Energy Conservation Program: Energy Conservation Standards for Consumer Clothes Dryers
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Abstract
The Energy Policy and Conservation Act, as amended ("EPCA"), prescribes energy conservation standards for various consumer products and certain commercial and industrial equipment, including consumer clothes dryers. EPCA also requires the U.S. Department of Energy ("DOE") to periodically determine whether more stringent standards would be technologically feasible and economically justified, and would result in significant energy savings. In this notice of proposed rulemaking ("NOPR"), DOE proposes amended energy conservation standards for consumer clothes dryers, and also announces a public meeting to receive comment on these proposed standards and associated analyses and results.
Full Text
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<title>Federal Register, Volume 87 Issue 162 (Tuesday, August 23, 2022)</title>
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[Federal Register Volume 87, Number 162 (Tuesday, August 23, 2022)]
[Proposed Rules]
[Pages 51734-51809]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2022-17900]
[[Page 51733]]
Vol. 87
Tuesday,
No. 162
August 23, 2022
Part II
Department of Energy
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10 CFR Part 430
Energy Conservation Program: Energy Conservation Standards for Consumer
Clothes Dryers; Proposed Rule
Federal Register / Vol. 87 , No. 162 / Tuesday, August 23, 2022 /
Proposed Rules
[[Page 51734]]
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DEPARTMENT OF ENERGY
10 CFR Part 430
[EERE-2014-BT-STD-0058]
RIN 1904-AD99
Energy Conservation Program: Energy Conservation Standards for
Consumer Clothes Dryers
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking and announcement of public
meeting.
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SUMMARY: The Energy Policy and Conservation Act, as amended (``EPCA''),
prescribes energy conservation standards for various consumer products
and certain commercial and industrial equipment, including consumer
clothes dryers. EPCA also requires the U.S. Department of Energy
(``DOE'') to periodically determine whether more stringent standards
would be technologically feasible and economically justified, and would
result in significant energy savings. In this notice of proposed
rulemaking (``NOPR''), DOE proposes amended energy conservation
standards for consumer clothes dryers, and also announces a public
meeting to receive comment on these proposed standards and associated
analyses and results.
DATES:
Meeting: DOE will hold a public meeting via webinar on September
13, 2022, from 1:00 p.m. to 4:00 p.m. See section VII, ``Public
Participation'' for webinar registration information, participant
instructions and information about the capabilities available to
webinar participants.
Comments: DOE will accept comments, data, and information regarding
this NOPR no later than October 24, 2022.
Comments regarding the likely competitive impact of the proposed
standard should be sent to the Department of Justice contact listed in
the ADDRESSES section on or before September 22, 2022.
ADDRESSES: Interested persons are encouraged to submit comments using
the Federal eRulemaking Portal at <a href="http://www.regulations.gov">www.regulations.gov</a>. Follow the
instructions for submitting comments. Alternatively, interested persons
may submit comments, identified by docket number EERE-2014-BT-STD-0058,
by any of the following methods:
1. Federal eRulemaking Portal: <a href="http://www.regulations.gov">www.regulations.gov</a>. Follow the
instructions for submitting comments.
2. Email: to <a href="/cdn-cgi/l/email-protection#faa89f89b996958e929f89be88839f8889c8cacbcea9aebecacacfc2ba9f9fd49e959fd49d958c"><span class="__cf_email__" data-cfemail="feac9b8dbd92918a969b8dba8c879b8c8dcccecfcaadaabacececbc6be9b9bd09a919bd0999188">[email protected]</span></a>. Include docket
number EERE-2014-BT-STD-0058 in the subject line of the message.
No telefacsimiles (``faxes'') will be accepted. For detailed
instructions on submitting comments and additional information on this
process, see section IV of this document.
Docket: The docket for this activity, which includes Federal
Register notices, comments, and other supporting documents/materials,
is available for review at <a href="http://www.regulations.gov">www.regulations.gov</a>. All documents in the
docket are listed in the <a href="http://www.regulations.gov">www.regulations.gov</a> index. However, not all
documents listed in the index may be publicly available, such as
information that is exempt from public disclosure.
The docket web page can be found at <a href="http://www.regulations.gov/docket/EERE-2014-BT-STD-0058">www.regulations.gov/docket/EERE-2014-BT-STD-0058</a>. The docket web page contains instructions on how
to access all documents, including public comments, in the docket. See
section VII for information on how to submit comments through
<a href="http://www.regulations.gov">www.regulations.gov</a>.
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 following the instructions at <a href="http://www.RegInfo.gov">www.RegInfo.gov</a>.
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 <a href="/cdn-cgi/l/email-protection#11747f746376683f6265707f7570637562516462757e7b3f767e67"><span class="__cf_email__" data-cfemail="2742494255405e0954534649434655435467525443484d09404851">[email protected]</span></a> on or
before the date specified in the DATES section. Please indicate in the
``Subject'' line of your email the title and Docket Number of this
rulemaking notice.
FOR FURTHER INFORMATION CONTACT:
Mr. Bryan Berringer, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Office, EE-5B,
1000 Independence Avenue SW, Washington, DC 20585-0121. Email:
<a href="/cdn-cgi/l/email-protection#125362627e7b737c71774166737c767360766143677761667b7d7c615277773c767d773c757d64"><span class="__cf_email__" data-cfemail="d091a0a0bcb9b1beb3b583a4b1beb4b1a2b4a381a5b5a3a4b9bfbea390b5b5feb4bfb5feb7bfa6">[email protected]</span></a>.
Ms. Kathryn McIntosh, U.S. Department of Energy, Office of the
General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC
20585-0121. Telephone: (202) 586-2002. Email:
<a href="/cdn-cgi/l/email-protection#0c476d78647e756222416f456278637f644c647d22686369226b637a"><span class="__cf_email__" data-cfemail="307b51445842495e1e7d53795e445f43587058411e545f551e575f46">[email protected]</span></a>.
For further information on how to submit a comment, review other
public comments and the docket, or participate in the public meeting,
contact the Appliance and Equipment Standards Program staff at (202)
287-1445 or by email: <a href="/cdn-cgi/l/email-protection#44053434282d252a27211730252a202536203715312137302d2b2a370421216a202b216a232b32"><span class="__cf_email__" data-cfemail="7e3f0e0e12171f101d1b2d0a1f101a1f0c1a0d2f0b1b0d0a1711100d3e1b1b501a111b50191108">[email protected]</span></a>.
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. Current Process
C. Deviation From Appendix A
III. General Discussion
A. Product Classes and Scope of Coverage
B. Test Procedure
C. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
D. Energy Savings
1. Determination of Savings
2. Significance of Savings
E. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared To Increase in Price (LCC
and PBP)
c. Energy Savings
d. Lessening of Utility or Performance of Products
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion of Related Comments
A. Market and Technology Assessment
1. Scope of Coverage and Product Classes
2. Technology Options
B. Screening Analysis
1. Screened-Out Technologies
a. Thermoelectric Heating, Electric Only
b. Microwave, Electric Only
c. Indirect Heating
d. RF Drying, Electric Only
e. Ultrasonic Drying, Electric Only
2. Remaining Technologies
C. Engineering Analysis
1. Efficiency Analysis
a. Baseline Efficiency Levels
b. Incremental Efficiency Levels
2. Cost Analysis
3. Cost-Efficiency Results
D. Markups Analysis
E. Energy Use Analysis
F. Life-Cycle Cost and Payback Period Analysis
1. Product Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Maintenance and Repair Costs
6. Product Lifetime
7. Discount Rates
[[Page 51735]]
8. Energy Efficiency Distribution in the No-New-Standards Case
9. Payback Period Analysis
G. Shipments Analysis
H. National Impact Analysis
1. Product Efficiency Trends
2. National Energy Savings
3. Net Present Value Analysis
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
2. Government Regulatory Impact Model and Key Inputs
a. Manufacturer Production Costs
b. Shipments Projections
c. Product and Capital Conversion Costs
d. Manufacturer Markup Scenarios
3. Manufacturer Interviews
a. Heat Pump Technology
b. Preservation of Electromechanical Controls
c. Cost Increases and Component Shortages
4. Discussion of MIA Comments
K. Emissions Analysis
1. Air Quality Regulations Incorporated in DOE's Analysis
L. Monetizing Emissions Impacts
M. Utility Impact Analysis
N. Employment Impact Analysis
V. Analytical Results and Conclusions
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash Flow Analysis Results
b. Direct Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Consumer Costs and Benefits
c. Indirect Impacts on Employment
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 Economic Impacts
C. Conclusion
1. Benefits and Burdens of TSLs Considered for Consumer Clothes
Dryers Standards
2. Annualized Benefits and Costs of the Proposed Standards
D. Reporting, Certification, and Sampling Plan
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
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. Information Quality
VII. Public Participation
A. Participation in the Webinar
B. Procedure for Submitting Prepared General Statements for
Distribution
C. Conduct of the Public Meeting
D. Submission of Comments
E. 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 EPCA,\2\ established the Energy
Conservation Program for Consumer Products Other Than Automobiles. (42
U.S.C. 6291-6309) These products include consumer clothes dryers, the
subject of this proposed rulemaking.
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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 Infrastructure Investment and Jobs Act,
Public Law 117-58 (Nov. 15, 2021).
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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 DOE determines 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 NOPR
including new proposed energy conservation standards (proceeding to a
final rule, as appropriate). (42 U.S.C. 6295(m))
In accordance with these and other statutory provisions discussed
in this document, DOE proposes amended energy conservation standards
for consumer clothes dryers. The proposed standards, which are
expressed as the combined energy factor as determined in accordance
with the appendix D2 test procedure (``CEF<INF>D2</INF>'') in pounds
per kilowatt-hour (``lb/kWh'')--a metric based on the clothes dryer
test load weight in pounds (``lb'') divided by the sum of ``active
mode'' and ``inactive mode'' per-cycle energy use in kilowatt-hours
(``kWh''), are shown in Table I.1. These proposed standards, if
adopted, would apply to all consumer clothes dryers listed in Table I.1
manufactured in, or imported into, the United States starting on the
date 3 years after the publication of the final rule for this proposed
rulemaking.
Table I.1--Proposed Energy Conservation Standards for Consumer Clothes
Dryers as Measured Under Appendix D2
------------------------------------------------------------------------
CEFD2 (lb/
Product class kWh)
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1. Electric, Standard (4.4 cubic feet (``ft\3\'') or 3.93
greater capacity)......................................
2. Electric, Compact (120 volts (``V'')) (less than 4.4 4.33
ft\3\ capacity)........................................
3. Vented Electric, Compact (240V) (less than 4.4 ft\3\ 3.57
capacity)..............................................
4. Vented Gas, Standard (4.4 ft\3\ or greater capacity). 3.48
5. Vented Gas, Compact (less than 4.4 ft\3\ capacity)... 2.02
6. Ventless Electric, Compact (240V) (less than 4.4 2.68
ft\3\ capacity)........................................
7. Ventless Electric, Combination Washer-Dryer.......... 2.33
------------------------------------------------------------------------
[[Page 51736]]
DOE also considered more-stringent energy efficiency levels as
potential standards, and is still considering them in this proposed
rulemaking. DOE may also consider adopting more stringent-energy
efficiency levels for some or all classes. However, DOE has tentatively
concluded at this time that the potential burdens of the more-stringent
energy efficiency levels would outweigh the projected benefits.
A. Benefits and Costs to Consumers
Table I.2 presents DOE's evaluation of the economic impacts of the
proposed standards on consumers of consumer clothes dryers, as measured
by the average life-cycle cost (``LCC'') savings and the simple payback
period (``PBP'').\3\ The average LCC savings are positive for all
product classes, and the PBP is less than the average lifetime of
consumer clothes dryers, which is estimated to be 14 years (see section
IV.F of this document).
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\3\ The average LCC savings refer to consumers that are affected
by a standard and are measured relative to the efficiency
distribution in the no-new-standards case, which depicts the market
in the compliance year in the absence of new or amended standards
(see section IV.F.8 of this document). The simple PBP, which is
designed to compare specific efficiency levels, is measured relative
to the baseline product (see section IV.F.9 of this document).
Table I.2--Impacts of Proposed Energy Conservation Standards on
Consumers of Consumer Clothes Dryers
------------------------------------------------------------------------
Average LCC Simple payback
Consumer clothes dryer class savings (2020$) period (years)
------------------------------------------------------------------------
Electric, Standard (4.4 ft\3\ or $578 0.55
greater capacity)..................
Electric, Compact (120V) (less than 160 1.81
4.4 ft\3\ capacity)................
Vented Electric, Compact (240V) 192 1.62
(less than 4.4 ft\3\ capacity).....
Vented Gas, Standard (4.4 ft\3\ or 198 1.95
greater capacity)..................
Vented Gas, Compact (less than 4.4 25.2 5.07
ft\3\ capacity)....................
Ventless Electric, Compact (240V) 145 0.33
(less than 4.4 ft\3\ capacity).....
Ventless Electric, Combination 15.1 0.00
Washer-Dryer.......................
------------------------------------------------------------------------
DOE's analysis of the impacts of the proposed standards on
consumers is described in section IV.F of this document.
B. Impact on Manufacturers
The industry net present value (``INPV'') is the sum of the
discounted cash flows to the industry from the base year through the
end of the analysis period (2022-2056). Using a real discount rate of
7.5 percent, DOE estimates that the INPV for manufacturers of consumer
clothes dryers in the case without amended standards is $1,810.1
million in 2020$. Under the proposed standards, the change in INPV is
estimated to range from -6.4 percent to -4.5 percent, which is
approximately $115.6 million to $81.6 million. In order to bring
products into compliance with amended standards, it is estimated that
the industry would incur total conversion costs of $149.7 million.
DOE's analysis of the impacts of the proposed standards on
manufacturers is described in section IV.J of this document. The
analytic results of the manufacturer impact analysis (``MIA'') are
presented in section V.B.2 of this document.
C. National Benefits and Costs 4
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\4\ All monetary values in this document are expressed in 2020
dollars.
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DOE's analyses indicate that the proposed energy conservation
standards for consumer clothes dryers would save a significant amount
of energy. Relative to the case without amended standards, the lifetime
energy savings for consumer clothes dryers purchased in the 30-year
period that begins in the anticipated year of compliance with the
amended standards (2027-2056) amount to 3.11 quadrillion British
thermal units (``Btu''), or quads.\5\
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\5\ 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 document.
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The cumulative net present value (``NPV'') of total consumer
benefits of the proposed standards for consumer clothes dryers ranges
from $9.07 billion (at a 7-percent discount rate) to $20.8 billion (at
a 3-percent discount rate). This NPV expresses the estimated total
value of future operating-cost savings minus the estimated increased
product costs for consumer clothes dryers purchased in 2027-2056.
In addition, the proposed standards for consumer clothes dryers are
projected to yield significant environmental benefits. DOE estimates
that the proposed standards would result in cumulative emission
reductions (over the same period as for energy savings) of 116 million
metric tons (``Mt'') \6\ of carbon dioxide (``CO<INF>2</INF>''), 42.6
thousand tons of sulfur dioxide (``SO<INF>2</INF>''), 181 thousand tons
of nitrogen oxides (``NO<INF>X</INF>''), 883 thousand tons of methane
(``CH<INF>4</INF>''), 1.09 thousand tons of nitrous oxide
(``N<INF>2</INF>O''), and 0.26 tons of mercury (``Hg'').\7\
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\6\ A metric ton is equivalent to 1.1 short tons. Results for
emissions other than CO<INF>2</INF> are presented in short tons.
\7\ DOE calculated emissions reductions relative to the no-new-
standards case, which reflects key assumptions in the Annual Energy
Outlook 2021 (``AEO2021''). AEO2021 represents current Federal and
State legislation and final implementation of regulations as of the
time of its preparation. See section IV.K of this document for
further discussion of AEO2021 assumptions that effect air pollutant
emissions.
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DOE estimates the value of climate benefits from a reduction in
greenhouse gases using four different estimates of the social cost of
CO<INF>2</INF> (``SC-CO<INF>2</INF>''), the social cost of methane
(``SC-CH<INF>4</INF>''), and the social cost of nitrous oxide (``SC-
N<INF>2</INF>O''). Together these represent the social cost of
greenhouse gases (SC-GHG). DOE used interim SC-GHG values developed by
an Interagency Working Group on the Social Cost of Greenhouse Gases
(``IWG'').\8\ The derivation of these values is discussed in section
IV.L of this document. For presentational purposes, the climate
benefits associated with the average SC-GHG at a 3-percent discount
rate are estimated to be $5.42 billion. DOE does not have a single
central SC-GHG point estimate and it emphasizes the
[[Page 51737]]
importance and value of considering the benefits calculated using all
four SC-GHG estimates.\9\
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\8\ See Interagency Working Group on Social Cost of Greenhouse
Gases, Technical Support Document: Social Cost of Carbon, Methane,
and Nitrous Oxide. Interim Estimates Under Executive Order 13990,
Washington, DC (February 2021) (Available at: <a href="http://www.whitehouse.gov/wp-content/uploads/2021/02/TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf">www.whitehouse.gov/wp-content/uploads/2021/02/TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf</a>)
(Last accessed March 17, 2022).
\9\ On March 16, 2022, the Fifth Circuit Court of Appeals (No.
22-30087) granted the Federal government's emergency motion for stay
pending appeal of the February 11, 2022, preliminary injunction
issued in Louisiana v. Biden, No. 21-cv-1074-JDC-KK (W.D. La.). As a
result of the Fifth Circuit's order, the preliminary injunction is
no longer in effect, pending resolution of the Federal government's
appeal of that injunction or a further court order. Among other
things, the preliminary injunction enjoined the defendants in that
case from ``adopting, employing, treating as binding, or relying
upon'' the interim estimates of the social cost of greenhouse
gases--which were issued by the Interagency Working Group on the
Social Cost of Greenhouse Gases on February 26, 2021--to monetize
the benefits of reducing greenhouse gas emissions. As reflected in
this rule, DOE has reverted to its approach prior to the injunction
and presents monetized greenhouse gas abatement benefits where
appropriate and permissible under law.
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DOE also estimates health benefits from SO<INF>2</INF> and
NO<INF>X</INF> emissions reductions. DOE estimates the present value of
the health benefits would be $3.59 billion using a 7-percent discount
rate, and $9.14 billion using a 3-percent discount rate. DOE is
currently only monetizing (for SO<INF>2</INF> and NO<INF>X</INF>)
PM<INF>2.5</INF> precursor health benefits and (for NO<INF>X</INF>)
ozone precursor health benefits but will continue to assess the ability
to monetize other effects such as health benefits from reductions in
direct PM<INF>2.5</INF> emissions.
Table I.3 summarizes the monetized benefits and costs expected to
result from the proposed standards for consumer clothes dryers. There
are other important unquantified effects, including certain
unquantified climate benefits, unquantified public health benefits from
the reduction of toxic air pollutants and other emissions, unquantified
energy security benefits, and distributional effects, among others.
Table I.3--Summary of Monetized Economic Benefits and Costs of Proposed
Energy Conservation Standards for Consumer Clothes Dryers
[TSL 3]
------------------------------------------------------------------------
Billion 2020$
------------------------------------------------------------------------
3% discount rate
------------------------------------------------------------------------
Consumer Operating Cost Savings....................... 22.2
Climate Benefits *.................................... 5.42
Health Benefits **.................................... 9.14
Total Benefits [dagger]............................... 36.8
Consumer Incremental Product Costs [Dagger]........... 1.36
Net Benefits.......................................... 35.4
------------------------------------------------------------------------
7% discount rate
------------------------------------------------------------------------
Consumer Operating Cost Savings....................... 9.83
Climate Benefits *.................................... 5.42
Health Benefits **.................................... 3.59
Total Benefits [dagger]............................... 18.8
Consumer Incremental Product Costs [Dagger]........... 0.76
Net Benefits.......................................... 18.1
------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with
consumer clothes dryers shipped in 2027-2056. These results include
benefits to consumers which accrue after 2056 from the products
shipped in 2027-2056.
* Climate benefits are calculated using four different estimates of the
social cost of carbon (SC-CO2), methane (SC-CH4), and nitrous oxide
(SC-N2O) (model average at 2.5 percent, 3 percent, and 5 percent
discount rates; 95th percentile at 3 percent discount rate), as shown
in Table V.36, Table V.38, and Table V.40. Together these represent
the global social cost of greenhouse gases (SC-GHG). For
presentational purposes of this table, the climate benefits associated
with the average SC-GHG at a 3 percent discount rate are shown, but
the Department does not have a single central SC-GHG point estimate.
See section. IV.L of this document for more details. On March 16,
2022, the Fifth Circuit Court of Appeals (No. 22-30087) granted the
Federal government's emergency motion for stay pending appeal of the
February 11, 2022, preliminary injunction issued in Louisiana v.
Biden, No. 21-cv-1074-JDC-KK (W.D. La.). As a result of the Fifth
Circuit's order, the preliminary injunction is no longer in effect,
pending resolution of the Federal government's appeal of that
injunction or a further court order. Among other things, the
preliminary injunction enjoined the defendants in that case from
``adopting, employing, treating as binding, or relying upon'' the
interim estimates of the social cost of greenhouse gases--which were
issued by the Interagency Working Group on the Social Cost of
Greenhouse Gases on February 26, 2021--to monetize the benefits of
reducing greenhouse gas emissions. As reflected in this rule, DOE has
reverted to its approach prior to the injunction and presents
monetized greenhouse gas abatement benefits where appropriate and
permissible under law.
** Health benefits are calculated using benefit-per-ton values for NOX
and SO2. DOE is currently only monetizing (for SO2 and NOX) PM2.5
precursor health benefits and (for NOX) ozone precursor health
benefits, but will continue to assess the ability to monetize other
effects such as health benefits from reductions in direct PM2.5
emissions. The health benefits are presented at real discount rates of
3 and 7 percent. See section IV.L of this document for more details.
[dagger] Total and net benefits include those consumer, climate, and
health benefits that can be monetized. For presentation purposes,
total and net benefits for both the 3-percent and 7-percent cases are
presented using the average SC-GHG with 3-percent discount rate, but
the Department does not have a single central SC-GHG point estimate.
DOE emphasizes the importance and value of considering the benefits
calculated using all four SC-GHG estimates. See Table V.46 for net
benefits using all four SC-GHG estimates.
[Dagger] Costs include incremental equipment costs as well as
installation costs.
The benefits and costs of the proposed standards, for consumer
clothes dryers sold in 2027-2056, can also be expressed in terms of
annualized values. The monetary values for the total annualized net
benefits are (1) the reduced consumer operating costs, minus (2) the
increase in product purchase prices and installation costs, plus (3)
the value of the benefits of NO<INF>X</INF> and SO<INF>2</INF> emission
reductions, all annualized.\10\
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\10\ To convert the time-series of costs and benefits into
annualized values, DOE calculated a present value in 2021, 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., 2030), and then discounted the present value from each year
to 2021. The calculation uses discount rates of 3 and 7 percent for
all costs and benefits. 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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[[Page 51738]]
The national operating savings are domestic private U.S. consumer
monetary savings that occur as a result of purchasing the covered
products and are measured for the lifetime of consumer clothes dryers
shipped in 2027-2056. The benefits associated with reduced emissions
achieved as a result of the proposed standards are also calculated
based on the lifetime of consumer clothes dryers shipped in 2027-2056.
Total benefits for both the 3-percent and 7-percent cases are presented
using the average GHG social costs with 3-percent discount rate.
Estimates of SC-GHG values are presented for all four discount rates in
section V.B.8 of this document. Estimates of annualized benefits and
costs of the proposed standards are shown in Table I.4. The results
under the primary estimate are as follows.
Using a 7-percent discount rate for consumer benefits and costs and
health benefits from reduced SO<INF>2</INF> and NO<INF>X</INF>
emissions, the estimated cost of the standards proposed in this rule is
$85.7 million per year in increased equipment costs, while the
estimated annual benefits are $1,111 million in reduced equipment
operating costs, $320 million in climate benefits, and $406 million in
health benefits (accounting for reduced NO<INF>X</INF> emissions and
increased SO<INF>2</INF> emissions). In this case, the net benefit
would amount to $1,752 million per year.
Using a 3-percent discount rate for all benefits and costs, the
estimated cost of the proposed standards is $80.7 million per year in
increased equipment costs, while the estimated annual benefits are
$1,313 million in reduced operating costs, $320 million in climate
benefits, and $541 million in health benefits (accounting for reduced
NO<INF>X</INF> emissions and increased SO<INF>2</INF> emissions). In
this case, the net benefit would amount to $2,094 million per year.
Table I.4--Annualized Monetized Benefits and Costs of Proposed Energy Conservation Standards for Consumer
Clothes Dryers
[TSL 3]
----------------------------------------------------------------------------------------------------------------
Million 2020$/year
-----------------------------------------------
Low-net- High-net-
Primary benefits benefits
estimate estimate estimate
----------------------------------------------------------------------------------------------------------------
3% discount rate
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. 1,313 1,227 1,403
Climate Benefits *.............................................. 320 311 327
Health Benefits **.............................................. 541 526 551
Total Benefits [dagger]......................................... 2,174 2,065 2,280
Consumer Incremental Product Costs [Dagger]..................... 80.7 80.5 76.6
Net Benefits.................................................... 2,094 1,984 2,204
----------------------------------------------------------------------------------------------------------------
7% discount rate
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. 1,111 1,050 1,178
Climate Benefits *.............................................. 320 311 327
Health Benefits **.............................................. 406 395 413
Total Benefits [dagger]......................................... 1,837 1,757 1,917
Consumer Incremental Product Costs [Dagger]..................... 85.7 85.3 82.4
Net Benefits.................................................... 1,752 1,671 1,835
----------------------------------------------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with consumer clothes dryers shipped in 2027-2056.
These results include benefits to consumers which accrue after 2056 from the products shipped in 2027-2056.
* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.L of this
document). For presentational purposes of this table, the climate benefits associated with the average SC-GHG
at a 3 percent discount rate are shown, but the Department does not have a single central SC-GHG point
estimate, and it emphasizes the importance and value of considering the benefits calculated using all four SC-
GHG estimates. On March 16, 2022, the Fifth Circuit Court of Appeals (No. 22-30087) granted the federal
government's emergency motion for stay pending appeal of the February 11, 2022, preliminary injunction issued
in Louisiana v. Biden, No. 21-cv-1074-JDC-KK (W.D. La.). As a result of the Fifth Circuit's order, the
preliminary injunction is no longer in effect, pending resolution of the federal government's appeal of that
injunction or a further court order. Among other things, the preliminary injunction enjoined the defendants in
that case from ``adopting, employing, treating as binding, or relying upon'' the interim estimates of the
social cost of greenhouse gases--which were issued by the Interagency Working Group on the Social Cost of
Greenhouse Gases on February 26, 2021--to monetize the benefits of reducing greenhouse gas emissions. As
reflected in this rule, DOE has reverted to its approach prior to the injunction and presents monetized
greenhouse gas abatement benefits where appropriate and permissible under law.
** Health benefits are calculated using benefit-per-ton values for NOX and SO2. DOE is currently only monetizing
(for SO2 and NOX) PM2.5 precursor health benefits and (for NOX) ozone precursor health benefits, but will
continue to assess the ability to monetize other effects such as health benefits from reductions in direct
PM2.5 emissions. The health benefits are presented at real discount rates of 3 and 7 percent. See section IV.L
of this document for more details.
[dagger] Total benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with 3-
percent discount rate, but the Department does not have a single central SC-GHG point estimate. DOE emphasizes
the importance and value of considering the benefits calculated using all four SC-GHG estimates.
[Dagger] Costs include incremental equipment costs as well as installation costs.
DOE's analysis of the national impacts of the proposed standards is
described in sections IV.H, IV.K and IV.L of this document.
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. Specifically, with regards to
technological feasibility, products achieving these standard levels are
already commercially available for all product classes covered by this
proposal. As for economic justification,
[[Page 51739]]
DOE's analysis shows that the benefits of the proposed standard exceed,
to a great extent, the burdens of the proposed standards. Using a 7-
percent discount rate for consumer benefits and costs and
NO<INF>X</INF> and SO<INF>2</INF> reduction benefits, the estimated
cost of the proposed standards for consumer clothes dryers is $85.7
million per year in increased product costs, while the estimated annual
benefits are $1,111 million in reduced product operating costs, and
$406 million in health benefits. The net benefit amounts to $1,752
million per year.
The significance of energy savings offered by a new or amended
energy conservation standard cannot be determined without knowledge of
the specific circumstances surrounding a given rulemaking.\11\ For
example, some covered products and equipment have substantial energy
consumption occur during periods of peak energy demand. The impacts of
these products on the energy infrastructure can be more pronounced than
products with relatively constant demand. In evaluating the
significance of energy savings, DOE considers differences in primary
energy and FFC effects for different covered products and equipment
when determining whether energy savings are significant. Primary energy
and FFC effects include the energy consumed in electricity production
(depending on load shape), in distribution and transmission, and in
extracting, processing, and transporting primary fuels (i.e., coal,
natural gas, petroleum fuels), and thus present a more complete picture
of the impacts of energy conservation standards. Accordingly, DOE
evaluates the significance of energy savings on a case-by-case basis.
---------------------------------------------------------------------------
\11\ Procedures, Interpretations, and Policies for Consideration
in New or Revised Energy Conservation Standards and Test Procedures
for Consumer Products and Commercial/Industrial Equipment, 86 FR
70892, 70901 (Dec. 13, 2021).
---------------------------------------------------------------------------
As previously mentioned, the standards are projected to result in
estimated national energy savings of 3.11 quads, the equivalent of the
electricity consumption of 78 million residential homes in one
year.\12\ DOE has initially determined the energy savings from the
proposed standard levels are ``significant'' within the meaning of 42
U.S.C. 6295(o)(3)(B). A more detailed discussion of the basis for these
tentative conclusions is contained in the remainder of this document
and the accompanying technical support document (``TSD'').
---------------------------------------------------------------------------
\12\ U.S. Environmental Protection Agency, Greenhouse Gas
Equivalencies Calculator. Available at <a href="http://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator">www.epa.gov/energy/greenhouse-gas-equivalencies-calculator</a>.
---------------------------------------------------------------------------
DOE also considered more-stringent energy efficiency levels as
potential standards, and is still considering them in this proposed
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 document and related information collected and
analyzed during the course of this rulemaking effort, DOE may adopt
energy efficiency levels presented in this document 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 proposed rule, as well as some of the relevant
historical background related to the establishment of standards for
consumer clothes dryers.
A. Authority
EPCA authorizes DOE to regulate the energy efficiency of a number
of consumer products and certain industrial equipment. Title III, Part
B of EPCA established the Energy Conservation Program for Consumer
Products Other Than Automobiles. These products include consumer
clothes dryers, the subject of this document. (42 U.S.C. 6292(a)(8))
EPCA prescribed energy conservation standards for these products (42
U.S.C. 6295(g)(3)), and directs DOE to conduct future rulemakings to
determine whether to amend these standards. (42 U.S.C. 6295(g)(4)) EPCA
further provides that, not later than 6 years after the 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 NOPR including new proposed energy conservation
standards (proceeding to a final rule, as appropriate). (42 U.S.C.
6295(m)(1)).
The energy conservation program under EPCA consists essentially of
four parts: (1) testing, (2) labeling, (3) the establishment of Federal
energy conservation standards, and (4) certification and enforcement
procedures. Relevant provisions of EPCA specifically include
definitions (42 U.S.C. 6291), test procedures (42 U.S.C. 6293),
labeling provisions (42 U.S.C. 6294), energy conservation standards (42
U.S.C. 6295), and the authority to require information and reports from
manufacturers (42 U.S.C. 6296).
Federal energy efficiency requirements for covered products
established under EPCA generally supersede State laws and 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 EPCA. (See 42
U.S.C. 6297(d)).
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.
6295(o)(3)(A) and 42 U.S.C. 6295(r)) 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 42 U.S.C. 6295(s)) Similarly,
DOE must use these test procedures to determine whether the products
comply with standards adopted pursuant to EPCA. (42 U.S.C. 6295(s)) The
DOE test procedures for consumer clothes dryers appear at title 10 of
the Code of Federal Regulations (``CFR'') part 430, subpart B, appendix
D1 and appendix D2 (``appendix D1'' and ``appendix D2'', respectively).
DOE must follow specific statutory criteria for prescribing new or
amended standards for covered products, including consumer clothes
dryers. Any new or amended standard for a covered product must be
designed to achieve the maximum improvement in energy efficiency that
the Secretary of Energy determines is technologically feasible and
economically justified. (42 U.S.C. 6295(o)(2)(A) and 42 U.S.C.
6295(o)(3)(B)) Furthermore, DOE may not adopt any standard that would
not result in the significant conservation of energy. (42 U.S.C.
6295(o)(3) (B))
Moreover, DOE may not prescribe a standard if DOE determines by
rule that the standard is not technologically feasible or economically
justified. (42 U.S.C. 6295(o)(3)(B)) In deciding whether a proposed
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
[[Page 51740]]
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
standard;
(3) The total projected amount of energy (or as applicable,
water) savings likely to result directly from the standard;
(4) Any lessening of the utility or the performance of the
covered products likely to result from 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
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))
Further, 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 applicable test
procedure. (42 U.S.C. 6295(o)(2)(B)(iii))
EPCA 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 in 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))
Additionally, EPCA specifies requirements when promulgating an
energy conservation standard for a covered product that has two or more
product classes. DOE must specify a different standard level for a type
or class of product that has 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))
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
a single 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 consumer clothes
dryers address standby mode and off mode energy use. In this
rulemaking, DOE intends to incorporate such energy use into any amended
energy conservation standards that it may adopt.
B. Background
1. Current Standards
The most recent standards rulemaking for consumer clothes dryers
was promulgated on April 21, 2011. Specifically, DOE published a direct
final rule (the ``2011 Direct Final Rule'') amending the energy
conservation standard for consumer clothes dryers manufactured on and
after January 1, 2015. 76 FR 22454 (Apr. 21, 2011). The energy
conservation standards, as amended in the 2011 Direct Final Rule,
represent the current standards and are in accordance with the appendix
D1 test procedure as discussed in section III.B of this document. They
are based on combined energy factor (``CEF'')--a metric that
incorporates energy use in active mode, standby mode, and off mode.
Compliance with the current standards was required as of January 1,
2015. 76 FR 52852 (Aug. 24, 2011).
Even though DOE maintained the same energy-efficiency descriptor
for both appendix D1 and appendix D2, DOE notes that the CEF values are
not equivalent because of the extensive differences in test methods. To
avoid potential confusion that would result from using the same
efficiency descriptor for both test procedures as it relates to the
standards discussed in this document, DOE is including a ``D1'' or
``D2'' subscript when referring to the appendix D1 CEF and appendix D2
CEF, respectively (i.e., CEF<INF>D1</INF> and CEF<INF>D2</INF>), in
this document.\13\
---------------------------------------------------------------------------
\13\ Note that while the current standards are based on CEF as
determined in accordance with appendix D1, manufacturers are
permitted to use the appendix D2 test procedure to comply with the
current standards, as long as they use a single appendix for all
representations.
---------------------------------------------------------------------------
These current consumer clothes dryer standards as measured under
appendix D1 are set forth in DOE's regulations at 10 CFR 430.32(h) and
are repeated in Table II.1. DOE has conducted the rulemaking analysis
for this proposed rule under the appendix D2 test procedure because
compliance will be required concurrent with amended energy
conservation, if finalized. DOE discusses additional details about the
engineering baseline in section IV.C.1 of this document.
[[Page 51741]]
Table II.1--Federal Energy Conservation Standards for Consumer Clothes
Dryers as Measured Under Appendix D1
------------------------------------------------------------------------
CEFD1 (lbs/
Product class kWh)
------------------------------------------------------------------------
(A) Vented Electric, Standard (4.4 ft \3\ or greater 3.73
capacity)..............................................
(B) Vented Electric, Compact (120V) (less than 4.4 ft 3.61
\3\ capacity)..........................................
(C) Vented Electric, Compact (240V) (less than 4.4 ft 3.27
\3\ capacity)..........................................
(D) Vented Gas.......................................... 3.30
(E) Ventless Electric, Compact (240V) (less than 4.4 ft 2.55
\3\ capacity)..........................................
(F) Ventless Electric, Combination Washer-Dryer......... 2.08
------------------------------------------------------------------------
On December 16, 2020, DOE published a final rule establishing a
separate product class for consumer clothes dryers that offer cycle
times for a ``normal'' cycle \14\ of less than 30 minutes. 85 FR 81359
(Dec. 16, 2020) (``December 2020 Final Rule''). Because no such
``short-cycle'' consumer clothes dryers are currently on the market in
the United States, DOE did not include analysis of this newly
established product class in the preliminary TSD.
---------------------------------------------------------------------------
\14\ Section 3.3.2 of appendix D2 requires that the ``normal''
program shall be selected for the test cycle; for clothes dryers
that do not have a ``normal'' program, the cycle recommended by the
manufacturer for drying cotton or linen clothes shall be selected.
---------------------------------------------------------------------------
While these short-cycle products had previously been subject to
energy and water conservation standards, the December 2020 Final Rule
stated that short-cycle product classes were no longer subject to any
water or energy conservation standards. 85 FR 68723, 68742; 85 FR
81359, 81376. As a result, the short-cycle products were allowed to
consume unlimited amounts of energy and water.
As discussed in a NOPR subsequently published on August 11, 2021,
DOE noted that in amending the standards for short-cycle products to
allow for unlimited water and energy usage, DOE failed to consider
whether the amended standards met the criteria in EPCA for issuing an
amended standard. Notably, among other things, DOE did not determine,
as required, that the amended standards for short-cycle products were
designed to achieve the maximum improvement in energy efficiency that
is technologically feasible and economically justified. (42 U.S.C.
6295(o)(2)(A)) 86 FR 43970, 43971. DOE has since published a final rule
on January 19, 2022, which revoked the December 2020 Final Rule that
improperly promulgated standards for this new product class and
reinstated the prior product classes and applicable standards for these
covered products. 87 FR 2673, 2686. Therefore, DOE did not include
analysis of a short-cycle product class in the NOPR TSD.
2. Current Process
DOE published a request for information (``RFI'') on March 27, 2015
(the ``March 2015 RFI'') describing the approaches and methods DOE will
use in evaluating potential amended standards for consumer clothes
dryers. 80 FR 16309 (Mar. 27, 2015). In addition, the RFI solicited
information from the public to help DOE determine whether amended
standards for consumer clothes dryers would result in a significant
amount of additional energy savings, and whether those standards would
be technologically feasible and economically justified. Id. The March
2015 RFI is available at <a href="http://www.regulations.gov/document/EERE-2014-BT-STD-0058-0001">www.regulations.gov/document/EERE-2014-BT-STD-0058-0001</a>.
DOE published a notice of public webinar and availability of the
preliminary TSD on April 19, 2021 (``April 2021 Preliminary Analysis'')
to collect data and information to inform its decision consistent with
its obligations under EPCA. 86 FR 20327. DOE subsequently held a public
webinar on May 26, 2021, to discuss and receive comments on the
preliminary TSD. The preliminary TSD that presented the methodology and
results of the preliminary analysis is available at:
<a href="http://www.regulations.gov/document/EERE-2014-BT-STD-0058-0020">www.regulations.gov/document/EERE-2014-BT-STD-0058-0020</a>.
DOE received comments in response to the April 2021 Preliminary
Analysis from the interested parties listed in Table II.2.
Table II.2--April 2021 Preliminary Analysis Written Comments
------------------------------------------------------------------------
Commenter(s) Abbreviation Commenter type
------------------------------------------------------------------------
Association of Home Appliance AHAM.............. Trade Association.
Manufacturers.
Appliance Standards Awareness ASAP, NRDC........ Efficiency
Project, Natural Resources Organizations.
Defense Council.
California Investor-Owned California IOUs... Utilities.
Utilities.
GE Appliances, a Haier Company.. GEA............... Manufacturer.
Whirlpool Corporation........... Whirlpool......... Manufacturer.
Samsung Electronics America..... Samsung........... Manufacturer.
Northwest Energy Efficiency NEEA.............. Efficiency
Alliance. Organization.
Institute for Policy Integrity IPI............... Efficiency
at NYU School of Law. Organization.
------------------------------------------------------------------------
A parenthetical reference at the end of a comment quotation or
paraphrase provides the location of the item in the public record.\15\
---------------------------------------------------------------------------
\15\ The parenthetical reference provides a reference for
information located in the docket of DOE's rulemaking to develop
energy conservation standards for consumer clothes dryers. (Docket
No. EERE-2014-BT-STD-0058, which is maintained at
<a href="http://www.regulations.gov">www.regulations.gov</a>). The references are arranged as follows:
(commenter name, comment docket ID number, page of that document).
---------------------------------------------------------------------------
In response to the preliminary analysis, AHAM and Whirlpool stated
that as laundry products are designed and used in pairs, DOE should
harmonize its rulemaking processes such that the compliance dates for
residential clothes washers and consumer clothes dryers are, if not
identical, very close in time. According to AHAM and Whirlpool, this
would
[[Page 51742]]
greatly reduce burden on manufacturers as they work to design products
to meet amended standards as well as on retailers and consumers as
products are re-floored leading up to and on the compliance date of any
amended energy conservation standards. (AHAM, No. 23 at p. 6;
Whirlpool, No. 27 at p. 13)
DOE appreciates the comments from AHAM and Whirlpool and recognizes
the benefits of aligning the schedule for future amended standards for
both products and may investigate harmonization of future rulemaking
processes.
Additionally, AHAM stated its strong opposition to Natural
Resources Canada's (``NRCan'') proposal to make ENERGY STAR levels the
minimum energy conservation standard for clothes dryers in Canada and
strongly urged DOE to not only weigh in against NRCan's approach
through the U.S.-Canada Regulatory Cooperation Council and under the
recently signed Memorandum of Understanding on energy cooperation, but
also to account for the burden of any misalignment in DOE's analysis.
According to AHAM it is critical that amended standards are coordinated
in both substance and timing in order to maintain a consistent U.S.-
Canadian market for home appliances. (AHAM, No. 23 at p. 9)
DOE notes that review of efficiency standards efforts in other
regions is discussed in chapter 3 of the NOPR TSD. DOE will continue to
review and track these efforts as part of its analysis.
C. Deviation From Appendix A
Section 3(a) of 10 CFR part 430, subpart C, appendix A (``appendix
A'') specifies that, in those instances where the Department may find
it necessary or appropriate to deviate from the procedures,
interpretations or policies that are generally applicable to the
development of energy conservation standards and test procedures, DOE
will provide interested parties with notice of the deviation and an
explanation. DOE finds that it is appropriate to deviate from its
existing procedures by publishing this NOPR instead of releasing an
additional framework document because such activity would be redundant
due to the information previously obtained through the March 2015 RFI
and the preliminary analysis. Additionally, DOE finds it necessary to
deviate from its existing procedures by providing a 60-day comment
period for this NOPR because interested parties received sufficient
time to comment on earlier rulemaking documents that relied on many of
the same analytical assumptions and approaches presented in this
proposal.
In accordance with section 3(a) of appendix A, DOE notes that it is
deviating from the provision in appendix A regarding the pre-NOPR
stages for an energy conservation standards rulemaking. Section 6(a)(2)
of appendix A states that if the Department determines it is
appropriate to proceed with a rulemaking, the preliminary stages of a
rulemaking to issue or amend an energy conservation standard that DOE
will undertake will be a framework document and preliminary analysis,
or an advance notice of proposed rulemaking. DOE is opting to deviate
from this step by publishing a NOPR following the preliminary analysis
without a framework document. A framework document is intended to
introduce and summarize the various analyses DOE conducts during the
rulemaking process and requests initial feedback from interested
parties. As discussed, prior to the preliminary analysis and this NOPR,
DOE published the March 2015 RFI, in which DOE identified and sought
comment on the technical and economic analyses to be conducted in
determining whether amended energy conservation standards would be
justified. See 80 FR 16309. DOE provided a 45-day comment period for
the RFI. Id. Comments received following publication of the March 2015
RFI assisted DOE in identifying and resolving issues related to the
preliminary analyses. 86 FR 20327, 20330. Given the level of comments
received to the March 2015 RFI, publication of a framework document
would be largely redundant with the published RFI and preliminary
analysis. As such, DOE is deviating from the procedures provided in
appendix A and is not publishing a framework document prior to the
publication of this NOPR. The Department has determined that it is
appropriate to proceed with this proposal due to the information
obtained through the March 2015 RFI and the preliminary analysis.
Section 6(f)(2) of appendix A specifies that the length of the
public comment period for a NOPR will vary depending upon the
circumstances of the particular rulemaking, but will not be less than
75 calendar days. For this NOPR, DOE has opted to instead provide a 60-
day comment period. As stated previously DOE requested comment in the
March 2015 RFI on the technical and economic analyses and provided
stakeholders a 45-day comment period. Additionally, DOE provided a 75-
day comment period for the preliminary analysis. 86 FR 20327. DOE has
relied on many of the same analytical assumptions and approaches as
used in the preliminary assessment and has determined that a 60-day
comment period in conjunction with the prior comment periods provides
sufficient time for interested parties to review the proposed rule and
develop comments. As such, DOE has determined that a 75-comment period
is not necessary for this proposal and that a 60-day comment period is
sufficient time for interested stakeholders to submit their comments on
this document.
III. General Discussion
DOE developed this proposal after considering oral and written
comments, data, and information from interested parties that represent
a variety of interests. The following discussion addresses issues
raised by these commenters.
A. Product Classes and Scope of Coverage
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 justify
differing standards. In determining whether a performance-related
feature justifies a different standard, DOE must consider such factors
as the utility of the feature to the consumer and other factors DOE
determines are appropriate. (42 U.S.C. 6295(q)) DOE's review of the
preliminary analysis and comments received in response to the
preliminary analysis, in addition to results from an updated test
sample, are discussed in more detail in section IV.A of this document.
B. 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. On October
8, 2021, DOE published a final rule for the test procedure rulemaking
(86 FR 56608) (the ``October 2021 TP Final Rule''), in which it amended
appendix D1 and appendix D2, both entitled ``Uniform Test Method for
Measuring the Energy Consumption of Clothes Dryers,'' to provide
additional detail in response to questions from manufacturers and test
laboratories, including additional detail regarding the testing of
``connected'' models, dryness level selection, and the procedures for
maintaining the required heat input rate for gas clothes dryers;
[[Page 51743]]
additional detail for the test procedures for performing inactive and
off mode power measurements; specifications for the final moisture
content (``FMC'') required for testing automatic termination control
dryers; specification of a narrower scale resolution for the weighing
scale used to determine moisture content of test loads; and
specification that the test load must be weighed within 5 minutes after
a test cycle has terminated. In addition, DOE amended the test
procedures to update the estimated number of annual use cycles for
clothes dryers; provide further direction for additional provisions
within the test procedures; specify rounding requirements for all
reported values; apply consistent use of nomenclature and correct
typographical errors; remove obsolete sections of the test procedures,
including appendix D; and update the reference to the applicable
industry test procedure to the version certified by the American
National Standards Institute (``ANSI''). 86 FR 56608, 56610 DOE's
current energy conservation standards for consumer clothes dryers are
expressed in terms of CEF<INF>D1</INF>. (See 10 CFR 430.32(h)(3).)
In response to the preliminary analysis, commenters requested that
DOE finalize the test procedure rulemaking prior to proceeding with
energy conservation standards rulemaking in order to capture any
impacts a finalized test procedure would have on amended standards.
(AHAM, No. 22 at pp. 7-8; AHAM, No. 23 at pp. 2-4; California IOUs, No.
26 at pp. 4-5; GEA, No. 28 at p. 2; NEEA, No. 30 at p. 8).
At the time of the publication of the preliminary analysis, the
October 2021 TP Final Rule had not yet published; however, DOE noted in
the October 2021 TP Final Rule that the amendments adopted, other than
the amendment to the number of annual use cycles in appendix D2, would
not substantively alter the measured efficiency of consumer clothes
dryers, and that the test procedures would not be unduly burdensome to
conduct. The amendment to the number of annual use cycles specified for
calculating per-cycle standby mode and off mode energy consumption
would alter the measured energy efficiency of consumer clothes dryers
when using appendix D2, but use of the amended value in appendix D2 is
not required until such time as DOE were to amend the energy
conservations standards accounting for such changes in the test
procedure, should such amended energy conservation standards be
adopted. 86 FR 56608, 56611.
GEA, AHAM, and Samsung requested that DOE review the FMC
requirement according to appendix D2, stating that the current 2-
percent FMC requirement is too strict and not representative of
consumer preference. (GEA, No. 22 at pp. 42-44; AHAM, No. 23 at p. 4;
Samsung, No. 29 at pp. 2-3) AHAM questioned the degree of savings that
can be achieved through more stringent standards, stating that the
energy conservation standards would have less of an impact on consumer
clothes dryer energy use than the FMC itself. As stated in the October
2021 TP Final Rule, the current 2-percent FMC requirement using the DOE
test cloth was adopted as representative of approximately 5-percent FMC
for ``real-world'' clothing, based on data submitted in a joint
petition for rulemaking.\16\ DOE determined in the August 2013 Final
Rule that the specified 2-percent FMC using the DOE test load was
representative of consumer expectations for dryness of clothing in
field use. 78 FR 49608, 49620-49622, 49610-49611 (Aug. 14, 2013). DOE
has not identified any systemic problems with any consumer clothes
dryer types being able to achieve the required FMC of 2 percent or
less, such that amendments to the test procedure would be warranted and
therefore did not amend the FMC requirement for either appendix D1 or
appendix D2 in the October 2021 TP Final Rule. 86 FR 56608, 56626.
---------------------------------------------------------------------------
\16\ The petition was submitted by AHAM, Whirlpool Corporation,
General Electric Company, Electrolux, LG Electronics, Inc., BSH,
Alliance Laundry Systems, Viking Range, Sub-Zero Wolf, Friedrich A/
C, U-Line, Samsung, Sharp Electronics, Miele, Heat Controller, AGA
Marvel, Brown Stove, Haier, Fagor America, Airwell Group, Arcelik,
Fisher & Paykel, Scotsman Ice, Indesit, Kuppersbusch, Kelon, and
DeLonghi, American Council for an Energy Efficient Economy,
Appliance Standards Awareness Project, Natural Resources Defense
Council, Alliance to Save Energy, Alliance for Water Efficiency,
Northwest Power and Conservation Council, and Northeast Energy
Efficiency Partnerships, Consumer Federation of America and the
National Consumer Law Center. See Docket No. EERE-2011-BT-TP-0054,
No. 3.
---------------------------------------------------------------------------
ASAP, NRDC, and Samsung requested that DOE consider the testing of
an additional smaller test load to supplement the current test load,
stating a smaller test load could better represent consumer use and
clothes dryer efficiency. (ASAP, NRDC, No. 25 at p. 1; Samsung, No. 29
at p. 3) As stated in the October 2021 TP Final Rule, with little
expected change to the CEF<INF>D2</INF> value when considering the
energy consumption associated with a range of load sizes, DOE does not
believe the additional testing would provide consumers with improved
information that would change their purchasing decisions compared to
the current test procedure. As such, any incremental benefit of testing
with additional load sizes would be outweighed by the significant added
burden that would be imposed by conducting such tests. For these
reasons, DOE did not propose or adopt any amendments to the test
procedure requiring additional test load sizes in the October 2021 TP
Final Rule. 86 FR 56608, 56621.
In response to the preliminary analysis, the California IOUs
presented data suggesting that consumer clothes dryers that have
identical ratings under appendix D1 can vary considerably when tested
to appendix D2, and also stated that DOE's analysis in the preliminary
TSD shows that baseline efficiency consumer clothes dryers tested under
appendix D1 significantly underperform when tested under appendix D2.
For these reasons, the California IOUs recommended that DOE use this
rulemaking or the open test procedure rulemaking to phase out appendix
D1 in favor of an updated appendix D2 test procedure. Samsung further
supported DOE requiring the appendix D2 test procedure for
manufacturers as the mandatory procedure for testing consumer clothes
dryers. (California IOUs, No. 26 at p. 5) According to Samsung,
appendix D2 has been recognized by stakeholders as truly representing
how automatic termination control dryers are used by consumers, and
manufacturers of ENERGY STAR-qualified consumer clothes dryers are
familiar with, and have invested in, the test procedure in appendix D2,
as it is already mandated for ENERGY STAR qualification. Furthermore,
Samsung asserted that the appendix D1 test procedure was intended as a
stopgap measure to test ``sensor [automatic termination control]
dryers'' using ``non-sensing'' settings (i.e., timer drying cycle) and
does not represent how automatic termination clothes dryers are used by
consumers as accurately as the appendix D2 test procedure. Samsung
recommended that, since appendix D2 has been used for many years for
ENERGY STAR qualification, appendix D1 be phased out now, with an
appropriate adjustment to the underlying energy conservation standards
to reflect the change in test method as described in EPCA. (Samsung,
No. 29 at p. 2)
As discussed in the October 2021 TP Final Rule, the version of
appendix D2 adopted in that final rule would be used for the evaluation
and issuance of updated energy conservation standards, with compliance
with that version of appendix D2 required on the
[[Page 51744]]
implementation date of updated standards. 86 FR 56608, 56635-56636
(Oct. 8, 2021). Accordingly, DOE notes that the preliminary analysis
and this NOPR analysis are based on the appendix D2 test procedure, and
therefore the proposed amended energy conservation standards in this
document are also based on the appendix D2 test procedure. These
proposed amendments are discussed in more detail in section IV.C of
this document.
C. Technological Feasibility
1. General
In evaluating potential amendments to energy conservation
standards, 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. Sections 6(b)(3)(i) and 7(b)(1) of appendix
A.
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; (3) adverse impacts on
health or safety, and (4) unique-pathway proprietary technologies.
Sections 6(b)(3)(ii)-(v) and 7(b)(2)-(5) of appendix A. Section IV.B of
this document discusses the results of the screening analysis for
consumer clothes dryers, particularly the designs DOE considered, those
it screened out, and those that are the basis for the standards
considered in this rulemaking. For further details on the screening
analysis for this rulemaking, see chapter 4 of the NOPR 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
engineering analysis, DOE determined the maximum technologically
feasible (``max-tech'') improvements in energy efficiency for consumer
clothes dryers, using the design parameters for the most efficient
products available on the market or in working prototypes. The max-tech
levels that DOE determined for this rulemaking are described in section
IV.C.1 of this document and in chapter 5 of the NOPR TSD.
D. Energy Savings
1. Determination of Savings
For each trial standard level (``TSL''), DOE projected energy
savings from application of the TSL to consumer clothes dryers
purchased in the 30-year period that begins in the year of compliance
with the proposed standards (2027-2056).\17\ The savings are measured
over the entire lifetime of consumer clothes dryers purchased in the
previous 30-year 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 that reflects how the
market for a product would likely evolve in the absence of amended
energy conservation standards.
---------------------------------------------------------------------------
\17\ Each TSL is composed of specific efficiency levels for each
product class. The TSLs considered for this NOPR are described in
section V.A of this document. DOE conducted a sensitivity analysis
that considers impacts for products shipped in a 9-year period.
---------------------------------------------------------------------------
DOE used its national impact analysis (``NIA'') spreadsheet model
to estimate national energy savings (``NES'') from potential amended or
new standards for consumer clothes dryers. The NIA spreadsheet model
(described in section IV.H of this document) calculates energy savings
in terms of site energy, which is the energy directly consumed by
products at the locations where they are used. For electricity, DOE
reports national energy savings in terms of primary energy savings,
which is the savings in the energy that is used to generate and
transmit the site electricity. For natural gas, the primary energy
savings are considered to be equal to the site energy savings. DOE also
calculates NES in terms of 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.\18\ 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 document.
---------------------------------------------------------------------------
\18\ 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.
The significance of energy savings offered by a new or amended
energy conservation standard cannot be determined without knowledge of
the specific circumstances surrounding a given rulemaking.\19\ For
example, some covered products and equipment have most of their energy
consumption occur during periods of peak energy demand. The impacts of
these products on the energy infrastructure can be more pronounced than
products with relatively constant demand. In evaluating the
significance of energy savings, DOE considers differences in primary
energy and FFC effects for different covered products and equipment
when determining whether energy savings are significant. Primary energy
and FFC effects include the energy consumed in electricity production
(depending on load shape), in distribution and transmission, and in
extracting, processing, and transporting primary fuels (i.e., coal,
natural gas, petroleum fuels), and thus present a more complete picture
of the impacts of energy conservation standards.
---------------------------------------------------------------------------
\19\ The numeric threshold for determining the significance of
energy savings established in a final rule published on February 14,
2020 (85 FR 8626, 8670), was subsequently eliminated in a final rule
published on December 13, 2021 (86 FR 70892).
---------------------------------------------------------------------------
Accordingly, DOE evaluates the significance of energy savings on a
case-by-case basis, taking into account the significance of cumulative
FFC national energy savings, the cumulative FFC emissions reductions,
and the need to confront the global climate crisis, among other
factors. As discussed in section V.C of this document, DOE is proposing
to adopt TSL 3, which would save an estimated 3.11 quads of energy
(FFC). DOE has initially determined that these energy savings are
``significant'' within the meaning of 42 U.S.C. 6295(o)(3)(B).
E. Economic Justification
1. Specific Criteria
As noted previously, EPCA provides seven factors to be evaluated in
[[Page 51745]]
determining whether a potential energy conservation standard is
economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII)) 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 an MIA, as discussed in section IV.J of
this document. 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 consumer costs and benefits expected to result from particular
standards. DOE also evaluates the impacts of potential standards on
identifiable subgroups of consumers that may be affected
disproportionately by a 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 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 new
or amended standards. The LCC savings for the considered efficiency
levels are calculated relative to the case that reflects projected
market trends in the absence of new or amended standards. DOE's LCC and
PBP analysis is discussed in further detail in section IV.F of this
document.
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.D of this document, 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 document 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 the ADDRESSES section for
information to send comments to DOJ.
f. Need for National Energy Conservation
DOE also considers the need for national energy and water
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 the proposed 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 document.
DOE maintains that environmental and public health benefits
associated with the more efficient use of energy are important to take
into account when considering the need for national energy
conservation. The proposed standards 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
potential standards may
[[Page 51746]]
affect these emissions, as discussed in section IV.K of this document;
the estimated emissions impacts are reported in section V.B.6 of this
document. DOE also estimates the economic value of health benefits from
certain emissions reductions resulting from the considered TSLs, as
discussed in section IV.L of this document.
AHAM stated its continued objection to DOE's use of the social cost
of carbon and other monetization of emissions reductions benefits in
its analysis of the factors EPCA requires DOE to balance to determine
the appropriate standard. According to AHAM, while it may be acceptable
for DOE to continue its current practice of examining the social cost
of carbon and monetization of other emissions reductions benefits as
informational so long as the underlying interagency analysis is
transparent and vigorous, the monetization analysis should not impact
the trial standards levels DOE selects as a new or amended standard.
(AHAM, No. 23 at pp. 11-12)
DOE's evaluation of whether a potential energy conservation
standard is economically justified is guided by EPCA and also by OMB
Circular A-4 (Sept. 17, 2003), which provides guidance to Federal
agencies on the development of regulatory analysis. As indicated above,
DOE believes that avoiding negative impacts to human health and the
wide range of impacts associated with climate change are key factors
behind the need for energy conservation.\20\ OMB Circular A-4 states:
``Benefit-cost analysis is a primary tool used for regulatory analysis.
Where all benefits and costs can be quantified and expressed in
monetary units, benefit-cost analysis provides decision makers with a
clear indication of the most efficient alternative, that is, the
alternative that generates the largest net benefits to society.'' (p.
2) Monetizing public health benefits of regulations is a long-standing
practice in Federal regulatory analysis. To not consider such benefits
when evaluating whether a potential energy conservation standard is
economically justified would be contrary to both EPCA and OMB's
guidance. In addition, on March 16, 2022, the Fifth Circuit Court of
Appeals (No. 22-30087) granted the federal government's emergency
motion for stay pending appeal of the February 11, 2022, preliminary
injunction issued in Louisiana v. Biden, No. 21-cv-1074-JDC-KK (W.D.
La.). As a result of the Fifth Circuit's order, the preliminary
injunction is no longer in effect, pending resolution of the federal
government's appeal of that injunction or a further court order. Among
other things, the preliminary injunction enjoined the defendants in
that case from ``adopting, employing, treating as binding, or relying
upon'' the interim estimates of the social cost of greenhouse gases--
which were issued by the Interagency Working Group on the Social Cost
of Greenhouse Gases on February 26, 2021--to monetize the benefits of
reducing greenhouse gas emissions. As reflected in this rule, DOE has
reverted to its approach prior to the injunction and presents monetized
greenhouse gas abatement benefits where appropriate and permissible
under law.
---------------------------------------------------------------------------
\20\ As mentioned previously, following the preliminary
injunction issued on February 11, 2022, in Louisiana v. Biden, No.
21-cv-1074-JDC-KK (W.D. La.), DOE is currently not monetizing the
costs of greenhouse gas emissions.
---------------------------------------------------------------------------
g. Other Factors
In determining whether an energy conservation standard is
economically justified, DOE may consider any other factors that the
Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) To
the extent DOE identifies any relevant information regarding economic
justification that does not fit into the other categories described
previously, 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.9 of this document.
IV. Methodology and Discussion of Related Comments
This section addresses the analyses DOE has performed for this
rulemaking with regard to consumer clothes dryers. Separate sections
address each component of DOE's analyses.
DOE used several analytical tools to estimate the impact of the
standards proposed in this document. The first tool is a spreadsheet
that calculates the LCC savings and PBP of potential amended or new
energy conservation standards. The national impacts analysis uses a
second spreadsheet set that provides shipments projections and
calculates national energy savings and net present value of total
consumer costs and savings expected to result 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 on the DOE website for this rulemaking: <a href="http://www.regulations.gov/docket/EERE-2014-BT-STD-0058/">www.regulations.gov/docket/EERE-2014-BT-STD-0058/</a>. Additionally, DOE used output from the
latest version of the Energy Information Administration's (``EIA's'')
Annual Energy Outlook (``AEO''), a widely known energy projection for
the United States, for the emissions and utility impact analyses.
A. Market and Technology Assessment
DOE develops information in the market and technology assessment
that provides an overall picture of the market for the products
concerned, including the purpose of the products, the industry
structure, manufacturers, market characteristics, and technologies used
in the products. This activity includes both quantitative and
qualitative assessments, based primarily on publicly available
information. The subjects addressed in the market and technology
assessment for this rulemaking include (1) a determination of the scope
of the rulemaking and product classes, (2) manufacturers and industry
structure, (3) existing efficiency programs, (4) shipments information,
(5) market and industry trends, and (6) technologies or design options
that could improve the energy efficiency of consumer clothes dryers.
The key findings of DOE's market assessment are summarized in the
following sections. See chapter 3 of the NOPR TSD for further
discussion of the market and technology assessment.
[[Page 51747]]
1. Scope of Coverage and Product Classes
DOE defines ``electric clothes dryer'' under EPCA as a cabinet-like
appliance designed to dry fabrics in a tumble-type drum with forced air
circulation. The heat source is electricity and the drum and blower(s)
are driven by an electric motor(s). Similarly, DOE defines ``gas
clothes dryer'' as a cabinet-like appliance designed to dry fabrics in
a tumble-type drum with forced air circulation. The heat source is gas
and the drum and blower(s) are driven by an electric motor(s). (10 CFR
430.2)
In response to the preliminary analysis, the California IOUs
offered information on at least two manufacturers producing a dry-and-
steam clothing cabinet and encouraged DOE to explore the market
prevalence and potential growth of this equipment and what features
represent an average use cycle. The California IOUs also suggested DOE
consider the current clothes washers rulemaking or dehumidifiers
rulemaking to provide guidance on how this product should be classified
and, if appropriate, tested and rated. (California IOUs, No. 26 at p.
7) DOE may investigate this product in a future rulemaking; however, as
this product does not meet the definition of a clothes dryer because it
does not include a tumble-type drum, it was not included in this
analysis.
The current product classes, which were established by the April
2011 Direct Final Rule, are presented in Table IV.1.
Table IV.1--Current Consumer Clothes Dryer Product Classes
------------------------------------------------------------------------
-------------------------------------------------------------------------
Vented dryers:
Electric, Standard (4.4 cubic feet (ft\3\) or greater capacity).
Electric, Compact (120 volts (V)) (less than 4.4 ft\3\ capacity).
Electric, Compact (240 V) (less than 4.4 ft\3\ capacity).
Gas.
Ventless dryers:
Electric, Compact (240 V) (less than 4.4 ft\3\ capacity).
Electric, Combination Washer-Dryer.
------------------------------------------------------------------------
Based on its review of products available on the market in the
United States, DOE notes that at least six manufacturers currently
offer a ventless clothes dryer with a drum capacity greater than 4.4
ft\3\. As a result, in the preliminary analysis, DOE analyzed an
additional product class for ventless electric standard clothes dryers,
with drum capacity larger than 4.4 ft\3\.
In response to the preliminary analysis, the California IOUs
requested that DOE investigate potential reporting errors within the
Compliance Certification Database (``CCD''), as the California IOUs
asserted that multiple products were incorrectly listed in the CCD as
``vented'' products while certified as ``ventless'' products in the
ENERGY STAR product database and represented as ``ventless'' in
manufacturer literature. (California IOUs, No. 26 at p. 4) DOE will
work to investigate any classification errors within the CCD and
requests comment on additional information regarding potential
classification errors.
In response to the preliminary analysis, ASAP, NRDC, the California
IOUs, and NEEA requested that DOE review the efficiencies of models
currently available on the market, specifically for the vented electric
standard product class, stating that there are currently available
models with higher efficiencies than the max-tech efficiency level
considered in the preliminary analysis for this product class. (ASAP,
NRDC, No. 25 at pp. 1-2; California IOUs, No. 26 at pp. 3-4; NEEA, No.
30 at pp. 10-11) Upon review of these higher efficiency models, DOE
discovered that many of the higher efficiency electric standard clothes
dryers on the market are ventless and employ heat pump technology and
that there are no lower-efficiency ventless electric standard models
associated with the less efficient condensing technology that is
available with the ventless electric compact (240V) product class.
Given that most heat pump designs at the standard size are inherently
ventless and result in higher efficiencies, establishing a product
class for ventless electric standard clothes dryers would essentially
result in a separate product class for heat pump dryers and leave the
vented electric standard product class with less efficient conventional
resistive heating-element dryers. This would effectively restrict the
efficiency of the vented electric standard product class, as higher
efficiency technologies would be associated with a different product
class.
DOE received comments from AHAM and Whirlpool in response to the
preliminary analysis stating that ventless electric clothes dryers,
especially those implementing heat pump designs, have difficulty in
meeting the 2-percent FMC requirement with Whirlpool stating that
ventless electric clothes dryers result in longer cycle times than
conventional vented clothes dryers. (AHAM, No. 23, p. 11; Whirlpool,
No. 27 at pp. 13-17) Additionally, Whirlpool recommended that DOE
consider the consumer utility of the differences that arise when
consumer clothes dryers utilize heat pump technology and to establish a
separate product class for heat pump clothes dryers (including hybrid
heat pump clothes dryers). Whirlpool stated that differences in fabric
care, drying time, heating and cooling energy impacts, lower drying
temperatures, and technology used are all relevant performance-related
features that distinguish heat pump and hybrid heat pump clothes dryers
from all other consumer clothes dryer product classes, which may
justify a higher standard than for other product types. (Whirlpool, No.
27 at p. 17) DOE observes that all standard size ventless electric
clothes dryers and compact ventless electric (120V) clothes dryers are
rated according to appendix D2 and are ENERGY STAR-qualified, and
therefore meet the 80-minute cycle time requirement to receive ENERGY
STAR recognition. Additionally, DOE found no issue in its own testing
of ventless electric clothes dryers inherent in the ventless electric
clothes dryer design that supports the claims made by commenters
regarding difficulty in meeting the FMC requirement and longer cycle
times (i.e., all ventless electric clothes dryers tested, including
those utilizing either condensing or heat pump technology, were able to
meet the 2-percent FMC requirement).
As discussed, a rule prescribing an energy conservation standard
must specify a level of energy use or efficiency higher or lower than
that which applies (or would apply) for any group of covered products
which have the same function or intended use, if the Secretary
determines that covered products within such group have a
[[Page 51748]]
capacity or other performance-related feature which justifies a higher
or lower standard. (42 U.S.C. 6295(q)(1)(B)) For standard size electric
clothes dryers, the ventless feature does not justify a separate
standard as compared to standard size electric clothes dryers that are
vented. Standard size ventless electric clothes dryers can accommodate
heat pump technology that results in improved efficiency similar to
that for standard size vented electric clothes dryers. Therefore, upon
further consideration, no product class distinction is proposed in this
NOPR between ventless and vented electric standard clothes dryers, nor
between heat pump and non-heat pump clothes dryers.
Instead, DOE proposes an ``electric standard'' product class that
would comprise both ventless and vented electric standard clothes
dryers. Such a product class would not impact consumer utility, given
that a consumer could install a ventless electric standard clothes
dryer in the same locations as vented electric standard clothes dryers,
and would not result in unacceptable drying performance or cycle time,
as evidenced by the existing heat pump clothes dryers that are able to
achieve the 2-percent FMC requirement within an 80-minute cycle time.
In response to the preliminary analysis, the California IOUs
requested that DOE consider an additional product class for ventless
electric compact (120V) models, as such clothes dryers are currently
available on the market. (California IOUs, No. 26 at p. 3) Upon further
review, DOE found that, as for ventless electric standard clothes
dryers, all currently available ventless electric compact (120V)
clothes dryers utilize heat pump technology. For the same reasons as
for electric standard clothes dryers (i.e., to capture the energy
savings associated with heat pump technology and to avoid restricting
potential efficiency gains for vented electric clothes dryers), DOE
proposes an ``electric compact (120V)'' product class comprising
ventless and vented electric compact (120V) models.
In light of the proposal to have single product classes containing
all standard size electric clothes dryers and a single product class
for all compact electric (120V) clothes dryers, DOE also considered
whether to maintain the current separate product classes distinction
based on venting for compact electric (240V) clothes dryers. DOE has
previously determined that for compact electric clothes dryers, a
ventless configuration is a consumer utility because these dryers
provide for installations in space-constrained environments. 76 FR
22454, 22485 (Apr. 21, 2011). Based on the analysis presented in this
NOPR, DOE has tentatively determined that the higher efficiencies for
ventless compact (240V) clothes dryers would not be economically
justified as they would be for vented compact (240V) clothes dryers.
See Section IV.F of this document. Therefore, DOE tentatively
determines that venting characteristics continue to justify a separate
product class for compact (240V) clothes dryers.
As discussed, vented electric clothes dryers are divided, in part,
based on capacity such that there is a standard size product class (4.4
ft\3\ or greater capacity) and compact classes (capacity less than 4.4
ft\3\). There is no similar class distinction for vented gas clothes
dryers. Since the previous energy conservation standards rulemaking,
DOE has identified at least one manufacturer of a vented gas clothes
dryer with a drum less than 4.4 ft\3\. Such capacity units are subject
to the energy conservation standard for vented gas clothes dryers. AHAM
supported splitting the product classes for gas clothes dryers based on
capacity consistent with the product classes for electric dryers.
(AHAM, No. 23 at p. 7)
As discussed, DOE must specify a different standard level for a
type or class of product that has 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.
In evaluating potential technologies to improve the energy
efficiency of vented gas clothes dryers, DOE tentatively has determined
that vented gas clothes dryers with a capacity of less than 4.4 ft\3\
perform in a way that is substantively different than vented gas
clothes dryers that are 4.4 ft\3\ or greater in capacity. For example,
DOE has observed that compact vented gas clothes dryers generally
perform at a lower efficiency than standard size vented gas clothes
dryers, likely due to the chassis size restrictions, and due to that
inherent difference, DOE believes that a separate product class is
warranted. Furthermore, creating a new product class for vented gas
clothes dryers with a capacity of less than 4.4 ft\3\ would ensure that
efficiency levels and potential amended standards could better and more
directly assess the impact of design option implementations for a given
product configuration. Therefore, DOE has tentatively determined that a
separate product class and standard for vented gas compact clothes
dryers (i.e., with a capacity less than 4.4 ft\3\) are justified for
similar reasons as DOE determined for vented electric compact clothes
dryers. See 76 FR 22404, 22485 (Apr. 21, 2011). As a result, DOE
analyzed separate product classes for vented gas standard and vented
gas compact clothes dryers.
In sum, DOE proposes the consumer clothes dryer product classes
listed in Table IV.2 in this NOPR, which expand the scope of certain
product classes to include both vented and ventless designs, and
include an additional product class for compact vented gas dryers.
Table IV.2--Notice of Proposed Rulemaking Consumer Clothes Dryer Product
Classes
------------------------------------------------------------------------
-------------------------------------------------------------------------
Product Classes:
1. Electric, Standard (4.4 cubic feet (ft\3\) or greater capacity).
2. Electric, Compact (120 volts (V)) (less than 4.4 ft\3\ capacity).
3. Vented Electric, Compact (240 V) (less than 4.4 ft\3\ capacity).
4. Vented Gas, Standard (4.4 ft\3\ or greater capacity).
5. Vented Gas, Compact (less than 4.4 ft\3\ capacity).
6. Ventless Electric, Compact (240 V) (less than 4.4 ft\3\
capacity).
7. Ventless Electric, Combination Washer/Dryer.
------------------------------------------------------------------------
[[Page 51749]]
2. Technology Options
In the preliminary market analysis and technology assessment, DOE
identified 16 technology options that would be expected to improve the
efficiency of consumer clothes dryers, as measured by the DOE test
procedure. DOE continues to consider these technology options in this
NOPR analysis. These technology options can be broadly grouped into
five main categories: dryer control or drum upgrades, methods of
exhaust heat recovery (for vented models only), heat generation
options, improvements to components, and options to reduce standby
power.
Table IV.3--Preliminary Analysis: Technology Options for Consumer
Clothes Dryers
------------------------------------------------------------------------
-------------------------------------------------------------------------
Dryer Control or Drum Upgrades:
Improved termination.
Increased insulation.
Modified operating conditions.
Improved air circulation.
Improved drum design.
Methods of Exhaust Heat Recovery (Vented Models Only):
Recycle exhaust heat.
Inlet air preheat.
Inlet air preheat, condensing mode.
Heat Generation Options:
Heat pump, electric only.
Thermoelectric heating, electric only.
Microwave, electric only.
Modulating heat.
Indirect heating.
Component Improvements:
Improved motor efficiency.
Improved fan efficiency.
Standby Power Improvements:
Transformerless power supply with auto-powerdown.
------------------------------------------------------------------------
DOE notes that two recently developed consumer clothes dryer
technologies were not included as part of the preliminary analysis:
long wavelength radio frequency (``RF'') drying and ultrasonic drying.
Despite the potential benefits of RF and ultrasonic clothes drying,
however, both technologies are currently under patent or have received
a provisional patent. Any energy conservation standard that relied on
either of these technologies would unfairly advantage the manufacturer
or individual holder of the patent, and thus DOE did not consider them
as technology options for the preliminary analysis. Because these
technologies are technologically feasible, however, DOE proposes in
this NOPR to retain these as technology options in the technology
assessment, noting one of the criteria for screening technology options
for use in further analyses is whether a technology represents a unique
proprietary pathway (see section IV.B of this document and chapter 4 of
the NOPR TSD). DOE notes that the current energy conservation standards
for consumer clothes dryers would not prohibit the use of these
technologies.
DOE received several comments in response to the technologies
proposed in the preliminary analysis to be analyzed for consumer
clothes dryers.
Whirlpool suggested that reduced drum seal leakage be considered as
a technology option. Additionally, Whirlpool stated that approaches to
reduce standby power may not be consumer-friendly solutions that
manufacturers would readily implement. Whirlpool suggested that
delaying the drum light turning on after opening the door or delaying
the start of a cycle after powering on the unit would frustrate
consumers, as they typically expect appliances to turn on when action
is taken such as pressing the power button or opening the door.
Whirlpool also suggested an off position on the control dial but stated
that intellectual property may exist around this and may result in
higher costs. (Whirlpool, No. 27 at p. 17) DOE is not aware of data at
this time to characterize the impacts reduced drum seal leakage may
have on efficiency and requests information on efficiency impacts of
this technology. In addition, the strategies that Whirlpool suggested
to reduce energy use in standby mode, including delaying the activation
of the drum light after a door opening or delaying the start of the
cycle after powering on the unit, would not be measured by appendix D2.
Furthermore, although appendix D2 incorporates measures of energy use
in both off mode and inactive (standby) mode, DOE does not have
information to indicate the relative power consumption in each of these
modes for any consumer clothes dryers on the market which may have an
off mode position on the controls, which would provide an estimate of
the reduction in combined low-power mode energy use. For these reasons,
at this time, DOE is not proposing to include these technology options
in its analysis.
NEEA stated that manufacturers in the current consumer clothes
dryer market utilize an ``eco mode'' as a lower heat/longer drying time
strategy to achieve a given efficiency. NEEA asserted that the
efficiency of a consumer clothes dryer increases substantially with
lower heat and longer drying time, citing laboratory testing by the
California IOUs that quantified this effect by alternating periods of
heat with no heat during a cycle. According to the results of this
work, NEEA claimed, the average efficiency of consumer clothes dryers
with these modified controls increased 30 percent compared to their
default settings used for appendix D2 testing, and drying time
increased 140 percent. According to NEEA, a no-heat cycle took 4 hours
to complete but achieved a CEF<INF>D2</INF> value of 7.0. NEEA stated
that with the energy savings associated with this strategy, as well as
the relatively low cost associated with the redesign of the control
panel to enable additional heater/burner algorithms, manufacturers have
a solid incentive to extensively utilize eco mode as the sole redesign
strategy to enable their models to meet DOE's forthcoming mandatory
standard. NEEA warned that the longer drying times associated with
these energy saving programs are unlikely to be acceptable to many
consumers in some
[[Page 51750]]
circumstances (e.g., serial dryer loads and other time-sensitive
loads), which could potentially result in consumers regularly disabling
these eco modes and may therefore significantly reduce the energy
savings of dryers in everyday use relative to expectations created by
the current appendix D2 test procedure. Therefore, NEEA requested that
DOE require the sole use of appendix D2 for certification purposes as
well as the required reporting of cycle times in order to mitigate
against significant reductions in actual real-world energy savings
associated with a low heat/long drying time eco mode strategy.
According to NEEA, cycle time reporting would help moderate
inordinately long cycle times during the D2 test, enable consumers and
other stakeholders to consider trade-offs between the efficiency and
cycle time for a given model, and provide data to possibly consider
more sophisticated approaches to cycle time in subsequent standard
updates. (NEEA, No. 30 at pp. 1-7) DOE recognizes that some consumer
clothes dryers are currently certified using appendix D2, and their
controls may include an ``eco mode'' or ``energy saver mode,'' which
typically reduce the temperature used in the cycle at the expense of
increasing the drying time. However, appendix D2 requires, for
automatic termination control dryers, that the ``normal'' program be
selected for the energy test cycle. In the event that the automatic
termination control dryer does not have a ``normal'' program, the cycle
recommended by the manufacturer for drying cotton or linen clothing is
selected. Where the drying temperature setting can be chosen
independently of the program (as would be the case if ``eco mode'' or
``energy saver mode'' were an optional setting that could be selected
for the ``normal'' program), the drying temperature must be set to the
maximum. Section 3.3.2, appendix D2. For timer dryers, the maximum
temperature setting is selected for the energy test cycle. Section
3.3.1, appendix D2. Therefore, an available ``eco mode'' or ``energy
saver mode'' would not be included in the energy test cycle, as they
would not produce a measure of energy use during a representative
cycle. For this reason, DOE did not consider such energy saving modes
as a technology option in this NOPR.
NEEA further encouraged DOE to consider the following technology
options: (1) coupled blower modulation with the multi-stage burner/
heater efficiency level, (2) cabinet insulation, (3) backward curved
fan blades, and (4) recuperation heat recovery in vented heat pump
clothes dryers associated with a PNNL study. (NEEA, No. 30 at pp. 12-
13) DOE notes that blower modulation is already coupled with the multi-
stage burner/heater efficiency level for both electric and gas consumer
clothes dryers, although this was not previously stated in chapter 5 of
the preliminary TSD. DOE has not observed the technology option of
cabinet insulation in clothes dryers used in this analysis, and
therefore does not currently have sufficient information to determine
the potential efficiency impacts associated with the suggested
technology options, however, DOE notes that with the inherent risk of
fires that may occur during operation of a consumer clothes dryer, any
insulation used within the cabinet space would likely need to be fire
retardant in order to satisfy the fire containment requirements
according to the UL 2158 safety standard. While insulation of the dryer
cabinet space would likely lead to potential energy savings, DOE
expects that the insulation could lead to an increased internal cabinet
temperature and may potentially lead to the degradation of other
components within the clothes dryer assembly. DOE therefore requests
information that would be beneficial in determining any impacts to
efficiency or performance as a result of implementing each of the
technology options mentioned. DOE notes that improvements to fan blades
would be captured in the analyzed technology options as improved fan
efficiency, however the efficiency improvements specified by NEEA refer
to heating, ventilation, and air conditioning (``HVAC'') research and
do not specifically refer to efficiency improvements in consumer
clothes dryers. Therefore, until DOE has sufficient information on
efficiency improvements associated with fan designs, the proposed
incremental efficiency levels will not be associated with improved fan
efficiency. Regarding the recuperation heat recovery technology option,
DOE notes that this technology is already considered in this analysis
referred to as the inlet-air preheat design option. Given the proposed
change to the product class structure regarding the combination of
vented and ventless clothes dryers in the standard and compact (120V)
categories, this technology is now considered in the proposed design
options for vented consumer clothes dryers, however given that DOE has
not observed inlet-air preheat technology in consumer clothes dryers on
the market, specifically heat pump consumer clothes dryers, this
technology has not been considered at the max-tech level associated
with heat pump technology.
Table IV.4 lists the technology options identified for consumer
clothes dryers in this NOPR. With the inclusion of RF and ultrasonic
drying technologies in the list of technology options in the NOPR, DOE
has renamed the grouping for ``heat generation options'' as ``moisture
removal options.'' See chapter 3 of the NOPR TSD for further discussion
of the analyzed technologies.
Table IV.4--Technology Options for Consumer Clothes Dryers
------------------------------------------------------------------------
-------------------------------------------------------------------------
Dryer Control or Drum Upgrades:
Improved termination.
Increased insulation.
Modified operating conditions.
Improved air circulation.
Improved drum design.
Methods of Exhaust Heat Recovery (Vented Models Only):
Recycle exhaust heat.
Inlet air preheat.
Inlet air preheat, condensing mode.
Moisture Removal Options:
Heat pump, electric only.
Thermoelectric heating, electric only.
Microwave, electric only.
Modulating heat.
Indirect heating.
RF drying, electric only.
[[Page 51751]]
Ultrasonic drying, electric only.
Component Improvements:
Improved motor efficiency.
Improved fan efficiency.
Standby Power Improvements:
Transformerless power supply with auto-powerdown.
------------------------------------------------------------------------
B. Screening Analysis
DOE uses the following five 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
projected 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 a significant adverse impact on
the utility of the product for 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.
(5) Unique-Pathway Proprietary Technologies. If a design option
utilizes proprietary technology that represents a unique pathway to
achieving a given efficiency level, that technology will not be
considered further due to the potential for monopolistic concerns.
10 CFR part 430, subpart C, appendix A, 6(b)(3) and 7(b).
In summary, if DOE determines that a technology, or a combination
of technologies, fails to meet one or more of the listed five criteria,
it will be excluded from further consideration in the engineering
analysis. The reasons for eliminating any technology are discussed in
the following sections.
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
AHAM requested that DOE consider the effects that different
technology options may have on fabric care, specifically the impact
longer drying cycles may have on fabric. (AHAM, No. 23 at p. 10) While
certain technology options may be associated with an increase in cycle
times (e.g., modified operating conditions (reduced drying
temperatures) and heat pump technology), DOE notes that AHAM did not
provide, nor is DOE aware of, information correlating fabric care
directly to cycle time. In addition, if longer cycle times are
accompanied by lower drying temperatures, it is uncertain whether the
net impact on fabric care is positive or negative, and how this result
would vary based on fabric type. Therefore, DOE did not screen out any
technology options solely on the basis of any fabric care
considerations due to cycle time. However, DOE requests comment on any
potential impacts that different technology options, including any that
may impact cycle times, have on fabric care.
a. Thermoelectric Heating, Electric Only
DOE notes that Oak Ridge National Laboratory (``ORNL'') is still
researching thermoelectric heating clothes dryers. While ORNL's test
results of a preliminary prototype have shown the potential for
improved efficiency, ORNL indicated that the initial prototype design
produced longer-than-desired drying times due to direct-contact heat
transfer limitations via the drum surface. ORNL has subsequently
developed another prototype which added pumped secondary water loops
that transferred heat from the thermoelectric modules to the process
air via air-to-water heat exchangers to further improve efficiency and
minimize cycle length. ORNL's testing indicated efficiency and cycle
times for this prototype that are approximately equivalent to those of
vapor compression heat pump clothes dryers.\21\ Because the research
for such a thermoelectric heating clothes dryer that produces energy
savings and meets consumer expectations for drying cycle time is still
in the prototype stage, DOE determined that this technology option
would not be practicable to manufacture, install, and service on a
scale necessary to serve the relevant market at the time of the
projected compliance date of any new or amended consumer clothes dryer
standards, and did not be consider it for further analysis.
---------------------------------------------------------------------------
\21\ Patel, V., Boudreaux, P., and Gluesenkamp, K. Oak Ridge
National Laboratory. Validated Model of a Thermoelectric Heat Pump
Clothes Dryer Using Secondary Pumped Loops. Applied Thermal
Engineering, Volume 184, February 5, 2021.
---------------------------------------------------------------------------
b. Microwave, Electric Only
Due to the large energy savings associated with microwave drying,
this technology was the subject of a multi-year development effort at
the Electric Power Research Institute (``EPRI'') in the mid-1990s; \22\
and at least one major manufacturer, Whirlpool Corporation
(``Whirlpool''), developed a countertop-scale version of such a product
as recently as 2002,\23\ but to date this technology has not been
successfully commercialized.
---------------------------------------------------------------------------
\22\ S. Ashley. 1998. ``Energy-Efficient Appliances'',
Mechanical Engineering Magazine, March, 1998, pp. 94-97.
\23\ E. Spagat. 2002. ``Whirlpool Goes Portable to Sell Dryers
to Gen Y'', Wall Street Journal, June 4, 2002.
---------------------------------------------------------------------------
Significant technical and safety issues are introduced by the
potential arcing from metallic objects in the fabric load, including
zippers, buttons, or ``stray'' items such as coins. While efforts have
been made to mitigate the conditions that are favorable to arcing, or
to detect incipient arcing and terminate the cycle, the possibility of
fabric damage cannot be completely eliminated.\24\ In addition to
consumer utility impacts, these conditions can also pose a safety
hazard.
[[Page 51752]]
For these reasons, microwave drying was not considered further for
analysis.
---------------------------------------------------------------------------
\24\ J.F. Gerling. 2003. ``Microwave Clothes Drying--Technical
Solutions to Fundamental Challenges'', Appliance Magazine, April,
2003, p. 120.
---------------------------------------------------------------------------
c. Indirect Heating
Indirect heating would be viable only in residences that use a
hydronic heating system. Also, in order to derive clothes dryer heat
energy from the home's heating system, significant plumbing work would
be required to circulate heated water through a heat exchanger in the
clothes dryer. Therefore, this technology option does not meet the
criterion of practicability to install on a scale necessary to serve
the relevant market at the time of the effective date of any new
standard and will not be considered for further analysis.
d. RF Drying, Electric Only
CoolDry, LLC (``CoolDry''), developed an RF clothes dryer
prototype, claiming an efficiency of 90 percent, compared to 50 percent
for conventional clothes dryers.\25\ CoolDry states that its RF drying
technology operates at lower temperatures than do conventional clothes
dryers and, because the transfer of energy to clothes is not dependent
on convective heat transfer, the RF clothes dryer requires less
tumbling and subsequently consumes less energy for drum rotation than a
conventional clothes dryer. Because this technology was in the
prototype stage at the time it was initially considered and the company
is no longer in business and thus there is likely no longer research
and development ongoing, DOE determined that this technology option
would not be practicable to manufacture, install, and service on a
scale necessary to serve the relevant market at the time of the
projected compliance date of any new or amended consumer clothes dryer
standards, and did not be consider it for further analysis.
---------------------------------------------------------------------------
\25\ CoolDry does not specify the metric or test method used to
determine the efficiency of its prototype. More information is
available at: <a href="http://www.cooldryrf.com/">http://www.cooldryrf.com/</a>.
---------------------------------------------------------------------------
e. Ultrasonic Drying, Electric Only
Researchers at ORNL have developed an ultrasonic drying prototype
that uses piezoelectric transducers to separate water from clothes
through water cavitation produced by ultrasonic vibrations. According
to their research, the energy imparted to the water must overcome
surface tension in order to break the water into droplets, but this
energy is substantially less than the latent heat of vaporization of
water, which is the primary thermodynamic barrier for conventional
evaporation drying. The ORNL researchers anticipate that ultrasonic
drying technology will result in an energy factor (``EF'') \26\ of
greater than 10 and a drying time of less than 20 minutes.\27\ Because
this technology is still in the prototype stage, DOE determined that
this technology option would not be practicable to manufacture,
install, and service on a scale necessary to serve the relevant market
at the time of the projected compliance date of any new or amended
consumer clothes dryer standards, and did not be consider it for
further analysis.
---------------------------------------------------------------------------
\26\ EF only incorporates active mode energy use and not standby
and off mode energy use.
\27\ Momen, A. Ultrasonic Clothes Dryer: 2016 Building
Technologies Office Peer Review. 2016. Prepared for the U.S.
Department of Energy at Oak Ridge National Laboratory, in
partnership with the University of Florida and General Electric. p.
2.
---------------------------------------------------------------------------
2. Remaining Technologies
Through a review of each technology, DOE tentatively concludes that
all of the other identified technologies listed in section IV.A.2 of
this document met all five screening criteria to be examined further as
design options in DOE's NOPR analysis. In summary, DOE did not screen
out the following technology options listed in Table IV.5.
Table IV.5--Retained Design Options for Consumer Clothes Dryers
------------------------------------------------------------------------
-------------------------------------------------------------------------
Dryer Control or Drum Upgrades:
Improved termination.
Modified operating conditions.
Improved air circulation.
Increased insulation.
Improved drum design.
Methods of Exhaust Heat Recovery (vented models only):
Recycle exhaust heat.
Inlet air preheat.
Inlet air preheat, condensing mode.
Moisture Removal Options:
Heat pump, electric only.
Modulating heat.
Component Improvements:
Improved motor efficiency.
Improved fan efficiency.
Standby Power Improvements:
Transformerless Power Supply with Auto-Powerdown.
------------------------------------------------------------------------
DOE has initially determined that these technology options are
technologically feasible because they are being used or have previously
been used in commercially-available products or working prototypes. DOE
also finds that all of the remaining technology options meet the other
screening criteria (i.e., practicable to manufacture, install, and
service and do not result in adverse impacts on consumer utility,
product availability, health, or safety, nor are unique-pathway
proprietary technologies). For additional details, see chapter 4 of the
NOPR TSD.
C. Engineering Analysis
The purpose of the engineering analysis is to establish the
relationship between the efficiency and cost of consumer clothes
dryers. There are two elements to consider in the engineering analysis;
the selection of efficiency levels to analyze (i.e., the ``efficiency
analysis'') and the determination of product cost at each efficiency
level (i.e., the ``cost analysis''). In determining the performance of
higher-efficiency products, DOE considers technologies and design
option combinations not eliminated by the screening analysis. For each
product class, DOE estimates the baseline cost, as well as the
incremental cost for the product at efficiency levels above the
baseline. The output of the engineering analysis is a
[[Page 51753]]
set of cost-efficiency ``curves'' that are used in downstream analyses
(i.e., the LCC and PBP analyses and the NIA).
1. Efficiency Analysis
DOE typically uses one of two approaches to develop energy
efficiency levels for the engineering analysis: (1) relying on observed
efficiency levels in the market (i.e., the efficiency-level approach),
or (2) determining the incremental efficiency improvements associated
with incorporating specific design options to a baseline model (i.e.,
the design-option approach). Using the efficiency-level approach, the
efficiency levels established for the analysis are determined based on
the market distribution of existing products (in other words, based on
the range of efficiencies and efficiency level ``clusters'' that
already exist on the market). Using the design option approach, the
efficiency levels established for the analysis are determined through
detailed engineering calculations and/or computer simulations of the
efficiency improvements from implementing specific design options that
have been identified in the technology assessment. DOE may also rely on
a combination of these two approaches. For example, the efficiency-
level approach (based on actual products on the market) may be extended
using the design option approach to ``gap fill'' levels (to bridge
large gaps between other identified efficiency levels) and/or to
extrapolate to the max-tech level (particularly in cases where the max-
tech level exceeds the maximum efficiency level currently available on
the market).
In this proposed rulemaking, DOE relied on an efficiency-level
approach, supplemented with reverse-engineering. This approach involved
testing and physically disassembling a representative sample of
commercially available products, reviewing publicly available cost
information, and modeling equipment cost. From this information, DOE
estimated the manufacturer production costs (``MPCs'') for a range of
products currently available on the market, considering the design
options and the steps manufacturers would likely take to reach a
certain efficiency level. As part of this NOPR analysis, DOE included
additional test units beyond those considered in the preliminary
analysis as part of its updated test sample. The additional test units
were included to represent additional baseline models, newly introduced
units on the market, units with unique configurations, and units with
technologies that were not available at the time of the preliminary
analysis. The efficiency levels analyzed as part of this engineering
analysis are attainable using commercially available clothes dryer
technologies, or technologies that have been demonstrated in working
prototypes.
a. Baseline Efficiency Levels
For each product class, DOE generally selects a baseline model as a
reference point for each class, and measures changes resulting from
potential energy conservation standards against the baseline. The
baseline model in each product class represents the characteristics of
a product typical of that class. Generally, a baseline model is one
that just meets current energy conservation standards, or, if no
standards are in place, the baseline is typically the most common or
least efficient unit on the market.
The baseline clothes dryer efficiency levels for this NOPR differ
from the existing energy conservation standards that were established
in the 2011 rulemaking analysis primarily due to the difference between
the then-current appendix D1, which DOE used to evaluate products in
the previous rulemaking, and the present version of appendix D2, as
established by the October 2021 TP Final Rule and which DOE used as the
basis for this analysis. Appendix D2 includes test methods that more
accurately measure the effects of automatic cycle termination and that
may result in differences in the total measured energy consumption of
the test cycle as compared to the test methods in appendix D1.
Specifically, for automatic termination control dryers, appendix D2
requires a lower FMC of the test load and does not rely on a field use
factor to account for the over drying energy consumption, instead
requiring that the automatic termination drying program run to the end
of the cycle. Additionally, appendix D2 contains instructions for the
testing of timer dryers, which include a lower FMC of the test load as
compared to the version of appendix D1 used for the 2011 rulemaking
analysis.
For the engineering analysis, DOE begins the engineering analysis
by identifying the efficiency level corresponding to the Federal
minimum energy conservation standards for each product class. Due to
the test procedure changes adopted in the October 2021 Final Rule, DOE
determined the baseline efficiency level representative of minimally
compliant products when tested under appendix D2. In order to identify
the appendix D2 baseline levels, DOE tested 22 models that were
certified as minimally compliant with the current energy conservation
standards, from across all product classes. Because certified
performance data are not available for models on the market as tested
in accordance with both appendix D1 and appendix D2, DOE tested each
basic model in its test sample in accordance with appendix D1 and
appendix D2 and used the test values for appendix D2 to determine the
baseline models in support of this engineering analysis. Due to the
differences in the two test procedures described above, the baseline
CEF<INF>D2</INF> measured using appendix D2 is numerically lower for
each product class than the corresponding CEF<INF>D1</INF> value in the
current energy conservation standards, though that does not indicate a
lower efficiency. The test procedure differences are driving the lower
baseline CEF<INF>D2</INF> values and do not represent a lower
efficiency or backsliding.
The consumer clothes dryer baseline efficiency levels for the
preliminary analysis are presented in Table IV.6.
Table IV.6--Preliminary Analysis Consumer Clothes Dryer Baseline
Efficiency Levels
------------------------------------------------------------------------
CEFD2 (lb/kWh)
Product class
------------------------------------------------------------------------
Vented Electric, Standard (4.4 ft\3\ or greater 2.20
capacity)..............................................
Vented Electric, Compact (120V) (less than 4.4 ft\3\ 2.42
capacity)..............................................
Vented Electric, Compact (240V) (less than 4.4 ft\3\ 2.00
capacity)..............................................
Vented Gas, Standard (4.4 cubic ft\3\ or greater 2.63
capacity)..............................................
Vented Gas, Compact (less than 4.4 ft\3\ capacity)...... 1.66
Ventless Electric, Compact (240V) (less than 4.4 ft\3\ 2.03
capacity)..............................................
Ventless Electric, Standard ((4.4 ft\3\ or greater 2.23
capacity)..............................................
Ventless Electric, Combination Washer-Dryer............. 2.27
------------------------------------------------------------------------
[[Page 51754]]
In response to the preliminary analysis, AHAM agreed that testing
was appropriate to determine the baseline and incremental efficiency
levels, but stated that the testing of 18 models was insufficient to
establish the baseline efficiency levels. AHAM also stated that basing
DOE's analysis on a few baseline units may not accurately represent the
market, especially when so many baseline models have electromechanical
controls. AHAM therefore requested that DOE make its test results
available so that representativeness could be assessed from a shipments
perspective, and so that manufacturers could evaluate the test results
for their models and compare to their own results. (AHAM, No. 23 at p.
3)
Upon request, DOE provided to individual manufacturers the test
data for any of their units which were included in DOE's testing
sample, otherwise maintaining confidentiality of the products tested.
DOE also increased the number of units included in its updated test
sample to better represent consumer clothes dryers currently available
on the market, as discussed in chapter 5 of the NOPR TSD.
The California IOUs recommended that DOE revise the engineering
analysis and investigate lowering the baseline efficiency of the vented
gas standard dryer product class. According to the California IOUs,
their testing data that were presented to DOE in response to the test
procedure NOPR that was published on July 23, 2019 (84 FR 35484),
support the baseline efficiency level for the vented electric standard
product class. However, for the vented gas standard product class, the
California IOUs referred to a currently available product with a
CEF<INF>D2</INF> value below the baseline efficiency level presented in
the preliminary TSD. NEEA asserted that DOE has historically set
standard levels for gas clothes dryers lower than the standards for
electric clothes dryers because some energy counted in the higher
heating value of the gas consumed, which is the basis of the
CEF<INF>D2</INF>, is not used by the consumer clothes dryer. NEEA
encouraged DOE to re-evaluate the CEF<INF>D2</INF> levels of electric
and gas clothes dryers in its engineering analysis, as it pointed out
that the electric clothes dryer efficiency levels are lower than the
efficiency levels for gas clothes dryers that incorporate similar
technology options. NEEA encouraged DOE to increase the stringency of
the electric clothes dryer efficiency levels. (California IOUs, No. 26
at pp. 1-3; NEEA, No. 30 at pp. 13-14)
Additionally, NEEA submitted test data for 41 standard size
electric and gas clothes dryers, which suggested that the average
CEF<INF>D2</INF> values for the non-ENERGY STAR-qualified electric and
gas clothes dryers in its sample were significantly higher than the
baseline efficiency levels in the preliminary analysis. NEEA also found
that the least efficient electric clothes dryer in its sample had a
measured CEF<INF>D2</INF> that was more than 20 percent higher than
DOE's value for electromechanically controlled consumer clothes dryers.
NEEA encouraged DOE to use these data in developing appropriate
efficiency levels for the engineering analysis. (NEEA, No. 30 at pp. 8-
10)
DOE appreciates the data provided by NEEA and observes that, in
general, the data support the historical trend regarding the lower
efficiency of gas clothes dryers in comparison to electric clothes
dryers. These data also support the updated baseline and incremental
efficiency levels for gas clothes dryers, that latter of which are
discussed in more detail in section IV.C.1.b of this document. Although
the results of NEEA's test sample exhibit a higher average efficiency
among baseline electromechanically controlled electric clothes dryers,
as stated above, DOE set the baseline efficiency levels so that they
would represent a minimally compliant, basic-construction consumer
clothes dryer on the market. Accordingly, DOE has updated the baseline
value for each product class to be equal to the minimum
CEF<INF>D2</INF>, measured using appendix D2, among the corresponding
consumer clothes dryers in its NOPR test sample.
Similarly, DOE notes that the baseline efficiency level for the
vented electric compact (120V) product class has been updated to
reflect the CEF<INF>D2</INF> value using the appendix D2 test procedure
based on the best available data at this time.
Finally, DOE has considered the revised product classes proposed in
this NOPR analysis in updating the baseline efficiency levels, based on
further analysis of results and new testing since the preliminary
analysis. The baseline efficiency levels considered for this NOPR
analysis are presented along with the current standards in Table IV.7
and are discussed in more detail in chapter 5 of the NOPR TSD.
Table IV.7--Notice of Proposed Rulemaking Consumer Clothes Dryer
Baseline Efficiency Levels
------------------------------------------------------------------------
CEFD1 (lb/kWh) CEFD2 (lb/kWh)
Product class *
------------------------------------------------------------------------
Electric, Standard (4.4 ft\3\ or greater 3.73 2.20
capacity)..............................
Electric, Compact (120V) (less than 4.4 3.61 2.36
ft\3\ capacity)........................
Vented Electric, Compact (240V) (less 3.27 2.00
than 4.4 ft\3\ capacity)...............
Vented Gas, Standard (4.4 cubic ft\3\ or 3.30 2.00
greater capacity)......................
Vented Gas, Compact (less than 4.4 ft\3\ 3.30 ** 1.66
capacity)..............................
Ventless Electric, Compact (240V) (less 2.55 2.03
than 4.4 ft\3\ capacity)...............
Ventless Electric, Combination Washer- 2.08 2.27
Dryer..................................
------------------------------------------------------------------------
* As discussed above, the baseline CEFD2 values represent differences in
test procedure between appendix D1 and appendix D2 and do not
constitute backsliding.
** CEFD2 baseline efficiency levels as measured under the Appendix D2
account for differences in the effectiveness of automatic cycle
termination. Manufacturers implement automatic termination in a
variety of ways, which will impact the representations as measured
under Appendix D2 resulting in a range of possible CEFD2 values, as
compared to the same CEFD1 values in the existing Federal standards.
b. Incremental Efficiency Levels
DOE developed incremental efficiency levels by reviewing products
currently available on the market and by testing and reverse
engineering products in the DOE test sample in support of the NOPR. For
each product class, DOE analyzed several efficiency levels and
determined the incremental MPC at each of these levels. DOE initially
reviewed data in DOE's CCD to evaluate the range of efficiencies for
consumer clothes dryers currently available on the market.\28\ As
discussed in chapter 5 of the NOPR TSD, non-ENERGY STAR-qualified
products (generally units with lower rated efficiencies) are typically
[[Page 51755]]
tested using appendix D1, while ENERGY STAR-qualified products are
required to be tested using appendix D2. As a result, DOE conducted
testing on a representative sample of non-ENERGY STAR products using
appendix D2 to determine appropriate initial incremental efficiency
levels for each product class. DOE observed that while electronic
controls are typically implemented with other design options in this
NOPR analysis, the improved automatic termination precision offered by
switching to electronic controls contributed significantly to an
increase in efficiency. This efficiency gain informed the first
incremental efficiency levels for most product classes and was noted
simply as electronic controls in the design options listed in the
following tables. The design options associated with higher efficiency
levels were subsequently distinguished according to specific design
options DOE found manufacturers used to meet these higher efficiencies.
As part of DOE's analysis, the maximum available efficiency level is
defined by the highest efficiency unit currently available on the
market. DOE also defines a ``max-tech'' efficiency level to represent
the maximum possible efficiency for a given product.
---------------------------------------------------------------------------
\28\ DOE's Compliance Certification Database is available for
review at <a href="http://www.regulations.doe.gov/certification-data/#q=Product_Group_s%3A">www.regulations.doe.gov/certification-data/#q=Product_Group_s%3A</a>*.
---------------------------------------------------------------------------
The incremental efficiency levels developed in the preliminary
analysis are presented in Table IV.8 through Table IV.15.
Table IV.8--Preliminary Analysis: Vented Electric Standard Efficiency
Levels
------------------------------------------------------------------------
CEFD2 (lb/kWh)
Level Design option
------------------------------------------------------------------------
Baseline....................... Baseline 2.20
(Electromechanical
Controls).
1.............................. Baseline + Electronic 2.68
Controls.
2.............................. EL1 + Optimized Heating 3.04
System.
3.............................. EL2 + More Advanced 3.27
Automatic Termination
Control System.
4.............................. EL3 + Modulating (2- 3.93
Stage) Heat.
5.............................. EL4 + Inlet Air Preheat 4.21
6.............................. Heat Pump Dryer (Max- 4.30
Tech).
------------------------------------------------------------------------
Table IV.9--Preliminary Analysis: Vented Electric Compact (120V)
Efficiency Levels
------------------------------------------------------------------------
CEFD2 (lb/kWh)
Level Design option
------------------------------------------------------------------------
Baseline....................... Baseline 2.42
(Electromechanical
Controls).
1.............................. Baseline + Electronic 2.95
Controls.
2.............................. EL1 + Optimized Heating 3.35
System.
3.............................. EL2 + More Advanced 4.28
Automatic Termination
Control System.
4.............................. EL3 + Modulating (2- 4.33
Stage) Heat.
5.............................. EL4 + Inlet Air Preheat 4.63
6.............................. Heat Pump Dryer (Max- 4.73
Tech).
------------------------------------------------------------------------
Table IV.10--Preliminary Analysis: Vented Electric Compact (240V)
Efficiency Levels
------------------------------------------------------------------------
CEFD2 (lb/kWh)
Level Design option
------------------------------------------------------------------------
Baseline....................... Baseline 2.00
(Electromechanical
Controls).
1.............................. Baseline + Electronic 2.44
Controls.
2.............................. EL1 + Optimized Heating 2.76
System.
3.............................. EL2 + More Advanced 3.53
Automatic Termination
Control System.
4.............................. EL3 + Modulating (2- 3.57
Stage) Heat.
5.............................. EL4 + Inlet Air Preheat 3.82
6.............................. Heat Pump Dryer (Max- 2.91
Tech).
------------------------------------------------------------------------
Table IV.11--Preliminary Analysis: Vented Gas Standard Efficiency Levels
------------------------------------------------------------------------
CEFD2 (lb/kWh)
Level Design option
------------------------------------------------------------------------
Baseline....................... Baseline 2.63
(Electromechanical
Controls).
1.............................. Baseline + Electronic 3.21
Controls.
2.............................. EL1 + Optimized Heating 3.48
System and More
Advanced Automatic
Termination Control
System.
3.............................. EL2 + Modulating (2- 4.70
Stage) Heat.
4.............................. EL3 + Inlet Air Preheat 5.04
(Max-Tech).
------------------------------------------------------------------------
Table IV.12--Preliminary Analysis: Vented Gas Compact Efficiency Levels
------------------------------------------------------------------------
CEFD2 (lb/kWh)
Level Design option
------------------------------------------------------------------------
Baseline....................... Baseline 1.66
(Electromechanical
Controls).
1.............................. Baseline + Electronic 2.02
Controls.
2.............................. EL1 + Optimized Heating 2.19
System and More
Advanced Automatic
Termination Control
System.
[[Page 51756]]
3.............................. EL2 + Modulating (2- 2.96
Stage) Heat.
4.............................. EL3 + Inlet Air Preheat 3.17
(Max-Tech).
------------------------------------------------------------------------
Table IV.13--Preliminary Analysis: Ventless Electric Standard Efficiency
Levels
------------------------------------------------------------------------
CEFD2 (lb/kWh)
Level Design option
------------------------------------------------------------------------
Baseline....................... Baseline (Electronic 2.23
Controls).
1.............................. Baseline + More 2.95
Advanced Automatic
Termination Control
System.
2.............................. Heat Pump Dryer (Max- 4.50
Tech).
------------------------------------------------------------------------
Table IV.14--Preliminary Analysis: Ventless Electric Compact (240V)
Efficiency Levels
------------------------------------------------------------------------
CEFD2 (lb/kWh)
Level Design option
------------------------------------------------------------------------
Baseline....................... Baseline (Electronic 2.03
Controls).
1.............................. Baseline + More 2.68
Advanced Automatic
Termination Control
System.
2.............................. Heat Pump Dryer (Max- 5.70
Tech).
------------------------------------------------------------------------
Table IV.15--Preliminary Analysis: Ventless Electric Combination Washer-
Dryer Efficiency Levels
------------------------------------------------------------------------
CEFD2 (lb/kWh)
Level Design option
------------------------------------------------------------------------
Baseline....................... Baseline (Electronic 2.27
Controls).
1.............................. Baseline + High Speed 2.55
Spin.
2.............................. Heat Pump Dryer (Max- 5.42
Tech).
------------------------------------------------------------------------
DOE received comments regarding the hybrid heat pump design
investigated in a 2016 study by Pacific Northwest National Laboratory
(``PNNL''), which utilizes a low-wattage electric resistance heater
located downstream of the condenser to provide supplementary heating to
minimize drying cycle time.\29\ ASAP and NRDC encouraged DOE to review
the max-tech level and heat pump technology design option based on
current hybrid heat pump models available and the PNNL prototype hybrid
heat pump clothes dryer which utilized a recuperative heat exchanger in
addition to a resistive heating element and heat pump design. (ASAP,
NRDC, No. 25 at p. 2)
---------------------------------------------------------------------------
\29\ See: <a href="http://www.pnnl.gov/main/publications/external/technical_reports/PNNL-25510.pdf">www.pnnl.gov/main/publications/external/technical_reports/PNNL-25510.pdf</a>.
---------------------------------------------------------------------------
At the time of the preliminary analysis, DOE was not aware of the
efficiency impacts associated with consumer clothes dryers utilizing a
hybrid heat pump design and therefore did not include this design as
part of the preliminary analysis. In the time since the publishing of
the preliminary analysis, DOE has identified at least two manufacturers
that market consumer clothes dryers utilizing a hybrid heat pump
design. DOE investigated the efficiency savings associated with hybrid
heat pump clothes dryers and included in its updated test sample two
hybrid heat pump clothes dryers. DOE observed that, compared to heat
pump-only clothes dryer designs, the hybrid heat pump clothes dryers
had lower efficiencies, albeit higher than the efficiencies of any non-
heat pump clothes dryer. This analysis indicates that use of hybrid
heat pump technology may provide a ``bridge'' in the market between
consumer clothes dryer models utilizing conventional heating elements
and models based on heat pump-only technology. Therefore, in this NOPR,
DOE analyzed an intermediate efficiency level associated with the
hybrid heat pump technology that would capture the efficiency savings
from consumer clothes dryers implementing a conventional heating
element in addition to heat pump technology. The efficiency savings
associated with heat recovery are still captured in the efficiency
levels modeling inlet air preheat.
ASAP, NRDC, the California IOUs, and NEEA requested that DOE review
the consumer clothes dryers currently available on the market,
asserting that at the time of publication of the preliminary analysis,
there were models available with higher efficiency than the preliminary
max-tech levels in the ventless electric standard and compact product
classes. (ASAP, NRDC, No. 25 at pp. 1-2; California IOUs, No. 26 at pp.
3-4; NEEA, No. 30 at pp. 10-11) DOE reviewed the highest efficiency
ventless clothes dryers on the market by examining DOE's Compliance
Certification Management System database (``CCMS'') and ENERGY STAR
databases and included a sample of them in the updated test sample to
better represent the max-tech levels in the proposed electric standard,
electric compact (120V), and ventless electric compact (240V) product
classes.
Chapter 5 of the NOPR TSD discusses the incremental efficiency
levels for each of the product classes proposed in this NOPR analysis.
The revised CEF<INF>D2</INF> efficiency levels for each product class
are shown below in Table IV.16 through Table IV.21, along with the
current energy conservation standards in CEF<INF>D1</INF> for
comparison. As discussed in section IV.C.1.a of this document, the
baseline CEF<INF>D2</INF> values estimated for the preliminary analysis
are lower than the current CEF<INF>D1</INF> values in the energy
conservation standards due to the differences in testing using appendix
D1 and appendix D2. DOE requests
[[Page 51757]]
comment on the incremental efficiency levels used in the NOPR
engineering analysis.
---------------------------------------------------------------------------
\30\ DOE is aware of clothes dryers in the electric standard
product class that perform at higher efficiencies than the proposed
max-tech level, but those models are not representative of the
typical capacity in the electric standard product class. Therefore,
based on the certified performance of those models and additional
investigative testing, DOE determined a representative max-tech
efficiency for the electric standard product class that reflects an
appropriate, representative unit capacity. See chapter 5 of the TSD
for more information.
Table IV.16--Notice of Proposed Rulemaking Analysis: Electric Standard Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Current
standard CEFD1 NOPR CEFD2 (lb/
Efficiency level Design option (lb/kWh) kWh) *
----------------------------------------------------------------------------------------------------------------
Baseline...................................... Baseline (Electromechanical 3.73 2.20
Controls).
1............................................. Baseline + Electronic Controls.. .............. 2.68
2............................................. EL1 + Optimized Heating System.. .............. 3.04
3............................................. EL2 + More Advanced Automatic .............. 3.27
Termination Control System.
4............................................. EL3 + Modulating (2-Stage) Heat. .............. 3.93
5............................................. EL4 + Inlet Air Preheat......... .............. 4.21
6............................................. Hybrid Heat Pump Dryer .............. 5.20
(Additional Resistance Heater).
7............................................. Heat Pump Dryer (Max-Tech)...... .............. \30\ 7.39
----------------------------------------------------------------------------------------------------------------
* As discussed above, the baseline CEFD2 values represent differences in test procedure between Appendix D1 and
Appendix D2 and do not constitute backsliding.
Table IV.17--Notice of Proposed Rulemaking Analysis: Electric Compact (120V) Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Current
standard CEFD1 NOPR CEFD2 (lb/
Efficiency level Design option (lb/kWh) kWh)
----------------------------------------------------------------------------------------------------------------
Baseline...................................... Baseline (Electromechanical 3.61 2.36
Controls).
1............................................. Baseline + Electronic Controls.. .............. 3.15
2............................................. EL1 + Optimized Heating System.. .............. 3.35
3............................................. EL2 + More Advanced Automatic .............. 4.28
Termination Control System.
4............................................. EL3 + Modulating (2-Stage) Heat. .............. 4.33
5............................................. EL4 + Inlet Air Preheat......... .............. 4.63
6............................................. Heat Pump Dryer (Max-Tech)...... .............. 6.37
----------------------------------------------------------------------------------------------------------------
Table IV.18--Notice of Proposed Rulemaking Analysis: Vented Electric Compact (240V) Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Current
standard CEFD1 NOPR CEFD2 (lb/
Efficiency level Design option (lb/kWh) kWh)
----------------------------------------------------------------------------------------------------------------
Baseline...................................... Baseline (Electromechanical 3.27 2.00
Controls).
1............................................. Baseline + Electronic Controls.. .............. 2.44
2............................................. EL1 + Optimized Heating System.. .............. 2.76
3............................................. EL2 + More Advanced Automatic .............. 3.30
Termination Control System.
4............................................. EL3 + Modulating (2-Stage) Heat. .............. 3.57
5............................................. EL4 + Inlet Air Preheat......... .............. 3.82
6............................................. Heat Pump Dryer (Max-Tech)...... .............. 3.91
----------------------------------------------------------------------------------------------------------------
Table IV.19--Notice of Proposed Rulemaking Analysis: Vented Gas Standard and Compact Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Current NOPR CEFD2 (lb/kWh)
standard CEFD1 -------------------------------
Efficiency level Design option (lb/kWh) \31\ Vented gas Vented gas
standard compact
----------------------------------------------------------------------------------------------------------------
Baseline.............................. Baseline 3.30 2.00 1.66
(Electromechanical
Controls).
1..................................... Baseline + Electronic .............. 2.44 2.02
Controls.
2..................................... EL1 + Optimized Heating .............. 3.00 2.49
System and More
Advanced Automatic
Termination Control
System.
3..................................... EL2 + Modulating (2- .............. 3.48 2.89
Stage) Heat.
4..................................... EL3 + Inlet Air Preheat .............. 3.83 3.17
(Max-Tech).
----------------------------------------------------------------------------------------------------------------
[[Page 51758]]
---------------------------------------------------------------------------
\31\ The current standard does not distinguish a separate
product class for compact sized gas consumer clothes dryers. As
such, the current standard may apply to all gas consumer clothes
dryers.
Table IV.20--Notice of Proposed Rulemaking Analysis: Ventless Electric Compact (240V) Efficiency Levels
----------------------------------------------------------------------------------------------------------------
Current
standard CEFD1 NOPR CEFD2 (lb/
Efficiency level Design option (lb/kWh) kWh)
----------------------------------------------------------------------------------------------------------------
Baseline...................................... Baseline (Electronic Controls).. 2.55 2.03
1............................................. Baseline + More Advanced .............. 2.68
Automatic Termination Control
System.
2............................................. Heat Pump Dryer (Max-Tech)...... .............. 6.80
----------------------------------------------------------------------------------------------------------------
Table IV.21--Notice of Proposed Rulemaking Analysis: Ventless Electric Combination Washer-Dryer Efficiency
Levels
----------------------------------------------------------------------------------------------------------------
Current
standard CEFD1 NOPR CEFD2 (lb/
Efficiency level Design option (lb/kWh) kWh)
----------------------------------------------------------------------------------------------------------------
Baseline...................................... Baseline (Electronic Controls).. 2.08 2.27
1............................................. Baseline + High Speed Spin...... .............. 2.55
2............................................. Heat Pump Dryer (Max-Tech)...... .............. 4.01
----------------------------------------------------------------------------------------------------------------
2. Cost Analysis
The cost analysis portion of the engineering analysis is conducted
using one or a combination of cost approaches. The selection of cost
approach depends on a suite of factors, including the availability and
reliability of public information, characteristics of the regulated
product, the availability and timeliness of purchasing the product on
the market. The cost approaches are summarized as follows:
<bullet> Physical teardowns: Under this approach, DOE physically
dismantles a commercially available product, component-by-component, to
develop a detailed bill of materials (``BOM'') for the product.
<bullet> Catalog teardowns: In lieu of physically deconstructing a
product, DOE identifies each component using parts diagrams (available
from manufacturer websites or appliance repair websites, for example)
to develop the BOM for the product.
<bullet> Price surveys: If neither a physical nor catalog teardown
is feasible (for example, for tightly integrated products such as
fluorescent lamps, which are infeasible to disassemble and for which
parts diagrams are unavailable) or cost-prohibitive and otherwise
impractical (e.g. large commercial boilers), DOE conducts price surveys
using publicly available pricing data published on major online
retailer websites and/or by soliciting prices from distributors and
other commercial channels.
In the present case, DOE conducted the analysis using physical
product teardowns to determine the baseline MPC for each product class
as outlined in chapter 5 of the NOPR TSD. DOE developed the cost-
efficiency relationships for each product class as discussed in section
IV.C.3 of this document. DOE developed incremental MPCs based on
product teardowns and manufacturing cost modeling of the expected
design changes at each efficiency level. DOE observed that the basic
product designs of vented electric and vented gas clothes dryers are
similar except for the heating system. DOE also observed that the
technology designs of standard size and compact size clothes dryers are
similar as well, simply scaled in size. As a result, in the absence of
models available on the market at certain efficiency levels for certain
product classes, DOE estimated the incremental MPC for these based on
the same design changes observed for the electric standard product
class. DOE updated the cost-efficiency analysis from the preliminary
analysis by updating the costs of raw materials and purchased
components, as well as updating costs for manufacturing equipment,
labor, and depreciation. DOE also used information from teardown of
units in the updated test sample to inform updates to the cost-
efficiency analysis. Not all units in the updated test sample were torn
down; DOE focused on units recently introduced in the market, units
with unique configuration, and units with technologies that were not
available at the time of the preliminary analysis to better inform the
costs associated with particular product classes and design options.
The resulting BOMs provided the basis for the MPC estimates in this
NOPR. The baseline MPCs for each consumer clothes dryer product class
are listed in Table IV.22, with all costs presented in 2020 dollars.
DOE requests comment on the baseline MPCs in the NOPR engineering
analysis.
Table IV.22--Notice of Proposed Rulemaking: Consumer Clothes Dryer
Baseline Manufacturing Production Costs
------------------------------------------------------------------------
Baseline MPC
Product class (2020$)
------------------------------------------------------------------------
1. Electric, Standard (4.4 cubic feet (ft\3\) or greater $250.65
capacity)..............................................
2. Electric, Compact (120 volts (V)) (less than 4.4 267.09
ft\3\ capacity)........................................
3. Vented Electric, Compact (240V) (less than 4.4 ft\3\ 267.68
capacity)..............................................
4. Gas, Standard (4.4 cubic ft\3\ or greater capacity).. 284.33
5. Gas, Compact (less than 4.4 ft\3\ capacity).......... 309.82
[[Page 51759]]
6. Ventless Electric, Compact (240V) (less than 4.4 464.90
ft\3\ capacity)........................................
7. Electric, Combination Washer-Dryer................... 629.65
------------------------------------------------------------------------
The following section presents the incremental MPCs for each
consumer clothes dryer product class.
3. Cost-Efficiency Results
The results of the engineering analysis are presented as cost-
efficiency data for each of the efficiency levels for each of the
product classes that were analyzed, as well as those extrapolated from
a product class with similar features. DOE developed estimates of MPCs
for each unit in the teardown sample to develop a comprehensive set of
incremental MPCs (i.e., the additional costs manufacturers would likely
incur by producing consumer clothes dryers at each efficiency level
compared to the baseline).
In response to the MPCs presented in the preliminary analysis, AHAM
stated that due to unprecedented supply chain issues facing home
appliance manufacturers resulting from the COVID-19 pandemic and
increased tariffs on raw materials, components, and finished goods, DOE
must take into account these challenges if it is to consider amending
energy conservation standards. AHAM stated it is working to collect
data on the impact of supply chain challenges and would be willing to
share that data with DOE. (AHAM, No. 23 at p. 9) DOE also received
similar feedback from manufacturers during the interview process. DOE
notes that increased costs associated with recent supply chain issues
have been implemented in the cost analysis and are presented in the
MPCs in this NOPR analysis, specifically by way of 5-year moving
averages for material and purchase parts prices.
The resulting incremental MPCs from this NOPR analysis are provided
in Table IV.23 through Table IV.29. See chapter 5 of the NOPR TSD for
additional detail on the engineering analysis. DOE requests comment on
the incremental MPCs from the NOPR engineering analysis, as well as any
data on the impact of supply chain challenges that could better inform
the cost analysis.
Table IV.23--Notice of Proposed Rulemaking Analysis: Electric Standard
Incremental Manufacturing Production Costs
------------------------------------------------------------------------
Incremental
Efficiency level Design option MPC (2020$)
------------------------------------------------------------------------
Baseline....................... Baseline ..............
(Electromechanical
Controls).
1.............................. Baseline + Electronic $11.02
Controls.
2.............................. EL1 + Optimized Heating 13.70
System.
3.............................. EL2 + More Advanced 16.59
Automatic Termination
Control System.
4.............................. EL3 + Modulating (2- 21.00
Stage) Heat.
5.............................. EL4 + Inlet Air Preheat 70.51
6.............................. Hybrid Heat Pump Dryer 226.18
(Additional Resistive
Heater).
7.............................. Heat Pump Dryer (Max- 239.46
Tech).
------------------------------------------------------------------------
Table IV.24--Notice of Proposed Rulemaking Analysis: Electric Compact
(120V) Incremental Manufacturing Production Costs
------------------------------------------------------------------------
Incremental
Efficiency level Design option MPC (2020$)
------------------------------------------------------------------------
Baseline....................... Baseline ..............
(Electromechanical
Controls).
1.............................. Baseline + Electronic $13.43
Controls.
2.............................. EL1 + Optimized Heating 17.76
System.
3.............................. EL2 + More Advanced 21.40
Automatic Termination
Control System.
4.............................. EL3 + Modulating (2- 26.32
Stage) Heat.
5.............................. EL4 + Inlet Air Preheat 83.07
6.............................. Heat Pump Dryer (Max- 220.29
Tech).
------------------------------------------------------------------------
Table IV.25--Notice of Proposed Rulemaking Analysis: Vented Electric
Compact (240V) Incremental Manufacturing Production Costs
------------------------------------------------------------------------
Incremental
Efficiency level Design option MPC (2020$)
------------------------------------------------------------------------
Baseline....................... Baseline ..............
(Electromechanical
Controls).
1.............................. Baseline + Electronic $13.99
Controls.
2.............................. EL1 + Optimized Heating 18.31
System.
[[Page 51760]]
3.............................. EL2 + More Advanced 21.97
Automatic Termination
Control System.
4.............................. EL3 + Modulating (2- 26.88
Stage) Heat.
5.............................. EL4 + Inlet Air Preheat 83.63
6.............................. Heat Pump Dryer (Max- 220.84
Tech).
------------------------------------------------------------------------
Table IV.26--Notice of Proposed Rulemaking Analysis: Vented Gas Standard
Incremental Manufacturing Production Costs
------------------------------------------------------------------------
Incremental
Efficiency level Design option MPC (2020$)
------------------------------------------------------------------------
Baseline....................... Baseline ..............
(Electromechanical
Controls).
1.............................. Baseline + Electronic $14.50
Controls.
2.............................. EL1 + Optimized Heating 17.46
System and More
Advanced Automatic
Termination Control
System.
3.............................. EL2 + Modulating (2- 26.75
Stage) Heat.
4.............................. EL3 + Inlet Air Preheat 76.25
(Max-Tech).
------------------------------------------------------------------------
Table IV.27--Notice of Proposed Rulemaking Analysis: Vented Gas Compact
Incremental Manufacturing Production Costs
------------------------------------------------------------------------
Incremental
Efficiency level Design option MPC (2020$)
------------------------------------------------------------------------
Baseline....................... Baseline ..............
(Electromechanical
Controls).
1.............................. Baseline + Electronic $12.32
Controls.
2.............................. EL1 + Optimized Heating 16.49
System and More
Advanced Automatic
Termination Control
System.
3.............................. EL2 + Modulating (2- 26.97
Stage) Heat.
4.............................. EL3 + Inlet Air Preheat 83.72
(Max-Tech).
------------------------------------------------------------------------
Table IV.28--Notice of Proposed Rulemaking Analysis: Ventless Electric
Compact (240V) Incremental Manufacturing Production Costs
------------------------------------------------------------------------
Incremental
Efficiency level Design option MPC (2020$)
------------------------------------------------------------------------
Baseline....................... Baseline (Electronic ..............
Controls).
1.............................. Baseline + More $3.01
Advanced Automatic
Termination Control
System.
2.............................. Heat Pump Dryer (Max- 184.11
Tech).
------------------------------------------------------------------------
Table IV.29--Notice of Proposed Rulemaking Analysis: Ventless Electric
Combination Washer-Dryer Incremental Manufacturing Production Costs
------------------------------------------------------------------------
Incremental
Efficiency level Design option MPC (2020$)
------------------------------------------------------------------------
Baseline....................... Baseline (Electronic ..............
Controls).
1.............................. Baseline + High Speed $0.00
Spin.
2.............................. Heat Pump Dryer (Max- 383.58
Tech).
------------------------------------------------------------------------
D. Markups Analysis
The markups analysis develops appropriate markups (e.g., retailer
markups, distributor markups, contractor markups) in the distribution
chain and sales taxes to convert the manufacturer selling price
(``MSP'') estimates derived in the engineering analysis to consumer
prices, which are then used in the LCC and PBP analysis. At each step
in the distribution channel, companies mark up the price of the product
to cover costs.
Before developing mark-ups, DOE defines key market participants and
identifies distribution channels.
For consumer clothes dryers, the main parties in the distribution
chain are retailers.
DOE developed baseline and incremental markups for each actor in
the distribution chain. Baseline markups are applied to the price of
products with baseline efficiency, while incremental markups are
applied to the
[[Page 51761]]
difference in price between baseline and higher-efficiency models (the
incremental cost increase). The incremental markup is typically less
than the baseline markup and is designed to maintain similar per-unit
operating costs before and after new or amended standards.\32\
---------------------------------------------------------------------------
\32\ Because the projected price of standards-compliant products
is typically higher than the price of baseline products, using the
same markup for the incremental cost and the baseline cost would
result in higher per-unit operating profit. While such an outcome is
possible, DOE maintains that in markets that are reasonably
competitive it is unlikely that standards would lead to a
sustainable increase in profitability in the long run.
---------------------------------------------------------------------------
DOE relied on economic data from the U.S. Census Bureau to estimate
average baseline and incremental markups. Specifically, DOE used the
2017 Annual Retail Trade Survey for the ``electronics and appliance
stores'' sector to develop retailer markups; \33\ and the 2017 Annual
Wholesale Trade Survey for the ``household appliances, and electrical
and electronic goods merchant wholesalers'' to estimate wholesaler
markups.\34\
---------------------------------------------------------------------------
\33\ US Census Bureau, Annual Retail Trade Survey. 2017.
Available at <a href="http://www.census.gov/programs-surveys/arts.html">www.census.gov/programs-surveys/arts.html</a> (last
accessed November 17, 2021).
\34\ US Census Bureau, Annual Wholesale Trade Survey. 2017.
Available at <a href="http://www.census.gov/awts">www.census.gov/awts</a> (last accessed November 17, 2021).
---------------------------------------------------------------------------
Chapter 6 of the NOPR TSD provides details on DOE's development of
markups for consumer clothes dryers.
E. Energy Use Analysis
The purpose of the energy use analysis is to determine the annual
energy consumption of consumer clothes dryers at different efficiencies
in representative U.S. single-family homes, multi-family residences,
and mobile homes, and to assess the energy savings potential of
increased consumer clothes dryer efficiency. The energy use analysis
estimates the range of energy use of consumer clothes dryers in the
field (i.e., as they are actually used by consumers). The energy use
analysis provides the basis for other analyses DOE performed,
particularly assessments of the energy savings and the savings in
consumer operating costs that could result from adoption of amended or
new standards.
To establish a reasonable range of energy consumption in the field
for consumer clothes dryers, DOE primarily used data from the EIA's
2015 Residential Energy Consumption Survey (``2015 RECS'').\35\ 2015
RECS collected data on 5,686 housing units and was constructed by EIA
to be a national representation of the household population in the
United States. DOE developed household samples from 2015 RECS.\36\
---------------------------------------------------------------------------
\35\ U.S. Department of Energy--Energy Information
Administration, Residential Energy Consumption Survey: 2015 Public
Use Data Files. Available at <a href="http://www.eia.doe.gov/emeu/recs/recspubuse15/pubuse15.html">www.eia.doe.gov/emeu/recs/recspubuse15/pubuse15.html</a> (last accessed November 18, 2021).
\36\ Microdata of 2020 RECS, which contains household samples,
was released in July 2022. Hence it was not available at the time
the NOPR analysis was conducted. However, DOE plans to use 2020 RECS
for the Final Rule analysis.
---------------------------------------------------------------------------
DOE divided the sample of households into four sub-samples to
characterize the product classes being analyzed: standard or compact
clothes dryer using electricity or natural gas as the clothes dryer
fuel. For compact clothes dryers, DOE developed a sub-sample consisting
of households with an electric or gas clothes dryer in multifamily
buildings, manufactured homes, and single-family homes with less than
1,000 square feet and no garage or basement, since these products are
most likely to be found in these housing types.
The energy use analysis requires DOE to establish a range of total
annual usage (number of cycles) in order to estimat
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