Energy Conservation Program: Energy Conservation Standards for Battery Chargers
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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 battery chargers. EPCA also requires the U.S. Department of Energy ("DOE" or "Department") 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 battery chargers, and also announces a public meeting to receive comment on these proposed standards and associated analyses and results.
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<title>Federal Register, Volume 88 Issue 50 (Wednesday, March 15, 2023)</title>
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[Federal Register Volume 88, Number 50 (Wednesday, March 15, 2023)]
[Proposed Rules]
[Pages 16112-16168]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2023-04765]
[[Page 16111]]
Vol. 88
Wednesday,
No. 50
March 15, 2023
Part III
Department of Energy
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10 CFR Part 430
Energy Conservation Program: Energy Conservation Standards for Battery
Chargers; Proposed Rule
Federal Register / Vol. 88 , No. 50 / Wednesday, March 15, 2023 /
Proposed Rules
[[Page 16112]]
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DEPARTMENT OF ENERGY
10 CFR Part 430
[EERE-2020-BT-STD-0013]
RIN 1904-AE50
Energy Conservation Program: Energy Conservation Standards for
Battery Chargers
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking; 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 battery
chargers. EPCA also requires the U.S. Department of Energy (``DOE'' or
``Department'') 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 battery chargers, 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 Thursday,
April 27, 2023, 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 May 15, 2023.
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 April 14, 2023.
ADDRESSES: Interested persons are encouraged to submit comments using
the Federal eRulemaking Portal at <a href="http://www.regulations.gov">www.regulations.gov</a>, under docket
number EERE-2020-BT-STD-0013. Follow the instructions for submitting
comments. Alternatively, interested persons may submit comments,
identified by docket number EERE-2020-BT-STD-0013, by any of the
following methods:
Email: <a href="/cdn-cgi/l/email-protection#d2b0b3a6a6b7a0abb1bab3a0b5b7a0a1e0e2e0e2818696e2e2e3e192b7b7fcb6bdb7fcb5bda4"><span class="__cf_email__" data-cfemail="87e5e6f3f3e2f5fee4efe6f5e0e2f5f4b5b7b5b7d4d3c3b7b7b6b4c7e2e2a9e3e8e2a9e0e8f1">[email protected]</span></a>. Include the docket
number EERE-2020-BT-STD-0013 in the subject line of the message.
Postal Mail: Appliance and Equipment Standards Program, U.S.
Department of Energy, Building Technologies Office, Mailstop EE-5B,
1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone:
(202) 287-1445. If possible, please submit all items on a compact disc
(``CD''), in which case it is not necessary to include printed copies.
Hand Delivery/Courier: Appliance and Equipment Standards Program,
U.S. Department of Energy, Building Technologies Office, 950 L'Enfant
Plaza SW, 6th Floor, Washington, DC 20024. Telephone: (202) 287-1445.
If possible, please submit all items on a CD, in which case it is not
necessary to include printed copies.
No telefacsimiles (``faxes'') will be accepted. For detailed
instructions on submitting comments and additional information on this
process, see section VII 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-2020-BT-STD-0013">www.regulations.gov/docket/EERE-2020-BT-STD-0013</a>. The docket web page contains instructions on how
to access all documents, including public comments, in the docket. See
section VII of this document for information on how to submit comments
through <a href="http://www.regulations.gov">www.regulations.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#5f3a313a2d3826712c2b3e313b3e2d3b2c1f2a2c3b303571383029"><span class="__cf_email__" data-cfemail="1f7a717a6d7866316c6b7e717b7e6d7b6c5f6a6c7b707531787069">[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
proposed rulemaking.
FOR FURTHER INFORMATION CONTACT: Mr. Jeremy Dommu, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Office, EE-2J, 1000 Independence Avenue SW, Washington, DC
20585-0121. Email: <a href="/cdn-cgi/l/email-protection#a6e7d6d6cacfc7c8c5c3f5d2c7c8c2c7d4c2d5f7d3c3d5d2cfc9c8d5e6c3c388c2c9c388c1c9d0"><span class="__cf_email__" data-cfemail="91d0e1e1fdf8f0fff2f4c2e5f0fff5f0e3f5e2c0e4f4e2e5f8feffe2d1f4f4bff5fef4bff6fee7">[email protected]</span></a>.
Ms. Melanie Lampton, U.S. Department of Energy, Office of the
General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC
20585-0121. Telephone: (240) 751-5157. Email:
<a href="/cdn-cgi/l/email-protection#bef3dbd2dfd0d7db90f2dfd3cecad1d0fed6cf90dad1db90d9d1c8"><span class="__cf_email__" data-cfemail="c18ca4ada0afa8a4ef8da0acb1b5aeaf81a9b0efa5aea4efa6aeb7">[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#b0f1c0c0dcd9d1ded3d5e3c4d1ded4d1c2d4c3e1c5d5c3c4d9dfdec3f0d5d59ed4dfd59ed7dfc6"><span class="__cf_email__" data-cfemail="f2b382829e9b939c9197a186939c9693809681a3879781869b9d9c81b29797dc969d97dc959d84">[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. History of Standards Rulemaking for Battery Chargers
3. Deviation From Appendix A
III. General Discussion
A. General Comments
B. Scope of Coverage
C. Test Procedure
D. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
E. Energy Savings
1. Determination of Savings
2. Significance of Savings
F. Economic Justification
1. Specific Criteria
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. Product Classes
2. Technology Options
B. Screening Analysis
1. Screened-Out Technologies
2. Remaining Technologies
C. Engineering Analysis
1. Efficiency Analysis
a. Baseline Energy Use
b. Higher Efficiency Levels
2. Cost Analysis
3. Cost-Efficiency Results
[[Page 16113]]
D. Markups Analysis
E. Energy Use Analysis
F. Life-Cycle Cost and Payback Period Analysis
1. Product Cost
2. Annual Energy Consumption
3. Energy Prices
4. Product Lifetime
5. Discount Rates
6. Energy Efficiency Distribution in the No-New-Standards Case
7. 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. Markup Scenarios
3. Manufacturer Interviews
K. Emissions Analysis
1. Air Quality Regulations Incorporated in DOE's Analysis
L. Monetizing Emissions Impacts
1. Monetization of Greenhouse Gas Emissions
a. Social Cost of Carbon
b. Social Cost of Methane and Nitrous Oxide
2. Monetization of Other 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 Battery Chargers
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
1. Description of Reasons Why Action Is Being Considered
2. Objectives of, and Legal Basis for, Rule
3. Description on Estimated Number of Small Entities Regulated
4. Description and Estimate of Compliance Requirements for Small
Entities
5. Duplication, Overlap, and Conflict With Other Rules and
Regulations
6. Significant Alternatives to the Rule
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Information Quality
VII. Public Participation
A. Participation in the Webinar
B. Procedure for Submitting Prepared General Statements for
Distribution
C. Conduct of the Webinar
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
The Energy Policy and Conservation Act, Public Law 94-163, as
amended (``EPCA''),\1\ authorizes DOE to regulate the energy efficiency
of a number of consumer products and certain industrial equipment. (42
U.S.C. 6291-6317) Title III, Part B of EPCA established the Energy
Conservation Program for Consumer Products Other Than Automobiles. (42
U.S.C. 6291-6309) These products include battery chargers, the subject
of this rulemaking.
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\1\ All references to EPCA in this document refer to the statute
as amended through the Energy Act of 2020, Public Law 116-260 (Dec.
27, 2020), which reflect the last statutory amendments that impact
Parts A and A-1 of EPCA.
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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 notice of
proposed rulemaking 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 new multi-metric energy conservation
standards for battery chargers. The proposed standards, which are
expressed in max active charge energy and max standby and off modes
power values, are shown in Table I.1. These proposed standards, if
adopted, would apply to all battery chargers listed in Table I.1
manufactured in, or imported into, the United States starting on the
date 2 years after the publication of the final rule for this
rulemaking.
Table I.1--Proposed Energy Conservation Standards for Battery Chargers
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Maximum active Maximum standby
Product class Battery energy Ebatt mode energy Ea mode power Psb* Off mode power
(Wh) (Wh) (W) Poff (W)
----------------------------------------------------------------------------------------------------------------
1a Fixed-Location Wireless..... <=100.................. 1.718 * Ebatt + 1.5............... 0
8.5.
1b Open-Placement Wireless..... N/A.................... N/A............... 0.8 (Pnb only).... 0
2a Low-Energy.................. <=100.................. 1.222 * Ebatt + 0.00098 * Ebatt + 0
4.980. 0.4.
2b Medium-Energy............... 100-1,000.............. 1.367 * Ebatt + -
9.560.
2c High-Energy................. >1,000................. 1.323 * Ebatt +
34.361.
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* Standby mode power is the sum of no-battery mode power and maintenance mode power, unless noted otherwise.
[[Page 16114]]
A. Benefits and Costs to Consumers
Table I.2 presents DOE's evaluation of the economic impacts of the
proposed standards on consumers of battery chargers, as measured by the
average life-cycle cost (``LCC'') savings and the simple payback period
(``PBP'').\2\ The average LCC savings are positive or nearly zero for
all product classes and the PBP is similar to or less than the average
lifetime of battery chargers, which is estimated to range from 3.0 to
10.0 years (see section IV.F of this document).
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\2\ 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.6 of this document). The simple PBP, which is
designed to compare specific efficiency levels, is measured relative
to the baseline product (see section IV.C of this document).
Table I.2--Impacts of Proposed Energy Conservation Standards on
Consumers of Battery Chargers
------------------------------------------------------------------------
Average LCC Simple payback
Battery charger product class savings period
(2021$) (years)
------------------------------------------------------------------------
Fixed-Location Wireless Chargers........ -0.03 3.8
Open-Placement Wireless Chargers........ 0.12 4.1
Low-Energy Wired Chargers............... 0.13 4.0
Medium-Energy Wired Chargers............ 1.55 4.4
High-Energy Wired Chargers.............. 14.32 1.5
------------------------------------------------------------------------
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 (2023-2056). Using a real discount rate of
9.1 percent, DOE estimates that the INPV for manufacturers of battery
charger applications in the case without amended standards is $78.9
billion in 2021$. Under the proposed standards, the change in INPV is
estimated to range from 4.6 percent to -0.3 percent, which is
approximately -$3,659 million to -$214 million. To bring products into
compliance with amended standards, it is estimated that the industry
would incur total conversion costs of $398.2 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.
C. National Benefits and Costs \3\
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\3\ All monetary values in this document are expressed in 2023
dollars.
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DOE's analyses indicate that the proposed energy conservation
standards for battery chargers would save a significant amount of
energy. Relative to the case without amended standards, the lifetime
energy savings for battery chargers purchased in the 30-year period
that begins in the anticipated year of compliance with the amended
standards (2027-2056) amount to 1.2 quadrillion British thermal units
(``Btu''), or quads.\4\ This represents a savings of 17.6 percent
relative to the energy use of these products in the case without
amended standards (referred to as the ``no-new-standards case'').
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\4\ 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.1 of this document.
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The cumulative net present value (``NPV'') of total consumer
benefits of the proposed standards for battery chargers ranges from
$3.7 billion (at a 7-percent discount rate) to $7.5 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 battery chargers purchased in 2027-2056.
In addition, the proposed standards for battery chargers 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 40 million
metric tons (``Mt'') \5\ of carbon dioxide (``CO<INF>2</INF>''), 272
thousand tons of methane (``CH<INF>4</INF>''), 0.42 thousand tons of
nitrous oxide (``N<INF>2</INF>O''), 18 thousand tons of sulfur dioxide
(``SO<INF>2</INF>''), 62 thousand tons of nitrogen oxides
(``NO<INF>X</INF>''), and 0.11 tons of mercury (``Hg'').\6\
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\5\ A metric ton is equivalent to 1.1 short tons. Results for
emissions other than CO<INF>2</INF> are presented in short tons.
\6\ DOE calculated emissions reductions relative to the no-new-
standards case, which reflects key assumptions in the Annual Energy
Outlook 2022 (``AEO2022''). AEO2022 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 AEO2022 assumptions that effect air pollutant
emissions.
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DOE estimates the value of climate benefits from a reduction in
greenhouse gases (GHG) 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
GHG (SC-GHG).\7\ 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 $2.1 billion. DOE does not have a single central SC-GHG
point estimate and it emphasizes the importance and value of
considering the
[[Page 16115]]
benefits calculated using all four sets of SC-GHG estimates.
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\7\ 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 proposed rule, DOE has reverted to its approach prior to the
injunction and presents monetized benefits where appropriate and
permissible under law.
\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 (``February 2021 SC-GHG TSD'').
<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>.
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DOE estimated the monetary health benefits of SO<INF>2</INF> and
NO<INF>X</INF> emissions reductions using benefit per ton estimates
from the scientific literature, as discussed in section IV.L. of this
document. DOE estimated the present value of the health benefits would
be $1.8 billion using a 7-percent discount rate, and $3.8 billion using
a 3-percent discount rate.\9\ 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.
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\9\ DOE estimates the economic value of these emissions
reductions resulting from the considered TSLs for the purpose of
complying with the requirements of Executive Order 12866.
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Table I.3 summarizes the economic benefits and costs expected to
result from the proposed standards for battery chargers. 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 Economic Benefits and Costs of Proposed Energy
Conservation Standards for Battery Chargers
[TSL 2]
------------------------------------------------------------------------
Billion $2021
------------------------------------------------------------------------
3% discount rate
------------------------------------------------------------------------
Consumer Operating Cost Savings...................... 9.0
Climate Benefits *................................... 2.1
Health Benefits **................................... 3.8
Total Benefits [dagger].............................. 15.0
Consumer Incremental Product Costs................... 1.4
Net Benefits......................................... 13.5
------------------------------------------------------------------------
7% discount rate
------------------------------------------------------------------------
Consumer Operating Cost Savings...................... 4.6
Climate Benefits * (3% discount rate)................ 2.1
Health Benefits **................................... 1.8
Total Benefits [dagger].............................. 8.6
Consumer Incremental Product Costs................... 0.9
Net Benefits......................................... 7.7
------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with product
name 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) (see
section IV.L of this NOPR). Together these represent the global 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 DOE does not have a single central SC-GHG point estimate.
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 proposed rule,
DOE has reverted to its approach prior to the injunction and presents
monetized 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. 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 quantified and 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 DOE does not have a single central SC-GHG point estimate.
DOE emphasizes the importance and value of considering the benefits
calculated using all four sets of SC-GHG estimates.
The benefits and costs of the proposed standards 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 climate and health benefits
of 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 2023, 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 2023. 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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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 battery chargers 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 battery chargers 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 IV.L of
this document.
Using a 7-percent discount rate for consumer benefits and costs and
health benefits from reduced NO<INF>X</INF> and SO<INF>2</INF>
emissions, and the 3-percent discount rate case for climate benefits
from
[[Page 16116]]
reduced GHG emissions, the estimated cost of the standards proposed in
this rule is $89 million per year in increased equipment costs, while
the estimated annual benefits are $457 million in reduced equipment
operating costs, $120 million in climate benefits, and $178 million in
health benefits. In this case. The net benefit would amount to $665
million per year.
Using a 3-percent discount rate for all benefits and costs, the
estimated cost of the proposed standards is $81 million per year in
increased equipment costs, while the estimated annual benefits are $500
million in reduced operating costs, $120 million in climate benefits,
and $215 million in health benefits. In this case, the net benefit
would amount to $754 million per year.
Table I.4 presents the total estimated monetized benefits and costs
associated with the proposed standard, expressed in terms of annualized
values. 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 NO<INF>X</INF> and SO<INF>2</INF>
emissions, and the 3-percent discount rate case for climate benefits
from reduced GHG emissions, the estimated cost of the standards
proposed in this rule is $89 million per year in increased equipment
costs, while the estimated annual benefits are $457 million in reduced
equipment operating costs, $120 million in climate benefits, and $178
million in health benefits. In this case. The net benefit would amount
to $665 million per year.
Using a 3-percent discount rate for all benefits and costs, the
estimated cost of the proposed standards is $81 million per year in
increased equipment costs, while the estimated annual benefits are $500
million in reduced operating costs, $120 million in climate benefits,
and $215 million in health benefits. In this case, the net benefit
would amount to $754 million per year.
Table I.4--Annualized Benefits and Costs of Proposed Energy Conservation Standards for Battery Chargers
[TSL 2]
----------------------------------------------------------------------------------------------------------------
Million 2021$/year
-----------------------------------------------
Low-net- High-net-
Primary benefits benefits
estimate estimate estimate
----------------------------------------------------------------------------------------------------------------
3% discount rate
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. 500 487 516
Climate Benefits *.............................................. 120 120 120
Health Benefits **.............................................. 215 215 215
Total Benefits [dagger]......................................... 834 821 850
Consumer Incremental Product Costs.............................. 81 90 71
Net Benefits.................................................... 754 731 779
----------------------------------------------------------------------------------------------------------------
7% discount rate
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings................................. 457 447 469
Climate Benefits * (3% discount rate)........................... 120 120 120
Health Benefits **.............................................. 178 178 178
Total Benefits [dagger]......................................... 754 744 766
Consumer Incremental Product Costs.............................. 89 98 79
Net Benefits.................................................... 665 646 687
----------------------------------------------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with battery chargers shipped in 2027-2056. These
results include benefits to consumers which accrue after 2056 from the products shipped in 2027-2056. The
Primary, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy prices from the
AEO2022 Reference case, Low Economic Growth case, and High Economic Growth case, respectively. In addition,
incremental equipment costs reflect a medium decline rate in the Primary Estimate, a low decline rate in the
Low Net Benefits Estimate, and a high decline rate in the High Net Benefits Estimate. Note that the Benefits
and Costs may not sum to the Net Benefits due to rounding.
* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.L of this
NOPR). 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 sets of 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 proposed rule, DOE has reverted to its approach prior to the injunction and presents
monetized 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. 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'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
[[Page 16117]]
all product classes covered by this proposal. As for economic
justification, 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, and a 3-percent
discount rate case for GHG social costs, the estimated cost of the
proposed standards for battery chargers is $89 million per year in
increased battery charger costs, while the estimated annual benefits
are $457 million in reduced battery charger operating costs, $120
million in climate benefits and $178 million in health benefits. The
net benefit amounts to $665 million per year.
The significance of energy savings is evaluated by DOE on a case-
by-case basis considering the specific circumstances surrounding a
specific rulemaking. The standards are projected to result in estimated
national energy savings of 1.2 quad FFC. DOE has initially determined
the energy savings that would result 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
TSD.
DOE also considered more-stringent energy efficiency levels as
potential standards, and is still considering them in this rulemaking.
However, DOE has tentatively concluded that the potential burdens of
the more-stringent energy efficiency levels would outweigh the
projected benefits.
Based on consideration of the public comments DOE receives in
response to this 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
battery chargers.
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 battery
chargers, the subject of this document. (42 U.S.C. 6291(32); 42 U.S.C.
6292(a)(20)) EPCA directed DOE to issue a final rule that prescribes
energy conservation standards for battery chargers or classes of
battery charges or to determine that no energy conservation standard is
technically feasible or economically justified. 42 U.S.C.
6295(u)(1)(E)(i)(II) 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 battery chargers appear at title 10 of the Code
of Federal Regulations (``CFR'') part 430, subpart B, appendix Y and
appendix Y1.
DOE must follow specific statutory criteria for prescribing new or
amended standards for covered products, including battery chargers. 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))
Moreover, DOE may not prescribe a standard: (1) for certain
products, including battery chargers, if no test procedure has been
established for the product, or (2) if DOE determines by rule that the
standard is not technologically feasible or economically justified. (42
U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a 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 on the proposed standard,
and by considering, to the greatest extent practicable, the following
seven statutory factors:
(1) The economic impact of the standard on manufacturers and
consumers of the products subject to the standard;
(2) The savings in operating costs throughout the estimated average
life of the covered products in the type (or class) compared to any
increase in the price, initial charges, or maintenance expenses for the
covered products that are likely to result from the imposition of the
standard;
(3) The total projected amount of energy (or as applicable, water)
savings likely to result directly from the imposition of the standard;
(4) Any lessening of the utility or the performance of the covered
products likely to result from the imposition of the standard;
(5) The impact of any lessening of competition, as determined in
writing by the Attorney General, that is likely to result from the
imposition of the standard;
(6) The need for national energy and water conservation; and
(7) Other factors the Secretary of Energy (``Secretary'') considers
relevant.
(42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
[[Page 16118]]
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
subcategories. 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 battery chargers
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
In a final rule published on June 13, 2016 (``June 2016 Final
Rule''), DOE prescribed the current energy conservation standards for
battery chargers manufactured on and after June 13, 2018. 81 FR 38266.
These standards are set forth in DOE's regulations at 10 CFR 430.32(z)
and are summarized in Table II.1.
Table II.1--Current Federal Energy Conservation Standards for Battery
Chargers
------------------------------------------------------------------------
Maximum unit of
energy
Product class Battery charger consumption
classification (UEC) * (kWh/
year)
------------------------------------------------------------------------
1............................. Low-energy inductive 3.04.
battery chargers to
be used in wet
environment with
associated battery
energy of less than
or equal to 5 watt-
hours (Wh).
2............................. Low-energy, low- 0.1440 * Ebatt +
voltage battery 2.95.
chargers with
associated battery
energy of less than
100Wh, and battery
voltage of less than
4 volts (V).
3............................. Low-energy, medium- For Ebatt <
voltage battery 10Wh, 1.42;
chargers with For Ebatt >=
associated battery 10Wh,
energy of less than 0.0255 * Ebatt +
100Wh, and battery 1.16.
voltage of 4V to 10V.
4............................. Low-energy, high- 0.11 * Ebatt +
voltage battery 3.18.
chargers with
associated battery
energy of less than
100Wh, and battery
voltage of more than
10V.
5............................. Medium-energy, low- 0.0257 * Ebatt +
voltage battery 0.815.
chargers with
associated battery
energy of 100Wh to
3,000Wh, and battery
voltage of less than
20V.
6............................. Medium-energy, high- 0.0778 * Ebatt +
voltage battery 2.4.
chargers with
associated battery
energy of 100Wh to
3,000Wh, and battery
voltage of higher
than or equal to 20V.
7............................. High-energy battery 0.0502 * Ebatt +
chargers with 4.53.
associated battery
energy of more than
3,000Wh.
------------------------------------------------------------------------
* Maximum UEC is expressed as a function of representative battery
energy (Ebatt).
2. History of Standards Rulemaking for Battery Chargers
On September 16, 2020, DOE published notice that it was initiating
an early assessment review to determine whether any new or amended
standards would satisfy the relevant requirements of EPCA for a new or
amended energy conservation standard for battery chargers and a request
for information (``RFI''). 85 FR 57787 (``September 2020 Early
Assessment Review RFI''). Specifically, through the published notice
and request for information, DOE sought data and information that could
enable the agency to determine whether DOE should propose a ``no new
standard'' determination because a more stringent standard: (1) would
not result in a significant savings of energy; (2) is not
technologically feasible; (3) is not economically justified; or (4) any
combination of foregoing. Id.
Subsequently, DOE published a preliminary analysis on March 3, 2022
(``March 2022 Preliminary Analysis'') to respond to comments pertaining
to the September 2020 Early Assessment Review RFI, and presented
preliminary engineering analyses based on a multi-metric approach that
independently measures active mode, standby mode, and off mode energy
use metrics. 87 FR 11990. DOE conducted in-depth technical analyses in
the following
[[Page 16119]]
areas: (1) engineering; (2) markups to determine product price; (3)
energy use; (4) LCC'' and ``PBP''; and (5) national impacts. The
preliminary TSD that presents the methodology and results of each of
these analyses is available at <a href="https://www.regulations.gov/docket/EERE-2020-BT-STD-0013">https://www.regulations.gov/docket/EERE-2020-BT-STD-0013</a>.
DOE received comments in response to the March 2022 Preliminary
Analysis from the interested parties listed in Table II.2.
Table II.2--March 2022 Preliminary Analysis Written Comments
----------------------------------------------------------------------------------------------------------------
Comment number
Commenter(s) Abbreviation in the docket Commenter type
----------------------------------------------------------------------------------------------------------------
UL Solutions............................ UL........................ 11 Efficiency Organization.
Northwest Energy Efficiency Alliance.... NEEA...................... 16 Efficiency Organization.
Association of Home Appliance Joint Trade Associations.. 17 Trade Association.
Manufacturers; Consumer Technology
Association; Information Technology
Industry Council; National Electrical
Manufacturers Association; Outdoor
Power Equipment Institute; Power Tool
Institute.
Pacific Gas and Electric Company; San CA IOUs................... 18 Utility Association.
Diego Gas & Electric Company; Southern
California Edison.
Appliance Standards Awareness Project; Joint Efficiency Advocates 19 Efficiency Organization.
American Council for an Energy-
Efficiency Economy; Consumer Federation
of America; New York State Energy
Research and Development Authority.
Delta-Q Technologies.................... Delta-Q................... 20 Manufacturer.
----------------------------------------------------------------------------------------------------------------
A parenthetical reference at the end of a comment quotation or
paraphrase provides the location of the item in the public record.\11\
To the extent that interested parties have provided written comments
that are substantively consistent with any oral comments provided
during the April 2022 public meeting, DOE cites the written comments
throughout this document. Any oral comments provided during the webinar
that are not substantively addressed by written comments are summarized
and cited separately throughout this document.
---------------------------------------------------------------------------
\11\ The parenthetical reference provides a reference for
information located in the docket of DOE's rulemaking to develop
energy conservation standards for battery chargers. (Docket No.
EERE-2020-BT-STD-0013, 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).
---------------------------------------------------------------------------
3. Deviation From Appendix A
In accordance with section 3(a) of 10 CFR part 430, subpart C,
appendix A (``appendix A''), DOE notes that it is deviating from the
provision in appendix A regarding the NOPR stages for an energy
conservation standards rulemaking. Section 6(f)(2) of appendix A
specifies that the length of the public comment period for a NOPR will
not be less than 75 calendar days. For this NOPR, DOE has opted to
instead provide a 60-day comment period. DOE requested comment in the
March 2022 Preliminary Analysis on the technical and economic analyses
and provided stakeholders with a 60-day comment period. 87 FR 11990.
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.
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. General Comments
This section summarizes general comments received from interested
parties regarding rulemaking timing and process.
In response to the March 2022 Preliminary Analysis, Joint Trade
Associations commented that DOE's process for this rulemaking
undermines the value of early stakeholder engagement because: (1) DOE
developed the preliminary analysis based on a proposed test procedure
rather than a finalized one; and (2) DOE has provided a shortened
comment period on the preliminary analysis that overlaps with the
comment period for the external power supply (``EPS'') preliminary
analysis as well as a preliminary analysis on amended standards for
electric motors, both of which impact many of the same manufacturers as
the ones for battery chargers. (Joint Trade Associations, No. 17 at pp.
2-3) The Joint Trade Associations further commented that the proposed
test procedure has drawn serious concerns from several commenters, and
it would be flawed without addressing opposing comments. The Joint
Trade Associations also suggested that amended standards would not be
justified regardless of whether the standards were analyzed using
either the current test procedure or the recently finalized new test
procedure in appendix Y1 and that, as a result, DOE should issue a
notice of proposed determination not to amend battery charger
standards. (Joint Trade Associations, No. 17 at p. 4)
DOE reiterates that the preliminary analysis was intended to
provide stakeholders with an opportunity to comment on the various
methodologies DOE intended to use in the NOPR. DOE again notes that the
preliminary analysis results should not be relied upon to assess
whether amended standards for battery chargers are justified. In
addition, by conducting the March 2022 Preliminary Analysis with the
proposed test procedure, DOE gave stakeholders an early preview of what
the new multi-metric standards may potentially look like, allowing
stakeholders enough time to review and comment on potential issues with
DOE's approach and results. DOE notes that there were concerns and
potential test burdens associated with the original proposed test
procedure; however, these issues have been addressed in the test
procedure final rule published in September 2022 (``September 2022 Test
Procedure Final Rule''). 87 FR 55090. As such, unless otherwise noted,
test results used in support of this NOPR were measured using the
multi-metric test procedure as finalized in the September 2022 Test
Procedure Final Rule. DOE further notes that because the finalized test
procedure adopts the multi-metric approach, the current integrated UEC
standards would
[[Page 16120]]
no longer be applicable to test results under the new test procedure.
As such, even if DOE were to hold the multi-metric standards at the
same level as the current UEC standards, DOE would still need to amend
the current standards to translate them to the multi-metric one. DOE
understands that the Joint Trade Associations are concerned that
amended standards might not be justified, based on results from the
preliminary analysis. However, DOE has expanded its analysis further in
the NOPR stage and has more robust results that indicate amended
standards can result in significant conservation of energy. These
results are further discussed in section V of this NOPR document.
With regards to a shortened comment period, DOE believes the 60-day
comment period was sufficient for reviewing the methodologies and
results presented. However, DOE did not receive any comment period
extension requests from any stakeholder during the preliminary analysis
comment period.
NEEA stated its general support for several aspects of the
preliminary TSD, including the general framework and approach to
battery charger efficiency metrics and standards levels, active
candidate standard levels (CSLs) that are continuous across product
class boundaries, the approach to translate current compliance
certification data (CCD) to active mode by subtracting 5 hours of
battery maintenance power from the total charge and maintenance energy
measurement, and the technology neutral definition of wireless
charging. (NEEA, No. 16 at p. 5) DOE appreciates NEEA's general support
on these aspects of DOE's battery charger rulemaking.
B. Scope of Coverage
This NOPR covers those consumer products that meet the definition
of ``battery chargers,'' which are devices that charge batteries for
consumer products, including battery chargers embedded in other
consumer products. 10 CFR 430.2. (See also 42 U.S.C. 6291(32)) A
battery charger may be wholly embedded in another consumer product,
partially embedded in another consumer product, or wholly separate from
another consumer product. Currently under the test procedure at
appendix Y, only consumer wired chargers and wet environment wireless
inductive chargers designed for battery energies of no more than 5
watt-hours are covered battery charger product classes.
In the September 2022 Test Procedure Final Rule, DOE expanded the
battery charger test procedure coverage to cover all fixed-location
wireless chargers in all modes of operation, and open-placement
wireless chargers in no-battery mode only. 87 FR 55090, 55095-55098. As
such, in this NOPR, DOE is proposing to expand the scope of battery
energy conservation standards to cover these fixed-location and open-
placement wireless chargers in separate product classes.
See section IV.A.1 of this document for discussion of the product
classes analyzed in this NOPR.
C. Test Procedure
EPCA sets forth generally applicable criteria and procedures for
DOE's adoption and amendment of test procedures. (42 U.S.C. 6293)
Manufacturers of covered products must use these test procedures to
certify to DOE that their product complies with energy conservation
standards and to quantify the efficiency of their product. As stated,
currently, only consumer wired chargers and wet environment wireless
inductive chargers designed for batteries with energies of no more than
5 watt-hours are covered under the test procedure scope at 10 CFR part
430, subpart B, appendix Y. However, on September 8, 2022, DOE
published a test procedure final rule that expanded the battery charger
test procedure coverage to cover all fixed-location and open-placement
wireless chargers, and adopted the multi-metric test procedure
approach, where each mode of operation is independently regulated, thus
making usage profiles no longer required. 87 FR 55090, 55092-55093.
This new test procedure is in the separate appendix Y1, and
manufacturers will be required to use results of testing under the new
test procedure to determine compliance with amended energy conservation
standards.
D. Technological Feasibility
1. General
In each energy conservation standards rulemaking, DOE conducts a
screening analysis based on information gathered on all current
technology options and prototype designs that could improve the
efficiency of the products or equipment that are the subject of the
rulemaking. As the first step in such an analysis, DOE develops a list
of technology options for consideration in consultation with
manufacturers, design engineers, and other interested parties. DOE then
determines which of those means for improving efficiency are
technologically feasible. DOE considers technologies incorporated in
commercially-available products or in working prototypes to be
technologically feasible. Sections 6(b)(3)(i) and 7(b)(1) of appendix A
to 10 CFR part 430 subpart C (``Process Rule'').
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 the Process Rule. Section
IV.B of this document discusses the results of the screening analysis
for battery chargers, 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 technical support document
(``TSD'').
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt an amended standard for a type or class
of covered product, it must determine the maximum improvement in energy
efficiency or maximum reduction in energy use that is technologically
feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the
engineering analysis, DOE determined the maximum technologically
feasible (``max-tech'') improvements in energy efficiency for battery
chargers, 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
of this proposed rule and in chapter 5 of the NOPR TSD.
E. Energy Savings
1. Determination of Savings
For each trial standard level (``TSL''), DOE projected energy
savings from application of the TSL to battery chargers purchased in
the 30-year period that begins in the year of compliance with the
proposed standards (2027-2056).\12\ The savings are measured over the
entire lifetime of
[[Page 16121]]
battery chargers 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.
---------------------------------------------------------------------------
\12\ 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 battery chargers. 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.\13\ 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.1 of this document.
---------------------------------------------------------------------------
\13\ The FFC metric is discussed in DOE's statement of policy
and notice of policy amendment. 76 FR 51282 (Aug. 18, 2011), as
amended at 77 FR 49701 (Aug. 17, 2012).
---------------------------------------------------------------------------
2. Significance of Savings
To adopt any new or amended standards for a covered product, DOE
must determine that such action would result in significant energy
savings. (42 U.S.C. 6295(o)(3)(B))
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.\14\ 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.
---------------------------------------------------------------------------
\14\ 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. DOE has initially determined the energy savings from the
proposed standard levels at TSL 2 are ``significant'' within the
meaning of 42 U.S.C. 6295(o)(3)(B).
F. Economic Justification
1. Specific Criteria
As noted previously, EPCA provides seven factors to be evaluated in
determining whether a potential energy conservation standard is
economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(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
[[Page 16122]]
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.E, 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 GHGs associated with energy production and use. DOE
conducts an emissions analysis to estimate how potential standards may
affect these emissions, as discussed in section IV.K; the estimated
emissions impacts are reported in section IV.L of this document. DOE
also estimates the economic value of emissions reductions resulting
from the considered TSLs, as discussed in section IV.L of this
document.
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 V.B of this proposed rule.
IV. Methodology and Discussion of Related Comments
This section addresses the analyses DOE has performed for this
rulemaking with regard to battery chargers. Separate subsections
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/document/EERE-Mar-BT-STD-0013">www.regulations.gov/document/EERE-Mar-BT-STD-0013</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
[[Page 16123]]
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 battery chargers. 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.
1. Product Classes
When evaluating and establishing energy conservation standards, DOE
may establish separate standards for a group of covered products (i.e.,
establish a separate product class) if DOE determines that separate
standards are justified based on the type of energy used, or if DOE
determines that a product's capacity or other performance-related
feature justifies a different standard. (42 U.S.C. 6295(q)) In making a
determination 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. (Id.)
DOE currently defines separate energy conservation standards for
the following battery charger product classes (10 CFR 430.32(z)(1)):
Table IV.1--Current Battery Charger Product Classes
------------------------------------------------------------------------
Battery charger Maximum UEC *
Product class classification (kWh/year)
------------------------------------------------------------------------
1............................. Low-energy inductive 3.04.
battery chargers to
be used in wet
environment with
associated battery
energy of less than
or equal to 5 watt-
hours (Wh).
2............................. Low-energy, low- 0.1440 * Ebatt +
voltage battery 2.95.
chargers with
associated battery
energy of less than
100Wh, and battery
voltage of less than
4 volts (V).
3............................. Low-energy, medium- For Ebatt <
voltage battery 10Wh, 1.42; For
chargers with Ebatt >= 10Wh,
associated battery 0.0255 * Ebatt
energy of less than + 1.16.
100Wh, and battery
voltage of 4V to 10V.
4............................. Low-energy, high- 0.11 * Ebatt +
voltage battery 3.18.
chargers with
associated battery
energy of less than
100Wh, and battery
voltage of more than
10V.
5............................. Medium-energy, low- 0.0257 * Ebatt +
voltage battery 0.815.
chargers with
associated battery
energy of 100Wh to
3,000Wh, and battery
voltage of less than
20V.
6............................. Medium-energy, high- 0.0778 * Ebatt +
voltage battery 2.4.
chargers with
associated battery
energy of 100Wh to
3,000Wh, and battery
voltage of higher
than or equal to 20V.
7............................. High-energy battery 0.0502 * Ebatt +
chargers with 4.53.
associated battery
energy of more than
3,000Wh.
------------------------------------------------------------------------
* Maximum UEC is expressed as a function of representative battery
energy (Ebatt).
Battery chargers are devices that charge batteries for consumer
products, including battery chargers embedded in other consumer
products. 10 CFR 430.2. (See also 42 U.S.C. 6291(32)) A battery charger
may be wholly embedded in another consumer product, partially embedded
in another consumer product, or wholly separate from another consumer
product. Under appendix Y, only consumer wired chargers and wet
environment wireless inductive chargers designed for battery energies
of no more than 5 watt-hours are covered battery charger product
classes.
In the September 2022 Test Procedure Final Rule, DOE adopted the
proposal to expand the battery charger test procedure scope to cover
all both fixed-location wireless chargers and open-placement wireless
chargers. 87 FR 55090, 55095-55098. DOE also adopted the proposal to
establish new multi-metric test procedure for battery chargers. 87 FR
55090, 55100-55108.
DOE notes that in transitioning to the multi-metric approach where
each mode of operation is independently regulated, usage profiles are
no longer required. Currently established product classes help identify
the particular set of usage profiles that must be applied to the UEC
equation for a given battery charger model's UEC to be calculated.
Without the need for usage profiles, however, the need to maintain
currently established product classes is also greatly diminished. In
light of this situation, along with the additional wireless battery
charger test procedure coverage, DOE is proposing to remove the
existing product classes and establish new ones as follows:
Table IV.2--Proposed Battery Charger Product Class Description
------------------------------------------------------------------------
Product class Rated battery
Product class No. description energy (Ebatt)
------------------------------------------------------------------------
1a............................ Fixed-Location <=100Wh.
Wireless Battery
Chargers.
1b............................ Open-Placement All Battery
Wireless Battery Energies.
Chargers.
2a............................ Low-energy Wired 0-100Wh.
Battery Charger.
2b............................ Medium-energy Wired 100-1000Wh.
Battery Charger.
2c............................ High-energy Wired >1000Wh.
Battery Charger.
------------------------------------------------------------------------
As shown in Table IV.2, wired battery chargers are further divided
into three sub-product classes representing chargers with associated
battery energies that are either low-energy (0-100Wh), medium-energy
(100-1000Wh), or high-energy (>1000Wh) such that equations representing
potential standards for each of these sub-classes can be independently
adjusted to accommodate the unique characteristics of chargers at each
of these ranges and to achieve a desired pass rate. Similarly, wireless
chargers are divided into fixed-location wireless charger and open-
placement wireless charger because of the expanded test procedure
scope.
[[Page 16124]]
The Joint Efficiency Advocates stated support for DOE's evaluation
of both fixed-location and open-placement wireless chargers in the NOPR
stage analysis because of the significant energy savings that could be
achieved. The Joint Efficiency Advocates reiterated that wireless
chargers are significantly less efficient than wired chargers, as
stated from their response to the standards RFI published on September
16, 2020.\15\ (Joint Efficiency Advocates, No. 19 at p. 2)
---------------------------------------------------------------------------
\15\ The Joint Efficiency Advocates' response to the September
2020 RFI can be found at <a href="https://www.regulations.gov/comment/EERE-2020-BT-STD-0013-0005">https://www.regulations.gov/comment/EERE-2020-BT-STD-0013-0005</a>.
---------------------------------------------------------------------------
The CA IOUs and NEEA both supported DOE's development of standards
for wireless chargers. (CA IOUs, No. 18 at pp.2-3; NEEA No. 16 at pp.
3-4) NEEA further commented that considering active mode and standby
mode CSLs are appropriate for fixed-location wireless chargers and no
battery mode only standards for open-placement wireless chargers are
also appropriate at this time. (Id.) Both the CA IOUs and NEEA also
encouraged DOE to further analyze the standards for wireless chargers
with the CA IOUs urging DOE to work with the industry to cover the
active mode operation of open-placement wireless chargers as well.
DOE notes that DOE's battery charger standards are developed with
the test procedure in mind. Although DOE adopted both active and
standby modes test procedure for fixed-location wireless chargers,
because of the intrinsic testing repeatability and representativeness
issues, DOE did not prescribe an active mode test procedure for open-
placement wireless chargers in the September 2022 Test Procedure Final
Rule. As a result, DOE is also not considering active mode energy
conservation standards for open-placement wireless chargers in this
rulemaking.
An engineer from UL commented that a cross-class standard for
multi-port and/or multi-voltage battery chargers should be developed
because one of the battery charger products that they are testing
cannot be classified with the current battery charger product classes,
and the compliance certification management system (CCMS) reporting
template also does not address such issue. (UL, No. 11 at pp. 1-2)
DOE notes that for multi-port and/or multi-voltage battery
chargers, DOE's battery selection criteria in Table 3.2.1 from appendix
Y and appendix Y1 clearly notes that all ports and battery or
configuration of batteries with the highest individual voltage should
be used for testing, and if multiple batteries meet the criteria, then
the battery or configuration of batteries with the highest total
nameplate charge capacity at the highest individual voltage should be
used for testing. As such, the battery charger product class for such
multi-port/multi-voltage battery would be based on the highest
individual battery voltage, and the highest total battery charge
capacity.
The CA IOUs stated that DOE should reconsider its decision not to
include DC fast chargers (DCFCs) used to charge light-duty EVs and
PHEVs in DOE's battery charger standards. The CA IOUs stated that the
original decision to not regulate these products under battery charger
rulemaking scope was because DOE stated that it lacks the authority to
regulate automobiles as consumer products. However, the CA IOUs
considered that DCFCs fall within the definition of covered products in
that ``a battery charger must charge batteries for consumer products,''
and that such DCFCs are consumer products used to charge other consumer
products. The CA IOUs further commented that when EPCA passed in 1975,
it could not have foreseen how excluding automobiles from consumer
products could bar DOE from regulating DCFCs. Therefore, the CA IOUs
recommended DOE to reconsider if DCFCs should fall within the scope of
DOE's standards. (CA IOUs, No. 18 at pp. 3-5)
DOE reiterates that DOE's authority to regulate battery chargers is
limited to battery chargers that charge batteries for consumer
products. (42 U.S.C. 6291(32)) As defined by EPCA, ``consumer
products'' explicitly excludes automobiles as that term is defined in
49 U.S.C. 32901(a)(3). (42 U.S.C 6291(1)) DOE has limited information
on whether DCFCs are used to charge any consumer products other than
automobiles. As such, DOE is not proposing standards for DCFCs at this
time. However, considering the current trend towards electrification in
many industries, DOE is interested in whether DCFCs are used to charge
other consumer products, including electric vehicles other than
automobiles, such as electric motorcycles.
2. Technology Options
For technology assessment, DOE identifies technology options that
appear to be a feasible means of improving product efficiency. This
assessment provides the technical background and structure on which DOE
bases its screening and engineering analyses. The following discussion
provides an overview of the salient aspects of the technology
assessment, including issues on which DOE seeks public comment. Chapter
3 of the NOPR TSD provides detailed descriptions of the basic
construction and operation of battery chargers, followed by a
discussion of technology options to improve their efficiency and power
consumption in various modes. These technology options are also listed
in the table as follows:
Table IV.3--Battery Charger Design Options
------------------------------------------------------------------------
Technology option Description
------------------------------------------------------------------------
Slow Charger:
Improved Cores..................... Use transformer cores with low
losses.
Termination........................ Limit power provided to fully-
charged batteries.
Elimination/Limitation of Limit power provided to fully-
Maintenance Current. charged batteries.
Elimination of No-Battery Current.. Limit power provided drawn when
no battery is present.
Switched-Mode Power Supply......... Use switched-mode power
supplies instead of linear
power supplies.
Fast Charger:
Low-Power Integrated Circuits...... Use integrated circuit
controllers with minimal power
consumption.
Elimination/Limitation of Limit power provided to fully-
Maintenance Current. charged batteries.
Schottky Diodes and Synchronous Use rectifiers with low losses.
Rectification.
Elimination of No-Battery Current.. Limit power provided drawn when
no battery is present.
Phase Control to Limit Input Power. Limit input power in lower-
power modes.
[[Page 16125]]
Wide-Band Gap Semiconductors....... Use semiconductors such as
Gallium Nitride and Silicon
Carbide to achieve higher
charging efficiency.
------------------------------------------------------------------------
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 commercially viable, existing
prototypes will not be considered further.
(2) Practicability to manufacture, install, and service. If it is
determined that mass production of a technology in commercial products
and reliable installation and servicing of the technology 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. If a technology is determined to
have a significant adverse impact on the utility of the product to
subgroups of consumers, or 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) Safety of technologies. 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 technology has
proprietary protection and represents a unique pathway to achieving a
given efficiency level, it will not be considered further, due to the
potential for monopolistic concerns.
10 CFR part 430, subpart C, appendix A, sections 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
Battery charger manufacturers often use various combinations of the
DOE identified technology option, and because these options are
relatively common with little barrier to implement, DOE did not screen
out any technology option. DOE did not receive comments on its
screening analysis.
2. Remaining Technologies
DOE tentatively concludes that all of the identified technologies
listed in section IV.A.2 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:
Table IV.4--Remaining Battery Charger Design Options
------------------------------------------------------------------------
------------------------------------------------------------------------
Technology Option Description
------------------------------------------------------------------------
Slow Charger........... Improved Cores......... Use transformer cores
with low losses.
Termination............ Limit power provided
to fully-charged
batteries.
Elimination/Limitation Limit power provided
of Maintenance Current. to fully-charged
batteries.
Elimination of No- Limit power provided
Battery Current. drawn when no battery
is present.
Switched-Mode Power Use switched-mode
Supply. power supplies
instead of linear
power supplies.
Fast Charger........... Low-Power Integrated Use integrated circuit
Circuits. controllers with
minimal power
consumption.
Elimination/Limitation Limit power provided
of Maintenance Current. to fully-charged
batteries.
Schottky Diodes and Use rectifiers with
Synchronous low losses.
Rectification.
Elimination of No- Limit power provided
Battery Current. drawn when no battery
is present.
Phase Control to Limit Limit input power in
Input Power. lower-power modes.
Wide-Band Gap Use semiconductors
Semiconductors. such as Gallium
Nitride and Silicon
Carbide to achieve
higher charging
efficiency.
------------------------------------------------------------------------
DOE has initially determined that these technology options are
technologically feasible because they are being 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, unique-pathway proprietary technologies). While DOE
does not anticipate any material impact on fit, function, and utility
of the battery chargers, we request comment on potential impacts from
the proposed standard. For additional details on the analysis, 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 battery chargers. 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.
[[Page 16126]]
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 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).
To analyze the battery charger efficiency levels under the new
multi-metric approach, DOE established efficiency levels for active
charge energy and standby power separately. For off mode power
consumption, DOE notes that for chargers that offer an off mode, the
power draw is usually negligible; therefore, DOE estimated the off mode
power to be zero across all efficiency levels and did not analyze the
off mode performance for battery chargers in this NOPR.
In developing CSLs, DOE used data available in the CCD as a
representation of the wired battery charger market. The CCD currently
provides values for metrics based on the DOE test procedure at 10 CFR,
part 430, subpart B, appendix Y, which includes UEC, 24-hour charge and
maintenance mode energy (``E<INF>24</INF>''), maintenance mode power
(``P<INF>m</INF>''), standby mode power (``P<INF>nb</INF>''), and off
mode power (``P<INF>off</INF>''). However, in order to develop CSLs for
wired chargers in consideration of the metrics in the newly adopted
appendix Y1, DOE needed to further disaggregate the current
E<INF>24</INF> rated value to estimate the active charge energy
(``E<INF>a</INF>'') component. DOE achieved this by subtracting
maintenance mode energy, which equals the time in hours spent in
maintenance mode multiplied by P<INF>m</INF>, from E<INF>24</INF>.
However, the time spent in maintenance mode for each battery charger
basic model can vary significantly depending on intended application,
and DOE does not have sufficient information to derive these times on a
case-by-case basis. As such, for this NOPR, DOE continues to estimate
that every charger spends five hours in maintenance mode out of the 24-
hour charge and maintenance mode test period, as determined by section
3.3.2 of the current test procedure. As a result, DOE calculated
E<INF>a</INF> as E<INF>24</INF> minus five hours times P<INF>m</INF>.
DOE used the resultant data to define CSLs. DOE also slightly adjusted
the intercept of the resultant CSL equation for each analyzed battery
energy group as necessary so that each CSL would be a continuous
function across battery energy groups.
For fixed-location wireless battery chargers, DOE also relied on
the CCD data to estimate the relationship between the CCD derived
E<INF>a</INF> and CCD reported E<INF>batt</INF> for their active mode
CSLs. However, for the standby mode power (the sum of maintenance mode
power and no-battery mode power), or P<INF>sb</INF>, because the newly
covered fixed-location wireless chargers can have higher maintenance
mode power consumption because of different inductive power
transmitting standards, DOE developed the standby power CSLs based on
its own testing data. The multi-metric CSL results for fixed-location
wireless chargers are further discussed in sections IV.C.1.a and
IV.C.1.b below.
For open-placement wireless battery chargers, similarly, because
these are chargers covered under the expanded scope, DOE relied on its
own testing data to develop the no-battery mode only CSLs for these
chargers, with further discussion in sections IV.C.1.a and IV.C.1.b
below.
The Joint Efficiency Advocates commented that DOE could consider
uncoupling active mode and standby mode efficiency levels rather than
increasing both active mode and standby mode efficiency together at
each CSL so that alternate combinations could be analyzed to explore
the potential for additional cost-effective savings. (Joint Efficiency
Advocates, No. 19 at p. 2)
DOE notes that the electronics related to these modes of operations
are typically highly integrated and in performing teardowns, DOE was
unable to accurately establish technology options and cost that would
solely improve the energy performance in one mode of operation without
affecting another. While not universal, DOE noticed from its teardowns
that battery charger designs with improved efficiency in one more of
operation will typically also be more efficient in other modes. Lacking
accurate cost information associated with improving the performance in
each mode of operation separately, DOE chose not to decouple active
mode and standby mode efficiency levels for wired and fixed-location
wireless battery chargers in this NOPR. In taking this approach, DOE
however ensured that teardown units representing successive efficiency
levels (``ELs'') achieved both the required active mode as well as
standby performance for that EL. This ensures that the teardown cost of
representative units accurately capture the cost of attaining both the
active mode and standby performance required by each EL. The results of
these TSLs are also further discussed in chapter 5 of the TSD.
The CA IOUs also supported DOE in updating the standards for
battery chargers and expand the engineering analysis to higher-capacity
battery chargers because of advances in technology and the increasing
availability of higher-powered lithium-ion battery consumer devices on
the market. (CA IOUs, No. 18 at pp. 1-2) The CA IOUs recommended DOE to
reevaluate the bins for battery chargers as proposed in the preliminary
analysis because the CSLs allow higher active mode energy for battery
chargers with higher battery capacities within a product class. The CA
IOUs recommended DOE to develop more granular battery capacity bins or
redesign the standard algorithms to flatten the curve of allowable
maximum active mode energy, making CSLs equally stringent across
battery chargers of all battery capacities. (CA IOUs, No. 18 at p. 5)
DOE notes that DOE's active mode charge energy measures the raw
energy input into the battery charger; therefore, as battery energy
increases within each product class, the corresponding raw active
energy would increase as well. As such, ``flattening'' the active
charge energy curve within each product class
[[Page 16127]]
would increase relative stringency for those battery chargers designed
to charge higher-energy batteries from the same product class.
The Joint Trade Associations stated that several joint commenters
opposed DOE's test procedure proposal to rely on separate metrics, and
urged retention of the UEC metric in response to the test procedure
NOPR published in November 2021. The commenters also opposed DOE's
proposed approach for determining active, standby, and battery
maintenance mode energy, as well as DOE's proposal to specify that, for
chargers not shipped with adapters and where one is not recommended,
the test can be done with any EPS that is minimally compliant with
DOE's energy conservation standards. (Joint Trade Associations, No. 17
at pp. 3-4)
DOE notes that these comments pertain to the test procedure
rulemaking, and DOE has already addressed these stakeholder concerns in
the September 2022 Test Procedure Final Rule by adopting the alternate
method for measuring the active mode energy consumption of a battery
charger, ensuring that the test method for the new multiple metrics
remain largely the same as that of DOE's previous test procedure for
the UEC metric. 87 FR 55090, 55100-55108. DOE also notes that it
adopted the additional requirement to test battery chargers with an EPS
because it ensures test procedure representativeness and test result
comparability. 87 FR 55090, 55098-55099.
Delta-Q commented that DOE's efficiency level analysis of product
class 2c contains incorrect assumptions, because the test procedure
measures the energy consumption of the battery charge system as a
whole, which fails to take into account energy losses in the battery
itself and these losses vary depending on battery type and battery
chemistry. Attempting to reduce the amount of charge delivered,
particularly for lead acid batteries, would result in precipitous
reductions in battery life. (Delta-Q, No. 20 at p. 1) Delta-Q provided
an example that for a golf cart with a flooded lead acid battery of 80%
round-trip efficiency, a charger around 90% efficiency, and a total
system efficiency that meets the current DOE standard of around 70%
total efficiency; however, DOE's proposed CSL for product class 2c
would require battery charge system efficiency to be substantially
increased. In the extreme case of CSL 3, lead-acid batteries would be
effectively banned because they cannot meet the standard, even though
lead-acid batteries dominate some parts of the market. Delta-Q further
noted that the cost to replace these batteries can be ten to fifteen
times the charger cost, with the total system replacement cost
increasing in hundreds of dollars. (Delta-Q, No. 20 at p. 2) As such,
Delta-Q commented that DOE's proposed CSL efficiencies appear to be
flawed because product class 2c contains products with a variety of
battery chemistries and system efficiencies, and while most lithium ion
batteries would have system efficiencies passing at CSL 2, flooded
lead-acid batteries would struggle to pass CSL 1; in effect, 100% of
lead-acid battery charge systems would fail. (Id.)
DOE notes that the battery charger test procedure was designed to
measure the overall system efficiency. As a result, the energy losses
in the batteries would also be accounted for as wasted energy or ``non-
useful energy''. DOE understands that for some manufacturers, they do
not have direct control over the type of battery consumers use with
their chargers; however, for each battery charger product class and
each comparable battery energy range, these chargers would still be
regulated along with other similar types of chargers with comparable
battery characteristics. DOE's standards have been, and will be,
developed based on the representative units from a variety of end use
product types and battery energy ranges. As such, DOE's battery charger
standards do account for the battery energy losses and do not
negatively impact battery charger manufacturers. DOE further notes that
CSL 0 for active mode and standby mode were developed to be an
approximate translation of the current DOE battery charger UEC
standard, with higher CSLs developed based on CCD reported battery
charger performance trends and/or DOE's own testing results. Currently
presented CSLs are only for standards development process; any standard
DOE decides to adopt later in the final rule stage will be verified to
be cost effective while having meaningful energy savings without undue
burden. To account for Delta-Q's concern, DOE has slightly relaxed
high-energy chargers' higher CSL levels in this NOPR, and from DOE's
internal testing and modeling, DOE was able to confirm that even CSL 3
was attainable by some lead-acid battery chargers.
Delta-Q commented that the present single, unified metric of UEC
would provide more flexibility in reducing overall energy consumption
while still delivering on customer features and cost targets, and that
separate standards for separate metrics will reduce design flexibility
and raise the cost of compliance. (Delta-Q, No. 20 at p. 2) Delta-Q
further commented that the proposed baseline standby mode power
requirements are already restrictive, resulting in targets that are
very challenging to meet, which can limit the maximum charge speed or
the minimum battery size. This is particularly challenging for generic
and standalone battery chargers such as those manufactured by Delta-Q
and used by many OEMs. (Delta-Q, No. 20 at pp. 2-3) Delta-Q commented
that standby mode power provides a variety of customer-required
functions, such as status display, signal communication, or maintain
state of charge, and therefore does not necessarily represent wasted
energy. Delta-Q further stated that if efficiency regulations precluded
drawing from AC mains in maintenance mode power, battery chargers would
require power draw from the DC battery, reducing battery readiness and
runtime. (Id.)
DOE recognizes that the current UEC metric may provide design
flexibility for manufacturers; however, it risks being increasingly
unrepresentative without frequent and continuous updates to the usage
profiles. If DOE were to constantly update the usage profiles,
manufacturers would also need to repeatedly recalculate the
representative UEC and recertify their products, which would add undue
burden for manufacturers. Although DOE's adopted multi-metric testing
approach does not provide the same level of freedom for battery charger
design in all modes of operation when compared to the current
integrated UEC approach, it would still provide design flexibility in
standby mode operation by allowing manufacturers to prioritize either
maintenance power or no-battery power, which accounts for the majority
of battery charger operation time. DOE reiterates that the CSLs
presented in the preliminary analysis were only for DOE to present the
general approach for developing the standards, and for stakeholders to
get an early chance at contributing to DOE's standards rulemaking
process. As such, the CSLs presented in the preliminary analysis are
not final results. Any standard adopted by DOE in the final rule must
be economically justifiable and technologically feasible, and will be
required to demonstrate that they are verified to be cost effective
while having meaningful energy savings without undue burden. In
response to Delta-Q's comment that the baseline standard levels
presented in the preliminary analysis are already restrictive, DOE
notes that these were either translated from the current UEC standard,
or developed from DOE's own testing data
[[Page 16128]]
representing some of the most energy consumptive products in the
market; demonstrating that the technology required to achieve the
currently prescribed standards at the baseline level are readily
available and not restrictive.
a. Baseline Energy Use
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 (e.g., capacity, physical size).
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.
Consistent with the baseline efficiency levels analyzed from the
preliminary analysis, for this NOPR, DOE's baseline multi-metric
efficiency levels for wired battery chargers are approximated from the
current UEC standards along with reference to the original California
Energy Commission's (``CEC'') battery charger multi-metric standard.
Because the current UEC standard was adopted based on approximated CEC
standards for most of the original product classes except product
classes 5 and 6, which were more efficient than CEC's, DOE's current
standard can be approximately ``translated'' back to the CEC's
standard, especially on the lower end of the battery energy spectrum
(for battery chargers with battery energy less than 100Wh). DOE further
assumed that most chargers on the CCD are only single port chargers and
applied the CEC active charge energy standard to the current CCD
battery energy levels to get the maximum charge and maintenance energy,
and then subtracted five hours of maintenance mode power to approximate
the active charge energy for every single wired battery charger entry.
DOE did not receive any opposing comments to this approach.
DOE further notes that the September 2022 Test Procedure Final Rule
adopted the requirement that for all battery chargers that would need
an external power supply for operation, they would need to be tested
with a minimally compliant EPS. 87 FR 55090, 55098-55099. DOE
anticipated that a proposed standard would also be affected by this
change. As such, DOE analyzed the CCD reported battery charger basic
models and manually removed entries with negligible power draw in no-
battery mode so that the remaining entries would likely be tested with
an EPS or with input power measured directly at the wall. Although this
may unintentionally remove some entries with very efficient no-battery
mode design, it would ensure that all the remaining models are indeed
tested with an appropriate power supply or have the conversion losses
captured. DOE then applied a linear regression to the remaining CCD
entries to establish a relationship between battery energy and the
approximated CEC standard described in the previous paragraph. DOE
repeated the same steps for standby mode power and battery energy to
establish the standby mode baseline efficiency level for wired battery
chargers. Each CSL would contain both the independent active mode
efficiency level, and the independent standby mode efficiency level.
For fixed-location wireless chargers in active mode, DOE also
repeated similar steps to establish the active energy CSL based off of
CCD data, but assumed that the slopes across CSL 0 to CSL 3 are the
same, which equal to the slope of the active charge energy vs. battery
energy from the wet-environment wireless charger CCD data. DOE then
adjusted the intercept so that all currently reported wet-environment
wireless chargers pass the baseline standard level.
For the baseline efficiency level for standby mode power of fixed-
location wireless chargers, DOE relied on the worst average 30% standby
mode power of the fixed-location wireless chargers that passed DOE's
internal testing. Similarly for open-placement wireless chargers'
baseline no-battery mode power level, DOE also relied on the worst no-
battery mode power of the wireless chargers that passed DOE's internal
testing.
Table IV.5 below shows the baseline efficiency level for all wired
and wireless battery chargers.
Table IV.5--Baseline Efficiency Level or CSL 0 for Battery Chargers
----------------------------------------------------------------------------------------------------------------
CSL 0: Approximated current standards
-----------------------------------------------------------------------------------------------------------------
Standby mode
Product class Battery energy (Ebatt) Active mode energy power (Psb = Pm + Off mode power
(Ea) Pnb) (Poff)
----------------------------------------------------------------------------------------------------------------
1a............................. <=100Wh................. 1.718 * Ebatt + 1.7.............. 0
17.3.
1b............................. N/A..................... N/A............... 1.4 (Pnb only)... 0
2a............................. <=100Wh................. 1.656 * Ebatt + 0.0021 * Ebatt + 0
10.5. 1.
2b............................. 100-1000................ 1.564 * Ebatt +
19.661.
2c............................. >1000................... 1.549 * Ebatt +
34.361.
----------------------------------------------------------------------------------------------------------------
b. Higher Efficiency Levels
As part of DOE's analysis, the maximum available efficiency level
is 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.
Again, DOE applied linear regression models to different portions
of the CCD to characterize three different performance levels of the
reported wired battery charger basic models. For active mode energy of
high-energy battery chargers in product class 2c, DOE held the
intercept constant but adjusted the slope to allow slightly relaxed
higher CSLs when compared to the preliminary analysis and to retain the
continuous CSL for each level.
For active mode energy of fixed-location wireless chargers, DOE
held the slopes the same across efficiency levels but adjusted the
intercepts to achieve similar pass rates when compared to the wired
battery charger pass rates at each corresponding CSLs. DOE further
finetuned the intercepts by aligning them with DOE's internal testing
results.
Similar to how DOE developed the baseline standard levels for
standby mode power of fixed-location wireless chargers and no-battery
mode power for open-placement wireless chargers, DOE relied on its own
testing data to develop the higher efficiency levels as well. For
P<INF>sb</INF> of fixed-location wireless chargers, CSL 2 represents
the approximated average value of DOE's tested samples,
[[Page 16129]]
whereas CSL 3 represents the most efficient 25-30% of the samples. CSL
1 P<INF>sb</INF> of fixed-location wireless chargers was set to
approximately be the average of CSL 0 and CSL 2 levels. For open-
placement wireless charger no-battery mode CSLs, DOE approximated CSL 2
to be the average no-battery mode power of all the units tested by DOE.
DOE then set CSL 1 to be the average of the bottom third of tested
units and CSL 3 to represent open-placement wireless chargers that do
not consume any power in no-battery mode from their wireless charging
components, but with all power draw coming from the power supply just
meeting DOE's multi-voltage EPS maximum no-load power of 0.3W, as
prescribed in 10 CFR 430.32(w)(1)(ii).
DOE analyzed these three higher battery charger efficiency levels,
identified design options, and obtained incremental cost data at each
of these levels. Table IV.6 below shows the efficiency levels analyzed
for this NOPR analysis.
Table IV.6--Higher Efficiency Levels for Battery Chargers
----------------------------------------------------------------------------------------------------------------
Standby mode
Product class Battery energy (Ebatt) Active mode power (Psb = Pm Off mode power
energy Ea + Pnb) Poff
----------------------------------------------------------------------------------------------------------------
CSL 1: Intermediate (~70% Pass Rate)
----------------------------------------------------------------------------------------------------------------
1a............................. <=100Wh.................. 1.718 * Ebatt + 1.5.............. 0
8.5.
1b............................. N/A...................... N/A.............. 0.8 (Pnb only)... 0
2a............................. <=100Wh.................. 1.390 * Ebatt + 0.00154 * Ebatt + 0
7.5. 0.65.
2b............................. 100-1000................. 1.418 * Ebatt +
4.692.
2c............................. >1000.................... 1.388 * Ebatt +
34.361.
----------------------------------------------------------------------------------------------------------------
CSL 2: Above Intermediate (~40% Pass Rate)
----------------------------------------------------------------------------------------------------------------
1a............................. <=100Wh.................. 1.718 * Ebatt + 1.25............. 0
5.54.
1b............................. N/A...................... N/A.............. 0.5 (Pnb only)... 0
2a............................. <=100Wh.................. 1.222 * Ebatt + 0.00098 * Ebatt + 0
4.980. 0.4.
2b............................. 100-1000................. 1.367 * Ebatt + -
9.560.
2c............................. >1000.................... 1.323 * Ebatt +
34.361.
----------------------------------------------------------------------------------------------------------------
CSL 3: Max-Tech (~10% Pass Rate)
----------------------------------------------------------------------------------------------------------------
1a............................. <=100Wh.................. 1.718 * Ebatt + 2 0.65............. 0
1b............................. N/A...................... N/A.............. 0.3 (Pnb only)... 0
2a............................. <=100Wh.................. 1.053 * Ebatt + 0.0005 * Ebatt + 0
4.980. 0.25.
2b............................. 100-1000................. 1.316 * Ebatt + -
21.292.
2c............................. >1000.................... 1.260 * Ebatt +
34.361.
----------------------------------------------------------------------------------------------------------------
For wired battery chargers, the three analyzed higher efficiency
levels (i.e., ELs) correspond to the top 70%, 40%, and 10% of battery
chargers in the market in terms of their active mode energy and standby
mode power consumption. For ease of reference, DOE refers to the
efficiency level that represents the top 70% of the market as
``Intermediate'', the top 40% of the market as ``Above Intermediate''
and those that represent the top 10% of the market as ``Max-Tech,''
which typically also represents the lowest active mode energy and
standby mode power consumption commercially attainable using current
technology. Fixed-location wireless chargers share similar market
distribution as wired chargers for these higher CSLs from DOE's
estimates. However, for open-placement wireless chargers, DOE's
internal testing data shows higher pass rates for higher efficiency
levels, especially at Max-Tech. DOE notes that although DOE tried to
test a wide variety of the wireless chargers covered under the expanded
scope, there are still hundreds of wireless charger models in the
market that have various no-battery mode efficiency. As such, the
actual market efficiency distribution for open-placement wireless
chargers in higher CSLs can be different than DOE's current estimates;
additionally, because the CSL differences of the no-battery mode power
draw is relatively small, the overall energy use analysis based on
these market distribution estimates should still yield meaningful and
reliable results.
DOE requests feedback on DOE's approach of establishing these
higher efficiency CSLs and welcomes stakeholders to submit any data on
the actual market distribution of these higher efficiency CSLs.
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 battery
charger 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 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 bill of materials 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 all three
methods (physical teardowns, catalog teardowns, and price surveys) of
analysis to determine manufacturing cost as it
[[Page 16130]]
relates to the efficiency of a battery charger. Units for teardown were
selected from the CCD based on reported energy values. Several units
were selected as representative units for each CSL. In addition to
units from the CCD, DOE purchased various open-placement and fixed-
location wireless chargers to study their design, cost, and
performance. DOE received additional cost data from manufacturer
interviews and stakeholder feedback, which was incorporated in the cost
model generation.
After testing, physical teardowns of CCD units were performed using
internal tools. Price survey data was collected in manufacturer
interviews and in some stakeholder feedback for units at each CSL.
To generate the cost model, cost data from teardowns were combined
with price survey data to generate cost/efficiency relationships at
each battery energy group of interest. Equations for cost as a function
of relative active mode energy and standby mode power were then created
using an exponential fit to the data at each battery energy level. The
resulting manufacturer production costs (MPCs) were then generated for
each efficiency level using the fit equations.
The Joint Efficiency Advocates expressed concerned that only four
units representing CSL 0 and CSL 3 at two battery energy levels were
used in the preliminary engineering analysis to estimate costs for all
other wired charger CSLs and battery energy combinations. The Joint
Efficiency Advocates commented that better accuracy would be obtained
through additional testing and teardowns for all product classes, or
through a design option approach for estimating costs for all wired
chargers, or a combination of both. (Joint Efficiency Advocates, No. 19
at p. 2)
The CA IOUs further suggested DOE conduct additional teardowns of
larger battery chargers in product classes 2a, 2b, and 2c for common
product types (e.g., notebooks, cordless vacuums, power tools,
landscaping equipment, ride-on electric vehicles, electric scooters,
and golf carts) because larger battery chargers for such devices may
have different efficiency profiles than smaller ones due to higher
quality components or the incorporation of high-efficiency
technologies, such as wide-band-gap semiconductors. The CA IOUs stated
their expectation that larger battery chargers may not show a linear
trend between active energy and battery energy. (CA IOUs, No. 18 at p.
2)
Similarly, NEEA commented that DOE's methodology of conducting
teardowns of four chargers in product class 2a representing only the
lowest (baseline) and highest (CSL 3) of the four CSLs resulted in
insufficient reliable data for class 2a CSL 1 and 2. NEEA's own
research suggested that design options to enable CSL 1 and CSL 2
efficiencies are likely quite different than those used to achieve the
highest efficiency level (CSL 3), creating inaccuracies in DOE's
current estimates of the incremental cost for these middle levels. NEEA
further commented that the reliance on four charger teardowns with
battery energies less than 20 Wh (product class 2a) to 35 different
battery charger applications with battery energies up to two orders of
magnitude higher (2000 Wh) has yielded insufficient data to develop
incremental cost information for product classes 2b and 2c because
these higher power battery chargers likely use different semiconductor
chipsets and/or can be impacted by production volume-related cost
effects from other similar power electronics applications. (NEEA, No.
16 at pp. 1-2) NEEA commented that incremental battery charger costs
presented for product class 2b ($2.59 to $8.73) are high relative to
DOE EPS cost analysis, indicating that battery charger incremental
costs are likely to be overestimated for these middle CSLs (CSLs 1 and
2). (NEEA, No. 16 at p. 2) NEEA stated that DOE should make three
changes to more accurately measure the energy consumption of battery
chargers: (1) add an alternative approach such as design option
approach to teardown data already collected for class 2a CSL 1 and CSL
2; (2) conduct teardowns and/or utilize design option approaches to
determine costs for product classes 2b and 2c; and (3) consider costs
that maintain charge rate (slow or fast), given that slower chargers
can be less costly due to a lower power output level. NEEA commented
that if an expanded engineering analysis reveals that current CSL
levels are not cost-effective in wired charges, NEEA recommends that
DOE consider alternative combinations and standby and active mode that
are more likely to be cost-effective, and adding an additional CSL
level between CSL 0 and CSL 1. (NEEA, No. 16 at pp. 2-3)
DOE acknowledges that better representativeness can be achieved
through additional testing and teardowns. Therefore, for the NOPR
analysis, DOE has expanded the representative unit size significantly
to cover more battery energy ranges and different end product types.
DOE has also conducted various manufacturer interviews to get more
direct design and cost information from stakeholders to calibrate DOE's
internal teardown results, which improves the accuracy and
representativeness of DOE's battery charger cost-efficiency
relationship. Details of how DOE updated its cost analysis can be found
in chapter 5 of the NOPR TSD.
To account for manufacturers' non-production costs and profit
margin, DOE applies a multiplier (the manufacturer markup) to the MPC.
The resulting manufacturer selling price (``MSP'') is the price at
which the manufacturer distributes a unit into commerce. DOE,
throughout this NOPR analysis, is using the average manufacturer markup
presented in the June 2016 final rule. This markup was determined based
on information collected during the manufacturer interviews preceding
that rulemaking. More detail on the manufacturer markup is given in
section IV.D of this document.
3. Cost-Efficiency Results
The results of the engineering analysis are presented as cost-
efficiency data for each product class by efficiency levels. The cost-
efficiency curves are described by the efficiency levels DOE analyzed
and the increase in MPC required to improve a baseline-efficiency
product to each of the considered efficiency levels. DOE recognizes
that costs of battery chargers vary according to the energy of the
battery it is intended to charge. DOE analyzed costs at various battery
energies from different battery energy groups for each CSL as shown
below. These representative battery energies were selected based on
areas of significant market density, as indicated by entries in the
CCD. They also span a wide range of battery energy groups for which the
CSL equations were defined. For battery energy groups for which DOE
lacks direct teardown costs, DOE extrapolated these costs from
representative units that DOE has physically torn down and calibrated
DOE's extrapolation with price information DOE acquired from
manufacturer interviews.
Tables and plots with MPC results, as well as extrapolation methods
used both within and across each product class, are presented below as
well as in greater detail in chapter 5 of the NOPR TSD.
DOE requests stakeholder feedbacks on these analyzed incremental
costs as well as any topic covered in chapter 5 of the NOPR TSD. DOE
also welcomes stakeholders to submit their own cost-efficiency results,
should there be any.
[[Page 16131]]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Incremental MPC ($)
Product class Product class name Battery energy ---------------------------------------------------------------
(Wh) Base CSL 1 CSL 2 CSL 3
--------------------------------------------------------------------------------------------------------------------------------------------------------
1a..................................... Fixed-Location Wireless Charger 12 0.00 0.67 1.51 3.52
1b..................................... Open-Placement Wireless Charger N/A 0.00 0.53 1.49 2.14
2a..................................... Low-Energy Wired Battery 5 0.00 0.23 0.63 0.75
Charger (<=100Wh). 12 0.00 0.40 0.77 1.59
25 0.00 0.55 1.00 1.85
75 0.00 0.93 1.60 2.67
2b..................................... Medium-Energy Wired Battery 200 0.00 1.58 2.45 3.24
Charger (100-1000Wh). 420 0.00 3.35 5.20 6.86
2c..................................... High-Energy Wired Battery 2000 0.00 3.35 5.20 6.86
Charger (>1000Wh).
--------------------------------------------------------------------------------------------------------------------------------------------------------
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 MSP estimates derived in the
engineering analysis to consumer prices, which are then used in the LCC
and PBP analysis and in the manufacturer impact analysis. At each step
in the distribution channel, companies mark up the price of the product
to cover business costs and profit margin.
For battery chargers, the main parties in the distribution chain
are battery charger manufacturers, end-use product original equipment
manufacturers, consumer product retailers, and consumers. 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
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 profit before and after new or amended standards.\16\
---------------------------------------------------------------------------
\16\ 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.
---------------------------------------------------------------------------
In the March 2022 Preliminary Analysis, DOE used the same baseline
and incremental markups that were used in the June 2016 Final Rule.\17\
DOE did not receive any comments regarding the markups or distribution
channels in the March 2022 Preliminary Analysis, therefore DOE used the
same markups in this NOPR.
---------------------------------------------------------------------------
\17\ See Chapter 6 of the 2016 Final Rule Technical Support
Document for Battery Chargers. (Available at: <a href="http://www.regulations.gov/document/EERE-2008-BT-STD-0005-0257">www.regulations.gov/document/EERE-2008-BT-STD-0005-0257</a>) (last accessed Sept. 12, 2022).
See also Chapter 6 of the 2022 Preliminary Analysis Technical
Support Document for Battery Chargers. (Available at:
<a href="http://www.regulations.gov/document/EERE-2020-BT-STD-0013-0009">www.regulations.gov/document/EERE-2020-BT-STD-0013-0009</a>) (last
accessed Sept. 12, 2022).
---------------------------------------------------------------------------
Chapter 6 of the NOPR TSD provides details on DOE's development of
markups for battery chargers.
DOE requests comment on the estimated increased manufacturer
markups and incremental MSPs that result from the analyzed energy
conservation standards from the NOPR engineering analysis.
E. Energy Use Analysis
The purpose of the energy use analysis is to determine the annual
energy consumption of battery chargers at different efficiencies in
representative U.S. single-family homes, multi-family residences, and
commercial buildings, and to assess the energy savings potential of
increased battery charger efficiency. The energy use analysis estimates
the range of energy use of battery chargers in the field (i.e., as they
are actually used by consumers). The energy use analysis provides the
basis for other analyses DOE performs, particularly assessments of the
energy savings and the savings in consumer operating costs that could
result from adoption of amended or new standards.
In the March 2022 Preliminary Analysis, DOE used usage profiles
that were developed in the June 2016 Final Rule, along with efficiency
data at different load conditions, to calculate the UECs for battery
chargers for a variety of applications.\18\ Usage profiles are
estimates of the average time a device spends in each mode of
operation. In the February 2023 NOPR for external power supplies, DOE
updated some of the usage profiles for certain applications based on
stakeholder comments. 88 FR 7284. For this analysis, DOE aligned the
battery charger usage profiles for these applications with the EPS
usage profiles for consistency.
---------------------------------------------------------------------------
\18\ See appendix 7A of the 2016 Final Rule Technical Support
Document for Battery Chargers. (Available at: <a href="http://www.regulations.gov/document/EERE-2008-BT-STD-0005-0257">www.regulations.gov/document/EERE-2008-BT-STD-0005-0257</a>) (last accessed Sept. 12, 2022).
See also appendix 7A of the 2022 Preliminary Analysis Technical
Support Document for Battery Chargers. (Available at:
<a href="http://www.regulations.gov/document/EERE-2020-BT-STD-0013-0009">www.regulations.gov/document/EERE-2020-BT-STD-0013-0009</a>) (last
accessed Sept. 12, 2022).
---------------------------------------------------------------------------
Chapter 7 of the NOPR TSD provides details on DOE's energy use
analysis for battery chargers.
F. Life-Cycle Cost and Payback Period Analysis
DOE conducted LCC and PBP analyses to evaluate the economic impacts
on individual consumers of potential energy conservation standards for
battery chargers. The effect of new or amended energy conservation
standards on individual consumers usually involves a reduction in
operating cost and an increase in purchase cost. DOE used the following
two metrics to measure consumer impacts:
[ballot] The LCC is the total consumer expense of an appliance or
product over the life of that product, consisting of total installed
cost (manufacturer selling price, distribution chain markups, sales
tax, and installation costs) plus operating costs (expenses for energy
use, maintenance, and repair). To compute the operating costs, DOE
discounts future operating costs to the time of purchase and sums them
over the lifetime of the product.
[ballot] 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
at higher efficiency levels by the change in annual operating cost for
the year that amended or new standards are assumed to take effect.
For any given efficiency level, DOE measures the change in LCC
relative to the LCC in the no-new-standards case, which reflects the
estimated efficiency distribution of battery chargers in the absence of
new or amended energy conservation standards. In contrast, the PBP for
a given efficiency level is
[[Page 16132]]
measured relative to the baseline product.
For each considered efficiency level in each product class, DOE
calculated the LCC and PBP for a nationally representative set of
housing units and commercial buildings. DOE developed household samples
from the 2015 Residential Energy Consumption Survey \19\ (RECS 2015)
and the 2018 Commercial Building Energy Consumption Survey \20\ (CBECS
2018). For each sample household, DOE determined the energy consumption
for the battery chargers and the appropriate energy price. By
developing a representative sample of households, the analysis captured
the variability in energy consumption and energy prices associated with
the use of battery chargers.
---------------------------------------------------------------------------
\19\ <a href="http://www.eia.gov/consumption/residential/data/2015/">www.eia.gov/consumption/residential/data/2015/</a> (last
accessed Sept. 12, 2022). EIA is currently working on RECS 2020, and
the entire RECS 2020 microdata are expected to be fully released in
early 2023. Until that time, RECS 2015 remains the most recent full
data release. For future analyses, DOE plans to consider using the
complete RECS 2020 microdata when available.
\20\ <a href="http://www.eia.gov/consumption/commercial/">www.eia.gov/consumption/commercial/</a> (last accessed Sept.
12, 2022).
---------------------------------------------------------------------------
Inputs to the calculation of total installed cost include the cost
of the product--which includes MPCs, manufacturer markups, retailer and
distributor markups, and sales taxes--and installation costs. Inputs to
the calculation of operating expenses include annual energy
consumption, energy prices and price projections, repair and
maintenance costs, product lifetimes, and discount rates. DOE created
distributions of values for product lifetime, discount rates, and sales
taxes, with probabilities attached to each value, to account for their
uncertainty and variability.
The computer model DOE uses to calculate the LCC relies on a Monte
Carlo simulation to incorporate uncertainty and variability into the
analysis. The Monte Carlo simulations randomly sample input values from
the probability distributions and battery chargers' user samples. For
this rulemaking, the Monte Carlo approach is implemented in MS Excel.
The model calculated the LCC for products at each efficiency level for
10,000 housing units and commercial buildings per simulation run. The
analytical results include a distribution of 10,000 data points showing
the range of LCC savings for a given efficiency level relative to the
no-new-standards case efficiency distribution. In performing an
iteration of the Monte Carlo simulation for a given consumer, product
efficiency is chosen based on its probability. If the chosen product
efficiency is greater than or equal to the efficiency of the standard
level under consideration, the LCC calculation reveals that a consumer
is not impacted by the standard level. By accounting for consumers who
already purchase more-efficient products, DOE avoids overstating the
potential benefits from increasing product efficiency.
DOE calculated the LCC and PBP for all consumers of battery
chargers as if each were to purchase a new product in the expected year
of required compliance with new or amended standards. New and amended
standards would apply to battery chargers manufactured 2 years after
the date on which any new or amended standard is published. (42 U.S.C.
6295(u)) At this time, DOE estimates publication of a final rule in
late 2024, therefore, for purposes of this analysis, DOE used 2027 as
the first year of compliance with any amended standards for EPSs.
Table IV.7 summarizes the approach and data DOE used to derive
inputs to the LCC and PBP calculations. The subsections that follow
provide further discussion. Details of the spreadsheet model, and of
all the inputs to the LCC and PBP analyses, are contained in chapter 8
of the NOPR TSD and its appendices.
Table IV.7--Summary of Inputs and Methods for the LCC and PBP Analysis *
------------------------------------------------------------------------
Inputs Source/method
------------------------------------------------------------------------
Product Cost........................... Derived by multiplying MPCs by
battery charger manufacturer
and appliance manufacturer
markups and sales tax, as
appropriate. Used historical
Product Price Index (PPI) data
for semiconductors to derive a
price scaling index to project
product costs.
Installation Costs..................... No installation costs.
Annual Energy Use...................... The total annual energy use
calculated using product
efficiency and operating
hours.
Variability: Based on the 2015
RECS and 2018 CBECS.
Energy Prices.......................... Electricity: EIA data--2021.
Variability: Census Division.
Energy Price Trends.................... Based on AEO2022 price
projections.
Repair and Maintenance Costs........... No repair or maintenance costs
were considered.
Product Lifetime....................... Average: 3 to 10 years.
Discount Rates......................... Approach involves identifying
all possible debt or asset
classes that might be used to
purchase the considered
appliances, or might be
affected indirectly. Primary
data source was the Federal
Reserve Board's Survey of
Consumer Finances.
Compliance Date........................ 2027.
------------------------------------------------------------------------
* References for the data sources mentioned in this table are provided
in the sections following the table or in chapter 8 of the NOPR TSD.
1. Product Cost
To calculate consumer product costs, DOE multiplied the MPCs
developed in the engineering analysis by the markups described
previously (along with sales taxes). DOE used different markups for
baseline products and higher-efficiency products because DOE applies an
incremental markup to the increase in MSP associated with higher-
efficiency products.
In the March 2022 Preliminary Analysis, DOE did not use any price
trend.\21\ In response, the CA IOUs commented that based on American
Council for an Energy-Efficient Economy information and price
comparisons, DOE has historically overestimated its forecasts of the
incremental cost for products subject to standards due to energy
conservation policies that may accelerate the decline of appliance
costs due to increased production and innovation. (CA IOUs, No. 18 at
pp. 5-6) The CA IOUs further commented that battery chargers are
increasingly employing gallium nitride (GaN) semiconductors as a
primary cost component, and GaN semiconductor costs are expected to
decrease substantially; in addition, GaN topologies require fewer
components and heat dissipation needs, causing system-level costs to
decrease. For these reasons, DOE should include price learning in its
analysis of battery chargers and develop criteria for applying price
learning in all cases involving products with rapidly expanding sales
volumes or based on components or materials that are likely
[[Page 16133]]
to experience declining costs. (CA IOUs, No. 18 at pp. 6-7)
---------------------------------------------------------------------------
\21\ See Chapters 8 and 10 of the 2022 Preliminary Analysis
Technical Support Document for Battery Chargers. (Available at:
<a href="http://www.regulations.gov/document/EERE-2020-BT-STD-0013-0009">www.regulations.gov/document/EERE-2020-BT-STD-0013-0009</a>) (last
accessed Sept. 12, 2022).
---------------------------------------------------------------------------
The Joint Efficiency Advocates stated that with price learning not
addressed in the preliminary analysis, costs to achieve higher
efficiency levels over the analysis period could be overestimated;
learning rates associated with semiconductors are especially important
because improved semiconductors are a key technology option for
reaching higher efficiency levels. (Joint Efficiency Advocates, No. 19
at p. 2)
NEEA also commented that DOE should incorporate manufacturer price
learning and leverage general semiconductor price data into its
analysis of life-cycle cost and payback period for battery chargers.
(NEEA, No. 16 at p. 3)
DOE agrees with the commenters that costs for electronic components
are likely to change during the analysis period. In this NOPR, DOE has
incorporated a price trend based on the PPI for semiconductors,\22\
with an estimated annual deflated price decline of approximately 6
percent per year from 1967 through 2021. DOE applied this price trend
to the proportion of battery charger costs attributable to
semiconductors, which is estimated at 90 percent of incremental costs.
---------------------------------------------------------------------------
\22\ Producer Price Index: Semiconductors and Related
Manufacturing. Series ID: PCU334413334413. (Available at:
<a href="http://beta.bls.gov/dataViewer/view/timeseries/PCU334413334413">beta.bls.gov/dataViewer/view/timeseries/PCU334413334413</a>) (last
accessed Sept. 12, 2022).
---------------------------------------------------------------------------
2. Annual Energy Consumption
For each sampled household or commercial business, DOE determined
the energy consumption for a battery charger at different efficiency
levels using the approach described previously in section IV.E of this
document.
3. Energy Prices
Because marginal electricity price more accurately captures the
incremental savings associated with a change in energy use from higher
efficiency, it provides a better representation of incremental change
in consumer costs than average electricity prices. Therefore, DOE
applied average electricity prices for the energy use of the product
purchased in the no-new-standards case, and marginal electricity prices
for the incremental change in energy use associated with the other
efficiency levels considered.
For the NOPR, DOE derived average monthly residential and
commercial marginal electricity prices for the various regions using
2021 data from EIA.\23\
---------------------------------------------------------------------------
\23\ U.S. Department of Energy-Energy Information
Administration, Form EIA-861M (formerly EIA-826) Database Monthly
Electric Utility Sales and Revenue Data (1990-2020). (Available at:
<a href="http://www.eia.gov/electricity/data/eia861m/">www.eia.gov/electricity/data/eia861m/</a>) (last accessed Sept. 12,
2022).
---------------------------------------------------------------------------
To estimate energy prices in future years, DOE multiplied the 2021
energy prices by the projection of annual average price changes for
each of the nine census divisions from the Reference case in AEO2022,
which has an end year of 2050.\24\ To estimate price trends after 2050,
DOE used the average annual rate of change in prices from 2023 through
2050.
---------------------------------------------------------------------------
\24\ EIA. Annual Energy Outlook 2022 with Projections to 2050.
Washington, DC. (Available at <a href="http://www.eia.gov/forecasts/aeo/">www.eia.gov/forecasts/aeo/</a>) (last
accessed Sept. 12, 2022).
---------------------------------------------------------------------------
See chapter 8 of the NOPR TSD for details.
4. Product Lifetime
In the March 2022 Preliminary Analysis, DOE based the battery
charger lifetime on the lifetime of the application for which it is
associated.\25\ In the February 2023 NOPR for external power supplies,
DOE increased the lifetime for several applications based on
stakeholder comments. 88 FR 7284. For this analysis, DOE aligned the
application lifetimes (and thus battery charger lifetimes) for these
applications with the EPS lifetime estimates for consistency.
---------------------------------------------------------------------------
\25\ See Chapter 8 of the 2022 Preliminary Analysis Technical
Support Document for Battery Chargers. (Available at:
<a href="http://www.regulations.gov/document/EERE-2020-BT-STD-0013-0009">www.regulations.gov/document/EERE-2020-BT-STD-0013-0009</a>) (last
accessed Sept. 12, 2022).
---------------------------------------------------------------------------
5. Discount Rates
In the calculation of LCC, DOE applies discount rates appropriate
to households and commercial buildings to estimate the present value of
future operating cost savings. DOE estimated a distribution of discount
rates for battery chargers based on the opportunity cost of consumer
funds.
For residential households, DOE applies weighted average discount
rates calculated from consumer debt and asset data, rather than
marginal or implicit discount rates.\26\ The LCC analysis estimates net
present value over the lifetime of the product, so the appropriate
discount rate will reflect the general opportunity cost of household
funds, taking this time scale into account. Given the long time horizon
modeled in the LCC analysis, the application of a marginal interest
rate associated with an initial source of funds is inaccurate.
Regardless of the method of purchase, consumers are expected to
continue to rebalance their debt and asset holdings over the LCC
analysis period, based on the restrictions consumers face in their debt
payment requirements and the relative size of the interest rates
available on debts and assets. DOE estimates the aggregate impact of
this rebalancing using the historical distribution of debts and assets.
---------------------------------------------------------------------------
\26\ The implicit discount rate is inferred from a consumer
purchase decision between two otherwise identical goods with
different first cost and operating cost. It is the interest rate
that equates the increment of first cost to the difference in net
present value of lifetime operating cost, incorporating the
influence of several factors: transaction costs; risk premiums and
response to uncertainty; time preferences; interest rates at which a
consumer is able to borrow or lend. The implicit discount rate is
not appropriate for the LCC analysis because it reflects a range of
factors that influence consumer purchase decisions, rather than the
opportunity cost of the funds that are used in purchases.
---------------------------------------------------------------------------
To establish residential discount rates for the LCC analysis, DOE
identified all relevant household debt or asset classes in order to
approximate a consumer's opportunity cost of funds related to appliance
energy cost savings. It estimated the average percentage shares of the
various types of debt and equity by household income group using data
from the Federal Reserve Board's Survey of Consumer Finances \27\
(``SCF'') for 1995, 1998, 2001, 2004, 2007, 2010, and 2013. Using the
SCF and other sources, DOE developed a distribution of rates for each
type of debt and asset by income group to represent the rates that may
apply in the year in which amended standards would take effect. DOE
assigned each sample household a specific discount rate drawn from one
of the distributions. The average rate across all types of household
debt and equity and income groups, weighted by the shares of each type,
is 4.1% percent.
---------------------------------------------------------------------------
\27\ Board of Governors of the Federal Reserve System. Survey of
Consumer Finances. 1995, 1998, 2001, 2004, 2007, 2010, and 2013.
(Available at: <a href="http://www.federalreserve.gov/econres/scfindex.htm">www.federalreserve.gov/econres/scfindex.htm</a>) (last
accessed Sept. 12, 2022).
---------------------------------------------------------------------------
For commercial buildings, DOE derived the discount rates for the
LCC analysis by estimating the cost of capital for companies or public
entities that purchase EPSs. For private firms, the weighted average
cost of capital (``WACC'') is commonly used to estimate the present
value of cash flows to be derived from a typical company project or
investment. Most companies use both debt and equity capital to fund
investments, so their cost of capital is the weighted average of the
cost to the firm of equity and debt financing, as estimated from
financial data for publicly traded firms across all commercial sectors.
The average commercial cost of capital is 6.7%.
See chapter 8 of the NOPR TSD for further details on the
development of consumer discount rates.
[[Page 16134]]
6. Energy Efficiency Distribution in the No-New-Standards Case
To accurately estimate the share of consumers that would be
affected by a potential energy conservation standard at a particular
efficiency level, DOE's LCC analysis considered the projected
distribution (market shares) of product efficiencies under the no-new-
standards case (i.e., the case without amended or new energy
conservation standards).
In the March 2022 Preliminary Analysis, DOE used the CCD \28\ to
estimate the energy efficiency distribution of battery chargers for
2027.\29\ DOE updated these distributions based on the latest data in
CCD. For wireless chargers, DOE estimated the efficiency distributions
based on the models tested and used for the engineering analysis. The
estimated market shares for the no-new-standards case for battery
chargers are shown in Table IV.8. See chapter 8 of the NOPR TSD for
further information on the derivation of the efficiency distributions.
---------------------------------------------------------------------------
\28\ <a href="https://www.regulations.doe.gov/ccms">https://www.regulations.doe.gov/ccms</a>.
\29\ See Chapter 8 of the 2022 Preliminary Analysis Technical
Support Document for Battery Chargers. (Available at:
<a href="http://www.regulations.gov/document/EERE-2020-BT-STD-0013-0009">www.regulations.gov/document/EERE-2020-BT-STD-0013-0009</a>) (last
accessed Sept. 12, 2022).
Table IV.8--Estimated Market Shares of Battery Chargers in the No-New-Standards Case
----------------------------------------------------------------------------------------------------------------
Above
Representative unit (battery energy) Baseline (%) Intermediate intermediate Max-Tech (%)
(%) (%)
----------------------------------------------------------------------------------------------------------------
10Wh............................................ 9.8 48.9 19.4 21.9
10-50Wh (RPU 12.7Wh)............................ 26.1 53.0 18.1 2.8
10-50Wh (RPU 25Wh).............................. 26.1 53.0 18.1 2.8
50-100Wh (RPU 75Wh)............................. 20.6 51.5 27.8 0.1
100-400Wh (RPU 200Wh)........................... 19.7 27.5 37.6 15.2
400-1000Wh (RPU 420Wh).......................... 19.7 27.5 37.6 15.2
>1000Wh (RPU 2000Wh)............................ 38.5 36.1 13.6 11.8
Fixed-Location wireless charger................. 8.3 25.0 58.3 8.3
Open-Placement wireless charger................. 6.7 20.0 20.0 53.3
----------------------------------------------------------------------------------------------------------------
7. Payback Period Analysis
The payback period is the amount of time (expressed in years) it
takes the consumer to recover the additional installed cost of more-
efficient products, compared to baseline products, through energy cost
savings. Payback periods that exceed the life of the product mean that
the increased total installed cost is not recovered in reduced
operating expenses.
The inputs to the PBP calculation for each efficiency level are the
change in total installed cost of the product and the change in the
first-year annual operating expenditures relative to the baseline. DOE
refers to this as a ``simple PBP'' because it does not consider changes
over time in operating cost savings. The PBP calculation uses the same
inputs as the LCC analysis when deriving first-year operating costs.
As noted previously, 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 first year's energy savings resulting from the standard,
as calculated under the applicable test procedure. (42 U.S.C.
6295(o)(2)(B)(iii)) For each considered efficiency level, DOE
determined the value of the first year's energy savings by calculating
the energy savings in accordance with the applicable DOE test
procedure, and multiplying those savings by the average energy price
projection for the year in which compliance with the amended standards
would be required.
The Joint Trade Associations and Delta-Q commented that amended
standards for battery chargers are not economically justified because
the payback periods are far longer than the average useful life of the
product; therefore, most consumers will experience a net cost through
amended standards. The Joint Trade Associations further recommended
that DOE focus on other rulemakings for potential significant energy
savings. (Joint Trade Associations, No. 17 at p. 1; Delta-Q, No. 20 at
p. 1)
DOE notes that the preliminary analysis did not propose any
specific standard level. For this NOPR, DOE's evaluation of the
economic justification of potential standard levels, including the
consideration of payback periods, is provided in section V.C.
G. Shipments Analysis
DOE uses projections of annual product shipments to calculate the
national impacts of potential amended or new energy conservation
standards on energy use, NPV, and future manufacturer cash flows.\30\
The shipments model takes an accounting approach, tracking market
shares of each product class and the vintage of units in the stock.
Stock accounting uses product shipments as inputs to estimate the age
distribution of in-service product stocks for all years. The age
distribution of in-service product stocks is a key input to
calculations of both the national energy savings (``NES'') and NPV,
because operating costs for any year depend on the age distribution of
the stock.
---------------------------------------------------------------------------
\30\ DOE uses data on manufacturer shipments as a proxy for
national sales, as aggregate data on sales are lacking. In general,
one would expect a close correspondence between shipments and sales.
---------------------------------------------------------------------------
In the March 2022 Preliminary Analysis, DOE developed shipments
estimates based on actual shipments from 2019 and a population growth
rate based on U.S. Census population projections through 2050.\31\ DOE
did not receive any comments on the shipments analysis and therefore
used this same approach in the NOPR.
---------------------------------------------------------------------------
\31\ See Chapter 9 of the 2022 Preliminary Analysis Technical
Support Document for Battery Chargers. (Available at:
<a href="http://www.regulations.gov/document/EERE-2020-BT-STD-0013-0009">www.regulations.gov/document/EERE-2020-BT-STD-0013-0009</a>) (last
accessed Sept. 12, 2022).
---------------------------------------------------------------------------
See Chapter 9 of the NOPR TSD for more detail on the shipments
analysis.
DOE requests comment on its methodology for estimating shipments.
DOE also requests comment on its approach to estimate the market share
for EPSs of all product classes.
H. National Impact Analysis
The NIA assesses the NES and the NPV from a national perspective of
total consumer costs and savings that would be expected to result from
new or amended standards at specific efficiency levels.\32\
(``Consumer'' in this context
[[Page 16135]]
refers to consumers of the product being regulated.) DOE calculates the
NES and NPV for the potential standard levels considered based on
projections of annual product shipments, along with the annual energy
consumption and total installed cost data from the energy use and LCC
analyses. For the present analysis, DOE projected the energy savings,
operating cost savings, product costs, and NPV of consumer benefits
over the lifetime of battery chargers sold from 2027 through 2056.
---------------------------------------------------------------------------
\32\ The NIA accounts for impacts in the 50 states and U.S.
territories.
---------------------------------------------------------------------------
DOE evaluates the impacts of new or amended standards by comparing
a case without such standards with standards-case projections. The no-
new-standards case characterizes energy use and consumer costs for each
product class in the absence of new or amended energy conservation
standards. For this projection, DOE considers historical trends in
efficiency and various forces that are likely to affect the mix of
efficiencies over time. DOE compares the no-new-standards case with
projections characterizing the market for each product class if DOE
adopted new or amended standards at specific energy efficiency levels
(i.e., the TSLs or standards cases) for that class. For the standards
cases, DOE considers how a given standard would likely affect the
market shares of products with efficiencies greater than the standard.
DOE uses a spreadsheet model to calculate the energy savings and
the national consumer costs and savings from each TSL. Interested
parties can review DOE's analyses by changing various input quantities
within the spreadsheet. The NIA spreadsheet model uses typical values
(as opposed to probability distributions) as inputs.
Table IV.9 summarizes the inputs and methods DOE used for the NIA
analysis for the NOPR. Discussion of these inputs and methods follows
the table. See chapter 10 of the NOPR TSD for further details.
Table IV.9--Summary of Inputs and Methods for the National Impact
Analysis
------------------------------------------------------------------------
Inputs Method
------------------------------------------------------------------------
Shipments......................... Annual shipments from shipments
model.
Compliance Date of Standard....... 2027.
Efficiency Trends................. No-new-standards case: Varies by
application.
Annual Energy Consumption per Unit Annual weighted-average values are a
function of energy use at each TSL.
Total Installed Cost per Unit..... Annual weighted-average values are a
function of cost at each TSL.
Incorporates projection of future
product prices based on historical
data.
Annual Energy Cost per Unit....... Annual weighted-average values as a
function of the annual energy
consumption per unit and energy
prices.
Repair and Maintenance Cost per Annual values do not change with
Unit. efficiency level.
Energy Price Trends............... AEO2022 projections (to 2050) and
extrapolation thereafter based on
the growth rate from 2023-2050.
Energy Site-to-Primary and FFC A time-series conversion factor
Conversion. based on AEO2022.
Discount Rate..................... 3 percent and 7 percent.
Present Year...................... 2022.
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1. Product Efficiency Trends
A key component of the NIA is the trend in energy efficiency
projected for the no-new-standards case and each of the standards
cases. Section IV.F.6 of this document describes how DOE developed an
energy efficiency distribution for the no-new-standards case (which
yields a shipment-weighted average efficiency) for each of the
considered product classes for the first full year of anticipated
compliance with an amended or new standard. To project the trend in
efficiency absent amended standards for battery chargers over the
entire shipments projection period, DOE assumed a constant efficiency
trend. The approach is further described in chapter 10 of the NOPR TSD.
For the standards cases, DOE used a ``roll-up'' scenario to
establish the shipment-weighted efficiency for the year that standards
are assumed to become effective (2027). In this scenario, the market
shares of products in the no-new-standards case that do not meet the
standard under consideration would ``roll up'' to meet the new standard
level, and the market share of products above the standard would remain
unchanged.
To develop standards case efficiency trends after 2027, DOE used a
constant efficiency trend, keeping the distribution equal to the
compliance year.
2. National Energy Savings
The national energy savings analysis involves a comparison of
national energy consumption of the considered products between each
potential standards case (``TSL'') and the case with no new or amended
energy conservation standards. DOE calculated the national energy
consumption by multiplying the number of units (stock) of each product
(by vintage or age) by the unit energy consumption (also by vintage).
DOE calculated annual NES based on the difference in national energy
consumption for the no-new standards case and for each higher
efficiency standard case. DOE estimated energy consumption and savings
based on site energy and converted the electricity consumption and
savings to primary energy (i.e., the energy consumed by power plants to
generate site electricity) using annual conversion factors derived from
AEO2022. Cumulative energy savings are the sum of the NES for each year
over the timeframe of the analysis.
Use of higher-efficiency products is occasionally associated with a
direct rebound effect, which refers to an increase in utilization of
the product due to the increase in efficiency. DOE did not consider a
rebound effect in this analysis, because the price differences by EL
and energy use are so small that any rebound effect would be close to
zero.
In 2011, in response to the recommendations of a committee on
``Point-of-Use and Full-Fuel-Cycle Measurement Approaches to Energy
Efficiency Standards'' appointed by the National Academy of Sciences,
DOE announced its intention to use FFC measures of energy use and
greenhouse gas and other emissions in the national impact analyses and
emissions analyses included in future energy conservation standards
rulemakings. 76 FR 51281 (Aug. 18, 2011). After evaluating the
approaches discussed in the August 18, 2011 notice, DOE published a
statement
[[Page 16136]]
of amended policy in which DOE explained its determination that EIA's
National Energy Modeling System (``NEMS'') is the most appropriate tool
for its FFC analysis and its intention to use NEMS for that purpose. 77
FR 49701 (Aug. 17, 2012). NEMS is a public domain, multi-sector,
partial equilibrium model of the U.S. energy sector \33\ that EIA uses
to prepare its Annual Energy Outlook. The FFC factors incorporate
losses in production and delivery in the case of natural gas (including
fugitive emissions) and additional energy used to produce and deliver
the various fuels used by power plants. The approach used for deriving
FFC measures of energy use and emissions is described in appendix 10B
of the NOPR TSD.
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\33\ For more information on NEMS, refer to The National Energy
Modeling System: An Overview 2009, DOE/EIA-0581(2009), October 2009.
Available at <a href="http://www.eia.gov/forecasts/aeo/index.cfm">www.eia.gov/forecasts/aeo/index.cfm</a> (last accessed
December 2, 2022).
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3. Net Present Value Analysis
The inputs for determining the NPV of the total costs and benefits
experienced by consumers are (1) total annual installed cost, (2) total
annual operating costs (energy costs and repair and maintenance costs),
and (3) a discount factor to calculate the present value of costs and
savings. DOE calculates net savings each year as the difference between
the no-new-standards case and each standards case in terms of total
savings in operating costs versus total increases in installed costs.
DOE calculates operating cost savings over the lifetime of each product
shipped during the projection period.
As discussed in section IV.F.1 of this document, DOE developed
battery charger price trends based on historical PPI data for the
semiconductor industry. DOE applied the same trends to project prices
for each product class at each considered efficiency level. By 2056,
which is the end date of the projection period, the average battery
charger price is projected to drop 90 percent relative to 2021. DOE's
projection of product prices is described in chapter 8 of the NOPR TSD.
The operating cost savings are energy cost savings, which are
calculated using the estimated energy savings in each year and the
projected price of the appropriate form of energy. To estimate energy
prices in future years, DOE multiplied the average regional energy
prices by the projection of annual national-average residential and
commercial energy price changes in the Reference case from AEO2022,
which has an end year of 2050. To estimate price trends after 2050, DOE
used the average annual rate of change in prices from 2020 through
2050.
In calculating the NPV, DOE multiplies the net savings in future
years by a discount factor to determine their present value. For this
NOPR, DOE estimated the NPV of consumer benefits using both a 3-percent
and a 7-percent real discount rate. DOE uses these discount rates in
accordance with guidance provided by the Office of Management and
Budget (``OMB'') to Federal agencies on the development of regulatory
analysis.\34\ The discount rates for the determination of NPV are in
contrast to the discount rates used in the LCC analysis, which are
designed to reflect a consumer's perspective. The 7-percent real value
is an estimate of the average before-tax rate of return to private
capital in the U.S. economy. The 3-percent real value represents the
``social rate of time preference,'' which is the rate at which society
discounts future consumption flows to their present value.
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\34\ United States Office of Management and Budget. Circular A-
4: Regulatory Analysis. September 17, 2003. Section E. Available at
<a href="http://georgewbush-whitehouse.archives.gov/omb/memoranda/m03-21.html">georgewbush-whitehouse.archives.gov/omb/memoranda/m03-21.html</a> (last
accessed December 2, 2022).
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I. Consumer Subgroup Analysis
In analyzing the potential impact of new or amended energy
conservation standards on consumers, DOE evaluates the impact on
identifiable subgroups of consumers that may be disproportionately
affected by a new or amended national standard. The purpose of a
subgroup analysis is to determine the extent of any such
disproportional impacts. DOE evaluates impacts on particular subgroups
of consumers by analyzing the LCC impacts and PBP for those particular
consumers from alternative standard levels. For this NOPR, DOE analyzed
the impacts of the considered standard levels on one subgroup: low-
income households. The analysis used subsets of the RECS 2015 and CBECS
2018 sample composed of households that meet the criteria for the two
subgroups. DOE used the LCC and PBP spreadsheet model to estimate the
impacts of the considered efficiency levels on these subgroups. Chapter
11 in the NOPR TSD describes the consumer subgroup analysis.
J. Manufacturer Impact Analysis
1. Overview
DOE performed an MIA to estimate the financial impacts of amended
energy conservation standards on manufacturers of battery chargers and
to estimate the potential impacts of such standards on employment and
manufacturing capacity. The MIA has both quantitative and qualitative
aspects and includes analyses of projected industry cash flows, the
INPV, investments in research and development (``R&D'') and
manufacturing capital, and domestic manufacturing employment.
Additionally, the MIA seeks to determine how amended energy
conservation standards might affect manufacturing employment, capacity,
and competition, as well as how standards contribute to overall
regulatory burden. Finally, the MIA serves to identify any
disproportionate impacts on manufacturer subgroups, including small
business manufacturers.
The quantitative part of the MIA primarily relies on the Government
Regulatory Impact Model (``GRIM''), an industry cash flow model with
inputs specific to this rulemaking. The key GRIM inputs include data on
the industry cost structure, unit production costs, product shipments,
manufacturer markups, and investments in R&D and manufacturing capital
required to produce compliant products. The key GRIM outputs are the
INPV, which is the sum of industry annual cash flows over the analysis
period, discounted using the industry-weighted average cost of capital,
and the impact to domestic manufacturing employment. The model uses
standard accounting principles to estimate the impacts of more-
stringent energy conservation standards on a given industry by
comparing changes in INPV and domestic manufacturing employment between
a no-new-standards case and the various standards cases (``TSLs''). To
capture the uncertainty relating to manufacturer pricing strategies
following amended standards, the GRIM estimates a range of possible
impacts under different markup scenarios.
The qualitative part of the MIA addresses manufacturer
characteristics and market trends. Specifically, the MIA considers such
factors as a potential standard's impact on manufacturing capacity,
competition within the industry, the cumulative impact of other DOE and
non-DOE regulations, as well as impacts on manufacturer subgroups. The
complete MIA is outlined in chapter 12 of the NOPR TSD.
DOE conducted the MIA for this rulemaking in three phases. In Phase
1 of the MIA, DOE prepared a profile of the battery charger
manufacturing industry based on the market and technology assessment,
manufacturer interviews, and publicly-available information. This
included a top-down
[[Page 16137]]
analysis of battery charger manufacturers that DOE used to derive
preliminary financial inputs for the GRIM (e.g., revenues; materials,
labor, overhead, and depreciation expenses; selling, general, and
administrative expenses (``SG&A''); and R&D expenses). DOE also used
public sources of information to further calibrate its initial
characterization of the battery charger manufacturing industry,
including company filings of form 10-K from the U.S. Securities and
Exchange Commission (``SEC''),\35\ corporate annual reports, the U.S.
Census Bureau's Economic Census,\36\ and reports from D&B Hoovers.\37\
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\35\ See <a href="http://www.sec.gov/edgar.shtml">www.sec.gov/edgar.shtml</a>.
\36\ See <a href="http://www.census.gov/programs-surveys/asm/data.html">www.census.gov/programs-surveys/asm/data.html</a>.
\37\ See <a href="http://app.dnbhoovers.com">app.dnbhoovers.com</a>.
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In Phase 2 of the MIA, DOE prepared a framework industry cash-flow
analysis to quantify the potential impacts of amended energy
conservation standards. The GRIM uses several factors to determine a
series of annual cash flows starting with the announcement of the
standard and extending over a 30-year period following the compliance
date of the standard. These factors include annual expected revenues,
costs of sales, SG&A and R&D expenses, taxes, and capital expenditures.
In general, energy conservation standards can affect manufacturer cash
flow in three distinct ways: (1) creating a need for increased
investment, (2) raising production costs per unit, and (3) altering
revenue due to higher per-unit prices and changes in sales volumes.
In Phase 3 of the M
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