decline case, the NPV is lower than in the
default case.
[[Page 60859]]
b. Impacts on Employment
DOE expects energy conservation standards for conventional cooking
products to reduce energy bills for consumers of those products, and
the resulting net savings to be redirected to other forms of economic
activity. These expected shifts in spending and economic activity could
affect the demand for labor. As described in section IV.N of this
SNOPR, DOE used an input/output model of the U.S. economy to estimate
indirect employment impacts of the TSLs that DOE considered in this
rulemaking. DOE understands that there are uncertainties involved in
projecting employment impacts, especially changes in the later years of
the analysis. Therefore, DOE generated results for near-term
timeframes, where these uncertainties are reduced.
The results suggest that the proposed standards are likely to have
negligible impact on the net demand for labor in the economy. The net
change in jobs is so small that it would be imperceptible in national
labor statistics and might be offset by other, unanticipated effects on
employment. Chapter 16 of the SNOPR TSD presents detailed results.
4. Impact on Utility or Performance of Products
Based on testing conducted in support of this proposed rule,
discussed in section IV.C.2 of this SNOPR, DOE concluded that the
standards proposed in this SNOPR would not reduce the utility or
performance of the conventional cooking products under consideration in
this rulemaking. Manufacturers of these products currently offer units
that meet or exceed the proposed standards.
5. Impact of Any Lessening of Competition
DOE has also considered any lessening of competition that is likely
to result from the proposed standards. The Attorney General determines
the impact, if any, of any lessening of competition likely to result
from a proposed standard, and transmits such determination to DOE,
together with an analysis of the nature and extent of such impact. (42
U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii))
DOE will transmit a copy of this SNOPR and the accompanying TSD to
the Attorney General, requesting that the DOJ provide its determination
on this issue. DOE will consider DOJ's comments on the proposed rule in
determining whether to proceed with the proposed energy conservation
standards. DOE will also publish and respond to DOJ's comments in the
Federal Register.
6. Need of the Nation To Conserve Energy
Enhanced energy efficiency, where economically justified, improves
the nation's energy security, strengthens the economy, and reduces the
environmental impacts (costs) of energy production. Reduced electricity
demand due to energy conservation standards is also likely to reduce
the cost of maintaining the reliability of the electricity system,
particularly during peak-load periods. As a measure of this reduced
demand, chapter 15 in the SNOPR TSD presents the estimated reduction in
generating capacity, relative to the no-new-standards case, for the
TSLs that DOE considered in this rulemaking.
Energy conservation resulting from proposed standards for
conventional cooking products are expected to yield environmental
benefits in the form of reduced emissions of air pollutants and
greenhouse gases. Table V.46 provides DOE's estimate of cumulative
emissions reductions to result from the TSLs considered in this
rulemaking. The table includes site emissions, power sector emissions
and upstream emissions. The emissions were calculated using the
multipliers discussed in section IV.K of this SNOPR. DOE reports annual
emissions reductions for each TSL in chapter 13 of the SNOPR TSD.
Table V.46--Conventional Cooking Products: Cumulative Emissions Reduction for Products Shipped in 2019-2048
----------------------------------------------------------------------------------------------------------------
Trial standard level
---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
Power Sector and Site Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................... 23.0 42.6 54.7 102.3
SO2 (thousand tons)............................. 13.7 23.2 24.2 52.4
NOX (thousand tons)............................. 25.4 48.1 64.9 117.4
Hg (tons)....................................... 0.05 0.09 0.09 0.19
CH4 (thousand tons)............................. 2.0 3.4 3.8 7.8
N2O (thousand tons)............................. 0.28 0.48 0.52 1.09
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................... 1.3 2.7 4.3 7.0
SO2 (thousand tons)............................. 0.2 0.4 0.4 0.9
NOX (thousand tons)............................. 18.6 39.8 65.7 104.2
Hg (tons)....................................... 0.00 0.00 0.00 0.00
CH4 (thousand tons)............................. 102.5 224.1 378.5 591.1
N2O (thousand tons)............................. 0.01 0.02 0.02 0.05
----------------------------------------------------------------------------------------------------------------
Total FFC Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................... 24.3 45.3 59.1 109.3
SO2 (thousand tons)............................. 13.9 23.6 24.6 53.3
NOX (thousand tons)............................. 43.9 88.0 130.6 221.6
Hg (tons)....................................... 0.05 0.09 0.09 0.20
CH4 (thousand tons)............................. 104.5 227.5 382.2 598.9
CH4 (thousand tons CO2eq)*...................... 2,926 6,369 10,703 16,769
N2O (thousand tons)............................. 0.29 0.50 0.54 1.14
[[Page 60860]]
N2O (thousand tons CO2eq)*...................... 76.8 132.6 144.3 302.9
----------------------------------------------------------------------------------------------------------------
* CO2eq is the quantity of CO2 that would have the same GWP.
As part of the analysis for this proposed rule, DOE estimated
monetary benefits likely to result from the reduced emissions of
CO2 and NOX that DOE estimated for each of the
considered TSLs for conventional cooking products. As discussed in
section IV.L of this SNOPR, for CO2, DOE used the most
recent values for the SCC developed by an interagency working group.
The four sets of SCC values for CO2 emissions reductions
resulting from that process refer to the average value from a
distribution that uses a 5-percent discount rate, the average value
from a distribution that uses a 3-percent discount rate, the average
value from a distribution that uses a 2.5-percent discount rate, and
the 95th-percentile value from a distribution that uses a 3-percent
discount rate. The values for later years are higher due to increasing
damages (emissions-related costs) as the projected magnitude of climate
change increases.
Table V.47 presents the global value of CO2 emissions
reductions at each TSL. For each of the four cases, DOE calculated a
present value of the stream of annual values using the same discount
rate as was used in the studies upon which the dollar-per-ton values
are based. DOE calculated domestic values as a range from 7 percent to
23 percent of the global values; these results are presented in chapter
14 of the SNOPR TSD.
Table V.47--Conventional Cooking Products: Estimates of Global Present Value of CO2 Emissions Reduction for
Products Shipped in 2019-2048
----------------------------------------------------------------------------------------------------------------
Million 2015$
---------------------------------------------------------------
SCC Case
TSL ---------------------------------------------------------------
3% discount
5% discount 3% discount 2.5% discount rate, 95th
rate, average rate, average rate, average percentile
----------------------------------------------------------------------------------------------------------------
Power Sector and Site Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 166 751 1,190 2,289
2............................................... 312 1,405 2,222 4,279
3............................................... 400 1,805 2,856 5,498
4............................................... 742 3,354 5,311 10,219
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 9.2 41.9 66.6 128
2............................................... 19.6 88.9 141 271
3............................................... 31.5 142 226 434
4............................................... 50.4 229 363 699
----------------------------------------------------------------------------------------------------------------
Total FFC Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 175 793 1,257 2,417
2............................................... 331 1,494 2,363 4,550
3............................................... 432 1,947 3,081 5,933
4............................................... 792 3,584 5,674 10,917
----------------------------------------------------------------------------------------------------------------
DOE is well aware that scientific and economic knowledge about the
contribution of CO2 and other GHG emissions to changes in
the future global climate and the potential resulting damages to the
world economy continues to evolve rapidly. Thus, any value placed on
reducing CO2 emissions in this rulemaking is subject to
change. DOE, together with other Federal agencies, will continue to
review various methodologies for estimating the monetary value of
reductions in CO2 and other GHG emissions. This ongoing
review will consider the comments on this subject that are part of the
public record for this and other rulemakings, as well as other
methodological assumptions and issues. However, consistent with DOE's
legal obligations, and taking into account the uncertainty involved
with this particular issue, DOE has included in this proposed rule the
most recent values and analyses resulting from the interagency process.
DOE also estimated the cumulative monetary value of the economic
benefits associated with NOX emissions reductions
anticipated to result from the considered TSLs for conventional cooking
products. The dollar-per-ton values that DOE used are discussed in
section IV.L of this SNOPR. Table V.48 presents the cumulative present
values for each TSL calculated using 7-percent and 3-percent discount
rates. This table presents values that use the low dollar-per-ton
values, which reflect DOE's primary estimate. Results that reflect the
range of NOX dollar-per-ton values are presented in Table
V.50.
[[Page 60861]]
Table V.48--Conventional Cooking Products: Estimates of Present Value of
NOX Emissions Reduction for Products Shipped in 2019-2048
------------------------------------------------------------------------
Million 2015$
-------------------------------
TSL 3% discount 7% discount
rate rate
------------------------------------------------------------------------
Power Sector and Site Emissions
------------------------------------------------------------------------
1....................................... 48.1 20.3
2....................................... 109.5 47.0
3....................................... 189.7 80.9
4....................................... 288.9 122.7
------------------------------------------------------------------------
Upstream Emissions
------------------------------------------------------------------------
1....................................... 35.3 14.5
2....................................... 77.5 32.7
3....................................... 128.6 54.7
4....................................... 201.4 84.6
------------------------------------------------------------------------
Total FFC Emissions
------------------------------------------------------------------------
1....................................... 83.4 34.9
2....................................... 187.0 79.7
3....................................... 318.3 135.6
4....................................... 490.4 207.3
------------------------------------------------------------------------
7. Other Factors
The Secretary of Energy, in determining whether a standard is
economically justified, may consider any other factors that the
Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) No
other factors were considered in this analysis.
8. Summary of National Economic Impacts
The NPV of the monetized benefits associated with emissions
reductions can be viewed as a complement to the NPV of the consumer
savings calculated for each TSL considered in this rulemaking. Table
V.49 presents the NPV values that result from adding the estimates of
the potential economic benefits resulting from reduced CO2
and NOX emissions in each of four valuation scenarios to the
NPV of consumer savings calculated for each TSL considered in this
rulemaking, at both a 7-percent and 3-percent discount rate. The
CO2 values used in the columns of each table correspond to
the 2015 values in the four sets of SCC values discussed above.
Table V.49--Conventional Cooking Products: Net Present Value of Consumer Savings Combined With Present Value of
Monetized Benefits From CO2 and NOX Emissions Reductions
[Billion 2015 $]
----------------------------------------------------------------------------------------------------------------
Consumer NPV at 3% discount rate added with:
---------------------------------------------------------------
TSL SCC case $12.4/ SCC case $40.6/ SCC case $63.2/ SCC case $118/
t and 3% low t and 3% low t and 3% low t and 3% low
NOX values NOX values NOX values NOX values
----------------------------------------------------------------------------------------------------------------
1............................................... 3.8 4.4 4.9 6.0
2............................................... 6.8 7.9 8.8 11.0
3............................................... 7.0 8.5 9.7 12.5
4............................................... (10.6) (7.8) (5.7) (0.5)
----------------------------------------------------------------------------------------------------------------
Consumer NPV at 7% discount rate added with:
---------------------------------------------------------------
TSL SCC case $12.4/ SCC case $40.6/ SCC case $63.2/ SCC case $118/
t and 7% low t and 7% low t and 7% low t and 7% low
NOX values NOX values NOX values NOX values
----------------------------------------------------------------------------------------------------------------
1............................................... 1.7 2.4 2.8 4.0
2............................................... 3.1 4.3 5.2 7.3
3............................................... 3.1 4.6 5.7 8.6
4............................................... (7.9) (5.1) (3.1) 2.2
----------------------------------------------------------------------------------------------------------------
Note: The SCC case values represent the global SCC in 2015, in 2015$, for each case.
Although adding the value of consumer savings to the values of
emission reductions provides a valuable perspective, two issues should
be considered. First, the national operating cost savings are domestic
U.S. monetary
[[Page 60862]]
savings that occur as a result of market transactions, while the value
of CO2 reductions is based on a global value. Second, the
assessments of operating cost savings and the SCC are performed with
different methods that use different time frames for analysis. The
national operating cost savings is measured for the lifetime of
equipment shipped in 2019 to 2048. Because CO2 emissions
have a very long residence time in the atmosphere,\97\ the SCC values
in future years reflect future climate-related impacts resulting from
the emission of CO2 that continue well beyond 2100.
---------------------------------------------------------------------------
\97\ The atmospheric lifetime of CO2 is estimated of
the order of 30-95 years. Jacobson, MZ (2005). ``Correction to
``Control of fossil-fuel particulate black carbon and organic
matter, possibly the most effective method of slowing global
warming.'' '' J. Geophys. Res. 110. pp. D14105.
---------------------------------------------------------------------------
C. Conclusion
When considering new or amended energy conservation standards that
DOE adopts for any type or class of covered product, they must be
designed to achieve the maximum improvement in energy efficiency that
the Secretary determines is technologically feasible and economically
justified. (42 U.S.C. 6295(o)(2)(A)) In determining whether a standard
is economically justified, the Secretary must determine whether the
benefits of the standard exceed its burdens, considering to the
greatest extent practicable the seven statutory factors discussed
previously. (42 U.S.C. 6295(o)(2)(B)(i)) The new or amended standard
must also result in a significant conservation of energy. (42 U.S.C.
6295(o)(3)(B))
For this SNOPR, DOE considered the impacts of potential amended
standards for conventional cooking products at each TSL, beginning with
the maximum technologically feasible level, to determine whether that
level was economically justified. Where the max-tech level was not
justified, DOE then considered the next most efficient level and
undertook the same evaluation until it reached the highest efficiency
level that is both technologically feasible and economically justified
and saves a significant amount of energy.
To aid the reader as DOE discusses the benefits and/or burdens of
each trial standard level, tables present a summary of the results of
DOE's quantitative analysis for each TSL. In addition to the
quantitative results presented in the tables, DOE also considers other
burdens and benefits that affect economic justification. Those include
the impacts on identifiable subgroups of consumers who may be
disproportionately affected by a national standard. Section V.B.1 of
this SNOPR presents the estimated impacts of each TSL for these
subgroups.
DOE also notes that the economics literature provides a wide-
ranging discussion of how consumers trade off upfront costs and energy
savings in the absence of government intervention. Much of this
literature attempts to explain why consumers appear to undervalue
energy efficiency improvements. This undervaluation suggests that
regulation that promotes energy efficiency can produce significant net
private gains (as well as producing social gains by, for example,
reducing pollution). There is evidence that consumers undervalue future
energy savings as a result of (1) a lack of information; (2) a lack of
sufficient salience of the long-term or aggregate benefits; (3) a lack
of sufficient savings to warrant delaying or altering purchases; (4)
excessive focus on the short term, in the form of inconsistent
weighting of future energy cost savings relative to available returns
on other investments; (5) computational or other difficulties
associated with the evaluation of relevant tradeoffs; and (6) a
divergence in incentives (between renters and owners, or builders and
purchasers). Having less than perfect foresight and a high degree of
uncertainty about the future, consumers may trade off these types of
investments at a higher than expected rate between current consumption
and uncertain future energy cost savings.
In DOE's current regulatory analysis, potential changes in the
benefits and costs of a regulation due to changes in consumer purchase
decisions are included in two ways: First, if consumers forego a
purchase of a product in the standards case, this decreases sales for
product manufacturers, and the impact on manufacturers attributed to
lost revenue is included in the MIA. Second, DOE accounts for energy
savings attributable only to products actually used by consumers in the
standards case; if a regulatory option decreases the number of products
used by consumers, this decreases the potential energy savings from an
energy conservation standard. DOE provides estimates of shipments and
changes in the volume of product purchases in chapter 9 of the SNOPR
TSD. However, DOE's current analysis does not explicitly control for
heterogeneity in consumer preferences, preferences across subcategories
of products or specific features, or consumer price sensitivity
variation according to household income.\98\
---------------------------------------------------------------------------
\98\ P.C. Reiss and M.W. White. Household Electricity Demand,
Revisited. Review of Economic Studies (2005) 72, 853-883.
---------------------------------------------------------------------------
While DOE is not prepared at present to provide a fuller
quantifiable framework for estimating the benefits and costs of changes
in consumer purchase decisions due to an energy conservation standard,
DOE is committed to developing a framework that can support empirical
quantitative tools for improved assessment of the consumer welfare
impacts of appliance standards. DOE has posted a paper that discusses
the issue of consumer welfare impacts of appliance energy efficiency
standards, and potential enhancements to the methodology by which these
impacts are defined and estimated in the regulatory process.\99\ DOE
welcomes comments on how to more fully assess the potential impact of
energy conservation standards on consumer choice and how to quantify
this impact in its regulatory analysis in future rulemakings.
---------------------------------------------------------------------------
\99\ Alan Sanstad, Notes on the Economics of Household Energy
Consumption and Technology Choice. Lawrence Berkeley National
Laboratory. 2010. Available online at: www1.eere.energy.gov/buildings/appliance_standards/pdfs/consumer_ee_theory.pdf.
---------------------------------------------------------------------------
1. Benefits and Burdens of TSLs Considered for Conventional Cooking
Products
Table V.51 summarize the quantitative impacts estimated for each
TSL for conventional cooking products. The national impacts are
measured over the lifetime of conventional cooking products purchased
in the 30-year period that begins in the anticipated year of compliance
with amended standards (2019-2048). The energy savings, emissions
reductions, and value of emissions reductions refer to full-fuel-cycle
results. The efficiency levels contained in each TSL are described in
section V.A of this SNOPR.
[[Page 60863]]
Table V.50--Conventional Cooking Products: Summary of National Impacts
--------------------------------------------------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3 TSL 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Cumulative FFC Energy Savings (quads)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0.41......................... 0.76........................ 1.01........................ 1.85
--------------------------------------------------------------------------------------------------------------------------------------------------------
NPV of Consumer Costs and Benefits (2015$ billion)
--------------------------------------------------------------------------------------------------------------------------------------------------------
3% discount rate............... $3.52........................ $6.24....................... $6.28....................... ($11.91).
7% discount rate............... 1.53......................... 2.72........................ 2.50........................ (8.94).
--------------------------------------------------------------------------------------------------------------------------------------------------------
Cumulative FFC Emissions Reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO2 million metric tons........ 24.3......................... 45.3........................ 59.1........................ 109.
SO2 thousand tons.............. 13.9......................... 23.6........................ 24.6........................ 53.3.
NOX thousand tons.............. 43.9......................... 88.0........................ 131......................... 222.
Hg tons........................ 0.05......................... 0.09........................ 0.09........................ 0.20.
CH4 thousand tons.............. 104.......................... 227......................... 382......................... 599.
CH4 thousand tons CO2eq*....... 2,926........................ 6,369....................... 10,703...................... 16,769.
N2O thousand tons.............. 0.29......................... 0.50........................ 0.54........................ 1.14.
N2O thousand tons CO2eq*....... 76.8......................... 133......................... 144......................... 303.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Value of Emissions Reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO2 2015$ million**............ 175 to 2,417................. 331 to 4,550................ 432 to 5,933................ 792 to 10,917.
NOX--3% discount rate 2015$ 83.4 to 190.2................ 187.0 to 426.3.............. 318.3 to 725.7.............. 490.4 to 1,118.0.
million.
NOX--7% discount rate 2015$ 34.9 to 78.7................. 79.7 to 179.7............... 135.6 to 305.7.............. 207.3 to 467.4.
million.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Parentheses indicate negative (-) values.
* CO2eq is the quantity of CO2 that would have the same GWP.
** Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions.
Table V.51--Conventional Cooking Products: Summary of Manufacturer and Consumer Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3 TSL 4
----------------------------------------------------------------------------------------------------------------
Manufacturer Impacts
----------------------------------------------------------------------------------------------------------------
Industry NPV (2015$ million) (No-New- 1,198.3-1,200.1 1,148.5-1,156.7 844.7-868.0 314.6-511.1
Standards Case INPV = $1,238.1)........
Industry NPV (% change)*................ (3.2)-(3.1) (7.2)-(6.6) (31.8)-(29.9) (74.6)-(58.7)
----------------------------------------------------------------------------------------------------------------
Consumer Average LCC Savings (2015$)
----------------------------------------------------------------------------------------------------------------
PC1: Electric Open (Coil) Element $0.00 $2.87 $2.87 $2.87
Cooking Tops...........................
PC2: Electric Smooth Element Cooking 24.37 24.37 24.37 (280.82)
Tops *.................................
PC3: Gas Cooking Tops................... 0.00 1.10 15.83 15.83
PC4: Electric Standard Ovens, Free- 5.93 5.93 10.23 (30.82)
Standing *.............................
PC5: Electric Standard Ovens, Built-in/ 5.96 5.96 10.23 (30.83)
Slide-in *.............................
PC6: Electric Self-Clean Ovens, Free- 7.04 7.04 7.04 (17.19)
Standing *.............................
PC7: Electric Self-Clean Ovens, Built-in/ 7.08 7.08 7.08 (17.21)
Slide-in *.............................
PC8: Gas Standard Ovens, Free-Standing.. 7.60 43.64 9.77 9.77
PC9: Gas Standard Ovens, Built-In/Slide- 7.60 43.65 9.77 9.77
In.....................................
PC10: Gas Self-Cleaning Ovens, Free- 7.73 48.03 20.27 20.27
Standing...............................
PC11: Gas Self-Cleaning Ovens, Built-In/ 7.73 48.05 20.27 20.27
Slide-In...............................
----------------------------------------------------------------------------------------------------------------
Consumer Simple PBP (years)
----------------------------------------------------------------------------------------------------------------
PC1: Electric Open (Coil) Element .................. 0.5 0.5 0.5
Cooking Tops...........................
PC2: Electric Smooth Element Cooking 1.0 1.0 1.0 61.9
Tops...................................
PC3: Gas Cooking Tops................... .................. 9.1 4.4 4.4
PC4: Electric Standard Ovens, Free- 0.9 0.9 4.7 17.1
Standing...............................
PC5: Electric Standard Ovens, Built-in/ 0.9 0.9 4.7 17.1
Slide-in...............................
PC6: Electric Self-Clean Ovens, Free- 0.9 0.9 0.9 16.2
Standing...............................
PC7: Electric Self-Clean Ovens, Built-in/ 0.9 0.9 0.9 16.2
Slide-in...............................
PC8: Gas Standard Ovens, Free-Standing.. 0.6 1.1 6.0 6.0
PC9: Gas Standard Ovens, Built-In/Slide- 0.6 1.1 6.0 6.0
In.....................................
----------------------------------------------------------------------------------------------------------------
Built-In/Slide-In
----------------------------------------------------------------------------------------------------------------
PC10: Gas Self-Cleaning Ovens, Free- 0.7 1.1 5.3 5.3
Standing...............................
PC11: Gas Self-Cleaning Ovens, Built-In/ 0.7 1.1 5.3 5.3
Slide-In...............................
----------------------------------------------------------------------------------------------------------------
[[Page 60864]]
% of Consumers That Experience Net Cost
----------------------------------------------------------------------------------------------------------------
PC1: Electric Open (Coil) Element 0 19 19 19
Cooking Tops...........................
PC2: Electric Smooth Element Cooking 0 0 0 98
Tops...................................
PC3: Gas Cooking Tops................... 0 14 6 6
PC4: Electric Standard Ovens, Free- 0 0 20 80
Standing...............................
PC5: Electric Standard Ovens, Built-in/ 0 0 20 80
Slide-in...............................
PC6: Electric Self-Clean Ovens, Free- 0 0 0 72
Standing...............................
PC7: Electric Self-Clean Ovens, Built-in/ 0 0 0 72
Slide-in...............................
PC8: Gas Standard Ovens, Free-Standing.. 0 0 61 61
PC9: Gas Standard Ovens, Built-In/Slide- 0 0 61 61
In.....................................
PC10: Gas Self-Cleaning Ovens, Free- 0 0 49 49
Standing...............................
PC11: Gas Self-Cleaning Ovens, Built-In/ 0 0 49 49
Slide-In...............................
----------------------------------------------------------------------------------------------------------------
* Parentheses indicate negative (-) values.
DOE first considered TSL 4, which represents the max-tech
efficiency levels. TSL 4 would save 1.85 quads of energy, an amount DOE
considers significant. Under TSL 4, the NPV of consumer benefit would
be negative 8.94 billion using a discount rate of 7 percent, and
negative 11.91billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 4 are 109 Mt of
CO2, 222 thousand tons of NOX, 53.3 thousand tons
of SO2, 0.20 ton of Hg, 599 thousand tons of CH4,
and 1.14 thousand tons of N2O. The estimated monetary value
of the CO2 emissions reduction at TSL 4 ranges from $792
million to $10,917 million.
At TSL 4, the average LCC impact ranges from a loss of $280.82 for
PC2 (Electric Smooth Element Cooking Tops) to a savings of $15.83 for
PC3 (Gas Cooking Tops). The simple payback period ranges from 0.5 years
for PC1 (Electric Open Element Cooking Tops) to 61.9 years for PC2
(Electric Smooth Element Cooking Tops). The fraction of consumers
experiencing an LCC net cost ranges from 6 percent for PC3 (Gas Cooking
Tops) to 98 percent for PC2 (Electric Smooth Element Cooking Tops).
DOE notes that the reduction in IAEC at TSL 4 could result in the
unavailability of certain product types, specifically commercial-style
cooking tops that incorporate certain features that may be expected by
purchasers of such products, e.g., heavier cast iron grates to support
larger loads and high input rate burners to provide faster cooking
times for larger loads. Because it is uncertain how greatly consumers
value these product types, DOE is concerned that TSL 4 may result in
the unavailability of certain product types for PC3 (Gas Cooking Tops).
In addition, as discussed in section III.B, DOE recognizes that there
may be uncertainty in conducting the standards analysis and analyzing
energy savings from performance standards for conventional ovens based
on efficiency levels using the oven test procedure adopted in the July
2015 TP Final Rule, which DOE is now proposing to repeal due to
concerns whether the test procedure accurately reflects the energy use
of all product types.
At TSL 4, the projected change in INPV ranges from a decrease of
$923.6 million to a decrease of $727.1 million, equivalent to a loss of
74.6 percent and a loss of 58.7 percent, respectively.
Products that meet the efficiency standards specified by TSL 4 are
forecast to represent 13 percent of shipments in the year leading up to
new and amended standards. As such, manufacturers would have to
redesign nearly all products by the 2019 compliance date to meet
demand. Redesigning all units to meet max-tech would require
considerable capital and product conversion expenditures. At TSL 4, DOE
estimates capital conversion costs would total $580.2 million and
product conversion costs would total $525.4 million. Total capital and
product conversion costs associated with the changes in products and
manufacturing facilities required at TSL 4 would require significant
use of manufacturers' financial reserves and would significantly reduce
manufacturer INPV. Additionally, manufacturers are more likely to
reduce their margins to maintain a price-competitive product at higher
TSLs, so DOE expects that TSL 4 would yield impacts closer to the most
severe range of INPV impacts. If the most severe range of impacts is
reached, as DOE expects could happen, TSL 4 could result in a net loss
of 74.6 percent in INPV to residential conventional cooking product
manufacturers. As a result, at TSL 4, DOE expects that some companies
could be forced to exit the residential conventional cooking product
market or shift production abroad, both of which would negatively
impact domestic manufacturing capacity and employment. The commercial-
style manufacturer subgroup, which primarily produces gas cooking
products that are marketed as commercial-style, would not be able to
meet the gas cooking product standards required at this TSL and would
likely be forced to exit the gas cooking product market, which could
negatively impact domestic employment.
In view of the foregoing, DOE has tentatively concluded that, at
TSL 4 for conventional cooking products, the benefits of energy
savings, positive NPV of total customer benefits, customer LCC savings
for six of the eleven product classes, emission reductions and the
estimated monetary value of the emissions reductions would be
outweighed by the negative customer impacts for product classes 2, 4,
5, 6 and 7 (Electric Smooth Element Cooking Tops and all Electric
Ovens), the potential burden on consumers from the unavailability of
certain product types for PC3 (Gas Cooking Tops), the uncertainty of
performance-based standards for PC4 through PC11 (Conventional Ovens)
since DOE is proposing to repeal its conventional oven test procedure,
the significant reduction in industry value at TSL 4, as well as the
potential for loss of domestic manufacturing. Consequently, DOE has
tentatively concluded that TSL 4 is not economically justified.
DOE then considered TSL 3, which comprises efficiency levels
providing maximum NES with positive NPV. TSL 3 would save 1.01 quads of
energy, an amount DOE considers significant. Under TSL 3, the NPV of
consumer benefit would be $2.50 billion using a discount rate of 7
percent, and $6.28 billion using a discount rate of 3 percent.
[[Page 60865]]
The cumulative emissions reductions at TSL 3 are 59.1 Mt of
CO2, 131 thousand tons of NOX, 24.6 thousand tons
of SO2, 0.09 ton of Hg, 382 thousand tons of CH4,
and 0.54 thousand tons of N2O. The estimated monetary value
of the CO2 emissions reduction at TSL 3 ranges from $432
million to $5,933 million.
At TSL 3, the average LCC impact is a savings ranging from $2.87
for PC1 (Electric Coil Cooking Tops) to $24.37 for PC2 (Electric Smooth
Element Cooking Tops). The simple payback period ranges from 0.5 years
for PC1 (Electric Open Element Cooking Tops) to 6.0 years for Gas
Standard Ovens. The fraction of consumers experiencing an LCC net cost
ranges from zero percent for PC2, PC6, and PC7 (Electric Smooth Element
Cooking Tops, and all Electric Self-Clean Ovens) to 61 percent for all
Gas Standard Ovens.
As described for TSL 4, the reduction in IAEC at TSL 3 could also
result in a lack in the availability of commercial-style cooking tops
that incorporate certain features that may be expected by purchasers of
such products, e.g., heavier cast iron grates to support larger loads
and high input rate burners to provide faster cooking times for larger
loads. DOE is concerned that TSL 3 may also result in the
unavailability of certain product types for PC3 (Gas Cooking Tops). In
addition, as discussed in section III.B, DOE recognizes that there may
be uncertainty in conducting the standards analysis and analyzing
energy savings from performance standards for conventional ovens based
on efficiency levels using the oven test procedure adopted in the July
2015 TP Final Rule, which DOE is now proposing to repeal due to
concerns whether the test procedure accurately reflects the energy use
of all product types.
At TSL 3, the projected change in INPV ranges from a decrease of
$393.5 million to a decrease of $370.1 million, equivalent to a loss of
31.8 percent and a loss of 29.9 percent, respectively.
Products that meet the efficiency standards specified by TSL 3 are
forecast to represent 30 percent of shipments in the year leading up to
new and amended standards. As such, manufacturers would have to
redesign a large portion of products by the 2019 compliance date to
meet demand. Redesigning the majority of units to meet efficiency
requirements at TSL 3 would require considerable capital and product
conversion expenditures. At TSL 3, DOE estimates capital conversion
costs would total $248.2 million and product conversion costs would
total $261.8 million. Total capital and product conversion costs
associated with the changes in products and manufacturing facilities
required at TSL 3 would require significant use of manufacturers'
financial reserves and would significantly reduce manufacturer INPV. As
a result, at TSL 3, DOE expects that some companies could be forced to
exit the residential conventional cooking product market or shift
production abroad, both of which would negatively impact domestic
manufacturing capacity and employment. The commercial-style
manufacturer subgroup, which primarily produces gas cooking products
that are marketed as commercial-style, would not be able to meet the
gas cooking product standards required at this TSL and would likely be
forced to exit the gas cooking product market, which could negatively
impact domestic employment.
In view of the foregoing, DOE has tentatively concluded that, at
TSL 3 for conventional cooking products, the benefits of energy
savings, positive NPV of total customer benefits, customer LCC savings
for all the product classes, emission reductions and the estimated
monetary value of the emissions reductions would be outweighed by the
negative customer impacts for product classes 8 through 11 (all Gas
Ovens), the potential burden on consumers from the unavailability of
certain product types for PC3 (Gas Cooking Tops), the uncertainty of
performance-based standards for PC4 through PC11 (Conventional Ovens)
since DOE has proposed to repeal its conventional oven test procedure,
the significant reduction in industry value at TSL 3, as well as the
potential for loss of domestic manufacturing. Consequently, DOE has
tentatively concluded that TSL 3 is not economically justified.
DOE then considered TSL 2. TSL 2 includes the prescriptive
standards for conventional ovens and represents a level between TSL 1
and TSL 3 that does not eliminate commercial-style cooking tops from
the market and yields an NPV greater than TSL 1. TSL 2 would save 0.76
quads of energy, an amount DOE considers significant. Under TSL 2, the
NPV of consumer benefit is $2.72 billion using a discount rate of 7
percent, and $6.24 billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 2 are 45.3 Mt of
CO2, 88.0 thousand tons of NOX, 23.6 thousand
tons of SO2, 0.09 tons of Hg, 227 thousand tons of
CH4, and 0.50 thousand tons of N2O. The estimated
monetary value of the CO2 emissions reduction at TSL 3
ranges from $331 million to $4,550 million.
At TSL 2, the average LCC impact is a savings ranging from $1.10
for PC3 (Gas Cooking Tops) to $48.05 for PC11 (Gas Self-Cleaning Ovens,
Built-in/Slide-in). The simple payback period ranges from 0.5 years for
PC1 (Electric Open Element Cooking Tops) to 9.1 years for PC3 (Gas
Cooking Tops). The fraction of consumers experiencing a LCC net cost
ranges from zero percent for PC2 and PC4 through PC11 (Electric Smooth
Element Cooking Tops, and all Electric and Gas Ovens) to 19 percent for
PC1 (Electric Open Element Cooking Tops).
At TSL 2, the projected change in INPV ranges from a decrease of
$89.6 million to a decrease of $81.4 million, equivalent to a loss of
7.2 percent and a loss of 6.6 percent, respectively. Products that meet
the efficiency standards specified by this TSL are forecast to
represent 49 percent of shipments in the year leading up to new and
amended standards. DOE estimates that compliance with TSL 2 would
require manufacturers to make an estimated $47.9 million in capital
conversion costs and would require manufacturers to make an estimated
$71.3 million in product conversion costs primarily relating to the
research and development programs needed to improve upon existing
platforms to meet the specified efficiency levels. The substantial
reduction in conversion costs corresponding to compliance with TSL 2,
compared to compliance with TSL 3 and TSL 4, greatly mitigates the
operational risk and impact on manufacturer INPV.
DOE estimates that the reduction in IAEC due to a performance
standard under TSL 2 for PC3 (Gas Cooking Tops) would not result in the
unavailability of certain product types and features. Specifically, the
commercial-style gas cooking tops that may be lost under TSL 3 would be
retained at TSL 2. Based on DOE's testing, as presented in section
IV.C.2 of this SNOPR, commercial-style gas cooking tops are available
on the market that meet the proposed efficiency level under TSL 2.
Additionally, because TSL 2 is composed of prescriptive
requirements for conventional ovens, the industry would not face the
costs associated with complying with performance requirements for these
product classes. TSL 2 would require conventional gas ovens to be
equipped with a control system that uses intermittent/interrupted
ignition or intermittent pilot ignition and does not use a linear power
supply. For conventional electric ovens, TSL 2 would require that
conventional electric ovens not be equipped with a control system that
uses a linear power
[[Page 60866]]
supply. Current prescriptive standards for conventional gas cooking
products require that gas cooking products with or without an
electrical supply cord not be equipped with a constant burning pilot.
As a result, conventional cooking product manufacturers are not
currently subject to the costs of testing the rated performance of
their products to label and comply with performance-based energy
conservation standards. By maintaining prescriptive standards at TSL 2,
DOE avoids burdening manufacturers of conventional ovens with testing,
labeling, and compliance costs that they currently do not bear. As
discussed in section III.B of this SNOPR, the prescriptive standards
for conventional ovens that are proposed under TSL 2 would also avoid
the issues with uncertainty in measured energy use values for different
oven product types, particularly since DOE is proposing to repeal the
oven test procedure.
After considering the analysis and weighing the benefits and
burdens, the Secretary tentatively concludes that at TSL 2 for
residential conventional cooking products, the benefits of energy
savings, positive NPV of consumer benefits, emission reductions, and
the estimated monetary value of the CO2 emissions
reductions, and positive average LCC savings would outweigh the
negative impacts on some consumers and on manufacturers. Although TSL 2
could result in a reduction in INPV for manufacturers, DOE has
concluded that it would not place a significant burden on manufacturers
to comply with the standards in terms of changes to existing
manufacturing processes and certification testing. Accordingly, the
Secretary has tentatively concluded that TSL 2 would offer the maximum
improvement in efficiency that is technologically feasible and
economically justified, and would result in significant conservation of
energy.
Therefore, based on the above considerations, DOE proposes TSL 2
for conventional cooking products. The proposed energy conservation
standards for conventional cooking tops are shown in Table V.52. As
discussed in section IV.C.3 in this SNOPR, the efficiency levels
analyzed in this SNOPR are based, in part, on DOE's testing of products
in its test sample. DOE recognizes that manufacturers implement
different heating element or burner designs and welcomes additional
test data regarding the proposed standard levels.
Table V.52--Proposed Amended Energy Conservation Standards for
Conventional Cooking Tops
[Compliance date: January 1, 2019]
------------------------------------------------------------------------
Integrated annual
energy
Product class consumption
(IAEC) (kWh/year)
------------------------------------------------------------------------
Electric Open (Coil) Element Cooking Tops............ 113.2
Electric Smooth Element Cooking Tops................. 121.2
Gas Cooking Tops..................................... 924.4
------------------------------------------------------------------------
For conventional ovens, the proposed standards at TSL 2 correspond
to a prescriptive design requirement for the control system of the
oven. DOE is proposing to require that conventional electric ovens not
be equipped with a control system that uses a linear power supply. DOE
is also proposing that conventional gas ovens be equipped with a
control system that uses an intermittent/interrupted ignition or
intermittent pilot ignition and does not use a linear power supply. DOE
also notes that the current prescriptive standards for conventional gas
ovens prohibiting constant burning pilot lights would continue to be
applicable. (10 CFR 430.32(j)).
2. Summary of Annualized Benefits and Costs of the Proposed Standards
The benefits and costs of the proposed standards can also be
expressed in terms of annualized values. The annualized net benefit is
the sum of (1) the annualized national economic value (expressed in
2015$) of the benefits from operating products that meet the proposed
standards (consisting primarily of operating cost savings from using
less energy, minus increases in product purchase costs, which is
another way of representing consumer NPV), and (2) the monetary value
of the benefits of CO2 and NOX emission
reductions.\100\
---------------------------------------------------------------------------
\100\ To convert the time-series of costs and benefits into
annualized values, DOE calculated a present value in 2015, the year
used for discounting the NPV of total consumer costs and savings.
For the benefits, DOE calculated a present value associated with
each year's shipments in the year in which the shipments occur
(2020, 2030, etc.), and then discounted the present value from each
year to 2015. The calculation uses discount rates of 3 and 7 percent
for all costs and benefits except for the value of CO2
reductions, for which DOE used case-specific discount rates. Using
the present value, DOE then calculated the fixed annual payment over
a 30-year period, starting in the compliance year that yields the
same present value.
---------------------------------------------------------------------------
Table V.53 shows the annualized values for conventional cooking
products under TSL 2, expressed in 2015$. The results under the primary
estimate are as follows.
Using a 7-percent discount rate for benefits and costs other than
CO2 reductions, for which DOE used a 3-percent discount rate
along with the SCC series corresponding to a value of $40.6/ton in 2015
(in 2015$), the cost of the standards for conventional cooking products
in today's rule is $42.6 million per year in increased equipment costs,
while the annualized benefits are $293 million per year in reduced
equipment operating costs, $80.8 million in CO2 reductions,
and $7.4 million in reduced NOX emissions. In this case, the
net benefit amounts to $339 million per year. Using a 3-percent
discount rate for all benefits and costs and the SCC series
corresponding to a value of $40.6/ton in 2015 (in 2015$), the cost of
the standards for conventional cooking products in today's rule is
$42.3 million per year in increased equipment costs, while the benefits
are $380 million per year in reduced operating costs, $80.8 million in
CO2 reductions, and $10.1 million in reduced NOX
emissions. In this case, the net benefit amounts to $429 million per
year.
[[Page 60867]]
Table V.53--Annualized Benefits and Costs of Proposed Amended Standards (TSL 2) for Conventional Cooking Products Sold in 2019-2048
--------------------------------------------------------------------------------------------------------------------------------------------------------
Million
Discount rate Primary estimate* Low net benefits High net benefits 2015$/
estimate* estimate* year
------------------------------------------------------------------------------------------------------------------------------------------------- ---------
Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings. 7%............................ 293...................... 262...................... 332.
3%............................ 380...................... 336...................... 439.
CO2 Reduction at $12.4/t **..... 5%............................ 23.8..................... 21.7..................... 26.5.
CO2 Reduction at $40.6/t **..... 3%............................ 80.8..................... 73.6..................... 90.5.
CO2 Reduction at $63.2/t **..... 2.5%.......................... 118.6.................... 107.9.................... 132.8.
CO2 Reduction at $118/t **...... 3%............................ 246.3.................... 224.1.................... 275.6.
NOX Reduction Value [dagger].... 7%............................ 7.4...................... 6.8...................... 18.2.
3%............................ 10.1..................... 9.2...................... 25.6.
Total Benefits [dagger][dagger]. 7% plus CO2 range............. 325 to 547............... 290 to 493............... 377 to 626.
7%............................ 382...................... 342...................... 441.
3% plus CO2 range............. 414 to 637............... 367 to 569............... 491 to 740.
3%............................ 471...................... 418...................... 555.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Costs
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Incremental Product 7%............................ 42.6..................... 41.6..................... 45.3.
Costs. 3%............................ 42.3..................... 41.3..................... 45.2.
Total [dagger].................. 7% plus CO2 range............. 282 to 504............... 249 to 451............... 332 to 581.
7%............................ 339...................... 301...................... 396.
3% plus CO2 range............. 372 to 594............... 325 to 528............... 446 to 695.
3%............................ 429...................... 377...................... 510.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with cooking products shipped in 2019-2048. Note that the benefits and costs may not
exactly sum to the net benefits due to rounding. These results include benefits to consumers which accrue after 2048 from the products purchased in
2019-2048. The results account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of which may be
incurred in preparation for the rule. The Primary, Low Benefits, and High Benefits Estimates utilize projections of energy prices from the AEO 2015
Reference case, Low Economic Growth case, and High Economic Growth case, respectively. In addition, incremental product costs reflect a medium decline
rate in the Primary Estimate, a low decline rate in the Low Benefits Estimate, and a high decline rate in the High Benefits Estimate. The methods used
to derive projected price trends are explained in section IV.F.1 of this SNOPR.
** The CO2 values represent global monetized values of the SCC, in 2015$, in 2015 under several scenarios of the updated SCC values. The first three
cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case represents the 95th
percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series incorporate an escalation factor.
[dagger] DOE estimated the monetized value of NOX emissions reductions associated with electricity savings using benefit per ton estimates from the
Regulatory Impact Analysis for the Clean Power Plan Final Rule, published in August 2015 by EPA's Office of Air Quality Planning and Standards.
(Available at: http://www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis.) See section IV.L.2 of this SNOPR for further
discussion. For DOE's Primary Estimate and Low Net Benefits Estimate, the agency used a national benefit-per-ton estimate for NOX emitted from the
Electric Generating Unit sector based on an estimate of premature mortality derived from the ACS study (Krewski et al., 2009). For DOE's High Net
Benefits Estimate, the benefit-per-ton estimates were based on the Six Cities study (Lepuele et al., 2011), which are nearly two-and-a-half times
larger than those from the ACS study.
[dagger][dagger] Total Benefits for both the 3% and 7% cases are derived using the series corresponding to the average SCC with a 3-percent discount
rate ($40.6/t case). In the rows labeled ``7% plus CO2 range'' and ``3% plus CO2 range,'' the operating cost and NOX benefits are calculated using the
labeled discount rate, and those values are added to the full range of CO2 values.
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
Section 1(b)(1) of Executive Order 12866, ``Regulatory Planning and
Review,'' 58 FR 51735 (Oct. 4, 1993), requires each agency to identify
the problem that it intends to address, including, where applicable,
the failures of private markets or public institutions that warrant new
agency action, as well as to assess the significance of that problem.
The problems that the proposed standards address are as follows:
(1) Insufficient information and the high costs of gathering and
analyzing relevant information leads some consumers to miss
opportunities to make cost-effective investments in energy efficiency.
(2) In some cases the benefits of more efficient products are not
realized due to misaligned incentives between purchasers and users. An
example of such a case is when the products purchase decision is made
by a building contractor or building owner who does not pay the energy
costs.
(3) There are external benefits resulting from improved energy
efficiency of appliances that are not captured by the users of such
products. These benefits include externalities related to public
health, environmental protection, and national security that are not
reflected in energy prices, such as reduced emissions of air pollutants
and greenhouse gases that impact human health and global warming.
The Administrator of the Office of Information and Regulatory
Affairs (OIRA) in the OMB has determined that the proposed regulatory
action is a significant regulatory action under section (3)(f) of
Executive Order 12866. Accordingly, pursuant to section 6(a)(3)(B) of
the Order, DOE has provided to OIRA: (i) The text of the draft
regulatory action, together with a reasonably detailed description of
the need for the regulatory action and an explanation of how the
regulatory action will meet that need; and (ii) An assessment of the
potential costs and benefits of the regulatory action, including an
explanation of the manner in which the regulatory action is consistent
with a statutory mandate. DOE has included these documents in the
rulemaking record.
In addition, DOE has determined that this regulatory action is an
``economically significant regulatory action'' under Executive Order
12866. Accordingly, pursuant to section 6(a)(3)(C) of the Order, DOE
has
[[Page 60868]]
provided to OIRA an assessment, including the underlying analysis, of
benefits and costs anticipated from the regulatory action, together
with, to the extent feasible, a quantification of those costs; and an
assessment, including the underlying analysis, of costs and benefits of
potentially effective and reasonably feasible alternatives to the
planned regulation, and an explanation why the planned regulatory
action is preferable to the identified potential alternatives. These
assessments can be found in the technical support document for this
rulemaking.
DOE has also reviewed this regulation pursuant to Executive Order
13563. 76 FR 3281 (Jan. 21, 2011). Executive Order 13563 is
supplemental to and explicitly reaffirms the principles, structures,
and definitions governing regulatory review established in Executive
Order 12866. To the extent permitted by law, agencies are required by
Executive Order 13563 to: (1) Propose or adopt a regulation only upon a
reasoned determination that its benefits justify its costs (recognizing
that some benefits and costs are difficult to quantify); (2) tailor
regulations to impose the least burden on society, consistent with
obtaining regulatory objectives, taking into account, among other
things, and to the extent practicable, the costs of cumulative
regulations; (3) select, in choosing among alternative regulatory
approaches, those approaches that maximize net benefits (including
potential economic, environmental, public health and safety, and other
advantages; distributive impacts; and equity); (4) to the extent
feasible, specify performance objectives, rather than specifying the
behavior or manner of compliance that regulated entities must adopt;
and (5) identify and assess available alternatives to direct
regulation, including providing economic incentives to encourage the
desired behavior, such as user fees or marketable permits, or providing
information upon which choices can be made by the public.
DOE emphasizes as well that Executive Order 13563 requires agencies
to use the best available techniques to quantify anticipated present
and future benefits and costs as accurately as possible. In its
guidance, OIRA has emphasized that such techniques may include
identifying changing future compliance costs that might result from
technological innovation or anticipated behavioral changes. For the
reasons stated in the preamble, DOE believes that this SNOPR is
consistent with these principles, including the requirement that, to
the extent permitted by law, benefits justify costs and that net
benefits are maximized.
B. Review Under the Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis (IRFA) for
any rule that by law must be proposed for public comment, unless the
agency certifies that the rule, if promulgated, will not have a
significant economic impact on a substantial number of small entities.
As required by Executive Order 13272, ``Proper Consideration of Small
Entities in Agency Rulemaking,'' 67 FR 53461 (August 16, 2002), DOE
published procedures and policies on February 19, 2003, to ensure that
the potential impacts of its rules on small entities are properly
considered during the rulemaking process. 68 FR 7990. DOE has made its
procedures and policies available on the Office of the General
Counsel's Web site (http://energy.gov/gc/office-general-counsel). DOE
has prepared the following IRFA for the products that are the subject
of this rulemaking.
1. Description and Estimated Number of Small Entities Regulated
a. Methodology for Estimating the Number of Small Entities
For manufacturers of residential conventional cooking products, the
SBA has set a size threshold, which defines those entities classified
as ``small businesses'' for the purposes of the statute. DOE used the
small business size standards published by SBA to determine whether any
small entities would be required to comply with this rule. The size
standards are codified at 13 CFR part 121. The size standards are
listed by North American Industry Classification System (NAICS) code
and industry description and are available at http://www.sba.gov/sites/default/files/files/Size_Standards_Table.pdf. Residential conventional
cooking products manufacturing is classified under NAICS 335221,
``Household Cooking Appliance Manufacturing.'' The SBA sets a threshold
of 1,500 employees or fewer for an entity to be considered a small
business for this category.
DOE reviewed the potential standard levels considered in this SNOPR
under the provisions of the Regulatory Flexibility Act and the
procedures and policies published on February 19, 2003. To better
assess the potential impacts of this rulemaking on small entities, DOE
conducted a more focused inquiry of the companies that could be small
businesses of products covered by this rulemaking. During its market
survey, DOE used available public information to identify potential
small businesses. DOE's research involved industry trade association
membership directories (e.g., AHAM), information from previous
rulemakings, individual company Web sites, and market research tools
(e.g., Hoover's reports) to create a list of companies that manufacture
or sell residential conventional cooking products covered by this
rulemaking.
Table VI.1--Sources Used To Identify Residential Conventional Cooking Product Businesses
----------------------------------------------------------------------------------------------------------------
Number of large Number of small
Source businesses businesses
identified identified
----------------------------------------------------------------------------------------------------------------
AHAM Trade Association Directory.......................................... 9 2
Previous Rulemaking....................................................... 2 4
Market Research........................................................... 0 4
-------------------------------------
Total................................................................. 11 10
----------------------------------------------------------------------------------------------------------------
DOE also asked stakeholders and industry representatives if they
were aware of any additional small businesses during manufacturer
interviews and at DOE public meetings. DOE reviewed publicly available
data and contacted various companies on its complete list of
businesses, as necessary, to determine whether they
[[Page 60869]]
met the SBA's definition of a small business. DOE screened out
companies that do not offer products impacted by this rulemaking, do
not meet the definition of a ``small business,'' or are foreign owned
and operated.
DOE identified 21 companies that either manufacture or sell
residential conventional cooking products that would be affected by
this proposal. Of these 21 companies, DOE identified 10 that met the
SBA's definition of a small business. However, DOE believes that only
eight of these 10 small businesses actually manufacture the products
they sell. The other two are rebranders and do not manufacture the
products they sell.
b. Manufacturer Participation
DOE contacted identified businesses to invite them to take part in
a manufacturer impact analysis interview. DOE contacted all 10
potential small businesses to participate in manufacturer interviews.
DOE was able to reach and discuss potential standards with two small
businesses. DOE also obtained information about small businesses and
potential impacts on small businesses while interviewing large
manufacturers.
c. Residential Conventional Cooking Product Industry Structure and
Nature of Competition
Three major manufacturers supply approximately 85 percent of the
market for residential conventional cooking products. None of the three
major manufacturers of residential conventional cooking products
affected by this rulemaking is a small business. DOE estimates that the
remaining 15 percent of the market is served by a combination of 10
small businesses and eight large businesses, not counting the three
major manufacturers.
d. Comparison Between Large and Small Manufacturers
In general, small manufacturers differ from large manufacturers in
several ways that affect the extent to which a manufacturer may be
impacted by proposed standards. Characteristics of small manufacturers
typically include: lower production volumes, fewer engineering
resources, and less access to capital. Lower production volumes in
particular may place small manufacturers at a competitive disadvantage
relative to large manufacturers as they convert products and facilities
to comply with new and amended standards. When producing at lower
volumes, a small manufacturer's conversion costs must be spread over
fewer units than a larger competitor's. Therefore, unless a small
manufacturer can differentiate its products in order to earn a price
premium, the small manufacturer may experience a disproportionate cost
penalty as it spreads one-time conversion costs over fewer unit sales.
Additionally, when producing at lower volumes, small manufacturers may
lack the purchasing power of their larger competitors and may therefore
face higher costs when sourcing components for more efficient products.
Disadvantages tied to lower production volumes may be further
exacerbated by the fact that small manufacturers often have more
limited engineering resources than their larger competitors, thereby
complicating the redesign effort required to comply with new and
amended standards. Finally, small manufacturers often have less access
to capital, which may be needed to cover the conversion costs
associated with new and amended standards. Combined, these factors may
entail a disproportionate burden on small manufacturers compared to
large manufacturers.
2. Description and Estimate of Compliance Requirements
DOE discovered that small businesses can be divided into two
groups; (1) small manufacturers, that manufacture their products; and
(2) rebranders, that label already-manufactured products under their
company name. Even though small businesses that re-label already-
manufactured products may experience slightly higher unit costs, DOE
does not anticipate this rulemaking having a significant effect on
these businesses, since these rebranders are not responsible for the
conversion costs associated with the proposed standards.
There are two types of small businesses responsible for
manufacturing the products they sell; niche small manufacturers and
premium small manufacturers. Niche small manufacturers typically
produce inexpensive cooking products in non-conventional sizes for
unique applications. They typically do not compete with large
manufacturers due to the lower sales volumes associated with these non-
conventional sizes and unique applications. In order to comply with the
proposed oven standards, several niche small manufacturers would need
to purchase SMPS for their ovens. However, since this is a purchased
part, DOE does not anticipate a significant impact to these
manufacturers due to the proposed standards for ovens. For cooking
tops, most niche small manufacturers use lighter metal grates in their
cooking tops that are more efficient and would already meet the
proposed standards for cooking tops.
Premium small manufacturers sell premium cooking products that
typically do not compete in the market place on price. These products
can be significantly more expensive than the mass volume cooking
products that large manufacturers typically sell. Most premium small
manufacturers already use switch mode power supplies in their ovens and
would not be significantly impacted by the proposed standards for
ovens. While some premium manufacturers would have to redesign their
cooking tops to meet the proposed standards, there are premium cooking
tops on the market that are able to meet these standards while still
retaining their premium quality.
At TSL 2, the level proposed in this SNOPR, DOE estimates capital
conversion costs of $1.5 million and product conversion costs of $4.0
million for an average small manufacturer. This brings the total
conversion costs to approximately $5.5 million for an average small
manufacturer. Based on publicly available information from online
sources such as Hoovers,\101\ Cortera,\102\ and Glassdoor,\103\ DOE
estimates the average annual revenue of a small manufacturer to be
approximately $161.5 million. Table VI.2 presents the estimated
conversion costs as a percentage of annual revenue for an average small
manufacturer.
---------------------------------------------------------------------------
\101\ See: http://www.hoovers.com/.
\102\ See: https://www.cortera.com/.
\103\ See: https://www.glassdoor.com/.
[[Page 60870]]
Table VI.2--Conversion Costs as a Percentage of Annual Revenue for an Average Small Manufacturer of Residential
Conventional Cooking Products
----------------------------------------------------------------------------------------------------------------
Conversion
Annual revenue Conversion costs as a
(millions costs (millions percentage of
2014$) 2014$) annual revenue
----------------------------------------------------------------------------------------------------------------
Average Small Manufacturer................................... $161.5 $5.5 3.4
----------------------------------------------------------------------------------------------------------------
Since the proposed standards could impact up to eight small
manufacturers' level of investment and profitability, DOE cannot
certify that the proposed standards would not have a significant impact
on a substantial number of small businesses.
DOE requests comments on the number of small businesses identified
and on the impacts of new and amended energy conservation standards on
small businesses, including small rebranders and small manufacturers.
3. Duplication, Overlap, and Conflict With Other Rules and Regulations
DOE is not aware of any rules or regulations that duplicate,
overlap, or conflict with the rule being proposed.
4. Significant Alternatives to the Rule
The discussion in the previous section analyzes impacts on small
businesses that would result from the proposed standards. In reviewing
alternatives to the proposed rule, DOE examined energy conservation
standards set at higher and lower efficiency levels, TSL 4, TSL 3, and
TSL 1. DOE estimates that for an average small manufacturer, conversion
costs would be 86.8 percent lower at TSL 2 ($5.5 million) compared to
the conversion costs at TSL 4 ($41.8 million) and would be 75.5 percent
lower at TSL 2 ($5.5 million) compared to the conversion costs at TSL 3
($22.6 million). The substantial reduction in small manufacturer
conversion costs corresponding to TSL 2 compared to TSL 4 and TSL 3
greatly mitigates the operational risk and the impact of the standards
on small manufacturer's profitability.
While TSL 1 would reduce the impacts on small businesses, it would
come at the expense of a significant reduction in energy savings and
NPV benefits to consumers, achieving 29 percent lower energy savings
and 36 percent less NPV benefits to consumers compared to the energy
savings and NPV benefits at TSL 2.
DOE believes that establishing standards at TSL 2 balances the
benefits of the energy savings and the NPV benefits to consumers
created at TSL 2 with the potential burdens placed on residential
conventional products manufacturers, including small businesses.
Accordingly, DOE is declining to adopt one of the other TSLs, or the
other policy alternatives detailed as part of the regulatory impacts
analysis included in chapter 17 of the SNOPR TSD.
Additional compliance flexibilities may be available through other
means. For example EPCA provides that a manufacturer whose annual gross
revenue from all of its operations does not exceed $8 million may apply
for an exemption from all or part of an energy conservation standard
for a period not longer than 24 months after the effective date of a
final rule establishing the standards. (42 U.S.C. 6295(t)) DOE
estimates that three of the nine small manufacturers could potentially
petition for a waiver based on their annual gross revenue not exceeding
$8 million. Additionally, Section 504 of the Department of Energy
Organization Act, 42 U.S.C. 7194, provides authority for the Secretary
to adjust a rule issued under EPCA in order to prevent ``special
hardship, inequity, or unfair distribution of burdens'' that may be
imposed on that manufacturer as a result of such rule. Manufacturers
should refer to 10 CFR part 430, subpart E, and part 1003 for
additional details.
DOE continues to seek input from businesses that would be affected
by this rulemaking and will consider comments received in the
development of any final rule (See section VII.B of this SNOPR that
solicits specific data as well as input on the results of the analyses
contained in this section VI.B.4.)
C. Review Under the Paperwork Reduction Act
Manufacturers of covered products must certify to DOE that their
products comply with any applicable energy conservation standards. In
certifying compliance, manufacturers must test their products according
to the applicable DOE test procedure, including any amendments adopted
for that test procedure. DOE has established regulations for the
certification and recordkeeping requirements for all covered consumer
products and commercial equipment, including conventional cooking
products. 76 FR 12422 (March 7, 2011). The collection-of-information
requirement for the certification and recordkeeping is subject to
review and approval by OMB under the Paperwork Reduction Act (PRA).
This requirement has been approved by OMB under OMB control number
1910-1400. DOE requested OMB approval of an extension of this
information collection for 3 years, specifically including the
collection of information proposed in the present rulemaking, and
estimated that the annual number of burden hours under this extension
is 30 hours per company. In response to DOE's request, OMB approved
DOE's information collection requirements covered under OMB control
number 1910-1400 through November 30, 2017. 80 FR 5099 (Jan. 30, 2015).
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a penalty
for failure to comply with, a collection of information subject to the
requirements of the PRA, unless that collection of information displays
a currently valid OMB Control Number.
D. Review Under the National Environmental Policy Act of 1969
Pursuant to the National Environmental Policy Act (NEPA) of 1969,
DOE has determined that the proposed rule fits within the category of
actions included in Categorical Exclusion (CX) B5.1 and otherwise meets
the requirements for application of a CX. See 10 CFR part 1021, App. B,
B5.1(b); 1021.410(b) and App. B, B(1)-(5). The proposed rule fits
within the category of actions because it is a rulemaking that
establishes energy conservation standards for consumer products or
industrial equipment, and for which none of the exceptions identified
in CX B5.1(b) apply. Therefore, DOE has made a CX determination for
this rulemaking, and DOE does not need to prepare an Environmental
Assessment or Environmental Impact Statement for this proposed rule.
DOE's CX
[[Page 60871]]
determination for this proposed rule is available at http://cxnepa.energy.gov/.
E. Review Under Executive Order 13132
Executive Order 13132, ``Federalism.'' 64 FR 43255 (Aug. 10, 1999)
imposes certain requirements on Federal agencies formulating and
implementing policies or regulations that preempt State law or that
have Federalism implications. The Executive Order requires agencies to
examine the constitutional and statutory authority supporting any
action that would limit the policymaking discretion of the States and
to carefully assess the necessity for such actions. The Executive Order
also requires agencies to have an accountable process to ensure
meaningful and timely input by State and local officials in the
development of regulatory policies that have Federalism implications.
On March 14, 2000, DOE published a statement of policy describing the
intergovernmental consultation process it will follow in the
development of such regulations. 65 FR 13735. EPCA governs and
prescribes Federal preemption of State regulations as to energy
conservation for the products that are the subject of this proposed
rule. States can petition DOE for exemption from such preemption to the
extent, and based on criteria, set forth in EPCA. (42 U.S.C. 6297) No
further action is required by Executive Order 13132.
F. Review Under Executive Order 12988
With respect to the review of existing regulations and the
promulgation of new regulations, section 3(a) of Executive Order 12988,
``Civil Justice Reform,'' imposes on Federal agencies the general duty
to adhere to the following requirements: (1) Eliminate drafting errors
and ambiguity; (2) write regulations to minimize litigation; (3)
provide a clear legal standard for affected conduct rather than a
general standard; and (4) promote simplification and burden reduction.
61 FR 4729 (Feb. 7, 1996). Regarding the review required by section
3(a), section 3(b) of Executive Order 12988 specifically requires that
Executive agencies make every reasonable effort to ensure that the
regulation: (1) Clearly specifies the preemptive effect, if any; (2)
clearly specifies any effect on existing Federal law or regulation; (3)
provides a clear legal standard for affected conduct while promoting
simplification and burden reduction; (4) specifies the retroactive
effect, if any; (5) adequately defines key terms; and (6) addresses
other important issues affecting clarity and general draftsmanship
under any guidelines issued by the Attorney General. Section 3(c) of
Executive Order 12988 requires Executive agencies to review regulations
in light of applicable standards in section 3(a) and section 3(b) to
determine whether they are met or it is unreasonable to meet one or
more of them. DOE has completed the required review and determined
that, to the extent permitted by law, this proposed rule meets the
relevant standards of Executive Order 12988.
G. Review Under the Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA)
requires each Federal agency to assess the effects of Federal
regulatory actions on State, local, and Tribal governments and the
private sector. Public Law 104-4, sec. 201 (codified at 2 U.S.C. 1531).
For a proposed regulatory action likely to result in a rule that may
cause the expenditure by State, local, and Tribal governments, in the
aggregate, or by the private sector of $100 million or more in any one
year (adjusted annually for inflation), section 202 of UMRA requires a
Federal agency to publish a written statement that estimates the
resulting costs, benefits, and other effects on the national economy.
(2 U.S.C. 1532(a), (b)) The UMRA also requires a Federal agency to
develop an effective process to permit timely input by elected officers
of State, local, and Tribal governments on a proposed ``significant
intergovernmental mandate,'' and requires an agency plan for giving
notice and opportunity for timely input to potentially affected small
governments before establishing any requirements that might
significantly or uniquely affect small governments. On March 18, 1997,
DOE published a statement of policy on its process for
intergovernmental consultation under UMRA. 62 FR 12820. DOE's policy
statement is also available at http://energy.gov/gc/office-general-counsel.
Although the proposed rule does not contain a Federal
intergovernmental mandate, it may require expenditures of $100 million
or more in any one year by the private sector. Such expenditures may
include: (1) Investment in research and development and in capital
expenditures by conventional cooking product manufacturers in the years
between the final rule and the compliance date for the new standards,
and (2) incremental additional expenditures by consumers to purchase
higher-efficiency conventional cooking products.
Section 202 of UMRA authorizes a Federal agency to respond to the
content requirements of UMRA in any other statement or analysis that
accompanies the proposed rule. 2 U.S.C. 1532(c). The content
requirements of section 202(b) of UMRA relevant to a private sector
mandate substantially overlap the economic analysis requirements that
apply under section 325(o) of EPCA and Executive Order 12866. The
SUPPLEMENTARY INFORMATION section of this SNOPR and the ``Regulatory
Impact Analysis'' section of the TSD for this proposed rule respond to
those requirements.
Under section 205 of UMRA, the Department is obligated to identify
and consider a reasonable number of regulatory alternatives before
promulgating a rule for which a written statement under section 202 is
required. 2 U.S.C. 1535(a). DOE is required to select from those
alternatives the most cost-effective and least burdensome alternative
that achieves the objectives of the proposed rule unless DOE publishes
an explanation for doing otherwise, or the selection of such an
alternative is inconsistent with law. As required by 42 U.S.C. 6295(d),
(f), and (o), 6313(e), and 6316(a), this proposed rule would establish
new and amended energy conservation standards for conventional cooking
products that are designed to achieve the maximum improvement in energy
efficiency that DOE has determined to be both technologically feasible
and economically justified. A full discussion of the alternatives
considered by DOE is presented in the ``Regulatory Impact Analysis''
section of the TSD for the proposed rule.
H. Review Under the Treasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any rule that may affect family well-being.
This rule would not have any impact on the autonomy or integrity of the
family as an institution. Accordingly, DOE has concluded that it is not
necessary to prepare a Family Policymaking Assessment.
I. Review Under Executive Order 12630
Pursuant to Executive Order 12630, ``Governmental Actions and
Interference with Constitutionally Protected Property Rights'' 53 FR
8859 (Mar. 18, 1988), DOE has determined that this regulation would not
result in any takings that might require compensation under the Fifth
Amendment to the U.S. Constitution.
[[Page 60872]]
J. Review Under the Treasury and General Government Appropriations Act,
2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (44 U.S.C. 3516, note) provides for Federal agencies to
review most disseminations of information to the public under
information quality guidelines established by each agency pursuant to
general guidelines issued by OMB. OMB's guidelines were published at 67
FR 8452 (Feb. 22, 2002), and DOE's guidelines were published at 67 FR
62446 (Oct. 7, 2002). DOE has reviewed the SNOPR under the OMB and DOE
guidelines and has concluded that it is consistent with applicable
policies in those guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ``Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use'' 66 FR 28355
(May 22, 2001), requires Federal agencies to prepare and submit to OIRA
at OMB, a Statement of Energy Effects for any proposed significant
energy action. A ``significant energy action'' is defined as any action
by an agency that promulgates or is expected to lead to promulgation of
a final rule, and that: (1) Is a significant regulatory action under
Executive Order 12866, or any successor order; and (2) is likely to
have a significant adverse effect on the supply, distribution, or use
of energy, or (3) is designated by the Administrator of OIRA as a
significant energy action. For any proposed significant energy action,
the agency must give a detailed statement of any adverse effects on
energy supply, distribution, or use should the proposal be implemented,
and of reasonable alternatives to the action and their expected
benefits on energy supply, distribution, and use.
DOE has tentatively concluded that this regulatory action, which
sets forth energy conservation standards for conventional cooking
products, is not a significant energy action because the proposed
standards are not likely to have a significant adverse effect on the
supply, distribution, or use of energy, nor has it been designated as
such by the Administrator at OIRA. Accordingly, DOE has not prepared a
Statement of Energy Effects on the proposed rule.
L. Review Under the Information Quality Bulletin for Peer Review
On December 16, 2004, OMB, in consultation with the Office of
Science and Technology Policy (OSTP), issued its Final Information
Quality Bulletin for Peer Review (the Bulletin). 70 FR 2664 (Jan. 14,
2005). The Bulletin establishes that certain scientific information
shall be peer reviewed by qualified specialists before it is
disseminated by the Federal Government, including influential
scientific information related to agency regulatory actions. The
purpose of the bulletin is to enhance the quality and credibility of
the Government's scientific information. Under the Bulletin, the energy
conservation standards rulemaking analyses are ``influential scientific
information,'' which the Bulletin defines as scientific information the
agency reasonably can determine will have, or does have, a clear and
substantial impact on important public policies or private sector
decisions. 70 FR 2667.
In response to OMB's Bulletin, DOE conducted formal in-progress
peer reviews of the energy conservation standards development process
and analyses and has prepared a Peer Review Report pertaining to the
energy conservation standards rulemaking analyses. Generation of this
report involved a rigorous, formal, and documented evaluation using
objective criteria and qualified and independent reviewers to make a
judgment as to the technical/scientific/business merit, the actual or
anticipated results, and the productivity and management effectiveness
of programs and/or projects. The ``Energy Conservation Standards
Rulemaking Peer Review Report'' dated February 2007 has been
disseminated and is available at the following Web site:
www1.eere.energy.gov/buildings/appliance_standards/peer_review.html.
VII. Public Participation
A. Submission of Comments
DOE will accept comments, data, and information regarding this
proposed rule no later than the date provided in the DATES section at
the beginning of this proposed rule. Interested parties may submit
comments, data, and other information using any of the methods
described in the ADDRESSES section at the beginning of this SNOPR.
Submitting comments via www.regulations.gov. The
www.regulations.gov Web page will require you to provide your name and
contact information. Your contact information will be viewable to DOE
Building Technologies staff only. Your contact information will not be
publicly viewable except for your first and last names, organization
name (if any), and submitter representative name (if any). If your
comment is not processed properly because of technical difficulties,
DOE will use this information to contact you. If DOE cannot read your
comment due to technical difficulties and cannot contact you for
clarification, DOE may not be able to consider your comment.
However, your contact information will be publicly viewable if you
include it in the comment itself or in any documents attached to your
comment. Any information that you do not want to be publicly viewable
should not be included in your comment, nor in any document attached to
your comment. Otherwise, persons viewing comments will see only first
and last names, organization names, correspondence containing comments,
and any documents submitted with the comments.
Do not submit to www.regulations.gov information for which
disclosure is restricted by statute, such as trade secrets and
commercial or financial information (hereinafter referred to as
Confidential Business Information (CBI)). Comments submitted through
www.regulations.gov cannot be claimed as CBI. Comments received through
the Web site will waive any CBI claims for the information submitted.
For information on submitting CBI, see the Confidential Business
Information section below.
DOE processes submissions made through www.regulations.gov before
posting. Normally, comments will be posted within a few days of being
submitted. However, if large volumes of comments are being processed
simultaneously, your comment may not be viewable for up to several
weeks. Please keep the comment tracking number that www.regulations.gov
provides after you have successfully uploaded your comment.
Submitting comments via email, hand delivery/courier, or mail.
Comments and documents submitted via email, hand delivery/courier, or
mail also will be posted to www.regulations.gov. If you do not want
your personal contact information to be publicly viewable, do not
include it in your comment or any accompanying documents. Instead,
provide your contact information in a cover letter. Include your first
and last names, email address, telephone number, and optional mailing
address. The cover letter will not be publicly viewable as long as it
does not include any comments
Include contact information each time you submit comments, data,
documents, and other information to DOE. If you submit via mail or hand
delivery/courier, please provide all items on a CD, if feasible, in
which case it is not
[[Page 60873]]
necessary to submit printed copies. No telefacsimiles (faxes) will be
accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, that are written in English, and that are free of any
defects or viruses. Documents should not contain special characters or
any form of encryption and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
into one or more PDFs. This reduces comment processing and posting
time.
Confidential Business Information. Pursuant to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email, postal mail, or hand delivery/courier two well-marked copies:
One copy of the document marked ``confidential'' including all the
information believed to be confidential, and one copy of the document
marked ``non-confidential'' with the information believed to be
confidential deleted. Submit these documents via email or on a CD, if
feasible. DOE will make its own determination about the confidential
status of the information and treat it according to its determination.
Factors of interest to DOE when evaluating requests to treat
submitted information as confidential include: (1) A description of the
items; (2) whether and why such items are customarily treated as
confidential within the industry; (3) whether the information is
generally known by or available from other sources; (4) whether the
information has previously been made 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) when such information might lose its
confidential character due to the passage of time; and (7) why
disclosure of the information would be contrary to the public interest.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
B. Issues on Which DOE Seeks Comment
Although DOE welcomes comments on any aspect of this proposal, DOE
is particularly interested in receiving comments and views of
interested parties concerning the following issues:
1. DOE welcomes comments on whether there are products currently
available on the market that would meet DOE's definition of a
conventional oven, but that could not be tested according to the DOE
test procedures adopted in adopted in the July 2015 TP Final Rule (see
section III.A of this SNOPR).
2. DOE requests comment on the proposed product classes for
residential conventional cooking products. DOE welcomes comment and
data on the determination that conventional gas cooking products with
higher input rates (i.e., ``commercial-style'' products) do not warrant
establishing a separate product class. DOE also requests comment on its
conclusion that cooking efficiency for gas cooking tops is more closely
related to burner and grate design rather than input rate per se (see
section IV.A.2.a of this SNOPR).
3. DOE seeks comment the proposed determination to consider
induction heating as a technology option for electric smooth cooking
tops rather than as a separate product class. DOE noted that induction
heating provides the same basic function of cooking or heating food as
heating by gas flame or electric resistance and that the installation
options available to consumers are also the same for both cooking
products with induction and electric resistance heating. DOE also noted
that the utility of speed of cooking, ease of cleaning, and
requirements for specific cookware for induction cooking tops do not
appear to be uniquely associated with higher energy use compared to
other smooth cooking tops with electric resistance heating elements
(see section IV.A.2.a of this SNOPR).
4. DOE requests comment on its determination to consider self-clean
ovens as a separate product class and that the self-cleaning function
of the self-clean oven may employ methods other than a high temperature
pyrolytic cycle to perform the cleaning action. DOE welcomes data on
the effectiveness and frequency of consumer use of pyrolytic versus
non-pyrolytic self-cleaning technologies (see section IV.A.2.b of this
SNOPR).
5. DOE welcomes comment on whether improved contact conductance
should be considered as a technology option, in particular information
and data substantiating the claims that radiation acts like conduction
at very short distances and the degree to which the heating element or
cookware may deform and impact the heat transfer between the two
surfaces (see section IV.A.3.a of this SNOPR).
6. DOE requests comment on the proposed definitions of the terms
``intermittent/interrupted ignition'' and ``intermittent pilot
ignition'' (see section IV.A.3.b of this SNOPR).
7. DOE requests comment on whether a reduced vent rate should be
considered a design option and whether a reduction in vent rate could
be used to reduce the energy consumption of conventional electric
standard ovens (see section IV.A.3.b of this SNOPR).
8. DOE requests comment and data regarding additional design
options or variants of the considered design options that can increase
the range of considered efficiency improvements for conventional
cooking tops, including design options that may not yet be found in the
market (see section IV.B.2 of this SNOPR).
9. DOE requests comment on the proposed baseline and incremental
efficiency levels. DOE specifically requests inputs and test data on
the baseline efficiency levels and the efficiency improvements
associated with the design options identified at each incremental
efficiency level that were determined based on either the analysis from
the 2009 TSD or updated based on testing and reverse engineering
analyses for this SNOPR (see section IV.C.3 of this SNOPR).
10. DOE requests input and data on the proposed incremental
manufacturing production costs for each efficiency level analyzed that
were determined based on either the analysis from the 2009 TSD adjusted
to reflect changes in the PPI or costs determined based on testing and
reverse engineering analyses conducted for this SNOPR (see section
IV.C.4 of this SNOPR).
11. DOE seeks comment on the tentative determination that the
proposed efficiency levels and design options would not impact the
consumer utility of conventional cooking products (see section IV.C.5
of this SNOPR).
12. DOE requests comments on its repair cost estimation for gas
ovens, as well as on its decision not to include changes in repair and
maintenance costs for products more efficient than baseline products
for electric cooking products (see section IV.F.5 of this SNOPR).
13. DOE requests comments on the use of a consumer choice model to
establish the no-new standards case and standards case efficiency
distribution for both electric and gas cooking products (see section of
this IV.F.9 SNOPR)
[[Page 60874]]
14. DOE requests comments on it approach to developing the
shipments forecast and the use of relevant data in the shipments
analysis (see section IV.G of this SNOPR).
15. DOE requests comment on extending data it received from AHAM on
the average lifetime for ovens to cooktop products as well, resulting
in an average lifetime estimate for all gas ovens and cooktops of 13
years and all electric ovens and cooktops of 16 years (See section
IV.F. 6).
16. DOE requests data that would allow for use of different price
trend projections for electric and gas cooking products (see section
IV.H.3.b of this SNOPR).
17. To estimate the impact on shipments of the price increase for
the considered efficiency levels, DOE determined that the new
construction market will be inelastic to price changes and will not
impact shipments, and any impact of the price increase would be on the
replacement market. DOE welcomes input on the effect of new and amended
standards on impacts across products within the same fuel class and
equipment (see section IV.G of this SNOPR).
18. DOE requests comment on the reasonableness of the approach DOE
has used to consider the rebound effect with higher-efficiency cooking
products (see section IV.F.3 of this document).
19. DOE requests comment on DOE's approach for estimating monetary
benefits associated with emissions reductions (see section IV.L of this
SNOPR).
20. DOE seeks comment on the use of 1.20 as a manufacturer markup
for all residential conventional cooking products (see section IV.J.2
of this SNOPR).
21. DOE seeks comment on the potential domestic employment impacts
to residential conventional cooking product manufacturers at the
proposed efficiency levels (see section V.B.2 of this SNOPR).
22. DOE requests comment on any potential manufacturer capacity
constraints caused by the proposed standards in this SNOPR, TSL 2 (see
section V.B.2 of this SNOPR).
23. DOE requests comment on the two manufacturer subgroups that DOE
identified, the impacts of the proposed standards on those manufacturer
subgroups, and any other potential manufacturer subgroups that could be
disproportionally impacted by this rulemaking (see section V.B.2 of
this SNOPR).
24. DOE seeks comment on the compliance costs of any other
regulations that residential conventional cooking product manufacturers
may incur, especially if compliance with those regulations is required
3 years before or after the estimated compliance date of this proposed
standard (2019) (see section V.B.2 of this SNOPR).
25. DOE requests comments on the number of small businesses
identified and on the impacts of new and amended energy conservation
standards on small businesses, including small rebranders and small
manufacturers (see section VI.B of this SNOPR).
VIII. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this proposed
rule.
List of Subjects
10 CFR Part 429
Confidential business information, Energy conservation, Household
appliances, Imports, Reporting and recordkeeping requirements.
10 CFR Part 430
Administrative practice and procedure, Confidential business
information, Energy conservation, Household appliances, Imports,
Intergovernmental relations, Reporting and recordkeeping requirements,
and Small businesses.
Issued in Washington, DC, on August 16, 2016.
David Friedman,
Acting Assistant Secretary, Energy Efficiency and Renewable Energy.
For the reasons set forth in the preamble, DOE proposes to amend
parts 429 and 430 of chapter II, subchapter D, of title 10 of the Code
of Federal Regulations, as set forth below:
PART 429--CERTIFICATION, COMPLIANCE, AND ENFORCEMENT FOR CONSUMER
PRODUCTS AND COMMERCIAL AND INDUSTRIAL EQUIPMENT
0
1. The authority citation for part 429 continues to read as follows:
Authority: 42 U.S.C. 6291-6317; 28 U.S.C, 2461 note.
0
2. Section 429.23 is revised to read as follows:
Sec. 429.23 Cooking products.
(a) Sampling plan for selection of units for testing. (1) The
requirements of Sec. 429.11 are applicable to cooking products; and
(2) For each basic model of cooking products a sample of sufficient
size shall be randomly selected and tested to ensure that any
represented value of estimated annual operating cost, standby mode
power consumption, off mode power consumption, annual energy
consumption, integrated annual energy consumption, or other measure of
energy consumption of a basic model for which consumers would favor
lower values shall be greater than or equal to the higher of:
[[Page 60875]]
[GRAPHIC] [TIFF OMITTED] TP02SE16.002
And x is the sample mean; s is the sample standard deviation; n
is the number of samples; and t0.975 is the t statistic
for a 97.5% one-tailed confidence interval with n-1 degrees of
freedom (from Appendix A).
(b) Certification reports. (1) The requirements of Sec. 429.12 are
applicable to cooking products; and
(2) Pursuant to Sec. 429.12(b)(13), a certification report shall
include the following public product-specific information:
(i) Conventional gas cooking tops: The integrated annual energy
consumption in thousand British thermal units per year (kBtu/yr);
(ii) Conventional electric cooking tops: The integrated annual
energy consumption in thousand watt-hours per year (kWh/yr);
(iii) Conventional gas ovens: The type of gas ignition and power
supply with a declaration that the manufacturer has incorporated the
applicable design requirements;
(iv) Conventional electric ovens: The type of power supply with a
declaration that the manufacturer has incorporated the applicable
design requirements; and
(v) Microwave ovens: The average standby power in watts (W).
PART 430--ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS
0
3. The authority citation for part 430 continues to read as follows:
Authority: 42 U.S.C. 6291-6309; 28 U.S.C. 2461 note.
0
4. Section 430.2 is amended by adding definitions for ``intermittent/
interrupted ignition'' and ``intermittent pilot ignition'' in
alphabetical order to read as follows:
Sec. 430.2 Definitions.
* * * * *
Intermittent/interrupted ignition is an ignition source which is
ignited or energized upon initiation of each main burner operational
cycle and which is extinguished or no longer energized after the main
burner is ignited.
Intermittent pilot ignition is an ignition source which, upon
initiation of each main burner operational cycle, ignites a pilot that
remains lit continuously during the main burner operational cycle and
is extinguished when the main burner operational cycle is completed.
* * * * *
0
5. In Sec. 430.32, revise paragraph (j) to read as follows:
Sec. 430.32 Energy and water conservation standards and their
compliance dates.
* * * * *
(j) Cooking Products. (1) The control system of a conventional oven
shall:
(i) Not be equipped with a constant burning pilot light for gas
ovens manufactured on or after April 9, 2012;
(ii) Be equipped with an intermittent/interrupted ignition or
intermittent pilot ignition for gas ovens manufactured on or after
[DATE 3 years after final rule Federal Register publication]; and
(iii) Not be equipped with a linear power supply for electric and
gas ovens manufactured on or after [DATE 3 years after final rule
Federal Register publication].
(2) Conventional cooking tops manufactured on or after [Date 3
years after final rule Federal Register publication] shall have an
integrated annual energy consumption no greater than:
------------------------------------------------------------------------
Maximum
Integrated Annual
Product class Energy
Consumption
(IAEC) (kWh/yr)
------------------------------------------------------------------------
Electric Open (Coil) Element Cooking Tops............ 113.2
Electric Smooth Element Cooking Tops................. 121.2
Gas Cooking Tops..................................... 924.4
------------------------------------------------------------------------
(3) Microwave-only ovens and countertop convection microwave ovens
manufactured on or after June 17, 2016 shall have an average standby
power not more than 1.0 watt. Built-in and over-the-range convection
microwave ovens manufactured on or after June 17, 2016
[[Page 60876]]
shall have an average standby power not more than 2.2 watts.
* * * * *
[FR Doc. 2016-20721 Filed 9-1-16; 8:45 am]
BILLING CODE 6450-01-P