Energy Conservation Program for Consumer Products: Clothes Washer Energy Conservation Standards

Rulemaking

Energy Conservation Program for Consumer Products: Clothes Washer Energy Conservation Standards

Stated Purpose

"Washing Machines to Become More Energy Efficient: Agreement Will Yield Big Savings for Consumers and the Environment"

Summary of RSP Comment

DOE's proposed standards for clothes washers . The standards would force Americans to buy washing machines that DOE estimates will be 57 percent more expensive than machines today, with fewer of the attributes consumers seek. DOE claims that mandating washing machine specifications is necessary to save consumers money through lower operating costs over the life of the machine. Yet, manufacturers currently offer energy- and water-efficient washing machines that would meet the new standards (and, by DOE's calculus, save consumers money), but only five percent of consumers choose to buy them.

Rather than respect (or try to understand) consumers' revealed and expressed preferences, DOE assumes they are either misinformed or irrational, and that DOE knows more than consumers do about the tradeoffs that are important to them. Its analysis focuses purely on potential cost savings over the life of the machine, without considering the value consumers place on the convenience or other attributes that vertical-axis machines offer over horizontal-axis machines. (In particular, H-axis machines tend to load from the side, rather than the top, which consumers prefer.) Furthermore, DOE's conclusion that more energy-efficient machines will save operating costs assumes the machine will wash 392 loads of laundry per year over more than 14 years. Our analysis suggests that consumers who wash under six loads per week would actually lose money, as well as convenience, if DOE imposes the proposed mandate.

If DOE believes that consumers pass up energy efficient washers because they are "misinformed" about operating costs, the only logical solution is to provide consumers with information to make a more informed decision. Cost is only one factor influencing consumer preferences for clothes washers, and eliminating the machines that 95 percent of consumers prefer will not make consumers better off.