Energy Conservation Program: Energy Conservation Standards for Residential Clothes Dryers and Room Air Conditioners, 22454-22564 [2011-9040]
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Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket Number EERE–2007–BT–STD–
0010]
RIN 1904–AA89
Energy Conservation Program: Energy
Conservation Standards for
Residential Clothes Dryers and Room
Air Conditioners
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Direct final rule.
AGENCY:
The Energy Policy and
Conservation Act (EPCA) prescribes
energy conservation standards for
various consumer products and
commercial and industrial equipment,
including residential clothes dryers and
room air conditioners. EPCA also
requires the U.S. Department of Energy
(DOE) to determine if amended
standards for these products are
technologically feasible and
economically justified, and would save
a significant amount of energy. In this
direct final rule, DOE adopts amended
energy conservation standards for
residential clothes dryers and room air
conditioners. A notice of proposed
rulemaking that proposes identical
energy efficiency standards is published
elsewhere in today’s Federal Register. If
DOE receives adverse comment and
determines that such comment may
provide a reasonable basis for
withdrawing the direct final rule, this
final rule will be withdrawn and DOE
will proceed with the proposed rule.
DATES: The final rule is effective on
August 19, 2011 unless adverse
comment is received by August 9, 2011.
If adverse comments are received that
DOE determines may provide a
reasonable basis for withdrawal of the
final rule, a timely withdrawal of this
rule will be published in the Federal
Register. If no such adverse comments
are received, compliance with the
standards in this final rule will be
required on April 21, 2014.
ADDRESSES: Any comments submitted
must identify the direct final rule for
Energy Conservation Standards for
Residential Clothes Dryers and Room
Air Conditioners, and provide docket
number EERE–2007–BT–STD–0010
and/or regulatory information number
(RIN) number 1904–AA89. Comments
may be submitted using any of the
following methods:
1. Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
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SUMMARY:
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2. E-mail: home_appliance2.
rulemaking@ee.doe.gov. Include the
docket number and/or RIN in the
subject line of the message.
3. Mail: Ms. Brenda Edwards, U.S.
Department of Energy, Building
Technologies Program, Mailstop EE–2J,
1000 Independence Avenue, SW.,
Washington, DC 20585–0121. If
possible, please submit all items on a
CD. It is not necessary to include
printed copies.
4. Hand Delivery/Courier: Ms. Brenda
Edwards, U.S. Department of Energy,
Building Technologies Program, 950
L’Enfant Plaza, SW., Suite 600,
Washington, DC 20024. Telephone:
(202) 586–2945. If possible, please
submit all items on a CD. It is not
necessary to include printed copies.
For detailed instructions on
submitting comments and additional
information on the rulemaking process,
see section VII of this document (Public
Participation).
Docket: The docket is available for
review at regulations.gov, including
Federal Register notices, framework
documents, public meeting attendee
lists and transcripts, comments, and
other supporting documents/materials.
All documents in the docket are listed
in the regulations.gov index. Not all
documents listed in the index may be
publicly available, such as information
that is exempt from public disclosure. A
link to the docket web page can be
found at https://www.regulations.gov.
For further information on how to
submit or review public comments or
view hard copies of the docket in the
Resource Room, contact Ms. Brenda
Edwards at (202) 586–2945 or e-mail:
Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT:
Stephen L. Witkowski, U.S. Department
of Energy, Office of Energy Efficiency
and Renewable Energy, Building
Technologies Program, EE–2J, 1000
Independence Avenue, SW.,
Washington, DC 20585–0121, (202)
586–7463, e-mail: stephen.witkowski
@ee.doe.gov.
Ms. Elizabeth Kohl, U.S. Department of
Energy, Office of General Counsel,
GC–71, 1000 Independence Avenue,
SW., Washington, DC 20585–0121,
(202) 586–7796, e-mail: Elizabeth.
Kohl@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Summary of the Direct Final Rule
A. The Energy Conservation Standard
Levels
B. Benefits and Costs to Consumerss
C. Impact on Manufacturers
D. National Benefits
E. Conclusion
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II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for
Residential Clothes Dryers and Room Air
Conditioners
3. Consensus Agreement for Residential
Clothes Dryers and Room Air
Conditioners
III. General Discussion
A. Test Procedures
1. Clothes Dryer Test Procedure
a. Standby Mode and Off Mode
b. Automatic Cycle Termination
c. Ventless Clothes Dryers
d. Consumer Usage Habits
e. Drum Capacity Measurement
f. HVAC Effects
g. Efficiency Metric
2. Room Air Conditioner Test Procedure
a. Standby Mode and Off Mode
b. Active Mode Referenced Standards
c. Annual Active Mode Hours
d. Part-Load Operation
e. Distribution of Air
3. Effects of Test Procedure Revisions on
the Measured Efficiency
a. Clothes Dryers
b. Room Air Conditioners
B. Technological Feasibility
1. General
2. Maximum Technologically Feasible
Levels
a. Clothes Dryers
b. Room Air Conditioners
c. Available Max-Tech Products With
Higher EER Ratings
d. Consideration of Conversion to R–410A
Refrigerant in Max-Tech Selections
C. Energy Savings
1. Determination of Savings
2. Significance of Savings
D. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and
Consumers
b. Life-Cycle Costs
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
A. Market and Technology Assessment
1. General
2. Products Included in This Rulemaking
a. Clothes Dryers
b. Room Air Conditioners
3. Product Classes
a. Clothes Dryers
b. Room Air Conditioners
4. Non-Regulatory Programs
5. Technology Options
a. Clothes Dryers
b. Room Air Conditioners
B. Screening Analysis
1. Clothes Dryers
2. Room Air Conditioners
C. Engineering Analysis
1. Technologies Not Analyzed
a. Clothes Dryers
b. Room Air Conditioners
2. Efficiency Levels and Cost-Efficiency
Results
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a. Clothes Dryers
b. Room Air Conditioners
D. Markups Analysis
E. Energy Use Analysis
1. Clothes Dryers
2. Room Air Conditioners
F. Life-Cycle Cost and Payback Period
Analyses
1. Product Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Energy Price Projections
6. Maintenance and Repair Costs
7. Product Lifetime
8. Discount Rates
a. Residential Discount Rates
b. Commercial Discount Rates
9. Compliance Date of Amended Standards
10. Base Case Efficiency Distribution
11. Inputs to Payback Period Analysis
12. Rebuttable-Presumption Payback
Period
G. National Impact Analysis—National
Energy Savings and Net Present Value
Analysis
1. Shipments
2. Forecasted Efficiency in the Base Case
and Standards Cases
3. National Energy Savings
4. Net Present Value of Consumer Benefit
5. Benefits From Effects of Standards on
Energy Prices
H. Consumer Subgroup Analysis
I. Manufacturer Impact Analysis
1. Overview
a. Phase 1, Industry Profile
b. Phase 2, Industry Cash Flow Analysis
c. Phase 3, Sub-Group Impact Analysis
2. GRIM Analysis
a. GRIM Key Inputs
b. GRIM Scenarios
3. Discussion of Comments
a. Small Businesses
b. Cumulative Regulatory Burden
c. Employment Impacts
4. Manufacturer Interviews
a. Clothes Dryer Key Issues
b. Room Air Conditioner Key Issues
J. Employment Impact Analysis
K. Utility Impact Analysis
L. Environmental Assessment
M. Monetizing Carbon Dioxide and Other
Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Social Cost of Carbon Values Used in
Past Regulatory Analyses
c. Current Approach and Key Assumptions
2. Valuation of Other Emissions
Reductions
V. Analytical Results
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 Sub-Group Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash Flow Analysis Results
b. Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Sub-Groups 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. 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
C. Proposed Standards
1. Benefits and Burdens of TSLs
Considered for Clothes Dryers
2. Benefits and Burdens of TSLs
Considered for Room Air Conditioners
3. Summary of Benefits and Costs
(Annualized) of the Standards
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866
and 13563
B. Review Under the Regulatory Flexibility
Act
1. Residential Clothes Dryer Industry
2. Room Air Conditioner Industry
C. Review Under the Paperwork Reduction
Act
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D. Review Under the National
Environmental Policy Act
E. Review under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates
Reform Act of 1995
H. Review Under the Treasury and General
Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General
Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality
Bulletin for Peer Review
M. Congressional Notification
VII. Public Participation
A. Submission of Comments
VIII. Approval of the Office of the Secretary
I. Summary of the Direct Final Rule
A. The Energy Conservation Standard
Levels
The Energy Policy and Conservation
Act (42 U.S.C. 6291 et seq.; EPCA or the
Act), as amended, provides that any
amended energy conservation standard
DOE prescribes for covered products,
such as residential clothes dryers
(clothes dryers) and room air
conditioners, must be designed to
achieve the maximum improvement in
energy efficiency that is technologically
feasible and economically justified. (42
U.S.C. 6295(o)(2)(A)) Furthermore, the
amended standard must result in a
significant conservation of energy. (42
U.S.C. 6295(o)(3)(B)) In accordance with
these and other statutory provisions
discussed in this notice, DOE adopts
amended energy conservation standards
for clothes dryers and room air
conditioners as shown in Table I–1. The
standards apply to all products listed in
Table I–1 and manufactured in, or
imported into, the United States on or
after April 21, 2014.
TABLE I–1—AMENDED ENERGY CONSERVATION STANDARDS FOR RESIDENTIAL CLOTHES DRYERS AND ROOM AIR
CONDITIONERS
Minimum
CEF levels*
lb/kWh
Product class
Residential Clothes Dryers
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1.
2.
3.
4.
5.
6.
Vented Electric, Standard (4.4 ft3 or greater capacity) ...................................................................................................................
Vented Electric, Compact (120 V) (less than 4.4 ft3 capacity) .......................................................................................................
Vented Electric, Compact (240 V) (less than 4.4 ft3 capacity) .......................................................................................................
Vented Gas ......................................................................................................................................................................................
Ventless Electric, Compact (240 V) (less than 4.4 ft3 capacity) .....................................................................................................
Ventless Electric Combination Washer/Dryer .................................................................................................................................
3.73
3.61
3.27
3.30
2.55
2.08
Minimum
CEER
levels**
Btu/Wh
Product class
Room Air Conditioners
1. Without reverse cycle, with louvered sides, and less than 6,000 Btu/h .........................................................................................
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Minimum
CEER
levels**
Btu/Wh
Product class
2. Without reverse cycle, with louvered sides, and 6,000 to 7,999 Btu/h ..........................................................................................
3. Without reverse cycle, with louvered sides, and 8,000 to 13,999 Btu/h ........................................................................................
4. Without reverse cycle, with louvered sides, and 14,000 to 19,999 Btu/h ......................................................................................
5a. Without reverse cycle, with louvered sides, and 20,000 to 24,999 Btu/h ....................................................................................
5b. Without reverse cycle, with louvered sides, and 25,000 Btu/h or more .......................................................................................
6. Without reverse cycle, without louvered sides, and less than 6,000 Btu/h ....................................................................................
7. Without reverse cycle, without louvered sides, and 6,000 to 7,999 Btu/h .....................................................................................
8a. Without reverse cycle, without louvered sides, and 8,000 to 10,999 Btu/h .................................................................................
8b. Without reverse cycle, without louvered sides, and 11,000 to 13,999 Btu/h ...............................................................................
9. Without reverse cycle, without louvered sides, and 14,000 to 19,999 Btu/h .................................................................................
10. Without reverse cycle, without louvered sides, and 20,000 Btu/h or more ..................................................................................
11. With reverse cycle, with louvered sides, and less than 20,000 Btu/h ..........................................................................................
12. With reverse cycle, without louvered sides, and less than 14,000 Btu/h .....................................................................................
13. With reverse cycle, with louvered sides, and 20,000 Btu/h or more ............................................................................................
14. With reverse cycle, without louvered sides, and 14,000 Btu/h or more .......................................................................................
15. Casement-only ...............................................................................................................................................................................
16. Casement-slider .............................................................................................................................................................................
11.0
10.9
10.7
9.4
9.0
10.0
10.0
9.6
9.5
9.3
9.4
9.8
9.3
9.3
8.7
9.5
10.4
* CEF (Combined Energy Factor) is calculated as the clothes dryer test load weight in pounds divided by the sum of ‘‘active mode’’ per-cycle
energy use and ‘‘inactive mode’’ per-cycle energy use in kWh.
* * CEER (Combined Energy Efficiency Ratio) is calculated as capacity times active mode hours (equal to 750) divided by the sum of active
mode annual energy use and inactive mode.
B. Benefits and Costs to Consumers
Table I–2 presents DOE’s evaluation
of the economic impacts of today’s
standards on consumers of clothes
dryers and room air conditioners, as
measured by the average life-cycle cost
(LCC) savings and the median payback
period. The average LCC savings are
positive for all product classes of
clothes dryers and room air conditioners
for which consumers would be
impacted by the standards.
TABLE I–2—IMPACTS OF TODAY’S STANDARDS ON CONSUMERS OF CLOTHES DRYERS AND ROOM AIR CONDITIONERS
Average
LCC savings
(2009$)
Product class
Median
payback
period
(years)
Clothes Dryers
Electric Standard .....................................................................................................................................................
Compact 120V .........................................................................................................................................................
Compact 240V .........................................................................................................................................................
Gas ..........................................................................................................................................................................
Ventless 240V ..........................................................................................................................................................
Ventless Combination Washer/Dryer ......................................................................................................................
$14
14
8
2
*0
*0
5.3
0.9
0.9
11.7
* n/a
* n/a
7
22
6
1
13
11
8.6
2.8
4.3
10.1
2.1
3.7
Room Air Conditioners
< 6,000 Btu/h, with Louvers .....................................................................................................................................
8,000–13,999 Btu/h, with Louvers ...........................................................................................................................
20,000–24,999 Btu/h, with Louvers .........................................................................................................................
> 25,000 Btu/h, with Louvers ...................................................................................................................................
8,000–10,999 Btu/h, without Louvers ......................................................................................................................
> 11,000 Btu/h, without Louvers ..............................................................................................................................
* Because the standard level is the same as the baseline efficiency level, no consumers are impacted and therefore calculation of a payback
period is not applicable.
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C. Impact on Manufacturers
The industry net present value (INPV)
is the sum of the discounted cash flows
to the industry from the base year
through the end of the analysis period
(2011 to 2043). Using a real discount
rate of 7.2 percent, DOE estimates that
the industry net present value (INPV)
for manufacturers of clothes dryers is
$1,003.6 million in 2009$. Under
today’s standards, DOE expects that
manufacturers may lose 6.4 to 8.0
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percent of their INPV, which is $64.5 to
¥$80.6 million. Additionally, based on
DOE’s interviews with the
manufacturers of clothes dryers, DOE
does not expect any plant closings or
significant loss of employment.
For room air conditioners, DOE
estimates that the INPV for
manufacturers of room air conditioners
is $956 million in 2009$ using a real
discount rate of 7.2 percent. Under
today’s standards, DOE expects that
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manufacturers may lose 11.6 to 18.6
percent of their INPV, which is $111.3
to $177.6 million. Additionally, based
on DOE’s interviews with the
manufacturers of room air conditioners,
DOE does not expect any plant closings
or significant loss of employment.
D. National Benefits
DOE’s analyses indicate that today’s
standards would save a significant
amount of energy over 30 years (2014–
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2043)—an estimated 0.39 quads of
cumulative energy for clothes dryers
and 0.31 quads of cumulative energy for
room air conditioners. The combined
total, 0.70 quads, is equivalent to threefourths of the estimated amount of
energy used in 2008 to dry clothes in all
U.S. homes. In addition, DOE expects
the energy savings from today’s
standards to eliminate the need for
approximately 0.98 gigawatts (GW) of
generating capacity by 2043.
The cumulative national net present
value (NPV) of total consumer costs and
savings of today’s standards in 2009$
ranges from $1.08 billion (at a 7-percent
discount rate) to $3.01 billion (at a 3percent discount rate) for clothes dryers,
and from $0.57 billion (at a 7-percent
discount rate) to $1.47 billion (at a 3percent discount rate) for room air
conditioners. This NPV expresses the
estimated total value of future
operating-cost savings minus the
estimated increased product costs for
products purchased in 2014–2043,
discounted to 2011.
In addition, today’s standards would
have significant environmental benefits.
The energy savings would result in
cumulative greenhouse gas emission
reductions of approximately 36.1
million metric tons (Mt) of carbon
dioxide (CO2) from 2014 to 2043. During
this period, the standards would also
result in emissions reductions 1 of
approximately 29.3 thousand tons of
nitrogen oxides (NOX) and 0.073 ton of
mercury (Hg).2 DOE estimates that the
net present monetary value of the CO2
emissions reductions is between $170
and $2,654 million, expressed in 2009$
and discounted to 2011. DOE also
estimates that the net present monetary
value of the NOX emissions reductions,
expressed in 2009$ and discounted to
2011, is $4.3 to $43.8 million at a
7-percent discount rate, and $8.9 to
$91.7 million at a 3-percent discount
rate.3
1 DOE calculates emissions reductions relative to
the most recent version of the Annual Energy
Outlook (AEO) Reference case forecast. As noted in
section 15.2.4 of TSD chapter 15, this forecast
accounts for regulatory emissions reductions
through 2008, including the Clean Air Interstate
Rule (CAIR, 70 FR 25162 (May 12, 2005)), but not
the Clean Air Mercury Rule (CAMR, 70 FR 28606
(May 18, 2005)). Subsequent regulations, including
the currently proposed CAIR replacement rule, the
Clean Air Transport Rule (75 FR 45210 (Aug. 2,
2010)), do not appear in the forecast.
2 Results for NO and Hg are presented in short
X
tons. One short ton equals 2000 lbs.
3 DOE is aware of multiple agency efforts to
determine the appropriate range of values used in
evaluating the potential economic benefits of
reduced Hg emissions. DOE has decided to await
further guidance regarding consistent valuation and
reporting of Hg emissions before it once again
monetizes Hg emissions reductions in its
rulemakings.
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The benefits and costs of today’s
standards can also be expressed in terms
of annualized values. The annualized
monetary values are the sum of (1) the
annualized national economic value,
expressed in 2009$, of the benefits from
operating the product (consisting
primarily of operating cost savings from
using less energy, minus increases in
equipment purchase costs, which is
another way of representing consumer
NPV, plus (2) the monetary value of the
benefits of emission reductions,
including CO2 emission reductions.4
The value of the CO2 reductions is
otherwise known as the Social Cost of
Carbon (SCC), and is calculated using a
range of values per metric ton of CO2
developed by a recent interagency
process. The monetary benefits of
emissions reductions are reported in
2009$ so that they can be compared
with the other costs and benefits in the
same dollar units. The derivation of the
SCC values is discussed in section IV.M.
Although adding the value of
consumer savings to the values of
emission reductions provides a valuable
perspective, two issues should be
considered. First, the national operating
cost savings are domestic U.S. consumer
monetary savings that occur as a result
of market transactions, while the value
of CO2 reductions is based on a global
value. Second, the assessments of
operating cost savings and the SCC are
performed with different methods that
use quite different timeframes for
analysis. The national operating cost
savings is measured for the lifetime of
products shipped in 2014–2043. The
SCC values, on the other hand, reflect
the present value of future climaterelated impacts resulting from the
emission of one metric ton of carbon
dioxide in each year. These impacts
continue well beyond 2100.
Table I–3 shows the annualized
values for the clothes dryer standards.
Using a 7-percent discount rate and the
SCC value of $22.1/ton in 2010 (in
2009$), the cost of the standards for
clothes dryers in today’s rule is $52.3
4 DOE used a two-step calculation process to
convert the time-series of costs and benefits into
annualized values. First, DOE calculated a present
value in 2011, the year used for discounting the
NPV of total consumer costs and savings, for the
time-series of costs and benefits using discount
rates of three and seven percent for all costs and
benefits except for the value of CO2 reductions. For
the latter, DOE used a range of discount rates, as
shown in Table I.3. From the present value, DOE
then calculated the fixed annual payment over a 30year period, starting in 2011, that yields the same
present value. The fixed annual payment is the
annualized value. Although DOE calculated
annualized values, this does not imply that the
time-series of cost and benefits from which the
annualized values were determined would be a
steady stream of payments.
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million per year in increased equipment
costs, while the annualized benefits are
$139.1 million per year in reduced
equipment operating costs, $25.0
million in CO2 reductions, and $0.9
million in reduced NOX emissions. In
this case, the net benefit amounts to
$112.7 million per year. DOE has
calculated that the annualized increased
equipment cost can range from $50.5 to
$66.6 million per year depending on
assumptions and modeling of
equipment price trends. The high end of
this range corresponds to a constant real
equipment price trend. Using the central
estimate of energy-related benefits, DOE
estimates that calculated net benefits
can range from $98.4 to $114.5 million
per year.
Using a 3-percent discount rate and
the SCC value of $22.1/ton in 2010 (in
2009$), the cost of the standards for
clothes dryers in today’s rule is $55.4
million per year in increased equipment
costs, while the benefits are $209.1
million per year in reduced operating
costs, $25.0 million in CO2 reductions,
and $1.4 million in reduced NOX
emissions. In this case, the net benefit
amounts to $180.1 million per year.
DOE has calculated that the annualized
increased equipment cost can range
from $53.1 to $73.5 million per year
depending on assumptions and
modeling of equipment price trends.
The high end of this range corresponds
to a constant real equipment price trend.
Using the central estimate of energyrelated benefits, DOE estimates that
calculated net benefits can range from
$162.0 to $182.4 million per year.
Table I–4 shows the annualized
values for the room air conditioner
standards. Using a 7-percent discount
rate and the SCC value of $22.1/ton in
2010 (in 2009$), the cost of the
standards for room air conditioners in
today’s rule is $107.7 million per year
in increased equipment costs, while the
annualized benefits are $153.7 million
per year in reduced equipment
operating costs, $19.5 million in CO2
reductions, and $0.999 million in
reduced NOX emissions. In this case, the
net benefit amounts to $66.4 million per
year.
DOE has calculated that the
annualized increased equipment cost
can range from $105.7 to $136.6 million
per year depending on assumptions and
modeling of equipment price trends.
The high end of this range corresponds
to a constant real equipment price trend.
Using the central estimate of energyrelated benefits, DOE estimates that
calculated net benefits can range from
$37.5 to $68.4 million per year.
Using a 3-percent discount rate and
the SCC value of $22.1/ton in 2010 (in
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2009$), the cost of the standards for
room air conditioners in today’s rule is
$111.0 million per year in increased
equipment costs, while the benefits are
$186.2 million per year in reduced
operating costs, $19.5 million in CO2
reductions, and $1.20 million in
reduced NOX emissions. In this case, the
net benefit amounts to $95.9 million per
year DOE has calculated that the range
in the annualized increased equipment
cost can range from $108.0 to $146.0
million per year depending on
assumptions and modeling of
equipment price trends. The high end of
this range corresponds to a constant real
equipment price trend. Using the central
estimate of energy-related benefits, DOE
estimates that calculated net benefits
can range from $60.9 to $98.9 million
per year.
TABLE I–3—ANNUALIZED BENEFITS AND COSTS OF AMENDED STANDARDS (TSL 4) FOR CLOTHES DRYERS SOLD IN
2014–2043
Monetized (million 2009$ year)
Discount rate
Primary estimate *
Low estimate *
High estimate *
120.6
177.4
6.0
25.0
39.8
76.0
0.9
1.4
127.6 to 197.6
146.5
203.7
184.8 to 254.8
158.3
241.3
6.0
25.0
39.8
76.0
0.9
1.4
165.3 to 235.3
184.3
267.6
248.7 to 318.7
66.6
73.5
50.5
53.1
61.0 to 131.0
79.9
130.2
111.3 to 181.3
114.8 to 184.8
133.8
214.5
195.6 to 265.6
Benefits
Operating Cost Savings ...................
CO2 Reduction at $4.9/t ** ...............
CO2 Reduction at $22.1/t ** .............
CO2 Reduction at $36.3/t ** .............
CO2 Reduction at $67.1/t ** .............
NOX Reduction at $2,519/ton ** ......
Total† ........................................
7%
3%
5%
3%
2.5%
3%
7%
3%
7% plus CO2 range
7%
3%
3% plus CO2 range
139.1
209.1
6.0
25.0
39.8
76.0
0.9
1.4
146.1 to 216.1
165.0
235.4
216.5 to 286.5
Costs
Incremental Product Costs# ............
7%
3%
52.3
55.4
Net Benefits
Total† ........................................
7% plus CO2 range
7%
3%
3% plus CO2 range
93.7 to 163.7
112.7
180.1
161.1 to 231.1
* The primary, low, and high estimates utilize forecasts of energy prices and housing starts from the AEO2010 Reference case, Low Economic
Growth case, and High Economic Growth case, respectively. Low estimate corresponds to the low net benefit estimate and uses the zero real
price trend sensitivity for equipment prices, and the high estimate corresponds to the high net benefit estimate and utilizes the high technological
learning rate sensitivity for the equipment price trend.
** The CO2 values represent global values (in 2009$) of the social cost of CO2 emissions in 2010 under several scenarios. The values of $4.9,
$22.1, and $36.3 per metric ton are the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.1 per ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. The
value for NOX (in 2009$) is the average of the low and high values used in DOE’s analysis.
† Total benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 3-percent discount rate, which is
$22.1/ton in 2010 (in 2007$). In the rows labeled as ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are
calculated using the labeled discount rate, and those values are added to the full range of CO2 values.
TABLE I–4—ANNUALIZED BENEFITS AND COSTS OF AMENDED STANDARDS (TSL 4) FOR ROOM AIR CONDITIONERS SOLD
IN 2014–2043
Monetized (million 2009$/year)
Discount rate
Primary estimate *
Low estimate *
High estimate *
145.1
174.2
5.0
19.5
30.7
59.4
0.999
1.197
151.1 to 205.5
165.5
194.9
180.4 to 234.8
161.9
197.3
5.0
19.5
30.7
59.4
0.999
1.197
167.9 to 222.3
182.4
218.0
203.5 to 257.9
Benefits
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Operating Cost Savings ...................
CO2 Reduction at $4.9/t ** ...............
CO2 Reduction at $22.1/t ** .............
CO2 Reduction at $36.3/t ** .............
CO2 Reduction at $67.1/t ** .............
NOX Reduction at $2,519/ton ** ......
Total † .......................................
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7%
3%
5%
3%
2.5%
3%
7%
3%
7% plus CO2 range
7%
3%
3% plus CO2 range
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153.7
186.2
5.0
19.5
30.7
59.4
0.999
1.197
159.6 to 214.0
174.1
206.8
192.3 to 246.7
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TABLE I–4—ANNUALIZED BENEFITS AND COSTS OF AMENDED STANDARDS (TSL 4) FOR ROOM AIR CONDITIONERS SOLD
IN 2014–2043—Continued
Monetized (million 2009$/year)
Discount rate
Primary estimate *
Low estimate *
High estimate *
136.6
146.0
105.7
108.0
43.4 to 97.8
28.9
48.9
34.4 to 88.8
62.2 to 116.6
76.7
110.0
95.5 to 149.9
Costs
Incremental Product Costs ..............
7%
3%
107.7
111.0
Net Benefits
Total† .................................
7% plus CO2 range
7%
3%
3% plus CO2 range
51.9 to 106.3
66.4
95.9
81.4 to 135.8
* The primary, low, and high estimates utilize forecasts of energy prices and housing starts from the AEO2010 Reference case, Low Economic
Growth case, and High Economic Growth case, respectively. Low estimate corresponds to the low net benefit estimate and uses the zero real
price trend sensitivity for equipment prices, while the high estimate corresponds to the high net benefit estimate and utilizes the high technological learning rate sensitivity for the equipment price trend.
** The CO2 values represent global values (in 2009$) of the social cost of CO2 emissions in 2010 under several scenarios. The values of $4.9,
$22.1, and $36.3 per metric ton are the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.1 per ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. The
value for NOX (in 2009$) is the average of the low and high values used in DOE’s analysis.
† Total benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 3-percent discount rate, which is
$22.1/ton in 2010 (in 2009$). In the rows labeled as ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are
calculated using the labeled discount rate, and those values are added to the full range of CO2 values.
E. Conclusion
Based on the analyses culminating in
this final rule, DOE found the benefits
to the nation of the standards (energy
savings, consumer LCC savings, national
NPV increase, and emission reductions)
outweigh the burdens (loss of INPV and
LCC increases for some users of these
products). DOE has concluded that the
standards represent the maximum
improvement in energy efficiency that is
technologically feasible and
economically justified, and would result
in significant conservation of energy.
DOE further notes that clothes dryers
and room air conditioners achieving
these standard levels are already
commercially available.
II. Introduction
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A. Authority
Title III of EPCA sets forth a variety
of provisions designed to improve
energy efficiency. Part B of title III
(42 U.S.C. 6291–6309) provides for the
Energy Conservation Program for
Consumer Products other than
Automobiles.5 The program covers
consumer products and certain
commercial equipment (referred to
hereafter as ‘‘covered products’’),
including clothes dryers and room air
conditioners (42 U.S.C. 6292(a)(2) and
(8)), and the Act prescribes energy
conservation standards for certain
clothes dryers (42 U.S.C. 6295(g)(3)) and
for room air conditioners (42 U.S.C.
5 For editorial reasons, upon codification in the
U.S. Code, Part B was re-designated Part A.
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6295(c)(1)). EPCA further directs DOE to
conduct two cycles of rulemakings to
determine whether to amend these
standards. (42 U.S.C. 6295(c)(2) and
(g)(4)) As explained in further detail in
section II.C, ‘‘Background,’’ this
rulemaking represents the second round
of amendments to both the clothes dryer
and room air conditioner standards.
DOE notes that this rulemaking is one
of the required agency actions in the
consolidated Consent Decree in State of
New York, et al. v. Bodman et al., 05
Civ. 7807 (LAP), and Natural Resources
Defense Council, et al. v. Bodman, et al.,
05 Civ. 7808 (LAP), DOE is required to
complete a final rule for amended
energy conservation standards for room
air conditioners and clothes dryers that
must be sent to the Federal Register by
June 30, 2011.
Under the Act, DOE’s energy
conservation program for covered
products consists essentially of four
parts: (1) Testing, (2) labeling, (3)
Federal energy conservation standards,
and (4) certification and enforcement
procedures. The Federal Trade
Commission (FTC) is responsible for
labeling, and DOE implements the
remainder of the program. The Act
authorizes DOE, subject to certain
criteria and conditions, to develop test
procedures to measure the energy
efficiency, energy use, or estimated
annual operating cost of each covered
product. (42 U.S.C. 6293) Manufacturers
of covered products must use the DOE
test procedure as the basis for certifying
to DOE that their products comply with
applicable energy conservation
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standards adopted under EPCA and for
representing the efficiency of those
products. (42 U.S.C. 6293(c) and
6295(s)) Similarly, DOE must use these
test procedures to determine whether
the products comply with standards
adopted under EPCA. Id. The test
procedures for clothes dryers and room
air conditioners appear at title 10 Code
of Federal Regulations (CFR) part 430,
subpart B, appendices D and F,
respectively.
EPCA provides criteria for prescribing
amended standards for covered
products. As indicated above, any
amended standard for a covered product
must be designed to achieve the
maximum improvement in energy
efficiency that is technologically
feasible and economically justified.
(42 U.S.C. 6295(o)(2)(A)) Furthermore,
EPCA precludes DOE from adopting any
standard that would not result in
significant conservation of energy.
(42 U.S.C. 6295(o)(3)) EPCA also
provides that, in determining whether a
standard is economically justified, DOE
must determine whether the benefits of
the standard exceed its burdens. (42
U.S.C. 6295(o)(2)(B)(i)) DOE must do so
after receiving comments on the
proposed standard and by considering,
to the greatest extent practicable, the
following seven 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
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class) compared to any increase in the
price, initial charges, or maintenance
expenses for the covered products that
are likely to result from the imposition
of the standard;
3. The total projected amount of
energy savings likely to result directly
from the imposition of the standard;
4. Any lessening of the utility or the
performance of the covered products
likely to result from the imposition of
the standard;
5. The impact of any lessening of
competition, as determined in writing
by the Attorney General, that is likely to
result from the imposition of the
standard;
6. The need for national energy
conservation; and
7. Other factors the Secretary
considers relevant. (42 U.S.C.
6295(o)(2)(B)(i)(I)–(VII))
The Energy Independence and
Security Act of 2007 (EISA 2007; Public
Law 110–140) amended EPCA, in
relevant part, to grant DOE authority to
issue a final rule (hereinafter referred to
as a ‘‘direct final rule’’) establishing an
energy conservation standard on receipt
of a statement submitted jointly by
interested persons that are fairly
representative of relevant points of view
(including representatives of
manufacturers of covered products,
States, and efficiency advocates) as
determined by the Secretary, that
contains recommendations with respect
to an energy conservation standard that
are in accordance with the provisions of
42 U.S.C. 6295(o). A notice of proposed
rulemaking (NOPR) that proposes an
identical energy efficiency standard
must be published simultaneously with
the final rule, and DOE must provide a
public comment period of at least
110 days on this proposal. 42 U.S.C.
6295(p)(4). Not later than 120 days after
issuance of the direct final rule, if one
or more adverse comments or an
alternative joint recommendation are
received relating to the direct final rule,
the Secretary must determine whether
the comments or alternative
recommendation may provide a
reasonable basis for withdrawal under
42 U.S.C. 6295(o) or other applicable
law. If the Secretary makes such a
determination, DOE must withdraw the
direct final rule and proceed with the
simultaneously published notice of
proposed rulemaking. DOE must
publish in the Federal Register the
reason why the direct final rule was
withdrawn. Id.
The Consent Decree in State of New
York, et al. v. Bodman et al., described
above, defines a ‘‘final rule’’ to have the
same meaning as in 42 U.S.C. 6295(p)(4)
and defines ‘‘final action’’ as a final
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decision by DOE. As this direct final
rule is issued under authority at
42 U.S.C. 6295(p)(4) and constitutes a
final decision by DOE which becomes
legally effective 120 days after issuance,
absent an adverse comment that leads
the Secretary to withdraw the direct
final rule, DOE asserts that issuance of
this direct final rule on or before the
date required by the court constitutes
compliance with the Consent Decree in
State of New York, et al. v. Bodman et
al.
Furthermore, EPCA contains what is
commonly known as an ‘‘antibacksliding’’ provision, which mandates
that the Secretary not prescribe 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 a new
standard if interested persons have
established by a preponderance of the
evidence that the standard is likely to
result in the unavailability in the United
States of any covered product type (or
class) with performance characteristics,
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))
EPCA also 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 requires DOE to specify a
different standard level than that which
applies generally to a type or class of
products for any group of covered
products that have the same function or
intended use if DOE determines that
products within such group (A)
consume a different kind of energy from
that consumed by other covered
products within such type (or class); or
(B) have a capacity or other
performance-related feature which other
products within such type (or class) do
not have and such feature justifies a
higher or lower standard. (42 U.S.C.
6295(q)(1)) In determining whether a
performance-related feature justifies
such 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
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higher or lower level was established.
(42 U.S.C. 6295(q)(2))
Federal energy conservation
requirements for covered products
generally supersede state laws or
regulations concerning energy
conservation testing, labeling, and
standards. (42 U.S.C. 6297 (a)–(c)) DOE
can, however, grant waivers of Federal
preemption for particular state laws or
regulations, in accordance with the
procedures and other provisions of
section 327(d) of the Act. (42 U.S.C.
6297(d))
EPCA also requires that energy
conservation standards address standby
mode and off mode energy use.
Specifically, when DOE adopts a
standard for a covered product after
July 1, 2010 it must, if justified by the
criteria for adoption of standards in
section 325(o) of EPCA, incorporate
standby mode and off mode energy use
into the standard, if feasible, or adopt a
separate standard for such energy use
for that product. (42 U.S.C. 6295(gg)) As
set forth below, the standards for clothes
dryers and room air conditioners at
10 CFR 430.32 (h) and (b) are minimum
energy factors (EF) and minimum
energy efficiency ratios (EER),
respectively. Neither of these metrics
incorporates standby or off mode energy
use, with the limited exception that the
EF in appendix D addresses the energy
use of pilot lights in gas clothes dryers.
(DOE notes that standing pilot lights
were prohibited by EPCA for products
manufactured after January 1, 1988. As
a result, the final amended test
procedure, published on January 6,
2011, eliminates measurement of the
energy use of such pilot lights.
Similarly, DOE does not incorporate the
energy use of pilot lights in the metric
for gas clothes dryers established in this
final rule.) By contrast, the standard
levels DOE considered in this direct
final rule are expressed in terms of the
‘‘combined energy factor’’ (CEF) for
clothes dryers and the ‘‘combined
energy efficiency ratio’’ (CEER) for room
air conditioners, and each of these
metrics incorporates energy use in all
modes, including the standby and off
modes. DOE uses these metrics in the
standards it adopts in this direct final
rule.
DOE has also reviewed this regulation
pursuant to Executive Order 13563,
issued on January 18, 2011 (76 FR 3281,
Jan. 21, 2011). EO 13563 is
supplemental to and explicitly reaffirms
the principles, structures, and
definitions governing regulatory review
established in Executive Order 12866.
To the extent permitted by law, agencies
are required by Executive Order 13563
to: (1) Propose or adopt a regulation
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Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
only upon a reasoned determination
that its benefits justify its costs
(recognizing that some benefits and
costs are difficult to quantify); (2) tailor
regulations to impose the least burden
on society, consistent with obtaining
regulatory objectives, taking into
account, among other things, and to the
extent practicable, the costs of
cumulative regulations; (3) select, in
choosing among alternative regulatory
approaches, those approaches that
maximize net benefits (including
potential economic, environmental,
public health and safety, and other
advantages; distributive impacts; and
equity); (4) to the extent feasible, specify
performance objectives, rather than
specifying the behavior or manner of
compliance that regulated entities must
adopt; and (5) identify and assess
available alternatives to direct
regulation, including providing
economic incentives to encourage the
desired behavior, such as user fees or
marketable permits, or providing
information upon which choices can be
made by the public.
We emphasize as well that Executive
Order 13563 requires agencies ‘‘to use
the best available techniques to quantify
anticipated present and future benefits
and costs as accurately as possible.’’ In
its guidance, the Office of Information
and Regulatory Affairs has emphasized
that such techniques may include
‘‘identifying changing future compliance
costs that might result from
technological innovation or anticipated
behavioral changes.’’ For the reasons
stated in the preamble, DOE believes
that today’s direct final rule is
consistent with these principles,
including that, to the extent permitted
by law, agencies adopt a regulation only
upon a reasoned determination that its
benefits justify its costs and select, in
choosing among alternative regulatory
approaches, those approaches that
maximize net benefits.
22461
Consistent with EO 13563, and the
range of impacts analyzed in this
rulemaking, the energy efficiency
standard adopted herein by DOE
achieves maximum net benefits.
B. Background
1. Current Standards
In a final rule published on May 14,
1991, DOE prescribed the current
Federal energy conservation standards
for clothes dryers manufactured on or
after May 14, 1994. 56 FR 22250. This
rule completed the first of the two
rulemakings required under 42 U.S.C.
6295(g)(4) to consider amending the
standards for clothes dryers. The current
standards consist of four minimum EFs,
expressed in pounds of clothing load
(lb) per kilowatt-hour (kWh), one for gas
dryers and one each for three different
types of electric dryers. 10 CFR
430.32(h). These standards are set forth
in Table II.1 below.
TABLE II.1—RESIDENTIAL CLOTHES DRYER CURRENT ENERGY CONSERVATION STANDARDS
Product class
EF lb/kWh
Electric, Standard (4.4 cubic feet (ft3) or greater capacity) ....................................................................................................................
Electric, Compact (120 V) (less than 4.4 ft3 capacity) ............................................................................................................................
Electric, Compact (240 V) (less than 4.4 ft3 capacity) ............................................................................................................................
Gas ..........................................................................................................................................................................................................
In a final rule published on
September 24, 1997, DOE prescribed the
current Federal energy conservation
standards for room air conditioners
manufactured on or after October 1,
2000. 62 FR 50122. This rule completed
the first of the two rulemakings required
under 42 U.S.C. 6295(c)(2) to consider
amending the standards for room air
conditioners. The current standards
consist of minimum EERs, expressed as
cooling capacity in British thermal units
(Btu) per hour (h) divided by electrical
input power in watts (W), that vary
3.01
3.13
2.90
2.67
depending on the size of the room air
conditioner, whether it has louvered
sides and a heating cycle, and whether
it is for casement installations. 10 CFR
430.32(b). These standards are set forth
in Table II.2 below.
TABLE II.2—ROOM AIR CONDITIONER CURRENT ENERGY CONSERVATION STANDARDS
EER
Btu/Wh
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Product class
Without reverse cycle, with louvered sides, and less than 6,000 Btu/h .................................................................................................
Without reverse cycle, with louvered sides, and 6,000 to 7,999 Btu/h ...................................................................................................
Without reverse cycle, with louvered sides, and 8,000 to 13,999 Btu/h .................................................................................................
Without reverse cycle, with louvered sides, and 14,000 to 19,999 Btu/h ...............................................................................................
Without reverse cycle, with louvered sides, and 20,000 Btu/h or more .................................................................................................
Without reverse cycle, without louvered sides, and less than 6,000 Btu/h ............................................................................................
Without reverse cycle, without louvered sides, and 6,000 to 7,999 Btu/h ..............................................................................................
Without reverse cycle, without louvered sides, and 8,000 to 13,999 Btu/h ............................................................................................
Without reverse cycle, without louvered sides, and 14,000 to 19,999 Btu/h ..........................................................................................
Without reverse cycle, without louvered sides, and 20,000 Btu/h or more ............................................................................................
With reverse cycle, with louvered sides, and less than 20,000 Btu/h ....................................................................................................
With reverse cycle, without louvered sides, and less than 14,000 Btu/h ...............................................................................................
With reverse cycle, with louvered sides, and 20,000 Btu/h or more ......................................................................................................
With reverse cycle, without louvered sides, and 14,000 Btu/h or more .................................................................................................
Casement-Only ........................................................................................................................................................................................
Casement-Slider ......................................................................................................................................................................................
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9.7
9.8
9.7
8.5
9.0
9.0
8.5
8.5
8.5
9.0
8.5
8.5
8.0
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2. History of Standards Rulemaking for
Residential Clothes Dryers and Room
Air Conditioners
EPCA prescribes energy conservation
standards for clothes dryers and for
room air conditioners, consisting of a
requirement that gas clothes dryers
manufactured after January 1, 1988 not
be equipped with constant burning
pilots and performance standards
(minimum EER levels) for room air
conditioners. (42 U.S.C. 6295(c)(1) and
(g)(3)) These amendments also required,
for both products, that DOE conduct two
cycles of rulemakings to determine
whether to amend these standards. (42
U.S.C. 6295(c)(2) and (g)(4)) As
indicated above, DOE completed the
first of these rulemaking cycles for
clothes dryers in 1991, by adopting
performance standards for gas and
electric products. DOE completed the
first of these rulemaking cycles for room
air conditioners in 1997 by adopting
amended minimum EER levels.
DOE initiated this rulemaking on
October 9, 2007 by publishing a notice
announcing the availability of the
framework document, the ‘‘Energy
Conservation Standards Rulemaking
Framework Document for Residential
Clothes Dryers and Room Air
Conditioners.’’ In this notice, DOE also
announced a public meeting and
requested public comment on the
matters raised in the framework
document. 72 FR 57254 (October 9,
2007). The framework document
describes the procedural and analytical
approaches that DOE anticipated using
to evaluate energy conservation
standards for clothes dryers and room
air conditioners, and identified various
issues to be resolved in conducting this
rulemaking. The framework document
is available at https://
www1.eere.energy.gov/buildings/
appliance_standards/.
DOE held the public meeting on
October 24, 2007 to present the contents
of the framework document, describe
the analyses it planned to conduct
during the rulemaking, seek comments
from interested parties on these
subjects, and, in general, inform
interested parties about, and facilitate
their involvement in, the rulemaking.
Interested parties discussed the
following major issues at the public
meeting: test procedure revisions;
product classes; technology options;
approaches to the engineering, life-cycle
cost, payback period and national
impact analyses; efficiency levels
analyzed in the engineering analysis;
and the approach for estimating typical
energy consumption. At the meeting
and during the period for commenting
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on the framework document, DOE
received many comments that helped it
identify and resolve issues involved in
this rulemaking.
DOE then gathered additional
information and performed preliminary
analyses to help develop potential
energy conservation standards for
clothes dryers and room air
conditioners. This process culminated
in DOE’s announcement of the
availability of its preliminary technical
support document (preliminary TSD)
and another public meeting to discuss
and receive comments on the following
matters: the product classes DOE
planned to analyze; the analytical
framework, models, and tools that DOE
was using to evaluate standards; the
results of the preliminary analyses
performed by DOE; and potential
standard levels that DOE could
consider. 75 FR 7987 (Feb. 23, 2010)
(the February 2010 notice). DOE also
invited written comments on the
preliminary analysis. Id. (The
preliminary TSD is available at https://
www1.eere.energy.gov/buildings/
appliance_standards/residential/
preliminary_analysis_tsd.html.) DOE
also stated its interest in receiving views
concerning other relevant issues that
participants believe would affect energy
conservation standards for clothes
dryers or room air conditioners. Id. at
7990.
The preliminary TSD provided an
overview of the activities DOE
undertook in developing standards for
clothes dryers and room air
conditioners, and discussed the
comments DOE received in response to
the framework document. It also
described the analytical framework that
DOE uses in this rulemaking, including
a description of the methodology, the
analytical tools, and the relationships
among the various analyses that are part
of the rulemaking. The preliminary TSD
presented and described in detail each
analysis DOE performed, including
descriptions of inputs, sources,
methodologies, and results. These
analyses were as follows:
• A market and technology
assessment addressed the scope of this
rulemaking, identified the potential
classes for clothes dryers and room air
conditioners, characterized the markets
for these products, and reviewed
techniques and approaches for
improving their efficiency.
• A screening analysis reviewed
technology options to improve the
efficiency of clothes dryers and room air
conditioners, and weighed these options
against DOE’s four prescribed screening
criteria.
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• An engineering analysis estimated
the manufacturer selling prices (MSPs)
associated with more energy-efficient
clothes dryers and room air
conditioners.
• An energy use analysis estimated
the annual energy use of clothes dryers
and room air conditioners.
• A markups analysis converted
estimated MSPs derived from the
engineering analysis to consumer prices.
• A life-cycle cost analysis calculated,
for individual consumers, the
discounted savings in operating costs
throughout the estimated average life of
each product, compared to any increase
in installed costs likely to result directly
from the imposition of a given standard.
• A payback period (PBP) analysis
estimated the amount of time it takes
individual consumers to recover the
higher purchase expense of more energy
efficient products through lower
operating costs.
• A shipments analysis estimated
shipments of clothes dryers and room
air conditioners over the time period
examined in the analysis, and was used
in performing the national impact
analysis (NIA).
• A national impact analysis assessed
the national energy savings (NES), and
the national net present value of total
consumer costs and savings, expected to
result from specific, potential energy
conservation standards for clothes
dryers and room air conditioners. and
• A preliminary manufacturer impact
analysis (MIA) took the initial steps in
evaluating the effects on manufacturers
of new amended energy conservation
standards.
The public meeting announced in the
February 2010 notice took place on
March 16, 2010. At this meeting, DOE
presented the methodologies and results
of the analyses set forth in the
preliminary TSD. Major topics
discussed at the meeting included test
procedure revisions; product classes
(including ventless clothes dryers);
integrated efficiency levels; the use of
alternate refrigerants in room air
conditioners; engineering analysis tools;
mark-ups; field energy consumption;
life-cycle cost inputs; efficiency
distribution forecasts; national impact
analysis inputs; and trial standard level
selection criteria. DOE also discussed
plans for conducting the NOPR
analyses. The comments received since
publication of the February 2010 notice,
including those received at the March
2010 public meeting, have contributed
to DOE’s proposed resolution of the
issues in this rulemaking. This direct
final rule responds to the issues raised
in the comments received.
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3. Consensus Agreement for Residential
Clothes Dryers and Room Air
Conditioners
In response to the preliminary
analysis, DOE received the ‘‘Agreement
on Minimum Federal Efficiency
Standards, Smart Appliances, Federal
Incentives and Related Matters for
Specified Appliances’’ (the ‘‘Joint
Petition’’), a comment submitted by
groups representing manufacturers (the
Association of Home Appliance
Manufacturers (AHAM), Whirlpool
Corporation (Whirlpool), General
Electric Company (GE), Electrolux, LG
Electronics, Inc. (LG), BSH Home
Appliances (BSH), Alliance Laundry
Systems (ALS), Viking Range, Sub-Zero
Wolf, Friedrich A/C, U-Line, Samsung,
Sharp Electronics, Miele, Heat
Controller, AGA Marvel, Brown Stove,
Haier, Fagor America, Airwell Group,
Arcelik, Fisher & Paykel, Scotsman Ice,
Indesit, Kuppersbusch, Kelon, and
DeLonghi); energy and environmental
advocates (American Council for an
Energy Efficient Economy (ACEEE),
Appliance Standards Awareness Project
(ASAP), Natural Resources Defense
Council (NRDC), Alliance to Save
Energy (ASE), Alliance for Water
Efficiency (AWE), Northwest Power and
Conservation Council (NPCC), and
Northeast Energy Efficiency
Partnerships (NEEP)); and consumer
groups (Consumer Federation of
America (CFA) and the National
Consumer Law Center (NCLC))
(collectively, the ‘‘Joint Petitioners’’).
This collective set of comments, which
DOE refers to in this notice as the ‘‘Joint
Petition’’ 1B 6 or ‘‘Consensus Agreement’’
recommends specific energy
conservation standards for residential
clothes dryers and room air conditioners
that, in the commenters’ view, would
satisfy the EPCA requirements in 42
U.S.C. 6295(o). DOE has considered the
recommended energy conservation
standards in today’s final rule.
After careful consideration of the joint
comment containing a consensus
recommendation for amended energy
conservation standards for clothes
dryers and room air conditioners, the
Secretary has determined that this
‘‘Consensus Agreement’’ has been
submitted by interested persons who are
fairly representative of relevant points
of view on this matter. Congress
provided some guidance within the
statute itself by specifying that
representatives of manufacturers of
6 DOE Docket No. EERE–2007–BT–STD–0010,
Comment 35. DOE considered the Joint Petitioners
comments to supersede earlier comments by the
listed parties regarding issues subsequently
discussed in the Joint Petition.
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covered products, States, and efficiency
advocates are relevant parties to any
consensus recommendation. (42 U.S.C.
6295(p)(4)(A)) As delineated above, the
Consensus Agreement was signed and
submitted by a broad cross-section of
the manufacturers who produce the
subject products, their trade
associations, and environmental,
energy-efficiency and consumer
advocacy organizations. Although States
were not signatories to the Consensus
Agreement, they did not express any
opposition to it. Moreover, DOE does
not read the statute as requiring absolute
agreement among all interested parties
before the Department may proceed
with issuance of a direct final rule. By
explicit language of the statute, the
Secretary has discretion to determine
when a joint recommendation for an
energy or water conservation standard
has met the requirement for
representativeness (i.e., ‘‘as determined
by the Secretary’’). Accordingly, DOE
will consider each consensus
recommendation on a case-by-case basis
to determine whether the submission
has been made by interested persons
fairly representative of relevant points
of view.
Pursuant to 42 U.S.C. 6295(p)(4), the
Secretary must also determine whether
a jointly-submitted recommendation for
an energy or water conservation
standard is in accordance with 42 U.S.C.
6295(o) or 42 U.S.C. 6313(a)(6)(B), as
applicable. This determination is
exactly the type of analysis which DOE
conducts whenever it considers
potential energy conservation standards
pursuant to EPCA. DOE applies the
same principles to any consensus
recommendations it may receive to
satisfy its statutory obligation to ensure
that any energy conservation standard
that it adopts achieves the maximum
improvement in energy efficiency that is
technologically feasible and
economically justified and will result in
significant conservation of energy, Upon
review, the Secretary determined that
the Consensus Agreement submitted in
the instant rulemaking comports with
the standard-setting criteria set forth
under 42 U.S.C. 6295(o). Accordingly,
the consensus agreement levels were
included as TSL 4 in today’s rule for
both clothes dryers and room air
conditioners, the details of which are
discussed at relevant places throughout
this document.
In sum, as the relevant criteria under
42 U.S.C. 6295(p)(4) have been satisfied,
the Secretary has determined that it is
appropriate to adopt amended energy
conservation standards for clothes
dryers and room air conditioners
through this direct final rule
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As required by the same statutory
provision, DOE is also simultaneously
publishing a NOPR which proposes the
identical standard levels contained in
this direct final rule with a 110-day
public comment period. DOE will
consider whether any comment received
during this comment period is
sufficiently ‘‘adverse’’ as to provide a
reasonable basis for withdrawal of the
direct final rule and continuation of this
rulemaking under the NOPR. Typical of
other rulemakings, it is the substance,
rather than the quantity, of comments
that will ultimately determine whether
a direct final rule will be withdrawn. To
this end, the substance of any adverse
comment(s) received will be weighed
against the anticipated benefits of the
Consensus Agreement and the
likelihood that further consideration of
the comment(s) would change the
results of the rulemaking. DOE notes
that to the extent an adverse comment
had been previously raised and
addressed in the rulemaking
proceeding, such a submission will not
typically provide a basis for withdrawal
of a direct final rule.
III. General Discussion
A. Test Procedures
As noted above, DOE’s test
procedures for clothes dryers and room
air conditioners appear at 10 CFR part
430, subpart B, appendices D and F,
respectively. Moreover, EPCA requires
DOE to amend its test procedures for all
covered products, including those for
clothes dryers and room air
conditioners, to include measurement of
standby mode and off mode energy
consumption, except where current test
procedures fully address such energy
consumption or such a procedure is
technically infeasible. (42 U.S.C.
6295(gg)(2)) Because the clothes dryer
and room air conditioner test
procedures previously covered such
energy use only as to pilot lights in gas
dryers (as noted above, the final test
procedure rule eliminates the
measurement of this energy use given
the statutory prohibition), on December
1, 2008 DOE issued a NOPR in which
it proposed revisions of these test
procedures to fully address standby and
off mode energy use and sought
comment on those revisions. 73 FR
74639 (Dec. 9, 2008) (TP NOPR). DOE
also held a public meeting on December
17, 2008 to receive oral comments.
DOE subsequently issued a
supplemental NOPR (SNOPR) in that
rulemaking, in which it (1) addressed
comments received in response to the
TP NOPR; (2) proposed adoption of
certain definitions and calculation
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methods for standby and off mode
energy use; and (3) proposed several
amendments to the clothes dryer and
room air conditioner test procedures
concerning the active modes of these
products. 75 FR 37594 (June 29, 2010)
(TP SNOPR). For air conditioners, these
proposed amendments would update
references to industry test standards. Id.
at 37598. For clothes dryers, DOE
proposed to amend its test procedures
for the active mode by adopting
methods that would allow the testing of
ventless products and would more
accurately account for automatic cycle
termination. Id. at 35798, 35799. DOE
also proposed amendments to reflect the
current usage and capabilities of
products (for example, clothes dryer use
cycles per year, remaining moisture
content (RMC) of clothes dryer loads,
and load sizes), and to update test cloth
preconditioning provisions, eliminate
reference to an obsolete industry test
standard, and clarify the required gas
supply pressure for testing gas clothes
dryers. Id. DOE sought and received
written comments on the TP SNOPR
and also held a public meeting on July
14, 2010 to receive oral comments.
On January 6, 2011, DOE published in
the Federal Register a final rule for the
test procedure rulemaking (76 FR 972)
(TP Final Rule), in which it (1) adopted
the provisions for the measurement of
standby mode and off mode power use
for both products proposed in the TP
NOPR, as modified by the TP SNOPR,
but required that products be installed
and set up for standby and off mode
testing in accordance with
manufacturers’ instructions (and if no
instructions are given, then the
appliance shall be tested at the factory
or ‘‘default’’ settings); and (2) adopted
several amendments to the clothes dryer
and room air conditioner test
procedures concerning the active mode
for these products, as proposed in and
informed by public comment on the TP
SNOPR. 76 FR 972 (January 6, 2011).
Specifically for room air conditioners,
the amendments adopted in the TP
Final Rule updated the references to
industry test standards. Specifically for
clothes dryers, DOE adopted the
amendments to include provisions for
the testing of ventless products
proposed in the TP SNOPR, along with
additional clarifications regarding the
testing conditions for ventless clothes
dryers. 76 FR 976–7. The amendments
also include the following changes to
reflect the current usage and capabilities
of products: (1) Changing the annual
clothes dryer use cycles from 416 to 283
cycle per year, (2) changing the initial
RMC of clothes dryer loads from 70
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percent ± 3.5 percent to 57.5 percent
±3.5 percent, and (3) changing the
clothes dryer test load size from 7.00
pounds (lbs) ± .07 lbs to 8.45 ± .085 lbs
for standard-size clothes dryers. 76 FR
977. The TP Final Rule also amends the
DOE clothes dryer test procedure by
updating test cloth preconditioning
provisions; revising the water
temperature for test load preparation
from 100 degrees Fahrenheit (°F) ± 5 °F
to 60 °F ± 5 °F; updating references to
industry test standards; eliminating
reference to an obsolete industry test
standard; clarifying the required gas
supply conditions for testing gas clothes
dryers; clarifying the provisions for
measuring the drum capacity; clarifying
the definition of ‘‘automatic termination
control’’ for clothes dryers; and adding
the calculations of EF and CEF to 10
CFR part 430, subpart B, appendix D1.
76 FR 978.
DOE did not adopt the amendments to
more accurately measure automatic
cycle termination proposed in the TP
SNOPR. As discussed in the TP Final
Rule, DOE conducted testing of
representative clothes dryers using the
automatic cycle termination test
procedure proposed in the TP SNOPR.
The results showed that all of the
clothes dryers tested significantly overdried the DOE test load to near bone dry
and, as a result, the measured EF values
were significantly lower than EF values
obtained using the existing DOE test
procedure. The test data also indicated
that dryers equipped with automatic
termination controls were less efficient
than timer dryers. 76 FR 977.
As noted in the TP Final Rule, DOE
believes the test procedure amendments
for automatic cycle termination
proposed in the TP SNOPR do not
adequately measure the energy
consumption of clothes dryers equipped
with such systems using the test load
specified in the DOE test procedure.
DOE believes that clothes dryers with
automatic termination sensing control
systems, which infer the RMC of the
load from the properties of the exhaust
air such as temperature and humidity,
may be designed to stop the cycle when
the consumer load has a higher RMC
than the RMC obtained using the
proposed automatic cycle termination
test procedure in conjunction with the
existing test load.7 Manufacturers have
7 To investigate this, DOE conducted additional
testing using a test load similar to that specified in
AHAM Standard HLD–1–2009, which consists of
cotton bed sheets, towels, and pillow cases. For
tests using the same automatic cycle termination
settings as were used in the testing described earlier
(that is, normal cycle setting and highest
temperature setting), the alternate test load was
dried to 1.7 to 2.2 percent final RMC, with an
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indicated, however, that test load types
and test cloth materials different than
those specified in the DOE test
procedure do not produce results as
repeatable as those obtained using the
test load as currenty specified. Id.
In addition, DOE presented data in
the test procedure final rule published
on May 19, 1981 from a field use survey
conducted by AHAM as well as an
analysis of field test data on automatic
termination control dryers conducted by
the National Bureau of Standards (now
known as the National Institute of
Standards and Technology (NIST)).
Analysis of this data showed that
clothes dryers equipped with an
automatic cycle termination feature
consume less energy than timer dryers
by reducing over-drying. 46 FR 27324
(May 19, 1981).
For these reasons, DOE stated in the
TP Final Rule that the test procedure
amendments for automatic cycle
termination proposed in the TP SNOPR
do not adequately measure the energy
consumption of clothes dryers equipped
with such systems. As a result, DOE did
not adopt the amendments for automatic
cycle termination proposed in the TP
SNOPR. 76 FR 972, 977 (January 6,
2011).
The following sections discuss the
comments received in response to the
preliminary analyses regarding the test
procedures for clothes dryers and room
air conditioners.
1. Clothes Dryer Test Procedure
ACEEE and Earthjustice (EJ) both
commented that the DOE test procedure
inadequately represents field energy
use, seriously hindering efforts to
develop effective regulations and sound
public policy, and produces misleading
information for consumers and other
interested parties. (ACEEE, No. 24 at
p. 2; EJ, No. 28 at p. 1) 8 ACEEE
provided suggested test procedure
changes, which are outlined in its
comments and discussed in the sections
below. ACEEE stated these suggested
test procedure changes would improve
the understanding of the overall
contribution of clothes dryers to
national energy consumption, the
average RMC of 2.0 percent. In comparison, the
same clothes dryer under the same cycle settings
dried the DOE test load to 0.3 to 1.2 percent RMC,
with an average RMC of 0.7 percent. Thus, DOE
concluded that the proposed automatic cycle
termination control test procedures may not stop at
an appropriate RMC when used with the current
test load.
8 A notation in the form ‘‘ACEEE, No. 24 at
p. 2’’ identifies a written comment (1) made by the
American Council for an Energy Efficient Economy
(ACEEE), (2) recorded in document number 24 that
is filed in the docket of this rulemaking, and (3)
which appears on page 2 of document number 24.
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relative performance of products
currently on the market, and
opportunities to improve clothes dryer
energy performance (including the
potential of the design options defined
in DOE’s analysis). ACEEE stated that its
suggested test procedure changes would
provide DOE better data for determining
the appropriate level for standards that
yield the maximum cost-effective energy
savings for consumers. (ACEEE, No. 24
at p. 2) Earthjustice commented that
DOE should correct errors in the
existing test procedure that, according
to Earthjustice, misstate the actual
clothes dryer energy consumption, as
identified in the report by ECOS
Consulting (ECOS) (prepared for the
NRDC),9 and recalculate the estimates of
clothes dryer energy use. (EJ, No. 28 at
p. 1) As discussed above, DOE recently
published the TP Final Rule amending
its clothes dryer test procedure to
address many of the test procedure
issues identified by ACEEE and
Earthjustice. DOE addresses each of
these issues individually in the sections
below.
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a. Standby Mode and Off Mode
Referenced Standards
EPCA directs DOE to amend its test
procedures to include measures of
standby mode and off mode energy
consumption. EPCA further directs DOE
to amend the test procedures to
integrate such energy consumption into
a single energy descriptor for that
product. If that is technically infeasible,
DOE must prescribe a separate standby
mode and off mode energy-use test
procedure, if technically feasible. (42
U.S.C. 6295(gg)(2)(A)) Any such
amendment must consider the most
current versions of the International
Electrotechnical Commission (IEC)
Standard 62301 [‘‘Household electrical
appliances—Measurement of standby
power,’’ First Edition 2005–06] and IEC
Standard 62087 [‘‘Methods of
measurement for the power
consumption of audio, video, and
related equipment,’’ Second Edition
2008–09].10 Id.
AHAM supported DOE’s evaluation of
the most current draft version of IEC
Standard 62301 Second Edition, which
at the time of the preliminary analysis
for the standards rulemaking was
designated as the Committee Draft for
Vote (IEC Standard 62301 CDV), for
potential revisions to address standby
9 NRDC,
No. 30 at pp. 1–40.
considered IEC Standard 62087 and
determined that this standard addresses the
methods of measuring the power consumption of
audio, video, and related equipment and is
therefore inapplicable to the products covered in
this rulemaking.
10 DOE
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mode and off mode power in DOE’s
clothes dryer test procedure. AHAM
commented that DOE would thus
harmonize with international standards,
including those used in Canada and
Europe. (AHAM, Public Meeting
Transcript, No. 21.4 at p. 30).11
In the TP NOPR, DOE discussed that
IEC Standard 62301 Second Edition was
expected at that time to be published in
July 2009. For this reason, DOE stated
in the TP NOPR that IEC Standard
62301 First Edition would be the
‘‘current version’’ at the time of
publication of the final rule, so
consideration thereof would comply
with EPCA. DOE incorporated sections
from IEC Standard 62301 First Edition
in the proposed amendments to the
clothes dryer test procedure in the TP
NOPR. 73 FR 74639, 74644 (Dec. 9,
2008). DOE did not receive any
comments in response to the TP NOPR
objecting to the proposed testing
methods and procedures referenced in
IEC Standard 62301 First Edition.
Therefore, the TP SNOPR did not affect
DOE’s proposal in the TP NOPR to
incorporate by reference clauses from
IEC Standard 62301 First Edition. 75 FR
37594, 37602 (June 29, 2010). In the TP
Final Rule, DOE noted that the most
recent draft of IEC Standard 62301
Second Edition, designated as the Final
Draft International Standard (IEC
Standard 62301 FDIS) had yet to be
made available on IEC’s public Web site
and that IEC Standard 62301 Second
Edition is now projected to be issued in
April 2011. For the reasons stated in the
TP Final Rule, DOE amended its test
procedures for clothes dryers in the
final rule to incorporate by reference the
clauses from IEC Standard 62301 First
Edition proposed in the TP SNOPR.
DOE also adopted the definitions of
‘‘active mode,’’ ‘‘standby mode,’’ and ‘‘off
mode’’ based on the language presented
in IEC Standard 62301 CDV. 76 FR 972,
976–977 (January 6, 2011). DOE may
consider incorporating by reference
clauses from IEC Standard 62301
Second Edition when that version has
been published.
11 A notation in the form ‘‘AHAM, Public Meeting
Transcript, No. 21.4 at p. 30’’ identifies an oral
comment that DOE received during the March 16,
2010 public meeting and which was recorded in the
public meeting transcript in the docket for this
rulemaking (Docket No. EE–2007–BT–STD–0010),
maintained in the Resource Room of the Building
Technologies Program. This particular notation
refers to a comment (1) made by the Association of
Home Appliance Manufacturers (AHAM) during the
public meeting, (2) recorded in document number
21.4, which is the public meeting transcript that is
filed in the docket of this rulemaking, and (3) which
appears on page 30 of document number 21.4.
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Testing Procedures
As discussed in the Referenced
Standards section, EPCA directs DOE to
amend the test procedures to integrate
such energy consumption into a single
energy descriptor for that product. If
that is technically infeasible, DOE must
prescribe a separate standby mode and
off mode energy-use test procedure, if
technically feasible. (42 U.S.C.
6295(gg)(2)(A)) In the TP NOPR, DOE
determined that it is technically feasible
to incorporate measures of standby
mode and off mode energy use into the
overall energy use metric. 73 FR 74639,
74650 (Dec. 9, 2008). In the TP NOPR,
DOE proposed to adopt the 140 hours
associated with drying as the active
mode hours and to associate the
remaining 8,620 hours of the year with
standby mode and off mode. 73 FR
74639, 74647 (Dec. 9, 2008). In the TP
NOPR, DOE also proposed definitions
and testing methods for multiple
standby modes, including ‘‘inactive
mode,’’ ‘‘delay start mode,’’ and ‘‘cycle
finished mode.’’ 12 73 FR 74639, 74647–
48 (Dec. 9, 2008). DOE proposed to
calculate clothes dryer energy use per
cycle associated with standby mode and
off mode by (1) calculating the product
of wattage and allocated hours for all
possible standby modes and off modes;
(2) summing the results; (3) dividing the
sum by 1,000 to convert from watt-hours
(Wh) to kWh; and (4) dividing by the
number of cycles per year. 73 FR 74639,
74648 (Dec. 9, 2008). In the TP NOPR,
DOE reported that the comparison of
annual energy use of different clothes
dryer modes showed that delay start and
cycle finished modes represent a
negligible percentage of total annual
energy consumption. The comparison
also showed that the power levels in
these modes are similar to those for
inactive mode and off mode. For these
two reasons, DOE presented an alternate
approach that would be limited to
specifying the hours for only inactive
mode and off mode when calculating
energy use associated with standby
mode and off mode. Under this alternate
approach, all of the non-active mode
hours (8,620) would be allocated to
inactive mode and off mode. 73 FR
74639, 74648 (Dec. 9, 2008).
12 ‘‘Inactive mode’’ is defined as ‘‘a standby mode
other than delay start mode or cycle finished mode
that facilitates the activation of active mode by
remote switch (including remote control), internal
sensor, or provides continuous status display.’’
‘‘Delay start mode’’ is defined as ‘‘a standby mode
that facilitates the activation of active mode by
timer.’’ ‘‘Cycle finished mode’’ is defined as ‘‘a
standby mode that provides continuous status
display following operation in active mode.’’
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In the TP NOPR, DOE proposed to
establish the CEF 13 for clothes dryer to
integrate energy use in the standby
mode and off mode with the energy use
of the main functions of the product.
The CEF would be defined as the
clothes dryer test load weight in pounds
divided by the sum of the per-cycle
standby and off mode energy
consumption and either the total percycle electric dryer energy consumption
or the total per-cycle gas dryer energy
consumption expressed in kWh. 73 FR
74639, 74650 (December 9, 2008).
As discussed in chapter 5 of the
preliminary TSD, for the preliminary
analyses, DOE analyzed the costefficiency relationship for CEF using the
alternative approach for this metric in
the TP NOPR. That approach allocates
all of the non-active mode hours into
inactive mode and off mode energy use,
and then integrates inactive mode and
off mode energy use with active mode
energy use.
BSH commented that, in the formula
to calculate the CEF in the clothes dryer
test procedure, ‘‘8620’’ inactive/off mode
hours should be replaced by (8720—per
cycle duration (hours) × 416 clothes
dryer annual cycles), where 8720 = 365
days × 24 hours per day. According to
BSH, the standby mode is not valid
during the active mode and, therefore,
the duration of the active mode should
be subtracted from the hours per year
when calculating the standby energy
consumption. (BSH, No. 23 at p. 5) DOE
notes that the estimate for active mode
hours presented in the TP NOPR was
fixed based on the number of such
hours specified in the existing test
procedure (140 hours). 73 FR 74646–7
(Dec. 9, 2008). DOE acknowledges that
its estimate of the number of cycles per
year has decreased. As discussed in the
TP Final Rule, DOE notes that changes
to the initial RMC, test load size, and
specified water temperature for test load
preparation may also affect cycle time
and the number of active mode hours
per year. DOE is not aware, however, of
any data indicating that the number of
active mode hours has changed and, if
so, what a more accurate number might
be. Therefore, DOE did not adopt
amendments to the number of active
mode hours in the TP Final Rule. 76 FR
972, 988 (January 6, 2011). For these
reasons, DOE believes that using the 140
13 DOE proposed to use the term ‘‘Integrated
Energy Factor’’ (IEF) in the TP NOPR. 73 FR 74639,
74650 (Dec. 9, 2008). However, in the TP SNOPR,
DOE proposed to revise the name of the metric to
‘‘Combined Energy Factor’’ (CEF) to avoid confusion
with an existing industry standard. 75 FR 37594,
37612 (June 29, 2010). DOE adopted CEF as the
measure of clothes dryer energy efficiency in the TP
Final Rule. 76 FR 972, 992 (January 6, 2011).
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annual active mode hours, as specified
in the existing test procedure, to
determine the number of annual
inactive mode and off mode hour of
8,620, as adopted in the TP Final Rule
(76 FR 990), provides a more
representative estimate of consumer use
than the method suggested by BSH.
b. Automatic Cycle Termination
In the framework document, DOE
stated the clothes dryer test procedure
may not adequately measure the
benefits of automatic cycle termination,
in which a sensor monitors either the
exhaust air temperature or moisture in
the drum to determine the length of the
drying cycle. Currently, the test
procedure provides a single field use
factor for the enhanced performance of
clothes dryers equipped with automatic
termination. This single field use factor
does not distinguish between the type of
sensing control system (for example,
temperature-sensing or moisture-sensing
controls) and the accuracy of the control
system. In chapter 2 of the preliminary
TSD, DOE stated that it agrees that the
effects of automatic cycle termination
should be more accurately measured in
its clothes dryer test procedure, and that
this effect should properly account for
any over- or under-drying. Thus, DOE
noted it was considering clothes dryer
test procedure amendments to address
automatic cycle termination in the
active mode test procedure rulemaking.
In response, interested parties
commented on the following topics
relating to automatic cycle termination.
Definition of Automatic Termination
Control
The Joint Petitioners commented that
DOE should revise section 1.11 of 10
CFR 430 subpart B, appendix D to more
clearly account for electronic controls
by specifying that a preferred automatic
termination control setting can also be
indicated by a visual indicator (in
addition to the mark or detent). The
clarification would read ‘‘* * * mark,
visual indicator or detent which
indicates a preferred * * *’’ (Joint
Petitioners, No. 33 at p. 25) As
discussed in the TP Final Rule, DOE
agreed that a clarification should be
added to the definition of ‘‘automatic
termination control.’’ The clarification
would be that a mark, detent, or other
visual indicator which indicates a
preferred automatic termination control
setting must be present if the dryer is to
be classified as having an automatic
termination control. DOE so revised the
definition in the TP Final Rule. 76 FR
972, 978 (January 6, 2011).
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Testing Procedures
AHAM commented in response to the
preliminary analyses that it continues to
support the use of the automatic
termination field use factor as currently
specified by the DOE clothes dryer test
procedure. AHAM stated that clothes
dryers utilize different algorithms to
determine when the drying cycle should
end, and any evaluation of a different
approach will need to be thoroughly
investigated and should not be based on
DOE test results from four sample units.
AHAM proposed that DOE conduct a
study that evaluates: (1) The accuracy of
the DOE field use factor for today’s
products; and (2) the repeatability and
reproducibility of a procedure where
cycle end is determined by a moisture
or temperature sensor. (AHAM, No. 25
at p. 13)
Whirlpool commented that its testing
showed significant improvement in the
performance of sensors and automatic
termination cycles when using systems
that incorporate sensors that directly
measure the moisture level of the
clothes. Based on these test results,
Whirlpool recommended that an
additional automatic termination factor
be included that would be equal to 1.01
to provide an appropriate field use
factor for clothes dryers that utilize
improved moisture sensor systems.
(Whirlpool, No. 22 at p. 5)
After the publication of the
preliminary analyses, the Joint
Petitioners submitted the Joint Petition,
in which they commented that DOE
should modify the clothes dryer test
procedure to address the effectiveness of
automatic termination controls (for
example, moisture sensor and
temperature sensor controls). (Joint
Petitioners, No. 33 at p. 25) Pacific Gas
& Electric (PG&E), Southern California
Gas Company (SCGC), San Diego Gas
and Electric Company (SDGE), and
Southern California Edison (SCE) jointly
(hereafter the ‘‘California Utilities’’).
NRDC, and NEEP commented that the
current DOE test procedure does not test
the effectiveness of control sensors,
which was found to vary significantly.
(California Utilities, No. 31 at p. 3;
NRDC, No. 26 at pp. 1, 2; NRDC, No. 30
at p. 29; NEEP, No. 27 at p. 3) NRDC,
NEEP, and the California Utilities stated
that the DOE test procedure is
unrealistic and tests only the bulkdrying stage. In addition, by not testing
the high-heat stage (which contributes
very little to drying clothes) and instead
applying a field use factor, the current
test methods overestimate the efficiency
of the clothes dryer. The current test
methods also do not appropriately
measure the energy use of clothes dryers
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that use more effective controls to limit
the energy consumption of the high-heat
stage. (NRDC, No. 26 at pp. 1, 2; NRDC,
No. 30 at p. 29; NEEP, No. 27 at p. 3;
California Utilities, No. 31 at p. 3) NRDC
added that the ECOS report stated that
there is not much variation in efficiency
of the bulk drying stage among different
clothes dryers. However, there are
considerable differences in the energy
consumption of the high-heat stage,
which is not measured by the DOE test
procedure. (NRDC, No. 30 at p. 23) The
ECOS report found that the difference
between a standard clothes dryer and
one that is effective at turning itself off
when clothes are actually dry is about
0.76 kWh per load (5,000 kWh over
typical lifetime). (NRDC, No. 26 at pp.
1, 2) The California Utilities also added
that according to the ECOS report,
clothes dryers, even with the same
sensors, can use very different control
algorithms that result in substantial
variations between clothes dryers in the
length of, and the amount of energy
consumed during, the high-heat stage.
(California Utilities, No. 31 at p. 3)
NRDC commented that DOE should
change its test procedure to measure at
dryness levels less than 5-percent RMC
with logging equipment that provides
data enabling the lab to calculate when
5-percent RMC is reached and how long
the clothes dryer continues to run
thereafter. (NRDC, No. 26 at pp. 1, 2;
NRDC, No. 30 at pp. 29–30) The
California Utilities, ACEEE, and NPCC
also commented that the test procedure
should let the clothes dryer run until
automatic shutoff, allowing the clothes
dryer’s sensors and termination controls
to operate as intended, which would: (1)
Be more representative of actual
consumer behavior and give a better
measure of expected energy use for
consumers; (2) avoid the need for a field
use factor to account for high-heat stage
energy use and instead measure energy
use directly; (3) appropriately measure
the energy use of clothes dryers with
better termination controls and
encourage innovation in these controls;
and (4) make the test procedure easier
because the technician does not need to
keep weighing the clothes. (California
Utilities, No. 31 at pp. 3–4, 12; ACEEE,
No. 24 at pp. 1–2; NPCC, No. 32 at pp.
1–2)
The California Utilities recommended
the following amendments to section
3.3, ‘‘Test cycle’’ of the clothes dryer test
procedure:
• Set the clothes dryer for its
‘‘Normal’’ or ‘‘Cotton’’ cycle. If this in
turn sets a temperature or dryness
control, leave those controls at the
default setting. If a temperature control
must also be set, set it for ‘‘High heat’’
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or ‘‘Cotton.’’ If a dryness control must
also be set, set it for ‘‘Normal dry’’ or
midway between ‘‘More dry’’ and ‘‘Less
dry.’’
• Allow the clothes dryer to run until
its cycle is complete. Promptly remove
and weigh the test load. If it contains 5percent or less RMC, the test cycle is
complete.
• If the test load contains more than
5-percent RMC, return the load to the
clothes dryer and reset the controls. In
this case, the dryness control would
then be set for ‘‘Maximum dry’’ and the
cycle would be run to completion again
and the test load weighed. Repeat if
necessary until the RMC is 5 percent or
less.
• Total the amount of electricity (and
gas if applicable) used during the initial
default cycle and any subsequent cycles.
(California Utilities, No. 31 at p. 4)
The California Utilities also stated
that section 4 of the DOE test procedure
would be modified to remove all
references to the field use factor. That
factor is no longer needed because the
test cycle now represents a typical
consumer use cycle (including both the
bulk-drying and high-heat stages), and
would be omitted from all calculations.
(California Utilities, No. 31 at p. 4) The
California Utilities stated that the
clothes dryers tested for the ECOS
report using the default settings of the
‘‘Normal’’ or ‘‘Cotton’’ cycles all resulted
in RMCs between 0 and 3 percent at the
completion of the clothes dryer cycle.
Therefore, it may be reasonable to
assume that the additional cycles will
rarely be used. The California Utilities
stated that the additional cycles are
included in their proposal to prevent a
manufacturer from creating a default
cycle that saves energy by not actually
getting the clothes adequately dry. The
California Utilities also stated that their
proposed procedure represents the most
likely consumer response to clothes that
did not get dry the first time. (California
Utilities, No. 31 at p. 4)
The California Utilities also
commented that, under their
recommended test procedure changes
for automatic cycle termination, there is
a noticeable difference in energy
consumption between the best and
worst clothes dryers. For clothes dryers
that respond effectively when the
clothes have reached 5-percent RMC by
discontinuing the application of heat
and allowing the residual heat in the
clothes to evaporate the remaining
moisture, the energy measured under
the new test cycle will be very similar
to the energy measured under the
current DOE test procedure, as the
shutoff point will occur near 5-percent
RMC under either test. The California
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Utilities stated that its proposed test
procedure would more accurately
measure the real contribution of
automatic termination controls and
mimic consumer behavior. As a result
there would be no need to use a field
use factor for clothes dryers with
automatic termination controls.
(California Utilities, No. 31 at p. 4)
BSH commented that DOE should test
clothes dryers using the automatically
controlled programs including the cooldown phase. According to BSH, timer
dryers waste energy because consumers
will set a longer drying time than
required to ensure the desired drying
results, resulting in over-drying. BSH
commented that a change in the test
procedure to measure the real final
moisture content for automatically
controlled dryers will show the
differences between competitive clothes
dryers. BSH also commented that the
cool-down phase is, in automatically
controlled dryers, an essential part of
the process to use the energy in the most
efficient way, and that the heat
accumulated in the appliance and the
laundry may be used to finish drying
the laundry and increase the efficiency
of the clothes dryer. (BSH, No. 23 at pp.
4–5)
NRDC commented that the ECOS
report states that newer clothes dryers
are capable of moisture-sensing drying,
but that feature can be (and likely
routinely is being) overridden by
consumers who continue to operate
clothes dryers on a time basis as they
always have. NRDC added that the
ECOS report states that DOE should
require manufacturers to incorporate
moisture sensing into the timed cycle to
ensure that the heating element shuts off
and that airflow is greatly reduced once
the clothes are dry. (NRDC, No. 30 at p.
29)
As discussed above in this section,
DOE proposed amendments to its
clothes dryer test procedure in the TP
SNOPR to more accurately account for
automatic cycle termination. However,
as discussed in the TP Final Rule, DOE
conducted testing on a sample of
representative clothes dryers according
to the amendments to the test procedure
for automatic cycle termination
proposed in the TP SNOPR. The tests
consisted of running the clothes dryer
on a ‘‘normal’’ automatic termination
setting and stopping the clothes dryer
when the heater switches off for the
final time (immediately before the cooldown period begins). Three identical
tests were conducted for each clothes
dryer unit, and the results were
averaged. DOE first noted that not all of
the clothes dryers offered a ‘‘normal’’
cycle setting. For those clothes dryers,
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DOE chose the cycle that would most
closely match a ‘‘normal’’ cycle. The
results of this testing, presented below
in Table III.1, showed that the tested
clothes dryers had a measured EF of
between 12.4 percent and 38.8 percent
lower than the EF measured according
to the current DOE clothes dryer test
procedure. DOE also noted that all of
tested units dried the test load to final
RMCs well below the target RMC of 5
percent, ranging from 0.4 percent to 1.4
percent RMC, with an average of 0.8
percent. DOE also noted that even if the
field use factor for a timer dryer is
applied to the measured EF for a clothes
dryer equipped with automatic cycle
termination, using the current DOE
clothes dryer test procedure (to add the
fixed estimate of over-drying energy
consumption associated with time
termination control dryers), this EF
would still be less than the EF measured
under the automatic cycle termination
test procedure amendments proposed in
the TP SNOPR. 76 FR 972, 999 (January
6, 2011).
TABLE III.1—DOE CLOTHES DRYER AUTOMATIC CYCLE TERMINATION TESTS
Current DOE test
procedure
EF lb/kWh
Test unit
Vented Electric Standard:
Unit 3 ........................................................
Unit 4 ........................................................
Vented Gas:
Unit 8 ........................................................
Unit 9 ........................................................
Unit 11 ......................................................
Vented Electric Compact 240V:
Unit 12 ......................................................
Unit 13 ......................................................
Vented Electric Compact 120V:
Unit 14 ......................................................
Ventless Electric Compact 240V:
Unit 15 ......................................................
Current DOE
test procedure
w/modified
field use
factor *
EF lb/kWh
Proposed automatic cycle
termination test procedure
EF lb/kWh
% Change
Final RMC %
3.20
3.28
2.82
2.89
2.59
2.59
¥19.1
¥21.2
1.0
0.6
2.83
2.85
2.98
2.50
2.51
2.63
2.42
2.38
2.40
¥14.5
¥16.3
¥19.5
0.4
0.9
0.9
3.19
2.93
2.81
2.59
2.64
2.27
¥17.3
¥22.7
0.5
1.4
3.23
2.85
1.98
¥38.8
0.7
2.37
2.09
2.07
¥12.4
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* Field use factor changed from 1.04 for clothes dryers with automatic termination to 1.18 for timer dryers.
In the TP Final Rule, DOE stated that
these test results showed significantly
higher measured energy use for clothes
dryers tested under the DOE test
procedure with the proposed automatic
cycle termination amendments. DOE
evaluated possible reasons for this
difference. DOE concluded that given
the test load specified in the test
procedure,14 the proposed automatic
cycle termination control procedures
may not adequately measure clothes
dryer performance. As discussed in the
previous paragraph, DOE believes that,
although automatic termination control
dryers may be measured as having a
lower efficiency than a comparable
dryer with only time termination
control if tested according to the
proposed test procedure, automatic
termination control dryers may in fact
be drying the clothing to approximately
5-percent RMC in real world use. DOE
believes that automatic termination
control dryers reduce energy
consumption (by reducing over-drying)
compared to timer dryers based on
analysis of the AHAM field use survey
and analysis of field test data conducted
by NIST. 46 FR 27324 (May 19, 1981).
14 The DOE clothes dryer test load is comprised
of 22 in x 34 in pieces of 50/50 cotton/polyesterblend cloth.
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For these reasons, DOE stated in the
TP Final Rule that it believes that the
test procedure amendments for
automatic cycle termination proposed in
the TP SNOPR do not adequately
measure the energy consumption of
clothes dryers equipped with such
systems. As a result, DOE did not adopt
the amendments for automatic cycle
termination proposed in the TP SNOPR.
76 FR 972, 1000 (January 6, 2011). DOE
noted that if data is made available to
develop a test procedure that accurately
measures the energy consumption of
clothes dryers equipped with automatic
termination controls, DOE may consider
revised amendments in a future
rulemaking.
With regard to NRDC’s comment that
DOE should require manufacturers to
incorporate moisture sensing into the
timed cycle, DOE notes that EPCA
defines an energy conservation standard
as either a performance standard or, for
certain products including clothes
dryers, a design requirement. (42 U.S.C.
6291(6)) EPCA also specifies that DOE
may set more than one energy
conservation standard for products that
serve more than one major function by
setting one energy conservation
standard for each major function. (42
U.S.C. 6295(o)(5)) DOE notes the energy
conservation standards for clothes
dryers set forth in this final rule are
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based on drying performance and that
an additional precriptive standard to
require manufacturers to incorporate
moisture sensing into the timed dry
cycle would address the same major
function of the drying performance. For
these reasons, DOE is not adopting an
additional prescriptive requirement for
clothes dryers.
DOE believes that the alternate test
procedure for automatic cycle
termination recommended by the
California Utilities is similar to the test
cycle proposed by DOE in the TP
SNOPR. DOE notes that the California
Utilities’ recommendations would
clarify the settings to be used in cases
where a ‘‘Normal’’ cycle or ‘‘High heat’’
temperature setting was not clearly
specified. DOE does not believe that this
added clarification would resolve the
issues with the proposed automatic
cycle termination test procedure
identified in this section because the
setting used during DOE testing would
be the same under the California
Utilities’ recommendation. In addition,
DOE notes that the California Utilties’
recommendation to specify the ‘‘Normal
dry’’ setting is generally the default
setting under the ‘‘Normal’’ cycle. DOE
also notes that the ‘‘Normal dry’’ setting
was used during its testing, and as a
result this clarification would not
resolve the issues associated with the
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automatic cycle termination test
procedure identified above. Finally,
DOE notes the California Utilities’
recommendation that if the test load
contains more than 5-percent RMC, the
test load would be placed back in the
clothes dryer and the cycle would be
run again using the ‘‘Maximum dry’’
setting is similar to the proposed
amendments in the TP SNOPR.
However, the proposed amendments in
the TP SNOPR would require the test be
re-run from the start using the specified
initial RMC and the ‘‘Maximum dry’’
setting. The California Utilities’
recommendations would require that
the test load with the RMC at the end
of the first test cycle be re-run on a cycle
with the ‘‘Maximum dry’’ setting and the
energy would then be accumulated.
DOE believes that this recommendation
would not resolve the issue of the
significant over-drying observed during
testing because it addresses cases only
in which the test load under-dries. For
these reasons, DOE is not adopting the
alternate test procedure for automatic
cycle termination recommended by the
California Utilities. If DOE considers
adopting test procedure amendments for
automatic cycle termination in a future
rulemaking, it may consider these
recommendations.
Cycle Settings
NRDC commented that the testing
described in the ECOS report showed
that automatic termination cycles using
lower heat settings or lower dryness
level reduce energy consumption and
increase efficiency because less energy
is spent heating air, cloth, and metal.
NRDC commented that the ECOS report
summarized testing results for one
clothes dryer that showed that the
difference in energy consumption
between the highest and lowest heat
settings was 13 percent and that the
drying time increased (from 35 to 49
minutes), but very similar final RMCs
were achieved. (NRDC, No. 30 at p. 22)
NRDC commented that the ECOS report
found that a ‘‘normal dry’’ setting
removed practically all of the water
(producing a final RMC of less than 1
percent), making the ‘‘more dry’’ setting
appear to be unnecessary. The ECOS
report stated that the ‘‘normal dry’’ used
about 12 percent less energy than the
‘‘more dry’’ setting, and the ‘‘less dry’’
setting saved another 18 percent, but
did leave residual moisture in the
clothes. NRDC commented that the
ECOS report added that in all but the
highest humidity climates, the ‘‘less dry’’
setting may be fully adequate and would
give considerable energy savings. Id.
NRDC commented that DOE should
measure the efficiency of different
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clothes dryer settings, in particular the
‘‘more dry’’ setting, which the ECOS
report stated may not be warranted
because the ‘‘normal dry’’ settings
remove effectively all of the moisture.
(NRDC, No. 26 at pp. 1, 3)
As discussed in the previous section,
DOE did not adopt amendments to more
accurately account for automatic cycle
termination in the TP Final Rule.
Therefore DOE did not consider
amendments to the clothes dryer test
procedure to measure the efficiency of
different clothes dryer automatic cycle
termination temperature and dryness
level settings.
Effect of Automatic Cycle Termination
Test Procedure on Measured Energy
Factor
The California Utilities stated that
under their proposed test procedure, the
4 percent field use factor would not be
necessary; therefore removing it would
reduce apparent (reported) energy use
by 4 percent. Instead of EFs from 3.01
to 3.4, these clothes dryers would be
rated at EF from 3.13 to 3.54. According
to the California Utilities, these higher
ratings are appropriate because these
clothes dryers stop quickly and save the
consumer energy under real world
operating conditions. (California
Utilities, No. 31 at pp. 4–5) NRDC
commented that the ECOS report
summarized testing results that showed
that some electronically controlled
dryers could detect the clothes were
already dry and shut down after 5 to 15
minutes, while electromechanically
controlled dryers needed up to 50
minutes before shutting down. (NRDC,
No. 30 at pp. 29–30) The California
Utilities also noted that one clothes
dryer tested in the ECOS report ran for
an additional 30 minutes after reaching
5 percent RMC because of an inefficient
control algorithm and would test with
an EF of about 2.51 under their
proposed test procedure. According to
the California Utilities, this lower rating
would be appropriate, because in real
practice this dryer would significantly
increase clothes dryer energy use.
(California Utilities, No. 31 at p. 5) The
California Utilities commented that a
real savings opportunity exists simply
through an improved test procedure (as
they proposed), which will better
characterize the real-world energy
performance of dryers. The California
Utilities added that dryers that meet the
baseline EF under the current test
procedure but have poor automatic
termination controls will not meet the
same EF under a revised test. Thus,
those dryers will have to improve to
meet the baseline EF of 3.01. The
California Utilities added that, if tested
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using their proposed test procedure, the
least efficient clothes dryers in the
sample of clothes dryers in the ECOS
report will need to increase their
efficiency by 20 percent or more to meet
the current energy conservation
standard. (California Utilities, No. 31 at
p. 5)
As discussed in the Test Procedures
section, DOE did not adopt the
amendments to the clothes dryer test
procedure to better account for
automatic cycle termination that were
proposed in the TP SNOPR. As a result,
DOE is not considering any revisions to
the energy conservation standards based
on the proposed amendments for
automatic cycle termination in the TP
SNOPR. If DOE considers potential
amendments for automatic cycle
termination in a future rulemaking, it
would also consider any necessary
revisions to the energy conservation
standards. In addition, as discussed
above, DOE noted that the alternate test
procedure for automatic cycle
termination recommended by the
California Utilities is similar to the test
cycle proposed by DOE in the TP
SNOPR. As a result, DOE does not
believe the measured EF would be
different between the proposed
amendments in the TP SNOPR and the
California Utilities’ recommendations
except for cases in which the test load
is not dried to below 5-percent RMC. In
this case the California Utilities’
recommendations would require that
the measured energy consumption from
any additional test cycles using the
‘‘Maximum dry’’ setting be added to the
energy consumption from the first test
cycle, whereas the measured efficiency
under the proposed amendments in the
TP SNOPR would be based on only the
re-run test cycle using the ‘‘Maximum
dry’’ setting. However, for the reasons
discussed above, DOE believes that the
California Utilities’ recommendations
would not resolve the issue of the
significant over-drying observed during
DOE testing. As a result, DOE is not
adopting the alternate test procedure for
automatic cycle termination
recommended by the California Utilities
and therefore is not considering any
revisions to the energy conservation
standards based on these
recommendations.
c. Ventless Clothes Dryers
For the reasons discussed in section
IV.A.3.a of this direct final rule, DOE
defines two new product classes in this
rulemaking for ventless clothes dryers.
The clothes dryer test procedure at 10
CFR part 430, subpart B, appendix D is
unable to test ventless clothes dryers,
which include condensing clothes
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dryers as well as combination washer/
dryers. Ventless clothes dryers do not
vent exhaust air to the outside as a
conventional, vented dryer does.
Instead, they typically use ambient air
in a heat exchanger to cool the hot,
humid air inside the appliance, thereby
condensing out the moisture.
Alternatively, cold water can be used in
the heat exchanger to condense the
moisture from the air in the drum. In
either case, the dry air exiting the drum
is reheated and recirculated in a closed
loop. Thus, rather than venting
moisture-laden exhaust air outside,
ventless clothes dryers produce a
wastewater stream that can be either
collected in an included water container
or discharged down the household
drain. The process of condensing out
the moisture in the recirculated air
results in higher energy consumption
than a conventional dryer, and it can
significantly increase the ambient room
temperature.
To address the potential limitation of
the clothes dryer test procedure for
ventless dryers, DOE proposed an
alternate test procedure for ventless
dryers in the TP SNOPR and adopted
this procedure in the TP Final Rule. [75
FR 37594, 37620 (June 29, 2010); 76 FR
972, 976–977 (January 6, 2011)] The
alternate test procedure consists of
adding separate definitions for a
‘‘conventional clothes dryer’’ (vented)
and a ‘‘ventless clothes dryer.’’ Further,
the alternate test procedure qualifies the
requirement for an exhaust simulator so
that it would only apply to conventional
clothes dryers. DOE also adopted
provisions to clarify the testing
procedures for ventless clothes dryers,
including requirements for clothes
dryers equipped with a condensation
box, requirements for the condenser
heat exchanger, and specifications for
ventless clothes dryer preconditioning.
DOE also adopted clarifications in the
TP Final Rule to provide explicit
instructions as to the procedure for rerunning the test cycle when the
condensation box is full. DOE also
revised the requirement for ventless
clothes dryer preconditioning to remove
the maximum time limit for achieving a
steady-state temperature. DOE also
included additional editorial
clarifications to the testing procedures
for ventless clothes dryers. 76 FR 972,
976–977 (January 6, 2011).
In chapter 2 of the preliminary TSD,
prior to adoption of the TP Final Rule,
DOE stated that it was considering
amendments to its clothes dryer test
procedure to allow for the measurement
of the energy efficiency of ventless
clothes dryers in its active mode test
procedure rulemaking.
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The Joint Petitioners commented that
DOE should create a ventless clothes
dryer (including ventless combination
washer/dryer) test procedure to inform
a baseline energy consumption level for
this new product category. (Joint
Petitioners, No. 33 at p. 25)
AHAM suggested that DOE
incorporate language from the alternate
test procedure presented in the LG’s
Petition for Waiver and Denial of the
Application for Interim Waiver (71 FR
49437, 49439 (Aug. 23, 2006)), with the
additional changes that the term
‘‘condensing clothes dryer’’ be changed
to ‘‘ventless clothes dryer’’ and ‘‘HLD–1’’
be changed to ‘‘AHAM HLD–1.’’ AHAM
stated that DOE should validate the
proposed test procedure approach and
the resultant energy consumption values
through a viable statistical method.
AHAM stated that it is not in a position
to provide data on ventless products
due to the small number of products in
the proposed ‘‘compact ventless’’
product class. According to AHAM,
ventless clothes dryers, when tested
using the dryer-centric approach
presented by DOE in the LG Petition for
Waiver, will appear to have higher
energy consumption (kWh per year)
than conventional vented clothes
dryers. (AHAM, No. 25 at p. 4)
Whirlpool commented that its
proposal, which provides amendments
to the DOE test procedure to include
methods for testing of ventless clothes
dryers, improves upon the DOE
proposal for the ventless clothes dryer
test procedure because it takes into
account technical differences between
vented and ventless clothes dryers.15
(Whirlpool, No. 13 at pp. 1–22)
Whirlpool indicated that their proposal
was a draft only and they would be
willing to work with DOE to make
revisions or enhancements to this
proposal. (Whirlpool, No. 22 at p. 1)
In the TP Final Rule, DOE adopted
testing methods for the testing of
ventless clothes dryers based on the
alternate test procedure proposed in the
TP SNOPR; the amendments suggested
by Whirlpool; and additional language
from the internationally accepted test
standards Australia/New Zealand (AS/
NZS) Standard 2442, ‘‘Performance of
household electrical appliances—Rotary
clothes dryers’’ and European Standard
EN 61121, ‘‘Tumble dryers for
household use—Methods for measuring
the performance,’’ Edition 3 2005 (EN
15 Whirlpool’s proposed amendments for ventless
clothes dryers included: (1) Definitions of
‘‘conventional’’ and ‘‘condensing’’ clothes dryers; (2)
installation conditions; (3) requirements for clothes
dryer preconditioning; (4) requirements for
condensation boxes and condenser units; and (5)
requirements for test cycle measurements.
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Standard 61121). 76 FR 972, 976
(January 6, 2011). Also noted in the TP
Final Rule, DOE used the term
‘‘ventless’’ instead of ‘‘condensing,’’ as
suggested by AHAM, to reflect the
actual consumer utility (that is, no
external vent required) because it is
possible that vented dryers that also
condense may become available on the
market. Id. DOE also conducted testing
for the TP Final Rule to evaluate the
repeatability of the amended test
procedure for ventless dryers. As
detailed in the TP Final Rule, ventless
electric compact 240V dryers and
ventless electric combination washer/
dryers showed less than 1 percent
variation and less than 3.5 percent
variation in EF from test to test,
respectively. DOE stated in the TP Final
Rule that it believes that the
amendments for ventless clothes dryers
produce repeatable measurements of EF.
76 FR 972, 1009 (January 6, 2011). DOE
also notes that the measured EF values
for ventless electric compact (240V)
dryers and ventless electric combination
washer/dryers tested according to the
DOE test procedure at appendix D,
using only the amendments for ventless
clothes dryers (2.37 and 2.02,
respectively), are in close agreement
with the baseline values proposed in the
preliminary analyses shown below in
Table IV.15 and Table IV.16. Therefore,
DOE did not revise the baseline EF
levels for the ventless clothes dryer
product classes.
In response to AHAM’s comment that
‘‘HLD–1’’ should be changed to ‘‘AHAM
HLD–1,’’ DOE has adopted this editorial
change in the TP Final Rule. 76 FR 972,
1032 (January 6, 2011).
BSH commented that DOE should
consider the condensation rate for
ventless clothes dryers. BSH added that
the condensation rate efficiency is an
important indicator to measure. (BSH,
No. 23 at p. 4) DOE notes that EN
Standard 61121 provides for a
measurement of the condensation rate
efficiency. However, this measurement
is not used in the calculation of energy
use, which considers only the energy
required to dry the load to a specified
final RMC. However, DOE also notes
that the ability of a ventless clothes
dryer to condense moisture directly
affects the energy use per-cycle. For
example, if a ventless clothes dryer has
a lower condensation efficiency, the air
recirculated into the drum would
contain more moisture and thus would
be able to remove less moisture from the
test load. As a result, the energy use of
such a ventless clothes dryer would be
greater than a ventless clothes dryer
with a higher condensation efficiency
because it would need to run for a
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longer time to condense the same
amount of moisture from the test load.
Therefore, DOE believes that the
condensation efficiency of a ventless
clothes dryer is sufficiently accounted
for in the measurement of the per-cycle
energy consumption. For these reasons,
DOE is not providing for a measurement
of condensation efficiency of a clothes
dryer.
NRDC questioned whether ventless
electric combination washer/dryers are
going to be tested in drying mode only
or as a unit with washing and drying
capability. NRDC stated that, according
to the ECOS report, there is a potential
for energy savings if manufacturers are
allowed to test units together that work
together, because it is more efficient to
manually remove the water than to dry
it. NRDC supported the ECOS report
suggestion that DOE consider a testing
and labeling program based on the total
energy use, cost, and CO2 emissions for
washing and drying a standard load of
clothes. According to the ECOS report
submitted by NRDC, highly efficient
clothes washers greatly decrease the
amount of work that a clothes dryer
needs to do, but that a clothes dryer is
less efficient when drying loads with
lower initial RMCs. (NRDC, Public
Meeting Transcript, No. 21.4 at p. 22;
NRDC, No. 30 at pp. 31–32) Whirlpool
commented that the development of a
test procedure for ventless electric
combination washer/dryers is not worth
the time and resources necessary to
develop it and suggested that DOE not
proceed with such an effort. (Whirlpool,
No. 22 at p. 1) DOE is not aware of
repeatable and representative test
methodologies to accurately measure
the efficiency of a combined wash-dry
cycle. DOE notes that the clothes washer
test procedure requires the
measurement of multiple load sizes
(minimum, maximum, and average
values) as well as multiple cycle settings
and water temperatures, but the clothes
dryer test procedure requires only a
single test load size with a single timed
dry cycle with the highest temperature
setting. DOE is not aware of how the test
load sizes and cycle settings would be
aligned to produce accurate and
representative test results. DOE also
notes that the maximum load size for
the washing portion of the cycle (sized
according to the capacity of the drum),
may be larger than the load size
recommended by manufacturers for the
drying portion of the cycle, and thus it
is not clear what size test load should
be specified for a combined cycle. For
these reasons, DOE is not adopting a test
procedure to measure a full combined
wash-dry cycle. DOE also notes that the
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efficiency of the washer portion of a
combination washer/dryer is covered
under the minimum energy
conservation standards for clothes
washers, and that the TP Final Rule
amended the clothes dryer test
procedure to include methods for
measuring the energy use of the drying
portion of a combination washer/dryer.
d. Consumer Usage Habits
Annual Cycles
DOE published a final rule on August
27, 1997, amending the DOE clothes
washer test procedure to lower the
annual clothes washer use cycle value
from 416 to 392 cycles per year, a value
DOE determined to be more
representative of current usage patterns.
62 FR 45484. Further, the revised DOE
clothes washer test procedure assumes
that 84 percent of all clothes washer
loads are dried in clothes dryers. Thus,
the annual usage pattern for clothes
dryers would be 329 cycles per year. In
addition, in the recently proposed
amendments to the clothes washer test
procedure, DOE proposed to amend the
number of cycles per year to 295. 75 FR
57556, 57564 (Sept. 21, 2010). In
contrast, the current DOE residential
clothes dryer test procedure in appendix
D assumes an average annual clothes
dryer use of 416 cycles per year. (10
CFR 430.23(d)(1))
DOE stated in chapter 2 of the
preliminary TSD that it was reviewing
available data on the number of annual
clothes dryer cycles, and would
consider amendments to its test
procedure to accurately reflect the
number of annual clothes dryer cycles
for the clothes dryer tests.
The Joint Petitioners and ACEEE
commented that DOE should update the
number of clothes dryer cycles per year
based on the best available data (ideally
based on a nationally representative
sample). (Joint Petitioners, No. 33 at
p. 25; ACEEE, No. 24 at p. 1) The
California Utilities supported reducing
the clothes dryer cycles per year from
416 to 329 to reflect new Energy
Information Administration (EIA)’s
‘‘Residential Energy Consumption
Survey’’ (RECS) survey data on
household use. (California Utilities, No.
31 at pp. 2–3, 12) According to AHAM,
a recent Proctor & Gamble (P&G)
consumer survey showed that the
average consumer dries 5.35 loads per
week, or 278 load per year, which is
essentially identical to the value
estimated by RECS (279 cycles per year),
providing good verification for the RECS
approach. AHAM commented that DOE
should ensure that any value used in the
economic portion of the rulemaking
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22471
analysis (that is, cycles per year) be used
in the engineering analysis, and that the
test procedure be modified to reflect this
value. (AHAM, No. 25 at p. 9)
As discussed in the TP Final Rule,
DOE amended its clothes dryer test
procedure to change the number of
clothes dryer cycles per year from 416
to 283 based on data from the 2005
RECS. 76 FR 972, 977 (January 6, 2011).
DOE notes that this value is in close
agreement with the estimates provided
in the P&G data (278 cycles per year).
DOE also noted in the TP SNOPR that
data from the 2004 California Statewide
Residential Appliance Saturation Study
(RASS), which surveyed appliance
product usage patterns, including
clothes dryers, indicated an average of
4.69 loads per week, or approximately
244 loads per year, which is in
agreement with the downward trend of
the number of clothes dryer cycles per
year. Because the 2004 California
Statewide RASS provides only a limited
dataset, however, DOE stated in the TP
SNOPR that it did not intend to rely
only on this data to determine an
appropriate number of annual use
cycles for the clothes dryer test
procedure. 75 FR 37594, 37625 (June 29,
2010). DOE believes that these data
sources provide sufficient justification
for the revised value of 283 cycles per
year using the RECS-based approach.
Cycle Time
Edison Electric Institute (EEI)
commented that DOE’s assumption of
8,620 standby hours leaves 140 active
mode hours which would correspond to
20 minutes per drying cycle (if the
assumption is that there are 416 dryer
cycles per year). EEI questioned whether
this was accurate and stated that DOE
should review those numbers. (EEI,
Public Meeting Transcript, No. 21.4, at
p. 49) DOE notes that the TP Final Rule
amends the DOE clothes dryer test
procedure to lower the initial RMC of
the clothes load from 70 percent to 57.5
percent which will result in a decreased
cycle time. DOE also notes that the
amendments in the TP Final Rule to
increase the test load size for standard
size dryers from 7 lb. to 8.45 lb. as well
as changing the water temperature for
test load preparation from 100 °F to 60
°F will result in an increased cycle time.
76 FR 972, 988 (January 6, 2011). The
TP Final Rule also amended the clothes
dryer test procedure to change the
number of cycles per year from 416 to
283. 76 FR 977. Based on the
amendment to the number of annual use
cycles, DOE notes that the cycle length
would be approximately 30 minutes
(140 annual active mode hours/283
active mode cycles per year). DOE is
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unaware, however, of consumer usage
data indicating that the number of active
mode hours per year has changed. For
these reasons, DOE did not change the
number of clothes dryer active mode
hours in the TP Final Rule.
Initial RMC
The DOE clothes dryer test procedure
in appendix D specifies that the clothes
load have an initial RMC of 70 ± 3.5
percent. DOE stated in the preliminary
TSD that a review of residential clothes
washer models in the California Energy
Commission (CEC) product database
suggests that the average RMC is less
than the nominal 70 percent that is
currently provided for in the DOE
clothes dryer test procedure. Therefore,
DOE stated it was considering
amendments to the clothes dryer test
procedure to address RMC.
The Joint Petitioners and ACEEE
commented that DOE should update the
initial RMC based on the best available
data (ideally based on a nationally
representative sample). (Joint
Petitioners, No. 33 at p. 25; ACEEE, No.
24 at p. 1) NRDC commented that DOE’s
initial RMC assumptions do not reflect
today’s washing machines and should
be revised to better reflect current
washer technology. (NRDC, No. 26 at
pp. 2, 4) NRDC commented that the
ECOS report summarized test results for
a single clothes washer which showed
that the RMCs after the wash cycle is
finished are 70-percent RMC for cotton
bath towels and 40-percent RMC for the
DOE 50/50 cotton/polyester test cloths.
(NRDC, No. 30 at pp. 30–31) NRDC also
stated that the energy consumption of a
clothes dryer decreases when the initial
RMC is lower, but not in direct
proportion to the lowered water content
because energy is still used to heat and
move the air, cloth and metal. (NRDC,
No. 26 at pp. 2, 4) The California
Utilities and the NPCC both supported
reducing the initial RMC from the
current 70 percent to a value nearer to
56 percent, based on data submitted by
AHAM, recognizing that today’s
washers have faster spin speeds and
typically leave less water in the clothes.
(California Utilities, No. 31 at pp. 2, 12;
NPCC, No. 32 at p. 2) However, NPCC
also commented that even an initial
RMC of 56 percent may not reflect the
RMC produced by higher efficiency
clothes washers that may be required as
a result of the current DOE rulemaking
for those products. NPCC commented
that the average RMC for clothes
washers in the July 2008 CEC appliance
product directory was only 46 percent
(as presented by DOE), which is well
below its proposed revised value.
(NPCC, No. 32 at p. 2)
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AHAM and Whirlpool supported
using the industry shipment-weighted
average residential clothes washer RMC
of 47 percent derived from data
provided by AHAM. They commented
that DOE should use the 47-percent
RMC in both the engineering and
economic analyses; modify the test
procedure by changing the RMC from 70
percent to 47 percent; and modify the
baseline energy factor to reflect the
change in the test procedure. Whirlpool
added that failure to do so will result in
overstating clothes dryer energy use,
thus rendering all payback and LCC
calculations erroneous. (AHAM, No. 25
at p. 10; Whirlpool, No. 22 at pp. 2–3)
AHAM also stated that data collected by
industry showed a 22-percent increase
in EF when the initial RMC is changed
to 56 percent. AHAM commented that
they expect EF will increase further as
RMC is reduced to 47 percent, but that
the relationship is not expected to be
linear. (AHAM No. 25 at p. 10)
BSH also commented that it supports
reducing the initial RMC for testing
purposes, and added that the DOE test
procedure should be defined before any
energy conservation standard levels are
established. (BSH, No. 23 at p. 6) BSH
also commented that it should be
clarified which energy consumption
results from each change in the test
procedure before a suitable
classification can be done and added
that a round robin test may be helpful
to estimate the energy levels. (BSH, No.
23 at p. 6)
In the TP SNOPR, DOE proposed to
change the initial RMC from 70 percent
to 47 percent based on shipmentweighted clothes washer RMC data
provided by AHAM. 75 FR 37594,
37626–31 (June 29, 2010). As discussed
in the TP Final Rule, DOE received
comments in response to the TP SNOPR
that the shipment-weighted average
RMC value in the AHAM data was
based on the clothes washer RMC,
which uses an RMC correction factor to
normalize testing results from different
lots of test cloth, but the DOE clothes
dryer test procedure should instead use
the uncorrected RMC value. DOE
determined that an initial clothes dryer
RMC of 57.5 percent more accurately
represents the moisture content of
current laundry loads after a wash cycle
for the purposes of clothes dryer testing,
derived from the 47-percent shipmentweighted RMC for clothes washers (that
was based on analysis of data provided
by AHAM) without the application of
the RMC correction factor specified in
the DOE clothes washer test procedure,
as discussed above in this paragraph.
DOE validated this estimate using
clothes washer uncorrected RMC data
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from testing of a limited sample of
representative clothes washers for the
DOE clothes washer energy
conservation standards rulemaking. As a
result, the TP Final Rule amended the
DOE clothes dryer test procedure to
adopt this value for the initial RMC. 76
FR 972, 977 (January 6, 2011). As
discussed in section IV.C.2.a, DOE
conducted testing for the TP Final Rule
in order to analyze how the
amendments to the test procedure,
including the change to the initial RMC,
would affect the measured efficiency of
clothes dryers.
Load Size
Currently the DOE test procedure for
clothes dryers requires a 7.00 lb. ± .07
lb. test load for standard-size dryers and
a 3.00 lb. ± .03 lb. test load for compactsize dryers. (10 CFR part 430, subpart B,
appendix D, section 2.7) DOE stated in
chapter 2 of the preliminary TSD that it
was reviewing available data to
determine the current representative
clothes dryer load size, and would
consider amendments to its test
procedure to accurately reflect the
current clothes dryer test load size for
the clothes dryer tests.
The Joint Petitioners and ACEEE
commented that DOE should update the
size of the clothes dryer test load based
on the best available data (ideally based
on a nationally representative sample).
(Joint Petitioners, No. 33 at p. 25;
ACEEE, No. 24 at p. 1) The California
Utilities and NPCC both supported
increasing the test load size from 7 lb.
to 8.3 lb., or another appropriate value,
commenting that 8.3 lb. is more typical
of the size of loads in today’s larger
clothes dryers, as based on DOE’s
distribution of tub sizes from models in
the CEC database. (California Utilities,
No. 31 at p. 2; NPCC, No. 32 at p. 2)
NRDC also commented that DOE should
consider modifying the clothes dryer
size criteria, stating that test load sizes
for clothes dryers do not correlate to the
test load sizes for washers and likely do
not reflect real life load size. According
to NRDC, current clothes dryer size
classes are likely inaccurate given that
today’s clothes dryers can comfortably
hold loads of 10 to 17 lb., with more 7
to 8 cubic foot (ft3) models now on the
market than models smaller than 7 ft3.
NRDC commented that DOE should
reevaluate its clothes dryer size criteria
and test load size to better reflect the
clothes dryers available on the market
today. (NRDC, No. 26 at pp. 2, 4; NRDC,
No. 30 at p. 30)
AHAM commented that it prefers that
DOE utilize industry values for data
such as clothes dryer load size. AHAM
stated that the shipment-weighted
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residential clothes washer drum volume
for standard-size products in 2008 was
3.24 ft3, which corresponds to an
average clothes washer load size of 8.15
lb. AHAM also stated that for compact
clothes washers, the shipment-weighted
average drum volume was 1.5 ft3, which
corresponds to an average load size of
4.70 lb. AHAM added that because
compact products are a separate product
class, they should be treated as such in
the analysis. AHAM commented that it
supports the use of two separate load
sizes (8.15 lb. for standard-size and 4.70
lb. for compact-size products), if the
modified load size is used in both the
engineering and economic analyses, and
if the test procedure is modified to be
consistent with this analysis and the
baseline EF is modified to reflect the
change in load size. (AHAM, No. 25 at
pp. 10–11)
In the TP Final Rule, DOE amended
the clothes dryer test procedure to
change the load size from 7.00 lb ± .07
lb to 8.45 lb ± .085 lb based on the
historical trends of the shipmentweighted average tub volume for
residential clothes washers from 1981 to
2008 and the corresponding percentage
increase in clothes washer load sizes (as
specified in the load size table 5.1 in the
DOE clothes washer test procedure at 10
CFR part 430, subpart B, appendix J1),
which is assumed to proportionally
impact clothes dryer load size. 76 FR
972, 977 (January 6, 2011). DOE believes
that this estimate using the percentage
increase in load size based on trends in
clothes washer tub volumes would
produce a more representative value
than simply using the nominal load size
value in the clothes washer test
procedure, as suggested by AHAM. DOE
does not have any consumer usage data
indicating that consumers always
machine dry the same size load from the
wash cycle such that the average clothes
washer load size can be directly applied
to the clothes dryer test procedure, as
suggested by AHAM. As discussed in
section IV.C.2.a, DOE conducted testing
for the TP Final Rule in order to analyze
how the amendments to the test
procedure, including the change to the
load size, would affect the measured
efficiency.
DOE stated in the TP Final Rule that
it believes that most compact clothes
dryers are used in conjunction with
compact-size clothes washers, and DOE
is not aware of data on the trends of
compact clothes washer tub volumes
that would suggest that the tub volume
for such clothes washers has changed
significantly. 76 FR 972, 1014 (January
6, 2011). DOE did not receive any such
data in response to its requests in the TP
SNOPR. In addition, as discussed above,
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DOE does not have any consumer usage
data indicating that consumers always
machine dry the same size load from the
wash cycle such that the average clothes
washer load size can be directly applied
to the clothes dryer test procedure, as
suggested by AHAM. For these reasons,
DOE did not revise the test load size for
compact clothes dryers in the TP Final
Rule. Id.
NRDC also commented that the ECOS
report states that if DOE were to test
each model across a wide range of load
sizes and report multiple values, it
would help consumers choose the
appropriate sized clothes dryer and to
fill it with the recommended amount of
clothing to dry as efficiently as possible.
(NRDC, No. 30 at p. 30) DOE is not
aware of any data indicating what load
sizes typical consumers use or data on
the percentage of clothes dryer cycles at
different load sizes to determine how
such results would be used to calculate
an energy use or energy efficiency
metric. DOE is also unaware of data
showing how such a change would
affect the measured EF compared to the
existing test procedure, as required by
EPCA. (42 U.S.C. 6293(e)(1)) DOE notes
that requiring additional test cycles for
different size loads would add
significant testing burden on
manufacturers. For these reasons, DOE
did not amend the clothes dryer test
procedure to require the testing of
multiple test load sizes in the TP Final
Rule.
BSH proposed that tumble clothes
dryers be tested with a load size relative
to the drum volume, and that this
relationship be linear. BSH commented
that the load size that the consumer uses
generally matches the drum size of the
clothes dryer (the larger the drum the
higher the average load size dried).
According to BSH, using only two load
sizes for a wide range of drum volumes
will cause unfairness in comparison of
different clothes dryers. For example, a
standard clothes dryer with a 125-liter
drum volume but 60 centimeter (cm)
housing (which is right above the limit
to be ‘‘compact’’) has an unfair
advantage when its energy efficiency is
measured due to the fact that the load
fills the drum much better than in a
larger appliance. (BSH, No. 23 at p. 4)
DOE is not aware of any consumer usage
data indicating how load size varies
with clothes dryer drum capacity. In
addition, DOE is not aware of any data
indicating how such a change would
affect the measured efficiency. For these
reasons, DOE did not amend the clothes
dryer test procedure to require that the
load size vary with drum capacity.
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Water Temperature for Test Load
Preparation
The current clothes dryer test
procedure specifies a water temperature
of 100 °F ± 5 °F for the test load
preparation. (10 CFR part 430, subpart
B, appendix D, section 2.7) The
California Utilities, ACEEE, and NPCC
stated that this initial clothes load
temperature may have been common
when most clothes washers used a hot
water rinse. However, today almost all
clothes washers now default to a cold
water final rinse to save water heating
energy. (California Utilities, No. 31 at
pp. 3, 12; ACEEE, No. 24 at p. 2; NPCC,
No. 32 at p. 2) According to ACEEE,
today’s clothes washers typically have a
cold rinse default and consumers
increasingly select cold water wash and
rinse in response to public information
campaigns and the introduction of
special ‘‘cold water wash’’ detergents.
(ACEEE, No. 24 at p. 2) The California
Utilities, ACEEE, and NPCC
recommended that DOE align the
clothes dryer test method with the
clothes washer test method by reducing
the water temperature for clothes dryer
test load preparation to 60 °F ± 5 °F.
(ACEEE, No. 24 at p. 2)
As discussed in the TP Final Rule,
DOE analyzed 2005 RECS data on the
rinse water temperatures selected by
consumers for clothes washer cycles,
which indicates that for consumers that
use a clothes washer in the home,
approximately 80 percent of wash
cycles per year use a cold rinse. 76 FR
972, 996 (January 6, 2011). In addition,
DOE also noted that the clothes washer
test procedure specifies a warm rinse
temperature use factor of 27 percent,
suggesting that for the majority of
clothes washer cycles, consumers use
the cold rinse. (10 CFR part 430, subpart
B, appendix J1) DOE also sought
comment on the warm rinse
temperature use factor in the recent
proposal to amend the test procedure for
residential clothes washers because it
received consumer usage survey data
from a manufacturer indicating that, for
one clothes washer model with no cold
rinse option on the cycle recommended
for cotton clothes and a default cold
rinse on all other cycles, users
participating in the survey reported
using warm rinse for 1.6 percent of all
cycles. 75 FR 57556, 57571 (Sept. 21,
2010) For these reasons, DOE amended
the clothes dryer test procedure to
change the water temperature for
clothes dryer test load preparation from
100 °F ± 5 °F to 60 °F ± 5 °F to be more
representative of the clothes load after a
cold rinse cycle at the end of the wash
cycle. 76 FR 972, 996 (January 6, 2011).
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Test Cloth
The current clothes dryer test
procedure specifies the use of energy
test cloth consisting of a pure finished
bleach cloth, made with a momie or
granite weave, which is a blended fabric
of 50-percent cotton and 50-percent
polyester. Each energy test cloth
measures 24 inches by 36 inches.
Additional specifications are provided
in the test procedure for the weight,
thread count, and allowable shrinkage.
(10 CFR part 430, subpart B, appendix
D, section 2.7)
The ECOS report stated that DOE
should test a mix of cotton and
synthetics of various sizes, including
large sheets, towels, and jeans, rather
than only testing small, uniform
synthetic-blend test cloths to more
closely approximate real-world
performance. The ECOS report also
stated that this would deal more fairly
with the real-world situation in which
some fabrics have finished drying before
others, causing the load to either finish
before everything is dry or after some of
the fabrics have been over-dried. NRDC
also commented that the ECOS report
presented test results using different
mixes of test loads which showed that
clothes dryers often stopped with the
synthetic quite dry (less than 2-percent
final RMC) but the cotton still damp
(greater than 6-percent RMC). According
to NRDC, if DOE were to test each
model across a wide range of load types
and report multiple values, it would
help consumers choose an appropriately
sized clothes dryer and to fill it with the
recommended amount of clothing so
that it would dry as efficiently as
possible. (NRDC, No. 30 at pp. 22, 30)
NRDC added that in this real-world
scenario, clothes dryers may be less
effective due to clothing balling up or
the clothes dryer shutting off early due
to a variety in cloth blends. NRDC
added that certain techniques such as
agitating the drum or reversing the cycle
may help mitigate these problems and
potentially increase efficiency in a real
world scenario. NRDC also added that
the standard DOE test cloths do not
constitute a typical load and therefore
do not accurately test clothes dryers’
effectiveness at drying loads that have a
variety of fabric types or are more likely
to clump. NRDC suggested a mix of 100percent cotton and 50:50 cotton/
polyester as an alternative test load.
(NRDC, No. 26 at pp. 1, 3; NRDC, Public
Meeting Transcript, No. 21.4 at p. 43)
DOE is unaware of data to determine
the composition of clothing types and
materials that would be more
representative of typical consumer
clothing loads than the existing DOE
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test cloth and still produce accurate and
repeatable results. Similarly, DOE is
unaware of data showing the test-to-test
repeatability of different test loads.
Based on discussions with
manufacturers, DOE understands the
test material specified in the existing
DOE clothes dryer test procedure
produces the most repeatable results,
and other tests loads are less repeatable.
In addition, DOE also notes that
requiring additional test cycles for loads
with different clothes types and
materials would add significant testing
burden on manufacturers. For these
reasons, DOE did not amend the clothes
dryer test procedure in the TP Final
Rule to change the DOE test load or to
require the testing of multiple test loads
composed of different clothes types and
materials.
e. Drum Capacity Measurement
The Joint Petitioners commented that
DOE should clarify section 3.1 of the
clothes dryer test procedure regarding
the measurement of drum capacity to
specify that the clothes dryer’s rear
drum surface be supported on a
platform scale to ‘‘prevent deflection of
the drum surface * * *’’ instead of
‘‘prevent deflection of the dryer.’’ (Joint
Petitioners, No. 33 at p. 25) As
discussed in the TP Final Rule, DOE
agrees with the comments that the
reference to deflection of the ‘‘dryer’’ is
unclear and should be clarified to
specify that the clothes dryer’s rear
drum surface should be supported on a
platform scale to prevent deflection of
the drum surface. For this reason, DOE
amended the clothes dryer test
procedure in TP Final Rule to reflect
this change. 76 FR 972, 1019 (January 6,
2011).
f. HVAC Effects
According to EPCA, any prescribed or
amended test procedures shall be
reasonably designed to produce test
results which measure energy
efficiency, energy use, water use, or
estimated annual operating cost of a
covered product during a representative
average use cycle or period of use. (42
U.S.C. 6293(b)(3))
NRDC and NPCC commented that
DOE should analyze the effects of
clothes dryers on a home’s heating and
cooling energy use. (NRDC, No. 26 at
pp. 1, 4; NPCC, No. 32 at p. 2) NRDC
also commented that the current test
procedure does not analyze the clothes
dryer’s effect on the heating and cooling
of the surrounding room, in particular,
whether the clothes dryer warms the
room, cools it, or leaves it unchanged.
NRDC stated that the test procedure
does not distinguish between clothes
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dryers that vent their exhaust air outside
(and require makeup air to be
conditioned), and those that are
unvented. (NRDC, No. 26 at pp. 1, 4;
NRDC, No. 30 at p. 31) NPCC also
commented that DOE’s analysis of the
economics of heat recovery clothes
dryers should incorporate the reduced
impact on space conditioning of this
technology option. (NPCC, No. 32 at p.
2) The California Utilities recommended
that the DOE clothes dryer test
procedure be amended to measure the
total airflow volume during the test
cycle in order to gather data on heating,
ventilation, and air conditioning
(HVAC) loading. (California Utilities,
No. 31 at pp. 9, 12)
As discussed above, EPCA requires
that any prescribed or amended test
procedures be reasonably designed to
produce test results which measure
energy efficiency, energy use, water use,
or estimated annual operating cost of a
covered product during a representative
average use cycle or period of use. (42
U.S.C. 6293(b)(3)) DOE believes that
accounting for the effects of clothes
dryers on HVAC energy use is
inconsistent with the EPCA requirement
that a test procedure measure the energy
efficiency, energy use, or estimated
annual operating cost of a covered
product. As a result, DOE did not revise
the clothes dryer test procedure to
account for HVAC energy use in the TP
Final Rule and does not account for
HVAC energy use in these standards.
g. Efficiency Metric
The energy efficiency metric currently
used for clothes dryer energy
conservation standards, EF, is defined
on the basis of a per-cycle measure of
the lb. of clothes dried per kWh. (10
CFR 430.23)
BSH commented that DOE should
calculate yearly energy consumption for
clothes dryers by considering a defined
amount of laundry dried within a year.
BSH stated that the energy consumption
for the yearly load dried in small clothes
dryer should be correlated to the energy
consumption when the same yearly load
is dried in a larger clothes dryer. BSH
added that if only the number of loads
is used then for a larger clothes dryer,
the energy labeled would refer to a
much larger amount of clothing than for
a smaller clothes dryer. According to
BSH, the values would not be
comparable and it would appear to the
consumer that the larger clothes dryer
uses more energy per cycle than the
smaller. In reality, when using a
compact size clothes dryer consumers
would run more cycles per year to dry
their yearly amount of laundry. (BSH,
No. 23 at p. 5) DOE is not aware of
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consumer usage data showing the
relationship between clothes dryer
drum capacity and the amount of
laundry dried by the consumer per year
that would suggest that consumers
typically dry the same amount of
clothing per year, regardless of the drum
capacity. For these reasons, DOE did not
amend the clothes dryer test procedure
in the TP Final Rule to specify a single
value for the amount of laundry dried
per year.
2. Room Air Conditioner Test Procedure
a. Standby Mode and Off Mode
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Referenced Standards
As noted above, EPCA directs DOE to
amend its test procedures to include
measures of standby mode and off mode
energy consumption, taking into
consideration the most current versions
of IEC Standard 62301 and IEC Standard
62087. (42 U.S.C. 6295(gg)(2)(A)) For the
reasons discussed for the clothes dryer
test procedure, DOE determined that
only IEC Standard 62301 is relevant to
the room air conditioner test procedure.
AHAM supported DOE’s evaluation of
IEC Standard 62301 CDV for potential
revisions to address standby mode and
off mode power in the room air
conditioner test procedure. AHAM
commented that DOE would thus
harmonize with international standards,
including those developed in Canada
and Europe. (AHAM, Public Meeting
Transcript, No. 21.4 at p. 30) As
discussed for clothes dryers in section
III.A.1.a, DOE considered the current
version, IEC Standard 62301 First
Edition, as required by EPCA. For the
reasons stated in the TP Final Rule, DOE
amended its test procedures for room air
conditioners in the final rule to
incorporate by reference the clauses
from IEC Standard 62301 First Edition
proposed in the TP SNOPR, as well as
the provisions of IEC Standard 62301
CDV for the mode definitions. 76 FR
972, 975–6 (January 6, 2011). DOE may
consider incorporating by reference
clauses from IEC Standard 62301
Second Edition when that version has
been published.
Testing Procedures
EEI commented that the total number
of standby hours would be 8,010 if a
product is plugged in all year (8,760
total hours in a year less the 750 cooling
mode operating hours), and closer to
2,000 if unplugged. EEI requested
clarification on the source of the 5,115
standby hours. (EEI, Public Meeting
Transcript, No. 21.4 at p. 37) DOE notes
that the estimate of 5,115 total standby
and off mode hours, explained in greater
detail in the TP SNOPR (75 FR 37594,
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37610 (June 29, 2010), assumes (1) the
cooling season length is 90 days or
2,160 hours; (2) half of the products in
the field would be unplugged outside of
the cooling season, while the others
would be in standby and/or off mode;
and (3) that the cooling season hours not
associated with active mode cooling are
evenly split between off-cycle mode and
standby mode or off mode. Off-cycle
mode involves operation of the fan but
not the compressor. DOE noted in the
TP NOPR that it is not aware of any
reliable data for hours spent in different
standby and off modes for room air
conditioners. 73 FR 7439, 74648–49
(Dec. 9, 2008). In the absence of data
suggesting a different allocation of
annual hours, DOE adopted the estimate
of 5,115 annual hours standby and off
mode hours in the TP Final Rule. 76 FR
972, 991 (January 6, 2011).
b. Active Mode Referenced Standards
The current DOE room air conditioner
test procedure incorporates by reference
two industry test standards: (1)
American National Standard (ANS)
(since renamed American National
Standards Institute (ANSI)) Z234.1–
1972, ‘‘Room Air Conditioners;’’ 16 and
(2) American Society of Heating,
Refrigerating, and Air-Conditioning
Engineers (ASHRAE) Standard 16–69,
‘‘Method of Testing for Rating Room Air
Conditioners.’’ 17 (10 CFR part 430,
subpart B, appendix F, section 1)
AHAM commented that its current
room air conditioner standard is
American National Standards Institute
(ANSI)/AHAM RAC–1–2008. (AHAM,
Public Meeting Transcript, No. 21.4 at
p. 35; AHAM, No. 25 at p. 13) As
discussed in the TP Final Rule, DOE
adopted the amendments to reference
the relevant sections of the current
industry test standards for room air
conditioners, which are designated as:
(1) ANSI/AHAM RAC–1–R2008, ‘‘Room
Air Conditioners;’’ and (2) ANSI/
American Society of Heating,
Refrigerating, and Air-Conditioning
Engineers (ASHRAE) Standard 16–1983
(RA 2009), ‘‘Method of Testing for
Rating Room Air Conditioners and
Packaged Terminal Air Conditioners’’
(ANSI/ASHRAE Standard 16–1983 (RA
2009)). 76 FR 972, 978 (January 6, 2011)
c. Annual Active Mode Hours
The current DOE room air conditioner
test procedure assumes that room air
conditioners have an average annual use
of 750 hours. (10 CFR part 430.23(f))
16 ANSI standards are available at https://
www.ansi.org.
17 ASHRAE standards are available at https://
www.ashrae.org.
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DOE noted in chapter 3 of the
preliminary TSD that DOE’s TSD from
September 1997, issued in support of
the 1997 room air conditioner
rulemaking, provides estimates for
average annual operating hours closer to
500.18 DOE noted in the preliminary
TSD developed in support of today’s
final rule, however, that a similar
assessment of room air conditioner
hours of operation developed in support
of the June 2010 TP SNOPR suggests
that the annual hours of operation have
since increased and are now in fact
close to 750. 75 FR 37594, 37633 (June
29, 2010).
EEI commented that the active mode
hours for room air conditioners may be
more than the 750 hours currently
specified in the DOE room air
conditioner test procedure and
questioned whether the 750 hours
reflect both residential and commercial
applications. (EEI, Public Meeting
Transcript, No. 21.4 at p. 36) As
discussed in the TP Final Rule, DOE
noted that estimates using data from the
EIA’s 2005 RECS 19 support maintaining
the 750 annual operating hours
specification. As a result, DOE did not
amend the room air conditioner test
procedure to change the number of
annual operating hours. 76 FR 972, 978
(January 6, 2011).
d. Part-Load Operation
DOE noted in the preliminary TSD
(chapter 5, ‘‘Engineering Analysis’’) that
the DOE room air conditioner test
procedure at appendix F measures fullload performance but is not able to
assess energy savings associated with
technologies which improve part-load
performance.
DOE considered amendments to its
room air conditioner test procedure to
measure part-load performance, but did
not propose such changes, as explained
in the June 2010 TP SNOPR and the TP
final rule. 75 FR 37594, 37634 (June 29,
2010); 76 FR 972, 1016 (January 6,
2011). DOE concluded that developing
an additional test for part load, or
switching to a seasonal metric to
integrate part-load performance is not
warranted. DOE noted that (1) sufficient
information is not available at this time
regarding use of room air conditioner
18 U.S. Department of Energy—Office of Energy
Efficiency and Renewable Energy, Technical
Support Document for Energy Conservation
Standards for Room Air Conditioners. September
1997. Chapter 1, section 1.5. Washington, DC,
available at https://www.eere.energy.gov/buildings/
appliance_standards/residential/room_ac.html
19 U.S. Department of Energy-Energy Information
Administration. ‘‘Residential Energy Consumption
Survey,’’ 2005 Public Use Data Files, 2005.
Washington, DC. Available online at: https://
www.eia.doe.gov/emeu/recs/.
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features that prevent over-cooling; (2)
widespread use of part-load technology
in room air conditioners is not likely to
be stimulated by the development of a
part-load or seasonal metric at this time,
and therefore, the significant effort
required to develop an accurate partload metric is not likely to be justified
by the expected minimal energy savings;
and (3) key design changes that improve
full-load efficiency also improve partload efficiency, so the existing EER
metric is already a strong indication of
product efficiency over a wide range of
conditions.
DOE stated in the preliminary TSD
that it did not consider technologies
such as variable speed compressors and
thermostatic expansion valves as design
options during the engineering analysis
because these design options save
energy only during part-load operation.
DOE expects, based on available data
and the considerations discussed in the
test procedure SNOPR and reiterated
above, that such technologies will not
save enough energy to be cost effective.
DOE requested comments regarding
additional design options that it should
consider in the engineering analysis.
(See the preliminary TSD Executive
Summary, section ES.4).
NRDC commented that DOE should
further analyze the efficiency of partload operation. NRDC stated that DOE
assumed that room air conditioners are
generally undersized and run at full
capacity and, therefore, did not take into
consideration the potential to improve
part-load efficiency. NRDC
recommended that DOE further
investigate the underlying assumption
that room air conditioners are almost
always run at full capacity and analyze
the potential to improve part-load
operation efficiency. (NRDC, No. 26 at
p. 5) The comment does not provide any
new information regarding room air
conditioner operation that would allow
development of an appropriate seasonal
efficiency metric. As discussed in the
TP Final Rule, development of such a
metric that would take part load
operation into account would require
knowledge of the distribution of hours
spent by room air conditioners at
different load levels and at different
outdoor and indoor temperature and
humidity conditions. 76 FR 972, 1016
(January 6, 2011). Because such data is
not available, DOE cannot establish an
appropriate efficiency metric and
cannot properly evaluate part-load
technologies. DOE may amend the test
procedure to account for part-load
performance in a future rulemaking if
sufficient information becomes
available.
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DOE also notes that the existing EER
metric, which represents most of the
CEER metric that is the basis of the
energy standard prescribed in today’s
rule, is already a strong indicator of
product efficiency over a wide range of
conditions. Most of the design options
that improve efficiency measured using
EER would also improve efficiency
measured using a part-load metric. For
these reasons, DOE did not amend its
room air conditioner test procedure to
measure part-load performance. 76 FR
972, 1016 (January 6, 2011).
e. Distribution of Air
NRDC commented that DOE should
consider how effectively room air
conditioners distribute air throughout
the room, adding that if all the cooling
is provided by convection into the
space, the effectiveness of delivering
that cooling by the fan and integral
diffuser may have a significant impact
on energy use. NRDC stated that the
DOE test procedure should take into
account how far into the room the
airflow travels and whether the unit
allows for adjustments to the airflow
pattern. NRDC also commented that
many units will be placed at sill height,
but buildings with wall sleeves will
likely have units that are installed
below the sill, which could pose
different concerns with room air
distribution to provide adequate mixing
to avoid drafts. (NRDC, No. 26 at p. 6)
DOE notes that the DOE test
procedure measures the cooling
delivered by the room air conditioner
regardless of the distribution of the
cooling air within the test chamber.
Thus, design options that optimize
distribution of the cooling air would not
improve the measurement.
DOE agrees with the comment’s
premise that the energy use of a room
air conditioner used by a consumer may
be affected by the air circulation
patterns it establishes in a room. For
example, a consumer located in a room
far from the unit and not in line with
the product’s discharge air outlet may
keep the unit operating longer to
achieve comfortable local room
conditions. This influence has as much
to do with installation and use as it does
with product characteristics. The
relationship between room air
circulation and room air conditioner
energy use is not sufficiently well
understood to allow any consideration
of integration of such factors into the
energy use metric. DOE is not aware of
data evaluating the impact a product’s
air distribution patterns have on
product energy use by consumers. As a
result, this issue is not addressed by
today’s rule.
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3. Effects of Test Procedure Revisions on
the Measured Efficiency
In any rulemaking to amend a test
procedure, DOE must determine to what
extent, if any, the proposed test
procedure would alter the measured
energy efficiency of any covered
product as determined under the
existing test procedure. (42 U.S.C.
6293(e)(1)) If DOE determines that the
amended test procedure would alter the
measured efficiency of a covered
product, DOE must amend the
applicable energy conservation standard
accordingly. In determining the
amended energy conservation standard,
the DOE must measure, pursuant to the
amended test procedure, the energy
efficiency, energy use, or water use of a
representative sample of covered
products that minimally comply with
the existing standard. The average of
such energy efficiency, energy use, or
water use levels determined under the
amended test procedure shall constitute
the amended energy conservation
standard for the applicable covered
products. (42 U.S.C. 6293(e)(2)) EPCA
also states that models of covered
products in use before the date on
which the amended energy conservation
standard becomes effective (or revisions
of such models that come into use after
such date and have the same energy
efficiency, energy use, or water use
characteristics) that comply with the
energy conservation standard applicable
to such covered products on the day
before such date shall be deemed to
comply with the amended energy
conservation standard. (42 U.S.C.
6293(e)(3))
EPCA also provides that amendments
to the test procedures to include
standby mode and off mode energy
consumption will not determine
compliance with previously established
standards. (U.S.C. 6295(gg)(2)(C))
Because the amended test procedures
for standby mode and off mode energy
consumption would not alter existing
measures of energy consumption or
efficiency, these amendments would not
affect a manufacturer’s ability to
demonstrate compliance with
previously established standards.
For the TP Final Rule, DOE
investigated how the amended test
procedures would affect the measured
efficiency as compared to the existing
DOE test procedures. The following
sections discuss these effects for each
product.
a. Clothes Dryers
The Joint Petitioners proposed that
the final rule amending the clothes
dryer test procedure also amend the
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standards in the Joint Petition according
to the procedures in section 323(e)(2) of
EPCA, except that for the purposes of
establishing a representative sample of
products, DOE should choose a sample
of minimally compliant dryers which
automatically terminate the drying cycle
at no less than 4-percent RMC. (Joint
Petitioners, No. 33 at p. 17)
As discussed above, DOE did not
adopt amendments to the clothes dryer
test procedure to better account for
automatic cycle termination. As a result,
DOE did not consider any revisions to
the energy conservation standards based
on amendments for automatic cycle
termination. However, DOE notes that
EPCA does not include any exceptions
that would allow for the measurement
of only dryers that automatically
terminate the drying cycle at no less
than 4-percent RMC. (42 U.S.C.
6293(b)(1)–(3))
As part of the TP Final Rule, DOE
conducted testing on a sample of 17
representative clothes dryers to evaluate
the effects of the amendments to the
clothes dryer test procedure on the
measured EF. 76 FR 972, 1026–27
(January 6, 2011). DOE tested these
units according to the amended clothes
dryer test procedure in the TP Final
Rule, conducting up to three tests for
each test unit and averaging the results.
The results from this testing are shown
below in Table III.2. DOE noted in its
testing that the amendments to the
initial RMC, water temperature for test
load preparation, and load size had an
effect on the measured EF as compared
to the existing test procedure. For
vented electric-standard size clothes
dryers tested using the amended test
procedure, the measured EF increases
by an average of about 20.1 percent. For
vented gas clothes dryers, the measured
EF increased by an average of about 19.8
percent. For vented electric compact
120V and 240V clothes dryers, the
measured EF increased by an average of
about 15.6 and 12.8 percent,
respectively. For ventless electric
compact 240V clothes dryers and
ventless electric combination washer/
dryers, the measured EF increased by an
average of about 13.6 and 11.4 percent,
respectively, as compared to the
measured EF using the existing test
procedure with only the amendments
for ventless clothes dryers. (That is,
without the changes to the initial RMC,
water temperature for test load
preparation, or other changes) DOE
noted that the increase in measured EF
is greater for the standard-size products
(that is, vented electric standard and
vented gas clothes dryers) than for
compact-size products due to the
additional amendments to increase the
test load size for standard-size products.
76 FR 972, 1027 (January 6, 2011). As
discussed in section IV.C.2.a, DOE
applied these percentage increases in
the measured EF based on the test
procedure amendments for each product
class to the efficiency levels proposed in
the preliminary analysis.
TABLE III.2—DOE TEST RESULTS TO EVALUATE THE EFFECTS OF THE CLOTHES DRYER TEST PROCEDURE AMENDMENTS
ON MEASURED EF
Average EF lb/kWh
Test unit
Current test
procedure
Vented Electric Standard:
Unit 1 ....................................................................................................................................
Unit 2 ....................................................................................................................................
Unit 3 ....................................................................................................................................
Unit 4 ....................................................................................................................................
Unit 5 ....................................................................................................................................
Unit 6 ....................................................................................................................................
Vented Gas:
Unit 7 ....................................................................................................................................
Unit 8 ....................................................................................................................................
Unit 9 ....................................................................................................................................
Unit 10 ..................................................................................................................................
Unit 11 ..................................................................................................................................
Vented Electric Compact (240V):
Unit 12 ..................................................................................................................................
Unit 13 ..................................................................................................................................
Vented Electric Compact (120V):
Unit 14 ..................................................................................................................................
Ventless Electric Compact (240V):
Unit 15 ..................................................................................................................................
Ventless Electric Combo Washer/Dryer:
Unit 16 ..................................................................................................................................
Unit 17 ..................................................................................................................................
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Table III.3 shows how the current
energy conservation standards are
Amended test
procedure
Change
(percent)
3.07
3.14
3.20
3.28
3.24
3.12
3.69
3.77
3.83
3.92
3.96
3.72
20.4
19.5
19.6
19.4
22.5
19.1
2.78
2.83
2.85
2.80
2.98
3.36
3.40
3.42
3.37
3.50
20.6
19.9
20.2
20.5
17.6
3.19
2.93
3.56
3.35
11.4
14.2
3.23
3.74
15.6
2.37
2.69
13.6
2.01
2.50
2.27
2.76
12.5
10.3
affected by the amendments to the DOE
clothes dryer test procedure.
TABLE III.3—ENERGY FACTOR OF A MINIMALLY COMPLIANT CLOTHES DRYER WITH THE CURRENT AND AMENDED TEST
PROCEDURE
EF lb/kWh
Product class
Existing test
procedure
1. Electric, Standard (4.4 ft3 or greater capacity) ...................................................................................................
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TABLE III.3—ENERGY FACTOR OF A MINIMALLY COMPLIANT CLOTHES DRYER WITH THE CURRENT AND AMENDED TEST
PROCEDURE—Continued
EF lb/kWh
Product class
Existing test
procedure
2. Electric, Compact (120 v) (less than 4.4 ft3 capacity) ........................................................................................
3. Electric, Compact (240 v) (less than 4.4 ft3 capacity) ........................................................................................
4. Gas ......................................................................................................................................................................
b. Room Air Conditioners
B. Technological Feasibility
The Joint Petitioners proposed that
the final rule amending the room air
conditioner test procedure amend the
standards in the consensus agreement
according to the procedures in section
323(e)(2) of EPCA. (Joint Petitioners,
No. 33 at p. 18) These are the provisions
that require DOE to adjust the efficiency
standard if DOE determines that
changes in the energy test procedure
alter the measured energy use of
covered products. While the measured
efficiency of room air conditioners is
altered by the incorporation of standby
and off mode energy use in the new
efficiency metric. However, DOE
determined in the TP Final Rule that the
amendments to the room air conditioner
test procedure do not impact the
measurement of EER while providing
more accurate and repeatable
measurements of capacity and greater
flexibility to manufacturers in selecting
equipment and facilities. 76 FR 972,
1028 (January 6, 2011). For this reason,
DOE believes that revisions to the
energy conservation standards for room
air conditioners because of the
amendments to the test procedure
would not be warranted.
1. General
In each standards rulemaking, DOE
conducts a screening analysis based on
information it has gathered on all
current technology options and
prototype designs that could improve
the efficiency of the products or
equipment that are the subject of the
rulemaking. As the first step in such
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 these
means for improving efficiency are
technologically feasible. DOE considers
a technology option to be
technologically feasible if it is
incorporated into commercially
available products or working
prototypes. 10 CFR part 430, subpart C,
appendix A, section 4(a)(4)(i).
Once DOE has determined that
particular technology options are
technologically feasible, it further
evaluates each of these technology
options in light of the following
additional screening criteria:
(1) Practicability to manufacture, install,
or service; (2) adverse impacts on
product utility or availability; and (3)
adverse impacts on health or safety.
3.13
2.90
2.67
Amended test
procedure
3.62
3.27
3.20
Section IV.B of this notice discusses the
results of the screening analysis for
clothes dryers and room air
conditioners, particularly the designs
DOE considered, those it screened out,
and those that are the basis for the trial
standard levels (TSLs) in this
rulemaking. For further details on the
screening analysis for this rulemaking,
see chapter 4 of the technical support
document accompanying today’s direct
final rule (direct final rule TSD).
2. Maximum Technologically Feasible
Levels
When DOE proposes to adopt an
amended standard for a type or class of
covered product, it must ‘‘determine the
maximum improvement in energy
efficiency or maximum reduction in
energy use that is technologically
feasible’’ for such product. (42 U.S.C.
6295(p)(1)) Accordingly, DOE
determined the maximum
technologically feasible (‘‘max-tech’’)
improvements in energy efficiency for
clothes dryers and room air conditioners
in the engineering analysis, using the
design options used in the most efficient
products available on the market or in
working prototypes. (See chapter 5 of
the direct final rule TSD.) Table III.4
lists the max-tech levels that DOE
determined for this rulemaking.
TABLE III.4—MAXIMUM TECHNOLOGICALLY FEASIBLE EFFICIENCY LEVELS FOR RESIDENTIAL CLOTHES DRYERS AND ROOM
AIR CONDITIONERS
Residential clothes dryers
Max-tech
CEF lb/kWh
Product class
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1.
2.
3.
4.
5.
6.
Vented Electric, Standard (4.4 ft3 or greater capacity) .......................................................................................................................
Vented Electric, Compact (120 V) (less than 4.4 ft3 capacity) ...........................................................................................................
Vented Electric, Compact (240 V) (less than 4.4 ft3 capacity) ...........................................................................................................
Vented Gas ..........................................................................................................................................................................................
Ventless Electric, Compact (240 V) (less than 4.4 ft3 capacity) .........................................................................................................
Ventless Electric Combination Washer/Dryer .....................................................................................................................................
5.42
5.41
4.89
3.61
4.03
3.69
Room air conditioners
Max-tech
CEER Btu/
Wh
Product class
1. Without reverse cycle, with louvered sides, and less than 6,000 Btu/h .............................................................................................
2. Without reverse cycle, with louvered sides, and 6,000 to 7,999 Btu/h ..............................................................................................
3. Without reverse cycle, with louvered sides, and 8,000 to 13,999 Btu/h ............................................................................................
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22479
Room air conditioners
Max-tech
CEER Btu/
Wh
Product class
4. Without reverse cycle, with louvered sides, and 14,000 to 19,999 Btu/h ..........................................................................................
5A. Without reverse cycle, with louvered sides, and 20,000 to 27,999 Btu/h ........................................................................................
5B. Without reverse cycle, with louvered sides, and 28,000 Btu/h or more ...........................................................................................
6. Without reverse cycle, without louvered sides, and less than 6,000 Btu/h ........................................................................................
7. Without reverse cycle, without louvered sides, and 6,000 to 7,999 Btu/h .........................................................................................
8A. Without reverse cycle, without louvered sides, and 8,000 to 10,999 Btu/h .....................................................................................
8B. Without reverse cycle, without louvered sides, and 11,000 to 13,999 Btu/h ...................................................................................
9. Without reverse cycle, without louvered sides, and 14,000 to 19,999 Btu/h .....................................................................................
10. Without reverse cycle, without louvered sides, and 20,000 Btu/h or more ......................................................................................
11. With reverse cycle, with louvered sides, and less than 20,000 Btu/h ..............................................................................................
12. With reverse cycle, without louvered sides, and less than 14,000 Btu/h .........................................................................................
13. With reverse cycle, with louvered sides, and 20,000 Btu/h or more ................................................................................................
14. With reverse cycle, without louvered sides, and 14,000 Btu/h or more ...........................................................................................
15. Casement-Only ..................................................................................................................................................................................
16. Casement-Slider ................................................................................................................................................................................
a. Clothes Dryers
For electric vented and vent-less
clothes dryers, the max-tech level
corresponds to the efficiency
improvement associated with
incorporating heat pump technology,
according to information from
manufacturer interviews and available
research on heat pump dryers. For
vented gas clothes dryers, the max-tech
level is the value proposed in the
framework document was based on data
contained in the CEC product database.
AHAM submitted aggregated
incremental manufacturing cost data in
support of this max-tech efficiency level
for vented gas clothes dryers. As
discussed in chapter 5 of the
preliminary TSD, multiple
manufacturers stated during interviews
that the current maximum efficiency
listed for vented gas clothes dryers in a
more recent version of the CEC product
database is not achievable. Also, as
discussed in chapter 5 of the
preliminary TSD, DOE testing of the
‘‘maximum-available’’ vented gas clothes
dryer in this more recent version of the
CEC product database determined that
this unit did not achieve the rated
efficiency. For these reasons, DOE
considered the vented gas clothes dryer
max-tech value for which AHAM
submitted aggregated incremental
manufacturing costs. This max-tech
level was supported by multiple
manufacturers during interviews.
b. Room Air Conditioners
As described in the direct final rule
TSD (chapter 5, ‘‘Engineering Analysis’’),
DOE conducted a full engineering
analysis for seven room air conditioner
product classes, which comprise a large
percentage of identified products on the
market. DOE’s approach for extending
the analysis of the proposed standard
11.96
10.15
9.80
10.35
10.35
10.35
10.02
10.02
9.80
11.96
10.15
10.35
10.02
10.35
10.35
levels to the non-analyzed product
classes is described in chapter 5,
‘‘Engineering Analysis’’, of the direct
final rule TSD. This section of this
notice reports specifically on the maxtech efficiency levels for the product
classes directly analyzed in the
engineering analysis.
DOE used the full set of design
options considered applicable to these
product classes to determine the maxtech efficiency levels. (See chapter 5 of
the direct final rule TSD.) Table III.5,
below, lists the max-tech levels that
DOE determined for this rulemaking—
the table shows the levels for the
directly analyzed product classes (see
section IV.C regarding discussion of the
product classes that were directly
analyzed). The max-tech levels that DOE
determined for this rulemaking are
based on design options that are used in
commercially-available products.
TABLE III.5—MAX-TECH EERS FOR THE ROOM AIR CONDITIONER PRODUCTS RULEMAKING
Analyzed product class
Combined energy efficiency
ratio (EER)
level
Description
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DOE final rule
max-tech
1 ................................................................
2 ................................................................
3 ................................................................
4 ................................................................
5A ..............................................................
5B ..............................................................
8A ..............................................................
8B ..............................................................
Less than 6,000 Btu/h, without reverse cycle and with louvered sides ......................
6,000 to 7,999 Btu/h, without reverse cycle and with louvered sides .........................
8,000 to 13,999 Btu/h, without reverse cycle and with louvered sides .......................
14,000 to 19,999 Btu/h, without reverse cycle and with louvered sides .....................
20,000 Btu/h to 27,999 Btu/h, without reverse cycle and with louvered sides ...........
28,000 Btu/h or more, without reverse cycle and with louvered sides .......................
8,000 to 10,999 Btu/h, without reverse cycle and without louvered sides ..................
11,000 to 13,999 Btu/h, without reverse cycle and without louvered sides ................
The DOE max-tech levels differ from
those presented in the preliminary TSD.
They are higher for three of the analyzed
product classes, and lower for three (one
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product class was not analyzed during
the preliminary analysis). The
engineering analysis revisions are
discussed in section IV.C.2.b below.
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11.7
*N/A
12.0
*N/A
10.2
9.8
10.4
10.0
DOE determined that max-tech levels
for most room air conditioner product
classes higher than the commercially
available max-tech were technologically
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feasible. Although the commercially
available products generally do not use
all the energy efficient design options
considered in the DOE max-tech
analyses, the design options are all used
in commercially available products,
some of which combine nearly all of the
design options used in the DOE maxtech configurations.
DOE determined the max-tech levels
of each analyzed product class as part
of its engineering analysis. The maxtech levels represent the most efficient
design option combinations applicable
for the analyzed products. Details of this
analysis are described in the direct final
rule TSD in chapter 5. DOE used
different design option groups for each
analyzed product class’s max-tech
design, as indicated in Table III.6.
Stakeholder comments and questions
regarding the preliminary analysis maxtech levels primarily addressed the maxtech levels that DOE selected for the
analyses. Some stakeholders argued that
max available products exist at higher
levels, while others argued that the
conversion to R–410A refrigerant
requires a re-examination of max-tech
levels.
include all current ENERGY STAR® and
max-tech units on the market. The
California Utilities suggested that DOE
consider the current best R–410A
products on the ENERGY STAR list
(California Utilities, No. 31 at pp. 16–
17). The California Utilities also pointed
out that the ENERGY STAR Database
listed products with a 13.5 EER, and
that the CEC Database listed four
products with a 13.8 EER (California
Utilities, No. 31 at p. 13). The Northwest
Power and Conservation Council
(NPCC) and ACEEE also commented
that there were higher efficiency
products available than had been
assumed by DOE (NPCC, No. 32 at p. 4;
ACEEE, No. 24 at p. 4).
DOE is aware that the ENERGY–STAR
and CEC databases list products that
exceed the max-tech EER of 12.0 that
DOE identified in the preliminary
analysis. Table III.7 lists products listed
at 12.0 EER or higher in one or both of
these databases.
c. Available Max-Tech Products With
Higher EER Ratings
Numerous stakeholders commented
that DOE should update its analysis to
TABLE III.7—ROOM AIR CONDITIONER MODELS OF INTEREST FOR MAX-TECH ANALYSIS, AS LISTED IN THE ENERGY
STAR AND CEC DATABASES
Source
Climette .......................................................................
Comfort-Aire ...............................................................
Fedders .......................................................................
Maytag ........................................................................
Fedders .......................................................................
Turbo Air .....................................................................
Turbo Air .....................................................................
Turbo Air .....................................................................
Friedrich ......................................................................
Friedrich ......................................................................
Friedrich ......................................................................
Friedrich ......................................................................
Friedrich ......................................................................
Haier ...........................................................................
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EER
Model
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CH1826A ....................................................................
REC–183 ....................................................................
AED18E7DG ...............................................................
MED18E7A .................................................................
A7Q06F2A ..................................................................
TAS–09EH ..................................................................
TAS–12EH ..................................................................
TAS–18EH ..................................................................
SS10M10 ....................................................................
YS09L10 .....................................................................
SS10L10 .....................................................................
XQ06M10 ....................................................................
SS12M10 ....................................................................
ESAD4066 ..................................................................
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13.8
13.8
13.8
13.8
13.4
13.5
13.0
13.0
12.0
12.0
12.0
12.0
12.0
12.0
CEC
ENERGY
STAR
✔
✔
✔
✔
✔
................
................
................
✔
✔
✔
✔
✔
................
................
................
................
................
................
✔
✔
✔
✔
✔
✔
✔
................
✔
ER21AP11.000
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DOE searched product databases and
manufacturer Web sites to gather
information about these products and to
determine whether these products
represented valid room air conditioner
ratings. DOE’s investigation indicates
that none of the products listed with
EER higher than 12.0 represent valid
room air conditioner ratings, and that
some of the products rated at an EER of
12.0 are also invalid representations.
The first five products in the table are
listed with much lower EER ratings in
Natural Resources Canada (NRCan)
database.20 The three Turbo-Air
products are ductless mini-split
products (as identified by the
manufacturer’s Web site 21), not room
air conditioners. The Friedrich
SS12M10 has been re-rated at lower
than 12.0 EER 22, and the validity of the
12.0 rating of the Haier ESAD4066 is
likely also incorrect, as discussed in
greater detail below. Consequently, DOE
concludes that its identification of a
max-tech available level no higher than
12.0 EER is valid.
The California Utilities stated that the
analysis for room air conditioners was
quite favorable in terms of costeffectiveness, and that many of the
analyzed efficiency levels had LCC
savings relative to the baseline levels.
They indicated that, if DOE’s selected
efficiency levels are as cost-effective as
the analysis suggests, that there may be
additional design options or higher
efficiency levels that also merit DOE’s
analysis. (California Utilities, No. 31 at
p. 13) PG&E asked whether DOE would
consider higher max-tech levels that
might result in more stringent standards
(Public Meeting Transcript, No. 21.4 at
p. 130).
DOE is required to establish energy
conservation standards that achieve the
maximum improvement in energy
efficiency that is technologically
feasible and economically justified. (42
U.S.C. 6295(o)(2)). DOE developed maxtech levels in the preliminary analysis
and made adjustments in the
engineering analysis based on new
information, as mentioned above,
particularly regarding compressors
designed for R–410A refrigerant. The
engineering analysis adjustments are
20 (1) Natural Resources Canada, Office of Energy
Efficiency. EnerGuide for Equipment—EnerGuide
Room Air Conditioner Directory 2002. 2002; (2)
Room Air Conditioner Model Listing. ‘‘EnerGuide
Room Air Conditioner Directory 2004’’ https://
oee.nrcan.gc.ca/.
21 Product Specifications and Descriptions for
Turbo Air Products TAS–09EH, TAS–12EH, TAS–
18EH. https://www.turboairinc.net/productspecs/
productspecs.html.
22 Friedrich product specifications. Specifications
for SS12M10. https://kuhl.friedrich.com/modelspecifications/.
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discussed in more detail in section
IV.C.2.b below. DOE determined that
the products cited by the commenters
that appeared to have higher efficiencies
than the max-tech levels either were not
room air conditioners or did not have
valid ratings. The max-tech levels
incorporate all applicable design
options for each of the product classes,
and based on DOE’s research and
engineering analysis, DOE does not
believe that products with higher
efficiency than DOE’s max-tech are
technologically feasible.
d. Consideration of Conversion to
R–410A Refrigerant in Max-Tech
Selections
As detailed in the direct final rule
TSD (chapter 5), the use of HCFC–22
refrigerant in room air conditioners was
phased out starting January 1, 2010. The
industry has switched to R–410A
refrigerant, which has required
significant design modification.
Although DOE based its preliminary
analyses on use of R–410A refrigerant
because HCFC–22 can no longer be
used, few R–410A products were
available for reverse engineering when
DOE conducted the preliminary
analyses. Also, there was limited
information regarding compressors
designed for the new refrigerant, or
regarding manufacturers’ experiences
developing product designs for the new
refrigerant.
GE Consumer & Industrial (GE) asked
during the March 2010 public meeting
whether any of the models considered
for the engineering analysis (specifically
the max-tech levels) were R–410A
products (GE, Public Meeting
Transcript, No. 21.4 at pp. 72–73). DOE
responded that it based the max-tech
analysis of product class 1 on a 12 EER
R–410A product that was available at
the time of the analysis. GE commented
that Consumer Reports published an
article in October 2008 23 in which it
reported on test results indicating that
this product’s efficiency was not 12 EER
(Public Meeting Transcript, No. 21.4 at
72–73). GE indicated that DOE should
not consider this model to be
representative of the technologies or
costs required to achieve 12 EER. GE
recommended that DOE instead use an
alternative model to represent this
efficiency level: the Friedrich model
XQ06M10,24 which has a 6,000 Btu/h
23 ‘‘Energy Star has lost some luster.’’ Consumer
Reports. October 2008. Pg. 24 Vol. 73 No. 10.
Copyright 2008 Consumers Union of U.S., Inc.
24 The GE comment identified Friedrich model
AQ06M10, but the listing on the Friedrich Web site
is XQ06M10 for a product matching the GE
description (same capacity, EER, weight, and other
relevant attributes).
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capacity and 12.0 EER, with a retail
price of over $600 and a weight of 72
lbs.
The California Utilities requested
clarification on DOE’s decision to not
pursue a full teardown of the single R–
410A unit identified in the preliminary
analysis (California Utilities, No. 31 at
p. 17). In response, DOE notes that it
had obtained sufficient information
about this unit to allow development of
both an energy model and
manufacturing cost model through close
examination of heat exchanger details,
identification of the compressor and fan
motor model number, and measurement
of fan power input.
DOE considered the Consumer
Reports article regarding the product
identified in the preliminary analysis,
which was initially considered to
represent 12.0 EER using R–410A.
Matching this performance level with
the energy model required making some
input assumptions that DOE considers
unlikely, particularly for the condenser
air flow rate. Given the information
available, DOE agrees with GE’s
suggestion to instead use the Friedrich
12.0 EER product as a representation of
this performance level. The revised
analysis for product class 1 is based on
calibration of the energy model to match
the performance of the Friedrich
product. DOE conducted a teardown of
this product to verify its design details.
The analysis shows that the product
class 1 max-tech level is 11.8, slightly
lower than 12. This reflects
(1) reduction of the capacity from the
6,000 Btu/h of the Friedrich unit to the
5,000 Btu/h considered representative
for the product class, and (2) adopting
a 50 lb. product weight limit, as
suggested by AHAM (AHAM, No. 25 at
p. 6) AHAM commented that OSHA
recommends that articles heavier than
50 lbs. should be lifted by two rather
than one person. Id. DOE considers this
limit to be an appropriate demarcation
for product class 1, since most of these
products currently weigh less than 50
lb. Increase in weight beyond 50 lbs.,
requiring additional personnel for
installation, represents a distinct
reduction in consumer utility
(specifically, the ability to remove the
unit from the window during the offseason, relocate it to other windows
without calling an installer, or both).
Size limits for room air conditioners are
discussed in greater detail in section
IV.C.2.b, below.
During the final rule analysis, DOE
also considered new products of other
product classes that use R–410A
refrigerant and adjusted its analysis
accordingly based on new information
regarding designs and efficiency levels
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of these products. Adjustments DOE
made to the engineering analysis during
the final rule phase are detailed in
section IV.C.2.b below, and in chapter 5
of the TSD.
C. Energy Savings
1. Determination of Savings
DOE used its NIA spreadsheet model
to estimate energy savings from
amended standards for the products that
are the subject of this rulemaking.25 For
each TSL, DOE forecasted energy
savings beginning in 2014, the year that
manufacturers would be required to
comply with amended standards, and
ending in 2043. DOE quantified the
energy savings attributable to each TSL
as the difference in energy consumption
between the standards case and the base
case. The base case represents the
forecast of energy consumption in the
absence of amended mandatory
efficiency standards, and considers
market demand for more-efficient
products.
The NIA spreadsheet model calculates
the electricity savings in ‘‘site energy’’
expressed in kWh. Site energy is the
energy directly consumed by appliances
at the locations where they are used.
DOE reports national energy savings on
an annual basis in terms of the
aggregated source (primary) energy
savings, the savings in the energy used
to generate and transmit the site energy.
(See direct final rule TSD chapter 10.)
To convert site energy to source energy,
DOE derived annual conversion factors
from the model used to prepare the EIA
Annual Energy Outlook 2010
(AEO2010).
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2. Significance of Savings
As noted above, DOE cannot adopt a
standard for a covered product if such
standard would not result in
‘‘significant’’ energy savings. 42 U.S.C.
6295(o)(3)(B) While the term
‘‘significant’’ is not defined in the Act,
the U.S. Court of Appeals, in Natural
Resources Defense Council v.
Herrington, 768 F.2d 1355, 1373 (DC
Cir. 1985), indicated that Congress
intended ‘‘significant’’ energy savings in
this context to be savings that were not
‘‘genuinely trivial.’’ The energy savings
for all of the TSLs considered in this
rulemaking are nontrivial, and,
therefore, DOE considers them
‘‘significant’’ within the meaning of
42 U.S.C. 6295(o)(3)(B).
25 The NIA spreadsheet model is described in
section IV.G of this notice.
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D. Economic Justification
1. Specific Criteria
As noted in section II.B, EPCA
provides seven factors to be evaluated in
determining whether a potential energy
conservation standard is economically
justified. (42 U.S.C. 6295(o)(2)(B)(i)) The
following sections discuss how DOE has
addressed each of those seven factors in
this rulemaking.
a. Economic Impact on Manufacturers
and Consumers
In determining the impacts of an
amended standard on manufacturers,
DOE first determines the quantitative
impacts using an annual cash-flow
approach. This step includes both a
short-term assessment—based on the
cost and capital requirements during the
period between the issuance of a
regulation and when entities must
comply with the regulation—and a longterm assessment over a 30-year analysis
period. The industry-wide impacts
analyzed include INPV (which values
the industry on the basis of expected
future cash flows), cash flows by year,
changes in revenue and income, and
other measures of impact, as
appropriate. Second, DOE analyzes and
reports the impacts on different types of
manufacturers, including analysis of
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 different
DOE regulations and other regulatory
requirements on manufacturers.
For individual consumers, measures
of economic impact include the changes
in LCC and the PBP associated with new
or amended standards. The LCC,
specified separately in EPCA as one of
the seven factors to be considered in
determining the economic justification
for a new or amended standard, 42
U.S.C. 6295(o)(2)(B)(i)(II), is discussed
in the following section. For consumers
in the aggregate, DOE also calculates the
national net present value of the
economic impacts on consumers over
the forecast period used in a particular
rulemaking.
b. Life-Cycle Costs
The LCC is the sum of the purchase
price of a product (including its
installation) and the operating expense
(including energy and maintenance and
repair expenditures) discounted over
the lifetime of the product. The LCC
savings for the considered efficiency
levels are calculated relative to a base
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case that reflects likely trends in the
absence of amended standards. The LCC
analysis requires a variety of inputs,
such as product prices, product energy
consumption, energy prices,
maintenance and repair costs, product
lifetime, and consumer discount rates.
DOE assumed in its analysis that
consumers will purchase the considered
products in 2014.
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. A
distinct advantage of this approach is
that DOE can identify the percentage of
consumers estimated to receive LCC
savings or experience an LCC increase,
in addition to the average LCC savings
associated with a particular standard
level. In addition to identifying ranges
of impacts, DOE evaluates the LCC
impacts of potential standards on
identifiable subgroups of consumers
that may be disproportionately affected
by a national standard.
c. Energy Savings
While significant conservation of
energy is a separate statutory
requirement for imposing an energy
conservation standard, EPCA requires
DOE, in determining the economic
justification of a standard, to consider
the total projected energy savings
expected to result directly from the
standard. (42 U.S.C. 6295(o)(2)(B)(i)(III))
DOE uses the NIA spreadsheet results in
its consideration of total projected
energy savings.
d. Lessening of Utility or Performance of
Products
In establishing classes of products,
and in evaluating design options and
the impact of potential standard levels,
DOE sought to develop standards for
clothes dryers and room air conditioners
that would not lessen the utility or
performance of these products. (42
U.S.C. 6295(o)(2)(B)(i)(IV)) None of the
TSLs considered in this notice would
reduce the utility or performance of the
clothes dryers under consideration in
this rulemaking. DOE considered the
possibility that room air conditioners
size increases (and related weight
increases) may reduce utility. DOE
requested comments from stakeholders
during the preliminary analysis phase
addressing this issue. In response, DOE
received comments from AHAM
recommending limits to product
weights and from NRDC recommending
limits to product dimensions. These
comments and DOE’s response to them
are discussed in section IV.C.2.b. DOE
adjusted its analysis so that analyzed
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TSLs are within the weigh and
dimension limits suggested by
stakeholders. These adjustments
included: (1) Use of a 50 lbs. limit for
the product class 1 analysis, and (2) use
of maximum height and width
dimensions (for all product classes with
louvered sides) consistent with maxtech available products. DOE made
these adjustments to its analysis
specifically to avoid the possible
reduction in consumer utility that could
result from increases in size and weight.
Further discussion of this analysis can
be found in the direct final rule TSD in
chapter 5. Furthermore, the energy
conservation standards are performance
standards rather than design standards,
so they do not specify the design
options that manufacturers must use to
achieve the required efficiency levels.
Manufacturers may use design options
other than those selected by DOE in its
analyses to achieve the required levels.
Consequently, DOE believes that the
TSLs considered and the TSLs adopted
for the energy conservation standard do
not represent any such consumer utility
reductions, notwithstanding increases
in size and weight that DOE considered
in the analyses for some of the product
classes.
e. Impact of Any Lessening of
Competition
EPCA directs DOE to consider any
lessening of competition that is likely to
result from standards. It also directs the
Attorney General of the United States
(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)(i)(V) and (B)(ii))
DOE published a NOPR containing
energy conservation standards identical
to those set forth in today’s direct final
rule and transmitted a copy of today’s
direct final rule and the accompanying
TSD to the Attorney General, requesting
that the Department of Justice (DOJ)
provide its determination on this issue.
DOE will consider DOJ’s comments on
the rule in determining whether to
proceed with the direct final rule. DOE
will also publish and respond to DOJ’s
comments in the Federal Register in a
separate notice.
f. Need for National Energy
Conservation
The energy savings from new or
amended standards are likely to
improve the security and reliability of
the nation’s energy system. Reduced
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demand for electricity may also 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.
Energy savings from the proposed
standards are also likely to result in
environmental benefits in the form of
reduced emissions of air pollutants and
greenhouse gases associated with energy
production. DOE reports the
environmental effects from the proposed
standards, and from each TSL it
considered, in the environmental
assessment contained in chapter 15 in
the direct final rule TSD. DOE also
reports estimates of the economic value
of emissions reductions resulting from
the considered TSLs.
g. Other Factors
EPCA allows the Secretary of Energy,
in determining whether a standard is
economically justified, to consider any
other factors that the Secretary deems to
be relevant. (42 U.S.C.
6295(o)(2)(B)(i)(VII)) In developing the
direct final rule, DOE has also
considered the submission of the Joint
Petition, which DOE believes sets forth
a statement by interested persons that
are fairly representative of relevant
points of view (including
representatives of manufacturers of
covered products, States, and efficiency
advocates) and contains
recommendations with respect to an
energy conservation standard that are in
accordance with 42 U.S.C. 6295(o). DOE
has encouraged the submission of
consensus agreements as a way to bring
diverse stakeholders together, to
develop an independent and probative
analysis useful in DOE standard setting,
and to expedite the rulemaking process.
DOE also believes that standard levels
recommended in the consensus
agreement may increase the likelihood
for regulatory compliance, while
decreasing the risk of litigation.
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 of 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 payback period for
consumers of potential amended energy
conservation standards. These analyses
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22483
include, but are not limited to, the 3year payback period contemplated
under the rebuttable presumption test.
DOE routinely conducts, however, an
economic analysis that considers the
full range of impacts to the consumer,
manufacturer, nation, and environment,
as required under 42 U.S.C.
6295(o)(2)(B)(i). The results of this
analysis serve as the basis for DOE to
definitively evaluate 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.12 of this
direct final rule and chapter 8 of the
direct final rule TSD.
IV. Methodology and Discussion
DOE used two spreadsheet tools to
estimate the impact of today’s proposed
standards. The first spreadsheet
calculates LCCs and payback periods of
potential new energy conservation
standards. The second provides
shipments forecasts and then calculates
national energy savings and net present
value impacts of potential energy
conservation standards. The two
spreadsheets are available online at
https://www1.eere.energy.gov/buildings/
appliance_standards/.
The Department also assessed
manufacturer impacts, largely through
use of the Government Regulatory
Impact Model (GRIM).
Additionally, DOE estimated the
impacts on utilities and the
environment of energy efficiency
standards for clothes dryers and room
air conditioners. DOE used a version of
EIA’s National Energy Modeling System
(NEMS) for the utility and
environmental analyses. The NEMS
model simulates the energy sector of the
U.S. economy. EIA uses NEMS to
prepare its Annual Energy Outlook
(AEO), a widely known baseline energy
forecast for the United States. For more
information on NEMS, refer to ‘‘The
National Energy Modeling System: An
Overview,’’ DOE/EIA–0581 (98) (Feb.
1998), available at: https://
tonto.eia.doe.gov/FTPROOT/
forecasting/058198.pdf.
The version of NEMS used for
appliance standards analysis is called
NEMS–BT, and is based on the AEO
version with minor modifications.26
26 EIA approves the use of the name ‘‘NEMS’’ to
describe only an AEO version of the model without
any modification to code or data. Because the
present analysis entails some minor code
modifications and runs the model under various
policy scenarios that deviate from AEO
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NEMS–BT offers a sophisticated picture
of the effect of standards, because it
accounts for the interactions between
the various energy supply and demand
sectors and the economy as a whole.
A. Market and Technology Assessment
1. General
When beginning an energy
conservation standards rulemaking,
DOE develops information that provides
an overall picture of the market for the
products concerned, including the
purpose of the products, the industry
structure, and market characteristics.
This activity includes both
quantitative and qualitative assessments
based on publicly available information.
The subjects addressed in the market
and technology assessment for this
rulemaking include quantities and types
of products sold and offered for sale;
retail market trends; products covered
by the rulemaking; product classes and
manufacturers; regulatory and nonregulatory programs; and technology
options that could improve the energy
efficiency of the product(s) under
examination. See chapter 3 of the direct
final rule TSD for further discussion of
the market and technology assessment.
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2. Products Included in This
Rulemaking
This subsection addresses the scope
of coverage for today’s direct final rule,
discussing whether certain products are
subject to the amended standards and
whether certain technologies provide a
viable means of improving energy
efficiency. In the sections that follow,
DOE discusses the comments received
on the scope of coverage set forth in the
preliminary analysis.
a. Clothes Dryers
Hydromatic Technologies Corporation
(HTC) suggested that DOE consider
‘‘solar’’ clothes dryers in this
rulemaking. (HTC, No. FDMS DRAFT
0068 at p. 3) Under EPCA, any standard
for clothes dryers must establish either
a maximum amount of energy use or a
minimum level of efficiency based on
energy use. (42 U.S.C. 6291(5)–(6))
EPCA defines ‘‘energy use,’’ in part, as
‘‘the quantity of energy’’ that the product
consumes. (42 U.S.C. 6291(4)) EPCA
defines ‘‘energy’’ as meaning ‘‘electricity,
or fossil fuels,’’ or other fuels that DOE
adds to the definition, by rule, upon
determining ‘‘that such inclusion is
necessary or appropriate to carry out the
purposes’’ of EPCA. (42 U.S.C. 6291(3))
DOE has not added solar energy (or any
assumptions, the name ‘‘NEMS–BT’’ refers to the
model as used here. (BT stands for DOE’s Building
Technologies Program.)
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other type of fuel) to EPCA’s definition
of ‘‘energy.’’ Thus, DOE currently lacks
authority to prescribe standards for
clothes dryers when they use the sun’s
energy instead of fossil fuels or
electricity. DOE also notes that it is
unaware of any existing clothes dryers
that are solar-powered.
DOE has also considered in this
rulemaking standards based on
microwave or heat pump technology.
EPCA does not define ‘‘clothes dryer,’’
but DOE’s regulations under EPCA
provide separate definitions for electric
and gas products. Because the types of
clothes dryers just mentioned are or
would be electric products, DOE’s
definition of ‘‘electric clothes dryer’’ is
relevant in considering them. DOE
defines electric clothes dryer as a
cabinet-like appliance designed to dry
fabrics in a tumble-type drum with
forced air circulation. The heat source is
electricity and the drum and blower(s)
are driven by an electric motor(s). 10
CFR 430.2.
As to microwave technology, in this
rulemaking DOE has considered
whether microwave drying would be a
viable option for improving clothes
dryer efficiency. DOE determined,
however, that this technology did not
merit further consideration for reasons
discussed in section IV.B.1. In addition,
DOE is unaware of any microwave
dryers that are currently commercially
available for sale in the United States or
elsewhere. Therefore, in this rulemaking
DOE did not consider clothes dryer
standards based on microwave
technology.
DOE also identified heat pump
technology as a possible option for
improving the energy efficiency of
electric clothes dryers. Unlike
microwave technology, DOE did not
screen out this technology from further
consideration in this rulemaking.
Furthermore, DOE determined that heat
pump clothes dryers are commercially
available in Europe and Japan.
Accordingly, DOE has fully evaluated in
this rulemaking whether standards
based on heat pump technology are
warranted for clothes dryers.
DOE also considered non-tumbling
(that is, cabinet) clothes dryers. DOE
notes that, because they do not use a
tumbling-type drum, they are not
currently within DOE’s definition of
‘‘electric clothes dryer.’’ 10 CFR 430.2. In
analyzing non-tumbling dryers, DOE
determined that although these clothes
dryers are currently on the market in the
United States, DOE understands that
they have a very limited market share.
Based on a survey of cabinet clothes
dryer models available on the U.S.
market, DOE is aware of only three
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cabinet clothes dryer models from two
clothes dryer manufacturers that have
very low market share (i.e., less than 1
percent) in the conventional tumblingtype clothes dryer market. For these
reasons, DOE is not considering
standards for these clothes dryers in this
rulemaking.
DOE also considered centrifugal
spinners. DOE notes that, although
centrifugal spinners remove a certain
quantity of moisture from a clothes load,
they are not within DOE’s definition of
‘‘electric clothes dryer’’ as a product
designed to dry fabrics in a tumble-type
drum with forced air circulation, where
the heat source is electricity and the
drum and blower(s) are driven by an
electric motor(s). 10 CFR 430.2. Such
products extract moisture from a clothes
load by means of centrifugal force at
high spin speeds, without the
application of additional heat. The
ECOS report submitted to DOE by NRDC
states that centrifugal spinners remove
5–14 lbs. of water per kWh of electricity,
depending on the size and type of load,
making them at least two to seven times
as efficient as a typical electric dryer.
The ECOS report further cites multiple
sources suggesting that mechanical
extraction of water is 19–70 times more
efficient than evaporating it in a typical
drying process. According to the ECOS
report, a centrifugal spinner can reduce
initial RMC in a clothes load to be dried
in a conventional clothes dryer from 60–
70 percent down to 45 percent. Sources
cited in the ECOS report variously
ascribe to this decrease in initial RMC
a 25-percent reduction in clothes dryer
electricity use, or 209 kWh annual
energy savings for a typical clothes
dryer. (NRDC, No. 30 at pp. 10–11)
Although such centrifugal spinners are
currently on the market in the United
States, DOE understands that they have
a very limited market share. DOE also
notes that it is not aware of any
centrifugal spinners that can remove
moisture from the test load down to 2.5–
5 percent RMC, as required by the DOE
clothes dryer test procedure. In
addition, DOE is not aware of any
clothes dryers currently available on the
market or prototype designs that
incorporate centrifugal spinning and are
capable of drying the test load to 2.5–
5 percent RMC. For these reasons, DOE
is not considering standards for these
clothes dryers in this rulemaking
b. Room Air Conditioners
DOE defines ‘‘room air conditioner’’
under EPCA, in part, as a ‘‘consumer
product * * * which is an encased
assembly designed as a unit for
mounting in a window or through the
wall for the purpose of providing
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delivery of conditioned air to an
enclosed space. It includes a prime
source of refrigeration and may include
a means for ventilating and heating.’’
10 CFR 430.2. A product known as a
‘‘portable air conditioner’’ has most of
these characteristics. However, it rests
on the floor, often on wheels, with a
short ducted connection to a window or
other access to the outside to vent warm
condenser air and, for some of these
products, to provide condenser cooling
air from the outside. DOE notes that
portable air conditioners are not within
the current DOE definition of ‘‘room air
conditioner’’ because they are not
designed ‘‘for mounting in a window or
through the wall.’’ 10 CFR 430.2
DOE notes that EPCA authorizes the
prescription of standards for room air
conditioners (42 U.S.C. 6292(2)), and
that portable air conditioners do not fall
within DOE’s regulatory definition of
room air conditioner at 10 CFR 430.2, as
stated above, or the definitions found in
the current industry standards ANSI/
AHAM RAC–1–2008 and ANSI/
ASHRAE Standard 16–1983 (RA
2009).27 DOE also notes that portable air
conditioners cannot be tested in the
window configuration used in the
referenced standard ANSI/ASHRAE
Standard 16–1983 (RA 2009), in the
amended test procedure. 76 FR 972, 978
(January 6, 2011). DOE believes that a
separate test procedure analysis would
need to be considered for these
products; as an example, DOE notes that
the ANSI/ASHRAE test procedure
standard for portable air conditioners
(ANSI/ASHRAE Standard 128–2001,
‘‘Method of Rating Unitary Spot Air
Conditioners’’) references the ANSI/
ASHRAE Standard 37–2005 ‘‘Methods of
Testing for Rating Unitary AirConditioning and Heat Pump
Equipment’’ for testing, and excludes
equipment covered by ANSI/AHAM
RAC–1 2008. Thus, DOE is not
considering standards for portable air
conditioners in this rulemaking. DOE
may, however, consider standard for
portable air conditioners in a future
rulemaking.
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3. Product Classes
In evaluating and establishing energy
conservation standards, DOE divides
covered products into classes by the
type of energy used, or by capacity or
other performance-related feature that
justifies a different standard for
products having such feature. (See 42
U.S.C. 6295(q)) In determining whether
27 EPCA
also authorizes the classification of
additional consumer products as covered products
pursuant to 42 U.S.C. 6292(b) provided that certain
criteria are met.
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a feature justifies a different standard,
DOE must consider factors such as the
utility of the feature to users. Id. DOE is
required to establish different energy
conservation standards for different
product classes based on these criteria.
a. Clothes Dryers
In the preliminary analysis, DOE
proposed to analyze six product classes
for residential clothes dryers (for details
on these product classes, see chapter 3
of the preliminary TSD). In particular,
DOE considered four product classes for
vented clothes dryers and two product
classes for ventless clothes dryers,
ventless electric compact (240 V) and
combination washer/dryers, recognizing
the unique utility that ventless clothes
dryers offer to consumers.28
AHAM, BSH, and Whirlpool
suggested that DOE consider an
additional product class for electric
standard-size ventless clothes dryers,
even though such products are not
currently on the market in the United
States, to prepare for likely market
entry. AHAM stated that a standard-size
ventless product class would decrease
the request for waivers that DOE may
receive in the near future. AHAM
further commented that the analysis for
a standard-size ventless product class
could be extrapolated from the analysis
for compact-size ventless clothes dryers.
(AHAM, Public Meeting Transcript, No.
21.4 at pp. 19–20; AHAM, No. 25 at pp.
4–5; BSH, No. 23 at p. 3; Whirlpool, No.
22 at p. 1)
Because DOE is unaware of any
standard-size ventless clothes dryers
currently on the market, as discussed in
section IV.A.2.a, and because DOE does
not have information on the
performance of standard-size ventless
clothes dryers that would warrant the
definition of a separate product class,
DOE is not establishing a product class
for standard-size ventless clothes dryers
in today’s direct final rule.
According to BSH, clothes dryers
should be classified as vented, ventless,
and gas product classes, without
differentiation by drum size. (BSH, No.
23 at p. 4) EPCA requires DOE to specify
a level of energy use or efficiency
different from that which applies to the
type of covered product for any group
of such products that have a capacity or
other performance-related feature that
justifies a different standard. DOE has
previously determined, and has verified
in recent testing, that compact-size
clothes dryers have inherently different
28 Previously, DOE has described ventless dryers
as condensing dryers. The new designation reflects
the actual consumer utility (that is, no external vent
required) and the market availability of vented
dryers that also condense.
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energy consumption than standard-size
clothes dryers. DOE also notes that
compact-size clothes dryers provide
utility to consumers by allowing for
installation in space-constrained
environments. Therefore, DOE has
determined that the capacity and utility
of compact clothes dryers justifies a
different standard and establishes
separate product classes for compact
clothes washers under EPCA. (42 U.S.C.
6295(q))
b. Room Air Conditioners
The 1997 final rule for room air
conditioners established standards for
16 product classes based on the
following characteristics: Capacity,
presence or absence of louvered-sides
(louvered-side products are intended for
installation in windows, while products
without louvered sides are for throughthe-wall installation), type of cabinet
(casement-only, casement-slider, and
other), and presence or absence of heat
pump mode for heating. 72 FR 50122
(Sept. 24, 1997).
In its preliminary analysis, DOE
proposed no changes to the existing
product class structure. DOE received
two comments addressing product
classes, as discussed below.
AHAM recommended that DOE
consider splitting the following two
product classes: Product class 5 (room
air conditioners without reverse cycle,
with louvered sides, and capacity
20,000 Btu/h or more) and product class
8 (room air conditioners without reverse
cycle, without louvered sides, and
capacity 8,000 to 13,999 Btu/h) (AHAM,
No. 25 at p. 6). AHAM recommended
that product class 5 be split into two
product classes, (1) from 20,000 Btu/h to
24,999 Btu/h, and (2) greater than
25,000 Btu/h. AHAM also
recommended that product class 8 be
split into two product classes, (1) 8,000
Btu/h to 10,999 Btu/h, and (2) 11,000
Btu/h to 13,999 Btu/h. AHAM stated
that manufacturers are reaching the
limit of achievable efficiency levels for
higher-capacity room air conditioners.
Id.
The Joint Comment also proposed
splitting both product classes 5 and 8,
but recommended a different capacity at
which to split product class 5. The Joint
Comment proposed that the new
product classes derived from the current
product class 5 be (1) from 20,000
Btu/h to 27,999 Btu/h, and (2) 28,000
Btu/h and greater. The Joint Comment
proposed the same two separated
product classes for product class 8 that
AHAM proposed. (Joint Comment, No.
31 at pp. 7–8)
DOE agrees with the
recommendations of AHAM and the
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Joint Comment that the new product
classes are needed to ensure
establishment of meaningful efficiency
levels over the full range of capacities.
This is discussed in detail in the
following sections which separately
address each of the product class splits.
Splitting of Product Class 5
DOE splits current product class 5
(room air conditioners without reverse
cycle, with louvered sides, and capacity
20,000 Btu/h or more) into two new
product classes: 5A (room air
conditioners without reverse cycle, with
louvered sides, and capacity from
20,000 Btu/h to 27,999 Btu/h) and 5B
(room air conditioners without reverse
cycle, with louvered sides, and capacity
28,000 Btu/h or more). This step is
consistent with the recommendations of
AHAM and the Joint Comment
recommendations to split the product
class, but uses the split recommended
by the Joint Comment.
DOE made this decision based on the
following input:
• Discussions with individual
manufacturers of the efficiency options
available to large room air conditioners.
• Research on available product sizes
and available product efficiencies.
• Reverse engineering of two product
class 5 units, including a 28,500 Btu/h
unit.
• Engineering analysis of R–410A
product class 5 baseline products at two
capacity levels (24,000 Btu/h and 28,000
Btu/h).
Max-tech available EER for product
classes 1 through 5 (room air
conditioners without reverse cycle, with
louvered sides, covering the full
capacity range of available products) for
products using R–410A refrigerant are
shown in Table IV.1 below. The maxtech EER drops gradually as capacity
increases above 6,000 Btu/h, but drops
significantly above 28,000 Btu/h.
TABLE IV.1—MAX-TECH LOUVERED R–
410A ROOM AIR CONDITIONERS
Room air conditioner R–410A louvered products (market max available levels)
Product class
1
1
2
2
3
4
5
5
5
Max available EER
Capacity
........................
........................
........................
........................
........................
........................
........................
........................
........................
5,200
5,500
6,000
7,900
11,700
18,000
20,800
27,800
36,000
11.0
11.2
12.0
11.7
11.4
10.7
10.0
9.7
8.5
DOE produced cost-efficiency curves
for product class 5 products at both
24,000 Btu/h and 28,000 Btu/h capacity
levels. Table IV.2 shows the results of
these analyses, which clearly show
(1) much steeper increase in cost as the
CEER increases and (2) significantly
lower max-tech for the larger capacity
products. This analysis demonstrates
the much greater potential for efficiency
improvement for the lower-capacity
products.
TABLE IV.2—COMPARISON OF 24,000 Btu/h AND 28,000 Btu/h ROOM AIR CONDITIONER INCREMENTAL COSTS
PC5A—24,000 Btu/h
Efficiency level
CEER
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1
2
3
4
5
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
The cost-efficiency analysis and the
market analysis demonstrate that
limitations in the max-tech levels for
product class 5 units occur at the 28,000
Btu/h capacity, rather than the 24,000
Btu/h capacity. DOE used these analyses
to determine that the 28,000 Btu/h
capacity split was more appropriate
than the 24,000 Btu/h split.
DOE’s decision to establish the new
product classes 5A and 5B that take the
place of the current product class 5, and
split the product class at the 28,000 Btu/
h capacity level, is based on the
stakeholder comments and DOE’s
analysis. Additional details of the
analysis can be found in chapter 3 of the
direct final rule TSD.
Splitting of Product Class 8
DOE splits product class 8 (room air
conditioners without reverse cycle,
without louvered sides, and capacity
8,000 to 13,999 Btu/h) to establish two
new product classes: 8A (room air
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Incremental
cost
8.47
9.0
9.4
9.8
10.15
conditioners without reverse cycle,
without louvered sides, and capacity
8,000 to 10,999 Btu/h) and 8B (room air
conditioners without reverse cycle,
without louvered sides, and capacity
11,000 to 13,999 Btu/h).
DOE based this split on information
similar to that of the decision to split
product class 5, as discussed above.
DOE focused its reverse engineering and
engineering for these product classes on
capacities of 8,000 Btu/h and 12,000
Btu/h.
The max-tech EERs of available room
air conditioners without louvered sides
using R–410A refrigerant are dependent
on capacity range. These products are
designed to fit in sleeves installed in the
building wall. Due to the dependence of
this market on replacement sales, as
reported by manufacturers during
interviews for the final rule analysis,
there is little opportunity to adjust the
physical size of the product. (This is in
contrast to products with louvered
PC5B—28,000 Btu/h
$0.00
8.85
19.04
50.66
204.62
CEER
Incremental
cost
8.48
9.0
9.4
9.8
........................
$0.00
23.52
50.27
229.01
........................
sides, designed to fit in windows, which
allows more flexibility for size increase
to improve efficiency.) Non-louvered
products with capacity greater than
12,600 Btu/h are unable to meet the
current ENERGY STAR EER level. DOE
further notes that non-louvered
ENERGY STAR products in the capacity
range 11,500 to 12,800 Btu/h require
oversized sleeves. At a slightly higher
capacity level, these products cannot be
designed to meet the DOE energy
standard—the available data show that
there are currently no available nonlouvered products having greater than
13,999 Btu/h capacity.
DOE produced cost-efficiency curves
for non-louvered R–410A room air
conditioners at 8,000 Btu/h and 12,000
Btu/h capacities, shown in Table IV.3
below. As for the product class 5
analyses, the results show the
significantly steeper increase in cost as
efficiency level is raised above the
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22487
baseline and the reduced max-tech level
for the higher-capacity product.
TABLE IV.3—COMPARISON OF 8,000 Btu/h AND 12,000 Btu/h ROOM AIR CONDITIONER INCREMENTAL COSTS
PC8A—8,000 Btu/h
Efficiency level
CEER
1
2
3
4
5
...................................................................................................................
...................................................................................................................
...................................................................................................................
...................................................................................................................
...................................................................................................................
Incremental
cost
8.41
9.3
9.6
10.0
10.4
Btu/h capacity level recommended by
both AHAM and the Joint Comment.
Additional details of the analysis can be
found in chapter 3 of the direct final
rule TSD.
DOE’s decision to establish the new
product classes 8A and 8B that take the
place of the current product class 8 is
based on the stakeholder comments and
DOE’s analysis. DOE has decided to
split the product class at the 11,000
PC8B—12,000 Btu/h
$0.00
4.61
6.68
16.63
88.45
CEER
Incremental
cost
8.44
9.3
9.5
9.8
10.0
$0.00
11.72
15.39
26.06
93.36
Product Class Summary
Table IV.4 below presents the product
classes established in this rulemaking,
including both current and classes
established in this rulemaking.
TABLE IV.4—PROPOSED ROOM AIR CONDITIONER PRODUCT CLASSES
Number
Product class
Classes Listed in the CFR
1 ..................................
2 ..................................
3 ..................................
4 ..................................
6 ..................................
7 ..................................
9 ..................................
10 ................................
11 ................................
12 ................................
13 ................................
14 ................................
15 ................................
16 ................................
Without reverse cycle, with louvered sides, and less than 6,000 Btu/h.
Without reverse cycle, with louvered sides, and 6,000 to 7,999 Btu/h.
Without reverse cycle, with louvered sides, and 8,000 to 13,999 Btu/h.
Without reverse cycle, with louvered sides, and 14,000 to 19,999 Btu/h.
Without reverse cycle, without louvered sides, and less than 6,000 Btu/h.
Without reverse cycle, without louvered sides, and 6,000 to 7,999 Btu/h.
Without reverse cycle, without louvered sides, and 14,000 to 19,999 Btu/h.
Without reverse cycle, without louvered sides, and 20,000 Btu/h or more.
With reverse cycle, with louvered sides, and less than 20,000 Btu/h.
With reverse cycle, without louvered sides, and less than 14,000 Btu/h.
With reverse cycle, with louvered sides, and 20,000 Btu/h or more.
With reverse cycle, without louvered sides, and 14,000 Btu/h or more.
Casement-Only.
Casement-Slider.
Product Classes Established in This Rulemaking
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5A
5B
8A
8B
................................
................................
................................
................................
Without
Without
Without
Without
reverse
reverse
reverse
reverse
cycle,
cycle,
cycle,
cycle,
EPCA requires that the establishment
of separate product classes be based on
either (A) consumption of a different
kind of energy from that consumed by
other covered products within such type
(or class); or (B) a capacity or other
performance-related feature which other
products within such type (or class) do
not have, where such feature justifies a
higher or lower standard from that
which applies to other products within
such type (or class). (42 U.S.C. 6295(q)).
The second of these criteria is
applicable to the new product classes
proposed in this rulemaking, because
the new product classes are based on
product capacity. The justification of
different standards for the new product
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with louvered sides, and 20,000 Btu/h to 27,999 Btu/h.
with louvered sides, and 28,000 Btu/h or more.
without louvered sides, and 8,000 to 10,999 Btu/h.
without louvered sides, and 11,000 to 13,999 Btu/h.
classes of different capacities is
discussed above in this section.
4. Non-Regulatory Programs
DOE’s market assessment provides a
profile of the residential clothes dryer
and room air conditioner industries in
the United States. As part of the market
and technology assessment, DOE
reviews non-regulatory programs
promoting energy-efficient residential
appliances in the United States. Nonregulatory programs that DOE considers
in its market and technology assessment
include ENERGY STAR, a voluntary
labeling program jointly administered
by the U.S. Environmental Protection
Agency (EPA) and DOE. ENERGY STAR
identifies energy efficient products
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through a qualification process.29 To
qualify, a product must exceed Federal
minimum standards by a specified
amount, or if no Federal standard exists,
exhibit select energy-saving features.
ENERGY STAR specifications currently
exist for room air conditioners, but not
for residential clothes dryers.
BSH commented that it would
support ENERGY STAR qualification for
clothes dryers, as well as an energy label
system that would help consumers
purchase the most efficient models on
the market. According to BSH, the
European labeling system for clothes
dryers has resulted in benefits to
29 For more information, please visit https://
www.energystar.gov.
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consumers, manufacturers, and the
environment. (BSH, No. 23 at pp. 2, 6)
The California Utilities commented that
a revised test procedure could better
differentiate clothes dryer models in
terms of energy performance, facilitating
an ENERGY STAR program. According
to the California Utilities, there is
currently no ENERGY STAR program
because clothes dryers do not differ in
apparent energy use as measured by the
existing clothes dryer test procedure.
(California Utilities, No. 31 at p. 6).
DOE notes that, according to the joint
program between the EPA and DOE, the
EPA determines whether to add
qualification specifications for newly
covered products within ENERGY
STAR. DOE encourages the
implementation of ENERGY STAR
specifications and labeling as a means to
achieve national energy savings, and
would assist the EPA in applying the
DOE clothes dryer test procedure to
evaluate qualifying products in any
future ENERGY STAR ratings for clothes
dryers.
Energy labeling for clothes dryers
under the EnergyGuide program is
regulated by the FTC. (10 CFR 305)
Although DOE does not have the
authority under EPCA to revise the
regulations for energy labeling to
include clothes dryers, DOE would
provide technical information to the
FTC to support any new EnergyGuide
labeling requirement for these products.
5. Technology Options
As part of the market and technology
assessment, DOE develops a list of
technologies for consideration for
improving the efficiency of clothes
dryers and room air conditioners.
Initially, these technologies encompass
all those DOE believes are
technologically feasible (the first of the
four criteria in the screening analysis).
Chapter 3 of the preliminary TSD
includes the detailed list of all
technology options identified for clothes
dryers and room air conditioners. DOE
received several comments in response
to the technologies proposed in the
preliminary analysis to be analyzed for
clothes dryers and room air
conditioners.
a. Clothes Dryers
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Heat Pump Clothes Dryers
DOE notes that heat pump clothes
dryers function by recirculating the
exhaust air back to the dryer while
moisture is removed by a refrigerationdehumidification system. The warm and
damp exhaust air of the dryer enters the
evaporation coil of the dehumidifier
where it cools down below the dew
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point, and sensible and latent heat are
extracted. The heat is transferred to the
condenser coil by the refrigerant and
reabsorbed by the air, which is moving
in a closed air cycle. DOE notes that
there are no heat pump dryers currently
available on the U.S. market, but that
heat pump clothes dryers are available
on the market in Europe.
BSH commented that it foresees the
heat pump clothes dryer as an
innovative technology breakthrough for
improved efficiency in the next few
years in North America. BSH noted that
in Europe in the last 2 years the market
share for heat pump clothes dryers has
increased from 3 to 11 percent, and that
this success is based on four key factors:
(1) European energy consumption
values are comparable for all sizes of
clothes dryers because they are
independent of drum size; (2) the
percent range between energy classes in
Europe (A = best, B, C * * *) 30 remains
constant, so one energy classification is
not proportionally larger than another;
(3) realistic load quantities are used for
testing; and (4) automatic termination
control dryers are standard and are
given preferential treatment over timer
dryers (which tend to over dry and use
more energy). (BSH, No. 23 at p. 2)
In the context of the energy
conservation standards rulemaking,
DOE conducts its analysis to determine
an economically justified minimum
efficiency standard. DOE notes that the
efficiency levels proposed in the
preliminary analyses are not used for
product marketing classification as they
are in the European energy label system.
As a result, DOE does not intend to
create an energy class system as part of
the energy conservation standard
rulemaking. As discussed in section
III.A.1.d, DOE also notes that its clothes
dryer test procedure specifies a single
test load size for standard-size clothes
dryers and a single test load size for
compact-size clothes dryers. In response
to BSH’s comments regarding realistic
load quantities, DOE also notes that it
amended the clothes dryer test
procedure to revise the test load size for
standard-size clothes dryers to be more
representative of current consumer
usage habits, as discussed in the TP
Final Rule. 76 FR 972, 977 (January 6,
2011). Also, as discussed above in
section III.A.1.b, DOE did not amend the
test procedure in the TP Final Rule to
better account for automatic cycle
termination. DOE notes that the clothes
dryer test procedure provides a field use
30 The European energy label system uses a letter
scale from ‘‘A’’ to ‘‘G’’ to rate the efficiency and
performance of certain appliance products. A rating
of ‘‘A’’ denotes the highest efficiency unit, whereas
a rating of ‘‘G’’ denotes the lowest efficiency unit.
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factor for automatic termination control
dryers and a different field use factor for
timer dryers. As discussed above, DOE
notes that heat pump clothes dryers are
available on the market in Europe. DOE
also notes that multiple clothes dryer
manufacturers that manufacture heat
pump clothes dryers for the
international markets also manufacture
clothes dryers for the United States. For
these reasons, DOE believes that heat
pump technology is technologically
feasible and therefore considered heat
pump clothes dryers for the engineering
analysis.
Heat Recovery
For this technology option, a heat
exchanger is used to recover exhaust
heat energy and to preheat inlet air.
Based on research of this technology
and discussions with manufacturers,
this system is feasible for both gas and
electric dryers because none of the
exhaust air re-enters the dryer. Energy
savings are achieved either by using the
additional recovered heat to increase the
temperature of the air entering the drum
and thus reduce the drying time or by
using the additional recovered heat to
reduce the required heater input power,
depending on how the system is
implemented. As reported in chapter 3
of the preliminary TSD, estimated
energy savings from several researchers
range from 2 to 6 percent in noncondensing mode.
The California Utilities and NRDC
commented that the energy savings
associated with heat recovery would be
significantly higher. According to the
California Utilities, 80-percent efficient
counter-flow heat exchangers are widely
available, while 90-percent efficient
heat exchangers are technically feasible.
The California Utilities estimate energy
savings for heat recovery to be about 30
percent for electric clothes dryers and
20 percent for gas clothes dryers. The
California Utilities noted that ventless
dryers are available in the United States
and are common in Europe, suggesting
that heat recovery is both technically
feasible and practical to manufacture
(California Utilities, No. 31 at pp. 6–7,
12, 21) The California Utilities stated
that the technologies behind heat
recovery and ventless clothes dryers
differ only in where the air from the
heat exchanger is routed. In ventless
clothes dryers, cooled exhaust air is
channeled to the heater to be reused and
the warmed room air is vented back to
the room. For heat recovery, these are
reversed, such that cooled exhaust air is
vented (usually outside) and the
warmed room air is channeled into the
heater. (California Utilities, No. 31 at p.
6) The California Utilities provided a
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specific example of a dryer with an EF
of 3.10, or 2.26 kWh per cycle, which
is stopped at the end of the bulk drying
stage. The clothes dryer in this example
is assumed to have an average exhaust
temperature of 110 °F, or 40 °F above
ambient temperature. According to the
California Utilities, a 90-percent
efficient counter-flow heat exchanger
would preheat the incoming air by 36
°F, which would result in 0.684 kWh
directly replacing heat that would
otherwise be supplied by the electric
resistance heater. The replaced heat
would correspond to 1.58 kWh per cycle
to dry the 7-lb. test load and an EF of
4.43. This would result in a 30-percent
energy savings due to heat recovery. Id.
According to NRDC, as stated in the
ECOS report, 40-percent energy savings
(1.348 kWh of heater energy savings per
cycle) can be achieved for a load of
cotton towels with a 90-percent efficient
air-to-air cross-flow heat exchanger
between the exhaust and intake of the
clothes dryer. (NRDC, No. 30 at p. 27)
DOE is not aware of any data
indicating that a cross-flow heat
exchanger may be used in a clothes
dryer application and achieve 80percent or 90-percent efficiency. DOE
notes that an air-to-air heat exchanger
used in a clothes dryer must have
sufficient fin spacing to prevent lint
fouling of the heat exchanger. DOE also
notes that the ECOS report does not
provide details of how the potential
energy savings associated with heat
recovery were calculated (that is, data
for airflow, temperature, specific heat,
and similar items). DOE notes that the
California Utilities comment stated that,
for an exhaust temperature of 110 °F
and a 90-percent efficient cross-flow
heat exchanger, the energy savings
would be approximately 0.684 kWh per
cycle. However, the ECOS report
estimated that the energy savings would
be 1.348 kWh for what appear to be the
same conditions. Because the details of
how these estimates were calculated
were not provided, DOE is unable to
verify the energy savings suggested by
the commenters would occur.
DOE also notes that it is unclear
whether the estimates provided by the
California Utilities and the ECOS report
for heat recovery considered
condensation in the exhaust air stream.
Manufacturers indicated that such heat
recovery systems must be designed to
prevent condensation in the exhaust
ducting, and as a result, there is a limit
to the amount of heat that can be
recovered.
DOE notes that it has revised the costefficiency analysis from the preliminary
analyses based on its analysis and
discussions with manufacturers. As
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discussed in section IV.C.2, inlet air
preheating (that is, heat recovery) is
considered applicable to the maximumavailable efficiency levels for vented
clothes dryer product classes, and DOE
estimates this technology option would
provide roughly a 6–7 percent
improvement in efficiency.
Manufacturers confirmed during
interviews with DOE that this efficiency
improvement accurately estimates the
energy savings potential associated with
inlet-air preheating in real-world
applications, considering such factors as
condensation in the exhaust airstream
and lint accumulation in the heat
exchanger.
Hydronic Heating
HTC requested that DOE consider its
‘‘hydronically heated’’ clothes dryer,
which uses a self-contained hydronic
heating system, as a technology option.
According to HTC, this technology
currently exists, but products
incorporating such a design are not yet
being sold pending HTC’s resolution of
licensing and private labeling
considerations. (HTC, No. FDMS
DRAFT 0068 at p. 3) DOE is also aware
of HTC’s stand-alone hydronic heater
that could be implemented as a clothes
dryer heat source, utilizing water or
other heat transfer fluids and an
immersion element similar to a water
heater. The heated fluid would then
pass through a heat exchanger, where
the heat would be transferred to the air
entering the drum and then pumped
back to the hydronic heater. Because
DOE has not been able to identify any
clothes dryers with such hydronic
heating systems currently on the market,
however, DOE is unable to evaluate the
energy consumption associated with a
clothes dryer equipped with a standalone hydronic heating device and thus
has not included it as a design option
in today’s direct final rule.
Improved Cycle Termination
According to NRDC, the test results in
the ECOS report show that a clothes
dryer equipped with improved
automatic cycle termination saves 0.76
kWh per load compared to a clothes
dryer with electromechanical controls.
(NRDC, Public Meeting Transcript, No.
21.4 at p. 42) The California Utilities
noted that ‘‘high performance’’
automatic cycle termination controls are
already available in dryers on the
market that produce energy savings on
the order of 10-percent or more above
current energy use, although DOE’s
clothes dryer test procedure must be
amended to measure this improvement.
The California Utilities strongly urged
DOE to analyze this technology option.
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22489
For the reasons described in section
III.A.1.b, DOE did not adopt in the TP
Final Rule the amendments for
measuring automatic cycle termination
proposed in the TP SNOPR. Therefore,
DOE did not analyze this technology
option further.
Modulating Heat
The NRDC/ECOS report stated that if
a conventional gas clothes dryer is
improved with modulating burner
technology, the performance of the
clothes dryer would be roughly
equivalent to or superior to many heat
pump clothes dryers in terms of CO2
emissions, source energy use, and
energy cost. This performance would be
achieved while also offering faster
drying times and lower initial purchase
price. (NRDC, No. 30 at pp. 37–38) DOE
notes that heat pump technology is
applicable only to electric clothes
dryers, for which DOE maintains a
product class distinction from gas
clothes dryers. DOE analyzed
technologies currently available on the
market and concluded that two-stage gas
burner modulation is necessary to
achieve max-tech performance. Because
DOE is not aware of any gas clothes
dryers with fully modulating burner
systems currently on the market, DOE
did not consider this technology further
in developing the standards set forth in
today’s direct final rule. DOE does
include this technology as a longer-term
means to achieve energy efficiency
improvements in a sensitivity analysis
described in chapter 16 of the direct
final rule TSD.
Outdoor Intake Air
The California Utilities and NRDC
suggested that DOE consider as a
technology option those technologies
that draw intake air for the clothes dryer
from outside the residence, thereby
reducing space conditioning loads in
the home. (California Utilities, No. 31 at
p. 8; NRDC, Public Meeting Transcript,
No. 21.4 at p. 44) The California
Utilities further suggest that such a
technology option may be necessitated
by the trend in residential new
construction towards tighter building
envelopes. Tighter envelopes result in
reduced exhaust airflow from the
clothes dryer and greater
depressurization impacts, which can
potentially result in indoor air quality
problems. According to the California
Utilities, the HVAC load is proportional
to the amount of air vented from the
clothes dryer, but this load can be
reduced or eliminated by reducing the
total air drawn through the dryer or by
having a separate outside air intake and
vent. The California Utilities estimate
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energy savings due to reductions in
HVAC load on the order of 10 percent
or more. (California Utilities, No. 31 at
pp. 2, 8–9) The NRDC/ECOS report
states that outdoor intake air could save
about 1 kWh per load, but that without
heat recovery this technology option
would only be advantageous in the
summer. The NRDC/ECOS report adds
that with heat recovery outdoor intake
air is advantageous year-round. (NRDC,
No. 30 at pp. 27–28).
As discussed in section III.A.1.f,
EPCA requires that any test procedures
prescribed or amended under this
section shall be reasonably designed to
produce test results which measure
energy efficiency, energy use, water use,
or estimated annual operating cost of a
covered product during a representative
average use cycle or period of use. (42
U.S.C. 6293(b)(3)) DOE believes that
accounting for the effects of clothes
dryers on HVAC energy use is
inconsistent with this requirement.
Therefore, DOE did not revise the
clothes dryer test procedure to account
for HVAC energy use in the TP Final
Rule, and does not consider outdoor
intake air as an additional technology
option.
mstockstill on DSKH9S0YB1PROD with RULES2
Reverse Tumble
NRDC commented that the use of
synthetic mixed fabric in the DOE
clothes dryer test procedure may be
underestimating the efficiency
improvement associated with reverse
tumble. NRDC stated that cotton and
other natural fabrics tend to ball up
when rotated continuously in one
direction, and therefore the test
procedure is underestimating the
potential benefit of reverse tumble.
(NRDC, Public Meeting Transcript, No.
21.4 at pp. 42–43) As discussed in
section III.A.1.d, DOE is unaware of data
to determine the composition of
clothing types and materials that would
produce results as repeatable as those
resulting from use of the current test
cloth. Therefore, DOE did not amend
the clothes dryer test procedure in the
TP Final Rule to change the test load
composition. In the absence of
comments providing information on the
efficacy of reverse tumble for the
existing DOE test cloth, DOE continues
to believe that no measurable energy
savings are associated with this
technology option.
Switch Mode Power Supply
ACEEE stated that the technology to
reduce standby power consumption to
less than 1 W, via switch mode power
supply controllers, is widely available at
low cost. (ACEEE, No. 24 at p. 2) NRDC
stated that the ECOS report found
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standby power levels in the range of
0.03 to 0.05 W with switch mode power
supply controllers, corresponding to
energy consumption of 4–6 kWh over
the lifetime of the clothes dryer. (NRDC,
No. 26 at p. 3; NRDC, No. 30 at p. 5)
DOE has observed that switching power
supplies offer the highest conversion
efficiencies (up to 75 percent) and
lowest no-load standby losses (0.2 W or
less), though at a higher cost, higher part
count, and greater complexity than
conventional linear power supplies.
DOE noted, however, that switch mode
power supplies are incorporated in
many clothes dryers currently on the
market, and thus has included switch
mode power supplies in its analysis for
today’s direct final rule.
Vent Selector Switch
The NRDC/ECOS report suggested as
an additional technology option the
incorporation of a ‘‘summer/winter’’
selector so that the waste heat would be
delivered to the building during the
winter instead of being vented outside.
According to the ECOS report, 60
percent of the energy used by the
clothes dryer evaporates water from the
clothes load and the other 40 percent is
available as waste heat to the room.
(NRDC, No. 30 at p. 28) For the reasons
discussed in section III.A.1.f, DOE did
not consider the energy impacts on the
space conditioning requirements in
amending its clothes dryer test
procedure, and thus did not evaluate
this technology further.
b. Room Air Conditioners
DOE received comments from several
interested parties recommending that
DOE also consider the following
technologies: Alternative refrigerants,
suction line heat exchangers (SLHX),
flooded evaporator coils, and automatic
timers.
AHAM commented that it had no
additional design option suggestions for
room air conditioners, and that many of
the design options proposed and
initially evaluated by DOE are already
employed by a number of manufacturers
to increase the efficiency of today’s
products (AHAM, No. 25 at p. 4).
Alternative Refrigerants
DOE notes that HCFC–22 was
traditionally the refrigerant used in
room air conditioners. On December 15,
2009, the EPA issued a final rule
banning the sale and distribution of airconditioning and refrigeration
appliances containing HCFC–22,
applying to appliances and components
manufactured on or after January 1,
2010. 74 FR 66412, 66418.
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During individual manufacturer
interviews conducted for the
preliminary analysis, manufacturers
revealed that the room air conditioning
industry was transitioning to using
R–410A refrigerant. DOE also discussed
the transition with compressor
manufacturers, who were developing
and manufacturing R–410A rotary
compressors for use in room air
conditioners.
Because of the phaseout of HCFC–22
and the transition to R–410A, DOE
conducted the analysis for today’s direct
final rule based on use of R–410A
refrigerant. DOE’s analysis of R–410A
room air conditioners is presented in
chapter 5 of the direct final rule TSD.
A number of commenters urged DOE
to consider alternative refrigerants as a
technology option in the screening
process. Both ACEEE and the California
Utilities suggested that DOE consider
hydrocarbon refrigerants possible
alternatives to R–410A. (ACEEE, No. 24
at p. 4; California Utilities, No. 31 at p.
16) The California Utilities also
suggested that DOE consider R–407C.
(California Utilities, No. 31 at p. 16)
NPCC supported consideration of
alternative refrigerants as well. (NPCC,
No. 32 at p. 4)
DOE notes that no hydrocarbon
refrigerants are currently included as
acceptable for use in air-conditioning
applications by the EPA Significant
New Alternatives Policy (SNAP)
Program list. This program was
established to identify acceptable
alternatives to ozone-depleting
substances used in a variety of
applications.31 The list identifies
allowed applications for use of the
alternative substances. Since there have
been no hydrocarbons included on the
SNAP list as acceptable for use in air
conditioning appliances, DOE did not
consider these alternative refrigerants in
its analysis.
R–407C, on the other hand, is
approved as an acceptable substitute for
use in air-conditioning equipment,
which includes room air conditioners.
DOE analyzed R–407C to determine
whether it offers efficiency
improvement over R–410A, using the
energy model developed and used
throughout the engineering analysis.
The results indicate that the efficiency
of R–407C is less than that of R–410A
for room air conditioners operating at
rating conditions. As a result, DOE
determined that use of R–407C
refrigerant is not a viable design option.
Additional details of this analysis are
31 See the SNAP program Web site at https://
www.epa.gov/ozone/snap/.
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presented in chapter 3 of the direct final
rule TSD.
DOE also performed research to
identify other potential alternative
refrigerants during the preliminary
analysis, but was unable to identify
viable alternative refrigerants to
R–410A. The research included a review
of air-conditioning products, academic
articles, industry publications, and
interviews with component vendors.
DOE sought to include refrigerants that
were approved by the EPA for use in
room air conditioners. For more detail,
see chapter 3 of the direct final rule
TSD.
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Suction Line Heat Exchangers
An SLHX transfers heat between the
high-temperature liquid refrigerant
leaving the condenser and the lowtemperature vaporized refrigerant
leaving the evaporator. The heat
exchanger lowers the outgoing
temperature of the liquid refrigerant and
raises the temperature of the outgoing
vapor refrigerant. This heat transfer
allows for the liquid refrigerant to be
subcooled before entering the expansion
device and offers the potential to
increase the vapor-compression cycle’s
cooling capacity.
The California Utilities and NPCC
argued that DOE should consider SLHXs
based on possible performance
improvements (California Utilities, No.
31 at pp. 14–15; NPCC, No. 32 at p. 4).
The California Utilities comment cited
the 1997 room air conditioner
rulemaking, which cited a study by
Allied-Signal demonstrating a 4 percent
increase in system performance with the
addition of a SLHX in a 2.5 ton split
system AC application, and simulations
by NIST for split-system air
conditioning applications showing EER
improvement of 3.5 percent 32 for
R–410A systems using SLHX.
(California Utilities, No. 31 at pp. 14–
15).
DOE reviewed the room air
conditioner rulemaking cited by the
California Utilities and noted that the
improvement was based on a
comparison to a non-optimized system.
DOE also considered the NIST
simulation study referenced by the
California Utilities.33 In this study, the
EER improvement of 3.5 percent
occurred for an outdoor temperature of
32 This efficiency increase was described in the
source as reduction of an EER loss of 6.5 percent
(when comparing R–410A performance to HCFC–
22, at 131 °F outdoor temperature) to 3.2 percent.
33 National Institute of Standards and
Technology. Performance of R–22 and its
Alternatives Working at High Outdoor
Temperatures. In Eighth International Refrigeration
Conference at Purdue University, 2000. West
Lafayette, IN—July 25–28, 2000, pp. 47–54.
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131 °F. The paper includes performance
data for an outdoor temperature
condition of 95 °F (which is used in the
DOE Test Procedure), for which the EER
improvement was 1.0 percent 34 using a
SLHX. These results were simulated for
systems using reciprocating-type
compressors, and the analyzed systems
were not optimized to maximize
performance of individual fluids. There
is no indication in the paper that the
simulations address room air
conditioners because it does not
mention outdoor air moisture content,
which would be an important parameter
affecting performance of room air
conditioners. While the simulations
show a potential for slight performance
improvement, it is not clear that the
simulations are applicable for room air
conditioners, and the results were not
validated experimentally. DOE therefore
concludes that the cited studies do not
support the conclusion that SLHXs will
significantly improve room air
conditioner efficiency.
During interviews conducted during
the preliminary and final rule analysis,
manufacturers did not indicate that
SLHX could be used to improve system
performance. Furthermore, use of
SLHX’s may be inconsistent with the
operating temperature limits for
compressors. The technology
significantly raises the temperature of
the suction gas entering the compressor.
Because hermetic compressors are
cooled by the suction gas, the
compressor will overheat if the suction
gas temperature exceeds limits specified
by the compressor manufacturer. DOE
notes that 65 °F is typically the highest
allowable suction temperature for R–
410A rotary compressors. DOE noted
that a SLHX operating at close to 50%
effectiveness (as analyzed in the NIST
study) would raise suction temperature
roughly 20 °F, thus significantly
exceeding the specified limit. For
additional details of this analysis, see
chapter 3 of the TSD. Use of this
technology would adversely affect the
reliability of the compressor, and
consequently, DOE cannot consider
SLHX as a design option.
Flooded Evaporator Coils
Flooded evaporator coils are
evaporators for which refrigerant flow is
higher than the amount that can be
evaporated. As a result, a portion of the
refrigerant leaves such an evaporator
unevaporated (that is, still in the liquid
phase). Such a design assures that liquid
34 Again, expressed as reduction of an EER loss
of 2.5 percent (when comparing R–410A
performance to HCFC–22, at a 95 °F outdoor
temperature) to 1.5 percent.
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is available for boiling heat transfer
throughout the evaporator. Because
boiling heat transfer is much more
effective than vapor phase heat transfer,
the evaporator’s heat transfer
characteristics can be improved.
However, the liquid refrigerant leaving
the evaporator cannot be routed to the
compressor, because (1) compressors
cannot tolerate significant amounts of
liquid without damage; and (2) this
would represent lost cooling and lost
efficiency. The liquid refrigerant returns
to a reservoir from which it can be
redirected to the evaporator. The
reservoir inventory is controlled to
allow low pressure vapor to exit to the
compressor, while ‘‘fresh’’ refrigerant
from the condenser enters through an
expansion valve that may vary flow
based on the reservoir liquid level.
The California Utilities stated that
DOE should consider flooded
evaporator coils as a design option, as
this technology is used in some
refrigerant systems (California Utilities,
No. 31 at p. 14). Oak Ridge National
Laboratories (ORNL) tests on window
air conditioners found that a flooded
evaporator coil setup using R–22
increased cooling capacity by 8
percent.35
DOE considered the ORNL study
referenced by the California Utilities.
The article describes work in which a
room air conditioner was tested,
modified to have a flooded evaporator,
and then retested. Data provided in the
article shows that the evaporator of the
unmodified unit was very poorly
controlled. A plot graph of heat
exchanger tube temperature versus
evaporator length shows the tube
temperature rising after the refrigerant
liquid had traveled 60 percent of the
heat exchanger tube length, indicating
that the refrigerant liquid has
evaporated. Air conditioner designs that
incorporate flooded evaporator coils are
not optimized, and the performance of
such designs could have improved
significantly with much less costly
changes than converting to a flooded
evaporator. As a result, DOE does not
believe that the cited ORNL study
supports analyzing flooded evaporator
coils as a technology option in the room
air conditioner engineering analysis.
Automatic Timers
The California Utilities stated that
DOE should consider automatic timers
as a design option in its analysis,
35 V.C. Mei and F.C. Chen, et al. Experimental
Analysis of a Window Air Conditioner with R–22
and Zeotropic Mixture of R–32/125/134a. Energy
Renewable and Research Section, Energy Division,
Oak Ridge National Laboratory: Oak Ridge, TN.
August 1995.
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arguing that many room air conditioner
models currently feature an automatic
timer that shuts off operation after a predetermined amount of time, thus
avoiding unnecessary cooling
(California Utilities, No. 31 at p. 14).
The California Utilities argued that this
is a simple and inexpensive option that
can be implemented to improve
consumer utility and provide potential
energy savings.
DOE notes that automatic timers may
save energy by preventing cooling of the
space when occupants have left.
However, the benefits of automatic
timers would not be measured by the
current or amended test procedures,
unless the test procedure allocation of
hours to full-load and standby or off
mode were adjusted based on presence
of the automatic timer. Information to
allow proper allocation of the hours in
this fashion is not available, thus the
test procedure rulemaking did not
establish adjustment of hours to address
this technology. DOE acknowledges the
importance of conducting appropriate
test programs to provide a basis for
crediting technologies such as automatic
timers. DOE will consider supporting
such work to assist in a future test
procedure rulemaking. At this time,
however, DOE cannot consider
automatic timers in the engineering
analysis.
B. Screening Analysis
DOE uses the following four screening
criteria to determine which technology
options are suitable for further
consideration in a standards
rulemaking:
1. Technological feasibility. DOE will
consider technologies incorporated in
commercial products or in working
prototypes to be technologically
feasible. (The technological feasibility of
options was discussed in the preceding
section as part of the market and
technology assessment.)
2. Practicability to manufacture,
install, and service. If mass production
and reliable installation and servicing of
a technology in commercial products
could be achieved on the scale
necessary to serve the relevant market at
the time the standard comes into effect,
then DOE will consider that technology
practicable to manufacture, install, and
service.
3. Adverse impacts on product utility
or product availability. If DOE
determines a technology would have
significant adverse impact on the utility
of the product to significant subgroups
of consumers, or would result in the
unavailability of any covered product
type with performance characteristics
(including reliability), features, sizes,
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capacities, and volumes that are
substantially the same as products
generally available in the United States
at the time, it will not consider this
technology further.
4. Adverse impacts on health or
safety. If DOE determines that a
technology will have significant adverse
impacts on health or safety, it will not
consider this technology further.
10 CFR part 430, subpart C, appendix A,
(4)(a)(4) and (5)(b).
Technologies that pass through the
screening analysis are referred to as
‘‘design options’’ in the engineering
analysis. Details of the screening
analysis are in chapter 4 of the direct
final rule TSD.
1. Clothes Dryers
In the preliminary analysis, DOE
identified the following technology
options that could improve the
efficiency of clothes dryers, as shown in
Table IV.5.
TABLE IV.5—TECHNOLOGY OPTIONS
FOR RESIDENTIAL CLOTHES DRYERS
Dryer Control or Drum Upgrades:
Improved termination.
Increased insulation.
Modified operating conditions.
Improved air circulation.
Reverse tumble.
Improved drum design.
Methods of Exhaust Heat Recovery (vented
models only):
Recycle exhaust heat.
Inlet air preheat.
Inlet air preheat, condensing mode.
Heat Generation Options:
Heat pump, electric only.
Microwave, electric only.
Modulating, gas only.
Water-cooling, ventless electric only.
Indirect heating.
Component Improvements:
Improved motor efficiency.
Improved fan efficiency.
Standby Power Improvements:
Switching power supply.
Transformerless power supply with autopowerdown.
For the preliminary analysis, DOE
considered eliminating the following
clothes dryer technology options from
consideration:
Microwave, Electric Only
DOE’s research suggested that
significant technical and safety issues
would be introduced with microwave
drying by the potential arcing from
metallic objects in the fabric load,
including zippers, buttons, or ‘‘stray’’
items such as coins. While DOE noted
that efforts have been made to mitigate
the conditions that are favorable to
arcing, or to detect incipient arcing and
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terminate the cycle, the possibility of
fabric damage could not be completely
eliminated. Thus, for these reasons of
consumer utility and adverse impacts
on safety, microwave drying was not
considered further for analysis.
Water-Cooling, Ventless Electric Only
DOE noted that water-cooling for
ventless electric clothes dryers, which
uses water as a cooling fluid to
condense the moisture in the air exiting
the drum, would require significant
plumbing to circulate water through a
heat exchanger in the dryer and add to
the complexity of maintenance. Such
home renovations would require
installing a water hook-up and drain in
the laundry area, which is not typically
done for clothes dryers. Therefore, DOE
determined in the preliminary analysis
that the water-cooling for ventless
electric dryers technology option does
not meet the criterion of practicability to
install and service on a scale necessary
to serve the relevant market at the time
of the compliance date of a new
standard and proposed screening it out
of the analysis. DOE did not receive any
comments objecting to this
determination. For these reasons, DOE
is continuing to screen out watercooling for ventless electric clothes
dryers in today’s final rule.
Indirect Heating
DOE tentatively concluded in the
preliminary analysis that indirect
heating would be viable only in
residences which use a hydronic
heating system. An energy conservation
standard that required indirect heating
would require homes without a
hydronic heating system to have such a
system installed. DOE also notes that
there would be added maintenance
requirements because the home’s
hydronic heating system because it
would be used more frequently (that is,
year-round). Also, to derive dryer heat
energy from the home’s heating system,
significant plumbing work would be
required to circulate heated water
through a heat exchanger in the dryer.
Therefore, DOE determined that this
technology option does not meet the
criterion of practicability to install on a
scale necessary to serve the relevant
market at the time of the compliance
date of a new standard and did not
consider it further in the preliminary
analysis.
In response, ACEEE commented that
DOE should reconsider its decision to
leave water-cooled clothes dryers
unregulated because these products are
very water-intensive. ACEEE stated that,
although water-cooled clothes dryers are
currently of very limited use in the
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United States, this technology is used
overseas and could find a larger market
niche in the United States if left
unregulated. (ACEEE, No. 24 at
pp. 2–3) DOE believes that the current
unavailability of such products in the
Unites States, along with the reasons
noted above, confirms its initial
conclusion regarding the failure of this
technology to meet the screening criteria
of practicability to install and service on
the scale necessary to serve the relevant
market at the time of the effective date
of a new standard. In addition, EPCA
does not authorize DOE to set waterefficiency standards for clothes dryers.
(42 U.S.C. 6291(6), 6295(g)) Therefore,
DOE continues to screen out this
technology option.
No other comments were received
objecting to the technology options
which were screened out in the
preliminary analysis, or to the initial
determination that the remaining design
options met all of the screening criteria
listed above. Therefore, DOE considered
the same design options in the final rule
as those evaluated in the preliminary
analysis (see Table IV.6).
TABLE IV.6—RETAINED DESIGN OPTIONS FOR RESIDENTIAL CLOTHES
DRYERS
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Dryer Control or Drum Upgrades:
Improved termination.
Increased insulation.
Modified operating conditions.
Improved air circulation.
Reverse tumble.
Improved drum design.
Methods of Exhaust Heat Recovery (vented
models only):
Recycle exhaust heat.
Inlet air preheat.
Inlet air preheat, condensing mode.
Heat Generation Options:
Heat pump, electric only.
Modulating, gas only.
Component Improvements:
Improved motor efficiency.
Improved fan efficiency.
Standby Power Improvements:
Switching power supply.
Transformerless power supply with autopowerdown.
2. Room Air Conditioners
In the preliminary analysis, DOE
identified the following technology
options that could improve the
efficiency of room air conditioners, as
shown in Table IV.7.
TABLE IV.7—TECHNOLOGY OPTIONS
FOR ROOM AIR CONDITIONERS
Increased Heat Transfer Surface Area:
Increased frontal coil area.
Increased depth of coil (add tube rows).
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TABLE IV.7—TECHNOLOGY OPTIONS dryers and room air conditioners. For
FOR ROOM AIR CONDITIONERS— this analysis, DOE relied upon
efficiency data published in multiple
Continued
Increased fin density.
Add subcooler to condenser coil.
Increased Heat Transfer Coefficients:
Improved fin design.
Improved tube design.
Hydrophilic film coating on fins.
Spray condensate onto condenser coil.
Microchannel heat exchangers.
Component Improvements:
Improved indoor blower and outdoor fan
efficiency.
Improved blower/fan motor efficiency.
Improved compressor efficiency.
Part-Load Technology Improvements:
Two-speed, variable-speed, or modulatingcapacity compressors.
Thermostatic or electronic expansion
valves.
Thermostatic cyclic controls.
Standby Power Improvements:
Switching power supply.
For the preliminary analysis, DOE
tentatively concluded that all room air
conditioner technology options met the
screening criteria listed above and did
not propose to eliminate any of these
technology options from consideration.
DOE did not receive any comments
objecting to this list of technology
options and, therefore, retained all of
the technologies in Table IV.7 as room
air conditioner design options. As
described and explained below in
section IV.C.1.b below, however, some
of the technologies were not considered
in the engineering analysis.
C. Engineering Analysis
The engineering analysis develops
cost-efficiency relationships to show the
manufacturing costs of achieving
increased efficiency. DOE has identified
the following three methodologies to
generate the manufacturing costs
needed for the engineering analysis:
(1) The design-option approach, which
provides the incremental costs of adding
to a baseline model design options that
will improve its efficiency; (2) the
efficiency-level approach, which
provides the relative costs of achieving
increases in energy efficiency levels,
without regard to the particular design
options used to achieve such increases;
and (3) the cost-assessment (or reverse
engineering) approach, which provides
‘‘bottom-up’’ manufacturing cost
assessments for achieving various levels
of increased efficiency, based on
detailed data as to costs for parts and
material, labor, shipping/packaging, and
investment for models that operate at
particular efficiency levels.
DOE conducted the engineering
analyses for this rulemaking using the
efficiency-level approach for clothes
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databases, including those published by
CEC, the Consortium for Energy
Efficiency (CEE), and ENERGY STAR,
which were supplemented with
laboratory testing, data gained through
engineering analysis, and primary and
secondary research. Details of the
engineering analysis are in chapter 5 of
the direct final rule TSD.
1. Technologies Not Analyzed
In performing the engineering
analysis, DOE did not consider for
analysis certain technologies that were
not evaluated for one or more of the
following reasons: (1) Data are not
available to evaluate the energy
efficiency characteristics of the
technology; (2) available data suggest
that the efficiency benefits of the
technology are negligible; and (3) for the
reasons stated in the TP Final Rule, DOE
did not amend the test procedure to
measure the energy impact of these
technologies.
In the preliminary analysis, DOE did
not include the following design
options:
a. Clothes Dryers
Reverse Tumble
As discussed in section IV.A.5.a,
NRDC commented that the DOE clothes
dryer test procedure may be
underestimating the efficiency
improvement associated with reverse
tumble due to the composition of the
test cloth. (NRDC, Public Meeting
Transcript, No. 21.4 at pp. 42–43)
Because DOE did not amend the
specifications for the test cloth
composition in the TP Final Rule (as
discussed in section III.A.1.d), and in
the absence of comments providing
information on the efficacy of reverse
tumble for the existing DOE test cloth,
DOE continues to conclude that no
measurable energy savings are
associated with this design option.
Thus, this design option was not
considered further in the analysis for
today’s final rule.
Improved Termination
For the reasons noted in section
III.A.1.b, DOE did not adopt
amendments to its clothes dryer test
procedure to better account for
automatic cycle termination. Therefore,
energy savings due to improved
termination technologies cannot be
measured according to the test
procedure, and this design option was
not considered further in the analysis
for today’s direct final rule.
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b. Room Air Conditioners
DOE eliminated the following
technologies from further consideration
due to the three criteria mentioned
above.
1. Improved fin design
2. Improved tube design
3. Hydrophilic-film coating on fins
4. Spray condenser onto condenser coil
5. Improved indoor blower and outdoor
fan efficiency
6. Variable speed compressors
7. Thermostatic or electronic expansion
valves
8. Thermostatic cyclic controls
Of these technologies, numbers
1 through 4 are used in baseline
products. Information indicating
efficiency improvement potential is not
available for number 5. Any potential
energy savings of technologies 6 through
8 cannot be measured with the
established energy use metric because
those technologies are associated with
part-load performance. As discussed in
Section III.A.2.d above, DOE did not
amend the test procedure to measure
part-load performance of room air
conditioners. Chapter 5 of the direct
final rule TSD discusses these reasons
in greater detail.
2. Efficiency Levels and Cost-Efficiency
Results
a. Clothes Dryers
In the preliminary analysis, DOE
analyzed active mode and standby mode
separately to develop integrated costefficiency results. For vented clothes
dryer product classes, DOE proposed
the active mode efficiency levels shown
in Table IV.8, which were based on EF
values measured using the previous
clothes dryer test procedure. For
ventless clothes dryer product classes,
DOE proposed the active mode
efficiency levels shown in Table IV.9,
which were based on EF values
measured using the previous clothes
dryer test procedure without the
requirement to install an exhaust
simulator. DOE proposed the standby
power levels shown in Table IV.10 for
all clothes dryer product classes.
TABLE IV.8—CLOTHES DRYER ACTIVE MODE EFFICIENCY LEVELS (EF)—VENTED PRODUCT CLASSES
Efficiency level (EF) lb/kWh
Efficiency level
description
Level
Baseline .......................
1 ...................................
2 ...................................
3 ...................................
4 ...................................
Electric
standard
DOE Standard .......................................................................
Gap Fill ..................................................................................
Gap Fill ..................................................................................
Gap Fill/Maximum Available ..................................................
Max-Tech ...............................................................................
Electric
compact
(120V)
3.01
3.10
3.16
3.4
4.51
3.13
3.22
3.29
3.54
4.70
Electric
compact
(240V)
2.90
2.98
3.09
3.2
4.35
Gas
2.67
2.75
2.85
3.02
....................
TABLE IV.9—CLOTHES DRYER ACTIVE MODE EFFICIENCY LEVELS (EF)—VENTLESS PRODUCT CLASSES
Efficiency level (EF)
lb/kWh
Level
Efficiency level description
Baseline .......................
1 ...................................
2 ...................................
3 ...................................
DOE Test Data ......................................................................................................................
Gap Fill ..................................................................................................................................
Gap Fill ..................................................................................................................................
Max-Tech ..............................................................................................................................
Electric
compact
(240V)
2.37
2.39
2.59
3.55
Electric
combination
washer/
dryer
1.95
2.21
2.42
3.32
TABLE IV.10—CLOTHES DRYER STANDBY POWER LEVELS
Power Input
W
Level
Standby power source
Baseline .......................
1 ...................................
2 ...................................
DOE Test Data and Analysis ......................................................................................................................
DOE Test Data ............................................................................................................................................
DOE Test Data (Max-Tech) .........................................................................................................................
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In the preliminary analyses, DOE
developed integrated efficiency levels
based on the integrated EF (IEF) metric
proposed as an alternative option in the
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TP NOPR. The IEF is calculated as the
clothes dryer test load weight in lb
divided by the sum of active mode percycle energy use and standby/off mode
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2.0
1.5
0.08
per-cycle energy use in kWh. Table
IV.11 through Table IV.13 show the
integrated efficiency levels proposed in
the preliminary analyses.
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TABLE IV.11—CLOTHES DRYER INTEGRATED EFFICIENCY LEVELS (IEF)—VENTED PRODUCT CLASSES
Integrated efficiency level (IEF) lb/kWh
Level
Efficiency level description
Baseline .......................
1 ...................................
2 ...................................
3 ...................................
4 ...................................
5 ...................................
6 ...................................
Electric
standard
DOE Standard + 2.0 W Standby ...........................................
Gap Fill + 2.0 W Standby ......................................................
Gap Fill + 2.0 W Standby ......................................................
Gap Fill/Maximum Available + 2.0 W Standby .....................
Maximum Available + 1.5 W Standby ...................................
Maximum Available + 0.08 W Standby .................................
Heat Pump (Max-Tech) + 0.08 W Standby ..........................
2.96
3.04
3.10
3.33
3.35
3.40
4.52
Electric
compact
(120V)
Electric
compact
(240V)
3.00
3.08
3.15
3.37
3.41
3.53
4.69
Gas
2.79
2.86
2.96
3.06
3.10
3.19
4.34
2.63
2.71
2.80
2.97
2.98
3.02
....................
TABLE IV.12—CLOTHES DRYER INTEGRATED EFFICIENCY LEVELS (IEF)—VENTLESS ELECTRIC COMPACT (240V)
Level
Integrated
efficiency
level (IEF)
lb/kWh
Efficiency level description
Electric compact (240 V)
Baseline .......................
1 ..................................
2 ..................................
3 ..................................
4 ..................................
5 ..................................
Baseline + 2.0 W Standby .........................................................................................................................
Baseline + 1.5 W Standby .........................................................................................................................
Baseline + 0.08 W Standby .......................................................................................................................
Gap Fill + 0.08 W Standby ........................................................................................................................
Gap Fill + 0.08 W Standby ........................................................................................................................
Heat Pump (Max-Tech) + 0.08 W Standby ...............................................................................................
2.29
2.31
2.37
2.39
2.59
3.54
TABLE IV.13—CLOTHES DRYER INTEGRATED EFFICIENCY LEVELS (IEF)—VENTLESS ELECTRIC COMBINATION WASHER/
DRYERS
Integrated
efficiency level
(IEF) lb/kWh
Level
Efficiency level description
Electric
combination
washer/dryer
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Baseline ...................................................
1 ...............................................................
2 ...............................................................
3 ...............................................................
4 ...............................................................
5 ...............................................................
Baseline + 2.0 W Standby .......................................................................................
Gap Fill + 2.0 W Standby ........................................................................................
Gap Fill + 2.0 W Standby ........................................................................................
Gap Fill + 1.5 W Standby ........................................................................................
Gap Fill + 0.08 W Standby ......................................................................................
Heat Pump (Max-Tech) + 0.08 W Standby .............................................................
DOE also noted that it was
considering revisions to the clothes
dryer test procedure for active mode,
standby mode, and off mode, and that
those potential amendments would
affect the calculated IEF. (IEF has since
been renamed CEF for this direct final
rule to avoid confusion with an existing
industry standard.) AHAM commented
that, to ensure a rigorous analysis and
to mitigate confusion, DOE should
modify the baseline efficiency level to
account for a revised initial RMC in the
clothes dryer test procedure. (AHAM,
No. 25 at p. 10) The TP Final Rule was
published on January 6, 2011, and DOE
has adjusted the efficiency levels,
including the baseline level, as
discussed later in this section to account
for the impacts of all test procedure
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revisions, including those pertaining to
initial RMC.
Integrated Efficiency Metric
DOE received comments from
interested parties on the adequacy of
IEF as the energy efficiency metric for
clothes dryer energy conservation
standards. AHAM supported the
incorporation of standby mode and off
mode power into the total energy use of
clothes dryers, and commented that the
integrated metric is appropriate.
(AHAM, No. 25 at p. 2)
Whirlpool commented that standby
power technologies should not be
considered as separate design options
associated with specific TSLs, and that
doing so would avoid the requirement
that standby power be incorporated into
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1.90
2.15
2.34
2.36
2.42
3.31
the total energy use of the clothes dryer.
Whirlpool also stated that standby
levels should not vary by TSL.
(Whirlpool, No. 22 at p. 5) DOE notes
that the CEF metric at each TSL
incorporates a measure of standby
power as a contributor to energy use
along with energy use in active mode,
as required by EPCA. Because CEF does
not preferentially weigh the energy use
contributions attributable to either
active or standby mode, improvements
in CEF due to standby power reductions
are considered equally to those due to
active mode design options. For these
reasons, DOE believes that technologies
associated with standby power
reductions should be considered in the
definition of efficiency levels and thus
TSLs. In today’s direct final rule, DOE
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analyzes some TSLs that would require
standby power reductions only, and
some that would require reductions to
both standby power and active mode
power, as shown later in this section.
The NRDC/ECOS report stated that
the fact that natural gas clothes dryers
tend to have lower average energy
factors than electric clothes dryers could
lead consumers to believe that electric
dryers are generally more efficient.
NRDC/ECOS report stated that
conventional gas clothes dryers that
have been available for 30 years have
significantly less source energy use and
environmental impact than today’s
efficient electric clothes dryers. The
NRDC/ECOS report added that heat
pump clothes dryers that may reach the
U.S. market in the future have only
slightly lower impacts than
conventional gas clothes dryers. (NRDC,
No. 30 at pp. 17–18) The NRDC/ECOS
report further stated that the current EF
metric is not intuitive and fails to
capture meaningful differences between
electric and natural gas models.
According to the NRDC/ECOS report,
converting natural gas consumption into
equivalent electrical consumption on a
site basis ignores all of the losses that
occur in the electrical generation and
transmission process. The NRDC/ECOS
report stated that this draws attention
from the substantial advantage of most
gas clothes dryers—that they convert
their fuel directly into heat at the site
where it is needed, avoiding upstream
losses. According to the NRDC/ECOS
report, there are three ways to compare
gas and electric clothes dryers more
fairly: (1) Source Btu basis, (2) total CO2
emissions basis, and (3) energy cost
basis. The NRDC/ECOS report presented
test results which showed that the
standard natural gas clothes dryer uses
less source energy, costs less, and emits
less CO2 per lb of water removed than
any other option except (in some cases)
a heat pump clothes dryer. (NRDC, No.
30 at pp. 32–33) NRDC commented that
DOE should consider reporting actual
kWh and Btu consumption rather than
converting to site equivalent kWh.
NRDC stated that it would be more
useful to consumers to have information
on actual kWh of electricity and Btu of
gas consumed. According to NRDC,
organizations such as EnergyGuide,
ENERGY STAR, and Top Ten could use
this information to more accurately
inform prospective buyers on CO2
emitted or operating costs of a given
clothes dryer. (NRDC, No. 26 at pp. 1,
3)
In response, DOE notes that EPCA
defines ‘‘energy conservation standard’’
in relevant part as either: (1) A
performance standard which prescribes
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a minimum level of energy efficiency or
a maximum quantity of energy use; or
(2) for certain products, including
clothes dryers but not including room
air conditioners, a design requirement;
the term also includes any other
requirements that DOE may prescribe
under 42 U.S.C. 6295(r). (42 U.S.C.
6291(6)) EPCA also provides definitions
for the terms ‘‘energy use’’ and ‘‘energy
efficiency’’. Specifically, ‘‘energy use’’
refers to the quantity of energy directly
consumed by a consumer product at the
point of use, and ‘‘energy efficiency’’
means the ratio of the useful output of
services from a consumer product to the
energy use of such product. (42 U.S.C.
6291(4)–(5)) Therefore, an energy
conservation standard metric based on
source energy use, emissions, or annual
energy cost would be inconsistent with
the definitions set forth in EPCA. In
addition, DOE promulgates test
procedures for all product classes of
clothes dryers that calculate energy use
or energy efficiency on a consistent
basis, regardless of the type of energy
used. The energy content of either the
electricity or fossil fuels used at the site
of the clothes dryer may be equally and
interchangeably expressed in any unit of
energy measurement, including kWh
and Btu. DOE notes that, for other
covered products which may consume
gas as well as electricity, such as
cooking products, DOE defines an
energy efficiency metric (EF) in which
any contributory site gas energy use is
expressed in equivalent kWh. DOE
continues to believe that the measure of
CEF in terms of lb of clothes load per
kWh is meaningful and representative of
the performance for both electric and
gas clothes dryers, and thus is not
adopting alternative measures of energy
use or energy efficiency.
NRDC and the California Utilities
recommended that the metric be based
on the water removed in the clothes
load per kWh. The NRDC/ECOS report
stated that the efficiency using this
approach would be measured by
converting the lbs. of water removed
into kWh with a conversion factor of
0.308 (the kWh necessary to evaporate
a 1 lb. of water,) then dividing by the
measured energy consumption.
According to the NRDC/ECOS report,
this metric would be more meaningful
because it would measure the work
actually being performed by the clothes
dryer. The NRDC/ECOS report provided
as an example the case in which a
clothes dryer removed 3 lbs. of water
from either a heavily saturated small
load of absorbent fabrics such as cotton
or a lightly saturated larger load of
synthetics. According to the NRDC/
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ECOS report, testing and reporting the
results for both situations would help
consumers choose the most efficient
clothes dryers. The California Utilities
stated that the metric should be based
on lbs. of water removed per kWh, and
that this metric would correct for small
variations in actual test load or moisture
content. The California Utilities also
stated that this approach would
eliminate the need for the 0.66
correction factor (in sections 4.1–4.3 of
the current clothes dryer test
procedure), which corrects for the RMC
change during the test. (California
Utilities, No. 31 at pp. 11–12; NRDC,
Public Meeting Transcript, No. 21.4 at
pp. 49–50; NRDC, No. 26 at pp. 1–3;
NRDC, No. 30 at pp. 8, 32)
As noted above, DOE did not amend
the clothes dryer test procedure to allow
for testing materials other than the
current 50–50 cotton-polyester test
cloth. In addition, test conditions that
would allow the test load size or initial
RMC to vary would only be allowable if
the resulting measured energy efficiency
metric was independent of such
variations, implying that the metric
would need to be a linear function of
these test conditions. DOE testing
indicates that the efficacy of moisture
removal becomes significantly nonlinear as the RMC in the clothes load
approaches low values, particularly near
the 5-percent maximum allowable RMC
for the conclusion of the test cycle
according to the clothes dryer test
procedure. Therefore, test loads with
different initial RMC that are allowed to
dry to a range of final RMCs, or
differences in test load size, would not
produce repeatable and consistent
measures of energy efficiency
performance due to this non-linearity of
efficiency through the drying process. In
order for testing results to be
comparable, the test procedure would
need to be amended to specific an exact
starting and ending RMC, which would
likely represent a significant testing
burden. In addition, DOE does not
believe that a metric based on lbs. of
water removed per kWh, as commented
by NRDC/ECOS, would be more
meaningful to consumers, who may not
be aware of how much water is
contained in their test load. For these
reasons, and because DOE has
insufficient data to suggest that a metric
based on lbs. of water removed per kWh
instead of lb of test cloth per kWh is a
more accurate or representative measure
of clothes dryer energy use, DOE is not
amending the clothes dryer energy
conservation standards as suggested by
NRDC and the California Utilities.
The California Utilities recommended
that DOE consider a prescriptive design
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requirement that all vented clothes
dryers have a standard 4-inch round
port for air intake, which would be the
same diameter as the exhaust duct.
According to the California Utilities,
there would be negligible cost
associated with this design, and would
allow consumers the option to install
outdoor intake air in the future.
(California Utilities, No. 31 at pp. 8, 12)
As noted in section IV.A.5.a, DOE
concluded that consideration of HVAC
energy use associated with outdoor
intake air was inconsistent with EPCA’s
requirement that a test procedure
measure the energy use or energy
efficiency of a covered product. As a
result, DOE did not consider this
technology in its analysis and is not
adopting a prescriptive design standard
addressing the potential implementation
of outdoor intake air.
PG&E inquired whether DOE would
consider a performance metric that
would include the non-energy benefit of
clothing life if such data were available.
(PG&E, Public Meeting Transcript, No.
21.4 at p. 129) DOE is not aware of such
data and notes that EPCA provides that
any test procedures prescribed or
amended under this section shall be
reasonably designed to produce test
results which measure energy
efficiency, energy use, water use, or
estimated annual operating cost of a
covered product during a representative
average use cycle or period of use. (42
U.S.C. 6293(b)(3)) DOE believes that a
clothes dryer metric incorporating the
non-energy benefit of clothing life
would be inconsistent with this
requirement. Therefore, DOE did not
consider such a metric in the TP Final
Rule. DOE is required, however, to
consider any lessening of utility or
performance in establishing energy
conservation standards. 42 U.S.C.
6295(o)(2)(B)(i)(IV).
The NRDC/ECOS report stated that,
due to the complexity of the current
DOE clothes washer test procedure and
energy use calculations, it might be
simpler for manufacturers to report total
energy used to wash and dry one load.
(NRDC, No. 30 at p. 32) EPCA provides
separate standards for clothes dryers
and clothes washers, and directs DOE to
consider amended energy conservation
standards for each product separately.
(42 U.S.C. 6295(g)) Therefore, DOE is
unable to adopt a single standard based
on overall energy use of the wash and
dry cycles in total.
Comments on Preliminary Analysis
Integrated Efficiency Levels
DOE also received comments from
interested parties on the efficiency
levels proposed in the preliminary
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analysis. The California Utilities stated
that, with the low or negative
incremental costs of the standby power
design options, such design options
should be implemented at lower
efficiency levels. According to the
California Utilities, this implementation
would not affect clothes dryers with
electromechanical controls, which have
zero standby and are thus receiving a
‘‘free’’ benefit of 2.0 W. (California
Utilities, No. 31 at pp. 11–12) DOE
agrees that the low cost of the standby
power design options should result in
these technologies being included in the
initial efficiency levels above the
baseline. Thus, the clothes dryer
efficiency levels analyzed in this direct
final rule implement the standby power
design options at the efficiency levels
where they are most cost-effective. As
noted by the California Utilities, these
changes would impact only those
clothes dryers that consume standby
power, that is, those products with
electronic controls.
Earthjustice commented that EPCA
contains an ‘‘anti-backsliding provision’’
that constrains DOE’s authority in
revising energy efficiency standards.
According to Earthjustice, some of the
clothes dryer efficiency levels that DOE
is considering would violate the antibacksliding requirement. Earthjustice
commented that adding standby power
consumption factors into the existing
metrics reduces the stringency of each
metric. Earthjustice provided an
example for vented electric compact
(120 V) clothes dryers in which the
addition of the 2 W of standby power
lowers the EF rating of the baseline
efficiency level from 3.13 to 3.00. If DOE
adopts efficiency level 1, with an IEF of
3.08, such a standard would violate
EPCA’s anti-backsliding provision.
NRDC commented that if an existing
vented electric compact (120V) clothes
dryer model with electromechanical
controls (which DOE has shown to
consume no power in standby mode)
has an EF of 3.10, it would be barred
from the U.S. market by the existing
standard. However, it would meet an
IEF standard set at 3.08 (which DOE
proposed as efficiency level 1 in the
preliminary TSD). Earthjustice
commented that implementing an IEF
standard set at 3.08 would have the
effect of decreasing the minimum
required energy efficiency as is
prohibited by the anti-backsliding
provisions. (EJ, No. 28 at pp. 1–2; EJ,
Public Meeting Transcript, No. 21.4 at
p. 58) Earthjustice also commented that
DOE’s proposed approach to the
integration of standby and off mode
energy consumption into the
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performance standards for clothes
dryers would require DOE to adopt
standards that increase EF sufficiently
to avoid violating EPCA’s antibacksliding provision. (EJ, No. 28 at
p. 1)
EPCA contains what is commonly
known as an ‘‘anti-backsliding’’
provision. This provision prohibits DOE
from prescribing any amended standard
that either increases the maximum
allowable energy use or decreases the
minimum required energy efficiency of
a covered product or equipment. (42
U.S.C. 6295(o)(1)) Congress also
directed DOE to incorporate standby
and off mode energy use in a single
amended or new standard, or to
prescribe a separate standard if such
incorporation is not feasible, pursuant
to 42 U.S.C. 6295(o). (42 U.S.C.
6295(gg)(3)) Today’s final rule
incorporates additional measures of
energy consumption in the energy
conservation standards for clothes
dryers (that is, standby and off mode
energy use). DOE notes that clothes
dryers and room air conditioners that
consume energy in standby and off
modes have always used energy in these
modes, and that today’s final rule now
accounts for that energy as directed by
42 U.S.C. 6295(gg). Given the
Congressional directive to account for
standby and off mode energy use, DOE
does not believe that accounting for
energy use in these modes could result
in backsliding under 42 U.S.C.
6295(o)(1). In addition, DOE evaluated
the clothes dryer TSLs to ensure that no
product currently on the market could
be determined compliant with the new
energy conservation standards while
consuming more energy in active mode
than was allowable under the previous
standards.
NPCC commented that the clothes
dryer test procedure does not measure
the efficiency improvement associated
with improved automatic termination
controls such as moisture sensing.
NPCC stated that because moisture
sensing would require switching from
electromechanical controls to electronic
controls, part of the incremental
manufacturing cost associated with
electronic controls would be accounted
for in the improved automatic cycle
termination design option. However,
NPCC also stated that all clothes dryers
have some form of automatic cycle
termination for which the current test
procedure uses a fixed field use factor.
NPCC commented that because moisture
sensing requires electronic controls and
thus consumes standby power, the cost
of the implementing electronic controls
is inappropriately accounted for only in
the standby power design options
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because the test procedure does not
measure the efficiency improvement
associated with moisture sensing. NPCC
stated that part of the costs for
implementing electronic controls
should be accounted for in the costs
associated with improved automatic
cycle termination with moisture
sensing. (NPCC, Public Meeting
Transcript, No. 21.4 at pp. 58–60, 61–
62) NPCC commented that if a product
is receiving the 1.04 field use factor for
automatic cycle termination, then the
cost of that type of device (that is, the
cost of electronic controls) needs to be
in the baseline cost analysis. (NPCC,
Public Meeting Transcript, No. 21.4 at
p. 60)
DOE first notes that electronic
controls are not required to implement
automatic cycle termination. Clothes
dryers are currently available on the
market that use inputs from exhaust air
temperature sensors to control or
modify the length of the drying cycle
without the use of electronic controls.
For this reason, DOE did not include the
cost of electronic controls in the
baseline cost, unless the baseline
product already incorporated electronic
controls (such as, ventless electronic
compact (240V) and ventless electric
combination washer/dryers). As
discussed below, DOE noted that
baseline efficiency clothes dryers
implement both electromechanical
controls and electronic controls. As a
result, DOE analyzed baseline efficiency
products available on the market, and
weighted the contribution of the 2 W
baseline standby power as well as the
efficiency improvement and
incremental manufacturing cost for
standby power design changes based on
the percentage of baseline efficiency
products that used electronic controls.
BSH commented that DOE should
analyze and implement evenly
distributed efficiency levels to help
consumers make purchasing decisions.
BSH also commented that the
implementation of the proposed
efficiency levels in the preliminary
analyses would cause confusion to
consumers. According to BSH, with a
relatively small improvement in
efficiency in the lower efficiency levels,
a better rating can be achieved, and at
the high end of the efficiency levels,
much more effort must be taken to
improve the rating. In addition,
according to BSH, consumers will not
support the higher efficiency level
because they cannot see the advantage
of paying a significantly higher price for
a small change in product efficiency.
(BSH, No. 23 at pp. 3–4) BSH also
commented that DOE should use the
same efficiency scale to analyze ventless
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and vented clothes dryers. According to
BSH, ventless clothes dryers, especially
those with heat pump technology, will
be penalized by keeping a lower number
of efficiency levels. (BSH, No. 23 at
p. 4)
DOE notes that the efficiency levels
analyzed for the preliminary analyses
were derived from the distribution of
efficiencies for products available on the
market from data provided in the CEC
and NRCan product databases. DOE also
notes that the efficiency levels for the
ventless clothes dryer product classes
were based on product testing as well as
scaling of the efficiency improvements
associated with vented clothes dryer
product classes. The efficiency levels
analyzed are not being established for a
product marketing classification system
for consumers to make purchasing
decisions (as is done in the European
energy class system). As a result, DOE
does not intend to create an energy class
system for product marketing based on
evenly distributed efficiency levels.
BSH commented that a separate
classification of heat pump clothes
dryers will not be possible because the
European market shows large variation
within this class of clothes dryers.
According to BSH, heat pump clothes
dryers in Europe differ by up to 40
percent in energy efficiency. (BSH, No.
23 at pp. 3–4) DOE notes that the
efficiency levels established by DOE for
the max-tech heat pump design are
based on research and discussions with
manufacturers. In addition, DOE does
not intend to create a marketing
classification system that would create a
‘‘heat pump’’ label from which
consumers may perceive that all heat
pump clothes dryers have the same
efficiency. For these reasons, DOE
continued to analyze the efficiency
levels associated with heat pump
clothes dryers presented in the
preliminary analyses for today’s direct
final rule.
BSH commented that the gap between
conventional and heat pump dryers is
not filled with intermediate levels to
show consumers the large improvement
in efficiency they would be paying for
when making purchasing decisions.
(BSH, No. 23 at p. 6) DOE is not aware
of products available on the market at
efficiency levels between the maximumavailable (on the U.S. market) efficiency
levels and the max-tech heat pump
efficiency level. In addition, DOE does
not have any information indicating that
design options are available that may be
implemented to achieve efficiencies
between the maximum-available and
max-tech heat pump efficiency levels.
As discussed above, DOE is not creating
a marketing classification system for
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consumers to make purchasing
decisions. As a result, DOE did not
analyze additional intermediate
efficiency levels between those
associated with conventional and heat
pump dryers.
Integrated Efficiency Levels—Final Rule
As discussed in section III.A, DOE
recently published the TP Final Rule
amending the clothes dryer test
procedure. DOE conducted testing on a
sample of representative clothes dryers
to evaluate the effects of the
amendments to the clothes dryer test
procedure on the measured EF. As
discussed in section III.A.3.a, DOE test
results showed that the measured EF
according to the amended test
procedure resulted in an average
increase of about 20.1 percent for vented
electric standard clothes dryers. For
vented gas clothes dryers, the measured
EF increased by an average of about 19.8
percent. For vented electric compactsize 120V and 240V clothes dryers, the
measured EF increased by an average of
about 15.6 and 12.8 percent,
respectively. For the ventless clothes
dryer product classes, the preliminary
analyses were based on the DOE test
procedure with only the proposed
amendments to for ventless clothes
dryers. DOE also conducted testing
according to the final amended test
procedure (that is, including changes to
the initial RMC, water temperature for
test load preparation, etc.). Test results
showed that for ventless electric
compact 240V clothes dryers and
ventless electric combination washer/
dryers, the measured EF increased by an
average of about 13.6 and 11.4 percent,
respectively. DOE applied these results
for each product class to adjust the
active mode efficiency levels to account
for the amendments to the DOE clothes
dryer test procedure in the TP Final
Rule. In addition, DOE revised the
active mode efficiency level 1 for vented
electric standard clothes dryers and
vented gas clothes dryers from 3.10 EF
to 3.11 EF and from 2.75 to 2.76 EF,
respectively. The revisions were based
on discussions with manufacturers and
the efficiency improvement associated
with the design options modeled by
DOE. See chapter 5 of the direct final
rule TSD for more details. DOE
subsequently integrated the standby
power efficiency levels to convert these
EF values to CEF. For the preliminary
analyses, DOE only incorporated
incremental standby power levels into
IEF efficiency levels above which
electronic controls would be required as
part of the active mode design option
changes. At that point, DOE
incorporated the incremental standby
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power levels where it determined them
to be most cost effective. Chapter 5 of
the direct final rule TSD provides
details of the active mode and standby
mode efficiency levels for each product
class. The revised CEF efficiency levels
for each product class are shown below
in Table IV.14 through Table IV.16.
TABLE IV.14—CLOTHES DRYER INTEGRATED EFFICIENCY LEVELS (CEF)—VENTED PRODUCT CLASSES
Integrated efficiency level
(CEF) lb/kWh
Level
Efficiency level description
Electric
standard
Baseline .......................
1 ...................................
2 ...................................
3 ...................................
4 ...................................
5 ...................................
6 ...................................
DOE Standard + 2.0 W Standby ...........................................
DOE Standard + 1.5 W Standby ...........................................
DOE Standard + 0.08 W Standby .........................................
Gap Fill + 0.08 W Standby ....................................................
Gap Fill + 0.08 W Standby ....................................................
Gap Fill/Maximum Available + 0.08 W Standby ...................
Heat Pump (Max-Tech) + 0.08 W Standby ..........................
3.55
3.56
3.61
3.73
3.81
4.08
5.42
Electric
compact
(120V)
3.43
3.48
3.61
3.72
3.80
4.08
5.41
Electric
compact
(240V)
3.12
3.16
3.27
3.36
3.48
3.60
4.89
Gas
3.14
3.16
3.20
3.30
3.42
3.61
....................
TABLE IV.15—CLOTHES DRYER INTEGRATED EFFICIENCY LEVELS (CEF)—VENTLESS ELECTRIC COMPACT (240V)
Level
Integrated
efficiency
level
(CEF)
lb/kWh
Efficiency level description
Electric
compact
(240 V)
Baseline ......................................................
1 .................................................................
2 .................................................................
3 .................................................................
4 .................................................................
5 .................................................................
Baseline + 2.0 W Standby ..............................................................................................
Baseline + 1.5 W Standby ..............................................................................................
Baseline + 0.08 W Standby ............................................................................................
Gap Fill + 0.08 W Standby .............................................................................................
Gap Fill + 0.08 W Standby .............................................................................................
Heat Pump (Max-Tech) + 0.08 W Standby ....................................................................
2.55
2.59
2.69
2.71
2.80
4.03
TABLE IV.16—CLOTHES DRYER INTEGRATED EFFICIENCY LEVELS (CEF)—VENTLESS ELECTRIC COMBINATION WASHER/
DRYERS
Level
Integrated
efficiency
level
(CEF)
lb/kWh
Efficiency level description
Electric
combination
washer/
dryer
mstockstill on DSKH9S0YB1PROD with RULES2
Baseline ......................................................
1 .................................................................
2 .................................................................
3 .................................................................
4 .................................................................
5 .................................................................
Baseline + 2.0 W Standby ..............................................................................................
Gap Fill + 2.0 W Standby ...............................................................................................
Gap Fill + 1.5 W Standby ...............................................................................................
Gap Fill + 0.08 W Standby .............................................................................................
Gap Fill + 0.08 W Standby .............................................................................................
Heat Pump (Max-Tech) + 0.08 W Standby ....................................................................
Cost-Efficiency Results—Preliminary
Analysis
For the preliminary analysis, DOE
first analyzed design options separately
for active mode and standby mode and
developed the cost-efficiency
relationships based on product
teardowns and cost modeling. Details of
the active mode and standby mode costefficiency relationships for each product
VerDate Mar<15>2010
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class are presented in chapter 5 of the
preliminary TSD. DOE then developed
overall cost-efficiency relationships for
the IEF efficiency levels presented in
the preliminary analyses. Table IV.17
through Table IV.22 shows DOE’s
estimates of incremental manufacturing
cost for improvement of clothes dryer
IEF above the baseline. Also shown
below are the technologies DOE
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2.08
2.35
2.38
2.46
2.56
3.69
analyzed for each efficiency level to
develop incremental manufacturing
costs. Detailed descriptions of the
design options associated with each
efficiency level are also presented in
chapter 5 of the preliminary TSD. DOE
used an efficiency level approach,
noting that different manufacturers may
implement different design changes to
achieve certain efficiency levels.
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Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
TABLE IV.17—PRELIMINARY ANALYSIS: COST-EFFICIENCY RELATIONSHIP FOR VENTED ELECTRIC STANDARD CLOTHES
DRYERS
Incremental
manufacturing
cost
Integrated efficiency level (IEF), lb/kWh
Technology
Baseline (2.96) ........................................
1 (3.04) ....................................................
DOE Standard + 2.0 W Standby ...............................................................................
DOE Standard + Change in Airflow Patterns, Dedicated Heater Duct, Open-Cylinder Drum.
IEL 2 + Inlet Air Pre-Heating .....................................................................................
IEL 2 + Modulating Heat ...........................................................................................
IEL 3 + 1.5 W Standby ..............................................................................................
IEL 3 + 0.08 W Standby ............................................................................................
Heat Pump + 0.08 W Standby ..................................................................................
2
3
4
5
6
(3.10)
(3.33)
(3.35)
(3.40)
(4.52)
....................................................
....................................................
....................................................
....................................................
....................................................
$0
11.89
63.56
97.48
98.78
98.14
259.13
TABLE IV.18—PRELIMINARY ANALYSIS: COST-EFFICIENCY RELATIONSHIP FOR VENTED ELECTRIC COMPACT (120V)
CLOTHES DRYERS
Incremental
manufacturing
cost
Integrated efficiency level (IEF), lb/kWh
Technology
Baseline (3.00) ........................................
1 (3.08) ....................................................
DOE Standard + 2.0 W Standby ...............................................................................
DOE Standard + Change in Airflow Patterns, Dedicated Heater Duct, Open-Cylinder Drum.
IEL 2 + Inlet Air Pre-Heating .....................................................................................
IEL 2 + Modulating Heat ...........................................................................................
IEL 3 + 1.5 W Standby ..............................................................................................
IEL 3 + 0.08 W Standby ............................................................................................
Heat Pump + 0.08 W Standby ..................................................................................
2
3
4
5
6
(3.15)
(3.37)
(3.41)
(3.53)
(4.69)
....................................................
....................................................
....................................................
....................................................
....................................................
$0
10.95
63.37
96.45
97.75
97.11
246.35
TABLE IV.19—PRELIMINARY ANALYSIS: COST-EFFICIENCY RELATIONSHIP FOR VENTED ELECTRIC COMPACT (240V)
CLOTHES DRYERS
Incremental
manufacturing
cost
Integrated efficiency level (IEF), lb/kWh
Technology
Baseline (2.79) ........................................
1 (2.86) ....................................................
DOE Standard + 2.0 W Standby ...............................................................................
DOE Standard + Change in Airflow Patterns, Dedicated Heater Duct, Open-Cylinder Drum.
IEL 2 + Inlet Air Pre-Heating .....................................................................................
IEL 2 + Modulating Heat ...........................................................................................
IEL 3 + 1.5 W Standby ..............................................................................................
IEL 3 + 0.08 W Standby ............................................................................................
Heat Pump + 0.08 W Standby ..................................................................................
2
3
4
5
6
(2.96)
(3.06)
(3.10)
(3.19)
(4.34)
....................................................
....................................................
....................................................
....................................................
....................................................
$0
10.95
63.37
96.45
97.75
97.11
246.35
TABLE IV.20—PRELIMINARY ANALYSIS: COST-EFFICIENCY RELATIONSHIP FOR VENTED GAS CLOTHES DRYERS
Incremental
manufacturing
cost
Integrated efficiency level (IEF), lb/kWh
Technology
Baseline (2.63) ........................................
1 (2.71) ....................................................
DOE Standard + 2.0 W Standby ...............................................................................
DOE Standard + Change in Airflow Patterns, Dedicated Heater Duct, Open-Cylinder Drum.
IEL 2 + Inlet Air Pre-Heating .....................................................................................
IEL 2 + Modulating Heat ...........................................................................................
IEL 3 + 1.5 W Standby ..............................................................................................
IEL 3 + 0.08 W Standby ............................................................................................
mstockstill on DSKH9S0YB1PROD with RULES2
2
3
4
5
(2.80)
(2.97)
(2.98)
(3.02)
....................................................
....................................................
....................................................
....................................................
$0
14.79
65.36
156.01
157.31
156.67
TABLE IV.21—PRELIMINARY ANALYSIS: COST-EFFICIENCY RELATIONSHIP FOR VENTLESS ELECTRIC COMPACT (240V)
CLOTHES DRYERS
Incremental
manufacturing
cost
Integrated efficiency level (IEF), lb/kWh
Technology
Baseline (2.29) ........................................
1 (2.31) ....................................................
2 (2.37) ....................................................
Baseline + 2.0 W Standby ........................................................................................
Baseline + 1.5 W Standby ........................................................................................
Baseline + 0.08 W Standby ......................................................................................
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22501
TABLE IV.21—PRELIMINARY ANALYSIS: COST-EFFICIENCY RELATIONSHIP FOR VENTLESS ELECTRIC COMPACT (240V)
CLOTHES DRYERS—Continued
Incremental
manufacturing
cost
Integrated efficiency level (IEF), lb/kWh
Technology
3 (2.39) ....................................................
4 (2.59) ....................................................
5 (3.54) ....................................................
IEL 2 + Change in Airflow Patterns, Open-Cylinder Drum .......................................
IEL 3 + Modulating Heat ...........................................................................................
Heat Pump + 0.08 W Standby ..................................................................................
13.01
69.02
216.37
TABLE IV.22—PRELIMINARY ANALYSIS: COST-EFFICIENCY RELATIONSHIP FOR VENTLESS ELECTRIC COMBINATION
WASHER/DRYERS
Incremental
manufacturing
cost
Technology
Baseline (1.90) ........................................
1 (2.15) ....................................................
2 (2.34) ....................................................
3 (2.36) ....................................................
4 (2.42) ....................................................
5 (3.31) ....................................................
mstockstill on DSKH9S0YB1PROD with RULES2
Integrated efficiency level (IEF), lb/kWh
Baseline + 2.0 W Standby ........................................................................................
Baseline + 2.0 W Standby + Baseline Automatic Termination .................................
IEL 1 + Modulating Heat ...........................................................................................
IEL 2 + 1.5 W Standby ..............................................................................................
IEL 2 + 0.08 W Standby ............................................................................................
Heat Pump + 0.08 W Standby ..................................................................................
DOE received comments from
interested parties on the whether the
baseline clothes dryer manufacturing
costs should be adjusted to reflect the
cost of complying with the Underwriters
Laboratory (UL) Standard 2158 ‘‘Electric
Clothes Dryers’’ (UL 2158) fire
containment requirements. AHAM
commented that it would need to look
into and understand how the fire
containment regulation in UL 2158
would affect the cost similar to the
refrigerant change from R–22 to R–410a
for room air conditioners. (AHAM,
Public Meeting Transcript, No. 21.4 at
p. 153) AHAM commented that when
manufacturers submitted incremental
clothes dyer manufacturing cost
estimates to DOE in late 2008, costs to
comply with UL 2158 were not
included. According to AHAM, while
the new UL requirements may not
directly impact energy efficiency, the
requirements place significant
cumulative regulatory burden on clothes
dryer manufacturers. AHAM
commented that DOE should evaluate
an additional step for clothes dryers,
where the costs to implement the UL
fire containment requirements are
incorporated into the baseline analysis,
similar to the approach used to evaluate
the phase-out of R–22 to R–410A for
room air conditioners. AHAM
commented that DOE should evaluate
these costs through manufacturer
interviews and determine how this cost
affects the incremental costs to reach
higher efficiency. (AHAM, No. 25 at
p. 5) DOE notes that it attempted to
obtain data on the incremental
manufacturing cost associated with
complying with the fire containment
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requirements in UL 2158 during
manufacturing interviews. While
manufacturers noted that different
manufacturers will be required to make
different changes to their product design
to meet the fire containment
requirements, DOE did not receive
sufficient data to determine the
incremental manufacturing costs to
baseline clothes dryers to comply with
the fire containment requirements of UL
2158. In addition, DOE did not receive
sufficient information to indicate that
the cost associated with complying with
UL 2158 would vary at efficiency levels
above the baseline. As a result, DOE did
not include additional cost to comply
with UL 2158 in the baseline
manufacturing production cost. As
discussed below in section IV.I.3.b, DOE
has investigated the costs of complying
with the fire containment requirements
in UL 2158 in the cumulative regulatory
burden for the MIA.
Cost-Efficiency Results—Final Rule
For today’s final rule, DOE updated
the cost-efficiency analysis from the
preliminary analyses by updating the
costs of raw materials and purchased
components, as well as updating costs
for manufacturing equipment, labor, and
depreciation.
In addition, based on discussions
with clothes dryer manufacturers, DOE
revised the design options analyzed for
each integrated efficiency level in the
preliminary analyses. Based on these
discussions, DOE believes that
manufacturers would apply a two-stage
modulating heater design (which would
also require moisture sensing and multispeed airflow) to achieve integrated
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54.04
55.34
54.70
230.83
efficiency level 4 for all clothes dryer
product classes. In addition, based on
discussions with manufacturers, DOE
believes that inlet-air preheating (which
would require better airflow control and
more advanced control systems), along
with the design options for the lower
efficiency levels (that is, changes in
airflow patterns, open cylinder drum,
dedicated heater duct, two-stage
modulating heat, and standby power
changes), would be applied to achieve
integrated efficiency level 5 (maximumavailable) for vented clothes dryer
product classes. As a result, the maxtech efficiency level for vented gas
clothes dryers would correspond to inlet
air pre-heating.
As discussed above, DOE also
believes that the low cost of the standby
power design options should result in
these technologies being included in the
initial efficiency levels above the
baseline. As a result, DOE revised the
order of the design options and
efficiency levels presented in the
preliminary analyses. As discussed
above in this section, DOE previously
incorporated incremental standby
power levels into integrated efficiency
levels above which electronic controls
would be required as part of the active
mode design option changes. At that
point, DOE incorporated the
incremental standby power levels where
it determined them to be most cost
effective. For today’s final rule, DOE
applied the standby power levels
immediately above the baseline level
because they were determined to be the
most cost-effective design option. The
revised order of design options are
shown below in Table IV.23 through
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Table IV.28. DOE also noted that for the
integrated efficiency levels where
electronic controls are not required for
the design changes, the standby power
level changes would impact only those
clothes dryers that consume standby
power, that is, those products with
electronic controls. As a result, DOE
analyzed baseline efficiency products
available on the market, and weighted
the efficiency improvement and
incremental manufacturing cost based
on the percentage of baseline efficiency
products that have electronic controls.36
For the integrated efficiency levels for
which electronic controls would be
required as part of the active mode
design changes, DOE assumed that the
standby power levels and incremental
manufacturing costs affected 100
percent of clothes dryer models.
Table IV.23 through Table IV.28
shows the cost-efficiency results, along
with the technologies DOE analyzed for
each efficiency level to develop
incremental manufacturing costs.
Details of the cost-efficiency analysis
and descriptions of the technologies
associated with each design change are
presented in chapter 5 of the direct final
rule TSD.
TABLE IV.23—COST-EFFICIENCY RELATIONSHIP FOR VENTED ELECTRIC STANDARD CLOTHES DRYERS
Incremental
manufacturing
cost
Integrated efficiency level (CEF), lb/kWh
Technology
Baseline (3.55) ........................................
1 (3.56) ....................................................
2 (3.61) ....................................................
3 (3.73) ....................................................
4 (3.81) ....................................................
5 (4.08) ....................................................
6 (5.42) ....................................................
DOE Standard + 2.0 W Standby ...............................................................................
DOE Standard + 1.5 W Standby ...............................................................................
DOE Standard + 0.08 W Standby .............................................................................
IEL 2 + Change in Airflow Patterns, Dedicated Heater Duct, Open-Cylinder Drum
IEL 3 + 2-Stage Modulating Heat .............................................................................
IEL 4 + Inlet Air Pre-Heating .....................................................................................
Heat Pump + 0.08 W Standby ..................................................................................
$0
0.68
0.82
8.74
50.67
88.89
280.54
TABLE IV.24—COST-EFFICIENCY RELATIONSHIP FOR VENTED ELECTRIC COMPACT (120V) CLOTHES DRYERS
Incremental
manufacturing
cost
Integrated efficiency level (CEF), lb/kWh
Technology
Baseline (3.43) ........................................
1 (3.48) ....................................................
2 (3.61) ....................................................
3 (3.72) ....................................................
4 (3.80) ....................................................
5 (4.08) ....................................................
6 (5.41) ....................................................
DOE Standard + 2.0 W Standby ...............................................................................
DOE Standard + 1.5 W Standby ...............................................................................
DOE Standard + 0.08 W Standby .............................................................................
IEL 2 + Change in Airflow Patterns, Dedicated Heater Duct, Open-Cylinder Drum
IEL 3 + 2-Stage Modulating Heat .............................................................................
IEL 4 + Inlet Air Pre-Heating .....................................................................................
Heat Pump + 0.08 W Standby ..................................................................................
$0
0.68
0.82
21.46
62.76
109.31
267.48
TABLE IV.25—COST-EFFICIENCY RELATIONSHIP FOR VENTED ELECTRIC COMPACT (240V) CLOTHES DRYERS
Incremental
manufacturing
cost
Integrated efficiency level (CEF), lb/kWh
Technology
Baseline (3.12) ........................................
1 (3.16) ....................................................
2 (3.27) ....................................................
3 (3.36) ....................................................
4 (3.48) ....................................................
5 (3.60) ....................................................
6 (4.89) ....................................................
DOE Standard + 2.0 W Standby ...............................................................................
DOE Standard + 1.5 W Standby ...............................................................................
DOE Standard + 0.08 W Standby .............................................................................
IEL 2 + Change in Airflow Patterns, Dedicated Heater Duct, Open-Cylinder Drum
IEL 3 + 2-Stage Modulating Heat .............................................................................
IEL 4 + Inlet Air Pre-Heating .....................................................................................
Heat Pump + 0.08 W Standby ..................................................................................
$0
0.68
0.82
21.46
62.76
109.31
267.48
TABLE IV.26—COST-EFFICIENCY RELATIONSHIP FOR VENTED GAS CLOTHES DRYERS
Incremental
manufacturing
cost
mstockstill on DSKH9S0YB1PROD with RULES2
Integrated efficiency level (CEF), lb/kWh
Technology
Baseline (3.14) ........................................
1 (3.16) ....................................................
2 (3.20) ....................................................
3 (3.30) ....................................................
4 (3.42) ....................................................
5 (3.61) ....................................................
DOE Standard + 2.0 W Standby ...............................................................................
DOE Standard + 1.5 W Standby ...............................................................................
DOE Standard + 0.08 W Standby .............................................................................
IEL 2 + Change in Airflow Patterns, Dedicated Heater Duct, Open-Cylinder Drum
IEL 3 + 2-Stage Modulating Heat .............................................................................
IEL 4 + Inlet Air Pre-Heating .....................................................................................
36 DOE’s review of currently available models
with baseline efficiency showed that roughly
74 percent of models have electronic controls.
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0.82
9.12
72.32
109.98
22503
Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
TABLE IV.27—COST-EFFICIENCY RELATIONSHIP FOR VENTLESS ELECTRIC COMPACT (240V) CLOTHES DRYERS
Incremental
manufacturing
cost
Integrated efficiency level (CEF), lb/kWh
Technology
Baseline (2.55) ........................................
1 (2.59) ....................................................
2 (2.69) ....................................................
3 (2.71) ....................................................
4 (2.80) ....................................................
5 (4.03) ....................................................
Baseline + 2.0 W Standby ........................................................................................
Baseline + 1.5 W Standby ........................................................................................
Baseline + 0.08 W Standby ......................................................................................
IEL 2 + Change in Airflow Patterns, Open-Cylinder Drum .......................................
IEL 3 + 2-Stage Modulating Heat .............................................................................
Heat Pump + 0.08 W Standby ..................................................................................
$0
0.93
1.11
26.42
57.80
242.36
TABLE IV.28—COST-EFFICIENCY RELATIONSHIP FOR VENTLESS ELECTRIC COMBINATION WASHER/DRYERS
Incremental
manufacturing
cost
Technology
Baseline (2.08) ........................................
1 (2.35) ....................................................
2 (2.38) ....................................................
3 (2.46) ....................................................
4 (2.56) ....................................................
5 (3.69) ....................................................
mstockstill on DSKH9S0YB1PROD with RULES2
Integrated efficiency level (CEF), lb/kWh
Baseline + 2.0 W Standby ........................................................................................
Baseline + 2.0 W Standby + Baseline Automatic Termination .................................
IEL 1 + 1.5 W Standby ..............................................................................................
IEL 2 + 0.08 W Standby ............................................................................................
IEL 3 + 2-Stage Modulating Heat .............................................................................
Heat Pump + 0.08 W Standby ..................................................................................
b. Room Air Conditioners
During the preliminary analysis, DOE
performed the room air conditioner
engineering analysis as follows:
• Reverse engineering and teardown
for 21 room air conditioners across 6
product classes.
• Interviews with room air
conditioner manufacturers to obtain
greater insight into design strategies and
their associated costs to improve
efficiency, including designs
incorporating R–410A refrigerant.
• Energy modeling for room air
conditioner designs using R–410A
refrigerant.
DOE selected teardown products
covering the range of available
efficiency levels at a group of selected
capacities. The products selected for
teardown were designed for HCFC–22
refrigerant because DOE conducted this
work before the January 1, 2010
phaseout of this refrigerant for new
products was required. 74 FR 66450
(Dec. 19, 2009) DOE modeled the 21
HCFC–22 teardown units to calibrate
the model before modeling the R–410A
efficiency levels. DOE also identified
one R–410A room air conditioner
during the preliminary analysis and
analyzed it in the reverse engineering
analysis.
From these analyses, DOE produced
R–410A cost-efficiency curves for each
of the analyzed product classes. Details
of the engineering analysis are provided
in the direct final rule TSD chapter 5.
DOE received several comments from
interested parties on its approach to the
engineering analysis, as described
below. Stakeholders commented on
(1) the availability of R–410A products
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and data for incorporation into the
engineering analysis, and (2) limitations
on the maximum size of room air
conditioners.
Conversion to R–410a
During the preliminary analysis
public meeting, DOE requested
comments on the approach for the
engineering analysis for room air
conditioners, specifically on the use of
both energy modeling and manufacturer
cost modeling. DOE explained that this
was the best approach for the
preliminary engineering analysis. An
efficiency level analysis based on only
teardowns of specific products at
different efficiency levels would have
been based on HCFC–22 and would not
have been representative of the R–410A
products that would be available on the
compliance date for the rule.
ACEEE suggested that DOE’s analysis
should be updated due to the transition
from HCFC–22 refrigerant (ACEEE, No.
24 at p. 4). ACEEE and the California
Utilities recommended that DOE revise
its analysis using current R–410A
models for product teardowns, as it
would enable DOE to more accurately
determine the energy use of new room
air conditioners (ACEEE, No. 24 at p. 4;
California Utilities, No. 31 at p. 17). In
addition, the California Utilities
recommended that DOE conduct testing
of products that contain R–410A
refrigerant. (California Utilities, No. 31
at p. 17)
During the preliminary analysis phase
of this rulemaking, DOE indicated that
there was only one R–410A product
available on the market for analysis.
Subsequently, however, DOE examined
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2.62
31.69
297.54
information associated with
commercialized R–410A products and
made appropriate adjustments based on
the new information, as described
below.
In the engineering analysis supporting
today’s final rule, DOE purchased and
conducted teardowns on four R–410A
products to update and validate the
analysis performed during the
preliminary analysis. Table IV.29 lists
the R–410A products used. DOE focused
this effort on the largest and most
efficient units.
TABLE IV.29—R–410A ROOM AIR
CONDITIONERS
SELECTED
FOR
TEARDOWN
Product class
1 ................................
2 ................................
3 ................................
5B .............................
Capacity
Btu/hr
5000
6,000
12,000
28,500
EER
9.7
12.0
10.8
8.5
The new information obtained from
the four R–410A product teardowns,
and examination of product information
of available R–410A products,
confirmed that the baseline product
designs, design option costs, and design
pathways chosen during the preliminary
analysis, developed based on teardowns
of HCFC–22 units, provided accurate
results for calculating the cost-efficiency
curves for R–410A designs.
SCE noted that a study conducted by
NIST for split systems indicated that R–
410A dropped in efficiency compared
with R–22 only in systems with
condensing temperatures above 95 °F.
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22504
Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
(SCE, Public Meeting Transcript, No.
21.4 at p. 69)
DOE notes that its modeling of room
air conditioners indicates that they
operate with condensing temperatures
between 110 °F and 130 °F under DOE
test conditions, depending on the sizes
of the heat exchangers. DOE’s analysis
confirms that the impact of the switch
to R–410A is more severe as condensing
temperatures increase above 95 °F, and
that additional improvements in
efficiency (larger heat exchangers, more
efficient components, and similar
improvements) are required to reach
comparable efficiencies to HCFC–22.
Energy modeling of R–410A and HCFC–
22 room air conditioners shows that a
system modeled with HCFC–22
experiences an efficiency reduction if a
‘‘drop-in’’ of R–410A is considered (that
is, switch refrigerant and make no other
system changes).
As discussed previously, DOE
conducted the engineering analysis
based on use of R–410A refrigerant.
DOE sought information on the
performance of R–410A rotary
compressors of varying efficiency levels
for all of the products under analysis. In
many cases, the range of efficiency for
which compressor vendors were able to
provide performance data was limited.
Because conducting the analysis
generally required knowledge not just of
design point capacity and EER, DOE
requested performance data for a
representative range of evaporating and
condensing conditions. In some cases,
the trends of compressor performance as
a function of operating conditions were
extrapolated from the trends exhibited
by a compressor of the same refrigerant
of nearly the same capacity. During the
preliminary analysis, DOE considered
the available performance data for
R–410A rotary compressors, noting that
discussions with compressor vendors
revealed that many vendors were still
developing their R–410A compressor
lines and could only provide
preliminary data. The compressors for
which performance data was available
varied significantly in EER, depending
on their capacity. DOE did not consider
increases in compressor efficiency as a
design option, because no higherefficiency compressor data was
available.
The California Utilities commented
that concern over the cost and
availability of R–410A compressors may
be mitigated as designs and efficiency of
these compressors improve, and as the
market grows and availability of
compressors increases. (California
Utilities, No. 31 at p. 17) EEI asked
whether DOE conducted testing on
R–410A compressors during its analysis.
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(EEI, Public Meeting Transcript, No.
21.4 at pp. 67–68)
DOE did not conduct tests on R–410A
compressors during the engineering
analysis, but has no reason to believe
that the manufacturers’ performance
data is incorrect. During the final rule
analyses, however, DOE obtained
additional data regarding R–410A
compressor performance and did
consider EER improvement, as
described below.
During interviews conducted during
the final rule phase of today’s final rule,
individual manufacturers reported that
vendor selections of R–410A rotary
compressors were still limited, and that
compressor vendors, where they had
once offered up to three different
efficiency tiers of compressors, now
only offered one or two tiers. One
manufacturer reported a need to source
from many different vendors to achieve
performance goals. Individual
manufacturers identified 10 EER as the
maximum available efficiency for
R–410A compressors, but reported
testing of higher efficiency compressors.
DOE also reviewed R–410A
compressor options available on
compressor vendors’ Web sites, and also
contacted compressor vendors to
discuss their current R–410A
compressor options.
In the analysis for today’s final rule,
DOE added a design option to its
engineering analysis for increasing
compressor efficiency to the identified
maximum compressor EER level.
During the preliminary analysis, DOE
sought information on the performance
of R–410A rotary compressors of
varying efficiency levels for all of the
products under analysis. In many cases,
the range of efficiency for which
vendors provided performance data for
R–410A compressors was limited. In
most cases, compressor vendors had
developed sufficiently for use in
products compressors at only one
efficiency level at each of the relevant
capacities that DOE examined. These
efficiency levels varied widely,
depending on the available
compressors. Due to the lack of maturity
of the R–410A rotary compressor market
at that time, DOE could not confidently
project that higher efficiency levels
would be made available.
During the final rule analysis, DOE
again reviewed the R–410A compressor
market and the available compressors
and found that many more R–410A
rotary compressor options at varying
efficiency levels had been developed.
The highest available nominal EER for
R–410A rotary compressors with
capacities less than 18,000 Btu/h is 10
EER, while the highest available EER for
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compressors with capacities greater than
18,000 Btu/h is 10.3 EER. Interviews
with individual manufacturers
supported these observations.
Consequently, DOE has concluded
that 10 EER is a reasonable maximum
available EER for rotary R–410A
compressors in capacities suitable for
product classes 1 (room air conditioners
without reverse cycle, with louvered
sides, and capacity less than 6,000
Btu/h); 3 (room air conditioners without
reverse cycle, with louvered sides, and
capacities 8,000 to 13,999 Btu/h); 8A
(room air conditioners without reverse
cycle, without louvered sides, and
capacities 8,000 to 10,999 Btu/h); and
8B (room air conditioners without
reverse cycle, without louvered sides,
and capacities 11,000 to 13,999 Btu/h).
Also, DOE concluded that 10.3 EER is
a reasonable maximum available EER
for rotary R–410A compressors in
capacities suitable for product classes
5A (room air conditioners without
reverse cycle, with louvered sides, and
capacities 20,000 to 27,999 Btu/h) and
5B (room air conditioners without
reverse cycle, with louvered sides, and
capacity 28,000 Btu/h or more).
Thereby, DOE selected 10.0 EER as the
maximum EER compressor level for the
analysis of product classes 1, 3, 8A, and
8B; and 10.3 EER as the maximum
compressor level for the analysis of
product classes 5A and 5B.
During the analysis for today’s final
rule, in cases where compressor data
was unavailable for the two maximum
EER levels selected by DOE (as
discussed above), the trends of
compressor performance as a function of
operating conditions were extrapolated.
Compressor performance was
extrapolated from the trends exhibited
by a compressor currently offered on the
market that used the same refrigerant of
nearly the same capacity. DOE
extrapolated compressor data for 10 EER
compressors from similar compressors
with ratings ranging from 9.4 EER to 9.7
EER, and compressor data for 10.3 EER
compressor from similar compressor
with 10 EER ratings. DOE noted the
rapid pace of development of R–410A
compressors (over the course of this
rulemaking); manufacturer interviews
suggested that this rapid development is
on-going and is likely to continue. Thus,
the data suggests that manufacturers
will be able to incorporate R–410A
rotary compressors of capacities for
which data was not available into air
conditioners by the new energy
standard’s compliance date in 2014.
DOE notes that compressors at the
selected max-tech EER levels (for some
capacity levels analyzed) are already
available on the market, and some
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products may already use these
compressors. DOE has determined that
such compressors are currently
manufactured at many more capacity
levels than were observed during the
preliminary analysis. Additional details
of this analysis are available in chapter
5 of the direct final rule TSD.
The greater availability of rotary
compressors also caused DOE to
eliminate consideration of scroll
compressors. DOE had used scroll
compressors as a design option during
the preliminary analysis. However, the
higher EER of high-capacity rotary
compressors that are now available
shifts the economic attractiveness of
scroll compressor technology such that
it is no longer cost effective.
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Size Increases
In the preliminary analysis, DOE
considered chassis size increases to
increase the efficiency of window units,
which corresponded to product classes
1, 3, and 5. DOE believes increases in
coil frontal area and package size are
among the primary factors contributing
to EER improvements in the higherefficiency teardown units for product
classes 1, 3, and 5.
DOE selected baseline, medium, and
large chassis sizes based on the range of
sizes of available room air conditioners.
DOE did not consider chassis size
increases beyond the range of available
products, and considered both the
physical volume and the weight of the
unit. DOE performed cost modeling and
energy modeling of these larger chassis
sizes to calculate cost and efficiency
impacts due to chassis size increases,
based on product teardowns.
During the preliminary analysis
public meeting, DOE requested
comment on the approach for
determining appropriate maximum sizes
for different product classes and
capacities. DOE received stakeholder
comments on both non-louvered room
air conditioner sizes and louvered room
air conditioner sizes.
Non-Louvered Room Air Conditioner
Sizes
PG&E commented that the size of
through-the-wall room air conditioners
(products without louvers) would not
necessarily be constrained if allowed to
project into the outdoor space. (PG&E,
Public Meeting Transcript, No. 21.4 at p.
77) In response, GE stated that existing
wall sleeves do not allow for additional
growth in depth, and through-the-wall
units are typically slid into an existing
wall sleeve. (GE, Public Meeting
Transcript, No. 21.4 at p. 77) To achieve
additional depth, the existing wall
sleeve would need to be replaced.
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AHAM also noted that while additional
heat exchanger coils may increase
efficiency, placing these coils too deep
within the unit will actually decrease
the heat transfer efficiency. (AHAM,
No. 25 at p. 7)
DOE did not consider chassis size
growths as a design option for product
class 8 (room air conditioners without
reverse cycle, without louvered sides,
and capacities 8,000 to 13,999 Btu/h) in
the preliminary analysis. According to
manufacturer interviews, the majority of
non-louvered products are replacement
products that must fit into existing
building sleeves. Building sleeves are
often built into the existing structure
and are fixed components. Replacing
them would require altering the size of
the opening, which would generally be
cost-prohibitive. Due to these
constraints, replacement products must
fit into existing sleeves, which clearly
limit product height and width.
Increases in product depth can be
limited by the design of the sleeve, and
consumers may be unwilling to accept
products that extend further into the
interior. DOE also notes that any
increases in product depth would
present very limited potential in
improvement, because it would not
allow for the unit’s heat exchangers to
grow in width or height.
For these reasons, DOE has chosen to
retain the preliminary analysis
assumption for non-louvered products
that size increase cannot be used to
increase efficiency.
Louvered Room Air Conditioner Sizes
DOE received the following comments
from stakeholders on room air
conditioner sizes for louvered products.
AHAM commented that there are a
range of product depths and weights,
which may suggest that increased
depths and weights may be feasible.
(AHAM, No. 25 at pp. 6–7) AHAM
noted, however, that UL requirements
are an issue when considering increases
in room air conditioner depth, as the
units require that mounting brackets be
designed to ensure that the room air
conditioner remains in the window.
Ensuring that these brackets are used in
each installation can be a potential
safety concern, in particular for smaller
units installed by consumers. Id. AHAM
also noted that smaller products
(especially those in product classes 1
(room air conditioners without reverse
cycle, with louvered sides, and
capacities less than 6,000 Btu/h) and 2
(room air conditioners without reverse
cycle, with louvered sides, and
capacities 6,000 to 7,999 Btu/h)) would
be most negatively impacted by an
increase in weight. AHAM indicated
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that the Occupational Safety and Health
Administration (OSHA) recommends an
additional person for lifting and
installing products weighing over 50
lbs. AHAM stated that the 50-lb. limit is
expected to influence consumer
acceptance of these products. Id.
NPCC recommended that DOE
compare the maximum unit dimensions
in each analyzed product class to the
dimensions of the highest efficiency
model available on the market. (NPCC,
No. 32 at pp. 4–5) NPCC recommended
that, if these two product dimensions
are similar, DOE assume that all units
can be equally as large. NPCC also
recommended that, if the market unit is
smaller than the unit proposed by DOE,
that DOE determine whether a redesign
of the proposed unit would eliminate
the size constraint. (Id.) DOE received
no additional stakeholder comments
addressing maximum acceptable
product sizes for louvered products.
DOE has chosen to use the 50-lb.
weight limitation for product class 1
(room air conditioners without reverse
cycle, without louvered sides, and
capacities less than 6,000 Btu/h). The
National Institute for Occupational
Safety and Health (NIOSH) and OSHA
guidance recommends against handling
loads greater than 50 lbs. for a single
person. NIOSH lists among its hazard
evaluation checklist the handling of
loads exceeding 50 lbs. as a risk factor
used to identify potential problems.37
OSHA, in its ‘‘Ergonomics eTool:
Solutions for Electrical Contractors,’’
states that lifting loads heavier than
50 lbs will increase the risk of injury,
and recommends use of more than one
person to lift weights larger than 50
lbs.38 These guidelines calling for
additional personnel for product lifting
represent distinct changes in consumer
utility for products that currently weigh
less than 50 lbs. This would not be true
for products that already exceed this
limit. DOE notes that all but the smallest
room air conditioners weigh more than
50 lbs. The baseline R–410A designs of
the analyses were all determined to
have weights greater than this limit,
except for product class 1 (room air
conditioners without reverse cycle, with
louvered sides, and capacities less than
6,000 Btu/h). DOE adjusted the analysis
for product class 1 to limit its weight to
50 lbs., but did not make similar
adjustments for any of the other product
classes. Additional details regarding
these adjustments for the product class
37 https://www.cdc.gov/niosh/docs/2007-131/.
38 https://www.osha.gov/SLTC/etools/
electricalcontractors/materials/heavy.html.
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1 analysis is presented in chapter 5 of
the direct final rule TSD.
For the other product classes with
louvered sides, the maximum height
and width considered is consistent with
these dimensions for max-tech available
products. These are the dimensions that
determine that available size for heat
exchangers; DOE’s analysis of product
classes with louvered sides contains
heat exchangers with the same
dimensions as max-tech available units.
DOE observed that all max-tech
products for room air conditioners are
produced primarily by one
manufacturer, and that the depth of
these max-tech available products was
much greater in proportion to other
dimensions than the depths observed in
other manufacturers’ products. DOE’s
analysis indicated that depths
consistent with the proportions
observed in these other manufacturers’
non-max-tech products are sufficient to
provide max-tech performance. In
particular, DOE’s analysis indicated that
the smaller depth was enough to
achieve the requisite condenser airflow,
enabling appropriate heat transfer by the
larger heat exchangers. Thus, DOE’s
analyses did not use the larger product
depths observed in the max-tech
available products. Instead, DOE used
smaller product depths, consistent with
the proportions observed in other
products. This approach was adopted
for product classes 3 (room air
conditioners without reverse cycle, with
louvered sides, and capacities 8,000 to
13,999 Btu/h); 5A (room air
conditioners without reverse cycle, with
louvered sides, and capacities 20,000 to
27,999 Btu/h); and 5B (room air
conditioners without reverse cycle, with
louvered sides, and capacities 28,000
Btu/h or more). Additional details of
this analysis are available in chapter 5
of the direct final rule TSD.
Engineering Analysis Adjustments
A summary table of the key
adjustments made to the product class
structure and the engineering analysis
during the final rule phase of the
rulemaking is presented in Table IV.30.
TABLE IV.30—SUMMARY OF KEY ADJUSTMENTS TO THE ENGINEERING ANALYSIS FOR ROOM AIR CONDITIONERS
Preliminary
Changes for the direct final rule
Product Classes .................................................
No changes considered ...................................
Compressor Efficiency ........................................
Based on available compressor data during
preliminary analysis.
50 lbs Limit .........................................................
Not considered .................................................
Chassis Sizes for Louvered Products ................
Based on analysis of HCFC–22 units .............
Scroll Compressors ............................................
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Parameter
Considered for product class 5 analysis .........
Split of product classes 5 and 8 into two product classes each (5A, 5B, 8A, 8B) based on
stakeholder comments.
Max-efficiency increased to 10 EER for product classes 1, 3, 8A, and 8B, and 10.3 EER
for product classes 5A and 5B.
Introduced a 50 lb weight limit for the analysis
of design options for product class 1.
Adjusted based on additional market research
and teardowns of R–410A units.
Not considered, since they provide no additional improvement over 10.3 EER rotary
compressors, and are much more expensive. This design option is less cost-effective than the design options selected by
DOE for analysis, so it was not considered.
D. Markups Analysis
The markups analysis develops
appropriate markups in the distribution
chain to convert the estimates of
manufacturer cost derived in the
engineering analysis to consumer prices.
At each step in the distribution channel,
companies mark up the price of the
product to cover business costs and
profit margin. DOE estimated the
markups associated with the main
parties in the distribution channel. For
clothes dryers and room air
conditioners, these are manufacturers
and retailers.
DOE developed an average
manufacturer markup by examining the
annual Securities and Exchange
Commission (SEC) 10–K reports filed by
four publicly traded manufacturers
primarily engaged in appliance
manufacturing and whose combined
product range includes residential
clothes dryers and room air
conditioners.
For retailers, DOE developed separate
markups for baseline products (baseline
markups) and for the incremental cost of
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more-efficient products (incremental
markups). Incremental markups are
coefficients that relate the change in the
manufacturer sales price of higherefficiency models to the change in the
retailer sales price.
Commenting on the preliminary TSD,
AHAM filed comments that criticized
DOE’s application of ‘‘incremental’’
markups to the incremental
manufacturer selling price of products
more efficient than the baseline
products. (AHAM, No. 25 at p. 3) In
Exhibit B accompanying this comment,
AHAM stated that (1) DOE provides no
empirical evidence to validate that
retailers obtain only incremental
markups on products with greater
features and costs; and (2) DOE is
asserting a normative approach without
any support showing that its model
reflects actual retail practices. These
comments criticized two of the key
assumptions in DOE’s theoretical
construct: (1) That the costs incurred by
appliance retailers can be divided into
costs that vary in proportion to the MSP
(variable costs), and costs that do not
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vary with the MSP (fixed costs); (2) that
retailer prices vary in proportion to
retailer costs included in the balance
sheets.
Regarding the first assumption,
AHAM stated that DOE has offered no
evidence that the fixed/variable cost
mix of a retailer has anything to do in
practice with the markups that will be
earned by a retailer on products that
meet a new energy conservation
standard. It added that DOE uses an
incorrect analogy to HVAC contractors
as a basis for considering the costs of a
retailer, and that DOE did not analyze
the actual drivers of retail costs. The
retail cost structure has considerably
different characteristics than those of an
HVAC contractor. AHAM stated that
DOE has not presented any data or
analysis that would yield a fixed versus
variable cost allocation applicable to
retailers. Regarding DOE’s second
assumption, AHAM stated that DOE’s
approach depends on the presence of a
relatively high level of competition in
the retail industry. AHAM presented
data showing that the four firm
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concentration ratio (FFCR) of the sectors
that sell major appliances ranges from
42 to 65 percent, which does not
support DOE’s assumption of a high
level of competition in the retail
industry.39
In conclusion, AHAM viewed DOE’s
incremental markup approach as
lacking a credible theoretical
underpinning and demonstrated
reliability and asserted that the data
required for the approach are not
available. AHAM stated that DOE
should return to its traditional practice
of using average markups for both the
baseline products and for the added
costs of efficiency improvements. In
AHAM’s view, the stability of markups
in the retailing sectors leads to the
reasonable inference that such markups
will continue and apply to higherefficiency products in the future when
they become the bulk of sales under
amended standards. (AHAM, No. 34,
Exhibit B, p. 12)
In response to the above comments,
DOE extensively reviewed its
incremental markup approach. DOE
assembled and analyzed relevant data
from other retail sectors and found that
empirical evidence is lacking with
respect to appliance retailer markup
practices when a product increases in
cost due to increased efficiency or other
factors. DOE understands that realworld retailer markup practices vary
depending on market conditions and on
the magnitude of the change in cost of
goods sold (CGS) associated with an
increase in appliance efficiency.
Given this uncertainty with respect to
actual markup practices in appliance
retailing, DOE uses an approach that
reflects two key concepts. First, changes
in the efficiency of the appliances sold
are not expected to increase retailers’
economic profits. Thus, DOE calculates
markups/gross margins to allow cost
recovery for retailers (including changes
in the cost of capital) without changes
in company profits. Second, efficiency
improvements only impact some
distribution costs. DOE sets markups to
cover only the variable costs expected to
change with efficiency.
Market competition is another reason
why DOE believes that profit margins
would not change in a significant way.
Regarding AHAM’s assertion that the
degree of competition in appliance
retailing is not sufficient to support
DOE’s model, DOE believes that
AHAM’s measure of competition is
39 The
FFCR represents the market share of the
four largest firms in the relevant sector. Generally,
an FFCR of less than 40 percent indicates that a
sector is not concentrated and an FFCR of more
than 70 percent indicates that a sector is highly
concentrated.
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inaccurate. AHAM measured the FFCR
of three retail channels: Electronics and
appliance stores, building material and
supplies dealers, and general
merchandise stores. These values
represent competitiveness within each
sector, but clothes dryers and room air
conditioners are sold across all three
sectors, preventing major retailers in
each sector from exercising significant
market power. To properly measure the
competitiveness within appliance
retailing, DOE believes that one should
measure the FFCR for only the
appliance subsector within the above
channels and accordingly estimated the
‘‘appliance sales’’ FFCR as equal to the
sector FFCR times the percent of
appliance sales within each sector. DOE
estimated that these sub-sector FFCRs
are under the 40 percent threshold.
Furthermore, ‘‘Household Appliance
Stores,’’ a subsector of the electronics
and appliance stores sector that
specifically represents appliance
retailers, rather than computer or other
electronics stores, has an FFCR of 17
percent, signifying an unconcentrated
sector.
DOE’s separation of operating
expenses into fixed and variable
components to estimate an incremental
markup follows from the above
concepts. In separating retailer costs,
DOE did not directly use information
from the HVAC contractor industry.
Instead, DOE defined fixed expenses as
including labor and occupancy
expenses because these costs are not
likely to increase as a result of a rise in
CGS due to amended efficiency
standards. All other expenses, as well as
the net profit, are assumed to vary in
proportion to the change in CGS. DOE’s
method results in an outcome in which
retailers are assumed to cover their costs
while maintaining their profit margins
when the CGS of appliances changes.
DOE seeks additional information from
interested parties to help refine its
allocation approach.
Regarding AHAM’s observation about
the relative stability of average markups
for the major retail channels that sell
home appliances, DOE believes that the
usefulness of this information for
estimating markups on specific product
lines is limited. The markups implied
by gross margin at the level of major
retail channels 40 are averaged over
multiple product lines and many
different store types. The empirical data
40 The channels for which AHAM provided gross
margin data for 1993–2007 are electronics and
appliance stores, general merchandise stores, and
building material and supplies dealers. According
to AHAM, these channels accounted for 43 percent,
31 percent and 17 percent of major appliance sales
in 2007, respectively.
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at this level do not provide useful
guidance for estimating what happens to
the markup on specific products when
their costs change. Applying the same
markup as CGS increases, as AHAM
recommends, would mean that the
increase in CGS associated with higherefficiency products would translate into
higher retail gross margins for that
product line. Because the majority of
operating expenses would not be
affected by the increase in CGS, the
result would be an increase in net profit
as a share of sales. While such an
outcome could occur in the short run,
DOE believes that competitive forces in
the market would tend to decrease the
profit margin over time.
Based on the above considerations,
DOE has decided to continue to apply
an incremental markup to the
incremental MSP of products with
higher efficiency than the baseline
products. As part of its review, DOE
developed a new breakdown into fixed
and variable components using the
latest expense data provided by the U.S.
Census for Electronics and Appliance
Stores, which cover 2002. The newlyderived incremental markup, which
would be applied to an incremental
change in CGS, is 1.17, which is slightly
higher than the value of 1.15 that DOE
used in the preliminary analysis.
Chapter 6 of the direct final rule TSD
provides a description of both the
method and its current application
using the aforementioned data.
E. Energy Use Analysis
DOE’s analysis of the energy use of
clothes dryers and room air conditioners
estimated the energy use of these
products in the field, that is, as they are
actually used by consumers. The energy
use analysis provided the basis for other
analyses DOE performed, particularly
assessments of the energy savings and
the savings in consumer operating costs
that could result from DOE’s adoption of
amended standards. In contrast to the
DOE test procedure, which provides a
measure of the energy use, energy
efficiency or annual operating cost of a
covered product during a representative
average use cycle or period of use, the
energy use analysis seeks to capture the
range of operating conditions for clothes
dryers and room air conditioners in U.S.
homes.
To determine the field energy use of
products that would meet possible
amended standard levels, DOE used
data from the EIA’s 2005 RECS, which
was the most recent such survey
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available at the time of DOE’s analysis.41
RECS is a national sample survey of
housing units that collects statistical
information on the consumption of and
expenditures for energy in housing units
along with data on energy-related
characteristics of the housing units and
occupants. RECS provides sufficient
information to establish the type
(product class) of clothes dryer or room
air conditioner used in each household.
As a result, DOE was able to develop
household samples for each of the
considered product classes. DOE
developed a separate building sample
for commercial-sector use of room air
conditioners and accounted for the
distinct features of room air conditioner
utilization in commercial buildings.
A more detailed description of DOE’s
energy use analysis for clothes dryers
and room air conditioners is contained
in chapter 7 of the direct final rule TSD.
1. Clothes Dryers
For clothes dryers with a specific
efficiency, the annual energy
consumption depends on the annual
number of cycles. In the preliminary
analysis, DOE used a distribution of
values with an average of 283 cycles/
year based on RECS data. Whirlpool
stated that a range of 278–300 annual
dryer cycles is reasonable, based on P&G
data which indicate 278 annual dryer
cycles, and internal data which indicate
288 annual dryer cycles. (Whirlpool,
No. 22 at p. 3) AHAM stated that P&G
data indicate 278 annual dryer loads,
which verifies the RECS data. (AHAM,
No. 25 at p. 9) DOE acknowledges the
above comments and has retained the
approach used in the preliminary
analysis, which resulted in an average of
283 cycles/year, for its final rule
analysis. This average value matches the
number of cycles/yr in the most current
DOE clothes dryers test procedure and
is within the range of the values
submitted by the commenters.
In the preliminary analysis, DOE
estimated that clothes dryers take on
average 60 minutes to complete a cycle.
EEI stated that DOE should consider
manufacturer data, consumer reports, or
data from other third parties to
determine typical cycle time for clothes
dryers. (EEI, Public Meeting Transcript,
No. 21.4 at pp. 106–107) ALS stated that
cycle time should be derived based on
RMC, assuming that a sensor will be
included in all future models. (ALS,
Public Meeting Transcript, No. 21.4 at
pp. 110–111) NRDC stated that there is
a 20-minute variation in cycle time,
based on whether the sensors work
41 For
information on RECS, see https://
www.eia.doe.gov/emeu/recs/.
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accurately. (NRDC, Public Meeting
Transcript, No. 21.4 at p. 106) The
NRDC/ECOS report stated that a typical
drying cycle is much different than the
constant drying cycle duration fixed at
60 minutes that is used in the LCC.
(NRDC, No. 30 at p. 11)
DOE acknowledges that there is
variation in cycle time and that it is
dependent on the RMC and the sensors’
accuracy. In the final rule analysis, DOE
revised the cycle time to match the most
current DOE test procedure average
value of 30 minutes. Overall, the cycle
time has very little impact on the
calculation of energy use because it is
only used for the determination of
standby energy use.
In the preliminary analysis, DOE
assigned an RMC value to each sample
unit using a distribution of clothes
washer RMC values from the CEC
directory 42 ranging from 30 percent to
61 percent, with an average of 46
percent. In response, AHAM suggested
DOE use a RMC value of 47 percent
because it is representative of products
likely to be sold in the 2015 timeframe.
(AHAM, No. 25 at pp. 9–10) Whirlpool
stated that they support the use of
AHAM data, which indicate a shipmentweighted average RMC of 47 percent.
(Whirlpool, No. 22 at p. 4)
In its analysis for the final rule, DOE
incorporated new information about the
RMC value developed during DOE’s
recent clothes dryers test procedure
rulemaking. In response to comments on
the clothes dryers test procedure NOPR,
DOE issued an SNOPR in which it
proposed a revision of the average RMC
value. FR 75 37594 (June 29, 2010). The
revision addresses the fact that the RMC
values listed in the CEC directory are
multiplied by a correction factor and
therefore do not represent the actual
cloth moisture content at the end of the
clothes washer spin cycle. In keeping
with this revision, for the final rule
analysis DOE used a distribution of
clothes washer RMC values from the
CEC directory multiplied by a correction
factor to match the average RMC value
of 57.5 percent assumed in the proposed
test procedure.
In the preliminary analysis, DOE
assigned load weights to each sample
household by developing a distribution
based on the CEC directory. The average
load weights for standard-size units
ranged from 5.1 lbs. to 10 lbs., with a
mean value of 8.1 lbs.
AHAM stated that the shipmentweighted residential clothes washer
drum volume for standard size products
42 California Energy Commission. Appliance
Efficiency Database: Clothes Washers. July 2010.
URL: https://www.appliances.energy.ca.gov/.
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in 2008 was 3.24 ft3, which corresponds
to an average load size of 8.15 lbs.,
which is consistent with the value
proposed by DOE, using the alternative
CEC approach. AHAM also stated that
the load size should be 4.70 lbs. for
compact clothes dryers, based on the
shipment-weighted drum volume of 1.5
ft3. (AHAM, No. 25 at p. 10) BSH stated
that load size should increase linearly
with drum size. (BSH, No. 23 at p. 5)
The NRDC/ECOS Report suggested that
the values used in the preliminary
analysis may be too low. It stated that
today’s dryers can comfortably
accommodate loads between 10 and 17
lbs., and that there are more dryer
models on the market today between 7
and 8 ft3 than there are models smaller
than 7 ft3. (NRDC, No. 30 at p. 35)
In its analysis for the final rule, DOE
used the average load size value of 8.45
lbs. from the TP Final Rule. To
represent a range of load size values in
the field, DOE used a distribution of
load sizes ranging from 3.80 to 13.7 lbs.,
with a mean value of 8.45 lbs. Chapter
7 of the TSD presents the details of the
DOE’s load size analysis.
DOE received several comments
recommending that it use the same
values for number of cycles, RMC, and
load weights in both the engineering
analysis and the LCC and PBP analysis,
and that it revise the test procedure to
reflect the values used in its analysis.
(AHAM, No. 25 at pp. 9–10; Whirlpool,
No. 22 at pp. 3–4) The California
Utilities stated that DOE should
consider all changes in the test
procedure in additional analysis of
clothes dryer energy use. (California
Utilities, No. 31 at p. 13)
For its LCC and payback period
analysis DOE developed distributions of
values for number of cycles, RMC, and
load weights that reflect its best estimate
of the range of practices found in U.S.
homes. In the engineering analysis, DOE
uses the test procedure to evaluate the
relative improvement in energy
efficiency provided by different design
options. As discussed in section III.A,
DOE has modified the clothes dryer test
procedure to reflect current field
conditions, and these changes are also
incorporated in the analysis for the final
rule.
In the preliminary analysis, DOE
estimated an average energy use of 519
kWh per year for the baseline vented
electric standard clothes dryer. ACEEE
stated that DOE should revisit the
approach to determining annual energy
consumption, and it noted that the
baseline average unit energy
consumption (UEC) of 519 kWh/year in
DOE’s analysis is much lower than the
values found in field studies and
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metered evaluations of clothes dryer
models. (ACEEE, No. 24 at p. 2) The
California Utilities stated that a Florida
Solar Energy Center survey found that
field-average UEC for electric standard
clothes dryers was around 900 kWh/
year, the 2001 RECS lists 1079 kWh/
year, and a 1999 Progress Energy Florida
study shows 885 kWh/year. They noted
that these numbers are significantly
higher than DOE’s average UEC.
(California Utilities, No. 31 at p. 12)
As described above, DOE made
several changes to its approach for
estimating clothes dryer energy use for
the final rule (increased initial RMC
value and clothes dryer load size). As a
result, the average annual energy use for
the baseline vented electric clothes
dryer derived for the final rule is 718
kWh. This value is lower than those
found in the surveys mentioned above
primarily because it reflects more recent
clothes washer technology and clothes
dryer utilization than the surveys
discussed in the comment. In particular,
this value reflects the lower initial RMC
associated with newer clothes washers
and the lower number of clothes dryer
cycles per year seen in recent P&G data
and 2005 RECS data. The value from
2001 RECS was derived using
conditional demand analysis that
utilized assumptions based on the
previous clothes dryer test procedure.
The Florida surveys date from 1999,
when initial RMC and annual number of
dryer cycles were higher significantly
higher than the values used in the final
rule analysis. In addition, the sample
size of these surveys is small and not
necessarily representative of the nation.
In the preliminary analysis, DOE
considered the impact of clothes dryer
operation on home heating and cooling
loads. A clothes dryer releases heat to
the surrounding environment. If the
dryer is located indoors, its use will
tend to slightly reduce the heating load
during the heating season and slightly
increase the cooling load during the
cooling season. DOE believed that the
effect is the same for all of the
considered efficiency levels because the
amount of air passing through the
clothes dryer does not vary, and thus it
did not include this factor in its
preliminary analysis.
ACEEE, NRDC, NEEP and NPCC and
the California Utilities stated that DOE
should consider the impact on space
conditioning loads from clothes dryer
use. (ACEEE, No. 24 at p. 2; NRDC, No.
26 at p. 2; NEEP, No. 27 at p. 3; NPCC,
No. 32 at p. 3; California Utilities, No.
31 at p. 9) The California Utilities stated
that the HVAC load created by dryers
can amount to as much as 3 kWh/cycle.
(California Utilities, No. 31 at p. 9)
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As discussed in section III.A.1, DOE
believes that accounting for the effects
of clothes dryers on HVAC energy use
in a DOE test procedure is inconsistent
with the EPCA requirement that a test
procedure measure the energy
efficiency, energy use, or estimated
annual operating cost of a covered
product. As a result, DOE did not
consider the impact of standards on
HVAC energy use, is permissible under
42 U.S.C. 6295(o) in developing the
energy conservation standards
established in today’s direct final rule.
To calculate this impact, DOE first
estimated whether the clothes dryer in
a RECS sample home is located in
conditioned space (referred to as
indoors) or in unconditioned space
(such as garages, unconditioned
basements, outdoor utility closets, or
attics). Based on the 2005 RECS and the
2009 American Housing Survey (AHS),
DOE assumed that 50 percent of vented
standard electric and gas dryers are
located indoors, while 100 percent of
compact and ventless clothes dryers are
located indoors. For these installations,
DOE utilized the results from a
European Union study about the
impacts of clothes dryers on home
heating and cooling loads to determine
a the appropriate factor to apply to the
total clothes dryer energy use.43 This
study reported that for vented dryers
there is a factor of negative 3 to 9
percent (average 6 percent) and for
ventless dryers there is a factor of
positive 7 to 15 percent (average 11
percent). For the reasons stated earlier,
DOE assumed that the effect is the same
for all considered efficiency levels.
2. Room Air Conditioners
For room air conditioners with a
specific size and EER, the annual energy
use depends on the annual hours of
operation. In the preliminary analysis,
for units in the residential sector, DOE
calculated the number of operating
hours for each room air conditioner in
the residential sample using the
reported energy use for room air
conditioning in the 2005 RECS, along
with estimates of the EER of the room
air conditioner(s) in each sample home.
DOE based the latter on the reported age
of the unit and historical data on
shipment-weighted average EER.
For units used in the commercial
sector, DOE calculated the number of
operating hours for each room air
conditioner in the commercial sample
43 Rudenauer, Ina and Gensch, Carl-Otto. Energy
¨
demand of tumble dryers with respect to differences
in technology and ambient conditions. Report
commissioned by European Committee of Domestic
Equipment Manufacturers (CECED). January 13,
2004.
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by establishing a relationship between
cooling degree-days and operating hours
for a number of building types and
building schedule combinations. DOE
assumed that a room air conditioner is
operated when the outdoor air
conditions are above the comfort zone
described by ANSI/ASHRAE Standard
55–2004 Thermal Environmental
Conditions for Human Occupancy. For
a given location, the number of annual
hours above the ASHRAE Standard 55
comfort zone varies by building
operating schedule, which refers to the
time that a building is in operation.
AHAM stated that it opposes the use
of RECS and CBECS data to estimate
energy consumption of room air
conditioners in the LCC and payback
period calculations, and it requested
confirmation that DOE’s estimates for
both residential and commercial room
air conditioner use are realistic.
(AHAM, No. 25 at pp. 8–9) AHAM
questioned the validity of DOE’s
analysis for residential use of room air
conditioners. AHAM stated that RECS
data do not provide information on
room air conditioner capacity or a direct
measurement of room air conditioner
energy use. (AHAM, No. 25 at p. 2)
AHAM also questioned DOE’s estimate
of the capacity of the unit (or units)
based on the reported total cooled area,
as well as the approach DOE used to
distribute the capacity sizes among the
various product classes evaluated.
(AHAM, No. 25 at pp. 8–9)
Regarding the use of RECS data to
estimate the capacity of the unit (or
units), DOE believes that the reported
total cooled area is an important
indicator of the capacity of the unit (or
units). The reason is that for room air
conditioners this is the primary sizing
criteria used by manufacturers,
contractors, and programs such as
ENERGY STAR. Therefore, DOE
continued to use reported total cooled
area to estimate the room air conditioner
capacity. To improve the accuracy of the
estimate, for the final rule DOE also
considered additional factors that are
likely to influence the capacity
selection: The number of occupants,
local weather, and building
characteristics such as envelope
insulation and shading. In addition, for
the final rule analysis DOE revised its
criteria for assigning room air
conditioner units for the RECS
household sample associated with each
product class. DOE took into
consideration AHAM’s suggestion and
did not assign smaller-size units in the
sample for the largest product class.
In addition to the above changes, DOE
applied an adjustment to the values for
annual operating hours derived from the
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2005 RECS to account for the warmerthan-average weather in 2005. (DOE
used long-term national average cooling
degree-day values as a basis for the
adjustment). DOE also adjusted the
values to account for the fact that the
stock of homes in 2014 is likely to have
slightly more floor area and have better
insulation than homes in 2005. DOE
based the adjustment on projections in
AEO2010. These modifications are
described in chapter 7 of the direct final
rule TSD.
Regarding DOE’s use of CBECS for
estimating the commercial use of room
air conditioners, AHAM stated that (1)
DOE made substantial assumptions
regarding the number of room air
conditioners per commercial
application and the room air
conditioner capacities employed at
these locations; and (2) it appears that
DOE, to obtain enough data for
statistical analysis, overlapped the units
in each product class. (That is, units
calculated as having > 20,000 Btu/hr
capacity have also been included in the
analysis of the < 6,000 Btu/hr and
8,000–13,999 Btu/hr product classes.) It
stated that the latter approach is
misleading and unacceptable. (AHAM,
No. 25 at p. 3)
DOE believes that the assumptions
made in the preliminary analysis are
consistent with the CBECS and AHAM
shipments data that are available for
evaluating commercial use of room air
conditioners. Therefore, DOE retained
the approach used in the preliminary
analysis for the final rule analysis.
Regarding the overlapping of units
among product classes, DOE believes
that its approach is reasonable given
that there is no information available on
the number of air conditioner units in
a building, so a building could have one
or more units in any of the considered
product classes.
AHAM stated that DOE’s approach for
estimating room air conditioner energy
use is not consistent with the law,
which requires that the test procedure
be used to determine energy use and
energy savings. (AHAM, No. 25 at p. 2)
AHAM elaborated on this statement and
made arguments that can be
summarized as follows (AHAM, No. 25
at pp. 7–8):
1. While use of RECS data has proven
useful over the years to provide general
guidance to DOE on residential energy
use, this is the first time that DOE
proposes to use it to estimate actual
energy consumption in the field and to
justify a new energy efficiency standard;
2. It is inconsistent for DOE to use
RECS data and statistical regression
techniques to estimate energy use for
determining the life cycle cost and
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payback period used to justify an
appliance standard, while it uses the
applicable test procedure as the sole
source of energy use data for purposes
of determining compliance with the
standard.
3. Reliance on the test procedure for
the energy data used in LCC and
payback period calculations to set new
appliance standards is the tried and true
method that has a clear statutory basis.
4. The law on labeling prohibits
manufacturers, distributors, and
retailers from making energy use
representations about their products
based on anything other than the results
of a test procedure, so it is irrational if
DOE’s analysis makes energy claims that
sellers cannot make.
AHAM also stated that DOE should
use 750 annual operating hours (the
value in the current test procedure) to
maintain consistency while additional
surveys or testing are completed to
determine a representative number of
annual operating hours. (AHAM, No. 25
at p. 9)
In response, DOE notes that EPCA
specifies particular uses of the
applicable test procedure, such as when
DOE ascertains whether the consumer
costs associated with the purchase of a
product that complies with the
proposed standard level is less than
three times the value of the energy
savings the consumer will receive
during the first year of ownership. (42
U.S.C. 6295(o)(2)(B)(iii)) This
calculation is separate from the payback
periods calculated in the LCC and
payback period analysis. The latter
analysis helps DOE to evaluate two of
the factors that EPCA directs DOE to
consider in determining whether an
energy conservation standard for a
particular covered product is
economically justified. The first of these
is the economic impact of potential
standards on the manufacturers and the
consumers of the covered products. (42
U.S.C. 6295(o)(2)(B)(i)(I)) The second
factor is 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
products which are likely to result from
the imposition of the standard. (42
U.S.C. 6295(o)(2)(B)(i)(II))
To evaluate economic impacts on
consumers and the savings in operating
costs as accurately as possible, DOE
needs to determine the energy savings
that are likely to result from a given
standard. Such a determination requires
knowledge of the range of actual use of
covered products by consumers.
Because it is a recent nationally-
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representative survey of U.S.
households, RECS provides information
that helps DOE to determine such use.
In addition, DOE uses RECS data
because it is consistent with the
guidance contained in 10 CFR part 430,
subpart C, appendix A—‘‘Procedures,
Interpretations and Policies for
Consideration of New or Revised Energy
Conservation Standards for Consumer
Products.’’ Specifically, section 11 of
appendix A lists variation in consumer
impacts as one of the principles for the
analysis of impacts on consumers.
Because RECS provides considerable
information about each household in
the sample, it allows DOE to evaluate
factors that contribute to variation in the
energy use of covered products. In turn,
this allows DOE to estimate the fraction
of consumers that will benefit from
standards at various efficiency levels.
Consistent with the EPCA and DOE’s
regulatory guidance, DOE has used
RECS data in a variety of ways over the
past decade. In most cases, DOE has
used the relevant DOE test procedure or
a similar procedure as the basis for the
energy use calculation, and used RECS
data to provide a range for key input
variables concerning the operation of
covered products. Examples include the
standards rulemaking for water heaters
concluded in 2001 (66 FR 4474 (Jan. 17,
2001)), and the recently-concluded
rulemaking that amended standards for
water heaters. 75 FR 20112, 20112–
20236 (Apr. 16, 2010). In both
rulemakings, DOE used data for each of
the households in the RECS sample to
estimate the amount of household daily
hot water use, and to specify certain
factors that affect water heater operating
conditions. Additionally, DOE’s 2001
final rule for central air conditioners
and heat pumps relied on annual energy
use based on the annual end-use energy
consumption values in RECS. 66 FR
7070, 7170–7200 (Jan. 22, 2001). DOE
determined that basing the energy use
on RECS household data provided an
accurate measure of the savings possible
from more-efficient equipment, and
accounted for variability due to climatic
conditions and consumer behavior.
Regarding AHAM’s suggestion that
DOE should use the test procedure only
to estimate energy use for the purposes
of its analysis of standards, DOE notes
that test procedures must be designed to
produce test results which measure
energy efficiency, energy use or
estimated annual operating cost of a
covered product during a representative
average use cycle or period of use. (42
U.S.C. 6293(b)(3)) For the purposes of
evaluating two of the factors that EPCA
directs DOE to consider in determining
whether an energy conservation
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standard for covered products is
economically justified, determining
energy use based on only a
representative average use cycle or
period of use does not provide an
accurate measure of the range of
possible energy savings. Thus, doing so
would not be consistent with EPCA and
the above-cited guidance of appendix A
to subpart C of part 430.
In addition, EPCA requires that
manufacturers and DOE use the DOE
test procedures prescribed pursuant to
42 U.S.C. 6293 in determining
compliance. Determining compliance
requires a metric that provides
repeatable and consistent results for
appliances in a given product class, a
purpose best served by the test
procedure. Similarly, energy labeling of
appliances is designed to provide
consumers with information that allows
comparison of the technical
performance of different products with
respect to energy efficiency.
Measurement of such performance is
best conducted with a standard metric
such as the applicable test procedure.
The LCC and PBP analysis, in contrast,
seeks to estimate the impact of
alternative standard levels on
consumers. This requires an evaluation
of variation in energy use in the field,
which is provided by analysis of the
RECS data.
DOE included a ‘‘rebound effect’’ in its
analysis of room air conditioner energy
use. A rebound effect could occur when
a piece of equipment that is more
efficient is used more intensively, so
that the expected energy savings from
the efficiency improvement may not
fully materialize. A rebound effect of 10
percent implies that 90 percent of the
expected energy savings from more
efficient equipment will actually occur.
Based on the data available,44 DOE
incorporated a rebound effect of 15
percent for room air conditioners in the
analysis for the final rule.
F. Life-Cycle Cost and Payback Period
Analyses
DOE conducts LCC and PBP analyses
to evaluate the economic impacts on
individual consumers of potential
energy conservation standards for
clothes dryers and room air
conditioners. The LCC is the total
consumer expense over the life of a
product, consisting of purchase 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.
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
(normally higher) due to a more
stringent standard by the change in
average annual operating cost (normally
lower) that results from the standard.
For any given efficiency level, DOE
measures the PBP and the change in
LCC relative to an estimate of the basecase appliance efficiency levels. The
base-case estimate reflects the market in
the absence of new or amended energy
conservation standards, including the
market for products that exceed the
current energy conservation standards.
For each considered efficiency level
in each product class, DOE calculated
the LCC and PBP for a nationally
representative set of housing units. For
the preliminary analysis and the
analysis for today’s rule, DOE developed
household samples from the 2005 RECS.
For each sample household, DOE
determined the energy consumption for
the clothes dryer or room air
conditioner and the appropriate
electricity or natural gas price. By
developing a representative sample of
households, the analysis captured the
variability in energy consumption and
energy prices associated with the use of
residential clothes dryers and room air
conditioners. DOE developed a separate
22511
building sample for commercial-sector
use of room air conditioners and
accounted for the distinct features of
room air conditioner utilization in
commercial buildings.
Inputs to the calculation of total
installed cost include the cost of the
product—which includes manufacturer
costs, 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, discount rates, and the year
that compliance with standards is
required. DOE created distributions of
values for some inputs, with
probabilities attached to each value, to
account for their uncertainty and
variability. DOE used probability
distributions to characterize product
lifetime, discount rates, and sales taxes.
The computer model DOE uses to
calculate the LCC and PBP, which
incorporates Crystal Ball (a
commercially available software
program) 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 clothes
dryer and room air conditioner user
samples. The model calculated the LCC
and PBP for products at each efficiency
level for 10,000 housing units per
simulation run. Details of the
spreadsheet model, and of all the inputs
to the LCC and PBP analyses, are
contained in chapter 8 of the direct final
rule TSD and its appendices.
Table IV.31 summarizes the approach
and data DOE used to derive inputs to
the LCC and PBP calculations. The table
provides the data and approach DOE
used for the preliminary TSD, as well as
the changes made for today’s direct final
rule. The subsections that follow
discuss the initial inputs and methods
and the changes DOE made for the final
rule.
TABLE IV.31—SUMMARY OF INPUTS AND METHODS IN THE LCC AND PBP ANALYSIS *
Inputs
Preliminary TSD
Changes for the final rule
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Installed Costs
Product Cost ............................................
44 S. Sorrell, J. Dimitropoulos, and M.
Sommerville Empirical estimates of the direct
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Derived by multiplying manufacturer cost by
manufacturer and retailer markups and sales
tax, as appropriate.
Used a product-specific price/cost adjustment
factor based on experience curves that forecasts changes in price relative to inflation in
the over-all economy.
rebound effect: A review Energy Policy, 2009 37,
pp. 1356–71.
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TABLE IV.31—SUMMARY OF INPUTS AND METHODS IN THE LCC AND PBP ANALYSIS *—Continued
Inputs
Preliminary TSD
Changes for the final rule
Installation Costs ......................................
Based on RS Means, assumed no change with
efficiency level.
Based on RS Means; included additional installation cost for heat pump dryers and higher-efficiency room air conditioners due to their larger
dimensions and weight.
Operating Costs
Annual Energy Use ..................................
Energy Prices ...........................................
Energy Price Trends ................................
Repair and Maintenance Costs ...............
Clothes Dryers: Used DOE test procedure with
data on cycles from the 2005 RECS, market
data on RMC, and load weights from test procedure.
Room Air Conditioners: Based on calculation of
operating hours for each 2005 RECS sample
unit.
Electricity (clothes dryers): Based on EIA’s Form
861 data for 2007.
Electricity (room air conditioners): Used utility tariff data to develop monthly marginal electricity
prices for each sample household.
Natural gas: Based on EIA’s Natural Gas Monthly data for 2007.
Variability: Regional energy prices determined for
13 regions for clothes dryers; tariffs determined
for sample households for room air conditioners.
Forecasted using AEO2009 price forecasts .........
Not included ..........................................................
Clothes Dryers: Same approach, but RMC and
load weight revised to account for proposed
changes in DOE test procedure.
Room Air Conditioners: No change.
Electricity (clothes dryers): Updated using Form
861 data for 2008.
Electricity (room air conditioners): No change.
Natural gas: Updated using Natural Gas Monthly
data for 2009.
Variability: No change.
Forecasts updated using AEO2010.
Derived annualized maintenance and repair frequencies and costs per service call based on
RS Means and equipment cost.
Present Value of Operating Cost Savings
Product Lifetime .......................................
Discount Rates .........................................
Compliance Date ......................................
Estimated using survey results from RECS
(1990, 1993, 1997, 2001, 2005) and the U.S.
Census American Housing Survey (2005,
2007), along with historic data on appliance
shipments.
Variability: Characterized using Weibull probability distributions.
Identified all possible debt or asset classes that
might be used to purchase the considered appliances, or might be affected indirectly. Primary data source was the Federal Reserve
Board’s SCF ** for 1989, 1992, 1995, 1998,
2001, 2004 and 2007.
2014 ......................................................................
No change.
No change.
No change.
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* References for the data sources mentioned in this table are provided in the sections following the table or in chapter 8 of the direct final rule
TSD.
** Survey of Consumer Finances.
As discussed in section IV.E, DOE
takes into account the rebound effect
associated with more efficient room air
conditioners. The take-back in energy
consumption associated with the
rebound effect provides consumers with
increased value (for example, a cooler or
warmer indoor environment). The net
impact on consumers is thus the sum of
the change in the cost of owning the
room air conditioner (that is, life-cycle
cost) and the increased value for the
more comfortable indoor environment.
The consumer effectively pays for the
increased value of a more comfortable
environment in his or her utility bill.
Because the monetary cost of this added
value is equivalent to the value of the
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foregone energy savings, the economic
impacts on consumers measured in the
LCC analysis are the same regardless of
the rebound effect.
1. Product Cost
To calculate consumer product costs,
DOE multiplied the manufacturer
selling prices developed in the
engineering analysis by the supplychain markups described above (along
with sales taxes). DOE used different
markups for baseline products and
higher-efficiency products because, as
discussed previously, DOE applies an
incremental markup to the MSP
increase associated with higher
efficiency products.
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On February 22, 2011, DOE published
a Notice of Data Availability (NODA, 76
FR 9696) stating that DOE may consider
improving regulatory analysis by
addressing equipment price trends.
Consistent with the NODA, DOE
examined historical producer price
indices (PPI) for room air conditioners
and household laundry equipment and
found a consistent, long-term declining
real price trend for both products.
Consistent with the method proposed in
the NODA, DOE used experience curve
fits to forecast a price scaling index to
forecast product costs into the future for
this rulemaking. DOE also considered
the public comments that were received
in response to the NODA and refined
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the evaluation of its experience curve
trend forecasting estimates. Many
commenters were supportive of DOE
moving from an assumption-based
equipment price trend forecasting
method to a data-driven methodology
for forecasting price trends. Other
commenters were skeptical that DOE
could accurately forecast price trends
given the many variables and factors
that can complicate both the estimation
and the interpretation of the numerical
price trend results and the relationship
between price and cost. DOE evaluated
these concerns and determined that
retaining the assumption-based
approach of a constant real price trend
was not consistent with the historical
data for the products covered in this
rule though this scenario does represent
a reasonable upper bound on the future
equipment price trend. DOE also
performed an initial evaluation of the
possibility of other factors complicating
the estimation of the long-term price
trend, and developed a range of
potential price trend values that were
consistent with the available data and
justified by the amount of data available
to DOE. DOE recognizes that its price
trend forecasting methods are likely to
be modified as more data and
information becomes available to
enhance the statistical certainty of the
trend estimate and the completeness of
the model. Additional data should
enable an improved evaluation of the
potential impacts of more of the factors
that can influence equipment price
trends over time.
To evaluate the impact of the
uncertainty of the price trend estimates,
DOE performed price trend sensitivity
calculations in the national impact
analysis to examine the dependence of
the analysis results—specifically
annualized net national benefits—on
different analytical assumptions. DOE
also included a zero real price trend
assumption as a sensitivity scenario
representing an upper bound on the
forecast price trend DOE found that for
the selected standard levels the benefits
outweighed the burdens under all
scenarios.
A more detailed discussion of price
trend modeling and calculations is
provided in Appendix 8–J of the TSD.
2. Installation Cost
Installation cost includes labor,
overhead, and any miscellaneous
materials and parts needed to install the
equipment. For the preliminary
analysis, DOE derived baseline
installation costs for clothes dryers and
room air conditioners from data in the
RS Means 2008. DOE found no evidence
that installation costs would be
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impacted with increased efficiency
levels. Commenting on DOE’s
assumption, Whirlpool stated that heat
pump dryers would be considerably
heavier than conventional dryers,
leading to increased installation costs.
(Whirlpool, No. 22 at p. 4) AHAM made
a similar comment. (AHAM, Public
Meeting Transcript, No. 21.4 at pp.
89–90)
For the final rule analysis, DOE
included an additional installation cost
for heat pump dryers due to their larger
dimensions and weight. DOE added 0.5
hour of additional labor (or about $20)
to the installation cost. For room air
conditioners, DOE also added additional
labor hours for higher efficiency
equipment with significant larger
dimensions and/or weight based on RS
Means labor hour estimates for room air
conditioners with different capacities.
3. Annual Energy Consumption
For each sampled household, DOE
determined the energy consumption for
a clothes dryer or room air conditioner
at different efficiency levels using the
approach described above in section
IV.E.
4. Energy Prices
For clothes dryers, DOE derived
average annual energy prices for 13
geographic areas consisting of the nine
U.S. Census divisions, with four large
states (New York, Florida, Texas, and
California) treated separately. For
Census divisions containing one of
these large states, DOE calculated the
regional average excluding the data for
the large state.
DOE calculated average residential
electricity prices for each of the 13
geographic areas using data from EIA’s
Form EIA–861 Database (based on
‘‘Annual Electric Power Industry
Report’’).45 DOE calculated an average
annual regional residential price by: (1)
Estimating an average residential price
for each utility (by dividing the
residential revenues by residential
sales); and (2) weighting each utility by
the number of residential consumers it
served in that region. For the
preliminary TSD, DOE used the data for
2007. The final rule analysis updated
the data for 2008, the most recent data
available.
DOE calculated average residential
natural gas prices for each of the 13
geographic areas using data from EIA’s
‘‘Natural Gas Monthly.’’ 46 DOE
calculated average annual regional
45 Available at: https://www.eia.doe.gov/cneaf/
electricity/page/eia861.html.
46 Available at: https://www.eia.gov/oil_gas/
natural_gas/data_publications/
natural_gas_monthly/ngm.html.
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residential prices by: (1) Estimating an
average residential price for each state;
and (2) weighting each state by the
number of residential consumers. For
the preliminary TSD, DOE used EIA
data for 2007. The final rule analysis
updated the data for 2009, the most
recent data available.
For the preliminary analysis, for room
air conditioners DOE used utility tariff
data to develop monthly marginal
electricity prices for each sample
household used in the LCC analysis.
The marginal prices were calculated by
taking account of the difference between
the household’s electricity expenditures
for the base case electricity use and for
a candidate standard level, in
combination with the associated change
in energy use expected as a result of a
particular standard level. The price used
was based on the default (non-TOU)
tariffs, because TOU tariffs are optional
and very few customers opt for such
rates. DOE then applied the monthly
prices to the estimated electricity use by
the room air conditioner in each
corresponding month. This approach
applies summer rates to the estimated
consumption in summer months. DOE
also used tariff data to develop marginal
electricity prices for each commercial
building in the LCC sample. DOE used
the same approach for today’s final rule.
5. Energy Price Projections
To estimate energy prices in future
years for the preliminary TSD, DOE
multiplied the above average regional
energy prices by the forecast of annual
average residential energy price changes
in the Reference Case from
AEO2009.47 AEO2009 forecasted prices
through 2030. For today’s proposed
rule, DOE updated its energy price
forecasts using AEO2010, which has an
end year of 2035.48 To estimate the price
trends after 2035, DOE used the average
annual rate of change in prices from
2020 to 2035.
6. Maintenance and Repair Costs
Repair costs are associated with
repairing or replacing components that
have failed in the appliance, whereas
maintenance costs are associated with
maintaining the operation of the
equipment. In its preliminary analysis,
DOE did not have information
suggesting that these costs would
change with higher efficiency levels.
47 The spreadsheet tool that DOE used to conduct
the LCC and PBP analyses allows users to select
price forecasts from either AEO’s High Economic
Growth or Low Economic Growth Cases. Users can
thereby estimate the sensitivity of the LCC and PBP
results to different energy price forecasts.
48 U.S. Energy Information Administration.
Annual Energy Outlook 2010. Washington, DC.
April 2010.
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Commenting on DOE’s approach,
AHAM stated that repair costs are
typically estimated using a 1:1 ratio
with part costs, so if component costs
increase by 10 percent, repair costs are
expected to also increase by 10 percent.
AHAM stated that DOE should
incorporate these higher repair costs
into its analysis of clothes dryers and
room air conditioners to provide a more
representative evaluation of total
consumer cost for higher efficiency
products. (AHAM, No. 25 at p. 12)
For clothes dryers, Whirlpool stated
that the repair and maintenance costs
generally do not vary by efficiency, but
for heat pump dryers, this assumption is
not valid. Whirlpool stated that new
technologies such as these would cost
two to three times more to repair than
conventional dryers due to their
complex nature and the cost of
disconnecting and reconnecting water
sources. (Whirlpool, No. 22 at p. 4)
AHAM stated that maintenance costs
generally will not vary by efficiency
level, but a heat pump clothes dryer is
expected to have higher maintenance
costs because of the heat pump and the
addition of refrigerant. AHAM stated
that maintenance for these units would
be similar to that for standard air
conditioning equipment or heat pump
water heaters. (AHAM, No. 25 at p. 11)
For the final rule analysis, DOE
modified the maintenance and repair
costs for both clothes dryers and room
air conditioners. For clothes dryers,
DOE derived annualized maintenance
and repair frequencies based on
Consumer Reports data on repair and
maintenance issues for clothes dryers
during the first 4 years of ownership.
DOE estimated that on average 1.5
percent of electric and 1.75 percent of
gas clothes dryers are maintained or
repaired each year. Based on RS Means
Facilities Maintenance & Repair 2010
Cost Data,49 DOE also estimated that an
average service call and any necessary
repair or maintenance takes about 2.5
hours. DOE further estimated that the
average material cost is equal to one-half
of the equipment cost. The values for
cost per service call were then
annualized by multiplying by the
frequencies and dividing by the average
equipment lifetime of 16 years.
For room air conditioners, based on
data on repair frequencies for central air
conditioners, DOE assumed that repair
frequencies are low and increase for the
higher-capacity units due to their more
expensive equipment cost. DOE
assumed that 1 percent of small sized
units (below 6,000 Btu/hr), 2.5 percent
49 Available at: https://
rsmeans.reedconstructiondata.com/60300.aspx.
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of medium sized units (8,000 to 14,000
Btu/hr), and 5 percent of large sized
units (above 20,000 Btu/hr) are
maintained or repaired each year. Based
on the above-cited RS Means data, DOE
also estimated that an average service
call and any necessary repair or
maintenance takes about 1 hour for
small and medium-sized units and 2
hours for large units. DOE further
estimated that the average material cost
is equal to one-half of the incremental
equipment cost. The values for cost per
service call were then annualized by
multiplying by the frequencies and
dividing by the average equipment
lifetime of 10.5 years.
7. Product Lifetime
Because the lifetime of appliances
varies depending on utilization and
other factors, DOE develops a
distribution of lifetimes from which
specific values are assigned to the
appliances in the samples. In the
preliminary analysis, DOE conducted an
analysis of actual lifetime in the field
using a combination of shipments data,
the stock of the considered appliances,
and responses in RECS on the age of the
appliances in the homes. The data
allowed DOE to estimate a survival
function, which provides a distribution
of lifetimes. This analysis yielded an
average lifetime of approximately 16
years for clothes dryers and
approximately 10.5 years for room air
conditioners.
For clothes dryers, the ECOS report
(prepared for NRDC) stated that the
typical lifetime of a clothes dryer is
about 12 years. (NRDC, No. 30 at p. 8)
AHAM stated that DOE should modify
average clothes dryer lifetime to 13
years because both Appliance Magazine
and confidential industry data support
that value. (AHAM, No. 25 at p. 11)
Whirlpool stated that Appliance
Magazine shows 12 years as the
expected lifetime for clothes dryers,
which is largely consistent with their
internal estimates. (Whirlpool, No. 22 at
p. 5)
For the final rule analysis, DOE
retained the approach used to estimate
clothes dryer lifetime in the preliminary
analysis because it relies on field data,
and because the sources used by
Appliance Magazine and the
confidential industry data were
unavailable for analysis by DOE.
For room air conditioners, AHAM
stated that the average lifetime of 10.5
years from the preliminary analysis
appears reasonable, and is consistent
with the value of 10 years reported by
Appliance Magazine. (AHAM, No. 25 at
p. 11) AHAM stated, however, that there
could be a very large difference in room
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air conditioner lifetime between product
classes. (AHAM, Public Meeting
Transcript, No. 21.4 at p. 126) While
DOE acknowledges that there may be
differences in room air conditioner
lifetime among the product classes, DOE
continued to use the same lifetime
distribution for all room air conditioner
product classes because it is not aware
of any data that would provide a basis
for using different lifetimes.
See chapter 8 of the direct final rule
TSD for further details on the method
and sources DOE used to develop
product lifetimes.
8. Discount Rates
In the calculation of LCC, DOE
applies discount rates to estimate the
present value of future operating costs.
DOE estimated a distribution of
residential discount rates for clothes
dryers and room air conditioners, and
also estimated a distribution of
commercial discount rates for
commercial users of room air
conditioners. See chapter 8 in the direct
final rule TSD for further details on the
development of consumer discount
rates.
a. Residential Discount Rates
In its preliminary analysis, to
establish residential discount rates for
the LCC analysis, DOE identified all
debt or asset classes that might be used
to purchase refrigeration products,
including household assets that might
be affected indirectly. It estimated the
average percentage shares of the various
debt or asset classes for the average U.S.
household using data from the Federal
Reserve Board’s ‘‘Survey of Consumer
Finances’’ (SCF) for 1989, 1992, 1995,
1998, 2001, 2004, and 2007. Using the
SCF and other sources, DOE then
developed a distribution of rates for
each type of debt and asset 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, weighted by
the shares of each class, is 5.1 percent.
DOE used the same approach for today’s
final rule.
b. Commercial Discount Rates
In its preliminary analysis, DOE
derived discount rates for commercialsector customers from the cost of capital
of publicly-traded firms in the sectors
that purchase room air conditioners.
The firms typically finance equipment
purchases through debt, equity capital,
or both. DOE estimated the cost of the
firms’ capital as the weighted average of
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based on historical trends of penetration
of ENERGY STAR models. DOE believes
that this data support a constant growth
rate of energy efficiency of 0.25 percent
per year. For further information on
DOE’s estimate of base-case efficiency
distributions, see chapter 8 of the direct
final rule TSD.
9. Compliance Date of Amended
Standards
DOE is required by consent decree to
publish a final rule establishing any
amended energy conservation standards
by June 30, 2011. In the absence of any
adverse comment on today’s direct final
rule that may provide a reasonable basis
for withdrawing the rule, compliance
with amended standards for clothes
dryers and room air conditioners will be
required on April 21, 2014. DOE
calculated the LCC and PBP for clothes
dryers and room air conditioners as if
consumers would purchase new
products in the year compliance with
the standard is required. If adverse
comment that may provide a reasonable
basis for withdrawing the rule is
received, DOE will proceed with the
NOPR published elsewhere in today’s
Federal Register, and compliance with
any amended standards would be
required 3 years after the date of
publication of any final standards. As
noted above, DOE is required by consent
decree to publish a final rule
establishing any amended standards by
June 30, 2011.
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the cost of equity financing and the cost
of debt financing for recent years for
which data were available (2001
through 2008). The estimated average
discount rate for companies that
purchase room air conditioners is 5.7
percent. DOE used the same approach
for today’s final rule.
11. Inputs To Payback Period Analysis
The payback period is the amount of
time it takes the consumer to recover the
additional installed cost of more
efficient products, compared to baseline
products, through energy cost savings.
The simple payback period does not
account for changes in operating
expense over time or the time value of
money. Payback periods are expressed
in years. 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 are
the total installed cost of the equipment
to the customer for each efficiency level
and the average annual operating
expenditures for each efficiency level.
The PBP calculation uses the same
inputs as the LCC analysis, except that
discount rates are not used.
10. Base Case Efficiency Distribution
To accurately estimate the share of
consumers that would be affected by a
standard at a particular efficiency level,
DOE’s LCC analysis considered the
projected distribution of product
efficiencies that consumers purchase
under the base case (that is, the case
without new energy efficiency
standards). DOE refers to this
distribution of product of efficiencies as
a base-case efficiency distribution.
In the preliminary analysis, DOE
primarily relied on data submitted by
AHAM to estimate the efficiency
distributions in recent years for each of
the product classes that were analyzed
in the LCC and PBP analysis. DOE
assumed that these market shares would
remain constant through 2014.
Whirlpool supported DOE’s approach to
forecast base-case market shares.
(Whirlpool, No. 22 at p. 5)
For the final rule analysis, DOE
retained the approach used in the
preliminary analysis for clothes dryers.
For room air conditioners, however,
DOE modified its approach for
estimating base-case efficiency
distributions for the final rule analysis
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12. Rebuttable-Presumption Payback
Period
As noted above, EPCA, as amended,
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
(and, as applicable, water) savings
during the first year that the consumer
will receive as a result of the standard,
as calculated under the test procedure
in place for that standard. (42 U.S.C.
6295(o)(2)(B)(iii)) For each considered
efficiency level, DOE determined the
value of the first year’s energy savings
by calculating the quantity of those
savings in accordance with the
applicable DOE test procedure, and
multiplying that amount by the average
energy price forecast for the year in
which compliance with the amended
standard would be required. The results
of the rebuttable payback period
analysis are summarized in section
V.B.1.c of this notice.
G. National Impact Analysis—National
Energy Savings and Net Present Value
Analysis
The NIA assesses the national energy
savings (NES) and the NPV of total
consumer costs and savings that would
be expected to result from new or
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amended standards at specific efficiency
levels. (‘‘Consumer’’ in this context
refers to consumers of the product being
regulated.) DOE calculates the NES and
NPV based on projections of annual
appliance shipments, along with the
annual energy consumption and total
installed cost data from the energy use
and LCC analyses. For the final rule
analysis, DOE forecasted the energy
savings, operating cost savings, product
costs, and NPV of consumer benefits for
products sold from 2014 through 2043.
DOE evaluates the impacts of new and
amended standards by comparing basecase projections with standards-case
projections. The base-case projections
characterize energy use and consumer
costs for each product class in the
absence of new or amended energy
conservation standards. DOE compares
these projections with projections
characterizing the market for each
product class if DOE adopted new or
amended standards at specific energy
efficiency levels (that is, the TSLs or
standards cases) for that class. For the
base case forecast, DOE considers
historical trends in efficiency and
various forces that are likely to affect the
mix of efficiencies over time. For the
standards cases, DOE also considers
how a given standard would likely
affect the market shares of efficiencies
greater than the standard.
DOE uses an MS Excel spreadsheet
model to calculate the energy savings
and the national consumer costs and
savings from each TSL. The direct final
rule TSD and other documentation that
DOE provides during the rulemaking
help explain the models and how to use
them, and interested parties can review
DOE’s analyses by changing various
input quantities within the spreadsheet.
The NIA spreadsheet model uses typical
values as inputs (as opposed to
probability distributions).
For the current analysis, the NIA used
projections of energy prices and housing
starts from the AEO2010 Reference case.
In addition, DOE analyzed scenarios
that used inputs from the AEO2010 Low
Economic Growth and High Economic
Growth cases. These cases have higher
and lower energy price trends compared
to the Reference case, as well as higher
and lower housing starts, which result
in higher and lower appliance
shipments to new homes. NIA results
based on these cases are presented in
appendix 10–A of the direct final rule
TSD.
Table IV–32 summarizes the inputs
and key assumptions DOE used for the
NIA analysis for the preliminary
analysis and the changes to the analyses
for the direct final rule. Discussion of
these inputs and changes follows the
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table. See chapter 10 of the direct final
rule TSD for further details.
TABLE IV.32—SUMMARY OF INPUTS AND KEY ASSUMPTIONS FOR THE NATIONAL IMPACT ANALYSIS
Inputs
Preliminary TSD
Changes for the proposed rule
Shipments ...........................................................
Compliance Date of Standard ............................
Base-Case Forecasted Efficiencies ...................
Annual shipments from shipments model .......
2014 .................................................................
For clothes dryers and room air conditioners,
efficiency distributions are maintained unchanged during the forecast period.
Standards-Case Forecasted Efficiencies ...........
For clothes dryers and air conditioners, used
a ‘‘roll-up’’ scenario.
Annual Energy Consumption per Unit ................
Annual weighted-average values as a function
of CEF * (clothes dryers) and SWCEER * *
(room air conditioners).
Annual weighted-average values as a function
of CEF * (clothes dryers) and SWCEER * *
(room air conditioners).
Annual weighted-average values as a function
of the annual energy consumption per unit
and energy prices.
Annual values as a function of efficiency level
AEO2009 forecasts (to 2035) and extrapolation through 2043.
Varies yearly and is generated by NEMS–BT
Three and seven percent real .........................
Future expenses discounted to 2011, when
the final rule is published.
No change in approach.
No change.
For clothes dryers, no change in basic approach; modified efficiency distributions
based on new information. For room air
conditioners, used an efficiency trend based
on historical market data.
For clothes dryers, no change in basic approach; modified efficiency distributions
based on new information. For room air
conditioners, used a ‘‘roll-up + shift’’ scenario to establish the distribution of efficiencies.
No change.
Total Installed Cost per Unit ...............................
Annual Energy Cost per Unit .............................
Repair and Maintenance Cost per Unit ..............
Energy Prices .....................................................
Energy Site-to-Source Conversion Factor .........
Discount Rate .....................................................
Present Year ......................................................
No change.
No change.
No change.
Updated using AEO2010 forecasts.
No change.
No change.
No change.
* Combined Energy Factor
* * Shipments-Weighted (stand by) Combined Energy Efficiency Ratio.
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1. Shipments
Forecasts of product shipments are
needed to calculate the national impacts
of standards on energy use, NPV, and
future manufacturer cash flows. DOE
develops shipment forecasts based on
an analysis of key market drivers for
each considered product. In DOE’s
shipments model, shipments of
products are driven by new
construction, stock replacements, and
other types of purchases. The shipments
models take an accounting approach,
tracking market shares of each product
class and the vintage of units in the
existing 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. DOE also
considers the impacts on shipments
from changes in product purchase price
and operating cost associated with
higher energy efficiency levels.
Commenting on the preliminary
analysis, Whirlpool stated that clothes
dryer base case shipments will not grow
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linearly as DOE assumes. Clothes dryers
are a highly saturated product today,
and homes without dryers are generally
multi-family units that lack sufficient
space for these products. Whirlpool
stated that saturation of clothes dryers
will not change. Hence, growth in this
product category cannot exceed the
growth of the housing stock. (Whirlpool,
No. 22 at p. 7)
For the final rule analysis, DOE
reviewed its approach for forecasting
dryer purchases for first-time owners,
which include consumers that currently
do not have a dryer and consumers in
new homes who purchase a dryer. To
better account for constraints on
purchase, such as those mentioned by
Whirlpool, DOE reduced its estimate of
the number of purchases by first-time
owners. As a result, its forecast for the
final rule analysis shows shipments
growing more slowly over the forecast
period (an average of 0.8 percent per
year) than in the forecast in the
preliminary analysis. The average
growth rate of 0.8 percent is slightly less
than the average annual growth rate in
the number of households projected in
AEO2010 (1.0 percent in 2008–2035).
To estimate the effects on product
shipments from increases in product
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price projected to accompany amended
standards at higher efficiency levels,
DOE applied a price elasticity
parameter. It estimated this parameter
with a regression analysis that used
purchase price and efficiency data
specific to residential refrigerators,
clothes washers, and dishwashers over
the period 1980–2002. The estimated
‘‘relative price elasticity’’ incorporates
the impacts from purchase price,
operating cost, and household income,
and it also declines over time. DOE
estimated shipments in each standards
case using the relative price elasticity
along with the change in the relative
price between a standards case and the
base case.
For details on the shipments analysis,
see chapter 9 of the direct final rule
TSD.
2. Forecasted Efficiency in the Base Case
and Standards Cases
A key component of the NIA is the
trend in energy efficiency forecasted for
the base case (without new or amended
standards) and each of the standards
cases. Section IV.F.10 described how
DOE developed a base-case energy
efficiency distribution (which yields a
shipment-weighted average efficiency)
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for each of the considered product
classes for the first year of the forecast
period. To project the trend in efficiency
over the entire forecast period, DOE
considered recent trends and programs
such as ENERGY STAR. For clothes
dryers, DOE assumed no improvement
of energy efficiency in the base case and
held the base-case energy efficiency
distribution constant throughout the
forecast period. For room air
conditioners, DOE applied a constant
growth rate of energy efficiency of 0.25
percent per year, based on historical
trends of penetration of ENERGY STAR
products.
To estimate efficiency trends in the
standards cases, DOE has used ‘‘roll-up’’
and/or ‘‘shift’’ scenarios in its standards
rulemakings. Under the roll-up scenario,
DOE assumes: (1) Product efficiencies in
the base case that do not meet the
standard level under consideration
would roll-up to meet the new standard
level; and (2) product efficiencies above
the standard level under consideration
would not be affected. Under the shift
scenario, DOE re-orients the distribution
above the new minimum energy
conservation standard.
In the preliminary analysis, DOE used
a roll-up scenario in developing its
forecasts of efficiency trends in the
standards cases. The California Utilities
stated that DOE should consider a ‘‘rollup and market shift’’ scenario for room
air conditioners in standards cases
because, if the ENERGY STAR level is
revised above the new standard, it may
create a market incentive that increases
the share of higher efficiency products.
(California Utilities, No. 31 at p. 19)
DOE agrees that amended standards
for room air conditioners would likely
result in changes to ENERGY STAR
levels that would increase the share of
products with energy efficiency above
the standard based on the historical data
reviewed for room air conditioners.
Therefore, for the final rule analysis,
DOE applied a ‘‘roll-up and shift’’
scenario that accounts for such increase
in share. For clothes dryers, DOE
retained the approach used in the
preliminary analysis for the final rule.
For further details about the forecasted
efficiency distributions, see chapter 10
of the direct final rule TSD.
3. National Energy Savings
For each year in the forecast period,
DOE calculates the NES for each
standard level by multiplying the stock
of equipment affected by the energy
conservation standards by the per-unit
annual energy savings. As discussed in
section IV.E, DOE incorporated the
rebound effect utilized in the energy use
analysis into its calculation of national
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energy savings for room air
conditioners.
To estimate the national energy
savings expected from appliance
standards, DOE uses a multiplicative
factor to convert site energy
consumption (at the home or
commercial building) into primary or
source energy consumption (the energy
required to convert and deliver the site
energy). These conversion factors
account for the energy used at power
plants to generate electricity and losses
in transmission and distribution, as well
as for natural gas losses from pipeline
leakage and energy used for pumping.
For electricity, the conversion factors
vary over time due to projected changes
in generation sources (that is, the power
plant types projected to provide
electricity to the country). The factors
that DOE developed are marginal
values, which represent the response of
the system to an incremental decrease in
consumption associated with appliance
standards.
In the preliminary analysis, DOE used
annual site-to-source conversion factors
based on the version of NEMS that
corresponds to AEO2009. For today’s
rule, DOE updated its conversion factors
based on the NEMS that corresponds to
AEO2010, which provides energy
forecasts through 2035. For 2036–2043,
DOE used conversion factors that
remain constant at the 2035 values.
Section 1802 of the Energy Policy Act
of 2005 (EPACT 2005) directed DOE to
contract a study with the National
Academy of Science (NAS) to examine
whether the goals of energy efficiency
standards are best served by
measurement of energy consumed, and
efficiency improvements, at the actual
point-of-use or through the use of the
full-fuel-cycle, beginning at the source
of energy production. (Pub. L. 109–58
(August 8, 2005)). NAS appointed a
committee on ‘‘Point-of-Use and FullFuel-Cycle Measurement Approaches to
Energy Efficiency Standards’’ to conduct
the study, which was completed in May
2009. The NAS committee defined fullfuel-cycle energy consumption as
including, in addition to site energy use,
the following: energy consumed in the
extraction, processing, and transport of
primary fuels such as coal, oil, and
natural gas; energy losses in thermal
combustion in power generation plants;
and energy losses in transmission and
distribution to homes and commercial
buildings.50
50 The National Academies, Board on Energy and
Environmental Systems, Letter to Dr. John Mizroch,
Acting Assistant Secretary, U.S. DOE, Office of
EERE from James W. Dally, Chair, Committee on
Point-of-Use and Full-Fuel-Cycle Measurement
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22517
In evaluating the merits of using
point-of-use and full-fuel-cycle
measures, the NAS committee noted
that DOE uses what the committee
referred to as ‘‘extended site’’ energy
consumption to assess the impact of
energy use on the economy, energy
security, and environmental quality.
The extended site measure of energy
consumption includes the energy
consumed during the generation,
transmission, and distribution of
electricity but, unlike the full-fuel-cycle
measure, does not include the energy
consumed in extracting, processing, and
transporting primary fuels. A majority of
the NAS committee concluded that
extended site energy consumption
understates the total energy consumed
to make an appliance operational at the
site. As a result, the NAS committee
recommended that DOE consider
shifting its analytical approach over
time to use a full-fuel-cycle measure of
energy consumption when assessing
national and environmental impacts,
especially with respect to the
calculation of greenhouse gas emissions.
The NAS committee also recommended
that DOE provide more comprehensive
information to the public through labels
and other means, such as an enhanced
Web site. For those appliances that use
multiple fuels (such as water heaters),
the NAS committee indicated that
measuring full-fuel-cycle energy
consumption would provide a more
complete picture of energy consumed
and permit comparisons across many
different appliances, as well as an
improved assessment of impacts.
In response to the NAS committee
recommendations, DOE issued, on
August 20, 2010 a Notice of Proposed
Policy proposing to incorporate a fullfuel cycle analysis into the methods it
uses to estimate the likely impacts of
energy conservation standards on
energy use and emissions. FR 75 51423.
Specifically, DOE proposed to use fullfuel-cycle (FFC) measures of energy and
greenhouse gas (GHG) emissions, rather
than the primary (extended site) energy
measures it currently uses.
Additionally, DOE proposed to work
collaboratively with the Federal Trade
Commission (FTC) to make FFC energy
and GHG emissions data available to the
public to enable consumers to make
cross-class comparisons. On October
7th, DOE held an informal public
meeting to discuss and receive
comments on its planned approach. The
Notice, a transcript of the public
meeting and all public comments
received by DOE are available at:
Approaches to Energy Efficiency Standards, May
15, 2009.
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https://www.regulations.gov/search/
Regs/home.html#docketDetail?R=EERE2010-BT-NOA-0028. DOE intends to
develop a final policy statement on
these subjects and then take steps to
begin implementing that policy in
future rulemakings and other activities.
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4. Net Present Value of Consumer
Benefit
The inputs for determining the NPV
of the total costs and benefits
experienced by consumers of the
considered appliances are: (1) Total
annual installed cost, (2) total annual
savings in operating costs, and (3) a
discount factor. DOE calculates net
savings each year as the difference
between the base case and each
standards case in total savings in
operating costs and total increases in
installed costs. DOE calculates operating
cost savings over the life of each
product shipped in the forecast period.
DOE multiplies the net savings in
future years by a discount factor to
determine their present value. For the
preliminary analysis and today’s final
rule, DOE estimated the NPV of
appliance 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.51 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 ‘‘societal rate of time
preference,’’ which is the rate at which
society discounts future consumption
flows to their present value.
As noted above, DOE is accounting for
the rebound effect associated with more
efficient room air conditioners in its
determination of national energy
savings. The take-back in energy
consumption associated with the
rebound effect provides consumers with
increased value (that is, a cooler or
warmer indoor environment). The net
impact on consumers is thus the sum of
the change in the cost of owning the
room air conditioner (that is, life-cycle
cost) and the increased value for the
more comfortable indoor environment.
The consumer effectively pays for the
increased value of a more comfortable
environment in his or her utility bill.
Because the monetary cost of this added
value is equivalent to the value of the
foregone energy savings, the economic
51 OMB
Circular A–4 (Sept. 17, 2003), section E,
‘‘Identifying and Measuring Benefits and Costs.
Available at: https://www.whitehouse.gov/omb/
memoranda/m03-21.html.
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impacts on consumers, as measured in
the NPV are the same regardless of the
rebound effect.
5. Benefits From Effects of Standards on
Energy Prices
Reduction in electricity consumption
associated with amended standards for
clothes dryers and room air conditioners
could reduce the electricity prices
charged to consumers in all sectors of
the economy and thereby reduce their
electricity expenditures. In chapter 2 of
the preliminary TSD, DOE explained
that, because the power industry is a
complex mix of fuel and equipment
suppliers, electricity producers and
distributors, it did not plan to estimate
the value of potentially reduced
electricity costs for all consumers
associated with amended standards for
refrigeration products. In response,
NEEP urged DOE to quantify electricity
demand reductions achieved by these
updated standards in financial terms.
(NEEP, No. 27 at p. 1)
For this rule, DOE used NEMS–BT to
assess the impacts of the reduced need
for new electric power plants and
infrastructure projected to result from
standards. In NEMS–BT, changes in
power generation infrastructure affect
utility revenue requirements, which in
turn affect electricity prices. DOE
estimated the impact on electricity
prices associated with each considered
TSL. Although the aggregate benefits for
electricity users are potentially large,
there may be negative effects on some of
the actors involved in electricity supply,
particularly power plant providers and
fuel suppliers. Because there is
uncertainty about the extent to which
the benefits for electricity users from
reduced electricity prices would be a
transfer from actors involved in
electricity supply to electricity
consumers, DOE has concluded that, at
present, it should not give a heavy
weight to this factor in its consideration
of the economic justification of new or
amended standards. DOE is continuing
to investigate the extent to which
electricity price changes projected to
result from standards represent a net
gain to society.
H. Consumer Subgroup Analysis
In analyzing the potential impact of
new or amended standards on
consumers, DOE evaluates the impact
on identifiable subgroups of consumers
(such as low-income households) that
may be disproportionately affected by a
national standard. DOE evaluates
impacts on particular subgroups of
consumers primarily by analyzing the
LCC impacts and PBP for those
particular consumers from alternative
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standard levels. For this rule, DOE
analyzed the impacts of the considered
standard levels on low-income
consumers and senior citizens. Section
V.B.1.b summarizes the results of the
consumer subgroup analysis, and
chapter 11 in the direct final rule TSD
describes the analysis method.
I. Manufacturer Impact Analysis
The following sections address the
various steps taken to analyze the
impacts of the amended standards on
manufacturers. These steps include
conducting a series of analyses,
interviewing manufacturers, and
evaluating the comments received from
interested parties during this
rulemaking.
1. Overview
In determining whether an amended
energy conservation standard for
residential clothes dryers and room air
conditioners subject to this rulemaking
is economically justified, DOE is
required to consider ‘‘the economic
impact of the standard on the
manufacturers and on the consumers of
the products subject to such standard.’’
(42 U.S.C. 6295(o)(2)(B)(i)(I)) The statute
also calls for an assessment of the
impact of any lessening of competition
as determined by the Attorney General
that is likely to result from the adoption
of a standard. (42 U.S.C.
6295(o)(2)(B)(i)(V)) DOE conducted the
MIA to estimate the financial impact of
amended energy conservation standards
on manufacturers of clothes dryers and
room air conditioners, and to assess the
impacts of such standards on
employment and manufacturing
capacity.
The MIA is both a quantitative and
qualitative analysis. The quantitative
part of the MIA relies on the
Government Regulatory Impact Model
(GRIM), an industry cash-flow model
customized for the clothes dryer and
room air conditioners covered in this
rulemaking. See section IV.I.2 below, for
details on the GRIM analysis. The
qualitative part of the MIA addresses
factors such as product characteristics,
characteristics of particular firms, and
market trends. The qualitative
discussion also includes an assessment
of the impacts of standards on
manufacturer subgroups. The complete
MIA is discussed in chapter 12 of the
direct final rule TSD. DOE conducted
the MIA in the three phases described
below.
a. Phase 1, Industry Profile
In Phase 1 of the MIA, DOE prepared
a profile of the clothes dryers and room
air conditioner industries based on the
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market and technology assessment
prepared for this rulemaking. Before
initiating the detailed impact studies,
DOE collected information on the
present and past structure and market
characteristics of each industry. This
information included market share data,
product shipments, manufacturer
markups, and the cost structure for
various manufacturers. The industry
profile includes: (1) Further detail on
the overall market and product
characteristics; (2) estimated
manufacturer market shares;
(3) financial parameters such as net
plant, property, and equipment; selling,
general and administrative (SG&A)
expenses; cost of goods sold, and other
similar information; and (4) trends in
the number of firms, market, and
product characteristics. The industry
profile included a top-down cost
analysis of manufacturers in each
industry that DOE used to derive
preliminary financial inputs for the
GRIM (such as revenues, depreciation,
SG&A, and research and development
(R&D) expenses). DOE also used public
sources of information to further
calibrate its initial characterization of
each industry, including Security and
Exchange Commission 10–K filings,52
Standard & Poor’s stock reports,53 and
corporate annual reports. DOE
supplemented this public information
with data released by privately held
companies.
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b. Phase 2, Industry Cash Flow Analysis
Phase 2 focused on the financial
impacts of potential amended energy
conservation standards on each industry
as a whole. Amended energy
conservation standards can affect
manufacturer cash flows in three
distinct ways: (1) By creating a need for
increased investment, (2) by raising
production costs per unit, and (3) by
altering revenue due to higher per-unit
prices and/or possible changes in sales
volumes. DOE used the GRIMs to
perform two cash-flow analyses: One for
the clothes dryers industry and one for
room air conditioners. In performing
these analyses, DOE used the financial
values derived during Phase 1 and the
shipment assumptions from the NIA.
c. Phase 3, Sub-Group Impact Analysis
Using average cost assumptions to
develop an industry-cash-flow estimate
may not adequately assess differential
impacts of amended energy
conservation standards among
manufacturer subgroups. For example,
52 Available
online at https://www.sec.gov.
online at https://
www2.standardandpoors.com.
53 Available
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small manufacturers, niche players, or
manufacturers exhibiting a cost
structure that differs significantly from
the industry average could be more
negatively affected. To address this
possible impact, DOE used the results of
the industry characterization analysis in
Phase 1 to group manufacturers that
exhibit similar production and cost
structure characteristics. During the
manufacturer interviews, DOE
discussed financial topics specific to
each manufacturer and obtained each
manufacturer’s view of the industry as
a whole.
DOE reports the MIA impacts of
amended energy conservation standards
by grouping together the impacts on
manufacturers of certain product
classes. While DOE did not identify any
other subgroup of manufacturers of
clothes dryers or room air conditioners
that would warrant a separate analysis,
DOE specifically investigated impacts
on small business manufacturers. See
section VI.B for more information.
2. GRIM Analysis
DOE uses the GRIM to quantify the
changes in cash flow that result in a
higher or lower industry value. The
GRIM analysis is a standard, annual
cash-flow analysis that incorporates
manufacturer costs, manufacturer
selling prices, shipments, and industry
financial information as inputs, and
models changes in costs, distribution of
shipments, investments, and
manufacturer margins that would result
from amended energy conservation
standards. The GRIM spreadsheet uses
the inputs to arrive at a series of annual
cash flows, beginning with the base year
of the analysis, 2011 (which accounts
for the investments needed to bring
products into compliance by 2014), and
continuing to 2043. DOE calculated
INPVs by summing the stream of annual
discounted cash flows during this
period. For clothes dryers and room air
conditioners, DOE uses a real discount
rate of 7.2 percent for all products.
DOE used the GRIM to calculate cash
flows using standard accounting
principles and to compare changes in
INPV between a base case and various
TSLs (the standards cases). The
difference in INPV between the base and
standards cases represents the financial
impact of the amended standard on
manufacturers. DOE collected this
information from a number of sources,
including publicly available data and
interviews with a number of
manufacturers (described in the next
section). Additional details about the
GRIM can be found in chapter 12 of the
direct final rule TSD.
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a. GRIM Key Inputs
Manufacturer Production Costs
DOE used the manufacturer
production costs (MPCs) calculated in
the engineering analysis for each
efficiency level for the year 2009, as
described in section IV.C above, and
further detailed in chapter 5 of the
direct final rule TSD. For both clothes
dryers and room air conditioners, DOE
calculated the 2009 MPCs using cost
models based on product tear downs.
The cost models also provide a
breakdown of MPCs into material, labor,
overhead, and depreciation.
Manufacturing a higher-efficiency
product is typically more expensive
than manufacturing a baseline product
due to the use of more complex
components and higher-cost raw
materials. The changes in the MPCs of
the analyzed products can affect
revenues, gross margins, and cash flow
of the industry, making these product
cost data key GRIM inputs for DOE’s
analysis.
Base-Case Shipments Forecast
The GRIM estimates manufacturer
revenues based on total unit shipment
forecasts and the distribution of these
values by efficiency level. Changes in
the efficiency mix at each standard level
affect manufacturer finances. For this
analysis, the GRIM uses the NIA
shipments forecasts from 2011 to 2043,
the end of the analysis period.
In the shipments analysis, DOE also
estimated the distribution of efficiencies
in the base case for all product classes.
For clothes dryers, DOE held the basecase energy efficiency distribution
constant throughout the forecast period.
For the room air conditioner industry,
DOE assumed a migration of the market
toward higher efficiency over time. See
section IV.G.1, above, for additional
details.
Product and Capital Conversion Costs
Amended energy conservation
standards will cause manufacturers to
incur conversion costs to bring their
production facilities and product
designs into compliance. For the MIA,
DOE classified these costs into two
major groups: (1) Product conversion
costs and (2) capital conversion costs.
Product conversion costs are
investments in research, development,
testing, marketing, and other noncapitalized costs focused on making
product designs comply with the
amended energy conservation standard.
Capital conversion costs are investments
in property, plant, and equipment to
adapt or change existing production
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facilities so that new product designs
can be fabricated and assembled.
For both clothes dryers and room air
conditioners, DOE based its conversion
cost estimates that would be required to
meet each TSL on information obtained
from manufacturer interviews, the
design pathways analyzed in the
engineering analysis, and market
information about the number of
products that would require
modification at each efficiency level.
Because no energy label is currently
prescribed for clothes dryers, and
because clothes dryers are not part of
the ENERGY STAR program, the best
source of clothes dryer efficiency
information is the CEC product
database. DOE segmented each product
on the CEC Web site into its appropriate
product class using energy source, drum
capacity, voltage, and combination unit
information. DOE then searched
manufacturer Web sites and numerous
retail Web sites to determine which
clothes dryers were current products.
DOE assigned each product currently
produced into efficiency levels using
the reported energy factor. Finally, DOE
assigned each of these products into
product lines, classifying each group of
products made by same manufacturer
with identical drum capacities and
energy factors into the same product
line.
DOE calculated the product and
capital conversion costs at each
efficiency level for every product class
by multiplying the total number of
product lines that fell below the
required efficiency by an estimate of the
conversion costs to reach that efficiency
level. DOE calculated the total product
development required at each efficiency
level by estimating the necessary
engineering resources required to
implement the design options in the
engineering analysis at the efficiency
level across a product line. DOE
calculated the total capital conversion
costs required at each efficiency level by
estimating the additional equipment
and changes to existing equipment that
would be required to implement the
design option in the engineering
analysis at that efficiency level across a
product line.
While DOE’s calculation of
conversion costs for room air
conditioners was similar to the
calculation of conversion costs for
clothes dryers, DOE used a slightly
different approach to determine the
number of product lines at each
efficiency level. DOE used the CEC
appliance database to determine what
models currently exist on the market for
room air conditioners and verified these
current products through manufacturer
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and retail Web sites. DOE eliminated
products in the database that were
discontinued due to the recent
refrigerant switch to R–410A. DOE
segmented each product from the CEC
database into its appropriate product
class using cooling capacity, the
existence of louvers, and type of room
air conditioner. DOE assigned each
product currently produced into
efficiency levels using the reported EER.
Finally, DOE determined a
representative distribution of the
industry by extrapolating the
information for manufacturers for which
it had complete efficiency information
to account for the product lines of all
manufacturers.
Like its method for clothes dryers,
DOE calculated the industry wide
conversion costs by multiplying the
number of product lines in each product
class that fell below the required
efficiency by its estimate of the product
and capital conversion costs. DOE’s
estimate was based on the design
options at each efficiency level in the
engineering analysis. DOE’s per line
product conversion costs were
calculated by estimating the product
development time required to make the
design change across a product family.
For component switch outs, DOE
assumed that design changes for
components that interacted with other
parts of the room air conditioner would
be more costly than one-for-one switch
outs because these components would
require greater engineering effort to be
adapted into new product designs. For
capital conversion costs, DOE assumed
based on manufacturer feedback that the
only design changes that would require
changes to existing equipment were
larger chassis volumes, evaporator
changes, and condenser changes.
DOE’s estimates of the total capital
conversion and production conversion
costs for clothes dryer and room air
conditioners by TSL can be found in
section V.B.2 of today’s direct final rule.
The estimates of the total capital
conversion and product conversion
costs by product class and efficiency
level can be found in chapter 12 of the
direct final rule TSD.
b. GRIM Scenarios
Clothes Dryer Standards-Case Shipment
Forecasts
The GRIM used the shipments
developed in the NIA for clothes dryers.
To determine efficiency distributions for
the standards case, DOE used a roll-up
scenario. In this scenario, products that
fall below the amended energy
conservation standard are assumed to
‘‘roll-up’’ to the new standard in 2014.
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DOE also assumed there was a relative
price elasticity in the clothes dryers
market, meaning amended energy
conservation standards that increase the
first cost of clothes dryers would result
in lower total shipments. See section
IV.G.1 of this direct final rule, and
chapter 10 of the direct final rule TSD
for more information on the clothes
dryer standards-case shipment
scenarios.
Room Air Conditioner Standards-Case
Shipment Forecasts
The GRIM used the shipments
developed in the NIA for room air
conditioners. As stated in IV.I.2.a, the
base case shipments assume that there
is a migration over time to more
efficient products based on historical
trends of penetration of ENERGY STAR
products. In the standards case, DOE
used a ‘‘roll-up + shift’’ scenario. In this
scenario, DOE assumed that amended
standards for room air conditioners
would likely result in changes to
ENERGY STAR levels that would
increase the share of products with
energy efficiency above the standard.
DOE also assumed there was a relative
price elasticity in the room air
conditioner market, meaning that
amended energy conservation standards
that increase the first cost of room air
conditioners would result in lower total
shipments. See section IV.G.1 of this
direct final rule and chapter 10 of the
direct final rule TSD for more
information on the room air conditioner
standards-case shipment scenarios.
Markup Scenarios
In the GRIM, DOE used the MSPs
calculated in the engineering analysis
for each product class and efficiency
level. MSPs include direct
manufacturing production costs (that is,
labor, material, and overhead estimated
in DOE’s MPCs) and all non-production
costs (that is, SG&A, R&D, and interest),
along with profit. For clothes dryers,
DOE did not separate shipping costs
from the manufacturer markup because
shipping costs are not a function of the
design options analyzed. The MSP for
clothes dryers is equal to the MPC times
the manufacturer markup. For room air
conditioners, DOE separated the
shipping costs from the markup
multiplier for the analysis to explicitly
account for the design options that
would result in higher shipping costs
due to weight increases. DOE calculated
the MSP for room air conditioners by
multiplying the MPC by the
manufacturer markup and adding
shipping costs.
For the MIA, DOE modeled two
standards-case markup scenarios to
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represent the uncertainty regarding the
potential impacts on prices and
profitability for manufacturers following
the implementation of amended energy
conservation standards: (1) A flat
markup scenario, and (2) a preservation
of operation profit scenario. Modifying
these markups from the base case to the
standards cases yields different sets of
impacts on manufacturers’ changing
industry revenue and cash flow.
The flat markup scenario assumes that
the cost of goods sold for each product
is marked up by a flat percentage to
cover standard SG&A expenses, R&D
expenses, and profit. The flat markup
scenario uses the baseline manufacturer
markup (discussed in chapter 6 of the
direct final rule TSD) for all products in
both the base case and the standards
case. To derive this percentage, DOE
evaluated publicly available financial
information for manufacturers of major
household appliances whose product
offerings include clothes dryers and
room air conditioners. DOE also
requested feedback on this value during
manufacturer interviews. This scenario
represents the upper bound of industry
profitability in the standards case
because under this scenario,
manufacturers are able to fully pass
through additional costs due to
standards to their customers.
DOE also modeled a lower bound
profitability scenario. In this scenario,
the manufacturer markups are lowered
such that, in the standards case,
manufacturers are able to maintain only
the base-case total operating profit in
absolute dollars, despite higher product
costs and investment. DOE
implemented this scenario in GRIM by
lowering the manufacturer markups at
each TSL to yield approximately the
same earnings before interest and taxes
in the standards case in the year after
the compliance date of the amended
standards as in the base case. For
clothes dryers in the preservation of
operating profit scenario, DOE assumed
that the industry wide impacts would
occur under the new minimum
efficiency levels. DOE altered the
markups only for the minimally
compliant products in this scenario,
with margin impacts not occurring for
products that already exceed the
amended energy conservation standard.
For room air conditioners, DOE
assumed that the margin impacts would
affect the minimally compliant products
at the amended energy conservation
standards and the next highest
efficiency level. The NIA analyzed an
efficiency migration in both the base
case and the standards case due to the
assumption that manufacturers will
produce increasingly more efficient
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room air conditioners as ENERGY STAR
levels for these products change over
time. Therefore, under amended energy
conservation standards the shipment
weighted average efficiency increases
from the new minimum standard to
higher efficiency levels. DOE assumed
this market shift caused by standards
would impact margins on products that
also become the de facto minimally
efficient product over time. For both
clothes dryers and room air
conditioners, the preservation of
operating profit represents the lower
bound of industry profitability
following amended energy conservation
standards because under this scenario,
higher production costs and the
investments required to comply with
the amended energy conservation
standard do not yield additional
operating profit.
While DOE used the same markup
scenarios for clothes dryers and room
air conditioners, DOE captured different
concerns for each industry by modeling
the preservation of operating profit
scenario. For clothes dryers,
manufacturers were particularly
concerned about the inability to markup
the full cost of production. Because
there is currently no energy label
requirement or ENERGY STAR program
for clothes dryers, the lack of consumer
information makes it more difficult for
customers to calculate individual
payback and energy savings.
Consequently, the manufacturing cost
for more efficient clothes dryers could
not be fully marked up because energy
efficiency, unlike price and other
features, is not a factor in the
purchasing decision of most consumers.
Manufacturers also cited the highly
competitive market, the concentrated
retail market that represents the
majority of sales, and price points that
are fixed partly by paired washing
machines as other reasons that
additional production costs would not
yield higher profits in the standards
case. For room air conditioners,
manufacturers stated that higher
production costs could severely harm
profitability. Manufacturers already earn
very little profit on the small, highvolume window units due to the
enormous price pressure retailers exert
because of their purchasing power, and
due to fierce competition within the
room air conditioner industry.
Manufacturers accept lower absolute
profit on these units with the
expectation of making a larger per unit
profit on other more costly products.
They also do so because maintaining
high production volumes of these units
allows manufacturers to keep factories
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utilized and to achieve purchasing
economies. In addition, because many
purchases are impulse buys during
periods of atypically warm weather for
products that are used sparingly, any
increase in first cost could impact these
types of sales. Therefore, manufacturers
were skeptical that customers would
accept the full additional cost of
production.
3. Discussion of Comments
During the March 2010 public
meeting, interested parties commented
on the assumptions and results of the
manufacturer impacts presented in the
preliminary analysis. Oral and written
comments discussed several topics,
including the classification of small
business manufacturers, the cumulative
regulatory burden on manufacturers, the
impact of R–410A conversion, and
direct employment impacts. DOE
addresses these comments below.
a. Small Businesses
In the preliminary analysis, DOE
stated it did not identify any small
business manufacturers of residential
clothes dryers but that it did identify at
least one room air conditioner
manufacturer that was designated as a
small business by the U.S. Small
Business Administration criteria. DOE
requested comment on this assertion.
AHAM stated that it agreed with DOE’s
assessment regarding the number of
small businesses for room air
conditioners and clothes dryers.
(AHAM, No. 25 at p. 12) Whirlpool
similarly stated that it did not know of
any qualifying small businesses for
residential clothes dryers. (Whirlpool,
No. 22 at p. 4) HTC, however, stated that
it is a small business registered under
the Central Contracting Registration and
the appropriate NAICS code for the
residential clothes dryers covered by
this rulemaking (335224—household
laundry equipment manufacturers).
HTC requested consideration by DOE as
a small business and asserted that it
would be negatively impacted if DOE
decided not to include its technologies
in the standards for residential clothes
dryers (HTC, No. FDMS DRAFT 0068 at
pp. 6, 10)
For clothes dryers, DOE notes that it
could not locate HTC as a small
business on the SBA Web site (https://
dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm)
or under the Central Contracting
Registration (https://www.bpn.gov/
CCRSearch/Search.aspx). DOE does not
question HTC’s assertion that it is a
small business, but DOE does not
believe that HTC would be directly
impacted by this rule. HTC has
developed a technology that can be
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incorporated into clothes dryers. DOE
acknowledges in section IV.A.5.a that
HTC’s technology is a potential design
option but also notes this technology is
not commercially available. DOE does
not believe this rulemaking would affect
HTC’s ability to commercialize or sell
its technology. Therefore, DOE does not
believe HTC will be impacted by this
rulemaking.
For room air conditioners, DOE
amends its conclusion of the number of
small manufacturers in today’s direct
final rule. The one manufacturer
previously identified by DOE as a small
business was since acquired by a
company and exceeds the 750-employee
threshold under NAICS code 333415
(air conditioning and warm air heating
equipment manufacturers and
commercial and industrial refrigeration
equipment manufacturers). As such,
DOE believes there are no qualifying
small business manufacturers in the
room air conditioner industry.
For more information on the potential
impact on small business
manufacturers, see section VI.B.
b. Cumulative Regulatory Burden
Several interested parties responded
to DOE’s request for comment during
the preliminary analysis period on
regulations that could impose a burden
on manufacturers of clothes dryers and
room air conditioners. BSH stated that
DOE should consider potential
greenhouse gas regulations and the EPA
ban on hydrochlorofluorocarbon (HCFC)
refrigerants in new products since these
regulations are relevant for heat pump
clothes dryers. (BSH, No. 23 at p. 5) In
contrast, NPCC stated that DOE should
not include the cost of converting to
alternative refrigerants such as R–410A
in its manufacturer impact analysis for
room air conditioners since the HCFC
ban has already taken effect. (NPCC, No.
32 at p. 4)
DOE acknowledges that the phase-out
of hydrofluorocarbons (HFC) or similar
refrigerants could necessitate changes to
heat pump clothes dryers if current
products offered on the market have to
be redesigned. DOE also notes that the
most efficient electric clothes dryers on
the U.S. market today do not use heat
pump technology, so a change in the
available refrigerants would not
currently impact products on the U.S.
market. Because heat pump technology
passed the screening criteria, it is
analyzed as in technology that could
increase the efficiency of residential
clothes dryers. DOE has analyzed heat
pump clothes dryers as the max-tech
units for electric clothes dryer product
classes. In its engineering analysis for
these relevant product classes, DOE
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assumed that these products would
utilize refrigerants that are currently
available on the market. However, DOE
does not include the impacts of a
potential change in available refrigerant
for heat pump clothes dryers because it
would be speculative to predict the
passage of legislation or the outcome of
future rulemakings that would alter
available refrigerants.
In response to the inclusion of the ban
on HCFC refrigerants, DOE notes that
the ban is relevant to both heat pump
clothes dryer manufactures and room air
conditioner manufacturers. The ban on
R–22 became effective on January 1,
2010, so all products currently
produced must comply with this
regulation. This ban, which required
manufacturers to cease using virgin
R–22 in new equipment, necessitated
substantial product design changes and
capital investments. DOE accounts for
these design changes in its engineering
analysis by basing its analysis for room
air conditioners on the use of R–410A
refrigerant, as described in section
IV.C.2.b. This allows DOE to capture the
impacts of the refrigerant change on
product cost and efficiency.
The ban also caused manufacturers to
incur significant product and capital
conversion costs. Manufacturers had to
redesign units for new compressors and
other new components and conduct
extensive testing, and in some cases
manufacturers devoted full-time
engineering resources to this conversion
for up to 2 years. Additionally,
manufacturers had to purchase new heat
exchanger equipment and make other
capital investments. DOE did not
include the costs of converting to
alternative refrigerants in the GRIM
because these changes were not driven
by the standards established in today’s
final rule. DOE describes the HCFC ban
in further detail as part of the
cumulative regulatory burden in chapter
12 of the direct final rule TSD.
Several manufacturers also responded
to DOE’s request for comment on the UL
fire safety regulation for clothes dryers.
Whirlpool stated that this regulation has
no effect on energy efficiency, but added
that DOE should include it as a
regulatory burden. (Whirlpool, No. 22 at
p. 2) BSH noted that the regulation takes
effect in 2013. (BSH, No. 23 at p. 6) ALS
speculated that each clothes dryer
manufacturer will have its own
concerns about this regulation and its
impacts. (ALS, Public Meeting
Transcript, No. 21.4 at p. 154) HTC
stated that it has successfully passed UL
2158 safety guidelines for electric
clothes dryers and requested
consideration of this compliance. (HTC,
No. FDMS DRAFT 0068 at p. 7)
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DOE appreciates this input on the UL
fire safety regulations for clothes dryers.
While DOE did not receive enough
information to calculate the cost of
changes to baseline clothes dryers to
comply with UL 2158 in the engineering
analysis, DOE agrees with Whirlpool
that this regulation would not impact
energy efficiency and consequently
would not change the incremental costs
calculated in the engineering analysis.
While the UL 2158 is not a Federal
regulation, UL certification is a de facto
requirement for selling products in the
U.S. because of local building codes
requiring all installed products meet
safety regulations and to avoid
litigation. DOE included the conversion
costs for manufacturers to comply with
UL 2158 as part of the cumulative
regulatory burden.
Additional information on the
cumulative regulatory burden on clothes
dryer and room air conditioner
manufacturers is included in chapter 12
of the direct final rule TSD, including
details on how DOE treated the
conversion costs for the UL 2158
regulation.
c. Employment Impacts
Two interested parties commented on
DOE’s characterization of the domestic
employment impacts for room air
conditioner manufacturers. EEI stated
that if DOE concluded no room air
conditioner production remains in the
United States, there should be no
domestic impacts on employment. EEI
stated that further analysis may be
necessary to capture impacts on these
manufacturers. (EEI, Public Meeting
Transcript, No. 21.4 at pp. 31–34) To
follow up on this issue, GE stated that
revenue from non-domestic
manufacturing helps fund the R&D and
domestic production of other products
that room air conditioner manufacturers
produce. Therefore, the effects of room
air conditioner manufacturing spill over
into other industries. (GE, Public
Meeting Transcript, No. 21.4 at pp. 33–
34)
DOE’s direct employment impact
assessment focuses on domestic
employment impacts. These
employment impacts are calculated in
the GRIM based on the domestic
expenditures and labor content of room
air conditioner production. Because all
room air conditioners are manufactured
abroad, any change in labor content
resulting from amended standards
would impact labor requirements in
non-domestic facilities and would not
be quantified in DOE’s direct
employment impact assessment. While
many room air conditioner
manufacturers produce other products
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and a company’s revenues in one
industry may impact its overall
revenues and operations, DOE does not
analyze spillover effects among different
business segments in its direct
employment impact assessment. DOE
does analyze indirect employment
impacts in the domestic economy in
section IV.J.
4. Manufacturer Interviews
DOE interviewed manufacturers
representing more than 90 percent of
clothes dryer sales and approximately
50 percent of room air conditioner sales.
These interviews were in addition to
those DOE conducted as part of the
engineering analysis. DOE used these
interviews to tailor the GRIM to
incorporate unique financial
characteristics for each industry. All
interviews provided information that
DOE used to evaluate the impacts of
potential amended energy conservation
standards on manufacturer cash flows,
manufacturing capacities, and
employment levels. See appendix 12–A
of the direct final rule TSD for
additional information on the MIA
interviews.
The following sections describe the
most significant issues identified by
manufacturers.
a. Clothes Dryer Key Issues
Test Procedure
Manufacturers indicated that a key
concern for this rulemaking was
ensuring that the test procedure
accurately measured actual energy use.
In particular, manufacturers indicated
that proposed changes to the RMC value
and the average number of annual
cycles needed to be updated.
Manufacturers indicated that without
these changes, consumers could be
negatively impacted by amended energy
conservation standards because clothes
dryers have a limited number of
improvements that would be cost
effective for most consumers.
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UL Fire Containment Standard
Most manufacturers indicated that
they had not fully investigated the exact
technical changes that will be required
to meet the UL fire containment
regulation (UL 2158). However,
manufacturers were concerned that this
regulation would require changes to all
their products around the same time
that they would be required to meet the
amended energy conservation standard.
Most manufacturers agreed that even if
the exact approach of meeting UL 2158
is different or unknown by individual
manufactures, DOE should still treat the
regulation as an overall burden.
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Heat Pump Technology
Manufacturers indicated that the high
capital conversion and product
conversion costs for clothes dryers at
the second gap fill levels or the
maximum available units were
significant and would represent a
substantial burden. Manufacturers also
indicated that the pathways to meeting
those levels, while potentially costly,
were well-defined, proven in the
market, and could be made within their
existing production facilities.
Manufacturers also indicated, however,
that heat pump technology at the maxtech levels for electric product classes
would represent a significant departure
from current products and add
significantly to the product and capital
conversion costs. A heat pump standard
would require a total renovation of
existing facilities. The changes required
to manufacture heat pumps would
require revamping most existing
production equipment and redesigning
a new platform. The capital conversion
costs would include equipment for new
drum lines, assembly line testing
equipment, stamping equipment for
cabinets, and other production
equipment to manufacturer the sealed
systems. In addition to the large
development costs to develop new
platforms, manufacturers would have
the additional expense of developing
the sealed system. Other increases to the
product development costs for heat
pump clothes dryers that concerned
manufacturers were the significant
retraining costs for their servicers and
the marketing costs to educate
consumers and ensure they accept the
new technology. With the substantial
change that would be required to
develop, manufacture, and educate
consumers about heat pump clothes
dryers, manufacturers were concerned
they might not be able to make all the
required changes with a 3-year lead time
between the announcement of the final
rule and the compliance date of the
amended energy conservation.
Manufacturers also indicated that an
energy conservation standard at a level
that effectively required a heat pump
clothes dryer would force them to
consider off-shoring any remaining
production in the United States. Besides
the significant capital and product
conversion costs, manufacturers
indicated that the much higher labor
content of a heat pump clothes dryer
would put additional pressure on
moving production out of the United
States. Finally, manufacturers believed
that repair and maintenance costs
would increase if an energy
conservation standard effectively
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required heat pump clothes dryers.
Repair and maintenance costs would
increase due to the more expensive
components, potential lint management
problems, and some manufacturers’
inexperience with the technology.
Impacts on Profitability
Manufacturers indicated that an
amended energy conservation standard
would likely impact profits in the
clothes dryer market. Because there is
currently no energy label requirement
and no ENERGY STAR program for
clothes dryers, manufacturers indicated
that, unlike clothes washers, efficiency
does not command any premium in the
market (either in percentage or absolute
terms). Because it is difficult to
communicate any energy benefit to
consumers, it is very unlikely that they
could benefit from higher production
costs caused by amended energy
conservation standards.
In addition, manufacturers indicated
that the large incremental cost jumps at
some of the higher efficiency levels,
including heat pump clothes dryers,
were unlikely to be fully passed on to
their customers. Beside the inability to
show the energy benefit of the products,
manufacturers indicated that the
concentrated number of players in the
retail market would put pressure on all
manufacturers to keep costs down in
response to amended energy
conservation standards. Manufacturers
also indicated that many of their sales
are from pairs of clothes washers and
dryers that have similar price points. If
the cost of clothes dryers increased,
manufacturers felt that retailers would
not accept any price increase to keep the
retail prices of the matched pair similar.
b. Room Air Conditioner Key Issues
Impact on Manufacturer Profitability
Several manufacturers stated that they
expect amended energy conservation
standards to negatively impact the
profitability of room air conditioners.
Higher component, tooling, and
development costs for more efficient
products would increase MPCs, but
manufacturers believed these higher
costs could not necessarily be passed on
to consumers due to the nature of the
industry. A few large retailers dominate
the industry and exert downward
pressure on prices. Retailers demand
low prices because consumers have
come to expect room air conditioners at
particular price points. For example,
consumers expect many product
offerings of product class 1 for under
$100, and retailers have successfully
maintained that price point through
competitive bidding. This has resulted
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in price pressure on the most popular
units as manufacturers accept lower
absolute profit on those units in the
hopes of making a larger per unit profit
on other more costly products. Many
room air conditioner purchases are
weather-dependent, so consumers could
easily forgo the purchase of a room air
conditioner unit altogether if prices
increased. Consequently, manufacturers
believed that cost increases would be at
least partly absorbed by manufacturers
to keep retail prices from rising sharply.
If amended energy conservation
standards led to a significant reduction
in profitability, some manufacturers
could exit the market (as a number of
large players have in recent years).
Many manufacturers source room air
conditioner lines from overseas and do
not own the production equipment.
This arrangement would allow
manufacturers to exit the industry
without stranded assets.
Impact on Product Utility
Manufacturers believed a negative
profitability impact could also
indirectly affect product utility. Several
manufacturers indicated that other
features that do not affect efficiency
could be removed or component quality
could be sacrificed to meet amended
standard levels and maintain product
prices at levels that would be acceptable
to consumers.
Manufacturers also expressed concern
that the energy savings from more
stringent energy conservation standards
would not be great enough to justify
passing through the added costs to
consumers. Currently, manufacturers
bundle higher efficiency with other
desirable features to justify higher prices
for ENERGY STAR models. According
to manufacturers, if amended standards
caused prices to increase, the lower
operating costs would not justify higher
prices because the energy savings would
be low compared to the initial price of
the unit. Therefore, the increased cost of
meeting the amended efficiency
requirements may cause manufacturers
to reduce the number of features to
retain a reasonable price point.
The value of future ENERGY STAR
levels is also a concern for
manufacturers. Many retailers and other
distribution channels require ENERGY
STAR products. Because the features
bundled with ENERGY STAR products
are the selling point to consumers,
manufacturers were concerned that a
higher ENERGY STAR level after
amended standards would result in
products with fewer features.
Manufacturers also stated that the
financial burden of developing products
to meet amended energy conservation
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standards has an opportunity cost due
to limited capital and R&D dollars.
Investments incurred to meet amended
energy conservation standards reflect
foregone investments in innovation and
the development of new features that
consumers value and on which
manufacturers earn higher absolute
profit.
Component Availability
Several manufacturers stated they
were concerned about component
availability. Compressor availability
since the conversion to R–410A was the
main problem cited by manufacturers.
Some manufacturers stated that
component suppliers do not give
priority to room air conditioning
because the market is exclusive to North
America and smaller than some of the
other markets they supply. Since the
conversion R–410A, manufacturers
noted the total production capacity of
compressor suppliers has not fully
rebounded. In addition, compressor
suppliers have yet to offer the same
range of compressor capacities and
efficiency tiers.
Size Constraints
A number of manufacturers expressed
concerns about physical limitations of
how large room air conditioners could
grow. Most residential buildings have
standardized window openings.
Because a large portion of air
conditioners are installed in these
standardized openings, products must
still fit in these typical windows after
they have been redesigned.
Manufacturers were largely concerned
that the limited opportunity for growth
also limited opportunities for efficiency
improvements. Increasing the size of
units also presents a problem for smaller
air conditioners, which typically
operate at under 10,000 Btu/hr. Much of
the appeal of these units is that they can
be lifted and installed by one person.
Increasing the size of these units would
greatly alter the market and may cause
consumers to purchase less efficient
portable air-conditioning units.
Manufacturers mentioned refrigerant
charge as another reason why room air
conditioners are constrained by size. If
manufacturers used increased coil size
and a smaller compressor capacity to
improve efficiency, the larger heat
exchangers combined with the reduced
nominal compressor capacity could lead
to a system refrigerant charge amount
that exceeds the recommended level.
Exceeding recommended charge levels
could damage the compressor, thereby
limiting the extent of efficiency
improvements associated with coil size
growth. To counteract the increase in
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charge levels, some manufacturers have
used smaller tubing in their heat
exchangers. However, North American
suppliers are not currently properly
equipped to support smaller tube sizes
and might not be willing to make the
investment required to do so.
Several manufacturers stated that size
is also a concern because moving from
a smaller chassis to larger chassis would
cause material costs to increase
dramatically due to more costly
components and the potential capital
costs required for development. If the
adopted standards required significant
rather than incremental increases in
efficiency, the largest units in each
capacity range would likely have to
move to the next largest or a new
chassis in order to meet the required
efficiency levels. This is a notable
concern for capacities above 28,000 Btu/
hr because manufacturers could choose
to no longer offer these product lines
due to the conversion cost.
Numerous manufacturers stated that
size constraints pose a problem for nonlouvered units in particular. Nonlouvered units inherently have less
room for efficiency improvement
because they need to fit into the existing
sleeves in buildings. They are also
constrained by air flow, increasing the
depth does not result in significant
efficiency gains because air on the
condenser side must still flow through
the rear face. Additionally, increasing
depth creates a product that is less
aesthetically pleasing and could
decrease the available space in the
room.
Product Switching
Some manufacturers noted that higher
consumer prices after an amended
energy conservation standard could
result in product switching along the
upper capacity boundaries of a product
class if efficiency requirements are not
implemented proportionally across
product classes. For example, if after
energy conservation standards are
amended the first cost of units in
product class 1 is not proportionally
lower than units in product class 3,
consumers who would have purchased
product class 1 units are likely to
purchase less efficient, slightly higher
capacity units in product class 3.
Without a significant price differential
between product classes, consumers
would be more likely to buy units with
higher capacity, potentially lowering the
calculated energy savings.
J. Employment Impact Analysis
DOE considers employment impacts
in the domestic economy as one factor
in selecting a proposed standard.
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Employment impacts consist of direct
and indirect impacts. Direct
employment impacts are any changes in
the number of employees of
manufacturers of the appliance products
that are the subject of this rulemaking,
their suppliers, and related service
firms. Indirect employment impacts are
changes in national employment that
occur due to the shift in expenditures
and capital investment caused by the
purchase and operation of more efficient
appliances. The MIA discussed above in
Section IV.I. addresses the direct
employment impacts that concern
manufacturers of clothes dryers and
room air conditioners. The employment
impact analysis addresses the indirect
employment impacts.
Indirect employment impacts from
standards consist of the net jobs created
or eliminated in the national economy,
other than in the manufacturing sector
being regulated, due to: (1) Reduced
spending by end users on energy; (2)
reduced spending on new energy supply
by the utility industry; (3) increased
spending on new products to which the
new standards apply; and (4) the effects
of those three factors throughout the
economy. DOE expects the net monetary
savings from standards to be redirected
to other forms of economic activity.
DOE also expects these shifts in
spending and economic activity to affect
the demand for labor in the short term,
as explained below.
One method for assessing the possible
effects on the demand for labor of such
shifts in economic activity is to compare
sectoral employment statistics
developed by the Labor Department’s
Bureau of Labor Statistics (BLS).54 The
BLS regularly publishes its estimates of
the number of jobs per million dollars
of economic activity in different sectors
of the economy, as well as the jobs
created elsewhere in the economy by
this same economic activity. Data from
BLS indicate that expenditures in the
utility sector generally create fewer jobs
(both directly and indirectly) than
expenditures in other sectors of the
economy. There are many reasons for
these differences, including wage
differences and the fact that the utility
sector is more capital intensive and less
labor intensive than other sectors.55
54 Data on industry employment, hours, labor
compensation, value of production, and the implicit
price deflator for output for these industries are
available upon request by calling the Division of
Industry Productivity Studies (202–691–5618) or by
sending a request by e-mail to dipsweb@bls.gov.
Available at: https://www.bls.gov/news.release/
prin1.nr0.htm.
55 See: Bureau of Economic Analysis. Regional
Multipliers: A User Handbook for the Regional
Input-Output Modeling System (RIMS II). 1192. U.S.
Department of Commerce: Washington, DC.
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Energy conservation standards have
the effect of reducing consumer utility
bills. Because reduced consumer
expenditures for energy likely lead to
increased expenditures in other sectors
of the economy, the general effect of
efficiency standards is to shift economic
activity from a less labor-intensive
sector (i.e., the utility sector) to more
labor-intensive sectors (e.g., the retail
and service sectors). Thus, based on the
BLS data alone, DOE believes net
national employment will increase due
to shifts in economic activity resulting
from amended standards for clothes
dryers and room air conditioners.
For the standard levels considered in
today’s direct final rule, DOE estimated
indirect national employment impacts
using an input/output model of the U.S.
economy called Impact of Sector Energy
Technologies (ImSET). ImSET is a
spreadsheet model of the U.S. economy
that focuses on 187 sectors most
relevant to industrial, commercial, and
residential building energy use.56
ImSET is a special purpose version of
the ‘‘U.S. Benchmark National InputOutput’’ (I–O) model, which has been
designed to estimate the national
employment and income effects of
energy-saving technologies. The ImSET
software includes a computer-based I–O
model with structural coefficients to
characterize economic flows among the
187 sectors. ImSET’s national economic
I–O structure is based on a 2002 U.S.
benchmark table, specially aggregated to
the 187 sectors. DOE estimated changes
in expenditures using the NIA
spreadsheet. Using ImSET, DOE then
estimated the net national, indirect
employment impacts by sector of
potential amended efficiency standards
for clothes dryers and room air
conditioners.
For more details on the employment
impact analysis and the results of this
analysis, see direct final rule TSD
chapter 13.
K. Utility Impact Analysis
The utility impact analysis estimates
several important effects on the utility
industry of the adoption of new or
amended standards. For this analysis,
DOE used the NEMS–BT model to
generate forecasts of electricity
consumption, electricity generation by
plant type, and electric generating
capacity by plant type, that would result
from each TSL. DOE obtained the
energy savings inputs associated with
56 J.M. Roop, M.J. Scott, and R.W. Schultz. ImSET
3.1: Impact of Sector Energy Technologies. 2009.
Pacific Northwest National Laboratory: Richland,
WA. PNNL–18412. Available at: https://
www.pnl.gov/main/publications/external/technical
_reports/PNNL-18412.pdf.
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efficiency improvements to considered
products from the NIA. DOE conducts
the utility impact analysis as a scenario
that departs from the latest AEO
Reference case. In the analysis for
today’s rule, the estimated impacts of
standards are the differences between
values forecasted by NEMS–BT and the
values in the AEO2010 Reference case.
As part of the utility impact analysis,
DOE used NEMS–BT to assess the
impacts on electricity prices of the
reduced need for new electric power
plants and infrastructure projected to
result from the considered standards. In
NEMS–BT, changes in power generation
infrastructure affect utility revenue
requirements, which in turn affect
electricity prices. DOE estimated the
change in electricity prices projected to
result over time from each TSL. For
further discussion, see section IV.G.5.
For more details on the utility impact
analysis and the results of this analysis,
see chapter 14 of the direct final rule
TSD.
L. Environmental Assessment
Pursuant to the National
Environmental Policy Act and the
requirements of 42 U.S.C.
6295(o)(2)(B)(i)(VI), DOE prepared an
environmental assessment (EA) of the
impacts of the standards for clothes
dryers and room air conditioners in
today’s direct final rule, which it has
included as chapter 15 of the direct final
rule TSD. DOE found that the
environmental effects associated with
the standards for clothes dryers and
room air conditioners were not
significant. Therefore, DOE issued a
Finding of No Significant Impact
(FONSI) pursuant to NEPA, the
regulations of the Council on
Environmental Quality (40 CFR parts
1500–1508), and DOE’s regulations for
compliance with NEPA (10 CFR part
1021). The FONSI is available in the
docket for this rulemaking.
In the EA, DOE estimated the
reduction in power sector emissions of
CO2, NOX, and Hg using the NEMS–BT
computer model. In the EA, NEMS–BT
is run similarly to the AEO NEMS,
except that clothes dryer and room air
conditioner energy use is reduced by the
amount of energy saved (by fuel type)
due to each TSL. The inputs of national
energy savings come from the NIA
spreadsheet model, while the output is
the forecasted physical emissions. The
net benefit of each TSL in today’s direct
final rule is the difference between the
forecasted emissions estimated by
NEMS–BT at each TSL and the AEO
2010 Reference Case. NEMS–BT tracks
CO2 emissions using a detailed module
that provides results with broad
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coverage of all sectors and inclusion of
interactive effects. Because the on-site
operation of gas clothes dryers requires
use of fossil fuels and results in
emissions of CO2, NOX and sulfur
dioxide (SO2), DOE also accounted for
the reduction in these emissions due to
standards at the sites where these
appliances are used.
DOE has determined that SO2
emissions from affected fossil fuel fired
combustion devices (also known as
Electric Generating Units (EGUs)) are
subject to nationwide and regional
emissions cap and trading programs that
create uncertainty about the standards’
impact on SO2 emissions. Title IV of the
Clean Air Act, 42 U.S.C. 7401–7671q,
sets an annual emissions cap on SO2 for
affected EGUs in the 48 contiguous
states and the District of Columbia (DC).
SO2 emissions from 28 eastern States
and DC are also limited under the Clean
Air Interstate Rule (CAIR, 70 FR 25162
(May 12, 2005)), which created an
allowance-based trading program.
Although CAIR has been remanded to
the EPA by the U.S. Court of Appeals for
the District of Columbia (DC Circuit),
see North Carolina v. EPA, 550 F.3d
1176 (DC Cir. 2008), it remains in effect
temporarily, consistent with the DC
Circuit’s earlier opinion in North
Carolina v. EPA, 531 F.3d 896 (DC Cir.
2008). On July 6, 2010, EPA issued the
Transport Rule proposal, a replacement
for CAIR, which would limit emissions
from EGUs in 32 states, potentially
through the interstate trading of
allowances, among other options. 75 FR
45210 (Aug. 2, 2010).
The attainment of the emissions caps
is typically flexible among EGUs and is
enforced through the use of emissions
allowances and tradable permits. Under
existing EPA regulations, and under the
Transport Rule if it is finalized, any
excess SO2 emission allowances
resulting from the lower electricity
demand caused by the imposition of an
efficiency standard could be used to
permit offsetting increases in SO2
emissions by any regulated EGU.
However, if the standard resulted in a
permanent increase in the quantity of
unused emission allowances, there
would be an overall reduction in SO2
emissions from the standards. While
there remains some uncertainty about
the ultimate effects of efficiency
standards on SO2 emissions covered by
the existing cap and trade system, the
NEMS–BT modeling system that DOE
uses to forecast emissions reductions
currently indicates that no physical
reductions in power sector emissions
would occur for SO2.
A cap on NOX emissions, affecting
electric generating units in the CAIR
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region, means that standards on clothes
dryers and room air conditioners may
have little or no physical effect on NOX
emissions in the 28 eastern States and
the DC covered by CAIR, or any states
covered by the proposed Transport Rule
if the Transport Rule is finalized. The
standards would, however, reduce NOX
emissions in those 22 States not affected
by the CAIR. As a result, DOE used
NEMS–BT to forecast emission
reductions from the standards
considered for today’s direct final rule.
Similar to emissions of SO2 and NOX,
future emissions of Hg would have been
subject to emissions caps. In May 2005,
EPA issued the Clean Air Mercury Rule
(CAMR). 70 FR 28606 (May 18, 2005).
CAMR would have permanently capped
emissions of mercury for new and
existing coal-fired power plants in all
States by 2010. However, on February 8,
2008, the DC Circuit issued its decision
in New Jersey v. Environmental
Protection Agency, in which it vacated
CAMR. 517 F.3d 574 (DC Cir. 2008).
EPA has decided to develop emissions
standards for power plants under the
Clean Air Act (Section 112), consistent
with the DC Circuit’s opinion on the
CAMR. See https://www.epa.gov/air/
mercuryrule/pdfs/certpetition_
withdrawal.pdf. Pending EPA’s
forthcoming revisions to the rule, DOE
is excluding CAMR from its
environmental assessment. In the
absence of CAMR, a DOE standard
would likely reduce Hg emissions and
DOE plans to use NEMS–BT to estimate
these emission reductions. However,
DOE continues to review the impact of
rules that reduce energy consumption
on Hg emissions, and may revise its
assessment of Hg emission reductions in
future rulemakings.
The operation of gas clothes dryers
requires use of fossil fuels and results in
emissions of CO2, NOX, and SO2 at the
sites where these appliances are used.
NEMS–BT provides no means for
estimating such emissions. DOE
calculated the effect of the standards in
today’s rule on the above site emissions
based on emissions factors derived from
the literature.
Commenting on the preliminary TSD,
AHAM stated that if DOE includes
values for CO2 reductions, it should also
include CO2 emissions that result
indirectly from changes in a standard,
including increased manufacturing
emissions, increased transportation
emissions, and reduced carbon
emissions from peak load reductions.
(AHAM, No. 25 at p. 12) In response,
DOE notes that the inputs to the EA for
national energy savings come from the
NIA. In the NIA, DOE accounts for only
the primary energy savings associated
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with considered standards. In so doing,
EPCA directs DOE to consider (when
determining whether a standard is
economically justified) ‘‘the total
projected amount of energy * * *
savings likely to result directly from the
imposition of the standard.’’ 42 U.S.C.
6295(o)(2)(B)(i)(III) DOE interprets
‘‘directly from the imposition of the
standard’’ to include energy used in the
generation, transmission, and
distribution of fuels used by appliances.
In addition, DOE is evaluating the fullfuel-cycle measure, which includes the
energy consumed in extracting,
processing, and transporting primary
fuels (see section IV.G.3). Both DOE’s
current accounting of primary energy
savings and the full-fuel-cycle measure
are directly linked to the energy used by
appliances. In contrast, energy used in
manufacturing and transporting
appliances is a step removed from the
energy used by appliances. Thus, DOE
did not consider such energy use in
either the NIA or the EA. DOE did
include CO2 emissions reductions
resulting from projected impacts of
revised standards on electricity demand.
M. Monetizing Carbon Dioxide and
Other Emissions Impacts
As part of the development of this
direct final rule, DOE considered the
estimated monetary benefits likely to
result from the reduced emissions of
CO2 NOX that are expected to result
from each of the TSLs considered. In
order to make this calculation similar to
the calculation of the NPV of consumer
benefit, DOE considered the reduced
emissions expected to result over the
lifetime of products shipped in the
forecast period for each TSL. This
section summarizes the basis for the
monetary values used for each of these
emissions and presents the benefits
estimates considered.
For today’s direct final rule, DOE is
relying on a set of values for the social
cost of carbon (SCC) that was developed
by an interagency process. A summary
of the basis for these values is provided
below, and a more detailed description
of the methodologies used is provided
in appendix 15–A of the direct final rule
TSD.
1. Social Cost of Carbon
Under Executive Order 12866,
agencies must, to the extent permitted
by law, ‘‘assess both the costs and the
benefits of the intended regulation and,
recognizing that some costs and benefits
are difficult to quantify, propose or
adopt a regulation only upon a reasoned
determination that the benefits of the
intended regulation justify its costs.’’
The purpose of the SCC estimates
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presented here is to allow agencies to
incorporate the monetized social
benefits of reducing CO2 emissions into
cost-benefit analyses of regulatory
actions that have small, or ‘‘marginal,’’
impacts on cumulative global emissions.
The estimates are presented with an
acknowledgement of the many
uncertainties involved and with a clear
understanding that they should be
updated over time to reflect increasing
knowledge of the science and
economics of climate impacts.
As part of the interagency process that
developed these SCC estimates,
technical experts from numerous
agencies met on a regular basis to
consider public comments, explore the
technical literature in relevant fields,
and discuss key model inputs and
assumptions. The main objective of this
process was to develop a range of SCC
values using a defensible set of input
assumptions grounded in the existing
scientific and economic literatures. In
this way, key uncertainties and model
differences transparently and
consistently inform the range of SCC
estimates used in the rulemaking
process.
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a. Monetizing Carbon Dioxide Emissions
The SCC is an estimate of the
monetized damages associated with an
incremental increase in carbon
emissions in a given year. It is intended
to include (but is not limited to) changes
in net agricultural productivity, human
health, property damages from
increased flood risk, and the value of
ecosystem services. Estimates of the
SCC are provided in dollars per metric
ton of carbon dioxide.
When attempting to assess the
incremental economic impacts of carbon
dioxide emissions, the analyst faces a
number of serious challenges. A recent
report from the National Research
Council 57 points out that any
assessment will suffer from uncertainty,
speculation, and lack of information
about (1) future emissions of greenhouse
gases, (2) the effects of past and future
emissions on the climate system, (3) the
impact of changes in climate on the
physical and biological environment,
and (4) the translation of these
environmental impacts into economic
damages. As a result, any effort to
quantify and monetize the harms
associated with climate change will
raise serious questions of science,
economics, and ethics and should be
viewed as provisional.
57 National
Research Council. Hidden Costs of
Energy: Unpriced Consequences of Energy
Production and Use. National Academies Press:
Washington, DC. 2009.
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Despite the serious limits of both
quantification and monetization, SCC
estimates can be useful in estimating the
social benefits of reducing carbon
dioxide emissions. Consistent with the
directive quoted above, the purpose of
the SCC estimates presented here is to
make it possible for agencies to
incorporate the social benefits from
reducing carbon dioxide emissions into
cost-benefit analyses of regulatory
actions that have small, or ‘‘marginal,’’
impacts on cumulative global emissions.
Most Federal regulatory actions can be
expected to have marginal impacts on
global emissions.
For such policies, the agency can
estimate the benefits from reduced (or
costs from increased) emissions in any
future year by multiplying the change in
emissions in that year by the SCC value
appropriate for that year. The net
present value of the benefits can then be
calculated by multiplying each of these
future benefits by an appropriate
discount factor and summing across all
affected years. This approach assumes
that the marginal damages from
increased emissions are constant for
small departures from the baseline
emissions path, an approximation that
is reasonable for policies that have
effects on emissions that are small
relative to cumulative global carbon
dioxide emissions. For policies that
have a large (non-marginal) impact on
global cumulative emissions, there is a
separate question of whether the SCC is
an appropriate tool for calculating the
benefits of reduced emissions. DOE does
not attempt to answer that question
here.
At the time of the preparation of this
notice, the most recent interagency
estimates of the potential global benefits
resulting from reduced CO2 emissions in
2010, expressed in 2009$, were $4.9,
$22.1, $36.3, and $67.1 per metric ton
avoided. For emission reductions that
occur in later years, these values grow
in real terms over time. Additionally,
the interagency group determined that a
range of values from 7 percent to 23
percent should be used to adjust the
global SCC to calculate domestic
effects,58 although preference is given to
consideration of the global benefits of
reducing CO2 emissions.
It is important to emphasize that the
interagency process is committed to
updating these estimates as the science
and economic understanding of climate
change and its impacts on society
improves over time. Specifically, the
58 It is recognized that this calculation for
domestic values is approximate, provisional, and
highly speculative. There is no a priori reason why
domestic benefits should be a constant fraction of
net global damages over time.
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interagency group has set a preliminary
goal of revisiting the SCC values within
2 years or at such time as substantially
updated models become available, and
to continue to support research in this
area. In the meantime, the interagency
group will continue to explore the
issues raised by this analysis and
consider public comments as part of the
ongoing interagency process.
b. Social Cost of Carbon Values Used in
Past Regulatory Analyses
To date, economic analyses for
Federal regulations have used a wide
range of values to estimate the benefits
associated with reducing carbon dioxide
emissions. In the final model year 2011
CAFE rule, the Department of
Transportation (DOT) used both a
‘‘domestic’’ SCC value of $2 per ton of
CO2 and a ‘‘global’’ SCC value of $33 per
ton of CO2 for 2007 emission reductions
(in 2007 dollars), increasing both values
at 2.4 percent per year.59 See Average
Fuel Economy Standards Passenger
Cars and Light Trucks Model Year 2011,
74 FR 14196 (March 30, 2009); Final
Environmental Impact Statement
Corporate Average Fuel Economy
Standards, Passenger Cars and Light
Trucks, Model Years 2011–2015 at 3–90
(Oct. 2008) (Available at: https://
www.nhtsa.gov/fuel-economy). It also
included a sensitivity analysis at $80
per ton of CO2. A domestic SCC value
is meant to reflect the value of damages
in the United States resulting from a
unit change in carbon dioxide
emissions, while a global SCC value is
meant to reflect the value of damages
worldwide.
A 2008 regulation proposed by DOT
assumed a domestic SCC value of $7 per
ton of CO2 (in 2006 dollars) for 2011
emission reductions (with a range of
$0–$14 for sensitivity analysis), also
increasing at 2.4 percent per year. See
Average Fuel Economy Standards,
Passenger Cars and Light Trucks, Model
Years 2011–2015, 73 FR 24352 (May 2,
2008); Draft Environmental Impact
Statement Corporate Average Fuel
Economy Standards, Passenger Cars and
Light Trucks, Model Years 2011–2015 at
3–58 (June 2008) (Available at: https://
www.nhtsa.gov/fuel-economy). A
regulation for packaged terminal air
conditioners and packaged terminal
heat pumps finalized by DOE in October
of 2008 used a domestic SCC range of
$0 to $20 per ton CO2 for 2007 emission
reductions (in 2007 dollars). 73 FR
58772, 58814 (Oct. 7, 2008) In addition,
EPA’s 2008 Advance Notice of Proposed
Rulemaking for Greenhouse Gases
59 Values per ton of CO given in this section refer
2
to metric tons.
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identified what it described as ‘‘very
preliminary’’ SCC estimates subject to
revision. See Regulating Greenhouse
Gas Emissions Under the Clean Air Act,
73 FR 44354 (July 30, 2008). EPA’s
global mean values were $68 and $40
per ton CO2 for discount rates of
approximately 2 percent and 3 percent,
respectively (in 2006 dollars for 2007
emissions).
In 2009, an interagency process was
initiated to offer a preliminary
assessment of how best to quantify the
benefits from reducing carbon dioxide
emissions. To ensure consistency in
how benefits are evaluated across
agencies, the Administration sought to
develop a transparent and defensible
method, specifically designed for the
rulemaking process, to quantify avoided
climate change damages from reduced
CO2 emissions. The interagency group
did not undertake any original analysis.
Instead, it combined SCC estimates from
the existing literature to use as interim
values until a more comprehensive
analysis could be conducted. The
outcome of the preliminary assessment
by the interagency group was a set of
five interim values: Global SCC
estimates for 2007 (in 2006 dollars) of
$55, $33, $19, $10, and $5 per ton of
CO2.
These interim values represent the
first sustained interagency effort within
the U.S. government to develop an SCC
for use in regulatory analysis. The
results of this preliminary effort were
presented in several proposed and final
rules and were offered for public
comment in connection with proposed
rules, including the joint EPA–DOT fuel
economy and CO2 tailpipe emission
proposed rules. See CAFE Rule for
Passenger Cars and Light Trucks Draft
EIS and Final EIS, cited above.
c. Current Approach and Key
Assumptions
Since the release of the interim
values, the interagency group
reconvened on a regular basis to
generate improved SCC estimates,
which were used in this direct final
rule. Specifically, the group considered
public comments and further explored
the technical literature in relevant
fields.
The interagency group relied on three
integrated assessment models (IAMs)
commonly used to estimate the SCC:
The FUND, DICE, and PAGE models.60
These models are frequently cited in the
peer-reviewed literature and were used
in the last assessment of the
Intergovernmental Panel on Climate
Change. Each model was given equal
weight in the SCC values that were
developed.
Each model takes a slightly different
approach to model how changes in
emissions result in changes in economic
damages. A key objective of the
interagency process was to enable a
consistent exploration of the three
models while respecting the different
approaches to quantifying damages
taken by the key modelers in the field.
An extensive review of the literature
was conducted to select three sets of
input parameters for these models:
Climate sensitivity, socio-economic and
emissions trajectories, and discount
rates. A probability distribution for
climate sensitivity was specified as an
input into all three models. In addition,
the interagency group used a range of
scenarios for the socio-economic
parameters and a range of values for the
discount rate. All other model features
were left unchanged, relying on the
model developers’ best estimates and
judgments.
The interagency group selected four
SCC values for use in regulatory
analyses. Three values are based on the
average SCC from three integrated
assessment models, at discount rates of
2.5, 3, and 5 percent. The fourth value,
which represents the 95th percentile
SCC estimate across all three models at
a 3-percent discount rate, is included to
represent higher-than-expected impacts
from temperature change further out in
the tails of the SCC distribution. For
emissions (or emission reductions) that
occur in later years, these values grow
in real terms over time, as depicted in
Table IV–33.
TABLE IV–33—SOCIAL COST OF CO2, 2010–2050
[In 2007 dollars per metric ton]
Discount rate
5%
Avg
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2010
2015
2020
2025
2030
2035
2040
2045
2050
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
It is important to recognize that a
number of key uncertainties remain, and
that current SCC estimates should be
treated as provisional and revisable
since they will evolve with improved
scientific and economic understanding.
The interagency group also recognizes
that the existing models are imperfect
and incomplete. The National Research
Council report mentioned above points
out that there is tension between the
goal of producing quantified estimates
of the economic damages from an
incremental ton of carbon and the limits
of existing efforts to model these effects.
There are a number of concerns and
problems that should be addressed by
the research community, including
research programs housed in many of
3%
Avg
4.7
5.7
6.8
8.2
9.7
11.2
12.7
14.2
15.7
2.5%
Avg
21.4
23.8
26.3
29.6
32.8
36.0
39.2
42.1
44.9
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64.9
72.8
80.7
90.4
100.0
109.7
119.3
127.8
136.2
the agencies participating in the
interagency process to estimate the SCC.
The U.S. government intends to
periodically review and reconsider
estimates of the SCC used for costbenefit analyses to reflect increasing
knowledge of the science and
economics of climate impacts, as well as
improvements in modeling. In this
context, statements recognizing the
60 The models are described in appendix 15–A of
the final rule TSD.
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35.1
38.4
41.7
45.9
50.0
54.2
58.4
61.7
65.0
3%
95th
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limitations of the analysis and calling
for further research take on exceptional
significance. The interagency group
offers the new SCC values with all due
humility about the uncertainties
embedded in them and with a sincere
promise to continue work to improve
them.
In summary, in considering the
potential global benefits resulting from
reduced CO2 emissions, DOE used the
most recent values identified by the
interagency process, adjusted to 2009$
using the GDP price deflator values for
2008 and 2009. For each of the four
cases specified, the values used for
emissions in 2010 were $4.9, $22.1,
$36.3, and $67.1 per metric ton avoided
(values expressed in 2009$). To
monetize the CO2 emissions reductions
expected to result from amended
standards for clothes dryers and room
air conditioners in 2014–2043, DOE
used the values identified in Table A1
of the ‘‘Social Cost of Carbon for
Regulatory Impact Analysis Under
Executive Order 12866,’’ which is
reprinted in appendix 16–A of the direct
final rule TSD, appropriately adjusted to
2009$.61 To calculate a present value of
the stream of monetary values, DOE
discounted the values in each of the
four cases using the specific discount
rate that had been used to obtain the
SCC values in each case.
2. Valuation of Other Emissions
Reductions
DOE investigated the potential
monetary benefit of reduced NOX
emissions from the TSLs it considered.
As noted above, amended energy
conservation standards would reduce
NOX emissions in those 22 States that
are not affected by the CAIR, in addition
to the reduction in site NOX emissions
nationwide. DOE estimated the
monetized value of NOX emissions
reductions resulting from each of the
TSLs considered for today’s direct final
rule based on environmental damage
estimates from the literature. Available
estimates suggest a very wide range of
monetary values, ranging from $370 per
ton to $3,800 per ton of NOX from
stationary sources, measured in 2001$
(equivalent to a range of $447 to $4,591
per ton in 2009$).62 In accordance with
OMB guidance, DOE conducted two
calculations of the monetary benefits
derived using each of the economic
values used for NOX, one using a real
discount rate of 3 percent and another
using a real discount rate of 7 percent.63
DOE is aware of multiple agency
efforts to determine the appropriate
range of values used in evaluating the
potential economic benefits of reduced
Hg emissions. DOE has decided to await
further guidance regarding consistent
valuation and reporting of Hg emissions
before it once again monetizes Hg in its
rulemakings.
Commenting on the preliminary TSD,
Whirlpool stated that CO2 emissions
should not be monetized because the
market value cannot be readily
determined, the impact is negligible,
and it is already included in energy
savings. (Whirlpool, No. 22 at p. 6) DOE
acknowledges that the market value of
future CO2 emissions reductions is
uncertain, and for this reason it uses a
wide range of potential values, as
described above. The impact of revised
standards for room air conditioners and
clothes dryers on future CO2 emissions,
described in section V.6 of this notice,
is not negligible. In addition, the value
of CO2 emissions reductions is not
included in energy cost savings because
the energy prices that DOE used to
calculate those savings do not include
any taxes or other charges to account for
the CO2 emissions associated with the
use of electricity or natural gas by the
considered appliances.
V. Analytical Results
The following section addresses the
results from DOE’s analyses with
respect to potential energy conservation
standards for the products examined as
part of this rulemaking. It addresses the
TSLs examined by DOE, the projected
impacts of each of these levels if
adopted as energy conservation
standards for clothes dryers and room
air conditioners, and the standards
levels that DOE sets forth in today’s
direct final rule. Additional details
regarding the analyses conducted by the
agency are contained in the publicly
available direct final rule TSD
supporting this notice.
A. Trial Standard Levels
DOE analyzed the benefits and
burdens of a number of TSLs for the
products that are the subject of today’s
direct final rule. A description of each
TSL DOE analyzed is provided below.
DOE attempted to limit the number of
TSLs considered for the final rule by
excluding efficiency levels that do not
exhibit significantly different economic
or engineering characteristics from the
efficiency levels already selected as a
TSL. While DOE presents the results for
only those efficiency levels in TSL
combinations, DOE presents the results
for all efficiency levels that it analyzed
in chapter 10 of the direct final rule
TSD.
Table V–1 presents the TSLs and the
corresponding product class efficiency
levels for clothes dryers. TSL 1 consists
of the efficiency levels with the largest
market share with a positive NPV (at a
3-percent discount rate). TSL 2 consists
of the efficiency levels with the highest
NPV (at a 3-percent discount rate). TSL
3 consists of the efficiency levels with
the highest energy savings and a
positive NPV (at a 3-percent discount
rate). TSL 4 consists of the efficiency
levels that reflect 5-percent efficiency
increase above the baseline. TSL 4 also
corresponds to the standards
recommended by the Joint Petitioners.
TSL 5 consists of non heat pump design
efficiency levels with the highest energy
savings. TSL 6 consists of the max-tech
efficiency levels.
TABLE V–1—TRIAL STANDARD LEVELS FOR CLOTHES DRYERS
CEF
Product class
mstockstill on DSKH9S0YB1PROD with RULES2
TSL 1
Vented Electric Standard .....................................................................................
Vented Electric Compact 120V ............................................................................
Vented Electric Compact 240V ............................................................................
Vented Gas ..........................................................................................................
Ventless Electric Compact 240V .........................................................................
Ventless Electric Combination Washer/Dryer ......................................................
61 Table A1 presents SCC values through 2050.
For DOE’s calculation, it derived values after 2050
using the 3-percent per year escalation rate used by
the interagency group.
VerDate Mar<15>2010
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TSL 2
3.56
3.43
3.12
3.16
2.55
2.08
62 For additional information, refer to U.S. Office
of Management and Budget, Office of Information
and Regulatory Affairs. 2006 Report to Congress on
the Costs and Benefits of Federal Regulations and
PO 00000
Frm 00077
Fmt 4701
Sfmt 4700
3.61
3.61
3.27
3.20
2.69
2.56
TSL 3
3.73
3.61
3.27
3.20
2.69
2.56
TSL 4
3.73
3.61
3.27
3.30
2.55
2.08
TSL 5
4.08
4.08
3.60
3.61
2.80
2.56
TSL 6
5.42
5.41
4.89
3.61
4.03
3.69
Unfunded Mandates on State, Local, and Tribal
Entities. 2006. Washington, DC.
63 OMB, Circular A–4: Regulatory Analysis (Sept.
17, 2003).
E:\FR\FM\21APR2.SGM
21APR2
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Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
Table V–2 presents the TSLs and the
corresponding product class efficiency
levels for room air conditioners. TSL 1
consists of the efficiency levels with the
largest market share with a positive NPV
(at a 3-percent discount rate). TSL 2
consists of the ENERGY STAR levels for
each product class. TSL 3 consists of the
efficiency levels with the highest NPV
(at a 3-percent discount rate). TSL 4
consists of the efficiency levels set forth
in the Joint Petition presented to DOE.
TSL 5 consists of the efficiency levels
with the highest energy savings and a
positive NPV (at a 7-percent discount
rate). TSL 6 consists of the max-tech
efficiency levels.
TABLE V–2—TRIAL STANDARD LEVELS FOR ROOM AIR CONDITIONERS
CEER
Product class
TSL 1
Group
Group
Group
Group
Group
Group
1—includes
2—includes
3—includes
4—includes
5—includes
6—includes
PC
PC
PC
PC
PC
PC
1 ......................................................................................
2, 3, 4, 11 .......................................................................
5A, 9, 13 .........................................................................
5B, 10 .............................................................................
6, 7, 8A, 12 .....................................................................
8B, 14, 15, 16 .................................................................
B. Economic Justification and Energy
Savings
1. Economic Impacts on Individual
Consumers
a. Life-Cycle Cost and Payback Period
Consumers affected by new or
amended standards usually experience
higher purchase prices and lower
operating costs. Generally, these
impacts on individual consumers are
best captured by changes in life-cycle
costs and by the payback period.
10.10
10.70
9.40
9.40
9.30
9.30
TSL 2
TSL 3
10.60
10.70
9.40
9.40
9.30
9.30
Therefore, DOE calculated the LCC and
PBP analyses for the potential standard
levels considered in this rulemaking.
DOE’s LCC and PBP analyses provided
key outputs for each TSL, which are
reported by clothes dryer product class
in Table V–3 through Table V–8, and by
room air conditioner product class in
Table V–9 through Table V–14. Each
table includes the average total LCC and
the average LCC savings, as well as the
fraction of product consumers for which
the LCC will either decrease (net
benefit), or increase (net cost), or exhibit
10.10
10.90
8.47
8.48
9.60
9.50
TSL 4
TSL 5
11.10
10.90
9.40
9.00
9.60
9.50
11.10
11.50
8.47
8.48
10.00
9.50
TSL 6
11.67
11.96
10.15
9.80
10.35
10.02
no change (no impact) relative to the
base-case forecast. The last output in the
tables is the median PBP for the
consumer purchasing a design that
complies with the TSL. DOE presents
the median PBP because it is the most
statistically robust measure of the PBP.
The results for each potential standard
level are relative to the efficiency
distribution in the base case (no
amended standards). DOE based the
LCC and PBP analyses on the range of
energy consumption under conditions
of actual product use.
TABLE V–3—LCC AND PAYBACK PERIOD RESULTS FOR ELECTRIC STANDARD DRYERS
Life-cycle cost 2009$
TSL
CEF
1 .........................................................
2 .........................................................
3, 4 .....................................................
5 .........................................................
6 .........................................................
3.56
3.61
3.73
4.08
5.42
Installed
cost
Discounted
operating
cost
$455
456
467
583
879
$867
856
829
761
580
LCC savings
LCC
$1,323
1,311
1,296
1,343
1,459
Percent of households that
experience
Average
savings
2009$
Net cost
$0
2
14
¥30
¥146
0.7
0.3
19.0
75.3
81.0
No
impact
Net
benefit
97.6
78.7
24.8
1.0
0.0
1.7
21.0
56.3
23.7
19.0
Payback
period
years
Median
3.9
0.2
5.3
19.1
22.1
TABLE V–4—LCC AND PAYBACK PERIOD RESULTS FOR ELECTRIC COMPACT 120V DRYERS
Life-cycle cost 2009$
mstockstill on DSKH9S0YB1PROD with RULES2
TSL
CEF
1 .........................................................
2, 3, 4 .................................................
5 .........................................................
6 .........................................................
VerDate Mar<15>2010
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Jkt 223001
3.43
3.61
4.08
5.41
PO 00000
Installed
cost
Discounted
operating
cost
$470
471
627
875
Frm 00078
LCC savings
LCC
Percent of households that
experience
Average
savings
2009$
Net cost
n/a
$14
¥99
¥264
0
4.0
95.5
95.4
$384
369
325
243
Fmt 4701
$854
840
953
1,118
Sfmt 4700
E:\FR\FM\21APR2.SGM
21APR2
No
impact
100
0.0
0.0
0.0
Net
benefit
0
96.0
4.5
4.6
Payback
period
years
Median
n/a
0.9
36.1
40.1
22531
Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
TABLE V–5—LCC AND PAYBACK PERIOD RESULTS FOR ELECTRIC COMPACT 240V DRYERS
Life-cycle cost 2009$
TSL
CEF
1 .........................................................
2, 3, 4 .................................................
5 .........................................................
6 .........................................................
3.12
3.27
3.60
4.89
Installed
cost
Discounted
operating
cost
$470
471
627
875
$427
411
373
272
LCC savings
LCC
$896
882
1,000
1,147
Percent of households that
experience
Average
savings
2009$
Net cost
n/a
$8
¥99
¥246
0
2.3
93.3
94.5
No
impact
100
41.4
4.2
0.0
Net
benefit
Payback
period
years
Median
0
56.3
2.5
5.5
n/a
0.9
45.1
38.2
TABLE V–6—LCC AND PAYBACK PERIOD RESULTS FOR GAS DRYERS
Life-cycle cost 2009$
TSL
CEF
1 .........................................................
2, 3 .....................................................
4 .........................................................
5, 6 .....................................................
3.16
3.20
3.30
3.61
Installed
cost
Discounted
operating
cost
$554
555
555
658
$445
440
427
404
LCC savings
LCC
$999
995
983
1,062
Percent of households that
experience
Average
savings
2009$
Net cost
n/a
$0
2
¥69
0
0.5
0.3
87.7
No
impact
100
92.9
84.5
10.5
Net
benefit
Payback
period
years
Median
0
6.6
15.2
1.8
n/a
2.2
0.5
73.3
TABLE V–7—LCC AND PAYBACK PERIOD RESULTS FOR VENTLESS 240V DRYERS
Life-cycle cost 2009$
TSL
CEF
1, 4 .....................................................
2, 3 .....................................................
5 .........................................................
6 .........................................................
2.55
2.69
2.80
4.03
Installed
cost
Discounted
operating
cost
$1,093
1,094
1,176
1,462
$452
431
411
261
LCC savings
LCC
$1,545
1,525
1,587
1,722
Percent of households that
experience
Average
savings
2009$
Net cost
n/a
$20
¥42
¥177
0
0.0
92.5
88.5
No
impact
100
0.0
0.0
0.0
Net
benefit
Payback
period
years
Median
0
100.0
7.5
11.5
n/a
0.9
25.3
26.9
TABLE V–8—LCC AND PAYBACK PERIOD RESULTS FOR VENTLESS COMBINATION WASHER/DRYERS
Life-cycle cost 2009$
TSL
CEF
1, 4 .....................................................
2, 3, 5 .................................................
6 .........................................................
2.08
2.56
3.69
Installed
cost
Discounted
operating
cost
$1,533
1,579
1,981
$565
446
282
LCC savings
LCC
$2,098
2,025
2,263
Percent of households that
experience
Average
savings
2009$
Net cost
n/a
$73
¥166
0
20.6
82.4
No
impact
100
0.0
0.0
Net
benefit
Payback
period
years
Median
0
79.4
17.6
n/a
5.3
22.4
TABLE V–9—LCC AND PAYBACK PERIOD RESULTS FOR ROOM AIR CONDITIONERS, < 6,000 Btu/h, WITH LOUVERS
Life-cycle cost 2009$
mstockstill on DSKH9S0YB1PROD with RULES2
TSL
CEER
1, 3 .....................................................
2 .........................................................
4, 5 .....................................................
6 .........................................................
VerDate Mar<15>2010
16:58 Apr 20, 2011
Jkt 223001
10.10
10.60
11.10
11.67
PO 00000
Installed
cost
Discounted
operating
cost
$361
374
393
472
Frm 00079
$357
341
326
311
Fmt 4701
Sfmt 4700
LCC savings
LCC
$718
715
719
784
Percent of households that
experience
Average
savings
2009$
Net cost
$9
11
7
¥58
21.2
32.8
64.6
90.4
E:\FR\FM\21APR2.SGM
21APR2
No
impact
30.7
30.7
1.2
0.0
Net
benefit
48.1
36.6
34.2
9.6
Payback
period
years
Median
4.1
5.8
8.6
20.9
22532
Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
TABLE V–10—LCC AND PAYBACK PERIOD RESULTS FOR ROOM AIR CONDITIONERS, 8,000–13,999 Btu/h, WITH LOUVERS
Life-cycle cost 2009$
TSL
CEER
1, 2 .....................................................
3, 4 .....................................................
5 .........................................................
6 .........................................................
10.70
10.90
11.50
11.96
Installed
cost
Discounted
operating
cost
$493
497
525
605
$557
547
519
500
LCC savings
LCC
$1,050
1,045
1,044
1,104
Percent of households that
experience
Average
savings
2009$
Net cost
$16
22
22
¥38
9.3
33.6
55.7
77.3
No
impact
60.5
2.2
0.8
0.5
Net
benefit
Payback
period
years
Median
30.2
64.1
43.4
22.2
0.0
2.8
7.1
14.7
TABLE V–11—LCC AND PAYBACK PERIOD RESULTS FOR ROOM AIR CONDITIONERS, 20,000–24,999 Btu/h, WITH
LOUVERS
Life-cycle cost 2009$
TSL
CEER
3, 5 .....................................................
1, 2, 4 .................................................
6 .........................................................
8.47
9.40
10.15
Installed
cost
Discounted
operating
cost
$857
887
1,159
$750
672
626
LCC savings
LCC
$1,607
1,559
1,785
Percent of households that
experience
Average
savings
2009$
Net cost
n/a
$6
¥214
0
5.1
97.6
No
impact
100
85.3
2.1
Net
benefit
0
9.6
0.3
Payback
period
years
Median
n/a
4.3
73.8
TABLE V–12—LCC AND PAYBACK PERIOD RESULTS FOR ROOM AIR CONDITIONERS, > 25,000 Btu/h, WITH LOUVERS
Life-cycle cost 2009$
TSL
CEER
3, 5 .....................................................
4 .........................................................
1, 2 .....................................................
6 .........................................................
8.48
9.00
9.40
9.80
Installed
cost
Discounted
operating
cost
$979
1,019
1,058
1,313
$823
777
739
712
LCC savings
LCC
$1,802
1,796
1,797
2,025
Percent of households that
experience
Average
savings
2009$
Net cost
n/a
$1
1
¥227
0
8.9
11.0
99.8
No
impact
100
87.6
85.3
0.0
Net
benefit
0
3.5
3.7
0.2
Payback
period
years
Median
n/a
10.1
10.3
107.7
TABLE V–13—LCC AND PAYBACK PERIOD RESULTS FOR ROOM AIR CONDITIONERS, 8,000–10,999 Btu/h, WITHOUT
LOUVERS
Life-cycle cost 2009$
TSL
CEER
1, 2 .....................................................
3, 4 .....................................................
5 .........................................................
6 .........................................................
9.30
9.60
10.00
10.35
Installed
cost
Discounted
operating
cost
%495
498
512
615
$490
476
454
440
LCC savings
LCC
$986
974
966
1,055
Percent of households that
experience
Average
savings
2009$
Net cost
$4
13
20
¥66
0.9
12.3
38.0
91.8
No
impact
89.9
25.2
5.6
1.9
Net
benefit
9.2
62.5
56.3
6.2
Payback
period
years
Median
1.5
2.1
4.9
25.2
TABLE V–14—LCC AND PAYBACK PERIOD RESULTS FOR ROOM AIR CONDITIONERS, > 11,000 Btu/h, WITHOUT LOUVERS
mstockstill on DSKH9S0YB1PROD with RULES2
Life-cycle cost 2009$
TSL
CEER
1, 2 .....................................................
3, 4, 5 .................................................
VerDate Mar<15>2010
16:58 Apr 20, 2011
Jkt 223001
9.30
9.50
9.80
PO 00000
Installed
cost
Discounted
operating
cost
$590
596
611
Frm 00080
$698
684
660
Fmt 4701
Sfmt 4700
LCC savings
LCC
$1,288
1,279
1,271
Percent of households that
experience
Average
savings
2009$
Net cost
$5
11
18
2.2
22.7
36.0
E:\FR\FM\21APR2.SGM
21APR2
No
impact
89.9
30.6
17.3
Net
benefit
7.9
46.6
46.6
Payback
period
years
Median
2.6
3.7
5.3
22533
Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
TABLE V–14—LCC AND PAYBACK PERIOD RESULTS FOR ROOM AIR CONDITIONERS, > 11,000 Btu/h, WITHOUT
LOUVERS—Continued
Life-cycle cost 2009$
TSL
CEER
6 .........................................................
10.02
b. Consumer Subgroup Analysis
As described in section IV.H, DOE
determined the impact of the considered
TSLs on low-income households and
senior-only households.
Table V–15 and Table V–16 compare
the average LCC savings at each
Discounted
operating
cost
Installed
cost
707
LCC savings
Net cost
¥64
LCC
647
Percent of households that
experience
Average
savings
2009$
92.6
1,354
efficiency level for the two consumer
subgroups with the average LCC savings
for the entire sample for each product
class for clothes dryers and room air
conditioners, respectively. DOE found
that the average LCC savings for lowincome households and senior-only
No
impact
Net
benefit
0.0
Payback
period
years
Median
7.3
25.9
households at the considered efficiency
levels are not substantially different
from the average for all households.
Chapter 11 of the direct final rule TSD
presents the complete LCC and PBP
results for the two subgroups.
TABLE V–15—CLOTHES DRYERS: COMPARISON OF AVERAGE LCC SAVINGS FOR CONSUMER SUBGROUPS AND ALL
HOUSEHOLDS
Electric standard
CEF
3.56
3.61
3.73
3.81
4.08
5.42
Senior
.......
.......
.......
.......
.......
.......
Vented 120V
Low-income
$0
2
7
¥40
¥62
¥245
All
$0
2
12
¥30
¥38
¥170
CEF
$0
2
14
¥27
¥30
¥146
Senior
3.48
3.61
3.72
3.80
4.08
5.41
3.16
3.20
3.30
3.41
3.61
Senior
.......
.......
.......
.......
.......
$0
2
¥1
¥76
¥115
Low-income
$3
14
¥8
¥63
¥113
¥306
Gas
CEF
Vented 240V
All
$3
13
¥5
¥57
¥99
¥262
$4
14
¥5
¥56
¥99
¥264
CEF
Senior
3.16
3.27
3.36
3.48
3.60
4.89
Ventless 240V
Low-income
All
$0
2
2
¥69
¥100
CEF
$0
2
2
¥69
¥100
Senior
2.59
2.69
2.71
2.80
4.03
$5
20
¥14
¥49
¥234
$2
9
¥8
¥54
¥110
¥291
Low-income
$2
8
¥6
¥47
¥99
¥243
All
$2
8
¥5
¥47
¥99
¥246
Ventless Combination
Low-income
All
$5
19
¥14
¥42
¥175
$5
20
¥13
¥42
¥177
CEF
Senior
2.35
2.38
2.46
2.56
3.69
$49
54
68
41
¥253
Low-income
$76
80
93
73
¥162
All
$75
79
93
73
¥166
TABLE V–16—ROOM AIR CONDITIONERS: COMPARISON OF AVERAGE LCC SAVINGS FOR CONSUMER SUBGROUPS AND
ALL HOUSEHOLDS
< 6,000 Btu/h, with louvers
CEER
10.10
10.60
11.10
11.38
11.67
Senior
.....
.....
.....
.....
.....
8,000–13,999 Btu/h, with louvers
Low-income
$5
4
¥5
¥17
¥75
All
$12
17
17
9
¥44
CEER
$9
11
7
¥3
¥58
10.20
10.70
10.90
11.50
11.96
> 25,000 Btu/h, with louvers
Low-income
All
9.00 .......
9.40 .......
9.80 .......
...............
mstockstill on DSKH9S0YB1PROD with RULES2
Senior
$0
¥1
¥234
.................
$4
7
¥209
.......................
$1
1
¥227
.................
CEER
c. Rebuttable Presumption Payback
As discussed above, EPCA provides a
rebuttable presumption that an energy
conservation standard is economically
justified if the increased purchase cost
for a product that meets the standard is
less than three times the value of the
16:58 Apr 20, 2011
$8
13
17
14
¥49
Low-income
All
$10
18
24
27
¥31
$9
16
22
22
¥38
CEER
Senior
Low-income
All
9.00
9.40
9.80
10.15
.................
$1
3
¥17
¥223
.................
$7
13
8
¥187
.......................
$3
6
¥10
¥214
.................
8,000–10,999 Btu/h, without louvers
CEER
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20,000–24,999 Btu/h, with louvers
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Senior
9.30
9.60
10.00
10.35
$4
11
16
¥73
Low-income
> 11,000 Btu/h, without louvers
All
$5
15
23
¥62
$4
13
20
¥66
first-year energy savings resulting from
the standard. In calculating a rebuttable
presumption payback period for the
considered standard levels, DOE used
discrete values rather than distributions
for input values, and, as required by
EPCA, based the energy use calculation
on the DOE test procedures for the
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CEER
Senior
9.30
9.50
9.80
10.02
$4
9
13
¥71
Low-income
$6
13
21
¥60
All
$5
11
18
¥64
considered products. As a result, DOE
calculated a single rebuttable
presumption payback value, and not a
distribution of payback periods, for each
efficiency level. Table V–17 and Table
V–18 present the average rebuttable
presumption payback periods for those
efficiency levels where the increased
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purchase cost for a product that meets
a standard at that level is less than three
times the value of the first-year energy
savings resulting from the standard.
TABLE V–17—CLOTHES DRYERS: EFFICIENCY LEVELS WITH REBUTTABLE PAYBACK PERIOD LESS THAN THREE YEARS
Product class
CEF
Electric standard ..........................................................................................................................................................................
Electric compact 120V .................................................................................................................................................................
Electric compact 240V .................................................................................................................................................................
Gas ..............................................................................................................................................................................................
Ventless compact 240V ...............................................................................................................................................................
Ventless combination washer/dryers ...........................................................................................................................................
3.61
3.48
3.61
3.16
3.27
3.20
2.59
2.69
2.46
2.46
2.46
PBP
(years)
0.95
2.49
0.86
2.57
0.85
1.81
2.33
0.83
0.42
0.68
0.74
TABLE V–18—ROOM AIR CONDITIONERS: EFFICIENCY LEVELS WITH REBUTTABLE PAYBACK PERIOD LESS THAN THREE
YEARS
Product class
CEER
Room Air Conditioners (8000–13,999 Btu/h), with Louvers ........................................................................................................
Room Air Conditioners (20,000–24,999 Btu/h), with Louvers .....................................................................................................
Room Air Conditioners (> 25,000 Btu/h), with Louvers ...............................................................................................................
Room Air Conditioners (8000–10,999 Btu/h), without Louvers ...................................................................................................
Room Air Conditioners (> 11,000 Btu/h), without Louvers ..........................................................................................................
While DOE examined the rebuttablepresumption criterion, it considered
whether the standard levels considered
for today’s rule are economically
justified through a more detailed
analysis of the economic impacts of
these levels pursuant to 42 U.S.C.
6295(o)(2)(B)(i). The results of this
analysis serve as the basis for DOE to
definitively evaluate the economic
justification for a potential standard
level (thereby supporting or rebutting
the results of any preliminary
determination of economic
justification).
mstockstill on DSKH9S0YB1PROD with RULES2
2. Economic Impacts on Manufacturers
DOE performed an MIA to estimate
the impact of amended energy
conservation standards on
manufacturers of clothes dryers and
room air conditioners. The section
below describes the expected impacts
on manufacturers at each TSL. Chapter
12 of the direct final rule TSD explains
the analysis in further detail.
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a. Industry Cash Flow Analysis Results
The tables below depict the financial
impacts on manufacturers (represented
by changes in INPV) and the conversion
costs DOE estimates manufacturers
would incur at each TSL. Each set of
results below shows two tables of
INPV impacts: The first table reflects the
lower (less severe) bound of impacts
and the second represents the upper
bound. To evaluate this range of cashflow impacts on each industry, DOE
modeled two different scenarios using
different markup assumptions. These
assumptions correspond to the bounds
of a range of market responses that DOE
anticipates could occur in the standards
case. Each scenario results in a unique
set of cash flows and corresponding
industry value at each TSL.
The INPV results refer to the
difference in industry value between the
base case and the standards case, which
DOE calculated by summing the
discounted industry cash flows from the
base year (2011) through the end of the
analysis period. The discussion also
notes the difference in cash flow
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10.2
10.7
10.9
9.0
9.4
9.8
9.0
9.4
9.3
9.6
10.0
9.3
9.5
9.8
PBP
(years)
1.1
1.6
1.8
0.9
1.1
1.9
2.1
2.4
0.6
0.7
1.3
1.3
1.4
1.9
between the base case and the standards
case in the year before the compliance
date of potential amended energy
conservation standards. This figure
provides a proxy for the magnitude of
the required conversion costs, relative to
the cash flow generated by the industry
in the base case.
Cash Flow Analysis Results for Clothes
Dryers
To assess the lower (less severe) end
of the range of potential impacts on the
residential clothes dryer industry, DOE
modeled the flat markup scenario. The
flat markup scenario assumes that in the
standards case manufacturers would be
able to pass the higher productions costs
required for more efficient products on
to their customers. Specifically, the
industry would be able to maintain its
average base-case gross margin, as a
percentage of revenue, despite higher
product costs. In general, the larger the
product price increases, the less likely
manufacturers are to achieve the cash
flow from operations calculated in this
scenario because the less likely it is that
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manufacturers would be able to fully
markup these larger cost increases.
To assess the higher (more severe) end
of the range of potential impacts on the
residential clothes dryer industry, DOE
modeled the preservation of operating
profit markup scenario. The scenario
represents the upper end of the range of
potential impacts on manufacturers
important driver of the INPV results
below (Table V–19 and Table V–20).
The main NIA shipment scenario
includes a price elasticity effect,
meaning higher prices in the standards
case result in lower shipments. Lower
shipments also reduce industry revenue,
and, in turn, INPV.
because no additional operating profit is
earned on the higher production costs,
eroding profit margins as a percentage of
total revenue.
DOE used the main NIA shipment
scenario for the both the lower- and
higher-bound MIA scenarios that were
used to characterize the potential INPV
impacts. The shipment forecast is an
TABLE V–19—MANUFACTURER IMPACT ANALYSIS FOR CLOTHES DRYERS—FLAT MARKUP SCENARIO
Trial standard level
Units
Base case
1
INPV .............................................................................
Change in INPV ...........................................................
Product Conversion Costs ...........................................
Capital Conversion Costs ............................................
Total Conversion Costs ........................................
2009$
2009$
%
2009$
2009$
millions
millions
2
3
4
5
6
millions
millions
1,003.6
..................
..................
..................
..................
1,001.1
¥2.6
¥0.3%
4
0
1,000.0
¥3.6
¥0.4%
5
2
962.5
¥41.13
¥4.1%
18
48
939.2
¥64.46
¥6.4%
24
71
827.1
¥176.5
¥17.6%
166
328
699.7
¥303.9
¥30.3%
383
536
2009$ millions
..................
4
7
66
95
494
919
TABLE V–20—MANUFACTURER IMPACT ANALYSIS FOR CLOTHES DRYERS—PRESERVATION OF OPERATING PROFIT
MARKUP SCENARIO
Trial standard level
Units
Base case
1
INPV ...........................................................................
Change in INPV .........................................................
Product Conversion Costs ..........................................
Capital Conversion Costs ...........................................
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Total Conversion Costs .......................................
TSL 1 represents the baseline CEF for
120V electric compact clothes dryers
(product class 2), 240V electric compact
clothes dryers (product class 3), 240V
compact ventless clothes dryers
(product class 5), and electric
combination ventless clothes dryers
(product class 6). TSL 1 represents a
CEF of 3.56 for standard-size vented
electric clothes dryers (product class 1)
and a CEF of 3.16 for gas vented clothes
dryers (product class 4). At TSL 1, DOE
estimates impacts on INPV to range
¥$2.55 million to ¥$2.62 million, or a
change in INPV of ¥0.3 percent. At this
proposed level, industry free cash flow
is estimated to decrease by
approximately 1.6 percent to $68.6
million, compared to the base-case
value of $69.7 million in the year
leading up to the proposed energy
conservation standards.
The design options DOE analyzed for
product class 1 and 4 include lowering
standby power consumption only.
Standby power changes would result in
only minor changes to baseline products
and would take a minimal effort by
manufacturers to comply with the
amended energy conservation
standards. The standby power changes
at TSL 1 would require relatively small
product development efforts to reach
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2009$
2009$
%
2009$
2009$
millions
millions
2
3
4
5
6
millions
millions
1,003.6
..................
..................
..................
..................
1,001.0
¥2.6
¥0.3%
4
0
998.7
¥4
¥0.5%
5
2
948.2
¥55.46
¥5.5%
18
48
923.0
¥80.63
¥8.0%
24
71
606.2
¥397.4
¥39.6%
166
328
273.6
¥730.0
¥72.7%
383
536
2009$ millions
..................
4
7
66
95
494
919
the CEF levels and would not change
the assembly of currently products,
greatly limiting the necessary capital
conversion costs. In addition, the design
options for standby power do not add
significant costs to existing products.
Therefore, the impact on manufacturers
is very small at TSL 1.
TSL 2 represents a CEF of 3.61 for
product class 1, a CEF of 3.61 for
product class 2, a CEF of 3.27 for
product class 3, a CEF of 3.20 for
product class 4, a CEF of 2.69 for
product class 5, and a CEF of 2.56 for
product class 6. At TSL 2, DOE
estimates impacts on INPV to range
¥$3.6 million to ¥$4.9 million, or a
change in INPV of ¥0.4 percent to ¥0.5
percent. At this proposed level, industry
free cash flow is estimated to decrease
by approximately 3.0 percent to $67.6
million, compared to the base-case
value of $69.7 million in the year
leading up to the proposed energy
conservation standards.
The design options analyzed at TSL 2
for product classes 1 through 5
represent improvements to standby
power consumption only. The changes
required at TSL 2 would not greatly
alter baseline products for these product
classes because these analyzed design
options are small component changes
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for standby power for product classes 1
through 5. The design options analyzed
for product class 6 include changes to
active mode power consumption.
However, these active mode changes for
product class 6 are also relatively minor
and would take a minimal effort by
manufacturers to comply with the
amended energy conservation
standards. For product class 6, the
analyzed design option for active mode
is automatic cycle termination
technology which adds very little cost to
the product and takes minimal capital
and product conversion costs to
implement. Because the changes for
product class 1 through 5 only include
standby power changes and the active
mode changes for product class 6 are
minor, the impact on manufacturers is
very small at TSL 2.
The efficiency requirements for
product classes 2 to 6 are the same at
TSL 3 as at TSL 2. TSL 3, however,
represents a further improvement to a
CEF of 3.73 for product class 1. At TSL
3, DOE estimates impacts on INPV to
range from ¥$41.1 million to ¥$55.5
million, or a change in INPV of ¥4.1
percent to ¥5.5 percent. At this
proposed level, industry free cash flow
is estimated to decrease by
approximately 34.2 percent to $45.9
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million, compared to the base-case
value of $69.7 million in the year
leading up to the proposed energy
conservation standards.
The design options DOE analyzed for
product class 1 include improvements
to standby and active power
consumption (airflow improvements, a
dedicated heater duct, and an open
cylinder drum). While the actual design
path taken by manufacturers could vary
at TSL 3, these technologies represent
incremental improvements and are well
known in the industry. The changes for
design options analyzed for product
class 1 would require both changes to
production equipment and product
development costs. These design
options would not greatly alter the
production process for product class 1
and could be made within most existing
products. The conversion costs to
implement these changes are also
relatively low compared to the total
value of the industry. The industry
impacts would increase at TSL 3,
however, because for product class 1,
manufacturers would have to make
changes for a large volume of the
common standard-size electric models.
TSL 4 represents the baseline
efficiency for product classes 5 and 6.
TSL 4 also represents the same
efficiency requirements for product
classes 2 and 3 as TSL 2 and TSL 3.
TSL 4 also has the same efficiency
requirements for product class 1 as
TSL 3, but represents a 3.30 CEF for
product class 4. At TSL 4, DOE
estimates impacts on INPV to range
¥$64.5 million to ¥$80.6 million, or a
change in INPV of ¥6.4 percent to ¥8.0
percent. At this proposed level, industry
free cash flow is estimated to decrease
by approximately 49.8 percent to $35.0
million, compared to the base-case
value of $69.7 million in the year
leading up to the proposed energy
conservation standards.
The impacts at TSL 4 are due
primarily to the efficiency requirements
for product classes 1 and 4 because all
other product classes are at baseline
efficiency or could be met with changes
to standby power consumption. For
both product classes 1 and 4, DOE
analyzed changes to standby power
consumption and the same
improvements to active mode power
consumption for both gas and electric
units (airflow improvements, a
dedicated heater duct, and an open
cylinder drum). As with TSL 3, while
the actual design path taken by
manufacturers could vary at TSL 4,
these technologies represent
incremental improvements to most
products and are well known in the
industry. Industry impacts would
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increase at TSL 4, however, because for
both product classes 1 and 4, the
changes would require improvements in
the most common standard-size gas and
electric products on the market today.
The changes for design options analyzed
for product class 1 and 4 would require
both changes to production equipment
and product development costs. These
design options would not greatly alter
the production processes for either
product class and could be made within
most existing products. The conversion
costs to implement these changes for
both product class 1 and 4 are still
relatively low compared to the total
value of the industry.
TSL 5 represents a CEF of 4.08 for
product class 1, a CEF of 4.08 for
product class 2, a CEF of 3.60 for
product class 3, a CEF of 3.61 for
product class 4, a CEF of 2.80 for
product class 5, and a CEF of 2.56 for
product class 6. At TSL 5, DOE
estimates impacts on INPV to range
¥$176.5 million to ¥$397.4 million, or
a change in INPV of ¥17.6 percent to
¥39.6 percent. At this proposed level,
industry free cash flow is estimated to
decrease by approximately 249.7
percent to ¥$104.4 million, compared
to the base-case value of $69.7 million
in the year leading up to the proposed
energy conservation standards.
Most of the impacts on INPV at TSL
5 are due to the efficiency requirements
for product classes 1 through 4. Very
few products on the market today meet
the efficiency requirements at TSL 5,
and for product classes 1 through 4, TSL
5 represents the most efficient units
currently on the market. The design
options DOE analyzed for these product
classes included similar design options
for all product classes as for product
classes 1 and 4 at TSL 4 (airflow
improvements, a dedicated heater duct,
and an open cylinder drum) plus
additional changes. In addition to
airflow improvements, a dedicated
heater duct, and an open cylinder drum,
the design options analyzed by DOE
also include modulating heat, inlet air
preheating, and a more efficient fan
motor. Out of all these design options
used the reach the required efficiencies
at TSL 5, inlet air preheating would
require the most substantial changes to
existing products because it would
change the ducting system. This change
would impact drum stamping
equipment and, possibly, the fabrication
of the cabinets for some product lines.
The impacts also increase dramatically
at TSL 5 due to the large increase in
production costs for the additional
design options beyond those needed to
reach the required efficiencies at TSL 4.
The large incremental costs result in
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lower shipments due to the price
elasticity. These additional costs also
cause a greater impact on INPV if
manufactures are unable to earn
additional profit on these added costs
(under the preservation of operating
profit markup scenario).
TSL 6 represents the max-tech level
for all product classes. The max-tech
level corresponds to a CEF of 5.42 for
product class 1, a CEF of 5.41 for
product class 2, a CEF of 4.89 for
product class 3, a CEF of 3.61 for
product class 4, a CEF of 4.03 for
product class 5, and a CEF of 3.69 for
product class 6. At TSL 6, DOE
estimates impacts on INPV to range
¥$303.9 million to ¥$730.0 million, or
a change in INPV of ¥30.3 percent to
¥72.7 percent. At this proposed level,
industry free cash flow is estimated to
decrease by approximately 467.5
percent to ¥$256.2 million, compared
to the base-case value of $69.7 million
in the year leading up to the proposed
energy conservation standards.
At TSL 6, the efficiency requirements
for all electric clothes dryers would
effectively require a heat pump clothes
dryer. Currently, there are no heat pump
clothes dryers on the market in the
United States. Manufacturing
exclusively heat pump clothes dryers
would be extremely disruptive to
existing manufacturing facilities. A heat
pump standard would require a total
renovation of existing facilities and
would force the industry to design
completely new clothes dryer platforms.
The capital conversion costs for these
changes are extremely large—more than
double the capital conversion costs
calculated for these products to meet
TSL 5. The product development costs
to manufacturer heat pump clothes
dryers also increase substantially
because manufacturers must not only
redesign clothes washer platforms, but
also design the heat pump system.
Manufacturers also indicated that
training their service and installation
network to use a completely different
technology would be extremely costly,
as would the cost to educate consumers.
Finally, the impacts on INPV are also
great at TSL 6 because the cost of a heat
pump clothes dryer is more than double
a minimally compliant clothes dryer in
the market today. If manufactures are
unable to earn additional profit on these
production costs, profitability is
severely impacted.
Cash Flow Analysis Results for Room
Air Conditioners
To assess the lower (less severe) end
of the range of potential impacts on the
room air conditioner industry, DOE
modeled the flat markup scenario. The
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flat markup scenario assumes that in the
standards case manufacturers would be
able to pass the higher productions costs
required for more efficient products on
to their customers. Specifically, the
industry would be able to maintain its
average base-case gross margin, as a
percentage of revenue, despite higher
product costs. In general, the larger the
product price increases, the less likely
manufacturers are to achieve the cash
flow from operations calculated in this
scenario because the less likely it is that
manufacturers would be able to fully
markup these larger cost increases.
To assess the higher (more severe) end
of the range of potential impacts on the
room air conditioner industry, DOE
modeled the preservation of operating
profit markup scenario. Through its
discussion with manufacturers, DOE
found that manufacturers are faced with
significant market pressure to keep
prices low. Consumers are accustomed
to certain price points for room air
conditioners, and they could forgo their
purchases if prices increased
significantly because many purchases
are weather-dependent impulse buys.
As a result, several key retailers exert
their purchasing power to pressure
manufacturers to offer product lines at
low prices. Higher efficiency units that
earn a premium in the base case are
bundled with additional features that
drive higher prices. Thus,
manufacturers are skeptical that
customers would accept higher prices
for increased energy efficiency because
it does not command higher margins in
the current market. Under such a
scenario, it follows that the large
retailers that compose the relatively
concentrated customer base of the
industry would not accept
manufacturers fully passing through the
additional cost of improved efficiency
because consumers would be wary of
higher prices. Therefore, to assess the
higher (more severe) end of the range of
potential impacts, DOE modeled the
preservation of operating profit markup
scenario in which higher energy
conservation standards result in lower
manufacturer markups. This markup is
applied to both the minimum standard
level and the de facto minimally
efficient products due to the modeled
efficiency migration over time. This
scenario models manufacturers’
concerns that the higher costs of more
efficient technology would harm
profitability if the full cost increases
cannot be passed on. The scenario
represents the upper end of the range of
potential impacts on manufacturers
because no additional operating profit is
earned on the investments required to
meet the proposed amended energy
conservation standards, while higher
production costs erode profit margins
and result in lower cash flows from
operations.
DOE used the main NIA shipment
scenario for the both the lower- and
higher-bound MIA scenarios that were
used to characterize the potential INPV
impacts. The shipment forecast is an
important driver of the INPV results
below (Table V–21 and Table V–22).
The main NIA shipment scenario
includes a price elasticity effect,
meaning higher prices in the standards
case result in lower shipments. Lower
shipments also reduce industry revenue,
and, in turn, INPV.
TABLE V–21—MANUFACTURER IMPACT ANALYSIS FOR ROOM AIR CONDITIONERS—FLAT MARKUP SCENARIO
Base
case
Units
INPV .....................................
Change in INPV ....................
Trial standard level
1
2
3
4
5
6
Product Conversion Costs ....
Capital Conversion Costs .....
2009$ millions .......................
2009$ millions .......................
% ...........................................
2009$ millions .......................
2009$ millions .......................
956.0 ..
............
............
............
............
911.8
(44.2)
¥4.6%
22
46
890.6
(65.4)
¥6.8%
29
69
890.3
(65.7)
¥6.9%
41
61
844.7
(111.3)
¥11.6%
61
109
869.5
(86.6)
¥9.1%
74
101
875.9
(80.2)
¥8.4%
117
193
Total Conversion Costs ........
2009$ millions .......................
............
68
98
102
171
176
310
TABLE V–22—MANUFACTURER IMPACT ANALYSIS FOR ROOM AIR CONDITIONERS—PRESERVATION OF OPERATING PROFIT
MARKUP SCENARIO
Base
case
Units
1
2
3
4
5
6
Product Conversion Costs ....
Capital Conversion Costs .....
2009$ millions .......................
2009$ millions .......................
% ...........................................
2009$ millions .......................
2009$ millions .......................
956.0 ..
............
............
............
............
871.1
(84.9)
¥8.9%
22
46
843.3
(112.7)
¥11.8%
29
69
843.6
(112.4)
¥11.8%
41
61
778.4
(177.6)
¥18.6%
61
109
771.6
(184.4)
¥19.3%
74
101
611.5
(344.5)
¥36.0%
117
193
Total Conversion Costs ........
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INPV .....................................
Change in INPV ....................
Trial standard level
2009$ millions .......................
............
68
98
102
171
176
310
TSL 1 represents a CEER of 9.30 for
product class 8A (without reverse cycle
and without louvered sides—8,000 to
10,999 Btu/h) and product class 8B
(without reverse cycle and without
louvered sides—11,000 to 13,999 Btu/
h); 9.40 for product class 5A (without
reverse cycle and with louvered sides—
20,000 to 24,999 Btu/h) and product
class 5B (without reverse cycle and with
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louvered sides—25,000 Btu/h and
more); 10.10 for product class 1
(without reverse cycle and with
louvered sides—less than 6,000 Btu/h);
and 10.70 for product class 3 (without
reverse cycle and with louvered sides—
8,000 to 13,999 Btu/h). At TSL 1, DOE
estimates impacts on INPV to range
from ¥$44.2 million to ¥$84.9 million,
or a change in INPV of ¥4.6 percent to
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¥8.9 percent. At this proposed level,
industry free cash flow is estimated to
decrease by approximately 27.7 percent
to $62.4 million, compared to the basecase value of $86.3 million in the year
leading up to the proposed energy
conservation standards.
The INPV impacts at TSL 1 are
relatively minor, in part because the
vast majority of manufacturers produce
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units that exceed this level (such as,
ENERGY STAR and other high
efficiency units) in significant volumes.
Approximately 60 percent of product
class 3 shipments, 85 percent of product
class 5A and 5B shipments, and 90
percent of product class 8A and 8B
shipments currently meet this TSL. By
contrast, the vast majority of product
class 1 shipments are baseline units.
Although most of the design options
DOE analyzed at this proposed level are
one-for-one component swaps, some
more complex design options that
would be required at TSL 1 necessitate
more substantial changes. These design
options that have a significant impact
on conversion costs at TSL 1 are heat
exchanger changes and increased
chassis volumes. Changes to the
condenser or evaporator require
machinery for new dies for every
product line and require greater design
effort than component swaps. Increased
chassis volumes require a complete
redesign of the product and substantial
tooling to make the unit larger.
Although some room air conditioners,
particularly those in product class 1,
will require these changes at TSL 1,
these changes would not be required
across the entire industry because the
majority of units in most product classes
already meet TSL 1. As such, DOE
estimated total product conversion costs
of $22 million and capital conversion
costs of $46 million, which is relatively
low compared to the industry value of
$956 million.
The efficiency requirements for
product class 3, product class 5A,
product class 5B, product class 8A, and
product class 8B are the same at TSL 2
as TSL 1. Thus, the only change from
TSL 1 occurs for product class 1, which
requires a CEER of 10.60 at TSL 2. DOE
estimates the INPV impacts at TSL 2
range from ¥$65.4 million to ¥$112.7
million, or a change in INPV of ¥6.8
percent to ¥11.8 percent. At this
proposed level, the industry cash flow
is estimated to decrease by
approximately 40.5 percent to $51.4
million, compared to the base-case
value of $86.3 million in the year
leading up to the proposed energy
conservation standard.
The additional impacts at TSL 2
relative to TSL 1 result from the further
improvements manufacturers must
make to meet a CEER of 10.6 for product
class 1. Most units in product class 1
would need to increase their chassis
size even further than at TSL 1 in order
to meet TSL 2, resulting in estimated
product and capital conversion costs of
$29 million and $69 million,
respectively.
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TSL 3 represents different efficiency
levels for every product class compared
to TSL 2. TSL 3 represents the baseline
CEERs of 8.47 and 8.48 for product
classes 5A and 5B, respectively,
meaning that no amended standards
would be set and no impacts on INPV
would occur. TSL 3 represents a CEER
of 9.50 for product class 8B, 9.60 for
product class 8A, 10.10 for product
class 1, and 10.90 for product class 3.
DOE estimates the INPV impacts at TSL
3 to range from ¥$65.7 million to
¥$112.4 million, or a change in INPV
of ¥6.9 percent to ¥11.8 percent. At
this proposed level, the industry cash
flow is estimated to decrease by
approximately 40.5 percent to $51.4
million, compared to the base-case
value of $86.3 million in the year
leading up to the standards.
At TSL 3, several product classes
require design options that increase
conversion costs. For product class 1,
some units would require increased
chassis volumes, though not as
substantially as at TSL 2. For product
class 3, all smaller units would require
chassis changes, driving the majority of
the conversion costs at TSL 3. For
product classes 8A and 8B, some
changes to the heat exchangers would
be required. However, no conversion
costs would be applied to product
classes 5A and 5B, resulting in total
product and capital conversion costs at
TSL 3 of $41 million and $61 million,
respectively.
TSL 4 represents the same efficiency
requirements as TSL 3 for product
classes 3, 8A, and 8B. For product class
5B, TSL 4 represents a CEER of 9.00. For
product class 5A, TSL 4 represents a
CEER of 9.40, and for product class 1,
TSL 4 represents a CEER of 11.10. DOE
estimates the INPV impacts at TSL 4 to
range from ¥$111.3 million to ¥$177.6
million, or a change in INPV of ¥11.6
percent to ¥18.6 percent. At this
proposed level, the industry cash flow
is estimated to decrease by
approximately 69.1 percent to $26.7
million, compared to the base-case
value of $86.3 million in the year
leading up to the proposed energy
conservation standards.
At TSL 4, significant changes to the
manufacturing process would be
required. Product classes 1, 5A, and 5B
would all require increased chassis
volumes, and product classes 1 and 5A
would also require heat exchanger
changes. These design options drive
increases of $20 million in product
conversion costs and $48 million in
capital conversion costs compared to
TSL 3.
TSL 5 represents the same efficiency
requirements as TSL 4 for product
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classes 1 and 8B. For product classes 5A
and 5B, TSL 5 represents the baseline
CEERs of 8.47 and 8.48, respectively, so
all impacts of TSL 4 on these product
classes, such as chassis changes, would
not be required. For product class 8A,
TSL 5 represents a CEER of 10.00, and
for product class 3, TSL 5 represents a
CEER of 11.50. DOE estimates the INPV
impacts at TSL 5 to range from ¥$86.6
million to ¥$184.4 million, or a change
in INPV of ¥9.1 percent to ¥19.3
percent. At this proposed level, the
industry cash flow is estimated to
decrease by approximately 69.3 percent
to $26.5 million, compared to the basecase value of $86.3 million in the year
leading up to the proposed energy
conservation standards.
At TSL 5, impacts are negative under
both scenarios due to the high
conversion costs that exist at TSL 5.
Although capital conversion costs
would be $8 million lower at TSL 5 than
at TSL 4 due to the removal of any
capital costs associated with product
classes 5A and 5B (despite higher
capital costs for product class 3),
product conversion costs are $13
million higher at TSL 5 compared to
TSL 4 because a greater number of
product lines would need to be
redesigned at this level.
TSL 6 represents max-tech for all
room air conditioners. The max-tech
level corresponds to CEERs of 9.80,
10.02, 10.15, 10.35, 11.67, and 11.96 for
product classes 5B, 8B, 5A, 8A, 1, and
3, respectively. DOE estimates the INPV
impacts at TSL 6 to range from ¥$80.2
million to ¥$344.5 million, or a change
in INPV of ¥8.4 percent to ¥36.0
percent. At this proposed level, the
industry cash flow is estimated to
decrease by 124.8 percent to ¥$21.4
million, compared to the base-case
value of $86.3 million in the year
leading up to the proposed energy
conservation standards.
At TSL 6, all products would need to
be fully redesigned, resulting in large
product and capital conversion costs of
$117 million and $193 million,
respectively. These conversion costs are
mostly driven by the high-volume
product classes 1 and 3 and their
associated chassis and heat exchanger
changes.
b. Impacts on Employment
Clothes Dryer Employment Impacts
For clothes dryers, DOE used the
GRIM to estimate the domestic labor
expenditures and number of domestic
production workers in the base case and
at each TSL from 2011 to 2043. DOE
used statistical data from the most
recent U.S. Census Bureau’s 2008
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‘‘Annual Survey of Manufacturers,’’ the
results of the engineering analysis, and
interviews with manufacturers to
determine the inputs necessary to
calculate industry-wide labor
expenditures and domestic employment
levels. Labor expenditures for the
manufacture of a product are a function
of the labor intensity of the product, the
sales volume, and an assumption that
wages in real terms remain constant.
In the GRIM, DOE used the labor
content of each product and the
manufacturing production costs from
the engineering analysis to estimate the
annual labor expenditures in the clothes
dryers and room air conditioner
industries. DOE used Census data and
interviews with manufacturers to
estimate the portion of the total labor
expenditures that is attributable to
domestic labor.
The production worker estimates in
this section only cover workers up to
the line-supervisor level who are
directly involved in fabricating and
assembling a product within an Original
Equipment Manufacturer (OEM) facility.
Workers performing services that are
closely associated with production
operations, such as material handing
with a forklift, are also included as
production labor. DOE’s estimates
account only for production workers
who manufacture the specific products
covered by this rulemaking.
The employment impacts shown in
Table V–23 represent the potential
production employment that could
result following amended energy
conservation standards. The upper end
of the results in this table estimates the
total potential increase in the number of
production workers after amended
energy conservation standards. To
calculate the total potential increase,
DOE assumed that manufacturers
continue to produce the same scope of
covered products in domestic
production facilities and domestic
production is not shifted to lower-laborcost countries. Because there is a real
risk of manufacturers evaluating
sourcing decisions in response to
amended energy conservation
standards, the lower end of the range of
employment results in Table V–23
includes the estimated total number of
U.S. production workers in the industry
who could lose their jobs if all existing
22539
production were moved outside of the
United States. While the results present
a range of employment impacts
following the compliance date of
amended energy conservation
standards, the discussion below also
includes a qualitative discussion of the
likelihood of negative employment
impacts at the various TSLs. Finally, the
employment impacts shown are
independent of the employment impacts
from the broader U.S. economy, which
are documented in chapter 13 of the
direct final rule TSD.
Using the GRIM, DOE estimates that
in the absence of amended energy
conservation standards, there would be
4,426 domestic production workers
involved in manufacturing residential
clothes dryers in 2014. Using 2008
Census Bureau data and interviews with
manufacturers, DOE estimates that
approximately three-quarters of clothes
dryers sold in the United States are
manufactured domestically. Table V–23
shows the range of the impacts of
potential amended energy conservation
standards on U.S. production workers in
the clothes dryer industry.
TABLE V–23—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC CLOTHES DRYER PRODUCTION WORKERS IN
2014
Base case
Total Number of Domestic Production Workers in 2014 (without changes in production locations) .........................................
Potential Changes in Domestic
Production Workers in 2014 * ...
1
2
3
4
5
6
3,962
3,962
3,965
4,370
4,420
5,040
6,218
....................
0–(3,962)
3–(3,962)
408–(3,962)
458–(3,962)
1,078–(3,962)
2,256–(3,962)
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* DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative numbers.
All examined TSLs show relatively
minor impacts on domestic employment
levels at the lower end of the range. In
particular, the design options used in
the engineering analysis for TSL 1 and
TSL 2 almost exclusively involve
changes to standby power. These TSLs
would not measurably impact domestic
employment levels.
At TSL 3 through TSL 5, DOE
analyzed design options for the most
common product classes that would add
labor content to the final product. If
manufacturers continue to produce
these more complex products in house,
it is likely that employment would
increase in response to the energy
conservation standards. At TSL 3
through 5, greater levels of domestic
production employment are also likely
because, while requiring more labor, the
product changes could be made within
existing platforms. The ability to make
product changes within existing
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platforms mitigates some of the pressure
to find lower labor costs because this
decision would add disruptions with
suppliers and add capital costs.
However, TSL 6 would effectively
require heat pump clothes dryers for all
electric units. Manufacturers indicated
that such a drastic change to existing
products could force them to consider
moving domestic production to
countries with lower labor costs.
Besides the large capital conversion
costs, the much higher labor content in
heat pump clothes dryers would also
put pressure on manufacturers to
consider a lower-labor-cost country.
Room Air Conditioner Employment
Impacts
DOE’s research suggests that currently
no room air conditioners are made
domestically. All manufacturers or their
domestic distributors do maintain
offices in the United States to handle
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design, technical support, training,
certification, and other requirements. As
amended energy conservation standards
for room air conditioners are
implemented, however, DOE does not
anticipate any changes in domestic
employment levels.
c. Impacts on Manufacturing Capacity
Clothes Dryers
At TSL 1 through TSL 5,
manufacturers could maintain capacity
levels and continue to meet market
demand under amended energy
conservation standards. While the
changes required at these TSLs would
require changes that could be made
within most existing designs, TSL 6,
which would effectively require heat
pump technology, could result in shortterm capacity constraints. Significant
changes to production facilities would
be required if amended energy
conservation standards effectively
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Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
mandated heat pump clothes dryers at
TSL 6. Several manufacturers stated that
they could move all or part of their
production if they were required to
exclusively manufacture heat pump
clothes dryers. Because of these drastic
changes, a 3-year time period between
the announcement of the final rule and
the compliance date of the amended
energy conservation standard might not
be sufficient to design and manufacture
products that have yet to be introduced
in the United States and which would
require new dryer designs from each
manufacturer that continued to offer
electric clothes dryers for the United
States market.
Room Air Conditioners
mstockstill on DSKH9S0YB1PROD with RULES2
DOE anticipates that amended energy
conservation standards would not
significantly affect the production
capacity of room air conditioner
manufacturers. Manufacturers
mentioned two issues that could
potentially constrain capacity. One is
the availability of high efficiency
compressors, which are currently
difficult to obtain. Because amended
energy conservation standards would
cause the demand for high efficiency
compressors to increase, manufacturers
worried that they would not be able to
obtain the quantities they need to
maintain desired production levels.
DOE understands that compressor
availability is a concern at present. DOE
does not believe this shortage will
continue when amended standards take
effect in 2014 because the number of R–
410A compressors available for the
room air conditioner industry has
already greatly expanded since the ban
on R–22 took effect. Because there is a
3-year delay between the announcement
of the final rule and the compliance date
of the amended energy conservation
standard, DOE believes suppliers will
have sufficient time to anticipate
demand and ramp up production of
high efficiency compressors for room air
conditioners.
The second potential capacity
constraint involves changes to existing
chassis sizes, which could be required
by amended energy conservation
standards. Manufacturers stated that
increasing chassis volume requires
significant product development and
capital investments, which could
severely disrupt production at their
facilities. DOE understands that
increasing chassis volume causes
substantial conversion costs, which are
quantified in the GRIM. DOE does not
believe, however, that the proposed
standards would significantly affect
production capacity. Even though
chassis size increases require large
capital and product conversion costs,
this design option is not required across
all analyzed product classes. In
addition, manufacturers were more
concerned about the capital and product
conversion costs to make these changes
than having a three year implementation
period to do so, and DOE has accounted
for these costs in the establishment of
the room air conditioner standards. DOE
believes that room air conditioner
manufacturers will be able to increase
chassis volumes by 2014 while
maintaining production capacity levels
and continuing to meet market demand
for all room air conditioner standard
levels.
d. Impacts on Sub-Groups of
Manufacturers
Using average cost assumptions to
develop an industry cash-flow estimate
is not adequate for assessing differential
impacts among manufacturer subgroups.
Small manufacturers, niche equipment
manufacturers, and manufacturers
exhibiting a cost structure substantially
different from the industry average
could be affected disproportionately.
While DOE analyzed the impacts to
small business in section VI.B, DOE did
not identify any other subgroups for
clothes dryers or room air conditioners
for this rulemaking based on the results
of the industry characterization.
e. Cumulative Regulatory Burden
While any one regulation may not
impose a significant burden on
manufacturers, the combined effects of
several impending regulations may have
serious consequences for some
manufacturers, groups of manufacturers,
or an entire industry. Assessing the
impact of a single regulation may
overlook this cumulative regulatory
burden. In addition to energy
conservation standards, other
regulations can significantly affect
manufacturers’ financial operations.
Multiple regulations affecting the same
manufacturer can strain profits and can
lead companies to abandon product
lines or markets with lower expected
future returns than competing products.
For these reasons, DOE conducts an
analysis of cumulative regulatory
burden as part of its rulemakings
pertaining to appliance efficiency.
During previous stages of this
rulemaking DOE identified a number of
requirements, in addition to amended
energy conservation standards for
clothes dryers and room air
conditioners, with which manufacturers
of these products will be required to
comply. Manufacturers provided
comment on some of these regulations
during the preliminary analysis period,
including UL 2158, which deals with
fire containment in electric clothes
dryers, and the Montreal Protocol,
which banned R–22 refrigerant in new
room air conditioners. DOE summarizes
and addresses these comments in
section IV.I.3.b and provides additional
details of the cumulative regulatory
burden analysis in chapter 12 of the
direct final rule TSD.
3. National Impact Analysis
a. Significance of Energy Savings
To estimate the energy savings
through 2043 attributable to potential
standards for clothes dryers and room
air conditioners, DOE compared the
energy consumption of these products
under the base case to their anticipated
energy consumption under each TSL.
As discussed in section IV.E, the results
account for a rebound effect of 15
percent for room air conditioners (that
is, 15 percent of the total savings from
higher product efficiency are ‘‘taken
back’’ by consumers through more
intensive use of the product).
Table V–24 and Table V–25 present
DOE’s forecasts of the national energy
savings for each TSL for clothes dryers
and room air conditioners, respectively.
The savings were calculated using the
approach described in section IV.G.
Chapter 10 of the direct final rule TSD
presents tables that also show the
magnitude of the energy savings if the
savings are discounted at rates of 7 and
3 percent. Discounted energy savings
represent a policy perspective in which
energy savings realized farther in the
future are less significant than energy
savings realized in the nearer term.
TABLE V–24—CLOTHES DRYERS: CUMULATIVE NATIONAL ENERGY SAVINGS IN QUADS
Trial standard level
Product class
1
Vented Electric Standard .........................................................
Vented Electric Compact 120V ................................................
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2
0.000
0.000
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0.038
0.000
3
4
0.347
0.000
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5
6
0.347
0.000
1.268
0.002
2.923
0.003
Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
22541
TABLE V–24—CLOTHES DRYERS: CUMULATIVE NATIONAL ENERGY SAVINGS IN QUADS—Continued
Trial standard level
Product class
1
Vented Electric Compact 240V ................................................
Vented Gas ..............................................................................
Ventless Electric Compact 240V .............................................
Ventless Electric Combination Washer/Dryer ..........................
2
3
4
5
6
0.000
0.000
0.000
0.000
0.001
0.009
0.002
0.011
0.001
0.038
0.000
0.000
0.006
0.164
0.004
0.011
0.016
0.164
0.016
0.023
0.00
Total ..................................................................................
0.001
0.009
0.002
0.011
0.062
0.37
0.386
1.455
3.145
TABLE V–25—ROOM AIR CONDITIONERS: CUMULATIVE NATIONAL ENERGY SAVINGS IN QUADS
Trial standard level
Product class
1
Group
Group
Group
Group
Group
Group
1—includes
2—includes
3—includes
4—includes
5—includes
6—includes
PC
PC
PC
PC
PC
PC
2
3
4
5
6
1 ..........................................................
2, 3, 4, 11 ...........................................
5A, 9, 13 .............................................
5B, 10 .................................................
6, 7, 8A, 12 .........................................
8B, 14, 15, 16 .....................................
0.046
0.051
0.001
0.000
0.004
0.002
0.083
0.115
0.001
0.000
0.004
0.002
0.046
0.161
0.000
0.000
0.006
0.004
0.133
0.161
0.001
0.000
0.006
0.004
0.133
0.327
0.000
0.000
0.014
0.004
0.171
0.445
0.008
0.003
0.021
0.016
Total ..................................................................................
0.105
0.205
0.218
0.305
0.477
0.665
DOE also performed a sensitivity to
investigate the impact of adding the
rebound effect on the NES for the six
energy efficiency TSLs for clothes
dryers in appendix 10–C of the TSD. As
described in more detail in the TSD, at
least one study estimated a potential
rebound effective of 5 percent for
clothes dryers. The NES results for this
sensitively show a consistent, small
decrease in potential energy savings
from a standard. (Refer to section IV.E
for a discussion of the rebound effect.)
DOE recognizes that there may be
forms of direct consumer rebound that
have not been measured in previous
studies. For example, if automatic
termination of clothes dryer cycles
leaves clothes feeling humid or damp,
then consumers may change to longer
timed drying cycles. DOE is addressing
this type of rebound effect in updates of
its clothes dryer test procedure which
provides for a field use factor that
relates tested clothes dryer energy use to
in-field energy use. If DOE detects a
significant rebound effect from changing
characteristics of clothes dryers, DOE
will consider such effects in updates of
its test procedure regulations and in
future amendments to the energy
conservation standards, as appropriate.
b. Net Present Value of Consumer Costs
and Benefits
DOE estimated the cumulative NPV to
the nation of the total costs and savings
for consumers that would result from
particular standard levels for clothes
dryers and room air conditioners. In
accordance with the OMB’s guidelines
on regulatory analysis (OMB Circular
A–4, section E, September 17, 2003),
DOE calculated NPV using both a
7-percent and a 3-percent real discount
rate. The 7-percent rate is an estimate of
the average before-tax rate of return to
private capital in the U.S. economy, and
reflects the returns to real estate and
small business capital as well as
corporate capital. DOE used this
discount rate to approximate the
opportunity cost of capital in the private
sector, since recent OMB analysis has
found the average rate of return to
capital to be near this rate. In addition,
DOE used the 3-percent rate to capture
the potential effects of standards on
private consumption (for example,
through higher prices for products and
the purchase of reduced amounts of
energy). This rate represents the rate at
which society discounts future
consumption flows to their present
value. This rate can be approximated by
the real rate of return on long-term
government debt (that is, yield on
Treasury notes minus annual rate of
change in the Consumer Price Index),
which has averaged about 3 percent on
a pre-tax basis for the last 30 years.
Table V–26 through Table V–29 show
the consumer NPV results for each TSL
DOE considered for clothes dryers and
room air conditioners, using both a
7-percent and a 3-percent discount rate.
In each case, the impacts cover the
lifetime of products purchased in 2014–
2043. See chapter 10 of the direct final
rule TSD for more detailed NPV results.
TABLE V–26—CUMULATIVE NET PRESENT VALUE OF CONSUMER BENEFITS FOR CLOTHES DRYERS, 3-PERCENT DISCOUNT
RATE
Trial standard level
Product class
mstockstill on DSKH9S0YB1PROD with RULES2
1
2
3
4
5
6
Billion 2009$
Vented Electric Standard .........................................................
Vented Electric Compact 120V ................................................
Vented Electric Compact 240V ................................................
Vented Gas ..............................................................................
Ventless Electric Compact 240V .............................................
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0.00
0.00
0.00
0.00
0.00
Fmt 4701
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0.40
0.005
0.014
0.094
0.019
2.779
0.005
0.014
0.094
0.019
E:\FR\FM\21APR2.SGM
21APR2
2.779
0.005
0.014
0.215
0.00
2.125
¥0.013
¥0.066
¥1.906
¥0.010
0.563
¥0.029
¥0.12
¥1.906
¥0.036
22542
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TABLE V–26—CUMULATIVE NET PRESENT VALUE OF CONSUMER BENEFITS FOR CLOTHES DRYERS, 3-PERCENT DISCOUNT
RATE—Continued
Trial standard level
Product class
1
2
3
4
5
6
Billion 2009$
Ventless Electric Combination Washer/Dryer ..........................
0.00
0.086
0.086
0.00
0.086
0.00
Total ..................................................................................
0.00
0.619
2.998
3.013
0.216
¥1.528
TABLE V–27—CUMULATIVE NET PRESENT VALUE OF CONSUMER BENEFITS FOR CLOTHES DRYERS, 7-PERCENT DISCOUNT
RATE
Trial standard level
Product class
1
2
3
4
5
6
Billion 2009$
Vented Electric Standard .........................................................
Vented Electric Compact 120V ................................................
Vented Electric Compact 240V ................................................
Vented Gas ..............................................................................
Ventless Electric Compact 240V .............................................
Ventless Electric Combination Washer/Dryer ..........................
0.00
0.00
0.00
0.00
0.00
0.00
0.168
0.002
0.006
0.039
0.008
0.031
1.017
0.002
0.006
0.039
0.008
0.031
1.017
0.002
0.006
0.051
0.00
0.00
¥1.079
¥0.011
¥0.051
¥1.474
¥0.013
0.031
¥5.025
¥0.024
¥0.101
¥1.474
¥0.050
¥0.043
Total ..................................................................................
0.00
0.254
1.104
1.076
¥2.596
¥6.716
TABLE V–28—CUMULATIVE NET PRESENT VALUE OF CONSUMER BENEFITS FOR ROOM AIR CONDITIONERS, 3-PERCENT
DISCOUNT RATE
Trial standard level
Product class
1
2
3
4
5
6
Billion 2009$
1 ..........................................................
2, 3, 4, 11 ...........................................
5A, 9, 13 .............................................
5B, 10 .................................................
6, 7, 8A, 12 .........................................
8B, 14, 15, 16 .....................................
0.276
0.427
¥0.001
¥0.002
0.036
0.011
0.362
0.902
¥0.003
¥0.008
0.036
0.011
0.276
1.162
0.00
0.00
0.049
0.024
0.245
1.162
¥0.003
¥0.002
0.049
0.024
0.245
1.121
0.00
0.00
0.066
0.024
¥1.838
¥2.374
¥0.481
¥0.229
¥0.379
¥0.314
Total ..................................................................................
0.747
1.30
1.511
1.474
1.456
¥5.616
Group
Group
Group
Group
Group
Group
1—includes
2—includes
3—includes
4—includes
5—includes
6—includes
PC
PC
PC
PC
PC
PC
TABLE V–29—CUMULATIVE NET PRESENT VALUE OF CONSUMER BENEFITS FOR ROOM AIR CONDITIONERS, 7-PERCENT
DISCOUNT RATE
Trial standard level
Product class
1
2
3
4
5
6
Billion 2009$
1 ..........................................................
2, 3, 4, 11 ...........................................
5A, 9, 13 .............................................
5B, 10 .................................................
6, 7, 8A, 12 .........................................
8B, 14, 15, 16 .....................................
0.117
0.21
¥0.002
¥0.002
0.019
0.006
0.12
0.438
¥0.003
¥0.006
0.019
0.006
0.117
0.558
0.00
0.00
0.025
0.012
¥0.02
0.558
¥0.003
¥0.002
0.025
0.012
¥0.02
0.307
0.00
0.00
0.029
0.012
¥1.386
¥2.084
¥0.317
¥0.169
¥0.262
¥0.223
Total ..................................................................................
0.349
0.575
0.712
0.57
0.328
¥4.441
mstockstill on DSKH9S0YB1PROD with RULES2
Group
Group
Group
Group
Group
Group
1—includes
2—includes
3—includes
4—includes
5—includes
6—includes
PC
PC
PC
PC
PC
PC
DOE investigated the impact of
different learning rates on the NPV for
the six energy efficiency TSLs for room
air conditioners and clothes dryers. The
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18:27 Apr 20, 2011
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NPV results presented above in Table
V.26 to Table V.29 are based on learning
rates of 38.9% for room air conditioners
and 41.6% for clothes dryers, both of
PO 00000
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Sfmt 4700
which are referred to as the ‘‘default’’
learning rates. DOE considered three
learning rate sensitivities: (1) A ‘‘high
learning’’ rate; (2) a ‘‘low learning’’ rate;
E:\FR\FM\21APR2.SGM
21APR2
Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
and (3) a ‘‘no learning’’ rate. In addition,
for clothes dryers there is a fourth
sensitivity: ‘‘Clothes Dryers Only’’. The
‘‘high learning’’ rates are 41.4-percent for
room air conditioners and 42.9-percent
for clothes dryers. The ‘‘low learning’
rates are 31.0-percent for room air
conditioners and 33.9-percent for
clothes dryers. The ‘‘no learning’’ rate
sensitivity, which is zero-percent for all
products, assumes constant real prices
over the entire forecast period. For
clothes dryers, ‘‘clothes dryers only’’ is
based on limited set of historical price
data specifically for clothes dryers and
the learning rate is 52.2-percent. Refer to
section IV.F.1 for details on the
development of the above learning rates.
For room air conditioners, Table V.31
provides the annualized NPV of
consumer benefits at a 7-percent
discount rate for each of the six energy
efficiency TSLs for the ‘‘default’’
learning rate and the three sensitivity
cases. Table V.32 provides the same
annualized NPVs but at a 3-percent
discount rate. For clothes dryers, Table
V.33 provides the annualized NPV of
consumer benefits at a 7-percent
discount rate for each of the six energy
efficiency TSLs for the ‘‘default’’
learning rate and the four sensitivity
22543
cases. Table V.34 provides the same
annualized NPVs but at a 3-percent
discount rate. Included as part of the
annualized NPV in Table V.31 through
Table V.34 is the annualized present
value of monetized benefits from CO2
and NOX emissions reductions. Section
V.B.6 below provides a complete
description and summary of the
monetized benefits from CO2 and NOX
emissions reductions. For details on the
development of the learning rate
sensitivities and the corresponding NPV
results, see appendix 10–C of the final
rule TSD.
TABLE V–30—ROOM AIR CONDITIONERS: ANNUALIZED NET PRESENT VALUE OF CONSUMER BENEFITS INCLUDING
ANNUALIZED PRESENT VALUE OF MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS FOR ENERGY
EFFICIENCY TSLS FOR PRODUCTS SHIPPED IN 2014–2043
[3 Percent discount rate]
Trial standard level
Learning rate (LR)
Default:
LRRoomAC = 38.9%
Low sensitivity:
LRRoomAC = 31.0%
High sensitivity:
LRRoomAC = 41.4%
No learning:
LR = 0%
(constant real
prices)
Billion 2009$
1
2
3
4
5
6
...............................................................................................
...............................................................................................
...............................................................................................
...............................................................................................
...............................................................................................
...............................................................................................
0.079
0.080
0.092
0.096
0.106
(0.241)
0.075
0.076
0.088
0.088
0.091
(0.289)
0.081
0.082
0.093
0.098
0.111
(0.226)
0.059
0.061
0.072
0.061
0.037
(0.463)
Parentheses indicate negative (¥) values.
TABLE V–31—ROOM AIR CONDITIONERS: ANNUALIZED NET PRESENT VALUE OF CONSUMER BENEFITS INCLUDING
ANNUALIZED PRESENT VALUE OF MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS FOR ENERGY
EFFICIENCY TSLS FOR PRODUCTS SHIPPED IN 2014–2043
[7 Percent discount rate]
Trial standard level
Learning rate (LR)
Default:
LRRoomAC = 38.9%
Low sensitivity:
LRRoomAC = 31.0%
High sensitivity:
LRRoomAC = 41.4%
No learning:
LR = 0%
(constant real
prices)
Billion 2009$
1
2
3
4
5
6
...............................................................................................
...............................................................................................
...............................................................................................
...............................................................................................
...............................................................................................
...............................................................................................
0.059
0.060
0.072
0.066
0.058
(0.313)
0.055
0.057
0.068
0.060
0.045
(0.355)
Sfmt 4700
E:\FR\FM\21APR2.SGM
0.060
0.061
0.073
0.069
0.062
(0.300)
mstockstill on DSKH9S0YB1PROD with RULES2
Parentheses indicate negative (¥) values.
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21APR2
0.041
0.043
0.056
0.037
(0.000)
(0.502)
22544
Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
TABLE V–32—CLOTHES DRYER: ANNUALIZED NET PRESENT VALUE OF CONSUMER BENEFITS INCLUDING ANNUALIZED
PRESENT VALUE OF MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS FOR ENERGY EFFICIENCY
TSLS FOR PRODUCTS SHIPPED IN 2014–2043
[3 Percent discount rate]
Trial standard level
Learning rate (LR)
Low sensitivity:
LRCD = 33.9%
Default:
LRCD = 41.6%
High sensitivity:
LRCD = 42.9%
No learning: LR =
0%
(constant real
prices)
Sensitivity
(Clothes dryers
only):
LR = 52.2%
Billion 2009$
1
2
3
4
5
6
.............................................................
.............................................................
.............................................................
.............................................................
.............................................................
.............................................................
0.001
0.036
0.178
0.180
0.110
0.185
0.001
0.036
0.173
0.175
0.033
0.018
0.001
0.036
0.179
0.181
0.121
0.209
0.001
0.035
0.158
0.156
(0.220)
(0.531)
0.001
0.036
0.183
0.186
0.199
0.378
Parentheses indicate negative (¥) values.
TABLE V–33—CLOTHES DRYER: ANNUALIZED NET PRESENT VALUE OF CONSUMER BENEFITS INCLUDING ANNUALIZED
PRESENT VALUE OF MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS FOR ENERGY EFFICIENCY
TSLS FOR PRODUCTS SHIPPED IN 2014–2043
[7 Percent discount rate]
Trial standard level
Learning rate (LR)
Default:
LRCD = 41.6%
Low Sensitivity:
LRCD = 33.9%
No Learning:
LR = 0%
(constant real
prices)
High Sensitivity:
LRCD = 42.9%
Sensitivity
(Clothes Dryers
Only):
LR = 52.2%
Billion 2009$
1
2
3
4
5
6
.............................................................
.............................................................
.............................................................
.............................................................
.............................................................
.............................................................
0.001
0.025
0.114
0.113
(0.111)
(0.282)
0.001
0.024
0.110
0.108
(0.176)
(0.421)
0.001
0.025
0.114
0.113
(0.103)
(0.263)
0.001
0.024
0.098
0.094
(0.375)
(0.853)
0.001
0.025
0.118
0.118
(0.041)
(0.130)
Parentheses indicate negative (¥) values.
c. Impacts on Employment
DOE develops estimates of the
indirect employment impacts of
potential standards on the economy in
general. As discussed above, DOE
expects energy conservation standards
for clothes dryers and room air
conditioners to reduce energy bills for
consumers of these products, and the
resulting net savings to be redirected to
other forms of economic activity. These
expected shifts in spending and
economic activity could affect the
demand for labor. As described in
section IV.J, to estimate these effects
DOE used an input/output model of the
U.S. economy. Table V–34 presents the
estimated net indirect employment
impacts in 2020 and 2043 for the TSLs
that DOE considered in this rulemaking.
Chapter 13 of the direct final rule TSD
presents more detailed results.
TABLE V–34—NET INCREASE IN JOBS FROM INDIRECT EMPLOYMENT EFFECTS UNDER CLOTHES DRYER AND ROOM AIR
CONDITIONER TRIAL STANDARD LEVELS
Thousands
mstockstill on DSKH9S0YB1PROD with RULES2
TSL 1
Residential Clothes Dryers:
2020 ..................................................
2043 ..................................................
Room Air Conditioners:
2020 ..................................................
2043 ..................................................
16:58 Apr 20, 2011
Jkt 223001
TSL 3
TSL 4
TSL 5
TSL 6
0.00
0.01
0.00
0.01
0.41
1.82
0.36
1.75
¥1.37
4.25
¥3.16
9.30
0.90
0.74
The input/output model suggests that
today’s proposed standards are likely to
increase the net demand for labor in the
VerDate Mar<15>2010
TSL 2
0.88
0.73
0.97
0.74
1.34
1.16
2.04
1.94
3.22
3.07
economy. The projected gains are very
small, however, relative to total national
employment (currently approximately
PO 00000
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Sfmt 4700
120 million). Moreover, neither the BLS
data nor the input/output model DOE
E:\FR\FM\21APR2.SGM
21APR2
Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
uses includes the quality or wage level
of the jobs.
5. Impact of Any Lessening of
Competition
4. Impact on Utility or Performance of
Products
DOE has also considered any
lessening of competition that is likely to
result from amended standards. The
Attorney General determines the
impact, if any, of any lessening of
competition likely to result from a
proposed standard, and transmits such
determination to DOE, together with an
analysis of the nature and extent of such
impact. (42 U.S.C. 6295(o)(2)(B)(i)(V)
and (B)(ii))
DOE published an NOPR containing
energy conservation standards identical
to those set forth in today’s direct final
rule and transmitted a copy of today’s
direct final rule and the accompanying
TSD to the Attorney General, requesting
that the DOJ provide its determination
As presented in section III.D.1.d of
this notice, DOE concluded that none of
the TSLs considered in this notice
would reduce the utility or performance
of the clothes dryers or room air
conditioners under consideration in this
rulemaking. DOE also notes that
manufacturers of these products
currently offer clothes dryers and room
air conditioners that meet or exceed
today’s standards. (42 U.S.C.
6295(o)(2)(B)(i)(IV))
22545
on this issue. DOE will consider DOJ’s
comments on the rule in determining
whether to proceed with the direct final
rule. DOE will also publish and respond
to DOJ’s comments in the Federal
Register in a separate notice.
6. Need of the Nation To Conserve
Energy
An improvement in the energy
efficiency of the products subject to
today’s rule is likely to improve the
security of the nation’s energy system by
reducing overall demand for energy.
Reduced electricity demand may also
improve the reliability of the electricity
system. As a measure of this reduced
demand, Table V–35 presents the
estimated reduction in electricity
generating capacity in 2043 for the TSLs
that DOE considered in this rulemaking.
TABLE V–35—REDUCTION IN ELECTRIC GENERATING CAPACITY IN 2043 UNDER CLOTHES DRYER AND ROOM AIR
CONDITIONER TRIAL STANDARD LEVELS
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
TSL 6
Gigawatts
Clothes Dryers .........................................
Room Air Conditioners .............................
0.002
0.348
Energy savings from amended
standards for clothes dryers and room
air conditioners are expected to produce
environmental benefits in the form of
reduced emissions of air pollutants and
greenhouse gases associated with
electricity production. Table V–36
provides DOE’s estimate of cumulative
CO2, NOX, and Hg emissions reductions
that would be expected to result from
0.060
0.429
0.358
0.436
the TSLs considered in this rulemaking.
In the environmental assessment
(chapter 15 of the direct final rule TSD),
DOE reports annual CO2, NOX, and Hg
emissions reductions for each TSL.
As discussed in section IV.L, DOE has
not reported SO2 emissions reductions
from power plants because there is
uncertainty about the effect of energy
conservation standards on the overall
0.345
0.632
1.27
1.01
2.27
1.46
level of SO2 emissions in the United
States due to SO2 emissions caps. DOE
also did not include NOX emissions
reduction from power plants in States
subject to CAIR because an energy
conservation standard would not affect
the overall level of NOX emissions in
those States due to the emissions caps
mandated by CAIR.
TABLE V–36—EMISSIONS REDUCTION ESTIMATED FOR CLOTHES DRYER AND ROOM AIR CONDITIONER TRIAL STANDARD
LEVELS
[Cumulative for 2014 through 2043]
TSL 1
mstockstill on DSKH9S0YB1PROD with RULES2
Clothes Dryers:
CO2 million metric tons .........
NOX thousand tons ...............
Hg tons .................................
Room Air Conditioners:
CO2 million metric tons .........
NOX thousand tons ...............
Hg tons .................................
16:58 Apr 20, 2011
Jkt 223001
TSL 3
TSL 4
TSL 5
TSL 6
0.119
0.097
0.000
2.99
2.41
0.009
17.75
14.26
0.053
18.67
15.14
0.051
70.47
57.26
0.188
186.6
151.3
0.569
9.83
8.02
0.012
DOE also estimated monetary benefits
likely to result from the reduced
emissions of CO2 and NOX that DOE
estimated for each of the TSLs
considered for clothes dryers and room
air conditioners. In order to make this
calculation similar to the calculation of
the NPV of consumer benefit, DOE
considered the reduced emissions
VerDate Mar<15>2010
TSL 2
11.88
9.69
0.015
12.49
10.2
0.017
17.4
14.2
0.022
26.89
21.91
0.032
37.68
30.69
0.044
expected to result over the lifetime of
products shipped in 2014–2043. Thus,
the emissions reductions extend past
2043.
As discussed in section IV.M, DOE
used values for the SCC developed by
an interagency process. The four values
for CO2 emissions reductions resulting
from that process (expressed in 2009$)
PO 00000
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Fmt 4701
Sfmt 4700
are $4.9/ton (the average value from a
distribution that uses a 5-percent
discount rate), $22.1/ton (the average
value from a distribution that uses a 3percent discount rate), $36.3/ton (the
average value from a distribution that
uses a 2.5-percent discount rate), and
$67.1/ton (the 95th-percentile value
from a distribution that uses a 3-percent
E:\FR\FM\21APR2.SGM
21APR2
22546
Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
discount rate). These values correspond
to the value of emission reductions in
2010; the values for later years are
higher due to increasing damages as the
magnitude of climate change increases.
For each of the four cases, DOE
calculated a present value of the stream
of annual values using the same
discount rate as was used in the studies
upon which the dollar-per-ton values
are based. Table V–37 and Table V–38
present the global values of CO2
emissions reductions at each TSL. DOE
calculated domestic values as a range
from 7 percent to 23 percent of the
global values, and these results are
presented in Table V–39 and Table
V–40.
TABLE V–37—CLOTHES DRYERS: ESTIMATES OF GLOBAL PRESENT VALUE OF CO2 EMISSIONS REDUCTION UNDER TRIAL
STANDARD LEVELS
Million 2009$
TSL
1
2
3
4
5
6
5% discount rate,
average *
3% discount rate,
average *
1
15
88
93
351
929
3
79
465
489
1848
4894
...............................................................................................
...............................................................................................
...............................................................................................
...............................................................................................
...............................................................................................
...............................................................................................
2.5% discount
rate, average *
5
134
793
834
3148
8339
3% discount rate,
95th percentile *
10
239
1417
1490
5626
14902
* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn from a different part of the
distribution. Values presented in the table incorporate the escalation of the SCC over time.
TABLE V–38—ROOM AIR CONDITIONERS: ESTIMATES OF GLOBAL PRESENT VALUE OF CO2 EMISSIONS REDUCTION
UNDER TRIAL STANDARD LEVELS
Million 2009$
TSL
1
2
3
4
5
6
5% discount rate,
average *
3% discount rate,
average *
43
52
55
77
118
166
212
259
271
382
591
833
...............................................................................................
...............................................................................................
...............................................................................................
...............................................................................................
...............................................................................................
...............................................................................................
2.5% discount
rate, average *
357
436
455
642
996
1404
3% discount rate,
95th percentile *
648
790
826
1164
1803
2541
* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn from a different part of the
distribution. Values presented in the table incorporate the escalation of the SCC over time.
TABLE V–39—CLOTHES DRYERS: ESTIMATES OF DOMESTIC PRESENT VALUE OF CO2 EMISSIONS REDUCTION UNDER
TRIAL STANDARD LEVELS
Million 2009$ *
TSL
1
2
3
4
5
6
5% discount
rate, average **
...........................................................................................................
...........................................................................................................
...........................................................................................................
...........................................................................................................
...........................................................................................................
...........................................................................................................
3% discount
rate, average **
2.5% discount
rate, average **
3% discount
rate, 95th
percentile **
0.042 to 0.14 ....
1.04 to 3.43 ......
6.19 to 20.3 ......
6.51 to 21.4 ......
24.6 to 80.7 ......
65.1 to 214 .......
0.22 to 0.72 ......
5.50 to 18.1 ......
32.6 to 107 .......
34.3 to 113 .......
129 to 425 ........
343 to 1126 ......
0.37 to 1.22 ......
9.37 to 30.8 ......
55.5 to 182 .......
58.4 to 192 .......
220 to 724 ........
584 to 1918 ......
0.67 to 2.19.
16.7 to 55.0.
99.2 to 326.
104 to 343.
394 to 1294.
1043 to 3428.
* Domestic values are presented as a range between 7 percent and 23 percent of the global values.
** Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn from a different part of the
distribution. Values presented in the table incorporate the escalation of the SCC over time.
TABLE V–40—ROOM AIR CONDITIONERS: ESTIMATES OF DOMESTIC PRESENT VALUE OF CO2 EMISSIONS REDUCTION
UNDER TRIAL STANDARD LEVELS
mstockstill on DSKH9S0YB1PROD with RULES2
Million 2009$ *
TSL
1
2
3
4
5
5% discount
rate, average **
...........................................................................................................
...........................................................................................................
...........................................................................................................
...........................................................................................................
...........................................................................................................
VerDate Mar<15>2010
16:58 Apr 20, 2011
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3% discount
rate, average **
2.5% discount
rate, average **
3.00
3.64
3.83
5.36
8.29
14.9
18.1
18.9
26.7
41.4
25.0
30.5
31.9
45.0
69.7
Fmt 4701
to
to
to
to
to
9.85
12.0
12.6
17.6
27.2
Sfmt 4700
......
......
......
......
......
to
to
to
to
to
48.8 ......
59.6 ......
62.3 ......
87.8 ......
136 .......
E:\FR\FM\21APR2.SGM
21APR2
to
to
to
to
to
82.1 ......
100 .......
105 .......
148 .......
229 .......
3% discount
rate, 95th
percentile **
45.4 to 149.
55.3 to 182.
57.8 to 190.
81.5 to 268.
126 to 415.
Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
22547
TABLE V–40—ROOM AIR CONDITIONERS: ESTIMATES OF DOMESTIC PRESENT VALUE OF CO2 EMISSIONS REDUCTION
UNDER TRIAL STANDARD LEVELS—Continued
Million 2009$ *
TSL
5% discount
rate, average **
3% discount
rate, average **
2.5% discount
rate, average **
6 ...........................................................................................................
11.6 to 38.3 ......
58.3 to 192 .......
98.3 to 323 .......
3% discount
rate, 95th
percentile **
178 to 584.
* Domestic values are presented as a range between 7 percent and 23 percent of the global values.
** Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn from a different part of the
distribution. Values presented in the table incorporate the escalation of the SCC over time.
DOE is well aware that scientific and
economic knowledge about the
contribution of CO2 and other GHG
emissions to changes in the future
global climate and the potential
resulting damages to the world economy
continues to evolve rapidly. Thus, any
value placed in this rulemaking on
reducing CO2 emissions is subject to
change. DOE, together with other
Federal agencies, will continue to
review various methodologies for
estimating the monetary value of
reductions in CO2 and other GHG
emissions. This ongoing review will
consider the comments on this subject
that are part of the public record for this
and other rulemakings, as well as other
methodological assumptions and issues.
However, consistent with DOE’s legal
obligations, and taking into account the
uncertainty involved with this
particular issue, DOE has included in
this final rule the most recent values
and analyses resulting from the ongoing
interagency review process.
DOE also estimated a range for the
cumulative monetary value of the
economic benefits associated with NOX
emissions reductions anticipated to
result from amended standards for
clothes dryers and room air
conditioners. The dollar-per-ton values
that DOE used are discussed in section
IV.M. Table V–41 and Table V–42
present the cumulative present values
for each TSL calculated using sevenpercent and three-percent discount
rates.
TABLE V–41—CLOTHES DRYERS: ESTIMATES OF PRESENT VALUE OF NOX EMISSIONS REDUCTION UNDER TRIAL
STANDARD LEVELS
3% discount rate
Million 2009$
TSL
1
2
3
4
5
6
.........................................................................................................................................................................
.........................................................................................................................................................................
.........................................................................................................................................................................
.........................................................................................................................................................................
.........................................................................................................................................................................
.........................................................................................................................................................................
7% discount rate
Million 2009$
0.031 to 0.314 ..
0.759 to 7.8 ......
4.49 to 46.2 ......
4.77 to 49.02 ....
18.0 to 185 .......
47.6 to 490 .......
0.013 to 0.136.
0.328 to 3.37.
1.94 to 19.98.
2.06 to 21.2.
7.8 to 80.2.
20.6 to 212.
TABLE V–42—ROOM AIR CONDITIONERS: ESTIMATES OF PRESENT VALUE OF NOX EMISSIONS REDUCTION UNDER TRIAL
STANDARD LEVELS
3% discount rate
Million 2009$
TSL
mstockstill on DSKH9S0YB1PROD with RULES2
1
2
3
4
5
6
.........................................................................................................................................................................
.........................................................................................................................................................................
.........................................................................................................................................................................
.........................................................................................................................................................................
.........................................................................................................................................................................
.........................................................................................................................................................................
The NPV of the monetized benefits
associated with emissions reductions
can be viewed as a complement to the
NPV of the consumer savings calculated
for each TSL considered in this
rulemaking. Table V–43 shows an
example of the calculation of the
combined NPV including benefits from
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16:58 Apr 20, 2011
Jkt 223001
emissions reductions for the case of TSL
4 for clothes dryers. Table V–44 through
Table V–47 present the NPV values that
result from adding the estimates of the
potential economic benefits resulting
from reduced CO2 and NOX emissions
in each of four valuation scenarios to
the NPV of consumer savings calculated
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Sfmt 4700
7% discount rate
Million 2009$
2.34
2.83
2.99
4.16
6.40
8.96
1.25 to 12.9.
1.50 to 15.4.
1.61 to 16.6.
2.2 to 22.6.
3.35 to 34.4.
4.64 to 47.7.
to
to
to
to
to
to
24.0
29.1
30.7
42.7
65.8
92.1
......
......
......
......
......
......
for each TSL considered in this
rulemaking, at both a 7-percent and 3percent discount rate. The CO2 values
used in the columns of each table
correspond to the four scenarios for the
valuation of CO2 emission reductions
presented in section IV.M.
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TABLE V–43—ADDING NET PRESENT VALUE OF CONSUMER SAVINGS TO PRESENT VALUE OF MONETIZED BENEFITS
FROM CO2 AND NOX EMISSIONS REDUCTIONS AT TSL 4 FOR CLOTHES DRYERS
Present value
billion 2009$
Category
Benefits:
Operating Cost Savings .....................................................................................................................
Discount rate
(percent)
1.726
4.099
0.093
0.489
0.834
1.49
0.012
0.027
2.227
4.615
0.65
1.086
Total Monetary Benefits ** ..................................................................................................................
Costs:
Total Incremental Installed Costs .......................................................................................................
Net Benefits/Costs:
Including CO2 and NOX** ...................................................................................................................
7
3
1.58
3.53
CO2 Reduction Monetized Value (at $4.9/metric ton) * ......................................................................
CO2 Reduction Monetized Value (at $22.1/metric ton) * ....................................................................
CO2 Reduction Monetized Value (at $36.3/metric ton) * ....................................................................
CO2 Reduction Monetized Value (at $67.1/metric ton) * ....................................................................
NOX Reduction Monetized Value (at $2,519/ton) * ............................................................................
7%
3%
5
3
2.5
3
7
3
7
3
7
3
* These values represent global values (in 2009$) of the SCC in 2010 under several scenarios. The values of $4.9, $22.1, and $36.3 per ton
are the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.1 per
ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. See section IV.M for details. The value for
NOX (in 2009$) is the average of the low and high values used in DOE’s analysis.
** Total Monetary Benefits for both the 3-percent and 7-percent cases utilize the central estimate of social cost of CO2 emissions calculated at
a 3% discount rate, which is equal to $22.1/ton in 2010 (in 2009$).
TABLE V–44—RESULTS OF ADDING NET PRESENT VALUE OF CONSUMER SAVINGS (AT 7-PERCENT DISCOUNT RATE) TO
NET PRESENT VALUE OF MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS UNDER TRIAL STANDARD LEVELS FOR CLOTHES DRYERS
Consumer NPV at 7% discount rate added with:
SCC Value of
$4.9/metric ton
CO2* and Low
Value for NOX**
billion 2009$
TSL
1
2
3
4
5
6
.......................................................................................
.......................................................................................
.......................................................................................
.......................................................................................
.......................................................................................
.......................................................................................
SCC Value of
$22.1/metric ton
CO2* and Medium
Value for NOX**
billion 2009$
0.00061
0.0152
0.0903
0.0950
0.359
0.950
SCC Value of
$36.3/metric ton
CO2* and Medium
Value for NOX**
billion 2009$
0.00320
0.0804
0.476
0.501
1.892
5.010
0.00540
0.136
0.804
0.846
3.192
8.455
SCC Value of
$67.1/metric ton
CO2* and High
Value for NOX**
billion 2009$
0.00965
0.243
1.437
1.512
5.707
15.114
* These label values represent the global SCC in 2010, in 2009$. Their present values have been calculated with scenario-consistent discount
rates. See section IV.M for a discussion of the derivation of these values.
** Low Value corresponds to $447 per ton of NOX emissions. Medium Value corresponds to $2,519 per ton of NOX emissions. High Value corresponds to $4,591 per ton of NOX emissions.
TABLE V–45—RESULTS OF ADDING NET PRESENT VALUE OF CONSUMER SAVINGS (AT 3-PERCENT DISCOUNT RATE) TO
NET PRESENT VALUE OF MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS UNDER TRIAL STANDARD LEVELS FOR CLOTHES DRYERS
Consumer NPV at 3% discount rate added with:
SCC Value of
$4.9/metric ton
CO2* and Low
Value for NOX**
billion 2009$
mstockstill on DSKH9S0YB1PROD with RULES2
TSL
1
2
3
4
5
6
.......................................................................................
.......................................................................................
.......................................................................................
.......................................................................................
.......................................................................................
.......................................................................................
SCC Value of
$22.1/metric ton
CO2* and Medium
Value for NOX**
billion 2009$
0.00062
0.0157
0.0929
0.0977
0.369
0.977
SCC Value of
$36.3/metric ton
CO2* and Medium
Value for NOX**
billion 2009$
0.00330
0.0829
0.491
0.516
1.949
5.163
0.00550
0.138
0.818
0.861
3.250
8.608
SCC Value of
$67.1/metric ton
CO2* and High
Value for NOX**
billion 2009$
0.00983
0.247
1.463
1.539
5.812
15.392
* These label values represent the global SCC in 2010, in 2009$. Their present values have been calculated with scenario-consistent discount
rates. See section IV.M for a discussion of the derivation of these values.
** Low Value corresponds to $447 per ton of NOX emissions. Medium Value corresponds to $2,519 per ton of NOX emissions. High Value corresponds to $4,591 per ton of NOX emissions.
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TABLE V–46—RESULTS OF ADDING NET PRESENT VALUE OF CONSUMER SAVINGS (AT 7-PERCENT DISCOUNT RATE) TO
NET PRESENT VALUE OF MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS UNDER TRIAL STANDARD LEVELS FOR ROOM AIR CONDITIONERS
Consumer NPV at 7% discount rate added with:
SCC Value of
$4.9/metric ton
CO2* and Low
Value for NOX**
billion 2009$
TSL
1
2
3
4
5
6
.............................................................................................
.............................................................................................
.............................................................................................
.............................................................................................
.............................................................................................
.............................................................................................
SCC Value of
$22.1/metric ton
CO2* and Medium
Value for NOX**
billion 2009$
SCC Value of
$36.3/metric ton
CO2* and Medium
Value for NOX**
billion 2009$
0.219
0.267
0.280
0.394
0.610
0.859
SCC Value of
$67.1/metric ton
CO2* and High
Value for NOX**
billion 2009$
0.364
0.444
0.464
0.655
1.015
1.430
0.044
0.054
0.0563
0.0788
0.122
0.171
0.661
0.805
0.843
1.187
1.838
2.588
* These label values represent the global SCC in 2010, in 2009$. Their present values have been calculated with scenario-consistent discount
rates. See section IV.M for a discussion of the derivation of these values.
** Low Value corresponds to $447 per ton of NOX emissions. Medium Value corresponds to $2,519 per ton of NOX emissions. High Value corresponds to $4,591 per ton of NOX emissions.
TABLE V–47—RESULTS OF ADDING NET PRESENT VALUE OF CONSUMER SAVINGS (AT 3-PERCENT DISCOUNT RATE) TO
NET PRESENT VALUE OF MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS UNDER TRIAL STANDARD LEVELS FOR ROOM AIR CONDITIONERS
Consumer NPV at 3% discount rate added with:
SCC Value of
$4.9/metric ton
CO2* and Low
Value for NOX**
billion 2009$
TSL
1
2
3
4
5
6
.............................................................................................
.............................................................................................
.............................................................................................
.............................................................................................
.............................................................................................
.............................................................................................
SCC Value of
$22.1/metric ton
CO2*and Medium
Value for NOX**
billion 2009$
SCC Value of
$36.3/metric ton
CO2* and Medium
Value for NOX**
billion 2009$
0.226
0.275
0.288
0.405
0.627
0.884
0.370
0.452
0.472
0.666
1.032
1.454
0.045
0.055
0.0576
0.0807
0.125
0.175
SCC Value of
$67.1/metric ton
CO2* and High
Value for NOX**
billion 2009$
0.672
0.819
0.857
1.207
1.869
2.633
mstockstill on DSKH9S0YB1PROD with RULES2
* These label values represent the global SCC in 2010, in 2009$. Their present values have been calculated with scenario-consistent discount
rates. See section IV.M for a discussion of the derivation of these values.
** Low Value corresponds to $447 per ton of NOX emissions. Medium Value corresponds to $2,519 per ton of NOX emissions. High Value corresponds to $4,591 per ton of NOX emissions.
Although adding the value of
consumer savings to the values of
emission reductions provides a valuable
perspective, two issues should be
considered. First, the national operating
cost savings are domestic U.S. consumer
monetary savings that occur as a result
of market transactions, while the value
of CO2 reductions is based on a global
value. Second, the assessments of
operating cost savings and the SCC are
performed with different methods that
use quite different time frames for
analysis. The national operating cost
savings is measured for the lifetime of
products shipped in 2014–2043. The
SCC values, on the other hand, reflect
the present value of future climaterelated impacts resulting from the
emission of one ton of carbon dioxide in
each year. These impacts continue well
beyond 2100.
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7. Other Factors
The Secretary of Energy, in
determining whether a standard is
economically justified, may consider
any other factors that the Secretary
deems to be relevant. (42 U.S.C.
6295(o)(2)(B)(i)(VI))) In developing the
direct final rule, DOE has also
considered the Joint Petition submitted
to DOE. DOE recognizes the value of
consensus agreements submitted by
parties in accordance with 42 U.S.C.
6295(p)(4) and has weighed the value of
such consensus in establishing the
standards set forth in today’s final rule.
DOE has encouraged the submission of
consensus agreements as a way to get
diverse stakeholders together, to
develop an independent and probative
analysis useful in DOE standard setting,
and to expedite the rulemaking process.
DOE also believes that standard levels
recommended in the consensus
agreement may increase the likelihood
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Fmt 4701
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for regulatory compliance, while
decreasing the risk of litigation.
C. Proposed Standards
When considering proposed
standards, the new or amended energy
conservation standard that DOE adopts
for any type (or class) of covered
product shall 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)) In determining whether a
standard is economically justified, DOE
must determine whether the benefits of
the standard exceed its burdens to the
greatest extent practicable, in light of
the seven statutory factors discussed
previously. (42 U.S.C. 6295(o)(2)(B)(i))
The new or amended standard must also
‘‘result in significant conservation of
energy.’’ (42 U.S.C. 6295(o)(3)(B))
The Department considered the
impacts of standards at each trial
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standard level, beginning with
maximum technologically feasible level,
to determine whether that level was
economically justified. Where the maxtech level was not economically
justified, DOE then considered the next
most efficient level and undertook the
same evaluation until it reached the
highest efficiency level that is both
technologically feasible and
economically justified and saves a
significant amount of energy.
To aid the reader as DOE discusses
the benefits and burdens of each trial
standard level, DOE has included tables
that present a summary of the results of
DOE’s quantitative analysis for each
TSL. In addition to the quantitative
results presented in the tables, DOE also
considers other burdens and benefits
that affect economic justification. These
include the impacts on identifiable
subgroups of consumers, such as lowincome households and seniors, who
may be disproportionately affected by a
national standard. Section V.B.1
presents the estimated impacts of each
TSL for these subgroups.
DOE also notes that the economics
literature provides a wide-ranging
discussion of how consumers trade off
upfront costs and energy savings in the
absence of government intervention.
Much of this literature attempts to
explain why consumers appear to
undervalue energy efficiency
improvements. This undervaluation
suggests that regulation that promotes
energy efficiency can produce
significant net private gains (as well as
producing social gains by, for example,
reducing pollution). There is evidence
that consumers undervalue future
energy savings as a result of (1) a lack
of information; (2) a lack of sufficient
salience of the long-term or aggregate
benefits; (3) a lack of sufficient savings
to warrant delaying or altering
purchases (for example, an inefficient
ventilation fan in a new building or the
delayed replacement of a water pump);
(4) excessive focus on the short term, in
the form of inconsistent weighting of
future energy cost savings relative to
available returns on other investments;
(5) computational or other difficulties
associated with the evaluation of
relevant tradeoffs; and (6) a divergence
in incentives (that is, renter versus
owner; builder vs. purchaser). Other
literature indicates that with less than
perfect foresight and a high degree of
uncertainty about the future, consumers
may trade off these types of investments
at a higher than expected rate between
current consumption and uncertain
future energy cost savings.
In its current regulatory analysis,
potential changes in the benefits and
costs of a regulation due to changes in
consumer purchase decisions are
included in two ways: (1) If consumers
forego a purchase of a product in the
standards case, this decreases sales for
product manufacturers and the cost to
manufacturers is included in the MIA,
and (2) DOE accounts for energy savings
attributable only to products actually
used by consumers in the standards
case; if a regulatory option decreases the
number of products used by consumers,
this decreases the potential energy
savings from an energy conservation
standard. DOE provides detailed
estimates of shipments and changes in
the volume of product purchases in
chapter 9 of the TSD. However, DOE’s
current analysis does not explicitly
control for heterogeneity in consumer
preferences, preferences across
subcategories of products or specific
features, or consumer price sensitivity
variation according to household
income (Reiss and White 2004).
While DOE is not prepared at present
to provide a fuller quantifiable
framework for estimating the benefits
and costs of changes in consumer
purchase decisions due to an energy
conservation standard, DOE seeks
comments on how to more fully assess
the potential impact of energy
conservation standards on consumer
choice and how to quantify this impact
in its regulatory analysis in future
rulemakings.
1. Benefits and Burdens of TSLs
Considered for Clothes Dryers
Table V–48 and Table V–49 present a
summary of the quantitative impacts
estimated for each TSL for clothes
dryers. The efficiency levels contained
in each TSL are described in section
V.A.
TABLE V–48—SUMMARY OF RESULTS FOR CLOTHES DRYER TRIAL STANDARD LEVELS: NATIONAL IMPACTS
Category
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
TSL 6
National Energy Savings (quads) .....
0.00 .................
0.062 ...............
0.37 .................
0.39 .................
1.45 .................
3.14.
3.01 .................
1.08 .................
0.22 .................
(2.60) ..............
(1.53).
(6.72).
18.67 ...............
15.14 ...............
0.051 ...............
70.47 ...............
57.26 ...............
0.188 ...............
186.6.
151.3.
0.569.
NPV of Consumer Benefits (2009$ billion)
3% discount rate ...............................
7% discount rate ...............................
0.00 .................
0.01 .................
0.62 .................
0.25 .................
3.00 .................
1.10 .................
Cumulative Emissions Reduction
CO2 (million metric tons) ..................
NOX (thousand tons) ........................
Hg (ton) .............................................
0.119 ...............
0.097 ...............
0.000 ...............
2.99 .................
2.41 .................
0.009 ...............
17.75 ...............
14.26 ...............
0.053 ...............
mstockstill on DSKH9S0YB1PROD with RULES2
Value of Emissions Reduction
CO2 (2009$ million) * ........................
NOX—3% discount rate (2009 million).
NOX—7% discount rate (2009$ million).
Generation
Capacity
Reduction
(GW)**.
1 to 10 ............
0.031 to 0.314
15 to 239 ........
0.759 to 7.8 ....
88 to 1417 ......
4.49 to 46.2 ....
93 to 1490 ......
4.77 to 49.0 ....
351 to 5626 ....
18.0 to 185 .....
929 to 14902.
47.6 to 490.
0.013 to 0.136
0.328 to 3.37 ..
1.94 to 20.0 ....
2.06 to 21.2 ....
7.8 to 80.2 ......
20.6 to 212.
0.002 ...............
0.060 ...............
0.358 ...............
0.345 ...............
1.27 .................
2.27.
0.46 to (3.96) ..
1.08 to (3.96) ..
2.26 to (3.96).
Employment Impacts
Total Potential Change in Domestic
Production Workers in 2014
(thousands).
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Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
TABLE V–48—SUMMARY OF RESULTS FOR CLOTHES DRYER TRIAL STANDARD LEVELS: NATIONAL IMPACTS—Continued
Category
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
Indirect Domestic Jobs (thousands)**
0.01 .................
0.01 .................
1.82 .................
1.75 .................
4.25 .................
TSL 6
9.30.
Parentheses indicate negative (¥) values.
* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions.
** Changes in 2043.
TABLE V–49—SUMMARY OF RESULTS FOR CLOTHES DRYER TRIAL STANDARD LEVELS: CONSUMER AND MANUFACTURER
IMPACTS
Category
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
TSL 6
(176.5) to
(397.4).
(17.6) to (39.6)
(303.9) to
(730.0).
(30.3) to (72.7).
$14 ..................
$14 ..................
$8 ....................
$2 ....................
$0 ....................
$0 ....................
($30) ...............
($99) ...............
($99) ...............
($100) .............
($42) ...............
$73 ..................
($146).
($264).
($246).
($100).
($177).
($166).
5.3 ...................
0.9 ...................
0.9 ...................
11.7 .................
n/a ...................
n/a ...................
19.1 .................
36.1 .................
45.1 .................
49.5 .................
25.3 .................
5.3 ...................
22.1.
40.1.
38.2.
49.5.
26.9.
22.4.
Manufacturer Impacts
Industry NPV (2009$ million) ............
(2.5) to (2.5) ....
(3.6) to (4.9) ....
(41.1) to (55.5)
(64.5) to (80.6)
Industry NPV (% change) .................
(0.3) to (0.3) ....
(0.4) to (0.5) ....
(4.1) to (5.5) ....
(6.4) to (8.0) ....
Consumer Mean LCC Savings * (2009$)
Electric Standard ..............................
Compact 120V ..................................
Compact 240V ..................................
Gas ...................................................
Ventless 240V ...................................
Ventless Combination Washer/Dryer
$0
$0
$0
$0
$0
$0
....................
....................
....................
....................
....................
....................
$2 ....................
$14 ..................
$8 ....................
$2 ....................
$20 ..................
$73 ..................
$14 ..................
$14 ..................
$8 ....................
$2 ....................
$20 ..................
$73 ..................
Consumer Median PBP (years) **
Electric Standard ..............................
Compact 120V ..................................
Compact 240V ..................................
Gas ...................................................
Ventless 240V ...................................
Ventless Combination Washer/Dryer
3.9
n/a
0.0
2.2
n/a
n/a
...................
...................
...................
...................
...................
...................
0.2
0.9
0.9
0.5
0.9
5.3
...................
...................
...................
...................
...................
...................
5.3
0.9
0.9
0.5
0.9
5.3
...................
...................
...................
...................
...................
...................
Distribution of Consumer LCC Impacts
mstockstill on DSKH9S0YB1PROD with RULES2
Electric Standard:
Net Cost (%) ..............................
No Impact (%) ...........................
Net Benefit (%) ..........................
Compact 120V:
Net Cost (%) ..............................
No Impact (%) ...........................
Net Benefit (%) ..........................
Compact 240V:
Net Cost (%) ..............................
No Impact (%) ...........................
Net Benefit (%) ..........................
Gas:
Net Cost (%) ..............................
No Impact (%) ...........................
Net Benefit (%) ..........................
Ventless 240V:
Net Cost (%) ..............................
No Impact (%) ...........................
Net Benefit (%) ..........................
Ventless Combination Washer/Dryer:
Net Cost (%) .....................................
No Impact (%) ...................................
Net Benefit (%) .................................
1% ..................
98% ................
2% ..................
0% ..................
79% ................
21% ................
19% ................
25% ................
56% ................
19% ................
25% ................
56% ................
75% ................
1% ..................
24% ................
81%.
0%.
19%.
0% ..................
100% ...............
0% ..................
4% ..................
0% ..................
96% ................
4% ..................
0% ..................
96% ................
4% ..................
0% ..................
96% ................
95% ................
0% ..................
5% ..................
95%.
0%.
5%.
0% ..................
100% ...............
0% ..................
.........................
1% ..................
93% ................
7% ..................
2% ..................
41% ................
56% ................
.........................
0% ..................
85% ................
15% ................
2% ..................
41% ................
56% ................
.........................
0% ..................
85% ................
15% ................
2% ..................
41% ................
56% ................
.........................
32% ................
42% ................
26% ................
93% ................
4% ..................
3% ..................
.........................
95% ................
1% ..................
4% ..................
95%.
0%.
5%.
95%.
1%.
4%.
0% ..................
100% ...............
0% ..................
0% ..................
0% ..................
100% ...............
0% ..................
0% ..................
100% ..............
0% ..................
100% ..............
0% ..................
92% ................
0% ..................
8% ..................
88%.
0%.
12%.
0% ..................
100% ...............
0% ..................
21% ................
0% ..................
79% ................
21% ................
0% ..................
79% ................
0% ..................
100% ..............
0% ..................
21% ................
0% ..................
79% ................
82%.
0%.
18%.
Parentheses indicate negative (¥) values.
* For LCCs, a negative value means an increase in LCC by the amount indicated.
** In some cases the standard level is the same as the baseline efficiency level, so no consumers are impacted and therefore calculation of a
payback period is not applicable.
DOE first considered TSL 6, which
represents the max-tech efficiency
levels. TSL 6 would save 3.14 quads of
energy, an amount DOE considers
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16:58 Apr 20, 2011
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significant. Under TSL 6, the NPV of
consumer benefit would be ¥$6.72
billion, using a discount rate of 7
PO 00000
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Sfmt 4700
percent, and ¥$1.53 billion, using a
discount rate of 3 percent.
The cumulative emissions reductions
at TSL 6 are 186.6 Mt of CO2, 151.3
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thousand tons of NOX, and 0.569 ton of
Hg. The estimated monetary value of the
CO2 emissions reductions at TSL 6
ranges from $929 million to $14,902
million. Total generating capacity in
2043 is estimated to decrease by 2.27
GW under TSL 6.
At TSL 6, the average LCC impact is
a cost (LCC increase) of $146 for electric
standard clothes dryers, a cost of $264
for 120V compact clothes dryers, a cost
of $246 for 240V compact clothes
dryers, a cost of $100 for gas clothes
dryers, a cost of $177 for ventless 240V
clothes dryers, and a cost of $166 for
combination washer/dryers. The median
payback period is 22.1 years for electric
standard clothes dryers, 40.1 years for
120Vcompact clothes dryers, 38.2 years
for 240V compact clothes dryers, 49.5
years for gas clothes dryers, 26.9 years
for ventless 240V clothes dryers, and
22.4 years for combination washer/
dryers. The fraction of consumers
experiencing an LCC benefit is 19
percent for electric standard clothes
dryers, 5 percent for 120V compact
clothes dryers, 5 percent for 240V
compact clothes dryers, 4 percent for
gas clothes dryers, 12 percent for
ventless 240V clothes dryers, and 18
percent for combination washer/dryers.
The fraction of consumers experiencing
an LCC cost is 81 percent for electric
standard clothes dryers, 95 percent for
120Vcompact clothes dryers, 95 percent
for 240V compact clothes dryers, 95
percent for gas clothes dryers, 88
percent for ventless 240V clothes dryers,
and 82 percent for combination washer/
dryers.
At TSL 6, the projected change in
INPV ranges from a decrease of $303.9
million to a decrease of $730.0 million.
TSL 6 would effectively require heat
pump clothes dryers for all electric
clothes dryer product classes. Changing
all electric models to use heat pump
technology would be extremely
disruptive to current manufacturing
facilities and would require substantial
product and capital conversion costs. In
addition, the large cost increases would
greatly harm manufacturer profitability
if they were unable to earn additional
operating profit on these additional
costs. At TSL 6, DOE recognizes the risk
of very large negative impacts if
manufacturers’ expectations concerning
reduced profit margins and large
conversion costs are realized. If the high
end of the range of impacts is reached
as DOE expects, TSL 6 could result in
a net loss of 72.6 percent in INPV to
clothes dryer manufacturers.
DOE concludes that at TSL 6 for
residential clothes dryers, the benefits of
energy savings, generating capacity
reductions, emission reductions, and
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the estimated monetary value of the CO2
emissions reductions would be
outweighed by the negative NPV of
consumer benefits, the economic burden
on a significant fraction of consumers
due to the large increases in product
cost, and the conversion costs and profit
margin impacts that could result in a
very large reduction in INPV for the
manufacturers. Consequently, the
Secretary has concluded that TSL 6 is
not economically justified.
DOE next considered TSL 5. TSL 5
would save 1.45 quads of energy, an
amount DOE considers significant.
Under TSL 5, the NPV of consumer
benefit would be ¥$2.60 billion, using
a discount rate of 7 percent, and $0.22
billion, using a discount rate of
3 percent.
The cumulative emissions reductions
at TSL 5 are 70.47 Mt of CO2, 57.26
thousand tons of NOX, and 0.188 tons of
Hg. The estimated monetary value of the
CO2 emissions reductions at TSL 5
ranges from $351 million to $5,626
million. Total generating capacity in
2043 is estimated to decrease by 1.27
GW under TSL 5.
At TSL 5, the average LCC impact is
a cost (LCC increase) of $30 for electric
standard clothes dryers, a cost of $99 for
120Vcompact clothes dryers, a cost of
$99 for 240V compact clothes dryers, a
cost of $100 for gas clothes dryers, a cost
of $42 for ventless 240V clothes dryers,
and a savings of $73 for combination
washer/dryers. The median payback
period is 19.1 years for electric standard
clothes dryers, 36.1 years for
120Vcompact clothes dryers, 45.1 years
for 240V compact clothes dryers, 49.5
years for gas clothes dryers, 25.3 years
for ventless 240V clothes dryers, and 5.3
years for combination washer/dryers.
The fraction of consumers experiencing
an LCC benefit is 24 percent for electric
standard clothes dryers, 5 percent for
120Vcompact clothes dryers, 3 percent
for 240V compact clothes dryers, 4
percent for gas clothes dryers, 8 percent
for ventless 240V clothes dryers, and 79
percent for combination washer/dryers.
The fraction of consumers experiencing
an LCC cost is 75 percent for electric
standard clothes dryers, 95 percent for
120Vcompact clothes dryers, 93 percent
for 240V compact clothes dryers, 95
percent for gas clothes dryers, 92
percent for ventless 240V clothes dryers,
and 21 percent for combination washer/
dryers.
At TSL 5, the projected change in
INPV ranges from a decrease of $176.5
million to a decrease of $397.4 million.
While most changes at TSL 5 could be
made within existing product design,
redesigning units to the most efficient
technologies on the market today would
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take considerable capital and product
conversion costs. At TSL 5, DOE
recognizes the risk of very large negative
impacts if manufacturers are not able to
earn additional operating profit from the
additional production costs to reach
TSL 5. If the high end of the range of
impacts is reached as DOE expects, TSL
5 could result in a net loss of 39.6
percent in INPV to clothes dryer
manufacturers.
The Secretary concludes that at TSL
5 for residential clothes dryers, the
benefits of energy savings, generating
capacity reductions, emission
reductions, and the estimated monetary
value of the CO2 emissions reductions
would be outweighed by the negative
NPV of consumer benefits, the economic
burden on a significant fraction of
consumers due to the large increases in
product cost, and the conversion costs
and profit margin impacts that could
result in a large reduction in INPV for
the manufacturers. Consequently, the
Secretary has concluded that TSL 5 is
not economically justified.
DOE then considered TSL 4. TSL 4
would save 0.39 quads of energy, an
amount DOE considers significant.
Under TSL 4, the NPV of consumer
benefit would be $1.08 billion, using a
discount rate of 7 percent, and $3.01
billion, using a discount rate of 3
percent.
The cumulative emissions reductions
at TSL 4 are 18.67 Mt of CO2, 15.14
thousand tons of NOX, and 0.051 ton of
Hg. The estimated monetary value of the
CO2 emissions reductions at TSL 4
ranges from $93 million to $1,490
million. Total generating capacity in
2043 is estimated to decrease by 0.345
GW under TSL 4.
At TSL 4, DOE projects that the
average LCC impact is a savings (LCC
decrease) of $14 for electric standard
clothes dryers, a savings of $14 for 120V
compact clothes dryers, a savings of $8
for 240V compact clothes dryers, a
savings of $2 for gas clothes dryers, and
no change for ventless 240V clothes
dryers and combination washer/dryers.
The median payback period is 5.3 years
for electric standard clothes dryers, 0.9
years for 120V compact clothes dryers,
0.9 years for 240V compact clothes
dryers, 11.7 years for gas clothes dryers,
and is not applicable for ventless 240V
clothes dryers and combination washer/
dryers.64 The fraction of consumers
experiencing an LCC benefit is 56
percent for electric standard clothes
dryers, 96 percent for 120V compact
64 For these product classes, the efficiency level
at TSL 4 is the same as the baseline efficiency level,
so no consumers are impacted and therefore
calculation of a payback period is not applicable.
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clothes dryers, 56 percent for 240V
compact clothes dryers, 26 percent for
gas clothes dryers, zero percent for
ventless 240V clothes dryers, and zero
percent for combination washer/dryers.
The fraction of consumers experiencing
an LCC cost is 19 percent for electric
standard clothes dryers, 4 percent for
120V compact clothes dryers, 2 percent
for 240V compact clothes dryers, 32
percent for gas clothes dryers, zero
percent for ventless 240V clothes dryers,
and zero percent for combination
washer/dryers.
At TSL 4, the projected change in
INPV ranges from a decrease of $64.5
million to a decrease of $80.6 million.
The design changes required at TSL 4
for the most common standard-size gas
and electric products are incremental
improvements that are well known in
the industry but would still require
moderate product and capital
conversion costs to implement. At TSL
4, DOE recognizes the risk of negative
impacts if manufacturers’ expectations
concerning reduced profit margins are
realized. If the high end of the range of
impacts is reached as DOE expects, TSL
4 could result in a net loss of 8.0 percent
in INPV to clothes dryer manufacturers.
DOE concludes that at TSL 4 for
residential clothes dryers, the benefits of
energy savings, generating capacity
reductions, emission reductions and the
estimated monetary value of the CO2
emissions reductions, and positive NPV
of consumer benefits outweigh the
economic burden on some consumers
due to the increases in product cost and
the profit margin impacts that could
result in a reduction in INPV for the
manufacturers.
In addition, the efficiency levels in
TSL 4 correspond to the recommended
levels in the consensus agreement,
which DOE believes sets forth a
statement by interested persons that are
fairly representative of relevant points
of view (including representatives of
manufacturers of covered products,
States, and efficiency advocates) and
contains recommendations with respect
to an energy conservation standard that
are in accordance with 42 U.S.C.
6295(o). Moreover, DOE has encouraged
the submission of consensus agreements
as a way to get diverse stakeholders
together, to develop an independent and
probative analysis useful in DOE
standard setting, and to expedite the
rulemaking process. DOE also believes
that standard levels recommended in
the consensus agreement may increase
the likelihood for regulatory
compliance, while decreasing the risk of
litigation.
After considering the analysis,
comments to the preliminary TSD, and
the benefits and burdens of TSL 4, the
Secretary concludes that this trial
standard level will offer the maximum
improvement in efficiency that is
technologically feasible and
economically justified, and will result
in the significant conservation of
energy. Therefore, DOE today adopts
TSL 4 for residential clothes dryers. The
amended energy conservation standards
for clothes dryers, expressed as CEF, are
shown in Table V–50 .
TABLE V–50—AMENDED ENERGY CONSERVATION STANDARDS FOR CLOTHES DRYERS
Residential clothes dryers
Minimum CEF
levels
lb/kWh
Product class
1.
2.
3.
4.
5.
6.
Vented Electric, Standard (4.4 ft3 or greater capacity) .............................................................................................................
Vented Electric, Compact (120 V) (less than 4.4 ft3 capacity) .................................................................................................
Vented Electric, Compact (240 V) (less than 4.4 ft3 capacity) .................................................................................................
Vented Gas ................................................................................................................................................................................
Ventless Electric, Compact (240 V) (less than 4.4 ft3 capacity) ...............................................................................................
Ventless Electric Combination Washer/Dryer ...........................................................................................................................
2. Benefits and Burdens of TSLs
Considered for Room Air Conditioners
Table V–51 and Table V–52 present a
summary of the quantitative impacts
3.73
3.61
3.27
3.30
2.55
2.08
estimated for each TSL for room air
conditioners. The efficiency levels
contained in each TSL are described in
section V.A.
TABLE V–51—SUMMARY OF RESULTS FOR ROOM AIR CONDITIONER TRIAL STANDARD LEVELS: NATIONAL IMPACTS
Category
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
TSL 6
National Energy Savings (quads) .....
0.105 ...............
0.205 ...............
0.218 ...............
0.305 ...............
0.477 ...............
0.665.
1.47 .................
0.57 .................
1.46 .................
0.33 .................
(5.62).
(4.44).
17.4 .................
14.2 .................
0.022 ...............
26.9 .................
21.9 .................
0.032 ...............
37.7.
30.7.
0.044.
77 to 1164 ......
4.16 to 42.7 ....
118 to 1803 ....
6.40 to 65.8 ....
166 to 2541.
8.96 to 92.1.
NPV of Consumer Benefits (2009$ billion)
3% discount rate ...............................
7% discount rate ...............................
0.75 .................
0.35 .................
1.30 .................
0.57 .................
1.51 .................
0.71 .................
mstockstill on DSKH9S0YB1PROD with RULES2
Cumulative Emissions Reduction
CO2 (million metric tons) ..................
NOX (thousand tons) ........................
Hg (ton) .............................................
9.83 .................
8.02 .................
0.012 ...............
11.9 .................
9.69 .................
0.015 ...............
12.5 .................
10.2 .................
0.017 ...............
Value of Emissions Reduction
CO2 (2009$ million) * ........................
NOX—3% discount rate (2009$ million).
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2.34 to 24.0 ....
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2.83 to 29.1 ....
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55 to 826 ........
2.99 to 30.7 ....
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TABLE V–51—SUMMARY OF RESULTS FOR ROOM AIR CONDITIONER TRIAL STANDARD LEVELS: NATIONAL IMPACTS—
Continued
Category
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
TSL 6
NOX—7% discount rate (2009$ million).
Generation
Capacity
Reduction
(GW) **.
1.25 to 12.9 ....
1.50 to 15.4 ....
1.61 to 16.6 ....
2.2 to 22.6 ......
3.35 to 34.4 ....
4.64 to 47.7.
0.348 ...............
0.429 ...............
0.436 ...............
0.632 ...............
1.01 .................
1.46.
Employment Impacts
Total Potential Changes in Domestic
Production Workers in 2014
(thousands).
Indirect
Domestic
Jobs
(thousands) **.
N/A ..................
N/A ..................
N/A ..................
N/A ..................
N/A ..................
N/A.
0.74 .................
0.73 .................
0.74 .................
1.16 .................
1.94 .................
3.07.
Parentheses indicate negative (¥) values.
* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions.
** Changes in 2043.
TABLE V–52—SUMMARY OF RESULTS FOR ROOM AIR CONDITIONER TRIAL STANDARD LEVELS: CONSUMER AND
MANUFACTURER IMPACTS
Category
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
TSL 6
Manufacturer Impacts
Industry NPV (2009$
million).
Industry NPV (%
change).
(44.2) to (84.9) ....
(65.4) to (112.7) ..
(65.7) to (112.4) ..
(111.3) to (177.6)
(86.6) to (184.4) ..
(80.2) to (344.5).
(4.6) to (8.9) ........
(6.8) to (11.8) ......
(6.9) to (11.8) ......
(11.6) to (18.6) ....
(9.1) to (19.3) ......
(8.4) to (36.0).
Consumer Mean LCC Savings * (2009$)
< 6,000 Btu/h, with
Louvers.
8,000–13,999 Btu/h,
with Louvers.
20,000–24,999 Btu/h,
with Louvers.
> 25,000 Btu/h, with
Louvers.
8,000–10,999 Btu/h,
without Louvers.
> 11,000 Btu/h, without Louvers.
$9 ........................
$11 ......................
$9 ........................
$7 ........................
$7 ........................
($58).
$16 ......................
$16 ......................
$22 ......................
$22 ......................
$22 ......................
($38).
$6 ........................
$6 ........................
$0 ........................
$6 ........................
$0 ........................
($214).
$1 ........................
$1 ........................
$0 ........................
$1 ........................
$0 ........................
($227).
$4 ........................
$4 ........................
$13 ......................
$13 ......................
$20 ......................
($66).
$5 ........................
$5 ........................
$11 ......................
$11 ......................
$11 ......................
($64).
Consumer Median PBP (years) **
<6,000 Btu/h, with
Louvers.
8,000–13,999 Btu/h,
with Louvers.
20,000–24,999 Btu/h,
with Louvers.
> 25,000 Btu/h, with
Louvers.
8,000–10,999 Btu/h,
without Louvers.
> 11,000 Btu/h, without Louvers.
4.1 .......................
5.8 .......................
4.1 .......................
8.6 .......................
8.6 .......................
20.9.
0.0 .......................
0.0 .......................
2.8 .......................
2.8 .......................
7.1 .......................
14.7.
4.3 .......................
4.3 .......................
n/a .......................
4.3 .......................
n/a .......................
73.8.
10.3 .....................
10.3 .....................
n/a .......................
10.1 .....................
n/a .......................
107.7.
1.5 .......................
1.5 .......................
2.1 .......................
2.1 .......................
4.9 .......................
25.2.
2.6 .......................
2.6 .......................
3.7 .......................
3.7 .......................
3.7 .......................
25.9.
mstockstill on DSKH9S0YB1PROD with RULES2
Distribution of Consumer LCC Impacts
< 6,000 Btu/h, with
Louvers:
Net Cost (%) ......
No Impact (%) ...
Net Benefit (%) ..
8,000–13,999 Btu/h,
with Louvers:
Net Cost (%) ......
No Impact (%) ...
Net Benefit (%) ..
VerDate Mar<15>2010
21% .....................
31% .....................
48% .....................
33% .....................
31% .....................
37% .....................
21% .....................
31% .....................
48% .....................
65% .....................
1% .......................
34% .....................
65% .....................
1% .......................
34% .....................
90%.
0%.
10%.
9% .......................
60% .....................
30% .....................
9% .......................
60% .....................
30% .....................
34% .....................
2% .......................
64% .....................
34% .....................
2% .......................
64% .....................
56% .....................
1% .......................
43% .....................
77%.
0%.
22%.
16:58 Apr 20, 2011
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TABLE V–52—SUMMARY OF RESULTS FOR ROOM AIR CONDITIONER TRIAL STANDARD LEVELS: CONSUMER AND
MANUFACTURER IMPACTS—Continued
Category
20,000–24,999 Btu/h,
with Louvers:
Net Cost (%) ......
No Impact (%) ...
Net Benefit (%) ..
> 25,000 Btu/h, with
Louvers:
Net Cost (%) ......
No Impact (%) ...
Net Benefit (%) ..
8,000–10,999 Btu/h,
without Louvers:
Net Cost (%) ......
No Impact (%) ...
Net Benefit (%) ..
> 11,000 Btu/h, without Louvers:
Net Cost (%) ......
No Impact (%) ...
Net Benefit (%) ..
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
TSL 6
5% .......................
85% .....................
10% .....................
5% .......................
85% .....................
10% .....................
0% .......................
0% .......................
0% .......................
5% .......................
85% .....................
10% .....................
0% .......................
0% .......................
0% .......................
98%.
2%.
0%.
11% .....................
85% .....................
4% .......................
11% .....................
85% .....................
4% .......................
0% .......................
0% .......................
0% .......................
9% .......................
88% .....................
4% .......................
0% .......................
0% .......................
0% .......................
100%.
0%.
0%.
1% .......................
90% .....................
9% .......................
1% .......................
90% .....................
9% .......................
12% .....................
25% .....................
62% .....................
12% .....................
25% .....................
62% .....................
38% .....................
6% .......................
56% .....................
92%.
2%.
6%.
2% .......................
90% .....................
8% .......................
2% .......................
90% .....................
8% .......................
23% .....................
31% .....................
47% .....................
23% .....................
31% .....................
47% .....................
23% .....................
31% .....................
47% .....................
93%.
0%.
7%.
mstockstill on DSKH9S0YB1PROD with RULES2
Parentheses indicate negative (-) values.
* For LCCs, a negative value means an increase in LCC by the amount indicated.
** In some cases the standard level is the same as the baseline efficiency level, so no consumers are impacted and therefore calculation of a
payback period is not applicable.
DOE first considered TSL 6, which
represents the max-tech efficiency
levels. TSL 6 would save 0.665 quads of
energy, an amount DOE considers
significant. Under TSL 6, the NPV of
consumer benefit would be -$4.44
billion, using a discount rate of 7
percent, and ¥$5.62 billion, using a
discount rate of 3 percent.
The cumulative emissions reductions
at TSL 6 are 37.7 Mt of CO2, 30.7
thousand tons of NOX, and 0.044 tons of
Hg. The estimated monetary value of the
CO2 emissions reductions at TSL 6
ranges from $166 million to $2,541
million. Total generating capacity in
2043 is estimated to decrease by 1.46
GW under TSL 6.
At TSL 6, the average LCC impact is
a cost (LCC increase) of $58 for room air
conditioners < 6,000 Btu/h, with
louvers; a cost of $38 for room air
conditioners 8,000–13,999 Btu/h, with
louvers; a cost of $214 for room air
conditioners 20,000–24,999 Btu/h, with
louvers; a cost of $227 for room air
conditioners > 25,000 Btu/h, with
louvers; a cost of $66 for room air
conditioners 8,000–10,999 Btu/h,
without louvers; and a cost of $64 for
room air conditioners > 11,000 Btu/h,
without louvers. The median payback
period is 20.9 years for room air
conditioners < 6,000 Btu/h, with
louvers; 14.7 years for room air
conditioners 8,000–13,999 Btu/h, with
louvers; 73.8 years for room air
conditioners 20,000–24,999 Btu/h, with
louvers; 107.7 years for room air
conditioners > 25,000 Btu/h, with
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Jkt 223001
louvers; 25.2 years for room air
conditioners 8,000–10,999 Btu/h,
without louvers; and 25.9 years for room
air conditioners > 11,000 Btu/h, without
louvers. The fraction of consumers
experiencing an LCC benefit is 10
percent for room air conditioners
< 6,000 Btu/h, with louvers; 22 percent
for room air conditioners 8,000–13,999
Btu/h, with louvers; zero percent for
room air conditioners 20,000–24,999
Btu/h, with louvers; zero percent for
room air conditioners > 25,000 Btu/h,
with louvers; 6 percent for room air
conditioners 8,000–10,999 Btu/h,
without louvers; and 7 percent for room
air conditioners > 11,000 Btu/h, without
louvers. The fraction of consumers
experiencing an LCC cost is 90 percent
for room air conditioners < 6,000 Btu/h,
with louvers; 77 percent for room air
conditioners 8,000–13,999 Btu/h, with
louvers; 98 percent for room air
conditioners 20,000–24,999 Btu/h, with
louvers; 100 percent for room air
conditioners > 25,000 Btu/h, with
louvers; 92 percent for room air
conditioners 8,000–10,999 Btu/h,
without louvers; and 93 percent for
room air conditioners > 11,000 Btu/h,
without louvers.
At TSL 6, the projected change in
INPV ranges from a decrease of $80.2
million to a decrease of $344.5 million.
At TSL 6, DOE recognizes the risk of
large negative impacts if manufacturers’
expectations concerning reduced profit
margins are realized. If the high end of
the range of impacts is reached as DOE
expects, TSL 6 could result in a net loss
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of 36.0 percent in INPV to room air
conditioner manufacturers.
The Secretary concludes that at TSL
6 for room air conditioners, the benefits
of energy savings, generating capacity
reductions, emission reductions, and
the estimated monetary value of the CO2
emissions reductions would be
outweighed by the negative NPV of
consumer benefits, the economic burden
on a significant fraction of consumers
due to the large increases in product
cost, and the capital conversion costs
and profit margin impacts that could
result in a large reduction in INPV for
the manufacturers. Consequently, the
Secretary has concluded that TSL 6 is
not economically justified.
DOE next considered TSL 5. TSL 5
would save 0.477 quads of energy, an
amount DOE considers significant.
Under TSL 5, the NPV of consumer
benefit would be $0.33 billion, using a
discount rate of 7 percent, and $1.46
billion, using a discount rate of 3
percent.
The cumulative emissions reductions
at TSL 5 are 26.9 Mt of CO2, 21.9
thousand tons of NOX, and 0.032 ton of
Hg. The estimated monetary value of the
CO2 emissions reductions at TSL 5
ranges from $118 million to $1,803
million. Total generating capacity in
2043 is estimated to decrease by 1.01
GW under TSL 5.
At TSL 5, the average LCC impact is
a savings (LCC decrease) of $7 for room
air conditioners < 6,000 Btu/h, with
louvers; a savings of $22 for room air
conditioners 8,000–13,999 Btu/h, with
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louvers; a savings of $0 for room air
conditioners 20,000–24,999 Btu/h, with
louvers; a savings of $0 for room air
conditioners > 25,000 Btu/h, with
louvers; a savings of $20 for room air
conditioners 8,000–10,999 Btu/h,
without louvers; and a savings of $11 for
room air conditioners > 11,000 Btu/h,
without louvers. The median payback
period is 8.6 years for room air
conditioners < 6,000 Btu/h, with
louvers; 7.1 years for room air
conditioners 8,000–13,999 Btu/h, with
louvers; not applicable for room air
conditioners 20,000–24,999 Btu/h, with
louvers or for room air conditioners
> 25,000 Btu/h, with louvers; 65 4.9
years for room air conditioners 8,000–
10,999 Btu/h, without louvers; and 3.7
years for room air conditioners > 11,000
Btu/h, without louvers. The fraction of
consumers experiencing an LCC benefit
is 34 percent for room air conditioners
<6,000 Btu/h, with louvers; 43 percent
for room air conditioners 8,000–13,999
Btu/h, with louvers; zero percent for
room air conditioners 20,000–24,999
Btu/h, with louvers; zero percent for
room air conditioners > 25,000 Btu/h,
with louvers; 56 percent for room air
conditioners 8,000–10,999 Btu/h,
without louvers; and 47 percent for
room air conditioners > 11,000 Btu/h,
without louvers. The fraction of
consumers experiencing an LCC cost is
65 percent for room air conditioners
<6,000 Btu/h, with louvers; 56 percent
for room air conditioners 8,000–13,999
Btu/h, with louvers; zero percent for
room air conditioners 20,000–24,999
Btu/h, with louvers; zero percent for
room air conditioners > 25,000 Btu/h,
with louvers; 38 percent for room air
conditioners 8,000–10,999 Btu/h,
without louvers; and 23 percent for
room air conditioners > 11,000 Btu/h,
without louvers.
At TSL 5, the projected change in
INPV ranges from a decrease of $86.6
million to a decrease of $184.4 million.
At TSL 5, DOE recognizes the risk of
moderately negative impacts if
manufacturers’ expectations concerning
reduced profit margins are realized. If
the high end of the range of impacts is
reached as DOE expects, TSL 5 could
result in a net loss of 19.3 percent in
INPV to room air conditioner
manufacturers.
The Secretary concludes that at TSL
5 for room air conditioners, the benefits
of energy savings, positive NPV of
consumer benefits, generating capacity
reductions, emission reductions, and
65 In these cases the standard level is the same as
the baseline efficiency level, so no consumers are
impacted and therefore calculation of a payback
period is not applicable.
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the estimated monetary value of the CO2
emissions reductions would be
outweighed by the economic burden on
a significant fraction of consumers in
some product classes due to the large
increases in product cost, and the
capital conversion costs and profit
margin impacts that could result in a
moderate reduction in INPV for the
manufacturers. In particular, the
fraction of consumers experiencing an
LCC cost is 56 percent for room air
conditioners with 8,000–13,999 Btu/h,
with louvers, which is the product class
with the largest market share. Based on
the above findings, the Secretary has
concluded that TSL 5 is not
economically justified.
DOE then considered TSL 4. TSL 4
would save 0.305 quads of energy, an
amount DOE considers significant.
Under TSL 4, the NPV of consumer
benefit would be $0.57 billion, using a
discount rate of 7 percent, and $1.47
billion, using a discount rate of 3
percent.
The cumulative emissions reductions
at TSL 4 are 17.4 Mt of CO2, 14.2
thousand tons of NOX, and 0.022 ton of
Hg. The estimated monetary value of the
CO2 emissions reductions at TSL 4
ranges from $77 million to $1,164
million. Total generating capacity in
2043 is estimated to decrease by 0.632
GW under TSL 4.
At TSL 4, DOE projects that the
average LCC impact is a savings (LCC
decrease) of $7 for room air conditioners
< 6,000 Btu/h, with louvers; a savings of
$22 for room air conditioners 8,000–
13,999 Btu/h, with louvers; a savings of
$6 for room air conditioners 20,000–
24,999 Btu/h, with louvers; a savings of
$1 for room air conditioners > 25,000
Btu/h, with louvers; a savings of $13 for
room air conditioners 8,000–10,999 Btu/
h, without louvers; and a savings of $11
for room air conditioners > 11,000 Btu/
h, without louvers. The median payback
period is 8.6 years for room air
conditioners < 6,000 Btu/h, with
louvers; 2.8 years for room air
conditioners 8,000–13,999 Btu/h, with
louvers; 4.3 years for room air
conditioners 20,000–24,999 Btu/h, with
louvers; 10.1 years for room air
conditioners > 25,000 Btu/h, with
louvers; 2.1 years for room air
conditioners 8,000–10,999 Btu/h,
without louvers; and 3.7 years for room
air conditioners > 11,000 Btu/h, without
louvers. The fraction of consumers
experiencing an LCC benefit is 34
percent for room air conditioners
< 6,000 Btu/h, with louvers; 64 percent
for room air conditioners 8,000–13,999
Btu/h, with louvers; 10 percent for room
air conditioners 20,000–24,999 Btu/h,
with louvers; 4 percent for room air
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conditioners > 25,000 Btu/h, with
louvers; 62 percent for room air
conditioners 8,000–10,999 Btu/h,
without louvers; and 47 percent for
room air conditioners > 11,000 Btu/h,
without louvers. The fraction of
consumers experiencing an LCC cost is
65 percent for room air conditioners
< 6,000 Btu/h, with louvers; 34 percent
for room air conditioners 8,000–13,999
Btu/h, with louvers; 5 percent for room
air conditioners 20,000–24,999 Btu/h,
with louvers; 9 percent for room air
conditioners > 25,000 Btu/h, with
louvers; 12 percent for room air
conditioners 8,000–10,999 Btu/h,
without louvers; and 23 percent for
room air conditioners > 11,000 Btu/h,
without louvers.
At TSL 4, the projected change in
INPV ranges from a decrease of $111.3
million to a decrease of $177.6 million.
DOE recognizes the risk of moderately
negative impacts if manufacturers’
expectations concerning reduced profit
margins are realized. If the high end of
the range of impacts is reached as DOE
expects, TSL 4 could result in a net loss
of 18.6 percent in INPV to room air
conditioner manufacturers.
The Secretary concludes that at TSL
4 for room air conditioners, the benefits
of energy savings, generating capacity
reductions, emission reductions and the
estimated monetary value of the CO2
emissions reductions, positive NPV of
consumer benefits and positive average
consumer LCC savings outweigh the
economic burden on some consumers (a
significant fraction for one product class
but small to moderate fractions for the
other product classes) due to the
increases in product cost, and the
capital conversion costs and profit
margin impacts that could result in a
moderate reduction in INPV for the
manufacturers.
In addition, the efficiency levels in
TSL 4 correspond to the recommended
levels in the consensus agreement,
which DOE believes sets forth a
statement by interested persons that are
fairly representative of relevant points
of view (including representatives of
manufacturers of covered products,
States, and efficiency advocates) and
contains recommendations with respect
to an energy conservation standard that
are in accordance with 42 U.S.C.
6295(o). Moreover, DOE has encouraged
the submission of consensus agreements
as a way to get diverse stakeholders
together, to develop an independent and
probative analysis useful in DOE
standard setting, and to expedite the
rulemaking process. DOE also believes
that standard levels recommended in
the consensus agreement may increase
the likelihood for regulatory
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compliance, while decreasing the risk of
litigation.
After considering the analysis,
comments on the preliminary TSD, and
the benefits and burdens of TSL 4, DOE
concludes that this trial standard level
will offer the maximum improvement in
efficiency that is technologically
feasible and economically justified, and
will result in the significant
conservation of energy. Therefore, DOE
today adopts TSL 4 for room air
conditioners. The amended energy
conservation standards for room air
conditioners, expressed as CEER, are
shown in Table V–53.
TABLE V–53—AMENDED ENERGY CONSERVATION STANDARDS FOR ROOM AIR CONDITIONERS
Room air conditioners
Minimum CEER
levels
Btu/Wh
Product class
1. Without reverse cycle, with louvered sides, and less than 6,000 Btu/h ...................................................................................
2. Without reverse cycle, with louvered sides, and 6,000 to 7,999 Btu/h ....................................................................................
3. Without reverse cycle, with louvered sides, and 8,000 to 13,999 Btu/h ..................................................................................
4. Without reverse cycle, with louvered sides, and 14,000 to 19,999 Btu/h ................................................................................
5a. Without reverse cycle, with louvered sides, and 20,000 to 24,999 Btu/h ..............................................................................
5b. Without reverse cycle, with louvered sides, and 25,000 Btu/h or more .................................................................................
6. Without reverse cycle, without louvered sides, and less than 6,000 Btu/h ..............................................................................
7. Without reverse cycle, without louvered sides, and 6,000 to 7,999 Btu/h ...............................................................................
8a. Without reverse cycle, without louvered sides, and 8,000 to 10,999 Btu/h ...........................................................................
8b. Without reverse cycle, without louvered sides, and 11,000 to 13,999 Btu/h .........................................................................
9. Without reverse cycle, without louvered sides, and 14,000 to 19,999 Btu/h ...........................................................................
10. Without reverse cycle, without louvered sides, and 20,000 Btu/h or more ............................................................................
11. With reverse cycle, with louvered sides, and less than 20,000 Btu/h ....................................................................................
12. With reverse cycle, without louvered sides, and less than 14,000 Btu/h ...............................................................................
13. With reverse cycle, with louvered sides, and 20,000 Btu/h or more ......................................................................................
14. With reverse cycle, without louvered sides, and 14,000 Btu/h or more .................................................................................
15. Casement-Only ........................................................................................................................................................................
16. Casement-Slider ......................................................................................................................................................................
3. Summary of Benefits and Costs
(Annualized) of the Standards
mstockstill on DSKH9S0YB1PROD with RULES2
The benefits and costs of today’s
standards can also be expressed in terms
of annualized values. The annualized
monetary values are the sum of (1) the
annualized national economic value,
expressed in 2009$, of the benefits from
operating products that meet the
proposed standards (consisting
primarily of operating cost savings from
using less energy, minus increases in
equipment purchase costs, which is
another way of representing consumer
NPV), and (2) the monetary value of the
benefits of emission reductions,
including CO2 emission reductions.66
The value of the CO2 reductions,
otherwise known as the Social Cost of
Carbon (SCC), is calculated using a
66 DOE used a two-step calculation process to
convert the time-series of costs and benefits into
annualized values. First, DOE calculated a present
value in 2011, the year used for discounting the
NPV of total consumer costs and savings, for the
time-series of costs and benefits using discount
rates of three and seven percent for all costs and
benefits except for the value of CO2 reductions. For
the latter, DOE used a range of discount rates, as
shown in Table V.50. From the present value, DOE
then calculated the fixed annual payment over a 30year period, starting in 2011, that yields the same
present value. The fixed annual payment is the
annualized value. Although DOE calculated
annualized values, this does not imply that the
time-series of cost and benefits from which the
annualized values were determined would be a
steady stream of payments.
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range of values per metric ton of CO2
developed by a recent interagency
process. The monetary costs and
benefits of cumulative emissions
reductions are reported in 2009$ to
permit comparisons with the other costs
and benefits in the same dollar units.
Although combining the values of
operating savings and CO2 reductions
provides a useful perspective, two
issues should be considered. First, the
national operating savings are domestic
U.S. consumer monetary savings that
occur as a result of market transactions
while the value of CO2 reductions is
based on a global value. Second, the
assessments of operating cost savings
and CO2 savings are performed with
different methods that use quite
different time frames for analysis. The
national operating cost savings is
measured for the lifetime of products
shipped in 2014–2043. The SCC values,
on the other hand, reflect the present
value of future climate-related impacts
resulting from the emission of one ton
of carbon dioxide in each year. These
impacts go well beyond 2100.
Table V–54 and Table V–55 show the
annualized values for clothes dryers and
room air conditioners, respectively.
Using a 7-percent discount rate and the
SCC value of $22.1/ton in 2010 (in
2009$), the cost of the standards for
clothes dryers in today’s rule is $52.3
million per year in increased equipment
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11.0
11.0
10.9
10.7
9.4
9.0
10.0
10.0
9.6
9.5
9.3
9.4
9.8
9.3
9.3
8.7
9.5
10.4
costs, while the annualized benefits are
$139.1 million per year in reduced
equipment operating costs, $25.0
million in CO2 reductions, and $0.9
million in reduced NOX emissions. In
this case, the net benefit amounts to
$112.7 million per year. DOE has
calculated that the annualized increased
equipment cost can range from $50.5 to
$66.6 million per year depending on
assumptions and modeling of
equipment price trends. The high end of
this range corresponds to a constant real
equipment price trend. Using the central
estimate of energy-related benefits, DOE
estimates that calculated net benefits
can range from $98.4 to $114.5 million
per year. Using a 3-percent discount rate
and the SCC value of $22.1/ton in 2010
(in 2009$), the cost of the standards for
clothes dryers in today’s rule is $55.4
million per year in increased equipment
costs, while the benefits are $209.1
million per year in reduced operating
costs, $25.0 million in CO2 reductions,
and $1.4 million in reduced NOX
emissions. In this case, the net benefit
amounts to $180.1 million per year.
DOE has calculated that the range in the
annualized increased equipment cost
can range from $53.1 to $73.5 million
per year depending on assumptions and
modeling of equipment price trends.
The high end of this range corresponds
to a constant real equipment price trend.
Using the central estimate of energy-
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related benefits, DOE estimates that
calculated net benefits can range from
$162.0 to $182.4 million per year.
Using a 7-percent discount rate and
the SCC value of $22.1/ton in 2010 (in
2009$), the cost of the standards for
room air conditioners in today’s rule is
$107.7 million per year in increased
equipment costs, while the annualized
benefits are $153.7 million per year in
reduced equipment operating costs,
$19.5 million in CO2 reductions, and
$0.999 million in reduced NOX
emissions. In this case, the net benefit
amounts to $66.4 million per year. DOE
has calculated that the annualized
increased equipment cost can range
from $105.7 to $136.6 million per year
depending on assumptions and
modeling of equipment price trends.
The high end of this range corresponds
to a constant real equipment price trend.
Using the central estimate of energyrelated benefits, DOE estimates that
calculated net benefits can range from
$37.5 to $68.4 million per year. Using a
3-percent discount rate and the SCC
value of $22.1/ton in 2010 (in 2009$),
the cost of the standards for room air
conditioners in today’s rule is $111.0
million per year in increased equipment
costs, while the benefits are $186.2
million per year in reduced operating
costs, $19.5 million in CO2 reductions,
and $1.20 million in reduced NOX
emissions. In this case, the net benefit
amounts to $95.9 million per year. DOE
has calculated that the range in the
annualized increased equipment cost
can range from $108.0 to $146.0 million
per year depending on assumptions and
modeling of equipment price trends.
The high end of this range corresponds
to a constant real equipment price trend.
Using the central estimate of energyrelated benefits, DOE estimates that
calculated net benefits can range from
$60.9 to $98.9 million per year.
TABLE V–54—ANNUALIZED BENEFITS AND COSTS OF AMENDED STANDARDS (TSL 4) FOR CLOTHES DRYERS SOLD IN
2014–2043
Monetized (million 2009$/year)
Discount rate
Primary estimate> *
Low estimate> *
High estimate> *
120.6
177.4
6.0
25.0
39.8
76.0
0.9
1.4
127.6 to 197.6
146.5
203.7
184.8 to 254.8
158.3
241.3
6.0
25.0
39.8
76.0
0.9
1.4
165.3 to 235.3
184.3
267.6
248.7 to 318.7
66.6
73.5
50.5
53.1
61.0 to 131.0
79.9
130.2
111.3 to 181.3
114.8 to 184.8
133.8
214.5
195.6 to 265.6
Benefits
Operating Cost Savings ...................
CO2 Reduction at $4.9/t ** ...............
CO2 Reduction at $22.1/t ** .............
CO2 Reduction at $36.3/t ** .............
CO2 Reduction at $67.1/t ** .............
NOX Reduction at $2,519/ton ** ......
Total† ........................................
7%
3%
5%
3%
2.5%
3%
7%
3%
7% plus CO2 range
7%
3%
3% plus CO2 range
139.1
209.1
6.0
25.0
39.8
76.0
0.9
1.4
146.1 to 216.1
165.0
235.4
216.5 to 286.5
Costs
Incremental Product Costs ..............
7%
3%
52.3
55.4
Total Net Benefits
Total † .......................................
7% plus CO2 range
7%
3%
3% plus CO2 range
93.7 to 163.7
112.7
180.1
161.1 to 231.1
* The Primary, Low, and High Estimates utilize forecasts of energy prices and housing starts from the AEO2010 Reference case, Low Economic Growth case, and High Economic Growth case, respectively. Low estimate corresponds to the low net benefit estimate and uses the zero
real price trend sensitivity for equipment prices, and the high estimate corresponds to the high net benefit estimate and utilizes the high technological learning rate sensitivity for the equipment price trend.
** The CO2 values represent global values (in 2009$) of the social cost of CO2 emissions in 2010 under several scenarios. The values of $4.9,
$22.1, and $36.3 per ton are the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.1 per ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. The value for
NOX (in 2009$) is the average of the low and high values used in DOE’s analysis.
† Total Benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 3-percent discount rate, which is
$22.1/ton in 2010 (in 2009$). In the rows labeled as ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are
calculated using the labeled discount rate, and those values are added to the full range of CO2 values.
TABLE V–55—ANNUALIZED BENEFITS AND COSTS OF AMENDED STANDARDS (TSL 4) FOR ROOM AIR CONDITIONERS
SOLD IN 2014–2043
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Monetized (million 2009$/year)
Discount rate
Primary estimate *
Low estimate *
High estimate *
145.1
174.2
5.0
19.5
161.9
197.3
5.0
19.5
Benefits
Operating Cost Savings ...................
CO2 Reduction at $4.9/t ** ...............
CO2 Reduction at $22.1/t ** .............
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7%
3%
5%
3%
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5.0
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TABLE V–55—ANNUALIZED BENEFITS AND COSTS OF AMENDED STANDARDS (TSL 4) FOR ROOM AIR CONDITIONERS
SOLD IN 2014–2043—Continued
Monetized (million 2009$/year)
Discount rate
Primary estimate *
CO2 Reduction at $36.3/t ** .............
CO2 Reduction at $67.1/t ** .............
NOX Reduction at $2,519/ton ** ......
Total † .......................................
2.5%
3%
7%
3%
7% plus CO2 range
7%
3%
3% plus CO2 range
Low estimate *
High estimate *
30.7
59.4
0.999
1.197
159.6 to 214.0
174.1
206.8
192.3 to 246.7
30.7
59.4
0.999
1.197
151.1 to 205.5
165.5
194.9
180.4 to 234.8
30.7
59.4
0.999
1.197
167.9 to 222.3
182.4
218.0
203.5 to 257.9
136.6
146.0
105.7
108.0
43.4 to 97.8
28.9
48.9
34.4 to 88.8
62.2 to 116.6
76.7
110.0
95.5 to 149.9
Costs
Incremental Product Costs ..............
7%
3%
107.7
111.0
Total Net Benefits
Total † .......................................
7% plus CO2 range
7%
3%
3% plus CO2 range
51.9 to 106.3
66.4
95.9
81.4 to 135.8
* The Primary, Low, and High Estimates utilize forecasts of energy prices and housing starts from the AEO2010 Reference case, Low Economic Growth case, and Low Economic Growth case, respectively. Low estimate corresponds to the low net benefit estimate and uses the zero
real price trend sensitivity for equipment prices, and the high estimate corresponds to the high net benefit estimate and utilizes the high technological learning rate sensitivity for the equipment price trend.
** The CO2 values represent global values (in 2009$) of the social cost of CO2 emissions in 2010 under several scenarios. The values of $4.9,
$22.1, and $36.3 per ton are the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.1 per ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. The value for
NOX (in 2009$) is the average of the low and high values used in DOE’s analysis.
† Total Benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 3-percent discount rate, which is
$22.1/ton in 2010 (in 2009$). In the rows labeled as ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are
calculated using the labeled discount rate, and those values are added to the full range of CO2 values.
mstockstill on DSKH9S0YB1PROD with RULES2
VI. Procedural Issues and Regulatory
Review
A. Review Under Executive Orders
12866 and 13563
Section 1(b)(1) of Executive Order
12866, ‘‘Regulatory Planning and
Review,’’ 58 FR 51735 (Oct. 4, 1993),
requires each agency to identify the
problem that it intends to address,
including, where applicable, the failures
of private markets or public institutions
that warrant new agency action, as well
as to assess the significance of that
problem. The problems that today’s
standards address are as follows:
(1) There is a lack of consumer
information and/or information
processing capability about energy
efficiency opportunities in clothes dryer
and room air conditioner market.
(2) There is asymmetric information
(one party to a transaction has more and
better information than the other) and/
or high transactions costs (costs of
gathering information and effecting
exchanges of goods and services).
(3) There are external benefits
resulting from improved energy
efficiency of clothes dryers and room air
conditioners that are not captured by
the users of such equipment. These
benefits include externalities related to
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environmental protection and energy
security that are not reflected in energy
prices, such as reduced emissions of
greenhouse gases.
In addition, DOE has determined that
today’s regulatory action is an
‘‘economically significant regulatory
action’’ under section 3(f)(1) of
Executive Order 12866. Accordingly,
section 6(a)(3) of the Executive Order
requires that DOE prepare a regulatory
impact analysis (RIA) on today’s rule
and that the Office of Information and
Regulatory Affairs (OIRA) in the Office
of Management and Budget (OMB)
review this rule. DOE presented to OIRA
for review the draft rule and other
documents prepared for this
rulemaking, including the RIA, and has
included these documents in the
rulemaking record. The assessments
prepared pursuant to Executive Order
12866 can be found in the technical
support document for this rulemaking.
They are available for public review in
the Resource Room of DOE’s Building
Technologies Program, 950 L’Enfant
Plaza, SW., Suite 600, Washington, DC
20024, (202) 586–2945, between 9 a.m.
and 4 p.m., Monday through Friday,
except Federal holidays.
DOE has also reviewed this regulation
pursuant to Executive Order 13563,
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issued on January 18, 2011 (76 FR 3281,
Jan. 21, 2011). EO 13563 is
supplemental to and explicitly reaffirms
the principles, structures, and
definitions governing regulatory review
established in Executive Order 12866.
To the extent permitted by law, agencies
are required by Executive Order 13563
to: (1) Propose or adopt a regulation
only upon a reasoned determination
that its benefits justify its costs
(recognizing that some benefits and
costs are difficult to quantify); (2) tailor
regulations to impose the least burden
on society, consistent with obtaining
regulatory objectives, taking into
account, among other things, and to the
extent practicable, the costs of
cumulative regulations; (3) select, in
choosing among alternative regulatory
approaches, those approaches that
maximize net benefits (including
potential economic, environmental,
public health and safety, and other
advantages; distributive impacts; and
equity); (4) to the extent feasible, specify
performance objectives, rather than
specifying the behavior or manner of
compliance that regulated entities must
adopt; and (5) identify and assess
available alternatives to direct
regulation, including providing
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economic incentives to encourage the
desired behavior, such as user fees or
marketable permits, or providing
information upon which choices can be
made by the public.
We emphasize as well that Executive
Order 13563 requires agencies ‘‘to use
the best available techniques to quantify
anticipated present and future benefits
and costs as accurately as possible.’’ In
its guidance, the Office of Information
and Regulatory Affairs has emphasized
that such techniques may include
‘‘identifying changing future compliance
costs that might result from
technological innovation or anticipated
behavioral changes.’’ For the reasons
stated in the preamble, DOE believes
that today’s direct final rule is
consistent with these principles,
including that, to the extent permitted
by law, agencies adopt a regulation only
upon a reasoned determination that its
benefits justify its costs and select, in
choosing among alternative regulatory
approaches, those approaches that
maximize net benefits.
B. Review Under the Regulatory
Flexibility Act
The Regulatory Flexibility Act (5
U.S.C. 601 et seq.) requires preparation
of a final regulatory flexibility analysis
(FRFA) for any rule that by law must be
proposed for public comment, unless
the agency certifies that the rule, if
promulgated, will not have a significant
economic impact on a substantial
number of small entities. As required by
Executive Order 13272, ‘‘Proper
Consideration of Small Entities in
Agency Rulemaking’’ 67 FR 53461 (Aug.
16, 2002), DOE published procedures
and policies on February 19, 2003, to
ensure that the potential impacts of its
rules on small entities are properly
considered during the rulemaking
process. 68 FR 7990. DOE has made its
procedures and policies available on the
Office of the General Counsel’s Web site
(https://www.gc.doe.gov).
For the manufacturers of residential
clothes dryers and room air
conditioners, the Small Business
Administration (SBA) has set a size
threshold, which defines those entities
classified as ‘‘small businesses’’ for the
purposes of the statute. DOE used the
SBA’s small business size standards to
determine whether any small entities
would be subject to the requirements of
the rule. 65 FR 30836, 30850 (May 15,
2000), as amended at 65 FR 53533,
53545 (Sept. 5, 2000) and codified at 13
CFR part 121. The size standards are
listed by NAICS code and industry
description and are available at https://
www.sba.gov/idc/groups/public/
documents/sba_homepage/
serv_sstd_tablepdf.pdf. Residential
clothes dryer manufacturing is classified
under NAICS Code 335224, ‘‘Household
Laundry Equipment Manufacturing’’ and
room air conditioner manufacturing is
classified under NAICS Code 333415,
‘‘Air-Conditioning and Warm Air
Heating Equipment and Commercial
and Industrial Refrigeration Equipment
Manufacturing.’’ The SBA sets a
threshold of 1,000 employees or less
and 750 employees or less, respectively,
for these categories in order for an entity
to be considered as a small business, as
shown in Table VI–1.
TABLE VI–1—SBA CLASSIFICATION OF SMALL BUSINESSES POTENTIALLY AFFECTED BY THIS RULE
Revenue
limit
Employee
limit
Household Laundry Equipment Manufacturing .....................................................................................................
Air-Conditioning and Warm Air Heating Equipment and Commercial and Industrial Refrigeration Equipment
Manufacturing.
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Industry description
N/A .......
N/A .......
1,000
750
DOE reviewed the potential standard
levels considered in today’s notice
under the provisions of the Regulatory
Flexibility Act and the procedures and
policies published on February 19,
2003. To estimate the number of small
businesses that could be impacted by
the amended energy conservation
standards, DOE conducted a market
survey using all available public
information to identify potential small
manufacturers. DOE’s research included
the AHAM membership directory,
product databases (the AHRI, AHAM,
CEC, and ENERGY STAR databases),
individual company Web sites, and the
SBA dynamic small business search to
find potential small business
manufacturers. DOE also asked
stakeholders and industry
representatives if they were aware of
any other small business manufacturers
during manufacturer interviews and at
previous DOE public meetings. DOE
reviewed all publicly available data and
contacted various companies, as
necessary, to determine whether they
met the SBA’s definition of a small
business manufacturer of covered
residential clothes dryers or room air
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conditioners. DOE screened out
companies that did not offer products
covered by this rulemaking, did not
meet the definition of a ‘‘small
business,’’ or are foreign owned and
operated.
1. Residential Clothes Dryer Industry
The majority of residential clothes
dryers are currently manufactured in the
United States by one corporation that
accounts for over 70 percent of the
market. Two additional large
manufacturers with foreign and
domestic production hold much of the
remaining share of the market. The
small portion of the remaining
residential clothes dryer market is
supplied by a combination of
international and domestic companies,
all of which have small market shares.
Based on its review of the dynamic
small business search on the SBA Web
site (https://dsbs.sba.gov/dsbs/search/
dsp_dsbs.cfm), the Central Contracting
Registration (https://www.bpn.gov/
CCRSearch/Search.aspx), and input
from commenters, DOE identified only
one manufacturer who could potentially
be considered a small business under
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NAICS
335224
333415
NAICS Code 335224, ‘‘Household
Laundry Equipment Manufacturing.’’
DOE does not believe, however, that this
company would be directly impacted by
the standards established for clothes
dryers in today’s final rule. DOE notes
that while the potential small business
manufacturer has developed a highly
efficient technology that could be used
by other manufacturers to increase the
efficiency of clothes dryers, the
company does not produce clothes
dryers and the technology is not yet
commercially available. DOE
acknowledges that the technology
developed by this small business is a
potential design option for clothes
dryers, but DOE does not believe this
rulemaking would in any way affect the
ability of this company to
commercialize or sell its technology.
2. Room Air Conditioner Industry
No room air conditioners are
manufactured in the United States. Most
manufacturing takes place in Asia,
primarily China, with limited
production in Mexico. In recent years at
least two major manufacturers have
exited the market. At least three major
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corporations supply a majority of the
market. The remaining market share is
held by several large companies. DOE
did not identify any small business
manufacturers of room air conditioners.
For room air conditioners, DOE
initially identified at least 11 distinct
manufacturers of room air conditioners
sold in the United States. DOE initially
determined that 10 of these were large
or foreign-owned and operated. DOE
determined that the one room air
conditioner manufacturer that was
previously designated as a small
business manufacturer was acquired by
another company and now exceeds
SBA’s employment threshold for
consideration as a small business under
the appropriate NAICS code. As such,
DOE did not identify any small business
manufacturers of room air conditioners.
Based on the discussion above, DOE
certifies that the standards for clothes
dryers and room air conditioners set
forth in today’s rule would not have a
significant economic impact on a
substantial number of small entities.
Accordingly, DOE has not prepared a
regulatory flexibility analysis for this
rulemaking. DOE will transmit this
certification to SBA as required by 5
U.S.C. 605(b).
C. Review Under the Paperwork
Reduction Act
Manufacturers of clothes dryers and
room air conditioners must certify to
DOE that their products comply with
any applicable energy conservation
standards. In certifying compliance,
manufacturers must test their products
according to the DOE test procedures for
clothes dryers and room air
conditioners, including any
amendments adopted for those test
procedures. DOE has proposed
regulations for the certification and
recordkeeping requirements for all
covered consumer products and
commercial equipment, including
clothes dryers and room air
conditioners. 75 FR 56796 (Sept. 16,
2010). The collection-of-information
requirement for the certification and
recordkeeping is subject to review and
approval by OMB under the Paperwork
Reduction Act (PRA). This requirement
has been submitted to OMB for
approval. Public reporting burden for
the certification is estimated to average
20 hours per response, including the
time for reviewing instructions,
searching existing data sources,
gathering and maintaining the data
needed, and completing and reviewing
the collection of information.
Notwithstanding any other provision
of the law, no person is required to
respond to, nor shall any person be
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subject to a penalty for failure to comply
with, a collection of information subject
to the requirements of the PRA, unless
that collection of information displays a
currently valid OMB Control Number.
D. Review Under the National
Environmental Policy Act
DOE has prepared an environmental
assessment (EA) of the impacts of the
direct final rule pursuant to the National
Environmental Policy Act of 1969 (42
U.S.C. 4321 et seq.), the regulations of
the Council on Environmental Quality
(40 CFR parts 1500–1508), and DOE’s
regulations for compliance with the
National Environmental Policy Act (10
CFR part 1021). This assessment
includes an examination of the potential
effects of emission reductions likely to
result from the rule in the context of
global climate change, as well as other
types of environmental impacts. The EA
has been incorporated into the direct
final rule TSD as chapter 15. DOE found
that the environmental effects
associated with the standards for clothes
dryers and room air conditioners were
not significant. Therefore, DOE is
issuing a Finding of No Significant
Impact (FONSI), pursuant to NEPA, the
regulations of the Council on
Environmental Quality (40 CFR parts
1500–1508), and DOE’s regulations for
compliance with NEPA (10 CFR part
1021). The FONSI is available in the
docket for this rulemaking.
E. Review Under Executive Order 13132
Executive Order 13132, ‘‘Federalism,’’
64 FR 43255 (August 4, 1999), imposes
certain requirements on agencies
formulating and implementing policies
or regulations that preempt State law or
that have federalism implications. The
Executive Order requires agencies to
examine the constitutional and statutory
authority supporting any action that
would limit the policymaking discretion
of the States and to carefully assess the
necessity for such actions. The
Executive Order also requires agencies
to have an accountable process to
ensure meaningful and timely input by
State and local officials in the
development of regulatory policies that
have federalism implications. On March
14, 2000, DOE published a statement of
policy describing the intergovernmental
consultation process it will follow in the
development of such regulations. 65 FR
13735. EPCA governs and prescribes
Federal preemption of State regulations
as to energy conservation for the
products that are the subject of today’s
direct final rule. States can petition DOE
for exemption from such preemption to
the extent, and based on criteria, set
forth in EPCA. (42 U.S.C. 6297) No
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22561
further action is required by Executive
Order 13132.
F. Review Under Executive Order 12988
With respect to the review of existing
regulations and the promulgation of
new regulations, section 3(a) of
Executive Order 12988, ‘‘Civil Justice
Reform’’ imposes on Federal agencies
the general duty to adhere to the
following requirements: (1) Eliminate
drafting errors and ambiguity; (2) write
regulations to minimize litigation; and
(3) provide a clear legal standard for
affected conduct rather than a general
standard and promote simplification
and burden reduction. 61 FR 4729
(February 7, 1996). Section 3(b) of
Executive Order 12988 specifically
requires that Executive agencies make
every reasonable effort to ensure that the
regulation: (1) Clearly specifies the
preemptive effect, if any; (2) clearly
specifies any effect on existing Federal
law or regulation; (3) provides a clear
legal standard for affected conduct
while promoting simplification and
burden reduction; (4) specifies the
retroactive effect, if any; (5) adequately
defines key terms; and (6) addresses
other important issues affecting clarity
and general draftsmanship under any
guidelines issued by the Attorney
General. Section 3(c) of Executive Order
12988 requires Executive agencies to
review regulations in light of applicable
standards in section 3(a) and section
3(b) to determine whether they are met
or it is unreasonable to meet one or
more of them. DOE has completed the
required review and determined that, to
the extent permitted by law, this direct
final rule meets the relevant standards
of Executive Order 12988.
G. Review Under the Unfunded
Mandates Reform Act of 1995
Title II of the Unfunded Mandates
Reform Act of 1995 (UMRA) requires
each Federal agency to assess the effects
of Federal regulatory actions on State,
local, and Tribal governments and the
private sector. Public Law. 104–4, sec.
201 (codified at 2 U.S.C. 1531). For a
proposed regulatory action likely to
result in a rule that may cause the
expenditure by State, local, and Tribal
governments, in the aggregate, or by the
private sector of $100 million or more
in any one year (adjusted annually for
inflation), section 202 of UMRA requires
a Federal agency to publish a written
statement that estimates the resulting
costs, benefits, and other effects on the
national economy. (2 U.S.C. 1532(a), (b))
The UMRA also requires a Federal
agency to develop an effective process
to permit timely input by elected
officers of State, local, and Tribal
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governments on a proposed ‘‘significant
intergovernmental mandate,’’ and
requires an agency plan for giving notice
and opportunity for timely input to
potentially affected small governments
before establishing any requirements
that might significantly or uniquely
affect small governments. On March 18,
1997, DOE published a statement of
policy on its process for
intergovernmental consultation under
UMRA. 62 FR 12820; also available at
https://www.gc.doe.gov.
Although today’s rule does not
contain a Federal intergovernmental
mandate, it may impose expenditures of
$100 million or more on the private
sector. Specifically, the final rule could
impose expenditures of $100 million or
more. Such expenditures may include
(1) investment in research and
development and in capital
expenditures by home appliance
manufacturers in the years between the
final rule and the compliance date for
the new standard, and (2) incremental
additional expenditures by consumers
to purchase higher efficiency home
appliances.
Section 202 of UMRA authorizes an
agency to respond to the content
requirements of UMRA in any other
statement or analysis that accompanies
the proposed rule. 2 U.S.C. 1532(c). The
content requirements of section 202(b)
of UMRA relevant to a private sector
mandate substantially overlap the
economic analysis requirements that
apply under section 325(o) of EPCA and
Executive Order 12866. The
Supplementary Information section of
this notice and the ‘‘Regulatory Impact
Analysis’’ section of the direct final rule
TSD for this rule respond to those
requirements.
Under section 205 of UMRA, the
Department is obligated to identify and
consider a reasonable number of
regulatory alternatives before
promulgating a rule for which a written
statement under section 202 is required.
2 U.S.C. 1535(a). DOE is required to
select from those alternatives the most
cost-effective and least burdensome
alternative that achieves the objectives
of the rule unless DOE publishes an
explanation for doing otherwise or the
selection of such an alternative is
inconsistent with law. As required by 42
U.S.C. 6295(h) and (o), 6313(e), and
6316(a), today’s rule would establish
energy conservation standards for
clothes dryers and room air conditioners
that are designed to achieve the
maximum improvement in energy
efficiency that DOE has determined to
be both technologically feasible and
economically justified. A full discussion
of the alternatives considered by DOE is
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presented in the ‘‘Regulatory Impact
Analysis’’ section of the direct final rule
TSD.
H. Review Under the Treasury and
General Government Appropriations
Act, 1999
Section 654 of the Treasury and
General Government Appropriations
Act, 1999 (Pub. L. 105–277) requires
Federal agencies to issue a Family
Policymaking Assessment for any rule
that may affect family well-being. This
rule would not have any impact on the
autonomy or integrity of the family as
an institution. Accordingly, DOE has
concluded that it is not necessary to
prepare a Family Policymaking
Assessment.
I. Review Under Executive Order 12630
DOE has determined, under Executive
Order 12630, ‘‘Governmental Actions
and Interference with Constitutionally
Protected Property Rights,’’ 53 FR 8859
(March 18, 1988), that this regulation
would not result in any takings which
might require compensation under the
Fifth Amendment to the U.S.
Constitution.
J. Review Under the Treasury and
General Government Appropriations
Act, 2001
Section 515 of the Treasury and
General Government Appropriations
Act, 2001 (44 U.S.C. 3516, note)
provides for agencies to review most
disseminations of information to the
public under guidelines established by
each agency pursuant to general
guidelines issued by OMB. OMB’s
guidelines were published at 67 FR
8452 (Feb. 22, 2002), and DOE’s
guidelines were published at 67 FR
62446 (Oct. 7, 2002). DOE has reviewed
today’s notice under the OMB and DOE
guidelines and has concluded that it is
consistent with applicable policies in
those guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ‘‘Actions
Concerning Regulations That
Significantly Affect Energy Supply,
Distribution, or Use,’’ 66 FR 28355 (May
22, 2001), requires Federal agencies to
prepare and submit to OIRA at OMB, a
Statement of Energy Effects for any
proposed significant energy action. A
‘‘significant energy action’’ is defined as
any action by an agency that
promulgates or is expected to lead to
promulgation of a final rule, and that (1)
is a significant regulatory action under
Executive Order 12866, or any successor
order; and (2) is likely to have a
significant adverse effect on the supply,
distribution, or use of energy, or (3) is
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designated by the Administrator of
OIRA as a significant energy action. For
any proposed significant energy action,
the agency must give a detailed
statement of any adverse effects on
energy supply, distribution, or use
should the proposal be implemented,
and of reasonable alternatives to the
action and their expected benefits on
energy supply, distribution, and use.
DOE has concluded that today’s
regulatory action, which sets forth
energy conservation standards for
clothes dryers and room air
conditioners, is not a significant energy
action because the proposed standards
are not likely to have a significant
adverse effect on the supply,
distribution, or use of energy, nor has it
been designated as such by the
Administrator at OIRA. Accordingly,
DOE has not prepared a Statement of
Energy Effects on the direct final rule.
L. Review Under the Information
Quality Bulletin for Peer Review
On December 16, 2004, OMB, in
consultation with the Office of Science
and Technology (OSTP), issued its Final
Information Quality Bulletin for Peer
Review (the Bulletin). 70 FR 2664 (Jan.
14, 2005). The Bulletin establishes that
certain scientific information shall be
peer reviewed by qualified specialists
before it is disseminated by the Federal
Government, including influential
scientific information related to agency
regulatory actions. The purpose of the
bulletin is to enhance the quality and
credibility of the Government’s
scientific information. Under the
Bulletin, the energy conservation
standards rulemaking analyses are
‘‘influential scientific information,’’
which the Bulletin defines as ‘‘scientific
information the agency reasonably can
determine will have, or does have, a
clear and substantial impact on
important public policies or private
sector decisions.’’ 70 FR 2667.
In response to OMB’s Bulletin, DOE
conducted formal in-progress peer
reviews of the energy conservation
standards development process and
analyses and has prepared a Peer
Review Report pertaining to the energy
conservation standards rulemaking
analyses. Generation of this report
involved a rigorous, formal, and
documented evaluation using objective
criteria and qualified and independent
reviewers to make a judgment as to the
technical/scientific/business merit, the
actual or anticipated results, and the
productivity and management
effectiveness of programs and/or
projects. The ‘‘Energy Conservation
Standards Rulemaking Peer Review
Report’’ dated February 2007 has been
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disseminated and is available at the
following Web site: https://
www1.eere.energy.gov/buildings/
appliance_standards/peer_review.html.
M. Congressional Notification
As required by 5 U.S.C. 801, DOE will
report to Congress on the promulgation
of this rule prior to its effective date.
The report will state that it has been
determined that the rule is not a ‘‘major
rule’’ as defined by 5 U.S.C. 804(2).
VII. Public Participation
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A. Submission of Comments
DOE will accept comments, data, and
information regarding this direct final
rule no later than the date provided in
the DATES section at the beginning of
this rule. Interested parties may submit
comments using any of the methods
described in the ADDRESSES section at
the beginning of this notice.
Submitting comments via
regulations.gov. The regulations.gov
Web page will require you to provide
your name and contact information.
Your contact information will be
viewable to DOE Building Technologies
staff only. Your contact information will
not be publicly viewable except for your
first and last names, organization name
(if any), and submitter representative
name (if any). If your comment is not
processed properly because of technical
difficulties, DOE will use this
information to contact you. If DOE
cannot read your comment due to
technical difficulties and cannot contact
you for clarification, DOE may not be
able to consider your comment.
However, your contact information
will be publicly viewable if you include
it in the comment or in any documents
attached to your comment. Any
information that you do not want to be
publicly viewable should not be
included in your comment, nor in any
document attached to your comment.
Persons viewing comments will see only
first and last names, organization
names, correspondence containing
comments, and any documents
submitted with the comments.
Do not submit to regulations.gov
information for which disclosure is
restricted by statute, such as trade
secrets and commercial or financial
information (hereinafter referred to as
Confidential Business Information
(CBI)). Comments submitted through
regulations.gov cannot be claimed as
CBI. Comments received through the
Web site will waive any CBI claims for
the information submitted. For
information on submitting CBI, see the
Confidential Business Information
section.
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DOE processes submissions made
through regulations.gov before posting.
Normally, comments will be posted
within a few days of being submitted.
However, if large volumes of comments
are being processed simultaneously,
your comment may not be viewable for
up to several weeks. Please keep the
comment tracking number that
regulations.gov provides after you have
successfully uploaded your comment.
Submitting comments via email, hand
delivery, or mail. Comments and
documents submitted via email, hand
delivery, or mail also will be posted to
regulations.gov. If you do not want your
personal contact information to be
publicly viewable, do not include it in
your comment or any accompanying
documents. Instead, provide your
contact information on a cover letter.
Include your first and last names, email
address, telephone number, and
optional mailing address. The cover
letter will not be publicly viewable as
long as it does not include any
comments.
Include contact information each time
you submit comments, data, documents,
and other information to DOE. Email
submissions are preferred. If you submit
via mail or hand delivery, please
provide all items on a CD, if feasible. It
is not necessary to submit printed
copies. No facsimiles (faxes) will be
accepted.
Comments, data, and other
information submitted to DOE
electronically should be provided in
PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file
format. Provide documents that are not
secured, written in English and are free
of any defects or viruses. Documents
should not contain special characters or
any form of encryption and, if possible,
they should carry the electronic
signature of the author.
Campaign form letters. Please submit
campaign form letters by the originating
organization in batches of between 50 to
500 form letters per PDF or as one form
letter with a list of supporters’ names
compiled into one or more PDFs. This
reduces comment processing and
posting time.
Confidential Business Information.
According to 10 CFR 1004.11, any
person submitting information that he
or she believes to be confidential and
exempt by law from public disclosure
should submit via email, postal mail, or
hand delivery two well-marked copies:
one copy of the document marked
confidential including all the
information believed to be confidential,
and one copy of the document marked
non-confidential with the information
believed to be confidential deleted.
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Submit these documents via email or on
a CD, if feasible. DOE will make its own
determination about the confidential
status of the information and treat it
according to its determination.
Factors of interest to DOE when
evaluating requests to treat submitted
information as confidential include: (1)
A description of the items; (2) whether
and why such items are customarily
treated as confidential within the
industry; (3) whether the information is
generally known by or available from
other sources; (4) whether the
information has previously been made
available to others without obligation
concerning its confidentiality; (5) an
explanation of the competitive injury to
the submitting person which would
result from public disclosure; (6) when
such information might lose its
confidential character due to the
passage of time; and (7) why disclosure
of the information would be contrary to
the public interest.
It is DOE’s policy that all comments
may be included in the public docket,
without change and as received,
including any personal information
provided in the comments (except
information deemed to be exempt from
public disclosure).
VIII. Approval of the Office of the
Secretary
The Secretary of Energy has approved
publication of today’s direct final rule.
List of Subjects in 10 CFR Part 430
Administrative practice and
procedure, Confidential business
information, Energy conservation,
Household appliances, Reporting and
recordkeeping requirements, and Small
businesses.
Issued in Washington, DC, on April 8,
2011.
Kathleen Hogan,
Deputy Assistant Secretary for Energy
Efficiency, Office of Technology
Development, Energy Efficiency and
Renewable Energy.
For the reasons set forth in the
preamble, DOE amends chapter II,
subchapter D, of title 10 of the Code of
Federal Regulations, as set forth below:
PART 430—ENERGY CONSERVATION
PROGRAM FOR CONSUMER
PRODUCTS
1. The authority citation for part 430
continues to read as follows:
■
Authority: 42 U.S.C. 6291–6309; 28 U.S.C.
2461 note.
2. Revise § 430.32 paragraphs (b), and
(h) to read as follows:
■
E:\FR\FM\21APR2.SGM
21APR2
22564
Federal Register / Vol. 76, No. 77 / Thursday, April 21, 2011 / Rules and Regulations
§ 430.32 Energy and water conservation
standards and effective dates.
*
*
*
*
(b) Room air conditioners.
*
Energy efficiency
ratio, effective
from Oct. 1, 2000
to April 20, 2014
Product class
Combined energy
efficiency ratio,
effective as of
April 21, 2014
9.7
9.7
9.8
9.7
8.5
8.5
9.0
9.0
8.5
8.5
8.5
8.5
9.0
8.5
8.5
8.0
8.7
9.5
11.0
11.0
10.9
10.7
9.4
9.0
10.0
10.0
9.6
9.5
9.3
9.4
9.8
9.3
9.3
8.7
9.5
10.4
1. Without reverse cycle, with louvered sides, and less than 6,000 Btu/h .................................................
2. Without reverse cycle, with louvered sides, and 6,000 to 7,999 Btu/h ..................................................
3. Without reverse cycle, with louvered sides, and 8,000 to 13,999 Btu/h ................................................
4. Without reverse cycle, with louvered sides, and 14,000 to 19,999 Btu/h ..............................................
5a. Without reverse cycle, with louvered sides, and 20,000 to 24,999 Btu/h ............................................
5b. Without reverse cycle, with louvered sides, and 25,000 Btu/h or more ...............................................
6. Without reverse cycle, without louvered sides, and less than 6,000 Btu/h ............................................
7. Without reverse cycle, without louvered sides, and 6,000 to 7,999 Btu/h .............................................
8a. Without reverse cycle, without louvered sides, and 8,000 to 10,999 Btu/h .........................................
8b. Without reverse cycle, without louvered sides, and 11,000 to 13,999 Btu/h .......................................
9. Without reverse cycle, without louvered sides, and 14,000 to 19,999 Btu/h .........................................
10. Without reverse cycle, without louvered sides, and 20,000 Btu/h or more ..........................................
11. With reverse cycle, with louvered sides, and less than 20,000 Btu/h ..................................................
12. With reverse cycle, without louvered sides, and less than 14,000 Btu/h .............................................
13. With reverse cycle, with louvered sides, and 20,000 Btu/h or more ....................................................
14. With reverse cycle, without louvered sides, and 14,000 Btu/h or more ...............................................
15. Casement-Only ......................................................................................................................................
16. Casement-Slider ....................................................................................................................................
*
*
*
*
*
(h) Clothes dryers. (1) Gas clothes
dryers manufactured after January 1,
1988 shall not be equipped with a
constant burning pilot.
(2) Clothes dryers manufactured on or
after May 14, 1994 and before April 21,
2014, shall have an energy factor no less
than:
Energy factor
(lbs/kWh)
Product class
i. Electric, Standard (4.4 ft3 or greater capacity) ...........................................................................................................................
ii. Electric, Compact (120V) (less than 4.4 ft3 capacity) ...............................................................................................................
iii. Electric, Compact (240V) (less than 4.4 ft3 capacity) ..............................................................................................................
iv. Gas ............................................................................................................................................................................................
3.01
3.13
2.90
2.67
(3) Clothes dryers manufactured on or
after April 21, 2014, shall have a
combined energy factor no less than:
Combined energy
factor
(lbs/kWh)
Product class
i. Vented Electric, Standard (4.4 ft3 or greater capacity) ..............................................................................................................
ii. Vented Electric, Compact (120V) (less than 4.4 ft3 capacity) ...................................................................................................
iii. Vented Electric, Compact (240V) (less than 4.4 ft3 capacity) ..................................................................................................
iv. Vented Gas ...............................................................................................................................................................................
v. Ventless Electric, Compact (240V) (less than 4.4 ft3 capacity) ................................................................................................
vi. Ventless Electric, Combination Washer-Dryer .........................................................................................................................
*
*
*
*
*
[FR Doc. 2011–9040 Filed 4–20–11; 8:45 am]
mstockstill on DSKH9S0YB1PROD with RULES2
BILLING CODE 6450–01–P
VerDate Mar<15>2010
18:27 Apr 20, 2011
Jkt 223001
PO 00000
Frm 00112
Fmt 4701
Sfmt 9990
E:\FR\FM\21APR2.SGM
21APR2
3.73
3.61
3.27
3.30
2.55
2.08
Agencies
[Federal Register Volume 76, Number 77 (Thursday, April 21, 2011)]
[Rules and Regulations]
[Pages 22454-22564]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-9040]
[[Page 22453]]
Vol. 76
Thursday,
No. 77
April 21, 2011
Part II
Department of Energy
-----------------------------------------------------------------------
10 CFR Part 430
Energy Conservation Program: Energy Conservation Standards for
Residential Clothes Dryers and Room Air Conditioners; Final Rule
Federal Register / Vol. 76 , No. 77 / Thursday, April 21, 2011 /
Rules and Regulations
[[Page 22454]]
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket Number EERE-2007-BT-STD-0010]
RIN 1904-AA89
Energy Conservation Program: Energy Conservation Standards for
Residential Clothes Dryers and Room Air Conditioners
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Direct final rule.
-----------------------------------------------------------------------
SUMMARY: The Energy Policy and Conservation Act (EPCA) prescribes
energy conservation standards for various consumer products and
commercial and industrial equipment, including residential clothes
dryers and room air conditioners. EPCA also requires the U.S.
Department of Energy (DOE) to determine if amended standards for these
products are technologically feasible and economically justified, and
would save a significant amount of energy. In this direct final rule,
DOE adopts amended energy conservation standards for residential
clothes dryers and room air conditioners. A notice of proposed
rulemaking that proposes identical energy efficiency standards is
published elsewhere in today's Federal Register. If DOE receives
adverse comment and determines that such comment may provide a
reasonable basis for withdrawing the direct final rule, this final rule
will be withdrawn and DOE will proceed with the proposed rule.
DATES: The final rule is effective on August 19, 2011 unless adverse
comment is received by August 9, 2011. If adverse comments are received
that DOE determines may provide a reasonable basis for withdrawal of
the final rule, a timely withdrawal of this rule will be published in
the Federal Register. If no such adverse comments are received,
compliance with the standards in this final rule will be required on
April 21, 2014.
ADDRESSES: Any comments submitted must identify the direct final rule
for Energy Conservation Standards for Residential Clothes Dryers and
Room Air Conditioners, and provide docket number EERE-2007-BT-STD-0010
and/or regulatory information number (RIN) number 1904-AA89. Comments
may be submitted using any of the following methods:
1. Federal eRulemaking Portal: https://www.regulations.gov. Follow
the instructions for submitting comments.
2. E-mail: home_appliance2.rulemaking@ee.doe.gov. Include the
docket number and/or RIN in the subject line of the message.
3. Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building
Technologies Program, Mailstop EE-2J, 1000 Independence Avenue, SW.,
Washington, DC 20585-0121. If possible, please submit all items on a
CD. It is not necessary to include printed copies.
4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Program, 950 L'Enfant Plaza, SW., Suite
600, Washington, DC 20024. Telephone: (202) 586-2945. If possible,
please submit all items on a CD. It is not necessary to include printed
copies.
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section VII of this document
(Public Participation).
Docket: The docket is available for review at regulations.gov,
including Federal Register notices, framework documents, public meeting
attendee lists and transcripts, comments, and other supporting
documents/materials. All documents in the docket are listed in the
regulations.gov index. Not all documents listed in the index may be
publicly available, such as information that is exempt from public
disclosure. A link to the docket web page can be found at https://www.regulations.gov.
For further information on how to submit or review public comments
or view hard copies of the docket in the Resource Room, contact Ms.
Brenda Edwards at (202) 586-2945 or e-mail: Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT:
Stephen L. Witkowski, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Program, EE-2J,
1000 Independence Avenue, SW., Washington, DC 20585-0121, (202) 586-
7463, e-mail: stephen.witkowski@ee.doe.gov.
Ms. Elizabeth Kohl, U.S. Department of Energy, Office of General
Counsel, GC-71, 1000 Independence Avenue, SW., Washington, DC 20585-
0121, (202) 586-7796, e-mail: Elizabeth.Kohl@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Summary of the Direct Final Rule
A. The Energy Conservation Standard Levels
B. Benefits and Costs to Consumerss
C. Impact on Manufacturers
D. National Benefits
E. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for Residential Clothes
Dryers and Room Air Conditioners
3. Consensus Agreement for Residential Clothes Dryers and Room
Air Conditioners
III. General Discussion
A. Test Procedures
1. Clothes Dryer Test Procedure
a. Standby Mode and Off Mode
b. Automatic Cycle Termination
c. Ventless Clothes Dryers
d. Consumer Usage Habits
e. Drum Capacity Measurement
f. HVAC Effects
g. Efficiency Metric
2. Room Air Conditioner Test Procedure
a. Standby Mode and Off Mode
b. Active Mode Referenced Standards
c. Annual Active Mode Hours
d. Part-Load Operation
e. Distribution of Air
3. Effects of Test Procedure Revisions on the Measured
Efficiency
a. Clothes Dryers
b. Room Air Conditioners
B. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
a. Clothes Dryers
b. Room Air Conditioners
c. Available Max-Tech Products With Higher EER Ratings
d. Consideration of Conversion to R-410A Refrigerant in Max-Tech
Selections
C. Energy Savings
1. Determination of Savings
2. Significance of Savings
D. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Life-Cycle Costs
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
A. Market and Technology Assessment
1. General
2. Products Included in This Rulemaking
a. Clothes Dryers
b. Room Air Conditioners
3. Product Classes
a. Clothes Dryers
b. Room Air Conditioners
4. Non-Regulatory Programs
5. Technology Options
a. Clothes Dryers
b. Room Air Conditioners
B. Screening Analysis
1. Clothes Dryers
2. Room Air Conditioners
C. Engineering Analysis
1. Technologies Not Analyzed
a. Clothes Dryers
b. Room Air Conditioners
2. Efficiency Levels and Cost-Efficiency Results
[[Page 22455]]
a. Clothes Dryers
b. Room Air Conditioners
D. Markups Analysis
E. Energy Use Analysis
1. Clothes Dryers
2. Room Air Conditioners
F. Life-Cycle Cost and Payback Period Analyses
1. Product Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Energy Price Projections
6. Maintenance and Repair Costs
7. Product Lifetime
8. Discount Rates
a. Residential Discount Rates
b. Commercial Discount Rates
9. Compliance Date of Amended Standards
10. Base Case Efficiency Distribution
11. Inputs to Payback Period Analysis
12. Rebuttable-Presumption Payback Period
G. National Impact Analysis--National Energy Savings and Net
Present Value Analysis
1. Shipments
2. Forecasted Efficiency in the Base Case and Standards Cases
3. National Energy Savings
4. Net Present Value of Consumer Benefit
5. Benefits From Effects of Standards on Energy Prices
H. Consumer Subgroup Analysis
I. Manufacturer Impact Analysis
1. Overview
a. Phase 1, Industry Profile
b. Phase 2, Industry Cash Flow Analysis
c. Phase 3, Sub-Group Impact Analysis
2. GRIM Analysis
a. GRIM Key Inputs
b. GRIM Scenarios
3. Discussion of Comments
a. Small Businesses
b. Cumulative Regulatory Burden
c. Employment Impacts
4. Manufacturer Interviews
a. Clothes Dryer Key Issues
b. Room Air Conditioner Key Issues
J. Employment Impact Analysis
K. Utility Impact Analysis
L. Environmental Assessment
M. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Social Cost of Carbon Values Used in Past Regulatory Analyses
c. Current Approach and Key Assumptions
2. Valuation of Other Emissions Reductions
V. Analytical Results
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 Sub-Group Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash Flow Analysis Results
b. Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Sub-Groups 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. 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
C. Proposed Standards
1. Benefits and Burdens of TSLs Considered for Clothes Dryers
2. Benefits and Burdens of TSLs Considered for Room Air
Conditioners
3. Summary of Benefits and Costs (Annualized) of the Standards
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Residential Clothes Dryer Industry
2. Room Air Conditioner Industry
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act
E. Review under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality Bulletin for Peer Review
M. Congressional Notification
VII. Public Participation
A. Submission of Comments
VIII. Approval of the Office of the Secretary
I. Summary of the Direct Final Rule
A. The Energy Conservation Standard Levels
The Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.;
EPCA or the Act), as amended, provides that any amended energy
conservation standard DOE prescribes for covered products, such as
residential clothes dryers (clothes dryers) and room air conditioners,
must be designed to achieve the maximum improvement in energy
efficiency that is technologically feasible and economically justified.
(42 U.S.C. 6295(o)(2)(A)) Furthermore, the amended standard must result
in a significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) In
accordance with these and other statutory provisions discussed in this
notice, DOE adopts amended energy conservation standards for clothes
dryers and room air conditioners as shown in Table I-1. The standards
apply to all products listed in Table I-1 and manufactured in, or
imported into, the United States on or after April 21, 2014.
Table I-1--Amended Energy Conservation Standards for Residential Clothes
Dryers and Room Air Conditioners
------------------------------------------------------------------------
Minimum CEF
Product class levels* lb/
kWh
------------------------------------------------------------------------
Residential Clothes Dryers
------------------------------------------------------------------------
1. Vented Electric, Standard (4.4 ft\3\ or greater 3.73
capacity)..............................................
2. Vented Electric, Compact (120 V) (less than 4.4 ft\3\ 3.61
capacity)..............................................
3. Vented Electric, Compact (240 V) (less than 4.4 ft\3\ 3.27
capacity)..............................................
4. Vented Gas........................................... 3.30
5. Ventless Electric, Compact (240 V) (less than 4.4 2.55
ft\3\ capacity)........................................
6. Ventless Electric Combination Washer/Dryer........... 2.08
------------------------------------------------------------------------
Minimum CEER
Product class levels** Btu/
Wh
------------------------------------------------------------------------
Room Air Conditioners
------------------------------------------------------------------------
1. Without reverse cycle, with louvered sides, and less 11.0
than 6,000 Btu/h.......................................
[[Page 22456]]
2. Without reverse cycle, with louvered sides, and 6,000 11.0
to 7,999 Btu/h.........................................
3. Without reverse cycle, with louvered sides, and 8,000 10.9
to 13,999 Btu/h........................................
4. Without reverse cycle, with louvered sides, and 10.7
14,000 to 19,999 Btu/h.................................
5a. Without reverse cycle, with louvered sides, and 9.4
20,000 to 24,999 Btu/h.................................
5b. Without reverse cycle, with louvered sides, and 9.0
25,000 Btu/h or more...................................
6. Without reverse cycle, without louvered sides, and 10.0
less than 6,000 Btu/h..................................
7. Without reverse cycle, without louvered sides, and 10.0
6,000 to 7,999 Btu/h...................................
8a. Without reverse cycle, without louvered sides, and 9.6
8,000 to 10,999 Btu/h..................................
8b. Without reverse cycle, without louvered sides, and 9.5
11,000 to 13,999 Btu/h.................................
9. Without reverse cycle, without louvered sides, and 9.3
14,000 to 19,999 Btu/h.................................
10. Without reverse cycle, without louvered sides, and 9.4
20,000 Btu/h or more...................................
11. With reverse cycle, with louvered sides, and less 9.8
than 20,000 Btu/h......................................
12. With reverse cycle, without louvered sides, and less 9.3
than 14,000 Btu/h......................................
13. With reverse cycle, with louvered sides, and 20,000 9.3
Btu/h or more..........................................
14. With reverse cycle, without louvered sides, and 8.7
14,000 Btu/h or more...................................
15. Casement-only....................................... 9.5
16. Casement-slider..................................... 10.4
------------------------------------------------------------------------
* CEF (Combined Energy Factor) is calculated as the clothes dryer test
load weight in pounds divided by the sum of ``active mode'' per-cycle
energy use and ``inactive mode'' per-cycle energy use in kWh.
* * CEER (Combined Energy Efficiency Ratio) is calculated as capacity
times active mode hours (equal to 750) divided by the sum of active
mode annual energy use and inactive mode.
B. Benefits and Costs to Consumers
Table I-2 presents DOE's evaluation of the economic impacts of
today's standards on consumers of clothes dryers and room air
conditioners, as measured by the average life-cycle cost (LCC) savings
and the median payback period. The average LCC savings are positive for
all product classes of clothes dryers and room air conditioners for
which consumers would be impacted by the standards.
Table I-2--Impacts of Today's Standards on Consumers of Clothes Dryers
and Room Air Conditioners
------------------------------------------------------------------------
Median
Average LCC payback
Product class savings period
(2009$) (years)
------------------------------------------------------------------------
Clothes Dryers
------------------------------------------------------------------------
Electric Standard....................... $14 5.3
Compact 120V............................ 14 0.9
Compact 240V............................ 8 0.9
Gas..................................... 2 11.7
Ventless 240V........................... * 0 * n/a
Ventless Combination Washer/Dryer....... * 0 * n/a
------------------------------------------------------------------------
Room Air Conditioners
------------------------------------------------------------------------
< 6,000 Btu/h, with Louvers............. 7 8.6
8,000-13,999 Btu/h, with Louvers........ 22 2.8
20,000-24,999 Btu/h, with Louvers....... 6 4.3
> 25,000 Btu/h, with Louvers............ 1 10.1
8,000-10,999 Btu/h, without Louvers..... 13 2.1
> 11,000 Btu/h, without Louvers......... 11 3.7
------------------------------------------------------------------------
* Because the standard level is the same as the baseline efficiency
level, no consumers are impacted and therefore calculation of a
payback period is not applicable.
C. Impact on Manufacturers
The industry net present value (INPV) is the sum of the discounted
cash flows to the industry from the base year through the end of the
analysis period (2011 to 2043). Using a real discount rate of 7.2
percent, DOE estimates that the industry net present value (INPV) for
manufacturers of clothes dryers is $1,003.6 million in 2009$. Under
today's standards, DOE expects that manufacturers may lose 6.4 to 8.0
percent of their INPV, which is $64.5 to -$80.6 million. Additionally,
based on DOE's interviews with the manufacturers of clothes dryers, DOE
does not expect any plant closings or significant loss of employment.
For room air conditioners, DOE estimates that the INPV for
manufacturers of room air conditioners is $956 million in 2009$ using a
real discount rate of 7.2 percent. Under today's standards, DOE expects
that manufacturers may lose 11.6 to 18.6 percent of their INPV, which
is $111.3 to $177.6 million. Additionally, based on DOE's interviews
with the manufacturers of room air conditioners, DOE does not expect
any plant closings or significant loss of employment.
D. National Benefits
DOE's analyses indicate that today's standards would save a
significant amount of energy over 30 years (2014-
[[Page 22457]]
2043)--an estimated 0.39 quads of cumulative energy for clothes dryers
and 0.31 quads of cumulative energy for room air conditioners. The
combined total, 0.70 quads, is equivalent to three-fourths of the
estimated amount of energy used in 2008 to dry clothes in all U.S.
homes. In addition, DOE expects the energy savings from today's
standards to eliminate the need for approximately 0.98 gigawatts (GW)
of generating capacity by 2043.
The cumulative national net present value (NPV) of total consumer
costs and savings of today's standards in 2009$ ranges from $1.08
billion (at a 7-percent discount rate) to $3.01 billion (at a 3-percent
discount rate) for clothes dryers, and from $0.57 billion (at a 7-
percent discount rate) to $1.47 billion (at a 3-percent discount rate)
for room air conditioners. This NPV expresses the estimated total value
of future operating-cost savings minus the estimated increased product
costs for products purchased in 2014-2043, discounted to 2011.
In addition, today's standards would have significant environmental
benefits. The energy savings would result in cumulative greenhouse gas
emission reductions of approximately 36.1 million metric tons (Mt) of
carbon dioxide (CO2) from 2014 to 2043. During this period,
the standards would also result in emissions reductions \1\ of
approximately 29.3 thousand tons of nitrogen oxides (NOX)
and 0.073 ton of mercury (Hg).\2\ DOE estimates that the net present
monetary value of the CO2 emissions reductions is between
$170 and $2,654 million, expressed in 2009$ and discounted to 2011. DOE
also estimates that the net present monetary value of the
NOX emissions reductions, expressed in 2009$ and discounted
to 2011, is $4.3 to $43.8 million at a 7-percent discount rate, and
$8.9 to $91.7 million at a 3-percent discount rate.\3\
---------------------------------------------------------------------------
\1\ DOE calculates emissions reductions relative to the most
recent version of the Annual Energy Outlook (AEO) Reference case
forecast. As noted in section 15.2.4 of TSD chapter 15, this
forecast accounts for regulatory emissions reductions through 2008,
including the Clean Air Interstate Rule (CAIR, 70 FR 25162 (May 12,
2005)), but not the Clean Air Mercury Rule (CAMR, 70 FR 28606 (May
18, 2005)). Subsequent regulations, including the currently proposed
CAIR replacement rule, the Clean Air Transport Rule (75 FR 45210
(Aug. 2, 2010)), do not appear in the forecast.
\2\ Results for NOX and Hg are presented in short
tons. One short ton equals 2000 lbs.
\3\ DOE is aware of multiple agency efforts to determine the
appropriate range of values used in evaluating the potential
economic benefits of reduced Hg emissions. DOE has decided to await
further guidance regarding consistent valuation and reporting of Hg
emissions before it once again monetizes Hg emissions reductions in
its rulemakings.
---------------------------------------------------------------------------
The benefits and costs of today's standards can also be expressed
in terms of annualized values. The annualized monetary values are the
sum of (1) the annualized national economic value, expressed in 2009$,
of the benefits from operating the product (consisting primarily of
operating cost savings from using less energy, minus increases in
equipment purchase costs, which is another way of representing consumer
NPV, plus (2) the monetary value of the benefits of emission
reductions, including CO2 emission reductions.\4\ The value
of the CO2 reductions is otherwise known as the Social Cost
of Carbon (SCC), and is calculated using a range of values per metric
ton of CO2 developed by a recent interagency process. The
monetary benefits of emissions reductions are reported in 2009$ so that
they can be compared with the other costs and benefits in the same
dollar units. The derivation of the SCC values is discussed in section
IV.M.
---------------------------------------------------------------------------
\4\ DOE used a two-step calculation process to convert the time-
series of costs and benefits into annualized values. First, DOE
calculated a present value in 2011, the year used for discounting
the NPV of total consumer costs and savings, for the time-series of
costs and benefits using discount rates of three and seven percent
for all costs and benefits except for the value of CO2
reductions. For the latter, DOE used a range of discount rates, as
shown in Table I.3. From the present value, DOE then calculated the
fixed annual payment over a 30-year period, starting in 2011, that
yields the same present value. The fixed annual payment is the
annualized value. Although DOE calculated annualized values, this
does not imply that the time-series of cost and benefits from which
the annualized values were determined would be a steady stream of
payments.
---------------------------------------------------------------------------
Although adding the value of consumer savings to the values of
emission reductions provides a valuable perspective, two issues should
be considered. First, the national operating cost savings are domestic
U.S. consumer monetary savings that occur as a result of market
transactions, while the value of CO2 reductions is based on
a global value. Second, the assessments of operating cost savings and
the SCC are performed with different methods that use quite different
timeframes for analysis. The national operating cost savings is
measured for the lifetime of products shipped in 2014-2043. The SCC
values, on the other hand, reflect the present value of future climate-
related impacts resulting from the emission of one metric ton of carbon
dioxide in each year. These impacts continue well beyond 2100.
Table I-3 shows the annualized values for the clothes dryer
standards. Using a 7-percent discount rate and the SCC value of $22.1/
ton in 2010 (in 2009$), the cost of the standards for clothes dryers in
today's rule is $52.3 million per year in increased equipment costs,
while the annualized benefits are $139.1 million per year in reduced
equipment operating costs, $25.0 million in CO2 reductions,
and $0.9 million in reduced NOX emissions. In this case, the
net benefit amounts to $112.7 million per year. DOE has calculated that
the annualized increased equipment cost can range from $50.5 to $66.6
million per year depending on assumptions and modeling of equipment
price trends. The high end of this range corresponds to a constant real
equipment price trend. Using the central estimate of energy-related
benefits, DOE estimates that calculated net benefits can range from
$98.4 to $114.5 million per year.
Using a 3-percent discount rate and the SCC value of $22.1/ton in
2010 (in 2009$), the cost of the standards for clothes dryers in
today's rule is $55.4 million per year in increased equipment costs,
while the benefits are $209.1 million per year in reduced operating
costs, $25.0 million in CO2 reductions, and $1.4 million in
reduced NOX emissions. In this case, the net benefit amounts
to $180.1 million per year. DOE has calculated that the annualized
increased equipment cost can range from $53.1 to $73.5 million per year
depending on assumptions and modeling of equipment price trends. The
high end of this range corresponds to a constant real equipment price
trend. Using the central estimate of energy-related benefits, DOE
estimates that calculated net benefits can range from $162.0 to $182.4
million per year.
Table I-4 shows the annualized values for the room air conditioner
standards. Using a 7-percent discount rate and the SCC value of $22.1/
ton in 2010 (in 2009$), the cost of the standards for room air
conditioners in today's rule is $107.7 million per year in increased
equipment costs, while the annualized benefits are $153.7 million per
year in reduced equipment operating costs, $19.5 million in
CO2 reductions, and $0.999 million in reduced NOX
emissions. In this case, the net benefit amounts to $66.4 million per
year.
DOE has calculated that the annualized increased equipment cost can
range from $105.7 to $136.6 million per year depending on assumptions
and modeling of equipment price trends. The high end of this range
corresponds to a constant real equipment price trend. Using the central
estimate of energy-related benefits, DOE estimates that calculated net
benefits can range from $37.5 to $68.4 million per year.
Using a 3-percent discount rate and the SCC value of $22.1/ton in
2010 (in
[[Page 22458]]
2009$), the cost of the standards for room air conditioners in today's
rule is $111.0 million per year in increased equipment costs, while the
benefits are $186.2 million per year in reduced operating costs, $19.5
million in CO2 reductions, and $1.20 million in reduced
NOX emissions. In this case, the net benefit amounts to
$95.9 million per year DOE has calculated that the range in the
annualized increased equipment cost can range from $108.0 to $146.0
million per year depending on assumptions and modeling of equipment
price trends. The high end of this range corresponds to a constant real
equipment price trend. Using the central estimate of energy-related
benefits, DOE estimates that calculated net benefits can range from
$60.9 to $98.9 million per year.
Table I-3--Annualized Benefits and Costs of Amended Standards (TSL 4) for Clothes Dryers Sold in 2014-2043
--------------------------------------------------------------------------------------------------------------------------------------------------------
Monetized (million 2009$ year)
Discount rate -----------------------------------------------------------------------------
Primary estimate * Low estimate * High estimate *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Operating Cost Savings.......................... 7% 139.1 120.6 158.3
3% 209.1 177.4 241.3
CO2 Reduction at $4.9/t **...................... 5% 6.0 6.0 6.0
CO2 Reduction at $22.1/t **..................... 3% 25.0 25.0 25.0
CO2 Reduction at $36.3/t **..................... 2.5% 39.8 39.8 39.8
CO2 Reduction at $67.1/t **..................... 3% 76.0 76.0 76.0
NOX Reduction at $2,519/ton **.................. 7% 0.9 0.9 0.9
3% 1.4 1.4 1.4
Total[dagger]............................... 7% plus CO2 range 146.1 to 216.1 127.6 to 197.6 165.3 to 235.3
7% 165.0 146.5 184.3
3% 235.4 203.7 267.6
3% plus CO2 range 216.5 to 286.5 184.8 to 254.8 248.7 to 318.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
Costs
--------------------------------------------------------------------------------------------------------------------------------------------------------
Incremental Product Costs.............. 7% 52.3 66.6 50.5
3% 55.4 73.5 53.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Net Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total[dagger]............................... 7% plus CO2 range 93.7 to 163.7 61.0 to 131.0 114.8 to 184.8
7% 112.7 79.9 133.8
3% 180.1 130.2 214.5
3% plus CO2 range 161.1 to 231.1 111.3 to 181.3 195.6 to 265.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
* The primary, low, and high estimates utilize forecasts of energy prices and housing starts from the AEO2010 Reference case, Low Economic Growth case,
and High Economic Growth case, respectively. Low estimate corresponds to the low net benefit estimate and uses the zero real price trend sensitivity
for equipment prices, and the high estimate corresponds to the high net benefit estimate and utilizes the high technological learning rate sensitivity
for the equipment price trend.
** The CO2 values represent global values (in 2009$) of the social cost of CO2 emissions in 2010 under several scenarios. The values of $4.9, $22.1, and
$36.3 per metric ton are the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The
value of $67.1 per ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. The value for NOX (in 2009$)
is the average of the low and high values used in DOE's analysis.
[dagger] Total benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 3-percent discount rate, which is
$22.1/ton in 2010 (in 2007$). In the rows labeled as ``7% plus CO2 range'' and ``3% plus CO2 range,'' the operating cost and NOX benefits are
calculated using the labeled discount rate, and those values are added to the full range of CO2 values.
Table I-4--Annualized Benefits and Costs of Amended Standards (TSL 4) for Room Air Conditioners Sold in 2014-2043
--------------------------------------------------------------------------------------------------------------------------------------------------------
Monetized (million 2009$/year)
Discount rate -----------------------------------------------------------------------------
Primary estimate * Low estimate * High estimate *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Operating Cost Savings.......................... 7% 153.7 145.1 161.9
3% 186.2 174.2 197.3
CO2 Reduction at $4.9/t **...................... 5% 5.0 5.0 5.0
CO2 Reduction at $22.1/t **..................... 3% 19.5 19.5 19.5
CO2 Reduction at $36.3/t **..................... 2.5% 30.7 30.7 30.7
CO2 Reduction at $67.1/t **..................... 3% 59.4 59.4 59.4
NOX Reduction at $2,519/ton **.................. 7% 0.999 0.999 0.999
3% 1.197 1.197 1.197
Total [dagger].............................. 7% plus CO2 range 159.6 to 214.0 151.1 to 205.5 167.9 to 222.3
7% 174.1 165.5 182.4
3% 206.8 194.9 218.0
3% plus CO2 range 192.3 to 246.7 180.4 to 234.8 203.5 to 257.9
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 22459]]
Costs
--------------------------------------------------------------------------------------------------------------------------------------------------------
Incremental Product Costs....................... 7% 107.7 136.6 105.7
3% 111.0 146.0 108.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Net Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total[dagger]........................... 7% plus CO2 range 51.9 to 106.3 43.4 to 97.8 62.2 to 116.6
7% 66.4 28.9 76.7
3% 95.9 48.9 110.0
3% plus CO2 range 81.4 to 135.8 34.4 to 88.8 95.5 to 149.9
--------------------------------------------------------------------------------------------------------------------------------------------------------
* The primary, low, and high estimates utilize forecasts of energy prices and housing starts from the AEO2010 Reference case, Low Economic Growth case,
and High Economic Growth case, respectively. Low estimate corresponds to the low net benefit estimate and uses the zero real price trend sensitivity
for equipment prices, while the high estimate corresponds to the high net benefit estimate and utilizes the high technological learning rate
sensitivity for the equipment price trend.
** The CO2 values represent global values (in 2009$) of the social cost of CO2 emissions in 2010 under several scenarios. The values of $4.9, $22.1, and
$36.3 per metric ton are the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The
value of $67.1 per ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. The value for NOX (in 2009$)
is the average of the low and high values used in DOE's analysis.
[dagger] Total benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 3-percent discount rate, which is
$22.1/ton in 2010 (in 2009$). In the rows labeled as ``7% plus CO2 range'' and ``3% plus CO2 range,'' the operating cost and NOX benefits are
calculated using the labeled discount rate, and those values are added to the full range of CO2 values.
E. Conclusion
Based on the analyses culminating in this final rule, DOE found the
benefits to the nation of the standards (energy savings, consumer LCC
savings, national NPV increase, and emission reductions) outweigh the
burdens (loss of INPV and LCC increases for some users of these
products). DOE has concluded that the standards represent the maximum
improvement in energy efficiency that is technologically feasible and
economically justified, and would result in significant conservation of
energy. DOE further notes that clothes dryers and room air conditioners
achieving these standard levels are already commercially available.
II. Introduction
A. Authority
Title III of EPCA sets forth a variety of provisions designed to
improve energy efficiency. Part B of title III (42 U.S.C. 6291-6309)
provides for the Energy Conservation Program for Consumer Products
other than Automobiles.\5\ The program covers consumer products and
certain commercial equipment (referred to hereafter as ``covered
products''), including clothes dryers and room air conditioners (42
U.S.C. 6292(a)(2) and (8)), and the Act prescribes energy conservation
standards for certain clothes dryers (42 U.S.C. 6295(g)(3)) and for
room air conditioners (42 U.S.C. 6295(c)(1)). EPCA further directs DOE
to conduct two cycles of rulemakings to determine whether to amend
these standards. (42 U.S.C. 6295(c)(2) and (g)(4)) As explained in
further detail in section II.C, ``Background,'' this rulemaking
represents the second round of amendments to both the clothes dryer and
room air conditioner standards.
---------------------------------------------------------------------------
\5\ For editorial reasons, upon codification in the U.S. Code,
Part B was re-designated Part A.
---------------------------------------------------------------------------
DOE notes that this rulemaking is one of the required agency
actions in the consolidated Consent Decree in State of New York, et al.
v. Bodman et al., 05 Civ. 7807 (LAP), and Natural Resources Defense
Council, et al. v. Bodman, et al., 05 Civ. 7808 (LAP), DOE is required
to complete a final rule for amended energy conservation standards for
room air conditioners and clothes dryers that must be sent to the
Federal Register by June 30, 2011.
Under the Act, DOE's energy conservation program for covered
products consists essentially of four parts: (1) Testing, (2) labeling,
(3) Federal energy conservation standards, and (4) certification and
enforcement procedures. The Federal Trade Commission (FTC) is
responsible for labeling, and DOE implements the remainder of the
program. The Act authorizes DOE, subject to certain criteria and
conditions, to develop test procedures to measure the energy
efficiency, energy use, or estimated annual operating cost of each
covered product. (42 U.S.C. 6293) Manufacturers of covered products
must use the DOE test procedure as the basis for certifying to DOE that
their products comply with applicable energy conservation standards
adopted under EPCA and for representing the efficiency of those
products. (42 U.S.C. 6293(c) and 6295(s)) Similarly, DOE must use these
test procedures to determine whether the products comply with standards
adopted under EPCA. Id. The test procedures for clothes dryers and room
air conditioners appear at title 10 Code of Federal Regulations (CFR)
part 430, subpart B, appendices D and F, respectively.
EPCA provides criteria for prescribing amended standards for
covered products. As indicated above, any amended standard for a
covered product must be designed to achieve the maximum improvement in
energy efficiency that is technologically feasible and economically
justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, EPCA precludes DOE
from adopting any standard that would not result in significant
conservation of energy. (42 U.S.C. 6295(o)(3)) EPCA also provides that,
in determining whether a standard is economically justified, DOE must
determine whether the benefits of the standard exceed its burdens. (42
U.S.C. 6295(o)(2)(B)(i)) DOE must do so after receiving comments on the
proposed standard and by considering, to the greatest extent
practicable, the following seven 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
[[Page 22460]]
class) compared to any increase in the price, initial charges, or
maintenance expenses for the covered products that are likely to result
from the imposition of the standard;
3. The total projected amount of energy savings likely to result
directly from the imposition of the standard;
4. Any lessening of the utility or the performance of the covered
products likely to result from the imposition of the standard;
5. The impact of any lessening of competition, as determined in
writing by the Attorney General, that is likely to result from the
imposition of the standard;
6. The need for national energy conservation; and
7. Other factors the Secretary considers relevant. (42 U.S.C.
6295(o)(2)(B)(i)(I)-(VII))
The Energy Independence and Security Act of 2007 (EISA 2007; Public
Law 110-140) amended EPCA, in relevant part, to grant DOE authority to
issue a final rule (hereinafter referred to as a ``direct final rule'')
establishing an energy conservation standard on receipt of a statement
submitted jointly by interested persons that are fairly representative
of relevant points of view (including representatives of manufacturers
of covered products, States, and efficiency advocates) as determined by
the Secretary, that contains recommendations with respect to an energy
conservation standard that are in accordance with the provisions of 42
U.S.C. 6295(o). A notice of proposed rulemaking (NOPR) that proposes an
identical energy efficiency standard must be published simultaneously
with the final rule, and DOE must provide a public comment period of at
least 110 days on this proposal. 42 U.S.C. 6295(p)(4). Not later than
120 days after issuance of the direct final rule, if one or more
adverse comments or an alternative joint recommendation are received
relating to the direct final rule, the Secretary must determine whether
the comments or alternative recommendation may provide a reasonable
basis for withdrawal under 42 U.S.C. 6295(o) or other applicable law.
If the Secretary makes such a determination, DOE must withdraw the
direct final rule and proceed with the simultaneously published notice
of proposed rulemaking. DOE must publish in the Federal Register the
reason why the direct final rule was withdrawn. Id.
The Consent Decree in State of New York, et al. v. Bodman et al.,
described above, defines a ``final rule'' to have the same meaning as
in 42 U.S.C. 6295(p)(4) and defines ``final action'' as a final
decision by DOE. As this direct final rule is issued under authority at
42 U.S.C. 6295(p)(4) and constitutes a final decision by DOE which
becomes legally effective 120 days after issuance, absent an adverse
comment that leads the Secretary to withdraw the direct final rule, DOE
asserts that issuance of this direct final rule on or before the date
required by the court constitutes compliance with the Consent Decree in
State of New York, et al. v. Bodman et al.
Furthermore, EPCA contains what is commonly known as an ``anti-
backsliding'' provision, which mandates that the Secretary not
prescribe 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 a new standard if interested persons have
established by a preponderance of the evidence that the standard is
likely to result in the unavailability in the United States of any
covered product type (or class) with performance characteristics,
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))
EPCA also 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 requires DOE to specify a different standard level than that
which applies generally to a type or class of products for any group of
covered products that have the same function or intended use if DOE
determines that products within such group (A) consume a different kind
of energy from that consumed by other covered products within such type
(or class); or (B) have a capacity or other performance-related feature
which other products within such type (or class) do not have and such
feature justifies a higher or lower standard. (42 U.S.C. 6295(q)(1)) In
determining whether a performance-related feature justifies such a
different standard for a group of products, DOE must consider such
factors as the utility to the consumer of the feature and other factors
DOE deems appropriate. Id. Any rule prescribing such a standard must
include an explanation of the basis on which such higher or lower level
was established. (42 U.S.C. 6295(q)(2))
Federal energy conservation requirements for covered products
generally supersede state laws or regulations concerning energy
conservation testing, labeling, and standards. (42 U.S.C. 6297 (a)-(c))
DOE can, however, grant waivers of Federal preemption for particular
state laws or regulations, in accordance with the procedures and other
provisions of section 327(d) of the Act. (42 U.S.C. 6297(d))
EPCA also requires that energy conservation standards address
standby mode and off mode energy use. Specifically, when DOE adopts a
standard for a covered product after July 1, 2010 it must, if justified
by the criteria for adoption of standards in section 325(o) of EPCA,
incorporate standby mode and off mode energy use into the standard, if
feasible, or adopt a separate standard for such energy use for that
product. (42 U.S.C. 6295(gg)) As set forth below, the standards for
clothes dryers and room air conditioners at 10 CFR 430.32 (h) and (b)
are minimum energy factors (EF) and minimum energy efficiency ratios
(EER), respectively. Neither of these metrics incorporates standby or
off mode energy use, with the limited exception that the EF in appendix
D addresses the energy use of pilot lights in gas clothes dryers. (DOE
notes that standing pilot lights were prohibited by EPCA for products
manufactured after January 1, 1988. As a result, the final amended test
procedure, published on January 6, 2011, eliminates measurement of the
energy use of such pilot lights. Similarly, DOE does not incorporate
the energy use of pilot lights in the metric for gas clothes dryers
established in this final rule.) By contrast, the standard levels DOE
considered in this direct final rule are expressed in terms of the
``combined energy factor'' (CEF) for clothes dryers and the ``combined
energy efficiency ratio'' (CEER) for room air conditioners, and each of
these metrics incorporates energy use in all modes, including the
standby and off modes. DOE uses these metrics in the standards it
adopts in this direct final rule.
DOE has also reviewed this regulation pursuant to Executive Order
13563, issued on January 18, 2011 (76 FR 3281, Jan. 21, 2011). EO 13563
is supplemental to and explicitly reaffirms the principles, structures,
and definitions governing regulatory review established in Executive
Order 12866. To the extent permitted by law, agencies are required by
Executive Order 13563 to: (1) Propose or adopt a regulation
[[Page 22461]]
only upon a reasoned determination that its benefits justify its costs
(recognizing that some benefits and costs are difficult to quantify);
(2) tailor regulations to impose the least burden on society,
consistent with obtaining regulatory objectives, taking into account,
among other things, and to the extent practicable, the costs of
cumulative regulations; (3) select, in choosing among alternative
regulatory approaches, those approaches that maximize net benefits
(including potential economic, environmental, public health and safety,
and other advantages; distributive impacts; and equity); (4) to the
extent feasible, specify performance objectives, rather than specifying
the behavior or manner of compliance that regulated entities must
adopt; and (5) identify and assess available alternatives to direct
regulation, including providing economic incentives to encourage the
desired behavior, such as user fees or marketable permits, or providing
information upon which choices can be made by the public.
We emphasize as well that Executive Order 13563 requires agencies
``to use the best available techniques to quantify anticipated present
and future benefits and costs as accurately as possible.'' In its
guidance, the Office of Information and Regulatory Affairs has
emphasized that such techniques may include ``identifying changing
future compliance costs that might result from technological innovation
or anticipated behavioral changes.'' For the reasons stated in the
preamble, DOE believes that today's direct final rule is consistent
with these principles, including that, to the extent permitted by law,
agencies adopt a regulation only upon a reasoned determination that its
benefits justify its costs and select, in choosing among alternative
regulatory approaches, those approaches that maximize net benefits.
Consistent with EO 13563, and the range of impacts analyzed in this
rulemaking, the energy efficiency standard adopted herein by DOE
achieves maximum net benefits.
B. Background
1. Current Standards
In a final rule published on May 14, 1991, DOE prescribed the
current Federal energy conservation standards for clothes dryers
manufactured on or after May 14, 1994. 56 FR 22250. This rule completed
the first of the two rulemakings required under 42 U.S.C. 6295(g)(4) to
consider amending the standards for clothes dryers. The current
standards consist of four minimum EFs, expressed in pounds of clothing
load (lb) per kilowatt-hour (kWh), one for gas dryers and one each for
three different types of electric dryers. 10 CFR 430.32(h). These
standards are set forth in Table II.1 below.
Table II.1--Residential Clothes Dryer Current Energy Conservation
Standards
------------------------------------------------------------------------
Product class EF lb/kWh
------------------------------------------------------------------------
Electric, Standard (4.4 cubic feet (ft\3\) or greater 3.01
capacity).................................................
Electric, Compact (120 V) (less than 4.4 ft\3\ capacity)... 3.13
Electric, Compact (240 V) (less than 4.4 ft\3\ capacity)... 2.90
Gas........................................................ 2.67
------------------------------------------------------------------------
In a final rule published on September 24, 1997, DOE prescribed the
current Federal energy conservation standards for room air conditioners
manufactured on or after October 1, 2000. 62 FR 50122. This rule
completed the first of the two rulemakings required under 42 U.S.C.
6295(c)(2) to consider amending the standards for room air
conditioners. The current standards consist of minimum EERs, expressed
as cooling capacity in British thermal units (Btu) per hour (h) divided
by electrical input power in watts (W), that vary depending on the size
of the room air conditioner, whether it has louvered sides and a
heating cycle, and whether it is for casement installations. 10 CFR
430.32(b). These standards are set forth in Table II.2 below.
Table II.2--Room Air Conditioner Current Energy Conservation Standards
------------------------------------------------------------------------
Product class EER Btu/Wh
------------------------------------------------------------------------
Without reverse cycle, with louvered sides, and less than 9.7
6,000 Btu/h...............................................
Without reverse cycle, with louvered sides, and 6,000 to 9.7
7,999 Btu/h...............................................
Without reverse cycle, with louvered sides, and 8,000 to 9.8
13,999 Btu/h..............................................
Without reverse cycle, with louvered sides, and 14,000 to 9.7
19,999 Btu/h..............................................
Without reverse cycle, with louvered sides, and 20,000 Btu/ 8.5
h or more.................................................
Without reverse cycle, without louvered sides, and less 9.0
than 6,000 Btu/h..........................................
Without reverse cycle, without louvered sides, and 6,000 to 9.0
7,999 Btu/h...............................................
Without reverse cycle, without louvered sides, and 8,000 to 8.5
13,999 Btu/h..............................................
Without reverse cycle, without louvered sides, and 14,000 8.5
to 19,999 Btu/h...........................................
Without reverse cycle, without louvered sides, and 20,000 8.5
Btu/h or more.............................................
With reverse cycle, with louvered sides, and less than 9.0
20,000 Btu/h..............................................
With reverse cycle, without louvered sides, and less than 8.5
14,000 Btu/h..............................................
With reverse cycle, with louvered sides, and 20,000 Btu/h 8.5
or more...................................................
With reverse cycle, without louvered sides, and 14,000 Btu/ 8.0
h or more.................................................
Casement-Only.............................................. 8.7
Casement-Slider............................................ 9.5
------------------------------------------------------------------------
[[Page 22462]]
2. History of Standards Rulemaking for Residential Clothes Dryers and
Room Air Conditioners
EPCA prescribes energy conservation standards for clothes dryers
and for room air conditioners, consisting of a requirement that gas
clothes dryers manufactured after January 1, 1988 not be equipped with
constant burning pilots and performance standards (minimum EER levels)
for room air conditioners. (42 U.S.C. 6295(c)(1) and (g)(3)) These
amendments also required, for both products, that DOE conduct two
cycles of rulemakings to determine whether to amend these standards.
(42 U.S.C. 6295(c)(2) and (g)(4)) As indicated above, DOE completed the
first of these rulemaking cycles for clothes dryers in 1991, by
adopting performance standards for gas and electric products. DOE
completed the first of these rulemaking cycles for room air
conditioners in 1997 by adopting amended minimum EER levels.
DOE initiated this rulemaking on October 9, 2007 by publishing a
notice announcing the availability of the framework document, the
``Energy Conservation Standards Rulemaking Framework Document for
Residential Clothes Dryers and Room Air Conditioners.'' In this notice,
DOE also announced a public meeting and requested public comment on the
matters raised in the framework document. 72 FR 57254 (October 9,
2007). The framework document describes the procedural and analytical
approaches that DOE anticipated using to evaluate energy conservation
standards for clothes dryers and room air conditioners, and identified
various issues to be resolved in conducting this rulemaking. The
framework document is available at https://www1.eere.energy.gov/buildings/appliance_standards/.
DOE held the public meeting on October 24, 2007 to present the
contents of the framework document, describe the analyses it planned to
conduct during the rulemaking, seek comments from interested parties on
these subjects, and, in general, inform interested parties about, and
facilitate their involvement in, the rulemaking. Interested parties
discussed the following major issues at the public meeting: test
procedure revisions; product classes; technology options; approaches to
the engineering, life-cycle cost, payback period and national impact
analyses; efficiency levels analyzed in the engineering analysis; and
the approach for estimating typical energy consumption. At the meeting
and during the period for commenting on the framework document, DOE
received many comments that helped it identify and resolve issues
involved in this rulemaking.
DOE then gathered additional information and performed preliminary
analyses to help develop potential energy conservation standards for
clothes dryers and room air conditioners. This process culminated in
DOE's announcement of the availability of its preliminary technical
support document (preliminary TSD) and another public meeting to
discuss and receive comments on the following matters: the product
classes DOE planned to analyze; the analytical framework, models, and
tools that DOE was using to evaluate standards; the results of the
preliminary analyses performed by DOE; and potential standard levels
that DOE could consider. 75 FR 7987 (Feb. 23, 2010) (the February 2010
notice). DOE also invited written comments on the preliminary analysis.
Id. (The preliminary TSD is available at https://www1.eere.energy.gov/buildings/appliance_standards/residential/preliminary_analysis_tsd.html.) DOE also stated its interest in receiving views concerning
other relevant issues that participants believe would affect energy
conservation standards for clothes dryers or room air condit