Energy Conservation Program: Energy Conservation Standards for Dehumidifiers
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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 dehumidifiers. EPCA also requires the U.S. Department of Energy ("DOE") to periodically determine whether more stringent standards would be technologically feasible and economically justified, and would result in significant energy savings. In this notice of proposed rulemaking ("NOPR"), DOE proposes amended energy conservation standards for dehumidifiers, and also announces a public meeting to receive comment on these proposed standards and associated analyses and results.
Full Text
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<title>Federal Register, Volume 88 Issue 213 (Monday, November 6, 2023)</title>
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[Federal Register Volume 88, Number 213 (Monday, November 6, 2023)]
[Proposed Rules]
[Pages 76510-76573]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2023-24106]
[[Page 76509]]
Vol. 88
Monday,
No. 213
November 6, 2023
Part IV
Department of Energy
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10 CFR Part 430
Energy Conservation Program: Energy Conservation Standards for
Dehumidifiers; Proposed Rule
Federal Register / Vol. 88 , No. 213 / Monday, November 6, 2023 /
Proposed Rules
[[Page 76510]]
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DEPARTMENT OF ENERGY
10 CFR Part 430
[EERE-2019-BT-STD-0043]
RIN 1904-AE61
Energy Conservation Program: Energy Conservation Standards for
Dehumidifiers
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking and announcement of public
meeting.
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SUMMARY: The Energy Policy and Conservation Act, as amended (``EPCA''),
prescribes energy conservation standards for various consumer products
and certain commercial and industrial equipment, including
dehumidifiers. EPCA also requires the U.S. Department of Energy
(``DOE'') to periodically determine whether more stringent standards
would be technologically feasible and economically justified, and would
result in significant energy savings. In this notice of proposed
rulemaking (``NOPR''), DOE proposes amended energy conservation
standards for dehumidifiers, and also announces a public meeting to
receive comment on these proposed standards and associated analyses and
results.
DATES:
Comments: DOE will accept comments, data, and information regarding
this NOPR no later than January 5, 2024.
Meeting: DOE will hold a public meeting via webinar on Thursday,
December 14, 2023, from 1:00 p.m. to 4:00 p.m. See section VII of this
document, ``Public Participation,'' for webinar registration
information, participant instructions, and information about the
capabilities available to webinar participants.
Comments regarding the likely competitive impact of the proposed
standard should be sent to the U.S. Department of Justice (``DOJ'')
contact listed in the ADDRESSES section on or before December 6, 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-2019-BT-STD-0043. Follow the instructions for submitting
comments. Alternatively, interested persons may submit comments,
identified by docket number EERE-2019-BT-STD-0043, by any of the
following methods:
Email: <a href="/cdn-cgi/l/email-protection#6f2b0a071a02060b0609060a1d1c5d5f5e563c3b2b5f5f5b5c2f0a0a410b000a41080019"><span class="__cf_email__" data-cfemail="cd89a8a5b8a0a4a9a4aba4a8bfbefffdfcf49e9989fdfdf9fe8da8a8e3a9a2a8e3aaa2bb">[email protected]</span></a>. Include docket number
EERE-2019-BT-STD-0043 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, 1000
Independence Avenue SW, Washington, DC 20585-0121. 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 IV of this document.
Docket: The docket for this activity, which includes Federal
Register notices, comments, and other supporting documents/materials,
is available for review at <a href="http://www.regulations.gov">www.regulations.gov</a>. All documents in the
docket are listed in the <a href="http://www.regulations.gov">www.regulations.gov</a> index. However, not all
documents listed in the index may be publicly available, such as
information that is exempt from public disclosure.
The docket web page can be found at <a href="http://www.regulations.gov/docket/EERE-2019-BT-STD-0043">www.regulations.gov/docket/EERE-2019-BT-STD-0043</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#fc9992998e9b85d28f889d92989d8e988fbc898f989396d29b938a"><span class="__cf_email__" data-cfemail="22474c4750455b0c5156434c4643504651625751464d480c454d54">[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:
Dr. Carl Shapiro, 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#4a0b3a3a26232b24292f193e2b242e2b382e391b3f2f393e232524390a2f2f642e252f642d253c"><span class="__cf_email__" data-cfemail="99d8e9e9f5f0f8f7fafccaedf8f7fdf8ebfdeac8ecfceaedf0f6f7ead9fcfcb7fdf6fcb7fef6ef">[email protected]</span></a>.
Mr. Peter Cochran, U.S. Department of Energy, Office of the General
Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0121.
Telephone: (202) 586-9496. Email: <a href="/cdn-cgi/l/email-protection#6e3e0b1a0b1c402d010d061c0f002e061f400a010b40090118"><span class="__cf_email__" data-cfemail="4a1a2f3e2f386409252922382b240a223b642e252f642d253c">[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#571627273b3e3639343204233639333625332406223224233e3839241732327933383279303821"><span class="__cf_email__" data-cfemail="b4f5c4c4d8ddd5dad7d1e7c0d5dad0d5c6d0c7e5c1d1c7c0dddbdac7f4d1d19ad0dbd19ad3dbc2">[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 Dehumidifiers
III. General Discussion
A. Scope of Coverage
B. Test Procedure
C. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
D. Energy Savings
1. Determination of Savings
2. Significance of Savings
E. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared to Increase in Price (LCC
and PBP)
c. Energy Savings
d. Lessening of Utility or Performance of Products
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion of Related Comments
A. Market and Technology Assessment
1. Product Classes
2. Technology Options
a. Improved Compressor Efficiency
b. Washable Air Filters
c. Air-to-Air Heat Exchangers
d. Alternative Refrigerants
e. Low-Standby-Loss Electronic Controls
f. Multi-Circuited Evaporator and Secondary Condenser Coils
B. Screening Analysis
1. Screened-Out Technologies
2. Remaining Technologies
C. Engineering Analysis
1. Efficiency Analysis
[[Page 76511]]
a. Baseline Efficiency
b. Higher Efficiency Levels
2. Cost Analysis
3. Cost-Efficiency Results
D. Markups Analysis
E. Energy Use Analysis
F. Life-Cycle Cost and Payback Period Analysis
1. Product Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Maintenance and Repair Costs
6. Product Lifetime
7. Discount Rates
8. Energy Efficiency Distribution in the No-New-Standards Case
9. Payback Period Analysis
G. Shipments Analysis
H. National Impact Analysis
1. Product Efficiency Trends
2. National Energy Savings
3. Net Present Value Analysis
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
2. Government Regulatory Impact Model and Key Inputs
a. Manufacturer Production Costs
b. Shipments Projections
c. Capital and Product Conversion Costs
d. Manufacturer Markup Scenarios
3. Manufacturer Interviews
a. Increases in Chassis Size
b. Refrigerant Regulation
4. Discussion of MIA Comments
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 Dehumidifier
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 Including
Differences in Cost, if Any, for Different Groups of 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. Attendance at the Public Meeting
B. Procedure for Submitting Prepared General Statements for
Distribution
C. Conduct of the Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Synopsis of the Proposed Rule
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 \2\ established the Energy
Conservation Program for Consumer Products Other Than Automobiles. (42
U.S.C. 6291-6309) These products include dehumidifiers, the subject of
this proposed 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.
\2\ For editorial reasons, upon codification in the U.S. Code,
Part B was redesignated Part A.
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Pursuant to EPCA, any new or amended energy conservation standard
must be designed to achieve the maximum improvement in energy
efficiency that DOE determines is technologically feasible and
economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the new
or amended standard must result in a significant conservation of
energy. (42 U.S.C. 6295(o)(3)(B)) EPCA also provides that not later
than 6 years after issuance of any final rule establishing or amending
a standard, DOE must publish either a notice of determination that
standards for the product do not need to be amended, or a NOPR
including new proposed energy conservation standards (proceeding to a
final rule, as appropriate). (42 U.S.C. 6295(m))
In accordance with these and other statutory provisions discussed
in this document, DOE analyzed the benefits and burdens of four trial
standard levels (``TSLs'') for dehumidifiers. The TSLs and their
associated benefits and burdens are discussed in detail in sections V.A
through V.C of this document. As discussed in section V.C of this
document, DOE has tentatively determined that TSL 3 represents the
maximum improvement in energy efficiency that is technologically
feasible and economically justified. The proposed standards, which are
expressed in Integrated Energy Factor (``IEF''), or the volume of water
in liters (``L'') removed by a kilowatt hour (``kWh'') of energy, are
shown in Table I.1. These proposed standards, if adopted, would apply
to all dehumidifiers listed in Table I.1. manufactured in, or imported
into, the United States starting on the date 3 years after the
publication of the final rule for this proposed rulemaking.
[[Page 76512]]
Table I.1--Proposed Energy Conservation Standards for Dehumidifiers
------------------------------------------------------------------------
Minimum
integrated
Portable dehumidifier product capacity (pints/day) energy factor
(L/kWh)
------------------------------------------------------------------------
25.00 or less.......................................... 1.70
25.01-50.00............................................ 2.01
50.01 or more.......................................... 3.10
Whole-home dehumidifier product case volume (cubic
feet):
8.0 or less........................................ 2.22
More than 8.0...................................... 3.81
------------------------------------------------------------------------
A. Benefits and Costs to Consumers
Table I.2 presents DOE's evaluation of the economic impacts of the
proposed standards on consumers of dehumidifiers, as measured by the
average life-cycle cost (``LCC'') savings and the simple payback period
(``PBP'').\3\ The average LCC savings are positive for all product
classes, and the PBP is less than the average lifetime of
dehumidifiers, which is estimated to be 10 years for portable
dehumidifiers and 12 years for whole-home dehumidifiers (see section
IV.F.6 of this document).
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\3\ The average LCC savings refer to consumers that are affected
by a standard and are measured relative to the efficiency
distribution in the no-new-standards case, which depicts the market
in the compliance year in the absence of new or amended standards
(see section IV.F.9 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 Dehumidifiers
------------------------------------------------------------------------
Average LCC Simple payback
Product class savings (2022$) period (years)
------------------------------------------------------------------------
Portable dehumidifiers, <=25.00 pints/ $42 0.9
day.................................
Portable dehumidifiers, 25.01-50.00 81 0.6
pints/day...........................
Portable dehumidifiers, >50.00 pints 31 4.8
per day.............................
Whole-home dehumidifiers, <=8.0 cubic 56 6.4
feet case volume....................
Whole-home dehumidifiers, >8.0 cubic 146 5.7
feet case volume....................
------------------------------------------------------------------------
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 <SUP>4</SUP>
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\4\ All monetary values in this document are expressed in 2022
dollars.
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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 (2023-2057). Using a real discount rate of 8.4 percent,
DOE estimates that the INPV for manufacturers of dehumidifiers in the
case without amended standards is $158.3 million. Under the proposed
standards, the change in INPV is estimated to range from -3.3 percent
to -2.1 percent, which is approximately -$5.2 million to -$3.3 million.
In order to bring products into compliance with amended standards, it
is estimated that the industry would incur total conversion costs of
$6.9 million.
DOE's analysis of the impacts of the proposed standards on
manufacturers is described in section IV.J of this document. The
analytic results of the manufacturer impact analysis (``MIA'') are
presented in section V.B.2 of this document.
C. National Benefits and Costs
DOE's analyses indicate that the proposed energy conservation
standards for dehumidifiers would save a significant amount of energy.
Relative to the case without amended standards, the lifetime energy
savings for dehumidifiers purchased in the 30-year period that begins
in the anticipated year of compliance with the amended standards (2028-
2057) amount to 0.33 quadrillion British thermal units (``Btu''), or
quads.\5\ This represents a savings of 5.8 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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\5\ The quantity refers to full-fuel-cycle (``FFC'') energy
savings. FFC energy savings includes the energy consumed in
extracting, processing, and transporting primary fuels (i.e., coal,
natural gas, petroleum fuels), and, thus, presents a more complete
picture of the impacts of energy efficiency standards. For more
information on the FFC metric, see section IV.H.2 of this document.
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The cumulative net present value (``NPV'') of total consumer
benefits of the proposed standards for dehumidifiers ranges from $1.26
billion (at a 7-percent discount rate) to $2.61 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
dehumidifiers purchased from 2028 through 2057.
In addition, the proposed standards for dehumidifiers 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 6.94 million metric tons
(``Mt'') \6\ of carbon dioxide (``CO<INF>2</INF>''), 1.76 thousand tons
of sulfur dioxide (``SO<INF>2</INF>''), 11.81 thousand tons of nitrogen
oxides (``NO<INF>X</INF>''), 51.94 thousand tons of methane
(``CH<INF>4</INF>''), 0.06 thousand tons of nitrous oxide
(``N<INF>2</INF>O''), and 0.01 tons of mercury (``Hg'').\7\
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\6\ A metric ton is equivalent to 1.1 short tons. Results for
emissions other than CO<INF>2</INF> are presented in short tons.
\7\ DOE calculated emissions reductions relative to the no-new-
standards case, which reflects key assumptions in the Annual Energy
Outlook 2023 (``AEO2023''). AEO2023 reflects, to the extent
possible, laws and regulations adopted through mid-November 2022,
including the Inflation Reduction Act. See section IV.K of this
document for further discussion of AEO2023 assumptions that affect
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 (``SC'') of
[[Page 76513]]
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''). DOE used interim SC-GHG values (in terms of benefit per
ton of GHG avoided) developed by the 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 $0.40
billion. DOE does not have a single central SC-GHG point estimate and
emphasizes the importance and value of considering the benefits
calculated using all four sets of SC-GHG estimates.
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\8\ To monetize the benefits of reducing GHG emissions this
analysis uses the interim estimates presented in the Technical
Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide
Interim Estimates Under Executive Order 13990 published in February
2021 by the IWG. (``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 Environmental Protection Agency,\9\ as discussed in section
IV.L of this document. DOE estimated the present value of the health
benefits would be $0.33 billion using a 7-percent discount rate, and
$0.74 billion using a 3-percent discount rate.\10\ DOE is currently
only monetizing health benefits from changes in ambient fine
particulate matter (PM<INF>2.5</INF>) concentrations from two
precursors (SO<INF>2</INF> and NO<INF>X</INF>), and from changes in
ambient ozone from one precursor (for NO<INF>X</INF>), 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\ U.S. EPA. Estimating the Benefit per Ton of Reducing
Directly Emitted PM<INF>2.5</INF>, PM<INF>2.5</INF> Precursors and
Ozone Precursors from 21 Sectors. Available at <a href="http://www.epa.gov/benmap/estimating-benefit-ton-reducing-pm25-precursors-21-sectors">www.epa.gov/benmap/estimating-benefit-ton-reducing-pm25-precursors-21-sectors</a>.
\10\ DOE estimates the economic value of these emissions
reductions resulting from the considered trial standard levels
(``TSLs'') for the purpose of complying with the requirements of
Executive Order 12866.
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Table I.3 summarizes the monetized economic benefits and costs
expected to result from the proposed standards for dehumidifiers. There
are other important unquantified effects, including certain
unquantified climate benefits, unquantified public health benefits from
the reduction of toxic air pollutants and other emissions, unquantified
energy security benefits, and distributional effects, among others.
Table I.3--Summary of Monetized Benefits and Costs of Proposed Energy
Conservation Standards for Dehumidifiers
[Trial Standard Level (``TSL'') 3]
------------------------------------------------------------------------
Billion ($2022)
------------------------------------------------------------------------
3% discount rate
------------------------------------------------------------------------
Consumer Operating Cost Savings........................ 2.75
Climate Benefits *..................................... 0.40
Health Benefits **..................................... 0.74
Total Benefits [dagger]................................ 3.89
Consumer Incremental Product Costs [Dagger]............ 0.14
Net Benefits........................................... 3.75
Change in Producer Cashflow (INPV) [Dagger][Dagger].... (0.005)-(0.003)
------------------------------------------------------------------------
7% discount rate
------------------------------------------------------------------------
Consumer Operating Cost Savings........................ 1.34
Climate Benefits * (3% discount rate).................. 0.40
Health Benefits **..................................... 0.33
Total Benefits [dagger]................................ 2.07
Consumer Incremental Product Costs [Dagger]............ 0.08
Net Benefits........................................... 1.99
Change in Producer Cashflow (INPV) [Dagger][Dagger].... (0.005)-(0.003)
------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with
dehumidifiers shipped in 2028-2057. These results include consumer,
climate, and health benefits that accrue after 2057 from the products
shipped in 2028-2057.
* 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 a 3-percent discount rate) (see
section IV.L of this document). 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.
To monetize the benefits of reducing GHG emissions this analysis uses
the interim estimates presented in the Technical Support Document:
Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates
Under Executive Order 13990 published in February 2021 by the
Interagency Working Group on the Social Cost of Greenhouse Gases
(IWG).
** 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 and
emphasizes the importance and value of considering the benefits
calculated using all four sets of SC-GHG estimates.
[Dagger] Costs include incremental equipment costs as well as
installation costs.
[Dagger][Dagger] Operating Cost Savings are calculated based on the life
cycle costs analysis and national impact analysis as discussed in
detail below. See sections IV.F and IV.H of this document. DOE's
national impacts analysis includes all impacts (both costs and
benefits) along the distribution chain beginning with the increased
costs to the manufacturer to manufacture the product and ending with
the increase in price experienced by the consumer. DOE also separately
conducts a detailed analysis on the impacts on manufacturers (i.e.,
manufacturer impact analysis, or ``MIA''). See section IV.J of this
document. In the detailed MIA, DOE models manufacturers' pricing
decisions based on assumptions regarding investments, conversion
costs, cashflow, and margins. The MIA produces a range of impacts,
which is the rule's expected impact on the INPV. The change in INPV is
the present value of all changes in industry cash flow, including
changes in production costs, capital expenditures, and manufacturer
profit margins. Change in INPV is calculated using the industry
weighted average cost of capital value of 8.4 percent that is
estimated in the manufacturer impact analysis (see chapter 12 of the
NOPR TSD for a complete description of the industry weighted average
cost of capital). For dehumidifiers, the change in INPV ranges from -
$5 million to -$3 million. DOE accounts for that range of likely
impacts in analyzing whether a trial standard level is economically
justified. See section V.C of this document. DOE is presenting the
range of impacts to the INPV under two markup scenarios: the
Preservation of Gross Margin scenario, which is the manufacturer
markup scenario used in the calculation of Consumer Operating Cost
Savings in this table; and the Preservation of Operating Profit Markup
scenario, where DOE assumed manufacturers would not be able to
increase per-unit operating profit in proportion to increases in
manufacturer production costs. DOE includes the range of estimated
INPV in the above table, drawing on the MIA explained further in
section IV.J of this document to provide additional context for
assessing the estimated impacts of this proposal to society, including
potential changes in production and consumption, which is consistent
with OMB's Circular A-4 and E.O. 12866. If DOE were to include the
INPV into the net benefit calculation for this proposed rule, the net
benefits would range from $3.74 billion to $3.75 billion at 3-percent
discount rate and would range from $1.98 billion to $1.99 billion at 7-
percent discount rate. DOE seeks comment on this approach.
[[Page 76514]]
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.\11\
---------------------------------------------------------------------------
\11\ 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.
---------------------------------------------------------------------------
The national operating cost 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 dehumidifiers
shipped between 2028 and 2057. The benefits associated with reduced
emissions achieved as a result of the proposed standards are also
calculated based on the lifetime of dehumidifiers shipped between 2028
and 2057. Total benefits for both the 3-percent and 7-percent cases are
presented using the average GHG social costs with a 3-percent discount
rate. Estimates of SC-GHG values are presented for all four discount
rates in section V.B.6 of this document.
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 $8.55 million per year in increased equipment
costs, while the estimated annual benefits are $142.04 million in
reduced equipment operating costs, $22.85 million in climate benefits,
and $34.54 million in health benefits. In this case, the net benefit
would amount to $190.89 million per year.
Using a 3-percent discount rate for all benefits and costs, the
estimated cost of the proposed standards is $7.89 million per year in
increased equipment costs, while the estimated annual benefits are
$157.99 million in reduced operating costs, $22.85 million in climate
benefits, and $42.30 million in health benefits. In this case, the net
benefit would amount to $215.24 million per year.
Table I.4--Annualized Benefits and Costs of Proposed Energy Conservation Standards for Dehumidifiers
[TSL 3]
----------------------------------------------------------------------------------------------------------------
Million 2022$/year
-------------------------------------------------------
Primary Low-net-benefits High-net-benefits
estimate estimate estimate
----------------------------------------------------------------------------------------------------------------
3% discount rate
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings......................... 157.99 153.04 163.15
Climate Benefits *...................................... 22.85 22.66 22.93
Health Benefits **...................................... 42.30 41.95 42.42
Total Benefits [dagger]................................. 223.14 217.65 228.50
Consumer Incremental Product Costs [Dagger]............. 7.89 7.94 7.77
Net Benefits............................................ 215.24 209.71 220.74
Change in Producer Cashflow............................. (0.5)-(0.3) (0.5)-(0.3) (0.5)-(0.3)
(INPV) [Dagger][Dagger].................................
----------------------------------------------------------------------------------------------------------------
7% discount rate
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings......................... 142.04 138.10 146.50
Climate Benefits * (3% discount rate)................... 22.85 22.66 22.93
Health Benefits **...................................... 34.54 34.31 34.64
Total Benefits [dagger]................................. 199.44 195.07 204.06
Consumer Incremental Product Costs [Dagger]............. 8.55 8.58 8.44
Net Benefits............................................ 190.89 186.49 195.62
Change in Producer Cashflow (INPV) [Dagger][Dagger]..... (0.5)-(0.3) (0.5)-(0.3) (0.5)-(0.3)
----------------------------------------------------------------------------------------------------------------
Note: This table presents the costs and benefits associated with dehumidifiers shipped in 2028-2057. These
results include consumer, climate, and health benefits that accrue after 2057 from the products shipped in
2028-2057. The Primary, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy prices
from the AEO 2023 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. The methods
used to derive projected price trends are explained in sections IV.F.1 and IV.H.3 of this document. 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
document). For presentational purposes of this table, the climate benefits associated with the average SC-GHG
at a 3-percent discount rate are shown, but DOE does not have a single central SC-GHG point estimate and
emphasizes the importance and value of considering the benefits calculated using all four sets of SC-GHG
estimates. To monetize the benefits of reducing GHG emissions this analysis uses the interim estimates
presented in the Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim
Estimates Under Executive Order 13990 published in February 2021 by the Interagency Working Group on the
Social Cost of Greenhouse Gases (IWG).
** 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 DOE does not have a single central SC-GHG point estimate.
[Dagger][Dagger] Costs include incremental equipment costs as well as installation costs.
[[Page 76515]]
[Dagger][Dagger] Operating Cost Savings are calculated based on the life cycle costs analysis and national
impact analysis as discussed in detail below. See sections IV.F and IV.H of this document. DOE's national
impacts analysis includes all impacts (both costs and benefits) along the distribution chain beginning with
the increased costs to the manufacturer to manufacture the product and ending with the increase in price
experienced by the consumer. DOE also separately conducts a detailed analysis on the impacts on manufacturers
(i.e., manufacturer impact analysis, or ``MIA''). See section IV.J of this document. In the detailed MIA, DOE
models manufacturers' pricing decisions based on assumptions regarding investments, conversion costs,
cashflow, and margins. The MIA produces a range of impacts, which is the rule's expected impact on the INPV.
The change in INPV is the present value of all changes in industry cash flow, including changes in production
costs, capital expenditures, and manufacturer profit margins. The annualized change in INPV is calculated
using the industry weighted average cost of capital value of 8.4 percent that is estimated in the manufacturer
impact analysis (see chapter 12 of the NOPR TSD for a complete description of the industry weighted average
cost of capital). For dehumidifiers, the annualized change in INPV ranges from -$0.5 million to -$0.3 million.
DOE accounts for that range of likely impacts in analyzing whether a trial standard level is economically
justified. See section V.C of this document. DOE is presenting the range of impacts to the INPV under two
markup scenarios: the Preservation of Gross Margin scenario, which is the manufacturer markup scenario used in
the calculation of Consumer Operating Cost Savings in this table; and the Preservation of Operating Profit
Markup scenario, where DOE assumed manufacturers would not be able to increase per-unit operating profit in
proportion to increases in manufacturer production costs. DOE includes the range of estimated annualized
change in INPV in the above table, drawing on the MIA explained further in section IV.J of this document to
provide additional context for assessing the estimated impacts of this proposal to society, including
potential changes in production and consumption, which is consistent with OMB's Circular A-4 and E.O. 12866.
If DOE were to include the INPV into the annualized net benefit calculation for this proposed rule, the
annualized net benefits would range from $214.8 million to $214.9 million at 3-percent discount rate and would
range from $190.4 million to $190.6 million at 7-percent discount rate. DOE seeks comment on this approach.
DOE's analysis of the national impacts of the proposed standards is
described in sections IV.H, IV.K, and IV.L of this document.
D. Conclusion
DOE has tentatively concluded that the proposed standards represent
the maximum improvement in energy efficiency that is technologically
feasible and economically justified, and would result in the
significant conservation of energy. Specifically, with regards to
technological feasibility, products achieving these standard levels are
already commercially available for all product classes covered by this
proposal. As for economic justification, 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 dehumidifiers is $8.55 million per year in
increased product costs, while the estimated annual benefits are
$142.04 million in reduced product operating costs, $22.85 million in
climate benefits, and $34.54 million in health benefits. The net
benefit amounts to $190.89 million per year.
The significance of energy savings offered by a new or amended
energy conservation standard cannot be determined without knowledge of
the specific circumstances surrounding a given rulemaking.\12\ For
example, some covered products and equipment have substantial energy
consumption occur during periods of peak energy demand. The impacts of
these products on the energy infrastructure can be more pronounced than
products with relatively constant demand. Accordingly, DOE evaluates
the significance of energy savings on a case-by-case basis.
---------------------------------------------------------------------------
\12\ Procedures, Interpretations, and Policies for Consideration
in New or Revised Energy Conservation Standards and Test Procedures
for Consumer Products and Commercial/Industrial Equipment, 86 FR
70892, 70901 (Dec. 13, 2021).
---------------------------------------------------------------------------
As previously mentioned, the standards are projected to result in
estimated national energy savings of 0.33 quad full-fuel-cycle
(``FFC''), the equivalent of the primary annual energy use of 3.5
million homes. In addition, they are projected to reduce CO<INF>2</INF>
emissions by 6.94 Mt, SO<INF>2</INF> emissions by 1.76 thousand tons,
NO<INF>X</INF> emissions by 11.81 thousand tons, CH<INF>4</INF>
emissions by 51.94 thousand tons, N<INF>2</INF>O emissions by 0.06
thousand tons, Hg emissions by 0.01 tons. Based on these findings, DOE
has initially determined the energy savings from the proposed standard
levels are ``significant'' within the meaning of 42 U.S.C.
6295(o)(3)(B). The basis for these tentative conclusions is detailed in
the remainder of this document and the accompanying technical support
document (``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
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
dehumidifiers.
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 dehumidifiers,
the subject of this document. (42 U.S.C. 6295(cc)) EPCA prescribed
initial energy conservation standards for these products. Id. 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. (42 U.S.C.
6297(d))
[[Page 76516]]
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 dehumidifiers appear at title 10 of the Code of
Federal Regulations (``CFR'') part 430, subpart B, appendix X1.
DOE must follow specific statutory criteria for prescribing new or
amended standards for covered products, including dehumidifiers. 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) 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 dehumidifiers, 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 standard;
(3) The total projected amount of energy (or as applicable, water)
savings likely to result directly from the standard;
(4) Any lessening of the utility or the performance of the covered
products likely to result from the standard;
(5) The impact of any lessening of competition, as determined in
writing by the Attorney General, that is likely to result from the
standard;
(6) The need for national energy and water conservation; and
(7) Other factors the Secretary of Energy (``Secretary'') considers
relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
Further, EPCA establishes a rebuttable presumption that a standard
is economically justified if the Secretary finds that the additional
cost to the consumer of purchasing a product complying with an energy
conservation standard level will be less than three times the value of
the energy savings during the first year that the consumer will receive
as a result of the standard, as calculated under the applicable test
procedure. (42 U.S.C. 6295(o)(2)(B)(iii))
EPCA also contains what is known as an ``anti-backsliding''
provision, which prevents the Secretary from prescribing any amended
standard that either increases the maximum allowable energy use or
decreases the minimum required energy efficiency of a covered product.
(42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe an amended
or new standard if interested persons have established by a
preponderance of the evidence that the standard is likely to result in
the unavailability in the United States in any covered product type (or
class) of performance characteristics (including reliability),
features, sizes, capacities, and volumes that are substantially the
same as those generally available in the United States. (42 U.S.C.
6295(o)(4))
Additionally, EPCA specifies requirements when promulgating an
energy conservation standard for a covered product that has two or more
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 dehumidifiers
address standby mode and off mode energy use. In this proposed
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
dehumidifiers manufactured on and after June 13, 2019. 81 FR 38338.
These standards are set forth in DOE's regulations at 10 CFR
430.32(v)(2).
Table II.1--Federal Energy Conservation Standards for Dehumidifiers
------------------------------------------------------------------------
Minimum
integrated
Portable dehumidifier product capacity (pints/day) energy factor
(L/kWh)
------------------------------------------------------------------------
25.00 or less.......................................... 1.30
[[Page 76517]]
25.01-50.00............................................ 1.60
50.01 or more.......................................... 2.80
------------------------------------------------------------------------
Whole-home dehumidifier product case volume ...............
(cubic feet)
------------------------------------------------------------------------
8.0 or less............................................ 1.77
More than 8.0.......................................... 2.41
------------------------------------------------------------------------
2. History of Standards Rulemaking for Dehumidifiers
On June 4, 2021, DOE published a Request for Information (``June
2021 RFI'') in the Federal Register to collect data and information to
inform its decision, consistent with its obligations under EPCA, as to
whether the Department should proceed with an energy conservation
standards rulemaking for an amended energy conservation standard for
dehumidifiers. 86 FR 29964, 29965.
DOE published a notice of public meeting and availability of the
preliminary TSD on June 22, 2022 (``June 2022 Preliminary Analysis'').
87 FR 37240. DOE received comments in response to the June 2022
Preliminary Analysis from the interested parties listed in Table II.2.
Table II.2--June 2022 Preliminary Analysis Written Comments
----------------------------------------------------------------------------------------------------------------
Comment
Commenter(s) Abbreviation number in Commenter type
the docket
----------------------------------------------------------------------------------------------------------------
Appliance Standards Awareness Joint Commenters.......... 21 Efficiency Organizations.
Project, American Council for an
Energy-Efficient Economy,
National Consumer Law Center,
Natural Resources Defense
Council, Northwest Energy
Efficiency Alliance.
Association of Home Appliance AHAM...................... 22 Trade Association.
Manufacturers.
Madison Indoor Air Quality....... MIAQ...................... 20 Manufacturer.
----------------------------------------------------------------------------------------------------------------
A parenthetical reference at the end of a comment quotation or
paraphrase provides the location of the item in the public record.\13\
To the extent that interested parties have provided written comments
that are substantively consistent with any oral comments provided
during the July 19, 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.
---------------------------------------------------------------------------
\13\ The parenthetical reference provides a reference for
information located in the docket of DOE's rulemaking to develop
energy conservation standards for dehumidifiers (Docket No. EERE-
2019-BT-STD-0043, 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).
---------------------------------------------------------------------------
C. 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 pre-NOPR stages for an energy
conservation standards rulemaking. Section 6(a)(2) of appendix A states
that if the Department determines it is appropriate to proceed with a
rulemaking, the preliminary stages of a rulemaking to issue or amend an
energy conservation standard that DOE will undertake will include a
framework document and preliminary analysis, or an advance notice of
proposed rulemaking. While DOE published a preliminary analysis for
this proposed rulemaking, DOE did not publish a framework document in
conjunction with the preliminary analysis. 87 FR 37240. DOE notes,
however, chapter 2 of the June 2022 Preliminary TSD that accompanied
the June 2022 Preliminary Analysis--entitled Analytical Framework,
Comments from Interested Parties, and DOE Responses--describes the
general analytical framework that DOE uses in evaluating and developing
potential amended energy conservation standards. DOE also previously
published the June 2021 RFI, in which DOE identified and sought comment
on the analyses that would be conducted in support of an energy
conservation standards rulemaking for dehumidifiers. 86 FR 29964,
29965-29966. As such, publication of a separate framework document
would be largely redundant of previously published documents.
Section 6(f)(2) of appendix A specifies that the length of the
public comment period for a NOPR will vary depending upon the
circumstances of the particular proposed rulemaking, but 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 June 2021
RFI on the technical and economic analyses and provided stakeholders a
45-day comment period, after granting a 15-day comment period
extension. 86 FR 29964 and 86 FR 34639. Additionally, DOE provided a
60-day comment period for the June 2022 Preliminary Analysis. 87 FR
37240, 37241. The analytical methods used for this NOPR are similar to
those used in previous rulemaking documents. As such, DOE believes a
60-day comment period is appropriate and will provide interested
parties with a meaningful opportunity to comment on the proposed rule.
Section 8(d)(1) of appendix A specifies that test procedure rulemakings
establishing methodologies used to evaluate proposed energy
conservation standards will be finalized prior to publication of a NOPR
proposing new or amended energy conservation standards. Additionally,
new test procedures and amended test procedures that impact measured
energy use or efficiency will be finalized at least 180 days prior to
the close of the
[[Page 76518]]
comment period for (1) a NOPR proposing new or amended energy
conservation standards or (2) a notice of proposed determination that
standards do not need to be amended. In the dehumidifier test procedure
final rule published on July 26, 2023, (July 2023 Test Procedure Final
Rule), DOE amended the test procedures for dehumidifiers. 88 FR 48035.
DOE determined that the amendments adopted will not alter (i.e., will
not impact) the measured efficiency of dehumidifiers. Id. As such, the
requirement that the amended test procedure be finalized at least 180
days prior to the close of the comment period for this NOPR does not
apply.
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. Scope of Coverage
This NOPR covers those consumer products that meet the definition
of ``dehumidifier'' as codified at 10 CFR 430.2.
EPCA defines a dehumidifier as a product that is a self-contained,
electrically operated, and mechanically encased assembly, consisting of
a refrigerated surface (evaporator) that condenses moisture from the
atmosphere, a refrigerating system with an electric motor, an air-
circulating fan, and a means for collecting or disposing of the
condensate. (42 U.S.C. 6291(34)) In a final rule published on July 31,
2015 (``July 2015 Test Procedure Final Rule''), DOE clarified that this
definition of a dehumidifier, codified at 10 CFR 430.2, does not apply
to portable air conditioners, room air conditioners, or packaged
terminal air conditioners. 80 FR 45802, 45804-45805 (July 31, 2015).
DOE also added definitions for portable dehumidifiers and whole-home
dehumidifiers to 10 CFR 430.2. Portable dehumidifiers are designed to
operate within the dehumidified space without ducting attached,
although ducting may be attached optionally. Whole-home dehumidifiers
are designed to be installed with inlet ducting for return process air
and outlet ducting that supplies dehumidified process air to one or
more locations in the dehumidified space. 10 CFR 430.2 DOE further
established that dehumidifiers that are able to operate as both a
portable and whole-home dehumidifier would be tested and rated for both
configurations. 80 FR 45802, 45805-45806. See section IV.A.1 of this
document for discussion of the product classes analyzed in this NOPR.
B. Test Procedure
EPCA sets forth generally applicable criteria and procedures for
DOE's adoption and amendment of test procedures. (42 U.S.C. 6293)
Manufacturers of covered products must use these test procedures to
certify to DOE that their product complies with energy conservation
standards and to quantify the efficiency of their product. DOE's
current energy conservation standards for dehumidifiers are expressed
in terms of IEF in L/kWh. 10 CFR 430.32(v)(2) and 10 CFR part 430,
subpart B, appendix X1.
C. 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
proposed 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. See sections 6(b)(3)(i) and 7(b)(1) of
appendix A to 10 CFR part 430 subpart C (``appendix A'').
After DOE has determined that particular technology options are
technologically feasible, it further evaluates each technology option
in light of the following additional screening criteria: (1)
practicability to manufacture, install, and service; (2) adverse
impacts on product utility or availability; (3) adverse impacts on
health or safety; and (4) unique pathway proprietary technologies. See
sections 6(b)(3)(ii)-(v) and 7(b)(2)-(5) of appendix A. Section IV.B of
this document discusses the results of the screening analysis for
dehumidifiers, particularly the designs DOE considered, those it
screened out, and those that are the basis for the standards considered
in this proposed rulemaking. For further details on the screening
analysis for this proposed rulemaking, see chapter 4 of the NOPR TSD.
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt a new or 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 dehumidifiers, 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 proposed rulemaking
are described in section IV.C.1.b of this document and in chapter 5 of
the NOPR TSD.
D. Energy Savings
1. Determination of Savings
For each trial standard level (``TSL''), DOE projected energy
savings from application of the TSL to dehumidifiers purchased in the
30-year period that begins in the year of compliance with the proposed
standards (2028-2057).\14\ The savings are measured over the entire
lifetime of dehumidifiers 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.
---------------------------------------------------------------------------
\14\ 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 dehumidifiers. 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. DOE also calculates NES in terms of FFC energy savings.
The FFC metric includes the energy consumed in extracting, processing,
and transporting primary
[[Page 76519]]
fuels (i.e., coal, natural gas, petroleum fuels), and thus presents a
more complete picture of the impacts of energy conservation
standards.\15\ 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.
---------------------------------------------------------------------------
\15\ 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.\16\ 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. 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.
---------------------------------------------------------------------------
\16\ Procedures, Interpretations, and Policies for Consideration
in New or Revised Energy Conservation Standards and Test Procedures
for Consumer Products and Commercial/Industrial Equipment, 86 FR
70892, 70901 (Dec. 13, 2021).
---------------------------------------------------------------------------
As stated, the standard levels proposed in this document are
projected to result in national energy savings of 0.33 quad, the
equivalent of the primary annual energy use of 3.5 million homes. Based
on the amount of FFC savings, the corresponding reduction in emissions,
and the need to confront the global climate crisis, DOE has initially
determined the energy savings from the proposed standard levels are
``significant'' within the meaning of 42 U.S.C. 6295(o)(3)(B).
E. 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 proposed rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a potential new or amended standard
on manufacturers, DOE conducts an MIA, as discussed in section IV.J of
this document. DOE first uses an annual cash-flow approach to determine
the quantitative impacts. This step includes both a short-term
assessment--based on the cost and capital requirements during the
period between when a regulation is issued and when entities must
comply with the regulation--and a long-term assessment over a 30-year
period. The industry-wide impacts analyzed include (1) INPV, which
values the industry on the basis of expected future cash flows, (2)
cash flows by year, (3) changes in revenue and income, and (4) other
measures of impact, as appropriate. Second, DOE analyzes and reports
the impacts on different types of manufacturers, including impacts on
small manufacturers. Third, DOE considers the impact of standards on
domestic manufacturer employment and manufacturing capacity, as well as
the potential for standards to result in plant closures and loss of
capital investment. Finally, DOE takes into account cumulative impacts
of various DOE regulations and other regulatory requirements on
manufacturers.
For individual consumers, measures of economic impact include the
changes in LCC and PBP associated with new or amended standards. These
measures are discussed further in the following section. For consumers
in the aggregate, DOE also calculates the national net present value of
the consumer costs and benefits expected to result from particular
standards. DOE also evaluates the impacts of potential standards on
identifiable subgroups of consumers that may be affected
disproportionately by a standard.
b. Savings in Operating Costs Compared To Increase in Price (LCC and
PBP)
EPCA requires DOE to consider the savings in operating costs
throughout the estimated average life of the covered product in the
type (or class) compared to any increase in the price of, or in the
initial charges for, or maintenance expenses of, the covered product
that are likely to result from a standard. (42 U.S.C.
6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC and PBP
analysis.
The LCC is the sum of the purchase price of a product (including
its installation) and the operating expense (including energy,
maintenance, and repair expenditures) discounted over the lifetime of
the product. The LCC analysis requires a variety of inputs, such as
product prices, product energy consumption, energy prices, maintenance
and repair costs, product lifetime, and discount rates appropriate for
consumers. To account for uncertainty and variability in specific
inputs, such as product lifetime and discount rate, DOE uses a
distribution of values, with probabilities attached to each value.
The PBP is the estimated amount of time (in years) it takes
consumers to recover the increased purchase cost (including
installation) of a more-efficient product through lower operating
costs. DOE calculates the PBP by dividing the change in purchase cost
due to a more stringent standard by the change in annual operating cost
for the year that standards are assumed to take effect.
For its LCC and PBP analysis, DOE assumes that consumers will
purchase the covered products in the first year of compliance with new
or amended standards. The LCC savings for the considered efficiency
levels are calculated relative to the case that reflects projected
market trends in the absence of new or amended standards. DOE's LCC and
PBP analysis is discussed in further detail in section IV.F of this
document.
c. Energy Savings
Although significant conservation of energy is a separate statutory
requirement for adopting an energy conservation standard, EPCA requires
DOE, in determining the economic justification of a standard, to
consider the total projected energy savings that are expected to result
directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As
discussed in section III.D of this document, DOE uses the NIA
spreadsheet models to project national energy savings.
d. Lessening of Utility or Performance of Products
In establishing product classes and in evaluating design options
and the impact of potential standard levels, DOE evaluates potential
standards that would not lessen the utility or performance of the
considered products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) Based on data
available to DOE, the standards proposed in this document would not
reduce the utility or performance of the products under consideration
in this proposed rulemaking.
[[Page 76520]]
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 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 of this document;
the estimated emissions impacts are reported in section V.B.6 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 IV.F.9 of this document.
IV. Methodology and Discussion of Related Comments
This section addresses the analyses DOE has performed for this
proposed rulemaking with regard to dehumidifiers. 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 shipment 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 proposed rulemaking:
<a href="http://www.regulations.gov/docket/EERE-2019-BT-STD-0043">www.regulations.gov/docket/EERE-2019-BT-STD-0043</a>. Additionally, DOE
used output from the latest version of the Energy Information
Administration's (``EIA's'') Annual Energy Outlook (``AEO''), a widely
known energy projection for the United States, for the emissions and
utility impact analyses.
A. Market and Technology Assessment
DOE develops information in the market and technology assessment
that provides an overall picture of the market for the products
concerned, including the purpose of the products, the industry
structure, manufacturers, market characteristics, and technologies used
in the products. This activity includes both quantitative and
qualitative assessments, based primarily on publicly available
information. The subjects addressed in the market and technology
assessment for this proposed 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
dehumidifiers. 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
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
[[Page 76521]]
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))
DOE currently defines separate energy conservation standards using
five dehumidifier product classes (10 CFR 430.32(v)(2)):
Portable dehumidifiers have three product classes based on the
product capacity: Product Class 1 are those with a capacity of 25.00
pints/day or less, Product Class 2 dehumidifiers have a capacity of
25.01 to 50.00 pints/day, and Product Class 3 dehumidifiers have a
capacity of 50.01 pints/day or more. Whole-home dehumidifiers have two
product classes based on product case volume: Product Class 4
dehumidifiers have a case volume of 8.0 cubic feet or less, and Product
Class 5 have a case volume of more than 8.0 cubic feet.
According to MIAQ, many of the units that are meant to be placed in
the crawlspace of a home meet the portable dehumidifier definition due
to their installation and configuration but have the same manufacturer
production cost (``MPC'') as whole-home dehumidifiers. MIAQ stated that
DOE did not clearly distinguish the difference between typical portable
dehumidifiers and portable crawlspace dehumidifiers in the June 2022
Preliminary Analysis and requested that DOE keep this difference in
mind when updating the TSD. (MIAQ, No. 20 at pp. 1-2)
Dehumidifiers are classified based on their ducting configuration
during consumer use, according to the definitions established in 10 CFR
430.2. Portable dehumidifiers operate in applications that require
space dehumidification without ducting. Whole-home dehumidifiers
operate with ducting, typically in conjunction with a heating,
ventilating, and air conditioning (``HVAC'') system. Dehumidifiers
installed in basement crawlspaces without ducting are classified as
portable dehumidifiers. DOE is not aware of any specific performance-
related feature that would justify a new product class for portable
dehumidifiers installed in basement crawlspaces. Therefore, when
conducting the engineering analysis, as discussed further in section
IV.C of this document and chapter 5 of the NOPR TSD, DOE considered the
MPCs of a variety of units in the largest portable dehumidifier product
class, Product Class 3.
2. Technology Options
In the preliminary market analysis and technology assessment, DOE
identified 16 technology options that would be expected to improve the
efficiency of dehumidifiers, as measured by the DOE test procedure.
Table IV.2--Technology Options for Dehumidifiers
------------------------------------------------------------------------
-------------------------------------------------------------------------
1. Microchannel heat exchangers.
2. Built-in hygrometer/humidistat.
3. Improved compressor efficiency.
4. Improved condenser and evaporator performance.
5. Improved controls.
6. Improved defrost methods.
7. Improved demand-defrost controls.
8. Improved fan and fan-motor efficiency.
9. Improved flow-control devices.
10. Low-standby-loss electronic controls.
11. Washable air filters.
12. Pre-cooling air-to-air heat exchangers.
13. Heat pipes.
14. Improved refrigeration system insulation.
15. Refrigerant-desiccant systems.
16. Alternative refrigerants.
------------------------------------------------------------------------
Several commenters provided feedback on some of these technology
options. These comments are summarized below, along with DOE's
responses.
a. Improved Compressor Efficiency
MIAQ stated that finding suitable high-efficiency compressors at
the capacities and price points needed for dehumidifiers is a
challenge, particularly with the transition to new refrigerants.
According to MIAQ, the whole-home and crawlspace dehumidifier industry
does not have sufficient volume to garner the full attention of
compressor manufacturers. (MIAQ, No. 20 at p. 2)
DOE has considered MIAQ's comments regarding high-efficiency
compressor availability, and for the reasons discussed in chapter 3 of
the NOPR TSD, expects that by the time that compliance is required with
any new dehumidifier standards, dehumidifier manufacturers will
transition to compressors utilizing R-32 in place of compressors
designed for the refrigerants currently in use. DOE acknowledges that
there is significant uncertainty regarding the availability of the
highest-efficiency single-speed compressors designed for operation with
R-32 refrigerant that were analyzed for the June 2022 Preliminary
Analysis, particularly in the smallest capacities. For this NOPR
analysis, DOE has limited the improved compressor efficiency technology
option to the maximum R-32 compressor efficiency that was observed
within its teardown sample of dehumidifiers, to ensure that such
compressors are already commercially available to the dehumidifier
industry. Furthermore, should this NOPR proceed to a final rule,
compliance with any amended standards would not be required until 3
years after a final rule is published. DOE expects that this 3-year
compliance period would provide adequate time for dehumidifier original
equipment manufacturers (``OEMs'') to source a sufficient supply of
more efficient R-32 compressors ahead of anticipated demand. DOE
expects that standards, if adopted, would therefore provide sufficient
time and regulatory certainty for manufacturers and compressor
suppliers to establish additional capacity in the supply chain, if
needed.
MIAQ reiterated its comment on the June 2022 Dehumidifier Test
Procedure NOPR \17\ that variable-speed compressors do not provide
sufficient energy savings to justify the significant increase in cost
required to implement this technology, especially in the consumer
product market. (MIAQ, No. 20 at p. 3)
---------------------------------------------------------------------------
\17\ See posted comment on <a href="http://www.regulations.gov">www.regulations.gov</a>, Docket No. EERE-
2019-BT-TP-0026-0008-0015.
---------------------------------------------------------------------------
In the June 2022 Preliminary Analysis, DOE considered variable-
speed compressors as part of the technology assessment, but took into
account only their full-load efficiency. As discussed in chapter 3 of
the preliminary TSD, the DOE test procedure at appendix X1 does not
attribute any partial-load efficiency improvements to variable-speed
dehumidifiers as the test procedures for room air conditioners and
portable air conditioners do for units with variable-speed compressors,
because variable-speed dehumidifiers must maintain a constant
evaporator temperature below the dew point regardless of the amount of
moisture present in the room. This provides no opportunity for energy
savings. DOE also noted the costs associated with implementing
variable-speed compressors and accounted for these costs in the
engineering analysis where appropriate.
Since publication of the June 2022 Preliminary Analysis, additional
market research, manufacturer interviews, and input from commenters led
DOE to understand that variable-speed compressors do not offer
efficiency benefits sufficient to justify the costs and design
challenges associated with implementing them for dehumidifiers.
Therefore, in the analysis for this NOPR, DOE did not consider
variable-speed compressors as a design option to improve compressor
efficiency. See chapter 3 of the NOPR TSD for
[[Page 76522]]
additional discussion about variable-speed compressors.
AHAM requested that DOE evaluate whether the use of variable-
frequency drives and similar high frequency components will lead to
increased nuisance tripping of ground-fault circuit-interrupters
(``GFCIs'') and associated cost implications. According to AHAM,
nuisance tripping may require a consumer to call an electrician to
change a breaker or replace a unit and could lead to less efficient
operation, as continuous dehumidification over time is more efficient
than interrupted dehumidification. (AHAM, No. 22 at p. 7)
DOE is aware that when implementing variable-frequency drives, as
for both variable-speed compressors and fan blower electronically
commutated motors (``ECMs''), it is possible that GFCI systems will
trip without a fault present, requiring a manual reset of the
dehumidifier by the consumer. However, DOE understands that GFCI
tripping, even for units with variable-speed drives, can generally be
mitigated through the use of best practices for reducing leakage
current, such as minimizing ECM cable length and ensuring that filtered
and unfiltered cables are separated to whatever extent possible to
reduce leakage current. Additionally, optimizing the variable-frequency
controller power filter to reduce total leakage current to levels below
the GFCI detection limits can prevent GFCI tripping. Furthermore, DOE
does not have any information on the prevalence of nuisance tripping
events or on the potential impact of such trips on consumer utility or
dehumidifier energy use. DOE notes that despite the potential for
nuisance tripping, a wide range of appliances on the market today,
including dehumidifiers, implement variable-frequency drives in their
designs. The inclusion of these variable-frequency drive designs in
units on the market suggests that they do not have a significant impact
on the consumer utility of these products. Therefore, DOE is continuing
to consider ECMs for fan blowers as a technology option for the NOPR
engineering analysis. However, for the reasons discussed above, DOE did
not consider variable-speed compressors as a technology option to
improve compressor efficiency in this NOPR analysis.
b. Washable Air Filters
MIAQ did not support the use of washable air filters and stated
that in a limited study washable filters were changed less frequently
than disposable filters, leading to reduced airflow and reduced
efficiency. (MIAQ, No. 20 at p. 3)
DOE understands that the efficiency impacts due to air filters are
dependent on regular consumer maintenance. As DOE noted in the
technology assessment in chapter 3 of the preliminary TSD, it is
difficult to predict the amount of energy savings that could be
realized with the addition of washable air filters, as it is dependent
on the specific dehumidifier model and use characteristics, and on the
degree to which the consumer takes advantage of this feature. DOE also
noted in the preliminary TSD that most dehumidifiers incorporate an air
filter and that most manufacturers design the air filters to be
removable and washable. Therefore, DOE did not consider washable air
filters as a design option to improve efficiency in the engineering
analysis for the June 2022 Preliminary Analysis. The information that
MIAQ provided regarding the efficiency impacts of washable air filters
further supports DOE's preliminary determination not to include
washable air filters as a design option in the engineering analysis,
and in light of the uncertainty and lack of sufficient data as to any
efficiency benefit associated with them and the prevalence of them in
dehumidifiers already on the market, DOE has tentatively removed from
consideration washable air filters as a technology option in this NOPR.
c. Air-to-Air Heat Exchangers
According to MIAQ, air-to-air heat exchangers add significant cost
and complexity to the design, MPC, and installation of the unit and
typically push the unit into the greater than 8 cubic foot category
where minimum efficiency values are considerably higher. (MIAQ, No. 20
at p. 3)
DOE considers the costs of design options in the engineering
analysis. Although DOE is aware that air-to-air heat exchangers are
implemented in many whole-home dehumidifiers with case volumes greater
than 8 cubic feet, DOE did not implement air-to-air heat exchangers as
a design option to achieve higher efficiency levels in the NOPR
engineering analysis because dehumidifiers with size constraints that
allow air-to-air heat exchangers already implement them and they
require too much case volume increase to implement for other units.
(See chapter 5 of the NOPR TSD for additional details.)
d. Alternative Refrigerants
The Joint Commenters supported DOE's decision to consider R-32
compressors as a design option for dehumidifiers due to their
significant potential to improve efficiencies, and agreed that R-32
will likely be acceptable for use in dehumidifiers by the time amended
standards come into effect. The Joint Commenters noted that in July
2022, the U.S. Environmental Protection Agency (``EPA'') proposed to
list R-32 as acceptable for use in new residential dehumidifiers.
(Joint Commenters, No. 21 at p. 1)
MIAQ requested that DOE consider the impact on efficiency that any
new refrigerant would have on dehumidifiers. Although some refrigerants
may provide efficiency improvements, optimizing the unit's performance
would require time and the assistance of component suppliers. (MIAQ,
No. 20 at p. 3)
DOE is aware that new refrigerant regulations from entities such as
the California Air Resource Board (``CARB'') are prompting an industry-
wide refrigerant changeover. Based on feedback received during the
manufacturer interview process, DOE expects that the process of
redesigning and optimizing dehumidifiers for new refrigerants such as
R-32 will be part of the typical new unit design process, not a result
of any amended standards that DOE may adopt. Additionally, DOE
estimates that the implementation of R-32 in dehumidifiers is unlikely
to result in an efficiency increase due to the refrigerant changeover
alone, although compressors designed for R-32 may be slightly more
efficient than compressors designed for R-410a due to other design
improvements. Therefore, given this industry-wide refrigerant
changeover expected to occur by the compliance date of any new
dehumidifier standards, in this NOPR analysis DOE considered the impact
of compressor improvements on overall dehumidifier efficiency only for
those compressors using R-32, assuming that manufacturers will already
have transitioned to refrigeration systems optimized for the new
refrigerant.
DOE requests comment on the effects of EPA and CARB regulations on
refrigerant choices and on whether changes in refrigerant will affect
manufacturer's ability to achieve the efficiency levels in the NOPR
analysis and the availability of high-efficiency R-32 compressors.
For further discussion of the cumulative regulatory burden, see
section V.B.2.e of this document.
e. Low-Standby-Loss Electronic Controls
According to AHAM, low standby-loss electronic controls save as
little as 1 watt of power and have a minimal impact to overall energy
savings that
[[Page 76523]]
does not warrant the cost of implementing this technology option, and
should therefore have been screened out by DOE. (AHAM, No. 22 at p. 4)
In the engineering analysis, DOE accounts for the cost relative to
the efficiency benefit of all technologies that pass the screening
analysis and are considered, as discussed. See chapter 3 of the NOPR
TSD for discussion of the potential efficiency benefits of low-standby-
loss electronic controls and chapter 5 of the NOPR TSD for further
discussion of the costs of this technology.
f. Multi-Circuited Evaporator and Secondary Condenser Coils
Since publication of the June 2022 Preliminary Analysis, DOE became
aware of at least one whole-home dehumidifier on the market that
implements a novel refrigeration loop design. This patented design
``causes part of the refrigerant within the system to evaporate and
condense twice in one refrigeration cycle, thereby increasing the
compressor capacity over typical systems without adding any additional
power to the compressor.'' \18\ DOE has observed that this technology
has resulted in a unit that is at least 4-percent more efficient than
any other unit available on the market and a significant reduction in
case volume compared to units with similar dehumidification capacities.
Therefore, DOE has included multi-circuited evaporator and secondary
condenser coil refrigerant systems as an additional technology option
for this NOPR. See chapter 3 of the NOPR TSD for additional discussion
of this technology.
---------------------------------------------------------------------------
\18\ U.S. Patent No. 10,845,069.
---------------------------------------------------------------------------
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
In the June 2022 Preliminary Analysis, DOE screened out pre-cooling
air-to-air heat exchangers and heat pipes from the analysis for
portable dehumidifiers with capacities up to and including 50 pints/
day. DOE determined that these dehumidifiers could not accommodate the
significant increases in case size and weight required to implement
these technologies without a significant adverse effect on consumer
utility (screening criterion 3).
AHAM agreed that implementation of pre-cooling air-to-air heat
exchangers is applicable only to high-capacity portable dehumidifiers
in Product Class 3 and requested that DOE recognize that current
dehumidifier casings may not accommodate the increase in components and
product size associated with this technology option. (AHAM, No. 22 at
p. 4)
For the reasons given in the June 2022 Preliminary Analysis, DOE is
maintaining the same approach to air-to-air heat exchangers and heat
pipes in this NOPR analysis. See chapter 4 of the NOPR TSD for further
discussion.
DOE is also screening out multi-circuited evaporator and secondary
condenser coil refrigerant systems, a technology newly considered for
the NOPR per section IV.A.2.f of this document, because it represents a
unique-pathway proprietary technology. See chapter 4 of the NOPR TSD
for further discussion.
2. Remaining Technologies
Through a review of each technology, DOE tentatively concludes that
all of the other identified technologies listed in section IV.A.2 of
this document meet 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.3--Retained Design Options for Dehumidifiers
------------------------------------------------------------------------
-------------------------------------------------------------------------
1. Microchannel heat exchangers.
2. Built-in hygrometer/humidistat.
3. Improved compressor efficiency.
4. Improved condenser and evaporator performance.
5. Improved controls.
6. Improved defrost methods.
7. Improved demand-defrost controls.
8. Improved fan and fan-motor efficiency.
9. Improved flow-control devices.
[[Page 76524]]
10. Low-standby-loss electronic controls.
11. Pre-cooling air-to-air heat exchanger (high-capacity portable and
whole-home dehumidifiers only).
12. Heat pipes (high-capacity portable and whole-home dehumidifiers
only).
13. Improved refrigeration system insulation.
14. Refrigerant-desiccant systems.
15. Alternative refrigerants.
------------------------------------------------------------------------
DOE has initially determined that these technology options are
technologically feasible because they are being used or have previously
been used in commercially available products or working prototypes. DOE
also finds that all of the remaining technology options meet the other
screening criteria (i.e., practicable to manufacture, install, and
service and do not result in adverse impacts on consumer utility,
product availability, health, or safety, unique-pathway proprietary
technologies). For additional details, see chapter 4 of the NOPR TSD.
C. Engineering Analysis
The purpose of the engineering analysis is to establish the
relationship between the efficiency and cost of dehumidifiers. There
are two elements to consider in the engineering analysis; the selection
of efficiency levels to analyze (i.e., the ``efficiency analysis'') and
the determination of product cost at each efficiency level (i.e., the
``cost analysis''). In determining the performance of higher-efficiency
products, DOE considers technologies and design option combinations not
eliminated by the screening analysis. For each product class, DOE
estimates the baseline cost, as well as the incremental cost for the
product at efficiency levels above the baseline. The output of the
engineering analysis is a set of cost-efficiency ``curves'' that are
used in downstream analyses (i.e., the LCC and PBP analyses and the
NIA).
1. Efficiency Analysis
DOE typically uses one of two approaches to develop energy
efficiency levels for the engineering analysis: (1) relying on observed
efficiency levels in the market (i.e., the efficiency-level approach),
or (2) determining the incremental efficiency improvements associated
with incorporating specific design options to a baseline model (i.e.,
the design-option approach). Using the efficiency-level approach, the
efficiency levels established for the analysis are determined based on
the market distribution of existing products (in other words, based on
the range of efficiencies and efficiency level ``clusters'' that
already exist on the market). Using the design option approach, the
efficiency levels established for the analysis are determined through
detailed engineering calculations and/or computer simulations of the
efficiency improvements from implementing specific design options that
have been identified in the technology assessment. DOE may also rely on
a combination of these two approaches. For example, the efficiency-
level approach (based on actual products on the market) may be extended
using the design option approach to ``gap fill'' levels (to bridge
large gaps between other identified efficiency levels) and/or to
extrapolate to the max-tech level (particularly in cases where the max-
tech level exceeds the maximum efficiency level currently available on
the market).
In this proposed rulemaking, DOE relied on a combination of these
two methods in developing cost estimates at each efficiency level for
dehumidifiers, structured around the reverse engineering approach. For
each product class, DOE analyzed a few units from different
manufacturers to ensure the analysis was representative of various
designs on the market. The analysis involved reviewing publicly
available cost and performance information, physically disassembling
commercially available products and modeling equipment cost while
removing costs associated with non-efficiency related components or
features. From this information, DOE estimated the MPCs for a range of
products currently available on the market. DOE then considered the
incremental steps manufacturers may take to reach higher efficiency
levels. In its modeling, DOE started with the baseline MPC and added
the expected design options at each higher efficiency level to estimate
incremental MPCs. See chapter 5 of the NOPR TSD for additional detail
on the dehumidifiers analyzed.
DOE analyzed six efficiency levels (``ELs'') as part of the
engineering analysis for portable dehumidifiers with capacities less
than or equal to 50 pints/day: (1) the current DOE standard (baseline);
(2) an intermediate level above the baseline but below the ENERGY
STAR[supreg] level, representing units that exist on the market above
the baseline but are not ENERGY STAR units (EL 1); (3) the ENERGY STAR
efficiency criterion (EL 2); (4) the level of the most efficient units
available on the market (EL 3); (5) an intermediate level below the
maximum technologically feasible (max-tech) efficiency that represents
the implementation of more efficient compressors and fan motors on the
market without any changes to the unit chassis (EL 4); and (6) the max-
tech efficiency (EL 5).
For portable dehumidifiers with capacities of 50.01 pints/day and
above, the distribution of efficiencies that are available on the
market and the technology options feasible for this product class
required DOE to analyze different efficiency levels, as follows: (1)
the current DOE standard (baseline); (2) an intermediate level above
the baseline but below the ENERGY STAR level, representing units that
exist on the market above the baseline but are not ENERGY STAR units
(EL 1); (3) the ENERGY STAR efficiency criterion (EL 2); (4) an
intermediate level below max tech that represents the implementation of
more efficient compressors and fan motors on the market (EL 3); and (5)
the max-tech efficiency (EL 4).
For whole-home dehumidifiers with case volumes of 8 cubic feet or
below, likewise, the distribution of efficiencies that are available on
the market and the technology options feasible for this product class
required DOE to analyze different efficiency levels, as follows: (1)
the current DOE standard (baseline); (2) the ENERGY STAR efficiency
criterion (EL 1); (3) an intermediate level below max tech,
representing the level of the most efficient units available on the
market (EL 2); and (4) the max-tech efficiency (EL 3).
For whole-home dehumidifiers with case volumes larger than 8 cubic
feet, likewise, the distribution of efficiencies that are available on
the market and the technology options feasible for this product class
required DOE to analyze different efficiency levels, as follows: (1)
the current DOE standard (baseline); (2) an intermediate level above
the baseline but below the ENERGY STAR level, representing the level of
the most efficient units available on the market
[[Page 76525]]
(EL 1); (3) the ENERGY STAR efficiency criterion (EL 2); (4) an
intermediate level below max tech that represents the implementation of
more efficient compressors and fan motors on the market and some
increase to heat exchanger size relative to EL 2 (EL 3); and (5) the
max-tech efficiency (EL 4).
a. Baseline Efficiency
For each product/equipment 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/equipment class represents
the characteristics of a product/equipment 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.
For representative units for teardowns and the NOPR, DOE selected
three baseline units that fell within two of the five dehumidifier
product classes (Product Class 1 and Product Class 2) as reference
points for each analyzed product class, against which DOE measured
changes that would result from amended energy conservation standards to
support the engineering, LCC, and PBP analyses. Baseline units for two
of the other three product classes (Product Class 3 and Product Class
5) were not readily available on the market for analysis. Additionally,
as discussed in chapter 5 of the preliminary TSD, for whole-home
dehumidifiers with case volumes of 8 cubic feet or less, DOE does not
expect that efficiencies and overall designs have changed since the
previous standards rulemaking, given that the whole-home dehumidifier
standards adopted in the June 2016 Final Rule were the baseline level
at the time. For this reason, DOE did not select additional baseline
units in Product Class 4 for teardown as part of the NOPR analysis.
However, DOE found that higher-efficiency models could provide insight
into technologies that were likely to be implemented in baseline units
to improve efficiency. Therefore, for product classes where baseline
units were not available, DOE estimated the MPC of baseline units by
evaluating which design options would need to be removed from the
higher-efficiency unit analyzed in order to reduce its efficiency to
the baseline level. The baseline units in each of the analyzed product
classes represent the basic characteristics of equipment in that class.
MIAQ stated in response to the June 2022 Preliminary Analysis that
the current energy conservation standards for portable dehumidifier
product classes are not appropriate or in the best interest of the
Nation's energy consumption. According to MIAQ, the jump in baseline
efficiency from 1.60 L/kWh at the 25.01-50.00 pints/day capacity up to
2.80 L/kWh for larger-capacity units is too drastic and would force MPC
and manufacturer selling price (``MSP'') to escalate far above that of
smaller dehumidifiers. According to MIAQ, as consumers purchase
sufficient dehumidifier capacity match the latent load of their
dwelling, this could be through a more expensive, higher-efficiency
dehumidifier at an efficiency of 2.80 L/kWh or through multiple less-
expensive and less-efficient dehumidifiers at an efficiency of 1.30 L/
kWh. MIAQ stated that as MPC and MSP on these two types of units are
drastically different, anecdotal evidence indicates many consumers have
two or more dehumidifiers in their basement or crawlspace consuming
twice the power of a larger unit. Therefore, MIAQ requested that DOE
develop a new set of baseline efficiency levels for portable
dehumidifiers that create more parity in the MPCs and baseline
efficiencies for the product sizes. (MIAQ, No. 20 at pp. 3-4)
As noted, DOE analyzes the changes due to potential energy
conservation standards against the baseline for each product class. DOE
determined in the June 2016 Final Rule that the current standards were
technologically feasible and economically justified for each of the
five dehumidifier product classes (81 FR 38338, 38385-38388), and
models exist on the market at or above the current standard level in
each class. Therefore, DOE has evaluated baseline efficiency levels for
this NOPR analysis that correspond to the current energy conservation
standards for dehumidifiers. DOE notes that units with capacities
larger than 50 pints/day have inherent differences in design from those
with smaller capacities related to the different consumer utility they
provide. The larger dehumidifiers in Product Class 3 provide
dehumidification for large spaces, are more robustly constructed, and
are more efficient due to their greater size and capacity. The smaller
dehumidifiers are intended to dehumidify smaller spaces and provide
consumers with an affordable, lighter-weight, and more compact option
to dehumidify a targeted area. The current energy conservation
standards on which the baseline efficiency levels are based reflect
that consumers derive utility from the greater capacity, efficiency,
and robust construction of larger dehumidifiers and that smaller
dehumidifiers offer utility in the form of their smaller size and lower
cost. These differences in utility are borne out in the design
differences observed between these classes of dehumidifiers, with
larger dehumidifiers implementing more durable materials and larger
heat exchangers. These design differences lead to the cost differential
observed by manufacturers and consumers between larger and smaller
dehumidifiers. DOE developed the higher efficiency levels in each
product class based on the units currently on the market, external
efficiency criteria such as ENERGY STAR, and technological feasibility
of design options to improve dehumidifier efficiency. DOE then
evaluated the economic impacts of potential standards at each of these
efficiency levels, including incremental impacts on MPCs and MSPs in
each product class, as part of the NOPR analysis. DOE is not aware of
and lacks sufficient consumer usage data showing that consumers install
multiple smaller dehumidifiers in the same room instead of purchasing
one larger, more efficient dehumidifier as part of an average period of
use, and therefore did not model any product class switching as a
result of evaluated potential standards.
DOE requests comment regarding consumer's dehumidifier usage
patterns and whether consumers typically purchase multiple smaller
dehumidifiers to meet dehumidification requirements as opposed to a
single, higher capacity dehumidifier.
b. Higher Efficiency Levels
As discussed above, DOE modeled several efficiency levels above the
baseline for dehumidifiers in each product class, using a combination
of design options that varied by product class (for detailed discussion
of the design options used to model each efficiency level, see chapter
5 of the NOPR TSD). 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. At all
of these levels, DOE considered incremental compressor efficiency
improvements as a design option. In the June 2022 Preliminary Analysis,
DOE reviewed compressor manufacturer product catalogues to identify the
maximum technologically feasible R-32 compressor efficiency. However,
based on additional research and input from
[[Page 76526]]
manufacturer interviews, DOE understands that the most efficient
compressors listed in catalogues may not be widely available to all
dehumidifier manufacturers or available at the scale necessary to serve
the dehumidifier market at the anticipated date of compliance of any
new standards. This is especially true for the relatively small
manufacturers that produce dehumidifiers in Product Class 4 and Product
Class 5, given the specialized applications for these products and the
corresponding lower production volumes. To address this concern in the
NOPR analysis, DOE considered incremental compressor efficiency
increases for each product class only up to the highest R-32 single-
speed compressor efficiency observed in the teardown sample in that
class. This change ensures that the higher-efficiency compressors
considered as design options are widely available and technologically
feasible for all dehumidifier manufacturers to implement. As discussed
in chapter 5 of the NOPR TSD, DOE modeled replacing permanent split
capacitor (``PSC'') fan motors with more efficient ECMs, replacing
baseline single-speed compressors with the most efficient single-speed
compressors already available on the market, reducing standby power
using more efficient controls, and increasing the cabinet and heat
exchanger to the largest sizes feasible without impacting consumer
utility to improve efficiency. For all product classes, the max-tech
level identified exceeds any other regulatory or voluntary efficiency
criteria currently in effect.
DOE received the following comments related to the higher
efficiency levels modeled in the preliminary engineering analysis.
AHAM requested that DOE account for additional controls,
specifically variable-frequency drives that are required for ECMs in
the improved fan and fan motor efficiency technology option. According
to AHAM, in addition to the significant cost increase associated with
ECMs being a significant obstacle to widespread adoption in
dehumidifiers, additional controls would only further increase the cost
and require additional space within the product case, potentially
affecting the size and weight of the product. (AHAM, No. 22 at p. 5)
DOE is aware that ECMs require specialized control boards and
additional space within dehumidifier chassis to locate them and
considered this issue as part of the engineering analysis. DOE found
that there is a variable-speed dehumidifier on the market that
implements a variable-speed compressor, and this model has the same
chassis size as another comparable dehumidifier from the same
manufacturer that does not implement the variable-speed components and
functionality. DOE expects that a variable-speed dehumidifier would
have similar control requirements to one that implements ECMs.
Therefore, DOE tentatively finds that the implementation of ECMs for
fan blowers in dehumidifiers does not inherently necessitate a change
in chassis size.
According to AHAM and a survey of its members, employing the
technology options that DOE suggested in the preliminary TSD to meet
the analyzed efficiency levels for Product Classes 1, 2, and 3 would
require significant increases in both model weight and model
dimensions. For Product Classes 1 and 2, AHAM stated that an increase
of up to 30 percent in model weight and up to 59 percent in model
dimensions is required to meet EL 3, and an increase of up to 38
percent in model weight and up to 68 percent in model dimensions is
required to meet EL 4. For Product Class 3, AHAM stated that EL 2 would
require a product redesign and likely an increase in both weight and
dimension by unknown quantities. AHAM also stated that increased
product size and weight associated with implementing the technology
options specified in the preliminary TSD will affect the consumer
utility of dehumidifiers, specifically regarding portability. According
to AHAM, consumers must move or lift dehumidifiers when purchased and
when used in different spaces in their homes. Additionally,
manufacturers design models to meet a 51-pound weight threshold for a
one-person lift, a design parameter that not only reflects consumer
utility but also is a requirement under worker safety standards, parcel
delivery service fee structures, and other distribution requirements
that AHAM stated DOE should consider for all product classes. AHAM
urged DOE to assess impacts on product weight associated with increased
heat exchanger area and added tube rows in the improved condenser and
evaporator performance technology option. According to AHAM, an
increase in weight of the coil section could severely impact consumer
use in existing dehumidifier designs that require lifting the coil
section in order to access the water collection bucket. Additionally,
AHAM stated that its members specifically identified weight increases
associated with this technology option in meeting EL 3 for all product
classes. AHAM requested that DOE assess all potential cost increases
associated with the technology options that increase product size and/
or weight and noted its recommendation for a standard that does not go
beyond EL 2 for Product Class 1, a gap-fill analysis for Product Class
2, and no change in the standard for Product Class 3 to avoid these
negative impacts. (AHAM, No. 22 at pp. 2-5)
In the June 2022 Preliminary Analysis, DOE modeled the efficiency
levels below max-tech mentioned by AHAM by implementing more efficient
compressors without any additional design options. In DOE's assessment,
these higher-efficiency compressors would result in a slight weight
increase but would require no changes to the dehumidifier's chassis
size or any substantive change in overall weight. Additionally, based
on teardowns of other space conditioning products, DOE does not expect
that ECMs are heavier than the PSC motors currently used in
dehumidifiers. However, as AHAM suggested, DOE does expect weight
changes at the max-tech level associated with increasing the heat
exchanger size. DOE accounted for the effect of these weight changes
and changes to chassis size in its analysis of shipping costs, and
limited the maximum increase in heat exchanger size for portable
dehumidifiers in Product Classes 1 and 2 to dimensions already observed
on the market in these product classes to ensure the units analyzed
retained their consumer utility as smaller, portable units. Because
product weight changes due to heat exchanger size increases are
correlated with product dimensions, DOE does not expect that these
weight increases will result in units that are significantly heavier
than those currently on the market, such that any weight increases will
not adversely affect consumer utility. For Product Class 3, DOE's
market analysis suggests that most models in Product Class 3, even at
baseline efficiency, typically weigh roughly between 55 and 70 pounds,
already surpassing the 51-pound weight limit for a single-person lift
mentioned by AHAM. Therefore, Product Class 3 units already require two
people to lift and install, a requirement that would not be altered by
minor increases in chassis size and thus weight. However, a
significantly larger chassis size might become more unwieldy for two
people to lift. Accordingly, DOE limited the heat exchanger dimension
increases considered for Product Class 3 to 5 percent greater than
those observed in product teardowns in order to preclude any adverse
effects on consumer utility.
[[Page 76527]]
DOE further notes that portable dehumidifiers are typically equipped
with wheels that allow consumers to move them from room to room within
the home. While DOE is aware of a dehumidifier design that requires
consumers to lift the coil section to access the water bucket, the
design is not efficiency-related and is proprietary, and therefore DOE
did not consider this design in its analysis. In sum, DOE expects that
the NOPR analysis and any subsequent amended energy conservation
standards would not impact the design, weight, or dimensions of any
dehumidifier significantly, as the required chassis dimensions are
within the scope of those previously observed in dehumidifiers. For
these reasons, in the NOPR analysis DOE continued to consider design
options that increase the weight of dehumidifiers, limited to the
extent discussed by restrictions on the allowable chassis size
increases.
DOE requests comment on whether limiting needed chassis size
increases is sufficient to preserve consumer utility at the max-tech
level.
AHAM stated that while improved compressor efficiency can achieve
higher overall efficiency, changes in compressor technology may require
product redesigns in the form of additional safety components,
particularly with the transition to R-32 refrigerant. According to
AHAM, these additional safety components would make it more difficult
to implement other technology options that will require room within the
product casing. (AHAM, No. 22 at p. 5)
DOE is aware that the EPA's Significant New Alternatives Policy
(``SNAP'') regulations now allow the use of R-32 in new dehumidifiers,
provided that they comply with the relevant industry safety standard
\19\ to ensure new dehumidifiers are designed with the flammability of
R-32 in mind. See 88 FR 26382. However, DOE does not have information
regarding the sorts of design changes necessary to comply with this
standard. See section V.B.2.e of this document for discussion of how
DOE accounts for refrigerant transition costs in its cumulative
regulatory burden analysis.
---------------------------------------------------------------------------
\19\ 3rd edition, dated November 1, 2019, of Underwriters
Laboratories (``UL'') Standard 60335-2-40, ``Household and Similar
Electrical Appliances--Safety--Part 2-40: Particular Requirements
for Electrical Heat Pumps, Air Conditioners and Dehumidifiers''.
---------------------------------------------------------------------------
ASAP and the Joint Commenters encouraged DOE to evaluate at least
one intermediate efficiency level between EL 3 and EL 4 for Product
Classes 1 and 2 to address the large gap in efficiencies due to the
introduction of multiple design options at EL 4. The Joint Commenters
added that DOE could evaluate an intermediate level based on the
highest-efficiency compressors, or one reflecting all design options
except for increases in heat exchanger size. According to the Joint
Commenters, DOE may refer to the April 2022 NOPR for room air
conditioners in which the most efficient single-speed compressors were
associated with an increase in efficiency of 19 to 25 percent relative
to baseline units and an incremental cost of less than $15. (ASAP,
Public Meeting Transcript, No. 19 at pp. 19-20; Joint Commenters, No.
21 at p. 2)
In the June 2022 Preliminary Analysis for Product Classes 1 and 2,
DOE analyzed two efficiency levels above the ENERGY STAR level: the
maximum available efficiency on the market and the max-tech efficiency.
For Product Class 3 and for whole-home dehumidifiers, DOE analyzed the
max-tech efficiency level above the ENERGY STAR level and no other
intermediate levels, because there were no units on the market above
the ENERGY STAR efficiency. While conducting the analysis for this
NOPR, DOE noted the potential to add an efficiency level for all
product classes beyond the maximum available efficiency but below max
tech by using more efficient single-speed compressors and implementing
ECM technology. DOE used these design options to model a new
intermediate efficiency level, EL 4, for all product classes. The new
EL 4 level improves the efficiency by 35 to 63 percent relative to
baseline units with incremental costs between $83 and $119, depending
on product class. See chapter 5 of the NOPR TSD for additional
discussion of the new efficiency levels and incremental costs.
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, and the availability and timeliness of purchasing the product
on the market. The cost approaches are summarized as follows:
[squ] 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.
[squ] Catalog teardowns: In lieu of physically deconstructing a
product, DOE identifies each component using parts diagrams (e.g.,
available from manufacturer websites or appliance repair websites) to
develop the bill of materials for the product.
[squ] Price surveys: If neither a physical nor catalog teardown is
feasible (e.g., for tightly integrated products such as fluorescent
lamps, which are infeasible to disassemble and for which parts diagrams
are unavailable) or is cost-prohibitive and otherwise impractical
(e.g., for large commercial boilers), DOE conducts price surveys using
publicly available pricing data published on major online retailer
websites and/or by soliciting prices from distributors and other
commercial channels.
In the present case, DOE conducted the analysis using physical
teardowns. The resulting bill of materials provides the basis for the
MPC estimates.
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 developed
an average manufacturer markup by examining corporate annual reports
filed by publicly traded manufacturers primarily engaged in appliance
manufacturing and whose combined product range includes dehumidifiers.
See section IV.J.2.d of this document or chapter 12 of the NOPR TSD for
additional information on the manufacturer markup.
In response to June 2022 Preliminary Analysis, MIAQ stated that
although the manufacturer markup of 1.45 used in the preliminary
analysis was historically accurate, it now overstates the current
market situation which is decreasing as costs continue to increase and
are unable to be passed onto the consumer. MIAQ also stated it would be
willing to share information on their current markup for dehumidifiers.
(MIAQ, No. 20 at p. 5)
For this NOPR analysis, DOE adjusted the estimated industry average
manufacturer markup from the 1.45 estimate published in the June 2022
Preliminary Analysis. DOE used market share weights to adjust the
manufacturer markup based on confidential feedback provided in
manufacturer interviews and a review of recent corporate annual reports
by public companies engaged in manufacturing dehumidifiers. DOE
estimates that the industry average manufacturer markup is 1.40 for all
product classes. See section IV.J.2.d of this document and chapter 12
of the NOPR TSD for additional information on the manufacturer markup.
[[Page 76528]]
AHAM stated that implementation of technology options that both
increase product efficiency and product size and/or weight runs counter
to manufacturer efforts to decrease product size and maximize shipping
container space in order to deliver products to consumers in a timely
manner while minimizing added costs due to ongoing supply chain and
logistics issues. AHAM requested that DOE avoid design options that
require increases in size and/or weight for these reasons and requested
that DOE account for these added costs in its analysis. (AHAM, No. 22
at p. 3)
In this NOPR, DOE's analysis includes the impact of changes in
dimensions on overseas container and domestic shipping rates. For
efficiency levels below max-tech, DOE does not find increases in
shipping costs, because chassis size and weight of the units are not
expected to change from the baseline at these efficiency levels. At
max-tech, there are increases in shipping costs due to the expected
increase in chassis size. Additional information about shipping costs
is available in section IV.F.1 of this document and chapter 8 of the
NOPR TSD.
3. Cost-Efficiency Results
The results of the engineering analysis are presented as cost-
efficiency data for each of the efficiency levels for each of the
product classes. DOE developed estimates of MPCs for each unit in the
teardown sample, and also performed additional modeling for each of the
teardown samples, to develop a comprehensive set of MPCs at each
efficiency level. DOE then consolidated the resulting MPCs for each of
DOE's teardown units and modeled units using a weighted average for
product classes in which DOE analyzed units from multiple
manufacturers. DOE's weighting factors were based on a market
penetration analysis for each of the manufacturers within each product
class. The resulting weighted-average incremental MPCs (i.e., the
additional costs manufacturers would likely incur by producing
dehumidifiers at each efficiency level compared to the baseline) are
provided in Tables 5.5.12 and 5.5.13 in chapter 5 of the NOPR TSD. See
chapter 5 of the NOPR TSD for additional detail on the engineering
analysis.
DOE requests comment on the incremental MPCs from the NOPR
engineering analysis.
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. At each step in the distribution channel, companies
mark up the price of the product to cover business costs and profit
margin.
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.\20\
---------------------------------------------------------------------------
\20\ Because the projected prices of standards-compliant
products are 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 in the short term, 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.
---------------------------------------------------------------------------
For portable dehumidifiers with capacities less than or equal to
50.0 pints/day, DOE assumed all sales were through the retail channel.
DOE developed baseline and incremental retail markups using data from
the 2017 Annual Retail Trade Survey for the ``electronics and appliance
stores'' sector.\21\ The whole-home dehumidifier distribution channel
reflects two additional markups to include wholesalers and contractors
used in the purchase of the larger dehumidifiers. DOE developed
wholesaler and contractor markups using U.S. Census Bureau data from
the 2017 Annual Wholesale Trade Report \22\ and the 2017 U.S. Economic
Census,\23\ respectively. For portable dehumidifiers with capacities
greater than 50.00 pints/day, DOE assumed 60 percent of shipments were
through the retail channel, and 40 percent of shipments were through
the whole-home dehumidifier distribution channel based on feedback from
manufacturer interviews.
---------------------------------------------------------------------------
\21\ US Census Bureau, Annual Retail Trade Survey. 2017.
<a href="http://www.census.gov/programs-surveys/arts.html">www.census.gov/programs-surveys/arts.html</a>.
\22\ US Census Bureau, Annual Retail Trade Survey. 2017.
<a href="http://www.census.gov/programs-surveys/arts.html">www.census.gov/programs-surveys/arts.html</a>.
\23\ US Census Bureau, 2017 Economic Census. <a href="http://www.census.gov/programs-surveys/economic-census/year/2017/economic-census-2017/data.html">www.census.gov/programs-surveys/economic-census/year/2017/economic-census-2017/data.html</a>.
---------------------------------------------------------------------------
Chapter 6 of the NOPR TSD provides details on DOE's development of
markups for dehumidifiers.
E. Energy Use Analysis
The purpose of the energy use analysis is to determine the annual
energy consumption of dehumidifiers at different efficiencies in
representative U.S. single-family homes and multi-family residences,
and to assess the energy savings potential of increased dehumidifier
efficiency. The energy use analysis estimates the range of energy use
of dehumidifiers in the field (i.e., as they are actually used by
consumers). The energy use analysis provides the basis for other
analyses DOE performed, particularly assessments of the energy savings
and the savings in consumer operating costs that could result from
adoption of amended or new standards.
DOE used data from the EIA's 2020 Residential Energy Consumption
Survey (``RECS 2020'') \24\ to determine dehumidifier ownership and
usage across the United States. RECS 2020 represents the largest
nationally available dataset of installed residential appliance stock
of dehumidifiers in households (either portable or whole home) as well
as the number of portable units in each household. RECS also provides
dehumidifier usage information in the form of broad categories of
annual usage frequency as reported by the households. DOE estimated
monthly vapor density data for each household that reported owning a
portable dehumidifier by using corresponding outdoor temperature and
humidity information for the year 2020 provided by the National Oceanic
and Atmospheric Administration (NOAA).\25\ DOE used this vapor density
data in conjunction with the annual usage information to estimate the
respective annual operating hours of portable dehumidifiers for each
consumer sample as applicable.
---------------------------------------------------------------------------
\24\ U.S. Department of Energy-Energy Information
Administration. Residential Energy Consumption Survey. 2020.
<a href="http://www.eia.gov/consumption/residential/data/2020/">www.eia.gov/consumption/residential/data/2020/</a>.
\25\ Available at <a href="https://www.ncdc.noaa.gov/cdo-web/datatools/lcd">https://www.ncdc.noaa.gov/cdo-web/datatools/lcd</a>.
---------------------------------------------------------------------------
DOE determined that portable dehumidifiers operated in active
(dehumidification) mode, fan-only mode, and standby mode while whole-
home dehumidifiers operated in active and standby modes only. To
estimate the annual dehumidifier energy consumption, DOE first
calculated the number of operating hours in each mode. For portable
dehumidifiers, DOE used available dehumidifier field
[[Page 76529]]
studies <SUP>26 27</SUP> that provided a relationship between vapor
density and daily operating hours. DOE estimated that portable
dehumidifiers operated in active mode for an average of 1,337 hours
annually. For whole-home dehumidifiers, based on data from the field
study, DOE estimated that, on average, 28 percent of the daily
operating hours were spent in active or dehumidification mode and the
remaining in standby mode. DOE paired these data with estimates of the
number of months that dehumidifiers may be used based on usage behavior
as reported in RECS 2020. DOE estimated that consumers leave the
dehumidifier to cycle on and off for the entire month or months of the
dehumidification season.
---------------------------------------------------------------------------
\26\ Willem, H., T. Burke, C. Dunham, B. Beraki, J. Lutz, M.
Melody, M. Nagaraju, C. Ni, S. Pratt, S. Price, and V. Tavares.
Using Field-Metered Data to Quantify Annual Energy Use of
Residential Portable Unit Dehumidifiers. 2013. Report No. LBNL-
6469e.
\27\ Burke, T. A., H. Willem, C. C. Ni, H. Stratton, C. Dunham
Whitehead, and R. Johnson. Whole-Home Dehumidifiers: Field-
Monitoring Study. 2014. Report No. LBNL-1003950E.
---------------------------------------------------------------------------
MIAQ stated that although dehumidifiers use the same vapor
compression refrigeration cycle as air conditioners, their operation is
much different and the latent load or run time is affected by many
variables. According to MIAQ, consumers typically do not manually
change the mode of operation or settings once a dehumidifier is
installed. (MIAQ, No. 20 at p. 4)
DOE agrees that there are differences in operation between
dehumidifiers and air conditioners. DOE's energy use analysis is based
on dehumidifier field studies that capture real world dehumidifier
operation in a variety of different operating conditions. The studies
used by DOE support MIAQ's assertion that consumers do not manually
change the mode of operation or settings once the dehumidifier is
installed.
MIAQ stated that more than 10 percent of households have more than
one dehumidifier, which indicates that consumers understand they can
purchase two smaller capacity units rather than one large capacity
unit. (MIAQ, No. 20 at p. 4)
Using RECS 2020, DOE estimates that 10.6 percent of portable
dehumidifier-owning households own multiple units, similar to the
estimate provided by MIAQ. DOE adjusted the consumer sample to account
for households with multiple units using the household weights derived
by RECS 2020 and the reported number of portable dehumidifiers in each
household.
Chapter 7 of the NOPR TSD provides details on DOE's energy use
analysis for dehumidifiers.
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
dehumidifiers. 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:
[squ] 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.
[squ] 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 dehumidifiers in the absence of
new or amended energy conservation standards. In contrast, the PBP for
a given efficiency level is 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 U.S.
households. As stated previously, DOE developed household samples from
RECS 2020. For each sample household, DOE determined the energy
consumption for the dehumidifiers 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 dehumidifiers.
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 dehumidifier user samples. The model
calculated the LCC for products at each efficiency level for 10,000
households 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 consumers of dehumidifiers 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 dehumidifiers manufactured 3 years after the date on
which any new or amended standard is published. (42 U.S.C. 6295
(m)(4)(A)) At this time, DOE estimates publication of a final rule in
2025. Therefore, for purposes of its analysis, DOE used 2028 as the
first year of compliance with any amended standards for dehumidifiers.
Table IV.3 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
[[Page 76530]]
chapter 8 of the NOPR TSD and its appendices.
Table IV.4--Summary of Inputs and Methods for the LCC Analysis *
------------------------------------------------------------------------
Inputs Source/method
------------------------------------------------------------------------
Product Costs................ Derived by multiplying MPCs by
manufacturer, retailer, and contractor
markups and sales tax, as appropriate.
Used historical data to derive a price
scaling index to project product costs.
Applied price trend to electronic
controls used on products with variable-
speed blower motors.
Installation Costs........... Baseline installation cost determined
with data from RSMeans. Assumed no
change with efficiency level.
Annual Energy Use............ The total annual energy use derived from
power demand of each mode multiplied by
the hours per year in that mode. Average
number of hours based on field data.
Variability: Based on RECS 2020.
Energy Prices................ Electricity: Based on Edison Electric
Institute data for 2022.
Variability: Regional energy prices
determined for each census division.
Energy Price Trends.......... Based on AEO2023 electricity price
projections from 2022-2050; constant
value based on average of price for 2046-
2050 thereafter.
Repair and Maintenance Costs. Assumed no change with efficiency level.
Product Lifetime............. Weibull probability distribution based on
averages provided from manufacturer
interviews: 10 years for portable
dehumidifiers and 12 years for whole-
home dehumidifiers.
Discount Rates............... Approach involves identifying all
possible debt or asset classes that
might be used to purchase the considered
appliances or that might be affected
indirectly. Primary data source was the
Federal Reserve Board's Survey of
Consumer Finances.
Compliance Date.............. 2028.
------------------------------------------------------------------------
* Not used for PBP calculation. References for the data sources
mentioned in this table are provided in the following sections and 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.
Economic literature and historical data suggest that the real costs
of many products may trend downward over time according to ``learning''
or ``experience'' curves. Experience curve analysis implicitly includes
factors such as efficiencies in labor, capital investment, automation,
materials prices, distribution, and economies of scale at an industry-
wide level. DOE developed two types of experience curves to project the
future dehumidifier prices. One is an overall price trend applied to
the cost of dehumidifier units excluding the cost of electronic
controls used for variable-speed blower fans, and the other is a
separate learning rate associated with the electronic controls used in
units with variable-speed blower fans. To derive the first type of
experience curve for portable dehumidifiers, DOE used historical
Producer Price Index (``PPI'') data between 1983 and 2014 for ``small
electric household appliances, except fans'' and data from the Bureau
of Labor Statistics (``BLS'') \28\ between 2014 and 2022 for ``small
electric household appliances manufacturing'' to construct a combined
price index that is most representative of portable dehumidifiers.
Inflation-adjusted price indices were calculated by dividing the PPI
series by the implicit gross domestic product (``GDP'') price deflator
for the same years. DOE assembled a time series of annual shipments of
portable dehumidifiers from AHAM and Appliance Magazine.\29\ For
efficiency levels that include variable-speed blowers, DOE applied a
different price trend to the controls portion of the variable-speed
blowers that contributes to the price increments moving from single-
speed blower to variable-speed blower. DOE used PPI data between 1967
and 2022 on ``semiconductors and related device manufacturing'' to
estimate the historic price trend of electronic components in the
controls. The regression performed as an exponential trend line fit
results in an R-square of 0.99, with an annual price decline rate of
6.3 percent. DOE applied the same learning parameters for whole-home
dehumidifiers. See chapter 8 of the NOPR TSD for further details on
this topic.
---------------------------------------------------------------------------
\28\ Product series IDs: PCU33521033521014 and PCU335210335210.
More information at <a href="http://www.bls.gov/ppi/">www.bls.gov/ppi/</a>.
\29\ Appliance Magazine. Appliance Historical Statistical
Review: 1954-2012. 2014. UBM Canon.
---------------------------------------------------------------------------
DOE included the cost to internationally ship and domestically
transport dehumidifier units to the United States. DOE calculated
shipping costs for the baseline and for higher efficiency levels that
have larger product dimensions that increase shipping costs.
2. Installation Cost
Installation cost includes labor, overhead, and any miscellaneous
materials and parts needed to install the product. In the June 2022
Preliminary Analysis, DOE assumed that there were no installation costs
for portable dehumidifiers given that consumers were directed by
manufacturer instructions to simply plug them in to a wall outlet for
operation. For whole-home dehumidifiers, DOE used data from RSMeans'
2022 Residential Cost Data to estimate installation costs for baseline
and more efficient units.
For this NOPR, DOE assumed that whole-home dehumidifier
installation costs do not increase with efficiency based on feedback
from manufacturer interviews. DOE used the baseline installation cost
for all efficiency levels for whole-home dehumidifiers. DOE maintained
the assumption of no installation costs for portable dehumidifiers.
DOE seeks available data on installation costs for baseline and
more efficient units.
3. Annual Energy Consumption
For each sampled household, DOE determined the energy consumption
for dehumidifiers at different efficiency levels using the approach
described
[[Page 76531]]
previously in section IV.E of this document.
4. 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.
DOE derived electricity prices in 2022 using data from Edison
Electric Institute (``EEI'') Typical Bills and Average Rates reports.
Based upon comprehensive, industry-wide surveys, this semi-annual
report presents typical monthly electric bills and average kilowatt-
hour costs to the customer as charged by investor-owned utilities. For
the residential sector, DOE calculated electricity prices using the
methodology described in Coughlin and Beraki (2018).\30\ DOE used the
EEI data to define a marginal price as the ratio of the change in the
bill to the change in energy consumption.
---------------------------------------------------------------------------
\30\ Coughlin, K. and B. Beraki. 2018. Residential Electricity
Prices: A Review of Data Sources and Estimation Methods. Lawrence
Berkeley National Laboratory. Berkeley, CA. Report No. LBNL-2001169.
<a href="http://ees.lbl.gov/publications/residential-electricity-prices-review">ees.lbl.gov/publications/residential-electricity-prices-review</a>.
---------------------------------------------------------------------------
To estimate energy prices in future years, DOE multiplied the 2022
energy prices by the projection of annual average price changes for
each of the nine census divisions from the Reference case in AEO2023,
which has an end year of 2050.\31\ To estimate energy prices after
2050, DOE assumed a constant 2050 value for all years.
---------------------------------------------------------------------------
\31\ EIA. Annual Energy Outlook 2023. Washington, DC. Available
at <a href="http://www.eia.gov/forecasts/aeo/">www.eia.gov/forecasts/aeo/</a> (accessed August 21, 2023).
---------------------------------------------------------------------------
5. Maintenance and Repair Costs
Repair costs are associated with repairing or replacing product
components that have failed in an appliance; maintenance costs are
associated with maintaining the operation of the product. Typically,
small incremental increases in product efficiency produce no, or only
minor, changes in repair and maintenance costs compared to baseline
efficiency products.
In the June 2022 Preliminary Analysis, DOE assumed that maintenance
and repair costs would not vary by efficiency level and did not include
them in the LCC analysis.
MIAQ stated that, in general, more efficient dehumidifiers are
typically made with more complex components which potentially increases
the failure probability and the skill level of the technician required
to conduct any repairs. (MIAQ, No. 20 at p. 5)
Feedback from manufacturer interviews (see section IV.J.3 of this
document) indicated that portable dehumidifiers do not require
maintenance costs that would change with efficiency and whole-home
dehumidifier consumers are more likely to replace rather than repair
their units. Based on this feedback, DOE assumed that portable
dehumidifier consumers are also more likely to replace a unit rather
than repair it, similar to whole-home units. For this NOPR analysis,
DOE did not include maintenance or repair costs for portable or whole-
home dehumidifiers. DOE assumes that filter change frequency and cost
would not change with efficiency for each product class. DOE notes that
higher failure rates for units with more complex technology could
potentially indicate a different lifetime for those units. However, DOE
is unaware of any data indicating differences in failure rates based on
the components used in more efficient dehumidifiers.
DOE seeks comment on the assumption that dehumidifier consumers are
most likely to replace a broken unit rather than repair it. DOE also
seeks available data on the filter change and repair frequency and
costs.
6. Product Lifetime
In the June 2022 Preliminary Analysis, DOE assumed a lifetime
distribution with an average age of 11 years for portable
dehumidifiers, based on the June 2016 Final Rule. 81 FR 38338, 38359.
In the absence of data specific to whole-home dehumidifiers, DOE
assumed that whole-home dehumidifiers would have a lifetime
distribution similar to residential packaged central air conditioners
that operate in humid climates. For whole-home dehumidifiers, DOE used
the lifetime distribution with an average lifetime of 18 years from the
Residential Central Air and Heat Pumps Direct Final Rule, published on
January 6, 2017. 82 FR 1786.
MIAQ stated that since dehumidifiers operate under different
conditions than air conditioning equipment, dehumidifiers may have a
shorter average lifetime due to increased freeze/thaw cycling,
corrosion from increased water saturation time, and component failure
from extreme intake air temperatures. MIAQ suggested a shorter 8- to
12-year lifetime as more applicable for dehumidifiers due to these
different conditions. (MIAQ, No. 20 at p. 2)
For this NOPR analysis, DOE has included the estimates from MIAQ
and other feedback from manufacturers in its lifetime distributions.
For portable dehumidifiers, DOE incorporated additional average
lifetime estimates from manufacturers indicating an average lifetime of
10 years. A previous estimate of an average lifetime of 12 years from
the Northeast Energy Star Lighting and Appliance is no longer available
online and thus not included in the lifetime estimates. For whole-home
units, as described by MIAQ, dehumidifiers are subject to different
operating conditions relative to other air conditioning equipment that
could lead to a different average lifetime. For whole-home
dehumidifiers, DOE used an average value of 12 years whole-home
dehumidifiers based on MIAQ's comments.
7. Discount Rates
In the calculation of LCC, DOE applies discount rates appropriate
to households to estimate the present value of future operating cost
savings. DOE estimated a distribution of discount rates for
dehumidifiers based on the opportunity cost of consumer funds.
DOE applies weighted average discount rates calculated from
consumer debt and asset data, rather than marginal or implicit discount
rates.\32\ 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
[[Page 76532]]
aggregate impact of this rebalancing using the historical distribution
of debts and assets.
---------------------------------------------------------------------------
\32\ 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; and 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 triennial Survey of Consumer Finances
\33\ (``SCF'') starting in 1995 and ending in 2019. 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 4.3
percent. See chapter 8 of the NOPR TSD for further details on the
development of consumer discount rates.
---------------------------------------------------------------------------
\33\ U.S. Board of Governors of the Federal Reserve System.
Survey of Consumer Finances. 1995, 1998, 2001, 2004, 2007, 2010,
2013, 2016, and 2019. Available at <a href="http://www.federalreserve.gov/econresdata/scf/scfindex.htm">www.federalreserve.gov/econresdata/scf/scfindex.htm</a> (last accessed February 22, 2023).
---------------------------------------------------------------------------
8. 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 June 2022 Preliminary Analysis, DOE used shipments-weighted
efficiency data submitted by AHAM to estimate the efficiency
distribution for portable dehumidifiers. DOE used these data in
conjunction with the model counts from the Compliance Certification
Database (``CCD'') database to assign market share to efficiency levels
defined in the June 2022 Preliminary Analysis. DOE assumed an annual
efficiency improvement of 0.25 percent to develop the efficiency
distribution in the first year of compliance.
AHAM stated that model counts based on the CCD database are not an
accurate proxy to estimate the efficiency distribution for portable
dehumidifiers. AHAM suggested DOE use shipment-weighted data gathered
from AHAM members. AHAM also noted that data from AHAM members
indicated that 100 percent of shipments for Product Class 3 are at the
baseline efficiency level and the one model in CCD meeting EL 2 is a
whole-home dehumidifier. (AHAM, No. 22 at p. 7)
DOE thanks AHAM for providing shipments-weighted distributions and
has included the data for establishing the efficiency distribution of
portable dehumidifiers in 2022. DOE notes in response to AHAM's note on
current market efficiency distribution that the no-new-standards case
efficiency distribution used in the LCC is the projected efficiency
distribution in the compliance year (2028) and includes the impact of
market efficiency trends. For dehumidifiers, the efficiency trend
employed by DOE is based on historical market trends towards more
efficient products in response to ENERGY STAR criterion updates. The
current ENERGY STAR specification 5.0 criterion were adopted in 2019.
As indicated by ENERGY STAR shipments data, 94 percent of the
dehumidifier market met ENERGY STAR levels in 2021, compared to 88
percent in 2020 and 80 percent in 2019. On October 10, 2023, EPA
released the final recognition criteria for ENERGY STAR Most Efficient
2024, which meet or exceed the proposed standards in all product
classes.\34\ The expected publication of ENERGY STAR specification 6.0
for dehumidifiers in 2024 will likely continue to shift the
dehumidifier market toward more efficient products in the absence of a
standard. To account for this observed historical trend towards a
higher average market efficiency in the absence of a new standard, DOE
included an annual improvement of 0.25 percent in the average shipment-
weighted IEF, based on trends observed for room air conditioners \35\
and also used in the June 2016 Final Rule for dehumidifiers. For whole-
home dehumidifiers, in the absence of shipments-weighted data, DOE has
maintained the approach of using model counts from the CCD database for
the estimation of efficiency distributions and included an annual
improvement of 0.25 percent in average shipment-weighted IEF for the
no-new-standards case.
---------------------------------------------------------------------------
\34\ Available at <a href="https://www.energystar.gov/sites/default/files/asset/document/Dehumidifiers%20ENERGY%20STAR%20Most%20Efficient%202024%20Final%20Criteria.pdf">https://www.energystar.gov/sites/default/files/asset/document/Dehumidifiers%20ENERGY%20STAR%20Most%20Efficient%202024%20Final%20Criteria.pdf</a>.
\35\ Ganeshalingam, M., Ni, C., and Yang, H-C. 2021. A
Retrospective Analysis of the 2011 Direct Final Rule for Room Air
Conditioners. Lawrence Berkeley National Laboratory. LBNL-2001413.
---------------------------------------------------------------------------
DOE seeks data and comment on its efficiency distribution estimate
and the assumption of an annual efficiency improvement of 0.25 percent
and the expected market respond to updated ENERGY STAR 6.0
specifications.
The estimated market shares for the no-new-standards case for
dehumidifiers in 2028 are shown in Tables IV.4 and IV.5. See chapter 8
of the NOPR TSD for further information on the derivation of the
efficiency distributions.
Table IV.5--Market Share of Each Efficiency Level for Portable Dehumidifiers for the No-New-Standards Case in 2028
--------------------------------------------------------------------------------------------------------------------------------------------------------
Product class <=25.00 pints/day 25.01-50.00 pints/day >=50.01 pints/day
--------------------------------------------------------------------------------------------------------------------------------------------------------
Product class market share 19.5% 77.9% 1.1%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Integrated Integrated Integrated
EL energy factor Market share energy factor Market share energy factor Market share
(L/kWh) (%) (L/kWh) (%) (L/kWh) (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 1.30 0 1.60 0 2.80 86
1....................................................... 1.40 25 1.70 0 3.10 14
2....................................................... 1.57 66 1.80 87 3.30 0
3....................................................... 1.70 9 2.01 13 3.51 0
4....................................................... 1.94 0 2.07 0 3.67 0
5....................................................... 2.32 0 2.38 0 .............. ..............
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 76533]]
Table IV.6--Market Share of Each Efficiency Level for Whole-Home Dehumidifiers for the No-New-Standards Case in
2028
----------------------------------------------------------------------------------------------------------------
Product class <=8.0 cu ft case volume >8.0 cu ft case volume
----------------------------------------------------------------------------------------------------------------
Product class market share 1.2% 0.3%
----------------------------------------------------------------------------------------------------------------
Integrated Integrated
EL energy factor Market share energy factor Market share
(L/kWh) (%) (L/kWh) (%)
----------------------------------------------------------------------------------------------------------------
0............................................... 1.77 8 2.41 54
1............................................... 2.09 14 2.70 46
2............................................... 2.22 74 3.30 0
3............................................... 2.39 4 3.81 0
4............................................... .............. .............. 4.17 0
----------------------------------------------------------------------------------------------------------------
The LCC Monte Carlo simulations draw from the efficiency
distributions and randomly assign an efficiency to the dehumidifiers
purchased by each sample household in the no-new-standards case. The
resulting percent shares within the sample match the market shares in
the efficiency distributions.
9. 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.
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.\36\
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 NES and NPV, because operating costs for any
year depend on the age distribution of the stock.
---------------------------------------------------------------------------
\36\ 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.
---------------------------------------------------------------------------
DOE's stock accounting model is calibrated based on historical
shipments for portable and whole-home dehumidifiers. In the June 2022
Preliminary Analysis, DOE used historical shipments provided by AHAM
for portable dehumidifiers and assumed that whole-home dehumidifiers
accounted for 1 percent of total dehumidifier shipments. In this NOPR
analysis, DOE included 2022 shipments estimates for whole-home
dehumidifiers based on feedback from manufacturers indicating whole-
home dehumidifiers shipments account for 1.6 percent of the total
dehumidifier market.
DOE's shipments model for dehumidifiers considers shipments to
replace existing units and to first-time owners. To determine
replacement shipments, DOE used survival probability distributions
based on average lifetime estimates of 10 years for portable
dehumidifiers and 12 years for whole-home dehumidifiers provided by
manufacturers. To estimate shipments to first-time owners, DOE used
projections of AEO2023 housing stock coupled with the historical
shipments data. DOE's shipments projections include shipments
reductions due to consumers that do not replace a failed unit.
DOE considers the impacts on shipments from changes in product
purchase price associated with higher energy efficiency levels using a
price elasticity. As in the June 2022 Preliminary Analysis, DOE employs
a price elasticity of -0.45 in its shipments model. These values are
based on analysis of aggregated data for five residential
appliances.\37\ The market impact is defined as the difference between
the product of price elasticity of demand and the change in price due
to a standard level.
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\37\ Fujita, K. (2015) Estimating Price Elasticity using Market-
Level Appliance Data. Lawrence Berkeley National Laboratory, LBNL-
188289.
---------------------------------------------------------------------------
When comparing the first cost of the efficiency level selected for
PC1 and PC2 at each TSL, DOE considers that the difference of installed
cost in standards case is not significant enough to warrant a product
switching scenario that would result in a different market share
distribution from the no-new-standards case. Given the small overall
market share of PC3, DOE did not include a product switching scenario
in the analysis. DOE assumed that consumers are unlikely to purchase
multiple lower capacity units in place of a larger capacity unit as a
result of a standard.
DOE seeks comment on the assumption that dehumidifier consumers'
purchase decision are unlikely to change as a result of a standard.
H. National Impact Analysis
The NIA assesses the national energy savings (``NES'') and the NPV
from a national perspective of total consumer costs and savings that
would be expected to result from new or amended
[[Page 76534]]
standards at specific efficiency levels.\38\ (``Consumer'' in this
context 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 dehumidifiers sold from 2028 through
2057.
---------------------------------------------------------------------------
\38\ 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.6 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.7--Summary of Inputs and Methods for the National Impact
Analysis
------------------------------------------------------------------------
Inputs Method
------------------------------------------------------------------------
Shipments.............................. Annual shipments from shipments
model.
Compliance Date of Standard............ 2028.
Efficiency Trends...................... No-new-standards case: 0.25
percent annual increase in
efficiency.
Standards cases: Roll-up in
compliance year to meet
potential efficiency level.
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 Unit... Annual values do not change
with efficiency level.
Energy Price Trends.................... AEO2023 projections to 2050 and
constant 2050 value
thereafter.
Energy Site-to-Primary and FFC A time-series conversion factor
Conversion. based on AEO2023.
Discount Rate.......................... 3 percent and 7 percent.
Present Year........................... 2023.
------------------------------------------------------------------------
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. 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 year of anticipated
compliance with an amended or new standard. As described in section
IV.F.8 of this document, the efficiency trend used in the no-new-
standards case is based on historical market trends towards more
efficient product in response to ENERGY STAR specifications. To account
for the historical movement towards more efficient products in the
market in the absence of a standard, DOE included an annual improvement
of 0.25 percent in the average shipment-weighted IEF in each year of
the analysis period shipments projection in the no-new-standards case.
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 (2028). 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.
2. National Energy Savings
The national energy savings analysis involves a comparison of
national energy consumption of the considered products between each 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 AEO 2023. Cumulative energy savings are
the sum of the NES for each year over the timeframe of the analysis.
Use of higher-efficiency products is sometimes 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 find any
data on the rebound effect specific to dehumidifiers and assumed no
rebound in the NOPR analysis.
[[Page 76535]]
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 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 \39\
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.
---------------------------------------------------------------------------
\39\ For more information on NEMS, refer to The National Energy
Modeling System: An Overview 2018, DOE/EIA-0581(2018), April 2019.
Available at <a href="https://www.eia.gov/outlooks/aeo/nems/overview/pdf/0581">https://www.eia.gov/outlooks/aeo/nems/overview/pdf/0581</a>(2018).pdf (last accessed February 22, 2023).
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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
dehumidifier price trends based on historical PPI data. DOE applied the
same trends to project prices for each product class at each considered
efficiency level. By 2057, which is the end date of the projection
period, the average dehumidifier price is projected to drop 25 percent
relative to 2028. DOE's projection of product prices is described in
appendix 10C of the NOPR TSD.
To evaluate the effect of uncertainty regarding the price trend
estimates, DOE investigated the impact of different product price
projections on the consumer NPV for the considered TSLs for
dehumidifiers. In addition to the default price trend, DOE considered
two product price sensitivity cases: (1) a high price decline case and
(2) a low price decline case. In the high price decline case, DOE used
a faster price decline for the non-controls portion of the price
derived from the same combined price index PPI data for dehumidifiers
between 2005 and 2022. In the low price decline case, DOE used the same
combined price index PPI data for dehumidifiers between 1983 and 1998.
For both high and low price decline cases, DOE used the default price
decline for variable-speed blower controls. The derivation of these
price trends and the results of these sensitivity cases are described
in appendix 10C of the NOPR TSD.
The energy cost savings 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 energy price changes in the Reference case from
AEO2023, which has an end year of 2050. To estimate price trends after
2050, the 2050 value was used for all years. As part of the NIA, DOE
also analyzed scenarios that used inputs from variants of the AEO2023
Reference case that have lower and higher economic growth. Those cases
have lower and higher energy price trends compared to the Reference
case. NIA results based on these cases are presented in appendix 10C of
the NOPR TSD.
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.\40\ 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.
---------------------------------------------------------------------------
\40\ United States Office of Management and Budget. Circular A-
4: Regulatory Analysis. September 17, 2003. Section E. Available at
<a href="https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A4/a-4.pdf">https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A4/a-4.pdf</a>.
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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 two subgroups: (1)
low-income households and (2) senior-only households. The analysis used
subsets of the RECS 2020 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 dehumidifiers 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 GRIM, an
industry cash flow model with inputs specific to this proposed
rulemaking.
[[Page 76536]]
The key GRIM inputs
[…truncated; see source link]This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.